Text

Enclosure 2: Browns Ferry Nuclear Plant Subsequent License Renewal Application Appendix E, Applicants Environmental Report-Operating License Renewal Stage
	ML24023A476
Person / Time
Site:	Browns Ferry
Issue date:	01/19/2024
From:	; Tennessee Valley Authority
To:	; Office of Nuclear Reactor Regulation
References
	CNL-24-001
	Download: ML24023A476 (1)
	v • d • e

{{#Wiki_filter:ENCLOSURE 2 Browns Ferry Nuclear Plant Subsequent License Renewal Application Appendix E, Applicants Environmental Report-Operating License Renewal Stage

Appendix E - Environmental Report-Operating License Renewal Stage Environmental Report-Operating License Renewal Stage

Appendix E - Applicants Environmental Report-Operating License Renewal Stage TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT UNITS 1, 2, AND 3 SUBSEQUENT LICENSE RENEWAL ENVIRONMENTAL REPORT

Appendix E - Applicants Environmental Report-Operating License Renewal Stage TABLE OF CONTENTS CHAPTER 1 - INTRODUCTION ............................................................................................ E1-1 1.1. Purpose of and Need for Action ...................................................................... E1-1 1.2. Environmental Report Scope and Methodology .............................................. E1-1 1.3. BFN Licensee and Ownership ......................................................................... E1-4 1.4. References ...................................................................................................... E1-5 CHAPTER 2 - PROPOSED ACTION AND DESCRIPTION OF ALTERNATIVES................ E2-1 2.1. The Proposed Action ....................................................................................... E2-1 2.2. General Plant Information ............................................................................... E2-1 2.2.1. Reactor and Containment Systems ..................................................... E2-2 2.2.2. Fuel Enrichment, Burn-Up, and Independent Spent Fuel Storage Installation............................................................................................ E2-3 2.2.3. Cooling and Auxiliary Water Systems.................................................. E2-3 2.2.3.1. Condenser Circulating Water System .................................. E2-3 2.2.3.2. Residual Heat Removal Service Water System ................... E2-5 2.2.4. Radioactive Waste Management Systems .......................................... E2-5 2.2.4.1. Liquid Radioactive Waste Control System ........................... E2-5 2.2.4.2. Gaseous Radioactive Waste Management Systems ........... E2-6 2.2.4.3. Solid Radioactive Waste Management Systems .................. E2-7 2.2.4.4. Spent Nuclear Fuel............................................................... E2-8 2.2.4.5. Low-Level Radioactive Waste .............................................. E2-8 2.2.5. Non-Radioactive Waste Management ................................................. E2-9 2.2.5.1. General Plant Trash ............................................................. E2-9 2.2.5.2. Construction/Demolition Debris ............................................ E2-9 2.2.5.3. Hazardous Waste ............................................................... E2-10 2.2.6. Power Transmission System ............................................................. E2-10 2.2.6.1. In-Scope Transmission Lines ............................................. E2-10 2.2.6.2. Vegetation Management Practices .................................... E2-11 2.2.6.3. Public.................................................................................. E2-12 2.2.6.4. Plant Workers ..................................................................... E2-12 2.3. Refurbishment Activities ................................................................................ E2-16 2.4. Programs and Activities for Managing the Effects of Aging........................... E2-16 2.5. Employment .................................................................................................. E2-16 2.6. Alternatives to the Proposed Action .............................................................. E2-17 2.7. References .................................................................................................... E2-18 CHAPTER 3 - AFFECTED ENVIRONMENT ......................................................................... E3-1 3.1. Land Use and Visual Resources ..................................................................... E3-4 3.1.1. Offsite Land Use .................................................................................. E3-4 3.1.2. Onsite Land Use .................................................................................. E3-6 3.1.3. Visual Resources ................................................................................. E3-6 3.2. Meteorology, Air Quality, Greenhouse Gases, and Climate Change ............ E3-12 3.2.1. Meteorology ....................................................................................... E3-12 3.2.2. Criteria and Hazardous Pollutants ..................................................... E3-13 3.2.3. Permitting........................................................................................... E3-14 3.2.4. Greenhouse Gases............................................................................ E3-14 3.2.5. Climate Change ................................................................................. E3-15 3.2.5.1. Temperature Trends ........................................................... E3-16 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E-i

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 3.2.5.2. Precipitation Trends ........................................................... E3-16 3.2.5.3. Acute Weather Trends ....................................................... E3-16 3.2.6. Browns Ferry Emission Sources and Permits ................................... E3-17 3.3. Noise ............................................................................................................. E3-17 3.4. Geologic Environment ................................................................................... E3-18 3.4.1. Geology ............................................................................................. E3-18 3.4.1.1. Seismicity ........................................................................... E3-19 3.4.2. Soils ................................................................................................... E3-26 3.5. Water Resources ........................................................................................... E3-26 3.5.1. Surface Water Resources.................................................................. E3-26 3.5.1.1. Surface Water Hydrology ................................................... E3-26 3.5.1.2. Surface Water Use ............................................................. E3-29 3.5.1.3. Surface Water Quality ........................................................ E3-31 3.5.2. Groundwater Resources .................................................................... E3-33 3.5.2.1. Groundwater Hydrology ..................................................... E3-33 3.5.2.2. Groundwater Use ............................................................... E3-35 3.5.2.3. Groundwater Quality .......................................................... E3-35 3.6. Ecological Resources .................................................................................... E3-43 3.6.1. Terrestrial and Wetland Communities ............................................... E3-43 3.6.1.1. Community Characteristics ................................................ E3-43 3.6.1.2. Wetlands ............................................................................ E3-45 3.6.1.3. Invasive/Non-Native Terrestrial Species ............................ E3-47 3.6.1.4. Special-Status Terrestrial Species ..................................... E3-48 3.6.2. Aquatic Communities ......................................................................... E3-51 3.6.2.1. Physical Characteristics and Water Quality of Wheeler Reservoir ............................................................................ E3-51 3.6.2.2. Community Characteristics ................................................ E3-51 3.6.2.3. Invasive/Non-Native Aquatic Species ................................ E3-53 3.6.2.4. Special-Status Aquatic Species ......................................... E3-54 3.7. Historic and Cultural Resources .................................................................... E3-63 3.7.1. NRHP and Alabama Register of Landmarks and Heritage Properties .......................................................................................... E3-64 3.7.2. Archaeological Resources ................................................................. E3-65 3.7.3. Historic Resources............................................................................. E3-66 3.7.4. Cemeteries ........................................................................................ E3-67 3.8. Socioeconomics ............................................................................................ E3-67 3.8.1. Demography ...................................................................................... E3-67 3.8.2. Transportation.................................................................................... E3-72 3.8.3. Recreation ......................................................................................... E3-72 3.9. Human Health ............................................................................................... E3-82 3.9.1. Radiological Hazards ......................................................................... E3-82 3.9.2. Microbiological Hazards..................................................................... E3-82 3.9.3. Electric Shock Hazards...................................................................... E3-84 3.10. Environmental Justice ................................................................................... E3-84 3.10.1. Minority Populations .......................................................................... E3-84 3.10.2. Low-Income Populations ................................................................... E3-85 3.10.3. Subsistence-Like Populations and Migrant Workers ......................... E3-86 3.11. Waste Management ...................................................................................... E3-92 3.12. References .................................................................................................... E3-92 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E-ii

Appendix E - Applicants Environmental Report-Operating License Renewal Stage CHAPTER 4 - ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION AND MITIGATING ACTIONS ..................................................................................... E4-1 4.1. Land Use and Visual Resources ..................................................................... E4-3 4.1.1. Onsite Land Use .................................................................................. E4-3 4.1.2. Offsite Land Use .................................................................................. E4-4 4.1.3. Offsite Land Use in Transmission ROWs ............................................ E4-4 4.1.4. Aesthetic Impacts ................................................................................ E4-4 4.2. Air Quality ........................................................................................................ E4-5 4.2.1. Air Quality Impacts (All Plants) ............................................................ E4-5 4.2.2. Air Quality Effects of Transmission Lines ............................................ E4-6 4.3. Noise ............................................................................................................... E4-7 4.4. Geology and Soils ........................................................................................... E4-7 4.5. Water Resources ............................................................................................. E4-9 4.5.1. Surface Water Resources.................................................................... E4-9 4.5.1.1. Surface Water Use and Quality (Non-Cooling System) ..... E4-10 4.5.1.2. Altered Current Patterns at Intake and Discharge Structures ........................................................................... E4-12 4.5.1.3. Altered Salinity Gradients ................................................... E4-12 4.5.1.4. Altered Thermal Stratification of Lakes .............................. E4-12 4.5.1.5. Scouring Caused by Discharged Cooling Water ................ E4-13 4.5.1.6. Discharge of Metals in Cooling System Effluent ................ E4-13 4.5.1.7. Discharge of Biocides, Sanitary Wastes, and Minor Chemical Spills ................................................................... E4-14 4.5.1.8. Surface Water Use Conflicts (Plants with Once-Through Cooling Systems) ............................................................... E4-14 4.5.1.9. Surface Water Use Conflicts (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River) ...... E4-16 4.5.1.10. Effects of Dredging on Surface Water Quality .................... E4-16 4.5.1.11. Temperature Effects on Sediment Transport Capacity ...... E4-17 4.5.2. Groundwater Resources .................................................................... E4-17 4.5.2.1. Groundwater Contamination (Non-Cooling System Impacts).............................................................................. E4-19 4.5.2.2. Groundwater Use Conflicts (Plants that Withdraw less than 100 GPM) ................................................................... E4-19 4.5.2.3. Groundwater Use Conflicts (Plants that Withdraw greater than 100 GPM) ................................................................... E4-19 4.5.2.4. Groundwater Use Conflicts (Plants with Closed Cycle Cooling Systems that Withdraw Makeup Water from a River) .................................................................................. E4-20 4.5.2.5. Groundwater Quality Degradation Resulting from Water Withdrawals ........................................................................ E4-20 4.5.2.6. Groundwater Quality Degradation (Plants with Cooling Ponds in Salt Marshes) ...................................................... E4-20 4.5.2.7. Groundwater Quality Degradation (Plants with Cooling Ponds at Inland Sites) ........................................................ E4-21 4.5.2.8. Radionuclides Released to Groundwater ........................... E4-21 4.6. Ecological Resources .................................................................................... E4-22 4.6.1. Terrestrial Resources ........................................................................ E4-22 4.6.1.1. Effects on Terrestrial Resources (Non-Cooling System Impacts).............................................................................. E4-23 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E-iii

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.6.1.2. Exposure of Terrestrial Organisms to Radionuclides ......... E4-24 4.6.1.3. Cooling Tower Impacts on Terrestrial Resources (Plants with Once-Through Cooling Systems or Cooling Ponds) ... E4-24 4.6.1.4. Cooling Tower Impacts on Vegetation (Plants with Cooling Towers) ................................................................. E4-25 4.6.1.5. Bird Collisions with Plant Structures and Transmission Lines ................................................................................... E4-25 4.6.1.6. Water Use Conflicts with Terrestrial Resources (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River) ............................................................ E4-26 4.6.1.7. Transmission Line ROW Management Impacts on Terrestrial Resources ......................................................... E4-26 4.6.1.8. EMFs Impacts on Flora and Fauna (Plants, Agricultural Crops, Honeybees, Wildlife, Livestock) .............................. E4-26 4.6.2. Aquatic Resources............................................................................. E4-27 4.6.2.1. Impingement and Entrainment of Aquatic Organisms (Plants with Once-Through Cooling Systems or Cooling Ponds) ................................................................................ E4-29 4.6.2.2. Impingement and Entrainment of Aquatic Organisms (Plants with Cooling Towers) .............................................. E4-32 4.6.2.3. Entrainment of Phytoplankton and Zooplankton ................ E4-33 4.6.2.4. Thermal Impacts on Aquatic Organisms (Plants with Once-Through Cooling Systems or Cooling Ponds) .......... E4-33 4.6.2.5. Thermal impacts on Aquatic Organisms (Plants with Cooling Towers) ................................................................. E4-34 4.6.2.6. Infrequently Reported Thermal Impacts ............................. E4-34 4.6.2.7. Effects of Cooling Water Discharge on Dissolved Oxygen, Gas Supersaturation, and Eutrophication ............ E4-35 4.6.2.8. Effects of Non-radiological Contaminants on Aquatic Organisms .......................................................................... E4-36 4.6.2.9. Exposure of Aquatic Organisms to Radionuclides ............. E4-36 4.6.2.10. Effects of Dredging on Aquatic Resources ......................... E4-37 4.6.2.11. Water Use Conflicts with Aquatic Resources (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River) ....................................................................... E4-38 4.6.2.12. Effects on Aquatic Resources (Non-Cooling System Impacts).............................................................................. E4-39 4.6.2.13. Impacts of Transmission Line ROW Management on Aquatic Resources ............................................................. E4-40 4.6.2.14. Losses from Predation, Parasitism, and Disease Among Organisms Exposed to Sub-Lethal Stresses ...................... E4-40 4.6.3. Special Status Species and Habitats ................................................. E4-40 4.7. Historic and Cultural Resources .................................................................... E4-43 4.8. Socioeconomics ............................................................................................ E4-44 4.8.1. Employment, Income, Recreation, and Tourism................................ E4-45 4.8.2. Tax Revenues.................................................................................... E4-45 4.8.3. Community Service and Education.................................................... E4-46 4.8.4. Population and Housing..................................................................... E4-46 4.8.5. Transportation.................................................................................... E4-46 4.9. Human Health ............................................................................................... E4-47 4.9.1. Radiation Exposures to the Public ..................................................... E4-48 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E-iv

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.9.2. Radiation Exposures to Plant Workers .............................................. E4-49 4.9.3. Human Health Impact from Chemicals .............................................. E4-50 4.9.4. Microbiological Hazards to the Public (Plants with Cooling Ponds or Canals or Cooling Towers that Discharge to a River) ................... E4-50 4.9.5. Microbiological Hazards to Plant Workers ......................................... E4-52 4.9.6. Chronic Effects of EMFs .................................................................... E4-52 4.9.7. Physical Occupational Hazards ......................................................... E4-53 4.9.8. Electric Shock Hazards...................................................................... E4-53 4.10. Postulated Accidents ..................................................................................... E4-54 4.10.1. Design Basis Accidents ..................................................................... E4-54 4.10.2. Severe Accidents ............................................................................... E4-55 4.10.2.1. Probability-Weighted Consequences of Severe Accidents Are Small ........................................................... E4-55 4.10.2.2. Consideration of SAMAs Is Not Required For BFN ............ E4-65 4.11. Environmental Justice ................................................................................... E4-74 4.12. Waste Management ...................................................................................... E4-74 4.12.1. Low-Level Waste Storage and Disposal ............................................ E4-76 4.12.2. Onsite Storage of Spent Nuclear Fuel ............................................... E4-77 4.12.3. Offsite Radiological Impacts of Spent Nuclear Fuel and High-Level Waste Disposal................................................................ E4-78 4.12.4. Mixed Waste Storage and Disposal................................................... E4-78 4.12.5. Nonradioactive Waste Storage and Disposal .................................... E4-79 4.13. Climate Change ............................................................................................. E4-81 4.13.1. Greenhouse Gas Impacts on Climate Change .................................. E4-81 4.13.2. Effects of Climate Change on Environmental Resources .................. E4-81 4.13.2.1. Temperature and Precipitation Effects ............................... E4-82 4.13.2.2. Acute Weather Effects ........................................................ E4-83 4.13.2.3. Public Health Effects .......................................................... E4-83 4.13.2.4. Environmental Justice Effects ............................................ E4-84 4.14. Cumulative Impacts ....................................................................................... E4-85 4.14.1. Land Use and Visual Resources ....................................................... E4-87 4.14.2. Meteorology and Air Quality .............................................................. E4-87 4.14.3. Noise ................................................................................................. E4-87 4.14.4. Geology and Soils.............................................................................. E4-87 4.14.5. Water Resources ............................................................................... E4-87 4.14.5.1. Surface Water Use ............................................................. E4-87 4.14.5.2. Groundwater Use ............................................................... E4-88 4.14.5.3. Groundwater Quality .......................................................... E4-88 4.14.6. Ecological Resources ........................................................................ E4-88 4.14.6.1. Terrestrial Resources ......................................................... E4-88 4.14.6.2. Aquatic Resources ............................................................. E4-89 4.14.6.3. Special Status Species and Habitats ................................. E4-90 4.14.7. Historic and Cultural Resources ........................................................ E4-91 4.14.8. Socioeconomics................................................................................. E4-91 4.14.9. Human Health .................................................................................... E4-92 4.14.9.1. Non-Radiological Health Impacts ....................................... E4-92 4.14.9.2. Radiological Health Impacts ............................................... E4-92 4.14.10. Environmental Justice..................................................................... E4-92 4.14.11. Waste Management and Pollution Prevention................................ E4-92 4.15. Uranium Fuel Cycle ....................................................................................... E4-93 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E-v

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.15.1. Offsite Radiological Impacts Individual Impacts From Other Than the Disposal of Spent Fuel and High-Level Waste ............................ E4-93 4.15.2. Offsite Radiological Impacts Collective Impacts From Other Than the Disposal of Spent Fuel and High-Level Waste ............................ E4-94 4.15.3. Non-Radiological Impacts of the Uranium Fuel Cycle ....................... E4-94 4.15.4. Transportation.................................................................................... E4-95 4.16. Termination of Nuclear Plant Operations and Decommissioning .................. E4-96 4.17. References .................................................................................................... E4-97 CHAPTER 5 - ASSESSMENT OF NEW AND SIGNIFICANT INFORMATION .................... E5-1 5.1. New and Significant Information ...................................................................... E5-1 5.2. New and Significant Information Review Process ........................................... E5-2 5.3. References ...................................................................................................... E5-4 CHAPTER 6 -

SUMMARY

OF LICENSE RENEWAL IMPACTS AND MITIGATING ACTIONS .................................................................................................................... E6-1 6.1. License Renewal Impacts ............................................................................... E6-1 6.2. Mitigation ......................................................................................................... E6-6 6.3. Unavoidable Adverse Impacts ......................................................................... E6-6 6.4. Irreversible or Irretrievable Resource Commitments ....................................... E6-7 6.5. Short-Term Use Versus Long-Term Productivity of the Environment ............. E6-7 6.6. References ...................................................................................................... E6-8 CHAPTER 7 - ALTERNATIVES TO THE PROPOSED ACTION .......................................... E7-1 7.1. No-Action Alternative ....................................................................................... E7-1 7.1.1. Replacement Power ............................................................................ E7-1 7.2. Energy Alternatives that Meet System Generating Needs .............................. E7-3 7.2.1. Energy Alternatives Considered as Reasonable - Construction of New Generating Assets ....................................................................... E7-4 7.2.1.1. Natural Gas-Fired Combined Cycle Generation ................... E7-5 7.2.1.2. Natural Gas-Fired Combustion Turbine Generation ............. E7-5 7.2.1.3. Solar (with and without storage) ........................................... E7-6 7.2.1.4. Storage (Battery Energy) ...................................................... E7-7 7.2.1.5. New Nuclear - Small Modular Reactors .............................. E7-8 7.2.2. Energy Alternatives Not Considered Reasonable ............................... E7-8 7.2.2.1. Alternatives Requiring New Generating Capacity ................ E7-8 7.2.2.2. Alternatives Not Requiring New Generating Capacity ........ E7-13 7.2.3. Environmental Impacts of Alternatives .............................................. E7-14 7.2.3.1. Combination of Natural Gas-Fired Combined Cycle, Natural-Gas Fired Combustion Turbine, Solar, Storage, and SMR Generation.......................................................... E7-15 7.2.4. Summary ........................................................................................... E7-26 7.3. Alternatives for Reducing Adverse Impacts................................................... E7-26 7.4. References .................................................................................................... E7-27 CHAPTER 8 - COMPARISON OF ENVIRONMENTAL IMPACT OF SUBSEQUENT LICENSE RENEWAL TO THE ALTERNATIVES ....................................................... E8-1 8.1. References ...................................................................................................... E8-7 CHAPTER 9 - STATUS OF COMPLIANCE .......................................................................... E9-1 9.1. Proposed Action .............................................................................................. E9-1 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E-vi

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 9.1.1. General ................................................................................................ E9-1 9.1.2. Endangered Species Act ..................................................................... E9-1 9.1.3. Bald and Golden Eagle Protection Act ................................................ E9-1 9.1.4. Migratory Bird Treaty Act ..................................................................... E9-2 9.1.5. Clean Air Act ........................................................................................ E9-2 9.1.6. National Historic and Preservation Act ................................................ E9-2 9.1.7. Clean Water Act................................................................................... E9-2 9.1.7.1. Water Quality (401) Certification .......................................... E9-2 9.1.7.2. Section 404 Permit ............................................................... E9-3 9.1.8. Rivers and Harbor Act of 1899 ............................................................ E9-3 9.1.9. Coastal Zone Management Program................................................... E9-3 9.2. Alternatives ...................................................................................................... E9-7 9.3. References ...................................................................................................... E9-7 ATTACHMENTS National Pollutant Discharge Elimination System (NPDES) Permit TVA Bat Strategy Agency Correspondence LIST OF TABLES Table 1.2-1. Correspondence between License Renewal Regulatory Requirements and Environmental Report Sections ....................................................................... E1-3 Table 3.1-1. NLCD Land Cover Within a 6-Mile Radius of BFN Property Boundary .............. E3-9 Table 3.1-2. NLCD Land Cover Within the BFN Property Boundary1 ..................................... E3-9 Table 3.4-1. Agricultural Soil Characterization Details .......................................................... E3-21 Table 3.5-1. Summary of Streams and Drainage Features .................................................. E3-37 Table 3.5-2. Summary of Historical Releases at BFN .......................................................... E3-38 Table 3.8-1. Nation, State, and County Population: 2000-2020 ........................................... E3-74 Table 3.8-2. Nation, State, and County Population: 2020-2040 ........................................... E3-74 Table 3.8-3. Counties Where BFN Workers Reside ............................................................. E3-75 Table 3.8-4. BFN Worker Residence by City and County ..................................................... E3-75 Table 3.8-5. Housing Units and Housing Units Vacant (Available) by County - 2000, 2010 and 2020 .............................................................................................. E3-76 Table 3.8-6. Employment and Industry Sectors, 2010 - 2020 .............................................. E3-77 Table 3.10-1. Minority and Low-Income Populations Within 50-mile Radius ........................ E3-87 Table 4.1-1. Land Use and Visual Resource Issues and the NRC 2013 GEIS Findings ........ E4-3 Table 4.2-1. Air Quality Issues and the NRC 2013 GEIS Findings ......................................... E4-5 Table 4.2-2. BFN Annual Emissions (tons per year) ............................................................... E4-6 Table 4.3-1. Noise Issues and the NRC 2013 GEIS Findings ................................................ E4-7 Table 4.4-1. Geology and Soil Issues and the NRC 2013 GEIS Findings .............................. E4-7 Table 4.5-1. Surface Water Issues and the NRC 2013 GEIS Findings .................................. E4-9 Table 4.5-2. Groundwater Issues and the NRC 2013 GEIS Findings ................................... E4-18 Table 4.6-1. Terrestrial Ecology Issues and the NRC 2013 GEIS Findings.......................... E4-22 Table 4.6-2. Aquatic Resource Issues and the NRC 2013 GEIS Findings ........................... E4-27 Table 4.6-3. Special Status Species and Habitat Issues and the NRC 2013 GEIS Findings ......................................................................................................... E4-41 Table 4.7-1. Historic and Cultural Resource Issues and the NRC 2013 GEIS Findings ....... E4-43 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E-vii

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 4.8-1. Socioeconomic Issues and the NRC 2013 GEIS Findings ............................... E4-44 Table 4.9-1. Human Health Issues and the NRC 2013 GEIS Findings................................. E4-47 Table 4.10-1. Postulated Accident Issues and the NRC 2013 GEIS Findings ...................... E4-54 Table 4.10-2. BFN Internal Events with Internal Flooding Model CDF and LERF ................ E4-55 Table 4.10-3. BFN Internal Events with Internal Flooding Model CDF and LERF ................ E4-56 Table 4.10-4. BFN Fire Model CDF and LERF ..................................................................... E4-59 Table 4.10-5. BFN Fire Model CDF and LERF ..................................................................... E4-60 Table 4.10-6. BFN Seismic Model CDF and LERF ............................................................... E4-60 Table 4.10-7. BFN Seismic Model CDF and LERF ............................................................... E4-61 Table 4.10-8. BFN Total CDF and LERF Risk Metrics ......................................................... E4-63 Table 4.10-9. SAMAs Quantitatively Assessed in Stage 1 ................................................... E4-69 Table 4.10-10. Percent Reduction for SAMAs Quantitatively Assessed in Stage 1.............. E4-73 Table 4.11-1. Environmental Justice Issues and the NRC 2013 GEIS Findings .................. E4-74 Table 4.12-1. Waste Management Issues and the NRC 2013 GEIS Findings ..................... E4-75 Table 4.14-1. Cumulative Impacts Issues and the NRC 2013 GEIS Findings ...................... E4-85 Table 4.15-1. Uranium Fuel Cycle Issues and the NRC 2013 GEIS Findings ...................... E4-93 Table 4.16-1. Termination of Nuclear Plant Operations and Decommissioning Issues and the NRC 2013 GEIS Findings ....................................................................... E4-96 Table 6.1-1. Environmental Impacts Related to License Renewal at BFN ............................. E6-1 Table 7.2-1. 500-Mwe Gas-fired Turbine Annual Emissions................................................. E7-17 Table 9.1-1. Environmental Authorizations for Current BFN ................................................... E9-5 Table 9.1-2. Environmental Authorizations for BFN Subsequent License Renewal ............... E9-6 LIST OF FIGURES Figure 2.2-1. BFN Site Overview Map .................................................................................. E2-14 Figure 2.2-2. BFN In-Scope Transmission Lines .................................................................. E2-15 Figure 3.1-1. 6-Mile Radius BFN NLCD Land Use/Land Cover Map .................................... E3-10 Figure 3.1-2. Onsite BFN NLCD Land Use/Land Cover Map ............................................... E3-11 Figure 3.4-1. Geological Cross Section of the BFN Site ....................................................... E3-22 Figure 3.4-2. BFN Soil Map .................................................................................................. E3-23 Figure 3.4-3. Earthquake Epicenters within 50 Miles of BFN ............................................... E3-24 Figure 3.4-4. Seismic Hazard Map within 50 Miles of BFN ................................................... E3-25 Figure 3.5-1. Delineated Surface Water Features ................................................................ E3-40 Figure 3.5-2. BFN Site Monitoring Wells ............................................................................... E3-41 Figure 3.5-3. Historical Release Locations at BFN ............................................................... E3-42 Figure 3.6-1. Forest Zones Surveyed at the BFN Site .......................................................... E3-62 Figure 3.8-1. Counties within 20 Miles of BFN ...................................................................... E3-80 Figure 3.8-2. Counties within 50 Miles of BFN ...................................................................... E3-81 Figure 3.10-1. Aggregate Minority Block Groups within 50 Miles of BFN ............................. E3-89 Figure 3.10-2. Hispanic and Black or African Block Groups within 50 Miles of BFN ............ E3-90 Figure 3.10-3. Poverty Block Groups within 50 Miles of BFN ............................................... E3-91 Figure 4.10-1. SAMA New & Significant Assessment Flowchart ........................................ E4-67 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E-viii

Appendix E - Applicants Environmental Report-Operating License Renewal Stage ACRONYMS AND ABBREVIATIONS °F degrees Fahrenheit ADEM Alabama Department of Environmental Management ADPH Alabama Department of Public Health ADT average daily traffic AEC U.S. Atomic Energy Commission Aero Aeroderivative Ag silver AHC Alabama Historical Commission ALARA as low as reasonably achievable amsl above mean sea level APE area of potential effects AREOR Annual Radiological Environmental Operating Report BCC birds of conservation concern BESS battery energy storage systems BFARF Browns Ferry Aquatic Research Facility BFN Browns Ferry Nuclear Plant BGEPA Bald and Golden Eagle Protection Act BLEU blended low enriched uranium BLS U.S. Bureau of Labor Statistics BMP best management practice BTA best technology available BWR boiling water reactor C&D construction and demolition ca. circa CAA Clean Air Act CAES compressed air energy storage CC combined cycle CCW condenser circulating water CDC U.S. Centers for Disease Control and Prevention CDF core damage frequency CFR Code of Federal Regulations cfs cubic feet per second CH4 methane CO carbon monoxide Co cobalt CO2 carbon dioxide CO2e carbon dioxide equivalent CPUE catch per unit effort CRP Cummings Research Park Cs cesium CT combustion turbine CWA Clean Water Act CWIS cooling water intake structure CZMP Coastal Zone Management Program dBA decibels in A-weighted scale DNL day/night sound level DO dissolved oxygen DOE U.S. Department of Energy DOT U.S. Department of Transportation Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E-ix

Appendix E - Applicants Environmental Report-Operating License Renewal Stage DR demand response EA Environmental Assessment EDS Environmental Data Station EE energy efficiency EECW emergency equipment cooling water EFH essential fish habitat EI exposure indexes EIA Energy Information Administration EIS Environmental Impact Statement EMF electromagnetic field EPU extended power uprate EO Executive Order ER Environmental Report ESA Endangered Species Act FBI Federal Bureau of Investigation FICON Federal Interagency Committee on Noise fps feet per second FR Federal Register gal gallons GEIS Generic Environmental Impact Statement GHG greenhouse gas GIS geographic information system gpm gallons per minute GWh gigawatt hours GWP global warming potential HAP hazardous air pollutant HVAC heating, ventilation, and air conditioning IGCC integrated gasification combined cycle IPaC Information for Planning and Consultation IPCC Intergovernmental Panel on Climate Change IPE Individual Plant Examination IPEEE Individual Plant Examination of External Events IRP Integrated Resource Plan ISFSI independent spent fuel storage installation kV kilovolt kW kilowatt kWh kilowatt hour LERF large early release frequencies LLRW Low level radioactive waste LOCA loss-of-coolant accident MB maximum benefit MBTA Migratory Bird Treaty Act MGD million gallons per day Mn manganese MOA memorandum of agreement mph miles per hour mrem millirem MSA Magnuson-Stevens Fishery Conservation and Management Act mSv millisievert MW megawatt MWd/MTU megawatt day/metric tons of uranium Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E-x

Appendix E - Applicants Environmental Report-Operating License Renewal Stage MWe megawatts electric MWh megawatt hour MWt megawatt thermal N&SI new and significant information N2O nitrous oxide NAAQS National Ambient Air Quality Standards NEI Nuclear Energy Institute NEPA National Environmental Policy Act NESC National Electric Safety Code NHPA National Historic Preservation Act NLCD National Land Cover Database NMFS National Marine Fisheries Service NO2 nitrogen dioxide NOAA Fisheries National Marine Fisheries Service NOAA National Oceanic and Atmospheric Administration NOx nitrogen oxide NPDES National Pollutant Discharge Elimination System NPG Nuclear Power Group NRC Nuclear Regulatory Commission NREL National Renewable Energy Laboratory NRHP National Register of Historic Places NSPS New Source Performance Standards NWI National Wetland Inventory ODCM Off-site Dose Calculation Manual OSHA Occupational Safety and Health Administration OTMHM one-top multi-hazard model PAH polycyclic aromatic hydrocarbon Pb lead PCB polychlorinated biphenyl pCi/L picocurie per liter PFOS perfluorooctane sulfonate PM10 particulate matter with aerodynamic diameters of 10 microns or less PM2.5 particulate matter with aerodynamic diameters of 2.5 microns or less PPA Power Purchase Agreement PRA Probabilistic Risk Assessment PV photovoltaic RCP Representative Concentration Pathways RCRA Resource Conservation and Recovery Act REMP Radiological Environmental Monitoring Program RFAI Reservoir Fish Assemblage Index RFOL Renewed Facility Operating License RHA Rivers and Harbors Act of 1899 RHR residual heat removal ROI Region of Interest ROW right-of-way SAMA Severe Accident Mitigation Alternatives SCPC supercritical pulverized coal SEIS Supplemental Environmental Impact Statement SF6 Sulfur hexafluoride SHPO state historic preservation officer SLR subsequent license renewal Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E-xi

Appendix E - Applicants Environmental Report-Operating License Renewal Stage SLRA subsequent license renewal application SMR small modular reactor SND summer net dependable capacity SO2 sulfur dioxide spp species (plural) SWPPP stormwater pollution prevention plan TEDE total effective dose equivalent tpy tons per year TRM Tennessee River Mile TVA Tennessee Valley Authority TWH terawatt hours U.S. United States U.S.C. United States Code USACE US Army Corps of Engineers USCB US Census Bureau USDA US Department of Agriculture USEPA U.S. Environmental Protection Agency USFWS U.S. Fish and Wildlife Service WinMACCS Windows MELCOR Accident Consequences Code System WMA Wildlife Management Area Zn zinc Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E-xii

Appendix E - Applicants Environmental Report-Operating License Renewal Stage CHAPTER 1 - INTRODUCTION 1.1. Purpose of and Need for Action The U.S. Nuclear Regulatory Commission (NRC) licenses the operation of domestic nuclear power plants in accordance with the Atomic Energy Act of 1954, as amended, (Public Law 83-703) and NRC implementing regulations. The Tennessee Valley Authority (TVA) operates the Browns Ferry Nuclear Plant (BFN) Units 1, 2, and 3 pursuant to NRC Renewed Facility Operating Licenses (RFOLs) DPR-33, DPR-52, and DPR-68, respectively. The Unit 1 RFOL will expire December 20, 2033, the Unit 2 RFOL will expire June 28, 2034, and the Unit 3 RFOL will expire July 2, 2036. TVA has prepared this Environmental Report (ER) in conjunction with its application to NRC to subsequently renew the BFN RFOLs for an additional 20 years, as provided by the following NRC regulations: Title 10, Energy, Code of Federal Regulations (CFR), Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, Section 54.23, Contents of Application - Environmental Information (10 CFR 54.23) and Title 10, Energy, CFR, Part 51, Environmental Protection Requirements for Domestic Licensing and Related Regulatory Functions, Section 51.53, Postconstruction Environmental Reports, Section 51.53(c), Operating License Renewal Stage [10 CFR 51.53(c)]. NRC has defined the purpose and need for the proposed action, renewal of the operating licenses for nuclear power plants such as BFN, as follows (NRC 2013a): The purpose and need for the proposed action (issuance of a renewed license) is to provide an option that allows for baseload power generation capability beyond the term of the current nuclear power plant operating license to meet future system generating needs. Such needs may be determined by other energy-planning decision-makers, such as State, utility, and, where authorized, Federal agencies (other than the NRC). Unless there are findings in the safety review required by the Atomic Energy Act or the NEPA [National Environmental Policy Act] environmental review that would lead the NRC to reject a license renewal application, the NRC does not have a role in the energy-planning decisions of whether a particular nuclear power plant should continue to operate. The Subsequent RFOLs would allow an additional 20 years of operation for BFN units beyond the current licensed operating periods. The Subsequent RFOL for BFN Unit 1 would expire on December 20, 2053, the Subsequent RFOL for BFN Unit 2 would expire on June 28, 2054, and the Subsequent RFOL for BFN Unit 3 would expire on July 2, 2056. 1.2. Environmental Report Scope and Methodology NRC regulations for domestic licensing of nuclear power plants require reviews of environmental impacts from renewing an operating license. NRC regulation 10 CFR 51.53(c) requires that an applicant for license renewal submit with its application an ER (Appendix E of the application) entitled, "Applicant's Environmental ReportOperating License Renewal Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E1-1

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Stage." In determining what information to include in the BFN Subsequent License Renewal Application (SLRA) ER, TVA has relied on NRC regulations and the following supporting documents that provide additional insight into the regulatory requirements:

Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants, NUREG-1437, Revision 1 (NRC 2013a).
Regulatory Guide 4.2, Supplement 1, Revision 1 Preparation of Environmental Reports for Nuclear Power Plant License Renewal Applications. June 2013 (NRC 2013b).
Regulatory Guide 4.2, Revision 3, Preparation of Environmental Reports for Nuclear Power Stations. September 2018 (NRC 2018).
NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants Supplement 1, Revision 1: Operating License Renewal Final Report. June 2013 (NRC 2013c).

TVA has prepared Table 1.2-1, which indicates the sections in the BFN SLRA ER that respond to each requirement of 10 CFR 51.53(c), to verify conformance with regulatory requirements. In the 2013 GEIS, NRC considered Category 1 issues to be those that had been found to result in essentially the same (generic) impact at all nuclear plants (or for some issues, those plants having a specific type of cooling system or other characteristics in common) (NRC 2013a). Under NUREG-1437, Category 1 issues did not need to be re-evaluated in plant specific environmental reviews absent new and significant information indicating the potential for a change in the level of impact relative to that in the GEIS. Category 2 issues were identified as those that could have different levels of impact depending upon the characteristics of each plant. Therefore, Category 2 issues were required to have a plant-specific analysis for impact determinations as part of their environmental review for relicensing. In February 2022, the NRC ruled that the 2013 GEIS was not sufficient for SLRAs. The NRC initiated a rulemaking to amend Table B-1 of Appendix B, Summary of Findings on NEPA [National Environmental Policy Act] Issues for License Renewal of Nuclear Power Plant, to Subpart A, National Environmental Policy Act - Regulations Implementing Section 102(2), of Part 51 of Title 10 of the Code of Federal Regulations (10 CFR), Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions. NUREG-1437 provides the technical and regulatory basis for Table B-1. Consequently, NUREG-1437 will also be updated. The NRC held that the 2013 license renewal GEIS was only acceptable to address the impacts of initial 20-year license renewal periods, and that the Table B-1 Category 1 conclusions could not be credited in an SLRA. Because the NRC is reviewing and amending the GEIS with respect to the subsequent period of extended operation, the GEIS Category 1 findings can no longer be applied generically and this ER will evaluate each Category 1 issue based on the specific characteristics of BFN. Due to the length of time that will be required to implement the new rulemaking, this ER fully evaluates each GEIS Category 1 issue on a site-specific basis, as is done for GEIS Category 2 issues. Until the new NRC rulemaking is complete, the 2013 GEIS, Regulatory Guide 4.2, NUREG-1437, and NUREG-1555 provide a general framework for the analysis presented within this ER, defining the number and scope of environmental impact issues that need to be addressed. After Rulemaking has concluded, TVA may consider supplementing the ER to reference the revised GEIS Category 1 dispositions. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E1-2

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 1.2-1. Correspondence between License Renewal Regulatory Requirements and Environmental Report Sections Regulatory Requirement Responsive Environmental Report Section(s) 10 CFR 51.53(c)(1) Entire Document 10 CFR 51.53(c)(2) Chapter 2 Proposed Action and Description of Alternatives 2.1 The Proposed Action 2.3 Refurbishment Activities 2.4 Programs and Activities for Managing the Effects of Aging 2.6 Alternatives to the Proposed Action Chapter 3 Affected Environment Chapter 4 Environmental Consequences of the Proposed Action and Mitigating Actions 6.2 Mitigation 6.3 Unavoidable Adverse Impacts 6.4 Irreversible or Irretrievable Resource Commitments 6.5 Short-Term Use Versus Long-Term Productivity of the Environment Chapter 7 Alternatives to the Proposed Action Chapter 8 Comparison of Environmental Impact of Subsequent License Renewal to the Alternatives Chapter 9 Status of Compliance 9.1 Proposed Action 9.2 Alternatives 10 CFR 51.53(c)(3)(ii) 2.3 Refurbishment Activities Chapter 4 Environmental Consequences of the Proposed Action and Mitigating Actions 10 CFR 51.53(c)(3)(ii)(A) 4.5.1.9 Surface Water Use Conflicts (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River) 4.5.2.4 Groundwater Use Conflicts (Plants with Closed-Cycle Cooling Systems that Withdraw Makeup Water from a River) 4.6.1.6 Water Use Conflicts with Terrestrial Resources (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River) 4.6.2.11 Water Use Conflicts with Aquatic Resources (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River) 10 CFR 51.53(c)(3)(ii)(B) 4.6.2.1 Impingement and Entrainment of Aquatic Organisms (Plants with Once-through Cooling Systems or Cooling Ponds) 4.6.2.4 Thermal Impacts on Aquatic Organisms (Plants with Once-through Cooling Systems or Cooling Ponds) 10 CFR 51.53(c)(3)(ii)(C) 4.5.2.3 Groundwater Use Conflicts (Plants that Withdraw greater than 100 GPM) 10 CFR 51.53(c)(3)(ii)(D) 4.5.2.7 Groundwater Quality Degradation (Plants with Cooling Ponds at Inland Sites) 10 CFR 51.53(c)(3)(ii)(E) 4.6.1.1 Effects on Terrestrial Resources (Non-Cooling System Impacts) 4.6.3 Special Status Species and Habitats Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E1-3

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Regulatory Requirement Responsive Environmental Report Section(s) 10 CFR 51.53(c)(3)(ii)(G) 4.9.4 Microbiological Hazards to the Public (Plants with Cooling Ponds or Canals or Cooling Towers that Discharge to a River) 10 CFR 51.53(c)(3)(ii)(H) 4.9.8 Electric Shock Hazards 10 CFR 51.53(c)(3)(ii)(K) 4.7 Historic and Cultural Resources 10 CFR 51.53(c)(3)(ii)(L) 4.10.2 Severe Accidents 10 CFR 51.53(c)(3)(ii)(N) 3.10 Environmental Justice 4.11 Environmental Justice 10 CFR 51.53(c)(3)(ii)(O) 4.14 Cumulative Impacts 10 CFR 51.53(c)(3)(ii)(P) 4.5.2.8 Radionuclides Released to Groundwater 10 CFR 51.53(c)(3)(iii) Chapter 4 Environmental Consequences of the Proposed Action and Mitigating Actions 6.2 Mitigation 10 CFR 51.53(c)(3)(iv) Chapter 4 Environmental Consequences of the Proposed Action and Mitigating Actions Chapter 5 Assessment of New and Significant Information 10 CFR 51.45(b)(1) Chapter 4 Environmental Consequences of the Proposed Action and Mitigating Actions 10 CFR 51.45(b)(2) 6.3 Unavoidable Adverse Impacts 10 CFR 51.45(b)(3) 2.6 Alternatives to the Proposed Action Chapter 7 Alternatives to the Proposed Action Chapter 8 Comparison of Environmental Impact of Subsequent License Renewal to the Alternatives 10 CFR 51.45(b)(4) 6.5 Short-Term Use Versus Long-Term Productivity of the Environment 10 CFR 51.45(b)(5) 6.4 Irreversible or Irretrievable Resource Commitments 10 CFR 51.45(c) Chapter 4 Environmental Consequences of the Proposed Action and Mitigating Actions 6.2 Mitigation 6.3 Unavoidable Adverse Impacts Chapter 7 Alternatives to the Proposed Action Chapter 8 Comparison of Environmental Impact of Subsequent License Renewal to the Alternatives 10 CFR 51.45(d) Chapter 9 Status of Compliance 9.1 Proposed Action 9.2 Alternatives 10 CFR 51.45(e) Chapter 4 Environmental Consequences of the Proposed Action and Mitigating Actions NUREG 1437, Revision 1 2.3 Refurbishment Activities Chapter 7 Alternatives to the Proposed Action 1.3. BFN Licensee and Ownership TVA, a corporate agency and instrumentality of the United States, holds the RFOLs for BFN Units 1 (DPR-33), Unit 2 (DPR-52), and Unit 3 (DPR-68). TVA owns and operates BFN Units 1, 2, and 3 consistent with its mission as charged under the TVA Act of 1933. For the purposes of this ER, TVA is considered the applicant. TVA also owns and operates the transmission lines constructed for purposes of connecting BFN to the electric power grid. TVA manages the Tennessee River system, the source of operational water for BFN, through control of a series of mainstem and tributary dams. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E1-4

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 1.4. References NRC (Nuclear Regulatory Commission). 2013a. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG-1437, Volume 1, Revision 1. Office of Nuclear Reactor Regulation. June 2013. NRC. 2013b. Preparation of Environmental Reports for Nuclear Power Plan License Renewal Applications. Regulatory Guide 4.2, Supplemental 1, Revision 1. June 2013. NRC. 2013c. Standard Review Plans for Environmental Reviews for Nuclear Power Plants. Supplement 1: Operating License Renewal. Final Report. NUREG-1555, Revision 1. June 2013. NRC. 2018. Preparation of Environmental Reports for Nuclear Power Stations. Regulatory Guide 4.2, Revision 3. September 2018. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E1-5

Appendix E - Applicants Environmental Report-Operating License Renewal Stage CHAPTER 2 - PROPOSED ACTION AND DESCRIPTION OF ALTERNATIVES 2.1. The Proposed Action The Tennessee Valley Authority (TVA) proposes that the U.S. Nuclear Regulatory Commission (NRC) subsequently renew the existing Renewed Facility Operating Licenses (RFOLs) for Browns Ferry Nuclear Plant (BFN) Units 1, 2 and 3 for an additional 20 years beyond the current license expiration dates of December 20, 2033, for Unit 1, June 28, 2034, for Unit 2, and July 2, 2036, for Unit 3. Subsequent renewal of the existing RFOLs would give TVA the option of relying on BFN to help meet the future baseload power generating needs of the approximately 10 million people currently being served in a seven-state region (Tennessee and parts of Alabama, Georgia, Kentucky, Mississippi, North Carolina, and Virginia); over 80,000 square miles during the subsequent period of extended operation (TVA 2019). Section 2.2 discusses the major features of the plant and the operation and maintenance practices directly related to the subsequent period of extended operation. The subsequent period of extended operation for BFN does not require any new construction or modifications beyond normal operation and maintenance that could directly affect the environment or plant effluents. The relationship of refurbishment (major facility modifications/component replacements) to subsequent license renewal (SLR) is described in Section 2.3. Administrative control procedures to control the effects of aging is described in Section 2.4. 2.2. General Plant Information TVA operates BFN Units 1, 2, and 3 in Limestone County, Alabama. BFN is located on an approximately 880-acre tract on the north shore of Wheeler Reservoir at Tennessee River Mile (TRM) 294, approximately 10 miles northwest of the center of Decatur, Alabama, and 10 miles southwest of Athens, Alabama. BFN consists of three General Electric boiling water reactors (BWRs) and associated turbine generators that collectively supply approximately 3,900 megawatts of electric power (MWe) to the TVA transmission and distribution system (TVA 2023a). Each of BFNs three nuclear reactors is connected to its own dedicated generator. BFN uses a once-through (open-cycle) condenser circulating water system with seven helper cooling towers which can be used to dissipate waste heat and reduce cooling water temperature as necessary to comply with environmental regulations before cooling water is discharged back to Wheeler Reservoir. TVA began construction of BFN in 1967 (TVA 1972). In 1972, TVA and the U.S. Atomic Energy Commission (AEC), the predecessor agency of NRC, prepared a Final Environmental Statement for the construction and operation of BFN Units 1, 2, and 3. The AEC concluded on August 28, 1972, that the statement was adequate to support the proposed license to operate the plant (TVA 2002) Unit 1 began commercial operation in 1974, Unit 2 in 1975, and Unit 3 in 1977 (TVA 2023a). TVA submitted a License Renewal Application to the NRC in December 2003 for a 20-year renewal of the Facility Operating Licenses for each BFN unit. In June 2005, the NRC issued Supplement 21 to the Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants, Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3, which presented Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-1

Appendix E - Applicants Environmental Report-Operating License Renewal Stage updated information on BFN and evaluated the environmental impacts associated with the initial period of extended operation (NRC 2005). The NRC issued RFOLs for Units 1, 2, and 3 in May 2006, allowing continued operation of the three BFN units until 2033, 2034, and 2036, respectively. In 2013, the NRC published the GEIS, NUREG-1437, Revision 1, which presented BFN features that NRC considered in its updated industry-wide assessment of license renewal environmental impacts (NRC 2013a). In September 2015, TVA requested an amendment to the 2006 RFOLs to allow Units 1, 2, and 3 to operate at up to 120 percent of the original licensed thermal power level (i.e., 120 percent of 3,293, or 3,952 megawatts thermal [MWt] per unit) (NRC 2017) ). The BFN units had previously been uprated by 5 percent (from 3,293 to 3,458 MWt) and the remaining power increase was approximately 15 percent increase for each BFN unit. In 2017, the NRC issued its Environmental Assessment and Finding of No Significant Impact for Browns Ferry Nuclear Plant Units 1, 2, and 3 supporting an increase in the maximum licensed thermal power level for each reactor from 3,458 MWt to 3,952 MWt (NRC 2017). The BFN central site area consists of a reactor building, a turbine building, a service building, a maintenance building, two diesel generator buildings (one for Units 1 and 2 and one for Unit 3), a radioactive waste building, administration buildings, a Diverse and Flexible Coping Strategies equipment storage building, an intake pumping station, a 161-kilovolt (kV) switchyard and a 161-kV capacitor yard, a 500-kV switchyard, an off-gas stack, wastewater lagoons, and two independent spent fuel storage facility installation (ISFSI) pads. Northwest of the central site area are the hot water and cold water discharge channels and seven mechanical draft helper cooling towers. To the east of the central site area are the meteorological tower, the Training Center, employee physical fitness center, low-level radioactive waste and hazardous waste storage areas, and a materials and procurement complex. Figure 2.2-1 shows the general features of the facility and the site boundary. Five of the original six cooling towers that serve BFN (Cooling Towers 1, and 3-6) have been replaced, Cooling Tower 2 is scheduled for replacement by 2027, and the Cooling Tower 7 was constructed in May 2012. 2.2.1. Reactor and Containment Systems BFN Units 1, 2, and 3 are General Electric Type 4 boiling water reactors (BWR/4) with Mark I containment systems and a combined maximum generation capacity of 11,856 MWt or approximately 3,900 MWe, including power uprates. The BWR/4 reactor systems at BFN are characterized by a reactor vessel housing a reactor core where nuclear fission within the uranium dioxide fuel pellets creates heat; thus, causing the coolant water to boil. The resultant steam and water droplets are separated by steam separators and steam dryers. The dried steam is directed to the turbines, which turn and generate electricity. After exiting the turbine, steam is cooled back to coolant water in the condenser from which it is recirculated to the preheaters and the reactor core. Off-gases are treated through the off-gas treatment system and then released through the BFN plant stack. The Mark I primary containment system for each unit at BFN is a pressure suppression system consisting of a drywell, pressure suppression chamber, vent system, isolation valves, containment cooling system, and other service equipment. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-2

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Designed to withstand an internal pressure of 62 pounds per square inch above atmospheric pressure and coupled with its engineered safety features, each Mark I containment is designed to provide adequate radiation protection for both normal operation and postulated design-basis events, such as earthquakes or loss-of-coolant accidents. The reactor building acts as a secondary containment system by completely surrounding the primary containments, which, in turn, surround the reactor vessels. In addition, the reactor building houses refueling and reactor servicing equipment, new and spent fuel storage facilities, and other reactor safety and auxiliary systems. The containment systems and their engineered safeguards are designed to ensure that offsite doses resulting from postulated design-basis accidents are below the requirements of 10 Code of Federal Regulations (CFR) 50.67. 2.2.2. Fuel Enrichment, Burn-Up, and Independent Spent Fuel Storage Installation BFN Units 1, 2, and 3 are licensed to operate using fuel composed of uranium-dioxide pellets enriched up to 5 percent by weight of uranium-235 and contained in sealed zircaloy fuel rod tubes which are assembled into individual fuel bundles. Average peak rod fuel burnup for each unit will not exceed 62,000-megawatt day/metric tons of uranium. Refueling of approximately one third of the fuel in each unit is performed approximately every 24 months. Refueling outages occur for approximately 28-45 days. The spent fuel pools for Units 1, 2, and 3 are available for storage of new fuel and spent fuel assemblies. Each spent fuel pool is designed to hold 3471 fuel assemblies which is 4.5 full core loads. However, the number of spent fuel assemblies in each fuel pool varies due to cycle specific variations in the number of fuel assemblies discharged at the end of each cycle and the number of spent fuel assemblies removed and transferred to dry storage casks during dry cask storage campaigns. Spent nuclear fuel from Units 1, 2, and 3 is also stored onsite in dry casks in the ISFSI. The ISFSI complies with the General License issued under 10 CFR Part 72, Subpart K (General License for Storage of Spent Fuel at Power Reactor Sites) and the conditions contained in the Certificate of Compliance for the cask system. Implementation of the ISFSI was reviewed as part of the TVA Final Supplemental Environmental Impact Statement for operating license renewal of the three units and restart of Unit 1 at BFN (TVA 2002). 2.2.3. Cooling and Auxiliary Water Systems This section describes BFNs condenser circulating water (CCW) system and residual heat removal (RHR) service water system. 2.2.3.1. Condenser Circulating Water System BFN units normally operate utilizing a once-though (open cycle) condenser circulating water system. Wheeler Reservoir on the Tennessee River is the source for cooling water systems for BFN. Tables 2.2-1 and 2.2-2 provide daily water withdrawals by month and daily water consumption by month, respectively for the years 2016 through 2022. The intake pumping forebay is separated from Wheeler Reservoir by a gate structure with three motor-operated wheel gates which can be controlled independently of one another. The bays are each 40 feet wide by about 24 feet high. Each bay includes a 20-foot high gate that can be raised or lowered depending on Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-3

Appendix E - Applicants Environmental Report-Operating License Renewal Stage the operational requirements of the plant. The flow velocity through the openings varies depending on the gate position (TVA 2020b). Nine circulating water pumps, which operate in groups of three, supply condenser cooling water requirements for the full power requirements of a single generating unit. Entering water is strained by trash stacks and travelling screens. The three groups of pumps are brought together into a single tunnel and channeled to the condenser. A debris filter is installed in the 78 inch inlet pipe of the condenser circulating piping. Normal filling and operation of the condensers is accomplished by venting, evacuation of the condenser water box, and operation of one or more of the circulating water pumps. Each BFN unit has one main condenser. The discharge from the condenser may either:

Pass to the discharge tunnel to then go to cooling towers via the warm water channel;
Pass to the discharge tunnel to the discharge diffusers in Wheeler Reservoir; or
A combination of these discharge paths Water is pumped to the seven cooling towers by pumps located in seven pumping stations along the warm water channel. Each pumping station for Cooling Towers 1 through 6 have two 137,500 gallons per minute (gpm) pumps at a design head of 75 feet. The pumping station for Cooling Tower 7 has four 102,500 gpm pumps at a design head of 83.5 feet. The discharge from the cooling towers flows into an open channel over a discharge control structure and back to the reservoir through the diffuser.

When the gates are in their full open position and the plant is operated in either the open or helper modes, the average flow velocity through the openings is about 0.6 feet per second (fps) for the operation of one unit, 1.1 fps for the operation of two units, and 1.7 fps for the operation of all three units. These flow velocities are based on an intake flow per unit of about 734,000 gpm, which is 1,635 cubic feet per second (cfs) (TVA 2020b). The intake pumping station includes 18 bays (i.e., six bays per reactor unit), each with a traveling water screen. Each bay has a net opening size of about 8.5 feet by 20 feet. The maximum average flow velocity through each bay is about 1.6 fps and is independent of the reservoir surface elevation. The maximum average velocity through a clean screen with net openings of 3/8 inch by 3/8 inch is about 2.1 fps. Flow velocities through the intake pump station bays and traveling screens are independent of the number of units in operation and the reservoir elevation (TVA 2020b). Heat is rejected from the power conversion system by pumping water from Wheeler Reservoir into the turbine generator condensers and discharging it back to the reservoir via three large-submerged diffuser pipes that are partially perforated to maximize uniform mixing into the flow stream. These pipes range in diameter from 17 feet to 20.5 feet. The flow exits each discharge pipe through more than 7,000 two-inch-diameter holes (TVA 2020b). Thus, approximately 22,000 holes spaced 6 inches on centers in both directions distribute the 4400 cfs (approximate) of warm water into the river for thermal mixing). This straight-through flow path is known as "open cycle" or "open mode" operation (TVA 2020b). The water is withdrawn from the Tennessee River Wheeler Reservoir by an intake structure located at about TRM 294. As originally designed, the maximum thermal discharge from the once-through cooling water system is directed into the Wheeler Reservoir, with a temperature increase across the intake and discharge of 25 degrees Fahrenheit [°F]. The flow exits the diffusers and mixes with the Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-4

Appendix E - Applicants Environmental Report-Operating License Renewal Stage reservoir flow. At the edge of the discharge mixing zone, the water temperature is required to be less than 10°F above ambient (TVA 2020b). However, when river temperatures near one or more of the National Pollutant Discharge Elimination System (NPDES) limits, BFN is shifted from open mode operation to helper mode operation, wherein through various gates condenser circulating water from one or more units is directed through one or more cooling tower(s) before it is released to the reservoir. The amount of water treated by the cooling towers depends on the amount of cooling needed for the plant to remain within compliance of the NPDES permit. TVA may also derate one or more BFN generating units to ensure compliance with NPDES thermal limits. Adverse scouring effects have not been observed at the discharge location. The capacity also exists to recycle cooling water from the cooling towers directly back to the intake structure without being discharged to the reservoir. This flow path, known as the "close mode" of operation, has not been used since the restart of Units 2 and 3 because of difficulties in achieving temperature limits in summer months and problems with equipment reliability. TVA does not anticipate using this mode in the future, and no procedures for operating in this mode currently exist (TVA 2020b). The CCW system is designed to provide a flow of approximately 675,000 gpm to the condenser, and a flow of approximately 25,000 gpm to raw cooling water system of each unit during open cycle operation. In addition to flow through the CCW pumps and the raw cooling water system, the plant total intake also includes flow for pumps to draw water for the emergency equipment cooling water system, the residual heat removal service water system, the fire protection system, the intake screen wash system, and the raw service water system. 2.2.3.2. Residual Heat Removal Service Water System The RHR Service Water System consists of four pairs of pumps located on the intake structure for pumping raw river water from Wheeler Reservoir to the heat exchangers in the RHR System and four additional pumps for supplying water to the Emergency Equipment Cooling Water (EECW) System. The EECW System distributes cooling water supplied by the RHR Service Water System to essential equipment during normal and accident conditions. 2.2.4. Radioactive Waste Management Systems The radioactive waste systems at BFN Units 1, 2, and 3 are designed to collect, process, and dispose of plant-produced radioactive wastes in a controlled and safe manner. These systems are designed to limit discharges in accordance with 10 CFR Part 50, Appendix I. The actual performance and operation of installed equipment, and reporting of actual offsite releases and doses, are controlled by the requirements of the Offsite Dose Calculation Manual (ODCM) and NPDES permit (Attachment 1). The ODCM is subject to NRC inspection and describes the methods and parameters used for calculating offsite doses resulting from radioactive gaseous and liquid effluents and ensuring compliance with NRC regulations. The methods employed for the controlled release of those contaminants are dependent primarily upon the state of the material: liquid, solid, or gaseous. 2.2.4.1. Liquid Radioactive Waste Control System The Liquid Radioactive Waste Control System collects, treats, stores, and disposes of all potentially radioactive liquid wastes. These wastes are collected in sumps and drain tanks at various locations throughout the plant and then transferred to the appropriate collection tanks in the Radioactive Waste Building for treatment, storage, discharge, or disposal. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-5

Appendix E - Applicants Environmental Report-Operating License Renewal Stage During normal operation, the liquid effluent treatment systems process and control the release of liquid radioactive effluents to the environment such that the doses to individuals offsite are maintained within the limits of 10 CFR Part 20 and as low as reasonably achievable dose standards in Appendix I to 10 CFR Part 50. The Liquid Radioactive Waste Management System is designed to process the waste and then recycle it within the plant as condensate, reprocess it through the radioactive waste system for further purification, or discharge it to the environment as liquid radioactive waste effluent in accordance with state and federal regulations. Wastes to be discharged to the environment from the liquid radioactive waste management system are processed on a batch basis, with each batch being processed by such method(s) appropriate for the quality and quantity of materials determined to be present. Processed liquid wastes may be returned to the condensate system or discharged to the environs through the circulating water discharge channel. The liquid wastes in the discharge channel are diluted with condenser effluent circulating water to achieve a permissible concentration at the site boundary. The low conductivity (high purity) liquid wastes are processed by filtration and ion exchange through the waste filter and waste demineralizer. After processing, the waste is pumped to a waste sample tank where it is sampled and then, if satisfactory for reuse, and there is sufficient available volume in the condensate storage tanks to accept the waste, it is transferred to the condensate storage tanks as makeup water. High-conductivity (low purity) liquid wastes are processed through a filter and are collected in a floor drain sample tank because they have low concentrations of radioactive impurities. If the concentration after dilution is less than or equal to the applicable limits, the filtered liquid may be discharged. An alternate method of processing low and high conductivity liquid is the use of vendor-supplied skid-mounted equipment, interconnected to the permanent radwaste system. Depending on effluent quality and plant needs, the water can be sent to either the waste sample tank or floor drain sample tank. Processing from the waste sample tank or floor drain sample tank is identical as described above. The processing equipment is located within concrete buildings to provide secondary enclosures for the wastes in the event of leaks or overflows. Tanks and equipment which contain wastes with high radioactive concentrations that could be determined to result in increased dose to personnel are shielded. Except where flanges are required for maintenance, most pipe connections are welded to reduce the probability of leaks. Process lines which penetrate shield walls are routed to prevent a direct radiation path from the tanks or equipment. Control of the waste system is from local panels in the Radioactive Waste Building. Protection against accidental discharge of liquid radioactive waste is provided by valve redundancy, instrumentation for detection of alarms of abnormal conditions, procedural controls, interlocks, and radiation monitor controlled valves. 2.2.4.2. Gaseous Radioactive Waste Management Systems The Gaseous Radioactive Waste Management System collects and processes gaseous radioactive wastes from the main condenser air ejectors, the startup vacuum pumps, condensate drain tank vent, and the steam packing exhauster, and controls their release to the atmosphere through the plant stack so that the total radiation exposure to persons outside the controlled area is as low as reasonably achievable and does not exceed applicable regulations. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-6

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 2.2.4.3. Solid Radioactive Waste Management Systems With the Solid Radioactive Waste Management System, solid radioactive wastes are collected, processed, stored, packaged, and prepared for shipment. Solid radioactive wastes include dry solid wastes and wet solid wastes. Dry Solid Wastes Dry solid wastes include contaminated rags, paper, clothing, spent filter elements, laboratory apparatus, small parts and equipment, and tools. Items of dry solid waste are collected in suitable containers located throughout the plant. Spent elements which may have a high-radiation level are packaged in accordance with applicable burial site requirements prior to being transported for processing, burial, or approved onsite storage. Low-radiation level solid wastes may be stored onsite in approved storage areas. In such instances, a maximum curie inventory of 325 curies will not be exceeded. After a period of storage, the containers are removed from the storage area and prepared for disposal. Shielded containers are provided for offsite shipment of high-activity waste if required. Wet Solid Wastes Wet solid wastes consist of spent powdered ion exchange resins, filter aid sludge, and bead-type ion exchange resins. Spent powdered ion exchange resin and filter aid sludge are accumulated and stored in phase separator tanks. Successive batches of slurried materials are accumulated, and supernatant liquid decanted, until the desired settled slurry volume has been reached. High-activity-level sludge from the reactor water cleanup filter-demineralizers is stored in three cleanup phase-separator tanks. Bead-type ion exchange resins from the waste demineralizer are stored in the spent resin tank. The spent resin remains in that tank until operations personnel determine it needs to be transferred. From that tank the spent resin is transferred to the phase separator tanks where it is mixed with other sludges. After mixing it is sent to the packaging area. Sludge from the condensate, the fuel pool filter-demineralizers, and the waste and floor drain filters is stored in six condensate phase-separator tanks. Sludge from the various sources may be either mixed in the six tanks or segregated. Each cleanup phase-separator tank and condensate phase-separator tank has decant outlets, a bottom outlet that lead to the suction of a sludge transfer pump, and an overflow outlet leading to the Radioactive Waste Building equipment drain sump. After an appropriate decay period, the sludge is reslurried and pumped to the packaging area. The packaging system is designed to permit the use of several different types of containers, including disposable tanks (liners) in reusable shields constructed of carbon steel or high-density polyethylene plastic. Prior to a packaging run, a container is positioned at one of two dewatering systems, either in a shipping cask or in a shielded enclosure. For a condensate phase-separator, hoses are connected and the sludge pump and air-operated spargers are used to stir up the settled sludge in the phase-separator and bring it into suspension. For a cleanup phase-separator, eductors are used to mix the slurry instead of air spargers. The slurry then is pumped to the loading station and back to the phase-separator tank. A portion of the slurry is drawn off into the waste package until the package is nearly filled. Water is withdrawn through the built-in filter elements via the portable dewatering system(s) and drained into the waste package drain tank. This process is repeated until the package is nearly full of dewatered slurry. Then the portable dewatering system hoses are disconnected, package penetrations are plugged, and the package is prepared for onsite storage or offsite shipment. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-7

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 2.2.4.4. Spent Nuclear Fuel BFN has two ISFSI storage pads used to safely store spent fuel in licensed and approved dry cask storage containers on site. This ISFSI is licensed separately from BFN Units 1, 2, and 3 RFOLs and will remain in place until the U.S. Department of Energy (DOE) takes possession of the spent fuel and removes it from the site for permanent disposal or processing. Expansion of the onsite spent fuel storage capacity is required in the future if a national storage solution for the permanent storage of spent fuel does not become available during the subsequent period of extended operation. The current ISFSI storage pads are projected to be filled on or before year 2036. Under the existing licenses and assuming decommissioning at the end of the current license periods, an additional 104 dry fuel storage casks will be needed to support operations and decommissioning. The addition of a third ISFSI storage pad to further increase storage capacity needed for the subsequent period of extended operation is under consideration, but plans are in the conceptual stage and no installation schedule has been established. The BFN site has adequate space onsite to accommodate the construction of an additional ISFSI pad if necessary. The impacts associated with this expansion will also be assessed under a licensing process separate from that of BFN Units 1, 2, and 3 RFOLs. 2.2.4.5. Low-Level Radioactive Waste Low-level radioactive wastes (LLRW) at BFN are processed, packaged, and stored for subsequent shipment and offsite burial using the solid radioactive waste system. Solid radioactive wastes and potentially radioactive wastes include spent resin material, filter sludges, contaminated rags, clothing, and paper products, contaminated reactor internal parts, and other processing media from the liquid radwaste disposal system. The spent resin materials and filter sludges are dewatered and temporarily stored onsite before being shipped offsite for storage and disposal based on radioactivity classification. The contaminated rags, clothing, and paper products are collected and packaged onsite before being shipped offsite for storage and disposal, also based on radioactivity classification. Spent control rods, incore instrument strings, and other miscellaneous irradiated components are stored in the spent fuel pools. They are loaded into shielded containers under water. These containers may then be stored onsite in approved areas or shipped offsite. BFN sends LLRW to the following licensed processing and disposal sites (TVA 2022):

EnergySolutions (Clive, UT; Oak-Ridge, TN; Memphis, TN)
TOXCO Inc.
Unitech Services Group, Inc.
Waste Control Specialists, LLC.

In 2020, a total of 117 LLRW shipments were made from BFN to the above listed processing and disposal sites. The total volume and radioactivity of LLRW shipped offsite in 2020 was 9.00x104 cubic feet and 2.82x102 curies, respectively (TVA 2021a). In 2021, a total of 133 LLRW shipments were made from BFN to the above listed processing and disposal sites. The total volume and radioactivity of LLRW shipped offsite in 2021 was 1.16x105 cubic feet and 3.95x104 curies, respectively (TVA 2022). In 2022, a total of 150 LLRW shipments were made from BFN to the above listed processing and disposal sites. The total volume and radioactivity of LLRW shipped offsite in 2022 was 1.27x105 cubic feet and 2.20x104 curies, respectively (TVA 2023b). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-8

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Routine plant operation, refueling outages, and maintenance activities that generate radioactive solid waste will continue during the subsequent period of extended operation. BFN will continue to generate radioactive solid waste and ship it offsite for disposal during the subsequent period of extended operation. BFN has sufficient existing capability to temporarily store all generated LLRW onsite. No additional construction of onsite storage facilities is necessary for LLRW storage during the subsequent period of extended operation, as BFN has contracts in place to ship LLRW offsite for disposal. LLRW is transported by truck on state and federal highways. LLRW is processed and packaged for shipping, and subsequently shipped in accordance with applicable Department of Transportation (DOT) regulations. BFN infrequently generates small quantities of mixed waste (i.e., waste that contains both radioactive material and Toxic Substances Control Act-regulated items (e.g., polychlorinated biphenyls, asbestos), and or Resource Conservation and Recovery Act (RCRA)-regulated items (e.g., listed or exhibits characteristic of hazardous wastes). In accordance with TVA procedures, mixed waste generated at BFN is collected and stored as low-level radioactive waste and then shipped offsite by trained and certified personnel to a permitted/licensed vendor. Environmental personnel ensure all applicable U.S. Environmental Protection Agency (USEPA), state environmental agency, and DOT regulations are met. In cases where the two acts are found to be inconsistent, the Atomic Energy Act takes precedence. The hazardous component is regulated by USEPA under RCRA and the radiological component is regulated by DOE or NRC. 2.2.5. Non-Radioactive Waste Management TVA expects that during the subsequent period of extended operation that BFN will continue to generate types and quantities of nonradioactive wastes similar to those generated during current and past operations. The nonradioactive waste management system receives and processes non-radiological wastes including hazardous, non-hazardous, universal, and sanitary wastes. Wastes are managed in accordance with applicable federal and state regulations as implemented through corporate procedures. 2.2.5.1. General Plant Trash BFN generates municipal solid waste commonly known as trash or garbage which consists of food waste, plastic film, paper waste, and food product packaging waste. Solid wastes generated in conjunction with operation of BFN are managed in accordance with applicable state and federal environmental regulations and disposed in approved and licensed disposal facilities. General municipal solid waste is collected as part of the routine plant operation activities and is managed through a TVA Long-term Valley Wide Contract with Republic Service. Waste material is collected in dumpsters and transported to a state licensed regional landfill permitted to accept waste materials. Republic Service uses Morris Farms Landfill in Lawrence County, Alabama. Generation rates for BFN were approximately 1.8 tons per day between May 1, 2022 and May 31, 3023. BFN also has an active recycling program that segregates and recycles scrap metal; cardboard; white, mixed, and office paper; food cans; wood pallets; plastic, glass, and aluminum container; non-asbestos ceiling tile; and batteries. The segregated materials are accepted for recycling by TVA-approved waste vendors. 2.2.5.2. Construction/Demolition Debris BFN uses Republic Service to dispose of construction and demolition (C&D) solid waste at the Morris Farms Landfill in Lawrence County, Alabama. These waste include material produced Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-9

Appendix E - Applicants Environmental Report-Operating License Renewal Stage directly or incidentally by construction and demolition at BFN such as scrap lumber, bricks, sandblast grit, crushed metal drums, glass, wiring, non-asbestos insulation, roofing materials, building siding, scrap metal, concrete with reinforcing steel, nails, wood, electrical wiring, rebar, bricks, concrete, excavated dirt, tree stumps, rubble, and similar C&D wastes. BFN currently has in place the necessary contracts for proper disposal of C&D wastes. A permitted C&D landfill is present at BFN operated under the Alabama Department of Environmental Management (ADEM) Permit No. 42-02 for C&D waste such as unwanted material produced directly or incidentally by the construction or demolition of buildings at BFN. This includes such building material as non-asbestos insulation, metals, such as steel, aluminum, copper, and brass; lumber; timber and other land clearing waste; electrical wiring; bricks; concrete; and rubble. The BFN C&D landfill is approximately 7.7 acres in size and was closed in 2021. 2.2.5.3. Hazardous Waste BFN generates a variety of wastes that are classified as hazardous under RCRA. These wastes include paint-related materials, spent solvents used for cleaning and degreasing, spent batteries, and fluorescent light tubes. In addition to these major waste streams, BFN generates universal waste such as spent batteries, fluorescent light bulbs, and used oil (which is recycled). Hazardous wastes generated at BFN are managed through the TVA Direct Shipment Program with the ADEM Land Division in Montgomery, Alabama. BFN is a Small Quantity Generator of hazardous waste, with generation amounts less than 2,200 pounds/month. Annual hazardous waste generation rates for BFN from 2016 to 2022 are summarized in Table 2.2-3. With the exception of December 2020 and October 2021, BFN did not generate more than 1,323 pounds in any one month during the 2016 to 2022 period. In December 2020 and October 2021, BFN generated 6,376 and 3,468 pounds of hazardous waste, respectively, as a result of a planned episodic generation. Therefore, BFN is not considered a Large Quantity Generator. Hazardous and universal wastes are collected for recycling and shipped to recycling firms listed on the Environmental Restricted Awards List. TVA has procedures in place for handling of hazardous and universal wastes. Hazardous waste generation rates for BFN between 2016 and 2022 averaged approximately 5,380 pounds per calendar year. While not a hazardous waste as defined in the RCRA regulations, used oil is also generated at BFN as a result of maintenance activities on plant equipment. All used oil is collected, stored on site, and shipped to an approved recycling center for energy recovery. 2.2.6. Power Transmission System 2.2.6.1. In-Scope Transmission Lines According to NRC Regulatory Guide 4.2 Supplement 1, in-scope transmission lines subject to evaluation of environmental impacts for license renewal are those that connect the nuclear power plant to the switchyard where electricity is fed into the regional power distribution system and power lines that feed the plant from the grid during outages (NRC 2013b). All in-scope transmission lines are located completely within the BFN site boundary, as shown in Figure 2.2-2. BFN Units 1 , 2, and 3 generators are connected into TVAs existing network supplying large load centers. Each generator is connected through a generator breaker with force-cooled, isolated-phase bus to a bank of three single-phase transformers which step up the generator voltage from 22 to 500 kV. Each BFN unit is connected to the 500 kV switchyard on the BFN property through three 500-kV transmission lines. The 500-kV switchyard receives the output of Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-10

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Units 1 , 2, and 3 generators and delivers this output to the 500-kV system network for transmission to system loads. This switchyard also serves as an offsite power source from seven 500-kV transmission lines through six unit station service. One line is to Madison substation, two to Trinity substation, one line each to the West Point, Maury and Union substations, and one line to the Limestone 500-kV Substation. The 500-kV switchyard is designed such that the output of Units 1, 2, and 3 generators may be transmitted to various parts of the 500-kV system network as the system load may require. BFN is also connected to the 161-kV switchyard through two 161-kV transmission lines. The 161-kV switchyard receives power from the 161-kV system network and delivers this power to station auxiliaries. This switchyard also serves as an offsite power source through two common station service transformers for Units 1, 2, and 3. One of these lines connects to the Trinity 500-1 61-kV Substation, and the other connects to the Athens, Alabama, 161-kV Substation. The 500- and 161-kV switchyards supply startup, running, and shutdown power through stepdown transformers. The 161-kV switchyard also supplies the cooling tower power. Normal station power is from the unit station service transformers connected between the generator breaker and main transformer of each unit. Startup power is from the TVA 500-kV system network through the 500- to 22-kV main and 20.7- to 4.16-kV unit station service transformers. Auxiliary power is available through the two common station service transformers which are fed from two 161-kV lines supplying the 161-kV switchyard, one line each from the Athens and Trinity substations. The standby source of auxiliary power is from eight diesel-driven generators. These units start automatically on an accident signal, loss of voltage, or degraded voltage on the associated shutdown board from self-contained starting air systems. The 500- and 161-kV switchyards are designed to minimize the effects of failures of individual items of equipment so that any such single probable event should not interrupt power from their respective system networks to the station service transformers. Collectively the switchyards are designed to provide adequate offsite power to start all three units, carry common plant auxiliary loads and, when necessary, to carry the required emergency loads of equipment in engineered safeguards systems for Units 1, 2, and 3 in a design basis accident while supplying the auxiliary power requirements of the non-accident units. The lines are separated sufficiently to ensure that the failure of any Iower in one line will not endanger the integrity of the 500-kV or the 161-kV transmission systems. Continued operation of BFN will not require transmission system upgrades during the subsequent period of extended operation. 2.2.6.2. Vegetation Management Practices The in-scope transmission lines are completely within the BFN site boundary as shown in Figure 2.2-2. The transmission lines cross the BFN industrial area, where vegetation is sparse. Except in unusual circumstances, transmission corridors where out-of-scope transmission lines are located are maintained on a 3-year cycle as provided for in TVAs Transmission System Routine Periodic Vegetation Management Final Environmental Assessment. Localized herbicide application and mowing are the predominant methods for corridor vegetation maintenance (TVA 2021b). Avian Protection Threatened and endangered species potentially occurring near BFN, or within counties occurring within a 6-mile radius of BFN, are described in Sections 3.6.1.4 and 3.6.2.4. As Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-11

Appendix E - Applicants Environmental Report-Operating License Renewal Stage required under Executive Order (EO) 13186 - Responsibilities of Federal Agencies to Protect Migratory Birds, TVA is currently developing a Memorandum of Understanding in coordination with the United States Fish and Wildlife Service and an Avian Management Plan. In the interim, consistent with EO 13186, TVA implements measures for the conservation of migratory bird populations. Additionally, TVAs Transmission System Routine Periodic Vegetation Management Final Environmental Assessment describes protective measures TVA implements near sensitive wildlife resources (TVA 2021b). 2.2.6.3. Public All in-scope transmission lines are located completely within TVA-owned property. The public does not have access to this area, and therefore, no induced shock hazards exist for the public. 2.2.6.4. Plant Workers TVA's safe work practices and processes provide a comprehensive description of the company's electrical transmission safety guidances. TVA maintains safety-specific policies, including those for work conducted at electrical transmission locations, extra high voltage switchyards, and working on electrical equipment and components which could be exposed to an arc flash hazard. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-12

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 2.2-1. BFN Average Daily Water Withdrawals by Month from Wheeler Reservoir (2016-2022) (million gallons per day) 2016 2017 2018 2019 2020 2021 2022 January 3044 2779 2843 2966 2392 3047 3021 February 3050 2747 2357 2858 2468 3107 2942 March 3051 2219 1920 2802 2207 3020 2304 April 2826 2802 2849 2871 2850 2480 3047 May 2849 2896 2896 3046 3002 3045 3045 June 3049 2903 2802 2776 2789 3046 3046 July 3029 2806 3045 3046 2809 3046 3045 August 2805 2802 3044 3024 3045 3048 3045 September 2810 2802 3045 2681 3045 3048 3045 October 2182 3045 2335 3045 2158 2991 2404 November 2883 2924 2323 2977 3046 2998 3045 December 2984 2873 3006 2802 3047 3005 2755 Yearly 2880 2800 2706 2908 2738 2907 2895 Average Table 2.2-2. BFN Average Daily Water Consumption by Month from Wheeler Reservoir (2016-2022) (million gallons per day) 2016 2017 2018 2019 2020 2021 2022 January 0.6 1.1 1.0 1.0 0.5 2.7 8.2 February 7.0 1.2 1.0 1.0 0.9 0.6 4.8 March 7.4 3.4 2.3 1.0 4.2 5.7 1.0 April 0.9 1.1 7.8 4.0 24.2 2.9 2.4 May 0.8 1.1 1.1 2.0 1.8 0.9 0.6 June 5.0 4.8 1.1 2.0 6.8 1.7 1.4 July 0.9 5.2 1.1 2.0 14.8 1.7 0.4 August 3.9 0.6 0.4 6.0 0.7 3.6 0.9 September 1.0 0.5 0.4 13.0 0.8 3.5 0.9 October 9.4 1.2 5.5 1.0 3.9 2.5 5.9 November 0.8 0.6 3.6 6.0 1.7 1.2 0.5 December 2.6 0.9 1.0 1.0 3.1 1.1 5.8 Yearly 3.4 1.8 2.2 3.3 5.3 2.3 2.7 Average Table 2.2-3. Annual Hazardous Waste Generation for BFN from 2016 to 2021 Year Hazardous Waste Generation at BFN (pounds) RCRA Generator Status 2016 3,797 Small Quantity Generator 2017 4,220 Small Quantity Generator 2018 5,376 Small Quantity Generator 2019 6,275 Small Quantity Generator 2020 8,485 Small Quantity Generator 2021 7,118 Small Quantity Generator 2022 2,390 Small Quantity Generator Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-13

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 2.2-1. BFN Site Overview Map Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-14

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 2.2-2. BFN In-Scope Transmission Lines Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-15

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 2.3. Refurbishment Activities 10 CFR 54.21 requires a demonstration that the effects of aging will be adequately managed so that the intended system functions will be maintained consistent with the current licensing basis throughout the period of extended operation. The BFN SLR application (SLRA) contains this demonstration. The BFN SLR does not require any new construction or modifications beyond normal maintenance. No transmission system upgrades are expected to be needed in support of the SLR. However, there are other proposed projects not directly related to SLR that are connected to, or could affect, license renewal. TVA has no plans for refurbishment or replacement activities, outside of normal maintenance at BFN associated with SLR. TVA has addressed refurbishment activities in this Environmental Report in accordance with NRC regulations and complementary information in the NRC GEIS for license renewal. 2.4. Programs and Activities for Managing the Effects of Aging Changes to power plant operations, inspections, maintenance activities, systems, and administrative control procedures designed to manage the effects of aging during the SLR term are described in the body of the BFN SLRA and associated Appendices A (Final Safety Analysis Report Supplement) and B (Aging Management Programs), as required by 10 CFR Part 54. Implementing such aging management activities during the SLR term will not substantially alter previously reviewed environmental impacts from BFN. 2.5. Employment Approximately 2,147 people work at BFN Units 1, 2, and 3: approximately 900 contract employees and 1,248 permanent employees. Approximately 83.2 percent of the employees live in Alabama, 7.0 percent live in Tennessee, and the remaining 9.8 percent is distributed across 35 other states, with numbers ranging from one to 41 people per state. Almost 80 percent of all BFN employees live in the following counties in Alabama: Lauderdale County (32.9 percent), Limestone County (18.4 percent), Colbert County (10.4 percent), Madison County (9.0 percent), and Morgan County (5.4 percent), and Lawrence County (2.2 percent). The cities of Athens (Limestone County), Florence (Lauderdale County), and Muscle Shoals (Colbert County), and the towns of Killen (Lauderdale County), and Rogersville (Lauderdale County) have the highest numbers of employees in residence, with 13.5, 12.8, 4.6, 9.0, and 7.2 percent, respectively. During the 28-to-45 day regularly scheduled refueling outages, staggered on a 24-month cycle for each unit, the normal plant staff is supplemented by approximately 900 contract workers. These outage workers are either permanent residents of the region or stay in temporary housing locations assumed to be distributed similar to the locations in which permanent employees live. TVA anticipates that existing surge capabilities for routine activities, such as outages, will enable TVA to perform the surveillance, monitoring, inspections, testing, trending, and recordkeeping workload without increasing the BFN staff. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Accordingly, the current employment figures reported above are considered representative of those during the subsequent period of extended operation. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-16

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 2.6. Alternatives to the Proposed Action Section 2.1 describes the proposed action, which is for NRC to renew the existing RFOLs for BFN Units 1, 2, and 3 for an additional 20 years beyond the current expiration dates. Because the decision before the NRC is to renew or not renew the existing RFOLs, there is only one fundamental alternative to the proposed action: the no-action alternative. Under the no-action alternative, the NRC would deny SLR. Unlike the proposed action of subsequently renewing the existing RFOLs, denying SLR does not provide baseload generation capability to meet future system generating needs beyond the term of the current RFOLs. Therefore, unless replacement generating capacity is provided as part of the no-action alternative, a large amount of baseload generation would no longer be available, and the alternative would not satisfy the purpose and need for the proposed action (see Section 1.1). For this reason, the no-action alternative has two components: replacing the baseload generating capacity of BFN and decommissioning BFN Units 1, 2, and 3. Baseload resources are used primarily to provide continuous, reliable power over long periods of uniform demand due to their lower operating cost. Baseload resources typically have higher construction costs than other alternatives, but also have lower fuel and variable costs. Nuclear power plants are baseload resources. Larger coal units and natural gas-fired combined cycle plants may also be used as incremental baseload generators. A peaking unit is typically used to serve only intermittent and short-lived spikes in demand, and may be called on from time to time to run continuously for a limited period even though it may be less economical to do so. Peaking units are essential for maintaining system reliability requirements because they can start up quickly to meet sudden changes in either demand or supply. Typical peaking resources include natural gas-fired frame combustion turbines, aeroderivative combustion turbines, and conventional hydro generation. Intermediate resources are used primarily to fill the gap in generation between baseload and peaking needs. Intermediate units are required to produce variable output as the energy demand changes over time, both during the course of a day and seasonally. Intermediate generation comes from natural gas-fired combined cycle plants, smaller coal units, and from wind and solar generation. Chapter 7 presents, in some detail, the methodology of identifying actions that could be taken to replace the baseload generation capacity of BFN in the region. Alternative generating technologies were evaluated to identify candidate technologies that are capable of replacing BFN generating capacity at the time the BFN Unit 1, Unit 2, and Unit 3 RFOLs expire in 2033, 2034, and 2036 respectively. For purposes of this environmental report, TVA considers a combination of the following power source alternatives to the subsequent license renewal which could implement the generation replacement component of the no-action alternative:

Natural gas-fired combined cycle generation (Section 7.2.1.1)
Natural gas-fired combustion turbine generation (Section 7.2.1.2)
Solar (Section 7.2.1.3)
Storage (Section 7.2.1.4)
New Nuclear - Small Modular Reactors (Section 7.2.1.5)

Section 7.2.2 discusses additional alternatives that TVA has determined are not reasonable and the bases for these determinations (i.e., renewable resources [other than solar], oil, coal, purchase power, demand-side management, and delayed retirement). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-17

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 2.7. References NRC (Nuclear Regulatory Commission). 2005. Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3. NUREG-1437, Supplemental 21. June 2005. NRC. 2013a. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG-1437, Volume 1, Revision 1. Office of Nuclear Reactor Regulation. June 2013. NRC. 2013b. Preparation of Environmental Reports for Nuclear Power Plan License Renewal Applications. Regulatory Guide 4.2, Supplemental 1, Revision 1. June 2013. NRC. 2017. Environmental Assessment and Finding of No Significant Impact for Browns Ferry Nuclear Plant, Units 1, 2, and 3. May 2017. TVA (Tennessee Valley Authority). 1972. Browns Ferry Nuclear Plant Units 1, 2, and 3 Environmental Statement. Volume 1. TVA-OHES-EIS-72-6. September 1972. TVA. 2002. Final Supplemental Environmental Impact Statement for Operating License Renewal of the Browns Ferry Nuclear Plant in Athens, Alabama. March 2002. TVA. 2019. 2019 Integrated Resource Plan. Volume 1 - Final Resource Plan. June 2019. TVA. 2020a. Browns Ferry Nuclear Plant Thermal Performance Program Cooling Tower Capacity Improvements Environmental Assessment. June 2020. TVA. 2020b. Clean Water Act Section 316(b) § 122.21(r)(9) Entrainment Characterization Study for the Browns Ferry Nuclear Plant. River and Reservoir Compliance Monitoring Program. TVA. 2021a. Browns Ferry Nuclear Plant 2020 Annual Radioactive Effluent Release Report. April 30, 2021. TVA. 2021b. Transmission System Routine Periodic Vegetation Management Final Environmental Assessment. Fiscal Years 2022 and 2023. October 2021. TVA. 2022. Browns Ferry Nuclear Plant 2021 Annual Radioactive Effluent Release Report. May 2, 2022. TVA. 2023a. Browns Ferry Nuclear Plant. Accessed January 24, 2023 at https://www.tva.com/energy/our-power-system/nuclear/browns-ferry-nuclear-plant. TVA. 2023b. 2022 Annual Radiological Environmental Operating Report. Tennessee Valley Authority Browns Ferry. May 15, 2023. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E2-18

Appendix E - Applicants Environmental Report-Operating License Renewal Stage CHAPTER 3 - AFFECTED ENVIRONMENT The Browns Ferry Nuclear Plant (BFN) site is located on the north shore of Wheeler Reservoir in Limestone County, Alabama, at Tennessee River Mile (TRM) 294.0 (Figures 3.0-1 and 3.0-2). The site is an approximately 880-acre tract approximately 9 miles south of United States (U.S.) Highway 72 and is directly accessible from the north via Shaw Road and from the east via Nuclear Plant Road. Shaw Road intersects U.S. Highway 72 approximately 6 miles north of the site and Nuclear Plant Road intersects U.S. Highway 31 approximately 9 miles east of the site (Figure 3.0-2). No major metropolitan areas are located within the 6-mile radius (Figure 3.0-2). The site is 10 miles northwest of the center of Decatur, Alabama, 10 miles southwest of Athens, Alabama, and 30 miles west of Huntsville, Alabama (Figure 3.0-1). The area within 6 miles of the site includes parts of Limestone, Lawrence, and Morgan Counties (Figure 3.0-2). The area around BFN is predominantly flat to gently rolling agricultural farmland or forest. BFN is located on property owned by the United States and held in the custody of the Tennessee Valley Authority (TVA), a corporate agency and instrumentality of the United States. The protected area for the three-unit plant, including the intake and discharge channels, is enclosed by a security fence. Primary access to the protected area is by way of the West Access Control Portal Building. The plant has the following principal physical structures in the central site area: a reactor building, a turbine building, a service building, a maintenance building, two diesel generator buildings (one for Units 1 and 2 and one for Unit 3), a radioactive waste building, administration building, a Diverse and Flexible Coping Strategies equipment storage building, an intake pumping station, a 161-kilovolt (kV) switchyard and a 161-kV capacitor yard, a 500-kV switchyard, an off-gas stack, wastewater lagoons, and two independent spent fuel storage facility installation pads. Northwest of the central site area are the hot water and cold water discharge channels and seven mechanical draft helper cooling towers. To the east of the central site area are a meteorological tower, the Training Center, employee physical fitness center, low-level radioactive waste and hazardous waste storage areas, and a materials storage and procurement complex (see Figure 2.2-1). The BFN site is situated in an area where the land is used primarily for agriculture. The surrounding area includes open pasturelands, scattered farmsteads, a few residential areas to the northwest and southeast of BFN, and little industry within several miles. The terrain is flat to gently rolling with open views to higher elevations to the north. The south and west side of the plant site abuts Wheeler Reservoir, which is used for an array of purposes. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-1

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 3.0-1. 50-Mile Radius Map Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-2

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 3.0-2. 6-Mile Radius Map Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-3

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 3.1. Land Use and Visual Resources 3.1.1. Offsite Land Use BFN is located on Wheeler Reservoir at TRM 294.0. The Wheeler Reservoir extends from Guntersville Dam at TRM 349.0 to Wheeler Dam at TRM 274.9. Land use within a 6-mile radius of BFN is primarily open water (22.1 percent), cultivated crops (32.5 percent), hay and pasture (15.2 percent) and woody wetlands (12.3 percent). Deciduous forest, developed open space, and emergent herbaceous wetlands are other land uses within the 6-mile radius of BFN. Figure 3.1-1 shows the land cover within a 6-mile radius of BFN. Table 3.1-1 shows land cover in the 6-mile region based on data downloaded from the National Land Cover Database (NLCD) 2019 (NLCD 2019). TVA manages Wheeler Reservoir, which has 1,063 miles of shoreline and a total surface area of approximately 67,070 acres (TVA 2017). Less than one percent of the shoreline miles on Wheeler Reservoir is privately owned and available for residential shoreline development; 54 percent of this privately owned shoreline is already developed with residential subdivisions (TVA 2017). TVAs 2017 Wheeler Reservoir Land Management Plan updated the allocation of approximately 36,045 acres of TVA-managed land to seven planning zones (TVA 2017). Of this land, 70 percent is allocated as natural resource conservation, 13 percent is project operations, 10 percent is sensitive resource management, 4 percent is developed recreation, three percent industrial, and less than one percent is shoreline access (TVA 2017). Project operations is land currently used, or planned for future use, for TVA operations and public works projects. Mallard-Fox Creek Wildlife Management Area (WMA) is located about 2.5 miles from BFN on the southern shore of Wheeler Reservoir in Lawrence County, Alabama. This WMA is comprised of 1,483 acres of mixed habitats including hardwood forests, grasslands, and agricultural fields (Alabama Birding Trails 2021c). The Decatur/Wheeler Lake KOA Holiday is located approximately 2.2 miles west of BFN on the southern shore of Wheeler Reservoir. Cowford Campground is located approximately 3.0 miles southeast of BFN on the northern shore of Wheeler Reservoir in Limestone County. Swan Creek Wildlife Management Area is located approximately 6 miles east of BFN on the Northern shore of Wheeler Reservoir in Limestone County Alabama. This WMA is 8,870 acres of mixed habitat including wetlands, open water, and mixed hardwood forests. It is open to the public for waterfowl and small game hunting during the hunting season. There is also a firing range which is open during the offseason (Muscle Shoals National Heritage Area 2023). The following sections look specifically at land use in the three counties located within the 6-mile radius of BFN, Limestone, Lawrence, and Morgan counties. Limestone County Limestone County is situated in northwest Alabama. The county is bordered by Lauderdale County to the west, Madison County to the east, and Lawrence and Morgan Counties to the south on the southern shore of Wheeler Reservoir. Northern Limestone County is bordered by Giles and Lincoln Counties in Tennessee (Figure 3.0-1). Limestone County is approximately 559 square miles or 357,760 acres of land (Siebenthaler 2020). Limestone County has several types of natural features due to its location at the foothills of the Appalachian Mountains. Limestone Countys southern borders extends 77 miles along Wheeler Reservoir, which is formed from impounding dams on the Tennessee River, Guntersville Dam at TRM 349 and Wheeler Dam at TRM 274.9 (TVA 2017). Wheeler National Wildlife Refuge is a unit of the Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-4

Appendix E - Applicants Environmental Report-Operating License Renewal Stage National Wildlife Refuge System consisting of 35,000 acres of Limestone and Morgan County. The land is used to manage and protect a diverse range of habitats including federally listed, threatened, or endangered species. Recreational activities at Wheeler National Wildlife Refuge include wildlife education and observation, hiking, boating, fishing, and seasonal day camps (USFWS 2017, USFWS 2020). Limestone County has various types of trails including seven public birding trails along Wheeler Reservoir and throughout Wheeler National Wildlife Refuge (Alabama Birding Trails 2021b). Other trails and outdoor recreation areas sit along the Elk River which flows for 15 miles from Veto, Alabama south to Wheeler Reservoir (Limestone County 2021c). Limestone County contains six cities, with the City of Athens acting as the county seat (Limestone County 2021a). The City of Athens published a future land use and development plan in 2013 that discusses further urban development and expansion plans to meet the needs of their growing population (Martin 2013). Similar to the overall population of the state, Limestone County is experiencing population growth (USCB 2020f). In 1969, 301,295 acres of land were used for agriculture (USDA 1969). By 2017, only 224,822 acres of the county land was used for agriculture, representing a total loss of 76,473 acres of farmland in Limestone County, or 25.4 percent (USDA 2017b). Lawrence County Lawrence County is situated in northwest Alabama. The county is bordered by Morgan County to the east, Cullman County to the southeast, Winston County to the south, Colbert and Franklin Counties to the west, and Lauderdale and Limestone Counties across Wheeler Reservoir to the north. Lawrence County is approximately 693 square miles or 443,520 acres (Lawrence County Chamber of Commerce 2021a). Lawrence County has many natural features. Bankhead National Forest takes up a quarter of the countys southern portion. Lawrence County is also home to many other natural areas, including Joe Wheeler State Park, wilderness areas, and recreation parks (Lawrence County Chamber of Commerce 2021a, Lawrence County Chamber of Commerce 2021b). The section of Wheeler Reservoir that borders Lawrence County extends 64 miles. Lawrence County contains six cities, and the City of Moulton functions as the county seat (City of Moulton 2021). The City of Moulton published zoning ordinances in July 2013 (City of Moulton 2013) that provide the city with regulations on zoning areas like residential communities, industrial and business areas, swimming pools, and permitting. Although there are no zoning, building, or occupancy permits required in unincorporated areas of Lawrence County, other local municipalities have primary authority and responsibility for land development and zoning within their respective limits. As a result, zoning regulations vary from municipality to municipality, with some being much more restrictive than others. However, Lawrence County does have subdivision regulations, a floodplain ordinance, and a pipe/access permit (Lawrence County Road Department 2020). As discussed in detail in Section 3.8.1, the population of Lawrence County is experiencing an overall increase in population. In 1969, there were 260,081 acres of farmland in Lawrence County (USDA 1974). By 2017, there was only 213,747 acres of farmland, which is equivalent to a loss of 46,334 acres, or 17.8 percent (USDA 2017a). Morgan County Morgan County is situated in northwest Alabama. The county is bordered by Limestone and Madison Counties to the north, Marshall County to the east, Winston and Cullman Counties to the south, and Lawrence County to the west. It is approximately 579 square miles of land or Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-5

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 370,560 acres (USCB 2022). Morgan County is abundant with natural resources. The county seat, the City of Decatur, has many parks and recreational areas throughout the built-up urban areas along Wheeler Reservoir (Morgan County Alabama 2021a). In addition to Wheeler National Wildlife Refuge, there are multiple trails and wildlife areas for recreation, including Point Mallard Park along the Tennessee River and viewing sites on the North Alabama Birding Trail (City of Decatur Alabama 2023). There are seven cities/towns in Morgan County, and the rest of the land is unincorporated areas (Morgan County Alabama 2021b). Most of Decaturs land use within the 6-mile radius is developed high and medium intensity land along Wheeler Reservoir with hay/pasture, cultivated crops, forests, and various water features as shown in Figure 3.1-1. The section of Wheeler Reservoir that borders Morgan County extends 40 miles, formed from impounding dams on the Tennessee River. In 1969, agricultural land use within Morgan County consisted of 231,500 acres (USDA 1969). By 2017 there was only 134,864 acres of farmland, representing a loss of 96,636 acres of farmland, or 41.7 percent of farmland (USDA 2017c). As discussed in Section 3.8.1, although Morgan County and Decatur, its largest city, are near BFN, the majority of BFN employees live in other Alabama counties. Located on Wheeler Reservoir approximately 10 miles from BFN, the City of Decatur shares a border with the City of Huntsville, one of Alabamas fastest growing cities. The City of Decatur also includes Wheeler Wildlife Refuge within its limits. Plans for Decatur include capitalizing on its unique natural resources, its access to Interstate 65, and its proximity to Huntsville. Plans to improve the quality of life in Decatur include creating recreational and civic development opportunities along the riverfront; thus improving the connection with an increasingly vibrant and pedestrian friendly downtown (City of Decatur 2018). 3.1.2. Onsite Land Use The BFN site consists of approximately 880 acres (Figure 3.1-2). The BFN generation facility includes many buildings and facilities as described in Section 3.0 (also see Figure 2.2-1). NLCD land cover classifications onsite in the undeveloped areas of BFN as hay/pasture, herbaceous, open water, deciduous forest, mixed forest, cultivated crops, woody wetlands, barren land (rock/sand/clay), evergreen forest, shrub/scrub, and emergent herbaceous wetlands. However, the land cover classifications are based on satellite data and may not represent actual ground conditions. For example, no hay/pasture or cultivated crops are actually grown within the BFN property. Table 3.1-2 shows the amount of onsite acreage in various land cover categories (NLCD 2019). 3.1.3. Visual Resources The terrain on either side of Wheeler Reservoir is relatively flat to gently rolling. Overall, the area surrounding BFN is rural with single lane roads and agricultural and forested areas. With the exception of the Paradise Shores neighborhood northwest of BFN and the residential area southeast of BFN, residences near BFN are sparse and generally associated with agricultural fields or are in small clusters to the northwest and southeast of BFN (Photo 3.1-1). The active portions of the BFN facility are visible from Wheeler Reservoir and the surrounding area located to the south and west. BFN is also visible at night due to exterior night lighting. The largest structures onsite are the reactor building and turbine building; the tallest structure on the site is the off-gas stack. Additional structures visible from the south and west of BFN (on or Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-6

Appendix E - Applicants Environmental Report-Operating License Renewal Stage across Wheeler Reservoir) include transmission towers and lines, the switchyard, parking areas, and cooling towers (Photo 3.1-1). There is a small residential area to the north of the cooling towers, but there are wooded areas that block the view of the site. Water vapor plumes may be present and visible from nearby residences when the cooling towers are in operation. The cooling towers, which create the water vapor plumes, operate when river temperatures near one or more of the National Pollutant Discharge Elimination System (NPDES) permit limits and cool the water prior to being released into Wheeler Reservoir. When the cooling towers are not operating, no water vapor plumes are present. Views from the west are the most imposing as the scale of the plant is more obvious from water level and across Wheeler Reservoir. Although the plant contrasts as an industrial feature in an otherwise rural setting, it is not a dominant feature from most views due to its distance from residences and the presence of wooded areas around BFN. Photo 3.1-1 presents a view of the BFN facility from the southwest and illustrates the agricultural and undeveloped land to the north and northeast of the facility - where few observers will be present. It also illustrates the visual shield that the berm and landscaping present southwest of the intake forebay. The most visually obvious structures are the reactor building, cooling towers and the off-gas stack. Photo 3.1-2 presents a view looking to the south of BFN. The land on the southern side of Wheeler Reservoir is forested and includes Mallard-Fox Creek WMA. The forested areas help shield the view of the facility from observers across Wheeler Reservoir. Therefore, observers that have the most imposing view of the plant are recreational boaters and fishermen on the water. Photo 3.1-1. A view of the BFN facility from the southwest looking northeast Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-7

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Photo 3.1-2. A View of the area looking to the south of the plant Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-8

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 3.1-1. NLCD Land Cover Within a 6-Mile Radius of BFN Property Boundary 6-Mile Radius Land Use/Land Cover Type Percent of Total (%) Acreage Cultivated Crops 23,499.40 32.45 Open Water 15,999.16 22.10 Hay / Pasture 10,985.12 15.17 Woody Wetlands 8,894.84 12.28 Deciduous Forest 3,070.03 4.24 Developed, Open Space 2,334.35 3.22 Emergent Herbaceous Wetlands 1,550.93 2.14 Developed, Low Intensity 1,208.94 1.67 Evergreen Forest 1,128.78 1.56 Developed, Medium Intensity 1,016.20 1.40 Developed, High Intensity 796.43 1.10 Mixed Forest 705.49 0.97 Shrub/Scrub 561.86 0.78 Herbaceous 454.66 0.63 Barren Land (Rock/Sand/Clay) 201.62 0.28 Total 72,407.82 100.0 Source: Land cover data from NLCD 2019 (as shown in Figure 3.1-1). Table 3.1-2. NLCD Land Cover Within the BFN Property Boundary1 Land Use/land Cover Type Onsite Acreage Percent of total (%) Hay / Pasture 233.16 26.70 Developed, Medium Intensity 174.87 20.02 Developed, High Intensity 92.85 10.63 Developed, Low Intensity 87.05 9.97 Herbaceous 52.34 5.99 Deciduous Forest 43.89 5.02 Open Water 41.91 4.80 Developed, Open Space 33.69 3.86 Cultivated Crops 30.10 3.45 Mixed Forest 29.50 3.38 Woody Wetlands 26.71 3.06 Barren Land (Rock/Sand/Clay) 16.81 1.92 Shrub/Scrub 5.83 0.67 Evergreen Forest 4.79 0.55 Emergent Herbaceous Wetlands 0.22 0.03 Total 873.72 100.0 1 Fee acreage for the BFN Reservation is approximately 880 acres. A land survey has not been conducted to create a Geographic Information System (GIS) shapefile of the property. The GIS shapefiles of the BFN Reservation used for this analysis includes 873.72 acres of the property. Source: Land cover data from NLCD 2019 (as shown in Figure 3.1-2). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-9

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 3.1-1. 6-Mile Radius BFN NLCD Land Use/Land Cover Map Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-10

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 3.1-2. Onsite BFN NLCD Land Use/Land Cover Map Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-11

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 3.2. Meteorology, Air Quality, Greenhouse Gases, and Climate Change 3.2.1. Meteorology The BFN site is adjacent to the Wheeler Reservoir impoundment of the Tennessee River which flows northwest at this location. There are no local physiographical features to cause significant climatological anomalies at the site, as the immediate terrain is flat or slightly undulating, with scattered 400- to 600-foot foothills and ridges located 20 to 25 miles to the east through south and southwest. At the BFN site, Wheeler Reservoir averages 1 to 1.5 miles in width. Normally, discontinuities in ambient thermal structure from differential surface heating between land and water should not cause detectable reservoir breeze circulation at the site area. Limited air mass modification may occur within the lower few hundred feet, particularly with southeast winds, when the over-water trajectory may approach 10 miles. The climate at the BFN site is interchangeably continental and maritime in winter and spring, predominantly maritime in summer, and generally continental in fall (Chaney 2020, NOAA 2023a). The mean annual temperature at Decatur, Alabama, is approximately 61.4 degrees Fahrenheit (°F), with mean daily temperatures ranging from 41°F to 80°F (NOAA 2023f). In a typical year at Decatur, there are about 64 days with maximum temperatures equal to or greater than 90°F and about 62 days with minimum temperatures equal to or less than 32°F (NOAA 2023b). From 1991 to 2020, the most extreme daily temperatures recorded at Decatur occurred in June 2012 (105°F) and in January 2011 (2°F) (NOAA 2023d). Much of the annual precipitation at the BFN site results from migratory storms in the winter and early spring (December through April) (NOAA 2023e). Most of the remaining precipitation is in June and July when air mass thundershower activity is common (Chaney 2020, NOAA 2023e). Thunderstorms occurred most frequently in July, August, June, and May (in order of occurrence). November and December had the smallest number of thunderstorms, with an average of one thunderstorm day each month. August usually has the lowest precipitation (NOAA 2023e). BFN is located in an area occasionally traversed by cyclonic storms. While wind speeds in excess of 40 miles per hour (mph) are occasionally reported, wind speeds in excess of 75 mph are rare. The estimated probability of a tornado occurrence at the BFN site in any one year is 6.979E-04, or about one occurrence in 1,433 years should be expected. In spite of the low probability, the plant is designed to withstand tornado forces. Over 60 confirmed severe tornadic events occurred in Limestone County between 1909 and 2021, though it is unknown how many of these occurred in the immediate vicinity of BFN (NOAA 2023c). On April 27, 2011, an historic outbreak of 62 tornadoes occurred in Alabama. (Call et al. 2013, NWS 2011). Collection of onsite meteorological data at BFN commenced in February 1967 from a meteorological tower located about 0.5 mile north-northeast of the reactor building and about 25 feet above plant grade. This facility was moved in early 1970 to a new location approximately 0.7 mile north-northwest of the reactor building and about 10 feet above plant grade. In March 1973, the facility was moved to its present location about 0.5 mile east-southeast of the reactor building and about 30 feet above plant grade. A BFN meteorological program has been developed to be consistent with the guidance given in Nuclear Regulatory Commission (NRC) Regulatory Guide 1.23 (Revision 0) and the reporting procedures in Regulatory Guide 1.21 (Revision 1). The basic objective is to maintain data collection performance to assure at least 90 percent joint recoverability and availability of data needed for assessing the relative concentrations and doses resulting from accidental or routine releases. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-12

Appendix E - Applicants Environmental Report-Operating License Renewal Stage The permanent meteorological facility consists of a 91-meter (300-foot) instrumented tower for wind and temperature measurements, a separate 10-meter (33-foot) tower for dew point measurements, a ground based instrument for rainfall measurements, and a data collection system in an instrument building [(Environmental Data Station (EDS)]. The data collected include: wind speeds and directions at the 33-, 150-, and 300-foot levels (wind data collection at 150 feet began on April 23, 1976); temperatures at the 33-, 150-, and 300-foot levels (temperature data collection at four feet ended on May 24, 1979); and dewpoint temperatures at the 33-foot level (dewpoint data collection at 150- and 300-foot level ended on March 6, 1978 and the 4-foot level dewpoint data collection ended on November 15, 1978). The dewpoint sensor was moved to a separate tower on September 27, 1994. Rainfall is monitored from a rain gage located about 70 feet from the tower. The meteorological sensors are connected to the data collection and recording equipment in the EDS. A system of lightning and surge protection circuitry with proper grounding is included in the facility design. 3.2.2. Criteria and Hazardous Pollutants Under the Clean Air Act (CAA), the U.S. Environmental Protection Agency (USEPA) has established National Ambient Air Quality Standards (NAAQS) (40 Code of Federal Regulations [CFR] Part 50) that specify maximum concentrations for six criteria pollutants: carbon monoxide (CO), particulate matter with aerodynamic diameters of 10 microns or less (PM10), particulate matter with aerodynamic diameters of 2.5 microns or less (PM2.5), ozone, sulfur dioxide (SO2), lead (Pb), and nitrogen dioxide (NO2). NAAQS are classified as primary or secondary. Primary standards protect against adverse health effects; secondary standards protect against welfare effects, such as damage to farm crops and vegetation and damage to buildings. Some pollutants have long-term and short-term standards. Short-term standards are designed to protect against acute, or short-term, health effects, while long-term standards were established to protect against chronic health effects. Areas of the United States that are and have historically been in compliance with the NAAQS are designated by the USEPA as attainment areas. Areas that violate a federal air quality standard are designated by the USEPA as nonattainment areas. Areas that have transitioned from nonattainment to attainment are designated as maintenance areas and are required to adhere to maintenance plans to ensure continued attainment. The USEPA General Conformity Rule applies to federal actions occurring in nonattainment or maintenance areas when the total direct and indirect emissions of nonattainment pollutants (or their precursors) exceed specified thresholds. The emissions thresholds that trigger requirements for a conformity analysis are called de minimis levels. De minimis levels (in tons per year) vary by pollutant and also depend on the severity of the nonattainment status for the air quality management area in question. However, BFN is located in Limestone County, Alabama, which is an attainment area for all criteria pollutants, and therefore the general conformity rule does not apply. In addition to the NAAQS for criteria pollutants, national standards exist for Hazardous Air Pollutants (HAPs), which are regulated under Section 112 of the CAA. The National Emission Standards for Hazardous Air Pollutants regulate HAP emissions from stationary sources including emissions of radionuclide from NRC and federal facilities (40 CFR Parts 61 and 63). However, given the characteristics of radionuclide that are traditionally regulated under the Atomic Energy Act to control and manage the nuclear technology plus very few States have yet developed the technical expertise to independently implement these emission standard requirements under Title V permit program (USEPA 1994), the control of such emissions is not typically considered in the air permitting process. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-13

Appendix E - Applicants Environmental Report-Operating License Renewal Stage The CAA, as amended, established Mandatory Class I Federal Areas where visibility is an important issue. The Sipsey Wilderness Class I area is located approximately 33 miles from BFN. 3.2.3. Permitting This section describes the regulatory setting for air regulations. BFN specific permitting details are discussed in Section 3.2.5. New Source Review (Preconstruction Permit) New major stationary sources and major modifications at existing major stationary sources are required by the CAA to obtain an air pollution permit before commencing construction. This permitting process for major stationary sources is called New Source Review (NSR) and is required whether the major source or major modification is planned for nonattainment areas or attainment areas. In general, permits for sources in attainment areas regulated under the major source program are referred to as Prevention of Significant Deterioration (PSD) permits, while permits for major sources emitting nonattainment pollutants and located in nonattainment areas are referred to as nonattainment new source review permits (USEPA 1990). Additional PSD permitting thresholds apply to increases in stationary source greenhouse gas (GHG) emissions (USEPA 2011). PSD permitting can also apply to a new major stationary source (or any net emissions increase associated with a modification to an existing major stationary source) that is constructed within 6.2 miles of a Class I area (NPS 1993). Title V (Operating Permit) The Title V Operating Permit Program consolidates all CAA requirements applicable to the operation of a source, including preconstruction permits, and the air toxics program. It applies to stationary sources of air pollution that exceed the major stationary source emission thresholds, and other non-major sources specified in a particular regulation. Any TVA facilities subject to Title V permitting comply with the requirements of the Title V Operating Permit Program, which are detailed in 40 CFR Part 70 and all specific requirements contained in their individual permits. 3.2.4. Greenhouse Gases GHGs are gas emissions that trap heat in the atmosphere (USEPA 2023a). Some GHGs are present in the atmosphere naturally, some are released by natural processes and anthropogenic sources, and some are formed from secondary reactions taking place in the atmosphere (IPCC 2021). Natural sources of GHGs include the respiration of humans, animals, and plants; decomposition of organic matter; and evaporation from the oceans. Anthropogenic sources include the combustion of fossil fuels, waste treatment, and agricultural processes (IPCC 2021, Center for Sustainable Systems 2023). The USEPA issued the Final Mandatory Reporting of Greenhouse Gases Rule on September 22, 2009. G The rule requires reporting of annual emissions of carbon dioxide (CO2), methane, nitrogen oxide (NOx), hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, and other fluorinated gases including nitrogen trifluoride and hydrofluorinated ethers. Under the rule, suppliers of fossil fuels or industrial GHGs, manufacturers of mobile sources and engines, and facilities that emit 25,000 or more metric tons per year (tpy) of GHG emissions as CO2 equivalent are required to submit annual reports to USEPA (USEPA 2009). GHG emissions are also regulated under PSD and Title V permitting programs, which was initiated by a USEPA rulemaking issued on June 3, 2010, known as the GHG Tailoring Rule (75 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-14

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Federal Register [FR] 31514). GHG emissions thresholds for permitting of stationary sources are an increase of 75,000 CO2-equivalent (CO2e) tpy at existing major sources and facility-wide emissions of 100,000 CO2e tpy for a new source or a modification of an existing minor source. The 100,000 CO2e tpy threshold defines a major GHG source for both construction (PSD) and operating (Title V) permitting, respectively (USEPA 2010). However, USEPA will no longer apply or enforce federal regulatory provisions or provisions of the USEPA approved Title V programs that require a stationary source to obtain a Title V permit solely because the source emits or has the potential to emit GHGs above the major source thresholds (77 FR 41051) (USEPA 2012). Global warming potential (GWP) is a concept developed to compare the ability of each GHG to trap heat in the atmosphere relative to CO2. The GWP of a specific GHG is based on several factors, including the relative effectiveness of that gas in absorbing infrared radiation and length of time (i.e., lifetime) that the gas remains in the atmosphere (atmospheric lifetime). The reference gas for GWP is CO2; therefore, CO2 has a GWP of 1. The other main GHGs that have been attributed to human activity include methane (CH4), which has an estimated GWP of 27-30 over 100 years, and nitrous oxide, which has a GWP of 273 for a 100-year timescale (USEPA 2023b). For example, 1 ton of CH4 has the same contribution to the greenhouse effect as approximately 27-30 tons of CO2. GHGs with lower emissions rates than CO2 may still contribute to climate change because they are more effective at absorbing outgoing infrared radiation than CO2 (i.e., high GWP). The concept of CO2e is used to account for the different GWP potentials of GHGs to absorb infrared radiation (Center for Sustainable Systems 2023). 3.2.5. Climate Change Scientific evidence indicates a trend of increasing global temperature over the past century due to an increase in GHG emissions from human activities. Climate change refers to any significant change in measures of climate, such as temperature, precipitation, or wind lasting for an extended period (decades or longer). The climate change associated with global warming is predicted to produce negative economic and social consequences across the globe. Climate change is primarily a function of excessive CO2 in the atmosphere. CO2 is the primary GHG emitted through human activities. The southeast region where BFN is located is predominantly powered by coal, natural gas, and nuclear power plants and contains extensive oil and gas infrastructure that is essential to the nations energy supply. The majority of these generation sources, with the exception of nuclear energy, are significant producers of GHGs. The Fourth National Climate Assessment concluded that global climate is projected to continue to change over this century and beyond (USGCRP 2018). Climate change has already been affecting public health, natural resources, and infrastructure within all regions of the country. More frequent and intense extreme weather and climate-related events, and changes in average climate conditions, are expected to continue to damage infrastructure, ecosystems, and social systems that provide essential benefits to communities. As changes in the climate become more frequent and/or severe, it is anticipated that a variety of sectors will experience greater physical risks that result in infrastructure and environmental damage, and the loss of life. Climate change is likely to exacerbate existing challenges to prosperity posed by aging and deteriorating infrastructure, stressed ecosystems, and economic inequality. Physical climate risks often disproportionately impact disadvantaged communities, and the potential risks from climate change on the most vulnerable populations need to be considered. Climate change impacts in an area could include rising temperatures and heat waves, severe drought, intense rainfall, sea level rise, hurricanes, and wildfires (USGCRP 2018). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-15

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 3.2.5.1. Temperature Trends Average Annual Temperature Temperatures in Alabama were relatively stable throughout the 1900s, the state is located in one of few areas across the globe that have experienced no net warming. Temperatures have been warming in the state in recent years, though they have not yet exceeded the peak temperatures recorded in the 1920s-1930s. The 5-year interval from 2016-2020 was the warmest consecutive interval. (Runkle et al. 2022). Extreme Heat In its Hazard Mitigation Plan, the State of Alabama defined extreme heat days as those when the maximum temperature exceeds 90°F. The National Weather Service (NWS) began collecting information on extreme heat event data in 2008. Since 2008, local NWS field offices in Alabama have reported 13 extreme heat episodes. That equates to about 1.4 extreme heat episodes per year. In the records for Alabama, such extreme heat events are generally localized affecting three or fewer counties; however, events in June 2009 and August 2010 affected seven and eight counties respectively. Both events affected Limestone and other surrounding counties. No deaths were reported for these extreme heat events in Alabama; however, several were reported to cause injuries and hospitalizations. The number of extreme heat days and heat waves (consecutive days exceeding 95°F) are both projected to increase throughout the 21st century (State of Alabama 2018). 3.2.5.2. Precipitation Trends Average Annual Precipitation Average annual precipitation has been increasing by about 30 percent during the fall season in the southeastern United States since 1901. However, at the same time, drought has been increasing by about 9 percent, with more moderate to extreme droughts in the spring and summer increasing by 12-14 percent since the mid-1970s. This contrast between wetter falls and drier spring and summer seasons is attributed to more intense storms, with longer periods of dryness between precipitation events (Janasie J.D. 2014). The annual variability in precipitation does not indicate an overall trend. (Runkle et al. 2022). Extreme Precipitation Extreme precipitation events (those of 3 or more inches) have remained near or above average since 1995; no statistically significant long-term trends have been observed. It is projected that extreme precipitation events will eventually increase somewhat with time because it is assumed that atmospheric water vapor will increase along with temperatures (Runkle et al. 2022). 3.2.5.3. Acute Weather Trends Though BFN is located inland, it is located close enough to the coastline that it can be affected by hurricanes and tropical storms. Effects can include flooding (from both storm surge on the coastline and increased precipitation) and wind damage (from hurricane-force winds and spawned tornadoes). In Alabama, the most extreme and deadliest weather hazards are tornadoes and hurricanes. Historic tornadic activity in the vicinity of BFN is described in Section 3.2.1 (Runkle et al. 2022). Since 2000, five hurricanes have affected Alabama (Runkle et al. 2022), with the biggest effects being storm surge related flooding (Strauss et al. 2015). While BFN is located far enough from shore that the immediate effects from hurricanes are not a factor, as the storms move inland, they can cause inland flooding, cause wind damage, and spawn tornadoes. There has been no long-term trend in hurricane occurrence affecting Alabama over the past century (Runkle et al. 2022). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-16

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 3.2.6. Browns Ferry Emission Sources and Permits The air pollutant emission sources at BFN include the auxiliary boilers, the emergency diesel or propane fired generators, and miscellaneous sources such as fuel storage facilities. BFN is not considered a major source of emissions subject to NSR or PSD programs discussed previously and is therefore not required to obtain a Title V air permit (TVA 2020a). BFN operates under a synthetic minor source permit (Permit No. 708-0003-X005) issued on November 6, 2020 by Alabama Department of Environmental Management (ADEM) (TVA 2020a). BFN tracks monthly operating hours for each equipment on a 12-month rolling basis. As of July 7, 2022, BFN generated a total of 17,593 tpy CO2e and has been operated in compliance of the synthetic minor source permit conditions. This amount represents approximately 0.02 percent of Alabama energy-related 2016 emission inventory for GHG in terms of CO2 reported by U.S. Department of Energy (EIA 2019). 3.3. Noise Noise at BFN is generated by onsite equipment such as diesel generators, transformers, and cooling towers. The largest amount of noise from BFN which can periodically be heard offsite is from the cooling towers. The cooling towers operate most frequently during the summer months when neighborhood houses utilize air conditioning units, which mask potential outside intrusive noise. There are no noise complaints on record for BFN. Although there are no federal, state, or local municipal noise standards, regulations or ordinances that are applicable to the subsequent license renewal (SLR), USEPAs noise control guideline (USEPA 1974) recommended average annual equivalent day/night sound level (DNL) of 55 decibels in A-weighted scale (dBA) to protect the health and well-being of the public can be used as a measure of annoyance from industrial noise in a noise sensitive neighborhood. Furthermore, as recommended by the Federal Interagency Committee on Noise (FICON 1992), a 3-dBA or greater increase in DNL indicates a possible impact when the background is 60 dBA or less. A 24-hour ambient noise sample was collected at BFN on August 8, 2012, when the cooling towers were in operation, and on September 6, 2012, when none of the cooling towers were operating (Ensafe 2012). The noise measurements on both dates were measured at the location of the nearest residence to BFN in the Paradise Shores Community, approximately 1,500 feet from the BFN property boundary. Based on the 24-hour noise measurements, the DNLs were calculated to be 61.9 dBA and 59.7 dBA with and without cooling towers operating, respectively (Ensafe 2012). A second 24-hour ambient noise assessment was conducted between July 30 and July 31, 2020 at the same sample location as in 2012, during which a DNL of 62.5 dBA was calculated (Cardno 2020). The most recent measurement collected at this location between August 1 and August 2, 2022 shows a 61.4 dBA in DNL (Cardno 2022) when the cooling towers were in operation, which is slightly lower but comparable as compared to the 2020 measurement. The measured sound levels were similar to the 2012 DNLs, indicating that ambient noise levels around the BFN have remained essentially unchanged over the years. Additionally, the USEPA noted that if a community is accustomed to the noise levels and the noise maker maintains a positive relationship with the community, then the day/night average sound level can be lowered by 5.0 dBA (USEPA 1974). After this correction, the average DNL measured most recently in August 2022 would be 56.4 dBA. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-17

Appendix E - Applicants Environmental Report-Operating License Renewal Stage The results of these noise surveys, which focused on impacts to nearby residences (Cardno 2020, Ensafe 2012), indicate that the noise from the dominant sources at the BFN, i.e., operation of cooling tower(s) is barely noticeable by identified noise sensitive receptors in the vicinity. 3.4. Geologic Environment 3.4.1. Geology BFN is located on the southern margin of the Highland Rim section of the Interior Low Plateaus physiographic province (USGS 2000). This is characterized by a young-to-mature plateau exhibiting moderate relief. Elevations vary from 600 feet above mean sea level (amsl) on the north shore of Wheeler Reservoir to approximately 800 feet amsl 10 miles north at Athens, Alabama. Surface water generally flows from the northeast to the southwest through Poplar, Round Island, and Mud Creeks. BFN is located on a river terrace surface with an average elevation of 575 feet amsl; the plant grade is 565 feet amsl. This surface represents a historic floodplain developed when the Tennessee River was flowing at a higher level. The most recent floodplain is now inundated by the waters of Wheeler Reservoir. Throughout most of the Paleozoic Era, the region was at or slightly below sea level, and more than 5,000 feet of limestone, dolomite, and shale were deposited. The plateau on which the BFN site lies is underlain by near-horizontal limestone strata of Mississippian age having an aggregate thickness of slightly over 1,000 feet. According to the Alabama Geological Survey, the formations and their maximum thicknesses, in ascending order are: Fort Payne (207 feet); Tuscumbia (200 feet); Ste. Genevieve (43 feet); Bethel (40 feet); Gasper (160 feet); Cypress (7 feet); Golconda (70 feet); Hartselle (200 feet); and Bangor (90 feet). The bedrock is mantled by varying thicknesses of cherty clay, silt, sand, and gravel of residual and alluvial origin. The only formations within the BFN Reservation are the unconsolidated materials overlying bedrock and the Tuscumbia Limestone and the Fort Payne Formation. A brief description of each of these follows. Figure 3.4-1 provides a geologic cross section of the site. Unconsolidated Deposits - Within the site area, bedrock is overlain by red and yellow clay containing some residual chert boulders and lenses of sand and gravel. This material varies in thickness from a known minimum of 41 feet to a known maximum of 69 feet. Tuscumbia Limestone - Only the lower 50 feet of the Tuscumbia formation was encountered at the BFN site. The Tuscumbia is characterized by medium-to-thick beds of light-gray, medium-to-coarse-crystalline, fossiliferous limestone. The Tuscumbia Limestone is more affected by solution than the Fort Payne Formation. Practically all the cavities encountered at the site were developed in this formation. Fort Payne Formation - The maximum known thickness of the Fort Payne formation in northern Alabama is slightly over 200 feet. At the BFN site, the total thickness, penetrated in one drill hole, is 145 feet. The formation consists of medium-bedded, medium to dark gray, silty dolomite and siliceous limestone with a few thin horizons of shale. Near the top of the formation, some of the beds are cherty. Quartz- and calcite-filled vugs (cavities) up to one inch in diameter are the most distinguishing lithologic feature. The development of solution cavities in the Fort Payne Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-18

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Formation are inhibited by the siliceous nature of the limestone. In general, excavation grades for the major structures of BFN were set in the Fort Payne formation. Since the end of the Paleozoic Era the area has been above sea level and has been subjected to numerous cycles of erosion resulting in a general peneplanation. During its history this immediate region has been one of little structural deformation. Major folds and faults are entirely absent. The rock strata are only slightly warped with regional dips of less than 1 degree to the southeast away from the Nashville dome and toward the foreslope of the Appalachian geosyncline (TVA 2014). The regional structure in the BFN area is controlled by the Nashville dome. The area lies on the southeast flank of this dome and the regional dip is to the southeast. This regional trend is commonly obscured by the slight local variations in dip caused by minor folding. In general, axes of these secondary flexures trend northwest-southeast, which is compatible with a regional trend on the flank of the Nashville dome. In the immediate site area, the beds of the Tuscumbia and Fort Payne formations are essentially horizontal. The direction of dip varies considerably but has an overall westward major component. Bedrock is cut by a pattern of near-vertical joints, and close to the surface of bedrock solution channels have developed along these joints, especially in the Tuscumbia Limestone. At depth in the less soluble Fort Payne, the joints are tight and most are cemented with calcite. During its history this immediate region has been one of little structural deformation. Faulting is not a significant factor in considering the geologic structure in the BFN area. No active faults showing recent surface displacement are known within a 200-mile radius of the site. The nearest known ancient fault is in Lawrence County, Alabama, 16.5 miles to the west-southwest from the BFN site and is one of three apparently related near-vertical faults. The vertical displacement varies from 0 to 60 feet and cuts Mississippian bedrock. At the BFN site, the only indications of any rock movement are small shears along bedding planes which represent minor readjustments between beds when the area was uplifted at the end of the Paleozoic Era. 3.4.1.1. Seismicity BFN is located in an area remote from any centers of significant seismic activity. A few major earthquakes centered at distant points, several light-to-moderate shocks at distant points, and several light-to-moderate shocks with nearer centers have affected the area at low-to-moderate intensity (TVA 2014). Figure 3.4-3 provides a map of earthquake epicenters within 50 miles of BFN. Figure 3.4-4 presents a seismic hazard map within 50 miles of BFN; BFN is in a low to moderate hazard zone. To evaluate the earthquake hazard at the plant site, a 2014 study of the known seismic history of a large surrounding area was conducted by TVA (TVA 2014). The study was facilitated by research carried over a period of three decades on the seismicity of the southeastern United States with a focus on the Tennessee Valley. Research of files of earthquake data, collected from a number of sources, were used in the compilation of seismic histories. By plotting the epicenters of the earthquakes, the areas of continuing seismic activity became apparent (TVA 2014). The more active areas are as follows (TVA 2014):

a. Mississippi Valley, especially the New Madrid region of Missouri, Arkansas, Tennessee and Kentucky. The New Madrid region is about 170 miles northwest of the plant site.

The area has been the center of several large earthquakes, and a large number of smaller earthquakes are still occurring at intervals. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-19

Appendix E - Applicants Environmental Report-Operating License Renewal Stage

b. The Lower Wabash Valley of Indiana and Illinois. The Lower Wabash Valley is about 225 miles north-northwest from the plant site. This area has been the center of moderately strong earthquakes, some of which were felt as far south as Tennessee.

c. Charleston area, South Carolina. Charleston is about 420 miles east of the plant site. At least one very large earthquake was centered in the Charleston area in 1886. Many other light-to-moderate earthquakes have occurred in this area and the activity has continued to the present time.

d. The Southern Appalachian area of western North Carolina and eastern Tennessee. This area is centered about 200 miles east of Decatur. Light-to-moderate earthquakes occur in this area on average once or twice a year.

In addition to these areas, earthquakes of light-to-moderate intensity have occurred at many other localities in the southeastern states at various distances from BFN. At many of these localities, only a few light-to-moderate earthquakes from widely scattered centers are known (TVA 2014). From 1974 through 2022, only 12 earthquakes Richter magnitude (M) 2.5 or higher were centered within 30 miles of BFN; one M3.9 earthquake occurred on the August 20, 1989, centered about 2.5 miles east of East Florence. During this same period, 100 earthquakes ranging from M2.5 to M4.6 were centered within 100 miles of BFN, only 26 of these earthquakes were greater than M2.9. The top 4 earthquakes from 1974 to 2022 within 100 miles of BFN were M3.9, M3.9, M4.5, and M4.6 centered near East Florence, Pleasant Groves, Fayette, and Valley Head, respectively, the greatest occurring in April 2003 (USGS 2023a). There has been no seismic activity of M2.5 or higher at the site (within a radius of 3.2 miles) since 1974. The only seismic activity recorded at the site with a minimum magnitude of 0.1M was 1.6M earthquake 4.35 miles northeast of Hillsborough, AL, on May 14, 1999 (USGS 2023b). BFN is founded on a thick succession of essentially horizontal sedimentary rocks. The site is 16.5 miles from the nearest known inactive fault and approximately 200 miles from the New Madrid region of the Mississippi Valley. Light shocks have been centered near Huntsville, Hazel Green, Anniston, Cullman, Easonville, and Birmingham, but most of them were low intensity. The earthquakes felt most strongly in the BFN area have been major earthquakes centered at distant points, especially in the Mississippi Valley. There is continuing seismic activity in the Mississippi Valley, and there is the possibility of another large earthquake in the New Madrid region of Missouri, Arkansas, Tennessee, and Kentucky. An earthquake of intensity XI or XII on the Modified Mercalli Intensity Scale at New Madrid might be felt in the Decatur area with an intensity of VII. Overall, the BFN site is underlain by massive formations of bedrock, thus, providing adequate foundations for all plant structures. The major seismic activity experienced at the site has been caused by distant major earthquakes (TVA 2014). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-20

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 3.4-1. Agricultural Soil Characterization Details USDA Soil Farmland of Map Prime Erosion Soil Series Texture Statewide Designation Farmland Potential Classification Importance Abernathy Emory, 0 to fine sandy Af Yes No 0.32 2 percent slopes loams Emory Abernathy, 0 to Asu silt loams Yes No 0.43 6 percent slopes Abernathy Emory, 0 to Asv silt loams Yes No 0.43 2 percent slopes Cumberland eroded Cde clay loam Yes No 0.28 undulating phase Cumberland undulating fine sandy Cfu Yes No 0.28 phase loam Cumberland severely Cmd silty clay loam No No 0.28 eroded rolling phase Cumberland eroded Cme silty clay loam Yes No 0.28 undulating phase Cumberland undulating Csu silt loams Yes No 0.32 phase Cumberland level Csv silt loams Yes No 0.32 phase Decatur, 2 to 6 percent DbB2 silty clay loam Yes No 0.32 slopes, eroded Decatur, 6 to 10 Dmd percent slopes, silty clay loam No Yes 0.28 severely eroded Decatur eroded rolling Dmn silty clay loam No Yes 0.28 phase Dewey, 2 to 6 percent Dwe silty clay loam Yes No 0.24 slopes, eroded Dewey, 6 to 10 percent Dwn silty clay loam No Yes 0.28 slopes, eroded Esv Etowah level phase silt loam Yes No 0.32 Guthrie , 0 to 2 percent Gl slopes, occasionally silt loam No No 0.43 flooded Ln Lawrence silt loam Yes No 0.32 Lobelville , 0 to 3 Lo percent slopes, silt loam Yes No 0.32 occasionally flooded Ml Melvin silt loam No Yes 0.37 Os Ooltewah silt loam No No 0.43 Rl Robertsville silt loam No No 0.43 Source: (NRCS 2023) Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-21

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 3.4-1. Geological Cross Section of the BFN Site Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-22

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 3.4-2. BFN Soil Map Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-23

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 3.4-3. Earthquake Epicenters within 50 Miles of BFN Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-24

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 3.4-4. Seismic Hazard Map within 50 Miles of BFN Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-25

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 3.4.2. Soils Soil at the site has been extensively excavated and reworked. Figure 3.4-2 provides the soil map for the BFN property and Table 3.4-1 shows the characteristics of the soil. The initial soil investigation program in 1966 was performed to establish the allowable bearing value for soil-supported structures. It was determined that the original ground surface was at approximately 15 feet above the planned final plant grade. The top 15 to 20 feet was classified as alluvial terrace deposits consisting of a red to reddish brown sandy clay with a lean to medium lean silty clay with a maximum thickness of 30 feet. Below the alluvial terrace deposits was approximately 40 feet of medium to fat clays and plastic silts interbedded with beds of gravelly chert. The groundwater table was detected at an elevation of 555.1 feet amsl, corresponding with the current level of Wheeler Reservoir. A soil investigation was also performed in 1980 to support the Low-Level Radioactive Waste Storage Facility. During that investigation, measured soil thickness varied from 37 to 50 feet. The uppermost layer consisted of red lean clays to depths ranging from 2 to 18 feet deep and averaging 16 feet. Below this layer was an intermediate layer of discontinuous tan to red medium to high plasticity clays. These clays were up to 26 feet thick and averaged 16 feet in thickness. Immediately above bedrock, a continuous layer of basal cherty clay (clayey chert) averaging 18 feet thick was encountered. Soil or vegetation disturbing activities (grading, trenching, etc.) may lead to soil erosion. By minimizing the amount of vegetation disturbed and the extent of soil exposed, soil erosion can be greatly reduced. Any such disruptive activity will include best management practices (BMPs) aimed at reducing soil loss from the site and reduce impacts on nearby water bodies. These BMPs may include sediment basins, silt fencing, straw wattles, straw blankets, and rapid vegetation reestablishment depending on the type and extent of disturbance (TVA 2022c). 3.5. Water Resources 3.5.1. Surface Water Resources 3.5.1.1. Surface Water Hydrology BFN is located on the north shore of Wheeler Reservoir at TRM 294.0 in Limestone County, Alabama. Wheeler Dam is downstream of BFN at TRM 274.9 and Guntersville Dam lies upstream at TRM 349.0. For orientation, TRM 0.0 is downstream of BFN, where the Tennessee River joins the Ohio River in Paducah, Kentucky (TVA 2021d). As described in Section 3.1.1, land use within the Wheeler Lake sub basin includes cultivated crops (32.5 percent), hay and pasture (15.2 percent), and woody wetland (12.3 percent) as the most prevalent land types in addition to open water (22.1 percent). Cities and towns located within the sub-basin include: Albertville, Athens, Boaz, Decatur, Florence, Huntsville, Madison, and Owens Crossroads. Wheeler Reservoir was completed in 1936 as one of the first major dam projects on the Tennessee River for flood control, power generation, and navigation (TVA 2021d, TVA 2021f). It is one of nine reservoirs that create a stairway of navigable water on the 652-mile Tennessee River system from Knoxville, Tennessee, to Paducah, Kentucky (TVA 2021d, TVA 2021f). Wheeler Reservoir covers a surface area of 67,070 acres, has 1,027 miles of shoreline, a water volume of 1.05 million acre-feet, and a hydraulic retention time of 10.7 days. Wheeler Reservoir in the vicinity of BFN ranges in width from 1 to 1.5 miles and is relatively shallow, with an average depth of 15 feet and a maximum depth of 60 feet. Normal summer pool elevation is 556 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-26

Appendix E - Applicants Environmental Report-Operating License Renewal Stage feet amsl, with a minimum level of 550 feet amsl (TVA 2020b, TVA 2021f). Wheeler Reservoir usually reaches summer elevation annually by mid-April (TVA 2004, TVA 2023w). Fall drawdown, in anticipation of winter rains, usually begins after Labor Day (TVA 2021e). The 7Q10 flow rate for the Tennessee River ranged from 4,880 cubic feet per second (cfs) at TRM 333.9 to 8,650 cfs at TRM 256.7 (USGS 2017). TRM 256.7 is located 2.7 miles downstream of Wilson Dam, and TRM 333.9 is located 39 river miles above BFN (USGS 2017). Average daily flow in Wheeler Reservoir past BFN is approximately 47,600 cfs. During the period from February 2018 to December 2019, average daily flow was approximately 71,200 cfs (TVA 2020b). Average streamflow at the dam is 33,500 cfs or 1.1 cfs per square mile of drainage area. Surface water runoff at BFN is derived from precipitation remaining after losses due to infiltration and evapotranspiration. It can generally be classified as local surface runoff or streamflow. Surface water runoff from the plant site is to Wheeler Reservoir. In response to the recommendations of the NRCs Fukushima Task Force, TVA developed a strategy to improve the ability of each TVA operating nuclear plant, including BFN, to cope with a severe accident using lessons learned from the Fukushima accident. TVA did a re-evaluation of flood causing mechanisms for BFN (TVA 2015). BFN is not located within the 100-year floodplain or below the TVA Flood Risk Profile elevation. BFN does not have a history of flooding on site, with TVA records indicating that BFN has never exceeded probable maximum flood level nor critical rainfall amounts that would cause site flooding. Managed by the TVA flood control system, the probable maximum flood would result in increasing Wheeler Reservoir level to 572.5 feet amsl at the site. Safety-related structures are protected against all flood conditions up to elevation 578 feet amsl. Onsite Surface Water Features Field assessments of onsite surface water features were conducted in September 2021 to determine stream, drainage, pond, and wetland presence, extent, and condition within the BFN site (TVA 2021a). Wetland features are discussed in Section 3.6.1. Stream and drainage features present on the BFN site are summarized in Table 3.5-1. Streams were delineated in the field using the methods contained within the U.S. Army Corps of Engineers (USACE) Jurisdictional Determination Form Instructional Guidebook. Streams were assessed and classified as perennial, intermittent, or ephemeral in the field using the Tennessee Division of Water Pollution Controls Hydrologic Determination Field Data Sheet (Version 1.4). The entire length of each stream was walked to assess the various geomorphic, hydraulic, and biological parameters associated with determining stream classification. Delineated stream/drainage features included two constructed ditches, two ephemeral streams, three intermittent streams, and three perennial streams. General descriptions of each feature identified within the BFN site are provided below. See Figure 3.5-1 for feature locations. Stream 1 was identified in the southeastern portion of the site, downstream of Stream 2. The stream was identified southeast of the construction and demolition (C&D) Landfill. Hydrology within the drainage basin has been significantly altered by development. The channel alignment also appears to have been straightened during past activities on the property. Much of the water observed within the channel appears to be backwater from Wheeler Reservoir and not contribution from upstream sources. Fish and amphibians were readily observed along the reach. Hydric soils were also observed within the channel. Stream 1 has an average width of 10.5 feet and average depth of 5 feet. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-27

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Stream 2 was identified in the southeastern portion of the site along the toe of the slope for the C&D Landfill. Hydrology within the drainage basin has been significantly altered by development. Much of the channel bottom is covered by wetland plants. Flowing water was observed, though the stream is dominated primarily by pools and appears to lack the energy required to erode a significant channel through the soil profile. Hydric soils were observed within the channel. Stream 2 has an average width of 6 feet and an average depth of 2 feet. Stream 3 is located downstream of Wetland 2 and flows south into Stream 2. The stream is hydrologically supplied by stormwater runoff that is stored in Wetland 2 and slowly released downstream. Hydrology within the drainage basin has been significantly altered by development. Considering the length of this stream is less than 25 feet, its depth (2.5 feet) suggests that high flows are common following large rain events. Stream 3 lacks much structure in terms of geomorphology and more closely resembles a roadside ditch than a stream. Hydric soils were observed within the channel. Stream 3 has an average width of 3 feet and an average depth of 2.5 feet. Stream 4 was observed northeast of the Materials and Procurement Complex and flows east through the site where the channel dissipates upstream of Wetland 3. Hydrology for this stream has been significantly altered by development. This wet weather conveyance reach lacks the frequent flows and erosive energy necessary to scour out a true channel. Field observations indicate that the stream exhibits flow only immediately following large rain events. The sinuosity of the reach is due to modification of the channel from development of the property. Hydric soils were not observed within the channel. Stream 4 has an average width of 4 feet and an average depth of 0.5 feet. Stream 5 was identified northwest of the Training Center downstream of Stream 6. The stream flows southwest through the property and into Wheeler Reservoir. The channel is severely incised with channel depths exceeding 10 feet. Hydrology within the drainage basin has been significantly altered by development. Aquatic life was observed in the downstream end of the reach where backwater from Wheeler Reservoir extends upstream. Hydric soils were observed within the channel. Stream 5 has an average width of 4 feet and average depth of 2 feet. Stream 6 was identified northwest of the Training Center upstream of Stream 5. The upstream end of Stream 6 is a headwall where stormwater captured by storm infrastructure discharges. The channel bottom and side slopes are lined with rip rap to prevent erosion and scour following rain events. Hydrology within the drainage basin has been significantly altered by development. Water was not observed within the channel of this wet weather conveyance during field investigation. Hydric soils were not observed within the channel. Stream 6 has an average width of 6 feet and an average depth of 2 feet. Stream 7 was identified in the northern portion of the property near the intersection of Paradise Shores and Shaw Road. The stream flows east to west through a narrow portion of the property. Continuous bed and bank, grade control, and in-channel structure were readily observed in the field. The channel is well developed through the soil profile. Aquatic life was observed throughout the reach. Hydric soils were observed within the channel. Stream 7 has an average width of 17.5 feet and an average depth of 8 feet. Stream 8 was identified northeast of the Training Center and flows south through the property to flow into Wheeler Reservoir. The upstream end of Stream 8 is a headwall where stormwater captured by storm infrastructure discharges. The channel bottom and side slopes are lined with rip rap in the upstream portion of the reach to prevent erosion and scour during rain events. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-28

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Continuous bed and bank, grade control, and lack of vegetation within the channel were readily observed in the field. The reach is well developed through the soil profile. Hydric soils were observed within the channel. Stream 8 has an average width of 18 feet and an average depth of 6 feet. Ditch 1 was identified southeast of the Turbine Building and converges with Stream 5 near the property boundary. Backwater from Wheeler Reservoir was observed in the downstream end of the feature. No ordinary high-water mark was observed during field investigation. The channel bottom and side slopes are lined with rip rap to prevent erosion and scour following construction of the channel. Ditch 2 was identified northwest of the cooling towers and extends to the downstream end of Wetland 9. No ordinary high-water mark was observed during field investigation. The channel bottom and side slopes are lined with rip rap to prevent erosion and scour following construction of the channel. Seven ponds totaling approximately 69 acres are present on the BFN site (See Figure 3.5-1 for locations). General descriptions of each feature are provided below. Pond 1 and Pond 2 are adjacent to each other between the Intake Forebay and Training Center. The ponds are lined with an impermeable membrane and likely function to provide water for facility operations. Ponds 1 and 2 appear to be isolated with no outlet structures observed. No vegetation was observed within the ponded areas. Ponds 3, 4, and 5 are adjacent and located north of the 500 kV Switchyard. The ponds are part of a three-pond system designed to manage wastewater from facility operations. The ponds appear to be isolated with no outlet structures observed. Pond 6 is located northwest of the Administration Building between two rows of cooling towers. The pond is divided into three chambers and appears to be used for facility operations. Pond 6 appears to be isolated from adjacent waters with no inlet or outlet structure observed. Pond slopes are lined with rip rap and no vegetation was observed. Pond 7 was identified along the western property boundary adjacent to Wheeler Reservoir. The pond is divided into chambers that provide cold water to facility operations. Water is supplied to Pond 7 via the Intake Forebay located on Wheeler Reservoir. Slopes of the pond are lined with rip rap and no vegetation was observed. 3.5.1.2. Surface Water Use Plant Surface Water Use Wheeler Reservoir is the source for cooling water systems for BFN. BFN uses a once-through or open mode condenser circulating water (CCW) system to dissipate waste heat from the plant steam turbines. The water is withdrawn from Wheeler Reservoir by an intake structure located at about TRM 294.3. For open mode operation, the CCW system is designed to provide a flow of approximately 675,000 gallons per minute (gpm) to the condenser, and a flow of approximately 25,000 gpm to raw cooling water system of each. When all three units are in operation, this water is pumped through the plant at the rate of about 4,400 cfs. Between 2016 and 2022, BFN withdrew an average of approximately 2,833 million gallons per day (MGD). Most of the water withdrawn at the plant intake is returned to Wheeler Reservoir. Water losses by evaporation and drift occur for the CCW system when cooling towers are in service. In Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-29

Appendix E - Applicants Environmental Report-Operating License Renewal Stage addition, a negligible amount of water is lost from the raw cooling water system due to evaporation. Between 2016 and 2022, losses were approximately 3.01 MGD, or 0.11 percent of the total withdrawal. Wheeler Reservoir water use by BFN is managed per the TVA Reservoir Operations Study published in 2004 (TVA 2004). The purpose of the Reservoir Operations Study was to enable TVA to review and evaluate its reservoir operations policy. The policy guides the day-to-day operation of the Tennessee River system. Eleven major issues were evaluated, including reservoir and downstream water quality, environmental resources, reservoir pool levels, recreation flows, economic development, water supply, navigation, flood risk, power reliability, power costs, and capital costs. Discharges from the BFN are regulated by the ADEM NPDES Permit No. AL0022080. The permit (Outfalls DSN001, DSN0011 and DSN0012) requires that BFN report discharge water temperature, pH, chlorine, temperature differentials between upstream and downstream monitoring points, and flow (ADEM 2018). Water withdrawals from the Wheeler Reservoir in 2022 by BFN for cooling water purposes totaled 1,056,013 million gallons, with the highest withdrawal occurring in August (94,399 million gallons) and the lowest withdrawal in March (71,430 million gallons). This resulted in an average withdrawal volume of 88,001 million gallons per month. Return discharges in 2022 totaled 1,055,012 million gallons, with the highest discharges occurring in May, July, and August (94,370 million gallons), and the lowest in March (71,399 million gallons). Average discharge for 2022 totaled 87,918 million gallons per month. This resulted in a consumption of 1,001 million gallons. The highest consumption occurred in January (254 million gallons), and the lowest consumption occurred in July (13 million gallons). The average monthly consumption for 2022 was 83 million gallons per month. Potable water for the BFN is provided by the Athens Municipal Water Supply. In 2022, BFN consumed a total of 993,849 gallons of water. The average monthly consumption was 82,821 gallons, with January having the highest use (101,954 gallons) and October having the lowest use (67,187 gallons). Offsite Surface Water Use Public uses of water from Wheeler Reservoir include water supplies, recreation, and waste disposal. From Decatur, Alabama (located approximately 12 miles upstream from BFN) to the Colbert Steam Plant (about 49 miles downstream from BFN) there are six public (municipal) water intakes on Wheeler Reservoir withdrawing a total of approximately 56 MGD. In that same reach, there are 11 industrial plants withdrawing approximately 1,458 MGD for primarily industrial and limited potable water use. The major public uses of Wheeler Reservoir are for water supplies, recreation, and waste disposal. The nearest community surface water supply, which uses an average of 26.92 MGD, is at Decatur, Alabama, on Wheeler Reservoir 12 miles upstream from BFN. The first downstream water intake, 7.5 miles downstream from BFN, is the West Morgan-East Lawrence Water Authority which uses 4 MGD. There are also major industrial water users located both upstream and downstream within 15 miles of BFN. Upstream from BFN, Amoco Chemicals Corporation (5.5 miles upstream) uses an average of 6.63 MGD, 3M Company Decatur Facility (5.7 miles upstream) uses an average of 12.96 MGD, and Solutia Company (8 miles upstream) uses an average of 120.3 MGD. Downstream from BFN, Champion International (11.4 miles downstream) uses 55.9 MGD. These users withdraw water from Wheeler Reservoir each day for process and cooling needs. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-30

Appendix E - Applicants Environmental Report-Operating License Renewal Stage In 2020, an average of 3,537 MGD (surface water and groundwater) were used for public supply, industrial water supply, irrigation, and thermoelectric power generation in the Wheeler Reservoir Catchment Area. Only 1.4 percent of the total water withdrawn, or about 48 MGD, was used consumptively. Overall, in 2020, an average of 8,368 MGD (surface water and groundwater) were used in the Tennessee River watershed for these same uses (including Wheeler Reservoir). Approximately 4.8 percent of the total water withdrawn, or about 4,032 MGD, was used consumptively. By the year 2045, even though water demands from industry, public water supply and irrigation are expected to increase, overall water withdrawals from the Tennessee River watershed are projected to decline from 2015 levels, primarily due to the retirement of old coal-fired power plants (Sharkey and Springston 2022). 3.5.1.3. Surface Water Quality Regional Surface Water Quality The Clean Water Act (CWA) authorizes the NPDES permit program to control water pollution by regulating point sources that discharge pollutants into waters of the United States. ADEM is authorized by USEPA to administer NPDES permitting rules in Alabama (USEPA 2020). Within ADEM, the Water Division administers the NDPES permits (ADEM 2021). The requirements for NPDES permits are detailed in Alabama Administrative Code Chapter 335-6-6 (ADEM 2015). Wheeler Reservoir is the fifth of nine reservoirs on the Tennessee Rivers 652-mile long main navigation channel, which begins at Knoxville, Tennessee, and joins up with the Ohio River at Paducah, Kentucky (TVA 2021d). Wheeler Reservoir has been routinely monitored for ecological health since 1994, with the most recent comprehensive report showing results for all parameters released in 2018. There are five health indicators that have been used to access aquatic health: dissolved oxygen (DO), chlorophyll, sediment quality, benthic macroinvertebrate community, and fish assemblages. General ecological health has been rated as good or fair for all monitoring years except for 2007 and 2011 when it was rated poor due in large part to the low flow (drought) conditions. Four locations are monitored: forebay (deep, still water near the dam) at TRM 277.0, middle reservoir at TRM 295.9, Elk River embayment (Elk River Mile 6.0), and the inflow (river-like area at the extreme upper end of Wheeler Reservoir) at TRM 348.0 (TVA 2018). Monitoring also occurred in 2019 and 2020, but only the benthic macroinvertebrate community and fish assemblage data are available (TVA 2021c). These results are discussed in Section 3.6.2. Wheeler Reservoir has a notable gradient in DO concentration, decreasing from the surface to the bottom. Low DO concentrations are particularly evident during summer and fall seasons (TVA 2021c). DO in 2017 rated good at the mid-reservoir location, fair at the forebay, and poor at the Elk River embayment. The lower ratings were due to low DO concentrations (less than 2 milligrams per liter) in the lower water column during the summer. DO has rated good at the mid-reservoir location in all previous years, but ratings have varied between good, fair, and poor at the forebay and embayment locations, primarily in response to reservoir flows (TVA 2018). Similarly, health indicators for benthic communities and chlorophyll at each location followed the same pattern as DO because the benthic invertebrates could not tolerate low DO concentrations during the summer and because of elevated chlorophyll levels. Sediment was rated good at all locations except the mid-reservoir location because low levels of polychlorinated biphenyls were detected. All locations were considered good for fish (TVA 2018). Water temperature patterns in Wheeler Reservoir are constantly changing in response to varying meteorological and flow conditions. Natural water temperatures in Wheeler Reservoir vary from around 50°F in January to around 87 - 89°F in July and August, respectively. In-Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-31

Appendix E - Applicants Environmental Report-Operating License Renewal Stage stream temperature patterns upstream from BFN are typically well-mixed or develop only weak thermal stratification. When stratification does occur in the summer, it is approximately a 0.9°F difference concentrated mainly in the top 7 feet where solar radiation has the greatest influence on water temperatures. Most of Wheeler Reservoir is classified by ADEM for use as public water supply, swimming and other whole-body water-contact sports, and fish and wildlife. Water quality is generally good in Wheeler Reservoir, but nutrient loads are a concern. Wheeler Reservoir is on the 2020 Alabama 303(d) list as partially supporting its designated uses due to excess nutrients attributed to agricultural sources (ADEM 2020). In addition, the Alabama Department of Public Health (ADPH) issued fish consumption advisories for certain areas of Wheeler Reservoir due to elevated mercury levels or perfluorooctane sulfonate (PFOS) contamination (ADPH 2020). PFOS is a man-made compound used in a variety of industrial and commercial products. PFOS is no longer manufactured in the United States and its use is being phased out. Mercury occurs naturally in rock and soils but can also originate from other sources, including atmospheric emissions from human activities (fossil fuel combustion, waste incinerations, steel mills) or from natural processes (forest fires, volcanoes) (USEPA 2021). Regulated Releases to Surface Water The NRC requires all licensed nuclear power reactors to comply with regulations limiting radiation doses to members of the public and mandates that radioactive releases contributing to such doses be as low as reasonably achievable (ALARA; 10 CFR Parts 20 and 50 and 40 CFR Part 190). In addition, 40 CFR Part 141 imposes limits on the concentrations of radionuclides, including tritium, in drinking water, provided via public water systems. Each nuclear power plant site has a Radiological Environmental Monitoring Program (REMP) in place specifying sampling frequency of environmental media, and reporting requirements, to meet these requirements. As part of the BFN REMP, TVA analyses the concentration of certain radionuclides, including tritium, in the surface water intake and the discharge structures. Results are reported in the Annual Radiological Environmental Effluent Release Report. In 2021, tritium was released in gaseous and liquid form, and reached the Wheeler Reservoir as described in the Annual Radioactive Effluent Release Report (TVA 2022a) The radioactivity measured in environmental samples in the BFN program can mostly be attributed to naturally occurring radioactive materials. There is no indication that BFN activities increased the background direct radiation levels normally observed in the areas surrounding the plant, as measured by environmental dosimeters. In 2021, trace quantities of cesium-137 (Cs-137) were measured in most soil samples, from both indicator and control locations. In addition, one indicator soil location identified a low-level of Sr-90. The concentrations were typical of the levels expected to be present in the environment from past nuclear weapons. The fallout from accidents at the Chernobyl plant in the Ukraine in 1986 and the Fukushima plant in Japan in 2011 may have also contributed to the low levels of Cs-137 measured in environmental samples. There was no identified increase in Cs-137 levels attributed by BFN. Low levels of gross beta activity were detected in some drinking water samples, but this can be attributed to natural radioactivity. Only naturally occurring radioactivity was identified in all fish and local crop samples, as well air particulate, surface water and shoreline sediment samples (CNS and GEL Labs 2022). ADEM has USEPA authorization to implement the NPDES in Alabama for facilities such as BFN. ADEM (1) regulates thermal discharges in accordance with CWA Section 316(a) to control thermal impacts on the aquatic environment in the receiving water, and (2) implements CWA Section 316(b) requirements to ensure that the location, design, construction, and capacity of industrial cooling water intake structures reflect the best technology available (BTA) for reducing Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-32

Appendix E - Applicants Environmental Report-Operating License Renewal Stage adverse environmental impacts. The BFN NPDES permit (No. AL0022080) also regulates discharges of pollutants to Wheeler Reservoir in outflows including once-through cooling water from the condenser circulating water, raw cooling water, turbine building station sump effluent, intake building sump effluent, and liquid radwaste system (ADEM 2018). The NPDES permit was renewed by TVA with an effective date of July 1, 2018, and expiration date of August 31, 2023. TVA has applied for and anticipates renewal of the NPDES permit in 2023. TVA will continue to renew and comply with the permit as long as the outfalls remain operational. The permit establishes discharge limitations and monitoring requirements for specific constituents by outfall, based on the type of wastewater discharged through the respective outfall. Discharge waters from the CCW system are regulated under NPDES Permit No. AL0022080 (ADEM 2018). The permit specifies that the ambient upstream river temperature shall be determined by an upstream monitor located in the main channel at about river mile 297.8, and that impacts relative to the ambient temperature shall be measured downstream by three monitors located in a line across the reservoir at approximately river mile 293.5 (ADEM 2018). The upstream monitor is located about 3.8 miles upstream of the plant diffusers which are located at TRM 294.0; the downstream monitors are located near the end of a permit-defined mixing zone, which extends a maximum of 2,400 feet (0.45 miles) downstream of the diffusers. The mixing zone is also defined in the permit as being a maximum of 2,000 feet wide and a maximum length of 150 feet upstream of the diffusers (ADEM 2018). The current NPDES permit specifies that at the downstream end of the mixing zone, the operation of the plant shall not cause:

The measured 1-hour average temperature to exceed 93°F,
The measured daily average temperature to exceed 90°F, and
The measured daily average temperature rise (relative to ambient) to exceed 10°F.

3.5.2. Groundwater Resources 3.5.2.1. Groundwater Hydrology Regional shallow groundwater flow is generally to the southwest towards Wheeler Reservoir (Arcadis 2021). Water-level measurements collected at onsite wells installed from 2014 through 2016 suggest that local groundwater flow is also generally to the southwest. However, groundwater flow is complicated due to the presence of building foundations set into bedrock and underground utility corridors located beneath the water table. There are three principal hydrogeologic units on site: unconsolidated sediments (silty/sandy clays and coarse-grained backfill), the underlying Tuscumbia Limestone, and the Fort Payne Chert. The Tuscumbia Limestone weathers readily and can form solution features along some bedding planes or fractures (Arcadis 2021). Groundwater flow in the Fort Payne Chert is likely inhibited by the formations resistance to chemical weathering and limited to fractures and partings. It should be noted that limited data exist relative to the Fort Payne Chert, but borings in the vicinity of the site where Fort Payne Chert is encountered indicate the area is less prone to weathering than Tuscumbia Limestone (Arcadis 2021). It is reasonable to assume that hydraulic connection exists between the bedrock formations and the overlying sediments. Wheeler Reservoir is the primary discharge location for groundwater at BFN. There are also a number of secondary surface water bodies associated with operations that could potentially influence groundwater flow on the site because they are unlined, including the hot water channel, cold water channel, intake channel, wastewater lagoons, and sediment ponds. However, the degree to which these artificially controlled water bodies affect groundwater flow has not been determined. Water level elevations of secondary surface water features, Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-33

Appendix E - Applicants Environmental Report-Operating License Renewal Stage particularly the hot water channel and cold water channel, are controlled by site operations, depending on various plant conditions and reservoir height. Natural and artificial fluctuations in surface water elevations can vary greatly and impact groundwater flow at the site, although these rates are not well quantified. Seasonal groundwater fluctuation strongly correlates with the Wheeler Reservoir elevation, which suggests a high degree of surface water-groundwater communication in both hydrogeologic units (Arcadis 2021). Shallow groundwater at BFN occurs within unconsolidated terrace deposits and residual soils, and along the epikarst, a relatively thin weathered horizon at the top of bedrock. Below the epikarst, groundwater occurs exclusively in fractures and solution features of the Tuscumbia Limestone and Fort Payne Chert. The Tuscumbia Limestone and Fort Payne Chert are collectively described as the Tuscumbia-Fort Payne aquifer system (Arcadis 2021). This aquifer system is the primary water-bearing unit in the site vicinity from a regional perspective since it is a source of water for both wells and springs in the area (USGS 1987). Recharge to the shallow groundwater system at the plant site is derived primarily from precipitation. As stated in the 2021 Site Conceptual Model, annual precipitation ranged from 39.48 inches in 2016 to 57.32 inches in 2020 (Arcadis 2021). As shown in Figure 3.5-2, there are 33 existing groundwater monitoring wells and one dewatering well included in the well sampling program established in the 2021 Site Conceptual Model (Arcadis 2021). Groundwater levels at the site are generally highest during spring and summer and at their lowest in the fall and winter. The direction of groundwater movement is generally west-southwest toward Wheeler Reservoir. Groundwater elevations at some groundwater wells were strongly correlated with Wheeler Reservoir stage levels while groundwater elevations at other exhibited secondary elevation trends that resembled either groundwater extraction or injection cycles over a period of days. This occurred in the general vicinity of the Radwaste Building yard where groundwater elevations are typically lower than other wells near Wheeler Reservoir. Groundwater elevation data collected between April 2020 and April 2021 indicated that some plant process may affect groundwater hydraulics in this area, but the potential groundwater drawdown and recovery in this area has not been determined (Arcadis 2021). Periodic dewatering occurred between 1969 and 1984. Dewatering ceased in 1984 (TVA 2006). Within overburden soils at the site, groundwater movement is predominantly downward. Local areas of lateral flow likely occur near some streams, topographic lows, and where extensive root systems exist. The saturated hydraulic conductivity of site soils in the vicinity of the low-level radiological waste storage facility averages 3.7E-08 feet per second, which is typical of clay soil (Boggs 1982). Based on aquifer testing in a similar setting (TVA 1993), the cherty gravel horizon near bedrock (epikarst) can be significantly transmissive. Measured transmissivity values suggest horizontal hydraulic conductivity values that are from one to two orders of magnitude greater than those measured in the shallow Tuscumbia Limestone (TVA 1993). Observations of groundwater levels during early site borings also suggest that groundwater within the epikarst zone and Tuscumbia-Fort Payne aquifer might be confined (TVA 2006). Groundwater flow in the Tuscumbia Limestone occurs solely in fractured and weathered zones. The orientation of fractures and solution features within the Tuscumbia is coincident with a structurally controlled joint system (i.e., along strike and dip). Studies by TVA indicate that the transmissivities of bedrock fractures and solution features in the Tuscumbia may decrease with depth (TVA 1993). However, the interconnectivity of these features is equally important. Although fractured, the silty, siliceous nature of the Fort Payne Chert inhibits the development of solution features. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-34

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 3.5.2.2. Groundwater Use Offsite Groundwater Use The Tuscumbia-Fort Payne aquifer system provides volumes of water sufficient for domestic supplies and some limited municipal and industrial supplies in the region (USGS 1987). Groundwater supply wells within a 20-mile radius of BFN and privately owned groundwater wells within a 2-mile radius of the BFN site have been identified by TVA. The closest known public groundwater supply well (Limestone County Water System) is located approximately 2 miles north of BFN (Geosyntec 2013). Onsite Groundwater Use There is no groundwater use by BFN, and site dewatering wells have been inactive since the 1980s. However, as shown in Figure 3.5-2, there are 33 existing groundwater monitoring wells and one former dewatering well included in the well sampling program established in the 2021 Site Conceptual Model (Arcadis 2021). 3.5.2.3. Groundwater Quality Offsite Groundwater Quality Groundwater associated with the Tuscumbia-Fort Payne aquifer system is a calcium-bicarbonate type and can generally be used without extensive treatment (Cook 2012). Onsite Groundwater Quality In the early 2000s, BFN initiated the Tritium Releases to Groundwater study to identify the source of low-level tritium detected onsite. Results from a groundwater study conducted in 2006 suggested the source of tritiated groundwater was from historical leaks and spills associated with the Radwaste/Condensate Transfer Tunnel. Groundwater and surface water level measurements during that study indicated the return channel and subsequently the Wheeler Reservoir (Tennessee River) will ultimately be recipient to tritiated groundwater discharge from the site. Groundwater movement in the area has been determined to be from the plant site toward the Wheeler Reservoir (Tennessee River) with no groundwater drinking wells onsite (TVA 2022a). As required by 10 CFR 50.75(g), BFN maintains records of spills involving radioactive contamination in and around the facility, equipment, and site. Between April 2000 and April 2016, there were 15 known releases of tritium. Most of these releases were associated with systems, structures, and components such as the Cable Tunnel, Condensate Transfer Tunnel, Auxiliary Decay Heat Removal System, Condensate Storage Tanks, and Condensate Head Tank. Other tritium releases resulted from spill or leaks from temporary storage containers and frac tanks (Arcadis 2016). From 2016 to 2020, five additional accidental tritium releases occurred at BFN. Each of these releases were estimated to be less than 100 gal., and therefore were not subject to the voluntary reporting requirements outlined in NEI-07-07 (Arcadis 2021) for informing the public of releases that are below the normal NRC reporting threshold. In March 2023 a leak was observed from a demineralized water storage tank and cooling coil. Per 10 CFR 50.72(b)(2)(xi) BFN initiated voluntary communication to the NRC, state of Alabama, and local officials after receiving analysis activity results above the Nuclear Energy Institute Groundwater Protection Initiative threshold. Additional samples collected prior to the water entering the reservoir were at levels less than detectable. This condition did not exceed any NRC regulations or reporting criteria (NRC 2023). Figure 3.5-3 shows the locations of the releases of tritium from April 2000 through July 2020, and descriptions of the releases are provided in Table 3.5-2. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-35

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Onsite groundwater monitoring was performed as part of the Groundwater Protection Initiative, whereby BFN monitored a total of 30 groundwater wells located in the protected area and the owner-controlled area during 2021. Normal sampling frequencies are quarterly and semiannually, and some wells were sampled monthly if certain criteria are met or for investigation purposes. Samples are routinely analyzed for environmental level tritium and principal gamma emitters with selected wells analyzed for Hard-to-Detect radionuclides (Gross Alpha, iron-55, nickel-63, strontium-89, and strontium-90). In support of the groundwater program, the site also monitors recapture and onsite storm drains, catch basins and surface water (TVA 2022a). In 2021, low levels of tritium were detected in onsite groundwater wells; no other plant-related radionuclides were detected in any groundwater well. Tritium concentrations in 2021 groundwater samples ranged from non-detectable [less than 131 picocuries per liter (pCi/L)] to 7,080 pCi/L in MW-01. BFN has been monitoring a legacy tritium plume in the vicinity of groundwater well Dewat-A located adjacent to the reactor building. This plume is the result of previous leaks in 2015 and 2016 (TVA 2022a). Elevated concentrations of tritium have only been observed at monitoring wells located between Wheeler Reservoir and the Power Block. Tritium transport in shallow groundwater primarily occurs along two pathways, advective flow through primary porosity and preferential flow along underground utilities. Groundwater flow and tritium transport direction is expected to vary significantly; however, since Wheeler Reservoir surface elevation is equivalent to the intake channel surface elevation and is almost always lower than the groundwater elevation, the intake channel is the ultimate discharge location for tritium transport via advective groundwater flow, regardless of the temporal variation in transport direction (Arcadis 2021). This is due in part to the location of the intake channel between the suspected sources areas and the Reservoir itself. The second flow path for shallow groundwater is along underground utilities. The four utilities most likely to provide preferential transport of tritium are the Cable Tunnel, the Condensate Transfer Tunnel, the CCW Intake Conduits, and the CCW Discharge Conduits. Preferential flow of groundwater through and/or along these utilities likely accounts for the majority of the tritium transport in shallow groundwater at BFN. Except for well Dewat-A, the highest concentrations of tritium are consistently observed at wells located less than 100 feet from one of these underground utility lines. Because the groundwater elevation is higher than the Wheeler Reservoir and the intake channel, the most likely tritium fate and transport pathway for titrated groundwater in the intermediate bedrock is discharge through shallow groundwater into the intake channel. Tritiated groundwater becomes diluted in the intake channel and is recycled through the plant via the Intake Pumping Station. However, based on 2020 data, groundwater flow conditions and tritium fate and transport indicate that it is not likely that tritium concentrations exceeding the drinking water standard of 20,000 pCi/L will be measured at the intake channel. Furthermore, significant dilution is expected to occur when groundwater discharges to surface water (Arcadis 2021). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-36

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 3.5-1. Summary of Streams and Drainage Features Stream ID Width (ft) at Top of Bank Depth (ft) at Top of Bank TDEC Score Ditch 1 NA NA NA Ditch 2 NA NA NA Stream 1 10.5 5.0 40.0 Stream 2 6.0 2.0 19.0 Stream 3 3.0 2.5 19.0 Stream 4 4.0 0.5 10.5 Stream 5 12.0 9.0 32.5 Stream 6 6.0 2.0 15.0 Stream 7 17.5 8.0 40.5 Stream 8 18.0 6.0 27.5 Source: (TVA 2021a) NA = not applicable Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-37

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 3.5-2. Summary of Historical Releases at BFN Release Location Location Description Date A break in the High Pressure Coolant Injection system return line resulted in impacted water April 2000 entering the Intake Pumping Station at the entrance to the Cable Tunnel. Radioactive (Discovered Radwaste Tunnel to A contamination with trace amounts of Manganese-54 (Mn-54), Cobalt-60 (Co-60), and Cs-137 October Intake were found in numerous locations such as the Pumping Station and Cable Tunnel, Waste 2000) Sump, CCW. The tunnel was decontaminated. A leak occurred in an elbow on the east side of the Cooling Tower and at the overflow of the Auxiliary Decay Heat Cooling Tower Basin due to a malfunction of the system level indicators. Low-level B March 2005 Removal (ADHR) radioactive water was released to the concrete pad and ground. Trace amounts of Co-60, System Zn-65, Mn-54, Cs-134, Cs-137, Silver-110 (Ag-110), and tritium were measured. Soil was excavated. A shipping container carrying used Control Rod Drives leaked contaminated water onto the November Roadway at Plant C shipping trailer and the roadway, affecting a small (3-foot square) area. Based on hydrostatic 2005 Office Building testing of the container, the leak was apparently caused by handling activities. Cable Tunnel (between the Turbine January Water from an unknown source was discovered (containing tritium, Cs-137, Cs-134, and Co-D Building and the 2006 60). Intake Pumping Station) Degraded expansion joints in the Condensate Transfer Tunnel may have allowed releases to Condensate Transfer E June 2006 groundwater. An evaluation of the tunnel noted that there was no liner, some joints were in Tunnel poor shape, several inches of water are often present, and there was a floor drain and sump. January A leak from an unknown source, along with groundwater, was discovered bubbling out of the F Water Exfiltration 2008 ground near the nitrogen tank. Samples were determined to contain low levels of tritium. Condensate Storage Approximately 11,000 gal. of impacted water overflowed into the Condensate Transfer January G Tank (CST) No. 3 Tunnel, with the following constituents: tritium, Mn-54, Co-60, Iodine-131, Cs-134, and Cs-2008 Overflow 137. The majority of the water was collected in sumps. A drum was dropped while in transport via forklift, and the contents (containing tritium, Mn-Radwaste Building H March 2010 54, Co-60, Co-58, and Cs-137) were spilled outside of the Radiologically Controlled Area but Parking Area inside the Protected Area. The water was collected with absorbent media. Water was discovered to be flowing from an open test valve near the top of Condensate I April 2010 CST No. 5 Release Storage Tank No. 3. Approximately 330 gallons were released (containing tritium, Mn-54, Co-60, Co-58, and Cs-137). Soil was excavated. A leak from a valve was identified and was believed to be due to system freezing. The leak December J ADHR Cooling Tower rate was estimated at 0.5 gallons per minute, with an affected are of approximately 100 2010 square feet. The valve was replaced, and dirt from the area was excavated. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-38

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Release Location Location Description Date January Radwaste Building Frac berms tested positive for tritium. Water from berms was pumped back to Frac 1 and K 2013 Parking Area tested when dry. Smears taken once dry showed no contamination. February Radwaste Building Frac #1 tank overflow due to heavy rain. The puddle outside the berm was pumped back into L 2013 Parking Area Frac #1 tank and ponded water on asphalt was absorbed. January- CST-grade, tritiated water flooded the basement floor of Radwaste Building for a 6-month M Radwaste Basement June 2013 period. It is not known whether tritium was released to the environment during this period. January Condensate Head A 0.5-gallon per minute leak from an air release valve was identified, with water (containing N 2015 Tank tritium) accumulating on the concrete-lined reactor/refuel air zone intake and on the ground. A leak within the Unit 2 Turbine Building Steam Tunnel was found, and tritiated water reached groundwater through degraded expansion joints within the tunnel room. A blockage O March 2016 Unit 2 Steam Tunnel in a floor drain allowed contaminated water to pool on the floor and reach the degraded expansion joints. The expansion joints were repaired via coating application. A leak was observed from the Unit 2 steam exhaust on the Reactor Building Roof, resulting December P Reactor Building Roof in approximately 80 gallons of tritiated water leaking from the exhaust. It is unclear if tritiated 2016 water reached the ground before the leak was repaired. A leak occurred at the Unit 1 Condensate Head Tank when the vacuum relief valve became stuck open. The leak volume was estimated to be less than 50 gallons before the leak was Q May 2017 Reactor Building Roof repaired. The tritiated water overflowed the tank and ran down the side of the Reactor Building onto the ground. Multiple leaks were observed from hose connections attached to a steel frac tank. A small January Radwaste Building R volume of tritiated water (less than 2 gallons) was released to the ground. The water was 2018 Yard frozen when found and the impacted soil was excavated. A leak of less than 100 gallons of tritiated water occurred while rigging the 3A4 Feed Water February Unit 3 Condenser Heater from the Unit 3 condenser bay to the Unit 3 Condenser Tube Pull-Out Area. Most of S 2018 Tube Pull-Out Area the spill was contained within the Pull-Out Area, but some volume may have entered a nearby storm drain or the surrounding ground. A leak was observed at the Unit 3 CST due to severe corrosion to the piping and valve. Approximately 88 gallons of tritiated water was released to the surrounding concrete and soil. T July 2020 CST No. 3 Some of the release was routed to the Condensate Transfer Tunnel before the leak was repaired. A leak was observed from a demineralized water storage tank and cooling coil. Per 10 CFR March 2, 50.72(b)(2)(xi) BFN initiated voluntary communication to the NRC, state of Alabama, and U1 Water Storage Tank 2023 local officials after receiving analysis activity results above the Nuclear Energy Institute Groundwater Protection Initiative threshold. Source: (Arcadis 2021) 1 Source: (NRC 2023) Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-39

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Source: (TVA 2021a) Figure 3.5-1. Delineated Surface Water Features Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-40

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Source: (Arcadis 2021) Figure 3.5-2. BFN Site Monitoring Wells Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-41

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Source: (Arcadis 2021, NRC 2023) Figure 3.5-3. Historical Release Locations at BFN Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-42

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 3.6. Ecological Resources This section describes the ecological resources that may be affected by the operation of BFN during the subsequent period of extended operation. The characteristics of the region, the site vicinity, and the site are described in the introduction to Chapter 3, Section 3.1.1 (Offsite Land Use), Section 3.1.2 (Onsite Land Use), Section 3.4.2 (Soils), Section 3.5.1 (Surface Water Resources), and Section 3.6.1 (Terrestrial and Wetland Communities). Potentially affected water bodies are described in Section 3.6.2 (Aquatic Communities) and Section 3.5.1 (Surface Water Resources). Relevant historical characteristics of ecological resources in the vicinity of BFN are described in the sections listed above. Places and entities of special ecological interest in the vicinity of the plant are described in Section 3.6.1.2 (Wetlands) and Section 3.8.3 (Recreation). 3.6.1. Terrestrial and Wetland Communities 3.6.1.1. Community Characteristics BFN is located on an approximately 880-acre tract on the north shore of Wheeler Reservoir at TRM 294.0, approximately 10 miles northwest of Decatur, Alabama, and 10 miles southwest of Athens, Alabama. Much of the BFN site is covered in plant facilities, paved and gravel parking lots, roads, and mowed grass fields. The BFN property includes approximately 2.5 miles of Wheeler Reservoir shoreline. According to the USEPA, BFN is located in the Interior Plateau ecoregion (Griffith et al. 2001). This ecoregion is dominated by oak-hickory and mesophytic forests. The historic bottomland hardwood forests common to the Interior Plateau have been mostly inundated by the impounded waters of the Tennessee River and other natural streams that cross the region. The Interior Plateau ecoregion has soils that are rich, deep, and intensively used for agriculture. Wetlands in this ecoregion are most commonly associated with the floodplains of these streams and river systems; although springs and seepage wetlands occur as well. The area surrounding BFN includes multiple fields that are used for row crop production. In the areas of the BFN property along the shoreline of Wheeler Reservoir, a typical riparian habitat is present. This section describes the characteristics of the natural communities on the BFN site, including terrestrial plants and animals, wetlands, invasive/non-native species, and special-status species. Terrestrial Plants Fragments of forest remain scattered across the BFN site. Forests are mixed deciduous-evergreen or deciduous. Herbaceous areas are primarily mowed grass with a small amount of more variable vegetation on a wet section of right-of-way. A vegetation survey was conducted in forested areas of the BFN property over two days in April 2023. No uncommon plant communities or rare plant species were found on the BFN property. The forested survey areas were categorized as three zones (Figure 3.6-1). Zone 1 was a southeastern forest area in the southeast portion of the BFN property. It is adjacent to the shoreline of the river and covers 12.5 acres. Over 20 distinct woody plant species, and very few nonnative species, were observed in this area. Species present include willow oak (Quercus phellos), black oak (Quercus velutina), cherrybark oak (Quercus pagoda), Carolina buckthorn (Frangula caroliniana), bitternut hickory (Carya cordiformis), tulip poplar (Liriodendron tulipifera), and yellow buckeye (Aesculus flava). Herbaceous species present in the understory included seven true sedges (genus Carex) and three fern species. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-43

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Zone 2 includes 36.5 acres of forest with vegetation diversity similar to that in Zone 1, but with an increase in nonnative plants. Multiflora rose (Rosa multiflora), Chinese privet (Ligustrum sinense), Virginia pine (Pinus virginiana), broomsedge (Andropogon virginicus), poison ivy (Toxicodendron radicans), and Japanese honeysuckle (Lonicera japonica) were more prevalent than in Zone 1, and the forest structure was much more condensed, providing less habitat for some of the herbaceous ground cover species found in Zone 1. Zone 3 includes two other woody areas covering a total of 47.8 acres. There was a marked drop off in vegetation quality within this zone. The dominant species in these areas include Bradford pear (Pyrus calleryana), black locust (Robinia pseudoacacia), Japanese honeysuckle, poison ivy , trumpet vine (Campsis radicans), and Virginia creeper (Parthenium quinquefolia). Overall, these Zone 3 areas were the densest and had the lowest overall species diversity among the forested areas surveyed at BFN. While there are some residential and wooded areas near BFN, the surrounding area is essentially dominated by regularly maintained grassy areas and fields used for agricultural production of row crops. Terrestrial Animals As most areas on the BFN site have been previously disturbed and provide limited wildlife habitat, the terrestrial wildlife species found at BFN are common and have widespread distributions. No uncommon wildlife communities or important terrestrial habitats occur within or immediately adjacent to BFN. Developed areas and areas otherwise previously disturbed by human activity, including the large areas of mowed fields, provide habitat that may be used by a number of common wildlife species. Birds observed in these areas during site visits in September include the Canada goose, house finch, killdeer, mourning dove, and rock dove. Other birds likely to occur include the American robin, American crow, Carolina chickadee, European starling, house sparrow, Carolina wren, northern cardinal, northern mockingbird, black vulture, and turkey vulture (National Geographic 2002). During a field survey, an osprey nest was observed, and a colony of cliff swallow nests was observed around the outside of the reactor building. Mammals likely to occur in the disturbed community include the eastern gray squirrel, striped skunk, and raccoon (Whitaker 1996). Road-side ditches provide potential habitat for amphibians such as the American toad and upland chorus frog. Reptiles potentially present include the eastern black kingsnake and gray rat snake (Gibbons and Dorcas 2005, Powell et al. 2016). Forest fragments on BFN property may provide habitat for common birds such as the American robin, barred owl, blue-gray gnatcatcher, blue jay, brown thrasher, common yellowthroat, eastern bluebird, eastern phoebe, eastern towhee, eastern wood peewee, gray catbird, red-eyed vireo, red-shouldered hawk, ruby-throated hummingbird, scarlet tanager, and yellow-breasted chat. Species observed in forest areas during site visits in September include the Carolina wren, eastern wood pewee, northern cardinal, northern flicker, pileated woodpecker, red-bellied woodpecker, summer tanager, and white-eyed vireo. Mammals observed in these fragments were the armadillo, gray squirrel, and white-tailed deer. Other mammals likely to occur include the raccoon, eastern chipmunk, and Virginia opossum. Amphibians and reptiles likely to occur here include the eastern box turtle, Fowlers toad, gray treefrog, and gray rat snake. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-44

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Constructed channels around the cooling units provide foraging and loafing habitat for wading birds and waterfowl. Species observed in this area include the black duck, Canada goose, great blue heron, double-crested cormorant, and mallard. Some existing rights-of-way are early successional habitats rather than mowed grass fields. Areas with a wider variety of vegetation may be used by birds such as the chipping sparrow, field sparrow, house finch, killdeer, grasshopper sparrow, mourning dove, red-tailed hawk, red-winged blackbird, wild turkey, and white-throated sparrow (National Geographic 2002). Mammals that may occur in these areas are the common mole, coyote, least shrew, white-footed mouse, and white-tailed deer (Whitaker 1996). Reptiles that may use these habitats in this region include the black racer, gray rat snake, corn snake, eastern black kingsnake, and scarlet kingsnake (Gibbons and Dorcas 2005). Emergent wetlands and saturated wet weather conveyances within field settings provide habitat for common amphibians. Amphibians likely to be present include the American bullfrog, American toad, southern leopard frog, spring peeper, and upland chorus frog (Powell et al. 2016). 3.6.1.2. Wetlands Wetlands are those areas inundated or saturated by surface or groundwater such that vegetation adapted to saturated soil conditions is prevalent (USACE 33 CFR Part 328(b); USEPA 40 CFR 230.3(t)). Examples include bottomland forests, swamps, wet meadows, isolated depressions, and shoreline fringe along watercourses or impoundments. Due to their landscape position, vegetation structure, and influence on downstream hydrology, wetlands provide a suite of benefits valued by society. These include toxin absorption and sediment retention for improved water quality, storm water impediment and attenuation for flood control, shoreline buffering for erosion protection, and provision of fish and wildlife habitat for commercial, recreational, and conservation purposes. Because of this, wetlands are protected under federal and state laws that mandate wetland avoidance, minimization of impacts, and compensation for loss of wetland function resulting from regulated activities. The BFN site is located in the Upper Lake Wheeler watershed (HUC10 0603000211). The National Wetland Inventory (NWI) uses coarse aerial imagery to identify potential wetlands at a large scale. Within the Upper Lake Wheeler watershed, the NWI maps approximately 90,000 acres of wetland habitat, covering roughly 42 percent of the watersheds total acreage. The BFN site covers approximately 880 acres on the north side of Wheeler Reservoir. Nine wetlands, totaling 24.1 acres, were delineated and assessed across the BFN site during the field reconnaissance for the license renewal (Table 3.6-1). Identified wetlands cover less than 3 percent of the BFN study area, which is a smaller percentage than that mapped by the NWI at the watershed scale (Buecker 2021). As discussed in Section 3.5.1, field assessments were conducted in September 2021 to determine wetland presence, extent, and condition within the BFN site (TVA 2021a). The wetland determinations were performed according to the USACE standards, which require documentation of hydrophytic (wet site) vegetation, hydric soil, and wetland hydrology (Environmental Laboratory 1987, USACE 2012). Wetland condition was evaluated using a TVA-developed modification of the Ohio Rapid Assessment Method (Mack 2001) specific to the TVA region (TVA Rapid Assessment Method [TVARAM]). Wetlands were evaluated by their functions and classified into three categories: low quality, moderate quality, and superior quality. Low quality wetlands are degraded aquatic resources which may exhibit low species diversity, minimal hydrologic input and connectivity, recent or on-going disturbance regimes, and/or predominance of non-native species. These wetlands provide low functionality and are considered of low value. Moderate quality wetlands provide functions at a greater value due to a Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-45

Appendix E - Applicants Environmental Report-Operating License Renewal Stage lesser degree of degradation and/or due to their habitat, landscape position, or hydrologic input. Moderate quality wetlands are considered healthy water resources of value. Disturbance to hydrology, substrate, and/or vegetation may be present to a degree at which valuable functional capacity is sustained and there is reasonable potential for restoration. High-quality wetlands include those wetlands that offer superior functions and values within a watershed or that are of regional/statewide concern. High-quality wetlands may exhibit little, if any, recent disturbance, provide essential and/or large-scale stormwater storage, sediment retention, and toxin absorption, contain mature vegetation communities, and/or offer habitat to rare species. Conditions found in high quality wetlands often represent restoration goals for wetlands functioning at a lower capacity. The nine delineated wetlands on the BFN site cover a total 24.1 acres (Table 3.6-1; see Figure 3.5-1 for locations). These wetlands are primarily located on the eastern portion of the BFN site and include emergent, scrub shrub, and forested wetland communities that exhibit a range of resource values. Each of these wetlands is described below. Wetland 1 is an emergent wetland located adjacent to a stream in the southeast portion of the BFN site. Surface water, water table, and saturation were observed during field investigation. Hydrophytic vegetation observed within the wetland included Virginia buttonweed (Diodia virginiana), soft rush (Juncus effuses), fox sedge (Carex vulpinoidea), and swamp smartweed (Persicaria hydropiperoides). Soil samples taken within the wetland exhibited hydric indicators, including F7 (depleted dark surface), F8 (redox depressions), and F12 (iron-manganese masses). This wetland scored as low quality using TVARAM, indicating poor provision of wetland functions. Wetland 2 is an emergent wetland located in the southeast portion of the BFN site. Stormwater runoff from a roadside ditch and adjacent upland areas appears to be the primary water source for this wetland. Surface water, water table, and saturation were observed during field investigation. Hydrophytic vegetation observed within the wetland included Virginia buttonweed, soft rush, fox sedge, and swamp smartweed. Soil samples taken within the wetland area exhibited hydric indicators, including F7, F8, and F12. This wetland scored as low quality using TVARAM, indicating poor provision of wetland functions. Wetland 3 is an emergent wetland located in the southeast portion of the BFN site. The wetland drains south through a culverted road crossing to a stream. Surface water, water table, and saturation were observed during field investigation. The primary source of hydrology is stormwater runoff from surrounding upland areas. Hydrophytic vegetation observed within the wetland area included smooth false buttonweed (Spermacoce glabra) and soft rush. This wetland is located within a drainage ditch lacking an ordinary high-water mark. Soil samples taken within the wetland exhibited hydric indicators including F7, F8, and F12.This wetland scored as low quality using TVARAM, indicating poor provision of wetland functions. Wetland 4 is an emergent wetland located in the central eastern portion of the BFN site. Portions of the wetland have been channelized during past development of the property. Channelized portions of the wetland did not possess an ordinary high-water mark. The primary source of hydrology for this wetland appears to be concentrated stormwater runoff upstream of the wetland and sheet flow runoff from adjacent uplands. Hydrophytic vegetation observed within the wetland area included false buttonweed, swamp smartweed, soft rush, and southern cattail (Typha domingensis). Soil samples taken within the wetland exhibited hydric indicators, including F12. This wetland scored as low quality using TVARAM, indicating poor provision of wetland functions. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-46

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Wetland 5 is an emergent wetland located in the central portion of the BFN site. The primary source of hydrology for this wetland appears to be concentrated stormwater runoff upstream of the wetland and sheet flow runoff from adjacent uplands. The wetland is located within a drainage ditch lacking an ordinary high-water mark. Surface water, water table, and saturation were observed during field investigation. Hydrophytic vegetation observed within the wetland included java waterdropwort (Oenanthe javanica), fox sedge, and Virginia buttonweed. Soil samples taken within the wetland exhibited hydric indicators, including F7, F8, and F12. This wetland scored as low quality using TVARAM, indicating poor provision of wetland functions. Wetland 6 is a scrub-shrub wetland located in the central portion of the BFN site. The primary source of hydrology for this wetland appears to be concentrated stormwater runoff upstream of the wetland and sheet flow runoff from adjacent uplands. The wetland is located within a drainage ditch lacking an ordinary high-water mark. Vegetation observed within the wetland included fox sedge, white morning-glory (Ipomoea lacunose), tufted lovegrass (Eragrostis pectinacea), and woody goldenrod (Chrysoma pauciflosculosa). Soil samples taken within the wetland exhibited hydric indicators, including F7 and F8. This wetland scored as moderate quality using TVARAM, indicating a healthy provision of wetland functions. Wetland 7 is an emergent wetland located in the northern portion of the BFN site. Wetland 7 and Wetland 6 are divided by Shaw Road. Two culverts are installed under the roadway, connecting the two wetlands. The primary source of hydrology for this wetland appears to be concentrated stormwater runoff upstream of the wetland and sheet flow runoff from adjacent uplands. The wetland is located within a drainage ditch lacking an ordinary high-water mark. Vegetation observed within the wetland included fox sedge, white morning-glory, tufted lovegrass, and woody goldenrod. Soil samples taken within the wetland exhibited hydric indicators, including F7, F8, and F12. This wetland scored as low quality using TVARAM, indicating poor provision of wetland functions. Wetland 8 is an emergent wetland located in the northeastern portion of the BFN site. A man-made berm separates Wetland 8 from Wetland 9. Saturated conditions were observed during field investigation. Hydrophytic vegetation observed within the wetland included marsh bristlegrass (Setaria parviflora), Virginia buttonweed, fox sedge, and swamp smartweed. Soil samples taken within the wetland exhibited hydric indicators including F6 (redox dark surface), F8 and F12. This wetland scored as low quality using TVARAM, indicating a poor provision of wetland functions. Wetland 9 is a forested wetland located in the northeastern portion of the BFN site. Much of the wetland is linear in shape, following excavated channels lacking an ordinary high-water mark. Saturated conditions were observed during field investigation. Vegetation observed within the wetland included swamp smartweed, woody goldenrod, and willow oak (Quercus phellos). Soil samples taken within the wetland exhibited hydric indicators, including F6, F8, and F12. This wetland scored as moderate quality using TVARAM, indicating a healthy provision of wetland functions. 3.6.1.3. Invasive/Non-Native Terrestrial Species The BFN site was and continues to be a highly altered and managed environment. With the construction and development of the facility, the introduction of non-native and potentially invasive species has occurred. Native plant communities have been converted to and are maintained as herbaceous, field habitats on much of the site. Among the non-native plant species likely to be present in these disturbed habitats are Chinese lespedeza, Japanese honeysuckle, and multiflora rose. Although there are currently no reports of invasive plants on Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-47

Appendix E - Applicants Environmental Report-Operating License Renewal Stage the BFN site becoming problematic, invasive species are continually monitored and managed as needed. 3.6.1.4. Special-Status Terrestrial Species This section addresses species that have a special status that provides them legal protection based on the following federal or state legislation. Endangered Species Act (ESA) (16 United States Code [U.S.C.] Parts 1531-1544, as amended): Section 7 of the federal ESA requires federal agencies to consider the effects of their actions on federally listed species and designated critical habitat, and to take steps to conserve and protect these species and habitats. The requirements of ESA Section 7 are administered by the U.S. Fish and Wildlife Service (USFWS), which principally has jurisdiction over terrestrial and freshwater aquatic species (as well as sea turtles when nesting onshore), and by National Oceanic and Atmospheric Administration (NOAA) Fisheries, which principally has jurisdiction over marine species (including sea turtles when in water). Alabama Administrative Code, Alabama Department of Conservation and Natural Resources, Chapter 220-2-.92, Protected Nongame Species. This regulation makes it unlawful to take, capture, or kill any of the nongame wildlife species identified in the regulation, which include fish, amphibians, reptiles, birds, and mammals. Bald and Golden Eagle Protection Act (BGEPA) (16 U.S.C. Parts 668-668c): Although delisted under the federal ESA in 2007, the bald eagle (Haliaeetus leucocephalus) remains protected under the federal BGEPA. The BGEPA prohibits anyone, without a permit issued by the Secretary of the Interior, from taking bald eagles, which includes molesting or disturbing the birds or their nests or eggs. Migratory Bird Treaty Act (MBTA): The federal MBTA makes illegal the killing, injury, or other taking of birds and their nests or eggs. It applies to essentially all native bird species that occur in the region, with the exception of certain non-migratory game birds that are managed by the states (e.g., quail, turkey, and grouse). Birds of conservation concern (BCC) are a subset of migratory birds identified by USFWS. Federal-Status Species Review of the TVA Natural Heritage Project Database (TVA 2022b) indicated that one federal listed terrestrial animal species (gray bat) and one federal protected species (bald eagle) have reported occurrences within 3 miles of the BFN site in Limestone County, Alabama. In addition, the USFWS has determined that the federal status Indiana bat, northern long-eared bat, tricolored bat, and monarch butterfly have the potential to occur in the vicinity of the BFN site (Table 3.6-2). No federal listed plant species have recorded occurrences within 5 miles of the BFN site, and critical habitat has not been designated for any federal listed species in the project vicinity (USFWS 2022a). Gray bats roost in caves year-round and migrate between summer and winter roosts during spring and fall (Brady et al. 1982, Tuttle 1976a). Bats disperse over bodies of water at dusk where they forage for insects emerging from the surface of the water (Tuttle 1976b). Two hibernacula for the gray bat are known in Limestone County, the closest of which is approximately 8.7 miles away. No caves are known within 3 miles of BFN. No mines or other gray bat roosting habitat on BFN property are known. Foraging habitat and sources of drinking water exist over streams, channels and wetlands on BFN property and over Wheeler Reservoir. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-48

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Indiana bats hibernate in caves in winter and use areas around them for swarming (mating) in the fall and staging in the spring, prior to migration back to summer habitat. During the summer, Indiana bats roost under the exfoliating bark of dead snags and living trees in mature forests with an open understory and a nearby source of water (Pruitt and TeWinkel 2007). Indiana bats are known to change roost trees frequently throughout the season, while still maintaining site fidelity, returning to the same summer roosting areas in subsequent years (Pruitt and TeWinkel 2007). No caves are known within 3 miles of BFN, and no records of Indiana bats are known from Limestone County. The closest known record of this species is a historical record from 9.4 miles away in Lauderdale County. The northern long-eared bat predominantly overwinters in large hibernacula such as caves, abandoned mines, and cave-like structures. During the fall and spring, they utilize entrances of caves and the surrounding forested areas for swarming and staging. In the summer, northern long-eared bats roost individually or in colonies beneath exfoliating bark or in crevices of both live and dead trees (typically greater than 3 inches in diameter). Roost selection by northern long-eared bat is similar to that of the Indiana bat; however, northern long-eared bats are thought to be more opportunistic in roost site selection. This species also roosts in abandoned buildings and under bridges. Northern long-eared bats emerge at dusk to forage below the canopy of mature forests on hillsides and near roads, and occasionally over forest clearings and along riparian areas (USFWS 2014). No caves are known within 3 miles of BFN. The closest known record of the northern long-eared bat is from 25.6 miles away in Bankhead National Forest. The tricolored bat was proposed for listing as endangered under the ESA in September 2022 (87 FR 56373; September 14, 2022). Designating critical habitat for this species is not prudent according to USFWS. These bats hibernate in caves, mines, and rock crevices during winter. Tricolored bats in Alabama are often found roosting in road culverts and will forage on warm, winter nights. During spring, summer, and fall, the tricolored bat utilizes forested habitats, where it roosts in live or recently dead deciduous trees, primarily among leaves, and occasionally in human structures. It forages around forest edges and over waterways. This species is known or believed to occur in Limestone County, Alabama (Outdoor Alabama 2022). No suitable winter roosting structures for the Indiana bat, northern long-eared bat, or tricolored bat exist on the BFN property. Moderately suitable summer roosting habitat occurs in some scattered forest fragments across the BFN property. The least disturbed forest remains along the shoreline in the southeastern corner of the property. Based on aerial photos, it appears most other forested areas are regrowth after being cleared sometime before 1998. Remaining suitable habitat fragments consist of mature forests and/or areas with trees that have suitable cracks and crevices. Suitable foraging habitat includes the forest and forest edges and wetlands and water bodies, including the adjacent Wheeler Reservoir. Surveys performed using the 2020-2021 USFWS Indiana Bat Survey Guidelines identified 111.4 acres of forest fragments scattered across the BFN property that may offer potential habitat for summer roosting by the Indiana bat, northern long-eared bat, or tricolored bat. Review of the TVA Regional Natural Heritage Program database in February 2022 indicated that no caves exist within 3 miles of BFN. Thus, there are no suitable hibernacula for bats near BFN. The TVA bat strategy was implemented for the SLR and was completed on October 26, 2022 (Attachment 2). The review determined that the project is not likely to adversely affect bats with implementation of conservation measures and complies with the TVA Bat Strategy. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-49

Appendix E - Applicants Environmental Report-Operating License Renewal Stage The monarch butterfly is a candidate for listing under the ESA. It is a highly migratory species, with eastern United States populations overwintering in Mexico. Monarch populations typically return to the eastern United States in April (Davis and Howard 2005). Summer breeding habitat requires milkweed plant species, on which adults exclusively lay eggs for larvae to develop and feed on. Adults will drink nectar from other blooming wildflowers when milkweeds are not in bloom (NatureServe Explorer 2022). The early successional fields within the BFN property include several species of wildflowers and other flowering plants that provide suitable foraging habitat for adult monarchs. The overwhelming majority of areas with herbaceous vegetation on the BFN property are mowed grass fields. It is possible that small patches of flowering herbaceous plants may persist on the edges of fields where mowing has been infrequent, though none were documented. The Alabama Natural Heritage Program database does not include any known occurrences of federal-status terrestrial plant species within 5 miles of BFN (TVA 2022b). State-Status Species State-protected animal species with recorded occurrences within 3 miles of the BFN site are shown in Table 3.6-2. The three bat species also have federal listing status and are discussed above. The two bird species are the bald eagle and osprey. The bald eagle is not a federal listed species but has federal protection under the BGEPA and is state protected. It is discussed below. The osprey has a status of state protected. In inland areas, the osprey occupies riparian habitats along bodies of water such as rivers, lakes, and reservoirs. It builds nests of sticks on trees or a variety of man-made structures (e.g., power transmission line structures, lighting towers) near water (NatureServe Explorer 2022). Two osprey nests were documented on the BFN reservation during field reviews in September 2021. Due to maintenance issues with the cell tower one of the nests was on, it was removed a few weeks after the field surveys. The nest was not active at the time of removal. The remaining nest is on a TVA transmission tower. The Alabama Natural Heritage Program does not assign a state protected status to plants; however, the program does assign ranks to species based on rarity. The ranking does not confer legal protection. The TVA Regional National Heritage Database includes records from Limestone County for eight plant species with a state rank of S1 or S2 as shown in Table 3.6-3 (TVA 2022b). According to the database, no plants with a state rank of S1 (critically imperiled in the state) or S2 (imperiled in the state) have been recorded within a 5-mile radius of BFN (TVA 2022b). Bald Eagle The bald eagle is protected under the BGEPA. It formerly was federally listed but has been de-listed by USFWS as it is now considered recovered. This species is associated with larger, mature trees capable of supporting its massive nests. Nests are usually found near larger waterways where the eagles forage (USFWS 2007). Three bald eagle nests are known from Limestone County, the closest of which is 5.4 miles away. Wheeler Reservoir provides foraging habitat for the bald eagle. Suitable nesting trees occur throughout the forest fragment along Wheeler Reservoir in the southeastern corner of BFN; however, no bald eagle nests have been documented on the BFN site. Migratory Birds Most bird species in the BFN area are protected by the MBTA. (Federal and state listed birds, and the bald eagle, are also protected under the MBTA and are discussed above.) The MBTA is Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-50

Appendix E - Applicants Environmental Report-Operating License Renewal Stage the primary legislation in the United States established to conserve migratory birds. The MBTA prohibits the intentional taking, killing, or possessing of migratory birds unless permitted by regulation. Executive Order (EO) 13186 (66 FR 3853-3856), Responsibilities of Federal Agencies to Protect Birds, provides a specific framework for federal agencies to comply with their MBTA obligations and aids in incorporating bird conservation planning into agency programs. For the purposes of the MBTA and EO 13186, migratory birds have been defined to include all native birds in the United States, except certain non-migratory game species managed by the states (e.g., quail, turkey, grouse, and ptarmigan). The BFN area includes habitats that are used by a variety of birds protected under the MBTA. Migratory BCC are species that are of particular concern to USFWS. The Information for Planning and Consultation (IPaC) report for the BFN site (USFWS 2022a) contains a list of BCC that potentially could occur in the vicinity. It includes BCC that could occur in the area during breeding season, wintering season, or year-round. The list includes nine BCC that could occur in the area during the breeding season (bobolink, brown-headed nuthatch, chimney swift, field sparrow, Kentucky warbler, prairie warbler, prothonotary warbler, red-headed woodpecker, and wood thrush) and two species that breed elsewhere (lesser yellowlegs and rusty blackbird). 3.6.2. Aquatic Communities This section describes the ecological resources of the aquatic communities that may be affected by the operation of BFN during SLR. The aquatic community that will be affected by water withdrawals and discharges associated with the continued operation of BFN is that of Wheeler Reservoir. 3.6.2.1. Physical Characteristics and Water Quality of Wheeler Reservoir The physical characteristics and water quality of Wheeler Reservoir are discussed in Sections 3.5.1.1 and 3.5.1.3, respectively. TVA evaluates the status of the aquatic community in the Wheeler Reservoir downstream of The plants thermal discharge with a focus on the fish community to demonstrate that a balanced indigenous population of fish and wildlife is present and being maintained in the Tennessee River downstream from the plant. Since BFN began full operation in 1977, studies have demonstrated that Wheeler Reservoir contains diverse communities of phytoplankton, zooplankton, and benthic macroinvertebrates (TVA 2021c). TVAs biological monitoring program to evaluate reservoir ecological and water quality health in 2020 demonstrated that all expected major trophic levels for fish in the portion of Wheeler Reservoir unaffected by thermal effluent were also present in the portion of the reservoir affected by thermal discharge (TVA 2021c). Ecological conditions of benthic macroinvertebrate communities, when compared among the downstream and upstream reaches, have been similar since initiation of sampling in 2001. The ADPH fish consumption advisory released in June 2022 lists Bakers Creek embayment at Wheeler Reservoir near Decatur, Alabama, approximately 10 miles upstream from BFN (ADPH 2022). The advisory includes all fish species based on PFOS in fish tissue. 3.6.2.2. Community Characteristics Fish TVA monitors the health of the aquatic community using a multi-metric Reservoir Fish Assemblage Index (RFAI). Characteristics of a balanced indigenous population are determined holistically by measuring 12 population metrics, scoring the metrics based on expectations of healthy populations in the region, and summing the scores to arrive at an overall RFAI score and health rating (TVA 2021c). Scores for autumn 2020 were similar between downstream (46-Good) and upstream (49-Good) sites, and both were the highest observed at the respective Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-51

Appendix E - Applicants Environmental Report-Operating License Renewal Stage reaches. With the exception of 2005 and 2019, RFAI scores at both reaches have not been statistically different (i.e. similar, or differed by six points or less). When compared between reaches, scores since 2000 have not been significantly different (P=0.13) (TVA 2021c). Table 3.6-4 lists fish species collected by TVA in the vicinity of BFN from autumn 1993-1997, 1999-2011, 2013, 2015, 2017, 2019, and 2020 (TVA 2021b). Sampling sites were nominally located at TRMS 292.5 and 295.9. Electrofishing and gill netting locations ranged from 0.5 to 1.0 mile upstream and downstream from these river mile locations (TVA 2021b). Excluding four hybrid fish species, 69 species were collected. Mississippi silverside, gizzard shad, emerald shiner, and threadfin shad were most abundant, exhibiting the highest catch per unit effort (CPUE). Gizzard shad, bluegill, largemouth bass, channel catfish, skipjack herring, redear sunfish, and freshwater drum were the species most widespread in occurrence, having been collected in all samples, while 15 species were collected in only one sample. Studies conducted in support of CWA Section 316(a) indicate that the fish community of Wheeler Reservoir in the vicinity of BFN does not show an increase or dominance of heat tolerant or invasive, non-native fish species as a result of the thermal component of the BFN discharge. Fish species were categorized as heat tolerant (upper incipient lethal temperatures [UILTs] of 95°F to 102°F) and heat sensitive (UILTs <91°F) using thermal sensitivity data from Yoder et al. (Yoder et al. 2006). Upstream samples included more heat tolerant species than downstream samples during 10 of 18 sampling events since 2000. Additionally, average numbers of heat tolerant species and the abundances of heat-tolerant individuals, and the relative abundances of heat tolerant species and heat sensitive species, were not statistically different between the reaches upstream and downstream of the thermal discharge (TVA 2021c). Regarding invasive fish species, data indicate there are few present in the reservoir around BFN. A statistical test performed on the autumn 2020 dataset indicated that numbers of invasive species and abundances were not different between the reaches sampled upstream and downstream of the thermal discharge. On average since 2000, one more invasive fish species was collected at the thermally unaffected upstream reach, and abundance of invasive species has not been statistically different between reaches (TVA 2021c). Mussels and Other Macroinvertebrates TVA conducted a mussel survey at BFN on July 12-13, 2021, to assess the current freshwater mussel assemblage in Wheeler Reservoir immediately adjacent to BFN (Amaker 2021). Mussels were found only in the overbank habitat. Current mussel fauna is characterized by 11 common, widespread, silt-tolerant species. The most numerous species was the Washboard (Megalonaias nervosa), which was common at most sites sampled and dominated the mussel biomass. All age classes from juveniles to large adults were present. Four snail species also were observed during the survey. All species present during the survey are shown in Table 3.6-5. The survey was conducted at six downstream and five upstream stations in the immediate vicinity of BFN. CPUE ranged from 0.13 to 1.93 mussels per minute at downstream survey locations to 0.86 to 3.4 mussels per minute at upstream stations. Water depths at downstream and upstream stations ranged from 8 to 25 feet and 13 to 18 feet, respectively. Substrate at various downstream stations consisted of silt, gravel, and artificial rock piles. Asian clam (Corbicula fluminea) and relict shells were present at two locations and sparse to dense eelgrass (Vallisneria americana) was present at two locations. Substrate at various upstream stations consisted of silt, gravel, or rock. Relict Corbicula shell was present at two locations. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-52

Appendix E - Applicants Environmental Report-Operating License Renewal Stage The results of macroinvertebrate assessments in Wheeler Reservoir have shown that the downstream reaches have scored in the Excellent range during eight of ten sample years, including the last four sampling years (TVA 2021c). The macroinvertebrate community structure demonstrates a seasonally abundant and diverse macroinvertebrate community present at both downstream and upstream reaches (Table 3.6-6). In summary, ecological conditions of benthic macroinvertebrate communities, when compared among the downstream and upstream reaches, have been similar since the initiation of sampling. Aquatic Macrophytes TVA collects shoreline and river bottom habitat data upstream and downstream of BFN every 5 years to characterize habitats important to fish to find comparable habitats at upstream and downstream sampling sites to minimize habitat differences that might bias interpretation of the results. Aquatic macrophytes are present in low abundance near BFN. Aquatic macrophytes were present in low percentages within both reaches during 2020 habitat surveys conducted by TVA (TVA 2021c). No aquatic macrophytes were observed at either the upstream or downstream reaches. 3.6.2.3. Invasive/Non-Native Aquatic Species Invasive, non-native, aquatic species observed in the immediate vicinity of BFN are listed in Table 3.6-7 and discussed below. Striped bass are marine species that are anadromous. Adults spend their lives in the ocean and return to freshwater tributaries to spawn. Young striped bass remain in streams and tributaries as they grow, usually returning to salt water before the first winter after they are hatched (USFWS 2023). Yellow Perch native range includes the Atlantic, Arctic, Great Lakes, and Mississippi River basins from Nova Scotia and Quebec west to Great Slave Lake, Northwest Territories, and south to Ohio, Illinois, and Nebraska; south in Atlantic drainages to Santee River, South Carolina. Non-indigenous occurrence in Tennessee includes Hiwassee, Kentucky Lake, Lower Clinch, Lower Little Tennessee, Pickwick Lake, and Watts Bar Lake (Fuller and Neilson 2023). Hybrid striped bass is a cross between striped bass and white bass. The cross was first produced in South Carolina. Hybrid striped bass have been widely introduced and are a popular sport fish in the Southeast, particularly in large reservoirs (Texas A&M 2023). The grass carp is native to eastern Asia and was imported for aquaculture and for phytoplankton control. This species has significantly altered the food web and trophic structure of aquatic systems by inducing changes in plant, invertebrate, and fish communities (USDA 2023). The Atlantic needlefish is a marine invader. This species is present on the Gulf and Atlantic coasts and enters the surface waters of rivers, sloughs, canals and some lakes (Florida Museum 2023).The redbreast sunfish can be found in creeks, rivers and streams with a balanced pH and vegetation (Texas Invasive Species Institute 2014). Adults feed on terrestrial insects, immature and adult aquatic insects, and crayfish. When introduced in non-native habitats, this fish can take over the habitat of native fish species. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-53

Appendix E - Applicants Environmental Report-Operating License Renewal Stage The Mississippi silverside has been introduced to reservoirs on the Tennessee and Cumberland Rivers in Alabama, Tennessee, and Kentucky (Smithsonian Environmental Research Center 2022b). This species apparently evolved from the estuarine fish, M. beryllina, and can tolerate a wide range of temperature and salinity. Mississippi silversides swim in large schools, and feed on zooplankton, insects, small benthic invertebrates, and small fishes. The common carp is native to eastern Asia, but has been widely introduced, domesticated, and hybridized in the United States and elsewhere (Smithsonian Environmental Research Center 2022a). This species feeds on aquatic vegetation and thrives in conditions not suitable for other fish, which made the common carp an attractive import. Common carp can impact native fish species. Branchiura sowerbyi is a tubificid worm established sporadically and widely around the United States (Liebig et al. 2019). It is a benthic deposit bottom feeder that occurs in rivers and warmer waters. Apocorophium lacustre is an amphipod crustacean that is a recent colonizer of freshwater systems in the United States and Europe (Keller et al. 2017). This species is native primarily in estuarine environments. It is believed to have the potential to alter food webs and may compete with native filter feeders for space and food. Corbicula fluminea is a filter feeding, non-native, invasive clam species that causes biofouling of power-plant and industrial water systems (USGS 2022). This species is consumed by fish and crayfish. 3.6.2.4. Special-Status Aquatic Species The hydrologic units that make up the Wheeler Reservoir watershed contain numerous records of federal and state listed species (Table 3.6-8). Numerous records of listed mussel species also occur within a 10-mile radius of BFN (Table 3.6-8). However, these mussel species are not expected to occur near BFN for the following reasons: they are presumed to be extinct, they are presumed to be extirpated from the region, there are no recent records for the species in the region, there are no collection records for the species from pertinent locations, and/or the area near the BFN site does not contain suitable habitat for the species. Species that are federal or state listed and persist in Wheeler Reservoir occupy more suitable habitat that is located much farther upstream of BFN in the more riverine portion of the Tennessee River downstream from Guntersville Dam. The other group of aquatic animals with federal or state status and recorded occurrences in Wheeler Reservoir and/or within 10 miles of BFN are fish (spring pygmy sunfish, slackwater darter, Tuscumbia darter, and paddlefish). In 21 years (since 1993) of fish entrainment sampling by TVA in the vicinity of BFN, the paddlefish was collected in only 1 year (TVA 2020b). The spring pygmy sunfish, slackwater darter, and Tuscumbia darter were never collected and would not be expected to be present because they do not occur in lacustrine habitat such as that available in this portion of Wheeler Reservoir. The snail darter was listed as endangered under the ESA in 1975, and its status was later changed to threatened. It was removed from the federal list of endangered and threatened species effective November 4, 2022 (87 FR 60298-60313; October 5, 2022). Although the snail darter has been federally delisted under the ESA, it currently remains a state listed species in Alabama. TVA has monitored for the presence of this species and has found populations in tributaries to the Tennessee River and in Tennessee River reservoirs. TVA sampling in all Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-54

Appendix E - Applicants Environmental Report-Operating License Renewal Stage mainstem Tennessee River reservoirs from 2017 - 2020 found this species in five reservoirs, including Wheeler Reservoir. It is possible that larvae and adults could be present in Wheeler Reservoir near BFN (Simmons 2019). However, snail darters prefer clean gravel substrates, and this habitat is most common on the opposite side of Wheeler Reservoir from BFN (TVA 2021c, USFWS 2022b). Essential Fish Habitat Essential fish habitat (EFH) includes waters and substrate that are necessary for spawning, breeding, feeding, or growth to maturity of fish and shellfish that are federally managed species. EFH is identified and described by the National Marine Fisheries Service (NMFS) and regional fishery management councils, in accordance with the Magnuson-Stevens Act (16 USC 1801 et seq.). According to the NMFS EFH Mapper, EFH has not been designated within Wheeler Reservoir (NOAA Fisheries 2022). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-55

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 3.6-1. Wetlands on the BFN Site Total Wetland TRAM Wetland Type 1 Location on BFN Site Wetland Identifier Category2 Acreage on BFN Site Wetland 1 PEM1C Low (24.5) Southeast 1.45 Wetland 2 PEM1C Low (24.5) Southeast 0.46 Wetland 3 PEM1C Low (24.5) Southeast 0.40 Wetland 4 PEM1B Low (29.5) Central east 10.61 Wetland 5 PEM1C Low (26.5) Central south 0.58 Wetland 6 PSS1C Moderate (39) Central 1.33 Wetland 7 PEM1E Low (28) North 3.63 Wetland 8 PEM1E Low (23) Northeast 0.82 Wetland 9 PFO6E Moderate (45) Northeast 4.82 Total 24.1 1 Classification codes as defined in (Cowardin 1979): P = Palustrine; EM1 = emergent, persistent vegetation; FO6= forested, deciduous vegetation,seasonally flooded/saturated; SS1= scrub-shrub, broad-leaved deciduous vegetation; C = Seasonally flooded; B = Saturated; E = seasonally flooded/saturated 2 TRAM (Tennessee Rapid Assessment Methodology) category definitions: Low = low resource value; Moderate = moderate resource value; Exceptional = exceptional waters. Table 3.6-2. Federal and State Status Terrestrial Animal Species with the Potential to Occur or Documented within 3 miles of the BFN Site Federal State Status3 Common Name Scientific Name Status3 (State Rank)4 Mammals Gray bat2,5 Myotis grisescens E SP(S2) Indiana bat2 Myotis sodalis E SP(S2) Northern long-eared bat2 Myotis septentrionalis T SP(S2) Tricolored bat Perimyotis subflavus PE -- Invertebrates Monarch butterfly2,6 Danaus plexippus C -- Birds Bald eagle5 Haliaeetus leucocephalus DM SP(S4B) Osprey1 Pandion haliaetus -- SP(S4) 1 Source: TVA Regional Natural Heritage Database, extracted Feb. 2022 (TVA 2022b) mile buffer query 2 USFWS IPaC query (USFWS 2022a) 3 Status Codes: E = Endangered; T = Threatened; PE = Proposed Endangered; C = Candidate species for federal listing; DM = Delisted, recovered, and still being monitored; SP = State Protected. 4 Alabama Natural Heritage Program State Ranks: S2 = Imperiled; S4 = Apparently Secure; S#B = Rank of breeding population. 5 Species known from Limestone County, Alabama but not within 3 miles of the BFN site. 6 Historically this species has not been tracked by natural heritage databases. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-56

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 3.6-3. Plants with a State Rank of Imperiled and Occurring in Limestone County, Alabama1 Common Name Scientific Name State Rank2 Lake-cress Armoracia lacustris S1 Waterweed Elodea canadensis S1 Duck River bladderpod Paysonia densipila S1 Alabama snow-wreath Neviusia alabamensis S2 Ragged fringe orchid Platanthera lacera S2 Mohrs rosin-weed Silphium mohrii S1 Sessile trillium Trillium sessile S2 Northern prickly-ash Zanthoxylum americanum S1 1 Source: TVA Regional Natural Heritage Database, extracted Feb. 2022 (TVA 2022b) - recorded occurrences within Limestone County 2 Alabama Natural Heritage Program ranking system: S1 = Critically imperiled in Alabama because of extreme rarity (5 or fewer occurrences of very few remaining individuals or acres) or because of some factor(s) making it especially vulnerable to extirpation from Alabama. S2 = Imperiled in Alabama because of rarity (6 to 20 occurrences or few remaining individuals or acres) or because of some factor(s) making it very vulnerable to extirpation from Alabama. Table 3.6-4. Catch Rates (CPUE; in the Vicinity of Browns Ferry Nuclear Plant (Tennessee River Miles 292.5 and 295.9) from 1993 through 2020 Species Average CPUE Common Name Scientific Name Occurrence CPUE1 Range (No. of Samples)2 Mississippi silverside Menidia audens 17.2 0.1 - 80.7 40 Gizzard shad Dorosoma cepedianum 15.7 0.3 - 45.7 45 Emerald shiner Notropis atherinoides 11.8 0.1 - 220.3 27 Threadfin shad Dorosoma petenense 9.8 0.1 - 133.3 39 Bluegill Lepomis macrochirus 5.4 0.2 - 19.1 45 Largemouth bass Micropterus salmoides 3.6 0.4 - 13.0 45 Eastern sand darter Ammocrypta pellucida 3.1 3.1 - 3.1 1 Channel catfish Ictalurus punctatus 3.1 0.2 - 7.9 45 Longear sunfish Lepomis megalotis 2.1 0.1 - 5.6 43 Skipjack herring Alosa chrysochloris 2.0 0.1 - 8.0 45 Spotfin shiner Cyprinella spiloptera 1.5 0.1 - 2.7 30 Redear sunfish Lepomis microlophus 1.5 0.1 - 4.6 45 Freshwater drum Aplodinotus grunniens 1.5 0.3 - 3.3 45 Logperch Percina caprodes 1.4 0.1 - 13.7 35 White bass Morone chrysops 1.3 0.1 - 8.6 41 Smallmouth bass Micropterus dolomieu 1.2 0.1 - 5.0 44 Yellow bass Morone mississippiensis 1.1 0.1 - 5.0 44 Spotted sucker Minytrema melanops 1.1 0.1 - 8.9 43 Green sunfish Lepomis cyanellus 1.0 0.1 - 6.6 39 Brook silverside Labidesthes sicculus 0.9 0.1 - 3.8 5 Smallmouth buffalo Ictiobus bubalus 0.9 0.1 - 2.4 42 Blue catfish Ictalurus furcatus 0.8 0.1 - 4.5 44 Sauger Sander canadensis 0.8 0.1 - 4.1 37 Spotted bass Micropterus punctulatus 0.7 0.1 - 2.7 42 Yellow bullhead Ameiurus natalis 0.7 0.7- 0.7 1 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-57

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Species Average CPUE Common Name Scientific Name Occurrence CPUE1 Range (No. of Samples)2 Flathead catfish Pylodictis olivaris 0.5 0.1 - 1.6 44 Longnose gar Lepisosteus osseus 0.5 0.1 - 1.8 9 Spotted gar Lepisosteus oculatus 0.5 0.1 - 1.8 33 Golden shiner Notemigonus crysoleuca 0.4 0.1 - 1.8 29 Saddleback darter Percina vigil 0.4 0.4 - 0.4 1 Hybrid striped x white Morone saxatilis x M. 0.4 0.1 - 1.4 11 bass chrysops Striped bass Morone saxatilis 0.3 0.1 - 1.3 21 Black buffalo Ictiobus niger 0.3 0.1 - 1.6 17 Common carp Cyprinus carpio 0.3 0.1 - 1.3 35 Walleye Sander vitreus 0.3 0.1 - 0.5 4 Golden redhorse Moxostoma erythrurum 0.2 0.1 - 1.3 20 Silver redhorse Moxostoma anisurum 0.2 0.1 - 0.9 9 Lake sturgeon Acipenser fulvescens 0.2 0.2 - 0.2 1 Orangespotted sunfish Lepomis humilis 0.2 0.1 - 0.3 4 Striped shiner Luxilus chrysocephalus 0.2 0.1 - 0.3 4 Yellow perch Perca flavescens 0.2 0.1 - 0.7 15 Black redhorse Moxostoma duquesnei 0.2 0.1 - 0.7 26 White crappie Pomoxis annularis 0.2 0.1 - 0.8 24 Quillback Carpiodes cyprinus 0.2 0.1 - 0.3 6 Bullhead minnow Pimephales vigilax 0.1 0.1 - 0.5 20 Bluntnose minnow Pimephales notatus 0.1 0.1 - 0.3 6 Black crappie Pomoxis nigromaculatus 0.1 0.1 - 0.4 24 Warmouth Lepomis gulosus 0.1 0.1 - 0.5 33 Blackside snubnose Etheostoma duryi 0.1 0.1 - 0.1 1 darter Mooneye Hiodon tergisus 0.1 0.1 - 0.2 3 Hybrid sunfish Lepomis sp 0.1 0.1 - 0.2 6 Blackstripe topminnow Fundulus notatus 0.1 0.1 - 0.1 2 River darter Percina shumardi 0.1 0.1 - 0.1 2 River redhorse Moxostoma carinatum 0.1 0.1 - 0.2 4 Shortnose gar Lepisosteus platostomus 0.1 0.1 - 0.1 1 Smallmouth redhorse Moxostoma breviceps 0.1 0.1 - 0.1 1 Stripetail darter Etheostoma kennicotti 0.1 0.1 - 0.1 4 Northern hog sucker Hypentelium nigricans 0.1 0.1 - 0.3 14 Largescale stoneroller Campostoma oligolepis 0.1 0.1 - 0.2 10 Redbreast sunfish Lepomis auritus 0.1 0.1 - 0.3 15 Bowfin Amia calva 0.1 0.1 - 0.1 4 Bigmouth buffalo Ictiobus cyprinellus 0.1 0.1 - 0.1 7 Chestnut lamprey Ichthyomyzon castaneus 0.1 0.1 - 0.1 7 Atlantic needlefish Strongylura marina 0.1 0.1 - 0.1 1 Blackspotted topminnow Fundulus olivaceus 0.1 0.1 - 0.1 1 Central stoneroller Campostoma anomalum 0.1 0.1 - 0.1 1 Grass carp Ctenopharyngodon idella 0.1 0.1 - 0.1 1 Hybrid bass Micropterus sp. 0.1 0.1 - 0.1 2 Hybrid walleye x sauger Sander vitreus x S. 0.1 0.1 - 0.1 1 canadensis Mimic shiner Notropis volucellus 0.1 0.1 - 0.1 1 Rock bass Ambloplites rupestris 0.1 0.1 - 0.1 1 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-58

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Species Average CPUE Common Name Scientific Name Occurrence CPUE1 Range (No. of Samples)2 Silver chub Macrhybopsis storeriana 0.1 0.1 - 0.1 4 Snubnose darter Etheostoma simoterum 0.1 0.1 - 0.1 1 Source: (TVA 2021b). 1 CPUE = catch per unit effort 2 Number of samples in which species occurred collected by electrofishing and gill netting during 45 sampling events from 1993 through 2020. Table 3.6-5. Mussel and Snail Species Present During the Survey July 12-13, 2021 Common Name Scientific Name Mussels Elephant ear Elliptio crassidens Fawnsfoot Truncilla donaciformes Fragile papershell Potamilis fragilis Mapleleaf Quadrula quadrula Pimpleback Cyclonaias pustulosa Pink heelsplitter Potamilis alatus Rock pocketbook Arcidens confragosus Southern mapleleaf Quadrula apiculata Threehorn wartyback Obliquaria reflexa Threeridge Amblema plicata Washboard Megalonaias nervosa Snails Noble hornsnail Pleurocera nobilis Olive mysterysnail Viviparus subpurpureus Pointed campeloma Campeloma decisum Silty hornsnail Pleurocera canaliculata Table 3.6-6. Results of Benthic Macroinvertebrate Functional Feeding Groups Upstream and Downstream of BFN for Sampling Years1 between 2001 and 2020 Sampling Metric Downstream Average3 Upstream Average4 Number of species 24 23 Total mean density (per m2) 961 703 Percent composition by feeding group2 CF 16 20 CG 43 37 PA 0 0 PR 33 31 SC 7 10 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-59

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Sampling Metric Downstream Average3 Upstream Average4 SH 1 2 PI 0 0 1 Years sampled: 2001-2004, 2006, 2011, 2012, 2013, 2015, 2017, and 2020. 2 CF = collector/filterer; CG = collector/gatherer; PA = parasitic; PR = predator; SC = scraper; SH = shredder; PI = piercer. 3 River Miles 291.7, 290.4, 293.2 4 River Mile 295.9 Source: (TVA 2021c) Table 3.6-7. Invasive, Non-native, Aquatic Species Observed in the Immediate Vicinity of BFN Common Name Scientific Name Downstream Upstream Fish1 Striped bass Monrone saxatilis --- --- Yellow perch Perca flavescens --- --- Hybrid striped bass x white bass M. saxatilis x M.chrysops --- --- Grass carp Ctenoopharyngodon idella --- --- Atlantic needlefish Strohgylura marina --- --- Redbreast sunfish Lepomis auritus X Mississippi silverside Menidia audens X X Common carp Cyprinus carpio X Benthic Macroinvertebrates2 Tubificid worm Branchiura sowerbyi X --- Amphipod Apocorophium lacustre X X Asian clam Corbicula fluminea X X 1 Non-indigenous species 2 Invasive species Source: (TVA 2021c). Seasonal surveys were conducted during spring 2007, and autumn 2000-2011, 2013, 1015, 2017, 2019, and 2020 at TRM 292.5 (downstream) and 295.9 (upstream). Table 3.6-8. Federal and State Status Aquatic Animal Species with Documented Occurrences or the Potential to Occur within Wheeler Reservoir Federal State State Common Name Scientific Name Status4 Status5 Rank6 Fish Spring pygmy sunfish1, 2 Elassoma alabamae T SP S1 1 Slackwater darter Etheostoma boschungi T SP 1, 2 Tuscumbia darter Etheostoma tuscumbia -- SP S2 Snail darter Percina tanasi --7 SP S1 2 Paddlefish Polyodon spathula -- SP S3 Mussels Mucket1 Actinonaias ligamentina -- PSM S2 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-60

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Federal State State Common Name Scientific Name Status4 Status5 Rank6 Spectaclecase1 Cumberlandia monodonta E SP S1 Dromedary pearlymussel1, 2 Dromus dromas E, XN SP SX Cumberlandian combshell2 Epioblasma brevidens E, XN SP S1 2 Acornshell Epioblasma haysiana -- PSM SX Tuberculed blossom pearlymussel1 Epioblasma torulosa torulosa E SP SX Cracking pearlymussel2 Hemistena lata E, XN SP S1 1, 2, 3 Pink mucket Lampsilis abrupta E SP S1 1 Pocketbook Lampsilis ovata -- PSM S2 1, 2 White heelsplitter Lasmigona complanata -- PSM S2 2 Birdwing pearlymussel Lemiox rimosus E, XN SP S1 Hickorynut1 Obovaria olivaria -- PSM SX Ring pink1 Obovaria retusa E, XN SP SH Orange-foot pimpleback1 Plethobasus cooperianus E, XN SP SX Sheepnose1 Plethobasus cyphyus E SP S1 1, 2 Ohio pigtoe Pleurobema cordatum -- PSM S2 1, 2, 3 Rough pigtoe Pleurobema plenum E, XN SP S1 1 Tennessee pigtoe Pleuronaia barnesiana -- PSM S1 1 Pink papershell Potamilus ohiensis -- PSM S3 Kidneyshell1 Ptychobranchus fasciolaris -- PSM S2 Fluted kidneyshell2 Ptychobranchus subtentum E SP SX Purple lilliput1 Toxolasma lividus -- PSM S2 1 Painted creekshell Villosa taeniata -- PSM S2 1 Source: TVA Natural Heritage Database (TVA 2022b) - hydrologic unit code query 2 Source: TVA Natural Heritage Database (TVA 2022b) mile buffer query 3 Source: USFWS IPaC query (USFWS 2022a) 4 Federal Status: E = Endangered; T = Threatened; XN = experimental population, nonessential (experimental reintroduced population) 5 State Status: SP = State Protected; PSM = Partial Status Mussels 6 State Rank: S1 = Critically imperiled; S2 = Imperiled; S3 = Vulnerable; S4 = Apparently secure; S5 = Secure; SH = Historical (possibly extirpated); SX = Presumed extirpated in Alabama 7 Source: 87 FR 192 60298-60313; October 5, 2022 - Removing the Snail Darter From the List of Endangered and Threatened Wildlife Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-61

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 3.6-1. Forest Zones Surveyed at the BFN Site Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-62

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 3.7. Historic and Cultural Resources As a corporate agency and instrumentality of the United States, TVA complies with Section 106 of the National Historic Preservation Act (NHPA) for TVA undertakings that have the potential to affect properties included or eligible for inclusion in the National Register of Historic Places (NRHP). As required by 36 CFR 800.1-13, TVA determines the undertakings area of potential effects (APE), identifies appropriate consulting parties, and follows the processes for identifying historic properties, evaluating project effects, and resolving any adverse effects to historic properties. TVA follows these steps in consultation with the appropriate consulting parties including state historic preservation officers (SHPOs) and tribal governments. In addition, the Categorical Exclusion Checklist (for projects that do not require an Environmental Assessment or Environmental Impact Statement) specifically includes consideration of actions which can potentially affect historic structures, historic sites, Native American religious or cultural properties, or archaeological sites. Furthermore, any project or activity that involves ground disturbance on TVA land requires prior review and concurrence by TVA Cultural Compliance staff. BFN is eligible for inclusion in the NRHP, therefore, he BFN SLR qualifies as an undertaking with potential to affect historic properties (§800.16(y)) given that the project may require maintenance actions or refurbishment to BFN to maintain consistency with the current licensing basis, and NRC and TVA requirements [and that] plant improvements including intake structures, buried piping, and large external tanks would be expected upgrades for continued operation from 60 to 80 years. TVA determined the APE for the undertaking as BFN and all areas within the 880-acre reservation. In February 2023, a desktop cultural review was conducted to examine the extent of inventoried archaeological and historic resources present within a 6-mile buffer surrounding BFN. This review considered the data maintained by the Alabama Historical Commission (AHC), available both in the public domain and by request for qualified cultural resources professionals, and the NRHP and National Historic Landmarks. This review indicated that a total of 10 cultural resources have been inventoried previously within or directly adjacent to the BFN, all of which represent archaeological sites. An additional five archaeological sites have been recorded within 1,000 feet of BFN. Further, large portions of the existing BFN site have been surveyed previously for cultural resources (Dison et al. 2020, Gage 2001, Gage and Hermann 2009, Marshall 2013, Stanton 2013), the extent of which has effectively accounted for all undeveloped elements of the current APE. Considering the desktop review examined out to the full 6-mile archival buffer, multiple cultural resources have been inventoried across the portion of all three counties which extend within this buffer. In summary:

Two NRHP properties are located within 6 miles of BFN, both situated on the opposite side of Wheeler Reservoir and south across the Mallard Fox Creek WMA: the Boxwood Plantation Slave Quarters in Lawrence County, and the Dr. William E. Murphey House in Morgan County. The Murphey House was destroyed by a tornado in 2011 and is no longer extant, while the Boxwood Plantation Slave Quarters is located approximately 4 miles southeast of BFN and is not directly visible from BFN. There are no National Historic Landmarks present within the 6-mile study buffer.
There are four resources listed in the Alabama Register of Landmarks and Heritage within the 6-mile study buffer, including both of the NRHP properties referenced above, Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-63

Appendix E - Applicants Environmental Report-Operating License Renewal Stage the circa (ca.) 1912 Nebo Community Church (Mt. Nebo Cumberland Presbyterian Church) and the ca. 1921 Tennessee Valley School in Hillsboro. Both the church and the school are located just under 6 miles distant from BFN.

In addition to the 10 archaeological sites located within BFN referenced above, over 250 archaeological sites have been previously inventoried within 6 miles of BFN. At least 170 of these contained evidence of precontact activities and occupations, with the remainder composed of historic period archaeological deposits (typically associated with the former locations of rural farms and residences). Not surprisingly, the majority of these inventoried archaeological sites are situated on landforms above and/or overlooking permanent water sources, particularly above the former alignment of the Tennessee River.
A total of 59 aboveground resources have been inventoried in the 6-mile vicinity of BFN through the AHCs architectural survey, the majority of which are residential dwellings constructed between 1900 and 1950. All 59 of these structures are located between 2 and 6 miles south of and across Wheeler Reservoir from BFN in Lawrence County. Due to the intervening topography and modern land use, it does not appear that any of these 59 resources are directly visible from BFN.
Four cemeteries are included in the Alabama Cemetery Register within the 6-mile study buffer, all of which were established in the nineteenth century, including three (the Minor Cemetery, Kimbell Cemetery and Bell-Nebo Cemetery) in Morgan County and one (the Elliott-Jackson Cemetery) in Lawrence County. All four of these cemeteries are located over 4 miles from BFN, and are not directly visible from BFN.
A total of 37 different cultural resources survey reports are on-file with the AHC within the 6-mile study buffer, including several which extend within the current BFN location and the existing BFN site.

The following section provides additional detail on the historic resources inventories data outlined above, specific to the current BFN location. 3.7.1. NRHP and Alabama Register of Landmarks and Heritage Properties The desktop archival review identified the presence of two NRHP and four Alabama Register properties within the 6-mile study buffer, none of which occur within or immediately adjacent to BFN. These properties include:

The Boxwood Plantation Slave Quarter is cross-listed in both the NRHP and the Alabama Register in Lawrence County. The slave quarter building is a brick structure that stands in its original location. It represents one of the very few extant slave quarters remaining in Alabama. The main plantation house that it was associated with was demolished in the 1950s for highway widening. The slave quarters period of significance is ca. 1854-1865.
The Dr. William E. Murphey House is cross-listed in both the NRHP and the Alabama Register in Morgan County. The ca.1830 structure, which once occupied this location, was destroyed by a tornado on April 27, 2011.

Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-64

Appendix E - Applicants Environmental Report-Operating License Renewal Stage

The ca. 1912 Nebo Community Church is listed in the Alabama Register. This church is the only church for the rural farm community of Jones Crossroads. It is one of only a few surviving buildings that date to the early 1900 in this area.
The ca. 1921 Tennessee Valley School in Hillsboro is listed in the Alabama Register.

The school was originally named the Tennessee Valley Primitive Baptist Institute and was used to educate local African American children. This two-story brick building closed in the 1960s after school integration. The majority of the building was destroyed in a fire in June of 2016 (Decaturdaily.com 2016, Flickr 2017). As noted above, the two extant NRHP and Alabama Register properties are each located over 4 miles from BFN and will not be directly or indirectly impacted by any proposed activities. 3.7.2. Archaeological Resources The February 2023 review identified the presence of over 260 archaeological sites previously inventoried within 6 miles of BFN. These sites contain archaeological evidence for both precontact and historic activity and occupation. A majority of the recorded sites (n=156) are characterized in the AHC system as unknown aboriginal precontact sites, followed by nineteenth/twentieth century historic deposits (most likely associated with the former locations of residential dwellings, barns and farmsteads). Multiple precontact sites contained materials diagnostic to a specific prehistoric temporal period, typically manifest as projectile points/knives and ceramics. Of the total inventory, most (n=206) were identified within 300 feet of a permanent water source, with several situated within the modern extent of Lake Wheeler (on landforms which once overlooked the Tennessee River). In 2021, TVA conducted a Phase I archaeological survey of undeveloped areas within the APE that had not been included in prior archaeological surveys meeting current survey standards, pursuant to Section 110 of the NHPA (Dison et al. 2022). The survey included systematic shovel testing and pedestrian survey of approximately 193 acres distributed across six separate areas. The survey revisited six previously-recorded archaeological sites (1LI24, 1LI284, 1LI286, 1LI287, 1LI856, and 1LI857) located within or adjacent to the survey area, and identified seven previously-unrecorded archaeological sites (1LI915, 1LI916, 1LI917, 1LI918, 1LI919, 1LI920, and 1LI921). Site 1LI24 is no longer extant, having been destroyed during construction of BFN. Site 1LI857 lacks intact deposits and is ineligible. Sites 1LI287 and 1LI856 have been combined into a single site (1LI287), and sites 1LI284 and 1LI286 also are combined into a single site (1LI284). TVA determined that sites 1LI284 and 1LI287 both have research potential and should be avoided by project activities, if possible. All seven newly recorded sites lack research potential and are ineligible for the NHRP (Dison et al. 2022). TVA consulted with the SHPO (and federally-recognized Indian tribes who have an interest in Limestone County, Alabama (Tribes) regarding the study and eligibility determinations. The SHPO agreed, and none of the Tribes disagreed or identified additional resources of concern in the APE. With the combined areas of Disons 2021 survey and prior archaeological surveys in the APE (Dison et al. 2020, Gage 2001, Gage and Hermann 2009, Marshall 2013, Stanton 2013) all areas within the APE that are not developed or subjected to heavy disturbance in the past (documented by construction drawings, historic photographs, or aerial imagery) have now been included in archaeological surveys meeting SHPO standards and TVA criteria for archaeological surveys. TVA has consulted with the SHPO and Tribes regarding each of these surveys, pursuant to §800.4. Besides sites 1LI284 and 1LI287, TVA and the SHPO have agreed that site 1LI535 also is potentially-eligible for the NRHP. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-65

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 3.7.3. Historic Resources TVA has previously consulted with the Alabama SHPO regarding an undertaking that resulted in physical effects on BFN, the BFN Cooling Tower Additions Project, in 2010. TVA found that the cooling tower capacity upgrades would not appreciably alter the existing silhouette of BFN and would therefore have no visual effect (Howard 2010). The Alabama SHPO agreed that the upgrades would not result in adverse effects to historic properties (letter from Brown to Howard dated October 25, 2010), but did not comment on BFNs NRHP eligibility. In an informal email correspondence with AL SHPO in regards to the Thermal Performance Program EA, the SHPO clarified that the 1974 cooling towers would not be National Register eligible due to age, the fact they were not part of the original design, and since they have lost their historic context due to the replacement of five of BFNs six original cooling towers after 2010 (Wofford 2020). TVA completed an architectural assessment of the Browns Ferry Aquatic Research Facility (BFARF) in 2018 (Karpynec and Weaver 2018). Based on this assessment, TVA determined that the BFARF is eligible for the NRHP under the Secretary of the Interiors Criteria Consideration G of 36 CFR 60.4 (A property achieving significance within the past 50 years if it is of exceptional importance) as a contributing resource to BFN, which although considered NRHP-eligible by TVA had not been determined eligible in consultation (Jones 2018a). The historic significance of the BFARF relates to TVAs efforts in the late twentieth century to study the environmental effects of heated water discharged from its nuclear-powered plants on regional aquatic life. The SHPO agreed by letter dated June 20, 2018. In consultation with SHPO, TVA proposed mitigation and prepared a draft Memorandum of Agreement (Jones 2018b, Jones 2018c), but TVAs plan to remove the BFARF was later cancelled and the mitigation was not completed. TVA conducted a historic architectural inventory of BFN and assessment of BFNs eligibility for inclusion in the NRHP (Reynolds 2022) to identify historic properties in the APE as required by §800.4. Based on this study, TVA has determined that BFN is eligible for the NRHP under Criteria Consideration G as a historic district with a period of significance of 1966-1980. BFN is also eligible for the NRHP under Criteria A and C for their association with early nuclear energy development in Alabama and the TVA system, and as representative examples of nuclear energy engineering and architecture. The BFN historic district is comprised of 49 buildings and structures. The Unit 1, Unit 2, and Unit 3 Reactor Buildings are individually eligible, and 46 buildings/structures are eligible as contributing to the district. The contributing buildings/structures include, as examples: the Units 1-3 containment structures, multiple diesel generator buildings, the Intake Pumping Station, Turbine Buildings, Discharge Structure, BFARF, Meteorological Tower, Switchyard, and Warm Water Channel. Twenty structures within the boundaries of the district are considered non-contributing due to being built after 1980. The NRHP boundary is the BFN reservation boundary. TVA provided this report (Reynolds 2022) to SHPO and invited their comments on the study and on the NRHP eligibility of BFN prior to making any decisions on SLR or future projects that could affect BFN. The SHPO agreed with TVAs findings and eligibility determination (Wofford to Osborne, November 14, 2022, Attachment C). Based on this finding, BRF is considered a historic property and TVA must the consider potential effects on BFN from any future undertaking that has potential for effects on historic properties. This would include formal evaluation of potential effects and additional consultation with the SHPO. The results of the February 2023 desktop cultural review identified a total of 59 aboveground resources situated within 6 miles of BFN inventoried previously with the AHC architectural survey. The closest resources to BFN, a pair of ca. 1925 houses (LA 0520 and LA 0519) are Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-66

Appendix E - Applicants Environmental Report-Operating License Renewal Stage located approximately 2.5 miles to the west of BFN on the opposite side of the Wheeler Reservoir. Out of the 59 aboveground resources, 50 are identified as residential with the remaining nine consisting of a church and eight commercial/ stores. None of these resources are currently listed in either the NRHP or the Alabama Register; however the data obtained from the AHC note Determination of Eligibility status for all the resources. A total of 19 aboveground resources are noted as having a Determination of Eligibility of eligible with the remaining 40 classified as not eligible. As stated above, due to the modern land use and intervening topography, none of these resources appear to be directly visible from BFN. 3.7.4. Cemeteries When TVA acquired 880 acres of land in the 1960s for the construction of BFN, one historic cemetery, known as the Cox Cemetery, was located on the property. Soon after TVAs acquisition of the property TVA survey crews identified seven graves belonging to individuals with the family names Cox, Lang, and Madrey. Burial dates range from 1836 to 1908. In 1966 TVA relocated all seven graves to a new location within the BFN reservation (Gage 2001). TVA does not consider the cemetery eligible for inclusion in the NRHP. However, TVA does consider the cemetery to be a significant cultural resource and has complied with Alabama state statutes regarding the treatment of human remains. Along with the previously recorded archaeological sites and aboveground resources, the February 2023 desktop review identified four cemeteries in the Alabama Cemetery Register within 6-miles of BFN. Three of these cemeteries were established during the early half of the nineteenth century while the fourth dates to the second half of the nineteenth century. The Minor Cemetery and Kimbell Cemetery are both small family cemeteries used from the early nineteenth century up to the late ninetieth to early twentieth century. The remaining two cemeteries, Bell-Nebo and Elliott-Jackson are still active cemeteries with over two hundred interments. The Bell-Nebo Cemetery includes internments from the Old Nebo Cemetery, an early slave cemetery that was moved from its original location to the current Bell-Nebo Cemetery. All four of these cemeteries are located over 4 miles from BFN. 3.8. Socioeconomics As stated in the 2013 Generic Environmental Impact Statement (GEIS), the nuclear plant and the communities that support it can be described as a dynamic socioeconomic system (NRC 2013). The communities provide the people, goods, and services needed to operate the nuclear power plant. Power plant operations, in turn, provide wages and benefits for people and dollar expenditures for goods and services. The communities ability to support power plant operations depends on how well it can respond to changing environmental, social, economic, and demographic conditions. The socioeconomics region of influence around a nuclear power plant is defined by the counties where plant employees and their families reside, spend their income, and use their benefits, thereby affecting the economic conditions of the region. Changes in nuclear power plant operations affect socioeconomic conditions in the surrounding regions, including employment and income; population and housing; community services; and transportation (NRC 2013). 3.8.1. Demography The GEIS presents a population characterization method used to evaluate the remoteness of areas in which nuclear plants are located. This method is based on two factors: sparseness and proximity. Sparseness measures population density and city size within 20 miles of a site. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-67

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Proximity measures population density and city size within 50 miles of the site. When combined, these two remoteness measures, combined with the population density and distance to larger cities allow for the classification of nuclear plants into three population classes: low, medium, and high. Sparseness categorizes the demographic information as follows (NRC 2013): Sparseness Category Most sparse 1. Less than 40 persons per square mile and no community with 25,000 or more persons within 20 miles.

2. 40 to 60 persons per square mile and no community with 25,000 or more persons within 20 miles.

3. 60 to 120 persons per square mile or less than 60 persons per square mile with at least one community with 25,000 or more persons within 20 miles.

Least sparse 4. Greater than or equal to 120 persons per square mile within 20 miles. Proximity categorizes the demographic information as follows (NRC 2013): Proximity Category Not in close proximity 1. No city with 100,000 or more persons and less than 50 persons per square mile within 50 miles.

2. No city with 100,000 or more persons and between 50 and 190 persons per square mile within 50 miles.

3. One or more cities with 100,000 or more persons and less than 190 persons per square mile within 50 miles.

In close proximity 4. Greater than or equal to 190 persons per square mile within 50 miles. Population was estimated from the BFN site out to 20-mile and 50-mile radii using the results of the U.S. Census Bureau (USCB) 2020 decennial census and geographic information system (GIS) software (ArcView) to determine demographic characteristics in the BFN vicinity. Block Groups not wholly within the area were allocated on the basis of the land area within the area. According to this analysis, 225,115 individuals live within 20 miles of the BFN site, for a population density of 179 persons per square mile. Athens City, located in Limestone County approximately 10 miles northeast of the site, had a population of 25,406. Decatur City, located in Morgan County approximately 10 miles southeast of the site, had a population of 57,938 (Google Earth 2022a, USCB 2020e). Applying the GEIS sparseness measures, the BFN site falls into the least sparse category, Category 4 (having greater than or equal to 120 persons per square mile within 20 miles of the plant) (NRC 2013). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-68

Appendix E - Applicants Environmental Report-Operating License Renewal Stage A total of 1,074,109 persons live within 50 miles of the site, for a population density of 136 persons per square mile. The largest city within the 50 mile radius is the City of Huntsville, with a population of 215,006, is located about 30 miles to the east of the site (Google Earth 2022a, USCB 2020e). This places the site in proximity Category 3 (having one or more cities with 100,000 people, and fewer than 190 persons per square mile within 50 miles of the plant) (NRC 2013). These ratings place BFN in category 4.3 of the GEIS Sparseness and Proximity Matrix which result in the conclusion that BFN is located in a high population area (NRC 2013). There are six counties within a 20-mile radius of the site, all within Alabama. The counties are Colbert County, Lauderdale County, Lawrence County; Limestone County, Madison County and Morgan County (Figure 3.8-1). Two counties (Colbert and Madison) have only a very small edge or corner and very little population within the 20-mile zone. There are 21 counties within a 50-mile radius of the site, located in both Alabama and Tennessee (Figure 3.8-2). Of these, 14 counties are located in Alabama and seven counties are in Tennessee. Three metropolitan areas are located largely or totally within the 50-mile zone: Decatur, Florence-Muscle Shoals, and Huntsville, all in Alabama. Approximately 83.2 percent of the employees (contract workers and employees) live in Alabama, 7.0 percent live in Tennessee, and the remaining 9.8 percent is distributed across 35 other states. As shown in Table 3.8-3, a majority, approximately 61.7 percent, live in three nearby counties, all in Alabama: Lauderdale (32.9 percent), Limestone (18.4 percent) and Colbert (10.4 percent). Thus, the following discussion specifically focuses on population growth in these three counties in relation to Alabama. Population Table 3.8-1 shows population between 2000 and 2020 in Lauderdale, Limestone and Colbert Counties and Alabama. Between 2010 and 2020, the population of Lauderdale, Limestone and Colbert Counties increased 0.9 percent, 25.1 percent, and 5.1 percent respectively. During the same period, population in the State of Alabama increased 5.1 percent (USCB 2010, USCB 2020i, USCB 2000b). As shown in Table 3.8.2, population in Limestone is projected to grow 17.6 percent between 2020 and 2030. During this same period the population of Lauderdale and Colbert County is projected to grow 3 percent and 2 percent respectively while the population of Alabama is projected to increase 5.6 percent (ASDC 2022, USCB 2020i). Housing As described above and as depicted in Table 3.8-3, 1,681 employees (approximately 61.7 percent) of BFN employees live in the three Alabama counties closest to BFN - Lauderdale (707 employees or 32.9 percent), Limestone (396 employees or 18.4 percent) and Colbert Counties (223 employees or 10.4 percent). The remaining 21.4 percent is distributed across 22 Alabama counties, with numbers ranging from 1 to 193 people. The larger cities within the three counties in proximity to BFN include Athens in Limestone County approximately 10 miles to the northeast, Huntsville in Madison County approximately 30 miles east, and Decatur in Morgan County approximately 10 miles southeast. As shown in Table 3.8-4, the cities of Athens, Florence and Killen have the highest numbers of employees in residence, with 13.5 percent, 12.8 percent and 9.0 percent respectively. Given the predominance of BFN employees living in Lauderdale, Limestone and Colbert Counties, the Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-69

Appendix E - Applicants Environmental Report-Operating License Renewal Stage focus of the analyses of housing and economy analysis in this Environmental Report is on these three counties. Lauderdale County - As shown in Table 3.8-5, housing units grew 1.8 percent, from 43,791 to 44,585 between 2010 and 2020. The 2020 vacancy rate was 11.3 percent (USCB 2000a, USCB 2012, USCB 2020d). Limestone County - Between 2010 and 2020, housing units grew 22.1 percent, from 34,977 to 42,692. The 2020 vacancy rate was 7.8 percent (USCB 2000a, USCB 2012, USCB 2020d, USCB 2020g). Colbert County - Between 2010 and 2020, housing units grew 7.4 percent, from 25,758 to 27,666. The 2020 vacancy rate was 11.7 percent (USCB 2000a, USCB 2012, USCB 2020d, USCB 2020g). Existing BFN Effects on Housing TVA refuels each nuclear unit on a 24-month cycle on a staggered basis. During these refueling outages, site employment increases by approximately 900 temporary workers for 28 to 45 days. Some temporary workers are from the BFN vicinity whereas others come into the area for temporary stays. Table 3.8-5 provides the number of housing units and housing unit vacancies for the years 2000, 2010 and 2020. Each of these counties had vacancy rates greater than 5 percent in 2020, indicating the availability of housing. In 2020, a combined total of 11,609 (10.1 percent) units were vacant, indicating that population increase related to refueling outage would not significantly impact availability. Available housing remained flat (decreased less than 1 percent) as compared to 2010 when approximately 11,627 units were available in those three counties combined (USCB 2000a, USCB 2012, USCB 2020d). Economy In 2020, per capita income for Lauderdale, Limestone and Colbert Counties was $28,540, $28,695, and $25,807 respectively. During the same period, per capita income was $28,934 in Alabama (USCB 2020g). Employment Lauderdale County - As shown in Table 3.8-6, between 2010 and 2020, the total number of jobs decreased 1.1 percent (from 43,230 to 42,760). In 2010, the leading sectors were government (14.3 percent), retail trade (13.9 percent) and health care and social assistance (9.5 percent). By 2020 a shift in leading sectors had occurred to retail trade (13.8 percent), government (13.3 percent) and health care and social assistance (12.1 percent) (BEA 2020). Limestone County - As shown in Table 3.8-6, between 2010 and 2020, the total number of jobs increased 21.3 percent (from 31,404 to 38,080). In 2010, the leading sectors were government (22.5 percent), retail trade (13.0 percent) and construction (10.6 percent). By 2020 a shift in leading sectors had occurred to government (19.4 percent), retail trade (12.9 percent) and manufacturing (11.1 percent) (BEA 2020). Colbert County - As shown in Table 3.8-6, between 2010 and 2020, the total number of jobs increased 5.8 percent (from 29,256 to 30,948). In 2010, the leading sectors were government (19.9 percent), manufacturing (13.5 percent), and retail trade (11.4 percent). By 2020 the Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-70

Appendix E - Applicants Environmental Report-Operating License Renewal Stage manufacturing sector was the leading sector (18.5 percent), followed by government (15.6 percent) and retail trade (11.7 percent) (BEA 2020). Unemployment The 2020 unemployment rate for the Alabama was 6.5 percent. In comparison, Lauderdale, Limestone and Colbert Counties had 2020 unemployment rates of 5.5, 4.3, and 6.6 percent, respectively (BLS 2020a, BLS 2020b). Taxes TVA does not pay property taxes; however, in accordance with federal law, Section 13 of the TVA Act, 16 U.S.C. 8311, TVA makes payments in lieu of taxation to states and counties in which its power operations are carried on and in which it has acquired properties previously subject to state and local taxation. Under Section 13, TVA pays 5 percent of its gross power revenues to such states and counties therein, for each fiscal year. Only a very small share of the payments is paid directly by TVA to counties; most is paid to the states, which use their own formulas for redistribution of some or all of the payments to local governments. TVA's payments in lieu of taxes are apportioned among the states and counties according to complex allocation formulas developed by each state in the TVA power service area, but in general, half of the money is apportioned based on power sales and half is apportioned based on the book value of TVA power property. Title 40 Chapter 28 of the Alabama State Code, updated in 2021, specifies how Alabama distributes TVA payments in lieu of taxes to its counties. Alabama retains 17 percent of TVAs payments for general fund purposes, allocates 78 percent to TVA-served counties based on a formula of TVA's book value of power property and power sales, and redistributes 5 percent to dry counties and municipalities that are not served by TVA. TVA-served counties share a portion of their payment with cities (based on a population ratio) within their boundaries (State of Tennessee 2022). As shown in Table 3.8-7, Alabamas payments in lieu of taxes allocation from TVA was $82.6 million in 2022. According to the Annual Report to the Tennessee General Assembly, Tennessee receives more than 67 percent of the total distributed by TVAs formula based on gross power revenues. Title 67, Chapter 9, Part 1 of the Tennessee Code Annotated specifies how the payments in lieu of taxes are distributed to cities and counties with additional payments set aside for local governments in counties with TVA construction. Local governments receive more than 40 percent of the amount TVA allocates to Tennessee for distributes through the states formula. (State of Tennessee 2022). As shown in Table 3.8-7, Tennessees payments in lieu of taxes allocation from TVA was $341.7 million in 2022. Community Services and Education As shown in Table 3.8-9, during FY 2020, public schools in this 21 county area in Tennessee and Alabama served more than 100,000 students (Alabama State Department of Education 2022, Blount County Schools 2022, Colbert County Schools 2022, Cullman County Schools 2022, Franklin County Schools 2022, Jackson County Schools 2022, Lauderdale County Schools 2022, Lawrence County Schools 2022, Limestone County Schools 2022, Madison County Schools 2022, Marion County Board of Education 2022, Marshall County Schools 2022, Morgan County Schools 2022, Tennessee Department of Education 2020, Walker County School 2022, Winston County Schools 2022). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-71

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 3.8.2. Transportation BFN is located approximately 10 miles southwest of Athens, Alabama. The site is approximately 6 miles south of U.S. Highway 72, which runs in an east-west direction passing through Huntsville, Athens, and Florence, Alabama. BFN is also approximately 9.3 miles and 10.5 miles west of U.S. Highway 31 and Interstate 65, respectively, which both run in a north-south direction through Athens to the north and Decatur to the south (Figure 3.0-1). U.S. Highway 72 and U.S. Highway 31 are both high quality four-lane routes with good lane widths, alignments, turning lanes, and speed limits of 45 mph through Athens and increasing away from the city. Employees commuting to and from BFN typically utilize the various paved, two-lane roads in the vicinity of the plant. Immediate road access to BFN is via County Road 20, which runs south from U.S. Highway 72 as Shaw Road and continues east just north of BFN as Nuclear Plant Road, ultimately intersecting with U.S. Highway 31. Browns Ferry Road is also a primary road to the site which runs northeast-southeast from Athens to Nuclear Plant Road near BFN (ALDOT 2022). Shaw Road, Nuclear Plant Road, and Browns Ferry Road are medium quality two lane roads with level alignment, some passing zones, and speed limits of 45 mph. The primary traffic generator in the vicinity of the site is the nuclear plant, which currently has approximately 2,147 employees. The employee population peaks at approximately 3050 to 3500 employees during refueling outages, which occur every 24 months (per unit) for approximately 28 to 45 days. Rural residences located along the county roads that provide access to the site are also traffic generators in the area. In 2021, Interstate 65, U.S. Highway 72, and U.S. Highway 31 had the greatest average daily traffic (ADT) counts at 30,476, 15,746, and 18,871 vehicles per day, respectively. In 2021, ADT for Shaw Road, Nuclear Plant Road, and Browns Ferry Road was 2,455, 2,302, and 1,185 vehicles, respectively (ALDOT 2022). Table 3.8-8 lists roadways in the vicinity of BFN and the ADTs for 2021. 3.8.3. Recreation Wheeler Reservoir is Alabamas second largest reservoir and is used for recreational fishing by residents. Fishery species include largemouth bass, small mouth bass, spotted bass, and catfish (Outdoor Alabama 2021). Developed recreation includes campgrounds, lodges, marinas, boat-launching ramps, parks, beaches, and day use facilities. Dispersed recreation activities include picnicking, primitive camping, hiking, hunting, kayaking, and canoeing (TVA 2017). Mallard-Fox Creek WMA is located about 2.5 miles south of BFN on the southern shore of Wheeler Reservoir in Lawrence County. The WMA is 1,483 acres and contains a number of habitats including hardwood forests, wildlife openings, grasslands, and agricultural fields and offers bird watching, hunting, canoeing and fishing opportunities (AL DCNR 2020, Alabama Birding Trails 2021c). The BP-Amoco Environmental trail is located 5 miles southeast of BFN. This is a walking and bird watching trail which travels through agricultural fields, and also has woodland and marsh habitat (Alabama Birding Trails 2021a). The Decatur/Wheeler Lake KOA Holiday is located approximately 2.2 miles west of BFN on the southern shore of Wheeler Reservoir. The KOA currently offers RV and tent camping and boat rentals, playground, outdoor movie theater, a zipline and rope park, water activities, and biking (KOA 2021a, KOA 2021b, The Raptor Adventure 2021). Cowford Campground is located approximately 3.0 miles southeast of BFN on the northern shore of Wheeler Reservoir in Limestone County. This site has 52 seasonal use campsites meant for RV and tent camping along with a boat ramp and fishing/boat pier (Limestone County 2021b). Cowford Campground is within the Round Island Creek Public use area and offers RV camping, swimming, fishing, Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-72

Appendix E - Applicants Environmental Report-Operating License Renewal Stage and boating (Limestone County 2021b). Round Island Recreation area is located approximately 3.0 miles southeast of BFN and offers canoeing, picnic areas, fishing, and a boat ramp (Alabama Birding Trails 2021d). Swan Creek Wildlife Management Area is used for hunting, fishing and boating and is approximately 8,642 acres including a portion of Wheeler Reservoir (Gaia GPS 2021). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-73

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 3.8-1. Nation, State, and County Population: 2000-2020 Percent (%) Percent (%) Percent (%) Change 2000 2010 2020 Change Change 2000 - 2020 2000 - 2010 2010 - 2020 Colbert County 54,984 54,428 57,227 -1.0 5.1 4.1 Lauderdale 87,966 92,709 93,564 5.4 0.9 6.4 County Limestone County 65,676 82,782 103,570 26.0 25.1 57.7 Alabama 4,447,100 4,779,736 5,024,279 7.5 5.1 13.0 United States 281,421,906 308,745,538 331,449,281 9.7 7.4 17.8 Source: (USCB 2010, USCB 2020i, USCB 2000b) Table 3.8-2. Nation, State, and County Population: 2020-2040 Percent (%) Percent (%) 2020 Projected 2030 Projected 2040 Change 2020-2030 Change 2020-2040 Colbert County 57,227 58,380 59,532 2.0 4.0 Lauderdale County 93,564 96,368 99,172 3.0 6.0 Limestone County 103,570 121,768 139,966 17.6 35.1 Alabama 5,024,279 5,306,554 5,588,829 5.6 11.2 United States 331,449,281 355,101,000 373,528,000 7.1 12.7 Source: (ASDC 2022, USCB 2017, USCB 2020i) Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-74

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 3.8-3. Counties Where BFN Workers Reside Number of Workers1 County State Percent (%) of Total Workers 396 Limestone County AL 18.4 47 Lawrence County AL 2.2 115 Morgan County AL 5.4 223 Colbert County AL 10.4 193 Madison County AL 9.0 707 Lauderdale County AL 32.9 1 Workers include permanent employees and contract personnel. Because of the COVID-19 pandemic, some TVA and contract personnel are allowed to work from remote locations. Some or all of the remote workers may, at the discretion of TVA, be required to report to the site. The numbers in this table are based upon work location assignments. Table 3.8-4. BFN Worker Residence by City and County Percentage (%) of Total BFN City (County) Employees Per City Workers (2147) Athens (Limestone) 290 13.5 Florence (Lauderdale) 274 12.8 Killen (Lauderdale) 194 9.0 Rogersville (Lauderdale) 155 7.2 Muscle shoals (Colbert) 99 4.6 Madison (Madison) 90 4.2 Tuscumbia (Colbert) 72 3.4 Decatur (Morgan) 61 2.8 Madison (Limestone) 58 2.7 Huntsville (Madison) 53 2.5 Lexington (Lauderdale) 51 2.4 Elkmont (Limestone) 36 1.7 Leighton (Colbert) 28 1.3 Anderson (Lauderdale) 25 1.2 Hartselle (Morgan) 25 1.2 1 Workers include permanent employees and contract personnel. Because of the COVID-19 pandemic, some TVA and contract personnel are allowed to work from remote locations. Some or all of the remote workers may, at the discretion of TVA, be required to report to the site. The numbers in this table are based upon work location assignments. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-75

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 3.8-5. Housing Units and Housing Units Vacant (Available) by County - 2000, 2010 and 2020 Percent Percent Percent (%) (%) (%) 2000 2010 2020 Change Change Change 2000-2010 2010-2020 2000-2020 Lauderdale County Housing Units 40,424 43,791 44,585 8.3 1.8 10.3 Occupied Units 36,088 38,680 39,544 7.2 2.2 9.6 Vacant Units 4,336 5,111 5,041 17.9 -1.4 16.3 Vacant Units Percent (%) of 10.7 11.7 11.3 0.9 -0.4 0.6 Total Units Limestone County Housing Units 26,897 34,977 42,692 30.0 22.1 58.7 Occupied Units 24,688 31,446 39,365 27.4 25.2 59.4 Vacant Units 2,209 3,531 3,327 59.8 -5.8 50.6 Vacant Units Percent (%) of 8.2 10.1 7.8 1.9 -2.3 -0.4 Total Units Colbert County Housing Units 24,980 25,758 27,666 3.1 7.4 10.8 Occupied Units 22,461 22,773 24,425 1.4 7.3 8.7 Vacant Units 2,519 2,985 3,241 18.5 8.6 28.7 Vacant Units Percent (%) of 10.1 11.6 11.7 1.5 0.1 1.6 Total Units Source: (USCB 2000a, USCB 2012, USCB 2020d) Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-76

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 3.8-6. Employment and Industry Sectors, 2010 - 2020 Other Services Total Government Health Care Accommodation (except Employment Farm Retail and Construction Manufacturing and Social and Food Government and (Number of Employment Trade Government Assistance Services Government Jobs) Enterprises Enterprises) Colbert, AL 29,256 2.5% 8.0% 13.5% 11.4% 8.1% 5.8% 6.3% 19.9% 2010 Colbert, AL 30,948 2.1% 8.5% 18.5% 11.7% 7.3% 5.5% 6.4% 15.6% 2020 Lauderdale, AL 43,230 3.6% 5.9% 8.2% 13.9% 9.5% 8.3% 7.3% 14.3% 2010 Lauderdale, AL 42,760 3.1% 6.5% 6.3% 13.8% 12.1% 8.9% 7.2% 13.3% 2020 Limestone, AL 31,404 4.6% 10.6% 7.9% 13.0% 5.0% 5.7% 6.8% 22.5% 2010 Limestone, AL 38,080 3.3% 10.0% 11.1% 12.9% 4.5% 5.2% 7.5% 19.4% 2020 Source: (BEA 2020) Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-77

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 3.8-7. TVA PILOT Payments Directly to Alabama and Tennessee from 2017 to 2022 (U.S. Dollars) Payments in lieu of taxes paid to Payments in lieu of taxes paid to Year Alabama Tennessee 2017 $ 87,016,906 $ 340,730,321 2018 $ 87,492,443 $ 343,986,487 2019 $ 85,761,959 $ 363,938,934 2020 $ 87,514,788 $ 369,443,363 2021 $ 79,291,166 $ 336,145,561 2022 $ 82,562,087 $ 341,689,664 PILOT - Payments in lieu of taxes Table 3.8-8. Roadways in the BFN Vicinity and Average Number of Vehicles Per Day Station ID Road 2021 Average Daily Traffic Count Limestone 916 Shaw Road 2,455 Limestone 917 Browns Ferry Rd 1,185 Limestone 119 Nuclear Plant Rd 2,302 Limestone 812 U.S. Highway 72 15,746 Limestone 502 U.S. Highway 31 18,871 Limestone 815 Interstate 65 (Athens) 30,476 Source (ALDOT 2022) Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-78

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 3.8-9. Public Schools in the Site Region State/City Number of Schools Number of Students Alabama Blount 20 7,653 Colbert 8 2,720 Cullman 28 9,349 Franklin 10 3,674 Jackson 18 5,188 Lauderdale 10 8,160 Lawrence 13 4,658 Limestone 17 11,042 Madison 29 19,478 Marion 10 3,280 Marshall 13 5,764 Morgan 18 7,616 Walker 16 7,492 Winston 10 2,292 Tennessee Franklin 11 374 Giles 8 279 Lawrence 13 555 Lincoln 8 272 Marshall 10 416 Maury 23 871 Wayne 8 176 Sources: (Alabama State Department of Education 2022, Blount County Schools 2022, Colbert County Schools 2022, Cullman County Schools 2022, Franklin County Schools 2022, Jackson County Schools 2022, Lauderdale County Schools 2022, Lawrence County Schools 2022, Limestone County Schools 2022, Madison County Schools 2022, Marion County Board of Education 2022, Marshall County Schools 2022, Morgan County Schools 2022, Tennessee Department of Education 2020, Walker County School 2022, Winston County Schools 2022) Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-79

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 3.8-1. Counties within 20 Miles of BFN Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-80

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 3.8-2. Counties within 50 Miles of BFN Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-81

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 3.9. Human Health 3.9.1. Radiological Hazards Depending on work assignments, occupational radiation exposure is possible for workers who have received radiation safety training and are classified as radiological workers. NRC regulations in 10 CFR Part 20 require that occupational radiation exposures be kept ALARA with a limit on the annual total effective dose equivalent (TEDE) for individual radiation workers of 0.05 Sieverts (5 rem) per year. Data from NRC indicate that BFN occupational radiation exposures fall within the range of those for other operating boiling water reactors (BWRs) with an average TEDE per worker of 1.36 millisievert (136 millirem; 0.136 rem) (NRC 2022). The 3-year average collective TEDE for BFN reported in 2020, which is the average collective dose per reactor from 2018 to 2020, was approximately 1.32 person-Sievert (132 person-rem) per reactor (NRC 2022). This value is higher than the national average collective dose per reactor for 31 United States BWRs which was approximately 1.06 person-Sievert (106 person-rem) for the same 3-year period (NRC 2022). For 2019 and 2020, the 3-year average collective dose per-reactor at BFN were 1.34 person-Sievert (134 person-rem) and 1.31 person-Sievert (131 person-rem), respectively. Although NRC requires nuclear plants to keep collective doses ALARA, there is no regulatory limit on collective dose (NRC 2022). The average TEDE per worker over the same 3-year period of 2018 to 2020 was 1.36 millisievert (136 millirem; 0.136 rem) for BFN and 1.15 millisievert (115 millirem; 0.115 rem) for all United States BWRs. The average TEDE per megawatt (MW) generated per year was 1.2 millisievert (120 millirem; 0.120 rem) for BFN and 1.1 millisievert (110 millirem; 0.110 rem) for the national average for BWRs (NRC 2022). To evaluate its impacts on the surrounding environment, TVA has implemented a REMP in the vicinity of BFN since 1968. Through this program, radiological impacts on non-radiological workers, the public and the environment are monitored, documented, and then compared to standards. The monitoring includes monitoring of the aquatic environment (fish and shoreline sediments), the atmospheric environment (airborne radioiodine, gross beta, and gamma), the terrestrial environment (crops, soil, milk), and direct radiation (TVA 2023). The BFN 2022 Annual Radiological Environmental Operating Report describes the results of the REMP. The 2022 environmental dosimeters indicated that there is no facility related dose measured in the environment around BFN. In 2022, there were no quarterly or annual dosimeters that exceeded the historical baseline plus the calculated minimum differential dose (TVA 2023). Air particulate, airborne radioiodine, and Cs-137 in soil concentrations were compared to the preoperational averages and reported annual concentrations were well below the preoperational averages (TVA 2023). 3.9.2. Microbiological Hazards Thermal effluents from nuclear power plants such as BFN that discharge to a large water body have the potential to promote the growth of thermophilic microorganisms, some of which can cause adverse effects on human health. Microorganisms of particular concern for their potential to impact the health of the public and plant workers include bacteria such as Salmonella species (spp.), Shigella spp., Pseudomonas aeruginosa, and Legionella spp., and free-living amoebae of the genera Naegleria and Acanthamoeba (NRC 2013). These microorganisms can grow in warm waters that can occur at nuclear power plants in cooling towers and cooling water discharges (NRC 2013). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-82

Appendix E - Applicants Environmental Report-Operating License Renewal Stage As discussed in Section 2.2.3.1, BFN usually releases cooling water from its once-through cooling system directly into Wheeler Reservoir. However, during periods of hot weather, the cooling water may be circulated through helper cooling towers prior to being discharged to the river/reservoir. The 2013 GEIS discusses microbiological hazards potentially associated with nuclear power plant thermal discharges (NRC 2013). The public has access to Wheeler Reservoir and could be exposed to thermophilic microorganisms during swimming, boating, or other recreational uses. If a nuclear plants thermal effluent promotes the growth of thermophilic microorganisms, recreational users could have an elevated risk of exposure when using waters near the nuclear plants discharge. Salmonella spp., Shigella spp., and Pseudomonas aeruginosa are usually transmitted through ingestion and cause fever, diarrhea, and potentially a variety of more serious effects. Two thermophilic microorganisms of particular concern due to their potential to cause fatalities are Legionella and Naegleria fowleri, which are discussed below. Legionella bacteria are responsible for Legionnaires disease, with the onset of pneumonia in the first two weeks following exposure through inhalation. Risk groups for serious effects from Legionella include the elderly, cigarette smokers, persons with chronic lung disease or an immunocompromising disease, and persons receiving immunosuppressive drugs (NRC 2013). A temperature range of 77°F to 113°F is favorable for Legionella growth (CDC 2021a). Exposure to Legionella from plant operations is a potential problem for workers who dislodge biofilms during the cleaning of condenser tubes or cooling towers (NRC 2013). TVA has performed rigorous sampling of cooling tower basins, cooling tower water, and surrounding areas with the potential for growth of Legionella. Sampling results identified levels of Legionella that were lower than the standard threshold that could potentially impact workers or the publics health. Naegleria fowleri (N. fowleri) is a free-living pathogenic amoeba that occurs naturally in surface waters and is the main cause of primary amoebic meningoencephalitis (PAM). N. fowleri is thermophilic and can grow in heated plant effluent and become a hazard to recreational water users. Amoebic meningoencephalitis is an extremely rare disease that results from the nasal intake of water containing the amoeba. Primary affected groups are individuals of all ages, but groups with the greatest risk of severe disease include infants, the elderly, and those with compromised immune systems. N. fowleri is commonly present in freshwaters in the United States; however, infections are rare. From 1962 through 2021 there were only 154 reported cases of N. fowleri infection in the United States. Of those 154 cases, 36 were reported between 2011 and 2021 (CDC 2021c) Alabama has not reported any cases of N. fowleri infection (CDC 2021b). No data currently exist to accurately estimate the true risk of PAM, and low infection rates make epidemiological studies difficult (CDC 2020). No method currently exists to accurately measure the numbers of amoebae in water, making it unclear how to set standards to protect human health (CDC 2017). N. fowleri is rarely found in water temperatures below 95°F, and infections rarely occur at temperatures of 95°F or below. Increases in growth of N. fowleri occur when water temperatures range from 95°F to 106°F or higher (NRC 2013). Discharge limitations in NPDES Permit No. AL0022080 include a daily maximum temperature of 93°F (hourly average of the three downstream temperature monitors) and a daily average temperature of 90°F (when the 24-hour ambient average temperature exceeds 90°F, the downstream temperature may equal but not exceed the upstream value) (ADEM 2018). From 2015 to 2020, average water temperatures from the cooling water discharge during the warmest months of the year did not exceed 90°F. Maximum temperatures recorded during those months and years did not exceed 91°F. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-83

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 3.9.3. Electric Shock Hazards The 500 kV switchyard will remain in place and energized regardless of SLR. The 500 kV switchyard is located entirely on the BFN site and in-scope 500 kV lines are located completely within the BFN site boundary. The only purpose of the 161 kV switchyard is to provide power from the grid to some BFN loads. The 161 kV switchyard would not be needed if BFN was decommissioned. The 161 kV transmission lines would remain energized however and would effectively bypass (pass through) the BFN site. The 161 kV switchyard and lines supplying BFN loads are also located entirely within the BFN site boundary. Thus, the in-scope transmission lines are located entirely within the BFN site and are not accessible to the public. All in-scope transmission lines meet national electric safety code (NESC) standards. The electric shock hazards associated with these lines are controlled in accordance with applicable industrial safety standards. 3.10. Environmental Justice The environmental justice analysis identifies disadvantaged communities (minority, low-income, migrant, and subsistence) around BFN and considers whether these communities might suffer disproportionately high and adverse human health or environmental effects as a result of SLR. The NRC has performed environmental justice analyses in site-specific environmental impact statements for multiple nuclear power plant license renewals. In doing so, NRC established the use of a 50-mile radius as the overall area that would reasonably experience potential environmental impacts for the local population. The NRC also established the state or states that have land within the 50-mile radius of the nuclear plant seeking license renewal as the geographic area for acceptable comparative analysis (NRC 2013). For this ER, TVA has adopted this approach for identifying the BFN minority and low-income populations that could be impacted by activities at BFN. The NRC guidance calls for use of the most recent USCB decennial census data to identify minority and low-income populations. TVA used 2020 decennial census data from the USCB to determine the percentage of the total population within the states of Tennessee and Alabama for each minority category and to identify the aggregate minority populations within 50 miles of BFN (Figure 3.10-1). Estimates from the 2016-2020 American Community Survey were used to identify the low-income population. TVA used ArcView GIS software to combine 2020 USCB block group data with Environmental Systems Research Institute tract-boundary spatial data to determine the minority and low-income characteristics for the 50-mile radius around BFN. All block groups located wholly or partly within 50 miles of BFN were included in the analysis. The 50-mile radius includes 785 block groups. The following sections describe the minority and low-income populations found within the 50-mile radius. 3.10.1. Minority Populations The NRC guidance for performing environmental justice reviews defines a minority population as: Hispanic, Latino, or Spanish origin; American Indian or Alaskan Native; Asian; Black or African American; Native Hawaiian and Other Pacific Islander; or individuals who identified themselves on a census form as being a member of two or more races (NRC 2013). The guidance indicates that a minority population exists if either of the two following conditions exists: Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-84

Appendix E - Applicants Environmental Report-Operating License Renewal Stage

Exceeds 50 Percent - the minority population of an impacted area exceeds 50 percent or
Meaningfully Greater - the minority population percentage of the impacted area is meaningfully greater (for this analysis at least 10 percent) than the minority population percentage in the geographic area chosen for comparative analysis.

TVA calculated percent minority populations by dividing USCB population numbers for the minority population within each census block group by the total population of the respective state where each block group is located. The meaningfully greater criterion is used rather than the exceeds 50 percent criterion because the meaningfully greater is a more conservative estimate. Table 3.10-1 presents the number of census tracts within each county that exceed the threshold for determining the presence of a minority population. For each of the 785 census block groups within 50 miles of BFN, TVA calculated the percent of the population for the aggregate minority population as well for each minority group (Black, Latino, Asian, Native American, Native Hawaiian, other, multi-race) and compared the result to the corresponding threshold percent to determine whether a significant minority population exists. For Alabama, the presence of a significant minority population was found in nine of 14 counties (64.3 percent) and in 131 of 692 block groups (18.9 percent). In Tennessee the presence of a significant minority block group was found in 2 out of 7 counties (28.6 percent) and 3 out of 93 block groups (3.2 percent) (USCB 2020a, USCB 2020h). Based on the most encompassing criterion for each state, the most prevalent minority population is Black or African American. As shown in Table 3.10-1, Black or African American populations exist in 83 block groups: 80 in Alabama, and three in Tennessee. Hispanic minority populations are the second most common and exist in 65 block groups, all in Alabama (USCB 2020a, USCB 2020h). Figure 3.10-1 shows the aggregate minority population block groups within 50 miles of BFN. Figure 3.10-2 shows the significant Hispanic and Black or African American Block Groups within a 50-mile radius of BFN which tend to be concentrated in urban areas. 3.10.2. Low-Income Populations NRC guidance defines low-income by using USCB statistical poverty thresholds (NRC 2013). The guidance indicates that a low-income population exists if either of the two following conditions exists:

Exceeds 50 Percent - the low-income population of an impacted area exceeds 50 percent or
Meaningfully Greater - the low-income population percentage of the impacted area is meaningfully greater (for this analysis at least 10 percent) than the low-income population percentage in the geographic area chosen for comparative analysis.

For the low-income population, the meaningfully greater criterion was the most conservative. Applying the NRC criteria, 126 of the 785 census block groups contain low-income populations. Table 3.10-1 presents the number of census tracts within each state and county that exceed the threshold for determining the presence of low-income populations. Based on an analysis of USCB American Community Survey 2016-2020 population estimates, TVA determined the Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-85

Appendix E - Applicants Environmental Report-Operating License Renewal Stage percent of low-income block groups within the 50-mile radius from BFN. In Alabama, 16.2 percent of blocks groups were low-income. In Tennessee, 15.1 percent of block groups were low-income. Figure 3.10-3 shows the locations of significant low-income populations within the 50-mile radius (USCB 2020b, USCB 2020c). 3.10.3. Subsistence-Like Populations and Migrant Workers Subsistence refers to the use of natural resources as food for direct consumption (rather than produced for sale) or for use in ritual practices or ceremonies, usually by low-income and minority populations. This would include groups in which hunting, gathering, fishing, and gardening constituted a larger fraction of the subpopulations food sources than those of the general population. According to the Encyclopedia of Alabama, Alabama has long had a strong rural tradition based on farming. Subsistence farming dominated Alabama life until the mid-twentieth century. Most families in Alabama lived on small plots of land that allowed them to sustain themselves. Rural gatherings focused on locally grown and processed food such as fish frys, cane grindings, peanut boils and chicken stews provided a social outlet, and became traditions. Subsistence as a way of life declined in the early 1940s, as industries associated with World War II caused people to leave rural areas and move to the cities for work. Urbanization pressures continued into the 1960s during the Great Migration as African Americans moved north to seek better jobs and freedom from racial discrimination (Encyclopedia of Alabama 2021). TVA queried government organizations, and social welfare organizations to identify the existence of subpopulations near BFN that engage in a subsistence-like lifestyle. No organization identified any subpopulations with resource dependencies or practices, such as subsistence agriculture, hunting, or fishing. There are a number of Amish and Mennonite communities within a 50-mile radius of BFN. There are Mennonite congregations near Hartselle, AL (Morgan County) and an Amish settlement in Ethridge, TN (Lawrence County) (Google Earth 2022b, Smietana 2012, Young Center for Anabaptist and Pietist Studies 2022). These subpopulations dont meet the definition of an environmental justice community as they are not a minority or low-income population. However, aspects of their lifestyles, such as hunting, fishing and maintaining large gardens for their own consumption are commonly referred to as subsistence based. While such practices may constitute a significant part of their food supply, many items are bought from traditional stores and supermarkets, and their approach to hunting and fishing is considered recreational. As a result of the use of gardening as a supplement to their food source, and a recreational approach to hunting, it was concluded that their lifestyle behaviors reflect a self-sufficiency philosophy instead of subsistence behavior. Therefore, it was concluded that no subpopulations near BFN engage in a subsistence-like lifestyle. A migrant farm worker is one whose employment required travel that prevented the worker from returning to his/her permanent place of residence the same day. In 2017, Alabama had 175 farms with migrant workers and a total of 1,864 migrant workers while Tennessee had 557 farms with migrant workers and a total of 5,038 migrant workers (USDA 2017d, USDA 2017e). See Table 3.10-2 for a list of migrant workers by state and county within the 50-mile radius of BFN. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-86

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 3.10-1. Minority and Low-Income Populations Within 50-mile Radius Minority Block Groups2 Total Low- Native Number American State / Income1 Black or Hawaiian Some of Indian or County Block Aggregate African Asian or Other Other Multiracial Hispanic Block Native Groups American Pacific Race Groups Alaskan Islander Alabama 692 112 131 80 0 6 0 0 1 65 Blount 4 1 0 0 0 0 0 0 0 1 Colbert 49 12 5 5 0 0 0 0 0 0 Cullman 65 5 0 0 0 0 0 0 0 2 Franklin 23 4 5 0 0 0 0 0 0 11 Jackson 4 0 0 0 0 0 0 0 0 0 Lauderdale 71 13 5 3 0 0 0 0 0 2 Lawrence 31 4 4 4 0 0 0 0 1 0 Limestone 52 7 6 2 0 2 0 0 0 6 Madison 245 39 85 59 0 4 0 0 0 18 Marion 8 2 0 0 0 0 0 0 0 0 Marshall 25 2 0 0 0 0 0 0 0 0 Morgan 88 19 21 7 0 0 0 0 0 25 Walker 3 1 0 0 0 0 0 0 0 0 Winston 24 3 0 0 0 0 0 0 0 0 Tennessee 93 14 3 3 0 0 0 0 0 0 Franklin 1 0 0 0 0 0 0 0 0 0 Giles 20 2 1 1 0 0 0 0 0 0 Lawrence 31 7 0 0 0 0 0 0 0 0 Lincoln 25 3 2 2 0 0 0 0 0 0 Marshall 5 0 0 0 0 0 0 0 0 0 Maury 3 0 0 0 0 0 0 0 0 0 Wayne 8 2 0 0 0 0 0 0 0 0 Source: (USCB 2020a, USCB 2020b, USCB 2020c, USCB 2020h) Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-87

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 3.10-2 Migrant Workers by County Within 50-mile Radius Number of farms with # of migrant State County migrant workers workers Alabama Blount 9 105 Colbert 6 6 Cullman 6 11 Franklin 1 (D) Jackson 2 (D) Lauderdale 0 0 Lawrence 0 0 Limestone 3 (D) Madison 2 (D) Marion 1 (D) Marshall 1 (D) Morgan 1 (D) Walker 2 (D) Winston 0 0 Tennessee Franklin 8 22 Giles 1 (D) Lawrence 3 (D) Lincoln 10 102 Marshall 2 (D) Maury 4 10 Wayne 0 0 D = withheld to avoid disclosing data for individual operations. Source: (USDA 2017d, USDA 2017e) Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-88

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 3.10-1. Aggregate Minority Block Groups within 50 Miles of BFN Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-89

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 3.10-2. Hispanic and Black or African Block Groups within 50 Miles of BFN Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-90

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Figure 3.10-3. Poverty Block Groups within 50 Miles of BFN Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-91

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 3.11. Waste Management Section 2.2.4 of this Environmental Report describes the radioactive waste management systems. Section 2.2.5 describes the nonradioactive waste management systems. As stated in Sections 2.2.4 and 2.2.5, nonradioactive and radioactive wastes are all managed according to state and federal regulations, as implemented through TVA procedures. 3.12. References ADEM (Alabama Department of Environmental Management). 2014. 2014 Integrated Water Quality Monitoring and Assessment Report. Water Quality in Alabama 2012-2014. April 1, 2014. ADEM. 2015. Water Quality Program. Administrative Code Chapter 335-6-6. National Pollutant Discharge Elimination System. ADEM. 2018. National Pollutant Discharge Elimination System (NPDES), Permit Number: AL0022080. Permittee: Tennessee Valley Authority, Browns Ferry Nuclear Plant, Issuance Date: June 7, 2018, Effective Date: July 1, 2018, Expiration Date: August 31, 2023. ADEM. 2020. Alabama 303(d) List. Accessed September 20, 2021 at http://adem.alabama.gov/programs/water/wquality/2020AL303dList.pdf. ADEM. 2021. NPDES Permits. Accessed September 20, 2021 at http://adem.alabama.gov/programs/water/permitting.cnt. ADPH (Alabama Department of Public Health). 2020. Alabama Fish Consumption Advisories 2020. July 2020. ADPH. 2022. Alabama Fish Consumption Advisories 2022. June 2022. AL DCNR (Alabama Department of Conservation and Natural Resources). 2020. Swan Creek Wildlife Management Area and Mallard-Fox Creek Wildlife Management Area Map. Alabama Birding Trails. 2021a. BP-Amoco Environmental Trail. Accessed September 21, 2021 at https://alabamabirdingtrails.com/sites/bp-amoco-environmental-trail/. Alabama Birding Trails. 2021b. Limestone. Accessed September 15, 2021 at https://alabamabirdingtrails.com/counties/limestone/. Alabama Birding Trails. 2021c. Mallard Fox Creek Wildlife Management Area. Accessed September 13, 2021 at https://alabamabirdingtrails.com/sites/mallard-fox-creek-wildlife-management-area. Alabama Birding Trails. 2021d. Round Island Recreation Area. Accessed September 21, 2021 at https://alabamabirdingtrails.com/sites/round-island-recreation-area/. Alabama State Department of Education. 2022. Alabama State Department Of Education School System Per-Pupil Expenditures FY 2020. Accessed September 21, 2022 at Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-92

Appendix E - Applicants Environmental Report-Operating License Renewal Stage https://www.alabamaachieves.org/wpcontent/uploads/2021/12/RepData_Fin_20211215_ SystemLevelPPE_FY2020_20210824_Publish_V1.0.pdf. ALDOT (Alabama Department of Transportation). 2022. Alabama Traffic Data. 2021 Average Annual Daily Traffic. Accessed September 2, 2022 at https://aldotgis.dot.state.al.us/TDMPublic/. ALNHP (Alabama Natural Heritage Program). 2021. Rare Species Lists by County, Limestone County. Accessed September 8, 2021 at www.auburn.edu/cosam/natural_history_museum/alnhp/data/index.htm. Amaker T. 2021. Browns Ferry Nuclear Mussel Survey, Limestone County, Alabama. July 12-13, 2021. Arcadis. 2016. Site Conceptual Model Update. Browns Ferry Nuclear Plant. Athens, Alabama. November. Arcadis. 2021. 2021 Site Conceptual Model Update. Browns Ferry Nuclear Plant. Athens, Alabama. September. ASDC (Alabama State Data Center). 2022. Alabama County Population Estimates as of August 2022. Accessed September 29, 2023 at https://alabama.app.box.com/s/07wi7a7u1qe1wk48yrngdt4yjnsqapw1.. BEA (U.S. Bureau of Economic Analysis). 2020. Total Full-Time and Part-Time Employment by NAICS Industry 1/. Accessed September 3, 2022 at https://apps.bea.gov/iTable/iTable.cfm?reqid=70&step=1&acrdn=6. Blount County Schools. 2022. All Schools - Blount County School District. Accessed September 21, 2022 at https://www.blountk12.org/our_district/schools/all_schools. BLS (Bureau of Labor Statistics). 2020a. Labor Force Data By County, 2020 Annual Averages. Accessed September 20, 2021 at https://www.bls.gov/lau/#cntyaa. BLS. 2020b. Labor Force Data By State. Accessed October 27, 2022 at https://www.bls.gov/lau/lastrk20.htm. Boggs JM. 1982. Browns Ferry Nuclear Plant Low-Level Radwaste Storage Facility Groundwater Pathway Analysis. October 1982. Brady J., Kunz T.H., Tuttle M.D. and Wilson D. 1982. Gray Bat Recovery Plan. U.S. Fish and Wildlife Service. Denver, Colorado. July 1, 1982. Buecker Zach. 2021. TVA Environmental Impact Statement Input - Wetlands. February 3, 2021. Call J.M., TVA Muscle Shoals, AL,, Wastrack K.G. and Cook T.M. 2013. The Impact of the April 27, 2011 Severe Weather Outbreak on TVAs Radiological Emergency Preparedness Program. Accessed February 8, 2023 at https://ams.confex.com/ams/93Annual/webprogram/Paper214217.html. Cardno. 2020. Environmental Noise Assessment - Browns Ferry Nuclear Plant. August 2020. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-93

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Cardno. 2022. Noise Assessment - Browns Ferry Nuclear Plant. August 24, 2022. CDC (Centers for Disease Control and Prevention). 2017. Parasites Naegleria fowleri Primary Amebic Meningoencephalitis (PAM) Amebic Encephalitis. Accessed September 1, 2021 at https://www.cdc.gov/parasites/naegleria/index.html. CDC. 2020. Prevention & Control, Naegleria fowleri, Risk of Infection. Accessed September 17, 2021 at https://www.cdc.gov/parasites/naegleria/prevention.html. CDC. 2021a. Controlling Legionella in Cooling Towers. Accessed November 10, 2022 at https://www.cdc.gov/legionella/wmp/control-toolkit/cooling-towers.html. CDC. 2021b. Number of Case Reports of Primary Amebic Meningoencephalitis by State of Exposure* United States, 1962-2020. Accessed August 30, 2021 at https://www.cdc.gov/parasites/naegleria/state-map.html. CDC. 2021c. Parasites, Naegleria fowleri, primary amebic meningoencephalitis (PAM). Case Report Data and Graphs. Accessed September 16, 2021 at https://www.cdc.gov/parasites/naegleria/graphs.html. Center for Sustainable Systems, University of Michigan. 2023. Greenhouse Gases Factsheet. Pub. No. CSS05-21. Accessed November 8, 2023 at https://css.umich.edu/sites/default/files/2023-10/GHG_CSS05-21.pdf. Chaney Philip. 2020. Encyclopedia of Alabama_Climate. May 6, 2020. Accessed February 15, 2023 at http://www.encyclopediaofalabama.org/article/h-1283. City of Decatur Alabama. 2018. Comprehensive Plan. Decatur, Alabama. February 2018. City of Decatur Alabama. 2020. FY 2020-2024 Consolidated Plan and FY 2020 Annual Action Plan. February 2020. City of Decatur Alabama. 2023. Outdoor Recreation. Accessed November 8, 2023 at https://www.cityofdecatural.com/play/outdoor-recreation/. City of Moulton. 2013. City of Moulton Zoning Ordinance. City of Moulton. 2021. City of Moulton. Accessed September 10, 2021 at https://www.cityofmoultonal.com. CNS and GEL Labs (Chesapeake Nuclear Services Inc. and GEL Laboratories). 2022. 2021 Annual Radiological Environmental Operating Report. May. Colbert County Schools. 2022. Colbert County School District. Accessed September 21, 2022 at https://www.colbertk12.org/. Cook Marlon R. and Dorina Murgulet. 2012. Groundwater Hydrogeologic Characterization, Preservation, and Development in the Trussville Area, Jefferson and St. Clair Counties, Alabama. Geological Survey of Alabama. Open-File Report 1205. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-94

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Cowardin L.M., V. Carter, F.C. Golet, and E.T. LaRoe. 1979. Classification of Wetland and Deepwater Habitats of the United States. Washington, D.C.: U.S. Fish and Wildlife Publication FWS/OBS-79/31. December 1979. Cullman County Schools. 2022. Cullman County School District. Accessed September 21, 2022 at https://www.ccboe.org/page/parent-community. Davis A.K. and Howard E. 2005. Spring recolonization rate of monarch butterflies in eastern North America: New estimates from citizen-science data. Journal of the Lepidopterists Society. 59(1): 1-5. Dison Braden A., Dan H. Webb, Heather Bass, Elin Crook and Johnson Hunter B. 2020. A Phase I Archaeological Survey of Browns Ferry Nuclear Plant Meteorological Tower Tree Clearing Project in Limestone County, Alabama. Prepared by Tennessee Valley Archaeological Research, Huntsville, Alabama. Prepared for Tennessee Valley Authority, Knoxville, Tennessee. Classified report, not publicly available. Dison Braden A., Heather Bass, Hunter B. Johnson, Brittney Carnell, Katie Weis and Breiding Katie. 2022. A Phase I Archaeological Survey of Previously Unsurveyed Areas within the Tennessee Valley Authoritys Browns Ferry Nuclear Plant in Limestone County, Alabama. Prepared by Tennessee Valley Archaeological Research, Huntsville, Alabama. Prepared for Tennessee Valley Authority, Knoxville, Tennessee. Classified report, not publicly available. EIA (U.S. Energy Information Administration). 2019. Energy-Related Carbon Dioxide Emissions by State, 2005-2016. February 2019. Encyclopedia of Alabama. 2021. Alabama Foodways. Accessed September 19, 2021 at http://encyclopediaofalabama.org/article/h-3477. Ensafe. 2012. Environmental Sound Pressure Level Assessment Report Browns Ferry Nuclear Plant Revision 1. Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual. January 1987. FICON (Federal Interagency Committee On Noise). 1992. Federal Agency Review on Selected Airport Noise Analysis Issues. August 1992. Florida Museum. 2023. Atlantic Needlefish - Discover Fishes. Accessed October 2, 2023 at https://www.floridamuseum.ufl.edu/discover-fish/florida-fishes-gallery/atlantic-needlefish/. Franklin County Schools. 2022. Franklin County School District. Accessed September 21, 2022 at https://www.franklin.k12.al.us/Page/http%3A%2F%2Fwww.franklin.k12.al.us%2Fsite%2 Fdefault.aspx%3FPageID%3D1. Fuller Pam and Neilson Matt. 2023. Yellow Perch (Perca flavescens) - Species Profile. U.S. Geological Survey, Nonindigenous Aquatic Species Database. Revision Date: August Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-95

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 15, 2019. Accessed October 2, 2023 at https://nas.er.usgs.gov/queries/factsheet.aspx?SpeciesID=820. Gage Matthew D. 2001. A Cultural Resources Reconnaissance Survey of Three Locations for the Proposed Expansion of Browns Ferry Nuclear Power Plant in Limestone County, Alabama. Prepared by The University of Alabama Office of Archaeological Services, Moundville, Alabama. Prepared for Tennessee Valley Authority, Division of Land and Forest Resources, Norris, Tennessee. Classified report, not publicly available. Gage Matthew D. and Hermann Nicholas P. 2009. Archaeological Site Identification and Erosion Monitoring for the TVA Reservoir Operation Compliance Project: 2005-2009 Field Seasons on Portions of Blue Ridge, Chatuge, Cherokee, Fontana, Hiwassee, Norris, Nottely, Pickwick, South Holston, Watauga, and Wheeler Reservoirs. Wheeler Volume. Prepared by The Archeological Research Laboratory, Department of Anthropology at the University of Tennessee, Knoxville. Prepared for Tennessee Valley Authority, Knoxville, Tennessee. Classified report, not publicly available. Gaia GPS. 2021. Alabama WMAs Swan Creek Wildlife Management Area. Accessed September 21, 2021 at https://www.gaiagps.com/hunting/alabama/wildlife-areas/113/gaiagps.com. Geosyntec. 2013. Browns Ferry Nuclear Plant Conceptual Site Model Revision 0. Browns Ferry Nuclear Plant. Athens, Alabama. March. Gibbons W. and Dorcas M. 2005. Snakes of the Southeast. Athens, Georgia: University of Georgia Press, 253pp. Google Earth. 2022a. Alabama. Accessed at https://earth.google.com/web. Google Earth. 2022b. Mennonite Congregations. Accessed September 19, 2022 at https://www.google.com/search?q=mennonite+communities+in+alabama&rlz=1C1GCEB _en&oq=mennonite+population+in+alabama&aqs=chrome.1.69i57j0i22i30j0i390.7573j0j 7&sourceid=chrome&ie=UTF-8. Griffith, GE, Omernik, JM, Comstock, JA, Lawrence, S, Martin, G, Goddard, A, Hulcher, VJ and Foster, T. 2001. Ecoregions of Alabama and Georgia. Howard E. 2010. Browns Ferry Nuclear (BFN) Power Plant Cooling Tower Additions, Limestone County, Alabama. Communication to S. Hathorn, Alabama Historical Commission. September 24, 2010. IPCC (Intergovernmental Panel on Climate Change). 2021. Climate Change 2021 - The Physical Science Basis. Contribution of Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change. Jackson County Schools. 2022. Jackson County School District. Accessed September 21, 2022 at https://www.jacksonk12.org/Domain/http%3A%2F%2Fwww.jacksonk12.org%2Fsite%2F default.aspx%3FDomainID%3D1109. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-96

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Janasie J.D. LL.M., Catherine. 2014. Climate Resiliency on Dauphin Island, Alabama. Sea Grant Law and Policy Journal. 6(2): 54-72. Jones C. E. 2018a. Tennessee Valley Authority (TVA) Browns Ferry Aquatic Research Facility, Limestone County, Alabama. Communication to L. A. Wofford, Alabama Historical Commission. May 21, 2018. Jones C. E. 2018b. Tennessee Valley Authority (TVA), Executed Memorandum of Agreement (MOA) for the Browns Ferry Aquatic Research Facility, Limestone County, Alabama (AHC 2018-0907). Communication to L. A. Wofford, Alabama Historical Commission. November 16, 2018. Jones C. E. 2018c. Tennessee Valley Authority (TVA), Memorandum of Agreement (MOA) for the Browns Ferry Aquatic Research Facility, Limestone County, Alabama (AHC 2018-0907). Communication to L. A. Wofford, Alabama Historical Commission. September 19, 2018. Karpynec T. and Weaver M. 2018. Phase I Architectural Assessment for the Tennessee Valley Authoritys Browns Ferry Aquatic Research Facility, Limestone County, Alabama. Prepared by Tennessee Valley Archaeological Research, Huntsville, Alabama. Prepared for Tennessee Valley Authority, Knoxville, Tennessee. Classified report, not publicly available. Keller Reuben P., Gabrielle Habeeb, Trent Henry and Jonathon Brenner. 2017. Non-native amphipod, Apocorophium lacustre (Vanhoffen, 1911), in the Illinois River and Chicago Area Waterway System, Management Biological Invasions. Volume 8(3): 377-382. KOA (Kampgrounds of America, Inc.). 2021a. Decatur/Wheeler Lake KOA Holiday. Accessed September 2, 2021 at https://koa.com/campgrounds/decatur/. KOA. 2021b. Decatur/Wheeler Lake KOA Holiday Amenities. Accessed September 21, 2021 at https://koa.com/campgrounds/decatur/amenities/. Lauderdale County Schools. 2022. Lauderdale County School District. Accessed September 21, 2022 at https://www.lcschools.org/Page/http%3A%2F%2Fwww.lcschools.org%2Fsite%2Fdefault

       .aspx%3FPageID%3D2822.

Lawrence County Chamber of Commerce. 2021a. About Lawrence County. Accessed September 2, 2021 at https://www.lawrencecountyalabama.com/about-lawrence-county. Lawrence County Chamber of Commerce. 2021b. Tourist Attractions. Accessed September 2, 2021 at https://www.lawrencecountyalabama.com/tourist-attractions. Lawrence County Road Department. 2020. Zoning/Permits Unincorporated Lawrence County, Alabama. Communication to T. W. I. M. Concern, January 1, 2020. Lawrence County Schools. 2022. Lawrence County School District. Accessed October 27, 2022 at https://www.lawrenceal.org/domain/http%3A%2F%2Fwww.lawrenceal.org%2Fsite%2Fd efault.aspx%3FDomainID%3D1489. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-97

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Liebig J., Larson J. and Fusaro A. 2019. Branchiura sowerbyi. U.S. Geology Survey, Nonindigenous Aquatic Species Database, Gainsville, FL, and NOAA Great Lakes Aquatic Nonindigenous Species Informaton System, Ann Arbor, MI. September 12, 2019. Accessed August 29, 2022 at https://nas.er.usgs.gov/queries/greatlakes/FactSheet.aspx?Species_ID=1151. Limestone County. 2021a. About Limestone County. Accessed September 2, 2021 at https://limestonecounty-al.gov/about/. Limestone County. 2021b. Cowford Campground. Accessed September 2, 2021 at https://limestonecounty-al.gov/departments/parks-and-recreation/cowford-campground/. Limestone County. 2021c. Parks and Recreation. Accessed September 2, 2021 at https://limestonecounty-al.gov/departments/parks-and-recreation/. Limestone County Schools. 2022. Limestone County School District. Accessed September 21, 2022 at https://www.lcsk12.org/. Mack John J. 2001. Ohio Rapid Assessment Method for Wetlands v. 5.0, User's Manual and Scoring Forms. Ohio EPA Technical Report WET/2001-1. Ohio Environmental Protection Agency, Division of Surface Water, 401/Wetland Ecology Unit. Columbus, Ohio. February 1, 2001. Madison County Schools. 2022. Madison County School District. Accessed September 21, 2022 at https://www.mcssk12.org/Page/http%3A%2F%2Fwww.mcssk12.org%2Fsite%2Fdefault. aspx%3FPageID%3D751. Marion County Board of Education. 2022. Marion County School District. Accessed September 21, 2022 at https://www.mcbe.net. Marshall. 2013. A Phase I Archaeological Survey for the Trinity-Browns Ferry Nuclear Plant 161-kV Transmission Linen Project, Limestone and Morgan Counties, Alabama. Prepared by Tennessee Valley Archaeological Research, Huntsville, Alabama. Prepared for Tennessee Valley Authority, Knoxville, Tennessee. Classified report, not publicly available. Marshall County Schools. 2022. Marshall County Schools. Accessed September 21, 2022 at https://www.marshallk12.org/. Martin M. 2013. A Vision for Athens: A Future Land Use and Development Plan. December 2013. Morgan County Alabama. 2021a. About Morgan County. Accessed September 14, 2021 at http://co.morgan.al.us/aboutus.html. Morgan County Alabama. 2021b. Morgan County Incorporated and Unincorporated Areas Map. Morgan County Schools. 2022. Morgan County School District. Accessed September 21, 2022 at Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-98

Appendix E - Applicants Environmental Report-Operating License Renewal Stage https://www.morgank12.org/domain/http%3A%2F%2Fwww.morgank12.org%2Fsite%2F default.aspx%3FDomainID%3D2229. National Geographic. 2002. Field Guide to the Birds of North America (Fourth Edition). Washington D.C.: National Geographic Society, 480pp. NatureServe Explorer. 2022. Species-specific search results for spring pygmy sunfish, slackwater darter, Tuscumbia darter, paddlefish, osprey, and monarch butterfly. Accessed at https://explorer.natureserve.org/Search. NLCD (National Land Cover Database). 2019. Multi-Resolution Land Characteristics Consortium Data. Accessed September 16, 2022 at https://www.mrlc.gov/data?f%5B0%5D=category%3ALand%20Cover. NOAA (National Oceanic and Atmospheric Administration). 2023a. CONUS Climate Divisions. Accessed February 15, 2023 at https://www.ncei.noaa.gov/access/monitoring/reference-maps/conus-climate-divisions. NOAA. 2023b. Summary of Monthly Normals 1991-2020. Accessed February 16, 2023 at https://www.ncei.noaa.gov/access/services/data/v1?dataset=normals-monthly-1991-2020&stations=USW00053852&format=pdf&dataTypes=MLY-TMAX-NORMAL,MLY-TMIN-NORMAL,MLY-TAVG-NORMAL,MLY-PRCP-NORMAL,MLY-SNOW-NORMAL. NOAA. 2023c. Tornadoes in Limestone County Alabama. Accessed February 6, 2023 at https://w2.weather.gov/hun/limestonetor#:~:text=Tornatoes%20in%20Limestone%20Co unty%20Alabama%20%20%20,%20%20450%20%207%20more%20rows%20. NOAA. 2023d. U.S. Climate Data Online. Daily Records 1991-2020. Accessed February 16, 2023 at https://www.ncei.noaa.gov/cdo-web/. NOAA. 2023e. U.S. Climate Normals Quick Access. Accessed February 15, 2023 at https://www.ncei.noaa.gov/access/us-climate-normals/#dataset=normals-monthly&timeframe=30&location=AL&station=USW00053852. NOAA. 2023f. U.S. Climate Normals. Daily Normals 1991-2020. Accessed February 16, 2023 at https://www.ncei.noaa.gov/cdo-web/. NOAA Fisheries (National Oceanic and Atmospheric Administration). 2022. Essential Fish Habitat Mapper. Accessed September 6, 2022 at https://efhtools.github.io/InlandEFH/Mapper.html. NPS (National Parks Service). 1993. Permit Application Guidance for New Air Pollution Sources. Natural Resources Report NPS/NRAQD/NRR-93/09. March 1996. NPS. 2021. Mandatory Class I Areas Map. Accessed September 22, 2021 at https://www.nps.gov/subjects/air/upload/Class_I_Areas_NPS_web_small.png. NRC (Nuclear Regulatory Commission). 2013. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG-1437, Volume 1, Revision 1. Office of Nuclear Reactor Regulation. June 2013. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-99

Appendix E - Applicants Environmental Report-Operating License Renewal Stage NRC. 2022. Occupational Radiation Exposure at Commercial Nuclear Power Reactors and Other Facilities 2020. Fifty-Third Annual Report, NUREG-0713. Volume 42. September 2022. NRC. 2023. Event Notification Report for March 3, 2023. Accessed April 27, 2023 at https://www.nrc.gov/reading-rm/doc-collections/event-status/event/2023/20230303en.html. NRCS (Natural Resources Conservation Service). 2023. Custom Soil Resource Report for Limestone County, Alabama. Accessed October 2, 2023 at https://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx. NWS (National Weather Service). 2011. Historic Outbreak of April 27, 2011. Accessed February 8, 2023 at https://www.weather.gov/bmx/event_04272011. Outdoor Alabama. 2021. Wheeler Reservoir. Accessed September 21, 2021 at https://www.outdooralabama.com/reservoirs/wheeler-reservoir. Outdoor Alabama. 2022. Tricolored bat found in Alabama caves proposed for endangered species list. September 14, 2022. Accessed October 7, 2022 at https://www.outdooralabama.com/bats/tri-colored-bat. Powell R., Conant R. and Collins J. T. 2016. Peterson Field Guide to Reptiles and Amphibians of Eastern and Central North America (Fourth Edition). Boston, Massachusetts: Houghton Mifflin Harcourt, 494pp. Pruitt L. and TeWinkel L. 2007. Indiana Bat (Myotis sodalis) Draft Recovery Plan: First Revision. U.S. Fish and Wildlife Service. Fort Snelling, MN. April 2007. Reynolds Mike. 2022. Historic Architectural Resources Survey of the Browns Ferry Nuclear Plant Project, Limestone County, Alabama. Prepared by Brockington and Associates, Inc., Atlanta, Georgia. Prepared for Tennessee Valley Authority, Knoxville, Tennessee. Classified report, not publicly available. Runkle J., K.E. Kunkel, L.E. Stevens, R. Frankson and Rayne Sandra. 2022. Alabama State Climate Summary 2022. NOAA Technical Report NESDIS 150-AL. NOAA/NESDIS, Silver Spring, MD. Accessed May 16, 2023 at https://statesummaries.ncics.org/chapter/al/. Sharkey J.K. and Springston G.L. 2022. Water Use in the Tennessee Valley for 2020 and Projected Use in 2045. Tennessee Valley Authority. River & Resources Stewardship. August 2022. Siebenthaler Donna J. 2020. Limestone County. Encyclopedia of Alabama. Last Updated: November 24, 2020. Accessed September 2, 2021 at http://www.encyclopediaofalabama.org/article/h-1289. Simmons J.W. 2019. Recent Advances in the Understanding of the Distribution and Status of the Snail Darter (Percina tanasi). April 2019. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-100

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Smietana Bob. 2012. Tenn. Amish Communitys Growth Follows National Trend. USA Today. Accessed September 19, 2022 at https://www.usatoday.com/story/news/nation/2012/10/10/tennessee-amish-growth/1625695/. Smithsonian Environmental Research Center. 2022a. Cyprinus carpio. Accessed August 30, 2022 at https://invasions.si.edu/nemesis/chesreport/species_summary/Cyprinus%20carpio. Smithsonian Environmental Research Center. 2022b. Menidia audens. Accessed September 16, 2022 at https://invasions.si.edu/nemesis/species_summary/165993. Stanton Jessica C. 2013. Phase I Archaeological Survey of Tennessee Valley Authoritys Browns Ferry-Athens 161-KV TL Rebuild and Associated Access Roads in Limestone County, Alabama. Prepared by Tennessee Valley Archaeological Research, Huntsville, Alabama. Prepared for Tennessee Valley Authority, Knoxville, Tennessee. Classified report, not publicly available. State of Alabama. 2018. Alabama State Hazard Mitigation Plan. July 18, 2018. State of Tennessee. 2022. Tennessee Valley Authoritys Payments in Lieu of Taxes: Annual Report to the Tennessee General Assembly. January. Strauss B., C. Tebaldi, S. Kulp, S. Cutter, C. Emrich, D. Rizza and Yawitz D. 2015. Alabama and the Surging Sea: A vulnerability assessment with projections for sea level rise and coastal flood risk. August 2015. Tennessee Department of Education. 2020. TN School Districts Report Card Data FY 2020. Accessed October 27, 2022 at https://www.tn.gov/education/data/data-downloads.html. Texas Invasive Species Institute. 2014. Redbreast Sunfish. Accessed August 30, 2022 at http://www.tsusinvasives.org/home/database/lepomis-auritus. Texas A&M University. 2023. Hybrid Striped Bass (Morone hybrid). Accessed October 2, 2023 at https://fisheries.tamu.edu/pond-management/species/hybrid-striped-bass/ The Raptor Adventure. 2021. The RAPTOR Aerial Adventures. Accessed September 9, 2021 at https://theraptoraerialadventures.com. Tuttle M. D. 1976a. Population ecology of the gray bat (Myotis grisescens): philopatry, timing, and patterns of movement, weight loss during migration, and seasonal adaptive strategies: University of Kansas, 1-38pp. Tuttle M.D. 1976b. Population ecology of the gray bat (Myotis grisescens): factors influencing growth and survival of newly volant young. Ecology. 57: 587-595. TVA (Tennessee Valley Authority). 1993. NFERC Regional Groundwater Investigation. Report No. WR28-1-520-191, Norris, Tennessee. Julian, H. E., S. C. Young, C. Lu, and K. E. Richter, TVA Engineering Laboratory. April 1993. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-101

Appendix E - Applicants Environmental Report-Operating License Renewal Stage TVA. 2004. Reservoir Operations Study. Final Programmatic Environmental Impact Statement and Record of Decision. May. TVA. 2006. Browns Ferry Nuclear Plant Investigation of Tritium Releases to Groundwater. June 2006. TVA. 2014. Seismic Hazard and Screening Report for Tennessee Valley Authoritys Browns Ferry Nuclear Plant: Enclosure 2, Chattanooga, Tennessee. March 2014. TVA. 2017. Wheeler Reservoir Final Reservoir Land Management Plan. Volume VIII. Multiple Reservoir Land Management Plans. Final Environmental Impact Statement. August. TVA. 2018. Ecological Health Ratings: Wheeler Reservoir. Accessed September 15, 2021 at https://www.tva.com/environment/environmental-stewardship/water-quality/reservoir-health-ratings/wheeler-reservoir#:~:text=The%20ecological%20health%20of%20Wheeler,during%20years%20 with%20lower%20flow. TVA. 2020a. Browns Ferry Nuclear Plant Thermal Performance Program Cooling Tower Capacity Improvements Environmental Assessment. June 2020. TVA. 2020b. Clean Water Act Section 316(b) § 122.21(r)(9) Entrainment Characterization Study for the Browns Ferry Nuclear Plant. River and Reservoir Compliance Monitoring Program. TVA. 2021a. Browns Ferry Nuclear Plant Delineation Report. Prepared by Schoel Engineering Company, Inc. September 21, 2021. TVA. 2021b. Clean Water Act Section 316(b) § 122.21(r) Compliance Documentation for the Browns Ferry Nuclear Plant, Limestone County, Alabama. April. TVA. 2021c. Evaluating the Presence and Maintenance of a Balanced Indigenous Population of Fish and Wildlife in the Tennessee River Downstream of TVAs Browns Ferry Nuclear Plant. June. TVA. 2021d. Navigation on the Tennessee River. Accessed September 20, 2021 at https://www.tva.com/Environment/Managing-the-River/Navigation-on-the-Tennessee-River. TVA. 2021e. Understanding the Drawdown. Accessed September 16, 2022 at https://www.tva.com/environment/managing-the-river/flood-management/understanding-the-drawdown. TVA. 2021f. Wheeler Dam Facts and Figures. Accessed September 19, 2021 at https://www.tva.com/energy/our-power-system/hydroelectric/wheeler. TVA. 2022a. Browns Ferry Nuclear Plant 2021 Annual Radioactive Effluent Release Report. May 2, 2022. TVA. 2022b. TVA Regional National Heritage Database. February 2022. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-102

Appendix E - Applicants Environmental Report-Operating License Renewal Stage TVA. 2022c. A Guide for Environmental Protection and Best Management Practices for TVA Construction and Maintenance Activities. Revision 4. TVA. 2023. 2022 Annual Radiological Environmental Operating Report. Tennessee Valley Authority Browns Ferry. May 15, 2023. USACE (U.S. Army Corps of Engineers). 2012. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Eastern Mountains and Piedmont Region (Version 2.0). ed. J. F. Berkowitz, J. S. Wakeley, R. W.Lichvar, C. V. Noble. ERDC/EL TR-12-9. U.S. Army Engineer Research and Development Center. Vicksburg, MS. April 2012. USCB (U.S. Census Bureau). 2000a. Alabama: 2000. Summary Population and Housing Characteristics. 2000 Census of Population and Housing. June. USCB. 2000b. Total Population. Accessed September 22, 2021 at https://data.census.gov/cedsci/table?q=P001&g=0100000US_0400000US01_0500000U S01033,01077,01079,01083,01089,01103_1600000US0137000&y=2000&tid=DECENNI ALSF12000.P001&tp=true. USCB. 2010. 2010 Total Population. Table P1. Accessed September 22, 2021 at https://data.census.gov/table?text=population&g=010XX00US_040XX00US01,47_050X X00US01033,01077,01083,47001,47093,47105,47129,47145_160XX00US4755120&y= 2010&d=DEC+Summary+File+1&tid=DECENNIALSF12010.P1&tp=true. USCB. 2012. Alabama: 2010. Summary Population and Housing Characteristics. 2010 Census of Population and Housing. December 2012. USCB. 2017. Projected Population Size and Births, Deaths, and Migration: Main Projections Series for the United States, 2017-2060. U.S. Census Bureau, Population Division: Washington, DC. Accessed September 29, 2023 at https://www.census.gov/data/tables/2017/demo/popproj/2017-summary-tables.html. USCB. 2020a. Alabama Table P2 Hispanic or Latino, and Not Hispanic or Latino By Race - Block Groups. Accessed October 27, 2022 at https://data.census.gov/cedsci/table?q=United%20States&g=0100000US_0500000US0 1009%241500000,01033%241500000,01043%241500000,01059%241500000,01071% 241500000,01077%241500000,01079%241500000,01083%241500000,01089%241500 000,01093%241500000,01095%241500000,01103%241500000,01127%241500000,01 133%241500000&y=2020&d=DEC%20Redistricting%20Data%20%28PL%2094-171%29&tid=DECENNIALPL2020.P2. USCB. 2020b. B17021 Poverty Status Of Individuals In The Past 12 Months By Living Arrangement - Alabama. 2016-2020 American Community Survey. Accessed October 27, 2022 at https://data.census.gov/cedsci/table?q=B17021%3A%20POVERTY%20STATUS%20OF

     %20INDIVIDUALS%20IN%20THE%20PAST%2012%20MONTHS%20BY%20LIVING%

20ARRANGEMENT&g=0100000US_0500000US01009%241500000,01033%24150000 0,01043%241500000,01059%241500000,01071%241500000,01077%241500000,0107 9%241500000,01083%241500000,01089%241500000,01093%241500000,01095%241 500000,01103%241500000,01127%241500000&tid=ACSDT5Y2020.B17021. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-103

Appendix E - Applicants Environmental Report-Operating License Renewal Stage USCB. 2020c. B17021 Poverty Status Of Individuals In The Past 12 Months By Living Arrangement - Tennessee. Accessed October 27, 2022 at https://data.census.gov/cedsci/table?q=B17021%3A%20POVERTY%20STATUS%20OF

     %20INDIVIDUALS%20IN%20THE%20PAST%2012%20MONTHS%20BY%20LIVING%

20ARRANGEMENT&g=0100000US_0500000US47051%241500000,47055%24150000 0,47099%241500000,47103%241500000,47117%241500000,47119%241500000,4718 1%241500000. USCB. 2020d. Housing Table H1: Census Bureau Table. Decennial Census. Accessed September 3, 2022 at https://data.census.gov/cedsci/table?q=housing&g=0400000US01_0500000US01033,01 077,01083&tid=DECENNIALPL2020.H1. USCB. 2020e. P2: Hispanic or Latino, and Not Hispanic or Latino by Race. Accessed November 17, 2022 at https://data.census.gov/cedsci/table?t=Populations%20and%20People&g=0100000US_ 0400000US01_0500000US01033,01077,01083_1600000US0102956,0120104,0137000

     &y=2020&d=DEC%20Redistricting%20Data%20%28PL%2094-171%29&tid=DECENNIALPL2020.P2.

USCB. 2020f. Quick Facts Limestone County Alabama. Accessed September 28, 2021 at https://www.census.gov/quickfacts/limestonecountyalabama. USCB. 2020g. S1902: Mean Income In The Past 12 Months (In 2020 Inflation-Adjusted Dollars). Accessed September 3. 2022 at https://data.census.gov/cedsci/table?q=per%20capita%20income&g=0100000US_0400 000US01_0500000US01033,01077,01079,01083,01089,01103&tid=ACSST5Y2020.S19 02&moe=false. USCB. 2020h. Tennessee Table P2 Hispanic or Latino, and Not Hispanic or Latino By Race - Block Groups. Accessed October 27, 2022 at https://data.census.gov/cedsci/table?q=United%20States&g=0100000US_0500000US4 7051%241500000,47055%241500000,47099%241500000,47103%241500000,47117% 241500000,47119%241500000,47181%241500000&y=2020&d=DEC%20Redistricting% 20Data%20%28PL%2094-171%29&tid=DECENNIALPL2020.P2. USCB. 2020i. Alabama Table P1: Decennial Census. Accessed 5/9/2023 at https://data.census.gov/cedsci/table?t=Populations%20and%20People&g=0100000US_ 0400000US01_0500000US01033,01077,01083_1600000US0102956,0120104,0137000

     &y=2020&d=DEC%20Redistricting%20Data%20%28PL%2094-171%29&tid=DECENNIALPL2020.P1.

USCB. 2022. Quick Facts. Lawrence County, Limestone County, and Morgan County Alabama. Accessed November 17, 2022 at https://www.census.gov/quickfacts/fact/table/lawrencecountyalabama,limestonecountyal abama,morgancountyalabama,AL/PST045221. USDA (U.S. Department of Agriculture). 1969. County Summary - 1969 Census of Agriculture. National Agricultural Statistics Service (NASS). Accessed September 19, 2021 at https://www.census.gov/geographies/mapping-files/time-series/geo/tiger-line-file.html. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-104

Appendix E - Applicants Environmental Report-Operating License Renewal Stage USDA. 1974. Number, Land, and Value of Farms: 1974 and 1969. National Agricultural Statistics Service (NASS). Accessed September 19, 2021 at http://lib-usda-05.serverfarm.cornell.edu/usda/AgCensusImages/1974/01/01/306/Table-01.pdf. USDA. 2017a. 2017 Census of Agriculture County Profile Lawrence County Alabama. National Agricultural Statistics Service (NASS). Accessed September 19, 2021 at https://www.nass.usda.gov/Publications/AgCensus/2017/Online_Resources/County_Pro files/Alabama/cp01079.pdf. USDA. 2017b. 2017 Census of Agriculture County Profile Limestone County Alabama. National Agricultural Statistics Service (NASS). Accessed September 19, 2021 at https://www.nass.usda.gov/Publications/AgCensus/2017/Online_Resources/County_Pro files/Alabama/cp01083.pdf. USDA. 2017c. 2017 Census of Agriculture County Profile Morgan County Alabama. National Agricultural Statistics Service (NASS). Accessed September 19, 2021 at https://www.nass.usda.gov/Publications/AgCensus/2017/Online_Resources/County_Pro files/Alabama/cp01103.pdf. USDA. 2017d. Table 7. Hired Farm Labor - Workers and Payroll: 2017 - Alabama. 2017 Census of Agriculture - County Data. Accessed February 7, 2023 at https://www.nass.usda.gov/Publications/AgCensus/2017/Full_Report/Volume_1,_Chapte r_2_County_Level/Alabama/st01_2_0007_0007.pdf. USDA. 2017e. Table 7. Hired Farm Labor - Workers and Payroll: 2017 - Tennessee. 2017 Census of Agriculture - County Data. Accessed February 7, 2023 at https://www.nass.usda.gov/Publications/AgCensus/2017/Full_Report/Volume_1,_Chapte r_2_County_Level/Tennessee/st47_2_0007_0007.pdf. USDA. 2023. Grass Carp - National Invasive Species Information Center. Accessed October 2, 2023 at https://www.invasivespeciesinfo.gov/aquatic/fish-and-other-vertebrates/grass-carp. USEPA (U.S. Environmental Protection Agency). 1974. Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety. March. USEPA. 1990. New Source Review Workshop Manual. Prevention of Significant Deterioration and Nonattainment Area Permitting. October 1990. USEPA. 1994. Memorandum for The Radionuclide National Emission Standard for Hazardous Air Pollutants (NESHAP) and the Title V Operating Permits Program. Office of Air Quality Planning and Standards and Office of Radiation and Indoor Air. September 20, 1994. USEPA. 2009. Final Rule for Reporting of Greenhouse Gases. Accessed November 8, 2023 at https://www.epa.gov/regulations-emissions-vehicles-and-engines/final-rule-mandatory-reporting-greenhouse-gases. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-105

Appendix E - Applicants Environmental Report-Operating License Renewal Stage USEPA. 2010. Final Rule for the Prevention of Significant Deterioration and Title V GHG Tailoring Rule. 75 Federal Register 31514. June 3, 2010. Accessed November 8, 2023 at https://www.govinfo.gov/content/pkg/FR-2010-06-03/pdf/2010-11974.pdf. USEPA. 2011. PSD and Title V Permitting Guidance for Greenhouse Gases. Office of Air Quality Planning and Standards. March 2011. USEPA. 2012. Final Rule for the Prevention of Significant Deterioration and Title V GHG Tailoring Rule Step 3 and GHG Plantwide Applicability Limits. 77 Federal Register 41051. July 12, 2012. Accessed November 8, 2023 at https://www.govinfo.gov/content/pkg/FR-2012-07-12/pdf/2012-16704.pdf. USEPA. 2020. Alabama NPDES Permits. Accessed September 20, 2021 at https://www.epa.gov/npdes-permits/alabama-npdes-permits. USEPA. 2021. Basic Information on Mercury. Last Updated September 24, 2021. Accessed September 16, 2021 at https://www.epa.gov/mercury/basic-information-about-mercury. USEPA. 2023. Understanding Global Warming Potentials. Accessed May 16, 2023 at https://www.epa.gov/ghgemissions/understanding-global-warming-potentials. USFWS (U.S. Fish and Wildlife Service). 2007. National Bald Eagle Management Guidelines. May. USFWS. 2014. Northern Long-eared Bat Interim Conference and Planning Guidance. USFWS Regions 2, 3, 4, 5, & 6. January 6, 2014. USFWS. 2017. Wheeler National Wildlife Refuge. September. Accessed September 19, 2021 at https://www.fws.gov/southeast/pdf/brochure/wheeler-national-wildlife-refuge.pdf. USFWS. 2020. Wheeler National Wildlife Refuge Tear Map. Accessed September 28, 2021 at https://www.fws.gov/sites/default/files/documents/Wheeler%20Map%20Digital%20File% 20-%202021.11.08.pdf. USFWS. 2022a. Information for Planning and Consultation (IPaC). Accessed October 27, 2022 at https://ipac.ecosphere.fws.gov/. USFWS. 2022b. Post-Delisting Monitoring Plan for Snail Darter (Percina tanasi). Tennessee Ecological Services Field Office. Cookeville, Tennessee. October 2022. USFWS. 2023. Rockfish (Morone saxatilis). Accessed October 2, 2023 at https://www.fws.gov/species/rockfish-morone-saxatilis. USGCRP (U.S. Global Change Research Program). 2018. Impacts, Risks, and Adaptation in the United States: Fourth National Climate Assessment. Volume II. [Reidmiller, D.R., C.W. Avery, D.R. Easterling, K.E. Kunkel, K.L.M. Lewis, T.K. Maycock, and B.C. Stewart (eds.)]. Washington, DC. June 2019. USGS (U.S. Geological Survey). 1987. Geohydrology and Susceptibility of Major Aquifers to Surface Contamination in Alabama Area I. Water-Resources Investigations Report 87-4068. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-106

Appendix E - Applicants Environmental Report-Operating License Renewal Stage USGS. 2000. A Tapestry of Time and Terrain. Geologic Investigation Series 2720. Pamphlet to accompany Geologic Investigations Series I-2720. February 2000. USGS. 2017. Low-Flow Frequency and Flow-Duration Characteristics of Selected Streams In Alabama through March 2014. Scientific Investigation Report 2017-5083. Accessed September 16, 2017 at https://pubs.er.usgs.gov/publication/sir20175083. USGS. 2022. Asian clam (Corbicula fluminea) - Species Profile. Accessed September 16, 2022 at https://nas.er.usgs.gov/queries/factsheet.aspx?speciesid=92. USGS. 2023a. BFN Earthquakes 1974 to present_30 and 100 miles. Accessed February 8, 2023 at https://earthquake.usgs.gov/earthquakes/map/?extent=32.96259,269.91211&extent=35. 94688,275.91614&range=search&timeZone=utc&search=%7B%22name%22:%22Searc h%20Results%22,%22params%22:%7B%22starttime%22:%221974 01%2000:00:00%22,%22endtime%22:%222023 08%2023:59:59%22,%22latitude%22:34.70389,%22longitude%22:- 87.11861,%22maxradiuskm%22:161,%22minmagnitude%22:2.5,%22eventtype%22:%2 2earthquake%22,%22orderby%22:%22time%22%7D%7D. USGS. 2023b. BFN Earthquakes 1974 to present_3.2 mile radius. Accessed November 9, 2023 at https://earthquake.usgs.gov/earthquakes/map/?extent=-88.93202,- 247.5&extent=88.91883,607.5&range=search&timeZone=utc&search=%7B%22name% 22:%22Search%20Results%22,%22params%22:%7B%22starttime%22:%221974 01%2000:00:00%22,%22endtime%22:%222023-11-09%2023:. Walker County School. 2022. Walker County School District. Accessed September 21, 2022 at https://www.walkercountyschools.com/domain/http%3A%2F%2Fwww.walkercountyscho ols.com%2Fsite%2Fdefault.aspx%3FDomainID%3D48. Whitaker J. O. 1996. Field Guide to North American Mammals. National Audubon Society, New York: Alfred A. Knopf, Inc., 937pp. Winston County Schools. 2022. Winston County School District. Accessed September 21, 2022 at https://www.winstonk12.org/. Wofford L.A. 2020. TVA-Browns Ferry Nuclear Plant - Proposed cooling tower demo - Section 106. Communication to S. C. Cole and A. McBride, March 6, 2020. Yoder C.O., B.J. Armitage and Rankin E.T. 2006. Re-evaluation of the Technical Justification for Existing Ohio River Mainstem Temperature Criteria. Midwest Biodiversity Institute. Columbus, Ohio. Young Center for Anabaptist and Pietist Studies Elizabethtown College. 2022. Amish Population in the United States by State, County, and Settlement, 2022. Accessed September 19, 2022 at https://groups.etown.edu/amishstudies/files/2022/07/Amish-Pop-2022_by_state_and_county.pdf. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E3-107

Appendix E - Applicants Environmental Report-Operating License Renewal Stage CHAPTER 4 - ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED ACTION AND MITIGATING ACTIONS Chapter 4 presents an assessment of the environmental consequences and potential mitigating actions associated with the subsequent license renewal (SLR) of the existing Browns Ferry Nuclear Plant (BFN) Renewed Facility Operating Licenses (RFOLs). In the 2013 Generic Environmental Impact Statement (GEIS), the Nuclear Regulatory Commission (NRC) considered Category 1 issues to be those that had been found to result in essentially the same (generic) impact at all nuclear plants (or for some issues, those plants having a specific type of cooling system or other characteristics in common) (NRC 2013). In the 2013 GEIS, Category 1 issues did not need to be re-evaluated in plant-specific environmental reviews absent new and significant information (N&SI) indicating the potential for a change in the level of impact relative to that in the GEIS. Category 2 issues were identified as those that could have different levels of impact depending upon the characteristics of each plant. Therefore, Category 2 issues were required to have a plant-specific analysis for impact determinations as part of their environmental review for license renewal (NRC 2013). As described in Section 1.2 of this Environmental Report (ER), in February 2022, the U.S. Nuclear Regulatory Commission (NRC) ruled that the 2013 Generic Environmental Impact Statement (GEIS; NUREG-1437, Rev. 1) was not sufficient for SLR applications (NRC 2013). The NRC initiated a rulemaking to amend Table B-1 of Appendix B, Summary of Findings on NEPA [National Environmental Policy Act] Issues for License Renewal of Nuclear Power Plant, to Subpart A, National Environmental Policy Act - Regulations Implementing Section 102(2), of Part 51 of Title 10 of the Code of Federal Regulations (10 CFR), Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions. The 2013 GEIS provides the technical and regulatory basis for Table B-1. Consequently, the 2013 GEIS will also be updated. The NRC held that the 2013 license renewal GEIS was only acceptable to address the impacts of initial 20-year license renewal periods and that the Table B-1 Category 1 conclusions could not be credited in an SLR application. Because the NRC is reviewing and amending the GEIS with respect to subsequent periods of extended operation, the GEIS Category 1 findings can no longer be applied generically and this ER evaluates each Category 1 issue based on the specific characteristics of BFN, as is done for GEIS Category 2 issues. Until the new NRC rulemaking is complete, the 2013 GEIS, Regulatory Guide 4.2, NUREG-1437, and NUREG-1555 provide a general framework for the analysis presented within this ER, defining the number and scope of environmental impact issues that need to be addressed. Therefore, this ER presents a site-specific evaluation for all 78 Category 1 and 2 issues, and one uncategorized issue, defined in the 2013 GEIS. The sections in Chapter 4 identify the specific GEIS issues that apply to BFN for each environmental resource area, and the existence of N&SI for each is addressed. Except for historic and cultural resources and special status species, The Tennessee Valley Authority (TVA) has identified the significance of the impacts associated with each issue as SMALL, MODERATE, or LARGE, consistent with the NRC criteria found in 10 CFR Part 51, Subpart A, Appendix B, Table B-1, footnote 3: SMALL - Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource. For the purposes of assessing radiological impacts, the Commission has concluded that those impacts Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-1

Appendix E - Applicants Environmental Report-Operating License Renewal Stage that do not exceed permissible levels in the Commissions regulations are considered small. MODERATE - Environmental effects are sufficient to alter noticeably, but not to destabilize, important attributes of the resource. LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource. Consistent with the NRC guidance provided in 10 CFR Part 51, Appendix B to Subpart A, TVA has adopted the impact determinations described below for historic and cultural resources. For federally protected species, TVA has used effects determinations developed in accordance with the Endangered Species Act (ESA) Section 7 guidance in assessing the significance of impacts, as discussed below. The National Historic Preservation Act (NHPA) requires the NRC to consider the effects on historic properties in the vicinity of the project site and provide a reasonable opportunity for the Advisory Council on Historic Preservation to comment. If continued operation, including refurbishment, could result in adverse effects on a historic property, then the NRC must consult with the State Historic Preservation Officer (SHPO) to assess mitigation. Thus, regarding historic or cultural resources, the significance of effects from the SLR, and the need for mitigation can be characterized based on a determination that (1) no historic properties are present (no effect); (2) historic properties are present, but not adversely affected (no adverse effect); or (3) historic properties are adversely affected (adverse effect) (78 Federal Register [FR] 37281-37324; June 20, 2013). TVA has used these determinations in its conclusion of SLR impacts to historic and cultural resources. In complying with the ESA, the NRC must consult with the U.S. Fish and Wildlife Service (USFWS) and/or National Oceanic and Atmospheric Administrations (NOAA) National Marine Fisheries Service (NOAA Fisheries) if the effects of authorizing continued nuclear power plant operations, including refurbishment, would affect any federal listed species or designated critical habitat for a listed species under their respective jurisdictions. Thus, regarding species protected under the ESA, the significance of the effects from the subsequent period of extended operation (and the need for NRC consultation with USFWS and/or NOAA Fisheries) can be characterized based on a determination of whether and to what degree continued nuclear power plant operations, including refurbishment, could affect a listed species. In accordance with the ESA, the NRC determines effects on federal listed species based on the following effects categories: (1) NO EFFECT; (2) may affect but NOT LIKELY TO ADVERSELY AFFECT; (3) LIKELY TO ADVERSELY AFFECT; or (4), for listed species that are likely to be adversely affected, LIKELY (or NOT LIKELY) TO JEOPARDIZE THE CONTINUED EXISTENCE of the affected species or adversely modify designated critical habitat (78 FR 37281-37324; June 20, 2013). For species proposed for listing, the determination is whether effects are LIKELY TO JEOPARDIZE the proposed species (USFWS and NMFS 1998). TVA has used these determinations in its conclusions regarding the effects of SLR on species that are federally listed or proposed for listing as threatened or endangered species, and on designated critical habitats. In complying with the Magnuson-Stevens Fishery Conservation and Management Act (MSA), the NRC must consult with NOAA Fisheries if the effects of authorizing continued nuclear power plant operations, including refurbishment, would adversely affect any essential fish habitat (EFH) identified under the MSA for federally managed fish populations. In accordance with the MSA, the NRC characterizes the significance of effects on EFH from SLR based on a Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-2

Appendix E - Applicants Environmental Report-Operating License Renewal Stage determination of whether continued nuclear power plant operations, including refurbishment, would have (1) no adverse impact, (2) minimal adverse impact, or (3) substantial adverse impact on EFH (78 FR 37281 - 37324; June 20, 2013). TVA has determined that EFH for federally managed fish populations is not present in the vicinity of BFN. In accordance with footnote 6 to Table B-1 in 10 CFR Part 51, Subpart A, Appendix B, the issue of chronic effects of electromagnetic fields (EMFs), which the 2013 GEIS left uncategorized, is described without analysis in Section 4.9. 4.1. Land Use and Visual Resources Table 4.1-1 lists the land use and visual resources issues identified in the GEIS and the GEIS findings. Each of these issues was reviewed with respect to impacts associated with the BFN SLR. Table 4.1-1. Land Use and Visual Resource Issues and the NRC 2013 GEIS Findings Issue GEIS Finding SLR-ER Section Onsite land use SMALL (Category 1). Changes in onsite land use from 3.1.2; continued operations and refurbishment associated with 4.1.1 license renewal would be a small fraction of the nuclear power plant site and would involve only land that is controlled by the licensee. Offsite land use SMALL (Category 1). Offsite land use would not be affected 3.1.1; by continued operations and refurbishment associated with 4.1.2 license renewal. Offsite land use in SMALL (Category 1). Use of transmission line ROWs from 2.2.6; transmission line continued operations and refurbishment associated with 4.1.3 rights of way license renewal would continue with no change in land use (ROWs) restrictions. Aesthetic impacts SMALL (Category 1). No important changes to the visual 3.1.3; appearance of plant structures or transmission lines are 4.1.4 expected from continued operations and refurbishment associated with license renewal. Source: (NRC 2013) 4.1.1. Onsite Land Use Section 3.1.2 of this ER describes existing onsite land use at BFN. Onsite land use currently constitutes the BFN generation facility (including various buildings, structures, parking areas, etc.) and undeveloped areas. Onsite land use changes are not anticipated at present during the subsequent period of extended operation. Ongoing and routine maintenance activities are not expected to require development of new areas of the BFN site. As is explained in Section 2.2.6, there are three 500-kilovolt (kV) and two 161-kV transmission lines that are considered in-scope transmission lines onsite at BFN, but only routine maintenance activities within existing rights-of-way (ROWs) and active plant areas are anticipated during the subsequent period of extended operation. This work will be managed under guidelines developed by TVA in consultation with the USFWS. TVA has no plans for modifications or refurbishment activities beyond of normal maintenance associated with the SLR for BFN. As described in Section 2.2.4.4, the current independent spent fuel storage installation (ISFSI) storage pads are projected to be filled on or before year 2036. The addition of a third ISFSI storage pad to further increase storage capacity needed at BFN for the subsequent period of Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-3

Appendix E - Applicants Environmental Report-Operating License Renewal Stage extended operation is under consideration, but plans are in the conceptual stage and no installation schedule has been established. The BFN site has adequate space onsite to accommodate the construction of an additional ISFSI pad if necessary. The impacts associated with this expansion will also be assessed under a licensing process separate from that of BFN Units 1, 2, and 3 RFOLs. No N&SI has been identified in relation to onsite land use at BFN; therefore, because there are no changes anticipated for onsite land use during the subsequent period of extended operation and no N&SI has been identified, TVA concludes that onsite land use impacts are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.1-1). 4.1.2. Offsite Land Use Section 3.1.1 describes existing offsite land use in the three counties immediately surrounding BFN. While the number of operational staff and outage and non-outage workers onsite at BFN may occasionally fluctuate based on ongoing operations and maintenance activities, there have been no substantial changes during the current period of extended operation. As described in Section 2.5, the number of workers currently present throughout the subsequent period of extended operation are and anticipated to remain consistent. Additionally, as described in Section 3.8.1.1, no significant changes to payments in lieu of taxes are anticipated during the subsequent period of extended operation. The Alabama Coastal Area Management Program as part of the Coastal Zone Management Program (CZMP) enforces policies on coastal lands and waters in the continuous 10-foot contour seaward in Baldwin and Mobile counties (ADEM 2023). BFN and the three immediate surrounding counties are not located in or near a coastal zone under the Alabama CZMP. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, corresponding offsite impacts are also not anticipated. Finally, no N&SI has been identified in relation to offsite land use at BFN; therefore, TVA concludes that offsite land use impacts are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.1-1). 4.1.3. Offsite Land Use in Transmission ROWs As described in Section 2.2.6, all in-scope transmission lines are located onsite at BFN. No offsite transmission lines will be affected by SLR at BFN. TVA may conduct routine maintenance activities in offsite transmission ROWs during the subsequent period of extended operation. This work will be managed under guidelines developed by TVA in consultation with the USFWS. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. No N&SI was identified; therefore, TVA concludes this issue is not relevant to SLR at BFN. 4.1.4. Aesthetic Impacts Section 3.1.3 of this ER describes the existing aesthetics at BFN. BFN contrasts as an industrial feature in a rural setting and is not a dominant feature due to its distance from residences and the wooded areas that surround the plant. BFN is most visible from the west at water level and across Wheeler Reservoir. The most visible structures at BFN consist of the reactor building, cooling towers, and the off-gas stack. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified with relation to aesthetics at BFN. Therefore, TVA concludes that aesthetic impacts associated with SLR at BFN are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.1-1). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-4

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.2. Air Quality Table 4.2-1 lists the air quality issues identified in the GEIS and the GEIS findings. Each of these issues was reviewed with respect to impacts associated with the BFN SLR. Table 4.2-1. Air Quality Issues and the NRC 2013 GEIS Findings SLR-ER Issues GEIS Finding Section Air quality impacts SMALL (Category 1). Air quality impacts from continued 3.2.2; (all plants) operations and refurbishment associated with license renewal are 4.2.1 expected to be small at all plants. Emissions resulting from refurbishment activities at locations in or near air quality nonattainment or maintenance areas would be short-lived and would cease after these refurbishment activities are completed. Operating experience has shown that the scale of refurbishment activities has not resulted in exceedance of the de minimis thresholds for criteria pollutants, and best management practices including fugitive dust controls and the imposition of permit conditions in state and local air emissions permits would ensure conformance with applicable State or Tribal Implementation Plans. Emissions from emergency diesel generators and fire pumps and routine operations of boilers used for space heating would not be a concern, even for plants located in or adjacent to nonattainment areas. Impacts from cooling tower particulate emissions even under the worst-case situations have been small. Air quality effects SMALL (Category 1). Production of ozone and oxides of nitrogen 3.2.2; of transmission is insignificant and does not contribute measurably to ambient 4.2.2 lines levels of these gases. Source: (NRC 2013) 4.2.1. Air Quality Impacts (All Plants) Section 3.2.2 of this ER describes the existing onsite air quality at BFN. Effects on air quality can be assessed based on estimated long-term emissions associated with the proposed action. Since Limestone County, where BFN is located, is in attainment for all criteria pollutants and has no designated maintenance areas, the Clean Air Act (CAA) general conformity rule does not apply. In the general conformity rule applicable to nonattainment areas, the U.S. Environmental Protection Agency (USEPA) uses the major stationary source definition under the New Source Review program (100 tons per year or more of any air pollutant subject to regulations under the CAA) as the de minimis levels to separate presumably exempt actions from those requiring a positive conformity determination. For purposes of this ER, the 100 tons per year annual threshold was considered as an indicator to trigger further evaluation of potential air quality impacts. This threshold provides indication or a warning that the proposed action is approaching the level with potential significant impacts to air quality. Based on the most recent 12-month rolling annual emissions at BFN as presented in Table 4.2-2, no exceedances of the de minimis threshold for any criteria pollutant or the major source hazardous air pollutants (HAPs) threshold were recorded. Cooling tower particulate emissions in the air via steam drift cannot be reasonably quantifiable as those sources identified in Table 4.2-2 and are considered negligible to have impact to air quality around BFN including the Sipsey Wilderness Class I area located well beyond the 6.2-mile radius warranting a Prevention of Significant Deterioration (PSD) review for a major source. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-5

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Therefore, the subsequent period of extended operation will not result in significant operational air quality impacts. Furthermore, the annual greenhouse gas (GHG) emissions at BFN are below the GHG 25,000 tons per year reporting threshold and are not considered to have potential significant impact on global climate change. Table 4.2-2. BFN Annual Emissions (tons per year) PM GHG Source SO2 NOx VOC CO HAPs (PM10 or PM2.5) (CO2e) Auxiliary Boilers 1.17 0.125 11.7 0.12 2.9 0.042 13,436 Large Diesel 2.22 0.034 71.0 1.82 18.8 0.035 3,628 Generators Small Diesel 0.46 0.207 8.2 0.82 5.4 0.009 529 Generators Paint Shop - - - 26.80 - - - Sandblast Shop 1.46 - - - - - - Total 5.31 0.4 90.9 29.6 27.2 0.086 17,593 PM = particulate matter; PM10 = particulate matter with aerodynamic diameters of 10 microns or less; PM2.5 = particulate matter with aerodynamic diameters of 2.5 microns or less; SO2 = sulfur dioxide; NOx = nitrogen oxide; CO = carbon monoxide; HAPs - hazardous air pollutants; CO2e = carbon dioxide equivalent As described in the 2013 GEIS, the operation of wet cooling towers such as those at BFN results in the emission of salt and other dissolved solids to the air, known as drift emissions (NRC 2013). As this particulate matter settles, it can lead to particulate matter deposited on downwind surfaces (drift deposition) and can contribute to wetting, visibility, icing, and damage to vegetation. The magnitude of the particulate matter emissions depends on a variety of conditions and parameters. BFNs cooling towers are operated in helper mode as needed. Water is not withdrawn from the river for makeup water, and the volume of water returned to the Wheeler Reservoir is only slightly reduced due to evaporation and drift. Drift deposition has not been a documented occurrence at BFN and TVA did not uncover any new information regarding drift with regard to SLR. During the subsequent period of extended operation, BFN will continue to manage all air emissions in compliance with all permit conditions and regulatory requirements. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. No N&SI has been identified in relation to air quality impacts at BFN. TVA will continue to employ best management practices for fugitive dust controls during all maintenance and operational activities. Therefore, TVA concludes that air quality impacts are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.2-1). 4.2.2. Air Quality Effects of Transmission Lines Section 3.2.2 of this ER describes existing onsite air quality at BFN. The ozone and nitrogen oxide emissions associated with BFN high-voltage transmission lines are minimal. Therefore, the potential air quality impacts from in-scope transmission lines operation located at BFN are small. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. No N&SI has been identified in relation to air quality effects of transmission lines at BFN; therefore, TVA concludes that air quality impacts associated with transmission lines are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.2-1). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-6

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.3. Noise Table 4.3-1 lists the noise issue identified in the GEIS and the GEIS findings. This issue was reviewed with respect to impacts associated with the BFN SLR. Table 4.3-1. Noise Issues and the NRC 2013 GEIS Findings SLR-ER Issues GEIS Finding Section Noise impacts SMALL (Category 1). Noise levels would remain below regulatory 3.3; guidelines for offsite receptors during continued operations and 4.3 refurbishment associated with license renewal. Source: (NRC 2013) Section 3.3 of this ER describes existing onsite noise conditions at BFN. The noise-generating equipment at BFN include helper cooling towers, transformers, turbines, auxiliary boilers, emergency generators and pumps. Given that the closest distance from the BFN property boundary to sensitive receptors in the Paradise Shores residential development is approximately 1,500 feet (Ensafe 2012), potential operational noise impacts from the BFN will be small as demonstrated by the ambient noise monitoring test conducted in 2020 and described in in Section 3.3. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Therefore, TVA concludes that noise impacts are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.3-1). 4.4. Geology and Soils Table 4.4-1 lists the geology and soil issue identified in the GEIS and the GEIS findings. This issue was reviewed with respect to impacts associated with the BFN SLR. Table 4.4-1. Geology and Soil Issues and the NRC 2013 GEIS Findings SLR-ER Issue GEIS Finding Section Geology and SMALL (Category 1). The effect of geologic and soil conditions on 3.4; soil plant operations and the impact of continued operations and 4.4 refurbishment activities on geology and soils would be small for all nuclear power plants and would not change appreciably during the license renewal term. Source: (NRC 2013) Section 3.4 of this ER discusses the existing geologic environment at BFN and the surrounding region. During the subsequent period of extended operation, ground-disturbing activities and stormwater runoff could result from routine infrastructure, renovation, and maintenance activities at BFN. The impact on soil resources of continued operations and refurbishment associated with SLR would consist of soil disturbance, including sediment and/or any associated bedrock, for projects, such as replacing or adding buildings, roads, parking lots, and utility structures. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. The need for a geotechnical study will be evaluated if construction of new facilities or other buildings were to become necessary in the future. BFN will continue to comply with National Pollutant Discharge Elimination System (NPDES) permit requirements and Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-7

Appendix E - Applicants Environmental Report-Operating License Renewal Stage employ stabilization measures to minimize erosion and sedimentation resulting from stormwater runoff as appropriate. BFN maintenance activities that could require a construction stormwater permit will obtain the required permit and comply with the stormwater management and best management practices (BMPs) requirements. A stormwater pollution prevention plan (SWPPP) will be prepared prior to initiation of any ground-disturbing activities at the site. The Alabama Department of Environmental Management (ADEM) generic permit for stormwater discharge from large and small construction activities (ALR100000) is a general permit which requires preparation of a SWPPP that identifies BMPs to minimize erosion and sediment resulting from stormwater runoff (Alabama Administrative Code Chapter 335-6-6) (ADEM 2015). BFNs compliance with the comprehensive regulatory controls and permits in place will mitigate impacts to the land from BFNs continued operations during the subsequent period of extended operation. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. TVA concludes that compliance with current NPDES permit conditions, preparation of and implementation of a SWPPP and BMPs as appropriate will ensure that geology and soil impacts from continued plant operations over the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.4-1). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-8

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.5. Water Resources This section evaluates surface water and groundwater impacts associated with the BFN SLR. 4.5.1. Surface Water Resources Table 4.5-1 lists surface water issues identified in the GEIS and the GEIS findings. Each of these issues was reviewed with respect to impacts associated with the BFN SLR. Table 4.5-1. Surface Water Issues and the NRC 2013 GEIS Findings SLR-ER Issues GEIS Finding Section Surface water use SMALL (Category 1). Impacts are expected to be small if best 3.5.1; and quality (non- management practices are employed to control soil erosion and 4.5.1.1 cooling system) spills. Surface water use associated with continued operations and refurbishment associated with license renewal would not increase significantly or would be reduced if refurbishment occurs during a plant outage. Altered current SMALL (Category 1). Altered current patterns would be limited to 3.5.1; patterns at intake the area in the vicinity of the intake and discharge structures. 4.5.1.2 and discharge These impacts have been small at operating nuclear power structures plants. Altered salinity SMALL (Category 1). Effects on salinity gradients would be 3.5.1; gradients limited to the area in the vicinity of the intake and discharge 4.5.1.3 structures. These impacts have been small at operating nuclear power plants. Altered thermal SMALL (Category 1). Effects on thermal stratification would be 3.5.1; stratification of limited to the area in the vicinity of the intake and discharge 4.5.1.4 lakes structures. These impacts have been small at operating nuclear power plants. Scouring caused SMALL (Category 1). Scouring effects would be limited to the 3.5.1; by discharged area in the vicinity of the intake and discharge structures. These 4.5.1.5 cooling water impacts have been small at operating nuclear power plants. Discharge of SMALL (Category 1). Discharges of metals have not been found metals in cooling to be a problem at operating nuclear power plants with cooling-system effluent tower-based heat dissipation systems and have been 3.5.1.3; satisfactorily mitigated at other plants. Discharges are monitored 4.5.1.6 and controlled as part of the National Pollutant Discharge Elimination System (NPDES) permit process. Discharge of SMALL (Category 1). The effects of these discharges are biocides, sanitary regulated by federal and state environmental agencies. 3.5.1.3; wastes, and minor Discharges are monitored and controlled as part of the NPDES 4.5.1.7 chemical spills permit process. These impacts have been small at operating nuclear power plants. Surface water use SMALL (Category 1). These conflicts have not been found to be conflicts (plants a problem at operating nuclear power plants with once-through 3.5.1.2; with Once-Through heat dissipation systems. 4.5.1.8 Cooling systems) Surface water use (Category 2). Impacts could be of small or moderate 3.5.1.2; conflicts (plants significance, depending on makeup water requirements, water 4.5.1.9 with cooling ponds availability, and competing water demands. or cooling towers using makeup water from a river) Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-9

Appendix E - Applicants Environmental Report-Operating License Renewal Stage SLR-ER Issues GEIS Finding Section Effects of dredging SMALL (Category 1). Dredging to remove accumulated on surface water sediments in the vicinity of intake and discharge structures and quality to maintain barge shipping has not been found to be a problem 4.5.1.10 for surface water quality. Dredging is performed under permit from the United States Army Corp of Engineers (USACE), and possibly, from other state or local agencies. Temperature SMALL (Category 1). These effects have not been found to be a effects on problem at operating nuclear power plants and are not expected 3.5.1.3, sediment transport to be a problem. 4.5.1.11 capacity Source: (NRC 2013) Section 3.5.1 of this ER describes existing surface water resources in the vicinity of BFN which may be affected by the issues listed in Table 4.5-1. 4.5.1.1. Surface Water Use and Quality (Non-Cooling System) Section 3.5.1 of this ER describes existing surface water resources in the vicinity of BFN. Potential impacts to surface water use as a result of operations or refurbishment during the subsequent period of extended operation could occur if the activities used a substantial volume of surface water, such that the amount of surface water remaining was not sufficient to supply other surface water users or support ecological or navigational purposes. With the exception of the cooling water system, BFN uses municipal water provided by the Athens Municipal Water Supply for all potable and non-potable water uses. The source of water for the Athens Municipal Water Supply is surface water from the Elk River, which flows into Wheeler Reservoir. In 2022, BFN consumed a total of 993,849 gallons of water. The average monthly consumption was 82,821 gallons, with January having the highest use (101,954 gallons) and October having the lowest use (67,187 gallons). This represents an insignificant fraction of the average withdrawal rate of 1,056,013 million gallons per month for cooling water for BFN. The volume of water used during any potential refurbishment activity would also be insignificant compared to the volume used by the cooling system. Potential impacts to surface water quality as a result of operations or refurbishment during the subsequent period of extended operation could occur from the release of pollutants in stormwater runoff, including erosion of suspended sediment from exposed soils, pesticides and fertilizers from landscaped areas, oils and lubricants from motorized vehicles, spills of fuels or paint, road salts, metals and sediment from roof shingles, and temperature effects from impervious surfaces. BFN has an Integrated Pollution Prevention Plan that describes fuel and hazardous material management requirements to minimize the potential for release of these materials to surface water. Attachment 5 of the plan provides an inventory listing all of the tanks, pumps, transformers, and other containers where fuel or hazardous materials are used or stored. For each container, the inventory lists the contents, capacity, and type of containment. The containment depends on the type of equipment or container, but includes berms, double-walled tanks, sumps, curbs, and clay or plastic linings of ditches. Pesticides are reviewed by TVA toxicologists for state approval and acceptable areas of application. Motor vehicle re-fueling is done using secondary containment. Because of the climate, use of road salt is extremely rare. In addition, TVA follows BMPs intended to minimize the potential for release of fuels and hazardous materials, as specified in A Guide for Environmental Protection and Best Management Practices for Tennessee Valley Authority Construction and Maintenance Activities, Revision 4, 2022. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-10

Appendix E - Applicants Environmental Report-Operating License Renewal Stage The Clean Water Act (CWA) authorizes the NPDES permit program to control water pollution by regulating point sources that discharge pollutants into waters of the United States. ADEM is authorized by USEPA to administer NPDES permitting rules in Alabama (USEPA 2020). Within ADEM, the Water Division administers the NDPES permits (ADEM 2021). The requirements for NPDES permits are detailed in Alabama Administrative Code Chapter 335-6-6 (ADEM 2015). The Water Quality Branch of ADEM has determined that the NPDES permit will address any water quality concerns. Therefore, a CWA Section 401 Water Quality Certification from ADEM will not be required as part of the license renewal process. As outlined in ADEM Admin Code 335-6-6, conditions of the NPDES permit include requirements for BFN to institute programs targeting industrial wastewater and stormwater to prevent or minimize the generation and potential for release of pollutants from facility operations to stormwater. The BMP program requires each facility component or system to be examined for waste minimization opportunities and determine and implement actions to reduce waste loadings and chemical losses to all wastewater and stormwater streams. Whenever there is a reasonable potential for equipment failure (e.g., a tank overflow or leakage), natural condition (e.g., precipitation), or other circumstances to result in pollutants reaching the condenser circulating water (CCW) system, the BMP must include a prediction of the direction, rate of flow, and the total quantity of pollutants which could be discharged to the CCW system as a result of each condition or circumstance. Stormwater BMPs must include a preventive maintenance program that includes timely inspection and maintenance of stormwater management devices (e.g., cleaning oil/water separators and catch basins) and inspecting and testing facility equipment and systems to uncover conditions that could cause breakdowns or failures resulting in discharges of pollutants to surface waters, and ensuring appropriate maintenance of such equipment and systems (ADEM 2018). Land disturbance is not currently anticipated for continued operations, but could result from routine infrastructure maintenance or renovation activities to maintain and upgrade or replace infrastructure and structures if needed to support BFN operations. BFNs administrative procedure for approving construction activities, which includes any clearing of land, excavation, or other action which would alter the physical environment or ecology of the site, therefore applies to maintenance activities which include land disturbance. The BFN procedure specifies obtaining the state-required construction stormwater permit. The ADEM generic permit for stormwater discharge from large and small construction activities (permit ALR100000) is a general permit for construction activities that requires preparation of a construction SWPPP that includes BMPs to be followed to minimize erosion and sediment resulting from stormwater runoff (ADEM 2021). As part of the BFN Radiological Environmental Monitoring Plan (REMP), TVA analyzes the concentration of certain radionuclides, including tritium, on releases to unrestricted areas. Results are reported in the Annual Radiological Effluent Release. As discussed above, BFN monitors surface water quality in accordance with its NPDES permit (ADEM 2018). Compliance with the current NPDES and stormwater regulatory requirements and permit conditions as well as implementation of the SWPPP, BMPs, and the Integrated Pollution Prevention Plan will ensure continued insignificant impact on surface water quality during the subsequent period of extended operation. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Based on the site-specific analyses presented above, TVA finds that impacts to surface water use and quality during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.5-1). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-11

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.5.1.2. Altered Current Patterns at Intake and Discharge Structures Section 3.5.1 of this ER describes existing surface water resources in the vicinity of BFN. Potential impacts to current patterns as a result of operations or refurbishment during the subsequent period of extended operation could occur if the intake or discharge rates or locations were to change in a way that affected existing flow within the reservoir. The degree of influence of intake and discharge structures on currents depends on the design and location of the intake and discharge structures and the characteristics of the surface water body. In general, the impacts of intake and discharge on current patterns are limited to a localized area, and do not affect the larger part of a reservoir or river (NRC 2013). The effect on currents near the intake and discharge locations for BFN during the subsequent period of extended operation is expected to be localized, as any previous problems will have been mitigated during the early operational period of a plant. The size of Wheeler Reservoir precludes significant current alterations except in a limited area in the vicinity of the intake and discharge structures. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified with regard to current patterns at the BFN intake and discharge structures or with regard to Wheeler Reservoir currents in general. TVA concludes that altered current patterns are limited to the area in the vicinity of the BFN intake and discharge structures. Therefore, TVA finds that impacts to surface water current patterns are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.5-1). 4.5.1.3. Altered Salinity Gradients Section 3.5.1 of this ER describes existing surface water resources in the vicinity of BFN. This issue relates to plants located on estuaries and addresses changes in salinity caused by cooling system water withdrawals and discharges to estuaries. BFN is located on Wheeler Reservoir, which is not on an estuary. Therefore, this issue does not apply to BFN. 4.5.1.4. Altered Thermal Stratification of Lakes Section 3.5.1 of this ER describes existing surface water resources in the vicinity of BFN. For plants on lakes or reservoirs, the effect of cooling water intake or discharge on thermal stratification is examined periodically through the NPDES permit renewal process. Impacts on thermal stratification due to nuclear power plant operations have not been encountered (NRC 2013). Impacts from altered thermal stratification of lakes and reservoirs during the license renewal term were considered to be SMALL for all plants and were designated as Category 1 issues in NUREG-1437, Volume 1 (NRC 1996). The BFN units are normally cooled by pumping water from Wheeler Reservoir and discharging it back to the reservoir via three large, submerged, diffuser pipes that are perforated to maximize uniform mixing into the flow stream. This straight-through flow path is known as open cycle or open mode operation. As originally designed, the maximum thermal discharge from the once-through cooling water system is directed into the Wheeler Reservoir, with a temperature increase from the intake to the discharge of 25 degrees Fahrenheit (°F). The discharge exits through the diffusers and mixes with the reservoir. A thermal plume of discharge water loses heat to the atmosphere and to the receiving surface water body. It also undergoes mixing with the surface water. During the initial license renewal for BFN, the NRC concluded there were no impacts of altered thermal stratification in Wheeler Reservoir beyond those discussed in NUREG-1437, Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-12

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Supplemental 21 (NRC 2005). Thermal stratification in Wheeler Reservoir is predominantly determined by operation of the dam and River Operations, which manage releases from both Guntersville and Wheeler Dams to maintain sufficient river flow, and to actively manage thermal conditions within the reservoir. To achieve this, TVA monitors water temperature at six to ten different water depths at six locations near BFN, with data recorded every 15 minutes. Thermal stratification generally begins in late March, and continues until overnight temperatures drop to below 50°F. TVA manages the reservoir in order to keep the thermal stratification intact, because this allows them to ensure that they withdraw the coolest possible water. Because TVA actively manages water flow in the reservoir to maintain thermal stratification during the months when cool water is needed, ongoing operations are not expected to adversely impact thermal stratification. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, TVA did not identify any N&SI regarding this issue. Therefore, TVA concludes that the impacts of altered thermal stratification as a result of the BFN SLR are SMALL, which is consistent with the conclusions in the 2013 GEIS (Table 4.5-1). 4.5.1.5. Scouring Caused by Discharged Cooling Water Section 3.5.1 of this ER describes existing surface water resources in the vicinity of BFN. In the 2013 GEIS, the NRC reviewed the impacts of scouring caused by discharged cooling water (NRC 2013). The high flow rate of water from a cooling system discharge structure has the potential to scour sediments and redeposit them elsewhere. The scouring will remove fine-grained sediments, resulting in turbidity, and leave behind coarse-grained sediments. Scouring is expected to occur only in the vicinity of the discharge structure where flow rates are high. While scouring is possible during reactor startup, negligible scouring typically occurs during operational periods when discharge rates remain constant. Because BFN operates three units, lengthy shutdowns of the cooling water systems do not occur. There have been no observed effects of scouring or substantial re-suspension of sediment following start-up after a lengthy shutdown. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified that is applicable to this issue at BFN. Therefore, TVA finds that impacts related to scouring caused by discharged cooling water during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.5-1). 4.5.1.6. Discharge of Metals in Cooling System Effluent Section 3.5.1.3 of this ER describes regulated releases to surface waters in the vicinity of BFN. Heavy metals such as copper, zinc, and chromium can be leached from condenser tubing and other components of the heat exchange system by circulating cooling water, and would then be discharged to the receiving water body. These metals are normally addressed in plant NPDES permits because high concentrations of the metals can be toxic to aquatic organisms. During normal operations, heavy metal concentrations are normally below laboratory detection levels (NRC 2013). There have been no NPDES non-compliance issues due to release of metals at BFN. Toxicity sampling is performed annually at the plant discharge, and no exceedances of any toxins have been detected. BFNs continued adherence to comprehensive regulatory controls and permits and BFNs internal procedures will mitigate potential impacts of heavy metals to surface waters from BFNs operations during the subsequent period of extended operation. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-13

Appendix E - Applicants Environmental Report-Operating License Renewal Stage TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Therefore, TVA finds that impacts related to discharge of metals in cooling system effluent during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.5-1). 4.5.1.7. Discharge of Biocides, Sanitary Wastes, and Minor Chemical Spills Section 3.5.1.3 of this ER describes regulated releases to surface waters in the vicinity of BFN. In the 2013 GEIS, the NRC reviewed the discharge of biocides, sanitary wastes, and minor chemical spills (NRC 2013). The use of biocides is common and is required to control biofouling and nuisance organisms in plant cooling systems. Minor chemical spills collected in floor drains are associated with industry in general and are a possibility at all plants. Each of these factors represents a potential impact on surface water quality. The NRC considered the potential impacts of these factors resulting from nuclear plant operations of surface water quality in its GEIS for license renewal. BFNs sanitary wastewater is treated in an onsite biological treatment lagoon that has a capacity of 65,000 gallons per day. The sewage lagoon consists of three open ponds that operate in series, with the final pond discharging treated sanitary wastewater to Wheeler Reservoir through an outfall that is regulated under the BFN NPDES permit. BFN has an Integrated Pollution Prevention Plan that addresses storage, secondary containment, and inspections. The plan provides an inventory of all of the tanks, pumps, transformers, and other containers where fuel or hazardous materials are used or stored, including the type of secondary containment for each. The secondary containment will limit the potential for minor chemical spills to occur outside of containment areas. BFN has a comprehensive environmental protection program for the non-radiological hazards of plant operations guided by compliance with state, district, and local environmental permits and requirements. The comprehensive regulatory controls and permits in place and BFNs compliance with them, guided by their internal procedures, will prevent, or minimize impacts to surface waters from BFNs continued operations during the subsequent period of extended operation. Discharges will continue to be monitored and constituents will be controlled in compliance with the permit. Compliance with NPDES regulatory requirements and permit conditions and the Integrated Pollution Prevention Plan will ensure the impact of biocides and minor chemical spills would continue to be limited. Additionally, BFN will continue to sample all discharge through the permitted outfalls and submit a monthly Discharge Monitoring Report for ADEM to meet the NPDES Permit AL0022080 requirements. Parameters recorded will include water temperatures, differential temperatures, flows, pH, total suspended solids, and oil and grease concentrations TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Therefore, TVA finds that impacts related to discharge of biocides, sanitary wastes, and minor chemical spills in cooling system effluent during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.5-1). 4.5.1.8. Surface Water Use Conflicts (Plants with Once-Through Cooling Systems) Section 3.5.1.2 of this ER describes surface water use at BFN. Nuclear power plant cooling systems may compete with other users relying on surface water resources, including Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-14

Appendix E - Applicants Environmental Report-Operating License Renewal Stage downstream municipal, agricultural, or industrial users. Once-through cooling systems remove water from a water body, use the water to cool the reactor, and then return almost all of the withdrawn water to the same surface water body. Typically evaporative cooling (cooling towers) represent the only losses in these types of systems and have a consumptive volume loss of less than 3 percent. Consumptive use by plants with once-through cooling systems during the subsequent period of extended operation is not expected to change unless power uprates, with associated increases in water use, are proposed. Such uprates would require an environmental assessment by the NRC (NRC 2013). Future scenarios for water availability focus on climate change and associated changes in precipitation and temperature patterns. Increased temperatures and/or decreased rainfall would result in lower river flows, increased cooling pond evaporation, and lowered water levels in the Great Lakes or reservoirs. While weather will vary from year to year, the results of climate change models and the projected changes to surface water runoff in the 21st century (NETL 2006) predicted increases in runoff in the eastern United States and decreases in runoff in the western United States. Regardless of overall climate change, droughts could result in problems with water supplies and allocations. Because future agricultural, municipal, and industrial users would continue to share their demands for surface water with power plants, conflicts might arise if the availability of this resource decreased. This situation would then necessitate decisions by local, state, and regional water planning officials (NRC 2013). Population growth around nuclear power plants has caused increased demand on municipal water systems, including systems that rely on surface water. Municipal intakes located downstream of a nuclear power plant could experience water shortages, especially in times of drought. Water demands upstream of a plant could impact the water availability at the plants intake (NRC 2013). As discussed in Section 3.5.1.1, the average daily flow in Wheeler Reservoir past BFN is approximately 47,600 cubic feet per second (cfs; 30,763 million gallons per day [MGD]) (TVA 2020b). In 2020, BFN withdrew approximately 3,289 MGD, which was 94 percent of the total withdrawal by all users of 3,496 MGD (Sharkey and Springston 2022). Of the 3,289 MGD withdrawn, BFN consumed approximately 6 MGD, or 0.2 percent of the withdrawal. As a result, consumptive and off-stream water uses do not conflict significantly due to the large volume of reservoir water available, and the return of almost all of the withdrawn water to the reservoir. Both surface water withdrawals and net water usage in the Wheeler Reservoir have declined since 1995, and this trend is expected to continue into the subsequent period of extended operation. Overall, watershed-wide surface water withdrawal peaked at 12,237 MGD in 2005, and has since declined to 8,182 MGD in 2020. This is almost entirely due to reduction in thermoelectric withdrawal, which has declined 20.5 percent since 1995 (Sharkey and Springston 2022). Net water demand in the Wheeler-Wilson Water Use Tabulation Area declined from 196 MGD in 2000 to 69 MGD in 2020. According to the Water Use in the Tennessee River Watershed for 2020 and Projected Use in 2045 (Sharkey and Springston 2022), there will be an 11 percent decrease in water withdrawals in the watershed from 2020 levels by 2045. There will be a minor increase in water use for irrigation and public supply, a minor decrease in water use for industrial purposes, and a major decrease in thermoelectric water use. Thermoelectric water use will decline from 6,536 MGD in 2020 to 5,501 MGD in 2045, a decrease of 16 percent. Overall net water demand will increase 18 percent from 403 MGD in 2020 to 475 MGD in 2045, but this is due to increases in net usage in irrigation, public supply, and industrial uses. Net usage in thermoelectric water use will decrease 7 percent from 73 to 68 MGD. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-15

Appendix E - Applicants Environmental Report-Operating License Renewal Stage TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Therefore, TVA finds that impacts related to conflicts with surface water use from the BFN cooling systems during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.5-1). 4.5.1.9. Surface Water Use Conflicts (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River) Section 3.5.1.2 of this ER describes surface water use at BFN. Nuclear power plants with cooling ponds and closed-cycle cooling tower systems require makeup water to replace losses due mostly to evaporation. Although the rate of consumptive water use (chiefly evaporative losses) normally does not change over the operating life of a power plant, external circumstances and environmental conditions may change, increasing pressures on surface water supplies. For example, there may be an extended period of drought, a large population increase in the area, or an influx of industrial facilities (NRC 2013). There could, in theory, be a change in precipitation patterns in the region. For this reason, the NRC made surface water use conflicts a Category 2 issue requiring a site-specific analysis for plants utilizing cooling towers or cooling ponds and withdrawing makeup water from a river. BFN operates an open-cycle, once-through cooling water system that does not utilize either a cooling pond or closed-cycle cooling towers requiring makeup water. The flow rate withdrawn from the river does not change during times of helper cooling tower operation. Even during helper cooling tower operation, BFN operates in once-through, open-cycle mode, returning nearly all of the volume of water withdrawn back to the Wheeler Reservoir Water is not withdrawn from the river for makeup water, and the volume of water returned to the Wheeler Reservoir is only slightly reduced due to evaporation and drift. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Because BFN uses a once-through cooling water system and no water is withdrawn for use as makeup water, and because nearly all of the water withdrawn is returned to the Wheeler Reservoir, this issue as specified does not apply to BFN. 4.5.1.10. Effects of Dredging on Surface Water Quality Section 3.5.1.3 of this ER describes existing surface water quality in the vicinity of BFN. Dredging in the vicinity of surface water intakes, canals, and discharge structures takes place in order to remove deposited sediment and maintain the function of plant cooling systems. Dredging may also be needed to maintain barge shipping lanes. Whether accomplished by mechanical, suction, or other methods, dredging disturbs sediments in the surface water body and affects surface water quality by temporarily increasing the turbidity of the water column. In areas affected by industries, dredging can also mobilize heavy metals, polychlorinated biphenyls (PCBs), or other contaminants in the sediments (NRC 2013). The frequency of dredging depends on the rate of sedimentation. In general, maintenance dredging briefly affects localized areas. Dredging operations are performed under permits issued by the USACE, and from state or local agencies. The physical alteration of water bodies is regulated by federal and state statutes under Section 401 (Certification) and Section 404 (Permits) of the CWA. The USACE regulates the discharge of dredged and/or fill material under Section 404, while Section 401 requires the applicant for a Section 404 permit to also obtain a Water Quality Certification from the State to confirm that the discharge of fill materials will be in compliance with applicable state water quality standards. If dredging affect threatened or endangered species or critical habitat, as established under the ESA, the USACE must consult with the USFWS or NOAA Fisheries before it makes a permit decision. In issuing a Section 404 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-16

Appendix E - Applicants Environmental Report-Operating License Renewal Stage permit, the USACE also considers other potential impacts on aquatic resources, archaeological resources, Tribal concerns, and the permitting requirements of state and local agencies. The permitting process may include planning for the sampling and disposal of the dredged sediments (NRC 2013). The BFN intake channel must occasionally be dredged for maintenance purposes to return the intake channel to design specifications. The intake channel has been dredged only once (in 2018), which was the first time in the 46-year operating history of BFN. TVA evaluates routine maintenance impacts using a NEPA categorical exclusion checklist. Generally, the dredged material is dewatered using flocculent either in Geo Tubes at a location onsite or in a barge, with filtrate water being returned either to the cold water channel or directly to the river. The dewatered solids will either be deposited at an onsite spoils area or shipped offsite Maintenance dredging is performed under a permit provided by the USACE Mobile District. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Based on the site-specific analyses presented above, TVA finds that impacts of dredging on surface water quality during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.5-1). 4.5.1.11. Temperature Effects on Sediment Transport Capacity Section 3.5.1.3 of this ER describes existing surface water quality in the vicinity of BFN. In the 2013 GEIS, the NRC reviewed the potential for increased water temperature and the resulting decreased viscosity to reduce the ability of water to carry sediment, which in turn could result in deposition of sediment (NRC 2013). The GEIS concluded that any increased sedimentation resulting from increased temperature will be minimal compared to changes in sedimentation due to the presence of plant structures or modification of current patterns, and that these changes were easily mitigated. TVA has not identified sediment transport as a potential issue in this area of the Tennessee River, and there has been no need to conduct any sediment transport modeling or analysis of the effects of temperature on sediment transport. Also, the temperature of the BFN discharge is limited to the temperatures specified in the NPDES permit, which were established to avoid or minimize impacts of increased water temperatures. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Based on the site-specific information presented above, TVA finds that impacts of temperature effects on sediment transport capacity during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.5-1). 4.5.2. Groundwater Resources Table 4.5-2 lists the groundwater issues identified in the GEIS and the GEIS findings. Each of these issues was reviewed with respect to impacts associated with the BFN SLR. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-17

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 4.5-2. Groundwater Issues and the NRC 2013 GEIS Findings SLR-ER Issues GEIS Finding Section Groundwater contamination SMALL (Category 1). Extensive dewatering is not 3.5.2.2, and use (non-cooling system anticipated from continued operations and refurbishment 3.5.2.3, impacts) associated with license renewal. Industrial practices 4.5.2.1 involving the use of solvents, hydrocarbons, heavy metals, or other chemicals, and/or the use of wastewater ponds or lagoons have the potential to contaminate site groundwater, soil, and subsoil. Contamination is subject to state or United States Environmental Protection Agency (USEPA) regulated cleanup and monitoring programs. The application of best management practices for handling any materials produced or used during these activities would reduce impacts. Groundwater use conflicts SMALL (Category 1). Plants that withdraw less than 100 3.5.2; (plants that withdraw less gpm are not expected to cause any groundwater use 4.5.2.2 than 100 gallons per minute conflicts. [gpm]) Groundwater use conflicts (Category 2). Plants that withdraw more than 100 gpm 3.5.1; (plants that withdraw more could cause groundwater use conflicts with nearby 3.5.2; than 100 gallons per minute groundwater users. 4.5.2.3 [gpm]) Groundwater use conflicts (Category 2). Water use conflicts could result from water 4.5.2.4 (plants with closed-cycle withdrawals from rivers during low-flow conditions, which cooling systems that withdraw may affect aquifer recharge. The significance of impacts makeup water from a river) would depend on makeup water requirements, water availability, and competing water demands. Groundwater quality SMALL (Category 1). Groundwater withdrawals at 4.5.2.5 degradation resulting from operating nuclear power plants would not contribute water withdrawals significantly to groundwater quality degradation. Groundwater quality SMALL (Category 1). Sites with closed-cycle cooling 3.5.2; degradation (plants with ponds could degrade groundwater quality. However, 4.5.2.6 cooling ponds in salt groundwater in salt marshes is naturally brackish and thus, marshes) not potable. Consequently, the human use of such groundwater is limited to industrial purposes. Groundwater quality (Category 2). Inland sites with closed-cycle cooling ponds 3.5.2.3; degradation (plants with could degrade groundwater quality. The significance of the 4.5.2.7 cooling ponds at inland sites) impact would depend on cooling pond water quality, site hydrogeologic conditions (including the interaction of surface water and groundwater), and the location, depth, and pump rate of water wells. Radionuclides released to (Category 2). Leaks of radioactive liquids from plant 3.5.2.3; groundwater components and pipes have occurred at numerous plants. 4.5.2.8 Groundwater protection programs have been established at all operating nuclear power plants to minimize the potential impact from any inadvertent releases. The magnitude of impacts would depend on site-specific characteristics. Source: (NRC 2013) Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-18

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.5.2.1. Groundwater Contamination (Non-Cooling System Impacts) This renamed issue is an expansion of the issue Impacts of refurbishment on groundwater use and quality from the 1996 GEIS with the addition of the impacts of industrial activities associated with continued operations on groundwater use and quality (NRC 2013). The contamination of groundwater and soil can result from general industrial practices at any site and is not limited to those occurring at nuclear power plants. Such industrial practices can be evaluated generically, as they are common to industrial facilities and nuclear power plants. Activities that result in contamination may include the use of solvents, hydrocarbon fuels (diesel and gasoline), heavy metals, or other chemicals. These materials all have the potential to affect groundwater and soil if released. Furthermore, contaminants present in the soil can act as long-term sources of contamination to underlying groundwater depending on the severity of the spill. BFN has an Integrated Pollution Prevention Plan that describes fuel and hazardous material management requirements to minimize the potential for release of these materials to groundwater. The plan provides an inventory listing all of the tanks, pumps, transformers, and other containers where fuel or hazardous materials are used or stored. For each container, the inventory lists the contents, capacity, and type of containment. The containment depends on the type of equipment or container, but includes berms, double-walled tanks, sumps, curbs, and clay or plastic linings of ditches. Pesticides are reviewed by TVA toxicologists for state approval and acceptable areas of application. Motor vehicle re-fueling is done using secondary containment. Because of the climate, use of road salt is extremely rare. In addition, TVA follows BMPs intended to minimize the potential for release of fuels and hazardous materials, as specified in A Guide for Environmental Protection and Best Management Practices for Tennessee Valley Authority Construction and Maintenance Activities, Revision 4, 2022. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Based on the site-specific analyses presented above, TVA finds that impacts to groundwater quality during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.5-1). 4.5.2.2. Groundwater Use Conflicts (Plants that Withdraw less than 100 GPM) Section 3.5.2 of this ER describes the existing groundwater resources within the vicinity of BFN. As mentioned in Section 3.5.2, the original construction of some plants required dewatering of a shallow aquifer. Dewatering wells have been inactive at BFN since the 1980s. Continued operations and refurbishment activities during the subsequent period of extended operation are not expected to require any dewatering (TVA 2006). BFN does not currently use groundwater and TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Based on the site-specific analyses presented above, TVA finds that impacts to groundwater use during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.5-1). 4.5.2.3. Groundwater Use Conflicts (Plants that Withdraw greater than 100 GPM) In the 2013 GEIS, the NRC made groundwater use conflicts a Category 2 issue because, at a withdrawal rate of more than 100 gallons per minute (gpm), a cone of depression could extend offsite (NRC 2013). This could deplete the groundwater supply available to offsite users, an impact that could warrant mitigation. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-19

Appendix E - Applicants Environmental Report-Operating License Renewal Stage The issue of groundwater use conflicts at plants that pump more than 100 gpm of groundwater does not apply to BFN because BFN does not use groundwater, as discussed in Section 3.5.2. As Section 3.5.1 describes, the plant obtains all its cooling water and process water from Wheeler Reservoir via the intake channel and obtains its potable water from the City of Athens, Alabama. BFN does not currently use groundwater and TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. No N&SI was identified. Therefore, this issue does not apply to BFN. 4.5.2.4. Groundwater Use Conflicts (Plants with Closed Cycle Cooling Systems that Withdraw Makeup Water from a River) In the 2013 GEIS, the NRC made groundwater use conflicts a Category 2 issue for closed-cycle cooling systems using cooling towers and cooling ponds that withdraw makeup water from a river because consumptive use of river water could adversely affect users of the rivers water, and influence aquifer water level depending on the water requirements and availability, and competing water demands of the plant (NRC 2013). This Category 2 issue addresses influence on aquifer water level, which is a particular concern during low-flow conditions and could result in a more severe cumulative impact to the aquifer recharge system if a river supports several to many consumptive users. As discussed in Section 4.5.1.8, Wheeler Reservoir is the source for the open cycle cooling water systems operated at BFN and water is not withdrawn from the river for makeup water; BFN does not use groundwater. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Therefore, this issue does not apply to BFN. 4.5.2.5. Groundwater Quality Degradation Resulting from Water Withdrawals In the 2013 GEIS, the NRC reviewed the use of groundwater for purposes other than cooling and the potential for groundwater contamination from plant operations other than discharges from the plants cooling water system (NRC 2013). The 2013 GEIS determined that this was a Category 1 issue. As mentioned in Section 3.5.1, BFN does not use groundwater for any processes. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Therefore, this issue is not applicable to BFN. 4.5.2.6. Groundwater Quality Degradation (Plants with Cooling Ponds in Salt Marshes) Section 3.5.2.3 of this ER describes existing groundwater quality in the vicinity of BFN. In the 2013 GEIS, the NRC reviewed the use of groundwater for purposes other than cooling and the potential for groundwater contamination from plant operations other than discharges from the plants cooling water system (NRC 2013). The 2013 GEIS determined that this was a Category 1 issue. As mentioned in Section 3.5.2, BFN does not use groundwater for any processes, and does not have cooling ponds in salt marshes. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Therefore, this issue is not applicable to BFN. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-20

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.5.2.7. Groundwater Quality Degradation (Plants with Cooling Ponds at Inland Sites) In the 2013 GEIS, the NRC made degradation of groundwater quality a Category 2 issue because inland sites with unlined cooling ponds could result in degradation of groundwater quality. Potential impacts will be dependent upon cooling water pond quality, site hydrogeologic conditions, and water well characteristics at the plant (NRC 2013). Section 3.5.2.3 of this ER describes existing groundwater quality in the vicinity of BFN. BFN uses a once-through cooling system with helper cooling towers and does not use cooling ponds. TVA has no plans for modifications or refurbishment activities beyond normal maintenance at BFN associated with SLR that will affect BFNs once-through cooling system or require use of cooling ponds. Additionally, no N&SI was identified. Therefore, the issue of groundwater degradation from cooling ponds does not apply to BFN. 4.5.2.8. Radionuclides Released to Groundwater In the 2013 GEIS, the NRC made the release of radionuclides to groundwater a Category 2 issue because inadvertent releases to groundwater of liquids containing radioactive materials have occurred at some nuclear power plants and the magnitude of impacts would depend on site specific characteristics (NRC 2013). Section 3.5.2.3 of this ER describes existing groundwater quality in the vicinity of BFN. TVA participates in the Nuclear Energy Institute (NEI) industry initiative to protect groundwater (NEI 07-07 "Industry Groundwater Protection Initiative - Final Guidance Document"). As part of that initiative, BFN has implemented an active program to monitor and mitigate the potential for radiological releases to groundwater. TVA operates the Nuclear Power Group (NPG) Groundwater Protection Program (GPP) which implements the requirements specified in NEI 07-07 and publishes an Annual Radiological Environmental Operating Report for the station. Under this program, BFN informs the NRC, state agencies and local officials of unintended releases of radiological materials to groundwater which meet specified reporting criteria. In the early 2000s, BFN initiated a groundwater study to identify the source of low-level tritium detected onsite. Results from the groundwater study conducted in 2006 suggested the source of tritiated groundwater was from historical leaks and spills associated with Radwaste/Condensate transfer tunnel. Groundwater and surface water level measurements during the study indicated the return channel and subsequently the Wheeler Reservoir (Tennessee River) will ultimately be recipient to tritiated groundwater discharge from the site. Groundwater movement in the area has been determined to be from the plant site toward the Wheeler Reservoir (Tennessee River) with no groundwater drinking wells onsite (TVA 2022a). BFN conducts annual and semi-annual groundwater monitoring of groundwater wells in order to monitor for potential leaks from plant equipment. As part of the NPG GPP, BFN sampled 30 groundwater wells located in the protected area and the owner-controlled area during 2020. Normal sampling frequencies are quarterly and semiannually, and some wells are sampled monthly if certain criteria are met or for investigation purposes. Samples are routinely analyzed for environmental level tritium (H3) and principal gamma emitters with selected wells analyzed for HardtoDetect radionuclides (Gross Alpha, Fe55, Ni63, Sr89, and Sr90). In support of the groundwater program, the site also monitors recapture and onsite storm drains, catch basins and surface water (TVA 2021a). In 2020, low levels of tritium were detected in 13 onsite groundwater wells (TVA 2021a). Tritium concentrations ranged from nondetectable (less than 163 picocuries per liter (pCi/L]) up to a maximum concentration of 35,400 pCi/L (Dewat-A). BFN has been monitoring a legacy tritium plume in the vicinity of groundwater well Dewat-A located adjacent to the reactor building. This plume is the result of leaks that occurred in 2015 and 2016 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-21

Appendix E - Applicants Environmental Report-Operating License Renewal Stage (TVA 2023b). No other plant related radionuclides were detected in any groundwater wells and no other instances of onsite spills or leaks occurred during the 2017 through 2022 reporting periods that needed to be communicated to offsite agencies or that met the criteria in NEI 07-07 (TVA 2018a, TVA 2019, TVA 2020a, TVA 2021a, TVA 2022a, TVA 2023b). Based on results of the GPP monitoring, TVA concludes that the occurrence of radionuclides in the groundwater beneath BFN is not adversely affecting offsite groundwater because groundwater that has detectable tritium flows into the discharge canal, where it is diluted to negligible levels (TVA 2021a). Furthermore, with the containment provided for the liquid radwaste system, there is little likelihood of the release of liquid radwaste to the groundwater. In the event of any unusual release of radwaste liquid which could contaminate groundwater at the site, special local monitoring will be carried out in accordance with BFNs REMP to ensure that the use of these wells will not result in undue hazards to any person. There are no groundwater drinking wells onsite (TVA 2022a). Therefore, the BFN SLR will have a SMALL impact on groundwater contamination and further mitigation is not warranted. 4.6. Ecological Resources This section evaluates ecological impacts associated with the BFN SLR. 4.6.1. Terrestrial Resources Table 4.6-1 lists the terrestrial ecology issues identified in the 2013 GEIS and the GEIS findings. Each of these issues was reviewed with respect to impacts associated with BFN SLR. Table 4.6-1. Terrestrial Ecology Issues and the NRC 2013 GEIS Findings SLR-ER Issues GEIS Finding Section Effects on terrestrial (Category 2). Impacts resulting from continued operations and 3.6.1 resources (non- refurbishment associated with license renewal may affect 4.6.1.1 cooling system terrestrial communities. Application of best management impacts) practices would reduce the potential for impacts. The magnitude of impacts would depend on the nature of the activity, the status of the resources that could be affected, and the effectiveness of mitigation. Exposure of SMALL (Category 1). Doses to terrestrial organisms from 3.6.1; terrestrial organisms continued operations and refurbishment associated with 4.6.1.2 to radionuclides license renewal are expected to be well below exposure guidelines developed to protect these organisms. Cooling system SMALL (Category 1). No adverse effects to terrestrial plants or 3.6.1; impacts on terrestrial animals have been reported as a result of increased water 4.6.1.3 resources (plants with temperatures, fogging, humidity, or reduced habitat quality. Once-Through Due to the low concentrations of contaminants in cooling Cooling systems or system effluents, uptake, and accumulation of contaminants in cooling ponds. the tissues of wildlife exposed to the contaminated water or aquatic food sources are not expected to be significant issues. Cooling tower SMALL (Category 1). Impacts from salt drift, icing, fogging, or 3.6.1; impacts on vegetation increased humidity associated with cooling tower operation 4.6.1.4 (plants with cooling have the potential to affect adjacent vegetation, but these towers) impacts have been small at operating nuclear power plants and are not expected to change over the license renewal term. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-22

Appendix E - Applicants Environmental Report-Operating License Renewal Stage SLR-ER Issues GEIS Finding Section Bird collisions with SMALL (Category 1). Bird collisions with cooling towers and 3.6.1 plant structures and other plant structures and transmission lines occur at rates that 4.6.1.5 transmission lines are unlikely to affect local or migratory populations and the rates are not expected to change. Water use conflicts (Category 2). Impacts on terrestrial resources in riparian 4.6.1.6 with terrestrial communities affected by water use conflicts could be of resources (plants with moderate significance. cooling ponds or cooling towers using makeup water from a river) Transmission line SMALL (Category 1). Continued ROW management during the 2.2.6.1 ROW management license renewal term is expected to keep terrestrial 3.6.1; impacts on terrestrial communities in their current condition. Application of best 4.6.1.7 resources management practices would reduce the potential for impacts. Electromagnetic SMALL (Category 1). No significant impacts of EMFs on 2.2.6.1 fields on flora and terrestrial flora and fauna have been identified. Such effects 4.6.1.8 fauna (plants, are not expected to be a problem during the license renewal agricultural crops, term. honeybees, wildlife, livestock) Source: (NRC 2013) Section 3.6.1 describes terrestrial resources in the vicinity of BFN. 4.6.1.1. Effects on Terrestrial Resources (Non-Cooling System Impacts) Section 3.6.1 of this ER describes terrestrial ecological resources in the vicinity of BFN. Non-cooling system impacts to terrestrial resources could result from refurbishment or from activities such as landscape maintenance and infrastructure upgrades. In the 2013 GEIS, the NRC made non-cooling system impacts to terrestrial resources a Category 2 issue because the significance of impacts on terrestrial habitats and wildlife would depend on site-specific factors. Aspects of the site and project to be ascertained are: (1) the nature of refurbishment or other license renewal activities, (2) the identification of important ecological resources, and (3) the extent of impacts to terrestrial plant and animal habitats (NRC 2013). No refurbishment or changes to plant operational activities or in-scope transmission lines that would change effects on terrestrial resources are expected to occur during the subsequent period of extended operation. Wildlife and plant species on the developed parts of the BFN property are common species adapted to industrial sites and able to tolerate industrial noise and human activity. The characteristics of terrestrial communities on less intensively developed parts of the property have been influenced by years of BFN operations and maintenance activities occurring in close proximity. No known sensitive terrestrial habitats currently exist within the BFN property boundaries, and operations and maintenance activities during the subsequent period of extended operation are expected to be similar to current activities. Furthermore, as a corporate agency and instrumentality of the United States, TVA is subject to the requirements of federal laws and regulations, including NEPA and the ESA, CWA, and CAA. Thus, environmental reviews under these and other regulations are carried out for all TVA actions in consultation and/or cooperation with other federal agencies. Pursuant to this process, applicable environmental requirements are identified for each proposed activity, and mitigation measures are considered. As a result, Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-23

Appendix E - Applicants Environmental Report-Operating License Renewal Stage current operations and maintenance have had small impacts on terrestrial resources. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. TVA concludes that continued operations and maintenance activities associated with non-cooling systems during the subsequent period of extended operation will have SMALL impacts on terrestrial resources and warrant no additional mitigation measures. 4.6.1.2. Exposure of Terrestrial Organisms to Radionuclides Section 3.6.1 of this ER describes terrestrial ecological resources in the vicinity of BFN. Doses to terrestrial organisms from continued operations and refurbishment associated with license renewal are expected to be well below exposure guidelines developed to protect these organisms (NRC 2013). The 2022 REMP compared the radioactive material content in the environmental monitoring samples to that in control stations samples. There was no identified increase in cesium-137 (Cs-137) levels attributable to BFN operation. The detected concentrations were typical of the levels expected to be present in the environment from past nuclear weapons testing and accidents, such as fallout from the Chernobyl and Fukushima nuclear plants. Tritium was not detected in any water samples. Only naturally occurring radioactivity was identified in fish and local crop samples and in air particulate samples (TVA 2023a). These results are consistent with the NRCs conclusion in the 2013 GEIS (Table 4.6-1). Measured levels of radioactivity in the environmental samples at BFN were similar to expected background levels. There was no identified increase in exposure of terrestrial organisms to radionuclides from ingestion of plants or fish attributable to BFN operations. Doses to terrestrial organisms from continued operations and refurbishment associated with license renewal are expected to be well below exposure guidelines developed to protect these organisms. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Therefore, TVA finds that SLR of the BFN will have a SMALL impact on terrestrial organisms, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.6-1). Further mitigation is not necessary. 4.6.1.3. Cooling Tower Impacts on Terrestrial Resources (Plants with Once-Through Cooling Systems or Cooling Ponds) Section 3.6.1 of this ER describes terrestrial ecological resources in the vicinity of BFN. Terrestrial plants and animals can be impacted from increased water temperatures, fogging, increased humidity, or reduced habitat quality. These impacts have generally been found to be small at operating nuclear power plants and are not expected to change at BFN over the subsequent period of extended operation. Adverse effects from nuclear power plants with once-through cooling systems would not be expected to result in significant impact to plants or animals. BFN does not utilize either a cooling pond or closed-cycle cooling towers in which contaminants could be concentrated and result in uptake and accumulation in aquatic food sources. BFN uses an open-cycle, once-through cooling water system. The cooling water is discharged back to Wheeler Reservoir via three large, submerged, diffuser pipes that are perforated to maximize uniform mixing into the flow stream to meet the facilitys NPDES discharge permit limits and to minimize concentrations of contaminants in cooling system effluents. When necessary to reduce discharge water temperatures to meet NPDES permit thermal discharge temperature limits, some of the BFN cooling water is directed through cooling towers. Helper cooling towers typically operate at BFN only during the hottest part of the summer, typically in July and August. As described in Section 3.2.5, icing and fogging have not been concerns because helper cooling towers are normally operated for only a short period of time Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-24

Appendix E - Applicants Environmental Report-Operating License Renewal Stage during the summer months. Because the helper cooling towers operate with fresh water, no salt deposition has been observed. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. TVA concludes that the impacts on terrestrial plants and animals from helper cooling tower operation at BFN during the subsequent period of extended operation are SMALL with no reduction in habitat quality, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.6-1). 4.6.1.4. Cooling Tower Impacts on Vegetation (Plants with Cooling Towers) Section 3.6.1 of this ER describes terrestrial vegetation in the vicinity of BFN. Terrestrial plants can be impacted from cooling tower salt drift, icing, fogging, or increased humidity. These impacts have generally been found to be small even at operating nuclear power plants that rely entirely on cooling towers (NRC 2013). Such impacts will not be expected and have not been found at BFN, which uses helper cooling towers only when necessary to meet thermal discharge temperature limits specified in the NPDES permit, and this is not expected to change over the subsequent period of extended operation. As discussed in the previous section, the helper cooling towers at BFN are normally operated only for a short period of time mostly during the months of July and August, so fogging and icing have not been concerns. Because the helper cooling towers operate with fresh water, no salt deposition has been observed. Further, there have been no problems or complaints resulting from helper cooling tower operation. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. TVA finds that the impacts on vegetation from helper cooling tower operation at BFN are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.6-1). 4.6.1.5. Bird Collisions with Plant Structures and Transmission Lines Section 3.6.1 of this ER describes the bird species in the vicinity of BFN. Birds can be impacted from collisions with natural draft cooling towers and other tall plant structures, including transmission lines. The NRC studies found that mechanical draft cooling towers, which is the type used at BFN, are usually shorter than 100 feet and cause negligible mortality to birds (NRC 2013). The NRC found that transmission lines associated with nuclear power plants are likely to be responsible for only a small fraction of total bird collision mortality, and it found no known instances in which nuclear plant transmission lines have affected local bird populations (NRC 2013). In-scope transmission lines include only those lines that connect the plant to the first substation that feeds into the regional power distribution system. At BFN, the in-scope transmission lines are entirely within the developed portion of the BFN property and have a length of only several hundred feet (Figure 2.2-2). Therefore, the potential for bird collisions with in-scope transmission lines at BFN are negligible. TVA currently complies with Executive Order (EO) 13186: Responsibilities of Federal Agencies to Protect Migratory Birds, in accordance with the Migratory Bird Treaty Act (MBTA). Additionally, TVA is developing a memorandum of agreement (MOA) with the USFWS that will include an Avian Protection Plan. The MOA and Avian Protection Plan will be applicable TVA-wide, including BFN. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. TVA finds the impact of bird collisions with plant structures and transmission lines at BFN are SMALL, which. is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.6-1). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-25

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.6.1.6. Water Use Conflicts with Terrestrial Resources (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River) This issue pertains to the effects of water use conflicts on terrestrial resources in riparian communities. It applies to nuclear power plants with cooling ponds or cooling towers, typically with high levels of consumptive use and that use makeup water from a river. Water use conflicts with terrestrial resources in riparian communities could occur when water that supports these resources is diminished either because of droughts; increased water demand for agricultural, municipal, or industrial usage; or a combination of such factors. Because water use circumstances vary from site to site, the NRC concluded that the impact of water use conflicts with riparian communities is a site-specific, Category 2 issue (NRC 2013). BFN does not utilize cooling ponds. BFN uses an open-cycle, once-through cooling water system and directs some of the flow through helper cooling towers only when necessary to reduce discharge water temperatures to meet NPDES permit thermal discharge temperature limits. The helper cooling towers are typically used only a few months during the hottest part of the summer (usually July and August). Even when helper cooling towers are in operation, BFN operates in open-cycle mode, returning nearly all of the water withdrawn back to the river. Water is not withdrawn from the river for makeup water, and the flow rate at the intake does not change during helper cooling tower operation. Additionally, no N&SI was identified. Therefore, this issue is not applicable to BFN. 4.6.1.7. Transmission Line ROW Management Impacts on Terrestrial Resources Section 3.6.1 of this ER describes terrestrial resources in the vicinity of BFN, and Section 2.2.6.1 describes the in-scope transmission lines at BFN. The in-scope transmission lines are entirely within the BFN site. These lines run from the main transformers to the 500 kV and 161 kV switchyards located on the BFN site (Figure 2.2-2). There are no associated ROWs to be maintained onsite, and TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Therefore, TVA finds the impact to terrestrial communities from in-scope transmission line management on the BFN site are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.6-1). 4.6.1.8. EMFs Impacts on Flora and Fauna (Plants, Agricultural Crops, Honeybees, Wildlife, Livestock) In the 2013 GEIS, the NRC identified no significant impacts of EMFs from transmission lines on terrestrial biota (NRC 2013). The overall productivity and reproduction of native and agricultural plants appear unaffected, and no evidence suggests significant impacts on individual animals or wildlife populations that are chronically exposed to EMFs under transmission lines or in the towers. As described in Section 2.2.6.1, the in-scope transmission lines are entirely within the BFN property. These lines are from the main transformers to the 500 kV and 161 kV switchyards located on the BFN site (Figure 2.2-2). There are no associated ROWs onsite that traverse habitat or agricultural land, and TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Most areas on the BFN site have been previously disturbed and provide limited terrestrial resources and negligible potential for exposure of biota to EMFs, and no N&SI was identified. TVA finds the impact to terrestrial communities from EMFs associated with in-scope transmission lines on the BFN site are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.6-1). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-26

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.6.2. Aquatic Resources Section 3.6.2 describes aquatic ecological resources in the vicinity of BFN. Table 4.6-2 lists the aquatic resources issues identified in the GEIS and the GEIS findings. Each of these issues was reviewed with respect to impacts associated with the BFN SLR. Table 4.6-2. Aquatic Resource Issues and the NRC 2013 GEIS Findings SLR-ER Issues GEIS Finding Section Impingement and (Category 2). The impacts of impingement and entrainment 3.6.2; entrainment of aquatic are small at many plants but may be moderate or even 4.6.2.1 organisms (plants with large at a few plants with once-through and cooling-pond Once-Through cooling systems, depending on cooling system withdrawal Cooling systems or rates and volumes and the aquatic resources at the site. cooling ponds) Impingement and SMALL (Category 1). Impingement and entrainment rates 4.6.2.1; entrainment of aquatic are lower at plants that use closed-cycle cooling with 4.6.2.2 organisms (plants with cooling towers because the rates and volumes of water cooling towers) withdrawal needed for makeup are minimized. Entrainment of SMALL (Category 1). Entrainment of phytoplankton and 3.6.2; phytoplankton and zooplankton has not been found to be a problem at 4.6.2.1; zooplankton operating nuclear power plants and is not expected to be a 4.6.2.3 problem during the license renewal term. Thermal impacts on (Category 2). Most of the effects associated with thermal 2.2.3; aquatic organisms discharges are localized and are not expected to affect 3.6.2; (plants with once overall stability of populations or resources. The magnitude 4.6.2.1; through cooling of impacts, 4.6.2.4 systems or cooling however, would depend on site-specific thermal plume ponds) characteristics and the nature of aquatic resources in the area. Thermal impacts on SMALL (Category 1). Thermal effects associated with 2.2.3; aquatic organisms plants that use cooling towers are expected to be small 4.6.2.4; (plants with cooling because of the reduced amount of heated discharge. 4.6.2.5 towers) Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-27

Appendix E - Applicants Environmental Report-Operating License Renewal Stage SLR-ER Issues GEIS Finding Section Infrequently reported SMALL (Category 1). Continued operations during the 3.5.1.1; thermal impacts license renewal term are expected to have small thermal 3.5.1.3; impacts with respect to the following: 3.6.2;

Cold shock has been satisfactorily mitigated at operating 4.6.2.6 nuclear plants with once-through cooling systems, has not endangered fish populations or been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds, and is not expected to be a problem.
Thermal plumes have not been found to be a problem at operating nuclear power plants and are not expected to be a problem.
Thermal discharge may have localized effects but is not expected to affect the larger geographical distribution of aquatic organisms.
Premature emergence has been found to be a localized effect at some operating nuclear power plants but has not been a problem and is not expected to be a problem.
Stimulation of nuisance organisms has been satisfactorily mitigated at the single nuclear power plant with a once-through cooling system where previously it was a problem. It has not been found to be a problem at operating nuclear power plants with cooling towers or cooling ponds and is not expected to be a problem.

Effects of cooling SMALL (Category 1). Gas supersaturation was a concern 2.2; water discharge on at a small number of operating nuclear power plants with 3.5.1.3; dissolved oxygen, gas once-through cooling systems but has been mitigated. Low 3.5.2.3 supersaturation, and dissolved oxygen was a concern at one nuclear power 4.6.2.7 eutrophication plant with a once-through cooling system but has been mitigated. Eutrophication (nutrient loading) and resulting effects on chemical and biological oxygen demands have not been found to be a problem at operating nuclear power plants. Effects of non- SMALL (Category 1). Best management practices and 2.2.5; radiological discharge limitations of NPDES permits are expected to 3.6.2; contaminants on minimize the potential for impacts to aquatic resources 4.6.2.8 aquatic organisms during continued operations and refurbishment associated with license renewal. Accumulation of metal contaminants has been a concern at a few nuclear power plants but has been satisfactorily mitigated by replacing copper alloy condenser tubes with those of another metal. Exposure of aquatic SMALL (Category 1). Doses to aquatic organisms are 2.2.4.1; organisms to expected to be well below exposure guidelines developed 3.6.2; radionuclides to protect these aquatic organisms. 4.6.2.9 Effects of dredging on SMALL (Category 1). Dredging at nuclear power plants is 4.6.2.10 aquatic resources expected to occur infrequently, would be of relatively short duration, and would affect relatively small areas. Dredging is performed under permit from the USACE, and possibly, from other state or local agencies. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-28

Appendix E - Applicants Environmental Report-Operating License Renewal Stage SLR-ER Issues GEIS Finding Section Water use conflicts (Category 2). Impacts on aquatic resources in stream 2.2; with aquatic resources communities affected by water use conflicts 3.5.1.2; (plants with cooling could be of moderate significance in some 4.6.2.11 ponds or cooling situations. towers using makeup water from a river) Effects on aquatic SMALL (Category 1). Licensee application of appropriate 2.2; resources (non- mitigation measures is expected to result in no more than 3.6.2; cooling system small changes to aquatic communities from their current 4.6.2.12 impacts) condition. Impacts of SMALL (Category 1). Licensee application of best 2.2.6.1; transmission line management practices to ROW maintenance is expected to 3.6.2; ROW management on result in no more than small impacts to aquatic resources. 4.6.2.13 aquatic resources Losses from SMALL (Category 1). These types of losses have not been 3.6.2; predation, parasitism, found to be a problem at operating nuclear power plants 4.6.2.14 and disease among and are not expected to be a problem during the license organisms exposed to renewal term. sublethal stresses Source: (NRC 2013) 4.6.2.1. Impingement and Entrainment of Aquatic Organisms (Plants with Once-Through Cooling Systems or Cooling Ponds) In the 2013 GEIS, the NRC made impacts to fish and shellfish from impingement and entrainment a Category 2 issue for plants with once-through cooling systems because it could not assign a single significance level to the issue for all nuclear power plant sites (NRC 2013). The impacts of impingement and entrainment are small at many plants, but they may be moderate or large at others, depending on location, design, and capacity of the plants cooling water intake structure. Section 316(b) of the CWA requires that the cooling water intake structure (CWIS) reflect the best technology available (BTA) for minimizing adverse environmental impacts (33 United States Code [U.S.C.] 1326) from entrainment and impingement of aquatic organisms (33 U.S.C. 1326(b). The location, design, construction, and capacity of the CWIS must reflect the BTA for minimizing such impacts. The NRC requires license renewal applicants to demonstrate the significance level of impingement and entrainment impacts by providing current CWA Section 316(b) determinations and supporting documentation, or alternatively by providing site-specific assessments of impingement and entrainment impacts. USEPA issued a final 316(b) rule effective October 2014 for existing power generating and industrial facilities (79 FR 48299; August 15, 2014). Under the rule, the BFN facility, as an existing facility that withdraws more than 125 million gallons of cooling water per day (actual intake flow), is required to provide an Entrainment Characterization Study (§ 122.21(r)(9)) that includes a minimum of 2 years of entrainment data collection. TVA conducted this study in compliance with Section 316(b) (TVA 2020b). Wheeler Reservoir on the Tennessee River is the source of cooling water for BFN. The intake forebay is separated from Wheeler Reservoir by a gate structure with three bays that are each 40 feet wide by approximately 24 feet high (TVA 2020b). The flow velocity through the gate openings varies depending on the gate position. The intake pumping station includes 18 bays (i.e., six bays per reactor unit), each with a traveling screen. Each bay has a net opening size of about 8.5 feet by 20 feet. The maximum average flow velocity through each bay is Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-29

Appendix E - Applicants Environmental Report-Operating License Renewal Stage approximately 1.6 feet per second and is independent of the reservoir surface elevation. The maximum average velocity through a clean screen with net openings of 3/8 inches by 3/8 inches is about 2.1 feet per second. Flow velocities through the intake pump station bays and traveling screens are independent of the number of units in operation and the reservoir elevation (TVA 2020b). The proportion of cooling water withdrawn from Wheeler Reservoir is small (8.9 percent) compared to the long-term average river flow of 48,300 cfs passing the intake structure (TVA 2021b). The BFN units are cooled by pumping water from Wheeler Reservoir and discharging it back to the reservoir via three large, submerged, diffuser pipes that are perforated to maximize uniform mixing into the flow stream. This straight-through flow path is known as once-through, open cycle, or open mode operation. As originally designed, the maximum thermal discharge from the once-through cooling water system is directed into Wheeler Reservoir, with a temperature increase from the intake to the discharge of 25°F. The flow exits the diffusers and mixes with the reservoir flow. At the edge of the discharge mixing zone, the water temperature is required to be less than 10°F above ambient water temperature. Some of this cooling water can also be directed through helper cooling towers to reduce its temperature as necessary to comply with environmental regulations. The helper cooling towers are operated only when necessary to meet thermal discharge temperature limits specified in the NPDES permit issued by the ADEM, typically a few months during the hottest part of the summer (usually July and August). Entrainment Section 3.6.2 of this ER describes the existing aquatic ecological communities in the vicinity of BFN. In accordance with CWA Section 316(b), § 122.21(r)(9), TVA conducted an entrainment characterization study with sampling over 2 years in 2018 and 2019. Ichthyoplankton sampling was conducted during the period from February 20-21, 2018, through December 17-19, 2019. Samples were collected weekly during February through August (expected period of fish spawning) and monthly from September through January. Samples were collected during day and night at all sampling locations. Samples were collected immediately outside the CCW intake channel located at Tennessee River Mile (TRM) 294.3. To determine the number of fish eggs and larvae available for entrainment, samples were also collected from three equidistant locations along a river transect located at TRM 294.5, immediately upstream from the CCW intake and perpendicular to river flow (TVA 2020b). During the entrainment characterization study, fish eggs and larvae collected were from 11 families: Clupeidae, Moronidae, Centrarchidae, Atherinopsidae, Sciaenidae, Cyprinidae, Catostomidae, Percidae, Ictaluridae, Fundulidae, and Poeciliidae. The remaining fish eggs and larvae were not identifiable. No species were collected that are currently protected under federal, state, or tribal law. No entrainable shellfish occur in the vicinity of the BFN intake (TVA 2020b). Clupeids and freshwater drum eggs comprise a high percentage of the total ichthyoplankton composition. Fish egg densities (mostly freshwater drum) tended to be lowest along the right descending bank and highest at the mid-channel station during both sampling years. Entrainment data demonstrated annual variations in the relative abundance and spatial-temporal distribution of fish, and fluctuations in river flow are common in the vicinity of BFN. The total annual percent of all taxa of fish eggs and larvae in the river that were entrained at BFNs cooling water intake was similar between day (fish eggs 1.8 percent; larvae 4.2 percent) and nighttime (fish eggs 4.2 percent; larvae 6.6 percent) during both sampling years combined (TVA 2020b). Fish egg densities in Wheeler Reservoir tended to be lowest along the right descending bank and highest at the mid-channel sampling station. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-30

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Based on study findings, BFN entrains a low percentage of a small portion of the ichthyoplankton population transported past the site. TVA assumes 100 percent mortality of all aquatic organisms that enter the plant. This entrainment affects only a small portion of the Tennessee River since fish eggs and larvae spawned below the plant are not subject to entrainment and many of those spawned above the plant become nonplanktonic before reaching the plant intake. Entrainment of fish eggs and larvae by BFN is not considered to be a significant adverse impact on the fisheries resources of Wheeler Reservoir. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. For this reason, TVA finds that the impacts on aquatic organisms from entrainment over the subsequent period of extended operation are SMALL and will require no mitigation measures beyond those already in place. Impingement Existing facilities are required to meet BTA for impingement via one of several compliance alternatives. In freshwater, shellfish are limited to crayfish and freshwater mussels. TVA collected data to measure impingement on BFN intake screens during the period from 2007 through 2009. There are no occurrence records of Federal listed species near the BFN intake, and only one crayfish has been collected in impingement samples at BFN (TVA 2021b). Fish taxa collected in impingement samples were designated as forage, commercial, and/or recreational species. Forage fish were defined as those generally regarded as prey for top carnivore fish. Commercially valuable species were defined as those that may be harvested and sold commercially for food or bait in Alabama. Recreationally valuable species were those targeted by anglers or used as bait. During impingement monitoring, a total of 51 fish taxa were collected: 16 taxa were considered forage taxa, 18 commercially valuable, and 28 recreationally valuable, with some taxa included in more than one category (TVA 2021b). Actual numbers of fish collected in impingement samples during the first year (2,810,778) were more than twice that of the second year (1,172,660), but total taxa were similar between years: 46 and 43 taxa during 2007-2008 and 2008-2009, respectively. The increase in total numbers was due to much higher numbers of threadfin shad. Thirty-eight species were collected during both years, and 13 were collected during only one year. Threadfin shad was the species most susceptible to impingement (TVA 2021b). The estimated average annual impingement at the CCW intake during the 2007-2009 sampling was 13,942,033 fish; of these, 96 percent were fragile threadfin shad. Over 90 percent of fish impinged on cooling water intake screens at thermal power plants in the southeastern United States typically are threadfin shad and gizzard shad. The preamble to the Section 316(b) existing facilities rule acknowledges the susceptibility and fragility of these species to impingement and focuses impingement mortality requirements on non-fragile species, unless additional measures are specified by ADEM. Of the non-clupeid species, yellow bass, bluegill, and freshwater drum were most susceptible to impingement. Peak impingement periods were during the cooler months (November-January), indicating shad impingement may be related to cold shock (TVA 2021b). Therefore, TVA finds the impacts on aquatic organisms from impingement are SMALL over the subsequent period of extended operation and will require no mitigation measures beyond those already in place. Conclusion TVA conducted a Comprehensive Technical Feasibility and Cost Evaluation Study of the potential implementation of closed-cycle cooling and fine mesh screens at BFN (TVA 2022b). TVA currently has no plans to implement closed-cycle cooling and/or fine mesh screens. These Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-31

Appendix E - Applicants Environmental Report-Operating License Renewal Stage modifications would not be prudent or practical measure for entrainment reduction due to the challenges, impacts, costs, schedule, and risks. ADEM has determined that the existing CWIS represents the interim BTA (40 CFR 125.98(b)(5)) to minimize adverse environmental impacts in accordance with Section 316(b) of the CWA (33 U.S.C. 1326). BFN is required to operate and maintain the CWIS in a manner that minimizes impingement and entrainment. On January 28, 2022, TVA submitted to ADEM the BFN 316(b) studies along with other information required at § 122.21(r). The purpose of these submittals was to provide the pertinent information to assist ADEM in making a final BTA determination for entrainment under the CWA Section 316(b) Rule. Once BFN receives this final determination in the subsequent NPDES permit, it is then required to select one of seven compliance methods for impingement mortality at § 125.94(c) and submit to ADEM the method and schedule for implementation. If the final determination is that BFNs existing technology is BTA for entrainment, BFN's method of impingement compliance will be to operate modified traveling water screens with a fish return system. In selecting this method, BFN will also be required to undertake a 2-year Impingement Technology Performance Optimization Study (optimization study) after implementation, the purpose of which is to optimize performance of the system. The results of the optimization study will be used by ADEM to develop permit conditions that will ensure optimal performance of the traveling water screens and fish return system. The long-term data collected by TVA on the aquatic community of Wheeler Reservoir indicates that the communities downstream and upstream of BFN are similar based on Reservoir Fish Assemblage Index (RFAI) scores. When compared to the 2000 to 2019 averages, the 2020 RFAI data indicate similarity or improvement in all 12 metrics. The RFAI index incorporates elements used in Section 316 for defining a balanced indigenous community, such as diversity (number of species), trophic levels (categorization by feeding guild), presence of necessary food chain species, non-domination of pollution-tolerant species, and representation of indigenous species. Also, the repetitive sampling and scoring across many years provides a measure of sustainability and trends (TVA 2021c). TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Based on long-term data from the period of operation of BFN, TVA finds the impacts of impingement and entrainment during the subsequent period of extended operation are SMALL. 4.6.2.2. Impingement and Entrainment of Aquatic Organisms (Plants with Cooling Towers) This section discusses the impacts on aquatic organisms from impingement and entrainment when the BFN cooling system is operating in once-through mode, which is its primary mode of operation. The helper cooling towers are operated only when necessary to meet thermal discharge temperature limits specified in the NPDES permit issued by ADEM, typically a few months during the hottest part of the summer (usually July and August). The NRC compared impingement and entrainment rates at plants with once-through versus closed-cycle cooling and found lower rates at plants that use closed-cycle cooling with cooling towers because the rates and volumes of water withdrawal needed for makeup are minimized. However, for plants such as BFN that use a once-through cooling system with helper cooling towers (helper mode operated only when necessary to meet thermal discharge temperature limits specified in the NPDES permit), withdrawal rates would not be reduced (NRC 2013). TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. Thus, TVA finds that the impacts of impingement and entrainment on aquatic organisms during the subsequent period of extended operation is as described in Section 4.6.2.1. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-32

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.6.2.3. Entrainment of Phytoplankton and Zooplankton Section 3.6.2 of this ER describes the existing aquatic ecological communities in the vicinity of BFN. TVA assumes 100 percent mortality of all aquatic organisms that enter the plant. As described in Section 4.6.2.1, BFN entrains a low percentage of a small portion of the plankton population transported past the site. The proportion of cooling water withdrawn from Wheeler Reservoir is small (8.9 percent) compared to the long-term average river flow of 48,300 cfs passing the intake structure (TVA 2020b). As described in Section 4.6.2.1, ADEM has determined that the cooling water intake structure represents the interim BTA to minimize adverse environmental impacts. BFN is required to operate and maintain the CWIS in a manner that minimizes entrainment levels. Phytoplankton and zooplankton have short regeneration times. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. Based on these factors, TVA finds that the impacts of entrainment on phytoplankton and zooplankton during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.6-2). 4.6.2.4. Thermal Impacts on Aquatic Organisms (Plants with Once-Through Cooling Systems or Cooling Ponds) In the 2013 GEIS, the NRC made impacts on fish and shellfish from thermal discharges a Category 2 issue, because the significance of impacts at a given plant depends on cooling system design, plant operating characteristics, configuration of the thermal plume (both horizontal [surface area] and vertical [depth]), and characteristics of the potentially affected aquatic resources (NRC 2013). Thermal impacts may be small, moderate, or large, depending on site-specific circumstances. As a general rule, plants with once-through cooling systems produce greater thermal impacts than plants with recirculating, closed-cycle cooling systems, but other factors may come into play, such as the use of helper cooling towers, bathymetry of the receiving stream, and/or the presence/absence of rare or sensitive aquatic species. Section 2.2.3 of this ER describes BFNs CCW system and residual heat removal service water system. The BFN cooling water system operates in once-through or open mode. When necessary to meet thermal discharge requirements, a portion of the water withdrawn from the river is diverted through helper cooling towers. As originally designed, the maximum thermal discharge from the once-through cooling water system is directed into the Wheeler Reservoir, with a temperature increase from the intake to the discharge of 25°F. The flow exits the diffusers and mixes with the reservoir flow. At the edge of the discharge mixing zone, the water temperature is required to be less than 10°F above ambient water temperature. At certain times of the year, some of this cooling water can also be directed through helper cooling towers to reduce its temperature prior to discharge to Wheeler Reservoir. The helper cooling towers are operated only when necessary to meet thermal discharge temperature limits specified in the NPDES permit issued by ADEM, typically a few months during the hottest part of the summer (usually July and August). As discussed in Sections 3.6.2 and 4.6.2.1, TVA annual monitoring shows that there is a balanced indigenous aquatic community in the immediate vicinity of BFN, and the fish community of Wheeler Reservoir has not been significantly altered by the thermal discharge. The BFN cooling water discharge will continue to be in compliance with the thermal limitations of the BFN NPDES permit. The discharge is not expected to affect the overall stability of aquatic populations or resources of Wheeler Reservoir. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Therefore, TVA finds the thermal impacts of BFN on aquatic resources during the subsequent period of extended operation are SMALL, and no additional mitigation is needed. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-33

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.6.2.5. Thermal impacts on Aquatic Organisms (Plants with Cooling Towers) Section 2.2.3 of this ER describes BFNs CCW system and residual heat removal service water system. The NRC found that thermal impacts have not been a problem at plants that use closed-cycle cooling with cooling towers because of their smaller thermal plumes. As discussed in Section 4.6.2.1, BFN uses a cooling water system that operates in open mode. When necessary to meet thermal discharge requirements, the helper cooling towers are operated, typically only a few months during the hottest part of the summer (usually July and August). Section 4.6.2.4 discusses the thermal impacts on aquatic organisms when the BFN cooling system is operating in once-through mode, which is its primary mode of operation. Even when helper cooling towers are in use, the CCW system operates in open-cycle mode. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Therefore, this issue is not applicable to BFN. 4.6.2.6. Infrequently Reported Thermal Impacts In the 2013 GEIS, the NRC evaluated several additional thermal impacts on aquatic organisms that potentially could result from the operation of nuclear power plant cooling systems. These impacts include cold shock, thermal plume barriers to migration, changes in the distribution of aquatic organisms, accelerated development and maturation of aquatic insects, and stimulation of the growth of aquatic nuisance species (NRC 2013). Cold shock can occur when aquatic organisms that have become acclimated to the elevated temperatures of a thermal plume are abruptly exposed to decreased water temperatures when the artificial heat source stops. These effects are most likely to occur in winter. Cold shock events have only rarely occurred at nuclear plants, usually only a few fish were killed, and population-level effects did not result. Gradual shutdown of plant operations generally prevents cold shock events (NRC 2013). At BFN, routine shutdowns (outages) of each reactor unit occur every other year for refueling, but only one unit is refueled at a time, and the shutdowns typically are scheduled to occur in spring or fall, which are seasons when cold shock is not a concern. Based on operational records for BFN, unplanned, rapid shutdowns also occur occasionally but are expected to be rare, and the occurrence of such an event during a cold period in winter is likely to be even more rare. Cold shock to threadfin shad, which are very sensitive to cold temperatures, has occurred in Wheeler Reservoir in the vicinity of BFN. However, these occurrences have been attributed to natural factors not associated with BFN, such as rapid drops in water temperature due to winter cold fronts. As discussed in Sections 3.6.2 and 4.6.2.1, TVA annual monitoring shows that there is a balanced indigenous aquatic community in the immediate vicinity of BFN, and populations of shad or other fish have not been impacted by cold shock. Thus, continued compliance with the thermal limitations of the BFN NPDES permit, and the practice of gradual shutdowns whenever possible are expected to prevent occurrences of cold shock events associated with the BFN discharge during the subsequent period of extended operation. Thermal plumes can create a barrier to fish migration if the mixing zone covers an extensive cross-sectional area of a river or reservoir and the plume temperature exceeds levels avoided by fish. However, substantial effects on fish passage from such a scenario have not been reported at nuclear power plants and would not be expected to occur at BFN given the limited area of the thermal plume compared to the width of Wheeler Reservoir. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-34

Appendix E - Applicants Environmental Report-Operating License Renewal Stage The potential for changes in the distribution of aquatic organisms as a result of thermal discharges was evaluated by NRC (NRC 2013) based on literature reviews, operational monitoring reports, consultations with regulatory agencies and utilities, and previously published SEISs for license renewals at nuclear power plants. Thermal discharges were not found to have constrained the regional geographic distribution of aquatic organisms at any existing nuclear power plant. NRC concluded that this was because heat from power plant discharge plumes is usually dissipated rapidly, and heated plumes are often small relative to the size of the receiving water body. This is the case at BFN, and changes in the distribution of aquatic organisms as a result of thermal discharges are not expected to occur at BFN during the subsequent period of extended operation. Accelerated development and maturation of aquatic insects potentially may occur as a result of heated effluents. Adult insects could emerge prematurely before the normal seasonal cycle and may be unable to feed or reproduce. NRC (NRC 2013) found that, although premature emergence has been observed in laboratory investigations, it has not been observed in field investigations. Accordingly, such effects are not expected to occur at BFN during the subsequent period of extended operation. Stimulation of the growth of aquatic nuisance species was evaluated by NRC (NRC 2013). The definition of an aquatic nuisance species used by NRC is from the Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 (16 U.S.C. 4701); i.e., a nonindigenous species that threatens the diversity or abundance of native species or the ecological stability of infested waters, or commercial, agricultural, aquacultural or recreational activities dependent on such waters. A wide variety of nuisance species may become established or proliferate as a result of power plant operations. Asiatic clams and zebra mussels can become so abundant that they cause fouling and operational difficulties for the power plant and may out-compete native bivalves in heated waters. NRC considered the effects of stimulating the growth of nuisance organisms to be of small significance for aquatic resources if restricted to the cooling water system and the immediate vicinity of the plant. BFN mitigates the effects of Asiatic clams and zebra mussels at the plant through the use of biocides, and stimulation of the growth of aquatic nuisance species is not expected to occur at BFN during the subsequent period of extended operation. As discussed in Section 3.6.2 and 4.6.2.1, TVA reservoir monitoring shows that there is a balanced indigenous aquatic community in the immediate vicinity of BFN. The BFN cooling water discharge has operated and will continue to be operated in compliance with the thermal limitations of the BFN NPDES permit. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. Therefore, TVA finds that the impacts on aquatic resources from these infrequently reported thermal effects during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.6-2). No additional mitigation is needed. 4.6.2.7. Effects of Cooling Water Discharge on Dissolved Oxygen, Gas Supersaturation, and Eutrophication In the 2013 GEIS, the NRC found that gas supersaturation and low dissolved oxygen are generally not a concern at operating nuclear power plants with once-through cooling systems (NRC 2013). Eutrophication resulting in effects on chemical and biological oxygen demands have not been found to be a problem. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-35

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Sections 3.5.1.3 and 3.5.2.3 describe the surface water quality and groundwater quality, respectively, within the vicinity of BFN. As discussed in Section 3.5.1.3, water quality is generally good in Wheeler Reservoir, but nutrient loads are a concern. The reservoir is on the 2020 Alabama 303(d) list as partially supporting its designated uses due to excess nutrients attributed to agricultural sources (ADEM 2020). TVA has a program to ensure adequate oxygenation of Tennessee River Reservoirs under the 2004 Reservoir Operations System Plan and subsequent consultation with the USFWS. During the long-term period of operation of BFN, effects of cooling water discharge on dissolved oxygen, gas supersaturation, or eutrophication have not been observed. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. TVA concludes that during the subsequent period of extended operation these effects will continue to be SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.6-2). 4.6.2.8. Effects of Non-radiological Contaminants on Aquatic Organisms Section 3.6.2 of this ER describes the existing aquatic ecological communities in the vicinity of BFN. Aquatic biota can be impacted from exposure to biocides and other non-radiological contaminants. BMPs are employed to control pollutants to the maximum extent practicable during operation of nuclear power plants. In the 2013 GEIS, the NRC found that BMPs and compliance with discharge limitations of NPDES permits are expected to minimize the potential for impacts to aquatic resources from non-radiological contaminants (NRC 2013). BFN reported an exceedance of the total residual chloride permit limit at Outfall DSN001Q during the April through June 2020 reporting period. This was attributed to a draw-down test conducted on the sodium bisulfite feed pump to verify pump capacity (TVA 2020c). To prevent reoccurrence, BFN implemented a design change that included installation of a radio control system which automatically terminates the sodium hypochlorite feed into the CCW system if low flow of the detoxifying agent sodium bisulfite is detected at the injection point. Routine operation and maintenance of the BFN facility is subject to TVAs environmental compliance procedures and BFNs Integrated Pollution Prevention Plan. As discussed in Section 2.2, BFN has a comprehensive environmental protection program for the non-radiological hazards of plant operations guided by compliance with state, district, and local environmental permits and requirements. The comprehensive regulatory controls and permits in place and BFNs compliance with them will prevent or minimize impacts to surface waters from BFNs continued operations during the subsequent period of extended operation. Discharges will be monitored and constituents will be controlled to remain in compliance with the NPDES regulatory requirements and permit conditions and the Integrated Pollution Prevention Plan. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. Therefore, TVA finds the impacts of non-radiological contaminants (e.g., biocides and minor chemical spills) during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.6-2). No additional mitigation is needed. 4.6.2.9. Exposure of Aquatic Organisms to Radionuclides In the 2013 GEIS, the NRC found that radionuclide doses to aquatic organisms from operating nuclear power plants are expected to be well below exposure guidelines for the protection of aquatic organisms (NRC 2013). Section 3.6.2 of this ER describes the existing aquatic ecological communities in the vicinity of BFN, and Section 2.2.4.1 describes the Liquid Radioactive Waste Control System at BFN. The Liquid Radioactive Waste Control System Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-36

Appendix E - Applicants Environmental Report-Operating License Renewal Stage collects, treats, stores, and disposes of all potentially radioactive liquid wastes. During normal operation, the liquid effluent treatment systems process and control the release of liquid radioactive effluents to the environment are maintained within the limits of 10 CFR Part 20 and as low as reasonably achievable (ALARA) dose standards in Appendix I to 10 CFR Part 50. The low conductivity (high purity) liquid wastes are processed by filtration and ion exchange through the waste filter and waste demineralizer. After processing, the waste is pumped to a waste sample tank where it is sampled and then, depending upon the conductivity and level of radioactivity, the liquid may be discharged to the circulating-water discharge canal or the cooling tower blowdown line, transferred to the condensate storage tanks, or returned for further processing. An alternate method used for processing low and high conductivity liquid is by vendor-supplied skid-mounted equipment. Depending on effluent quality and plant needs, the water can be sent to either the waste sample tank or floor drain sample tank. Processing from the waste sample tank or floor drain sample tank is identical as described above. The 2022 REMP compared the radioactive material content in environmental samples to control stations samples. There was no identified increase in Cs-137 levels attributed to BFN operation. The concentrations detected were typical of the levels expected to be present in the environment from past nuclear weapons testing and accidents such as fallout from the Chernobyl and Fukushima nuclear plants. Low levels of gross beta activity were detected in some drinking water samples, but this can be attributed to natural radioactivity. Cs-137 was detected in one shoreline sediment sample at a level similar to other low-level detections during previous past monitoring, thus it is not indicative of a new or on-going release from BFN. Tritium was not detected in any surface water or sediment samples. No fission or activation products were detected in any of the environmental monitoring samples. No fission or activation products were detected in any of the game fish samples (TVA 2023a). Only naturally-occurring radioactivity was identified in fish and surface water samples and in air particulate samples. The TVA corrective action program database for the period from January 1, 2016, to July 8, 2021, which includes game and commercial fish, showed no condition reports related to exposure to radionuclides. Measured levels of radioactivity in environmental samples were typical of expected background levels. There was no identified increase in exposure of aquatic organisms to radionuclides attributable to BFN operation from ingestion of fish or exposure to sediment. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. Therefore, TVA concludes that the impacts of radionuclides on aquatic organisms during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.6-2). Further mitigation is not warranted. 4.6.2.10. Effects of Dredging on Aquatic Resources In the 2013 GEIS, the NRC expected that dredging at nuclear power plants would be infrequent and of relatively short duration, and it would affect relatively small areas (NRC 2013). Dredging is regulated under permit from the USACE, and the NRC considers compliance with permits to be sufficient to mitigate potential impacts. The BFN intake channel must occasionally be dredged for maintenance purposes to return the intake channel to design specifications. The intake channel has been dredged only once (in 2018), which was the first time in the 46-year operating history of BFN. TVA evaluates routine maintenance impacts using a NEPA categorical exclusion checklist. Generally, the dredged material will be dewatered using flocculent either in Geo Tubes at a location onsite or in a barge, with filtrate water being returned either to the cold water channel or directly to the river. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-37

Appendix E - Applicants Environmental Report-Operating License Renewal Stage The dewatered solids will either be deposited at an onsite spoils area or shipped offsite (TVA 2018b). Maintenance dredging is performed under a permit provided by the USACE Mobile District. The 2017 and 2018 categorical exclusion checklist for the intake channel dredging did not indicate the need for permitting for aquatic resources or the need for mitigation commitments (TVA 2017b, TVA 2018b). TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. Therefore, TVA concludes that the impacts of dredging on aquatic organisms during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.6-2). Further mitigation is not warranted. 4.6.2.11. Water Use Conflicts with Aquatic Resources (Plants with Cooling Ponds or Cooling Towers Using Makeup Water from a River) Surface water use conflicts may occur when plants withdraw water from rivers experiencing reduced flows, whether the reduction in flow is caused by drought or as the result of increased use of the surface water by additional agricultural, municipal, or industrial users. Reduced river flows associated with climate or increased water use could in turn affect the quantity and quality of stream habitat that is available to aquatic communities. Because the extent of surface water use conflicts varies from location to location, and the potential impacts arising from these conflicts, the NRC concluded that the impact of water use conflicts on aquatic communities could not be determined generically (NRC 2013). Therefore, the impact of surface water use conflicts on stream communities was considered by NRC to be a plant-specific, Category 2 issue. Consumptive water use includes evaporation and drift when cooling towers are being used in the helper mode. This consumptive water use represents a small percentage of the average annual flow in Wheeler Reservoir. During the 7-year period from 2016 through 2022, the average annual volume BFN withdrew cooling water from Wheeler Reservoir of approximately 2,833 MGD, with average losses due to evaporation and drift of approximately 3.01 MGD, or 0.11 percent of the total withdrawal. Thus, most of the water withdrawn at the plant intake (almost 99.8 percent) was returned to the reservoir. The water source at BFN for systems other than the cooling water system is municipal supply, i.e., domestic water and treated surface water are used for process water. As discussed in Section 2.2, BFN operates as an open-cycle, once-through cooling water system. At certain times of the year, some of the BFN cooling water withdrawn from the river is diverted through helper cooling towers to dissipate waste heat and reduce cooling water temperature as necessary to comply with NPDES permit temperature limits before cooling water is discharged back to Wheeler Reservoir. The helper cooling towers are operated only when necessary to meet thermal discharge temperature limits specified in the NPDES permit issued by ADEM, typically a few months during the hottest part of the summer (typically July and August). Even when helper cooling towers are in operation, BFN operates in open-cycle mode, returning nearly all of the water withdrawn back to the river. Water is not withdrawn from the river for makeup water, and the flow rate at the intake does not change due to cooling tower operation. As discussed in Section 3.5.1, the water resources of Wheeler Reservoir are managed per the TVA Reservoir Operations Study, in consultation with the USFWS and USACE (TVA 2004). TVA controls releases from the upstream and downstream dams (Guntersville Dam and Wheeler Dam, respectively), to maintain required minimum flow in Wheeler Reservoir to meet Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-38

Appendix E - Applicants Environmental Report-Operating License Renewal Stage specific system requirements for navigation, aquatic habitats, water quality, water supply, and waste assimilation (TVA 2004). Given that BFN consumptive water use averages only about 0.5 percent of the total withdrawal from the reservoir and that TVA controls these dam releases, neither water availability nor competing water demands in Wheeler Reservoir are adversely affected by BFN operation. Even in low-flow conditions, impacts on the aquatic community will be minimal, if discernible, because of the controls placed on water elevation in Wheeler Reservoir. The aquatic community has adapted to the normally fluctuating water levels and flow conditions of the reservoir. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Therefore, TVA finds that impacts of BFN operation on surface water use and related conflicts with aquatic resources during the subsequent period of extended operation are SMALL. Further mitigation is not warranted. 4.6.2.12. Effects on Aquatic Resources (Non-Cooling System Impacts) In the 2013 GEIS, NRC evaluated potential impacts on aquatic resources from causes other than the cooling system. These impacts include (1) direct disturbance of aquatic habitats within the project area, (2) sedimentation of nearby aquatic habitats as a consequence of soil erosion, (3) changes in water quantity or quality (e.g., due to grading that affects surface water runoff patterns or depletions or discharges of water into aquatic habitats), and (4) releases of chemical contaminants into nearby aquatic systems (NRC 2013). As discussed in Section 4.5.1.1, TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR that would affect surface water quality. Land disturbance is not currently anticipated for continued operations, but could result from routine infrastructure maintenance or renovation activities to maintain and upgrade or replace infrastructure and structures if needed to support BFN operations. BFNs administrative procedure for approving construction activities, which include any clearing of land, excavation, or other actions that would alter the physical environment or ecology of the site, applies to maintenance activities that include land disturbance. The BFN procedure specifies obtaining the state-required construction stormwater permit. The ADEM generic permit for stormwater discharge from large and small construction activities (permit ALR100000) is a general permit for construction activities that requires preparation of a construction SWPPP that includes BMPs to be followed to minimize erosion and sediment resulting from stormwater runoff (ADEM 2021). BFN also monitors surface water quality and possible releases of contaminants in accordance with its NPDES permit (ADEM 2018). Compliance with the current NPDES and stormwater regulatory requirements and permit conditions and implementation of the SWPPP, BMPs, and the Integrated Pollution Prevention Plan will ensure impacts on surface waters and aquatic resources from biocides, minor chemical spills, and other operational activities are minimal. Given adherence to the above procedures and permitting, the aquatic habitats of Wheeler Reservoir and the small water bodies on the BFN site will not be directly disturbed, and sedimentation of aquatic habitats due to soil erosion will not impact aquatic resources nearby. BMPs and mitigation measures associated with permits will prevent erosion during any vegetation clearing or construction activity that may occur. Also, changes in surface water quality or quantity and releases of chemical contaminants into nearby surface waters will be prevented or minimized by regulatory requirements and permits. The comprehensive regulatory controls and permits in place and BFNs compliance with them will prevent or minimize impacts to aquatic resources from continued BFN operations during the subsequent period of extended operation. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. Therefore, TVA finds that non-cooling-system impacts on aquatic resources during the subsequent period of Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-39

Appendix E - Applicants Environmental Report-Operating License Renewal Stage extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.6-2). No additional mitigation measures is needed. 4.6.2.13. Impacts of Transmission Line ROW Management on Aquatic Resources In the 2013 GEIS, NRC evaluated potential impacts on aquatic resources that could result from transmission line ROW management. These impacts include (1) direct disturbance of aquatic habitats, (2) soil erosion, (3) changes in water quality (from sedimentation and thermal effects), and (4) inadvertent releases of chemical contaminants from herbicide use (NRC 2013). Section 3.6.2 of this ER describes aquatic ecological resources in the vicinity of BFN, and Section 2.2.6.1 describes the in-scope transmission lines at BFN. The in-scope transmission lines are entirely within the BFN site. These lines extend from the main transformers to the 500 kV and 161 kV switchyards located on the BFN site (Figure 2.2-2). There are no associated ROWs to be maintained, and these in-scope transmission lines do not cross aquatic resources. This condition is expected to continue during the subsequent period of extended operation. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Additionally, no N&SI was identified. Therefore, impacts of in-scope transmission lines on aquatic resources is not applicable to BFN. 4.6.2.14. Losses from Predation, Parasitism, and Disease Among Organisms Exposed to Sub-Lethal Stresses In the 2013 GEIS, the NRC review found that loss of organisms from predation, parasitism, or disease from sublethal stresses has not been a problem at operating nuclear plants during the license renewal period when changes are localized and the populations of aquatic organisms in the receiving waterbody are not reduced (NRC 2013). Section 3.6.2 of this ER describes aquatic ecological resources in the vicinity of BFN. While BFN operation could contribute to stresses from impingement, entrainment, thermal discharge, low dissolved oxygen levels in the mixing zone, and exposure to radionuclides and non-radiological contaminants, TVA considers these effects to be small, as discussed previously for other aquatic issues. The aquatic community exposed to these stressors has adapted to the conditions resulting from BFNs on-going operations. TVA annual monitoring shows that there is a balanced, indigenous, aquatic community in the immediate vicinity of the BFN cooling water discharge after many years of operation. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. Given that changes in these stresses are not expected, TVA finds impacts from sublethal stresses leading to increased susceptibility to predation, parasitism, and disease during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.6-2). 4.6.3. Special Status Species and Habitats Table 4.6-3 lists the special status species and habitat issue identified in the GEIS and the GEIS findings. This issue was reviewed with respect to impacts associated with the BFN SLR. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-40

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 4.6-3. Special Status Species and Habitat Issues and the NRC 2013 GEIS Findings SLR-ER Issue GEIS Finding Section Threatened, (Category 2). The magnitude of impacts on threatened, 3.6.1.4; endangered, and endangered, and protected species, critical habitat, and 3.6.2.4; protected species and essential fish habitat would depend on the occurrence of listed 4.6.3 essential fish habitat species and habitats and the effects of power plant systems on them. Consultation with appropriate agencies would be needed to determine whether special status species or habitats are present and whether they would be adversely affected by continued operations and refurbishment associated with license renewal. Source: (NRC 2013) In the 2013 GEIS, the NRC made impacts to threatened and endangered species a Category 2 issue because the status of these species is subject to change, and a site-specific assessment is required to determine whether any identified species could be affected by refurbishment activities or continued plant operations during the renewal period (NRC 2013). In addition, compliance with the ESA requires consultation with appropriate federal agencies to determine whether threatened or endangered species are present and whether they will be adversely affected by the continued operation of the nuclear plant, or refurbishment of facilities, during the subsequent period of extended operation. Terrestrial Species Section 3.6.1.4 of this ER describes the special status terrestrial species with a potential to occur in the vicinity of the BFN site. Under the proposed action, TVA will continue to operate BFN according to license requirements, and terrestrial habitats will continue to be managed as they are currently. There are no state or federal listed plant species within 6 miles of BFN. The species with a federal listing status and/or a state protected status and the potential to occur at BFN are the gray bat, Indiana bat, northern long-eared bat, tricolored bat, monarch butterfly, bald eagle, and osprey. The gray bat roosts (ESA listed as endangered) in caves year-round and may occur on BFN property and over Wheeler Reservoir only when foraging. Continued operation of BFN during the subsequent period of extended operation will have NO EFFECT on the gray bat. The Indiana bat (ESA listed as endangered), northern long-eared bat (ESA listed as threatened), and tricolored bat (proposed for listing as endangered under the ESA) roost in trees during the summer. If tree removal became necessary on the BFN property, these species could be affected if the removal occurred during the summer roosting season. Any proposed tree removal will undergo an environmental review process to determine if the trees offer potentially suitable summer roosting habitat for the Indiana bat, northern long-eared bat, or tricolored bat. If the trees to be affected are determined to potentially provide suitable habitat, compliance with ESA Section 7 will be required. If the proposed activities fall under TVAs Programmatic Consultation for routine actions that may impact federal listed bats, completed in 2018, actions and appropriate use of take under the ESA will be documented and reported annually to USFWS. If proposed activities fall outside of those covered under the Programmatic Consultation, a separate Section 7 consultation will be initiated with the USFWS by TVA to avoid adverse effects on listed (or proposed for listing) bat species. With ongoing implementation of these procedures in conjunction with continued operation of BFN during the subsequent period of extended operation, potential effects on listed bat species will be Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-41

Appendix E - Applicants Environmental Report-Operating License Renewal Stage insignificant or discountable. Therefore, the proposed action may affect but are NOT LIKELY TO ADVERSELY AFFECT the Indiana bat and northern long-eared bat, and it are NOT LIKELY TO JEOPARDIZE the tricolored bat. The monarch butterfly currently is a candidate for listing under the ESA. As such, it is not subject to ESA Section 7 consultation. The eastern monarch population breeds throughout eastern North America where milkweeds (Asclepias spp.) occur, including Alabama. Its breeding habitat is mainly prairies, meadows, and weedy fields with milkweeds. It is dependent on milkweeds for breeding habitat because they are the only food source for monarch larvae (caterpillars) (USFWS 2020). Several species of milkweeds potentially could occur in field and wetland habitats at BFN. A wide variety on flowering plants that provide nectar for migrating monarchs also occur in the area. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Therefore, milkweed and nectar sources if present in these habitats will not be impacted by continued operation of BFN. Migrating adults are likely to transit the action area in the fall, but they are highly mobile and will not be affected by continued operation of BFN during the subsequent period of extended operation. For these reasons, the proposed action will not significantly impact monarch populations, and its effects on the species are SMALL. The bald eagle could forage in Wheeler Reservoir, and suitable nesting trees are present in the forest fragment along the reservoir in the southeastern corner of BFN, although no bald eagle nests have been documented on the BFN site. The National Bald Eagle Management Guidelines require the maintenance of a 660-foot buffer around bald eagle nest sites and coordination with USFWS to determine if mitigation measures are adequate (USFWS 2007). Bald eagle nests if established within this distance of the BFN site will be protected in accordance with the guidelines. With ongoing implementation of these measures in conjunction with continued operation of BFN during the subsequent period of extended operation, potential effects on the bald eagle are SMALL. The osprey is a state protected species and one of many native birds that occur in the vicinity of BFN that are protected by the MBTA. Under the MBTA, BFN grounds management practices will continue during the subsequent period of extended operation, and those that must occur within 660 feet of migratory bird nests while nests are active will be limited to bush hogs, mowers, and selective herbicides. If other actions cannot be modified to avoid nesting seasons, coordination with USDA-Wildlife Services will be required for guidance to ensure compliance with the MBTA and EO 13186, Responsibilities of Federal Agencies to Protect Migratory Birds. With ongoing implementation of these procedures in conjunction with continued operation of BFN during the subsequent period of extended operation, potential effects on the osprey and other migratory birds are SMALL. Aquatic Species Section 3.6.2.4 of this ER describes the special status aquatic species with a potential to occur in the vicinity of the BFN site. The TVAs Regional Natural Heritage Database (queried February 2022) included current or historical records of 14 aquatic species with a federal listing status within a 10-mile radius of BFN and/or within the hydrologic units of the Wheeler Reservoir watershed (Table 3.6-8). These include 12 mussel species federally listed as endangered and two fish species listed as threatened (spring pygmy sunfish and slackwater darter). These species also have a state protected status. An additional 11 mussel species and three fish species (Tuscumbia darter, paddlefish, and snail darter) identified in the query have only a state protected status. As described in Section 3.6.2.4, the snail darter has been delisted as a federal threatened species, but it still has state protected status and has recently been found to occur in Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-42

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Wheeler Reservoir. In 1982, 12 mussel species were collected in Wheeler Reservoir in the vicinity of BFN. None of the species had a federal listing status or state protected status (TVA 2021b). In 1999, a survey collected 16 native mussel species in the vicinity of BFN, none of which were federal listed species (TVA 2021b). In July 2021, a mussel survey was conducted by TVA, in conjunction with the Alabama Department of Conservation and Natural Resources, in order to assess the current assemblage of mussels present in the portion of Wheeler Reservoir immediately adjacent to BFN. It found that in the portion of the reservoir near BFN, the mussel community is composed of 11 common, widespread, silt-tolerant species, and no species of mussels or snails with federal or state status were found (Amaker 2021). The historical and current data indicate that rare mussel species with federal or state status do not occur in the portion of Wheeler Reservoir adjacent to and potentially affected by BFN. Therefore, continued operation of BFN during the subsequent period of extended operation will have NO EFFECT on mussel species with federal or state status. As discussed in Section 3.6.2.4, in 21 years (since 1993) of fish entrainment sampling by TVA in the vicinity of BFN, the paddlefish was collected in only 1 year, and the spring pygmy sunfish, slackwater darter, and Tuscumbia darter were never collected (TVA 2020b). The historical and current data indicate that these fish with federal or state status do not occur in the portion of Wheeler Reservoir adjacent to and potentially affected by BFN, and they would not be expected to be present because they do not occur in lacustrine habitat such as that available in this portion of Wheeler Reservoir (NatureServe Explorer 2022). The snail darter has recently been detected in Wheeler Reservoir (Simmons 2019). However, the only suitable habitat for this species that may be present in the vicinity of BFN is on the opposite side of Wheeler Reservoir from BFN. The snail darter was never collected in the 21 years of fish entrainment sampling at BFN, so its occurrence there is unlikely. Therefore, subsequent renewal of the BFN operating license will have NO EFFECT on fish species with federal or state status. 4.7. Historic and Cultural Resources Table 4.7-1 lists the historic and cultural resources issue identified in the GEIS and the GEIS findings. This issue was reviewed with respect to impacts associated with the BFN SLR. Table 4.7-1. Historic and Cultural Resource Issues and the NRC 2013 GEIS Findings SLR-ER Issue GEIS Finding Section Historic and cultural (Category 2). Continued operations and refurbishment 3.7; resources associated with license renewal are expected to have no more 4.7 than small impacts on historic and cultural resources located onsite and in the transmission line ROW because most impacts could be mitigated by avoiding those resources. The National Historic Preservation Act (NHPA) requires the Federal agency to consult with the State Historic Preservation Officer (SHPO) and appropriate Native American Tribes to determine the potential effects on historic properties and mitigation, if necessary. Source: (NRC 2013) In the 2013 GEIS, the NRC made impacts to historic and cultural resources a Category 2 issue (NRC 2013). Determinations of impacts to historic and cultural resources are site-specific in nature and the NHPA mandates that impacts from future plant operations and any planned Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-43

Appendix E - Applicants Environmental Report-Operating License Renewal Stage future refurbishment activities must be considered, which is typically accomplished through consultation with the SHPO. Section 3.7 of this ER describes the historic and cultural resources in the vicinity of BFN. TVA has no plans for refurbishment or other changes to plant structures or activities during the subsequent period of extended operation with potential for effects on BFN or archaeological sites in the area of potential effects (APE). Should such plans be developed in future, TVA will review the plans, identify whether any of the contributing resources to the BFN historic district or potentially-eligible archaeological sites will be affected, and consult further with the appropriate consulting parties regarding TVAs evaluation of effect. Should any activity related to continued operation be proposed that would modify BFN or affect any of the potentially-eligible archaeological sites, TVA will follow the steps of Section 800.5 for assessing adverse effects and, if required, the steps of Section 800.6 for resolving adverse effects. Should future TVA plans have potential for adverse effects on any NRHP-eligible resources, TVA will take the consulting parties comments into consideration in developing ways to avoid, minimize, or mitigate any adverse effects. If adverse effects cannot be avoided, TVA will, in consultation with the appropriate consulting party(-ies), prepare a treatment plan including mitigation for the adverse effect, and will notify the Advisory Council on Historic Preservation. TVA will continue to avoid any activities that would disturb any of the graves in the relocated Cox Cemetery during the subsequent period of extended operation. Should TVA propose any activity that would physically affect the cemetery, TVA will voluntarily complete steps consistent with state statutes regarding cemeteries and human remains. Therefore, TVA concludes that continued operation of BFN during the subsequent period of extended operation will have NO ADVERSE EFFECT on historic and cultural resources. 4.8. Socioeconomics Table 4.8-1 lists the socioeconomic issues identified in the GEIS and the GEIS findings. Each of these issues was reviewed with respect to impacts associated with the BFN SLR. Table 4.8-1. Socioeconomic Issues and the NRC 2013 GEIS Findings SLR-ER Issues GEIS Finding Section Employment and SMALL (Category 1). Although most nuclear plants have large 3.8; income, recreation, and numbers of employees with higher than average wages and 4.8.1 tourism salaries, employment, income, recreation, and tourism impacts from continued operations and refurbishment associated with license renewal are expected to be small. Tax revenues SMALL (Category 1). Nuclear plants provide tax revenue to 3.8.1; local jurisdictions in the form of property tax payments, 4.8.2 payments in lieu of tax, or tax payments on energy production. The amount of tax revenue paid during the license renewal term as a result of continued operations and refurbishment associated with license renewal is not expected to change. Community services SMALL (Category 1). Changes resulting from continued 3.8.1; and education operations and refurbishment associated with license renewal 4.8.3 to local community and educational services would be small. With little or no change in employment at the licensee's plant, value of the power plant, payments on energy production, and payments in lieu of tax expected during the license renewal term, community and educational services would not be affected by continued power plant operations. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-44

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Population and housing SMALL (Category 1). Changes resulting from continued 3.8.1; operations and refurbishment associated with license renewal 4.8.4 to regional population and housing availability and value would be small. With little or no change in employment at the licensee's plant expected during the license renewal term, population and housing availability and values would not be affected by continued power plant operations. Transportation SMALL (Category 1). Changes resulting from continued 3.8.2; operations and refurbishment associated with license renewal 4.8.5 to traffic volumes would be small. Source: (NRC 2013) 4.8.1. Employment, Income, Recreation, and Tourism In the 2013 GEIS, the NRC reviewed the impacts of continued operation and refurbishment of nuclear power plants on employment, income, recreation, and tourism, finding a dynamic socioeconomic system between nuclear power plants and the communities that support them (NRC 2013). BFN provides employment and income to the community, which provides the people, goods, and services to the plant. Section 3.8 of this ER discusses existing socioeconomic conditions in the vicinity of BFN. Impacts to employment and income are directly related to operations at the plant; continuing operations and maintenance activities at the plant provides continuing employment and income streams to the community. During the subsequent period of extended operation, operations and maintenance activities at BFN will be continuous and consistent with current activities, with no expected interruption or change in employment levels. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR; additionally, BFN has no plans to change existing employment levels. No N&SI was identified with regard to employment or income at or in the vicinity of BFN. In the 2013 GEIS, the NRC found that it was not anticipated that continued operation or refurbishment activities would produce changes in employment levels at nuclear power plants (NRC 2013). TVA concurs that it is not anticipated that SLR will change employment or income in the community. TVA finds that impacts to employment and income during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.8-1). As discussed in Section 4.1.4, TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR that would significantly change the existing visual profile of BFN or the visual appearance of plant structures or in-scope transmission lines. Consequently, recreation and tourism activities in the vicinity of BFN are not expected to change as a result of SLR. Additionally, no N&SI was identified. Based on the site-specific analyses presented above, TVA finds that impacts to recreation and tourism during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.8-1). 4.8.2. Tax Revenues In the 2013 GEIS, the NRC reviewed the impacts of continued operation and refurbishment of nuclear power plants on tax revenue income and found a dynamic socioeconomic system between nuclear power plants and the communities that support them (NRC 2013). Details of TVAs payments in lieu of taxes are described in Section 3.8.1. TVA makes payments in lieu of taxation to states and counties in which its power operations are carried on and in Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-45

Appendix E - Applicants Environmental Report-Operating License Renewal Stage which it has acquired properties previously subject to state and local taxation. Only a very small share of the payments is paid directly to counties by TVA; most is paid to the states, which use their own formulas for redistribution of some or all of the payments to local governments. TVA's payments in lieu of taxes are apportioned among the states and counties according to complex allocation formulas developed by each state in the TVA power service area, but in general, half of the money is apportioned based on power sales and half is apportioned based on the book value of TVA Power property (State of Tennessee 2022). Table 3.8-7 shows TVAs payments in lieu of taxes to both Alabama and Tennessee from 2017 through 2022. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. Additionally, BFN has no plans to change existing employment levels. TVA does not anticipate any significant changes in payments in lieu of taxes during the subsequent period of extended operation. Thus, TVA finds that impacts to tax revenues in these states and the counties in the vicinity of BFN are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.8-1). 4.8.3. Community Service and Education Section 3.8.1 of this ER describes community services and education in the vicinity of BFN. In the 2013 GEIS, the NRC found that changes in employment or tax revenue at nuclear plants can impact community services and education either through changes in funding or through increased demand on resources (NRC 2013). Operations and maintenance activities at BFN are not anticipated to result in significant changes in employment, income, population levels, or in payments in lieu of taxes during the subsequent period of extended operation. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. Therefore, TVA finds that the impacts to community services and education from continued operation of BFN during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.8-1). 4.8.4. Population and Housing Sections 3.8.1 and 3.8.1.1 describe the population and housing, respectively, within the vicinity of BFN. As the NRC concluded in the 2013 GEIS, the increased numbers of workers present during refueling and maintenance outages does create a short-term demand for temporary rental or temporary lodging in the vicinity of a nuclear plant such as BFN (NRC 2013). These refueling and maintenance activities are of short-duration and generally occur on a repetitive cycle. Therefore, in general, these activities do not affect the overall availability or cost of rental housing or short-term lodging. BFN anticipates that the refueling and maintenance outage activities during the subsequent period of extended operation will continue in a manner consistent with current schedules and procedures. There are no anticipated changes in workforce levels at BFN either during normal operations or during outages. Therefore, changes to population, housing availability and housing value and costs are not anticipated in the vicinity of BFN during the subsequent period of extended operation. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. Thus, TVA finds that the impacts of continued operation of BFN during the subsequent period of extended operation to population and housing are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.8-1). 4.8.5. Transportation In the 2013 GEIS, the NRC found that transportation impacts associated license renewals are dependent on changes in the workforce, local road network capacity, traffic patterns, and Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-46

Appendix E - Applicants Environmental Report-Operating License Renewal Stage availability of commuting routes to access the plant (NRC 2013). As described previously, BFN does not anticipate changes in the operational or outage workforce during the subsequent period of extended operation. Section 3.8.2 of this ER describes the existing road network, commuting routes, and traffic patterns in the vicinity of BFN. No new or significant information was identified which would indicate changes in these transportation conditions during the subsequent period of extended operation. It is possible that some roadway improvements could occur during this period along routes utilized by BFN employees and fleet vehicles. TVA assumes that any such road improvements would proceed consistent with standard operating procedures and BMPs with implementation of mitigation measures as appropriate to minimize disruptions and safety issues. As there are no planned changes in workforce and no known changes in the transportation network in the vicinity of BFN, TVA finds that the impacts to transportation in associated with continued operation of BFN during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.8-1). 4.9. Human Health Table 4.9-1 lists the human health issues identified in the GEIS and the GEIS findings. Each of these issues was reviewed with respect to impacts associated with the BFN SLR. Table 4.9-1. Human Health Issues and the NRC 2013 GEIS Findings SLR-ER Issues GEIS Finding Section Radiation exposures to SMALL (Category 1). Radiation doses to the public from 3.9.1; the public continued operations and refurbishment associated with 4.9.1 license renewal are expected to continue at current levels and would be well below regulatory limits. Radiation exposures to SMALL (Category 1). Occupational doses from continued 3.9.1; plant workers operations and refurbishment associated with license renewal 4.9.2 are expected to be within the range of doses experienced during the current license term and would continue to be well below regulatory limits. Human health impact SMALL (Category 1). Chemical hazards to plant workers 4.9.3 from chemicals resulting from continued operations and refurbishment associated with license renewal are expected to be minimized by the licensee implementing good industrial hygiene practices as required by permits and federal and state regulations. Chemical releases to the environment and the potential for impacts to the public are expected to be minimized by adherence to discharge limitations of NPDES and other permits. Microbiological hazards (Category 2). These organisms are not expected to be a 3.9.2; to the public (plants problem at most operating plants except possibly at plants 4.9.4 with cooling ponds or using cooling ponds, lakes, or canals that discharge into rivers. canals or cooling Impacts would depend on site-specific characteristics. towers that discharge to a river) Microbiological hazards SMALL (Category 1). Occupational health impacts are 3.9.2; to plant workers expected to be controlled by continued application of accepted 4.9.5 (occupational health) industrial hygiene practices to minimize worker exposures as required by permits and federal and state regulations. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-47

Appendix E - Applicants Environmental Report-Operating License Renewal Stage SLR-ER Issues GEIS Finding Section Chronic effects of (Uncertain). Studies of 60-Hz EMFs have not uncovered 4.9.6 electromagnetic fields consistent evidence linking harmful effects with field (EMFs) exposures. EMFs are unlike other agents that have a toxic effect (e.g., toxic chemicals and ionizing radiation) in that dramatic acute effects cannot be forced and longer-term effects, if real, are subtle. Because the state of the science is currently inadequate, no generic conclusion on human health impacts is possible. Physical occupational SMALL (Category 1). Occupational safety and health hazards hazards are generic to all types of electrical generating stations, 4.9.7 including nuclear power plants, and are of small significance if the workers adhere to safety standards and use protective equipment as required by federal and state regulations. Electric shock hazards (Category 2). Electrical shock potential is of small significance 2.2.6; for transmission lines that are operated in adherence with the 3.9.3; National Electrical Safety Code (NESC). Without a review of 4.9.8 conformance with NESC criteria of each nuclear power plants in-scope transmission lines, it is not possible to determine the significance of the electrical shock potential. Source: (NRC 2013) 4.9.1. Radiation Exposures to the Public Section 3.9.1 of this ER describes the radiological hazards within the vicinity of BFN. BFN operation is in compliance with the design objectives of Appendix I to 10 CFR Part 50 and maintains average annual releases of radioactive material in effluents at small percentages of the limits specified in 10 CFR Part 20 and 40 CFR Part 190. During continued normal operations of BFN, small quantities of fission, corrosion, and activation products will be released to the environment at levels consistent with current operations. The dose impacts of these releases will be calculated using data provided by existing environmental monitoring programs. TVA submits annual radioactive effluent release reports to the NRC and calculates the public dose from its liquid and gaseous radioactive releases. Gaseous effluents considered in the offsite dose calculation include fissions and activation gases and iodines and particulates with half-lives greater than eight days (TVA 2022a). TVA uses its offsite dose calculation manual to provide methods and procedures for calculating offsite doses and to demonstrate that releases do not exceed the dose limits of 10 CFR Part 50 Appendix I. The BFN reports for years 2016 through 2022 were reviewed and the results indicated that the annual public dose is a fraction (less than one percent) of the regulatory limits and were in accordance with radiation protection standards identified within 10 CFR Part 50 (Appendix I), 10 CFR Part 20, and 40 CFR Part 190 (CNS and GEL Labs 2021, CNS and GEL Labs 2022, TVA 2017a, TVA 2018a, TVA 2019, TVA 2020a, TVA 2021a, TVA 2022a, TVA 2023a, TVA 2023b). Because there is no reason to expect effluents to increase during the subsequent period of extended operation, annual doses to the public from continued operation are expected to continue to be a small fraction of the regulatory limits. The NRC has considered cumulative dose from an additional 20 years of operation, acknowledging the fatal cancer risk from the cumulative dose to an exposed individual would be 50 percent higher for 60 years of operation over the baseline of 40 years of operation (NRC 2013). However, as noted previously, annual offsite dose rates are less than one percent of the Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-48

Appendix E - Applicants Environmental Report-Operating License Renewal Stage regulatory limits and cumulative doses over an additional 20-year operating period will be less than 20 percent of one years annual dose limit. For example, the highest total body dose reported between 2016 and 2022 was 0.184 millirem (mrem) in 2019 (TVA 2020a) which is compared to an annual dose limit of 25 mrem. If the highest annual dose of 0.184 mrem was received by the same individual for a period of 20 years, the resulting cumulative dose will be 3.68 mrem, less than 15 percent of the annual dose limit of 25 mrem. In 2022, the average quarterly direct radiation levels at the BFN onsite stations were generally 2 to 6 mrem per quarter higher than levels at the offsite stations. The difference in onsite and offsite averages is consistent with levels measured for the preoperational and construction phases of TVA nuclear power plant sites, where the average levels onsite were slightly higher than levels offsite (TVA 2023b). Results from atmospheric, terrestrial, and liquid pathway monitoring have been consistent during operations at BFN (TVA 2023a) and any activity that is not attributed to fallout or natural background radiation does not represent a significant contribution to the exposure of members of the public (TVA 2023b). TVA does not expect deviation in this trend over an additional 20-year operating period. Radiation doses to the public from continued operations will be expected to continue at current levels and will be well below regulatory limits during the subsequent period of extended operation. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. TVA finds that radiation doses to the public during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.8-1). 4.9.2. Radiation Exposures to Plant Workers Section 3.9.1 of this ER describes the radiological hazards to plant workers at BFN. In the 2013 GEIS, the NRC reviewed radiation exposures to workers at nuclear power plants (NRC 2013). Occupational dose information collected and reviewed by the NRC provides evidence that doses to nearly all radiation workers at operating nuclear power plants are far below the worker dose limit established by 10 CFR Part 20 and that the continuing efforts to maintain doses at levels that are ALARA have been successful (NRC 2013). The NRC also acknowledges that as plants age, there may be slight increases in radioactive inventories, which would result in slight increases in occupational radiation doses. However, the NRC expects that occupational doses from refurbishment activities associated with SLR and occupational doses for continued operations during the subsequent period of extended operation will be similar to the doses during the current operations. The proposed action is to continue to operate BFN as currently designed throughout the subsequent period of extended operation, and TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. The most recent occupational radiation exposure report (NUREG-0713, Volume 41) presents dose data for the NRC licensees (NRC 2022). The average collective dose per reactor at boiling water reactors (BWRs) have trended downward since 1994 when the average dose per reactor was 327 person-rem to 2019 when the average dose per reactor was 105 person-rem (Table 4.1) (NRC 2022). The dose performance trend presented for BFN shows that since 2010, BFNs collective dose per reactor is on a slight downward trend slightly higher than the national average for BWRs (NRC 2022). TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. Therefore, TVA finds that radiation exposures to plant workers during the subsequent period of Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-49

Appendix E - Applicants Environmental Report-Operating License Renewal Stage extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.9-1). 4.9.3. Human Health Impact from Chemicals In the 2013 GEIS, the NRC reviewed potential human health impacts from chemicals associated with nuclear power plant operations (NRC 2013). Human health effects potentially could occur at BFN and other nuclear power plants as a result of discharges of chlorine or other biocides, small-volume discharges of sanitary or other liquid wastes, chemical spills, and metals leached from cooling system piping and condenser tubing. Chemical discharges are regulated by the NPDES permitting system. Minor spills and other small-volume discharges have not had substantial impacts on water quality or human exposure at operating nuclear power plants. Multiple environmental laws, regulations, and permits minimize the potential for impacts on humans from chemical releases at nuclear plants. Accordingly, the NRC found that chemical hazards to plant workers resulting from continued operations and refurbishment associated with SLR are expected to be minimized by the licensee implementing good industrial hygiene practices as required by permits and federal and state regulations. The NRC anticipates chemical releases to the environment and the potential for impacts to the public will be minimized by adherence to discharge limitations of NPDES and other permits. BFN complies with all applicable federal, state, and local environmental laws, regulations and permits to minimize the potential for human impacts from chemical releases. BFN employs good industrial hygiene practices in accordance with all requirements. BFN operates within the constraints of the NPDES permit. BFN has an Integrated Pollution Prevention Plan that describes fuel and hazardous material management requirements to minimize the potential for release of these materials to surface water. Pesticides are reviewed by TVA toxicologists for state approval and acceptable areas of application. In addition, TVA follows BMPs intended to minimize the potential for release of fuels and hazardous materials, as specified in A Guide for Environmental Protection and Best Management Practices for Tennessee Valley Authority Construction and Maintenance Activities, Revision 4, 2022. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. Consistent with the GEIS, TVA finds that chemical exposures of plant workers and the public during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.9-1). 4.9.4. Microbiological Hazards to the Public (Plants with Cooling Ponds or Canals or Cooling Towers that Discharge to a River) In the 2013 GEIS, the NRC designated impacts to public health from microbiological hazards a Category 2 issue, requiring plant-specific analysis, because the magnitude of the potential public health impacts associated with thermal enhancement of such organisms habitats, particularly those of Naegleria fowleri (N. fowleri) and Legionella, could not be determined generically (NRC 2013). The NRC requires [10 CFR 51.53(c)(3)(ii)(G)] an assessment of the potential impact of thermophilic organisms in receiving waters on public health if a nuclear power plant uses a cooling pond, cooling lake, or cooling canal or discharges to a river. This issue is applicable to BFN because BFN ultimately discharges heated water to Wheeler Reservoir. Section 3.9.2 describes the microbiological human health hazards from the operation of BFN. Wheeler Reservoir averages between 1- and 1.5-miles wide near BFN and is used by the public for recreational boating, fishing, and swimming. Guntersville and Wheeler Reservoirs are popular sport fishing areas (CNS and GEL Labs 2022). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-50

Appendix E - Applicants Environmental Report-Operating License Renewal Stage As discussed in Section 3.9.2, the common occurrence of N. fowleri in warm, fresh-water bodies accessible to the public, like Wheeler Reservoir, may make this thermophilic organism more likely than Legionella to potentially pose a public health hazard resulting from operation of nuclear power plants. TVA has performed rigorous sampling of cooling tower basins, cooling tower water, and surrounding areas with the potential for growth of Legionella. Sampling results identified levels of Legionella that were lower than the standard threshold that could potentially impact workers or the publics health. Conversely, as also described in Section 3.9.2, although N. fowleri naturally occurs in surface waters, infections rarely occur at temperatures of 95°F or below. Discharge limitations in NPDES permit number AL0022080 include temperature limits. From 2015 through 2020, average water temperatures from the cooling water discharge did not exceed 90°F and maximum recorded temperatures did not exceed 91°F, even during the warmest months of the year. In the 2005 GEIS Supplement 21, Regarding Browns Ferry Nuclear Plants Units 1, 2, and 3, Section 4.9.5, the NRC concluded that the potential effects of microbiological organisms on human health on or in the vicinity of the plant to the operation of cooling water discharge to the aquatic environment are SMALL (NRC 2005). As discussed in Sections 2.2.3, 2.2.3.1, and 2.2.3.2 of this ER, the BFN NPDES permit limits the temperature of the ambient water downstream of the mixing zone of the submerged diffusers. As originally designed, the maximum thermal discharge from the once-through cooling water system is directed into the Wheeler Reservoir, with a temperature increase across the intake and discharge of 25°F (TVA 2020b). The flow exits the diffusers and mixes with the reservoir flow. At the edge of the discharge mixing zone, the water temperature is required to be less than 10°F above ambient (ADEM 2018). Temperatures near the diffusers could be conducive to the survival and growth of the thermophilic pathogen N. fowleri (CDC 2017). While exposure of the public to N. fowleri is possible in Wheeler Reservoir below the discharge structure, the probability of such exposure is very low due to several factors: (1) the three diffuser pipes located on the bottom of the reservoir under approximately 20 feet of water enhance mixing of effluent and ambient water; discharging heated effluent from a total of 23,400 downstream ports (Benton 2001), (2) the area of the discharge mixing zone in which daily high temperatures exceed 95°F in summer is very small compared to the size of Wheeler Reservoir, and (3) infection from N. fowleri occurs through the nose. Because the discharge mixing zone has a steep shoreline and no residential or recreational facilities to attract recreators, activities that could result in immersion and nasal exposure, such as swimming, diving, and water skiing, are unlikely to occur in the discharge mixing zone, and thus, the probability of exposure and infection is extremely low. Based on the thermal characteristics of Wheeler Reservoir (described in Section 3.5.1.3) and of the BFN discharge (described in Section 3.9.2), ongoing operation of the BFN facility is not expected to stimulate growth and reproduction of pathogenic microbiological organisms in Wheeler Reservoir. Under certain circumstances, pathogenic microbiological organisms might be present in the immediate area of the discharge, but they would not be expected to occur in sufficient concentration to pose a threat to downstream water users. The relationship between the presence of N. fowleri in a water body and the occurrence of infections in people remains unclear, but the risk of infection is very low (CDC 2020, Gharpure et al. 2021). While N. fowleri is a natural, free-living amoeba commonly found in warm, freshwater around the world, increased public risk of N. fowleri infection cases from BFN effluent discharge are not Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-51

Appendix E - Applicants Environmental Report-Operating License Renewal Stage anticipated. The U.S. Centers for Disease Control and Prevention (CDC) maintains a database of reported primary amebic meningoencephalitis (PAM) cases in the United States since 1962. Fewer than ten cases of PAM) occur annually in the United States, and the CDC has no record of infection from N. fowleri in Alabama (CDC 2020, Gharpure et al. 2021). Operation of BFN Units 1, 2, and 3 and their cooling systems are not expected to change substantially over the subsequent period of extended operation, and there is no reason to believe that discharge temperatures will increase or that disinfection would be discontinued. As previously discussed, compliance with the current NPDES permit will continue to protect against high temperatures in the BFN discharge mixing zone that might result in human health impacts from microbiological organisms (NRC 2013, NRC 2005). Compliance with the permit will limit the effects of the BFN cooling water discharge on water temperatures in Wheeler Reservoir, regardless of natural increases in reservoir water temperatures that may result from short-term or long-term changes in weather or climate. From 2015 through 2020, average water temperatures from the cooling water discharge, even during the warmest months of the year, did not exceed 90°F. Maximum temperatures recorded during those months and years did not exceed 91°F. These temperatures are below the range at which N. fowleri is typically found, and the low levels of Legionella found in onsite sampling of waters favorable for its growth indicate that conditions in the reservoir are unlikely to support its growth. Thus, TVA finds that the impacts on public health from thermophilic organisms in Wheeler Reservoir during the subsequent period of extended operation are SMALL. 4.9.5. Microbiological Hazards to Plant Workers In the 2013 GEIS, the NRC reviewed potential microbiological hazards to plant workers (NRC 2013). Section 3.9.2 describes the microbiological human health hazards from the operation of BFN. The NRC found that occupational health impacts were expected to be controlled by continued application of accepted industrial hygiene practices to minimize worker exposures as required by permits and federal and state regulations. BFN complies with all applicable federal, state, and local environmental laws, regulations and permits to minimize the potential for microbiological hazards to impact plant workers. BFN practices good industrial hygiene practices in accordance with all requirements. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. TVA finds that microbiological hazards to plant workers during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.9-1). 4.9.6. Chronic Effects of EMFs In the 2013 GEIS, the NRC determined that the chronic effects of EMFs associated with nuclear plants and associated transmission lines are uncertain (NRC 2013). In Section 4.9.1.1.4 of the 2013 GEIS, the NRC states that because the scientific evidence is inconclusive, the chronic health effects of EMF are uncertain, and no generic impact level can be assigned (NRC 2013). The NRC will continue to monitor research on the potential carcinogenicity of EMFs, and other potential EMF effects. If the NRC finds that appropriate federal health agencies have reached a consensus on the potential human health effects from EMF exposure, the NRC will revise the GEIS to include the new information and will determine how to categorize and evaluate this issue for future license renewal applications. Until such time that this issue is categorized, applicants for license renewal are not required to submit information on this issue [10 CFR Part 51, Subpart A, Appendix B, Table B-1, Footnote 6]; therefore, this issue is not addressed further. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-52

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.9.7. Physical Occupational Hazards The conditions at BFN which result in an occupational risk, but do not affect the safety of licensed radioactive materials, are under the statutory authority of Occupational Safety and Health Administration (OSHA). BFN adheres to OSHA standard 29 CFR Part 1960 and has a comprehensive occupational safety program covering BFN workers and activities. Regarding applicability to a SLR, TVA will continue to maintain a comprehensive occupational safety program. The human health impact from most physical hazards would be due to singular events (e.g., fall) which do not accumulate; therefore, there will be no material difference from one renewal term and a subsequent one. The exception will be physical hazards that have a chronic exposure component such as sound level exposure. OSHA regulations address such precautions and continued compliance with OSHA regulations for exposure and use of personal protective equipment. Therefore, there will not be a material difference between the physical hazard risk of the current period of extended operation and a subsequent one. Occupational safety and health hazards are generic to all types of electrical generating stations, including nuclear power plants, and are of small significance. According to the U.S. Bureau of Labor Statistics, the 2020 total recordable cases of nonfatal occupational injuries and illnesses per 100 full-time workers in the nuclear electric power generation industry was 0.3 (BLS 2021). With TVAs comprehensive occupational safety program designed to address OSHA safety standards and use of protective equipment, BFN carries low incidence of OSHA-recordable work-related injuries and illnesses. This is indicative of the effectiveness of the occupational safety program and BFN workers continued adherence to safety standards and use of protective equipment, which will continue throughout the subsequent period of extended operation. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. TVA finds that physical occupational hazards during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.9-1). 4.9.8. Electric Shock Hazards The electrical shock hazard issue, which is generic to all types of electrical generating stations, including nuclear plants, is of SMALL significance for transmission lines that are operated in adherence with the NESC. In the 2013 GEIS, the NRC made impacts of electric shock from transmission lines a Category 2 issue because, without a review of conformance by each plants in-scope transmission lines, it is not possible to determine the significance of the electrical shock potential generically (NRC 2013). Footnote 4 to Table B-1 in Appendix B to 10 CFR Part 51, Subpart A clarifies the applicability of this issue as follows: This issue applies only to the in-scope portion of electric power transmission lines, which are defined as transmission lines that connect the nuclear power plant to the substation where electricity is fed into the regional power distribution system and transmission lines that supply power to the nuclear plant from the grid. The NRC adopted this clarification in 2013, recognizing that in most cases lines originating at the power plant substations would remain in place and be energized regardless of whether the subject nuclear power plant license was renewed or not and, therefore, would not be impacted by an SLR decision (78 FR 37282; June 20, 2013). Characteristics of the in-scope transmission lines are described in Section 2.2.6 and Figure 2.2-2, and electric shock hazards are discussed in Section 3.9.3. As indicated there, the in-scope transmission lines are all located within the BFN site and are not accessible to the general public. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-53

Appendix E - Applicants Environmental Report-Operating License Renewal Stage The electric shock hazards associated with the in-scope transmission lines are controlled in accordance with applicable industrial safety standards. Additionally, TVAs transmission lines are designed to meet or exceed medium loading requirements of the NESC. Members of the public are precluded from direct contact with these lines in general, and have no access to the transmission lines located within the boundary of BFN. Any induced currents from these lines will be limited to 5 milliamperes, will be within the immediate vicinity of the lines (within the magnetic field), and will not be a hazard to members of the public. Thus, TVA concludes that the potential electric shock hazards from in-scope transmission lines at BFN are SMALL, and no additional mitigation is warranted. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Given that in the 2013 GEIS: (1) for current period of extended operation, the NRC determined that the human health impact from electric shock hazards was SMALL; (2) the in-scope transmission lines are NESC compliant; and (3) BFN routine maintenance, surveillance, and training procedures for the in-scope transmission lines will continue to provide assurance design ground clearances are maintained (NRC 2013), TVA finds the human health impacts from electric shock hazards during the subsequent period of extended operation are SMALL. 4.10. Postulated Accidents Table 4.10-1 lists the postulated accident issues identified in the GEIS and the GEIS findings. Each of these issues was reviewed with respect to impacts associated with the BFN SLR. Table 4.10-1. Postulated Accident Issues and the NRC 2013 GEIS Findings SLR-ER Issues GEIS Finding Section Design-basis accidents SMALL (Category 1). The NRC staff has concluded that the 4.10.1 environmental impacts of design-basis accidents are of small significance for all plants. Severe accidents (Category 2). The probability-weighted consequences of 4.10.2 atmospheric releases, fallout onto open bodies of water, releases to groundwater, and societal and economic impacts from severe accidents are small for all plants. However, alternatives to mitigate severe accidents must be considered for all plants that have not considered such alternatives. Source: (NRC 2013) 4.10.1. Design Basis Accidents In the 2013 GEIS, the NRC reviewed the potential impacts from design-basis accidents. The 2013 GEIS concluded that because a licensee is required to maintain their licensing basis and implement aging management programs during a renewal term, environmental impacts of a design-basis accident will be the same as during the initial license period (NRC 2013). The impacts from BFN are based on calculated radioactive releases, are not affected by the plant environment, and were previously determined by the NRC to be SMALL. TVA maintains existing design-basis accident calculations on an ongoing basis to ensure postulated releases would remain below 10 CFR limits. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified regarding impacts from design-basis accidents. Therefore, impacts of design-basis accidents during the subsequent period of extended operation should not differ significantly from those calculated for the existing design-basis accident assessment. Therefore, TVA concludes that the impacts from Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-54

Appendix E - Applicants Environmental Report-Operating License Renewal Stage design-basis accidents during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.10-1). 4.10.2. Severe Accidents The 2013 GEIS concluded that the probability-weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to groundwater, and societal and economic impacts from severe accidents would be small for all plants. The 2013 GEIS further concluded that applicants for license renewal of plants that have not already had a Severe Accident Mitigation Alternatives (SAMA) analysis considered by the NRC as part of an Environmental Impact Statement (EIS), supplement to an EIS, or an Environmental Assessment, must perform a SAMA analysis for license renewal. The site-specific nature of the SAMA analysis, when one is required, resulted in the categorization of severe accidents as a Category 2 issue. TVA conducted a review for new and significant information related to the following generic conclusions in the 2013 GEIS concerning this issue.

1. The probability-weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to groundwater, and societal and economic impacts from severe accidents are small for all plants.

2. License renewal environmental reports for plants for which SAMAs have been previously considered need not perform an additional SAMA analysis for license renewal.

4.10.2.1. Probability-Weighted Consequences of Severe Accidents Are Small The assessment process for new and significant information related to the first conclusion included review of documents related to predicted impacts of severe accidents at BFN. Consideration was given to developments in plant operation and accident analysis that could have changed the assumptions made concerning severe accident consequences after SAMAs were previously evaluated by the NRC for BFN in the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Supplement 21 Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3 (NRC 2005). Developments in the following areas were included: new internal events information; external events; new source term information; power uprates; higher fuel burnup; and other considerations including population increase. New Internal Events In the 2013 GEIS, the NRC reviewed the BWR accident frequencies (core damage frequency [CDF]) for internal events that formed the basis for the environmental impacts shown in the 1996 GEIS, finding them in most cases to be comparable to or higher than updated accident frequencies. Table 4.10-2 lists BFN CDFs for internal events since the previous SAMA analysis was performed. Table 4.10-3 presents a summary of internal events with internal flooding model change history. Table 4.10-2. BFN Internal Events with Internal Flooding Model CDF and LERF U1 LERF U2 CDF U2 LERF U3 CDF U3 LERF Model Date U1 CDF (/ry) (/ry) (/ry) (/ry) (/ry) (/ry) EPU PSA 2004 1.86E-06 N/A 2.6E-06 N/A 3.4E-06 N/A Rev. 0 MAR 2010 7.18E06 2.60E06 7.89E06 3.16E06 1.13E05 1.75E06 Rev. 1 AUG 2010 5.08E06 9.81E07 5.40E06 9.70E07 6.36E06 8.44E07 Rev. 2 SEP 2010 4.90E06 8.76E07 4.93E06 8.67E07 4.56E06 7.49E07 Rev. 3 JUN 2011 4.66E06 1.27E06 4.32E06 1.70E06 5.95E06 6.26E07 Rev. 4 DEC 2011 4.65E06 1.23E06 4.29E06 1.65E06 5.80E06 6.21E07 Rev. 5 NOV 2012 5.64E06 9.50E07 4.97E06 9.19E07 5.96E06 9.66E07 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-55

Appendix E - Applicants Environmental Report-Operating License Renewal Stage U1 LERF U2 CDF U2 LERF U3 CDF U3 LERF Model Date U1 CDF (/ry) (/ry) (/ry) (/ry) (/ry) (/ry) Rev. 6 JAN 2015 6.05E06 1.11E06 5.25E06 1.06E06 5.88E06 1.05E06 Rev. 7 MAR 2016 6.93E06 1.26E06 6.29E06 1.21E06 7.72E06 1.45E06 Rev. 8 FEB 2018 1.08E05 1.44E06 6.98E06 1.28E06 1.02E05 1.34E06 Rev. 9 NOV 2019 4.07E06 8.64E07 3.28E06 7.95E07 5.99E06 7.98E07 EPU = extended power uprate; ry = reactor year; LERF = large early release frequency Table 4.10-3. BFN Internal Events with Internal Flooding Model CDF and LERF

            % Change in CDF            % Change in LERF Model                                                                                  Comments U1      U2       U3        U1         U2       U3 Initial CAFTA model issued after August 2009 Rev. 0    N/A     N/A      N/A       N/A        N/A      N/A peer review.

Initiating events updated to include current generic data, recent plant events and multiunit initiators. Fire initiators that fail offsite power were added to the model to assess the Diesel Rev. 1 29.2% 31.6% 43.7% 62.3% 69.3% 51.8% Generator Allowed Outage Time Extension. Some logic errors and type code errors were also corrected that were identified from the Revision 0 to Revision 1 model. Initiators %VR and %VS were added for all units. The human error probability for failure to align additional CST inventory was reevaluated based on an additional MAAP run performed. A design Rev. 2 3.5% 8.7% 28.3% 10.7% 10.6% 11.3% change was incorporated into the model that requires three air compressors to supply the entire plant instead of all four. Some logic errors were also corrected that were identified from the Revision 1 to Revision 2 model. The Fire initiators used to assess the Diesel Generator Allowed Outage Time Extension were removed from Revision 3 of the model. Some Rev. 3 4.9% 12.4% 30.5% 45% 96.1% 16.4% logic errors and type code errors were also corrected that were identified from the Revision 2 to Revision 3 model. Changes were made from the Revision 3 to Revision 4 model to support increased unavailability for infrequent maintenance Rev. 4 0.2% 0.7% 2.5% 3.1% 2.9% 0.8% performed on the Emergency Diesel Generators and corrections to logic errors and type code errors found. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-56

Appendix E - Applicants Environmental Report-Operating License Renewal Stage

          % Change in CDF         % Change in LERF Model                                                                         Comments U1      U2      U3      U1        U2       U3 The major change in this update was to revise the data, and mutually exclusive logic. Changes were made in the Revision 5 model to correct errors in the logic noted during review following the issuing of the Revision 4 documentation and to support increased unavailability for infrequent maintenance being performed on the Emergency Diesel Generators. The data in the PRA model was updated for plant specific failures and successes through January 1, 2012. There were no changes in the Accident Analysis, Success Criteria, Internal Flooding, or LERF Analysis, from Revision 4 to Revision 5.

The initiating event analysis was updated to include initiating event data through January 1, 2012 to include current industry generic data, recent plant events and multiunit initiators.

Rev. 5 21.3% 15.9% 2.8% 22.8% 44.3% 55.6%

Changes were made in the Revision 5 model to correct errors in the logic noted during review following the issuing of the Revision 4 documentation.
The unreliability, unavailability, and common cause data analyses were updated. The unreliability (or failure rate) data are based on generic industry data that underwent Bayesian updating with plant specific data. Plant specific data for the period 1/1/2003 to 1/1/2012 was evaluated and used as input to the Bayesian analysis. Plant maintenance unavailability data was based on the same time period as the failure data, 1/1/2003 to 1/1/2012. Generic industry data from NUREG/CR6928 was used for components for which no plant specific data was available.

Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-57

Appendix E - Applicants Environmental Report-Operating License Renewal Stage

          % Change in CDF        % Change in LERF Model                                                                       Comments U1     U2        U3    U1        U2       U3 A model update was performed to merge the Internal Events PRA and the Fire PRA into a single model, to improve the event tree logic, and to resolve issues for AC and DC power. A brief overview of these changes is included in the bullets shown below:

Event Tree changes to credit RCIC for scenarios with an inadvertent open relief valve
Event Tree changes to separate the decay heat removal functional top logic in a more logical manner (hardened wetwell vent and drywell vent, Drywell Sprays)
Event Tree changes to incorporate Alternate Shutdown Cooling for the Fire PRA
Event Tree changes to incorporate the High Rev. 6 7.3% 5.6% -1.3% 16.8% 15.3% 8.7%

Pressure Makeup for the Fire PRA

Logic fault tree changes to address net positive suction head without CAP
Correct the logic for DC chargers
Logic fault tree changes to address overload and load shed logic
Logic changes to address preferred pump logic
Logic changes to address diesel paralleling logic
Logic changes to address conditional LOOP logic
Limited enhancement for LOOP recovery
Develop recoveries for Main Steam Line Break Outside Containment instrumentation
Updated Raw Cooling Water logic The initiating event analysis was updated in Revision 7 of the model to include initiating event data through September 1, 2015 to include current industry generic data, recent plant events and multiunit initiators.

The event trees were updated to account for Rev. 7 14.5% 19.8% 31.3% 14.3% 14.2% 38.1% inclusion of the Fire PRA model into the Internal Events PRA model. The Large LOCA event tree was revised to remove the core flood mitigation system as it does not prevent core damage Multiple model changes to match the asbuilt configuration, correct errors and enhance the model. Changes were made to the Revision 7 model to update the human reliability analysis, internal flood analysis, to implement enhancements, or to correct errors in the logic noted during review following the issuing of the Revision 7 documentation. In addition, plant design changes Rev. 8 55.8% 11.0% 32.1% 14.3% 5.8% -7.6% implemented following the Revision 7 model were reviewed to determine whether additional changes to the model were necessary. Multiple model changes to match the asbuilt configuration, correct errors and enhance the model. The Rev. 9 MOR documentation was updated to Rev. 9 62.3% 53% 41.3% 40% 37.9% -40.4% explain modeling asymmetries. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-58

Appendix E - Applicants Environmental Report-Operating License Renewal Stage The CDFs and large early release frequencies (LERFs) are between one and two orders of magnitude below the conservative value of 1.0E-4 per reactor-year, which was used in the 1996 GEIS to calculate population dose estimates and determined by NRC in the 2013 GEIS to remain bounding. In the 2013 GEIS, the NRC notes that changes in the likelihood of accidents that release substantial amounts of radioactive material to the environment affect the probability-weighted offsite consequences from airborne, surface water, and groundwater pathways, and the resulting economic impacts from such pathways. Considering the decreasing trend observed in the likelihood of severe accidents caused by internal events since 1996 and the conservative dose values used in the 1996 GEIS, the 2013 GEIS concludes that the 1996 GEIS estimates of offsite consequences from severe accidents initiated by internal events remain valid. As indicated above, plant risk from internal events at BFN is similar to the license renewal environmental review in 2003 (TVA 2003). Also, TVA is aware of no changes to the plant likely to occur during the subsequent period of extended operation that would adversely affect plant risk from internal events. Therefore, TVA concludes that no new and significant information exists for BFN concerning offsite consequences from severe accidents initiated by internal events. Accordingly, the conclusions of the 2013 GEIS on this topic are considered appropriate for the BFN SLR. Consideration of External Events In the 2013 GEIS, the NRC reviewed accident frequencies (CDFs) for external events reported in NUREG-1150 (NRC 1990) and NUREG/CR-5305 (NRC 1992), finding them to be generally one or more orders of magnitude lower than the CDFs that formed the basis of the 1996 GEIS. The primary focus of the assessment was on seismic and fire events, which NRC had determined would contribute most to plant risk from external events. Based on a comparison of the risks from internal events to risks from seismic and fire events, the 2013 GEIS concluded that it would be reasonable to assume that contributions to plant risk from fire events and seismic events are each comparable to the contribution from internal events (although a preliminary assessment from Generic Issue 199 indicated that, on average, updated seismic CDFs remained slightly (approximately 30 percent) less than the internal events CDF). Table 4.10-4 lists BFN CDFs for fire events since the previous SAMA analysis was performed. Table 4.10-5 presents a summary of fire model change history. Table 4.10-4. BFN Fire Model CDF and LERF U1 CDF U1 LERF U2 CDF U2 LERF U3 CDF U3 LERF Model1 Date (/ry) (/ry) (/ry) (/ry) (/ry) (/ry) Rev. 0 FEB 2013 6.28E05 2.14E06 6.59E05 1.90E06 5.30E05 1.83E06 Rev. 1 MAR 2013 6.28E05 2.14E06 6.59E05 1.90E06 5.30E05 1.83E06 Rev. 2 NOV 2013 6.28E05 2.14E06 6.59E05 1.90E06 5.30E05 1.83E06 Rev. 3 DEC 2014 5.03E05 5.47E06 5.64E05 5.37E06 5.92E05 5.02E06 Rev. 4 APR 2015 5.03E05 5.47E06 5.64E05 5.37E06 5.92E05 5.02E06 Rev. 5 DEC 2017 6.03E05 6.80E06 6.47E05 7.37E06 6.49E05 5.96E06 Rev. 6 NOV 2019 3.48E05 5.44E06 4.25E05 5.50E06 3.28E05 4.52E06

1. Note: The Quantification Notebook revision was used in this table as opposed to the model revision. All of the document numbers correspond to the BFN Fire PRA post-transition model.

Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-59

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 4.10-5. BFN Fire Model CDF and LERF

           % Change in CDF          % Change in LERF                               Comments Model U1     U2      U3       U1        U2       U3 Rev. 0    N/A    N/A     N/A      N/A       N/A      N/A     Initial posttransition CAFTA model.

Editorial changes to documentation, including Rev. 1 0% 0% 0% 0% 0% 0% some F&O dispositions. Editorial changes to documentation, including Rev. 2 0% 0% 0% 0% 0% 0% some F&O dispositions. Circuit failure mode likelihood analysis now uses probability values based on test data documented Rev. 3 19.9% 14.4% 11.7% 155.6% 182.6% 174.3% in NUREG/CR7150. This impacts Section 6.1.10 and the disposition of F&Os 246, 247, and 415. Updated various F&O dispositions. Revision of Attachment A and B and other Rev. 4 0% 0% 0% 0% 0% 0% editorial changes. Changes in this are limited to minor revisions in Section 6.1.16, a complete revision of the quantification results tables in Section 7.0, an update of Attachment A to incorporate results of 2015 FocusedScope Peer Review, and minor Rev. 5 19.9% 14.7% 9.6% 24.3% 37.2% 18.7% editorial changes throughout the body of the calculation. The references to BFN documents are updated to the current revisions as applicable. Attachment 1 was deleted because it is no longer relevant for this revision of the notebook. This revision was a scheduled update that incorporated quantification results from model changes to include those made to the ignition frequencies, fire modeling, cable selection, circuit Rev. 6 42.3% 34.3% 49.5% 20% 25.4% 24.2% failure probabilities, and plant response model analyses in response to demands such as condition reports plant modifications, and internal events model updates. Table 4.10-6 lists BFN CDFs for seismic events since the previous SAMA analysis was performed. Table 4.10-7 presents a summary of seismic model change history. Table 4.10-6. BFN Seismic Model CDF and LERF U1 CDF U1 LERF U2 CDF U2 LERF U3 CDF U3 LERF Model1 Date (/ry) (/ry) (/ry) (/ry) (/ry) (/ry) APR Rev. 0 5.07E06 3.53E06 5.77E06 3.56E06 6.50E06 4.84E06 2019 NOV Rev. 1 6.30E06 3.00E06 6.40E06 3.10E06 7.13E06 3.31E06 2019 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-60

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 4.10-7. BFN Seismic Model CDF and LERF

            % Change in CDF          % Change in LERF                            Comments Model U1      U2     U3       U1     U2        U3 Rev. 0    N/A      N/A     N/A    N/A     N/A       N/A   Initial posttransition CAFTA model.

Revision 1 was issued to reflect the F&O Closure Rev. 1 24.3% 10.9% 9.7% 15.0% 12.9% 31.6% review. The information in Tables 4.10-4 and 4.10-6 shows that, even though the BFN fire and seismic CDFs (BFN Fire, BFN Seismic) exceeded the BFN internal events CDF, the fire and seismic CDFs for BFN, and the sum of the two, are less than 1.0E-4 per reactor-year, which was the internal events mean value CDF for all BWRs used in the 2013 GEIS to estimate probability-weighted, offsite consequences from airborne, surface water, and groundwater pathways, and the resulting economic impacts from such pathways. The 2013 GEIS concluded that the contribution of other external events, such as high winds and flooding, are generally much lower than those from seismic and fire events consistent with the results obtained from individual plant examination of external events (IPEEEs) and the perspectives articulated in NUREG-1742. This conclusion is also consistent with the BFN IPEEE (BFN IPEEE), which determined that these hazards are low contributors to BFN plant risk. Furthermore, more recent analysis confirmed the other external event hazards either do not present a design-basis challenge to BFN, the challenge is adequately addressed in the PRA, or the hazard has a negligible impact and can be excluded (BFN RICT). Since performance of the BFN initial 40-to-60 year SAMA analysis, several changes have been implemented at the site that are risk-beneficial. The following list summarizes the major changes with risk-beneficial attributes for BFN:

B.5.b-related changes (10 CFR 50.155)
Implementation of NRC orders regarding FLEX and the hardened containment vent (10 CFR 50.155), which includes:
Strategies using severe accident water addition and severe accident water management
Implementation of procedures and hardware for long-term station battery power supply
NFPA 805 modifications associated with the NRC Safety Evaluation (NRC 2019); some of the more risk-beneficial enhancements include:
Installation of the Emergency High Pressure Makeup system, a manually initiated and manually controlled high pressure injection system; the normal power supply is offsite power, and the alternate supply is two independent, electrically separated supplemental diesel generators
Backup methods for providing CST refill
Increase reliability of opening the hardened wetwell vent
Incipient detection in the Auxiliary Instrumentation Rooms TVA is aware of no changes to the plant likely to occur during the subsequent period of extended operation that would adversely affect plant risk from external events. Based on the Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-61

Appendix E - Applicants Environmental Report-Operating License Renewal Stage information provided above, TVA concludes that no new and significant information exists for BFN concerning offsite consequences of severe accidents caused by external events. Accordingly, the conclusions of the 2013 GEIS on this topic are considered appropriate for the TVA SLR. New Source Term Information Based on a comparison of NRC studies from 1982 (NUREG-0773) and 1997 (NUREG/CR-6295), which included data for BFN, the 2013 GEIS concluded that the 1997 source term information indicated that the timing from dominant severe accident sequences is comparable to the analysis forming the basis of the 1996 GEIS. In most cases, the release frequencies and release fractions estimated in the 1997 study were significantly lower than previously estimated. Thus, the environmental impacts used as the basis for the 1996 GEIS (i.e., the frequency-weighted consequences) were higher than impacts that would be estimated using the 1997 source term information. Therefore, the updated estimates of offsite consequences remained within the bounds of the 1996 GEIS evaluation. The NRC approved a 14.3 percent extended power uprate (EPU) for BFN Units 1, 2, and 3 on August 14, 2017 (NRC 2017). In its review of the proposed BFN EPU, the NRC staff found that the radioactive source term under EPU conditions meets the requirements of 10 CFR Part 20, 10 CFR Part 50, Appendix I, and draft [General Design Criteria] GDC-70, and as such, the EPU is acceptable with respect to source terms. This conclusion implies that source term-based environmental impacts from severe accidents estimated for BFN after EPU would also remain within the acceptable bounds of the 1996 GEIS and 2013 GEIS evaluations. TVA is aware of no additional changes to the plant likely to occur during the subsequent period of extended operation that would adversely increase the radioactive source term. Hence, TVA concludes that no new and significant information exists for BFN concerning the effect of source term information on offsite consequences of severe accidents. Accordingly, the conclusions of the 2013 GEIS on this topic are considered appropriate for the BFN SLR. Power Uprates The 2013 GEIS considered the effects on plant risk of power uprates and concluded the impact of a power uprate on early fatalities can be gauged by considering the impact of the uprate on the LERF metric. Accordingly, the 2013 GEIS considered LERF calculated by each licensee who at that time had been granted a power uprate of greater than 10 percent. It was found that the increase in LERF ranged from a minimal impact to an increase of 30 percent (with a mean of 10.5 percent), which was characterized as small to moderate change. Taken in combination with the other information presented in the 2013 GEIS, the NRC concluded that effects of such increases on risk and environmental impacts of severe accidents would be bounded by the 1996 GEIS, which used the 95 percent upper confidence bound values as the basis for estimating offsite consequences. The NRC approved a 14.3 percent EPU for BFN Units 1, 2, and 3 on August 14, 2017 (NRC 2017). Because plant modifications associated with power uprates could change the calculated radioactive releases for BFN, TVA and the NRC evaluated the effects of the uprates (NRC 2017). The NRC staff reviewed the BFN's assessments of the internal and external events risk associated with the implementation of the proposed EPU and concluded that BFN adequately addressed the potential impacts associated with the implementation of the EPU. The NRC staff further concluded that the results of BFN's internal events risk analysis indicate that the risks associated with the proposed EPU are acceptable. Therefore, the NRC staff found the risk implications of the proposed EPU acceptable. Table 4.10-8 summarizes the results of the risk Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-62

Appendix E - Applicants Environmental Report-Operating License Renewal Stage evaluation for internal events before and after the EPU was implemented; all estimated risk metric changes are less than 10 percent. Table 4.10-8. BFN Total CDF and LERF Risk Metrics Pre-EPU Risk Post-EPU Risk Change in Risk % Change in Model (per year) (per year) (per year) Risk (per year) Unit 1 CDF 5.91E-05 6.08E-05 1.69E-06 2.9% Unit 1 LERF 7.96E-06 8.73E-06 7.74E-07 9.7% Unit 2 CDF 5.96E-05 6.14E-05 1.74E-06 2.9% Unit 2 LERF 7.99E-06 8.65E-06 6.63E-07 8.3% Unit 3 CDF 6.47E-05 6.64E-05 1.67E-06 2.6% Unit 3 LERF 7.18E-06 7.72E-06 5.45E-07 7.6% In its review of the proposed BFN EPU, the NRC staff found that estimated doses associated with BFN will comply with applicable NRC guidelines, and BFN will continue to provide sufficient safety margins with adequate defense-in-depth to address unanticipated events and to compensate for uncertainties in accident progression and analysis assumptions and parameters. On the basis of its findings, the NRC staff concluded that the BFN EPU was acceptable with respect to the radiological consequences of design basis accidents (NRC 2017). This conclusion implies that changes, if any, in offsite radiological consequences from severe accidents estimated for BFN after EPU would also remain within the acceptable bounds of the 1996 GEIS evaluation. A risk assessment performed with the post-EPU model for Maximum Extended Load Line Limit Analysis Plus (MELLLA+) implementation concluded there was no risk increase for implementing MELLLA+ (JH 2018). Higher Burnup Rates The 2013 GEIS evaluates updated information from NUREG/CR-6703 to account for the effect of future increased fuel burnup on consequences of postulated accidents as predicted in the 1996 GEIS. Future peak burnups considered in the 2013 GEIS were 70 GWd/MTU for BWRs. Average peak rod fuel burnup for each BFN unit during the terms of the extended licenses will not exceed 62 GWd/MTU (NRC 2017). Taken in combination with the other information presented in the 2013 GEIS, the NRC concluded that increased peak fuel burnup from 60 to 75 GWd/MTU for BWRs would have effects on risk and environmental impacts of severe accidents that are bounded by the 1996 GEIS. Because BFN peak fuel burnup during the subsequent period of extended operation will be within the range considered by the NRC in the 2013 GEIS for BWRs, TVA concludes that no new and significant information exists for BFN concerning the effect of peak fuel burnup on risk and environmental impacts of severe accidents. Accordingly, the conclusions of the 2013 GEIS on this topic are considered appropriate for the BFN SLR. Other Considerations In reaching its conclusions about the aggregate effect of new information on the environmental impacts and uncertainties stated in the 1996 GEIS, the NRC reviewed three developments not listed in Table 4.4-1 above. These are: Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-63

Appendix E - Applicants Environmental Report-Operating License Renewal Stage

Low power and shutdown events (2013 GEIS Section E.3.6);
Spent fuel pool accidents (2013 GEIS Section E.3.7); and
Risk coefficients from the Biological Effects of Ionizing Radiation (BEIR VII) (2013 GEIS Section E.3.8).

Based on a combination of considerations, the 2013 GEIS found that environmental impacts from the first two developments listed above would be bounded with margin by the estimate of impacts from full power reactor accidents in the 1996 GEIS. Because no plant configurations during low power and shutdown conditions and no spent fuel pool management practices are known that would distinguish BFN such that assumptions in the 2013 and 1996 GEISs would not apply, TVA concludes that no new and significant information exists for BFN concerning low power and shutdown events and spent fuel pool accidents. Accordingly, the conclusions of the 2013 GEIS on these topics are considered appropriate for the BFN SLR. The 2013 GEIS reported that use of BEIR VII risk coefficients would be consistent with the process the NRC uses to develop its standards of radiological protection, and therefore, that NRCs regulations would continue to be adequately protective of public health and safety and the environment. TVA will continue to comply with NRC radiological protection standards during the BFN subsequent period of extended operation. Accordingly, the conclusion in the 2013 GEIS on this topic is considered appropriate for the BFN SLR. The 2013 GEIS, section E.3.9.2 provides a discussion of the effect of population increases, which states the following: The 1996 GEIS estimated impacts at the mid-year of each plants license renewal period (i.e., 2030 to 2050). To adjust the impacts estimated in the NUREGs and NUREG/CRs to the mid-year of the assessed plants license renewal period, the information (i.e., exposure indexes [EIs]) in the 1996 GEIS can be used. The EIs adjust a plants airborne and economic impacts from the year 2000 to its mid-year license renewal period based on population increases. These adjustments result in anywhere from a 5 to a 30 percent increase in impacts, depending upon the plant being assessed. Given the range of uncertainty in these types of analyses, a 5 to 30 percent change is not considered significant. Therefore, the effect of increased population around the plant does not generally result in significant increases in impacts. TVA estimates that in 2055 (around the end of the license renewal period) the population within the 50-mile radius will be 28 percent higher than in 2010 based on a linear projection of the annual population growth rate. TVA assumes a 28 percent increase in population would yield an approximate 28 percent increase in total off-site dose values. Because this estimated increase is within the range determined by the NRC in the 2013 GEIS to be not significant, TVA concludes that no new and significant information exists for BFN concerning offsite dose and economic consequences resulting from population growth within the 50-mile radius surrounding the plant. Conclusions for Severe Accident Consequences: No new and significant information was identified. CDFs from internal events are between one and two orders of magnitude below the conservative value of 1x10-4 per reactor-year, which was used in the 1996 GEIS to calculate population dose estimates and determined by NRC in the 2013 GEIS to remain bounding. Even though the BFN fire and seismic CDFs exceeded the BFN internal events CDF, the fire and seismic CDFs, and the sum of the two, are less than 1x10-4 per reactor-year, which was the internal events mean value CDF for all BWRs used in Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-64

Appendix E - Applicants Environmental Report-Operating License Renewal Stage the 2013 GEIS to estimate probability-weighted, offsite consequences from airborne, surface water, and groundwater pathways, and the resulting economic impacts from such pathways. Based on a comparison of NRC studies from 1982 (NUREG-0773) and 1997 (NUREG/CR-6295), which included data for BFN, the 2013 GEIS concluded that the 1997 source term information indicated that the timing from dominant severe accident sequences is comparable to the analysis forming the basis of the 1996 GEIS. The NRC staff concluded that the BFN EPU was acceptable with respect to the radiological consequences of design basis accidents (NRC 2017). Changes, if any, in offsite radiological consequences from severe accidents estimated for BFN after EPU would also remain within the acceptable bounds of the 1996 GEIS evaluation. The 2013 GEIS evaluates updated information from NUREG/CR-6703 to account for the effect of future increased fuel burnup on consequences of postulated accidents as predicted in the 1996 GEIS. Future peak burnups considered in the 2013 GEIS were 70 GWd/MTU for BWRs. Average peak rod fuel burnup for each BFN unit during the terms of the extended licenses will not exceed 62 GWd/MTU (NRC 2017). Estimated population increase is within the range determined by the NRC in the 2013 GEIS to be not significant. Therefore, the NRC conclusion in the 1996 and 2013 GEISs that the probability-weighted consequences of atmospheric releases, fallout onto open bodies of water, releases to groundwater, and societal and economic impacts from severe accidents are small is considered appropriate for the BFN SLR and no further analysis is needed. 4.10.2.2. Consideration of SAMAs Is Not Required For BFN Because TVA performed and submitted a SAMA analysis as part of a 40-to-60-year license renewal application for BFN (TVA 2003), consistent with the second conclusion mentioned in Section 4.10.2, it is not required to submit a SAMA analysis as part of any SLR application. Instead, the environmental report must contain any new and significant information pertinent to the previous SAMA analysis of which the applicant is aware. The assessment process used by TVA in its review for new and significant information related to the second conclusion was developed by the NEI on behalf of industry and has been reviewed by the NRC staff. It is referred to herein as the NEI model approach, and it provides a multi-stage assessment process for determining whether or not there is any new and significant information relevant to a previous SAMA analysis. If information that is both new and significant is determined to exist, an updated SAMA assessment would follow (NEI 2019). The first stage of the process uses probabilistic risk assessment insights and/or risk model quantifications to estimate the percent of maximum benefit (MB) reduction associated with (1) unimplemented final plant-specific SAMAs for the analyzed plant and (2) those SAMAs identified as potentially cost beneficial for other industry plants that have been determined to be applicable to the analyzed plant. Consistent with the NRCs rulings that new and significant information is that which "presents 'a seriously different picture' of the environmental impacts compared to the previously issued final environmental impact statement, (NextEra 2016), the first stage examines whether such potentially cost-beneficial SAMAs might reduce severe accident risk substantially. If it can be demonstrated that none of the SAMAs being evaluated can reduce the MB by 50 percent or more, then the applicant may document the conclusion that there is no new and significant information relevant to the previous SAMA analysis. In the event that any SAMAs evaluated in Stage 1 are shown to reduce the MB by 50 percent or more, Stage 2 of the NEI model approach will be used to develop an updated averted cost-risk estimate for implementing those SAMAs. Two options are provided for performing the Stage 2 assessment: Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-65

Appendix E - Applicants Environmental Report-Operating License Renewal Stage

Option 1: Perform a simplified (conservative) Level 3 model update to support the update of the averted cost-risk calculations.
Option 2: Perform a full Level 3 model update to support the update of the averted cost-risk calculations.

In the event that refinements to the averted cost-risk calculations related to the Stage 2 assessment demonstrate that the MB reduction is less than 50 percent for all SAMAs, then the applicant may document the conclusion that there is no new and significant information relevant to the previous SAMA analysis. If the results of the Stage 2 assessment indicate that one or more SAMAs reduce the MB by 50 percent or more, then the impact of new information on those SAMAs is further assessed to determine whether it is significant. New information will be deemed potentially significant to the extent it results in the identification of an unimplemented SAMA that reduces the MB by 50 percent or more. The final determination of significance will be made in the Stage 3 assessment, which consists of performing a cost-benefit analysis for unimplemented SAMAs that reduce the MB by 50 percent or more (i.e., potentially significant SAMAs). If such SAMAs are found to be potentially cost-beneficial, then they indicate the existence of new and significant information relevant to the previous SAMA analysis. Figure 4.10-1 provides a flowchart of the 3-stage assessment process. For BFN, a Stage 1 assessment was completed. A total of 188 BFN unimplemented Phase 2 SAMAs (38) and applicable industry SAMAs (150) were identified for Stage 1 evaluation. First, the following pre-screening criteria were applied, which reduced to 36 the number of SAMAs for which quantification of CDFs and Level 2 release category frequencies was needed:

1. Not Applicable: If a SAMA candidate does not apply to the plant design, it may be excluded from further review.

2. Already Implemented: If a SAMA candidate has already been implemented at the plant, or its benefit achieved by other means, it may be excluded from further review.

3. Combined: If a SAMA candidate is similar in nature and can be combined with another SAMA candidate to develop a more comprehensive or plant-specific SAMA candidate, only the combined SAMA candidate is retained.

Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-66

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Source: (NEI 2019) Figure 4.10-1. SAMA New & Significant Assessment Flowchart BFN Risk Models The NEI model approach indicates that the plant risk models that have been developed or updated since the time of the original SAMA analysis constitute new information and should be considered as part of the significance assessment. The original BFN SAMA analysis (TVA 2003) used an Internal Events PRA that has subsequently been replaced, and the potential effects of external events were evaluated through sensitivity studies that applied multipliers. The BFN risk models that are currently available are the Internal Events model (including internal flooding), the Fire PRA, and the Seismic PRA, all of which are new information elements that are necessary to include in this assessment. There are no plant or model changes that have not been incorporated in the PRA models that could significantly impact the model results. No forthcoming model revisions or updated modeling techniques have been identified for BFN that would significantly impact the SAMA results or alter the conclusions of this analysis. In accordance with the ASME/ANS PRA Standard (ASME/ANS 2009), based on the analysis of external hazards for BFN Units 1, 2, and 3, no additional external hazards need to be added to the existing PRA model. The other external event hazards either do not present a design-basis challenge to BFN, the challenge is adequately addressed in the PRA, or the hazard has a negligible impact and can be excluded (BFN RICT). The implication of this conclusion is that the Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-67

Appendix E - Applicants Environmental Report-Operating License Renewal Stage reduction in risk resulting from SAMA implementation will be small for non-fire/non-seismic external hazards relative to overall plant risk. Hence, the Stage 1 evaluation process does not require risk reduction estimates to be provided for non-fire/non-seismic external hazards, and they are not considered further in this analysis. The SAMA analysis was performed using the most recent BFN one-top multi-hazard model (OTMHM) (Level 1 and Level 2) for each unit, which combines the Internal Events model (including internal flooding), the Fire PRA, and the Seismic PRA. Evaluation Process For each unscreened SAMA, the Stage 1 analysis requires generation of an estimated percent reduction in the CDF and Level 2 release category frequencies. Because the averted cost-risks of most SAMAs are proportional to the changes in CDF and Level 2 release category frequencies, if it can be demonstrated that a SAMA would reduce neither the CDF nor any release category frequency by 50 percent or more, the SAMA cannot correlate to an averted cost-risk that equals or exceeds 50 percent of the maximum averted cost risk (i.e., SAMA implementation cannot result in a significant change in plant risk). Exceptions may exist for SAMAs that do not impact the Level 1 or Level 2 analyses but do impact the Level 3 analysis. An example would be a SAMA that provides a means of spraying a break point in the containment in order to reduce the magnitude of release from containment following a severe accident. In general, it would be necessary to treat SAMAs of this type separately in the Stage 1 assessment for the potential significance of new information. However, for BFN, no such SAMAs were identified. Table 4.10-9 presents the 36 SAMAs that were not qualitatively screened. The first column presents the number assigned to each SAMA for tracking purposes. The fourth column identifies the plant from which the SAMA originated (i.e., BFN or an industry SAMA); the third column identifies the SAMA number from the source plant; the fourth column provides a description of the SAMA. The fifth column provides a description of how the SAMA analysis was quantified. An assessment of the reduction in the CDF and Level 2 release category frequencies was made for each unscreened SAMA, as reported for BFN in Table 4.10-10; the maximum reductions among the three units are shown. If the CDF and all Level 2 release category reductions for a SAMA was found to be less than 50 percent, it was concluded that the SAMA is not significant. None of the 36 SAMAs for which quantifications were performed reduced the MB for BFN by 50 percent or more. Therefore, it was concluded that no new and significant information relevant to the BFN SAMA analysis exists, and no further analysis is needed. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-68

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 4.10-9. SAMAs Quantitatively Assessed in Stage 1 SLR Source SAMA Ph. II Reference SAMA Title Disposition Comment Number SAMA Source Number A bounding analysis was performed by eliminating failure of the safety 3 B03 Improve Hardware Reliability Of SRVs Browns Ferry relief valves (SRVs) and related equipment by setting their failure events to zero. Station Blackout: Improve Reliability Of One A bounding analysis was performed by setting all diesel generator fail 4 B04 Browns Ferry Diesel to start events (including common cause) to zero. A bounding analysis was performed by eliminating Standby Liquid Control (SLC) failure by setting failure events related to SLC (including 6 B06 Automatic Initiation Of SLC (ATWS) Browns Ferry operator actions, pump failures, accumulator failures, valve failures, testing/maintenance events, and common cause failures) to zero. A bounding analysis was performed by eliminating Standby Liquid Improve Hardware Reliability Of SLC Control (SLC) failure by setting failure events related to SLC (including 7 B07 Browns Ferry (ATWS) operator actions, pump failures, accumulator failures, valve failures, testing/maintenance events, and common cause failures) to zero. Decrease Frequency Of Interfacing A bounding analysis was performed by eliminating ISLOCA events by 8 B08A Browns Ferry Systems LOCA - Hardware setting events ISLOCA initiators to zero. A bounding analysis was performed by eliminating failure of SPC by setting failure events related to SPC (including operator actions, valve 14 B13 Improve Suppression Pool Cooling (ATWS) Browns Ferry failures, pump failures, testing/maintenance events, and common cause failures) to zero. A bounding analysis was performed by eliminating failure of SPC by setting failure events related to SPC (including operator actions, valve 15 B14 Reduce Frequency Of Excessive LOCA Browns Ferry failures, pump failures, testing/maintenance events, and common cause failures) to zero. A bounding analysis was performed by eliminating all Internal Flooding Implement Internal Flood Prevention and 17 B18 Browns Ferry scenarios by setting the failure of operators to isolate internal floods Mitigation Enhancement (basic events HFA_0_519FLOOD and HFA_0_519FLOODM) to zero. A bounding analysis was performed by eliminating failure of RHR and Replace ECCS pump motor with air-cooled 18 G02 Browns Ferry Core Spray HVAC equipment by setting the fan cooler failure events motors. (including common cause failure) to zero. A bounding analysis was performed by eliminating failure of RHRSW Improved ability to cool the residual heat and RCW equipment by setting failure events related to RHRSW and 21 G06 Browns Ferry removal heat exchangers RCW (including operator actions, valve failures, pump failures, testing/maintenance events, and common cause failures) to zero. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-69

Appendix E - Applicants Environmental Report-Operating License Renewal Stage SLR Source SAMA Ph. II Reference SAMA Title Disposition Comment Number SAMA Source Number A bounding analysis was performed by eliminating failure of drywell spray by setting failure events related to drywell spray (including 26 G11 Install a passive containment spray system. Browns Ferry operator actions, valve failures, pump failures, testing/maintenance events, and common cause failures) to zero. Develop procedures to repair or replace A bounding analysis was performed by eliminating the failure of the 32 G14 Browns Ferry failed 4 kV breakers. USSTs and related failure events by setting them to zero. Use Fire Protection System as a back-up A bounding analysis was performed by eliminating the failure of diesel 33 G15 Browns Ferry source for diesel cooling. cooling by setting events related to diesel cooling to zero. Procedure to instruct operators to trip A bounding analysis was performed by eliminating failure of RHR and 35 G17 unneeded RHR/CS pumps on loss of room Browns Ferry Core Spray HVAC equipment by setting the fan cooler failure events ventilation. (including common cause failure) to zero. A bounding analysis was performed by eliminating Standby Liquid Increase the SRV reseat reliability. Control (SLC) failure by setting failure events related to SLC (including 36 G18 Reduced risk of dilution of boron due to Browns Ferry operator actions, pump failures, accumulator failures, valve failures, SRV failure to reseat after SLC injection. testing/maintenance events, and common cause failures) to zero. Providing the MCR with the capability to Brunswick A bounding analysis was performed by eliminating failure of loss of perform the 480V AC substation cross-tie offsite power initiators. can potentially improve operator reliability. Modifications which would allow the action 41 11 to be performed entirely within the MCR would reduce the time required to perform the action and simplify the manipulations required for the action. Installation of a CRD cross-tie is a potential Brunswick A bounding analysis was performed by eliminating the failure of the 42 13 method of reducing the core damage CRD system by setting the system logic top gates to zero. contribution attributed to CRD mitigation. Diverse EDG HVAC Logic: The backup Brunswick A bounding analysis was performed by eliminating the failure of DG logic would reduce the reliance on HVAC by setting the DG HVAC flag and ventilation fan failure events 43 15 operators to perform a fan start on loss of to zero. the current automatic actuation logic. Brunswick A bounding analysis was performed by setting all diesel generator fail 44 16 Diverse swing DG Air compressor to start events (including common cause) to zero. Provide alternate feeds to panels supplied Brunswick A bounding analysis was performed by eliminating the failure of DC 45 17 only by DC Bus 2A-1 buses by setting the DC bus and breaker failure events to zero. Brunswick A bounding analysis was performed by eliminating loss of plant air Provide an alternate means of supplying the 47 19 initiating events (%1LOPA, %2LOPA, and %3LOPA) and air instrument air header compressor failures. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-70

Appendix E - Applicants Environmental Report-Operating License Renewal Stage SLR Source SAMA Ph. II Reference SAMA Title Disposition Comment Number SAMA Source Number Brunswick A bounding analysis was performed by eliminating failure of battery Proceduralize battery charger high voltage 49 25 chargers by setting the battery charger failure events (including shutdown circuit inhibit common cause) to zero. Brunswick A bounding analysis was performed by reducing the frequency of all 51 30 Improve alternate shutdown panel ASD scenarios by 50%. Add automatic fire suppression system: Brunswick The change in plant risk was evaluated from adding automatic fire The results of the BSEP fire model indicate suppression to fire compartment (FC) 05 for Unit 1, FC 09 for Unit 2, that 13.1 percent of the fire risk is related to and FC 13 for Unit 3. Other top-contributing FCs either already have fires in the 20 level of the Reactor building automatic suppression or incipient detection installed or it is not North Central and North West, 53.3 percent appropriate to install automatic suppression. A bounding analysis was 53 32 from the main control room, and 3.0 percent performed by applying a 5% factor (the nominal failure rate of an from the switchgear rooms. These rooms do automatic suppression system) the mitigable FC 05 (Unit 1), FC 09 not have automatic suppression systems (Unit 2), and FC 13 (Unit 3) fire ignition frequencies (source-only and and installation of these types of systems non-full-room-burn high-energy arcing fault (HEAF) fire scenarios were has been suggested as a potential means not included in the recovery text file because fire suppression would of reducing plant risk. not prevent those fire scenarios). Supplemental power supplies for offsite Brunswick A bounding analysis was performed by eliminating failure of loss of 54 34 power recovery after battery depletion offsite power initiators. during SBO Protect critical fire targets: This SAMA Nine Mile A bounding analysis was performed by setting the top fire ignition would protect critical fire targets from Point frequency (based on RRW from CDF and LERF) to zero. dominant fire sources by moving some of 57 U1-210 the targets or sources to improve separation and/or providing cable tray protection (e.g., barrier board). Enhance alternate injection reliability: The Monticello A bounding analysis was performed by eliminating failure of RHRSW capability exists at MNGP to provide flow and RCW equipment by setting failure events related to RHRSW and from the RHRSW and FSW systems to the RCW (including operator actions, valve failures, pump failures, RHR system; however, the reliability of the testing/maintenance events, and common cause failures) to zero. 74 11 cross-tie could potentially be improved by including the cross-tie valves in the maintenance program so that the operability of the valves is monitored and tested. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-71

Appendix E - Applicants Environmental Report-Operating License Renewal Stage SLR Source SAMA Ph. II Reference SAMA Title Disposition Comment Number SAMA Source Number Passive Overpressure Relief: This SAMA Monticello A bounding analysis was performed by setting operator actions for would prevent catastrophic failure of the failing to use hardened wetwell vent for long-term decay heat removal containment. The current Torus Hard Pipe to zero. Vent includes a rupture disk beyond an isolation valve; however, an alternate path 76 16 to the Torus Hard Pipe Vent could be made in the wetwell using a rupture disk that would fail at about 60 psid. Alternatively, the containment vent valves could be changed so that they "fail open" on loss of support. Enhance the ASDS panel to include Monticello A bounding analysis was performed by reducing the frequency of all 78 39 additional system controls ASD scenarios by 50%. Add an emergency level control system to Monticello A bounding analysis was performed by eliminating loss of feedwater the hotwell: This system would actuate on initiating events and operator actions for failure to control hotwell level. low level in the main condenser (well 79 40 outside of the normal operating range) and automatically provide makeup so that the feedwater (FW)/Condensate system would have a long-term suction source. Oyster Creek A bounding analysis was performed by applying a 50% reduction 96 124 Block wall 53 Reinforcement factor to all seismic fragilities with a RRW exceeding 1.005. Oyster Creek A bounding analysis was performed by applying a 50% reduction 99 138 Protect Transformers factor to the main transformer, the USSTs, switchyard-related LOOPs, and the switchyard fire scenarios. Modify portable station diesel generator to Susquehanna A bounding analysis was performed by eliminating failure of battery 104 5 automatically align to 125 V DC battery 1&2 chargers by setting the battery charger failure events (including chargers. common cause) to zero. Duane Arnold A bounding analysis was performed by eliminating Standby Liquid Increase boron concentration or enrichment Control (SLC) failure by setting failure events related to SLC (including 115 117 in the standby liquid control (SLC) system. operator actions, pump failures, accumulator failures, valve failures, testing/maintenance events, and common cause failures) to zero. Install additional physical barriers to limit Hope Creek A bounding analysis was performed by eliminating multi-compartment 129 32 dispersion of fuel oil from diesel generator fire scenarios by setting multi-compartment (MCA*) fire ignition rooms. frequencies to zero. LaSalle A bounding analysis was performed by eliminating Standby Liquid Control (SLC) failure by setting failure events related to SLC (including 166 21 Install automatic ATWS level control system operator actions, pump failures, accumulator failures, valve failures, testing/maintenance events, and common cause failures) to zero Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-72

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 4.10-10. Percent Reduction for SAMAs Quantitatively Assessed in Stage 1 SLR SAMA Number CDF L2 total LERF H-I H-L M-E M-I L-I LL-I 3 -0.1% -0.1% 0.0% -0.2% 0.0% 0.0% -0.1% -2.8% -0.3% 4 -1.4% -1.4% -0.1% -1.3% 0.0% 0.0% -4.1% -0.3% -0.7% 6 -0.1% -0.2% -0.3% 0.0% 0.0% -42.2% 0.0% 0.0% 0.0% 7 -0.1% -0.2% -0.3% 0.0% 0.0% -42.2% 0.0% 0.0% 0.0% 8 -0.5% -0.5% -2.2% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 14 -3.9% -2.6% -0.7% -3.6% 0.0% -3.9% -0.9% -1.9% -4.5% 15 -0.1% 0.0% 0.0% 0.0% 0.0% -2.2% 0.0% -0.5% 0.0% 17 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 18 -0.4% -0.4% 0.0% -1.4% 0.0% -0.6% -0.2% -0.6% -0.6% 21 -0.7% -0.8% -0.1% -1.6% -0.4% 0.0% -2.3% -1.5% 0.0% 26 -1.1% -1.1% -0.1% -2.8% -0.1% -2.5% -0.7% -1.9% -1.6% 32 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 33 -1.5% -1.6% -0.2% -4.6% -0.4% 0.0% -3.4% -1.8% -0.3% 35 -0.4% -0.4% 0.0% -1.4% 0.0% -0.6% -0.2% -0.6% -0.6% 36 -0.1% -0.2% -0.3% 0.0% 0.0% -42.2% 0.0% 0.0% 0.0% 41 0.0% 0.0% 0.0% 0.0% 0.0% -0.2% 0.0% 0.0% 0.0% 42 -0.6% -0.8% -1.7% 0.0% -11.4% 0.0% -0.3% -0.6% 0.0% 43 -4.1% -4.9% -0.5% -4.9% -0.2% 0.0% -11.1% -1.9% -2.9% 44 -1.4% -1.4% -0.1% -1.3% 0.0% 0.0% -4.1% -0.3% -0.7% 45 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 47 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 49 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 51 -5.2% -5.7% -0.1% -0.2% 0.0% 0.0% -1.4% 0.0% -13.6% 53 -1.6% -1.5% -0.5% -3.7% 0.0% 0.0% -2.8% 0.0% -0.1% 54 0.0% 0.0% 0.0% 0.0% 0.0% -0.2% 0.0% 0.0% 0.0% 57 -1.0% -1.1% -0.4% -2.9% 0.0% 0.0% -2.9% -0.5% -0.1% 74 -0.7% -0.8% -0.1% -1.6% -0.4% 0.0% -2.3% -1.5% 0.0% 76 -0.6% -1.0% -1.7% -0.9% -16.6% 0.0% -0.3% -0.2% 0.0% 78 -5.2% -5.7% -0.1% -0.2% 0.0% 0.0% -1.4% 0.0% -13.6% 79 -0.3% -0.1% -0.2% 0.0% -0.4% -3.2% 0.0% 0.0% 0.0% 96 -3.5% -3.6% -7.2% -1.7% -32.5% 0.0% -4.7% -0.1% 0.0% 99 -1.7% -1.5% -0.7% -1.3% 0.0% -0.1% -2.1% -1.6% -1.5% 104 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 115 -0.1% -0.2% -0.3% 0.0% 0.0% -42.2% 0.0% 0.0% 0.0% 129 -2.3% -2.5% -0.2% -3.0% 0.0% 0.0% -1.5% 0.0% -4.9% 166 -0.1% -0.2% -0.3% 0.0% 0.0% -42.2% 0.0% 0.0% 0.0% Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-73

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.11. Environmental Justice Table 4.11-1 lists the environmental justice issue identified in the GEIS and the GEIS findings. This issue was reviewed with respect to impacts associated with the BFN SLR. Table 4.11-1. Environmental Justice Issues and the NRC 2013 GEIS Findings SLR-ER Issue GEIS Finding Section Minority and low- (Category 2) Impacts to minority and low-income populations 3.10.1; income populations and subsistence consumption resulting from continued 3.10.2; operations and refurbishment associated with license renewal 4.11.1 will be addressed in plant-specific reviews. See NRC Policy Statement on the Treatment of Environmental Justice Matters in NRC Regulatory and Licensing Actions (69 FR 52040, August 24, 2004). Source: (NRC 2013) Minority and Low-Income Populations In the 2013 GEIS, the NRC designated impacts to minority and low-income populations as a Category 2 issue, requiring plant-specific analysis, because the magnitude of the potential impacts from the renewal of the plants operating license could not be determined generically (NRC 2013). The NRC requires an assessment of the potential impacts on minority and low-income populations, including populations engaged in subsistence-like living, from continued operation of BFN and any planned refurbishment activities. BFN has no plans for refurbishment. See the NRC's policy statement on the treatment of environmental justice matters in the NRC regulatory and licensing actions (69 FR 52040; August 24, 2004). Section 3.10 describes the environmental justice analyses for minority, low-income, and subsistence-like populations within a 50-mile radius of BFN. The other sections in Chapter 4 evaluate the impacts of continued operation of BFN on the environment, including the population within a 50-mile radius. All activities associated with the continued operation have been determined to have SMALL or non-adverse impacts during the subsequent period of extended operation. Therefore, high or adverse impacts to the general human population will not occur. Section 3.10 identifies the locations of minority and low-income populations as defined by the NRC in the 2013 GEIS. Section 3.10 also describes the search for subsistence-like populations near BFN, of which none were found. The figures accompanying Section 3.10 show the locations of minority and low-income populations within 50 miles of BFN. None of those locations, when considered in the context of impact pathways described in Chapter 4, is expected to be disproportionately impacted. Each location is sufficiently distant from BFN to not present a focal point of impacts that are disproportionate compared to other locations. Hence, TVA concludes that disproportionately high and adverse impacts to minority and low-income populations will not occur. Therefore, impacts to such populations are SMALL, and no mitigation is warranted. 4.12. Waste Management Table 4.12-1 lists the waste management issues identified in the GEIS and the GEIS findings. Each of these issues was reviewed with respect to impacts associated with the BFN SLR. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-74

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 4.12-1. Waste Management Issues and the NRC 2013 GEIS Findings SLR-ER Issues GEIS Finding Section Low-level waste storage SMALL (Category 1). The comprehensive regulatory controls 2.2.4.5; and disposal that are in place and the low public doses being achieved at 4.12.1 reactors ensure that the radiological impacts to the environment would remain small during the license renewal term. Onsite storage of spent SMALL (Category 1). The expected increase in the volume of 2.2.4.4; nuclear fuel spent nuclear fuel from an additional 20 years of operation can 4.12.2 be safely accommodated onsite during the license renewal term with small environmental impacts through dry or pool storage at all plants. For the period after the licensed life for reactor operations, the impacts of onsite storage of spent nuclear fuel during the continued storage period are discussed in NUREG-2157 and as stated in §51.23(b), shall be deemed incorporated into this issue. Offsite radiological (Uncertain). For the high-level waste and spent-fuel disposal 4.12.3 impacts of spent component of the fuel cycle, the USEPA established a dose nuclear fuel and high- limit of 0.15 mSv (15 millirem) per year for the first 10,000 level waste disposal years and 1.0 mSv (100 millirem) per year between 10,000 years and 1 million years for offsite releases of radionuclides at the proposed repository at Yucca Mountain, Nevada. The NRC concludes that the impacts would not be sufficiently large to require the National Environmental Policy Act (NEPA) conclusion, for any plant, that the option of extended operation under 10 CFR part 54 should be eliminated. Accordingly, while the NRC has not assigned a single level of significance for the impacts of spent fuel and high level waste disposal, this issue is considered Category 1. Mixed waste storage SMALL (Category 1). The comprehensive regulatory controls 2.2.4; and disposal and the facilities and procedures that are in place ensure 4.12.4 proper handling and storage, as well as negligible doses and exposure to toxic materials for the public and the environment at all plants. License renewal would not increase the small, continuing risk to human health and the environment posed by mixed waste at all plants. The radiological and non-radiological environmental impacts of long-term disposal of mixed waste from any individual plant at licensed sites are small. Nonradioactive waste SMALL (Category 1). No changes to systems that generate 2.2.5; storage and disposal nonradioactive waste are anticipated during the license 4.12.5 renewal term. Facilities and procedures are in place to ensure continued proper handling, storage, and disposal, as well as negligible exposure to toxic materials for the public and the environment at all plants. Source: (NRC 2013) Section 2.2.4 describes radioactive wastes, including spent nuclear fuel, that are generated during plant operations. Section 2.2.5 describes the nonradioactive wastes generated during plant operations. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-75

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.12.1. Low-Level Waste Storage and Disposal In the 2013 GEIS, the NRC considered the generation of low-level radioactive waste (LLRW) from normal nuclear plant operation, including routine maintenance and cleaning (NRC 2013). The NRC determined that the anticipated LLRW generated and managed during a nuclear power plants license renewal term would not result in significant environmental impacts. Additionally, the NRC concluded that existing regulatory controls and low public doses would ensure radiological impacts on the environment would remain SMALL during a license renewal term and that non-radiological impacts on air and water would be negligible. The NRC concluded that the radiological and non-radiological environmental impacts of long-term disposal of LLRW generated from individual nuclear plants would be SMALL and that sufficient disposal capacity for LLRW from decommissioning activities would be available as needed. Section 2.2.4.5 of this ER describes the LLRW waste management system at BFN. At BFN, radioactive waste programs and controls, established in accordance with the NRC regulations, are based upon waste classifications. Long-term plans for radioactive waste generated during the subsequent period of extended operation will be consistent with existing plans that involve LLRW being either stored onsite in existing structures, shipped to an offsite licensed facility for processing, or sent directly for disposal at an offsite licensed disposal facility. As discussed in Section 2.2.4.5, BFN has sufficient existing onsite capability to temporarily store all generated LLRW onsite in accordance with the NRC regulations. No additional construction of onsite storage facilities will be necessary for LLRW storage during the subsequent period of extended operation. Additionally, BFN has contracts in place to ship LLRW offsite for disposal at two licensed facilities (EnergySolutions and Waste Control Specialists, LLC) and anticipates continued access to licensed LLRW processing and disposal facilities during the subsequent period of extended operation. LLRW will continue to be processed and packaged for shipping, and subsequently shipped by truck on state and federal highways in accordance with applicable Department of Transportation (DOT) regulations. BFNs 2022 Annual Radiological Environmental Operating Report documented that all doses to the public were within ALARA criteria established by 10 CFR Part 50, Appendix I. Sampling within the vicinity of BFN included air, water, food crops, soil, fish, and shoreline sediment along with measurements of direct radiation levels. Measured radiation levels were compared to measurements taken at control locations, located outside the near vicinity of BFN, and to preoperational levels, measured at BFN prior to operation of BFN in 1973. No detectable increase in background direct radiation levels was identified in areas surrounding BFN. Further, trace quantities of cesium-137 and low levels of gross beta activity detected in soil and drinking water samples, respectively, were attributable to natural background radioactivity, as were activities and levels found in fish, local crops, and air particulates. Measured levels of radioactivity in the environmental samples were typical of background levels, thus it was concluded that there was no identified increase in exposure to members of the public attributable to operations at BFN (TVA 2023a). As discussed in the 2013 GEIS, nonradioactive waste storage and disposal, the radiological impacts from disposal of waste generated during a license renewal term has the potential to increase as long-lived radionuclides accumulate at disposal facilities (NRC 2013). However, the disposal facilities will be licensed, which means the facility will have a design including design capacity and conditions of operation to minimize environmental impacts. BFN will continue managing and storing LLRW onsite in accordance with the NRC regulations and disposing of LLRW in licensed treatment and disposal facilities during the subsequent Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-76

Appendix E - Applicants Environmental Report-Operating License Renewal Stage period of extended operation. During the subsequent period of extended operation, BFN will remain in compliance with the comprehensive regulatory controls and continue to utilize licensed treatment and disposal facilities. TVAs recent annual radiological environmental operating report indicated that doses to members of the public are currently well within ALARA criteria established by 10 CFR Part 50, Appendix I. Additionally, no adverse levels of radiation and radioactive materials have been detected in publicly accessible areas. No N&SI was identified. Therefore, TVA finds that impacts from LLRW waste storage and disposal for the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.12-1). 4.12.2. Onsite Storage of Spent Nuclear Fuel In 2014, the NRC amended GEIS 2013 Table B-1 with the Continued Storage of Spent Nuclear Fuel (10 CFR Part 51) or the Continued Storage Rule (79 FR 56238; September 19, 2014). The 2014 Continued Storage Rule codified NRCs determination that impacts from onsite storage of spent fuel during the license renewal term would be SMALL. Although the NRC issuance of SECY-21-0066, "Rulemaking Plan for Renewing Nuclear Power Plant Operating Licenses - Environmental Review" in February 2022 impacted the SLR of six nuclear plants, the 2014 Continued Storage Rule was not overturned by the NRCs determination. The 2014 Continued Storage Rule explicitly considered SLRs. As developed in the 2014 Continued Storage Rule, the 2013 GEIS considered the licensed life for operation of a reactor as the term of the license to operate a reactor: assuming a 40-year original license with up to two 20-year license extensions per reactor or a total of 80 years. The 2014 Continued Storage Rule explains further that, The Commissions regulations provide that renewed operating licenses may be subsequently renewedThe GEIS [2013] assumes two renewals in evaluating potential environmental impacts (NUREG-2157, Volume 1) (NRC 2014). Section 2.2.4.4 of this ER describes the onsite spent nuclear storage system at BFN. In addition, TVA did not identify issues concerning onsite storage of spent nuclear fuel in the first license renewal period and does not anticipate issues during the subsequent period of extended operation. Storage containers comply with federal requirements and compliance will continue during the subsequent period of extended operation. The NRC submitted a request for additional information during the initial license renewal reviews with respect to the need for a Spent Fuel Pool Neutron Absorber Aging Management Program. BFN provided justification that an Aging Management Program was not required. The NRC documented the acceptance of this position in the BFN License Renewal Safety Evaluation Report (NRC 2006). During a 20-year extension for the three BFN units, it is assumed that a fuel reload will be required every two years (10 reloads) and each reload will include 308 fuel bundles for each of the three units (924 fuel bundles per reload), resulting in total of 9,240 fuel bundles generated. Each dry spent fuel storage cask holds 89 fuel bundles; therefore, 104 dry spent fuel storage casks will be needed for onsite spent fuel storage. TVA has concluded that an additional ISFSI pad will be needed for the storage of the additional casks prior to or during the subsequent period of extended operation if TVA cannot transport spent fuel to a federally approved interim or long-term storage site. Furthermore, the impacts associated with this expansion will also be assessed under a licensing process separate from that of BFN Units 1, 2, and 3 RFOLs. Therefore, TVA concluded that impacts associated with onsite storage of spent fuel are SMALL. Therefore, with no N&SI to change the conclusion of the first license renewal and pursuant to NRCs generic analysis and codified conclusion, the impacts of onsite storage of spent fuel Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-77

Appendix E - Applicants Environmental Report-Operating License Renewal Stage during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.12-1). 4.12.3. Offsite Radiological Impacts of Spent Nuclear Fuel and High-Level Waste Disposal In 2014, the NRC amended GEIS 2013 Table B-1 with the Continued Storage of Spent Nuclear Fuel (10 CFR Part 51) or the Continued Storage Rule (79 FR 56238; September 19, 2014). The 2014 Continued Storage Rule referenced the USEPAs established dose limit for offsite releases from a long-term geologic repository of 0.15 millisievert (mSv; 15 mrem) per year for the first 10,000 years of storage, and 1.0 mSv (100 mrem) through the remainder of the next million years. NRC concluded that offsite impacts would not be sufficiently large to require the NEPA conclusion that the option of extended operation of any nuclear plant under 10 CFR Part 54 should be eliminated. The 2014 Continued Storage Rule codified NRCs determination to classify the offsite radiological impacts of spent nuclear fuel and high-level waste disposal as a Category 1 issue with no impact level assigned. As noted in Section 4.12.2, the 2014 Continued Storage Rule was not overturned by the 2022 NRC determination on SLRs. Further, the 2014 Continued Storage Rule explicitly considered SLRs with up to two 20-year license extensions per reactor or a total of 80 years. In addition, TVA did not identify issues concerning offsite radiological impacts from onsite storage of spent nuclear fuel. Storage and transport containers comply with federal requirements and compliance will continue during the subsequent period of extended operation. While the ultimate offsite disposal or interim storage is a separate licensing action and outside the scope of license renewal, the GEIS only assesses the consideration of an ultimate repository site for the disposal of spent nuclear fuel. Since the issuance of the BFN renewed operating licenses, the NRC has received two applications for Consolidated Interim Storage Facilities, one in 2016 and one in 2017. These facilities were reviewed as applications for a specific license under 10 CFR Part 72 and, as proposed, are not co-located with a power reactor. A license was issued to Interim Storage Partners, LLC in September 2021 to construct and operate a consolidated interim storage facility in Andrews County, Texas. In July 2022, the NRC issued its final EIS for Holtec Internationals consolidated interim storage facility to be located southeastern New Mexico. Although progress with these two facilities provides new information, the new information is not significant with respect to TVAs SLR because interim storage remains a separate licensing action. Therefore, pursuant to NRCs generic analysis and codified conclusion, and coupled with TVAs analysis of N&SI, the offsite radiological impacts of spent nuclear fuel and high-level waste disposal during BFNs subsequent period of extended operation are SMALL. 4.12.4. Mixed Waste Storage and Disposal In the 2013 GEIS, the NRC reviewed mixed waste storage and disposal (NRC 2013). Considering the guidance for handling, storing, and disposing of mixed waste, the NRC determined that the comprehensive regulatory controls along with the facilities and procedures in place at nuclear power plants ensure that mixed waste is properly handled and stored and that doses to and exposure to toxic materials by the public and the environment are negligible at all plants. Further, the NRC review found that license renewal would not increase the small but continuing risk to human health and the environment posed by mixed waste at all plants and that radiological and non-radiological environmental impacts from long-term disposal of mixed waste from any individual plant at licensed sites were minimal (NRC 2013). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-78

Appendix E - Applicants Environmental Report-Operating License Renewal Stage As discussed in Section 2.2.4 of this ER, BFN has established radiological waste programs and controls to manage radioactive waste onsite in accordance with the NRC regulations and to dispose of mixed waste in the NRC-licensed and USEPA-permitted treatment and disposal facilities during the subsequent period of extended operation. As discussed in Section 2.2.4.5, BFN infrequently generates small quantities of mixed waste (i.e., waste that contains both radioactive material and Toxic Substances Control Act regulated items (e.g., PCBs, asbestos), and or Resource Conservation and Recovery Act (RCRA)-regulated items (e.g., listed or exhibits characteristic of hazardous wastes). In accordance with TVA procedures, mixed waste generated at BFN is collected and stored based on its hazardous constituents and applicable RCRA waste storage time limits before being shipped offsite by trained and certified personnel to a permitted/licensed vendor. Environmental personnel ensure all applicable USEPA, state environmental agency, and DOT regulations are met. As indicated in Chapter 9, based on a review of BFNs compliance history, BFN has not received any violations for hazardous waste management during the past 5 years. ADEM inspects BFN for compliance with state and county waste management regulations. TVA anticipates that it will continue to have access to the NRC-licensed and USEPA-permitted processing and disposal facilities during the subsequent period of extended operation. This is consistent with the 2013 GEIS conclusion, LLRW storage and disposal, specific to the greater disposal capacity needed for decommissioning that sufficient LLRW disposal capacity will be available. As indicated in the 2013 GEIS, license renewal would not increase the SMALL but continuing risk to human health and the environment posed by mixed waste at all plants and that radiological and non-radiological environmental impacts from the long-term disposal of mixed waste from any individual plant at licensed sites were minimal (NRC 2013). The SMALL risk will continue during the subsequent period of extended operation. Although the radiological and non-radiological impacts from disposal of mixed waste generated during the subsequent period of extended operation has the potential to increase as long-lived radionuclides and toxic metals accumulate at disposal facilities, these facilities will be permitted and licensed, and therefore will be designed to minimize environmental impacts. Based on the very small quantities of mixed waste generated at BFN, a minimal impact (i.e., SMALL) will be anticipated during the subsequent period of extended operation. BFNs continued compliance with comprehensive regulatory controls and use of the NRC-licensed and USEPA-permitted treatment and disposal facilities will ensure the continued SMALL impact from the handling, storage, and disposal of mixed waste during the subsequent period of extended operation. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. Further, negligible doses and exposure for the public and the environment provide a SMALL impact. SLR will not increase the SMALL continuing risk to human health and the environment posed by mixed waste at BFN. As discussed in the 2013 GEIS, the radiological and non-radiological environmental impacts of long-term disposal of mixed waste from any individual plant at licensed sites are considered to be SMALL (NRC 2013). Therefore, TVA finds impacts from mixed waste storage and disposal for the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.12-1). 4.12.5. Nonradioactive Waste Storage and Disposal As discussed in the 2013 GEIS, nuclear plants generate small quantities of hazardous waste (including universal waste) during operation and refurbishment (NRC 2013). Management of Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-79

Appendix E - Applicants Environmental Report-Operating License Renewal Stage hazardous wastes generated at nuclear facilities, both onsite and offsite, is strictly regulated by the USEPA or the responsible state agencies per the requirements of the RCRA. Nonradioactive non-hazardous waste generated at nuclear facilities is managed using BMPs and generally disposed in local landfills permitted under RCRA Subtitle D regulations. In Section 4.11.1.5 of the 2013 GEIS, the 1996 GEIS was reviewed and it was determined that systems and procedures are in place at nuclear power plants to ensure continued proper handling and disposal of the wastes at all plants (NRC 2013). It was also concluded that changes to nonradioactive waste generation rates will not be anticipated for license renewal. Further, the impacts associated with managing nonradioactive wastes at uranium fuel cycle facilities, including nuclear power plants, were found to be SMALL. Under RCRA standards, BFN is currently classified as a small quantity generator of hazardous wastes with less than 2,200 pounds per month (1,000 kilograms per month) and it is not anticipated that this status will change during the subsequent period of extended operation. TVA addresses the management of BFNs hazardous waste, universal waste, and oily waste through its administrative procedures. These procedures establish responsibilities and controls for managing generated waste, including pollution prevention and the control and storage of chemicals. A hazardous material coordinator ensures the proper sampling, packaging, storage, shipping analysis, and disposal of hazardous materials generated at BFN and is supported by corporate environmental services. BFN utilizes permitted and licensed vendors to transport and recycle or dispose of wastes. Vendors and suppliers are managed and vetted at the corporate level. BFN maintains the following non-radioactive waste-related permits and licenses:

ADEM NPDES Facility Permit No. AL0022080
ADEM RCRA Regulated Waste Permit No. AL8640015410 As discussed in Section 2.2.5, the nonradioactive waste management system receives and processes nonradioactive wastes including hazardous, non-hazardous, universal, and sanitary wastes. Wastes are managed in accordance with federal and state regulations. BFN has an active recycling program, diverting accepted materials for recycling to TVA-approved vendor provides collection and disposal of municipal trash along with construction and demolition solid waste at their Morris Farms Landfill in Lawrence County, Alabama. In addition, per TVA procedures, hazardous waste and universal waste produced by BFN are collected and recycled or disposed, as applicable, through firms on the Environmental Restricted Awards List.

During the subsequent period of extended operation, TVA expects BFN to continue generating similar types and quantities of nonradioactive wastes to those generated during current and past operations. In addition, BFN will continue storing and disposing of nonradioactive hazardous and non-hazardous waste in accordance with USEPA, state, and local regulations, and continue disposing of the wastes in appropriately permitted disposal facilities during the subsequent period of extended operation. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. The continuation of existing systems and procedures to ensure proper storage and disposal will allow the impacts to be of SMALL magnitude. TVA finds that impacts associated with managing nonradioactive wastes at BFN for the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.12-1). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-80

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.13. Climate Change Changes in climate have broader implications for environmental resources (e.g., water resources, air quality, and ecosystems). For instance, changes in precipitation patterns and increase in air temperature can affect water availability and quality. As a consequence, climate change can have overlapping impacts on environmental resources by inducing changes in resource conditions that can also be affected by the proposed action. On the basis of these considerations, the following two issues are considered in this section:

Greenhouse gas impacts on climate change.
Climate change impacts on environmental resources.

4.13.1. Greenhouse Gas Impacts on Climate Change Impacts on climate change during normal operations at nuclear power plants can result from the release of GHGs from stationary combustion sources (e.g., diesel generators, pumps, diesel engines, oilers), refrigeration systems, electrical transmission and distribution systems, and mobile sources (worker vehicles and delivery vehicles). The GHG emissions from BFN are very minor because the plant does not normally combust fossil fuels to generate electricity. As discussed in Section 3.2.6, direct GHG emissions from operations at BFN do not exceed the 25,000 metric tons of CO2e reporting threshold established by USEPA. Furthermore, when compared to State GHG emissions, GHG emissions from operating BFN are orders of magnitude lower. Therefore, the impacts of GHG emissions on climate change from continued operations of BFN are SMALL. 4.13.2. Effects of Climate Change on Environmental Resources Projected climate change trends indicate the potential for future physical climate risks in the BFN area from increasing temperatures (both average annual and extreme heat events including more severe, frequent, and longer lasting heat waves), increasing precipitation (both average annual and extreme precipitation events), and unpredictable frequency and increasing intensity of tropical and extra-tropical storms, and the associated impacts to storm surge, flooding, and high wind events as a result of these predicted climate trends. Such climate change creates additional strain on the energy infrastructure; electricity demand for cooling rises with increasing air and water temperatures (DOE 2015). Section 3.2.5 provides discussions of historic and present climate data and trend for the region or state. This section discusses the potential effects of climate change on resources and how climate change could affect BFN operations. Climate change impacts can occur across all resource areas affected by the proposed action. Projections of possible climate futures incorporating global GHG emission concentrations and climate models provide insight into possible impacts from future climate change. With higher concentrations of GHG trapping more heat in the atmosphere, climate scenarios modeling current atmospheric GHG emission concentrations project a continued increase in global temperatures over the next several decades (Melillo et al. 2014). Because the global climate requires vast time to fully respond to changes in GHG concentrations, the U.S. Global Change Research Program determined that stabilizing GHG concentrations at current atmospheric levels would result in at least an additional 1.1°F of warming over this century (USGCRP 2018). A key finding from the U.S. Global Change Research program states that the magnitude of change depends primarily on cumulative emissions of greenhouse gases and aerosols and the sensitivity of the climate system to those emissions (Hayhoe et al. 2017). In addition, emission levels of GHG influence technological developments along with social, economic, and Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-81

Appendix E - Applicants Environmental Report-Operating License Renewal Stage demographic developments, which, reciprocally, influence GHG emissions. As a result of this interdependency, projections of possible climate change impacts modeled from GHG emission scenarios and their supporting assumptions, include substantial uncertainty. The Intergovernmental Panel on Climate Change (IPCC) is a United Nations body for assessing the science related to climate change. The synthesis report written by the IPCC contains their most comprehensive climate change work. The most recent report is the Synthesis Report of the IPCC Sixth Assessment Report, published in March 2023 (IPCC 2023). 4.13.2.1. Temperature and Precipitation Effects Projected changes for 2006-2100 near surface air temperatures based global climate models show two possible futures for the state under higher GHG emissions scenario and lower GHG emissions scenario, respectively. Although temperatures in Alabama have not risen since the beginning of the 20th century, recent years have been very warm, and the warmest consecutive 5-year interval was the most recent between 2016 and 2020. Less warming is expected under a lower emissions future (the coldest projections at 2100 being about as warm as the hottest year in the historical record) and more warming under a higher emissions future (the hottest 2100 projections being about 11°F warmer than the hottest year in the historical record (NOAA 2022). Under the higher emissions pathway, historically unprecedented warming is projected during this century at 2100 that is 11°F warmer than the hottest year in the historical record. Even under a lower emissions pathway, annual average temperatures are projected to most likely exceed historical record levels by 2050. A large range of temperature increases is projected under both pathways. The southeastern region, including Alabama, is in a transition zone between projected high latitude increases and subtropical decreases in precipitation, and as such, future projection of precipitation changes are uncertain (NOAA 2022). Consequently, climate change is likely to result in higher temperatures within the BFN area and may result in unknown effects on precipitation. Higher air temperatures can result in higher water temperatures. Increasing air and water temperatures reduce the efficiency of thermoelectric power generation and could reduce available generation capacity. Natural gas, coal, nuclear, bioenergy, and geothermal power plants are all affected by elevated air temperatures. Warmer air and heat waves can increase ambient cooling water temperatures, which affects generation efficiency regardless of fuel source. Changes in precipitation can affect water availability. In general, the increased frequency of days with extreme heat is one factor contributing to peak power demand. In contrast, technology advances such as improvements in air conditioning efficiency could help reduce the projected increases in electricity demand. In addition, because air conditioning use is greatest during the same periods of extremely high temperatures that can lead to transmission losses and reduced thermal efficiencies at electric generation facilities, increased cooling demand may increase the occurrence of peak loads coinciding with periods when generation efficiencies are lowest. Therefore, climate change may have a SMALL impact on BFN operations by affecting efficiencies and increasing demand during the subsequent period of extended operation. Because current climate change patterns in the southeast do not indicate a trend toward drought, climate change impacts on water availability in Wheeler Reservoir are also anticipated to be SMALL. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-82

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.13.2.2. Acute Weather Effects As discussed in Section 3.2.5.3, even though Alabama is directly impacted by a hurricane about once every 6 years, there has been no long-term trend over the past century in the number of hurricane events (Runkle et al. 2022). Thus, the future projection of such events is uncertain. However, the future flooding risk projection indicates there are 1,741 properties in the BFN neighborhood that have greater than a 26 percent chance of being severely affected by flooding over the next 30 years. This represents 14 percent of all properties in the BFN neighborhood. Overall, the BFN neighborhood has a moderate risk of flooding over the next 30 years, which means flooding is likely to impact day-to-day life within the community. If a low-likelihood storm resulting in severe flooding (a 1-in-100 flood event) occurred today, it could affect 1,706 properties. This type of event has a 26 percent chance of occurring at least once over the next 30 years (First Street Foundation 2023). Public infrastructure and other public services already experience impacts from climate change, and climate change is expected to add stress to any existing infrastructure that is already aging and near the end of its service life. High wind events can damage power lines leading to electrical outages, down trees, and cause flying debris that can disrupt transportation and telecommunication infrastructure, and cause damage to buildings, structures, and vehicles. While BFN SLR is not expected to contribute to climate-related impacts on public infrastructure and services, infrastructure damage from extreme weather events and flooding may impact the ability of workers to reach BFN, could disrupt shipments of materials arriving via roadway, or could disrupt transmission system infrastructure thus affecting BFNs ability to deliver power. Overall, acute weather effects associated with climate change are anticipated to have a SMALL impact on BFN SLR. 4.13.2.3. Public Health Effects Current and projected climate change conditions could have impacts to public health. Health impacts from climate change vary across communities and depend on social, socioeconomic, demographic, and other societal factors, and community adaptation efforts and the underlying vulnerability of individuals. Climate change related impacts have already begun affecting the health and well-being of residents throughout Alabama. In 2011, a deadly tornado outbreak swept across the southern, midwestern, and northeastern United States. Alabama was one of the hardest-hit states, suffering an estimated 238 tornado-related deaths and millions of dollars in property and infrastructure damages (Runkle et al. 2022). From mid-July, through mid-September, 1980, a sustained period of extreme heat and high humidity took its toll on the state. The month of July alone saw an estimated 120 heat related deaths, the loss of more than 200,000 chickens, and the loss of half the state's corn crop. The hottest day of the summer was July 17th, when over 80 percent of the state reached 100°F, and nearly one quarter of the state reached 105°F (State of Alabama 2018). The southeast region of the United States is projected to experience the countrys highest increase in heat index, which is a measure of comfort that combines relative humidity and temperature. Because the Southeast is expected to experience the United States greatest increase in heat index, the quality of life in the region could also decrease (Janasie J.D. 2014). A ridge of high pressure persisted over the State including Limestone County, on the 27th and 28th of June 2009, producing hot temperatures in the upper 90s to around 100°F. The heat combined with high humidity pushed heat index values into the 105 to 110°F range on both days. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-83

Appendix E - Applicants Environmental Report-Operating License Renewal Stage BFN SLR would not be expected to contribute to climate change, and thus will not contribute to adverse impacts to public health due to climate change. However, climate change related impacts to public health could have indirect impacts to BFN if the increased demand for air conditioning places greater demands on the generation system or if individual workers and their families are affected. Therefore, overall public health related effects of climate change on BFN are anticipated to be SMALL. Changes in the temperature of the water driven by climate change could result in changes to the development of microbiological hazards within Wheeler Reservoir. As discussed in Section 4.9.4, the BFN NPDES permit limits the temperature of the ambient water downstream of the mixing zone of the submerged diffusers. At present risk of exposure of the public to N. fowleri is possible below the discharge structure, however the probability of such exposure is low. Compliance with the NPDES permit would limit the effects of the BFN cooling water discharge on water temperatures in Wheeler Reservoir, regardless of natural increases in reservoir water temperatures that may result from short-term or long-term climate changes. Thus, TVA finds that the cumulative impacts on public health from thermophilic organisms in Wheeler Reservoir during the subsequent period of extended operation are SMALL. 4.13.2.4. Environmental Justice Effects As described in Section 3.8.1, the 50-mile region around BFN is classified as Category 3 (having one or more cities with 100,000 people, and fewer than 190 persons per square mile within 50 miles of the plant). BFN falls within category 4.3 of the GEIS Sparseness and Proximity Matrix which means it is in a high population area. Regardless, there are also areas within this 50-mile radius that are rural. These rural areas are important to the social and economic well-being of the region. Many in rural communities are maintaining connections to traditional livelihoods and relying on natural resources that are inherently vulnerable to climate change. The southeast region of the United States has the second highest number of farmworkers hired per year compared to other National Climate Assessment regions. Climate trends and possible climate futures show patterns that are already impactingand are expected to further impactrural sectors, from agriculture and forestry to human health and labor productivity. While adaptation and resilience can moderate climate change impacts, rural areas generally face other stressors, such as poverty and limited access to healthcare, which will make coping to climate-related challenges more difficult (Carter et al. 2018). As described in Section 3.10.1, minority populations are present within nine of 14 counties (64.3 percent) and in 131 of 692 block groups (18.9 percent) in Alabama. In Tennessee, minority populations are present in 2 out of 7 counties (28.6 percent) and 3 out of 93 block groups (3.2 percent) (USCB 2020a, USCB 2020d). Additionally, as described in Section 3.10.2, low-income populations were identified in 16.2 percent of blocks groups in Alabama and 15.1 percent of block groups in Tennessee (USCB 2020b, USCB 2020c). Limited subsistence populations and migrant workers are also present in the BFN 50-mile region as described in Section 3.10.3. Section 4.11 presents the analysis that indicates that the BFN SLR will not result in any disproportionately high and adverse effects on environmental justice populations and that overall impacts to these populations are SMALL. As described above, climate change can result in impacts to public health. Impacts to public health may be disproportionate to environmental justice communities. For example, these communities may not have the resources to afford higher costs for indoor climate control that could result from overall higher temperatures. This could result in more heat-related health impacts to disadvantaged populations which also may not have the resources to provide for Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-84

Appendix E - Applicants Environmental Report-Operating License Renewal Stage health care. Therefore, climate change impacts on environmental justice are expected to be SMALL to MODERATE, however, BFN SLR would not contribute to those impacts. 4.14. Cumulative Impacts Table 4.13-1 lists the cumulative impact issue identified in the GEIS and the GEIS findings. This issue was reviewed with respect to impacts associated with the BFN SLR. Table 4.14-1. Cumulative Impacts Issues and the NRC 2013 GEIS Findings SLR-ER Issue GEIS Finding Section Cumulative Impacts (Category 2). Cumulative impacts of continued operations and 4.13 refurbishment associated with license renewal must be considered on a plant-specific basis. Impacts would depend on regional resource characteristics, the resource-specific impacts of license renewal, and the cumulative significance of other factors affecting the resource. Source: (NRC 2013) This section considers the contribution of continued operation of BFN to potential regional environmental cumulative impacts. It assesses the potential significance of BFNs impacts in relation to other known or reasonably foreseeable projects. Impacts are defined in the Council on Environmental Quality regulations (40 CFR 1508.1(g)) as changes to the human environment from the proposed action or alternatives that are reasonably foreseeable and have a reasonably close causal relationship to the proposed action or alternatives, including those effects that occur at the same time and place as the proposed action or alternatives and may include effects that are later in time or farther removed in distance from the proposed action or alternatives. In this section, reasonably foreseeable actions that are authorized or funded by an agency (federal or non-federal) and take place in the vicinity of BFN are identified. Possible cumulative effects associated with these actions are discussed in the following sections. For the purposes of this analysis, reasonably foreseeable actions include those that have been publicly announced before submittal of the BFN SLR application to the NRC. Reasonably foreseeable future actions are those that are ongoing (and would continue into the future), are funded for future implementation, or are included in firm, near-term publicly available plans covering the operating periods of the subsequent period of extended operation. The geographic area affected by cumulative impacts depends on the resource being considered (NRC 2013). Reasonably foreseeable actions may include individually minor, but collectively significant, actions occurring over a period of time (NRC 2013). Reasonably foreseeable projects which could contribute to cumulative impacts with respect to BFN would include transportation projects and plans, additional industrial development, and water resources projects. Reasonably foreseeable projects include:

Expansion of the BFN onsite spent fuel storage capacity may be required in the future if a national storage solution for the permanent storage of spent fuel does not become available during the subsequent period of extended operation. The current BFN ISFSI storage pads are projected to be filled on or before year [2036]. The addition of a third ISFSI storage pad Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-85

Appendix E - Applicants Environmental Report-Operating License Renewal Stage to further increase storage capacity at BFN is under consideration, but plans are in the conceptual stage and no installation schedule has been established.

Limestone County does not have a full comprehensive land use plan, but the cities of Athens (2013), Huntsville (2018), and Decatur (2018) have published either a land use plan or comprehensive plan (City of Decatur Alabama 2018, Huntsville 2018, Martin 2013). Each of the three cities are looking to increase population density, and although Limestone County is one of the fastest growing counties in Alabama with regard to industrial development (Limestone County 2021), population growth in the area is slow (City of Decatur Alabama 2018). Desktop research did not result in the identification of any information regarding major residential or industrial development projects within a 10-mile radius of BFN; however, it can be assumed that local residential, business, and commercial developments will occur during the subsequent period of extended operation.
Redstone Arsenal is a U.S. Army post established in 1941 that covers over 38,000 acres in Huntsville, Alabama, approximately 30 miles east of BFN. It is a garrison for various tenants from the Department of Defense, Department of Justice, and the National Aeronautics and Space Administration, and has childcare facilities, shops, restaurants, and hotels. The master plan shows that there are developed areas, areas under development, and areas proposed for future development (Redstone Gateway 2020). The Federal Bureau of Investigation (FBI) is expanding their current campus at the Redstone Arsenal. There are currently approximately 1,800 employees working at the FBI campus on Redstone Arsenal, but it is anticipated that there will be at least 3,000 FBI employees working there across 19 divisions (Newsum 2023).
Cummings Research Park (CRP), which is approximately 24.5 miles east of BFN, is the second largest research park in the country and includes over 300 companies, more than 26,000 employees, and 13,500 students (CRP 2021b). CRP published a Master Plan in 2016 (CRP 2016) and there are currently approximately 280 acres of land available for development in CRP (CRP 2021a).
The Town of Courtland, Alabama, approximately 11 miles west of BFN on the south side of Wheeler Reservoir, was awarded a Community Development Block Grant by the State of Alabama Department of Economic and Community Affairs and has begun construction to replace approximately 8,400 linear feet of new water mains and new customer service lines.

The Town of Courtland will be working with the West Morgan-East Lawrence Water and Sewer Authority (WMEL 2021).

As of August 31, 2021, there was one transportation project under construction in Limestone County and eight additional projects were anticipated (ALDOT 2021b). Each of these projects is more than 10 miles from BFN. The other counties adjacent to the BFN site, Morgan and Lawrence Counties, are on the south side of Wheeler Reservoir. There are two projects under construction in Morgan County and one planned project in Lawrence County (ALDOT 2021a, ALDOT 2021c), with the closest of the three projects being approximately16.5 miles from BFN in Lawrence County.

The incremental contribution of BFN operation to the cumulative impacts on resource areas is discussed below. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-86

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.14.1. Land Use and Visual Resources As discussed in Section 4.1, TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR continued operation of BFN and will have a SMALL impact on land use and visual resources during the subsequent period of extended operation. Therefore, the incremental contribution of BFN to cumulative impacts to land use or visual resources is also SMALL. 4.14.2. Meteorology and Air Quality As discussed in Section 3.2, Limestone County is designated as being in attainment for all National Ambient Air Quality Standards criteria pollutants. The only local projects in addition to BFN that could contribute to air quality impacts are transportation projects or development projects. However, the majority of the impacts to air quality from these transportation or development projects will be related to construction, which will be short in duration and potentially negative impacts to air quality are negligible. As noted in Section 4.1, TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Therefore, no changes to existing air quality conditions will occur due to continued operations at BFN and the incremental contribution of SLR to cumulative impacts to the regions air quality is SMALL. 4.14.3. Noise There are no projects in the vicinity of BFN that would contribute to noise in the vicinity of BFN due to the distance of each of the projects from BFN. The closest project is a transportation project which is more than 10 miles from BFN and noise would not be noticeable at this distance. As noted in Section 4.3, the closest distance from the BFN to sensitive receptors is approximately 1,500 feet, and potential operational noise impacts from the BFN will be small as demonstrated by the ambient noise monitoring program conducted during 2020 and described in in Section 3.3. In addition, TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR and continued operation of BFN will have a SMALL impact on noise in the area. Therefore, no changes to existing noise conditions will occur due to continued operations at BFN and the incremental contribution to cumulative impacts to noise associated with the continued operation of BFN is SMALL. 4.14.4. Geology and Soils The closest project is a transportation project which is more than 10 miles from BFN. Due to the distance of each of the projects from BFN, there are no cumulative that would contribute to impacts to geology and soils in the vicinity of BFN. As noted in Section 4.4, no changes to existing conditions with respect to geology and soils are anticipated during the subsequent period of extended operation. Therefore, the incremental contribution to cumulative impacts to the regions geology or soils associated with the continued operation of BFN is SMALL. 4.14.5. Water Resources 4.14.5.1. Surface Water Use As described in Section 4.5.1, impacts from the BFN SLR on surface water use are SMALL, and will not warrant mitigation. This determination took into consideration effects from existing water users with intakes on Wheeler Reservoir. The major public uses of the Reservoir are for water supplies, recreation, and waste disposal. The BFN water supply is withdrawn from Wheeler Reservoir by an intake structure located at approximately TRM 294.3. The nearest community surface water supply intake upstream of BFN is for Decatur, Alabama, located on Wheeler Reservoir 12 miles from BFN; the nearest downstream water intake is the West Morgan-East Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-87

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Lawrence Water Authority intake located approximately 7.5 river miles downstream of BFN on the left bank of Wheeler Reservoir at TRM 286.5. Additionally, as discussed in Section 4.5.1, TVA is responsible for managing the water resources of Wheeler Reservoir, including water releases from the upstream and downstream dams (Guntersville and Wheeler, respectively), which allows TVA to monitor and address surface water use issues near BFN. None of the proposed or in-progress projects in the vicinity of BFN will impact water use beyond the TVAs capacity to regulate it. Accordingly, and because the result presented in Section 4.5.1 is based on a cumulative analysis, BFNs incremental contribution to cumulative surface water use is SMALL. 4.14.5.2. Groundwater Use As described in Section 3.5.2, groundwater is not used by BFN and thus, does not create an offsite cone of depression. The closest known public groundwater supply well (Limestone County Water System) is located approximately 2 miles north of BFN (Geosyntec 2013). Since all local groundwater near BFN flows toward and discharges to Wheeler Reservoir, it is improbable that any release from BFN would contaminate nearby sources of water supply through contamination of groundwater. Additionally, the closest project is a transportation project which is more than 10 miles from BFN and none of the projects would impact groundwater use in the vicinity of BFN. Consequently, BFNs incremental contribution to cumulative groundwater use is SMALL. 4.14.5.3. Groundwater Quality As discussed in Section 4.5.2, the impacts of the BFN SLR on groundwater quality are SMALL and will not warrant mitigation. There will be no seepage from the cooling pond as BFN does not have a cooling pond. Furthermore, with the containment provided for the liquid radwaste system, there is little likelihood of the release of liquid radwaste to the groundwater. Additionally, since groundwater movement in the area is toward the Wheeler Reservoir, the potential for contamination of groundwater wells within 1 mile of BFN will be SMALL. As the closest project is a transportation project which is more than 10 miles from BFN, none of the projects would impact groundwater quality in the vicinity of BFN. Therefore, the incremental contribution of continued operation of BFN to cumulative impacts to groundwater quality is SMALL. 4.14.6. Ecological Resources 4.14.6.1. Terrestrial Resources As described in Section 4.6.1, the impacts of the BFN SLR on terrestrial resources are SMALL and will not warrant mitigation. No refurbishment activities or changes to plant operational activities or in-scope transmission lines that would change effects on terrestrial resources are expected to occur during the subsequent period of extended operation. There was no identified increase in exposure of terrestrial organisms to radionuclides attributable to BFN operation from ingestion of plants or fish. Helper cooling tower impacts on terrestrial plants and animals have not been observed. Impacts from bird collisions will be managed through compliance with Executive Orders, TVAs adherence to federal regulations. In-scope transmission lines are entirely within the BFN site, present negligible exposure to terrestrial organisms, and there are no associated ROWs requiring management. As described in Section 3.6.1.1, wildlife and plant species on the developed parts of the BFN property are common species adapted to industrial sites and able to tolerate relatively high levels of noise and human activity. The characteristics of terrestrial communities on less Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-88

Appendix E - Applicants Environmental Report-Operating License Renewal Stage developed property reflect the communities adaptations to the activities at BFN, which are not expected to change during the subsequent period of extended operation. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Section 4.6.1 explains that the TVA manages water resources of Wheeler Reservoir and can control variable dam releasees from the upstream and downstream dams (Guntersville and Wheeler Dam, respectively), in part to protect wetlands and ecologically sensitive areas. Hence, the contribution to cumulative impacts on terrestrial resources in riparian communities from extending operation of BFN for the 20-year subsequent period of extended operation is SMALL, if discernible, because (1) the withdrawal of water from Wheeler Reservoir by BFN has almost no effect on river flow or level during normal or higher flows, (2) TVA will mitigate potential impacts from consumptive cooling water withdrawals during drought conditions, and (3) BFN does not use groundwater. Based on the information provided above, TVA concludes that the incremental contribution of the continued operation of BFN to cumulative impacts on terrestrial resources is SMALL. 4.14.6.2. Aquatic Resources As described in Section 4.6.2, the impacts of the BFN SLR on aquatic resources are SMALL and will not warrant mitigation. Since BFN began full operation in 1977, effects of cooling water discharge on dissolved oxygen, gas supersaturation, or eutrophication have not been observed. The comprehensive regulatory controls and permits in place and BFNs compliance with them will prevent or minimize impacts to surface waters from non-radiological contaminants. Radiological monitoring by BFN indicates no identified increase in exposure of aquatic organisms to radionuclides attributable to BFN operation from ingestion of fish or exposure to sediment. Dredging is infrequent and impact analysis for dredging did not indicate the need for permitting for aquatic resources or the need for mitigation commitments. The comprehensive regulatory controls and permits in place and BFNs compliance with them will prevent or minimize impacts to surface waters and aquatic resources from non-radiological impacts. Changes in sublethal stresses that could lead to increased susceptibility to predation, parasitism, or disease are not expected. The aquatic community exposed to these stressors has adapted to the conditions from BFNs on-going operations. TVA annual monitoring shows that there is a balanced, indigenous, aquatic community in the immediate vicinity of the BFN cooling water discharge after many years of operation. Section 3.5.1.3 describes existing water quality in Wheeler Reservoir. The existing water quality reflects the cumulative effect of pollutants from existing dischargers that could potentially affect aquatic resources, most of which (including BFN) are subject to controls imposed through NPDES permits. As described in Section 4.5.1.1, TVA has determined that non-cooling system surface water quality impacts associated with the BFN SLR are SMALL. The current NPDES permit (AL 0022080) for BFN requires the facility to comply with BTA standards that limit impingement and entrainment mortality from operation of the cooling water intake. Prior to construction and operation of BFN and since BFN began full operation in 1977, TVA has conducted extensive biological studies and assessments which demonstrate that there have been no significant impacts to aquatic resources due to operation of BFN, and avoidance of the plume was not detected for any species of fish (TVA 2021c). Ongoing compliance with NPDES permit conditions would ensure that such impacts will continue to be minimized by employing BTA for intake structures. Based on the long-term data during the current period of extended operation of BFN, TVA finds the impacts of impingement and entrainment over the Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-89

Appendix E - Applicants Environmental Report-Operating License Renewal Stage subsequent period of extended operation will be SMALL and will not warrant additional mitigation. BFNs thermal discharges comply with applicable NPDES permit conditions, affect a very small area of Wheeler Reservoir, and do not create a barrier to upstream and downstream fish movement patterns. Additionally, the current NPDES permit contains mitigation measures to be used if temperature critical levels are exceeded, or if drought or hot weather begins to impact reservoir temperatures. The existing NPDES discharges to Wheeler Reservoir are regulated by ADEM, and any new discharges to the basin will also be regulated by the ADEM, thereby minimizing potential cumulative thermal impacts to aquatic resources across the entire basin. Because thermal discharges from BFN are expected to remain at existing levels throughout the subsequent period of extended operation, thermal impacts to aquatic organisms over the subsequent period of extended operation will continue to be SMALL and will not warrant additional mitigation. Section 4.6.1.3 explains that the TVA manages water resources of Wheeler Reservoir and can control variable dam releasees from the upstream and downstream dams (Guntersville and Wheeler Dam, respectively) to maintain required minimum flow in Wheeler Reservoir to meet specific system requirements for aquatic habitats, water quality, and waste assimilation. The contribution to cumulative impacts on aquatic resources from extending operation of BFN for the 20-year subsequent period of extended operation will be SMALL, if discernible, because (1) the withdrawal of water from Wheeler Reservoir by BFN has almost no effect on river flow or level during normal or higher flows, (2) TVA will mitigate potential impacts from consumptive cooling water withdrawals during drought conditions, and (3). BFN does not use groundwater. Therefore, TVA concludes that the incremental contribution of the continued operation of BFN to cumulative impacts on aquatic resources is SMALL. 4.14.6.3. Special Status Species and Habitats Special status species with a potential to occur in the vicinity of the BFN site are discussed in Section 3.6.1.4 (terrestrial) and Section 3.6.2.4 (aquatic). Tables 3.6-2 and 3.6-8 list the endangered or threatened species identified from the TVA Natural Heritage Project Database and Alabama Natural Heritage Program database. The federal listed terrestrial species (and/or state protected) with a potential to occur at BFN are the gray bat, Indiana bat, northern long-eared bat, tricolored bat (proposed listing as endangered), monarch butterfly, and one federal protected species (Bald eagle). As described in Section 3.6.1.4, the state protected osprey has been known to nest at BFN. Review of the TVA Natural Heritage Project Database (TVA 2022b) indicates that one federal listed terrestrial animal species (gray bat) and one federal protected species (bald eagle) have been reported within 3 miles of the BFN site. In addition, the USFWS has determined that the federal status Indiana bat, northern long-eared bat, tricolored bat, and monarch butterfly have the potential to occur in the vicinity of the BFN site (Table 3.6-2). No federal listed plant species have recorded occurrences within 5 miles of the BFN site, and critical habitat has not been designated for any federal listed species in the project vicinity (USFWS 2022). As described in Section 3.6.2.4, listed mussel species recorded within a 10-mile radius of BFN (Table 3.6-8) are not expected to occur near BFN. The fish species with federal or state status and recorded occurrences in Wheeler Reservoir and/or within 10 miles of BFN are spring pygmy sunfish, slackwater darter, Tuscumbia darter, and paddlefish. In 21 years (since 1993) of fish entrainment sampling by TVA in the vicinity of BFN, the paddlefish was collected in only 1 year (TVA 2020b). The spring pygmy sunfish, slackwater darter, and Tuscumbia darter were never Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-90

Appendix E - Applicants Environmental Report-Operating License Renewal Stage collected and would not be expected to be present because they do not occur in lacustrine habitat. The snail darter has been detected in Wheeler Reservoir, and adults may be present in the vicinity of BFN. However, the only suitable habitat for this species in the vicinity of BFN is present only opposite the location of BFN. The Alabama Natural Heritage Program database also does not include any known occurrences of federal status terrestrial plant species for Limestone County (ALNHP 2021). Section 4.6.3 addresses potential impacts to special-status species and concludes that it is unlikely that any activities at BFN will adversely impact any of the species known to exist on or near the project site. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. Accordingly, there will be no impacts to special status species from such activities. Also, TVA is not aware of any BFN activities during the subsequent period of extended operation that would adversely impact special-status species that may occur at or near the site. Operations and maintenance activities during the subsequent period of extended operation are expected to be similar to current activities, and existing procedures consider impacts to threatened and endangered species and their habitats as part of operations and maintenance planning. Based on the information provided above, TVA concludes that the incremental contribution of the continued operation of BFN on the cumulative impacts to any special status species is SMALL. 4.14.7. Historic and Cultural Resources As discussed in Section 4.7, TVA has no plans for refurbishment or other changes to BFN structures or activities during the subsequent period of extended operation with potential for effects on BFN or archaeological sites in the APE. TVA will continue to avoid any activities that would disturb any of the graves in the relocated Cox Cemetery. Therefore, TVA concluded that impacts to historic and cultural resources in association with SLR at BFN are SMALL. The SLR will have no effect on historic structures associated with Units 1, 2, and 3, and appropriate consideration will be given to the historic significance of any such onsite structures at the time of decommissioning. Hence, TVA concludes that BFNs continued operation will not contribute to cumulative adverse impacts on historic and cultural resources. 4.14.8. Socioeconomics Section 2.5 (employment at BFN), Section 3.8 (socioeconomic conditions of Colbert, Lauderdale and Limestone Counties), and Section 3.10 (minority and low-income populations within a 50-mile radius of BFN) provide background information pertinent to cumulative socioeconomic impacts. BFNs impacts to socioeconomics were evaluated in Section 4.8. TVA concluded that impacts to employment, income, recreation and tourism, tax revenues, community services and education, population and housing, and transportation will all be SMALL. Continued operation of BFN during the subsequent period of extended operation will have no impact on socioeconomic conditions in the region beyond those already experienced. Because TVA has no plans to significantly alter the number of workers during the subsequent period of extended operation, overall expenditures and employment levels at the BFN will remain relatively constant and will not increase the demand for permanent housing or public services. Therefore, changes to socioeconomic conditions in the community as a result of the BFN SLR are not expected. Although the population of all three counties where the majority of BFN employees live continues to grow, the Athens, Huntersville, and Decatur Land Use and Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-91

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Comprehensive Plans did not identify any major future development plans that would adversely affect recreation and tourism, tax revenues, community services and education, housing availability and cost, or transportation in the vicinity of BFN. Therefore, the incremental contribution of the continued operation of BFN during the subsequent period of extended operation to socioeconomics is SMALL. 4.14.9. Human Health Human health impacts from operation of nuclear power plants include non-radiological and radiological impacts. The human health issues identified in the 2013 GEIS are summarized in Table 4.9-1, and each is discussed with respect to impacts associated with the BFN SLR in Section 4.9. 4.14.9.1. Non-Radiological Health Impacts The non-radiological issues potentially affecting human health include impacts from chemicals, microbiological hazards, chronic effects of EMFs, physical occupational hazards, and electric shock hazards. These issues were assessed with respect to impacts from the BFN SLR in Sections 4.9.3 through 4.9.8. TVA found that human health impacts of each of these issues during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS. (An exception is the issue of chronic effects of EMFs, for which effects are uncertain and evidence is inconclusive, such that applicants for license renewal are not required to submit information on this issue.) Therefore, TVA concludes that the incremental contribution from continued operation of BFN to cumulative non-radiological health effects to workers and the public from all sources is SMALL. 4.14.9.2. Radiological Health Impacts Radiological exposures to the public and to plant workers are evaluated in Sections 4.9.1 and 4.9.2, respectively. Radiological dose limits for protection of the public and workers have been developed by USEPA and the NRC to ensure that the cumulative impacts of acute and long-term exposure to radiation and radioactive material are SMALL regardless of the source or sources. Operation of BFN during the subsequent period of extended operation will comply with these dose limits, which are codified in 40 CFR Part 190, 10 CFR Part 20 and 10 CFR Part 50, Appendix I. For the purpose of this cumulative analysis, the area within a 50-mile radius of BFN was included. There are no other nuclear power plants within a 50-mile radius of BFN (NEI 2022) and TVA is not aware of any plans to construct a new nuclear power plant during the subsequent period of extended operation within this area. Therefore, TVA concludes that the incremental contribution of continued operation of BFN to cumulative radiation doses and associated health impacts to workers and the public from all sources is SMALL. 4.14.10. Environmental Justice As noted in Section 4.11, there will be no disproportionately high and adverse health or environmental impacts from BFN to minority or low-income populations in the region. Hence, TVA concludes that the incremental contribution of the continued operation of BFN to the cumulative environmental justice conditions in the region during the subsequent period of extended operation is SMALL. 4.14.11. Waste Management and Pollution Prevention As stated in Section 4.12, no refurbishment or changes to the BFN operational activities that will affect waste management are expected during the BFN subsequent period of extended operation. Therefore, BFNs incremental contribution to changes in the cumulative waste Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-92

Appendix E - Applicants Environmental Report-Operating License Renewal Stage management conditions in the region during the subsequent period of extended operation is SMALL. 4.15. Uranium Fuel Cycle Table 4.14-1 lists the uranium fuel cycle issues identified in the 2013 GEIS and the 2013 GEIS findings. Each of these issues was reviewed with respect to impacts associated with the BFN SLR. Table 4.15-1. Uranium Fuel Cycle Issues and the NRC 2013 GEIS Findings SLR-ER Issues GEIS Finding Section Offsite radiological SMALL (Category 1). The impacts to the public from 4.14.1 impacts individual radiological exposures have been considered by the NRC in impacts from other than Table S-3 of this part. Based on information in the GEIS, the disposal of spent impacts to individuals from radioactive gaseous and liquid fuel and high-level releases, including radon-222 and technetium-99, would remain waste at or below the NRC's regulatory limits. Offsite radiological (Category 1). There are no regulatory limits applicable to 4.14.2 impacts collective collective doses to the general public from fuel-cycle facilities. impacts from other than The practice of estimating health effects on the basis of the disposal of spent collective doses may not be meaningful. All fuel-cycle facilities fuel and high-level are designed and operated to meet the applicable regulatory waste limits and standards. The NRC concludes that the collective impacts are acceptable. The NRC concludes that the impacts would not be sufficiently large to require the NEPA conclusion, for any plant, that the option of extended operation under 10 CFR part 54 should be eliminated. Accordingly, while the NRC has not assigned a single level of significance for the collective impacts of the uranium fuel cycle, this issue is considered Category 1. Non-radiological SMALL (Category 1). The non-radiological impacts of the 4.14.3 impacts of the uranium uranium fuel cycle resulting from the renewal of an operating fuel cycle license for any plant would be small. Transportation SMALL (Category 1). The impacts of transporting materials to 4.14.4 and from uranium-fuel-cycle facilities on workers, the public, and the environment are expected to be small. Source: (NRC 2013) 4.15.1. Offsite Radiological Impacts Individual Impacts From Other Than the Disposal of Spent Fuel and High-Level Waste This issue addresses the radiological impacts on individuals who live near uranium fuel cycle facilities. The primary indicators of impact are the concentrations of radionuclides in the effluents from the fuel cycle facilities and the radiological doses received by a maximally exposed individual on the BFN site boundary or at some location away from the BFN site boundary (NRC 2013). The basis for establishing the significance of individual effects from the uranium fuel cycle is the comparison of the releases in the effluents and the maximally exposed individual doses with the permissible levels in applicable regulations. The impacts to the public from radiological exposures from the uranium fuel cycle have been considered by NRC in Table S-3 of 10 CFR 51.51. Based on information in the 2013 GEIS, impacts to individuals from radioactive gaseous Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-93

Appendix E - Applicants Environmental Report-Operating License Renewal Stage and liquid releases, including radon-222 and technetium-99, would remain at or below the NRC's regulatory limits (10 CFR Part 51, Subpart A, Appendix B, Table B-1) (NRC 2013).The analyses performed by the NRC in the preparation of Table S-3 and found in the 1996 GEIS indicate that when the facilities operate under a valid license issued by either the NRC or an agreement State, the individual effects will meet the applicable regulations. Based on these considerations, the NRC has concluded that the impacts on individuals from radioactive gaseous and liquid releases during the subsequent period of extended operation would remain at or below the NRCs regulatory limits. Accordingly, the NRC concludes that offsite radiological impacts of the uranium fuel cycle (individual effects from sources other than the disposal of spent fuel and high-level waste) would be SMALL (NRC 2013). BFN previously utilized blended low enriched uranium (BLEU), provided by the Department of Energy, in fuel assemblies at the site. BFN has since transitioned to conventionally sourced low-enriched uranium fuel for new fuel loads, with the last fuel load of BLEU occurring in fall of 2018. The final fuel assemblies containing BLEU fuel will be removed from the BFN reactor core(s) in fall of 2024, and consequently use of BLEU fuel does not impact the subsequent period of extended operation. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified. Based on the site-specific analyses presented above, TVA finds that offsite radiological impacts related to individual impacts from other than disposal of spent fuel and disposal of high-level waste during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.14-1). 4.15.2. Offsite Radiological Impacts Collective Impacts From Other Than the Disposal of Spent Fuel and High-Level Waste This issue concerns the direct collective impacts from facilities involved in supplying nuclear fuel to nuclear power plants. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified as it relates to offsite radiological impacts - collective impacts from other than the disposal of spent fuel and high-level waste. Based on the site-specific analyses presented above, TVA finds that impacts offsite radiological impacts related to collective impacts from other than disposal of spent fuel and disposal of high-level waste during the subsequent period of extended operation are SMALL. 4.15.3. Non-Radiological Impacts of the Uranium Fuel Cycle This issue concerns the direct non-radiological impacts from facilities involved in supplying nuclear fuel to nuclear power plants. Data on the non-radiological impacts of the fuel cycle are provided in Table S-3 (10 CFR 51.51). These data cover land use, water use, fossil fuel use, and chemical effluents. The significance of the environmental impacts associated with these data was evaluated in the 1996 GEIS on the basis of several relative comparisons. It was noted that the impacts associated with each of the referenced resources would be SMALL. Any impacts associated with non-radiological liquid releases from the fuel cycle facilities would also be SMALL. As a result, the aggregate non-radiological impact of the uranium fuel cycle resulting from the renewal of an operating license for a plant would be SMALL. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-94

Appendix E - Applicants Environmental Report-Operating License Renewal Stage The issue was considered in the new and significant review for BFNs first license renewal, and no N&SI was found at that time. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR, and no N&SI was identified as it relates to non-radiological impacts of the uranium fuel cycle. Based on the site-specific analyses presented above, TVA finds that non-radiological impacts of the uranium fuel cycle during the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.14-1). 4.15.4. Transportation The issue concerns the impact of transporting materials to and from uranium fuel cycle facilities on workers, the public, and the environment. Information presented in Table S-4 in 10 CFR 51.52 forms the basis for analysis of the impacts associated with transportation of fuel and waste to and from one light water reactor during the subsequent period of extended operation for the purpose of evaluating the applications for SLR from owners of light water reactors. The applicability of Table S-4 for license renewal applications was extensively studied in the 1996 GEIS (NRC 1996) and its Addendum 1 (NRC 1999). The impacts were found to be SMALL, and the findings were stated as follows: The impacts of transporting spent fuel enriched up to 5 percent uranium-235 with average burnup for the peak rod to current levels approved by NRC up to 62,000 MWd/MTU and the cumulative impacts of transporting high-level waste to a single repository, such as Yucca Mountain, Nevada are found to be consistent with the impact values contained in 10 CFR 51.52(c), Summary Table S-4, Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power Reactor. If fuel enrichment or burnup Environmental Consequences and Mitigating Actions 4-197 NUREG-1437, Revision 1 conditions are not met, the applicant must submit an assessment of the implications for the environmental impact values reported in 10 CFR 51.52. The issue was assigned to Category 1. No new information has been identified that would alter this conclusion (NRC 1999). Provided that fresh fuel enrichment is limited to 5 percent or less, spent fuel burnup remains 62,000 megawatt days per metric ton of uranium (MWd/MTU) or less, and higher burnup (greater than 33,000 MWd/MTU) fuel was cooled for a minimum of 5 years prior to shipping offsite, the NRC considers the impacts of this issue to be SMALL. As noted in Section 2.2.2, fuel enrichment at BFN would be limited to 5 percent by weight uranium-235, average peak rod fuel burnup would not exceed 62,000 MWd/MTU and spent fuel assemblies would be cooled in the spent fuel pool until conditions are met allowing transfer to onsite dry storage. The issue was considered in the new and significant review for BFNs first license renewal, and no N&SI was found at that time. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR that would have offsite radiological impacts and no N&SI related to this issue was identified. Based on the site-specific analyses presented above, TVA finds that impacts related to transportation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.14-1). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-95

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 4.16. Termination of Nuclear Plant Operations and Decommissioning Table 4.15-1 lists the decommissioning issue identified in the 2013 GEIS and the 2013 GEIS findings. Each of these issues was reviewed with respect to impacts associated with the BFN SLR. Table 4.16-1. Termination of Nuclear Plant Operations and Decommissioning Issues and the NRC 2013 GEIS Findings SLR-ER Issue GEIS Finding Section Termination of plant SMALL (Category 1). License renewal is expected to have a 4.15 operations and negligible effect on the impacts of terminating operations and decommissioning decommissioning on all resources. Source: (NRC 2013) The issue of termination of plant operations and subsequent plant decommissioning is addressed in this section. Additional background information is provided, and an analysis of the issue as it pertains to the subsequent period of extended operation is also included. Per the findings of 10 CFR Part 51, Subpart A, Appendix B, Table B-1, SLR is not expected to have an effect on the impacts associated with the termination of nuclear operations and decommissioning. The impacts associated with decommissioning activities at nuclear plants were evaluated by the NRC and are detailed in NUREG-0586, Generic Environmental Impact Statement for Decommissioning Nuclear Facilities: Supplement 1, Regarding the Decommissioning of Nuclear Power Reactors (NRC 2002). The environmental consequences associated with the termination of plant operation and decommissioning are further detailed here. The impacts that are associated with the subsequent period of extended operation are limited to those with effects on identified decommissioning impacts. The impacts associated with active nuclear plant operation would generally end with the conclusion of nuclear power operation (i.e., reactor shutdown). There are impacts that may continue but likely at different, often reduced, levels than those experienced during plant operation. Therefore, in the absence of specific identified impacts for the period after nuclear power operation has concluded, impacts associated with power operation could be evaluated for use as bounding assumptions. There is also the potential for new impacts that result from discontinuing power operation. The termination of nuclear power operation would allow some activities that are required for reactor operation to cease and could result in a corresponding reduction in the total workforce. However, since it is not anticipated that immediate dismantlement of the reactor and associated systems, structures, and components would generally be pursued by the licensees, the continued operation of support systems in parts of the facilities are expected to be required after reactor operation has ended, either in support of other operating units on site or, for single unit sites, to ensure safe shutdown conditions are maintained. The scope of this issue is limited to the impacts on termination of nuclear plant operation and subsequent decommissioning that are related to the extension of plant operation for the SLR operating period. The SLR operating period may result in an increase in the volume of radioactive waste and radioactive materials that must be managed during and after plant shutdown. The additional operating period would also result in an increase in the amount of spent fuel that would require Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-96

Appendix E - Applicants Environmental Report-Operating License Renewal Stage management during decommissioning. However, the issue was considered in the new and significant review for BFNs first license renewal, and no N&SI was found at that time. TVA has no plans for refurbishment activities or modifications beyond normal maintenance at BFN associated with SLR. The construction of additional plant structures that would require decommissioning would not be required to support the subsequent period of extended operation. No labor force changes in support of the additional operating period would increase socioeconomic impacts of plant shutdown. Decommissioning activities would be conducted by TVA in accordance with established NRC guidance. Based on the analyses presented above, TVA finds that impacts from decommissioning following the subsequent period of extended operation are SMALL, which is consistent with the NRCs conclusion in the 2013 GEIS (Table 4.14-1). 4.17. References ADEM (Alabama Department of Environmental Management). 2015. Water Quality Program. Administrative Code Chapter 335-6-6. National Pollutant Discharge Elimination System. ADEM. 2018. National Pollutant Discharge Elimination System (NPDES), Permit Number: AL0022080. Permittee: Tennessee Valley Authority, Browns Ferry Nuclear Plant, Issuance Date: June 7, 2018, Effective Date: July 1, 2018, Expiration Date: August 31, 2023. ADEM. 2020. Alabama 303(d) List. Accessed September 20, 2021 at http://adem.alabama.gov/programs/water/wquality/2020AL303dList.pdf. ADEM. 2021. NPDES Permits. Accessed September 20, 2021 at http://adem.alabama.gov/programs/water/permitting.cnt. ADEM. 2023. Coastal Programs. Accessed September 26, 2023 at https://www.adem.alabama.gov/programs/coastal/default.cnt. ALDOT (Alabama Department of Transportation). 2021a. North Projects - Lawrence County. Accessed September 7, 2021 at https://www.dot.state.al.us/projects/nregion/lawrenceprojects.html. ALDOT. 2021b. North Projects - Limestone County. Accessed September 7, 2021 at https://www.dot.state.al.us/projects/nregion/limestoneprojects.html. ALDOT. 2021c. North Projects - Morgan County. Accessed September 7, 2021 at https://www.dot.state.al.us/projects/nregion/morganprojects.html. ALNHP (Alabama Natural Heritage Program). 2021. Rare Species Lists by County, Limestone County. Accessed September 8, 2021 at www.auburn.edu/cosam/natural_history_museum/alnhp/data/index.htm. Amaker T. 2021. Browns Ferry Nuclear Mussel Survey, Limestone County, Alabama. July 12-13, 2021. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-97

Appendix E - Applicants Environmental Report-Operating License Renewal Stage ASME/ANS. 2009. Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications. ASME/ANS RA-Sa-2009. Addendum A to RA-S-2008. February 2009. Benton PhD, D.J. 2001. TVA's Browns Ferry Nuclear Plant Thermal/Hydraulic Model. Accessed September 9, 2021 at http://dudleybenton.altervista.org/publications/Browns%20Ferry%20Thermal%20Dischar ge%20Model.pdf. BLS (Bureau of Labor Statistics). 2021. Injuries, Illnesses, and Fatalities. Table 1. Incidence rates of nonfatal occupational injuries and illnesses by industry and case types, 2020. Accessed October 13, 2022 at https://www.bls.gov/web/osh/summ1_00.htm. Carter L., A. Terando, K. Dow, K. Hiers, K.E. Kunkel, A. Lascurain, D. Marcy, M. Osland and Schramm P. 2018. Southeast. In Impacts, Risks, and Adaptation in the United States: Fourth National Climate Assessment, Volume II. [Reidmiller, D.R., C.W. Avery, D.R. Easterling, K.E. Kunkel, K.L.M. Lewis, T.K. Maycock, and B.C. Stewart (eds.)]. U.S. Global Change Research Program, Washington, DC, USA, pp. 743-808. doi: 10.7930/NCA4.2018.CH19. CDC (Centers for Disease Control and Prevention). 2017. Primary Amebic Meningoencephalitis (PAM) - Naegleria fowleri - Pathogen and Environment. Accessed September 8, 2021 at https://www.cdc.gov/parasites/naegleria/pathogen.html. CDC. 2020. Primary Amebic Meningoencephalitis (PAM) - Naegleria fowleri - Frequently Asked Questions. Accessed September 8, 2021 at https://www.cdc.gov/parasites/naegleria/general.html. City of Decatur Alabama. 2018. Comprehensive Plan. Decatur, Alabama. February 2018. CNS and GEL Labs (Chesapeake Nuclear Services Inc. and GEL Laboratories). 2021. 2020 Annual Radiological Environmental Operating Report. Tennessee Valley Authority Browns Nuclear Plant. May 2021. CNS and GEL Labs (Chesapeake Nuclear Services Inc. and GEL Laboratories). 2022. 2021 Annual Radiological Environmental Operating Report. May. CRP (Cummings Research Park). 2016. Final CRP Master Plan. Accessed September 8, 2021 at https://issuu.com/hsvchamber/docs/crp_master_plan. CRP. 2021a. Cummings Research Park. Sites for Development. Accessed September 3, 2021 at https://cummingsresearchpark.com/move-to-the-park/development/. CRP. 2021b. Cummings Research Park. The Nations second largest Research Park. Accessed September 3, 2021 at https://cummingsresearchpark.com/. DOE (U.S. Department of Energy). 2015. Climate Change and the U.S. Energy Sector: Regional Vulnerabilities and Resilience Solutions. October 2015. Ensafe. 2012. Environmental Sound Pressure Level Assessment Report Browns Ferry Nuclear Plant Revision 1. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-98

Appendix E - Applicants Environmental Report-Operating License Renewal Stage First Street Foundation. 2023. Risk Factor - Does 35611 have risk? Alabama Flood Factor Report. Accessed February 26, 2023 at https://riskfactor.com/zip/35611-al/35611_fsid/flood. Geosyntec. 2013. Browns Ferry Nuclear Plant Conceptual Site Model Revision 0. Browns Ferry Nuclear Plant. Athens, Alabama. March. Gharpure Radhika, Gleason Michelle, Salah Zainab, Blackstock Anna J., Hess-Homeier David, Yoder Jonathan S. , Ali Ibne Karim M., Collier Sarah A. and Cope Jennifer R. 2021. Geographic Range of Recreational Water-Associated Primary Amebic Meningoencephalitis, United States, 1978-2018 Emerging Infectious Diseases. Volume 27(Issue 1). Hayhoe K., J. Edmonds, R.E. Kopp, A.N. LeGrande, B.M. Sanderson, M.F. Wehner and Wuebbles D.J. 2017. In: Climate models, scenarios, and projections. Climate Science Special Report: Fourth National Climate Assessment. Vol. 1: 133-160. DOI: 10.7930/J0WH2N54. Huntsville. 2018. The Big Picture. Interactive Land Use Plan. Last Modified November 20, 2018. Accessed September 3, 2021 at https://bigpicturehuntsville.com/process/land-use/. IPCC (Intergovernmental Panel on Climate Change). 2023. Synthesis Report of the IPCC Sixth Assessment Report (AR6). March 2023. Janasie J.D. LL.M., Catherine. 2014. Climate Resiliency on Dauphin Island, Alabama. Sea Grant Law and Policy Journal. 6(2): 54-72. JH (Jensen Hughes). 2018. Browns Ferry MELLLA+ Risk Assessment. Report 06043.000-RPT-13142. January 2018. Limestone County. 2021. Industrial Development. Accessed September 7, 2021 at https://limestonecounty-al.gov/departments/industrial-development/ Martin M. 2013. A Vision for Athens: A Future Land Use and Development Plan. December 2013. Melillo Jerry M., Terese (T.C.) Richmond and Gary W. Yohe Eds. 2014. Climate Change Impacts in the United States: The Third National Climate Assessment. U.S. Global Change Research Program. NatureServe Explorer. 2022. Species-specific search results for spring pygmy sunfish, slackwater darter, Tuscumbia darter, paddlefish, osprey, and monarch butterfly. Accessed at https://explorer.natureserve.org/Search. NEI (Nuclear Energy Institute). 2019. Model SLR New and Significant Assessment Approach for SAMA. NEI 17-04 Revision 1. August 2019. NEI (Nuclear Energy Institute). 2022. Nuclear Energy Fact Sheet 2022. Accessed May 11, 2022 at https://www.nei.org/resources/map-of-us-nuclear-plants. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-99

Appendix E - Applicants Environmental Report-Operating License Renewal Stage NETL (National Energy Technology Laboratory). 2006. Emerging Issues for Fossil Energy and Water. Investigation of Water Issues Related to Coal Mining, Coal to Liquids, Oil Shale, and Carbon Capture and Sequestration. DOE/NETL-2006/1233. June. Newsum, K. 2023. FBI Director confirms expansion on Redstone Arsenal. WHNT News. Accessed November 2, 2023 at https://whnt.com/news/redstone-arsenal/fbi-director-confirms-expansion-on-redstone-arsenal/. NextEra. 2016. NextEra Energy Seabrook, LLC (Seabrook Station, Unit 1), CLI-16-03, 83 NRC 52, 55. ML16056A088. February 2016. NOAA (National Oceanic and Atmospheric Administration). 2022. State Climate Summaries 2022 150-AL (Alabama). Accessed May 10, 2023 at https://statesummaries.ncics.org/chapter/al/. NRC (Nuclear Regulatory Commission). 1990. Severe Accident Risks: An Assessment for Five U.S. Nuclear Power Plants. NUREG-1150. NRC. 1992. Integrated risk assessment for the LaSalle Unit 2 nuclear power plant. NUREG/CR-5305. NRC. 1996. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG-1437, Volume 1. May 1996. Accessed January 9, 2023. NRC. 1999. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. " Section 6.3-Transportation and Table 9.1 Summary of findings on NEPA issues for license renewal of nuclear power plants." NUREG-1437, Vol. 1, Addendum I. August 1999. NRC. 2002. Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Regarding the Decommissioning of Nuclear Power Reactors. NUREG-0586, Supplement 1, Volume 1: Main Report, Appendices A though M. November 2022. NRC. 2005. Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3. NUREG-1437, Supplemental

21. June 2005.

NRC. 2006. Safety Evaluation Report Related to the License Renewal of the Browns Ferry Nuclear Plant, Units 1, 2, and 3. Docket Nos. 50-259, 50-260, and 50-296. April 2006. NRC. 2013. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG-1437, Volume 1, Revision 1. Office of Nuclear Reactor Regulation. June 2013. NRC. 2014. Generic Environmental Impact Statement for Continued Storage of Spent Nuclear Fuel. Final Report. NUREG-2157, Volume 1. Office of Nuclear Material Safety and Safeguards. September. NRC. 2017. Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Issuance of Amendments Regarding Extended Power Uprate (CAC Nos. MF6741, MF6742, and MF6743). August 14, 2017. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-100

Appendix E - Applicants Environmental Report-Operating License Renewal Stage NRC. 2019. Supplement to TVA Request for Revision of Modifications 85, 102, and 106 Related to NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants for the Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Tables S-2 and B-1. ADAMS Accession Number ML19044A708. February 13, 2019. NRC. 2022. Occupational Radiation Exposure at Commercial Nuclear Power Reactors and Other Facilities 2019 Fifty-Second Annual Report. NUREG-0713, Volume 41. April 2022. Redstone Gateway. 2020. Redstone Gateway. Where the future works. Accessed January 5, 2022 at https://redstonegateway.com/wp-content/uploads/2020/11/RG_brochure_e.pdf. Runkle J., K.E. Kunkel, L.E. Stevens, R. Frankson and Rayne Sandra. 2022. Alabama State Climate Summary 2022. NOAA Technical Report NESDIS 150-AL. NOAA/NESDIS, Silver Spring, MD. Accessed May 16, 2023 at https://statesummaries.ncics.org/chapter/al/. Sharkey J.K. and Springston G.L. 2022. Water Use in the Tennessee Valley for 2020 and Projected Use in 2045. Tennessee Valley Authority. River & Resources Stewardship. August 2022. Simmons J.W. 2019. Recent Advances in the Understanding of the Distribution and Status of the Snail Darter (Percina tanasi). April 2019. State of Alabama. 2018. Alabama State Hazard Mitigation Plan. July 18, 2018. State of Tennessee. 2022. Tennessee Valley Authoritys Payments in Lieu of Taxes: Annual Report to the Tennessee General Assembly. January. TVA (Tennessee Valley Authority). 2003. Applicant's Environmental Report - Operating License Renewal Stage, Browns Ferry Nuclear Plant Units 1, 2, and 3. December 2003. TVA. 2004. Reservoir Operations Study. Final Programmatic Environmental Impact Statement and Record of Decision. May. TVA. 2006. Browns Ferry Nuclear Plant Investigation of Tritium Releases to Groundwater. June 2006. TVA. 2017a. Browns Ferry Nuclear Plant 2016 Annual Radioactive Effluent Release Report. April 28, 2017. TVA. 2017b. Browns Ferry Nuclear Plant - Plant Intake Maintenance Dredging, Project Number 37680, National Environmental Policy Act (NEPA) Categorical Exclusion Checklist (CEC). November. TVA. 2018a. Browns Ferry Nuclear Plant 2017 Annual Radioactive Effluent Release Report. April 30, 2018. TVA. 2018b. Categorical Exclusion Checklist for Proposed TVA Actions - Intake Channel Dredging. October. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-101

Appendix E - Applicants Environmental Report-Operating License Renewal Stage TVA. 2019. Browns Ferry Nuclear Plant 2018 Annual Radioactive Effluent Release Report. April 30, 2019. TVA. 2020a. Browns Ferry Nuclear Plant 2019 Annual Radioactive Effluent Release Report. April 30, 2020. TVA. 2020b. Clean Water Act Section 316(b) § 122.21(r)(9) Entrainment Characterization Study for the Browns Ferry Nuclear Plant. River and Reservoir Compliance Monitoring Program. TVA. 2020c. Alabama Department of Environmental Management (ADEM) NPDES/SID Non-Compliance Notification Form. July 20, 2020. TVA. 2021a. Browns Ferry Nuclear Plant 2020 Annual Radioactive Effluent Release Report. April 30, 2021. TVA. 2021b. Clean Water Act Section 316(b) § 122.21(r) Compliance Documentation for the Browns Ferry Nuclear Plant, Limestone County, Alabama. April. TVA. 2021c. Evaluating the Presence and Maintenance of a Balanced Indigenous Population of Fish and Wildlife in the Tennessee River Downstream of TVAs Browns Ferry Nuclear Plant. June. TVA. 2022a. Browns Ferry Nuclear Plant 2021 Annual Radioactive Effluent Release Report. May 2, 2022. TVA. 2022b. Tennessee Valley Authority Browns Ferry Nuclear Power Plant National Pollutant Discharge Elimination System (NPDES) Permit No. AL0022080. Updated Final §316(b) Rule Information 40 CFR 122.21(r)(10) Submittal. January. TVA. 2023a. 2022 Annual Radiological Environmental Operating Report. Tennessee Valley Authority Browns Ferry. May 15, 2023. TVA. 2023b. Browns Ferry Nuclear Plant 2022 Annual Radioactive Effluent Release Report. May 1, 2023. USCB (U.S. Census Bureau). 2020a. Alabama Table P2 Hispanic or Latino, and Not Hispanic or Latino By Race - Block Groups. Accessed October 27, 2022 at https://data.census.gov/cedsci/table?q=United%20States&g=0100000US_0500000US0 1009%241500000,01033%241500000,01043%241500000,01059%241500000,01071% 241500000,01077%241500000,01079%241500000,01083%241500000,01089%241500 000,01093%241500000,01095%241500000,01103%241500000,01127%241500000,01 133%241500000&y=2020&d=DEC%20Redistricting%20Data%20%28PL%2094-171%29&tid=DECENNIALPL2020.P2. USCB. 2020b. B17021 Poverty Status Of Individuals In The Past 12 Months By Living Arrangement - Alabama. 2016-2020 American Community Survey. Accessed October 27, 2022 at https://data.census.gov/cedsci/table?q=B17021%3A%20POVERTY%20STATUS%20OF

     %20INDIVIDUALS%20IN%20THE%20PAST%2012%20MONTHS%20BY%20LIVING%

20ARRANGEMENT&g=0100000US_0500000US01009%241500000,01033%24150000 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-102

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 0,01043%241500000,01059%241500000,01071%241500000,01077%241500000,0107 9%241500000,01083%241500000,01089%241500000,01093%241500000,01095%241 500000,01103%241500000,01127%241500000&tid=ACSDT5Y2020.B17021. USCB. 2020c. B17021 Poverty Status Of Individuals In The Past 12 Months By Living Arrangement - Tennessee. Accessed October 27, 2022 at https://data.census.gov/cedsci/table?q=B17021%3A%20POVERTY%20STATUS%20OF

     %20INDIVIDUALS%20IN%20THE%20PAST%2012%20MONTHS%20BY%20LIVING%

20ARRANGEMENT&g=0100000US_0500000US47051%241500000,47055%24150000 0,47099%241500000,47103%241500000,47117%241500000,47119%241500000,4718 1%241500000. USCB. 2020d. Tennessee Table P2 Hispanic or Latino, and Not Hispanic or Latino By Race - Block Groups. Accessed October 27, 2022 at https://data.census.gov/cedsci/table?q=United%20States&g=0100000US_0500000US4 7051%241500000,47055%241500000,47099%241500000,47103%241500000,47117% 241500000,47119%241500000,47181%241500000&y=2020&d=DEC%20Redistricting% 20Data%20%28PL%2094-171%29&tid=DECENNIALPL2020.P2. USEPA (U.S. Environmental Protection Agency). 2020. Alabama NPDES Permits. Accessed September 20, 2021 at https://www.epa.gov/npdes-permits/alabama-npdes-permits. USFWS (U.S. Fish and Wildlife Service). 2007. National Bald Eagle Management Guidelines. May. USFWS. 2020. Monarch (Danaus plexippus) Species Status Assessment Report, version 2.1. September. USFWS. 2022. Information for Planning and Consultation (IPaC). Accessed October 27, 2022 at https://ipac.ecosphere.fws.gov/. USFWS and NMFS (U.S. Fish and Wildlife Service and National Marine Fisheries Service). 1998. Endangered Species Act Consultation Handbook: Procedures for Conducting Section 7 Consultations and Conferences. March. USGCRP (U.S. Global Change Research Program). 2018. Impacts, Risks, and Adaptation in the United States: Fourth National Climate Assessment. Volume II. [Reidmiller, D.R., C.W. Avery, D.R. Easterling, K.E. Kunkel, K.L.M. Lewis, T.K. Maycock, and B.C. Stewart (eds.)]. Washington, DC. June 2019. WMEL (West Morgan -East Lawrence Water and Sewer Authority). 2021. Courtland Grant Project. Accessed September 8, 2021 at https://wmel.org/courtland-grant-project/. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E4-103

Appendix E - Applicants Environmental Report-Operating License Renewal Stage CHAPTER 5 - ASSESSMENT OF NEW AND SIGNIFICANT INFORMATION The Nuclear Regulatory Commission (NRC) licenses operation of domestic nuclear power plants and provides for license renewal, requiring a license renewal application that includes an environmental report (10 Code of Federal Regulations [CFR] 54.23). NRC regulations, 10 CFR Part 51, prescribe the environmental report content and identify the specific analyses the applicant must perform. In February 2022, the NRC ruled that the 2013 Generic Environmental Impact Statement (GEIS) (NRC 2013a) which resolved most environmental issues generically (Category 1) for all plants, was not sufficient for subsequent license renewal (SLR) applications. The NRC initiated a rulemaking to amend Table B-1 of Appendix B, Summary of Findings on NEPA Issues for License Renewal of Nuclear Power Plant, to Subpart A, National Environmental Policy Act - Regulations Implementing Section 102(2), of Part 51 of Title 10 of the Code of Federal Regulations (10 CFR), Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions. NUREG-1437 provides the technical and regulatory basis for Table B-1 (NRC 2013a). Consequently, NUREG-1437 will also be updated. The NRC held that the 2013 license renewal GEIS was only acceptable to address the impacts of initial 20-year license renewal periods and that the Table B-1 Category 1 conclusions could not be credited in an SLR application. Because the NRC is reviewing and amending the GEIS with respect to the subsequent period of extended operation, the GEIS Category 1 findings can no longer be applied generically and this Environmental Report (ER) will evaluate each Category 1 issue based on the specific characteristics of the Browns Ferry Nuclear Plant (BFN). Due to the length of time that will be required to implement the new rulemaking, this ER fully evaluates each GEIS Category 1 issue on a site-specific basis, as is done for GEIS Category 2 issues. NRC regulations require an applicant identify any new and significant information of which the applicant is aware that relates to Category 1 issues which previously were generically evaluated in the GEIS [10 CFR 51.53(c)(3)(iv)]. The Tennessee Valley Authority (TVA) new and significant information process was designed to evaluate whether new information for the previously identified GEIS Category 1 issues exists. The N&SI process was then used to inform the evaluation of Category 1 issues in Chapter 4 of this ER. 5.1. New and Significant Information The NRC provides guidance on new and significant information in Regulatory Guide 4.2, Supplement 1, Revision 1 (NRC 2013b). Based on this guidance, new and significant information would include:

Information that identifies a significant environmental impact issue not covered in the GEIS and consequently not codified in the regulation,
Information not considered in the assessment of impacts evaluated in the GEIS leading to a seriously different picture of the environmental consequences of the action than previously considered, such as an environmental impact finding different from that codified in the regulation, or Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E5-1

Appendix E - Applicants Environmental Report-Operating License Renewal Stage

Any new activity or aspect associated with the nuclear power plant that can act upon the environment in a manner or an intensity and/or scope (context) not previously recognized.

Additionally, based on the definitions of SMALL, MODERATE, and LARGE impacts provided by NRC in 10 CFR Part 51, Appendix B, Table B-1, Footnote 3, TVA considered that MODERATE or LARGE impacts would be significant. Therefore, only new information that would suggest a change from SMALL impacts to either MODERATE or LARGE impacts for a Category 1 issue considered in the GEIS, or an issue not considered in the GEIS with MODERATE or LARGE impacts, would be considered significant. Chapter 4 presents the definitions of SMALL, MODERATE, and LARGE impacts that TVA used in the evaluation. 5.2. New and Significant Information Review Process TVA's N&SI assessment process is collectively carried out through its ongoing environmental planning, assessment, monitoring, and compliance activities performed by TVA and BFN management and staff and environmental report-specific reviews. TVAs team for the review of N&SI has collective knowledge of the license renewal process, the site, licensing and permitting, environmental issues, the first license renewal of BFN, the National Environmental Policy Act (NEPA) process, and nuclear industry activities. This team has implemented the in-house process for reviewing and evaluating environmental issues which could potentially be N&SI. TVA's new and significant review included establishment of applicable and non-applicable Category 1 issues through:

Review of the TVA initial license renewal ER (TVA 2003) and related NRC supplemental environmental impact statement (SEIS) (NRC 2005); the TVA initial license renewal SEIS (TVA 2002); and the GEIS Category 1 issues discussion (NRC 2013a).
Review of publicly available information, or information held by TVA, related to the resource area and each applicable Category 1 impact issue, as summarized in the appropriate section of Chapter 3.
Identification and review of past or potential modifications to BFN, since the most recent licensing environmental review, and if any, those anticipated during the subsequent period of extended operation, including refurbishment. However, the BFN SLR does not require any new construction or modifications beyond normal maintenance and TVA has no plans for refurbishment activities, outside of normal maintenance at BFN associated with SLR.
Identification and assessment of equipment and operations with the potential to result in changes in emissions, releases, discharge points, land use, noise levels, etc. considering environmental reviews since initial license renewal, and those anticipated during the subsequent period of extended operations.

In preparation of this SLR application, TVA implemented an investigative process to seek N&SI related to Category 1 environmental issues through:

Interviews with TVA subject matter experts on the Category 1 issues and the validity of the conclusions in the GEIS as they relate to BFN; Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E5-2

Appendix E - Applicants Environmental Report-Operating License Renewal Stage

Review of permits and reference documents related to the regulatory compliance status of the plant, environmental issues at BFN and Wheeler Reservoir, and the environmental resource areas related to Category 1 issues;
Review of BFN environmental monitoring and reporting required by regulations;
Review of BFN environmental programs and procedures;
Review of correspondence and permitting documentation as relating to oversight of BFN facilities and operations by state and federal regulatory agencies (activities that would bring significant issues to the plant's attention), to identify site-specific environmental concerns;
Review of recent license renewal applications for issues relevant to this BFN SLR application;
Review of previous licensing actions at BFN including the Extended Power Uprate License Amendment Request submitted to NRC in 2015 (TVA 2015); and
Consultation with state and federal agencies about potential BFN effects on resources within their specific jurisdictions.

In addition, TVA is made aware of and stays informed of new and emerging environmental issues and concerns on an ongoing basis through the following:

Review of nuclear industry publications, operational experience, and participation in nuclear industry organizations such as Electric Power Research Institute and Nuclear Energy Institute;
Review of correspondence and permitting documentation and discussions related to oversight of BFN facilities and operations by state and federal regulatory agencies in their role in identifying site-specific environmental concerns;
Contact with state and federal resource agencies with regulatory jurisdiction over environmental regulation; and
Development and periodic review of regulatory guidance procedures that address ongoing and emergent issues.

Information resulting from the information-seeking process was assessed to determine if it is new and significant, applying the following considerations:

Was the information included in or available for the GEIS analysis of the Category 1 issue?
Was the information included in or available for the SEIS for BFN initial license renewal?
Does the information identify an environmental issue not generically considered in the GEIS and, consequently, not codified in 10 CFR Part 51, Appendix B, Table B-1?
Does the information present a seriously different picture of the environmental consequences of the action than previously considered, leading to an impact finding different (i.e., MODERATE or LARGE) from that included in the GEIS or codified in regulation?

Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E5-3

Appendix E - Applicants Environmental Report-Operating License Renewal Stage

Does the information involve a new activity or aspect associated with the nuclear power plant that can act upon the environment in a manner or an intensity (MODERATE or LARGE impact) and/or scope (context) not previously recognized?

As a result of this review, TVA did not identify any N&SI regarding the BFN environment or operations that would alter the SMALL, MODERATE, or LARGE impact findings for Category 1 issues. Each resource section in Chapter 4 contains a table that lists each applicable Category 1 issue and indicates sections of this ER that contain BFN information relevant to the assessment for N&SI about each issue. The findings in NUREG-1437, Revision 1, for the applicable Category 1 issues, are incorporated in the respective tables. N&SI review methodology and results for the Severe Accident Mitigation Alternatives evaluation are addressed separately in Section 4.10.2. TVA did identify new information in the form of NRCs draft Revision 2 to NUREG-1437 (GEIS) which includes two proposed changes related to climate change. Revision 2 of the GEIS proposes to add one new Category 1 issue Greenhouse gas impacts on climate change and one new Category 2 issue Climate change impacts on environmental resources. Though Revision 2 remains in Draft form, TVA elected to consider climate change as new information which is addressed in Section 4.13. TVA did not identify any N&SI related to climate change that would alter the NRC impact findings in the proposed Revision 2 of the GEIS. 5.3. References NRC. 2005. Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3. NUREG-1437, Supplemental

21. June 2005.

NRC. 2013a. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG-1437, Volume 1, Revision 1. Office of Nuclear Reactor Regulation. June 2013. NRC. 2013b. Preparation of Environmental Reports for Nuclear Power Plan License Renewal Applications. Regulatory Guide 4.2, Supplemental 1, Revision 1. June 2013. TVA (Tennessee Valley Authority). 2002. Final Supplemental Environmental Impact Statement for Operating License Renewal of the Browns Ferry Nuclear Plant in Athens, Alabama. March 2002. TVA. 2003. Applicant's Environmental Report - Operating License Renewal Stage, Browns Ferry Nuclear Plant Units 1, 2, and 3. December 2003. TVA. 2015. Supplemental Environmental Report for the Browns Ferry Nuclear Plant Extended Power Uprate for Units 1, 2, and 3. Attachment 38. September. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E5-4

Appendix E - Applicants Environmental Report-Operating License Renewal Stage CHAPTER 6 -

SUMMARY

OF LICENSE RENEWAL IMPACTS AND MITIGATING ACTIONS 6.1. License Renewal Impacts The Tennessee Valley Authority (TVA) has reviewed the environmental impacts of the subsequent license renewal (SLR) of the Browns Ferry Nuclear Plant (BFN) and has concluded all impacts are SMALL and will not require mitigation beyond existing levels. This Environmental Report (ER) documents the basis for TVAs conclusions. Chapter 4 presents BFN site-specific analyses of both Category 1 and Category 2 issues identified by the U.S. Nuclear Regulatory Commissions (NRC) 2013 Generic Environmental Impact Statement (GEIS) license renewal in Appendix B to Subpart A of Title 10 of the Code of Federal Regulations (CFR) Part 51, Table B-1, all of which have impacts that are SMALL or not applicable to BFN. In accordance with Appendix B to Subpart A of 10 CFR Part 51, Table B-1, footnote 6, the uncategorized issue related to chronic health effects of electromagnetic fields (EMFs) is described without evaluation in Section 4.9.6. For the issue of severe accidents, TVA previously submitted a Severe Accident Mitigation Alternatives (SAMA) analysis to the NRC as part of the initial license renewal application. TVA has performed a SAMA evaluation for all three units in accordance with the Nuclear Energy Institute (NEI) 17-04, Rev. 1 methodology. The SAMA analysis is provided in Section 4.10 of this ER. Table 6.1-1 identifies the impacts that the BFN SLR will have on resources associated with the 2013 GEIS Category 1 and 2 issues. Table 6.1-1. Environmental Impacts Related to License Renewal at BFN GEIS Issue SLR-ER Section Environmental Impact Land Use and Visual Resources Onsite land use 3.1.2; SMALL 4.1.1 Offsite land use 3.1.1; SMALL 4.1.2 Offsite land use in transmission line 2.2.6; None. All in-scope transmission lines rights of way (ROWs) 4.1.3 are onsite at BFN. Aesthetic impacts 3.1.3; SMALL 4.1.4 Air Quality Air quality impacts 3.2.5; 4.2.1 SMALL (all plants) Air quality effects of transmission lines 3.2.5; SMALL 4.2.2 Noise Noise Impacts 3.3; SMALL 4.3 Geology and Soils Geology and Soils 3.4; SMALL 4.4 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E6-1

Appendix E - Applicants Environmental Report-Operating License Renewal Stage GEIS Issue SLR-ER Section Environmental Impact Surface Water Resources Surface water use and quality (non- 3.5.1; SMALL cooling system) 4.5.1.1 Altered current patterns at intake and 3.5.1; SMALL discharge structures 4.5.1.2 3.5.1; None. Wheeler Reservoir is not an Altered salinity gradients 4.5.1.3 estuary. 3.5.1; Altered thermal stratification of lakes SMALL 4.5.1.4 Scouring caused by discharged cooling 3.5.1; SMALL water 4.5.1.5 Discharge of metals in cooling system 3.5.1.3; SMALL effluent 4.5.1.6 Discharge of biocides, sanitary wastes, 3.5.1.3; SMALL and minor chemical spills 4.5.1.7 Surface water use conflicts (plants with 3.5.1.2; SMALL Once-Through Cooling systems) 4.5.1.8 None. This issue does not apply as Surface water use conflicts (plants with 3.5.1.2; BFN uses a once-though cooling cooling ponds or cooling towers using 4.5.1.9 water system and no water is makeup water from a river) withdrawn for use as makeup water. Effects of dredging on surface water 4.5.1.10 SMALL quality Temperature effects on sediment 3.5.1.3, SMALL transport capacity 4.5.1.11 Groundwater Resources Groundwater contamination and use 3.5.2.2; 3.5.2.3; SMALL (non-cooling system impacts) 4.5.2.1 Groundwater use conflicts (plants that 3.5.2; withdraw less than 100 gallons per SMALL 4.5.2.2 minute [gpm]) NONE. The issue does not apply Groundwater use conflicts (plants that 4.5.2.3 because the plant does not use withdraw more than 100 gpm) groundwater. NONE. The issue does not apply Groundwater use conflicts (plants with because the plant does not use a closed-cycle cooling systems that 4.5.2.4 closed-cycle cooling system and does withdraw makeup water from a river) not withdraw from the river for makeup water. NONE. The issue does not apply Groundwater quality degradation 4.5.2.5 because the plant does not use resulting from water withdrawals groundwater. NONE. The issue does not apply Groundwater quality degradation (plants 3.5.2; because BFN does not use cooling with cooling ponds in salt marshes) 4.5.2.6 ponds. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E6-2

Appendix E - Applicants Environmental Report-Operating License Renewal Stage GEIS Issue SLR-ER Section Environmental Impact NONE. The issue does not apply Groundwater quality degradation (plants 3.5.2.3; because BFN does not use cooling with cooling ponds at inland sites) 4.5.2.7 ponds. 3.5.2.3; Radionuclides released to groundwater. SMALL 4.5.2.8 Ecological Resources Effects on terrestrial resources (non- 3.6.1; SMALL cooling system impacts) 4.6.1.1 Exposure of terrestrial organisms to 3.6.1; SMALL radionuclides 4.6.1.2 Cooling tower impacts on terrestrial 3.6.1; resources (plants with once-through SMALL 4.6.1.3 cooling systems or cooling ponds. Cooling tower impacts on vegetation 3.6.1; SMALL (plants with cooling towers) 4.6.1.4 Bird collisions with plant structures and 3.6.1; SMALL transmission lines 4.6.1.5 Water use conflicts with terrestrial resources (plants with cooling ponds or 4.6.1.6 SMALL cooling towers using makeup water from a river) Transmission line ROW management 2.2.6.1; 3.6.1; SMALL impacts on terrestrial resources 4.6.1.7 Electromagnetic fields on flora and 2.2.6.1; fauna (plants, agricultural crops, SMALL 4.6.1.8 honeybees, wildlife, livestock) Impingement and entrainment of aquatic organisms (plants with once-4.6.2.1 SMALL through cooling systems or cooling ponds) Impingement and entrainment of 4.6.2.1; aquatic organisms (plants with cooling SMALL 4.6.2.2 towers) Entrainment of phytoplankton and 3.6.2; 4.6.2.1; SMALL zooplankton 4.6.2.3 Thermal impacts on aquatic organisms (plants with once- through cooling 4.6.2.4 SMALL systems or cooling ponds) Thermal impacts on aquatic organisms 2.2.3; 4.6.2.4; SMALL (plants with cooling towers) 4.6.2.5 3.5.1.1; 3.5.1.3; Infrequently reported thermal impacts SMALL 3.6.2; 4.6.2.6 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E6-3

Appendix E - Applicants Environmental Report-Operating License Renewal Stage GEIS Issue SLR-ER Section Environmental Impact Effects of cooling water discharge on 2.2; 3.5.1.3; dissolved oxygen, gas supersaturation, SMALL 3.5.2.3; and eutrophication 4.6.2.7 Effects of non-radiological contaminants 2.2.5; 3.6.2; SMALL on aquatic organisms 4.6.2.8 Exposure of aquatic organisms to 2.2.4.1; 3.6.2; SMALL radionuclides 4.6.2.9 Effects of dredging on aquatic 4.6.2.10 SMALL resources Water use conflicts with aquatic resources (plants with cooling ponds or 2.2; 3.5.1.2; SMALL cooling towers using makeup water 4.6.2.11 from a river) Effects on aquatic resources (non- 2.2; 3.6.2; SMALL cooling system impacts) 4.6.2.12 2.2.6.1; None. All in-scope transmission lines Impacts of transmission line ROW 3.6.2; are onsite at BFN and do not cross management on aquatic resources 4.6.2.13 aquatic resources. Losses from predation, parasitism, and 3.6.2; disease among organisms exposed to SMALL 4.6.2.14 sublethal stresses Impacts range from NO EFFECT to NOT LIKELY TO ADVERSELY Threatened, endangered, and protected 3.6.1.4; AFFECT threatened or endangered 3.6.2.4; species and EFH 4.6.3 species. No critical habitat has been designated for any federal listed species in the project vicinity. Historic and Cultural Resources Historic and cultural resources 3.7; NO ADVERSE EFFECT 4.7 Socioeconomics Employment and income, recreation, 3.8; SMALL and tourism 4.8.1 Tax revenues 3.8.1; SMALL 4.8.2 Community services and education 3.8.1; SMALL 4.8.3 Population and housing 3.8.1; SMALL 4.8.4 Transportation 3.8.2; SMALL 4.8.5 Human Health Radiation exposures to the public 3.9.1; SMALL 4.9.1 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E6-4

Appendix E - Applicants Environmental Report-Operating License Renewal Stage GEIS Issue SLR-ER Section Environmental Impact Radiation exposures to plant workers 3.9.1; SMALL 4.9.2 Human health impact from chemicals 4.9.3 SMALL Microbiological hazards to the public (plants with cooling ponds or canals or 3.9.2; SMALL 4.9.4 cooling towers that discharge to a river) Microbiological hazards to plant workers 3.9.2; SMALL (occupational health) 4.9.5 Chronic effects of electromagnetic fields 4.9.6 UNCERTAIN (EMFs) Physical occupational hazards SMALL 4.9.7 2.2.6; Electric shock hazards 3.9.3; SMALL 4.9.8 Postulated Accidents Design-basis accidents 4.10.1 SMALL Severe accidents 4.10.2 SMALL Environmental Justice Minority and low-income populations 3.10.1; 3.10.2; SMALL 4.11.1 Waste Management Low-level waste storage and disposal 2.2.4.5; SMALL 4.12.1 Onsite storage of spent nuclear fuel 2.2.4.4; SMALL 4.12.2 Offsite radiological impacts of spent 4.12.3 nuclear fuel and high-level waste SMALL disposal Mixed waste storage and disposal 2.2.4; SMALL 4.12.4 Nonradioactive waste storage and 2.2.5; 4.12.5 SMALL disposal Greenhouse Gas Emissions and Climate Change Greenhouse gas emissions and climate 3.2.4 4.2.1 SMALL change Cumulative Impacts Cumulative impacts 4.13 SMALL Uranium Fuel Cycle Offsite radiological impacts individual 4.14.1 impacts from other than the disposal of SMALL spent fuel and high-level waste Offsite radiological impacts collective 4.14.2 impacts from other than the disposal of SMALL spent fuel and high-level waste Non-radiological impacts of the uranium 4.14.3 SMALL fuel cycle Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E6-5

Appendix E - Applicants Environmental Report-Operating License Renewal Stage GEIS Issue SLR-ER Section Environmental Impact Transportation 4.14.4 SMALL Termination of Nuclear Plant Operations and Decommissioning Termination of nuclear plant operations 4.15 SMALL and decommissioning 6.2. Mitigation Chapter 4 in this ER concludes impacts of BFN subsequent license renewal activities are SMALL for issues to which the NRC applies the levels SMALL, MODERATE or LARGE as a measure of significance. Federally listed threatened or endangered species are determined not likely to be adversely affected by SLR activities. Impacts to cultural resources are determined to be SMALL. Also, Chapter 4 reports no new and significant information has been identified for any applicable Category 1 issue; all Category 1 issues have been analyzed and impacts found to be SMALL or not applicable to BFN. TVA previously submitted a SAMA analysis to the NRC as part of the initial license renewal application. TVA has performed a SAMA evaluation for all three units in accordance with the NEI 17-04, Rev. 1 methodology. The SAMA analysis is provided in Section 4.10 of this ER. Chapter 5 indicates no new and significant issues have been identified. Current operations include monitoring activities that will continue during the subsequent period of extended operation. TVA performs routine monitoring to ensure the safety of workers, the public, and the environment. These activities include gaseous and liquid radiological release monitoring and environmental monitoring in accordance with the BFN operating license technical specifications issued by the NRC, groundwater monitoring in accordance with the BFN Radiological Groundwater Protection Program, effluent monitoring in accordance with the National Pollutant Discharge Elimination System (NPDES) permit issued by the Alabama Department of Environmental Management (ADEM), and monitoring of consumptive use. These programs ensure that BFNs emissions and effluents are within regulatory limits, and that unusual or off-normal emissions are quickly detected, thus mitigating potential impacts. Because all impacts of the BFN SLR are SMALL (or not applicable to BFN), consideration of alternatives for achieving further mitigation is not necessary. TVA acknowledges, as described in Section 4.6.2.1, the existing cooling water intake structure (CWIS) represents the interim best technology available (40 CFR 125.98(b)(5)) to minimize adverse environmental impacts from impingement and entrainment in accordance with Section 316(b) of the Clean Water Act (33 United States Code. 1326). Furthermore, BFN is required to operate and maintain the CWIS in a manner that minimizes impingement and entrainment, thereby mitigating ecological impacts from operation of the CWIS. 6.3. Unavoidable Adverse Impacts Because the NRC is reviewing and amending the 2013 GEIS with respect to the subsequent period of extended operation, the GEIS Category 1 findings can no longer be applied generically and this ER evaluated each Category 1 issue based on the specific characteristics of BFN. TVA also examined all Category 2 issues identified in the GEIS to assess site-specific impacts. TVA identified the following unavoidable adverse impacts of SLR activities: Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E6-6

Appendix E - Applicants Environmental Report-Operating License Renewal Stage

Solid radioactive wastes are a product of plant operations and permanent disposal is necessary.
Disposal of nonradioactive and radioactive wastes will result in a SMALL impact as long as BFN is in operation. Disposal procedures for these wastes are intended to reduce adverse impacts to acceptably low levels.
Operation of BFN results in a very small increase in radioactivity in air and water.

However, there are no increases in external radiation or air dose from BFN above measurable background, and emissions to water and groundwater result in doses well below the regulatory allowable level. Operation of BFN also creates a very low probability of accidental radiation exposure to BFN employees and inhabitants of the area.

Operation of BFN results in consumptive use of surface water.
Loss of small numbers of adult and juvenile fish impinged on traveling screens.
Loss of small numbers of larval fish and shellfish entrained at the intake structures.

6.4. Irreversible or Irretrievable Resource Commitments Continued operation of BFN for the subsequent period of extended operation will result in irreversible and irretrievable resource commitments, including the following:

Nuclear fuel, which is used in the reactor and is converted to radioactive waste;
Land required to permanently disposition the spent nuclear fuel offsite, low- level radioactive wastes generated as a result of plant operations, and nonradioactive industrial wastes generated from normal industrial operations;
Elemental materials that will become radioactive; and
Materials used for the normal industrial operations of BFN that cannot be recovered or recycled or that are consumed or reduced to unrecoverable forms.

6.5. Short-Term Use Versus Long-Term Productivity of the Environment The current balance between short-term use and long-term productivity at the BFN site was basically set once the units began operating in the 1970s. The Final Environmental Statement related to the operation evaluated the impacts of operating BFN (TVA 1972). Approximately 13 acres of Wheeler Reservoir was filled or enclosed within the berm surrounding the outer intake structure, discharge basin, and discharge canal (TVA 1972). It is likely that this acreage will not be recovered. However, this represents a small percentage of the total 67,070 acres of water surface in the reservoir (TVA 2021) and does not affect the aquatic habitat in any consequential way. As discussed in Section 3.5.1.2, water resources of Wheeler Reservoir are managed by TVA under comprehensive planning principles through its own programs and through coordination with state and federal agencies. Approximately 388 acres of the approximately 880-acre site have been developed (Table 3.1-2). After decommissioning of the nuclear facilities at the site, most environmental disturbances Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E6-7

Appendix E - Applicants Environmental Report-Operating License Renewal Stage would cease and restoration of the natural habitat could occur. Thus, the trade-off between the production of electricity and changes in the local environment is reversible to some extent. Experience with other commercial nuclear plants has demonstrated the feasibility of decommissioning and dismantling such plants sufficiently to restore a site to its former use (NEI 2016). The degree of dismantlement will take into account the intended new use of the site and a balance among health and safety considerations, salvage values, and environmental impacts. However, decisions on the ultimate disposition of these lands have not yet been made. Continued operation for another 20 years beyond the currently licensed term would not increase the short-term productivity impacts described here. 6.6. References NEI (Nuclear Energy Institute). 2016. Decommissioning Nuclear Power Plants. Fact Sheet. August 2016. Accessed February 10, 2021 at https://nei.org/resources/fact-sheets/decommissioning-nuclear-power-plants. TVA (Tennessee Valley Authority). 1972. Browns Ferry Nuclear Plant Units 1, 2, and 3 Environmental Statement. Volume 1. TVA-OHES-EIS-72-6. September 1972. TVA. 2021. Wheeler Dam Facts and Figures. Accessed September 19, 2021 at https://www.tva.com/energy/our-power-system/hydroelectric/wheeler. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E6-8

Appendix E - Applicants Environmental Report-Operating License Renewal Stage CHAPTER 7 - ALTERNATIVES TO THE PROPOSED ACTION Chapter 7 evaluates alternatives to the Browns Ferry Nuclear Plant (BFN) subsequent license renewal (SLR). The chapter identifies actions that the Tennessee Valley Authority (TVA) might take, and associated environmental impacts, if the Nuclear Regulatory Commission (NRC) does not renew the existing BFN renewed operating licenses. The chapter also addresses alternative actions that TVA has identified, but has concluded will not be taken, and discusses the basis for determining that such actions would be unreasonable. In considering the level of detail and analysis that it should provide for each alternative, TVA relied on the NRC decision-making standard for license renewal: the NRC staff, adjudicatory officers, and Commission shall determine whether or not the adverse environmental impacts of license renewal are so great that preserving the option of license renewal for energy planning decision makers would be unreasonable [10 Code of Federal Regulations [CFR] 51.95(c)(4)]. An Environmental Report (ER) supports NRC decision-making when the document provides sufficient information to clearly indicate whether an alternative would have a smaller, comparable, or greater environmental impact than the Proposed Action. Providing additional detail or analysis serves no function if it only brings to light additional adverse impacts of alternatives to the SLR. This approach is consistent with regulations of the Council on Environmental Quality, which provide that the consideration of alternatives (including the Proposed Action) should enable reviewers to evaluate their comparative merits (40 CFR Parts 1500-1508). Chapter 7 provides sufficient detail about alternatives to establish the basis for necessary comparisons to the Chapter 4 discussion of impacts from the Proposed Action. In characterizing environmental impacts from alternatives, this section uses the same definitions as those presented in the introduction to Chapter 4: for most resources, SMALL, MODERATE, and LARGE; for historic and cultural resources, threatened and endangered species, and wetlands, impact categories are based on those from the applicable regulations. 7.1. No-Action Alternative The No-Action Alternative refers to a scenario in which the NRC does not renew the existing BFN renewed operating licenses. Unlike the Proposed Action, denying the SLR does not provide a means of meeting future electric system needs. Therefore, unless replacement generating capacity is provided as part of the No-Action Alternative, approximately 3,900 megawatts electricity (MWe) of baseload generation would no longer be available to meet TVAs electricity customers needs, and the alternative would not satisfy the purpose and need for the Proposed Action. For this reason, the No-Action Alternative is defined as having two components: (1) replacing the generating capacity of BFN with alternative generating supply available during or by the end of the term of the existing BFN renewed operating licenses, and (2) decommissioning the BFN facility, as described below. 7.1.1. Replacement Power BFNs 3,900 MWe of electric generating capability provides power to the TVA power service area. The Tennessee Valley obtains approximately 39 percent of its total power generation from nuclear power. BFN provides approximately 45 percent of that nuclear power generation (TVA 2022b). This power would be unavailable to customers in the event the existing BFN renewed operating licenses are not subsequently renewed. As provided in 10 CFR 51.53(c)(2), TVA has not considered in this ER the need for power from BFN, but instead considered alternatives for Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-1

Appendix E - Applicants Environmental Report-Operating License Renewal Stage replacing power from BFN. As described by the NRC, a reasonable alternative must be technically feasible and commercially viable on a utility scale and operational prior to the expiration of the reactors renewed operating license, or expected to become commercially viable on a utility scale and operational prior to the expiration of the reactors renewed operating license. The replacement option must provide equivalent baseload capacity as previously supplied by the reactor (NRC 2013a). Replacement options to consider include construction of a combination of new generating capacity using energy from natural gas, solar, storage, and nuclear small modular reactors (SMRs). Section 7.2.1 describes each of these feasible alternatives in detail while Section 7.2.2 describes the alternatives dismissed as being not feasible. Section 7.2.3 describes environmental impacts from feasible alternatives. Decommissioning NRC defines the No-Action Alternative as the process of not renewing operating licenses and allowing termination of plant operations followed by decommissioning (NRC 2013b). Decommissioning is the process of removing a facility or site safely from service, reducing residual radioactivity to a level that permits either the release of the property for unrestricted use or use under restricted conditions, and terminating the license (10 CFR 20.1003). The NRC-evaluated decommissioning options include immediate decontamination and dismantlement after the facility closes (DECON); safe storage and monitoring of the facility for a period of time that allows the radioactivity to decay, followed by additional decontamination and dismantlement (SAFSTOR); and encasing radioactive contaminants in a structurally long-lived material, such as concrete, and maintaining the entombment structure with continued surveillance until the radioactivity decays to a level permitting unrestricted release of the property (ENTOMB) (NRC 2002). Regardless of the option chosen, decommissioning must be completed within the 60-year period following permanent cessation of operations and permanent removal of fuel. Under the No-Action Alternative, TVA would have the option to continue operating BFN Units 1, 2, and 3 until the existing renewed operating licenses expire in 2033, 2034, and 2036, respectively, and then terminate operations and initiate decommissioning for the units in accordance with NRC requirements. The NRC generically evaluated environmental impacts from termination of operations and decommissioning, which include those to occupational and public radiation dose, waste management, air and water quality, and ecological, economic, and socioeconomic resources. The NRC indicated in the Final Generic Environmental Impact Statement (GEIS) on Decommissioning of Nuclear Facilities, Supplement 1 (NUREG-0586) (NRC 2002) that the environmental effects of greatest concern (i.e., radiation dose and releases to the environment) are substantially less for decommissioning than the same effects resulting from reactor operations. TVA considers the description of decommissioning impacts in NUREG-0586 as representing the actions that will be performed for the BFN decommissioning. TVA incorporates herein by reference the NRC conclusions from NUREG-0586 regarding environmental impacts of decommissioning for all three BFN units. TVA notes that decommissioning activities and their impacts are not discriminators between the Proposed Action and the No-Action Alternative. BFN will have to be decommissioned regardless of the NRC decision on SLR, which would only postpone decommissioning for another 20 years. TVA evaluated the impacts from decommissioning in the supplemental environmental impact statement (EIS) for the license renewal of BFN, which concluded that the timing of decommissioning would not influence the environmental impacts of decommissioning (TVA 2023a). The NRC had also established in the 2013 GEIS that the timing of decommissioning operations does not substantially influence the environmental impacts of decommissioning (NRC 2013a). TVA still assumes that delaying decommissioning until after the end of the Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-2

Appendix E - Applicants Environmental Report-Operating License Renewal Stage subsequent period of extended operation term would have little effect on decommissioning environmental impacts. Therefore, TVA postulates that the discriminators between the Proposed Action and the No-Action Alternative lie in the choice of generation replacement options associated with terminating plant operations that would be part of the No-Action Alternative. Section 7.2.3 analyzes the impacts from these generation replacement options. 7.2. Energy Alternatives that Meet System Generating Needs TVA operates the nation's largest public power system. It provides power to more than 10 million people, through 153 local power companies and 58 directly served customers, in an area encompassing 80,000 square miles, including most of Tennessee and parts of Alabama, Georgia, Kentucky, Mississippi, North Carolina, and Virginia (TVA 2019a). TVAs portfolio has evolved over the past decade to a more diverse, reliable, and cleaner mix of generation resources. Currently, more than half of TVAs generation is carbon-free. TVAs current generating assets include 3 nuclear sites, 5 coal-fired sites, 29 hydroelectric sites, 1 pumped-storage site, 9 combustion turbine gas sites, 8 combined cycle gas sites, 1 co-generation unit, 1 diesel generator, and 13 solar energy sites. These assets provided 38,111 megawatt (MW) summer net capability capacity in fiscal year (FY) 2022 (TVA 2022b). This capacity included units fueled by nuclear (39 percent), natural gas (22 percent), coal (13 percent), hydroelectric (8 percent), and the remainder (18 percent) is from power purchase agreements (PPAs) from renewable and non-renewable sources (TVA 2022b). In accordance with 10 CFR 51.53(c)(2), TVA considered a range of alternatives to replace generation if the existing BFN renewed operating licenses are not subsequently renewed. TVA considered each of the replacement alternatives identified in TVAs 2019 Integrated Resource Plan (IRP) in addition to other alternatives (e.g., geothermal and ocean wave energy). These alternatives were evaluated based on their ability to provide reliable baseload power and their ability to be operational prior to the expiration of the current BFN renewed operating licenses. TVAs 2019 IRP provides a system-wide review on meeting projected future energy demands and the direction on potential replacement power sources that TVA is considering over the planning period from 2019-2038 (TVA 2019a). Specifically, the 2019 IRP forecasted generating assets that would be added to, or removed from, TVAs fleet by 2028 and by 2038. The 2019 IRP and associated Final Environmental Impact Statement (TVA 2019b) evaluated six scenarios or plausible futures, including No Nuclear Extension of BFN, with five strategies per scenario (potential TVA responses to those futures). Using these scenarios, TVA identified a range of potential resource additions and retirements throughout the TVA power service area based upon TVAs system-wide generation planning models. Not all alternatives would be reasonable alternatives to the proposed action. NRC defined a reasonable alternative as, "commercially viable on a utility scale and operational before the expiration of the reactors operating license or expected to become commercially viable on a utility scale and operational before expiration of the reactors operating license," and whose generating capacity, "must equal the base load capacity previously supplied by the nuclear plant" (NRC 2013b). NRC elected to evaluate only individual alternatives rather than combinations of alternatives in its GEIS because the possible combinations of alternatives could be large in number. However, TVA elected to present the assessment of a reasonable alternatives as sliding scale of a combination of individual alternative replacement options, rather than individual alternatives or a single combination of alternatives. This allowed TVA to evaluate an alternative that aligns with TVAs evaluation in the 2019 IRP if there were no nuclear extension of BFN. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-3

Appendix E - Applicants Environmental Report-Operating License Renewal Stage The analysis below favors the generation sources that TVA selected in the 2019 IRP for current and future power sources in the TVA service area. The power sources considered as reasonable replacements for the approximately 3,900 MWe of BFN generation include a combination of natural gas-fired combined cycle (CC) generation, natural gas combustion turbine (CT) generation, solar photovoltaic (PV) facilitates, storage, and SMRs. The following sections identify the replacement power sources considered as reasonable (Section 7.2.1) and power sources considered as unreasonable (Section 7.2.2). 7.2.1. Energy Alternatives Considered as Reasonable - Construction of New Generating Assets Alternative generating technologies were evaluated to identify a combination of candidate technologies that would be capable of replacing the BFN total net baseload capacity of approximately 3,900 MWe at the time the BFN Unit 1, Unit 2, and Unit 3 Renewed Facility Operation Licenses (RFOLs) expire in 2033, 2034, and 2036, respectively. For purposes of this alternatives analysis, TVA assumed that the region of interest (ROI) within which facilities would be sited includes the entire TVA power service area because it is too early to know where exactly the replacement generating assets would be constructed. It is also assumed that each new generating asset would have its own separate environmental review under the National Environmental Policy Act (NEPA) since TVA, as a corporate agency and instrumentality of the United States, is required to comply with NEPA. Further, TVA has limited the analysis of impacts from new generating plant technology alternatives in this ER to the technologies it deems as reasonably likely to be commercially viable on a utility scale and operational by 2033. TVA also incorporated capacity factors of generating assets in their assumptions in the 2019 IRP. Capacity factor is a measure of a power plants actual energy generation compared to the maximum amount it could generate in a given period without any interruption. Thus, capacity factor is the annual generation of a power plant divided by the product of the capacity and the number of hours of a given period. As power plants sometimes operate at less than full output, the annual capacity factor is a measure of both how many hours in the year the power plant operated and at what percentage of its entire production. Assets that run constantly, such as nuclear plants, provide a significant amount of energy with capacity factors greater than 90 percent (TVA 2019a). As previously mentioned, the 2019 IRP forecasted TVA generating assets for 2028 and 2038. IRP Scenario 6 specifically evaluated strategies in which there would be no nuclear extension of BFN. Because the existing BFN renewed operating licenses expire between 2033 and 2036, the 2028 forecasted generating capacity does not consider power replacement needs for the retirement of BFN. However, the 2038 forecasted generating capacity does account for replacement generating assets that would need to be commercially viable on a utility scale and operational before the expiration of BFNs renewed operating licenses in 2033, 2034, and 2036 (TVA 2019a). The difference in the maximum forecasted generating capacity between 2028 and 2038 was calculated and is assumed to be the maximum incremental capacity that could be added for each generating asset to replace BFN power generation before the renewed operating licenses expire. Therefore, the alternative analysis was identified using a combination of the following power sources to meet the NRC criteria for reasonableness for replacement of the BFN generation during the subsequent period of extended operation:

Natural gas-fired CC generation
Natural gas-fired CT generation
Solar generation
Energy storage Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-4

Appendix E - Applicants Environmental Report-Operating License Renewal Stage

New Nuclear - Small Modular Reactors (SMR)

Even without consideration for the need of replacement generation at BFN, TVA already expects to add about 10,000 MW of solar generation by 2035 to meet customer demands and system needs (TVA 2023b). Additions may be a combination of utility and distributed scale solar facilities. Integrating this significant amount of intermittent resources requires a generation fleet that is highly flexible and capable of ramping up and down quickly to cover gaps in renewable generation which is why gas CTs and energy storage are also included in this alterative. A combination of gas CC, gas CT, solar, storage, and SMR power producing units would provide the equivalent generation to replace the current MWe of generation produced from BFN (TVA 2019a). These energy alternatives considered as reasonable alternatives are further discussed in Section 7.2.3. 7.2.1.1. Natural Gas-Fired Combined Cycle Generation Natural gas-fired CC plants are efficient intermediate power generation units with large energy potential and the ability to provide grid support and to load follow. CCs are composed of multiple natural gas-fired CT generating units which are paired with heat recovery steam generators and one or more steam turbines for increased efficiency and power output. CCs are fully dispatchable year-round with the ability to ramp generation output up and down throughout the day. This ability to ramp up and down throughout the day is increasingly important as TVA begins integrating up to 10,000 MW of solar by 2035. The high fuel efficiency, relatively low construction cost, and flexibility of CCs lend them to be good candidates for intermediate and baseload operations. In the 2019 IRP, TVA evaluated the addition of up to 9,800 MW of incremental gas CC capacity by 2038 if a high level of load growth materializes. But for the IRP scenario that anticipated No Nuclear Extension of BFN (Scenario 6), up to 3,900 MWe of incremental gas CC capacity was added, of which 1,800 MWe was forecast to be added between 2028 and 2038 during the time when the existing BFN renewed operating licenses would expire. The IRP evaluation included four natural gas CC fueled options:

One turbine and one steam generator (CC 1 x 1)
Two turbines and one steam generator (CC 2 x 1)
Three turbines and one steam generator (CC 3 x 1)
Three by one integrated gasification combined cycle (IGCC) with carbon capture and storage For purposes of this analysis, TVA assumed development of a modern natural gas-fired CC plant with design characteristics similar to those being developed elsewhere in the TVA region.

TVA has chosen to evaluate a CC plant using a closed-cycle cooling system with cooling towers at an alternate site, due to the lack of available land within the site boundaries of BFN. The CC plant would have a book life of 30 years. It is assumed that the plant would be designed to minimize air emissions (i.e., heat recovery steam generators equipped with a selective catalytic reduction system and ammonia vaporizers). Table 7.2-1 presents the basic characteristics for the CC gas-fired alternative, and impacts are described in Section 7.2.3.1. 7.2.1.2. Natural Gas-Fired Combustion Turbine Generation Natural gas-fired simple cycle frame CT plants are peaking units with the ability to start and ramp up quickly on short notice and the ability to provide grid support and load following. Simple cycle frame CT plants are composed of multiple natural gas-fired CT generating units. CTs draw in air at the front of the unit, compress it, mix it with fuel, and ignite it. The combustion occurs Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-5

Appendix E - Applicants Environmental Report-Operating License Renewal Stage immediately, allowing gases to then expand through turbine blades connected to a generator to produce electricity. CT power plants normally run on natural gas as a fuel; however, they may also be run on low-sulfur fuel oil if needed (TVA 2022d). CTs are fully dispatchable year-round with the ability to meet capacity needs during short periods, typically have the lowest installed capital cost per MW, and offer flexibility to assist in the integration of renewable resources. Aeroderivative (Aero) CT units are highly efficient peaking units similar to TVAs existing natural gas simple cycle frame CTs, but they offer higher cycling capability and no start-up costs (TVA 2019a). They can achieve full generating capacity from a cold start very quickly and allow for multiple daily starts to more closely following load. In the 2019 IRP, for the IRP scenario that anticipated no license extension of BFN (Scenario 6), up to 6,500 MWe of gas CT capacity was forecast in 2038, of which 5,900 MWe was forecast to be added between 2028 and 2038 during the time when the existing BFN renewed operating licenses would expire. The IRP evaluated five different natural gas CT options: two simple cycle frame combustion turbines with either three or four turbines, and three Aero CT configurations with two, four, or six turbines. However, CT units generally have a capacity factor less than 5 percent. A 250-MW natural gas-fired CT unit could theoretically produce 2,190 gigawatt hours (GWh) of energy if it ran every hour of the year, but the CT unit would likely only operate about 440 hours of the year and produce only about 110 GWh, resulting in a low capacity factor (TVA 2019a). Investments in adding CTs to the peaking fleet aligns with the models in the IRP, which recommended substantial solar additions over the next two decades, by enhancing system flexibility to integrate renewables and distributed resources. As the amount of solar generation on the TVA generation portfolio continues to increase, flexibility of the remainder of the fleet becomes even more important. Therefore, TVA assumed development of single-cycle frame CTs or Aero CTs to ensure TVA maintains a reliable peaking fleet and to enhance system flexibility by facilitating the integration of intermittent renewable resources such as solar. As an example, TVA is proposing the addition of 10 natural gas-fired Aero CTs at the existing Johnsonville CT Reservation, which would be operational no later than December 31, 2024 (TVA 2022e) and aid, in some combination with the other energy alternatives, in replacement of BFN generation. The GHG life cycle emission rate of the Aero CTs is likely about 10 percent lower than that of the frame-type 7FA CTs given the approximately 10 percent lower heat rate and higher efficiency of the Aero CTs (TVA 2019b). 7.2.1.3. Solar (with and without storage) Solar PV systems consist of interconnected PV cells that convert sunlight into electricity. Utility-scale solar costs have fallen substantially over the past 10 years, with forecasts indicating continued declines in real dollars throughout the balance of the decade. Depending on the configuration, technology employed, and other factors, in-Valley utility-scale solar farms can expect a 20 to 23 percent capacity factor. While relatively inexpensive on a cost per megawatt-hour (MWh) basis, solar farms are not dispatchable and generation is intermittent in nature, varying by time of day, weather, and season (TVA 2019a). At present, approximately 250 MWe of utility generating capacity in the TVA region is purchased solar power through several programs and long-term PPAs. TVA obtains the renewable energy credits from these sites, and the existing PPAs extend through the late 2030s. TVA aspires to add up to 10,000 MW solar by 2035 (TVA 2023b). It is possible that some of these new solar facilities would be located on TVA-owned lands in the BFN vicinity. Each facility would each require varying amounts of land based on its generation capacity. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-6

Appendix E - Applicants Environmental Report-Operating License Renewal Stage To provide dependable peak capacity needs for the TVA system, solar generation must be paired with dispatchable resources, such as storage or gas. Battery energy storage systems (BESS) typically represent one of the lowest cost storage options today and setups include a capacity output rating in MW along with an energy rating in MWh, which are customizable at each facility. Dividing the energy rating by the capacity rating provides the number of hours of duration that can be expected from the system at full output. Many utilities have found that four-hour BESS systems provide a good balance of price, output, and duration. The combination of utility-scale solar and battery storage would provide a carbon-free alternative to replace a portion of the BFN generation. 7.2.1.4. Storage (Battery Energy) Storage units usually serve the same power supply function as peaking units but use low-cost, off-peak electricity to store energy for generation at peak times. As solar penetration on the system continues to increase, long-duration storage facilities will become increasingly more important to balance system demand. The 2019 IRP factored in the addition of up to 5,300 MW by 2038 (TVA 2019a). For the No Nuclear Extension scenario in the IRP (Scenario 6) and to remain consistent with TVAs strategy of having a diverse mix of power-generation, up to 3,000 MW storage was added by 2038, of which 1,600 MWe was forecast between 2028 and 2038 during the time when the existing BFN renewed operating licenses would expire. For every 100 MW of distributed solar in the scenario, TVA included an additional 10 MW of battery storage in their projection modeling (TVA 2019a). The IRP evaluated several types of storage: utility-scale battery storage, pumped storage, compressed air energy storage (CAES), and fuel cells. However, only a few are considered as possible options for supplementing the generating capacity of BFN if the renewed licenses are not subsequently renewed. Storage options considered not reasonable are described below in Section 7.2.2.1. Most storage additions evaluated in the IRP were anticipated to be utility-scale batteries (TVA 2019a). It was estimated that these batteries would have a maximum capacity of 100 MW summer net dependability (SND) capacity at an efficiency of 88 percent and storage capacity of approximately 4 hours (TVA 2019a). Lithium-ion batteries are another example of a storage resource (TVA 2019a). At the end of 2019, lithium-ion batteries represented more than 90 percent of the installed power and energy capacity of large-scale battery storage in operation in the United States primarily because they have a high energy density, high-cycle efficiency, and fast response times (EIA 2021). A BESS, as discussed in Section 7.2.1.3, typically represents one of the lowest cost storage options today. TVA is installing its first grid-scale BESS near an industrial complex in Vonore, Tennessee. The Vonore BESS will use lithium-ion batteries capable of generating up to 20 MW and storing 40 MWh of energy, which is enough electricity to power over 10,600 homes for three hours (TVA 2020). The Vonore BESS will require approximately 10-15 acres of land (TVA 2022g). A new hydro pumped storage unit was also evaluated in the IRP as a resource option. The pumped-storage option would use three reversible turbine generators to either take electricity from the grid by pumping water into a higher altitude reservoir during periods of excess power or add electricity to the grid by using the pumped water to power a turbine as it falls from the upper to the lower reservoir. While TVA currently operates one large hydro energy storage facility in the southeast (i.e., Raccoon Mountain Pumped-Storage Plant which has a SND capacity of about 1,600 MW), TVA is also in the process of initiating a pumped-storage study to explore potential sites and develop cost estimates for additional pumped-storage on the TVA system. TVA modeled the addition of a pumped-storage unit providing 850 MW SND capacity. Although long timelines are required to meet environmental requirements and for construction of pumped storage, this type of storage may be a potentially viable option (in combination with other Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-7

Appendix E - Applicants Environmental Report-Operating License Renewal Stage generation alternatives) by the time the last existing BFN renewed license would expire in 2036 (Unit 3). 7.2.1.5. New Nuclear - Small Modular Reactors TVA has extensive nuclear operating experience with seven operating nuclear units at three sites, including BFN. The 2019 IRP included the addition of SMRs totaling 1,200 MW to replace one of the three BFN Units in the No Nuclear Extension scenario (TVA 2019a). SMRs require less space and are more flexible to operate than a traditional nuclear plant. Their smaller footprint and manufactured components mean they can be built more quickly, are easier to operate, and better fit into the landscape due to their compact size (TVA 2022a). TVA currently holds the only early site permit from the NRC for SMRs at its Clinch River site in Oak Ridge, TN. SMRs have the potential to serve cost-effective baseload or load following needs in the future with low fuel costs, carbon-free generation, advanced passive safety systems, and anticipated cost reductions achieved by assembling components in a factory setting. As yet, no SMRs have been built in the United States, and no SMR technology has been fully licensed by the NRC. There are substantial cost and timeline risks associated with first-of-a-kind deployment of new technology. Successful partnerships with the U.S. Department of Energy and other utility stakeholders is critical to the deployment of this new technology. TVA believes that SMRs could play a role in meeting capacity needs in the early 2030s as additional capacity is retired or expires. TVA has published the Final Programmatic EIS and Record of Decision for the Clinch River Nuclear Site Advanced Nuclear Reactor Technology Park in Oak Ridge, Tennessee (TVA 2022c) and has announced the New Nuclear Program to explore innovative technology and potential locations for advanced nuclear reactors to support TVAs decarbonization goal (TVA 2022f). Therefore, construction of SMRs may be a potential base-load generation alternative to SLR for BFN Unit 1, in some combination with the other energy alternatives. 7.2.2. Energy Alternatives Not Considered Reasonable The full range of energy alternatives include power sources that will require development of new generation and power alternatives that will not require new generation, such as purchased power and demand side management. This section addresses the energy alternatives that were not considered reasonable for additional evaluation with regard to replacement of the BFN generation. 7.2.2.1. Alternatives Requiring New Generating Capacity Wind Wind is intermittent and, therefore, by itself is not capable of providing baseload power. The capacity factor of a wind turbine normally ranges from 25 percent to 50 percent, although higher capacity factors can be achieved during windy periods (TVA 2021b). For wind power to be viable as a discrete source of power generation that is available during peak hours, energy storage would need to be considered in the planning process, similar to solar. As outlined in the 2019 IRP, wind from both outside and inside the Valley has challenging economics. Out-of-Valley wind must be imported to TVA across interconnected systems, driving significant transmission expense. In-Valley wind would have lower intensity and efficiency, and would result in lower capacity factors and higher effective costs (TVA 2019a). Furthermore, there are limited wind resources in the eastern United States and potentially LARGE environmental impacts associated with development of a wind facility, primarily associated with land use conversion, land disturbance, viewshed changes, and avian species mortality. Because wind resources are energy- and capacity-limited resources (TVA 2019a), construction of new wind farms in the TVA service area was not factored into any of the IRP portfolios. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-8

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Land use impacts for wind energy also include permanent disturbances for turbine bases and infrastructure and temporary disturbances for construction areas. Using wind power to replace 100 MW would require a construction footprint of 247 acres to produce 74 acres of permanent structures on 8,500 acres (DOE 2015). Although, once constructed, the land areas between turbines may be put to a non-intrusive, beneficial use, wind power requires a large amount of land. It would require a significant conversion of land to replace the 3,900 MW produced by BFN, even if wind were a viable alternative in the Tennessee Valley. The turbines also create a visual obstruction for miles around the vicinity, both during the day and at night. Thus, using wind power as a significant source of replacement energy for BFN would have LARGE land and visual impacts. Bird and bat collisions with wind turbines are fatal. The large geographic extent of land use conversion that would be associated with use of wind power to replace BFN would correlate to potential MODERATE to LARGE ecological impacts on wildlife habitats, vegetation, and avian species mortality. Since TVA cannot take direct advantage of the tax credits and other investment incentives offered by the federal government to encourage wind power development, it has been more financially advantageous to acquire wind power resources through PPAs (TVA 2019a). But TVA does not consider purchasing power to make up for a large portion of generation capacity of BFN as a reasonable alternative to the BFN SLR. There is risk that purchased power could not be delivered and TVA would need to plan total generating reserves to accommodate the potential for undelivered purchased capacity. Therefore, wind power (with or without energy storage) is not considered a reasonable alternative for the replacement of BFN generating capacity. Hydropower Construction of a new large-scale hydropower facility capable of generating utility-scale power would require considerable siting considerations due to the area that would be inundated to provide water storage for generation. If a new run-of-the-river hydroelectric generating facility was developed in the TVA region (i.e., a facility that redirects the natural flow of a river through a hydroelectric facility with little to no storage), land requirements would be approximately 0.5 acres/MW (TVA 2019b). Based on this estimate, replacement of the generating capacity of one BFN unit would require approximately 600 acres. The development of one or more hydropower facilities to replace BFN would result in direct conversion of hundreds of acres of land, which would also directly impact vegetation, wildlife, aquatic habitats and species, water resources and hydrology, soils, wetlands, and floodplains. Both archaeology and architectural cultural resources could be affected if present. Socioeconomic impacts would occur depending on the nature of the other impacts and could be both beneficial and adverse. Therefore, construction of one or more hydropower facilities as replacement power for BFN would likely result in LARGE impacts to land use, water resources, socioeconomics, ecology, and cultural resources. TVA has a Hydro Modernization Program through which outdated turbines and other equipment in the existing hydroelectric plants are replaced and modernized. This has resulted in increases in generating capacity and average efficiency of the hydroelectric plants (TVA 2019b). In the 2019 IRP, all portfolios reflect continued investment in the hydroelectric fleet to maintain capacity and consideration of additional hydro capacity where feasible; however, no new hydropower projects were considered (TVA 2019a). TVA has concluded that construction of a new hydropower facility would have severe environmental impacts and the improvements to existing hydroelectric generating facilities would not be enough to replace BFN generation. Therefore, hydropower is not considered a reasonable alternative to the BFN SLR. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-9

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Geothermal To produce electric power with geothermal energy, underground high-temperature reservoirs of steam or hot water are tapped by wells and the escaping steam rotates turbines to generate electricity (Unwin 2019). Geothermal energy can achieve average capacity factors of 92 percent and can be used for baseload power where this type of energy source is available (Geothermal Energy Association 2013). The major challenge for geothermal development lies in geothermal resource mapping. The National Renewable Energy Laboratory (NREL) has not identified any viable sites for geothermal energy in the eastern United States (NREL 2021). Geothermal energy resources that can be developed for power generation are primarily located in the western United States. Geothermal power plants are currently generating power in Alaska, California, Hawaii, Idaho, Nevada, New Mexico, Oregon, and Utah (NREL 2021). Therefore, TVA has concluded that geothermal energy is not a reasonable alternative to the BFN SLR in the TVA service area. Biomass Biomass includes wood waste, animal and other organic waste, certain agricultural crops or waste, energy crops (crops grown specifically to produce biomass for use as fuels), landfill gas, wastewater methane, and other types of waste residues used to create electricity. The generating facilities have typically been built on heavily disturbed landfill or other industrial sites and occupy small land areas. TVA currently purchases electricity generated from landfill gas and wood wastes and generates biomass electricity from Chestnut Ridge Landfill gas (TVA 2019a). The environmental impacts of this generation are, overall, beneficial due to the avoidance of methane emissions and utilization of residues at wood and grain processing plants. Currently, the largest municipal waste plant in the United States produces 96 MWe of baseload generation (ERC 2018). The land requirements for these vary and are plant specific. In the 2019 IRP, TVA evaluated two options for new biomass generation, including a dedicated biomass facility and a repowered coal unit in which TVA would convert one or more of its existing smaller coal-fired units to exclusively burn biomass. Most of the components of a biomass plant could likely be sited on an existing TVA plant reservation, on areas that have been previously disturbed, but the generating capacity of a biomass facility would be limited due to fuel delivery constraints (TVA 2019a). Fuels for a biomass-fueled generating facility are available in various areas of the TVA region but utilizing municipal solid waste for electricity would be dependent on being close to large population centers that generate large amounts of waste. Otherwise, the harvesting and transportation of trees for use as fuel can result in adverse environmental impacts including the modification or loss of wildlife habitat, sedimentation, reduction in soil fertility, loss of old growth forest, change in forest type and understory vegetation, altered scenery, and competition with other wood-using industries (TVA 2019a). Biomass fueled energy facilities with utility-scale capacities could require at least 300 acres (NRC 2013b). The physical appearance of a biomass power facility would be similar to a fossil fueled fired facility, but the industrial footprint would be less. However, a large amount of land could be required for growing energy crops. Thus, using biomass power as a significant source of replacement energy would have MODERATE to LARGE land and visual impacts. The large geographic extent of land use by biomass power correlates to possibly LARGE ecological impacts. Air quality impacts from biomass plants from construction and maintenance activities would be similar to that of other energy technologies. During operation, biomass plants would have impacts on air quality from fuel handling activities and from combustion. Combustion of biomass generally results in smaller amounts of GHG than combustion of fossil fuel (NRC Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-10

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 2013b). Thus, construction and operation of a biomass facility sized to provide replacement fuel for BFN would result in MODERATE to LARGE impacts on air quality. Overall, biomass plants are unable to produce the large baseloads of electricity that nuclear plants generate without the construction of multiple smaller facilities. The construction and operation of a biomass plant of the size necessary to act as an alternative to BFN would result in MODERATE to LARGE environmental impacts to land use, water quality, ecological resources, and air quality. Therefore, biomass is not considered a reasonable alternative for replacement of the BFN SLR. Ocean Wave and Current Energy Although TVA's 2019 IRP did not include tidal, ocean wave or current energy in its energy planning scenarios, these technologies are being included for consistency with licensing applications for other nuclear facilities. The potential for ocean energy in Alabama has been estimated at 3 terawatt hours (TWH) along the outer shelf and 2 TWH along the inner shelf (EPRI 2011). This potential for ocean energy is low in Alabama and the technology is in its early stages of commercial development. Only one wave energy test site project is currently operating in the Unites States off the coast of Hawaii (DOE 2019) and there are two potential tests sites off the coast of Oregon (PacWave 2021). There is very minimal information available regarding the implementation of this technology in the United States and there are no federal market initiatives available for this renewable resource energy. Additionally, the environmental impacts associated with these facilities have not yet been studied in any detail in the United States. At most, ocean energy would be available only through PPAs, and TVA does not consider purchasing power to make up for a large portion of generation capacity of BFN a reasonable alternative to the BFN SLR. Therefore, ocean energy is not considered a reasonable alternative for replacement of BFN generating capacity. Combination of Only Renewable Resources (including Solar) A combination of only renewable resources as generating assets was also considered. This could include any combination of solar, wind, hydropower, biomass, and ocean wave and current energy. Each of these resources was discussed in the sections above. As previously discussed, wind and solar are intermittent and wind is not a viable generation source within the Valley. TVA has not considered new hydropower as a future generating asset in the IRP and upgrades to existing hydropower facilities would be insufficient to replace more than a fraction of the BFN generation. Biomass plants would not be able to produce large amounts of electricity to make a significant contribution to making up the baseload generation of BFN without MODERATE to LARGE environmental impacts. Finally, ocean wave and current energy is not a realistic option because it is in the very early stages of development and because PPAs would be required if available. The most viable renewable resource is solar which, because of the intermittent nature of the resource cannot be the sole replacement BFN generation. Therefore, using a combination of only renewable resources as an alternative to BFN SLR was considered but dismissed. Storage As discussed in Section 7.2.1.4, TVA has evaluated several types of storage options in the 2019 IRP. Utility-scale battery storage and pumped storage were evaluated as potentially reasonable energy alternatives considered. However, CAES and fuel cells were not considered reasonable alternatives for the replacement of BFN generating capacity. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-11

Appendix E - Applicants Environmental Report-Operating License Renewal Stage CAES plants are similar to a pumped-storage plant (Section 7.2.1.4) with the major difference being that instead of pumping water from a lower to an upper reservoir, a CAES plant uses a gas turbine to compress air often into an underground cavern where it can be stored under pressure until electricity is required. The pressurized air is then heated and directed through a conventional generator to produce electricity. It is estimated that the SND capacity is approximately 330 MW with 70 percent efficiency; however, there are very few operating CAES plants and information on these systems and their environmental impacts is limited. In addition, they likely would not be commercially available before the existing BFN renewed operating licensees expire, and their environmental impacts is limited. Therefore, a CAES plant is not considered a reasonable alternative to the BFN SLR. Fuel cells as a reliable generation alternative are not presently economically or technologically competitive with other alternatives. The Energy Information Administration (EIA) projects that fuel cells may cost $7,224 per installed kilowatt (KW; total overnight capital costs) (EIA 2022a), which is higher than most generation technologies analyzed in the 2019 IRP and this ER. This high cost is associated with the durability of fuel cells and the technology to convert natural gas to hydrogen. Therefore, fuel cells are not considered a reasonable alternative to the BFN SLR. Oil Petroleum (Oil)-fired power plants are generally used for short periods during times of peak electricity demand and otherwise operate mostly at low capacity factors because of the high price, air pollution restrictions, and lower efficiencies of their aging generating technology (EIA 2017). TVA currently owns five diesel generators, but construction of new oil-fired generation does not fit into TVAs policy to replace high carbon emission fuel sources with generation that has a lower carbon footprint (TVA 2019a). TVA expects to phase out petroleum power purchases by 2028 and has committed to developing cleaner energy and continue to reduce environmental impacts. There are no diesel fuels or other petroleum-based resource options as a primary fuel source under consideration in the 2019 IRP because of the large amounts of carbon dioxide and hazardous air pollutants from these facilities. Thus, TVA has concluded that, due to the high costs and lack of obvious environmental advantage, burning oil to generate electricity is not a reasonable alternative to the BFN SLR. Coal TVA currently operates five coal-fired power plants consisting of 25 active generating units with a total capability of approximately 6,580 MW (TVA 2022b). For the past few years, TVA has implemented a program to reduce coal-fired baseload generation in its service area, retiring and proposing to retire existing coal-fired generation. TVA's program to reduce coal-fired baseload generation in its service area is fundamental to Agency efforts to reduce carbon emissions and comply with probable carbon regulations. Coal mining results in significant environmental impacts on numerous resources including air quality, water quality, and biological resources. The mining and combustion (burning) of coal also release high levels of greenhouse gases (GHGs), including methane and carbon dioxide, contributing to climate change impacts. Due to higher relative capital costs, none of the 2019 IRP scenarios included additional coal in the capacity expansion, but it did include six coal expansion options, including two coal fired-IGCC options and four supercritical pulverized coal (SCPC) facilities (TVA 2019a). Coal-fired IGCC is a gasification process that produces synthetic natural gas from coal to use as fuel in the combined cycle process. SCPC are similar to conventional pulverized coal plants, but they can operate at much higher temperatures and pressures to increase efficiency. This results in the use of less coal and lower emissions. However, implementation of IGCC and SCPC options are very cost prohibitive compared to natural gas and IGCC technologies have been installed on a very limited scale (TVA 2019b). Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-12

Appendix E - Applicants Environmental Report-Operating License Renewal Stage TVA has identified the retirement of several of their coal-fired power plants and no new coal-fired generation is proposed in the IRP; therefore, this source of generation is not considered a reasonable alternative to the BFN SLR. 7.2.2.2. Alternatives Not Requiring New Generating Capacity Purchased Power TVA has evaluated conventional and prospective power supply options that could be reasonably implemented before the existing BFN renewed operating licenses expire. The TVA Act authorizes TVA to exchange, buy or sell power with 13 neighboring electric utilities at interconnection voltages ranging from 69-kV to 500-kV. This arrangement gives TVA the ability to purchase power when its generating capacity cannot meet demand or when purchasing power from a neighboring utility is more economical for TVA than generating it. The arrangement also allows TVA to sell power to neighboring utilities when its generation exceeds demand (TVA 2019a). Purchased power does not include solar PPAs which are electrical power agreements in which TVA purchase solar electricity from specific companies that intend to own and operate solar facilities specifically to sell the power to an electric power company. Although purchased power can be a component of a reasonable alternative, there is risk that purchased power will not be delivered and TVA must plan total generating reserves to accommodate the potential for undelivered purchased capacity (TVA 2019a). Therefore, TVA does not consider purchasing power to make up for the total generation capacity of BFN as a reasonable alternative to the BFN SLR. Demand-Side Management Demand side resources, such as Energy Efficiency (EE) and Demand Response (DR), reduce demand by either installing efficiency measures to reduce energy use across all hours or provide on-demand load reduction during times of heavy demand by issuing a call to contractually non-firm load. TVA currently offers EE programs under its EnergyRight brand, in partnership with Local Power Companies, and will continue to offer programs for the foreseeable future. In recent years, TVA has placed increased emphasis on its missional offerings, including low-income assistance through its Home Uplift program and community redevelopment through its Community Centered Growth program. TVA also has extensive experience with DR, with over 1,500 MW of DR capacity today. A large percentage of this capacity is currently contracted with industrial customers, although TVA has DR contracts for aggregated commercial customers as well. Additionally, TVA has been piloting a program in the residential DR space, which has the potential to offer additional diversification in its DR portfolio. TVA anticipates initiating an updated Energy Programs Potential Study in 2021 and completing it in 2022, which will further inform costs and depth of EE and DR potential in the Tennessee Valley. Demand side EE and DR resources are well positioned to help TVA absorb load growth resulting from increased electrification of the economy, from sources such as electric vehicles or appliance fuel switching (gas to electric). However, demand side resources do face challenges around timing and limits on dispatchability. EE programs take time to scale and market, while also facing increasing costs for higher depth and penetration levels. DR programs allow TVA to offset physical capacity needs; however, they are limited in the number of calls available. While demand side options have the potential to contribute to the overall system solution, the capacity and energy needs required to replace the generating power of BFN make these options not viable replacement options. Delayed Retirement of Existing Generating Capacity Extending the lives of existing non-nuclear generating plants beyond the time they were originally scheduled to be retired represents another potential alternative to license renewal. TVA has retired 34 coal-fired power units and currently has five coal-fired power plants Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-13

Appendix E - Applicants Environmental Report-Operating License Renewal Stage consisting of 25 active generating units (TVA 2022b). However, several of these units will be retired before or near the expiration date of the existing BFN renewed operating licenses. TVA does not consider the delayed retirement of coal-power generating assets to be a reasonable alternative to the BFN SLR because it is not in line with TVAs commitment to reduce carbon emissions and goal of moving toward net-zero carbon emissions by 2050 (TVA 2021a). Additionally, in January 2021, Executive Order 14008 was signed to tackle the climate crisis and achieve a pollution-free electricity sector no later than 2035. Thus, delaying retirement of coal-fired generation would result in the continued use of generation that has higher environmental issues, and does not meet the goals identified in the 2019 IRP or Executive Order 14008 to lower air emissions. For these reasons, TVA does not consider the delayed retirement of non-nuclear generating units to be a reasonable alternative to the BFN SLR. 7.2.3. Environmental Impacts of Alternatives This section evaluates the environmental impacts of alternatives that TVA has determined to be reasonable alternatives to the BFN SLR, which is a combination of gas-fired CC generation, gas-fired CT generation, solar generation and storage, and new nuclear generation replacing the BFN total net baseload capacity of approximately 3,900 MWe. Replacement of BFN generation with a combination of these alternatives would have relatively larger environmental impacts in comparison to the BFN SLR, which would involve no new construction or refurbishment activities beyond normal maintenance. Construction of a hypothetical new power station at an existing power station would be preferable to construction at a new greenfield site. This approach would minimize environmental impacts by building on previously disturbed land and by making the most use possible of existing facilities, such as transmission lines, roads and parking areas, office buildings, and components of the cooling system. However, there is insufficient area at the existing BFN site to construct a new nuclear, solar, coal- or gas-fired unit of adequate capacity without impacting the ongoing operations; thus, a new plant(s) would have to be located elsewhere. Accordingly, it is assumed that space would be found at one or more existing power plant sites other than BFN within the ROI to benefit from the existing infrastructure and minimize the environmental impact that would occur in comparison to a new greenfield location. This approach avoids overstating the environmental impacts of these alternatives in comparison to the Proposed Action. For new solar facility(-ies), it is assumed that the amount of required land would dictate greenfield site development. To compare the environmental impacts of alternative electricity supplies with the BFN SLR on an equal basis, TVA set the existing approximate net average annual generating capacity of BFN (approximately 3,900 MWe) as the approximate net electrical generating capacity that any reasonable alternative would need to supply. However, because some alternative technologies are manufactured in standard unit sizes, it was not always possible to aggregate such technologies to exactly match the BFN capacity. In such cases, generation capacity at the BFN net average annual generating capacity has been used to conservatively evaluate impacts in cases of new facility construction. It must be emphasized, however, that all scenarios are hypothetical. TVA has no current plans for new facility construction to replace BFN. As described in TVAs 2023 BFN Supplemental Environmental Impact Statement (SEIS), if the BFN SLR is not approved, TVA would conduct site-specific environmental reviews for each replacement facility to inform the decision making process. TVAs future IRP reviews would also inform replacement generation planning. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-14

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 7.2.3.1. Combination of Natural Gas-Fired Combined Cycle, Natural-Gas Fired Combustion Turbine, Solar, Storage, and SMR Generation As discussed in Section 7.2.1, no single technology alternative would be suitable to replace BFN. Therefore, a combination of natural gas-fired CC, natural-gas fired CT, solar, storage, and possibly SMR generation facilities would be required to produce enough power to replace BFN. The environmental effects of this combination of technologies must also be considered in combination. TVA assumes most of the new generation facilities would be constructed on one or more existing fossil plant sites in the ROI if the BFN operating licenses were not renewed (IRP Scenario 6). TVA assumes new solar and possibly storage facilities could be constructed on greenfield sites. The following sections describe the potential environmental impacts of construction and operations of a combination of all possible replacement generation types if the BFN operating licenses were not renewed. Land Use and Visual Resources The average land area required for a new CC or CT plant is assumed to be about 90 acres (0.153 acres/MW) (TVA 2019b). A new natural gas pipeline may be required to supply fuel for the natural-gas facilities. To the extent practicable, the pipeline would be routed along existing, previously disturbed, rights-of-way to minimize impacts. This new construction may also necessitate an upgrade of the statewide pipeline network. BFN estimates that approximately 80 acres would be needed for a natural-gas plant site. Impacts from construction on a greenfield site would be dependent on efforts needed to carry out grading activities and potential conversion of prime farmland. Therefore, land use impacts would range from SMALL to MODERATE. The stacks and boilers of new gas-fired units may add visual impacts at the existing power plant site where it is constructed; but these would be minimal due to the presence of existing plant structures. Depending on whether the land was located on previously disturbed industrial, commercial, or agricultural lands, the visual impact would range from SMALL to MODERATE during construction and operations. Due to the lower efficiencies in producing electricity from solar power, the amount of land required to install solar generation is larger than other technologies being considered in this ER. New building-mounted solar facilities would not impact land resources because no additional land would be required, while new ground-mounted solar facilities are assumed to require 6.1 acres/MWDirect Current(DC) (7.2 acres/MWAlternating Current(AC)) for fixed-tilt systems and 7.3 acres/MWDC (8.6 acres/MWAC) for single-axis tracking systems (TVA 2019b). Solar PV facilities are likely to be constructed on cropland which requires less grading compared to other land types, but may be considered prime farmland. Impacts could be reduced by developing solar facilities on sites that had been previously disturbed. Impacts may also be reduced by using permanent grass or vegetative cover, that when composed of native plant species, can also increase local wildlife diversity. Therefore, depending on the number, sizes, and locations of the solar facilities, the land use disturbances could result in MODERATE to LARGE impacts on land use. Visual impacts for solar facility(-ies) would be considerable due to the number and size of the PV arrays together with ancillary systems that would be required to provide new solar capability. The solar facilities would require large land areas that would tend to change the visual context of the landscape. These components would be prominent in the open landscape and over a large area. Solar facilitates constructed within the Tennessee Valley region would likely increase the industrialization of the area and transform a larger area to industrial use. Depending on whether the land was located on previously disturbed industrial, commercial, or agricultural lands, the visual impact would range from SMALL to MODERATE. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-15

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Land use required for an energy storage facility is typically small. If not built on an existing site, land use may change from a greenfield to industrial, but the land use surrounding the storage facility would not change. As a minimal amount of land would be affected for construction and operations, the land use impacts would be SMALL. Visual impacts of a storage facility would result in minor impacts if the storage facility was constructed on undeveloped lands but would have minimal impacts if built in an existing industrial setting. Overall visual impacts for construction and operation of an energy storage facility would be SMALL. SMR designs require less land than conventional nuclear power plants (DOE 2023). It is assumed that the new SMR facility would require 375 acres of land disturbance (TVA 2019b). The impacts of constructing and operating a SMR plant would be generally similar to those of TVAs existing nuclear plants, but proportionately less due to the lower capacity of the SMR plant. These impacts have been described by NRC in the April 2019 Final EIS (NRC 2019) for a new SMR plant at TVAs Clinch River Site. The use of modular construction for major plant components would reduce construction impacts at a proposed plant site compared to a conventional or advanced pressurized water reactor TVA estimated that approximately 0.6250 acres/MW would be needed for the new nuclear facility and because most of this construction would be on previously disturbed land (TVA 2019b), impacts would be SMALL. Should additional SMRs be constructed at other locations around the Tennessee Valley, impacts could be SMALL to MODERATE depending on the characteristics of the location selected. Visual impacts would be consistent with the industrial nature of the previous energy generating sites, thus aesthetic impacts would be SMALL to MODERATE. Cumulatively, land use and visual resource impacts associated with the construction and operations of a combination of new CC, CT, solar, storage, and SMR generation would range from SMALL to MODERATE based on site-specific conditions and the technology selected for each location. Air Quality Natural gas is considered a relatively clean-burning fossil fuel as compared to coal or fuel oil that emits criteria pollutants, hazardous air pollutants (HAPs), and GHG emissions in terms of carbon dioxide equivalent (CO2e) during combustion (EIA 2022b). If the total 3,900 Mwe of BFN generation were to be replaced with natural gas-fired CC plants, it is assumed that each plant would likely provide an average of 500-Mwe generating capacity. Therefore, a total of eight plants (i.e., seven 500-Mwe plants and one 400-Mwe plant) would be required. These facilities would be developed either through major modification of existing facilities and/or construction of new facilities. Table 7.2-1 presents the basic characteristics for the gas-fired alternative including an estimate of air emissions in tons per year (tpy) with potential to be generated from a typical 500-Mwe CC facility with a net heat rate of 5,000 British thermal unit per kilowatt hour (Btu/kWh) assuming the facility operated continuously over the entire year. A new natural gas-fired plant with 500-Mwe generation would be considered a major-emitting industrial facility and would be subject to the New Source Review (NSR) preconstruction permit program under Part C (Prevention of Significant Deterioration NSR permits) and Part D (Nonattainment NSR permits) of the Clean Air Act (CAA). The new plant would also need to comply with the New Source Performance Standards (NSPS) for set forth in Subpart KKKK of Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-16

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Title 40 CFR Part 60 for stationary combustion turbines. The key pollutants the U.S. Environmental Protection Agency (USEPA) regulates from these combustion turbines with the NSPS includes nitrogen oxide (NOx) and sulfur dioxide (SO2). In addition to criteria pollutants, the new plant would also require to be in compliance with the National Emission Standards for Hazardous Air Pollutants (NESHAP) codified in Subpart YYYY of Title 40 CFR Part 63 for major sources of HAP emissions such as formaldehyde as shown in Table 7.2-1. The NESHAP would implement Section 112(d) of the CAA by requiring all major sources to meet HAP emission standards reflecting the application of the maximum achievable control technology for combustion. Table 7.2-1. 500-Mwe Gas-fired Turbine Annual Emissions Natural Gas-Fired Stationary Gas Turbines Simple Cycle Combined Cycle Pollutant AP-42 Emission Nox and CO Controlled, Factor Others Uncontrolled (lb/MMBtu) lb/hr tpy lb/hr tpy 1 Criteria Pollutants : NOx (Lean Pre-mix Control) 9.90E-02 440 1,925 302 1,324 CO (Lean Pre-mix Control) 1.50E-02 67 292 46 201 VOC 2.10E-03 9 41 6 28 SO2 3.4E-03 15 66 10 45 PM/PM10/PM2.5 filterable 1.90E-03 8 37 6 25 1 HAPs : Total HAP 20 14 1,3-Butadiene 4.3E-07 0 0 0 0 Acetaldehyde 4.0E-05 0 1 0 1 Acrolein 6.4E-06 0 0 0 0 Benzene 1.2E-05 0 0 0 0 Ethylbenzene 3.2E-05 0 1 0 0 Formaldehyde 7.1E-04 3 14 2 9 Naphthalene 1.3E-06 0 0 0 0 PAH 2.2E-06 0 0 0 0 Propylene Oxide 2.9E-05 0 1 0 0 Toluene 1.3E-04 1 3 0 2 Xylenes 6.4E-05 0 1 0 1 40 CFR Part 98 Emission Factor (kg/MMBtu) lb/hr tpy lb/hr tpy 2 GHGs : CO2 53.06 519,378 2,274,878 357,073 1,563,978 CH4 0.001 10 43 7 29 N2O 0.0001 1 4 1 3 CO2e 2,277,227 357,441 1,565,594 1 Emission factors from USEPAs AP42, Chapter 3.1, Tables 3.1-1, 3.1-2a, 3.1-3 Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-17

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Natural Gas-Fired Stationary Gas Turbines Simple Cycle Combined Cycle Pollutant AP-42 Emission Nox and CO Controlled, Factor Others Uncontrolled (lb/MMBtu) lb/hr tpy lb/hr tpy 2 Emission factors from 40 CFR Part 98, Subpart C, Tables C-1 & C-2 for Natural gas (Tables updated in Federal Register Nov. 2013) lb = pounds; MMBtu = million British thermal units; kg = kilograms; hr = hour VOC = volatile organic compound; PM = particulate matter; PM10 = particulate matter with aerodynamic diameters of 10 microns or less; PM2.5 = particulate matter with aerodynamic diameters of 2.5 microns or less; PAH = polycyclic aromatic hydrocarbon; CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide While gas-fired turbine emissions are less than coal-fired boiler emissions, the emissions are still substantial. TVA concludes that emissions from the gas-fired plants would noticeably alter local air quality conditions, but would be unlikely to cause or contribute to violations of National Ambient Air Quality Standards in the region that would be ensured from implementing various control technologies as applicable with limits specified in air permits. Therefore, TVA believes air quality impacts around each new natural gas-fired plant would be MODERATE and the corresponding human health impacts would be MODERATE. For solar and storage facility(-ies), generators to be used as backup power and for assisting in converting, storing, and/or transporting energy produced are common stationary sources emitting air pollutant emissions. Depending on the equipment needed to generate/convert/transport the solar energy, a state or federal air permit may still be required. NSPS/NESHAPs requirements may still be applicable for new generators. However, the proposed solar and storage facility(-ies) are not anticipated to be major sources of air pollutant emissions. Therefore, air quality impacts associated with operation of the solar and storage facility(-ies) would be SMALL. Air quality impacts due to the operation of SMR units would be expected to be minimal. Air emissions, primarily from facility equipment (e.g., diesel generators, auxiliary boilers) and mobile equipment (e.g., vehicular traffic), would be less than those associated with the continued operation of BFN and then natural gas-fired generation facilities. The NRC evaluated the impacts from cooling tower particulate emissions in the GEIS and considered the impacts to be SMALL (NRC 2013a). Additionally, GHG emissions associated with nuclear power are lower than those from fossil-fuel based energy sources and are within the same order of magnitude as renewable energy sources (NRC 2013a). Therefore, overall, the impact on air quality of such emissions from an SMR facility are characterized as SMALL. Construction activities associated with any new generation facility would generate fugitive dust from earth disturbance. Mitigation measures would be implemented via wetting of cleared areas and dirt roads to minimize fugitive dust. Construction equipment and vehicles would also emit exhaust emissions and these emissions would be mitigated from curtailing the idling of vehicles and using newer equipment powered with Tier 4 engines to the maximum extent practicable. Therefore, the temporary air quality impacts associated with construction of new generation facilities would be temporary and SMALL. Cumulatively, air quality impacts associated with the construction and operations of a combination of new CC, CT, solar, storage, and SMR generation would range from SMALL to MODERATE based on site-specific conditions and the technology selected for each location. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-18

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Noise Sources of noise in the construction of a new power generation facility, regardless of the type of facility, are numerous and include large heavy equipment, blasting, concrete batch plants, and construction and worker vehicle transport. Heavy construction equipment generates noise levels up to 98 decibels (dB) at 50 feet (USDOT 2017). Construction noise of 98 decibels in A-weighted scale (dBA) at 50 feet would be about 65 dBA at an approximate half-mile site boundary; a 6 dBA decrease each time the distance is doubled from the source (eNoiseControl 2023). Noise attenuates with distance, thus noise at a location at 1 mile from the site would be below 60 dBA. Noise from construction equipment is expected to be audible over background noise levels, but it is not expected to cause a noticeable adverse impact. Mitigation measures might include noise shields around stationary equipment, limited hours of operation, properly maintained noise suppression equipment on machinery, and equipment operation limited to the day shift only. Overall, noise for the construction of any new generation plant is expected to be SMALL to MODERATE (depending on location and type of sensitive receptor) because most noise-producing construction activities are of short duration (minutes to hours per day) and the construction is temporary, likely being completed in a few years (short-term), and there are numerous mitigation methods that can be implemented to limit the impact of noise. The operation of a new natural gas-fired plant would have noise sources similar to other large industrial facilities. Cooling towers, fans, pumps, compressors, boilers, etc. are usually on a smaller scale than nuclear or coal plants, but still produce noise as they are used to support plant operations. Natural gas-fired sites are usually smaller than coal or nuclear facilities and may be located closer to residences or sensitive receptors due to the smaller area required to separate the site from the public. However, noise levels would still be expected to be within acceptable background noise levels at the nearest residence. Based on projected noise levels, noise impacts from the operation of natural gas-fired facilities are expected to be SMALL for both the surrounding communities and for the nearest residents. Operational noise associated with a solar or storage facility(-ies) would be less than for a natural gas-fired or SMR facility. It is unlikely that noise from operations of a solar or storage facility(-ies) would be experienced beyond the boundaries of the site. Based on projected noise levels, noise impacts from the operation of solar or storage facility(-ies) are expected to be SMALL for both the surrounding communities and for the nearest residents. The major noise source in the operation of a new SMR plant is normally the cooling tower, with noise level dependent on the type of cooling tower chosen. A reasonable expectation for a nuclear unit with mechanical draft cooling towers is approximately 85 dBA near the tower and 55 dBA at 1,000 feet from the towers. At the potential nearest residence (approximately 0.5 miles from the site boundary), noise from the cooling tower is expected to be well below 50 dBA, which is similar to rural background noise levels in a typical rural area. These levels would not exceed USEPAs recommendation or the U.S. Department of Housing and Urban Developments guideline for residential areas. Other operational noise sources of motors, generators, pumps, trucks, and cars for any type of generation facility are typical of an operating Industrial facility. The permanent work force would produce traffic noise during its commute to and from work. Based on the projected noise levels, noise impacts associated with operation of an SMR facility are expected to be SMALL for the surrounding communities and the nearest residents. Cumulatively, noise impacts associated with the construction and operations of a combination of new CC, CT, solar, storage, and SMR generation would range from SMALL to MODERATE based on site-specific conditions and the technology selected for each location. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-19

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Geology and Soils The site chosen would be evaluated for geologic conditions and potential seismic impacts during the site-selection process for all generation technologies. Impacts to geology would be associated with the ground-disturbance activity and could include excavation and blasting. The amount of ground-disturbing activities and impacts to both geology and soils would depend on the site-specific design details for the generation facility. Should the replacement generation be an SMR plant(s), that facility would be required to meet or exceed the current federal regulations for seismic performance (10 CFR Part 50, Appendix S). Therefore, the impacts related to geology and soils, including seismic related impacts would be expected to be SMALL for the any replacement generation facility on a brownfield site. If the new generation resources were constructed on a greenfield site, impacts to soils from ground disturbing activities could range from SMALL to MODERATE depending on the presence of prime farmland soils or farmland of statewide importance and the level of impact to those farmland soils as compared to regional trends. Impacts to geology, including seismic related impacts, on a greenfield site would be SMALL. Cumulatively, geology and soils impacts associated with the construction and operations of a combination of new CC, CT, solar, storage, and SMR generation would range from SMALL to MODERATE based on site-specific conditions and the technology selected for each location. Water Resources Construction of any new generation facility would cause temporary, minor impacts to surface water associated with sedimentation from stormwater runoff during construction activities. These impacts would be minimized through implementation of best management practices (BMPs) designed to minimize erosion during construction. Minor impacts to groundwater due to dewatering of excavations during construction would be minimized with the use of BMPs. Therefore, impacts to water resources associated with the construction of any new generation facility would be SMALL. Both total water withdrawal and consumptive use of water are lower for natural gas-fired CC generating alternatives than the BFN cooling system. For facilities using cooling towers for cooling, natural gas-powered plants use approximately 230 gallons per megawatt-hour (gal/MWh), as opposed to approximately 800 to 1,100 gal/MWh for nuclear power plants. Water consumption is approximately 180 gal/MWh for gas-powered plants, versus approximately 720 gal/MWh for nuclear plants (EPRI 2002). For the same amount of output and similar environmental setting, the impacts to water use and water quality would be lower for the natural gas-fired CC facility than for the Proposed Action. Impacts on water resources of a CC gas-fired generation alternative in the same or comparable location as BFN would be SMALL. Impacts on water resources of a natural gas-fired CC power generation alternative on a greenfield location would range from MODERATE to LARGE. CT gas-fired power plants do not require cooling, so they do not withdraw or consume water (TVA 2019b). Therefore, impacts to water resources of a CT gas-powered generation alternative in the same or comparable location as BFN, or on a greenfield location, would be SMALL. Operation of solar or storage facilities would have minimal water consumption impacts because steam cooling is not needed. Impacts to water quality from operation of solar or storage facility(-ies) would be less than continued operation of BFN. Overall, impacts on water resources and water quality from solar and storage facilities are characterized as SMALL. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-20

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Aggregate cooling water requirements from SMR units totaling 1,200 Mwe output would be similar to that of one BFN unit, and thus one third of water requirements currently at the BFN site. In addition, a closed cycle cooling system such as mechanical cooling towers would likely be used. Impingement, entrainment, and thermal impacts to aquatic resources from make-up water withdrawals and discharges for these closed-cycle systems would be smaller than the impacts of the BFN once-through system (with helper towers) on Wheeler Reservoir. Water quality impacts due to concentration of solids in cooling tower blowdown would be higher than those associated with the once-through (with helper towers) cooling system at BFN. However, these discharges would be regulated under a NPDES permit, and the impacts to water quality would be SMALL. Depending on siting, discharges could be released to rivers or lakes smaller than Wheeler Reservoir, which could result in a greater or lesser relative impact, depending on the affected water bodies. Cumulatively, water resources impacts associated with the construction and operations of a combination of new CC, CT, solar, storage, and SMR generation would range from SMALL to LARGE based on site-specific conditions and the technology selected for each location. Ecological Resources Impacts to terrestrial resources are anticipated to be SMALL from construction of a natural gas-fired plant on an existing industrial site that has been previously disturbed. For the same amount of output and similar environmental setting, the impacts to aquatic resources would be lower for the CC, CT, or storage, facility than for the Proposed Action, due to the reduced water needs, and are, therefore, anticipated to be SMALL. For a greenfield setting, impacts to terrestrial and aquatic resources may be MODERATE. As described previously, solar and SMR facilities may have substantial land requirements (NRC 2013a). Impacts to terrestrial resources are anticipated to be SMALL to MODERATE depending on system land requirements and current land use and habitats present. Ground-mounted solar facilities typically are constructed on previously disturbed land or cropland with low biological diversity and on land where grading and tree clearing would be minimized. Impacts from operation of solar facilities would be SMALL and possibly beneficial for wildlife if the site vegetative cover is maintained in native plant species instead of crops. Impacts to terrestrial resources from constructing and operating an SMR facility at an existing industrial site would be similar to but smaller than TVAs existing nuclear plants. Impacts from construction would be SMALL to MODERATE. Impacts to aquatic resources from operation would be proportionately less than TVAs existing nuclear plants due to the lower capacity of the SMR nuclear plant (TVA 2019b) and, as discussed for water resources, could range from SMALL to MODERATE. The magnitude of impacts on threatened, endangered, and other protected species, critical habitat, and essential fish habitat would depend on the occurrence of such species and habitats and the effects of power plant systems on them. Consultation with appropriate agencies would be needed to determine whether special status species or habitats are present and whether they would be adversely affected by construction and operations. Compliance with the Endangered Species Act (ESA) would minimize impacts on federal listed threatened or endangered species. Therefore, for the purpose of this alternatives assessment, TVA assumes that the construction and operation of the natural gas combined generation alternative would have NO EFFECT or would be NOT LIKELY TO ADVERSELY AFFECT listed species. However, if the large acreage required for the solar or SMR facility could not be located within an existing industrial area, this alternative may have a greater potential to adversely affect listed Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-21

Appendix E - Applicants Environmental Report-Operating License Renewal Stage species due to the extensive areas of land and habitat potentially affected. The need for measures to avoid and mitigate such effects would be determined during consultation with the U.S. Fish and Wildlife Service (USFWS) and/or other agencies. Cumulatively, ecological resource impacts associated with the construction and operations of a combination of new CC, CT, solar, storage, and SMR generation would range from SMALL to MODERATE based on site-specific conditions and the technology selected for each location. Historic and Cultural Resources The magnitude of impacts on cultural resources would depend on the occurrence of such resources within the proposed footprint and in the vicinity of the new generation facility. Compliance with Section 106 of the National Historic Preservation Act (NHPA) and consultation with the appropriate State Historic Preservation Officer (SHPO) would minimize impacts to cultural resources. As the preferred site for placement of a new generation facility would be on an existing industrial site, TVA assumes effects to cultural resources would be minimized due to previous site disturbance. As solar facilities are frequently constructed in previously agricultural land as compared to on an existing industrial site, the potential for previously undiscovered archaeological resources is slightly higher for this alternative as compared to potential CC or CT sites, the effects would be minimized through compliance efforts. Overall, effects could range from NOT PRESENT to ADVERSE EFFECT for both existing industrial sites and greenfield sites depending on the presence or absence of historic properties and the nature of impacts to those resources. Cumulatively, historic and cultural resource impacts associated with the construction and operations of a combination of new CC, CT, solar, storage, and SMR generation would range from NO EFFECT to ADVERSE EFFECT based on site-specific conditions at each location. Socioeconomics Construction of replacement generation leads to an increase in short-term construction and long-term operational jobs at and in the vicinity of the site. The necessary construction workforce for a new natural gas-fired facility would likely come from local and regional sources, creating hundreds of new and indirect jobs for several years. The level of impacts to population, housing, schools, and public services associated with construction and operation of a new generation facility would vary depending on the workforce requirements for that facility, the sites proximity to a large labor force, and the areas economic characteristics. During construction there may be a temporary influx of workers to the area. Construction workers might choose to commute from their established residences, seek short-term rental facilities within commuter range, or acquire more permanent housing in a local area near a potential site. The operational workforce would likely relocate permanently to within commuter range of the new facility. Overall impacts to population, housing, schools, and public services associated with construction of a replacement generation facility would be SMALL to MODERATE depending on existing socioeconomic conditions of the area and region around the site. The phasing out of construction personnel and phasing in of a smaller operational workforce has the potential to cause a boom-and-bust scenario, where a community might not only experience a subsequent drop in overall populations, but also the need for staffing certain indirect jobs. This could result in substantial employment impacts to local communities and counties near the new generation site(s). An incoming permanent workforce would help offset the loss of certain jobs and also create others. The overall impacts could range from SMALL to MODERATE, depending on specific site conditions. Construction of a replacement generation facility could partially offset job loss associated with decommissioning of BFN if some of the Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-22

Appendix E - Applicants Environmental Report-Operating License Renewal Stage BFN workers moved to the new location and were retrained and employed for the construction and/or operations of the new facility. This could be particularly true for an SMR facility and may be less likely for a solar and/or storage facility which do not require many operational workers. Construction and operation of replacement generation sources would result in a beneficial impact to the economy if the total amount of TVA-managed land in any individual county increased and if there were a change in power sales and the value of TVA power property in different areas of the Tennessee Valley thus resulting in a change in TVAs payments in lieu of taxes for that area. Revenue increases would be proportionally small. Any in-lieu-of-tax payment distribution to the local government(s) would be apportioned based on the specific states legislative decision. Whether the local governments existing tax base is small or large, the disbursement would have an overall SMALL beneficial impact. Cumulatively, socioeconomic impacts associated with the construction and operations of a combination of new CC, CT, solar, storage, and SMR generation would range from SMALL to MODERATE based on site-specific conditions and the technology selected for each location. Human Health Worker safety during construction and operation of new generation facilities would be monitored in accordance with Occupational Safety and Health Administration (OSHA) worker protection standards and requirements. Compliance with air permit stipulations would minimize potential offsite impacts to human health associated with air emissions. Potential electric shock hazards associated with transmission lines could occur. TVA would maintain all transmission lines in accordance with its and all applicable standards and requirements. If the facilities use cooling towers with discharge to a water body, there could be the potential for promotion of the growth of thermophilic organisms. TVA would comply with all applicable permit requirements including sampling. Therefore, overall, impacts to human health associated with construction and operation of a CC, CT, solar, or storage facilities would be SMALL. Construction and operation of an SMR facility would also be monitored in accordance with OSHA worker protection standards and requirements. Operation of SMRs would produce radiological effects. There would be no radioactive effects during the construction of a new SMR plant(s) unless the construction takes place at the location of another operating nuclear plant, or there are multiple units being build and one unit becomes operational before the other(s). The radiological impacts from the construction of a new nuclear plant would be of small significance to the construction workers. Workers who would be in close proximity to the operating nuclear plant(s) would be tracked and monitored (radiation badge) as necessary to meet NRC requirements. Depending on the type of nuclear technology chosen, the radioactive effects of a new operating SMR plant(s) would be expected to be less than the BFN current effects. There would be no expected observable impacts from radioactive liquid or gaseous releases from a new SMR plant(s) during normal operations. The Radiological Environmental Monitoring Plan (REMP) would be set up for the new SMR plant(s) to ensure there are no measurable indirect or cumulative effects to the environment offsite of the new location or to the public. All handling and disposal of non-radioactive and radioactive wastes from an SMR facility would be in accordance with applicable rules, regulations, and requirements of local, state, and federal laws. All waste would be properly disposed of in licensed landfills or processed by licensed vendors to recover as much waste as practicable. Special chemicals used would be in accordance with all applicable permits, and personnel would be trained in handling hazardous materials. Overall, impacts to human health associated with operations of an SMR facility would be expected to be SMALL. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-23

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Cumulatively, impacts to human health associated with the construction and operations of a combination of new CC, CT, solar, storage, and SMR generation would be SMALL. Environmental Justice Environmental justice issues would depend on the proposed location of the replacement generation facility. Impacts to environmental justice communities are dependent on the nature of impacts to other resources and whether those impacts result in disproportionate impacts to the affected minority and low-income communities. Potential impacts that might disproportionately impact minority or low-income communities include, for example, pressure on food and housing process, or increases in road congestion or noise near residential communities. The type and level of impact would vary depending upon proximity, mitigation measures, and general construction and operation practices. Impacts to environmental justice in association with construction and operation of a replacement generation facility could range from SMALL to MODERATE. Cumulatively, environmental justice impacts associated with the construction and operations of a combination of new CC, CT, solar, storage, and SMR generation would range from SMALL to MODERATE based on site-specific conditions, including the presence of environmental justice communities, and the technology selected for each location. Waste Management The construction of a replacement generation facility would create sanitary and industrial wastes including general construction waste, concrete, land clearing and stabilizing debris, metals, plastic, wood, packing materials, scrap metals, and non-hazardous used oil and lubricants. These wastes would be properly managed onsite and disposed of at an approved offsite treatment or disposal facility. All non-hazardous waste from construction activities would be disposed of in accordance with applicable regulations and TVAs procedure which includes recycling where possible (TVA 2022e). Overall, waste impacts resulting from construction of a replacement generation facility would be SMALL. Small quantities of hazardous wastes would be generated during construction, operation and maintenance, and decommissioning of any generation facility. Hazardous wastes generated during the construction phase would include substances such as diesel fuel, paint and primer, thinners, oily rags, solvents, spent glycol-based coolants, spent battery electrolyte, and spent lead-acid batteries (BLM and DOE 2010, BLM and DOE 2012). These wastes would be managed in accordance with applicable environmental regulations. During operation, chemicals and hazardous materials would generally not be stored onsite. They would be transported to the site for immediate use during maintenance visits. The transport, storage, handling, use and disposal of chemicals would be conducted in accordance with applicable laws, ordinances, regulations, and standards (BLM and DOE 2010, BLM and DOE 2012).The solid waste generated during operations of a CC or CT facility would be minimal. For a CC or CT plant, the only noteworthy operational waste would be from spent selective catalytic reduction (SCR) catalyst used for NOx control. Most SCR manufacturers offer a disposal service, in which either the SCR catalyst is regenerated for reuse, or its components are recycled for other uses (ICAC 2009). If the catalyst cannot be recycled or reused, the facility operator must dispose of the spent catalyst in an approved landfill. In the United States, most catalyst formulations are not considered hazardous waste (ICAC 2009). Therefore, TVA concludes that waste management impacts expected during construction and operation of a natural gas-fired CC or CT facility would be SMALL. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-24

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Solar and storage facilities would also create minimal operational waste, typically in the form of waste from maintenance activities which would be processed in accordance with all applicable regulations. At solar facilities, high-performance solar cell materials would contain small amounts of toxic metals such as cadmium, selenium, and arsenic. Under normal conditions, these metals are secured within sealed solar panels and represent no hazard to workers or the public. When removed from service, legitimate recycling opportunities would be sought for these panels, but if such opportunities are not available, discarded solar panels containing toxic metals would be characterized, and they might need to be managed as hazardous waste (BLM and DOE 2010, BLM and DOE 2012). On an annual basis, malfunctions or damage sustained in accidents or by weather extremes may result in some panels needing to be replaced (BLM and DOE 2010, BLM and DOE 2012). In general, waste types and volumes produced at a solar generation facility would be small and would result in SMALL impacts associated with waste management. Lithium-ion batteries would be considered hazardous waste. Utility-scale storage using lithium-ion batteries is relatively new, so industrywide disposal guidelines have not been enacted. Lithium-ion batteries are regulated under the Resource Conservation and Recovery Act (RCRA) as they have two characteristics that qualify them as hazardous waste (ignitable and reactive). Like the batteries in a computer or cellphone, the lithium-ion battery modules used in large-scale energy storage projects cannot simply be thrown away, and under universal waste regulations (40 CFR Part 273) must be sent to a permitted hazardous waste disposal facility or a recycler (USEPA 2023). According to USEPA, if not properly managed at the end of their useful life, lithium-ion batteries can cause harm to human health or the environment (USEPA 2023). Recycling large-scale lithium-ion battery redirects batteries from disposal facilities to recycling facilities. While there are valuable components can be harvested and used to build new lithium-ion batteries the quality, performance, safety, and technical viability of reused and refurbished batteries is not yet proven (Curtis et al. 2021). Furthermore, current regulations create no incentives for resource recovery over disposal (Curtis et al. 2021). If recycling becomes mainstream, it could also help reduce the quantity of these hazardous materials entering landfills and could reduce the need to mine raw materials in unstable areas. Due to the potential environmental impacts of improper disposal, the complexities of disposal, and current limited recycling options, the waste management impacts from large-scale energy storage using lithium-ion batteries are characterized as SMALL to MODERATE. Management or radioactive and nonradioactive wastes from SMRs totaling 1,200 MWe output would be similar to that associated with the continued operation of BFN. The approved design would be subject to the same requirements for handling and processing radioactive waste at BFN. Similar to BFN, the environmental impacts associated with radioactive waste handling, storage, and transportation would be expected to be small. Impacts to the environment from releases of radioactive liquids and gases would be small. Solid radioactive waste would be handled in accordance with TVA-approved procedures, which ensure that all federal regulations and limits pertaining to solid radioactive waste are met. If new technology allowed for reduced radioactive waste volumes due to advancements in design, equipment, and programs in the new nuclear facility, the impacts associated with operation of a new nuclear generation facility may even be less than that at BFN. For a new nuclear generating facility, spent fuel typically would be stored in a spent fuel pool. Once a new nuclear generating facility is operating, spent fuel would be produced in processes similar to BFN. The expected environmental impacts associated with spent fuel storage at any new nuclear generation facility would be expected to be SMALL. A new SMR facility would be Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-25

Appendix E - Applicants Environmental Report-Operating License Renewal Stage bound by the same transportation criteria for radioactive wastes that currently applies to BFN operation and any impact would be expected to be SMALL. Cumulatively, waste management related impacts associated the construction and operations of a combination of new CC, CT, solar, storage, and SMR generation would range from SMALL to MODERATE based on site-specific conditions and the technology selected for each location. Climate Change Construction related sources of GHG emissions associated with new generation facilities primarily include engine exhaust from worker vehicles and onsite equipment. These emissions are also temporary. Therefore, the environmental impact of a construction of a new generation facility(-ies) on GHGs and climate change would be SMALL. GHG emissions from a new natural gas-fired plant would be controlled and in compliance with all applicable federal, state, and local regulations. Therefore, GHG emissions are anticipated to be SMALL and GHG-related impacts on climate change in association with new CC or CT facility(-ies) would be SMALL. Operations of new solar or storage facilities would not generate a significant source of GHG emissions. Emissions would occur primarily in connection with use of worker vehicles or vehicles and equipment for maintenance and inspection activities. GHG emissions would be intermittent and minor with the level less than that from BFN or natural gas-fired facilities. Therefore, GHG emissions and GHG-related impacts on climate change in association with operation of new solar or storage facilities would be SMALL. Operation of a new SMR facility would not create a significant source of pollutants including GHG. The primary GHG emissions from operation of a new SMR plant would be emitted from onsite combustion sources (diesel generators, boilers, pumps), worker vehicles, and equipment associated with site inspections or maintenance activities. GHG emissions would be intermittent and minor with the level less than or comparable to that from BFN or natural gas-fired facilities. Therefore, the environmental impact of a new SMR on GHGs and climate change would be SMALL. Cumulatively, climate change-related impacts associated with the construction and operations of a combination of new CC, CT, solar, storage, and SMR generation would be SMALL. 7.2.4. Summary Because any combination of natural gas-fired and renewable energy alternatives to replace BFN would require construction activities, TVA concludes that that the overall and cumulative environmental impacts of these alternatives would be greater than the SMALL level of impacts associated with the subsequent period of extended operations of the BFN operating licenses. 7.3. Alternatives for Reducing Adverse Impacts 10 CFR 51.53(c)(3)(iii) states that "The report must contain a consideration of alternatives for reducing adverse impacts, as required by 10 CFR 51.45(c), for all Category 2 license renewal issues in Appendix B to Subpart A of this part. No such consideration is required for Category 1 issues in Appendix B to Subpart A of this part." However, since the NRC has ruled that the 2013 GEIS approach was not sufficient for SLR applications, this ER fully evaluated all Category 1 issues at the same level of detail as Category 2 issues. A review of the environmental impacts associated with Category 1 and Category 2 issues as required by 10 CFR 51.53(c)(3)(ii), and Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-26

Appendix E - Applicants Environmental Report-Operating License Renewal Stage provided in Chapter 4, identified no significant adverse effects that would warrant consideration of additional alternatives to reduce or avoid those impacts. Therefore, TVA concludes that the impacts associated with renewal of the BFN SLR would not require consideration of alternatives for reducing adverse impacts as specified in the NRC Regulatory Guide 4.2, Revision 1. This determination assumes the existing mitigation measures discussed in Chapter 4 adequately minimize and avoid the environmental impacts associated with operating BFN. No additional alternatives were considered by TVA to reduce impacts. As determined in Chapter 4, all impacts identified for the continued operation of BFN were determined to be SMALL and do not result in significant adverse effects to the environment. 7.4. References BLM and DOE (Bureau of Land Management and U.S. Department of Energy). 2010. Draft Programmatic Environmental Impact Statement for Solar Energy Development in Six Southwestern States - Volume 1, DOE/EIS-0403. Chapter 3: Overview of Solar Energy Power Production Technologies, Development, and Regulation. December 2010. BLM and DOE. 2012. Final Programmatic Environmental Impact Statement (PEIS) for Solar Energy Development in Six Southwestern States - Volume 1. DOE/EIS-0403. July 2012. Curtis Taylor L., Ligia Smith, Heather Buchanan and Garvin Heath. 2021. A Circular Economy for Lithium-Ion Batteries Used in Mobile and Stationary Energy Storage: Drivers, Barriers, Enablers, and U.S. Policy Considerations. NREL/TP-6A20-77035. March 2021. DOE (U.S. Department of Energy). 2015. Wind Vision - A New Era for Wind Power in the United States. DOE. 2019. Demonstration of the Ocean Energy (OE) Buoy at US Navys Wave Energy Test Site. Water Power Technologies Office 2019 Peer Review. Marine and Hydrokinetics Program. Marine and Hydrokinetics Program. Accessed October 5, 2022 at https://www.energy.gov/sites/prod/files/2019/12/f69/07_EE0006924_OceanEnergy_Lewi s_%20Mauer_Final.pdf. DOE. 2023. Advanced Small Modular Reactors (SMRs). Accessed October 26, 2023 at https://www.energy.gov/ne/nuclear-reactor-technologies. EIA (U.S. Energy Information Administration). 2017. Oil-fired power plants provide small amount of U.S. electricity capacity and generation. May 16, 2017. Accessed October 5, 2022 at https://www.eia.gov/todayinenergy/detail.php?id=31232#tab2. EIA. 2021. Battery Storage in the United States: An Update on Market Trends. August 2021. Accessed September 23, 2022 at https://www.eia.gov/analysis/studies/electricity/batterystorage/pdf/battery_storage_2021. pdf. EIA. 2022a. Cost and Performance Characteristics of New generating Technologies, Annual Energy Outlook 2022. March 2022. Accessed October 5, 2022 at https://www.eia.gov/outlooks/aeo/assumptions/pdf/table_8.2.pdf. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-27

Appendix E - Applicants Environmental Report-Operating License Renewal Stage EIA. 2022b. Natural Gas and the Environment. November 7, 2022. Accessed October 25, 2023 at https://www.eia.gov/energyexplained/natural-gas/natural-gas-and-the-environment.php. eNoiseControl. 2023. Doubling of Distance Noise Reduction. Accessed November 15, 2023 at https://www.enoisecontrol.com/acoustic-terminology/doubling-distance-noise-reduction-decibel/. EPRI (Electric Power Research Institute). 2002. Water & Sustainability (Volume 3): U.S. Water Consumption for Power Production - The Next Half Century. March 2022. EPRI. 2011. Mapping and Assessment of the Unites States Ocean Wave Energy Resource. 2011 Technical Report. December 2011. ERC (Energy Recovery Council). 2018. 2018 Directory of Waste-to-Energy Facilities. October 2018. Geothermal Energy Association. 2013. The Values of Geothermal Energy: A discussion of the Benefits of Geothermal Power Provides to the Future U.S. Power System. October 2013. ICAC (Institute of Clean Air Companies). 2009. White Paper: Selective Catalytic Reduction (SCR) Control of NOx Emission from Fossil Fuel-Fired Electric Power Plants. NOX Control Technical Division, Institute of Clean Air Companies, Inc. May 2009. NRC (Nuclear Regulatory Commission). 2002. Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Regarding the Decommissioning of Nuclear Power Reactors. NUREG-0586, Supplement 1, Volume 1: Main Report, Appendices A though M. November 2022. NRC. 2013a. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG-1437, Volume 1, Revision 1. Office of Nuclear Reactor Regulation. June 2013. NRC. 2013b. Preparation of Environmental Reports for Nuclear Power Plan License Renewal Applications. Regulatory Guide 4.2, Supplemental 1, Revision 1. June 2013. NRC. 2019. Environmental Impact Statement for an Early Site Permit (ESP) at the Clinch River Nuclear Site. Final Report (NUREG-2226, Volume 1). Accessed January 4, 2023 at https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr2226/index.html. NREL (National Renewable Energy Laboratory). 2021. 2021 U.S. Geothermal Power Production and District Heating Market Report. July 2021. PacWave. 2021. Testing Wave Energy for the Future. Accessed October 5, 2022 at https://pacwaveenergy.org/. TVA. 2019a. 2019 Integrated Resource Plan. Volume 1 - Final Resource Plan. June 2019. TVA. 2019b. 2019 Integrated Resource Plan. Volume II. Final Environmental Impact Statement. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-28

Appendix E - Applicants Environmental Report-Operating License Renewal Stage TVA. 2020. First TVA-owned battery storage to shape energy future. September 21, 2020. Accessed October 5, 2022 at https://www.tva.com/newsroom/press-releases/first-tva-owned-battery-storage-to-shape-energy-future. TVA. 2021a. TVA Charts Path to Clean Energy Future. Accessed October 5, 2022 at https://www.tva.com/newsroom/press-releases/tva-charts-path-to-clean-energy-future. TVA. 2021b. Wind Energy Contracts. Accessed October 5, 2022 at https://www.tva.com/Energy/Valley-Renewable-Energy/Wind-Energy-Contracts. TVA. 2022a. Advanced Nuclear Solutions. Accessed October 5, 2022 at https://www.tva.com/energy-system-of-the-future/advanced-nuclear-solutions. TVA. 2022b. Annual Report Pursuant to Section 13, 15(d), or 37 of the Securities Exchange Act of 1934. For the fiscal year ended September 30, 2022. November 15, 2022. TVA. 2022c. Clinch River Nuclear Site Advanced Nuclear Reactor Technology Park. Final Programmatic Environmental Impact Statement and Record of Decision. Accessed November 30, 2022. TVA. 2022d. How a Combustion Turbine Plant Works. Accessed October 5, 2022 at https://www.tva.com/Energy/Our-Power-System/Natural-Gas/How-a-Combustion-Turbine-Plant-Works. TVA. 2022e. Johnsonville Aeroderivative Combustion Turbines Project Draft Environmental Assessment. Humphreys County, Tennessee. January. TVA. 2022f. TVA Board Authorizes New Nuclear Program to Explore Innovative Technology. February 10, 2022. Accessed October 5, 2022 at https://www.tva.com/newsroom/press-releases/tva-board-authorizes-new-nuclear-program-to-explore-innovative-technology. TVA. 2022g. Vonore Battery Energy Storage System and Associated Substation. Monroe and Blount Counties, Tennessee. Final Environmental Assessment. January 2022. TVA. 2023a. Browns Ferry Nuclear Plant Subsequent License Renewal Project, Final Supplemental Environmental Impact Statement. Limestone County, Alabama. August 2023. TVA. 2023b. Solar. Accessed November 14, 2023 at https://www.tva.com/energy-system-of-the-future/solar. Unwin, Jack. 2019. What Is Geothermal Energy? Power Technology. June 18, 2019. Accessed April 13, 2022 at https://www.power-technology.com/features/what-is-geothermal-energy/. USEPA (U. S. Environmental Protection Agency). Used Lithium - Ion Batteries. May 24, 2022. Accessed August 25, 2022 at https://www.epa.gov/recycle/used-lithium-ion-batteries. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E7-29

Appendix E - Applicants Environmental Report-Operating License Renewal Stage CHAPTER 8 - COMPARISON OF ENVIRONMENTAL IMPACT OF SUBSEQUENT LICENSE RENEWAL TO THE ALTERNATIVES Chapter 4 analyzes environmental impacts of the Browns Ferry Nuclear Plant (BFN) subsequent license renewal (SLR) and Chapter 7 analyzes impacts of reasonable alternatives. Table 8.1-1 summarizes environmental impacts of the Proposed Action (SLR) and the reasonable alternatives, for comparison purposes based on the 10 topical environmental resource areas identified in the Generic Environmental Impact Statement (GEIS) (NRC 2013) but consistent with the topical organization of Chapter 4 of this document. The topical environmental resource areas are the broader categories within which all of the 78 GEIS impact issues are categorized. Table 8.1-2 provides a more detailed comparison of the alternatives based on the topical environmental resource areas. As shown in Table 8.1-1 and Table 8.1-2, environmental impacts of the Proposed Action (BFN SLR) to which the SMALL, MODERATE or LARGE measures of significance apply are all expected to be SMALL or not applicable to BFN. For threatened and endangered species, the Proposed Action is likely to have NO EFFECT or NOT LIKLEY TO ADVERSELY EFFECT. The Proposed Action is likely to have NO ADVERSE EFFECT on cultural resources. With regard to the considered alternative actions, the Tennessee Valley Authority (TVA) expects that environmental impacts on specific resources could be SMALL to LARGE (Tables 8.1-1 and 8.1-2). For threatened and endangered species, the alternative actions are expected to have NO EFFECT or NOT LIKELY TO ADVERSELY EFFECT protected species, depending on the siting of the plants and assumed mitigation measures. For cultural resources, the alternative actions could occur where no resource is present or in a location where an ADVERSE EFFECT on resources could take place. TVA concludes the environmental impacts of the continued operation of BFN, providing approximately 3,900 megawatts electric (MWe) of base-load power generation through 2056, would be smaller overall than impacts associated with any of the other reasonable alternatives analyzed. BFNs continued operation will create the same or significantly less environmental impact than the construction and operation of any other new base-load generation capacity, and therefore, there is no other preferred alternative. Additionally, BFNs continued operation will extend the existing significant positive economic impact on the communities near BFN. Therefore, TVA concludes the results of this analysis support the approval of BFN Units 1, 2, and 3 SLR to maintain the option of continued BFN operation for energy planning decision makers. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E8-1

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 8.1-1. Impacts Comparison Summary No Action Proposed Action (Subsequent Impact No Action (Decommissioning) (Combination of New Generating License Renewal) Assets) Land Use and Visual SMALL SMALL SMALL to LARGE Resources Air Quality SMALL SMALL SMALL to MODERATE Noise SMALL SMALL SMALL to MODERATE Geology and Soils SMALL SMALL SMALL to MODERATE Water Resources SMALL SMALL SMALL to LARGE Ecological Resources SMALL SMALL SMALL to MODERATE Threatened or NO EFFECT to NOT LIKELY TO NO EFFECT to NOT LIKELY TO NO EFFECT to NOT LIKELY TO Endangered Species1 ADVERSELY AFFECT ADVERSELY AFFECT ADVERSELY AFFECT Historic and Cultural NOT PRESENT to ADVERSE NO ADVERSE EFFECT NO ADVERSE EFFECT Resources2 EFFECT Socioeconomics SMALL SMALL SMALL to MODERATE Human Health SMALL or UNCERTAIN SMALL SMALL Environmental Justice SMALL SMALL SMALL to MODERATE Waste Management SMALL SMALL SMALL to MODERATE Climate Change SMALL SMALL SMALL 1 Effects on threatened or endangered species may be characterized as follows: (1) no effect, (2) not likely to affect, (3) likely to affect, (4) likely to jeopardize continued existence. 2 Effects on historic properties may be characterized as follows: (1) no historic properties present, (2) historic properties are present, but not adversely affected, or (3) historic properties are adversely affected. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E8-2

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 8.1-2. Impacts Comparison Detail Proposed Action No Action No Action (Subsequent License Renewal) (Decommissioning) (Combination of New Generating Assets) Decommissioning following Construction of a combination natural gas-fired combined cycle Subsequent license renewal of expiration of current BFN Units 1, generation, natural gas-fired combustion turbine generation, solar BFN Units 1, 2, and 3 for 20 years 2 and 3 renewed operating generation, energy storage, and nuclear-powered generation in the each, followed by termination of licenses. Adopting by reference, form of small modular reactors (SMRs) within the Region of Interest plant operations and as bounding for BFN, (ROI). (Section 7.2.3.2) decommissioning. decommissioning 2002 description (Section 7.1). Land Use and Visual Resources SMALL to LARGE. Some of the new generation assets could be sited on the nearly 880-acre BFN site and some would be sited offsite SMALL for all GEIS issues. SMALL. within the ROI. The level of impact anticipated during construction (Table 6.1-1, Section 4.1) (Table 4.16-1; Section 4.16) and operation would vary depending upon the type of land chosen (i.e., disturbed industrial, commercial, or agricultural lands). (Section 7.2.3.2) Air Quality SMALL to MODERATE. Construction impacts would be minimized by the use of best management practices. To contribute to replacing a baseload of 3,900 MWe, operation of a 500 MWe natural gas-fired SMALL for all GEIS issues. SMALL. generation assets could generate approximately: (Table 6.1-1, Section 4.2) (Table 4.16-1; Section 4.16) 66 tons SO2/year; 1,925 tons NOx/year; 292 tons CO/year; 37 tons PM/PM10/PM2.5filterable/year; 2,274,878 tons CO2/year. All other generation asset operations would have SMALL impacts. (Section 7.2.3.2) Noise Impacts SMALL to MODERATE. Noise impacts associated with the construction for new generation would rise above ambient levels, but SMALL for all GEIS issues. SMALL. below 60 dBA 1 mile from the site, and range from SMALL to (Table 6.1-1, Section 4.3) (Table 4.16-1; Section 4.16) MODERATE, based on site-specific conditions and mitigation measures. Operational noise impacts would be SMALL for all generation assets. (Section 7.2.3.2) Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E8-3

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Proposed Action No Action No Action (Subsequent License Renewal) (Decommissioning) (Combination of New Generating Assets) Geology and Soils SMALL to MODERATE. Ground disturbance activities would cause SMALL impacts related to geology and soils, including seismic related impacts, for the any replacement generation facility on a SMALL for all GEIS issues. SMALL. brownfield or greenfield site. Depending on the presence of prime or (Table 6.1-1, Section 4.4) (Table 4.16-1; Section 4.16) important farmland soils, the level of impact could range from SMALL to MODERATE. Impacts may differ based on site-specific conditions and the technology. (Section 7.2.3.2) Water Resources SMALL to LARGE. Construction impacts would be minimized by best management practices. For operations, SMR units totaling 1,200 MWe output would have aggregate cooling water requirements similar to one BFN unit. Natural-gas facilities using cooling towers for SMALL - for all applicable GEIS SMALL. cooling use approximately 230 gallons per megawatt-hour (gal/MWh), issues. (Table 6.1-1, Section 4.5) (Table 4.16-1; Section 4.16) as opposed to approximately 800 to 1,100 gal/MWh for nuclear power plants. Therefore, a combination of generation assets would be anticipated to use and consume less water than BFN operations. (Section 7.2.3.2) Ecological Resources SMALL to MODERATE. Construction and operation impact of new generation assets would vary based on site selection and existing site SMALL for all GEIS issues. SMALL. conditions. Impacts would be minimized through the use of best (Table 6.1-1, Section 4.6) (Table 4.16-1; Section 4.16) management practices and adhering to federal and state regulations. (Section 7.2.3.2) Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E8-4

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Proposed Action No Action No Action (Subsequent License Renewal) (Decommissioning) (Combination of New Generating Assets) Threatened and Endangered Species1 NO EFFECT to NOT LIKELY TO ADVERSELY AFFECT. The magnitude of impacts on threatened, endangered, and other protected species, critical habitat, and essential fish habitat would NO EFFECT to NOT LIKELY TO NO EFFECT to NOT LIKELY TO depend on the occurrence of such species and habitats and the ADVERSELY AFFECT. ADVERSELY AFFECT. effects of the generating assets on them. Federal and state laws (Table 6.1-1, Section 4.6) prohibit destroying or adversely affecting protected species and their habitats. Consultation with appropriate agencies would be conducted. (Section 7.2.3.2) Historic and Cultural Resources2 NOT PRESENT to ADVERSE EFFECT. Impacts would vary for both existing industrial sites and greenfield sites depending on the presence or absence of historic properties on the sites selected for NO ADVERSE EFFECT. (Table the new generating assets. Compliance with Section 106 of the NO ADVERSE EFFECT. 6.1-1, Section 4.7). National Historic Preservation Act and consultation with the appropriate State Historic Preservation Officer and Tribal Historic Preservation Officers would minimize impacts to cultural resources. (Section 7.2.3.2) Socioeconomics SMALL to MODERATE. Closure of BFN would result in a loss of operational and temporary refueling jobs which could result in an adverse socioeconomic impact for various aspect of the local community including employment, taxes, housing, offsite land use, SMALL for all GEIS findings. SMALL. economic structure and public services. These impacts would be (Table 6.1-1, Section 4.8) (Table 4.16-1; Section 4.16) partially offset if some BFN workers were retrained and employed for the construction and/or operations of the replacement generation assets and/or at other locations within the TVA system. (Section 7.2.3.2) Human Health SMALL to Uncertain for all GEIS SMALL. Due to safety standards and regulations, impacts to human SMALL. findings. (Table 6.1-1, Section health associated with construction and operation of a new (Table 4.16-1; Section 4.16) 4.9) generation facilities would be SMALL. (Section 7.2.3.2) Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E8-5

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Proposed Action No Action No Action (Subsequent License Renewal) (Decommissioning) (Combination of New Generating Assets) Environmental Justice SMALL to MODERATE. The socioeconomic impacts could result in SMALL for all GEIS findings. SMALL. impacts to environmental justice communities. It is not anticipated (Table 6.1-1, Section 4.11) (Table 4.16-1; Section 4.16) that these impacts would be disproportionate. (Section 7.2.3.2) Waste Management SMALL to MODERATE. The quantities and types of solid waste generated by the construction and operation of replacement generation resources would be determined primarily by the number of SMALL for all GEIS findings. SMALL. acres, the initial condition of the selected site(s), and the location and (Table 6.1-1, Section 4.12) (Table 4.16-1; Section 4.6) type of technology chosen. All waste would be properly managed onsite and disposed of at approved treatment or disposal facilities in accordance with applicable regulations. (Section 7.2.3.2) Climate Change SMALL. All technologies would have very little GHG emissions, and SMALL SMALL therefore GHG-related impacts on climate change in association with (not included in the GEIS) (not included in the GEIS) construction and operation would be small for all generation assets (Section 7.2.3.2) 1 Effects on threatened or endangered species may be characterized as follows: (1) no effect, (2) not likely to adversely affect, (3) likely to adversely affect, (4) likely to jeopardize continued existence. 2 Effects on historic properties may be characterized as follows: (1) no historic properties present, (2) historic properties are present, but not adversely affected, or (3) historic properties are adversely affected. SMALL - Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource. MODERATE - Environmental effects are sufficient to alter noticeably, but not to destabilize, any important attribute of the resource. LARGE - Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource. (10 CFR Part 51, Subpart A, Appendix B, Table B-1, Footnote 3). ROI = region of interest = Tennessee Valley Power Service Area which includes all of Tennessee, portions of Alabama, Mississippi, and Kentucky, and small areas of Georgia, North Carolina, and Virginia. SO2 = sulfur dioxide; NOx = nitrogen oxide; CO = carbon monoxide; CO2 = carbon dioxide; PM = particulate matter; PM10 = particulate matter with aerodynamic diameters of 10 microns or less; PM2.5 = particulate matter with aerodynamic diameters of 2.5 microns or less Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E8-6

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 8.1. References NRC (Nuclear Regulatory Commission). 2002. Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities: Regarding the Decommissioning of Nuclear Power Reactors. NUREG-0586, Supplement 1, Volume 1: Main Report, Appendices A though M. November 2022. NRC. 2013. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG-1437, Volume 1, Revision 1. Office of Nuclear Reactor Regulation. June 2013. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E8-7

Appendix E - Applicants Environmental Report-Operating License Renewal Stage CHAPTER 9 - STATUS OF COMPLIANCE 9.1. Proposed Action 9.1.1. General Table 9.1-1 lists environmental authorizations Tennessee Valley Authority (TVA) has obtained for current Browns Ferry Nuclear Plant (BFN) operations. In this context, TVA uses authorizations to include any permits, licenses, approvals, or other entitlements. TVA expects to continue renewing these authorizations, as appropriate, during the current period of operation and throughout the subsequent period of extended operation associated with the subsequent license renewal (SLR) of BFN. Because the U.S. Nuclear Regulatory Commission (NRC) regulatory focus is prospective, Table 9.1-1 does not include authorizations TVA obtained for past activities that did not include continuing obligations. Before applying for the BFN SLR to operate, TVA conducted an assessment to identify new and significant environmental information (Chapter 5). The assessment included interviews with subject experts, review of TVA and BFN environmental documentation, and communication with state and federal environmental protection agencies. Based on this assessment, TVA concludes BFN is in substantive compliance with applicable environmental standards and requirements. Minor deviations from applicable standards or requirements are corrected, and notification is provided to regulatory agencies, as required. Table 9.1-2 lists additional environmental authorizations and consultations related to NRC renewal of the BFN licenses to operate. As indicated, TVA anticipates needing relatively few such additional authorizations and consultations. Sections 9.1.2 through 9.1.9 discuss these items in more detail. 9.1.2. Endangered Species Act Section 7 of the Endangered Species Act (ESA; 16 United States Code [U.S.C.] 1531 et seq.) requires federal agencies to ensure that their actions are not likely to jeopardize the continued existence of species that are federally listed, or proposed for listing, as endangered or threatened. Depending on the action involved, the ESA requires consultation with the United States Fish and Wildlife Service (USFWS), regarding effects on non-marine species, and with the National Marine Fisheries Service (NMFS), when marine species could be affected. USFWS and NMFS have issued joint procedural regulations at 50 CFR Part 402, Subpart B, that address consultation, and USFWS maintains the joint list of threatened or endangered species at 50 CFR Part 17. Although not required of an applicant by federal law or NRC regulation, TVA invited comment from federal and state agencies regarding potential effects the BFN SLR might have on state and federally protected species. includes TVAs Bat Strategy Review Form prepared in compliance with TVAs Bat Strategy negotiated with USFWS. 9.1.3. Bald and Golden Eagle Protection Act The Bald and Golden Eagle Protection Act prohibits anyone, without a permit issued by the Secretary of the Interior, from taking bald eagles, which includes molesting or disturbing the birds or their nests or eggs. The bald eagle could forage in Wheeler Reservoir, and suitable nesting trees are present in the forest fragment along the reservoir in the southeastern corner of BFN, although no bald eagle nests have been documented on the BFN site. The National Bald Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E9-1

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Eagle Management Guidelines require the maintenance of a 660-foot buffer around bald eagle nest sites and coordination with USFWS to determine if mitigation measures are adequate (USFWS 2007). Bald eagle nests, if established within this distance of the BFN site, would be protected in accordance with the guidelines. 9.1.4. Migratory Bird Treaty Act The Migratory Bird Treaty Act (MBTA) makes it unlawful to pursue, hunt, take, capture, kill, or sell birds listed and grants protection to any bird parts including feathers, eggs, and nests. TVA currently complies with Executive Order 13186: Responsibilities of Federal Agencies to Protect Migratory Birds, in accordance with the MBTA. Additionally, TVA is developing a memorandum of agreement (MOA) with the USFWS that will include an Avian Protection Plan. The MOA and Avian Protection Plan will be applicable TVA-wide, including BFN. 9.1.5. Clean Air Act BFN operates under a synthetic minor source permit (Permit No. 708-0003-X005) issued by Alabama Department of Environmental Management (ADEM). This permit allows for the use of emergency diesel generators and auxiliary boilers. BFN tracks monthly operating hours for each equipment on a 12-month rolling basis. BFN is operating in compliance of the synthetic minor source permit conditions. 9.1.6. National Historic and Preservation Act Section 106 of the National Historic Preservation Act (NHPA) requires federal agencies having the authority to license any undertaking to consider the effect of the undertaking on historic properties and to afford the Advisory Council on Historic Preservation an opportunity to comment on the undertaking, prior to the agency issuing the license (54 U.S.C. 306108). Advisory Council regulations provide for the State Historic Preservation Office (SHPO) to have a consulting role (36 CFR 800.2). Attachment 3 includes copies of TVAs correspondence with the SHPO regarding potential effects the BFN SLR might have on historic or cultural resources. Based on the TVA submittal and other information, the Alabama SHPO concurred with TVAs findings of BFNs National Register of Historic Places eligibility, any modifications to BFN would require consultation, and the BFN SLR will have no effect on historic buildings, structures, and/or archaeological resources located in or near the project area. 9.1.7. Clean Water Act 9.1.7.1. Water Quality (401) Certification Federal Clean Water Act (CWA) Section 401 requires an applicant seeking a federal license for an activity that may result in a discharge to navigable waters to provide the federal licensing agency with a certification, or a waiver of certification, by the state where the discharge would originate. If no waiver is issued by the state, its certification must indicate applicable state water quality standards will not be violated as a result of the discharge (33 U.S.C. 1341). The NRC recognized in the 2013 GEIS some National Pollutant Discharge Elimination System (NPDES) delegated states explicitly integrate their 401 certification process with NPDES permit issuance (NRC 2013). In accordance with Section 402 of the CWA (33 U.S.C. 1342) the U.S. Environmental Protection Agency (USEPA) delegated to the State of Alabama its authority to issue NPDES permits. The Alabama Department of Environmental Management (ADEM) is authorized by USEPA to administer NPDES permitting rules in Alabama (USEPA 2020). Within ADEM, the Water Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E9-2

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Division administers the NDPES permits (ADEM 2021). The requirements for NPDES permits are detailed in Alabama Administrative Code Chapter 335-6-6 (ADEM 2015). BFN is regulated by NPDES Permit No. AL0022080 which expires on August 31, 2023 (ADEM 2018). TVA has applied for and anticipates renewal of the NPDES permit in 2023. The NPDES permit establishes discharge limitations and monitoring requirements for specific constituents by outfall, based on the type of wastewater discharged through the respective outfall. The permit states that, based on the permittees application, plans, and other available information, ADEM has determined that compliance with the terms and conditions of the permit assures compliance with applicable water quality standards. TVA will continue to renew and comply with the permit as long as the outfalls remain operational. 9.1.7.2. Section 404 Permit The physical alteration of water bodies is regulated by federal and state statutes under Section 401 (Certification) and Section 404 (Permits) of the CWA. The U.S. Army Corps of Engineers (USACE) regulates and permits dredging and fill activities in the waters of the United States, including wetlands. The Section 404 permit authorizes the discharge of dredged and/or fill material under Section 404, while Section 401 requires the applicant for a Section 404 permit to also obtain a Water Quality Certification from the state to confirm that the discharge of fill materials will be in compliance with applicable state water quality standards. The BFN intake channel must occasionally be dredged for maintenance purposes to return the intake channel to design specifications. The intake channel has been dredged only once (in 2018), which was the first time in the 46-year operating history of BFN. TVA evaluates routine maintenance impacts using a National Environmental Policy Act (NEPA) categorical exclusion checklist. Maintenance dredging is performed under a permit provided by the USACE Mobile District. 9.1.8. Rivers and Harbor Act of 1899 The Rivers and Harbors Act of 1899 (RHA) is the initial authority of the USACE regulatory permit program to protect navigable waters of the United States. Section 10 prohibits the unauthorized obstruction or alteration of any navigable water (USACE 2012). The Tennessee River, which includes the Wheeler Reservoir, is an RHA Section 10 waterway from its mouth (Tennessee River Mile [TRM] 0) to its head (TRM 651.1 and the confluence of the French Broad and Holston Rivers). Regulatory control of Wheeler Reservoir is exercised by the USACE Nashville District (USACE 2022a, USACE 2022b). Wheeler Reservoir is a navigable waterway used by commercial and recreational traffic. It is one of nine reservoirs that create a stairway of navigable water on the Tennessee River from Knoxville, Tennessee, to the mouth of the Tennessee River at the Ohio River in Paducah, Kentucky (TVA 2021). TVA has no plans for refurbishments activities or modifications beyond normal maintenance at BFN associated with SLR. In the event construction is needed at water intakes or discharge structures, BFN will consult and obtain all necessary authorizations. 9.1.9. Coastal Zone Management Program Section 307 in the Coastal Zone Management Act of 1972 (16 U.S.C. 1451 et seq.), referred to as the federal consistency provision, requires that federal actions within and outside a states coastal zone that would have reasonably foreseeable effects on any coastal use or natural resource of the coastal zone be consistent with the enforceable policies of the states federally approved coastal management program. Federal actions include federal licensing activities, Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E9-3

Appendix E - Applicants Environmental Report-Operating License Renewal Stage such as renewal by the NRC of a nuclear reactor license. Since BFN is located inland on the Wheeler Reservoir, it is not subject to the Coastal Zone Management Act of 1972. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E9-4

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 9.1-1. Environmental Authorizations for Current BFN Agency Authority Requirements Number Issue and Expiration Dates Activity Covered Renewed DPR- Expires on December 20, Operation of BFN Unit 1 33 (Unit 1) 2033 Atomic Energy Act (42 Renewed DPR-NRC USC 2011, et seq.), 10 License to operate Expires on June 28, 2034 Operation of BFN Unit 2 52 (Unit 2) CFR 50.10 Renewed DPR-Expires on July 2, 2036 Operation of BFN Unit 3 68 (Unit 3) Issued on: June 7, 2018 Effective Date July 1, 2018 CWA (33 U.S.C. Section Discharges to river including Expires on August 31, 2023 ADEM 1251 et. seq); 40 CFR NPDES Permit AL0022080 cooling waters, fire Permit renewal application 122.26; Alabama protection, and storm waters submitted; renewal anticipated in 2023 Resource Conservation Regulated Waste Permit Regulated Waste ADEM and Recovery Act AL8640015410 Not Applicable (hazardous waste, used oil, Permit [RCRA] universal waste permit) Issued on: March 2014 USEPA; 40 CFR 49.158 Minor Source 708-0003-X003 Indefinite (valid until system Fuel Facility ADEM 335-14-01 Permit is modified) Issued on: November 2020 Synthetic minor permit (i.e., AL Codes 22-22A-1 Synthetic Minor ADEM 708-0003-X005 Indefinite (valid until system emergency diesel through 22-22a-17 Permit is modified) generators, auxiliary boilers) State of Tennessee Department of License to ship Radioactive material TDEC T-AL002-L22 Renewed Annually Environment & radioactive material shipments Conservation Health/Safety Code Texas Ship radioactive Issued on: July 2022 Radioactive material 401.52 and Admin Code W0019 DSHS material Expires: June 2032 shipments 289.257 UT Administrative Codes Ship radioactive Radioactive material UDEC 1505009347 Renewed annually R313-26 and R313-19 material shipments Tennessee River Use of Wheeler Reservoir TVA TVA Act of 1933 Not Applicable Not Applicable Management water Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E9-5

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Table 9.1-2. Environmental Authorizations for BFN Subsequent License Renewal Agency Authority Requirements Remarks Applicant for federal license Atomic Energy Act must submit an Environmental NRC License renewal (42 USC 2011 et seq.) Report in support of license renewal application. Federal agency issuing a USFWS ESA Section 7 license must consult with the Consultation NMFS (16 USC 1536) USFWS and NMFS regarding federally protected species. Bald and Golden Federal statute that protects 16 U.S.C. 668-668d Consultation Eagle Protection Act two species of bald eagles. Prohibits the take (killing, Migratory Bird Treaty capturing, selling, trading, and 16 U.S.C. 703-712 Consultation transport) of protected Act migratory bird species without prior authorization by USFWS. Federal law that regulates air Clean Air Act 42 U.S.C. 7401 et seq. Certification emissions from stationary and mobile sources. Applicant seeking federal license for a project with discharge to state waters must obtain either state certification CWA Section 401 that proposed action would (33 U.S.C. 1341) comply with applicable state ADEM (33 U.S.C. 1344) Certification water quality standards, or a waiver. (Section 404) Actions involving wetlands and/or stream crossings would be subject to federal Clean Water Act Section 404 permit requirements. Requires authorization from the Secretary of the Army, Rivers and Harbors acting through USACE, for the Section 10 Authorization Act of 1899 construction of any structure in or over any navigable water of the United States. Alabama State Federal agency issuing a NHPA Section 106 license must consider cultural Historic Preservation Consultation (54 USC 306108) impacts and consult with Office SHPO. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E9-6

Appendix E - Applicants Environmental Report-Operating License Renewal Stage 9.2. Alternatives NRC The discussion of alternatives in the report shall include a discussion of whether the alternatives will comply with such applicable environmental quality standards and requirements. 10 CFR 51.45(d), as required by 10 CFR 51.53(c)(2) As TVA is a federal entity, the combination of natural gas, solar, energy storage, and nuclear powered generation small modular reactors alternative discussed in Chapter 7 would be constructed and operated to comply with applicable environmental quality standards and requirements. The decision to construct and operate any of the Chapter 7 alternatives would also be subject to TVA Board approval and applicable environmental reviews. 9.3. References ADEM (Alabama Department of Environmental Management). 2015. Water Quality Program. Administrative Code Chapter 335-6-6. National Pollutant Discharge Elimination System. ADEM. 2018. National Pollutant Discharge Elimination System (NPDES), Permit Number: AL0022080. Permittee: Tennessee Valley Authority, Browns Ferry Nuclear Plant, Issuance Date: June 7, 2018, Effective Date: July 1, 2018, Expiration Date: August 31, 2023. ADEM. 2021. NPDES Permits. Accessed September 20, 2021 at http://adem.alabama.gov/programs/water/permitting.cnt. NRC (U.S. Nuclear Regulatory Commission). 2013. Generic Environmental Impact Statement for License Renewal of Nuclear Plants. NUREG-1437, Volume 1, Revision 1. Office of Nuclear Reactor Regulation. June 2013. TVA (Tennessee Valley Authority). 2018. Categorical Exclusion Checklist for Proposed TVA Actions - Intake Channel Dredging. October. TVA. 2021. Wheeler Reservoir. Accessed September 28, 2021 at https://lakeinfo.tva.gov/web/sites/wheeler.htm. USACE (U.S. Army Corps of Engineers). 2012. The Rivers and Harbors Act of 1899, Section

10. September 20, 2012.

USACE. 2022a. Navigable Waters List within the Nashville District. Accessed November 8, 2022 at https://www.lrn.usace.army.mil/Missions/Regulatory/Navigable-Waters-List/. USACE. 2022b. Tennessee River and Tributaries. Accessed November 8, 2022 at https://www.lrn.usace.army.mil/Missions/Regulatory/Navigable-Waters-List/. USEPA (U.S. Environmental Protection Agency). 2020. Alabama NPDES Permits. Accessed September 20, 2021 at https://www.epa.gov/npdes-permits/alabama-npdes-permits. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E9-7

Appendix E - Applicants Environmental Report-Operating License Renewal Stage USFWS (U.S. Fish and Wildlife Service). 2007. National Bald Eagle Management Guidelines. May. Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0) E9-8

Appendix E - Applicants Environmental Report-Operating License Renewal Stage Attachment 1 National Pollutant Discharge Elimination System (NPDES) Permit Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)

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Appendix E - Applicants Environmental Report-Operating License Renewal Stage Attachment 2 TVA Bat Strategy Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)
Project Review Form - TVA Bat Strategy (06/2019) This form should only be completed if project includes activities in Tables 2 or 3 (STEP 2 below). This form is not required if project activities are limited to Table 1 (STEP 2) or otherwise determined to have no effect on federally listed bats. If so, include the following statement in your environmental compliance document (e.g., add as a comment in the project CEC): Project activities limited to Bat Strategy Table 1 or otherwise determined to have no effect on federally listed bats. Bat Strategy Project Review Form NOT required. This form is to assist in determining required conservation measures per TVA's ESA Section 7 programmatic consultation for routine actions and federally listed bats.1 Project Name: Browns Ferry Nuclear Subsequent License Renewal SEIS Date: 1/12/22 Contact(s): Taylor Johnson CEC#: Project ID: 38126 Project Location (City, County, State): Limestone County, Alabama Project
Description:
TVA plans to submit a SLR application to the NRC requesting an additional 20 years of operation of all three BFN units until 2053, 2054, and 2056. No transmission system upgrades are expected to be needed in support the SLR. To date no major modifications or component replacements have been identified for the BFN SLR Project as being required for BFN to operate until 2053. SECTION 1: PROJECT INFORMATION - ACTION AND ACTIVITIES STEP 1) Select TVA Action. If none are applicable, contact environmental support staff, Environmental Project Lead, or Terrestrial Zoologist to discuss whether form (i.e., application of Bat Programmatic Consultation) is appropriate for project: 1 Manage Biological Resources for Biodiversity and Public Use on TVA Reservoir 6 Maintain Existing Electric Transmission Assets Lands 7 Convey Property associated with Electric 2 Protect Cultural Resources on TVA-Retained Land Transmission 8 Expand or Construct New Electric Transmission 3 Manage Land Use and Disposal of TVA-Retained Land Assets 4 Manage Permitting under Section 26a of the TVA Act 9 Promote Economic Development 5 Operate, Maintain, Retire, Expand, Construct Power Plants 10 Promote Mid-Scale Solar Generation STEP 2) Select all activities from Tables 1, 2, and 3 below that are included in the proposed project. TABLE 1. Activities with no effect to bats. Conservation measures & completion of bat strategy project review form NOT required.
19. Site-specific enhancements in streams

1. Loans and/or grant awards 8. Sale of TVA property and reservoirs for aquatic animals

2. Purchase of property 9. Lease of TVA property 20. Nesting platforms

41. Minor water-based structures (this does

3. Purchase of equipment for industrial 10. Deed modification associated with TVA not include boat docks, boat slips or facilities rights or TVA property piers)

42. Internal renovation or internal expansion

4. Environmental education 11. Abandonment of TVA retained rights of an existing facility

5. Transfer of ROW easement and/or ROW

12. Sufferance agreement 43. Replacement or removal of TL poles equipment

13. Engineering or environmental planning 44. Conductor and overhead ground wire

6. Property and/or equipment transfer or studies installation and replacement

7. Easement on TVA property 14. Harbor limits delineation 49. Non-navigable houseboats
Project Review Form - TVA Bat Strategy (06/2019) TABLE 2. Activities not likely to adversely affect bats with implementation of conservation measures. Conservation measures and completion of bat strategy project review form REQUIRED; review of bat records in proximity to project NOT required.
18. Erosion control, minor 57. Water intake - non-industrial 79. Swimming pools/associated equipment

24. Tree planting 58. Wastewater outfalls 81. Water intakes - industrial

30. Dredging and excavation; recessed 84. On-site/off-site public utility relocation or

59. Marine fueling facilities harbor areas construction or extension

60. Commercial water-use facilities (e.g.,

39. Berm development 85. Playground equipment - land-based marinas)

40. Closed loop heat exchangers (heat

61. Septic fields 87. Aboveground storage tanks pumps)

45. Stream monitoring equipment - 66. Private, residential docks, piers,

88. Underground storage tanks placement and use boathouses

46. Floating boat slips within approved

67. Siting of temporary office trailers 90. Pond closure harbor limits

68. Financing for speculative building

48. Laydown areas 93. Standard License construction

50. Minor land based structures 72. Ferry landings/service operations 94. Special Use License

51. Signage installation 74. Recreational vehicle campsites 95. Recreation License

53. Mooring buoys or posts 75. Utility lines/light poles 96. Land Use Permit

56. Culverts 76. Concrete sidewalks Table 3: Activities that may adversely affect federally listed bats. Conservation measures AND completion of bat strategy project review form REQUIRED; review of bat records in proximity of project REQUIRED by OSAR/Heritage eMap reviewer or Terrestrial Zoologist.

34. Mechanical vegetation removal,

15. Windshield and ground surveys for archaeological 69. Renovation of existing includes trees or tree branches > 3 resources structures inches in diameter

16. Drilling 35. Stabilization (major erosion control) 70. Lock maintenance/ construction

17. Mechanical vegetation removal, does not include trees or branches > 3 in diameter (in Table 3 due 36. Grading 71. Concrete dam modification to potential for woody burn piles)

21. Herbicide use 37. Installation of soil improvements 73. Boat launching ramps

77. Construction or expansion of

22. Grubbing 38. Drain installations for ponds land-based buildings

23. Prescribed burns 47. Conduit installation 78. Wastewater treatment plants

25. Maintenance, improvement or construction of

52. Floating buildings 80. Barge fleeting areas pedestrian or vehicular access corridors

26. Maintenance/construction of access control 54. Maintenance of water control structures 82. Construction of dam/weirs/
measures (dewatering units, spillways, levees) levees
83. Submarine pipeline, directional

27. Restoration of sites following human use and abuse 55. Solar panels boring operations

28. Removal of debris (e.g., dump sites, hazardous

62. Blasting 86. Landfill construction material, unauthorized structures)

63. Foundation installation for transmission

29. Acquisition and use of fill/borrow material 89. Structure demolition support

64. Installation of steel structure, overhead

31. Stream/wetland crossings 91. Bridge replacement bus, equipment, etc.

65. Pole and/or tower installation and/or 92. Return of archaeological

32. Clean-up following storm damage extension remains to former burial sites

33. Removal of hazardous trees/tree branches STEP 3) Project includes one or more activities in Table 3? YES (Go to Step 4) NO (Go to Step 13)
Project Review Form - TVA Bat Strategy (06/2019) SECTION 3: REQUIRED CONSERVATION MEASURES STEP 13) Review Conservation Measures in Table 4 and ensure those selected are relevant to the project. If not, manually override and uncheck irrelevant measures, and explain why in ADDITIONAL NOTES below Table 4. Did review of Table 4 result in ANY remaining Conservation Measures in RED? NO (Go to Step 14) YES (STOP HERE; Submit for Terrestrial Zoology Review. Click File/Save As, name form as "ProjectLead_BatForm_CEC-or-ProjectIDNo_Date", and submit with project information).
Project Review Form - TVA Bat Strategy (06/2019) Table 4. TVA's ESA Section 7 Programmatic Bat Consultation Required Conservation Measures The Conservation Measures in Table 4 are automatically selected based on your choices in Tables 2 and 3 but can Manual Override be manually overridden, if necessary. To Manually override, press the button and enter your name. Name: Elizabeth Hamrick Check if Activities Subject To Applies to Conservation Conservation Measure Description Project Measure NV1 - Noise will be short-term, transient, and not significantly different from urban interface or natural events (i.e., thunderstorms) that bats are frequently exposed to when present on the landscape.
Project Review Form - TVA Bat Strategy (06/2019) SSPC3 (Power Plants only) - Power Plant actions and activities will continue to implement standard environmental practices. These include: o Best Management Practices (BMPs) in accordance with regulations:
Ensure proper disposal of waste, ex: used rags, used oil, empty containers, general trash, dependent on plant policy

Maintain every site with well-equipped spill response kits, included in some heavy equipment

Conduct Quarterly Internal Environmental Field Assessments at each sight

Every project must have an approved work package that contains an environmental checklist that is approved by sight Environmental Health & Safety consultant.

When refueling, vehicle is positioned as close to pump as possible to prevent drips, and overfilling of tank. Hose and nozzle are held in a vertical position to prevent spillage o Construction Site Protection Methods

Sediment basin for runoff - used to trap sediments and temporarily detain runoff on larger construction sites

Storm drain protection device

Check dam to help slow down silt flow

Silt fencing to reduce sediment movement o Storm Water Pollution Prevention (SWPP) Pollution Control Strategies

Minimize storm water contact with disturbed soils at construction site

Protect disturbed soil areas from erosion

Minimize sediment in storm water before discharge

Prevent storm water contact with other pollutants

Construction sites also may be required to have a storm water permit, depending on size of land disturbance (>1ac) o Every site has a Spill Prevention and Control Countermeasures (SPCC) Plan and requires training. Several hundred pieces of equipment often managed at the same time on power generation properties. Goal is to

Minimize fuel and chemical use Ensure proper disposal of waste, ex: used rags, used oil, empty containers, general trash, dependent on plant policy

Maintain every site with well-equipped spill response kits, included in some heavy equipment

Conduct Quarterly Internal Environmental Field Assessments at each sight

Every project must have an approved work package that contains an environmental checklist that is approved by sight Environmental Health & Safety consultant.

When refueling, vehicle is positioned as close to pump as possible to prevent drips, and overfilling of tank. Hose and nozzle are held in a vertical position to prevent spillage o Construction Site Protection Methods

Sediment basin for runoff - used to trap sediments and temporarily detain runoff on larger construction sites

Storm drain protection device

Check dam to help slow down silt flow

Silt fencing to reduce sediment movement o Storm Water Pollution Prevention (SWPP) Pollution Control Strategies

Minimize storm water contact with disturbed soils at construction site

Protect disturbed soil areas from erosion

Minimize sediment in storm water before discharge

Prevent storm water contact with other pollutants

Construction sites also may be required to have a storm water permit, depending on size of land disturbance (>1ac) o Every site has a Spill Prevention and Control Countermeasures (SPCC) Plan and requires training. Several hundred pieces of equipment often managed at the same time on power generation properties. Goal is to minimize fuel and chemical use 1Bats addressed in consultation (02/2018), which includes gray bat (listed in 1976), Indiana bat (listed in 1967), northern long-eared bat (listed in 2015), and Virginia big-eared bat (listed in 1979).
Hide All Unchecked Conservation Measures HIDE UNHIDE Hide Table 4 Columns 1 and 2 to Facilitate Clean Copy and Paste HIDE
Project Review Form - TVA Bat Strategy (06/2019) UNHIDE NOTES (additional info from field review, explanation of no impact or removal of conservation measures). Only actions are license renewal.
Project Review Form - TVA Bat Strategy (06/2019) STEP 14) Save completed form (Click File/Save As, name form as "ProjectLead_BatForm_CEC-or-ProjectIDNo_Date") in project environmental documentation (e.g. CEC, Appendix to EA) AND send a copy of form to batstrategy@tva.gov Submission of this form indicates that Project Lead/Applicant: (name) is (or will be made) aware of the requirements below.
Implementation of conservation measures identified in Table 4 is required to comply with TVA's Endangered Species Act programmatic bat consultation.

TVA may conduct post-project monitoring to determine if conservation measures were effective in minimizing or avoiding impacts to federally listed bats.
For Use by Terrestrial Zoologist Only Terrestrial Zoologist acknowledges that Project Lead/Contact (name) Taylor Johnson has been informed of any relevant conservation measures and/or provided a copy of this form. For projects that require use of Take and/or contribution to TVA's Bat Conservation Fund, Terrestrial Zoologist acknowledges that Project Lead/Contact has been informed that project will result in use of Incidental Take ac trees and that use of Take will require $ contribution to TVA's Conservation Fund upon completion of activity (amount entered should be $0 if cleared in winter). For Terrestrial Zoology Use Only. Finalize and Print to Noneditable PDF.
Appendix E - Applicants Environmental Report-Operating License Renewal Stage Attachment 3 Agency Correspondence Browns Ferry Nuclear Plant Subsequent License Renewal Application (Rev. 0)
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April 19, 2001 Ms. Stacye Hathorn Alabama Historical Commission 468 South Perry Street Montgomery, Alabama 36130-0900 Tennessee Valley Authority (TVA) Proposed Expansion of Browns Ferry Nuclear Plant, Limestone County, Alabama
Dear Ms. Hathorn:
TVA proposes to use three areas as soil disposal sites for activities related to the expansion of Browns Ferry Nuclear Plant. A Phase I archaeological survey was conducted of the three proposed sites on April 2-6, 2001. The results of the investigation are found in the enclosed report A Cultural Resources Reconnaissance Survey of Three Locations for the Proposed Expansion of Browns Ferry Nuclear Plant in Limestone County, Alabama. TVA Cultural Resources Staff has reviewed the report and concur with the following findings and recommendations of the author: x archaeological site 1LI535 located in Area 1 is potentially eligible for inclusion in the National Register of Historic Places and should be avoided; x if avoidance of 1LI535 is not possible, then further testing will be required; x the Cox Cemetery located in Area 2 should be avoided or relocated; and x there are no historic properties located in Area 3. Therefore, pursuant to Section 106 of the National Historic Preservation Act and its implementing regulations at 36 CFR § 800, we are seeking your concurrence with our findings and recommendations for the proposed project areas. Should you have any questions or comments, please contact me at 865/632-1583. Sincerely, J. Bennett Graham Senior Archaeologist Enclosure cc: Dennis Baxter ABL, 1A-N CR Files
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A PHASE I ARCHAEOLOGICAL SURVEY FOR THE TRINITY-BROWNS FERRY NUCLEAR PLANT 161-KV TRANSMISSION LINE PROJECT, LIMESTONE AND MORGAN COUNTIES, ALABAMA
A PHASE I ARCHAEOLOGICAL SURVEY FOR THE TRINITY-BROWNS FERRY NUCLEAR PLANT 161-KV TRANSMISSION LINE PROJECT, LIMESTONE AND MORGAN COUNTIES, ALABAMA by Ann Marshall Prepared for: Tennessee Valley Authority TVA Cultural Resources 400 West Summit Hill Drive Knoxville, Tennessee 37902 Prepared by: Tennessee Valley Archaeological Research 2211 Seminole Drive, Suite 302 Huntsville, Alabama 35805 Hunter Johnson Principal Investigator June 2013

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From: :RIIRUG/HH$QQH To: &ROH6WHYH&0F%ULGH$PDQGD Cc: -RQHV&OLQWRQ(+HDUQHV+DOOLH$QQH
Subject:
5(79$%URZQV)HUU\1XFOHDU3ODQW3URSRVHGFRROLQJWRZHUGHPRVHFWLRQ Date: )ULGD\0DUFK$0 Attachments: LPDJHMSJ LPDJHSQJ LPDJHSQJ LPDJHSQJ LPDJHSQJ LPDJHSQJ LPDJHSQJ LPDJHSQJ LPDJHSQJ This is an EXTERNAL EMAIL from outside TVA. THINK BEFORE you CLICK links or OPEN attachments. If suspicious, please attach to a new email and forward to cybersecurity@tva.gov. Thank you for this additional information. It seems to me that the 1974 cooling towers would not be National Register eligible due to age, the fact they were not part of the original design, and since they have lost their historic context. Unless Im missing something, I think we can continue to concur with this project. Lee Anne Wofford Deputy State Historic Preservation Officer Alabama Historical Commission 468 South Perry Street Montgomery, AL 36130-0900 (US Post) 36104 (Courier) Phone: 334.230.2659 LeeAnne.Wofford@ahc.alabama.gov http://ahc.alabama.gov/ signature block From: Cole, Steve C <sccole0@tva.gov> Sent: Wednesday, March 04, 2020 2:35 PM To: McBride, Amanda <Amanda.McBride@ahc.alabama.gov>; Wofford, Lee Anne <LeeAnne.Wofford@ahc.alabama.gov> Cc: Jones, Clinton E <cjones5@tva.gov>; Hearnes, Hallie Anne <hahearnes@tva.gov>
Subject:
RE: TVA-Browns Ferry Nuclear Plant - Proposed cooling tower demo - section 106
Amanda,
I dont have any clear documentation of what the reasoning was, unfortunately. I did find a copy of our 2001 letter to your office after my last email, in an obscure folder; its just a draft (lacks letterhead and Bennetts signature), but the content is probably the same as what we mailed. Ive also looked at the 2001 final supplemental EIS for the operating license renewal and the 2010 final EA for the cooling tower replacements, and unfortunately those dont provide any insights. It looks to me like the operating license renewal just didnt involve any actions that would have had a visual effect. Although Bennett probably also believed the plant wasnt eligible because of its age. As for the proposed extended power uprate in 2010, although it included replacing four of the six extant cooling towers, our correspondence only discusses an archaeological APE. I dont know the reason visual effects werent considered; I assume it was also based on the assumption about the age threshold. The EA itself doesnt provide any insights. Richard Yarnell handled that consultation and he retired in 2016 and has moved out of state. Ive attached the lost 2001 letter, an excerpt from the 2001 SEIS, and the 2010 EA. I can provide the whole SEIS if youre interested, but I skimmed it and didnt see anything that answered the question. Hallie and I both think there are reasons that BFN could have historic significance, but we dont know whether it retains integrity, or whether the cooling towers should be considered contributing. I asked the project staff whether these two towers were part of the plants original design; they said no. Plant construction began in 1966, but the cooling towers were added to the design later and were built in 1974. This is pretty much all I know at this point. Does any of this help? Would you still be available to discuss on the phone?
Thanks, Steve From: McBride, Amanda <Amanda.McBride@ahc.alabama.gov>
Sent: Tuesday, March 03, 2020 4:02 PM To: Cole, Steve C <sccole0@tva.gov>; Wofford, Lee Anne <LeeAnne.Wofford@ahc.alabama.gov> Cc: Jones, Clinton E <cjones5@tva.gov>
Subject:
RE: TVA-Browns Ferry Nuclear Plant - Proposed cooling tower demo - section 106 This is an EXTERNAL EMAIL from outside TVA. THINK BEFORE you CLICK links or OPEN attachments. If suspicious, please attach to a new email and forward to cybersecurity@tva.gov.
Steve, Ive discussed this issue with Lee Anne and we have some questions. I know you indicated that you no longer have the letter that was sent to us in 2001, (we dont have it, either) but is
the EIS still available? We need to know why the towers were determined to be not eligible for the NR. Was it because of their ages or did they lack integrity, etc.? If age was the only reason we would want to re-review them since so much time has passed. I assume this was laid out in the missing letter but perhaps it was also in the EIS. Thanks! Amanda Amanda McBride Environmental Review Coordinator Historic Preservation Division Alabama Historical Commission 468 South Perry Street Montgomery, Alabama 36130-0900 (US Post) 36104 (Courier) 334.230.2692 Amanda.McBride@ahc.alabama.gov http://ahc.alabama.gov/ signature block From: Cole, Steve C <sccole0@tva.gov> Sent: Monday, March 02, 2020 12:18 PM To: McBride, Amanda <Amanda.McBride@ahc.alabama.gov> Cc: Jones, Clinton E <cjones5@tva.gov>
Subject:
FW: TVA-Browns Ferry Nuclear Plant - Proposed cooling tower demo - section 106
Amanda, Here are copies of our previous consultation correspondence about Browns Ferry; these give background on what we would like to discuss with you. The 2001 letter was for plant relicensing and plant expansion, and focuses on an archaeological site. Unfortunately, we cannot locate a copy of TVAs letter to your office for that project. The 2010 letters were regarding the replacement of four cooling towers, which was to involve the demolition of four towers built in the 1970s. Those letters show that our offices agreed the project would have no adverse effect. Subsequently, TVA
replaced two of the towers, but delayed work on the other two, until now. We are really just wanting to confirm that your 2010 concurrence still stands so we can close the loop. Would you be available for a half-hour call this afternoon at 4:00? Or if another time works better, please let me know.
Thanks, Steve Steve Cole
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5(675,&7('RU79$&21),'(17,$/$Q\PLVXVHRUXQDXWKRUL]HGGLVFORVXUHFDQUHVXOWLQERWKFLYLO DQGFULPLQDOSHQDOWLHV,I\RXDUHQRWWKHLQWHQGHGUHFLSLHQWEHDZDUHWKDWDQ\GLVFORVXUHFRS\LQJ GLVWULEXWLRQRUXVHRIWKHFRQWHQWRIWKLVLQIRUPDWLRQLVSURKLELWHG,I\RXKDYHUHFHLYHGWKLVFRPPXQLFDWLRQ LQHUURUSOHDVHQRWLI\PHLPPHGLDWHO\E\HPDLODQGGHOHWHWKHRULJLQDOPHVVDJH From: Cole, Steve C Sent: Friday, February 28, 2020 5:01 PM To: McBride, Amanda <Amanda.McBride@ahc.alabama.gov> Cc: Jones, Clinton E <cjones5@tva.gov>
Subject:
TVA-Browns Ferry Nuclear Plant - Proposed cooling tower demo - section 106
Dear Amanda,
We have a question about the level of review needed for a proposed project at Browns Ferry Nuclear Plant. Some of our past consultation seems to indicate our offices have agreed the plant is not eligible, and that TVAs finding of no effect for demolishing cooling towers was appropriate. However, there is some ambiguity in that and we would like to have your guidance. Would you be available for a brief call with me and Clint Jones Monday afternoon or Tuesday morning? If so,
please let me know what time would work for you.
Regards, Steve Steve Cole
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Figure 1. Project location (USA Topo edition of the USGS Hillsborough and Jones Crossroads 7.5-minute topographic quadrangles. Figure 2. Project footprint and surrounding landmarks. Figure 3. Recent low oblique aerial photo, view to north, showing the IPS, surrounding structures, the eastern extent of the Forebay Dike, and part of Gate Structure 3. IPS is in upper middle of photo.
Figure 4. Excerpt of image shown in Figure 3. The light green, peach, and blue structures are the traveling water screens. The nine white structures behind them are the CCW pumps. The trash racks are below the surface of the water.
Figure 5. Photograph of IPS, looking North, during BFN construction. The gridded structures on the concrete face of the IPS are the trash racks.
Figure 6. Laser scan image of IPS looking east. Figure 7. Traveling water screens on the IPS, viewed from the landward side, looking west.
Figure 8. View of traveling water screens on the IPS, looking west. These are the original structures, which were later replaced with those shown above in Figure 7.
Figure 9. Schematics of proposed monorail rake system provided by a potential vendor. Bottom view ("supplied equipment") shows monorail system; top view ("isometric view") shows how system would be mounted on the IPS.
Figure 10. Conceptual design for monorail trash rake. Figure 11. Sketch of proposed monorail design. In this view, the traveling water screens would be left of the monorail, and the Intake Forebay would be to the right. Figure 12. Sketch of the portion of the monorail that would lead to the discharge location, and the discharge dumping container.
Figure 13. Photo of area proposed for dumping containers to be used in eelgrass collection (view southwest). Traveling water screens on the IPS are visible in center-right. Figure 14. Photo looking west from proposed dumping container location. CCW pumps are white structures at extreme left of photo, in middle distance. Reactor building is in background.
Figure 15. Photo looking north/northwest from proposed dumping container location. Figure 16. Recent oblique aerial view toward IPS. Gate Structure 3, in foreground, largely blocks views to the IPS from Wheeler Reservoir.
Figure 17. Oblique aerial photo taken July 2020, looking northeast, showing IPS, the Intake Dike, Intake Forebay, and IPS.
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400 West Summit Hill Drive, Knoxville, Tennessee 37902 July 19, 2021 Mr. Paul Barton Mr. David Franks Tribal Historic Preservation Officer Tribal Historic Preservation Officer Eastern Shawnee Tribe of Oklahoma The Seminole Nation of Oklahoma 127 West Oneida 12555 NS 3540 Road Seneca, Missouri 64865 Seminole, Oklahoma 74868 Ms. Karen Brunso Ms. Devon Frazier Tribal Historic Preservation Officer Tribal Historic Preservation Officer Division of Historic Preservation Absentee Shawnee Tribe of Indians of Department of Culture & Humanities Oklahoma The Chickasaw Nation 2025 S. Gordon Cooper Drive Post Office Box 1548 Shawnee, Oklahoma 74801 Ada, Oklahoma 74821-1548 Mr. Larry Haikey Ms. RaeLynn Butler Tribal Historic Preservation Officer Manager Poarch Band of Creek Indians Historic & Cultural Preservation Regulatory Affairs Division Department 5811 Jack Springs Road The Muscogee Nation Atmore, Alabama 36502 Post Office Box 580 Okmulgee, Oklahoma 74447 Dr. Linda Langley Tribal Historic Preservation Officer Mr. Bryant Celestine Coushatta Tribe of Louisiana Tribal Historic Preservation Officer Post Office Box 10 Alabama-Coushatta Tribe of Texas Elton, Louisiana 70532 571 State Park Road 56 Livingston, Texas 77351 Ms. Alina J. Shively Tribal Historic Preservation Officer Mr. Galen Cloud Jena Band of Choctaw Indians Tribal Historic Preservation Officer Post Office Box 14 Thlopthlocco Tribal Town Jena, Louisiana 71342 Post Office Box 188 Okemah, Oklahoma 74859 Ms. Tonya Tipton Tribal Historic Preservation Officer Mr. David Cook Shawnee Tribe Tribal Administrator Post Office Box 189 Kialegee Tribal Town Miami, Oklahoma 74355 Post Office Box 332 Wetumka, Oklahoma 74883
Ms. Elizabeth Toombs Mr. Ben Yahola Tribal Historic Preservation Officer Tribal Historic Preservation Officer Cherokee Nation Alabama-Quassarte Tribal Town Post Office Box 948 Post Office Box 187 Tahlequah, Oklahoma 74465 101 East Broadway Wetumka, Oklahoma 74883 Ms. Whitney Warrior Director of Historic Preservation Mr. Stephen Yerka United Keetoowah Band of Cherokee Historic Presrvation Specialist Indians in Oklahoma Tribal Historic Preservation Office 18263 W. Keetoowah Circle Eastern Band of Cherokee Indians Tahlequah, Oklahoma 74464 Post Office Box 455 Cherokee, North Carolina 28719
Dear Sir/Madam:
TENNESSEE VALLEY AUTHORITY (TVA), BROWNS FERRY NUCLEAR PLANT (BFN), SUBSEQUENT LICENSE RENEWAL (TVA TRACKING NUMBER - CID 80680) (34.70414, -87.11800) TVA operates the BFN Units 1, 2, and 3 in Limestone County, Alabama, consistent with Nuclear Regulatory Commission (NRC) regulations. BFN is located on an 840-acre tract on the right-descending bank of Wheeler Reservoir at Tennessee River Mile 294, approximately 10 miles from both Decatur, Alabama, and Athens, Alabama. BFN consists of three General Electric boiling water reactors (BWRs) and associated turbine generators that collectively supply approximately 3,900 megawatts of electric power to the TVA transmission and distribution system. The BFN Units 1, 2, and 3 NRC-issued licenses currently expire in 2033, 2034, and 2036 respectively. In order for the three BFN units to continue to operate, these Nuclear Regulatory Commission (NRC) licenses must be renewed for another 20 years (termed subsequent license renewal, or SLR). TVA plans to submit a SLR application to the NRC by November 2023 requesting an additional 20 years of operation of all three BFN units. With the receipt of SLR from NRC, TVA proposes to maintain and operate BFN Units 1, 2, and 3 until 2053, 2054, and 2056 respectively. The BFN SLR may require maintenance actions or refurbishment to BFN to maintain consistency with the current licensing basis, as well as NRC and TVA requirements. To date no major modifications or component replacements have been identified as being required for the BFN SLR Project. Based on the Electric Power Research Institute (EPRI) Report 1021115 (EPRI Life-Limiting Issues for Long-Term Operation of Nuclear Power Plants), plant improvements including intake structures, buried piping, and large external tanks would be expected upgrades for continued operation for an additional 60 to 80 years beyond the SLR date. No transmission system upgrades are expected to be needed in support of the SLR. TVA has determined that the proposed BFN SLR is an undertaking (as defined at 36 CFR § 800.16(y)) with potential to cause effects on historic properties. We are initiating consultation under Section 106 of the National Historic Preservation Act to meet TVAs responsibility to consider the undertakings effects on historic properties.
Sir/Madam Page 2 July 19, 2021 As part of the Section 106 process for the BFN SLR project TVA plans to inventory historic properties on the BFN reservation. TVA has not completed a formal historic architectural/engineering assessment of BFN. In addition, only some areas within the reservation have been surveyed for archaeological sites. Table 1 lists the prior surveys. These have included approximately 255 acres of land in the 840-acre reservation. Figure 1 shows the previous surveys, developed areas, and the planned archaeological survey area. Table 1. Prior archaeological surveys in the BFN reservation Project Year Area Consultant (acres) Three Locations for the Proposed 2001 200.0 University of Alabama, Office of Expansion of BFN Archaeological Research Archaeological Site Identification 2009 (shoreline) University of Tennessee, Knoxville, and Erosion Monitoring for the TVA Archaeological Research Laboratory Reservoir Operation Compliance Trinity-Browns Ferry Nuclear Plant 2013 ~15.0 Tennessee Valley Archaeological 161-kV Transmission Line Project Research Browns Ferry-Athens 161-kV TL 2013 10.0 Tennessee Valley Archaeological Rebuild Research Meteorological Tower Tree Clearing 2020 29.6 Tennessee Valley Archaeological Research TVA proposes to complete a historic architectural assessment of BFN. When the plant opened in 1974, its three boiling-water reactors were the first in the world capable of producing more than 1,000 megawatts (1 billion watts of power). Unit 1 began commercial operation Dec. 20, 1973, and the NRC renewed the original 40-year license for another 20 years until 2033. Unit 2 began commercial operation June 28, 1974, with a renewed license until 2034. Unit 3 began commercial operation July 2, 1976, with a renewed license until 2036. Although BFN has been operating for less than 50 years, TVA feels that an architectural assessment is needed for two reasons. First, even if TVA determines, in consultation with your office, that BFN is ineligible to the National Register of Historic Places (NHRP) due to not meeting the minimum age threshold, the historic architectural assessment would provide an assessment of historic significance and integrity that would support an NRHP eligibility evaluation in 2024. Secondly, BFN could potentially be eligible under Criteria Consideration G, provided it possesses sufficient historic significance and retains sufficient integrity. The architectural assessment will be include BFN and all associated structures for which access can be obtained. During the field visit, the surveyors will collect information relevant to the potential NRHP eligibility of BFN and will document the facility with photographs. TVA will include in the archaeological survey all areas within the reservation that were not included in any previous archaeological survey, and show no clear evidence of prior
Sir/Madam Page 3 July 19, 2021 disturbance or development (buildings, parking lots, ponds, filled trenches, etc.). TVA estimates the total survey area at approximately 260 acres. The survey will include a pedestrian walkover of the entire survey area and systematic shovel testing in all areas with less than 50 percent ground surface visibility. Shovel testing will be conducted with a maximum shovel test interval of 30 meters. TVA will provide a report of the survey to your office for review. The report will include recommendations concerning the NRHP eligibility of any identified archaeological sites and cemeteries. TVA will take the current NRHP status of previously recorded sites into consideration when formulating the survey strategy. Any sites previously determined to be eligible will be avoided; sites with a current status of potentially eligible or undetermined will be investigated with shovel testing (if conditions indicate it would be appropriate) in order to assess their current condition and horizontal and vertical limits, and to provide data concerning their potential research value. Pursuant to 36 C.F.R. Part 800.3(f)(2), TVA is consulting with the following federally recognized Indian tribes regarding historic properties within the proposed projects APE that may be of religious and cultural significance and are eligible for the NRHP: Absentee Shawnee Tribe of Indians of Oklahoma, Alabama-Coushatta Tribe of Texas, Alabama-Quassarte Tribal Town, Cherokee Nation, The Chickasaw Nation, Coushatta Tribe of Louisiana, Eastern Band of Cherokee Indians, Eastern Shawnee Tribe of Oklahoma, Jena Band of Choctaw Indians, Kialegee Tribal Town, The Muscogee Nation, Poarch Band of Creek Indians, The Seminole Nation of Oklahoma, Shawnee Tribe, Thlopthlocco Tribal Town, and United Keetoowah Band of Cherokee Indians in Oklahoma. By this letter TVA is initiating consultation under Section 106 of the NHPA regarding the proposed BFN SLR project and is seeking your comments regarding any properties that may be of religious and cultural significance and may be eligible for listing in the NRHP pursuant to 36CFR § 800.2 (c)(2)(ii), 800.3 (f)(2), and 800.4 (a)(4)(b). Please contact Marianne Shuler by phone, 865-253-1265 or by email, mmshuler@tva.gov with any comments or questions. Sincerely, Official signature on file Marianne Shuler Senior Specialist, Archaeologist, and Tribal Liaison Cultural Compliance
Sir/Madam Page 4 July 19, 2021 MMS:ABM Enclosures cc (Enclosures): Ms. Sheila Bird Cultural Preservation Consultant Shawnee Tribe Post Office Box 189 Miami, Oklahoma 74355 Ms. Erica Gorsuch Assistant THPO/Section 106 Coordinator United Keetoowah Band of Cherokee Indians in Oklahoma Post Office Box 746 Tahlequah, Oklahoma 74465 Ms. Corain Lowe-Zepeda Tribal Historic Preservation Officer Historic & Cultural Preservation Department The Muscogee Nation Post Office Box 580 Okmulgee, Oklahoma 74447 Mr. Russell Townsend Tribal Historic Preservation Officer Eastern Band of Cherokee Indians Post Office Box 455 Cherokee, North Carolina 28719
Exempted from Disclosure by Statute Figure 1. Archaeological survey area, with developed areas (estimated), previous archaeological surveys, and previously-recorded sites. Prepared by Tennessee Valley Archaeological Research.
400 West Summit Hill Drive, Knoxville, Tennessee 37902 March 21, 2022 Ms. Lee Anne Wofford Deputy State Historic Preservation Officer Alabama Historical Commission 468 South Perry Street Montgomery, Alabama 36130-0900
Dear Ms. Wofford:
TENNESSEE VALLEY AUTHORITY (TVA), BROWNS FERRY NUCLEAR PLANT (BFN), SUBSEQUENT LICENSE RENEWAL - ARCHAEOLOGICAL SURVEY (TVA TRACKING NUMBER - CID 80680) (34.70414, -87.11800) (AHC 2021-0929) We initiated consultation with your office last year (letter dated July 19, 2021) regarding TVAs Subsequent License Renewal for BFN. Tennessee Valley Archaeological Research (TVAR) completed the Phase I Archaeological survey of all areas within the plant reservation that had not been included in previous archaeological surveys and show no clear evidence of prior disturbance or development in support of the project. The survey included approximately 193 acres distributed across six separate areas. Survey consisted of pedestrian walk-over of the entire survey area and systematic shovel testing in all areas with less than 50 percent ground surface visibility. Field observations during the survey resulted in exclusion of several small areas from the survey based on either visible signs of disturbance, or new information from plant personnel indicating past disturbance such as excavation, soil borrow, and waste disposal. This resulted in the actual surveyed area being somewhat smaller than we stated in our initial consultation, in which we estimated the survey area as approximately 260 acres. Figure 1 shows the current survey area, areas included in previous surveys, and all known archaeological sites at BFN. High- and low-resolution copies of the draft report can be downloaded . The survey revisited six previously recorded archaeological sites (1LI24, 1LI284, 1LI286, 1LI287, 1LI856, and 1LI857) located within or adjacent to the survey area, and identified seven previously unrecorded archaeological sites (1LI915, 1LI916, 1LI917, 1LI918, 1LI919, 1LI920, and 1LI921). TVAR recommends that site 1LI24 is no longer extant, having been destroyed during construction of BFN. They recommend that site 1LI857 is ineligible. Based on the shovel testing results, TVAR proposed combining sites 1LI287 and 1LI856 into a single site (1LI287) and combining sites 1LI284 and 1LI286 into a single site (1LI284). The updated State Archaeological Site forms reflect these changes.
Ms. Lee Anne Wofford Page 2 March 21, 2022 TVAR recommends that sites 1LI284 and 1LI287 both have research potential and should be avoided by project activities, and if avoidance is not possible, that additional investigations should be carried out at both sites to better ascertain their potential eligibility for the National Register of Historic Places (NRHP). Finally, TVAR recommends that all seven newly recorded sites lack research potential and should be considered ineligible for the NRHP. TVA has read the report and agrees with the findings and recommendations. Based on the survey results, site 1LI24 is no longer extant; sites 1LI915, 1LI916, 1LI917, 1LI918, 1LI919, 1LI920, and 1LI921 are ineligible for inclusion in the NRHP; and sites 1LI284 and 1LI287 should be considered to have undetermined eligibility for the NRHP. As mentioned in our previous letter on this project, TVA previously completed five archaeological surveys at BFN. The current survey was designed to include all remaining areas not included in those prior surveys and not obviously affected by plant construction/development. As a result, all areas within the BFN reservation that could have potential for archaeological sites have now been investigated. A total of three additional sites (1LI23, 1LI535, and 1LI812) have been identified at BFN in areas outside the current survey. Site LI23 Exempted from Disclosure by Statute and is presumed to have been destroyed during construction. Site 1LI535 was recommended potentially eligible (Gage 2001) and site 1LI812 was recommended ineligible (Marshall 2013). Our offices have reached agreement on these recommendations in previous consultation. Thus, based on the previous and current investigations, TVA finds there are three sites of undetermined eligibility (or that are considered potentially eligible) within the BFN reservation: 1LI535, 1LI284, and 1LI287. The BFN Subsequent License Renewal project does not include any plans for ground disturbance anywhere on the BFN reservation. The project would not result in any effects on any of the investigated archaeological sites. The information provided by the survey will serve to support TVAs Environmental Report and Environmental Impact Statement for this project. In addition, we plan to utilize the results of the survey in all future project planning at BFN. Should TVA propose any project in future that would include any ground-disturbing activities that could affect sites 1LI535, 1LI284, or 1LI287, TVA would consult further with your office concerning the possible effects and plans for additional investigations to determine eligibility. We have also completed an historic architectural assessment of BFN and will be providing the report to your office under separate cover. Pursuant to 36 CFR Part 800.3(f)(2), TVA is consulting with federally recognized Indian tribes regarding historic properties within the proposed projects APE that may be of religious and cultural significance and are eligible for the NRHP. Pursuant to 36 CFR Part 800.4(d)(1) we are notifying you of TVAs finding of no historic properties affected, providing the documentation specified in § 800.11(d); and inviting you
Ms. Lee Anne Wofford Page 3 March 21, 2022 to review the finding. Also, we are seeking your agreement with TVAs eligibility determinations, finding that the undertaking as currently planned will have no effects on historic properties, and proposal to use the results of current and past archaeological surveys at BFN in future planning efforts. Please contact Steve Cole at sccole0@tva.gov with any comments or questions. Sincerely, Official signature on file James W. Osborne, Jr. Manager Cultural Compliance SCC:ERB Enclosures
References Cited Gage, Matthew 2001 A Cultural Resources Reconnaissance Survey of three Locations for the Proposed Expansion of Browns Ferry Nuclear Power Plant in Limestone County, Alabama. Prepared by The University of Alabama Museums, Office of Archaeological Services, Moundville, Alabama. Prepared for Tennessee Valley Authority, Norris, Tennessee. Marshall, Ann 2013 A Phase I Archaeological Survey for the Trinity-Browns Ferry Nuclear Plant 161-kV Transmission Linen Project, Limestone and Morgan Counties, Alabama. Prepared by Tennessee Valley Archaeological Research, Huntsville, Alabama. Prepared for Tennessee Valley Authority, Knoxville, Tennessee.
Exempted from Disclosure by Statute Figure 1. Current survey area, prior surveys, and archaeological sites at BFN.
400 West Summit Hill Drive, Knoxville, Tennessee 37902 March 21, 2022 Mr. Paul Barton Ms. Johnna Flynn Tribal Historic Preservation Officer Interim Tribal Historic Preservation Eastern Shawnee Tribe of Oklahoma Officer 127 West Oneida Jena Band of Choctaw Indians Seneca, Missouri 64865 Post Office Box 14 Jena, Louisiana 71342 Ms. Karen Brunso Tribal Historic Preservation Officer Mr. David Frank Division of Historic Preservation Tribal Historic Preservation Officer Department of Culture & Humanities Thlopthlocco Tribal Town The Chickasaw Nation Post Office Box 188 Post Office Box 1548 Okemah, Oklahoma 74859 Ada, Oklahoma 74821-1548 Ms. Devon Frazier Ms. RaeLynn Butler Tribal Historic Preservation Officer Manager Absentee Shawnee Tribe of Indians of Historic & Cultural Preservation Oklahoma Department 2025 S. Gordon Cooper Drive The Muscogee (Creek) Nation Shawnee, Oklahoma 74801 Post Office Box 580 Okmulgee, Oklahoma 74447 Mr. Larry Haikey Tribal Historic Preservation Officer Mr. Bryant Celestine Poarch Band of Creek Indians Tribal Historic Preservation Officer Regulatory Affairs Division Alabama-Coushatta Tribe of Texas 5811 Jack Springs Road 571 State Park Road 56 Atmore, Alabama 36502 Livingston, Texas 77351 Dr. Andrea Hunter Mr. David Cook Director and Tribal Historic Preservation Tribal Administrator Officer Kialegee Tribal Town Osage Nation Historic Preservation Post Office Box 332 Office Wetumka, Oklahoma 74883 627 Grandview Avenue Pawhuska, Oklahoma 74056 Ms. Kassie Dawsey Section 106 Coordinator Ms. Tonya Tipton Coushatta Tribe of Louisiana Tribal Historic Preservation Officer Post Office Box 10 Shawnee Tribe Elton, Louisiana 70532 Post Office Box 189 Miami, Oklahoma 74355
Ms. Elizabeth Toombs Mr. Ben Yahola Tribal Historic Preservation Officer Tribal Historic Preservation Officer Cherokee Nation The Seminole Nation of Oklahoma Post Office Box 948 12555 NS 3540 Road Tahlequah, Oklahoma 74465 Seminole, Oklahoma 74868 Ms. Whitney Warrior Mr. Stephen Yerka Director of Historic Preservation Historic Preservation Specialist United Keetoowah Band of Cherokee Tribal Historic Preservation Office Indians in Oklahoma Eastern Band of Cherokee Indians 18263 W. Keetoowah Circle Post Office Box 455 Tahlequah, Oklahoma 74464 Cherokee, North Carolina 28719
Dear Sir/Madam:
TENNESSEE VALLEY AUTHORITY (TVA), BROWNS FERRY NUCLEAR PLANT (BFN), SUBSEQUENT LICENSE RENEWAL - ARCHAEOLOGICAL SURVEY (TVA TRACKING NUMBER - CID 80680) (34.70414, -87.11800) We initiated consultation last year (letter dated July 19, 2021) with federally recognized Indian tribes and the Alabama State Historic Preservation Officer (SHPO) regarding TVAs Subsequent License Renewal for BFN. Tennessee Valley Archaeological Research (TVAR) completed the Phase I Archaeological survey of all areas within the plant reservation that had not been included in previous archaeological surveys and show no clear evidence of prior disturbance or development, in support of the project. The survey included approximately 193 acres distributed across six separate areas. Survey consisted of pedestrian walk-over of the entire survey area and systematic shovel testing in all areas with less than 50 percent ground surface visibility. Field observations during the survey resulted in exclusion of several small areas from the survey based on either visible signs of disturbance, or new information from plant personnel indicating past disturbance such as excavation, soil borrow, and waste disposal. This resulted in the actual surveyed area being somewhat smaller than we stated in our initial consultation, in which we estimated the survey area as approximately 260 acres. Figure 1 shows the current survey area, areas included in previous surveys, and all known archaeological sites at BFN. High- and low-resolution copies of the draft report can be downloaded from the following links: Exempted from Disclosure by Statute The survey revisited six previously-recorded archaeological sites (1LI24, 1LI284, 1LI286, 1LI287, 1LI856, and 1LI857) located within or adjacent to the survey area, and identified seven previously-unrecorded archaeological sites (1LI915, 1LI916, 1LI917, 1LI918, 1LI919, 1LI920, and 1LI921). TVAR recommends that site 1LI24 is no longer extant, having been destroyed during construction of BFN. They recommend that site 1LI857 is ineligible. Based on the shovel testing results, TVAR proposed combining sites 1LI287 and 1LI856 into a single site (1LI287), and also combining sites 1LI284 and 1LI286 into a single site (1LI284). The updated State Archaeological Site forms reflect these changes. TVAR recommends that sites 1LI284 and 1LI287 both have research potential and
Sir/Madam Page 2 March 21, 2022 should be avoided by project activities, and if avoidance is not possible, that additional investigations should be carried out at both sites to better ascertain their potential eligibility for the National Register of Historic Places (NRHP). Finally, TVAR recommends that all seven newly recorded sites lack research potential and should be considered ineligible for the NHRP. TVA has read the report and agrees with the findings and recommendations. Based on the survey results, site 1LI24 is no longer extant; sites 1LI915, 1LI916, 1LI917, 1LI918, 1LI919, 1LI920, and 1LI921 are ineligible for inclusion in the NRHP; and sites 1LI284 and 1LI287 should be considered to have undetermined eligibility for the NRHP. As mentioned in our previous letter on this project, TVA previously completed five archaeological surveys at BFN. The current survey was designed to included all remaining areas not included in those prior surveys and not obviously affected by plant construction/development. As a result, all areas within the BFN reservation that could have potential for archaeological sites have now been investigated. A total of three additional sites (1LI23, 1LI535, and 1LI812) have been identified at BFN in areas outside the current survey. Site LI23 Exempted from Disclosure by Statute and is presumed to have been destroyed during construction. Site 1LI535 was recommended potentially eligible (Gage 2001) and site 1LI812 was recommended ineligible (Marshall 2013). TVA and Alabama SHPO have reached agreement on these recommendations in previous consultation. Thus, based on the previous and current investigations, TVA finds there are three sites of undetermined eligibility (or, that are considered potentially eligible) within the BFN reservation: 1LI535, 1LI284, and 1LI287. The BFN Subsequent License Renewal project does not include any plans for ground disturbance anywhere on the BFN reservation. The project would not result in any effects on any of the investigated archaeological sites. The information provided by the survey will serve to support TVAs Environmental Report and Environmental Impact Statement for this project. In addition, we plan to utilize the results of the survey in all future project planning at BFN. Should TVA propose any project in future that would include any ground-disturbing activities that could affect sites 1LI535, 1LI284, or 1LI287, TVA would consult further with your office concerning the possible effects and plans for additional investigations to determine eligibility. Pursuant to 36 C.F.R. Part 800.3(f)(2), TVA is consulting with the following federally recognized Indian tribes regarding historic properties within the proposed projects APE that may be of religious and cultural significance and are eligible for the NRHP: Absentee Shawnee Tribe of Indians of Oklahoma, Alabama-Coushatta Tribe of Texas, Cherokee Nation, The Chickasaw Nation, Coushatta Tribe of Louisiana, Eastern Band of Cherokee Indians, Eastern Shawnee Tribe of Oklahoma, Jena Band of Choctaw Indians, Kialegee Tribal Town, The Muscogee (Creek) Nation, The Osage Nation, Poarch Band of Creek Indians, The Seminole Nation of Oklahoma, Shawnee Tribe, Thlopthlocco Tribal Town, and United Keetoowah Band of Cherokee Indians in Oklahoma.
Sir/Madam Page 3 March 21, 2022 By this letter, TVA is providing notification of these findings and is seeking your comments regarding any properties that may be of religious and cultural significance and may be eligible for listing in the NRHP pursuant to 36CFR § 800.2 (c)(2)(ii), 800.3 (f)(2), and 800.4 (a)(4)(b). We are also seeking your agreement with TVAs proposal to use the results of current and past archaeological surveys at BFN in future planning efforts. Please respond by April 20, 2022 if you have any comments. If you have any questions, please contact me by phone, (865) 253-1265 or by email, mmshuler@tva.gov. Sincerely, Official signature on file Marianne Shuler Senior Specialist, Archaeologist, and Tribal Liaison Cultural Compliance SCC:ABM Enclosures cc (Enclosures): Ms. Sheila Bird Cultural Preservation Consultant Ms. Courtney Neff Shawnee Tribe Section 106 Assistant Post Office Box 189 Osage Nation Miami, Oklahoma 74355 627 Grandview Avenue Pawhuska, Oklahoma 74056 Mr. Dakota John Deputy Tribal Historic Mr. Russell Townsend Preservation Officer Tribal Historic Preservation Coushatta Tribe of Louisiana Officer Post Office Box 10 Eastern Band of Cherokee Elton, Louisiana 70532 Indians Post Office Box 455 Ms. Corain Lowe-Zepeda Cherokee, North Carolina 28719 Tribal Historic Preservation Officer Mr. Acee Watt Historic & Cultural Preservation Section 106 Coordinator Department United Keetoowah Band of The Muscogee (Creek) Nation Cherokee Indians in Oklahoma Post Office Box 580 Post Office Box 746 Okmulgee, Oklahoma 74447 Tahlequah, Oklahoma 74465
References Cited Gage, Matthew 2001 A Cultural Resources Reconnaissance Survey of three Locations for the Proposed Expansion of Browns Ferry Nuclear Power Plant in Limestone County, Alabama. Prepared by The University of Alabama Museums, Office of Archaeological Services, Moundville, Alabama. Prepared for Tennessee Valley Authority, Norris, Tennessee. Marshall, Ann 2013 A Phase I Archaeological Survey for the Trinity-Browns Ferry Nuclear Plant 161-kV Transmission Linen Project, Limestone and Morgan Counties, Alabama. Prepared by Tennessee Valley Archaeological Research, Huntsville, Alabama. Prepared for Tennessee Valley Authority, Knoxville, Tennessee.
Exempted from Disclosure by Statute Figure 1. Current survey area, prior surveys, and archaeological sites at BFN.
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Sent: Thursday, March 24, 2022 9:48:39 AM To: Shuler, Marianne M <mmshuler@tva.gov> Cc: Whitney Warrior <wwarrior@ukb-nsn.gov>
Subject:
RE: TVA-BFN-SLR-Archaeological Survey-LimestoneCoAL-CID80680-21Mar2022 This is an EXTERNAL EMAIL from outside TVA. THINK BEFORE you CLICK links or OPEN attachments. If suspicious, please click the Report Phishing button located on the Outlook Toolbar at the top of your screen. Good morning, Received. Thank you for consulting with the UKB, and at this time I have no comments or questions. Kind regards, Acee Watt%6%$ $FHH:DWW KHKLP 6HFWLRQ&RRUGLQDWRU 2IILFHRI+LVWRULF3UHVHUYDWLRQ 0DLQ/LQH &HOO DZDWW#XNEQVQJRY XNEWKSR#XNEQVQJRY 7KLVFRPPXQLFDWLRQLVFRQILGHQWLDO_'HVWUR\LIUHFHLYHGLQHUURUDQGSOHDVHOHWPHNQRZ_8QDXWKRUL]HGXVHFRS\LQJRUGLVWULEXWLRQLV SURKLELWHG From: Shuler, Marianne M <mmshuler@tva.gov> Sent: Monday, March 21, 2022 10:10 AM To: thpo@estoo.net; HPO <HPO@chickasaw.net>; Section106 <Section106@muscogeenation.com>; Corain Lowe <CLowe@mcn-nsn.gov>; 'Bryant Celestine (celestine.bryant@mail.actribe.org)' <celestine.bryant@mail.actribe.org>; Bryant Celestne (Celestine.Bryant@actribe.org) <celestine.bryant@actribe.org>; 'David.Cook@kialegeetribe.net' <David.Cook@kialegeetribe.net>;
dc13.dc4@gmail.com; Kassie Dawsey <KDawsey@coushatta.org>; Johnna Flynn <jflynn@jenachoctaw.org>; THPO <THPO@tttown.org>; 106NAGPRA@astribe.com; THPO@pci-nsn.gov; Courtney Neff <cneff@osagenation-nsn.gov>; Tonya Tipton <tonya@shawnee-tribe.com>; Elizabeth Toombs <elizabeth-toombs@cherokee.org>; Yahola.b@sno-nsn.gov; Acee Watt <awatt@ukb-nsn.gov>; Stephen Yerka <syerka@ebci-nsn.gov> Cc: Karen Brunso <karen.brunso@chickasaw.net>; RaeLynn Butler <raebutler@muscogeenation.com>; DakotaJohn@coushatta.org; Whitney Warrior <wwarrior@ukb-nsn.gov>; Audra E. Whitehurse <audra.whitehurse@osagenation-nsn.gov>; Sheila Bird <sheila.bird@shawnee-tribe.com>; Russell Townsend <russtown@ebci-nsn.gov>
Subject:
TVA-BFN-SLR-Archaeological Survey-LimestoneCoAL-CID80680-21Mar2022 Good Morning By this email I am sending the enclosed letter regarding TVAs proposed subsequent license renewal for the Browns Ferry Nuclear Plant located in Limestone County, Alabama. TVA initiated consultation with your office in July of last year regarding this undertaking. The referenced reports can be downloaded online at the following links: http://tvaresearch.com/download/TVA_Browns_Ferry_Nuclear_Section_110_AL_high_resolution.pdf and http://tvaresearch.com/download/TVA_Browns_Ferry_Nuclear_Section_110_AL_low_resolution.pdf Please let me know by April 20, 2022 if you have any questions or comments on the proposed undertaking. Thanks Marianne 'XHWR&29,'VDIHW\SUHFDXWLRQVHQDFWHGE\79$,DPFXUUHQWO\WHOHZRUNLQJ 0DULDQQH6KXOHU 6HQLRU6SHFLDOLVW$UFKDHRORJLVW 7ULEDO/LDLVRQ &XOWXUDO&RPSOLDQFH 7HQQHVVHH9DOOH\$XWKRULW\ :6XPPLW+LOO'ULYH .QR[YLOOH71
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LPPHGLDWHO\E\HPDLODQGGHOHWHWKHRULJLQDOPHVVDJH EASTERN SHAWNEE CULTURAL PRESERVATION DEPARTMENT 70500 East 128 Road, Wyandotte, OK 74370 March 25, 2022 TVA: Tennessee Valley Authority 400 W. Summit Hill Drive Knoxville, TN 37902 RE: CID 80680, Limestone County, Alabama
Dear Ms. Shuler,
The Eastern Shawnee Tribe has received your letter regarding the above referenced project(s) within Limestone County, Alabama. The Eastern Shawnee Tribe is committed to protecting sites important to Tribal Heritage, Culture and Religion. Furthermore, the Tribe is particularly concerned with historical sites that may contain but not limited to the burial(s) of human remains and associated funerary objects. As described in your correspondence, and upon research of our database(s) and files, we find our people occupied these areas historically and/or prehistorically. However, the project proposes NO Adverse Effect or endangerment to known sites of interest to the Eastern Shawnee Tribe. Please continue project as planned. However, should this project inadvertently discover an archeological site or object(s) we request that you immediately contact the Eastern Shawnee Tribe, as well as the appropriate state agencies (within 24 hours). We also ask that all ground disturbing activity stop until the Tribe and State agencies are consulted. Please note that any future changes to this project will require additional consultation. In accordance with the NHPA of 1966 (16 U.S.C. § 470-470w-6), federally funded, licensed, or permitted undertakings that are subject to the Section 106 review process must determine effects to significant historic properties. As clarified in Section 101(d)(6)(A-B), historic properties may have religious and/or cultural significance to Indian Tribes. Section 106 of NHPA requires Federal agencies to consider the effects of their actions on all significant historic properties (36 CFR Part 800) as does the National Environmental Policy Act of 1969 (43 U.S.C. § 4321-4347 and 40 CFR § 1501.7(a). This letter evidences NHPA and NEPA historic properties compliance pertaining to consultation with this Tribe regarding the referenced proposed projects. Thank you, for contacting the Eastern Shawnee Tribe, we appreciate your cooperation. Should you have any further questions or comments please contact our Office. Sincerely, Paul Barton, Tribal Historic Preservation Officer (THPO) Eastern Shawnee Tribe of Oklahoma (918) 666-5151 Ext:1833 THPO@estoo.net
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Re: TVA-BFN-SLR-Archaeological Survey-LimestoneCoAL-CID80680-21Mar2022 This is an EXTERNAL EMAIL from outside TVA. THINK BEFORE you CLICK links or OPEN attachments. If suspicious, please click the Report Phishing button located on the Outlook Toolbar at the top of your screen.
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Subject:
TVA-BFN-SLR-Archaeological Survey-LimestoneCoAL-CID80680-21Mar2022 CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Good Morning By this email I am sending the enclosed letter regarding TVAs proposed subsequent license renewal for the Browns Ferry Nuclear Plant located in Limestone County, Alabama. TVA initiated consultation with your office in July of last year regarding this undertaking. The referenced reports can be downloaded online at the following links: http://tvaresearch.com/download/TVA_Browns_Ferry_Nuclear_Section_110_AL_high_resolution.pdf and http://tvaresearch.com/download/TVA Browns Ferry Nuclear Section 110 AL low resolution.pdf Please let me know by April 20, 2022 if you have any questions or comments on the proposed undertaking. Thanks Marianne Due to COVID-19 safety precautions enacted by TVA, I am currently teleworking. Marianne Shuler 6HQLRU6SHFLDOLVW$UFKDHRORJLVW 7ULEDO/LDLVRQ
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400 West Summit Hill Drive, Knoxville, Tennessee 37902 October 18, 2022 Ms. Lee Anne Wofford Deputy State Historic Preservation Officer Alabama Historical Commission 468 South Perry Street Montgomery, Alabama 36130-0900
Dear Ms. Wofford:
TENNESSEE VALLEY AUTHORITY (TVA), BROWNS FERRY NUCLEAR PLANT (BFN), SUBSEQUENT LICENSE RENEWAL (SLR) - HISTORIC ARCHITECTURAL INVENTORY AND NATIONAL REGISTER OF HISTORIC PLACES (NRHP) EVALUATION (TVA TRACKING NUMBER - CID 80680) (AHC 2021-0929) We initiated consultation with your office last year (letter dated July 19, 2021) regarding TVAs SLR for BFN. BFN is a three-unit nuclear power generation plant located in an 880-acre tract on Wheeler Reservoir, on the right-descending bank of the Tennessee River in Limestone County, Alabama, approximately 10 miles southwest of Athens. BFN was TVAs first nuclear powered electrical generation facility. TVA began construction in 1966, put Unit 1 into commercial operation in December 1973, Unit 2 in June 1974, and Unit 3 in July 1976. With a capacity of over 3,200 megawatts, BFN was the worlds largest nuclear power plant at the time of its construction. TVAs original operating license for each of the three units was for a term of 40 years. TVA obtained approval to renew the operating license from the Nuclear Regulatory Commission (NRC) in 2006, which extended the operating licenses for each unit an additional 20 years. In order to continue to operate BFN, TVA is seeking an additional license renewal for Units 1-3. Currently, TVA has no plans for changes to BFN related to the SLR project. However, the project may require maintenance actions or refurbishment to BFN to maintain consistency with the current licensing basis, as well as NRC and TVA requirements. Also, intake structures, buried piping, and large external tanks may require upgrades for continued operation from 60 to 80 years. TVA has not yet identified plans for any such actions. However, if such actions were proposed in future, they could include modifications that have potential to alter the qualities that may lend historic significance to BFN, if BFN were determined eligible for inclusion in the NRHP, and could also include ground disturbing activities, which would have potential to affect archaeological sites. TVA determined the APE for the undertaking as BFN and all areas within the 880-acre reservation.
Ms. Lee Anne Wofford Page 2 October 18, 2022 We carried out an archaeological survey of previously unsurveyed (and undeveloped) land in the APE in the fall of 2021 and completed consultation with your office regarding the survey findings under Section 106 of the National Historic Preservation Act earlier this year (AHC- 21-0929). In this letter, we focus on our effort to determine whether BFN is eligible for the NRHP as an above-ground property. TVA completed an inventory and NRHP evaluation of BFN in the fall of 2021 as part of TVAs Section 106 compliance for the SLR project. Brockington and Associates, Inc. carried out the survey and prepared the report. The inventory included 69 architectural resources or features within the BFN boundary built prior to 1981. Fifty-one of these resources were constructed from 1973 through 1976. An electronic copy of the report, titled, Historic Architectural Resources Survey of the Browns Ferry Nuclear Plant Project, Limestone County, Alabama, is enclosed. Brockington recommends BFN eligible for the NRHP as a historic district under Criteria Consideration G, as a property of exceptional significance that is less than 50 years old. However, as the primary buildings and structures were built between 1973 and 1976, portions of the property will very soon meet the 50-year age threshold for consideration as historic properties. Further, as the SLR project could have effects on the plant that would occur after 1973, for purposes of this Section 106 review TVA assumes that BFN is sufficiently old to meet NRHP criteria of significance. Brockington recommends that the intact buildings and structures built 1973-76 meet NRHP criteria A and C for their association with early nuclear energy development in Alabama and the TVA system, and as representative examples of nuclear energy engineering and architecture. TVA has read the report and agrees with the findings and recommendations. TVA finds that BFN is eligible for the NRHP under Criterion Consideration G as a historic district of exceptional significance due to the role it played in the nations early efforts to develop nuclear power. As noted by Holland et al. (2013:1), Browns Ferry Nuclear Power Plant was the first project in an ambitious program to construct 17 nuclear power units at seven sites in the Southeast. Although the program was plagued by cost over runs, industrial accidents, cancellations, and other setbacks, by 1982 TVA was operating five nuclear units including three at BFN. And, as further stated by Holland et al. (2013:1), TVAs nuclear power program reflects the dynamic history of the Atomic Age in general, as well as the evolution of TVA as it sought to define its role in the shifting political and economic climate of the times. The recommended period of significance is from 1966, the year TVA began land acquisition for the project, to 1980, the date by which all the buildings and structures necessary for plant operations had been constructed. Further, given that BFN will soon meet the 50-year threshold for consideration as a historic property, TVA also evaluated the potential eligibility of BFN under Criteria A, B, and C. Although TVA generally relies on the 50-year threshold in evaluating properties, we also give consideration to the National Park Services explanation of their intention in creating a threshold: The 50-year period is an arbitrary span of time, designed as a filter to ensure that enough time has passed to evaluate the property in a historic context.
Ms. Lee Anne Wofford Page 3 October 18, 2022 However, it was not designed to be mechanically applied on a year-by-year basis (Sherfy and Luce 1979:6). In our view, sufficient time has passed since the construction of BFN to consider its significance within the broader context of the Nuclear Age and TVAs entry into the nuclear power industry. We agree with Brockingtons recommendation that BFN is eligible under Criterion A for its association with early nuclear energy development in Alabama and the TVA system, and under Criterion C as a representative example of nuclear energy engineering and architecture. As the SLR project as currently designed includes no changes to BFN or any other NRHP-eligible or -listed property, TVA finds that the undertaking will not affect above-ground historic properties. Should TVA propose any future actions with potential to cause effects on BFN as an above-ground resource, we will consult further with your office. Pursuant to 36 CFR Part 800.4(d)(1) we are notifying you of TVAs finding of no historic properties affected, providing the documentation specified in § 800.11(d); and inviting you to review the finding. Also, we are seeking your agreement with TVAs eligibility determination for BFN and finding that the undertaking as currently planned will have no effects on above-ground historic properties. Please contact Steve Cole by email, sccole0@tva.gov with any comments or questions. Sincerely, James W. Osborne, Jr. Manager Cultural Compliance SCC:ERB Enclosures Reference Cited Holland, Jeffrey L. 2013 TVA in the Nuclear Age: A History of the Tennessee Valley Authoritys Nuclear Power Program. Prepared by TRC Environmental Corporation, Norcross, Georgia. Prepared for Tennessee Valley Authority, Knoxville, Tennessee. Sherfy, Marcella and W. Ray Luce 1979 National Register Bullet: Guidelines for Evaluating and Nominating Properties that Have Achieved Significance Within the Past Fifty Years. U.S. Department of the Interior, National Park Service, National Register of Historic Places. Revised 1990, 1996, 1998.
Lisa D. Jones ALABAMA HISTORICAL COMMISSION Executive Director State Historic Preservation Officer 468 South Perry Street Tel: 334-242-3184 Montgomery, Alabama 36130-0900 Fax: 334-242-1083 November 14, 2022 James Osborne, Jr. TVA 400 West Summit Hill Drive Knoxville, TN 35209 Re: AHC 23-0066 Browns Ferry Nuclear Plant (BFN) Subsequent License Renewal (SLR) Limestone County
Dear Mr. Osborne:
Upon review of the above referenced architectural assessment of the Browns Ferry Nuclear Plant, we find that the AHC agrees with the authors recommendations that BFN is eligible under Criterion A for its association with early nuclear energy development in Alabama and the TVA system, and under Criterion C as a representative example of nuclear energy engineering and architecture. Further, we agree that the undertaking will not affect aboveground historic properties, as the proposed SLR project includes no changes to BFN or any other NRHP-eligible or -listed property. Therefore, we concur with the proposed project activities. We appreciate your commitment to helping us preserve Alabamas historic archaeological and architectural resources. Should you have any questions, please contact Leanne Waller-Trupp at 334.230.2653 or Leanne.Trupp@ahc.alabama.gov. Have the AHC tracking number referenced above available and include it with any future correspondence. Sincerely, Lee Anne Wofford Deputy State Historic Preservation Officer LAW/amh THE STATE HISTORIC PRESERVATION OFFICE www.ahc.alabama.gov}}

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