Text

Clinch River Nuclear Site Construction Permit Environmental Audit Summary Report
	ML25272A190
Person / Time
Site:	05000615
Issue date:	10/06/2025
From:	Nagel M; NRC/NMSS/DREFS/EPMB3
To:	Daniel Barnhurst; NRC/NMSS/DREFS/EPMB3
References
	Download: ML25272A190 (1)
	v • d • e

Enclosure

SUMMARY

REPORT ON THE ENVIRONMENTAL AUDIT OF CLINCH RIVER NUCLEAR SITE CONSTRUCTION PERMIT APPLICATION Docket No. 50-0615 1.0

Background

The U.S. Nuclear Regulatory Commission (NRC) is currently reviewing an application from Tennessee Valley Authority (TVA) for a construction permit (CP) for a nuclear power plant facility, based on the GE Hitachi BWRX-300 reactor design to be located in Roane County, Tennessee. As part of its review, the NRC is preparing a supplement to NUREG-2226, Environmental Impact Statement for an Early Site Permit (ESP) at the Clinch River Nuclear Site, (hereafter referred to as the SEIS). An audit was conducted from July 14, 2025, to September 15, 2025, to support the environmental review of TVAs CP application. This report presents a summary of the audits objectives and activities, and information that was obtained as a result of audit activities.

1.1 Application Overview By letters dated April 28, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25118A209) and May 20, 2025, (ADAMS Package Accession No. ML25140A062), TVA submitted the CRN Site CP application including an Environmental Report (ER). By letter dated June 12, 2025, the NRC accepted part one of TVAs CP application (ADAMS ML25156A058). A notice of acceptance for docketing of the complete application was published in the Federal Register on July 15, 2025. The Notice of Intent to prepare a SEIS was published in the Federal Register on July 18, 2025.

1.2 Project and Site Overview The proposed action is for the NRC to issue a CP to TVA authorizing construction of the CRN-1 reactor. In its CP application, TVA proposes to build and operate CRN-1 to demonstrate key elements of the BWRX-300 technology for possible future commercial deployment. The technology is an advanced nuclear reactor technology that leverages a water-cooled, natural circulation system. The proposed site is situated at the CRN Site, a previously disturbed site, and adjacent to land owned by the U.S. Department of Energy (DOE). The CRN Site CP ER provides TVAs analyses of the environmental impacts that could result from building, operating, and decommissioning the BWRX-300 reactor at the proposed site.

2.0 Audit Scope and Objectives During the audit, the staff discussed environmental matters related to land use, ground and surface waters, terrestrial and aquatic ecology, postulated accidents, radiological and non-radiological health, radiological and non-radiological waste, cultural resources, socioeconomics, alternatives to the proposed action, air quality and noise. The audit allowed the staff to better understand the site, environmental interfaces of the project, and modeling results in order to make appropriate environmental findings.

In its initial review of data and information within the corresponding context of the CP ER, the staff identified information needs that would promote a better understanding of the detailed analyses and bases underlying the CP application. These items were included in Attachment 1 of the audit plan presented to TVA in advance (ADAMS ML25189A385). Audit activities consisted of document reviews, virtual meetings organized in advance, and a few impromptu

2 discussions as documented herein. Additional resource discussions included cost-benefit, water resources, air quality, and ecology. These activities assisted the NRC, Pacific Northwest National Laboratory (PNNL), U.S. Army Corps of Engineers (USACE), DOE, and TVA staff in resolving the information needs that were outlined in the plan.

Table 1 of this report presents a list of the NRC and PNNL staff participating in the audit and their associated SEIS review areas. Table 2 presents a list of TVA staff and its contractors who participated in the audit. Table 3 presents a list of the USACE and DOE staff that participated in the audit discussions.

Table 1. List of Review Team Members Function or Review Area NRC Staff PNNL Staff Team Leads Madelyn Nagel Rajiv Prasad, Kimberly Leigh Accidents Donald Palmrose Jonathan Napier, Josh Hargraves Air Quality and Meteorology Nancy Martinez Saikat Ghosh Alternatives Brian Glowacki Katherine Cort Benefit Cost Jeffrey Rikhoff Lin Zeng, Michelle Niemeyer Cultural and Historic Jennifer Davis Cyler Conrad Ecology - Aquatic Peyton Doub Caitlin Wessel Ecology - Terrestrial Peyton Doub Dana Vesty Geology Gerry Stirewalt Rebecka Iveson Hydrology - Groundwater Gerry Stirewalt Rebecka Iveson Hydrology - Surface Water Brian Glowacki Kazi Tamaddun, Rajiv Prasad Land Use/Visual Resources Caroline Hsu Dana Vesty, Katherine Cort Non-Radiological Health Donald Palmrose Kimberly Leigh, Hayley McClendon Socioeconomics Jeffrey Rikhoff Lin Zeng, Michelle Niemeyer Table 2. List of TVA Staff and Contractors

a.

Tennessee Valley Authority

b. Sargent and Lundy

c.

WSP Todd Amacker a Walter Justice a Sean Pfeiffer b Ester Andrews a Evan Katzke a Andrew Rahn a Tyler Baker a Paul Kerr a Natalie Reiss c Jack Bryant a Laura Klein b Will Ross a Steve Cole a Mike Launi b Ray Schiele a David Daigle a Kenneth McMahan a Ed Schulte a Bill Elzinga c Laura Merwin b Jared Scott b Carol Freeman a David Mitchell a Owen Scott a Daniel Geren a Kelvin Montague a Jennifer Smith a Maggie Gilliland a Jennifer Myers a Jim Thorton a Elizabeth Hamrick a Chelsey Nieman c Konrad Quast c Dakota Huddleston a Dominic Norman a Jacob Wall a John Henry Sullivan Jr. a James Norris a Carrie Williamson a Steven Hilmes a Jeffrey Padgett a Ivan Zujovic a

3 Table 3. List of Other Federal Representatives Name Organization Cara Beverly USACE Timothy Dodson USACE Steve Cooke DOE Jayashree Jayaraj DOE Marla Larson-Williams DOE Tyler Walker DOE Jill Fortney DOE

4 3.0 Summary of Audit Activities and Issues Addressed During the first two weeks of the audit, an audit kickoff meeting and 16 breakout sessions were conducted virtually where the NRC and TVA staff discussed the 55 information needs that had been provided to TVA in the audit plan. For the remaining period of the audit, the NRC staff continued to examine supporting documents and hold follow-up discussions as needed. The NRC staff determined that responses to several items would be needed on the docket and TVA agreed to provide that information in response to one Request for Additional Information (RAI) and several Requests for Confirmatory Information (RCIs). Additionally, staff requested three studies to be submitted on the docket. By letter dated July 24, 2025, TVA provided the requested studies in support of the audit (ADAMS ML25205A137).

During the audit, the NRC staff identified the need for an additional groundwater analysis to evaluate potential impacts associated with the proposed onsite quarry and resulting long-term dewatering. The potential onsite quarry is considered new and significant information because it was not proposed or evaluated during the ESP proceedings. The NRC staff conducted a simple analysis and reviewed the results with TVA. These findings were incorporated into the draft SEIS.

Table 4 presents a tabulated summary of how the information needs presented to TVA in the audit plan were addressed. In summary, 16 of the 55 audit items were closed through audit discussions and the NRC staffs review of the supporting material. Thirty-nine items were resolved through TVAs response to RCIs. RCIs were submitted to TVA on July 30, 2025 (ADAMS ML25211A359) and August 7, 2025 (ADAMS ML25219A273).

Staff submitted one RAI to TVA on July 25, 2025 (ADAMS ML25204A049).

4.0 Audit Closeout Meeting The NRC and TVA staff conducted 3 status meetings during the virtual audit weeks on July 18, July 25 and July 29, 2025. The NRC staff reiterated the purpose of the audit, discussed the audit activities and the information still needed to close all audit items. TVA shared their expected timeframe for providing the agreed upon submittals expected to close the remaining items. The audit formally closed on September 15, 2025, after receipt of all information from TVA regarding the RCIs and RAI.

5.0 Post Audit Follow-up and Current Review Status As summarized in Table 4 TVA responded to RCIs and to close out those audit information needs requiring that particular information be submitted to the docket. By letter dated August 12, 2025, TVA provided their response to the NRC staffs RCIs (ADAMS ML25224A191). By letter dated August 12, 2025, TVA provided their response to the NRC staffs RAI (ADAMS ML25224A161). The NRC staff determined that all information was provided by TVA to adequately close all audit items.

To date, the staff has not identified any new information requiring additional RCIs or RAIs.

5 Table 4: Summary of Audit Information Need Resolution Information Need ID Regulatory Basis Information Needed Resolution General GEN-1 10 CFR 51.45(d)

Please provide a knowledgeable person(s) to discuss status for all permits/authorizations in Table 1.5-2 and Table 1.5-3 of the ER, such as Clean Water Act 401 Certification, Clean Water Act Section 404 permit, USACE Section 408 permit, Rivers and Harbors Act Section 10 permit, and air permits.

Closed Through Request for Confirmatory Information (RCI-GEN-1)

ML25224A191 GEN-2 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person to discuss the interchange area at TN-58 and Bear Creek Road, the T-line corridor, the possible tunneling in the river/reservoir for the intake, and a future independent spent fuel storage installation (ISFSI).

Closed Through Request for Confirmatory Information (RCI-GEN-2)

ML25224A191 New and Significant Review Process NS-1 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the new and significant information review process. Discuss (1) how new information was identified, (2) how it was compared to information available during the ESP proceedings, and (3) the metrics and/or logic used to categorize new information as confirmatory or as notable.

To facilitate this discussion, consider the following examples of new information listed in the ER:

1. Watts Bar Reservoir characteristics including water surface elevations, bathymetry, sediment transport characteristics, and other physical attributes,

2. Seasonal trends in groundwater elevations, flow paths, gradients, and velocities,

3. Hydrologic alterations to Watts Bar Reservoir from building intake and discharge structures and associated mitigation measures for unavoidable

impacts,

4. Aquatic ecology of the Watts Bar Reservoir, and

5. In-migrating workforce for building activities and related community infrastructure and services.

Closed Through Request for Confirmatory Information (RCI-NS-

1) ML25224A191

6 Information Need ID Regulatory Basis Information Needed Resolution NS-2 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the new and significant information review process related to reasonably foreseeable future actions.

Closed Through Request for Confirmatory Information (RCI-NS-

2) ML25224A191 Site Layout and Plant Structures SL-1 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the updated project setting related to principal land uses (e.g., habitat protection area), transmission corridor and site utilization plan.

Closed Through Request for Confirmatory Information (RCI-SL-

1) ML25224A191 SL-2 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the updated facility utilities including reactor power conversion system, plant water use, cooling systems, and cooling system components.

Closed Through Audit Discussion SL-3 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the discharge construction, excavation and dredging, and the riprap wall used to protect the discharge pipes.

Closed Through Request for Confirmatory Information (RCI-SL-

2) ML25224A191 SL-4 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the location and design of the intake structure and any changes between the ESP and the construction permit ER.

Closed Through Request for Confirmatory Information (RCI-SL-

3) ML25224A191 Land Use and Visual LU-1 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the timber harvesting of the 161-kV transmission corridor.

Closed Through Request for Confirmatory Information (RCI-LU-

1) ML25224A191 LU-2 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the amount and disposition of spoils and dredged material.

Closed Through Audit Discussion LU-3 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the potential CRN site quarry permanent and temporary impacts.

Closed Through Request for Confirmatory Information (RCI-LU-

2) ML25224A191 LU-4 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the offsite rights for the 161-kV transmission corridor.

Closed Through Audit Discussion LU-5 10 CFR 51.50(c)(1),

Please provide a knowledgeable person(s) to identify and discuss lands owned by the Closed Through Request for

7 Information Need ID Regulatory Basis Information Needed Resolution 10 CFR 51.92(e)

DOE, future plans, and offsite land rights.

Confirmatory Information (RCI-LU-3, 4) ML25224A191 LUTE-1 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss building activities within streams, wetlands and floodplains and visual intrusion from the 161 kV transmission line.

Closed Through Request for Confirmatory Information (RCI-LUTE-1)

ML25224A191 Meteorology and Air Quality MET-1 Clean Air Act, 10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss quantified greenhouse gas emissions and criteria pollutant emissions and its precursors from 1.) building activities (preconstruction and NRC authorized construction); 2.) vehicular traffic (worker vehicles, delivery vehicles) during operations, and 3.) air quality impacts from these activities. This information is needed per Section 176(c) of the Clean Air Act.

Closed Through Request for Confirmatory Information (RCI-MET-3)

ML25224A191; Request for Additional Information (RAI-MET-1)

ML25224A161 MET-2 10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss new and significant information related to greenhouse gas and criteria pollutant emissions during operations; emissions from cooling towers and auxiliary systems; cooling tower plume, fogging, icing, and salt deposition; emissions from new transmission lines; and associated calculations and assumptions for these estimates.

Closed Through Request for Confirmatory Information (RCI-MET-1, 2, 5)

ML25224A191; Request for Additional Information (RAI-MET-1)

ML25224A161 MET-3 10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss new and significant information related to the local climate, meteorological measurements, and extreme weather.

Closed Through Audit Discussion MET-4 10 CFR 51.45(d)

Please provide a knowledgeable person(s) to discuss air permits associated with building activities.

Closed Through Audit Discussion MET-5 10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss currently available design details of the cooling tower(s) including its location.

Closed Through Audit Discussion MET-6 10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss quantified greenhouse gas emissions, criteria air pollutant emissions, and vehicle and truck shipments associated with quarry operations.

Closed Through Request for Confirmatory Information (RCI-MET-4)

ML25224A191; Request for Additional Information (RAI-

8 Information Need ID Regulatory Basis Information Needed Resolution MET-1)

ML25224A161 Geology GEO-1 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss new geotechnical borings that confirm karst settings.

Closed Through Request for Confirmatory Information (RCI-GEO-1)

ML25224A191 Hydrology - Surface Water SW-1 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss updated reservoir surface elevation, bathymetric mapping, surface water delineation (e.g., dimensions) and functional assessment, drainage areas, and slope profiles in the affected environment section.

Closed Through Request for Confirmatory Information (RCI-SW-1, 2 and 3)

ML25224A191 SW-2 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss updated hydrologic alterations to onsite and offsite streams, ponds, and wet-weather conveyances (either temporary or permanent) during construction.

Closed Through Request for Confirmatory Information (RCI-SW-

4) ML25224A191 SW-3 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss floodplain encroachment and construction practices to adhere to Executive Order 11988.

Closed Through Request for Confirmatory Information (RCI-SW-

5) ML25224A191 SW-4 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss water quality effects of plant effluents including explanation of figures showing normal and maximum flow rate of the blowdown stream from cooling water systems to the Reservoir.

Closed Through Request for Confirmatory Information (RCI-SW-

6) ML25224A191 Hydrology - Groundwater GW-1 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the potential onsite quarry, specifically the construction extent and method, groundwater levels in the vicinity of the quarry (new monitoring and updated water quality data), anticipated rate of dewatering for construction and operation, and whether the pit will become an onsite reservoir.

Closed Through Request for Confirmatory Information (RCI-GW-

1) ML25224A191 GW-2 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the closure and abandonment of wells.

Closed Through Request for Confirmatory Information (RCI-GW-

9 Information Need ID Regulatory Basis Information Needed Resolution 2, 3) ML25224A191 Aquatic Ecology AE-1 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the 2022 and 2023 aquatic biota surveys that TVA conducted.

Closed Through Audit Discussion AE-2 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss STR09 (where/which water body it is), Grassy Creek, and other streams in the 161-kV transmission line corridor.

Closed Through Audit Discussion AE-3 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the new information that was identified for aquatic ecology in the Watts Bar Reservoir.

Closed Through Request for Confirmatory Information (RCI-AE-1, 6, and 7)

ML25224A191 AE-4 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss habitat descriptions and/or surveys for the new streams identified in the new 161 kHz transmission right-of-way (ROW) (STR09, STR17).

Closed Through Request for Confirmatory Information (RCI-AE-

2) ML25224A191 AE-5 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss TVA's streamside management zone provisions to reduce impacts to the surrounding areas.

Closed Through Request for Confirmatory Information (RCI-AE-3, 4, and 5)

ML25224A191 Terrestrial Ecology TE-1 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss pertinent communications with TDEC regarding the State status of affected wetlands, including those in the proposed ROW for the new 161-kV transmission line and the proposed mitigation plan for jurisdictional wetlands.

Closed Through Audit Discussion TE-2 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the habitat conversions from forested to scrub/shrub or herbaceous.

Closed Through Request for Confirmatory Information (RCI-TE-

1) ML25224A191 TE-3 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the vegetation management practices and the differences if the Sherwood injunction stands versus if the injunction is lifted.

Closed Through Request for Confirmatory Information (RCI-TE-

2) ML25224A191 TE-4 10 CFR 51.50(c)(1),

Please provide a knowledgeable person(s) to discuss the sustainability measures to be Closed Through Request for

10 Information Need ID Regulatory Basis Information Needed Resolution 10 CFR 51.92(e) implemented including pollinator habitats and land management practices.

Confirmatory Information (RCI-TE-

3) ML25224A191 TE-5 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the chemical components added to the cooling water (particularly the sulfuric acid).

Closed Through Audit Discussion TE-6 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the basis that no habitat for the white fringeless orchid and Virginia spiraea have been observed onsite or in the proposed 161-kV transmission line ROW during the vegetation surveys.

Closed Through Audit Discussion TE-7 10 CFR 51.50(c)(1),

10 CFR 51.92(e)

Please provide a knowledgeable person(s) to discuss the locations of the mist nest surveys and the gray bat and tricolored bat capture locations.

Closed Through Request for Confirmatory Information (RCI-TE-

4) ML25224A191 Historical and Cultural Resources HC-1 36 CFR 800.4, 36 CFR 800.5 Please provide a knowledgeable person(s) to discuss when the updated design schedule for the interchange area at TN-58 and Bear Creek Road and Barge Traffic Area (BTA) areas will be finalized, including a description of construction activities within the Clinch River at the BTA. This information is required to understand potential effects to historic properties and impacts to historic and cultural resources for the proposed project. This information is needed per Title 36 of the Code of Federal Regulations (36 CFR) Section 800.4 and 36 CFR 800.5 for identifying the area of potential effects and assessing potential effects.