ML25356A077
| ML25356A077 | |
| Person / Time | |
|---|---|
| Site: | 05000615 |
| Issue date: | 12/22/2025 |
| From: | Hunnewell S Tennessee Valley Authority |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NNP-25-013 | |
| Download: ML25356A077 (0) | |
Text
1101 Market Street, Chattanooga, Tennessee 37402 NNP-25-013 December 22, 2025 10 CFR 50.34 10 CFR 51.45 10 CFR 51.50 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Clinch River Project NRC Docket No. 50-0615
Subject:
TVA Comments on NRCs Draft Supplemental Environmental Impact Statement References
- 1. Tennessee Valley Authority, Submittal of the Environmental Report in Support of the Clinch River Nuclear Site Construction Permit Application, dated April 28, 2025 (ML25118A209)
- 2. U.S. Nuclear Regulatory Commission, Acceptance for Docketing of Part One of the Application for a Construction Permit at the Clinch River Nuclear Site, dated June 12, 2025 (ML25156A058)
- 3. U.S. Nuclear Regulatory Commission, Notification of the Issuance of the Draft Supplemental Environmental Impact Statement for Tennessee Valley Authority at the Clinch River Nuclear Site (EPID Number: L-2025-LNE-0000) (Docket Number 50-0615), dated November 7, 2025 (ML25274A093)
By letter dated April 28, 2025 (ML25118A209) the Tennessee Valley Authority (TVA) submitted the first part of an application for a construction permit to the U.S. Nuclear Regulatory Commission (NRC), including the Clinch River Nuclear (CRN) Site Environmental Report (Reference 1). In a letter dated June 12, 2025, the NRC stated it had accepted Part 1 of TVAs construction permit application for review (Reference 2). By letter dated November 7, 2025, the NRC notified TVA that it had completed a draft supplemental environmental impact statement (SEIS), Draft Supplement Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site, and that the NRC is conducting a 45-day comment period on the draft SEIS, ending December 22, 2025 (Reference 3).
The Enclosure to this letter contains TVAs comments on the draft SEIS.
U.S. Nuclear Regulatory Commission NNP-25-013 Page 2 December 22, 2025 This letter makes no regulatory commitments and no revisions to any existing regulatory commitments.
Please address any questions regarding this application to Mr. Ray Schiele, Senior Manager Licensing, New Nuclear Program, at rjschiele@tva.gov.
Respectfully, Scott W. Hunnewell, Vice President, New Nuclear Program
Enclosure:
TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site cc (with Enclosure):
Mahmoud MJ Jardaneh, Branch Chief, New Reactor Licensing Branch Daniel Barnhurst, Branch Chief, Environmental Review New Reactors Branch Allen H. Fetter, NRC Project Manager, Clinch River Nuclear Site Madelyn Nagel, Project Manager, Environmental Review of New Reactors Branch
Enclosure TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site
U.S. Nuclear Regulatory Commission NNP-25-013 December 22, 2025 Enclosure - TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site Page E-1 of 24 Comment SEIS Section #
SEIS Page #
TVA Comment 1
Abstract iii The first paragraph in the Abstract is not consistent with the No Action Alternative as described in Section 4.1 of the draft SEIS. The Abstract incorrectly states: "This supplemental environmental impact statement includes the preliminary analysis that evaluates the environmental impacts of the proposed action and environmental impacts of a combination of replacement energy generating capacity as part of the no-action alternative." As described in Section 4.1 of the draft SEIS, the no action alternative does not include replacement generation.
2 1.3.1 1-2 In Section 1.3.1, Page 1-2, starting at the end of the second paragraph and into the third paragraph, the USACE Purpose and Need appears to imply the USACE sets the project purpose and need. TVA would suggest the following underlined revisions:
"As part of the evaluation of permit applications subject to CWA Section 404 (TN1019), the USACE must define the overall project purpose in addition to the basic project need in support of the USACEs authority to identify the applicants available alternatives for reducing impacts to regulated waters based on the water dependency of the proposed action.
The overall project purpose establishes...Hence, defining the overall project purpose as it relates to CWA Section 404 compliance is the sole responsibility of the USACE."
U.S. Nuclear Regulatory Commission NNP-25-013 December 22, 2025 Enclosure - TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site Page E-2 of 24 Comment SEIS Section #
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TVA Comment 3
1.4 1-3 In Section 1.4, Page 1-3, the second paragraph is somewhat unclear regarding the Memorandum of Understanding (MOU).
TVA suggests the following underlined revisions:
"Under Section 10 of the Rivers and Harbors Act of 1899 (RHA) (33 U.S.C. § 403 et seq.-TN660), a Section 10 DA permit is normally required for work or structures in or affecting navigable waters of the U.S. TVA would submit its application to USACE prior to work in waters of the U.S. TVA and the DA have a memorandum of understanding (MOU) that applies to any TVA activities for which a DA permit may be required (TVA 1985-TN12322). TVAs RHA Section 10 permitting needs would be met under the terms of the MOU. Under Section 14 of RHA, TVA may need to obtain a Section 408 permission from USACE for potential impacts to the federally authorized navigation channel (33 U.S.C. § 408-TN4746). Additionally, under Section 404 of the CWA (TN1019), a DA permit is normally required for the discharge of dredged or fill material (e.g., fill, excavation, or mechanized land clearing) into waters of the U.S., including wetlands and navigable waters of the U.S."
4 1.6 1-9 Section 1.6, Page 1-9, in the first paragraph addresses 401 certification. TVA has requested a waiver from the Tennessee Department of Environment and Conservation that certification be obtained prior to issuance of the construction permit and suggests the following underlined revisions:
"Before TVA can obtain a CP from the NRC, it will be necessary for TVA to obtain a CWA Section 401 Certification or waiver from the Tennessee Department of Environment and Conservation (TDEC). This either waives state certification or certifies the project does not conflict with state water quality regulations."
Refer to 88 FR 66558 (September 27, 2023).
Also please note the change in this sentence from the Tennessee Department of Natural Resources, which is incorrect, to TDEC.
U.S. Nuclear Regulatory Commission NNP-25-013 December 22, 2025 Enclosure - TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site Page E-3 of 24 Comment SEIS Section #
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TVA Comment 5
1.6 1-9 In Section 1.6, Page 1-9, TVA did not obtain CGP coverage for construction activities on site in September 2021. TVA obtained CGP coverage for a variety of preconstruction actions at the CRN Site on July 11, 2025 and October 14, 2025.
6 2.1 2-1 In Section 2.1, Page 2-1, TVA requests the following underlined revisions:
"Vegetation in the transmission corridors will be managed under TVAs Vegetation Management Programmatic Environmental Impact Statement (PEIS) and updated best management practices, subject to compliance with the injunction issued in Sherwood v Tennessee Valley Authority, No: 3:12-CV-156-TAV-HBG (Sherwood), with measures to establish low-growing vegetation and promote biodiversity incorporated during and after building activities."
7 2.1 2-1 Section 2.1, last paragraph on Page 2-1 states: "The CP ER stated that the relocated 161 kV line will run parallel to the existing 500kV line for approximately 1.41 miles (mi) (2.27 kilometers [km]), down the east side of the site, for approximately 0.75 mi (1.21 km) to the switch yard, then run 0.49 mi (0.79 km) from the switch yard to rejoin the existing line."
This is not an accurate description. Section 3.8.1 of the draft SEIS (Physical Environment bullet) provides a better description of the location of the new 161-kV transmission line. The existing 161-kV line that crosses the CRN Site would not run parallel to the existing 500-kV line. The existing 161-kV line would be relocated to the southern portion of the CRN Site along the "west" side of the site. This was stated as "east" in error in TVA's Construction Permit Application (CPA) Environmental Report (ER).
U.S. Nuclear Regulatory Commission NNP-25-013 December 22, 2025 Enclosure - TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site Page E-4 of 24 Comment SEIS Section #
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TVA Comment 8
2.1 2-1 The fourth paragraph of Section 2.1 states: "The corridor extending from the 500 kV line to the interconnect at Bear Creek Road will be approximately 280 ft (85 m) to accommodate a 120 feet (ft) (37 meters [m]) wide corridor for the 161 kV tie in."
TVA offers the following clarification:
The final corridor will be 120-foot wide. However, TVA evaluated a 280-foot wide corridor to account for uncertainty in the final placement of the transmission line. TVA would not clear a 280-foot corridor.
9 2.2 2-4 In Section 2.2, Page 2-4, the second paragraph contains the following sentence: "The unloading area within barge traffic area (BTA) was expanded by approximately 133 feet (ft) (41 meters [m]) to the west and 435 ft (133 m) to the north but is still within the BTA footprint of the ESP EIS."
TVA did not provide these numbers in TVAs CPA ER. Please see the map following this table for TVA's measurement of the expansion of the Barge Landing Facility.
10 2.3 2-4 In Section 2.3, Page 2-4, the second paragraph contains the following sentence: "TVA updated the onsite traffic during operation to approximately 150 vehicles because of the reduced operation workforce (TVA 2025-TN12284)."
The cited document TVA 2025-TN12284 does not reference 150 vehicles. The response to the NRC RAI (NNP-25-006) indicated the number of vehicles estimated during operations is 200 based on 205 plant workers. Suggest revising this paragraph to reference 200 vehicles and cite the RAI as the reference source (TVA 2025-TN12318) similar to what is correctly stated in Note b in Table 3-2.
11 2.4 2-6 In Section 2.4, Page 2-6, the fourth paragraph should clarify that the control building is a three-story engineered metal building, and the service building is a three-story steel framed metal structure as described in Section 3.3.1 of TVA's CPA ER.
U.S. Nuclear Regulatory Commission NNP-25-013 December 22, 2025 Enclosure - TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site Page E-5 of 24 Comment SEIS Section #
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TVA Comment 12 2.4 2-7 In Section 2.4, Page 2-7, in the first sentence of the first paragraph on the page, "BTA" should be changed to "Barge Unloading Facility". The BTA is the entire area in the purple polygon shown in Figure 2-2 of the EIS. The features and changes described in this paragraph apply only to the Barge Unloading Facility which is located within the area designated as the BTA.
13 2.4 2-7 In Section 2.4, Page 2-7, in the second paragraph, the second to last sentence should clarify "Drill and blast benches" instead of "Drilling on blast benches". Refer to Section 3.3.4 of TVAs CPA ER.
14 2.5 2-7 In Section 2.5 on Page 2-7, the title for Section 2.5 seems to set the stage for a discussion of construction activities. However, the subsequent sections do not discuss construction activities. Rather they provide descriptions of various plant structures, systems, and components. It is not clear how Section 2.5 connects to the subsequent subsections which are focused on a description of the structures, systems, and components.
15 2.5.1 2-8 In Section 2.5.1, Page 2-8, third paragraph includes the following statement: "Notably, the electrical output for a single reactor at the CRN Site and its maximum average burnup exceed those in the PPE."
The reference to "electrical output" is in error, and should refer to "thermal output": This was also incorrectly stated in Section 3.2.1.1 of TVA's CPA ER, but is correctly stated in CPA ER Table 3.1-2, item 16.1.
16 2.5.2 2-10 Section 2.5.2, Page 2-10, second paragraph, first sentence indicates that water would be drawn primarily from municipal or treated surface-water sources. TVAs CPA ER Section 3.2.2.1 indicates that "surface water" sources may be used during construction for dust control/washdown (i.e., no specific mention of water being treated). The word "treated" should be removed from the statement in the draft SEIS for consistency with TVAs CPA ER.
U.S. Nuclear Regulatory Commission NNP-25-013 December 22, 2025 Enclosure - TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site Page E-6 of 24 Comment SEIS Section #
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TVA Comment 17 2.5.2 2-13 In Section 2.5.2, Page 2-13, the last paragraph contains the statement: "The intake elevation is 729 ft..."
This should state that the elevation of the bottom of the intake is 729 ft, consistent with Section 3.2.3.2.1 of TVAs CPA ER.
18 2.5.2 2-19 In Section 2.5.2, Page 2-19, the first sentence in the first paragraph is correct, with the exception of the about 491 yd3 estimate. Please refer to RCI-AE-6 in which TVA provided an estimate of 591 cubic yards of excavated material from the river bottom. Based on TVAs response to RCI-AE-6, approximately 480 cubic yards (cy) of material is estimated to be excavated between the existing riverbed and elevation 718 feet.
Additionally, 111 cy is estimated to be removed below the horizontal pipe. Therefore, a total of 591 cy (480 cy + 111 cy) is expected to be removed to support the installation of discharge piping at the river bottom.
This quantity is correctly indicated in the last sentence of the subject paragraph.
19 2.5.2 2-21 In Section 2.5.2, Page 2-21, the first paragraph states: "...comply with environmental standards..."
TVA recommends revising this to read: "...comply with water quality standards and effluent limitation guidelines..."
20 3.1.1 3-3 In Section 3.1.1, Page 3-3, the first bullet on this page includes the sentence: "The ESP EIS identified potential offsite transmission line connections including an underground 500 kV transmission corridor that extends from the CRN Site to the Bethel Valley substation."
In the ESP EIS, the proposed underground transmission line was a 69-kV line located within the existing 500-kV ROW/corridor.
U.S. Nuclear Regulatory Commission NNP-25-013 December 22, 2025 Enclosure - TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site Page E-7 of 24 Comment SEIS Section #
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TVA Comment 21 3.1.1 3-5 In Section 3.1.1 on Page 3-5, the last sentence of the first paragraph on the page states: "As of July 2025, the rail improvements and highway improvements are not included in this scope (TVA 2025-TN12285). "
The specific highway improvements needed to support construction and operation of CRN-1 have not yet been identified. ER Section 10.6.1.3 addresses TVA's coordination with The TN Department of Transportation regarding potential mitigation strategies. However, based on the reduced traffic during construction and operations, it is expected that the impacts will be bounded by those improvements evaluated in the ESP EIS.
22 3.1.1 3-5 In Section 3.1.1 on Page 3-5, the second sentence of the second paragraph states: TVA did not identify any new information related to the effected environment and the region in its CP application.
TVA did identify new information related to land use, as stated in Section 2.2 of TVAs CPA ER. However, TVA did not identify any new and significant information related to Land Use.
23 3.2.3 3-11 In Section 3.2.3, Page 3-11, the third paragraph states that a drift rate of 200 g/s is found in the ESP EIS. In the ESP EIS, the drift rate is shown as 8 gallons per minute (gpm), which converts to 505 g/s (Section 3.4.2.2.2 of the ESP EIS). The 200 g/s value is likely referring to the 200.7 g/s value in Table 5.3-12 of TVA's Early Site Permit Application (ESPA) ER, that documented a SACTI design input, which bounds the drift rate of 8 gpm in the Plant Parameter Envelope.
24 3.2.3 3-12 In Section 3.2.3, Page 3-12, Table 3-2, the total for PM2.5 should be 3.76 instead of 0.06. The cooling tower particulate matter was not accounted for in the total row.
U.S. Nuclear Regulatory Commission NNP-25-013 December 22, 2025 Enclosure - TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site Page E-8 of 24 Comment SEIS Section #
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TVA Comment 25 3.4.1.1 3-15 In general, there seems to be inconsistencies with the use of the terms "new and significant information" vs "potentially new and significant information" vs "new and potentially significant information." For example, the second paragraph of Section 3.1.1 states, "the following discussion provides context and presents 'new and significant information'..." However, the last sentence in the paragraph states that the subsequent bullet list is "new and potentially significant information".
Similar examples exist in Sections 3.2.1, 3.2.2, 3.2.3, 3.5.1, 3.6.1, 3.8.1, 3.10.1, and 3.11.1.
26 3.4.1.2 3-21 In Section 3.4.1.2, Page 3-21, this section only references construction activities in the reservoir. TVA recommends including a paragraph indicating compliance with Tennessee Construction Stormwater General Permit (CGP) and Oak Ridge MS4/Land Disturbance permit for compliance addressing stormwater discharges during construction and associated implementation of adequate control measures during all land disturbance activities supporting construction on site in a manner that sufficiently reduces construction stormwater impacts on the receiving stream/reservoir's water quality.
27 3.4.1.3 3-23 In Section 3.4.1.3, Page 3-23, the first paragraph refers to the "blowdown discharge temperature". This should be the "maximum expected blowdown temperature" as described in Table 3.1-2, sheet 3 of 12, page 3-8 of the CPA ER.
This is also noted on pages 1-7 and 2-20 in Sections 1.4.2 and 2.5.2.
U.S. Nuclear Regulatory Commission NNP-25-013 December 22, 2025 Enclosure - TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site Page E-9 of 24 Comment SEIS Section #
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TVA Comment 28 3.4.1.3 3-23 In Section 3.4.1.3, Page 3-23, the second paragraph under Water Quality states: "These extreme events are driven largely by displacement of the upstream portion of a naturally occurring warm-water thermal pancake in Watts Bar Reservoir, which forms when Melton Hill is not continuously operated." This statement is not quite accurate. Summer extreme temperature change events near the CRN Site are driven largely by displacement of a naturally occurring warm water "thermal pancake" in Watts Bar Reservoir, produced by solar radiation heating the water surface layers, being alternately pushed downstream by Melton Hill dam releases, and then shifting back upstream when Melton Hill Dam is not operating.
Sometimes the downstream shifts in the upstream edge of the thermal pancake can extend down-river of the CRN Site discharge area, potentially creating a delta-T violation that is not related to operation of the CRN Site.
29 3.4.2.1 3-26 In Section 3.4.2.1, Page 3-26, the bullet refers to previous-Block area. This term is not defined in the draft SEIS and it is not clear what this is referencing. Additional clarification would be helpful to the reader.
30 3.4.2.1 3-27 In Section 3.4.2.1, Page 3-27, the first partial bullet on the page contains the sentence: "The estimate ranged from 1,000-3,000 gpm (3,785-11,356 lpm) and aligns with the dewatering rate for the nearby Midway Quarry."
TVAs RCI response does not support the statement that the estimated range of 1,000-3,000 gpm aligns with the dewatering rate for the nearby Midway Quarry. TVA suggests rewording or omitting this statement.
31 3.4.2.2 3-30 In Section 3.4.2.2, Page 3-30, it is stated that "any groundwater withdrawn during dewatering would be regulated as part of the NPDES permit issued by TDEC."
However, if the withdrawn groundwater is not discharged and is managed in another manner other than discharge, it is not subject to the NPDES permit. As stated in the ER, discharge of groundwater would be regulated as part of the NPDES permit issued by TDEC.
U.S. Nuclear Regulatory Commission NNP-25-013 December 22, 2025 Enclosure - TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site Page E-10 of 24 Comment SEIS Section #
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TVA Comment 32 3.5.1 3-33 In Section 3.5.1, Page 3-33, the next to last sentence in the last bullet states: "TVA only notes the proposed species as being within Roane County and within 5 mi (8 km) of the CRN site and offsite areas".
It does not appear that the TVA CPA ER fully supports this statement. The proposed species noted by TVA is the eastern hellbender. In Section 2.4.1.3.2.2 of the TVA CPA ER, TVA mentions that a historical record of this species exists in the Reservoir 1.13 miles from the CRN Site. In Section 4.3.1.4.1 of the TVA CPA ER, TVA notes that the eastern hellbender is a proposed endangered species and mentions a record exists within 3 miles of the proposed activities.
33 3.5.1 3-34 In Section 3.5.1, Page 3-34, the second paragraph contains the sentence, Native coontail (Ceratophyllum demersum) and water stargrass (Heteranthera dubia) dominated the Reservoir, with the densest water stargrass just below Mean Higher High Water at CRM 22.6 (upstream of the proposed intake).
The "Mean Higher Water Mark" in this sentence should be the "Ordinary High Water Mark".
34 3.5.1 3-34 In Section 3.5.1, Page 3-34 (carrying onto page 3-35), the third sentence in the third paragraph states, The three fish species and spectaclecase have critical habitat identified but none of the critical habitats identified overlap with the CRN Site.
The word designated should be added before critical habitat.
This comment also applies to the second bullet on page 3-41 in Section 3.6.1.
U.S. Nuclear Regulatory Commission NNP-25-013 December 22, 2025 Enclosure - TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site Page E-11 of 24 Comment SEIS Section #
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TVA Comment 35 3.5.1 3-35 In Section 3.5.1, Page 3-35, the first sentence of the first full paragraph on the page states, Two cooling-water intake designs are described in the CP ER (2025-TN11927) and will be constructed at CRM 17.9 (TVA 2025-TN12285).
This sentence has the potential to be misinterpreted to read that two intakes will be constructed. TVA suggests clarifying this sentence to indicate that TVA is considering two alternatives.
Note that the selected intake will be constructed at approximately CRM 17.9 as described in Section 3.2.2.1 of the TVA CPA ER.
36 3.5.1 3-35 In Section 3.5.1, Page 3-35, the third paragraph states, The discharge structure will be constructed at CRM 15.55 The discharge will be constructed at approximately CRM 15.5 as described in Section 1.2.2.4 of TVAs CPA ER.
37 3.6.1 3-39 In Section 3.6.1, Page 3-39, the second paragraph on the page states: "Section 7 consultation for species listed under the ESA has been initiated by TVA."
This should be updated to reflect that the consultation has been completed. TVA received a Biological Opinion from the USFWS on July 11, 2025.
38 3.6.1 3-39 In Section 3.6.1, Page 3-39, the last bullet on the page indicates TVAs refined coverage map was developed in 2021.
TVA's refined habitat coverage was created in 2022, as described in Section 2.4.1.1 of the TVA CPA ER.
U.S. Nuclear Regulatory Commission NNP-25-013 December 22, 2025 Enclosure - TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site Page E-12 of 24 Comment SEIS Section #
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TVA Comment 39 3.6.1 3-40 In Section 3.6.1 on Page 3-40, the second bullet from the bottom (Wetlands Distribution and Functional Value) discusses 30 wetlands on the CRN site, 10 wetlands on the BTA, and 6 wetlands for the offsite 161kV ROW.
In Section 2.4.1.2 of TVAs CPA ER these numbers are provided as 25, 17, and 7, respectively.
40 3.6.1 3-41 In Section 3.6.1 on Page 3-41, the first bullet (Federal and State Jurisdiction) discusses jurisdictional determinations. However, there is no mention of the TDEC determinations in July and September 2025.
TVA has separately provided information about the TDEC determinations received in July and September 2025 to the NRC.
41 3.6.1 3-41 In Section 3.6.1 on Page 3-41, the first bullet (Federal and State Jurisdiction) contains an incomplete sentence - Consideration of conditions related to the CWA Section 401 certification.
It appears that the text beginning with the quoted phrase should be a separate bullet.
42 3.6.1 3-41 In Section 3.6.1 on Page 3-41, the first bullet (Federal and State Jurisdiction) states that a CWA 401 certification is required prior to the issuance of a CP.
Recommend that this sentence be revised to include the potential for a waiver. CWA Section 401 states that no license or permit shall be granted until the certification required by this section has been obtained or has been waived. Suggest revision to indicate that this certification is required for issuance of the CWA 404 Section permit, and CWA Section 401 certification or waiver is required prior to issuance of a CP. See Comment #4.
U.S. Nuclear Regulatory Commission NNP-25-013 December 22, 2025 Enclosure - TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site Page E-13 of 24 Comment SEIS Section #
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TVA Comment 43 3.6.1 3-43 In Section 3.6.1 on Page 3-43, the fourth bullet states, "The ESP EIS mentioned that three tricolored bats were captured during 2011 mist net surveys on the CRN Site, indicating that there is a possible nearby hibernaculum."
However, capture of tricolored bats during summer is not an automatic indication of nearby winter hibernacula use, as this species seasonally migrates. Suggest ending the sentence at the comma, i.e.,
removing the following phrase: ", indicating that there is a possible nearby hibernaculum".
44 3.6.2.2 3-45 In Section 3.6.2.2 on Page 3-45, the fourth paragraph states: "TVA will implement multiple post-construction sustainability measures including removal of invasive species, restoring the remanent cedar glade habitats onsite, improving host plants and foraging habitat for pollinators, and adaptive land management practices (TVA 2025-TN11927, TVA 2025-TN12285)."
However, in RCI-TE-3, TVA was asked to confirm that it may implement those various measures. TVA requests that this wording be revised to reflect the content of RCI-TE-3.
45 3.6.2.2 3-46 In Section 3.6.2.2 on Page 3-46, the first paragraph states: The one exceptionally rated wetland would be converted from forested wetland to herbaceous or scrub/shrub wetland.
However, only a portion of the one exceptionally rated wetland located within the proposed expanded transmission line corridor would be converted from forested wetland to herbaceous or scrub/shrub wetland.
46 3.6.2.3 3-46 In Section 3.6.2.3, Page 3-46, the second paragraph states: "On the offsite transmission corridor 3.6 ac (1.5 ha) of wetlands will be converted from forested to herbaceous or shrub scrub".
However, approximately 3.6 acres of wetlands, about 2.9 acres of which are forested woody wetlands, are located within the associated offsite 161-kV transmission line corridor. Therefore, approximately 2.9 acres of wetlands are converted from forested to herb or shrub scrub (not 3.6).
U.S. Nuclear Regulatory Commission NNP-25-013 December 22, 2025 Enclosure - TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site Page E-14 of 24 Comment SEIS Section #
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TVA Comment 47 3.6.3.2 3-47 In Section 3.6.3.2 on page 3-47, the second paragraph states, Based on the review of sustainability measures and given that manufacturing labels will be followed for the addition of sulfuric acid within the cooling water, the review team determined that the conclusion of SMALL presented in the ESP EIS remains bounding and valid.
This statement seems to be out of place, or context is missing. There is no discussion related to cooling tower water chemistry in Section 3.6.3.2.
48 3.7.2.1 3-55 In Section 3.7.2.1, Page 3-55, in the first full paragraph on this page, the draft SEIS summarizes that the ESP EIS identified one historic cemetery in the direct APE - the Hensley Cemetery. That is correct as described in the ESP EIS. However, as noted in Table 3-6 of the draft SEIS, 40RE219, which is the African-American Wheat Community Burial Ground is now located in the revised SEIS APE as depicted in draft SEIS Figure 3-8. This cemetery was located outside of the ESP EIS APE. Therefore, there is new information that NRCs APE in this area has been expanded and this cemetery is now located within the direct APE as evaluated in the draft SEIS.
Table 3-6 of the draft SEIS recommends that 40RE219 should be avoided if possible or mitigated in accordance with the TVA PA. TVA has no plans or actions that would disturb or occur in proximity to 40RE219. The nearest possible actions would be potential roadwork around the SR58 ramp to Bear Creek Road. Those activities are 850 feet away on the other side of the forested hill from this cemetery. Because the Wheat Community Burial Ground is located outside of TVA's evaluated disturbance area, and because of the intervening terrain (hill) and forest vegetation there would be no impacts to this cemetery that would need to be avoided or mitigated.
U.S. Nuclear Regulatory Commission NNP-25-013 December 22, 2025 Enclosure - TVA Comments on NRCs Draft Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site Page E-15 of 24 Comment SEIS Section #
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TVA Comment 49 3.8.2.1 3-60 In Section 3.8.2.1 on Page 3-60, first paragraph identifies "SMALL and MODERATE" impacts described in Section 4.4.1 of the ESP EIS.
However, the summary of physical impacts in Section 4.4.1.5 of the ESP EIS identifies "small to moderate" impacts.
50 3.8.2.3 3-61 In Section 3.8.2.3 on Page 3-61, the second paragraph states: "An average of $30.2 million annually would be spent on CRN-1 construction labor wages over the 6-year duration of building, while the estimated wages would reach an annualized total of $64.4 million at the peak employment (TVA 2025-TN11927)."
The $30.2 million figure is not present in the referenced document (TVA2025-11927). However, TVA can confirm that this information is accurate as stated. This comment also applies to Table 4-1.
51 3.8.3.3 3-63 In Section 3.8.3.3 on Page 3-63, the second paragraph discussed an incremental increase in 440 indirect jobs and references the TVA ER.
However, this information is not supported by the TVA CPA ER. Table 10.6-1 of the ER shows 221 indirect jobs. Suggest removing reference to TVAs CPA ER and describing how the 440 indirect jobs was derived.
52 3.10.1 3-66 In Section 3.10.1 on Page 3-66, the first sentence indicates the discussion presents new and significant information. However, there is no new or new and significant information presented in the section.
53 3.11.1 3-68 In Section 3.11.1, on Page 3-68, the second bullet (Onsite Construction Workforce Numbers) includes a workforce estimate of 2,200 workers. This value is not supported by the CPA ER. Table 3.1-2 and Section 3.3.7 of the ER shows a peak construction workforce of 1,301.
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TVA Comment 54 3.11.1 3-68 In Section 3.11.1, on Page 3-68, the third bullet (Publicly Accessible Area) states: The ESP EIS stated that the nearest publicly accessible area was approximately 1,900 ft (579 m) from the planned cooling-tower location." The bullet also states: "The nearest publicly accessible area is now 1,860 ft (569 m) from the cooling towers location."
The bullet provides the RCA response (TVA2025-TN12285) as a reference. However, in RCI-NRH-3, NRC requested confirmation that the nearest noise receptor is approximately 1,860 feet from the cooling towers.
TVA responded stating that the nearest noise receptor to the cooling tower is 1,330 feet from the cooling tower. The RCI response referenced in the draft SEIS does not mention the nearest publicly accessible area.
55 3.11.1 3-69 In Section 3.11.1, on Page 3-69, the second to last bullet (Nearest Sensitive Noise Receptor During Construction) states that the nearest sensitive noise receptor is now 750 ft (229 m) away, with expected noise levels attenuating to 77 dBA.
The bullet provides the RCI response (TVA 2025-TN12285) as a reference. However, the referenced RCI Response states that noise attenuates to 77.5 dBA.
56 3.11.1 3-69 In Section 3.11.1, on Page 3-69, the last bullet (Nearest Sensitive Noise Receptor for Operation) states the distance to the nearest noise receptor is approximately 1,860 feet.
The bullet provides TVAs RCI response (TVA2025-TN12285) as a reference. However, in RCI-NRH-3, NRC requested confirmation that the nearest noise receptor is approximately 1,860 feet from the cooling towers.
TVA responded stating that the nearest noise receptor to the cooling tower is 1,330 feet from the cooling tower.
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TVA Comment 57 3.11.1 3-70 In Section 3.11.1 on Page 3-70, the second sentence of the last paragraph states that TVA did not identify any new information related to the affected environment and acute effects of electromagnetic fields.
However, in Section 2.8 of TVAs CPA ER TVA did identify new information related to electromagnetic fields, but that the information is confirmatory of previous information considered in the ESP EIS.
58 5.4 5-8 In Section 5.4, Page 5-8, the draft SEIS states, "The draft 2025 IRP (TVA 2024-TN12296) preferred portfolio includes SMRs at the CRN Site and anticipates operation by summer 2033. By the end of 2035, the preferred portfolio includes up to 1 GW nuclear additions."
However, the draft 2025 IRP did not include a preferred portfolio. The draft 2025 IRP included consideration of SMRs at the CRN Site, as a component of the scenarios evaluated. Further, the final IRP will be released at a later date.
59 6.3.2 6-4 In Section 6.3.2, Page 6-4, the first paragraph includes the following statement: "The principal benefit is the production of electricity."
However, as correctly stated in Section 4.5.3, Page 4-9, the "principal" or "primary benefit" is "demonstrating the feasibility to license, construct, and operate SMR technology at the CRN Site."
60 Appendix E,
Section E.1 Pages E-2 Appendix E, Table E-1 on Page E-2 refers to "TVA's CRN Site NRIC Project."
Although this project is anticipated to occur on the CRN Site, this is a National Reactor Innovation Center (NRIC) project, not a TVA project. For the Status column, this is not a TVA action, and should state that NRIC (or the project) is currently engaged in final site selection, design, and planning.
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TVA Comment 61 Appendix F, Section F.1 F-1 In Appendix F, the title of Table F-1 is somewhat misleading because the table includes species that are not yet federally listed. Recommend replacing the word "listed" in the title with "protected" to provide additional clarity.
62 Appendix F, Section F.1 F-1 In Appendix F, Table F-1, 2025 TVA BA Effect Determination column should simply be "No Jeopardy" for Tricolored bat, little brown bat, and monarch. (Strike NLAA for all of these species).
63 Appendix F, Section F.1 F-1 In Appendix F, Table F-1 there are different determinations between TVA and NRC for northern long-eared bat. Recommend including a footnote providing additional explanation for the different determinations. TVA determined the species could be adversely affected due to a previous capture on site and abundance of suitable summer roosting habitat. Ultimately the USFWS BO indicated due to population declines, they were not reasonably certain the species would exist at this location and determined the species is not likely to be adversely impacted by proposed actions.
64 Appendix F, Section F.1 F-1 In Appendix F, Table F-1, little brown bat is not federally protected or federally listed at this time.
Recommend either removing little brown bat from this table or adding a footnote explaining why this species is included here.
65 Appendix F, Section F.1 F-2 In Appendix F, Footnote B of Table F-1 states: "TVA determined the Federal action may affect and was likely to adversely affect the Indiana bat, northern long-eared bat, gray bat, and tricolored bat."
This statement is not correct, TVA determined the Federal action may affect and was likely to adversely affect the Indiana bat, northern long-eared bat, gray bat, and would not jeopardize the continued existence of the tricolored bat.
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TVA Comment 66 Appendix F, Section F.1 F-2 In Appendix F, Footnote D of Table F-1 states: "The ESA does not require Federal agencies to seek FWS concurrence for no effect determinations or for may affect, not likely to adversely affect determinations for candidate and proposed species".
However, Section 7(a)(2) of the ESA requires that Federal agencies consult with the USFWS for actions that "may affect" federally listed species and critical habitats. Suggest revising this footnote for clarity.
67 Appendix F, Section F.1.2 F-5 In Appendix F, Section F.1.2, the first full paragraph states: "FWS concurred with TVA determination of may affect, likely to adversely affect for effects of the proposed action on the gray bat, Indiana bat, northern long-eared bat, and tricolored bat. FWS issued an incidental take statement for these species and detailed reasonable and prudent measures to avoid or limit take."
These statements could be clarified. FWS concurred with TVA's determination of may affect, likely to adversely affect for effects of the proposed action on the gray bat, and Indiana bat, and with a "no jeopardy" determination for tricolored bat. FWS indicated that northern long-eared bats are not reasonably certain to occur in the project area and thus effects are not expected. FWS issued an incidental take statement for gray bat and Indiana bat and detailed reasonable and prudent measures to avoid or limit take.
68 Appendix F, Section F.1.3 F-6 In Appendix F, Table F-4, the gray bat row includes the following statement: Winter cave surveys in 2021 documented five gray bat roosting inside a cave.
This statement is not accurate. As described in Section 2.4.1.3.2.2 of TVA's CPA ER, only one gray bat was documented roosting inside the cave in March 2021.
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TVA Comment 69 Appendix F, Section F.1.3 F-7 In Appendix F, Table F-4, the gray bat row includes the following statement: Drilling, excavation, and blasting within 0.5 mi of known caves will be avoided from November 15 through March 31 while bats are in torpor.
This statement is not accurate. Drilling and blasting with 0.5 mi of HPA caves will be avoided during torpor but there are no gray bats in those caves. Drilling and blasting within 0.5 mi of the gray bat cave will not have seasonal restrictions which is why TVA proposed blasting conservation measures.
70 Appendix F, Section F.1.3 F-8 In Appendix F, Table F-4, the Indiana bat row includes the following statement: "Approximately 0.65 acres of wetlands will be filled and 3,600 ft of 11 perennial/intermittent streams will be filled, which would reduce drinking water and food."
This statement is not accurate. As described in Section 4.3.1.2.1 of TVA's CPA ER, approximately 9.2 acres of wetlands will be impacted by the CRN-1 project. The 0.65 acre value is the area of onsite ponds that would be filled.
71 Appendix F, Section F.1.3 F-9 In Appendix F, Table F-4, the northern long-eared bat row includes the following statement: As mentioned, nine caves are known to be present within 3 mi of the CRN Site, however, internal surveys of these caves conducted in 2021 determined that northern long-eared bats are not currently using them.
This statement needs clarification. TVA performed internal surveys of the four closest caves to the CRN Site (3 HPA caves and one across the river). TVA did not survey the other five caves that occur off TVA property.
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TVA Comment 72 Appendix F, Section F.1.3 F-10 In Appendix F, Table F-4, the tricolored bat row includes the following statements: "Tree removal in wetlands and near streams would be restricted to those that would interfere with transmission lines. The proposed activities will increase the risk of collision; however, the majority of traffic will occur during daylight hours."
These statements do not completely capture wetland tree removal impacts on the CRN Site. While some wetlands will be converted from forested to emergent wetlands through the removal of trees for transmission lines, other forested wetlands will be removed in their entirety, removing both the trees and the wetland and thus reducing the amount of potential habitat on the CRN Site.
73 Appendix F, Section F.1.3 F-11 In Appendix F, Table F-4, the little brown bat row includes the following statements: "Nine caves are known to be present within 3 mi of the CRN Site. During internal winter cave surveys conducted in March 2021, no little brown bats were observed."
This second sentence needs clarification. During internal winter cave surveys of the four caves immediately adjacent to the CRN Site conducted in March 2021, no little brown bats were observed. TVA did not conduct internal surveys of all nine caves discussed in the preceding sentence in the draft SEIS.
74 Appendix F, Section F.1.3 F-12 In Appendix F, Table F-4, the monarch butterfly row includes the following sentences: "Proposed project construction, operation, and decommissioning activities will occur within potential monarch habitat. This includes the small population near the intake location."
These statements are not correct. As described in Section 4.3.1.4.1 of TVA's CPA ER, potentially suitable habitat for the monarch butterfly is only present in scattered pockets across the CRN-1 project area. TVA has not identified any known monarch populations or demarked any milkweed populations near the intake area on the CRN Site.
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TVA Comment 75 Appendix F
N/A TVA made a "no effect" determination for the eastern hellbender because it was included in TVA's heritage database query. TVA did include the eastern hellbender in the Biological Assessment submitted to USFWS.
However, it is not addressed in Appendix F of the NRCs draft SEIS along with other "no effect" species.
76 Appendix G
G-3 In Appendix G, Table G-1 on Page G-3, in the first TDEC row TVA recommends updating the Activity Covered to indicate TVA would need to obtain the certification or a waiver before the NRC can issue the construction permit. Refer to Comment #4.
77 Appendix H
H-4 In Appendix H, Table H-1 on Page H-4, in the second Land Use row, Figure 2.2 is referenced in the last column. There is no clickable link to this Figure and this Figure is not found within the draft SEIS.
78 Appendix H
H-6 In Appendix H, Table H-1 on Page H-6, in the first Terrestrial Ecology row, Tables 2.4-1 and 4.3-2 are referenced. These tables are not found in the draft SEIS.
79 Appendix H
H-8 In Appendix H, Table H-1, Page H-8, in the first row, a statement in the last column reads: "Consultation under Section 7(a)(2) of the ESA is underway regarding potential impacts to federally listed bats for construction and operation activities."
Because both TVA and NRC consulted under Section 7, this statement could use some clarification regarding the consultation (TVA or NRC) that is being referenced. If this is regarding the TVA consultation, that consultation was completed July 2025.
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TVA Comment 80 Appendix H
H-23 In Appendix H, Table H-2 on Page H-23, the Description of Issue column for Water and Wastewater Services states that Water and Wastewater Services are not addressed in the draft SEIS. In Section 3.2.2.1 of the TVAs CPA ER, TVA stated that potable and sanitary wastewater services would be provided by the City of Oak Ridge.
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