ML24264A070

Modification No. 008 to Task Order No. 31310020F0109 Under Contract No. 31310020D0010

ML24264A070
Person / Time
Issue date:	09/17/2024
From:	Rachel Glaros Acquisition Management Division
To:	Numark N Numark Associates
References
31310020D0010
Download: ML24264A070 (1)

Text

31310020D0010/31310020F0109 Page 3 Optional Task 9C: Removed Optional Task 9D: Removed Optional Task 9E: Removed Total Order Cost (Inclusive of Options)

Total Order Fixed Fee (Inclusive of Options)

Total Order Ceiling (Inclusive of Options)

$1,123,857.63 Section F - Deliveries or Performance was revised as follows.

Summary of Clause Changes:

Clause titled TASK/DELIVERY ORDER PERIOD OF PERFORMANCE (SEP 2013) is incorporated as follows:

TASK/DELIVERY ORDER PERIOD OF PERFORMANCE (SEP 2013)

This order shall commence on September 30, 2021 and will expire on March 31, 2026.

Section J - List of Documents, Exhibits and Other Attachments was revised as follows.

Table has been revised and now reads as follows:

Attachment Number Title Date Number of Pages 1

NRC Form 187 - Contract Security Classification Requirements 06/30/2021 2

2 Billing Instructions for Cost Plus Fixed Fee Contracts 09/01/2018 10 3

Statement of Work 09/27/2021 26 4

Statement of Work. - Revision 1 02/05/2024 26 5

Statement of Work - Revision 2 03/15/2024 26

31310020D0010/31310020F0109 Page 4 Attachment Number Title Date Number of Pages 6

Statement of Work - Revision 3 09/13/2024 29

1 STATMENT OF WORK - REVISION 3

1. PROJECT TITLE Technical Assistance for the Development of an Environmental Impact Statement and Safety Evaluation Report Chapter for Environmental Protection for X-Energy LLCs License Application Request for a License to Construct, Operate, and Decommission a Fuel Fabrication Facility

2. BACKGROUND The applicant, X-energy (XE), is expected to submit a license application to the U.S. Nuclear Regulatory Commission (NRC) in January 2022, to construct, operate, and decommission a fuel fabrication facility (FFF) on a site in Oak Ridge, Tennessee. Based on information provided by XE at public meetings with the NRC, the proposed project would be a facility to construct a tri-structural isotropic (TRISO) type FFF.

The NRCs review of the XEs license application request falls under the purview of the Office of Nuclear Material Safety and Safeguards (NMSS) for regulating activities which provide for the construction, operation and decommissioning of a fuel fabrication facility under the Atomic Energy Act.

The NRC staff finds that the proposed action is a major Federal action significantly affecting the quality of the human environment, which pursuant to 10 CFR § 51.20(a)(7), requires the NRC to prepare an Environmental Impact Statement (EIS) to meet the requirements of the National Environmental Policy Act of 1969, as amended (NEPA), and pursuant to the National Historic Preservation Act of 1966 (NHPA), is also federal undertaking pursuant to 36 CFR 800. In addition, the NRC typically coordinates reviews required by other statutes, such as the NHPA and Endangered Species Act of 1973 (ESA), with its NEPA reviews.

Furthermore, given the unique nature of the application, the XEs FFF license application request may gather a moderate level of interest from potential interveners who live near the site and the licensing action could potentially be adjudicated (i.e., a contested hearing to be conducted by the NRCs Atomic Safety and Licensing Board (ASLB)).

XE (TRISO-X) is expected to submit a supplement to their license application to the NRC in October 2024, which will include an updated Environmental Report and other supporting documents. An updated Safety Analysis Report and other supporting documents is expected to be submitted to the NRC in December 2024. The license application will be supplemented to include a new facility layout, processing area and change of feedstock.

3. OBJECTIVE The objective of this task order is to obtain Contractor technical assistance to the NRC staff for the development of an SER Chapter associated with environmental protection and monitoring, and an EIS and to assist in NHPA Section 106 consultation activities, in support of the staffs environmental review for the license application request from XE to construct and operate a nuclear fuel fabrication facility for TRISO particle fuell at a proposed site in Oak Ridge, Tennessee, as well as providing relevant Contractor expertise for a potential adjudicatory hearing on the licensing action.

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4. SCOPE OF WORK The Contractor shall provide all technical assistance including technical review, coordination and editing for all phases of the review that will conclude with the preparation of a SER Chapter and an EIS that the NRC will use to document its review of XEs license application request to construct and operate a TRISO FFF in Oak Ridge, Tennessee, pursuant to 10 CFR Part 51.

The resource/impact areas to be examined in the EIS in terms of the affected human environment and the potential impacts to that environment - shall include: land use; transportation; geology, seismology and soils; water resources (ground water and surface water); ecological resources (including threatened and endangered species); climatology; meteorology and air quality; climate change; noise; historic and cultural resources; visual and scenic resources; socioeconomics; public and occupational health (non-radiological and radiological); environmental consequences from accidents; waste management; and environmental justice. Both direct and cumulative impacts shall be evaluated in the impacts determination.

The EIS shall provide a comparative analysis of the potential environmental impacts from the applicants proposed action and from reasonable alternatives to that action, including, but not necessarily limited to, the no-action alternative. The EIS shall also document the purpose and need for the applicants proposed action, the applicable statutory and regulatory requirements (including and in addition to those of the NRC), mitigation measures to avoid or minimize environmental impacts, environmental measurement and monitoring programs, an analysis of cumulative impacts, and a cost-benefit analysis.

The proposed action may generate external stakeholder interest. Development of the EIS, therefore, will involve a public outreach, scoping and facilitation program.

Preparation of the EIS may involve other federal agencies in the role of cooperating agencies, with the NRC as the lead federal agency. The NRC will coordinate the role of the cooperating agencies, if any, in the schedule for EIS preparation. These cooperating agencies will provide input to and comments on working copies of the EIS.

The Contractor shall prepare the EIS in accordance with the NRCs applicable NEPA-implementing regulations in 10 CFR Part 51 and associated NRC staff guidance in NUREG-1748 and appropriate safety review guidance for those technical areas that overlap the safety review. Also, the NRC typically coordinates reviews required by other statutes, such as the NHPA and ESA, with its NEPA reviews. Therefore, the Contractor is expected to be cognizant of other statutes that the NRC will need to comply with during its licensing review of the proposed action. In addition, the Contractor shall provide the NRC staff with relevant expertise for a potential adjudicatory hearing on environmental issues.

In addition, the Contractor shall provide support for the NHPA Section 106 consultation process, potentially including research, facilitation, survey assistance, development of recommendations, survey and form reports, assessment of effects, and support in developing mitigation plans. In the Section 106 process, the Contractor shall obtain and leverage any information from consultations performed for other applications that are relevant to the current review (i.e. in the region of the proposed XE FFF site).

Prior to license application submittal to the NRC, the contractor is authorized to participate in a kick-off meeting and other discussions with the NRC COR upon request, and perform activities required to process security access for personnel

3 performing under the task order. Any additional work that the contractor needs to perform after award of contract and before NRC receipt of license application must be approved in writing in advance by the NRC COR.

SPECIFIC TASKS The specific tasks and deliverables required for the Contractor to complete the EIS, the NHPA consultation process, and provide support for a potential adjudicatory hearing on environmental issues and to complete an SER Chapter associated with environmental protection and monitoring are described in detail below. The NRC will issue a modification authorizing the contractor to begin work on optional tasks as required. See also Section 6 of this SOW for a summary of required deliverables and the deliverable/milestone schedule and Section 12.1 for travel requirements for the task order.

In preparing the EIS, the Contractor shall use the information provided by the NRC and additional information obtained by the Contractor in the course of preparing the EIS, as described in the tasks/subtasks below. In addition, the Contractor shall incorporate into the EIS other relevant information and conclusions developed during the NRC staffs safety review of XEs license application request, as will be documented in the NRCs Safety Evaluation Report (SER), such as potential public and occupational health impacts, and environmental consequences from accidents. Furthermore, the Contractor shall also use any additional information as provided by the NRC, which either supplements or replaces XEs original license application request. For example, the additions to the application may come in the form of an application supplement(s), and/or XEs responses to NRCs requests for additional information. The Contractor shall leverage information and experiences from other environmental reviews performed for nearby facilities for this review, if possible and appropriate.

Task 1 - Project Management and Document Management Throughout Task Order Duration This task shall last for the entire duration of the EIS development, the NHPA consultation process, and, if needed, the adjudicatory hearing. It may involve travel for the Contractor Project Manager to meet with the NRC Contracting Officers Representative (COR), if needed. The following activities will be included in performance of this task and throughout the life of the task order:

Schedule Development Following task order authorization, in consultation with the NRC COR, the Contractors Project Manager shall develop and maintain a detailed project schedule electronically in MS Project. This schedule shall be updated as necessary and provided to the NRC COR periodically upon request.

Communication Prior to the initiation of work, the NRC will conduct a kick-off meeting via teleconference call with the contractor to discuss the project.

The NRC expects that a weekly status call or face-to-face meeting between the NRC COR and the Contractor Project Manager will be held to discuss the current status of the project (e.g., technical issues, contract monitoring, file management). However, communication may occur more or less often depending on the need. NRC anticipates that quarterly

4 progress meetings with the NRC COR may be necessary.

File Management The Contractor shall work with the staff to develop a file sharing and management process that meets NRC security requirements. This process will be agreed upon by both parties andwill be used to transmit all project-related documents, correspondence, and all working and final files.

Comment Management The Contractor shall use the Pacific Northwest National Laboratorys Comment Response Database to sort and respond to comments during the EIS scoping and the draft EIS comment periods. All comments and responses shall be updated in the database.

Quality Assurance Program The Contractor Project Manager shall have overall responsibility for ensuring that a robust and comprehensive quality assurance program is adequately implemented for all aspects of the contract including, but not limited to, the quality of technical input as well as the editing of technical documents. The Contractor Project Manager shall ensure that all deliverables have been prepared in accordance with quality assurance standards and shall review all deliverables for adequacy, accuracy, and consistency in technical content. The Contract Project Manager shall assure that all NRC publishing requirements identified in Task 5 are met.

Technical Editing and Publishing Preparation The Contractor shall provide technical editing for all documents it develops associated with the environmental review and EIS preparation including but not limited to draft and final EIS reports, draft and final SER Chapter, requests for additional information, site visit reports, comment reports and meeting summaries.

Task 2 - Information Collection and Review Throughout Task Order Duration Contractor and NRC COR Communications The Contractor shall keep the NRC COR informed (via email, phone, or other correspondence) on at least a weekly basis, describing the information collected, reviewed, and analyzed under this task including, but not limited to, deficiencies found in XE submitted information (i.e., the license application, including the safety analysis report (SAR) and environmental report (ER), and any other supplemental information provided in support of the application); other information deficiencies; and any portions of other NEPA documents and other environmental reviews for activities at the proposed FFF site and in the vicinity of the proposed project that can be either adopted, tiered, and/or incorporated by reference into the NRCs EIS. The Contractor (anticipated to be the Project Manager, but maybe a technical reviewer as needed) may meet in person with the NRC at its offices in Rockville, Maryland when requested by the NRC COR.

Data Collection and Analysis The contractor will collect and analyze information to support the final impact conclusions in the EIS. This data collection and analysis can begin when the NRC COR initiates the review and can occur as early as the pre-application phase. The Contractors independent data collection shall include, among other available data and information sources, references cited in the applicants license application, SAR, and ER, and relevant documents found through a comprehensive search and utilization of the NRCs publicly available Agency-Wide Documents Access and Management System (ADAMS), at

5 http://www.nrc.gov/reading-rm/adams.html. Relevant documents in ADAMS may be found by the Contractor by searching, under the docket number assigned by NRC to the XE license application request. Additional information may be obtained by interactions with other Federal, State and Local entities.

As part of this information collection and review task, the NRC COR, with the assistance of the NRC safety/licensing project manager, will facilitate the Contractors coordination with the members of the NRCs safety review team for the project who are preparing the SER.

The NRC safety review team members and their contact information will be identified by the NRC COR following task order authorization. The purpose of this coordination is for Contractor and NRC safety review staff counterparts to familiarize themselves with each other, establish an understanding for initial and ongoing coordination and discussions as needed, and identify and exchange information as needed for the ongoing environmental and safety reviews. Contacts may be by phone, email, or other correspondence, as necessary and appropriate. Contacts between Contractor staff and NRC safety review staff shall be made with the knowledge of the NRC COR and the NRC safety/licensing project manager and may be arranged by the NRC COR when necessary.

In addition, as requested by the NRC COR, the Contractor shall provide support for NRC consultations, i.e., NHPA Section 106 consultation and the ESA Section 7 consultation, as well as support for NRC coordination with other Federal, State, and local agencies. This support may include identification of agencies to contact, providing supporting information/documentation for consultations/coordination, input to and review of NRC letters/emails to agencies, etc. To these ends, the Contractor shall compile a list of federal, tribal, state, and local statutes, laws, and permits that are applicable to the project, with an accompanying short description of each statue, law, or permit. Information resulting from NRCs consultations/coordination with other agencies will be provided to the Contractor for use in the EIS analyses, as well as for summary, referencing, and reproduction, as necessary, in the EIS documents. These activities and contacts may have to be updated as necessary based on the development of the EIS.

The Contractor shall collect and review information throughout the duration of the project, as necessary and as additional information may be identified or otherwise become available, to support the development and completion of the EIS and to provide support for a potential adjudicatory hearing on environmental issues. Coordination and discussions between the Contractor, the NRC COR, and the NRC safety review staff are also expected to be ongoing throughout the duration of the task order.

The Contractor shall develop and maintain a bibliographic listing of all documents collected (reports, maps, papers, data files, etc.), including ADAMS Accession Numbers or web links where applicable, and shall also maintain on file electronic copies of all collected documents. The Contractor shall include in the listing a short description of each document and an accompanying brief discussion of how the document will be used in the EIS. The bibliographic document list shall be in a format suitable for use in the EIS reference lists; and all references ultimately cited in both the EIS (cited references and maps, drawings, tables, etc.) must be already publicly available in ADAMS or elsewhere in the public record or can be made publicly available in ADAMS. The Contactor shall make the document list and electronic copies of documents, including periodic updates, available to the NRC COR upon request. The Contractor shall be responsible for obtaining and providing the NRC COR with appropriate permissions for use of any copyrighted materials and reference documents in the EIS. The contractor will develop a complete reference list and index for

6 the EIS.

Task 3 - Initial Technical Review of Application The Contractor shall conduct the Subtasks below concurrently as necessary.

Subtask 3A - Perform Acceptance Review of Application As required by the COR, the contractor shall conduct an acceptance review of the documents provided by XE in its license application. This review shall identify if there is sufficient information to perform a detailed technical review in support of the EIS preparation. The contractor shall perform this activity using guidance provided by the NRC COR and in accordance with information from NUREG-1748. The contractor shall develop Requests for Supplemental Information if the application is lacking sufficient information to allow commencement of the detailed technical review. The results of this review activity and any deficiencies shall be reported in writing to the NRC. Acceptance review of the application is complete when NRC issues acceptance letter.

Subtask 3B - Collect and Review Information After completion of the acceptance review and as the initial step in the EIS development, the Contractor shall review project-related information and shall also independently collect and review additional information related to the proposed FFF project area and its environs and to the activities proposed by XE in its license application request, as needed for preparation of the comprehensive Draft EIS. The information initially provided by the NRC COR includes XEs license application, SAR, and ER and the other documentation submitted to the NRC. The NRC COR will provide additional relevant documents to the Contractor as they become available throughout the duration of the task order. The Contractors independent data collection shall include, among other available data and information sources, references cited in the applicants license application, SAR, and ER, and relevant documents found through a comprehensive search and utilization of the NRCs publicly available Agency-Wide Documents Access and Management System (ADAMS), at http://www.nrc.gov/reading-rm/adams.html, relevant document provided by the applicant under the docket assigned to the review and information from public resources and local government entities.

Subtask 3C - Technical Review of License Application, SAR and ER and Submittal of the Initial Technical Review Report To aid in the potential development of formal requests for additional information (RAIs) to the applicant (i.e, XE), the Contractor shall also review XEs ER for completeness and acceptability in accordance with NUREG-1748, and in consideration of other available information available. In conjunction with this review, the Contractor shall also review the applicants license application and SAR to determine if any identified information deficiencies in the ER are instead addressed in those documents.

The Contractor shall provide an Initial Technical Review Report to the NRC COR. As necessary, the areas in the Initial Technical Review Report shall include, but not be limited to, the following:

purpose and need for the proposed action;

7 applicable statutory and regulatory requirements, permits, and consultations; descriptions of the proposed action and reasonable alternatives to the proposed action to be evaluated in detail in the EIS; descriptions of other alternatives considered, but eliminated, and reasons for elimination; applicable information on the affected environment and on environmental impacts of the proposed action and reasonable alternatives (in the following subject areas: site location and description, land use, transportation, geology, minerals and soils, water resources (ground water and surface water - water use and water quality), ecological resources, climatology, meteorology and air quality, climate change, noise, historic and cultural resources, visual and scenic resources, socioeconomics, public and occupational health (non-radiological and radiological), accidents, waste management, and environmental justice);

mitigation measures to avoid or minimize any potential adverse effects of the proposed action and reasonable alternatives; environmental measurement and monitoring programs; and cost-benefit analysis of the proposed action and reasonable alternatives.

The report shall include Information Needs for preparation of the site visit and scoping process. This information shall summarize the review and include a preliminary list in tabular format, by topical area, of information either not provided or not adequately provided in XEs license application, SAR, and ER (i.e., information needs) and which will be required for the preparation of the EIS and which will need to be obtained from the applicant (i.e.,

information which is not available from other available information sources). The listing shall also provide a brief discussion of the expected use of the needed information. In addition to being used in development of the RAIs, the list of information needs will be used by the NRC and the Contractor for discussion purposes with the applicant and other agencies and organizations during the site visit and information gathering meetings and discussions during the scoping and information gather stages.

The report shall also include a List of Required Consultations that includes identification of and information on any required consultations and coordination necessary with Federal, State, and local government agencies to cover permits, laws and regulations other than NEPA for which XE will need to apply or obtain, and to obtain information to complete the EIS. The report shall make use of information gathered in previous subtasks concerning applicable federal, tribal, state, and local statutes, laws, and permits.

The Contractor shall submit an updated List of Permits and Laws that is a list of federal, tribal, state, and local statutes, laws, and permits that are applicable to the project, with an accompanying short description of each statue, law, or permit. Information resulting from NRCs consultations/coordination with other agencies will be provided to the Contractor for use in the EIS analyses, as well as for summary, referencing, and reproduction, as necessary, in the EIS documents.

The report shall also include both a preliminary Statement of the Purpose and Need and a List of Alternatives. The specifics of the list of alternatives shall be included to the extent possible at the time of submittal. The contractor shall also provide an Initial EIS Outline and be prepared to discuss the proposed level of review for each of the subject areas listed in the outline.

8 Subtask 3D - EIS Scoping Activities, Site Visit, Scoping Comment Review and, Scoping Comment Review Report The Contractor shall assist the NRC staff in preparing for, organizing, and implementing the EIS scoping process. The Contractor also shall support the NRC staff in preparing for and attending the site visit and other information gathering meetings with federal, tribal, state, and local organizations, public interest groups, and members of the public.

General scoping activities would include:

Scoping Meeting(s)

The Contractor is required to attend and support the EIS in-person (or virtual if travel is not allowed due to the COVID-19 public health emergency) scoping meeting(s) for the project.

The scoping meeting(s) shall be attended by the Contractor's Project Manager and up to five (5) Contractor technical staff members (subject matter experts). The Contractor's meeting attendees shall be determined in consultation with the NRC COR in advance of the scoping meeting(s). Two (2) public scoping meetings near the proposed FFF site are anticipated to be held by the NRC during the public scoping comment period; an additional virtual webinar meeting also is possible. In addition, the Contractor may be requested by the NRC COR to provide information for and to review and provide comments on the PowerPoint (or similar format) presentation prepared by the NRC staff for the meeting(s), advertisement materials, handouts and assist the NRC staff in the preparation of anticipated questions and responses to those questions as well as other materials for the meeting(s).

Site Visit and information Gathering Meetings/Discussions The Contractor shall accompany the NRC staff on a visit of the proposed project site and vicinity as required by the NRC COR and shall conduct a detailed survey of the site and environs. The NRC COR will coordinate the site visit with the applicant. The site visit shall also include pre-arranged meetings with other Federal, State and local agencies. Meeting may also include Tribal government agencies, private sector organizations, public interest groups, and individuals, to be determined in consultation between the Contractor and the NRC COR. The duration of the site visit trip is presently anticipated to be up to five (5) days, with the trip possibly conducted during the same week as the EIS Scoping meeting(s),. In advance of the site visit and information gathering meetings, the Contractor shall provide the NRC COR with a compilation of the questions and issues that the Contractor plans to use in its survey of the site and environs, and in the meetings with the applicant and other organizations. The Contractor shall revise this compilation in response to comments from the NRC COR, if provided. The Contractor's Project Manager and up to five (5) Contractor technical staff members (subject matter experts) shall attend the site visit and related meetings. The Contractor shall coordinate with the NRC COR regarding which Contractor technical staff shall participate in the site visit and related meetings in advance of the trip. At the NRC COR's request, the Contractor shall provide necessary security information (name of individual, citizenship, etc.) of the Contractor staff that will be participating prior to the site visit.

Following the trip, the Contractor shall document the site visit and associated meetings in concise draft and final Site Visit Trip Reports. The Draft and Final Site Visit Trip Reports shall describe any relevant information that was learned, requested, or obtained from the applicant and other agencies, organizations, and individuals with which meetings were held, as well as relevant observations from the reconnaissance of the FFF project area and

9 vicinity. The final Site Trip Report shall reflect and address comments, if any, received from the NRC COR on the draft Site Trip Report.

Following the site visit, compilation of information for the EIS input may require additional contacts with and interviewing of the applicant personnel and its contractors as well as other stakeholders by the NRC and the Contractor, including, but not necessarily limited to:

Federal, State, and local resource agency staff and other government officials; Tribal government agencies; local elected officials; local economic development organizations; public interest groups; and members of the public. Any needed contacts shall be coordinated through the NRC COR, in advance. These contacts may be made in person or by email, phone, or other correspondence, as necessary. Such additional contacts may continue throughout the duration of the task order, as necessary. The Contractor shall document the additional contacts made and the information gathered in a manner that allows use as reference in the EIS.

Draft and Final Scoping Summary Reports In cooperation with the NRC COR, the Contractor shall identify, sort and bin, review, and analyze all public comments presented at the scoping meeting(s) and or otherwise provided to the NRC during the EIS scoping process (either by writing, email or regulations.gov). The Contractor shall use the comment response database on the EARRTH platform to help develop responses to the scoping comments received. The Contractor shall prepare a Draft and Final Scoping Summary Report. The Final Scoping Summary Report shall satisfy the requirements of 10 CFR § 51.29(b). Specifically, the report shall summarize the public comments received by topical area and shall present a concise summary of the determinations and conclusions reached from the EIS scoping process, including the significant issues identified. The Draft and Final Scoping Summary Reports shall be submitted to the NRC COR.

Task 4 - Development of Requests for Additional Information.

After completing scoping activities associated with development of the EIS, the Contractor shall develop Requests for Additional Information (RAIs). The RAIs will be based on the Contractors review of the XE license application, SAR, and ER; issues and concerns raised by commenters during the scoping process; the site visit and information gathering meetings; and the Contractors Initial Technical Review Report. The preparation of the RAIs shall be conducted concurrently with preparation of the Preliminary Draft EIS chapters/sections (as discussed in tasks below), such that the RAIs shall be developed in consideration of the additional information needed from the applicant to complete the EIS.

However, the RAI responses from the applicant are not expected to be available in time for inclusion in the Preliminary Draft EIS. Nevertheless, all of the Preliminary Draft EIS chapters/sections shall be as near complete and thorough as possible based on all other available data and information sources from Task 3, the site visit and information gathering meetings/discussions in Subtask 3D, and shall contain place holders for information expected in the applicants response to the RAIs.

The Contractor shall prepare draft RAIs that will be documented in a report to the NRC COR, with each RAI stating by topical area what information is sought, the basis for requesting the information (e.g., to support the analysis of potential environmental impacts),

and the expected use of the requested information in the EIS analysis. The RAIs shall be both clear and concise to elicit the necessary information from the applicant. It is noted that should XE be unable to provide certain information, the Contractor shall be able to define

10 (separate from the draft RAIs) what information could be developed by the Contractor versus information that must come from the applicant.

The NRC will review the draft RAIs and provide any comments to the Contractor, either in writing or through an electronic writing session (e.g., via webinar). The Contractor shall revise the draft RAIs to incorporate comments from the NRCs review and submit the final RAIs to the NRC COR. The NRC will transmit final RAIs to XE for response.

Following the applicants receipt of the RAIs, discussions between XE, the NRC, and the Contractor regarding the RAIs shall be conducted as necessary to respond to the applicants questions and to provide clarification.

Following the NRCs receipt and subsequent acceptance review of the applicants RAI responses, discussions by the NRC and the Contractor with XE regarding the RAI responses shall be conducted as necessary to obtain clarification of the responses.

Additionally, based on the review of XEs RAI responses, the Contractor (in coordination with the NRC) shall determine if there is still insufficient information in any areas to complete the EIS. If it is determined that additional RAIs are required, then the Contractor (in coordination with the NRC) shall identify the specific information needed in additional draft RAIs and shall provide the additional draft RAIs to the NRC COR in a letter report.

Preparation of the final additional RAIs, transmittal to the applicant, and subsequent discussions with the applicant as necessary will be conducted as for the initial round of RAIs.

OPTIONAL Subtask 4A - Second and Additional Rounds of Requests for Additional Information (RAIs)

(Option shall be exercised via a bilateral task order modification)

If the Contractor determines that the information provided by applicant (i.e., in the license application, SAR, and ER) and the information collected and reviewed during other subtasks is not sufficient to allow the Contractor to complete the EIS, the Contractor shall inform the NRC COR and subsequently, as directed by the NRC COR, prepare and provide the NRC COR with draft additional RAIs in a letter report. The NRC COR will provide the required RAI format and guidance on drafting the RAIs to the Contractor. The draft RAIs shall cover all topical areas needed to complete the EIS.

Task 5 - Plan, Develop, and Complete Draft EIS The Contractor shall continue to plan, develop, and complete a Draft EIS that will document the NRC staffs evaluation of the potential environmental impacts of the construction and operation of the FFF as proposed by XE. The EIS shall be completed in accordance with the requirements specified in following subtasks. The Contractor shall format the EIS to meet NRC standards in NUREG-0650, Preparing NUREG-Series Publications, current revision, and NUREG-1379, NRC Editorial Style Guide. Graphics for the EIS shall be prepared by the Contractor in consideration that the NRCs published hardcopy versions of the EIS documents will be printed in black and white.

Prior to submission to the NRC, the Contractor shall review all versions of the EIS for adequacy, accuracy, and consistency in technical content. In addition, reviews of the EIS shall be conducted by the Contractors technical editor. To the maximum extent possible, the EIS shall read as if written by a single author, rather than seeming to be a compilation of

11 individual articles written by multiple authors in differing styles. Additionally, the EIS shall be written in plain language, meeting the intent of NRCs plain writing philosophy, techniques, and guidance (see http://www.nrc.gov/public-involve/open/plain-writing/nrc-philosophy.html#guidance).

The Contractor shall provide a Preliminary Draft EIS that is consistent with 10 CFR Part 51 (see 10 CFR 51.70, 51.71, and 51.80) and the guidance provided in NUREG-1748.

Subtasks involved in the development and preparation of the Preliminary Draft EIS by the Contractor include (1) a site visit and additional information gathering meetings / discussions with other federal, state, local, and tribal agencies], (2) development of requests for additional information (RAIs), (3) preparation of a revised annotated EIS outline, a revised purpose and need, and a revised description of the proposed action and alternatives, and (4) preparation of all other preliminary draft chapters/sections of the EIS.

Subtask 5 A-Revised EIS Outline, Draft Chapter 1, and List of Alternatives The Contractor shall provide a Revised EIS Outline to the NRC COR to use as the basis for preparing the Preliminary Draft EIS. The Revised EIS Outline shall update the initial EIS Outline to include information reflecting (1) NRC review of the preliminary outline, (2) comments and other information from the EIS scoping process, and (3) new information from the site visit and other sources, as appropriate. The Contractor shall also provide a draft version of Chapter One and a list of alternatives incorporating any new information The NRC COR will provide comments on the task deliverables.

Subtask 5B -Preliminary Draft EIS For the proposed action and each of the reasonable alternatives described in the Revised Description of the Proposed Action and Alternatives, the Contractor shall provide an early preliminary draft of the EIS that includes: (1) a Preliminary Proposed Action & Alternatives, (2) Preliminary Purpose and Need, (3) Preliminary Affected Environment, and (4)

Preliminary Impacts on the affected environment and also the impacts for each of the resource areas. This version of the report shall provide the potential environmental impacts of normal operating conditions, including direct, indirect and cumulative impacts, as well as climate change and accident scenarios (as appropriate). Mitigation measures committed to and proposed by the applicant to avoid or minimize environmental impacts shall be identified and taken into consideration in the impact evaluation. The assessment of the impacts shall be based on the guidance provided in NUREG-1748, and shall be conducted for the following resource/impact areas, as appropriate: land use, transportation, geology, minerals and soils, water resources (groundwater and surface water - water use and water quality),

ecological resources, air quality, climate change, noise, historic and cultural resources, visual and scenic resources, socioeconomics, public and occupational health (non-radiological and radiological), accidents, waste management, and environmental justice.

In consultation with the NRC COR, the Contractor shall limit impact descriptions to those resource areas that are reasonably impacted by the proposed action or alternatives.

Additionally, the length and level of detail of the description of the impacts for each resource area shall be commensurate with the significance of the impacts to that resource area. For the impact discussion for resource areas other than environmental justice, historic and cultural resources, and threatened and endangered species, the Contractor shall make use of the impact significance levels (SMALL / MODERATE / LARGE) in Section 4.2.5.3 of NUREG-1748. The focus of the impact evaluation for those resource areas is to be on the

12 important attributes of the resource and whether the environmental effects alter and separately destabilize those attributes. For environmental justice evaluations, impacts to historic and cultural resources, and impacts to threatened and endangered species, the Contractor shall use the impact wording specific to those resources (e.g., disproportionately high and adverse impact, adversely effect, adversely affect).

The Contractor shall coordinate development of impacts from any accident scenarios with the NRC COR. If accident scenarios and their impacts, if any, are developed by NRC safety staff in preparation of the NRCs SER for the license application, they will be provided, as necessary, to the Contractor for inclusion (and modification as necessary) in the EIS. Note, however, that if the accident scenarios and impacts (if any) are not yet available for inclusion in the Preliminary Draft EIS, they will be provided by the NRC COR for inclusion by the Contractor in a subsequent version of the Draft EIS. The accident scenario and impact information included in the Draft EIS (and later in the Final EIS) must be presented in a form that can be made publicly available.

The Contractor shall also develop and provide all additional materials necessary for a complete Preliminary Draft EIS including, but not necessarily limited to: EIS introductory information; a description of the purpose and need for the proposed action; a description of the scope of the analysis in the EIS; information on applicable statutory and regulatory requirements, permits and consultations; identification of the applicants proposed mitigation strategies, if any, and identification of any additional NRC recommended mitigation measures that may be necessary to avoid or minimize the impacts, as appropriate; a description of XEs environmental measurement and monitoring programs; a cost-benefit analysis of the proposed action and alternatives; and a summary of environmental consequences. A copy of the Preliminary Draft EIS shall be transmitted securely to the NRC.

Subtask 5C - Revised Preliminary Draft EIS After receiving comments on Preliminary Draft EIS from the NRC staff, the Contractor shall prepare and provide the NRC COR with a Revised Preliminary Draft EIS in accordance with the NRC's technical and publication guidance, the NRC-approved Revised Annotated EIS Outline, and NRC staff comments. A copy of the Revised Preliminary Draft EIS also shall be transmitted securely to the NRC.

Subtask 5D - Writing Session for the Draft EIS The NRC will conduct a writing session of up to five (5) days in length with the Contractor on the Revised Preliminary Draft EIS. This writing session shall take place either at the NRC Headquarters offices in Rockville, MD or at the Contractors office. The purpose of the writing session shall be for the NRC to present its comments on the Preliminary Draft EIS and to provide clarification of the comments, as needed. The Contractor shall make available staff involved in the preparation of the Preliminary Draft EIS to take part in the writing session, either in person or by telephone or other appropriate medium. The writing session agenda and schedule shall be determined in consultation with the NRC COR in advance of the meeting.

13 Subtask 5E - Prepare Draft EIS (Concurrence Version)

The Contractor shall revise the Preliminary Draft EIS consistent with (1) NRC comments received at the Preliminary Draft EIS writing session, (2) NRC resolution of any cooperating agency comments (if there are one or more agencies cooperating with the NRC in the preparation of the EIS), and (3) the applicants RAI responses. This concurrence version of the Draft EIS shall be securely transmitted to the NRC COR... Versions of this working copy of the draft report maybe be transmitted between the NRC reviewers and the contractor as agreed upon to meet the final schedule for publication of the draft EIS.

Subtask 5F -Final Draft EIS - (Publication Ready Version)

The Contractor shall incorporate comments from the Draft EIS (concurrence version) and writing session to produce the final Draft EIS. The Contractor will work with the COR to address any open item or unresolved issues prior to submitting the final Draft EIS. The Contractor shall securely submit this final Draft EIS to the NRC COR.

As directed by the NRC COR, the Contractor shall incorporate any comments generated during the NRC and cooperating agency (if any) internal and legal review of the Draft EIS.

During this time, to facilitate the review process and expedite subsequent revision of the Draft EIS, the Contractor shall assist in promptly addressing and responding to NRC and cooperating agency management, legal, and technical reviewer comments, as requested by the NRC COR. Within two (2) business days of the NRC CORs direction (or longer at the NRC CORs discretion), the Contractor shall securely transmit a revised final Draft EIS that addresses the comments received and notify the NRC COR. Subsequently, there may be up to two (2) additional versions of the revised final Draft EIS requested from the Contractor by the NRC COR, with each of these two versions incorporating additional revisions that are presently anticipated to be relatively minor and editorial in nature. Each of these additional versions shall be transmitted on a secure server by the Contractor within one (1) business day of receiving direction from the NRC COR (or longer at the NRC CORs discretion).

Following the resolution of comments received during the pre-Draft EIS issuance document review and concurrence periods, the Contractor shall submit a publication-ready version of the Draft EIS to the NRC COR. The publication ready version of the report should be complete with all changes, updates, hyperlinks, figures and tables complete and in a format identified by the NRC publication guidance documents and COR direction.

Subtask 5G - Review Supplemental Information and Develop a Revised Preliminary Draft EIS - Revision 1 The Contractor shall evaluate a supplement to the application and determine whether the proposed changes to the facility will impact all or some of the resource areas. After evaluating the changes, the contractor shall evaluate the environmental impacts. The contractor shall update the Preliminary Draft EIS Revision 0 with the new characteristics of the affected environment and the impacts to the resource areas. The results of the impact evaluation shall be included in an updated Preliminary Draft EIS Revision 1. The contractor shall also determine if additional consultation would be required. Upon completion of task 5G, the Contractor shall continue supporting development of the Final Draft EIS starting with Subtask 5E of this Statement of Work.

After receipt of a license application supplement environmental report, the Contractor shall complete the following activities under Subtask 5G:

14 5G1 - Initial Review and Evaluation of Supplement to License Application The Contractor shall review the supplemental information for adequacy, accuracy, and consistency in technical content and to determine if there is sufficient information to perform a detailed technical review. The Contractor shall review and evaluate new information for potential changes to environment impacts to the Preliminary Draft EIS Revision 0 and sufficiency to be used in a Preliminary Draft EIS Revision 1 that is consistent with 10 CFR Part 51 (see 10 CFR 51.70, 51.71, and 51.80) and the guidance provided in NUREG-1748.

After review of the supplement to the application, the Contractor shall prepare and submit a summary report of the revisions to the application and initial assessment of potential impacts to all resource areas and identify any deficiencies.

5G2 - Determination on Additional Consultation Activities The Contractor shall evaluate supplemental information and determine if any additional consultation activities are necessary. The determination shall be provided to NRC in an email.

The communication should state whether additional consultation with the FWS is necessary and provide specific details of the additional activities required. If additional consultation is necessary, the Contractor shall prepare and provide an updated consultation letter to the FWS explaining any changes and effects and requesting concurrence.

5G3 - Update the Affected Environment in the Preliminary Draft EIS Revision 0 All resource areas that are affected by the supplemental information will be updated to reflect the changes. This includes the introductory Chapters 1 and 2 and the affected environment for the environmental resources in Chapter 3.

The Contractor shall prepare and provide the NRC staff with Preliminary Updated Chapters 1, 2 and 3 (affected environment) based on the supplementary information from the applicant.

These chapters will be reviewed by NRC staff and may be passed back with comments which shall be addressed and resolved by the Contractor. The Contractor shall provide a Revised Preliminary Updated Chapters 1, 2 and 3 (affected environment). These sections will ultimately be used in the Preliminary Draft EIS Revision 1.

5G 4 - Evaluate Direct, Indirect, and Cumulative Environmental Impacts to Each Resource Area Based on changes to the application from the supplement, the Contractor shall evaluate direct, indirect, and cumulative environmental impacts to each resource area. The Contractor shall prepare and provide an initial version of the environmental impacts evaluation with holes based on RAIs. The specific changes to Chapter 3 will be prepared and provided in a Preliminary Updated Chapter 3 for NRC staff review. The revised chapter will be reviewed by NRC staff and may be passed back with comments which shall be addressed and resolved by the Contractor. The Contractor shall provide a Revised Preliminary Updated Chapter 3. This Section will ultimately be used in the Preliminary Draft EIS Revision 1.

15 5G5 - Develop RAIs and Review Responses The Contractor shall develop RAIs. The RAIs will be based on the Contractors review of the license application supplement, and ER supplement, as applicable. The preparation of the RAIs shall be conducted concurrently with preparation of the Preliminary Draft EIS Revision 1 and preliminary chapter development. Any information that is requested will be updated in the preliminary chapter updates and ultimately in the Preliminary Draft EIS Revision 1 when made available. The NRC will review the draft RAIs and provide any comments to the Contractor.

The Contractor shall revise the draft RAIs to incorporate comments from the NRCs review and submit the final RAIs to the NRC COR. The NRC will transmit final RAIs to XE for response.

Following the applicants receipt of the RAIs, discussions between XE, the NRC, and the Contractor regarding the RAIs may be conducted as necessary to respond to the applicants questions and to provide clarification. Following the NRCs receipt and subsequent acceptance review of the applicants RAI responses, discussions by the NRC and the Contractor with XE may occur regarding the RAI responses as necessary to obtain clarification of the responses.

The contractor shall review RAI responses for adequacy to complete the EIS. The Contractor shall inform the NRC staff in writing if the RAI responses are acceptable.

5G6 - Complete Revised Preliminary Draft EIS Revision 1 Upon completion of the review of the supplement and the changes to impacts based on the additional information and RAI responses, the Contractor shall prepare and provide a Preliminary Draft EIS Revision 1 for NRC staff review and comment. The contractor shall review NRC staff comments and update the Preliminary Draft EIS Revision 1 to incorporate the comments. All additional references shall be updated to make a complete EIS document.

TASK 6 - Post Draft EIS Publication Activities The contractor shall revise the Draft EIS to incorporate comments from federal state and public and the NRC review to produce the final EIS. The contractor shall submit the final EIS to the NRC COR as indicated below. Specific subtasks include:

Subtask 6A - Support for Draft EIS public comment meetings The Contractor is required to attend and support the Draft EIS public comment meeting(s) for the project. The Draft EIS public meeting(s) shall be attended by the Contractors Project Manager and up to five (5) Contractor technical staff members (subject matter experts). The Contractors meeting attendees shall be determined in consultation with the NRC COR in advance of the scoping meeting(s). The NRC anticipates holding one virtual and two (2) in-

16 person public meetings in the project area after publishing the draft EIS and before the final EIS during the public comment period and will require a one-week trip to the project site area.

In addition, the Contractor may be requested by the NRC COR to provide information for and to review and provide comments on the PowerPoint (or similar format) presentation prepared by the NRC staff for the meeting(s), and to assist the NRC staff in the preparation of anticipated questions and responses to those questions as well as other materials for the meeting(s).

Subtask 6B - Compilation of Comments (Comment Binning)

The contractor shall identify individual comments on the Draft EIS made during the comment period from all comment gathering platforms (i.e., regular mail, www.regulations.gov website, email and meetings transcripts) and organize (i.e., bin) the comments according to topic area. This activity shall be in coordination with the NRC Comment Response Database on the EARRTH platform. Currently, the NRC (estimates the number of comments identified at less than or equal to 100 comments, according to the guidelines provided to the NRC COR. The NRC COR will review and approve the binning of the comments prior to the contractor developing the comment responses. The Contractor may have to revise the binning of the comments based on NRC CORs feedback. The NRC expects that some comments will be submitted to the NRC prior to the end of the public comment period on the Draft EIS. Therefore, the contractor shall begin this subtask upon receipt of the first set of comment submittals, which will be provided to the contractor by the NRC COR. The comments shall be binned within 14 calendar days of receiving the final set of comment submittals from the NRC COR. The contractor shall submit the binned comments database report to the NRC COR.

Subtask 6C - Comment Response Report The Contractor shall prepare a Draft Comment Response Report that provides responses to the comments made on the Draft EIS. The Contractor shall revise the comment response report in response to the NRCs review and produce the final comment response report.

The Contractor shall submit the Final Comment Response Report to the NRC COR.

Optional Subtask 6D - Significant Comments Received on Draft EIS In the event that significantly larger numbers of comment submissions are received (>100 comments) and the level of effort is exceeded for responding to these comments, the contractor shall provide the same level of detailed response for Subtask 6B and shall update the report in Subtask 6C to include additional comments. If comments require additional analysis and/or significant revision to the draft EIS, the contractor shall update the COR and get direction.

17 TASK 7 -Develop and Complete the Final EIS The contractor shall finalize the EIS based on additional information and comments from the NRC staff, public and federal agencies.

Subtask 7A - Preliminary Final EIS Based on addition information obtained since the publication of the draft EIS and public comments, the contractor shall revise the draft EIS by incorporating necessary documentation regarding consultations over Section 7 of Endangered Species Act (ESA) and Section 106 of NHPA, and in response to public comments, as needed, based on developed responses under Task 6. The revised draft EIS now called the Preliminary Final EIS shall be reviewed by a technical editor formatted to NRC standards and reviewed for technical content. The Preliminary Final EIS shall be submitted to the NRC COR. A writing session may be required after NRC staff have reviewed the Preliminary Final EIS deliverable.

Subtask 7B - Writing Session for Preliminary Final EIS The NRC may conduct a writing session of up to five (5) days in length with the Contractor on the Preliminary Final EIS. This writing session may take place either at the NRC Headquarters offices in Rockville, MD or at the Contractors office. The purpose of the writing session would be to discuss and resolve the NRC comments on the Preliminary Final EIS. The Contractor shall make available staff involved in the preparation of the Preliminary Draft EIS to take part in the writing session, either in person or by telephone or other appropriate medium. The writing session agenda and schedule will be determined in consultation with the NRC COR in advance of the meeting.

Subtask 7C - Final EIS The Contractor shall revise the preliminary final EIS in response to NRCs review comments received from the NRC COR. This final EIS shall be submitted to the NRC COR. Reports shall be transmitted securely and, in a format, directed by the NRC COR which could include Word and Adobe formats.

As directed by the NRC COR, the Contractor shall incorporate any comments generated during the NRC and cooperating agency (if any) internal and legal review of the Draft Final EIS. During this time, to facilitate the review process and expedite subsequent revision of the Draft Final EIS, the Contractor shall assist in promptly addressing and responding to NRC and cooperating agency management, legal, and technical reviewer comments, as requested by the NRC COR.

The Contractor shall submit a publication-ready version of the Draft Final EIS to the NRC COR. The publication ready version of the report shall be complete with all changes, updates, hyperlinks, figures and table complete and in a format identified by the NRC publication guidance documents and COR direction.

18 Task 8 - Hearing Support It is presently anticipated that petitioners may submit written contentions on the XE license application and/or NRCs proposed licensing action for consideration by the NRCs Atomic Safety Licensing Board (ASLB). If the ASLB grants standing to any of the petitioners and admits any of the proffered contentions, the ASLB will hold a contested hearing held on the project. If needed and as directed by the NRC COR, the Contractor shall support the NRC staff by reviewing the submitted contentions on environmental issues and providing written responses (including copies of reference materials, as necessary) to these contentions, as well as other written materials in response to interrogatories from the ASLB on the contentions and related matters, as required. If needed and as requested by the NRC COR, the Contractor shall also review and provide written comments on any written materials submitted by the applicant and other parties relevant to the submitted contentions. It shall be assumed that up to ten (10) contentions on environmental issues will be submitted by petitioners.

Task 9 - NHPA SECTION 106 REVIEW As needed, the Contractor shall coordinate meetings, site visits, and communication between all parties (Tribes, Tribal Historic Preservation Offices [THPOs], Tennessee State Historic Preservation Office [SHPO], NRC, the Advisory Council on Historic Preservation

[ACHP], etc).

Subtask 9A - Assistance with Section 106 Activities The Contractor shall plan, coordinate, and conduct activities relating to the NHPA Section 106 review, as needed and in consultation with the NRC COR. The schedule and timing of the consultation activities, review, and required findings shall be coordinated with the schedule of the NEPA review so that the Section 106 process, to the extent possible, is completed along with the NEPA review. That is, the NEPA and Section 106 reviews shall be coordinated together to leverage site visits, information gathering meetings, public involvement, among other opportunities, as appropriate.

Activities to be completed by the Contractor may include:

Conducting research, sharing expertise, and providing technical assistance to the NRC COR; Assisting with development, delineation and graphical representation for the Areas of Potential Effect; Participating in discussions with NRC experts as well as with the ACHP and the Licensees consultants to resolve conflicts and to help move the Section 106 process along; and Review of application and other documents that support the licensing action and provide feedback to COR.

The Contractor shall:

Develop reports and recommendations complying with SHPO guidelines for cultural reports; Participate in discussions with NRC and stakeholders to facilitate the Section 106 consultation process; Interact with all Tribes involved, as established by the NRC, and ensure adequate communication is maintained between all parties; and

19 Provide final reports and documentation for concurrence of finding with the SHPO.

OPTIONAL Subtask 9B - Tribal Meetings Deleted per Modification P00006 OPTIONAL Subtask 9C - Ethnographic Study Deleted per Modification P00008 OPTIONAL Subtask 9D - Traditional Cultural Property Survey Report Deleted per Modification P00008 OPTIONAL Subtask 9E - Additional Support to Conduct Required Analysis Deleted per Modification P00008 TASK 10 - Development Safety Evaluation Report Chapter - Environmental Protection The Contractor will evaluate the application material for requirements associated with the environmental protection for the NRC Safety Evaluation Report. This activity includes reviewing relevant information and application materials, developing RAIs and reviewing RAI responses and producing a draft and final version of the SER chapter. These activities will be completed in accordance with the staffs guidance in NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications.

The Contractor will evaluate any changes to the Draft Safety Evaluation Report (SER)

Chapter 9 due to the supplement to the application. Upon receipt of the supplement, the Contractor will review information, develop supplemental RAIs, review RAI responses, and prepare an updated Draft SER Chapter 9 that incorporates the analyses of the application supplement. The Contractor will prepare a Final Draft SER Chapter 9 that incorporates NRC comments. The Contractor will support the final concurrence process for the safety evaluation report through license issuance by addressing NRC comments and updating the Final Draft SER Chapter 9. Support for the final concurrence process is expected to be required through March 2026.

TASK 11 - New and Significant Evaluation The Contractor, after publication of the final EIS and prior to NRCs final licensing action, will review any changes to the environmental resources and evaluate any changes to the final EIS impact analysis. The Contractor will prepare a Technical Letter Report explaining the new information, significant information, and related changes to the FEIS impact evaluations.

5.

APPICABLE DOCUMENTS AND STANARDS The documents listed below are relevant to the requirement and shall be used by the Contractor in the performance of the task order. The documents are publicly available and may be obtained by the Contractor from ADAMS or will be provided by the NRC COR. The NRC COR will continue to identify and provide necessary documents to the Contractor as

20 they become available throughout the period of performance of this task order.

The Contractor shall be familiar with and shall rely upon the most current version of the following documents in the performance of this effort:

XEs license application, SAR, and ER XEs responses to RAIs and any other supplemental information provided by XE NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs Guidance documents related to NEPA and consultation activities NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications NUREG-1379, "NRC Editorial style Guide" NUREG-0650, "Preparing NUREG-Series Publications"

6. DELIVERABLES AND DELIVERY SCHEDULE The presently anticipated schedule for deliverables/milestones required under this task order is identified in Table 1 below. All deliverables shall be provided electronically to the NRC COR in MS Word format. The MS Word documents shall be saved such that they are compatible with previous MS Word versions. In addition, certain deliverables (primarily the final and revised final versions of the Draft EIS, but others if requested) shall also be provided electronically in PDF format, upon request from the NRC COR.

Table 1. Deliverable/Milestone Schedule Task Subtask Deliverable/Milestone Anticipated Schedule 1

Project Manager Detailed Project Schedule in MS Project Provided to NRC COR upon request 2

Pre-application Information Provide to NRC COR upon request 2

Bibliographic listing of all documents collected and file of electronic copies.

Permissions for use of copyrighted materials and reference documents Provided to NRC COR as needed 2

List of federal, tribal, state, and local statutes, laws, and permits that are applicable to the project As directed by NRC COR 3

A Acceptance Review Report and Request for Supplemental Information (if necessary) 30 days after receipt of the application B

Collect and Review Information No deliverable C

Initial Technical Review Report to include:

information needs, list of required consultations list of permits and laws initial EIS outline materials and information for focused information meetings with local government and public organizations, Statement of Purpose and Need and List of Alternatives 30 days after NRC Acceptance of the Application D

Scoping Meeting materials and preparations 14 days prior to scoping meeting and site visit trip

21 D

Compilation of questions and issues for focused scoping meetings (information needs) and site sit 14 days prior to scoping meeting and site visit trip Draft and Final Site Visit Trip Reports Draft: 7 days after site visit Final: 7 days after receipt of comments from NRC COR D

Draft Scoping Summary Report (include Scoping Comment Response Report) 45 days after scoping meetings D

Final Scoping Summary Report Within 14 days from receipt of the last comments from the NRC COR on the draft scooping summary report Interim versions of the Scoping Summary Report As directed by the NRC COR 4

Draft and Final RAIs Draft: 30 days from end of site visit Final: 45 days from end of the site visit Interim versions of the Draft and final RAIs As directed by the NRC COR 4

(Optional)

A Second and Additional Rounds of RAIs As directed by the NRC COR 5

A Revised EIS Outline, Draft Chapter 1 and List of Alternatives As directed by NRC COR B

Draft Description of Affected Environment and Environmental Impacts 60 days after conclusion of site visit B

Preliminary Draft EIS (for internal review) 120 days after conclusion of site visit trip C

Revised Preliminary Draft EIS As directed by NRC COR E

Draft EIS (Concurrence Version) 14 days from the receipt of NRCs final comments and resolution of comments from cooperating agencies (if applicable) on Preliminary Draft EIS F

Final Draft EIS (Publication Ready Version) 7 days after staff publication review Interim versions of the EIS As directed by NRC COR G1 License Application Supplement Summary Report Within 14 days of receipt of the supplement or as directed by NRC COR G2 Additional Consultation Recommendation Updated Consultation Letter to FWS, if applicable Within 20 days after receipt of the supplement or as directed by NRC COR Within 30 days after receipt of the supplement or within 10 days of receipt of RAI responses.

G3 Preliminary Updated Chapters 1, 2, and 3 (affected environment)

Revised Preliminary Updated Chapters 1, 2, and 3 (affected environment)

Within 45 days after receipt of the supplement or as directed by NRC COR With 10 Days of receiving comments from the NRC COR or as directed by NRC COR G4 Preliminary Updated Chapter 3 (Impacts)

Revised Preliminary Updated Chapter 3 (Impacts)

Within 45 days after receipt of the supplement or as directed by NRC COR With 10 Days of receiving comments from the NRC COR or as directed by NRC COR

22 G5 Draft Requests for Additional Information (RAIs)

Final RAIs (if applicable)

Evaluation of RAI responses Within 45 days after receipt of the supplement or as directed by NRC COR With 10 Days of receiving comments from the NRC COR or as directed by NRC COR Within 5 days after receipt of RAI responses or as directed by NRC COR G6 Revised Preliminary Draft EIS Revision 1(for internal review)

Within 100 days after receipt of the supplement to the application or as directed by the NRC COR Interim versions of the Preliminary Draft EIS Revision 1 As directed by NRC COR 6

B Draft EIS comment binning database report.

Within 14 days of closing of the comment period and final comment transmittal A

Materials in support of Draft EIS public meetings At least 14 days in advance of scheduled meetings C

Draft comment Response Report Within 30 days of end of comment period C

Final Comment Response report Within 5 days of NRC comments Interim versions of draft Comment Response report As directed by NRC COR 7

A Preliminary Final EIS Within 90 days of end of comment period B

Working version EIS As directed by NRC COR C

Final EIS Publication version Within 150 days of end of comment period Interim versions of the Final EIS As directed by the NRC COR 8

Hearing Support (Reponses and/or Comments_

As directed by NRC COR (based on direction from ASLBP) 9 A

Summary Reports of Section 106 Consultation Activities As needed, with schedule to be agreed to between NRC COR and Contractor (Optional)

C Deleted per Modification P00008 (Optional)

D Deleted per Modification P00008 10 Environmental Protection Chapter in Safety Evaluation Report RAIs: As directed by NRC COR Draft Chapter: As directed by NRC COR Final Chapter: As directed by NRC COR Supplement RAIs: March 1, 2025, or as directed by NRC COR Updated Draft SER Chapter 9:

March 1, 2025, or as directed by NRC COR Final SER Chapter 9: July 1, 2025, or as directed by NRC COR Continued support for concurrence

23 process - through March 2026 11 New and Significant Technical Report As directed by NRC COR (Approximately 6 months after publication of the Final EIS)

All Monthly Letter Status Report NLT 20th calendar day of the following Month Note: All days are calendar days unless otherwise specified.

7. REPORTING REQUIRMENTS Monthly Letter Status Report (MLSR)

The contractor shall provide a Monthly Letter Status Report in accordance with the base contract which consists of a technical progress report and financial status report by the 20th day of the following month. This report will be used by the Government to assess the adequacy of the resources proposed by the contractor to accomplish the work contained in this SOW and provide status of contractor progress in achieving activities and producing deliverables. The report shall include order summary information, work completed during the specified period, milestone schedule information, problem resolution, travel plans, and staff hour summary. If no work was performed during the prior month, the contractor shall not prepare and submit an MLSR.

25 10 years of technical experience in conducting environmental reviews in one or more of the specific technical areas assigned to complete the environmental review including:

Land Use Transportation Geology/seismology, minerals and soils water resources (groundwater and surface water) ecological resources climatology, meteorology and air quality, climate change noise historic and cultural resources visual and scenic resources socioeconomics public and occupational health (non-radiological and radiological),

accidents waste management environmental justice cumulative impacts assessment mitigation measures environmental measurements and monitoring Staff working on NHPA 106 Reviews must meet the professional standards under the regulations developed by the Secretary (see 36 CFR 800.2(a)(1))

Experience presenting technical information both oral and written Desired but not Required Qualifications Experience providing written and oral testimony at adjudicatory hearings

• Sr. Technical Reviewer Minimum Qualifications Bachelors Degree in Engineering or Science Substantial understanding of the depth of review generally required for preparing an EIS and an SER chapter on environmental protection and monitoring, and specifically for the technical areas assigned to evaluate.

5 years of technical experience in conducting environmental reviews in one or more of the specific technical areas assigned to complete the environmental review including:

Land Use Transportation Geology/seismology, minerals and soils water resources (groundwater and surface water) ecological resources climatology, meteorology and air quality, climate change noise historic and cultural resources

26 visual and scenic resources socioeconomics public and occupational health (non-radiological and radiological),

accidents waste management environmental justice cumulative impacts assessment mitigation measures environmental measurements and monitoring Staff working on NHPA 106 Reviews must meet the professional standards under the regulations developed by the Secretary (see 36 CFR 800.2(a)(1))

Experience presenting technical information both oral and written Desired but not Required Qualifications Experience providing written and oral testimony at adjudicatory hearings

• Technical Reviewer Minimum Qualifications Bachelors Degree in Engineering or Science Understanding of the depth of review generally required for preparing an EIS and an SER chapter on environmental protection and monitoring, and specifically for the technical areas assigned to evaluate.

3 years of technical experience in conducting environmental reviews in one or more of the specific technical areas assigned to complete the environmental review including:

Land Use Transportation Geology/seismology, minerals and soils water resources (groundwater and surface water) ecological resources climatology, meteorology and air quality, climate change noise historic and cultural resources visual and scenic resources socioeconomics public and occupational health (non-radiological and radiological),

accidents waste management environmental justice cumulative impacts assessment mitigation measures environmental measurements and monitoring Staff working on NHPA 106 Reviews must meet the professional standards under the regulations developed by the Secretary (see 36 CFR 800.2(a)(1))

Experience presenting technical information both oral and written

27 Desired but not Required Qualifications Experience providing written and oral testimony at adjudicatory hearings Technical Editor/Publication Support Minimum Qualifications Bachelor of Science or Bachelor of Arts Understanding of the NRCs publication and editorial requirements 5 years of experience in technical editing The Contractor shall ensure that the technical staff performing under this task order possess the necessary experience and expertise in the technical areas assigned to them.

• The NRC requires that technical team of Sr. Technical Staff/SME, Sr. Technical Reviewer, and Technical Reviewer as a whole meets all the specific technical areas listed above.

9. GOVERNMENT-FURNISHED PROPERTY The COR will facilitate the Contractors access to PNNLs EARRTH SharePoint site. The Comment Response Database is also found on the EARRTH website.

10. PERIOD OF PERFROMANCE The period of performance for this task order is September 30, 2021 through March 31, 2026.

11. PLACE OF PERFORMANCE Except as otherwise indicated in Section 4 and Section 12.1 of this SOW, the work shall be performed at the Contractors facilities.

12. SPECIAL CONSIDERATIONS 12.1 Travel The contractor shall be authorized and reimbursed for travel expenses consistent with the Federal Travel Regulation (FTR) and the limitation of funds for this task order. All travel requires prior written COR approval. Meetings and other activities that may require Contractor travel are summarized in Table 2 below. At the NRC CORs discretion, some of these meetings may be held in the form of teleconferences or webinars or at the contractors site.

28 Table 2. Meetings and Travel Task Purpose Location Number of Trips Days per Trip Contractor Staff Members per Trip 2

Quarterly Progress Meetings and Pre-application activities (as needed and requested by NRC COR)

Rockville, MD or XE site vicinity 8

3 1

4 RAI Meetings Rockville, MD 1

2 3D Scoping public meetings and site visit XE site vicinity 1

5 5

5D Revised Preliminary Draft EIS Writing Session Rockville, MD 1

5 2

6A Draft EIS comment public meetings XE site vicinity 1

5 5

7B Preliminary Final EIS (Writing Session)

Rockville, MD 1

5 2

8 Hearing Preparation (as needed and requested by NRC COR)

Rockville, MD 1

4 2

9C Optional Deleted per Modification P00008 9C Optional Deleted per Modification P00008 12.2 Security Work on this task order will involve the handling of documents that contain proprietary information. The contractor shall safeguard documents containing proprietary information against unauthorized disclosure. After completion of work, the contractor must either destroy the documents or return them to the NRC. If they are destroyed, please confirm this in an e-mail to the COR with a copy to the CO and include the date and manner in which the documents were destroyed.

12.3 License Fee Recovery The EIS preparation work and the NHPA Section 106 work are fee-recoverable.

The Hearing Support work is not fee-recoverable.

12.4 Data Rights The NRC shall have unlimited rights to and ownership of all deliverables provided under this contract/order, including reports, recommendations, briefings, work plans and all other deliverables. All documents and materials, to include the source codes of any software, produced under this contract/order are the property of the Government with all rights and privileges of ownership/copyright belonging exclusively to the Government. These

29 documents and materials may not be used or sold by the contractor without written authorization from the CO. All materials supplied to the Government shall be the sole property of the Government and may not be used for any other purpose. This right does not abrogate any other Government rights. The definition of unlimited rights is contained in Federal Acquisition Regulation (FAR) 27.401, Definitions. FAR clause at FAR 52.227-14, Rights in Data-General, is hereby incorporated by reference and made a part of this contract/order.

12.5 Quality Control Program The Contractors approach to quality control shall focus on project management and document production processes and tools that assure the quality of the deliverables and integrity of the environmental review process.

The Contractors project manager will serve as the focal point for coordinating the project activities and will be responsible for assuring the timely and high-quality submittal of deliverables. All information shall be accurate and complete. The project management responsibilities include verifying quality requirements and deliverables specifications, responding satisfactorily and in a timely manner to feedback, and continuously improving products and services by communicating to the necessary personnel and applying lessons learned. The Contractors project manager shall also ensure that scientific and technical reports are developed in accordance with established practices for publishing scientific and technical information.

Project deliverables will be reviewed by someone other than the project manager to ensure that they are technically accurate and complete.

Document version control is critical to the document production process. The Contractor shall ensure that previous versions are kept so the Contractor will be able to return to any earlier version of a document and be able to track the changes and the basis for those changes.

12.6 Key Personnel Refer to Section H - KEY PERSONNEL. (JAN 1993)