ML26013A055
| ML26013A055 | |
| Person / Time | |
|---|---|
| Site: | 05000615 |
| Issue date: | 12/19/2025 |
| From: | Jiang Y, Toohill S Breakthrough Institute |
| To: | Office of Administration |
| References | |
| NRC-2024-0146, 90FR50498 00009 | |
| Download: ML26013A055 (0) | |
Text
PUBLIC SUBMISSION As of: 1/13/26, 8:52 AM Received: December 19, 2025 Status: Pending_Post Tracking No. mjd-d21w-gm9c Comments Due: December 22, 2025 Submission Type: API Docket: NRC-2024-0146 Tennessee Valley Authority Clinch River Nuclear Site Exemption Comment On: NRC-2024-0146-0009 Tennessee Valley Authority; Clinch River Nuclear Site, Unit 1; Draft Supplemental Environmental Impact Statement Document: NRC-2024-0146-DRAFT-0009 Comment on FR Doc # 2025-19809 Submitter Information Email:spencer@thebreakthrough.org Organization:The Breakthrough Institute General Comment See attached file(s)
Attachments BTI Comment on Clinch River SEIS 1/13/26, 8:53 AM NRC-2024-0146-DRAFT-0009.html file:///C:/Users/BHB1/Downloads/NRC-2024-0146-DRAFT-0009.html 1/1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Madelyn Nagel, Antoinette Walker-Smith, Mary Neely Comment (9)
Publication Date:
11/7/2025 Citation: 90 FR 50498
December 19, 2025
Subject:
Supplemental Environmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site [Docket No. 50-615; NRC-2024-0146].
The Breakthrough Institute (BTI) appreciates this opportunity to comment on the U.S. Nuclear Regulatory Commissions (NRC) Draft Supplemental Environmental Impact Statement (SEIS) for the Tennessee Valley Authoritys (TVA) proposed Clinch River Nuclear Unit 1 (CRN-1) construction permit.1BTI is an independent 501(c)(3) global research center that advocates for appropriate regulation and oversight of nuclear reactors to enable the new and continued use of safe and clean nuclear energy. BTI acts in the public interest and does not receive funding from industry.
Overall, BTI supports NRCs conclusion that environmental impacts associated with issuing the construction permit are generally small across the evaluated categories, and that the project presents important benefits that would not be realized under the no-action alternative. We commend NRC staff for their thorough work in preparing this SEIS. We also appreciate the SEISs incorporation of amended National Environmental Policy Act (NEPA) requirements, especially in its treatment of the no-action alternative.
At the same time, we recommend several clarifications and expansions in the final SEIS to better align with amended NEPA §102(2)(C)(iii), strengthen analytical consistency, and set a strong precedent for future advanced reactor environmental reviews.
General Support for the Conclusion The purpose of the proposed project is to demonstrate the feasibility to license, construct, and operate a SMR at the Clinch River Site as well as to support the recommendations outlined in TVAs Integrated Resource Plan (IRP).2BTI agrees with the drafts overall conclusion that construction and operation of CRN-1 would result in small environmental impacts and that the project delivers meaningful benefits: including firm, dispatchable, zero-carbon electricity; 2U.S. Nuclear Regulatory Commission,SupplementalEnvironmental Impact Statement for a Construction Permit at the Clinch River Nuclear Site,Draft Report for Comment, IssuedNovember 2025, Page 1-1,ML25261A214, (HereinafterClinch River Draft SEIS).
1Federal Register, Tennessee Valley Authority; Clinch River Nuclear Site, Unit 1; Draft Supplemental Environmental Impact Statement,https://www.federalregister.gov/documents/2025/11/07/2025-19809/tennessee-valley-authority-clinch-river-nuclear-site-unit-1-draft-supplemental-environmental-impact.
opportunities for SMR technology demonstration; and regional socioeconomic gains. We support the conclusions and the proposed action that the construction permit be issued.
The draft SEIS thoroughly evaluates potential impacts to air quality, surface water, groundwater, aquatic and terrestrial ecology, threatened and endangered species, land use, socioeconomics, transportation, cultural resources, noise, radiological safety, and other pertinent impacts. Across these categories, NRC staff consistently concludes impacts would beSmall to Moderate, provided TVA implements the identified mitigation and best management practices. Out of the 14 environmental impacts described in the SEIS, the proposed project at the Clinch River Nuclear site has the same level of impact on 12 of the categories compared to the ESP EIS issued in 2019.3 The only category changed was Historic and Cultural Resources. It was stated asModerate to Largein the EP EIS, but revised findings show theimpact will beSmall to Moderate.
The need for power analysis in the draft SEIS correctly relies upon TVAs IRP analysis to show that new capacity is needed to replace the retiring and expiring capacity in the region and support long-term economic growth.4We support the NRCs inclusionof the fact that deploying SMRs would make this technology available for meeting future power demands.
The No-Action Alternative We appreciate that the draft SEIS identifies alternatives to the proposed action and support that no-action is the only reasonable alternative at the construction-permit stage, consistent with TVAs role in determining energy needs and the prior ESP review. The SEIS makes notable progress in complying with amended NEPA §102(2)(C)(iii),5whichrequires agencies to evaluate the negative environmental impacts of not implementing the proposed action. This is a meaningful improvement over prior SEIS reports. We particularly note that the draft takes an important step beyond earlier environmental draft reports by acknowledging that failing to proceed with CRN-1 could delay or impede the development of BWRX-300 SMR technology.6 6Clinch River Draft SEIS, Page 4-1,ML25261A214.
5National Environmental Policy Act of 1969 § 102(2)(C)(iii), 42 U.S.C. § 4332.
4Clinch River Draft SEIS, Page 5-8,ML25261A214.
3U.S. Nuclear Regulatory Commission,EnvironmentalImpact Statement for an Early Site Permit at the Clinch River Nuclear Site, Final Report, April 2019,ML19073A099.
The draft states:
Under the no-action alternative, the NRC would not issue a CP to build CRN-1. The applicant could not build the proposed CRN-1 and would therefore not have an opportunity to demonstrate the SMR technology. While forgoing the opportunities provided by CRN-1 may not necessarily preclude future development of reactors using BWRX-300 technology, it could slow or impede safe and efficient development of the technology.7 This acknowledgment is commendable and aligns with congressional intent in recent NEPA amendments. BTI agrees that the no-action alternative would limit the opportunity to demonstrate BWRX-300 technology; potentially slow or impede safe, efficient SMR development; result in only minimal avoided impacts at the Clinch River site; and not prevent future industrial or governmental development of the site, which may cause similar impacts later.
However, the draft SEIS stops short of fully analyzing how this delay constitutes a negative environmental impact, as required under amended NEPA. The no-action analysis leaves multiple stones unturned, namely lost emissions reductions, lost system efficiencies, lost economic development, and more. In addition, the SEISs own cost-benefit section identifies benefits that warrant explicit integration into the no-action evaluation.8Under NEPA, as amended, the NRC must analyze the negative environmental impacts of not implementing the action, including foregone environmental benefits that are intrinsic to the proposed project. Strengthening these areas in the final SEIS will improve analytical consistency and provide a clearer, more accurate assessment of the environmental significance of advanced nuclear deployment.
Expanded Analysis Delaying SMR deployment under the no-action alternative carries significant direct and indirect environmental consequences. These consequences arise from TVAs documented capacity needs, the critical role that firm clean energy plays, and the unique benefits associated with demonstrating advanced nuclear technologies, such as the BWRX-300. The final SEIS should explicitly evaluate these environmental effects, consistent with amended NEPA §102(2)(C)(iii).
8Clinch River Draft SEIS, Page 4-2,ML25261A214.
7Clinch River Draft SEIS, Page 4-1,ML25261A214.
First, the absence of the project would result in foregone emissions reductions. Because SMRs provide firm, dispatchable, zero-carbon capacity, TVA would, in the absence of this project, rely more heavily on existing natural gas and coal units to meet system capacity and reliability requirements. TVAs projected capacity gaps make clear that these needs do not disappear under no-action (See Figures 5-4 and 5-5).9 Second, the delay in integrating firm clean capacity has broader system implications. Firm resources like advanced nuclear are essential complements to variable renewable generation by providing stability, capacity adequacy, and ancillary services that would otherwise be supplied by fossil-fired units.
Third, foregoing the proposed project eliminates an important near-term opportunity for technological learning and cost reduction in advanced nuclear deployment. Early demonstration projects accelerate cost improvements, streamline regulatory processes, deepen learning and experience, and build commercial readiness. These improvements, in turn, help lower the cost and risk of subsequent SMR projects.
Fourth, the project would bring infrastructure improvements and socioeconomic gains that have environmentally relevant implications. The SEIS identifies benefits such as emission reduction, demonstration of technological capabilities, improved site and grid infrastructure, and local socioeconomic benefits. Under the no-action alternative, none of these occur.
The SEISs own cost-benefit analysis reinforces these points. The document identifies demonstration of technological capabilities, emission reduction, infrastructure improvements, and socioeconomic benefits as the primary benefits of the proposed action.10If these benefits accrue only under the proposed action, then the no-action alternative necessarily involves the loss of those benefits. The current draft SEIS acknowledges these benefits qualitatively but does not integrate their absence into the no-action environmental impact determination.
Recommendations To strengthen analytical consistency, fully meet the requirements of amended NEPA, and provide a more accurate characterization of the consequences of forgoing CRN-1, BTI respectfully 10Clinch River Draft SEIS, Pages 4-2 to 4-4,ML25261A214.
9Clinch River Draft SEIS, Pages 5-6 and 5-7,ML25261A214.
recommends that the final SEIS explicitly integrate lost benefits into the no-action alternative section:
- 1. Expand the no-action alternative analysisto explicitly consider the environmental consequences of delaying SMR deployment, including system-level emissions impacts and foregone technological learning.
- 2. Integrate the cost-benefit findingsinto the no-actionanalysis for consistency, especially those relating to emissions, technology demonstration, and socioeconomic benefits as listed in the cost-benefit analysis.
These refinements will strengthen the SEIS, improve transparency, and enhance the quality of NRC environmental reviews for future advanced nuclear projects.
Conclusion Breakthrough supports the NRCs conclusion that issuing the construction permit for CRN-1 would result in generally small environmental impacts and provide meaningful environmental and system benefits. We appreciate the NRCs progress in addressing amended NEPA requirements and its recognition of the environmental significance of SMR technology development. This is a positive development and demonstrates that the NRC is actively adapting its analytical framework to meet Congresss direction to consider the negative environmental impacts of inaction.
We encourage NRC to further expand the no-action alternative analysis in the final SEIS to fully reflect the environmental implications of delaying or foregoing advanced nuclear deployment.
Even further, the NRC should embrace this requirement not as a technical adjustment, but as a shift in perspective. Doing so will improve analytical rigor, align the SEIS with statutory requirements, and support sound decision-making as advanced nuclear technologies become an increasingly important component of the nations clean energy future.
The NRC must continue this trajectory in future advanced reactor environmental reviews by building on the progress reflected in this SEIS and fully integrating amended NEPA requirements into a robust, forward-looking analytical framework. Once established, this precedent will shape all future NRC reviews. Applicants will face clearer expectations, the staff will have a consistent framework for balancing costs and benefits, and reviews will better reflect the true societal stakes
of energy choices. Over time, this will build public trust in NRC decisions and accelerate deployment of clean nuclear projects, making environmental reviews a driver of societal benefit rather than a bottleneck.
Sincerely, Spencer Toohill Nuclear Energy Innovation Analyst The Breakthrough Institute Joy Yue Jiang Energy Innovation Analyst The Breakthrough Institute