ML24105A000
| ML24105A000 | |
| Person / Time | |
|---|---|
| Site: | Hermes File:Kairos Power icon.png |
| Issue date: | 04/14/2024 |
| From: | NRC |
| To: | NRC/NRR/DANU |
| References | |
| Download: ML24105A000 (8) | |
Text
From:
Peyton Doub Sent:
Sunday, April 14, 2024 9:54 PM To:
Martin Bryan Cc:
Kairos-Hermes2PUBLICem Resource
Subject:
Environmental Audit Summary Report for Hermes 2 Attachments:
SUMMARY
REPORT ON THE ENVIRONMENTAL AUDIT OF HERMES 2.docx Marty:
Call me if you have any questions.
-Peyton J. Peyton Doub, PWS, CEP Environmental Scientist US Nuclear Regulatory Commission NMSS/REFS/ETRB1 Office TWFN T4-C09, Mailstop T4-B72 (240)529-4212 Peyton.Doub@nrc.gov
Hearing Identifier:
Kairos_Hermes2_CPDocs_Public Email Number:
11 Mail Envelope Properties (SJ0PR09MB9446F856DEE5F3C1D7E0571EFE092)
Subject:
Environmental Audit Summary Report for Hermes 2 Sent Date:
4/14/2024 9:53:41 PM Received Date:
4/14/2024 9:53:47 PM From:
Peyton Doub Created By:
Peyton.Doub@nrc.gov Recipients:
"Kairos-Hermes2PUBLICem Resource" <Kairos-Hermes2PUBLICem.Resource@nrc.gov>
Tracking Status: None "Martin Bryan" <bryan@kairospower.com>
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SUMMARY
REPORT ON THE ENVIRONMENTAL AUDIT OF HERMES 2.docx 44035 Options Priority:
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SUMMARY
REPORT ON THE ENVIRONMENTAL AUDIT OF KAIROS HERMES 2 TEST REACTOR CONSTRUCTION PERMIT APPLICATION 1.0
Background
The U.S. Nuclear Regulatory Commission (NRC) is currently reviewing an application from Kairos Power, LLC (Kairos) for a construction permit (CP) for a two-unit test reactor project termed Hermes 2 in Oak Ridge, Tennessee. The Hermes 2 project is proposed for a location on the same site where Kairos received a CP in 2023 to build a different test reactor termed Hermes. As part of its review for Hermes 2, the NRC is preparing an Environmental Assessment (EA). An audit was conducted from January 17, 2024, to March 21, 2024, to support the environmental review of the CP application. This report presents a summary of the information obtained from the audit.
1.1 Application Overview By letter dated July 14, 2023 (Agencywide Documents Access and Management System (ADAMS) ML23195A122), Kairos Power LLC (Kairos) submitted an Environmental Report (ER)
(ML23195A125) in support of the Hermes 2 CP application. By letter dated September 11, 2023, the NRC notified Kairos of its acceptance of the CP application for detailed review (ML23233A167). The NRC environmental staff is reviewing the information in the ER (ML23195A125) and other relevant environmental information following procedures in Title 10 of the Code of Federal Regulations (10 CFR) Part 51. Concurrently, the NRC safety staff is separately reviewing the information in the applicants Preliminary Safety Analysis Report (PSAR, ML23195A124) following procedures in 10 CFR Part 50. Once the NRC staff completes its environmental and safety reviews, it will recommend to the Commission whether to issue the CP.
1.2 Project and Site Overview The proposed action is for the NRC to issue a CP to Kairos authorizing construction of the two Hermes 2 test reactors. In its CP application, Kairos proposes to build and operate the Hermes 2 project to demonstrate key elements of the Kairos Power Fluoride Salt-Cooled, High TemperatureReactor technology for possible future commercial deployment. The technology is an advanced nuclear reactor technology that leverages TRI-structural ISOtropic (TRISO) particle fuel in pebble form combined with a low-pressure fluoride salt coolant. The purpose and design of the Hermes 2 test reactors are similar to those of the Hermes test reactor, which has already received a CP from the NRC in 2023. However, the Hermes 2 reactors contain some additional design features such as an intermediate cooling loop and the capacity to generate electricity, while still meeting the NRC regulatory definition for a test reactor. The proposed site (for both Hermes 2 and Hermes) is situated in the Heritage Center of the East Tennessee Technology Park, an industrial park established by the City of Oak Ridge, on land formerly owned by the U.S.
Department of Energy (DOE) for the Oak Ridge Gaseous Diffusion Plant. The Kairos Hermes ER provides the applicants analyses of the environmental impacts that could result from construction, operation, and decommissioning of the Hermes 2 test reactors at the proposed site.
Although the CP would only authorize construction of the Hermes 2 reactors, the environmental review must consider the potential environmental impacts from the complete Hermes 2 life cycle, without segmentation into individual project phases.
2.0 Audit Scope and Objectives During the environmental audit, the NRC staff discussed environmental matters related to land use and visual resources, air quality and noise, hydrogeology and surface water, terrestrial and aquatic ecology, cultural resources, socioeconomics and environmental justice, human health, non-radiological waste, uranium fuel cycle and radiological waste management, transportation of
radioactive material, postulated accidents, climate change, and alternatives. The audit allowed the staff to better understand the site, the proposed Hermes 2 reactor design, the environmental interfaces of the Hermes 2 project, and environmental modeling results in order to make appropriate environmental findings.
In its initial review of data and information within the corresponding context of the ER, the NRC staff identified a list of environmental information needs that would promote a better understanding of the detailed analysis and bases underlying the construction permit application. The staff provided these information needs to Kairos in advance of the audit in an environmental report audit plan (ML23353A069). Environmental audit activities consisted of document reviews and virtual meetings organized in advance, followed by a sequence of virtual meetings and phone calls necessary to address specific questions and comments. Most issues were addressed in prearranged virtual meetings on January 17 and 18, 2024 with a series of follow-on calls as necessary over the duration of the audit. All of the environmental information needs identified prior to the audit were resolved between the NRC staff and the applicant over the course of the audit.
Table 1 of this report presents a list of the NRC staff participating in the audit and their associated environmental review areas. Table 2 presents a list of Kairos staff and its contractors who participated in the audit.
Table 1. Review Areas with Assigned NRC Staff Team Member Role/Review Area Peyton Doub Environmental Project Manager, Land Use, Alternatives. Peer Review: Ecology Mary Richmond Environmental Project Manager Support Madelyn Nagel Air Quality and Noise, Socioeconomics and Environmental Justice, Climate Change, Other Miscellaneous Laura Willingham Peer Review: Air Quality Brian Glowacki Hydrogeology and Water Resources, Ecological Resources, Non-radiological Human Health Joseph Giacinto Peer Review: Water Resources and Hydrogeology; Climate Change Beau Goldstein Historic and Cultural Resources Doug McFarland, PNNL Historic and Cultural Resources Tara ONeill Historic and Cultural Resources Dave Anderson, PNNL Socioeconomics Lin Zeng, PNNL Socioeconomics Rao Tammara Radiological Human Health; Transportation of Radioactive Materials; Fuel Cycle and Radiological Waste Management; Postulated Accidents Donald Palmrose Peer Review: Radiological Materials, Transportation, and Accidents Table 2. List of Audit Participants for Kairos Power, LLC and AECOM Kairos Power, LLC AECOM Austin Clark Kevin Taylor Marty Bryan Steve Ahr Drew Peebles Darrell Gardner Wayne Massie (contractor)
3.0 Summary of Audit Activities and Issues Addressed The audit kickoff meeting was held virtually on January 17, 2024, from 1:00pm to 4:00pm. The entire audit team attended the first hour of the kickoff meeting, and the entire team was invited but not required to attend the remainder of the meeting as specific information needs were discussed. The discussion of specific information needs continued virtually for a second day from 3:00pm to 5:00pm on January 18, 2024. A series of shorter, focused meetings were held virtually as necessary over the remaining course of the audit to address specific information needs. These meetings were attended only by persons specifically interested in the information need under discussion.
Table 3 presents a tabulated summary of how the information needs presented to Kairos in the audit plan were addressed. In summary, 17 of the 25 audit items were closed through audit discussions. Eight items were resolved through the responses by Kairos to RCIs (ML24072A316).
4.0 Audit Closeout Meeting The audit was closed via a phone call between Peyton Doub of NRC and Marty Bryan of Kairos on March 21, 2024. The staff has determined that the information provided by Kairos through the audit contains all of the information needed from the applicant to conduct the review.
Table 3. Summary of Environmental Audit Information Need Resolution Informatio n Need ID ER Section Information Needed Resolution Site and Technical Overview ST-1 1.2 Provide update on anticipated schedule for beginning construction and operations of Hermes.
Closed Through Audit Discussion Cumulative Impacts (Multiple Review Areas)
CM 4.13 No Info Needs beyond those identified below for specific resources.
N/A Land Use and Visual Resources LU-1 4.1 Identify present status of site ownership.
Closed by RCI LU-01 LU-2 4.1 Estimate the combined area of land occupied by the Hermes 2 and Hermes projects.
Closed Through Audit Discussion LU-3 4.1 Indicate how the presence of the H2 structures may affect the views from the Key Observation Points addressed in the ER for the first Hermes reactor.
Closed by RCI LU-02 LU-4 App A Indicate the voltage and ROW length and width extending off of the Kairos site.
Closed Through Audit Discussion Air Quality and Noise AN-1 4.2 Identify in a table the total emissions of operations related equipment (similar to total emissions table for construction, Table 4.2-1).
Closed Through Audit Discussion
AN-2 4.2 Estimate the maximum noise level and duration that may be experienced at the nearest resident or other noise sensitive receptor.
Closed Through Audit Discussion AN-3 4.2 Describe how noise generation from the totality of the three Hermes reactors would be attenuated to less than 65 dBA. Could noise levels of 65 dBA from simultaneous operation of three reactors interact synergistically to produce higher levels? Is there mitigation that could attenuate the noise to less than 55 dBA, which is recognized by EPA as the preferred target?
Closed Through Audit Discussion Water Resources and Hydrogeology WR 4.3, 4.4 No Info Needs Identified N/A Ecological Resources EC 4.5 No Info Needs Identified N/A Historical and Cultural Resources HC-1 4.6 Because the Hermes 2 ER was completed before the cultural resources geoarchaeological reconnaissance investigation, which covers both the Hermes 1 and Hermes 2 undertakings and construction locations, the new information on cultural and historic resources from that report are not in the ER. Provide an executive summary of the reconnaissance geoarchaeological investigation, results, and regulatory findings, to supplement information provided by the ER to be added to the docket.
Closed by RCI HC-01 Socioeconomics and Environmental Justice SE-1 4.7, 4.12 Section 2.1 of the ER provides total estimated staff numbers for the construction, operation and decommission stages of the project. Provide additional information about the residence of employees for each stage (breakdown by county) and indicate the percentage of the in-migrating labor force.
Closed Through Audit Discussion SE-2 4.7, 4.12 Section 3.3.2.4 of the Hermes 2 ER discusses tax payment information. Provide tax payment estimates (property taxes, payment in lieu of taxes, etc.) of the proposed project for all construction, operational and decommissioning activities. Also add the analysis of the tax consequences compared to the total tax revenue in the county (ranges, percentages, etc.).
Closed Through Audit Discussion SE-3 4.7, 4.12 Section 2.1 of the Hermes 2 ER provided the total estimated staff numbers for the construction, operation and decommission stages of the proposed project. Provide the shift schedules for the construction, operation, and decommissioning workforce (both at regular time and peak times),
as well as the duration for the peak times. Also, Closed by RCI SE-01
clarify whether the number of full-time positions is a combination of full-time workers on weekdays and part-time workers during the weekends and later evenings.
SE-4 4.7, 4.12 Provide the most recent baseline traffic info for the major road accessing the site. Please also provide the traffic assessment about how construction, operation and decommission workforce, plus the shipments and deliveries of the Hermes 2 will affect the level of service (LOS) of the major road intersections.
Closed Through Audit Discussion SE-5 4.7, 4.12 Section 2.1 of the Hermes 2 ER provided the estimated information of the shipments and deliveries for the construction, operation and decommission stages of the proposed project.
Please further provide the delivery methods (trucks or other methods)? If trucks, indicate what kind of trucks, how many trucks will be needed, the load limits for the trucks, and the durations of the deliveries for the fuel, coolant and any other equipment.
Closed by RCI SE-02 Human Health: Non-Radiological HN-1 4.8.1 At time of construction of the Hermes 2 reactors, indicate whether there may be radiological or hazardous materials present on site resulting from construction and operation of the Hermes reactor.
Closed Through Audit Discussion HN-2 4.8.1 The EIS for construction of the Hermes reactor also uses 100 tons per year (TPY) as a bounding figure, stating that air emission would be less than the 100 TPY allowed by the Clean Air Act. Indicate whether the combined air emissions could exceed 100 TPY if the Hermes reactor and the two Hermes 2 reactors were under construction at the same time.
Closed Through Audit Discussion HN-3 4.8.1 Indicate whether control measures would be implemented to reduce the electrical hazard posed by the transmission lines to workers.
Closed Through Audit Discussion Human Health: Radiological HR-1 4.8.2 Indicate the estimated Hermes 2 construction worker dose from the operation of the Hermes test reactor.
Closed by RCI HR-01 HR-2 4.8.2 Indicate the estimated doses from the operation of Hermes 2 on workers participating in the decommissioning of the Hermes test reactor.
Closed by RCI HR-02 Nonradiological Waste: Non-Radiological NW-1 4.9 Indicate whether the two Hermes 2 reactors would be separately registered as small quantity generators (SQGs) under the Resource Conservation and Recovery Act (RCRA) or included in that for the original Hermes test reactor.
Closed Through Audit Discussion NW-2 4.9 Indicate whether there would be waste streams during operations for anhydrous hydrogen fluoride, Flibe, and BeNaF.
Closed Through Audit Discussion
Fuel Cycle and Radiological Waste Management FC-1 Chapter 2 Discuss potential sources of HALEU needed to operate the Hermes 2 reactors, recognizing that no reprocessing facility is currently in operation in the United States.
Closed Through Audit Discussion FC-2 Chapter 2 Provide clarification on how 46 annual shipments of Dry Active Waste (DAW) is bounding for impact assessment for operation of two Hermes 2 reactor.
The ER for the Hermes reactor indicated a larger quantity of DAW for just one reactor.
Closed Through Audit Discussion Transportation of Radioactive Material TR-1 4.10 Provide clarification on how the ER estimates six truck shipments for shipping a years supply of fuel for the Hermes 2 reactors.
Closed by RCI TR-01 TR-2 4.10 Provide clarification why 23 shipments per year of low-level radioactive waste can be used to assess impacts from operations of the two Hermes 2 reactors when it is the same estimate used for assessment of only the one Hermes reactor.
Closed Through Audit Discussion TR-3 4.10 Provide an analysis of the effects of transportation of spent TRISO fuel.
Closed Through Audit Discussion Postulated Accidents AC 4.11 No Info Needs Identified N/A Alternatives AL Chapter 5 No Info Needs Identified N/A