ML24218A171
| ML24218A171 | |
| Person / Time | |
|---|---|
| Site: | 99902056 |
| Issue date: | 08/05/2024 |
| From: | Joseph Giacinto NRC/NMSS/DREFS/EPMB3 |
| To: | |
| References | |
| Download: ML24218A171 (6) | |
Text
1 Clinch River Nuclear Site Construction Permit Preapplication Readiness Assessment Report for the Draft Environmental Report August 5, 2024
=
Background===
Tennessee Valley Authority (TVA) is currently the holder of an Early Site Permit (ESP) for the Clinch River Nuclear (CRN) Site in Oak Ridge, Tennessee. The permit, (ESP-006) was issued to TVA on December 19, 2019 (ML19352D868). Prior to the issuance of ESP-006, the Nuclear Regulatory Commission (NRC) prepared a final environmental impact statement (ESP FEIS) to support the agencys licensing decision (ML19087A266). Subsequently, TVA completed a final programmatic environmental impact statement (TVA PEIS) for the CRN Site Advanced Nuclear Reactor Technology Park published in the Federal Register (87 FR 59860) on July 29, 2022.
Within the next few months, TVA intends to submit a construction permit (CP) application for a small modular reactor (SMR) at the CRN Site.
Readiness assessments are intended to provide the NRC staff with opportunities to (1) identify any required information that is missing from an application, (2) identify technical or regulatory issues that may complicate the acceptance or technical reviews of an application, and (3) become familiar with the content of an application, particularly in areas where applicants plan to propose new concepts or novel design features. For this assessment, the NRC staff reviewed chapters of TVAs draft Environmental Report (ER) and related information and provided observations to TVA based on these reviews.
Assessment Approach Per 10 CFR 51.50(c)(1), the ER submitted with an application referencing an ESP is not required to contain information or analysis that was previously submitted in the ER for the ESP application or address issues that were resolved in the ESP EIS. The ER for the Combined Operating License (COL) (or CP) stage is required to provide the following information:
- Information to demonstrate that the chosen design of the facility falls within the site characteristics and design parameters specified in the ESP.
- Sufficient information to resolve any significant environmental issues that were not resolved in the ESP EIS.
- New and significant information related to impacts of construction and operation that were resolved in the ESP process.
- A description of the process used to identify new and significant information regarding conclusions presented in the ESP EIS.
- Information that demonstrates that all environmental terms and conditions included as part of the ESP will be satisfied by the date of issuance of the COL (CP).
To proactively address regulatory requirements and help streamline the permitting and licensing process, TVA engaged NRC during preapplication related to the CP application submittal.
Initiated during July 2022 as part of the preapplication process, TVA subsequently began
2 providing draft chapters of the CP ER and corresponding Data Review Reports (DRR) through postings to an electronic reading room portal for the NRC staffs review. The DRRs contain supporting information that TVA utilized for development of the draft ER chapters. The DRRs contained the applicants implementation of the process used to identify new and significant information regarding issues that were resolved in the ESP FEIS. The draft ER and the DRRs included references to the ESP FEIS and the TVA PEIS. Where appropriate, NRC subject matter experts reviewed information contained in the DRRs, the ESP FEIS and the TVA PEIS, in addition to the draft ER as a basis for developing observations. During the review, the NRC staff periodically briefed TVA on the staffs draft observations and discussed preliminary results of the readiness assessment. Consistent with NRC regulations, the DRRs need not be submitted on the docket. This report summarizes the NRC staffs observations provided to TVA and serves to close the preapplication readiness assessment phase.
During engagements, TVA offered initial feedback on how it planned to address, as applicable, the NRC staffs observations (e.g., revise the ER and/or DRR, make additional information available during the application review phase). The NRC staff found TVAs feedback helpful to contextualize observations and considered this input when developing observations related to the information needed by staff to prepare the CP SEIS.
Per 10 CFR 51.92, the NRCs CP SEIS must include analyses of environmental issues related to the impacts of construction or operation of the facility that were not resolved during the ESP proceeding and, those that were resolved during the ESP proceeding but for which new and significant information has been identified, including, but not limited to, new and significant information demonstrating that the design of the facility falls outside the site characteristics and design parameters specified in the ESP. The NRC staff identified ten observation items as described in the following section and attachment.
NRC Observations As part of the readiness review, staff developed observations regarding whether the sections contained issues that may create a challenge with regard to acceptance or could require submittal of additional information after the application is submitted. However, the readiness assessment is not part of the NRCs official acceptance review process, and observations from the readiness assessment do not predetermine whether the ER will be docketed when submitted.
Observations from the NRC staffs readiness assessment based on a review of draft ER sections and information contained in the DRRs are included in the attachment. The attachment provides brief summaries of the NRC staff observations of TVAs readiness related to its draft ER for a future BWRX-300 SMR CP application at the CRN Site. These observations are related to TVAs draft ER analyses characterizing the potential environmental effects of construction, operation and decommissioning of the SMR at the site.
In general, draft ER sections available for review appeared to be comprehensive, contain a description of rationale and methodology and follow regulations and applicable guidance. Based on the review and discussions, staff did not identify issues that would indicate TVA would not be able to meet its proposed schedule for submittal of the CP application. However, the staff recommends that TVA address the observations presented in the attached table, as applicable, prior to submitting its application. Addressing the staff observations would improve the efficiency and schedule predictability of the staffs review when the CP application is submitted.
3 As indicated above, the observations presented in the attached table have been previously discussed with TVA during periodic meetings over the duration of the readiness review and where applicable, relevant details of these discussions have been included in the attached observations.
4
- Readiness Assessment Observation Summaries
5 Table 1: Readiness Assessment Review Observation Summaries Document Chapter /
Resource Area Obs.
Observation 02 - Proposed Site and Affected Area Draft CP ER Land Use 02.a Areas previously not analyzed in the NRC ESP EIS and TVAs PEIS, such as the new 161-kV transmission line and land near the barge area, should be reviewed for the following:
Raw material resources, specifically minerals Principal agricultural and commercial forest products Federal actions associated with the potential land acquisition for the new 161-kV in the Grassy Creek Habitat Protection Area Draft CP ER Land Use 02.b For maps that include areas not previously evaluated during the ESP proceedings, a detailed description of geographic information system coverages used to produce the resulting maps is not included in the ER.
04 - Environmental Impacts of Plant Construction Draft CP ER Land Use 04.a The DRR did not provide the necessary information for staff to confirm the assumption in ESP EIS, Appendix J, Table J-2 regarding the amount and disposition of spoils and dredged materials.
05 - Environmental Impacts from Operation of the Proposed Plant Draft CP ER Terrestrial Ecology 05.a Effects on terrestrial wildlife, and species of importance, resulting from maintenance of new transmission line rights-of-way and other exterior areas and corridors are not discussed and were areas previously not analyzed in the NRC ESP EIS and TVAs PEIS.
Draft CP ER Accidents 05.b Based on the draft ER, TVA identified no new inputs that would alter the NRC ESP FEIS analysis of impacts of postulated accidents.
Given the need for the NRCs CP SEIS to consider the new information related to being outside the design parameters specified in the PPE, TVA will need to demonstrate why the new information is not significant with regard to the ESP FEIS evaluation of severe accidents.
06 - Fuel Cycle, Transportation, and Decommissioning Impacts
6 Document Chapter /
Resource Area Obs.
Observation Draft CP ER Fuel Cyle 06.a With respect to burnup levels, current NEPA evaluations provides Table S-4 is bounding for up to 62 GWd/MTU as discussed in the 2013 LR GEIS (NUREG-1437). While the NRC has not yet finalized the documentation for justification that Table S-4 is valid up to or higher than 75 GWD/MTU, the staff has conducted a re-evaluation for up to 80 GWd/MTU as NUREG-2266 (ML23240A756) that is currently available for public comment through 10/31/2023. Also for the CP, TVA should address the spent fuel pool items in the Clinch River ESP FEIS Appendix J since the BWRX-300 spent fuel pool configuration varies from that stated in this Appendix J. Therefore, the spent fuel pool information is new and potentially significant.
07 - Cumulative Impacts Draft CP ER Accidents 07.a TVA has not included a discussion of the severe accidents and severe accident mitigation design alternatives in ER Chapter 5. TVA has not provided the cumulative effects of accidents in Chapter 7 of the ER. TVA is pursuing a two-step Part 50 application and has stated in Chapter 5 of the CPA ER that a full accident discussion will occur in the operating license application ER.
10 - Environmental Consequences of the Proposed Action Draft CP ER Socioeconomics/Benefit-Cost Balance 10.a An update of the most recent Integrated Resource Plan is not provided.
Draft CP ER Socioeconomics/Benefit-Cost Balance 10.b A discussion about payments made by TVA in lieu of taxes and the total annual wages paid for the purpose of the cost-benefit analysis is not provided.
Draft CP ER Socioeconomics/Benefit-Cost Balance 10.c An estimation about how much percentage of the costs go to local purchases is not provided.