ML25328A159
| ML25328A159 | |
| Person / Time | |
|---|---|
| Site: | 99902121 |
| Issue date: | 12/21/2025 |
| From: | Sayoc E NRC/NRR/DNRL/NLIB |
| To: | |
| Shared Package | |
| ML25328A157 | List: |
| References | |
| Download: ML25328A159 (0) | |
Text
Duke Energy Early Site Permit (ESP) Application Readiness Assessment Observations on the ESP Draft Site Safety Analysis Report (SSAR) and the Draft Environmental Report (ER)
Comments on Draft SSAR Section Basis for Observation/Comment Readiness Assessment Observations Chapter 2 - Site Characteristics and Site Parameters Chapter 2, Section 2.4.10 NUREG-0800 SRP 2.4.10 In the ESPA SSAR Section 2.4.10 should be updated to clarify conformance to Reg Guide 1.59, Regulatory Position 1, to include a separate consideration for flood protection and site drainage requirements with the resulting local intense precipitation (LIP). Section 2.4.10.2 should also be updated to clarify that LIP will be assessed, and once the reactor technology has been selected, the site grading and drainage will be designed to prevent LIP from impacting safety-related SSCs.
Chapter 2, Section 2.4.13 NUREG-0800 SRP 2.4.13 The ESPA should clearly describe the selection of source term for the accidental release scenario and the assumptions related to subsurface transport attenuation parameters Kd. The current analysis is based on particle tracking without radionuclide specific Kd values.
Chapter 11 - Radioactive Waste Management Chapter 11 52.17(a)(1)(ii)
The ESPA should clarify the location of the inhalation values in Table 11.3.3-6. In particular, are these values assuming inhalation at the site boundary, the nearest residence, or elsewhere?
Chapter 13 - Conduct of Operations Chapter 13 52.17(b)(2) (ii) or (i)
The draft ESPA (Chapter 13 of SSAR and Part 5) states that the ESP includes a complete and integrated emergency plan (EP) for review and approval under 10 CFR 52.17(b)(2)(ii). In contrast, the staff observes that the draft Part 5 EP reflected a major features EP under 10 CFR 52.17(b)(2)(i). The ESPA should correct this apparent discrepancy.
Chapter 15 - Accident Analysis Chapter 15, Sections 15.1, 12.2 10 CFR 52.17 The application considers several different reactor designs including light water reactor (LWR) and non-LWR designs. Section 15.2 indicates that the source term is based on an instrument line break accident and modeled as an instantaneous release. Section 15.1 indicates that the accident resulting in the most limiting dose was used as the surrogate source term.
The ESPA should contain additional information regarding the most limiting accident and the accidents that were considered. Specific discussion points should include verification that the most limiting accident is an instrument line break, clarification which reactor design is this, and what is the type of the instrument line break.
Chapter 15 10 CFR 52.17(a)(1)(ix) 10 CFR 52.17(a)(1)(ix) requires in part that the application must include a description and safety assessment of the site on which a facility is to be located and that it must contain an analysis and evaluation of the major structures, systems, and components of the facility that bear significantly on the acceptability of the site under the radiological evaluation factors identified. The regulation also specifies that the applicant shall assume a fission product release from the core. A footnote to the requirement specifies in part that the fission product release assumed for this evaluation should be based on a hypothesized major accident that has generally been assumed to result in substantial meltdown of the core.
In reviewing Chapter 15, the description of the event addressing 10 CFR 52.17(a)(1)(ix) and the assumptions made for this analysis is very limited and does not appear to contain enough information for staff to evaluate if the regulation has been met. In addition, based on the discussion, it is
unclear if the event and release assumed in the analysis is adequate to address the requirement, as it is unclear that the event adequately addresses the requirement of considering a fission product release from the core from a major hypothesized accident. The ESPA should provide appropriate clarification and details, including whether the Maximum Hypothetical Accident (MHA) Loss-of-Coolant Accident (LOCA) discussed in RG 1.183 assumed for the LWR designs.
Chapter 15 10 CFR 52.17(a)(ii) 10 CFR 52.17(a)(ii) requires that the application contain the anticipated maximum levels of radiological and thermal effluents each facility will produce.
It did not appear that the application includes a discussion of how the effluent released from the facility were developed. The ESPA should at least include a general discussion of how the effluent release values were determined and what they represent.
Chapter 17 - Quality Assurance Chapter 17 10 CFR 50, Appendix B The ESPA should resolve the following gaps that were identified between regulatory Quality Assurance (QA) requirements and Dukes Quality Assurance Program Description (QAPD): a) QAPD lacks a construction QA program, b) 17.5.4.2 mentions taking exception to lead auditor qualifications without specifying what the exception was, and c) exceptions for procurement document control were mentioned but there were not sufficient details to address 10 CFR Part 21 requirements.
Comments on Draft ER Section Basis for Observation/
Comment Readiness Assessment Observations Chapter 2 - Proposed Site and Affected Environment Chapter 2, Section 2.2.1.1.3.1.2 NUREG 1555, ESRP 5.3.2.1 Chapters 2 and 3 discuss a hydrologic model, which was used to evaluate the characteristics of Belews Lake to predict future hydrological details, however, the ER does not provide additional information or
details regarding this model. The NRC requests Duke to include this information in the ER.
Chapter 3 - Site Layout and Project Description Chapter 3, Section 3.2.2.4.2:
10 CFR 31.50(b)(2) 10 CFR 31.50(b)(2) states, The environmental report must address all environmental effects of construction and operation necessary to determine whether there is any obviously superior alternative to the site proposed. As such the NRC recommends consideration on providing a discussion of alternative locations for holding ponds other than that of existing landfills, or a discussion as to why the landfill location is superior to other locations. If this is not addressed in the Early Site Permit (ESP)
Environmental Impact Statement (EIS) (as the requirement of the holding pond has not yet been established), it may need to be addressed in a future Supplemental EIS developed for a construction permit, operating license, or a combination thereof.
Chapter 3, Section 3.3.1 CERCLA/RCRA NUREG-1555 (required permits as listed in ML102000585 )
The ER should include information regarding the anticipated source of fill material used in construction (both on-site and off-site) and if said fill is considered clean fill with regards to hazardous waste and Resource Conservation and Recovery Act (RCRA) / Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) contaminants of concern.
Chapter 3, Section 3.4.1 Clean Water Act, Section 402 (40 CFR Parts 122-125, Parts 401-471, excluding Part 403))
The ER should include not just average and maximum, but also anticipated seasonal variations of principal constituents of intake and receiving waters and any minor or trace materials that may be of environmental relevance including:
Please provide (or reference a section of the report that provides):
The anticipated concentration factor on a seasonal basis for evaporative cooling systems.
The anticipated operating cycles for each effluent treatment system for normal modes of facility operation (e.g., full power operation, shutdown/refueling, and startup).
Chapter 3, Section 3.4.3.3.4 Clean Air Act, Title V.
NUREG-1555 The ER should include more detail regarding applicable Federal, state, and Tribal regional standards concerning atmospheric emissions from
(required permits as listed in ML102000585) consultation with Federal, state, regional, local, and affected Native American tribal agencies.
Chapter 4 - Environmental Impacts of Construction of Proposed Project Chapter 4 10 CFR 51.45 As wetland mitigation is anticipated, the ER should include a discussion on anticipated or potential locations of mitigation banks/areas. Are there locations for mitigation within the same watershed controlled by Duke that would facilitate the ease of installing wetland mitigation without requiring acquisition or negotiation of interest in other properties? The NRC understands that mitigation locations, acreage, etc. must ultimately be negotiated with the U.S. Army Corps of Engineers, and will not occur until after site designs are finalized, but any additional information in this regard will make it easier to address in the ESP EIS.
Chapter 5 - Environmental Impacts of Operation of Proposed Plant Chapter 5, Section 5.2.1.2.1 NUREG 1555, ESRP 5.3.2.1 Same comment as Chapter 2, Section 2.2.1.1.3.1.2 Chapter 5, Section 5.2.1.1.2.1 NUREG 1555, ESRP 5.2.1 This section of the ER discusses that a surrogate U.S. Geological Survey streamflow station was used to develop a long-term Belews Lake hydrologic model. The streamflow station, however, was not identified.
The ER should provide this information as well as further discussion as to why the selected streamflow station was appropriate to use.
Chapter 5, Section 5.2.1.2.2.1 NUREG 1555, ESRP 5.2.1 The ER should provide a basis for concluding alterations of circulation patterns and flow that are localized and do not influence the overall Belews Lake circulation patterns as a result of intake and discharge flow.
Chapter 5, Section 5.2 10 CFR 51.45 The ER section on Water Resources is blank, and actual results of thermal modelling were not included in the Chapter 5 drafts provided to NRC. The NRC notes that discussions of thermal impacts to the Belews Creek hydrologic system should account for overlap when both the coal plant and nuclear power plant are operating simultaneously. The NRC understands that this scenario will be temporary.
Chapter 5, Section 5.2.3.1.2 NUREG 1555, ESRP 5.3.1.1.
The ER considers thermal stratification in Mayo Reservoir to provide potential stratification in the absence of the heat load from Belews Creek Steam Station (BCSS). During the phased implementation period, there will still be contributions from BCCS. Therefore, when conducting the thermal stratification prediction, the heat load from BCSS should be considered as the baseline/affected environment. The ER should present stratification in consideration of the existing thermal conditions.
Chapter 8 - Need for Power Chapter 8 10 CFR 52.17(a)(2) 10 CFR 51.50(b)(2)
The NRC requires that the assessments that form the basis of Need for Power be independent. The NRC considers state regulatory acceptance of utility generated Integrated Resources Plans as confirmation of such independence. The ER should include either references to any such state acceptance or copies of such documentation.
Chapter 8 10 CFR 52.17(a)(2) 10 CFR 51.50(b)(2)
The ER should include the price of electricity (rates) in the discussion of historical and projected economic factors, weather, energy mix (including energy-efficiency and fuel-switching effects), and demographic/population trends that affect electricity demand.
Chapter 8 10 CFR 52.17(a)(2) 10 CFR 51.50(b)(2)
The ER should include the Identification of known or expected customers (or firm power sales) outside the relevant service area for the power to be supplied by the proposed facility.