ML26055A068
| ML26055A068 | |
| Person / Time | |
|---|---|
| Site: | Crane |
| Issue date: | 02/26/2026 |
| From: | Kevin Folk NRC/NMSS/DREFS/EPMB1 |
| To: | Karpa Z Constellation Energy Company |
| References | |
| EPID L-2025-LNE-0008 | |
| Download: ML26055A068 (0) | |
Text
February 26, 2026 Zigmund Karpa Director of Environmental Programs Constellation Energy Generation, LLC 200 Energy Way Kennett Square, PA 19348
SUBJECT:
CHRISTOPHER M. CRANE CLEAN ENERGY CENTER - ENVIRONMENTAL AUDIT
SUMMARY
REPORT FOR THE PROPOSED REAUTHORIZATION OF POWER OPERATIONS UNDER RENEWED FACILITY OPERATING LICENSE NUMBER DPR-50 (EPID NUMBER: L-2025-LNE-0008) (DOCKET NUMBER:
50-289)
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. A review team consisting of staff from the U.S. Nuclear Regulatory Commission (NRC or the staff), supported by staff from Pacific Northwest National Laboratory (PNNL), participated in a hybrid environmental audit during the weeks of February 2 and February 16, 2026, for the CCEC as part of the NRCs review of the potential environmental effects related to proposed resumption of power operations at CCEC. A formal exit meeting was conducted on February 25, 2026.
The goal of the audit was to collect and validate relevant information to support the NRC staffs environmental review consistent with the NRCs regulations for implementing the National Environmental Policy Act of 1969, as amended, at Title 10 of the Code of Federal Regulations Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions. A letter dated January 2, 2026, (Agencywide Documents Access and Management System [ADAMS] Accession No. ML25364A023), was sent to CEG containing an audit plan with environmental information needs.
An entrance meeting was held on February 3, 2026, to introduce participants and discuss audit logistics. During the remainder of the audit, the NRC review team participated in smaller groups (breakout sessions) with CEG, and Enercon Services, Inc. (Enercon) staff to address the audit needs identified in the audit plan. Enclosure 1 to this letter provides an audit summary report.
The audit remained open until February 25, 2025, following the NRC staffs environmental site visit to CCEC on February 19, 2026. At the conclusion of the audit, the NRC staff summarized the status of its review with CEG and Enercon representatives during the exit meeting held on February 25, 2026.
Z. Karpa 2
Many of the staffs questions identified in the audit plan or subsequently during the audit sessions were answered through the conduct of the audit. Those that were answered but would need to be documented for use in the NRCs environmental assessment could be submitted (a) as a supplement to the application(s), (b) as responses to requests for confirmation of information (RCIs), or (c) as responses to requests for additional information (RAIs). Enclosure 2 to this letter contains the staffs RCIs and RAIs. The NRC requests CEGs response to these items within 30 days of receipt of this letter. The NRC staff remains available to meet to clarify these questions, if necessary.
While the NRC staff did not identify any significant environmental issues during the audit, the staff indicated that the environmental review was ongoing and that any additional information necessary to support the review would be formally requested via the RAI process in the future.
Persons who do not have access to ADAMS or who encounter problems in accessing the documents located in ADAMS should contact the NRC's Public Document Room staff at 800-397-4209 (or 301-415-4737) or via email at pdr.resource@nrc.gov.
If you have any questions, please contact me via email at Kevin.Folk@nrc.gov.
Sincerely, Signed by Folk, Kevin on 02/26/26 Kevin T. Folk Senior 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: GovDelivery
Z. Karpa 3
SUBJECT:
CHRISTOPHER M. CRANE CLEAN ENERGY CENTER - ENVIRONMENTAL AUDIT
SUMMARY
REPORT FOR THE PROPOSED REAUTHORIZATION OF POWER OPERATIONS UNDER RENEWED FACILITY OPERATING LICENSE NUMBER DPR-50 (EPID NUMBER: L-2025-LNE-0008) (DOCKET NUMBER:
50-289)
DATED:
February 26, 2026 DISTRIBUTION:
PUBLIC RidsNmssRefs Resource RidsNrrDorlLpl3Resource RidsACRS_MailCTR Resource RidsNrrPMCraneCleanEnergyCenter Resource RidsRgn1MailCenter Resource RidsOcaMailCenterResource RidsOpaMailResource RidsOgcMailCenterResource ZKarpa, CEG HPell, CEG AStalker, CEG ADAMS Accession No.: ML26055A068 OFFICE NE/PM:EPMB1 LA:REFS BC:EPMB1 NE/PM:EPMB1 NAME KFolk AWalker-Smith SKoenick KFolk DATE 02/26/2026 02/26/2026 02/26/2026 02/26/2026 OFFICE RECORD COPY
CHRISTOPHER M. CRANE CLEAN ENERGY CENTER PROPOSED REAUTHORIZATION OF POWER OPERATIONS ENVIRONMENTAL AUDIT
SUMMARY
February 3-25, 2026 OVERVIEW 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 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.
ML24324A048, ML25212A076, ML25300A118, and ML25304A097(package), respectively). 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 CEG that the requests had been accepted for review (ML24355A057, ML25247A220, ML25337A113, and ML25345A391, respectively).
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 (including any revisions or supplements) submitted to the NRC define the proposed Federal actions, that is, for the NRC to determine whether to grant or deny the requests necessary to reauthorize power operations at CCEC. The U.S. Department of Energy, Office of Energy Dominance Financing is a cooperating agency for this environmental review.
As part of its environmental review under the National Environmental Policy Act of 1969, as amended, the NRC is preparing an environmental assessment. An audit was conducted from February 3 to February 25, 2026, to support the environmental review of the licensing and regulatory requests.
This report presents a summary of the NRCs audit activities and preliminary information that was obtained in accordance with the staffs audit plan and associated environmental audit and information needs, dated January 2, 2026 (ML25364A023).
AUDIT SCOPE AND LOGISTICS The NRCs environmental audit included a virtual portion and a site visit. The virtual environmental audit was conducted from February 3 through February 5, 2026. The site visit was conducted on February 19, 2026. The virtual portion of the audit was organized into breakout meetings that focused on specific environmental resource areas or technical topics. The breakout sessions were led by a team consisting of NRC environmental staff along with supporting staff from its contractor, Pacific Northwest National Laboratory (PNNL). The sessions were attended by knowledgeable CEG staff and their supporting contractor staff from Enercon Services, Inc. (Enercon). During the breakout sessions, the NRC team reviewed and discussed CEGs responses to the NRCs environmental information needs and, where appropriate, asked clarifying questions. These breakout discussions, as supplemented by the NRC staffs site visit and independent environmental review activities, formed the basis for the NRC teams requests for confirmation of information or requests for additional information, as applicable.
2 Table 1 summarizes the audit activities and breakout sessions that were held. Table 2 lists the NRC environmental team staff who participated in all or part of the environmental audit. Table 3 lists CEG and Enercon staff who participated in one or more breakout sessions.
Table 1. Summary of Daily Activities and Breakout Sessions for the CCEC Environmental Audit Format/Date/Time*
ACTIVITY Virtual Audit February 3, 2026; 9:00 a.m. to 4 p.m. (ET)
Entrance Meeting; introductions, opening remarks, objectives, and expectations Virtual Tours; exterior grounds of the CCEC site and Three Mile Island vicinity, including training center on the mainland, in-scope transmission lines, historic and cultural sites, Independent Spent Fuel Storage Installation, views of CCEC from publicly accessible areas, location of major facilities and structures that have been or will be modified or refurbished to support restart, the area of the nature-like fishway associated with the York Haven Dam, and plant intake and discharge locations Breakout Session; General Information Needs Breakout Session; Air Quality, Noise, Greenhouse Gases/Climate Change Lunch Break Breakout Session; Geologic Environment, Groundwater Resources Breakout Session; Surface Water Resources Daily Closeout Meeting; review of action items Virtual Audit February 4, 2026; 9:00 a.m. to 12:30 p.m. (ET)
Breakout Session; Terrestrial Resources, Aquatic Resources Breakout Session; Federally Protected Ecological Resources Breakout Session; Historic and Cultural Resources Daily Closeout Meeting; review of action items Virtual Audit February 5, 2026; 9:00 a.m. to 11:30 a.m. (ET)
Breakout Session; Human Health, Spent Nuclear Fuel Breakout Session; Postulated Accidents Daily Closeout Meeting; review of action items In-Person Site Visit February 19, 2026; 12:00 p.m. to 4:00 p.m. (ET)
Walking Tour; plant views from and to 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/restored to support operations (particularly those with ground disturbance),
active work areas, cooling water intake system pathway from intake to main discharge structure, stormwater management facilities, and historic and cultural sites Virtual Meeting February 25, 2026 9:00 a.m. to 10 a.m. (ET)
Exit Meeting; discussion of closeout actions and preliminary requests for confirmation of information or requests for additional information, as applicable
- Start and end times are approximate.
3 Table 2. List of NRC Environmental Review Team Members Function or Review Area Team Member (NRC unless specified)
Environmental Review Supervisor Steve Koenick*
DOE Representative, Energy Dominance Financing, Environmental Compliance Alicia Williamson, DOE NRC Environmental Project Manager Kevin Folk*, Ashley Waldron*
PNNL Team Leads Cyler Conrad, Leah Hare, PNNL Air Quality, Meteorology, and Climatology Nancy Martinez Aquatic Resources Briana Arlene; Caitlin Wessel, PNNL Federally Protected Ecological Resources Mitchell Dehmer Geologic Environment Gerry Stirewalt Greenhouse Gases/Climate Change Nancy Martinez Groundwater Resources Gerry Stirewalt, Kevin Folk 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 William Rautzen, John Parillo Reasonable Alternatives Bradley Werling Socioeconomics Jeff 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 Spent Nuclear Fuel, Waste Management Donald Palmrose DOE=Department of Energy (Cooperating Agency); NRC=Nuclear Regulatory Commission; Pacific Northwest National Laboratory (NRC contractor).
- Indicates staff who participated in the environmental site visit and onsite audit session on February 19, 2026.
4 Table 3. List of CEG and Enercon Staff Function or Review Area Team Member Constellation Energy Generation Senior Chemist, CCEC Dani Brookhart Supervisor Maintenance, CCEC Allen Carmichael, Jr Principal Regulatory Engineer Rebecca Craddick Environmental Specialist Alyssa Hockaday Senior Environmental Specialist, CCEC Cory Hoffman Director of Environmental Programs Zigmund Karpa Principal Environmental Specialist Kristin Meek Senior Manager, Licensing Dennis Moore Manager Environmental Programs Debra Musser Regulatory Specialist, CCEC Hannah Pell Senior Reactor Engineer, CCEC Daniel Sells Regulatory Assurance Manager, CCEC Craig Smith Senior Environmental Specialist, CCEC Andrew Spriggle Principal Environmental Specialist Allison Stalker Senior Engineer - Risk Management Ryan Tennant Senior Engineer, CCEC Oliver Tillman Senior Site Safety Advisor, CCEC Scott Weichler Enercon Postulated Accidents Beth Baucom Environmental Project Manager Stacy Burgess Noise, Spent Nuclear Fuel, Virtual Tour Sharon Chavez Federally Protected Ecological Resources, Terrestrial Resources, Aquatic Resources Jay Hemmis Administrative, Editorial Support Lisa Hendrick Waste Management, Spent Nuclear Fuel, Uranium Fuel Cycle Emily Keenan Aquatic Resources, Human Health, Geologic Environment, Water Resources Randall Lantz Environmental Project Technical Lead, Geologic Environment, Water Resources, General Jennifer Meek Socioeconomics, General Cheyenne Riggs Air Quality, Greenhouse Gas Emissions and Climate Change, Terrestrial Resources Jerry Riggs Federally Protected Ecological Resources, Terrestrial Resources, Aquatic Resources, Note Taker Juliana Santarelli Observer, Human Health and Spent Nuclear Fuel Nicole Schlichting Human Health Jonathan Subacz Historic and Cultural Resources Betsy Tangora Virtual Tour Fred Woolridge
CHRISTOPER M. CRANE CLEAN ENERGY CENTER PROPOSED REAUTHORIZATION OF POWER OPERATIONS ENVIRONMENTAL AUDIT REQUESTS FOR CONFIRMATION OF INFORMATION Regulatory Basis The National Environmental Policy Act of 1969, as amended (NEPA), requires Federal agencies to integrate environmental values into their decisionmaking process by considering the environmental effects of proposed agency (Federal) actions and reasonable alternatives to those actions.
The U.S. Nuclear Regulatory Commissions (NRC) regulations at Title 10 of the Code of Federal Regulations (10 CFR) Part 51, which implement Section 102(2) of NEPA, include requirements for applicants to provide information as may be useful in aiding the NRC staff in complying with NEPA and conducting its environmental review. These requirements include 10 CFR 51.41, Requirement to submit environmental information, which constitutes the NRC staffs underlying regulatory basis for its requests for information.
Additionally, the NRC staff conducted its environmental audit and developed its information needs consistent with the guidance in the NRCs Office Instruction LIC-203, Procedural Guidance for Categorical Exclusions, Environmental Assessments, and Considering Environmental Issues (Agencywide Documents Access and Management System Accession No. ML20016A379).
In accordance with NEPA and the NRCs regulations for implementing NEPA, the NRC staff has determined that preparation of an environmental assessment (EA) constitutes the appropriate level of environmental review for the proposed Federal actions.
The following requests for confirmation of information (RCIs) and requests for additional information (RAIs) identify information needed by the NRC staff to complete its environmental review of the reasonably foreseeable environmental effects of the licensing and regulatory requests necessary to reauthorize power operations at the Christopher M. Crane Clean Energy Center (CCEC).
Requests for Confirmation of Information During the environmental audit, the NRC staff reviewed documents that were made available on the applicants (Constellation Energy Generation, LLC (CEG)) electronic information portal for the CCEC in response to the staffs audit plan and associated environmental audit and information needs, dated January 2, 2026 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML25364A023). The staff also participated in breakout sessions with CEG and contractor staff to gather information that will likely be used in the NRCs EA. To the best of the staffs knowledge, other than the Environmental Report (ER)
(ML25303A293) which was submitted on the docket, the information on the electronic portal and discussed in breakout sessions is not currently on the docket or publicly accessible. During the environmental audit, the NRC staff was able to resolve and close out a number of environmental information needs, requiring no further action. Where applicable, this is specified for the listed audit need. However, for the remaining items, the NRC staff requests that CEG provide confirmation that the information reviewed or discussed during the environmental audit and listed below is correct or provides the associated corrected information.
2 GENERAL GEN-1 Based on the information gathered and discussed during the audit, confirm the following updated information regarding ER Table 2.2-2:
Surface water withdrawal, groundwater withdrawal, and consumptive water use permit An updated application for a docket renewal with modification was submitted in November 2025 (11/25/25), and the groundwater attachments were updated and resubmitted in January 2026 Synthetic minor operating permit A Plan Approval Application for a State-Only Operating Permit was submitted in October 2025 Maintenance dredging permit The need for dredging near the intake structure that would require a U.S. Army Corps of Engineers (USACE) maintenance dredging permit is still to be determined Public water supply permit The application to restore the public drinking water permit at the training center has not yet been submitted Storage Tank Registration/Permit Certificate New tank registration applications have not been submitted as no on-site tanks have been restored to date National Pollutant Discharge Elimination System (NPDES) permit A permit renewal application was submitted in March 2025 (3/7/25), and CEG continues to provide information to Pennsylvania Department of Environmental Protection (PA DEP) as requested to support their review of the application Certification of water quality standards Final application for a water quality certification or waiver was submitted in November 2025 (11/21/25)
General site access permit for radioactive waste disposal This permit has been renewed and expires in April 2026. This permit is renewed annually GEN-2 Confirm the following statements and supporting information regarding the expected duration of preparation activities for the resumption of power operations. (1) CEG considers the starting date for preparation activities for the resumption of operations to have commenced on November 19, 2024, coinciding with CEG's Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82 (ADAMS Accession No. ML24324A048). This is consistent with NRC's Inspection Manual Chapter 2562 (ML24033A299). (2) After NRC approval of the proposed action, which CEG expects to occur by March 4, 2027, as stated in the NRC's letter dated January 7, 2026 (ML25345A027), CEG will formally rescind its Certification of Permanent Cessation of Power Operations for Three Mile Island Nuclear Station, Unit 1, submitted pursuant to 10 CFR 50.82 by letters dated June 20, 2017 (ML17171A151) and Certification of Permanent Removal of Fuel from the Reactor Vessel for Three Mile Island Nuclear Station, Unit 1, dated September 26, 2019 (ML19269E480). (3) Rescission of the referenced 10 CFR 50.82(a)(1) Certifications, which is planned to occur in 2027, would coincide with the date on which CCEC will
3 transition to the operating reactor license basis and return to the NRCs Reactor Oversight Process, thereby coinciding with the end of restart preparation activities.
GEN-3 See RAI GEN-1.
GEN-4 Confirm the following statements. (1) Onsite staffing is projected to peak around 1,200 during restart preparations and approximately 600 following resumption of operations. (2) CEG plans to hire more than 600 employees prior to the restart, in addition to the hundreds of highly skilled contractors who will support the CCECs safe opening and daily operations, mostly sourced from local union halls. (3) Peak workforce during 2024 was 132 active employees and peak workforce during 2025 was 536 active employees.
GEN-5 Resolved through audit activities.
AIR QUALITY, METEOROLOGY, CLIMATOLOGY AQN-1 Based on the information gathered and discussed during the audit, confirm the following:
The onsite meteorological tower was abandoned in August 2023.
The following represents onsite meteorological data for January 1, 2021, through August 28, 2023, period of record:
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Ann.
Avg.
Temp
(°F) 33.84 35.98 44.26 53.84 62.16 71.08 76.26 74.99 67.37 56.92 44.75 37.79 54.74 Avg.
Pcp.
(in) 1.77 2.18 2.68 2.41 2.70 2.85 5.06 2.74 6.33 3.21 2.04 1.99 36.89 Avg.
Wind Spd (mph) 7.77 7.80 8.66 8.02 5.94 5.82 4.84 4.99 5.46 5.22 6.48 6.11 6.44 Prev.
Wind Dir.
(deg) 310 310 310 310 310 310 310 130 200 320 310 300 310 AQN-2 Confirm that the air pollutant emissions listed in ER Table 3.6-1 account for auxiliary boilers (B1A and B1B) and various stationary combustion sources (Y1A, YIB, Y2, FSP1, FSP3, FX1A, and FX1B).
AQN-3 See RAI AQN-1.
AQN-4 Resolved through audit activities.
NOISE NOI-1 Based on the information gathered and discussed during the audit, confirm the following statements: (1) Primary noise sources during operations are expected to be the same as identified in the NRCs 2009 license renewal supplemental environmental impact statement (LR SEIS) (NUREG-1437, Supplement 37; ML091751063). (2) The distance from cooling towers to the nearest residence is 450 meters. (3) Noise generating sources during preparation activities for the resumption of power operations will primarily be from vehicles and construction equipment.
4 NOI-2 Resolved through audit activities.
NOI-3 Confirm the following statements with regard to noise issues at CCEC. CCEC did not receive any noise complaints during the 5-year period prior to shutdown in 2019.
CCEC has procedures in place on the handling of noise complaints.
NOI-4 Resolved through audit activities.
GEOLOGIC ENVIRONMENT GE-1 See RAI GE-1.
GE-2 Resolved through audit activities.
WATER RESOURCES - SURFACE WATER SW-1 Based on the information gathered and discussed during the audit, confirm the following statements. The cooling tower basins, and other structures which require a large volume of water, will be filled from the Susquehanna River. During normal operation, it is estimated that each basin contains approximately 5.5 million gallons of water at any given time; however, the actual volume of water in the cold water basins fluctuates by design.
SW-2 Confirm the following statements regarding CCECs intake and discharge systems.
(1) CEG has maintained the operation of the intake and discharge structures throughout decommissioning in accordance with the stations Susquehanna River Basin Commission (SRBC) docket and PA DEP National Pollutant Discharge Elimination System (NPDES) permit to withdraw from and discharge to the Susquehanna River, respectively, and regular inspections have followed current CEG procedures. (2) The intake structure has been inspected in anticipation of the resumption of power operations. (3) CEG has not yet determined if maintenance dredging of the intake structure is needed prior to resumption of power operations.
SW-3 Confirm the following with respect to water use for construction-related activities.
Water for construction purposes will be brought onsite from offsite sources (tanker spray trucks) for these purposes. CEG has not quantified the volumes required; however, CEG expects that there will be no water demand from the Susquehanna River for construction-related activities.
SW-4 Based on the information gathered and discussed during the audit, confirm the following statements and information. (1) After plant shutdown in 2019, the external fill structure of Cooling Tower B was removed. (2) Rather than replacing the external fill structure, Cooling Tower B is expected to be fitted with a modification to match the counter flow design of existing Cooling Tower A. (3) This modification is not expected to increase Cooling Tower Bs consumptive water use compared to pre-2019 operations. (4) The SRBC guidelines specify requesting a consumptive use amount that would account for "reasonably foreseeable needs" (i.e., normal operations, required testing of equipment, and planned increases in operation). (5) CEG does not have any planned projects that would increase the actual consumptive use; however, CCEC may require additional water in the future. (6) CEG will implement flow metering during the plant restart. Unlike previous estimates based on pump curves, flow metering will provide actual consumptive use measurements. (7) To account for potential future project demands and uncertainties in past estimates compared to upcoming metered data, CEG is requesting a consumptive use
5 allocation of 21 million gallons per daya 9 percent increase over the allocation authorized in 2011.
SW-5 Based on the information gathered and discussed during the audit, confirm the following statements and information. (1) Prior to plant shutdown, discharge temperatures were consistently below 110°F. (2) There are no operational changes planned that would change the thermal discharge temperature from previous power operations. Therefore, CEG expects that the thermal discharge under resumption of power operations can meet a lower discharge temperature limit of 110°F. (3) The maximum yearly discharge temperatures for operations from 2014 through 2019 are as provided below:
Year Maximum (°F) 2014 98.2 2015 100.9 2016 103.1 2017 102.5 2018 101.6 2019 102.6 SW-6 Confirm the following statements with respect to the CCEC Environmental Emergency Response Plan. (1) CEG consolidated the requirements of the individual pollution prevention and spill response programs into this single facility plan. (2) The Plan includes the identification and description of locations where hazardous materials may be stored; plant pollution prevention facilities, equipment, and spill response materials; discussion of potential hazards; operating procedures for prevention of and response to hazardous material incidents; training requirements; listing of organization responsibilities and duties; and a description of regulatory reporting requirements. (3) The Plan also includes the downstream water users notification list and a section on storm water pollution prevention (NPDES program).
(4) CCEC maintains a flood protection dike, as referenced in the Plan. (5) Site environmental training occurs onsite for targeted positions based on responsibilities and associated duties, as referenced in the Plan.
WATER RESOURCES - GROUNDWATER RESOURCES GW-1 Resolved through audit activities.
GW-2 Resolved through audit activities and General RCIs and RAIs.
GW-3 Resolved through audit activities.
TERRESTRIAL RESOURCES TER-1 Confirm the following statements regarding CCECs lighting regime. (1) Lights along the shell of the cooling towers are present as Aircraft Warning Lights. (2) Each tower has twelve lights: four at the top, four at two-thirds height, and four at one-third height. (3) These lights are blinking red lights in compliance with Federal Aviation Administration requirements. (4) The lights are controlled by a photoelectric sensor located on the north side of the towers, which toggles the lights on or off based on ambient brightness (ON when it is dark or gloomy, OFF when it is bright and sunny).
6 (5) The cooling towers are the tallest structures onsite. (6) Once operational, lighting on all structures is expected to remain consistent with previous operation.
TER-2 Based on the information gathered and discussed during the audit, confirm that the application(s) of herbicide, pesticide, and mowing will only occur/be applied according to company procedures and within pre-disturbed areas only.
TER-3 Resolved through audit activities.
TER-4 Resolved through audit activities.
TER-5 Confirm the following statements regarding CCECs natural-draft cooling towers (NDCTs). (1) Both NDCTs utilize drift eliminators. No substantial increase in drift rate or chemical composition is expected compared to operations prior to the 2019 shutdown. (2) There is no expected substantial increase in particulate matter emissions compared to operations prior to the 2019 shutdown. (3) The length of the visual plume is anticipated to remain consistent with the NRCs 2009 LR SEIS, Section 2.2.8.4, which indicates a plume length of 1 to 2 miles under certain meteorological conditions. (4) Prior to the 2019 shutdown, there were no observable effects on vegetation near CCEC related to the NDCTs.
TER-6 Based on the information gathered and discussed during the audit, confirm the following information and statements.
(1) Review and confirm the accuracy of the information in the table below.
Incident Date Avian Species Count Condition Incident Details 6/18/2015 peregrine falcon (Falco peregrinis) 1 Entangled Discovered in razor wire. Bird escaped with no signs of injury.
4/12/2018 bald eagle (Haliaeetus leucocephalus) 1 Injured; later euthanized Discovered injured on north end of property.
Notification made to certified wildlife rehabilitator who then notified Pennsylvania (PA) Game Commission.
6/2/2018 peregrine falcon (Falco peregrinis) 1 Injured Discovered in razor wire. Certified wildlife rehabilitator contacted to remove/rescue bird.
Bird was returned to site.
6/18/2022 peregrine falcon (Falco peregrinis) 1 Deceased Discovered in razor wire. Remains left for natural degradation.
1/2/2026 bald eagle (Haliaeetus leucocephalus) 1 Deceased Discovered on south end of property impaled on landscaping stake near reforestation area.
Notification made to Pennsylvania Game Commission in accordance with CEGs existing Avian and Wildlife Management procedure (EN-AA-100-2000).
(2)
Confirm that CEG currently maintains a contract with a certified wildlife rehabilitator to respond to distressed or injured wildlife, including raptors, and to provide treatment and rehabilitation, as appropriate.
(3)
Confirm that CEG does not currently hold any permits under the Bald and Golden Eagle Protection Act (16 U.S.C. 668-668d) and the Migratory Bird Treaty Act (16 U.S.C. 703-712) for activities at CCEC.
(4)
Confirm that CEG has initiated a change to the Avian and Wildlife Management procedure (EN-AA-100-2000, Rev. 3) to provide clarification that an avian event involving a bald eagle at CCEC necessitates contacting
7 the U.S. Fish and Wildlife Service (USFWS) in addition to the PA Game Commission. Confirm that this procedural change will be instituted as soon as practicable but no later than the end of March 2026.
TER-7 Resolved through audit activities.
TER-8 Resolved through audit activities.
TER-9 Confirm the following statements regarding CCECs Wildlife Management Plan. (1)
PA Game Commission identified Three Mile Island as the only known site in Pennsylvania where bald eagles, peregrine falcons, and osprey nest in close proximity to one another. (2) A peregrine falcon pair has a seasonal nest on top of the CCEC reactor building and produces approximately 2-3 fledglings per year. (3)
An osprey pair nests on the north meteorological tower. (4) Bat boxes have been installed onsite. (5) Numerous bald eagles are observed onsite. (6) Common milkweed (Asclepias syriaca) exists onsite. (7) Bald eagle nest(s) exist onsite.
TER-10 Resolved through audit activities.
TER-11 Confirm the following with respect to wetlands delineation work at the CCEC site.
CEG has not prepared a wetland delineation report within the last five years. CEG plans to conduct a wetland delineation in late spring of 2026 and will submit the findings to the PA DEP no later than the end of August 2026.
AQUATIC RESOURCES AQU-1 Resolved through audit activities and General information requests.
AQU-2 Based on the information gathered and discussed during the audit, confirm that CEGs NPDES permit renewal application for CCEC contains the most up-to-date information on intake flow rates.
AQU-3 Resolved through audit activities.
AQU-4 Resolved through audit activities.
AQU-5 Confirm the following statements regarding proposed dredging at CCEC. (1) CEG is still evaluating the need for a USACE dredging permit; therefore, timing of a new permit has not yet been established. (2) CEG has an existing maintenance dredging permit (No. 21275724) from the PA DEP that allows for dredging within the intake structure and intake channel. (3) If the need to dredge the emergency canal within the Susquehanna River is identified, then CEG will pursue a USACE dredging permit.
AQU-6 Resolved through audit activities.
FEDERALLY PROTECTED ECOLOGICAL RESOURCES FPE-1 Resolved through audit activities and Aquatic Resources information requests.
FPE-2 Confirm that the following Best Management Practices will be implemented as part of the proposed action. (1) A 15 mph speed limit for vehicles will be observed. (2) No land clearing is planned in association with preparation activities. (3) Any demolition work will be conducted in accordance with CEG's existing administrative procedures to minimize noise, dust, and other disturbance. (4) USFWS eagle avoidance measures will be followed as provided in the Pennsylvania Natural Diversity Inventory document related to CCEC restart including within 660 feet (200 meters) of
8 a nest, all loud and intrusive maintenance and restoration activities will be conducted outside the breeding season, and existing landscape buffers will be maintained that screen activities from the nest(s).
FPE-3 See RAI FPE-1.
FPE-4 Confirm that CEG plans to informally restart the bat monitoring program at CCEC upon restart.
FPE-5 Resolved through audit activities.
FPE-6 Resolved through audit activities and General information requests.
FPE-7 Resolved through audit activities.
HISTORIC AND CULTURAL RESOURCES HCR-1 Based on the information gathered and discussed during the audit, confirm the following statements regarding the CCECs cultural resources program. (1) CEG maintains an active cultural resources protection plan (CRPP) from Exelon Generation Company, LLC for the Three Mile Island Generating Station Unit 1 now called CCEC on Three Mile Island. (2) While sections of the CRPP have not been updated to account for recently completed surveys and eligibility determinations (for example, information regarding the TMI-2 historic district programmatic agreement and surveys conducted under a Federal Energy Regulatory Commission review),
CEG may update the CRPP in the future. (3) CRPP is an active plan for this Section 106 undertaking.
HCR-2 Resolved through audit activities.
HCR-3 Based on the information gathered and discussed during the audit, confirm the following statements regarding the CCECs cultural resource procedures and protocols, and related excavation-based procedures. (1) CEGs Excavation, Trenching, and Shoring procedure (SA-AA-117, Revision 26) instructs CEG staff to review previously performed cultural, historical and paleontological resources and previous surveys to ensure excavation does not disturb identified resources. If excavations do encounter resources, work is stopped, placed in a safe condition, environmental personnel are notified (among others), and work does not continue until qualified staff conduct their mitigation and salvage work, and release the stop work. (2) Exelon Generation Company, LLCs Archaeological Resources Erosion Monitoring Plan (Revision 0) instructs staff on the procedures and protocols in place for monitoring and managing erosion of areas on Three Mile Island where there is high potential for inadvertent discovery of archaeological materials. This plan focuses on portions of Three Mile Island outside of the TMI Unit 1 Protected Area (i.e., CCEC operational area). The plan also involves proper site identification and controls, site protection and mitigation, notifications to other relevant parties, and work being conducted by qualified archaeological personnel. (3) Exelon Generations Environmental Evaluations (EN-AA-103-0001, Revision 9), CEG s Environmental Screening Checklist (EN-AA-103-F-02), and CEGs Managing Environmental Issues and Commitments (EN-AA-104) procedures all broadly focus on ensuring compliance with various environmental regulations, permits, inspections, and other standards at company sites prior to, during, and after performing work. (4) The CRPP and the Archaeological Resources Erosion Monitoring Plan provide instructions on the notification protocols when inadvertent discoveries of artifacts or human remains occur on Three Mile Island. The plan involves instructions for
9 contacting the Pennsylvania State Historic Preservation Office in the event of an inadvertent discovery of cultural materials and contacting law enforcement if human remains are discovered. (5) As per CEGs procedure LS-AA-1110, SAF 1.9, the NRC staff and the NRC Operations Center are notified of any event or situation related to the health and safety of the public or onsite personnel, or protection of the environment, for which a news release is planned or notification to other government agencies has or will be made.
HCR-4 Confirm that since publication of the NRCs 2009 LR SEIS, there have been no inadvertent discoveries of human remains or archaeological resources at the CCEC on Three Mile Island.
HCR-5 Combined with HCR-3.
HCR-6 Combined with HCR-3.
HCR-7 Combined with HCR-3.
HCR-8 Resolved through audit activities.
HUMAN HEALTH HH-1 Based on the information gathered and discussed during the audit, confirm CCEC's in-scope transmission lines satisfy National Electrical Safety Code standards through adherence to CEG's electrical safety procedures.
HH-2 Based on the information gathered and discussed during the audit, confirm that during the last five years of Occupational Safety and Health Administration Form 300A reports (2020 to 2024) there were no deaths or serious injuries among CCEC workers.
HH-3 Based on the information gathered and discussed during the audit, confirm that the administrative abnormal releases of tritium over the 2025 calendar year were consistent with past annual radioactive release reports since 2020 (i.e., that the 2025 quarterly release of tritium in this pathway was in the range of 2.7E-03 to 2.8E-03 Curie/quarter).
HH-4 Resolved through audit activities.
HH-5 Resolved through audit activities.
SPENT NUCLEAR FUEL SNF-1 Based on the information gathered and discussed during the audit, confirm that no fresh nuclear fuel is currently being stored onsite at CCEC (i.e., a complete fresh fueling of the reactor is required with 177 Framatome fuel assemblies) and that the onsite spent fuel pool has enough capacity to last up through the end of CCECs current renewed facility operating license term.
GREENHOUSE GAS EMISSIONS AND CLIMATE CHANGE GHG-1 Based on information gathered and discussed during the audit, confirm the following statements regarding Table 3.6-2 and Table 4.6-3 of the ER. (1) Sulfur hexafluoride was used in a switchyard breaker that was evacuated as part of the shutdown; the breaker will be refilled prior to restart. (2) Carbon dioxide is used for processes including its use as a purge gas. (3) An entry of NA or 0 value in Table 3.6-2 and
10 Table 4.6-3 reflects no leaks from those respective units. (4) The Environmental Protection Agencys eGrid was used to calculate GHG emissions from purchased electricity.
GHG-2 Resolved through audit activities.
POSTULATED ACCIDENTS SAMA-1 Based on the information gathered and discussed during the audit, confirm the following statements regarding CCEC external events and internal events. (1) The current internal events Core Damage Frequency (CDF) (including internal flooding) is 5.86E-6/year. The current external events CDF is 8.11E-5/year, the same as in the 2009 LR SEIS.
SAMA-2 Based on the information gathered and discussed during the audit, confirm the following statements regarding the seismic model of record CDF for CCEC. (1) The current seismic model of record, based on GI-199 (ML051600272), and captured in the TMI Seismic Hazard Screening Report (ML14090A271), is 3.3E-5/year. (2) This updated model is relatively unchanged from the 2009 LR SEIS value of 3.21E-5.
SAMA-3 Based on the information gathered and discussed during the audit, confirm the following statements regarding the fire probabilistic risk assessment (PRA) model of record CDF for CCEC. (1) The current fire PRA model of record CDF is 9.39E-5/year. (2) This value is higher than the 2009 LR SEIS value of 1.22E-5/year, as it includes the application of NUREG/CR-6850, which was done for a Fire PRA Peer Review. (3) A fire PRA update to incorporate the most recent state-of-the-art Fire PRA methodology is currently in progress for the site, which should have the effect of lowering that 9.39E-5/year value.
SAMA-4 Based on the information gathered and discussed during the audit, confirm the following statements regarding CCEC. (1) No facility changes would be made to CCEC that would be significantly different from the pre-decommissioning plant, except for matters like age-related replacements. (2) Any changes or plant improvements are or would be aimed at operation reliability safety and which would (a) support a lower CDF than used in the license renewal severe accident mitigation alternatives analysis; (b) not change the SMALL impact for design-basis accidents in the 2009 LR SEIS; and (c) not change the assumptions used by the NRC staff during the generation of estimated population dose values in Table E.3-1 of the NRCs 2024 Generic Environmental Impact Statement for License Renewal of Nuclear Plants (ML24087A133).
11 CHRISTOPER M. CRANE CLEAN ENERGY CENTER PROPOSED REAUTHORIZATION OF POWER OPERATIONS ENVIRONMENTAL AUDIT REQUESTS FOR ADDITIONAL INFORMATION GEN-1 REQUIREMENT: Refer to the Regulatory Basis discussion in this enclosure.
ISSUE: 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 a condition 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.
REQUEST: Based on the information gathered and discussed during the audit, 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). Include associated general maintenance, facility and system restoration, and related activities to support restart. In addition, summarize and quantify the nature of the activities with an emphasis on new ground-disturbing activities. For ongoing or planned project activities with ground-disturbance, specify the area affected (size, location, and if any area is previously undisturbed land), and timeframe.
GE-1 REQUIREMENT: Refer to the Regulatory Basis discussion in this enclosure.
ISSUE: No current geologic/hydrogeologic cross section or a geologic/hydrogeologic column for the site is available in the record that illustrates 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.
REQUEST: Based on the information gathered and discussed during the audit, provide an updated hydrogeologic cross-section (north to south through the power block) that illustrates the groundwater potentiometric surface and flow direction beneath the CCEC site.
AQN-1 REQUIREMENT: Refer to the Regulatory Basis discussion in this enclosure. In addition, Section 176(c) of the Clean Air Act requires Federal actions comply with state implementation plans (SIP) designed to attain and maintain the National Ambient Air Quality Standards (NAAQS). The General Conformity Rule, which implements Section 176(c) of the Clean Air Act,
12 ensures that Federal actions comply with any applicable SIP. General Conformity prohibits Federal agencies from authorizing any activities unless or until the Federal agency proposing the activities assures the emissions will not, within nonattainment or maintenance areas affected by the activities (40 CFR 93):
Cause or contribute to a new violation of the NAAQS; Increase the frequency or severity of an existing NAAQS violation; or, Delay timely attainment or maintenance of the NAAQS.
Federal agencies are required to prepare a conformity determination if an applicability analysis shows that a proposed action occurs in a NAAQS nonattainment area or maintenance area and the total of the actions direct and indirect emissions of criteria pollutants and their precursors would exceed threshold (i.e., de minimis) emissions levels (40 CFR 93.153(b)).
ISSUE: CCEC is in Dauphin County, Pennsylvania, which is designated as a maintenance area for particulate matter less than 2.5 microns (PM2.5). The ER presents emissions data in Table 3.6-1 and Table 4.6-2 for certain on-site sources, but the ER does not provide estimated criteria air pollutant emissions from preparation activities for resumption of power operations (e.g.,
ground disturbance, construction vehicles), worker vehicles or deliveries during preparation for resumption of power operations/restart activities, or worker vehicles or deliveries during operations of the facility. The NRC staff requires additional information to determine if air pollutant emissions associated with the proposed action would or would not exceed threshold (i.e., de minimis) emissions levels (40 CFR 93.153(b)).
REQUEST: Provide estimated emissions of criteria pollutants (carbon monoxide, sulfur dioxide, particulate matter, etc.) and their precursors (e.g., volatile organic compounds) associated with:
(1) worker vehicles and deliveries during preparation activities for the resumption of power operations. Emissions should be provided as annual emissions (tons/year) and (2) worker vehicle and deliveries during operations of CCEC. Emissions should be provided as annual emissions (tons/year). (3) With respect to the ground disturbing activities identified in RAI-GEN-1, provide fugitive dust emissions; as part of the response identify the area of disturbance, duration of ground disturbing activities, and associated construction equipment. Provide all assumptions and calculations supporting estimated air pollutant emissions FPE-1 REQUIREMENT: Refer to the Regulatory Basis discussion in this enclosure. In addition, under 50 CFR 402.14(d), Federal agencies must provide the USFWS or the National Marine Fisheries Service with the best scientific and commercial data available during Endangered Species Act (ESA) Section 7 consultations to allow for a thorough review of potential effects on listed species and critical habitats.
ISSUE: The NRC staff discussed several Determination Keys (DKeys) related to the ESA action area, and the staff requests CEGs response(s) to the USFWS DKeys to facilitate ESA Section 7 consultation.
REQUEST: Based on the information gathered and discussed during the audit, provide copies of the following documents: (a) Northern Long-Eared Bat and Tricolored Bat Rangewide DKey_CCEC, and (b) Northeast Endangered Species DKey_CCEC.