ML25252A008
| ML25252A008 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 09/19/2025 |
| From: | Ashley Waldron NRC/NMSS/DREFS/EPMB1 |
| To: | Coleman J Southern Nuclear Operating Co |
| References | |
| EPID L-2024-LNE-0000 | |
| Download: ML25252A008 (1) | |
Text
Jamie M. Coleman Regulatory Affairs Director Southern Nuclear Operating Co., Inc.
3535 Colonnade Parkway, N 274.EC Birmingham, AL 35243
SUBJECT:
EDWIN I. HATCH PLANT, UNITS 1 AND 2 -
SUMMARY
OF ENVIRONMENTAL AUDIT RELATED TO THE ENVIRONMENTAL REVIEW OF THE LICENSE RENEWAL APPLICATION (EPID NUMBER: L-2024-LNE-0000) (DOCKET NUMBER: 50-321 AND 50-366)
Dear Jamie Coleman:
A review team consisting of staff from the U.S. Nuclear Regulatory Commission (NRC or the staff) participated in a virtual audit during the week of August 25, 2025, for the Edwin I. Hatch Nuclear Plant, Unit 1, as part of the license renewal application environmental review. The goal of the audit was to gather information to ensure that the environmental requirements for license renewal, as codified in Title 10 of the Code of Federal Regulations (10 CFR) Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, were met. The audit plan was provided to Southern Nuclear Corporation (SNC) by letter dated July 28, 2025 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML25202A167)
An entrance meeting was held on August 26, 2025, to introduce participants and discuss audit logistics. During the remainder of the audit, the NRC staff, supported by Pacific Northwest National Laboratory (PNNL) staff, participated in smaller groups (breakout sessions) with SNC and Enercon Services, Inc. (Enercon) representatives to address the audit needs identified in the audit plan. Enclosure 1 of this letter provides a list of representatives from NRC, PNNL, SNC, and Enercon who participated in the audit.
At the conclusion of the audit, the NRC staff summarized the status of the review with SNC and Enercon representatives during the exit meeting held on September 5, 2025. Many of the NRCs questions identified in the audit plan or during the audit were answered throughout the audit.
Those questions that were answered but would be needed to be used in the environmental assessment could be submitted (a) as responses to requests for additional information (RAIs),
or (b) as responses to requests for confirmation of information (RCIs). to this letter contains the staffs RAIs and RCIs. We are requesting SNCs responses to our requests within 30 days of receipt of this letter.
September 19, 2025
J. Coleman 2
While the NRC staff did not identify any significant environmental issues during this audit, the staff indicated the environmental review was ongoing and that any information necessary to support the review would be formally requested via the RAI process in the future.
If you have any questions, please contact me via email at Ashley.Waldron@nrc.gov.
Sincerely, Ashley N. Waldron Environmental Project Manager Environmental Project Management Branch 1 Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards Docket Nos. 50-321; 50-366
Enclosures:
As stated Signed by Waldron, Ashley on 09/19/25
ML25252A008 OFFICE PM:EPMB1 LA:REFS BC:EPMB1 PM:EPMB1 NAME AWaldron AWalker-Smith SKoenick AWaldron DATE 9/18/2025 09/18/2025 09/18/2025 09/19/2025 List of Participants Edwin I. Hatch Nuclear Plant, Unit 1 Subsequent License Renewal Application Environmental Review Audit August 2025 Nuclear Regulatory Commission (NRC)
Team Member Title/Discipline Ashley Waldron Environmental Project Manager Beau Goldstein Historic and Cultural Resources Bill Rautzen General/Overview Bradley Werling Air Quality Donald Palmrose Human Health, Spent Nuclear Fuel Gerry Stirewalt Groundwater Lloyd Desotell Surface Water Mitchell Dehmer Aquatic Resources Nancy Martinez Noise, Greenhouse Gases and Climate Change Noah Rebecca Human Health, Spent Nuclear Fuel Shannon Healy Terrestrial Resources Steve Koenick Environmental Review Supervisor Pacific Northwest National Laboratory (PNNL)
Team Member Title/Discipline Dan Nally Project Manager Phillip Meyer Groundwater Southern Nuclear Corporation (SNC)
Team Member Title/Discipline Abby Henry HNP Environmental Specialist, Sr.
Amy Aughtman Capital Projects Licensing Manager Brad Creek SLR Electrical Lead Brad Dean SLR Engineering Manager Brandon Marlow SLR Project Manager Casey Groce Environmental Specialist, Lead Clay Channel Fleet Dry Cask Storage Senior Manager Jim Delano Environmental Affairs Manager Jim Ozier Environmental Specialist, Sr.
Lindsey Grissom SLR Licensing and Environmental Engineer Michael Todd SLR Mechanical Lead Tony Dodd Environmental Specialist, Sr.
Will Phillips Fleet Dry Cask Storage Supervisor Yasmeen Arafeh Environmental Specialist, Sr.
Katherine Kosalko (Georgia Power)
Environmental Specialist, Sr.
2 Enercon Services (Enercon)
Team Member Title/Discipline Ben Barton Notetaker Betsy Tangora Historic and Cultural Resources Cheyenne Riggs Virtual Tour, Terrestrial Resources Emily Keenan General, Human Health, Spent Nuclear Fuel Fred Woolridge Virtual Tour Jay Hemmis Aquatic and Terrestrial Resources Jennifer Meek Groundwater and Surface Water Jerry Riggs Air Quality, Green House Gas/Climate Change Lisa Hendrick Project Support Sharon Chavez Noise Stacy Burgess Sr. Manager Environmental Licensing HATCH NUCLEAR PLANT UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW REQUESTS FOR CONFIRMATION OF INFORMATION Regulatory Basis Licensees are required by Title 10 of the Code of Federal Regulations (10 CFR) Part 51.53(c)(1) to submit with its application a separate document entitled Applicant's Environmental Report Operating License Renewal Stage. The U.S. Nuclear Regulatory Commissions (NRC) regulations at 10 CFR Part 51, which implement section 102(2) of the National Environmental Policy Act of 1969, as amended (NEPA), include requirements for applicants to provide information as may be useful in aiding the NRC staff in complying with NEPA. As part of its review, the NRC staff will prepare an environmental assessment (EA). Review guidance for the staff is provided in NUREG-1555, Supplement 1, Revision 2, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Supplement 1 - Operating License Renewal.
Requests for Confirmation of Information (RCIs)
The letter to Jamie Coleman, Regulatory Affairs Director, Edwin I. Hatch Nuclear Plant, Units 1 and 2, dated July 28, 2025 (Agencywide Documents Access and Management System ML25202A167), contained an audit plan for Hatch Nuclear Plant (HNP), which included a list of information needs with unique identifiers. During the environmental audit, the NRC staff reviewed documents that were made available on the applicants electronic information portal in response to the staff audit needs. The staff also participated in breakout sessions with applicant personnel for certain resource areas to gather information that will likely be referenced in the EA. To the best of the staffs knowledge, this information on the applicants electronic information portal and discussed in breakout sessions is not currently on the docket or publicly accessible. The NRC staff requests that the applicant provide confirmation that the information gathered from the audit listed below is correct or provides the associated corrected information.
1.
RCI GEN-1 10 CFR Part 51.53(c)(iv) requires that environmental reports contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware. The NRCs environmental document will include the permits and licenses issued by Federal, State, and local authorities for activities at HNP as identified in Table 9.1-1 of the ER, dated May 15, 2025 (ML25135A392). The NRC staff must consider whether there have been any changes to operating permits or other requirements. Please confirm the following updates to Table 9.1-1 that have occurred since the environmental report (ER) was submitted in May 2025. The updates to those permits (including updated permits and those administratively extended) are shown in italics.
2 2.
RCI GEN-2 As discussed during the audit, and as a result of Southern Nuclear Corporations (SNC) new and significant information review and results identified in Section 5 of the ER, please confirm no new and significant information was identified for Category 1 issues regarding the environmental impacts of the SLR for HNP.
3.
RCI AQ-1 Please confirm the units for the annual air emissions values in ER Table 3.3-9 are tons/year where one ton is 2,000 pounds.
4.
RCI AQU-1 Please confirm that there are currently no biofouling agents utilized by SNC for controlling invasive aquatic species at or near the intake and discharge.
5.
RCI GHGCC-1 As discussed during the environmental audit and in response to audit information need GHGCC-1, please confirm that SNC does not have continuous long-term intake cooling water temperature data.
6.
RCI GHGCC-2 As discussed during the environmental audit and in response to audit information need GHGCC-2, please confirm that SNC has not conducted thermal discharge studies that account for potential increases in water temperature in the Altamaha River due to climate change.
Table 9.1-1 UPDATES Environmental Authorizations for Current HNP Operations Authority Requirement Facility/Permit Number Expiration Date Authorized Activity 40 CFR 107 Subpart G Hazardous Materials Certificate of Registration Reg. No.
062525550250H Expiration:
June 30, 2026 Hazardous materials shipments.
Georgia Water Quality Control Act, OCGA
§ 27-2-12 Scientific Collecting Permit Permit No.
1000524483 Expiration: March 31, 2026 Allows take of non-listed freshwater fish under certain conditions.
Georgia R&R Chapter 750-3-.01 Certification Operator ID: W3-017389 Expiration: June 30, 2027 Operate non-transient, non-community public water system.
3 7.
RCI GHGCC-3 As discussed during the environmental audit and in response to audit information need GHGCC-3, please confirm:
Table 3.13-1 of the ER accounts for air permit combustion sources under the term Generators.
GHG data presented in Table 3.13-1 for mobile vehicles and air permit combustion sources was collected from EPAs Combined Air Emissions Reporting System EPAs Combined Air Emissions Reporting System did not have GHG data for mobile vehicles and air permit combustion source for HNP for the year 2019.
8.
RCI NOI-1 As discussed during the environmental audit and in response to audit information need NOI-1, please confirm that the nearest resident is 4,858 ft (0.92 miles) west-southwest from the turbine building and 5,122 feet (0.97 mi) from the cooling tower.
9.
RCI NOI-2 As discussed during the environmental audit and in response to audit information need NOI-2, please confirm SNC has not received noise complaints between January 2023 and August 2025.
10.
RCI NOI-3 As discussed during the environmental audit and in response to audit information need NOI-3.
Please confirm SNC has not conducted offsite noise assessments in the vicinity HNP and confirm the following with respect to onsite noise surveys:
Sound pressure levels taken inside the Turbine Building have ranged 82-97 dBA Sound pressure levels taken at roof and ground level of the cooling towers have ranged 71-90 dBA 11.
RCI GW-2 Please confirm the following table of 2024 groundwater withdrawals.
2024 Groundwater Withdrawals Monthly Max 7.45 MGal/mo 178.34 gpm Monthly Avg 6.15 MGal/mo 140.18 gpm Monthly Min 5.15 MGal/mo 119.24 gpm Yearly Total 73.82 MGal/yr 0.20 MGD 12.
RCI GW-5 Please confirm the following:
There have been no reportable nonradiological spills since December 2023.
4 13.
RCI GW-6 Please confirm the following:
There have been no unplanned radionuclide releases or abnormal liquid releases impacting soil or groundwater from 2024 to present that required any external notification.
- 14. RCI GW-08 Please confirm the following:
As documented in Table 2-1 of the Hatch Groundwater Monitoring Plan for Radionuclides V.
1.1 report provided for staff inspection, a radionuclide release occurred on 9/29/2011 in Area 2 involving a leak from the liquid radwaste processing system; the system was ultimately replaced with above-ground piping. The historical maximum tritium concentration in a groundwater sample at Hatch of 6,840,000 pCi/L in September 2011, as documented in ML24320A014, is attributable to the 9/29/2011 release.
As documented in Section 3.9 of the Hatch Groundwater Monitoring Plan for Radionuclides V. 1.1 report provided for staff inspection, groundwater quality in the vicinity of the condensate storage tanks may be monitored more frequently than required by the Groundwater Protection Program to provide timely detection of inadvertent releases. A monitoring well can show spikes that the GWPP samples do not identify. A spike occurred in 2021 with a maximum tritium concentration of about 1,500,000 pCi/L in well T-15 as determined by the more frequent leak detection sampling (shown in the file HNP Selected Trend Graphs 2019-2023.pdf provided for staff inspection), and a maximum quarterly sample tritium concentration of 215,000 pCi/L as reported in the 2021 ARERR (ML22118B159).
14.
RCI HCR-1 Please confirm the following:
Annual cultural resources sensitivity training is provided to timber harvesting staff and provided to maintenance and construction staff as appropriate.
15.
RCI HCR-2 Please confirm the following:
If any ground disturbance is planned at HNP, Environmental Affairs for Georgia Power is contacted and applicable procedures are followed, on a project-by-project review basis.
Bell Cemetery has not been subject to an official delineation. However, the boundary of the cemetery has been historically well established. Furthermore, monitoring has been conducted for projects near the cemetery, and no findings related to the cemetery have been identified outside the cemetery fence line
5 16.
RCI HCR-5 From the information gathered during the audit, please confirm that the following statement is correct:
ER Section 3.8 (page 3-200) states that a literature review was conducted through Georgias Natural, Archaeological, and Historic Resources Geographic Information System (GNAHRGIS).
This review was conducted in 2023 in preparation of the ER and was subsequently confirmed by SNC staff in 2025 as still accurate.
- 17. RCI HCR-9 From the information gathered during the audit, please confirm that the following statement is correct:
If there is a discovery situation involving human remains, appropriate parties, including federally recognized Tribes, will be notified in compliance with applicable local, state, and federal regulations. Georgia Power employs a professional archaeologist that has stop work authority and is responsible for contacting Tribes, as appropriate.
18.
RCI HH-1 Please confirm the following:
During routine inspections of in-scope transmission lines, no sag or other changes to the lines have been observed that would warrant a reevaluation of the 1998 Environmental Field Study Plan of Hatch Nuclear Plant or the 1999 Engineering Study on Short Circuit Currents.
19.
RCI HH-3 Please confirm the following:
Employees working in cooling water systems are briefed on safe work practices to protect against Legionella bacteria and N. Fowleri amoebae.
20.
RCI TER-1 Please confirm the main stack, the MET tower, the backup MET tower, Unit 1 and Unit 2 turbine buildings, Unit 1 and Unit 2 reactor buildings, and microwave tower are the only structures on site greater than 100 feet above ground level. Please also confirm that the backup MET tower is guyed and the Microwave Tower is free-standing (not guyed). Additionally, please confirm the lighting regimes are as follows:
a.
Main stack: steady burning red marker and flashing red beacon lighting at night. Flashing white beacon lighting in day. In the event that the beacon should fail at night, that beacon will be forced into white night back-up mode. That beacon will continue to flash in a low power white mode, keeping the structure illuminated.
b.
MET tower: a steady red beacon is located on top of the MET tower. Two obstruction lights are located at 1/3 tower height and two obstruction lights are located at 2/3 tower height (four total lights).
c.
Backup MET tower: one steady red light on top of the tower.
d.
Unit 1 and Unit 2 turbine buildings: no exterior lights.
6 e.
Unit 1 and Unit 2 reactor buildings: the buildings have lamp post style lighting (steady, white) mounted on top of the roof.
f.
Microwave tower: one blinking white light on top of the tower.
21.
RCI TER-2 Please confirm that herbicide and pesticide use on site will be targeted and utilized for aesthetic and safety purposes, and that no herbicides or pesticides are anticipated to be used within forested portions of the site.
22.
RCI TER-3 Please confirm the following statement:
Additional onsite activities include selective tree thinning, prescribed fire activities, and food plot planting. These forest management activities occur on approximately 1,963 acres of the HNP site for the purpose of timber production and beneficial wildlife habitat management. Forest management activities are conducted in partnership with the Georgia Department of Natural Resources (GA DNR) and are designed to maintain and improve existing gopher tortoise habitat onsite. Additionally, an informal agreement between SNC and the Boy Scouts of America allows for scouting groups to utilize the 100-acre Boy Scout camp area onsite located west of US-1.
The Boy Scouts would utilize this area on occasion for low impact camping activities. These activities are not associated with HNP operations and are expected to continue whether or not HNP continues operation.
23.
RCI TER-4 Please confirm that mowing that is associated with HNP operations occurs within the grass-maintained portions of the HNP site boundary.
24.
RCI TER-5 Please confirm that there have been no reported bird incidents associated with HNP operations from 2015 to August 2025. Additionally, please confirm that the three bird mortalities mentioned in Section 3.7.1.2.7 of the ER occurred over 10 miles from HNP and were not associated with plant operations.
25.
RCI TER-6 Please confirm that the removal of meso-mammal predators from gopher tortoise habitat is not an ongoing management activity, has not previously been implemented, and is not anticipated to occur during the SLR term.
26.
RCI TER-7 Please confirm that all eight mechanical draft cooling towers (MDCT) are equipped with drift eliminators and that there have been no observable effects on vegetation in the vicinity of these MDCTs.
27.
RCI TER-8 Please confirm the following statements specific to SNCs management plans:
The Biodiversity Initiatives Plan was provided to NRC staff to review. This plan endeavors to promote the growth and regeneration of quality hardwood stands within the managed forest on site. The Timber Management Plan endeavors to prioritize wildlife management while maintaining an economically viable forest.
7 Forestry and other operations are kept at a minimum within 300 feet of the Altamaha River and sloughs and wetlands are protected with proper stream zone management when forestry operations occur in nearby areas.
Prescribed burning occurs on a two-to-five-year rotation and is used in pine and pine-hardwood stands to reduce forest floor litter and herbaceous competition, decrease wildfire, insect and disease problems and to stimulate growth in the pine stands.
The Natural Resources - Wildlife Guideline was provided to NRC staff to review. This plan provides guidance for legal compliance, best management practices, and procedures for handling concerns and issues relating to wildlife when necessary. Additional protections are included in this plan for rare and protected species, including tree clearing restrictions and species specific BMPs.
The Excavation, Trenching and Shoring plan was provided to NRC staff to review. This plan includes directions to contact HNP environmental personnel for any excavation work that could result in the disturbance of wetland areas. Additionally, water pumped out of an excavation must be routed to prevent dirt and debris from entering surface waters.
28.
RCI SNF-1 Please confirm the following:
SNC has sufficient capacity for its spent fuel on its current pad until 2028 when the proposed expansion is scheduled to be completed.
29.
RCI SW-2 Please confirm the following:
HNP has implemented its drought contingency plan in the past as described below:
In 2014 to 2015, the river level was 62.5 feet above mean sea level (MSL) on several occasions. During these times, monitoring was performed, and a river projection was completed. The average days was >30 days to reach 61.2 feet MSL.
In October 2016 through December 2016, the river level was monitored weekly due to the river projection being <30 days to reach 61.2 feet MSL.
River projections were completed in September 2019 because the river level was 62.5 feet MSL. The river level projection was >30 days before reaching minimum specifications.
In October 2019, another river projection was completed, and the river level reached a low of 61.2 feet MSL, which is greater than the technical specification limit of 60.5 feet MSL.
In June 2022, a river projection was completed due to the river level falling 62.5 feet MSL. The river projection showed that the average number of days before reaching 61.2 feet MSL was >30 days.
HNP has not requested supplemental water be released from upstream lakes (e.g. Lake Sinclair, Lake Oconee or Lake Jackson) in response to drought conditions.
Additionally, please confirm the following analysis conducted by HNP staff regarding the potential aquatic impacts of implementing a supplemental flow release from Sinclair Dam, as described in the drought contingency plan:
SNC evaluated the aquatic impacts of a 24-hour, 500 cfs supplemental flow release from Sinclair Dam to support HNP during severe drought, triggered when river levels fall to 61.1 ft
8 MSL. Drought conditions reduce water depth, raise temperatures, and lower dissolved oxygen, stressing aquatic habitats. The supplemental flow would cause a minor, temporary rise in river elevation (0.8 ft) and velocity, but could offer ecological benefitssuch as re-wetting margins, improving water quality, and supporting aquatic species behavior. Sessile species like mussels may benefit from restored feeding conditions, while mobile species could relocate to better habitats. SNC concluded the release would have minimal adverse effects, outweighed by natural drought impacts, and could briefly benefit the aquatic community.
30.
RCI SW-3 Please confirm the following:
The values depicted in ER Figure 2.2-1 Water Balance Figure represent the maximum NPDES Permit GA0004120 discharge rates and the maximum surface water withdrawal rates based on Surface Water Withdrawal Permit No. 001-0690-01.
The consumptive use of surface water by the cooling towers is contemplated in the Georgia Environmental Protection Division (GA EPD) surface water withdrawal permit and not included in Figure 2.2-1. Additionally, groundwater withdrawals for plant make-up water and potable water (maximum permitted values of 1.1 million gallons per day monthly average withdrawal and 0.550 million gallons per day annual average) are not included on the figure and are included in the NPDES permitted discharges.
This does not include de minimis volumes of groundwater used via septic tanks and firewater used for training purposes. The difference between the discharge volumes and the monthly surface water withdrawal volumes represent cooling tower consumption volumes.
31.
RCI SW-4 Please confirm the following:
HNP has not had any power reductions over the past 5 years to meet thermal discharge limits.
32.
RCI SW-12 Please confirm the following regarding the SNC Drought Contingency Plan:
If a decision has been made to utilize the supplemental water release and the necessary agreements have been put in place, the following actions are recommended:
At 61.1 feet MSL, GPC Power System Coordinator will be contacted to deliver an additional 500 cfs of flow from Sinclair Dam for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> After 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the additional flow should be reduced to 100 cfs.
Additionally, water released from Sinclair dam is estimated to take approximately 7 days to reach HNP.
33.
RCI SW-13 Please confirm that no specific water conservation activities planned at this time, however these activities are always under consideration.
9 HATCH NUCLEAR PLANT UNITS 1 AND 2 SUBSEQUENT LICENSE RENEWAL APPLICATION ENVIRONMENTAL REVIEW REQUESTS FOR ADDITIONAL INFORMATION 1.
RAI AQU-01 REQUIREMENT: The NRC regulation at 10 CFR Part 51.53(c)(3)(ii)(A) requires that if the applicants plant utilizes cooling towers or cooling ponds and withdraws makeup water from a river, an assessment of the impact of the proposed action on water availability and competing water demands, the flow of the river, and related impacts on stream and riparian ecological communities must be provided. Additionally, 10 CFR 51.41(c) requires that licensees submit information that may be useful in aiding in the Commission in complying with the National Environmental Policy Act (NEPA) with information in an environmental report that should contain sufficient data to aid the Commission in its development of an independent analysis.
ISSUE: On August 26, 2025, NRC staff conducted a virtual audit with SNC staff. The NRC staff discussed several aquatic studies related to the site to better understand SNCs analysis related to 10 CFR 51.53(c)(3)(ii)(a) and as a result, the NRC staff request these aquatic studies to understand the current stream and riparian ecological communities.
REQUEST: Please provide copies of the following document(s):
APC (Alabama Power Company). 2024. Edwin I. Hatch Nuclear Plant, Instream Temperature Study. Environmental Affairs-Field Services. Calera, AL. September.
SNC (Southern Nuclear Company). 2022. Clean Water Act 316(b) Supporting Information Regarding NPDES No. GA0004120. Birmingham, AL. April.
SNC (Southern Nuclear Company). 2021. Biological Assessment of Effects on the Endangered Atlantic Sturgeon (Acipenser oxyrinchus oxyrinchus) and Endangered Shortnose Sturgeon (Acipenser brevirostrum). Appling County, GA. November.
GPC (Georgia Power Company). 2009. Plant Hatch Discharge Siltation Study Topographic Survey and Cross-Sections. Atlanta, GA. February.
GDNR (Georgia Department of Natural Resources). 2023. Candidate Conservation Agreement (CCA) for Mollusks of the Altamaha River Basin, Georgia. Georgia Department of Natural Resources Wildlife Resources Division. March.
2.
RAI HH-02 REQUIREMENT: 10 CFR 51.53(c)(3)(i) requires the ER to include impacts of operation during the renewal term, for those issues identified as Category 2 issues in appendix B to subpart A of 10 CFR part 51. In addition, 10 CFR 51.53(c)(3)(iv) indicates that an applicants ER must contain any new and significant information regarding environmental impacts of license renewal of which the applicant is aware.
ISSUE: SNC consulted with GA EPD regards to concerns about any waterborne disease associated with HNPs thermal discharges. A response letter dated May 9, 2025 was received by SNC from GA EPD concurring with SNCs conclusion that the HNP subsequent license renewal would not increase the number of deleterious thermophilic microorganisms to levels that would cause a public health problem.
10 REQUEST: Please provide a copy of the GA EPDs May 9, 2025 letter concerning thermophilic microorganisms discharged by HNP.
3.
RAI HCR-07 REQUIREMENT: Section 106 of the National Historic Preservation Act (NHPA [54 USC
§306108]) directs Federal agencies to take into account the effect of the undertaking on any district, site, building, structure, or object that is included in or eligible for the National Register of Historic Places within the area of potential effect (APE). NHPAs implementing regulations 36 CFR § 800.4(1) directs Federal agencies to identify historic properties, including background research, consultation, oral history interviews, sample field investigation, and field survey. In 36 CFR § 800.1(c), federal agencies must complete the Section 106 process prior to the issuance of any license. 10 CFR 51.53(c)(3)(ii)(K) requires All applicants shall identify any potentially affected historic and cultural resources and historic properties and assess whether continued operations and any planned refurbishment activities would affect these resources in accordance with the Section 106 of the National Historic Preservation Act and in the context of the National Environmental Policy Act. In addition, 10 CFR 51.53(c)(3)(iv) requires that The environmental report must contain any new and significant information regarding the environmental impacts of license renewal of which the applicant is aware.
ISSUE: The NRC staff is performing an environmental review that will analyze the environmental impacts of subsequent license renewal for HNP. As part of the environmental document preparation, the staff must consider the aforementioned regulatory requirements. ER Section 3.8.3 states. "An architectural survey of the HNP property was completed in June 2024This architectural survey and its results were submitted to the Georgia state historic preservation officer (SHPO) in July 2024, with no response received as of December 2024.
REQUEST: The NRC requests that SNC provide a letter affirming that the architectural report was submitted to SHPO in July 2024 and that no changes or revisions to the report have occurred since submittal to SHPO. If revisions or changes have occurred to the architectural survey report, provide the revised report preparation date and updated date of submittal to SHPO. Furthermore, provide any correspondence sent to SHPO and received from SHPO.
4.
RAI SW-01 REQUIREMENT: CWA Section 401 [33 U.S.C. 1341(a)(1)] states: No license or permit shall be granted until the certification required by this section has been obtained or has been waived as provided in the preceding sentence. No license or permit shall be granted if certification has been denied by the State, inter-State agency, or the Administrator, as the case may be.
Therefore, NRC cannot issue its license without a 401 certification or an NRC determination that a waiver has occurred, in accordance with 40 CFR 121.9(c).
ISSUE: On August 26, 2025, NRC staff conducted a virtual audit with SNC staff. SNC staff indicated that SNC staff requested a 401 Water Quality Certification from GA EPD on May 16, 2025, and expects that certification to be issued within a few weeks.
REQUEST: Please provide a copy of the 401 Water Quality Certification letter from GA EPD when it has been issued.