ML22340A043

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Comment (8) E-mail Regarding Kairos Hermes CP Deis
ML22340A043
Person / Time
Site: Hermes File:Kairos Power icon.png
Issue date: 12/03/2022
From: Public Commenter
Public Commenter
To:
NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
87FR59124
Download: ML22340A043 (7)


Text

From:

Peter Hastings <hastings@kairospower.com>

Sent:

Saturday, December 3, 2022 2:58 PM To:

KairosHermes-CPEIS Resource Cc:

Martin Bryan; Darrell Gardner; DCRM

Subject:

[External_Sender] Comments on Draft Environmental Impact Statement for Hermes Test Reactor Construction Permit (Docket ID:

NRC-2021-0193)

Attachments:

KP-NRC-2212-001 Comments on the Kairos Power Hermes Test Reactor Construction Permit Draft Environmental Impact Statement.pdf Kairos Power appreciates the opportunity to provide comments on the referenced Hermes Construction Permit Draft Environmental Impact Statement (DEIS). In addition to its oral comments made at the November 16, 2022 public meeting in Oak Ridge, TN, Kairos Power offers the attached comments to provide clarification on a handful of minor points.

Sincerely, Peter S. Hastings, PE Vice President, Regulatory Affairs & Quality Kairos Power LLC 2115 Rexford Road, Suite 325 Charlotte, NC 28211 Office +1 704 336 9596 Mobile +1 704 650 1700 hastings@kairospower.com Headquarters 707 West Tower Avenue, Suite A Alameda, CA 94501

Federal Register Notice:

87FR59124 Comment Number:

8 Mail Envelope Properties (SA1P110MB1647DD9BD77C3F937B8796AFDA169)

Subject:

[External_Sender] Comments on Draft Environmental Impact Statement for Hermes Test Reactor Construction Permit (Docket ID: NRC-2021-0193)

Sent Date:

12/3/2022 2:57:40 PM Received Date:

12/3/2022 2:58:09 PM From:

Peter Hastings Created By:

hastings@kairospower.com Recipients:

"Martin Bryan" <bryan@kairospower.com>

Tracking Status: None "Darrell Gardner" <gardner@kairospower.com>

Tracking Status: None "DCRM" <DCRM@kairospower.com>

Tracking Status: None "KairosHermes-CPEIS Resource" <KairosHermes-CPEIS.Resource@nrc.gov>

Tracking Status: None Post Office:

SA1P110MB1647.NAMP110.PROD.OUTLOOK.COM Files Size Date & Time MESSAGE 697 12/3/2022 2:58:09 PM image001.png 8211 KP-NRC-2212-001 Comments on the Kairos Power Hermes Test Reactor Construction Permit Draft Environmental Impact Statement.pdf 281314 Options Priority:

Normal Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

KP-NRC-2212-001 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 December 3, 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 Draft Environmental Impact Statement Hermes Test Reactor Construction Permit Docket ID: NRC-2021-0193

Reference:

Draft NUREG-2263, Nuclear Regulatory Commission, Environmental Impact Statement for the Construction Permit for the Kairos Hermes Test Reactor, September 2022 (ML22259A126)

Kairos Power appreciates the opportunity to provide comments on the referenced Hermes Construction Permit Draft Environmental Impact Statement (DEIS). In addition to its oral comments made at the November 16, 2022 public meeting in Oak Ridge, TN, Kairos Power offers the enclosed comments to provide clarification on a handful of minor points.

If you have any questions or need any additional information, please contact Marty Bryan at bryan@kairospower.com or (704) 317-7278, or Darrell Gardner at gardner@kairospower.com or (704) 769-1226.

Sincerely, Peter Hastings, PE Vice President, Regulatory Affairs and Quality

Enclosure:

1) Comments on the Kairos Power Hermes Test Reactor Construction Permit Draft Environmental Impact Statement

KP-NRC-XXXX-XXX Page 2 xc (w/enclosure):

William Jessup, Chief, NRR Advanced Reactor Licensing Branch Benjamin Beasley, Project Manager, NRR Advanced Reactor Licensing Branch Tamsen Dozier, Environmental Project Manager, NMSS, Environmental Review Branch Peyton Doub, Environmental Project Manager, NMSS, Environmental Review Branch

KP-NRC-2212-001 Comments on the Kairos Power Hermes Test Reactor Construction Permit Draft Environmental Impact Statement (Non-Proprietary)

Page 1 of 1 Comments on the Kairos Power Hermes Test Reactor Construction Permit Draft Environmental Impact Statement Comment Number Draft Environmental Impact Statement Text and Location Comment 1

Page 2-3, Line 19: the offsite discharges would include 16 gpm from the bathrooms and 1 gpm from the decay heat removal system (DHRS).

The 1 gpm from the decay heat removal system is evaporated. If evaporation is included in this discharge summary, the staff may also want to consider the 34 gpm of evaporation from the chilled water system, per ER Figure 2.4-1.

2 Page 3-6, Line 27: The applicant has indicated that the Atlas facility would occupy no more than 30 ac of land on the site, located outside of the approximately 30 ac of land occupied by the Hermes facilities The Atlas facility location, within the Kairos property, has not been chosen yet. No land use conflict is expected. We suggest the language in the DEIS be altered to delete located outside of the approximately 30 ac of land occupied by the Hermes facilities 3

Page 3-13, Line 22: Intermittent use of propane fired heaters for the intermediate coolant located in the primary heat rejection system during maintenance activities This information was deleted from the ER in an enclosure to a letter dated February 18, 2022.

(ML22049B556) 4 Page 3-71, Line 18: A primary heat rejection system capture system for tritium separation from dry air in the cover gas; This information was deleted from the PSAR and the ER in enclosures to a letter dated February 18, 2022 (ML22049B556).

5 Page 3-79, Line 36: Additionally, as an indicator of the low risks from postulated accidents, the MHA dose at the LPZ is also below the annual radiation dose limits for individual members of the public of 100 mrem TEDE under 10 CFR 20.1301(a).

The MHA dose at the LPZ is below the annual dose limit values specified in 10 CFR 20.1301(a).

However, these limits are for annual effluent releases and are not applicable to MHA doses associated with postulated events in this or other applications. We believe the NRC staffs purpose in making this comparison is to demonstrate the fact that even postulated accident doses are below normal-operation limits, but we suggest some clarification.

6 Page 4-9, Line 23: The applicant did not provide cost (internal, external, fuel, waste disposal) information for the construction, operation, or decommissioning of the proposed project.

Financial information was provided as proprietary information in enclosure 4 with the PSAR submission dated September 29, 2021.