ML26029A124
| ML26029A124 | |
| Person / Time | |
|---|---|
| Site: | Triso-X |
| Issue date: | 01/28/2026 |
| From: | Wheeler J Triso-X |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| TXO-REG-LTR-0105 | |
| Download: ML26029A124 (0) | |
Text
TX0-REG-LTR-0105 - Environmental Report Updates See following pages for updates made to the Environmental Report.
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2026 1-15 Rev. 2 Table 1.4-1 (Sheet 1 of 5)
Permits and Approvals Required for Construction and Operation Agency Regulatory Authority Permit or Approval Activity Covered Status U.S. Nuclear Regulatory Commission National Environmental Policy Act (NEPA) 40 CFR 1500-1508 10 CFR 51 Environmental Assessment or Environmental Impact Statement in accordance with NEPA Analysis of impacts associated with construction, operation, and decommissioning at the HCS in support of NRC decision-making Addressed in this license application 10 CFR 70 Special Nuclear Material License Receipt, possession, use, and transfer of special nuclear material Addressed in this license application 10 CFR 71 Quality Assurance Program for Radiological Material Packages must be approved by NRC The use of NRC certified transportation packages QA Plan not yet submitted U.S. Environmental Protection Agency Clean Water Act 40 CFR 112 Spill Prevention, Control and Countermeasure (SPCC) Plans for Construction and Operation Storage of oil during construction and operation Section 7.0 of the Stormwater Pollution Prevention Plan prepared to support the Notice of Coverage under the General NPDES Permit for Stormwater Discharges associated with Construction Activity discusses spill prevention, management, and notification.
SPCC Plan for Operations not yet prepared U.S. Department of Transportation Hazardous Material Transportation Act 49 CFR 107 Certificate of Registration Transportation of hazardous materials Registration application not yet submitted U.S. Army Corps of Engineers Clean Water Act 33 CFR 320 - 331 Section 404 permit No jurisdictional waters were identified within the site.
However, two channels and one stream were identified within the project survey area, outside the site boundary, with the potential to be regulated by either the USACE and/or TDEC.
Likely not required; Preliminary JD was completed March 15, 2023. See Appendix 1A, Regulatory Correspondence.
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2026 1-16 Rev. 2 Table 1.4-1 (Sheet 2 of 5)
Permits and Approvals Required for Construction and Operation Agency Regulatory Authority Permit or Approval Activity Covered Status Tennessee Department of Environment and Conservation Clean Water Act Tennessee Water Quality Control Act of 1977 Section 401 Certification No jurisdictional waters were identified within the site.
However, two channels and one stream were identified within the project survey
- area, outside the site boundary, with the potential to be regulated by either the USACE and/or TDEC.
Not required; See TDEC Concurrence Letter dated May 24, 2022 in Appendix 1A, Regulatory Correspondence Tennessee Air Pollution Control Board, Department of Environment and Conservation Federal Clean Air Act Tenn. Code Ann. Title 68 Air Quality Construction Permit Required to construct a new air contaminant source, the facility has at least one (and possibly several) new effluent discharge stack Permit application submitted November 24, 2025.
Application accepted for review December 31, 2025.
Air Pollution Control Operating Permit Required to operate a new air contaminant
- source, the facility has at least one (and possibly several) new effluent discharge stack Permit application not yet submitted Tennessee Department of Environment and Conservation, Division of Water Resources Federal Clean Water Act Tenn. Code Ann. Title 69 Notice of Coverage under the General National Pollutant Discharge Elimination System (NPDES) Permit for Stormwater Discharges associated with Construction Activity Required for
- clearing, grading, or excavation that disturbs one or more acres Permit application approved; Notice of Coverage effective November 10, 2022. See Appendix 1A, Regulatory Correspondence.
Industrial Storm Water Discharge Permit Discharge of storm water runoff from the site during facility operation Permit application not yet submitted
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2026 1-17 Rev. 2 Table 1.4-1 (Sheet 3 of 5)
Permits and Approvals Required for Construction and Operation Agency Regulatory Authority Permit or Approval Activity Covered Status Tennessee Department of Environment and Conservation, Division of Solid Waste Management Tenn. Code Ann. §0400-12-01 Tenn. Code Ann. §0400-12-02 40 CFR 260 through 279 Hazardous Waste Permit Required for any person owning or operating a new or existing facility that treats, stores, or disposes of a hazardous waste Pending applicability Tenn. Code Ann. §68-212-101 Resource Conservation and Recovery Act 40 CFR 261 and 262 Acknowledgement of Notification of Hazardous Waste Activity Generation of hazardous waste Notification not yet submitted Tennessee Department of Environment and Conservation, Division of Radiological Health Chapter 0400-20-05, Standards for Protection Against Radiation 0400-20-19, Licensing and Registration Specific Radioactive Material License Required for source material and/or sealed sources above exempt quantities License application not yet submitted General Radioactive Material License Required for certain types of radioactive sources and devices containing radioactive material require the purchaser to have a general radioactive material license which is provided by the manufacturer License application not yet submitted Registration of X-Ray Producing Equipment The facility has several types of X-Ray equipment License application not yet submitted Radioactive Waste License-for-Delivery Transportation of radioactive waste into or within the State of Tennessee to a disposal/
processing facility License application not yet submitted 10 CFR 30 By-Product Material License Production, possession, and transfer of radioactive by-product material License application not yet submitted 10 CFR 40 Source Material License Possession, use, and transfer of radioactive source material License application not yet submitted
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2026 1-18 Rev. 2 Table 1.4-1 (Sheet 4 of 5)
Permits and Approvals Required for Construction and Operation Agency Regulatory Authority Permit or Approval Activity Covered Status City of Oak Ridge Community Development Department City of Oak Ridge Ordinance Site Plan Application A site plan must be submitted for approval before a land disturbance permit and/or building permit can be issued Preliminary Site Plan approved October 2022.
Traffic Study review completed with no comments August 2023. Revised Preliminary Site Plan approved March 2024. See Appendix 1A, Regulatory Correspondence.
City of Oak Ridge Ordinance Building Permit Construction of buildings Building Permit issued September 8, 2025.
City of Oak Ridge Ordinance Land Disturbance Permit Required for land disturbing activity that disturbs more than one acre of land. A required attachment is a TDEC Notice of Coverage under the General NPDES Permit for Stormwater Discharges associated with Construction Activity Land Disturbance Permit issued October 3, 2024. See Appendix 1A, Regulatory Correspondence.
City of Oak Ridge Ordinance Plumbing Permit Installation of plumbing systems Plumbing permit issued September 22, 2025.
City of Oak Ridge Ordinance Electrical Permit Installation of electrical systems Electrical permits issued September 22, 2025, and November 6, 2025.
Permit application for permanent power not yet submitted.
City of Oak Ridge Ordinance Mechanical Permit Installation of mechanical systems Permit application not yet submitted City of Oak Ridge Zoning Ordinance Zoning Approval Construction of a nuclear fuel fabrication facility Rezoning from IND-2 to IND-3 (heavy industrial district) was approved on September 12, 2022 and the Ordinance to amend the zoning became effective on September 22, 2022. See Appendix 1A, Regulatory Correspondence.
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 1 - Introduction of the Environmental Report January 2026 1-19 Rev. 2 Table 1.4-1 (Sheet 5 of 5)
Permits and Approvals Required for Construction and Operation Sources for identification of permit requirements: City of Oak Ridge, 2022; State of Tennessee, 2022; Tennessee Department of Environment and Conservation, Division of Water Resources, 2022; Tennessee Air Pollution Control Board, Department of Environment and Conservation, 2021; Roane County, 2022.
Agency Regulatory Authority Permit or Approval Activity Covered Status City of Oak Ridge Zoning Ordinance Special Exception Requiring Board of Zoning Appeals Approval Based on the judgment of the Board of Appeals to promote orderly industrial districts containing industries compatible with each other Not required, does not meet criteria.
City of Oak Ridge Zoning Ordinance Temporary Use Permit Installation of seasonal or non-permanent uses Not required, does not meet criteria.
Roane County Building Permit Construction of building The project is not located within unincorporated Roane County, therefore, please refer to City of Oak Ridge Regulations Zoning Construction of a nuclear fuel fabrication facility
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives January 2026 2-25 Rev. 4 Table 2.1-1a Yard Storage - Underground Tanks Ethanol For storage information, see the TRISO-X Fuel Fabrication Facility Site Emergency Plan and/or TRISO-X Fuel Fabrication Facility Integrated Safety Analysis Summary
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives January 2026 2-26 Rev. 4 Table 2.1-1b Yard Storage - Above Ground Acetylene Argon Propylene Hydrogen Methyltrichlorosilane Helium Oxygen Nitrogen Argon/Hydrogen Argon/Carbon Monoxide P-10 For storage information, see the TRISO-X Fuel Fabrication Facility Site Emergency Plan and/or TRISO-X Fuel Fabrication Facility Integrated Safety Analysis Summary
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives January 2026 2-27 Rev. 4 Table 2.1-1c Indoor Storage - Liquids Ammonium Hydroxide Formaldehyde Hydrogen Peroxide Nitric Acid Tergitol SolvaClean Sodium Hydroxide Hydrochloric Acid For storage information, see the TRISO-X Fuel Fabrication Facility Site Emergency Plan and/or TRISO-X Fuel Fabrication Facility Integrated Safety Analysis Summary
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives January 2026 2-28 Rev. 4 Table 2.1-1d Indoor Storage - Solids in Main Facility HMTA Resorcinol Methocel Urea For storage information, see the TRISO-X Fuel Fabrication Facility Site Emergency Plan and/or TRISO-X Fuel Fabrication Facility Integrated Safety Analysis Summary
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 2 - Alternatives January 2026 2-29 Rev. 4 Table 2.1-1e Indoor Storage - Solids in GMP Building Graphite (Natural)
Graphite (Synthetic)
Phenolic Resin For storage information, see the TRISO-X Fuel Fabrication Facility Site Emergency Plan and/or TRISO-X Fuel Fabrication Facility Integrated Safety Analysis Summary
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 4 - Environmental Impacts January 2026 4-60 Rev. 3 scenario. To mitigate fugitive dust production, best management practices are used to prevent particulate matter from becoming airborne. These practices include the following:
The use of water spray or soil binders on soil surfaces, when necessary, in clearing and grading operations, and construction activities.
The use of adequate containment methods during excavation and similar operations.
Covering the beds of open-bodied trucks transporting materials likely to give rise to airborne dust when in motion.
The prompt removal of earthen materials on paved roads accidentally placed there by trucks or earth moving equipment, or by wind erosion.
The prompt stabilization or covering of bare soil once any earthmoving activities are completed.
The different types of construction equipment used during the construction phase are shown in Table 2.1-4. The equipment is powered by gasoline and diesel fuel. As a bounding assumption, this equipment is assumed to be fueled with diesel fuel. Construction of TX-1 and TX-2 results in the consumption of approximately 465,726 (145,546 for TX-1 and 320,180 for TX-2) gallons of diesel fuel (Section 2.1.2.1.2, Table 2.1-3). The air emissions from this equipment during construction is provided in Table 4.6-4.
Construction equipment may generate transient visible emissions. Proper maintenance of gas-and diesel-powered equipment mitigates those emissions.
These impacts only occur during the construction period. Preconstruction and construction activities at the site and in the offsite areas would generate temporary air emissions of both gaseous and particulate pollutants. The effects on air quality from these temporary emissions are expected to be minor and would be minimized through use of mitigation discussed above.
Accordingly, air quality impacts from construction are expected to be SMALL for the surrounding communities and the nearest residents.
4.6.4.2 Operation As described in Section 2.1.2.1.3, (Operation Activities), TRISO-X FFF manufacturing operations consist of receiving (High-assay low enriched uranium) HALEU in the form of triuranium octoxide (U3O8) powder enriched to less than 20 weight percent 235U; converting the U3O8 into a uranyl nitrate solution, into gel spheres, and then into fuel kernels; and processing the fuel kernels through coating, overcoating, fuel form pressing, and heat treatment and carbonization. These operations are supported by shipping and receiving, laboratory, quality control, research and development, uranium recovery, and waste disposal processes.
The TX-1 facility is designed for a target production capacity of 5 MTU per year. The facility is expected to operate 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s/day, seven days/week, using two 12-hour shifts per day.
The TX-2 facility is designed for two production lines. The target production capacity of each line is 10 MTU per year, for a total annual capacity of 20 MTU. The facility is expected to operate 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s/day, seven days/week, using two 12-hour shifts per day.
The ventilation and control systems for TX-1 are designed and operated to assure adequate control of radioactive dust, vapor, and particulate. For TX-1, air is exhausted from the process equipment enclosures, glove boxes, and hoods area through the main HEPA filter units. An
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 4 - Environmental Impacts January 2026 4-61 Rev. 3 additional standby HEPA filter unit is provided for redundancy. Exhaust air is discharged to the atmosphere through the facility 100 ft. (30.5 m) tall vent stack. Physical characteristics of the of the TX-1 are listed in Table 4.6-1. The location of the TX-1 stack for the ventilation system is shown in Figure 4.6-1.
The ventilation and control systems for TX-2 are designed and operated to assure adequate control of radioactive dust, vapor, and particulate. Ventilation pickups for process equipment have local high efficiency filters. In addition to the local filters, the ventilation system has two main banks of high efficiency particulate air (HEPA) filters in series prior to atmospheric discharge.
The ventilation system for each production line discharges to a 100-ft. (30.5 m) tall stack adjacent to the production building. The stack for one of the two production lines (Line 1) has a larger diameter than the stack for production Line 2 to accommodate discharges from the production line; an area for research and development and common areas. Physical characteristics of the two stacks are listed in Table 4.6-1. The locations of the stacks for the ventilation system are shown in Figure 4.6-1.
Additional operations-related traffic result in vehicular air emissions. Nominal localized increases in emissions occur due to the increased numbers of cars, trucks, and delivery vehicles traveling to and from the TRISO-X FFF. Most of the increased traffic is associated with employees driving to and from work. Once the workers are at the site, the volume of traffic and its associated emissions are expected to decrease.
4.6.4.2.1 Backup Operations Equipment Besides air emissions from the TRISO-X FFF process, other air emissions sources include two backup diesel generators that supply backup power in case of an outage. The generators operate intermittently and for brief durations. Physical characteristics of the generators are listed in Table 4.6-1. The locations of the backup generators are shown in Figure 4.6-1. Emission rates from generators are listed in Table 4.6-2.
4.6.4.2.2 Mechanical-Draft Cooling Towers The TX-2 facility has two sets of mechanical-draft cooling towers (MDCTs). One set of towers rejects heat from the production process equipment (Process Heat Removal System - PHR System) and the other set rejects heat from the heating, ventilation, and air-conditioning (HVAC) system (see Section 2.1.2, Proposed Action).
The PHR System uses six cooling tower cells. Four of the cells operate normally and two are in standby. The cooling tower for the HVAC system has three cells. The MDCTs use six concentration cycles. The total dissolved solids content of the cooling water is 156 parts per million.
In MDCTs, excess heat in the cooling water is transferred to the atmosphere by evaporative and conductive cooling. In addition to evaporative heat losses, a small percentage of water is lost in the form of droplets (drift). The droplets evaporate, leaving dissolved solids as deposits. No noticeable impacts are expected from MDCTs due to fogging, icing, and drift. Physical characteristics of the MDCTs are listed in Table 4.6-1. The locations of the MDCTs are shown in Figure 4.6-1.
For the TX-1 facility, TX-1 process heat is rejected to the surrounding air via air-cooled chillers (See Section 2.1.2.1.1.7.1.1).
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 4 - Environmental Impacts January 2026 4-62 Rev. 3 4.6.4.2.3 Air Pollutant Emissions Air emissions from the TRISO-X FFF (TX-1 and TX-2 facilities) include nitrogen oxides (NOx),
carbon monoxide (CO), sulfur oxides (SOx), hydrocarbons in the form of volatile organic compounds (VOCs), hazardous air pollutants (HAPs), particulate matter (PM) having an aerodynamic diameter less than 2.5 microns (PM2.5), and particulate matter having an aerodynamic diameter less than 10 microns (PM10).
Potential annual emissions from the TX-1 and TX-2 facilities are provided in Table 4.6-3. The emissions are based on an annual production rate of 5 MTU from the TX-1 facility and 20 MTU from the TX-2 facility. The potential annual emissions of each criteria pollutant is below the applicable 250 tons per year (TPY) major source threshold for Prevention of Significant Deterioration (PSD) under New Source Review regulations. The potential annual emissions of each criteria pollutant is below the applicable 100 TPY major source threshold under Title V regulations. Regarding the potential emissions of HAPs, emissions from the facility are below the Title V major source threshold of 25 TPY of any combination of HAPs or less than 10 TPY of any single HAP. Therefore, the TRISO-X FFF is a minor air pollutant source.
4.6.4.2.4 Ambient Air Quality Impacts Air emission sources associated with the TRISO-X FFF are managed in accordance with Federal, State, and local air-quality control laws and regulations. The facility complies with all applicable regulatory requirements of the Clean Air Act and TDEC requirements to minimize impacts on State and regional air quality. Since TRISO-X FFF is a minor source, impacts on ambient air quality are expected to be SMALL.
4.6.4.3 Decommissioning The decommissioning phase of the project is expected to last two years. The plans for decommissioning of the TRISO-X FFF are described in Section 2.1.2.1.4 [Decontamination and Decommissioning (Description of the Proposed Action)]. Decommissioning of the TRISO-X FFF would involve removal and decontamination of the used process equipment and materials. The number of truck shipments depends upon the quantities of equipment and waste materials resulting from decommissioning.
Traffic and equipment movement around the HCS may generate transient fugitive dust during decommissioning. As in the construction phase, these emissions may impact air quality near the HCS for short periods of time. To control fugitive dust production, best management practices are used to prevent particulate matter from becoming airborne. These practices are described in Section 4.6.4.1 (Construction). Due to the transient nature of the emissions around the HCS during decommissioning, impacts on visibility are expected to be SMALL.
4.6.4.3 Visibility Impacts 4.6.4.4.1 Construction Additional traffic and equipment movement around the HCS may generate transient fugitive dust during construction. These emissions may impact visibility near the HCS for short periods of time.
To control fugitive dust production, best management practices are used to prevent particulate matter from becoming airborne. These practices are described in Section 4.6.4.1. Due to the transient nature of the emissions around the HCS during construction, impacts on visibility are expected to be SMALL.
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 4 - Environmental Impacts January 2026 4-63 Rev. 3 4.6.4.4.2 Operation The principal air emission sources associated with the TRISO-X FFF are process furnaces, mechanical-draft cooling towers and engine-driven backup equipment. The backup equipment operates intermittently and for brief durations.
Air emission sources associated with the TRISO-X FFF are managed in accordance with Federal, State, and local air-quality control laws and regulations to minimize emissions. Due to the relatively small magnitude of emissions from the TRISO-X FFF, impacts on visibility are expected to be SMALL.
4.6.4.4.3 Decommissioning Additional traffic and equipment movement around the HCS may generate transient fugitive dust during decommissioning. As in the construction phase, these emissions may impact visibility near the HCS for short periods of time.
Equipment used for decommissioning may generate fugitive dust. To control fugitive dust production, best management practices are used to prevent particulate matter from becoming airborne. These practices are described in Section 4.6.4.1. Due to the transient nature of the emissions around the HCS during decommissioning, impacts on visibility are expected to be SMALL.
4.6.4.4.4 Class I Areas Class I areas are national parks and wilderness areas that are potentially sensitive to visibility impairment. As discussed in Section 3.6.2.3 (Class I Areas), the nearest Mandatory (Federal) or American Indian Class I area to the HCS is the Great Smoky Mountains National Park, Tennessee/North Carolina which is located approximately 34 mi. (54 km) southeast of the HCS.
Due to influence of the terrain in the Tennessee River Valley, prevailing winds around the HCS are from the southwesterly and northeasterly wind directions (see Section 3.6.1.1, General Climate; and Section 3.6.1.5, Local Meteorological Data Analysis), crosswind transport from the HCS to this Class I area is unlikely. Given the minor air emissions from the TRISO-X FFF, there is little likelihood that activities at the HCS could adversely affect air quality and air-quality-related values (e.g., visibility or deposition) in this Class I area.
4.6.5 CUMULATIVE IMPACTS Reasonably foreseeable future actions at other facilities in proximity to the HCS are summarized in Table 2.3-1. Most of the identified projects are located more than 2 mi. (3.2 km) from the HCS or are currently under construction (i.e., Oak Ridge Enhanced Technology and Training Center
[ORETTC]). Projects under construction are expected to result in transient air emissions from construction activity.
Three foreseeable projects that occur within 0.5 mi. (0.8 km) of the HCS are the CORED electrical system upgrades to serve the Horizon Center Industrial Park, the construction of a HTF located within the Horizon Center Industrial Park, and the construction of the Orano Uranium Enrichment Facility located across TN 95. Air emissions associated with construction of these projects may overlap with emissions from construction of the TRISO-X facility at the HCS. However, construction air emissions are expected to be temporary, localized, and intermittent.
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 4 - Environmental Impacts January 2026 4-64 Rev. 3 The scope of proposed actions in Table 2.3-1 may involve air emissions during their construction and operational phases within their respective project areas. While specific details regarding the scope of many of these actions are lacking, it is expected that these projects are developed in coordination with TDEC to ensure that air emissions permits are obtained and that air emissions are minimized as required. Furthermore, as described above air quality impacts resulting from construction, operation and decommissioning of the HCS are SMALL. Because the Proposed Action would not result in a noticeable change in air quality, the impact of the incremental contribution of the NRC-authorized activities related to construction, operation and decommissioning of the TRISO-X FFF on air quality would not be a significant contributor to the SMALL cumulative impact.
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 4 - Environmental Impacts January 2026 4-67a Rev. 3 Table 4.6-4 Potential Annual Air Emissions from the Construction of the TRISO-X Fuel Fabrication Facility Pollutant TX-1 5 MTU Potential Air Emissions (tons per year)
TX-2 20 MTU Potential Air Emissions (tons per year)
Particulate matter 0.81 1.79 CO 2.74 5.44 NOx 11.4 25.0 SO2 0.05 0.11 VOCs 0.91 2.0
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 4 - Environmental Impacts January 2026 4-125 Rev. 3 Table 4.12.2-1 (Sheet 1 of 2)
Summary of Potential Health Impacts Associated with Releases of Non-Radiological Materials Used in Production and Stored Outdoors at the TRISO-X Fuel Fabrication Facility Chemical Class Non-Radiological Materials Stored Outdoors Potential for Health Impacts if Released to the Environment Cryogenic Liquid Argon Argon is a simple asphyxiant (NLM, 2022a). Simple asphyxiants are harmful to the body only when the asphyxiant becomes so concentrated in air that the effective oxygen level in the breathing zone is lowered from 21 percent to 19.5 percent or lower (CCPS, 2022).
Stored argon is a refrigerated liquid. Upon accidental release from a cryogenic tank, argon would rapidly transition to the gaseous state at normal atmospheric pressure and outdoor temperature, as stated in the National Library of Medicines PubChem database citation for argon (NLM, 2022a). Because of this rapid transition to the gaseous phase, released argon would not be expected to impact environmental media including soil, ground water, sediment or surface water.
Liquids Ammonium Hydroxide Ammonium hydroxide is corrosive via inhalation, ingestion and dermal contact routes of exposure (NLM, 2022g).
Ethanol Ethanol is a skin and eye irritant. Ethanol vapors are heavier than air. Accidental release of ethanol is also a potential physical hazard in that ethanol is classified as flammable (NLM, 2022b).
Hydrogen Peroxide Hydrogen peroxide is caustic to mucous membranes and skin.
Hydrogen peroxide is also an oxidizer (NLM, 2022i).
Methyltrichlorosilane Methyltrichlorosilane is corrosive to skin and the intestinal tract.
Methyltrichlorosilane vapors are heavier than air. Accidental release of methyltrichlorosilane is also a potential physical hazard in that methyltrichlorosilane is classified as flammable (NLM, 2022c).
Nitric Acid Nitric acid is corrosive via inhalation, ingestion and dermal contact routes of exposure. Nitric acid is also an oxidizer (NLM, 2022j).
Propylene Propylene can be stored as a liquified gas under vapor pressure. It is an inhalation toxicant and simple asphyxiant. Accidental release of propylene gas is also a potential physical hazard in that propylene is classified as extremely flammable (NLM, 2022f).
Sodium Hydroxide Sodium hydroxide is corrosive via inhalation, ingestion and dermal contact routes of exposure. Sodium hydroxide is also an oxidizer (NLM, 2022k).
Solvaclean Solvaclean is not listed in the National Library of Medicines PubChem database.
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 4 - Environmental Impacts January 2026 4-126 Rev. 3 Table 4.12.2-1 (Sheet 2 of 2)
Summary of Potential Health Impacts Associated with Releases of Non-Radiological Materials Used in Production and Stored Outdoors at the TRISO-X Fuel Fabrication Facility Chemical Class Non-Radiological Materials Stored Outdoors Potential for Health Impacts if Released to the Environment Tergitol Tergitol is corrosive and causes skin irritation and serious eye damage (Sigma-Aldrich, 2024)
Solute-in-Solvent Acetylene Acetylene gas as an inhalation toxicant, affecting primarily the central nervous system and respiratory system. Acetylene gas is also listed as a simple asphyxiant. Accidental release of acetylene gas represents a potential physical hazard in that acetylene is classified as flammable (NLM, 2022d).
Compressed Gases Argon-Carbon Monoxide Mix The mixture of carbon monoxide in argon is a compressed gas that may explode if heated. It is a chemical asphyxiant; exposure to low concentrations for extended periods may result in dizziness or unconsciousness, or death (Linde, 2022a).
Argon-Hydrogen Mix The mixture of hydrogen in argon is a compressed gas that may explode if heated. It is an asphyxiant in high concentrations; may displace oxygen and cause rapid suffocation (Linde, 2022b)
Helium Helium is a compressed gas that may explode if the container becomes heated or may cause cryogenic burns or injury.
Accidental release of vapors may cause dizziness or asphyxiation (NLM, 2024a).
Hydrogen Hydrogen is an extremely flammable compressed gas that may explode if the container is heated and may cause cryogenic burns or injury. Vapors may cause dizziness or asphyxiation without warning, may be irritating if inhaled at high concentrations and may produce irritation and/or toxic gases if set on fire (NLM, 2024b).
Nitrogen Nitrogen is a pressurized gas that if accidentally released may cause dizziness or asphyxiation. If the container is heated, it has the potential to explode. (NLM, 2024d)
Oxygen Oxygen is an oxidizer, is a compressed gas that may explode if the container is heated and may cause cryogenic burns or injury.
Inhalation of 100% oxygen can cause nausea, dizziness, irritation of lungs, pulmonary edema, pneumonia, and collapse.
(NLM, 2024e).
P-10 P-10 gas is a mixture of 90% Argon and 10% Methane. Argon is a simple asphyxiant (NLM, 2022a). Simple asphyxiants are harmful to the body only when the asphyxiant becomes so concentrated in air that the effective oxygen level in the breathing zone is lowered from 21 percent to 19.5 percent or lower (CCPS, 2022). Methane is a colorless, odorless gas that is easily ignited. (NLM, 2026a)
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 4 - Environmental Impacts January 2026 4-127 Rev. 3 Table 4.12.2-2 Summary of Potential Health Impacts Associated with Exposure to Non-Radiological Materials Used in Production and Stored Indoors at the TRISO-X Fuel Fabrication Facility Chemical Class Non-Radiological Materials Stored Indoors Potential Health Impacts Associated in Exposure Liquids Formaldehyde Formaldehyde is corrosive via inhalation, ingestion and dermal contact routes of exposure and causes anesthetic effects. Formaldehyde is also a potential physical hazard in that formaldehyde is classified as flammable (NLM, 2022h).
Hydrochloric Acid Hydrochloric acid is corrosive, an acute toxin, and an irritant.
It is toxic if inhaled, ingested or absorbed through the skin and may be fatal. Vapors are irritating and corrosive.
Contacts with liquefied gas may cause burns, severe injury and/or frost bite (NLM, 2024c).
Solids Graphite (Natural and Synthetic)
Graphite is a respiratory, dermal and eye irritant (NLM, 2022l).
Hexamethylenetetramine Hexamethylenetetramine is a respiratory, dermal, eye and mucous membrane irritant. Hexamethylenetetramine is also a potential physical hazard in that it is classified as flammable (NLM, 2022m).
Methocel Methocel is a methyl cellulose polymer that is not digestible, not toxic, and not allergenic (NLM, 2026b).
Phenolic Resin Phenolic resin is corrosive to skin (NLM, 2022n).
Resorcinol Resorcinol is a skin and eye irritant (NLM, 2022o).
Urea Urea is a skin, respiratory tract, and eye irritant (NLM, 2022p)
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 6 - Environmental Measurements and Monitoring Programs January 2026 6-8 Rev. 2 The GERMs include sample nozzles in the effluent release point (i.e., stack) such that representative samples are extracted and delivered to the monitored filtration media. Using a parallel sampling system, the sampling system facilitates both uninterrupted continuous monitoring and sample removal for periodic laboratory analysis of quantity and identity of radionuclides collected. These removable samples and associated analysis form the basis of data reported in the regulatory required 10 CFR 70.59 effluent monitoring reports and are referred to as the for record samples. The GERMs have a measurement range of (5E-13 to 1E-04 µCi/cc).
6.1.1.2 Liquid Effluent Monitoring There are no radioactive liquid releases during normal operations from the TRISO-X FFF (TX-1 and TX-2). Therefore, there is no need for liquid effluent monitoring at the facility.
6.1.2 Radiological Environmental Monitoring Program The Radiological Environmental Monitoring Program (REMP) at the TRISO-X Facility aids in ensuring compliance with normal effluent requirements. It provides a supplementary check of containment and effluent controls, establishes a process for collecting data for assessing radiological impacts on the environs and estimating the potential impacts on the public, and supports the demonstration of compliance with applicable radiation protection standards and guidelines.
The requirement to have a REMP is documented in 10 CFR 20.1302. The REMP is used to verify the effectiveness of plant measures which are used to control the release of radioactive material and to verify that measurable concentrations of radioactive materials and levels of radiation are not higher than expected based on effluent measurements and modeling of the environmental exposure pathways.
Regulatory Guide 4.20, Constraint on Releases of Airborne Radioactive Materials to the Environment for Licensees Other Than Power Reactors, provides guidance on methods that can be used to meet 10 CFR 20.1101(d) and implement the ALARA requirements in 10 CFR 20.1101(b). In 1996, the NRC added the constraints to provide an ample margin of safety to members of the public from airborne emissions of radioactive material to the environment and to remove dual regulation by the NRC and the USEPA. Regulatory Guide 8.37, ALARA Levels for Effluents from Materials Facilities, provides guidance for development of a program to establish and maintain ALARA levels for gaseous and liquid effluents at materials facilities, including those facilities where special nuclear material is licensed under 10 CFR 70. As mentioned in Section 6.1, 10 CFR 70.59 requires semiannual reporting of the principal radionuclides released to unrestricted areas in liquid and gaseous effluents.
Continuous airborne particulate sampling is performed at 6 locations selected based on predominant wind direction and the direction of potential receptors. Sample media from the continuous airborne particulate sampler is retrieved monthly for gross alpha/beta analysis.
Isotopic analysis focused on U-234, U-235, and U-238 is performed when gross alpha/beta action levels are exceeded. Vegetation at 4 locations surrounding the facility is collected semiannually for gross alpha/beta analysis. Groundwater at 4 locations surrounding the facility is collected quarterly for gross alpha/beta analysis (see Section 6.2.2.2). Soil samples at 5 locations surrounding the facility (1 location at the outfall of the west detention basin and 4 locations in the predominant wind directions) are collected semi-annually for gross alpha/beta analysis.
Stormwater samples at 3 locations at the forebays of the detention basins are collected quarterly for gross alpha/beta analysis. All isotopic analysis conforms with the guidance in Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring Programs (Inception through Normal
Environmental Report for the TRISO-X Fuel Fabrication Facility Chapter 6 - Environmental Measurements and Monitoring Programs January 2026 6-9 Rev. 2 Operations to License Termination) - Effluent Streams and the Environment, which includes the use of established standards provided by the National Institute of Standards and Technology (NIST) and the National Environmental Laboratory Accreditation Conference (NELAC).
Thermoluminescent dosimeters (TLDs) provide indication of direct radiation from contained radiation sources within the TRISO-X Facility building, from radioactivity in the airborne effluent, and from deposition of airborne radioactivity onto the ground. TLDs are placed on the facility boundary fence in sufficient quantity such that detectors cover all possible directions for radiological release. This scheme is meant to give 360-degree coverage of the site boundary and provide sufficient resolution of data for analysis and reporting per 10 CFR 70. TLDs are collected quarterly for processing in conformance with guidance in RG 4.13, Performance, Testing, and Procedural Specifications for Thermoluminescence Dosimetry: Environmental Applications. The 6 TLD locations are shown in Figure 0.2-1. See Table 6.1.2-1 for summary of radiation monitoring stations.
The REMP falls under the oversight of the facilitys Regulatory Affairs (RA) program. Written procedures to ensure representative sampling, proper use of appropriate sampling methods and equipment, proper locations for sampling points, and proper handling, storage, transport, and analyses of effluent samples are a key part of the program. In addition, written procedures ensure that sampling and measuring equipment, including ancillary equipment such as airflow meters, are properly maintained and calibrated at regular intervals. Moreover, the REMP implementing procedures include functional testing and routine checks to demonstrate that monitoring and measuring instruments are in working condition.