ML24145A073

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Comment (2) of Peter Hastings on Kairos Power, LLC on Kairos Power, LLC; Hermes 2; Draft Environmental Assessment and Draft Finding of No Significant Impact
ML24145A073
Person / Time
Site: Hermes  File:Kairos Power icon.png
Issue date: 05/17/2024
From: Hastings P
Kairos Power
To:
Office of Administration
References
89FR 2462 00002, NRC-2023-0138
Download: ML24145A073 (1)


Text

PUBLIC SUBMISSION As of: 5/24/24, 6:58 AM Received: May 17, 2024 Status: Pending_Post Tracking No. lwb-b26a-3fya Comments Due: May 28, 2024 Submission Type: API Docket: NRC-2023-0138 Kairos Power, LLC Receipt of Construction Permit Application Comment On: NRC-2023-0138-0005 Kairos Power, LLC; Hermes 2; Draft Environmental Assessment and Draft Finding of No Significant Impact Document: NRC-2023-0138-DRAFT-0002 Comment on FR Doc # 2024-08964 Submitter Information Email:bhughes@kairospower.com Organization:Kairos Power LLC General Comment Kairos Power appreciates the opportunity to provide comments on the referenced Hermes 2 Construction Permit Draft Environmental Assessment (DEA). Kairos Power offers the attached comments to provide clarification on a handful of minor points.

Attachments KP-NRC-2405-002 Kairos Power Comments on the Draft Environmental Assessment and Finding of No Significant Impact for the Hermes 2 Construction Permit Application 5/24/24, 6:59 AM blob:https://www.fdms.gov/e6f1e740-dce1-4573-acbd-4c487aef73ce blob:https://www.fdms.gov/e6f1e740-dce1-4573-acbd-4c487aef73ce 1/1 SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Antoinette Walker-Smith, Peyton Doub, Mary Neely Comment (2)

Publication Date:4/26/2024 Citation: 89 FR 32462

KP-NRC-2405-002 Kairos Power LLC www.kairospower.com 707 W Tower Ave, Suite A 5201 Hawking Dr SE 2115 Rexford Rd, Suite 325 Alameda, CA 94501 Albuquerque, NM 87106 Charlotte, NC 28211 May 17, 2024 Docket No. 50-611 Docket No. 50-612 US Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Kairos Power LLC Comments on the Draft Environmental Assessment and Finding of No Significant Impact for the Hermes 2 Construction Permit Application (Docket ID NRC-2023-0138)

References:

Nuclear Regulatory Commission, Environmental Assessment for the Construction Permit for the Kairos Hermes 2 Test Reactor-Draft Report for Comment, April 2024, (ML24103A002)

Kairos Power appreciates the opportunity to provide comments on the referenced Hermes 2 Construction Permit Draft Environmental Assessment (EA). Kairos Power concurs with the NRC staffs conclusion that:

In consideration of the results of the recent Hermes environmental impact statement (EIS), it was prudent to first prepare a draft EA to determine whether preparation of an EIS would be necessary, or whether a finding of no significant impact (FONSI) could be issued for the Hermes 2 construction permit; and On the basis of the draft EA, the proposed action would not significantly affect the quality of the human environment, a FONSI is appropriate, and an EIS is not necessary.

Kairos Power acknowledges the NRC staffs efforts to identify and implement innovative practices to make the regulatory process as efficient as possible. Kairos Power further encourages the continuation of such efforts, including extension of the use of EAs to the maximum extent practical, in order to enable the deployment of safe, clean, and reliable nuclear energy.

Additionally, Kairos Power offers the enclosed specific comments to provide clarification on a handful of minor points.

If you have any questions or need any additional information, please contact Marty Bryan at bryan@kairospower.com or (704) 317-7278, or Darrell Gardner at gardner@kairospower.com or (704) 769-1226.

Sincerely, Peter Hastings, PE Vice President, Regulatory Affairs and Quality

KP-NRC-2405-002 Page 2

Enclosure:

1) Comments on the Kairos Power Hermes 2 Test Reactor Construction Permit Draft Environmental Assessment xc (w/enclosure):

Joshua Borromeo, Chief, NRR Advanced Reactor Licensing Branch Daniel Barnhurst, Chief, NMSS, Environmental Project Management Branch Michael Orenak, Project Manager, NRR Advanced Reactor Licensing Branch Peyton Doub, Environmental Project Manager, NMSS, Environmental Review Branch Mary Richmond, Environmental Project Manager, NMSS, Environmental Review Branch

KP-NRC-2405-002 Comments on the Kairos Power Hermes 2 Test Reactor Construction Permit Draft Environmental Assessment (Non-Proprietary)

Comments on the Kairos Power Hermes 2 Test Reactor Construction Permit Draft Environmental Assessment Comment Number Draft Environmental Impact Statement Text and Location Comment 1

Page 1-3, Line 14: and prohibit groundwater extraction, consumption, exposure, or use, in any way.

Per quitclaim deed restriction 10 for the property (ML22060A114), these activities are prohibited without proper approval and authorization. Kairos Power suggests the phrase, without prior approval of the appropriate authorities, be added to this sentence.

2 Page 3-2, Line 30: and prohibit groundwater extraction, consumption, exposure, or use, in any way.

Per quitclaim deed restriction 10 for the property (ML22060A114), these activities are prohibited without proper approval and authorization. Kairos Power suggests the phrase, without prior approval of the appropriate authorities, be added to this sentence.

3 Page 3-26, Line 33: Of all 101 operations positions, 59 workers are expected to be required onsite during normal weekday operations (including nightshifts),

and the remaining 42 workers would cover weekend shifts (Kairos 2024-TN9866).

This sentence includes details on weekend shift workers that were not included in the Kairos Power response to NRC request for confirmation of information (RCI) SE-01, which was transmitted by letter dated April 12, 2024 (ML24103A242). Kairos Power requests that the wording in this sentence reflect the information provided in the response to RCI SE-01, such that the wording and the remaining 42 workers would cover weekend shifts be replaced with the RCI SE-01 response language, with fewer workers required on the weekend.

4 Page 3-32, Line 21: only a small volume of radioactive liquid effluent releases to sewer lines.

Kairos Power requests the phrase, in accordance with the limits specified in 10 CFR 20.2003, be added to this sentence.

5 Page 5-7, Line 14: These losses would irreversibly affect wildlife populations in the surrounding area noticeably, and any affected populations can be expected to subsequently recover.

Kairos Power believes, based on context and on the findings of this draft environmental assessment, that there may be an omission in this sentence. If this is accurate, Kairos Power requests that the sentence be revised to read: These losses would not irreversibly affect wildlife populations in the surrounding area noticeably, and any affected populations can be expected to subsequently recover.