ML22097A062
| ML22097A062 | |
| Person / Time | |
|---|---|
| Site: | Hermes |
| Issue date: | 04/06/2022 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 87FR9394 | |
| Download: ML22097A062 (8) | |
Text
From: Bridget Hawn <hawn@kairospower.com>
Sent: Wednesday, April 6, 2022 12:16 PM To: KairosHermes-CPEIS Resource Cc: Dozier, Tami; Beasley, Benjamin; kennedy.william@nrc.gov; Darrell Gardner; Martin Bryan
Subject:
[External_Sender] Kairos Power LLC - Comments on Scoping of Hermes Environmental Impact Statement - Docket ID: NRC-2021-0193 CORRECTED COPY Attachments: KP-NRC-2204-004 Kairos Power Input to Hermes Scoping.pdf Please find attached the corrected copy of Kairos Power LLC - Comments on Scoping of Hermes Environmental Impact Statement - Docket ID: NRC-2021-0193. Please replace the version that was submitted yesterday with this new version.
Thank you, Bridget Hawn Regulatory Affairs Specialist c 704.609.4168 p 510.808.5265 e hawn@kairospower.com 2115 Rexford Rd, Suite 325, Charlotte, NC 28211 www.kairospower.com
Federal Register Notice: 87FR9394 Comment Number: 11 Mail Envelope Properties (SA1P110MB1581BF89828FD37071BAB593D7E79)
Subject:
[External_Sender] Kairos Power LLC - Comments on Scoping of Hermes Environmental Impact Statement - Docket ID: NRC-2021-0193 CORRECTED COPY Sent Date: 4/6/2022 12:16:06 PM Received Date: 4/6/2022 12:16:35 PM From: Bridget Hawn Created By: hawn@kairospower.com Recipients:
"Dozier, Tami" <Tamsen.Dozier@nrc.gov>
Tracking Status: None "Beasley, Benjamin" <Benjamin.Beasley@nrc.gov>
Tracking Status: None "kennedy.william@nrc.gov" <kennedy.william@nrc.gov>
Tracking Status: None "Darrell Gardner" <gardner@kairospower.com>
Tracking Status: None "Martin Bryan" <bryan@kairospower.com>
Tracking Status: None "KairosHermes-CPEIS Resource" <KairosHermes-CPEIS.Resource@nrc.gov>
Tracking Status: None Post Office: SA1P110MB1581.NAMP110.PROD.OUTLOOK.COM Files Size Date & Time MESSAGE 602 4/6/2022 12:16:35 PM image001.png 18807 image002.png 10571 image003.jpg 303990 image006.png 15131 KP-NRC-2204-004 Kairos Power Input to Hermes Scoping.pdf 254442 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
KP-NRC-2204-004 April 5, 2022 Regulations.gov Docket ID: NRC-2021-0193 NRC Licensing Docket No. 50-7513 Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Program Management, Announcements and Editing Staff Submitted via KairosHermes-CPEIS@nrc.gov
Subject:
Kairos Power LLC Comments on Scoping of Hermes Environmental Impact Statement Docket ID: NRC-2021-0193
References:
- 1. Kairos Power to Office of Administration, Generic Environmental Impact Statement for Advanced Nuclear Reactors, Comments to Docket ID NRC-2019-0226, January 24, 2020
- 2. Kairos Power to Office of Administration, Comments on Scoping of an Advanced Nuclear Reactor Generic Environmental Impact Statement, June 30, 2020 Kairos Power provided scoping input to the NRC staff via References 1 and 2 regarding a generic environmental impact statement (GEIS) for advanced nuclear reactors (ANRs) under docket NRC-2019-0226. This letter offers Kairos Power comments on scoping for the environmental impact statement (EIS) specific to the Hermes non-power reactor, the construction permit application for which is currently under review. This input includes encouragement of the NRC staff to make maximum use of the evaluations being conducted in support of the ANR GEIS.
Kairos Powers input is contained in the enclosure to this letter. Kairos Power sincerely appreciates the opportunity to provide input for the staffs consideration. If you have any questions or need any additional information, please contact Darrell Gardner at gardner@kairospower.com or (704) 769-1226, or myself at hastings@kairospower.com or (704) 336-9596.
Sincerely, Peter Hastings, PE Vice President, Regulatory Affairs and Quality
Enclosure:
Kairos Power Input to Hermes EIS Scoping xc (w/enclosure):
William Kennedy, Acting Chief, NRR, Advanced Reactor Licensing Branch Benjamin Beasley, Project Manager, NRR, Advanced Reactor Licensing Branch Tamsen Dozier, Environmental Project Manager, NMSS, Environmental Review Branch Kairos Power LLC www.kairospower.com 707 W Tower Ave, Suite A 5201 Hawking Dr SE, Unit A 2115 Rexford Rd, Suite 325 Alameda, CA 94501 Albuquerque, NM 87106 Charlotte, NC 28211
KP-NRC-2204-004 Enclosure Kairos Power Input to Hermes Environmental Impact Statement Scoping Kairos Power encourages continued innovation and enhanced efficiency in the NRC staffs execution of its responsibilities under the National Environmental Policy Act (NEPA). NEPA is a procedural statute intended to inform the federal action and not a substantive statute that requires a specific decision or outcome such as compliance determination.
The scope of the federal action is fully enveloped in the Environmental Report (ER) submitted by Kairos Power as part of its Construction Permit Application (CPA). In completing its Environmental Impact Statement (EIS), the NRC staffs level of analysis should be commensurate with the severity of anticipated impacts, and the staffs conclusions should take advantage of existing information to the maximum extent practical:
- First, may impacts are already demonstrated to be small under very conservative assumptions in the Preliminary Safety Analysis Report (PSAR) that comprises the balance of the CPA.
- Second, the staff should be able to conclude that, where applicable, impacts to human health and the environment are small by virtue of compliance with applicable federal and state licenses and permits.
Under the best-estimate models appropriate for NEPA, it is not reasonable to analyze conditions that would be likely to occur only during protracted periods of noncompliance that would be detected and corrected through routine monitoring, surveillance, and permit enforcement.
- Third, the staff should, to the maximum practical extent, avail itself of the evaluations conducted in support of the in-process advanced nuclear reactor generic EIS (ANR GEIS). While Kairos Power recognizes the ANR GEIS will not be finalized in time to be used as a direct input to the Hermes review, the supporting evaluations should be used as input to the Hermes EIS wherever applicable.
Finally, the staff also should consider the adverse impacts of the no-action alternative. Hermes is an enabling project that will facilitate broader deployment of clean, resilient energy. Not moving forward with Hermes would make that deployment more difficult and less likely, thereby reducing the likelihood of achievement of climate goals and U.S. energy policy, and impacting Kairos Powers ability to support those goals as a US Department of Energy Advanced Reactor Demonstration Program awardee.