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Slide Presentations for January 16, 2025 Us NRC Public Meeting on Advance Act Section 206 Brownfields
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ADVANCE Act Section 206:

Evaluating Potential Regulatory Issues for Nuclear Facilities at Brownfield Sites U.S. Nuclear Regulatory Commission Public Meeting January 16, 2025

Scope of Todays Meeting

Todays meeting will discuss topics related to Section 206 of the ADVANCE Act, Regulatory issues for nuclear facilities at brownfield sites.

Per NRCs public meeting policy (86 FR 14964), this is an Information Meeting with Question and Answer.

This meeting was noticed on the NRCs Public Meeting Schedule page on December 30, 2024.

To Stay Informed of NRCs Progress Follow NRCs ADVANCE Act implementation with this Dashboard https://www.nrc.gov/about-nrc/governing-laws/advance-act.html#dashboard

For Upcoming and Past Meetings For NRCs public meeting information on ADVANCE Act https://www.nrc.gov/about-nrc/governing-laws/advance-act.html#related

For Your Questions and Ideas Contact us with ADVANCE Act questions, comments and ideas https://www.nrc.gov/about-nrc/governing-laws/advance-act/contactus.html

Section 206. Regulatory Issues for Nuclear Facilities at Brownfield Sites Direction: Evaluate the extent to which modification of regulations, guidance, or policy is needed to enable efficient, timely, and predictable licensing reviews for, and to support oversight of, production and utilization facilities at brownfield sites.

Objective: Streamline licensing of NRC facilities at or near brownfield or retired fossil fuel sites by leveraging: (1) existing site infrastructure, (2) existing emergency preparedness organizations and planning; (3) availability of historical site-specific environmental data; (4) previously completed environmental reviews; (5) activities associated with potential decommissioning of facilities or decontamination and remediation; and (6) community engagement and historical experience with energy production.

Agenda, Panel 1 Time Topic Speaker 1:00 - 1:10 p.m.

Welcome & Logistics Mike King, NRC/OEDO Chris Regan, NRC/NMSS/REFS Sarah Lopas, NRC/NMSS/REFS 1:10 - 1:30 p.m.

Feasibility of Brownfield Sites for SMR Deployment -

Establishing Baseline Conditions to Support Regulation & Environmental Impact Assessment Matthew Bond, Environmental Biologist, Radioecology Section Head, Canadian Nuclear Laboratories 1:30 - 1:50 p.m.

Brownfield Redevelopment in Kentucky Cliff Hall, Manager, Superfund Branch, Division of Waste Management, Kentucky Energy and Environment Cabinet 1:50 - 2:10 p.m.

Brownfield Redevelopment in Tennessee Evan W. Spann, Deputy Director of Field Operations, Division of Remediation, Tennessee Department of Environmental Conservation 2:10 - 2:20 p.m.

NRCs Decommissioning Funding Assurance Requirements and Existing Radiological Contamination at Brownfield Sites Richard Turtil, Senior Financial Analyst, NRC/NMSS/REFS 2:20 - 2:35 p.m.

Panel Discussion NRC and Panelists

Agenda, Panel 2 Time Topic Speaker 2:35 - 2:45 p.m.

BREAK 2:45 - 2:50 p.m.

Introduction to Panel 2 - Population and Community Considerations Christine King, Director, Gateway for Accelerated Innovation in Nuclear (GAIN),

Idaho National Laboratory (INL) 2:50 - 3:10 p.m.

NRCs Population-Related Siting Requirements for Advanced Reactors William (Bill) Reckley, Senior Project Manager, Office of Nuclear Reactor Regulation, NRC 3:10 - 3:30 p.m.

Population-Related Siting Requirements -

Considerations and Recommendations Kati Austgen, Senior Project Manager for New Nuclear, Nuclear Energy Institute 3:30 - 3:45 p.m.

Workforce, Energy & Environmental Justice Christine King, Director, GAIN/INL 3:45 - 4:05 p.m.

Role of Local Governments in Support of New Nuclear Development Kara Colton, Principal, KacoGroup, LLC 4:05 - 4:25 p.m.

Community Perspective Tracy Boatner, President & CEO, East Tennessee Economic Corporation 4:25 - 4:45 p.m.

Panel Discussion NRC and Panelists 4:45 - 5:00 p.m.

Public Comments and Questions, Close Out Public and NRC

November 2024 Brownfield Meeting Detailed summary of the 11/21/2024 public meeting on Section 206 is available in the NRCs Agencywide Documents Access and Management System (ADAMS) at ML24345A048.

Includes links to all presentation slides and meeting transcript.

UNRESTRICTED / ILLIMITÉEFeasibility of Brownfield Sites for SMR DeploymentEstablishing Baseline Conditions to Support Regulation & Environmental Impact Assessment U.S. Nuclear Regulatory Commission Public Meeting 2025 January 16 Matt Bond, Environmental Biologist Radioecology Section Head Canadian Nuclear Laboratories matthew.bond@cnl.ca

UNRESTRICTED / ILLIMITÉE22 Source: NRCan Energy Fact Book (2023)Energy Mix in Canada

UNRESTRICTED / ILLIMITÉE33Adding SMRs to Canadas Energy Mix

SMRs could be a key player in meeting Canadas commitment to phase out the use of conventional coal-fired power plants by 2030, and as Canada strives to secure 90% non-emitting electricity supply by 2030

- SMR Roadmap (2018)

The Vision: Small Modular Reactors as a source of safe, clean, affordable energy, opening opportunities for a resilient, low carbon future and capturing benefits for Canada and Canadians - SMR Action Plan (2022) 2022 2018

UNRESTRICTED / ILLIMITÉE44Adding SMRs to Canadas Energy Mix -The Response Chalk River, ON Chalk River Laboratories Darlington, ON Darlington NPP Estevan, SK Boundary Dam Coal-Fired PP Belledune, NB Port of Belledune Coal-Fired PP Point Lepreau, NB Point Lepreau NPP Industrial Re-Use / Brownfield Sites CNSC Licensed Nuclear Sites

UNRESTRICTED / ILLIMITÉE55Adding SMRs to Canadas Energy Mix -The Response Chalk River, ON Chalk River Laboratories Darlington, ON Darlington NPP Estevan, SK Boundary Dam Coal-Fired PP Belledune, NB Port of Belledune Coal-Fired PP Point Lepreau, NB Point Lepreau NPP Industrial Re-Use / Brownfield Sites CNSC Licensed Nuclear Sites

UNRESTRICTED / ILLIMITÉE66 Advantages Re-development of a Brownfield may be eligible for government grants & tax credits; Critical infrastructure already in place (e.g.,

connection to the power grid);

Likely located near town/city (i.e., proximity to amenities, work-force);

Likely more publically-acceptable to re-develop a Brownfield site than to develop a Greenfield site.

Disadvantages May be more expensive than Greenfield sites due to environmental cleanup &

demolition; May be difficult to secure financing due to contamination uncertainties; Regulatory uncertainty in terms of baseline contaminant conditions and how this could affect site licensing.Re-Development of Brownfield Sites for SMR Siting

UNRESTRICTED / ILLIMITÉE77 Advantages Re-development of a Brownfield may be eligible for government grants & tax credits; Critical infrastructure already in place (e.g.,

connection to the power grid);

Likely located near town/city (i.e., proximity to amenities, work-force);

Likely more publically-acceptable to re-develop a Brownfield site than to develop a Greenfield site.

Disadvantages May be more expensive than Greenfield sites due to environmental cleanup &

demolition; May be difficult to secure financing due to contamination uncertainties; Regulatory uncertainty in terms of baseline contaminant conditions and how this could affect site licensing.Re-Development of Brownfield Sites for SMR Siting

UNRESTRICTED / ILLIMITÉE88Coal-burning PPNatural Gas-burning PPOil/Diesel-burning PPFossil-Fuel Power Plants in Canada

UNRESTRICTED / ILLIMITÉE99Coal-burning PPFossil-Fuel Power Plants in Canada

UNRESTRICTED / ILLIMITÉE1010Coal-burning PPNatural Gas-burning PPOil/Diesel-burning PPSKABONNBFossil-Fuel Power Plants in Canada

UNRESTRICTED / ILLIMITÉE1111Coal-burning PPNatural Gas-burning PPOil/Diesel-burning PPSKABONNBChalk RiverDarlingtonEstevanBelledunePoint LepreauPotential SMR????Fossil-Fuel Power Plants in Canada

UNRESTRICTED / ILLIMITÉE12NORM/TENORM Contamination at Coal-Burning Power PlantsU-238 SeriesU-235 SeriesTh-232 SeriesNanticoke Generating StationImage Source: CBC NewsImage Source: Getty Images

UNRESTRICTED / ILLIMITÉE13NORM/TENORM Contamination at Coal-Burning Power Plants Bottom ash: a coarse angular ash particle that is too large to be carried up into the smokestacks so it forms in the bottom of the coal furnace.

Fly ash: a very fine, powdery material composed mostly of silica made from the burning of finely ground coal in a boiler.

During combustion, radionuclides present in coal become concentrated in fly ash (TENORM).

A number of studies have reported elevated U-238, Ra-226, Th-232, K-40, Po-210, Pb-210 in the environment around coal-fired power plants.

From: Biajawi et al. (2022) Construction and Building Materials, 338:

127624. https://doi.org/10.1016/j.conbuildmat.2022.127624 From: Pandit et al. (2011) Radioprotection, 46(6): S173-S179.

https://doi.org/10.1051/radiopro/20116982s

UNRESTRICTED / ILLIMITÉE1414 The levels/types of radioactive contaminants in coal may vary considerably from deposit to deposit. The levels of release are, in large part, dependent on site-specific factors such as plant design and coal fuel.

Volatile radionuclides (e.g., radon) present in feed coal are lost in stack emissions as gas, while less volatile elements (e.g., Th, U, and the majority of their decay products) are almost entirely retained in the solid combustion products (i.e.,

bottom ash & fly ash).

Modern coal-fired power plants can recover ~99.5% of the solid combustion wastes (including fly ash) due in large part to the installation of particulate emissions control features like electrostatic precipitators (ESP) and cyclone separators.

However, many early-design (i.e., traditional) plants did not have these technologies and it has been estimated that 87%

of fly ash was recovered in these stations. NORM/TENORM Contamination at Coal-Burning Power Plants Source: Babcock & Wilcox From: Baig and Yousaf (2017) J. Earth Sci. & Clim. Change, 8(7).

https://doi.org/10.4172/2157-7617.1000404

UNRESTRICTED / ILLIMITÉE1515NORM/TENORM Contamination at Coal-Burning Power Plants

There is quite a bit of literature on TENORM contamination in the environment around coal power plants in Europe, Asia and the Middle East

Minimal research in North Americahttps://doi.org/10.1007/s11356-014-3888-2

UNRESTRICTED / ILLIMITÉE1616TENORM Contamination -What about Canada?

Source: Environment Canada. 1985. Radioactivity in Coal, Ashes and Selected Wastewaters from Canadian Coal-fired Steam Electric Generating Stations. https://inis.iaea.org/collection/NCLCollectionStore/_Public/20/063/20063463.pdf From: Kumar, K. et al. (2023). Effect of Additive on Flowability and Compressibility of Fly Ash. Advances in Functional and Smart Materials.

https://doi.org/10.1007/978-981-19-4147-4_22

UNRESTRICTED / ILLIMITÉE1717 MacCormack (1979) estimated radionuclide inventories escaping four Saskatchewan coal-burning power plants via fly ash.

The plants all burned Saskatchewan lignite coal containing 2.88 to 11.02 mg/kg of U. Assuming 0.7% escape of fly ash from the ESP equipped plants, and 12.9% escape of fly ash from non-ESP equipped plants, radionuclide releases were calculated:

~35 to 149 kg/yr of U released from an ESP-equipped 300 MW(e) unit at Poplar River Generating Station.

~53 to 201 kg/yr of U would leave the plant from the cyclone-equipped units 300 MW(e) Boundary Dam Generating Station.

~33 to 123 kg/yr of U was released from the smaller 70 MW(e)

Estevan Generating Station.

~193 to 753 kg/yr of U was released from Units 1-5 (582 MW(e))

at the Boundary Dam Generating Station.

All of this uranium would have been deposited to the nearby environment via fly ash fallout.TENORM Contamination -What about Canada?

Boundary Dam Generating Station Poplar River Generating Station

Reference:

MacCormack, J., "Trace Elements in Saskatchewan Coal-Fired Power Plants", Saskatchewan Environmental Protection Service, Regina (August, 1979).

UNRESTRICTED / ILLIMITÉE1818Genesee Generating StationImage Source: Capital PowerTENORM Contamination -What about Canada?https://doi.org/10.1016/j.envpol.2017.08.033

UNRESTRICTED / ILLIMITÉE1919AECL Federal Nuclear Science & Technology Work Plan

AECLs Federal Nuclear Science and Technology (FNST) Work Plan performs nuclear-related science and technology (S&T) to support core federal roles, responsibilities and priorities.

This includes the CNSC, ECCC and NRCan (among others).

After discussions with staff from a number of federal agencies, CNL prepared &

submitted a proposal to investigate the feasibility of brownfield sites for SMR deployment.

Focus on establishing environmental baseline conditions at Brownfield sites to support regulation & Environmental Impact Assessment. Contribute to regulatory readiness.

This proposal has been funded and the project will begin in April 2025.

UNRESTRICTED / ILLIMITÉE20General Project Plan We plan to sample a number of former coal-fired power plant sites across the country to establish general trends in radionuclide contamination and look at variability.

Operating history of the site? Fly ash recovery methods?

Source of coal?

Review regulations related to SMR siting & baseline characterization.

Given that this research will be funded by the Federal Government, we do not want to complete a full site assessment/baseline characterization for SMR proponents (that is their responsibility).

The goal is simply to understand current conditions at these sites (TENORM) - general trends - to help inform regulation and Environmental Impact Assessment.

UNRESTRICTED / ILLIMITÉE21Regulatory Context REGDOC-1.1.1 - Site Evaluation & Site Preparation for New Reactor Facilities (V1.1)

The baseline data shall consider contaminants of potential concern (COPCs) associated with historical, present or proposed future use of the site. An understanding of COPCs prior to collecting environmental baseline data will direct the selection of parameters to be included in the environmental baseline data collection program.

Where an area on the site has received substantial contamination from previous nuclear or non-nuclear industrial activities, the baseline characterization shall consider nuclear and hazardous substance levels within relevant environmental media of interest.

The applicant shall assess the doses to workers and the public associated with activities to be encompassed by the licence to prepare site, or from exposures to any radioactive substances resulting from past or present nuclear activities.

The objective of the site evaluation stage is to assess whether the site is suitable for the construction and operation of a nuclear facility.

REGDOC-2.9.1 - Environmental Protection: Environmental Principles, Assessments & Protection Measures (V1.2)

The applicant or licensee shall present a characterization of the baseline environment for any portion of the environment where the site characterization indicates potential for interaction.

The applicant or licensee shall use the facility-or activity-specific characterization and the local environmental baseline characterization to identify the potential interactions between the facility or activity and the surrounding environment. Note that these identified interactions will become the focus of further stages within the ERA.

Impact Assessment Act (IAA)

An IA must take into account any cumulative effects that are likely to result from the designated project in combination with other physical activities that have been or will be carried out.

Regulatory Limit (Cumulative Effects/Impact)

Baseline Ambient Radioactivity SMR Operating Envelope Environmental Radioactivity Low High (a)

(b)

(c)

(d)

Brownfield Theoretical Scenarios

UNRESTRICTED / ILLIMITÉE22References Pandit, G.G., S.K. Sahu and V.D. Puranik. 2011. Natural radionuclides from coal fired thermal power plants - estimation of atmospheric release and inhalation risk. Radioprotection, 46(6): S173-S179. https://doi.org/10.1051/radiopro/20116982s Yoho, B., Güler, E., Canbaz ztürk, B. et al. 2023. Environmental assessment of natural radionuclides and trace elements around Seyitmer coal fired power plant. J. Radioanal. Nucl. Chem. 332, 4819-4831. https://doi.org/10.1007/s10967-023-08947-9 Ahmed, U.A.Q., Wagner NJ, Joubert JA. 2020. Quantification of U, Th and specific radionuclides in coal from selected coal fired power plants in South Africa. PLoS One, 1;15(5):e0229452. https://doi.org/10.1371/journal.pone.0229452 Abedin, M.J., Karim, M.R., Hossain, S. et al. 2019. Spatial distribution of radionuclides in agricultural soil in the vicinity of a coal-fired brick kiln. Arab. J.

Geosci. 12, 236. https://doi.org/10.1007/s12517-019-4355-7 Flues, M, Moraes, V, Mazzilli, BP. 2002. The influence of a coal-fired power plant operation on radionuclide concentrations in soil. J. Environ. Radioact., 63(3):

285-94. https://doi.org/10.1016/S0265-931X(02)00035-8 Lovreni Mikeli, I., G. Ernei, D. Barii. 2024. Natural and anthropogenic radionuclides in soil around coal-fired Plomin thermal power plant (Istria, Croatia): What is the plant influence and what controls it? Fuel, 371(A): 131971.

https://doi.org/10.1016/j.fuel.2024.131971 Barst, B.D., J.M.E. Ahad, N.L. Rose, et al. 2017. Lake-sediment record of PAH, mercury, and fly-ash particle deposition near coal-fired power plants in Central Alberta, Canada. Environ. Pollut., 231(1): 44-653. https://doi.org/10.1016/j.envpol.2017.08.033 Chuangao, W., L. Ruirui, L. Jinfeng, H. Zhijun, et al. 2017. 210Po distribution after high temperature processes in coal-fired power plants. J. Environ. Radioact.,

171: 132-137. https://doi.org/10.1016/j.jenvrad.2017.02.015 uji, M., Dragovi, S., orevi, M. et al. 2015. Radionuclides in the soil around the largest coal-fired power plant in Serbia: radiological hazard, relationship with soil characteristics and spatial distribution. Environ. Sci. Pollut. Res., 22, 10317-10330. https://doi.org/10.1007/s11356-014-3888-2 Papastefanou, C. 2010. Escaping radioactivity from coal-fired power plants (CPPs) due to coal burning and the associated hazards: a review. J. Environ.

Radioact., 101( 3): 191-200. https://doi.org/10.1016/j.jenvrad.2009.11.006 Papp, Z, Dezso Z, Daróczy S. 2002. Significant radioactive contamination of soil around a coal-fired thermal power plant. J. Environ. Radioact., 59(2): 191-205.

http://doi.org/10.1016/s0265-931x(01)00071-6 Amin, Y.M., Mayeen Uddin Khandaker, et al. 2013. Radionuclide emissions from a coal-fired power plant. Appl. Radiat. Isot., 80: 109-116.

https://doi.org/10.1016/j.apradiso.2013.06.014 Thomas, G., G. Fariborz. 2000. Effect of geological processes on coal quality and utilization potential: review with examples from western Canada. J. Hazard.

Mater., 74(1-2): 109-124. https://doi.org/10.1016/S0304-3894(99)00202-2 Hong Loan, T.T., V. Ngoc Ba, B. Ngoc Thien. 2022. Natural radioactivity level in fly ash samples and radiological hazard at the landfill area of the coal-fired power plant complex, Vietnam. Nucl. Eng. Technol., 54(4): 1431-1438.

https://doi.org/10.1016/j.net.2021.10.019 Environment Canada. 1985. Radioactivity in Coal, Ashes and Selected Wastewaters from Canadian Coal-fired Steam Electric Generating Stations.

https://inis.iaea.org/collection/NCLCollectionStore/_Public/20/063/20063463.pdf

UNRESTRICTED / ILLIMITÉE23 Thank you!

Matt Bond, M.Sc.

Environmental Biologist & Radioecology Section Head Canadian Nuclear Laboratories matthew.bond@cnl.caWhat does all this mean in terms of siting, licensing & operating SMRs at Brownfield sites?

Brownfield Redevelopment Program, Kentucky DEPARTMENT FOR ENVIRONMENTAL PROTECTION, DIVISION OF WASTE MANAGEMENT, SUPERFUND BRANCH PRESENTATION TO NRC JANUARY 16, 2024 1

Objective and Tools To purchase and redevelop blighted properties in the state of Kentucky without incurring Potential Responsible Party Status.

Federal BFPP Kentucky Brownfield Redevelopment Program 2

Kentuckys Revised Statutes 3

KRS 224.1-400 (18) similar to 42 U.S. Code Chapter 103 §9607. Liability Any persons possessing or controlling a hazardous substance, pollutant, or contaminant which is released into the environment...shall take actions necessary to correct the effect of the release on the environment.

Although EEC pursues the causal responsible party first, the current owner or controller is liable.

Federal - Innocent Landowners, Standards For Conducting All Appropriate Inquires 40 CFR Part 312 Effective November 1, 2006. This introduced the Bona Fide Protective Purchaser (BFPP) defense Currently Applicable to CERCLA (Federal Sites - NPLs and Removals) - Most releases do not rise to this level.

Requires:

Environmental Site Assessments (ESAs) - ASTM E1527-21 (aka. All Appropriate Inquires)

All Appropriate Care (prevent exposures based on assessment)

Only Provides an Affirmative Defense (defending hindsight from regulatory agency can be problematic) 4

Kentucky - Brownfield Redevelopment Program Kentuckys legislature adopted the BFPP defense with upgrades.

Codified in KRS 224.1-415 on July 12, 2012 Established Conditions of Eligibility Promulgated in 401 KAR 102 February 3, 2014 Established Conditions for Applying and Requirements of Property Management Plans ($2,500 Fee)

The state approves all appropriate care up front (unlike the defense under the federal law).

Known eligibility status prior to property purchase 5

The Kentucky Superfund 1-415 Brownfields Redevelopment Program Program Outline & Features:

$2500 Fee Criteria is the same for an applicant as BFPP (no familiar, operational or business relationship with responsible party).

Places great importance on valid Phase I Environmental Site Assessment. Required for all applications. Must be Fresh (180 days expiration the assessment is void)

Eliminates uncertainty of appropriate care through use of the Property Management Plan (PMP).

PMP is designed/signed by applicants consultant (PG/PE) so it should represent applicants needs. DWM concurs.

PMP is living document, highly conformable and easily revised (Still needs PE/PG cert).

Offers documentation:

Prior to purchase to facilitate lending (Notice of Eligibility).

After purchase (Notification of Concurrence).

6

The Kentucky Superfund 1-415 Brownfields Redevelopment Program Program Outline (continued):

Property and Person Specific (not transferrable to a future owner)

Available to persons who already own if having BFPP Status.

Benefits to lenders:

Notice of Eligibility issued prior to purchase so lender knows if buyer qualifies before loaning.

If given reliance and if PMP includes a mothball provision, lender can foreclose without generating new PMP (the Phase I must still be performed to document conditions at time of possession).

Considerate of property transfer timelines/logistics:

Notice of Eligibility that has not expired will have the effect of a Notification of Concurrence upon obtaining legal title.

Packages will be reviewed within 30 days.

7

Environmental Site Assessments (ASTM E1527-21)

Phase I (Visual Site Inspection date sets the clock on expiration of the assessment not the date on the assessment.)

Phase II (Not required but characterization data may be requested to verify if management options are suitable.)

Does not reset expiration of application Establishes a baseline on like use Reduces unneeded management Confirms contaminants of potential concern Additional characterization is almost always required with RECs that may create vapor intrusion conditions.

8

Property Management Plans (PMPs) oManagement or precautions to prevent exposures by reuse.

oBased on the Environmental Site Assessments.

oNo required sampling unless required to demonstrate plan is working (Vapor Encroachment Condition) oIf reuse requires construction, a completion report is required.

9

Presumptive Remedies Phase I may discover a REC. Instead of confirming an expected situation with additional sampling, a management plan may just restrict all reasonable exposure pathways. Typically, applicable to a non-residential use.

Examples include:

No use (buy and hold) maintaining security No continued occupancy (Warehouses)

Barriers based on expected impacts as summarized in the Phase I Urban Fill -assume moderate contamination (paving, concrete, clean soil) 10

Voluntary Cleanup The PMP may include voluntary cleanup.

Do not exacerbate the release.

PMP can have a section dedicated to material management.

Once the waste is generated it is the responsibility of applicant to follow appropriate regulation or policy.

No need to enter Kentuckys Voluntary Environmental Remediation Program (VERP) KRS 224.510-224.1-532.

Application fee required Programmatic 11

Conclusion Kentucky Offers Upfront concurrence to all appropriate care rather than the federal defense Most Releases/Contamination are not subject to CERCLA BFPP may offer protection in other states. Kentucky had adopted the federal defense prior to the Brownfield Redevelopment Program. Other states may offer something similar.

12

Contact Information Presented by Clifford Hall P.G., Manager Superfund Branch clifford.hall@ky.gov Assisted by Nathan Hancock P.G., Consultant Superfund Branch nathan.Hancock@ky.gov 13

Brownfields are abandoned or underused industrial and commercial properties where redevelopment may be complicated by real or perceived environmental contamination.

Abandoned and former gas stations Former dry cleaners Old industrial facilities Former coal yards Former junk yards Legacy contamination of unknown origin

Federal: Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) and SARA (1986).

- 42 U.S.C. § 9601 et seq.

- Code of Federal Regulations State: Hazardous Waste Management Act of 1983

- T.C.A. § 68-212-224 (Brownfields Projects Voluntary Cleanup Oversight and Assistance Program)

- T.C.A. § 68-212-225 (Notice of Land Use Restrictions)

Tennessee Compilation of Rules &

Regulations

The Commissioner has the discretion and is authorized to establish an apportionment of liability consistent with T.C.A. § 68-212-207(b) in a voluntary agreement or consent order;

- Liability protections are automatically extended to successor parties; meaning the benefits of the Brownfield Voluntary Agreement follow the property, not the property owner.

Avoiding potential environmental enforcement actions that could impose penalties and costly cleanups; Reducing the likelihood that contamination from the property will result in unacceptable risk; To establish a legal basis for enforcement of institutional controls to limit future liability at a site resulting from it progressing to uses with increased

risk, Receiving tax benefits for cleaning up and reusing the property;

"Liable party" means:

(A) The owner or operator of an inactive hazardous substance site; (B) Any person who at the time of disposal was the owner or operator of an inactive hazardous substance site; (C) Any generator of hazardous substance who at the time of disposal caused such substance to be disposed of at an inactive hazardous substance site; or (D) Any transporter of hazardous substance which is disposed of at an inactive hazardous substance site who, at the time of disposal, selected the site of disposal of such substance;

(i) As used in this subdivision (a)(4), "owner or operator" does not include a person who establishes, by a preponderance of the evidence, that:

- acquired the title to the hazardous substance site after the disposal or placement of the hazardous substance

- did not know and had no reason to know that any hazardous substance which is the subject of the release or threatened release was disposed of on, in or at the site

- exercised due care with respect to the hazardous substance concerned in light of all relevant facts and circumstances (ii) the person must have undertaken, at the time of acquisition, all appropriate inquiry into the previous ownership and uses of the property consistent with good commercial or customary practice in an effort to minimize liability.

Voluntary Party certifications in application:

- 1) Other than being an owner or operator of the Site, it is not a liable party of the Site, as defined by Tennessee Code Annotated section 68-212-202(a)(4)(B-E);

Certification that the applicant did not generate, transport, or release the contamination at the subject property

- 2) Activities will not aggravate or contribute to existing contamination on the Site or pose significant human health or environmental risks;

- 3) A summary description of all known existing environmental investigations, studies, reports, or documents concerning the sites environmental condition with the application; and

- 3) it is financially viable to meet the obligations of a Brownfield Voluntary Agreement (BVA).

TCA 68-212-202 (a) (1) "Brownfield project" means the screening, investigation, monitoring, control and/or remediation of any abandoned, idled, under-utilized, or other property whose re-use, growth, enhancement or redevelopment is complicated by real or perceived adverse environmental conditions.

Perceived environmental conditions that may exist at a brownfield site must be identified and quantified to be addressed under a BVA.

The responsibility is on the prospective purchaser to perform All Appropriate Inquiry consistent with the current ASTM standard.

AAI is the process of evaluating a propertys environmental conditions and assessing potential liability for any contamination.

Understand environmental risks and costs of owning, operating, or redeveloping the property, Obtaining a Phase I Environmental Site Assessment compliant with ASTM Standard E 1527-21 (or its most recent version) at least 6 months prior to purchase.

§ 312.11 References.

(a) The procedures of ASTM International Standard E1527-21 entitled Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process.

all appropriate inquiry included in Tennessee Code Annotated section 68-212-202(a)(4)(F)(ii).

Every REC identified in AAI and for which liability protection is requested should be both identified/investigated and addressed though an Agreed Action.

AAI necessary to avoid being a responsible party for clean-up:

- Bona Fide Prospective Purchaser

- Innocent Landowner

- Contiguous Property Owners

Section D All Appropriate Inquiry

- Identify RECs

Provides credit for investigation but differentiates what is an actual matter identified and addressed.

Section E Matters Identified and Addressed

- Each matter identified and addressed should include three elements: media, location, and the contaminants and their concentrations in comparison to initial regulatory screening levels and risk-based action levels.

- Clearly defines how matters are to be addressed.

- TDECs expectation for voluntary parties is that matters identified and addressed are mitigated to ensure no unacceptable risk to human health and the environment, including any ongoing monitoring at brownfields.

Section I Continuing Obligations

- Continuing obligations are legal requirements designed to protect public health and the environment for contamination or a remedy that remains on a property.

- Continuing obligations still apply after a property is sold with successor parties responsible for complying.

- Vapor Intrusion Mitigation System Operation and Maintenance -

any modification or change in operation to the system would require the review and approval per the Notice of Land Use Restrictions.

- Site/Soil Management Plan

Mirrors BVA template to include three elements: media, location, and the contaminants and their concentrations.

- use restrictions (e.g., prohibiting residential land use due to presence of hazardous substances in soil above Residential RSLs),

- activity controls (e.g., to prevent exposure to contaminated ground water by prohibiting extraction or use of ground water), and

- operation and maintenance (O&M) controls used to ensure safe reuse of the impacted Property (e.g., caps and/or covers, vapor mitigation intrusion barriers, or other systems).

Written Notice of the Presence of Contamination Notice of Limitations in Future Conveyances Compliance Reporting Adds Successor notification

No Additional Action

- Letter from DoR acknowledging that no additional action is required

- TDEC oversight without a voluntary agreement or consent order

- No statutory protections No Further Action Letter

- Used only for BVA

- Entitled to all statutory defenses Letter of Completion

- Used for Consent Order

- Entitled to all statutory defenses

Incorporate targeted cleanup and/or caps/covers for on-site management into redevelopment plan Develop/Implement Soil Management Plan for future development Limit future use of the property via Notice of Land Use Restrictions Use of pre-emptive mitigation especially when dealing with volatile chemicals

ADVANCE Act Section 206 NRCs Decommissioning Funding Assurance Requirements and Existing Radiological Contamination at Brownfield Sites January 16, 2025 Richard H. Turtil, U.S. NRC Senior Financial Analyst Financial Assessment Branch

Current Financial Qualification and Nuclear Decommissioning Trust Fund Requirements Overview

- Applicant is Financially Qualified

Requirements at 10 CFR 50.33

Possesses or has Reasonable Assurance of Obtaining Funding for -

- Construction

- Operations

- Decommissioning 2

Current Nuclear Decommissioning Funding Assurance Requirements Overview

- Applicant to provide Certification of Financial Assurance for Decommissioning

- Requirements at 10 CFR 50.75

Use of a Minimum Formula Amount provided in 50.75 or

Based on a cost estimate for decommissioning the facility 3

Brownfield Site Considerations Nuclear Facilities at Brownfield Sites are Envisioned to Rely on Site-Specific Cost Estimates for Decommissioning In addition to meeting Financial Qualification requirements for construction and operations, applicant to provide evidence that:

Applicant is Financially Qualified to address contamination issues at the site Applicants plans consider radiological contamination at the site from pre-brownfield activities, if any.

4

Brownfield Site Considerations In support of a Site-Specific Cost Estimate for Decommissioning, anticipated need for:

o Thorough Site Description and Characterization Prior to Licensing; o Thorough and Transparent Understanding of:

Assumption of Liability at Contaminated Site, including:

Liability for prior radiological contamination, if present, Liability for post-operations radiological contamination.

Agreements, Terms of Lease or Sale Transaction that Articulate:

Reference to Current Site Characterization/Contamination Identifies Which Entity Assumes Site Liability Upon Transaction.

5

Thank You!

Questions?

Richard Turtil Senior Financial Analyst U.S. NRC, NMSS, REFS 6

NRCs Population-Related Siting Requirements for Advanced Reactors 1

William Reckley, Senior Project Manager Advanced Reactor Policy Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities (DANU)

Office of Nuclear Reactor Regulation

2 Commercial Power Reactor Siting

- A Long and Interesting History Potential radiological releases (source term)

TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites, (1962)

RG 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors SECY-16-0012, Accident Source Terms and Siting for Small Modular Reactors and Non-Light Water Reactors Policy Considerations NUREG-0478, Metropolitan Siting - A Historical Perspective, (1978)

NUREG -0625, Report of the Siting Policy Task Force, (1979)

Accident Consequences

Societal Risk

Defense in Depth Final Rule - Reactor Site Criteria Including Seismic and Earthquake Engineering Criteria for Nuclear Power Plants (61 FR 65157; December 11, 1996)

Defense in Depth Environmental Considerations Revision 4 to Regulatory Guide 4.7 SECY-20-0045, Population Related Siting Considerations for Advanced Reactors ORNL/TM-2019/1197, Advanced Reactor Siting Policy Considerations

OR-SAGE (Oak Ridge Siting Analysis for power Generation Expansion)

Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy Act of 2024 (ADVANCE Act)

3 Overview - Consideration of Radiological Consequences in NRC Activities (Offsite Areas/Zones)

ARCAP - Advanced Reactor Content of Applications Program (DANU-ISG-2022-01; Regulatory Guide (RG) 1.253)

RG 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors RG 4.7, General Site Suitability for Nuclear Power Stations RG 1.242, Performance-Based Emergency Preparedness for Small Modular Reactors, Non-Light-Water Reactors, and Non-Power Production or Utilization Facilities 10 CFR 50.160 RG 1.242 ARCAP RG 1.183 RG 4.7 Recent &

Ongoing Activities

4 Overview - Traditional Approach for 10 CFR Part 100, Reactor Site Criteria Design Basis Radiological Consequence Analyses (Siting Analysis)

(calculated dose to hypothetical individual)

Population Density Considerations (consideration of societal consequences)

5 10 CFR 100.21(h)

Reactor sites should be located away from very densely populated centers. Areas of low population density are, generally, preferred. However, in determining the acceptability of a particular site located away from a very densely populated center but not in an area of low density, consideration will be given to safety, environmental, economic, or other factors, which may result in the site being found acceptable3.

Traditional Approach (20 miles) 10 CFR 100.3 (Definitions)

Population center distance means the distance from the reactor to the nearest boundary of a densely populated center containing more than about 25,000 residents.

Regulatory Guide 4.7, General Site Suitability Criteria for Nuclear Power Stations Preferably, a reactor should be located so that, at the time of initial site approval and for about 5 years thereafter, the population density, including weighted transient population, averaged over any radial distance out to 20 miles (cumulative population at a distance divided by the area at that distance), is at most 500 persons per square mile. A reactor should not be located at a site where the population density is well in excess of this value.

6 SECY-20-0045, Population-Related Siting Considerations for Advanced Reactors, dated May 8, 2020 Staff Requirements Memorandum (SRM)-SECY-20-0045, Staff Requirements - SECY-20-0045 - Population-Related Siting Criteria for Advanced Reactors, dated July 13,2022 (ML22194A885)

Revision 4 to RG 4.7 issued February 2024 Recent Revisions to Population Density Considerations Regulatory Guide 4.7, General Site Suitability Criteria for Nuclear Power Stations, Rev. 4 APPENDIX A, Alternative Approaches to Address Population-Related Siting Considerations An applicant can demonstrate compliance with 10 CFR 100.21(h) by siting a nuclear reactor in a location where the population density does not exceed 500 persons per square mile out to a distance equal to twice the distance at which a hypothetical individual could receive a calculated TEDE of 1 rem over a period of 30 days from the release of radionuclides following postulated accidents.

An advanced reactor with estimated doses below 1 rem at the site boundary over the 30 days following the assumed postulated accident could be sited within towns with populations of no more than approximately 25,000 residents.

7 Recent and Ongoing Activities Revision 4, Regulatory Guide 4.7, General Site Suitability Criteria for Nuclear Power Stations, February 2024 Proposed Rule - Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors (Part 53), (89 FR 86918, October 31, 2024)

Microreactor Activities SECY-20-0093, Policy and Licensing Considerations Related to Micro-Reactors SECY-24-0008, Micro-Reactor Licensing and Deployment Considerations:

Fuel Loading and Operational Testing at a Factory White Paper - Nth-of-a-Kind Micro-Reactor Licensing and Deployment Considerations (September 2024)

Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy Act of 2024 (ADVANCE Act)

§ 206 - Regulatory issues for nuclear facilities at brownfield sites

§ 208 - Regulatory requirements for micro-reactors

8 Discussion

9 Option 3 - Case 1 LPD LPZ PCD >

1 LPZ pop center > ~ 25K 1 rem over month Case 1:

Event Sequences with Offsite Doses > 25 rem over course of event Event Sequences with Offsite Doses > 1 rem over the month following event r1 2r1 For plants with event sequence doses > 1 rem over a month beyond the site boundary, population density < 500 ppsm over the radial distance equal to twice the radius at which 1 rem over a month is estimated (or 20 miles)

BACKUP SLIDE (SECY-20-0045)

Note: population center defined by population distribution, not political boundaries

10 Option 3 - Case 2 LPD LPZ at site boundary pop center > ~ 25K 1 rem over month Case 2:

No Event Sequences with Offsite Doses > 25 rem over course of event Event Sequences with Offsite Doses > 1 rem over the month following event r1 2r1 For plants with event sequence doses > 1 rem over a month beyond the site boundary, population density < 500 ppsm over the radial distance equal to twice the radius at which 1 rem over a month is estimated (or 20 miles)

BACKUP SLIDE (SECY-20-0045)

11 Option 3 - Case 3 pop center > ~ 25K Case 3:

No Event Sequences with Offsite Doses > 25 rem over course of event (LPZ at site boundary)

No Event Sequences with Offsite Doses > 1 rem over the month following event pop center < ~ 25K Population center distance means the distance from the reactor to the nearest boundary of a densely populated center containing more than about 25,000 residents A

B BACKUP SLIDE (SECY-20-0045)

©2025 Nuclear Energy Institute 2 Rev. 4 issued in Feb. 2024 did clarify some flexibility in considering population-related siting, specifically Population Density Distance (PDD) for advanced reactor designs.

The revision did not adequately:

1.

Put the population-density siting consideration in context with other siting elements and defense-in-depth considerations 2.

Compare the level of protection afforded as proposed by NRC for advanced reactors to that currently applied to existing LWRs 3.

Identify whether NRCs guidance would result in undue burden (i.e., excessive restrictions on siting) for advanced reactors NEI Perspective: RG 4.7 Rev. 4 Outcome

©2025 Nuclear Energy Institute 3 In public comments (ML23326A031) on DG-4034, which would become RG 4.7, Rev. 4, we provided NEI White Paper: Advanced Reactor Population-Related Siting Considerations to inform the three preceding points, concluding:

In context: PDD minimizes societal impacts following an accident involving significant quantities of fission products released to the environment Level of protection: 2x the distance of 1 rem in 30 days is more than a factor of five times more conservative than what the NRC currently finds acceptable for large LWRs Undue burden: imposes excessive restrictions on the ability to site advanced reactors Recap NEI Input and Feedback

A PDD of 5 rem in 30 days would align with the current NRC accepted level of protection for large LWRs calculated using best estimate methods at 20 miles. NRC Staff disagreed with comparison. (ML23324A007)

The RG 4.7 Rev. 4 Appendix alternative PDD at 2x the distance of 1 rem in 30 days provides excessive baseline margin to previous large LWR licensing experience and should limit the need for extensive uncertainty analysis. NRC Staff agreed on flexibility in uncertainty assessments with no further change to RG.

Best estimate analysis approaches are more than adequate for defining the PDD. NRC Staff agreed without further clarification to RG.

Disposition of NEI Recommendations

©2025 Nuclear Energy Institute 5 10 CFR 100.21(b), (h) and 100.3, and RG 4.7, may challenge the business case for widespread advanced reactor deployment as they are overly restrictive compared to the accepted level of protection provided by requirements for existing large light water reactors.

Opportunities Provide regulatory history & bases for alternative approaches Modify corresponding 10 CFR Part 100 requirements Appropriately enable Population Density Distances commensurate with characteristics of advanced reactors Population-Related Siting More Broadly NEI developing bases for alternative pop.-related siting criteria

©2025 Nuclear Energy Institute 6 Power reactor siting has typically involved assessment of a variety of distances, most of which are depicted in Fig. 1 Each provides functional and defense-in-depth (DiD) purposes Siting criteria protect from societal impacts & provides DiD to minimize societal impacts should containment fail*

as we understand it; based on TID 14844 (1962)

Recall Various Siting Criteria / Limitations Source: NRC SECY 20-0045 Figure 1

©2025 Nuclear Energy Institute 7 For sites where the EPZ coincides with the site boundary, the EAB, LPZ, PDD & PCD could all be set to the site boundary Alternate PDD dose criterion could be developed to be more representative of the currently accepted level of protection for large LWR licensing, and/or definition of PCD changed from 25,000 people Clarity is needed on the modeling assumptions, which heavily influence dose criterion calculations, including consideration with respect to the realistic exposure risk to the public that would be acceptable to the NRC Others?

Preview/Draft Possibilities Going Forward

©2025 Nuclear Energy Institute 9 US tripling nuclear energy by 2050 = many sites needed Brownfield sites are already impacted and site reuse may be environmentally preferable to additional land disturbance NRC already looking closely at Environmental Requirements for Siting and Safety Siting Requirements Opportunity to fully consider whether population-related siting criteria serve an independent purpose and whether the analysis/justification necessary to site near populations is already provided by other requirements Environmental Justice & Energy Justice Opportunity to clarify and streamline consideration of communities that host retiring coal facilities Key Findings Relevant to Brownfields

create additional long-term jobs in host communities increase total income in host communities increase revenue for host communities, power plant operators, & local suppliers BUT, ~80% are in communities

>25,000 people Credit: DOEs April 2024, Stakeholder Guidebook for Coal-to-Nuclear Conversions, distribution of U.S. CPPs bound by the size of the community populations where they are located

©2025 Nuclear Energy Institute 11 NRC population-related siting criteria requirements and guidance are updated to meet ADVANCE Act direction, including increased use of risk-informed and performance-based approaches; with additional stakeholder engagement If population-related criteria serve a unique purpose, then clarify whether unique requirements are necessary or whether credit for other requirements (and analyses performed) can be justified.

Population Center Distance and Population Density Distance are updated to reflect the characteristics of advanced reactors, especially micro-reactors.

Population-Related Desired Outcomes 1996 Reactor Site Criteria Final Rule [61 FR 65175]: next-generation reactors are expected to have risk characteristics sufficiently low that the safety of the public is reasonably assured by the reactor and plant design and operation itself, resulting in a very low likelihood of occurrence of a severe accident.

©2025 Nuclear Energy Institute 12 NRC revise guidance (and regulations, as needed) to acknowledge brownfield sites are already impacted and site reuse may be environmentally preferable to additional land disturbance Brownfield site review should not be more resource intensive than greenfield Existing information for brownfield sites may be equivalent to what NRC needs NRC activities to respond to ADVANCE Act direction align with the opportunities identified in SECY 24-0046, Implementation of the Fiscal Responsibility Act of 2023 Staff recommends rulemaking to allow increased use of EAs, applicant preparation of draft EA/EIS, more narrowly-focused need statement and alternatives analyses Clear NRC summary position/guidance on what makes a brownfield site viable for nuclear Other Brownfield Sites Desired Outcomes

QUESTIONS?

By Third Way, GENSLER

INL/MIS-18-50189 NRC Advance Act: Section 206 Workforce, Energy and Environmental Justice Christine King - Director of Gateway for Accelerated Innovation in Nuclear (GAIN)

January 16, 2025 Virtual Meeting

P r e p a r e d b y M P R A s s o c i a t e s 3 2 0 K i n g S t r e e t A l e x a n d r i a V A 2 2 3 1 4 m p r. c o m 2

GAIN Studies Coronado Generating Station Primary Objective:

Assess the feasibility of transitioning from coal to nuclear; Learnings can be applied to other coal units within commuting distance from CGS.

Partnered with Salt River Project and St Johns Mayors Office Plant is in same county as Navajo Nation Ghent Generating Station Primary Objective:

Assess feasibility of nuclear energy at Ghent Generating Station (GGS) from a siting and technology perspective.

Partnered with PPL to assess siting and technology feasibility for producing electricity and process heat for nearby industrial users.

Colstrip Power Plant Primary Objective:

Assess nuclear and non-nuclear repowering timelines and site feasibility.

Partnered with Northwestern Energy to build on lessons learned from CGS/GGS, and assess various potential options and siting options for Colstrip.

Active in Coal Transition Discussions 157 Retired Sites, 237 Operating Sites Screened

Peeking into the details

- Started with 349 Retired Sites

Remove sites not owned/operated by utility or independent power producer

Remove units retired before 2012

- 229 Retired Sites remaining

Quick screen multiple factors including population

157 were analyzed in 2022 report

57 of 72 sites screened out in this step -

screened out on population

- 500 ppsm at 4 miles 3

If you would like the analysis for your coal stations, please use this link to request:

https://inlfedramp.gov1.qualtrics.com/jfe/form/SV_81EfQuLFZLHSrki

Required Nuclear Buildout - 200 GW by 2050

Annual industrial capacity additions:

Requires an additional 275,000 workers; currently 100,000 workers Ramping to 13 GW per year from 2035 - 2050 to achieve 200GW by 2050 2 GW per year 2029 - 2034

INL/MIS-18-50189 Coal Transitions Christine King - Director of Gateway for Accelerated Innovation in Nuclear (GAIN)

Christine.king@inl.gov April 2024 Jason Hansen, INL Alisa Trunzo, DOE Emily Nichols, INL Will Jenson, INL

What does nuclear power conversion offer a community?

Nuclear can bring lasting jobs to a plant for 40-80 years

There are both direct jobs created as well as indirect and induced jobs

Many other renewable technologies only bring construction jobs Source: DOE April 2024: COAL-TO-NUCLEAR TRANSITIONS: AN INFORMATION GUIDE Nuclear has a multiplier of ~1.5 For every $100 of electricity produced, $50 of economic activity occurs in suppliers and support industries

Overlap in Job Types and Education Levels

Comparing occupation codes shows the similarity in roles from each power plant type.

45 percent of the added nuclear jobs share identical occupation codes with the coal plant,

72 percent of the added share similar occupation codes.

This implies that many occupations at the CPP have the educational background to work at the NPP.

NOTE: Analysis does not account for nuclear, industry-specific training.

Interest in Redeveloping Coal https://www.cnbc.com/2024/09/27/americas-coal-communities-could-help-the-us-triple-nuclear-power.html?mkt_tok=NzY2LVdCTC04NzcAAAGV7JwhmyQZMvM6M2cN9rF0UBD17h7oFWRXoteJhxnyIU9FgR_oqjWjrWYU5BP-PcayZwfq8XgE4UvjvsiMTd3gUNmwsX8qHBNTIMGyeWiZ https://denvergazette.com/opinion/editorials/editorial-why-colorado-should-follow-microsofts-lead/article_42f277e0-e1ac-54b3-a53b-6a2f0677adff.html https://kleinmanenergy.upenn.edu/news-insights/can-nuclear-power-and-coal-plant-communities-bail-each-other-out/

Resources Referenced Arizona pilot studies for the Coronado Generating Station Coronado Generating Station Nuclear Feasibility Study: Summary Report https://www.srpnet.com/assets/srpnet/pdf/grid-water-management/grid-management/improvement-projects/coal-communities-transition/GAIN-Summary-Report.pdf Coronado Generating Station Repowering Evaluation: Siting Evaluation https://www.srpnet.com/assets/srpnet/pdf/grid-water-management/grid-management/improvement-projects/coal-communities-transition/GAIN-Siting-Analysis-Report.pdf Estimating Economic Impacts of Repurposing the Coronado Generating Station with Nuclear Technology: Summary Report https://www.srpnet.com/assets/srpnet/pdf/grid-water-management/grid-management/improvement-projects/coal-communities-transition/GAIN-Economic-Impact-Report.pdf Kentucky pilot studies for the Coronado Generating Station Ghent Generating Station Nuclear Feasibility Study - Summary Report https://gain.inl.gov/content/uploads/4/2024/06/Ghent-Generating-Station-Nuclear-Feasibility-Study-Summary-Report_INLRPT 72902.pdf Ghent Generating Station Nuclear Study - Siting Evaluation https://gain.inl.gov/content/uploads/4/2024/06/Ghent-Generating-Station-Nuclear-Study-Siting-Evaluation_INLRPT-23-72896.pdf Electric Power Research Institute Advanced Nuclear Technology: Owner-Operator Reactor Technology Assessment Guide2022 Version https://www.epri.com/research/programs/065093/results/3002025344 Pueblo Colorado study about the Comanche Station Pueblo Innovative Energy Solutions Advisory Committee

Resources Referenced Department of Energy - Systems Analysis and Integration Coal-to-Nuclear Transitions: An Information Guide (start here) https://www.energy.gov/ne/articles/coal-nuclear-transitions-information-guide Investigating Benefits and Challenges of Converting Retiring Coal Plants into Nuclear Plants (2022) https://fuelcycleoptions.inl.gov/SiteAssets/SitePages/Home/C2N2022Report.pdf Stakeholder Guidebook for Coal-to-Nuclear Conversions (2024) https://fuelcycleoptions.inl.gov/SiteAssets/SitePages/Home/C2N_Guidebook_2024.pdf

ML25032A022

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