ML22006A334
| ML22006A334 | |
| Person / Time | |
|---|---|
| Site: | 99902069 |
| Issue date: | 02/24/2022 |
| From: | Cuadrado S NRC/NRR/DANU/UARL |
| To: | William Kennedy NRC/NRR/DANU/UARL |
| Cuadrado S; 301-415-2946 | |
| References | |
| Download: ML22006A334 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 24, 2022 MEMORANDUM TO:
William B. Kennedy, Acting Chief Advanced Reactor Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation FROM:
Samuel Cuadrado, Project Manager Advanced Reactor Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
SUBJECT:
REPORT ON THE REGULATORY AUDIT OF KAIROS POWER LLC HERMES CONSTRUCTION PERMIT PRELIMINARY SAFETY ANALYSIS REPORT Kairos Power LLC (Kairos) began pre-application discussions with the U.S. Nuclear Regulatory (NRC) staff on their Kairos Power Fluoride-Salt-Cooled, High-Temperature Reactor (KP-FHR) in October 2018. Prior to submitting the Hermes test reactor construction permit (CP) preliminary safety analysis report (PSAR), the NRC staff audited a pre-submittal version of the PSAR to assess any potential gaps relative to the applicable regulations and NRC staff guidance, identify regulatory or technical issues which may complicate the review, and enhance staff knowledge of the Hermes design.
The audit plan is provided in the NRCs Agencywide Documents Access and Management System (ADAMS) under Accession No. ML21218A045, and the audit was conducted during the months of August and September 2021 at NRC Headquarters via the Kairos Power, LLC electronic reading room.
Project No. 99902069
Enclosure:
Audit Report CONTACT: Samuel Cuadrado, NRR/DANU 301-415-2946 Signed by Cuadrado de Jesu on 02/24/22
W. Kennedy
SUBJECT:
REPORT ON THE REGULATORY AUDIT OF KAIROS POWER LLC HERMES CONSTRUCTION PERMIT PRELIMINARY SAFETY ANALYSIS REPORT DATED: FEBRUARY 24, 2022 DISTRIBUTION:
PUBLIC RidsOgcMailCenter RidsAcrs_MailCTR RidsNrrDanuUarl RidsNrrDanu RidsNrrDexEICA JSchmidt, NRR BBeasley, NRR RRivera, NRR SCuadrado, NRR ADAMS Accession Number: ML22006A334 NRR-106 OFFICE NRR/DANU/UARL:PM NRR/DORL/LPL3:LA NRR/DANU/UTB2:BC NAME SCuadrado SLent SPhilpott DATE 01/10/2022 02/11/2022 02/15/2022 OFFICE NRR/DANU/UARL:BC NRR/DANU/UARL:PM NAME WKennedy SCuadrado DATE 02/18/2022 02/24/2022 OFFICIAL RECORD COPY
Enclosure KAIROS POWER, LLC
SUMMARY
REPORT ON THE REGULATORY AUDIT OF KAIROS POWER LLC HERMES CONSTRUCTION PERMIT PRELIMINARY SAFETY ANALYSIS REPORT August - September 2021
1.0 BACKGROUND
AND PURPOSE Kairos Power LLC (Kairos, the applicant) began pre-application discussions with the U.S.
Nuclear Regulatory Commission (NRC) staff on their Kairos Power Fluoride-Salt-Cooled, High-Temperature Reactor (KP-FHR) in October 2018. In December of 2020, Kairos announced that the Hermes test reactor would be used to support future development of the KP-FHR. Over the past several years, Kairos has submitted several topical and technical reports that apply to both the Hermes, as well as the full-scale KP-FHR reactor. As discussed in meetings held on January 27, 2021 and March 3, 2021, Kairos planned to submit an application for a construction permit (CP), including a preliminary safety analysis report (PSAR), for the Hermes test reactor in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic licensing of production and utilization facilities. At the time of these meetings and this audit the PSAR was expected to follow the guidance in NUREG-1537, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Format and Content (Agencywide Documents Access and Management System (ADAMS) Accession No. ML042430055).
After the conclusion of this audit, by letter dated September 29, 2021 (ADAMS Accession Number (No.) ML21272A375), Kairos submitted the Hermes test reactor CP application and PSAR. The NRC staff accepted the Hermes test reactor CP application by letter dated November 29, 2021 (ADAMS Accession No. ML21319A354), and is currently performing its review of the application and respective PSAR.
2.0 AUDIT REGULATORY BASES The bases for the audit are the regulations in 10 CFR Part 50, Sections 50.34(a), Preliminary safety analysis report, 50.35, Issuance of construction permits, 50.40(a), Common Standards, and NUREG-1537, Part 1 Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Format and Content.
3.0 AUDIT OBJECTIVES The audit team audited parts of the pre-submittal PSAR to identify potential gaps relative to the applicable regulations and NRC staff guidance, identify regulatory or technical issues which may complicate the review, and enhance staff knowledge of the Hermes design.
4.0 SCOPE OF THE AUDIT AND AUDIT ACTIVITIES The audit was conducted during the months of August and September 2021, at NRC Headquarters via the Kairos electronic reading room. The NRC staff conducted the audit in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction NRR-LIC-111, Revision 1, Regulatory Audits.
2 Members of the audit team, listed below, were selected based on their detailed knowledge of the subject. Audit team members included:
Jeff Schmidt Sr. Reactor Systems Engineer Tim Lupold Sr. Mechanical Engineer Alex Siwy Nuclear Engineer Ben Adams Nuclear Engineer Michelle Hart Sr. Reactor Engineer Alexander Chereskin Material Engineer Margaret Audrain Material Engineer Imtiaz Madni Sr. Reactor Systems Engineer Ken Mott Emergency Preparedness Specialist Khoi Nguyen Electrical Engineer Sheila Ray Sr. Electrical Engineer David Heeszel Geophysicist Yuan Cheng Hydrologist Jason White Meteorologist Amitava Ghosh Geotechnical Engineer Joe Ashcraft Electronics Engineer Suzanne Ani Material Control and Accounting Physical Scientist Odunayo Ayegbusi Reactor Operations Engineer Michael Takacs Security Specialist, Research and Test Reactors William Schuster Reactor Inspector, Research and Test Reactors Stewart Magruder Sr. Project Manager Samuel Cuadrado Project Manager Richie Rivera Project Manager Ed Helvenston Project Manager, Research and Test Reactors The NRC staff audited parts of the following documents:
Kairos Hermes PSAR Chapters 1-18 5.0
SUMMARY
OF OBSERVATIONS The NRC staffs summary of observations listed below is based on the notes taken by the staff during the audit. The NRC staff did not acquire any documents during the audit. The main purpose of the audit was to identify issues which could challenge potential acceptance of the PSAR when submitted and highly challenging regulatory or technical issues which may need additional documentation. In particular, the NRC staff noted:
The NRC staff observed that additional information in PSAR Chapter 11, Radiation Protection Program and Waste Management, would be needed for the staff to make a reasonable assurance finding that the design will comply with 10 CFR Part 20 dose requirements. The NRC staffs observation was based on 10 CFR 50.40(a), Common Standards, which states, Except for an early site permit or manufacturing license, the processes to be performed, the operating procedures, the facility and equipment, the use of the facility, and other technical specifications, or the proposals, in regard to any of the foregoing collectively provide reasonable assurance that the applicant will comply with the regulations in this chapter, including the regulations in part 20 of this chapter
[emphasis added], and that the health and safety of the public will not be endangered.
This regulation applies to a CP, as well as other licensing actions. The NRC staff noted
3 that no design information and/or sample calculations were provided to support a reasonable assurance finding that the design would comply with 10 CFR Part 20. The NRC staff informed Kairos of this concern on September 27, 2021.
The NRC staff noted that the pre-submittal PSAR contains little information on the materials or chemical control of nonsafety-related systems that could interact with safety-related systems. Regulations in 10 CFR 50.34(a)(3)(iii) state, Information relative to materials of construction, general arrangement, and approximate dimensions, sufficient to provide reasonable assurance that the final design will conform to the design bases with adequate margin for safety. The NRC staff does not consider this lack of information a potential acceptance review issue but may seek additional information regarding nonsafety-related system material selection and chemical control strategies to ensure an adequate margin of safety is preserved.
6.0 EXIT BRIEFING The NRC staff conducted an audit closeout meeting on September 27, 2021. At the exit briefing the NRC staff reiterated the purpose of the audit and discussed their activities. As noted above, the applicant was made aware of a potential issue with regard to Chapter 11 content on September 27, 2021.
7.0 REQUESTS FOR ADDITIONAL INFORMATION RESULTING FROM AUDIT The formal request for additional information (RAI) process was not used as part of this audit.
The staff provided Kairos several questions during the audit, which Kairos could consider and use to revise the PSAR prior to submittal.
8.0 OPEN ITEMS AND PROPOSED CLOSURE PATHS Not applicable. There were no open items or deviations from the audit plan.