ML25294A145

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Project Long Mott Docs - Lmgs Draft RAIs - Revision 1
ML25294A145
Person / Time
Site: 05000614
Issue date: 10/21/2025
From:
NRC
To:
NRC/NMSS/DREFS
References
Download: ML25294A145 (11)


Text

From:

Joe OHara Sent:

Tuesday, October 21, 2025 10:35 AM To:

Milton Gorden; ext_Mark_Feltner; ProjectLongMott-EnvPUBLICem Resource Cc:

Stephanie Yazzie; ext_Jared_Wicker; Robert Hoffman; ext_Dave_Goodman; ext_Hayley_McClendon

Subject:

LMGS Draft RAIs - Revision 1 Attachments:

Long Mott Draft RAIs - Revision 1.xlsx Good afternoon, Based upon our discussion on Tuesday October 14th, attached please find draft Request for Additional Information (RAI) Revision 1 which adds ACC-5 for your information and consideration and eliminates the request for the SWPPP in AE-4. There are 10 potential RAIs.

The NRC does not intend to issue formal RAIs (or RCIs) by letter until the week of October 26th. The draft RAIs are subject to change based upon our discussions and any supplemental information we receive prior to October 26th.

If you have any questions whatsoever, please contact me.

R/

Joe OHara Environmental Project Manager U.S. Nuclear Regulatory Commission Environmental Review Project Management Branch

Hearing Identifier:

XeDOW_ProjectLongMott_EnvPublic Email Number:

29 Mail Envelope Properties (DM8PR09MB648726B8181F96B691ABA2E1EEF2A)

Subject:

LMGS Draft RAIs - Revision 1 Sent Date:

10/21/2025 10:34:37 AM Received Date:

10/21/2025 10:34:41 AM From:

Joe OHara Created By:

Joe.OHara@nrc.gov Recipients:

"Stephanie Yazzie" <syazzie@x-energy.com>

Tracking Status: None "ext_Jared_Wicker" <>

Tracking Status: None "Robert Hoffman" <Robert.Hoffman@nrc.gov>

Tracking Status: None "ext_Dave_Goodman" <>

Tracking Status: None "ext_Hayley_McClendon" <>

Tracking Status: None "Milton Gorden" <mgorden@x-energy.com>

Tracking Status: None "ext_Mark_Feltner" <>

Tracking Status: None "ProjectLongMott-EnvPUBLICem Resource" <ProjectLongMott-EnvPUBLICem.Resource@nrc.gov>

Tracking Status: None Post Office:

DM8PR09MB6487.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 753 10/21/2025 10:34:41 AM Long Mott Draft RAIs - Revision 1.xlsx 33710 Options Priority:

Normal Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

Review Area Air Quality AQ-4 Accidents ACC-5 Alternatives ALT-5 Aquatic Ecology AE-1 Aquatic Ecology AE-4 Historic and Cultural Resources HCR-4

Hydrology - Surface Water SW-14 Land Use LU-2 Terrestrial Ecology TE-13 Waste Management - Non Radiological WNR-1

Information Need Post-Audit Status Please provide information on emissions during pre-construction and construction. While emission factors by vehicle type were provided, no data on total use of these was provided. Some mechanism to determine the total emissions during construction and pre-construction should be added. (10 CFR 51.45(c) and ESRPs 4.4.1, 5.3.2.1, and 5.3.3.1)

RAI Please provide an updated Table 5.13.1-12 that is consistent with PSAR Table 3.2-5 providing both the safety dose, air dispersion conversion factor, and environmental dose. Please indicate if the calculated environmental dose is on a per module or total module basis for each DBA sequence.

RAI Please clarify the comparative acreages of Sites A, B, C, and D. If Site A is the Proposed Site, then according to Sec 4.3.1 it is 1537 acres, of which appr. 721 acres would be disturbed. Site B is reported as 235 acres, Site C as 166 acres, and Site D as 193 acres. Yet in Figure 9.3-1, Site A does not appear to be several times bigger than Sites B, C, or D.

RAI Please provide any report(s) and data from the macroinvertebrate and fish surveys conducted in 2023 and 2024 that supported development of Tables 2.4-9 and 2.4-10. (ESRP 2.4.2)

RAI Please provide additional information (e.g. flow rates, grates and spacing, trash racks and spacing, temperature data, etc.) on the existing intake and discharge structures for the Seadrift Plant, the new pump station and water intake structure on the GBRA Calhoun Canal to provide water via Basin #5, digital, zoomable maps showing location of each structure, and copies of the current TPDES permit and SWPPP.

(ESRP 2.4.2)

RAI Confirm that the Phase I archaeological survey results are documented in two separate reports: (1) August 1, 2023 Hunter and Cantrell, Xe-100 Dow Seadrift Site Phase I Intensive Archaeological Survey, Calhoun County, Texas Negative Finding Short Report, and (2) February 19, 2024 Hunter and Cantrell, Phase I Intensive Archaeological Survey for the Proposed Project Long Mott, Calhoun County, Texas - Negative Finding Report (provided in Enclosure 6 of the ER)...

RAI

  • New*

Potential RAI may be resolved via box posting. 10/8/25.

Provide NRCS Form AD-1006 completed for the site.

Explain key assumptions used in completing the form.

Provide copies of key correspondence with the NRCS, if any.

RAI Per section 7(a)(2) of the Endangered Species Act, the NRC is required to examine all potential direct and indirect impacts of the Federal action on federally listed species. To fulfill this requirement, please complete the USFWS Northern Long-Eared Bat and Tricolored Bat Range-Wide Determination Key (https://ipac.ecosphere.fws.gov/) and provide a copy of the answers.

RAI Per Regulatory Guide 4.2, Revision 3, Section 3.4.3, please provide an estimate of the quantities of solid nonhazardous waste generated during construction.

RAI

Relevant Notes from Audit RAI for scaling information.

RAI - sites were evaluated early during feasibility, which did not account for additional footprint that was added as project went on (e.g, adding laydown yards and other extras). If Site A is used, it would grow into Site B. Stephanie says Site A is the proposed site; but there are different acreages identified throughout she said they will likely need a breakout to discuss.

RAI for acreage clarifications.

Caitlin - all information she needs is in the document provided via TE-12. RAI to make this document publicly available Post-audit note: LME noted that this permit has been withdrawn, so this will need to be an RAI after all RAI for August 2023 report. The August and February reports paint a complete picture for H&C review (figures in newer report dont show older testing from Aug one).

Already have the February 2024 one.

Stephen to write a new info need to cover above question (SW-14).. reliable vs. firm supply.

Potential RAI of NRCS correspondence unless publicly available.

RAI for DKey results RAI - LME should provide scaling information regarding solid non-hazardous waste

RAI Please provide 1) the estimated emissions generated during LMGS construction from the various sources identified in ER Section 4.4.5.3, or 2) some mechanism to supplement the ER information and determine the total LMGS construction emissions, or 3) bounding estimates, with an appropriate basis, for LGMS construction emissions.

Please provide an updated Table 5.13.1-12 that is consistent with PSAR Table 3.2-5 providing both the safety dose, air dispersion conversion factor, and environmental dose. Please indicate if the calculated environmental dose is on a per module or total module basis for each DBA sequence.

Please clarify the comparative acreages of Sites A, B, C, and D described in Chapter 9 of the ER. If Site A is the Proposed Site, then according to Sec 4.3.1 it is 1537 acres, of which appr. 721 acres would be disturbed. Site B is reported as 235 acres, Site C as 166 acres, and Site D as 193 acres. Yet in Figure 9.3-1, Site A does not appear to be several times bigger than Sites B, C, or D.

Please provide SL-XEN-2024-135_PLM_Ecological_Resources_Tech_Report_Rev_1.pdf Please provide the current TPDES permit.

RAI: Please submit a copy of the August 2023 archaeological report written by WSP to the docket for NRC to reference in the EA. The August 2023 report was requested because the figures in the February 2024 report do not provide the shovel testing conducted in the August 2023 survey, nor does it provide the results of the archaeological survey described in the August 2023 report.

Regarding estimated reliable surface volume for the six GBRA/Dow water rights, page 2.3-3 reports a TCEQ estimated firm water supply of 8,870 acre-feet per year while Table 2.3.1-10 lists 159,719 acre-feet per year as reliable. Additionally, Table 2.3.1-10 lists the minimum annual supply for the GBRA/Dow rights at ~33,700 acre-feet/year, of which ~12,000 acre-feet per year are associated with permitted industrial uses. Please clarify the differences between firm, reliable, and minimum annual supply for the GBRA/Dow water rights.

Please provide the NRCS Form AD-1006 completed for the site and any other copies of key correspondence with the NRCS, if any.

RAI: Please provide the completed USFWS Northern Long-Eared Bat and Tricolored Bat Range-Wide Determination Key for the project.

Please provide an estimate of the quantities of solid nonhazardous waste that will be generated during the construction of the LMGS.

SME Notes