ML22117A220

Kairos Power LLC, Changes to Hermes Environmental Report Resulting from NRC Environmental Review Audit

ML22117A220
Person / Time
Site:	Hermes
Issue date:	04/27/2022
From:	Kairos Power
To:	Office of Nuclear Reactor Regulation
Shared Package
ML22117A218	List: ML22117A219 ML22117A220
References
KP-NRC-2204-011
Download: ML22117A220 (22)

Text

Enclosure 1 Changes to Hermes Environmental Report Resulting from NRC Environmental Review Audit (Non-Proprietary)

Environmental Report Introduction Table 1.4-2: Consultations Required for Construction and Operation Agency Regulatory Authority Required Consultation Surveys Required Status U.S. Fish and Wildlife Endangered Species Act, 16 United Consultation regarding potential to None Developed biological assessment Service States Code (U.S.C.) 1536, Section 7 adversely affect Federal listed of potential for adverse effects species and designated critical from the project as part of the habitat. Initial informal consultation EA. Conclusions to be used in may continue to formal consultation informal consultation to request if action determined likely to USFWS concurrence with no effect adversely affect listed species or or may affect but not likely to critical habitat adversely affect determinations for each species. Letter requesting concurrence not yet submitted.

Bald and Golden Eagle Protection If nest present, follow National Bald Field survey for the Field survey identified no nests Act, 16 U.S.C. 668-668c Eagle Management Guidelines and presence of nests in in the project vicinity.

contact local USFWS Field Office for the vicinity of the additional guidance as needed to project.

avoid disturbance.

Tennessee Historical National Historic Preservation Act, Consultation with Tennessee SHPO None Original DOE consultation was Commission Section 106 regarding potential to adversely completed. No consultation impact historic resources; regarding the Proposed Action concurrence with no adverse impact has been conducted.

TDEC - Division of Rare Species Protection and Assessment of potential for project None EA assessed potential Natural Heritage and Conservation Act, TN Code §70 to affect rare species with a state occurrence of and effects on Tennessee Wildlife 101-112 protected status. species with state protected Resources Agency status.

Native American National Environmental Policy Act Consultation regarding protection of None No consultation regarding the Nations: traditional Native American Proposed Action has been National Historic Preservation Act religious and cultural resources conducted.

Native American Graves Protection and Repatriation Act Kairos Power Hermes Reactor 1-8 Revision 0

Environmental Report Description of the Affected Environment ambient noise conditions on the site. The 15-minute interval existing noise levels in terms of Leq were used to calculate the range of Leq(1) and Ldn as summarized in Table 3.2-10. The measured noise levels represent an ambient noise environment common to a quiet rural area surrounding the site. The R1 location was measured at having higher ambient noise levels as compared to R2; this is attributed to its closer proximity to the industrial activities at ETTP, as well as a public accessible road.

The nearest noise receptors within a 5-mile radius of the site include two parks (BORCE) [adjacent] and the Oak Ridge Country Club [4.9 miles northeast]), one rehabilitation facility (Michael Dunn Center [4.6 miles southwest]), and several churches. The nearest resident is approximately 0.7 mile north of the proposed facility, but Reactor Building. the residential area The resident is separated from the site by forests.

There is also a railroad station/yard immediately to the west of the site and the proposed Oak Ridge airport would be approximately 1.1 mile southeast of the site. These would be contributors to noise in the area. The Preserve Marina approximately 2 miles southwest on the Clinch River near Brashear Island. Other industries or businesses within 5 miles of the site include the ORNL Carbon Fiber Technology Center (2.25 miles northeast of the site), the proposed Clinch River Nuclear (CRN) site (3.53 miles south of the site), ORNL (4.87 mile east of the site).

3.2.7 References

1. National Climatic Data Center, 1999-2020 Annual Local Climatological Data (LCD) for Oak Ridge, TN, 2021.

2. U.S. Department of Energy, "Oak Ridge Reservation Annual Site Environmental Report (ASER) -

2019 - Appendix B: Climate Overview of the Oak Ridge Area," DOE/CSC-2513, September 2020.

3. National Climatic Data Center, Data Tools: 1981-2010 Normals for Oak Ridge, TN, Website:

https://www.ncdc.noaa.gov/cdo-web/datatools/normals, accessed July 2021.

4. National Climatic Data Center, 1981-2020 Annual Local Climatological Data (LCD) for Knoxville, TN, 2021.

5. Tennessee Department of Environment and Conservation Air Pollution Control Division, "2020 Tennessee Annual Monitoring Network Plan," July 1, 2020.

6. U.S. Environmental Protection Agency, Tennessee Nonattainment/Maintenance Status for Each County by Year for All Criteria Pollutants, Website:

https://www3.epa.gov/airquality/greenbook/anayo_tn.html, accessed April 13, 2021.

7. U.S. Environmental Protection Agency, Prevention of Significant Deterioration Basic Information, Website: https://www.epa.gov/nsr/prevention-significant-deterioration-basic-information, accessed June 8, 2021.

8. National Park Service, National Parks and the Clean Air Act, Website:

https://www.nps.gov/subjects/air/cleanairact.htm, accessed April 13, 2021.

9. U.S. Environmental Protection Agency, "New Source Review Workshop Manual - Prevention of Significant Deterioration and Nonattainment Permitting," October 1990.

10. National Climatic Data Center, Storm Events Database, Retrieved from:

http://www.ncdc.noaa.gov/stormevents, accessed May 6, 2021.

11. Oak Ridge National Laboratory, Oak Ridge Reservation Meteorology - Climate Data, Normals, and Extremes - Annual, Hourly Climate Data - Oak Ridge Reservation (2001-2020). Retrieved from https://metweb.ornl.gov/page5.htm.

Kairos Power Hermes Reactor 3-20 Revision 0

Environmental Report Description of the Affected Environment 3.4.2.3 Facility Water Use As discussed in Section 2.4.1, water used by the facility for cooling, sanitary, fire protection and other purposes would be obtained from municipal water suppliers. The total amount of water required for the site on a daily basis is estimated at 44 49 gpm (0.06 0.07 MGD), while the fire suppression system would infrequently require 3,170 gpm (4.56 MGD), with a makeup requirement of 793 gpm (1.14 MGD). There would be no direct use of surface water through an intake, or groundwater through production wells.

Municipal water is supplied by the City of Oak Ridge and has a capacity of 12 MGD of water (Reference 16).

3.4.3 Water Quality The site is located in a relatively water-rich part of the country that has numerous surface and groundwater resources. The site and the area immediately around the site have been used for nuclear research and production in the past, and some areas exhibit residual water quality impacts from that usage, including groundwater and surface water contamination. TVA manages the 652-mile Tennessee River system for navigation, flood reduction, power production, water quality and quantity, environmental benefits and recreation. The system consists of 49 dams, of which nine are on the Tennessee River (Reference 18).

3.4.3.1 Surface Water Restoration of the ORR is one of the largest environmental cleanup sites in the United States. Cleanup efforts at the ETTP began in the early 2000s under the authority of the Tennessee Department of Environment and Conservations Division of Remediation, the DOE, Oak Ridge Office of Environmental Management, and the contractor UCOR, at a cost of $4.5 billion for the 2,200 acre site (Reference 20).

3.4.3.1.1 Water Quality Historical activities in and around ETTP from the Manhattan project and other activities have impaired surface and groundwater quality. The main pollutants are mercury in soils (both terrestrial and submerged) and surface water, and volatile organic compounds (VOCs) and polychlorinated biphenyls (PCBs) in groundwater.

Impaired Waters and Total Maximum Daily Load Both Poplar Creek and the Clinch River arm of Watts Bar Reservoir are considered impaired based on the EPA 303(d) impaired waters list. Poplar Creek is impaired for high levels of PCBs and mercury, while the Clinch River is listed for PCBs, mercury, and pesticides for the year 2020 (Reference 21). Since 2017, a mercury treatment facility has been operating on the Upper East Fork of Poplar Creek at Outfall 200 to mitigate downstream effects of mercury on Poplar Creek and downstream waterways (Reference 22).

Section 1453 of the 1996 Safe Drinking Water Act required that all states establish Source Water Assessment Programs. In 2000, water quality data in the Upper Tennessee River Basin were reported by the USGS for 1994 to 1998. Concentrations and distributions of pesticides, nutrients, bacteria, and VOCs in surface water and sediment were reported, along with the impact of industry and mining on water quality and the effects of toxic spills and releases. This study was part of the USGS National Water-Quality Assessment Program, which evaluated 51 study areas throughout the United States. The report compared water quality data from the Upper Tennessee River to data from the other study areas and to national water quality benchmarks, such as those for drinking water quality and protection of aquatic organisms. The report showed that surface water in the Upper Tennessee River Basin usually meets existing guidelines for drinking water, recreation, and the protection of aquatic life (Reference 23).

Specific findings from Hampson, et. Al. included (Reference 23):

Kairos Power Hermes Reactor 3-69 Revision 0

Environmental Report Description of the Affected Environment Figure 3.4-2. FEMA Flood Hazard Kairos Power Hermes Reactor 3-78 Revision 0

Environmental Report Description of the Affected Environment Kairos Power Hermes Reactor 3-79 Revision 0

Environmental Report Description of the Affected Environment Figure 3.7-3. Existing 2019 Average Daily Traffic Volumes Kairos Power Hermes Reactor 3-147 Revision 0

Environmental Report Description of the Affected Environment Kairos Power Hermes Reactor 3-148 Revision 0

Environmental Report Chapter 4 - Impacts 4.2 AIR QUALITY AND NOISE 4.2.1 Air Quality 4.2.1.1 Impacts from Construction Construction activities result in localized increases in air emissions. Earthmoving, excavation, clearing, pile driving, erection, batch plant operation, and construction-related traffic generate fugitive dust and fine particulate matter that potentially impact both onsite workers and offsite residents of the community. Vehicles and engine-driven equipment (e.g., generators and compressors) generate combustion product emissions such as carbon monoxide (CO), nitrogen oxides (NOx) and, to a lesser extent, sulfur dioxide (SO2). Painting, coating, and similar operations also generate emissions from the use of volatile organic compounds. People living near or working at or near construction sites may be subject to the physical impacts of construction activities. Activities associated with the use of construction equipment may result in varying amounts of dust, air emissions, noise, and vibration. The magnitude and area of extent of the impacts from these emissions depends in part on atmospheric conditions at the time of the activity. The magnitude of these potential impacts is typically related to the specific construction activities that occur at a given site, the nature and effectiveness of implemented environmental controls, and the proximity of the site to populated areas. Contractors, vendors, and subcontractors are required to adhere to appropriate federal and state occupational health and safety regulations. These regulations set limits to protect workers from adverse conditions, including air emissions.

On-site equipment usage and traffic due to construction activities can also result in local increases in emissions. Section 4.7 and Section 4.9 provide information regarding the type and volume of traffic generated by the facility during construction. Guidance from the Final Interim Staff Guidance (ISG)

Augmenting NUREG-1537 suggests that emissions from on-site and offsite vehicle use (including fugitive dust) should be estimated. Air emissions estimates for the construction phase (assumed to be two years in duration) of the Hermes reactor are provided in Table 4.2-4. Based upon a larger project of a similar nature, the Versatile Test Reactor (Reference 1), the emissions of individual criteria pollutants such as SO2, NOx, CO, particulate matter with an aerodynamic diameter of 10 microns or less (PM10), and particulate matter with an aerodynamic diameter of 2.5 microns or less (PM2.5) during the 2-year construction period for the facility would not exceed 100 tons per year (tpy). In addition, hazardous air pollutants (HAPs) are expected to be below 10 tpy for any single pollutant, and below 25 tpy for all HAPs combined. The low level of expected emissions during construction (and lower for the operational and decommissioning phases) allows the project to apply for a minor (non-Title V) permit from the Tennessee Department of Environment and Conservation (TDEC), and no dispersion modeling is required by TDEC for a minor source permit application.

Construction equipment usage and generated traffic volumes are expected to be relatively minor compared to other regional traffic generated emissions, so potential air quality impacts from construction are limited. Implementation of controls and limits at the source of emissions on the construction site would result in reduction of impacts offsite. For example, the dust control program reduces dust due to construction activities to minimize dust reaching site boundaries. Transportation and other offsite activities result in emissions from vehicle usage. Offsite transportation activities generally occur on improved surfaces, limiting fugitive dust emissions.

Specific mitigation measures to control fugitive dust may include any or all of the following:

• Stabilizing construction roads and spoil piles Kairos Power Hermes Reactor 4-13 Revision 0

Environmental Report Chapter 4 - Impacts

• Limiting speeds on unpaved construction roads

• Periodically watering unpaved construction roads

• Performing housekeeping (e.g., remove dirt spilled onto paved roads)

• Covering haul trucks when loaded or unloaded

• Minimizing material handling (e.g., drop heights, double-handling)

• Phased grading to minimizes the area of disturbed soils

• Re-vegetating road medians and slopes While emissions from construction activities and equipment are unavoidable, implementation of mitigation measures minimize impacts to local ambient air quality and the nuisance impacts to the public in proximity to the project. The mitigation may include any or all of the following:

• Implementing controls to minimize daily emissions such as reducing engine idle time, using cleaner fuels (e.g., ultra-low sulfur diesel fuel or biodiesel), using pollution control equipment on construction equipment (e.g., diesel oxidation catalysts and particulate matter filters), and curtailing or controlling the time-of-day construction activities are performed.

• Requiring proper maintenance of construction vehicles to maximize efficiency and minimize emissions.

In summary, air emission impacts from construction would be controlled at the source where practicable; maintained within established regulatory limits designed to minimize impacts; and generally localized on the site. Therefore, the impacts to air quality would be SMALL.

4.2.1.2 Impacts from Operation PSAR Chapters 5, 9, and 11 provide information regarding the cooling and heating dissipation systems and the waste systems for the facility. The design of the facility includes a cooling system that does not require the use of external mechanical or natural draft cooling towers.

The site is located in Roane County, Tennessee. The Clean Air Act and its amendments establish National Ambient Air Quality Standards (NAAQS) for ambient pollutant concentrations that are considered harmful to public health and the environment. Similarly, Tennessee has established the Tennessee Ambient Air Quality Standards. Primary standards set limits to protect public health and secondary standards set limits to protect public welfare such as decreased visibility, and damage to animals, crops, vegetation, and buildings. The principal (criteria) pollutants for which NAAQS have been set are CO, NO2, lead, SO2, PM10, PM2.5, and ozone (O3). One or more averaging times are associated with each pollutant for which the standard must be attained.

Areas having air quality as good as, or better than, the NAAQS are designated as attainment areas. Areas having air quality that is worse than the NAAQS are designated as nonattainment areas. Roane County, TN is designated as attainment for all pollutants and averaging periods except for PM2.5. Census Block Group 47-145-0307-2 is the portion of Roane County that is designated as maintenance for the 1997 and 2006 PM2.5 standards. An area is redesignated from nonattainment to maintenance when mitigation measures are initiated by the state to improve air quality and an area meets the ambient air quality standards and other redesignation requirements under the Clean Air Act. This maintenance area is located approximately 5 miles southwest of the site. However, the area in the immediate vicinity of the site in Roane County is in attainment for PM2.5.

Operation of the Hermes reactor will emit non-radioactive gaseous and particulate emissions to the atmosphere. For the purpose of evaluating the operation of the Hermes facility, it is Kairos Power Hermes Reactor 4-14 Revision 0

Environmental Report Chapter 4 - Impacts assumed that emissions will not be greater than those estimated by the Tennessee Valley Authority for two or more small modular reactors (SMRs) operating at the vicinity Clinch River Nuclear Site (CRNS). As described in the CRNS Environmental Report (Reference 11), the primary sources of emissions for the CRNS SMRs are from auxiliary systems and are expected to be auxiliary boilers, standby diesel generators, and emergency standby gas turbine generators. These effluents commonly include particulates, sulfur oxides, carbon monoxide, hydrocarbons, and nitrogen oxides.

The Hermes reactor facility may employ standby diesel generators, gas turbine generators, and engine-driven emergency equipment, but is not expected to have auxiliary boilers. The diesel generators, gas turbines, and engine-driven emergency equipment would be used as needed, intermittently and for brief duration.

Given the similarity yet smaller scale of the Hermes reactor facility to the TVA CRNS, the operational emissions established for the CRNS Environmental Report (Reference 11) are considered to be applicable for the Hermes application.

The criteria pollutant operational emissions from the project are estimated to be well below 100 tpy for all criteria pollutants. Also, the HAPs are estimated to be below 10 tpy for any single pollutant and below 25 tpy for all HAPs combined. As a result, the project is subject to non-Title V requirements. No air quality modeling is required for non-Title V permitting.

4.2.1.2.1 Gaseous Effluents Air emissions of nonradiological gaseous criteria pollutants and HAPs would be emitted during the operations phase from: (1) intermittent use of diesel-powered or natural gas powered standby power generation sources such as generators or combustion gas turbines, (2) intermittent use of propane-fired heaters for the intermediate coolant located in the primary heat rejection system (PHRS) during maintenance activities, (3) diesel-powered trucks that deliver material and haul off wastes, and (4) worker commuter vehicles. Radiological air emissions would be produced in the operations phase from the primary heat rejection stack, decay heat removal system vents, Reactor Building ventilation stack, and spent fuel cooling stack.

4.2.1.2.2 Evaluation of Emission Impacts on Air Quality Vehicle and Other Emissions During the operations phase, vehicular air emissions occur from the commuting workforce and from routine deliveries to/from the facility. The volume of traffic generated during operations is considerably lower than that expected during construction. Additionally, the lands on the developed site are either developed surfaces (buildings, paved parking/access road) or have been landscaped. Limitation of routine vehicle usage to paved areas reduces the emissions of fugitive dust. Impacts from vehicular air emissions and fugitive dust are far less than during the construction phase. Therefore, impacts during the operations phase would be SMALL.

Kairos Power Hermes Reactor 4-15 Revision 0

Environmental Report Chapter 4 - Impacts the environmental monitoring program are analyzed to assess the environmental impact of DOE operations on the entire reservation and the surrounding area.

Nonradiological criteria pollutants are monitored by the TDEC Division of Air Pollution Control. The monitors are documented in the TDECs 2021 Tennessee Annual Monitoring Network Plan (Reference 3). Table 4.2-1 lists the closest criteria pollutant state and local air monitoring stations to the site. The monitors are also shown in Figure 4.2-2.

Local meteorological data sources are described in Subsection 3.2.4.2.

Per the Oak Ridge Reservation Annual Site Environmental Reports (available at Home of the Oak Ridge Reservation Annual Site Environmental Report (ASER), Reference 8 ), ORR meteorological monitoring satisfies onsite monitoring requirements for the DOE (Reference 6) and the Environmental Protection Agency (EPA) (Reference 7). The provided data are 100 percent complete, although some substitution of data from collocated instrumentation has taken place to handle missing values for individual sensors.

See Table 2.4-2 4.2-2 for more details on these towers.

4.2.2 Noise 4.2.2.1 Impacts of Construction Construction would have temporary adverse effects on noise and vibration during the likely 2-year duration of the project between 2023 and 2025. Construction activities would cause temporary increases and fluctuations in ambient noise levels around the site depending on the number and type of equipment in use at any given time. Typical maximum noise levels from equipment likely to be used during construction are listed in Table 4.2-3.

As discussed in Section 3.2, the nearest noise receptors around the site include:

• A greenway approximately 1 mile northeast of the site

• A residential area The nearest resident approximately 1.25 1.1 miles north northwest of the site Reactor Building, with a forest located between the site and the residential area resident.

Because the existing ambient noise level during the quietest daytime hours when construction activities would occur was measured as 38 dBA in Leq, the predicted noise impacts from the equipment would be likely not be perceptible (i.e., a 3-dBA or less increase over the ambient level of 38 dBA) in the nearest sensitive receptors as shown in Table 4.2-3. However, when pile driving activities and/or multiple heavy equipment operate simultaneously, a readily perceptible noise increase would likely be perceived by the nearest sensitive receptors. Given the temporary nature of construction activities and the distances from the site, the impact of noise from construction equipment operation on nearby residences, schools, churches, and parks would be SMALL.

Traffic associated with the construction workforce traveling to and from the site also generates noise.

The increase in noise relative to ambient background conditions would be most noticeable during the shift changes in the morning and late afternoon. Given the short duration of such potential traffic noise increase, potential noise impacts to the community are intermittent and limited primarily to shift changes. The impact from noise from construction-related traffic to nearby residences schools, churches, and parks would be SMALL.

4.2.2.2 Impacts of Operation Operation of the facility would involve equipment that would emit noise levels typical of industrial activities. The continuously operated equipment would include heat exchange fans and exhaust fans in Kairos Power Hermes Reactor 4-18 Revision 0

Environmental Report Chapter 4 - Impacts addition to intermittently or infrequently used equipment, such as compressors and standby generators.

However, most equipment would be indoors within enclosures resulting in minimal outdoor noise emissions. These enclosures mainly include:

• Reactor Building

• Auxiliary Systems Building

• Maintenance and Storage Building Outdoor equipment (i.e., heat exchange fans and several exhaust and ventilation stacks), employee vehicle trips, and routine maintenance activities involving trucks would be perceptible in the immediate vicinity of the facility, particularly during nighttime hours when ambient noise levels are low. The nearest resident noise receptor residential area would be the most sensitive to surrounding noise during nighttime operation; However, the nearest resident residential area is approximately 1.1 1.25 miles northwest away from the project site Reactor Building and is separated by the forest, creating a sound buffer. Therefore, operational noise is unlikely to be perceptible to the nearest resident those in the residential area. As a result, the facility operation would not result in significant noise impacts.

Consequently, operational impacts relative to the noise environment would be SMALL.

4.2.2.3 Impacts of Decommissioning Decommissioning is the removal of a nuclear facility from service and reduction of residual radioactivity to a level that permits release of the property for unrestricted use and termination of the license. During the decommissioning phase, activities, equipment usage, and the noise associated with typical decommissioning operations are expected to be similar or less than that of the construction phase.

Therefore, impacts during the decommissioning phase would be SMALL.

4.2.3 References

1. U. S. Department of Energy. Draft Versatile Test Reactor Environmental Impact Statement:

Chapter 4: Environmental Consequences. VTR EIS. DOE/EIS-0542. December 2020.

2. U.S. Department of Energy. Environmental Monitoring Plan for the Oak Ridge Reservation -

Calendar Year 2021. DOE/ORO-2228/R12. December 2020.

3. Tennessee Department of Environment and Conservation - Air Pollution Control Division. 2021 Tennessee Annual Monitoring Network Plan. July 1, 2021.

4. Not Used.

5. Not Used.

6. U.S. Department of Energy. HANDBOOK: Environmental Radiological Effluent Monitoring and Environmental Surveillance. DOE-HDBK-1216-2015.

7. U.S. Environmental Protection Agency. Meteorological Monitoring Guidance for Regulatory Modeling Applications. Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. EPA-454/R-99-005. 2005.

8. U.S. Department of Energy. Oak Ridge Reservation Annual Site Environmental Report (ASER)

(https://doeic.science.energy.gov/ASER/)

9. New York City Environmental Quality Review. Technical Manual (2021) (Table 22-1).

Kairos Power Hermes Reactor 4-19 Revision 0

Environmental Report Chapter 4 - Impacts

10. U.S. Department of Transportation. Federal Highway Administration Highway Construction Noise Handbook. Final Report. August 2006. [Table 7.3 and/or Table 9.1]

11. Clinch River Nuclear Site, Early Site Permit Application, Part 3 Environmental Report, Revision 2. Ascension No. ML19030A478 Chapter 2, Section 02.07.06, pp 2.7.6.3 -

2.7.6.5; March 2019 Kairos Power Hermes Reactor 4-20 Revision 0

Environmental Report Chapter 4 - Impacts Table 4.2-3: Typical Noise in dBA from Construction Equipment Equipment Lmax Noise Leq Noise Leq Noise Leq Noise Level at 50 Level at 50 Level at 1 mile Level at 1.25 feet feet (nearest park) 1.1 mile (nearest residence resident)

Air Compressor, 370 cfm9 80 76 34 36 31 35 Asphalt Paving Machine, 130 HP10 85 82 40 42 37 41 Backhoe Cat 428, 1.3 CY 85 HP10 80 76 34 36 31 35 Compactor Cat 433B, Smooth Drum 85 81 39 41 36 40 roller9 Concrete Pump, 100 yph10 82 75 33 35 30 34 Concrete saw, hand9 85 78 36 38 33 37 Crane Hydraulic 60 ton10 85 77 35 37 32 36 Crane Truck, 85 ton10 85 77 35 37 32 36 Dozer - Cat D8, 305 HP10 85 81 39 41 36 40 Demo Hammer, 7,500#10 85 78 36 38 33 37 Excavator Cat 330, 26'-6" dig 85 81 39 41 36 40 depth10 Farm Tractor10 84 80 38 40 35 39 Finisher - Concrete9 82 75 33 35 30 34 Hydromulcher9 85 78 36 38 33 37 Lift, boom JLG800, 80' articulating)9 85 78 36 38 33 37 Lift, Fork 8000 lb9 80 73 31 33 28 32 Lift, Scissor 24' 9 80 73 31 33 28 32 Wheel Loader, Cat 950 4 CY9 80 76 34 36 31 35 Pile Driver Vibratory Hammer10 95 88 46 48 43 47 Power Tools10 85 78 36 38 33 37 Trencher, < 5' deep9 85 81 39 41 36 40 Truck, Dump 18 CY9 85 81 39 41 36 40 Truck, flatbed 169 85 81 39 41 36 40 Welding Machine 400 amp10 84 82 80 78 38 35 37 Welding torch- oxygen/acetylene9 84 73 80 69 38 29 35 28 Well Drilling, Air Track Drill up to 4" 85 78 36 38 33 37 Diameter9 Source: (References 8, 9 and 10)

Kairos Power Hermes Reactor 4-23 Revision 0

Environmental Report Chapter 4 - Impacts Table 4.2-4: Total Emissions - Construction Related Equipment and Trucks Equipment Horse- Load Emissions Rate (tons)(1)

Type Hours power Factor VOC NOX CO PM2.5 PM10 SO2 CO2 CH4 (4) (2) (3)

Air Compressor 1012 300 0.43 0.00 0.25 0.07 0.01 0.01 0.00 76.31 0.00 Asphalt Paving Machine 110 130 0.59 0.00 0.01 0.00 0.00 0.00 0.00 4.99 0.00 Backhoe and Loader 3804 85 0.21 0.05 0.26 0.27 0.04 0.04 0.00 51.91 0.00 Compactor 13413 20 0.59 0.07 0.67 0.27 0.03 0.03 0.00 102.72 0.01 Concrete Pump 1251 181 0.43 0.02 0.25 0.06 0.01 0.01 0.00 56.89 0.00 Concrete Saw 1738 25 0.59 0.00 0.07 0.01 0.00 0.00 0.00 16.82 0.00 Crane 3876 335 0.43 0.04 0.71 0.17 0.03 0.03 0.00 326.44 0.00 Dozer 2152 303 0.43 0.01 0.18 0.07 0.01 0.01 0.00 165.74 0.00 Hammer 3822 54 0.43 0.04 0.44 0.19 0.03 0.03 0.00 57.59 0.00 Excavator 8030 303 0.59 0.05 0.79 0.32 0.05 0.06 0.00 848.56 0.00 Tractor 2361 70 0.21 0.03 0.16 0.14 0.02 0.02 0.00 26.53 0.00 Lift 12715 64 0.21 0.11 0.77 0.52 0.07 0.07 0.00 130.67 0.00 Trucks 15772 440 0.59 0.07 1.06 0.31 0.06 0.07 0.01 2420.50 0.01 Welder 2638 25 0.68 0.02 0.17 0.09 0.02 0.02 0.00 34.31 0.00 Total 0.51 5.79 2.49 0.38 0.40 0.01 4319.98 0.02 Notes:

1. Emissions factors are estimated using MOVES3.03, Non-road module for Roane County, Tennessee

2. Guidance for horsepower: USACE Construction Equipment Ownership and Operating Expense Schedule Region IV

3. Guidance for Load Factors; USEPA Median Life, Annual Activity, and Load Factor Values for Nonroad Engine Emissions Modeling

4. Estimated number of hours for each equipment type based on Hermes construction estimates Kairos Power Hermes Reactor 4-24 Revision 0

Environmental Report Chapter 4 - Impacts Figure 4.7-1. Likely Routes taken to/from the Site Kairos Power Hermes Reactor 4-53 Revision 0

Environmental Report Chapter 4 - Impacts Kairos Power Hermes Reactor 4-54 Revision 0

Environmental Report Chapter 4 - Impacts During the construction periods for the site and the potential and in-progress facilities above, additional impacts to noise are expected in the immediate area around each site, if construction happens at the same time. Noise levels from construction equipment are expected to attenuate rapidly with distance, and therefore, do not significantly impact nearby sensitive noise receptors (all one mile or farther away).

Additionally, there are few noise receptors in the 1-mile area other than employees at industrial facilities. Noise levels are also impacted by increases in traffic volume during both construction and operation; however, they are not expected to be significantly higher than current traffic levels. External noise emission from the facility and other potential and in-progress facilities in Table 4.13-1 during operation are primarily limited by the walls and other physical barriers of the facilities themselves.

Additionally, the area surrounding the one-mile radius of the site is heavily wooded and hilly, further attenuating noise prior to reaching any receptors. Noise impacts from the operation of the future airport would likely dominate future cumulative noise levels.

Therefore, cumulative impacts to noise in the region are SMALL and the incremental contribution to cumulative impacts from the Proposed Action would also be SMALL.

4.13.3 Geologic Environment The description of the affected environment in Section 3.3 serves as a baseline for the geologic environment cumulative impact assessment. The geographic area of analysis for evaluation of cumulative effects on geologic resources is the same as that used in Section 4.3 and includes the 185 acres within the site boundary and the 5-mile region surrounding the site. As discussed in Section 4.3, construction and operation impacts from the site on the geologic environment are SMALL.

Table 4.13-1 identifies recent past, present, and reasonably foreseeable future actions within the geographic extent of analysis that can be assessed to determine cumulative effects on the geologic environment. Relevant other actions that are considered in this cumulative effects analysis are limited to those within five miles. Of these projects, none the proposed operations at the planned Kairos Power Fuel Fabrication Facility (Atlas) were considered likely to contribute to cumulative impacts to geological resources.

The planned Atlas facility would be located near the Hermes site. Construction, operation, and decommissioning of the proposed Atlas facility would comply with federal, state, and local environmental laws, rules, regulations, and statutes. Current plans for the approximately 20,000 square foot Atlas facility include using municipal water and wastewater systems. No site groundwater or surface water use is anticipated. Due to the proximity of the planned Kairos Power Hermes site, the Atlas site will leverage the Hermes Environmental Report. Many of the same construction best management practices including separation of top-soil, reuse of excavated clean soil, and waste minimization would be anticipated at Hermes and Atlas. Anticipated impacts from Atlas to geologic resources would be SMALL and cumulative impacts to these resources would be minimal to SMALL.

Other potential projects in the vicinity of the site would result in impacts to the same geologic resources as those affected by the facility. However, there are no sensitive geologic resources in the region surrounding the site. Additionally, as noted in Section 3.3, the probability of regional-scale impacts due to geologic factors would be low. Impacts from those projects identified within five miles are expected to be localized and minor. As discussed in Section 4.3.2, impacts to soils from the facility would be SMALL as minimal amounts of grading and excavation would occur. Additionally, fill material would be stockpiled and used on-site. Due to the sizes of the acreages of the proposed and in-progress facilities within five miles, it is likely that these same measures would occur at these other facilities for cost reduction purposes. Therefore, cumulative impacts to geological resources would be SMALL and the incremental contribution to cumulative impacts from the Proposed Action would also be SMALL.

Kairos Power Hermes Reactor 4-122 Revision 0

Environmental Report Chapter 4 - Impacts Table 4.13-1: Past, Present, and Reasonably Foreseeable Projects and Other Actions Considered in the Cumulative Effects Analysis (Page 1 of 2)

Retained for Location Project Name Summary of Project Status Potentially Affected Resource(s) Cumulative Basis (from Reactor building)

Effects Analysis Federal Facilities Land use and visual resources, air quality Proposed Clinch River Nuclear Site Two or more small modular reactors to be Proposed NRC issued ESP-006 on Potential for overlapping 3.5 miles South-southeast and noise, water resources, ecological Y (Reference 7) built by TVA December 19, 2019 construction timeline resources, transportation, socioeconomics Land use and visual resources, air quality, East Tennessee Technology Park Clean up and redevelopment of the former Adjacent across Poplar Creek In progress transportation, socioeconomics, noise, Y On-going industrial developments (Reference 8) Manhattan Project Site water resources, human health Sludge Processing Mock Test Facility Construction of a TRU sludge waste processing Construction underway; expected Water resources, air quality, land use, waste Approximately 5.3 miles east Y Construction underway (Reference 9) facility completion 2022 management Uranium Processing Facility at Y-12 Approximately 8.4 miles Construction began 2018; expected to Water resources, air quality and noise, New building in Y-12 complex Y Construction underway (Reference 10, Reference 11) northeast continue through 2025 waste management, human health, Construction of two mercury Outfall 200 Mercury Treatment Facility at Y-12 Construction began 2017 and scheduled to Water quality, air quality and noise, human treatment facilities in separate areas Approximately 9 miles northeast Y Construction underway (Reference 12, Reference 13, Reference 14) begin operations in mid-2020s health, waste management connected by a pipeline New Y-12 Steam Plant Natural gas power generation for Y-12 Approximately 9 miles northeast Operational since 2010 Air quality Y Operational (Reference 15) operations.

Y-12 Shipping and Receiving (On-site verification) Non-hazardous shipping and receiving facility West and adjacent <1000 feet Operational Transportation Y Operational K-1251 Barge Facility Barge docking facility approximately 1-acre in 2 miles Southeast Operational Transportation Y Operational (Reference 39) size.

Land use and visual Roane Regional Business and Technology Park Business and industrial park with sites for Operational, although future Approximately 5 miles southeast Operational since 2001 resources, water resources, Y (Reference 16) development development timeline unknown air quality, socioeconomics, transportation ORNL DOE Nuclear and High-Tech Research Facility Approximately 5 miles east Operational since 1943 Water resources, air quality Y Operational (Reference 17)

Accelerator-based neutron pulse for research ORNL - Spallation Neutron Source and development (R&D). Includes upgrades Air quality, water resources, human health, Approximately 5.8 miles east Operational since 2006 Y Operational (Reference 18) and second target station construction waste management completion 2025.

ORNL - High Flux Isotope Reactor Critical reaction providing a stable beam of Operational since 1965. Decommission Air quality, water resources, human health, Approximately 5.75 miles east Y Operational (Reference 19) neutrons for R&D. anticipated after 2060. waste management Manhattan Project impoundment on White White Oak Dam Oak Creek with 25 ac settling pond. Formed to Approximately 5 miles southeast Operational since 1943 Water resources, human health Y Operational (Reference 20) reduce radioactive waste runoff into Clinch River, must be remediated by 2036.

Proposed new landfill for disposal of Approximately 5.3 miles Environmental Management Waste Management Facility Water resources, air quality, radioactive, hazardous, and toxic wastes in northeast on ORR Proposed socioeconomics, human health, waste Y Additional capacity needed Oak Ridge because current landfill (current location is 6.8 miles (Reference 21) management will soon reach max capacity northeast)

Industries and Manufacturing Facilities Land use and visual resources, air quality Fabrication of tri-structural isotropic (TRISO) Interdependent with the facility and noise, geologic resources, water Kairos Power Fuel Fabrication Facility coated uranium oxycarbide (UCO) kernels in a Near or on K-31 Site Potential Y construction and future resources, socioeconomics, transportation, graphite matrix development timeline unknown.

human health, waste management Land use and visual resources, air quality Close proximity and potential Coquí Pharma Duct Island; Approximately 0.75 Planned Medical Isotope Production Facility Proposed and noise, water resources, socioeconomics, Y for overlapping construction timelin (Reference 22) miles south human health e Tellico West Industrial Park Development of industrial site for Tellico 25.4 miles southeast Proposed Air quality, socioeconomics Y Timeframe uncertain (Reference 24) Reservoir Development Agency EnergySolutions, LLC Bear Creek Facility Processing and packaging of radioactive Approximately 2.1 miles Air quality, water resources, human health, Operational Y Operational (Reference 25) material for permanent disposal southeast waste management Kairos Power Hermes Reactor 4-135 Revision 0

Environmental Report Alternatives CHAPTER 5 ALTERNATIVES 5.1 NO-ACTION ALTERNATIVE The proposed federal action is issuance of a Construction Permit (CP) and subsequent Operating License (OL) for a non-power test reactor facility (Hermes) to test and demonstrate the key technologies, design features, and safety functions of the Kairos Power Fluoride Salt-Cooled High Temperature Reactor (KP-FHR) technology. The facility would also provide data that may be used for the validation of safety analysis tools and computational methodologies used for the design and licensing of a KP-FHR commercial power reactor. Under the No-Action Alternative, the NRC would not issue the CP or OL and there would be no subsequent construction or operation. Consistent with the guidance in the Final Interim Staff Guidance (ISG) Augmenting NUREG- 1537, Chapter 19, the environmental consequences of the No-Action Alternative are assumed to be the status quo.

If the test reactor were not constructed and operated, the adverse environmental consequences discussed in Chapter 4 would be avoided. However, as discussed in Chapter 4, the adverse impacts of construction and operation of the test reactor were concluded to be SMALL. Therefore, the benefit of avoiding those impacts would not be significant. Construction and operation of the test reactor does provide socioeconomic benefits as described in Section 4.7, including increases in tax revenues to local jurisdictions, which would not be realized if the test reactor were not constructed and operated.

Furthermore, as discussed in Chapter 1, the government has expressed interest in the development and demonstration of advanced reactor technologies; therefore, if the test reactor is not constructed and operated, the benefits of this initiative would not be realized.

As discussed in Section 1.1, construction and operation of the test reactor provides a means to test the key KP-FHR technologies, design features, and safety functions at a reduced scale relative to the anticipated commercial power reactor. These programmatic benefits would also not be realized under the No-Action Alternative. The programmatic benefits support deployment of advanced nuclear technologies that result in less reliance on carbon fuel-based forms of energy production.

5.2 ALTERNATIVE ELIMINATED FROM FURTHER DISCUSSION As discussed in Chapter 2 the site would have an average water intake of 0.7 0.07 million gallons per day (MGD) with a maximum of 1.1 MGD and discharge of 0.02 MGD. Per conversations with the Oak Ridge Utility Services Department, the water plant regularly supplies 6 to 8 MGD. The current plant has the capacity to regularly produce 12 MGD with the ability to occasionally produce 16 MGD. In addition, the City is planning a new modular treatment water plant that would be designed for 16 MGD with the ability to expand to 20 MGD. This new plant is anticipated to be tested and fully operational by 2025.

The projected average daily demand from the city for 2025 is 8.3 MGD and a peak day demand of 12.4 MGD.

Since the municipal water plant has sufficient capacity to service the needs of the site, the municipal water supply system has been selected as the proposed water source for the facility. Water intake from the Clinch River was considered as a potential alternative, but was eliminated from further consideration due to the following:

• An existing intake structure exists on the Clinch River from previous activities on the former K-33 site; however, it was decommissioned and all operating features other than the structure itself were removed and the area has not been maintained for operation since.

Kairos Power Hermes Reactor 5-1 Revision 0

Environmental Report Alternatives 2025 v/c ratios, the roadways in the vicinity are all under capacity (below 1.0); therefore, impacts to traffic would be SMALL during construction and operation.

Rail There is no direct rail access to the Eagle Rock site. Union Pacific provides three branches of freight rail service through Idaho Falls (Montana Main, Yellowstone, and Aberdeen), with the nearest access being approximately 20 miles to the east (Reference 31). In addition, a DOE-owned spur that connects at the Scoville Siding provides active freight service to the nearby INL, approximately 25 miles to the west of the Eagle Rock site. A regional short line carrier, Eastern Idaho Railroad, connects areas north and east of Idaho Falls to Union Pacific lines (Reference 31, Reference 32).

There may be some deliveries transported by rail for this project which would then be unloaded at a freight yard and shipped by tractor trailer to the site. There are no expected disruptions to rail service in or around the project area due to construction, and operation. The expected impacts to rail service would be SMALL.

Air Two airports serve the region of the Eagle Rock site. The Idaho Falls Regional Airport, approximately 20 miles east of the Eagle Rock site, is operated by the City of Idaho Falls. It provides regularly scheduled regional passenger service to Denver, Salt Lake City, Boise, Seattle, and Las Vegas. The airport has two runways that are different sizes to accommodate commercial and private aviation (Reference 33).

Approximately 20 miles to the west of the Eagle Rock site is Midway Airport in Atomic City. This airport is used exclusively by private planes.

There is likely to be a minor increase in air travel due to workers coming to and departing from the site during various stages of construction. These increases would be minimal and temporary. No expected increases in air travel would be expected during plant operation. The impact to air travel would be SMALL.

Water Although the Snake River flows through Idaho Falls east of the Eagle Rock site, there are no ports or viable water transportation routes that serve the region; therefore, the impact to water travel would be SMALL.

Public Services Public services include water supply and wastewater treatment facilities and police, fire, and social services. Irrigation and domestic water withdrawals are from the Snake River and the American Falls Reservoir, with 97 percent of the surface and groundwater withdrawn in the state being used for agriculture (Reference 34). The East Idaho Wastewater Treatment Plant has a capacity of 2 MGD servicing approximately 21,000 people (Reference 35) while the Idaho Falls Wastewater Treatment Plant has an average capacity of 17 MGD, with a maximum capacity of 34.4 MGD (Reference 36). Water is supplied exclusively through groundwater wells, with a system wide capacity of 88.1 MGD (Reference 37). With a daily water usage rate of 0.08 0.07 MGD, the facility would have a SMALL impact on water and wastewater treatment in the area.

There are 80 police officers in the Bingham County police force as well as 168 officers in Bonneville County with a level of service ranging from 1.2 to 2.5 officers per 1000 residents (Table 5.4-14)

(Reference 38, Reference 39). Bingham County employs 39 full time and 112 part time paid firefighters, while Bonneville County has 97 full time and 32 part time paid firefighters (Reference 40, Reference 41).

Kairos Power Hermes Reactor 5-23 Revision 0