ML24285A043
| ML24285A043 | |
| Person / Time | |
|---|---|
| Issue date: | 10/01/2025 |
| From: | O'Hara J NRC/NMSS/DREFS/EPMB3 |
| To: | TerraPower |
| References | |
| Download: ML24285A043 (13) | |
Text
BATCH #1 TerraPower Summary of Information Needs Info Need ID Information Need Environmental Report (ER)
Section Subject Matter Expert (SME)
Site and Technical Overview No site and technical overview information needs at this time.
Cumulative Impacts CMLT-1 Per ISG-26, Attachment 4, Does the application include a discussion of the time frames for past, present, and reasonably foreseeable actions? Time frames are not addressed in Chapter 7 of the ERs discussion of past, present, and reasonably foreseeable future projects. Please provide.
Chapter 7 Dave Goodman CMLT-2 Please provide an update on the status of any of the cumulative projects identified in Chapter 7 of the ER.
Chapter 7 Dave Goodman Land Use and Visual Resources LU-1 Section 4.1.1 of the ER states that Section 2.1 of the ER notes the zoning of the site as industrial; however, this is not stated in Section 2.1. Please confirm the zoning of the site.
2.1.1.2 Dave Goodman LU-2 ESRP 2.2.1 requires that the U.S. Nuclear Regulatory Commission (NRC) indicate whether any lands or leased and to whom, for how long, and for what purpose. Section 2.1.1.1 of the ER states that US Sodium Fast Reactor Owner LLC acquired mineral rights within the site. However, the owner of the surface estate is unclear.
Please confirm surface ownership.
2.1.1.1 Dave Goodman LU-3 ESRP 2.2.1 requires that the NRC identify egress limitations from the area surrounding the site. This information is not available in the ER. Please identify such limitations, if they exist.
2.1.1.1 Dave Goodman
2 Info Need ID Information Need Environmental Report (ER)
Section Subject Matter Expert (SME)
LU-4 ESRP 2.2.1 requires that the NRC identify prime farmland, unique farmland, and farmland of national or statewide importance on the site. However, these resources are not discussed in the ER. Please address.
2.1.1.1 Dave Goodman LU-5 ESRP 2.2.3 requires that the NRC identify principal agricultural products of the region, including commercial forest products. This is not discussed in the ER. Please include such information.
N/A Dave Goodman LU-6 Per ESRP 4.1.1, Has the applicant provided an overlay of the proposed construction footprint over the land use maps produced for ESRP 2.2.1? Does the overlay distinguish between permanent versus temporary elements? No overlay of the construction permit (CP) has been included in the ER. Please provide.
N/A Dave Goodman LU-7 Per ESRP 5.1.1, Depending on the site and the level of applicable demographic research, land-use impacts could be projected to result from demand for new housing of operations workers. Only in rare cases would it be expected that enough research would be available to predict the degree that new housing would have land-use impacts in the vicinity. The applicant should acknowledge the operations impact on housing and similar impacts that may occur from outage operations. Section 4.4.2 of the ER describes demographic impacts, such does not tie such impacts back to land use impacts. Please provide such information.
4.4.2 Dave Goodman Air Quality and Noise AQN-1 Per ESRP 2.7 A description of the regional air quality, including nonattainment or maintenance areas. Most NAAQS pollutants are discussed and characterized in the ER. PM-2.5 is not. Please provide a description of PM-2.5 emissions from construction, operation and decommissioning. Please provide background and/or regional PM-2.5 concentrations. Also please include any additional relevant PM-2.5 information.
2.7.2 Brad Fritz
3 Info Need ID Information Need Environmental Report (ER)
Section Subject Matter Expert (SME)
Water Resources and Hydrology HYD-01 ESRP 2.3.1 and 2.3.2 require maps of sufficient detail to show the relationship of the site to major hydrological systems that could affect or be affected by plant construction or operation. ESRP 5.2.1 requires identification and description of hydrological alterations resulting from the identified operational activities. ESRP 5.2.2.
requires a description of potential impacts to groundwater uses from plant-related operational activities. Section 2.5.3 of the preliminary safety analysis report (PSAR) identified groundwater surface water interactions along streams and river channels, but this potential interaction between the cooling water source stream and potentially affected groundwater was not discussed in the ER. Provide a description of the potential impacts of cooling water withdrawal due to surface water - groundwater interactions on the alluvial aquifer system.
2.2 Phil Meyer / Rajiv Prasad HYD-02 ESRP 2.3.3 requires a description of temporal and spatial variations of surface and groundwater-quality characteristics. Section 2.2 of the ER presents limited groundwater quality and surface water results. At minimum, provide a year of quarterly sampling for evaluating potential impacts to the environment that may result from construction or operation.
2.2 Phil Meyer / Rajiv Prasad HYD-03 ESRP 6.3 and 6.6 require a list of data describing hydrological monitoring, including monitoring locations, frequency, equipment, data analysis procedures, data quality objectives, and aspects related to chemical sampling of water systems. Provide a description of planned groundwater monitoring and surface water monitoring during operations, including water quality parameters, frequencies, types, methods, and other aspects related to monitoring.
4.2.4; 5.2.4 Phil Meyer / Rajiv Prasad
4 Info Need ID Information Need Environmental Report (ER)
Section Subject Matter Expert (SME)
HYD-04 ER Sections 1.1.4 and 2.2.1.1.8 describe the reactor cooling system and the plant cooling water source, respectively. Provide a description of normal and ultimate heat sinks for the proposed plant.
Provide a detailed description of water used for cooling purposes for the proposed plant. Provide a description of thermal discharge to any waterbodies.
1.1.4; 2.2.1.1.8 Rajiv Prasad HYD-05 ER Section 2.2.1.1.1 states that stream and reservoir water levels for Hams Fork River are discussed in PSAR Section 2.5.4. PSAR Section 2.5.4 cites PSAR Reference 2.5-102 for flows and withdrawals for the Naughton Plant. Provide PSAR Reference 2.5-102 for review.
2.2.1.1.1 Rajiv Prasad HYD-06 ER Section 2.2.3.1.3 states that surface water quality sampling is planned to occur July 2024 through July 2026. Provide an update on the status of this sampling plan including locations of sampling, water quality parameters, sampling methods, and sampling frequencies.
2.2.3.1.3 Rajiv Prasad HYD-07 ER Table 2.2-7 uses average monthly Hams Fork discharge from Viva Naughton Reservoir based on 1995-2021 reservoir outflow data. Provide an update to this data for more recent years, if available.
2.2.2.1.5 Rajiv Prasad HYD-08 Provide PacifiCorp Permit #22297 for review.
Rajiv Prasad HYD-09 Provide greater quality ER Figures 3.1-3, 3.1-4, 3.2-1, and 3.2-2.
3.1, 3.2 Rajiv Prasad HYD-10 Provide a description of post-construction groundwater-surface water interaction.
5.2.1 Rajiv Prasad / Phil Meyer Aquatic Ecology Resources AECO-1 Aquatic surveys described in the ER were conducted in October 2022 and June 2023, please describe any additional aquatic 2.3.2.1 and 2.3.2.2 Caitlin Wessel
5 Info Need ID Information Need Environmental Report (ER)
Section Subject Matter Expert (SME) sampling conducted. RG 4.2 states the applicant should include at least 1 year of baseline data.
AECO-2 Please provide a construction map that shows the areal extent and location of construction activities and water discharge along with aquatic features (ESRP 4.3.2).
Caitlin Wessel AECO-3 Please provide a proposed schedule of construction activities and work windows (ESRP 4.3.2).
3.3, Table 3.3-1 Caitlin Wessel AECO-4 Need additional information on the intake design and how it would affect flow and aquatic species in the Hams Fork River. Will the additional water needed for the plant increase the flow rate at the intake (ESRP 5.3.1.2)? Will the increased water take affect downstream aquatic environments?
5.3.2.1.2, 2.2.1.1.2, 2.2.1.1.8 Caitlin Wessel AECO-5 Need description and or diagram detailing the discharge structure (ex. Where will it enter the stream, info. about the flow reduction system, anticipated discharge flow rate and variations with season, and impacts to biota downstream; ESRP 5.3.2.2) 5.3.2.2, 3.2.2.12 Caitlin Wessel AECO-6 Describe aquatic resource impacts related to waste systems (ESRP 5.5.1) 5.3.2.2.2 Caitlin Wessel Terrestrial Ecology Resources TECO-1 The North American Wolverine (Gulo gulo luscus) is present on the official U.S. Fish and Wildlife Service (USFWS) Information for Planning and Consultation report as a species potentially affected by activities at this location. Please include information on this species, including habitat requirements, life history, and potential project effects. RG 4.2 states that the applicant should include a discussion of each important terrestrial species that has a reasonable likelihood of occurring in the area.
2.3.1.4, 4.3.1.4, 5.3.1.4 Tracy Fuentes, Sophie Baur TECO-2 Per RG 4.2, the ER should include a discussion of tall structures that might injure birds and bats. Tall structures with lights and that are guyed are more likely to injure birds and bats. The ER states that the Kemmerer Unit 1 meteorological tower is 197 feet (60 meters) above ground level but does not state whether the tower is 2.7.1.3.5, 2.7.4.1, 4.3.1.3.1 Tracy Fuentes, Sophie Baur
6 Info Need ID Information Need Environmental Report (ER)
Section Subject Matter Expert (SME) guyed or lit. Please state whether the tower is guyed or freestanding and state whether it is lit or unlit. If lit, please state lighting color and whether light is blinking or steady.
TECO-3 Please provide copies of the wetland delineation report (Reference 2.1-17, 2.3-39) and surveys for Ute ladies-tresses (Spiranthes diluvialis) in wetlands (References 2.3-42, 9.3-57, 9.3-59) as described in the ER (ESRP 4.1.1; 4.1.2; 4.3.1; 5.1.1; 5.1.2; 5.3.3.2) for NRC staff review. Please state the planned timing of the third year of surveys for Utes ladies-tresses. Three years of surveys are required as stated in USFWS's revised version of the 1992 Interim Survey Requirements for Ute Ladies-tresses Orchid (Spiranthes diluvialis). If year 3 surveys have already been completed for Utes ladies-tresses, please provide survey results for NRC staff review.
2.1.1.1, 2.3.1.2, 2.3.1.4, 4.3.1.4 Tracy Fuentes, Sophie Baur TECO-4 The ER states that terrestrial visual surveys were conducted in 2022 and 2023 (Reference 2.3-40, 2.3-41), that raptor nest surveys were conducted in 2023, and that burrowing owl nest-clearing surveys will be conducted 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before construction in areas of the site with prairie dog burrows. Please provide copies of these surveys for NRC staff review. RG 4.2 states the applicant should include at least 1 year of baseline data.
2.3.1.1.1, 2.3.1.4, 4.3.1.1.1 Tracy Fuentes, Sophie Baur TECO-5 RG 4.2 requires applicants to identify measures and controls to limit adverse impacts during construction activities. Provide copies of such environmental controls and procedures for the NRC staff review, including pre-construction nest survey protocols, stormwater pollution prevention plan, spill prevention plan, erosion controls, revegetation plan, and any planned terrestrial resource monitoring.
4.1.1, 4.1.2, 4.3.1, 4.3.2, 4.11 Historic and Cultural Resources HCR-1 Provide information about traditional ecological knowledge obtained through coordination, outreach, site visits, communication etc., with Native American Tribes.
4.6 Cyler Conrad
7 Info Need ID Information Need Environmental Report (ER)
Section Subject Matter Expert (SME)
HCR-2 Provide information about the visual impacts analysis for Kemmerer Unit 1 and the utility corridor based on current known facility heights and plumes (as an example for the utility corridor, based on height, structure type, color of transmission structures, etc.).
4.6 Cyler Conrad HCR-3 Provide a description of the proposed road in the utility corridor in terms of construction disturbance (depth, width, crown/ditch, etc.),
and long-term operations and maintenance.
4.6 Cyler Conrad HCR-4 What is the proposed right of way (ROW) width for the utility corridor? This information need is not related to the analyzed/surveyed corridor width, but for the actual negotiated ROW width.
4.6 Cyler Conrad HCR-5 Provide information, including records of past disturbance, regarding the small access road and its impacts to 48LN740 and provide corresponding documentation for staff review.
4.6 Cyler Conrad HCR-6 Confirm that railroad alignments that cross the direct area of potential effect (APE) represent non-contributing components of National Register of Historic Places (NRHP)-eligible sites and provide documentation of this determination from the State Historic Preservation Office (SHPO).
4.6 Cyler Conrad HCR-7 Provide information on any updates to identified traditional cultural properties or landscapes within the APE.
4.6 Cyler Conrad HCR-8 Provide recommendations for avoiding or mitigating adverse effects to 48LN740 and 48LN8940. Discuss and have construction plans for activities in these areas available for staff review. Provide records of Wyoming SHPO communication and engagement on adverse effects for these historic properties.
4.6; 5.6; 7.2.6 Cyler Conrad HCR-9 The ER states that 48LN740 is in the indirect APE (page 346/1501
- non-public version); please confirm.
4.6 Cyler Conrad HCR-10 The ER Table 2.6-4 (non-public version) describes site eligibility.
Are the eligibility determinations listed in this table based on the recommendation of previous recorders or of Karpinski and Karpinski (2023)?
4.6 Cyler Conrad
8 Info Need ID Information Need Environmental Report (ER)
Section Subject Matter Expert (SME)
HCR-11 The proposed electrical transmission lines, water pipelines, and electrical substation for TerraPower are to be constructed on the historic Naughton Power Plant site. Have these impacts been analyzed? Has the Naughton Power Plant been evaluated for NRHP eligibility? Will facilities/infrastructure at the Naughton Power Plant be affected, such as connection to, altering, replacing, tying-in, demolishing, etc.?
4.6; 7.2.6 Cyler Conrad HCR-12 Are off-site alterations needed to any of PacifiCorps water delivery systems (starting at Lake Viva Naughton) for the TerraPower project to be realized, such as to pipes, pumps, ponds, storage facilities, conveyance facilities, etc.)?
4.6; 7.2.6 Cyler Conrad HCR-13 The ER page 760/1501 (non-public version) states that a temporary parking lot will adversely affect 48LN740 - please confirm.
4.6 Cyler Conrad HCR-14 Provide an updated copy of Karpinski and Karpinski (2023) report, A Class III Cultural Resource Inventory for TerraPower, LLCs Natrium Demonstration Project, Lincoln County, Wyoming. Provide records of communication with the Wyoming SHPO, including any eligibility determinations and concurrences.
4.6; 5.6 Cyler Conrad HCR-15 Provide documentation of any ongoing or completed outreach and communication with Native American Tribes and the Wyoming SHPO, and their responses (in addition to those already provided in the ER).
4.6; 5.6 Cyler Conrad HCR-16 Provide copies of all procedures that describe protective measures (e.g., avoidance/monitoring) and an inadvertent discovery plan for historic and cultural resources during construction, operation and maintenance, and demolition.
4.6; 5.6; 7.2.6 Cyler Conrad Human Health: Non-Radiological No nonradiological health information needs identified at this time.
9 Info Need ID Information Need Environmental Report (ER)
Section Subject Matter Expert (SME)
Human Health - Radiological HHR-1 Per Regulatory Guide 4.2 Rev. 3 Section 5.9.1, the environmental pathways by which radiation from radioactive effluents can be transmitted from the proposed plant to living organisms should be provided. Please provide information that identifies gaseous and liquid effluents pathways, expected rates of emission, annual doses to the public within 50 miles of the site, and the code used to perform the analysis.
2.7.3.2; 5.9; 5.9.1 Tristan Hay HHR-2 Per RG 4.2 Rev 3, Section 5.9.7, the applicant should provide an estimate of the quantity of wastes produced and stored at the facility. Please provide a SME to discuss any potential exposures associated with onsite exposures from solid waste. This includes Class A, B, C, greater than Class C wastes, and spent fuel. The staff notes that there is mention of radioactive waste storage related to Fuel Handling Building in Section 3.1.1.1.2 of the ER.
5.9.6 Tristan Hay HHR-3 Please provide justification for sample sites. Please provide lower limits of detection regarding samples (ESRP 6.2) 2.9.3; 2.9.2 Tristan Hay Fuel Cycle and Radiological/Non-Radiological Waste Management FCRW-1 Per Regulatory Guide 4.2, Revision 3, Section 3.4.3, please provide an estimated yearly amount of solid waste during construction and possible locations of disposal.
4.10 Kim Leigh/Seema Verma FCRW-2 Please provide a SME to discuss the onsite storage of radiological wastes and spent fuel (e.g., a water-based environment). The ER Section 6.1.2.6.2 relies on NUREG-2157 as a bounding analysis of spent fuel storage impacts, however spent fuel generated by liquid metal fast reactors is not within the scope of the analysis in NUREG-2157 because that technology was in commercial use in the United States at the time of publication.
6.1.2.6.2 Jon Napier/ Don Palmrose
10 Info Need ID Information Need Environmental Report (ER)
Section Subject Matter Expert (SME)
FCRW-3 Section 6.1.1.4.5 states that the impacts of fuel fabrication are described in an ER supplement to the GNF-A Wilmington, North Carolina fuel fabrication facility. This supplemental ER has been withdrawn (ML24068A130). Please provide an updated Section 6.1.1.4.5 that addresses the impact of fuel fabrication.
6.1.1.4.5 Jon Napier/ Don Palmrose Transportation of Radioactive Material TR-1 10 CFR 51.52 (a)(3) states that The average level of irradiation of the irradiated fuel from the reactor does not exceed 33,000 megawatt-days per metric ton, and no irradiated fuel assembly is shipped until at least 90 days after it is discharged from the reactor.
While the commitment to 90 days has been met, the ER does not specify the expected burnup of spent fuel. Please provide an estimate of the potential.
6.2 Jon Napier TR-2 ESRP Section 5.7.2 identifies that information on transportation packaging systems to be used for fresh fuel, spent fuel, and other radioactive wastes is required. The ER section 6.2 references section 10.2 of the TerraPower PSAR, or the ALARA program. This program does not discuss waste transportation and packaging.
Please provide information regarding the transportation and packaging of low-level radioactive waste.
6.2 Jon Napier TR-3 The NRC staff has identified an issue with the population density values from a WebTRAGIS kml file for use in the RADTRAN Code.
Please provide an SME to discuss how this affected TerraPowers analysis in the ER. For reference, please see NUREG-2266 (ML24207A210). Please provide a complete discussion as described in RG 4.2 Rev 3 Section 6.2.1 to allow the staff to make a determination of sufficiency.
6.2 TR-4 Provide a knowledgeable expert to discuss the number of shipments of fuel and waste applied in the transportation analysis of ER Section 6.2 and related calculations.
6.2 Jon Napier/Rao Tammara
11 Info Need ID Information Need Environmental Report (ER)
Section Subject Matter Expert (SME)
Accidents ACC-1 Provide an SME to discuss the generation of the accident analysis information, such as that provided in Section 5.11.2, Table 5.11-20, and related material of the ER. The information provided in Table 5.11-20 cannot be traced to identifiable sources in the PSAR.
Additionally, the staff needs to confirm the use of recommended MACCS input data value in accordance with NUREG/CR-7270 and based on local environmental factors.
5.11.2 Jon Napier/Don Palmrose ACC-2 Provide an SME to discuss how licensing modernization project (e.g., NEI 18-04) was factored into the severe accident analysis and SAMDAs. The staff needs to discuss this due to the probabilistic risk assessment applied in the CP application is based on preliminary design information that the safety review team is assessing for acceptability at the CP stage. Please note that as directed by the 1980 Commission Policy Statement on NPP accident considerations under NEPA (45 FR 40101), the ER submitted by applicants for CPs on or after July 1, 1980, should include a discussion of the environmental risks associated with accidents.
5.11.2 Jon Napier/Don Palmrose ACC-3 Provide an SME to discuss the potential application of external events multipliers (e.g., NEI 05-01A) in the severe accident mitigation design alternatives (SAMDA) analysis.
5.11.3 Jon Napier/Don Palmrose Alternatives ALT-1 ESRP 9.4.2 states that for discharge systems, the following information should be obtained: sketches or preliminary designs and operational characteristics of alternative discharge systems showing the discharge design, its location with respect to the receiving water body, and its relationship to water surface, bottom geometry, intake structure, and shoreline. While discharge system alternatives are proposed in the ER, there are no sketches or 9.4.2.2 Dave Goodman
12 Info Need ID Information Need Environmental Report (ER)
Section Subject Matter Expert (SME) preliminary designs included. Please provide such information, as available.
Decommissioning There are no information needs related to Decommissioning at this time.
Jon Napier Socioeconomics - Environmental Justice SOCIOEJ-1 Section 4.4.4.1 of the ER states a traffic study will inform the design of the US 189 intersection and improvements and include additional recommendations for mitigating traffic congestion. The traffic study considers the peak workforce with two staggered start times, estimating that approximately 60 percent of the workforce and a few truck shipments (an estimated 980 vehicles) would arrive or depart at the peak a.m. and p.m. hours. The ER indicates the traffic study analyzes projected vehicle traffic for 2026, inclusive of Kemmerer Unit 1 construction and Sodium Test and Fill Facility construction. The ER does not provide a title or a reference citation for this traffic study. Please identify the traffic study and provide the source documentation for this information in the ER.
4.4.4.1 Michelle Niemeyer/Lin Zeng SOCIOEJ-2 Section 4.4.3.2.4, Table 4.4-14 and Table 4.4-15 of the ER provides estimated property tax payments for the Kemmerer Unit 1 during construction. The ER states these estimates do not reflect any negotiated property tax agreements, such as payments-in-lieu of taxes or power plant valuation agreements, between tax jurisdictions or the State. Please provide any updated information on estimated property tax payments for the Kemmerer Unit 1 during construction.
4.4.3 Michelle Niemeyer/Lin Zeng SOCIOEJ-3 Section 5.4.3.2.4 of the ER estimates property tax payments during power plant operation will be approximately $7.5 million. The ER states this estimate does not reflect any negotiated property tax agreements, such as payments-in-lieu of taxes or power plant 5.4.3.2.4 Michelle Niemeyer/Lin Zeng
13 Info Need ID Information Need Environmental Report (ER)
Section Subject Matter Expert (SME) valuation agreements, between tax jurisdictions or the State. Please provide any updated information on estimated property tax payment for the Kemmerer Unit 1 during power plant operations.
SOCIOEJ-4 Section 4.4.2 of the ER states 37 percent of the construction workers and 80 percent of the operation workers during the construction period are assumed to bring families. Section 5.4.2 of the ER states 100 percent of the operation workers are assumed to bring families. Please resolve this inconsistency.
4.4.2; 5.4.2 Michelle Niemeyer/Lin Zeng SOCIOEJ-5 Workers from the nearby Naughton Power plant are slated to be trained to work at Kemmerer Unit 1 however Section 4.4.2 of the ER states 100 percent of operations workers will be relocating to the region. Please clarify the percentage of operations workers expected to move into the region.
4.4.2; 5.4.2 Michelle Niemeyer/Lin Zeng Meteorology No meteorological information needs at this time.
Brad Fritz General Comments No additional comments at this time.
Dave Goodman