ML25007A078

Rci/Rai Audit Letter

ML25007A078
Person / Time
Site:	Browns Ferry
Issue date:	01/15/2025
From:	Jessica Umana NRC/NMSS/DREFS/EPMB1
To:	Erb D Tennessee Valley Authority
References
EPID L-2024-SLE-0000
Download: ML25007A078 (1)

Text

January 15, 2025 Delson C. Erb, Vice President OPS Support Tennessee Valley Authority 1101 Market Street, LP 4A-C Chattanooga, TN 37402

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 -

SUMMARY

OF THE 2024 ENVIRONMENTAL AUDIT RELATED TO THE REVIEW OF THE LICENSE RENEWAL APPLICATION ENVIRONMENTAL REPORT (EPID NUMBER: L-2024-SLE-0000) (DOCKET NUMBERS: 50-259, 50-260, AND 50-296)

Dear Delson C. Erb:

A review team consisting of staff from the U.S. Nuclear Regulatory Commission (NRC or the staff) participated in a hybrid audit during the weeks of July 21, September 30, and October 7, 2024, for Browns Ferry Station, Units 1, 2, and 3, as part of the license renewal application environmental review. The goal of the audit was to gather information to ensure that the environmental requirements for license renewal, as codified in Title 10 of the Code of Federal Regulations Part 51 Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, were met. A letter dated September 3, 2024 (Agencywide Documents Access and Management System [ADAMS] ML24239A333), was sent containing the full audit plan.

A virtual limited scope audit was held the week of July 21, 2024, to improve understanding and support the preparation of a Supplemental Environmental Impact Statement (SEIS). An audit plan dated July 10, 2024 (ML24183A414), outlined information needs identified by the staff to facilitate the review process.

A formal entrance meeting was held on September 30, 2024, to introduce participants and discuss audit logistics. During the remainder of the audit, the NRC staff, supported by Pacific Northwest National Laboratory (PNNL) staff, participated in smaller resource specific breakout sessions with Tennessee Valley Authority (TVA) representatives to address the audit needs identified in the audit plan (ML24239A333). Enclosure 1 to this letter provides a list of representatives from the NRC, PNNL, TVA who participated in the audit.

D. Erb 2

At the conclusion of the audit, the NRC staff summarized the status of the review with TVA representatives during the exit meeting held on December 13, 2024. Many of the NRCs questions identified in the audit plan or during the audit were answered through the conduct of the audit.

Audit needs that will be used in the SEIS could be submitted as (a) a supplement to the environmental report (ML24023A476), (b) responses to requests for additional information (RAIs), or (c) responses to requests for confirmation of information (RCIs). Enclosure 2 to this letter contains the staffs RAIs and RCIs. We are requesting TVA respond to our requests within 30 days of the receipt of this correspondence. Although delays may occur due to competing work priorities and shifting circumstances, responding in this timeframe will assist us in continuing to meet the milestones shared in our March 15, 2024, schedule letter (ML24068A177).

While the NRC staff did not identify any significant environmental issues during this audit, the staff indicated that the environmental review was ongoing and that any additional information necessary to support the review would be formally requested via the RAI process in the future.

Persons who do not have access to ADAMS or who encounter problems in accessing the documents located in ADAMS should contact the NRC's Public Document Room staff by phone at 1-800- 397-4209 (or 301-415-4737) or via email at pdr.resource@nrc.gov.

If you have any questions, please contact me via email at jessica.umana@nrc.gov.

Sincerely, Signed by Umana, Jessica on 01/15/25 Jessica Umana Environmental Project Manager Environmental Project Management Branch 1 Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards Docket No. 50-259, 50-260, and 50-296

Enclosures:

1. List of Participants

2. Requests for Confirmation of Information and Additional Information cc: Listserv

D. Erb 3

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 -

SUMMARY

OF THE 2024 ENVIRONMENTAL AUDIT RELATED TO THE REVIEW OF THE LICENSE RENEWAL APPLICATION ENVIRONMENTAL REPORT (EPID NUMBER: L-2024-SLE-0000) DOCKET NUMBERS: 50-259, 50-260, AND 50-296)

DATED:

January 15, 2025 DISTRIBUTION:

PUBLIC RidsNrrDnrl Resource RidsACRS_MailCTR Resource RidsRgn2MailCenter Resource RidsRgn2Drp Resource RidsRgn2Drs Resource RidsRgn2Ora Resource RidsRgn2Opa Resource RidsNrrOd Resource RidsNrrPMBrownsFerry Resource JHammock, NRR/DNRL AIm, NRR/DNRL LGibson, NRR/DNRL SLee, NRR/DNRL BSmith, NRR/DNRL JUmana, NMSS/REFS TSmith, NMSS/REFS KGreen, NRR/DORL DRoth, OGC TKeene, OEDO/AO SBurnell, HQ/OPA LWilkins, OCA DGasperson, RII/OPA TSteadham, RII/DORS NKarlovich, RII/DORS KPfeil, RII/DORS LMcKown, RII/DORS BDesai, RII/DORS PCooper, RII/DORS JPelchat, RII/FCO wrvictor@tva.gov pjdonahue@tva.gov tebraudt@tva.gov jhbashore@tva.gov ADAMS Accession No.: ML25007A078 OFFICE NE/PM:EPMB1 LA:REFS BC:EPMB1 NE/PM:EPMB1 NAME JUmana AWalker-Smith SKoenick JUmana DATE 1/11/2025 1/13/2025 1/14/2025 1/15/2025 OFFICE RECORD COPY

LIST OF PARTICIPANTS BROWNS FERRY SUBSEQUENT LICENSE RENEWAL APPLICATION HYBRID LIMITED AND FULL SCOPE ENVIRONMENTAL REVIEW AUDIT Week of July 21, 2024, Limited Scope Virtual Environmental Audit Name Affiliation Angela Sabet U.S. Nuclear Regulatory Commission (NRC)

Beth Alferink NRC Brian Glowacki NRC Caroline Hsu NRC Donald Palmrose NRC Gerry Stirewalt NRC Jay Robinson NRC Jeffrey Rikhoff NRC Jenny Davis NRC Jessica Umana NRC Leah Parks NRC Lloyd Desotell NRC Michelle Rome NRC Nancy Martinez NRC Peyton Doub NRC Robert Hoffman NRC Sarah Lopas NRC Steve Koenick NRC Ted Smith NRC Eric Asley Michael Tennessee Valley Authority (TVA)

Ethan Marcus Widener TVA Joseph Herbert Bashore TVA Lauren Ann Vinson TVA Peter John Donahue TVA Thomas Earl Braudt TVA William J. Baker TVA William Ross Victor TVA Kevin Taylor Architecture, Engineering, Construction, Operations, and Management (AECOM)

Russell Kiesling AECOM

2 Week of September 30, 2024, Virtual Environmental Audit Name Affiliation Name Affiliation Brian Glowacki NRC Josh Duncan TVA Caroline Hsu NRC K Carboni TVA Donald Palmrose NRC L Williams TVA Gerry Stirewalt NRC Lauren Ann Vinson TVA Jay Robinson NRC Lindsey Smith TVA Jeffrey Rikhoff NRC Maggie Gilliland TVA Jenny Davis NRC Nikki Berger TVA Jessica Umana NRC Peter John Donahue TVA Leah Parks NRC R Standford TVA Lloyd Desotell NRC Russell Kiesling TVA Michelle Rome NRC T Macker TVA Nancy Martinez NRC Thomas Earl Braudt TVA Peyton Doub NRC Todd M. Amacker TVA Robert Hoffman NRC William J. Baker TVA Sarah Lopas NRC William Ross Victor TVA Steve Koenick NRC F Hope Jensen Hughes Ted Smith NRC J Sattler Jensen Hughes Adrienne Rackley PNNL Nice Lovelace Jensen Hughes Caitlin Condon PNNL Russell Kiesling AECOM Caitlin Wessel PNNL Dana Vesty PNNL Dave Goodman PNNL Eric Michael PNNL Julia Flaherty PNNL Kazi Tamaddun PNNL Kirsten Chojnicki PNNL Leah Hare PNNL Lexie Goldberger PNNL Lindsey Renaud PNNL Michelle Neimeyer PNNL Philip Meyer PNNL Rajiv Prasad PNNL Bryce Mitchell TVA C Phillips TVA Colleen Rice Montgomery TVA Craig Lee Phillips TVA D Pollock TVA E Burton TVA Eric Ashley Michael TVA Ethan Marcus Widener TVA Joseph Herbert Bashore TVA

3 Week of October 7, 2024, Onsite Environmental Audit Name Affiliation Denny Campbell TVA Brad Holloway TVA Scott Christman TVA Joe Bashore TVA Hunter Johnson TVA Linsey Smith TVA Russell Stanford TVA Ethan Widener TVA Lauren Vinson TVA Lindsey Renaud PNNL Caitlin Condon PNNL Caitlin Wessel PNNL Rajiv Prasad PNNL Kazi Tamaddun PNNL Sam Cohen NRC Jessica Umana NRC Nancy Martinez NRC Angela Sabet NRC

4 LIST OF PARTICIPANTS BROWNS FERRY SUBSEQUENT LICENSE RENEWAL APPLICATION HYBRID SEVERE ACCIDENT MITIGATION ACCIDENTS AUDIT October 3, 2024, Virtual Severe Accident Mitigation Accidents Audit Name Affiliation Angela Sabet NRC Jay Robinson NRC Jerry Dozier NRC Jessica Umana NRC Samuel Cohen NRC Caitlin Condon PNNL Kirsten Chojnicki PNNL Douglas Pollock TVA Eric Ashley Michael TVA Josephe Herbert Bashore TVA Peter John Donahue TVA Thomas Earl Braudt TVA Wiliam J. Baker TVA William Ross Victor TVA Frank Hope Jensen Hughes Justin Sattler Jensen Hughes Nicholas Lovelace Jensen Hughes Russell Kiesling AECOM

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 SUBSEQUENT LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW REQUESTS FOR CONFIRMATION OF INFORMATION Regulatory Basis Licensees are required by Title 10 of the Code of Federal Regulations (10 CFR) Part 51.53(c)(1) to submit with its application a separate document entitled Applicant's Environmental Report Operating License Renewal Stage. The U.S. Nuclear Regulatory Commissions (NRC) regulations at 10 CFR 51, which implement section 102(2) of the National Environmental Policy Act of 1969, as amended (NEPA), include requirements for applicants to provide information as may be useful in aiding the NRC staff in complying with NEPA. As part of its review, the NRC staff is required to prepare a supplemental environmental impact statement (SEIS). Review guidance for the staff is provided in NUREG-1555, Supplement 1, Revision 2, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Supplement 1 - Operating License Renewal.

The letters to James Barstow, Vice President, Nuclear Regulatory Affairs and Support Services, Tennessee Valley Authority (TVA), dated July 10 (Agencywide Documents Access and Management System [ADAMS] ML24183A414), and September 3, 2024 (ML24239A333),

contained the limited scope and full scope audit plans, respectively, for Browns Ferry Nuclear Plant (BFN), which included a list of information needs with unique identifiers. The environmental audits were conducted both virtually and in-person. During the environmental audits, the NRC staff reviewed documents that were made available on the applicants electronic information portal in response to the staff audit needs. The staff also participated in breakout sessions with applicant personnel for specific resource areas to gather information that will likely be in the SEIS. To the best of the staffs knowledge, this information on the applicants electronic information portal and discussed in breakout sessions is not currently on the docket or publicly available. The NRC staff requests that the applicant submits confirmation that the information gathered from the audit and listed below is correct or provides the associated corrected information.

GENERAL GEN-2/GEN-3 The environmental report (ER) dated January 19, 2024 (ML24019A010), addresses spills that occurred through 2022. Please confirm that there have been no reportable inadvertent releases or spills of radioactive and/or nonradioactive contaminants including oil since those included in TVAs ER dated January 19, 2024 (ML24019A010).

GEN-4 The following information needs were discussed in the audit. As this represents a broad request crosscutting many resource areas the resolution to these information needs was that the answers would be incorporated into a supplement to the environmental report. Please confirm that the following information needs and requests discussed in the audit have been addressed in the environmental report supplement.

Air Quality (AQ)-1-LSA: Section 3.2.6 of the ER identifies air pollutant sources at BFN: auxiliary boilers, the emergency diesel or propane fired generators, and

2 miscellaneous sources such as fuel storage facilities. Section 3.2.6 of the ER goes on to state that BFN operates under a synthetic minor source permit. Table 4.2-2 of the ER provides BFN annual emissions for a single year. Identify the air pollutant sources that are regulated under BFNs synthetic minor source permit.

AQ-2-LSA: Section 4.2.1 of the ER states that cooling tower particulate emissions in the air via steam drift cannot be reasonably quantifiable and are considered negligible. Please explain the basis for concluding that particulate emissions cannot be quantified for the mechanical draft cooling towers.

AQ-3-LSA: Section 4.2.2 of the ER states that ozone and nitrogen oxide emissions associated with BFN high-voltage transmission lines are minimal. Have field tests concerning ozone and nitrogen oxide emissions generated by BFNs in-scope transmission lines been conducted? If so, please provide a copy. If field tests have not been conducted, provide a basis for concluding that air quality impacts associated with transmission line are SMALL.

AQ-4-LSA: Please provide a copy of BFNs synthetic minor source permit (Permit No. 708-0003-X005).

AQ-5-LSA: Provide annual air emissions for the most recent five years for the sources listed in table 4.2-2 of the ER.

AQ-1: Has TVA received any notices of violation or noncompliance regarding Browns Ferry synthetic minor source permit within the last 5 years?

Aquatic Ecology (AQU)-13: Please provide additional information on TVAs ability to achieve a no more than 10 F increase in discharge water temperature.

AQU-15: Please provide: TVA. 2021b. Clean Water Act Section 316(b) § 122.21(r)

Compliance Documentation for the BFN Plant, Limestone County, Alabama. April.

AQU-19: Please provide: Amaker T. 2021. Browns Ferry Nuclear Mussel Survey, Limestone County, Alabama. July 12-13, 2021.

AQU-23: Please provide: TVA. 2022b. TVA BFN Power Plant National Pollutant Discharge Elimination System (NPDES) Permit No. AL0022080. Updated Final

§316(b) Rule Information 40 CFR 122.21(r)(10) Submittal. January 2022.

Geologic Environment (GE)-1-LSA: Section 3.4.1 of the ER does not describe rare or unique geologic resources, including rock, mineral, or energy rights and assets at or adjoining the BFN site, as recommended in Regulatory Guide (RG) 4.2, Supplement 1, Revision 1. It is possible to assume there are none since Alabama Code Section 45-42.170.43 indicates that, in Limestone County after May 11, 2009, no new rock quarry may be established, nor any existing rock quarry located outside the corporate limits of any municipality within 10 miles of the BFN site. Please provide an explanation for the presence or absence of rare or unique geologic resources at or adjoining the BFN site.

General (GEN)-1: Please provide any relevant updates to table 9.1-1, Environmental Authorizations for Current BFN. If any authorizations have expired since TVAs Application for Subsequent Renewed Operating License, dated January 19, 2024 (ML24019A010), provide the status of those permits and/or renewals.

3 Greenhouse Gas and Climate Change (GC)-1-LSA: Section 3.2.6 of the ER states that as of July 7, 2022, BFN generated a total of 17,593 tpy [tons per year] CO2e.

Please provide annual greenhouse gas (GHG) emissions for the most recent five years. Emissions should account for direct and indirect GHG emissions (e.g., worker vehicles).

Are fluorinated gases, such as hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride, used onsite? If so, please identify the equipment that use these gases and include GHG emissions for these sources for the last 5 years as part of the response under part a above. Additionally, if fluorinated gases are used, identify and discuss procedures implemented to manage the handling of fluorinated gases.

GC-2-LSA: In Section 4.13.2.1, Temperature and Precipitation Effects, the ER concludes that because current climate change patterns in the southeast do not indicate a trend toward drought, climate change impacts on water availability in Wheeler Reservoir are anticipated to be SMALL. The ER states that climate change is likely to result in higher temperatures within the BFN area. The effect of climate change on precipitation within the BFN area is unknown because the BFN area is in a transition zone between projected high latitude increases and subtropical decreases in precipitation. With increased temperatures, evaporation could increase, reducing water availability. Please provide data and/or an assessment to support the ER conclusion regarding water availability for Wheeler Reservoir, including the Hydrothermal Evaluation for BFN and presentation material provided during the audit.

GC-3-LSA: Section 3.5.1.2 of the ER states that BFNs National Pollutant Discharge Elimination System permit requires that temperature differentials between upstream and downstream monitoring points and flow be reported in monthly Discharge Monitoring Reports. Has a warming trend been observed in river water temperatures measured at upstream or downstream monitoring points for the available period of record? Has a trend been observed in average daily flow in Wheeler Reservoir for the available period of record? Please provide data to support the conclusions reached (e.g., graphs, time series analysis, etc.).

GC-4-LSA: Section 4.13 of the ER states, [c]hanges in climate have broader implications for environmental resources (e.g., water resources, air quality, and ecosystems) [] As a consequence, climate change can have overlapping impacts on environmental resources by inducing changes in resource conditions that can also be affected by the proposed action. The effects of climate change in Section 4.13.2 of the ER considered impacts on water availability in Wheeler Reservoir; public health; thermophilic organisms in Wheeler Reservoir; and environmental justice. Please discuss why the ER did not consider climate change impacts to other environmental resource areas affected by the proposed action (e.g., air quality).

4 Historic and Cultural Resources (HCR)-1: Please provide a pre-contact and historic cultural context of the site and region, including the history of Browns Ferry and images of its construction.

HCR-2: Section 3.7.2 indicates that the entirety of the area of potential effects (APE) has been surveyed but the section lacks specific information on what previous surveys occurred and where. Please provide information on how many previous surveys occurred within the APE, the reasoning for the surveys, acreage surveyed, location of surveys, and whether any cultural resources were identified.

HCR-5: The ER did not identify plans or procedures for the protection of cultural resources, or the inadvertent discovery of human remains. Please provide TVAs procedures and other best management practices for the protection of cultural resources. Describe what workflow processes would be enacted if the inadvertent discovery of human remains were to happen, including coordination with the local coroners office, Tribes, and the Alabama State Historic Preservation Office (SHPO).

Provide a copy of an Inadvertent Discovery Plan for cultural resources and human remains.

HCR-6: Please provide information on the Browns Ferry historic district, including its significance under Criteria A, C, and Criteria Consideration G. Section of the ER states that TVA provided the Reynolds 2022 report to SHPO and invited their comments on the study and on the NRHP eligibility prior to making any decisions on SLR or future projects that could affect BFN. Detail how TVA plans to minimize potential impacts to the historic district and contributing properties for any projects that may affect them, including from maintenance actions, plant improvements, or upgrades.

HCR-10: Section 2.2 of the ER states that five of the original six cooling towers have been replaced (cooling towers 1 and 3-6), cooling tower 2 is scheduled for replacement by 2027, and cooling tower 7 was constructed in May 2012. Section 3.7.3 of the ER states that TVA conducted a historic architectural inventory of BFN and assessment of BFNs eligibility for inclusion in the NRHP. Based on the study, TVA determined that BFN is eligible as a historic district. The BFN historic district is comprised of 49 buildings and structures. Twenty structures within the boundaries of the district are considered non-contributing due to being built after 1980. Please discuss TVAs plans to mitigate potential impacts to the historic district due to the scheduled cooling tower 2 replacement in 2027.

HCR-12: Section 3.7 of the ER provides a quote which, in part, states: plant improvements including intake structures, buried piping, and large external tanks would be expected upgrades for continued operation from 60 to 80 years. Please provide a reference for the quote and describe how these improvements will or will not affect historic properties and cultural resources.

Human Health (HH)-1-LSA: Section 3.9.2 of the ER discusses Microbiological Hazards, but there is no discussion regarding consultation with state agencies as

5 recommended by RG 4.2, Supplement 1, Revision 1, which states the applicant should consult the State agency responsible for environmental health regarding potential existence and concentration of microbiological organisms in the receiving water for plant cooling water discharge to ensure that the 10 CFR 51.53(c)(ii)(G) assessment of the impact of the proposed action on public health from thermophilic organisms has been completed. Provide copies of consultation correspondence with the responsible state agency for microorganisms in the receiving waters of the plant cooling water discharge. This correspondence should indicate the states concurrence with the applicants risk assessment and proposed mitigation strategy if one is required. Following consultation, if the state agency requests additional assessments or actions related to thermophilic microbiological organisms, provide the status of those assessments or actions.

HH-2-LSA: Sections 3.9.3 and 4.9.8 of the ER discusses electric shock hazards and notes that all in-scope transmission lines meet national electric safety code standards, but there is no discussion of how this conclusion was drawn. Please plan to have a subject matter expert available to discuss the assessment or study performed for the in-scope transmission lines as it relates to the National Electric Safety Code (NESC) criteria and the maintenance program to ensure that design ground clearances are maintained. As part of this discussion, please plan to provide the assessment or study to ensure NESC criteria are being met in accordance with 10 CFR 51.53(c)(3)(ii)(H). The study performed as part of initial license renewal is not applicable to subsequent license renewal unless further verification for continued applicability due to the potential for land use changes in the vicinity of the lines, line voltage changes, facility construction, etc. are confirmed.

HH-3-LSA: As noted in HH-2, please provide a copy of the study and analysis findings used to determine compliance with the current NESC guidance. When providing a copy of the study, ensure that the conclusion of no clearance issues and that NESC clearance requirements are met as stated in the ER.

HH-2: Please provide an overview of the radiation control program with emphasis on the as low as reasonably achievable program to control worker radiation exposure (annual dose goals and status). Please discuss the annual variations in total personnel with measurable dose and the average total effective dose equivalent (TEDE) per worker noting that the average TEDE per worker at Browns Ferry tends to be higher than the boiling water reactor industry average over the rolling three-year periods summarized in NUREG-0713. Include in this discussion any plant or site-specific factors (e.g., plant design, equipment issues, etc.) that contribute to source terms and therefore doses averaging higher than the boiling water reactor industry average. Are there any proposed changes or upgrades to the program being considered during the subsequent license renewal term or site plans/goals to maintain doses as low as reasonably achievable?

HH-4: Section 4.9.7 notes that TVA has a comprehensive occupational safety program and notes statistics from the Bureau of Labor Statistics through 2020. It is noted in this section that Browns Ferry carries low incidence of OSHA-recordable

6 work-related injuries and illnesses, but this is not quantified in the site-specific environmental report. Please provide quantitative values for Browns Ferry incidence rate of OSHA-recordable work-related injuries and illnesses and justify the statement that this is a low incidence as stated in Section 4.9.7.

Land Use and Visual Resources (LUV)-2: Please update the land cover data (as discussed in ER tables 3.1-1 and 3.1-2 and ER Section 3.1.1 and referenced in ER Section 3.5.1.1) with National Land Cover Database 2021.

Meteorology (MET)-1-LSA: Section 3.2.1 of the ER provides meteorological data (mean annual temperature, mean daily temperature) at Decatur, Alabama. However, site-specific meteorological data is not provided. Please provide the following meteorological data from BFNs onsite meteorological facility for the past five years:

Prevailing wind direction and average wind speed, Monthly and annual daily mean temperature data and temperature extremes, Monthly and annual total mean precipitation MET-2-FSA: Section 2.2 of the ER identifies that to the east of the central site area is the meteorological tower. Section 3.2.1 of the ER states that the meteorological facility consists of a 91-meter (300-foot) instrumented tower for wind and temperature measurements, a separate 10-meter (33-foot) tower for dew point measurements, a ground-based instrument for rainfall measurements, and a data collection system in an instrument building. Figure 2.2-1 of the ER identifies one meteorological tower to the east of the central site area. Please clarify if the 91-meter is tower located is to the east of the central site area as shown in figure 2.2-1 and identify where the 10-meter tower is located.

Noise (NOI)-1-FSA: Section 3.3 of the ER identifies sources at BFN that generate noise and identifies that the noise from the cooling towers can be heard outside. a.

Section 2.2 of the ER states that five of the original six cooling towers have been replaced (cooling towers 1 and 3-6), cooling tower 2 is scheduled for replacement by 2027, and cooling tower 7 was constructed in May 2012. When were cooling towers 1 and 3-6 replaced? b. Primary offsite noise sources in the vicinity of BFN are not discussed in the ER. Please identify the primary offsite noise sources in the vicinity of BFN.

NOI-2-FSA: Section 3.3 of the ER states that the 2012 noise measurements were measured at the location of the nearest residence to BFN in the Paradise Shores Community, approximately 1,500 feet from the BFN property boundary. What is the distance between the sample location (nearest residence) and the cooling towers?

Was the sample location the nearest residence to the cooling towers?

NOI-3-FSA: Section 3.3 of the ER states that a second 24-hour ambient noise assessment was conducted between July 30 and July 31, 2020, at the same sample location as in 2012, during which a day/night sound level of 62.5 dBA was calculated (Cardno 2020). Please confirm that the cooling towers were in operation during the 2020 ambient noise assessment.

7 NOI-4-FSA: Section 3.3 of the ER identifies that in 2020 and 2022 noise levels were measured. Were measurements made when the cooling towers were not in operation? If so, please provide the noise levels when the cooling towers were not in operation.

NOI-5-FSA: Section 3.3 of the ER states that there are no noise complaints on record for Browns Ferry. Have any noise complaints been made since submission of the ER to the NRC?

Spent Nuclear Fuel (SNF)-1: Section 2.2.4.4 of the ER states: Expansion of the onsite spent fuel storage capacity is required in the future if a national storage solution for the permanent storage of spent fuel does not become available during the subsequent period of extended operation. The current Independent Spent Fuel Storage Installation (ISFSI) storage pads are projected to be filled on or before year 2036. Under the existing licenses and assuming decommissioning at the end of the current license periods, an additional 104 dry fuel storage casks will be needed to support operations and decommissioning. The addition of a third ISFSI storage pad to further increase storage capacity needed for the subsequent period of extended operation is under consideration, but plans are in the conceptual stage and no installation schedule has been established. The BFN site has adequate space onsite to accommodate the construction of an additional ISFSI pad if necessary. Please discuss the storage plans for the spent fuel produced during the license renewal term, including the plans and the potential area for expansion or additional storage locations necessary for capacity for license renewal term.

SNF-2: Provide a discussion regarding the burnup levels of the BFN spent fuel being stored in the spent fuel pools and the ISFSI given that the levels could be between 33,000 to 62,000 MWd/MTU and whether there are any plans to extend the maximum burnup levels above 62,000 MWd/MTU during the license renewal term.

SNF-3: Please provide related burnup levels of the spent fuel being stored at the BFN site.

Surface Water Hydrology (SW)-1: ER tables 2.2-1 and 2.2-2 present average daily water withdrawals and consumption by month from Wheeler Reservoir between 2016 to 2022. Please update these tables with more recent data, if available.

SW-9: The withdrawal and consumption values discussed in ER Section 4.5.1.8 are slightly different than those presented in tables 2.2-1 and 2.2-2. For example, ER Section 4.5.1.8 states that in 2020, BFN withdrew approximately 3,289 million gallons per day (MGD) from Wheeler Reservoir of which approximately 6 MGD were consumed while tables 2.2-1 and 2.2-2 present withdrawal and consumption values of 2,738 MGD and 5.3 MGD, respectively. Please clarify this apparent discrepancy.

SW-10: For each of the last 5 years, please provide the number of days per year the cooling towers have operated.

8 SW-13: Please provide a figure illustrating the site water balance.

SW-14: Please provide a figure illustrating the locations of the NDPES external outfalls.

SW-15: Please provide a figure illustrating the Federal Emergency Management Agency floodplain zones at the BFN site.

SW-16: Please provide a figure illustrating the location of the submerged cooling water discharge diffuser pipes.

SW-17: Please provide a time series figure illustrating the monthly average intake and discharge temperatures for the available period of record. WM-2-LSA: Please provide the appropriate section of the BFNs Updated Final Safety Analysis Report that describes the associated gaseous radioactive waste management systems to meet the guidance provided in RG 4.2, Supplement 1, Sections 2.2 and 3.11.

GEOLOGIC ENVIRONMENT GEO-2 As discussed during the environmental audit and in response to information need GEO-02, there have been ten Condition Reports documenting minor erosion at multiple plant locations over the last five years. Corrective actions have been taken, or open work orders are in place, to address these incidents of erosion. Site procedures require corrective actions for documented Condition Reports. Please confirm that the above summary is correct.

SURFACE WATER HYDROLOGY SW-3 As discussed during the environmental audit and in response to information need SW-03, TVA provided the description of the Open and Helper mode. (1) Open - Component Cooling Water (CCW) flow is from the forebay, through the CCW pumps, through the condenser, and out to the river through Gate Structure 1A and the diffusers (towers are not in operation in this mode). (2)

Helper - CCW flow is the same initially as Open mode. Water comes from the forebay via the CCW pumps and condenser but is diverted from returning to the river to go to the warm water channel by closing Gate Structure 1A. This forces CCW flow into the warm water channel through Gate Structure 1B. Water can also be pulled into the warm water channel by establishing vacuum in the cooling water system. Water is pumped from the warm water channel to the cooling towers via lift pumps allowing evaporative cooling to cool the water with the assistance of the air drawn in from the cooling tower fans. The cooled water falls to the tower basin where it is sent to the cold water channel, then out to the river through Gate Structure 1 and diffusers. Water consumption does not change substantially. This change is from system backpressure and the value (change in water consumption) is not directly known.

The Helper mode is in operation when the downstream water temperature reaches 10°F and/or the water coming out from the condenser reaches ~91.5°F. Please confirm that the above summary is correct.

9 SW-4 As discussed during the environmental audit and in response to information need SW-04, TVA mentioned that BFN is currently operating on an administratively continued NPDES permit (AL0022080, which expired in August 2023). TVA is currently working on an addendum that would request a 7-day rolling average downstream temperature limit instead of the current daily average. This is expected to delay the NPDES permit issuance even further. Please confirm that the above summary is correct.

SW-5 As discussed during the environmental audit and in response to information need SW-05, TVA provided the NPDES/State Indirect Discharge Noncompliance Notification Report (Form 421) as per Alabama Department of Environmental Management for the monitoring period 01/01/2024 to 01/31/2024. The report suggested no effluent violations. However, there was one monitoring/reporting violation related to exceeding the 48-hour maximum hold time for biochemical oxygen demand (BOD) (a biweekly sample for BOD and outfall DSN13C1 was collected on January 2, 2024, at 0734, while the lab began analysis on the BOD sample on January 4, 2024, at 1430, exceeding the hold time). The following biweekly sample was collected and analyzed as required by the NPDES permit (AL0022080). As per the report, to reduce or eliminate the noncomplying discharge and to prevent its recurrence, a condition report was entered (CR1912226) and the corrective action program process will be followed to determine corrective actions. The condition report was entered into the BFN corrective action program database. The following corrective actions are complete.

a) Determine if biological NPDES parameters can be analyzed in-house, using TVA-owned equipment, in a cost effective and efficient manner.

b) Details: Existing Action Tracking Action for Biweekly DSN13C1 monitoring should be moved from a monthly recurrence to a weekly recurrence. The instructions should also be added to deliver BOD samples to the lab the same day of sample collection unless prior arrangements are made.

c) Review for extent of conditions and develop an operating experience and share with environmental operations and other groups as determined appropriate.

d) Evaluate Southern Environmental Testings contract to determine if unusual sample information should be communicated with the TVA contact for that sample report.

Evaluate if hold time issues are required to be noted on lab report.

Please confirm that the above summary is correct.

SW-6 As discussed during the environmental audit and in response to information need SW-06, TVA provided the memorandum of understanding (MOU) between TVA and the Department of Army (DA) (Contract No. TV-63835A, signed on May 28, 1985). This MOU is a cooperative agreement between TVA and DA in recognition of each agencys responsibilities for regulating the waters of the US and their related responsibilities under NEPA of 1969. The authorities listed in this MOU are: Section 10 of the Rivers and Harbors Act of 1899 (RHA); Section 404 of the Clean Water Act (CWA), Section 26a of the TVA Act of 1933. However, the RHA of 1899 permit would not be required for BFNs license. Please confirm that the above summary is correct.

10 SW-7 As discussed during the environmental audit and in response to information need SW-21, TVA provided the certificate to withdraw/use water as per Alabama Water Use Reporting Program dated June 16, 2017 (State of Alabama, Certificate of Use, Certificate No. 1058.0). As mentioned in the certificate, the maximum withdrawal capacity is 2851.200 MGD and the average annual withdrawal is 1031563.00 million gallons per year (MGY) (from the Wheeler Lake). The certificate expires on January 1, 2027. Also, according to Sharkey and Springston (2022), as cited in the ER, by the year 2045, even though water demands from industry, public water supply, and irrigation are expected to increase, overall water withdrawals from the Tennessee River Watershed are projected to decline from 2015 levels, primarily due to the retirement of old coal-fired power plants. Please confirm that the above summary is correct.

SW-11 As discussed during the environmental audit and in response to information need SW-11, TVA has confirmed that continuous monitoring of the aquatic community within Wheeler Reservoir show a balanced and indigenous aquatic community population. Impairments listed by ADEM include excess nutrients attributed to agriculture, elevated mercury, and perfluorooctane sulfonate. Total suspended solids and mercury are parameters listed in BFNs NPDES permit with limits assigned by ADEM/Environmental Protection Agency (EPA). BFN is currently on an administratively continued permit since the NPDES permit (AL0022080) expired in August 2023, and a renewal has been submitted. These are sampled and reported on BFNs discharge monitoring report submitted to ADEM each month. TVA has developed a PFOS team to ensure sites across TVA, including BFN, are in compliance with any current or future PFOS regulation.

Please confirm that the above summary is correct.

SW-12 As discussed during the environmental audit and in response to information need SW-12, TVA has confirmed that BFNs process and stormwater discharges are regulated by the NPDES permit issued by ADEM every 5 years. BFN is currently on an administratively continued permit since the NPDES permit (AL0022080) expired in August 2023, and a renewal has been submitted. Constituents that could impact the surface water quality of Wheeler Reservoir are considered and appropriate limits are assigned based on current regulatory requirements. The CWA section 402(o)(1) prohibits the relaxation of effluent limitations. BFN will continue to obtain and stay within compliance of the NPDES permit, ensuring current and future protection to surface water quality. As per the ER, impacts from the BFN subsequent license renewal on surface water quality would be SMALL and will not warrant mitigation. Surface water discharges are regulated under the NPDES permit program, which includes conditions requiring BFN to prevent or minimize any surface water runoff from stormwater. BFN monitors surface water quality in accordance with its NPDES permit. Compliance with the current NPDES and stormwater regulatory requirements and permit conditions as well as implementation of the storm water pollution prevention plan (SWPPP), best management practices, and integrated pollution prevention plan (IPPP) will ensure continued insignificant impact on surface water quality during the subsequent period of extended operation. The ER also addresses impact from potential discharges of chemicals. Compliance with the NPDES permit requires all discharges are monitored and constituents controlled. IPPP ensures the impact of biocides and minor chemical spills would continue to be limited and the impact to surface water quality is SMALL.

BNF concluded that contribution to a cumulative impact to surface water quality would be SMALL during the SLR term. Please confirm that the above summary is correct.

11 SW-18 As discussed during the environmental audit and in response to information need SW-18, TVA has confirmed that they adopted a revised Reservoir Operating Policy in mid-2004, which changed the duration most reservoirs remained at the summer pool level until at least mid-October for the Tennessee River reservoirs. TVA controls the winter and spring flood events by utilizing the extra storage provided by lowering the reservoir pool in the fall by approximately four feet. Reservoir levels generally stay within a typical range, with higher levels in the summer and lowered levels during the fall drawdown. Please confirm that the above summary is correct.

SW-19 As discussed during the environmental audit and in response to information need SW-18, TVA has confirmed that BFN does not maintain an active SWPPP. The ER states that BFN maintenance activities that could require a construction stormwater permit will obtain the required permit and comply with the stormwater management and BMPs requirements. A SWPPP will be prepared prior to initiation of any ground-disturbing activities at the site. The ADEM generic permit for stormwater discharge from large and small construction activities (ALR100000) is a general permit that requires preparation of a SWPPP that identified BMPs to minimize erosion and sediment resulting from stormwater runoff (Alabama Administrative Code Chapter 335-6-6). Please confirm that the above summary is correct.

SW-20 As discussed during the environmental audit and in response to information need SW-20, TVA has provided the IPPP (BFN-TPP-ENV-007, Rev. 0003, effective date 03-10-2023). As per the document, the purpose of the BFN IPPP is to serve as a management tool to minimize the risk of a Comprehensive Environmental Response, Compensation and Liability Act Reportable Spill, Polychlorinated Biphenyls release, or accidental release of other hazardous materials (as defined in the IPPP document). This IPPP satisfies the regulatory requirements for Oil Pollution Prevention (40 CFR 112), Resource Conservation and Recovery Act (RCRA) Preparedness and Prevention (40 CFR Part 265 Subpart C), a RCRA Contingency Plan [40 CFR 122.44(k)(4a)] for toxic and hazardous pollutants. A copy of the IPPP document is kept available for use onsite at all times and for regulatory review during normal working hours [40 CFC 112.3(e)]. This IPPP ensures that oil, hazardous materials, and other pollutants potentially capable of discharge to the waters of the U.S. are managed consistently and efficiently to prevent spills or discharges and should spillage or discharge occur, ensure it is contained, cleaned up, and corrective actions initiated. Radioactive materials are excluded from consideration, except for mixed waste storage. Please confirm that the above summary is correct.

SW-21 As discussed during the environmental audit and in response to information need SW-07, TVA provided the certificate to withdraw/use water as per Alabama Water Use Reporting Program dated June 16, 2017 (State of Alabama, Certificate of Use, Certificate No. 1058.0). As mentioned in the certificate, the maximum withdrawal capacity is 2851.200 million gallons per day and the average annual withdrawal is 1031563.00 MGY (from the Wheeler Lake). The certificate expires on January 1, 2027. Please confirm that the above summary is correct.

SW-23 As discussed during the environmental audit and in response to information need SW-23, TVA provided the requested document (Browns Ferry Nuclear Plant Thermal Performance Program Cooling Tower Capacity Improvements Environmental Assessment. June 2020). This

12 environmental assessment (EA) provides the environmental impacts of cooling tower capacity improvements across different resource areas including air quality and climate change, geology and groundwater, wetlands, floodplains, soil erosion and surface water, aquatic ecology, terrestrial zoology, botany, archaeology, historic sites and structures, noise, solid and hazardous waste and hazardous materials, and transportation. The proposed action included demolition of existing CT1 and CT2 and replacement with two CTs; replacement of CTLP1A, CTLP1B, CTLP2A, and CTLP2B; upgrade of the flow distribution system to gain use of all four CTLPs on CT7; upgrades to the vacuum priming system and cold water channel outlet gage; and addition of a CT condenser circulating water chlorination system. The EA concluded no impacts for wetlands, floodplains, aquatic ecology, archaeology, and historic sites and structures. Minor, temporary, and localized impacts during the construction phase were identified for air quality and climate change, geology and groundwater, soil erosion and surface water, terrestrial zoology, botany, noise, solid and hazardous waste and hazardous materials, and transportation. No impacts were identified during the operational phase. Please confirm that the above summary is correct.

SW-24 As discussed during the environmental audit and in response to information need SW-24, TVA provided the requested document (i.e., TVA. 2020c. ADEM NPDES/SID Non-Compliance Notification Form. July 20, 2020), which reports a non-compliance for the monitoring period of April 01, 2020, to June 30, 2020. The exact period of noncompliance was May 07, 2020, at 0950 to 1215 Central Daylight Time. As mentioned in the provided document, the cause of non-compliance was due to the exceedance of maximum allowable TRC (total residual chlorine) at U3 CCW outfall (DSN001Q). During the second hourly sample, TRC was found in excess of the permit limit of 0.031 mg/l (ppm). The recorded TRC were 0.14 mg/l and 0.16 mg/l for the two samples tested. Injection of sodium hypochlorite (bleach) was stopped, and the bisulfite feed pump was found not rotating (i.e., pumping). The shift manager and Environmental were notified along with the Station Duty Manager. The fix-it-now team and Chemistry went out to trouble shoot the bisulfite pump and found that it had tripped on low flow. The pump was reset and restarted, and the pump functioned link normal. To reduce or eliminate the noncomplying discharge and to prevent its recurrence, BFN is in the process of a design change that will install a radio control system allowing for automatic termination of the sodium hypochlorite into the CCW system if low flow of the detoxifying agent sodium bisulfite is detected at the injection point. Please confirm that the above summary is correct.

GROUNDWATER HYDROLOGY GW-3 As discussed during the environmental audit and in response to information need GW-03, TVA provided information regarding historical groundwater dewatering at the site. Dewatering occurred between 1969 and 1984 to support construction and to mitigate leakage to plant substructures. Dewatering ceased in 1984 due to movement of soil fines into the dewatering wells and settlement of plant systems, structures, and components. Leakage is currently mitigated using methods other than dewatering and there are currently no plans for future groundwater dewatering at the site. Please confirm that the above summary is correct.

GW-4 As discussed during the environmental audit and in response to information need GW-04, TVA conducted slug tests to evaluate saturated hydraulic conductivities at the site. Rising and falling head slug tests were conducted in wells screened in unconsolidated sediments and fill materials (MW-01, MW-03, MW-04, MW-07, MW-08, MW-09, and MW-10) and in a well screened in

13 bedrock (6R). Tests were conducted using a solid slug (49 inches long and 1.5 inches in diameter) and a pressure transducer to record continuous head data. Three saturated hydraulic conductivity values were estimated for each well from four tests (two falling head and two rising head) conducted in each well. Average values determined from the slug tests and lithology of the tested zones are as shown in the table below for each well. Please confirm that the above summary and the table below are correct.

Well No.

Average Ksat (ft/d)

Lithologic Description MW-01 32.7 85% clay with 15% gravel and chert MW-03 76.1 Gravel and weathered bedrock MW-04 193.1 Contact between 95% clay/silt with 5% coarse sand/gravel and weathered bedrock MW-07 0.1 99% compact clay with trace coarse sand and gravel MW-08 155.3 90% clay/silt with 5% coarse sand and 5% gravel MW-09 14.1 95% clay/silt with 5% coarse sand and gravel MW-10 19.1 95% clay/silt with 5% coarse sand and gravel 6R 7.2 Fine-grained, competent limestone - Tuscumbia Limestone GW-7 As discussed during the environmental audit and in response to information need GW-07, TVA stated that there have been no inadvertent spills or leaks of radiological contaminants since the preparation of the 2023 Annual Radiological Effluent Release Report (January 2024). Please confirm that this statement is correct.

GW-8 As discussed during the environmental audit and in response to information need GW-08, TVA stated that there have been no inadvertent spills or leaks of nonradiological contaminants in the last ten years that are known to have affected groundwater quality. Please confirm that this statement is correct.

TERRESTRIAL ECOLOGY TER-2 As discussed during the environmental audit and in response to information need TER-02, TVA stated that the query for protected species was run for a 6-mile radius around the site and the bald eagle located approximately 5.4 miles from the site was the only new information. The other information within the environmental report is valid for a 6-mile (10 km) radius around the site. Please confirm if the above summary is correct.

TER-3 As discussed during the environmental audit and in response to information need TER-03, TVA states that an additional survey was completed on September 16, 2024, and found one active nest on a transmission tower north of the site and additional active nests on four water monitoring stations within the Tennessee River. Ospreys are no longer nesting where they were observed in 2021. In addition, TVA has a contract with US Department of Agriculture-Animal and Plant Health Inspection Service wildlife services if a nest removal is necessary. Please confirm the above summary is correct.

14 TER-4 As discussed during the environmental audit and in response to information need TER-04, TVA stated that no records have been kept for bird collisions onsite or no formal avian protection plan. In addition, the standard procedure is to call U.S. Fish and Wildlife Service (USFWS) or Alabama Department of Conservation and Natural Resources if any dead or injured species of concern is observed onsite. TVA is currently drafting a Memorandum of Agreement with USFWS that will include an Avian Protection Plan. Please confirm the above summary is correct.

TER-5 As discussed during the environmental audit and in response to information need TER-05, TVA stated there is no formal management plan but if an invasive species becomes problematic than the Browns Ferry site staff would issue a condition report and develop a corrective action program to manage. Please confirm that the above summary is correct.

AQUATIC ECOLOGY AQU-3 As discussed during the environmental audit and in response to information need AQU-03, river water moves past the barges, that are used to prevent eelgrass and other vegetation from entering the intake forebay bay, through the gate structure, then through the 1 5/8 spaced trash racks, and finally through the traveling screens. The trash racks are raked as needed, to clear debris and that debris is put in a dumpster and then disposed of with nonhazardous waste. The traveling screens are washed as they turn and debris that is rinsed off flows into a channel that drains back into the lake. Please confirm that the above summary is correct.

AQU-5 As discussed during the environmental audit and in response to information need AQU-05, per 40 CFR 125.94 BFN has chosen option (5) modified traveling screens for impingement compliance. TVA will be required to send ADEM the chosen impingement compliance option and a proposed schedule of when it will be implemented 180 days after BFN received the re-issued NPDES permit. Since the permit has not been re-issued yet, BFN has proactively moved forward with option (5) modified traveling screens due to the long lead times, challenging installs, and a 2-year optimization study. The details on the design and execution dates are still in progress. TVA will be required to have screens/fish return operational and optimized by the end of BFNs next NPDES permit cycle (5 years after the new permit is received from ADEM).

Since BFN has already installed modified traveling water screens installing a fish return system that aligns with Electric Power Research Institutes Design of Fish Return Systems and Operations/Maintenance Guidelines, and completion of an optimization study will be the main tasks to complete this next NPDES permit cycle. Please confirm that the above summary is correct.

AQU-6 As discussed during the environmental audit and in response to information need AQU-06, a review of TVAs data showed that Zebra mussels have been collected in limited numbers in benthic community samples from Wheeler Reservoir. Zebra mussels have not been collected in the BFN intake forebay or the Elk River Embayment. Excluding those locations, a total of 420 Ponar samples have been collected and processed in a lab. Zebra mussels were present in 12 of those samples. A total of 18 zebra mussels have been collected and only 1-2 were collected in any individual Ponar sample. They are more frequent at the inflow station below Guntersville

15 Dam (TRM 347.0, 8 samples), followed by TRM 295.9 (3 samples), then TRM 290.4 (1 sample).

In addition, TVA also monitors Zebra mussel and Asiatic clam densities through their veliger sampling program. TVA collects weekly samples at the skimmer wall of BFNs intake to quantify the mean number of individuals per cubic meter entering the water intake system. Chemical treatments are routinely scheduled regardless of data, however, this data aids in notifying the treatment team of large numbers of zebra mussels and Asiatic clams during the span of time between treatments. BFN typically has 3 molluscicide treatments from spring to fall, followed by two 21-28 day chlorination, spread out 8-12 weeks. Raw water chemical treatments for mollusks are controlled by BFN chemistry procedure CI-137, Raw Water Chemical Treatment and regulated by the NPDES permit. Quagga mussels have not been reported in TVAs benthic community data. Please confirm that the above summary is correct.

AQU-8 As discussed during the environmental audit and in response to information need AQU-08, the regulation of the Tennessee River and its tributaries through the TVA system of dams and reservoirs controls the rate of water movement through the reservoir system. The timing of reservoir releases changes the residence time of water in the reservoir and the pattern of downstream flows. Residence time influences several water quality constituents directly and many more indirectly. Temperature, dissolved oxygen (DO), and the production of algae are affected directly by residence time. The timing and degree of thermal stratification is also directly related to residence time. DO concentrations in reservoirs are related to thermal stratification, oxygen demand (biological, chemical, and sediment), and the timing and depth of water releases. Residence time and the availability of nutrients and light affect the dynamics of algal growth. In turn, algae play a critical role in the DO balance of the system. In the context of reservoir operations, residence time, thermal stratification, DO depletion, and algal growth are key water quality processes. They reflect overall water quality conditions, eutrophication, and the ability of the reservoir to assimilate waste. DO concentrations in the mainstem reservoirs are generally higher than in the tributary reservoirs. The primary reason is the movement of water through the reservoirs, resulting in greater mixing, aeration, and less opportunity for thermal stratification and biochemical reactions. The stratification that does occur is typically broken up when flows are increased progressively in June, July, and August. The turbines that pass much of the outflow from the mainstem reservoirs generally pass some surface water with the deeper water, resulting in higher DO concentrations in the tailwaters when compared to the tailwaters of the tributary reservoirs. Therefore, the balance of TVAs River operations and minimum flow requirements established for the operation of BFN have proven to provide conditions favorable for maintaining adequate DO levels in Wheeler Reservoir. Please confirm that the above summary is correct.

AQU-9 As discussed during the environmental audit and in response to information need AQU-09, when the intakes channel was dredged in 2018 an estimated 13,875 cubic yards of material was removed. River management and US Army Corps of Engineers monitors and surveys the area to determine if it needs to be dredged and there are currently no plans for additional dredging.

Please confirm that the above summary is correct.

AQU-10 As discussed during the environmental audit and in response to information need AQU-10, the mechanical draft cooling towers typically have a 2-3 percent water loss due to evaporation and drift when operational. BFN uses the cooling towers in summer months with July and August seeing the most use. BFN has not calculated the actual water loss from cooling tower operation

16 but they do track water consumption on a monthly basis, 97 percent of the water taken out of the river is returned to the river when the cooling towers are operational (3 percent loss) and when averaged across the whole year the total water loss is 0.11 percent. Please confirm that the above summary is correct.

FEDERALLY PROTECTED ECOLOGICAL RESOURCES FED-1 As discussed during the environmental audit and in response to information need FED-01:

1) TVA has to date not found milkweed or monarchs on the Browns Ferry site; 2) Although TVA has not conducted surveys to specifically assess the presence of either the monarch butterfly or milkweed on the site, it is likely that milkweed may occur on the unmowed portions of the Browns Ferry site; 3) most of the BFN site consists of plant facilities, parking lots, roads, and mowed grass fields, 4) mowing and selective herbicide application are the predominant methods for on-site vegetation management, along with brush hogs and occasional hazard tree removal, 5) on-site vegetation management under transmission lines is covered under TVAs 2024 Transmission System Routine Periodic Vegetation Management Environmental Assessment (EA), 6) TVA provided its Pollution Control Plan and Guide for Environmental Protection and Best Management Practices for Tennessee Valley Authority Construction and Maintenance Activities for NRC staff review, 7) TVA considers potential adverse impacts of herbicide application when selecting chemical, formulation, and application method, 8) all herbicides are applied by trained and licensed applicators, who apply chemicals according to label instruction, EPA guidelines, and applicable regulations; and 9) TVA follows all BMPs and processes for vegetation management detailed in the Guide for Environmental Protection and Best Management Practices for Tennessee Valley Authority Construction and Maintenance Activities, 2024 Transmission System Routine Periodic Vegetation Management EA, and Pollution Prevention Plan. Please confirm that the above summary is correct.

FED-3 As discussed during the environmental audit and in response to information need FED-03, Environmental Report Table 3.6.-4, which lists fish species collected by TVA in the vicinity of Browns Ferry from autumn 1993-2020 is complete with the addition of paddlefish (Polyodon spathula), which was collected only once, in 2019. Please confirm that the above summary is correct.

HISTORIC AND CULTURAL RESOURCES HCR-2 As discussed during the environmental audit and in response to information need HCR-02:

The APE is the 880-acre BFN site Two archaeological sites, LI286 and LI856 were merged with LI284 and LI287 respectively, resulting in 15 sites now within the APE.

Of the 15 sites, 10 sites are not eligible for the NRHP (LI24, 812, 857, 915, 916, 917, 918, 919, 920,921), 2 are potentially eligible (LI23 and 525), and three sites are undetermined (LI284, 287, and 536).

Please confirm that the above summary is correct.

HCR-4 As discussed during the environmental audit and in response to information need HCR-04:

17 TVAs cultural compliance staff consists of 32 staff overseen by a Cultural Compliance Manager. This includes 13 archaeologists and one architectural historian.

TVA maintains a cultural resource management system to track and document their projects. On average, TVA staff review approximately 2,000 projects a year.

TVA has existing data sharing agreements with some state agencies and has access to state data on recorded archaeological sites, inventoried historic architectural properties, and previous cultural resources surveys.

TVA hires private cultural resources management firms to support in-field services such as Phase I and II surveys and archaeological data recovery projects.

TVA executed a programmatic agreement in 2019 with seven Tennessee Valley states (Kentucky, Tennessee, Virginia, Mississippi, Alabama, Georgia, and North Carolina) excluding certain activities from the Section 106 process. The Programmatic Agreement (PA) also identifies a second set of activities that may be carried out without consultation, if performed within specified bounding conditions, and provide identification efforts that have been completed and no historic properties were identified that would be affected.

Please confirm that the above summary is correct.

HCR-5 As discussed during the environmental audit and in response to information need HCR-05, TVA has a Comprehensive Agreement signed with the Absentee Shawnee Tribe of Indians of Oklahoma, Alabama-Coushatta Tribe of Texas, Alabama-Quassarte Tribal Town, Cherokee Nation, the Chickasaw Nation, Eastern Band of Cherokee Indians, Eastern Shawnee Tribe of Oklahoma, Jena Band of Choctaw Indians, Kialegee Tribal Town, Mississippi Band of Choctaw Indians, The Muscogee (Creek) Nation, Osage Nation, Poarch Band of Creek Indians, the Quapaw Nation, the Seminole Nation of Oklahoma, the Shawnee Tribe, Thlopthlocco Tribal Town, and the United Keetoowah Band of Cherokee Indians in Oklahoma which establishes an efficient process under the Native American Graves Protection and Repatriation Act on the treatment of human remains and/or cultural items within TVA lands. Please confirm that the above summary is correct.

HCR-7 As discussed during the environmental audit and in response to information need HCR-07, TVA does not have any plans at this time to repurpose, alter, or remove the National Register-eligible Browns Ferry Aquatic Research Facility. Please confirm that the above summary is correct.

HCR-9 As discussed during the environmental audit and in response to information need HCR-09, all undisturbed areas on BFN have been surveyed archaeologically. The results are described in the Dison et al. 2022 report. Please confirm that the above summary is correct.

HCR-12 As discussed during the environmental audit and in response to information need HCR-12, TVA does not have any current plant improvements scheduled. If maintenance or upgrades were to

18 occur in the future, TVA would consult with SHPO to consider the potential effects on BFN from any potential undertaking. Please confirm that the above summary is correct.

WASTE MANAGMENT WM-2 As discussed during the environmental audit and in response to information need WM-02, the TVA procedures under the Integrated Pollution Prevention Plan and A Guide for Environmental Protection and Best Management Practices for Tennessee Valley Authority Construction and Maintenance Activities, Revision 4, 2022 would generate the specific best management practices to be applied for an approved activity. Please confirm that the above summary is correct.

WM-3 As discussed during the environmental audit and in response to information need WM-03, there are no proposed changes or upgrades to the effluent control program being considered during the license renewal term. Please confirm that the above summary is correct.

WM-4 As discussed during the environmental audit and in response to information need WM-04, there have not been any reportable releases which would trigger the reporting provisions of 40 CFR Part 110 since the ER was written. Please confirm that the above summary is correct.

WM-5 As discussed during the environmental audit and in response to information need WM-05, there have not been any reportable unplanned releases of radioactive materials (unplanned/inadvertent radioactive liquid or gaseous releases) which would trigger a notification requirement since the ER was written. Please confirm that the above summary is correct.

WM-6 As discussed during the environmental audit and in response to information need WM-06, there have not been any reportable inadvertent releases or spills of nonradioactive contaminants which would trigger a notification requirement since the ER was written. Please confirm that the above summary is correct.

19 BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 SUBSEQUENT LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW REQUEST FOR ADDITIONAL INFORMATION GEOLOGIC ENVRIONMENT GEO-1 REQUIREMENT: The requirements in 10 CFR 51.45(b) and 51.53(c)(2) state that the ER shall include a description of the affected environment.

ISSUE: The NRC staff is preparing an environmental impact statement (EIS) that considers the impacts of subsequent license renewal for Browns Ferry on the affected geologic environment.

NRC staff requested detailed information regarding site geology including cross-section figures.

The cross-section figures included in the ER supplement in response to info need GEO-1 (figures 3.4-1 to 3.4-5) are of a resolution that prevents the reader from clearly seeing all the text and figure details.

REQUEST: Please provide high resolution Geologic cross-section figures, figures 3.4-1 to 3.4-5 in the ER supplement.

GROUNDWATER HYDROLOGY GW-6 REQUIREMENT: The requirements in 10 CFR 51.45(b) and 51.53(c)(2) state that the ER shall include a description of the affected environment. In addition, 10 CFR 51.53(c)(3)(ii)(P) requires that the ER contain an assessment of the impact of any documented inadvertent releases of radionuclides into groundwater, which includes descriptions of the applicants groundwater protection program, past inadvertent releases, and projected impacts to the environment (aquifers and connected surface water bodies) during the license renewal term.

ISSUE: The NRC staff is preparing an EIS that considers the impacts of subsequent license renewal for Browns Ferry on affected groundwater resources. The NRC staff requested detailed information regarding site geology (affecting groundwater occurrence and movement),

groundwater levels, TVAs groundwater protection program, monitoring wells, and inadvertent releases of radioactive liquids for which a pathway to groundwater may exist. TVA responses to these requests referred to the 2021 Site Conceptual Model Update, prepared under the groundwater protection program.

REQUEST: Please provide the 2021 Site Conceptual Model Update discussed by TVA during the October 2024 Environmental Audit and referenced in the ER as Arcadis. 2021. 2021 Site Conceptual Model Update. Browns Ferry Nuclear Plant. Athens, Alabama. September.

TERRESTRIAL ECOLOGY TER-1 REQUIREMENT: The requirements in 10 CFR 51.45(b) and 51.53(c)(2) state that the ER include a description of the affected environment.

ISSUE: The NRC staff is preparing an EIS that considers the environmental impacts of subsequent license renewal for Browns Ferry. As part of the preparing the EIS, the staff must consider whether the has been any new information related to terrestrial resources. During the

20 October 2024 environmental audit, virtual tour and Terrestrial Resources breakout session, TVA discussed the meteorological (MET) towers, plant stack, and other tall structures onsite. After the audit, the NRC staff reviewed the Federal Aviation Administration (FAA) Digital Obstruction File (DOF) for Alabama from the FAA website:

https://www.faa.gov/air_traffic/flight_info/aeronav/digital_products/dof/.

REQUEST: 1) Please provide the height above ground level (AGL) in feet for both MET towers, state whether they are guyed or free standing, and describe lighting regime if lit. The DOF for the tall MET tower (OAS_NUM 01-000455) reported lighting regime as unknown. If MET tower has lights at different heights, then describe lighting at each level by color and whether steady or flashing. 2) For the three other structures within the site boundaries that are listed in the DOF that are not transmission structures (01-000343, 01-003112, 01-000281), please confirm that DOF AGL in feet is correct and describe the lighting regime (locations on structure, color, flashing or not). Because DOF structure 01-003112 is a communications tower, please state whether this is guyed or freestanding. 3) Provide a list of all the buildings and structures within the site boundaries that are greater than above 100 feet AGL and are not listed in the DOF, with the name of the building/structure, height as AGL (ft) and lighting regime as requested for the other structures.

FEDERALLY PROTECTED ECOLOGICAL RESOURCES FED-2 REQUIREMENT: The requirements in 10 CFR 51.53(c)(3)(ii)(E) state that the impact of the proposed action on federally protected ecological resources, including the Endangered Species Act, shall be assessed. In addition, the requirements in 10 CFR 51.41 indicate that NRC may direct the applicants to provide NRC information to complete their NEPA process.

ISSUE: The NRC staff is preparing an EIS that considers the environmental impacts of subsequent license renewal for Browns Ferry. As part of preparing the EIS, the staff must consider whether there has been any new information related to species protected under the Endangered Species Act. Since the initial license renewal SEIS, TVA has developed and updated a bat conservation and compliance strategy. FWS issued a biological opinion on the strategy in 2018 and 2023. During the environmental audit in responses to information needs FED_02 and FED-04, TVA provided information regarding management and protection of federally listed bats and their habitat on the Browns Ferry not previously included in the ER.

REQUEST: Please provide documentation relating to Browns Ferry compliance with the 2018 and 2023 Biological Opinions for Tennessee Valley Authoritys Programmatic Strategy for Routine Actions that May Affect Endangered and Threatened Bats. Please include the following:

1) a summary of the tree removals and forest management activities (# trees, acres) on the Browns Ferry site and TVA managed lands overall by season and year, 2) the Project Review form for the clearing of forest around the MET tower on Browns Ferry site, 3) any other project review forms on the Browns Ferry site related to tree removal from 2018-2024, 4) a summary of Browns Ferry policies and procedures meeting the requirements related to the handling and reporting of dead or injured listed species (2023 BO Monitoring and Reporting Requirement #3);

5) a summary of correspondence from FWS relating to bat incidental take from required annual reports submitted between 2019-2024 6) clarify whether TVA has updated BO from FWS to cover tricolored bat. If so, please provide.

FED-7 REQUIREMENT: The requirements in 10 CFR 51.53(c)(3)(ii)(E) state that the impact of the proposed action on federally protected ecological resources, including the Endangered Species

21 Act, shall be assessed. In addition, the requirements in 10 CFR 51.41 indicate that NRC may direct the applicants to provide NRC information to complete their NEPA process.

ISSUE: The NRC staff is preparing an EIS that considers the environmental impacts of subsequent license renewal for Browns Ferry. As part of the preparing the EIS, the staff must consider whether there has been any new information related to species protected under the Endangered Species Act. The FWS lists whooping crane (Grus americana) as an experimental, non-essential population in Alabama. As part of its independent review of federally protected ecological resources, the NRC staff observed that there are many recorded observations of whooping crane along the shoreline of Wheeler Reservoir. Potential effects on this species are not discussed in the ER.

REQUEST: Please provide a brief discussion of potential impacts to whooping cranes, including the following: 1) a description of what is known regarding whooping crane use of the site and vicinity; 2) a description of possible mortality or injury from whooping crane collisions with onsite structures and vehicles, 3) a description of possible whooping crane habitat loss, degradation, disturbance, fragmentation, and associated effect related to refurbishment or other site activities, and 4) a description of possible whooping crane behavior changes resulting from refurbishment or other site activities.

AQUATIC ECOLOGY AQU-2 REQUIREMENT: The requirements in 10 CFR 51.53(c)(3)(ii)(B) state that impingement mortality and entrainment of aquatic organisms (plants with once-through cooling systems or cooling ponds), shall be assessed.

If the NPDES permitting authority has made BTA determinations for the nuclear power plant pursuant to CWA Section 316(b) in accordance with the current regulations at 40 CFR 122 (Ref.

55) and 40 CFR 125 (Ref. 56), which were promulgated in 2014 (79 FR 48300) (Ref. 57), and the plant has implemented any associated requirements or those requirements would be implemented before the license renewal period, no additional analysis is required. In such cases, provide with the ER copies of the NPDES permit, CWA Section 316(b) BTA determinations, studies and information submitted to the NPDES permitting agency pursuant to 40 CFR 122.21(r), and relevant correspondence with the permitting agency. In cases where the NPDES permit has expired but has been administratively continued by the permitting authority because of timely renewal application submission (i.e., at least 180 days before the permit expiration date), provide a copy of the permit renewal application. If certain requirements associated with the CWA 316(b) determination have yet to be implemented, provide a timeline for such implementation.

ISSUE: During the environmental audit and in response to audit information needs AQU-02, AQU-4, AQU-15, AQU-20, and AQU-23, TVA provided copies of aquatic surveys, permits, and studies not previously included in the ER.

REQUEST: Please provide copies of the following documents

1. TVA. 2021b. Clean Water Act Section 316(b) § 122.21(r) Compliance Documentation for BFN(1).pdf

2. TVA_2022b_NPDES Permit Submittal_BFN r(12)(1).pdf

3. TVA_2020b_BFN Entrainment Characterization(3).pdf

4. NPDES Permit Renewal Application submitted in January 2023

22 AQU-16 REQUIREMENT: The requirements in 10 CFR 51.53(c)(3)(ii)(B) state that if a plant utilizes once-through cooling or cooling pond water intake and discharge systems, the impact of thermal discharges on aquatic organisms shall be assessed.

If the NPDES permitting authority has made a determination under CWA Section 316(a) that thermal effluent limits are sufficiently stringent to assure the protection and propagation of a balanced, indigenous population of shellfish, fish, and wildlife in and on the receiving body of water, and the nuclear power plant has implemented any associated requirements, no additional analysis is required. In such cases, provide with the ER copies of the NPDES permit, CWA Section 316(a) determination, CWA Section 316(a) demonstration studies and other information submitted to the NPDES permitting authority pursuant to CWA 316(a), and relevant correspondence with the permitting agency. In cases where the NPDES permit has expired but has been administratively continued by the permitting authority because of timely renewal application submission (i.e., at least 180 days before the permit expiration date), provide a copy of the permit renewal application. If certain requirements associated with the CWA 316(a) determination have yet to be implemented, provide a timeline for such implementation.

ISSUE: During the environmental audit and in response to audit information needs AQU-16 and AQU-19, TVA provided copies of aquatic surveys and studies not previously included in the ER.

REQUEST: Please provide copies of the following documents TVA_2021c_Eval. Presence & Maint. of Fish & Wildlife_TN River - BFN(1).pdf HISTORIC AND CULTURAL RESOURCES HCR-14 REQUIREMENT: The requirements in 36 CFR § 800.4(1) direct Federal agencies to identify historic properties, including background research, consultation, oral history interviews, sample field investigation, and field survey. Additionally, 10 CFR 51.41 indicates that NRC may direct the applicants to provide NRC information to complete their NEPA process.

ISSUE: NRC requested archaeological survey reports of the following reports listed below. TVA provided redacted archaeological reports via the Cetrec portal, redacting necessary information needed for NRCs confirmatory review.

REQUEST: Provide the following unredacted archaeological and architectural reports to support NRCs draft EIS:

Dison et al. 2022: A Phase I Archaeological Survey of Previously Unsurveyed Areas within the Tennessee Valley Authoritys Browns Ferry Nuclear Plant in Limestone County, Alabama. Prepared by Tennessee Valley Archaeological Research, Huntsville, Alabama Dison et al. 2020: A Phase I Archaeological Survey of Browns Ferry Nuclear Plant Meteorological Tower Tree Clearing Project in Limestone County, Alabama. Prepared by Tennessee Valley Archaeological Research, Huntsville, Alabama.

Reynolds Mike. 2022. Historic Architectural Resources Survey of the Browns Ferry Nuclear Plant Project, Limestone County, Alabama. Prepared by Brockington and Associates, Inc., Atlanta, Georgia

23 Marshall 2013: A Phase I Archaeological Survey for the Trinity-Browns Ferry Nuclear Plant 161-kV Transmission Linen Project, Limestone and Morgan Counties, Alabama.

Prepared by Tennessee Valley Archaeological Research, Huntsville, Alabama.

Stanton 2013: Phase I Archaeological Survey of Tennessee Valley Authoritys Browns Ferry-Athens 161-KV TL Rebuild and Associated Access Roads in Limestone County, Alabama. Prepared by Tennessee Valley Archaeological Research, Huntsville, Alabama Karpynec and Weaver 2018: Phase I Architectural Assessment for the Tennessee Valley Authoritys Browns Ferry Aquatic Research Facility, Limestone County, Alabama.

Prepared by Tennessee Valley Archaeological Research, Huntsville, Alabama