ML24214A327

Environmental Assessment and Finding of No Significant Impact for the Construction Permits for the Kairos Hermes 2 Test Reactors - Draft Report for Comment

ML24214A327
Person / Time
Site:	05000611, 05000612
Issue date:	04/30/2024
From:	Office of Nuclear Material Safety and Safeguards
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Download: ML24214A327 (1)

Text

Tennessee Ecological Services Field Office FWS Log No: 2024-0055395

The Service concurs with your effect determination(s) for resources protected by the Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.). This finding fulfills the requirements of the Act. If project design changes are made or new information becomes available, please submit new plans for review.

Field Supervisor Date ML24103A002

Environmental Assessment and Finding of No Significant Impact for the Construction Permits for the Kairos Hermes 2 Test Reactors

Draft Report for Comment

Completed: April 2024

Environmental Center of Expertise Division of Rulemaking, Environmental, and Financial Support

Office of Nuclear Material Safety and Safeguards

ML24103A002

Environmental Assessment and Finding of No Significant Impact for the Construction Permits for the Kairos Hermes 2 Test Reactors

Draft Report for Comment

Completed: April 2024

Office of Nuclear Material Safety and Safeguards

1 COMMENTS ON DRAFT REPORT

2 Any interested party may submit comments on this report for consideration by the NRC staff.

3 Comments may be accompanied by additional relevant information or supporting data. Please 4 specify Docket ID NRC-2023-0138 in your comments, and send them by the end of the 5 comment period specified in the Federal Register notice announcing the availability of this 6 report.

7 You may submit comments by using any of the following methods; however, the NRC 8 encourages electronic comment submission through the Federal rulemaking website:

9

• Federal rulemaking website: Go to https://regulations.gov and search for 10 Docket ID NRC-2023-0138.

11

• Email: Comments may be submitted to the NRC electronically using the email address:

12 Kairos-Hermes2Environmental@nrc.gov.

13

• Mail comments to: Office of Administration, Mail Stop: TWFN-7-A60M, U.S. Nuclear 14 Regulatory Commission, Washington, DC 20555-0001, ATTN: Program Management, 15 Announcements and Editing Staff.

16 For any questions about the material in this report, please contact: Peyton Doub, telephone:

17 301-415-6703; email: Peyton.Doub@nrc.gov or Mary Richmond, telephone: 301-415-7218; 18 email: Mary.Richmond@nrc.gov. Both are staff of the Office of Nuclear Material Safety and 19 Safeguards at the U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

20 The NRC cautions you not to include identifying or contact information that you do not want to 21 be publicly disclosed in your comment submission. The NRC will post all comment submissions 22 at https://www.regulations.gov as well as enter the comment submissions into the Agencywide 23 Documents Access and Management System (ADAMS). The NRC does not routinely edit 24 comment submissions to remove identifying or contact information.

25 If you are requesting or aggregating comments from other persons for submission to the NRC, 26 then you should inform those persons not to include identifying or contact information that they 27 do not want to be publicly disclosed in their comment submission. Your request should state 28 that the NRC does not routinely edit comment submissions to remove such information before 29 making the comment submissions available to the public or entering the comment into ADAMS.

30

1 COVER SHEET

2 Responsible Agency: U.S. Nuclear Regulatory Commission

3

Title:

Environmental Assessment for the Construction Permit for the Kairos Hermes 2 Test Reactors

4 5 ABSTRACT

6 The draft environmental assessment (EA) describes the environmental review conducted by 7 U.S. Nuclear Regulatory Commission (NRC) staff for an application by Kairos Power, LLC 8 (Kairos) for construction permits under Title 10 of the Code of Federal Regulations Part 50, 9 allowing construction of two non-power test reactors termed Hermes 2 on a 185-acre site in Oak 10 Ridge, Tennessee. Hermes 2 would be built on the same site as Hermes, another non -power 11 test reactor for which Kairos has already received a construction permit from the NRC. As with 12 Hermes, Kairos plans to build and operate Hermes 2 to demonstrate key elements of the Kairos 13 Power Fluoride Salt-Cooled, High Temperature Reactor technology for possible future 14 commercial deployment. Each Hermes 2 reactor would be of similar size and design as the 15 Hermes reactor but would include specific design differences. The draft EA follows procedures 16 in 10 CFR 51.30, Environmental assessment, and 10 CFR 51.31, Determinations based on 17 environmental assessment, which are NRCs regulations for preparing EAs to implement the 18 National Environmental Policy Act of 1969. The NRC staff concludes that the potential direct, 19 indirect, and cumulative environmental impacts from Hermes 2 would not be significant and has 20 determined that a draft Finding of No Significant Impact appears warranted.

iii

1 TABLE OF CONTENTS

2 ABSTRACT ................................................................................................................... iii

3 TABLE OF CONTENTS .................................................................................................. v

4 LIST OF FIGURES......................................................................................................... xi

5 LIST OF TABLES ........................................................................................................ xiii

6 EXECUTIVE

SUMMARY

.............................................................................................. xv

7 ABBREVIATIONS AND ACRONYMS ....................................................................... xxiii

8 1 INTRODUCTION ................................................................................................. 1-1 9 1.1 The Proposed Federal Action ..............................................................................1-1 10 1.2 Purpose and Need ...............................................................................................1-3 11 1.3 The NRC Application Review ...............................................................................1-4 12 1.4 Regulatory Provisions, Permits, and Required Consultations .............................. 1-7 13 1.5 Preconstruction Activities .....................................................................................1-7 14 1.6 Report Contents ..................................................................................................1-8

15 2 PROPOSED PROJECT ...................................................................................... 2-1 16 2.1 Project Overview .................................................................................................2-1 17 2.2 Site Location and Layout .....................................................................................2-1 18 2.3 Site Workers and Vehicular Deliveries ................................ .................................2-2 19 2.4 Equipment and Material Usage ................................ ............................................2-2 20 2.5 Water Consumption and Treatment ................................ .....................................2-2 21 2.6 Cooling and Heat Removal Systems................................ ....................................2-3 22 2.7 Waste Systems ....................................................................................................2-3 23 2.8 Storage, Treatment, and Transportation of Radioactive and Nonradioactive 24 Materials ..............................................................................................................2-4

25 3 AFFECTED ENVIRONMENT AND ENVIRONMENTAL IMPACTS .................... 3-1 26 3.1 Land Use and Visual Resources ................................ ..........................................3-2 27 3.1.1 Affected Environment ............................................................................3-2 28 3.1.2 Environmental Impacts of Construction ................................ .................3-3 29 3.1.3 Environmental Impacts of Operation .....................................................3-3 30 3.1.4 Environmental Impacts of Decommissioning ................................ .........3-4 31 3.1.5 Cumulative Impacts ...............................................................................3-4 32 3.1.6 Conclusions ..........................................................................................3-4 33 3.2 Air Quality and Noise ...........................................................................................3-4 34 3.2.1 Affected Environment ............................................................................3-4

v 1 3.2.1.1 Climatology and Meteorology .............................................3-4 2 3.2.1.2 Air Quality ...........................................................................3-5 3 3.2.1.3 Noise ..................................................................................3-6 4 3.2.2 Environmental Impacts of Construction ................................ .................3-6 5 3.2.2.1 Air Quality ...........................................................................3-6 6 3.2.2.2 Noise ..................................................................................3-7 7 3.2.3 Environmental Impacts of Operation .....................................................3-7 8 3.2.3.1 Air Quality ...........................................................................3-7 9 3.2.3.2 Noise ..................................................................................3-8 10 3.2.4 Environmental Impacts of Decommissioning ................................ .........3-8 11 3.2.5 Cumulative Impacts ...............................................................................3-8 12 3.2.6 Conclusions ..........................................................................................3-9 13 3.3 Hydrogeology and Water Resources ................................ ...................................3-9 14 3.3.1 Hydrogeology ........................................................................................3-9 15 3.3.1.1 Affected Environment .........................................................3-9 16 3.3.1.2 Environmental Impacts of Construction .............................. 3-9 17 3.3.1.3 Environmental Consequences of Operation ..................... 3-10 18 3.3.1.4 Environmental Consequences of Decommissioning ......... 3-10 19 3.3.1.5 Cumulative Impacts .......................................................... 3-10 20 3.3.1.6 Conclusions ...................................................................... 3-11 21 3.3.2 Water Resources ................................ ................................................ 3-11 22 3.3.2.1 Affected Environment ....................................................... 3-11 23 3.3.2.2 Environmental Consequences of Construction ................. 3-11 24 3.3.2.3 Environmental Consequences of Operation ..................... 3-12 25 3.3.2.4 Environmental Consequences of Decommissioning ......... 3-12 26 3.3.2.5 Cumulative Impacts .......................................................... 3-12 27 3.3.2.6 Conclusion ....................................................................... 3-13 28 3.4 Ecological Resources ........................................................................................ 3-13 29 3.4.1 Affected Environment ................................ .......................................... 3-13 30 3.4.2 Environmental Impacts of Construction ................................ ............... 3-14 31 3.4.3 Environmental Impacts of Operations ................................ .................. 3-14 32 3.4.4 Environmental Consequences of Decommissioning ............................ 3-15 33 3.4.5 Cumulative Impacts ............................................................................. 3-15 34 3.4.6 Conclusions ........................................................................................ 3-15 35 3.5 Historic and Cultural Resources ................................ ......................................... 3-18 36 3.5.1 Affected Environment ................................ .......................................... 3-18 37 3.5.1.1 Cultural Background ......................................................... 3-18 38 3.5.1.2 Historic and Cultural Resources at the Kairos Site ........... 3-18 39 3.5.1.3 Traditional Cultural Properties .......................................... 3-20 40 3.5.1.4 Consultation ..................................................................... 3-20 41 3.5.2 Environmental Impacts of Construction ................................ ............... 3-20

vi 1 3.5.3 Environmental Impacts of Operation ................................................... 3-21 2 3.5.4 Environmental Impacts of Decommissioning ................................ ....... 3-21 3 3.5.5 Cumulative Impacts ............................................................................. 3-22 4 3.5.6 Conclusions ........................................................................................ 3-22 5 3.6 Socioeconomics and Environmental Justice ...................................................... 3-23 6 3.6.1 Affected Environment .......................................................................... 3-23 7 3.6.1.1 Socioeconomics ............................................................... 3-23 8 3.6.1.2 Environmental Justice ...................................................... 3-25 9 3.6.2 Environmental Impacts of Construction ................................ ............... 3-25 10 3.6.2.1 Socioeconomics ............................................................... 3-25 11 3.6.2.2 Environmental Justice ...................................................... 3-26 12 3.6.3 Environmental Impacts of Operation ................................................... 3-26 13 3.6.3.1 Socioeconomics ............................................................... 3-26 14 3.6.3.2 Environmental Justice ...................................................... 3-27 15 3.6.4 Environmental Impacts of Decommissioning ................................ ....... 3-27 16 3.6.4.1 Socioeconomics ............................................................... 3-27 17 3.6.4.2 Environmental Justice ...................................................... 3-27 18 3.6.5 Cumulative Impacts ............................................................................. 3-27 19 3.6.6 Conclusions ........................................................................................ 3-28 20 3.7 Human Health .................................................................................................... 3-28 21 3.7.1 Nonradiological Human Health ............................................................ 3-28 22 3.7.1.1 Affected Environment ....................................................... 3-28 23 3.7.1.2 Environmental Consequences of Construction ................. 3-28 24 3.7.1.3 Environmental Consequences of Operation ..................... 3-29 25 3.7.1.4 Environmental Consequences of Decommissioning ......... 3-29 26 3.7.1.5 Cumulative Impacts .......................................................... 3-29 27 3.7.1.6 Conclusions ...................................................................... 3-30 28 3.7.2 Radiological Human Health ................................ ................................. 3-30 29 3.7.2.1 Affected Environment ....................................................... 3-30 30 3.7.2.2 Environmental Impacts of Construction ............................ 3-31 31 3.7.2.3 Environmental Impacts of Operation ................................ . 3-31 32 3.7.2.4 Environmental Impacts of Decommissioning .................... 3-33 33 3.7.2.5 Cumulative Impacts .......................................................... 3-34 34 3.7.2.6 Conclusions ...................................................................... 3-34 35 3.8 Nonradiological Waste ....................................................................................... 3-35 36 3.8.1 Affected Environment .......................................................................... 3-35 37 3.8.2 Environmental Impacts of Construction ................................ ............... 3-35 38 3.8.3 Environmental Impacts of Operation ................................................... 3-35 39 3.8.4 Environmental Impacts of Decommissioning ................................ ....... 3-36 40 3.8.5 Cumulative Impacts ............................................................................. 3-36 41 3.8.6 Conclusions ........................................................................................ 3-36

vii 1 3.9 Uranium Fuel Cycle and Waste Management .................................................... 3-36 2 3.9.1 Uranium Fuel Cycle ............................................................................. 3-36 3 3.9.2 Radiological Waste Management ................................ ........................ 3-37 4 3.9.3 Conclusions ........................................................................................ 3-38 5 3.10 Transportation of Radioactive Material ................................ ............................... 3-39 6 3.10.1 Environmental Impacts of Operation ................................................... 3-39 7 3.10.2 Environmental Impacts from Decommissioning ................................... 3-40 8 3.10.3 Conclusions ........................................................................................ 3-41 9 3.11 Postulated Accidents ......................................................................................... 3-41 10 3.11.1 Environmental Impacts of Operation ................................................... 3-41 11 3.11.2 Cumulative Impacts ............................................................................. 3-42 12 3.11.3 Conclusions ........................................................................................ 3-43 13 3.12 Climate Change ................................................................................................. 3-43

14 4 ALTERNATIVES ................................................................................................. 4-1 15 4.1 No-Action Alternative ...........................................................................................4-1 16 4.2 Site Alternatives ...................................................................................................4-2 17 4.2.1 Process for Identifying Reasonable Alternative Sites ............................4-2 18 4.2.2 Affected Environment and Environmental Consequences for Eagle 19 Rock Site...............................................................................................4-2 20 4.2.2.1 Affected Environment: ........................................................4-2 21 4.2.2.2 Environmental Consequences of Construction ...................4-4 22 4.2.2.3 Environmental Consequences of Operation .......................4-4 23 4.2.2.4 Environmental Consequences of Decommissioning ...........4-5 24 4.2.2.5 Cumulative Impacts ............................................................4-5 25 4.2.2.6 Conclusions ........................................................................4-5 26 4.3 Cost-Benefit of the Alternatives ............................................................................4-6 27 4.4 Comparison of the Potential Environmental Impacts ................................ ............4-6

28 5 CONCLUSIONS AND RECOMMENDATION ..................................................... 5-1 29 5.1 Environmental Impacts of the Proposed Action ................................ ....................5-1 30 5.2 Comparison of Alternatives ..................................................................................5-4 31 5.3 Resource Commitments ......................................................................................5-5 32 5.3.1 Unavoidable Adverse Environmental Impacts .......................................5-5 33 5.3.2 Relationship Between Local Short-Term Uses of the Environment 34 and Maintenance and Enhancement of Long-Term Productivity ............5-5 35 5.3.3 Irreversible and Irretrievable Commitment of Resources .......................5-6 36 5.3.4 Unresolved Conflicts .............................................................................5-7 37 5.4 Recommendation.................................................................................................5-7

38 6 DRAFT FINDING OF NO SIGNIFICANT IMPACT .............................................. 6-1

39 7 REFERENCES .................................................................................................... 7-1

viii 1 APPENDIX A LIST OF PREPARERS ...................................................................... A-1

2 APPENDIX B AGENCIES, ORGANIZATIONS, TRIBES, AND 3 INDIVIDUALS CONTACTED ............................................................. B-1

4 APPENDIX C CHRONOLOGY OF ENVIRONMENTAL REVIEW 5 CORRESPONDENCE ....................................................................... C-1

6 APPENDIX D REGULATORY COMPLIANCE AND LIST OF FEDERAL, 7 STATE, AND LOCAL PERMITS AND APPROVALS ....................... D-1

8 APPENDIX E GREENHOUSE GAS EMISSIONS ESTIMATES FOR A 9 REFERENCE 1,000 MWE REACTOR AND THE HERMES 2 10 TEST REACTOR ................................................................................E-1

11 APPENDIX F PAST, PRESENT, AND REASONABLY FORESEEABLE 12 PROJECTS AND OTHER ACTIONS CONSIDERED IN THE 13 CUMULATIVE EFFECTS ANALYSIS ................................................ F-1

ix

1 LIST OF FIGURES

2 Figure 1-1 Hermes 2 Reactor Site ......................................................................................1-2 3 Figure 4-1 Location of the Eagle Rock Site ........................................................................4-3

xi

1 LIST OF TABLES

2 Table 1-1 List of Related NEPA Documents .....................................................................1-6 3 Table 3-1 Total Estimated National Ambient Air Quality Emissions During 4 Construction and Operations ............................................................................3-5 5 Table 3-2 Species with Regulatory Status under the Federal ESA ................................ .. 3-14 6 Table 3-3 Biological Evaluation of Federally Listed Species from Proposed Kairos 7 Hermes 2 Project ............................................................................................ 3-16 8 Table 3-4 Demographic Profile of the Population in the Region of Influence in 2020 ...... 3-23 9 Table 3-5 Estimated Income Information for the Socioeconomic ROI ............................. 3-24 10 Table 3-6 Housing in the ROI .......................................................................................... 3-24 11 Table 5-1 Summary of Environmental Impacts from Construction, Operation, and 12 Decommissioning of Hermes 2 .........................................................................5-1

xiii

1 EXECUTIVE

SUMMARY

2 BACKGROUND

3 By letter dated July 14, 2023, Kairos Power LLC (Kairos) submitted an application to the 4 U.S. Nuclear Regulatory Commission (NRC) for construction permits (CP) pursuant to 5 Title 10 of the Code of Federal Regulations (10 CFR) Part 50 (TN249). The CPs would allow 6 construction of two non-power test reactors termed Hermes 2 on a 185-acre (ac) site located in 7 Oak Ridge, Tennessee. Kairos proposes to build the two Hermes 2 reactors on the same site 8 for which they received a CP in 2023 to build another non-power test reactor of similar design, 9 termed Hermes. Although the NRC issued a CP for Hermes in 2023 (NRC 2023-TN9771),

10 Kairos has not yet started construction. Hermes and Hermes 2 are two separate test reactor 11 projects, each requiring a separate CP from the NRC.

12 Section 104 of the Atomic Energy Act of 1954, as amended, (TN663) and its implementing 13 regulations authorize the NRC to issue CPs for testing facilities. To issue a CP, the NRC is 14 required to consider the environmental impacts of the proposed action under the National 15 Environmental Policy Act of 1969 (NEPA) (TN661). The NRCs environmental protection 16 regulations that implement NEPA in 10 CFR Part 51 (TN250) identify actions for which the NRC 17 prepares an environmental impact statement (EIS). CPs for test reactors are an action identified 18 as requiring an EIS. However, based on a review of the ER submitted as part of the CP 19 application for Hermes 2 and the results of the EIS recently issued for Hermes 1, the NRC staff 20 concluded that it would be prudent to first prepare a draft environmental assessment (EA) to 21 determine whether preparation of an EIS would be necessary or whether a finding of no 22 significant impact (FONSI) could be issued for Hermes 2 based on factors unique to the 23 Hermes 2 CP application. These factors include (1) the similar design of Hermes 2 and Hermes, 24 (2) the proposed siting of Hermes 2 within a few hundred feet of Hermes, (3) the industrial 25 nature and heavy prior disturbance of the site, (4) the recent thorough NEPA review performed 26 by the NRC staff as published in its final EIS for Hermes, and (5) the staffs final EIS for Hermes 27 covering the same site as Hermes 2 and documenting all impacts as SMALL. The staff has 28 made a preliminary determination that the proposed action would not significantly affect the 29 quality of the human environment and, therefore, a draft FONSI appears warranted.

30 The staff will consider comments received on the draft EA and draft FONSI over a 30-day public 31 comment period from Federal, State, local, and Tribal officials, and members of the public. After 32 consideration of these public comments, the NRC staff will make a final determination as to 33 whether preparation of an EIS is necessary or whether a FONSI can be issued for the Hermes 2 34 CP application. In addition, exemptions from certain regulations in 10 CFR Part 51 would be 35 necessary to issue a final EA and final FONSI to support issuance of the Hermes 2 CPs. In 36 accordance with 10 CFR 51.6, the NRC may grant exemptions from the requirements of 37 10 CFR Part 51 if it determines that the exemptions are authorized by law and are otherwise in 38 the public interest.

39 PROPOSED ACTION

40 The proposed action is for the NRC to decide whether to issue CPs to Kairos authorizing 41 construction of the two proposed Hermes 2 non-power test reactors. The site is situated in the 42 Heritage Center Industrial Park of the East Tennessee Technology Park that was established by 43 the City of Oak Ridge on land formerly owned by the U.S. Department of Energy (DOE) for the 44 Oak Ridge Gaseous Diffusion Plant (ORGDP). The site was occupied by DOE Buildings K-31

xv 1 and K-33, both of which were part of the ORGDP. DOE ceased operation of the ORGDP in 2 1986, and both buildings were razed. Since then, the DOE has remediated the land 3 environmentally and released it for industrial reuse, subject to restrictions.

4 Issuance of a CP is a separate licensing action from issuance of an operating license (OL),

5 which allows operation of facilities built pursuant to a CP. If the NRC issues CPs for Hermes 2, 6 then Kairos still would have to obtain OLs before being able to operate the Hermes 2 reactors.

7 To obtain an OL, Kairos would have to submit a separate application pursuant to NRC 8 requirements and receive the license before operating the reactors. To conduct a complete and 9 effective environmental review, this EA addresses the potential environmental impacts from the 10 full life cycle of the Hermes 2 reactors, including construction, operation, and decommissioning.

11 If, however, Kairos were to apply for an OL, the NRC staff would conduct another environmental 12 review in accordance with 10 CFR Part 51 (TN250).

13 PURPOSE AND NEED FOR ACTION

14 The purpose and need of this proposed Federal action is to allow Kairos to construct two non-15 power test reactors termed Hermes 2 that Kairos would use to demonstrate key elements of the 16 Kairos Power Fluoride Salt-Cooled, High Temperature Reactor technology for possible future 17 commercial deployment. Kairos states that Hermes 2 will produce electricity but is categorized 18 as a nonpower reactor under 10 CFR 50.22, as not more than 50 percent of the annual cost of 19 owning and operating the facility is devoted to the production of materials, products, or energy 20 for sale or commercial distribution, or to the sale of services, other than research and 21 development or education or training.

22 The technology is an advanced nuclear reactor technology that leverages TRI-structural 23 ISOtropic particle fuel in pebble form combined with a low-pressure fluoride salt coolant.

24 Hermes 2 would support Kaiross reactor development program, which relies on learning and 25 risk reduction by narrowing the design space through progressive test cycles. Construction and 26 operation of Hermes 2 also would provide validation and qualification data to support potential 27 future commercial reactors using the Kairos Power Fluoride Salt-Cooled, High Temperature 28 Reactor technology.

29 The determination of need and the decision to build a test reactor project such as Hermes 2 are 30 at the discretion of applicants such as Kairos. This definition of purpose and need reflects the 31 NRCs recognition that, unless there are findings in the safety review required by the Atomic 32 Energy Act of 1954 (TN663), as amended, or findings in the environmental analysis under the 33 National Environmental Policy Act of 1969, as amended, that would lead NRC to reject a CP 34 application, the agency does not have a role in the planning decisions as to whether a particular 35 test reactor should be constructed and operated.

36 ENVIRONMENTAL IMPACTS OF CONSTRUCTION, OPERATIONS, AND 37 DECOMMISSIONING

38 Results from an evaluation of the potential environmental impacts of the proposed action are 39 presented in this EA. NRC staff typically characterizes environmental impacts as SMALL, 40 MODERATE, and LARGE, as presented in the Final Interim Staff Guidance to NUREG-1537 41 (NRC 2012-TN5527, NRC 2012-TN5528):

42 SMALL: Environmental effects are not detectable or are so minor that they will neither 43 destabilize nor noticeably alter any important attribute of the resource. In assessing radiological

xvi 1 impacts, the NRC has concluded that those impacts that do not exceed permissible levels in the 2 agencys regulations are considered SMALL.

3 MODERATE: Environmental effects are sufficient to alter noticeably, but not to destabilize, 4 important attributes of the resource.

5 LARGE: Environmental effects are clearly noticeable and are sufficient to destabilize important 6 attributes of the resource.

7 Table ES-1 summarizes the NRCs staffs findings on the level of direct, indirect, and cumulative 8 impacts on environmental resources from the construction, operation, and decommissioning of 9 Hermes 2. As shown in the table, the NRC staff characterized the potential environmental 10 impacts of Hermes 2 on each relevant environmental resource as SMALL. SMALL 11 environmental impacts are generally considered to not be significant effects on the human 12 environment.

13 ALTERNATIVES

14 This EA also evaluates in detail the environmental impacts associated with the following two 15 alternatives to construction, operation, and decommissioning of Hermes 2 at the proposed site 16 in Oak Ridge, Tennessee:

17

• the no-action alternative 18

• construction, operation, and decommissioning of Hermes 2 at a site in Eagle Rock, Idaho 19 (the Eagle Rock alternative)

20 The NRC staff also considered possible alternative sites, alternative layouts of proposed 21 facilities within sites, modification of existing facilities instead of building new facilities, 22 alternative technologies, and alternative transportation methods. The staff determined that 23 there were no other reasonable alternatives that warranted detailed consideration.

24 The NRC staff evaluated each alternative considered in detail using the same resource areas 25 that were used in evaluating impacts from the proposed action. The staff determined that the 26 no-action alternative would result in SMALL impacts to all resource areas. However, the no-27 action alternative does not fulfill the purpose and need of Hermes 2. The staff determined that 28 construction, operation, and decommissioning of Hermes 2 at the Eagle Rock alternative site 29 would result in only SMALL impacts for most affected resources but would result in MODERATE 30 impacts to land use and visual resources, ecological resources, and historic and cultural 31 resources. The proposed action, which would also meet the purpose and need but result in only 32 SMALL environmental impacts to all affected resources, would therefore be the environmentally 33 preferrable action. The proposed site in Oak Ridge allows for siting Hermes 2, as well as the 34 original Hermes project, while disturbing only previously disturbed soils with a history of past 35 industrial development. Use of the proposed site would avoid disturbing natural vegetation, 36 wetlands, surface water features, agricultural land, and shallow subsurface cultural resources.

xvii 1 Table ES-1. Summary of Environmental Impacts from Construction, Operation, and 2 Decommissioning of Hermes 2

EA Impact Resource Area Section Summary of Impact Level Land Use and 3.1 Same 185 ac site proposed for Hermes. Temporary disturbance SMALL Visual Resources of 138 ac of land previously occupied by industrial buildings.

Permanent occupation of 30 ac of that land. Remainder of the site would be exclusion area throughout operation, where Kairos would have to ensure compatible land use. The site is within an established industrial park setting that is already of low scenic quality. Hermes 2 would have a compatible industrial appearance and be compatible with existing zoning. Short 161 kV electric transmission would be built extending approximately 600 feet west of the 185 ac Kairos site to connect to existing electrical grid; the transmission line would be built entirely with previous disturbed lands within an existing industrial park.

Air Quality and 3.2 Air emissions of criteria pollutants would be below 100 tons per SMALL Noise year, and hazardous air pollutants would be below 10 tons per year individually and 25 tons per year combined. Emissions would comply with non-Title V permitting requirements.

Standard control measures to minimize fugitive dust.

Hydrogeology and 3.3 No disturbance of geological features of economic or natural SMALL Water Resources value. Disturbances limited to previously disturbed soils. Best management practices employed for soil erosion and sediment control. Water demands met through municipal or commercial suppliers. No use of groundwater and no direct use of surface water. No cooling towers, ponds, or reservoirs. Wastewater discharged for treatment to municipal wastewater treatment facilities. Limited, temporary dewatering of two reactor excavations during construction. Dewatering water to be dispositioned in accordance with DOE requirements per the quit claim deed for the site. Stormwater to be managed using best management practices.

Ecological 3.4 Ground disturbance, including for transmission lines, limited to SMALL Resources previously disturbed soils lacking vegetation or with only ruderal vegetation. No disturbance of forest cover or other natural vegetation on natural soils, wetlands, surface waters, shorelines, or riparian land. No Clean Water Act Section 404 permit required. Best management practices would be employed to control stormwater runoff that might reach wetlands or aquatic habitats. Brief increases in noise generated during construction may affect wildlife, but area wildlife are currently exposed to industrial noise. Limited potential for wildlife to collide with new structures or be injured by vehicles. The biological evaluation presented in Table 3-4 of this EA presents NRC staff conclusions regarding effects of Hermes 2 on species protected under the Endangered Species Act of 1973 (TN1010).

Conclusions for all species are no effect or may affect but not likely to adversely affect. No critical habitat present. As required under Section 7 Endangered Species Act, the NRC is requesting the U.S. Fish and Wildlife Service concurrence with these findings. The EA will include the result of this request.

3

xviii Table ES-1. Summary of Environmental Impacts from Construction, Operation, and Decommissioning of Hermes 2 (Continued)

EA Impact Resource Area Section Summary of Impact Level Historic and 3.5 No historic properties in the direct effects area of potential SMALL Cultural effects. Ground disturbance limited to areas of extensive past Resources soil disturbance with little potential for remaining archaeological resources. Kairos has developed and would implement an Archaeological Resources Monitoring and Unanticipated Discovery Plan covering any work on the 185 ac site establishing stop work and notification procedures to address unexpected discovery of human remains or archaeological material in compliance with deed requirements and Tennessee State law. The Manhattan Project National Historical Park (eligible for the National Register of Historic Places) is in the indirect effects area of potential effects but would not be adversely affected because Hermes 2 would be visually compatible with the current industrial setting. The NRC staff has made a preliminary determination of no adverse effect to historic properties from the potential issuance of a CP for Hermes 2.

Socioeconomics 3.6 Construction of Hermes 2 would involve an average of 424 site SMALL and Environmental workers per year over a 3-year period with an estimated peak Justice of 850 workers. Staffing during an 11-year operational phase would require an estimated average of 59 workers per weekday (101 full-time positions). Decommissioning would involve an estimated peak employment level of 340 workers. These few workers would not substantially affect employment levels in the surrounding area, but the demand for some skilled labor might compete with other planned technology projects. Given that the nearest potentially affected environmental justice populations are over 8 miles away, and the small footprint of and potential impacts from Hermes 2, both physically and in terms of personnel, no disproportionately high and adverse human health and environmental effects on minority and low-income populations would be expected.

Human Health 3.7 The site was formerly occupied by buildings that were part of SMALL the DOE Oak Ridge Gaseous Diffusion Plant that was used to enrich uranium, but the DOE has already razed the buildings and has begun remediation with the end use land use designation of unrestricted industrial land use as the basis for defining its remedial action objectives s. The DOE retains responsibility for remediation following any unanticipated discovery of legacy wastes. Based on information in the CP application, the NRC staff expects that radiological releases, doses to the public, and occupational doses would be less than the limits established for protection of human health and the environment in 10 CFR Part 20 (TN283). Based on the calculated radiological doses, the NRC staff concludes that the radiological impacts to members of the public due to normal operation of Hermes 2 would be not significant. The applicant would implement normal safety practices contained in Occupational Safety and Health Administration regulations in 29 CFR Part 1910 (TN654) to protect occupational health.

xix Table ES-1. Summary of Environmental Impacts from Construction, Operation, and Decommissioning of Hermes 2 (Continued)

EA Impact Resource Area Section Summary of Impact Level Emissions would comply with the Resource Conservation and Recovery Act (TN1281), Clean Air Act (TN1141), and other environmental regulations.

Nonradiological 3.8 Kairos would develop and implement a plan to manage wastes SMALL Waste generated by Hermes 2. Management of solid waste, including construction and demolition wastes, would involve waste reduction efforts, recycling, and use of best management practices. Liquid wastes would be discharged for municipal treatment at a wastewater treatment plant or trucked offsite for proper disposal. Gaseous emissions would comply with Tennessee Department of Environment and Conservation regulations.

Uranium Fuel 3.9 A low quantity of uranium would be used during the 11-year SMALL Cycle and Waste operational period. TRI-structural ISOtropic (TRISO) fuel Management processes (including enrichment and fuel fabrication) would be bounded by Table S-3 in 10 CFR 51.51 (TN250), developed by the NRC to protect human health and the environment.

Environmental impacts from the storage of spent TRISO fuel from Hermes 2 is bounded by the analysis in the Continued Storage Generic EIS. The estimated volume of low-level radioactive waste (LLRW) is less than or comparable to that from a light water reactor, and the staff determined that there is adequate capacity at LLRW disposal sites and that LLRW sites would accept the LLRW from Hermes 2. Onsite storage of spent TRISO fuel would have to meet the same regulatory requirements as currently licensed light water reactors.

Transportation of 3.10 Transportation of radioactive fuels and wastes to and from SMALL Radioactive Hermes 2 would be performed in compliance with U.S.

Material Department of Transportation and NRC regulations and would constitute only a small percentage of the total materials of these types shipped each year. Based on the quantity of nuclear material and waste acceptable for disposal and employing certified packages in conforming NRC and Department of Transportation regulations, the NRC staff concludes that the transportation of fuel and waste impacts from operation and decommissioning of Hermes 2 would be not significant.

Postulated 3.11 The NRC staff is conducting an independent review of the SMALL Accidents consequences of accidents and will document it in its Safety Evaluation. To receive CPs, the Hermes 2 test reactors would have to meet NRC requirements for postulated accidents, for which potential doses at the exclusion area boundary and in the low population zone are below the dose reference values of 10 CFR Part 100 (TN282) for test reactor siting. Additionally, as another indication of the low level of environmental impacts, the nearest resident dose from accidents is also below the radiation dose limits for individual members of the public in 10 CFR 20.1301(a) (TN283).

xx 1 RECOMMENDATION

2 On the basis of this EA, and its determination that the environmental impacts would be SMALL 3 for each potentially affected resource area, the NRC staff concludes that the proposed action 4 would not have a significant effect on the quality of the human environment. Therefore, the staff 5 has made a preliminary determination that it will not prepare an EIS and that a draft FONSI 6 appears warranted. Further, after weighing the environmental, economic, technical, and other 7 benefits against environmental and other costs, and considering reasonable alternatives, the 8 NRC staff recommends, unless safety issues mandate otherwise, that the NRC issue CP s to 9 Kairos for Hermes 2. The NRC staff based its recommendation on the following:

10

• the NRC staffs review of Kaiross Hermes 2 environmental report (Kairos 2023-TN9774 and 11 associated responses to requests for clarifying information.

12

• the NRC staffs independent environmental review.

13 The NRCs staffs recommendation is tentative. Before identifying a final recommendation, the 14 staff also will consider comments received on this draft EA over a 30-day public comment period 15 from Federal, State, local, and Tribal officials, and members of the public.

16

xxi

1 ABBREVIATIONS AND ACRONYMS

2 ADAMS Agencywide Document Access and Management Systems 3 APE area of potential effect 4 BMP best management practices 5 CAA Clean Air Act 6 CERCLA Comprehensive Environmental Response, Compensation, and Liability 7 Act 8 CFR Code of Federal Regulations 9 CO2 carbon dioxide 10 CO2(e) carbon dioxide equivalent 11 COL combined license 12 CP construction permit 13 CRN Clinch River Nuclear 14 DOE U.S. Department of Energy 15 EA environmental assessment 16 EFPY effective fullpower years 17 EIS environmental impact statement 18 EJ environmental justice 19 EPA Environmental Protection Agency 20 ER environmental report 21 ESP Early Site Permit 22 ETTP East Tennessee Technology Park 23 FFA Federal Facility Agreement 24 FONSI finding of no significant impact 25 FWS U.S. Fish and Wildlife Service 26 GCRP Global Change Research Program 27 GHG Greenhouse Gases 28 GWL global warming levels 29 HALEU High-Assay Low Enriched Uranium 30 IHTS intermediate heat transport system 31 IPCC Intergovernmental Panel on Climate Change 32 Kairos Kairos Power LLC 33 KP-FHR Kairos Power Fluoride Salt-Cooled, High Temperature Reactor 34 LLRW low-level radioactive waste 35 LOS level of service

xxiii 1 LWR light water reactor 2 MA-NLAA may affect, but not likely to adversely affect 3 MEI maximally exposed individual 4 MHA maximum hypothetical accident 5 MOA memorandum of agreement 6 MT metric tons 7 MWe megawatts electric 8 MWt megawatts thermal 9 NAAQS National Ambient Air Quality Standards 10 NCA5 Fifth National Climate Assessment 11 NEPA National Environmental Policy Act of 1969 12 NHP National Historical Park 13 NHPA National Historic Preservation Act of 1966 14 NPS National Park Service 15 NRC U.S. Nuclear Regulatory Commission 16 NRHP National Register of Historic Places 17 OL operating license 18 ORGDP Oak Ridge Gaseous Diffusion Plant 19 ORR Oak Ridge Reservation 20 PM particulate matter 21 PNNL Pacific Northwest National Laboratory 22 PSAR preliminary safety analysis report 23 RCI requests for confirmatory information 24 RFP requests for proposals 25 ROD Record of Decision 26 ROI region of interest 27 SE Safety Evaluation 28 SQG Small Quantity Generator 29 SWPP stormwater pollution prevention plan 30 SWU separative work units 31 TDEC Tennessee Department of Environment and Conservation 32 TEDE total effective dose equivalent 33 THC Tennessee Historical Commission 34 TRISO Tri-structural ISOtropic 35 USCB U.S. Census Bureau 36

xxiv 1 1 INTRODUCTION

2 By letter dated July 14, 2023, Kairos Power LLC (Kairos) submitted an application to the 3 U.S. Nuclear Regulatory Commission (NRC) for construction permits (CP) pursuant to 4 Title 10 of the Code of Federal Regulations (10 CFR) Part 50 (TN249), that would allow 5 construction of two non-power test reactors termed Hermes 2 on a 185 acre (ac) site located 6 in Oak Ridge, Tennessee. Kairos proposes to build the two Hermes 2 reactors on the same site 7 for which they received a CP in 2023 to build another non-power test reactor of generally similar 8 design termed Hermes. Although the NRC issued a CP for Hermes in 2023, Kairos has not 9 started its construction yet. Hermes and Hermes 2 are two separate test reactor projects each 10 requiring a separate CP from the NRC.

11 Section 104 of the Atomic Energy Act of 1954, as amended, (TN663) and its implementing 12 regulations authorize the NRC to issue CPs for testing facilities. To issue a CP, the NRC is 13 required to consider the environmental impacts of the proposed action under the National 14 Environmental Policy Act of 1969 (NEPA) (TN661). The NRCs environmental protection 15 regulations that implement NEPA in 10 CFR Part 51 (TN250) identify actions for which the NRC 16 prepares an environmental impact statement (EIS). CPs for test reactors are an action identified 17 as requiring an EIS. However, based on a review of the environmental report (ER) submitted as 18 part of the CP application for Hermes 2 and the results of the EIS recently issued for Hermes 1, the 19 NRC staff concluded that it would be prudent to first prepare a draft environmental assessment 20 (EA) to determine whether preparation of an EIS would be necessary or whether a finding of no 21 significant impact (FONSI) could be issued for the Hermes 2 CP based on factors unique to the 22 Hermes 2 CP application. These factors include: (1) the similar design of Hermes 2 and Hermes, 23 (2) the proposed siting of Hermes 2 within a few hundred feet of Hermes, (3) the industrial nature 24 and heavy prior disturbance of the site, (4) the recent thorough NEPA review performed by the 25 staff as published in its final EIS for Hermes, and (5) the staffs final EIS for Hermes, covering the 26 same site as Hermes 2 and documenting all impacts as SMALL. The staff has made a 27 preliminary determination that the proposed action would not significantly affect the quality of the 28 human environment and, therefore, a draft FONSI appears warranted.

29 The staff will consider comments received on this draft EA and draft FONSI over a 30-day public 30 comment period from Federal, State, local, and Tribal officials, and members of the public. After 31 consideration of these public comments, the NRC staff will make a final determination as to 32 whether preparation of an EIS is necessary or whether a FONSI can be issued for the Hermes 2 33 CP application. In addition, exemptions from certain regulations in 10 CFR Part 51 would be 34 necessary to issue a final EA and final FONSI to support issuance of the Hermes 2 CPs. In 35 accordance with 10 CFR 51.6, the NRC may grant exemptions from the requirements of 36 10 CFR Part 51 if it determines that the exemptions are authorized by law and are otherwise in 37 the public interest.

38 1.1 The Proposed Federal Action

39 The proposed action is for the NRC to issue CPs to Kairos authorizing construction of the two 40 proposed Hermes 2 reactors. The site is situated in the Heritage Center Industrial Park of the 41 East Tennessee Technology Park (ETTP), an industrial park established by the City of Oak 42 Ridge, on land formerly owned by the U.S. Department of Energy (DOE) for the Oak Ridge 43 Gaseous Diffusion Plant (ORGDP). The site was formerly occupied by DOE Buildings K-31 44 and K-33, which were both part of the ORGDP (Figure 1-1). DOE ceased operation of the 45 ORGDP in 1986.

1-1 1

2 Figure 1-1 Hermes 2 Reactor Site (Source Kairos 2023-TN9774)

1-2 1 Historical missions at ETTP resulted in a legacy of contaminated, inactive facilities. After the 2 Oak Ridge Reservation (ORR) was listed on the National Priorities List, environmental work at 3 ETTP was driven by Comprehensive Environmental Response, Compensation, and Liability Act 4 (CERCLA) requirements. The early CERCLA actions and facility demolitions are complete.

5 Characterization and remedial actions for soil, buried waste, and subsurface structures were 6 implemented under a Soil Record of Decision (ROD) (DOE 2023-TN9801). The Soil ROD, 7 which addresses soil, including the K-31/K-33 Area, has an unrestricted industrial land use as 8 the basis for defining its remedial action objectives. The remaining CERCLA decisions at ETTP 9 will address contamination in groundwater, surface water, and sediment in the ponds, wetlands, 10 and perennial streams. These decisions will include protection of ecological receptors in aquatic 11 environments (i.e., ponds and streams) (DOE 2023-TN9801).

12 The site has Land Use Control restrictions established under the Soil ROD for the K-31/K-33 13 Area that limit development to industrial and commercial uses; allow for continued DOE 14 access as needed to complete CERCLA cleanup actions; and prohibit groundwater extraction, 15 consumption, exposure, or use, in any way. The designation for an end use of unrestricted 16 industrial use limits means any excavation or penetration below 10 feet is restricted and 17 requires Federal Facility Agreement (FFA) tri-party (i.e., DOE, U.S. Environmental Protection 18 Agency [EPA], and Tennessee Department of Environment and Conservation [TDEC]) approval.

19 A series of FFA tri-party letters from 2014 was issued regarding the request and approvals of 20 soil penetration and/or excavation to depths greater than 10 feet below the ground surface in 21 the greater K-33 Area (DOE 2023-TN9801).

22 This EA constitutes the NRC staffs review of potential environmental impacts from the 23 proposed action of issuing CPs for the Hermes 2 reactors. The issuance of a CP is a separate 24 licensing action from the issuance of an operating license (OL). If the NRC issues CPs and 25 Kairos were to seek NRC approval to operate the reactors, then Kairos would have to submit a 26 separate application for OLs pursuant to the NRCs requirements, and Kairos would have to 27 obtain NRC approval before operating the reactors. To conduct a complete environmental 28 review, this EA covers the potential impacts from the construction, operation, and 29 decommissioning life-cycle phases of the Hermes 2 project. The NRC staff recognizes that new 30 and significant information regarding operation and decommissioning may become available 31 subsequent to issuance of the CP. The NRC staff would therefore review any application for 32 OLs for the Hermes 2 project for new and significant information that might alter the staffs 33 conclusions made for this CP application. If Kairos were to apply for an OL, the NRC staff would 34 conduct another environmental review in accordance with 10 CFR Part 51 (TN250).

35 1.2 Purpose and Need

36 The purpose and need of this proposed Federal action is to allow Kairos to construct two non-37 power test reactors termed Hermes 2, that Kairos would use to demonstrate key elements of the 38 Kairos Power Fluoride Salt-Cooled, High Temperature Reactor (KP-FHR) technology for 39 possible future commercial deployment (Kairos 2023-TN9774). Kairos states that Hermes 2 will 40 produce electricity but is categorized as a nonpower reactor under 10 CFR 50.22, as not more 41 than 50 percent of the annual cost of owning and operating the facility is devoted to the 42 production of materials, products, or energy for sale or commercial distribution, or to the sale of 43 services, other than research and development or education or training.

44 Demonstration of the advanced nuclear reactor technology, which leverages TRI-structural 45 ISOtropic (TRISO) particle fuel in pebble form combined with a low-pressure fluoride salt 46 coolant, would support Kaiross reactor development program. The Kairos reactor development

1-3 1 program relies on learning and risk reduction by narrowing the design space through 2 progressive test cycles. Construction and operation of Hermes 2 also would:

3

• provide validation and qualification data to support potential future commercial reactors 4 using the Kairos Power Fluoride Salt-Cooled, High Temperature Reactor technology 5

• facilitate rapid demonstration of a multiunit nonpower reactor with shared power 6 conversion systems in support of Kairos iterative development approach 7

• reduce commercial cost uncertainty by demonstrating power conversion system and power 8 transmission system integration and a multiunit reactor facility 9

• retain construction workforce competency and demonstrate multiunit construction and 10 iteration of construction methods

11 Kairos participates in DOEs Advanced Reactor Demonstration Program, which assists private 12 industries in the United States in demonstrating advanced nuclear reactors, with the goal of 13 designing and developing safe and affordable reactor technologies that can be licensed and 14 deployed over the next 10 to 14 years (Kairos 2023-TN9774).

15 The determination of need and the decision to build a test reactor project such as Hermes 2 are 16 at the discretion of applicants such as Kairos. This definition of purpose and need reflects the 17 NRCs recognition that unless there are findings in the safety review required by the Atomic 18 Energy Act of 1954 (TN663), as amended, or findings in the environmental analysis under the 19 National Environmental Policy Act of 1969, as amended, that would lead NRC to reject a CP 20 application, the agency does not have a role in the planning decisions as to whether a particular 21 test reactor should be constructed and operated.

22 1.3 The NRC Application Review

23 The NRC process to review CP applications consists of two separate, parallel reviews. The 24 safety review evaluates the applicants ability to meet the NRC regulatory safety requirements.

25 The NRC staff documents the findings of the safety review in a Safety Evaluation (SE). The 26 environmental review, governed by NEPA and the requirements in 10 CFR Part 51 (TN250),

27 evaluates the environmental impacts of, and alternatives to, the proposed action. The NRC 28 considers the findings in both the environmental review and the SE in its decision to grant or 29 deny the issuance of a CP.

30 To guide its assessment of environmental impacts, the NRC staff uses three levels of 31 significance for potential impacts: SMALL, MODERATE, and LARGE, as defined below:

32

• SMALL: Environmental effects are not detectable or are so minor that they will neither 33 destabilize nor noticeably alter any important attribute of the resource.

34

• MODERATE: Environmental effects are sufficient to alter noticeably, but not to destabilize, 35 important attributes of the resource.

36

• LARGE: Environmental effects are clearly noticeable and are sufficient to destabilize 37 important attributes of the resource.

38 To conduct its environmental review, the NRC staff used guidance contained in the Final 39 Interim Staff Guidance Augmenting NUREG-1537, Part 1, Guidelines for Preparing and 40 Reviewing Applications for the Licensing of Non-Power Reactors: Format and Content, for 41 Licensing Radioisotope Production Facilities and Aqueous Homogeneous Reactors (NRC

1-4 1 2012-TN5527) and Part 2, Guidelines for Preparing and Reviewing Applications for the 2 Licensing of Non-Power Reactors: Standard Review Plan and Acceptance Criteria, for 3 Licensing Radioisotope Production Facilities and Aqueous Homogeneous Reactors (NRC 2012-4 TN5528). Use of the guidance is not mandatory and does not substitute for compliance with 5 NRC regulations. Therefore, the NRC staff ensured that the environmental review documented 6 in this EA met the applicable regulations in 10 CFR Part 51 (TN250) and used the guidance 7 associated with NUREG-1537 only as supplementary direction.

8 In July 2023, Kairos submitted its ER (Kairos 2023-TN9774) as part of its CP application 9 submittal, as discussed above. On September 11, 2023, the NRC notified Kairos of its decision 10 that the application (including the ER) was sufficient to conduct its detailed review (NRC 2023-11 TN9777). The NRC staff published a Notice of Acceptance for Docketing in the Federal Register 12 on September 15, 2023 (88 FR 63632-TN9776). In January-February 2024, the NRC staff 13 conducted a virtual audit to verify information in the Kairos ER. During the audit, the NRC staff 14 reviewed specific documentation and discussed specific information needs with Kairos staff and 15 their contractors. The information needs and the pertinent points from that audit are 16 documented in the staffs audit summary report (NRC 2024-TN9899).

17 This EA presents the NRC staffs analysis that considers and weighs the environmental impacts 18 of the Hermes 2 project at the proposed site, including the environmental impacts associated 19 with the construction, operation, and decommissioning of the proposed facilities; the impacts of 20 constructing, operating, and decommissioning the same facilities at an alternative site; the no-21 action alternative; and mitigation measures available for reducing or avoiding adverse 22 environmental effects. It also provides the NRC staffs recommendation to the Commission 23 regarding the issuance of the CPs for the proposed Kairos Hermes 2 facility at the site in 24 Oak Ridge, Tennessee.

25 The NRC and other Federal agencies have prepared other NEPA documents related to the 26 scope of the Hermes 2 project. Table 1-1 provides a brief description of the related NEPA 27 documents issued by the NRC and other Federal agencies along with the relevance of each 28 document. All NEPA documents that were incorporated by reference or referenced in this EA 29 are publicly available, and links to these documents can be found in Table 1-1 and Section 7.

30 Where parts of a NEPA document are incorporated by reference in the EA, the pertinent 31 section(s), figures, and tables of the document are indicated in the impact discussion sections 32 along with a brief description of the incorporated material.

33 Other sources of information the staff considered in its analysis also are listed in Table 1-1. For 34 information from Kairos, the NRC staff referenced the ER specifically prepared to address 35 Hermes 2 and submitted as part of the application (Kairos 2023-TN9774). When preparing the 36 ER for Hermes 2, Kairos incorporated by reference frequently from an ER it had recently 37 submitted for the Hermes project (Kairos 2023-TN8172). Where the NRC staff found it helpful to 38 reference certain sections of the ER for the prior Hermes submittal for readability, the staff did 39 so only after verifying that the referenced material was applicable to Hermes 2 and Kairos had 40 incorporated by reference the applicable content from the Hermes ER in the Hermes 2 ER.

1-5 1 Table 1-1 List of Related NEPA Documents

Title Relevance Reference NRC. Environmental Impact Statement EIS prepared for a CP for a test reactor TN9771 for the Construction Permit for the on the same site as Hermes 2.

Kairos Hermes Test Reactor, Final Establishes baseline affected Report. NUREG-2263. environment and provided environmental impact analyses of activities associated with construction, operation, and decommissioning of the Hermes reactor.

NRC. Environmental Impact Statement EIS prepared for new reactor in close TN6136 for an Early Site Permit (ESP) at the proximity to Hermes 2. Informs resource Clinch River Nuclear Site. NUREG- impact analyses such as ecological 2226. studies, transportation analyses, socioeconomic analyses, environmental justice population characteristics, cumulative impacts, and climate change.

NRC. Generic Environmental Impact Generic EIS that considers in a TN7254 Statement on Decommissioning of comprehensive manner all aspects Nuclear Facilities, Supplement 1, related to the radiological NUREG-0586 decommissioning of nuclear reactor facilities by incorporating updated information, regulations, and analyses.

Informs each of the decommissioning impact analyses.

DOE. Environmental Assessment, EA in 2011 prior to transferring the land TN4888 Transfer of Land and Facilities within the and facilities within the ETTP to the East Tennessee Technology Park and Community Reuse Organization of East Surrounding Area, Oak Ridge, Tennessee. DOEs EA provides that no Tennessee. DOE/EA-1640, Final prehistoric archaeological resources are Environmental Assessment and Finding known to exist within the ETTP site of No Significant Impact, Oak Ridge, which encompasses the proposed Tennessee. Hermes 2 site.

DOE. Covenant Deferral Request for the DOE performed radiological surveys and TN7964 Proposed Title Transfer of the Former K-environmental sampling under the DOE 33 Area at the East Tennessee Environmental Management Programs Technology Park, Oak Ridge, Dynamic Verification Strategy process to Tennessee, Final-Concurred. assess the condition of the site for title DOE/OR/01-2666. transfer. As documented in these title transfer reports, there were no exceedances of the measured maximum or average remediation level.

DOE. Environmental Assessment DOE prepared an EA for a proposed TN7903 Property Transfer to Develop a General airport in Oak Ridge. That assessment Aviation Airport at the East Tennessee indicated that 65 dBA is the maximum Technology Park Heritage Center, Oak compatible level with a residential area.

Ridge, Tennessee. Oak Ridge, Tennessee.

2

1-6 1 Table 1-1 List of Related NEPA Documents (Continued)

Title Relevance Reference Kairos Power LLC. Submittal of the This is the ER submitted by Kairos as TN8172 Environmental Report for the Kairos part of the CP application for Hermes.

Power Fluoride Salt-Cooled, High This document is frequently cited by the Temperature Non-Power Reactor ER (Kairos 2023-TN9774). It is (Hermes). occasionally referenced in this EA but only to the extent that it supports referencing to the ER or Hermes CP EIS (NRC 2023-TN9771).

Kairos Power, LLC. Submittal of the This is the ER submitted by Kairos as TN9774 Construction Permit Application for the part of the CP application for Hermes 2.

Hermes 2 Kairos Power Fluoride Salt- It summarizes the environmental Cooled, High Temperature Non-Power impacts of construction, operation, and Reactor. decommissioning for Hermes 2. Kairos incorporates by reference portions of the Hermes ER (Kairos 2023-TN8172).

Key: dBA = A-weighted decibel(s); DOE = Department of Energy; EA = environmental assessment; EIS = environmental impact statement; ER = environmental report; ESP = Early Site Permit; ETTP = East Tennessee Technology Park; NRC = U.S. Nuclear Regulatory Commission.

2 The staff notes that prior to incorporating by reference or referencing any portion of a document 3 in this EA, the NRC staff verified the current applicability of the referenced material to Hermes 2.

4 Additionally, any analysis in a referenced document was independently verified by the NRC 5 staff. The NRCs independent analysis related to any document incorporated by reference or 6 referenced are summarized to highlight the important aspects of the analysis presented in the 7 source document to determine impacts. This cuts down on bulk without impeding public review.

8 1.4 Regulatory Provisions, Permits, and Required Consultations

9 Appendix D to this EA lists each environmental regulatory requirement, permit, and consultation 10 necessary for construction of Hermes 2. They are the same as for Hermes, as presented in 11 Appendix D of the Hermes CP EIS (NRC 2023-TN9771). However, the applicant would have to 12 obtain separate permits specifically covering Hermes 2. The applicant bears the responsibility 13 for applying for each permit. The NRC staff bear the responsibility for performing the 14 consultations required under the Endangered Species Act of 1973, as amended (ESA) 15 (TN1010) and National Historic Preservation Act of 1966, as amended (NHPA) (TN4157).

16 Separate consultation efforts specific to Hermes 2 are required.

17 1.5 Preconstruction Activities

18 In a final rule dated October 9, 2007 (72 FR 57416-TN260), the Commission established the 19 definition of construction in 10 CFR 51.4 (TN250) as those activities that fall within its 20 regulatory authority. Many of the activities required to build test reactors are not part of the NRC 21 action to license the reactors because they do not have a reasonable nexus with radiological 22 health and safety and/or common defense and security; therefore, they are not within the NRCs 23 authority to regulate. Activities associated with building reactors that are not within the purview 24 of the NRC action are grouped under the term preconstruction. Under 10 CFR 51.45 ( TN250),

25 applicants are required to include in an ER a description of the impacts of the applicants 26 preconstruction activities.

1-7 1 Preconstruction activities include clearing and grading, excavating, building of service facilities 2 (e.g., paved roads, parking lots), erection of support buildings, and other associated activities.

3 These preconstruction activities may take place before the application for a CP is submitted, 4 during the staffs review of a CP application, or after a CP is granted. Consequently, the NRC 5 evaluates preconstruction impacts as cumulative impacts and not as direct impacts resulting 6 from the NRCs Federal action. Although preconstruction activities are outside the NRCs 7 regulatory authority, many are within the regulatory authority of local, State, or other Federal 8 agencies.

9 The applicant could choose to perform preconstruction work before receipt of the requested CP, 10 or even if the NRC never issues the CP. However, because the preconstruction is a precursor to 11 NRC-authorized construction of the proposed Kairos Hermes test reactor, and because 12 discussion of pre-construction and construction impacts together enhances the readability of the 13 document, Chapter 3 of this EA presents a single combined discussion of preconstruction and 14 construction impacts for each resource. Because the conclusions determined by the staff in this 15 EA for all combined preconstruction and NRC-authorized construction activity impact category 16 levels are SMALL for all resource areas (e.g., land use, water resources), no further breakdown 17 of impacts between preconstruction and NRC-authorized construction is provided.

18 1.6 Report Contents

19 This EA is organized as follows:

20

• Chapter 1 is this introduction.

21

• Chapter 2 provides a description of the proposed Hermes 2 project, summarizing key 22 elements of the design needed by the NRC staff to evaluate potential environmental 23 impacts. Most of the information in Chapter 2 is drawn from the applicants description of the 24 project in their ER (Kairos 2023-TN9774), preliminary safety analysis report (PSAR) (Kairos 25 2023-TN9774), and other parts of the application.

26

• Chapter 3 describes the affected environment for each of the 12 environmental resources 27 identified by the NRC staff as relevant to Hermes 2, followed by the staffs evaluation of 28 potential environmental impacts on each resource. The staff independently verified and 29 summarized the affected environment descriptions from prior NEPA documents issued by 30 the NRC or other Federal agencies, the applicants ER, and other public source documents.

31 As described in Section 1.3, as appropriate the NRC staff relied on incorporation by 32 reference and the referencing of source documents to the extent possible to simplify the EA.

33 While inherent in the use of previous issued NEPA documents by the NRC, it should be 34 noted that when referencing Kairos ER, the staff developed their evaluations of 35 environmental impacts independently from the applicant, relying in part on impact data 36 presented by the applicant only after independent verification.

37

• Chapter 4 presents the NRC staffs evaluation of a range of reasonable alternatives to the 38 proposed action.

39

• Chapter 5 summarizes the staffs conclusions and recommendation to the NRC Commission 40 based on the environmental review.

41

• Chapter 6 is the draft Finding of No Significant Impact

42 Appendices to this EA contain additional information in the following areas:

43

• Appendix A - Contributors to the Environmental Assessment

1-8 1

• Appendix B - Agencies, Organizations, and Individuals Contacted 2

• Appendix C - Chronology of Key Environmental Review Correspondence 3

• Appendix D - Regulatory Compliance and List of Federal, State, and Local Permits and 4 Approvals 5

• Appendix E - Greenhouse Gas Emissions 6

• Appendix F - Past, Present, and Reasonably Foreseeable Projects and Other Actions 7 Considered in the Cumulative Effects Analysis

1-9

1 2 PROPOSED PROJECT

2 The proposed Federal action is for the NRC to issue CPs to Kairos under 10 CFR Part 50 3 (TN249) to construct a two-unit non-power facility (Hermes 2) to test and demonstrate the 4 KP-FHR technology in Oak Ridge, Tennessee. After receipt of CPs from the NRC, the applicant 5 would be required to apply for a separate OL under 10 CFR Part 50 (TN249) before reactor 6 operation. The NRC would perform separate environmental reviews for the OL application and 7 for subsequent licensing actions, such as OL renewal and decommissioning. The information 8 presented below summarizes key characteristics of the Hermes 2 project that the NRC staff 9 considered when assessing the environmental impacts of the proposed action. The summaries 10 focus on construction of the proposed facilities but also include general information about 11 operation and decommissioning of the facilities to the extent currently known. Any new and 12 significant information not addressed in the environmental review for the Hermes 2 CPs would 13 be addressed as necessary in any subsequent environmental reviews for an OL application or 14 for decommissioning.

15 2.1 Project Overview

16 As noted in Section 2.1 of the ER (Kairos 2023-TN9774) the Hermes 2 project would test and 17 demonstrate key technologies, design features, and safety functions of the KP-FHR technology, 18 and it would provide data that may be used for validation of safety analysis tools and 19 computational methodologies used for designing and licensing future reactors using the 20 technology. As noted in the ER, Kairos plans to begin construction of the overall Hermes 2 21 project as early as mid-2025, with the earliest projected completion date of mid-2027 for 22 Hermes 2 Unit 1 and mid-2028 for Hermes 2 Unit 2. Kairos plans an operational life of 11 years 23 for each unit, after which the units would be decommissioned. The NRC staff recognizes that 24 the applicants estimated dates for construction, operation, and decommissioning are 25 approximate and that the actual dates might differ. Information related to land disturbance, 26 onsite workers, and material usage is provided in Chapter 2 of the ER (Kairos 2023-TN9774) 27 and summarized below.

28 With specific exceptions, the design of each Hermes 2 reactor, described in the Hermes 2 29 PSAR, would be similar to that of the Hermes reactor (Kairos 2023-TN9774). As described in 30 the both the PSAR and ER, the Hermes 2 project would consist of two test reactors (units), each 31 with a maximum thermal power of 35 megawatts thermal (MWt) and intermediate heat transport 32 system loops that reject heat via a steam superheater to a shared traditional power generation 33 system. A heat rejection radiator provided in the primary heat transport system would reject heat 34 directly to the atmosphere when the power generation system is not in service. The ER includes 35 process flow diagrams for the reactor units and primary and intermediate heat transport systems 36 (Figure 2.3-1 of the ER) and the shared power generation system (Figure 2.3-2 of the ER).

37 Kairos states that although the Hermes 2 reactors would generate electricity, they would still be 38 categorized as non-power reactors under the provisions of 10 CFR 50.22 (TN249), because not 39 more than 50 percent of the annual cost of owning and operating the facilities would be devoted 40 to the production of materials, products, or energy for sale or commercial distribution, or to the 41 sale of services, other than research and development or education or training.

42 2.2 Site Location and Layout

43 Kairos describes the site location and layout in Section 2.2 of the ER (Kairos 2023-TN9774).

44 Kairos proposes building the two Hermes 2 test reactors adjacent to the location of the Hermes

2-1 1 test reactor within a 185 ac site in the ETTP. The site had previously been occupied by 2 Buildings K-31 and K-33, which were formerly part of the DOE ORGDP. The Hermes 2 facilities 3 would permanently disturb approximately 30 ac within the former footprint of the K-33 facility.

4 Figure 1-1 of this EA depicts the proposed layout of the Hermes 2 facilities, which would include 5 the two reactor buildings, an auxiliary-systems building, a turbine building, and a switchyard.

6 The Hermes 2 facilities complex would be built on land formerly situated within the ORR (and 7 since excessed by DOE to the City of Oak Ridge for industrial redevelopment). The applicant 8 states that Hermes 2 would share various administrative facilities built for the Hermes reactor.

9 2.3 Site Workers and Vehicular Deliveries

10 The applicant estimates the numbers of site workers and vehicular deliveries in Section 2.1 11 of the ER (Kairos 2023-TN9774). The applicant estimates that construction would require an 12 average of 424 onsite workers, with 850 workers onsite at peak times, and would involve a 13 monthly average of 426 truck deliveries and 8 offsite shipments of construction debris.

14 Operation is estimated to involve an average of 59 workers per weekday (101 full-time 15 positions), with an estimated monthly average of 30 truck deliveries and 8 offsite waste 16 shipments. The applicant notes that the two Hermes 2 reactors (i.e., Units 1 and 2) would be 17 decommissioned in series and estimates that figures for decommissioning would be as 18 described for Hermes, which according to Section 2.3 of the Hermes CP EIS (NRC 2023-19 TN9771) would be an average of 170 workers (340 workers at peak times) and a monthly 20 average of four truck deliveries and 170 offsite waste shipments.

21 2.4 Equipment and Material Usage

22 Kairos provides estimates of anticipated equipment and material use by Hermes 2 in 23 Section 2.1 of the ER (Kairos 2023-TN9774). Table 2.1-1 in the ER provides the applicants 24 estimates of material such as concrete, structural steel, steel sheet pilings, asphalt, and stone 25 that would be consumed during construction of Hermes 2. Equipment usage for each unit of 26 Hermes 2 would be as outlined for Hermes in Section 2.4 of the Hermes CP EIS (NRC 2023-27 TN9771), which is incorporated by reference. Section 2.4 of the EIS relies in part on Table 2.1-2 28 in the Hermes ER (Kairos 2023-TN8172). Kairos also estimates in Section 2.1 of the ER (Kairos 29 2023-TN9774) that, as a bounding assumption, that approximately 63,600 gallons (gal) of diesel 30 fuel is assumed to be consumed on an average monthly basis during the construction phase.

31 As noted in Section 2.1 of the ER (Kairos 2023-TN9774), Kairos estimates shipments of a low-32 pressure, molten salt coolant termed FLiBe (a mixture of lithium fluoride and beryllium fluoride 33 [BeF2]) and intermediate coolant, BeNaF (57NaF:43BeF2), would be shipped to the site prior to 34 startup. FLiBe is estimated to be delivered in 40 shipments of 1 ton each prior to startup. An 35 additional 40 shipments of 1 ton each of FLiBe are estimated to be delivered before the end 36 of the first two years of operation. Kairos estimates a need for 32 shipments of 9 tons each of 37 the intermediate coolant BeNaF prior to startup. Kairos expects to store small quantities of 38 FLiBe, BeNaF, and anhydrous hydrogen fluoride onsite. Kairos estimates a bounding value of 39 43,110 gal of diesel fuel stored onsite in storage tanks for the standby diesel generator. Kairos, 40 as stated in Section 2.1 of the ER (Kairos 2023-TN9774), expects that other materials used and 41 stored onsite would be roughly twice those anticipated for the Hermes reactor.

42 2.5 Water Consumption and Treatment

43 The applicant provides a description of how it would obtain, use, and discharge water for 44 Hermes 2 in Section 2.4 of the ER (Kairos 2023-TN9774). Details concerning water sourcing,

2-2 1 treatment, consumption, and discharge for each unit of Hermes 2 would not generally differ from 2 those described for Hermes in Section 2.5 of the Hermes CP EIS (NRC 2023-TN9771), which is 3 incorporated by reference. Because Hermes 2 includes two reactors instead of just one, 4 increased volumes would be used. The applicants proposed water balance diagram for Hermes 5 2 is depicted in Figure 2.4-1 of the ER (Kairos 2023-TN9774). Water demands during 6 construction, operation, and decommissioning of Hermes 2 would be met using municipal 7 sources or truck deliveries, and wastewater generated by operation would be discharged into 8 municipal sewers that service the ETTP. The project would not involve building or operation of 9 intake or discharge pipelines, reservoirs, evaporation ponds, leach fields, or similar facilities.

10 Temporary dewatering of the reactor excavation pit during construction may be necessary but 11 would be managed in accordance with DOE, EPA, and TDEC requirements and in conformance 12 with deed restrictions, similar to Hermes as described in Section 3.3.2.2 of the Hermes CP EIS 13 (NRC 2023-TN9771), which is incorporated by reference.

14 2.6 Cooling and Heat Removal Systems

15 The proposed cooling and heating systems are described in Section 2.5 of the ER (Kairos 2023-16 TN9774). Details concerning water sourcing, treatment, consumption, and discharge for each 17 Hermes 2 unit would not generally differ from those for the Hermes reactor, as addressed in 18 Section 2.6 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by reference.

19 Similar to Hermes, there would be no cooling water system and hence no cooling towers or 20 intake or discharge structures for Hermes 2. Unlike Hermes, the Hermes 2 reactors would 21 include an intermediate heat transport system (IHTS) in addition to a primary heat transport 22 system. The primary heat transport system would transfer heat from the reactor through the 23 intermediate heat exchanger to the IHTS, which would transfer the heat to the power generation 24 system through superheaters. Heat not used by the shared power generation system would be 25 rejected to aircooled condensers and the surrounding atmosphere, which would be the ultimate 26 heat sink. The heat load would be approximately 55 MWt (up to 70 MWt with no power 27 conversion). A decay heat removal system using air cooled condensers would be used 28 whenever the heat transfer systems described above are not available.

29 2.7 Waste Systems

30 The waste generated and waste systems for Hermes 2 are described in Section 2.6 of the ER 31 (Kairos 2023-TN9774). Waste generation by each Hermes 2 unit would be as described for 32 Hermes in Section 2.7 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by 33 reference. However, as noted in Section 2.6 of the ER (Kairos 2023-TN9774), larger quantities 34 would be generated, as expected for two reactors rather than one. The Hermes 2 reactors also 35 would generate additional wastes resulting from operation of the IHTS. Intermediate salt would 36 be collected in storage containers and allowed to cool and solidify during storage and then 37 disposed of in solid form. The handling, packing, storage, and shipping areas for waste systems 38 will be shared between the two Hermes 2 units. The tritium management system described for 39 Hermes also would have to separate tritium from argon in the IHTS cover gas and from dry air 40 in heat rejection radiator enclosure, producing an additional waste stream for Hermes 2.

41 Operation of Hermes 2 is estimated to generate approximately 776,000 used pebbles between 42 the two units over the 10 effective fullpower years (EFPY) of the 11year operating life. The 43 onsite spent fuel pebble canister storage system would have sufficient storage capacity for 44 10 EFPY of licensed reactor operation.

2-3 1 The estimated types, quantities, and number of shipments of radioactive wastes are listed in 2 Table 2.6-1 of the ER (Kairos 2023-TN9774) and include inert gas system capture materials, 3 reactor cell capture materials, FLiBe, dry active waste, liquid waste, and spent fuel. The table 4 also identifies possible destinations for each category of waste.

5 2.8 Storage, Treatment, and Transportation of Radioactive and Nonradioactive 6 Materials

7 The applicant describes the proposed storage, treatment, and transportation of radioactive and 8 nonradioactive materials in Section 2.7 of the ER (Kairos 2023-TN9774). The sourcing, storage, 9 treatment, and transportation of radioactive and nonradioactive materials for each Hermes 2 unit 10 would generally not differ from that for Hermes. Information on the storage, treatment, and 11 transportation of radioactive and nonradioactive material for Hermes is also described in Section 12 2.8 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by reference. Fuel 13 shipments for Hermes 2 would continue over the estimated 11 years of operation. The spent 14 fuel storage area, the storage pool, and the aircooled cavity would be similar to those for 15 Hermes but with a total storage capacity sufficient for 10 EFPY of the 11 years of licensed 16 reactor operation of both units.

2-4 1 3 AFFECTED ENVIRONMENT AND ENVIRONMENTAL IMPACTS

2 This section presents the affected environment and potential environmental impacts from the 3 proposed action to issue CPs for the Kairos Hermes 2 facility. This section is organized into 4 separate sections addressing specific environmental resources identified by the NRC staff as 5 relevant to the proposed action. Each section is organized into subsections addressing the 6 affected environment for the resource; potential direct and indirect impacts on the resource from 7 each of three life-cycle phases (construction, operation, and decommissioning); and cumulative 8 impacts. Each section culminates in a final subsection presenting the NRC staffs conclusions 9 regarding the significance of the environmental impacts. Certain sections addressing two 10 substantially independent though interrelated environmental resources (e.g., air quality and 11 noise) are divided into two subsections organized as indicated above and lead to separate 12 conclusions. The range of possible conclusions used by the NRC staff in assessing the 13 significance of impacts on environmental resources is presented in Chapter 1 of this EA.

14 To present a complete environmental review, this EA covers the potential impacts from the 15 construction, operation, and decommissioning life-cycle phases of the Hermes 2 project.

16 The NRC staff recognizes that new and significant information regarding the operation and 17 decommissioning may become available after issuance of the Hermes 2 CPs. The NRC staff 18 would therefore review any application for OLs for Hermes 2 for new and significant information 19 that might alter the staffs conclusions made for this CP application. If Kairos were to apply for 20 OLs, the NRC staff would prepare another environmental review in accordance with 10 CFR 21 Part 51 (TN250).

22 The order of presentation of environmental resources follows that used in Section 19.4 of the 23 Final Interim Staff Guidance Augmenting NUREG-1537 (NRC 2012-TN5527), with the following 24 exceptions:

25

• First, the NRC staff considered it more efficient to combine the sections about geological 26 environment and water resources into a single Hydrogeology and Water Resources section 27 (Section 3.3). Although the staff presents separate analyses and conclusions regarding 28 impacts on the geological environment and on water resources, the combined subsection 29 emphasizes their interrelationship.

30

• Second, the staff presented the environmental justice (EJ) analysis as part of the 31 socioeconomic analysis in Section 3.6. The staff considered it simpler to present the EJ 32 analysis with the supporting socioeconomic information rather than requiring readers to 33 toggle between separate sections to gain an understanding.

34

• Third, the staff developed two separate sections addressing nonradiological and radiological 35 waste management. The staff termed the latter Uranium Fuel Cycle and Radiological Waste 36 Management to also capture uranium fuel cycle impacts.

37 In determining the cumulative environmental impacts associated with the construction, 38 operation, and decommissioning of Hermes 2, the combination of past, present, and reasonably 39 foreseeable actions or projects presented in Appendix A were evaluated along with the potential 40 effects of the Hermes facility.

41 Additionally, the staff considered it more efficient to address cumulative impacts within the 42 sections addressing other impacts to each resource rather than in a separate section as called 43 for in the Final Interim Staff Guidance (NRC 2012-TN5527). Cumulative impacts are defined as 44 impacts on an environmental resource resulting from the incremental impact of the action when

3-1 1 added to other past, present, and reasonably foreseeable future actions regardless of which 2 Federal or non-Federal agency or private party undertakes the other actions (40 CFR 3 1508.1(g)(3) TN428]). Cumulative impacts can result from individually minor but collectively 4 significant actions taking place over time (40 CFR 1508.1(g)(3) [TN428]).

5 3.1 Land Use and Visual Resources

6 3.1.1 Affected Environment

7 The two proposed Hermes 2 non-power test reactors would be built on the same site proposed 8 for the Hermes non-power test reactor. Baseline land use conditions on and around that site, 9 designated as the Kairos site, were characterized in Section 3.1 of the Hermes CP EIS, which is 10 incorporated by reference and was used to develop baseline land use conditions for Hermes 2 11 (NRC 2023-TN9771). The site consists of approximately 185 ac situated in the Heritage Center 12 in the ETTP within the City of Oak Ridge, Tennessee. The site was previously included within 13 the DOE ORR and accommodated two large buildings (i.e., Buildings K-31 and K-33) that were 14 operated by DOE until 1985 as part of the ORGDP.

15 The DOE ceased operation of the ORGDP in 1986. Historical missions at the ETTP resulted in 16 a legacy of contaminated, inactive facilities. After the ORR was listed on the National Priorities 17 List, environmental work at the ETTP was driven by CERCLA requirements. The early CERCLA 18 actions and facility demolitions are complete. Characterization and remedial actions for soil, 19 buried waste, and subsurface structures were implemented under a Soil ROD (DOE 2023-20 TN9801). The Soil ROD, which addresses soil in the K-31/K-33 Area, the location of the 21 Hermes 2 facilities, used the designation unrestricted industrial land use as the basis for 22 defining its remedial action objectives. The remaining CERCLA decisions at the ETTP address 23 contamination in groundwater, surface water, and sediment in the ponds, wetlands, and 24 perennial streams. These decisions will include protection of ecological receptors in aquatic 25 environments (i.e., ponds and streams).

26 The DOE transferred approximately 1,300 ac of those lands, including the 185 ac presently 27 comprising the Kairos site, to the City of Oak Ridge for industrial development. The deeds 28 transferring the properties to Kairos contain Land Use Control restrictions established under the 29 Soil ROD for the K-31/K-33 Area that limit development to industrial and commercial uses; allow 30 for continued DOE access as needed to complete CERCLA cleanup actions; and prohibit 31 groundwater extraction, consumption, exposure, or use, in any way (DOE 2023-TN9801). The 32 designation for an end use of unrestricted industrial use restricts any excavation or penetration 33 below 10 ft and requires FFA tri-party (DOE, EPA, and TDEC) approval. A series of FFA 34 tri-party letters from 2014 was issued regarding the request and approvals of soil penetration 35 and/or excavation to depths greater than 10 ft below the ground surface in the greater K-33 36 Area where the Hermes 2 facility will be located (DOE 2023-TN9801). According to the 37 applicant, Kairos purchased the site in July 2021 and has full control of the property, with all 38 deed restrictions (Kairos 2024-TN9866).

39 By the time Kairos begins construction of Hermes 2, construction of the Hermes reactor may be 40 underway. Kairos states in Section 2.1 of the ER that it anticipates beginning construction of 41 Hermes 2 in early to mid-2025 (Kairos 2023-TN9774). Section 3.1.2 of the Hermes CP EIS, 42 used to inform construction impacts, and incorporated by reference, indicates that as much as 43 138 ac of the 185 ac site could be in a state of temporary disturbance at that time (NRC 2023-44 TN9771). Those areas could at the time be accommodating the partially built Hermes facilities

3-2 1 as well as construction equipment, temporary construction facilities, construction laydown, 2 temporary parking, and other land uses typical of industrial construction sites.

3 Baseline visual conditions of the Kairos site and its surroundings are characterized in 4 Section 3.1 of the Hermes CP EIS, which was used to inform visual impacts and is incorporated 5 by reference (NRC 2023-TN9771). The site is visually typical of an industrial park, with forested 6 areas to the north. Using a subjective rating process developed by the Bureau of Land 7 Management, the Hermes CP EIS characterizes the site and surroundings as being of low 8 scenic quality. However, at the time the staff prepared the Hermes CP EIS, the entire Kairos site 9 was vacant. Because of the presence of site disturbance, construction equipment, and the 10 partially built Hermes test reactor, the NRC staff expects that the site will have an even greater 11 industrial appearance by the time construction begins on the Hermes 2 reactors.

12 3.1.2 Environmental Impacts of Construction

13 Land use impacts from construction of Hermes 2 would generally be as described for Hermes in 14 Section 3.1.2 of the Hermes CP EIS, which is incorporated by reference (NRC 2023-TN9771).

15 Section 4.1.1 of the ER (Kairos 2023-TN9774) indicates that Hermes 2 would be consistent with 16 the existing zoning for the Kairos site and be compatible with nearby existing land uses.

17 Hermes 2 would not affect any special land uses or agricultural land, such as prime or unique 18 farmland. Temporary land disturbance would be confined within the same 138 ac subject to 19 temporary disturbance to build Hermes. According to the Section 2.2.2 of the ER (Kairos 2023-20 TN9774), permanent land occupied by Hermes 2 would consist of approximately 30 ac, which 21 would overlap with land permanently occupied by Hermes. Hermes 2 would be built directly 22 north of Hermes and like Hermes be situated within the former footprint of the razed DOE 23 Building K-33 (Figure 1-1). No land disturbance for Hermes 2 would take place in floodplains.

24 Activities to build Hermes 2 would be visually compatible with the existing industrial setting of 25 the Kairos site. The height and size of the two Hermes 2 test reactor buildings would visually 26 resemble the Hermes test reactor characterized in Section 3.1 of the Hermes CP EIS, which is 27 incorporated by reference (NRC 2023-TN9771). The applicant has indicated that the visual 28 analysis presented for Hermes in the EIS would not generally change because of construction 29 of Hermes 2 (Kairos 2024-TN9866).

30 As characterized by the applicant in Appendix A of the ER (Kairos 2023-TN9774), developing 31 Hermes 2 would also require building a short 161-kilovolt electrical transmission line extending 32 from an onsite switchyard westward across other private property in the Heritage Center to an 33 existing Tennessee Valley Authority transmission line. Based on Figure 1-1, the NRC staff 34 estimates that the transmission line would extend approximately 600 ft west of the Kairos site 35 and require approximately 1.4 ac of additional land in the ETTP, assuming a right-of-way width 36 of 100 ft. Building the transmission line would involve only existing industrial land on the Kairos 37 site and elsewhere within the Heritage Center of the ETTP and would not substantially interfere 38 with use of that land.

39 3.1.3 Environmental Impacts of Operation

40 Land use impacts from operation of Hermes 2 would generally be as described for Hermes in 41 Section 3.1.2 of the Hermes CP EIS, which is incorporated by reference (NRC 2023-TN9771).

42 There would not be any substantial land use changes from Hermes 2 over its anticipated 11-43 year operational period. The staff does not expect there to be any substantive changes to the 44 overall visual appearance of the Hermes 2 project over operations. Kairos would likely 45 commence decommissioning of the Hermes reactor while the Hermes 2 reactors remain in

3-3 1 operation, which may result in the need for temporary disturbance to additional land on the 2 Kairos site. Because of the large size of the 185 ac Kairos site, the NRC staff does not expect 3 that the land demands for decommissioning Hermes would interfere with operations of Hermes 4 2. Operation of the transmission line is unlikely to affect land use or the visual appearance of the 5 site or surrounding land.

6 3.1.4 Environmental Impacts of Decommissioning

7 Land use impacts from decommissioning Hermes 2 would generally be as described for 8 Hermes in Section 3.1.3 of the Hermes CP EIS, which is incorporated by reference (NRC 2023-9 TN9771). As with Hermes, decommissioning impacts to land use and visual resources would be 10 bounded by the analyses in the generic EIS for decommissioning (NRC 2002-TN7254). There 11 may be a need to temporarily use other land on the 185 ac Kairos site. The 30 ac of land 12 occupied by Hermes 2 could be available for other future industrial land uses after 13 decommissioning, as allowed by future zoning. The general industrial appearance of the Kairos 14 site would remain generally the same during decommissioning, although the vacant site 15 following decommissioning may be less visually obtrusive, depending on its future disposition.

16 3.1.5 Cumulative Impacts

17 As presented in Section 3.0, Section 4.13 of the ER (Kairos 2023-TN9774) indicates that the 18 same past, present, and future actions contributing to the cumulative impacts from Hermes 19 could also contribute to those from Hermes 2, but it notes that Hermes should itself be 20 recognized as an additional contributor to the cumulative impacts from Hermes 2. Included in 21 the list of projects contributing to cumulative impacts to the Hermes 2 analysis (Appendix F) is 22 the TRISO X fuel fabrication facility under development in the Horizon Center of the ETTP to the 23 east. The NRC staff expects that other industrial lots in the Heritage and Horizon Centers of the 24 ETTP could become developed over the course of the Hermes 2 project. As stated for Hermes 25 in Section 3.1.5 of the Hermes CP EIS (NRC 2023-TN9771), incorporated by reference, the 26 NRC staff expects that the cumulative effects of the actions noted above would not generally 27 alter existing land use patterns in the Oak Ridge area or the aesthetic qualities of the 28 surrounding landscape.

29 3.1.6 Conclusions

30 The NRC staff concludes that the potential direct, indirect, and cumulative land use and visual 31 resource impacts from Hermes 2 would be SMALL. As with Hermes, the staff bases this 32 conclusion on the fact that Hermes 2 would be consistent with the City of Oak Ridges zoning 33 and land use objectives for the Heritage Center, would comply with applicable deed restrictions 34 for the Kairos site, and would be functionally and visually compatible with the existing land uses 35 and aesthetics of the industrial park setting. As with Hermes, reuse of former industrial land in 36 an existing industrial park offers an opportunity to achieve energy development objectives 37 without disturbing natural resources such as forests, wetlands, or agricultural land.

38 3.2 Air Quality and Noise

39 3.2.1 Affected Environment

40 3.2.1.1 Climatology and Meteorology

41 The proposed Hermes 2 non-power test reactors would be built on the same site proposed 42 for the Hermes non-power test reactor. Climate conditions for the Kairos site are described

3-4 1 in Section 3.2.1.1.1 of the Hermes CP EIS, which is incorporated by reference, and were used 2 to inform climatology and meteorology impacts for Hermes 2.(NRC 2023-TN9771). The 3 applicant used multiple sources including the National Climatic Data Center to collect 4 climatological data. The applicant updated climate conditions for the region for Hermes 2, 5 relative to what they presented in their application for Hermes, in Section 3.1 of the ER (Kairos 6 2023-TN9774). Updated temperatures differ from the values presented for Hermes by 7 approximately 1°F. Relative humidity in the region averaged 71 percent based on a 30year 8 period of record from the Knoxville local climatological data (1991-2020) from the National 9 Climatic Data Center, compared to the 73 percent reported for Hermes. Table 3-1 of the 10 Hermes 2 ER presents updated precipitation extremes for the region. Otherwise, the existing 11 climatology and meteorology data presented for the site in the EIS applies to Hermes 2 as well.

12 3.2.1.2 Air Quality

13 The region of influence for this air quality analysis is Roane County. Under the Federal Clean 14 Air Act of 1970, as amended (CAA) (TN1141), the EPA established National Ambient Air Quality 15 Standards (NAAQS) to limit the concentrations of the six criteria pollutants to protect the 16 environment and public health. These pollutants include ozone (O3), carbon monoxide (CO),

17 nitrogen dioxide (NO2), sulfur dioxide (SO2), lead (Pb), and particulate matter. Air quality 18 designations are generally made at the county-level, but designations may also be made for 19 smaller localized areas. The characterization and analysis of the existing air quality in 20 Section 3.2.1.1.2 of the Hermes CP EIS (NRC 2023-TN9771) is incorporated by reference. As 21 noted in the Hermes CP EIS, the City of Oak Ridge spans parts of Roane and Anderson 22 Counties, which are part of the Knoxville-Sevierville-LaFollette, Tennessee air quality area and 23 the immediate areas of Roane and Anderson Counties are currently in attainment for all criteria 24 pollutants (NRC 2023-TN9771). Because other areas within Roane and Anderson Counties are 25 designated as maintenance areas under the CAA, the NRC staff uses the thresholds for 26 maintenance areas when assessing impacts of NAAQS emissions from Hermes 2. These 27 thresholds are presented in Table 3-1 below.

28 Table 3-1 Total Estimated National Ambient Air Quality Emissions (metric tons/year) 29 During Construction and Operations

National Ambient Air Quality Standard Criteria Pollutant(a) Threshold (TPY) Construction (T)(b) Operation (TPY)

VOC 50 1.02 0.33 NOx 100 11.58 10.06 CO 100 4.98 2.57 PM2.5 100 0.76 0.30 PM10 100 0.80 0.31 SO2 100 0.02 0.16 Key: CO = carbon monoxide; NOx = nitrogen oxides; PM = particulate matter; SO2 = sulfur dioxide; T = ton(s);

TPY = ton(s) per year; VOC = volatile organic compounds.

(a) Air emission estimates are not provided for Lead (Pb) as they are negligible.

(b) The emissions totals presented are for the 3-year construction period.

Source: 40 CFR Part 93-TN2495; Kairos 2023-TN8172

30 Gases found in the Earths atmosphere that trap heat and play a role in the Earths climate are 31 collectively termed Greenhouse Gases (GHG). GHGs include CO2; CH4; nitrous oxide (N2O);

32 water vapor (H2O); and fluorinated gases, such as hydrofluorocarbons, perfluorocarbons, and

3-5 1 sulfur hexafluoride (SF6). Climate change is a subject of national and international interest 2 because of how it changes the affected environment. Commission Order CLI-09-21 (NRC 2009-3 TN6406) provides the current direction to the NRC staff to include the consideration of the 4 impacts of the emissions of CO2 and other GHGs that drive climate change in its environmental 5 reviews for major licensing actions1. Estimates of GHG emissions from a reference 6 1000 megawatt electric (MWe) advanced reactor were developed using the approach in 7 Interim Staff Guidance COL/ESP-ISG-026 (NRC 2014-TN3767), Interim Staff Guidance on 8 Environmental Issues Associated with New Reactors (NRC 2014-TN3768), and the Council on 9 Environmental Qualitys (CEQs) 2016 final guidance on considering GHGs emissions and 10 effects of climate changes in NEPA reviews (CEQ 2016-TN4732). The NRC is currently 11 reviewing the January 2023 CEQ Guidance: National Environmental Policy Act Guidance on 12 Consideration of Greenhouse Gas Emissions and Climate Change (88 FR 1196) and will update 13 its guidance as necessary. The GHG emissions estimates from the 1000 MWe advanced 14 reactor and the scaling calculations for Hermes 2 are presented in Appendix E. The NRC staff 15 calculated the GHG emissions for Hermes 2 to be approximately 38,000 metric tons (MT) of 16 CO2e using the assumptions discussed in Appendix E. Comparing the entire life cycle 17 estimated GHG emissions from construction, operation, the uranium fuel cycle, transportation of 18 fuel and waste, and decommissioning activities to the 2019 total gross annual U.S. energy 19 sector emissions, the Hermes 2 GHG emissions would be about 0.0007 percent of the 2019 20 GHG emissions from the U.S. energy sector.

21 3.2.1.3 Noise

22 Noise is unwanted or unwelcome sound usually caused by human activity that is added to the 23 natural acoustic setting. Although sound pressure levels are measured in decibels, noise levels 24 in environmental analyses are commonly expressed using A-weighted sound levels (dBA) that 25 are adjusted to better reflect how the human ear perceives sound. The characterization and 26 analysis of existing noise conditions in Section 3.2.2.1 of the Hermes CP EIS (NRC 2023-27 TN9771) is incorporated by reference. The nearest noise receptors within a 5 mi radius of the 28 Hermes site include several churches and two parks (the adjacent Black Oak Ridge 29 Conservation Easement and the Oak Ridge Country Club 4.9 mi to the northeast) . The nearest 30 resident is situated approximately 1.1 mi from the reactor center and 0.7 mi north of the Hermes 31 site boundary but is separated from the site by forests.

32 3.2.2 Environmental Impacts of Construction

33 3.2.2.1 Air Quality

34 Air quality impacts from construction of Hermes 2 would be similar to those described for 35 Hermes in Section 3.2.1 of the Hermes CP EIS, which is incorporated by reference and is relied 36 upon in development of the Hermes 2 impact analysis (NRC 2023-TN9771). The applicant lists 37 the total emission estimates during construction of the Hermes 2 reactors Table 4.2-1 in the ER 38 (Kairos 2023-TN9774). The impacts of air quality due to the construction of the Hermes and 39 Hermes 2 reactors would be similar. By the time Kairos begins construction of the Hermes 2 40 reactors, construction of the Hermes reactor may be underway. If so, then the emissions 41 presented for Hermes 2 in Table 3-1, would take place simultaneously with those for Hermes, 42 as presented in Section 3.2.1.2 of the Hermes CP EIS (NRC 2023-TN9771). Even if added

1 The Commission stated that the Staffs analysis for reactor applications should encompass emissions from the uranium fuel cycle as well as from construction and operation of the facility to be licensed (CLI-09-21 [NRC 2009-TN6406], at 6).

3-6 1 together the totals would be well below the corresponding NAAQS standards presented in 2 Table 3-1.

3 GHG emissions estimates during construction for Hermes 2 are presented in Table 3-5 in 4 Appendix E of this EA. The applicant lists the total emission estimates during construction of the 5 Hermes 2 reactors Table 4.2-1 in the ER (Kairos 2023-TN9774). The impacts of air quality due 6 to the construction of the Hermes and Hermes 2 reactors would be similar. By the time Kairos 7 begins construction of the Hermes 2 reactors, construction of the Hermes reactor may be 8 underway. If so, then the emissions presented for Hermes 2 in Table 3-1, would take place 9 simultaneously with those for Hermes, as presented in Section 3.2.1.2 of the Hermes CP EIS 10 (NRC 2023-TN9771). Even if added together the totals would be well below the corresponding 11 NAAQS standards presented in Table 3-1. GHG emissions estimates during construction for 12 Hermes 2 are presented in Table E-5 in Appendix E of this EA.

13 3.2.2.2 Noise

14 Noise generation from construction of the Hermes 2 reactors is expected to be similar to that 15 described for the Hermes reactor, and as such, Section 3.2.2 of the Hermes CP EIS, is used to 16 inform the environmental impacts of noise and is, therefore incorporated by reference (NRC 17 2023-TN9771). Table 4.2-3 of the Hermes ER, (Kairos 2023-TN8172) lists the typical noise in 18 dBA from the construction equipment anticipated for Hermes. Similar equipment would be used 19 to construct Hermes 2. In its ER submittal (Kairos 2022-TN7912), Kairos states that the nearest 20 residence is approximately 1.1 mi from where the reactors would be built. As noted in Section 21 3.2.2.2 of the Hermes CP EIS, noise from most construction equipment would not increase by 22 more than 3 dBA over ambient levels, and therefore, would not likely be perceptible to persons 23 at nearby sensitive locations, and this is also the case for Hermes 2. Similar to Hermes, it is 24 possible that noise increases from Hermes 2 might be temporarily perceptible at sensitive 25 locations during operation of certain heavy equipment such as pile drivers. But the Hermes CP 26 EIS characterized the effects of these temporary noise events as minimal which is expected to 27 also be the case for Hermes 2.

28 3.2.3 Environmental Impacts of Operation

29 3.2.3.1 Air Quality

30 Air emissions during operations of Hermes 2 would be similar to those described and analyzed 31 for Hermes in Section 3.2.1.3 of the Hermes CP EIS (NRC 2023-TN9771), which is, therefore, 32 incorporated by reference and used in the Hermes 2 evaluation. Table 3-3 in the EIS presents 33 emission estimates during Hermes operation. The emission estimates are well below the 34 NAAQS thresholds for maintenance areas, shown in Table 3-1 of the EIS. Similar to Hermes, 35 the design of Hermes 2 does not call for use of auxiliary boilers or cooling towers. The design 36 does include a cooling system that uses external mechanical aircooled condensers but does 37 not use opencycle, evaporative cooling. For this reason, the staff does not expect there to be 38 any impacts to local meteorology (localized icing or fogging) or impacts from cooling plumes.

39 Table 3-1 lists the NAAQS emissions estimates for Hermes 2 operations. The impacts of air 40 quality due to the operation of Hermes and each unit of Hermes 2 would be generally similar.

41 GHG emissions estimates for operations for Hermes 2 are presented in Table E-5 in 42 Appendix E of this EA.

3-7 1 3.2.3.2 Noise

2 Noise impacts during operation of Hermes 2 would be similar to those described and analyzed 3 for Hermes in Section 3.2.2.3 of the Hermes CP EIS (NRC 2023-TN9771), which is, therefore, 4 incorporated by reference, and used in the Hermes 2 evaluation. But as noted in Section 4.2.2.2 5 of the ER (Kairos 2023-TN9774), there would be additional noise generation from simultaneous 6 operation of the Hermes reactor; the two Hermes 2 reactors; the Hermes 2 power generation 7 systems, including a turbine; and dry aircooled condensers. The nearest resident is 8 approximately 1.1 mi away from the project site and is separated by forest and the Black Oak 9 Ridge, creating a sound buffer. The power generation systems would be housed within the 10 turbine building. As explained by the applicant during the audit (Kairos 2024-TN9866), the air-11 cooled condensers would not generate noise levels in excess of 70 dBA at 1000 ft from the 12 condensers. Noise generation from three Hermes reactors operating simultaneously would be 13 estimated at 75 dBA. Additional attenuation offered by vegetation and topography would serve 14 to lower the average noise level from the estimated 61 dBA at the nearest resident. As noted by 15 DOE in an EA prepared for a proposed airport in Oak Ridge (DOE 2016-TN7903), 65 dBA is the 16 maximum compatible level with a residential area. As noted in Section 3.2.2.3 of the Hermes CP 17 EIS, the NRC staff expects that the noise generated by operation of reactors such as Hermes 18 within an established industrial park would effectively blend in with other industrial noises and 19 not generally be noticeable to residents in the surrounding area.

20 3.2.4 Environmental Impacts of Decommissioning

21 Air emission impacts from decommissioning Hermes 2 would generally be as evaluated for 22 Hermes in Section 3.2.1.4 of the Hermes CP EIS (NRC 2023-TN9771), which is, therefore, 23 incorporated by reference and used in the evaluation for Hermes 2. The only differentiation is 24 that the area to be decommissioned would be slightly larger since Hermes 2 is for two reactors.

25 Activities, equipment usage, and associated emissions are expected to be similar but less than 26 those during construction of Hermes 2 because decommissioning activities are less extensive.

27 Similarly, the analysis of noise impacts from decommissioning of Hermes 2 would generally be 28 as described and evaluated for Hermes in Section 3.2.2.4 of the Hermes CP EIS, which is, 29 therefore, incorporated by reference. There would however be longer periods of noise 30 generation because Hermes 2 involves two reactors (Kairos 2023-TN9774), but the staff 31 expects that impacts would still be bounded by the generic EIS for decommissioning (NRC 32 2002-TN7254) and be brief and temporary enough to not be objectionable to the surrounding 33 community. GHG emissions estimates for decommissioning activities for Hermes 2 are 34 presented in Table E-5 in Appendix E of this EA.

35 3.2.5 Cumulative Impacts

36 Cumulative impacts on air quality and noise from Hermes 2 would generally be as described 37 and evaluated for Hermes in Sections 3.2.1.5 and 3.2.2.5 of the Hermes CP EIS (NRC 2023-38 TN9771), which are, therefore, incorporated by reference. However, the staff also considered 39 the additional emissions and noise from Hermes 2 and Hermes in the evaluation of cumulative 40 impacts. As described in Section 3, other past, present, and currently foreseeable actions are 41 listed in Appendix F, Table F-1. Implementation of the mitigation measures described in the 42 Hermes CP EIS would minimize impacts to local ambient air quality and the nuisance impacts to 43 the public in proximity to the project. Impacts to air quality from construction activities are 44 expected to be minor, localized, and shortterm; therefore, overlapping construction schedules 45 are not expected to contribute significantly to cumulative effects. The projects would both be

3-8 1 governed by air permits processed through TDEC. Noise during construction of the Hermes 2 2 would be temporary. Though construction of the Hermes and Hermes 2 facilities may be 3 concurrent, the equipment and workforce for the two projects would largely be shared, thereby 4 limiting noise generation.

5 3.2.6 Conclusions

6 The NRC staff concludes that the potential direct, indirect, and cumulative meteorology and air 7 quality impacts of the proposed action would be SMALL. Air emissions from Hermes 2 would be 8 well below NAAQS thresholds and not be a major source of air emissions. The NRC staff 9 concludes that the potential direct, indirect, and cumulative noise impacts of the proposed action 10 would be SMALL. Noise from heavy construction equipment may increase during construction 11 of Hermes 2. However, the noise would be unlikely to noticeably interfere with use and 12 enjoyment of surrounding properties. The noise generated by construction, operation, and 13 decommissioning of Hermes 2 would likely blend in with typical noise of an active industrial 14 park.

15 3.3 Hydrogeology and Water Resources

16 3.3.1 Hydrogeology

17 3.3.1.1 Affected Environment

18 The geographic location and geologic conditions at the site are characterized in Section 3.3.1 of 19 the Hermes CP EIS (NRC 2023-TN9771), which describes the Valley and Ridge physiographic 20 province where the site is located and the geologic history that created the conditions of the site 21 prior to its development. Weathering of ridges composed of limestone, shale, and dolomite 22 resulted in an accumulation of approximately 20 ft of clay, silt, and sand in the lower lying areas.

23 Soils on the site have been physically disturbed by decontamination, decommissioning, and 24 demolition activities for the industrial facilities that once occupied the land. This soil remediation 25 was conducted to a depth of 10 ft. The primary pollutant in these soils is mercury. Geotechnical 26 properties of the sites soils are provided in Section 2.5.2.2 of the Hermes 2 facility PSAR 27 (Kairos 2023-TN9774). Past development, use, and decommissioning of industrial facilities by 28 the DOE has resulted in a relatively flat site with no distinguishable surface water drainage 29 features. Decommissioning of the former DOE facilities left slabs and portions of the foundations 30 behind. The remnants of the foundations have been discovered less than 12 ft beneath the 31 ground surface (Kairos 2023-TN8172 l Sec 3.3.3.3).

32 3.3.1.2 Environmental Impacts of Construction

33 Because land disturbance for Hermes 2 would take place within the same 138 ac portion as the 34 site as Hermes, the evaluation of construction impacts of Hermes 2 would be as described for 35 Hermes in Section 3.3.1.2 of the Hermes CP EIS (NRC 2023-TN9771), which is, therefore, 36 incorporated by reference. The maximum temporarily disturbed area for construction of 37 Hermes 2 would encompass the same 138 ac. Geological disturbance to the site would include 38 excavation and may include blasting if conditions require. These disturbances could expose soil 39 contaminated by previous site occupants. Excavated soil suitable for backfill would be 40 stockpiled onsite. Soil that is not suitable for structural backfill would instead be used as non-41 structural fill (Kairos 2023-TN8172 l Sec 4.3.2).

3-9 1 As noted in Section 4.3 of the ER (Kairos 2023-TN9774), the estimated quantities of geologic 2 material necessary for the construction of the Hermes 2 facility would be:

3

• backfill: 222,666 cubic yards around structures in main excavation (reuse of suitable 4 material excavated onsite) 5

• topsoil: 1,066 cubic yards, acquired from onsite sources 6

• granular road base: 9,284 cubic yards 7

• asphaltic pavement: 17,846 cubic yards 8

• gravel surfacing: 1,000 cubic yards 9

• underground utilities: 2,344 cubic yards for backfill (reuse of suitable material excavated 10 onsite) 11

• site grading: quantity is to be determined, and to be acquired from material excavated onsite

12 As with Hermes, excavation would not exceed 30 ft below grade, for the Reactor Building and 13 the Auxiliary Systems Building. Utilities would be placed 5 ft below grade, and any additional 14 buildings necessary for construction of Hermes 2 would be excavated to depths of up to 10 ft 15 below grade (NRC 2023-TN9771).

16 3.3.1.3 Environmental Consequences of Operation

17 Geologic resources would not be used or altered during the operation of the Hermes 2 reactors ;

18 therefore, the impact of operations on geologic resources would be negligible. At the OL stage, 19 NRC staff would review the application for any new and significant information that might alter 20 the staffs conclusions made for this CP.

21 3.3.1.4 Environmental Consequences of Decommissioning

22 Decommissioning would have little additional impact on the geologic environment relative to 23 construction (Kairos 2023-TN9774). In addition to NRC requirements for decommissioning, 24 applicable demolition permits and best management practices (BMPs) would minimize the 25 effects of decommissioning impacts on the geologic environment.

26 3.3.1.5 Cumulative Impacts

27 Cumulative geological impacts from Hermes 2 would generally be as described for Hermes in 28 Sections 3.3.1.5 and 3.3.1.6 of the Hermes CP EIS (NRC 2023-TN9771), which is, therefore, 29 incorporated by reference. In addition to the Hermes and Hermes 2 projects, as described in 30 Section 3, past, present, and currently foreseeable actions evaluated are listed in Appendix F, 31 Table F-1. Soil erosion and sediment runoff is a typical effect of surface disturbances. Past, 32 current, and reasonably foreseeable projects in the area would add to the total extent of 33 disturbed soil. Within the site, most of the ongoing and reasonably foreseeable proposed 34 actions would take place on previously industrialized land. The staff also recognizes that Kairos 35 may build a planned fuel fabrication facility (referred to as Kairos Atlas Fuel Fabrication Facility) 36 on the same 185 ac site as that used for Hermes and Hermes 2. The staff anticipates that the 37 applicant would use the same construction BMPs noted above in compliance with Federal, 38 State, and local environmental laws, rules, regulations, and statutes. Neither existing projects 39 nor Hermes or Hermes 2 would further contribute to impacts on the geologic environment

3-10 1 because there are no identified sensitive or economic geologic resources in the area and the 2 proposed facility would be located in a previously disturbed reindustrialized area.

3 3.3.1.6 Conclusions

4 The NRC staff concludes that the potential direct, indirect, and cumulative geological impacts 5 would be SMALL. This conclusion is based primarily on the lack of disturbances to areas of 6 natural terrain and the fact that the disturbances to geology and soils would be limited to 7 previously disturbed industrial lands of low economic value as geologic resources. Reuse of 8 former industrial land provides the economic benefits of the project without requiring the 9 disturbance of natural ground or areas of economically viable geologic resources that have 10 not been previously disturbed.

11 3.3.2 Water Resources

12 3.3.2.1 Affected Environment

13 As can be seen in Figure 3.2-1 of the ER (Kairos 2023-TN9774), hydrologically, the 185 ac site 14 is bounded by Poplar Creek to the east and south and the Clinch River arm of the Watts Bar 15 Reservoir. Secondary drainage features include the K-901 Holding Pond to the west. There is a 16 rapid increase in topography from approximately 765 ft over much of the site to over 1,000 ft just 17 north of the site. Poplar Creek is also a part of the Clinch River arm of the Watts Bar Reservoir, 18 for which water levels and flow patterns are controlled by the power generation and release 19 schedules of the Watts Bar, Fort Loudon, and Melton Hill Dams.

20 The groundwater under the site has been contaminated by previous DOE industrial activities.

21 Nonradiological contaminants of concern for the groundwater are volatile organic compounds 22 and polychlorinated biphenyls. Radiological contaminants of concern are uranium, tritium, and 23 strontium-90. The DOE monitors surface and groundwater within the site and surrounding area 24 (DOE 2021-TN7913 l Figure 2.2) (DOE 2021-TN7915 l Figure 3.24).

25 The applicant indicates in the ER (Kairos 2023-TN9774) that the groundwater monitoring plan 26 for Hermes 2 would be the same as that for Hermes (Kairos 2023-TN8172 l Sec 4.4.3.2.1). The 27 groundwater monitoring plan is a quarterly radiological environmental monitoring plan consistent 28 with NUREG-1301 (NRC 1991-TN5758) and would be implemented alongside monitoring 29 through existing DOE sampling locations. The aquifers beneath or near the site are not 30 classified as sole source by the EPA. There are no liquid effluent release pathways for 31 radionuclides to escape to the surrounding surface waters; therefore, surface water monitoring 32 has been omitted from the radiological environmental monitoring plan.

33 3.3.2.2 Environmental Consequences of Construction

34 The construction of the Hermes 2 reactors would be of similar construction and occupy 35 the same site as Hermes, and, therefore, the evaluation of construction impacts for water 36 resources would have very similar consequences as those described in Section 3.3.2.2 of 37 the Hermes CP EIS (NRC 2023-TN9771) which is, therefore , incorporated by reference.

38 Construction would temporarily disturb the same 138 ac that would be disturbed for construction 39 of Hermes, with 30 ac of that land being permanently disturbed when construction is completed.

3-11 1 The maximum excavation depth would be 30 ft below the finished grade of 765 ft for the 2 Reactor Building and the Auxiliary Systems Building. The water table for the site is 6 to 8 ft 3 below grade. Groundwater would not be used during construction activities but may be 4 extracted as a consequence of dewatering for Reactor Building and the Auxiliary Systems 5 Building excavation. The upper bound of the total dewatering during the 30-day foundation 6 construction period would be 2.2 million gal. The impacts of this dewatering were determined in 7 the Hermes CP EIS (NRC 2023-TN9771 l Section 3.3.2.2) to be limited to the shallow 8 groundwater system on site. Extracted groundwater would be managed in compliance with 9 DOE, EPA, and TDEC, and any water discharge from dewatering or from other construction 10 activities would be handled in accordance with the storm-water discharge permit in compliance 11 with these three agencies.

12 There are neither surface water features on the site that could be affected nor discernable 13 surface water features that drain the site. Runoff flows to either Poplar Creek or to the K-901-A 14 Holding Pond. Stormwater runoff from construction activities would be mitigated by a 15 stormwater pollution prevention plan (SWPP) and other BMPs.

16 As described in Section 3.3.2.2 of the Hermes CP EIS (NRC 2023-TN9771) for the similar 17 excavation needed to build Hermes, dewatering activities from excavations to build Hermes 2 18 are unlikely to have any demonstrable effects on the environment beyond the boundaries of 19 the site. The ER (Kairos 2023-TN9774) reported that no additional information was identified 20 specific to Hermes 2, beyond what was presented for Hermes.

21 3.3.2.3 Environmental Consequences of Operation

22 As noted in Section 4.4.2 of the ER (Kairos 2023-TN9774), water usage during operation of 23 Hermes 2 would be similar to water usage for Hermes; estimated water usage during operation 24 would be 0.17 million gal per day. Water would be supplied by the City of Oak Ridge. Because 25 Hermes 2 would not use raw surface water or groundwater, any effects the facility may have on 26 groundwater during operation are negligible. Section 4.4 of the ER (Kairos 2023-TN9774) 27 reported that no additional information regarding surface water or groundwater was identified for 28 Hermes 2, beyond what was presented for Hermes.

29 3.3.2.4 Environmental Consequences of Decommissioning

30 There may be minor impacts from decommissioning associated with discharge of groundwater 31 from the site to Poplar Creek, but these discharges would be managed in accordance with DOE, 32 EPA, and TDEC requirements. Stormwater runoff from decommissioning activities would be 33 mitigated by a SWPP and BMPs similar to those used during construction. It is expected that 34 decommissioning impacts on water resources would be similar to those described in the generic 35 EIS for decommissioning (NRC 2002-TN7254).

36 3.3.2.5 Cumulative Impacts

37 As described in Section 3, in addition to Hermes, the past, present, and currently foreseeable 38 projects and other actions evaluated are listed in Appendix F, Table F-1. Past and present 39 actions currently affecting water resources in the affected area include Federal facilities for 40 nuclear and energy research such as the Y-12 Plant, Oak Ridge National Laboratory, and other 41 energy research facilities. A housing development is under construction 2 miles (mi) to the west 42 of the site. The construction of this development and future construction in the area, such as the 43 construction of a general aviation regional airport in the vicinity of the site, may impact water

3-12 1 resources in the area. However, it is unlikely that the proposed action will have a demonstrable 2 cumulative impact in the areas of surface water and groundwater due to mitigating measures 3 such as the SWPP and other BMPs limiting discharge to surface water during construction and 4 decommissioning.

5 3.3.2.6 Conclusion

6 The NRC staff concludes that the potential impacts of the proposed action on surface and 7 subsurface water resources would be SMALL. This conclusion is based on the usage of the City 8 of Oak Ridges water supply and wastewater treatment infrastructure for construction, operation, 9 and decommissioning. Compliance with Federal, State, and local regulations regarding the 10 handling of stormwater will ensure any stormwater runoff impacts are small or mitigated to be 11 small. Groundwater will not be used as a source of water for operations, and any impact on 12 subsurface water resources during construction due to dewatering would be temporary in 13 nature.

14 3.4 Ecological Resources

15 3.4.1 Affected Environment

16 The applicant indicates in Chapter 3 of the ER (Kairos 2023-TN9774) that the ecological 17 characterization provided for the site for Hermes is applicable to Hermes 2. The terrestrial and 18 aquatic habitats surrounding the Kairos site are described in Section 3.4.1 of the Hermes CP 19 EIS (NRC 2023-TN9771), which is incorporated by reference. The terrestrial habitat within the 20 185 ac site consists of 88 ac of developed land, 72 ac of herbaceous grassland, 19 ac of 21 deciduous forest, and 6 ac of mixed evergreen/deciduous forest. The developed land and 22 herbaceous grassland areas largely correspond to areas previously occupied by industrial 23 development. The forested areas only occur on the perimeter of the site and in riparian zones 24 separating previously developed land from Poplar Creek. This border between Poplar Creek 25 and the forest includes the only wetlands on the site. There are no aquatic habitats within the 26 site, but it is adjacent to Poplar Creek. There is also a 17 ac holding pond approximately 700 ft 27 west-southwest of the site.

28 The site provides poor quality ecological habitat due to its previous industrial history. The 29 grasses and forbs there are typical of previously disturbed soils. Terrestrial wildlife expected 30 to occur on the site, including mammals, birds, reptiles, and amphibians, is described in 31 Section 3.4.1 of the Hermes CP EIS (NRC 2023-TN9771). Species of wildlife expected to visit 32 the previously developed lands formerly occupied by DOE Buildings K-31 and K-33 are the 33 regionally abundant species typical of open field habitats. Aquatic biota of the Clinch River arm 34 of the Watts Bar Reservoir is described in Section 3.4.1 of the Hermes CP EIS (NRC 2023-35 TN9771). Poplar Creek is a tributary of the Clinch River, and the applicant expects the habitats 36 to be similar. Because of the heavy previous disturbances of the site and the aquatic habitat 37 adjoining it, invasive species occur in large quantities on and around the site.

38 The NRC staff searched the U.S. Fish and Wildlife Service (FWS) Information for Planning and 39 Consultation database and generated a species list for a Hermes 2 action area consisting of the 40 entire 185 ac site on February 28, 2024, updating the earlier searches reported for the same 41 site in Section 3.4.1 of the Hermes CP EIS (NRC 2023-TN9771). The species list (Table 3-2) 42 identified the following with regulatory status under the Federal ESA.

3-13 1 Table 3-2 Species with Regulatory Status under the Federal ESA Species Type Species Status Mammal Gray Bat (Myotis grisescens) Endangered Mammal Indiana Bat (M. soldalis) Endangered Mammal Northern Long-eared Bat (M. septentrionalis) Endangered Mammal Tricolored Bat (Perimyotis subflavus) Proposed Endangered Bird Whooping Crane (Grus americana) Experimental Population Nonessential Fish Spotfin Chub (Erimonax monachus) Threatened Insects Monarch Butterfly (Danaus plexippus) Candidate Flowering Plants Virginia Spiraea (Spiraea virginiana) Threatened Flowering Plants White Fringeless Orchid (Platanthera integrilabia) Threatened

2 The species list did not identify any critical habitat in the action area. The NRC staff recognizes 3 that the species noted above are unlikely to occur anywhere in the action area (i.e., the 185 ac 4 site) other than perhaps in the small areas of forest and other riparian vegetation separating the 5 proposed locations for Hermes and Hermes 2 from Poplar Creek, or in the channel of Poplar 6 Creek. None can be expected to occur in the developed land and herbaceous grassland areas 7 formerly occupied by DOE Buildings K-31 and K-33, where the land disturbance for 8 construction, operation, or decommissioning of Hermes or Hermes 2 would take place.

9 Table 3-3, together with the information included in the subsections below, constitute the NRC 10 staffs biological evaluation for the Hermes 2 CP application.

11 3.4.2 Environmental Impacts of Construction

12 The construction impacts of Hermes 2 would be similar to those described for Hermes in 13 Section 3.4.2 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by reference.

14 Section 4.5.1 of the ER (Kairos 2023-TN9774) indicates that approximately 138 ac of developed 15 land and herbaceous grassland could be temporarily disturbed to build Hermes 2, the same 138 16 ac of land the applicant proposes to disturbance to build Hermes. As noted in the EIS, no 17 wetlands or aquatic habitat would be disturbed, lands disturbed but not permanently occupied 18 by the new facilities would be restored to herbaceous grassland, and stormwater would be 19 managed using BMPs as required by TDEC. Construction would therefore not promote the 20 further establishment of invasive species, and the effects on ecological quality of habitat and 21 wildlife would be minimal.

22 Noise from construction of Hermes 2 may be noticeable to wildlife. As noted in Section 3.2.2.2 23 of this EA, most noise generated by construction of Hermes 2 would be within 3 dbA of ambient 24 noise within 1 mi from the site, but temporary periods of greater noise could occur. The 25 temporary duration of the construction noise and low quality of habitat within the sites industrial 26 setting, as well as the probable acclimation of the local wildlife to current levels of industrial 27 noise, suggest that the noise impacts of construction are unlikely to have a significant impact.

28 3.4.3 Environmental Impacts of Operations

29 The impacts from operation of Hermes 2 would be similar to those described for Hermes in 30 Section 3.4.3 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by reference.

31 In Section 4.5.2 of the ER (Kairos 2023-TN9774), the applicant characterizes the ecological 32 impact of operations for Hermes 2 as similar to Hermes. As noted in the EIS, no additional land 33 would be physically disturbed during operations, and operational noise would be less than for 34 construction. The risk of avian collisions with structures would be similar to construction.

3-14 1 Occasional maintenance of the site would utilize herbicides for weed control. For these reasons, 2 operation is unlikely to adversely affect threatened or endangered species.

3 As noted in Section 3.1 of this EA, the applicant would build a short 161 kV electric transmission 4 line of approximately 600 ft to connect the operating Hermes 2 project to the power grid. The 5 NRC staff recognizes that flying wildlife, including birds and bats, can be physically injured by 6 collisions with transmission towers and conductors or electrocuted if they contact two or more 7 conductors simultaneously. However, the NRC staff describes in Section 4.6.1.1 of the License 8 Renewal Generic EIS (NRC 2013-TN2654) that the potential impacts on migratory bird 9 populations from collisions with nuclear reactor related structures, including electric 10 transmission lines, are minimal (characterized as SMALL). Additionally, the short length of the 11 new transmission line and its presence entirely within an existing industrial area make the 12 potential for substantial collisions with the transmission line low. The License Renewal Generic 13 EIS does not specifically address bat collisions. However, the absence of trees or other high 14 quality bat habitat in or adjacent to the proposed path of the transmission line makes substantial 15 bat collisions unlikely.

16 3.4.4 Environmental Consequences of Decommissioning 17 The impacts from decommissioning Hermes 2 would be similar to those described for Hermes in 18 Section 3.4.4 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by reference.

19 Land disturbance, noise impacts, and bird collisions would be expected to be similar to 20 construction. The NRC staff expects that decommissioning impacts on ecological resources 21 would be bounded by the analyses in the generic EIS for decommissioning (NRC 2002-22 TN7254), which is incorporated by reference.

23 3.4.5 Cumulative Impacts

24 As described in Section 3, in addition to Hermes, the past, present, and currently foreseeable 25 projects and other actions evaluated are listed in Appendix F, Table F-1. The NRC staff expects 26 that other industrial lots in the ecologically disturbed and fragmented Heritage and Horizon 27 Centers of the ETTP could become developed over the course of the Hermes 2 project. The 28 cumulative impacts from Hermes 2 on ecological resources would be as described for Hermes 29 in Section 3.4.5 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by 30 reference. The Atlas facility, like Hermes and Hermes 2, would likely be sited in unused areas of 31 the 185 ac Kairos site previously disturbed by the former DOE Buildings K-31 and K-33, and it 32 would not likely further contribute to loss or degradation of ecological habitats. The close 33 proximity of Hermes, Hermes 2, and Atlas suggests that the addition of Atlas would not likely 34 alter the patterns of noise and physical obstruction experienced by wildlife in the surrounding 35 areas. The current state of the ETTP and adjoining areas is that of fragmented terrestrial habitat 36 and forest land mixed with industrial land.

37 3.4.6 Conclusions

38 The NRC staff concludes that the potential direct, indirect, and cumulative ecological impacts of 39 Hermes 2 would be SMALL. This conclusion is based on the project affecting only previously 40 industrial land in an established industrial park. Noise, light, and physical obstructions may 41 cause negligible to small impacts to local wildlife in the industrial park setting. Anticipated 42 projects in the surrounding area are recognized to have potential impacts, but the proposed 43 action is not expected to contribute to these impacts. The NRC staffs biological evaluation in 44 Table 3-3 concludes that Hermes 2 may affect, but is not likely to adversely affect, (or have no 45 effect on), each species considered.

3-15 1 Table 3-3 Biological Evaluation of Federally Listed Species from Proposed Kairos 2 Hermes 2 Project

Federal Species Status NRC Staff Evaluation Conclusion Gray bat Endangered Baseline information: Flying mammal. See Table 3 -5 of May affect, but (Myotis the Hermes CP EIS (NRC 2023-TN9771), incorporated not likely to grisescens) by reference. adversely affect (MA-Impacts: May forage transiently in riparian forest along NLAA)

Poplar Creek. Unlikely to enter lands where Hermes 2 would be built, operated, and decommissioned because those lands are not currently forested or contain trees and would not for the duration of the Hermes 2 life cycle.

Bats are expected to avoid areas of human activity, so the potential for injuries is minimal. Impact would be discountable and likely limited to minor disturbances while transiting the area due to temporary increases in noise or other human activity.

Indiana bat Endangered Baseline information: Flying mammal. See Table 3-5 of MA-NLAA (M. soldalis) the Hermes CP EIS (NRC 2023-TN9771).

Impacts: May forage transiently in the riparian forest along Poplar Creek. Expected to avoid lands where Hermes 2 would be built, which presently contain only ruderal vegetation of no foraging value. Impact would be discountable and likely limited to minor disturbances while transiting the area due to temporary increases in noise or other human activity.

Northern long- Endangered Baseline information: Flying mammal. See Table 3-5 of MA-NLAA eared bat the Hermes CP EIS (NRC 2023-TN9771).

(M.

septentrionalis) Impacts: May forage transiently in riparian forest along Poplar Creek. Expected to avoid lands where Hermes 2 would be built, which presently contain only ruderal vegetation of no foraging value. Impact would be discountable and likely limited to minor disturbances while transiting the area due to temporary increases in noise or other human activity.

Tricolored Bat Proposed Baseline information: Flying mammal. Information on life MA-NLAA (Perimyotis Endangered history and threats is presented in Section M.6.1.4 of the subflavus) EIS for the Clinch River Nuclear project (NRC 2019-TN6136), proposed for a site roughly 2 mi to the south.

This section is incorporated by reference. Individuals have been recorded in mist net surveys in that area and in acoustic surveys across the ORR.

Impacts: As noted in the Clinch River Nuclear EIS, the tri-colored bat is found in a variety of terrestrial habitats but generally avoids large open fields. It may forage occasionally in the riparian forest along Poplar Creek but can be expected to avoid the large open area of previously developed industrial land where Hermes 2 would be built. Impact would be discountable and likely limited to minor disturbances while transiting the area due to temporary increases in noise or other human activity.

3-16 1 Table 3-3 Biological Evaluation of Federally Listed Species from Proposed Kairos 2 Hermes 2 Project (Continued)

Federal Species Status NRC Staff Evaluation Conclusion Whooping Experimental Baseline information: Wading bird. The whooping crane No Effect Crane (Grus Population is limited in the wild to a single population that nests in americanus) Non-essential Wood Buffalo National Park in Canada and coastal marshes in Aransas, Texas , and occurs in captivity at other specific locations that do not include Oak Ridge (FWS 2023-TN8854).

Impacts: The ruderal upland vegetation on the disturbed soils where Hermes 2 would be built is not suitable habitat.

Spotfin chub Threatened Baseline information: Fish. See Table 3-5 of the Hermes MA-NLAA (Erimonax CP EIS (NRC 2023-TN9771).

monachus)

Impacts: Hermes 2 would not involve physical disturbances of aquatic or riparian habitats. Water demands would be met by municipal or commercial suppliers. Stormwater to be managed by BMPs. BMPs to control sedimentation and runoff. Impact would discountable and limited to non-significant changes in water quality levels due to stormwater runoff.

Virginia spiraea Threatened Baseline information: Shrub. See Table 3-5 of the MA-NLAA (Spiraea Hermes CP EIS (NRC 2023-TN9771).

virginiana)

Impacts: Potential occurrence limited to forested areas.

Physical disturbance for Hermes 2 would be limited to soils previously disturbed for past industrial development. Plants not affected by noise. BMPs to control sedimentation and runoff. Stormwater to be managed by BMPs. Impact would discountable and limited to non-significant changes in water quality levels due to stormwater runoff.

White fringeless Threatened Baseline information: Herbaceous wildflower. See Table MA-NLAA orchid 3-5 of the Hermes CP EIS (NRC 2023-TN9771).

(Platanthera integrilabia) Impacts: Potential occurrence limited to acidic seeps and stream heads. Physical disturbance for Hermes 2 would be limited to soils previously disturbed by past industrial development. Plants not affected by noise.

BMPs to control sedimentation and runoff. Stormwater to be managed by BMPs. Impact would discountable and limited to non-significant changes in water quality levels due to stormwater runoff.

Key: MA-NLAA = may affect but is not likely to adversely affect; NRC = U.S. Nuclear Regulatory Commission.

• Species identified through Information for Planning and Consultation searches conducted by the applicant in May 2021 and the NRC staff in February 2022, for an action area encompassing the entire 185 ac Hermes site.

• Conclusions follow the terminology used by the FWS when providing consultations under Section 7 of the ESA.

• Conclusions are inclusive for the Hermes project for construction, operation, decommissioning, and cumulative effects, based on the information available at the time of the NRC staffs environmental review of the CP.

3-17 1 3.5 Historic and Cultural Resources

2 3.5.1 Affected Environment

3 The NHPA (TN4157), as amended, requires Federal agencies to consider the effects of their 4 undertakings on historic properties; the potential approval of a construction permit for Hermes 2 5 is an undertaking that could potentially affect historic properties, should such properties be 6 present. The NHPA defines historic properties as any prehistoric or historic district, site, 7 building, structure, or object included in, or eligible for inclusion in, the National Register of 8 Historic Places (NRHP). The procedures in 36 CFR Part 800 (TN513) define how Federal 9 agencies meet the statutory responsibilities of the NHPA Section 106 process. If cultural 10 resources are present, their NRHP-eligibility is determined through the application of the NRHP 11 criteria in 36 CFR 60.4 (TN1682) in consultation with the State Historic Preservation Officer, 12 Indian Tribes that attach cultural and religious significance to historic properties, and other 13 interested parties, pursuant to 36 CFR 800.2(c) (TN513). Historic properties are a subset of 14 cultural resources that are considered during the NEPA process. Cultural resources include, but 15 are not limited to, properties that may not be NRHP-eligible or listed; places or landscapes of 16 traditional cultural importance; and sacred, ceremonial, and religious sites.

17 In accordance with 36 CFR 800.8(c) (TN513), the NRC has initiated the NHPA Section 106 18 consultation process and notified consulting parties, including the Advisory Council on Historic 19 Preservation, the Tennessee Historical Commission (THC [i.e., the State Historic Preservation 20 Officer]), Tribes, and the National Park Service (NPS), of its intent to use the NEPA (42 21 U.S.C. § 4321 et seq. TN661) process to comply with Section 106 of the NHPA (see section 22 on consultation below). Through 36 CFR 800.8(c) (TN513), the NRC will complete the NHPA 23 Section 106 process using procedures described in Regulatory Guide 4.2 (NRC 2018-TN6006).

24 The current NRC undertaking and action is the issuance of a CP to Kairos that allows for the 25 construction of the proposed Kairos Hermes 2 project. If Kairos chooses to proceed with its 26 proposed project, they will need to apply for and receive separate OLs from the NRC. The NRC 27 staff would then conduct another environmental review in accordance with 10 CFR Part 51 and 28 complete a separate NHPA Section 106 review and consultation.

29 The NRC has determined that the area of potential effect (APE) for the CP review includes the 30 area at the site and its immediate environs where the character and use of historic properties 31 may be directly (i.e., physically) or indirectly (i.e., visually or auditorily) impacted by land-32 disturbing and building activities associated with the construction and operation of the proposed 33 facility. Specifically, the NRC defined the direct-effects APE as the approximately 185 ac site 34 (i.e., Kairos ownership site boundary) and the indirect-effects APE as the 0.5 mi area around the 35 site, as depicted in Figure 3-2 of the Kairos Hermes CP (NRC 2023-TN9771).

36 3.5.1.1 Cultural Background

37 Because of the recency of the Hermes CP EIS (NRC 2023-TN9771), the cultural background 38 description in Section 3.5.1.1 of that document remains accurate for support of an assessment 39 for Hermes 2 and is incorporated by reference in this EA.

40 3.5.1.2 Historic and Cultural Resources at the Kairos Site

41 As noted in Section 3.5.1.2 of the Hermes CP EIS (NRC 2023-TN9771), the DOE completed an 42 EA in 2011 (DOE 2011-TN4888) prior to transferring the land and facilities within the ETTP to

3-18 1 the Community Reuse Organization of East Tennessee. According to DOEs EA, no prehistoric 2 archaeological resources are known to exist within the ETTP, which also includes the proposed 3 Hermes 2 site. This is due to the massive cut and fill excavation activities associated with the 4 construction, demolition, and decontamination of the former K-25 site and associated facilities 5 (i.e., Buildings K-33 and K-31 buildings). DOE concluded that there are likely no intact 6 archaeological sites to be found within the ETTP (DOE 2011-TN4888). As noted in 7 Section 3.5.1.1 of the Hermes CP EIS (NRC 2023-TN9771), the DOE and the THC signed a 8 memorandum of agreement (MOA) in 1998 to resolve the adverse effects of decontamination, 9 decommissioning, and removal, recycling, and/or disposal of equipment associated with 10 Buildings K-29, K-31, and K-33 as well as other ancillary activities (Kairos 2023-TN8172). This 11 MOA was amended in 2001 to address which diffusion equipment and displays would be 12 retained, and upon completion of MOA stipulations, Buildings K-29, K-31, and K-33 and the 13 ancillary facilities were demolished (Kairos 2023-TN8172). Currently, the site is a brownfield 14 site, and there are no historic properties or intact historic and cultural resources known within 15 the APE.

16 As part of the land transfer, DOE and Heritage Center LLC executed a Quitclaim Deed on 17 September 29, 2017, that stated the grantee shall protect any historical and/or archaeological 18 cultural resources which may be discovered on the premises subsequent to the date of this 19 conveyance and shall comply with the procedures set forth in attached Exhibit C (DOE 2017-20 TN8206, DOE 2017-TN8207). Exhibit C of the Quitclaim Deed states that no land-altering 21 activity of any kind, including, but not limited to, digging or excavation, shall be allowed or 22 conducted in any areas on which archaeological sites and resources are discovered subsequent 23 to the transfer (DOE 2017-TN8206, DOE 2017-TN8207). It further states that the owner of the 24 record shall consult with the State of Tennessee Historic Preservation Officer (i.e., the THC) to 25 determine what measures are required to mitigate any adverse effects and shall carry out the 26 agreed-upon mitigation plan (DOE 2017-TN8206, DOE 2017-TN8207). The NRC reviewed the 27 THC files and confirmed that there are no extant architectural (i.e., above-ground structures) 28 resources within the direct effects APE.

29 As part of field investigation activities that Kairos performed to support NRCs Section 106 30 consultation for the Hermes project, Kairos also considered the Hermes 2 location and 31 undertaking (Kairos 2024-TN9866). A reconnaissance geoarchaeological investigation was 32 completed due to the nature of the landscape, the past cut and fill construction process, and the 33 possibility for resources on the deeply buried 1949 surface and potential paleosols. The need 34 for this investigation was identified due to new information about the landform and construction 35 process for buildings K-33 and K-31 that was confirmed by DOE as the previous landowner.

36 The investigation also was requested by one of the consulting Tribes upon initiating consultation 37 for the Hermes project. The report documenting the results of this investigation was completed 38 in October 2023 and resulted in the subsequent development of an Archaeological Resources 39 Monitoring and Unanticipated Discovery Plan (Kairos 2024-TN9866).

40 The Manhattan Project National Historical Park (NHP), established in 2015, is the only NRHP-41 eligible property located within the indirect effects APE. The Manhattan Project NHP is jointly 42 operated and administered by the DOE and the NPS (DOI 2022-TN7957). The Manhattan 43 Project NHP consists of the K-25 History Center, which opened in 2020 and focuses on the 44 men and women who built and operated the K-25 gaseous diffusion process during the 45 Manhattan Project and Cold War. The proposed viewing platform and associated exhibits will 46 help visitors understand the scope and magnitude of the site, while they learn about the 47 personal stories of the workforce (DOE 2022-TN7897). Future plans include construction of a

3-19 1 viewing platform and wayside exhibits that are the final components of the previously mentioned 2 MOAs related to the K-25 site (DOE 2022-TN7897).

3 To verify its decision to delineate the indirect effects APE for the Hermes project to a 0.5 mi 4 radius around the proposed site, the NRC staff requested that Kairos take viewshed 5 photographs from four known historic and cultural resources located within the vicinity of the 6 proposed Kairos Hermes 2 site (1 mi) but outside of the 0.5 mi area. These historic and cultural 7 resources include the following: the Wheat Community Historic District (archaeological district);

8 the Wheat Community African Burial Ground, the Gallaher and Ellis cemeteries; and the NRHP-9 eligible George Jones Memorial Baptist Church. Kairos provided the photographs as 10 supplemental information, and they are presented in Appendix F of the Hermes CP EIS (NRC 11 2023-TN9771), which is incorporated by reference. The photographs confirm that the proposed 12 project location for Hermes, as well as the proposed adjoining location for Hermes 2 on the 13 same site, are not visible from these historic and cultural resources due to screening from 14 topographic features and vegetation.

15 3.5.1.3 Traditional Cultural Properties

16 Section 3.6.2 of the Hermes ER (Kairos 2023-TN8172), which supports Section 3.5.1.3 of the 17 Hermes CP EIS (NRC 2023-TN9771), states that previous cultural resource surveys throughout 18 the Kairos site, including the location proposed for Hermes 2, have identified eight sites within 19 the vicinity of Oak Ridge that include mounds and/or are known human burial sites, which could 20 be considered sacred sites. None of these sites is located within the direct or indirect effects 21 APE. To date, the results of NRCs NHPA Section 106 consultation efforts for Hermes and 22 Hermes 2, conducted with Tribes that attach cultural or religious significance to historic 23 properties, indicate that no traditional cultural properties are known to be located within the 24 direct or indirect effects APE at the time of publishing this EA.

25 3.5.1.4 Consultation

26 The NRC initiated consultation via a letter dated January 31, 2024, with the THC (NRC 2024-27 TN9778), the Advisory Council on Historic Preservation (NRC 2024-TN9779), and NPS (NRC 28 2024-TN9780); and February 2, 2024, with 16 Federally recognized Tribes (NRC 2024-29 TN9781): (1) Absentee Shawnee Tribe, (2) Alabama-Coushatta Tribe of Texas, (3) Alabama-30 Quassarte Tribal Town, (4) Cherokee Nation Eastern Band of Cherokee Indians, (5) Coushatta 31 Tribe of Louisiana, (6) Eastern Shawnee Tribe of Oklahoma, (7) Jena Band of Choctaw Indians, 32 (8) Kialegee Tribal Town, (9) Muscogee (Creek) Nation, (10) Poarch Band of Creek Indians, 33 (11) Seminole Nation of Oklahoma, (12) Seminole Tribe of Florida, (13) Shawnee Tribe, 34 (14) Thlopthlocco Tribal Town,(15) United Keetoowah Band of Cherokee Indians, and (16) the 35 Cherokee Nation. There are no Federally recognized Tribes currently located within the State of 36 Tennessee. The results of the NHPA Section 106 consultation efforts will be reported in the final 37 version of this EA.

38 3.5.2 Environmental Impacts of Construction

39 The proposed footprint of disturbance for the Hermes 2 project is composed entirely of land that 40 was previously used for industrial purposes (i.e., brownfield). No intact historic or cultural 41 resources currently are known to exist within the proposed project site due to the massive cut 42 and fill excavation activities associated with the construction of the former K-25 site and 43 associated facilities (i.e., Buildings K-33 and K-31) and their subsequent decontamination, 44 demolition, and decommissioning. During development of the EIS for the Hermes CP (NRC

3-20 1 2023-TN9771), new information regarding the potential for the buried 1949 surface and deeply 2 buried paleosols that could contain archaeological deposits was raised (NRC 2023-TN8208).

3 This new information was addressed through consultation for the Hermes CP project and 4 identification efforts for both the Hermes and Hermes 2 CP undertakings completed through the 5 geoarchaeological reconnaissance investigation and subsequent development by Kairos of the 6 Archaeological Resources Monitoring and Unanticipated Discovery Plan (Kairos 2024-TN9866).

7 As discussed by DOE (DOE 2011-TN4888), lease and/or deed restrictions require that if an 8 unanticipated discovery of cultural materials (e.g., human remains, pottery, weapon projectiles, 9 tools, etc.) or sites is made during any development activities, all ground-disturbing activities in 10 the vicinity of the discovery would be halted immediately. Kairos has developed an 11 Archaeological Resources Monitoring and Unanticipated Discovery Plan for implementation that 12 would establish stop work and notification procedures to address the unexpected discovery of 13 human remains or archaeological material (Kairos 2021-TN7880 Section 4.6.1 l, Kairos 2022-14 TN7902, DOE 2017-TN5081). These procedures would be in place prior to commencing 15 ground-disturbing activities (Kairos 2022-TN7902). If human remains or archaeological 16 resources were discovered, work would cease in the area, and notifications would be made in 17 accordance with Tennessee law (T.C.A. § 11-6-107 et seq. -TN7938). If human remains were 18 discovered, Kairos also would notify appropriate local law enforcement. If the human remains 19 were determined to be archaeological in nature, Kairos would notify the Tennessee Division of 20 Archaeology and the THC to determine what further actions would be taken (Kairos 2021-21 TN7880Sec 4.6.1 l, Kairos 2022-TN7902).

22 No impacts are expected to occur to traditional cultural properties because none have been 23 identified in the direct or indirect effects APE at the time of publishing this EA.

24 The Manhattan Project NHP is located at the site of the former K-25 plant that was demolished 25 and is the only NRHP-eligible site located within the indirect-effects APE. As noted in 26 Section 4.1.2 of the ER (Kairos 2023-TN9774), the proposed Hermes 2 reactor building 27 complex would not exceed 100 ft in height. The overall visual setting of the proposed project is 28 predominantly industrial and is in keeping with the current setting of the historical park, which 29 consists of a brownfield site, newly built history center, and concrete pads. Therefore, the 30 construction of Hermes 2 would not adversely affect the Manhattan Project NHP.

31 3.5.3 Environmental Impacts of Operation

32 No impacts to intact historic and cultural resources are expected to occur from operations and 33 maintenance activities. Operations and maintenance activities may entail ground-disturbing 34 activities within the direct effects APE; however, because there is a potential for the buried 1949 35 surface and deeply buried paleosols to contain archaeological deposits, Kairos would follow its 36 Archaeological Resources Monitoring and Unanticipated Discovery Plan and applicable 37 Tennessee law regarding inadvertent discovery of human remains.

38 3.5.4 Environmental Impacts of Decommissioning

39 Impacts from decommissioning are expected to be similar to those resulting from construction 40 activities. Because there are no known intact historic and cultural resources located within the 41 proposed Hermes 2 reactor site, impacts on these resources would not be expected during 42 decommissioning. Decommissioning activities would involve the use of heavy equipment to 43 remove buildings, roadways, and other structures within the APE. However, because there is 44 potential for the buried 1949 surface and deeply buried paleosols to contain archaeological

3-21 1 deposits, Kairos would follow its Archaeological Resources Monitoring and Unanticipated 2 Discovery Plan and applicable Tennessee law regarding inadvertent discovery of human 3 remains.

4 3.5.5 Cumulative Impacts

5 The description of the affected environment above serves as the baseline for the assessment of 6 cumulative impacts on historic and cultural resources. No intact historic and cultural resources 7 are known to exist within the proposed Hermes 2 project area; however, there is potential for the 8 buried 1949 surface and deeply buried paleosols to contain archaeological deposits. The 9 Manhattan Project NHP is the only NRHP-eligible site within the indirect effects APE. As 10 described in Section 3, in addition to Hermes, the other past, present, and currently foreseeable 11 projects and other actions evaluated are listed in Appendix F, Table F-1. Projects within the 12 direct and indirect effects APE that may have a potential cumulative impact on historic and 13 cultural resources include ongoing infrastructure improvements and future urbanization. Past 14 activities include adverse effects associated with the decontamination, demolition, and 15 decommissioning of K-25 and the ORGDP facilities. Adverse effects on historic properties 16 associated with these past activities were resolved by the DOE via execution of 17 MOA(s). Ongoing and future projects include Hermes, cleanup and redevelopment activities at 18 the ETTP, construction and operation of the Atlas facility, and redevelopment activities at the 19 Heritage Center. Development of such projects could affect historic and cultural resources if 20 ground-disturbing activities occur, and the severity of the impacts would vary depending upon 21 the extent of damage caused to archaeological resources and the extent of mitigation required 22 to address adverse effects on historic properties. If new aboveground structures are constructed 23 as part of the present and reasonably foreseeable projects, there could be significant cumulative 24 impacts on the Manhattan Project NHP. However, in most instances, visual impacts can be 25 minimized using creative design and by establishing vegetative screening. Although the 26 Manhattan Project was historically significant in U.S. history, most of the historic structures 27 formerly at the ETTP have already been demolished. Additionally, no known historic properties 28 would be affected by development on the proposed Hermes 2 site; therefore, no additional 29 cumulative impacts on historic and cultural resources would occur.

30 Historic and cultural resources are nonrenewable; hence, certain activities can result in an 31 irretrievable loss of the resource. Therefore, the impact of destruction on historic and cultural 32 resources is cumulative. Overall, the cumulative impacts of the proposed Hermes 2 project 33 combined with other past, present, and reasonably foreseeable future actions is substantial, but 34 the contribution of the proposed Hermes 2 project to those cumulative impacts would be 35 minimal.

36 3.5.6 Conclusions

37 The NRC staff concludes that the potential direct, indirect, and cumulative impacts on historic 38 and cultural resources would be SMALL. Even though other projects in the area surrounding the 39 proposed site have resulted in past impacts and may potentially result in future impacts on 40 historic and cultural resources, the Hermes 2 project would not contribute further to those 41 impacts. The NRC staff has made a preliminary determination of no adverse effect to historic 42 properties from the potential issuance of a CP for Hermes 2.

3-22 1 3.6 Socioeconomics and Environmental Justice

2 3.6.1 Affected Environment

3 3.6.1.1 Socioeconomics

4 This section describes the baseline socioeconomic and EJ characteristics of the Kairos site, 5 including the population demographics and the economy of the region, and the regions 6 infrastructure and public services. Socioeconomic information has been updated from that 7 documented for Hermes in the Hermes CP EIS (NRC 2023-TN9771) to reflect the availability of 8 more recent data where applicable. The NRC staff applies the same five-county economic 9 region of interest (ROI) described in Section 3.6.1 Hermes CP EIS (NRC 2023-TN9771), which 10 is, therefore, incorporated by reference for the socioeconomic and EJ analysis for Hermes 2.

11 The baseline demographic information of the resident populations in the five-county ROI is 12 characterized in Section 3.6.1 of the Hermes CP EIS (NRC 2023-TN9771) and shown in 13 Table 3-4 below. Data were gathered from the most recent decennial census or the most 14 current 5-year data from the American Community Survey. Based on the population projection 15 discussion in Section 3.6.1 of the Hermes CP EIS, the NRC staff assumed that economic 16 regions population will continue to grow around 1 percent per year until about 2080.

17 Table 3-4 Demographic Profile of the Population in the Region of Influence in 2020

Anderson Knox Loudon Morgan Roane Tennessee County County County County County ROI Total 6,910,840 77,123 478,971 54,886 21,035 53,404 685,419 Hispanic or Latino 479,187 2,820 28,568 5,356 299 1,011 38,054 White 4,900,246 66,044 373,790 46,419 19,029 48,094 553,376 Black or African American 1,083,772 2,841 39,853 578 971 1,302 45,545 American Indian and Alaska 15,539 217 1,079 95 54 161 1,606 Native Asian 134,302 975 11,881 450 41 341 13,688 Hawaiian/Other Pacific Islander 3,594 53 300 2 8 19 382 Some Other Race 23,977 272 1,776 161 64 157 2,430 Two or More Races 270,223 3,901 21,724 1,825 569 2,319 30,338 Source: USCB 2020-TN9782

18 The regional economic characteristics (including employment, income, etc.) of the five-county 19 ROI have been updated according to the most recent American Community Survey data. Based 20 on the U.S. Census Bureaus (USCB) 2018-2022 American Community Survey 5-Year 21 Estimates, the number of civilian labor force in the five-county ROI was 344,826 persons and 22 the number of individuals employed was 330,707 (USCB 2022-TN9783). The unemployment 23 rate in the five-county ROI was 4.1 percent. Comparatively, the unemployment rate in 24 Tennessee during the same time period was 5.0 percent (USCB 2022-TN9783). The 25 educational services, and healthcare and social assistance industry, has the largest 26 employment in the socioeconomic ROI, followed by professional, scientific, and management, 27 and administrative and waste management services (USCB 2022-TN9783).

28 Estimated income information for the socioeconomic ROI is presented in Table 3-5 according to 29 USCBs 2018-2022 American Community Survey 5-year estimates. As shown in the table,

3-23 1 people living in Knox County, Loudon County, and Roane County had a median household 2 income higher than the state average while people living in the Anderson County and Morgan 3 County had a median household income lower than the state average (USCB 2022-TN9783).

4 Table 3-6 updates the total number of occupied and vacant housing units, and vacancy rates in 5 the five-county ROI based on the USCBs most recent 2018-2022 American Community Survey 6 5-year estimates. There were 306,185 housing units in the ROI, of which 277,653 were 7 occupied. The vacancy rate is 9.3 percent.

8 Table 3-5 Estimated Income Information for the Socioeconomic ROI (2018-2022, 9 5-Year Estimates)

Anderson Knox Loudon Morgan Roane Parameter County County County County County Tennessee Median household income 60,633 68,580 75,008 51,971 66,460 64,035 (dollars)(a)

Per capita income (dollars)(a) 32,803 39,608 40,425 27,320 36,579 36,040 Families living below the poverty 10.7 7.6 8.7 16.9 8.3 10.0 level (percent)

People living below the poverty 15.4 12.4 11.8 20.9 12.2 14.0 level (percent)

Unemployment rate 5.4 3.8 3.0 8.4 4.9 5.0 (a) In 2021 inflation-adjusted U.S. dollars.

Source: USCB 2022-TN9783

10 Table 3-6 Housing in the ROI (2018-2022, 5-Year Estimate)

Anderson Knox Loudon Morgan Roane County County County County County ROI Total housing units 35,326 212,074 24,780 8,546 25,459 306,185 Occupied housing units 31,275 194,842 22,487 7,093 21,956 277,653 Vacant housing units 4,051 17,232 2,293 1,453 3,503 28,532 Vacancy rate (percent) 11.5 8.1 9.3 17.0 13.8 9.3 Source: USCB 2022-TN9784

11 The applicant indicates in the ER (Kairos 2023-TN9774), that the transportation details related 12 to the construction, operation, and decommissioning of the Hermes 2 facility are similar to 13 Hermes. Because the proposed Hermes 2 reactors would be built on the same site proposed for 14 the Hermes reactor, the NRC staff, also, expects the transportation network baseline is the 15 same for Hermes 2 as that for Hermes. As noted in Table 3.7-1 of the Hermes ER (Kairos 2023-16 TN8172), referenced in Section 3.6.1 of the Hermes CP EIS (NRC 2023-TN9771), the baseline 17 level of service (LOS) estimates for major roads and corridors approaching the site including 18 Perimeter Road, N Perimeter Road, and two bridges over Poplar Creek were ranked as C in 19 2019. The minimum standard for LOS on Tennessee roadways is D NRC 2019-20 TN6136Section 2.5.2.4). Meanwhile, Section 3.6.1 of the Hermes CP EIS (NRC 2023-TN9771) 21 accepted the applicants 2 percent annual growth assumption for the annual average daily traffic 22 volumes of roads serving the ORR based on the historical data analysis. The NRC staff relied 23 on the same assumption for Hermes 2 by estimating the existing road volumes would grow by 24 2 percent annually over 2019-2025.

3-24 1 Tax information is updated to the most recent data with respect to the information presented in 2 Section 3.6.1 of the Hermes CP EIS (NRC 2023-TN9771). Because Hermes 2 would be located 3 within Roane County, a property tax rate of $2.34 per $100 assessed value would apply. In 4 addition, the City of Oak Ridge property tax of $2.3136 per $100 assessed value also would 5 apply (RCT 2024-TN9785).

6 Baseline public infrastructure information (including local land use plans, water and sewer 7 facility, recreation venues, police, fire and medical services, social services, education system) 8 in the economic region is characterized in Section 3.6.1 of the Hermes CP EIS (NRC 2023-9 TN9771). The staff expects this information, based on its recency, still is valid for consideration 10 of the Hermes 2 project.

11 3.6.1.2 Environmental Justice

12 The NRC staff used the same approach for EJ impact assessment applied in the Hermes CP 13 EIS. Because Hermes 2 would be built on the same site proposed for Hermes, the NRC staff 14 determined that the characteristics of the EJ population for Hermes 2 would be the same as 15 indicated in Section 3.6.1.2 of the Hermes CP EIS (NRC 2023-TN9771), which was completed 16 in 2019 and is incorporated by reference. Section 2.6 of the Clinch River Nuclear (CRN) Site 17 EIS (NRC 2019-TN6136) analyzed the 760 census block groups within a 50-mi radius of the 18 nearby proposed CRN Site, of which 27 were identified as aggregate minority and 58 were 19 identified as low-income. Also, the closest EJ block groups are over 5 mi north of the Kairos 20 site. No subsistence or other practices were identified.

21 3.6.2 Environmental Impacts of Construction

22 3.6.2.1 Socioeconomics 23 In Section 2.1 of the ER (Kairos 2023-TN9774), the applicant stated that the construction 24 phase of this project is estimated to require an average of 424 onsite workers (850 at peak 25 times). The estimated duration of construction for each unit of Hermes 2 is 2 years. Total 26 duration of the Hermes 2 construction is estimated to be 3 years, with an overlap in construction 27 of the two units of approximately 1 year, which could be considered the peak construction 28 period (Kairos 2024-TN9866). The socioeconomic impacts related to the construction of Hermes 29 2 are similar to those described in Section 3.6.2 of the Hermes CP EIS (NRC 2023-TN9771) 30 which is, therefore, incorporated by reference. The NRC staff assumed that a third of the 31 maximum construction workforce (about 280 workers) would need to in-migrate, following the 32 approach taken in the Hermes CP EIS. The NRC concludes that the available housing units in 33 the ROI would be adequate to support 850 peak workers and their families.

34 At peak employment, the NRC staff assumed 850 round trip employee commutes per day.

35 Using the Highway Capacity Manual (TRB 2000-TN9065 and AECOM 2015-TN5000),

36 distribution of the 850 construction workers commuting for a single-shift construction schedule 37 would not degrade the LOS for major roads and corridors approaching the site (Kairos 2023-38 TN8172Table 3.7-12, Section 3.7.2). The LOS for these locations would remain as C, which 39 is acceptable by the State of Tennessee.

40 As noted in Section 2.1 of the ER (Kairos 2023-TN9774) and in the RCI Confirmation Letter 41 from the applicant (Kairos 2024-TN9866), deliveries and shipments during construction would 42 require an average 426 truck deliveries of construction materials per month, eight offsite 43 shipments of construction debris per month, 63,600 gal of diesel fuel per month (primarily trucks 44 are used for deliveries), and occasional deliveries of equipment and supplies. The small number

3-25 1 of shipments and deliveries for Hermes 2 would be minimal given the industrial nature of the 2 ETTP. Additionally, prior to startup, the applicant expects delivery of 40 1-ton shipments of low-3 pressure molten salt coolant and 32 shipments of approximately 9 tons each of the intermediate 4 coolant to the site (Kairos 2023-TN9774 Section 2.1). Given the one-time, temporary, nature of 5 these deliveries, the impact of the coolant shipments on traffic in the vicinity would be minor.

6 Kairos is not expecting to need local access road improvements to handle the volume and 7 weight of deliveries to the site (Kairos 2024-TN9866).

8 Based on the above assessment, the NRC staff concludes that the impacts of construction of 9 the Hermes 2 project on socioeconomics would be minimal.

10 3.6.2.2 Environmental Justice

11 As discussed in Section 4.5.6 of the CRN FEIS (NRC 2019-TN6136), which is incorporated by 12 reference, no unique EJ population characteristics or practices could be affected by the CRN 13 construction activities. Given the proximity of the CRN Site to the Kairos site (within 4 mi), the 14 distance from the Kairos site to the nearest potentially affected EJ populations (8 mi), and the 15 small footprint of the Hermes 2 project, both physically and in terms of personnel, no 16 disproportionately high and adverse health or environmental impacts would be expected and no 17 pathways could be identified linking minority or low-income populations with any adverse 18 impacts from the construction of the Hermes 2 project. Therefore, the NRC staff concludes that 19 the construction of Hermes 2 would not result in disproportionately high and adverse impacts to 20 minority or low-income populations.

21 3.6.3 Environmental Impacts of Operation

22 3.6.3.1 Socioeconomics

23 In Section 2.1 of the ER (Kairos 2023-TN9774), the applicant stated that During operations, an 24 estimated average of 59 workers per weekday (101 fulltime positions) are required for staffing.

25 The NRC staff considered the construction workforce impacts as a basis to establish an upper 26 bound for the impacts expected from the operation workforce for the duration of the anticipated 27 11-year operations period, given that the operation workforce is much smaller. There may be 28 planned outages or maintenance activities that could approximately double the workforce size 29 on site during operations, but these activities are not expected to last more than a few months 30 and are not expected to occur more than a few times during the operational life of Hermes 2 31 (Kairos 2024-TN9866).

32 Of all 101 operations positions, 59 workers are expected to be required onsite during normal 33 weekday operations (including nightshifts), and the remaining 42 workers would cover weekend 34 shifts (Kairos 2024-TN9866). During work commuting times, the addition of a maximum of 35 59 operation worker vehicles distributed across the 11 main routes into the ORR would 36 constitute negligible increase in traffic congestion and delay. The small number of shipments 37 and deliveries to Hermes 2 during operation, including an estimated monthly average of 30 truck 38 deliveries and eight offsite waste shipments (Kairos 2023-TN9774Section 2.1) would be minor 39 given the industrial nature of the ETTP. Additionally, 32 shipments per year of the intermediate 40 coolant (9 tons each) would be delivered to the facility during operations. Before the end of the 41 first two years of operation, the Hermes 2 test reactors would require a resupply of 40 one-ton 42 shipments of low-pressure molten salt coolant. The disruption to the quality of traffic during 43 these deliveries in the vicinity would be of short duration.

3-26 1 The NRC staff expects that the maximum temporary increase in property tax revenues 2 associated with the operation of Hermes 2 would be substantially less than 10 percent of the 3 total tax revenue at the city and county levels. Given the current baseline tax revenues for 4 Roane County of $16,938,367 in FY 2019 (RCT 2020-TN9788) and $209,371,435 for the City of 5 Oakridge in FY 2022 (City of Oak Ridge 2022-TN9789), revenue impacts would be minimal and 6 beneficial at the community level.

7 Based on the information provided by the applicant and the resulting assessment above, the 8 NRC staff concludes that the socioeconomic impacts from operations of the Hermes 2 project 9 would be minimal.

10 3.6.3.2 Environmental Justice 11 The NRC staff identified no unique EJ population characteristics or practices that could be 12 affected by operation of the Hermes 2 project, similar to the discussions in Section 3.6.3 of the 13 Hermes CP EIS (NRC 2023-TN9771), which is incorporated by reference. Project operations 14 would not be expected to create impact pathways between the Hermes 2 project and EJ 15 communities. Therefore, the NRC staff concludes that no disproportionately high and adverse 16 human health and environmental effects on minority and low-income populations would be 17 expected.

18 3.6.4 Environmental Impacts of Decommissioning

19 3.6.4.1 Socioeconomics 20 In Section 2.1 of the ER (Kairos 2023-TN9774), the applicant stated that the postoperational 21 decommissioning information and requirements are identical to those detailed for the Hermes 22 reactor, as the Hermes 2 units will be decommissioned in series. Based on this statement and 23 the similarity of Hermes 2 to Hermes, the NRC staff concludes that the socioeconomic impacts 24 from decommissioning of the Hermes 2 project would be the same as Hermes 1 and would be 25 minimal, as described in Section 3.6.4.1 of the Hermes CP EIS (NRC 2023-TN9771) which is, 26 therefore, incorporated by reference.

27 3.6.4.2 Environmental Justice

28 The NRC staff identified no unique EJ population characteristics or practices that could be 29 affected by decommissioning of the Hermes 2 project, similar to the discussions in Section 3.6.4 30 of the Hermes CP EIS (NRC 2023-TN9771), which is, therefore, incorporated by reference.

31 Decommissioning activities would not be expected to create impact pathways between the 32 Hermes 2 project and EJ communities. Therefore, the NRC staff concludes that no 33 disproportionately high and adverse human health and environmental effects on minority and 34 low-income populations would be expected.

35 3.6.5 Cumulative Impacts

36 As described in Section 3, in addition to Hermes, the other past, present, and currently 37 foreseeable projects and other actions evaluated are listed in Appendix F, Table F-1. The 38 cumulative impacts on the socioeconomic and EJ aspects associated with construction, 39 operation, and decommissioning activities of the proposed Hermes 2 project are similar to those 40 indicated for Hermes in Section 3.6.5 of the Hermes CP EIS (NRC 2023-TN9771), which is, 41 therefore, incorporated by referenced. Cumulative impacts were determined to be SMALL in the 42 EIS.

3-27 1 Construction of the Hermes and Hermes 2 facilities would be partially concurrent. The 2 equipment and workforce for the Hermes and Hermes 2 projects would largely be shared, thus 3 limiting cumulative impacts to socioeconomic resources (Kairos 2023-TN9774Section 4.13.7).

4 Consequently, the NRC staff determined the cumulative impacts on the socioeconomic aspects 5 of the Hermes 2 project would be minimal. Meanwhile, no disproportionately high and adverse 6 human health and environmental effects on minority and low-income populations would be 7 expected.

8 3.6.6 Conclusions

9 The NRC staff concludes the potential direct, indirect, and cumulative socioeconomic impacts 10 from Hermes 2 would be SMALL. Meanwhile, no disproportionately high and adverse human 11 health and environmental effects on minority and low-income populations would be expected.

12 This conclusion is based on the following considerations: First, staff relied heavily on the 13 Hermes CP EIS because Hermes 2 will be built on the same site proposed for the Hermes.

14 Second, the surrounding land is already in a state of industrial use and further disturbance 15 of the proposed site would be minor. Third, building or operating additional infrastructure 16 (i.e., utilities, roadways, or rail systems) for the proposed facilities is not anticipated. Given that 17 the nearest potentially affected environmental justice populations are over 8 mi away, and the 18 small footprint of Hermes 2, both physically and in terms of personnel, no disproportionately 19 high and adverse human health and environmental effects on minority and low-income 20 populations would be expected.

21 3.7 Human Health

22 3.7.1 Nonradiological Human Health 23 The following section addresses the potential effects of occupational hazards on the health of 24 people working on or near the Hermes 2 site, including effects caused by physical, electrical, 25 and chemical sources.

26 3.7.1.1 Affected Environment

27 The nonradiological background of the site is characterized in Section 3.7.1.1 of the Hermes CP 28 EIS (NRC 2023-TN9771), which is incorporated by reference. The Kairos site where Hermes 2 29 would be sited is an industrial site formerly occupied by DOE buildings. The site has been 30 remediated and levels of radioactive and nonradioactive contaminants are below risk-based 31 standards for industrial sites but above background levels. The surrounding area is occupied by 32 other industrial sites and fragmented forest habitat.

33 3.7.1.2 Environmental Consequences of Construction 34 During construction, nonradiological hazards such as diesel emissions and fuel, oil, chemical 35 solvents, and other material would be present and stored onsite. As noted in Section 4.8.1 of 36 the ER (Kairos 2023-TN9774), emissions from construction activities are expected to remain 37 below 100 tons per year for criteria pollutants during concurrent construction of the Hermes unit 38 and construction of the two Hermes 2 units. Section 3.7.1.2 of the ER (Kairos 2023-TN9774) 39 references Table 4.8-2 of the Hermes ER (Kairos 2023-TN9774), which details the occupational 40 hazards associated with construction activities for the similarly designed Hermes. The applicant 41 also reports in Section 4.8.1 (and Table 4.8-2) of the ER (Kairos 2023-TN9774) that the only 42 additional occupational physical hazards for Hermes 2 (compared to Hermes) would be related 43 to BeNaF and anhydrous hydrogen fluoride.

3-28 1 3.7.1.3 Environmental Consequences of Operation

2 According to Section 2.1 of the ER (Kairos 2023-TN9774), an estimated 43,110 gal of diesel 3 fuel would be kept onsite for the standby generator during Hermes 2 operations. Additional 4 chemical inventory projected to be kept onsite during Hermes operations is provided in 5 Table 4.8-1 of the ER (Kairos 2023-TN9774). Bounding inventory values include 80,000 lb of 6 FLiBe and 2,000,000 lb of BeNaF.

7 Process safety management of highly hazardous chemicals per 29 CFR 1910.119 (TN654) 8 applies to the facility due to onsite presence of BeNaF and FLiBe at greater than threshold 9 quantity. As noted in Section 4.8.1 of the ER (Kairos 2023-TN9774), anhydrous hydrogen 10 fluoride would be kept at levels below threshold quantity. Workers would have no exposures to 11 biocides, discharge streams, or any microbial threat from warmed surface water, because 12 Hermes 2, like Hermes, would not discharge to surface water. As for Hermes, discharge of 13 gaseous waste would be passed through a high efficiency particulate air filtration system prior to 14 venting to the atmosphere, and additional controls might be implemented as required. Section 15 4.8.1 of the ER (Kairos 2023-TN9774) indicates that the same would be true for Hermes 2.

16 Compliance with Occupational Safety Health Administration and National Institute of 17 Occupational Safety and Health regulations is mandatory and would ensure the safety of 18 properly qualified and trained site workers on the site where hazardous materials and wastes 19 would be present.

20 3.7.1.4 Environmental Consequences of Decommissioning

21 In Section 4.8.1 of the ER (Kairos 2023-TN9774), the applicant states that there is no additional 22 information that would differentiate the decommissioning of Hermes 2 from Hermes. In 23 Section 3.7.1.4 of the Hermes CP EIS (NRC 2023-TN9771), the NRC staff determined that the 24 decommissioning impacts of the Hermes facility would be bounded by the analyses for physical, 25 chemical, ergonomic, and biological hazards in the generic EIS for decommissioning (NRC 26 2002-TN7254). Because the applicant presents no additional information specific to 27 decommissioning for Hermes 2 in Section 4.8 of the ER (Kairos 2023-TN9774), Hermes 2 also 28 would be bounded by the generic EIS for decommissioning.

29 3.7.1.5 Cumulative Impacts

30 As described in Section 3, in addition to Hermes, the other past, present, and currently 31 foreseeable projects and other actions evaluated are listed in Appendix F, Table F-1 32 (Tables 4.13-1 and 4.13-2 of the Hermes ER (Kairos 2023-TN8172) and referenced in the CP 33 EIS (NRC 2023-TN9771)). Construction of the Hermes 2 facility overlapping with construction of 34 the Hermes facility would result in longer exposures to occupational hazards associated with 35 construction and higher emissions; however, this effect would be mitigated by previously 36 mentioned safety measures, and emissions are anticipated to remain under 100 tons per year.

37 In Section 4.13.8 of the ER (Kairos 2023-TN9774), the applicant states that there is no new 38 information regarding cumulative impacts related to nonradiological human health. Other 39 projects in the surrounding area may contribute to air quality reaching a non-attainment status.

40 Construction and decommissioning activities of the proposed action could further decrease air 41 quality temporarily, but dust suppression and other BMPs would limit these emissions and 42 mitigate their human health impacts. The limited amounts of gaseous emissions during 43 operation is unlikely to have a significant impact on air quality in the area.

3-29 1 3.7.1.6 Conclusions

2 The NRC staff concludes that the potential direct, indirect, and cumulative nonradiological 3 human health impacts of the proposed action would be SMALL. This conclusion is based on the 4 applicants plan for mitigation measures such as training, safety practices, and physical control 5 measures. For Hermes, the applicant proposed to perform environmental monitoring to protect 6 human health as required by permitting requirements and committed to procedures and 7 protective measures to ensure protection of human health and the environment (NRC 2023-8 TN9771). Section 4.8.1 of the ER (Kairos 2023-TN9774) indicates that the same would be true 9 for Hermes 2.

10 3.7.2 Radiological Human Health

11 The two proposed Hermes 2 non-power test reactors would be built on the same site proposed 12 for the Hermes non-power test reactor. Figure 1-1 of this EA depicts the physical layout of the 13 Hermes 2 site indicating features, structures, and designated areas. The reactor buildings would 14 contain spent fuel storage with capacity sufficient for 10 EFPYs for each unit.

15 3.7.2.1 Affected Environment

16 No radioactive or hazardous materials are currently stored on the site. The description of the 17 affected environment is summarized in Section 3.7.2.1 of the Hermes CP EIS (NRC 2023-18 TN9771). This information is applicable to the Hermes 2 reactors and is incorporated by 19 reference. The analyses in the Hermes CP EIS Section 3.7.2 (NRC 2023-TN9771) and in the 20 Hermes 2 ER Section 4.8 (Kairos 2023-TN9774) are based on the analysis in the Hermes ER 21 Section 4.8 (Kairos 2023-TN8172). The proposed units would be built in the footprint of the 22 former K-31 and K-33 gaseous diffusion plants. The DOE remediated past levels of chemical 23 and radiological contamination as a part of the demolition and decontamination of the areas 24 prior to releasing for industrial uses. The DOE performed radiological surveys and 25 environmental sampling under the DOE Environmental Management Programs Dynamic 26 Verification Strategy process to assess the condition of the K-31 and K-33 properties for title 27 transfer (DOE 2015-TN7964, DOE 2015-TN7964). As documented in these title transfer reports, 28 there were no exceedances of the measured maximum or average remediation level. Therefore, 29 the K-31 and K-33 Areas have a negligible radiological risk to Hermes 2 workers consistent with 30 EPAs guidance for the protection of human health and the environment.

31 The baseline radiation levels for the Hermes 2 facility are similar to those described in 32 Section 3.7.2.1 of the Hermes CP EIS (NRC 2023-TN9771).

33 The ORR Annual Site Environmental Report (DOE 2023-TN9801) provides the maximum 34 radiation dose a hypothetical offsite individual could receive from DOE activities at the ORR, 35 which was estimated by DOE to be 0.2 mrem from air pathways, 0.9 mrem from water 36 pathways, and 2 mrem from consumption of wildlife harvested on ORR for a total about 37 3 mrem/yr, which is significantly less than 310 mrem annual average dose to people in the 38 United States from background radiation. The two main sources of natural background radiation 39 in the surrounding the East Tennessee area include cosmic radiation produced by collisions of 40 high-energy particles in the upper atmosphere in range of 27 to 31 mrem per year, and naturally 41 occurring terrestrial radionuclides in rocks and soils in the range of 62 to 106 mrem per year.

42 The breathing of radon gas typically adds to natural background dose of 200 rem per year to 43 give an average total natural background dose of approximately 300 mrem per year.

3-30 1 3.7.2.2 Environmental Impacts of Construction

2 Environmental impacts from construction of Hermes 2 would be similar as described in 3 Section 3.7.2.2 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by reference, 4 but for two test reactors rather than one. During the construction phase, radioactive material 5 present on site would be present for constructionrelated activities such as compaction testing 6 and radiography. The controlled conditions would include restricting access to an area when a 7 device using a byproduct sealed source is in use to prevent radiological exposure of the general 8 construction workforce along with possession controls to the radioactive material. These 9 radioactive materials would be present as sealed sources covered by contractor radioactive 10 materials licenses and are operated according to standard operating procedures as described in 11 Section 3.7.2.2 of the Hermes CP EIS (NRC 2023-TN9771). This information is incorporated by 12 reference. These sealed sources of low-level radiation are required to be controlled by the 13 radiation protection program of the holder of the radioactive material license. The sources must 14 have very specific uses that are carried out under controlled conditions. The required radiation 15 protection procedures and monitoring of the radioactive material would ensure that doses to 16 construction workers from such uses of these radiation sources would be well below the annual 17 dose limits for members of the public set forth in 10 CFR 20.1301 (TN283), if not negligible. The 18 impacts from the use of these radioactive materials on Hermes 2 construction workers would 19 not be significant.

20 Because Hermes 2 will be built adjacent to the Hermes test reactor, the expected Hermes 2 21 construction worker dose would be the Hermes test reactor's site boundary annual estimated 22 dose of 2.4 mrem/yr (Kairos 2024-TN9866). This dose is significantly below the regulatory limits 23 of 10 CFR 20.1301 (TN283) of 100 mrem for members of the public and a small fraction of the 24 annual natural background radiation levels at this site. Therefore, based on the controls required 25 for the use of radioactive devices or radioactive material during construction, DOEs remediation 26 of the land prior to any Kairos construction activity, and the low dose to construction workers 27 from Hermes test reactor operation, the NRC staff concludes the radiological impacts during 28 construction would not be significant.

29 3.7.2.3 Environmental Impacts of Operation

30 The radiation sources and expected radioactive effluent of Hermes 2 facility are similar to those 31 described in Section 3.7.2.3 of the Hermes CP EIS (NRC 2023-TN9771) with the exception of 32 additional liquid source of radiation to include BeNaF salt as intermediate coolant, which is 33 cooled and solidified at the end of its life for Hermes 2. This section presents estimated annual 34 doses to facility workers and members of the public from the operation of the Hermes 2 reactors 35 along with radiological environmental monitoring over the anticipated 11-year licensed 36 operational period. The pertinent information presented in Section 3.7.2.3 of the Hermes CP EIS 37 (NRC 2023-TN9771) is similar and applicable for the Hermes 2 reactors and therefore is 38 incorporated by reference.

39 3.7.2.3.1 Occupational Doses

40 Occupational doses due to radiation exposure to workers from all sources at the Hermes 2 41 facility would not result in a dose greater than the occupational dose limits (annual total effective 42 dose equivalent [TEDE] limit of 5 rem) provided in 10 CFR Part 20 (TN283), Subpart C, by 43 incorporating as-low-as-reasonably-possible provisions of 10 CFR 20.1101. Therefore, the NRC 44 staff concludes that the dose impacts to workers from direct exposure sources would be 45 minimal.

3-31 1 3.7.2.3.2 Doses from Radiological Gaseous Effluent Releases

2 The calculated annual total effective dose equivalent, annual average airborne radioactivity 3 concentration, annual average waterborne radioactivity concentration, and other radiological 4 health considerations would be nearly identical on a per unit basis to those addressed in 5 Section 3.7.2.3.2 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by 6 reference. The dose evaluation methodology and assumptions are the same for Hermes 2 as 7 those applied for the Hermes test reactor. Because the Hermes 2 facility consists of two units, 8 the conservatively determined long-term TEDE values for Hermes are doubled to account 9 for the two units at Hermes 2. As noted in Section 4.8.2.4 of the Hermes 2 ER (Kairos 2023-10 TN9774), tritium release is conservatively assumed to be 125,000 Curies/yr for the two-unit 11 Hermes 2 project, based on 62,500 Curies/yr per unit. This bounding tritium emissions rate does 12 not evaluate the anticipated retention of tritium from the reactors and engineered systems. In 13 addition, the Hermes 2 facility also would employ molecular sieve desiccants to capture tritium 14 from the intermediate loop cover gas and the heat rejection radiator enclosure. The gaseous 15 radioactive effluent doses for Hermes 2 are assumed to be bounded by the doses calculated for 16 the Hermes test reactor facility on per unit basis and the dispersion values are assumed to be 17 co-located. This is conservative because the actual maximum atmospheric dispersion (/Q) 18 values for each unit would not be co-located, and additionally no credit is taken for the retention 19 of tritium from tritium management system functions present in the Hermes 2 facilities.

20 Based on the design of Hermes test reactor, the expected exposure pathways to members of 21 the public would principally be from radiological gaseous effluent release as only a small 22 volume of radioactive liquid effluent releases to sewer lines. The analysis pertaining to 23 environmental impacts of operation of Hermes test reactor is summarized and presented in 24 Section 3.7.2.3 of the Hermes CP EIS (NRC 2023-TN9771). This analysis is similar and 25 applicable to the Hermes 2 reactors and is incorporated by reference. The analysis in the 26 Hermes CP EIS Section 3.7.2 (NRC 2023-TN9771) is based on the analysis in Hermes ER 27 Section 4.8.2 (Kairos 2023-TN8172).

28 The calculated dose to maximally exposed individual (MEI) located at 0.5 mi south-southeast 29 within the boundary of the ETTP and the dose to the analytical nearest resident located at 30 1.1 mi north-northwest from air emissions, reported for the Hermes reactor in Table 4.8-3 of the 31 Hermes ER (Kairos 2023-TN8172), as evaluated in the Hermes CP EIS (NRC 2023-TN9771),

32 are doubled to account for two-unit operation of Hermes 2. The calculated annual total effective 33 dose equivalent values are summarized in Table 4.8-3 of the ER (Kairos 2023-TN9774). The 34 resulting annual TEDE from Hermes 2 to the MEI in an unrestricted area and nearest full-time 35 resident is 2.8 mrem and 2.4 mrem, respectively, which is much less than the limiting radiation 36 protection value of 10 mrem of 10 CFR 20.1101(d) (TN283). The external dose rate to the MEI 37 from Hermes 2 reactor operations is assumed to be 2 mrem/yr (based on assumed 1 mrem/yr 38 per unit Hermes test reactor operation). The total annual TEDE from Hermes 2 operations to the 39 MEI in an unrestricted area, and the full-time resident is 4.8 mrem and 4.4 mrem, respectively.

40 The total cumulative annual TEDE (to include combined external dose and gaseous effluent 41 dose) from the operation of both Hermes and Hermes 2 reactors to the MEI in an unrestricted 42 area and nearest full-time resident is calculated to be 7.2 mrem and 6.6 mrem, respectively, 43 which is less than the limiting value 100 mrem (10 CFR 20.1301(a)(1)) (TN283). The calculated 44 total annual TEDE from all three Hermes reactors is much lower than the average background 45 dose in Tennessee from natural sources of 564 mrem/yr (Kairos 2023-TN9774Section 46 4.8.2.4). Based on the calculated radiological doses, NRC staff concludes that the radiological 47 impacts to members of public due to normal operation of both Hermes and Hermes 2 would be 48 not significant.

3-32 1 3.7.2.3.3 Radiological Environmental Monitoring

2 The details regarding radiological monitoring that include effluent monitoring and environmental 3 monitoring are similar to those addressed in Section 3.7.2.3.3 of the Hermes CP EIS (NRC 4 2023-TN9771). This information in Section 3.7.2.3 of that EIS is incorporated by reference.

5 Monitoring instrumentation and sampling equipment may be shared between the facilities where 6 differentiation of the facility of origin is not feasible. A description of the environmental 7 monitoring program for the Hermes 2 facilities would be provided with the OL application.

8 Molecular sieve desiccants would capture tritium from the intermediate loop cover gas in 9 addition to other capture functions. The ingestion exposure pathway, its analysis, and 10 supplemental actions for Hermes 2 are identical to those for Hermes as presented by the 11 applicant in Section 4.8.3.2.4 of the Hermes ER (Kairos 2023-TN8172) and as summarized in 12 Section 3.7.2.3.2 of the Hermes CP EIS (NRC 2023-TN9771).

13 No additional significant information is identified for Hermes 2. Impacts to public health from 14 implementing monitoring would not be significant.

15 3.7.2.3.4 Conclusions

16 Based on the radiological gaseous effluent releases and estimated annual doses to members of 17 the public described above, the doses would be below the appropriate dose limits of 10 CFR 18 Part 20 (TN283). The NRC staff would perform an independent safety review of Kaiross plans 19 for exposure control and radiological effluent monitoring and compliance with applicable 20 regulatory requirements of 10 CFR Part 20, such as 10 CFR 20.1301 (TN283). The NRC staffs 21 independent safety review would be documented in its Hermes 2 SE. Based on the discussion 22 in this section, and the NRC staffs completion of a thorough independent safety review and 23 evaluation of the applicants commitment to comply with applicable requirements, the NRC staff 24 concludes that the environmental impacts from radiological gaseous effluent releases due to 25 operation of the Hermes 2 reactors would not be significant, and further mitigation would not be 26 warranted.

27 3.7.2.4 Environmental Impacts of Decommissioning

28 The impacts from decommissioning Hermes 2 would generally be similar to those for 29 Hermes test reactor as described in Section 3.7.2.4 of the Hermes CP EIS (NRC 2023-30 TN9771). This EIS section is incorporated by reference. Prior to decommissioning the facility, 31 Kairos would provide the NRC with a license termination plan as described in NUREG -1757 32 (NRC 2006-TN6599, NRC 2022-TN8031). The Hermes 2 facility, which consists of two small 33 reactors each of 35 MWt capacity, are only a small fraction of a large light water reactor (LWR) 34 with approximately 3,300 MWt and would have only a fraction of radiological impacts discussed 35 in the generic EIS for decommissioning (NRC 2002-TN7254). Decommissioning impacts from 36 the Hermes 2 projectwith its two small test reactors and associated additional electrical 37 generation equipment and materials requiring disposalwould be bounded by the expected 38 radiological impacts that could occur during the decommissioning of a large LWR as discussed 39 in the generic EIS for decommissioning (NRC 2002-TN7254). Therefore, the decommissioning 40 impacts for Hermes 2 would be small fraction of the impacts discussed in the above noted 41 generic EIS for decommissioning.

42 Because the two Hermes 2 reactors would be built and operate adjacent to the Hermes test 43 reactor, the expected Hermes test reactor decommission worker dose would be the 4.8 mrem/yr

3-33 1 (0.048 mSv/yr) based on each of the Hermes 2 reactors site boundary annual estimated dose 2 of 2.4 mrem/yr (Kairos 2024-TN9866). This dose is significantly below the regulatory limits of 10 3 CFR Part 20 (TN283).

4 3.7.2.5 Cumulative Impacts

5 As described in Section 3, in addition to Hermes, the other past, present, and currently 6 foreseeable projects and other actions evaluated are listed in Appendix F, Table F-1. Potential 7 cumulative environmental impacts on human health associated with construction, operation, and 8 decommissioning activities for the Hermes 2 facility in combination with other past, present, and 9 reasonably foreseeable actions or projects in the area are similar to those described in Section 10 3.7.2.5 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by reference, with the 11 exception of the additional potential cumulative environmental effects of the Hermes 2 facility.

12 The estimated total body dose presented in Table 4.8-3 of the ER (Kairos 2023-TN9774) to the 13 analytical nearest resident from gaseous effluents and direct radiation during operation of the 14 Hermes 2 facility combined would be 4.4 mrem/yr (4.8 for the MEI in an unrestricted area). The 15 estimated total body dose to the analytical nearest resident from gaseous effluents and direct 16 radiation during operation of the Hermes 2 facility from all onsite reactors would be 6.6 mrem/yr 17 (7.2 for the MEI in an unrestricted area).

18 Operations on the ORR release small quantities of radionuclides to the environment. In the 19 2023 ORR Annual Site Environmental Report (ORR 2023-TN9739), detailed analysis of the 20 effective dose received by the MEI from air pathways was determined to be 0.2 mrem/yr.

21 The effective dose to the MEI from water, including drinking, bathing, irrigating, recreating, 22 and fish consumption, was determined to be 0.9 mrem/yr. The effective dose from consumption 23 of wildlife harvested on the ORR, including turkeys, geese, and deer, was determined to be 24 2 mrem/yr. Combined, the annual dose to the MEI in an unrestricted area from normal 25 operations at the ORR is 3 mrem/yr (ORR 2023-TN9739). This dose is approximately 26 0.5 percent of the average background radiation dose in Tennessee (564 mrem/yr).

27 The cumulative radiological impact to members of public from the Hermes test reactor is 28 described in Section 3.7.2.5 of Hermes CP EIS (NRC 2023-TN9771), and the NRC staff 29 concluded that the impacts would be SMALL (not significant). This information is incorporated 30 into this EA by reference. Because there is no additional information regarding potential 31 cumulative radiological impacts in the area, other than the addition of Hermes 2, and because 32 the radiological impacts for Hermes 2 would be minimal, the cumulative impacts are determined 33 to be not significant.

34 3.7.2.6 Conclusions

35 The staff concludes that the potential direct, indirect, and cumulative radiological human health 36 impacts of the proposed action during the Hermes 2 operation and during decommissioning, 37 along with cumulative impacts would be SMALL. This conclusion is based primarily on the fact 38 that the proposed Hermes 2 project is estimated to have radiological effluent releases that would 39 be well below NRC requirements for potential doses to members of the public (e.g., the nearest 40 resident). With appropriate radiological environmental monitoring, expected occupational doses 41 would be less than annual dose limits under 10 CFR Part 20 (TN283) regulations.

3-34 1 3.8 Nonradiological Waste

2 3.8.1 Affected Environment

3 The Kairos site, within which Hermes 2 would be sited, and its surrounding vicinity are 4 characterized in Section 3.1 of the Kairos Hermes CP EIS (NRC 2023-TN9771). Current 5 land use categories within 5 mi surrounding the site include croplands, forested areas, and 6 developed land. Currently, there are no chemical plants, refineries, mining or quarrying facilities, 7 or military facilities within 5 mi, and no radioactive or hazardous materials currently are stored 8 on the site. Residual radioactive and hazardous contamination from previous industrial use have 9 left the site above radiation background levels but below risk-based standards.

10 3.8.2 Environmental Impacts of Construction

11 The applicant states in Section 4.9.1 of the ER (Kairos 2023-TN9774) that the types of 12 nonradiological waste generated by Hermes 2 would be similar to those generated by Hermes, 13 although the quantities would be increased reflecting two rather than one unit. As noted in 14 Section 3.8.2 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by reference, 15 the applicant characterized solid nonradiological waste generated during construction in Section 16 4.9.1.1 of the Hermes ER (Kairos 2023-TN8172). Solid nonradiological waste would include 17 scrap lumber, bricks, sandblast grit, glass, wiring, non-asbestos insulation, roofing materials, 18 building siding, scrap metal, concrete with reinforcing steel, and other similar materials. Liquid 19 nonradiological waste produced during normal activities of Hermes would include fuels, oils, 20 solvents, paints, stains, and other chemicals. Human waste would be the most common liquid 21 waste that would be produced during construction and would be discharged through municipal 22 sewers to the Rarity Ridge Wastewater Treatment Facility. By the applicants estimations, air 23 emissions for Hermes would fall below the 100 ton/yr threshold established by the TDEC for 24 criteria pollutants during construction. Because of the similarities between Hermes and Hermes 25 2, the NRC staff expects that the information about nonradiological waste presented in this 26 paragraph statement above concerning Hermes would also apply to Hermes 2.

27 3.8.3 Environmental Impacts of Operation

28 The applicant states in Section 4.9.1 of the ER (Kairos 2023-TN9774) that the types of 29 nonradiological waste generated by Hermes 2 would be similar to Hermes, although the 30 quantities would be increased reflecting two rather than one unit. Section 3.8.3 of the Hermes 31 CP EIS (NRC 2023-TN9771) indicates that the applicant plans to register Hermes as a Small 32 Quantity Generator (SQG) under the Resource Conservation and Recovery Act of 1976.

33 Because of the similarities between Hermes 2 and Hermes, the NRC staff expects that Kairos 34 would also register each Hermes 2 reactor as an SQG and might perhaps register Hermes and 35 Hermes 2 together as one SQG. No significant sources of nonradiological hazardous waste 36 were previously identified for the similarly designed Hermes. Based on information for Hermes 37 noted in Section 3.8.3 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by 38 reference, the NRC staff expects that the primary sources of solid waste generated by Hermes 39 2 operations would include food waste, food product packaging waste, and disposable office 40 items, and that these waste streams would be managed by recycling, waste reduction efforts, 41 and other BMPs. The NRC staff expected that no nonradiological liquid chemicals would be 42 generated. The primary liquid waste from the site is expected to be human waste. Anhydrous 43 hydrogen fluoride and BeNaF would likely be disposed of on an annual basis, but FLiBe would 44 be stored onsite until decommissioning and would not be disposed of during operations. Any

3-35 1 gaseous effluent from the site during operation would pass through high efficiency particulate air 2 filters prior to release to atmosphere through a vent stack.

3 3.8.4 Environmental Impacts of Decommissioning

4 Waste management during decommissioning would be addressed in a license termination 5 plan developed in accordance with NUREG 1757 ( NRC 2006-TN6599, NRC 2022-TN8031).

6 Nonradiological waste generated during decommissioning activities is anticipated to be similar 7 to construction impacts. Structural material waste such as glass, concrete rubble, wood, and 8 drywall would be generated during decommissioning. Office supplies from the operation of the 9 facility would also be removed from the site during decommissioning and can be reasonably 10 expected to be disposed of.

11 3.8.5 Cumulative Impacts

12 As described in Section 3, in addition to Hermes, the other past, present, and currently 13 foreseeable projects and other actions evaluated are listed in Appendix F, Table F-1.

14 Nonradiological waste generated by the Hermes 2, with the exceptions of the anhydrous 15 hydrogen fluoride, BeNaF, and FLiBe, would be typical to that of an industrial park. The Hermes 16 facility also will generate BeNaF and FLiBe waste, and storage and disposal methods for 17 Hermes 2 will follow the same paths as the Hermes facility. Anhydrous hydrogen fluoride will be 18 used in small quantities only and will only be disposed of on an annual basis. The addition of the 19 Hermes 2 facility is unlikely to strain or overwhelm nearby hazardous waste disposal facilities.

20 Additional hazardous waste generators in the area or proposed projects that could reasonably 21 be developed in the area may require a larger fraction of waste disposal facilities capacity, but it 22 is unlikely that the small fraction used by the proposed action would prevent future projects or 23 compound on existing hazardous waste generators significantly.

24 3.8.6 Conclusions

25 The NRC staff concludes that the nonradiological waste impacts of the proposed action would 26 be SMALL. This conclusion is drawn from the expected categorization of the Hermes 2 facility 27 as an SQG under Resource Conservation and Recovery Act of 1976 and its potential to be 28 considered as an SQG even when its hazardous waste outputs are combined with the Hermes 29 facility. Nonhazardous waste generation by the construction and decommissioning of the facility 30 is unlikely to have an adverse effect beyond the immediate area of the site and any adverse 31 effects would be temporary.

32 3.9 Uranium Fuel Cycle and Waste Management

33 3.9.1 Uranium Fuel Cycle 34 Each Hermes TRISO fuel pebble is estimated to contain 6 g of uranium. The Hermes reactor is 35 designed to use a maximum enrichment of 19.55 weight-percent uranium-235, which is known 36 as High-Assay Low Enriched Uranium (HALEU). The current state of the uranium fuel cycle is 37 presented in Section 3.9.1 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by 38 reference. An estimated 77,600 pebbles, or approximately 466 kg of uranium would be 39 consumed by Hermes 2 each year. An estimated total of 776,000 pebbles, or approximately 40 4,660 kg (4.66 metric tons of uranium) would be consumed over 10 EFPY.

41 Since the publication of the Hermes CP EIS, DOE continues to advance its efforts to secure a 42 domestic supply of HALEU under the HALEU Availability Program with $700 million from the

3-36 1 Inflation Reduction Act to support the development of a domestic supply chain for HALEU (DOE 2 2024-TN9790). First, on November 7, 2023, the Centrus Energy Corporation announced the 3 production of the nations first 20 kg of HALEU at their Advanced Centrifuge Cascade in 4 Piketon, Ohio. This enrichment facility is expected to boost its annual production of HALEU 5 material to 900 kg in 2024 under the DOE contract, with options to produce more in the future 6 (DOE 2023-TN9791). The DOE has issued two requests for proposals (RFPs) regarding 7 HALEU deconversions services (GSA 2023-TN9792) and enrichment acquisition (GSA 2023-8 TN9793). Under the HALEU enrichment acquisition RFP issued on January 9, 2024, the DOE is 9 seeking proposals to award one or more contracts to acquire mining, milling, conversion, and 10 enrichment services to produce and store HALEU in the form of uranium hexafluoride gas (DOE 11 2024-TN9790). The HALEU deconversions services RFP issued on November 28, 2023, seeks 12 proposals to acquire deconversion services to then reconvert HALEU uranium hexafluoride gas 13 to various chemical forms (i.e., uranium metal or an oxide form) that will be used to fabricate 14 fuels required by many advanced reactor developers. The DOE also published on February 29, 15 2024 for public comment the HALEU programmatic draft EIS that analyzes the impacts of 16 DOEs proposed action to acquire HALEU for commercial use or demonstration projects and to 17 facilitate the domestic commercialization of HALEU production (DOE 2024-TN9826). Section 18 3.9.1 of the Hermes CP EIS (NRC 2023-TN9771) indicates that the Hermes test reactor 19 requires approximately 931 kg of uranium over 4 years (232.8 kg/yr), and Section 4.9 of the 20 Hermes 2 ER (Kairos 2023-TN9774) indicates that the HALEU needs for the operation of the 21 two Hermes 2 reactors would be approximately 4,660 kg of uranium over 10 years (233 kg/yr 22 per reactor). For any year that the three test reactors are in operation, the annual amount of 23 HALEU required would be approximately 700 kg. Because these amounts are below the annual 24 HALEU production amount of 900 kg to be produced by Centrus, the DOE could supply the 25 Hermes and Hermes 2 test reactors with the necessary amount of HALEU for operation.

26 Because of the much lower quantity of uranium needed for Hermes 2 than for a 1,000 MW 27 reference large LWR and support from the prior evaluation in the Hermes CP EIS, the NRC staff 28 finds that the impacts from the uranium fuel cycle to produce and fabricate the HALEU TRISO 29 fuel would be much less than the impacts presented in WASH-1248 (AEC 1974-TN23) and 30 Table S-3 in 10 CFR 51.51 (Table S-3) would still be bounding (Kairos 2022-TN9796). GHG 31 emissions estimates of the uranium fuel cycle for Hermes 2 are presented in Table 3-5 in 32 Appendix E of this EA.

33 3.9.2 Radiological Waste Management 34 The radioactive wastes generated and waste systems designed and implemented to limit 35 discharges of radioactive materials in accordance with 10 CFR Part 20 (TN283) are addressed 36 in Section 3.9.2 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by 37 reference. Section 4.9.1 of the ER (Kairos 2023-TN9774) indicates that the radioactive wastes 38 associated with Hermes 2 would be similar to those associated with Hermes, except for 39 increases because of two units, operated for 11 rather than 4 years, and for the intermediate 40 coolant. A portion of liquid waste would be expected to be recycled or packaged and shipped 41 offsite for treatment and disposal. Small amounts may be released to the wastewater treatment 42 plant which would be monitored to be within limits of 10 CFR Part 20 (TN283), Appendix B, 43 Table 3. Liquid (molten) salt wastes would be separated to containerize salt waste where the 44 salt would be collected in storage containers to cool and solidify. This solidified FLiBe would be 45 stored onsite until decommissioning and then disposed as solid radioactive waste. Solid 46 radioactive waste systems produced wet and dry radioactive waste from normal operations and 47 maintenance would be shipped offsite as low-level radioactive waste (LLRW) periodically or 48 stored onsite until decommissioning.

3-37 1 The radioactive waste that would be generated by the operation of Hermes 2 would be similar to 2 that for Hermes as described in Section 3.9.2 of the Hermes CP EIS (NRC 2023-TN9771), with 3 an increase in total waste generation to account for the two Hermes 2 units and an 11 year 4 period. The general information pertaining Hermes reactor radiological waste management 5 presented in Section 3.9.2 of the Hermes CP EIS (NRC 2023-TN9771) is applicable to the 6 Hermes 2 project, which is incorporated by reference in this EA. Analyses in the Hermes CP 7 EIS Section 3.9.2 (NRC 2023-TN9771) and in Hermes 2 ER Section 4.9 (Kairos 2023-TN9774) 8 are based on the analysis in Hermes CP ER Section 4.9 (Kairos 2023-TN8172). Additional 9 radioactive wastes, not already identified in the Hermes ER, that would be generated by the 10 operation of Hermes 2 would include the removal of intermediate BeNaF salt coolant from its 11 circulating system, and an additional waste stream of high specific activity tritium on molecular 12 sieves produced by the tritium management system. Both of these wastes would be disposed of 13 in solid form. The estimated quantities of radioactive waste generated at the Hermes 2 facility 14 are provided in Table 2.6-1 of the ER (Kairos 2023-TN9774), accounting for both units. Based 15 on the information presented for Hermes and Hermes 2, the NRC staff concludes that the 16 impacts from radiological waste generated by Hermes 2 facility would be SMALL.

17 Information pertaining to Fuel Handling and Storage System and New and Irradiated Fuel is 18 described in Sections 2.6.1.2.4 and 2.7.1 of the Hermes ER (Kairos 2023-TN8172) and is 19 similar to that for Hermes 2. The TRISO fuel and moderator pebbles are continually cycled 20 through the pebble handling and storage system, which removes pebbles from the reactor for 21 inspection. When they meet pre-set standards for burnup and integrity, they are removed and 22 replaced. The pebbles that are removed are placed in storage canisters for transfer to onsite 23 canister storage. If necessary, spent fuel canisters would be loaded into dry storage casks for 24 onsite storage on an exterior spent fuel storage pad. Spent fuel would eventually be transported 25 by truck or rail to a final spent fuel repository or a regional spent fuel storage facility. The same 26 annual amounts of spent fuel produced per unit basis for the Hermes reactor is assumed for 27 each of the two Hermes 2 units. The total storage capacity between both units of Hermes 2 is 28 sufficient for 10 EFPY of the 11 years of licensed reactor operation. The radiological impacts 29 associated with the uranium fuel impacts and radiological impacts from wastes generated and 30 managed by the Hermes 2 would not be significant.

31 3.9.3 Conclusions

32 The NRC staff concludes that the uranium fuel cycle impacts and radiological waste 33 management impacts from the operation of Hermes 2 would be SMALL. This conclusion is 34 based on the following.

35

• The relatively low total quantity of uranium (4.66 metric tons of uranium) estimated to be 36 used for the license period of 11 years is much less than the annual amount used to assess 37 Table S-3 impacts.

38

• The TRISO fuel processes impacts for Hermes 2 reactors are bounded by Table S-3 39 assessments.

40

• The spent TRISO fuel environmental impacts from storage onsite or offsite upon cessation 41 of operations would be bounded by the Continued Storage generic EIS.

42

• Any liquid or gaseous radiological waste stream releases would be in accordance with and 43 within regulatory limits of 10 Part 20 (TN283).

44

• The estimated volume of LLRW from Hermes 2 operations would be comparable to or less 45 than the LLRW volume from a nuclear power plant. Additionally, there is adequate capacity

3-38 1 at LLRW disposal sites for potential disposal, and the waste form, especially the chemical 2 form, is acceptable at a LLRW disposal site.

3 Based on the above, the onsite storage of spent TRISO fuel would be similar to LWRs and must 4 meet same regulatory safety requirements.

5 3.10 Transportation of Radioactive Material

6 The radiological environmental impacts resulting from shipment of unirradiated fuel to the 7 Hermes 2 site at the ETTP, shipment of LLRW and mixed waste to offsite disposal facilities 8 during operations, and shipment of spent fuel to an interim storage or permanent repository 9 during decommissioning are addressed in this section. GHG emissions estimates for 10 transportation of unirradiated fuel, spent fuel, and radioactive wastes for Hermes 2 are 11 presented in Table E-5 in Appendix E of this EA.

12 3.10.1 Environmental Impacts of Operation

13 Details of transportation of nuclear materials during operation and decommissioning of the 14 Hermes 2 reactors would be similar to those described for the Hermes reactor in Section 3.10 15 of the Hermes CP EIS (NRC 2023-TN9771), but with an increase in total material generated 16 and transported to account for two units rather than one, the use of the intermediate heat 17 transport system, and the power conversion system. Analyses in the Hermes CP EIS 18 Section 3.10 (NRC 2023-TN9771) and in Hermes 2 ER Section 4.10 (Kairos 2023-TN9774) are 19 based on the analysis in Hermes CP ER Section 4.10 (Kairos 2023-TN8172). The information 20 addressed in Section 3.10 of the Hermes CP EIS is incorporated by reference in this EA.

21 Section 4.10 of the ER (Kairos 2023-TN9774), additional material for Hermes 2 (relative to 22 Hermes) would include construction materials, BeNaF salt, hydrogen fluoride, construction and 23 demolition wastes, and tritium capture materials. The Hermes 2 facility also would receive new 24 intermediate coolant salt (BeNaF). When shipped to the facility site, the coolant salt would be 25 nonradioactive; however, the intermediate BeNaF salt coolant would become radioactive during 26 operation of the two reactors. This BeNaF salt would be transported in 32 shipments of 27 approximately 9 tons each. Approximately 300 tons of BeNaF salt would be needed for startup 28 of both units, and an additional 300 tons of BeNaF would be needed annually. The BeNaF salt 29 would be radioactive at the end of its useful life, and some it is expected to be disposed of 30 during operations. The Hermes 2 reactors would receive shipments of hydrogen fluoride.

31 When shipped to the site, it would be nonradioactive; however, it would become radioactive as it 32 is used in the tritium management system-intermediate heat transport system. The total quantity 33 of hydrogen fluoride onsite would be maintained below 1,000 pounds. This hydrogen fluoride 34 would be transported to the facility in approximately two annual shipments of about 100 pounds 35 each. The estimated quantity of radioactive wastes and corresponding annual number of 36 shipments are summarized in Table 2.6-1 of the ER (Kairos 2023-TN9774).

37 As presented in Section 4.10 of the ER (Kairos 2023-TN9774), fuel would be transported to the 38 Hermes 2 facility either periodically or once per year, and 77,600 pebbles would be consumed 39 by the Hermes 2 reactors each year. This would require approximately 222 containers of new 40 fuel shipped each year consisting of 350 fuel pebbles in a VP-55 container. Assuming a 41 40,000 pound cargo weight limit for shipping, at 750 pounds per fuel container containing 42 350 fuel pebbles, approximately six truck shipments would be needed to transport a years 43 supply of fuel for the facility when operating both units at 35 MWt.

3-39 1 Incident-free transportation impacts of radioactive materials for Hermes reactor are addressed 2 in Section 3.10.1 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by 3 reference in this EA. Radiological impacts were determined for two crew members and the 4 general population exposed along the route of vehicle transport. The details of transportation of 5 radioactive materials and associated environmental impacts from facility operation would be 6 similar for the consideration of Hermes 2 facility. The per-shipment and annual incident free 7 radiological doses due to transportation of radioactive materials from the Hermes reactor facility 8 are addressed in Section 3.10.1 of the Hermes CP EIS (NRC 2023-TN9771), summarized from 9 information provided in Section 4.10 of the ER submitted by Kairos for Hermes and Hermes 2 10 (Kairos 2023-TN8172, Kairos 2023-TN9774). The dose and risk factors per shipment of 11 radioactive materials and annual dose and risk factors for shipment of radioactive materials are 12 presented in those above referenced tables, respectively. Using these dose and risk factors per 13 shipment, the updates to annual incident-free radiological doses due to transportation of new 14 nuclear fuel reflecting the two reactors operation annual total shipments are given in Table 4.10-15 1 of the ER (Kairos 2023-TN9774). The dose values and corresponding risk values are changed 16 due to doubling the number of shipments for new fuel transport. Nevertheless, the change is 17 very small. Therefore, the crew and population doses from annual incident-free radioactive 18 material transport reported for Hermes 2 ER are the same as for Hermes. The total dose to 19 transportation crews transporting radioactive material due to Hermes 2 facility operation is 3.16 20 person-rem/yr. The dose to the members of public due to transportation of radioactive material 21 due to Hermes 2 facility operation is 2.37 person-rem/year. The NRC concluded in NUREG-22 0170 that the average radiation dose to the population at risk from normal transportation is a 23 small fraction of the limits recommended for members of the general public from all sources of 24 radiation other than natural and medical sources (i.e., 100 mrem in a year under 10 CFR 25 20.1301) and is a small fraction of the natural background dose of 300 mrem per year.

26 Therefore, the NRC staff concludes that the Hermes 2 facility effect of radiation exposure from 27 incident-free transportation is not significant.

28 3.10.2 Environmental Impacts from Decommissioning

29 Spent TRISO fuel would be stored in the Reactor Building of Hermes 2 over the life span of the 30 facilities (Kairos 2023-TN9774). Following cessation of operations, the spent TRISO fuel would 31 have to be further stored at the ETTP or shipped offsite to an interim storage facility or a 32 permanent geologic repository. There also would be quantities of LLRW to be addressed during 33 decommissioning for disposal at one or more commercial LLRW disposal sites in the same 34 manner as previously discussed in Section 3.10.2 of the Hermes CP EIS (NRC 2023-TN9771),

35 which is also incorporated by reference for decommissioning impacts.

36 The Hermes 2 facility would not ship spent fuel offsite during reactors expected 11-year OL 37 period and would hold all spent fuel shipments until decommissioning. The spent TRISO fuel 38 could be shipped to an interim storage facility or permanent geologic repository, as discussed 39 in Section 3.10.2 of the Hermes CP EIS (NRC 2023-TN9771). The NRC staff has extensively 40 analyzed the shipments of spent fuel in a number of new reactor licensing reviews to the once-41 proposed Yucca Mountain repository and for three away-from-reactor interim storage facility 42 licensing reviews, as discussed in Section 3.10.2 of the Hermes CP EIS (NRC 2023-TN9771).

43 Prior NRC transportation analyses of spent LWR fuel environmental impacts were bounded by 44 Table S-4 in 10 CFR 51.52. The assessment of LWR spent fuel shipments in NUREG-2125 45 demonstrates providing adequate protection of public health and safety during transportation of 46 spent fuel (NRC 2014-TN3231). The transportation analysis in Section 6.2.2 of the CRN Early 47 Site Permit (ESP) final EIS (NRC 2019-TN6136) assessed 137 normalized annual spent LWR 48 shipments to the once-proposed Yucca Mountain geologic repository, and is incorporated by

3-40 1 reference. The Hermes 2 spent fuel would be transported from the site within a 2-3-year time 2 period resulting in approximately 103 shipments over a 2-year period, assuming 1,900 spent 3 TRISO pebbles in a spent storage container and two spent storage containers in a shipment.

4 Therefore, the annual spent TRISO shipments expected during Hermes 2 decommissioning 5 would be within those of CRN annual spent fuel shipments and would be bounded by the CRN 6 spent fuel transportation environmental impacts.

7 There would be some LLRW shipments for disposal to commercial LLRW sites during 8 decommissioning. Additional LLRW would be generated due to Hermes 2 pertaining to spent 9 FLiBe and intermediate salt BeNaF. However, the number of shipments would be bounded by a 10 total of 46 shipments considered for an 880 MWe reference reactor. The potential 11 environmental impacts for decommissioning of the Hermes test reactor consisting of spent 12 TRISO fuel to interim storage or permanent geologic repository and LLRW shipments to 13 licensed LLRW disposal facilities are addressed in Section 3.10.2 of the Hermes CP EIS (NRC 14 2023-TN9771). These shipments are bounded by an 880 MWe reference reactor. This 15 addressed information is comparable to Hermes 2 operations with an exception to include 16 increased number of potential shipments to account for two units. Nevertheless, these 17 shipments also are bounded by an 880 MWe reference reactor; therefore, the transportation 18 impacts would be minimal.

19 Because of the small size of the facility, its reactors, and support systems, facility 20 decommissioning is considered to be bounded by the NRC assessment in the generic EIS for 21 decommissioning (NRC 2002-TN7254). The NRC also concluded decommissioning of non 22 LWRs (i.e., fast breeder reactor and hightemperature gas reactor) would be bounded by the 23 analyses addressed in generic EIS for decommissioning. Based on this, the NRC staff 24 considers the decommissioning impacts form Hermes would not be significant. Therefore, the 25 impacts from the transportation of radioactive waste from decommissioning the facility would be 26 minimal.

27 3.10.3 Conclusions

28 Based on the quantity of nuclear material and waste acceptable for disposal and employing 29 certified packages in accordance with NRC and U.S. Department of Transportation regulations, 30 the NRC staff concludes that the transportation of fuel and waste impacts from operation and 31 decommissioning of the Hermes 2 would be SMALL.

32 3.11 Postulated Accidents

33 3.11.1 Environmental Impacts of Operation

34 The analysis of the postulated events that are within the design basis of the Hermes test reactor 35 facility are addressed in Section 3.11 of the Hermes CP EIS (NRC 2023-TN9771), which is 36 incorporated by reference. This analysis is similar and applicable for Hermes 2. The analyses in 37 the Hermes CP EIS Section 3.11 (NRC 2023-TN9771) and in Hermes 2 ER Section 4.11 38 (Kairos 2023-TN9774) are based on the analysis in Hermes CP ER Section 4.11 (Kairos 2023-39 TN8172). According to Section 4.11 of the ER (Kairos 2023-TN9774), postulated events for 40 Hermes 2 are within the design basis of the Hermes reactor and a maximum hypothetical 41 accident (MHA) that bounds the radiological consequences of postulated events, with the 42 exception of considerations for the intermediate heat transport loop and power generation 43 systems. The NRC staff performed its review of and discussed the consequences of MHA in 44 Section 3.11.1 of the Hermes CP EIS (NRC 2023-TN9771). Eight potential design basis

3-41 1 accidents are considered within design basis of Hermes test reactor facility. Of the eight events 2 considered, the MHA is an event that could result in radiological consequences exceeding those 3 of any other credible accident. Of the eight event groups considered in the Hermes ER for 4 evaluation, four groups consisting of salt spills, radioactive releases from subsystem 5 component, general challenges to normal operation and internal and external hazard events 6 include new information in consideration for the intermediate heat transport and power 7 generation systems. However, this additional new information has no meaningful change to the 8 insertion of excess reactivity, and therefore, dose consequences are unchanged.

9 The MHA is a heat-up event where hypothetical conditions result in a conservatively analyzed 10 release of the radionuclides circulating in FLiBe, and the risk of radioactive material release 11 distributed in primary system. The MHA analysis is required for the 10 CFR 100.11 (TN282) 12 determination of exclusion area, low population zone, and population center distance. The MHA 13 is a bounding event with conservative radionuclide transport assumptions that challenge the 14 important radioactive retention features of the functional containment. Dose consequences of 15 the MHA for Hermes are addressed in Section 3.11.1 of the Hermes CP EIS (NRC 2023-16 TN9771), which is incorporated by reference, and indicate the whole body dose to be 0.227 rem 17 at the exclusion area boundary and 0.059 rem at low population zone, which are well below the 18 regulatory limit (10 CFR Part 100-TN282) of 25 rem to whole body. Therefore, the MHA also 19 bounds the radiological consequences of the postulated accident for the Hermes 2 reactor 20 facility.

21 The NRC staff will determine whether the safety-related structures, systems, and components 22 will be designed, implemented, and maintained to ensure that they are available and reliable to 23 perform their preventive or mitigative functions when needed so that the likelihood of serious 24 consequences is small. If the NRC determines in its SE that Kairos Hermes 2 has met all the 25 regulatory requirements described above and clearly demonstrates adequate protection of 26 public health and safety, then the likelihood of accidents would be reliably controlled.

27 3.11.2 Cumulative Impacts

28 Cumulative impacts are related to present, and reasonably foreseeable future projects that 29 could cumulatively contribute to the environmental impacts of the proposed action. The 30 cumulative risk considers the total risk from potential severe accidents at all other existing and 31 proposed nuclear facilities that have the potential to increase risks at any location within 50 mi 32 of Hermes 2 facility site. As described in Section 3, in addition to Hermes, the other past, 33 present, and currently foreseeable projects and other actions evaluated are listed in Appendix F, 34 Table F-1. Key past and present actions affecting the area include Sequoyah Units 1 and 2, 35 Watts Bar Units 1 and 2, and DOE facilities on the ORR. As discussed in Section 7.10 of the 36 CRN ESP final EIS (NRC 2019-TN6136), which is incorporated by reference, the environmental 37 impacts of building and operating two small modular reactors (larger than Hermes) in close 38 proximity to Hermes site, the cumulative impacts when considered along with these facilities 39 were found to be SMALL. Based on the discussion presented in Section 3.11.2 of the Hermes 40 CP EIS (NRC 2023-TN9771), incorporated by reference, the NRC staff concludes that the 41 cumulative risks of severe accidents at any location within 50 mi of the Hermes test reactor site 42 likely would not be significant. Based on the additional estimated insignificant risk due to 43 potential MHA at Hermes 2 and cumulative risk addressed in CRN ESP, NRC staff concludes 44 that the cumulative risks of severe accidents within 50 mi of the Hermes 2 site would still not be 45 significant, and no further mitigation is warranted.

3-42 1 3.11.3 Conclusions

2 The NRC staff concludes that the potential direct, indirect, and cumulative postulated accident 3 impacts of the proposed action would be SMALL. This conclusion is based primarily on the fact 4 that the proposed Hermes 2 facility must meet the NRC requirements for postulated accidents 5 where potential doses at the exclusion area boundary and in the low population zone are below 6 the dose reference values of 10 CFR Part 100 (TN282) for reactor siting. The potential doses 7 from Hermes 2, as determined by Kairos, meet the requirements of 10 CFR 100.11 (TN282) and 8 therefore demonstrate adequate protection of the public health and safety. Additionally, the 9 nearest resident dose from accidents is also below the radiation dose limits for individual 10 members of the public in 10 CFR 20.1301(a) ( TN283).

11 3.12 Climate Change

12 The NRC staff has determined that it is reasonably foreseeable that climate change may alter 13 the affected environment described in this section. Climate change is a global phenomenon that 14 construction, operation, and decommissioning of Hermes 2 would not appreciably alter.

15 However, it is necessary to consider whether climate change could result in a changed 16 environment that could substantially alter the environmental impacts from Hermes 2. As part of 17 the CRN ESP EIS, Appendix L, the NRC previously analyzed the potential changes to the Oak 18 Ridge region as a result of climate change (NRC 2019-TN6136). Appendix L is, therefore, 19 incorporated by reference.

20 In Appendix L of the CRN ESP EIS, the NRC staff used the 2014, 2017, and 2018 U.S. Global 21 Change Research Program (GCRP) reports as the basis for its description of the potential 22 climate change effects in the CRN Site region (USGCRP 2014-TN3472, USGCRP 2017-23 TN5848, USGCRP 2018-TN5847). The staff considered the period of time during which the 24 CRN ESP, a combined construction permit and operating license, and a renewed license could 25 potentially be valid. The staff determined that this period of time extended into the late 26 21st century and considered the GCRP projections for the 20712099 period to be bounding for 27 assessing the effects of climate change for the CRN project (NRC 2019-TN6136). The following 28 resource areas were analyzed in the assessment:

29

• land use 30

• hydrology 31

• terrestrial and wetland ecology 32

• aquatic ecology 33

• socioeconomics 34

• EJ 35

• historic and cultural resources 36

• meteorology and air quality 37

• nonradiological health 38

• radiological impacts 39

• nonradioactive waste 40

• accidents 41

• transportation of radiological materials

42 For all resource areas considered, the NRC staff concluded that the projected climate change 43 effects would not alter impact determinations for the CRN project (NRC 2019-TN6136).

3-43 1 Because of the proximity of Hermes 2 to the CRN Site, the potential changes in the region as 2 a result of climate change can be expected to be the same for both the CRN Site and the 3 proposed Hermes 2 site. The NRC staff therefore incorporates by reference the analysis from 4 the CRN ESP EIS (NRC 2019-TN6136) to evaluate climate effects on the Hermes 2 project 5 impacts. However, the proposed Hermes 2 reactor units are smaller than those considered in 6 the CRN ESP (70 vs. 2,420 MWt total power output) with correspondingly smaller magnitudes of 7 impacts. In addition, the proposed Hermes 2 units are anticipated to operate for only 11 years 8 compared to the 60 years analyzed for CRN (40 years for the combined construction permit and 9 operating license and 20 years for the renewed license). As a result, the potential climate 10 changes to the affected environment analyzed in CRN ESP EIS Appendix L would not be fully 11 realized during the anticipated operation of the proposed Hermes 2 facilities. The smaller size 12 and shorter operating period indicate that the CRN ESP climate change effects would be 13 bounding for the Hermes 2 project.

14 The staff reviewed the latest National Climate Assessment (NCA5) produced by the GCRP 15 (USGCRP 2023-TN9762) to determine whether the climate change summary prepared for the 16 CRN ESP is still bounding for the region given the new information on the projected impacts of 17 climate change. The NCA5 Interactive Atlas (USGCRP 2024-TN9798) provides climate 18 projection maps downscaled to the county level. Available maps show projected values of 19 climate variables (temperature and precipitation) under four global warming levels (GWLs) 20 corresponding to global temperature increases of 1.5, 2, 3, and 4°C, respectively, above the 21 pre-industrial (1851-1900) average. The current global average temperature is about 1.1°C 22 above the pre-industrial level. The year a GWL is projected to occur depends on the emissions 23 scenario and the climate model. Under the very high emissions scenario (SSP5-8.5, similar to 24 the bounding scenario considered in the CRN ESP), the 2°C GWL is projected to be reached, 25 on average, in 2042 (USGCRP 2023-TN9762), a date consistent with the projected end of the 26 Hermes 2 operating period. The staff therefore assumes that climate change effects for a GWL 27 of 4°C are bounding for the Hermes 2 project.

28 According to the NCA5 Interactive Atlas (USGCRP 2024-TN9798), the average annual 29 temperature in Roane County is projected to increase by 3.9°C compared to 1991-2020 if the 30 global temperature rises 4°C above the pre-industrial average. This is similar to, but less than, 31 the 8-9°F increase considered in the CRN ESP assessment. The highest temperature of the 32 year in Roane County is projected to increase by 4.4°C for the 4°C GWL, comparable to the 33 10-15°F increase considered in the CRN ESP assessment. The annual number of days when 34 the lowest temperature is 0°C or lower is projected to decrease by 18 days for the 2°C GWL 35 and 38 days for the 4°C GWL; these values fall within the ranges considered in the CRN ESP.

36 Annual precipitation in Roane County is projected to increase 6 percent compared to 1991-37 2020 under the 2°C GWL and 8 percent under the 4°C GWL. The projected changes in climatic 38 water deficit in eastern Tennessee are small, with the small increase in precipitation offset by a 39 small increase in water evaporation and plant transpiration (USGCRP 2023-TN9762). Growth in 40 the southeastern United States is projected to increase climate risks, worsen human health, and 41 widen health inequities (USGCRP 2023-TN9762). These conclusions are consistent with the 42 regional climate effects considered in the CRN ESP assessment.

43 The NRC staff determined that the new information in NCA5 does not significantly differ from 44 the climate change information considered for the CRN ESP assessment, and that the climate 45 change effects considered in the CRN ESP EIS would bound the effects for the Hermes 2 46 project. Therefore, the staff concludes that the projected effects of climate change would not 47 alter any of the impact determinations described in this EA.

3-44 1 4 ALTERNATIVES

2 This section describes alternatives to granting construction permits for the proposed Hermes 2 3 test reactor project and the environmental impacts of those alternatives. For EAs, NRC 4 regulations in 10 CFR 51.30(a)(ii) (TN250) call for a brief discussion of alternatives in an EA.

5 In accordance with NUREG-1537 (NRC 2012-TN5527, NRC 2012-TN5528), the NRC staff 6 considers a no-action alternative and a range of reasonable alternatives that may include 7 alternative sites, alternative layouts of proposed facilities within a site, modification of existing 8 facilities instead of building new facilities, alternative technologies, and alternative transportation 9 methods. The applicant followed a systematic process for identifying a range of reasonable 10 alternative sites, as outlined in Sections 5.2 and 5.3 of the ER (Kairos 2023-TN9774). The 11 applicant relied on the same systematic consideration of alternative sites used for siting the 12 Hermes project, described in Section 4.2.1 of the Hermes CP EIS (NRC 2023-TN9771), which 13 led to identification of two reasonable sites: (1) the proposed site in Oak Ridge, Tennessee, and 14 (2) an alternative site in Eagle Rock, Idaho. As with Hermes, the applicant did not consider 15 alternative layouts of the proposed Hermes 2 facilities on either site. Land disturbance on the 16 proposed site in Oak Ridge would be limited to lands previously disturbed by the former 17 ORGDP. Furthermore, the proposed site is situated in an existing industrial park already served 18 by roadways and other infrastructure. Hence, consideration of other sites in the Oak Ridge area, 19 or alternative layouts of the new buildings within the proposed site, do not offer opportunities to 20 reduce environmental impacts. As described in Section 4.2.2.1 of the Hermes CP EIS (NRC 21 2023-TN9771), the Eagle Rock site is a large tract of relatively uniform undeveloped rangeland 22 and cropland without wetlands or surface water features. There are many possible layouts for 23 the proposed facilities within the site, but none would substantially differ with respect to 24 environmental impacts. Because neither site is developed, the applicant did not consider 25 opportunities to repurpose existing facilities in lieu of building new facilities.

26 As noted in Section 5.2 of the ER (Kairos 2023-TN9774), because the purpose of Hermes 2 is 27 to demonstrate and test specific new technologies, the applicant did not consider alternative 28 technologies. As noted in Section 4.0 of the Hermes CP EIS (Kairos 2023-TN9774), which is 29 incorporated by reference, the applicant indicated that transportation alternatives to the 30 proposed site for Hermes (where Hermes 2 would also be sited) are limited to using existing 31 road and rail facilities already servicing the ETTP. As also noted there, the applicant indicated 32 that the Eagle Rock site is served only by roads and cannot be served by alternative 33 transportation such as waterways or railroads. These statements remain true for Hermes 2 and 34 support why other transportation alternatives were not considered.

35 4.1 No-Action Alternative

36 Under the no action alternative, the NRC would not issue construction permits to Kairos to build 37 the proposed Hermes 2 test reactors. Not issuing CPs for Hermes 2 would not change that the 38 NRC has already issued a CP for the Hermes test reactor on the same site. The applicant could 39 still build Hermes but would not have the ability to test elements of the Hermes 2 design absent 40 from the Hermes design, such as the intermediate cooling loop. While forgoing the opportunities 41 provided by Hermes 2 might not necessarily preclude future development of reactors using the 42 KP-FHR technologies, it could slow or impede safe and efficient development of the technology.

43 The applicant notes in Section 5.1 of the ER (Kairos 2023-TN9774) that the adverse 44 environmental impacts from Hermes 2 would not take place under the no-action alternative. But

4-1 1 because Chapter 3 of this EA characterizes potential environmental impacts of the proposed 2 action as SMALL, any environmental benefits from selecting no action instead of the proposed 3 action would be minimal. Furthermore, because the applicant would still retain the ability to build 4 the Hermes test reactor, some impacts resulting from partial occupancy of the site could still 5 occur. Other areas of the site would remain available for other government or private industrial 6 development, resulting in similar environmental impacts resulting from land disturbance and 7 building new industrial facilities on the site.

8 4.2 Site Alternatives 9 Based on its review of available and relevant information, including Section 5.3 of the ER 10 (Kairos 2023-TN9774), the NRC staff identified one alternative site for detailed evaluation. This 11 alternative site, termed the Eagle Rock site, is situated approximately 20 mi west of Idaho Falls, 12 Idaho, on Federally owned property in eastern Idaho. Figure 4-1 of this EA depicts the location 13 of the Eagle Rock site and its proximity to the City of Idaho Falls and tracts of nearby Federal 14 land managed by the DOE and other agencies. As explained in Section 5.3 of the ER (Kairos 15 2023-TN9774), the applicant is relying on the same site selection process it performed to site 16 Hermes as the basis for siting Hermes 2. Considering the similarity of the two projects, and the 17 recency of the Hermes site selection process, the NRC staff finds that the applicants reliance 18 on the same site selection process for Hermes 2 is reasonable.

19 4.2.1 Process for Identifying Reasonable Alternative Sites 20 The applicants process for siting Hermes, and hence Hermes 2, is described in Section 4.2.1 21 of the Hermes CP EIS (NRC 2023-TN9771), which is incorporated by reference. The process 22 follows the outline presented by the Electric Power Research Institute in Advanced Nuclear 23 Technology: Site Selection and Evaluation Criteria for New Nuclear Power Generation Facilities 24 (EPRI 2015-TN5285).

25 4.2.2 Affected Environment and Environmental Consequences for Eagle Rock Site 26 4.2.2.1 Affected Environment:

27 The characterization of the Eagle Rock site presented Section 5.1 of the Hermes CP EIS 28 (Kairos 2023-TN9774) is still current given its recency and is, therefore, incorporated by 29 reference. The Eagle Rock site constitutes approximately 4,200 ac of undeveloped land 30 consisting of irrigated cropland, non-irrigated pasture, and natural sagebrush steppe. Multiple 31 wilderness study areas, national natural landmarks, national forests, national monuments, and 32 national wildlife refuges are located within 50 mi of the site. The site is zoned as G-1 Grazing, 33 which allows for industrial development. The site and surrounding counties are attainment areas 34 under the Clean Air Act, and Clean Air Act Class I areas near the site include the Craters of the 35 Moon National Monument (47 mi to the west), Grand Teton National Park (65 mi to the east),

36 and Yellowstone National Park (65 mi to the northeast). There are no rivers, lakes, streams, 37 wetlands, or 100-year or 500-year floodplains on the site, although there are a few small 38 drainage features that periodically carry water from irrigated agricultural areas. A search by the 39 applicant of the FWS Information for Planning and Consultation database on February 2, 2022, 40 identified no threatened or endangered species or critical habitat listed under the ESA (TN1010) 41 for an action area consisting of that portion of the site where facilities would be built. Significant 42 archaeological resources are known to be present on the site, and some have already been 43 identified to be eligible for listing in the National Register of Historic Places.

4-2 1

2 Figure 4-1 Location of the Eagle Rock Site (Source Kairos 2023-TN8172)

4-3 1 4.2.2.2 Environmental Consequences of Construction

2 The characterization of environmental impacts from construction of Hermes on the Eagle Rock 3 site presented in Section 4.2.2.2 of the Hermes CP EIS (NRC 2023-TN9771) would apply to 4 building Hermes 2 and is therefore incorporated by reference. Building Hermes 2 at the Eagle 5 Rock site would involve the temporary disturbance of approximately 95 ac, with permanent 6 occupation of approximately 30 ac, of cultivated cropland, sagebrush, pasture, open space, 7 upland grasslands, and prime farmland. As with Hermes, the visual changes to the landscape in 8 the surrounding relatively undeveloped, flat, and treeless natural setting would be noticeable, 9 thus altering scenic vistas extending long distances into the mostly flat and treeless landscape.

10 Air emissions would be as for the proposed site in Oak Ridge, low enough to be offset by 11 mitigation and below the threshold required for Class I area modeling. Noise generation would 12 be at levels indicated for similar test reactor facilities in Oak Ridge but may be imperceptible to 13 the nearest residence, which is approximately 4.8 mi away. Building Hermes 2 on the Eagle 14 Rock site would not require physical disturbance of surface water features, wetlands, or 15 floodplains. The applicant would have to develop groundwater supply wells, although usage 16 rates would be substantially below the annual water right appropriation. Municipal water sources 17 and municipal wastewater treatment facilities would not be available. Loss and disruption of 18 sagebrush steppe habitat and other natural vegetation within the land subject to temporary 19 disturbance could noticeably affect wildlife. Unlike at the proposed site in Oak Ridge, ground 20 disturbance at the Eagle Rock site would not be limited to soils previously graded and used for 21 previous industrial development. Grading could disturb four archaeological sites located on the 22 Eagle Rock site and possibly other uncharacterized archaeological sites. Impacts related to 23 nonradiological and radiological human health, fuel cycle and transportation, and 24 nonradiological waste management would be as described for the Hermes 2 project at the Oak 25 Ridge site. As noted in Section 4.2.2.1 of the Hermes CP EIS (Kairos 2023-TN9774), which is 26 incorporated by reference, there are no low-income populations subject to consideration as 27 potential environmental justice communities of concern within 5 mi of the Eagle Rock site.

28 Hence, there is no potential for EJ impacts.

29 4.2.2.3 Environmental Consequences of Operation

30 The characterization of environmental impacts from operation of Hermes on the Eagle Rock site 31 presented in Section 4.2.2.3 of the Hermes CP EIS (NRC 2023-TN9771) is incorporated by 32 reference. There would be no further land use or visual changes resulting from operation of 33 Hermes 2, and there would be no additional physical disturbance to natural habitats or 34 subsurface cultural resources. Water usage for operations would generally be as described for 35 the proposed action, but the water supply would be obtained from onsite groundwater wells.

36 Impacts to other environmental resources would be as described for Hermes 2 at the proposed 37 site. As noted for Hermes regarding transportation of radioactive material, the NRC staff 38 recognizes that the Eagle Rock site is in a different geographic region of the continental United 39 States. However, the transportation analysis presented in Section 3.10.1 of the Hermes CP EIS 40 for Hermes at the proposed site in Oak Ridge, which formed the basis of a SMALL conclusion, 41 would still bound the transportation impacts for Eagle Rock for Hermes 2 if one applies the 42 same assumptions. For fresh fuel, TRISO high-assay low-enriched uranium fuel is shipped from 43 the farthest NRC-licensed fuel fabrication facility, the BWX Technologies, Inc. fuel fabrication 44 facility in Lynchburg, Virginia, which is located approximately 2,200 mi away from the Eagle 45 Rock Site in Idaho, versus approximately 2,390 mi from Framatome Fuel Fabrication in 46 Richland, Washington, to the Hermes 2 site in Oak Ridge, Tennessee. The radioactive waste 47 transportation analysis would still be bounding for shipping shorter distances (e.g., shipping

4-4 1 waste from the Eagle Rock site in Idaho to the EnergySolutions LLRW disposal site in the 2 adjacent state of Utah, or to the LLRW disposal site of Waste Control and Storage Services in 3 Texas, which is approximately 1,200 mi away, versus approximately 1,260 mi from Oak Ridge 4 to Waste Control and Storage Services).

5 4.2.2.4 Environmental Consequences of Decommissioning

6 The characterization of environmental impacts from decommissioning of Hermes on the Eagle 7 Rock site presented in Section 4.2.2.4 of the Hermes CP EIS (NRC 2023-TN9771) would apply 8 to Hermes 2 and which is incorporated by reference. The staff expects that potential 9 environmental impacts would generally resemble those described for construction. Potential 10 impacts from transportation of radioactive material during decommissioning would be bounded 11 by the transportation impacts described in Section 3.10 of this EA, because the LLRW disposal 12 sites are nearer to Eagle Rock than to Oak Ridge. Eagle Rock is approximately 300 mi from the 13 EnergySolutions LLRW disposal site and approximately 1,200 mi from the Waste Control and 14 Storage Services LLRW disposal site, compared to 1,860 mi and 1,200 mi between Oak Ridge 15 and each LLRW disposal site, respectively. This also holds true for the shipments of spent 16 TRISO fuel, as these shipments would be going into the adjacent state of Nevada rather than 17 being shipped across the United States. The NRC staff expects that most of the effects on land 18 use, ecology, and cultural resources from decommissioning would generally be confined to 19 areas previously affected by site preparation. As noted for construction, there are no low-income 20 populations subject to consideration as potential environmental justice communities of concern 21 within 5 mi of Eagle Rock and hence no potential environmental justice impacts.

22 4.2.2.5 Cumulative Impacts

23 The characterization of cumulative environmental impacts developed for Hermes on the Eagle 24 Rock site, presented in Section 4.2.2.5 of the Hermes CP EIS (NRC 2023-TN9771), would also 25 apply to Hermes 2 at that site, and which is therefore incorporated by reference. The Eagle 26 Rock site is located in a sparsely populated rural area where past and present environmental 27 impacts are largely limited to agriculture and ranching. Section 4.2.2.5 of the EIS identifies three 28 reasonably foreseeable future projects that could cumulatively contribute to the environmental 29 impacts of Hermes 2 if sited at Eagle Rock. These include two transmission line projects and 30 the Idaho National Laboratory Carbon-Free Power Project, which was cancelled in November 31 2022. The NRC staff recognizes that the environmental impacts from the other major projects 32 might be noticeable in the context of their immediate surroundings. However, the staff finds that 33 the incremental effects of the Hermes 2 project added to the effects of these other proposed 34 projects would be minimal, except maybe for visual resources, ecological, and cultural 35 resources. The cumulative adverse visual effects of the projects could be noticeable in the flat, 36 largely treeless landscape. Similarly, the combined loss of sagebrush and other terrestrial 37 habitats and combined disturbance of subsurface cultural resources from building Hermes 2 at 38 the Eagle Rock site combined with the other nearby major projects could be noticeable.

39 4.2.2.6 Conclusions

40 Based on the analysis presented above, the NRC staff concludes that the potential direct, 41 indirect, and cumulative impacts of construction, operation, and decommissioning of Hermes 2 42 at the Eagle Rock site would be SMALL, with the exceptions that the visual, ecological, and 43 cultural resource impacts from the construction would be MODERATE. Building even a small 44 industrial project in a rural, treeless, flat landscape that has no previous industrial or urban 45 development could noticeably alter the areas visual characteristics. Clearing sagebrush steppe

4-5 1 vegetation could affect increasingly rare wildlife species dependent on this specialized habitat, 2 such as the greater sage grouse (Centrocercus urophasianus). Grading previously undisturbed 3 soils such as those at Eagle Rock could disturb archaeological resources. Otherwise, the small 4 size and limited land disturbance needed for Hermes 2, abundance of land on the Eagle Rock 5 site, presence of similar land cover in the surrounding rural area, low employment and water 6 demands, and absence of sensitive natural and hydrological features suggest that implementing 7 the project at Eagle Rock would have at most minimal adverse environmental impacts.

8 Furthermore, although rural and remote, Eagle Rock is still proximate to the City of Idaho Falls 9 and Idaho National Laboratory, a DOE facility with technical staff and capabilities much like 10 those in Oak Ridge.

11 4.3 Cost-Benefit of the Alternatives

12 The applicant states in Section 5.4 of the ER (Kairos 2023-TN9774) that the costs and benefits 13 of Hermes 2 would be similar to those for Hermes, with the exception of a general increase in 14 costs resulting from two test reactors for Hermes 2 instead of only one reactor for Hermes. The 15 staff recognizes the similarity of the Hermes 2 reactors to the Hermes reactor and proposed 16 location of the two projects on the same site. The analysis of costs and benefits completed for 17 Hermes in Section 4.3 of the Hermes CP EIS (NRC 2023-TN9771) would therefore apply to 18 Hermes 2 and which is incorporated by reference. On the basis of the assessments 19 summarized in this EA, the NRC staff concludes that building, operating, and decommissioning 20 Hermes 2 (taking the appropriate mitigation measures identified by the NRC staff and 21 acknowledging that Hermes 2 consists of two rather than only one reactor as for Hermes) would 22 have accrued benefits that would likely outweigh its economic, environmental, and social costs.

23 The staff draws this same conclusion regardless of whether the project is sited at Oak Ridge or 24 Eagle Rock.

25 4.4 Comparison of the Potential Environmental Impacts

26 Potential environmental impacts from the no action alternative and the proposed action would 27 be SMALL for each environmental resource identified for evaluation in this EA. Potential 28 environmental impacts from the Eagle Rock alternative would be SMALL for most environmental 29 resources but would be MODERATE for land use and visual resources, ecological resources, 30 and historic and cultural resources. These MODERATE conclusions reflect the fact that building 31 the proposed Hermes 2 test reactors at the Eagle Rock site would require disturbance of soils 32 that support natural vegetation and could contain subsurface archaeological resources.

33 Additionally, the visual appearance of the facilities could be noticeably intrusive in the rural 34 setting of the Eagle Rock site.

35 Based on the analysis presented above, the NRC staff concludes that there are no 36 environmentally preferrable alternatives to the proposed action that meet the purpose and need 37 of the proposed licensing action. Although the no action alternative might avoid some of the 38 impacts from the proposed action, the no action alternative would not meet the purpose and 39 need for Hermes 2. Furthermore, the analyses in this EA demonstrate that none of the impacts 40 from the proposed action would be greater than SMALL, thus avoidance of the impacts would 41 not be substantially preferable from an environmental perspective. Because the NRC staff did 42 not identify any environmentally preferrable alternatives that meet the purpose and need of the 43 proposed action, the staff concludes that there are no obviously superior alternatives to the 44 proposed action from an environmental perspective.

4-6 1 5 CONCLUSIONS AND RECOMMENDATION

2 This EA describes the environmental review conducted by the NRC staff for the Kairos 3 application for CPs under 10 CFR Part 50 (TN249) that would allow construction of the two 4 Hermes 2 non-power test reactors on a 185 ac site within the Heritage Center of ETTP 5 (Heritage Center) in Oak Ridge, Tennessee. This EA follows procedures in 10 CFR 51.30, 6 Environmental assessment and 10 CFR 51.31, Determinations based on environmental 7 assessment, which are the NRCs regulations for preparing EAs to implement NEPA 8 requirements (TN661). This chapter presents conclusions and recommendations based on the 9 NRC staffs environmental review of the application. The chapter is organized as follows:

10

• Section 5.1 summarizes the environmental impacts from construction, operation, and 11 decommissioning of Hermes 2.

12

• Section 5.2 compares the environmental impacts of the proposed action against reasonable 13 alternatives identified by the NRC staff.

14

• Section 5.3 discusses the unavoidable impacts of the proposed action and identifies 15 resource commitments.

16

• Section5.4 presents the NRC staffs conclusions and recommendations.

17 5.1 Environmental Impacts of the Proposed Action

18 As indicated in Section 1.1 of this EA, the proposed action is NRC issuing CPs to Kairos 19 authorizing construction of two proposed Hermes 2 non-power test reactors on a site in Oak 20 Ridge, Tennessee. Section 1.2 of this EA presents the purpose and need of the Federal action, 21 which is to demonstrate key technology of the KP-FHR technology for possible future 22 deployment. Chapter 3 of this EA characterizes the direct, indirect, and cumulative impacts from 23 construction, operation, and decommissioning of the proposed Hermes 2 reactors. As indicated 24 in Chapter 3, the NRC staff concludes that the potential impacts from Hermes 2 would be 25 SMALL for each potentially affected environmental resource. The NRC staff based its 26 conclusions on independent reviews of information provided in Kairos application for the 27 Hermes 2 CPs, including an ER (Kairos 2023-TN9774) and PSAR (Kairos 2023-TN9774), as 28 well as other relevant information sources. Table 5-1 summarizes the environmental impacts 29 and the staffs conclusions for each resource considered.

30 Table 5-1 Summary of Environmental Impacts from Construction, Operation, and 31 Decommissioning of Hermes 2

EA Impact Resource Area Section Summary of Impact Level Land Use and 3.1 Same 185 ac site proposed for Hermes. Temporary disturbance of SMALL Visual 138 ac of land previously occupied by industrial buildings.

Resources Permanent occupation of 30 ac of that land. Remainder of the site would be exclusion area throughout operation, where Kairos would have to ensure compatible land use. The site is within an established industrial park setting that is already of low scenic quality. Hermes 2 would have a compatible industrial appearance and be compatible with existing zoning. Short 161 kV electric transmission would be built extending approximately 800 ft west of the Hermes 2 site to connect to existing electrical grid; the transmission line would be built entirely with previous disturbed lands within the existing Heritage Center industrial park.

5-1 Table 5-1 Summary of Environmental Impacts from Construction, Operation, and Decommissioning of Hermes 2 (Continued)

EA Impact Resource Area Section Summary of Impact Level Air Quality and 3.2 Air emissions of criteria pollutants would be below SMALL Noise 100 tons/yr, and hazardous air pollutants would be below 10 tons/yr individually and 25 tons/yr combined. Emissions would comply with non-Title V permitting requirements. Standard control measures to minimize fugitive dust.

Hydrogeology 3.3 No disturbance of geological features of economic or natural SMALL and Water value. Disturbances limited to previously disturbed soils. BMPs Resources employed for soil erosion and sediment control. Water demands met through municipal or commercial suppliers. No use of groundwater and no direct use of surface water. No cooling towers, ponds, or reservoirs. Wastewater discharged for treatment to municipal wastewater treatment facilities. Limited, temporary dewatering of two reactor excavations during construction.

Dewatering water to be dispositioned in accordance with DOE requirements per the quit claim deed for the site. Stormwater to be managed using BMPs.

Ecological 3.4 Ground disturbance, including that for transmission line, limited to SMALL Resources previously disturbed soils lacking vegetation or with only ruderal vegetation. No disturbance of forest cover or other natural vegetation on natural soils, wetlands, surface waters, shorelines, or riparian land. No Clean Water Act Section 404 permit required.

BMPs to control stormwater runoff that might reach wetlands or aquatic habitats. Brief increases in noise during construction may affect wildlife, but area wildlife already exposed to industrial noise.

Limited potential for wildlife to collide with new structures or be injured by vehicles. Biological evaluation presented in Table 3.4-2 of this EA presents NRC staff conclusions regarding effects of Hermes 2 on species protected under the ESA (TN1010).

Conclusions for all species are no effect or may affect but not likely to adversely affect. No critical habitat present. The final EA will indicate whether the FWS concurs.

Historic and 3.5 No historic properties in the direct effects APE. Ground SMALL Cultural disturbance limited to areas of extensive past soil disturbance with Resources little potential for remaining archaeological resources. Kairos has developed and would implement an Archaeological Resources Monitoring and Unanticipated Discovery Plan covering any work on the 185 ac site establishing stop work and notification procedures to address unexpected discovery of human remains or archaeological material in compliance with deed requirements and Tennessee State law. The Manhattan Project National Historical Park (eligible for the National Register of Historic Places) is in the indirect effects APE but would not be adversely affected because Hermes 2 would be visually compatible with the current industrial setting.

Socioeconomics 3.6 Construction of Hermes 2 would involve an average of 424 site SMALL and workers per year over a 3-year period with an estimated peak of environmental 850 workers. Staffing during an 11-year operational phase would justice require an estimated average of 59 workers per weekday (101 full-time positions). Decommissioning would involve an estimated

5-2 Table 5-1 Summary of Environmental Impacts from Construction, Operation, and Decommissioning of Hermes 2 (Continued)

EA Impact Resource Area Section Summary of Impact Level peak employment level of 340 workers. These few workers would not substantially affect employment levels in the surrounding area, but the demand for some skilled labor might compete with other planned technology projects. Given that the nearest potentially affected EJ populations are over 8-mi away, and the small footprint of Hermes 2, both physically and in terms of personnel, no disproportionately high and adverse human health and environmental effects on minority and low-income populations would be expected.

Human Health 3.7 The site was formerly occupied by buildings that were part of the SMALL DOE ORGDP that was used to enrich uranium, but the DOE has already razed the buildings and has begun remediation with the end use land use designation of unrestricted industrial land use as the basis for defining its remedial action objectives. The DOE retains responsibility for remediation following any unanticipated discovery of legacy wastes. Based on information in the CP application, the NRC staff expects that radiological releases, doses to the public, and occupational doses would be less than the limits established for protection of human health and the environment in 10 CFR Part 20 (TN283). Based on the calculated radiological doses, the NRC staff concludes that the radiological impacts to members of the public due to normal operation of Hermes 2 would be not significant. The applicant would implement normal safety practices contained in Occupational Safety and Health Administration regulations in 29 CFR Part 1910 (TN654) to protect occupational health. Emissions would comply with the Resource Conservation and Recovery Act (TN1281), Clean Air Act (TN1141), and other environmental regulations.

Nonradiological 3.8 Kairos would develop and implement a plan to manage wastes SMALL Waste generated by Hermes 2. Management of solid waste, including construction and demolition wastes, would involve waste reduction efforts, recycling, and BMPs. Liquid wastes would be discharged for municipal treatment at a wastewater treatment plant or trucked offsite for proper disposal. Gaseous emissions would comply with Tennessee Department of Environment and Conservation regulations.

Uranium Fuel 3.9 A low quantity of uranium would be used during the 11-year SMALL Cycle and operational period. TRISO fuel processes (including enrichment Waste and fuel fabrication) would be bounded by Table S-3 in 10 CFR Management 51.51 (TN250), developed by the NRC to protect human health and the environment. Environmental impacts from the storage of spent TRISO fuel from Hermes 2 is bounded by the analysis in the Continued Storage Generic EIS. The estimated volume of LLRW is less than or comparable to that from an LWR, and the staff determined that there is adequate capacity at LLRW disposal sites that LLRW from Hermes 2 could be accepted. Onsite storage of spent TRISO fuel would have to meet the same regulatory requirements as currently licensed LWRs.

5-3 Table 5-1 Summary of Environmental Impacts from Construction, Operation, and Decommissioning of Hermes 2 (Continued)

EA Impact Resource Area Section Summary of Impact Level Transportation 3.10 Transportation of radioactive fuels and wastes to and from SMALL of Radioactive Hermes 2 would be performed in compliance with U.S.

Material Department of Transportation and NRC regulations and would constitute only a small percentage of the total materials of these types shipped each year. Based on the quantity of nuclear material and waste acceptable for disposal and employing certified packages in conforming NRC and Department of Transportation regulations, the NRC staff concludes that the transportation of fuel and waste impacts from operation and decommissioning of Hermes 2 would be not significant.

Postulated 3.11 The NRC staff is conducting an independent review of the SMALL Accidents consequences of accidents and will document it in its Safety Evaluation (SE). To receive CPs, the Hermes 2 test reactors would have to meet NRC requirements for postulated accidents, where potential doses at the exclusion area boundary and in the low population zone are below the dose reference values of 10 CFR Part 100 (TN282) for test reactor siting. Additionally, as another indication of the low level of environmental impacts, the nearest resident dose from accidents is also below the radiation dose limits for individual members of the public in 10 CFR 20.1301(a) (TN283).

1 5.2 Comparison of Alternatives

2 In Chapter 4 of this draft EA, the NRC staff considered two alternatives to construction, 3 operation, and decommissioning of Hermes 2 at the proposed site in Oak Ridge, Tennessee:

4 (1) the no action alternative and (2) construction, operation, and decommissioning of Hermes 2 5 at an alternative site in Eagle Rock, Idaho.

6 The NRC staff independently reviewed information concerning other potential alternatives, 7 including other alternative sites, and determined that there were no other reasonable 8 alternatives warranting detailed evaluation. Because Hermes 2 is designed to test a specific 9 energy generation technology, alternatives involving other energy generation processes would 10 not meet the projects purpose and need and hence were not analyzed in detail. Section 4.4 11 presents and compares the staffs conclusions about the no action alternative, proposed action, 12 and Eagle Rock alternative. The NRC staff concluded that environmental impacts from the no 13 action alternative and the proposed action would both be SMALL. The staff concluded that 14 impacts on many environmental resources from the Eagle Rock alternative would likewise be 15 SMALL but impacts on land use and visual resources, ecological resources, and historic and 16 cultural resources would be MODERATE. Building Hermes 2 at the proposed site in Oak Ridge 17 would introduce new industrial buildings to a previous industrial site within an existing industrial 18 park of low aesthetic quality, whereas building the same facilities at the Eagle Rock site would 19 introduce new industrial buildings to an open rural landscape free of previous urban 20 encroachment. The new industrial buildings would noticeably alter the visual character of the 21 existing open rural Idaho landscape. Furthermore, while land disturbance to build Hermes 2 at 22 the proposed Oak Ridge site would be confined to areas of previously disturbed soils within the 23 footprint of former industrial development, building Hermes 2 at the Eagle Rock site would

5-4 1 involve disturbance of natural vegetation, possibly including shrub-steppe vegetation, and 2 natural soils potentially containing subsurface archaeological resources. These disturbances 3 would noticeably degrade the quality of existing ecological and cultural resources present on the 4 site and possibly affect those qualities in the surrounding region.

5 The no action alternative would not meet the purpose and need identified for the Hermes 2.

6 Of the two alternatives considered that would meet the purpose and need for Hermes 2, the 7 proposed action would result in the fewest environmental impacts and is therefore the 8 environmentally preferrable alternative. The proposed site at Oak Ridge, which is the former 9 location of two large industrial buildings that have been razed and the land remediated to allow 10 industrial reuse, offers an opportunity to build new industrial buildings without disturbing 11 sensitive natural or cultural resources or introducing industrial activity to areas lacking an 12 industrial presence.

13 5.3 Resource Commitments

14 The following sections address issues related to resource commitments contributing to the 15 cost-benefit analysis presented in Section 4.3 of this EA.

16 5.3.1 Unavoidable Adverse Environmental Impacts

17 As noted in Chapter 3 of this EA, the NRC staff concluded that the environmental impacts from 18 construction, operation, and decommissioning of Hermes 2 would be SMALL. They would not 19 be detectable or would be so minor that they would neither destabilize nor noticeably alter any 20 important attribute of the resource. However, a SMALL conclusion does not necessarily indicate 21 that there would be no adverse effects that could be offset or minimized through mitigation. The 22 mitigation measures presented in Table 5.2 of the Hermes CP EIS (NRC 2023-TN9771) would 23 apply to Hermes 2 as well. Table 5-2 is therefore incorporated by reference. These mitigation 24 measures were developed for a reactor of similar size and design as the two Hermes 2 reactors, 25 which are proposed for the same site. Although the adverse impacts for Hermes 2 could be 26 somewhat greater than for Hermes because Hermes 2 is a two-reactor project, Chapter 3 of this 27 EA still indicates that the direct, indirect, and cumulative impacts, including adverse impacts, 28 would be minimal and suggests that the proposed mitigation would be similarly effective. The 29 staff did not identify any additional relevant mitigation measures for Hermes 2 beyond those 30 identified in Table 5.2 of the Hermes CP EIS (NRC 2023-TN9771).

31 5.3.2 Relationship Between Local Short-Term Uses of the Environment and 32 Maintenance and Enhancement of Long-Term Productivity

33 Hermes 2 would result in short-term uses of environmental resources. Short-term is the time 34 during which construction, operation, and decommissioning activities would take place. As 35 indicated in Section 2.1 of the ER (Kairos 2023-TN9774), Kairos plans to begin construction as 36 early as mid-2025 with an operational life of 11 years. The applicant indicates that 37 decommissioning would commence after operations and estimates that it would begin in 2039.

38 Applicants for licensing new reactors typically do not develop a decommissioning plan when 39 applying for CPs and/or OLs.

40 As indicated in Section 3.1 of this EA, Hermes 2 would require short-term use of approximately 41 30 ac of industrial land over the life of the project. This land would not be available for other 42 uses during that time but could be available after decommissioning. Construction would require 43 the temporary use of as much as 108 ac of additional previously used industrial land (temporary

5-5 1 disturbance of 138 ac), and decommissioning may again require the temporary use of all or part 2 of the same 138 ac of land. The additional 108 ac land may be available for other uses beyond 3 construction and decommissioning. As shown on Figure 2.1-3 of the applicants PSAR (Kairos 4 2023-TN9774), the applicant has designated the entire 185 ac site as the exclusion area for 5 Hermes 2, within which it would have to limit other land uses during operation to ensure that no 6 significant hazards to public health and safety are possible (10 CFR Part 100-TN282). This is 7 the same exclusion area that the applicant designated for Hermes. The Hermes 2 structures 8 may be visible from a distance over the life of the project from nearby parks and residential 9 areas, but they would be part of a cluster of existing and new industrial facilities (including but 10 not limited to Hermes and Hermes 2) that are also part of the Heritage Center in the ETTP.

11 Once the new facilities are razed as part of decommissioning, they would no longer be visible.

12 The discussion of the relationship between local short-term uses of the environment and 13 maintenance and enhancement of long-term productivity presented for Hermes in Section 5.3.2 14 of the Hermes CP EIS (NRC 2023-TN9771) applies to Hermes 2 and is therefore incorporated 15 by reference. Usage of resources such as water and labor and impacts related to air emissions, 16 noise, ecological resources, cultural resources, radiological and nonradiological health and 17 waste, and transportation would be minimal, although somewhat greater impacts could result 18 because the Hermes 2 project involves two rather than just one test reactor.

19 5.3.3 Irreversible and Irretrievable Commitment of Resources

20 This section describes the irreversible and irretrievable commitment of resources that have 21 been noted in this EA. Resource losses or degradation are irreversible when primary or 22 secondary impacts limit future options for a resource. An irretrievable commitment refers to 23 the use or consumption of resources that are neither renewable nor recoverable for future 24 use. Irreversible and irretrievable commitments of resources for construction, operation, and 25 decommissioning of a non-power test reactor project such as Hermes 2 include the commitment 26 of water, energy, raw materials, and other natural and human-made resources. In general, the 27 commitment of capital, energy, labor, and material resources for a project such as Hermes 2 28 also are irreversible.

29 The applicant states in Section 6.3 of the ER (Kairos 2023-TN9774) that the anticipated 30 irreversible and irretrievable commitments of environmental resources used in construction and 31 operation of Hermes 2 would be similar to those for Hermes, although would be larger because 32 Hermes 2 consists of two reactors rather than only one. As noted in Section 5.3.3 of the Hermes 33 CP EIS (NRC 2023-TN9771), incorporated by reference, building, operating, and 34 decommissioning the Hermes 2 reactors at the proposed site in Oak Ridge, Tennessee, or at 35 the alternative Eagle Rock site in Idaho would entail the irreversible and irretrievable 36 commitment of energy, water, chemicals, fossil fuels, and other natural and human-made 37 resources. Building Hermes 2 would consume concrete, structural steel, steel sheet pilings, 38 precast piles, precast panels, asphalt, stone, roofing/siding, and temporary tent structures, as 39 quantified by the applicant in Table 2.1-1 of the ER (Kairos 2023-TN9774). These materials 40 would be irretrievable unless Kairos recycles them during decommissioning (e.g., finds another 41 facility to use such materials).

42 As noted for Hermes in Section 5.3.3 of the Hermes CP EIS (NRC 2023-TN9771), the reactor 43 core of each Hermes 2 test reactor would be fueled during operation using 4 cm diameter 44 graphite pebbles with embedded coated TRISO particle fuel, with each particle comprising a 45 uranium fuel kernel with a maximum uranium enrichment of 19.55 weight-percent. The 46 availability of uranium ore and existing uranium stockpiles, including down-blending of highly

5-6 1 enriched uranium, in the United States and from foreign sources (i.e., Australia and Canada) 2 that could be processed into fuel is sufficient to support the operation of the Hermes 2 test 3 reactors (WNA 2022-TN7971). Thus, the irreversible and irretrievable commitment of the 4 quantity of uranium (0.93 MT of uranium) to be used by Hermes 2 would have a negligible 5 impact on U.S. uranium supplies. Over the anticipated 11-year operational period for Hermes 2, 6 the applicant estimates in Section 2.6 of the ER (Kairos 2023-TN9774) that 776,000 used 7 TRISO pebbles would be produced as waste. These used TRISO fuel pebbles would be an 8 irretrievable use of fuel and would not be available to fuel other advanced reactors.

9 As described in Section 3.3 of this EA, the water demands of Hermes 2 at either Oak Ridge or 10 Eagle Rock would be minimal and readily met by municipal and commercial sources. These 11 water resources are readily available at both sites, and the amounts required are not expected 12 to deplete available supplies or exceed available system capacities. As described in Section 3.4 13 of this EA, a small number of birds and other wildlife could be killed or injured by collision with 14 structures or collision with vehicles at either site. These losses would irreversibly affect wildlife 15 populations in the surrounding area noticeably, and any affected populations can be expected to 16 subsequently recover. As noted in Section 4.2.2 of this EA, building Hermes 2 at Eagle Rock 17 would disturb approximately 95 ac of cropland, sagebrush, pasture, and upland grasslands, 18 including some prime farmland. Although the affected land could be restored to rural uses after 19 decommissioning, some of the desirable ecological properties of the sagebrush and agricultural 20 quality of the prime farmland soils may not be fully restorable, and hence would be irreversible.

21 Irreversible losses of natural habitat or agricultural land would not be a possibility at the 22 proposed Oak Ridge site, because, as described in Section 3.4 of this EA, soils within all of the 23 land subject to disturbance have been heavily disturbed by past industrial development 24 and currently support only ruderal vegetation. Any disturbances to cultural resources at the 25 Eagle Rock site could be irreversible.

26 Energy expended would be in the form of fuel for equipment, vehicles, and facility operation and 27 electricity for equipment and facility operation. Electricity and fuel would be acquired from offsite 28 commercial sources.

29 5.3.4 Unresolved Conflicts

30 Section 102(2)(H) (TN661) of NEPA requires that the NRC staff study, develop, and describe 31 appropriate alternatives to recommended courses of action in any proposal that involves 32 unresolved conflicts concerning alternative uses of available resources. In reviewing the 33 potential impacts associated with Hermes 2, the NRC staff did not identify any unresolved 34 conflicts concerning alternative uses of available resources.

35 5.4 Recommendation

36 On the basis of this EA, and its determination that the environmental impacts would be SMALL 37 for each potentially affected resource area, the NRC staff concludes that the proposed action 38 would not have a significant effect on the quality of the human environment. Therefore, the staff 39 has made a preliminary determination that it will not prepare an EIS and that a draft FONSI 40 appears warranted. Further, after weighing the environmental, economic, technical, and other 41 benefits against environmental and other costs, and considering reasonable alternatives, the 42 NRC staff recommends, unless safety issues mandate otherwise, that the NRC issue CPs to 43 Kairos for Hermes 2. The NRC staff based its recommendation on the following:

5-7 1

• the NRC staffs review of Kaiross Hermes 2 ER (Kairos 2023-TN9774) and associated 2 responses to requests for clarifying information 3

• the NRC staffs independent environmental review

4 The NRCs staffs recommendation is tentative. Before identifying a final recommendation, the 5 staff also will consider comments received on this draft EA over a 30-day public comment period 6 from Federal, State, local, and Tribal officials, and members of the public.

7

5-8 1 6 DRAFT FINDING OF NO SIGNIFICANT IMPACT

2 The proposed action before the NRC is whether to issue CP s (one for each unit) to Kairos to 3 authorize construction of the two proposed reactors (units) making up the Hermes 2 project.

4 The NRC has conducted an environmental review of a request for NRC issuance of CPs for 5 the Hermes 2 project and prepared an EA. This draft FONSI incorporates by reference the EA 6 discussed in Section 1 through Section 5 of this document. On the basis of the EA, and its 7 determination that the environmental impacts would be SMALL for each potentially affected 8 resource area, the NRC staff has preliminarily determined that the proposed action would not 9 have a significant effect on the quality of the human environment. Accordingly, the NRC staff 10 has made a preliminary determination that preparation of an EIS is not required for the 11 proposed action and that a FONSI appears warranted.

12 This finding and the related environmental documents referenced throughout the EA are 13 available for public inspection as discussed in the EA. The NRC staffs determination is 14 tentative. Before making a final determination, the NRC staff also will consider comments 15 received on the draft EA and draft FONSI over a 30-day public comment period from Federal, 16 State, local, and Tribal officials, and members of the public. Once NRC makes a final 17 determination, it will publish the final EA and FONSI or proceed to prepare an EIS.

6-1

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17 TRB (Transportation Research Board). 2000. Highway Capacity Manual. HCM2000, 18 Washington, D.C. Available at:

19 https://sjnavarro.files.wordpress.com/2008/08/highway_capacital_manual.pdf. TN9065.

20 UniStar (UniStar Nuclear Energy, LLC). 2007. Technical Report in Support of Application of 21 UniStar Nuclear Energy, LLC and UniStar Nuclear Operating Services, LLC for Certificate of 22 Public Convenience and Necessity Before the Maryland Public Service Commission for 23 Authorization to Construct Unit 3 at Calvert Cliffs Nuclear Power Plant and Associated 24 Transmission Lines. Public Service Commission of Maryland, Baltimore, Maryland. ADAMS 25 Accession No. ML090680053. TN1564.

26 USCB (U.S. Census Bureau). 2020. Decennial Census, Urban and Rural, Table P2, DEC 118th 27 Congressional District Summary File, 2020. Loudon, Morgan, Knox, Anderson, and Roane, 28 Counties, Tennessee. Washington, D.C. Accessed February 29, 2024, at 29 https://data.census.gov/table/DECENNIALCD1182020.P2?q=P2&g=040XX00US47_050XX00U 30 S47001,47093,47105,47129,47145. TN9782.

31 USCB (U.S. Census Bureau). 2022. American Community Survey, Table DP03, ACS 5 -Year 32 Estimates Data Profiles, 2022, Loudon, Morgan, Knox, Anderson, and Roane, Counties, 33 Tennessee. Washington, D.C. Accessed February 29, 2024, at 34 https://data.census.gov/table/ACSDP5Y2021.DP03?q=DP03&g=040XX00US47_050XX00US47 35 001,47093,47105,47129,47145. TN9783.

7-9 1 USCB (U.S. Census Bureau). 2022. American Community Survey, Table DP04, ACS 5 -Year 2 Estimates Data Profiles, Selected Housing Characteristics, 2022, Loudon, Morgan, Knox, 3 Anderson, and Roane, Counties, Tennessee. Washington, D.C. Accessed on February 29, 4 2024, at 5 https://data.census.gov/table/ACSDP5Y2021.DP04?q=DP04&g=040XX00US47_050XX00US47 6 001,47093,47105,47129,47145. TN9784.

7 USGCRP (U.S. Global Change Research Program). 2014. Climate Change Impacts in the 8 United States: The Third National Climate Assessment. J.M. Melillo, T.C. Richmond, and G.W.

9 Yohe (eds.). U.S. Government Printing Office, Washington, D.C. ADAMS Accession No.

10 ML14129A233. TN3472.

11 USGCRP (U.S. Global Change Research Program). 2017. Climate Science Special Report:

12 Fourth National Climate Assessment. Volume I. Wuebbles, D.J., D.W. Fahey, K.A. Hibbard, D.J.

13 Dokken, B.C. Stewart, and T.K. Maycock (eds.). Washington, D.C. ADAMS Accession No.

14 ML19008A410. doi: 10.7930/J0J964J6. TN5848.

15 USGCRP (U.S. Global Change Research Program). 2018. Impacts, Risks, and Adaptation in 16 the United States: Fourth National Climate Assessment. Volume II. D.R. Reidmiller, C.W. Avery, 17 D.R. Easterling, K.E. Kunkel, K.L.M. Lewis, T.K. Maycock, and B.C. Stewart (eds.). Washington, 18 D.C. ADAMS Accession No. ML19008A414. doi: 10.7930/NCA4.2018. TN5847.

19 USGCRP (U.S. Global Change Research Program). 2023. The Fifth National Climate 20 Assessment. A.R. Crimmins, C.W. Avery, D.R. Easterling, K.E. Kunkel, B.C. Stewart, and T.K.

21 Maycock, Eds. Washington, D.C. Available at https://doi.org/10.7930/NCA5.2023. TN9762.

22 USGCRP (U.S. Global Change Research Program). 2024. Atlas of the 5th National Climate 23 Assessment. Washington, D.C. Accessed March 5, 2024, at https://atlas.globalchange.gov/.

24 TN9798.

25 WNA (World Nuclear Association). 2020. Uranium Enrichment. London, United Kingdom .

26 Webpage accessed October 16, 2020, at https://www.world-nuclear.org/information-27 library/nuclear-fuel-cycle/conversion-enrichment-and-fabrication/uranium-enrichment.aspx.

28 TN6661.

29 WNA (World Nuclear Association). 2022. Supply of Uranium. London, United Kingdom.

30 Available, at https://world-nuclear.org/information-library/nuclear-fuel-cycle/uranium-31 resources/supply-of-uranium.aspx. TN7971.

7-10 1 APPENDIX A 2

3 LIST OF PREPARERS

4 Members of the U.S. Nuclear Regulatory Commission; Office of Nuclear Material Safety and 5 Safeguards; Division of Rulemaking, Environmental, and Financial Support; Environmental 6 Center of Expertise prepared this draft environmental assessment. Staff from other U.S. Nuclear 7 Regulatory Commission branches and from Pacific Northwest National Laboratory provided 8 supplemental technical support and technical editing/production. Table A-1 below identifies 9 each contributors name and affiliation, summary of education and experience, and description 10 of function or expertise contributed to the document.

11 Table A-1 List of Preparers

Name & Affiliation Education/Experience Function or Expertise Anderson, David MS Forest Resources Socioeconomics PNNL BS Forest Resources Environmental Justice 31 years of relevant experience Barnhurst, Daniel MS Geology Branch Chief NRC BS Environmental Geology (February 2024-Present) 17 years of relevant experience Carlon, Teresa BS Information Technology Reference Coordinator PNNL 26 years of relevant experience Counts, Cary MS Environmental Engineering Technical Editor PNNL BS Ceramic Engineering 50 years of relevant experience Doub, Peyton MS Plant Physiology Project Manager NRC BS Plant Sciences (Botany) Acting Branch Chief Professional Wetland Scientist (Nov 2023-January 2024)

Certified Environmental Professional Introduction Duke NEPA Certificate Proposed Action 36 years of relevant experience Land Use and Visual Resources Biological Evaluation Cumulative Impacts Alternatives Conclusions Peer Review: Ecology Dozier, Tami MS Civil Engineering/Water Resources Project Management Support NRC BS Civil Engineering Duke NEPA Certificate 23 years of relevant experience Erwin, Kenneth MS Nuclear Engineering Branch Chief NRC BS Nuclear Engineering (through Oct 2023) 21 years of relevant experience Ghosh, Saikat PhD Chemical Engineering Air Emissions PNNL MS Environmental Engineering Green House Gas Emissions 15 years of relevant experience Giacinto, Joseph MS Hydrology Peer Review:

NRC BS Geology (Geophysics) Geology Professional Geologist Water Resources Duke NEPA Certificate 26 years of relevant experience

A-1 1 Table A-1 List of Preparers (Continued)

Name & Affiliation Education/Experience Function or Expertise Glowacki, Brian BS Environmental Engineering Geology NRC 3 years of relevant experience Water Resources Ecology Nonradiological Waste Nonradiological Human Health Goldstein, Beau MA Anthropology Cultural Resources NRC BA Anthropology Registered Professional Archaeologist 25 years of relevant experience Kautzky, Kevin BS English PNNL Deputy Team Lead PNNL 21 years of relevant experience References McFarland, Douglas MS Cultural Resource Management Cultural Resources PNNL BS Anthropology Registered Professional Archaeologist 26 years of relevant experience Meyer, Philip PhD Civil Engineering Climate Change PNNL MS Civil Engineering BS Physics 25 years of relevant experience Montgomery, Sadie BS Mathematics Comment Database PNNL 10 years of relevant experience Nagel, Madelyn BA Environmental Science & Policy Air Quality NRC BA Political Science Climate Change 2 years of relevant experience Palmrose, Donald PhD Nuclear Engineering Peer Review:

NRC MS Nuclear Engineering Radiological Health BS Nuclear Engineering Postulated Accidents Duke NEPA Certificate Uranium Fuel Cycle 38 years of relevant experience Radiological Waste Transportation of Rad. Material Richmond, Mary BA Biological Sciences Project Management Support NRC MS Environmental Engineering Peer Review:

35 years of relevant experience Introduction Proposed Action Land Use and Visual Resources Cumulative Impacts Wessel, Caitlin PhD Marine Science PNNL Team Lead PNNL MS Coastal, Marine, and Wetland Science BS Biology 11 years of relevant experience Willingham, Laura BS Environmental Sciences Peer Review:

NRC 18 years of relevant experience Air Quality Climate Change Zeng, Lin PhD Environmental Science & Engineering Socioeconomics PNNL BE Civil Engineering Environmental Justice 10 years of relevant experience 2 Key: BA = Bachelor of Arts; BE = Bachelor of Engineering; BS = Bachelor of Science; MA = Master of Arts; MS =

3 Master of Science; NEPA = National Environmental Policy Act; NRC = U.S. Nuclear Regulatory Commission; PhD =

4 Doctor of Philosophy; PNNL = Pacific Northwest National Laboratory.

5

A-2 1 APPENDIX B 2

3 AGENCIES, ORGANIZATIONS, TRIBES, AND 4 INDIVIDUALS CONTACTED

5 The U.S. Nuclear Regulatory Commission (NRC) is providing electronic copies of the draft 6 Kairos Hermes 2 Test Reactor Construction Permit Environmental Assessment to the agencies, 7 organizations, Tribes, and individuals listed n Table B-1. The NRC will also send copies to 8 citizens that provide comments and contact information during the 30-day comment period 9 following publication of the draft environmental assessment. The NRC will provide copies to 10 other interested organizations and individuals upon request.

11 Table B-1 List of Agencies, Organizations, Tribes, and Persons to Whom Copies of 12 this Environmental Assessment Will Be Sent

Name Affiliation Contact Information Federal and State Agencies Reid Nelson Advisory Council on Historic 401 F Street NW, Suite 308 Preservation Washington DC 20001-2637 rnelson@achp.gov E. Patrick State Historic Preservation Office 2941 Lebanon Pike McIntyre Nashville, TN 3721 4 section.106@tn.gov Larry Long U.S. Environmental Protection Agency, NEPA Program Office Region 4 USEPA Region 4 61 Forsyth Street SW Atlanta, GA 30303 long.larry@epa.gov Daniel Elbert U.S. Fish and Wildlife Service U.S. Fish and Wildlife Service Tennessee Ecological Services Field Office 446 Neal Street Cookeville, TN 38501-4027 daniel_elbert@fws.gov Kris Kirby National Park Service: Manhattan 12795 West Alameda Parkway Project National Historical Park P.O. Box 25287 Denver, CO 80225-0287 nps_environ_rev@nps.gov Niki Nicholas National Park Service: Manhattan niki_nicholas@nps.gov Project National Historical Park Billy Freeman Tennessee Department of Environment Division of Radiological Health, TDEC and and Conservation Knoxville Field Office Mariza Gonzalez 3711 Middlebrook Pike Knoxville, TN 3792 Mariza.Gonzalez@tn.gov Jennifer Tribble Tennessee Department of Environment Office of Policy and Planning, TDEC and Conservation William R. Snodgrass Tennessee Tower 312 Rosa L Parks Ave, 2nd Floor Nashville, TN 37243 Jennifer.Tribble@tn.gov Dave Adler U.S. Department of Energy david.adler@orem.doe.gov 13

B-1 Table B-1 List of Agencies, Organizations, Tribes, and Persons to Whom Copies of this Environmental Assessment Will Be Sent (Continued)

Name Affiliation Contact Information Tribes John Raymond Absentee Shawnee Tribe 2025 S. Gordon Cooper Drive Johnson, Shawnee, OK 74801 Governor Rick Sylestine, Alabama-Coushatta Tribe of Texas 571 State Park Road 56 Chairman Livingston, TX 77351 Wilson Yargee, Alabama-Quassarte Tribal Town P.O. Box 187 Chief Wetumka, OK 74883 Chuck Hoskin, Cherokee Nation P.O. Box 948 Jr., Principal Tahlequah, OK 74465 Chief Michell Hicks, Eastern Band of Cherokee Indians Qualla Boundary Principal Chief P.O. Box 1927 Cherokee, NC 28719 Glenna J. Eastern Shawnee Tribe of Oklahoma 12705 South 705 Road Wallace, Chief Wyandotte, OK 74370 Stephanie Kialegee Tribal Town P.O. Box 332 Yahola, Mekko Wetumka, OK 74883 David Hill, Muscogee (Creek) Nation P.O. Box 580 Principal Chief Okmulgee, OK 74447 Lewis J. Seminole Nation of Oklahoma P.O. Box 1498 Johnson, Chief Wewoka, OK 74884 Marcellus W. Seminole Tribe of Florida 6300 Stirling Road Osceola, Jr., Hollywood, FL 33024 Chairman Benjamin Barnes, Shawnee Tribe P.O. Box 189 Chief Miami, OK 74354 Ryan Morrow, Thlopthlocco Tribal Town P.O. Box 188 Town King Okemah, OK 74859 Joe Bunch, Chief United Keetoowah Band of Cherokee P.O. Box 746 Indians of Oklahoma Tahlequah, OK 74464 Jonathan Cernek, Coushatta Tribe of Louisiana P.O. Box 818 Chairman Elton, LA 70532 Libby Rogers, Jena Band of Choctaw Indians P.O. Box 14 Principal Chief Jena, LA 71432 Stephanie A. Poarch Band of Creek Indians 5811 Jack Springs Road Bryan, Atmore, AL 36502 Chairwoman Other Organizations and Individuals Mark Watson City of Oak Ridge mwatson@oakridgetn.gov Amy Fitzgerald City of Oak Ridge afitzgerald@oakridgetn.gov Ron Woody Roane County ron.woody@roanecountytn.org Peter Hastings Kairos Power, LLC hastings@kairospower.com Heather Hoff Mothers for Nuclear heather@mothersfornuclear.org Martin ONeill Nuclear Energy Institute mjo@nei.org

B-2 Table B-1 List of Agencies, Organizations, Tribes, and Persons to Whom Copies of this Environmental Assessment Will Be Sent (Continued)

Name Affiliation Contact Information Kati Austgen Nuclear Energy Institute kra@nei.org Alan Ahn Third Way aahn@thirdway.org D.A. Smith D.A. Smith Nuclear Matters D.A. Smith Nuclear Matters dasmith@apocworldwide.com dasmith@apocworldwide.com Danielle Emche Nuclear Innovation Alliance Danielle Emche Nuclear Innovation Alliance demche@nuclearinnovationalliance.org demche@nuclearinnovationalliance.org Natalie Clear Path houghtalen@clearpath.org Houghtalen Christine Oak Ridge Chamber of Commerce Oak Ridge Chamber of Commerce Michaels 1400 Oak Ridge Turnpike Oak Ridge, TN 37830 president@orcc.org Wade Creswell Wade Creswell Roane County 200 East Race Street, Suite 1 Executive P.O. Box 643 Kingston, TN 37763 wade.creswell@roanecountytn.gov Brad Parish Advanced Technologies & Laboratories bparish@atlintl.com Rani Franovich Nuclear ROSE Consulting, LLC rani@thebreakthrough.org 1

2

B-3

1 APPENDIX C 2

3 CHRONOLOGY OF ENVIRONMENTAL REVIEW CORRESPONDENCE

4 This appendix contains a chronological list of correspondence between the U.S. Nuclear 5 Regulatory Commission (NRC) and external parties as part of its environmental review for the 6 Kairos Hermes 2 Test Reactors. These documents are available electronically on the NRCs 7 website at https://www.nrc.gov/reading-rm.html. From this website, members of the public can 8 gain access to the NRCs Agencywide Document Access and Management Systems (ADAMS),

9 which provides text and image files of the NRCs public documents in the Publicly Available 10 Records component of ADAMS. The ADAMS accession numbers for each document are 11 included below. Some of the ADAMS accession numbers below lead to a folder containing 12 several documents. If you need assistance in accessing or searching in ADAMS, contact the 13 Public Document Room staff at 1-800-397-4209.

14 July 14, 2023 Letter to NRC from Peter Hastings, Kairos Power, submitting the 15 Construction Permit Application for Hermes 2 (Accession No.

16 ML23195A122)

17 September 11, 2023 Letter from NRC to Peter Hastings, Kairos Power, Acceptance for 18 Docketing of the Hermes 2 Test Reactor Facility Construction Permit 19 Application Submitted by Kairos Power LLC (Accession No.

20 ML23233A167)

21 September 15, 2023 Federal Register Notice - Acceptance for docketing of the Kairos 22 Power LLC Hermes 2 Test Reactor Construction Permit Application 23 (88 FR 63632) (Accession Number ML23237B465)

24 October 11, 2023 Letter from NRC to Peter Hastings, Kairos Power, Hermes 2 25 Construction Permit Application Review Schedule and Resource 26 Estimate (Accession Number ML23269A176)

27 November 22, 2023 Federal Register Notice - Kairos Power LLC Hermes 2 Construction 28 Permit Application; Opportunity to Request a Hearing and Petition for 29 Leave to Intervene (88 FR 81439) (Accession Number 30 ML23311A195)

31 January 5, 2024 Kairos Power, LLC-Hermes 2-Environmental Report Audit Plan 32 (Accession Number ML23353A069)

33 January 31, 2024 Letter from NRC to Reid Nelson, Advisory Council on Historic 34 Preservation, Request to Initiate Section 106 Consultation for Kairos 35 Power Proposed Non-Power Test Reactors (Hermes 2) Construction 36 Permit Review in Roane County, Tennessee (Accession No.

37 ML24008A099)

38 January 31, 2024 Letter from NRC to E. Patrick McIntyre, Executive Director and State 39 Historic Preservation Officer, Tennessee Historical Commission, 40 Request to Initiate Section 106 Consultation for Kairos Power 41 Proposed Non-Power Test Reactors (Hermes 2) Construction Permit 42 Review in Roane County, Tennessee (Accession No. ML24008A148)

C-1 1 January 31, 2024 Letter from NRC to Niki S. Nicholas, Superintendent, Manhattan 2 Project National Historical Park, Request to Initiate Section 106 3 Consultation for Kairos Power Proposed Non-Power Test Reactors 4 (Hermes 2) Construction Permit Review in Roane County, 5 Tennessee (Docket Numbers 50-611 and 50-612) (ML24009A179)

6 February 2, 2024 Letter from NRC to Hon. Wilson Yargee, Chief, Alabama-Quassarte 7 Tribal Town, Request to Initiate Section 106 Consultation for Kairos 8 Power Proposed Non-Power Test Reactors (Hermes 2) Construction 9 Permit Review in Roane County, Tennessee (Docket Numbers 50-10 611 and 50-612) (Accession No. ML24032A199)

11 February 2, 2024 Letter from NRC to Hon. Ban Barnes, Shawnee Tribe, Request to 12 Initiate Section 106 Consultation for Kairos Power Proposed Non-13 Power Test Reactors (Hermes 2) Construction Permit Review in 14 Roane County, Tennessee (Docket Numbers 50-611 and 50-612) 15 (Accession No. ML24032A186)

16 February 2, 2024 Letter from NRC to Hon. Chuck Hoskin, Jr., Principal Chief, 17 Cherokee Nation, Request to Initiate Section 106 Consultation for 18 Kairos Power Proposed Non-Power Test Reactors (Hermes 2) 19 Construction Permit Review in Roane County, Tennessee (Docket 20 Numbers 50-611 and 50-612) (Accession No. ML24032A187) 21 (Accession No. ML24032A187)

22 February 2, 2024 Letter from NRC to David Hill of Muscogee Nation, Request to Initiate 23 Section 106 Consultation for Kairos Power Proposed Non-Power 24 Test Reactors (Hermes 2) Construction Permit Review in Roane 25 County, Tennessee (Docket Numbers 50-611 and 50-612) 26 (Accession No. ML24032A188)

27 February 2, 2024 Letter from NRC to Hon. Glenna J. Wallace, Chief, Eastern Shawnee 28 Tribe of Oklahoma, Request to Initiate Section 106 Consultation for 29 Kairos Power Proposed Non-Power Test Reactors (Hermes 2) 30 Construction Permit Review in Roane County, Tennessee (Docket 31 Numbers 50-611 and 50-612) (Accession No. ML24032A189)

32 February 2, 2024 Letter from NRC to Hon. Joe Bunch, Chief, United Keetoowah Band 33 of Cherokee Indians, Request to Initiate Section 106 Consultation for 34 Kairos Power Proposed Non-Power Test Reactors (Hermes 2) 35 Construction Permit Review in Roane County, Tennessee (Docket 36 Numbers 50-611 and 50-612) (Accession No. ML24032A190)

37 February 2, 2024 Letter from NRC to Hon. John Raymond Johnson, Governor, 38 Absentee Shawnee Tribe, Request to Initiate Section 106 39 Consultation for Kairos Power Proposed Non-Power Test Reactors 40 (Hermes 2) Construction Permit Review in Roane County, 41 Tennessee (Docket Numbers 50-611 and 50-612) (Accession No.

42 ML24009A112)

C-2 1 February 2, 2024 Letter from NRC to Hon. Jonathan Cernek, Chairman, Coushatta 2 Tribe of Louisiana, Request to Initiate Section 106 Consultation for 3 Kairos Power Proposed Non-Power Test Reactors (Hermes 2) 4 Construction Permit Review in Roane County, Tennessee (Docket 5 Numbers 50-611 and 50-612) (Accession No. ML24032A191)

6 February 2, 2024 Letter from NRC to Hon. Lewis J. Johnson, Chief, Seminole Nation of 7 Oklahoma, Request to Initiate Section 106 Consultation for Kairos 8 Power Proposed Non-Power Test Reactors (Hermes 2) Construction 9 Permit Review in Roane County, Tennessee (Docket Numbers 50-10 611 and 50-612) (Accession No. ML24032A192)

11 February 2, 2024 Letter from NRC to Libby Rogers, Principal Chief, Jena Band of 12 Choctaw Indians, Request to Initiate Section 106 Consultation for 13 Kairos Power Proposed Non-Power Test Reactors (Hermes 2) 14 Construction Permit Review in Roane County, Tennessee (Docket 15 Numbers 50-611 and 50-612) (Accession No. ML24032A200)

16 February 2, 2024 Letter from NRC to Hon. Marcellus W. Osceola, Jr., Chairman, 17 Seminole Tribe of Florida, Request to Initiate Section 106 18 Consultation for Kairos Power Proposed Non-Power Test Reactors 19 (Hermes 2) Construction Permit Review in Roane County, 20 Tennessee (Docket Numbers 50-611 and 50-612) (Accession No.

21 ML24032A193)

22 February 2, 2024 Letter from NRC to Hon. Michell Hicks, Principal Chief, Eastern Band 23 of Cherokee Indians, Request to Initiate Section 106 Consultation for 24 Kairos Power Proposed Non-Power Test Reactors (Hermes 2) 25 Construction Permit Review in Roane County, Tennessee (Docket 26 Numbers 50-611 and 50-612) (Accession No. ML24032A194)

27 February 2, 2024 Letter from NRC to Hon. Rick Sylestine, Chairman, Alabama-28 Coushatta Tribe of Texas, Request to Initiate Section 106 29 Consultation for Kairos Power Proposed Non-Power Test Reactors 30 (Hermes 2) Construction Permit Review in Roane County, 31 Tennessee (Docket Numbers 50-611 and 50-612) (Accession No.

32 ML24032A195)

33 February 2, 2024 Letter from NRC to Hon. Ryan K. Morrow, Town King, Thlopthlocco 34 Tribal Town, Request to Initiate Section 106 Consultation for Kairos 35 Power Proposed Non-Power Test Reactors (Hermes 2) Construction 36 Permit Review in Roane County, Tennessee (Docket Numbers 50-37 611 and 50-612) (Accession No. ML24032A196)

38 February 2, 2024 Letter from NRC to Hon. Stephanie A. Bryan, Chairwoman, Poarch 39 Band of Creek Indians, Request to Initiate Section 106 Consultation 40 for Kairos Power Proposed Non-Power Test Reactors (Hermes 2) 41 Construction Permit Review in Roane County, Tennessee (Docket 42 Numbers 50-611 and 50-612) (Accession No. ML24032A197)

C-3 1 February 2, 2024 Letter from NRC to Stephanie Yahola, Mekko, Kialegee Tribal Town, 2 Request to Initiate Section 106 Consultation for Kairos Power 3 Proposed Non-Power Test Reactors (Hermes 2) Construction Permit 4 Review in Roane County, Tennessee (Docket Numbers 50-611 and 5 50-612) (Accession No. ML24032A198)

6 March 20, 2024 Letter from Wendy Berhman, Superintendent, Manhattan Project 7 National Historical Park to Peyton Doub of NRC, Comments in 8 response to letter dated January 31, 2024. (Accession No.

9 ML24109A060)

C-4 1 APPENDIX D 2

3 REGULATORY COMPLIANCE AND LIST OF FEDERAL, STATE, AND 4 LOCAL PERMITS AND APPROVALS

5 D.1 Required Environmental-Related Authorizations, Permits, and Certifications

6 Table D-1 contains a list of the environmental-related authorizations, permits, and certifications 7 potentially required by Federal, State, regional, local, and affected Native American Tribal 8 agencies related to site preparation, construction, and operation of the Hermes 2 project at the 9 proposed site in Oak Ridge, Tennessee.

10 Section 1.4 of the environmental report (Kairos 2023-TN9774) indicates that the regulatory 11 compliance requirements for Hermes 2 would the same as for the Hermes test reactor, for 12 which the U.S. Nuclear Regulatory Commission recently completed an environmental impact 13 statement (NRC 2023-TN9771) and issued a construction permit. Table D-1 was adapted from 14 Appendix D of the Hermes CP environmental impact statement (NRC 2023-TN9771).

15 D.2 References

16 Kairos Power, LLC. 2023. Letter from P. Hastings, Vice President, Regulatory Affairs and 17 Quality, to NRC Document Control Desk, dated July 14, 2023, regarding Kairos Power LLC, 18 Submittal of the Construction Permit Application for the Hermes 2 Kairos Power Fluoride Salt-19 Cooled, High Temperature Non-Power Reactor. KP-NRC-2307-002, Alameda, California.

20 ADAMS Accession No. ML23195A121. TN9774.

21 NRC (U.S. Nuclear Regulatory Commission). 2023. Environmental Impact Statement for the 22 Construction Permit for the Kairos Hermes Test Reactor, Final Report. NUREG-2263, 23 Washington, D.C. ADAMS Accession No. ML23214A269. TN9771.

D-1 1 Table D-1 Authorizations Required for Preconstruction, Construction, and Operation Activities

Agency Authority Requirement Activity Covered U.S. Nuclear Regulatory Atomic Energy Act Construction Permit Construction of the facilities Commission 10 CFR 50.50 U.S. Nuclear Regulatory 10 CFR 50.57 Operating License Operation of the facilities Commission U.S. Nuclear Regulatory 10 CFR Part 40 Source Material License Possession, use, and transfer of special nuclear material Commission U.S. Nuclear Regulatory 10 CFR Part 30 By-Product Material Production, possession, and transfer of radioactive by-product Commission License material U.S. Nuclear Regulatory 10 CFR Part 70 Special Nuclear Material Receipt, possession, use, and transfer of special nuclear material Commission License U.S. Nuclear Regulatory National Environmental Environmental Site approval for construction and operation of a radiation facilities Commission Policy Act (NEPA) Assessment or 10 CFR Part 51 Environmental Impact Statement in accordance with NEPA Federal Aviation Federal Aviation Act Construction Notice Construction of structures that may impact air navigation (height Administration 14 CFR Part 77 greater than 200 feet [ft]), construction of structures above a 1 to 100 slope from nearest runway U.S. Environmental Resource Conservation Acknowledgment of Generation of hazardous waste Protection Agency and Recovery Act Notification of 40 CFR Part 261 and Hazardous Waste 262 Activity U.S. Environmental Clean Water Act Spill Prevention, Storage of oil during construction and operation Protection Agency 40 CFR Part 112 Control, and Appendix F Countermeasure Plans for Construction and Operation U.S. Fish and Wildlife Endangered Species Section 7 Consultation Protection of endangered and threatened species and critical Service Act habitats designated under the Federal Endangered Species Act U.S. Department of Hazardous Material Certificate of Transportation of hazardous materials Transportation Transportation Act Registration Tennessee Department Federal Clean Air Act Air Pollution Control Construction of an air pollution emission source that is not of Environment and Construction Permit specifically exempted 2 Conservation (TDEC)

Table D-1 Authorizations Required for Preconstruction, Construction, and Operation Activities (Continued)

Agency Authority Requirement Activity Covered Tennessee Department Air Pollution Control Operation of an air pollution emission source that is not of Environment and Operation Permit specifically exempted Conservation (TDEC)

Tennessee Department Federal Clean Water Act Construction Storm Discharge of stormwater runoff from the construction site of Environment and Water Discharge Permit Conservation (TDEC)

Tennessee Department Industrial Storm Water Discharge of stormwater runoff from the site during facilities of Environment and Discharge Permit operation Conservation (TDEC)

Tennessee Department Building Plan Review Compliance with state building codes; required before local of Safety and building permit can be issued for a commercial building Professional Services Tennessee Department Permit for Connection to Construction of driveway connection to Highway 58 of Transportation State Trunk Highway (TDOT)

Tennessee Department Right-of-Entry Permit Construction by the City of Oak Ridge of Utility Extensions across of Transportation Highway 58 (TDOT)

City of Oak Ridge Site Plan Approval Administrative approval of site layout, plans for parking, landscaping, lighting, etc.

City of Oak Ridge Storm Water Plan Administrative approval of grading and drainage plans approval (may be included in Site Plan Approval)

City of Oak Ridge Erosion Control Permit Administrative approval of erosion control plans (may be included in Site Plan Approval)

City of Oak Ridge Building Permit Construction of buildings City of Oak Ridge Plumbing Plan Approval Installation of plumbing systems

Table D-1 Authorizations Required for Preconstruction, Construction, and Operation Activities (Continued)

Agency Authority Requirement Activity Covered City of Oak Ridge Heating, Ventilation, and Installation of heating, ventilation, and air conditioning systems Air Conditioning Plan approval City of Oak Ridge Occupancy Permit Occupancy of completed buildings City of Oak Ridge Conditional use Permit Construction of multiple buildings on the same site City of Oak Ridge Sanitary Sewer and Administrative approval of construction, installation, and operation Water Supply Facility of connections to the municipal sewer and water supply systems Approvals Tennessee State Section 106 of the National Historic Protection of archaeological and historical resources Historic Preservation National Historic Preservation Act Section Office Tribal Historic Preservation Act 106 compliance and Preservation Officer consultation, which includes State Historic Preservation Office/Tribal Historic Preservation Officers, and identification of potentially affected resources, i.e., a site survey

1

1 APPENDIX E 2

3 GREENHOUSE GAS EMISSIONS ESTIMATES FOR A REFERENCE 4 1,000 MWE REACTOR AND THE HERMES 2 TEST REACTOR

5 The U.S. Nuclear Regulatory Commission (NRC) staff estimated the greenhouse gas (GHG) 6 emissions of various activities associated with the building, operating, and decommissioning of 7 nuclear power plants. The GHG emission estimates include direct emissions from the nuclear 8 facility and indirect emissions from workforce and fuel transportation, decommissioning, and the 9 uranium fuel cycle. The estimates are based on a single installation of 1,000 megawatts electric 10 (MWe) output with an 80 percent capacity factor henceforth referred to as the reference 11 1,000 MWe reactor. The estimates may be roughly linearly scaled from the reference 12 1,000 MWe reactor for other reactor outputs.1 This report discusses the calculation of GHG 13 emission estimates for the reference 1,000 MWe reactor.

14 The estimated emissions from equipment used to build a nuclear power plant listed in Table E-1 15 are based on hours of equipment use estimated for a single nuclear power plant at a site 16 requiring a moderate amount of terrain modification (UniStar 2007-TN1564).

17 Table E-1 Greenhouse Gas Emissions from Equipment Used in Building and 18 Decommissioning (metric tons [MT] CO2(e))

Equipment Building Total(a) Decommissioning Total(b)

Earthwork and dewatering 12,000 6,000 Batch plant operations 3,400 1,700 Concrete 5,400 2,700 Lifting and rigging 5,600 2,800 Shop fabrication 1,000 500 Warehouse operations 1,400 700 Equipment maintenance 10,000 5,000 Total(c) 39,000 19,000 (a) Based on hours of equipment usage over a 7-year period.

(b) Based on equipment usage over a 10-year period.

(c) Results are rounded to the nearest 1,000 MT CO2(e).

19 Construction equipment carbon monoxide (CO) emission estimates were derived from the hours 20 of equipment use, and carbon dioxide (CO2) emissions were then estimated from the CO 21 emissions using a scaling factor of 172 tons of CO2 per ton of CO (Chapman et al. 2012-22 TN2644). The scaling factor is based on the ratio of CO2 to CO emission factors for diesel fuel 23 industrial engines as reported in Table 3.3-1 of AP-42 Compilation of Air Pollutant Emission 24 Factors (EPA 2012-TN2647). A CO2 to total GHG equivalency factor of 0.991 is used to account 25 for the emissions from other GHGs, such as methane (CH4) and nitrous oxide (N2O) (Chapman 26 et al. 2012-TN2644). The equivalency factor is based on non-road/construction equipment in 27 accordance with relevant guidance (NRC 2014-TN3768; Chapman et al. 2012-TN2644).

1 The term model LWR" has also been used to describe a 1,000 MWe light water reactor for the purpose of evaluating the environmental considerations of the supporting fuel cycle to the annual reactor operations (AEC 1974-TN23). It is assumed there are no significant differences between the 1,000 MWe reactor evaluated in WASH-1248 and the 1,000 MWe reference reactor evaluated in this appendix.

E-1 1 Equipment emissions estimates for decommissioning are assumed to be one-half of those for 2 construction equipment. Data on equipment emissions for decommissioning are not available; 3 the one-half factor is based on the assumption that decommissioning would involve less 4 earthmoving and hauling of material, as well as fewer labor hours, compared to those involved 5 in building activities (Chapman et al. 2012-TN2644).

6 Table E-2 lists the NRC staffs estimates of the CO2 equivalent2 (CO2(e)) emissions associated 7 with workforce transportation. Construction workforce estimates for the reference 1,000 MWe 8 reactor are conservatively based on estimates in various combined license applications 9 (Chapman et al. 2012-TN2644), and the operational and decommissioning workforce estimates 10 are based on Supplement 1 to NUREG-0586 (NRC 2002-TN665). Table E-2 lists the 11 assumptions used to estimate total miles traveled by each workforce and the factors used to 12 convert total miles to metric tons of CO2(e). The workers are assumed to travel in gasoline-13 powered passenger vehicles (cars, trucks, vans, and sport utility vehicles) that get an average 14 of 21.6 mi/gal (9.1 km/L) of gasoline (FHWA 2012-TN2645). Conversion from gallons of 15 gasoline burned to CO2(e) is based on U.S. Environmental Protection Agency emission factors 16 (EPA 2012-TN2643).

17 Table E-2 Workforce Greenhouse Gas Footprint Estimates

SAFe Construction Operational Decommissioning STORage Parameter Workforce Workforce Workforce Workforce Commuting Trips 1,000 550 200 40 (round trips per day)

Commute Distance 40 40 40 40 (miles per round-trip)

Commuting Days 365 365 250 365 (days per year)

Duration (years) 7 40 10 40 Total Distance Traveled (miles)(a) 102,000,000 321,000,000 20,000,000 23,000,000 Average Vehicle Fuel Efficiency(b) 21.6 21.6 21.6 21.6 (miles per gallon)

Total Fuel Burned(a) (gallons) 4,700,000 14,900,000 900,000 1,100,000 CO2 Emitted Per Gallon(c) 0.00892 0.00892 0.00892 0.00892 (MT CO2)

Total CO2 Emitted(a) 42,000 133,000 8,000 10,000 (MT CO2)

CO2 Equivalency Factor(c) 0.977 0.977 0.977 0.977 (MT CO2/MT CO2(e))

Total GHG Emitted(a) 43,000 136,000 8,000 10,000 (MT CO2(e))

Key: CO2 = carbon dioxide; CO2(e) = carbon dioxide equivalent; GHG = greenhouse gas; MT = metric ton.

(a) Values have been rounded.

(b) Source: FHWA 2012-TN2645.

(c) Source: EPA 2012-TN2643

2 A measure to compare the emissions from various GHGs on the basis of their global warming potential, defined as the ratio of heat trapped by one unit mass of the GHG to that of one unit mass of CO2 over a specific time period.

E-2 1 Title 10 of the Code of Federal Regulations 51.51(a) (10 CFR 51.51(a) TN250) states that every 2 environmental report (ER)3 prepared for an early site permit or combined license stage of a 3 light-water-cooled nuclear power reactor shall use Table S-3, Table of Uranium Fuel Cycle 4 Environmental Data, as set forth in 10 CFR 51.51(b) (TN250) as the basis for evaluating the 5 contribution of the environmental effects of uranium fuel-cycle activities to the environmental 6 costs of licensing the nuclear power reactor. Section 51.51(a) (TN250) further states that 7 Table S-3 shall be included in the ER and may be supplemented by a discussion of the 8 environmental significance of the data set forth in the table as weighted in the project-specific 9 analysis for the proposed facility.

10 Table S-3 of 10 CFR 51.51(b) (TN250) does not directly apply to non-light-water reactors 11 (LWRs), nor does it provide an estimate of GHG emissions associated with the uranium fuel 12 cycle; it only addresses pollutants that were of concern when the table was promulgated in the 13 1970s. However, Table S-3 states that 323,000 megawatt hour (MWh) is the assumed annual 14 electric energy use for the Table S-3 reference 1,000 MWe nuclear power plant and that this 15 323,000 MWh of annual electric energy is assumed to be generated by a 45 MWe coal-fired 16 power plant burning 118,000 MT of coal. These assumptions are based upon 1970s uranium 17 enrichment technology, which has changed substantially since then. The older, energy-intensive 18 gaseous-diffusion plants have been replaced with more efficient centrifuge-based systems. The 19 current operating gas centrifuge uranium enrichment facility in the United States is URENCO-20 USA (Louisiana Energy Services), which is located in Eunice, New Mexico. The URENCO-USA 21 facility does not rely solely upon coal as an energy source (Napier 2020-TN6443). If a 22 1,000 MWe plant is assumed to operate at 35 percent thermal efficiency and use uranium fuel 23 enriched to 5 percent in uranium-235 (235U) with an average burnup of 40,000 megawatt 24 days/MT for 40 years, then it will require about 1,043 tons of enriched uranium for fuel. To 25 produce 1 ton of 5 percent enriched uranium with 0.25 percent 235U in the depleted uranium 26 stream requires extraction of 10.3 tons of natural uranium and 7,923 separative work units, or 27 SWUs (Napier 2020-TN6443). The 1,043 tons of uranium enriched to 5 percent 235U required 28 over the 40-year life of the 1,000 MWe plant would then require 8,264,000 SWUs. Because a 29 centrifuge enrichment facility requires about 50 kWh per SWU (WNA 2020-TN6661), a total of 30 413,200 MWh is needed to produce 40 years worth of uranium enriched to 5 percent 235U for 31 fuel for the lifetime operation of the 1,000 MWe plant. For the existing U.S. centrifuge 32 enrichment plant, the regional average CO2 emission factor is 1,248 lb/MWh,4 and the total CO2 33 emission is about 243,000 MT.

34 Table S-3 also assumes that approximately 135,000,000 standard cubic feet (scf) of natural gas 35 is required per year to generate process heat for certain portions of the uranium fuel cycle. The 36 NRC staff estimates that burning 135,000,000 scf of natural gas per year results in 37 approximately 7,440 MT of CO2(e) being emitted into the atmosphere per year because of the 38 process heat requirements of the uranium fuel cycle.5 For a 40-year operational life, this is 39 298,000 MT of CO2(e). This amount is in addition to the CO2(e) emissions from the enrichment 40 process.

3 The NRC requires most applicants, including all reactor applicants, to submit an ER as part of the application. 10 CFR 51.45 and 10 CFR 51.50 (TN250).

4 The EPA provides estimates of emissions from electricity production for different regions in the United States at https://www.epa.gov/energy/emissions-generation-resource-integrated-database-egrid for CO2 in units of pounds per kilowatt-hour (lb/kWh). The value for southeastern New Mexico has been applied here (EPA 2023-TN9079).

5 The conversion is 0.0551 (metric tons CO2/thousand scf) (EPA 2023-TN9080).

E-3 1 The NRC staff estimated GHG emissions related to plant operations from the typical usage of 2 various onsite diesel generators (UniStar 2007-TN1564). Carbon monoxide emission estimates 3 were derived assuming an average of 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> (h) of emergency diesel generator operation 4 per year (four generators, each operating 150 h/yr) and 200 h of station blackout diesel 5 generator operation per year (two generators, each operating 100 h/yr) (Chapman et al. 2012-6 TN2644). A scaling factor of 172 was then applied to convert the CO emissions to CO2 7 emissions, and a CO2 to total GHG equivalency factor of 0.991 was used to account for the 8 emissions from other GHGs such CH4 and N2O (Chapman et al. 2012-TN2644).

9 The number of shipments and shipping distances for transport of fresh nuclear fuel, spent 10 nuclear fuel, and radioactive wastes are presented in Table S-5 of Supplement 1 to WASH-1238 11 (NRC 1975-TN216), for a 1,100 MWe LWR with an 80 percent capacity factor. WASH-1248 12 (AEC 1974-TN23) assumes that truck casks weigh 50,000 lb (23 MT) and rail casks weigh 100 t 13 (91 Mt). For this analysis, emission rates of CO2 are calculated as 64.7 g/t-mi (44.2 g/MT-km) 14 for trucks and 32.2 g/T-mi (22 g/MT-km) for rail (Cefic and European Chemical Transport 15 Association 2011-TN6966). For the calculation, it was also assumed that return trips with empty 16 casks double the total miles traveled by truck or rail. Table E-3 presents estimated annual 17 CO2(e) emissions from shipments associated with the reference 1,000 MWe reactor.

18 Table E-3 Annual Number of Shipments for the Reference 1,000 MWe Reactor

Annual Number of Shipments for the Reference 1,000 MWe Annual CO2(e)

Material Reactor Typical Distance (mi)(a) Emissions(b)

Unirradiated fuel (truck) 6 1,000 19 Spent fuel (truck) 60 1,000 194 Spent fuel (rail) 10 1,000 64 Radioactive waste (truck) 46 500 74 Key: Co2(e) = carbon dioxide equivalent; mi = mile MWe = megawatt electric.

(a) Source: NRC 1975-TN216, Table S-5.

(b) Results are rounded to the nearest 1,000 MT CO2(e).

19 The total GHG emissions for fuel and waste transportation was approximately 352 MT per 20 reference reactor-year as presented in Table E-3. Over a 40-year operating life for the reference 21 1,000 MWe reactor, the total is approximately 14,000 MT of CO2(e) emitted.

22 Given the various sources of GHG emissions discussed above, the NRC staff estimated the 23 total lifetime GHG footprint for the reference 1,000 MWe reactor to be about 990,000 MT 24 CO2(e), with a 7-year building phase, 40 years of operation, and 10 years of active 25 decommissioning.6 These source categories of the GHG emissions footprint are summarized in 26 Table E-4.

6 Under NRC regulations, a reactor licensee has up to 60 years to complete the decommissioning of a reactor facility commencing with the licensees certification that it has permanently ceased reactor operations (10 CFR 50.82(a)(3); TN249). The 60-year decommissioning period may be exceeded subject to NRC approval, if necessary, to protect public health and safety. Id. The estimated 10-year decommissioning period is a subset of the 60-year decommissioning period, during which significant demolition and earth-moving activities may occur (e.g., deployment and operation of equipment at the decommissioning site and shipments by truck or rail to remove irradiated soil, rubble, and debris from the site), as discussed in Supplement 1 to NUREG-0586 (NRC 2002-TN665).

E-4 1 Table E-4 Nuclear Power Plant Life-Cycle Greenhouse Gas Footprint

Total Emissions Source Activity Duration (yr)(a) (MT CO2(e))

Construction equipment 7 39,000 Construction workforce 7 43,000 Plant operations 40 181,000 Operations workforce 40 136,000 Uranium fuel cycle 40 540,000 Fuel and waste transportation 40 14,000 Decommissioning equipment 10 19,000 Decommissioning workforce 10 8,000 SAFe STORage workforce 40 10,000 TOTAL(b) 990,000 Key: CO2(e) = carbon dioxide equivalent; MT = metric tons; yr = year.

(a) Nuclear power plant life -cycle for estimating greenhouse gas is assumed to be 97 years which includes building, operating, and decommissioning.

(b) Results are rounded to the nearest 1,000 MT CO2(e).

2 The uranium fuel cycle component of the footprint is the largest portion of the overall estimated 3 GHG emissions and is directly related to the assumed power generated by the plant. The GHG 4 emission estimates for the uranium fuel cycle are based on newer enrichment technology, 5 assuming that the energy required for enrichment is provided by modern regional electric 6 systems.

7 The Intergovernmental Panel on Climate Change (IPCC) released a special report about 8 renewable energy sources and climate change mitigation in 2012 (IPCC 2012-TN2648).

9 Annex II of the IPCC report includes an assessment of previously published works on life-cycle 10 GHG emissions from various electric generation technologies, including nuclear energy. The 11 IPCC report included only reference material that passes certain screening criteria for quality 12 and relevance in its assessment. The IPCC screening yielded 125 estimates of nuclear energy 13 life-cycle GHG emissions from 32 separate references. The IPCC-screened estimates of the 14 life-cycle GHG emissions associated with nuclear energy, as shown in Table A.II.4 of the IPCC 15 report, ranged from 1 to 220 g of CO2(e)/kWh, with 25th percentile, 50th percentile, and 75th 16 percentile values of 8 g CO2(e)/kWh, 16 g CO2(e)/kWh, and 45 g CO2(e)/kWh, respectively. The 17 range of the IPCC estimates is due, in part, to assumptions regarding the type of enrichment 18 technology employed, how the electricity used for enrichment is generated, the grade of mined 19 uranium ore, the degree of processing and enrichment required, and the assumed operating 20 lifetime of a nuclear power plant. The NRC staffs life-cycle GHG estimate of approximately 21 990,000 MT CO2(e) for the reference 1,000 MWe reactor is equal to about 3.5 g CO2(e)/kWh, 22 which places the NRC staffs estimate at the lower end of the IPCC estimates in Table A.II.4 of 23 the IPCC report. This placement is primarily because the IPCC estimates were for LWRs that 24 used enrichment technologies that were based on the use of coal-fired generation as the 25 electricity source.

26 The calculation of GHG emissions for the proposed Hermes 2 facility assumes that two 27 35 megawatt thermal (MWt) advanced reactors would be installed. Assuming that GHG 28 emission estimates for operation and extended SAFe STORage for the proposed Hermes 2 29 reactors, could generally be scaled based on the plants output, the estimates for these stages 30 would be scaled down to 1.3 percent of the totals for the reference reactor calculated above.

E-5 1 Because two units would be installed, additional scaling by a factor of two was needed to 2 account for the number of the reactors at the proposed site. As a conservative assumption, 3 emissions from preconstruction/construction and decommissioning activities are assumed to be 4 half of those estimated for the reference reactor. In addition, the durations for 5 preconstruction/construction activities would be shorter than the durations assumed for the 6 reference reactor in Table E-4.

7 The GHG emission estimates for the reference reactor for the uranium fuel cycle and 8 transportation of fuel and waste are based on an annual capacity factor of 80 percent. Although 9 this annual capacity factor assumed for the reference commercial power production would not 10 necessarily apply to a research reactor, a capacity factor of 80 percent is assumed to be 11 bounding for the two test reactors. Under this assumption, the staff estimated GHG emissions 12 for uranium fuel cycle activities and fuel and waste transport associated for the proposed 13 Hermes 2 test reactors as 2.6 percent (1.3x2) of the totals presented for the reference 14 3,415 MWt (1,000 MWe) reference reactor. The assumed activity durations and total GHG 15 emissions for these activities for the reference reactor and for the Hermes 2 test reactors are 16 shown in Table E-5.

17 Table E-5 Life-Cycle Assumptions and GHG Emissions for Hermes 2

3,415 MWt Reference Reactor Two 35 MWt Hermes 2 reactors Activity Activity Total Duration Total Emissions Scaling Duration Emissions Source (yr)(a) (MT CO2(e)) factor (yr)(b) (MT CO2(e))

Construction equipment 7 39,000 0.5 3 8,357 Construction workforce 7 43,000 0.5 3 9,214 Plant operations 40 181,000 0.026 11 1,294 Operations workforce 40 136,000 0.026 11 972 Uranium fuel cycle 40 540,000 0.026 11 3,861 Fuel and waste transportation 40 14,000 0.026 11 100 Decommissioning equipment 10 19,000 0.5 10 9,500 Decommissioning workforce 10 8,000 0.5 10 4,000 SAFe STORage workforce 40 10,000 0.026 40 260 TOTAL(c) 990,000 38,000 Key: CO2(e) = carbon dioxide equivalent; MT = metric tons; MWt = megawatt thermal; yr = year.

(a) Nuclear power plant life-cycle for estimating GHG is assumed to be 97 years which includes construction (7 years), operations (40 years), and decommissioning (50 years).

(b) Nuclear power plant life-cycle for estimating GHG is assumed to be 64 years which includes construction (3 years), operations (11 years), and decommissioning (50 years).

(c) Results are rounded to the nearest 1,000 MT CO2e

18 The NRC staff calculated that the GHG emissions for the proposed Hermes 2 test reactors to be 19 approximately 38,000 MT CO2(e) using the assumptions discussed above to scale the 20 emissions from the reference 1,000 MWe reactor. A scaling factor of 0.026 is calculated from 21 the ratio of power outputs between the reference 3,415 MWt reactor accounting for 0.8 capacity 22 factor.

23 Scaling Factor = 35 MWt x 2 (3,415 MWt x 0.8)= 0.026

E-6 1 Yearly GHG emissions from the reference 3,415 MWt reactor is scaled down and then 2 multiplied by the number of years of construction, operation or decommissioning as shown 3 below:

4 Hermes CO2e Emissions

5 = 3,415 MWt Reactor CO (e) x Scaling Factor x Years of Activity for 35 MWt reactor 2 Years of Activity for 3,415 MWt reactor

6 A 3-year of construction period and an 11-year operation period were assumed for the 7 Hermes 2 reactors. The period of decommissioning and SAFe STORage activities were kept the 8 same as that for the reference reactor due to uncertainty with future post closure waste 9 management activities. The staff calculated that the GHG emissions for the Hermes 2 test 10 reactors to be 37,600 MT CO2(e). Comparing the entire life cycle estimated GHG emissions 11 from construction, operation, uranium fuel cycle, transportation of fuel and waste, and 12 decommissioning activities to 2019 total gross annual U.S. energy sector emissions, the 13 projects GHG emissions would be about 0.0007 percent of the 2019 GHG emissions from the 14 U.S. energy sector.

15 E.1 References

16 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, Domestic Licensing of 17 Production and Utilization Facilities. TN249.

18 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, Environmental 19 Protection Regulations for Domestic Licensing and Related Regulatory Functions. TN250.

20 AEC (U.S. Atomic Energy Commission). 1974. Environmental Survey of the Uranium Fuel 21 Cycle. WASH-1248, Washington, D.C. ADAMS Accession No. ML14092A628. TN23.

22 Cefic and ECTA (European Chemical Industry Council and European Chemical Transport 23 Association). 2011. Guidelines for Measuring and Managing CO2 Emission from Freight 24 Transport Operations. Brussels, Belgium. Accessed March 21, 2021, at 25 https://www.ecta.com/resources/Documents/Best%20Practices%20Guidelines/guideline_for_m 26 easuring_and_managing_co2.pdf. TN6966.

27 Chapman, E.G., J.P. Rishel, J.M. Niemeyer, K.A. Cort, and S.E. Gulley. 2012. Assumptions, 28 Calculations, and Recommendations Related to a Proposed Guidance Update on Greenhouse 29 Gases and Climate Change. PNNL-21494, Pacific Northwest National Laboratory, Richland, 30 Washington. ADAMS Accession No. ML12310A212. TN2644.

31 EPA (U.S. Environmental Protection Agency). 2012. Clean Energy: Calculations and 32 References. Washington, D.C. ADAMS Accession No. ML12292A648. TN2643.

33 EPA (U.S. Environmental Protection Agency). 2012. Stationary Internal Combustion Sources.

34 Chapter 3 in Technology Transfer Network Clearinghouse for Inventories & Emissions Factors:

35 AP-42. Fifth Edition, Research Triangle Park, North Carolina. ADAMS Accession No.

36 ML12292A637. TN2647.

E-7 1 EPA (U.S. Environmental Protection Agency). 2023. Emissions & Generation Resource 2 Integrated Database (eGRID). Washington, D.C. Accessed October 4, 2023, at 3 https://www.epa.gov/egrid. TN9079.

4 EPA (U.S. Environmental Protection Agency). 2023. Greenhouse Gases Equivalencies 5 Calculator - Calculations and References. Washington, D.C. Accessed October 4, 2023, at 6 https://www.epa.gov/energy/greenhouse-gases-equivalencies-calculator-calculations-and-7 references. TN9080.

8 FHWA (Federal Highway Administration). 2012. Highway Statistics 2010 (Table VM-1). Office 9 of Highway Policy Information, Washington, D.C. ADAMS Accession No. ML12292A645.

10 TN2645.

11 IPCC (Intergovernmental Panel on Climate Change). 2012. Renewable Energy Sources and 12 Climate Change MitigationSpecial Report of the Intergovernmental Panel on Climate Change.

13 Cambridge University Press, Cambridge, United Kingdom. TN2648.

14 Napier, B.A. 2020. Non-LWR Fuel Cycle Environmental Data. PNNL-29367, Revision 2, 15 Richland, Washington. ADAMS Accession No. ML20267A217. TN6443.

16 NRC (U.S. Nuclear Regulatory Commission). 1975. Environmental Survey of Transportation of 17 Radioactive Materials to and from Nuclear Power Plants, Supplement 1. NUREG-75/038, 18 Washington, D.C. ADAMS Accession No. ML14091A176. TN216.

19 NRC (U.S. Nuclear Regulatory Commission). 2002. Final Generic Environmental Impact 20 Statement of Decommissioning of Nuclear Facilities (NUREG-0586). NUREG-0586, 21 Supplement 1, Volumes 1 and 2, Washington, D.C. ADAMS Accession Nos. ML023470327, 22 ML023500228. TN665.

23 NRC (U.S. Nuclear Regulatory Commission). 2014. Attachment 1: Staff Guidance for 24 Greenhouse Gas and Climate Change Impacts for New Reactor Environmental Impact 25 Statements, COL/ESP-ISG-026. Washington, D.C. ADAMS Accession No. ML14100A157.

26 TN3768.

27 UniStar (UniStar Nuclear Energy, LLC). 2007. Technical Report in Support of Application of 28 UniStar Nuclear Energy, LLC and UniStar Nuclear Operating Services, LLC for Certificate of 29 Public Convenience and Necessity Before the Maryland Public Service Commission for 30 Authorization to Construct Unit 3 at Calvert Cliffs Nuclear Power Plant and Associated 31 Transmission Lines. Public Service Commission of Maryland, Baltimore, Maryland. ADAMS 32 Accession No. ML090680053. TN1564.

33 WNA (World Nuclear Association). 2020. Uranium Enrichment. London, United Kingdom.

34 Webpage accessed October 16, 2020, at https://www.world-nuclear.org/information-35 library/nuclear-fuel-cycle/conversion-enrichment-and-fabrication/uranium-enrichment.aspx.

36 TN6661.

37

E-8 1 APPENDIX F 2

3 PAST, PRESENT, AND REASONABLY FORESEEABLE PROJECTS 4 AND OTHER ACTIONS CONSIDERED IN THE CUMULATIVE 5 EFFECTS ANALYSIS

6 In determining the cumulative environmental impacts associated with the construction, 7 operation, and decommissioning of Hermes 2, the combination of the past, present, and 8 reasonably foreseeable actions or projects presented in Section 4.13 of the Hermes 9 Environmental Report (ER) (Kairos 2023-TN8172) were evaluated , with the exception that the 10 potential effects of the Hermes facility were also considered in the Hermes 2 evaluation.

11 Table F-1 reproduces, in part, Table 4.13-1 from the Hermes ER (Kairos 2023-TN 8172) used in 12 the cumulative impact evaluation.

13 Table F-1 Past, Present, and Reasonably Foreseeable Projects and Other Actions 14 Considered in the Cumulative Effects Analysis

Location Potentially (from Reactor Affected Project Name Summary of Project building) Status Resource(s)

Federal Facilities Proposed Clinch Two or more small 3.5 mi south Proposed NRC Land use and River Nuclear modular reactors to southeast issued ESP006 on visual resources, Site be built by TVA December 19, air quality and 2019 noise, water resources, ecological resources, transportation, socioeconomics East Tennessee Clean up and Adjacent across In progress Land use and Technology Park redevelopment of the Poplar Creek visual resources, former Manhattan air quality, Project Site transportation, socioeconomics, noise, water resources, human health Sludge Construction of a Approximately Construction Water resources, Processing Mock TRU sludge waste 5.3 mi east underway; air quality, land Test Facility processing facility expected use, waste completion 2022 management Uranium New building in Y-12 Approximately Construction began Water resources, Processing complex 8.4 mi northeast 2018; expected to air quality and Facility at Y12 continue through noise, waste 2025 management, human health 15

F-1 Table F-1 Past, Present, and Reasonably Foreseeable Projects and Other Actions Considered in the Cumulative Effects Analysis (Continued)

Location Potentially (from Reactor Affected Project Name Summary of Project building) Status Resource(s)

Outfall 200 Construction of two Approximately 9 mi Construction began Water quality, air Mercury mercury treatment northeast 2017 and quality and noise, Treatment Facility facilities in separate scheduled to begin human health, at Y12 areas connected by a operations in mid waste management pipeline 2020s New Y12 Steam Natural gas power Approximately 9 mi Operational since Air quality Plant generation for Y12 northeast 2010 operations.

Y12 Shipping Nonhazardous West and adjacent Operational Transportation and Receiving shipping and <1,000 ft (onsite receiving facility verification)

K1251 Barge Barge docking facility 2 mi southeast Operational Transportation Facility approximately 1 ac in size.

Roane Regional Business and Approximately 5 mi Operational since Land use and Business and industrial park with southeast 2001 visual resources, Technology Park sites for development water resources, air quality, socioeconomics, transportation ORNL DOE Nuclear and Approximately 5 mi Operational since Water resources, HighTech Research east 1943 air quality Facility ORNL Acceleratorbased Approximately Operational since Air quality, water Spallation neutron pulse for 5.8 mi east 2006 resources, human Neutron Source R&D. Includes health, waste upgrades and second management target station construction completion 2025.

ORNL High Flux Critical reaction Approximately Operational since Air quality, water Isotope Reactor providing a stable 5.75 mi east 1965. resources, human beam of neutrons for Decommission health, waste R&D. anticipated after management 2060.

White Oak Dam Manhattan Project Approximately 5 mi Operational since Water resources, impoundment on southeast 1943 human health White Oak Creek with 25 ac settling pond.

Formed to reduce radioactive waste runoff into Clinch River, must be remediated by 2036.

F-2 Table F-1 Past, Present, and Reasonably Foreseeable Projects and Other Actions Considered in the Cumulative Effects Analysis (Continued)

Location Potentially (from Reactor Affected Project Name Summary of Project building) Status Resource(s)

Environmental Proposed new landfill Approximately Proposed Water resources, Management for disposal of 5.3 mi northeast air quality, Waste radioactive, (current location is socioeconomics, Management hazardous, and toxic 6.8 mi northeast) human health, Facility on ORR wastes in Oak Ridge waste management because current landfill will soon reach full capacity Industries and Manufacturing Facilities Kairos Power Fabrication of TRISO- Near or on K31 Potential Land use and Fuel Fabrication coated uranium site visual resources, Facility oxycarbide (UCO) air quality and kernels in a graphite noise, geologic matrix resources, water resources, socioeconomics, transportation, human health, waste management Ultra Safe Fabrication of TRISO Approximately Operational since Land use and Nuclear coated UCO kernels 0.8 mi southeast 2022 visual resources, Corporation Pilot in a graphite matrix noise, Fuel socioeconomics, Manufacturing transportation Facility TRISOX Fuel Fabrication of TRISO Approximately Proposed Land use and Fabrication coated UCO kernels 2.4 mi northeast visual resources, Facility in a graphite matrix air quality, socioeconomics, human health, transportation Coquí Pharma Planned Medical Duct Island; Proposed Land use and Isotope Production Approximately visual resources, Facility 0.75 mi south air quality and noise, water resources, socioeconomics, human health Tellico West Development of 25.4 mi southeast Proposed Air quality, Industrial Park industrial site for socioeconomics Tellico Reservoir Development Agency

F-3 Table F-1 Past, Present, and Reasonably Foreseeable Projects and Other Actions Considered in the Cumulative Effects Analysis (Continued)

Location Potentially (from Reactor Affected Project Name Summary of Project building) Status Resource(s)

EnergySolutions, Processing and Approximately Operational Air quality, water LLC Bear Creek packaging of 2.1 mi southeast resources, human Facility radioactive material health, waste for permanent management disposal Horizon Center Industrial park Approximately Various lots sold Land use and Industrial Park available for 2.3 mi northeast and available visual resources, development air quality, water resources, socioeconomics, transportation, noise Heritage Center Industrial park Onsite and Various sites Land use and Industrial Park available for extending south pending sale, visual resources, development; and east leased, sold, or air quality and includes Hermes site fully serviced noise, water and Coquí Pharma resources, project site on Duct socioeconomics, Island transportation, noise Transportation Projects TDOT Projects Bridge Replacement, Approximately Preplanning, no Transportation, I40 over Clinch River 7.5 mi southwest data socioeconomics in Kingston TDOT Projects Total projects in fiveVarious within the Planned or in Transportation, with proposed county region of region of interest progress socioeconomics letting dates interest: 108, includes bridge repair/replacement, resurfacing, maintenance, and repair Construction of a Development of a Approximately Have not broken Land use and General Aviation general aviation 1.1 mi east ground yet; visual resources, Airport Future airport construction could air quality and Oak Ridge Airport start in 2021. noise, water resources, socioeconomics, transportation Utility Projects City of Oak Ridge Upgrade aging Approximately Construction to Air quality, water Water Treatment drinking water 9.6 mi northeast begin upon award resources, Plant treatment plant/ of WIFIA grant socioeconomics infrastructure (WIFIA grant)

F-4 Table F-1 Past, Present, and Reasonably Foreseeable Projects and Other Actions Considered in the Cumulative Effects Analysis (Continued)

Location Potentially (from Reactor Affected Project Name Summary of Project building) Status Resource(s)

New Construction The Preserve at New home Approximately 2 mi Operational since Land use and Clinch River construction, subarea south 2002 visual resources, G water resources, air quality, socioeconomic Kingston Point New residential, Approximately 9 mi proposed Land use and recreational, and southwest visual resources, commercial socioeconomics development Energy Projects Nuclear Sequoyah Power Generation Approximately Operational since Air quality, human Nuclear Plant, 62.5 mi southwest 1981 and 1982, health Units 1 and 2 respectively Watts Bar Power Generation Approximately Operational since Air quality, human Nuclear Plant, 31.75 mi 1996 and 2016, health Units 1 and 2 southwest respectively CoalFired Bull Run Fossil Net capability Bull Run Creek; Operational since Air quality, human Plant 870 MWe approximately 1967; will be retired health 15 mi northeast in Dec 2023 with decommissioning taking 56 years Kingston Fossil Net capability Watts Bar Operational since Air quality, human Plant 1,379 MWe Reservoir; 1955 health approximately 7 mi west Oher Actions/Projects Roane County Combine Harriman, Approximately Planning Land use and High School Rockwood, and 12 mi southwest visual resources, Roane County High transportation, Schools into a new socioeconomics combined high school to be located adjacent to Roane State Community College.

Key: ac = acre; DOE = Department of Energy; mi = mile; MWe = megawatts electric; NRC = U.S. Nuclear Regulatory Commission; ORNL = Oak Ridge National Laboratory; ORR = Oak Ridge Reservation; R&D = research and development; ROI = region of interest; TDOT = Tennessee Department of Transportation; TRISO = tristructural isotropic; TRU = transuranic; TVA = Tennessee Valley Authority; UCO = uranium oxycarbide; WIFIA = Water Infrastructure Finance and Innovation Act.

Source: Reproduced in part from Table 4.13-1 from the Hermes ER (Kairos 2023-TN 8172)

F-5

NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER (12-2010) (Assigned by NRC, Add Vol., Supp., Rev.,

NRCMD 3.7 and Addendum Numbers, if any.)

BIBLIOGRAPHIC DATA SHEET (See instructions on the reverse) ML24103A002

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED Environmental Assessment and Finding of No Significant Impact for the Construction MONTH YEAR Permits for the Kairos Hermes 2 Test Reactors April 2024 Draft Report for Comment 4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT See Appendix A Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U. S. Nuclear Regulatory Commission, and mailing address; if contractor, provide name and mailing address.)

Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type "Same as above", if contractor, provide NRC Division, Office or Region, U. S. Nuclear Regulatory Commission, and mailing address.)

Same as above

10. SUPPLEMENTARY NOTES Dockets 50-0611 and 50-0612

11. ABSTRACT (200 words or less)

This draft environmental assessment (EA) describes the environmental review conducted by U.S. Nuclear Regulatory Commission (NRC) staff for an application by Kairos Power, LLC (Kairos) for construction permits under Title 10 of the Code of Federal Regulations Part 50, allowing construction of two non-power test reactors termed Hermes 2 on a 185-acre site in Oak Ridge, Tennessee. Hermes 2 would be built on the same site as Hermes, another non -power test reactor for which Kairos has already received a construction permit from the NRC. As with Hermes, Kairos plans to build and operate Hermes 2 to demonstrate key elements of the Kairos Power Fluoride Salt -Cooled, High Temperature Reactor technology for possible future commercial deployment. Each Hermes 2 reactor would be of similar size and design as the Hermes reactor but would include specific design differences. The draft EA follows procedures in 10 CFR 51.30, Environmental assessment, and 10 CFR 51.31, Determinations based on environmental assessment, whi ch are NRCs regulations for preparing EAs to implement the National Environmental Policy Act of 1969. The NRC staff concludes that the potential direct, indirect, and cumulative environmental impacts from Hermes 2 would not be significant and has determined that a draft Finding of No Significant Impact appears warranted.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.) 13. AVAILABILITY STATEMENT Kairos Hermes 2 Test Reactors unlimited Kairos Power Hermes 2 Non-Power Test Reactor 14. SECURITY CLASSIFICATION Draft Environmental Assessment (This Page)

National Environmental Policy Act, NEPA unclassified

(This Report) unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (12-2010)

ML24103A002 Environmental Assessment and Finding of No Significant Impact for the Construction April 2024 Permits for the Kairos Hermes 2 Test Reactors Draft Report for Comment