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==SUMMARY==
==SUMMARY==
REPORT ON THE ENVIRONMENTAL AUDIT OF KAIROS HERMES TEST REACTOR CONSTRUCTION PERMIT APPLICATION 1.0      Background The U.S. Nuclear Regulatory Commission (NRC) is currently reviewing an application from Kairos Power, LLC (Kairos) for a construction permit (CP) for a test reactor to be located in Oak Ridge, Tennessee. As part of its review, the NRC is preparing an Environmental Impact Statement (EIS). An audit was conducted from February 28, 2022, to March 30, 2022, to support the environmental review of Kairos CP application. This report presents a summary of the audits objectives and activities, and information that was obtained as a result of audit activities.
REPORT ON THE ENVIRONMENTAL AUDIT OF KAIROS HERMES TEST REACTOR CONSTRUCTION PERMIT APPLICATION
1.1 Application Overview By {{letter dated|date=October 31, 2021|text=letter dated October 31, 2021}} (Agencywide Documents Access and Management System (ADAMS) ML21306A131), Kairos submitted an Environmental Report (ER) in support of its Hermes CP application. By letters dated February 10, February 18, and March 1, 2022, Kairos provided supplemental information regarding its CP application, including the ER (ML22042A095, ML22049B555, and ML22060A272). References to the Kairos ER in this summary report include these revisions.
1.2 Project and Site Overview The proposed action is for the NRC to issue a CP to Kairos authorizing construction of the Hermes reactor. In its CP application, Kairos proposes to build and operate the Hermes project to demonstrate key elements of the Kairos Power Fluoride Salt-Cooled, High Temperature Reactor technology for possible future commercial deployment. Operation of the Hermes reactor would not generate any power for sale or distribution. The technology is an advanced nuclear reactor technology that leverages TRI-structural ISOtropic (TRISO) particle fuel in pebble form combined with a low-pressure fluoride salt coolant. The proposed site is situated in the Heritage Center of the East Tennessee Technology Park, an industrial park established by the City of Oak Ridge, on land formerly owned by the U.S. Department of Energy (DOE) for the Oak Ridge Gaseous Diffusion Plant. The Kairos Hermes ER provides Kairos analyses of the environmental impacts that could result from building, operating, and decommissioning the Hermes test reactor at the proposed site.
2.0      Audit Scope and Objectives During the audit, the staff discussed environmental matters related to land use, ground and surface water, terrestrial and aquatic ecology, human health, postulated accidents, radiological and non-radiological waste, cultural resources, fuel cycle, transportation of radioactive material, alternatives to the proposed action, air quality and noise. The audit allowed the staff to better understand the site, environmental interfaces of the project, and modeling results in order to make appropriate environmental findings.
In its initial review of data and information within the corresponding context of the ER, the staff identified information needs that would promote a better understanding of the detailed analysis and bases underlying the construction permit application. These items were included in


Attachment 1 of the audit plan presented to Kairos in advance (ML22056A064). Audit activities consisted of document reviews, virtual meetings organized in advance and a few impromptu discussions as documented herein. These activities assisted the NRC and Kairos staff in resolving the information needs that were outlined in the plan. For items that the staff was not able to resolve through document reviews and audit discussions, Kairos submitted information to the Kairos Hermes docket, supplementing its CP application to provide the necessary information for the staff to make impact determinations in the EIS.
1.0 Background
Table 1 of this report presents a list of the NRC staff participating in the audit and their associated EIS review areas. Table 2 presents a list of Kairos staff and its contractors who participated in the audit.
Table 1. Review Areas with assigned team members Team Member Team Member                Role / Review Area Ken Erwin                  Environmental Review Supervisor Tami Dozier                Environmental Project Manager Peyton Doub                Technical Lead for the EIS; Site and Technical Overview / Proposed Action
                          / Land Use and Visual Resources; Ecological Resources / Non-Radiological Human Health; Noise; Alternatives Don Palmrose              Radiological Human Health; Transportation of Radioactive Materials; Fuel Cycle and Radiological Waste Management; Postulated Accidents Jennifer Davis            Historic and Cultural Resources Joseph Giacinto            Water Resources and Hydrogeology; Climate Change Laura Willingham          Air Quality Daniel Mussatti            Socioeconomics; Environmental Justice; Non-radiological Waste Management; Cost-Benefit Discussion Kevin Folk                Adjunct Team Member Table 2. List of Audit Participants for Kairos Power, LLC and AECOM Kairos Power, LLC                                    AECOM Katie Dignan                                          Kevin Taylor Darrell Gardner                                      Carol Freeman Marty Bryan                                          Carlos Szembek Austin Clark                                          Bob Paine Wayne Massie                                          Evelyn Rogers Brian Song                                            Kristen Beckhorn Antonio Fernandez                                    Fang Wang Lori Gross                                            Delia Halliman Per Peterson                                          Jim Orr Gus Merwin                                            Steve Dillard Kieran Dolan                                          Larry Neal Matt Denman                                          Anneliesa Barta Peiwen Whysall Alan Kruizenga Jim Tompkins Ryan Latta Jianxin Liu Jordan Hagaman 2


3.0      Summary of Audit Activities and Issues Addressed During the first week of the audit, an audit kickoff meeting and 15 breakout sessions were conducted virtually where the NRC and Kairos staff discussed the 78 information needs that had been provided to Kairos in the audit plan. For the remaining period of the audit, the staff continued to examine supporting documents and hold follow up discussions as needed. The staff determined that responses to several items would be needed on the docket and Kairos agreed to provide that information in supplemental submittals or as responses to Requests for Confirmatory Information (RCIs).
The U.S. Nuclear Regulatory Commission (NRC) is currently revie wing an application from Kairos Power, LLC (Kairos) for a construction permit (CP) for a test reactor to be located in Oak Ridge, Tennessee. As part of its review, the NRC is preparing a n Environmental Impact Statement (EIS). An audit was conducted from February 28, 2022, to March 30, 2022, to support the environmental review of Kairos CP application. Thi s report presents a summary of the audits objectives and activities, and information that was obtained as a result of audit activities.
In order to appropriately document the staffs confirmation of information gathered during the audit which would not otherwise be available in the public domain, the staff prepared and issued to Kairos a set of 22 RCIs (ML22090A060). Kairos provided all agreed upon supplemental information requested by the staff within 30 days of audit closure.
Table 3 presents a tabulated summary of how the information needs presented to Kairos in the audit plan were addressed. In summary, 52 of the 78 audit items were closed through audit discussions and staff review of supporting material. Five items required information to be provided by Kairos in supplemental submittals. Twenty-one items were resolved through Kairos response to RCIs (1 audit item required two separate RCIs, resulting in Kairos responding to 22 separate RCIs.)
4.0      Audit Closeout Meeting The NRC staff conducted a publicly noticed audit closeout meeting on March 30, 2022 (ML22088A212). At the closeout meeting the NRC staff reiterated the purpose of the audit, discussed the audit activities and the information still needed to close all audit items. Kairos shared their expected timeframe for providing the agreed upon submittals expected to close the remaining items. Conditional upon review of the information Kairos would be providing, the NRC staff stated that they did not anticipate the need for any additional information in order to complete their review; however, the staff stressed that the scoping comment period was still underway and should new information be received from the scoping process or from other means, additional information from Kairos could become necessary. The meeting presentation is available at ML22088A225.
Members of the public were provided an opportunity to comment during the meeting. Attendees asked questions related to the RCI process and other audit activities. Attendees expressed interest in the anticipated date for review deliverables. Table 4 presents the attendance list.
5.0      Post Audit Followup and Current Review Status As summarized in Table 3, Kairos provided supplemental information to respond to RCIs and to close out those audit information needs requiring that particular information be submitted to the docket. By {{letter dated|date=April 22, 2022|text=letter dated April 22, 2022}}, Kairos provided their response to the staffs RCIs (ML2215A204). On April 27, 2022, Kairos provided two submissions to address certain air quality, noise and water resource items requiring information on the docket (ML22117A215 and ML22117A218). The staff determined all information provided by Kairos to adequately close all information needed from the applicant to conduct their review.
The scoping comment period closed on April 19, 2022, and staff has completed its review of the public comments. To date, the staff has not identified any new information requiring additional 3


requests for information from Kairos. The draft EIS is currently on schedule to be issued on or before November 2022.
1.1 Application Overview
Table 3: Summary of Audit Information Need Resolution Info Need ID                        Information Need                        Resolution Site and Technical Overview Briefly outline the ownership history of the site, Closed Through STO-1            and indicate what if any easements or Audit Discussion encumbrances exist on the site property Show estimated, approximate routes for any new utilities that would be constructed, such as sewer lines and incoming electric distribution lines. Note Closed Through STO-2            that section 6.2.1 states that construction would Audit Discussion include "the installation of water and sewer lines that connect the facility to the City of Oak Ridge water supply system."
Cumulative Impacts Closed Through Please provide rough bounding information on        Request for CMLT-1           the location and land and water needs for the        Confirmatory Fuel Fabrication Facility.                          Information (RCI #18)
ML22115A204 Please provide a bounding estimate on the years      Closed Through CMLT-2 of operation of the Fuel Fabrication Facility.      Audit Discussion Land Use and Visual Resources The ER does not provide information on the zoning of the site. Indicate the zoning established  Closed Through by the City of Oak Ridge for the site. The City      Request for LU-1              zoning map indicates IND-2, but the zoning          Confirmatory ordinance indicates that industrial facilities      Information (RCI #1) handling radioactive materials require IND-3        ML22115A204 zoning. Clarification needed.
Figure 3.7-3 on page 3-145 shows an undeveloped right-of-way-like extension of the site proceeding southwest from the site to the      Closed Through LU-2                                                                  Audit Discussion Clinch River arm of Watts Bar Reservoir. This extension of the site does not appear on other site maps. Clarification needed.
Demonstrate that the proposed facilities would      Closed Through LU-3                                                                  Request for not penetrate the air spaces identified as having 4


Info Need ID                      Information Need                      Resolution to be free of flight obstructions for the proposed  Confirmatory City of Oak Ridge Airport to the south.            Information (RCI #2)
By {{letter dated|date=October 31, 2021|text=letter dated October 31, 2021}} (Agencywide Documents Access a nd Management System (ADAMS) ML21306A131), Kairos submitted an Environmental Report (ER) in support of its Hermes CP application. By letters dated February 10, February 1 8, and March 1, 2022, Kairos provided supplemental information regarding its CP application, including the ER (ML22042A095, ML22049B555, and ML22060A272). References to the Kairos ER in this summary report include these revisions.
ML22115A204 Page 3-77, figure 3.4-2: Should 2 percent Annual    Closed Through LU-4            Chance Flood Hazard be 0.2 % percent Annual        Audit Discussion Chance Flood Hazard?
Air Quality and Noise Section 3.2.6, p.3-20 states that the nearest      Closed Through Post resident is approximately 0.7 mi north of the site; Audit Submittal by AQN-1                                                                Kairos but section 4.2.2, p. 4-18 states that the nearest residence is 1.25 mi away. Clarification needed.    (ML22117A218)
Provide additional details as to how the noise      Closed Through Post attenuation data in table 4.2-3 were calculated. Audit Submittal by AQN-2                                                                Kairos Did the calculations assume leaf-on or leaf-off conditions?                                        (ML22117A218)
Provide air emission estimates for each criteria pollutant for the construction phase and the operation phase of the project. Provide a Closed Through Post description of the assumptions used to determine Audit Submittal by AQN-3            the estimates (i.e., hours use of differing Kairos equipment during construction). In addition, (ML22117A218) provide the total emission estimate for hazardous air pollutants for both the construction and operation phases of the project.
Water Resources and Hydrogeology As no offsite disposal is planned, please describe any change in the site grade, drainage, or topography as a result of the onsite use of        Closed Through excess excavated soil that would have formerly      Request for occupied the space of subgrade building            Confirmatory HYD-01          structures and foundations, measures or best        Information (RCI #3) practices to account for the potential exposure to  ML22115A204 contaminated soils and any anticipated coordination with DOE for soil excavation activities.
In section 4.13.3, the ER indicates that "Table 4.13-1 identifies recent past, present, and reasonably foreseeable future actions within the    Closed Through Post geographic extent of analysis that can be          Audit Submittal by HYD-02          assessed to determine cumulative effects on the     Kairos geologic environment." Yet, the geologic            (ML22117A218) environment is not listed as a "Potentially Affected Resource(s)" in this table. Please 5


Info Need ID                   Information Need                           Resolution explain how the Geologic Environment in section 4.13.3 was evaluated for recent, past, present and reasonably foreseeable future actions, including anticipated fuel fabrication facility that is planned to be built adjacent to the reactor given the lack of mention the Geologic Environment in table 4.13-1.
1.2 Project and Site Overview
Clarify the apparent variability of subsurface stratigraphy between ER section 3.3.3.1, ER figure 3.3-3 and PSAR figure 2.5-3 in the area         Closed Through HYD-03       crossing the former K-33 site with respect to the       Audit Discussion clay profile, associated depths to bottom of clay and the position the Oma (Mascot Dolomite) stratigraphy.
 
Please define and clarify any implications of the "TVA Flowage Easements" shown in figure 3.4-2           Closed Through HYD-04                                                              Audit Discussion adjacent to the reactor facility to anticipated land use, hydrological resources, and development.
The proposed action is for the NRC to issue a CP to Kairos auth orizing construction of the Hermes reactor. In its CP application, Kairos proposes to build and operate the Hermes project to demonstrate key elements of the Kairos Power Fluoride Salt-C ooled, High Temperature Reactor technology for possible future commercial deployment. O peration of the Hermes reactor would not generate any power for sale or distribution. The technology is an advanced nuclear reactor technology that leverages TRI-structural ISOtro pic (TRISO) particle fuel in pebble form combined with a low-pressure fluoride salt coolant. The proposed site is situated in the Heritage Center of the East Tennessee Technology Park, an i ndustrial park established by the City of Oak Ridge, on land formerly owned by the U.S. Depar tment of Energy (DOE) for the Oak Ridge Gaseous Diffusion Plant. The Kairos Hermes ER provide s Kairos analyses of the environmental impacts that could result from building, operatin g, and decommissioning the Hermes test reactor at the proposed site.
Please explain what is meant by the "...final           Closed Through HYD-05       decision on the K-31/K-33 Area groundwater..."         Audit Discussion as described in section 3.4.1.2.
 
Section 3.5.5.3 indicates that the K-901 Holding       Closed Through HYD-06       Pond is shown in figure 2.2-1; however, there is       Audit Discussion no pond labeled as the K901 Holding Pond.
2.0 Audit Scope and Objectives
 
During the audit, the staff discussed environmental matters rel ated to land use, ground and surface water, terrestrial and aquatic ecology, human health, p ostulated accidents, radiological and non-radiological waste, cultural resources, fuel cycle, tra nsportation of radioactive material, alternatives to the proposed action, air quality and noise. The audit allowed the staff to better understand the site, environmental interfaces of the project, a nd modeling results in order to make appropriate environmental findings.
 
In its initial review of data and information within the corres ponding context of the ER, the staff identified information needs that would promote a better unders tanding of the detailed analysis and bases underlying the construction permit application. These items were included in Attachment 1 of the audit plan presented to Kairos in advance ( ML22056A064). Audit activities consisted of document reviews, virtual meetings organized in ad vance and a few impromptu discussions as documented herein. These activities assisted the NRC and Kairos staff in resolving the information needs that were outlined in the plan. For items that the staff was not able to resolve through document reviews and audit discussions, Kairos submitted information to the Kairos Hermes docket, supplementing its CP application t o provide the necessary information for the staff to make impact determinations in the EIS.
 
Table 1 of this report presents a list of the NRC staff partici pating in the audit and their associated EIS review areas. Table 2 presents a list of Kairos staff and its contractors who participated in the audit.
 
Table 1. Review Areas with assigned team members Team Member
 
Team Member Role / Review Area Ken Erwin Environmental Review Supervisor Tami Dozier Environmental Project Manager Peyton Doub Technical Lead for the EIS; Site and Technical Overview / Proposed Action
/ Land Use and Visual Resources; Ecological Resources / Non-Radiological Human Health; Noise; Alternatives Don Palmrose Radiological Human Health; Transportation of Radioactive Materials; Fuel Cycle and Radiological Waste Management; Postulated Accidents Jennifer Davis Historic and Cultural Resources Joseph Giacinto Water Resources and Hydrogeology; Climate Change Laura Willingham Air Quality Daniel Mussatti Socioeconomics; Environmental Justice; Non-radiological Waste Management; Cost-Benefit Discussion Kevin Folk Adjunct Team Member
 
Table 2. List of Audit Participants for Kairos Power, LLC and A ECOM
 
Kairos Power, LLC AECOM Katie Dignan Kevin Taylor Darrell Gardner Carol Freeman Marty Bryan Carlos Szembek Austin Clark Bob Paine Wayne Massie Evelyn Rogers Brian Song Kristen Beckhorn Antonio Fernandez Fang Wang Lori Gross Delia Halliman Per Peterson Jim Orr Gus Merwin Steve Dillard Kieran Dolan Larry Neal Matt Denman Anneliesa Barta Peiwen Whysall Alan Kruizenga Jim Tompkins Ryan Latta Jianxin Liu Jordan Hagaman
 
2 3.0 Summary of Audit Activities and Issues Addressed
 
During the first week of the audit, an audit kickoff meeting an d 15 breakout sessions were conducted virtually where the NRC and Kairos staff discussed th e 78 information needs that had been provided to Kairos in the audit plan. For the remaining pe riod of the audit, the staff continued to examine supporting documents and hold follow up di scussions as needed. The staff determined that responses to several items would be neede d on the docket and Kairos agreed to provide that information in supplemental submittals o r as responses to Requests for Confirmatory Information (RCIs).
 
In order to appropriately document the staffs confirmation of information gathered during the audit which would not otherwise be available in the public doma in, the staff prepared and issued to Kairos a set of 22 RCIs (ML22090A060). Kairos provided all a greed upon supplemental information requested by the staff within 30 days of audit clos ure.
 
Table 3 presents a tabulated summary of how the information nee ds presented to Kairos in the audit plan were addressed. In summary, 52 of the 78 audit items were closed through audit discussions and staff review of supporting material. Five items required information to be provided by Kairos in supplement al submittals. Twenty-one items were resolved through Kairos response to RCIs (1 audit item required two separate RCIs, resu lting in Kairos responding to 22 separate RCIs.)
 
4.0 Audit Closeout Meeting
 
The NRC staff conducted a publicly noticed audit closeout meeti ng on March 30, 2022 (ML22088A212). At the closeout meeting the NRC staff reiterated the purpose of the audit, discussed the audit activities and the information still needed to close all audit items. Kairos shared their expected timeframe for providing the agreed upon s ubmittals expected to close the remaining items. Conditional upon review of the information Kai ros would be providing, the NRC staff stated that they did not anticipate the need for any addi tional information in order to complete their review; however, the staff stressed that the sco ping comment period was still underway and should new information be received from the scopin g process or from other means, additional information from Kairos could become necessar y. The meeting presentation is available at ML22088A225.
 
Members of the public were provided an opportunity to comment d uring the meeting. Attendees asked questions related to the RCI process and other audit acti vities. Attendees expressed interest in the anticipated date for review deliverables. Table 4 presents the attendance list.
 
5.0 Post Audit Followup and Current Review Status
 
As summarized in Table 3, Kairos provided supplemental informat ion to respond to RCIs and to close out those audit information needs requiring that particul ar information be submitted to the docket. By {{letter dated|date=April 22, 2022|text=letter dated April 22, 2022}}, Kairos provided their r esponse to the staffs RCIs (ML2215A204). On April 27, 2022, Kairos provided two submission s to address certain air quality, noise and water resource items requiring information o n the docket (ML22117A215 and ML22117A218). The staff determined all information provided by Kairos to adequately close all information needed from the applicant to conduct their review.
 
The scoping comment period closed on April 19, 2022, and staff has completed its review of the public comments. To date, the staff has not identified any new information requiring additional
 
3 requests for information from Kairos. The draft EIS is currentl y on schedule to be issued on or before November 2022.
 
Table 3: Summary of Audit Information Need Resolution
 
Info Need ID Information Need Resolution
 
Site and Technical Overview Briefly outline the ownership history of the site, Closed Through STO-1 and indicate what if any easements or Audit Discussion encumbrances exist on the site property Show estimated, approximate routes for any new utilities that would be constructed, such as sewer lines and incoming electric distribution lines. Note Closed Through STO-2 that section 6.2.1 states that construction would Audit Discussion include "the installation of water and sewer lines that connect the facility to the City of Oak Ridge water supply system."
 
Cumulative Impacts Closed Through Please provide rough bounding information on Request for CMLT-1 the location and land and water needs for the Confirmatory Fuel Fabrication Facility. Information (RCI #18)
ML22115A204 CMLT-2 Please provide a bounding estimate on the years Closed Through of operation of the Fuel Fabrication Facility. Audit Discussion
 
Land Use and Visual Resources
 
The ER does not provide information on the zoning of the site. Indicate the zoning established Closed Through by the City of Oak Ridge for the site. The City Request for LU-1 zoning map indicates IND-2, but the zoning Confirmatory ordinance indicates that industrial facilities Information (RCI #1) handling radioactive materials require IND-3 ML22115A204 zoning. Clarification needed.
Figure 3.7-3 on page 3-145 shows an undeveloped right-of-way-like extension of the LU-2 site proceeding southwest from the site to the Closed Through Clinch River arm of Watts Bar Reservoir. This Audit Discussion extension of the site does not appear on other site maps. Clarification needed.
LU-3 Demonstrate that the proposed facilities would Closed Through not penetrate the air spaces identified as having Request for
 
4 Info Need ID Information Need Resolution
 
to be free of flight obstructions for the proposed Confirmatory City of Oak Ridge Airport to the south. Information (RCI #2)
ML22115A204 Page 3-77, figure 3.4-2: Should 2 percent Annual Closed Through LU-4 Chance Flood Hazard be 0.2 % percent Annual Audit Discussion Chance Flood Hazard?
 
Air Quality and Noise Section 3.2.6, p.3-20 states that the nearest Closed Through Post AQN-1 resident is approximately 0.7 mi north of the site; Audit Submittal by but section 4.2.2, p. 4-18 states that the nearest Kairos residence is 1.25 mi away. Clarification needed. (ML22117A218)
Provide additional details as to how the noise Closed Through Post AQN-2 attenuation data in table 4.2-3 were calculated. Audit Submittal by Did the calculations assume leaf-on or leaf-off Kairos conditions? (ML22117A218)
Provide air emission estimates for each criteria pollutant for the construction phase and the operation phase of the project. Provide a Closed Through Post description of the assumptions used to determine Audit Submittal by AQN-3 the estimates (i.e., hours use of differing Kairos equipment during construction). In addition, (ML22117A218) provide the total emission estimate for hazardous air pollutants for both the construction and operation phases of the project.
 
Water Resources and Hydrogeology As no offsite disposal is planned, please describe any change in the site grade, drainage, or topography as a result of the onsite use of Closed Through excess excavated soil that would have formerly Request for occupied the space of subgrade building Confirmatory HYD-01 structures and foundations, measures or best Information (RCI #3) practices to account for the potential exposure to ML22115A204 contaminated soils and any anticipated coordination with DOE for soil excavation activities.
In section 4.13.3, the ER indicates that "Table 4.13-1 identifies recent past, present, and reasonably foreseeable future actions within the Closed Through Post geographic extent of analysis that can be Audit Submittal by HYD-02 assessed to determine cumulative effects on the Kairos geologic environment." Yet, the geologic (ML22117A218) environment is not listed as a "Potentially Affected Resource(s)" in this table. Please
 
5 Info Need ID Information Need Resolution
 
explain how the Geologic Environment in section 4.13.3 was evaluated for recent, past, present and reasonably foreseeable future actions, including anticipated fuel fabrication facility that is planned to be built adjacent to the reactor given the lack of mention the Geologic Environment in table 4.13-1.
Clarify the apparent variability of subsurface stratigraphy between ER section 3.3.3.1, ER figure 3.3-3 and PSAR figure 2.5-3 in the area Closed Through HYD-03 crossing the former K-33 site with respect to the Audit Discussion clay profile, associated depths to bottom of clay and the position the Oma (Mascot Dolomite) stratigraphy.
Please define and clarify any implications of the HYD-04 "TVA Flowage Easements" shown in figure 3.4-2 Closed Through adjacent to the reactor facility to anticipated land Audit Discussion use, hydrological resources, and development.
Please explain what is meant by the "...final Closed Through HYD-05 decision on the K-31/K-33 Area groundwater..." Audit Discussion as described in section 3.4.1.2.
Section 3.5.5.3 indicates that the K-901 Holding Closed Through HYD-06 Pond is shown in figure 2.2-1; however, there is Audit Discussion no pond labeled as the K901 Holding Pond.
In section 3.7.2.5, please clarify what constitutes "wet weather" and the frequency of these periods when Rarity Ridge WWTP operates at peak capacity and explain the ability of the Rarity Ridge WWTP to treat the estimated 0.02 MGD of facility wastewater during these periods and any associated potential indirect or direct impacts.
In section 3.7.2.5, please clarify what constitutes "wet weather" and the frequency of these periods when Rarity Ridge WWTP operates at peak capacity and explain the ability of the Rarity Ridge WWTP to treat the estimated 0.02 MGD of facility wastewater during these periods and any associated potential indirect or direct impacts.
Also, please provide a reference for the               Closed Through HYD-07       statement "...the plant is under evaluation for         Audit Discussion future growth." and, in section 5.2, a reference for what measures that the city is currently working towards reducing inflow and infiltration coming into the plant." Describe any agreements with Rarity Ridge WWTP for accepting wastewater from the planned facility with respect to anticipated construction and operation dates of the proposed Kairos facility.
Also, please provide a reference for the Closed Through HYD-07 statement "...the plant is under evaluation for Audit Discussion future growth." and, in section 5.2, a reference for what measures that the city is currently working towards reducing inflow and infiltration coming into the plant." Describe any agreements with Rarity Ridge WWTP for accepting wastewater from the planned facility with respect to anticipated construction and operation dates of the proposed Kairos facility.
Clarify if the estimated facility water use is "44 gpm (0.06 MGD)" as described in ER section             Closed Through HYD-08                                                              Audit Discussion 3.4.2.3 or "0.07 million gallons per day" as described in ER section 4.4.2.
Clarify if the estimated facility water use is "44 HYD-08 gpm (0.06 MGD)" as described in ER section Closed Through 3.4.2.3 or "0.07 million gallons per day" as Audit Discussion described in ER section 4.4.2.
6


Info Need ID                   Information Need                       Resolution Describe the potential for new underground (wastewater, utility lines, etc.) utilities to act as Closed Through HYD-09       groundwater sinks or sources as described in ER       Audit Discussion section 3.4.1.2 and any anticipated monitoring plan provisions.
6 Info Need ID Information Need Resolution
Based on the discussion in ER section 3.4.2.3, please clarify the intended source of Fire Suppression System's water supply for infrequent use (3,170 gpm/4.56 MGD) including the make-up supply (793 gpm/1.14 MDG) and the                 Closed Through approximate periods between refills with respect     Request for HYD-10       to the capacity of the municipal system. Please       Confirmatory confirm that the fire protection system (ER           Information (RCI #4) section 2.4.1) and the fire suppression system       ML22115A204 (ER section 3.4.2.3) are one in the same and clarify any discrepancies between the slightly different refill rates listed in section 2.4.1 and section 3.4.2.3.
 
As described in ER section 3.4.1.2.1, "Historically, building basement dewatering significantly altered the mapped potentiometric surface in the areas of the ETTP." and related to dewatering discussion in ER section 4.3.2 and         Closed Through section 4.5.1.2, provide an approximate bounding     Request for estimate of dewatering rates during the duration     Confirmatory HYD-11 of construction, plant operation and                 Information (RCI #5) decommissioning. If dewatering is planned,           ML22115A204 please describe the anticipating dispositioning of the any water volumes including any anticipated DOE consultations to manage the water and, anticipated alterations to the groundwater flow field due to dewatering during operations.
Describe the potential for new underground (wastewater, utility lines, etc.) utilities to act as Closed Through HYD-09 groundwater sinks or sources as described in ER Audit Discussion section 3.4.1.2 and any anticipated monitoring plan provisions.
Based on the discussion in ER section 3.4.2.3, please clarify the intended source of Fire Suppression System's water supply for infrequent use (3,170 gpm/4.56 MGD) including the make-up supply (793 gpm/1.14 MDG) and the Closed Through approximate periods between refills with respect Request for HYD-10 to the capacity of the municipal system. Please Confirmatory confirm that the fire protection system (ER Information (RCI #4) section 2.4.1) and the fire suppression system ML22115A204 (ER section 3.4.2.3) are one in the same and clarify any discrepancies between the slightly different refill rates listed in section 2.4.1 and section 3.4.2.3.
As described in ER section 3.4.1.2.1, "Historically, building basement dewatering significantly altered the mapped potentiometric surface in the areas of the ETTP." and related to dewatering discussion in ER section 4.3.2 and Closed Through section 4.5.1.2, provide an approximate bounding Request for HYD-11 estimate of dewatering rates during the duration Confirmatory of construction, plant operation and Information (RCI #5) decommissioning. If dewatering is planned, ML22115A204 please describe the anticipating dispositioning of the any water volumes including any anticipated DOE consultations to manage the water and, anticipated alterations to the groundwater flow field due to dewatering during operations.
Section 4.8.1.7 states that specific environmental monitoring of non-radiological constituents would be determined through the permitting process.
Section 4.8.1.7 states that specific environmental monitoring of non-radiological constituents would be determined through the permitting process.
Section 4.4.4 indicates that"..., no non-             Closed Through radiological groundwater monitoring activities are   Request for planned for the site." Please clarify permitting     Confirmatory HYD-12 requirements for monitoring non-radiological         Information (RCI #6) constituents and any apparent inconsistencies         ML22115A204 between the statements in section 4.8.1.7 and section 4.4.4 and the disposition of DOE's continuing monitoring program for the K-31/K-33 area.
Section 4.4.4 indicates that"..., no non-Closed Through radiological groundwater monitoring activities are Request for HYD-12 planned for the site." Please clarify permitting Confirmatory requirements for monitoring non-radiological Information (RCI #6) constituents and any apparent inconsistencies ML22115A204 between the statements in section 4.8.1.7 and section 4.4.4 and the disposition of DOE's continuing monitoring program for the K-31/K-33 area.
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Info Need ID                     Information Need                         Resolution Ecological Resources Page 1-3 of ER states that an onsite field delineation of wetlands and other waters of the United States was conducted on the site. But the       Closed Through ECO-1                                                                  Audit Discussion information presented in section 3.5.6 is referenced to a 1994 DOE study. Clarification needed.
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Indicate the references(s) for the unreferenced       Closed Through ECO-2           descriptive information in sections 3.5.7.1 and       Audit Discussion 3.5.7.2.
 
Page 3-92, section 3.5.7.2.2 (Birds) states that a field survey was conducted of the site in June         Closed Through ECO-3                                                                  Audit Discussion 2021. Provide a brief explanation of the procedures and observations of that survey.
Ecological Resources
Page 3-92, section 3.5.7.2.2 (Birds) states that a field survey was conducted of the site in June         Closed Through ECO-4           2021. Also, table 1.4-2 states that a field survey     Audit Discussion identified no eagle nests in the vicinity of the site.
 
Page 1-3 of ER states that an onsite field delineation of wetlands and other waters of the ECO-1 United States was conducted on the site. But the Closed Through information presented in section 3.5.6 is Audit Discussion referenced to a 1994 DOE study. Clarification needed.
Indicate the references(s) for the unreferenced Closed Through ECO-2 descriptive information in sections 3.5.7.1 and Audit Discussion 3.5.7.2.
Page 3-92, section 3.5.7.2.2 (Birds) states that a ECO-3 field survey was conducted of the site in June Closed Through 2021. Provide a brief explanation of the Audit Discussion procedures and observations of that survey.
Page 3-92, section 3.5.7.2.2 (Birds) states that a field survey was conducted of the site in June Closed Through ECO-4 2021. Also, table 1.4-2 states that a field survey Audit Discussion identified no eagle nests in the vicinity of the site.
Provide a copy of that survey.
Provide a copy of that survey.
Provide a copy of the IPaC search results forming the basis of section 3.5.11. Also, table       Closed Through ECO-5           1.4-2 on page 1-8 states that the applicant has       Audit Discussion developed a biological assessment. If so, provide a copy of that biological assessment.
Provide a copy of the IPaC search results forming the basis of section 3.5.11. Also, table Closed Through ECO-5 1.4-2 on page 1-8 states that the applicant has Audit Discussion developed a biological assessment. If so, provide a copy of that biological assessment.
Page 3-101 section 3.5.11.4 states that bald eagles are not known to nest or forage on or           Closed Through ECO-6           adjacent to site. Provide basis for this statement. Audit Discussion How can we know that bald eagles are not present in forests around perimeter of site?
Page 3-101 section 3.5.11.4 states that bald eagles are not known to nest or forage on or Closed Through ECO-6 adjacent to site. Provide basis for this statement. Audit Discussion How can we know that bald eagles are not present in forests around perimeter of site?
Page 4-35, section 4.5.1.5 (Protected Species) states that no suitable [Indiana] bat trees were     Closed Through ECO-7           observed in the undisturbed riparian corridor         Audit Discussion adjacent to the site. Indicate the basis for this statement.
Page 4-35, section 4.5.1.5 (Protected Species) states that no suitable [Indiana] bat trees were Closed Through ECO-7 observed in the undisturbed riparian corridor Audit Discussion adjacent to the site. Indicate the basis for this statement.
Page 4-37, section 4.5.2.5 states that no federal or state-listed threatened, endangered or special status plant species have been observed on or in       Closed Through ECO-8                                                                  Audit Discussion the immediate vicinity of the site. Provide the basis for this statement. Can you quantify what constitutes the "immediate area?"
Page 4-37, section 4.5.2.5 states that no federal or state-listed threatened, endangered or special ECO-8 status plant species have been observed on or in Closed Through the immediate vicinity of the site. Provide the Audit Discussion basis for this statement. Can you quantify what constitutes the "immediate area?"
Please explain why the temporary and                   Closed Through ECO-9           permanent impact acreages for                         Audit Discussion herbaceous/grassland impacts in table 4.5-1 total 8
Please explain why the temporary and Closed Through ECO-9 permanent impact acreages for Audit Discussion herbaceous/grassland impacts in table 4.5-1 total
 
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88 ac when the table states that the total acreage of that habitat is only 72 ac.
Page 4-33, section 4.5.1.2 states that "Groundwater removed during construction for Closed Through dewatering [of the reactor building excavation] Request for ECO-10 will be properly managed as discussed in section Confirmatory 4.4.1.1.1, That section just states that Kairos Information (RCI #7) would consult with DOE and follow DOE's ML22115A204 recommendations. Please provide more details on how that water would be managed.
Roughly bound the quantity of groundwater that Closed Through might have to be dewatered to excavate for Request for ECO-11 construction of the reactor. Confirmatory Information (RCI #8)
ML22115A204 Page 4-33 section 4.5.1.2 states that stormwater would flow to a stormwater pond and then be ECO-12 discharged to Poplar Creek. Indicate the location Closed Through of the proposed discharge. Page 2-15 states that Audit Discussion Kairos assumes that the stormwater discharge would use an existing outfall.


Info Need ID                      Information Need                      Resolution 88 ac when the table states that the total acreage of that habitat is only 72 ac.
Cultural and Historical Resources Provide a knowledgeable expert to discuss the historic and cultural resource investigations conducted on or near the proposed project site, HCUL-1 and historic and cultural resources described in Closed Through section 3.6.2. Staff would also like to discuss Audit Discussion potential impacts to historic and cultural resources from the proposed action as they are currently understood and as described in the ER.
Page 4-33, section 4.5.1.2 states that "Groundwater removed during construction for        Closed Through dewatering [of the reactor building excavation]    Request for will be properly managed as discussed in section    Confirmatory ECO-10 4.4.1.1.1, That section just states that Kairos    Information (RCI #7) would consult with DOE and follow DOE's            ML22115A204 recommendations. Please provide more details on how that water would be managed.
In ER table 1.4-1, there is a table entry for Tennessee Department of Transportation HCUL-2 (TDOT) that states that there would be Closed Through construction of a driveway connection to Hwy 58. Audit Discussion Is this land previously disturbed and has it been surveyed for historic and cultural resources?
Roughly bound the quantity of groundwater that      Closed Through might have to be dewatered to excavate for          Request for ECO-11          construction of the reactor.                        Confirmatory Information (RCI #8)
ML22115A204 Page 4-33 section 4.5.1.2 states that stormwater would flow to a stormwater pond and then be discharged to Poplar Creek. Indicate the location  Closed Through ECO-12                                                              Audit Discussion of the proposed discharge. Page 2-15 states that Kairos assumes that the stormwater discharge would use an existing outfall.
Cultural and Historical Resources Provide a knowledgeable expert to discuss the historic and cultural resource investigations conducted on or near the proposed project site, and historic and cultural resources described in   Closed Through HCUL-1                                                              Audit Discussion section 3.6.2. Staff would also like to discuss potential impacts to historic and cultural resources from the proposed action as they are currently understood and as described in the ER.
In ER table 1.4-1, there is a table entry for Tennessee Department of Transportation (TDOT) that states that there would be             Closed Through HCUL-2                                                              Audit Discussion construction of a driveway connection to Hwy 58.
Is this land previously disturbed and has it been surveyed for historic and cultural resources?
In ER section 1.4, states that Kairos (in addition to the formal consultations listed in table 1.4-2),
In ER section 1.4, states that Kairos (in addition to the formal consultations listed in table 1.4-2),
made informal contacts with the National Nuclear Security Administration, the Bureau of Indian       Closed Through HCUL-3                                                              Audit Discussion Affairs, the Tennessee Department of Environment and Conservation, the TDOT, and the City of Oak Ridge. The stated purpose was to inform the agencies about the project and to 9
made informal contacts with the National Nuclear HCUL-3 Security Administration, the Bureau of Indian Closed Through Affairs, the Tennessee Department of Audit Discussion Environment and Conservation, the TDOT, and the City of Oak Ridge. The stated purpose was to inform the agencies about the project and to
 
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coordinate project planning. Provide a summary of any interactions related to historic and cultural resources as well as any applicable correspondence.
In ER table 1.4-2 Consultations Required for Construction and Operation and ER Section 3.6.4 - Did Kairos engage the Tennessee Historical Commission, Tennessee Division of Closed Through HCUL-4 Archaeology, Native American Nations, DOE, or Audit Discussion the National Park Service while developing its application for this proposed action? If so, provide a summary of any interactions as well as any applicable correspondence.
Provide a knowledgeable expert to discuss DOE-OREM's NEPA and NHPA section 106 consultation and review activities associated with the land transfer to Community Reuse Organization of East Tennessee. ER table 1.4-2 provides a list of statutes that guide required consultations. With respect to Native American Nations, the table lists the Native American Grave Protection and Repatriation Act as one of the applicable statutes. Additionally, in ER section 4.6.1, it states to minimize impacts to historic and cultural resources, Kairos would develop an Archaeological Monitoring and Discovery plan that would specify procedures for addressing and handling the unexpected Closed Through discovery of human remains or archaeological Request for HCUL-5 material during construction. It states that if Confirmatory human remains are discovered, construction Information (RCI #9 personnel will notify a representative of Kairos, and RCI #10) and that representative will contact appropriate ML22115A204 local law enforcement and the DOE historic preservation officer. DOE's 2011 EA (DOE/EA-1640), section 3.6.2.1, states that inadvertent discovery and notification provisions would be contained within lease and/or deed restrictions.
Similarly, the 2017 Quitclaim Deed for the Former K-33 Site includes lease and/or deed restrictions regarding the protection of historic and/or archaeological resources. Since the lands are no longer considered Federal property, provide a summary response to confirm if federal land management requirements still apply as part of any existing lease and/or deed restrictions with respect to the inadvertent discovery and


Info Need ID                 Information Need                         Resolution coordinate project planning. Provide a summary of any interactions related to historic and cultural resources as well as any applicable correspondence.
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In ER table 1.4-2 Consultations Required for Construction and Operation and ER Section 3.6.4 - Did Kairos engage the Tennessee Historical Commission, Tennessee Division of        Closed Through HCUL-4      Archaeology, Native American Nations, DOE, or        Audit Discussion the National Park Service while developing its application for this proposed action? If so, provide a summary of any interactions as well as any applicable correspondence.
Provide a knowledgeable expert to discuss DOE-OREM's NEPA and NHPA section 106 consultation and review activities associated with the land transfer to Community Reuse Organization of East Tennessee. ER table 1.4-2 provides a list of statutes that guide required consultations. With respect to Native American Nations, the table lists the Native American Grave Protection and Repatriation Act as one of the applicable statutes. Additionally, in ER section 4.6.1, it states to minimize impacts to historic and cultural resources, Kairos would develop an Archaeological Monitoring and Discovery plan that would specify procedures for addressing and handling the unexpected              Closed Through discovery of human remains or archaeological        Request for material during construction. It states that if      Confirmatory HCUL-5                                                            Information (RCI #9 human remains are discovered, construction personnel will notify a representative of Kairos,    and RCI #10) and that representative will contact appropriate    ML22115A204 local law enforcement and the DOE historic preservation officer. DOE's 2011 EA (DOE/EA-1640), section 3.6.2.1, states that inadvertent discovery and notification provisions would be contained within lease and/or deed restrictions.
Similarly, the 2017 Quitclaim Deed for the Former K-33 Site includes lease and/or deed restrictions regarding the protection of historic and/or archaeological resources. Since the lands are no longer considered Federal property, provide a summary response to confirm if federal land management requirements still apply as part of any existing lease and/or deed restrictions with respect to the inadvertent discovery and 10


Info Need ID                  Information Need                        Resolution protection of historic and cultural resources (such as ARPA and NAGPRA). Provide a summary response to describe any stipulations that Kairos Power must abide with.
protection of historic and cultural resources (such as ARPA and NAGPRA). Provide a summary response to describe any stipulations that Kairos Power must abide with.
In ER section 4.6.1 - Provide a status update on the development of the Archaeological Monitoring and Discovery plan along with any training material that will be used with             Closed Through construction personnel regarding the                 Request for HCUL-6       identification of historic and cultural resources. Confirmatory Will this procedure be developed with input from     Information (RCI #11) the Tennessee Historical Commission,                 ML22115A204 Tennessee Division of Archaeology, or DOE?
In ER section 4.6.1 - Provide a status update on the development of the Archaeological Monitoring and Discovery plan along with any training material that will be used with Closed Through construction personnel regarding the Request for HCUL-6 identification of historic and cultural resources. Confirmatory Will this procedure be developed with input from Information (RCI #11) the Tennessee Historical Commission, ML22115A204 Tennessee Division of Archaeology, or DOE?
Would the plant incorporate any existing DOE-OREM guidance?
Would the plant incorporate any existing DOE-OREM guidance?
In ER section 3.6: DOE-OREM executed several Memorandum of Agreements (MOAs) with respect to the decontamination and decommissioning activities and mitigation of adverse effects to historic properties associated with the K-25 site and East Tennessee Technology Park (ETTP). In reviewing the 2012       Closed Through HCUL-7                                                            Audit Discussion final MOA, Execution Plan, and final Mitigation Plan for the interpretation of historical properties at ETTP (2012 MOA), and the July 31, 2019 amendment, is the Kairos Hermes project located outside the bounds of the K-25 Preservation Footprint Viewshed (see Stipulation 3 of 2019 Amendment)?
In ER section 3.6: DOE-OREM executed several Memorandum of Agreements (MOAs) with respect to the decontamination and decommissioning activities and mitigation of adverse effects to historic properties associated with the K-25 site and East Tennessee HCUL-7 Technology Park (ETTP). In reviewing the 2012 Closed Through final MOA, Execution Plan, and final Mitigation Audit Discussion Plan for the interpretation of historical properties at ETTP (2012 MOA), and the July 31, 2019 amendment, is the Kairos Hermes project located outside the bounds of the K-25 Preservation Footprint Viewshed (see Stipulation 3 of 2019 Amendment)?
In ER section 3.6.2 summarizes previous cultural resource investigations (archaeological and architectural) conducted on and in the vicinity of the ORR since the 1970. Did any of the referenced surveys occur within or overlap with the 185-acre proposed project area? Additionally, in DOE's Environmental Assessment prepared           Closed Through HCUL-8       for the Transfer of Land and Facilities within the   Audit Discussion ETTP and Surrounding Area, Oak Ridge, Tennessee (DOE/EA-1640), it discusses the location of four National Register of Historic Places -eligible prehistoric archaeological sites in the EA study area. Staff would like to discuss where these sites are in relation to the proposed Kairos site.
In ER section 3.6.2 summarizes previous cultural resource investigations (archaeological and architectural) conducted on and in the vicinity of the ORR since the 1970. Did any of the referenced surveys occur within or overlap with the 185-acre proposed project area? Additionally, in DOE's Environmental Assessment prepared Closed Through HCUL-8 for the Transfer of Land and Facilities within the Audit Discussion ETTP and Surrounding Area, Oak Ridge, Tennessee (DOE/EA-1640), it discusses the location of four National Register of Historic Places -eligible prehistoric archaeological sites in the EA study area. Staff would like to discuss where these sites are in relation to the proposed Kairos site.
Please make available copies of references listed   Closed Through HCUL-9                                                            Audit Discussion in section 3.6.5 of the ER in the reading room.
HCUL-9 Please make available copies of references listed Closed Through in section 3.6.5 of the ER in the reading room. Audit Discussion
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Info Need ID                   Information Need                       Resolution In ER section 4.6.1, it states that the nearest listed NRHP property is the K-25 Gaseous Diffusion Plant which is part of the Manhattan Project National Park. The ER states that "given the intervening structures between the     Closed Through Post site and the K-25 Plant as well as the low profile Audit Submittal by HCUL-10       of the proposed structures on the site, no visual   Kairos or other indirect impacts occur." Please describe   (ML22117A215) or discuss any architectural surveys conducted for the proposed project to assess indirect (i.e.,
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In ER section 4.6.1, it states that the nearest listed NRHP property is the K-25 Gaseous Diffusion Plant which is part of the Manhattan Project National Park. The ER states that "given the intervening structures between the Closed Through Post site and the K-25 Plant as well as the low profile Audit Submittal by HCUL-10 of the proposed structures on the site, no visual Kairos or other indirect impacts occur." Please describe (ML22117A215) or discuss any architectural surveys conducted for the proposed project to assess indirect (i.e.,
visual) effects to other historic and cultural resources (i.e., historic properties) within the viewshed/indirect effects APE?
visual) effects to other historic and cultural resources (i.e., historic properties) within the viewshed/indirect effects APE?
Human Health: Non-Radiological Provide a quantitative bound on what constitutes the "insignificant volumes" of nonradioactive       Closed Through HHN-1                                                              Audit Discussion liquid chemical wastes to be generated, as stated on page 4-51.
 
Provide information on the type and height of       Closed Through HHN-2         perimeter fencing and signage to be built around   Audit Discussion the proposed facilities.
Human Health: Non-Radiological
 
Provide a quantitative bound on what constitutes HHN-1 the "insignificant volumes" of nonradioactive Closed Through liquid chemical wastes to be generated, as stated Audit Discussion on page 4-51.
Provide information on the type and height of Closed Through HHN-2 perimeter fencing and signage to be built around Audit Discussion the proposed facilities.
Provide subject matter expert(s) to discuss chemical hazards regarding the FLiBe salt to be used in the Hermes test reactor. Due to the hazardous nature of beryllium, especially concerning airborne particulates, the staff needs to understand how this beryllium-bearing material will be controlled and monitored for potential beryllium exposure. PSAR section 1.2.1 states "Flibe coolant, while chemically stable, contains potentially toxic constituents including beryllium.
Provide subject matter expert(s) to discuss chemical hazards regarding the FLiBe salt to be used in the Hermes test reactor. Due to the hazardous nature of beryllium, especially concerning airborne particulates, the staff needs to understand how this beryllium-bearing material will be controlled and monitored for potential beryllium exposure. PSAR section 1.2.1 states "Flibe coolant, while chemically stable, contains potentially toxic constituents including beryllium.
The reactor building and ventilation system         Closed Through HHN-3                                                              Audit Discussion function as a confinement to manage and control beryllium hazards..." PSAR section 4.4.1 states "In addition, the biological shield reduces radiation damage to plant equipment and also reduces the potential for Beryllium exposure to reactor personnel." PSAR section 9.2.2 states "In addition, the RBHVAC system ensures that chemical hazards (such as Beryllium) are within applicable limits." However, the ER has no similar discussion regarding occupational and public safety with respect to beryllium.
HHN-3 The reactor building and ventilation system Closed Through function as a confinement to manage and control Audit Discussion beryllium hazards..." PSAR section 4.4.1 states "In addition, the biological shield reduces radiation damage to plant equipment and also reduces the potential for Beryllium exposure to reactor personnel." PSAR section 9.2.2 states "In addition, the RBHVAC system ensures that chemical hazards (such as Beryllium) are within applicable limits." However, the ER has no similar discussion regarding occupational and public safety with respect to beryllium.
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Provide the basis for the statement in section 4.8.1.6 that "the facility design and practices Closed Through HHN-4 would ensure compliance with storage Audit Discussion requirements and limit exposures." What practices would be taken to "limit exposures"?
Section 4.8.1.7 states that specific environmental monitoring of non-radiological constituents would HHN-5 be determined through the permitting process. Closed Through Please provide a brief description of what Audit Discussion monitoring activities (if any) might be required in the permits.


Info Need ID                    Information Need                        Resolution Provide the basis for the statement in section 4.8.1.6 that "the facility design and practices    Closed Through HHN-4          would ensure compliance with storage                Audit Discussion requirements and limit exposures." What practices would be taken to "limit exposures"?
Human Health - Radiological Provide a list of the specific radionuclides and Closed Through annual radiological effluents Request for HHR-1 amounts/concentrations applied as input Confirmatory parameter values in the NRCDose calculations. Information (RCI #12)
Section 4.8.1.7 states that specific environmental monitoring of non-radiological constituents would be determined through the permitting process.      Closed Through HHN-5                                                              Audit Discussion Please provide a brief description of what monitoring activities (if any) might be required in the permits.
ML22115A204 Provide in a location accessible by the staff for HHR-2 audit review the NRCDose input and output files Closed Through (i.e., for both XOQDOQ and GASPAR II) for staff Audit Discussion inspection.
Human Health - Radiological Provide a list of the specific radionuclides and   Closed Through annual radiological effluents                       Request for HHR-1         amounts/concentrations applied as input             Confirmatory parameter values in the NRCDose calculations.       Information (RCI #12)
Provide subject matter expert(s) to discuss the details of the NRCDose calculations and results Closed Through HHR-3 presented in section 4.8 of the ER and to explain Audit Discussion why table 4.8-3 TEDE values do not include contributions from tritium.
ML22115A204 Provide in a location accessible by the staff for audit review the NRCDose input and output files     Closed Through HHR-2                                                              Audit Discussion (i.e., for both XOQDOQ and GASPAR II) for staff inspection.
Provide subject matter expert(s) to discuss the Closed Through HHR-4 use of ORR Tower L meteorological data for Audit Discussion NRCDOSE calculations.
Provide subject matter expert(s) to discuss the details of the NRCDose calculations and results     Closed Through HHR-3         presented in section 4.8 of the ER and to explain   Audit Discussion why table 4.8-3 TEDE values do not include contributions from tritium.
Provide a subject matter expert(s) to discuss Closed Through HHR-5 radiological liquid discharges, such as its Audit Discussion sources, collection, and disposal.
Provide subject matter expert(s) to discuss the   Closed Through HHR-4         use of ORR Tower L meteorological data for         Audit Discussion NRCDOSE calculations.
Provide a subject matter expert(s) to discuss the Closed Through HHR-6 radiological environmental monitoring of ER Audit Discussion section 4.8.3, Radiological Monitoring.
Provide a subject matter expert(s) to discuss       Closed Through HHR-5         radiological liquid discharges, such as its         Audit Discussion sources, collection, and disposal.
Provide a subject matter expert(s) to discuss the   Closed Through HHR-6         radiological environmental monitoring of ER         Audit Discussion section 4.8.3, Radiological Monitoring.
Make available for staff review the following ER section 3.8 references (Note: if not listed below, then the references were accessible): 1) Ref # 12
Make available for staff review the following ER section 3.8 references (Note: if not listed below, then the references were accessible): 1) Ref # 12
              - U.S. Department of Energy, "Environmental         Closed Through HHR-7         Baseline Survey Report for the Proposed Title       Audit Discussion Transfer of the Former K-33 Area at the East Tennessee Technology Park, Oak Ridge, Tennessee." DOE/OR/01-2658. September 2015. 2) Ref # 13 - U.S. Department of Energy, 13
- U.S. Department of Energy, "Environmental Closed Through HHR-7 Baseline Survey Report for the Proposed Title Audit Discussion Transfer of the Former K-33 Area at the East Tennessee Technology Park, Oak Ridge, Tennessee." DOE/OR/01-2658. September 2015. 2) Ref # 13 - U.S. Department of Energy,
 
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"Environmental Baseline Survey Report for the Proposed Title Transfer of the Former K-31 Area at the East Tennessee Technology Park, Oak Ridge, Tennessee." DOE/OR/01-2677. July 2015. 3) Ref # 16-16. Bureau of Labor and Statistics, Hours-based fatal injury rates by industry, occupation, and selected demographic characteristics, Website: [missing hyperlink to website]
Provide information and subject matter expert(s)
HHR-8 to discuss the text in ER section 4.13.8 where the Closed Through Kairos Power Nuclear Fuel Fabrication Facility is Audit Discussion mentioned as a future project.
 
Fuel Cycle and Radiological Waste Management
 
Provide subject matter expert(s) to discuss FCRW-1 Kairos's source for HALEU material and the Closed Through related front end fuel cycle process with respect Audit Discussion to table S-3.
Provide subject matter expert(s) to discuss the statement in section 2.7.1: "A manufacturer has FCRW-2 not been decided for the Hermes reactor" and the Closed Through status of developing a Kairos-specific TRISO fuel Audit Discussion fabrication process including sources of HALEU material.
Provide subject matter expert(s) to discuss the use of the Continued Storage Generic Environmental Impact Statement, NUREG-2157 and, as presented in ER section 4.9.1.2, on the expected long-term storage performance of the Closed Through FCRW-3 TRISO coatings (e.g., "degradation rates for Audit Discussion storage systems associated with continued storage of TRISO fuel") based on available supporting data of prior TRISO fuels (e.g., Fort St Vrain reactor and the German pebble bed research reactor).
Provide information and subject matter expert(s) to discuss what is to be done with the spent FCRW-4 TRISO fuel once the facility is decommissioned, Closed Through such as to whether the facility footprint includes a Audit Discussion place for a dry storage facility during or after the cessation of operations.
Provide information and subject matter expert(s) Closed Through FCRW-5 to discuss the disposal of nitrate salt during Audit Discussion decommissioning to include the quantity of
 
14 Info Need ID Information Need Resolution
 
material and the rational for disposing as either class A or B LLRW.
Provide information and subject matter expert(s) Closed Through to discuss the disposal of tritium-bearing material Request for FCRW-6 used to capture tritium gas by the Tritium Confirmatory Management System (ER section 2.6.1.2.3). Information (RCI #13)
ML22115A204 Provide information and subject matter expert(s) to discuss the storage and disposal of solidified FLiBe salt with respect to: 1) possible off-gassing of florine (due to radiation decomposition) or the release of tritium during long-term storage, 2) the quantity to be disposed of during Closed Through decommissioning, 3) how this waste could be Request for FCRW-7 class C LLRW per 10 CFR 61.55 since there is Confirmatory no limits established for tritium in class B or C Information (RCI #14) wastes under table 2 of ML22115A204 10 CFR 61.55(a)(4), and 4) to confirm that the chemical form of this waste, outside of its radiological content, would meet all acceptance criteria for disposal at WCS (i.e., WCS would accept this waste stream).
Provide subject matter expert(s) to discuss the justification for the statement in ER section 2.6.1.3 that "[t]he facility is not expected to need Closed Through FCRW-8 a gaseous radioactive waste system." given that Audit Discussion is later noted releases will be controlled and a detailed radiological effluent release dose analysis is provided in ER section 4.8.
Provide a subject matter expert(s) to discuss the estimated table 2.6-1 volume of dry active waste (i.e., LLRW) in comparison to the typical annual Closed Through FCRW-9 amount produced by a PWR as described in Rev Audit Discussion 1 of NUREG-1437 section 3.11.1.1 on page 3-154 and to confirm how the approximately 8,800 ft3 per year was determined.
 
Transportation of Radioactive Material Provide information and subject matter expert(s) Closed Through to discuss the transportation of spent TRISO fuel Request for TR-1 including how TRISO fuel may or may not be Confirmatory bounded by previously analyzed scenarios Information (RCI #15) related to LLWR fuel. ML22115A204 TR-2 Provide subject matter expert(s) to discuss non-Closed Through radiological impacts that would result from an Audit Discussion
 
15 Info Need ID Information Need Resolution
 
accident involving the shipment of radioactive material including if or how the scenario would be bounded by previously analyzed scenarios for LLWR fuel.
Provide expected radionuclide activity levels Closed Through (especially for tritium) and disposal acceptance Request for TR-3 levels and subject matter expert(s) to discuss the Confirmatory shipment and disposal of this material at the Information (RCI #16) various commercial LLRW disposal sites. ML22115A204 Provide for staff review the following ER section 4.10.4 references: 1) Ref # 9 - Kairos Power LLC, 2021. Flibe Safety Data Sheet. Issued April Closed Through TR-4 2, 2021. 2) Ref # 10 - SQM, 2014. Sodium Audit Discussion Nitrate Safety Data Sheet. Issued January 2014.
: 3) Ref # 11 - SQM, 2015. Potassium Nitrate Safety Data Sheet. Issued March 2015
 
Accidents Provide subject matter expert(s) to discuss the Closed Through information and the results presented in section Request for ACC-1 4.11 of the ER, the related offsite accident Confirmatory consequences concerning the MHA, and the Information (RCI #17) potential for mitigation. ML22115A204 Provide the MHA release source term that Closed Through ACC-2 resulted in the dose consequences presented in Audit Discussion ER table 4.11-1.
 
Alternatives Provide a map (or a description) showing the Closed Through locations of Potential Sites 1.1 and 1.3 Request for ALT-1 Confirmatory Information (RCI #19)
ML22115A204 Provide maps (preferably as overlays on aerial photographs or topographic maps) clearly indicating the shapes and sizes of the Proposed Closed Through Eagle Rock Site and Proposed Eagle Rock Request for ALT-2 Property (as shown on figure 5.4-3 on page 5-Confirmatory 48). Indicate the approximate size of each. Can Information (RCI #20) you indicate where in the Proposed Eagle Rock ML22115A204 Site where the proposed test reactors would be built under this alternative, or can you indicate that they could be built anywhere within the site.
 
16 Info Need ID Information Need Resolution
 
Section 5.4.1.4. Indicate how water needs of the Closed Through proposed test reactor would be met, and how the Request for ALT-3 wastewater would be treated, if the proposed test Confirmatory reactor were to be built at the Eagle Rock Site. Information (RCI #21)
ML22115A204 Provide a copy of the IPaC search results for the Closed Through Eagle Rock site. Request for ALT-4 Confirmatory Information (RCI #22)
ML22115A204 Referring to figure 5.4-5 "Vegetation Types of the Proposed Eagle Rock Site" - explain what is Closed Through ALT-5 meant by the "Bird Point Survey Locations" and Audit Discussion the "Vegetation Transect Locations". What surveys are these a part of?


Info Need ID                    Information Need                        Resolution "Environmental Baseline Survey Report for the Proposed Title Transfer of the Former K-31 Area at the East Tennessee Technology Park, Oak Ridge, Tennessee." DOE/OR/01-2677. July 2015. 3) Ref # 16-16. Bureau of Labor and Statistics, Hours-based fatal injury rates by industry, occupation, and selected demographic characteristics, Website: [missing hyperlink to website]
Table 4. Attendee List for Environmental Audit Close Out Meeti ng, March 30, 2022
Provide information and subject matter expert(s) to discuss the text in ER section 4.13.8 where the  Closed Through HHR-8                                                                Audit Discussion Kairos Power Nuclear Fuel Fabrication Facility is mentioned as a future project.
Fuel Cycle and Radiological Waste Management Provide subject matter expert(s) to discuss Kairos's source for HALEU material and the          Closed Through FCRW-1                                                              Audit Discussion related front end fuel cycle process with respect to table S-3.
Provide subject matter expert(s) to discuss the statement in section 2.7.1: "A manufacturer has not been decided for the Hermes reactor" and the    Closed Through FCRW-2                                                              Audit Discussion status of developing a Kairos-specific TRISO fuel fabrication process including sources of HALEU material.
Provide subject matter expert(s) to discuss the use of the Continued Storage Generic Environmental Impact Statement, NUREG-2157 and, as presented in ER section 4.9.1.2, on the expected long-term storage performance of the        Closed Through FCRW-3          TRISO coatings (e.g., "degradation rates for        Audit Discussion storage systems associated with continued storage of TRISO fuel") based on available supporting data of prior TRISO fuels (e.g., Fort St Vrain reactor and the German pebble bed research reactor).
Provide information and subject matter expert(s) to discuss what is to be done with the spent TRISO fuel once the facility is decommissioned,     Closed Through FCRW-4                                                              Audit Discussion such as to whether the facility footprint includes a place for a dry storage facility during or after the cessation of operations.
Provide information and subject matter expert(s)    Closed Through FCRW-5          to discuss the disposal of nitrate salt during      Audit Discussion decommissioning to include the quantity of 14


Info Need ID                        Information Need                      Resolution material and the rational for disposing as either class A or B LLRW.
Name Affiliation
Provide information and subject matter expert(s)    Closed Through to discuss the disposal of tritium-bearing material  Request for FCRW-6            used to capture tritium gas by the Tritium          Confirmatory Management System (ER section 2.6.1.2.3).            Information (RCI #13)
ML22115A204 Provide information and subject matter expert(s) to discuss the storage and disposal of solidified FLiBe salt with respect to: 1) possible off-gassing of florine (due to radiation decomposition) or the release of tritium during long-term storage, 2) the quantity to be disposed of during                    Closed Through decommissioning, 3) how this waste could be          Request for FCRW-7            class C LLRW per 10 CFR 61.55 since there is        Confirmatory no limits established for tritium in class B or C    Information (RCI #14) wastes under table 2 of                              ML22115A204 10 CFR 61.55(a)(4), and 4) to confirm that the chemical form of this waste, outside of its radiological content, would meet all acceptance criteria for disposal at WCS (i.e., WCS would accept this waste stream).
Provide subject matter expert(s) to discuss the justification for the statement in ER section 2.6.1.3 that "[t]he facility is not expected to need Closed Through FCRW-8            a gaseous radioactive waste system." given that      Audit Discussion is later noted releases will be controlled and a detailed radiological effluent release dose analysis is provided in ER section 4.8.
Provide a subject matter expert(s) to discuss the estimated table 2.6-1 volume of dry active waste (i.e., LLRW) in comparison to the typical annual    Closed Through FCRW-9            amount produced by a PWR as described in Rev        Audit Discussion 1 of NUREG-1437 section 3.11.1.1 on page 3-154 and to confirm how the approximately 8,800 ft3 per year was determined.
Transportation of Radioactive Material Provide information and subject matter expert(s)    Closed Through to discuss the transportation of spent TRISO fuel    Request for TR-1              including how TRISO fuel may or may not be          Confirmatory bounded by previously analyzed scenarios            Information (RCI #15) related to LLWR fuel.                                ML22115A204 Provide subject matter expert(s) to discuss non-    Closed Through TR-2                                                                  Audit Discussion radiological impacts that would result from an 15


Info Need ID                  Information Need                      Resolution accident involving the shipment of radioactive material including if or how the scenario would be bounded by previously analyzed scenarios for LLWR fuel.
Dozier, Tami U.S. Nuclear Regulatory Agency (NRC)
Provide expected radionuclide activity levels      Closed Through (especially for tritium) and disposal acceptance  Request for TR-3        levels and subject matter expert(s) to discuss the Confirmatory shipment and disposal of this material at the      Information (RCI #16) various commercial LLRW disposal sites.            ML22115A204 Provide for staff review the following ER section 4.10.4 references: 1) Ref # 9 - Kairos Power LLC, 2021. Flibe Safety Data Sheet. Issued April  Closed Through TR-4        2, 2021. 2) Ref # 10 - SQM, 2014. Sodium          Audit Discussion Nitrate Safety Data Sheet. Issued January 2014.
Davis, Jennifer NRC Palmrose, Donald NRC Doub, Peyton NRC Glowacki, Brian NRC Willingham, Laura NRC Giacinto, Joseph NRC Miller, Ed NRC Wilkins, Lynnea NRC Marty Bryan Kairos Power, LLC (Kairos)
: 3) Ref # 11 - SQM, 2015. Potassium Nitrate Safety Data Sheet. Issued March 2015 Accidents Provide subject matter expert(s) to discuss the    Closed Through information and the results presented in section  Request for ACC-1        4.11 of the ER, the related offsite accident      Confirmatory consequences concerning the MHA, and the          Information (RCI #17) potential for mitigation.                          ML22115A204 Provide the MHA release source term that          Closed Through ACC-2        resulted in the dose consequences presented in    Audit Discussion ER table 4.11-1.
Austin Clark Kairos Darrell Gardner Kairos Wayne Massie Kairos Peter Hastings Kairos Taylor, Kevin AECOM Freeman, Carol L B AECOM Bergman, Jana member of the public Matis, Lisa Tetra Tech Steven Pope member of the public Generette, Lloyd U.S. Environmental Protection Agency Michelle Byman member of the public Erin Wisler member of the public
Alternatives Provide a map (or a description) showing the      Closed Through locations of Potential Sites 1.1 and 1.3          Request for ALT-1                                                          Confirmatory Information (RCI #19)
ML22115A204 Provide maps (preferably as overlays on aerial photographs or topographic maps) clearly indicating the shapes and sizes of the Proposed    Closed Through Eagle Rock Site and Proposed Eagle Rock            Request for Property (as shown on figure 5.4-3 on page 5-      Confirmatory ALT-2 48). Indicate the approximate size of each. Can    Information (RCI #20) you indicate where in the Proposed Eagle Rock      ML22115A204 Site where the proposed test reactors would be built under this alternative, or can you indicate that they could be built anywhere within the site.
16


Info Need ID                      Information Need                      Resolution Section 5.4.1.4. Indicate how water needs of the  Closed Through proposed test reactor would be met, and how the    Request for ALT-3            wastewater would be treated, if the proposed test  Confirmatory reactor were to be built at the Eagle Rock Site. Information (RCI #21)
17 Rani Franovich The Breakthrough Institute Adam Stein The Breakthrough Institute
ML22115A204 Provide a copy of the IPaC search results for the  Closed Through Eagle Rock site.                                  Request for ALT-4                                                              Confirmatory Information (RCI #22)
ML22115A204 Referring to figure 5.4-5 "Vegetation Types of the Proposed Eagle Rock Site" - explain what is        Closed Through ALT-5            meant by the "Bird Point Survey Locations" and    Audit Discussion the "Vegetation Transect Locations". What surveys are these a part of?
Table 4. Attendee List for Environmental Audit Close Out Meeting, March 30, 2022 Name                              Affiliation Dozier, Tami                      U.S. Nuclear Regulatory Agency (NRC)
Davis, Jennifer                    NRC Palmrose, Donald                  NRC Doub, Peyton                      NRC Glowacki, Brian                    NRC Willingham, Laura                  NRC Giacinto, Joseph                  NRC Miller, Ed                        NRC Wilkins, Lynnea                    NRC Marty Bryan                        Kairos Power, LLC (Kairos)
Austin Clark                      Kairos Darrell Gardner                    Kairos Wayne Massie                      Kairos Peter Hastings                    Kairos Taylor, Kevin                      AECOM Freeman, Carol L B                AECOM Bergman, Jana                      member of the public Matis, Lisa                        Tetra Tech Steven Pope                        member of the public Generette, Lloyd                  U.S. Environmental Protection Agency Michelle Byman                    member of the public Erin Wisler                        member of the public 17


Rani Franovich The Breakthrough Institute Adam Stein    The Breakthrough Institute 18}}
18}}

Latest revision as of 08:10, 16 November 2024

Environmental Audit Report - Kairos Hermes Test Reactor Construction Permit Application
ML22194A936
Person / Time
Site: Hermes File:Kairos Power icon.png
Issue date: 08/24/2022
From:
Office of Nuclear Material Safety and Safeguards
To:
Office of Nuclear Material Safety and Safeguards
Dozier T
Shared Package
ML22196A387 List:
References
Download: ML22194A936 (18)
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Text

SUMMARY

REPORT ON THE ENVIRONMENTAL AUDIT OF KAIROS HERMES TEST REACTOR CONSTRUCTION PERMIT APPLICATION

1.0 Background

The U.S. Nuclear Regulatory Commission (NRC) is currently revie wing an application from Kairos Power, LLC (Kairos) for a construction permit (CP) for a test reactor to be located in Oak Ridge, Tennessee. As part of its review, the NRC is preparing a n Environmental Impact Statement (EIS). An audit was conducted from February 28, 2022, to March 30, 2022, to support the environmental review of Kairos CP application. Thi s report presents a summary of the audits objectives and activities, and information that was obtained as a result of audit activities.

1.1 Application Overview

By letter dated October 31, 2021 (Agencywide Documents Access a nd Management System (ADAMS) ML21306A131), Kairos submitted an Environmental Report (ER) in support of its Hermes CP application. By letters dated February 10, February 1 8, and March 1, 2022, Kairos provided supplemental information regarding its CP application, including the ER (ML22042A095, ML22049B555, and ML22060A272). References to the Kairos ER in this summary report include these revisions.

1.2 Project and Site Overview

The proposed action is for the NRC to issue a CP to Kairos auth orizing construction of the Hermes reactor. In its CP application, Kairos proposes to build and operate the Hermes project to demonstrate key elements of the Kairos Power Fluoride Salt-C ooled, High Temperature Reactor technology for possible future commercial deployment. O peration of the Hermes reactor would not generate any power for sale or distribution. The technology is an advanced nuclear reactor technology that leverages TRI-structural ISOtro pic (TRISO) particle fuel in pebble form combined with a low-pressure fluoride salt coolant. The proposed site is situated in the Heritage Center of the East Tennessee Technology Park, an i ndustrial park established by the City of Oak Ridge, on land formerly owned by the U.S. Depar tment of Energy (DOE) for the Oak Ridge Gaseous Diffusion Plant. The Kairos Hermes ER provide s Kairos analyses of the environmental impacts that could result from building, operatin g, and decommissioning the Hermes test reactor at the proposed site.

2.0 Audit Scope and Objectives

During the audit, the staff discussed environmental matters rel ated to land use, ground and surface water, terrestrial and aquatic ecology, human health, p ostulated accidents, radiological and non-radiological waste, cultural resources, fuel cycle, tra nsportation of radioactive material, alternatives to the proposed action, air quality and noise. The audit allowed the staff to better understand the site, environmental interfaces of the project, a nd modeling results in order to make appropriate environmental findings.

In its initial review of data and information within the corres ponding context of the ER, the staff identified information needs that would promote a better unders tanding of the detailed analysis and bases underlying the construction permit application. These items were included in Attachment 1 of the audit plan presented to Kairos in advance ( ML22056A064). Audit activities consisted of document reviews, virtual meetings organized in ad vance and a few impromptu discussions as documented herein. These activities assisted the NRC and Kairos staff in resolving the information needs that were outlined in the plan. For items that the staff was not able to resolve through document reviews and audit discussions, Kairos submitted information to the Kairos Hermes docket, supplementing its CP application t o provide the necessary information for the staff to make impact determinations in the EIS.

Table 1 of this report presents a list of the NRC staff partici pating in the audit and their associated EIS review areas. Table 2 presents a list of Kairos staff and its contractors who participated in the audit.

Table 1. Review Areas with assigned team members Team Member

Team Member Role / Review Area Ken Erwin Environmental Review Supervisor Tami Dozier Environmental Project Manager Peyton Doub Technical Lead for the EIS; Site and Technical Overview / Proposed Action

/ Land Use and Visual Resources; Ecological Resources / Non-Radiological Human Health; Noise; Alternatives Don Palmrose Radiological Human Health; Transportation of Radioactive Materials; Fuel Cycle and Radiological Waste Management; Postulated Accidents Jennifer Davis Historic and Cultural Resources Joseph Giacinto Water Resources and Hydrogeology; Climate Change Laura Willingham Air Quality Daniel Mussatti Socioeconomics; Environmental Justice; Non-radiological Waste Management; Cost-Benefit Discussion Kevin Folk Adjunct Team Member

Table 2. List of Audit Participants for Kairos Power, LLC and A ECOM

Kairos Power, LLC AECOM Katie Dignan Kevin Taylor Darrell Gardner Carol Freeman Marty Bryan Carlos Szembek Austin Clark Bob Paine Wayne Massie Evelyn Rogers Brian Song Kristen Beckhorn Antonio Fernandez Fang Wang Lori Gross Delia Halliman Per Peterson Jim Orr Gus Merwin Steve Dillard Kieran Dolan Larry Neal Matt Denman Anneliesa Barta Peiwen Whysall Alan Kruizenga Jim Tompkins Ryan Latta Jianxin Liu Jordan Hagaman

2 3.0 Summary of Audit Activities and Issues Addressed

During the first week of the audit, an audit kickoff meeting an d 15 breakout sessions were conducted virtually where the NRC and Kairos staff discussed th e 78 information needs that had been provided to Kairos in the audit plan. For the remaining pe riod of the audit, the staff continued to examine supporting documents and hold follow up di scussions as needed. The staff determined that responses to several items would be neede d on the docket and Kairos agreed to provide that information in supplemental submittals o r as responses to Requests for Confirmatory Information (RCIs).

In order to appropriately document the staffs confirmation of information gathered during the audit which would not otherwise be available in the public doma in, the staff prepared and issued to Kairos a set of 22 RCIs (ML22090A060). Kairos provided all a greed upon supplemental information requested by the staff within 30 days of audit clos ure.

Table 3 presents a tabulated summary of how the information nee ds presented to Kairos in the audit plan were addressed. In summary, 52 of the 78 audit items were closed through audit discussions and staff review of supporting material. Five items required information to be provided by Kairos in supplement al submittals. Twenty-one items were resolved through Kairos response to RCIs (1 audit item required two separate RCIs, resu lting in Kairos responding to 22 separate RCIs.)

4.0 Audit Closeout Meeting

The NRC staff conducted a publicly noticed audit closeout meeti ng on March 30, 2022 (ML22088A212). At the closeout meeting the NRC staff reiterated the purpose of the audit, discussed the audit activities and the information still needed to close all audit items. Kairos shared their expected timeframe for providing the agreed upon s ubmittals expected to close the remaining items. Conditional upon review of the information Kai ros would be providing, the NRC staff stated that they did not anticipate the need for any addi tional information in order to complete their review; however, the staff stressed that the sco ping comment period was still underway and should new information be received from the scopin g process or from other means, additional information from Kairos could become necessar y. The meeting presentation is available at ML22088A225.

Members of the public were provided an opportunity to comment d uring the meeting. Attendees asked questions related to the RCI process and other audit acti vities. Attendees expressed interest in the anticipated date for review deliverables. Table 4 presents the attendance list.

5.0 Post Audit Followup and Current Review Status

As summarized in Table 3, Kairos provided supplemental informat ion to respond to RCIs and to close out those audit information needs requiring that particul ar information be submitted to the docket. By letter dated April 22, 2022, Kairos provided their r esponse to the staffs RCIs (ML2215A204). On April 27, 2022, Kairos provided two submission s to address certain air quality, noise and water resource items requiring information o n the docket (ML22117A215 and ML22117A218). The staff determined all information provided by Kairos to adequately close all information needed from the applicant to conduct their review.

The scoping comment period closed on April 19, 2022, and staff has completed its review of the public comments. To date, the staff has not identified any new information requiring additional

3 requests for information from Kairos. The draft EIS is currentl y on schedule to be issued on or before November 2022.

Table 3: Summary of Audit Information Need Resolution

Info Need ID Information Need Resolution

Site and Technical Overview Briefly outline the ownership history of the site, Closed Through STO-1 and indicate what if any easements or Audit Discussion encumbrances exist on the site property Show estimated, approximate routes for any new utilities that would be constructed, such as sewer lines and incoming electric distribution lines. Note Closed Through STO-2 that section 6.2.1 states that construction would Audit Discussion include "the installation of water and sewer lines that connect the facility to the City of Oak Ridge water supply system."

Cumulative Impacts Closed Through Please provide rough bounding information on Request for CMLT-1 the location and land and water needs for the Confirmatory Fuel Fabrication Facility. Information (RCI #18)

ML22115A204 CMLT-2 Please provide a bounding estimate on the years Closed Through of operation of the Fuel Fabrication Facility. Audit Discussion

Land Use and Visual Resources

The ER does not provide information on the zoning of the site. Indicate the zoning established Closed Through by the City of Oak Ridge for the site. The City Request for LU-1 zoning map indicates IND-2, but the zoning Confirmatory ordinance indicates that industrial facilities Information (RCI #1) handling radioactive materials require IND-3 ML22115A204 zoning. Clarification needed.

Figure 3.7-3 on page 3-145 shows an undeveloped right-of-way-like extension of the LU-2 site proceeding southwest from the site to the Closed Through Clinch River arm of Watts Bar Reservoir. This Audit Discussion extension of the site does not appear on other site maps. Clarification needed.

LU-3 Demonstrate that the proposed facilities would Closed Through not penetrate the air spaces identified as having Request for

4 Info Need ID Information Need Resolution

to be free of flight obstructions for the proposed Confirmatory City of Oak Ridge Airport to the south. Information (RCI #2)

ML22115A204 Page 3-77, figure 3.4-2: Should 2 percent Annual Closed Through LU-4 Chance Flood Hazard be 0.2 % percent Annual Audit Discussion Chance Flood Hazard?

Air Quality and Noise Section 3.2.6, p.3-20 states that the nearest Closed Through Post AQN-1 resident is approximately 0.7 mi north of the site; Audit Submittal by but section 4.2.2, p. 4-18 states that the nearest Kairos residence is 1.25 mi away. Clarification needed. (ML22117A218)

Provide additional details as to how the noise Closed Through Post AQN-2 attenuation data in table 4.2-3 were calculated. Audit Submittal by Did the calculations assume leaf-on or leaf-off Kairos conditions? (ML22117A218)

Provide air emission estimates for each criteria pollutant for the construction phase and the operation phase of the project. Provide a Closed Through Post description of the assumptions used to determine Audit Submittal by AQN-3 the estimates (i.e., hours use of differing Kairos equipment during construction). In addition, (ML22117A218) provide the total emission estimate for hazardous air pollutants for both the construction and operation phases of the project.

Water Resources and Hydrogeology As no offsite disposal is planned, please describe any change in the site grade, drainage, or topography as a result of the onsite use of Closed Through excess excavated soil that would have formerly Request for occupied the space of subgrade building Confirmatory HYD-01 structures and foundations, measures or best Information (RCI #3) practices to account for the potential exposure to ML22115A204 contaminated soils and any anticipated coordination with DOE for soil excavation activities.

In section 4.13.3, the ER indicates that "Table 4.13-1 identifies recent past, present, and reasonably foreseeable future actions within the Closed Through Post geographic extent of analysis that can be Audit Submittal by HYD-02 assessed to determine cumulative effects on the Kairos geologic environment." Yet, the geologic (ML22117A218) environment is not listed as a "Potentially Affected Resource(s)" in this table. Please

5 Info Need ID Information Need Resolution

explain how the Geologic Environment in section 4.13.3 was evaluated for recent, past, present and reasonably foreseeable future actions, including anticipated fuel fabrication facility that is planned to be built adjacent to the reactor given the lack of mention the Geologic Environment in table 4.13-1.

Clarify the apparent variability of subsurface stratigraphy between ER section 3.3.3.1, ER figure 3.3-3 and PSAR figure 2.5-3 in the area Closed Through HYD-03 crossing the former K-33 site with respect to the Audit Discussion clay profile, associated depths to bottom of clay and the position the Oma (Mascot Dolomite) stratigraphy.

Please define and clarify any implications of the HYD-04 "TVA Flowage Easements" shown in figure 3.4-2 Closed Through adjacent to the reactor facility to anticipated land Audit Discussion use, hydrological resources, and development.

Please explain what is meant by the "...final Closed Through HYD-05 decision on the K-31/K-33 Area groundwater..." Audit Discussion as described in section 3.4.1.2.

Section 3.5.5.3 indicates that the K-901 Holding Closed Through HYD-06 Pond is shown in figure 2.2-1; however, there is Audit Discussion no pond labeled as the K901 Holding Pond.

In section 3.7.2.5, please clarify what constitutes "wet weather" and the frequency of these periods when Rarity Ridge WWTP operates at peak capacity and explain the ability of the Rarity Ridge WWTP to treat the estimated 0.02 MGD of facility wastewater during these periods and any associated potential indirect or direct impacts.

Also, please provide a reference for the Closed Through HYD-07 statement "...the plant is under evaluation for Audit Discussion future growth." and, in section 5.2, a reference for what measures that the city is currently working towards reducing inflow and infiltration coming into the plant." Describe any agreements with Rarity Ridge WWTP for accepting wastewater from the planned facility with respect to anticipated construction and operation dates of the proposed Kairos facility.

Clarify if the estimated facility water use is "44 HYD-08 gpm (0.06 MGD)" as described in ER section Closed Through 3.4.2.3 or "0.07 million gallons per day" as Audit Discussion described in ER section 4.4.2.

6 Info Need ID Information Need Resolution

Describe the potential for new underground (wastewater, utility lines, etc.) utilities to act as Closed Through HYD-09 groundwater sinks or sources as described in ER Audit Discussion section 3.4.1.2 and any anticipated monitoring plan provisions.

Based on the discussion in ER section 3.4.2.3, please clarify the intended source of Fire Suppression System's water supply for infrequent use (3,170 gpm/4.56 MGD) including the make-up supply (793 gpm/1.14 MDG) and the Closed Through approximate periods between refills with respect Request for HYD-10 to the capacity of the municipal system. Please Confirmatory confirm that the fire protection system (ER Information (RCI #4) section 2.4.1) and the fire suppression system ML22115A204 (ER section 3.4.2.3) are one in the same and clarify any discrepancies between the slightly different refill rates listed in section 2.4.1 and section 3.4.2.3.

As described in ER section 3.4.1.2.1, "Historically, building basement dewatering significantly altered the mapped potentiometric surface in the areas of the ETTP." and related to dewatering discussion in ER section 4.3.2 and Closed Through section 4.5.1.2, provide an approximate bounding Request for HYD-11 estimate of dewatering rates during the duration Confirmatory of construction, plant operation and Information (RCI #5) decommissioning. If dewatering is planned, ML22115A204 please describe the anticipating dispositioning of the any water volumes including any anticipated DOE consultations to manage the water and, anticipated alterations to the groundwater flow field due to dewatering during operations.

Section 4.8.1.7 states that specific environmental monitoring of non-radiological constituents would be determined through the permitting process.

Section 4.4.4 indicates that"..., no non-Closed Through radiological groundwater monitoring activities are Request for HYD-12 planned for the site." Please clarify permitting Confirmatory requirements for monitoring non-radiological Information (RCI #6) constituents and any apparent inconsistencies ML22115A204 between the statements in section 4.8.1.7 and section 4.4.4 and the disposition of DOE's continuing monitoring program for the K-31/K-33 area.

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Ecological Resources

Page 1-3 of ER states that an onsite field delineation of wetlands and other waters of the ECO-1 United States was conducted on the site. But the Closed Through information presented in section 3.5.6 is Audit Discussion referenced to a 1994 DOE study. Clarification needed.

Indicate the references(s) for the unreferenced Closed Through ECO-2 descriptive information in sections 3.5.7.1 and Audit Discussion 3.5.7.2.

Page 3-92, section 3.5.7.2.2 (Birds) states that a ECO-3 field survey was conducted of the site in June Closed Through 2021. Provide a brief explanation of the Audit Discussion procedures and observations of that survey.

Page 3-92, section 3.5.7.2.2 (Birds) states that a field survey was conducted of the site in June Closed Through ECO-4 2021. Also, table 1.4-2 states that a field survey Audit Discussion identified no eagle nests in the vicinity of the site.

Provide a copy of that survey.

Provide a copy of the IPaC search results forming the basis of section 3.5.11. Also, table Closed Through ECO-5 1.4-2 on page 1-8 states that the applicant has Audit Discussion developed a biological assessment. If so, provide a copy of that biological assessment.

Page 3-101 section 3.5.11.4 states that bald eagles are not known to nest or forage on or Closed Through ECO-6 adjacent to site. Provide basis for this statement. Audit Discussion How can we know that bald eagles are not present in forests around perimeter of site?

Page 4-35, section 4.5.1.5 (Protected Species) states that no suitable [Indiana] bat trees were Closed Through ECO-7 observed in the undisturbed riparian corridor Audit Discussion adjacent to the site. Indicate the basis for this statement.

Page 4-37, section 4.5.2.5 states that no federal or state-listed threatened, endangered or special ECO-8 status plant species have been observed on or in Closed Through the immediate vicinity of the site. Provide the Audit Discussion basis for this statement. Can you quantify what constitutes the "immediate area?"

Please explain why the temporary and Closed Through ECO-9 permanent impact acreages for Audit Discussion herbaceous/grassland impacts in table 4.5-1 total

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88 ac when the table states that the total acreage of that habitat is only 72 ac.

Page 4-33, section 4.5.1.2 states that "Groundwater removed during construction for Closed Through dewatering [of the reactor building excavation] Request for ECO-10 will be properly managed as discussed in section Confirmatory 4.4.1.1.1, That section just states that Kairos Information (RCI #7) would consult with DOE and follow DOE's ML22115A204 recommendations. Please provide more details on how that water would be managed.

Roughly bound the quantity of groundwater that Closed Through might have to be dewatered to excavate for Request for ECO-11 construction of the reactor. Confirmatory Information (RCI #8)

ML22115A204 Page 4-33 section 4.5.1.2 states that stormwater would flow to a stormwater pond and then be ECO-12 discharged to Poplar Creek. Indicate the location Closed Through of the proposed discharge. Page 2-15 states that Audit Discussion Kairos assumes that the stormwater discharge would use an existing outfall.

Cultural and Historical Resources Provide a knowledgeable expert to discuss the historic and cultural resource investigations conducted on or near the proposed project site, HCUL-1 and historic and cultural resources described in Closed Through section 3.6.2. Staff would also like to discuss Audit Discussion potential impacts to historic and cultural resources from the proposed action as they are currently understood and as described in the ER.

In ER table 1.4-1, there is a table entry for Tennessee Department of Transportation HCUL-2 (TDOT) that states that there would be Closed Through construction of a driveway connection to Hwy 58. Audit Discussion Is this land previously disturbed and has it been surveyed for historic and cultural resources?

In ER section 1.4, states that Kairos (in addition to the formal consultations listed in table 1.4-2),

made informal contacts with the National Nuclear HCUL-3 Security Administration, the Bureau of Indian Closed Through Affairs, the Tennessee Department of Audit Discussion Environment and Conservation, the TDOT, and the City of Oak Ridge. The stated purpose was to inform the agencies about the project and to

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coordinate project planning. Provide a summary of any interactions related to historic and cultural resources as well as any applicable correspondence.

In ER table 1.4-2 Consultations Required for Construction and Operation and ER Section 3.6.4 - Did Kairos engage the Tennessee Historical Commission, Tennessee Division of Closed Through HCUL-4 Archaeology, Native American Nations, DOE, or Audit Discussion the National Park Service while developing its application for this proposed action? If so, provide a summary of any interactions as well as any applicable correspondence.

Provide a knowledgeable expert to discuss DOE-OREM's NEPA and NHPA section 106 consultation and review activities associated with the land transfer to Community Reuse Organization of East Tennessee. ER table 1.4-2 provides a list of statutes that guide required consultations. With respect to Native American Nations, the table lists the Native American Grave Protection and Repatriation Act as one of the applicable statutes. Additionally, in ER section 4.6.1, it states to minimize impacts to historic and cultural resources, Kairos would develop an Archaeological Monitoring and Discovery plan that would specify procedures for addressing and handling the unexpected Closed Through discovery of human remains or archaeological Request for HCUL-5 material during construction. It states that if Confirmatory human remains are discovered, construction Information (RCI #9 personnel will notify a representative of Kairos, and RCI #10) and that representative will contact appropriate ML22115A204 local law enforcement and the DOE historic preservation officer. DOE's 2011 EA (DOE/EA-1640), section 3.6.2.1, states that inadvertent discovery and notification provisions would be contained within lease and/or deed restrictions.

Similarly, the 2017 Quitclaim Deed for the Former K-33 Site includes lease and/or deed restrictions regarding the protection of historic and/or archaeological resources. Since the lands are no longer considered Federal property, provide a summary response to confirm if federal land management requirements still apply as part of any existing lease and/or deed restrictions with respect to the inadvertent discovery and

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protection of historic and cultural resources (such as ARPA and NAGPRA). Provide a summary response to describe any stipulations that Kairos Power must abide with.

In ER section 4.6.1 - Provide a status update on the development of the Archaeological Monitoring and Discovery plan along with any training material that will be used with Closed Through construction personnel regarding the Request for HCUL-6 identification of historic and cultural resources. Confirmatory Will this procedure be developed with input from Information (RCI #11) the Tennessee Historical Commission, ML22115A204 Tennessee Division of Archaeology, or DOE?

Would the plant incorporate any existing DOE-OREM guidance?

In ER section 3.6: DOE-OREM executed several Memorandum of Agreements (MOAs) with respect to the decontamination and decommissioning activities and mitigation of adverse effects to historic properties associated with the K-25 site and East Tennessee HCUL-7 Technology Park (ETTP). In reviewing the 2012 Closed Through final MOA, Execution Plan, and final Mitigation Audit Discussion Plan for the interpretation of historical properties at ETTP (2012 MOA), and the July 31, 2019 amendment, is the Kairos Hermes project located outside the bounds of the K-25 Preservation Footprint Viewshed (see Stipulation 3 of 2019 Amendment)?

In ER section 3.6.2 summarizes previous cultural resource investigations (archaeological and architectural) conducted on and in the vicinity of the ORR since the 1970. Did any of the referenced surveys occur within or overlap with the 185-acre proposed project area? Additionally, in DOE's Environmental Assessment prepared Closed Through HCUL-8 for the Transfer of Land and Facilities within the Audit Discussion ETTP and Surrounding Area, Oak Ridge, Tennessee (DOE/EA-1640), it discusses the location of four National Register of Historic Places -eligible prehistoric archaeological sites in the EA study area. Staff would like to discuss where these sites are in relation to the proposed Kairos site.

HCUL-9 Please make available copies of references listed Closed Through in section 3.6.5 of the ER in the reading room. Audit Discussion

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In ER section 4.6.1, it states that the nearest listed NRHP property is the K-25 Gaseous Diffusion Plant which is part of the Manhattan Project National Park. The ER states that "given the intervening structures between the Closed Through Post site and the K-25 Plant as well as the low profile Audit Submittal by HCUL-10 of the proposed structures on the site, no visual Kairos or other indirect impacts occur." Please describe (ML22117A215) or discuss any architectural surveys conducted for the proposed project to assess indirect (i.e.,

visual) effects to other historic and cultural resources (i.e., historic properties) within the viewshed/indirect effects APE?

Human Health: Non-Radiological

Provide a quantitative bound on what constitutes HHN-1 the "insignificant volumes" of nonradioactive Closed Through liquid chemical wastes to be generated, as stated Audit Discussion on page 4-51.

Provide information on the type and height of Closed Through HHN-2 perimeter fencing and signage to be built around Audit Discussion the proposed facilities.

Provide subject matter expert(s) to discuss chemical hazards regarding the FLiBe salt to be used in the Hermes test reactor. Due to the hazardous nature of beryllium, especially concerning airborne particulates, the staff needs to understand how this beryllium-bearing material will be controlled and monitored for potential beryllium exposure. PSAR section 1.2.1 states "Flibe coolant, while chemically stable, contains potentially toxic constituents including beryllium.

HHN-3 The reactor building and ventilation system Closed Through function as a confinement to manage and control Audit Discussion beryllium hazards..." PSAR section 4.4.1 states "In addition, the biological shield reduces radiation damage to plant equipment and also reduces the potential for Beryllium exposure to reactor personnel." PSAR section 9.2.2 states "In addition, the RBHVAC system ensures that chemical hazards (such as Beryllium) are within applicable limits." However, the ER has no similar discussion regarding occupational and public safety with respect to beryllium.

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Provide the basis for the statement in section 4.8.1.6 that "the facility design and practices Closed Through HHN-4 would ensure compliance with storage Audit Discussion requirements and limit exposures." What practices would be taken to "limit exposures"?

Section 4.8.1.7 states that specific environmental monitoring of non-radiological constituents would HHN-5 be determined through the permitting process. Closed Through Please provide a brief description of what Audit Discussion monitoring activities (if any) might be required in the permits.

Human Health - Radiological Provide a list of the specific radionuclides and Closed Through annual radiological effluents Request for HHR-1 amounts/concentrations applied as input Confirmatory parameter values in the NRCDose calculations. Information (RCI #12)

ML22115A204 Provide in a location accessible by the staff for HHR-2 audit review the NRCDose input and output files Closed Through (i.e., for both XOQDOQ and GASPAR II) for staff Audit Discussion inspection.

Provide subject matter expert(s) to discuss the details of the NRCDose calculations and results Closed Through HHR-3 presented in section 4.8 of the ER and to explain Audit Discussion why table 4.8-3 TEDE values do not include contributions from tritium.

Provide subject matter expert(s) to discuss the Closed Through HHR-4 use of ORR Tower L meteorological data for Audit Discussion NRCDOSE calculations.

Provide a subject matter expert(s) to discuss Closed Through HHR-5 radiological liquid discharges, such as its Audit Discussion sources, collection, and disposal.

Provide a subject matter expert(s) to discuss the Closed Through HHR-6 radiological environmental monitoring of ER Audit Discussion section 4.8.3, Radiological Monitoring.

Make available for staff review the following ER section 3.8 references (Note: if not listed below, then the references were accessible): 1) Ref # 12

- U.S. Department of Energy, "Environmental Closed Through HHR-7 Baseline Survey Report for the Proposed Title Audit Discussion Transfer of the Former K-33 Area at the East Tennessee Technology Park, Oak Ridge, Tennessee." DOE/OR/01-2658. September 2015. 2) Ref # 13 - U.S. Department of Energy,

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"Environmental Baseline Survey Report for the Proposed Title Transfer of the Former K-31 Area at the East Tennessee Technology Park, Oak Ridge, Tennessee." DOE/OR/01-2677. July 2015. 3) Ref # 16-16. Bureau of Labor and Statistics, Hours-based fatal injury rates by industry, occupation, and selected demographic characteristics, Website: [missing hyperlink to website]

Provide information and subject matter expert(s)

HHR-8 to discuss the text in ER section 4.13.8 where the Closed Through Kairos Power Nuclear Fuel Fabrication Facility is Audit Discussion mentioned as a future project.

Fuel Cycle and Radiological Waste Management

Provide subject matter expert(s) to discuss FCRW-1 Kairos's source for HALEU material and the Closed Through related front end fuel cycle process with respect Audit Discussion to table S-3.

Provide subject matter expert(s) to discuss the statement in section 2.7.1: "A manufacturer has FCRW-2 not been decided for the Hermes reactor" and the Closed Through status of developing a Kairos-specific TRISO fuel Audit Discussion fabrication process including sources of HALEU material.

Provide subject matter expert(s) to discuss the use of the Continued Storage Generic Environmental Impact Statement, NUREG-2157 and, as presented in ER section 4.9.1.2, on the expected long-term storage performance of the Closed Through FCRW-3 TRISO coatings (e.g., "degradation rates for Audit Discussion storage systems associated with continued storage of TRISO fuel") based on available supporting data of prior TRISO fuels (e.g., Fort St Vrain reactor and the German pebble bed research reactor).

Provide information and subject matter expert(s) to discuss what is to be done with the spent FCRW-4 TRISO fuel once the facility is decommissioned, Closed Through such as to whether the facility footprint includes a Audit Discussion place for a dry storage facility during or after the cessation of operations.

Provide information and subject matter expert(s) Closed Through FCRW-5 to discuss the disposal of nitrate salt during Audit Discussion decommissioning to include the quantity of

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material and the rational for disposing as either class A or B LLRW.

Provide information and subject matter expert(s) Closed Through to discuss the disposal of tritium-bearing material Request for FCRW-6 used to capture tritium gas by the Tritium Confirmatory Management System (ER section 2.6.1.2.3). Information (RCI #13)

ML22115A204 Provide information and subject matter expert(s) to discuss the storage and disposal of solidified FLiBe salt with respect to: 1) possible off-gassing of florine (due to radiation decomposition) or the release of tritium during long-term storage, 2) the quantity to be disposed of during Closed Through decommissioning, 3) how this waste could be Request for FCRW-7 class C LLRW per 10 CFR 61.55 since there is Confirmatory no limits established for tritium in class B or C Information (RCI #14) wastes under table 2 of ML22115A204 10 CFR 61.55(a)(4), and 4) to confirm that the chemical form of this waste, outside of its radiological content, would meet all acceptance criteria for disposal at WCS (i.e., WCS would accept this waste stream).

Provide subject matter expert(s) to discuss the justification for the statement in ER section 2.6.1.3 that "[t]he facility is not expected to need Closed Through FCRW-8 a gaseous radioactive waste system." given that Audit Discussion is later noted releases will be controlled and a detailed radiological effluent release dose analysis is provided in ER section 4.8.

Provide a subject matter expert(s) to discuss the estimated table 2.6-1 volume of dry active waste (i.e., LLRW) in comparison to the typical annual Closed Through FCRW-9 amount produced by a PWR as described in Rev Audit Discussion 1 of NUREG-1437 section 3.11.1.1 on page 3-154 and to confirm how the approximately 8,800 ft3 per year was determined.

Transportation of Radioactive Material Provide information and subject matter expert(s) Closed Through to discuss the transportation of spent TRISO fuel Request for TR-1 including how TRISO fuel may or may not be Confirmatory bounded by previously analyzed scenarios Information (RCI #15) related to LLWR fuel. ML22115A204 TR-2 Provide subject matter expert(s) to discuss non-Closed Through radiological impacts that would result from an Audit Discussion

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accident involving the shipment of radioactive material including if or how the scenario would be bounded by previously analyzed scenarios for LLWR fuel.

Provide expected radionuclide activity levels Closed Through (especially for tritium) and disposal acceptance Request for TR-3 levels and subject matter expert(s) to discuss the Confirmatory shipment and disposal of this material at the Information (RCI #16) various commercial LLRW disposal sites. ML22115A204 Provide for staff review the following ER section 4.10.4 references: 1) Ref # 9 - Kairos Power LLC, 2021. Flibe Safety Data Sheet. Issued April Closed Through TR-4 2, 2021. 2) Ref # 10 - SQM, 2014. Sodium Audit Discussion Nitrate Safety Data Sheet. Issued January 2014.

3) Ref # 11 - SQM, 2015. Potassium Nitrate Safety Data Sheet. Issued March 2015

Accidents Provide subject matter expert(s) to discuss the Closed Through information and the results presented in section Request for ACC-1 4.11 of the ER, the related offsite accident Confirmatory consequences concerning the MHA, and the Information (RCI #17) potential for mitigation. ML22115A204 Provide the MHA release source term that Closed Through ACC-2 resulted in the dose consequences presented in Audit Discussion ER table 4.11-1.

Alternatives Provide a map (or a description) showing the Closed Through locations of Potential Sites 1.1 and 1.3 Request for ALT-1 Confirmatory Information (RCI #19)

ML22115A204 Provide maps (preferably as overlays on aerial photographs or topographic maps) clearly indicating the shapes and sizes of the Proposed Closed Through Eagle Rock Site and Proposed Eagle Rock Request for ALT-2 Property (as shown on figure 5.4-3 on page 5-Confirmatory 48). Indicate the approximate size of each. Can Information (RCI #20) you indicate where in the Proposed Eagle Rock ML22115A204 Site where the proposed test reactors would be built under this alternative, or can you indicate that they could be built anywhere within the site.

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Section 5.4.1.4. Indicate how water needs of the Closed Through proposed test reactor would be met, and how the Request for ALT-3 wastewater would be treated, if the proposed test Confirmatory reactor were to be built at the Eagle Rock Site. Information (RCI #21)

ML22115A204 Provide a copy of the IPaC search results for the Closed Through Eagle Rock site. Request for ALT-4 Confirmatory Information (RCI #22)

ML22115A204 Referring to figure 5.4-5 "Vegetation Types of the Proposed Eagle Rock Site" - explain what is Closed Through ALT-5 meant by the "Bird Point Survey Locations" and Audit Discussion the "Vegetation Transect Locations". What surveys are these a part of?

Table 4. Attendee List for Environmental Audit Close Out Meeti ng, March 30, 2022

Name Affiliation

Dozier, Tami U.S. Nuclear Regulatory Agency (NRC)

Davis, Jennifer NRC Palmrose, Donald NRC Doub, Peyton NRC Glowacki, Brian NRC Willingham, Laura NRC Giacinto, Joseph NRC Miller, Ed NRC Wilkins, Lynnea NRC Marty Bryan Kairos Power, LLC (Kairos)

Austin Clark Kairos Darrell Gardner Kairos Wayne Massie Kairos Peter Hastings Kairos Taylor, Kevin AECOM Freeman, Carol L B AECOM Bergman, Jana member of the public Matis, Lisa Tetra Tech Steven Pope member of the public Generette, Lloyd U.S. Environmental Protection Agency Michelle Byman member of the public Erin Wisler member of the public

17 Rani Franovich The Breakthrough Institute Adam Stein The Breakthrough Institute

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