ML26071A140
| ML26071A140 | |
| Person / Time | |
|---|---|
| Site: | Triso-X |
| Issue date: | 03/12/2026 |
| From: | Office of Nuclear Material Safety and Safeguards, US Dept of Energy (DOE) |
| To: | |
| References | |
| Download: ML26071A140 (0) | |
Text
Environmental Impact Statement for the TRISO-X Special Nuclear Material License Application for a Fuel Fabrication Facility Errata to Final Report Docket Number: 070-07027 Issued: March 2026 Cooperating Agency U.S. Department of Energy Environmental Center of Expertise Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards
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Introduction This document lists the corrections (known as errata) to the Environmental Impact Statement for the TRISO-X Special Nuclear Material License Application for a Fuel Fabrication Facility. The errata correct the classification for volatile organic compounds (VOC) to clarify it as a major source of emission under the Clean Air Act (CAA) Title V regulations. The applicant would need to obtain a CAA Title V permit for operation emission. The impacts evaluation remains the same after assessing the source as major.
Errata by Chapter and Page Section 3.3.3.1 Air Quality Pg 3-16 Air emissions from the FFF could include nitrogen oxides, carbon monoxide, sulfur oxides, hydrocarbons in the form of volatile organic compounds, hazardous air pollutants, PM2.5, and PM10.
Air emission sources are managed in accordance with federal, state, and local air quality control laws and regulations. The FFF would comply with all applicable regulatory requirements of the Clean Air Act and Tennessee Department of Environment and Conservation (TDEC) requirements to minimize impacts on state and regional air quality. As discussed below, since the FFF is has the potential to be designated as a minor major source for emissions. However, TRISO-X would be required to obtain a Title V air pollution control operating permit, which would provide legally enforceable mitigation and monitoring conditions to ensure the FFF would remain in compliance with the Clean Air Act. Therefore, impacts on ambient air quality are expected to be SMALL.
Impacts to Class I areas, including the Great Smoky Mountains, are unlikely. Crosswind transport of emissions to this area would be unlikely and therefore would not likely adversely affect air quality and air quality-related values in this area (TRISO-X, 2025b).
Section 3.3.3.1.2 Operation Pg 3-22 The FFF air emissions constituents would all be below regulatory thresholds and be managed in accordance with Clean Air Act and TDEC requirements. Annual emissions of criteria pollutants would remain below the 250 tons per year threshold defining a major stationary source for PSD under New Source Review regulations; annual emissions of the individual criteria pollutants would remain below the 100-tons-per-year major source threshold under Title V regulations; and HAP emissions would remain below the Title V major source thresholds of 25 tons per year of any combination of HAPs and less than 10 tons per year of any single HAP (table 3.3-5). The estimated combined emissions of the criteria pollutants particulate matter, carbon monoxide, nitrogen oxides, and sulfur dioxide would total less than 15 tons per year. However, the FFF would have the potential to emit VOC at an annual rate slightly higher than the 100 tons per year major source threshold for criteria pollutants under Title V regulations (table 3.3-5).
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Therefore, the FFF would be subject to permitting as a minor major air pollutant source according to 40 Code of Federal Regulations (CFR) Part 70 requirements.
TRISO-X would be required to obtain a Title V operating permit through the TDEC Tennessee Air Pollution Control Board, which would provide legally enforceable requirements for TRISO-X to control and monitor emissions at the FFF to ensure compliance with the Clean Air Act.
Potential impacts upon visibility due to emissions would be minor. Because the FFF would be a minor air pollutant source, impacts upon air quality would be SMALL. Given the 34-mile distance to the The closest Class I area (the Great Smoky Mountains National Park) is 34 miles southeast of the FFF and prevailing winds as at the HCS blow northeast and southwest; therefore, described above impacts to Class I areas are unlikely. Given that the estimated criteria pollutant emissions at the FFF would remain below the major stationary source threshold for PSD; estimated HAP emissions would remain below the Title V major source thresholds; and given the strict requirements of the Title V operating permit that the FFF would be required to adhere to control and monitor potential VOC emissions, impacts on air quality during operation would be SMALL.
3.10.3 Public Health Impacts Pg 3-90 Potential public health impacts could result from the release of radiological materials and nonradiological hazardous materials that would be transported from the FFF through the air, surface water, or groundwater. For nonradiological impacts, the FFF would be required to adhere to strict air pollution control operating permit conditions and would therefore have a small effect on local air quality. be regarded as a minor source of air emissions. There are no planned liquid emissions.
3.14.2.10 Public and Occupational Health Pg 3-138 Strict adherence to the permit conditions of an air pollution control operating permit would minimize the impacts on local air quality of the FFFs would be considered a minor source of nonradiological air emissions. Workers at the FFF would be subject to chemical and occupational safety programs to prevent and minimize staff health impacts from radiological and nonradiological hazards in accordance with NRC and Occupational Safety and Health Administration (OSHA) regulations. Because the projects identified in appendix C are sufficiently far enough from the proposed FFF and from each other, and in light of assumed compliance with all applicable federal, state, and local regulations including those pertaining to safe transportation, storage, and use of nonhazardous, hazardous, and radiological materials, construction and operation of the projects would result in a SMALL risk of cross-project adverse health exposure reasonably foreseeable cumulative impacts on workers or the public.
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Table 4.1-1.
Air Quality Pg 4-2, 4-3 Air emissions from the FFF could include nitrogen oxides, carbon monoxide, sulfur oxides, hydrocarbons in the form of volatile organic compounds (VOC), hazardous air pollutants, particulate matter having an aerodynamic diameter less than 2.5 microns (PM2.5), and particulate matter having an aerodynamic diameter less than 10 microns (PM10). Air emission sources would be managed in accordance with federal, state, and local air quality control laws and regulations. The FFF would have the potential to emit VOC at an annual rate slightly higher than the 100 tons per year major source threshold for criteria pollutants under Title V regulations. All other air emissions from the FFF are estimated to remain below major source thresholds of would comply with all applicable regulatory requirements the Clean Air Act and Tennessee Department of Environment and Conservation (TDEC). The FFF would be required to obtain a Title V operating permit and adhere to strict permitting requirements to control and monitor emissions and ensure compliance with the Clean Air Act. requirements to minimize impacts on state and regional air quality Because the FFF would be a minor adhere to all mitigation and monitoring requirements of its air pollution control operating permit, impacts on ambient air quality would be expected to be minor.
4.2.1 Unavoidable Adverse Environmental Impacts and Irreversible Commitments of Resources 4.2-1 Meteorology and Air Quality Pg. 4-11, 4-12 The impact on meteorology, climatology, and air quality resulting from the proposed action would be SMALL. The FFF would have the potential to emit volatile organic compounds (VOC) at an annual rate slightly higher than the 100 tons per year major source threshold for criteria pollutants under Title V regulations. All other air emissions from the FFF are estimated to remain below major source thresholds of would comply with all applicable regulatory requirements of the Clean Air Act and Tennessee Department of Environment and Conservation (TDEC). The FFF would be required to obtain a Title V operating permit and adhere to strict permitting requirements to control and monitor emissions and ensure compliance with the Clean Air Act. requirements to minimize impacts on state and regional air quality. Because the FFF would be a minor source adhere to all mitigation and monitoring requirements of its air pollution control operating permit, impacts on ambient air quality are expected to be SMALL.
The NRC staff concludes there would be minimal overlap for impacts from both climate change and the proposed action. Climate change impacts are predicted to occur over long periods of time, and the license term of the proposed facility is 40 years. Therefore, impacts from the proposed FFF that may overlap with the impacts of climate change are likely to be SMALL.
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4.5 Cost and Benefits of Proposed Action and Alternatives Table 4.5-1 Air Quality Pg 4-28 Air emissions from the FFF could include nitrogen oxides, carbon monoxide, sulfur oxides, hydrocarbons in the form of volatile organic compounds (VOC), hazardous air pollutants, particulate matter having an aerodynamic diameter less than 2.5 microns (PM2.5), and particulate matter having an aerodynamic diameter less than 10 microns (PM10). Air emission sources would be managed in accordance with federal, state, and local air quality control laws and regulations. The FFF would have the potential to emit VOC at an annual rate slightly higher than the 100 tons per year major source threshold for criteria pollutants under Title V regulations. All other air emissions from the FFF are estimated to remain below major source thresholds would comply with all applicable regulatory requirements of the Clean Air Act and TDEC. The FFF would be required to obtain a Title V operating permit and adhere to strict permitting requirements to control and monitor emissions and ensure compliance with the Clean Air Act. requirements to minimize impacts on state and regional air quality. Because the FFF would adhere to all mitigation and monitoring requirements of its air pollution control operating permit would be a minor source, impacts on ambient air quality would be expected to be SMALL.
Appendix E E.2.4.1 Air Quality and ClimatologyComments of the EPA Pg. E-4.
The NRC received comments from the EPA requesting that the EIS include revised National Ambient Air Quality Standards (NAAQS) for primary particulate matter (PM2.5) and secondary sulfur dioxide (SO2); an air pollutant emissions estimate for construction of the FFF; and clarification regarding whether the FFF would be subject to permitting as a minor air pollutant source or a major air pollutant source according to 40 CFR Part 70.2 requirements.
Response: Table 3.3-2 of the EIS has been updated to reflect the revised NAAQS. Section 3.3.3 of the EIS has been revised to include an air pollutant emissions estimate for construction of the FFF and to clarify the FFF would be subject to permitting as a minor major air pollutant source due to the FFFs potential to emit volatile organic compounds (VOC) at an annual rate slightly higher than the 100 tons per year major source threshold for criteria pollutants under Title V regulations. All other air emissions from the FFF are estimated to remain below major source thresholds.
Comment: (TF3-EIS-DR-00013)