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Category:General FR Notice Comment Letter
MONTHYEARML23048A1712023-02-20020 February 2023 Comment (161) of Dana Petre-Miller on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23047A5402023-02-16016 February 2023 Comment (23) E-mail Regarding TRISO-X EIS Scoping ML23047A0992023-02-15015 February 2023 Comment (1) E-mail Regarding TRISO-X EIS Scoping ML23047A4052023-02-15015 February 2023 Comment (2) E-mail Regarding TRISO-X EIS Scoping ML23136B1582023-02-14014 February 2023 Comment (1738) of Doug Wagoner on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; TRISO-X Special Nuclear Material License ML23047A4092023-02-14014 February 2023 Comment (3) E-mail Regarding TRISO-X EIS Scoping ML23047A4102023-02-14014 February 2023 Comment (4) E-mail Regarding TRISO-X EIS Scoping ML23047A4112023-02-14014 February 2023 Comment (5) E-mail Regarding TRISO-X EIS Scoping ML23047A4132023-02-14014 February 2023 Comment (6) E-mail Regarding TRISO-X EIS Scoping ML23136B1612023-02-14014 February 2023 Comment (1739) of Michael Keegan on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1632023-02-14014 February 2023 Comment (1740) of Alice Hirt on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; TRISO-X Special Nuclear Material License ML23136B1652023-02-14014 February 2023 Comment (1741) of Mary Jane Williams on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1692023-02-14014 February 2023 Comment (1742) of Jessie Collins on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1702023-02-14014 February 2023 Comment (1743) of Mark Blandford on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; TRISO-X Special Nuclear Material License ML23136B1722023-02-14014 February 2023 Comment (1744) of Barbara Antonoplos on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; TRISO-X Special Nuclear Material License ML23047A4152023-02-14014 February 2023 Comment (7) E-mail Regarding TRISO-X EIS Scoping ML23047A4162023-02-14014 February 2023 Comment (8) E-mail Regarding TRISO-X EIS Scoping ML23136B1752023-02-14014 February 2023 Comment (1747) of Janine Carmona on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23047A4172023-02-14014 February 2023 Comment (9) E-mail Regarding TRISO-X EIS Scoping ML23136B1782023-02-14014 February 2023 Comment (1749) of Anne Kiley on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1792023-02-14014 February 2023 Comment (1750) of Elizabeth Guimarin on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1822023-02-14014 February 2023 Comment (1751) of Victor Ibarra, Jr. on Behalf of Nuclear Innovation Alliance on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1832023-02-14014 February 2023 Comment (1752) of William Dean on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B2072023-02-14014 February 2023 Comment (1771) of Christine Walturz on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B2062023-02-14014 February 2023 Comment (1770) of Marilyn Welker on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B2042023-02-14014 February 2023 Comment (1769) of Norda Gromoll on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B2022023-02-14014 February 2023 Comment (1768) of Ed Perry on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B2012023-02-14014 February 2023 Comment (1767) of Cheryl Gross on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B2002023-02-14014 February 2023 Comment (1766) of Cynthia Mcnamara on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1992023-02-14014 February 2023 Comment (1765) of Janet Sutton on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1982023-02-14014 February 2023 Comment (1764) of Norm Conrad on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; TRISO-X Special Nuclear Material License ML23136B1962023-02-14014 February 2023 Comment (1763) of Leigh Anne Lloveras on Behalf of Breakthrough Institute on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1952023-02-14014 February 2023 Comment (1762) of Nick Berezansky on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1942023-02-14014 February 2023 Comment (1761) of H. Rosenberg on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1852023-02-14014 February 2023 Comment (1753) of David Close on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1862023-02-14014 February 2023 Comment (1754) of Mary White on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1872023-02-14014 February 2023 Comment (1755) of S. Cook on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1932023-02-14014 February 2023 Comment (1760) of Molly Fleming on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1902023-02-14014 February 2023 Comment (1757) of M.L. Polak on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License ML23136B1882023-02-14014 February 2023 Comment (1756) of Axel Ringe on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Trisox Special Nuclear Material License 2023-02-20
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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
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