ML25364A023

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Env Reg Audit Re the Proposed Reauth of Power Operations for Crane Clean Energy Center
ML25364A023
Person / Time
Site: Crane 
Issue date: 01/02/2026
From: Kevin Folk
NRC/NMSS/DREFS/EPMB1
To: Karpa Z
Constellation Energy Generation
References
EPID L-2025-LNE-0008
Download: ML25364A023 (0)


Text

Zigmund Karpa Director of Environmental Programs Constellation Energy Generation, LLC 200 Energy Way Kennett Square, PA 19348

SUBJECT:

ENVIRONMENTAL REGULATORY AUDIT REGARDING THE PROPOSED REAUTHORIZATION OF POWER OPERATIONS FOR CRANE CLEAN ENERGY CENTER UNDER RENEWED FACILITY OPERATING LICENSE NUMBER DPR-50 (EPID NUMBER: L-2025-LNE-0008)

Dear Zigmund Karpa:

Constellation Energy Generation, LLC (CEG) submitted a series of licensing and regulatory requests that are necessary to reauthorize power operations at the Christopher M. Crane Clean Energy Center (CCEC) through April 19, 2034, the end of the current operating license term under CCEC's Renewed Facility Operating License No. DPR-50. Specifically, by letters dated November 19, 2024, July 31, 2025, October 24, 2025, and October 31, 2025, CEG submitted an exemption and three license amendment requests to support resumption of power operations at CCEC.1 By correspondence dated December 20, 2024, September 4, 2025, December 2, 2025, and December 9, 2025, the U.S. Nuclear Regulatory Commission (NRC) staff notified you that your requests had been accepted for review.2 In addition, by letter dated October 31, 2025 (ML25303A294), CEG submitted to the NRC an Environmental Report (ML25303A293) to support the NRC staff in performing its associated environmental review.

Collectively, the licensing and regulatory requests define the proposed NRC Federal actions, that is, for the NRC to determine whether to grant or deny the requests necessary to reauthorize power operations at CCEC.

The NRC staff has now initiated its environmental review associated with the referenced requests and associated connected actions. An environmental audit will be conducted by NRC staff in February 2026: a virtual audit the week of February 2, 2026, and a site visit the week of February 16, 2026. The environmental audit activities will be conducted in accordance with the enclosed Environmental Audit Plan (Enclosure 1).

1 Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML24324A048, ML25212A076, ML25300A118, and ML25304A097(package), respectively.

2 ML24355A057, ML25247A220, ML25337A113, and ML25345A391, respectively.

January 2, 2026

Z. Karpa 2

To the extent possible, the NRC staff requests the information identified in the Environmental Information Needs and Document Requests list (Enclosure 2) be made available on the CCEC online reference portal prior to the audit. A draft schedule of tours and meetings is provided in.

If you have any questions, please contact me at 301-415-6944 or via email at kevin.folk@nrc.gov.

Sincerely, Kevin T. Folk Sr. Environmental Project Manager Environmental Project Management Branch 1 Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards Docket No.: 50-289

Enclosures:

As stated cc w/encls: Listserv Signed by Folk, Kevin on 01/02/26

ML25364A023 OFFICE PM:REFS/EPMB1 LA:REFS/EPMB2 BC:REFS/EPMB1 PM:REFS/EPMB1 NAME KFolk MCampestrin SKoenick KFolk DATE 12/30/2025 12/31/2025 01/02/2026 01/02/2026 Audit Plan Environmental Review of the Proposed Reauthorization of Power Operations for Christopher M. Crane Clean Energy Center December 2025 Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission

2 Environmental Review of the Proposed Reauthorization of Power Operations Christopher M. Crane Clean Energy Center

===1.

Background===

Constellation Energy Generation, LLC (CEG) submitted a series of licensing and regulatory requests that are necessary to reauthorize power operations at the Christopher M. Crane Clean Energy Center (CCEC) through April 19, 2034, the end of the current operating license term under CCEC's Renewed Facility Operating License No. DPR-50. Specifically, by letters dated November 19, 2024, July 31, 2025, October 24, 2025, and October 31, 2025 (Agencywide Documents Access and Management System (ADAMS) accession numbers ML24324A048, ML25212A076, ML25300A118, and ML25304A097 [package], respectively), CEG submitted an exemption and three license amendment requests to support resumption of power operations at CCEC. By correspondence dated December 20, 2024, September 4, 2025, December 2, 2025, and December 9, 2025 (ML24355A057, ML25247A220, ML25337A113, and ML25345A391, respectively), the U.S. Nuclear Regulatory Commission (NRC) staff notified you that your requests had been accepted for review.

In addition, by letter dated October 31, 2025 (ML25303A294), CEG submitted to the NRC an Environmental Report (ER) (ML25303A293) to support the NRC staff in performing its associated environmental review.

Collectively, the referenced requests define the proposed NRC Federal actions, that is, for the NRC to determine whether to grant or deny the requests necessary to reauthorize power operations at CCEC.

The NRC staff is conducting an environmental audit of the CCEC site to improve understanding, to verify information, and to identify information for docketing to support the preparation of an environmental assessment (EA), as further discussed below. Specifically, the NRC staff will be identifying pertinent environmental data, reviewing the facility, and seeking clarifications regarding information provided in the ER.

2.

Environmental Audit Bases The NRC's implementing regulations (Title 10 of the Code of Federal Regulations (10 CFR) Part 51, "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions.) define specific actions under the National Environmental Policy Act (NEPA), as amended, which require different levels of environmental analyses, including an environmental impact statement (EIS), EA, or categorical exclusion. The NRC does not have a prescribed regulatory framework to reauthorize power operations, and the proposed Federal actions are not identified as an action requiring an EIS under 10 CFR 51.20, Criteria for and identification of licensing and regulatory actions requiring environmental impact statements. The NRC staff has determined that the appropriate level of NEPA review is an EA. An EA is appropriate to determine whether a Finding of No Significant Impact can be made or if, based on the EA, an EIS is appropriate. Given the NRC staff is preparing an EA, much of the regulatory basis is centered in 10 CFR 51.41 Requirement to submit environmental information. Where applicable, the staffs associated environmental review will be performed in accordance with the Office of Nuclear Reactor Regulation Office Instruction LIC-203, Revision 4, Procedural Guidance for Preparing Categorical Exclusions, Environmental Assessments, and Considering Environmental Issues (ML20016A379).

3 3.

Environmental Audit Scope The audit will focus on information provided in CEGs ER and supporting documentation. The scope of this environmental audit is to ensure the NRC staff has the information necessary to complete an EA and to identify issues which are significant and those which can be eliminated from detailed analysis. Audit team members will review the documents and other requested information made available on the CCEC online reference portal identified on the Environmental Information Needs and Document Requests list (Enclosure 2) and discuss any questions and additional information needs with the applicants subject matter experts (SMEs).

4.

Information and Other Material Necessary for the Environmental Audit As identified in the Environmental Audit and Information Needs (Enclosure 2).

5.

Environmental Audit Team Members and Resource Assignments The environmental audit team members and their assignments are shown in the table below.

Discipline NRC/PNNL* Team Members Environmental Review Supervisor Steve Koenick Environmental Project Manager/General Topics Kevin Folk Environmental Project Manager (Backup)

Ashley Waldron DOE Representative, Energy Dominance Financing-Environmental Compliance Alicia Williamson, DOE Air Quality, Meteorology, Climatology Nancy Martinez Aquatic Resources Briana Arlene; Caitlin Wessel, PNNL Federally Protected Ecological Resources Mitchell Dehmer Geologic Environment Gerry Stirewalt Greenhouse Gas Emissions/Climate Change Nancy Martinez Groundwater Resources Gerry Stirewalt Historic and Cultural Resources Jennifer Davis; Cyler Conrad, PNNL Human Health Donald Palmrose Land Use and Visual Resources Jeffrey Rikhoff Noise Nancy Martinez Postulated Accidents/ Severe Accident Mitigation Alt.

William Rautzen; John Parillo Reasonable Alternatives Bradley Werling Socioeconomics Jeffrey Rikhoff Spent Nuclear Fuel Donald Palmrose Surface Water Resources Lloyd Desotell Termination of Operations/Decommissioning Donald Palmrose Terrestrial Resources Mitchell Dehmer Uranium Fuel Cycle Donald Palmrose Waste Management (Radiological and Non-Radiological)

Donald Palmrose

  • DOE=Department of Energy (Cooperating Agency); NRC=Nuclear Regulatory Commission; Pacific Northwest National Laboratory (NRC contractor).

4 6.

Logistics An environmental audit (virtual) will be conducted remotely during the week of February 2, 2026, followed by a site visit the week of February 16, 2026. An entrance meeting will be held at the beginning of the audit and an exit meeting will be held following the site visit.

7.

Special Requests CEG staff and contractors who are SMEs in the disciplines identified on the environmental audit needs list should be available for interviews and tours, as applicable.

8.

Deliverables An audit summary report will be issued by the NRC staff within 30 days from the end of the environmental audit.

Crane Clean Energy Center Restart Environmental Audit and Information Needs Described below in three categories (i.e., tours, meetings, and information needs) are the information needs of the Nuclear Regulatory Commission (NRC) staff, supported by Pacific Northwest National Laboratory (PNNL), related to the submittals necessary to reauthorize power operations at Christopher M. Crane Clean Energy Center (CCEC). Information needs are identified as either resource-specific questions or document requests. Please arrange for the tours and meetings to occur during either the virtual environmental audit or site visit, as specified below. Additionally, the staff requests that responses to the information needs related to the October 2025 Environmental Report (ER) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25303A293) and related environmental matters be made available on the electronic portal at least one week prior to the start of the audit. The staff further requests that subject matter experts (SMEs) be available to discuss these items with the NRC staff.

Virtual Tours Please arrange for, and provide appropriate SMEs to contribute to, the following virtual tours.

Number and Title Features Observed Participants*

1.

General site Virtual walk-through of the following via photographs and/or diagrams:

Exterior grounds of the CCEC site and Three Mile Island vicinity, including training center on mainland In-scope transmission lines Historic and cultural sites Independent Spent Fuel Storage Installation (ISFSI)

Plant views from publicly accessible areas Location of major facilities and structures that have been or will be modified or refurbished to support operations (e.g., Cooling Tower B)

Area of the nature-like fishway associated with the York Haven Dam All NRC and PNNL staff, and DOE representatives 2.

Plant intake and discharge locations Virtual walk-through of the following, as applicable, via photographs and/or diagrams:

Intake and views of surrounding area Intake pump and screenhouse Intake traveling screens/trash baskets Circulating water pumphouse and desilting basin Cooling water intake system pathway from intake to discharge structure Discharge and views of surrounding area Main stormwater outfall All NRC and PNNL staff, and DOE representatives

  • DOE=Department of Energy (Cooperating Agency); NRC=Nuclear Regulatory Commission; Pacific Northwest National Laboratory (NRC contractor).

2 In-person Tours Please arrange for, and provide appropriate SMEs to contribute to, the following in-person tours as part of the NRCs site visit.

Number and Title Features Observed Participants* [Tentative]

1.

General site and features of interest Driving or walking survey of the following:

Plant views from publicly accessible areas Exterior grounds of the CCEC site and Three Mile Island vicinity, including major plant structures Location of major facilities and structures that have been or will be modified or refurbished to support operations, particularly those with ground disturbance Cooling water intake system pathway from intake to main discharge structure Historic and cultural sites Steve Koenick, Kevin Folk, Jennifer Davis (NRC); Cyler Conrad, (PNNL); Alicia Williamson (DOE)

  • DOE=Department of Energy (Cooperating Agency); NRC=Nuclear Regulatory Commission; Pacific Northwest National Laboratory (NRC contractor).

Meetings Please be prepared to support the specified breakout meetings with the appropriate SME(s) and/or the contractor(s) regarding the following topics. Those in attendance should be prepared to discuss the corresponding questions as described in the Environmental Information Needs and Document Requests section below. The staff intends to use these meetings, as needed, to resolve or clarify any outstanding data needs or questions arising from the environmental audit. NRC intends to leverage virtual breakouts to the extent possible.

Air Quality and Noise (virtual)

Aquatic Resources (virtual with any necessary follow-up on site)

Federally Protected Ecological Resources General topics (virtual with any necessary follow-up on site)

Geologic Environment (virtual with any necessary follow-up on site)

Greenhouse Gas Emissions and Climate Change (virtual)

Groundwater Resources (virtual)

Historic and Cultural Resources (virtual and in-person)

Human Health (virtual)

Postulated Accidents (virtual)

Surface Water Resources (virtual with any necessary follow-up on site)

Terrestrial Resources (virtual)

Spent Nuclear Fuel (virtual)

3 Environmental Information Needs and Document Requests Information needs and document requests are identified below by environmental resource area.

Issues applicable to these questions are provided along with the responsible NRC, and any supporting PNNL, SME, as appropriate.

General (Kevin Folk, with support from Other NRC staff)

Audit Needs The following requests are generic to more than one environmental resource area.

GEN-1 Section 2.2.4 of the ER (Tables 2.2-1 and 2.2-2) summarizes the permits and approvals CCEC currently possesses or those that Constellation Energy Generation, LLC (CEG) has plans to modify or request reinstatement to support the resumption of CCEC operations. Provide any status updates to the listed information including schedule(s) for completing application submittals. Note: the NRC staff may request copies of major new or modified permits and/or applications for review.

GEN-2 Section 2.2.1 of the ER states that the timeframe of preparations activities is 2024 to resumption of power operations. In addition, the term preparation activities is otherwise used throughout the ER. Specify the expected duration (in months or years) of preparation activities for the resumption of power operations and provide a summary description of the nature of indicated preparation activities.

GEN-3 Section 2.2.1 of the ER states that to facilitate plant restoration, CEG created a process to systematically group systems, structures, and components (SSCs),

evaluate their condition, and identify what is needed to restore them to operational status and supporting safe and reliable plant operation. The ER further states that planned activities in support of restart include, but are not limited to, the following:

Reconfiguration and modification of site structures and facilities, as needed.

Restoration of SSCs required for plant operation.

Restoration of radwaste processing and release capability comparable to normal power operations in accordance with regulatory limits and requirements.

Reestablishing operating procedures and regulatory-required programs necessary to support power operations.

Obtaining state-level permits and approvals, as needed.

Provide a listing and brief description of the site structures and facilities that will need to be, or have already been, refurbished and/or modified or replaced as referenced in the ER and other communications (ML25077A097) (e.g., Cooling Tower B, reactor building industrial coolers, north bridge repairs, underground diesel fuel storage tank, etc.) and summarize the nature of the restoration activities including the area affected (size, location, and if any area is previously undisturbed land), and timeframe. Illustrate the project locations on a suitable map of the CCEC site, if possible.

GEN-4 Sections 4.2.1.1, 4.4.1 and Table 5.0-1 of the ER indicate that on-site staffing is projected to peak around approximately 1,200 during restart preparations and approximately 600 following resumption of operations. Confirm that these statements remain valid and provide actual peak and projected workforce at CCEC at the end of 2024, 2025, and 2026.

4 Document Needs GEN-5 As cited in Table 2.2-2 of the ER, provide copies of the following new or modified permits if received, for NRC staff review, or CEGs applications, if receipt remains pending: (1) Surface water withdrawal, groundwater withdrawal, and consumptive water use permit, (2) Synthetic minor operating permit, (3) National Pollutant Discharge Elimination System (NPDES) permit, and (4) Certification of water quality standards.

Environmental Review Topic-Specific Requests The following requests are specific to a single environmental review topic or subject matter area. If a topic is not provided below, the discussions held in response to the generic requests above are expected to fully cover that topic.

Air Quality, Meteorology, Climatology (Nancy Martinez)

Audit Needs AQN-1 Clarify whether the on-site meteorological tower/monitoring system has remained in operation since 2019. If available, also provide the following on-site meteorological data for the last five years to assist the NRC staff with describing meteorological characteristics of the site and vicinity:

Average monthly and annual temperature Average monthly and annual precipitation Average annual wind speed Prevailing wind direction AQN-2 Table 3.6-1 of the ER includes reported air pollutant emissions from 2020 through 2022. Identify the air emission sources (e.g., diesel generators, cooling towers, etc.)

accounted for in Table 3.6-1 of the ER.

AQN-3 CCEC is in Dauphin County, Pennsylvania, which is designated a maintenance area for particulate matter (PM2.5). In accordance with the Clean Air Act, the NRC will need to determine whether the proposed action's air pollutant emissions exceed threshold levels specified in Title 40 of the Code of Federal Regulations (40 CFR) 93.153(b) and if a conformity determination is required. The ER presents some emissions data in Table 3.6-1 and Table 4.6-2 of the ER for certain on-site sources, but does not provide estimated air criteria pollutant emissions from preparation activities for resumption of power operations (e.g., cooling tower B internal fill structure, reconfiguration and modification of site structures and facilities), worker vehicles or deliveries during preparation for resumption of power operations/restart activities, or worker vehicles or deliveries during operations of the facility.

Furthermore, Table 4.6-2 of the ER does not present emissions for particulate matter less than 2.5 microns (PM2.5).

A. Provide estimated emissions of criteria pollutants (carbon monoxide, sulfur dioxide, particulate matter, etc.) and their precursors (e.g., volatile organic compounds) associated with:

1.

Preparation activities for the resumption of power operations. Emissions should be provided as total emissions in tons throughout the duration that preparation activities will take place.

5 2.

Worker vehicles and deliveries during preparation activities for the resumption of power operations. Emissions should be provided as total emissions in tons throughout the duration that the preparation of activities will take place.

3.

Worker vehicle and deliveries during operations of CCEC. Emissions should be provided as annual emissions (tons/year).

B. Provide annual estimated emissions for PM2.5 for the equipment accounted in Table 4.6-2 of the ER.

Provide all assumptions and calculations supporting estimated air pollutant emissions for A and B above.

Document Needs AQN-4 Provide copies of the supporting calculations or documentation (e.g., emission statement reports submitted to the air permitting agency) for the emissions presented in Table 4.6-2 of the ER for the 2014-2018 period of record.

Noise (Nancy Martinez)

Audit Needs NOI-1 The ER mentions noise impacts within the context of various resource area discussions, but noise impacts from restart activities and operation of the facility are not fully considered. Provide the following information:

1.

Primary noise sources during preparation activities for resuming power operations 2.

Primary noise sources during operations of CCEC 3.

Distance between the nearest noise sensitive receptor(s) and primary noise sources during preparation activities for resuming power operations 4.

Distance between the nearest noise sensitive receptor(s) and primary noise sources during operations of CCEC NOI-2 Discuss whether there are anticipated noticeable increases in noise levels at noise sensitive receptors from preparation activities for resuming power operations and from operations of CCEC. Provide a basis for why they would be or not be noticeable.

NOI-3 Did CEG receive any noise complaints during the 5-year period prior to plant shutdown in 2019? If so, provide a discussion regarding the noise complaints and any actions taken by CEG with respect to the noise complaints.

NOI-4 Did CEG conduct any on-site or off-site noise surveys during previous facility operations? If so, please provide a copy of the survey(s) for review.

Document Needs None identified at present.

6 Geologic Environment (Gerry Stirewalt)

Audit Needs GE-1 Provide for review the most current geologic/hydrogeologic cross section or a geologic/hydrogeologic column for the site illustrating the shallow unconfined fluvial/alluvial aquifer and the underlying deeper bedrock primary aquifer, the Triassic Gettysburg Formation. These materials will assist NRC staff with assessment of potential groundwater impacts. If a geologic/hydrogeologic column can be provided, consider including available data on thicknesses, lithologic descriptions, elevations of unit tops, and hydrogeologic parameters (e.g., permeability), if feasible.

Document Needs GE-2 If geologic/hydrogeologic cross-sections and/or columns are available, provide the appropriate reference or source documents for review by the staff (e.g., site hydrogeologic report, site conceptual model, or groundwater protection program documents).

Water Resources - Surface Water (Lloyd Desotell)

Audit Needs SW-1 ER Section 4.2.2.1 states that drained cooling tower basins will be filled using water from the Susquehanna River. Please provide the approximate volume of water required to refill these basins.

SW-2 ER Section 2.2.1 states that CEG has performed material condition reviews of plant equipment in support of resumption of power operations. Confirm that inspections of the intake, discharge and stormwater systems will occur to ensure their operability to support resumption of power operations. Provide a brief description of the inspection protocols with reference to the relevant procedures.

SW-3 What water source will be used for construction-related activities (e.g., dust suppression, concrete mixing, etc.)? Provide the approximate construction-related water demand, if known.

SW-4 ER Section 4.2.2.2 states that upon resumption of power operations, surface water use is expected to be similar to amounts from prior operations. This section further states that consumptive use is expected to be slightly higher than prior operations.

Quantify the projected consumptive use increase and describe the operational changes that may result in increased consumptive use.

SW-5 ER Section 4.2.2.2 states that CEG expects the Pennsylvania Department of Environmental Protection (PADEP) to decrease the thermal discharge limit from 115°F to 110°F. As a result of this expected lower limit, CEG expects that thermal discharges to the Susquehanna River would be below the previous power operations. Describe the operational changes planned to reduce thermal discharges below previous power operations.

Document Needs SW-6 ER Section 4.2.2.2 states that CEG consolidated the requirements of the individual pollution prevention and spill response programs into a single facility plan. Provide this consolidated plan for NRC staff review.

7 Water Resources - Groundwater Resources (Gerry Stirewalt)

Audit Needs GW-1 ER Section 3.2.1.1 indicates that there are eight (8) water supply wells associated with the CCEC. Provide a site map that clearly indicates the water supply well locations.

GW-2 ER Section 3.2.1.2 indicates that the screened aquifers include overburden, upper bedrock, and lower bedrock. Clarify the geologic/hydrogeologic distinction between the upper and lower bedrock aquifers.

GW-3 ER Section 3.2.1.2 indicates that over 2020 through 2024, a maximum tritium concentration of 2,770 picocuries per liter (pCi/L) was detected in monitoring well MW-TMI-21D in the upper bedrock aquifer, with a maximum concentration of 553 pCi/L in Well C in the lower bedrock aquifer. All measurements were below the U.S.

Environmental Protection Agency drinking water maximum contaminant level (MCL) of 20,000 pCi/L. Provide for review an updated layout of the sites radiological groundwater protection program monitoring well network, such as an update to Figure 2.3-1 in the 2008 environmental report (ML080220255) or similar graphic.

Document Needs None identified at present.

Terrestrial Resources (Mitchell Dehmer)

Audit Needs TER-1 Provide a description of the lighting regime (color of light, direction of light) for on-site lighting structures and any best management practices (BMPs) related to lighting for restart activities (e.g., light usage at night, buffer zones, etc.).

TER-2 Provide details regarding where herbicides, pesticides, and mowing are used/conducted on site as well as the method, location, purpose, and frequency of use.

TER-3 ER Section 3.3.1.3 discusses several terrestrial resource studies and monitoring.

Clarify if the amphibian identification and tracking as well as the raptor monitoring will resume in conjunction with resumption of operations.

TER-4 Clarify what preparation activities entails at the training center. Provide a description to include activity, length of time, and other associated impacts as a result of the preparation activities.

TER-5 ER Section 4.1.2 discusses natural-draft cooling tower (NDCT) impacts from resumption of power operations. Confirm or describe the following regarding the NDCTs: (1) the NDCTs utilize drift eliminators; (2) no substantial increase in drift rate or chemical composition is expected as compared to operations prior to 2019; (3) no substantial increase in particulate matter emissions as compared to operations prior to 2019; (4) expected length of the visual plume; and (5) prior to the 2019 shutdown, have there been any observable effects on vegetation in the vicinity of CCEC? If so, describe the effects including the species impacted and type, location, and timing of impacts.

TER-6 ER Section 3.3.1.4.1 describes avian incidents at CCEC. Specify whether there have been any reported avian incidents from 2015-2019 and whether there have been any

8 reported avian incidents since the time the ER was prepared. If so, provide the following, if available: (1) a summary of bird mortalities or injuries (species, date, cause if known, associated structures or buildings, if any) in chronological order; and (2) associated reports for each incident, if any.

Document Needs TER-7 Provide a copy of the Environmental Emergency Response Plan for review; this will support the NRC staffs review for federally protected ecological resources.

TER-8 Provide a copy of the Avian and Wildlife Management Plan for review.

TER-9 Provide a copy of the Wildlife Habitat Council Wildlife Management Plan, which includes ecological background information and wildlife inventory, for review.

TER-10 Provide a copy of the Pesticide Management Procedure for review; this will support the NRC staff's review for federally protected ecological resources.

Aquatic Resources (Briana Arlene, NRC; Caitlin Wessel, PNNL)

Audit Needs AQU-1 Provide an update on the status of CEGs request for impingement mortality and entrainment best technology available determinations from PADEP in the NPDES March 7, 2025, permit application.

AQU-2 Describe the potential impacts that the aquatic environment would experience upon initial restart, including impacts related to the resumption of water withdrawals and discharges, related flow regime changes, and potential water use conflicts.

AQU-3 Section 4.2.2.1 of the ER states that approximately 682,000 gallons of Susquehanna River water will be required to fill the spent fuel pool, reactor vessel, and piping in preparation for restart. Provide additional information regarding impacts associated with filling the cooling tower basins on aquatic resources, including impingement mortality, entrainment, and water use conflicts. Include timing and duration of activities, as well as approximations of the flow rate or consumption of water per minute or day.

AQU-4 Section 4.2.2.2 of the ER states that consumptive water use is expected to be slightly higher during future operations than during prior operations. Clarify and explain the reasoning behind this change and indicate whether any changes in the configuration of the heat dissipation system during future operations would contribute to the increase in consumptive water use (see also SW-4). Additionally, will the increase in consumptive water use change the flow rate at the intake or discharge? If so, please quantify.

AQU-5 Section 4.2.2.2 of the ER states that dredging of the intake bay is anticipated to be conducted during resumption of power operations. Does CEG have updated information concerning when it may submit a dredging permit application to the U.S.

Army Corps of Engineers or when dredging may take place (see also GEN-1)?

Document Needs AQU-6 Provide copies of the following studies that are referenced in Item 18 of CEGs March 7, 2025, NPDES permit renewal application, to inform the NRC staffs review:

a.

Mussel survey data conducted by York Haven Power Company, LLC (YHPC 2011) near the York Haven Dam in 2010.

9 b.

Upstream and Downstream Fish passage study at the York Haven Hydroelectric Project (Kleinschmidt Associates 2022 and 2023).

c.

Fish passage data through the East Channel fishway during spring operations from 2000-2012 (FERC 2012).

d.

Any other aquatic ecology studies of York Haven Pool in support of Susquehanna River Hydroelectric project licensing (FERC 2012 and FERC 2014).

Federally Protected Ecological Resources (Mitchell Dehmer)

Audit Needs FPE-1 In the ER, CEG finds that thermal and chemical effluent would have no effect on the green floater based on the fact that there have been no NPDES notice of violations or fish kills from 2020-2024. However, because the plant was not operating during this period, this does not represent the types of impacts that the green floater would experience from resumption of power operations over the remainder of the renewed operating license period. Describe the potential impacts on the green floater associated with the proposed action based on anticipated water withdrawal volumes and flow rates, thermal effluent discharge temperatures and spatial plume characteristics, chemical effluent discharge information, and water use conflicts that would occur during operations. This information is needed with respect to 50 CFR 402.12(f)(4).

FPE-2 Specify BMPs and avoidance and mitigation measures CEG plans to implement during preparation activities and following the resumption of operations as related to conservation of federally listed species (i.e., speed limits, fugitive dust controls, noise, erosion, sedimentation, land clearing and earthmoving activities, demolition, lighting, etc.).

FPE-3 Provide responses to the following U.S. Fish and Wildlife Service determination keys (dkeys): (1) Northern Long-eared Bat and Tricolored Bat Range-wide dkey (NorthernLong-earedBatandTricoloredBatRange-wideDeterminationKeyOverview.pdf); and (2) Northeast Endangered Species dkey (NortheastEndangeredSpeciesDeterminationKeyOverview.pdf).

FPE-4 ER Section 3.3.1.3 discusses the sites previous bat monitoring program. Clarify whether the bat monitoring program will restart as part of CCEC operations?

FPE-5 Provide a diagram or be able to discuss where suitable roosting and maternity habitat exists within the action area as indicated in ER Section 3.3.3.1.2.

FPE-6 Describe and list the known types of machinery that will be utilized as part of restart activities. Provide the type of equipment, frequency of usage, and duration of usage for each piece of equipment.

Document Needs FPE-7 Provide a copy of the bat study as referenced in ER Section 3.3.1.3.1.

10 Historic and Cultural Resources (Jennifer Davis, NRC; Cyler Conrad, PNNL)

Audit Needs HCR-1 Has the cultural resources management plan (CRMP) and the Cultural Resources Protection Plan, been updated, or is a revision anticipated as part of the restart project?

HCR-2 Section 4.5.1 of the ER states that the CRMP provides a framework for CEG to assess the potential impact that facility modifications or new construction may have on the Three Mile Island Nuclear Station, Unit 2 (TMI-2) historic district and other historic and cultural resources. Please provide a knowledgeable person to discuss the processes outlined in the CRMP or Cultural Resources Protection Plan to mitigate any potential impacts to the TMI-2 historic district and other historic properties (historic and cultural resources) from construction activities at CCEC associated with restart activities.

HCR-3 Have the protocols for unanticipated discoveries been updated, or is a revision planned as part of the restart project? Describe the process followed if human remains or archaeological materials are discovered, including coordination with local law enforcement and the Pennsylvania State Historic Preservation Office (SHPO).

HCR-4 ER Section 4.5.1 notes that CEG has an archaeological resources erosion monitoring plan. Have there been any unanticipated discoveries of human remains or archaeological resources resulting from erosion since the 2009 License Renewal Supplemental Environmental Impact Statement (LR SEIS; NUREG-1437, Supplement 37; ML091751063) was issued?

Document Needs HCR-5 Provide for review a copy of the CRMP, Cultural Resources Protection Plan, and CEGs standard protocols for environmental reviews of facility operations and activities and for excavations as referenced in ER Section 3.5.

HCR-6 Provide a copy of the protocol for unanticipated discoveries as referenced in ER Section 3.5.

HCR-7 Provide a copy of the archaeological resources erosion monitoring plan referenced in ER Section 3.5.

HCR-8 Provide access to consultation or communication records with the SHPO and/or Indian Tribes regarding the CCEC restart.

Human Health (Donald Palmrose)

Audit Needs HH-1 ER Sections 2.1.2 and 3.7.1.3 do not specify whether CCEC electrical safety procedures adhere to the National Electrical Safety Code (NESC). Clarify whether plant or corporate procedures address adherence to the NESC.

HH-2 ER Section 3.7.1.1 states that CCEC submitted Occupational Safety and Health Administration (OSHA) form 300A for the years 2020 through 2024, but no reference is provided. Clarify or provide a reference.

HH-3 Discuss the reported administrative releases for the year 2025. As stated in ER Section 3.7.2.1, 12 administrative releases are reported annually for the years 2020

11 through 2024 due to the continuous, low-level migration of existing tritium in on-site groundwater to the river via known hydrologic pathways.

Document Needs HH-4 Provide access to the electrical safety program and the industrial safety program documents (e.g., CCECs OSHA form 300A submittals for the years 2020 through 2024) for the staff to verify adherence to the NESC and compliance with the OSHA standards in 29 CFR Parts 1910 and 1926 (as stated in ER Section 3.7.1.1).

HH-5 Provide access to the year 2025 administrative release reports due to the migration of existing tritium in on-site groundwater to the river via known hydrologic pathways.

Spent Nuclear Fuel (Donal Palmrose)

Audit Needs SNF-1 Provide a status and inventory of the spent fuel pool regarding the use of the fuel currently stored at CCEC along with initial re-loading strategy. This information should include re-loading plans for fuel on-site and fraction of core loading that would be additional fresh fuel to be shipped to the site for the first re-loading. The ER did not provide a description of intended fuel characteristics to be used for the first core re-load related to the proposed action.

Document Needs None identified at present.

Greenhouse Gas Emissions and Climate Change (Nancy Martinez)

Audit Needs GHG-1 Table 3.6-2 of the ER presents CCEC Greenhouse Gas (GHG) Emissions for 2020-2024 and Table 4.6-3 of the ER presents CCEC GHG Emissions for the 2014-2018 timeframe. The ER discusses that data for mobile sources is not compiled or reported, except for fleet vehicles. Provide the following information: Total number of truck deliveries during the duration of preparation activities.

GHG-2 Section 4.6.2 of the ER identifies that two environmental resources (air quality and surface water resources) may experience incremental impacts of climate change and the continued operation of the plant beyond the baseline conditions. Clarify to what extent climate change could affect the baseline conditions of the affected environment for air quality and surface water resources.

Document Needs None identified at present.

Postulated Accidents/Severe Accident Mitigation Alternatives (SAMA) (William Rautzen)

Audit Needs SAMA-1 ER Section 4.7.2.3 contains CCEC's postulated accidents discussion. Confirm, regarding external events and internal events, that the 2009 LR SEIS values of 2.37 x 10-5 (external) and 8.11 x 10-5 (external, flooding) are the current models of record Core Damage Frequency (CDF) for CCEC. If they are not the current models of record, please provide those numbers and any information regarding the change(s).

12 SAMA-2 Confirm, regarding seismic CDF, that the 2009 LR SEIS value of 3.21 x 10-5 is the current model of record for CCEC. If it is not the current model of record, please provide the updated model and any information regarding the change.

SAMA-3 Confirm, regarding fire CDF, that the 2009 LR SEIS value of 1.22 x 10-5 is the current model of record for CCEC. If it is not the current model of record, please provide the updated model and any information regarding the change.

SAMA-4 Confirm that CCEC will not be significantly different from the pre-decommissioned plant, except for matters like age related replacements, etc. and that any changes or plant improvements are/would be aimed at operational reliability safety, which would support a lower CDF than used in the license renewal SAMA analysis.

Document Needs None identified at present.

Crane Clean Energy Center Restart - Environmental Audit Schedule Tuesday, February 3, 2026 START END ACTIVITY/

PARTICIPANTS 9:00 a.m.

9:30 a.m.

Entrance Meeting; U.S. Nuclear Regulatory Commission (NRC),

Constellation Energy Generation (CEG), U.S. Department of Energy (DOE), and contractors 9:30 a.m.

10:30 a.m.

Virtual Tours; NRC, CEG, DOE, and contractors 10:30 a.m.

11:00 a.m.

Meeting 1 (Virtual); NRC, CEG, DOE, and contractor subject matter experts (SMEs) 11:00 a.m.

12:00 p.m.

Meeting 2 (Virtual); NRC, CEG, DOE, and contractor SMEs 12:00 p.m.

1:00 p.m.

Lunch Break 1:00 p.m.

2:00 p.m.

Meeting 3 (Virtual); NRC, CEG, DOE, and contractor SMEs 2:00 p.m.

3:00 p.m.

Meeting 4 (Virtual); NRC, CEG, DOE, and contractor SMEs 3:30 p.m.

4:00 p.m.

Daily Closeout Wednesday, February 4, 2026 START END ACTIVITY/

PARTICIPANTS 9:00 a.m.

10:00 a.m.

Meeting 5 (Virtual); NRC, CEG, and contractor SMEs 10:00 a.m.

11:00 a.m.

Meeting 6 (Virtual); NRC, CEG, and contractor SMEs 11:00 a.m.

12:00 p.m.

Meeting 7 (Virtual); NRC, CEG, and contractor SMEs 12:00 p.m.

1:00 p.m.

Lunch Break 1:00 p.m.

1:30 p.m.

Daily Closeout Wednesday, February 11, 2026 START END ACTIVITY/

PARTICIPANTS 9:00 a.m.

10:00 a.m.

Meeting 8 (Virtual); NRC, CEG, and contractor SMEs [if needed]

Thursday, February 19, 2026 START END ACTIVITY/

PARTICIPANTS 8:00 a.m.

12:00 p.m.

NRC Site Visit; NRC, CEG, DOE, and contractor SMEs Monday, February 23, 2026 START END ACTIVITY/

PARTICIPANTS 9:00 a.m.

10:00 a.m.

Exit Meeting; NRC, CEG, DOE and contractor SMEs Note: Meeting topics to be determined. All times are Eastern; start and end times are tentative and subject to change.