ML26075A084
| ML26075A084 | |
| Person / Time | |
|---|---|
| Issue date: | 02/20/2026 |
| From: | Burris W NRC/NMSS/DREFS/EPMB3 |
| To: | Langley S Duke Energy Carolinas |
| References | |
| Download: ML26075A084 (0) | |
Text
1 Bill Burris From:
Bill Burris Sent:
Friday, February 20, 2026 11:26 AM To:
Langley, Shannon Cc:
Mary Richmond; Nancy Martinez; Condon, Caitlin A
Subject:
Request for Clarification, Surface Water Hydrology, Belews Creek ESP Environmental Report as submitted on 30 DEC 2025.
- Hello, By letter dated December 30, 2025, Duke Energy Carolinas, LLC (Duke) submitted an early site permit (ESP) application to the U.S. Nuclear Regulatory Commission (NRC) for the Belews Creek Site located in Stokes County, North Carolina. On February 9, 2026, the NRC provided notice that the application was accepted for docketing and contains suicient information to initiate detailed safety and environmental technical reviews.
Over the next few weeks, the NRC plans to issue a Federal Register Notice of Intent to develop an Environmental Impact Statement and initiate scoping with the public. Simultaneously the NRC plans to initiate an environmental regulatory audit.
To further assist the NRC in expediting the development of the audit plan, we are asking for further clari"cation regarding surface water as outlined below. It would be best if we can arrange a meeting between our subject matter experts and those of the applicant to work out some of the issues.
Prior to such a meeting it would be helpful if Duke would provide copies of the following documents referenced in the Environmental Report.
- Duke water chemistry program description
- Spreadsheet analysis of Belews Lake mass balance
- Reedy Fork near Oak Ridge stream"ow record for 1956-2024
- CORMIX model input and output "les (for Belews Lake and Dan River analyses) and any related modeling reports
- Duke Energy, 2021. CWA §316(a) Balanced and Indigenous Community Study Report, Belews Creek Steam Station, Belews Creek, North Carolina, April 2021.
The NRC subject matter experts have expressed concerns regarding the baseline surface water hydrology conditions described in the Environmental Report.
ER Section 5.2 states: the past 50 years of BCSS operation and its eects on Belews Lake and the surrounding environment represent the existing baseline condition and The analysis of operational eects on surface water resources described in this section are based on the aected environment described in Chapter 2. However, the impacts of operations of the proposed plant complexes on water use (e.g., impacts on hydrologic alterations to Belews Lake and Dan River) and water quality (i.e., impacts of cooling water discharged to Belews Lake and Dan River) did not consider the existing baseline (aected) environment. For instance, with respect to thermal impacts, the ER assessed the impacts from operations of the proposed plant complexes without
2 the heat load from operation of BCSS by using Mayo Reservoir as a reference (surrogate) lake rather than the existing aected environment of Belews Lake itself. Similarly, the ER considers the impacts on hydrologic alterations to Belews Lake and Dan River without consideration of BCSS consumption or BCSS condenser cooling.
The current state of the aected environment establishes the baseline conditions for evaluating the eects of building and operation on water resources. The ER provided an analysis of surface water resources under conditions that will not occur until after the year 2039 (i.e., complete shutdown of BCSS and operation of all 3 proposed plant complexes) under an aected environment that is not representative of current baseline conditions. Furthermore, as stated in the ER, the residence time of Belews Lake has been estimated to be 1500 days, therefore, any changes to Belews Lake as a result of derating BCSS could take a minimum of 4 years.
An analysis that uses the existing baseline conditions of Belews Lake (including operation of BCSS) in Chapter 2 to evaluate the impacts on hydrologic alterations (e.g., water balance, lake water levels) to Belews Lake and Dan River and impacts of cooling water discharged to Belews Lake and Dan River (e.g., thermal plume) from operations of the proposed Plant Complexes is needed. Provide this information using the existing baseline conditions of Belews Lake, including operation of BCSS.
We look forward to engaging with Duke regarding this issue.
William K. Burris, P.G.
Environmental Project Manager Environmental Center of Expertise Oice of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Rockville, MD william.burris@nrc.gov 301-415-1621