ML23129A772
| ML23129A772 | |
| Person / Time | |
|---|---|
| Site: | Hermes File:Kairos Power icon.png |
| Issue date: | 05/08/2023 |
| From: | NRC |
| To: | NRC/NRR/DANU |
| References | |
| Download: ML23129A772 (16) | |
Text
From:
Jennifer Davis Sent:
Monday, May 8, 2023 6:46 PM To:
Kelley Reid; Jennifer Barnett Cc:
Tami Dozier; Peyton Doub; O'Neil, Tara (tara.oneil@pnnl.gov); Mcfarland, Douglas P; Kenneth Erwin
Subject:
Consultation Update for THC and TDOA Re: Kairos Hermes Test Reactor, Oak Ridge, TN (Project # SHPO0001832)
Attachments:
ML23064A002 (4).pdf Kelley and Jennifer, As a follow-up to my February 13, 2023 email, we wanted to provide your offices with an update regarding our NHPA Section 106 consultation efforts.
On October 13, 2022, a consulting Tribe forwarded questions to the NRC inquiring if the APE had been subject to an archeological survey, and requested to review the Archaeological Resources Monitoring and Unanticipated Discovery Plan. The tribe also requested to view THCs comment letter. Prior to receiving the consulting Tribes formal comment letter, NRC staff requested additional information from DOE related to site geology, geomorphology, and the scope and extent of prior disturbance (i.e., total area and depth of disturbance) on the K-31 and K-33 site.
DOE provided NRC with additional information in Mid-November, and NRC staff met with DOE on December 21, 2022, to discuss NRCs interpretations of previous site disturbance and the potential for deeply buried paleosols on the K-33/K-31 site (see attached presentation). DOE confirmed that surface material in the proposed Hermes reactor footprint and surrounding areas was removed (cut) during original construction of K-33, and corrected the previous understanding that the top 10 feet of soil and sediment were not removed as part of remediation efforts. Additionally, DOE confirmed that there are still buried alluvial sediments, and other areas, that could contain paleosols that may or may not have been cut into during construction of K-33.
NRC staff sent additional information obtained from DOE-ORR for the consulting Tribes review on December 1, 2022. On December 6, 2022, the consulting Tribe submitted formal comments requesting that a cultural resources survey be conducted for the proposed project. In its letter, the Tribe also informed NRC of its interest in acting as a consulting party, and requested that the NRC include its office regarding the development of Kairos Archaeological Resources Monitoring and Unanticipated Discovery Plan for the Kairos site. Additionally, the consulting Tribe requested government-to-government consultation with the NRC.
Based on discussions with the NRC staff, Kairos submitted supplemental information on April 20th, 2023. Kairos submittal included a draft Archaeological Resources Monitoring and Unanticipated Discovery Plan, cultural resources memorandum, and geomorphological report for NRC and the consulting Tribes review.
We are planning to meet with the consulting Tribe within the week, and will circle back with you afterwards. If you would like to discuss further, please let me know and I can set up a Teams meeting.
Thank you,
Jennifer Jennifer A. Davis Senior Environmental Project Manager Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission (301) 415-3835
Hearing Identifier:
KairosPower_CPDocs_Public Email Number:
37 Mail Envelope Properties (DM8PR09MB735286680ACA9497994DDD1985719)
Subject:
Consultation Update for THC and TDOA Re Kairos Hermes Test Reactor, Oak Ridge, TN (Project # SHPO0001832)
Sent Date:
5/8/2023 6:45:50 PM Received Date:
5/8/2023 6:45:56 PM From:
Jennifer Davis Created By:
Jennifer.Davis@nrc.gov Recipients:
"Tami Dozier" <Tamsen.Dozier@nrc.gov>
Tracking Status: None "Peyton Doub" <Peyton.Doub@nrc.gov>
Tracking Status: None "O'Neil, Tara (tara.oneil@pnnl.gov)" <tara.oneil@pnnl.gov>
Tracking Status: None "Mcfarland, Douglas P" <douglas.mcfarland@pnnl.gov>
Tracking Status: None "Kenneth Erwin" <Kenneth.Erwin@nrc.gov>
Tracking Status: None "Kelley Reid" <Kelley.Reid@tn.gov>
Tracking Status: None "Jennifer Barnett" <Jennifer.Barnett@tn.gov>
Tracking Status: None Post Office:
DM8PR09MB7352.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 2901 5/8/2023 6:45:56 PM ML23064A002 (4).pdf 2389578 Options Priority:
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No Reply Requested:
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From:
Tami Dozier Sent:
Sunday, March 5, 2023 9:00 AM To:
Peyton Doub; Kenneth Erwin Cc:
KairosPower-CPDocsPEm Resource; Jennifer Davis; O'Neil, Tara
Subject:
Information related to Government to Government Consultations - Section 106 of the National Historic Preservation Act Attachments:
Kairos Cultural Resources Status Feb 2023_Final.pdf Ken and Peyton Attached is information provided by the cultural reviewers to support the Government to Government Consultations under the National Historic Preservation Act (ML23031A036).
Tamsen Dozier Environmental Project Manager Nuclear Regulatory Commission 301-415-2272 (o)
From: O'Neil, Tara <tara.oneil@pnnl.gov>
Sent: Friday, February 24, 2023 4:34 PM To: Tami Dozier <Tamsen.Dozier@nrc.gov>
Cc: Peyton Doub <Peyton.Doub@nrc.gov>; Jennifer Davis <Jennifer.Davis@nrc.gov>; Mcfarland, Douglas P <douglas.mcfarland@pnnl.gov>; Saulsbury, Bo <james.saulsbury@pnnl.gov>; Kautzky, Kevin J
<Kevin.Kautzky@pnnl.gov>
Subject:
[External_Sender] Kairos Cultural Resources Status - Slides Requested Hi Tami, Attached are the slides NRC management requested we pull together to support discussions around NHPA Section 106 consultation and the status of cultural resources for the Kairos Hermes Test Reactor environmental review effort.
These slides have gone through PNNLs information release process and have been marked as unlimited distribution.
Please let me know if you have questions.
Thank you, Tara Tara K. ONeil Nuclear Regulatory Sub-Sector, Advisor Energy and Environment Directorate Pacific Northwest National Laboratory tara.oneil@pnnl.gov http://nuclearenergy.pnnl.gov/
Hearing Identifier:
KairosPower_CPDocs_Public Email Number:
33 Mail Envelope Properties (BY3PR09MB75854EF13F994FA8D8C4296FF4B19)
Subject:
Information related to Government to Government Consultations - Section 106 of the National Historic Preservation Act Sent Date:
3/5/2023 9:00:05 AM Received Date:
3/5/2023 9:00:10 AM From:
Tami Dozier Created By:
Tamsen.Dozier@nrc.gov Recipients:
"KairosPower-CPDocsPEm Resource" <KairosPower-CPDocsPEm.Resource@nrc.gov>
Tracking Status: None "Jennifer Davis" <Jennifer.Davis@nrc.gov>
Tracking Status: None "O'Neil, Tara" <tara.oneil@pnnl.gov>
Tracking Status: None "Peyton Doub" <Peyton.Doub@nrc.gov>
Tracking Status: None "Kenneth Erwin" <Kenneth.Erwin@nrc.gov>
Tracking Status: None Post Office:
BY3PR09MB7585.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1498 3/5/2023 9:00:10 AM Kairos Cultural Resources Status Feb 2023_Final.pdf 2252447 Options Priority:
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No Reply Requested:
No Sensitivity:
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Kairos Site History and Subsurface Stratigraphy at the Hermes Site Doug McFarland February 2023 PNNL-SA-180686 Unlimited Distribution
Proposed Action The proposed action is for the NRC to issue a construction permit (CP) to Kairos authorizing construction of the Hermes reactor.
Construction would temporarily disturb approximately 138 ac of previously developed industrial lands on the site, but the disturbance would not encroach into areas of natural vegetation (Kairos 2021).
The applicant anticipates an excavation depth of approximately 30 ft below a finished grade of 765 ft for the Reactor Building and the Auxiliary Systems Building. Other ancillary buildings would be excavated to an estimated depth of approximately 10 ft below grade.
Section 106 Consultation
- Consulting tribe recommends that a cultural resources survey be conducted for this project Tribe requests to be included in the development of the Archaeological Monitoring and Discovery Plan
- No surface cultural resources are expected, but there is the potential for deeply buried cultural resources
- Clinch River - TVA project nearby Geomorphological study confirmed potential for deeply buried cultural resources Same ridge and valley formation Similar consulting parties 3
Sediments, soils, and archaeology There is a difference between sediments, soils, and paleosols as defined by archaeologists, relevant to the proposed action.
- Soils are sediments that have weathered in place over long periods of time, undergoing chemical processes which create horizontal stratification, or soil horizons.
- Sediments are either new lithic material from the mechanical weathering of rocks (silt, sand, gravel, pebbles, etc.), or they could be from soil material that has been eroded and transported and not weathered in place. They are deposited over the top of one another, creating horizontal stratification.
- Soils form in sediments.
- Archaeological features and artifacts are usually associated with old soil surfaces.
- Paleosols are a term used to define a soil that formed on a landscape of the past. Within the field of archaeology this term is usually associated with intact soils and associated horizons (including the soil surface) which have, over time, been buried.
4
Reading Geotechnical Profile Views of K-33 Area Fill Profile data comes from boreholes. Boreholes are the vertical lines in the profile graphic (above),
and corresponding red and green dots in plan view map inset (below). Boreholes are from both groundwater monitoring and geotechnical investigation, not archaeological investigation.
Example of profile map
Detailed cross sections from present day geotechnical analysis results from March of 2021 (red line in plan view map is profile location). Kairos 2021 Preliminary Safety Analysis Report (ML21272A375)
From Kairos 2021 Preliminary Safety Analysis Report (ML21272A375)
Interpretations and relevant observations
- There is some inconsistency in the geotechnical information provided by Department of Energy. Geotechnical report indicates 12+ feet of fill, but the meeting on 12/21/22 suggested that fill looks like the native soils/sediments on site, and it is sometimes hard to tell them apart.
- The weathered bedrock and Residium are the remains or partial remains of a soil column, now buried by fill and other material.
- The alluvial clay could be the remains of an old stream/river terrace and associated soil.
- Construction activities (pilings and footings) may be vertically passing through both of these earthen environments (alluvial clay and associated soil surface, and weathered Residium. Both are possible soil columns).
- Without knowing where, vertically in the soil column (to the left), that these earth materials came from, we cannot definitively say there is or is not potential for these sediments/soils to contain intact, deeply buried cultural material.
- It is important to note that at the nearby Clinch River site "geomorphic analysis reveals very high potential for buried archeological sites... and that Artifacts could occur down to 5 to 6 m deep. This was partially determined by soil ages in the TVA geomorphology report. The Kairos site has the same basic geology and hydrology as the Clinch River site.
Key Questions
- 1. Has the presence or absence of INTACT paleosols (deeply buried soil horizons and soil surfaces) been confirmed on site?
- 2. Can the location and depth of pilings and footings be delineated on the above safety geotechnical profiles (A-A and B-B) and associated plan view maps?
- 3. Has the proposed action changed?
- 4. Will there be activities near the shoreline that cause ground disturbance? Can these be delineated on associated plan view maps?
Thank you 10