ML22340A583
| ML22340A583 | |
| Person / Time | |
|---|---|
| Site: | Hermes |
| Issue date: | 12/06/2022 |
| From: | Public Commenter Public Commenter |
| To: | NRC/NMSS/DREFS |
| NRC/NMSS/DREFS | |
| References | |
| 87FR59124 | |
| Download: ML22340A583 (6) | |
Text
From: O'NEILL, Martin <mjo@nei.org>
Sent: Tuesday, December 6, 2022 1:29 PM To: KairosHermes-CPEIS Resource Cc: O'NEILL, Martin; NICHOL, Marcus; AUSTGEN, Kati
Subject:
[External_Sender] NRC Docket No. 50-7513; NRC-2021-0193 --
Nuclear Energy Institute Comments on NRC's Draft EIS for Kairos Hermes Test Reactor Construction Permit Application Attachments: NEI Comments on NRC Draft EIS for the Kairos Hermes Test Reactor CP_FINAL_12-06-2022.pdf In accordance with the Nuclear Regulatory Commissions September 29, 2022, Federal Register notice (87 Fed. Reg. 59124), please find attached the Nuclear Energy Institutes (NEI) comments on draft NUREG-2263, Environmental Impact Statement for the Construction Permit for the Kairos Hermes Test Reactor - Draft Report for Comment (Sept. 2022) (ADAMS Accession No. ML22259A126). NEI appreciates the opportunity to submit comments on the NRCs draft EIS.
Please feel free to contact me with any questions regarding this submittal.
Best regards, Marty ONeill Martin J. ONeill l Associate General Counsel Nuclear Energy Institute 1201 F Street NW, Suite 1100 l Washington, DC 20004 T: 202.739.8139 l mjo@nei.org l www.nei.org This electronic message transmission contains information from the Nuclear Energy Institute, Inc. The information is intended solely for the use of the addressee and its use by any other person is not authorized. If you are not the intended recipient, you have received this communication in error, and any review, use, disclosure, copying or distribution of the contents of this communication is strictly prohibited. If you have received this electronic transmission in error, please notify the sender immediately by telephone or by electronic mail and permanently delete the original message. IRS Circular 230 disclosure:
To ensure compliance with requirements imposed by the IRS and other taxing authorities, we inform you that any tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties that may be imposed on any taxpayer or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.
Federal Register Notice: 87FR59124 Comment Number: 11 Mail Envelope Properties (BYAPR03MB415148B5CA1FDABDBF4DFBEEA41B9)
Subject:
[External_Sender] NRC Docket No. 50-7513; NRC-2021-0193 -- Nuclear Energy Institute Comments on NRC's Draft EIS for Kairos Hermes Test Reactor Construction Permit Application Sent Date: 12/6/2022 1:29:02 PM Received Date: 12/6/2022 1:29:34 PM From: O'NEILL, Martin Created By: mjo@nei.org Recipients:
"O'NEILL, Martin" <mjo@nei.org>
Tracking Status: None "NICHOL, Marcus" <mrn@nei.org>
Tracking Status: None "AUSTGEN, Kati" <kra@nei.org>
Tracking Status: None "KairosHermes-CPEIS Resource" <KairosHermes-CPEIS.Resource@nrc.gov>
Tracking Status: None Post Office: BYAPR03MB4151.namprd03.prod.outlook.com Files Size Date & Time MESSAGE 1884 12/6/2022 1:29:34 PM image001.gif 627831 NEI Comments on NRC Draft EIS for the Kairos Hermes Test Reactor CP_FINAL_12-06-2022.pdf 154619 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Martin J. ONeill 202.739.8139 Associate General Counsel mjo@nei.org 1201 F Street NW, Suite 1100 Washington, DC 20004 nei.org
[Docket No. 50-7513; NRC-2021-0193]
December 6, 2022 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 electronically via KairosHermes-CPEIS@nrc.gov
Subject:
Nuclear Energy Institute Comments on the Draft Environmental Impact Statement for the Construction Permit for the Kairos Hermes Test Reactor (NUREG-2263)
The Nuclear Energy Institute (NEI) 1 appreciates this opportunity to provide comments on the NRCs Draft Environmental Impact Statement (DEIS) for Kairos Powers construction permit (CP) application for the Hermes advanced non-power test reactor to be built in Oak Ridge, Tennessee. 2 We continue to support the NRCs efforts to efficiently meet its obligations under the National Environmental Policy Act (NEPA) to consider any potentially significant environmental impacts of proposed licensing actions and to inform the public about the agencys environmental decision making. We also are pleased that the NRCs DEIS reflects appropriate consideration of comments submitted by NEI during the environmental scoping process for the Kairos Hermes CP application. 3 We concur fully with the NRC staffs preliminary recommendation (pending completion of its safety review and final EIS) that the CP be issued to Kairos Power. That recommendation rests soundly on the NRC staffs detailed technical review of the Hermes application, during which the staff weighed the environmental, economic, technical, and other benefits of the proposed action against its environmental and other costs. The DEIS makes clear that the construction and operation of the proposed Hermes test reactor, which has received strong local and national support, will have only minor environmental impacts while conferring potentially substantial long-term benefits.
1 NEI is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
2 NUREG-2263, Environmental Impact Statement for the Construction Permit for the Kairos Hermes Test Reactor -
Draft Report for Comment (Sept. 2022) (ADAMS Accession No. ML22259A126).
3 See Letter from Kati R. Austgen, NEI, to NRC,
Subject:
NEI Comments Regarding the Scope of the Environmental Review for the Kairos Power Hermes Non-Power Test Reactor Construction Permit Application [Docket ID: NRC-2021-0193] (Apr. 19, 2022) (ADAMS Accession No. ML22110A068).
Program Management, Announcements and Editing Staff Comments on Kairos Hermes Draft EIS December 6, 2022 Chief among those benefits are demonstrating the viability of the Kairos Power Fluoride Salt-Cooled High Temperature (KP-FHR) technology and generating technical data necessary to the future licensing and commercial deployment of the technology. In this regard, the Hermes project also will facilitate the mass production of many of the commercial-scale reactors standardized components, thereby reducing construction and maintenance costs and making the full-sized KP-FHR cost-competitive with other generation technologies. Successful future deployment of the KP-FHR technology, in turn, will enhance the nations ability to provide an affordable advanced generation source that complements renewable energy sources by reliably producing dispatchable, zero-emission electricity from a comparatively smaller geographic footprint - all in furtherance of critical climate and energy security objectives. Additionally, the Hermes test reactor project will yield local and regional socioeconomic benefits that will be amplified by the eventual commercial deployment of the KP-FHR on a wider geographic scale.
Consistent with NEIs scoping comments, the NRCs DEIS recognizes that the determination of the need to build a test reactor is within the applicants discretion. As the DEIS explains, [t]he purpose and need of this proposed Federal action is to allow Kairos Power to build and operate a non-power test reactor to demonstrate key elements of the [KP-FHR] technology for possible future commercial deployment. 4 The DEIS also notes that the need for the project is tied directly to the DOEs objectives the under Advanced Reactor Demonstration Program (ARDP), which seeks to enable private companies like Kairos Power demonstrate safe and affordable advanced reactor technologies that can be licensed and deployed over the next 10 to 14 years. 5 Importantly, the NRCs informed articulation of the purpose and need for the proposed action lays the groundwork for the appropriately focused analysis of reasonable alternatives in Section 4.0 of the DEIS.
Finally, we also support the NRCs approach to leverage existing evaluations and various regulatory tools to optimize the environmental review process. Notably, the NRC issued the DEIS less than a year after Kairos tendered its application and two months ahead of the staffs proposed schedule. This reflects the NRC staffs efforts to implement certain process improvements, including more effective pre-application engagement, an enhanced environmental audit process, and increased use of requests for confirmatory information in lieu of formal requests for additional information. Even with the appendices, the DEIS is less than 200 pages long, consistent with the NRC staffs stated intention to produce thorough but concise environmental review documents. To achieve this greater economy, the NRC staff consolidated the affected environment and environmental impacts discussions into a single section (Section 3.0) of the DEIS, presented a single combined discussion of preconstruction and construction impacts for each resource, and made increased use of incorporation by reference. Among other documents, the NRC made frequent use of its 2019 final EIS for Tennessee Valley Authoritys application for an early site permit for a small modular reactor project (the Clinch River Nuclear project) on a site located near the proposed Hermes site. 6 Given the anticipated substantial increase in the volume of advanced 4 DEIS at xiv.
5 DEIS at 1-3.
6 NUREG-2226, Environmental Impact Statement for an Early Site Permit (ESP) at the Clinch River Nuclear Site -
Final Report (Apr. 2019) (ADAMS Package Accession ML19087A266).
Nuclear Energy Institute 2
Program Management, Announcements and Editing Staff Comments on Kairos Hermes Draft EIS December 6, 2022 reactor license applications over the next decade (e.g., for light-water small modular reactors, non-LWRs, microreactors), efficient environmental reviews will be even more imperative. 7 In summary, NEI is pleased with the quality, timeliness, and efficiency of the NRCs DEIS for the Hermes application, as well as the NRCs consideration of our scoping comments. We also commend Kairos Power for submitting a high-quality application and working with the NRC staff to meet its related information needs, both of which are essential to timely and efficient NRC reviews.
These improvements in the EIS process provide a foundation for achieving even greater efficiencies and timeliness for future advanced reactor environmental reviews.
If you have questions concerning this letter, please contact me at mjo@nei.org or 202-739-8139.
Sincerely, Martin J. ONeill Martin J. ONeill Associate General Counsel 7 See Letter from Marcus R. Nichol, NEI, to Robert M. Taylor, NRC,
Subject:
NEI Input on Regulatory Priorities for New and Advanced Reactors (June 7, 2022) (ADAMS Accession No. ML22158A363).
Nuclear Energy Institute 3