ML19294A647
| ML19294A647 | |
| Person / Time | |
|---|---|
| Issue date: | 10/22/2019 |
| From: | Stewart Magruder NRC/NRR/DANU/UARL |
| To: | Benjamin Beasley NRC/NRR/DANU/UARL |
| Magruder S,NRR/DANU/UARL,348-5766 | |
| References | |
| Download: ML19294A647 (5) | |
Text
October 22, 2019 MEMORANDUM TO: Benjamin Beasley, Chief Advanced Reactor Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation FROM: Stewart Magruder, Senior Project Manager /RA/
Advanced Reactor Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
SUBJECT:
AUDIT PLAN FOR THE REGULATORY AUDIT OF KAIROS POWER LLC INSTRUMENTATION AND CONTROLS DESIGN Kairos Power LLC (Kairos) began pre-application discussions with the NRC staff on their Kairos Power Fluoride-Salt-Cooled, High-Temperature Reactor (KP-FHR) in October 2018. Over the past year, Kairos has submitted several topical and technical reports and has met with the NRC staff on numerous occasions. During these meetings, Kairos informed the NRC staff that they have begun work on the instrumentation and controls (I&C) portion of their design. This audit will allow the NRC staff to review documents that provide a high-level overview of the Kairos I&C approach.
The audit will take place at Kairos offices in Alameda, CA. The audit will be held on October 30, 2019. The contents of the audit plan are provided as an enclosure.
Enclosure:
Audit Plan CONTACT: Stewart Magruder, NRR/DANU/ARLB 301-348-5766
ML19294A647 OFFICE NRR/DANU/ARLB NRR/DEX/EICA NRR/DANU/ARLB NAME SMagruder JJohnston BBeasley DATE 10/22/2019 10/22/2019 10/22/2019 UNITED STATES NUCLEAR REGULATORY COMMISSION AUDIT PLAN FOR THE REGULATORY AUDIT OF KAIROS POWER LLC INSTRUMENTATION AND CONTROLS DESIGN PRE-APPLICANT: Kairos Power LLC DATE: October 30, 2019 LOCATION: Kairos Power LLC, 707 W Tower Ave. Alameda, CA A. Background and
Purpose:
Kairos Power LLC (Kairos) began pre-application discussions with the NRC staff on their Kairos Power Fluoride-Salt-Cooled, High-Temperature Reactor (KP-FHR) in October 2018. Over the past year, Kairos has submitted several topical and technical reports and has met with the NRC staff on numerous occasions. During these meetings, Kairos informed the NRC staff that they have begun work on the instrumentation and controls (I&C) portion of their design. This audit will allow the NRC staff to review documents that provide a high-level overview of the Kairos I&C approach.
B. Regulatory Audit Basis 10 CFR 50.34(a)(3)(i) requires in part that an applicant for a construction permit to build a power reactor provide principal design criteria for the facility. Similar regulatory requirements exist for design certification, combined license, and standard design approvals (10 CFR 52.47(a)(3)(i), 10 CFR 52.79(a)(4)(i), and 10 CFR 52.137(a)(3)(i), respectively).
General Design Criterion (GDC) 13, Instrumentation and control, requires that instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges. Although GDC 13 applies only to light water reactor (LWR) designs, the staff expects non-LWR designs to have a similar Principal Design Criteria (PDC). Kairos submitted their proposed PDC in a topical report on July 31, 2019 (ML19212A757).
The NRC staff will follow NRR Office Instruction NRR-LIC-111 (Revision 1), Regulatory Audits, (ADAMS Accession No. ML19226A274) in performing the audit of the information cited below.
Enclosure
C. Regulatory Audit Scope and Objectives Staff expects discussions will center on the following areas:
- Facility/Lab tour
- Reactor Protection System design overview
- Plant Control System design overview
- Health Monitoring System design overview
- Sensor Qualification plan
- Main Control Room concept
- Plan for Licensing Topical Reports and licensing reviews An early engagement with the applicant on the Kairos I&C design concepts will allow the NRC staff to gain understanding of the automations and credited manual operator actions (if any) needed for safe operation of the plant. As stated in GDC 13, safety function of the I&C systems is to monitor variables and systems over their anticipated ranges (from normal operation to accident conditions) to assure adequate safety through automatic and/or manual controls. Any diversity and defense-in-depth measures being considered for the I&C system design will also be discussed during this audit. Past reviews have shown that such early engagements aid the applicant in providing a thorough and essentially complete I&C system design in their application. Subsequently, this results in a safety-focused, risk-informed and an efficient staff review process.
D. Information and Other Material Necessary for the Regulatory Audit Staff expects discussions will center on the areas identified above in the Regulatory Audit Scope section, and documents pertaining to these areas are to be made available to the NRC staff, as applicable based on the discussion.
Other documents will be requested based on the progress of the staffs review.
Appropriate handling and protection of proprietary information shall be acknowledged and observed throughout the audit.
E. Audit Team The following are the NRC audit team members:
- 1. Joseph Ashcraft, Electronics Engineer (NRC)
- 2. Dinesh Taneja, Senior Electronics Engineer (NRC)
- 3. Dawnmathews Kalathiveettil, Electronics Engineer (NRC)
- 4. Benjamin Beasley, Branch Chief (NRC)
- 5. Stewart Magruder, Senior Project Manager (NRC)
The following are the Kairos contacts:
- 1. Darrell Gardner, Director, License Application
- 2. John Price, Project Manager 2
F. Logistics The NRC staff will address in the audit report the technical areas identified in the Regulatory Audit Scope of this audit plan along with presenting the audit outcomes.
The audit will be conducted in support of the pre-application interactions with Kairos, with an entrance and exit on October 30, 2019.
The NRC staff acknowledges the potential for the proprietary nature of some of the information requested. It will be handled appropriately throughout the audit. NRC staff will take notes that will be marked as proprietary and will not remove hard copies or copy electronic files.
G. Special Requests If necessary, any circumstances related to the performance of the audit will be communicated to the applicant.
H. Deliverables At the completion of the audit, the NRC staff will prepare an audit report within 45 days that will be declared and entered as an official agency record in ADAMS. The audit outcome may be used to identify any additional information to be submitted for making regulatory decisions.
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