ML25343A341
| ML25343A341 | |
| Person / Time | |
|---|---|
| Site: | Triso-X |
| Issue date: | 12/08/2025 |
| From: | Kajumba N US Environmental Protection Agency, Region 4 |
| To: | Caverly J Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML25343A341 (0) | |
Text
December 8, 2025 Ms. Jill Caverly Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, District of Columbia 20555-0001 Re: EPA Comments on the TRISO-X Special Nuclear Material License Application for a Fuel Fabrication Facility, CEQ No. 20250140
Dear Ms. Caverly:
The U.S. Environmental Protection Agency reviewed the Draft Environmental Impact Statement (EIS) for the TRISO-X Special Nuclear Material License Application for a Fuel Fabrication Facility, in accordance with Section 102(2)(C) of the National Environmental Policy Act (NEPA) and 309 of the Clean Air Act (CAA). The CAA Section 309 requires the EPA to review and comment on the environmental impact of any proposed federal action subject to NEPAs EIS requirements and make the agencys comments public. The Nuclear Regulatory Commission (NRC) prepared the draft EIS in cooperation with the Department of Energy (DOE) to evaluate the effects of issuing a special nuclear material license including construction, operation, and decommissioning of the proposed TRISO-X facilities in Oak Ridge, Tennessee.
According to the draft EIS, the proposed federal action for the DOE is to respond to the financial assistance request from X-energy to complete construction and operation of the TRISO-X fuel fabrication facility. The proposed federal action for the NRC is to authorize TRISO-X to possess and use special nuclear material to manufacture high-assay low-enriched uranium fuel at a fuel fabrication facility. According to the draft EIS, the fuel fabrication facility would be built on a 110-acre site within the Horizon Center site. The draft EIS evaluated the no action alternative and the action alternative.
Under the no action alternative, the NRC would not issue a 40-year license to TRISO-X.
Based on our review of the draft EIS, we have enclosed comments on air quality. These comments are intended to provide clarity on the project effects and improve the environmental outcome of the proposed action.
2 We appreciate the opportunity to review the draft EIS. If you have any questions, please contact Kristina Bowen, at 404-562-8399 or bowen.kristina@epa.gov.
Sincerely, Ntale Kajumba Manager NEPA Section Enclosure
- 1. Comments on the TRISO-X Special Nuclear Material License Application for a Fuel Fabrication Facility Ntale Kajumba Digitally signed by Ntale Kajumba Date: 2025.12.08 23:03:09 -05'00'
3 Enclosure EPA Comments on the TRISO-X Special Nuclear Material License Application for a Fuel Fabrication Facility Air Quality National Ambient Air Quality Standards As of the date of this letter, the National Ambient Air Quality Standards for Primary Particulate Matter (PM2.5) and Secondary Sulfur Dioxide (SO2) referenced in Table 3.3-2 (pgs. 3-14 and 3-15) are no longer in effect. The Primary PM2.5 annual standard was revised from 12.0 g/m3 to 9.0 g/m3 and promulgated on March 6, 2024, in 89 Federal Register (FR) 16202. In addition, the Secondary SO2 standard was revised to an annual average, averaged over three consecutive years, with a level of 10 parts per billion (ppb), as promulgated in 89 FR 105692 on December 27, 2024. Please reflect the current Primary PM2.5 and Secondary SO2 standards, as promulgated in 89 FR 16202 and 89 FR 105692, in the final EIS.
Mitigation Strategies Section 3.3.3.1.1 of the draft EIS describes air quality impacts from construction as small. Pursuant to NEPA Section 102(2)(C)(i), 42 U.S.C. § 4332(2)(C)(i), the EPA recommends the final EIS include an air pollutant emissions estimate for construction to support the conclusion that the air quality impacts are small.
Minor Air Pollutant Source The Draft EIS discusses air emission levels and potential impacts. It indicated the fuel fabrication facility will be managed in accordance with the Clean Air Act and Tennessee Department of Environmental Conservation requirements as applicable. The EPA recommends the final EIS clarify whether the facility will be subject to permitting as a minor air pollutant source, or a major air pollutant source according to 40 CFR Part 70.2 requirements. If the facility is a major title V source, any applicable requirements and appropriate modifications to the final EIS should be made pursuant to 40 C.F.R Part 70.3 and 42 U.S.C. § 4332(C)(i).