ML25288A093
| ML25288A093 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/16/2025 |
| From: | Kevin Folk NRC/NMSS/DREFS/EPMB1 |
| To: | Karpa Z Constellation Energy Generation |
| References | |
| EPID L-2025-LRM-0018 | |
| Download: ML25288A093 (1) | |
Text
Zigmund Karpa Director of Environmental Programs Constellation Energy Generation, LLC 200 Energy Way Kennett Square, PA 19348
SUBJECT:
CHRISTOPHER M. CRANE CLEAN ENERGY CENTER - PREAPPLICATION READINESS ASSESSMENT OBSERVATIONS ON DRAFT ENVIRONMENTAL REPORT RELATED TO REQUESTS FOR REAUTHORIZATION OF POWER OPERATIONS (EPID NUMBER: L-2025-LRM-0018) (DOCKET NUMBER; 50-0289)
Dear Zigmund Karpa:
On October 8, 2025, members of the staff of the U.S. Nuclear Regulatory Commission (NRC) completed a preapplication readiness assessment (hereinafter readiness assessment) of the draft environmental report (ER) which Constellation Energy Generation, LLC (CEG) prepared in support of its licensing and regulatory requests for reauthorizing power operations at the Christopher M. Crane Clean Energy Center (CCEC).
The staff performed the readiness assessment of CEGs draft ER to identify any major issues or information gaps between the draft ER and the technical content required to be included in the formal submittal to the NRC. Further, the staff focused on identifying critical information needed for the staff to execute an effective and efficient environmental review associated with CEGs licensing and regulatory requests.
The readiness assessment is not part of the NRCs official acceptance review process.
Therefore, the observations from the readiness assessment do not predetermine whether the environmental portion of a future application submittal will be docketed.
The enclosed document includes the NRC staff observations on the CCEC draft ER. Please consider the observations from the readiness assessment while finalizing your ER.
October 16, 2025
Z. Karpa 2
If you have any questions, please contact me via email at Kevin.Folk@nrc.gov.
Sincerely, 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. 50-0289
Enclosure:
As stated cc: GovDelivery Signed by Folk, Kevin on 10/16/25
Enclosure
SUMMARY
REPORT ON THE PREAPPLICATION READINESS ASSESSMENT OF THE DRAFT ENVIRONMENTAL REPORT CHRISTOPHER M. CRANE CLEAN ENERGY CENTER September 22 - October 8, 2025 BACKGROUND From September 22, 2025, through October 8, 2025, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a focused preapplication readiness assessment (hereinafter readiness assessment) of the draft environmental report (ER) prepared by Constellation Energy Generation, LLC (CEG). The ER supports CEGs licensing and regulatory requests for reauthorizing power operations at the Christopher M. Crane Clean Energy Center (CCEC). The NRCs Office Instruction LIC-116, Preapplication Readiness Assessment (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20104B698) provides guidance for staff in assessing the readiness of a draft application or related materials before being formally submitted for staff review. Specifically, the NRC staff conducted the readiness assessment in accordance with the approach provided to CEG on September 17, 2025 (ML25287A024).
REGULATORY BASES The NRCs regulations at Title 10 of the Code of Federal Regulations Part 51, which implement Section 102(2) of the National Environmental Policy Act of 1969, as amended (NEPA), include requirements for applicants to provide information as may be useful in aiding the NRC staff in complying with NEPA.
The NRC staff also conducted the readiness assessment using the guidance in the NRCs Office Instruction LIC-203, Procedural Guidance for Categorical Exclusions, Environmental Assessments, and Considering Environmental Issues (ML20016A379).
SCOPE OF THE ASSESSMENT AND ACTIVITIES The scope of the readiness assessment was limited to CEGs draft ER. The readiness assessment provided the opportunity for NRC staff to (1) identify any major issues or information gaps necessary to support the staffs environmental review, (2) identify technical or regulatory issues that may complicate the staffs acceptance review, and (3) become familiar with the content of the ER prior to formal submittal to the NRC.
The readiness assessment was conducted virtually using CEGs Online Reference Portal and via video conference (Microsoft Teams).
The NRC staff team members who conducted the readiness assessment included the following:
2 U.S. Nuclear Regulatory Commission (NRC)
Discipline or Title Team Member Environmental Project Manager Kevin Folk, NMSS Environmental Project Manager (Backup)
Ashley Waldron, NMSS Facility Description, Alternatives, Reasonably Foreseeable Effects Bradley Werling, NMSS Land Use and Visual Resources, Socioeconomics Jeff Rikhoff, NMSS Air Quality, Noise, Greenhouse Gas Emissions, Climate Change Nancy Martinez, NMSS Geologic Environment, Groundwater Resources Gerry Stirewalt, NMSS Surface Water Resources Lloyd Desotell, NMSS Terrestrial Resources Mitchell Dehmer, NMSS Aquatic Resources Briana Arlene, NMSS Federally Protected Ecological Resources Briana Arlene, Mitchell Dehmer, NMSS Historic and Cultural Resources Sarah Lopas, NMSS Human Health, Waste Management, Spent Nuclear Fuel, Decommissioning Dr. Donald Palmrose, NMSS Postulated Accidents William Rautzen, NRR NMSS=Office of Nuclear Material Safety and Safeguards; NRR=Office of Nuclear Reactor Regulation.
The NRC staff did not acquire any documents during the readiness assessment.
SUMMARY
OF OBSERVATIONS As summarized below, the NRC staff identified the following issues or information gaps between the draft ER and the technical content expected to be included in the formal submittal to the NRC.
The ER (Section 2.2.1) should provide a description of any new construction projects and/or major refurbishment and/or facility replacement actions that are ongoing or planned to support the resumption of operations.
The ER (Section 2.2.4) summarizes the permits and approvals CCEC plans to request or reinstate. This listing should be updated as necessary.
The ER (Sections 4 and 5) references noise impacts within various contexts, although no analysis of noise impacts from restart activities and the proposed resumption of operations is provided. The ER should include a discussion that identifies these potential impacts including any changes or potential increases in primary noise sources from restart and during operations in relation to noise sensitive receptors, and the basis for why they would or would not be noticeable.
The ER (Sections 3.6, 4.6.1, Tables 3.6-1 and 4.6-1) should provide additional information on air pollutant emissions including quantified direct and indirect emissions including but not limited to criteria pollutant emissions from restart activities, worker vehicles and deliveries vehicles during restart activities, as well as from worker vehicles and deliveries vehicles during operations (including fueling outages).
3 The ER (Section 4.2.2.2) references surface water consumptive water use as compared to prior operations. Any projected change should be quantified compared to prior operations.
The ER (Section 4.2.2.2) indicates an expected decrease in thermal limits on the plants discharge. It should be clarified whether the actual discharge temp is expected to be similar to previous operations.
The ER (Section 4.2.1.2) indicates that groundwater consumptive use may be slightly higher than during prior operations. The ER should quantify the change in groundwater consumptive use as compared to prior operations.
The ER (Section 3.3.1.4.1, etc.) references the site avian and wildlife management procedure. This procedure, including associated best management practices, should be further described.
The ER (Section 4.3.1.1, etc.) references herbicide and pesticide usage. The ER should further describe locations where treatment is conducted onsite to facilitate the staffs environmental review such as for federally protected ecological resources.
The ER (Section 3.3.2.5) references Clean Water Act Section 316(b) best technology available (BTA) concerning impingement mortality and entrainment for CCEC operations, but it is unclear whether the Pennsylvania Department of Environmental Protection has provided its BTA determination. The ER should clarify the status of the determination.
The ER (Section 4) should evaluate potential impacts on surface water, terrestrial, and aquatic ecological resources that could result from increased water withdrawal (water use conflicts) associated with restart operations, as compared to previous NRC analyses for federally protected ecological resources. The ER should consider whether the proposed action could result in changes to flow regimes, habitat availability, or water quality that may affect sensitive species or habitats.
The ER (Section 4.3.3.2) indicates that CCEC would follow procedures and processes for any required consultation and for compliance with regulatory requirements regarding federally listed species. The ER should explain what the referenced procedures and controls are, how CCEC personnel would assess site activities for potential impacts on federally listed species, and take action, if necessary, to notify appropriate agencies and address Endangered Species Act (ESA) requirements.
The ER (Section 4.3.3) discussion of environmental impacts for special status species and habitats does not contain sufficient information for the NRC staff to complete the U.S. Fish and Wildlife Service (FWS) northern long-eared bat and tricolored bat range-wide determination key (Dkey). There is additionally the Northeast Dkey, which evaluates the Indiana bat, green floater, and northeastern bulrush. The questions associated with these species should be reviewed with sufficient information included in the ER for the staff to complete the Dkey for the proposed agency action. The Dkey questions can be viewed in the FWS's December 5, 2025, DKey concurrence for Clinton Power Station, Unit 1, license renewal (ML24341A081, p. 5-10).
The ER (Section 4.3.3.2) does not consider the effects of water withdrawals or flow regime changes on the green floater. The ER should analyze the effects of water withdrawals on this species, including the effects of impingement of host fish species, such as mottled sculpin, rock bass, central stoneroller, blacknose dace, and margined madtom, that the green floater utilizes for upstream dispersal.
The ER (Section 4.3.3.2) discussion of environmental impacts for special status species and habitats should further evaluate whether thermal effluent discharges will expose green floater individuals that may be in the action area to temperatures above the temperature ranges required for basic life history functions. This information can be
4 drawn from the FWS's 2021 Species Status Assessment:
https://iris.fws.gov/APPS/ServCat/DownloadFile/233888.
The ER (Sections 3.3, 4.3) is unclear as to whether CCEC contacted FWS for input on the potential effects of the restart on federally listed species. The ER should include information on any communications with FWS concerning the proposed action, with consideration given to providing copies of relevant correspondence in the ER.
The ER (Sections 3.3.1.3.1) indicates that bat monitoring was conducted on the CCEC site prior to 2019. The ER should summarize the results of the studies.
The ER (Figure 3.3-1) shows the ESA Action Area. If indirect disturbances such as noise are anticipated to impact listed species outside of the project area, consideration should be given to expanding the action area accordingly and reflecting this change in the ER.
The ER (Sections 3.5, 4.5, Tables 3.5-1 and 3.5-2) describes plans to upgrade or replace equipment and facilities to support and maintain power operations; improvements will be limited to previously developed/disturbed areas. It is stated that impacts to cultural resources will be "mitigated." The ER should clarify whether any impacts would be mitigated or avoided including whether impacts to eligible sites (TMI-2 and 36DA0100) will be avoided.
The ER (Section 3.7.1.3) does not specify whether CCEC electrical safety procedures adhere to the National Electrical Safety Code. This should be clarified in the ER.
The ER (Section 4.7.2.3) discussion of postulated accidents does not provide current internal/external event model of record/core damage frequency (CDF) values. The ER should provide updated internal/external event model of record/CDF values including a confirmatory statement that the generic findings for severe accidents and severe accident mitigation alternatives will remain applicable following resumption of power operations.
The ER (Section 4.6.2) in Table 4.6-3 provides greenhouse gas emissions from CCEC but does not provide emissions from worker vehicles. This information should be provided in the ER.
The ER (Section 4.6.2) states that intake temperatures were reviewed to ascertain any temperature trends, but the period of record is not given. The ER should clarify the period of record.
The ER (Section 4.6.2) states that for CCEC, two environmental resource areas may experience incremental impacts of climate change. However, the ER does not discuss what the impacts would be. The ER should include an evaluation of the climate change impacts to the resources.
EXIT DISCUSSION The NRC staff held a readiness assessment feedback session with CEG staff on October 8, 2025. At the meeting, the NRC staff summarized the scope and limitations of the readiness assessment and discussed its observations and recommendations with CEG as summarized above.
Ltr ML25288A093 OFFICE NMSS/REFS
/ERLRB NMSS/REFS
/EPMB2 NMSS/REFS/ERNRB NMSS/REFS
/ERLRB NAME KFolk AWalker-Smith DBarnhurst KFolk DATE Oct 15, 2025 Oct 16, 2025 Oct 16, 2025 Oct 16, 2025