Nuclear Regulatory Commission Evolves Environmental Review for Hermes Test Reactor, Yet Opportunities for Improvement Remain

On November 16, 2022, Rani Franovich, a Senior Policy Advisor for Nuclear Energy Innovation at the Breakthrough Institute (BTI), attended a public meeting in Oak Ridge, TN, and presented a comment (see transcript pp. 33-41) on the NRC’s Draft EIS. Franovich had previously commented on the scope of the environmental review, urging the NRC staff to consider the environmental impacts of the Hermes test reactor relative to alternative forms of energy production and the benefits of the project “as a vital step forward to proving the safety and security of commercial deployment of larger-scale reactors of its design.” (See transcript pp. 57-60)

On December 5, 2022, BTI submitted a more detailed written comment commending the NRC staff on its timely publication of the Draft EIS and its finding that near-term costs were outweighed by the following long-term benefits:

• Operation of the Hermes test facility could help demonstrate the commercial viability of the technology and generate useful data for commercial deployment.
• Successful demonstration could lead to large-scale deployment of another economically viable source of energy vital to meeting National climate change objectives.
• Use of the technology may help the U.S. meet its climate change goals with less reliance on more land-intensive energy generation (e.g., large solar or wind) that has a more negative aesthetic impact on landscapes and seascapes and greater potential to harm wildlife. (Comment p. 4)

Notwithstanding these positive steps toward modernizing its environmental reviews, BTI offered areas for improvement and encouraged the NRC to:

• prepare [Environmental Assessments] in lieu of EISs to the maximum extent possible for non-major Federal actions involving the construction, operation, and decommissioning of test reactors and their larger-scale commercial reactors;
• make maximum use of the [Generic] EIS for advanced reactors when a licensing decision clearly constitutes a major Federal action;
• more fully and directly examine and characterize the economic benefits of the proposed action; and
• acknowledge and holistically consider the substantial adverse environmental and human health impacts of taking no Federal action. (Comment p. 6)