ML24228A193
| ML24228A193 | |
| Person / Time | |
|---|---|
| Site: | 99902056 |
| Issue date: | 08/28/2024 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| References | |
| Download: ML24228A193 (1) | |
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1
SUMMARY
REPORT ON THE ENVIRONMENTAL AUDIT OF THE REQUEST FOR EXEMPTION TO ALLOW EXCAVATION AT THE CLINCH RIVER NUCLEAR SITE PRIOR TO CONSTRUCTION PERMIT ISSUANCE
1.0 Background
The U.S. Nuclear Regulatory Commission (NRC) is currently reviewing a November 30, 2023, Tennessee Valley Authority (TVA) request for exemption for activities otherwise not permitted under Title 10 of the Code of Federal Regulations (10 CFR) Section 50.10(c) to allow excavation related activities prior to a potential construction permit (CP) issuance (Agencywide Documents Access and Management System [ADAMS] ML23335A100). TVA anticipates submitting a CP application in the near future to build a small modular reactor at the Clinch River Nuclear (CRN) Site in Roane County, Oak Ridge, Tennessee. As part of its review, the NRC staff is preparing an environmental assessment (EA). An audit was conducted from February 28, 2024, to August 2, 2024, to support the environmental review of the exemption request. This report presents a summary of the audits objectives and activities, and information that was obtained as a result of audit activities as described in the staffs audit plan (ML24060A069).
1.1 Exemption Request Overview The NRC accepted TVAs request by letter dated January 31, 2024 (ML24009A168) for exemption from 10 CFR 50.10 (c). Specifically, TVA is requesting an exemption pursuant to 10 CFR 50.12(b), to allow the conduct of certain ground support activities related to excavation at the CRN Site prior to the issuance of a CP not otherwise permitted by 10 CFR 50.10(c).
Although TVA noted in its exemption request that the initial ground support system (i.e., erosion control measures) it intends to install would be to ensure worker safety and would be independent of the future nuclear facility, the features would remain in place which requires an exemption.
1.2 Site Overview The CRN Site is located in the southwestern part of the city limits of Oak Ridge, Tennessee, approximately 10 miles south of the Oak Ridge urban center; 16 miles west of Knoxville, Tennessee, and 7 miles east of Kingston, Tennessee. The site was partially developed for the abandoned Clinch River Breeder Reactor Project (CRBRP). CRBRP site preparation activities began in 1982 and were terminated in 1983. Ground disturbance affected approximately 240 acres by the time the project was terminated (NRC 2019). The CRBRP redress plan included backfilling an associated excavation pit, grading, compacting level areas, reseeding of grass, and planting of trees, installation of culverts to direct water and modification of the stormwater retention ponds for long-term stability. The present site topography reflects the backfilling and grading done to remediate the site after the CRBRP was canceled, as well as surface drainage infrastructure, retention ponds, and other ponds that were left in place. The site has naturally revegetated back to mixed hardwood forests, upland meadows, and vegetated wetlands (NRC 2019).
The excavation area affiliated with this exemption request is within the area evaluated by NRCs Environmental Impact Statement (EIS) for an Early Site Permit (ESP) at the CRN Site, dated April 2019 (hereafter referred to as the NRC ESP EIS (ESP-006, ML19087A266)), and TVAs Clinch River Nuclear Site Advanced Nuclear Reactor Technology Park Final Programmatic Environmental Impact Statement (PEIS), dated July 2022 (hereafter referred to as the TVA PEIS (TVA 2022)).
2.0 Audit Scope and Objectives
2 The objective of the virtual audit of the exemption request was to more fully define and understand the scope of activities associated with the proposed action and to identify whether there was new and significant information since the publication of the ESP EIS that staff would need to consider in the EA. In preparation for the audit, the staff identified the information needed to meet the above audit objectives and these items were included in Attachment 1 of the audit plan (ML24060A071).
During the audit, the staff discussed environmental matters related to land use, ground and surface water, terrestrial and aquatic ecology, human health, non-radiological waste, historic and cultural resources, air quality, socioeconomic resources, and environmental justice. Audit activities consisted of document reviews and virtual meetings organized in advance. These activities assisted the NRC and TVA staff in resolving the information needs that were outlined in the plan. For items that the staff was not able to resolve through document reviews and audit discussions, TVA submitted information to the NRC, supplementing its exemption request to provide the necessary information for the staff to make impact determinations in the EA (ML24193A301).
The audit allowed the staff to better understand the activities associated with the proposed action and the affected area to differentiate those from the overall full set of CRN project activities evaluated in the ESP EIS. It also supported the staffs process for the identification and evaluation of new and potentially significant information regarding the staffs evaluation as documented in the ESP EIS, specific to the activities and affected area for the exemption request. During the audit, the staff also met with staff from the U.S. Army Corps of Engineers and the Tennessee Historical Commission to support their information gathering.
Table 1 of this report presents a list of the NRC staff participating in the audit and their associated EIS review areas.
Table 1. Review Areas with Assigned Team Members Team Member Role / Review Area Daniel Barnhurst Branch Chief Joseph Giacinto Project Manager Madelyn Nagel Deputy Project Manager Tamsen Dozier Supporting Project Manager Rajiv Prasad1 Team Lead, Surface Water Kim Leigh1 Deputy Team Lead, Non-radiological Human Health Peyton Doub/Dana Vesty1/Brandon Boehnke1/Ann Miracle1 Ecological Resources Kazi Tamaddun1 Surface Water Becka Bence1/Phil Meyer1 Groundwater Hydrology, Geology Dana Vesty1/Dave Anderson1 Land Use Lin Zeng1 /Dave Anderson/ Adrienne Rackley1 Socioeconomics/Environmental Justice Jon Napier 1/Michael Smith1 Waste Management Saikat Gosh1 Air Quality Resources 1 Pacific Northwest National Laboratory
3 Beau Goldstein/Cyler Conrad1 Historic and Cultural Resources 3.0 Summary of Audit Activities and Issues Addressed In order to appropriately document the staffs confirmation of information gathered during the audit which would not otherwise be available in the public domain, the staff prepared and issued information requests concerning exemption-related activities and TVA responded to the staffs requests (ML24193A301). All information items were resolved through TVAs responses to the staffs requests for information and related discussions.
4.0 Audit Closeout Based on discussions with TVA and related responses to staffs information needs (ML24193A301), the NRC staff determined no further follow up was needed and the audit was closed on August 2, 2024.