ML25087A164

Enclosure 1 - Environmental Report, Chapters 1 and 2

ML25087A164
Person / Time
Site:	Triso-X
Issue date:	03/28/2025
From:	Triso-X
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML25090A027	List: ML25087A161 ML25087A164 ML25087A165 ML25087A166 ML25087A167 ML25087A168 ML25087A169
References
TX0-REG-LTR-0059
Download: ML25087A164 (1)

Text

FUEL FABRICATION FACILITY ENVIRONMENTAL REPORT SUBMITTAL March 2025

Environmental Report for the TRISO-X Fuel Fabrication Facility Master Table of Contents March 2025 i

Rev.2 MASTER TABLE OF CONTENTS Section Title Page CHAPTER 1 INTRODUCTION OF THE ENVIRONMENTAL REPORT

1.0 INTRODUCTION

......................................................................................................... 1-6

1.1 BACKGROUND

.......................................................................................................... 1-7 1.2 PURPOSE AND NEED FOR THE PROPOSED ACTION.......................................... 1-9 1.3 THE PROPOSED ACTION....................................................................................... 1-11 1.4 APPLICABLE REGULATORY REQUIREMENTS, PERMITS, AND REQUIRED CONSULTATIONS.................................................................................................... 1-14 APPENDIX 1A REGULATORY CORRESPONDENCE........................................................... 1-23 CHAPTER 2 ALTERNATIVES 2.1 DETAILED DESCRIPTION OF THE ALTERNATIVES............................................... 2-8 2.2 ALTERNATIVES CONSIDERED BUT ELIMINATED............................................... 2-36 2.3 CUMULATIVE EFFECTS.......................................................................................... 2-41 2.4 COMPARISON OF THE PREDICTED ENVIRONMENTAL IMPACTS..................... 2-48 CHAPTER 3 DESCRIPTION OF THE AFFECTED ENVIRONMENT 3.1 LAND USE................................................................................................................ 3-17 3.2 TRANSPORTATION................................................................................................. 3-24 3.3 GEOLOGY AND SOILS............................................................................................ 3-27 3.4 WATER RESOURCES............................................................................................. 3-41 3.5 ECOLOGY.............................................................................................................. 3-104 3.6 METEOROLOGY, CLIMATOLOGY, AND AIR QUALITY....................................... 3-150 3.7 NOISE..................................................................................................................... 3-226 3.8 HISTORIC AND CULTURAL RESOURCES........................................................... 3-231 3.9 VISUAL/SCENIC RESOURCES............................................................................. 3-236 3.10 SOCIOECONOMICS.............................................................................................. 3-243 3.11 PUBLIC AND OCCUPATIONAL HEALTH.............................................................. 3-270 3.12 WASTE MANAGEMENT......................................................................................... 3-278 CHAPTER 4 ENVIRONMENTAL IMPACTS 4.1 LAND USE IMPACTS............................................................................................... 4-12 4.2 TRANSPORTATION IMPACTS................................................................................ 4-16 4.3 GEOLOGY AND SOILS IMPACTS........................................................................... 4-26 4.4 WATER RESOURCES IMPACTS............................................................................ 4-32 4.5 ECOLOGY IMPACTS............................................................................................... 4-51 4.6 AIR QUALITY IMPACTS........................................................................................... 4-59

Environmental Report for the TRISO-X Fuel Fabrication Facility Master Table of Contents March 2025 ii Rev.2 4.7 NOISE IMPACTS...................................................................................................... 4-68 4.8 HISTORIC AND CULTURAL RESOURCES IMPACTS............................................ 4-77 4.9 VISUAL/SCENIC RESOURCES IMPACTS.............................................................. 4-80 4.10 SOCIOECONOMIC IMPACTS.................................................................................. 4-86 4.11 ENVIRONMENTAL JUSTICE................................................................................. 4-104 4.12 PUBLIC AND OCCUPATIONAL HEALTH IMPACTS............................................. 4-110 4.13 WASTE MANAGEMENT IMPACTS........................................................................ 4-138 CHAPTER 5 MITIGATION MEASURES

5.0 INTRODUCTION

......................................................................................................... 5-5 5.1 LAND USE.................................................................................................................. 5-5 5.2 TRANSPORTATION................................................................................................... 5-6 5.3 GEOLOGY AND SOILS.............................................................................................. 5-7 5.4 WATER RESOURCES............................................................................................... 5-8 5.5 ECOLOGICAL RESOURCES................................................................................... 5-11 5.6 AIR QUALITY............................................................................................................ 5-12 5.7 NOISE....................................................................................................................... 5-13 5.8 HISTORIC AND CULTURAL RESOURCES............................................................. 5-14 5.9 VISUAL/SCENIC RESOURCES............................................................................... 5-15 5.10 SOCIOECONOMICS................................................................................................ 5-16 5.11 ENVIRONMENTAL JUSTICE................................................................................... 5-17 5.12 PUBLIC HEALTH...................................................................................................... 5-18 5.13 WASTE MANAGEMENT........................................................................................... 5-19 CHAPTER 6 ENVIRONMENTAL MEASUREMENTS AND MONITORING PROGRAMS 6.1 RADIOLOGICAL MONITORING................................................................................. 6-6 6.2 PHYSIOCHEMICAL MONITORING.......................................................................... 6-10 6.3 ECOLOGICAL MONITORING.................................................................................. 6-16 6.4 HISTORIC AND CULTURAL RESOURCES MONITORING.................................... 6-17 CHAPTER 7 COST BENEFIT ANALYSIS

7.0 INTRODUCTION

......................................................................................................... 7-5 7.1 COSTS AND BENEFITS OF THE PROPOSED ACTION.......................................... 7-5 7.2 COMPARATIVE COST-BENEFIT ANALYSIS OF PROPOSED ACTION RELATIVE TO NON-ACTION ALTERNATIVE............................................................................ 7-13 7.3 OVERALL COST-BENEFIT CONCLUSIONS........................................................... 7-15

Environmental Report for the TRISO-X Fuel Fabrication Facility Master Table of Contents March 2025 iii Rev.2 CHAPTER 8

SUMMARY

OF ENVIRONMENTAL CONSEQUENCES 8.1 UNAVOIDABLE ADVERSE ENVIRONMENTAL IMPACTS........................................ 8-6 8.2 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES.......... 8-7 8.3 SHORT-TERM AND LONG-TERM IMPACTS............................................................ 8-9 8.4 SHORT-TERM USES OF THE ENVIRONMENT AND MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY.............................................. 8-10 CHAPTER 9 LIST OF REFERENCES 9.1 CHAPTER 1 INTRODUCTION OF THE ENVIRONMENTAL REPORT..................... 9-3 9.2 CHAPTER 2 ALTERNATIVES.................................................................................... 9-4 9.3 CHAPTER 3 DESCRIPTION OF THE AFFECTED ENVIRONMENT......................... 9-7 9.4 CHAPTER 4 ENVIRONMENTAL IMPACTS............................................................. 9-30 9.5 CHAPTER 5 MITIGATION MEASURES................................................................... 9-39 9.6 CHAPTER 6 ENVIRONMENTAL MEASUREMENTS AND MONITORING PROGRAM.

.................................................................................................................................. 9-41 9.7 CHAPTER 7 COST BENEFIT ANALYSIS................................................................ 9-42 9.8 CHAPTER 8

SUMMARY

OF ENVIRONMENTAL CONSEQUENCES..................... 9-43 CHAPTER 10 LIST OF PREPARERS 10.1 LIST OF PREPARERS.............................................................................................. 10-5

Environmental Report for the TRISO-X Fuel Fabrication Facility Master List of Figures March 2025 iv Rev.2 MASTER LIST OF FIGURES Number Title CHAPTER 1 INTRODUCTION OF THE ENVIRONMENTAL REPORT 1.3-1 Site Location 1.3-2 Bounding Limits 1.3-3 Site Plan CHAPTER 2 ALTERNATIVES 2.1-1 Overall Site Layout 2.1-2 Water Balance Diagram 2.3-1 City of Oak Ridge Industrial Development Areas CHAPTER 3 DESCRIPTION OF THE AFFECTED ENVIRONMENT 3.1-1 Aerial View of the HCS Vicinity 3.1-2 Aerial View of the HCS Region 3.1-3 Regional Land Uses 3.1-4 Major Population Centers near the HCS 3.1-5 Major Special Land Uses in the HCS Region 3.1-6 Other Land Use Features near the HCS 3.1-7 Prime Farmland in the Region 3.1-8 Map of HCS Vicinity Zoning 3.2-1 Regional Highways and Interstates near the HCS 3.2-2 Roads in the Vicinity of the HCS 3.2-3 Average Annual Daily Traffic Count Locations Along Routes to the HCS 3.3.1-1 Physiographic Provinces within the Horizon Center Site Region 3.3.1-2 Valley and Ridge Province 3.3.1-3 Typical Stratigraphy within the Valley and Ridge Province Near Oak Ridge Reservation and the Horizon Center Site 3.3.3-1 Geologic Map in the Vicinity of the Horizon Center Site 3.3.3-2 Physiography in the Vicinity of the Horizon Center Site

Environmental Report for the TRISO-X Fuel Fabrication Facility Master List of Figures March 2025 v

Rev.2 3.3.3-3 Locations of Geotechnical Borings and Groundwater Wells Used to Characterize Subsurface Conditions at the Horizon Center Site 3.3.3-4 Representative Fence Diagram Illustrating Geologic Cross Section of Horizon Center Site at A-A 3.3.3-5 Geologic Cross Section in the Vicinity of the Horizon Center Site 3.3.5-1 Seismic Events Recorded by USGS from 2000 to 2021 3.4.1-1 Typical Groundwater Flow Patterns within the Aquifers and Aquitards of the Valley and Ridge Province and at the Horizon Center Site 3.4.1-2 Groundwater Wells Within a 3-mile Radius of the Horizon Center Site 3.4.1-3 Groundwater Monitoring Wells Within and Adjacent to the Horizon Center Site 3.4.1-4 Hydrograph of Groundwater Potentiometric Elevations: September 2021-August 2022 3.4.1-5 Groundwater Contours - September 2021 3.4.1-6 Groundwater Contours - January 2022 3.4.2-1 Streams and Topography Within 3-Mile Radius of Horizon Center Stie 3.4.2-2 Surface Drainage near the Horizon Center Site 3.4.2-3 Surface Water Quality Sampling Locations for the Horizon Center Site 3.4.3-1 NFIP Flood Insurance Rate Map for Horizon Center Site 3.4.3-2 3.4.3-3 East Fork Poplar Creek Flood Elevations East Fork Poplar Creek Floodplain Map 3.4.4-1 NWI-Mapped Wetland Habitats within the Horizon Center Site 3.4.4-2 Wetland and Stream Delineation of the Horizon Center Site 3.5-1 Land Cover, Vegetation Types, and Bat Habitat in the Study Area 3.5.2-1 Land Use/Land Cover within 5 Miles of the Horizon Center Site 3.5.4-1 Important Ecological Areas within 5 Miles of the Horizon Center Site 3.6-1 Annual Wind Rose Oak Ridge, Tennessee (2005 - 2020) 3.6-2 Seasonal Wind Roses Oak Ridge, Tennessee (2005 - 2020) 3.6-3 Annual Wind Rose Knoxville, Tennessee (1990 - 2020) 3.6-4 Seasonal Wind Roses Knoxville, Tennessee (1990 - 2020) 3.6-5 Locations of ASOS and COOP Meteorological Stations and Supplemental Data Sources 3.6-6 Annual Wind Rose Tower D (2016 - 2020) 3.6-7 January Wind Rose Tower D (2016 - 2020)

Environmental Report for the TRISO-X Fuel Fabrication Facility Master List of Figures March 2025 vi Rev.2 3.6-8 February Wind Rose Tower D (2016 - 2020) 3.6-9 March Wind Rose Tower D (2016 - 2020) 3.6-10 April Wind Rose Tower D (2016 - 2020) 3.6-11 May Wind Rose Tower D (2016 - 2020) 3.6-12 June Wind Rose Tower D (2016 - 2020) 3.6-13 July Wind Rose Tower D (2016 - 2020) 3.6-14 August Wind Rose Tower D (2016 - 2020) 3.6-15 September Wind Rose Tower D (2016 - 2020) 3.6-16 October Wind Rose Tower D (2016 - 2020) 3.6-17 November Wind Rose Tower D (2016 - 2020) 3.6-18 December Wind Rose Tower D (2016 - 2020) 3.6-19 Seasonal Wind Roses Tower D (2016 - 2020) 3.6-20 Terrain Near the Horizon Center Site 3.7.1-1 Ambient Noise Survey Monitoring Locations 3.8.1-1 Survey Area for Cultural Resources and Area of Potential Effect 3.9.1-1 Horizon Center Site Vicinity Map 3.9.3-1 Aerial View of the Horizon Center Site with Photograph Locations 3.9.3-2 Horizon Center Site Photographs (Sheets 1 - 6) 3.10.1-1 Population Centers within the Region of Influence 3.10.1-2 Minority Percentage by Census Block Group within 4.0 Mi. (6.4 Km) of the Horizon Center Site 3.10.1-3 Percentage of Population below Poverty Level by Census Block Group within 4.0 Mi. (6.4 Km) of the Horizon Center Site 3.10.1-4 Population Density by Census Block Group within the Region of Influence 3.10.3-1 Community Facilities CHAPTER 4 ENVIRONMENTAL IMPACTS 4.6-1 Emission Points for the TRISO-X Fuel Fabrication Facility 4.7.2-1 Location of Noise Sources Associated with the TRISO-X Fuel Fabrication Facility 4.8.2-1 McKamey and Carmichael Family Cemetery and Buffer 4.9.2-1 TRISO-X Fuel Fabrication Facility Layout 4.9.2-2 TRISO-X Fuel Fabrication Facility Renderings (Sheets 1 - 4)

Environmental Report for the TRISO-X Fuel Fabrication Facility Master List of Figures March 2025 vii Rev.2 4.9.2-3 Estimated Viewshed Boundaries for TRISO-X Fuel Fabrication Facility 4.12.2-1 Vicinity Sensitive Receptor Map CHAPTER 5 MITIGATION MEASURES None CHAPTER 6 ENVIRONMENTAL MEASUREMENTS AND MONITORING PROGRAMS 6.1.2-1 Location of Site Boundary TLDs CHAPTER 7 COST BENEFIT ANALYSIS None CHAPTER 8

SUMMARY

OF ENVIRONMENTAL CONSEQUENCES None CHAPTER 9 LIST OF REFERENCES None CHAPTER 10 LIST OF PREPARERS None

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Table of Contents January 2025 1-1 Rev. 1 CHAPTER 1 INTRODUCTION OF THE ENVIRONMENTAL REPORT TABLE OF CONTENTS Section Title Page

1.0 INTRODUCTION

......................................................................................................... 1-6

1.1 BACKGROUND

........................................................................................................... 1-7 1.2 PURPOSE AND NEED FOR THE PROPOSED ACTION.......................................... 1-9 1.3 THE PROPOSED ACTION....................................................................................... 1-11 1.3.1 SITE LOCATION AND LAYOUT............................................................................. 1-12 1.3.2 NUCLEAR FUEL FABRICATION FACILITY DESCRIPTION.................................. 1-12 1.4 APPLICABLE REGULATORY REQUIREMENTS, PERMITS, AND REQUIRED CONSULTATIONS.................................................................................................... 1-14 APPENDIX 1A REGULATORY CORRESPONDENCE........................................................... 1-23

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - List of Tables January 2025 1-2 Rev. 1 LIST OF TABLES Number Title 1.4-1 Permits and Approvals Required for Construction and Operation 1.4-2 Consultations Required for Construction and Operation

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - List of Figures January 2025 1-3 Rev. 1 LIST OF FIGURES Number Title 1.3-1 Site Location 1.3-2 Bounding Limits 1.3-3 Site Plan

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Acronyms and Abbreviations January 2025 1-4 Rev. 1 Acronyms and Abbreviations Acronym/Abbreviation Definition ac.

acres AGR Advanced Gas Reactor AR Advanced Reactor ARDP Advanced Reactor Demonstration Program ATF Accident tolerant fuel CFR Code of Federal Regulations DOE U.S. Department of Energy ER Environmental Report EIS Environmental Impact Statement GDP Gross Domestic Product GMP Graphite Matrix Powder ha hectare HALEU High Assay Low Enriched Uranium HCS Horizon Center site HTGRs high temperature gas reactors HTR-PM high-temperature gas-cooled reactor pebble-bed module IND-2 general industrial district IND-3 heavy industrial district INL Idaho National Laboratory km kilometer LWR light water reactor mi.

mile NE Office of Nuclear Energy NEPA National Environmental Policy Act NMSS Nuclear Material Safety and Safeguards NPDES National Pollutant Discharge Elimination System

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Acronyms and Abbreviations January 2025 1-5 Rev. 1 Acronym/Abbreviation Definition NRC U.S. Nuclear Regulatory Commission R&D research and development ROI Region of Influence Site Horizon Center site SPCC Spill Prevention, Control and Countermeasure SHPO State Historic Preservation Office TDEC Tennessee Department of Environment and Conservation TRISO TRi-structural ISOtropic TRISO-X FFF TRISO-X Fuel Fabrication Facility TRISO-X TRISO-X, LLC TWRA Tennessee Wildlife Resources Agency UCO uranium oxycarbide UO2 uranium dioxide U3O8 triuranium octoxide USACE U.S. Army Corps of Engineers

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-6 Rev. 1 CHAPTER 1 Introduction of the Environmental Report

1.0 INTRODUCTION

TRISO-X, LLC (TRISO-X) is the applicant for a license to possess and use special nuclear material in the TRISO-X Fuel Fabrication Facility (TRISO-X FFF). As required by Title 10 of the Code of Federal Regulations (CFR) Part 51 (Environmental Protection Regulations for Domestic Licensing and Related Functions), this Environmental Report (ER) is being submitted to the U.S. Nuclear Regulatory Commission (NRC) by TRISO-X to support licensing of the TRISO-X FFF. This fuel fabrication facility utilizes uranium enriched to less than 20 percent to produce Tri-structural Isotropic (TRISO) based particle fuel products to support a variety of advanced reactors (ARs) being considered and planned by the energy and industrial sectors, the Department of Defense, and the National Aeronautics and Space Administration. ARs are being designed to provide clean, reliable energy and provide a viable alternative to the aging, economically challenged, existing nuclear and fossil electric generation stations. TRISO-X plans to locate the TRISO-X FFF on the Horizon Center site (HCS) located in Oak Ridge, Roane County, Tennessee, in accordance with the Atomic Energy Act of 1954, as amended; 10 CFR 70 (Domestic Licensing of Special Nuclear Material); 10 CFR 40 (Domestic Licensing of Source Material); and other applicable laws and regulations.

This ER is organized in accordance with the guidance contained in NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS (Nuclear Material Safety and Safeguards) Programs, dated August 2003. This chapter provides an introduction and discusses why TRISO-X is requesting an NRC license to possess and use special nuclear material in the TRISO-X FFF. Chapter 2 of this Report (Alternatives) discusses the Proposed Action and alternatives, including the No Action Alternative and siting alternatives. Chapter 3 (Description of Affected Environment) discusses the existing environmental conditions at the HCS, and Chapter 4, (Environmental Impacts) discusses how those conditions are affected, if at all, by the Proposed Action. Chapter 5 (Mitigation Measures) discusses mitigation measures that could be implemented by TRISO-X to mitigate potential environmental impacts of the Proposed Action. Chapter 6 (Environmental Measurements and Monitoring Programs) discusses the environmental measurement and monitoring programs established for the TRISO-X FFF. Chapter 7 (Cost-Benefit Analysis) provides an analysis of the costs and associated benefits of the TRISO-X FFF. Chapter 8 (Summary of Environmental Consequences) summarizes the potential environmental consequences of the Proposed Action.

Chapter 9 (List of References) and Chapter 10 (List of Preparers) presents the references for, and preparers of, this ER.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-7 Rev. 1

1.1 BACKGROUND

The United States pioneered the development of nuclear power to produce electricity in the 1940s. Since then, U.S. leadership in nuclear energy technology has provided a benefit of clean, reliable electricity for nearly seven decades. The U.S. fleet of nuclear power plants supplies approximately 20 percent of the electricity generated in the United States, while avoiding millions of tons of carbon dioxide emissions each year. It is the largest source of clean, carbon-free energy and the most reliable, operating at a capacity factor of more than 93 percent.

Despite these benefits, the U.S. nuclear industry faces significant challenges. Many U.S.

reactors face economic challenges or are nearing the end of their planned operating lives. New construction of traditional reactors is costly and time consuming. New AR designs are being developed and demonstrated to provide clean energy and expand market opportunities before key infrastructure and supply chain capabilities are lost in the United States.

The U.S. Department of Energy (DOE) Office of Nuclear Energy (NE) is an applied research and development (R&D) organization that enables innovation, supports unique research infrastructure, and solves crosscutting challenges facing the nuclear sector. The DOE-NE invests in R&D that the private sector or other non-government stakeholders are unable to perform due to the cost, scale, or timeframe required. By leveraging private-public partnerships and the national laboratory system, the DOE-NE makes nuclear energy more cost effective, accelerates AR deployment, makes nuclear fuel more sustainable, encourages a resilient supply chain, and promotes a strong nuclear workforce. Goals cited in the DOE-NE Strategic Vision report include enabling continued operation of existing U.S. nuclear reactors, enabling deployment of advanced nuclear reactors, developing advanced nuclear fuel cycles to include addressing gaps in the domestic nuclear fuel supply chain, and maintaining U.S. leadership in nuclear energy technology. (DOE, 2021)

The Advanced Reactor Demonstration Program (ARDP), within the DOE-NE, is designed to help domestic private industry demonstrate advanced nuclear reactors in the U.S. These advanced nuclear energy systems hold great potential to lower emissions, create new jobs, and build a strong economy. On November 15, 2021, the bipartisan Infrastructure Investment and Jobs Act was signed into law, providing more than $62 billion for the DOE to support innovation as a critical component for meeting climate change goals of reaching 100 percent carbon-free electricity by 2035 and a net-zero-carbon economy by 2050. Within the Acts funding for DOE, the ARDP is fully funded for $2.5 billion to help domestic private industry demonstrate two U.S.

advanced nuclear reactor designs through cost-shared partnerships with industry by 2028.

Although nuclear fuel, fuel forms, and operating conditions vary widely across the numerous AR designs under development, TRISO coated particle fuel is essential for many AR designs.

TRISO fuel was first developed in the U.S. and United Kingdom in the 1960s with uranium dioxide (UO2) fuel. In 2002, the DOE initiated the Advanced Gas Reactor Fuel Development and Qualification (AGR) Program to establish the U.S. capability to fabricate high-quality TRISO fuel and improve its performance. In 2009, this improved TRISO fuel set an international record by achieving a 19 percent maximum burnup during a three-year test at Idaho National Laboratory (INL). These tests demonstrate TRISO fuel performance during irradiation and in post-irradiation high temperature accident safety tests. The results of the AGR program have been very successful to date and support current safety design and analysis assumptions about fuel

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-8 Rev. 1 performance and radionuclide retention required for AR designs. Fabrication of high-quality low-defect fuel is now achievable at an industrial scale.

In 2020 under the ARDP, the DOE selected X-energy, LLC (X-energy), the parent company of TRISO-X, to deliver a commercial TRISO fuel fabrication facility and a four-module version of its Xe-100 high temperature gas-cooled reactor by 2030. In March 2023, Dow Chemical Inc. (Dow) and X-energy signed a joint development agreement establishing a mutual partnership to support the development and commercial demonstration of the countrys first grid-scale advanced nuclear reactor for an industrial site in North America. X-energy and Dow have identified a site for this reactor in Texas. In addition, X-energy is involved with Energy Northwest and Amazon to construct an Xe-100 reactor at the WNP-1 site located on the Hanford Site in Benton County, Washington. As such, TRISO-X plans to manufacture their own proprietary version of the TRISO coated particle fuel at HCS to ensure supply and quality control for the Xe-100 reactors to be constructed in Washington State and Texas and to satisfy the needs of a variety of other advanced fuel designs and reactors (e.g., pebble bed high temperature gas-cooled, prismatic gas-cooled, molten salt-cooled, accident tolerant fuel, nuclear thermal propulsion, and others). The TRISO-X FFF is the first commercial facility to provide this fuel at an industrial scale. The Xe-100 reactor allows for passive safety systems and a small reactor footprint, allowing flexibility in siting and access to non-traditional markets.

Many ARs require fuel that is enriched to from 5 percent to less than 20 percent Uranium-235 (235U), called High Assay Low Enriched Uranium (HALEU) fuel. TRISO fuel is a HALEU fuel.

NRC licensing is a critical element of the process that the AR community must address now to have a credible reactor deployment program by the mid-to-late-2020s. This project proposes the construction and operation of the TRISO-X FFF which includes possession and use of special nuclear material. The TRISO-X FFF produces TRISO-based coated particles and final fuel forms in various shapes and configurations to power the coming fleet of advanced reactors.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-9 Rev. 1 1.2 PURPOSE AND NEED FOR THE PROPOSED ACTION The proposed Federal action is the issuance of a license to possess and use special nuclear material, under the provisions of 10 CFR 70, that would allow TRISO-X to possess and use special nuclear material in the TRISO-X FFF to produce TRISO-based coated particles and final fuel forms using uranium enriched to less than 20 weight percent 235U. The Proposed Action is intended to satisfy the need for safe and reliable fuel for ARs. Fuel for ARs:

Increase competitiveness of the U.S. nuclear industry: The Chinese have completed a commercial AR UO2 TRISO fuel facility and AR power plant (high-temperature gas-cooled reactor pebble-bed module or HTR-PM); the TRISO-X FFF project enables near-term competitiveness by employing a superior fuel [uranium oxycarbide (UCO) TRISO]

manufactured in a U.S. fuel fabrication facility (the TRISO-X FFF), as well as supporting the overall deployment of several AR designs.

Improve capabilities of the existing fleet: UCO TRISO particles offer future potential, with additional research, to enable improvements to light water reactors (LWRs) using TRISO-based accident tolerant fuels (ATFs).

Improve timelines for AR deployment: Without a stable source of U.S. HALEU and a licensed Category 2 fuel fabrication facility, the deployment timeline for ARs will be measured in decades. According to the NRC, Category 2 fuel fabrication facilities are categorized as possessing a special nuclear material of moderate strategic significance.

The Proposed Action will reduce the timeline for deployment through the licensing, construction, and operation of the TRISO-X FFF.

Improve cost and schedule for AR deployment: UCO TRISO technology offers higher burn-ups and improved safety at high temperatures; this competitive advantage enables U.S. ARs to out-perform and be more economical as compared to foreign UO2-based ARs.

Issuance of a license that enables the possession and use of special nuclear material at the TRISO-X FFF will be for a first-of-a kind manufacturing operation in the U.S. TRISO fuel has been in development since the 1960s and improvements beginning in 2002 have enhanced performance and manufacturing methods. Production of TRISO fuel supports ARs, creates clean energy, encourages a resilient supply chain, and promotes a strong nuclear workforce.

Currently, many U.S. reactors face economic challenges or are nearing the end of their planned operating lives. New construction of traditional reactors is costly and time consuming. AR designs have the potential to offer lower costs, faster construction, variable size, and more flexible operation, while providing safe, clean energy. The most critical element of design of these reactors is a robust fuel that can withstand very high temperatures while providing greater efficiency than fuel used in the current light water reactor (LWR) fleet. The TRISO-X FFF produces such a fuel for ARs.

Nuclear energy is an important source of energy in the U.S with nearly 20 percent of the nations electricity being generated by nuclear reactors. Nuclear power generates nearly 55 percent of the nations carbon-free electricity. Americas nuclear power industry also creates jobs. The industry employs nearly 100,000 people and that number increases to 475,000 when including secondary jobs. Nuclear energy is good for the economy. Nuclear saves consumers an average of 6 percent on electric bills and adds $60 billion to the U.S. Gross Domestic Product (GDP). Nuclear energy is safe, clean, and reliable. Continued use and development of

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-10 Rev. 1 nuclear technology including ARs will lower emissions, create new jobs, and build a strong economy.

Without the Proposed Action, the U.S. would lose its competitiveness in the nuclear industry, there would be limited improvement in fuel types for the existing fleet, and AR deployment would be delayed. The global market for nuclear power could triple by 2050 due to increasing pressures to transition to a carbon-free world. The U.S. industry must be able to compete quickly, in order to ensure our national security and regain leadership from Russia and China in the development and deployment of safe, reliable nuclear energy and its related components.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-11 Rev. 1 1.3 THE PROPOSED ACTION The Proposed Action is for TRISO-X, LLC (the applicant) to possess and use special nuclear material in the TRISO-X FFF at the HCS. The facility will produce nuclear fuel to support next generation reactors in the energy, aerospace, industrial, and defense sectors.

The TRISO-X FFF is located in Oak Ridge, Roane County, Tennessee. A site location map including nearby towns and natural features is provided in Figure 1.3-1. The TRISO-X FFF encompasses approximately 110 acres (ac.) (44.6 ha). The Project layout consists of the fuel process buildings, support buildings, administration building, associated equipment yards, stormwater detention basins, internal roadways, stormwater ditches, permanent parking, and construction laydown area. Additional details regarding the Proposed Action are provided in Section 2.1.2 of this Report (Proposed Action).

The TRISO-X FFF is designed to produce coated particle fuel for the next generation of nuclear reactors. TRISO-X FFF manufacturing operations consist of receiving HALEU in the form of triuranium octoxide (U3O8) powder enriched to less than 20 weight percent 235U; converting the U3O8 into a uranyl nitrate solution, into gel spheres, and then into fuel kernels; and processing the fuel kernels through coating, overcoating, fuel form pressing, and high temperature carbonization. Commercial scale HALEU production is expected to be available in the U.S. in the 2028-2030 timeframe; therefore, the HALEU feedstock for the ARDP project will be supplied by the U.S. DOE. The form of the material may be U3O8 powder or liquid uranyl nitrate. If the material form is liquid uranyl nitrate, there is an additional processing step to receive the uranyl nitrate and convert it to U3O8. These operations are supported by shipping and receiving, laboratory, quality control, research and development, uranium recovery, and waste disposal processes. The target production capacity is 25 metric tons uranium (MTU) per year.

The project includes construction, operation, and decommissioning of process buildings. In April 2022, TRISO-X submitted the safety and safeguards portions of the License Application. The start of commercial operations at TX-1 (5 MTU production building) is expected to begin in 2027. The Facility would be initially licensed for 40 years of operations. The following is a list of Proposed Action key dates:

2022 - Submittal of license application to NRC 2024 through 2027 - TX-1 construction (as defined in 10 CFR 70.4) 2026 - Anticipated issuance of Environmental Impact Statement by the NRC 2026 - Anticipated issuance of 40-year license by the NRC 2027 - Start of TX-1 commercial operation 2026 through 2029 - TX-2 (20 MTU production building) construction 2029 - Start of TX-2 commercial operation 2066 - Potential license renewal or decommissioning of the facility At the end of the useful life of the TRISO-X FFF, the facility is decommissioned.

Decontamination and decommissioning are projected to take two years. The impacts of decommissioning are analyzed in Chapter 4 of this Report, (Environmental Impacts);

decontamination and decommissioning are also described in Section 2.1.2 of this report (Proposed Action).

For the purpose of evaluating the potential impacts that would result from the implementation of the Proposed Action (as presented in Chapter 4 of this Report, (Environmental Impacts),

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-12 Rev. 1 impacts are presented for three distinct lifecycle phases. The first phase is the construction phase, which consists of two years of construction activities. This phase would entail the TRISO-X FFF site preparation and construction of the operations building and auxiliary facilities.

The second phase is the operation phase, which would consist of 40 years of commercial production. The third and final phase is the decommissioning phase. This phase consists of the scheduled two-year period of decontamination and closure of the TRISO-X FFF.

To measure the overall effect of the Proposed Action, aggregate costs and benefits of the project were examined, including both the socioeconomic and environmental effects of the project. Most of the environmental costs and benefits and some of the economic costs and benefits are measured qualitatively whereas other economic costs and benefits are quantified and valued. Overall, the TRISO-X FFF would be expected to convey positive net benefits.

1.3.1 SITE LOCATION AND LAYOUT 1.3.1.1 SITE LOCATION The HCS is located within the city limits of Oak Ridge, Roane County, Tennessee. The HCS boundary is approximately 7 mi. (11 km) southwest of the approximate city center of Oak Ridge.

The TRISO-X FFF is centered at approximately 35°5741.132 N latitude, and 84°22 13.367 W longitude. A site location map is provided in Figure 1.3-1.

The sensitive populations (e.g., schools, daycare facilities, hospitals), nearest resident, and landmarks (including highways, transportation facilities, rivers and other bodies of water) within the Region of Influence (ROI), which includes Roane, Anderson, Knox, Loudon, and Morgan counties, are discussed within Section 3.10.

1.3.1.2 BOUNDING LIMITS A circle with a radius of 0.38 mi. (0.61 km) measured from the center point encompasses all of the property within the HCS. This radius is used to define the bounding limits of the project site.

Assessments provided in this ER evaluating impacts to areas away from the project site are defined by adding the required radius for the specific impact assessment to the bounding limits.

A bounding limits map is provided in Figure 1.3-2.

1.3.1.3 SITE LAYOUT Figure 1.3-3 shows the layout of major structures and the site boundary. This figure identifies key buildings and features on the site, including the process buildings, support structures, drainage features and other infrastructure.

1.3.2 NUCLEAR FUEL FABRICATION FACILITY DESCRIPTION TRISO-X is in the process of licensing a nuclear fuel fabrication facility to produce TRISO uranium fuel to power high temperature gas reactors (HTGRs) and other users of TRISO-based fuel. The TRISO uranium fuel produced is used for nuclear reactor developers and by the energy, aerospace, industrial, and defense sectors.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-13 Rev. 1 1.3.2.1 GENERAL DESCRIPTION OF THE NUCLEAR FUEL FABRICATION PROCESS The TRISO-X FFF is designed to produce coated particle fuel for the next generation of nuclear power plants and new accident tolerant fuels currently under development for existing light water reactors. While the baseline design targets the fabrication of pebble fuel forms for X-energys Xe-100 Pebble Bed HTGR, the modular design of the process cells / areas anticipates additional production capabilities to satisfy the needs of a variety of reactors (e.g.,

prismatic gas cooled, molten salt cooled, accident tolerant fuel, and others) and fuel designs.

TRISO-X FFF manufacturing operations consist of receiving HALEU in the form of triuranium octoxide (U3O8) powder enriched to less than 20 weight percent 235U; converting the U3O8 into a uranyl nitrate solution, into gel spheres, and then into fuel kernels; and processing the fuel kernels through coating, overcoating, fuel form pressing, and high temperature carbonization.

Commercial scale HALEU production is expected to be available in the U.S. in the 2028-2030 timeframe; therefore, the HALEU feedstock for the ARDP project will be supplied by the U.S.

DOE. The form of the material may be U3O8 powder or liquid uranyl nitrate. If the material form is liquid uranyl nitrate, there is an additional processing step to receive the uranyl nitrate and convert it to U3O8. These operations are supported by shipping and receiving, laboratory, quality control, research and development, uranium recovery, and waste disposal processes. The target production capacity is 25 MTU per year.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-14 Rev. 1 1.4 APPLICABLE REGULATORY REQUIREMENTS, PERMITS, AND REQUIRED CONSULTATIONS This section lists and summarizes the status of Federal, State, local, and other permits and consultations required for the construction and operation of the TRISO-X FFF which includes possession and use of special nuclear material. The applicable law, ordinance, or regulation that governs each permit and/or consultation is also identified.

Table 1.4-1 lists the permits and other approvals required to possess and use special nuclear material as well as construction and operation of the TRISO-X FFF. The table provides the following information for each permit or approval, as applicable:

Name of the responsible regulatory agency Applicable law, ordinance, or regulation Name of the permit or approval Activity covered by the permit or approval Current status Table 1.4-2 lists the consultations required for construction and operation of the TRISO-X FFF.

The table provides the following information for each consultation, as applicable:

Name of the responsible regulatory agency Applicable law, ordinance, or regulation Required consultation Summary of any surveys required to complete the consultation Current status As discussed in Table 1.4-2, TRISO-X made informal contact with the U.S. Fish and Wildlife Service (USFWS), Tennessee State Historic Preservation Office (SHPO), Tennessee Wildlife Resources Agency (TWRA), U.S. Army Corps of Engineers (USACE), and Tennessee Department of Environment and Conservation (TDEC). The purpose of these informal consultations was to inform the agencies about the project and to coordinate project planning.

Copies of regulatory agency consultations and responses are provided in Appendix 1A, Regulatory Correspondence.

The TRISO-X FFF is designed to operate in compliance with all applicable environmental quality standards and regulatory requirements. The facility also complies with current good manufacturing practices.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-15 Rev. 1 Table 1.4-1 (Sheet 1 of 5)

Permits and Approvals Required for Construction and Operation Agency Regulatory Authority Permit or Approval Activity Covered Status U.S. Nuclear Regulatory Commission National Environmental Policy Act (NEPA) 40 CFR 1500-1508 10 CFR 51 Environmental Assessment or Environmental Impact Statement in accordance with NEPA Analysis of impacts associated with construction, operation, and decommissioning at the HCS in support of NRC decision-making Addressed in this license application 10 CFR 70 Special Nuclear Material License Receipt, possession, use, and transfer of special nuclear material Addressed in this license application 10 CFR 71 Quality Assurance Program for Radiological Material Packages must be approved by NRC The use of NRC certified transportation packages QA Plan not yet submitted U.S. Environmental Protection Agency Clean Water Act 40 CFR 112 Spill Prevention, Control and Countermeasure (SPCC) Plans for Construction and Operation Storage of oil during construction and operation SPCC Plans not yet prepared U.S. Department of Transportation Hazardous Material Transportation Act 49 CFR 107 Certificate of Registration Transportation of hazardous materials Registration application not yet submitted U.S. Army Corps of Engineers Clean Water Act 33 CFR 320 - 331 Section 404 permit No jurisdictional waters were identified within the site.

However, two channels and one stream were identified within the project survey area, outside the site boundary, with the potential to be regulated by either the USACE and/or TDEC.

Likely not required; Preliminary JD was completed March 15, 2023. See Appendix 1A, Regulatory Correspondence.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-16 Rev. 1 Table 1.4-1 (Sheet 2 of 5)

Permits and Approvals Required for Construction and Operation Agency Regulatory Authority Permit or Approval Activity Covered Status Tennessee Department of Environment and Conservation Clean Water Act Tennessee Water Quality Control Act of 1977 Section 401 Certification No jurisdictional waters were identified within the site.

However, two channels and one stream were identified within the project survey area, outside the site boundary, with the potential to be regulated by either the USACE and/or TDEC.

Not required; See TDEC Concurrence Letter dated May 24, 2022 in Appendix 1A, Regulatory Correspondence Tennessee Air Pollution Control Board, Department of Environment and Conservation Federal Clean Air Act Tenn. Code Ann. Title 68 Air Quality Construction Permit Required to construct a new air contaminant source, the facility has at least one (and possibly several) new effluent discharge stack Permit application in development, not yet submitted Air Pollution Control Operating Permit Required to operate a new air contaminant

source, the facility has at least one (and possibly several) new effluent discharge stack Permit application not yet submitted Tennessee Department of Environment and Conservation, Division of Water Resources Federal Clean Water Act Tenn. Code Ann. Title 69 Notice of Coverage under the General National Pollutant Discharge Elimination System (NPDES) Permit for Stormwater Discharges associated with Construction Activity Required for clearing, grading, or excavation that disturbs one or more acres Permit application approved; Notice of Coverage effective November 10, 2022. See Appendix 1A, Regulatory Correspondence.

Industrial Storm Water Discharge Permit Discharge of storm water runoff from the site during facility operation Permit application not yet submitted

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-17 Rev. 1 Table 1.4-1 (Sheet 3 of 5)

Permits and Approvals Required for Construction and Operation Agency Regulatory Authority Permit or Approval Activity Covered Status Tennessee Department of Environment and Conservation, Division of Solid Waste Management Tenn. Code Ann. §0400-12-01 Tenn. Code Ann. §0400-12-02 40 CFR 260 through 279 Hazardous Waste Permit Required for any person owning or operating a new or existing facility that treats, stores, or disposes of a hazardous waste Pending applicability Tenn. Code Ann. §68-212-101 Resource Conservation and Recovery Act 40 CFR 261 and 262 Acknowledgement of Notification of Hazardous Waste Activity Generation of hazardous waste Notification not yet submitted Tennessee Department of Environment and Conservation, Division of Radiological Health Chapter 0400-20-05, Standards for Protection Against Radiation 0400-20-19, Licensing and Registration Specific Radioactive Material License Required for source material and/or sealed sources above exempt quantities License application not yet submitted General Radioactive Material License Required for certain types of radioactive sources and devices containing radioactive material require the purchaser to have a general radioactive material license which is provided by the manufacturer License application not yet submitted Registration of X-Ray Producing Equipment The facility has several types of X-Ray equipment License application not yet submitted Radioactive Waste License-for-Delivery Transportation of radioactive waste into or within the State of Tennessee to a disposal/

processing facility License application not yet submitted 10 CFR 30 By-Product Material License Production, possession, and transfer of radioactive by-product material License application not yet submitted 10 CFR 40 Source Material License Possession, use, and transfer of radioactive source material License application not yet submitted

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-18 Rev. 1 Table 1.4-1 (Sheet 4 of 5)

Permits and Approvals Required for Construction and Operation Agency Regulatory Authority Permit or Approval Activity Covered Status City of Oak Ridge Community Development Department City of Oak Ridge Ordinance Site Plan Application A site plan must be submitted for approval before a land disturbance permit and/or building permit can be issued Preliminary Site Plan approved October 2022.

Traffic Study review completed with no comments August 2023. Revised Preliminary Site Plan approved March 2024. See Appendix 1A, Regulatory Correspondence.

City of Oak Ridge Ordinance Building Permit Construction of buildings Permit application not yet submitted City of Oak Ridge Ordinance Land Disturbance Permit Required for land disturbing activity that disturbs more than one acre of land. A required attachment is a TDEC Notice of Coverage under the General NPDES Permit for Stormwater Discharges associated with Construction Activity Land Disturbance Permit issued October 3, 2024. See Appendix 1A, Regulatory Correspondence.

City of Oak Ridge Ordinance Plumbing Permit Installation of plumbing systems Permit application not yet submitted City of Oak Ridge Ordinance Electrical Permit Installation of electrical systems Permit application not yet submitted City of Oak Ridge Ordinance Mechanical Permit Installation of mechanical systems Permit application not yet submitted City of Oak Ridge Zoning Ordinance Zoning Approval Construction of a nuclear fuel fabrication facility Rezoning from IND-2 to IND-3 (heavy industrial district) was approved on September 12, 2022 and the Ordinance to amend the zoning became effective on September 22, 2022. See Appendix 1A, Regulatory Correspondence.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-19 Rev. 1 Table 1.4-1 (Sheet 5 of 5)

Permits and Approvals Required for Construction and Operation Sources for identification of permit requirements: City of Oak Ridge, 2022; State of Tennessee, 2022; Tennessee Department of Environment and Conservation, Division of Water Resources, 2022; Tennessee Air Pollution Control Board, Department of Environment and Conservation, 2021; Roane County, 2022.

Agency Regulatory Authority Permit or Approval Activity Covered Status City of Oak Ridge Zoning Ordinance Special Exception Requiring Board of Zoning Appeals Approval Based on the judgment of the Board of Appeals to promote orderly industrial districts containing industries compatible with each other Not required, does not meet criteria.

City of Oak Ridge Zoning Ordinance Temporary Use Permit Installation of seasonal or non-permanent uses Pending applicability Building Permit Construction of building The project is not located within unincorporated Roane County, therefore, please refer to City of Oak Ridge Regulations Zoning Construction of a nuclear fuel fabrication facility

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-20 Rev. 1 Table 1.4-2 (Sheet 1 of 3)

Consultations Required Agency Regulatory Authority Required Consultation Surveys Required Status U.S. Fish and Wildlife Service Endangered Species Act TRISO-X informal consultation regarding potential to adversely impact protected species; concurrence with no adverse impact or consultation on appropriate mitigation measures Rare threatened and endangered species survey Initial coordination letter sent March 9, 2022. USFWS response dated April 15, 2022, states the USFWS will conduct a thorough review upon submittal of the Environmental Impact Statement (See Appendix 1A, Regulatory Correspondence). Field surveys conducted in 2021 and 2022 demonstrated no rare, threatened or endangered species on-site.

Endangered Species Act Section 7 NRC / DOE formal consultation regarding potential to adversely impact protected species; concurrence with no adverse impact or consultation on appropriate mitigation measures Rare threatened and endangered species survey Request to initiate consultation with the USFWS sent on September 20, 2023. USFWS response dated October 12, 2023, states that USFWS concurs with the DOEs determination of not likely to adversely affect federally listed species. The letter recommends two methods to minimize potential effects of artificial lighting on northern long-eared bats during construction and operation (See Appendix 1A, Regulatory Correspondence).

Bald and Golden Eagle Protection Act TRISO-X informal consultation regarding potential to adversely impact eagles; concurrence with no adverse impact or consultation on appropriate mitigation measures Bald eagle survey Initial coordination letter sent March 9, 2022. USFWS response dated April 15, 2022, states the USFWS will conduct a thorough review upon submittal of the Environmental Impact Statement (See Appendix 1A, Regulatory Correspondence). No bald eagle nests were observed during the 2021 and 2022 field surveys and no large trees typically used for bald eagle nesting (cottonwood or sycamore) were observed on-site.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-21 Rev. 1 Table 1.4-2 (Sheet 2 of 3)

Consultations Required Agency Regulatory Authority Required Consultation Surveys Required Status Tennessee State Historic Preservation Office National Historic Preservation Act, Section 106 TRISO-X Informal consultation regarding potential to adversely impact historic resources; concurrence with no adverse impact or consultation on appropriate mitigation measures Phase I Cultural Resource Survey Coordination letter sent April 13, 2022, and included the submittal of results of the cultural resource survey. SHPO response dated April 14, 2022, states no historic properties will be affected that are eligible for listing in the National Register of Historic Places (See Appendix 1A, Regulatory Correspondence). Formal Section 106 consultation will be conducted between the SHPO and NRC.

National Historic Preservation Act, Section 106 NRC/DOE formal consultation regarding potential to adversely impact historic resources; concurrence with no adverse impact or consultation on appropriate mitigation measures Phase I Cultural Resource Survey Consultation letter sent September 5, 2023, and included the final cultural resource report. SHPO response dated September 11, 2023, states the final report meets the SHPO Reporting Standards and/or the Tennessee SHPO Standards and Guidelines for Archeological Resource Management Studies (See Appendix 1A, Regulatory Correspondence).

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 1-22 Rev. 1 Table 1.4-2 (Sheet 3 of 3)

Consultations Required Agency Regulatory Authority Required Consultation Surveys Required Status Tennessee Wildlife Resources Agency Tennessee Administrative Code Chapter 1660-01-32

- Rules and Regulations for In Need of Management, Threatened, and Endangered Species Consultation regarding potential to adversely impact protected species or rare natural habitats species; concurrence with no adverse impact or consultation on appropriate mitigation measures None Initial Coordination letter sent March 9, 2022 (See Appendix 1A, Regulatory Correspondence). Response from TWRA not yet received.

U.S. Army Corps of Engineers and Tennessee Department of Environment and Conservation Section 401/402/404 of the Clean Water Act Concurrence and/or approval on the findings of the Wetlands and WOTUS Delineation Report (prepared in February 2022)

Wetlands Delineation survey Consultation letters sent to TDEC and USACE on February 2, 2022.

Received concurrence/approval from TDEC on May 24, 2022 (See Appendix 1A, Regulatory Correspondence). Preliminary Jurisdictional Determination received from USACE on March 15, 2023.

Environmental Report for the TRISO-X Fuel Fabrication Facility Appendix 1A Regulatory Correspondence January 2025 1-23 Rev. 1 APPENDIX 1A REGULATORY CORRESPONDENCE The following documents are included in this appendix:

1. Letter dated February 2, 2022 from Mary Motte Fikri and Stan Rudzinski (Wood Environment & Infrastructure Solutions, Inc.) to Mr. Michael Atchley (Tennessee Department of Environment and Conservation, Knoxville Environmental Field Office),

Request for Concurrence - Hydrologic Determination for Horizon Lot 6, Oak Ridge, Roane County, Tennessee. (1 page).

2. Letter dated February 2, 2022 from Mary Motte Fikri and Stan Rudzinski (Wood Environment & Infrastructure Solutions, Inc.) to Eastern Regulatory Field Office U.S.

Army Corps of Engineers, Request for Jurisdictional Determination - TRISO-X Facility Project Area, Horizon Center-Lot 6, Oak Ridge, Roane County, Tennessee. (1 page).

3. Letter dated March 9, 2022 from William Elzinga (Wood Environment & Infrastructure Solutions, Inc.) to Brandon Wear (Regional Wildlife Program Manager Tennessee Wildlife Resources Agency), Request for Information on Potential Site for a Proposed Fuel Fabrication Facility in Eastern Tennessee (Horizon Center site). (4 pages)

4. Letter dated March 9, 2022 from William Elzinga (Wood Environment & Infrastructure Solutions, Inc.) to Mr. Robbie Sykes (Permits Coordinator U.S. Fish and Wildlife Service), Request for Information on Potential Site for a Proposed Fuel Fabrication Facility in Eastern Tennessee (Horizon Center site). (4 pages)

5. Email from Steven Alexander (U.S. Fish and Wildlife Service) to Rebecca Porath and William J. Elzinga (Wood Environment & Infrastructure Solutions, Inc.),

Subject:

TRISO-X Project on the Oak Ridge Reservation, Date: Friday, April 15, 2022 6:08:05 AM. (2 pages)

6. Email from William Elzinga (Wood Environment & Infrastructure Solutions, Inc.) to Steven Alexander (U.S. Fish and Wildlife Service),

Subject:

Re: TRISO-X Project on the Oak Ridge Reservation, Date: Friday, April 15, 2022 8:05:34 AM. (2 pages)

7. Letter dated April 13, 2022 from William Elzinga (Wood Environment & Infrastructure Solutions, Inc.) to E. Patrick McIntyre, Jr. (Executive Director and State Historic Preservation Officer), Phase I Cultural Resource Survey for the TRISO-X Fuel Fabrication Facility Horizon Center site TRISO-X, LLC U.S. Nuclear Regulatory Commission (NRC) Licensing Application Project, Roane County, Tennessee. (3 pages)

8. Letter dated April 14, 2022 from E. Patrick McIntyre, Jr. (Executive Director and State Historic Preservation Officer) to William Elzinga (Wood Environment & Infrastructure Solutions, Inc.), NRC / Nuclear Regulatory Commission, TRISO-X Fuel Fabrication Facility Horizon Center site TRISO-X, LLC, Oak Ridge, Roane County, TN. (1 page)

9. Email from Steve Brooks (Environmental Scientist, TDEC Division of Water Resources, Knoxville Environmental Field Office) to Mary Motte Fikri (Wood Environment &

Infrastructure Solutions, Inc.),

Subject:

Fwd: HD submittal approval, Tuesday, May 24, 2022 8:25:04 AM. (1 page)

Environmental Report for the TRISO-X Fuel Fabrication Facility Appendix 1A Regulatory Correspondence January 2025 1-24 Rev. 1

10. Letter dated September 5, 2023 from Michelle Rome (Chief, Environmental Review Materials Branch Division of Rulemaking, Environmental and Financial Support Office of Nuclear Material Safety and Safeguards) to Patrick McIntyre (Executive Director and State Historic Preservation Officer), Section 106 Consultation of the National Historic Preservation Act for the TRISO-X Fuel Fabrication facility in Oak Ridge, Tennessee (DOCKET NUMBER: 70-7027). (3 pages)

11. Email from E. Patrick McIntyre, Jr. (Executive Director and State Historic Preservation Officer) to Marla Morales (Nuclear Regulatory Commission),

Subject:

TRISO-X Fuel Fabrication Facility Horizon Center Site TRISO-X, LLC - Project # SHPO0003744, Monday, September 11, 2023 3:05:48 PM. (2 pages)

12. Letter dated September 20, 2023 from Michelle Rome (Chief, Environmental Review Materials Branch Division of Rulemaking, Environmental and Financial Support Office of Nuclear Material Safety and Safeguards) to Steven R. Alexander (U.S. Fish and Wildlife Service), TRISO-X, LLC Special Nuclear Material License Application for a Fuel fabrication Facility in Oak Ridge, Roan County, Tennessee (DOCKET NUMBER: 70-7027). (18 pages)

13. Letter dated October 12, 2023 from Nicole Sikula (Acting Field Supervisor, U.S. Fish and Wildlife Service) to Jill S. Caverly (Senior Project Manager, U.S. Nuclear Regulatory Commission), FWS #2022-0019326: NRC TRISO-X Facility, Horizon Center, Roan County, Tennessee. (2 pages)

14. Letter dated March 15, 2023 from Brent Sewell (for Casey H. Ehorn, USACE Chief, East Branch Regulatory Division) to Jennifer Wheeler (X Energy, LLC/ TRISO-X, LLC), LRN-2013-00515, Horizon Center Site, Lot 6, oak Ridge, Roane County, Tennessee. (10 pages)

15. Notice of Coverage dated November 10, 2022, from Tennessee Department of Environment and Conservation, TNR136931, TRISO-X Fuel Fabrication Facility (88.75 acres - Phased Construction). (4 pages)

16. Email from @oakridgetn.gov to Jennifer Wheeler, Burns Cunningham (X Energy, LLC/

TRISO-X, LLC),

Subject:

TRISO-X Preliminary Site Plan Approval, Monday, October 24, 2022 4:21 PM. (1 page)

17. Email from @oakridgetn.gov to Jennifer Wheeler, Burns Cunningham (X Energy, LLC/

TRISO-X, LLC),

Subject:

TRISO-X traffic study questions, Friday, August 18, 2023, 1:34 PM. (1 page)

18. Email from @oakridgetn.gov to Burns Cunningham, Jennifer Wheeler (X Energy, LLC/

TRISO-X, LLC),

Subject:

TRISO-X Updated Site Plan Review Package for PLSPL20220174, Friday, March 8, 2024, 4:25 PM. (1 page)

19. Land Disturbance Permit Issuance, Permit No. PRLD202402171, from City of Oak Ridge, Issued October 3, 2024. (1 page)

20. City of Oak Ridge, Ordinance No. 19-2022, AN ORDINANCE TO AMEND ORDINANCE NO. 2, TITLED "THE ZONING ORDINANCE OF THE CITY OF OAK RIDGE,

Environmental Report for the TRISO-X Fuel Fabrication Facility Appendix 1A Regulatory Correspondence January 2025 1-25 Rev. 1 TENNESSEE," BY AMENDING THE ZONING MAP WHICH IS MADE A PART OF THE ORDINANCE BY CHANGING THE ZONING DISTRICT OF ROANE COUNTY TAX MAP 021, PARCEL 002.00, ALSO KNOWN AS HORIZON CENTER DEVELOPMENT AREA/LOT 6A, CONTAINING APPROXIMATELY 110 ACRES, FROM IND-2, INDUSTRIAL DISTRICT, TO IND-3, INDUSTRIAL DISTRICT. Effective Date:

September 22, 2022. (2 pages)

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report 6HSWHPEHU 2022 Rev. 0 Figure 1.3-1 Site Location

Environmental Report for the TRISO-X Fuel Fabrication Facility September 2022 Rev. 0 Figure 1.3-2 Bounding Limits Chapter 1 - Introduction of the Environmental Report

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2025 Rev. 1 Figure 1.3-3 Site Plan

Wood Environment & Infrastructure Solutions, Inc.

3800 Ezell Road, Suite 100 Nashville, Tennessee 37211 T: 615-333-0630 www.woodplc.com February 2, 2022 Mr. Michael Atchley Tennessee Department of Environment and Conservation Knoxville Environmental Field Office 3711 Middlebrook Pike, Knoxville, TN 37921 Michael.Atchley@tn.gov

Subject:

Request for Concurrence - Hydrologic Determination Horizon, Lot 6 Oak Ridge, Roane County, Tennessee Wood Project No. 325221235

Dear Mr. Atchley,

On behalf of X-energy, Wood Environment & Infrastructure Solutions, Inc. (Wood) is requesting a Hydrologic Determination (HD) on several drainages at the approximately 150-acre site identified as Horizon Lot 6 and located along Renovare Boulevard, in Oak Ridge, Roane County, Tennessee. The property is currently owned by the City of Oak Ridge Industrial Development Board. X-energy, an advanced reactor (AR) development company, is in the process of licensing a nuclear fuel fabrication facility to produce Tristructural Isotropic (TRISO) uranium fuel to power high temperature gas reactors (HTGRs) and other users of TRISO-based fuel and plans to purchase the site to develop the facility to fabricate pebble fuel for the Xe-100 pebble bed HTGR as well as for other advanced reactor designs. The license application will include information necessary for the U.S. Nuclear Regulatory Commission (NRC) to conduct an environmental analysis and make a decision regarding approval or denial of the requested license.

Wood conducted a review of the site on September 7-9, 2021. We have enclosed the Waters of the U.S. Delineation Technical Report, which includes relevant mapping, photographs, and HD field data sheets for each evaluated channel.

Based on our review, we identified two intermittent streams (channel segments 1a, 1b, and 2a) that likely fall under the jurisdiction of the Tennessee Department of Environment & Conservation (TDEC) and the U.S. Army Corps of Engineers (USACE). Other drainages at the site were determined to be wet weather conveyances.

If an on-site review is required, please contact me to arrange access to the site. Should you have any questions regarding the enclosed, please contact me at (615) 424-6279 or email me at marymotte.fikri@woodplc.com.

Respectfully submitted, Wood Environment & Infrastructure Solutions, Inc.

Mary Motte Fikri, PWS Stan Rudzinski, CE, CPESC, QHP Senior Biologist Associate Biologist

Enclosure:

TRISO-X Facility Environmental Report-Waters of the U.S. Delineation Technical Report, Horizon Center Site - Lot 6

Wood Environment & Infrastructure Solutions, Inc.

3800 Ezell Road, Suite 100 Nashville, Tennessee 37211 T: 615-333-0630 www.woodplc.com February 2, 2022 Eastern Regulatory Field Office U.S. Army Corps of Engineers 501 Adesa Blvd, Suite B 250 Lenoir City, Tennessee 37771 NashvilleRegulatory@usace.army.mil

Subject:

Request for Jurisdictional Determination TRISO-X Facility Project Area, Horizon Center-Lot 6 Oak Ridge, Roane County, Tennessee Wood Project No. 325221235

Dear Sir/Madam:

On behalf of X-energy, Wood Environment & Infrastructure Solutions, Inc. (Wood) is requesting a Jurisdictional Determination (JD) on an approximately 150-acre site located along Renovare Boulevard, in Oak Ridge, Roane County, Tennessee. The property is currently owned by the City of Oak Ridge Industrial Development Board. X-energy, an advanced reactor (AR) development company, is in the process of licensing a nuclear fuel fabrication facility to produce Tristructural Isotropic (TRISO) uranium fuel to power high temperature gas reactors (HTGRs) and other users of TRISO-based fuel and plans to purchase the site to develop the facility to fabricate pebble fuel for the Xe-100 pebble bed HTGR as well as for other advanced reactor designs. The license application will include information necessary for the U.S. Nuclear Regulatory Commission (NRC) to conduct an environmental analysis and make a decision regarding approval or denial of the requested license.

Wood conducted a review of the site on September 7-9, 2021. We have enclosed the Waters of the U.S. Delineation Technical Report, which includes relevant mapping, photographs, and data sheets. Based on our review, we identified two intermittent streams (channel segments 1a, 1b, and 2a) that likely fall under the jurisdiction of the Tennessee Department of Environment &

Conservation (TDEC) and the U.S. Army Corps of Engineers (USACE). Other drainages at the site were determined to be wet weather conveyances. No wetlands were identified at the site.

As indicated in the attached JD Request Form, the proposed project may require authorization from the USACE; however, project development is still in progress and impacts have not yet been identified. The JD would be used to avoid and minimize impacts to jurisdictional aquatic resources and as an initial step in a future permitting process.

If an on-site review is required, please contact us to arrange access to the site. Should you have any questions regarding the enclosed, please contact me at (615) 424-6279 or email me at marymotte.fikri@woodplc.com.

Respectfully submitted, Wood Environment & Infrastructure Solutions, Inc.

Mary Motte Fikri, PWS Stan Rudzinski, CE, CPESC, QHP Senior Biologist Associate Biologist

Enclosures:

Appendix 1 - Request for Corps Jurisdictional Determination Form TRISO-X Facility Environmental Report - Waters of the U.S. Delineation Technical Report, Horizon Center - Lot 6

March 9, 2022

1 Wood Environment & Infrastructure Solutions, Inc.

15933 Clayton Road, Suite 215 Ballwin, MO 63011 USA T: 636-200-5100 www.woodplc.com Brandon Wear, Regional Wildlife Program Manager Tennessee Wildlife Resources Agency Region 3 Office 464 Industrial Blvd.

Crossville, TN 38555 RE:

Request for Information on Potential Site for a Proposed Fuel Fabrication Facility in Eastern Tennessee (Horizon Center Site)

Dear Mr. Wear,

Wood Environment & Infrastructure Solutions, Inc. (Wood) has been retained by TRISO-X, LLC (TRISO-X) to assist in the evaluation of construction and operation impacts for a proposed Fuel Fabrication Facility (FFF). TRISO-X is an advanced nuclear reactor design and fuel fabrication company that intends to fabricate advanced nuclear fuels from high assay low enriched uranium (HALEU), based on TRISO-Xs uranium oxycarbide tristructural isotropic (TRISO) fuel forms, for use in both advanced reactors and the existing fleet of light-water reactors. TRISO-coated fuels are unique in their multi-layer encapsulation of uranium, providing increased safety, proliferation resistance, and functional containment. TRISO-X has demonstrated TRISO-based fuel fabrication capability at the commercial scale TRISO-X Pilot Facility at the Oak Ridge National Laboratory (ORNL).

A license under 10 CFR Part 70 from the Office of Nuclear Material Safety and Safeguards (NMSS) of the United States Nuclear Regulatory Commission (NRC) will be required for construction and operation of the proposed commercial TRISO-X FFF. TRISO-X is in the process of preparing an Environmental Report (ER) in compliance with NUREG 1748 (Environmental Review Guidance for Licensing Actions Associated with NMSS Programs, issued by NRC) to be used by the NRC to prepare an Environmental Impact Statement (EIS) for compliance with the National Environmental Policy Act (NEPA).

In 2019, a potential site for the facility was identified at the existing Technology & Manufacturing Center in Oak Ridge, Anderson County, Tennessee that is currently operated by Centrus Energy Corporation. A request for information regarding that site was sent to your agency on September 12, 2019. However, TRISO-X has since revised its preferred site for potential construction and operation of the FFF and is considering an undeveloped, approximately 110-acre site identified as the Horizon Center Site (HCS) located near 201 Renovare Boulevard in Oak Ridge, Roane County, Tennessee, approximately 25 miles from Knoxville. The HCS property is currently owned by the City of Oak Ridge Industrial Development Board and TRISO-X may purchase all or a portion of this site for development of the FFF.

HCS has the available space for construction of infrastructure required for all activities from receiving the raw material to the production of the final fuel product, including fuel fabrication, material storage, administrative offices, and other supporting facilities. The site has access to needed utilities, such as

2 gas, supply of water, electricity, and other utilities. The facility would obtain water, for both potable and industrial use, from the City of Oak Ridge public distribution system. Similarly, the City of Oak Ridge would provide wastewater treatment services to the proposed facility.

The FFF would be constructed mostly on previously disturbed land with herbaceous vegetation cover that is mowed periodically. It would consist of the following features:

Process building including administration Raw material preparation building Security/emergency operation building Electrical and mechanical equipment yards Roadways Drainage ditches Detention basin Shipping and receiving docks Gravel surfacing Grass seeding area Permanent asphalt parking areas Temporary construction laydown/parking/access roads Temporary sediment basin Temporary ditches The potential area of disturbance during construction would be approximately 90 acres, with approximately 60 acres of permanent development and approximately 15 acres of temporary use areas, including construction parking, laydown, and gravel access roads.

As part of the planning and evaluation process, and to meet requirements in NUREG 1748, we are requesting information and input from Tennessee Wildlife Resources Agency to identify notable environmental resources or issues of concern that should be considered in the construction and operation of the proposed facility. These issues could include state threatened or endangered species, rare species and/or ecological communities listed and/or tracked by the State of Tennessee, nuisance species or species considered disease vectors or pests, habitat at the site for important species relative to the habitat available throughout the species entire range, locations of travel corridors for important terrestrial species that could potentially be affected by use of the site, or the presence of wildlife species important for game or subsistence hunting or fishing.

In conjunction with the guidance of NUREG 1748, a full range interdisciplinary analysis will be conducted in the preparation of the ER and the overall licensing process. To assist your consideration of this request, please find attached figures depicting the project site and vicinity. We respectfully request your review and input for our consideration in the development of licensing application materials.

If you have any questions or comments about the proposed TRISO-X FFF or the materials provided, please call me at 314-520-1506.

Respectfully, William Elzinga Senior Associate Scientist Attachment

3

4

March 9, 2022

1 Wood Environment & Infrastructure Solutions, Inc.

15933 Clayton Road, Suite 215 Ballwin, MO 63011 USA T: 636-200-5100 www.woodplc.com Mr. Robbie Sykes, Permits Coordinator U.S. Fish and Wildlife Service Tennessee Field Office 446 Neal Street Cookeville, TN 38506 RE:

Request for Information on Potential Site for a Proposed Fuel Fabrication Facility in Eastern Tennessee (Horizon Center Site)

Dear Mr. Sykes,

Wood Environment & Infrastructure Solutions, Inc. (Wood) has been retained by TRISO-X, LLC (TRISO-X) to assist in the evaluation of construction and operation impacts for a proposed Fuel Fabrication Facility (FFF). TRISO-X is an advanced nuclear reactor design and fuel fabrication company that intends to fabricate advanced nuclear fuels from high assay low enriched uranium (HALEU), based on TRISO-Xs uranium oxycarbide tristructural isotropic (TRISO) fuel forms, for use in both advanced reactors and the existing fleet of light-water reactors. TRISO-coated fuels are unique in their multi-layer encapsulation of uranium, providing increased safety, proliferation resistance, and functional containment. TRISO-X has demonstrated TRISO-based fuel fabrication capability at the commercial scale TRISO-X Pilot Facility at the Oak Ridge National Laboratory (ORNL).

A license under 10 CFR Part 70 from the Office of Nuclear Material Safety and Safeguards (NMSS) of the United States Nuclear Regulatory Commission (NRC) will be required for construction and operation of the proposed commercial TRISO-X FFF. TRISO-X is in the process of preparing an Environmental Report (ER) in compliance with NUREG 1748 (Environmental Review Guidance for Licensing Actions Associated with NMSS Programs, issued by NRC) to be used by the NRC to prepare an Environmental Impact Statement (EIS) for compliance with the National Environmental Policy Act (NEPA).

In 2019, a potential site for the facility was identified at the existing Technology & Manufacturing Center in Oak Ridge, Anderson County, Tennessee that is currently operated by Centrus Energy Corporation. A request for information regarding that site was sent to your agency on September 12, 2019. However, TRISO-X has since revised its preferred site for potential construction and operation of the FFF and is considering an undeveloped, approximately 110-acre site identified as the Horizon Center Site (HCS) located near 201 Renovare Boulevard in Oak Ridge, Roane County, Tennessee, approximately 25 miles from Knoxville. The HCS property is currently owned by the City of Oak Ridge Industrial Development Board and TRISO-X may purchase all or a portion of this site for development of the FFF.

HCS has the available space for construction of infrastructure required for all activities from receiving the raw material to the production of the final fuel product, including fuel fabrication, material storage, administrative offices, and other supporting facilities. The site has access to needed utilities, such as

2 gas, supply of water, electricity, and other utilities. The facility would obtain water, for both potable and industrial use, from the City of Oak Ridge public distribution system. Similarly, the City of Oak Ridge would provide wastewater treatment services to the proposed facility.

The FFF would be constructed mostly on previously disturbed land with herbaceous vegetation cover that is mowed periodically. It would consist of the following features:

Process building including administration Raw material preparation building Security/emergency operation building Electrical and mechanical equipment yards Roadways Drainage ditches Detention basin Shipping and receiving docks Gravel surfacing Grass seeding area Permanent asphalt parking areas Temporary construction laydown/parking/access roads Temporary sediment basin Temporary ditches The potential area of disturbance during construction would be approximately 90 acres, with approximately 60 acres of permanent development and approximately 15 acres of temporary use areas, including construction parking, laydown, and gravel access roads.

As part of the planning and evaluation process, and to meet requirements in NUREG 1748, we are requesting information and input from the U.S. Fish and Wildlife Service to identify notable environmental resources or issues of concern that should be considered in the construction and operation of the proposed facility. These issues could include threatened or endangered species listed under the Endangered Species Act, designated critical habitats, nuisance species or species that are of concern as disease vectors or pests, habitat at the site for important species relative to the habitat available throughout the species entire range, locations of travel corridors for important terrestrial species that could potentially be affected by use of the site, or the presence of wildlife species important for game or subsistence hunting or fishing.

In conjunction with the guidance of NUREG 1748, a full range interdisciplinary analysis will be conducted in the preparation of the ER and the overall licensing process. To assist your consideration of this request, please find attached figures depicting the project site and vicinity. We respectfully request your review and input for our consideration in the development of licensing application materials.

If you have any questions or comments about the proposed TRISO-X FFF or the materials provided, please call me at 314-520-1506.

Respectfully, William Elzinga Senior Associate Scientist Attachment

3

4

From:

Alexander, Steven To:

Porath, Rebecca; Elzinga, William J

Subject:

TRISO-X Project on the Oak Ridge Reservation Date:

Friday, April 15, 2022 6:08:05 AM CAUTION: External email. Please do not click on links/attachments unless you know the content is genuine and safe.

Ms. Porath and Mr. Elzinga -

The U.S. Fish and Wildlife Service has reviewed the IPaC information and your correspondence, dated March 9, 2022, regarding the proposed nuclear fuel fabrication facility at the Horizon Center Site in Roane County. This area of the Oak Ridge Reservation provides significant summer roosting habitats for the federally endangered Indiana bat and threatened Northern long-eared bat. The general project area has significant karst features which support the federally endangered Gray bat and this specific parcel is adjacent to the Black Oak Ridge Conservation Easement.

This parcel was cleared by the Oak Ridge Industrial Development Board several years ago without appropriate environmental review or permitting by the State of Tennessee. There have been numerous protected species surveys on this site and the parcel has deed restrictions which direct appropriate environmental documentation requirements pursuant to the National Environmental Policy Act. We will provide a thorough review of your Environmental Assessment (EA) when completed. This information should include all necessary site infrastructure requirements including source(s) of electricity and water needed to facilitate its construction and operation. Please forward the draft EA and any ancillary project information to my attention.

Sincerely, Steven R. Alexander U.S. Fish and Wildlife Service South Atlantic-Gulf Interior Region Tennessee Ecological Services Field Office 446 Neal Street Cookeville, TN 38501 931/525-4980 (office) 931/650-0004 (cell) 931/528-7075 (fax) steven_alexander@fws.gov Web: http://cookeville.fws.gov

>>> I am working from home during the COVID-19 pandemic. All calls to my office phone are being forwarded to my cellphone. <<<

NOTE: This email correspondence, including any attachments to and from this sender, is subject to the Freedom of Information Act (FOIA) and may be disclosed to third parties.

From:

Elzinga, William J To:

Alexander, Steven Cc:

Jennifer Wheeler; Porath, Rebecca

Subject:

Re: TRISO-X Project on the Oak Ridge Reservation Date:

Friday, April 15, 2022 8:05:34 AM Mr. Alexander, Thank you so much for your prompt response to our letter on behalf of TRISO-X, LLC regarding the proposed TRISO-X Fuel Fabrication Facility in Oak Ridge, Tennessee. We appreciate your comments and acknowledge your observed sensitivities regarding the environmental resources of the Horizon Center Site and its associated environs. We can assure you that these factors have been taken into full account as part of our analysis.

Our analysis will be included in an Environmental Report (ER) that will be issued by the Nuclear Regulatory Commission (NRC) in their preparation of an Environmental Impact Statement (EIS) for the proposed project in conjunction with their licensing action. The NRC will certainly engage the USFWS as part of their ER review process.

Again, we thank you for your comments and we welcome continued dialog with the USFWS if needed.

Note that for your information I am also copying Ms. Jennifer Wheeler who is the environmental licensing lead for TRISO-X, LLC.

Regards, Bill Elzinga From: Alexander, Steven <steven_alexander@fws.gov>

Sent: Friday, April 15, 2022 6:08 AM To: Porath, Rebecca; Elzinga, William J

Subject:

TRISO-X Project on the Oak Ridge Reservation CAUTION: External email. Please do not click on links/attachments unless you know the content is genuine and safe.

Ms. Porath and Mr. Elzinga -

The U.S. Fish and Wildlife Service has reviewed the IPaC information and your correspondence, dated March 9, 2022, regarding the proposed nuclear fuel fabrication facility at the Horizon Center Site in Roane County. This area of the Oak Ridge Reservation provides significant summer roosting habitats for the federally endangered Indiana bat and threatened Northern long-eared bat. The general project area has significant karst features which support the federally endangered Gray bat and this specific parcel is adjacent to the Black Oak Ridge Conservation Easement.

This parcel was cleared by the Oak Ridge Industrial Development Board several years ago without appropriate environmental review or permitting by the State of Tennessee. There have been numerous protected species surveys on this site and the parcel has deed restrictions which direct appropriate environmental documentation requirements pursuant to the National Environmental Policy Act. We will provide a thorough review of your Environmental Assessment (EA) when completed. This information should include all necessary site infrastructure requirements including source(s) of electricity and water needed to facilitate its construction and operation. Please forward the draft EA and any ancillary project information to my attention.

Sincerely, Steven R. Alexander U.S. Fish and Wildlife Service South Atlantic-Gulf Interior Region Tennessee Ecological Services Field Office 446 Neal Street Cookeville, TN 38501 931/525-4980 (office) 931/650-0004 (cell) 931/528-7075 (fax) steven_alexander@fws.gov Web: http://cookeville.fws.gov

>>> I am working from home during the COVID-19 pandemic. All calls to my office phone are being forwarded to my cellphone. <<<

NOTE: This email correspondence, including any attachments to and from this sender, is subject to the Freedom of Information Act (FOIA) and may be disclosed to third parties.

Wood Environment & Infrastructure Solutions, Inc.

15933 Clayton Road, Suite 215 Ballwin, MO 63011 USA T: 636-200-5100 www.woodplc.com April 13, 2022 Mr. E. Patrick McIntyre, Jr.

Executive Director and State Historic Preservation Officer Tennessee Historical Commission State Historic Preservation Office 2941 Lebanon Pike Nashville, TN 37214 RE:

Phase I Cultural Resource Survey for the TRISO-X Fuel Fabrication Facility Horizon Center Site TRISO-X, LLC U.S. Nuclear Regulatory Commission (NRC) Licensing Application Project, Roane County, Tennessee

Dear Mr. McIntyre,

On behalf of TRISO-X LLC, Wood Environment & Infrastructure Solutions, Inc (Wood) is completing environmental reviews and environmental clearance documentation for a proposed project in Roane County, Tennessee. Wood is working to support our client (TRISO-X, LLC) to obtain a license from the United States National Regulatory Commission (NRC) for the proposed nuclear fuel fabrication facility to produce TRistructural ISOtropic (TRISO) uranium fuel to power high-temperature gas reactors (HTGRs). The licensing application includes an Environmental Report (ER) that NRC will use in the consideration of the licensing action and their preparation of an Environmental Impact Statement (EIS) pursuant to the National Environmental Policy Act (NEPA). The NRC released NUREG-1748 which provides guidance to NRC staff in conducting their environmental review of licensing actions. The environmental review process is initiated by an application for a new license or certification. NUREG 1748, Chapter 6, provides guidance to NRC staff, but this guidance is also used to assist the applicant/licensee in preparing the ER which aids the NRC in preparing an EA or EIS and complying with Section 102(2) of NEPA. Chapter 6.3.8 of NUREG 1748 notes that the ER should include the results of any consultation that the applicant may have had with Federal, State, local, and affected American Indian tribal agencies. The results of the site investigations related to historic properties and the correspondence with the SHPO will be documented in the ER which will be submitted to NRC as part of the license application (Note: the license application will be submitted by TRISO-X, LLC). Formal consultation will be conducted with the Tennessee State Historic Preservation Office (TN-SHPO) by NRC during the process of their review of the ER and their preparation of the EIS in accordance with the Section 106 process. We respectfully request comment from your office on the results of the attached Phase I Cultural Resource Survey Report and will represent the content of your comments in the ER.

TRISO-X Fuel Fabrication Facility Horizon Center Site TRISO-X, LLC April 13, 2022 2

The survey area for the archaeological survey consists of 150.1 acres (ac), while the Area of Potential Effect (APE) represents a subset of the survey area equaling approximately 110 acres. After archaeological survey of 150.1 acres was complete, TRISO-X reduced the size of their proposed project to 110 acres, known as the Horizon Center Site (HCS) within the original survey area. Since the survey was already complete and archaeological sites were identified outside the revised proposed project boundary, both the survey area (150.1 acres) and the APE (110 acres) were reported. TRISO-X proposes to build the TRISO-X Fuel Fabrication Facility within the APE and no construction or ground disturbance is planned outside of this boundary.

Wood determined that investigation of a 0.5-mile viewshed or visual Area of Potential Effects (APE) was appropriate to assess impacts on offsite architectural resources. However, background research was conducted for a 2-mile buffer of the survey area for both archaeological and architectural resources in an effort to gain a thorough understanding of the project vicinity prior to initiation of fieldwork.

During the archaeological survey, a total of five archaeological sites and one historic cemetery were documented: 40RE637, 40RE638, 40RE639, 40RE640, 40RE641, and the McKamey and Carmichael Cemetery. Sites 40RE637, 40RE638, and a portion of the McKamey and Carmichael Cemetery are located within the APE. The remaining sites (40RE639, 40RE640, and 40RE641) are located in the survey area but outside of the APE and no proposed construction or ground disturbance is planned at these sites.

Site 40RE637 is a historic domestic dwelling dating to the mid-nineteenth century and 40RE638 is a historic dwelling dating to the early-nineteenth to early-twentieth century. Wood recommends site 40RE637 and 40RE638 be considered not eligible for the National Register of Historic Places (NRHP) and no further archaeological work is recommended.

Sites 40RE639 and 40RE640 are historic domestic dwellings dating to the early-to mid-nineteenth century into the late-nineteenth century. Site 40RE639 contains a pile of cut stone with brick present that may represent a fallen chimney. Roughly 50 m east of 40RE639 is site 40RE640, a historic domestic dwelling with intact features. Site 40RE640 is a multicomponent historic domestic dwelling dating to the early-nineteenth century that continued into the early-twentieth century. 40RE640 also contains several intact and remnant historic features, including at least two large cut limestone piles, a stacked cut limestone wall within a deep depression that likely represents a cellar, and a large semi-circular wet and shallow area lined on its western side with cut limestone. Wood recommends avoidance of sites 40RE639 and 40RE640. If avoidance is not possible, additional archaeological and archival work is recommended to determine their NRHP eligibility.

Site 40RE641 is a multicomponent site containing three pieces of prehistoric lithic debitage of unknown temporal affiliation and a historic domestic dwelling dating to the late-nineteenth to early-twentieth century. Wood recommends 40RE641 be considered not eligible for the NRHP and no further archaeological work is recommended.

The McKamey and Carmichael Cemetery is a family cemetery dating to the mid-nineteenth to mid-twentieth century. The cemetery contains 22 possible grave markers and may represent a minimum of 16 graves. The earliest readable death date is Mary J. Carmichael, died Dec. 17, 1867, and the latest

TRISO-X Fuel Fabrication Facility Horizon Center Site TRISO-X, LLC April 13, 2022 3

readable headstone is Sarah Carmichael, born 1885, aged 62 years, equalling a death date of 1947. Wood recommends avoidance of the cemetery and its associated 100 ft (30.48 m) buffer. Based on the APE, the edge of the cemetery buffer is encroached upon by a distance of up to 50 ft (15.2 m). If avoidance is not possible, Wood recommends additional archaeological work that includes the use of near-surface geophysics to identify any unmarked graves within or surrounding the cemetery enclosure and associated buffer and archaeological monitoring of all proposed work within the cemetery or associated buffer.

The architectural viewshed survey identified one aboveground resource over 50 years of age within the survey area in Roane County. The resource located within the architectural survey area consists of the Silvey Cemetery dating to the mid-nineteenth to early-twentieth century. This historic resource is not eligible for listing on the NRHP.

We respectfully request your review and comment in regard to the attached report that summarizes Woods findings and NRHP recommendations resulting from our cultural resources investigations.

If you have any questions or additional concerns, please contact me at 314-520-1506 or by email at:

William.elzinga@woodplc.com.

Respectfully, William Elzinga Principal Scientist Enclosure cc. Jennifer Wheeler, TRIS-X, LLC



TENNESSEE HISTORICAL COMMISSION STATE HISTORIC PRESERVATION OFFICE 2941 LEBANON PIKE NASHVILLE, TENNESSEE 37243-0442 OFFICE: (615) 532-1550 www.tnhistoricalcommission.org April 14, 2022 Mr. William Elzinga Wood Environmental and Insfrastructure Solutions, Inc.

15933 Clayton Road, Suite 215 Ballwin, MO 63011 RE: NRC / Nuclear Regulatory Commission, TRISO-X Fuel Fabrication Facility Horizon Center Site TRISO-X, LLC, Oak Ridge, Roane County, TN

Dear Mr. Elzinga:

In response to your request, we have reviewed the cultural resources survey report and accompanying documentation submitted by you regarding the above-referenced undertaking. Our review of and comment on the proposed undertaking are among the requirements of Section 106 of the National Historic Preservation Act. This Act requires federal agencies or applicants for federal assistance to consult with the appropriate State Historic Preservation Office before they carry out their proposed undertakings. The Advisory Council on Historic Preservation has codified procedures for carrying out Section 106 review in 36 CFR 800 (Federal Register, December 12, 2000, 77698-77739).

Considering the information provided, we find that no historic properties eligible for listing in the National Register of Historic Places will be affected by this undertaking. As noted in your correspondence, the Nuclear Regulatory Commission (NRC) has not consulted with our office directly. This letter serves only to concur with the applicants proposed determinations of effect. Final formal consultation and determinations of effect will be conducted between our office and the NRC. If project plans are changed that may affect potentially eligible sites 40RE639 and/or 40RE640 or archaeological remains are discovered during project construction, please contact this office to determine what further action, if any, will be necessary to comply with Section 106 of the National Historic Preservation Act. Questions or comments may be directed to Jennifer Barnett (615) 687-4780, Jennifer.Barnett@tn.gov.

Your cooperation is appreciated.

Sincerely, E. Patrick McIntyre, Jr.

Executive Director and State Historic Preservation Officer EPM/jmb

1 Sent:

Tuesday, May 24, 2022 8:25 AM To:

Fikri, Mary Motte

Subject:

HD submittal approval CAUTION:Externalemail.Pleasedonotclickonlinks/attachmentsunlessyouknowthecontentisgenuineandsafe.

IhavereviewedaletterandsubmittaldatedFeb2,2022forHorizonLot6(WoodprojectNo.325221235).ThisHDis approvedassubmittedandthedatacontainedwithinitwillbeaddedtoourHDdatabase.

Pleasereplyorcallifyouhaveanyquestions.Thanks, SteveBrookslEnvironmentalScientist DivisionofWaterResources KnoxvilleEnvironmentalFieldOffice 3711MiddlebrookPike Knoxville,TN37921 8653649498Direct 8655946035Switchboard 8655946105Fax 8888918332TollFree Email:steven.brooks@tn.gov https://tn.gov/environment/section/wrwaterresources

Patrick McIntyre State Historic Preservation Officer Tennessee Historical Commission 2941 Lebanon Pike, Nashville, TN 37214

SUBJECT:

SECTION 106 CONSULTATION OF THE NATIONAL HISTORIC PRESERVATION ACT FOR THE TRISO-X FUEL FABRICATION FACILITY IN OAK RIDGE, TENNESSEE (DOCKET NUMBER: 70-7027)

Dear Patrick McIntyre:

The U.S. Nuclear Regulatory Commission (NRC) received an application dated April 5, 2022, and September 23, 2022, for a license to possess and use special nuclear material for the manufacture of high-assay low-enriched uranium fuel at a fuel fabrication facility (FFF) to be located in Oak Ridge, Roane County, Tennessee. Publicly available portions of the application can be accessed at: https://www.nrc.gov/info-finder/fc/triso-x.html. The application was submitted in accordance with the requirements of Part 70 of Title 10 of the Code of Federal Regulations (10 CFR) Part 70, Domestic Licensing of Special Nuclear Material. The FFF would produce tri-structural isotropic based coated particles and final fuel forms using uranium enriched to less than 20 weight percent Uranium-235. Issuance of a license enabling the possession and use of special nuclear material at the FFF would be for a first-of-its-kind fabrication operation in the United States.

As established in 10 CFR Part 51, the NRC regulation that implements the National Environmental Policy Act of 1969, as amended (NEPA), the NRC staff is preparing an environmental impact statement (EIS) for the possession and use of special nuclear material. The NRC staff will prepare an EIS to document the potential environmental impacts from the proposed action.

In accordance with Title 36 of the Code of Federal Regulations Part 800.8 (36 CFR § 800.8)

(Coordination with the National Environmental Policy Act), the NRC staff is coordinating compliance of Section 106 of the National Historic Preservation Act of 1966, as amended, (NHPA) with its NEPA review process. The EIS includes an analysis of potential impacts to historic and cultural resources.

In support of the environmental review and NHPA Section 106 consultation requirements, the NRC is requesting your concurrence on NRCs determination that no historic properties would be affected if the proposed license is issued. This determination is supported by the enclosed cultural resource report, Final Report - Phase I Cultural Resource Survey for the TRISO-X Fuel Fabrication Facility Horizon Center Site TRISO-X, LLC U.S. Nuclear Regulatory Commission (NRC) Licensing Application Project, Roane County, Tennessee. The enclosure to this letter has not been made publicly available in accordance with Section 304 of NHPA.

September 5, 2023

P. McIntyre 2

The NRC staff initiated the Section 106 process by reaching out to Tribes with current or former ties to the proposed site. The NRC contacted 15 Tribes to determine if they were interested in participating in the Section 106 consultation process. Two Tribes, the Alabama-Coushatta Tribe of Texas and the Eastern Band of Cherokee Indians of North Carolina responded stating that they were interested in consulting with the NRC. The NRC staff provided the two Tribes the enclosed historic and cultural resources report on April 3, 2023 (ML23073A201 and ML23075A278, respectively). The two consulting Tribes provided no changes or comments.

Similarly, the NRC staff evaluated if any potentially eligible historic properties are present and, if so, whether they would be affected by the undertaking. The NRC staffs determination is that no historic properties or potentially eligible historic properties would be affected by the proposed project.

The NRC staff acknowledges that if project plans change such that potentially eligible sites and/or archaeological remains are discovered during project construction potential impacts and mitigations will be reevaluated.

Please review the enclosed report and provide your concurrence or submit any comments and/or information you may have regarding this report within 30-days of receipt of this letter to Jill Caverly at Jill.Caverly@nrc.gov. If you have any questions, please contact Jill Caverly of my staff by telephone at 301-415-7674.

Thank you for your assistance.

Sincerely, Michelle Rome, Chief Environmental Review Materials Branch Division of Rulemaking, Environmental and Financial Support Office of Nuclear Material Safety and Safeguards Docket No. 70-7027

Enclosure:

Cultural Resource Report (ML22269A465)

(non-publicly available)

Signed by Rome, Michelle on 09/05/23

P. McIntyre 3

SUBJECT:

SECTION 106 CONSULTATION OF THE NATIONAL HISTORIC PRESERVATION ACT FOR THE TRISO-X FUEL FABRICATION FACILITY IN OAK RIDGE, TENNESSEE (DOCKET NUMBER: 70-7027)

DATED:

September 5, 2023 DISTRIBUTION: r/f MBartlett, DFM ADAMS Accession Number: Pkg 23223A209

• via email OFFICE NMSS/REFS NMSS/REFS NMSS/REFS NMSS/REFS NAME MMorales JCaverly AWalker-Smith MRome DATE 08/22/2023 08/30/2023 08/30/2023 09/05/2023 OFFICIAL 08/30RECORD COPY

From:

TN Help To:

Marla Morales

Subject:

[External_Sender] TRISO-X Fuel Fabrication Facility Horizon Center Site TRISO-X, LLC - Project # SHPO0003744 Date:

Monday, September 11, 2023 3:05:48 PM Attachments:

State Seal for TDEC.pngx patricksignature.pngx TENNESSEE HISTORICAL COMMISSION STATE HISTORIC PRESERVATION OFFICE 2941 LEBANON PIKE NASHVILLE, TENNESSEE 37243-0442 OFFICE: (615) 532-1550 www.tnhistoricalcommission.org

09-11-2023 14:05:07 CDT

Marla Morales Nuclear Regulatory Commission marla.morales@nrc.gov

RE: Nuclear Regulatory Commission (NRC), TRISO-X Fuel Fabrication Facility Horizon Center Site TRISO-X, LLC, Project#: SHPO0003744, Oak Ridge, Roane County, TN

Dear Marla Morales :

At your request, our office has reviewed the above-referenced cultural resources final report. This review is a requirement of Section 106 of the National Historic Preservation Act for compliance by the participating federal agency or applicant for federal assistance. Procedures for implementing Section 106 of the Act are codified at 36 CFR 800 (Federal Register, December 12, 2000, 77698-77739).

Based on the information provided, we find that the final report meets the Tennessee State Historic Preservation Office Reporting Standards and/or the Tennessee SHPO Standards and Guidelines for Archaeological Resource Management Studies.

Your continued cooperation is appreciated.

Sincerely,

E. Patrick McIntyre, Jr.

Executive Director and

State Historic Preservation Officer

Ref:MSG9913330_2GjlmYriCOZy53qUQLb1

`

September 20, 2023 Steven R. Alexander U.S. Fish and Wildlife Service South Atlantic-Gulf Interior Region Tennessee Ecological Services Field Office 446 Neal Street Cookeville, TN 38501

SUBJECT:

TRISO-X, LLC SPECIAL NUCLEAR MATERIAL LICENSE APPLICATION FOR A FUEL FABRICATION FACILITY IN OAK RIDGE, ROANE COUNTY, TENNESSEE (DOCKET NUMBER: 70-7027)

Dear Steven Alexander:

In accordance with Section 7 of the Endangered Species Act (ESA), this letter is a request to initiate informal consultation with the U.S. Fish and Wildlife Service (FWS) regarding an application for a special nuclear materials license for the manufacture of high-assay low-enriched uranium fuel at the TRISO-X Fuel Fabrication Facility (FFF), to be located at the Horizon Center Site (HCS) near 201 Renovare Boulevard, Roane County, Tennessee.

TRISO-X, LLC (TRISO-X) has applied for a license for possession and use of special nuclear fuels from the U.S. Nuclear Regulatory Commission (NRC) under Title 10 Code of Federal Regulations (10 CFR) Part 70 and, if granted, would operate the FFF. Prior to operating the facility, TRISO-X must receive a license from the NRC and must satisfy any applicable license conditions. TRISO-X intends to engage in construction activities prior to receiving a license. Such pre-licensing construction activities are permissible under NRC regulations in 10 CFR 70 0.23(a)(7) and 70.4 but would be conducted at-risk. A letter explaining this risk was sent to the applicant on July 3, 2023 (Agencywide Documents Access and Management System (ADAMS) ML23121A151).

In addition to the NRC, the U.S. Department of Energys (DOE) Office of Clean Energy Demonstrations is a signatory on this request to initiate informal consultation with the FWS because DOE has entered into a cost-sharing partnership with TRISO-X in the development of the FFF. DOEs proposed action as it relates to Section 7 consultation responsibilities include:

site development and civil works, construction of the facility, bulk chemical and gas storage infrastructure, restoration of temporary construction, installation of roadways and parking areas, landscaping, and security infrastructure.

The TRISO-X FFF would use uranium enriched to less than 20 percent to produce tri-structural isotropic based particle fuel products to support a variety of advanced nuclear reactors being considered and planned by the energy and industrial sectors, and federal government entities.

The proposed location is an approximately 110-acre parcel formerly within the DOE Oak Ridge

S. Alexander 2

Reservation that was cleared in 2011 by the Oak Ridge Industrial Development Board as part of the legacy of the lease of Parcel ED-1 by the DOE, originally to the East Tennessee Economic Council, for the purpose of developing an industrial park on certain portions of the parcel (i.e.,

what is now the HCS, also known as Development Area 6), while maintaining other, larger portions of the parcel as natural areas. Currently, the parcel consists primarily of open herbaceous vegetation with about 5 acres of mixed and evergreen forest (Enclosure 1). For precautionary safety and security reasons, construction of a facility such as this entails clearing and leveling of the entire parcel.

The NRC sent a letter to FWS, dated February 2, 2023, (ML23032A501) describing the project and requesting information and input from the FWS to identify notable environmental resources or issues of concern that should be considered in assessing the impacts of the proposed facility.

In follow-up telephone call, FWS requested that the NRC provide an analysis of the potential for effects to threatened and endangered species and additional details regarding the project.

The following threatened, endangered, or proposed endangered species with potential to occur within the action area of the project have been identified through the noted correspondence with the FWS and use of the FWS Information for Planning and Consultation (IPaC) (ADAMS ML23234A124) online tool. The summary of the staffs effects determinations is provided in the table below.

Impact Determinations Species Status Effects Determination Indiana Bat (Myotis sodalist)

Endangered may affect, not likely to adversely affect Northern Long-eared Bat (Myotis septentrionalis)

Endangered may affect, not likely to adversely affect Gray Bat (Myotis grisescens)

Endangered may affect, not likely to adversely affect Tricolored Bat (Perimyotis subflavus)

Proposed Endangered may affect, not likely to adversely affect Virginia spiraea (Spiraea virginiana)

Threatened no effect White Fringeless Orchid (Platanthera integrilabia)

Threatened no effect Spotfin Chub (Erimonax monachus)

Threatened no effect Finerayed Pigtoe (Fusconaia cuneolus)

Endangered no effect Shiny Pigtoe (Fusconaia cor)

Endangered no effect

S. Alexander 3

Based on the anticipated project impacts and life history information provided for the species above described in the enclosed report (Enclosure 2), the NRC and DOE have determined that the proposed action may affect the four proposed or listed bat species, however, these effects are expected to be discountable and therefore, have concluded that the proposed action is not likely to adversely affect any proposed or listed endangered or threatened species within the area of influence for the proposed action. The proposed action would have no effect to all other proposed, candidate or listed species or any critical habitat.

We respectfully request that the FWS provide concurrence under Section 7 of the ESA for NRC and DOEs effect determinations. Should you have any questions or comments on the submitted information, please feel free to contact the TRISO-X Environmental Project Manager, Jill Caverly at 301-415-7674 or via email at Jill.Caverly@nrc.gov.

Sincerely, Michelle Rome, Acting Chief Environmental Review Materials Branch Division of Rulemaking, Environment, and Financial Support, Office of Nuclear Material Safety and Safeguards Gretchen Applegate, NEPA Specialist Office of Clean Energy Demonstrations U.S. Department of Energy Docket No.: 70-7027

Enclosures:

1. Land Cover, Vegetation Types, and Bat Habitat in the Study Area

2. Evaluation of the Threatened and Endangered Species

Source: TRISO-X LLC

EVALUATION OF POTENTIAL EFFECTS ON THREATENED AND ENDANGERED SPECIES RELATED TO THE SPECIAL NUCLEAR MATERIALS LICENSE APPLICATION AND THE TRISO-X FUEL FABRICATION FACILITY TO BE LOCATED IN OAK RIDGE, TENNESSEE August 2023 TRISO-X, LLC (TRISO-X) applied for a license for possession and use of special nuclear fuels from the U.S. Nuclear Regulatory Commission (NRC) under Title 10 Code of Federal Regulations (CFR) Part 70 and, if granted, would operate the TRISO-X Fuel Fabrication Facility (FFF). Prior to operating the facility, TRISO-X must receive a license from the NRC and must satisfy any applicable license conditions. TRISO-X intends to engage in construction activities prior to receiving a license. Such pre-licensing construction activities are permissible under NRC regulations in 10 CFR 70 0.23(a)(7) and 70.4 but would be conducted at-risk. A letter explaining this risk was sent to the applicant on July 3, 2023. (Agencywide Documents Access and Management System ML23121A151).

The implementing regulations for section 7(a)(2) of the ESA define action area as all areas to be affected directly or indirectly by the Federal action and not merely the immediate area involved in the action (50 CFR 402.02). The action area effectively bounds the analysis of ESA-protected species and habitats because only species that occur within the action area may be affected by the Federal action.

The action area includes an approximately 110-acre parcel formerly within the Department of Energy (DOE) Oak Ridge Reservation that was cleared in 2011 by the Oak Ridge Industrial Development Board as part of the legacy of the lease of Parcel ED-1 by the DOE, originally to the East Tennessee Economic Council, for the purpose of developing an industrial park on certain portions of the parcel (i.e., what is now the Horizon Center Site (HCS), also known as Development Area 6), while maintaining other, larger portions of the parcel as natural areas.1 Currently, the parcel consists primarily of open herbaceous vegetation with about 5 acres of mixed and evergreen forest. For precautionary safety and security reasons, construction of a facility such as this entails clearing and leveling of the entire parcel. Infrastructure on the site would consist of the following features:

Process building; Administration building; Graphite Matrix Power building; Security/Emergency Operations Center building; Electrical and mechanical equipment yards; Process building exhaust stack; Roadways; Detention basin and drainage ditches; Permanent parking areas; 1 U.S. Department of Energy. 1996. Environmental Assessment. Lease of Parcel ED-1 of the Oak Ridge Reservation by the East Tennessee Economic Council. U.S. Department of Energy Oak Ridge Operations. Oak Ridge, Tennessee. April 1996. DOE/EA-1113.

U.S. Department of Energy. 2013. Implementation of Mitigation Action Plan for Parcel ED-1 on the Oak Ridge Reservation, Oak Ridge, Tennessee. Prepared by Science Applications International Corporation under subcontract 30492-BA-RR011 under work release 0014. May 2013. DOE/OR/01-2585 Final.

2 Shipping and receiving documents; Temporary construction laydown/parking; and Temporary sediment basin and drainage ditches.

The following threatened, endangered, or proposed endangered species with potential to occur within the action area of the project have been identified through the correspondence with the U.S. Fish and Wildlife Service (FWS) and use of the FWS Information for Planning and Consultation online tool (IPaC) (ADAMS M23234A124).

Species Status Indiana Bat (Myotis sodalist)

Endangered Northern Long-eared Bat (Myotis septentrionalis)

Endangered Gray Bat (Myotis grisescens)

Endangered Tricolored Bat (Perimyotis subflavus)

Proposed Endangered Virginia spiraea (Spiraea virginiana)

Threatened White Fringeless Orchid (Platanthera integrilabia)

Threatened Spotfin Chub (Erimonax monachus)

Threatened Finerayed Pigtoe (Fusconaia cuneolus)

Endangered Shiny Pigtoe (Fusconaia cor)

Endangered The NRC and DOE staffs evaluation of potential effects on threatened and endangered species and a proposed determination follows.

3 Bats Indiana Bat (Myotis sodalist)

Ecology and Habitat Indiana bats are medium-sized bats found throughout much of the eastern, southeastern, and north central United States.2 They migrate seasonally between caves, where they hibernate during winter months, and their summer range where they roost in dead, dying, or live trees with cracks, crevices, or exfoliating bark. When female Indiana bats emerge from hibernation, they migrate to maternity colonies in their summer range. The timing of annual spring emergence of Indiana bats from their hibernacula may vary depending on latitude and weather; however, literature indicates peak spring emergence of female Indiana bats occurs in mid-April and emergence of males occurs later.

Suitable summer habitat for Indiana bats consists of a wide variety of forested/wooded habitats where they roost, forage, and travel and may also include some adjacent and interspersed non-forested habitats such as emergent wetlands and adjacent edges of agricultural fields, old fields, and pastures. Indiana bats exhibit strong site fidelity to summer roosting and foraging areas.

Females form nursery colonies in a variety of habitat types, including uplands and riparian habitats. A wide variety of tree species are used as nursery colonies, indicating that it is tree form, not species that is important for roosts. Some trees are used more consistently and by a greater number of bats than other trees, and these focal or primary roosts are likely more important to the colony than alternate roosts that are used infrequently and by fewer animals.

Primary roost trees are typically located in canopy gaps in a forest, along fence lines, or within 50 feet of a forest edge. At the landscape level, Indiana bat maternity colonies occupy habitats ranging from completely forested to areas of highly fragmented forest.

Although Indiana bats are faithful to their home area, exact roosting sites must change frequently, due to the natural decay of roosts. Members of a maternity colony may use over 20 different trees during the reproductive season. The distance between trees used by a colony in the same season can range from 1 meter to as much as 8.2 kilometers.

Members of maternity colonies forage in a variety of woodland settings, including upland and floodplain forest. Foraging activity is concentrated above and around foliage surfaces, such as over the canopy in upland and riparian woods, around crowns of individual or widely spaced trees, and along forest edges. They forage less frequently over old fields, and occasionally over bushes in open pastures. Forest edges, small openings, and woodlands with patchy trees provide a better supply of insects for foraging than dense wooded areas.

2 Unless otherwise noted, the provided life history information for the Indiana bat is taken the following sources:

U.S. Fish and Wildlife Service (USFWS). 2007. Indiana Bat (Myotis sodalis) Draft Recovery Plan: First Revision. U.S.

Fish and Wildlife Service, Fort Snelling, MN. 258 pp.

Kurta, A. 2005. Roosting ecology and behavior of Indiana bats (Myotis sodalis) in summer. Pp. 29-42 in K.C. Vories and A. Harrington (eds.), Proceedings of the Indiana bat and coal mining: a technical interactive forum.

Office of Surface Mining, U.S. Department of the Interior, Alton, IL.

U.S. Fish and Wildlife Service. 2023. Range-wide Indiana Bat and Northern Long-eared Bat Survey Guidelines. U.S.

Fish and Wildlife Service, Region 3, Bloomington, MN. 76 pp.

4 There are no known Indiana Bat hibernacula in Roane County.3 Conversations with the FWS indicates the area surrounding the project site provides significant summer roosting habitat for Indiana bats. However, there are no known maternity roost trees within the vicinity of the project area.4 Environmental surveys of the project site conducted in 2021 indicated there are seven potential roost trees within the extent of the area that would be cleared during construction of the FFF.5 The identification of the trees as potential roost trees was based on the physical characteristics of the individual trees (i.e., trees and/or snags greater than three inches diameter at breast height that have exfoliating bark, cracks, crevices, and/or hollows) without specific regard to their locations within the project site. One of the seven potential roost trees is approximately 50 feet from a forest edge, as measured using aerial imagery, while the other six range between approximately 70 to 385 feet from a forest edge. TRISO-X, LLC stated in its application that clearing of potential roost trees would occur during the winter months (i.e.,

November through March) to avoid directly impacting roosting bats.

Impact Evaluation Potential impacts on Indiana bats from the proposed project could include 1) habitat loss, degradation, or fragmentation and 2) potential impacts due to behavioral changes resulting from construction activities and regular site maintenance during operations.

Potential Impacts to Habitat As noted above, potential Indiana bat habitat at the proposed project site is limited to summer habitat for roosting, foraging, or migrating. The proposed project includes removal of seven potential roost trees that would be used during the summer. The loss of multiple roost trees over a winter could affect returning bats under certain circumstances. If a number of alternate roosts, as well as a primary roost that is favored in early spring, disappeared over winter, then the bats would be without suitable shelter when they returned in spring, a period in which female bats face high energetic and nutritional demands. This could affect the returning bats due to the increased stress incurred by the bats while attempting to find new roosting sites.

However, the extent of any harmful effects depends on various factors, including number and quality of trees that are lost, severity of the weather when the bats are searching for new roosts, and the time it takes the bat to discover suitable replacement roosts. The ease of finding replacements likely is affected by the density of suitable large-sized trees within their home range and whether foraging sites also have been impacted.6 Published studies indicate Indiana 3 U.S. Fish and Wildlife Service. 2022. Indiana Bat Sites in Tennessee. August 22, 2022. Available at:

https://www.fws.gov/sites/default/files/documents/indiana_bat_8_22_22.pdf. Accessed May 24, 2023.

4 Copperhead Environmental Consulting, Inc. 2016. Indiana bat (Myotis sodalis) and Northern long-eared bat (Myotis septentrionalis) Habitat Assessment for Area 6 of the Horizon Center Industrial Park, Oak Ridge, Tennessee. Completed for: Industrial Development Board of Oak Ridge. Completed by: Steve Samoray, Copperhead Environmental Consulting, Inc. February 16, 2016.

5 Wood Environmental & Infrastructure Solutions Inc. 2022. TRISO-X Fuel Fabrication Facility Environmental Report, Ecological Resources Technical Report, Horizon Center Site. Prepared for TRISO-X, LLC. June 2022.

6 Kurta, A. 2005. Roosting ecology and behavior of Indiana bats (Myotis sodalis) in summer. Pp. 29-42 in K.C. Vories and A. Harrington (eds.), Proceedings of the Indiana bat and coal mining: a technical interactive forum.

Office of Surface Mining, U.S. Department of the Interior, Alton, IL.

5 bats can sustain the loss of multiple roosts as long as some primary roosts remain, which allow the bats to reconnect with roost mates and locate new roosts.7 The NRC and DOE staff determined that six of seven trees are located beyond 50 feet of the forest edge and, therefore, would not likely be used as primary roost trees by Indiana bats given the distance from the forest edge, The one tree spaced approximately 50 feet from the forest edge could be considered a viable primary roost tree; however, given its spacing at the farthest extent from a forest edge that typically characterizes primary roost trees, it is more likely the tree would be used as an alternative roost. Thus, if the trees are cleared in winter, and if bats were to occur within the action area in the summer, the cleared trees would be an insignificant loss of roosting trees since the forested areas surrounding the project site likely provide abundant options for higher-quality roost trees that could be readily used by returning bats.

In terms of foraging habitat, clearing of the project site and constructing the FFF would have a discountable effect to foraging habitat available to Indiana bats, given that they do not typically forage over open fields. In addition, other, higher-quality foraging habitat would be located nearby. Thus, if the trees are cleared in winter, and if bats were to occur within the action area in the summer, the cleared trees would be an insignificant loss of foraging habitat.

Potential impacts from behavioral changes In addition to impacts from habitat loss, degradation, and fragmentation, NRC and DOE analyzed potential impacts due to behavioral changes resulting from construction activities and regular site maintenance during operations. Bats can be affected through behavioral changes resulting from construction and site maintenance activities. For instance, bats could abandon previously used summer habitat due to increased noise, lighting, and other human activity during construction in a nearby area. Increased noise may also affect foraging success. Schaub et al. (2008) found that foraging success of the greater mouse-eared bat (Myotis myotis) diminished in areas with noise mimicking the traffic sounds that would be experienced within 15 m (49 ft) of a highway.8 Impacts due to the proposed construction and site maintenance of the proposed FFF such as noise, lighting, and human activity associated with construction would be temporary and located within lower-quality foraging habitat. Should the disturbances disrupt foraging or migrating bats, they could temporarily avoid the area and find higher-quality habitat nearby. The NRC and DOE staff does not believe that the construction project would result in long-term behavioral changes that would be able to be meaningfully measured, detected, or evaluated, and therefore, would be discountable.

Determination Given that there are no known maternity roosts in the project vicinity, TRISO-X would remove the seven potential roost trees during winter months during which Indiana bats would not be present because there are no known hibernacula in Roane County, the unlikelihood that the trees would be used as primary roost trees, that construction and operation of the FFF would not substantially impact available foraging habitat for Indiana bats, and that any noise 7 Silvis, A., A. B. Kniowski, S. D. Gehrt, and W. M. Ford. 2014b. Roosting and foraging social structure of the endangered Indiana bat (Myotis sodalis). PLoS ONE 9:1-12.

8 Schaub A, Ostwald J, Siemers BM. 2008. Foraging bats avoid noise. Journal of Experimental Biology 211:3174-3180.

6 disturbances would be temporary and higher quality habitat would be available nearby, the NRC and DOE determined that the proposed action may affect, but is not likely to adversely affect Indiana bats because all impacts would be discountable or insignificant.

Northern Long-Eared Bat (Myotis septentrionalis)

Ecology and Habitat The northern long-eared bat (NLEB) is a medium sized bat found throughout much of the eastern and north central United States, and all Canadian provinces from the Atlantic Ocean west to the southern Yukon Territory and eastern British Columbia.9 They migrate seasonally between caves, where they hibernate during winter months, and their summer range where they primarily roost underneath bark or in cavities or crevices of both live and dead trees.

Suitable summer habitat for NLEB consists of a wide variety of forested/wooded habitats where they roost, forage, and travel and may also include some adjacent and interspersed non-forested habitats such as emergent wetlands and adjacent edges of agricultural fields, old fields, and pastures. Wetlands and water features are important foraging and drinking water sources.

NLEB use multiple species of trees for roosts throughout their range. Forest successional patterns, structural complexity of habitat, and stand and tree structure appear to be more crucial than tree species in creating and maintaining suitable long-term roosting opportunities. NLEB often roost in dead or dying trees but living trees that contain defects that facilitate roosting are also used. Maternity roosts are typically large-diameter trees with peeling bark and/or notable defects. Compared to Indiana bats, NLEB roosts often have a higher degree of canopy cover surrounding the tree. Canopy coverage surrounding NLEB roosts generally ranges from about 50 percent to more than 80 percent.

NLEB colonies retain their identity and exhibit high site fidelity between years. NLEB females have been shown to roost together for multiple summers in the same location and individual females have been captured returning to the same small area for at least five consecutive summers. Within those areas, NLEBs switch tree roosts often. However, the rate at which they switch roosts varies based on local ambient conditions that affect the suitability of individual roosts to provide optimal thermal conditions.

Loss of roosts can also contribute to switches. NLEBs are likely adapted to roost loss because their roosts are relatively ephemeral. Consistent roost loss occurs at a low background level, with periodic pulses of increased loss after intense disturbances such as from fire, wind throw, 9 Unless otherwise noted, the provided life history information for the northern long-eared bat is taken from the following sources:

U.S. Fish and Wildlife Service. 2015. Northern Long-Eared Bat (Myotis septentrionalis) Fact Sheet. Available at:

https://www.fws.gov/sites/default/files/documents/508_NLEB%20fact%20sheet.pdf. Accessed May 24, 2023.

U.S. Fish and Wildlife Service. 2023. Standing analysis and implementation plan - Northern Long-eared bat assisted determination key. Version 1.0. March 2023. U.S. Fish and Wildlife Service. Bloomington, MN.

U.S. Fish and Wildlife Service. 2023. Range-wide Indiana Bat and Northern Long-eared Bat Survey Guidelines. U.S.

Fish and Wildlife Service, Region 3, Bloomington, MN. 76 pp.

7 ice damage, insect outbreak, or certain types of forest management actions. Published10 studies involving experimental over-winter removal of roost trees indicate Indiana bats can sustain the loss of multiple roosts as long as some primary roosts remain, which allow the bats to reconnect with roost mates and locate new roosts.

As noted, forest habitat is a key component of NLEB foraging. NLEB forage for insects in upland and lowland forests, woodlots, and tree-lined corridors. When available, NLEBs will use narrow lines of trees to move between forest patches to avoid crossing open fields and only rarely venture more than a few meters from forest when foraging.

Correspondence with the FWS indicates the area of the Oak Ridge Reservation surrounding the project site provides significant summer roosting habitat for NLEB. However, there are no known maternity roost trees within the vicinity of the project area.11 Environmental surveys of the project site conducted in 2021 indicated there are seven potential roost trees within the extents of the area that would be cleared during construction of the FFF.12 The identification of the trees as potential roost trees was based on the physical characteristics of the individual trees (i.e., trees and/or snags greater than 3 inches diameter at breast height that have exfoliating bark, cracks, crevices, and/or hollows) without specific regard to their locations within the project site.

Impact Evaluation Potential impacts to the bats from the proposed project could include 1) habitat loss, degradation, or fragmentation and 2) potential impacts due to behavioral changes resulting from construction activities and regular site maintenance during operations.

Potential Impacts to Habitat Potential NLEB habitat at the proposed project site is limited to summer habitat for roosting, foraging, or migrating. TRISO-X, LLC have stated the clearing of potential roost trees would be conducted during the winter months (i.e., November through March) to avoid directly impacting roosting bats. NRC and DOE staff determined that winter removal of the seven potential roost trees at the HCS would not cause adverse effects on NLEB. NLEB are adapted to ephemeral roosts. Though some extent of roost removal could interfere with maternity colony cohesion and affect NLEB, tree removal significant enough to fragment a colony, and affect roosting bats, would require an event resembling the periodic pulses of increased roost loss after intense disturbances such as fire or timber harvest. According to the FWS March 2023 NLEB Assisted Determination Key, for winter tree removal to cause adverse effects on NLEBs due to maternity colony fragmentation, each of the following would have to occur:

10 Silvis, A., W. M. Ford, and E. R. Britzke. 2015. Effects of hierarchical roost removal on northern long-eared bat (Myotis septentrionalis) maternity colonies. PLoS ONE 10:e0116356.

Silvis, A., W. M. Ford, E. R. Britzke, and J. B. Johnson. 2014a. Association, roost use and simulated disruption of Myotis septentrionalis maternity colonies. Behavioural Processes 103:283-290.

11 Copperhead Environmental Consulting, Inc. 2016. Indiana bat (Myotis sodalis) and Northern long-eared bat (Myotis septentrionalis) Habitat Assessment for Area 6 of the Horizon Center Industrial Park, Oak Ridge, Tennessee. Completed for: Industrial Development Board of Oak Ridge. Completed by: Steve Samoray, Copperhead Environmental Consulting, Inc. February 16, 2016.

12 Wood Environmental & Infrastructure Solutions Inc. 2022. TRISO-X Fuel Fabrication Facility Environmental Report, Ecological Resources Technical Report, Horizon Center Site. Prepared for TRISO-X, LLC. June 2022.

8

1) the tree removal would have to overlap with a NLEB maternity colony - tree removal would have to take place in an area where NLEBs are likely to return in the spring to reoccupy a colony area or to form new roosts - i.e., in an area likely to be occupied by the NLEB; and,

2) enough roosts would have to be removed to cause colony fragmentation - the extent and intensity of roost removal must cause an increase in roost loss above the low constant background level of the affected area, to a degree that a colony is likely to fragment.

As noted above, the potential impacted habitat is limited to seven potential roost trees that would be cleared during construction of the FFF and are within the otherwise open habitat of the cleared HCS. The trees range in distance from forest habitat from approximately 50 feet to 385 feet. Although these trees are considered suitable habitat for NLEB, based on the characterization of typical NLEB roost trees (i.e., found among or within 1,000 feet of forested habitat with canopy cover of 50 to upwards of 80 percent), it is unlikely they are primary maternal roost trees, the loss of which would result in fragmentation of a colony. As noted, there are no known NLEB maternity roost trees within the vicinity of the project area and maternity roost trees are typically trees surrounded by a higher degree of canopy than the trees that would be removed (i.e., it is more likely the removed trees would be non-maternity roost trees).

The FWS notes the likelihood that any 10-acre tree clearing project would overlap with an area to which a previously undocumented NLEB colony is likely to return in the spring to use a maternity colony is low.13 Accordingly, NRC and DOE staff determined that the likelihood that removal of seven trees in an open field would include a maternity roost would be significantly lower still. Secondly, the removal of seven potential roost trees is unlikely to cause colony fragmentation. Literature indicates roost loss surpassing the low constant background level of natural tree loss would require the loss of upwards of 20 percent of the potential roost trees across the range of a colony.14 Given the extensive forested area surrounding the HCS that has been determined to be potential NLEB summer habitat by the FWS, the likelihood of the seven trees that would be removed comprising more than 20 percent of available roost trees in the area is also low.

Likewise, NRC and DOE staff determined clearing of the project site and constructing the FFF would have a discountable effect to foraging habitat available to NLEB given their propensity to remain within or very close to forested habitat when foraging. In addition, other, higher-quality foraging habitat is be located nearby. Therefore, if NLEB were to occur within the action area in the summer, the development of the HCS would be an insignificant loss of foraging habitat.

Potential impacts from behavioral changes Similar to the Indiana bat, NLEB can be affected through behavioral changes resulting from construction and site maintenance activities. Effects such as noise, lighting, and human activity associated with construction would be temporary and located within lower-quality foraging habitat. Should the disturbances bother foraging or migrating bats, they could temporarily avoid the area and find higher-quality habitat nearby. The NRC and DOE staff does not believe that 13 U.S. Fish and Wildlife Service. 2023. Standing analysis and implementation plan - Northern Long-eared bat assisted determination key. Version 1.0. March 2023. U.S. Fish and Wildlife Service. Bloomington, MN.

14 Silvis, A., W. M. Ford, and E. R. Britzke. 2015. Effects of Hierarchical Roost Removal on Northern Long-Eared Bat (Myotis septentrionalis) Maternity Colonies. PLOS ONE 10:e0116356.

Silvis, A., W. M. Ford, E. R. Britzke, and J. B. Johnson. 2014. Association, roost use and simulated disruption of Myotis septentrionalis maternity colonies. Behavioural Processes. 103:283-290.

9 the construction project would result in long-term behavioral changes that would be able to be meaningfully measured, detected, or evaluated, and therefore, would be discountable.

Determination The NRC and DOE staff determined that with TRISO-Xs commitment to remove the seven potential roost trees during winter months, during which time NLEB would not be present; and the additional prevalence of significant summer roosting habitat in the forested areas surrounding the site, as determined by the FWS, the construction and operation of the FFF would not substantially impact available foraging habitat for NLEB. Therefore, the NRC and DOE determined that the proposed action may affect but is not likely to adversely affect the NLEB.

Gray Bat (Myotis grisescens)

Ecology and Habitat The gray bat is a medium-sized insectivorous bat found across a limited geographic range in limestone karst areas of the southeastern United States.15 Hibernating populations are concentrated in caves across northern Alabama and Arkansas, Kentucky, Missouri, and Tennessee. Their summer range extends from southwestern Virginia, western North Carolina, and northwestern Georgia, across southern Illinois and Indiana to as far west as eastern Oklahoma and very southeastern Kansas. Gray bats are one of the few species of bats in North America that inhabit caves year-round, occupying cold hibernating caves or mines in the winter and warmer caves during summer.

Foraging by gray bats during summer is strongly correlated with open water of rivers, streams, lakes, or reservoirs. Gray bats are highly dependent on aquatic insects, especially mayflies, caddisflies, and stoneflies, though they will also opportunistically consume beetles and moths.

Most maternity colonies are located between 1 to 4 kilometers from foraging locations.

Impact Evaluation Potential impacts to the bats from the proposed project could include 1) habitat loss, degradation, or fragmentation and 2) potential impacts due to behavioral changes resulting from construction activities and regular site maintenance during operations.

Potential Impacts to Habitat In conversations with the NRC, FWS noted the general project area contains significant karst features that support gray bats. However, although environmental surveys of the project site conducted in 2021 and 2022 found several karst sinkholes within and in the vicinity of the HCS, none contained aboveground openings to crevices or caves suitable for hibernating or roosting 15 Unless otherwise noted, life history information for gray bats is taken from the following source:

U.S. Fish and Wildlife Service. 2009. Gray Bat (Myotis grisescens) 5-Year Review: Summary and Evaluation. U.S. Fish and Wildlife Service Midwest Region. Columbia, Missouri Ecological Services Field Office Columbia, Missouri.

10 bats.16 Construction and operation of the FFF would be unlikely to have substantial adverse effects on grey bat foraging habitat given the lack of any open water or cave access withing the immediate area.

Potential Impacts from Behavioral Changes Similar to the other bat species identified above, the gray bat can be affected through behavioral changes resulting from construction and site maintenance activities. Effects such as noise, lighting, and human activity associated with construction would be temporary and and would not affect foraging habitat. Should the disturbances bother migrating bats, they could temporarily avoid the area and find higher-quality habitat nearby. The NRC and DOE staff does not believe that the construction project would result in long-term behavioral changes that would be able to be meaningfully measured, detected, or evaluated, and therefore, would be discountable.

Determination Given there are no winter hibernacula, summer roosting caves, or open waters within the project site and the lack of gray bat foraging habitat in the vicinity of the proposed project location that would be directly affected by construction and operation of the FFF, the NRC and DOE determined that the proposed action may affect but is not likely to adversely affect gray bats.

Tricolored Bat (Perimyotis subflavus)

Ecology and Habitat The tricolored bat is a small bat found across the eastern and central United States and portions of southern Canada, Mexico and Central America.17 They are the most common bat in Tennessee and are found throughout the state. Tricolored bats in Tennessee are part of the Northern Representation Unit (RPU) of tricolored bats. Northern tricolored bats hibernate in caves and mines during winter months (whereas tricolored bats in the Southern RPU often hibernate in road-associated culverts, tree cavities, and abandoned water wells). They typically emerge from hibernation between April and May.

Suitable summer habitat for tricolored bats consists of a wide variety of forested/wooded habitats, where they roost, forage, and travel, and may include some adjacent and interspersed non-forested habitats such as emergent wetlands and adjacent edges of agricultural fields, and old fields and pastures, as well as linear features such as fencerows, riparian forests, and other wooded corridors. Tricolored bats primarily roost in forested habitat among leaf clusters of live or recently dead deciduous hardwood trees. Tricolored bats have also been documented roosting among pine needles, eastern red cedar, within artificial roosts (i.e., human-constructed 16 Wood Environmental & Infrastructure Solutions Inc. 2022. TRISO-X Fuel Fabrication Facility Environmental Report, Ecological Resources Technical Report, Horizon Center Site. Prepared for TRISO-X, LLC. June 2022.

17 Unless otherwise noted, life history information for tricolored bats is taken from the following source:

U.S. Fish and Wildlife Service. 2021. Species Status Assessment Report for the Tricolored Bat (Perimyotis subflavus), Version 1.1. December 2021. Hadley, MA.

U.S. Fish and Wildlife Service. 2023. Range-wide Indiana Bat and Northern Long-eared Bat Survey Guidelines. U.S.

Fish and Wildlife Service, Region 3, Bloomington, MN. 76 pp.

11 structures), and, rarely, within caves. They are known to successfully roost and forage in forested areas near anthropogenic structures and buildings.

When roosting in trees, they often select roosts in tall, large diameter trees. However, they will roost in smaller diameter trees when potential roost substrate is present. Tricolored bats commonly roost in the mid to upper canopy of the trees, although males will occasionally roost in dead leaves at lower heights and females will occasionally roost in Spanish moss of understory trees in states where the epiphyte is present.

As with Indiana bats and NLEB, tricolored bats form maternity colonies to which they exhibit high site fidelity, returning year after year to the same summer roosting locations. Likewise, though they return to the same general locations, female tri-colored bats switch roost trees regularly (e.g., between 1.2 and 7 days at roost trees in Indiana) throughout the summer.

Tricolored bats primarily forage along forested edges of larger forest openings, along edges of riparian areas, and over water. They avoid foraging in dense, unbroken forests, and narrow road cuts through forests. They are opportunistic feeders of small insects including caddisflies (Trichoptera), flying moths (Lepidoptera), small beetles (Coleoptera), small wasps and flying ants (Hymenoptera), true bugs (Homoptera), and flies (Diptera).

Impact Evaluation Potential impacts to the bats from the proposed project could include 1) habitat loss, degradation, or fragmentation and 2) potential impacts due to behavioral changes resulting from construction activities and regular site maintenance during operations.

Potential Impacts to Habitat Historical survey efforts have confirmed presence of tricolored bats within the extents of the Oak Ridge Reservation.18 The bat habitat surveys conducted at the HCS in 2021 focused on trees more specifically suited as roosts for Indiana bats and NLEB (i.e., live trees and/or snags greater than 3 inches diameter at breast height with exfoliating bark, cracks, crevices, and/or hollows).19 The approximately 5 acres of mixed deciduous and evergreen forest habitat could potentially contain suitable roosting trees for tricolored bats as described above. However, there are no known maternity roost trees within the vicinity of the project area and the extensive forest habitat surrounding the HCS would offset the loss of the forested habitat within the project site.

20 The FWS Species Status Assessment Report for the Tricolored Bat discusses impacts on tricolored bats resulting from loss of habitat. Within the report, it characterizes removal of a small portion of foraging habitat in a largely forested landscape with robust tricolored bat 18 McCracken et al. 2015. McCracken, M.K., N.R. Giffen, A.M. Haines, and J.W. Evans, Bat Species Distribution on the Oak Ridge Reservation. ORNL/TM-2015/248, Oak Ridge National Laboratory, Oak Ridge, Tennessee.

19 Wood Environmental & Infrastructure Solutions Inc. 2022. TRISO-X Fuel Fabrication Facility Environmental Report, Ecological Resources Technical Report, Horizon Center Site. Prepared for TRISO-X, LLC. June 2022.

20 Copperhead Environmental Consulting, Inc. 2016. Indiana bat (Myotis sodalis) and Northern long-eared bat (Myotis septentrionalis) Habitat Assessment for Area 6 of the Horizon Center Industrial Park, Oak Ridge, Tennessee. Completed for: Industrial Development Board of Oak Ridge. Completed by: Steve Samoray, Copperhead Environmental Consulting, Inc. February 16, 2016.

12 populations as a minor impact. The document further states that adverse impacts are more likely in areas with little forest or highly fragmented forests (e.g., western U.S. and central Midwestern states), as there is a higher probability of removing roosts or causing loss of connectivity between roosting and foraging habitat.21 The NRC and DOE characterize the currently proposed clearing of the HCS site as being in line with the former scenario.

Potential Impacts from Behavioral Changes Similar to the other bat species identified above, the tricolored bat can be affected through behavioral changes resulting from construction and site maintenance activities. Impacts such as noise, lighting, and human activity associated with construction would be temporary and located within lower-quality foraging habitat. Should the disturbances bother foraging or migrating bats, they could temporarily avoid the area and find higher-quality habitat nearby. The NRC and DOE staff does not believe that the construction project would result in long-term behavioral changes that would be able to be meaningfully measured, detected, or evaluated, and therefore, would be discountable.

Determination Given that TRISO-X would clear individual trees and forested habitat within the project site during winter months when bats would not be present (i.e., November through March) and the open field, individual trees, and forest habitat within the project site does not match the description of typical tricolored bat foraging habitat (i.e., forested edges of larger forest openings, edges of riparian areas, and over water), the NRC and DOE staff concludes direct impacts on tricolored bats and bat foraging habitat resulting from construction and operation of the project would be minor. Further, noise, lighting, and human activity disturbances associated with construction of the FFF would be temporary and higher quality habitat would be available nearby. Therefore, all impacts on tri-colored bats would be discountable or insignificant and the NRC and DOE staff determine that the proposed action may affect, but is not likely to adversely affect tricolored bats.

Flowering Plants Virginia Spiraea (Spiraea virginiana)

The Virginia spiraea is a Southern Appalachian species found in the Appalachian Plateau or the southern Blue Ridge Mountains in Alabama, Ohio, West Virginia, Virginia, Tennessee, North Carolina, Kentucky, and Georgia. Virginia spiraea life history requirements are strongly tied to high gradient streams on larger creeks and rivers. It primarily occurs along scoured banks of second and third order streams, or on meander scrolls, point bars, natural levees, and other braided features of lower reaches of streams. Given the project area does not contain waterbodies of any sort, the NRC and DOE determined that the proposed action would have no effect on the Virginia spiraea.

21 U.S. Fish and Wildlife Service. 2021. Species Status Assessment Report for the Tricolored Bat (Perimyotis subflavus), Version 1.1. December 2021. Hadley, MA.

13 White Fringeless Orchid (Platanthera integrilabia)

The white fringeless orchid is a perennial herb that currently occurs in Alabama, Georgia, Kentucky, Mississippi, South Carolina, and Tennessee. White fringeless orchid habitat has historically been described as partially shaded areas with sandy and acidic soils in wet areas like seeps, bogs, or swamps but it may also occur in areas with differing light and moisture availability. However, the species is commonly associated with sphagnum moss (Sphagnum spp), an acidophilic species of moss often found in bogs, and often occurs in wooded wetland areas dominated by red maple, white oak, and black gum. Environmental surveys conducted during the summer and fall of 2021 and the spring of 2022 did not find presence or suitable habitat for the white fringeless orchid within the project site.22 Given the lack of suitable habitat present at the project site, the NRC and DOE determined that the proposed action t would have no effect on the white fringeless orchid.

Aquatic Species Spotfin Chub (Erimonax monachus)

The spotfin chub is a ray-finned fish that occurs in the Holston River drainage (Virginia and northeastern Tennessee), Emory River drainage (lower Clinch River Tennessee), and the Little Tennessee River drainage (North Carolina and Tennessee). The species is thought to be selective of boulder and bedrock substrates in medium to high velocity flows and medium depths (typical of runs). Given the project area does not contain waterbodies of any sort, the NRC and DOE determined that the proposed action would have no effect on the spotfin chub.

Finerayed Pigtoe (Fusconaia cuneolus), Shiny Pigtoe (Fusconaia cor)

The finerayed pigtoe and shiny pigtoe are freshwater mussels found only in the middle and upper Tennessee River system in relatively silt-free substrates of sand, gravel, and cobble in good flows of smaller streams. They occur in shallow shoals as well as deeper runs in Clinch River. Given the project area does not contain waterbodies of any sort, the NRC determined that the proposed action would have no effect on the finerayed pigtoe and shiny pigtoe.

Indirect Effects Indirect effects are those that are caused by the proposed action that are later in time, but are still reasonably certain to occur (50 CFR 402.02). The NRC and DOE did not identify any indirect effects associated with the proposed action.

Interrelated and Interdependent Effects Interrelated actions are those actions that are part of a larger action and depend on the larger action for their justification (50 CFR 402.02). Interdependent actions are those actions having no independent utility apart from the proposed action (50 CFR 402.02). The NRC and DOE staff has not identified any information that would constitute interrelated or interdependent actions and that might affect the bats.

22 Wood Environmental & Infrastructure Solutions Inc. 2022. TRISO-X Fuel Fabrication Facility Environmental Report, Ecological Resources Technical Report, Horizon Center Site. Prepared for TRISO-X, LLC. June 2022.

14 Cumulative Effects Cumulative effects are those effects of future State or private activities, not involving Federal activities, that are reasonably certain to occur within the action area of the Federal action subject to consultation (50 CFR 402.02). The NRC and DOE did not identify any cumulative effects within the action area.

United States Department of the Interior FISH AND WILDLIFE SERVICE Tennessee ES Office 446 Neal Street Cookeville, Tennessee 38501 October 12, 2023 Jill S. Caverly, Senior Project Manager US Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

FWS #2022-0019326: NRC Triso-X Facility, Horizon Center, Roane County, Tennessee

Dear Ms. Caverly:

Thank you for your letter transmitting the Department of Energy/Nuclear Regulatory Commission Evaluation of Potential Effects on Threatened and Endangered Species, received via e-mail on September 22, 2023, of the proposed construction and operation of the Triso-X nuclear fuel fabrication facility in Roane County, Tennessee. The Evaluation assessed the direct, indirect and cumulative effects of this project on federally listed species and their habitats within the action area of the Horizon Center. U.S. Fish and Wildlife Service (Service) personnel have reviewed the information submitted and we offer the following comments.

DOE made may affect, not likely to adversely affect determinations for the federally endangered Indiana bat (Myotis sodalis), northern long-eared bat (Myotis septentrionalis), gray bat (Myotis grisescens) and the proposed endangered tricolored bat (Perimyotis subflavus). Based on your assessment, the Service concurs with DOEs determinations that the proposed project is "not likely to adversely affect" federally listed species.

We believe that the requirements of section 7 of the Endangered Species Act of 1973, as amended, are fulfilled. Obligations under the Act must be reconsidered if (1) new information reveals impacts of the proposed action that may affect listed species or critical habitat in a manner not previously considered, (2) the proposed action is subsequently modified to include activities which were not considered during this consultation, or (3) new species are listed or critical habitat designated that might be affected by the proposed action.

We recommend, however, that potential effects from temporary or permanent artificial lighting of the facility within 1,000 feet of suitable northern long-eared bat habitat be minimized using the following

measures during construction and operation of the Triso-X facility:

1. The use of downward-facing, full cut-off lens lights (with same intensity or less for replacement lighting) when installing new or replacing existing permanent lights; or

2. If using the Backlight, Uplight, Glare (BUG) system developed by the Illuminating Engineering Society, will all three ratings (backlight, uplight, and glare) be as close to zero as is possible, with a priority of "uplight" of 0.

These constitute the comments of the Service, submitted in accordance with provisions of the Endangered Species Act (87 Stat. 884, as amended: 16 U.S.C. 1531 et seq.). Thank you for working collaboratively with the Service on this action. If you have any questions, please contact Steve Alexander at 931/525-4980 or at steven_alexander@fws.gov.

Sincerely, Nicole Sikula Acting Field Supervisor

DEPARTMENT OF THE ARMY NASHVILLE DISTRICT, CORPS OF ENGINEERS REGULATORY DIVISION 3701 BELL ROAD NASHVILLE, TENNESSEE 37214 March 15, 2023

SUBJECT:

LRN-2013-00515, Horizon Center Site, Lot 6, Oak Ridge, Roane County, TN Jennifer Wheeler, P.E.

X Energy, LLC/ TRISO-X, LLC.

400 Centrifuge Way Oak Ridge, TN 37830

Dear Ms. Wheeler:

This letter is in regard to your report entitled Request for Jurisdictional Determination, Dated February 2, 2022, which documented potential waters of the United States on a review area of approximately 150 acres. The JD report, associated with the Horizon Center Site, Lot 6 in Oak Ridge, Roane County, Tennessee, indicated your preference for potential waters of the U.S. on the review area to be reviewed as a preliminary jurisdictional determination (PJD). This project has been assigned File No.

LRN-2013-00515, please refer to this number in any future correspondence.

The U.S. Army Corps of Engineers (USACE) has regulatory responsibilities pursuant to Section 404 of the Clean Water Act (33 U.S.C. 1344) and Section 10 of the Rivers and Harbors Act of 1899 (33 U.S.C. 403). Under Section 10, the USACE regulates any work in, or affecting, navigable waters of the U.S. It appears the review area does not include navigable waters of the U.S. and would not be subject to the provisions of Section 10. Under Section 404, the USACE regulates the discharge of dredged and/or fill material into waters of the U.S., including wetlands.

Based on a desktop review of the area on March 15, 2023, two reaches of intermittent stream totaling 1,678 linear feet, and one reach of ephemeral stream totaling 695 linear feet were documented within the review area. This office has determined these features may be jurisdictional waters of the U.S. in accordance with 33 C.F.R. 331.2 and a PJD has been prepared. The PJD is non-binding, cannot be appealed and only provides a written indication that waters of the U.S, including wetlands, may be present on-site. For purposes of computation of impacts, compensatory mitigation requirements and other resource protection measures, a permit decision made on the basis of a PJD will treat all waters that would be affected in any way by the permitted activity on the site as if they are jurisdictional waters of the U.S. If you wish, you may request an approved JD (which may be appealed), by contacting this office. Also, you may provide new information for further consideration by

the USACE to re-evaluate the PJD. This determination is only valid for the review area shown on the attached map entitled LRN-2013-00515, Figure 1, attached to this letter.

Enclosed with this letter is a copy of the PJD. If you agree with the findings of this PJD and understand your options regarding the same, please sign and date the form and return it to this office within 30 days of receipt of this letter. You should submit the signed copy to the following address:

U.S. Army Corps of Engineers Nashville District 501 Adesa Blvd, Suite B250.

Lenoir City, TN 37771 Attn: Brent Sewell Please contact this office if you would like to schedule a pre-application meeting to further discuss alternatives for site development to assist you in avoiding and minimizing impacts to waters of the United States. If your development plan requires the discharge of material into waters of the U.S., a Department of the Army Permit would be required.

The delineation included herein has been conducted to identify the location and extent of the aquatic resource boundaries and/or the jurisdictional status of aquatic resources for purposes of the Clean Water Act for the particular site identified in this request. This delineation and/or jurisdictional determination may not be valid for the Wetland Conservation Provisions of the Food Security Act of 1985, as amended. If you or your tenant are USDA program participants, or anticipate participation in USDA programs, you should discuss the applicability of a certified wetland determination with the local USDA service center, prior to starting work.

We appreciate your awareness of the USACE regulatory program. If you have any questions, you may contact me or Brent Sewell at (615) 417-0240 or by e-mail at Brent.j.sewell@usace.army.mil.

Sincerely, Casey H Ehorn Chief, East Branch Regulatory Division Enclosures Electronic Copies Furnished:

Mary Motte Fikri (Wood Environment & Infrastructure Solutions, Inc)

)RU

RGL 16 Appendix 2 - PRELIMINARY JURISDICTIONAL DETERMINATION (PJD) FORM ATTACHMENT PRELIMINARY JURISDICTIONAL DETERMINATION (PJD) FORM BACKGROUND INFORMATION A. REPORT COMPLETION DATE FOR (PJD): 3/15/2023 B.

NAME AND ADDRESS OF PERSON REQUESTING PRELIMINARY JD:

Jennifer Wheeler, P.E.

X Energy, LLC/ TRISO-X, LLC.

400 Centrifuge Way Oak Ridge, TN 37830 C. DISTRICT OFFICE, FILE NAME, AND NUMBER:

Nashville District Horizon Center Site, Lot 6 LRN-2013-00515 D. PROJECT LOCATION(S) AND BACKGROUND INFORMATION:

(USE THE ATTACHED TABLE TO DOCUMENT MULTIPLE AQUATIC RESOURCES AND/OR AQUATIC RESOURCES AT DIFFERENT SITES)

State: TN County/parish/borough: Roane City: Oak Ridge Center coordinates of site (lat/long in degree decimal format):

Lat. 35.961425° N, Long. -84.3703796 ° W.

Universal Transverse Mercator:

Name of nearest waterbody: East Fork Poplar Creek Identify (estimate) amount of waters in the review area:

Non-wetland waters:

695 linear feet of Ephemeral Stream 1,678 linear feet of Intermittent Stream 0 linear feet of Perennial Stream Wetlands: 0.0 acres Open Waters 0 acres E.

REVIEW PERFORMED FOR SITE EVALUATION (CHECK ALL THAT APPLY):

Office (Desk) Determination. Date: March 15, 2023 Field Determination. Date(s):

RGL 16 Appendix 2 - PRELIMINARY JURISDICTIONAL DETERMINATION (PJD) FORM TABLE OF AQUATIC RESOURCES IN REVIEW AREA WHICH MAY BE SUBJECT TO REGULATORY JURISDICTION.

Site number Latitude (decimal degrees)

Longitude (decimal degrees)

Estimated amount of aquatic resource in review area (acreage and linear feet, if applicable)

Type of aquatic resource (i.e.,

wetland vs.

non-wetland waters)

Geographic authority to which the aquatic resource may be subject (i.e.,

Section 404 or Section 10/404)

Channel 1a/1b 35.9657

-84.3671 1,424 ft

Riverine, Intermittent Section 404 Channel 2a 35.9652

-84.3669 254 ft

Riverine, Intermittent Section 404 Channel 2b 35.9652

-84.3689 695 ft

Riverine, Ephemeral Section 404

1. The Corps of Engineers believes that there may be jurisdictional aquatic resources in the review area, and the requestor of this PJD is hereby advised of his or her option to request and obtain an approved JD (AJD) for that review area based on an informed decision after having discussed the various types of JDs and their characteristics and circumstances when they may be appropriate.

2. In any circumstance where a permit applicant obtains an individual permit, or a Nationwide General Permit (NWP) or other general permit verification requiring pre-construction notification (PCN), or requests verification for a non-reporting NWP or other general permit, and the permit applicant has not requested an AJD for the activity, the permit applicant is hereby made aware that: (1) the permit applicant has elected to seek a permit authorization based on a PJD, which does not make an official determination of jurisdictional aquatic resources; (2) the applicant has the option to request an AJD before accepting the terms and conditions of the permit authorization, and that basing a permit authorization on an AJD could possibly result in less compensatory mitigation being required or different special conditions; (3) the applicant has the right to request an individual permit rather than accepting the terms and conditions of the NWP or other general permit authorization; (4) the applicant can accept a permit authorization and thereby agree to comply with all the terms and conditions of that permit, including whatever mitigation requirements the Corps has determined to be necessary; (5) undertaking any activity in reliance upon the subject permit authorization without requesting an AJD constitutes the applicants acceptance of the use of the PJD; (6) accepting a permit authorization (e.g., signing a proffered individual permit) or undertaking any activity in reliance on any form of Corps permit authorization based on a PJD constitutes agreement that all aquatic resources in the review area affected in any way by that activity will be treated as jurisdictional, and waives any challenge to such jurisdiction in any administrative or judicial compliance or enforcement action, or in any administrative appeal or in any Federal court; and (7)whether the applicant elects to use either an AJD or a PJD, the JD will be processed as soon as practicable. Further, an

RGL 16 Appendix 2 - PRELIMINARY JURISDICTIONAL DETERMINATION (PJD) FORM AJD, a proffered individual permit (and all terms and conditions contained therein), or individual permit denial can be administratively appealed pursuant to 33 C.F.R. Part 331.

If, during an administrative appeal, it becomes appropriate to make an official determination whether geographic jurisdiction exists over aquatic resources in the review area, or to provide an official delineation of jurisdictional aquatic resources in the review area, the Corps will provide an AJD to accomplish that result, as soon as is practicable.

This PJD finds that there may be waters of the U.S. and/or that there may be navigable waters of the U.S. on the subject review area, and identifies all aquatic features in the review area that could be affected by the proposed activity, based on the following information:

RGL 16 Appendix 2 - PRELIMINARY JURISDICTIONAL DETERMINATION (PJD) FORM SUPPORTING DATA. Data reviewed for preliminary JD (check all that apply -

checked items should be included in case file and, where checked and requested, appropriately reference sources below):

Maps, plans, plots or plat submitted by or on behalf of the applicant/consultant:

Map: From Horizon Center, Lot 6 JD request, Dated February 2, 2022.

Data sheets prepared/submitted by or on behalf of the applicant/consultant.

Office concurs with data sheets/delineation report.

Office does not concur with data sheets/delineation report. Rationale:

Data sheets prepared by the Corps:

Corps navigable waters study:

U.S. Geological Survey Hydrologic Atlas :

USGS NHD data.

USGS 8 and 12 digit HUC maps.

U.S. Geological Survey map(s). Cite scale & quad name: Custom, From Horizon Center, Lot 6 JD request, Dated February 2, 2022.

Natural Resources Conservation Service Soil Survey. Citation: From Horizon Center, Lot 6 JD request, Dated February 2, 2022.

National wetlands inventory map(s). Cite name: From Horizon Center, Lot 6 JD request, Dated February 2, 2022.

State/Local wetland inventory map(s):

FEMA/FIRM maps:

100-year Floodplain Elevation is:

(National Geodectic Vertical Datum of 1929)

Photographs:

Aerial (Name & Date):

or Other (Name & Date):

Previous determination(s). File no. and date of response letter: LRN-2013-00515, Dated April 8, 2013 Other information (please specify):

IMPORTANT NOTE: The information recorded on this form has not necessarily been verified by the Corps and should not be relied upon for later jurisdictional determinations.

Signature and date of Signature and date of Project Manager person requesting preliminary JD (REQUIRED)

(REQUIRED, unless obtaining the signature is impracticable)1 1 Districts may establish timeframes for requestor to return signed PJD forms. If the requestor does not respond within the established time frame, the district may presume concurrence and no additional follow up is necessary prior to finalizing an action. For the Nashville District, concurrence is presumed after 30 days.

3/16/2023 Signature and date of



  
 

   




 

 

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()*+,-./0-1)2-34-5(-34+,-6738 LRN-2013-00515, Figure 1 PJD Review Area

NOTIFICATION OF ADMINISTRATIVE APPEAL OPTIONS AND PROCESS AND REQUEST FOR APPEAL Applicant: Jennifer Wheeler, P.E.

File Number: LRN-2013-00515 Date: March 16, 2023 Attached is:

See Section below INITIAL PROFFERED PERMIT (Standard Permit or Letter of permission)

A PROFFERED PERMIT (Standard Permit or Letter of permission)

B PERMIT DENIAL C

APPROVED JURISDICTIONAL DETERMINATION D

X PRELIMINARY JURISDICTIONAL DETERMINATION E

SECTION I - The following identifies your rights and options regarding an administrative appeal of the above decision. Additional information may be found at http://www.usace.army.mil/CECW/Pages/reg_materials.aspx or Corps regulations at 33 CFR Part 331.

A: INITIAL PROFFERED PERMIT: You may accept or object to the permit.

ACCEPT: If you received a Standard Permit, you may sign the permit document and return it to the district engineer for final authorization. If you received a Letter of Permission (LOP), you may accept the LOP and your work is authorized. Your signature on the Standard Permit or acceptance of the LOP means that you accept the permit in its entirety, and waive all rights to appeal the permit, including its terms and conditions, and approved jurisdictional determinations associated with the permit.

OBJECT: If you object to the permit (Standard or LOP) because of certain terms and conditions therein, you may request that the permit be modified accordingly. You must complete Section II of this form and return the form to the district engineer.

Your objections must be received by the district engineer within 60 days of the date of this notice, or you will forfeit your right to appeal the permit in the future. Upon receipt of your letter, the district engineer will evaluate your objections and may: (a) modify the permit to address all of your concerns, (b) modify the permit to address some of your objections, or (c) not modify the permit having determined that the permit should be issued as previously written. After evaluating your objections, the district engineer will send you a proffered permit for your reconsideration, as indicated in Section B below.

B: PROFFERED PERMIT: You may accept or appeal the permit ACCEPT: If you received a Standard Permit, you may sign the permit document and return it to the district engineer for final authorization. If you received a Letter of Permission (LOP), you may accept the LOP and your work is authorized. Your signature on the Standard Permit or acceptance of the LOP means that you accept the permit in its entirety, and waive all rights to appeal the permit, including its terms and conditions, and approved jurisdictional determinations associated with the permit.

APPEAL: If you choose to decline the proffered permit (Standard or LOP) because of certain terms and conditions therein, you may appeal the declined permit under the Corps of Engineers Administrative Appeal Process by completing Section II of this form and sending the form to the division engineer. This form must be received by the division engineer within 60 days of the date of this notice.

C: PERMIT DENIAL: You may appeal the denial of a permit under the Corps of Engineers Administrative Appeal Process by completing Section II of this form and sending the form to the division engineer. This form must be received by the division engineer within 60 days of the date of this notice.

D: APPROVED JURISDICTIONAL DETERMINATION: You may accept or appeal the approved JD or provide new information.

ACCEPT: You do not need to notify the Corps to accept an approved JD. Failure to notify the Corps within 60 days of the date of this notice, means that you accept the approved JD in its entirety, and waive all rights to appeal the approved JD.

APPEAL: If you disagree with the approved JD, you may appeal the approved JD under the Corps of Engineers Administrative Appeal Process by completing Section II of this form and sending the form to the division engineer. This form must be received by the division engineer within 60 days of the date of this notice.

E: PRELIMINARY JURISDICTIONAL DETERMINATION: You do not need to respond to the Corps regarding the preliminary JD. The Preliminary JD is not appealable. If you wish, you may request an approved JD (which may be appealed), by contacting the Corps district for further instruction. Also you may provide new information for further consideration by the Corps to reevaluate the JD.

SECTION II - REQUEST FOR APPEAL or OBJECTIONS TO AN INITIAL PROFFERED PERMIT REASONS FOR APPEAL OR OBJECTIONS: (Describe your reasons for appealing the decision or your objections to an initial proffered permit in clear concise statements. You may attach additional information to this form to clarify where your reasons or objections are addressed in the administrative record.)

ADDITIONAL INFORMATION: The appeal is limited to a review of the administrative record, the Corps memorandum for the record of the appeal conference or meeting, and any supplemental information that the review officer has determined is needed to clarify the administrative record. Neither the appellant nor the Corps may add new information or analyses to the record. However, you may provide additional information to clarify the location of information that is already in the administrative record.

POINT OF CONTACT FOR QUESTIONS OR INFORMATION:

If you have questions regarding this decision and/or the appeal process you may contact:

Brent Sewell Nashville District, U.S. Army Corps of Engineers Regulatory Branch 501 Adesa Blvd, Suite B250 Lenoir City, Tennessee 37771 (615) 417-0240, Brent.J.Sewell@usace.army.mil If you only have questions regarding the appeal process you may also contact:

Regulatory Appeals Review Officer ATTN: Ms. Katie McCafferty Army Engineer Division 550 Main Street, Room 10-780 Cincinnati, Ohio 45202-3222 Phone: (513) 684-2699 e-mail: katherine.a.mccafferty@usace.army.mil RIGHT OF ENTRY: Your signature below grants the right of entry to Corps of Engineers personnel, and any government consultants, to conduct investigations of the project site during the course of the appeal process. You will be provided a 15 day notice of any site investigation, and will have the opportunity to participate in all site investigations.

Signature of appellant or agent.

Date:

Telephone number:

CN-0759 RDA 2366 Tracking Number TNR136931 NOTICE OF COVERAGE UNDER THE GENERAL NPDES PERMIT FOR STORMWATER DISCHARGES ASSOCIATED WITH CONSTRUCTION ACTIVITY (CGP)

Tennessee Department of Environment and Conservation Division of Water Resources William R. Snodgrass Tennessee Tower 312 Rosa L. Parks Avenue, 11th Floor Nashville, TN 37243 Under authority of the Tennessee Water Quality Control Act of 1977 (T.C.A. 69-3-101 et seq.) and the delegation of authority from the United States Environmental Protection Agency under the Federal Water Pollution Control Act, as amended by the Clean Water Act of 1977 (33 U.S.C. 1251, et seq.):

Name of the Construction Project:

TRISO-X Fuel Fabrication Facility (88.75 acres - Phased Construction)

Master Tracking Number at the Site:

TNR136931 Permittee Name:

TRISO-X, LLC Project Name:

TRISO-X Fuel Fabrication Facility Contractor(s):

no contractor is authorized to discharge:

storm water associated with construction activity from site located at:

Horizon Center Industrial Park, Renovare Blvd, Roane County to receiving waters named:

Unnamed Tributary to East Fork Poplar Creek in accordance with effluent limitations, monitoring requirements and other conditions set forth herein.

Likely presence of threatened or endangered species in one mile radius: YES Likely presence of threatened or endangered species downstream: NO Additional pollution prevention requirements apply for discharges into waters which TDEC identifies as:

- Unavailable Condition - Siltation

- Exceptional Tennessee Waters: NO Your coverage under the CGP shall become effective on November 10, 2022, and shall be terminated upon receipt of Notice of Termination.

A copy of the CGP can be obtained from https://www.tn.gov/content/tn/environment/permit-permits/water-permits1/npdes-permits1/npdes-stormwater-permitting-program/npdes-stormwater-construction-permit.html

STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION DIVISION OF WATER RESOURCES Knoxville Environmental Field Office 3711 Middlebrook Pike Knoxville, TN 37921 Phone 865-594-6035 Statewide 1-888-891-8332 Fax 865-594-6105 November 10, 2022 Mrs. Jennifer Wheeler, Director TRISO-X, LLC e-copy: jwheeler@x-energy.com 400 Centrifuge Way Oak Ridge, TN 37830

Subject:

NPDES Construction General Permit Tracking No. TNR136931 Master Tracking Number: TNR136931 TRISO-X Fuel Fabrication Facility TRISO-X, LLC Oak Ridge, Roane County, Tennessee

Dear Mrs. Wheeler:

You recently submitted a Notice of Intent (NOI) form as part of an application package to obtain coverage under a General NPDES Permit for Storm Water Discharges Associated with Construction Activity. The Division of Water Resources (the division) acknowledges receipt of the most recent version of the application for the above referenced project on November 8, 2022. After review, the application was deemed to be complete on November 10, 2022. Enclosed is the Notice of Coverage (NOC) form which shows the site name and location, receiving stream, effective date of coverage, etc.

Contractor Information You have not identified a contractor on the NOI. You must identify a primary contractor, or contractor otherwise responsible for sediment and erosion controls on the construction site, if appropriate, and submit a revised NOI to this office prior to beginning earth clearing operations onsite. When submitting the NOI, please include the above referenced permit tracking number.

Storm Water Pollution Prevention Plan (SWPPP)

You have submitted a Storm Water Pollution Prevention Plan (SWPPP) as required by Section 1.4.2 of the CGP. Please note that the division has not performed an engineering review of the SWPPP and does not certify whether the SWPPP adequately provides for the pollution prevention requirements at the site as described in the general permit. The division acknowledges that you have submitted a SWPPP that appears to include the required components of a SWPPP. It is the responsibility of all site operators to design, implement, and maintain measures that are sufficient to prevent pollution at the referenced site, and to remain in compliance with the terms and conditions of the general permit.

Receiving Stream not Supporting Designated Uses The receiving stream for the construction site for which the NOI was submitted appears on the states list for partially supporting or for not supporting a stream's designated use due to siltation. Since the discharge from the proposed construction site may contain significant amounts of silt, the division considers the potential for degradation to the receiving stream from the discharge to be significant. Therefore, the additional pollution prevention requirements described in Subpart 6.4 of the General Permit are applicable to your construction site; requirements of Section 6.4.2. apply only if the stream is located on or adjacent to the disturbed area.

Site Assessment Per Subsection 5.5.3.8 of the permit, a quality assurance of erosion prevention and sediment controls (EPSCs) shall be done by performing site assessments by a qualified individual. Site assessment shall be conducted at each outfall draining 10 or more acres (Subsection 5.5.3.5) or 5 or more acres if draining to waters with unavailable parameters or Exceptional Tennessee Waters (Section 6.4.1). Site assessments must cover the entire disturbed area and occur within 30 days of construction commencing at each portion of the site that drains the qualifying acreage. At a minimum, site assessments should be performed to verify the installation, functionality and performance of the EPSC measures described in the SWPPP. If structural BMPs (or equivalent EPSC measures) are not constructed or construction is in progress at the time of the site assessment, a follow-up monthly assessment(s) is required until the BMPs are constructed per the SWPPP.

Submittal of Site Assessment The division requests that you submit the initial site assessment documentation to this office within 10 days upon completion of the assessment.

Threatened and Endangered Species The receiving stream for the construction site for which the NOI was submitted has Federal or State listed threatened and endangered species in the area, or downstream of your project. Stormwater discharges and stormwater discharge-related activities that are not protective of legally protected listed or proposed threatened or endangered aquatic fauna in the receiving stream(s); or discharges or activities that would result in a 'take' of a Federally listed endangered or threatened fish or wildlife species are not authorized by the General Permit. If the division finds that stormwater discharges or stormwater related activities are likely to result in any of the above effects, the division will deny the coverage under this general permit unless and until project plans are changed to protect the listed species. In addition, discharges from your construction site that result in harm to such species may incur additional fines and penalties from the US Fish and Wildlife Service and/or the Tennessee Wildlife Resources Agency.

Annual Maintenance Fee and Termination of Permit Coverage Effective July 1, 2014, permit fees for the General Permit have been revised. In addition to new application fee amounts, annual maintenance fees are now required for projects that exceed one year of coverage.

Permittees wishing to terminate coverage must submit a completed notice of termination (NOT) form, which is available on the divisions construction stormwater webpage at https://www.tn.gov/content/tn/environment/permit-permits/water-permits1/npdes-permits1/npdes-stormwater-permitting-program/npdes-stormwater-construction-permit.html.

The division will review the NOT for completeness and accuracy and, when necessary, investigate the site for which the NOT was submitted. The division will notify the applicant that either the NOT form was received and accepted, or that the permit coverage is not eligible for termination and has not been terminated. If applicable, the notification will include a summary of existing deficiencies.

We appreciate your attention to the general construction storm water permit and its requirements. A copy of the CGP can be obtained from https://www.tn.gov/content/tn/environment/permit-permits/water-permits1/npdes-permits1/npdes-stormwater-permitting-program/npdes-stormwater-construction-permit.html. We believe this does make a difference to the quality of state waters. If you have any questions, please contact Mr. Joshua Frazier at (865) 364-9500 or by e-mail at Joshua.Frazier@tn.gov.

Sincerely, Michael Atchley Environmental Program Manager cc:

DWR, Knoxville EFO Permit File Mr. Miller Bailey, Environmental Compliance Inspector, City of Oak Ridge MS4, mrbailey@oakridgetn.gov Mr. Jeff Search, Facility Design Program Manager, TRISO-X, LLC, jsearch@x-enegry.com

Jennifer Wheeler From:

Sent:

@oakridgetn.gov>

Monday, October 24, 2022 4:21 PM To:

Jennifer Wheeler* Burns Cunnin ham Cc:

Subject:

Attachments:

APPROVED_TRISOXPrelimSite Plan.pdf I

Notice: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Good afternoon, This email is to let you know that Triso-X's Preliminary Site Plan has been approved. A stamped copy is attached for your records, and is also available through the City's online portal. You are now able to move forward and apply for a land disturbance permit, which can also be done through the City's online portal. I believe you all have talked with-about getting a land disturbance bond for that site, and he will get in touch with you all about that.

If you have any other questions please let me know.

Thank you, ak Ridge

@oakridgetn.gov OAKRIDGE TENNlSSEE Electronic communications with officials and employees of the City are subject to Tennessee's Public Records Act.

1

Jennifer Wheeler From:

Sent:

To:

Subject:

@oakridgetn.gov>

Friday, August 18 2023 1 :34 PM Jennifer Wheeler; RE: TRISO-X traffic study questions I

Notice: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

I apologize for not getting back with you sooner. We have reviewed the Traffic Impact Study (TIS) and I have discussed a couple of items with the traffic engineer. At this time, we do not have any issues with the recommendations in the submitted TIS for Triso-X. I believe it just recommend added a turn lane on Renovare Boulevard at the entrance for your proposed development. Traffic will be monitored after the development is completed to see if any other modifications would be recommended.

If you have any questions feel free to contact us. Thanks.

ineer

• etn.gov

@CityofOakRidge I oakridgetn.gov OAKRIDGE TENNESSl:I:

1

Jennifer Wheeler From:

Sent:

To:

Cc:

Subject:

@oakridgetn.gov>

Friday, March 8, 2024 4:25 PM Burns Cunnin ham* Jennifer Wheeler Package for PLSPL20220174 I

Notice: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Burns, Received, thank you. Because there was no Site Plan re-submittal I don't think staff has any additional review to do at the moment. I believe TRISO is at a place where you would be able to apply for a land disturbance permit whenever you are ready to do so. That said, this is with the understanding that a finalized Site Plan (with all landscaping, site design, etc.) will be required prior to any issuance of permits for building construction.

Hopefully that makes sense, but if you have any other questions please let me know.

• ge oakridgetn.gov gov OAKRIDGE TENNlSSEE 1

CITY OF OAK RIDGE POST OFFICE BOX 1 y OAK RIDGE, TENNESSEE 37831-0001 Permit No:

PRLD202402171 LAND DISTURBANCE Oak Ridge, TN Job Address ISSUED October 03, 2024 Owner TRISO-X LLC 801 THOMPSON AVENUE ROCKVILLE, MD 20852 Applicant Jennifer K. Wheeler, PE 151 Lafayette Drive, Suite 300, TRISO-X LLC Oak Ridge, TN 37830 Contractor Description of Work Grading / site preparation activities for the TRISO-X Fuel Fabrication Facility Additional Comments/Details Parcel #

073021 00200 Type of Construction New Zoning IND-3

1. Of Units Stories Permit #

PRLD202402171-LD1 Permit Fee

$55.00 Permit Types Land Disturbance Total Value of Work:

$0.00 Permit in force for period of 180 days. Provided, however, the above named party complies with all of the regulations as set out in the Building and Zoning Ordinances as are now in effect or that may be enacted during the time this permit is in effect.

This permit covers only the building and/or work specified. Any other building and/or work must have a separate permit.

Any violations of Ordinances and Building Codes if not corrected will automatically cancel this permit.

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Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Table of Contents March 2025 2-1 Rev. 3 CHAPTER 2 ALTERNATIVES TABLE OF CONTENTS Section Title Page 2.1 DETAILED DESCRIPTION OF THE ALTERNATIVES............................................... 2-8 2.1.1 NO-ACTION ALTERNATIVE...................................................................................... 2-8 2.1.2 PROPOSED ACTION................................................................................................ 2-9 2.1.3 REASONABLE ALTERNATIVES............................................................................. 2-22 2.2 ALTERNATIVES CONSIDERED BUT ELIMINATED................................................ 2-36 2.2.1 FACILITY LOCATION.............................................................................................. 2-36 2.2.2 DESIGN ALTERNATIVES........................................................................................ 2-38 2.3 CUMULATIVE EFFECTS.......................................................................................... 2-41 2.3.1 ACTIONS AT THE HORIZON CENTER INDUSTRIAL PARK................................. 2-41 2.3.2 ACTIONS RELATED TO OTHER FACILITIES........................................................ 2-42 2.4 COMPARISON OF THE PREDICTED ENVIRONMENTAL IMPACTS..................... 2-48

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - List of Tables March 2025 2-2 Rev. 3 LIST OF TABLES Number Title 2.1-1a Yard Storage - Underground Tanks 2.1-1b Yard Storage - Above Ground 2.1-1c Indoor Storage - Liquids 2.1-1d Indoor Storage - Solids in Main Facility 2.1-1e Indoor Storage - Solids in GMP Building 2.1-2 Estimated Type and Quantity of Radioactive Wastes - Operations 2.1-3 Estimated Materials Consumed During Construction Phase 2.1-4 Construction/Demolition Equipment Used in the Construction and Decommissioning Phases 2.1-5 Summary of Adverse Impacts from the Proposed Action 2,2-1 Evaluation Criteria for Candidate Sites 2.3-1 Actions at Other Facilities 2.4-1 Comparison of the Predicted Environmental Impacts

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - List of Figures March 2025 2-3 Rev. 3 LIST OF FIGURES Number Title 2.1-1 Overall Site Layout 2.1-2 Water Balance Diagram 2.3-1 City of Oak Ridge Industrial Development Areas

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Acronyms and Abbreviations March 2025 2-4 Rev. 3 Acronyms and Abbreviations Acronym/Abbreviation Definition ac.

acre ACP American Centrifuge Plant ADUN acid deficient uranyl nitrate AEA Atomic Energy Act AGR Advanced Gas Reactor ARC15 Advanced Reactor Concept 2015 ASME American Society of Mechanical Engineers ATF Accident tolerant fuel Btu/hr British thermal units per hour C

degrees Celsius CAS Chemical Abstracts Service CEQ Council on Environmental Quality CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations CCS Closed Cooling System DAW Dry active waste DFP Decommissioning funding plan DOD U.S. Department of Defense DOE U.S. Department of Energy EGU Electric Generating Unit EIA Energy Information Administration EMDF Environmental Management Disposal Facility EPRI Electric Power Research Institute ER Environmental Report ETTP East Tennessee Technology Park oF degrees Fahrenheit GE General Electric

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Acronyms and Abbreviations March 2025 2-5 Rev. 3 Acronym/Abbreviation Definition GMC General Motors Corporation GMP Graphite matrix powder GNF Global Nuclear Fuel ha hectares HALEU High-assay low enriched uranium HCS Horizon Center site HEPA High-efficiency particulate air HMTA Hexamethylenetetramine hr.

hour HTGR High-Temperature Gas-cooled Reactor HVAC Heating, ventilation, and air conditioning IBC Intermediate Bulk (Storage) Container INL Idaho National Laboratory KCF Kernel Conversion Furnace km kilometer LWR Light Water Reactor m3 cubic meters mi.

mile MSR Molten Salt-Cooled Reactor MSW municipal solid waste MTS Methyltrichlorosilane MTU metric tons uranium NASA National Aeronautics and Space Administration NE Office of Nuclear Energy NEPA National Environmental Policy Act NFPA National Fire Protection Association NRC U.S. Nuclear Regulatory Commission NMSS Nuclear Material Safety and Safeguards NQA Nuclear Quality Assurance

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Acronyms and Abbreviations March 2025 2-6 Rev. 3 Acronym/Abbreviation Definition NTP Nuclear Thermal Propulsion OCP Overcoated particle OMA Organic Mix Area/Chemical Storage Area ORED Oak Ridge Electric Department ORETTC Oak Ridge Enhanced Technology and Training Center ORNL Oak Ridge National Laboratory OSHA Occupational Safety and Health Administration PHR Process Heat Removal PPE personal protective equipment QC Quality control RCRA Resource Conservation and Recovery Act ROI Region of Influence RRV Runoff reduction volume scf Standard cubic feet SMR Small modular reactor SRS Savannah River Site TCF TRISO Coating Furnace TDEC Tennessee Department of Environment and Conservation TMC Centrus Technology Manufacturing Center TN Tennessee Highway TRISO TRi-structural ISOtropic TRISO-X TRISO-X, LLC TRISO-X FFF TRISO-X Fuel Fabrication Facility TSDF Treatment, storage, or disposal facility TSP Temporary sediment pond U3O8 Triuranium octoxide 235U Uranium-235 USEPA U.S. Environmental Protection Agency

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Acronyms and Abbreviations March 2025 2-7 Rev. 3 Acronym/Abbreviation Definition USNC Ultra Safe Nuclear Corporation y3 cubic yards Y-12 Y-12 National Security Complex

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-8 Rev. 3 CHAPTER 2 Alternatives This chapter of the Environmental Report (ER) describes the alternatives considered by TRISO-X, LLC (TRISO-X) for the TRISO-X Fuel Fabrication Facility (TRISO-X FFF) that is located at the Horizon Center site (HCS). Section 2.1 identifies and describes the No-Action Alternative, the Proposed Action, and any reasonable alternatives to the Proposed Action.

Section 2.2 identifies potential alternatives that were not considered to be reasonable and were therefore eliminated from further study. Section 2.3 provides a discussion of reasonably foreseeable future actions that could result in cumulative impacts when combined with the Proposed Action. Lastly, Section 2.4 provides a summary and comparison of the impacts of the Proposed Action, the No-Action Alternative, and the reasonable alternatives.

2.1 DETAILED DESCRIPTION OF THE ALTERNATIVES This section of the ER identifies and describes the No-Action Alternative, the Proposed Action, and any reasonable alternatives, including the technical design requirements for the Proposed Action. This section of the ER also discusses any potential options for the Proposed Action.

2.1.1 NO-ACTION ALTERNATIVE The Proposed Action and the purpose and need for the Proposed Action are described in Section 1.3 and Section 2.1.2 of the ER. The proposed Federal action is the issuance of a license by the U.S. Nuclear Regulatory Commission (NRC) for the construction and operation of the TRISO-X FFF at the HCS.

The TRISO-X FFF produces TRi-structural ISOtropic (TRISO) particle fuel, which is a High-Assay Low-Enriched Uranium (HALEU) nuclear fuel based on the TRISO fuel form (see Section 1.1). TRISO-X uses uranium oxide that is enriched to less than 20 percent uranium-235 (235U).

The TRISO-X fuel is used in the following types of nuclear facilities:

National Aeronautics and Space Administration (NASA) Nuclear Thermal Propulsion (NTP) concepts.

U.S. Department of Defense (DOD) micro-reactors.

High-Temperature Gas-cooled Reactors (HTGRs).

Molten Salt-cooled Reactors (MSRs).

Light Water Reactors (LWRs) that use TRISO-based accident tolerant fuel (ATF).

The Proposed Action improves the overall economic outlook for the U.S. nuclear power industry by contributing to the development of domestic nuclear fuel providers and enabling them to expand and compete internationally. The production of TRISO-X fuel, which the U.S.

Department of Energy (DOE) Office of Nuclear Energy (NE) has called the most robust fuel on Earth (DOE-NE, 2019) contributes substantially to the fuel supply chain, making the U.S. a global leader in safe, reliable, and economically feasible nuclear energy.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-9 Rev. 3 Under the No-Action Alternative, the NRC does not issue a license for the construction and operation and the TRISO-X FFF will not be built. The facility is not available for the production of TRISO-X fuel and the fuel would not be available from this facility for the nuclear industry.

Therefore, the No-Action Alternative negatively impacts the domestic and international availability of TRISO-X fuel.

Under the No-Action Alternative, it is expected that other types of power generation are used in place of advanced reactors, including fossil-fuel based thermal power plants. Fossil-fuel use contributes to greenhouse gas emissions and other forms of air pollution that are not associated with nuclear power plants. Nuclear energy is a reliable energy source and creates higher paying jobs. Under the No-Action Alternative, the country uses less reliable sources of energy and creates fewer high paying jobs.

The No-Action Alternative does not result in any of the potential environmental impacts from the construction and operation of the TRISO-X FFF at the HCS, as described in Chapter 4 and summarized in Section 2.4 below. If the action doesnt proceed, then the adverse impacts associated with the nuclear industry, including spent fuel or radioactive waste transportation, storage and disposal do not have to be dealt with.

Under the No-Action Alternative, there are no impacts to the ecology, floodplains, wetlands, historical and cultural resources, public and occupational health, waste management, environmental justice, and visual/scenic conditions. The current terrain, groundwater, and surface water availability and quality would remain the same.

The current levels and/or projections of land development and transportation would not be affected. Under the No-Action Alternative, the area would not benefit from the expected positive impacts of the Proposed Action on local employment, income, and tax revenues during the construction, manufacturing, operation, and decommissioning phases.

2.1.2 PROPOSED ACTION This section provides a description of the Proposed Action, including a facility description, summary of construction, operations, and decommissioning activities and a summary of potential impacts.

2.1.2.1 Description of Proposed Action The proposed Federal action is the issuance of a license to possess and use special nuclear material, under the provisions of 10 CFR 70, that would allow TRISO-X to possess and use special nuclear material in the TRISO-X FFF to produce TRISO-based coated particles and final fuel forms using uranium enriched to less than 20 weight percent 235U. The TRISO uranium fuel produced is used for nuclear reactor developers and by the energy, aerospace, industrial, and defense sectors. The applicant for this license and owner of the nuclear FFF is TRISO-X.

TRISO-X has the necessary authority, control, and rights related to the construction and operation of the nuclear fuel fabrication facility once the license is approved.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-10 Rev. 3 2.1.2.1.1 Facility Description 2.1.2.1.1.1 Site Location The HCS is located within the city limits of Oak Ridge, Roane County, Tennessee. The HCS boundary is approximately 7 mi. (11 km) southwest of the approximate city center of Oak Ridge.

The TRISO-X FFF is centered at the following geographic coordinates.

State Plane Coordinate System Zone TN-4100 Northing 596,650.000 US Survey Feet Easting 2,450,750.000 US Survey Feet Universal Traverse Mercator (UTM)/USNG coordinates Northing 3,982,867.000 Meters Easting 737,142.857 Meters National Geodetic Survey (NGS) coordinates Latitude 35° 57 41.13171 N Longitude 84° 22 13.36646 W As discussed in Section 1.3.1.2, bounding limits are defined by the circle with a radius of 0.38 mi. (0.61 km) measured from the center point and encompasses all the property within the HCS.

A map of the TRISO-X FFF bounding limits is provided in Figure 2.1-1.

The sensitive populations (e.g., schools, daycare facilities, hospitals), nearest resident, and landmarks (including highways, transportation facilities, and rivers and other bodies of water) within the Region of Influence (ROI), which includes Roane, Anderson, Knox, Loudon, and Morgan counties, are discussed within Section 3.10.

2.1.2.1.1.2 Site Layout Figure 2.1-1 shows the overall site layout depicting major structures and the site boundary. As discussed in Section 1.3, the TRISO-X FFF encompasses approximately 110 acres (ac.) (44.6 hectares (ha)). The following structures are located on the site:

TX-1 Process Building.

TX-2 Process Building.

Administration Building.

Graphite Matrix Power (GMP) Building.

Security/Emergency Operations Center Building.

Electrical and mechanical equipment yards.

Process building exhaust stacks.

Roadways.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-11 Rev. 3 Detention basins and drainage ditches.

Permanent parking areas.

Shipping and receiving docks.

Temporary construction laydown/parking.

2.1.2.1.1.3 Underground Features A natural gas pipeline provides commercial natural gas to the TRISO-X FFF. Natural gas service to the local area is provided by Oak Ridge Utility District. The natural gas service line follows the western border and southern border (along Renovare Blvd) of the TRISO-X site.

Municipal water is supplied with two new lines connected to the City of Oak Ridge water main.

Similarly, a connection to the city sanitary sewer line is provided to the sanitary sewer system.

Within the project site, additional underground utilities are provided, various mechanical distribution piping, electrical conduits and duct banks. There is one underground chemical tank located on site (See Table 2.1-1a). Off-site power is brought to the TX-1 portion of the facility from underground electrical distribution lines. Overhead distribution lines will bring in additional power service during the TX-2 expansion. Some of the stormwater features are located underground as discussed in Section 2.1.2.1.1.4.

2.1.2.1.1.4 Stormwater and Sewage Features 2.1.2.1.1.4.1 Site Drainage Description Stormwater runoff collected within the developed portion of the HCS property is discharged at three outlets, one located at the western site boundary and the other two on the southern and southeastern periphery of the site.

The west outlet is located on the southwest side of the property and directly discharges the runoff collected from the western half of the undeveloped area of the site, with some minor natural ponding in a depressed, low-lying areas. This natural depression collects runoff from a major portion of the pre-developed and post-developed site areas, excluding the main entry road and the construction laydown / future expanded east and craft parking area. The pre-developed drainage runoff area includes the off-site run-on from the area north of the site via two 24-inch culverts. The run-on and the site accumulated runoff follow natural drainage patterns and accumulates in the low areas of the site. The low depressed areas of the site provide a brief detention and the overflow from these areas discharges to the natural channel on the west side and flow continues through the DOE greenbelt zone to a natural depression located within the DOE greenway area west of the site.

2.1.2.1.1.4.2 Sanitary System The sanitary sewer system consists of a network of underground gravity pipes collecting sanitary waste from the building facilities and discharging to a City of Oak Ridge sanitary line.

The new sanitary system is designed to handle the flow generated by the anticipated number of staff personnel and other sanitary waste (non-radiological) that is discharged from the facility.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-12 Rev. 3 2.1.2.1.1.5 Monitoring Stations The need for monitoring stations is discussed in Chapter 6.

In addition, monitoring plans for the TRISO-X FFF are discussed in Chapter 6.

2.1.2.1.1.6 Water Consumption and Treatment 2.1.2.1.1.6.1 Water Consumption The City of Oak Ridge municipal water system supplies the water needs of the TRISO-X FFF.

Water uses for the facility include the following:

Process Heat Removal System (Evaporation, Drift, Blowdown).

Heating, ventilation, and air conditioning (HVAC) Chiller / Cooling Tower System (Evaporation, Drift, Blowdown).

Domestic Water (Water Closet, Lavatory, Sink, Shower, Drinking Fountain, Landscaping,).

Demineralizer Skid Makeup (Demineralized Water Makeup).

Fire Protection Water (fire hydrants, sprinkler systems, hose stations).

Mechanical System Fill.

Humidification.

Ultimate heat rejection from process equipment (i.e., process heat rejection) is steady and continuous via mechanical draft cooling towers as part of the Process Heat Removal (PHR)

System.

Sensible and latent heat is rejected from process equipment (via vent ducts) and workspaces within the production facility to HVAC systems. The heat load from these sources varies seasonally. A portion of this heat is rejected to the ambient environment by dedicated mechanical draft towers via evaporative cooling. Cooling towers for both services require makeup water to allow for evaporation, drift, and blowdown.

The Administration Building demand of domestic water involves the water consumption by the expected number of fixtures (e.g., showers, toilets, sinks) and water required for landscaping.

The demand is developed in accordance with International Plumbing Code, 2018 Edition.

For fuel production and other miscellaneous processes (e.g., Hydrogen electrolysis units),

demineralized water is required in relatively small quantities. Demineralized water is produced on-site, with input from the municipal water system. In addition to consumed quantities, an allowance is included for concentrate rejection from reverse osmosis equipment.

The fire protection water demand includes water consumption for testing of fire hydrants and sprinkler systems throughout the facility.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-13 Rev. 3 The makeup water requirements for mechanical system fill, humidification, and other services are small relative to the total demand.

A water use diagram for the facility and quantities for various streams described above is provided per Figure 2.1-2. Note that wastewater disposal from water entering liquid radwaste processing per the diagram is addressed in Section 4.13.

2.1.2.1.1.6.2 Water Treatment The TRISO-X FFF includes the water treatment for the following systems:

Demineralized Water System (i.e., deionization).

Closed Cooling System (CCS).

PHR System.

HVAC Chilled Water System.

HVAC Cooling Tower System.

2.1.2.1.1.6.2.1 Water Demineralization Within the TRISO-X FFF, demineralized water of various types (e.g., Type III and Type IV) is used for a number of process steps as part of the fuel fabrication process. Using potable water as feed, demineralized and deionized water is produced and distributed within the facility.

2.1.2.1.1.6.2.2 Cooling Water Treatment Water for use in the closed-loop cooling water systems (process closed loop and HVAC chilled water) is treated prior to system start-up, and then treated periodically. The treatment is determined by regular grab sample testing.

Water for use in the mechanical draft cooling tower systems (process heat rejection and HVAC heat rejection) is treated.

The types of chemicals considered in water treatment include:

Biocides - added to inhibit microbial growth in the water to control the potential for pathogens and fouling.

Corrosion inhibitors - added to inhibit corrosion of piping and components the cooling water flows through. Often corrosion is inhibited by halogen-based biocides.

Scale inhibitors - added to reduce scale formation, particularly within heat exchangers and cooling towers.

The specific inhibitor(s) is (are) selected based on the chemistry of the makeup water for the cooling water system.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-14 Rev. 3 2.1.2.1.1.7 Cooling and Heating Dissipation Systems 2.1.2.1.1.7.1 Cooling Systems 2.1.2.1.1.7.1.1 Process Cooling Process cooling for TX-1 is provided by the TX-1 CCS and process cooling for TX-2 is provided by the TX-2 CCS and PHR System. Hot return water from the process equipment is collected and pumped through refrigerant based chillers. Chilled water is then distributed to various process equipment for heat removal.

For TX-1 process heat is rejected to the surrounding air via air-cooled chillers. For TX-2 process heat is rejected to the surrounding air via primary (TX-2 CCS) and secondary (TX-2 PHR System) cooling loops which include intermediate water-cooled chillers and mechanical draft cooling towers.

The total process heat rejection for TX-1 is approximately 22.5 x 106 BTU/hr (6.6 x 103 kW). The total process heat rejection for the mechanical draft cooling towers for TX-2 is approximately 89.9 x 106 BTU/hr (26.3 x 103 kW).

For estimating consumptive water use (see Figure 2.1-2), the PHR System heat loads are estimated to be present 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, seven days per week.

2.1.2.1.1.7.1.2 HVAC Chilled water is used in the facility for HVAC cooling and humidity control. A chilled water supply temperature of 40°F (4.4°C) with 56°F (13.3°C) return temperature is assumed. The air-cooled chillers (used for TX-1) and water-cooled chillers (used for TX-2) operate year-round. The air-cooled chillers reject heat directly to the atmosphere and the water-cooled chillers reject heat to the atmosphere via cooling towers. Water lost due to evaporation, drift, and blowdown for HVAC chillers is included in Section 2.1.2.1.1.6.1. The total estimated heat rejection witnessed by the chillers is as follows:

TX-1 Estimated peak HVAC load: 19.8 x 106 Btu/hr (5.8 x 103 kW).

Estimated heat of compression HVAC load: 4.95 x 106 Btu/hr (1.5 x 103 kW).

Estimated total heat rejection HVAC load: 24.8 x 106 Btu/hr(7.3 x 103 kW)

TX-2 Estimated peak HVAC load: 54.0 x 106 Btu/hr (15.8 x 103 kW).

Estimated heat of compression HVAC load: 13.5 x 106 Btu/hr (4.0 x 103 kW).

Estimated total heat rejection HVAC load: 67.5 x 106 Btu/hr (19.8 x 103 kW).

For bounding purposes, the units are considered to run continuously (i.e., 24 hr. per day, 7 days per week).

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-15 Rev. 3 Being a closed loop system, makeup water is periodic and minimal. The makeup water is treated with a standard chemical treatment system.

The chillers for both the CCS and the HVAC chilled water systems operate using a non-chlorofluorocarbon refrigerant (R-513A for TX-1 and R-514A for TX-2).

2.1.2.1.1.7.2 Heating System Electricity is used to provide building heat via electric heating coils in the Air Handling Units.

There is no on-site fuel combustion equipment related to the heating system, such as gas or oil fired boilers or furnaces. Therefore, there are minimal environmental impacts associated with the system.

2.1.2.1.1.8 Waste Systems Each waste stream at the TRISO-X FFF falls into one of many possible waste categories such as municipal solid waste (MSW), nonhazardous industrial waste, hazardous waste, or radioactive waste. Waste containing a combination of radioactive and hazardous material is referred to as mixed waste. The Resource Conservation and Recovery Act (RCRA) and the Atomic Energy Act (AEA) govern mixed waste. (USEPA, 2021a) The U.S. Nuclear Regulatory Commission (NRC) implements the AEA to regulate mixed waste. Sections 2.1.2.1.1.8.1 and 2.1.2.1.1.8.2 discuss management, storage, and disposal of radioactive mixed waste.

Hazardous waste is discussed in Section 2.1.2.1.1.9. The sources of radioactive liquid, solid, and gaseous waste generated by the operation of the TRISO-X FFF are summarized as follows:

Liquid and gaseous effluents associated with process streams (e.g., wet chemistry material recovery process, gelation process, TRISO particle washing, High Temperature Carbonization furnace process).

Solid waste associated with receipt of feedstock material (e.g., empty containers that contained HALEU); dry active waste including personal protective equipment (PPE),

rags, cleaning supplies; waste from consumables used in the production process; and material that gets carried over into the ventilation system (e.g., U3O8 powder, Graphite Matrix Powder (GMP), and abraded material from mechanical handling; HEPA filters).

Quality Control laboratory wastes.

Routine waste from maintenance activities (e.g., trash generation from decontamination, filter replacement).

Facilities that handle and store radioactive materials in the area of the TRISO-X FFF are discussed in Sections 3.11.1.2.3 and 3.11.1.2.4.

The type and quantity of radioactive wastes is provided in Table 2.1-2.

See Section 4.13.4 for a description of the waste minimization plan.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-16 Rev. 3 2.1.2.1.1.8.1 Solid Radioactive Waste Handing System The Class A waste is consolidated and compacted as necessary before being stored in 55-gallon drums. Drums are then shipped off-site for disposal. There is no solid radioactive waste disposal at the TRISO-X FFF.

2.1.2.1.1.8.2 Liquid Radioactive Waste System The primary liquid waste which potentially could have radioactive contamination to be encountered in the TRISO-X FFF is the liquid waste coming from the liquid processing operations:

Triuranium octoxide (U3O8) dissolution to Acid Deficient Uranyl Nitrate (ADUN), storage of the process solution, the formation of gel-sphere kernels, the subsequent aging, washing, and drying of the gel-spheres.

The high viscosity substance which comes off of the High Temperature Carbonization furnace.

Effluents from operation of the Quality Control Laboratory analytical equipment.

Effluents from uranium recovery.

These liquid waste streams are collected, sampled, and chemically adjusted as necessary to recycle/reuse in the process or to prepare and package for off-site disposal.

2.1.2.1.1.8.3 Gaseous Effluents High-efficiency particulate air (HEPA) filtration is installed on systems with the potential to discharge radioactive materials. Filters are disposed of as solid waste. Each radiological stack is planned to be continuously sampled to ensure air effluent discharge concentrations to the environment are less than action levels that are established to ensure that the 10 CFR 20, Appendix B, Table 2, Column 1, limits are not exceeded.

2.1.2.1.1.9 Hazardous Material Handling The U.S. Environmental Protection Agency (USEPA) regulates nonhazardous and hazardous solid waste under RCRA. The regulations governing hazardous waste identification, classification, generation, management and disposal are found in Title 40 of the Code of Federal Regulations (CFR) Parts 260 through 273. Title 40 CFR Parts 239 through 259 contain the regulations for nonhazardous solid waste. (USEPA, 2021b)

Waste not categorized as MSW, radioactive, or mixed waste is examined to determine if it is nonhazardous or hazardous. Uncategorized waste is managed as hazardous until sufficient information is available to show the waste does not warrant hazardous classification.

2.1.2.1.1.9.1 Hazardous Waste Classification Hazardous waste is classified as either listed waste or characteristic waste. Listed wastes are generated from common manufacturing and industrial processes, specific industries, or discarded pure commercial grade chemicals (USEPA, 2022). TRISO-X FFFs manufacturing

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-17 Rev. 3 and industrial process, as well as the raw materials used, are not listed in 40 CFR Part 261, Sections 31 through 34. Listed hazardous waste is not generated at the TRISO-X FFF.

Characteristic wastes have one or more property of toxicity, corrosivity, reactivity, or ignitability which qualify the waste as hazardous. Samples of uncategorized wastes are analyzed per USEPA approved Test Methods for Evaluating Solid Waste: Physical/Chemical Methods Compendium to determine if the waste exhibits any hazardous waste characteristics (USEPA, 2021c). Spent process chemicals (e.g., activated carbon and crystallizer bottoms containing formaldehyde) from the TRISO-FFF require additional analysis to determine if classifications as hazardous waste due to characteristics of the waste are appropriate.

2.1.2.1.1.9.2 Hazardous Waste Disposal When the waste is not mixed with radioactive material, not MSW, and does not meet the listed or characteristic classification of a hazardous waste, the waste is then treated as a nonhazardous industrial waste and disposed off-site at an appropriate treatment, storage, or disposal facility (TSDF) accordingly.

In the event analytical results show the waste to exhibit one or more of the hazardous characteristics, the material is stored temporally on-site. Hazardous waste is consolidated as necessary and properly packaged then shipped off-site to an approved hazardous waste TSDF.

There is no hazardous waste disposal at the HCS.

Section 4.13.4 provides details of the TRISO-X FFF waste minimization plan.

2.1.2.1.1.10 Direct Radiation Sources Stored On-Site or near the TRISO-X FFF 2.1.2.1.1.10.1 Direct Radiation Sources Stored On-Site The solid wastes listed in Table 2.1-2 are stored on-site for a period before they are shipped off-site. The frequency of shipment of each type of waste is provided in Table 2.1-2. See also Section 4.13.3.

2.1.2.1.1.10.2 Direct Radiation Sources Stored near the TRISO-X FFF Facilities that handle and store radioactive materials in the area of the TRISO-X FFF are discussed in Section 3.11.1.2.4.

2.1.2.1.1.11 Pollution Prevention and Waste Minimization Pollution prevention and waste minimization planning provides the framework for promoting environmental stewardship and educating employees in the environmental aspects of activities occurring in the workplace, the community, and homes. The TRISO-X FFF has a program for pollution prevention and waste minimization that is discussed in Section 4.13.4.

2.1.2.1.2 Construction Activities Construction of TX-1 starts in 2024 and continues through 2027. Construction of TX-2 starts in 2026 and continues through 2029. Construction workforce estimates were developed for the larger TX-2 building. The buildings have generally the same systems and equipment. Therefore, the construction workforce estimates developed for TX-2 are conservatively also used for TX-1.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-18 Rev. 3 During the period of time that both TX-1 and TX-2 construction is occurring concurrently, a daily average of 188 workers (268 peak daily workers) and a monthly average of 480 truck deliveries and 96 off-site waste shipments. Total materials consumed for construction are shown in Table 2.1-3 and also include approximately 465,726 (145,546 for TX-1 and 320,180 for TX-2) gallons of diesel fuel (as a bounding assumption fuel is assumed to be diesel). The different types of construction equipment used during the construction phase are shown in Table 2.1-4.

Based on the preliminary grading analysis of the site, approximately 560,243 yd3 (428,337 m3) of topsoil and subsoil are excavated during the first six months of construction and replaced with approximately 362,661 yd3 (277,274 m3) of clean, earthen material for backfill. It is conservatively assumed that all of the excavated material is unsuitable for backfill and is disposed of at an off-site landfill location, and that all backfill material is obtained from off-site borrow areas. Additional geotechnical investigation work during construction will determine if some or much of the excavated material is suitable for backfill after lime treatment for expansive clay. Re-use of excavated materials as backfill reduces the volume of off-site disposal and borrow activities. It is also conservatively assumed that all of the off-site material is transported during the first six months of construction. Based on these conservative assumptions, the project requires a monthly average of 15,729 truckloads of excavated materials and backfill during the first six months of the project.

Off-site disposal and borrow areas comply with all applicable local, state and federal environmental requirements. The City of Oak Ridge approves off-site landfill and borrow areas as part of the local zoning, land use, and building permits process. The specific locations are not yet identified, but they are expected to be located near the major truck transportation routes in and out of the HCS and within the HCS Region to minimize hauling distances and costs.

Required permits and other regulatory approvals discussed in Section 1.4 of this report (Applicable Regulatory Requirements, Permits, and Required Consultations) would be obtained prior to construction activities.

2.1.2.1.3 Operation Activities Operational activities require a total peak workforce of 1569 workers for TX-1 and TX-2 combined and an annual average of 24 truck deliveries and 89 off-site waste shipments (radiological and non-radiological waste).

Operations at the TRISO-X FFF are described in detail below.

2.1.2.1.3.1 Uranyl Nitrate Solution Receipt and Processing Dilute uranyl nitrate (UN) solution enriched to less than 20 weight percent 235U received as feedstock arrives by truck in approved shipping containers licensed by the NRC or DOE. The dilute UN is transferred from the approved shipping containers into a receipt and storage tank located in the TX-1 facility. The received dilute UN solution batch is converted into U3O8 powder to form input batches to the Dissolution process.

2.1.2.1.3.2 U3O8 Powder Receipt and Storage U3O8 powder enriched to less than 20 weight percent 235U received as feedstock arrives by truck in approved shipping containers licensed by the NRC or DOE. The approved shipping containers are unloaded into receipt and storage areas located in the TX-1 and TX-2 facilities.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-19 Rev. 3 U3O8 powder is supplied by (1) external suppliers (new material), (2) the dilute UN process in TX-1, and (3) uranium recovery process. U3O8 powder is sampled and repackaged unto portable containers within the receipt and storage area and stored until it is ready to be used in Dissolution process.

2.1.2.1.3.3 Dissolution U3O8 powder enriched to less than 20 weight percent 235U is manually transferred from a portable container into a hopper in a glovebox. The U3O8 powder is then metered into a nitric acid and water solution in a column where it is mixed until the required amount of U3O8 is dissolved resulting in a uranyl nitrate solution. The uranyl nitrate solution is then transferred to storage columns until it is ready to be used in the Gelation process.

2.1.2.1.3.4 Gelation The uranyl nitrate solution is mixed with organic additives, and liquid droplets are formed that react with heated silicone oil to produce gel spheres. The gel spheres are aged in silicone oil, washed and rinsed to remove the silicone and additives, and dried. The resulting dried microspheres are combined by mass to form the input batches to the Kernel Conversion process.

2.1.2.1.3.5 Kernel Conversion The dried microspheres are converted in a high temperature furnace to fuel kernels of uranium compounds, such as uranium dioxide and uranium dicarbide, based on the fuel design being fabricated. The fuel kernels undergo quality checks, and non-conforming products are rejected and sent to the Uranium Recovery process. The fuel kernels that pass the quality checks are combined by mass to form the input batches to the Coating process.

2.1.2.1.3.6 Coating The fuel kernels are coated with several carbonous layers using a fluidized bed chemical vapor deposition system, resulting in coated particle fuel. When four carbonous layers are used, the resulting uranium-bearing microspheres are known as TRISO particles. The coated particles undergo quality checks and non-conforming products are rejected and sent to the Uranium Recovery process. The coated particles that pass the quality checks are combined by mass to form the input batches to the Overcoating process.

2.1.2.1.3.7 Overcoating The coated particles are overcoated with a layer of graphite matrix powder, based on the fuel design being fabricated and the packing fraction required in the fuel element. The overcoated particles (OCPs) undergo quality checks and non-conforming products are rejected and sent to a washing station to remove the overcoating layer before being reintroduced into the Overcoating process. The OCPs that pass the quality checks are batched and sent to the Fuel Form Preparation process.

2.1.2.1.3.8 Fuel Form Preparation OCPs are poured into molds or tooling and compressed or compacted into green fuel forms of the desired geometry, such as compacts or pebbles, based on the fuel design being fabricated.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-20 Rev. 3 Some fuel designs require encapsulating OCPs in additional GMP and/or shaping. The green fuel forms undergo dimensional checks, and non-conforming products are rejected and sent to the Uranium Recovery process. The green fuel forms that pass the quality checks are batched and sent to the High Temperature Carbonization process.

2.1.2.1.3.9 High Temperature Carbonization The green fuel forms are processed through a high temperature furnace to convert the green body into a strong carbonized fuel form capable of withstanding handling and reactor service conditions. The final fuel forms undergo quality checks and those that pass are loaded into storage or shipping containers. Non-conforming products are rejected and sent to the Uranium Recovery process.

2.1.2.1.3.10 Uranium Recovery Uranium is recovered from damaged, degraded, or otherwise non-conforming product materials through a variety of batch operations. The batch operations size reduce, deconsolidate, oxidize, and/or convert the non-conforming product materials to U3O8 powder so that it can be used as feedstock for the Dissolution process.

2.1.2.1.3.11 Ventilation, Waste Processing, And Effluent Handling Ventilation systems are designed and operated to assure adequate control of radioactive dust and particulate. Solid wastes are collected in the areas of generation and transferred to the Waste Handling area for assay and processing; wastes may be compressed and/or size reduced to allow containerization into 55-gallon drums, and those that meet free release criteria may be disposed of as non-contaminated. Employee personal protective clothing is collected and packaged for shipment to a contaminated laundry service. Liquid waste streams are collected, sampled, and chemically adjusted as necessary to recycle/reuse in the process or to prepare and package for off-site disposal. A drum dryer system is provided to evaporate liquid waste solutions to allow for disposal of dissolved material as solid waste. Compliance with regulatory limits is verified through periodic sampling of the waste streams.

2.1.2.1.3.12 Quality Laboratory Product quality is verified by analyzing samples taken at various stages of the process.

Destructive and non-destructive tests are performed to confirm the chemical composition, physical attributes, and material properties.

2.1.2.1.3.13 Chemical Receipt, Storage, And Handling The TRISO-X FFF takes delivery and consumes a number of chemicals in the production of TRISO fuel. Those which are stored in bulk quantities are addressed here. These can be divided into chemicals stored outdoors and those stored indoors.

The storage configuration (e.g., design standards for vessels, valves, and piping, or separation requirements) for each chemical addresses and meets requirements from various codes, standards, and guidelines including certain applicable publications from the American Society of Mechanical Engineers (ASME), Compressed Gas Association, International Building Code, International Fire Code, National Fire Protection Association (NFPA), Occupational Safety and Health Administration (OSHA), and the NRC.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-21 Rev. 3 The liquid and gaseous chemicals stored in bulk quantities and consumed in the production of TRISO fuel (See Tables 2.1-1a through 2.1-1e) are received by truck. For these chemicals, provisions for: (i) on-site receipt and (ii) return of empty containers are included to prevent spills, releases, and accidents. These provisions follow accepted engineering practice, and adhere to applicable laws, regulations, codes, and standards.

For outdoor storage of certain liquids, deliveries are by transfer from a delivery vehicle (tanker truck) to the fixed on-site storage tank(s). Provisions for on-site chemical transfer operations are included to prevent spills and accidents. These provisions follow accepted engineering practice, and adhere to applicable laws, regulations, codes, and standards.

Table 2.1-1a summarizes the design for underground outdoor storage. Table 2.1-1b summarizes the design for above ground outdoor storage of hazardous chemicals. Table 2.1-1c summarizes the design for (non-pressurized) indoor storage of certain liquids used and consumed in the various production processes. Tables 2.1-1d and 2.1-1e summarize design provisions for solids stored in bulk quantities in the Main Facility and the GMP Building, respectively.

2.1.2.1.3.14 Shipping and Transportation All shipments of nuclear materials and wastes are conducted in conformance with NRC, U.S.

Department of Transportation, and State of Tennessee requirements. Incoming U3O8 or dilute uranyl nitrate feedstock arrives by truck in approved containers licensed by the NRC or DOE.

Final fuel forms are shipped out to customers by truck in approved containers licensed by the NRC. Low level waste shipments are appropriately packaged and analyzed for uranium content prior to shipment to licensed low-level waste disposal sites.

2.1.2.1.3.15 Research and Development Product research and development activities for planned and future fuel products and processes occur in this section of the facility. Small scale production process testing, as well as destructive and non-destructive tests, are performed which can include radiological materials of various chemical compositions, physical attributes, and material properties.

2.1.2.1.4 Decommissioning Activities At the end of useful plant life, the TRISO-X FFF would be decontaminated and decommissioned in accordance with applicable NRC license termination requirements. Decontamination and decommissioning of the TRISO-X FFF would be funded in accordance with the Decommissioning Funding Plan (DFP) for the TRISO-X FFF. The DFP, prepared by TRISO-X in accordance with 10 CFR 70.25(a), provides information required by 10 CFR 70.25(e) regarding TRISO-Xs plans for funding the decommissioning of the TRISO-X FFF and the disposal of radioactive waste generated as a result of plant operations. Funding would be provided by TRISO-X in accordance with NRC regulations in 10 CFR Part 70 and guidance in NUREG-1757.

Any radioactive equipment and materials are disposed of during decommissioning according to local and Federal laws and regulations. Post-operational decommissioning activities require up to 150 workers. It is expected that the average number of truck shipments from the site during decommissioning are bounded by the average daily truck traffic during the construction phase.

Building materials, such as wood, concrete, and steel, and process equipment would be

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-22 Rev. 3 removed from the site. The different types of construction equipment used during the decommissioning phase are shown in Table 2.1-4.

Before decommissioning activities begin, a Decommissioning Plan is prepared and submitted to the NRC pursuant to 10 CFR 70.38 (Expiration and Termination of Licenses and Decommissioning of Sites and Separate Buildings or Outdoor Areas). The Decommissioning Plan provides information concerning the TRISO-X FFF, the types of items to be decontaminated, the disposition of facilities used for hazardous materials, the assumptions upon which the cost of decommissioning is derived, and an estimated schedule for decommissioning and closing the facility. It is the intent of TRISO-X to decommission and close the TRISO-X FFF so as to reduce the level of radioactivity remaining in the facility to residual levels acceptable for release of the facility site for unrestricted use and for NRC license termination pursuant to 10 CFR 20.1401 (General provisions and scope) and 10 CFR 20.1402 (Radiological criteria for unrestricted use).

Prior to decommissioning, an assessment of the radiological status of the TRISO-X FFF is made. Decommissioning and closure activities include the cleaning and removal of radioactive and hazardous waste contamination that may be present on materials, equipment, and structures. General guidelines that would apply to the decommissioning and closure effort are discussed in Section 3.12.

2.1.2.2 Impacts from Performing the Proposed Action and Mitigation Measures Reasonably foreseeable environmental impacts and the extent of those impacts from the Proposed Action, potential mitigation measures, and restoration actions, if applicable, are described in detail in Chapter 4 of this Report (Environmental Impacts).

Potential mitigation measures of those impacts and associated potential restoration actions, if applicable, are further described in Chapter 5 of this Report (Mitigation Measures). Mitigation measures are those actions or processes that would be implemented to avoid or minimize the magnitude of the impact of the Proposed Action on the affected environment; rectify (i.e., repair, rehabilitate, or restore) the affected environment; or compensate for the impact by providing substitute resources or environments (40 CFR 1508.20, Mitigation). Chapter 4 also summarizes environmental impacts that result from the construction, operation, and decommissioning of the TRISO-X FFF.

A summary of adverse impacts from the Proposed Action are provided in Table 2.1-5. The extent of impacts considering all lifecycle phases from the Proposed Action is briefly summarized by the environmental resource that is impacted. As referenced in NUREG 1748 (Environmental Review Guidance for Licensing Actions Associated with NMSS [Nuclear Material Safety and Safeguards]) Programs), the standard of significance (i.e., SMALL, MODERATE, LARGE) established by the NRC in NUREG-1437, Revision 1 (Generic Environmental Impact Statement for License Renewal of Nuclear Plants), was used to define the extent of impacts from the Proposed Action (see also Section 2.3). Overall, adverse impacts from the Proposed Action are SMALL. Implementation of mitigation measures further reduce the severity of these impacts.

2.1.3 REASONABLE ALTERNATIVES Modern TRISO particle fuel technology is the product of particle fuel development activities spanning many countries during a half-century period. The U.S. Department of Energy (DOE)

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-23 Rev. 3 launched the Advanced Gas Reactor (AGR) Fuel Development and Qualification Program in 2002 to establish the ability to manufacture high-quality TRISO fuel in the United States and to demonstrate its performance (EPRI, 2019). The results of the AGR program have been successful to date and support current safety design and analysis assumptions about fuel performance and radionuclide retention required for advanced reactor designs. Fabrication of high-quality low-defect fuel is achievable at an industrial scale (INL, 2017).

Subsequent work by TRISO-X under a DOE cooperative agreement and industry partnership, DE-NE0008472 Advanced Reactor Concept 2015 (ARC15), established high throughput, high-yield commercial scale equipment, and advanced characterization techniques in the TRISO-X Pilot Facility inside the Oak Ridge National Laboratory. TRISO-Xs Pilot Facility produced qualification test articles for TRISO-based reactors, developed operational processes and procedures that comply with ASME Nuclear Quality Assurance (NQA-1) requirements, and demonstrated the technologies developed under the AGR Fuel Program to produce TRISO fuel forms is mature and ready for commercialization.

Alternatives to TRISO particle fuel technology would require decades to develop to maturity.

Therefore, there are currently no reasonable alternatives to TRISO particle fuel.

2.1.3.1 Design Alternatives Since the beginning of conceptual design work for the TRISO-X FFF in 2018, the energy landscape has been evolving rapidly, in part due to increasing global attention on climate change and the relationship to carbon emissions. Business model forecasts for deployments of Xe-100 reactor modules and the required quantities of TRISO pebble fuel went through several updates to reflect influences like those summarized below:

As the largest source of carbon-free electricity in the U.S., nuclear reactors provide carbon-free, resilient and reliable energy, and enable the replacement of retiring coal facilities and nuclear plants, as utilities that have pledged to decarbonize are now investing in license renewals to keep zero carbon generators online to 2050 and beyond (NEI, 2020a).

Nuclear energy, an essential part of the United States clean energy portfolio which generates nearly 20 percent of U.S. electricity and nearly 55 percent of our emission-free generation, along with wind, solar, hydro and other zero-carbon power generation sources, is critical to achieving a 100 percent carbon-free energy system (NEI, 2020b).

On November 15, 2021, the bipartisan Infrastructure Investment and Jobs Act, a 1.2 trillion dollar package containing a total of more than 62 billion dollars for the DOE to deliver a more equitable clean energy future, including the premature retirement of existing nuclear plants and investing in advanced nuclear projects, was signed into law.

The deal earmarks 2.5 billion dollars for advanced nuclear through the DOEs Advanced Reactor Demonstration Program (ADRP), which was launched by DOE in 2020 to speed the demonstration of advanced reactors through cost-shared partnerships with the US industry. In October 2020, Terrapower and X-energy were the two companies selected by DOE to demonstrate their advanced nuclear reactors by the end of the decade (WNN, 2021).

On December 8, 2021, Executive Order 14057, Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability, a policy set to achieve a carbon pollution-free

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-24 Rev. 3 electricity sector, including nuclear energy, by 2035 and a net zero emissions economy-wide by no later than 2050, was signed (Exec. Order No. 14057, 2021).

A June 2022 study by Vibrant Clean Energy, on behalf of NEI, concluded nuclear generation can play an important role in decarbonizing the electricity sector by providing over 40 percent of total generation in 2050, requiring more than 300 GW of new nuclear (VCN, 2022).

On August 16, 2022, the Inflation Reduction Act (IRA) was signed into law by President Biden. The IRA provides tax credits for both production and investment for advanced reactors generating electricity. Advanced reactor facilities that qualify for production or investment tax credits may only benefit from one, the production credit or the investment credit, but not both. The IRA also puts forth $700 Million to support research of HALEU fuel, as well as its development and use in advanced reactors. There is $100 Million to make HALEU fuel available for research, development, demonstration, and commercial use; $500 Million to make HALEU available for the first advanced reactors from the U.S.s uranium stockpile that is currently being formed, determine HALEU amounts needed for commercial HALEU markets in the U.S., and create a group to support the availability of HALEU for commercial use; and $100 Million to assist commercial entities in the licensing and regulation of special nuclear material fuel (such as HALEU) fabrication, enrichment facilities, and transportation packages.

As a result of influences on the energy landscape such as the examples above, the capacity of the TRISO-X FFF was increased from the 2018 projected need of 1.5 metric tons of uranium (MTU) per year, to a 5-6 MTU per year modular concept that could be used to right-size the size of factories at multiple locations. The 5-6 MTU per year modular concept was further increased to an 8-MTU per year module. In 2021, the projected need was further defined as two 8-MTU modules providing a factory capacity of 16 MTU per year. In 2023, the project need was further increased to add a 5 MTU per year module to ultimately provide a factory capacity of 21 MTU per year. In 2024, the announcement of a second Xe-100 reactor customer (Amazon) resulted in the production throughput capacities being updated to one 5 MTU process line (TX-1) and two 10 MTU process lines (TX-2) for a total capacity of 25 MTU per year.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-25 Rev. 3 Table 2.1-1a Yard Storage - Underground Tanks See the TRISO-X Fuel Fabrication Facility Site Emergency Plan and/or TRISO-X Fuel Fabrication Facility Integrated Safety Analysis Summary

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-26 Rev. 3 Table 2.1-1b Yard Storage - Above Ground See the TRISO-X Fuel Fabrication Facility Site Emergency Plan and/or TRISO-X Fuel Fabrication Facility Integrated Safety Analysis Summary

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-27 Rev. 3 Table 2.1-1c Indoor Storage - Liquids See the TRISO-X Fuel Fabrication Facility Site Emergency Plan and/or TRISO-X Fuel Fabrication Facility Integrated Safety Analysis Summary

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-28 Rev. 3 Table 2.1-1d Indoor Storage - Solids in Main Facility See the TRISO-X Fuel Fabrication Facility Site Emergency Plan and/or TRISO-X Fuel Fabrication Facility Integrated Safety Analysis Summary

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-29 Rev. 3 Table 2.1-1e Indoor Storage - Solids in GMP Building See the TRISO-X Fuel Fabrication Facility Site Emergency Plan and/or TRISO-X Fuel Fabrication Facility Integrated Safety Analysis Summary

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-30 Rev. 3 Table 2.1-2 (Sheet 1 of 2)

Estimated Type and Quantity of Radioactive Wastes - Operations Description Matrix Class as Generated Contents Mass (kg/yr)

Volume as shipped (ft3)(d) 55-gallon drum equivalent as shipped Shipment Type Destination TX-1(b)

Waste Drums B-25 boxes Solid A

Local and central system high efficiency particulate air (HEPA) filters, consumables, dry active waste (DAW),), solidified solutions, salts 168,150 11,381 1,467 LSA(a)

EnergySolutions Clive, UT Waste Control Specialist (WCS)

Andrews, TX Toxco Material Management Center (TMMC)

Oak Ridge, TN Quality Control (QC)

Lab Waste Waste Drums Mixed A

Unrecoverable uranium samples 14,979 443 58 LSA(a)

EnergySolutions Clive, UT Waste Control Specialist (WCS)

Andrews, TX Toxco Material Management Center (TMMC)

Oak Ridge, TN

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-31 Rev. 3 Table 2.1-2 (Sheet 2 of 2)

Estimated Type and Quantity of Radioactive Wastes - Operations a)

Low Specific Activity b)

For TX-1, there are 12 shipments per year. Each shipment consists of 71 drums, and 5 B-25 boxes.

c)

For TX-2, there are 48 shipments per year. Each shipment consists of 67 drums, and 5 B-25 boxes.

d)

The dimensions of the transportation packages:

55-gallon waste drums have a diameter of 24 and a height of 34.5.

B-25 boxes have a width of 46, a length of 72, and a height of 47.

Description Matrix Class as Generated Contents Mass (kg/yr)

Volume as shipped (ft3)(d) 55-gallon drum equivalent as shipped Shipment Type Destination TX-2(c)

Waste Drums B-25 boxes Solid A

Local and central system high efficiency particulate air (HEPA) filters, consumables, dry active waste (DAW), solidified solutions, salts 641,342 43,777 5,640 LSA(a)

EnergySolutions Clive, UT Waste Control Specialist (WCS)

Andrews, TX Toxco Material Management Center (TMMC)

Oak Ridge, TN Quality Control (QC)

Lab Waste Waste Drums Mixed A

Unrecoverable uranium samples 59,914 1,770 229 LSA(a)

EnergySolutions Clive, UT Waste Control Specialist (WCS)

Andrews, TX Toxco Material Management Center (TMMC)

Oak Ridge, TN

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-32 Rev. 3 Table 2.1-3 Estimated Materials Consumed During Construction Phase Material Amount (TX-1)

Amount (TX-2)

Total Concrete 14,151 cubic yards 42,000 cubic yards 56,151 cubic yards Structural Steel 2153 tons 5250 tons 7403 tons Misc. Steel 1216 tons 3040 tons 4256 tons Asphalt 800 cubic yards 8200 cubic yards 9000 cubic yards Stone Granular Material 6700 cubic yards 41,800 cubic yards 48,500 cubic yards Roofing 505 tons 1500 tons 2005 tons Diesel Fuel 145,546 gallons 320,180 gallons 465,726 gallons

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-33 Rev. 3 Table 2.1-4 (Sheet 1 of 2)

Construction/Demolition Equipment Used in the Construction and Decommissioning Phases Equipment Present During Construction (Y or N)

Present During Decommissioning (Y or N) 37" Walk Behind Finisher - Concrete, 6.5 HP Y

N Air Compressor, 600 cfm Y

Y Asphalt Compactor, Cat CB434C, 107 Hp Y

N Asphalt Paver, Barber Greene AP-1000, 174 Hp Y

N Backhoe Cat 426, 1.3 CY 85 HP Y

Y Backhoe/Loader, Cat 430, 105 Hp Y

Y Boom Lift, JLG 800AJ, 65 Hp Y

Y Compactor Plate, 20 HP Y

Y Concrete Pump, 100 yph, 100 HP Y

N Concrete saw, hand, 13 HP Y

Y Crane Hydraulic 18 ton, 160 HP Y

Y Crane, Lattice Boom, Manitowoc 8000, 80t, 205 Hp Y

N Crane, Picker, Grove RT530E-2 30t, 160 Hp Y

Y Dozer - Cat D5, 90 HP Y

Y Excavator Cat 320, 24'-10" dig depth, 162 HP Y

N Excavator, Large, Cat 345D L, 380 Hp Y

N Extended Forklift, Lull 1044C-54, 115 Hp Y

Y Fuel Truck, Mack MP6, 150 Hp Y

Y Hydromulcher, 44 HP, Kubota Diesel Y

N Lift, boom JLG40, 40' telescoping, 67 HP Y

Y Lift, Fork 8000 lb, 97 HP Y

Y

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-34 Rev. 3 Table 2.1-4 (Sheet 2 of 2)

Construction/Demolition Equipment Used in the Construction and Decommissioning Phases Equipment Present During Construction (Y or N)

Present During Decommissioning (Y or N)

Lift, Scissor 24', 65 HP Y

Y Mechanics Truck, 21/2 ton, F-650, 270 Hp Y

Y Pickup Truck, F-250, 300 Hp Y

Y Portable Air Compressors, <50 HP Y

Y Portable Generators, <50 Hp Y

Y Skidsteer Loader, Case SR200, 75 Hp Y

Y Tracked Dozer, Cat D7, 235 Hp Y

N Tracked Loader, Cat 973C, 242 Hp Y

N Trencher, < 5' deep, 44 HP Y

N Truck, Dump 16 CY, 280 HP Y

Y Vibratory Soil Compactor, Cat CS74, 156 Hp Y

Y Walk Behind Compactor, <50 Hp Y

Y Water Truck, Mack MP6, 150 Hp Y

Y Welding Machine 400 amp, 20 HP Y

N Wheel Loader, Cat 950 4 CY, 202 HP Y

Y

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-35 Rev. 3 Table 2.1-5 Summary of Adverse Impacts from the Proposed Action Category ER Section Extent of Impact Land Use 4.1 SMALL Transportation 4.2 SMALL Geology and Soils 4.3 SMALL Water Resources 4.4 SMALL Ecology 4.5 SMALL Air Quality 4.6 SMALL Noise 4.7 SMALL Historic and Cultural Resources 4.8 SMALL Visual/Scenic 4.9 SMALL Socioeconomics 4.10 SMALL to MODERATE Environmental Justice 4.11 SMALL Public and Occupational Health 4.12 SMALL Waste Management 4.13 SMALL

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-36 Rev. 3 2.2 ALTERNATIVES CONSIDERED BUT ELIMINATED 2.2.1 FACILITY LOCATION A site study was performed to identify a site for the TRISO-X Fuel Fabrication Facility (TRISO-X FFF). The goal of the site study was to recommend one or more suitable sites for the siting of the TRISO-X FFF from a nuclear licensing, environmental, engineering, and community acceptance standpoint. The site study identified and screened potential sites in order to identify candidate sites for the TRISO-X FFF. Those candidate sites were further evaluated to determine if there is an obviously superior site as defined by 10 CFR Part 51. The goal of the site study was to recommend one or more suitable sites from an environmental, engineering and community acceptance standpoint, to be used by the owner in conjunction with the owners economic evaluation, and other evaluations, to select a Proposed Site. The results of the site study are detailed further within this section.

The site study identified 25 potential sites or site areas in the U.S. for the siting of the TRISO-X FFF. Eleven of the potential sites are fuel cycle facilities licensed by the U.S. Nuclear Regulatory Commission (NRC). Four of the sites have been previously studied by the NRC for reactors but were never built and remain greenfield sites. Two of the potential sites are other nuclear sites or facilities. Four of the sites are industrial properties formerly owned by General Motors Corporation (GMC) that have been remediated for potential redevelopment. The GMC sites are now owned by an entity known as the RACER Trust and are available for redevelopment. Four of the sites are brownfield power plant sites. Two of the brownfield sites are retired fossil fuel electric generating units (EGUs) located in urban areas and were identified from lists published by the Energy Information Administration (EIA). Two of the brownfield sites are decommissioned nuclear plants for which the owners have announced the availability of the sites for disposition.

The potential sites were evaluated using a ranking methodology consistent with the Electric Power Research Institute (EPRI) Siting Guide (EPRI, 2002). The site selection criteria included the following environmental, technical, and social factors:

The proximity to a source of high assay low enriched uranium (HALEU) in the form of U3O8 powder.

Potential local government and community support for a proposed NRC-licensed facility.

Access to a skilled nuclear workforce.

Proximity to the interstate highway system.

Available municipal water, sewer, and electric power infrastructure.

Access to a well-developed health and safety infrastructure.

Sufficiently large (at least 75 ac. [30.4 ha]) site generally free of potential environmental constraints (e.g., wetlands, floodplains, natural habitats for protected species, steep terrain and known cultural resources).

Acceptable seismic characteristics.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-37 Rev. 3 Proximity of karst formations.

Frequency of inclement weather (e.g., tornadoes, hurricanes, and winter storms).

Proximity of hazardous industrial facilities and potentially contaminated properties (e.g.,

oil refineries, pipelines, liquified natural gas facilities).

Local and State environmental siting and permitting processes.

Proximity to airports. This criterion identifies sites with access to commercial air travel but avoids sites near public or private-use airports that could pose additional hazards to the facility.

Using the ranking methodology, the following five candidate sites for additional evaluation were identified:

Centrus American Centrifuge Plant (ACP), Piketon, Ohio.

Centrus Technology Manufacturing Center (TMC), Oak Ridge, Tennessee.

Horizon Center site (HCS), Oak Ridge, Tennessee.

General Electric/Global Nuclear Fuel-A Facility (GE/GNF-A), Wilmington, North Carolina.

Savannah River Site (SRS) Energy Park, Aiken, South Carolina.

The five identified candidate sites were then examined in more detail to determine whether the candidate sites had any significant environmental, engineering, or nuclear licensing issues that would make them impractical or otherwise undesirable for development of the TRISO-X Facility.

The purpose of this evaluation is to determine if any site is obviously superior from an environmental perspective as required by 10 CFR Part 51.

The five candidate sites were evaluated for 35 different site characteristics in 8 different categories (Table 2). Each of the site characteristics have both Must and Want requirements.

If a site did not meet the Must conditions, it was eliminated from further consideration.

However, none of the 5 sites were eliminated for not meeting a Must requirement.

The criteria included an objective means of assigning a numerical score for each site characteristic and importance weighting factors, which were used to evaluate the sites based on the relative importance of the site characteristics. Each of the sites was given a score from 1 to 5 for the Want requirements for each of the 35 characteristics, and each of the 35 characteristics was weighted from 1 to 10 based on the relative importance for the project.

The site characteristics, Must and Want conditions, numerical scoring criteria, possible scores, and importance weighting factors were decided upon through internal discussions and were based regulatory requirements and best practices. They are consistent with the EPRI Siting Guide (EPRI, 2002) and with the methods used for other nuclear power facility siting studies.

Based on the detailed examination, the study determined that all five of the candidate sites were suitable for the TRISO-X Facility and that there were no obviously superior alternative sites. The

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-38 Rev. 3 study recommended moving forward with full site characterization for any one of the five sites listed above, after selection based on further economic and other evaluations.

The HCS was selected over other evaluated sites because it provided the best opportunity to deploy the TRISO-X FFF, based on the criteria established in our site selection process.

Specifically, the HCS was located in Oak Ridge, Tennessee, a community supportive of nuclear facilities, with close location to emergency resources such as fire and police. The site also offered no major environmental concerns, in terms of ground water quality, soil plasticity, karst, and archaeological artifacts. In addition, the Industrial Development Board of Oak Ridge offered the 110-acre (Lot 6a) site to TRISO-X at no cost and a 20-year payment in lieu of taxes program. In summary, the physical location of the site, properties of the site itself, and real estate offer made the HCS the best option for the commercial fuel facility.

2.2.2 DESIGN ALTERNATIVES The purpose of the facility is to produce TRISO-based coated particle fuel. As described in Section 2.1.3, modern TRISO particle fuel technology is the product of particle fuel development activities spanning many countries during a half-century period. Alternatives to TRISO particle fuel technology would require decades to develop to maturity. Therefore, there are currently no reasonable alternatives to TRISO particle fuel. However, TRISO-X anticipates that the entire design of the TRISO-X FFF would consider the potential for automation where possible to optimize production and minimize cost in an industrial setting. It is not anticipated that such automation improvements would influence the fundamental production process but would instead improve production efficiency.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-39 Rev. 3 Table 2.2-1 (Sheet 1 of 2)

Evaluation Criteria for Candidate Sites No.

Description Weight A. Infrastructure and Utilities

1.

Site Utilities 7

2.

Highway Access 3

3.

Existing On-Site Infrastructure 10

4.

Access to Emergency Healthcare 8

B. Site Development

1.

Site Size and Topography 6

2.

Foundation, Earthwork and Pipe Installation Conditions 5

3.

Shallow Rock 3

4.

Groundwater Conditions 7

5.

Flood Protection 8

6.

Constructability 6

C. Seismic and Geotechnical Criteria

1.

Proximity to Active and Inactive Faults 9

2.

Seismic Hazards 10

3.

Settlement and Liquefaction Potential 7

4.

Karst, sinkholes and subsidence 7

D. Site Security

1.

Reserved

2.

Reserved

3.

Distance to Local Law Enforcement Agency (LLEA) 7 E. Land Use Issues

1.

Existing Land Use on the Site 6

2.

Existing Land Use within 1 Mile of the Site 4

3.

Zoning and Land Use Planning 8

4.

Parks and Recreation(a) 5

5.

Prime Farmland 5

F. Ecological Criteria

1.

Wetlands, Lakes and Streams 8

2.

Other Natural Habitats 6

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-40 Rev. 3 Table 2.2-1 (Sheet 2 of 2)

Evaluation Criteria for Candidate Sites a) These criteria apply to areas used primarily for human recreation, e.g., community parks, softball fields, swimming areas, etc.

b) These criteria apply to areas used primarily for management of ecological resources. The areas may be public, institutional (e.g., universities) or private lands (e.g., Nature Conservancy) and may or may not be open to the public. The areas may allow and provide facilities for recreational use.

No.

Description Weight

3.

Rare, Threatened and Endangered (RTE) Species 9

4.

Protected Natural Areas(b) 7

5.

Groundwater Impacts 8

G. Socioeconomic Criteria

1.

Community Acceptance (with input from X-energy) 10

2.

Historic and Cultural Resources 4

3.

Aesthetic and Noise Impacts 6

4.

Environmental Justice 7

5.

Socioeconomic Impacts 5

H. Other Hazards

1.

Aircraft Hazards 9

2.

Proximity to Hazardous Land Uses 7

3.

Proximity to Contaminated Properties 6

4.

Property Litigation 10

5.

Vehicle Controls 6

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-41 Rev. 3 2.3 CUMULATIVE EFFECTS Cumulative impacts result when the effects of an action are added to or interact with other past, present, and reasonably foreseeable future effects on the same resources. This section describes actions within the region surrounding the Horizon Center site (HCS) that, together with the effects of the construction, operation, and decommissioning of the HCS, may contribute to cumulative impacts to environmental resources. A cumulative impact is defined in current Council on Environmental Quality (CEQ) regulations (40 CFR 1508.1) as effects on the environment that result from the incremental effects of the action when added to the effects of other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-federal) or person undertakes such other actions. Cumulative effects can result from individually minor but collectively significant actions taking place over a period of time.

Table 2.3-1 identifies reasonably foreseeable future trends and planned actions that were identified to be in proximity to the HCS. Past and present actions inherently have environmental impacts that are integrated into the base condition for each of the resources as described in Chapter 3.

The geographic area of interest for consideration of cumulative effects is defined as the area where other actions occur that could potentially have impacts within the resource impact area.

Because the construction, operation and decommissioning of the TRISO-X Fuel Fabrication Facility (TRISO-X FFF) occurs on the HCS, a previously disturbed area designated for industrial use, the potential cumulative effects to off-site resources in the vicinity of the HCS is also limited for a number of resources. In contrast, the effects to other resources may be expressed beyond the immediate area surrounding the HCS. As such, the geographic area of interest is different for each resource.

The following sections provide a description of past and planned actions at the Horizon Center Industrial Park and within the broader area surrounding the HCS.

2.3.1 ACTIONS AT THE HORIZON CENTER INDUSTRIAL PARK The Horizon Center Industrial Park is a greenfield business park owned by the City of Oak Ridge Industrial Development Board, dedicated to industrial development. As shown in Figure 2.3-1, seven development areas are set amongst 500 acres of permanent natural area set aside for environmental preservation and protection. Development Area 6 has been identified as the preferred site for the TRISO-X FFF. The entirety of the land was owned by the U.S. Department of Energy (DOE) until 1996 when it was leased to the Community Reuse Organization of East Tennessee. The title was transferred to the current owner in 2003, with DOE retaining approximately half of the acreage for use as permanent greenspace. In 2020, the DOE expanded the available land uses for the seven development areas.

Among other small businesses, the Horizon Center Industrial Park is currently home to the DOEs Carbon Fiber Technology Facility (Development Area 3A) and Philotechnics (Development Area 6A). The City of Oak Ridge has identified carbon fiber and composites as one of its three main growth industries. Given this fact and the availability of additional sites at the Horizon Center Industrial Park, the City expects substantial future expansion of carbon fiber manufacturing at the industrial park, however specific projects have not been identified.

Philotechnics, a radiological services and mixed and radioactive waste brokerage provider, operates on the adjacent lot to the TRISO-X FFF.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-42 Rev. 3 X-energy is proposing the construction and operation of a Helium Test Facility (HTF) located within the Horizon Center Industrial Park, on the adjacent Development Area 7. As part of their development of a high-temperature gas-cooled small modular reactor (SMR), X-energy is required to test critical structures, systems, and components which would operate in a harsh, high-temperature helium environment in the reactor. The HTF will replicate the reactor environment, without the radioactive material, providing the required test conditions for verifying the performance of the SMR components. Construction of the facility is expected to commence in 2025 and take approximately 12 months. The facility would then operate for six years, with the possibility of extensions for up to an additional 20 years.

The City of Oak Ridge Electric Department (CORED) plans to expand electrical infrastructure to ensure 20 megawatts (MW) of electrical power is available to serve the Horizon Center Industrial Park, of which 15 MW will be reserved for TRISOXs use. Two new 10 MW transmission circuits are being added to the existing 10 MW circuit that currently serves the industrial park. The two 10 MW circuits will be added along the underground route of the current 10 MW circuit, utilizing existing rightofway from the CORED Blair Road substation to the Horizon Center Industrial Park, extending to the southwest corner of the property owned by TRISOX. Additionally, a future CORED substation will be constructed to serve TX-2 and the remainder of the undeveloped Horizon Center Industrial Park. The location of the new substation is on the east side of the Oak Ridge Turnpike (TN 95), opposite the Horizon Center Industrial Park. Four 10 MW circuits will be routed along an existing rightofway, overhead from the substation, across TN 95, along the right-ofway for Novus Drive, to the southwest corner of the property owned by TRISOX.

Previously, a motorsports park selected Development Areas 5, 6, and 7 at the Horizon Center Industrial Park for development and estimated a $50 million investment. The original proposal included a 4.5-mile track where car enthusiasts could race luxury cars up to speeds of 160 mph.

It was inspired by Barber Motorsports Park in Alabama. However, this proposal was withdrawn due to community opposition, zoning, and National Environmental Policy Act requirements, and has been relocated to another location in Cumberland County, Tennessee.

2.3.2 ACTIONS RELATED TO OTHER FACILITIES This section describes the reasonably foreseeable future actions in the vicinity of the HCS which could result in cumulative impacts when considered in conjunction with the construction, operation and decommissioning of the TRISO-X FFF. Actions identified within the geographic area of interest as having the potential to, in the aggregate, result in larger and potentially significant adverse impacts to the resources of concern are listed in Table 2.3-1. The analysis of the potential cumulative impacts of these actions by resource area is presented in Chapter 4.

To identify past, present, or reasonably foreseeable future actions which may be considered as part of a cumulative effects analysis, TRISO-X considered:

Information about current or planned local economic development programs or projects (e.g., commercial, industrial, and/or residential).

Information about current or planned infrastructure improvements (e.g., transportation, electric, and water utility).

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-43 Rev. 3 Information about other current or planned projects at nearby Federal facilities and within the nuclear industry.

Actions related to environmental remediation of facilities that were used for nuclear research, including the Manhattan Project, are presently planned or expected to occur in the reasonably foreseeable future. These facilities include the Oak Ridge National Laboratory (ORNL), East Tennessee Technology Park (ETTP) and the Y-12 National Security Complex (Y-12).The actions include remediation and construction at Y-12 (Oak Ridge Office of Environmental Management, 2019; National Nuclear Security Administration, 2020); remediation at ORNL (Oak Ridge Office of Environmental Management, 2019); remediation at ETTP (Oak Ridge Office of Environmental Management, 2019); ); construction of the Environmental Management Disposal Facility (EMDF) (DOE, 2021); and continued operation of a transuranic waste processing facility (Northwind Solutions LLC, 2021).

Other present or reasonably foreseeable future actions include a development project in downtown Oak Ridge (Oak Ridge Chamber of Commerce, 2020); construction and operation of a new water treatment plant for the City of Oak Ridge (City of Oak Ridge, 2017); construction and operation of SMR units at the Clinch River Nuclear site (NRC, 2019 and TVA, 2022);

operation of an emergency response training facility (Roane Alliance, 2020); and the construction of the Orano uranium enrichment facility (Orano, 2024). Additionally, several actions are planned to occur at the ETTP, including construction and operation of a low-power demonstration reactor (Hermes) and two low-power test reactors (Hermes 2) (Kairos Power, 2021; NRC, 2023); construction and operation of a proposed general aviation airport (City of Oak Ridge, 2021); and construction and operation of a medical isotope production facility (Coquí Pharma, 2019). The location of the proposed general aviation airport is being re-evaluated due to Oranos planned enrichment facility (City of Oak Ridge, 2024).

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-44 Rev. 3 Table 2.3-1 (Sheet 1 of 4)

Actions at Other Facilities Facility/Site Approximate Location Relative to the HCS site Description of Action Status of Action Comment Additional Development of the Horizon Center Industrial Park Adjacent Development of lots within the Horizon Center Industrial Park Potential Timeframe uncertain. No definitive development plans.

Helium Test Facility Adjacent Test facility to support small modular reactor design validation on 15-acre project site in Horizon Center Industrial Park.

Reasonably foreseeable.

Construction is expected to commence in 2025.

May overlap with construction and operation of the TRISO-X FFF Orano Uranium Enrichment Facility Across TN State Route 95 Construction of a state-of-the-art centrifuge uranium enrichment facility.

Reasonably foreseeable.

Operations anticipated to start in early 2030s No definitive timeline for construction. NRC pre-licensing meeting was completed in December 2024 Electrical Infrastructure Upgrades Opposite the Horizon Center Industrial Park Two new 10 MW transmission circuits are being added to the existing 10 MW circuit that currently serves the industrial park.

Additionally, a future CORED substation is planned for construction on the east side of the TN 95 and installation of four 10 MW overhead circuits to HCS.

Reasonably foreseeable Overlapping construction of the TRISO-X FFF Oak Ridge Enhanced Technology and Training Center (ORETTC) 0.9 mi. (1.5 km) east Operation of the ORETTC by DOE National Nuclear Security Administration to train first responders and other experts in nuclear operations, safeguards, and emergency response to support the National Security Enterprise.

Past, present, future.

Construction completed January 2023..

Operation will overlap with construction and operation of the TRISO-X FFF ETTP 2.3 mi. (3.6 km) southwest Continuing remediation activity and transfer of remediated facilities.

Past, present, future Operation will overlap with construction and operation of the TRISO-X FFF

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-45 Rev. 3 Table 2.3-1 (Sheet 2 of 4)

Actions at Other Facilities Facility/Site Approximate Location Relative to the HCS site Description of Action Status of Action Comment Kairos Reactor Demonstration at ETTP 2.3 mi. (3.6 km) southwest Construction and operation of a low-power demonstration reactor to support development of their fluoride salt-cooled, high-temperature reactor technology.

Past, present, future.

NRCs Final Environmental Impact Statement was released August 17, 2023.

Construction began July 2024.

Operation may overlap with construction and operation of the TRISO-X FFF Kairos Hermes 2 Reactor at ETTP 2.3 mi. (3.6 km) southwest Construction and operation of Hermes 2, consisting of two 35-MW reactors adjacent to the Hermes Test Reactor at ETTP.

Reasonably foreseeable.

Construction Permit issued by the NRC November 2024..

Construction and operation may overlap with construction and operation of the TRISO-X FFF USNC Pilot Fuel Manufacturing Operation /

ETTP 2.3 mi. (3.6 km) southwest Ultra Safe Nuclear Corporation (USNC) to site new Pilot Fuel Manufacturing operation, located on the ETTP, site of Manhattan Projects K-25 gaseous diffusion plant.

Past, present, future.

Operational as of August 2022.

Operation will overlap with construction and operation of the TRISO-X FFF Medical Isotope Production Facility 2.3 mi. (3.6 km) southwest Coquí Pharma construction of medical isotope facility.

Reasonably foreseeable.

Operational by 2025.

May overlap with construction and operation of the TRISO-X FFF Oak Ridge General Aviation Airport

/ ETTP 2.3 mi. (3.6 km) southwest Construction and operation by the City of Oak Ridge of a general aviation airport with a single 5,000 ft runway.

Approximately $22 million of the estimated

$55 million project cost has been made available.

Paused Planning phase.

Location is being re-evaluated due to Oranos planned enrichment facility

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-46 Rev. 3 Table 2.3-1 (Sheet 3 of 4)

Actions at Other Facilities Facility/Site Approximate Location Relative to the HCS site Description of Action Status of Action Comment Environmental Management Disposal Facility 3.4 mi. (5.4 km) east Proposed Landfill facility for disposal of Comprehensive Environmental

Response, Compensation, and Liability Act (CERCLA) low-level hazardous waste.

Under development.

Ground-breaking for the project occurred in 2023.

Operation will overlap with construction and operation of the TRISO-X FFF.

ORNL 4 mi. (6.4 km) southeast Continuing remediation of radiologically and chemically contaminated facilities. ORNL occupies approximately 4,470 acres and includes facilities in two areas Bethel Valley, which includes the central campus area of ORNL, includes reactor facilities, isotope production facilities, waste treatment facilities, and research facilities, and Melton Valley, which includes reactor facilities, research facilities, waste treatment facilities, and waste management areas.

Past, present, future Continued operation will overlap with construction and operation of the TRISO-X FFF.

TRU Waste Processing Center (TWPC) 4.8 mi. (7.7 km) southeast North Wind Solutions, LLC operates the Transuranic (TRU)

Waste Processing Center for the DOE Oak Ridge Office of Environmental Management to process and repackage ORNL legacy TRU waste and ship it off-site.

Past, present, future Continued operation will overlap with construction and operation of the TRISO-X FFF.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-47 Rev. 3 Table 2.3-1 (Sheet 4 of 4)

Actions at Other Facilities Facility/Site Approximate Location Relative to the HCS site Description of Action Status of Action Comment Clinch River Nuclear Site 5 mi. (8.1 km) southwest Construction and operation by Tennessee Valley Authority of an Advanced Nuclear Technology Park. The park would contain one or more advanced nuclear reactors with a cumulative electrical output not to exceed 800 megawatts electric for the site.

Reasonably foreseeable.

Early Site Permit issued by NRC in 2019.

Programmatic Environmental Impact Statement issued by TVA July 2022. Timing of construction/operation is unknown.

May overlap with construction and operation of the TRISO-X FFF Y-12 6.6 mi. (10.5 km) east Continuing remediation of contaminated facilities and mercury contamination in soil and groundwater. The following projects are proposed: West End Protected Area Reduction Project; Lithium Processing Facility; Calciner Project; and Electrorefining Project.

Past, present, future.

Planning and installation of the Calciner Project began in 2014 and is ongoing. Installation of the Electrorefining Project was scheduled to be complete in 2023. The West End Protected Area reduction project is scheduled for completion in 2025 The Lithium Processing Facility is scheduled for completion in 2031 and operation in 2034.

May overlap with construction and operation of the TRISO-X FFF City of Oak Ridge water treatment plant 7.3 mi (11.7 km) east New water treatment facility to be constructed at a location near the intake of the current water treatment plant.

Under development.

Expected to be operational by Spring 2025.

Operation will support operation of the TRISO-X FFF.

Downtown Oak Ridge 7.3 mi. (11.7 km) northeast Downtown Oak Ridge development project along the Wilson Street corridor. Project includes a mix of residential and retail development.

Reasonably foreseeable Planning phase.

Timeframe uncertain.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-48 Rev. 3 2.4 COMPARISON OF THE PREDICTED ENVIRONMENTAL IMPACTS As described in Section 2.2, evaluations have been performed for alternatives to the Proposed Action regarding technology, facility design, and location. The results of these evaluations have eliminated these alternatives from further consideration. Therefore, the comparison presented in this Report is that of the Proposed Action, under which the TRISO-X Fuel Fabrication Facility (TRISO-X FFF) is constructed and would produce TRISO-X fuel while minimizing potential adverse environmental impacts, against the No-Action Alternative, under which the TRISO-X FFF is not constructed. Reasonably foreseeable environmental impacts and the extent of those impacts from the Proposed Action, potential mitigation measures, and restoration actions, if applicable, are described in detail in the resource-specific sections of Chapter 4 of this Report (Environmental Impacts), as well as summarized earlier in Section 2.1.2.2. Table 2.4-1 details the comparison between the potential foreseeable environmental impacts for the Proposed Action, Alternative Sites, and No-Action Alternative.

As described in Section 2.2, during Phase 2 of the TRISO-X FFF site study an evaluation of the five candidate sites against 35 categories/evaluation criteria was presented in Appendix C of the report. The weighted scores found in Appendix C of the Site Study of each candidate site for the impact categories listed in Table 2.4-1 were used to assign the foreseeable environmental impacts. SMALL, MODERATE, and LARGE environmental impacts were assigned to each of the impact categories of the Alternative Sites presented in Table 2.4-1. Sites that received a high weighted score in an impact category during the site study were listed as having SMALL potential impacts in Table 2.4-1, whereas sites that received a low weighted score in an impact category during the site study were listed as having of LARGE potential impacts in Table 2.4-1.

Sites that received a moderate weighted score in an impact category during the site study were listed as having of MODERATE potential impacts in Table 2.4-1.

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-49 Rev. 3 Table 2.4-1 (Sheet 1 of 2)

Comparison of the Predicted Environmental Impacts Impact Category Proposed Action Alternative Sites No-Action HCS Oak Ridge, TN Centrus ACP Piketon, OH Centrus TMC Oak Ridge, TN GE/GNF-A Wilmington, NC SRS Energy Park Aiken, SC Land Use SMALL SMALL SMALL SMALL MODERATE SMALL Transportation SMALL SMALL SMALL SMALL MODERATE SMALL Geology and Soils SMALL SMALL SMALL SMALL to LARGE SMALL SMALL Water Resources SMALL SMALL SMALL MODERATE SMALL SMALL Ecology SMALL SMALL SMALL to MODERATE SMALL to MODERATE SMALL to MODERATE SMALL Air Quality SMALL SMALL SMALL SMALL SMALL SMALL Noise SMALL SMALL MODERATE MODERATE SMALL SMALL Historic and Cultural Resources SMALL SMALL SMALL SMALL SMALL SMALL Visual/Scenic SMALL SMALL MODERATE MODERATE SMALL SMALL Socioeconomics SMALL to MODERATE SMALL SMALL SMALL MODERATE SMALL

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 2-50 Rev. 3 Table 2.4-1 (Sheet 2 of 2)

Comparison of the Predicted Environmental Impacts Impact Category Proposed Action Alternative Sites No-Action HCS Oak Ridge, TN Centrus ACP Piketon, OH Centrus TMC Oak Ridge, TN GE/GNF-A Wilmington, NC SRS Energy Park Aiken, SC Environmental Justice SMALL MODERATE SMALL MODERATE SMALL SMALL Public and Occupational Health SMALL SMALL SMALL SMALL SMALL SMALL Waste Management SMALL SMALL SMALL SMALL SMALL SMALL

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives January 2025 Rev. 2 Figure 2.1-1 Overall Site Layout

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives March 2025 Rev. 1 Figure 2.1-2 Water Balance Diagram

Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives September 2022 Rev. 0 Figure 2.3-1 City of Oak Ridge Industrial Development Board Development Areas