ML23047A416

From kanterella
Jump to navigation Jump to search
Comment (8) E-mail Regarding TRISO-X EIS Scoping
ML23047A416
Person / Time
Site: Triso-X
Issue date: 02/14/2023
From: Public Commenter
Public Commenter
To:
NRC/NMSS/DREFS
NRC/NMSS/DREFS
References
87FR77146
Download: ML23047A416 (4)


Text

From: Rowen Price <rprice@thirdway.org>

Sent: Tuesday, February 14, 2023 11:11 AM To: TRISOX-EIS Resource Cc: Alan Ahn; Ryan Norman

Subject:

[External_Sender] Comment Submission from Third Way: Docket ID NRC-2022-0201 Attachments: Third Way Comment Submission - Docket ID NRC-2022-0201.pdf

Dear Mr. Moses:

Please see the attached written comment from Third Way in response to the U.S. Nuclear Regulatory Commissions scoping process to gather information necessary to prepare an environmental impact statement to evaluate the environmental impacts for a license for possession and use of special nuclear material requested by TRISO-X, LLC (Docket ID NRC-2022-0201).

We appreciate the opportunity to comment on this important issue. Please contact us if you have any questions or require clarification on any matters addressed in this comment.

Sincerely, Rowen Price Rowen Price Policy Advisor for the Climate and Energy Program l Third Way rprice@thirdway.org

Federal Register Notice: 87FR77146 Comment Number: 8 Mail Envelope Properties (PH0PR18MB49538BF747589212A7BBA273BDA29)

Subject:

[External_Sender] Comment Submission from Third Way: Docket ID NRC-2022-0201 Sent Date: 2/14/2023 11:10:40 AM Received Date: 2/14/2023 11:11:21 AM From: Rowen Price Created By: rprice@thirdway.org Recipients:

"Alan Ahn" <aahn@thirdway.org>

Tracking Status: None "Ryan Norman" <rnorman@thirdway.org>

Tracking Status: None "TRISOX-EIS Resource" <TRISOX-EIS.Resource@nrc.gov>

Tracking Status: None Post Office: PH0PR18MB4953.namprd18.prod.outlook.com Files Size Date & Time MESSAGE 723 2/14/2023 11:11:21 AM Third Way Comment Submission - Docket ID NRC-2022-0201.pdf 81766 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

February 14, 2023 Regulations.gov Docket ID: NRC-2022-0201 NRC Licensing Docket No. 70-7027 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 TRISOX-EIS@nrc.gov

Subject:

Comment from Third Way on the U.S. Nuclear Regulatory Commissions Scoping of TRISO-X Environmental Impact Statement (Docket ID NRC-2022-0201)

Dear Mr. John M. Moses:

The following is a written comment from Third Ways Climate and Energy Program on environmental issues related to TRISO-X, LLCs license application for the possession and use of special nuclear material for the manufacture of high-assay low-enriched uranium (HALEU) at a fuel fabrication facility in Oak Ridge, Tennessee. Third Way is a national think tank based in Washington, DC that champions center-left ideas and policies. The Climate and Energy Program at Third Way designs and advocates for policies with the aim of enabling the US and the rest of the world to achieve the fastest and fairest path to net-zero emissions.

Consistent with the views of prominent experts within the climate science community and the current executive administration, we believe that nuclear energy will play an essential role in meeting global climate objectives given the vast amounts of low-carbon energy sources that will need to be deployed in order to meaningfully reduce greenhouse gas emissions within a very short timeframe. Recognizing the role of nuclear energy, and in particular advanced reactors, in meeting climate goals, the Department of Energy has invested significant resources into the Advanced Reactor Demonstration Program (ARDP). The program is scheduled to demonstrate two advanced nuclear reactors before 2030, including X-energys Xe-100 design.

Adequate fuel supply is essential for timely demonstration of the Xe-100. We believe that the TRISO-X Fuel Fabrication Facility (FFF), designed to produce proprietary TRISO-X fuel for the Xe-100, will play a significant role in successfully demonstrating this reactor without delay.

X-energys TRISO-X fuel is one of the latest innovations in fuel design, building on a legacy of United States and global nuclear energy experience. TRISO-X fuel will be cheaper, able to safely operate at higher temperatures, and more operationally flexible. This fuel technology possesses inherent attributes that make it more resilient to accidents or other hazards. The FFFs licensing and operation is essential in order for X-energys Washington demonstration, one of the flagship ARDP award projects, to contribute to US and global decarbonization. Production of this robust fuel will contribute to fuel security for the Xe-100 design and thus broader US fuel security goals.

ARDP is a pivotal step towards the deployment of US advanced reactors for national and global climate goals, as the United States will not meet its goals without expanding and advancing its nuclear energy generation capacity and domestic fuel cycle capabilities. As has been shown in multiple studies, the premature reduction of US nuclear capacity would result in an increase in 1025 Connecticut Ave NW, Suite 400

  • 202.384.1700
  • 202.775.0430 fax

fossil fuel generation and therefore undermine progress toward climate objectives. The fabrication and use of new robust fuels including TRISO-X will support nuclear power generations ability to curb growth of hazardous fossil fuel emissions harming local communities.

We urge the NRC to implement a comprehensive view of nuclear energys environmental implications throughout the fuel cycle in developing its environmental assessment process by taking into account nuclear energys contribution to reducing climate and non-climate emissions. Further, we advise that the NRC apply this perspective in its review of the environmental impact statement for TRISO-X, LLCs TRISO-X Fuel Fabrication Facility, and keep its environmental review as efficient as possible by keeping the scope of the review focused.

Sincerely, Rowen Price Ryan Norman Policy Advisor Senior Policy Advisor Climate and Energy Program Climate and Energy Program Third Way Third Way Alan Ahn Josh Freed Senior Resident Fellow Senior Vice President Climate and Energy Program Climate and Energy Program Third Way Third Way Third Way

  • 2