ML19120A428

Letter to J. Isakson Interim Storage Partners Llc'S License Application to Construct and Operate the Waste Control Specialists Consolidated Interim Storage Facility, Andrews County, Texas, Dkt No. 72-1050 - First RAI (W/Enclosure)

ML19120A428
Person / Time
Site:	Consolidated Interim Storage Facility
Issue date:	04/23/2019
From:	Nguyen C Spent Fuel Licensing Branch
To:	Isakson J Consolidated Interim Storage Facility
Nguyen C
References
CAC 001028, EPID L-2017-NEW-0002
Download: ML19120A428 (37)

Text

National Environmental Policy Act of 1969Code of Federal Regulations

The Licensee shall submit License Amendment(s) to this license to incorporate applicable portions of License Renewals listed below, within 120 days of the effective date of License Renewal Approval for each of the following:

• • • • ER Section 2.2.2.5 states that an approximately 2,134 m [7,000 ft] railroad side track would be built adjacent to the existing railroad access loop for spent nuclear fuel (SNF) deliveries to the proposed CISF. The ER provides limited information on the construction, operation, and decommissioning activities associated with the railroad side track. Specifically, additional information on the railroad side track is needed to support the NRC staff's description of the proposed action and evaluation of environmental impacts in the Environmental Impact Statement (EIS).

• • • • • • • ER Section 2.2.2.6 states that a concrete batch plant may be constructed to facilitate storage module construction and future expansion of the site. The ER provides limited information on the construction, operation, and decommissioning activities associated with the batch plant. Specifically, additional information on the batch plant is needed to support the NRC staff's description of the proposed action and evaluation of environmental impacts, including cumulative impacts, in the EIS. ER Section 2.3 and Attachment 2-2 provide a discussion of the criteria and weighting factors that ISP used to identify potential locations to site the proposed CISF, as well as the scores for the four sites considered. Table 2.3-4 in the ER provides the overall scoring based on three criteria: siting, environmental considerations, and operational considerations. The discussion in ER Section 2.3.3 identifies certain criteria either as environmental considerations or as operational considerations; however, no siting criteria are identified. As a result, it is not clear how siting scores were determined in Table 2.3-4. Therefore, please clarify how the siting scores were calculated.

Additionally, in ER Section 2.3.7, ISP provides its review of a potential site in Eddy County, New Mexico, One of the references used is a 2015 report from Cox McLain Environmental Consulting. The NRC staff was not able to locate this report within ISP's license application. Therefore, please provide a copy of the report or point the staff to its location within the application. The ER should provide a description of ISP's outreach efforts made to inform communities and affected populations within the region of the proposed CISF. This information would assist the NRC staff's analysis regarding the potential for disproportionate impacts to communities. ER Section 1.3 provides a general discussion of applicable regulatory requirements, permits, and required consultations for construction and operation of the proposed CISF. Based on the NRC staff's review, it appears that some regulatory and permitting requirements are not discussed in the ER. For example, State permitting requirements may apply to construction and operation of the railroad side track that may extend into New Mexico (see ER Section 2.2.2.5 and ER Figure 4.5-1) and a new concrete batch plant (see ER Section 2.2.2.6). A complete discussion of applicable regulatory requirements is needed to support the NRC staff's description and evaluation of applicable statutory, regulatory, and permitting requirements in the NRC's EIS.

ER Section 3.1 states that land use classification in the vicinity of the proposed CISF is primarily rangeland, built-up land, and barren land. Provide specific information on the distribution of classes of land use within and surrounding the proposed CISF. NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs, recommends figures should be used to describe the area for land use (NRC, 2003). In addition, NUREG-1567, Standard Review Plan for Spent Fuel Dry Storage Facilities, recommends that land use should be described within an 8-km [5-mi] radius of independent spent fuel storage facilities (ISFSIs)

(NRC, 2000). The requested information is needed to support the NRC staff's description of the affected environment and evaluation of environmental impacts in the EIS. ER Section 3.1 states that land uses within a few miles of the proposed CISF includes drilling for and production from oil and gas wells and that the Elliott Littman oil field is to the northwest, the Freund and Nelson oil fields are to the south, the Paddock South and Drinkard oil fields are to the southwest, and the Fullerton oil field is to the east. However, the ER does not provide specific information on the type, status, and location of the oil and gas wells in the area of the proposed CISF. Specifically, this information is needed to support the NRC staff's description of the affected environment and evaluation of environmental impacts. ER Section 3.1 states that the proposed CISF would include 130 ha [320 ac] of land within the WCS property boundary. However, the description of the land area does not explicitly state whether the area includes land for the new rail siding. Therefore, clarification is needed on both the total land and soil areas disturbed by the proposed action (including the new rail siding). This information is needed to support the NRC staff's description of the proposed action and evaluation of environmental impacts in the EIS. The analyses of radiological impacts from transportation in ER Sections 4.2.6; 4.2.7; 4.2.8; and Attachment 4-1 do not appear to specifically describe radiological impacts or any dose calculations applicable to transportation workers such as vehicle crew members and escorts, cargo handlers and inspectors, rail yard workers, or to emergency response personnel. For example, the ER incident-free population dose estimate is described as applying to "residents," and accident calculations do not provide details as to whether the exposed population includes transportation workers. Because workers would be exposed to radiation and risks from the proposed transportation shipments, an analysis of radiological impacts that addresses workers

should be included as part of the transportation impact analysis. This is consistent with NRC guidance in NUREG-1748, which states that radiological impacts to both the public and workers should be evaluated (NRC, 2003). A subset of RADTRAN code input parameters is tabulated or otherwise described in the ER (Sections 4.2.6; 4.2.7, 4.2.8, and Attachment 4-1). If any other RADTRAN input parameters that were used in any ER transportation radiological risk assessment calculations (addressing both incident-free transportation and accidents) were modified from code defaults, these parameters should be identified along with the technical bases and applicable source references for parameter values. Complete documentation of the calculation inputs is necessary for the NRC staff to evaluate the technical correctness and applicability of these calculations to the

proposed action.

ER Sections 4.2.6, 4.2.7, 4.2.8, and Attachment 4-1 indicate that transportation doses and risks were calculated using the RADTRAN code for risk assessment and the WebTRAGIS code for routing. Code input and output files will allow the NRC staff to verify that the computer code runs support the calculation methods, assumptions, input parameters, and results that are described in the ER. Because the ER includes several different transportation dose/risk calculations, information should also be provided that links specific files to the applicable ER analysis results (e.g., 3 incident-free representative routes; 3 types of accident analyses; 12 short-distance heavy-haul truck or barge routes). ER Sections 4.2.6.1 and Attachment 4-1 indicate that transportation dose results were calculated using spreadsheets. These ER Sections indicated that these spreadsheets incorporated the results of RADTRAN code output (unit risk factors) and WebTRAGIS output (routing details) to calculate transportation doses. The requested information will allow the NRC staff to verify that the calculations are technically correct and consistent with the methods, assumptions, input parameters, and results described in the ER. ER Section 4.2.6 describes that the transportation analysis evaluated both incident-free transportation and accidents and references a study entitled "Transportation of Spent Nuclear Fuel to and from the Waste Control Specialists Proposed Consolidated Interim Storage Facility" in "Attachment 4.1" for the analysis. ER Section 4.2.8 (Impacts from Transportation Accidents) also references Attachment 4.1 for more details on accident dose risks. The ER does not appear to have an attachment with that number or title. The ER does include an Attachment 4-1 that contains information supporting RADTRAN incident-free calculations and WebTRAGIS routing, but does not appear to describe accident analysis methods or calculations. As a result, please provide further information on the methodology or calculations used to determine the impacts of transportation accidents. If this information is included in an analysis that was omitted from the Environmental Report, that may be used to satisfy this request. The requested information will allow the NRC staff to verify that the application contains complete and accurate references.

ER Section 4.2.8.2 (Accident Involving a Release of Radioactive Materials) states that accidents involving release of radioactive materials were evaluated by the RADTRAN code but the section does not appear to state whether ISP conducted these code calculations, or if they were from another source. If the RADTRAN calculations were from a prior analysis, the applicable analysis documentation should be referenced. If the RADTRAN calculations were conducted specifically for the ER, that should be clarified and information supporting the code runs including methods, assumptions, inputs, and results should be provided. The requested information will allow the NRC staff to evaluate the technical correctness and applicability of these calculations to the proposed action.

ER Section 4.2.8.2 (Accident Involving the Release of Radioactive Material) states that the radionuclide inventory used for estimating transportation accident consequences is provided in Attachment 4-1. The inventory information is not provided in Attachment 4-1. The RADTRAN code uses package release fractions in these accident calculations; therefore, the calculated release and dose are a function of the radionuclide inventory. The requested information

will allow the NRC staff to review the technica l correctness of the transportation accident dose calculations. ER Section 4.2.8.3 [Loss-of-Shielding (LOS) Accidents] refers to results in ER Table 4.2-9 and states that the highest calculated dose is 0.12 rem; however, the table shows a higher calculated dose of 0.26 rem for the Maine Yankee Route. Inconsistent statements in the ER should be corrected.

ER Section 4.2.9 (Non-radiological Risks) refers to an NRC analysis of non-radiological transportation risks from shipping SNF to a repository without reference to the analysis.

Additionally, this entire section is based on analysis and discussion that is not specific to the ISP proposal with no discussion that links the referenced analyses to the impact analyses and conclusions. The incomplete reference information in the ER should be provided. Additionally, a description of the applicability of referenced analyses to the proposed project should be added so that the technical basis for adoption of results in the ER is clear and transparent with clear linkage of these analyses to any specific impact conclusions. ER Sections 4.2.6, 4.2.7, 4.2.8, 4.2.9, and Attachment 4-1 are written in passive voice that lacks information about attribution (specifically, what parties conducted which analyses). These sections should be reviewed and revised to unambiguously attribute all ISP methods, analyses, assumptions, and conclusions to ISP and attribute other analyses to properly referenced sources. ER Section 4.3 identifies increased soil erosion as the result of construction activities due to site clearing and grading. ISP should identify and describe the planned best management practices (BMPs) that it will use to mitigate erosional impacts throughout the life of the CISF site. The additional information about BMPs would be used to assess the potential environmental impacts due to operation of the proposed CISF.

ER Section 4.3 (Geology and Soils) states that cut-and-fill activities might be required for some portions of the site. Provide information about the land areas that would be leveled and the potential volumes of material that would be exhumed and or redistributed to level the site.

ER Section 4.1 (Land Use Impacts) stated "[d]uring the construction phase of the CISF, conventional earthmoving and grading equipment would be used. The removal of very dense soil or caliche may require the use of heavy equipment with ripping tools. Soil removal work for foundations would be controlled to reduce over-excavation to minimize construction costs.

In addition, loose soil and/or damaged caliche would be removed prior to installation of foundations for seismically designed structures." Additional information about ISP's land surface modification, including details about how the natural topography and stratigraphy at the site would be modified by the proposed action, is needed to assess the potential environmental impacts due to construction and operation of the proposed CISF. A site-specific soil survey of the proposed CISF site has not been performed. Four soil types were previously inferred by USDA to occur on the proposed CISF site; it is unknown how the average material properties associated with these four soil types compare with the actual material properties of soils recently tested onsite. ISP should provide additional information to correlate between the inferred USDA soil types and the recent material property data obtained from onsite soil borings. ER Section 3.1 states that land uses within a few miles of the proposed CISF includes drilling for and production from oil and gas wells. Provide information on oil- and gas-producing formations, such as depth and thickness, in the vicinity of the proposed CISF.

ER Section 3.1 states that land uses within a few miles of the proposed CISF includes drilling for and production from oil and gas wells, and identifies oil fields northwest, south, southwest, and east of the proposed CISF. The requested information would be used to more accurately describe these current activities in the affected environment. The USACE letter concerning "Waste Control S pecialists Disposal Site-Non-Jurisdictional Determination Request" (WCS Project No. SWF-2007-173) supplied in ISP's license application states that the determination was valid for 5 years. The determination, therefore, expired in 2012. Updated surface water information is needed for the NRC staff to assess the potential environmental impacts to surface and groundwater near the proposed CISF.

• The additional information requested is needed to describe the surface water characteristics at and around the proposed CISF, and to evaluate potential impacts on surface water resources. **Baker Spring is described variously in literature as either a seasonally intermittent surface water feature sourced by rainfall (e.g., ISP's description at ER page 3-18) or as a Gatuna Formation groundwater-sourced spring (e.g., page 17 of Lehman and Rainwater, 2000). Updated surface water characterization information about Baker Spring and the other local spring are needed to describe the affected environment and to assess the potential environmental impacts to surface

water and groundwater near the CISF. **

• • • • • Clarified topographic information, site water-balance information, descriptions of any planned usage of new or existing manmade surface water bodies, and hydrostratigraphic information for the units present immediately beneath the proposed CISF site is needed to assess potential environmental impacts to surface water and near-surface groundwater at the proposed CISF. *

• • The regional stratigraphic column illustrated in SAR Figure 2-13 is too complicated (it shows units that are not present at ISP-WCS) and does not clearly describe the local subsurface geologic situation at the CISF. More simplified and accurate visual information is needed to clearly describe and communicate the affected groundwater and vadose zone environments at the proposed CISF, and to facilitate assessments of the potential environmental impacts of CISF construction, operation, and decommissioning.

Additional information about the depths to the tops of the local hydrogeologic units at the CISF site is needed to compare with potentiometric surface maps of hydraulic head and to accurately describe the affected groundwater and vadose zone environments at the proposed CISF to support the assessment of the potential environmental impacts of CISF construction and

operation. The CISF is located at or near a surface water/groundwater basin divide, where three near-surface geologic units have discrete interfaces within relatively short distances (i.e.,

Ogallala Formation, Antlers Formation, and Gatuna Formation). For the adjacent LLRW site, Lehman and Rainwater (2000) clearly indicated what units lay beneath the proposed facility.

In contrast, SAR Figures 2-16 and 2-17 only provide generic material type labels on the geologic cross-sections for the proposed CISF, and are, therefore, not explicit about which formations underlie the proposed facility. The proposed CISF would be located above regionally extensive, formally named geologic units having characteristics that are well-described in the literature. Additional information is needed about which hydrogeologic formations underlie the CISF site to accurately describe the affected groundwater and vadose zone environments at the proposed CISF and support assessment of the potential environmental impacts of CISF construction, operation, and decommissioning. ER Section 4.4 states that during construction and operation of the proposed CISF, potable water will be supplied by the existing potable water system that serves the WCS facility.

Additional information is needed to support assessment of the environmental impacts that ISP's CISF potable groundwater consumptive use will have on groundwater resources and cumulative impacts. ER Sections 3.4.14.1 and 3.4.14.5 use terminology [e.g., 55 m and 69 m (180 ft and 225 ft) zones] that is not defined in the ER. Additional information about which geochemical data are associated with the sampled groundwater formations (e.g., Gatuna, Antlers, Ogallala, Cooper Canyon, Santa Rosa, and or Trujillo) is needed to support assessment of the potential environmental impacts to groundwater quality at or near the proposed CISF. Please provide a map that spatially indicates where geochemical samples were acquired from wells/boreholes, relative to the footprint of the proposed CISF. In response to RSI 9.6, the applicant indicated, "The-nearest aquifer is located at a depth of 245 to 305 m [800 to 1,000 ft] below ground surface." The response to RSI 9.6 does not indicate by name a hydrogeologic formation associated with this aquifer. The applicant should clarify if they are referring to a water-bearing sandy zone within the Cooper Canyon Formation or to another aquifer deeper in the Dockum Group. Also in response to RSI 9.6, the applicant indicated that "(t)he WCS site is separated from that [unspecified nearest] aquifer by the Dockum Formation, consisting of low permeability clays (109 cm/s)." The applicant should clarify whether it meant, "separated from that aquifer by the Cooper Canyon Formation," given that the Dockum Group contains two aquifers at the ISP/WCS property located below the Cooper Canyon Formation, as well as additional water-bearing sandy zones within the otherwise clayey Cooper Canyon Formation.

Ecological studies at the WCS site were conducted during 1996, 1997, 2004, and 2006. Some of these surveys covered the entire proposed CISF area while others covered only a portion of the proposed CISF area; however, due to the age of these surveys and the natural changes of plants and animals over time, the presence or absence of State and Federal species of concern, including threatened and endangered species, should be confirmed. The NRC staff understands that it takes more than one growing and breeding season to conduct baseline ecological surveys. The NRC staff's review of WCS's R04100, Amendment No. 31 (October 2017) suggests that updated written documentation from the U.S. Fish and Wild Service (USFWS) and the Texas Parks & Wildfire Department (TPWD) may be available as a result of License Condition #160, which states "The Licensee must provide to the executive director every five (5) years written documentation from the Texas Parks and Wildlife Department and the United States Fish and Wildlife Service regarding the presence of threatened or endangered species occurring near the site." In addition, License Condition #161 noted in WCS's Amendment No. 12 from 2012 stated, "The Licensee must recognize Baker Spring as a perennial water body and conduct appropriate aquatic surveys to establish baseline conditions and to identify the supported species, including aquatic and benthic invertebrates." Specifically, the additional information requested regarding ecological studies conducted after 2006 and baseline ecological studies and surveys previously conducted for Baker Spring is needed to describe the most recently observed ecological characteristics at and around the proposed CISF, and to evaluate potential impacts on ecological resources, including sensitive species. *

• ER Section 1.3.2.3 states that ISP would obtain from the TCEQ any required air permits to support construction and operation of the proposed action. However, the ER is unclear whether this would be a new permit or a modification to the existing WCS site air permit. In addition, it is unclear whether some of the railroad side track construction occurs in New Mexico (see RAI PA-2); however, the ER does not provide information about air permitting associated with the New Mexico Environment Department. Specifically, this information is needed to support the NRC staff's description and evaluation of applicable statutory, regulatory, and permitting requirements in the NRC's EIS. Attachment A of the SAR Chapter 2 (a PDF file about 5,000 pages long) contains the hourly data from four onsite meteorological stations over a 6 year period from 2010 to 2015.

However, summary information for the onsite meteorological stations is limited to wind speed and direction averaged over a 5 year period (see ER Section 3.6.4). Onsite meteorological data supports the general description of the affected environment, and any inclusion of this data in the EIS would be in summary form. Specifically, additional information on the onsite meteorological data is needed to support NRC's description of the proposed action and the affected environment in the EIS. **

• ER Table 3.6-8 provides current annual emissions for some criteria pollutants for Andrews County and the State of Texas. However, this table does not include estimates for particulate matter PM 10 or non-radiological hazardous air pollutants. Also, this table does not include emission estimates from New Mexico, where a portion of the proposed action's activities, the construction of the CISF railroad side track, might occur (see RAI PA-2). Finally, ER Table 3.6-8 only presents a snapshot of current conditions and does not address regional emissions over the 40-year lifetime of the proposed action. Specifically, the regional annual air emissions are needed, including key air emissions (e.g., particulate matter PM 10), to support the NRC staff's characterization of the environment where the proposed action's activities occur over the lifetime of the proposed action. The ER does not provide the air emission generated by the existing WCS facilities, which are located in close proximity to the proposed CISF site. ***ER Section 1.3.2.3 indicates that mobile sources (e.g., train, heavy haul trucks, transporters, and private vehicles) were not included as part of the air quality impact analyses because these sources are not regulated by TCEQ. ER Section 2.2.2.6 states that if an onsite concrete batch plant is not constructed, then precast concrete pieces will be transported cross country to the proposed WCS site. Potential emissions from this activity were not included in the ER analyses. ER Section 3.2.3 states that a railroad side track will be constructed. It is unclear if emissions from this activity were included in the project emission estimates described in ER Section 4.2.1.

This information is needed to accurately characterize the entire range of emission sources and project emissions from the proposed action in the EIS.

• • • • • ER Section 1.3.2.3 identifies that both the construction and the operation activities generate air emissions. ER Section 4.5.3 states that the CISF could be built in eight phases and indicates that this phased approach means that construction and operation activities could overlap at times. ER Section 4.5.3 also indicates that the first phase would also include site infrastructure construction (e.g., facilities, the railroad side track, possibly a new concrete batch plant). The air impact analysis in ER Section 4.6 (i) does not clearly identify the proposed action's highest annual or peak year emissions considering the possible overlap of stages (i.e., construction, operation, and decommissioning) or phases as well as the distinction in construction emission levels between Phase 1 and the subsequent phases, (ii) only considers particulate matter, (iii) does not consider combustion emissions from mobile sources, and (iv) only provides estimated annual emission levels for the concrete batch plant (note that these emission level estimates in ER Table 4.6.2 do not specify units). The EIS analyses need to consider the peak year emission levels since this relates to the largest potential impacts from the proposed action. *

• • • • ER Sections 4.2.1 and 4.6 state that air dispersion modeling was conducted to assess impacts of the proposed CISF. However, information in the ER concerning the modeling input is limited and did not include the emission inventory used as input for the modeling. ER Section 4.6 stated that construction stage particulate matter PM 10 emission were below the NAAQS. However, the analyses in the ER did not (i) provide the actual modeling results, (ii) compare the results to PSD thresholds, (iii) provide baseline ambient pollutant concentrations for inclusion in the NAAQS assessment, or (iv) explain why the air dispersion modeling was limited to the particulate matter PM 10 emissions from fugitive dust from the construction stage. The requested detailed information provides a basis for characterizing the quality of the air dispersion modeling results. ***ER Section 1.3.2.3 identifies two primary types of air emissions associated with the proposed action: combustion emissions from construction equipment and fugitive dust from excavation activities and construction equipment. However, the air quality impact analyses in ER Section 4.6 is limited to fugitive dust. The EIS impact analyses need to consider the entire range of emission sources (see RAI AQ-4), the peak year emission levels (see RAI AQ-5), as well as the entire range of pollutants generated by the proposed CISF to accurately characterize the air quality impacts. If additional air dispersion modeling is conducted in response to this RAI, consideration should be given to the information requests in RAI AQ-6 associated with the existing air dispersion modeling.

ER Section 4.6 states that the air emission inventory used for assessing impacts assumes a 50-percent reduction in fugitive dust emissions for dust suppression activities. However, the ER does not identify the actual, specific mitigation measure that would be implemented or the basis for the using this 50 percent value. Other ER text identifies several factors that influence the level of dust suppression activities: water conservation (see ER Section 4.2.3), possible requirements from an air permit, which has not yet been obtained (see ER Section 1.3.2.3), and implementation of a Best Management Emission Control Plan, which has not yet been developed (see ER Section 1.3.2.3). Providing a basis for the effectiveness of the dust suppression mitigation allows for an accurate characterization of the air emissions and associated impacts.

• The discussion of greenhouse gas emissions is limited to text in ER Section 8.5, citing NUREG-2157, and states that the proposed action's emission would be small but would add to the overall atmospheric burden of emissions that could contribute to potential long term impacts (NRC, 2014). The EIS needs to address the project's greenhouse gas emissions and the potential overlap of environmental impacts from climate change and the storage of SNF at the

WCS site ER Sections 3.7.1 and 4.7.3 provide information on background noise levels at the neighoring URENCO facility measured in September 2003. In ER Section 4.7.3, ISP assumes that the measured September 2003 background noise levels at URENCO would be similar to current background noise levels at the proposed ISP CISF. Current site-specific information on background noise levels is necessary to describe the affected environment and establish background/ambient (baseline) conditions of the site so that the NRC staff can evaluate the impacts of construction and operation of the proposed CISF. ER Section 4.7.1 concludes that, "(p)redicted noise levels, background noise levels, calculated construction noise levels, and operational noise levels should typically be well below both HUD and Environmental Protection Agency (EPA) guidelines." However, the ER should estimate peak noise levels that would be generated during construction and operation of the proposed CISF to support this conclusion.Estimates of peak noise levels generated during construction and operation are needed to support the NRC staff's evaluation of potential noise impacts to offsite and onsite receptors.

• • The ER should assess the environmental impacts of noise to workers during construction and operation of the proposed CISF. Specifically, estimates of peak noise levels that workers will experience during construction and operation of the proposed CISF are needed to support the NRC staff's evaluation of noise impacts to onsite receptors. In response to its review of ISP's archeological survey of the proposed CISF site, the New Mexico State Historic Preservation Officer (NM SHPO) stated, "The SHPO concurs that no additional cultural resources identification efforts are needed for this undertaking with the condition that all new ground-disturbing and construction activities are confined to Texas.

If, however, any construction related ground disturbances such as staging areas, equipment or materials storage yards, or access roads are needed in New Mexico, then a cultural resource survey will be required to identify and evaluate historic properties in the area of potential effects." (see ER Appendix A, Attachment 3-3). Figures in the ER and SAR show that the railroad side track to be built as part of the proposed CISF would extend into New Mexico (e.g., ER Figures 3.3-1, 3.6-1, 4.5-1, 4.12-1, and 6.1-1 and SAR Figures 1-1, 1-2, and 2-1).

Therefore, the route of the railroad side track would result in new ground-disturbing and construction activities in New Mexico. Specifically, the requested information is needed to support the NRC staff's evaluation of applicable agency coordination and consultation requirements and complete the NRC staff's description of the affected environment and assessment of environmental impacts on cultural and historic resources in the EIS.

ER Section 3.8.2 states that, "In May 2015, a pedestrian archeological survey was completed in order to inventory and evaluate archeological resources on private land within the footprint of the proposed spent nuclear fuel CISF at the existing Waste Control Specialists waste disposal facility in western Andrews County, Texas." Information in ER Appendix A and D, indicates that the draft report for this survey entitled, "Intensive Archeological Survey of the Proposed Waste Control Specialists Spent Nuclear Fuel Consolidated Interim Storage Facility, Andrews County, Texas," was submitted for review to the Texas Historical Commission (THC) on July 2, 2015.

The requested information is needed to support the NRC staff's description of the affected environment and assessment of environmental impacts on cultural and historic resources in the EIS. Appendix A of the ER provides estimated employee compensation and regional tax impacts of the proposed CISF between 2019 and 2028. The iMpact analysis for PLANning (IMPLAN) model was run for a period of 20 years; however, ISP is requesting a license for a term of 40 years. This additional information is needed to evaluate the potential socioeconomic impacts on the states and the counties within the region during the requested license period. ER Section 3.11.1.1 (Background Radiation Levels at the CISF) provides monitoring results in Table 3.11-1, but should also include a figure showing the monitoring locations. Monitoring results should include information about the locations where the monitoring occurred. The requested information would allow the NRC staff to evaluate the applicability of measurements to the proposed CISF location.

ER Section 3.11.1.3 (Historical Exposure to Radioactive Materials at WCS) provides a table of monitoring results but should also include a map figure showing the monitoring locations.

Monitoring results should include information about the locations where the monitoring occurred.

The requested information would allow the NRC staff to evaluate the applicability of measurements to the proposed CISF location. ER Section 3.12 (Waste Management) describes the wastes expected to be generated by the proposed action, including liquid (nonradioactive wastewater; sanitary) and solid waste (low-level radioactive waste, nonhazardous solid waste, hazardous waste). These descriptions do not provide information by lifecycle stage (i.e., construction, operations, decommissioning) and the expected volume of each waste that would be generated is not quantified.

Volume estimates should be provided for any solid wastes that could be generated in larger than negligible quantities, for example:

• Annual and cumulative volumes of nonhazardous solid waste that would be generated from the fabrication of 3,200 storage systems over 20 years (ER Section 3.12.1.3)

• Annual and cumulative volume of nonhazardous solid waste that would be generated during decommissioning The requested information will allow the NRC staff to evaluate the magnitude of potential waste management impacts for each proposed facility lifecycle stage. This includes impacts of waste generation on available capacity and operational life of disposal facilities.ER Sections 3.12.1.3 (Solid Wastes) and 3.12.1.3.1 (Solid Low-Level Radioactive Waste) describe that nonhazardous solid waste and Low-Level Radioactive Waste (LLRW) would be disposed at a municipal landfill and the adjacent WCS LLRW facility, respectively, but provides no description of characteristics of these facilities. The characteristics of affected disposal facilities such as available capacity, annual disposed volume, and operational life will allow the NRC staff to evaluate the impacts of proposed waste generation on these facilities. ER Section 3.12.1.3.2 (Non-Radioactive Solid Waste) references NRC Regulatory Guide 1.86 for limits applicable to releasing waste materials for disposal. NRC Regulatory Guide 1.86 has been retired, but similar limits are referenced in Regulatory Guide 8.30. The commitments to follow NRC guidance in the application should reflect the currently applicable guidance. ER Section 1.3.2.4 (Pollution Prevention and Waste Management) states that small quantities of hazardous wastes would be generated and are expected to be much less than 100 kg in a month. This information appears to conflict with the statement in ER Section 3.12.1.3 (Solid Wastes) that indicates mixed and hazardous waste is not expected to be generated at the CISF.

If hazardous waste is generated by the proposed action, ISP should clarify if the hazardous waste would be disposed at the adjacent WCS Resource Conservation and Recovery Act (RCRA) facility. ER Section 2.6 provides a description of present actions within a 48-km [30-mi] radius of the proposed CISF that have a potential for cumulative environmental impacts. However, other past, present, and reasonably foreseeable future actions within and outside an 80-km [50-mi] radius of the proposed CISF have the potential for cumulative environmental impacts. For example, oil and gas development and production activities, livestock grazing, renewable energy projects (e.g., wind and solar farms), and a number of reasonably foreseeable future actions (e.g., the proposed Eddy Lea Energy Alliance/Holtec CISF, the Ochoa Potash Mine Project, and the DK Disposal E & P Landfill and Processing Facility) all have the potential for cumulative environmental impacts. The requested information is needed to support the NRC staff's evaluation of cumulative impacts in the EIS. The analysis of cumulative impacts presented in ER Section 2.6 is limited to brief statements regarding (i) air quality attributable to expansion of the WCS-Controlled Compact Waste Facility and Federal Waste Facility, operations at Permian Basin Materials, and manufacture of concrete at WCS's existing concrete batch plant; (ii) competition for and use of aggregate, crushed rock, and other mineral resources; and (iii) radiological doses attributable to the nearby URENCO USA uranium enrichment facility and WCS's low-level radioactive waste disposal facilities. To support the NRC staff's analysis of the potential cumulative impacts of the proposed action, address potential cumulative impacts relevant to all resource areas, including an evaluation with supporting information of the environmental impacts of nuclear acitivities (e.g., URENCO USA, WCS's low-level radioactive waste facilities, and the proposed Eddy Lea Energy Alliance/Holtec CISF) and non-nuclear activities (e.g., oil and gas exploration and development, potash mining, and livestock grazing) within an 80-km [50-mi] radius of the proposed CISF. The requested information is needed to support the NRC staff's evaluation of cumulative impacts in the EIS.

ER Section 6.3 provides a limited discussion and few details about the pre-operational and operational Radiological Monitoring Program for the proposed CISF. Specifically, the additional information is needed to support the NRC staff's description of the applicant's pre-operational and operational Radiological Monitoring Program and the NRC staff's environmental evaluation of the adequacy of radiological monitoring activities for the proposed CISF to demonstrate compliance with the requirements in 10 CFR 72.104 (Criteria for radionuclide material in effluents and direct radiation from an ISFSI or MRS).

Discounting was not used for any of the estimated costs and benefits of the proposed action and no-action alternative presented in ER Chapter 7. ER Section 7.2.1 explains that discounting was not used because ISFSI operations include substantial labor, technological, and regulatory compliance expenditures, and it was assumed that these expenses remain relatively constant. The justification for not discounting appears to focus only on ISFSI operational costs associated with the eliminated storage costs presented in ER Section 7.2.1. However, this only represents one of the three key cost factors presented in the analysis and the nature of the other two costs is somewhat different than the ISFSI operation cost. The cost for the development of the CISF and relocation of SNF described in ER Section 7.3 includes significant capital and infrastructure costs (see ER Table 7.4-2). The cost-benefit analysis for the repurposed land in ER Section 7.2.2 accounts for the future estimated value of the land at decommissioned nuclear-purposed land once the license is terminated (see ER Table 7.2-6). The net benefit calculation in ER Section 7.4.1 uses the undiscounted values from all three of these key qualitative estimates. Discounting is appropriate when analyzing this proposed action because of the 40year timeframe and the nature of some of the costs. Specifically, discounting the quantitative estimates is needed to support the description of the costs and benefits in the NRC's EIS. Discounting requires specifying the timing (i.e., the specific years) in which activities occur. Key "high dollar" activities include the construction, operation, and decommissioning of the CISF as well as the SNF transportation. The details and assumptions associated with the calculation (e.g., a project schedule by year specifying when activities occur) are needed to support NRC's staff's understanding of how the discounting calculations were performed and for evaluation of cost and benefits of the proposed action and no action alternative.

• • ER Section 7.2.1 describes that SNF transport occurs over a 31 year period. ER Section 4.2.7.1 states that the SNF would be transported over a 20 year period, assuming up to 200 canisters of SNF being transported to the CISF annually. The detailed assumptions for the SNF transport in ER Section 7.2.1 address the initial transportation at a greater level of detail than the potential future expansion (e.g., ER Table 7.2-3). ****ER Table 7.2-2 contains the assumed total cost of storing SNF storage at the various generation sites over the 40 years (i.e., the proposed CISF 40-year license period) for both the full build out (i.e. all eight phases) (with a CISF) and no-action alternative (without a CISF). The difference between these two values is the avoided reimbursement cost. ER Section 7.2.1 provides a general description on how these values were calculated based on the transition of SNF from the current storage locations to the proposed ISP site. However, the ER does not provide sufficient information for the NRC staff to determine exactly how the particular values in Table 7.2-2 (and the associated Figure 7.2-1) were calculated. ER Table 7.2-2 also does not provide the cost estimate information for just phase 1 (i.e., the initial license request). ER Table 7.2-2 assumes an annual cost of storing SNF at each generation site based on this activity occurring at a shutdown reactor. NRC staff requests that this table be supplemented to also include estimates assuming an annual cost of storing SNF based on this activity occurring at an operating reactor (i.e., no additional reactors are shut down). Using an annual storage cost based on a value for an operating reactor could alter the estimated benefit as calculated in ER Table 7.2-2. NRC staff consider this an important component for characterizing the costs and benefits. As requested in this RAI for the current estimate in ER Table 7.2-2, provide the detailed calculation and associated assumptions for the calculation so NRC staff can follow exactly how theses cost estimates were generated. Specifically, this additional information is needed to support NRC staff's description of the total cost for the proposed action and the no-action alternative in the NRC's EIS.

• • ER Section 7.3 explains that the costs for developing the proposed CISF, relocating the SNF to this facility, and operating the ISFSI incorporates the assumptions and cost estimates from a 2009 EPRI report (EPRI, 2009) and adjusts values, where appropriate, for the circumstances of the proposed CISF. However, the cost estimates in ER Section 7.3 appear to include future expansions (i.e. all eight phases) and do not include such estimates for just phase 1 (i.e., the initial license request). It is unclear whether the staffing estimates in Table 7.3-10 represent the total number of employees supporting the ISP operations or only the new employees augmenting the existing WCS staff. Specifically, this additional information is needed to support the NRC staff's description of the total cost for developing the proposed CISF, relocating the SNF to this facility, and operating this facility in the NRC's EIS.

Citations in the ER indicate that relevant information and studies can be found in WCS's "Application for License to Authorize Near Surface Land Disposal of Low-Level Radioactive Waste" (dated 2007). The requested information is needed to confirm information presented in the ER and to support NRC's evaluation of environmental impacts in the EIS.