ML25217A544
| ML25217A544 | |
| Person / Time | |
|---|---|
| Site: | Kemmerer File:TerraPower icon.png |
| Issue date: | 08/04/2025 |
| From: | Tilson D The Breakthrough Institue |
| To: | Office of Administration |
| References | |
| NRC-2024-0078, 90FR26333 00002 | |
| Download: ML25217A544 (1) | |
Text
PUBLIC SUBMISSION As of: 8/5/25, 3:13 PM Received: August 04, 2025 Status: Pending_Post Tracking No. mdx-iofg-ii1g Comments Due: August 04, 2025 Submission Type: API Docket: NRC-2024-0078 US SFR Owner, LLC; Construction Permit Application Comment On: NRC-2024-0078-0044 US SFR Owner, LLC; Kemmerer Power Station, Unit 1; Draft Environmental Impact Statement Document: NRC-2024-0078-DRAFT-0039 Comment on FR Doc # 2025-11307 Submitter Information Email:deric@thebreakthrough.org Organization:Breakthrough Institute General Comment See attached file:
BTI Comments on Kemmerer Unit 1 Draft EIS - Docket ID NRC-2024-0078.pdf Attachments BTI Comments on Kemmerer Unit 1 Draft EIS - Docket ID NRC-2024-0078 8/5/25, 3:13 PM NRC-2024-0078-DRAFT-0039.html file:///C:/Users/BHB1/Downloads/NRC-2024-0078-DRAFT-0039.html 1/1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Patricia Vokoun, Mary Neely Comment (4)
Publication Date:
6/20/2025 Citation: 90 FR 26333
August 4, 2025
Subject:
US SFR Owner, LLC (USO); Kemmerer Power Station, Unit 1; Draft Environmental Impact Statement; [Docket ID NRC-2024-0078].
The Breakthrough Institute (BTI) appreciates this opportunity to comment on the scope of environmental review for Kemmerer Power Station Unit 1 and express our support for the staffs recommendation to issue a Construction Permit (CP) following the issuance of the draft Environmental Impact Statement (EIS). BTI is an independent 501(c)(3) global research center that advocates for appropriate regulation and oversight of nuclear reactors to enable the new and continued use of safe and clean nuclear energy. BTI acts in the public interest and does not receive funding from industry.
PRIOR ENVIRONMENTAL ASSESSMENTS There have been three Environmental Assessments (EAs) performed at the Kemmerer Unit 1 site.
The first was done by the DOE regarding the Test and Fill Facility and was completed in May 2024 (DOE 2024-TN11200). The DOE then reached a Finding of No Significant Impact (FONSI) for preconstruction activities in February 2025 (DOE 2025-TN11602). Preconstruction activities reviewed by DOE under the related EA did not include any radioactive material or nuclear-safety-related systems, and all structures were classified as non-safety related.
In February 2025, Terrapower requested an exemption to commence construction of structural components for Kemmerer 1, normally prohibited without an NRC license. These rules apply to production and utilization facilities, relying on a small definitional change. This exemption would allow the driving of piles, subsurface preparation, placement of backfill, concrete, or permanent retaining walls within an excavation, installation of foundations, or in-place assembly, erection, fabrication or testing, which are for structures, systems, and components (SSCs) classified as non-safety-related with no special treatment (NST) the failure of which could cause a reactor scram or actuation of a safety-related system that are located on the proposed Kemmerer 1 energy island prior to receipt of a construction permit (CP) and without a limited work authorization.
The NRC filed an EA with a subsequent FONSI in response to Terrapowers request.1 The three EAs and FONSIs are evidence in favor of the small environmental impact that Kemmerer Unit 1 will have on the local environment. The EIS furthers this implication in its assessment.
ENVIRONMENTAL IMPACTS The EIS looks at twelve categories of potential environmental impacts and assigns each resource area an impact level of small, moderate, or large. These levels are defined as such:
Small: Environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource. For the purposes of assessing radiological impacts, the NRC has concluded that those impacts that do not exceed permissible levels in the NRCs regulations are considered small.
Moderate: Environmental effects are sufficient to noticeably alter important attributes of the resource but not to destabilize them.
Large: Environmental effects are clearly noticeable and are sufficient to destabilize important attributes of the resource.
Of the twelve environmental impacts described in the EIS, the CP has been determined to have an impact level of small on nine of the categories.
Three resource areas had impacts greater than small. One resource area, terrestrial ecological resources, would have a moderate impact with 118 acres being permanently disturbed; however, there would be no effects to resources protected under the Endangered Species Act. The terrain disturbed by the site is not unique, and the disturbance on the greater habitat would be relatively small.
Two resource areas were identified as having moderate to large impacts: 1) Historic and cultural, and 2) Socioeconomic. For historic and cultural resources, the impact could be reduced to MODERATE if USO is able to avoid adverse effects to the two historic properties, or if the adverse effects are resolved through the execution of a memorandum of agreement. The socioeconomic impacts result from there being a shortage of construction workers and specialized labor in the 1 US SFR Owner, LLC.; Kemmerer Power Station, Unit 1; Environmental Assessment and Finding of No Significant Impact https://www.federalregister.gov/documents/2025/05/07/2025-07960/
us-sfr-owner-llc-kemmerer-power-station-unit-1-environmental-assessment-and-finding-of-no
area; thus, additional housing would have to be provided, or mobile dwellings would need to be transported to the area. There would be additional impacts due to increased traffic and the increased use of public services. After peak construction, these impacts would be somewhat offset by new tax revenue. The report does not consider the socioeconomic impacts during longer time horizons, which would further mitigate the short-term effects of a sudden influx of workers.
NO-ACTION ALTERNATIVES AND ALTERNATIVE SITES The Draft EIS, in line with the amendments to NEPA required by the Fiscal Responsibility Act (2023), considers the no-action alternative along with site alternatives. If Kemmerer Unit 1 were not to move forward, the need for energy would still exist per PacifiCorps Integrated Resource Plan, discussed in Chapter 5 of the draft EIS. Such energy needs would have to be remediated through the continued operation of the Naughton Power Plant or the development of new generation elsewhere. The NRC correctly identifies that continued operation of the Naughton Power Plant or the construction of a different generating asset could have impacts that are substantial and greater than those of allowing the construction and operation of Kemmerer Unit 1.
The EIS also looks at alternate sites and finds that constructing and operating Kemmerer Unit 1 at the Naughton 12 site, Jim Bridger 22 site, or the currently proposed site would accrue benefits that would outweigh the economic, environmental, and social costs. The review team did not identify either of the proposed alternative sites as being preferable, nor did they find the no-action alternative preferable. Thus, the construction and operation of Kemmerer Unit 1 at its currently proposed site is the best step forward given the impacts and alternatives.
CONCLUSION The Breakthrough Institute supports the NRC staffs recommendation to issue a construction permit to USO. Issuance would allow both Terrapower and its subsidiary (USO) to build Kemmerer Unit 1 and replace electric capacity in the PacifiCorp service area. Kemmerer Unit 1 will replace the generation lost from the retirement of coal plants, reducing greenhouse gas emissions and other pollutants concurrently.
The issuance of a CP followed by the construction and operation of Kemmerer Unit 1 is in line with the principles of good regulation, and using nuclear to replace coal and fossil fuel electricity generation maximizes the public welfare. The NRC staff performed their due diligence in
seriously considering the no-action alternative and siting alternative. BTI commends the NRC staff for their continued efforts to enable nuclear power for the public benefit.
Sincerely, Deric Tilson, PhD Senior Nuclear Analyst The Breakthrough Institute