ML23136B196

Comment (1763) of Leigh Anne Lloveras on Behalf of Breakthrough Institute on Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement; Triso–X Special Nuclear Material License

ML23136B196
Person / Time
Site:	Triso-X
Issue date:	02/14/2023
From:	Lloveras L Breakthrough Institute
To:	Caverly J Office of Nuclear Material Safety and Safeguards, Office of Administration
References
NRC-2022-0201, 87FR77146 01763
Download: ML23136B196 (1)

Text

file:///C/...eDrive%20-%20U.S.%20NRC/Desktop/NRC-2022-0201%202023-03-08%2012-04-27_docs/NRC-2022-0201-DRAFT-1763.html[3/28/2023 11:21:55 AM]

PUBLIC SUBMISSION As of: March 08, 2023 Received: February 14, 2023 Status: Pending_Post Tracking No. le4-t7hn-bxfh Comments Due: February 14, 2023 Submission Type: Web Docket: NRC-2022-0201 Notice of Intent to Conduct Scoping Process and Prepare Supplement to Draft Environmental Impact Statement TRISO-X Fuel Fabrication Facility Comment On: NRC-2022-0201-0001 Notice of Intent To Conduct Scoping Process and Prepare Environmental Impact Statement; TRISO-X Special Nuclear Material License Document: NRC-2022-0201-DRAFT-1763 Comment on FR Doc # 2022-27164 Submitter Information Email:leighanne@thebreakthrough.org Organization:The Breakthrough Institute General Comment See attached file(s)

Attachments TRISO-X EIS Scoping comment SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Jill Caverly, Robert Sun, Antoinette Walker-Smith, Mary Neely Comment (1763)

Publication Date: 12/16/2022 Citation: 87 FR 77146

February 14, 2023 Jill Caverly Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Comment on the scope of environmental review for the TRISO-X facility [Docket ID NRC-2022-0201].

The Breakthrough Institute (BTI) appreciates this opportunity to comment on the scope of environmental review for the TRISO-X Special Nuclear Material License and to express our support for the facilitys construction. BTI is an independent 501(c)(3) global research center that advocates for appropriate regulation and oversight of nuclear reactors to enable the new and continued use of safe and clean nuclear energy. BTI acts in the public interest and does not receive funding from industry.

When Congress passed the Nuclear Energy Innovation and Modernization Act of 2019, it mandated that the NRC modernize and streamline nuclear licensing and other regulatory procedures to enable the use of a new generation of smaller, safer nuclear reactor technologies that rely on a variety of fuels and fuel cycles. The importance to these new reactors of being able to access reliable, domestic fuel cannot be overstated -

among other benefits, the availability of domestic fuel will strengthen our national energy security by reducing dependence on foreign sources. Licensing this TRISO-X fuel facility would be a huge step in the right direction toward enabling the deployment of advanced reactors. As such, BTI encourages the NRC to consider the efficiency and timeliness of the environmental review during the scoping process for this facility.

In the scope of the EIS, in addition to considering the on-site impacts of the project, BTI encourages the NRC to consider the offsite, downstream effects of not building this fuel facility. Without the ability to obtain this fuel, certain advanced reactors will face even steeper difficulties with starting operations. The lack of clean, reliable nuclear energy on the grid will result in reduced grid reliability and greater levels of air pollution. Both of these cause serious harm to the general public and the environment. Alternative energy

sources result in greater impacts on the environment than nuclear energy through pollution,1 greater land use,2 or the need to build in resource-optimal locations instead of low-impact locations.

Further, nuclear reactors are crucial to meeting national carbon reduction goals. This new generation of advanced reactors, that rely on new fuel facilities like this one, opens up many promising possibilities for deep decarbonization - some technologies can be used for water desalination or to produce the heat needed for industrial processes. There are not many other viable ways to decarbonize these sectors.

In addition to the positive health and safety and environmental impacts of nuclear energy, the NRC should consider its economic benefits. Nuclear power plants provide both direct and indirect good-paying jobs in many areas of the economy.

When the NRC is considering the impact of building/not building this facility, the full breadth of impacts needs to be taken into account to meet the mandate in the Atomic Energy Act of enabling nuclear energy to make the maximum contribution to the general welfare.3 BTI appreciates the opportunity to express our support for the TRISO-X Special Nuclear Material facility and to comment on the scope of environmental review for the project.

Sincerely, Leigh Anne Lloveras Nuclear Energy Analyst The Breakthrough Institute 3 See Pub. law 83-703, Sec. 1(a).

2 See Figure 1 of Lovering J, et al. (2022) Land-use intensity of electricity production and tomorrows energy landscape.

PLoS ONE 17(7): e0270155. https://doi.org/10.1371/journal.pone.0270155 1 See Figure 48 of the United Nations ECEe report accessible here:

https://unece.org/sed/documents/2021/10/reports/life-cycle-assessment-electricity-generation-options