ML25322A134
| ML25322A134 | |
| Person / Time | |
|---|---|
| Site: | Triso-X |
| Issue date: | 11/11/2025 |
| From: | Creswell W Roane County, TN, Office of the County Executive |
| To: | Office of Administration |
| References | |
| NRC-2022-0201, 90FR48508 00006 | |
| Download: ML25322A134 (1) | |
Text
PUBLIC SUBMISSION As of: 11/18/25, 8:33 AM Received: November 12, 2025 Status: Pending_Post Tracking No. mhw-5dxw-yf0k Comments Due: December 08, 2025 Submission Type: Web Docket: NRC-2022-0201 Notice of Intent to Conduct Scoping Process and Prepare Supplement to Draft Environmental Impact Statement TRISO-X Fuel Fabrication Facility Comment On: NRC-2022-0201-1774 TRISO-X, LLC; Special Nuclear Material License Application for the TRISO-X Fuel Fabrication Facility; Draft Environmental Impact Statement Document: NRC-2022-0201-DRAFT-1778 Comment on FR Doc # 2025-19646 Submitter Information Email:wade.creswell@roanecountytn.gov Government Agency Type:Local Government Agency:Roane County Government General Comment Roane County Government submits the attached document prepared by the Roane County Environmental Review Board on November 11, 2025. Triso-X is located within Horizon Center, a business park located within the county's boundaries. We ask that you consider and address the comments provided herein for the benefit of all associated with the project.
Attachments Comments TRISO EIS Nov2025-Roane County Government 11/18/25, 8:33 AM NRC-2022-0201-DRAFT-1778.html file:///C:/Users/BHB1/Downloads/NRC-2022-0201-DRAFT-1778.html 1/1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD Jill Caverly, Antoinette Walker-Smith, Mary Neely Comment (6)
Publication Date:
10/23/2025 Citation: 90 FR 48508
PO Box 643 Kingston, TN 37763 865.376. 5578 Office of the County Executive info@roanecountytn.gov www.roanecountytn.gov Comments on:
Draft Environmental Impact Statement for the TRISO-X Special Nuclear Material License Application for a Fuel Fabrication Facility (ML25267A128)
Prepared by:
Roane County Environmental Review Board November 11, 2025 General Comments:
- 1. There is excessive need for general public reviewers to refer to TRISO-Xs Environmental Report submitted as part of the licensing application and subsequent clarifications for understanding of the proposed operations and activities. Simplified process diagrams and flowcharts in the draft environmental impact statement would be helpful.
- 2. The Environmental Report and responses by the applicant to requests for additional information reveal a monitoring program that is more complex than indicated in the draft environmental impact statement. Oversight and independent monitoring by Tennessee Department of Environment and Conservation is recommended.
- 3. More graphics such as block and simplified process flow diagrams to describe the applicants processes and to track the wastes and effluents would make the environmental impact statement a useful reference document to the public.
Specific Comments:
- 1. P. 2-2, section 2.1.1.1: Please include the quantities of water that will be needed to support facility operations.
- 2. P. 2-3, section 2.1.1.3: The use of excavated material (dirt/soils) as landscaping features or otherwise used onsite (e.g., backfill as much as possible) should be considered. The removal and trucking of 560,243 cubic yards of material to offsite landfills is an unnecessary use of transportation and fuel resources, not to mention filling up offsite landfills. (It is realized that some grading and clearing has already begun.)
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- 3. P. 2-9, section 3.1.3: Class A waste will be containerized and sent for offsite disposal.
Liquid waste will result from processing operations, and either be reused or sent for offsite disposal. Please describe the potential quantities of Class A or liquid wastes being sent offsite or where it will be sent (in state or out of state).
- 4. p. 3-8 and 3-9, section 3.2.2: Please state whether the six ventilation stacks, that would rise approximately 100 feet above ground level, will require flashing warning lights. If so, please discuss the visual impact this will have.
- 5. P. 3-10, section 3.3.1.1: Some meteorological data are from 1981-2010. Other data are no more recent than 2020. Use of more recent data is needed to follow the effects of climate change/global warming.
- 6. p. 3-30; section 3.4.2.1, p. 3-43, section 3.5.2.1.1, p. 3.-47, section 3.5.2.2.1: Heavy rain during spring 2025 resulted in excessive runoff which overflowed barriers set up during site preparation. Please discuss what additions, or changes to, the stormwater management system have been considered to prevent soil erosion and sediment and stormwater runoff in context of more anticipated heavy rain events.
Additionally, new impacts to karst features need to be evaluated and mitigated, such as new sinkholes and depressions. This can lead to further impacts related to Section 3.4.2.2 Operation. Construction may be impacted, and groundwater patterns can be altered.
- 7. p. 3-32, section 3.4.4.2: Similar to the above comment, due to probability of heavy rain events, have any changes been made to the best management practices designed for erosion prevention and sediment controls?
- 8. P. 3-37, section 3.5.1.1.2: Surface water use describes withdrawal rates for Kingston and Rockwood Water Systems from 2010. This is outdated and not representative of water use downstream of the TRISO site. More recent data are needed.
- 9. Pp. 3-37 and 3-43/44, sections 3.5.1.1.3 and 3.5.2.1.1: Please describe how drainage from the TRISO site is monitored for possible migration of contaminations to East Fork Poplar Creek (EFPC), both during construction and operation. It is possible that both hazardous and radioactive contaminants can migrate downslope to EFPC. EPA drinking water standards have already been found to exceed TDEC criteria. It is unknown how TRISO activities can contribute to further EFPC contamination.
- 10. P. 3-44, section 3.5.2.1.2: Similar to comment 11, please consider that monitoring of water in stormwater detention basins may be necessary.
- 11. p. 3-42, section 3.5.1.3: The maximum 100-year flood elevation in the vicinity of the HCS and the lowest ground elevation at the HCS are the same at 760 feet.
3 of 3 Considering the increased rain events expected due to climate change, what are the levels above sea level expected for the construction sites?
- 12. p. 3-49, section 3.5.3: Please state when TRISO-X will be required to have both a sinkhole mitigation plan and the effluent monitoring plan in place and active.
- 13. p. 3.72, section 3.8.2: Noise levels are discussed as individual point sources but during construction, multiple trucks, equipment, etc. will be operating simultaneously. Please include an estimate of how many noise sources will be potentially operating at the same time during peak construction and the impact on surrounding areas, especially the North Boundary Greenway Trail.
- 14. p. 3-78, section 3.9: Disposition maps or block diagrams for each type of waste or effluent would be helpful to understand the impacts of waste generation and waste and effluent management.
- 15. p. 3-86, section 3.10.1: The first two paragraphs list several chemicals that will be onsite. However, there needs to be a listing identifying each hazardous chemical and radionuclide present at the facility, including specifications for trace impurities in the nuclear source material. Also, please include the maximum amount of radioactive material that will be at the facility during peak operation. Without more specifics on chemical identities and quantities, Section 3.13 is not very informative.
- 16. P. 3-86, section 3.10: The second paragraph states that a number of chemicals will be released at up to, or greater than, 10 tons per year. Does TRISO-X really mean that pollutant emissions from storage are not controlled any better than those amounts?
- 17. p. 3-91, section 3.11: Only the main roads connected to the HCS are listed. All transportation needs better descriptions of potential routes throughout the region for each aspect of construction and operation. For example, routes for soil removal and the backfill source; routes for construction materials; routes for rad materials and waste. (It is understood that you cannot predict worker commutes). While impacts on primary roads might be minimal, those on secondary and tertiary roads could be major.
Where is excavated soil going to? Where is backfill coming from?
P. 3-98 and 3-99 state that HALEU U3O8 will come from Ohio, and the uranyl nitrate will come from SC. To get by truck to the HCS probably requires going through Knoxville, TN via interstates 75 and 40. Please include impacts to Knoxville in the transportation analyses of these materials.
- 18. Table 3.12-1, p. 3-102: The last column header should be Percent Change 2010-2020 (not 2010-2010).
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- 19. Section 3.13: The evaluation of cumulative impacts together with other proposed projects is admittedly difficult to maintain as additional projects are being announced; however, the assessment presented seems based on highly qualitative reasoning and judgment rather than results of modeling that could be performed.
Please include some description/details of the Integrated Safety Assessment (ISA),
perhaps as an appendix, to give the reader an idea of assumptions behind the conclusions of this section.
For clarification of any of these comments or if you have additional information or questions related to this document, please contact me at wade.creswell@roanecountytn.gov or call (865)376-5578.
Sincerely, Wade Creswell Roane County Executive
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