ML25269A047
| ML25269A047 | |
| Person / Time | |
|---|---|
| Site: | 05000614 |
| Issue date: | 09/26/2025 |
| From: | NRC |
| To: | NRC/NMSS/DREFS |
| References | |
| Download: ML25269A047 (18) | |
Text
From:
Joe OHara Sent:
Friday, September 26, 2025 9:08 AM To:
ext_Mark_Feltner; Milton Gorden; Stephanie Yazzie; ext_Jared_Wicker; ProjectLongMott-EnvPUBLICem Resource Cc:
Robert Hoffman; ext_Dave_Goodman; ext_Hayley_McClendon; Daniel Barnhurst
Subject:
Long Mott Generating Station - Request for Confirmatory Information (RCI) - DRAFT Attachments:
Long Mott RCIs - DRAFT.xlsx Good morning, Attached please find draft Request for Confirmatory Information (RCI) for your information and consideration.
These RCIs were discussed with you and your staff on September 8th & 9th during the site audit. The draft RCIs are subject to change.
If you have any questions whatsoever, please contact me.
R/
Joe OHara Environmental Project Manager U.S. Nuclear Regulatory Commission Environmental Review Project Management Branch
Hearing Identifier:
XeDOW_ProjectLongMott_EnvPublic Email Number:
26 Mail Envelope Properties (DM8PR09MB6487BD09736AC8090F4D533BEE1EA)
Subject:
Long Mott Generating Station - Request for Confirmatory Information (RCI) -
DRAFT Sent Date:
9/26/2025 9:07:46 AM Received Date:
9/26/2025 9:07:49 AM From:
Joe OHara Created By:
Joe.OHara@nrc.gov Recipients:
"Robert Hoffman" <Robert.Hoffman@nrc.gov>
Tracking Status: None "ext_Dave_Goodman" <>
Tracking Status: None "ext_Hayley_McClendon" <>
Tracking Status: None "Daniel Barnhurst" <Daniel.Barnhurst@nrc.gov>
Tracking Status: None "ext_Mark_Feltner" <>
Tracking Status: None "Milton Gorden" <mgorden@x-energy.com>
Tracking Status: None "Stephanie Yazzie" <syazzie@x-energy.com>
Tracking Status: None "ext_Jared_Wicker" <>
Tracking Status: None "ProjectLongMott-EnvPUBLICem Resource" <ProjectLongMott-EnvPUBLICem.Resource@nrc.gov>
Tracking Status: None Post Office:
DM8PR09MB6487.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 493 9/26/2025 9:07:49 AM Long Mott RCIs - DRAFT.xlsx 38986 Options Priority:
Normal Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Review Area Accidents ACC-4 Accidents ACC-5 Aquatic Ecology AE-9 Aquatic Ecology AE-11 Aquatic Ecology AE-14
Aquatic Ecology AE-19 Historic and Cultural Resources HCR-3 Historic and Cultural Resources HCR-4 Historic and Cultural Resources HCR-5
Historic and Cultural Resources HCR-6 Human Health - Non-Radiological HHN-1 Hydrology - Surface Water SW-4 Hydrology - Surface Water SW-6 Hydrology - Surface Water SW-8
Terrestrial Ecology TE-2 Terrestrial Ecology TE-3 Terrestrial Ecology TE-5 Terrestrial Ecology TE-6 Terrestrial Ecology TE-7 Terrestrial Ecology TE-10 Terrestrial Ecology TE-13
Transportation TR-1 Visual Resources WM-1
Information Need Relevant Notes from Audit SecPop version 4.3.0 is based on the 2010 census data and 2007 county data. Please confirm that the population land use data used as an input to the accident analysis has been adjusted for potential changes in use over the time period analyzed (e.g.,
adjustment based on 2020 census data and years beyond along with recent county data). The staff observed population data in Section 2.5.1 and Section 5.13.2.2, however it is unclear if the population projections discussed in both sections are the same.
Please provide any additional relevant calculational files or explanations (in the ERR) and an SME to discuss the calculations.
RCI - Confirm that this information is correct and that the demographic information in Chapter 2 links to the analysis in Chapter 5.13 The last row in ER Table 5.13.101, Design Basis Accidents, is for seismic DBA sequences with N/A as initiating event along with the remarks statement As discussed in PSAR Section 2.5, a seismic event is not a credible initiating event for the LMGS site. However, PSAR Section 3.6.12 is entitled Seismic DBA and results of the seismic DBA analysis is an overall dose at the EAB of less than 15 rem (TEDE), satisfying the 25-rem limit (see the end of PSAR Section 3.6.12.4, Dose Consequence, at the top of PSAR page 3.5-72).
Please provide an SME(s) to discuss the apparent difference between ER Table 5.13.1-12 and PSAR Section 3.6.12.
RCI to confirm that the value provided in the PSAR tables are reduced corresponding to information in the ER.
Does the Section 10 permit currently held by the applicant for maintenance dredging apply to dredging done as part of the LMGS? If yes, please provide a copy of the permit. (ESRP 4.3.2)
Please provide additional information on the proposed locations of pile driving activities and any anticipated impacts to aquatic resources. (ESRP 4.3.2)
Please provide information on the original source of water (natural waterbody) that will supply the LMGS, beyond GBRA Calhoun Canal, to where the Canal gets its water from. Please include a figure(s) depicting the flow path, any relevant diversion structures, and the alternate intake location mentioned in ER Section 5.2.1.1.1 that draws from canal water downstream (east). Please clarify the scenario in which the alternate intake will be utilized and the expected frequency of utilization. (ESRP 5.3.1.2, 40 CFR 125.84(b)(2))
The implementing regulations for Section 7(a)(2) of the ESA define action area as all areas affected directly or indirectly by the Federal action and not merely the immediate area involved in the action (50 CFR 402.02).
The action area effectively bounds the analysis of federally listed species and critical habitats because only species and habitats that occur within the action area may be affected by the Federal action. Please provide a description of the ESA action area, including all potential direct and indirect impacts of construction and operation. In the description, address:...
RCI for stating that equipment/construction supplies are not expected to be barged to the site.
Section 2.5.3.1 and 2.5.3.2 mention archaeological and architectural surveys conducted but do not include any information on the purpose of the surveys, who conducted the surveys, who sponsored the surveys, or how they are connected to NRCs licensing action (issuance of a construction permit). Section 2.5.3.2.1 identified consultation that occurred through the Department of Energy for ground-disturbing site characterization and environmental monitoring activities at the LMGS site, but it is unclear how it is connected to NRCs licensing action. To support NRCs NHPA Section 106 review and avoid duplication of efforts, provide the following:...
Confirm that the Phase I archaeological survey results are documented in two separate reports: (1) August 1, 2023 Hunter and Cantrell, Xe-100 Dow Seadrift Site Phase I Intensive Archaeological Survey, Calhoun County, Texas Negative Finding Short Report, and (2) February 19, 2024 Hunter and Cantrell, Phase I Intensive Archaeological Survey for the Proposed Project Long Mott, Calhoun County, Texas - Negative Finding Report (provided in Enclosure 6 of the ER)...
RCI will be submitted to confirm responses provided by applicant to parts 3, 4, and 5 of this info need.
Based on the information provided in the ER, there is no clear indication that Traditional Cultural Places (TCPs) were considered or that efforts were made to identify them as part of the cultural resources review.
Provide documentation and/or summary that demonstrates the level of effort to identify potential TCPs.
Expect RCI to confirm response.
Section 4.1.3.4 of the ER mentions the development of an Inadvertent Discovery Plan with a description to provide three provisions for human burials or human remains. However, it is limited to human remains only and only supports consultation with THC and not the Tribes. Provide the Inadvertent Discovery Plan, or provide additional details about how inadvertent discoveries of cultural resources will be managed, such as: 1) immediate steps to halt work and secure the area; 2) contact details for archaeological personnel who will be involved in the evaluation of any discoveries; 3) protocols for notifying local enforcement, the coroners office, federal agencies, Tribes, and the Texas Historical Commission; and 4) projected timeline outlining how investigations and evaluations will occur after a discovery to minimize project delays and ensure effective preservation.
Expect RCI to confirm response there is no IDP yet, but applicant does plan to implement one for construction.
Per Regulatory Guide 4.2, Revision 3, Section 4.4.1, please provide a statement on blasting activities, what those noise levels would attenuate to at the nearest resident, and any mitigation that would be put in place due to blasting activities.
10 CFR 51.45(c). Please provide a knowledgeable person(s) to describe LMGS cooling systems water use and consumptive water use associated with process steam and electricity generation. Specifically, the different sources of consumptive water use for LMGS and their relative magnitudes and whether the frequency of steam generation expected to influence seasonal water demands from the Guadalupe River via the GBRA diversion.
Two RCIs needed (or one combined depending on how Stephen/Lloyd want to write it).
10 CFR 51.45(c). Please provide a knowledgeable person(s) to discuss the existing SDO wastewater discharge system. Are there any anticipated changes to SDO facility effluent (temperature, volume, solute/constituent loading) due to the shift from the current power plant to the LMGS? If so, are the changes substantial enough to require changes to the existing SDO TPDES permit? If there is an increase to the volume of discharge, are any structural modifications to the existing outfall required to accommodate the increased outfall discharge?
10 CFR 51.45(c). Please provide a knowledgeable person(s) to discuss LMGS plant water use in relation to other surface water uses in the GBRA Calhoun Canal.
Per Regulatory Guide 4.2, Revision 3, Section 4.3.1, provide 1) confirmation of the jurisdictional status of wetlands from USACE once received; 2) a breakout of wetland impacts by impact type, e.g., fill, vegetation conversion; and 3) copies of the jurisdictional determination package submitted to the USACE including relevant data sheets.
RCI to cite info need response Per Regulatory Guide 4.2, Revision 3, Section 4.3.1, provide 1) the height of building equipment that will be 50 feet or more; and 2) the height of the proposed MET tower.
RCI to confirm the equipment that would be used, including cranes Per Regulatory Guide 4.2, Revision 3, Section 4.3.1 and 5.3.1, provide more information on planned vegetation maintenance under onsite transmission line and switchyard. Please include the Best Management Practices for transmission line maintenance around aquatic and wetland habitats mentioned in Section 5.6.2 of the ER.
RCI to cite both parts of this question Per Regulatory Guide 4.2, Revision 3, Section 5.3.1, provide information on measures to prevent avian injury from transmission lines and meteorological tower guy wires.
RCI to summarize this info need response Per Regulatory Guide 4.2, Revision 3, Section 2.3.1 and 5.3.1, provide additional information on potential habitat on the site for the monarch butterfly and the construction and operation impacts.
RCI to summarize this info need response Please provide details regarding any tree clearing activities on site. Include the number or acreage of trees (alive or dead) that will be removed and specify where on site the clearing will occur. (ESRP 4.1.1)
Per section 7(a)(2) of the Endangered Species Act, the NRC is required to examine all potential direct and indirect impacts of the Federal action on federally listed species. To fulfill this requirement, please complete the USFWS Northern Long-Eared Bat and Tricolored Bat Range-Wide Determination Key (https://ipac.ecosphere.fws.gov/) and provide a copy of the answers.
RCI for culverts
Please provide the input and output files used for the transportation routing and risk analysis. Please include TRAGIS (or WebTRAGIS) and RADTRAN input and output files and provide an SME to discuss the analysis.
Regulatory Guide 4.2 Revision 3, Section 6.1.6 states the following should be described in the environmental report:
SECOND BULLET - RCI - would the form of the fuel kernels be similar to the Fort St.
Vrain?
RCI - DRAFT Please confirm: the demographic information stated in Chapter 2 of the ER was used for the analysis in Section 5.13.
Please confirm: the DBA analysis in PSAR Chapter 3 has been reduced in Table 5.13.1-12 of the ER by a scaling factor of 0.38, as defined in ER Section 5.7.1.2.
Please confirm: LME does not plan to conduct dredging within any waterways for the construction or operation of LMGS. LME does not anticipate requiring a Section 10 permit.
Please confirm: Current designs do not include any pile driving activities within or adjacent to waterways. All pile driving activities will occur upland within the terrestrial portion of the action area.
Please confirm: Freshwater from the Guadalupe River is diverted near Tivoli east into the GBRA Diversion Canal and flows into Goff Bayou. Just above Goff Bayou Salt Barrier two 96 pipelines convey water underneath the Victoria Barge Canal to the GBRA/Dow pump station (owned by GBRA and operated by Dow SDO at GBRA direction). The pump station is equipped with seven submersible pumps of varying capacity and conveys water into the Calhoun Canal network. The canal runs south along HWY 185 and then turns towards Port Lavaca and runs along the southside of the SDO facility where it is pulled from the canal into the operating basins, currently via the GBRA Relift 1 Pump Station. A new LMGS intake will be constructed along this same segment of the canal nearby and downstream of the existing (ER pg 3.4-
- 5) to serve Basin #5 for LMGS. It is assumed that the new intake structure would be similar to the existing pump station.
Please confirm: Construction materials for LMGS are expected to be transported to the site by existing roads, there are no plans to barge in materials.
Please Confirm that the scope of work provided to NRC in response to HCR-3 is the same scope of work provided to the Texas SHPO that discussed the fieldwork to support the architectural and archaeological surveys (Davis and Andrews 2024; Hunter and Cantrell 2023). Further, confirm that the Texas SHPO was aware that the field surveys were in support for LMEs proposed new reactor.
RCI: Please confirm the following:
- The correspondence provided in ER Appendix 1a documents the only correspondence exchanged between the Texas SHPO and LME in support of the proposed action.
- The first archaeological report written by WSP (Hunter and Cantrell 2023) covering 617 acres was conducted to support DOE-OCEDs NEPA for subsurface investigations (well installations). The second archaeological report written by WSP (Hunter and Cantrell 2024) covered additional acreage (930 acres) that was needed due to project needs that were not accounted for in the 2023 report.
Please confirm that LMEs background research for the cultural resource survey showed that no known Traditional Cultural Properties (TCPs) were recorded in the Area of Potential Effect or within the 1 km buffer surrounding the APE. Further, confirm that during the cultural surveys, no cultural material, archaeological sites, or potential TCPs were identified.
Please confirm that LME does not have an Inadvertent Discovery Plan (IDP) approved for the proposed action but will have one ready for implementation prior to the start of construction. Confirm that LME provided NRC an example IDP that will be used as a basis for LMEs future IDP.
Please confirm that no blasting activities will be conducted during construction of the LMGS.
Please confirm that: (1) LMGS surface water withdrawal rates for steam generation and water treatment, as summarized in ER Table 3-3.1, are not expected to have large fluctuations in annual variability, (2) SDO condensate from produced steam is discharged to TPDES Outfalls 001 and 002 and, (3) the rate of steam delivered to SDO from LMGS will be essentially the same as that delivered by the existing natural gas-fired cogeneration plant.
Please confirm: Long Mott Energy (LME) is engaged with TCEQ regarding a CWA Section 401 Water Quality Certification for the LMGS project. Additionally, LME is aware that the NRC cannot issue a construction permit until: (1) a 401 certification or waiver has been issued by the certifying authority and (2) NRC has completed EPAs neighboring jurisdiction process as described in 40 CFR Part 121 Please confirm that GBRA/Dow water rights presented in ER Table 2.3.1-10 are used to supply surface water to other non SDO surface water users of the GBRA Canal system, including supply for irrigation and municipal end uses.
Please confirm: out of the 23.52 ac of palustrine emergent (PEM) wetlands onsite, approximately 0.9 ac of will be permanently filled and 1 ac will be permanently converted to another vegetation type. Out of the 3.29 ac of palustrine scrub-shrub (PSS) wetlands onsite, 1.8 ac will be permanently converted to another vegetation type and 0 ac will be permanently filled.
Please confirm: The new MET tower will be 199 feet above ground level (AGL). It is not known at this time whether constuction equipment will exceed 50 ft in height since a more detailed list of equipment has not been compiled. It is anticipated that at least one 200 foot crane will be utilized on site during construction.
Please confirm: The vegetation management for the transmission lines and switchyards includes mechanical (i.e., mowing, pruning, weeding) and chemical (i.e.,
herbicide) controls. A majority of the proposed transmission corridor is in developed areas where these controls are currently utilized. LME will consider the recommendations from TPWD for minimizing disturbance to aquatic habitats, including limiting personnel and equipment to those essential for the work, limiting vegetation removal to vegetation impeding construction, utilizing protective mats, and avoiding construction during aquatic organism spawning periods. During operations, herbicides are used for maintenance as needed on transmission and steam lines, parking lots, operating areas, and access roads, as well as any targeted invasive plant management. LME would apply herbicides according to labeled uses.
Please confirm: The design of the power lines are not finalized, so the specific practices outlined in the Reducing Avian Collisions with Power Lines: State of the Art (2012) have not been chosen.
Asclepias viridis, green milkweed, was listed as a common grass and forb in Section 2.4.1.4.5 and uncommon for herbaceous land cover in Table 2.4-7. Please confirm that Asclepias viridis was uncommon in herbaceous communities, including the northeast portion of the LMGS site, and only a small portion of this area will be permanently affected by building activities.
Please confirm: The access/pipeline rights-of-way (ROWs) will result in a total of 5.3 ac of potential tree clearing, of which 3.5 ac would be from scrub/shrub habitat located west of the West Coloma Creek and east of the stormwater ponds near SD-WET-09 and 1.8 ac would be from woody wetlands, within SD-WET-08. The transmission line will result in 0.2 ac of potential tree clearing, all of which would be from shrub/scrub habitat that is located between existing development near SD-STR-
- 01. These numbers assume all temporary and permanent impacts will result in tree removal.
RCI: Please confirm: There is one culvert at the north portion of the site that goes under the railroad tracks that may be used by bats but will not be impacted during construction. There is a number of agricultural field culverts present onsite along West Coloma Creek, but all the observed culverts have debris screens.
Please confirm: The radiological and nonradiological transportation accident and incident free shipping analysis will be submitted as part of the Operating License Application.
Please confirm: The fuel kernels used by the Xe-100 at LME would be comparable to those used by the HGTR at Fort St. Vrain.
Confirm: Yes or No