ML22115A206
| ML22115A206 | |
| Person / Time | |
|---|---|
| Site: | Hermes File:Kairos Power icon.png |
| Issue date: | 04/22/2022 |
| From: | Kairos Power |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML2211A204 | List: |
| References | |
| KP-NRC-2204-005 | |
| Download: ML22115A206 (13) | |
Text
Enclosure 1 Kairos Power Response to NRC Requests for Confirmation of Information for the Review of the Hermes Environmental Report (Non-Proprietary)
© 2022 Kairos Power LLC 1 of 12 Kairos Power Hermes Test Reactor Construction Permit Application Environmental Review Requests for Confirmatory Information Responses REQUEST FOR CONFIRMATION OF INFORMATION On February 2, 2022, the NRC issued its plan for conducting an environmental audit (ML22056A064) related to the Kairos Power Hermes construction permit application. As part of the audit, the staff reviewed documents on the Kairos Power electronic information portal (ML20014E642) that were provided in response to the staff Audit Items outlined in Attachment 1 of the audit plan. Additionally, the staff held discussions with Kairos Power related to these Audit Items.
Some of the information reviewed is not on the docket or accessible in the public domain; therefore, the staff requested that Kairos Power submit confirmation that the information listed below is correct or provide the associated correct information.
In an email dated March 31, 2022, the NRC staff transmitted 22 requests for confirmation of information (RCIs) gathered during the environmental audit noted above. The NRC RCIs and Kairos Powers confirmation of each RCI are provided as follows.
© 2022 Kairos Power LLC 2 of 12 Land Use RCI-01 Based on the staffs review of ER Section 3.1.1 and 4.1.1, and audit activities related to Audit Item LU-01, please confirm that the City of Oak Ridge has indicated in writing that the proposed Hermes reactor, which will be a non-power generation facility, falls within the range of activities allowed by the city zoning ordinance for the IND-2 zoning for the site.
Kairos Power Response:
This information has been confirmed to be correct as stated.
RCI-02 Based on the staffs review of ER Section 3.1.1 and 4.1.1, and audit activities related to Audit Item LU-03, please confirm:
a) The tallest structure height for the proposed Hermes facilities will be less than 200 feet in height and not meet the definition of a flight obstruction as established in 14 CFR 77.17 (a).
b) Kairos will notify the Federal Aviation Administration (FAA) in accordance with 14 CFR 77.9 prior to building any structures on the proposed Hermes site with a height that would exceed the imaginary surface described in 14 CFR 77.9 (b).
Kairos Power Response:
This information has been confirmed to be correct as stated.
© 2022 Kairos Power LLC 3 of 12 Hydrogeology and Water Resources RCI-03 Based on the staffs review of ER Section 4.3 relating to site excavation and grading and audit activities related to Audit Item HYD-01, please confirm:
a) The DOE has removed the previous excavation limit of 10 feet and disposal of any potentially contaminated soils would be segregated and stockpiled with disposal coordinated with DOE.
b) Site drainage and topography will be minimally impacted by the onsite reuse of fill excavated to accommodate the foundations of the proposed facility.
Kairos Power Response:
This information has been confirmed to be correct as stated.
RCI-04 Based on the staff review of ER Section 3.4 relating to water usage and audit activities related to Audit Item HYD-10, please confirm:
a) The fire suppression system and the fire protection system are the same system as referred to in the ER.
b) The system will require approximately 1,440 cubic meters of stored fire water and the spent fire water would be replaced within a required 8-hour period. In the unlikely event of a required full refill, this refill rate is equivalent to approximately 1.15 million gallons per day for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Kairos Power Response:
This information has been confirmed to be correct as stated.
RCI-05 Based on the staffs review of ER Sections 3.4, 4.3 and 4.5 and audit activities related to Audit Item HYD-11, please confirm:
a) Based on site conceptual modeling and field test results, an estimated upper bound construction dewatering rate is approximately 50 gallons per minute over an estimated foundation construction period of approximately 30 days, given an estimated approximate excavation extent of 140 feet by 250 feet benched down to a base measuring approximately 50 by 180 feet.
b) Construction and any yet to be determined post-construction dewatering solutions will be compliant with DOE, EPA and, TDEC requirements consistent with any necessary permits or authorizations.
Kairos Power Response:
This information has been confirmed to be correct as stated.
© 2022 Kairos Power LLC 4 of 12 RCI-06 Based on the staffs review of ER Section 4.4, and audit activities related to Audit Item HYD-12, please confirm the intention of Kairos Power to follow any groundwater monitoring obligations imposed by the DOE for the site.
Kairos Power Response:
This information has been confirmed to be correct as stated.
© 2022 Kairos Power LLC 5 of 12 Ecological Resources RCI-07 Based on the staffs review of ER Section 4.5, and audit activities related to Audit Item ECO-10, please confirm that Kairos would transport any dewatered groundwater offsite for disposal or treat the water sufficiently for return to the groundwater or surface water in accordance with applicable EPA, DOE, and State of Tennessee requirements.
Kairos Power Response:
This information has been confirmed to be correct as stated.
RCI-08 Based on the staffs review of ER Section 4.5, and audit activities related to Audit Item ECO-11, please confirm that excavation to build the Hermes reactor would involve a bounding groundwater dewatering volume of approximately 2.2 million gallons at the location of the proposed reactor, estimated based on excavation of an area of approximately 140 by 250 feet benched down to a base of approximately 50 by 180 feet at a depth of approximately 30 feet for a period of approximately 30 days.
Kairos Power Response:
This information has been confirmed to be correct as stated.
© 2022 Kairos Power LLC 6 of 12 Historic and Cultural Resources RCI-09 Based on the staffs review of ER Sections 1.4, 3.6, and 4.6, and audit activities related to Audit Item HCUL-5, please confirm that the following statements are correct:
a) The reference to the Native American Graves Protection and Repatriation Act (NAGPRA) in ER Table 1.4-2 of the ER was an error.
b) Since the lands are no longer considered Federal property, neither NAGPRA nor the Archaeological Resources Protection Act apply.
Kairos Power Response:
This information has been confirmed to be correct as stated.
RCI-10 Based on the staffs review of ER Sections 4.6 and audit activities related to Audit Item HCUL-5, please confirm that in addition to the description in ER Section 4.6.1, related to development of an Archaeological Monitoring and Discovery Plan, Kairos will also notify the Tennessee State Historic Preservation Officer should human remains, or archaeological material be discovered during construction and operational activities.
Kairos Power Response:
This information has been confirmed to be correct as stated.
RCI-11 Based on the staffs review of ER Sections 4.6 and 4.6.1, and audit activities related to Audit Item HCUL-6, please confirm the following:
a) Kairos will develop the Archaeological Monitoring and Discovery plan and implement the plan prior to commencing construction activities.
b) Kairos will incorporate into the plan existing applicable DOE-OREM procedural guidance Kairos Power Response:
This information has been confirmed to be correct as stated.
© 2022 Kairos Power LLC 7 of 12 RCI-12 Based on the staffs review of ER Section 4.8.2.4, and audit activities related to Audit Item HHR-1, please confirm that Kairos applied the annual radiological gaseous effluent release quantities from the Clinch River Early Site Permit Environmental Report, Revision 2, Table 3.5-4 along with the estimated 62,500 Curies per year of tritium from the heat rejection stack (see the revised ER page 4-55 in the February 18, 2022 Kairos letter) as GASPAR input parameters for estimating the site boundary and the maximally expose individual doses provided in ER Tables 4.8-3 and 4.8-22.
Kairos Power Response:
This information has been confirmed to be correct as stated.
© 2022 Kairos Power LLC 8 of 12 Fuel Cycle and Radioactive Waste Management RCI-13 During audit activities for Audit Item FCRW-6, related to the staffs review of ER Sections 2.6.1.2.3 and 4.9, Kairos stated that it has no plans to recover any captured tritium as a commercial commodity. To bound potential radiological waste impacts, Kairos assumes that both concentrated and dilute tritium materials will be disposed of as low-level radioactive waste. Additionally, by addressing tritium-bearing material as a Class B LLRW disposal stream to the Waste Control Specialist LLRW disposal site for concentrated tritium waste, and as a Class A disposal stream to the EnergySolutions disposal site for dilute tritium wastes, Kairos would bound the expected radiological waste impacts for the purposes of assessing environmental impacts for the construction permit. Please confirm that Kairos has no plans to recover any of the captured tritium for commercial purposes and Waste Control Specialist can accept this form of Class B LLRW.
Kairos Power Response:
This information has been confirmed to be correct as stated.
RCI-14 Based on the staffs review of ER Sections 2.6.1.1 and 4.9, and audit activities related to Audit Item FCRW-7, please confirm the following:
a) The potential of a Class C LLRW classification for a Flibe waste stream to be disposed of during decommissioning would be because of the concentration levels for radionuclides other than tritium with their expected radionuclide concentration in the Flibe, being controlled by the technical specifications provided in PSAR Table 14.1-1.
b) The resulting gamma activity is low enough that this should not result in significant radiation decomposition of the Flibe during long-term storage of this material.
Kairos Power Response:
This information has been confirmed to be correct as stated.
© 2022 Kairos Power LLC 9 of 12 RCI-15 During the audit activities for Audit Item TR-1, related to the staffs review of Sections 4.10.2.2, 4.10.2.5, and 4.10.3.1, Kairos stated that their Hermes TRISO pebbles would have an equilibrium discharge burnup of about 6% FIMA (fissions per initial metal atom) as noted in PSAR Table 4.5-2, which would translate to approximately 57 GWd/MTU. Additionally, Kairos informed the staff they are considering the NAC-LWT package for spent TRISO shipments where two of the spent TRISO containers used within the Hermes facility could be placed into the NAC-LWT package. Please confirm that approximately 57 GWd/MTU is the burnup level for spent TRISO and the potential use of NAC-LWT truck shipment package holding two spent TRISO containers for any spent TRISO shipments.
Kairos Power Response:
This information has been confirmed to be correct as stated.
RCI-16 During the audit activities for Audit Item TR-3, related to the staffs review of Sections 4.10.2.3, 4.10.2.5, and 4.10.3.2, Kairos stated they applied the following assumptions concerning the LLRW shipments: 1) the total number of shipment were split evenly for the 46 annual shipments of LLRW described in PNNL-29365 to account for Class A LLRW being shipped to the EnergySolutions LLRW disposal site at Clive, UT, and Class B and C LLRW being shipped to the Waste Control Specialist (WCS)
LLRW disposal site near Andrews, TX; and 2) this split in disposal sites would not affect the overall results strictly based on distance because the shipping distances from the Kairos Hermes site to the two LLRW disposal sites are not drastically different (1,860 miles to the site in Utah and 1,200 miles to the WCS site in Texas).
Please confirm the validity of these two assumptions for generating the impacts presented in ER Table 4.10-2 between the two LLRW disposal sites. The staff would also like confirmation that the volume of Flibe to be disposed of during decommissioning as Class B and/or Class C LLRW to be approximately 16 to 20 cubic meters.
Kairos Power Response:
This information has been confirmed to be correct as stated.
© 2022 Kairos Power LLC 10 of 12 Accidents RCI-17 Based on the staffs review of ER Section 4.11.3, and audit activities related to Audit Item ACC-1, please confirm that the dominant contributors to the maximum hypothetical accident whole body and thyroid doses, for both at the exclusion area boundary and in the low population zone, provided in ER Table 4.11-1 are from gaseous radionuclides.
Kairos Power Response:
This information has been confirmed to be correct as stated.
Cumulative Impacts RCI-18 Based on audit activities related to Audit Item CMLT-1, please confirm that the land needed for the Atlas fuel fabrication facility is estimated to be no more than 30 acres, and that the water demands for Atlas are not expected to exceed 15,000 gallons per day.
Kairos Power Response:
This information has been confirmed to be correct as stated.
© 2022 Kairos Power LLC 11 of 12 Alternatives RCI-19 Based on the staffs review of ER Section 5.4, and audit activities related to Audit Item ALT-01, please confirm that Alternative Site 1.1 is the Clinch River Nuclear Site, Alternative Site 1.2 is the Proposed Site, and Site 1.3 is another site in the City of Oak Ridge.
Kairos Power Response:
This information has been confirmed to be correct as stated.
RCI-20 Based on the staffs review of ER Section 5.4, and audit activities related to Audit Item ALT-02, please confirm that under the Eagle Rock Alternative, the Hermes facilities would be built somewhere within the 592-acre tract of land formerly proposed for the Eagle Rock Enrichment Facility.
Kairos Power Response:
This information has been confirmed to be correct as stated.
RCI-21 Based on the staffs review of ER Section 5.4, and audit activities related to Audit Item ALT-03, please confirm that sanitary wastewater and non-radiological liquid waste generated over the life cycle of the Hermes facilities at the Eagle Rock site would be handled by portable systems or discharged to a municipal wastewater treatment facility, that stormwater would be collected in a lined retention basin where it would ultimately evaporate, and that there would be no direct discharges of wastewater to surface water or groundwater.
Kairos Power Response:
This information has been confirmed to be correct as stated.
© 2022 Kairos Power LLC 12 of 12 RCI-22 Based on the staffs review of ER Section 5.4, and audit activities related to Audit Item ALT-04, please confirm the following:
a) Kairos performed a search of the U.S. Fish & Wildlife Service Information for Planning and Consultation (IPaC) website on February 2, 2022 to obtain information on the possible occurrence of threatened and endangered species and critical habitat protected under the Endangered Species Act.
b) For the purpose of this search, Kairos defined a polygon that encompasses the entire 592-acre former Eagle Rock Enrichment Facility plus any potentially necessary access roads.
Kairos Power Response:
This information has been confirmed to be correct as stated.