ML22341A025

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Comment (13) E-mail Regarding Kairos Hermes CP Deis
ML22341A025
Person / Time
Site: Hermes
Issue date: 12/06/2022
From: Public Commenter
Public Commenter
To:
NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
87FR59124
Download: ML22341A025 (12)
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Text

From: dougcolcl@aol.com Sent: Tuesday, December 6, 2022 9:20 PM To: KairosHermes-CPEIS Resource; KairosHermes-CPEIS Resource Cc: Tami Dozier; Peyton Doub; Brian Glowacki

Subject:

[External_Sender] Elaboration - Re: Public Input --- Kairos Hermes Test Reactor Construction Permit Request Attachments: Airport_O_R_City_Council_7_2009_20200806_0008.pdf Public input - Re:

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumbe r=ML22259A126 U.S. NRC ( United States Nuclear Regulatory Commission NUREG-2263 Environmental Impact Statement for the Construction Permit for the Kairos Hermes Test Reactor Draft Report for Comment Manuscript Completed: September 2022 -- Date Published: September 2022 This additional input is elaboration on one point mentioned in my earlier public input attached below. Regarding proximity of the project to a proposed general aviation ( GA ) airport, I believe it is important and justified that the NRC reach out to the Federal Aviation Administration GA planners and voice concern-objection even, to the plans for a GA airport so close. As I noted in earlier input physical safety from what would be low flying and concentrated numbers of aircraft , is one concerning issue but the health risks of tetraethyllead is another and much more insidious. The proposed airport would be situated such that the Kairos-Hermes workforce would be in the shadow of the proposed airport primary aircraft takeoff location .

Here is some perspective on human health risks form piston engine aircraft

, see below four Wikepedia "links" that offer a understanding of lead as a motor-fuel additive and consequential health hazard. A picture of science and history of lead in our economy and health risks associated with piston engine aircraft .

1. https://en.wikipedia.org/wiki/Avgas Many may not be aware that approximately 190,000 piston engine aircraft in the US aircraft fleet today ( essentially the entire fleet ) require leaded aviation gas ( Avgas ) . This would be the predominant type of aircraft using a proposed Oak Ridge airport.

Tetraethyllead (TEL) found in leaded avgas and its combustion products are potent neurotoxins that have been shown in scientific research to

interfere with brain development in children. Children in residences or childcare facilities in close proximity to airports with moderate to high piston engine aircraft traffic are at especially high risk of high blood lead levels.[99][100][101] The United States Environmental Protection Agency (EPA) has noted that exposure to even very low levels of lead contamination has been conclusively linked to loss of IQ in children's brain function tests, thus providing a high degree of motivation to eliminate lead and its compounds from the environment.[102][103]

While lead concentrations in the air have declined, scientific studies have demonstrated that children's neurological development is harmed by much lower levels of lead exposure than previously understood. Low level lead exposure has been clearly linked to loss of IQ in performance testing. Even an average IQ loss of 1-2 points in children has a meaningful impact for the nation as a whole, as it would result in an increase in children classified as mentally challenged, as well as a proportional decrease in the number of children considered "gifted".[103]

Ttetraethyl lead in avgas.

Dr Patterson was an Oak Ridge Manhattan Project scientist early in his career . In later work he discovered this terrible public health problem of lead while he was trying to do something completely different, establishing the age of the Earth by measuring the decay of uranium wrt its daughter products.

2. https://en.wikipedia.org/wiki/Clair_Cameron_Patterson In the reboot of the Cosmos series (hosted by Neil Degrasse Tyson),

there is an entire episode (#7) about this,

3. https://en.wikipedia.org/wiki/The_Clean_Room and how Big Business tried to destroy Dr. Pattersons reputation and job, lying to Congress,
4. https://en.wikipedia.org/wiki/Robert_A._Kehoe knowing full well about the risks of lead already.

So the problem for the people who are near and downwind of the proposed airport is that during the most power- & fuel-hungry portion of a flight, i.e.

takeoff, this powerful neurotoxin will be spewed into the immediate environment at an orders of magnitude greater rate than at any other phase of flight (i.e., cruise, and landing which is essentially just a glide). Worse, this emission is occurring at and near ground level.

Before the Clean Water / Air Acts kicked in, this stuff was everywhere. But now that we (the human race) have done such a good job at removing heavy metallic neurotoxins from our economy, an operation like small-scale general aviation, has a relatively more toxic effect compared to past.

This proposed airport is a local recreational luxury by choice not economically essential, while Kairos's Hermes SMR initiative is a national clean energy economic priority. The contrast could not be more stark- clean energy R & D and next to it a proposal that began 13 years ago ( see attached ) to develop an airport, a major contributor of greenhouse gas emissions. When an airport was suggested during the depressed economy of 2009 there were little to no prospects at Heritage Center. That fact has changed dramatically with Hermes and other opportunities of far greater merit - even national priorities. No firm commitment to an airport after 13+

years is indication of the lack of merit. Especially with a modern GA airport within 23 minutes travel time -- RKW.

--- Respectfully Doug Colclasure, Citizen of Oak Ridge From: dougcolcl@aol.com To: KairosHermes-CPEIS@nrc.gov, KairosHermes-CPEIS.Resource@nrc.gov Cc: Jill.Caverly@nrc.gov, Matthew.Bartlett@nrc.gov, Tamsen.Dozier@nrc.gov, Peyton.Doub@nrc.gov, kenneth.erwin@nrc.gov Sent: 11/16/2022 9:54:48 AM Eastern Standard Time

Subject:

Public Input --- Kairos Hermes Test Reactor Construction Permit Request 11/16/2022 9:54:48 AM Eastern Standard Time, dougcolcl@aol.com writes:

KairosHermes-CPEIS@nrc.gov, KairosHermes-CPEIS.Resource@nrc.gov, Jill.Caverly@nrc.gov, Matthew.Bartlett@nrc.gov,

Tamsen.Dozier@nrc.gov, Peyton.Doub@nrc.gov, kenneth.erwin@nrc.gov Public input - Re:

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumbe r=ML22259A126 U.S. NRC ( United States Nuclear Regulatory Commission NUREG-2263 Environmental Impact Statement for the Construction Permit for the Kairos Hermes Test Reactor Draft Report for Comment Manuscript Completed: September 2022 -- Date Published: September 2022 .

As this point there is a proposal to construct a small general aviation airport in close proximity to the location of the Hermes nuclear facility. The safety implications were not foreseen by those proposing an Oak Ridge airport back in 2009, see attached. During the depressed economic prospects of 2009 it was believed that a small GA airport would lead to economic benefits to industries looking to locate adjacent to an airport. To this day ,

13 + years later, there are no independent assessments supporting that contention. Simply put - no compelling merits to justify an airport. For starters the 1300 acre Heritage Center industrial park is all but sold and occupied, only 151 acres in small isolated parcels, remaining. In fact quite the contrary.

Just in the last 5 years the following business entities have chose to locate and do business in Oak Ridge. And not one has tied their decision to the prospect of a general aviation airport. , Kairos, X-Energy, TVA-Hitachi-GE, Ultra Safe Nuclear Corp, General Fusion, Carbon Rivers, etc.

Some say TYS congestion suggests the need for a "reliever airport" . This is highly questionable. TYS has two runways over 9,500' in length. From 2014 through 2021 TYS had one runway completely closed for a total reconstruction ( $110 million ). And during that 7 years the GA traffic at TYS increased at least 33% - Cirrus. The FAA reported no traffic congestion issues. Keep in mind TYS is the 92nd largest Commercial & GA airport in the US. Spread over 2500 acres. Ample room for growth - re:

Cirrus for example. And not once has consideration been given to how convenient RKW is to west Knox County and Oak Ridge .

To be building a small General Aviation airport for use by a few dozen recreational pilots to store and fly light sport aircraft, many with FAA experimental designation, has nuclear safety & other implications that make such a project ill-advised on many levels.

You may be unaware that as recently as this past spring the runway preliminary design alignment-characteristics were changed again for at least the 6th time in the 13 years . There is just no location safe for aviation, in this narrow ridge and valley topographic province. Having a concentration of low flying LSA's passing directly above the reactor ,

preparing to land would be a recipe for concern.

The latest proposed plan is to construct the runway across the front of Heritage Center. Effectively constructing a wall, 50' high at the west end ,

for over a mile in length across the entire front of Heritage Center parallel to TN Rt 58, with tunnel access to the site. The vast majority of vehicle traffic doing business in Heritage Center would be funneled through this tunnel .

This would include primary access to and from Hermes, emergency services, the Oak Ridge fire department, tourists visiting the MPNHP K-25 History Center, Energy Solutions semi-trucktrailer access to their rail facility for off site transfer of hazardous materials , etc.

Please make your voices heard that an airport under such dubious merits is an unacceptable risk to the nuclear reactors and related nuclear facilities within & in the vicinity of Heritage Center industrial park. Keep in mid it is not just Hermes at risk , the list is quite lengthy :

  • Kairos 10 MW Thermal SMR "Hermes" -- requiring NRC permit now being addressed
  • And Kairos plans for Atlas - SMR fuel mfg -- requiring another NRC permit

-- handling HALEU

  • X-Energy's plans to mfg TRISO-X - requiring NRC permit - handling HALEU
  • TVA-Hitachi-GE plans for a three SMR demonstration project at the former CRBR site- requiring NRC permits
  • As well the HFIR at ORNL
  • And SNM (special nuclear materials} at CNS-Y12 All of these are within 9 miles or less from a proposed airport and in the shadow of often little more than sightseeing flights flown at low altitude by recreational pilots.

It would be one thing if an airport existed with established economic benefits compared to a yet to be constructed airport proposed 13 years ago under far different economic prospects and now offering little more than a recreational luxury. There is just no defense to place so many nuclear facilities at risk from an unnecessary GA airport, that will require 230 acres of rare flat land , tax exempt, creating at most 6 jobs with starting pay of

$17 per hour. Rewards vs risks are just not there. In a word a proposed GA

airport in this instance in this location is "unjustified" on many levels -

economically and nuclear safety risks are but two.

Public safety is a part of the environment being assessed, re: the EA. The NRC has every defensible reason ( safety, incompatibility, no clear economic justification, etc) to look at this permit request through a much broader lens and clearly oppose this proposed general aviation airport in such close proximity to Hermes and surrounding nuclear facilities. Think of it like this - "Would the NRC license a nuclear facility in the same Industrial Park this close to an existing GA airport? " , "Would you even be faced with that prospect ?"

It is likely the NRC is not aware of the fact that the proposed location of the airport does not meet the FAA "Entry Criteria" requirement .

See page 19 of the FAA Order:

https://www.faa.gov/documentLibrary/media/Order/planning_5090_3c.pdf RKW is only 23 minutes travel time from Heritage Center. And only 15 air miles. It is a modem ( $ millions in upgrades and new facilities in past 15 years ) general aviation airport with unlimited room for expansion.

https://airnav.com/airport/RKW Just 1 mile off I-40 at exit 340 . Here is a link to some of the pics of Rockwood Airport - One of the most modern airports in East Tennessee.

https://www.dropbox.com/sh/n2abiyzbicsutpe/AADy-UOu6h7zy7lm2FfBxvkVa?dl=0 This Kairos SMR R & D program is all about clean energy, reducing the carbon footprint, mitigating climate change-global warming , i.e.

supporting the greater public good by every measure. Kairos held a public engagement Zoom meeting on Nov 3, 2022. It is encouraging to hear first hand how focused and confident they are in making cleaner energy a reality for our nation. There is hope.

A proposed General Aviation airport with piston engine aircraft operating on leaded avgas https://en.wikipedia.org/wiki/Avgas ,

spewing carbon and lead emissions in great concentrations at low altitude operating at maximum power at takeoff directly overhead of the very people devoted to clean energy - is embarrassingly contrary to what our future in Oak Ridge ( think Hermes, ORNL materials-high speed computing-climate mitigation R & D programs ) ,

in Tennessee, and our country is desperately pursuing.

--- Respectfully, Doug Colclasure, Citizen of Oak Ridge TN .

((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((((

From: KairosHermes-CPEIS.Resource@nrc.gov To: KairosHermes-CPEIS.Resource@nrc.gov Cc: Tamsen.Dozier@nrc.gov, Peyton.Doub@nrc.gov Sent: 9/29/2022 10:55:23 AM Eastern Standard Time

Subject:

Availability of the Draft Environmental Impact Statement for Kairos Hermes Test Reactor Construction Permit The NRC has published the draft Environmental Impact Statement (EIS) for the Construction Permit for the Kairos Hermes Test Reactor. The draft EIS (NUREG-2263) is available through the Agencywide Document Access and Management System (ADAMS) at the below link.

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML22259A126 By letter dated September 26, the agency issued its Notice of Availability which was published in the Federal Register on September 29. Below is a link to the ADAMS package containing the issuance letter and enclosed FRN. These include information related to the comment period, ways to provide comments, and the comment gathering public meeting.

https://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML22243A251 If you have any questions or access difficulties, please contact Tamsen Dozier at Tamsen.dozier@nrc.gov (301-415-2272) or Peyton Doub at Peyton.Doub@nrc.gov (301-415-6703).

Federal Register Notice: 87FR59124 Comment Number: 13 Mail Envelope Properties (84461725.1218504.1670379600281)

Subject:

[External_Sender] Elaboration - Re: Public Input --- Kairos Hermes Test Reactor Construction Permit Request Sent Date: 12/6/2022 9:19:59 PM Received Date: 12/6/2022 9:20:22 PM From: dougcolcl@aol.com Created By: dougcolcl@aol.com Recipients:

"Tami Dozier" <Tamsen.Dozier@nrc.gov>

Tracking Status: None "Peyton Doub" <Peyton.Doub@nrc.gov>

Tracking Status: None "Brian Glowacki" <Brian.Glowacki@nrc.gov>

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

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

Tracking Status: None Post Office: mail.yahoo.com Files Size Date & Time MESSAGE 19888 12/6/2022 9:20:22 PM Airport_O_R_City_Council_7_2009_20200806_0008.pdf 2228108 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Page 6 Minutes - JulY 20,2009 OAK RIDGE CITY COUNCIL MEETING WHEREAS,onJulyl,2009,LawrenceT.Young,PresidentandCEooftheCommunity a letter to the Mayor requesting the Reuse organization of Easi Tennessee (CROET), submitted to oak Ridge; and ctty'. .rp[ort for cRoET's efforts in bringing an airport and its affiliates' the Heritage wHEREAS, the July 1, 200g tetter indicates that cRoET a formal study of the feasibility of center, LLC, and the Horizon cent"r, ilc, intends to undertake currently owned by cRoET or slated to be a general aviation airport on property which is either (DOE); and transferred to CROEi from the Department of Energy and rts affiliates do not intend WHEREAS, the letter further assures the City that CROET are only requesting the city's support of to request any funding from the city for this project ahd thisendeavorthrough"cooperationwithzoningandpermittingmatters, NoW,THEREFORE,BEITRESOLVEDBYTHECOUNCILoFTHECITYoFoAK RIDGE, TENNESSEE:

That the city council hereby supports the efforts of the community Reuse organization the feasibllity of bringing a general aviation of Easi rennessee (cRoET)and its affiliates to study airporttooakRidgetobelocatedonpropertywhichiseithercurrentlyownedbyCRoETor Oepartment of Energy (DOE)' as set forth in the slated to be transferred to CROET from the J.S' attached letterJated July'1,2009 from Lawrence T' Young, President and CEO of the Community Reuse Organization of East Tennessee' been assured that the support BE lT FURTHER RESOLVED that city council has

.uppori, as cRoET in its letter has indicated rt does not requested trom ine ilty l. not finan^cial intend to request funding from the City substitute. resorution focuses on support for a study of councirwoman smith exprained that her proposed to whether to support the airport the feasibirity of bringing an airport to ogk h;J;;

with the decision as study' itself to be considereO aiter completion of the feasibility with Garcia Garland and a brief discusston followed, The amendment was seconded by Councilwoman theCityManagerandMr.LawrenceTYoungrespondingtotheCouncil'squestronsandcomments.

electronic vote with Council members Garcia The motron to amend by substitutionr was adopted by "Rye" and Councrl members Hensley' Miller' and Mayor Garland, HaYes, MosbY, and Smith voting Beehan voting "NaY."

electronic vote with Council members Garcia The resolution WaS adopted, as amended, by unanimous Mayor Beehan voting "Aye'"

Garland, Hayes, nun.i"V ft,1ijler, Mosby, Smith and Bids and Contracts Resolution No. 7-72-09 to Stuart G' lrby Gompany' of A resolution awarding a bid in the estimated amount $133,415'00 electric cable' Johnson city, Tennes-see, for the furnishing of underground The motton was seconded by councilwoman councilwoman Miller moved that the resolution be adopted.

uy unrnimous voice vote with council members Garcia Smith and after brref Jetiueration, it carrieo Mayor Beehan voting "Aye "

Garland, Hayes, nensf ey, Hliller, Mosby, Smith' and

NUMBER 7-71-09 RESOLUTION WHEREAS, on July 1,2AOg, Lawrence T. Young, President and CEO of the Community Reuse Organization of East Tennessee (CROET), submitted a letter to the Mayor requesting the City's support for CROET's efforts in bringing an airport to Oak Ridge; and WHEREAS, the July 1 ,2OOg letter indicates that CROET and its affiliates, the Heritage Center, LLC, and the Horizon Center, LLC, intends to undertake a formal study of the feasibility of a general aviation airport on property which is either currently owned by CROET or slated to be transferred to CROET from the Department of Energy (DOE); and WHEREAS, the letter further assures the Clty that CROET and its affiliates do not intend to request any funding from the City for this project and are only requesting the City's support of this endeavor through cooperation with zoning and permitting matters.

NOW, THEREFORE, BE IT RESOLVED BY THE COUNCIL OF THE CITY OF OAK RIDGE, TENNESSEE:

That the City Council hereby supports the efforts of the Community Reuse Organization of East Tennessee (CROED and its affiliates to study the feasibility of bringing a general aviation airport to Oak Ridge to be located on property which is either currently owned by CROET or slated to be transferred to CROET from the U.S. Department of Energy (DOE), as set forth in the attached letter dated July 1, 2009 from Lawrence T. Young, President and CEO of the Community Reuse Organization of East Tennessee BE lT FURTHER RESOLVED that City Council has been assured that the support requested from the City is not financial support, as CROET in its letter has indicated it does not intend to request funding from the City.

This the 20th day of July 2009.

APPROVED AS TO FORM AND LEGALITY:

Mayor

i:i [*fi tvrii

@r Comnrunitl' Reuse Organization of East Tenncssee July 01 ,2009 fr** J*L 0FFiCE Cij

-Z Eii E: ftk T.iI Uli-]' i;l-;R;i Ma-vor Tom Beehan City of Oak Ridge P.O. Box I Oak fudge, Tennessee 31831-0001

'107 Lea Way R.E: Generai Aviarion Airport Study P.O Box 21'10 Mayor Beehan and Honorable Members of Citl,Council:

Oak Ridge, TN 37831-2110 phone; 865 482 9890 The Cornmunity Reuse Organization of East Tennessee and its affiiiates, the Helitage Center, LLC and the Horizon Center. LLC, have been investigating fax.865 4829891 the possibility of establishing a general aviation airporl on properly rr,,ithin the East Tennessee Technolo_ey Park (ETfP). \\ie are writing to 1.ou to infonn and gain ).our support in this endeavor.

wrvw.croet.com We have, over the past few months. been investigating numerous sites within the ETTP. \Vith the assistanee of the Knox.ville l,4etropolitan Airporl Authority staff, u,e har,e identilled a number of possibie choices that could suppofi a 5.000+ iinear foot runrvay. It is norv time to underlake a profbssional study of the ETTP area to ascefiain its true feasibility. The areas under consideration ale on propert,v owned by CROET or are on properly siated to be transferred from DOE to CROET.

It is our understanding that grant monies are available for such an endear,or.

We intend on contracting u,ith the Knoxville Metropolitan Airport Authoritl, to assist us in acquiring funClng lor the project. \,\ e Cc not inlencl t-c requesr any funding from the City, however, r.,e rvould ask that the City endorse our efforts to secure this project and that the City cooperate r.vith zoning and pennitting matters. if and u,hen, the project is determined to be feasible.

Much rvork needs to be done to ascertain the viability of the project rvithin the ETTP site and it is likely that mucir more w.ork rvill need to be done to any potentiai sites in making them ready to accommodate a general aviation airport. First steps are impofiant. As such, rve rvould very much like to have the Citl' of Oak Ridge's support in this ver,v rvorthrvhile community enhancement project.

J The CROET Fanzill: oJ gonrrrorott Heritage Center. LLC c Horizon Center, LLC a Halcyon, LLC a Het'itage Railroacl Cot'p.

Airport Feasibility Study July 01 .2009 Page 2 of 2 t1 I look fbrrvard to receipt of your considered and positive reply. As ah.r,ays. I am available to ans\\rer anv questions that arise fronr this request for supporl.

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I.aurence T. Young

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President and CEO cc: CROET Directors Heritage Center Directors Horizon Center Directors Roberl Brorvn- DOE N4ike Farmer, Roane County

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