ML23017A156

Preliminary Hermes CP SE Chapter 11, Radiation Protection and Waste Management for ACRS

ML23017A156
Person / Time
Site:	Hermes
Issue date:	01/10/2023
From:	Benjamin Beasley NRC/NRR/DANU/UAL1
To:	Advisory Committee on Reactor Safeguards
References
Download: ML23017A156 (1)

Text

11 RADIATION PROTECTION AND WASTE MANAGEMENT THIS NRC STAFF DRAFT SE HAS BEEN PREPARED AND IS BEING RELEASED TO SUPPORT INTERACTIONS WITH THE ACRS. THIS DRAFT SE HAS NOT BEEN SUBJECT TO FULL NRC MANAGEMENT AND LEGAL REVIEWS AND APPROVALS, AND ITS CONTENTS SHOULD NOT BE INTERPRETED AS OFFICIAL AGENCY POSITIONS.

The purposes of radiation protection and waste management programs and provisions are to ensure safety of a reactor facility and to provide protection to the facility staff, members of the public, and the environment.

This chapter of the Kairos Power, LLC (Kairos) Hermes test reactor construction permit safety evaluation report (SER) describes the U.S. Nuclear Regulatory Commission (NRC) staffs (the staffs) technical review and evaluation of the preliminary information on the Hermes radiation protection and waste management programs and design provisions as presented in Chapter 11, Radiation Protection and Waste Management, of the Hermes preliminary safety analysis report (PSAR), Revision XX. The staff reviewed PSAR Chapter 11 against applicable regulatory requirements using regulatory guidance and standards to assess the sufficiency of the preliminary information Kairos provided regarding Hermes facility radiation protection and waste management for the issuance of a construction permit in accordance with Title 10, Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities. As part of this review, the staff evaluated descriptions and discussions of Hermes radiation protection and waste management programs and provisions, with special attention to design and operating characteristics, unusual or novel design features, and principal safety considerations. The staff evaluated the preliminary design of the Hermes facility radiation protection program and waste management provisions to ensure the design criteria, design bases, and information relative to construction is sufficient to provide reasonable assurance that the final design will conform to the design basis. In addition, the staff reviewed Kaiross identification and justification for the selection of those variables, conditions, or other items which are determined to be probable subjects of technical specifications for the facility, with special attention given to those items which may significantly influence the final design.

The staffs reviews and evaluations for areas relevant to PSAR Chapter 11, including regulations and guidance used, summaries of the application information reviewed, and evaluation findings and conclusions, are discussed in the SER sections below for each of the two major areas of review (radiation protection and waste management) covered in this SER chapter. A summary and overall conclusions on the staffs technical evaluation of Hermes radiation protection and waste management are provided in SER Section 11.3, Summary and Conclusions on Radiation Protection and Waste Management.

11.1 Radiation Protection Introduction Hermes PSAR Section 11.1, Radiation Protection, identifies the sources of radiation at the Hermes facility and describes at a high level the programs and provisions for radiation protection and maintaining exposures to radiation as low as is reasonably achievable (ALARA), including preliminary facility design information relevant to radiation protection.

Regulatory Evaluation The applicable regulatory requirements for the evaluation of Hermes radiation protection are as follows:

• 10 CFR 50.34, Contents of applications; technical information, paragraph (a), Preliminary safety analysis report, including:

o 10 CFR 50.34(a)(1)(i), which requires "[a] description and safety assessment of the site on which the facility is to be located, with appropriate attention to features affecting facility design.

o 10 CFR 50.34(a)(4), which requires [a] preliminary analysis and evaluation of the design and performance of structures, systems, and components [SSCs] of the facility; and o 10 CFR 50.34(a)(6), which requires [a] preliminary plan for the applicant's organization, training of personnel, and conduct of operations.

• 10 CFR 50.35, Issuance of construction permits.

• 10 CFR 50.40, Common standards.

As provided in § 20.1002, Scope, the regulations in 10 CFR Part 20, Standards for Protection Against Radiation, apply to persons licensed by the Commission to receive, possess, use, transfer, or dispose of byproduct, source, or special nuclear material or to operate a production or utilization facility. Kairos has applied for a construction permit and has not specifically requested approval of any design information. A construction permit does not provide a license to operate the facility. In its Hermes construction permit application, Kairos also has not applied for licenses to receive, possess, use, transfer, or dispose of byproduct, source, or special nuclear material at the facility. Therefore, the staff did not evaluate whether requirements in 10 CFR Part 20 would be met for the construction of the Hermes reactor. Instead, the staff assessed whether Kairos had identified the relevant requirements for an operating facility and provided descriptions of the preliminary facility design and provisions for protecting the health and safety of the public, workers, and the environment in sufficient detail to determine whether the PSAR provides an acceptable basis for the development of the radiation protection programs and radioactive waste management, and whether there is reasonable assurance that Kairos will comply with the regulations in 10 CFR Part 20 during Hermes facility operation. This is consistent with 10 CFR 50.40(a), which provides that in determining whether a construction permit may be issued, the Commission will be guided by consideration of reasonable assurance that Kairos will comply with the regulations, including the regulations in 10 CFR Part 20, and that the health and safety of the public will not be endangered.

The applicable guidance for the evaluation of Hermes radiation protection is as follows:

• NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Parts 1, Format and Content, and Part 2, Standard Review Plan and Acceptance Criteria, Section 11.1, Radiation Protection.

Technical Evaluation Radiation Sources PSAR Section 11.1.1 identifies the radiation sources that present a potential hazard to workers and the public from operation of the Hermes reactor. The generation of the radiation sources is described in general terms. PSAR Table 11.11, Radiation Sources, lists the SSCs or facility locations which contain fission products or other sources of radiation, with the specific contents identified (e.g., tritium, circulating activity in systems with liquid or gas flow, activation products in structures and components). PSAR Section 11.1.1 states that additional details of radiation sources, including activity and external radiation fields in the facility, will be provided in an operating license application.

During the General Audit, the staff confirmed that Kairos developed preliminary isotopic values for fuel and Flibe radiation sources for preliminary shielding design. In its preliminary analysis, Kairos considered the information and methodology in the technical report KPTR0017, KP-FHR Core Design

and Analysis Methodology, included in the Hermes construction permit application.

As described in PSAR Section 11.1.5, Kairos performed a conservative screening analysis of gaseous tritium emissions from the Hermes reactor resulting in projected doses to the public from emissions of tritium which are well below the allowable limits in 10 CFR Part 20. During the General Audit, the staff reviewed the methodology, inputs, and assumptions for the screening analysis results for tritium reported in the PSAR. The staff noted during the audit that to perform the gaseous effluent screening analysis, Kairos used the XOQDOQ atmospheric dispersion model and GASPAR gaseous effluent pathway model in the NRCDose3 computer code, with site-specific input on the release point, dose receptor locations, and 5 years of site-specific, validated meteorological data. The staff notes that NRCDose3 was developed by the NRC to implement the NRCs requirements for ALARA for radioactive effluents from nuclear power plants. The staff noted during the audit that analysis assumptions for the tritium effluent release were based on a conservative tritium release rate equal to the generation rate, which does not account for retention in the reactor or engineered systems, which would reduce the effective tritium effluent rate. During the General Audit, based on its audit of the screening calculation described in the PSAR, the staff confirmed that Kairos analysis assumptions and methods were consistent with the description in the PSAR and are consistent with the regulatory guidance identified by Kairos in PSAR Section 11.1.5.

In its response to request for confirmation of information (RCI) 12 for the Hermes environmental review, submitted by letter dated April 22, 2022, Kairos stated that the assumed effluent release quantities for gaseous radionuclide effluents other than tritium (used in the Hermes Environmental Report) were taken from the Clinch River Early Site Permit (ESP) Environmental Report, and were based on light-water small modular reactor preliminary design information.

During the General Audit, Kairos confirmed that although its effluent screening analyses discussed in PSAR 11.1.5 do not model liquid effluents, based on the preliminary Hermes design, liquid effluent releases direct to the environment are not expected.

The staff evaluated the sufficiency of the preliminary information on Hermes radiation sources, as described in PSAR Sections 11.1.1 and 11.1.5, using the guidance and acceptance criteria from Section 11.1.1 of NUREG-1537, Parts 1 and 2. The staffs review included a comparison of the bases for identifying potential radiation safety hazards with the process and facility descriptions to verify that such hazards were accurately and comprehensively identified. Based on its review of the information in the PSAR, supported by the General Audit, the staff finds that the high-level description of radiation sources and their bases, including the effluent screening analysis, is consistent with generation and transport and cleanup of radionuclides, activation of materials, and radioactive waste production that would occur at Hermes. The staff finds that the results of the effluent screening analysis provide reasonable assurance that 10 CFR Part 20 limits will be met during Hermes operation. The staff finds use of the Clinch River ESP effluent information for radionuclides other than tritium to be a reasonable assumption for a preliminary scoping analysis, considering the relative power levels and design differences. The staff will review the effluent analysis corresponding to the detailed design in the application for an operating license. Based on its review, the staff finds the PSAR information on Hermes radiation sources is adequate because it identifies the potential radiation safety hazards associated with the Hermes reactor and provides an acceptable preliminary basis for the development of the radiation protection program, and that it meets the applicable acceptance criteria of NUREG1537, Part 2, Section 11.1.1.

Radiation Protection Program and ALARA Program PSAR Sections 11.1.2 and 11.1.3 describe the 10 CFR Part 20 regulatory requirements for a radiation protection program and an ALARA program, respectively. The PSAR sections also describe, at a high-

level, features of the programs (e.g., periodic program review, ALARA controls, and a constraint on air emissions of radioactive materials) that Kairos states it would implement to ensure regulatory requirements are met. Kairos also identifies in the PSAR relevant NRC regulatory guides that Kairos will use to design and implement the radiation protection program and the ALARA program. The PSAR states that Kairos will provide additional details for both programs in an operating license application.

The staff evaluated the sufficiency of the preliminary information on Kairos radiation protection and ALARA programs for Hermes, as described in PSAR Sections 11.1.2 and 11.1.3 and other relevant portions of the PSAR, using the guidance and acceptance criteria from Sections 11.1.2 and 11.1.3 of NUREG-1537, Parts 1 and 2. Based on its review, the staff determined that the level of detail provided on the radiation protection and ALARA programs is adequate because it identifies applicable requirements and appropriate guidance and general features for implementation of the Hermes radiation protection and ALARA programs, and that it meets the applicable acceptance criteria of NUREG-1537, Part 2, Sections 11.1.2 and 11.1.3. Accordingly, the staff finds that Kairos commitments to develop radiation protection and ALARA programs provide reasonable assurance that the Hermes radiation protection and ALARA programs will comply with applicable requirements.

Radiation Monitoring and Surveying PSAR Section 11.1.4 describes the requirements for and purpose of radiation monitoring and surveying at the Hermes facility, and states that written procedures for radiation monitoring and surveying will be established to ensure compliance with 10 CFR Part 20, Subpart F, Surveys and Monitoring. PSAR Section 11.1.4 identifies NRC regulatory guides that Kairos will consider in development of the Hermes radiation monitoring and surveying programs. In addition, PSAR Sections 9.1.2, 9.1.3, and 9.2 describe preliminary design information for radiation monitoring in the cover gas space, tritium management system, and reactor building, respectively. PSAR Section 11.1.4 states that additional details of radiation monitoring and surveying, including a description of the equipment, methods, and procedures, will be provided in an operating license application.

The staff evaluated the sufficiency of the preliminary information on Hermes radiation monitoring and surveying, as described in PSAR Section 11.1.4 and other relevant portions of the PSAR, using the guidance and acceptance criteria from Section 11.1.4 of NUREG-1537, Parts 1 and 2. Based on its review, the staff determined that the level of detail provided on the radiation monitoring and surveying is adequate because it identifies applicable requirements for radiation monitoring and surveying, and includes appropriate preliminary information on guidance, practices, and design features to help ensure that Hermes radiation fields and effluents are monitored and sampled as necessary, and that it meets the applicable acceptance criteria of NUREG-1537, Part 2, Section 11.1.4. Accordingly, the staff finds that Kairos commitments related to radiation monitoring and surveying provide reasonable assurance that Hermes radiation monitoring and surveying will comply with applicable requirements.

Radiation Exposure Control and Dosimetry PSAR Section 11.1.5 provides a preliminary discussion of radiation exposure controls, including access controls and shielding, and effluent monitoring and controls, for the Hermes facility. Radiological control areas will be established (including consideration of shielding) and access to high and very high radiation areas will be controlled as required by 10 CFR Part 20, Subpart G, Control of Exposure from External Sources in Restricted Areas. Precautionary procedures (e.g., posting of radiation areas) will be employed in the facility consistent with the requirements in 10 CFR Part 20, Subpart J, Precautionary Procedures. Additional details on dosimetry, radiation exposure control and assess control, including locations of radiological control areas, access controls, shielding, remote handling equipment, and expected annual radiation exposures, will be provided in an operating license application.

PSAR Section 4.4 provides preliminary design information on the biological shield, including its design bases. In addition, during the General Audit, the staff audited preliminary shielding design information (primarily for the Hermes bioshield) to confirm that Kairos developed preliminary shielding design analyses, including consideration of types of shielding materials and shielding dimensions.

PSAR Sections 9.2 and 11.1.5 describe at a high level the preliminary design features to monitor facility effluents during normal operation and postulated events. PSAR Section 11.1.5 also indicates that the design of SSCs will limit uncontrolled liquid or gaseous effluent releases to work areas or the environment, consistent with the goal of maintaining radiation exposures ALARA. As discussed in PSAR Sections 9.2 and 11.1.5, systems through which gaseous effluents are generally released to the atmosphere include provisions for gaseous effluent monitoring and filtration.

The staff evaluated the sufficiency of the preliminary information on Hermes radiation exposure control and dosimetry, as described in PSAR Section 11.1.5 and other relevant portions of the PSAR, using the guidance and acceptance criteria from Section 11.1.5 of NUREG-1537, Parts 1 and 2. Based on its review, the staff determined that the level of detail provided on the radiation exposure control and dosimetry is adequate because it identifies applicable requirements for radiation exposure control and includes appropriate preliminary information on access controls, shielding, and design features to help ensure that uncontrolled radiation releases and unauthorized entry into high radiation areas will be prevented and radiation doses will be maintained ALARA and within regulatory limits, and that it meets the applicable acceptance criteria of NUREG-1537, Part 2, Section 11.1.5. Accordingly, the staff finds that Kairos commitments related to descriptions of radiation exposure control and dosimetry provide reasonable assurance that Hermes radiation exposure control and dosimetry will comply with applicable requirements.

Contamination Control PSAR Section 11.1.6 states that design features for the control of radioactive contamination at the Hermes facility will be developed consistent with the requirements in 10 CFR 20.1406, Minimization of contamination. The design of such features will also consider the guidance in NRC RG 4.21, Minimization of Contamination and Radioactive Waste Generation: Life-Cycle Planning. PSAR Section 11.1.6 states that a description of these design features will be provided in an operating license application.

The staff evaluated the sufficiency of the preliminary information on Hermes contamination control, as described in PSAR Section 11.1.6, using the guidance and acceptance criteria from Section 11.1.6 of NUREG-1537, Parts 1 and 2. Based on its review, the staff determined that the level of detail provided on the contamination control is adequate because it identifies applicable requirements for contamination control and includes appropriate preliminary information on guidance, practices, and design features that will help ensure that the spread of contamination at Hermes will be minimized, and that it meets the applicable acceptance criteria of NUREG-1537, Part 2, Section 11.1.6. Accordingly, the staff finds that Kairos commitments related to contamination control provide reasonable assurance that Hermes contamination control will comply with applicable requirements.

Environmental Monitoring PSAR Section 11.1.7 states that an operational radiological environmental monitoring program (REMP) will be established to meet the requirements in 10 CFR 20.1302, Compliance with dose limits for individual members of the public, and will be implemented coincident with the start of Hermes operational activities. PSAR Section 11.1.7 identifies regulatory guidance for effluent and environmental monitoring for nuclear power plants that Kairos will consider for developing the operational REMP for Hermes. PSAR Section 11.1.7 states that a description of the REMP will be provided in an operating

license application.

The staff evaluated the sufficiency of the preliminary information on Hermes environmental monitoring, as described in PSAR Section 11.1.7, using the guidance and acceptance criteria from Section 11.1.7 of NUREG-1537, Parts 1 and 2. Based on its review, the staff determined that the level of detail provided on the environmental monitoring is adequate because it identifies applicable requirements for environmental monitoring and includes preliminary information on guidance for the REMP that will help ensure any environmental impacts from Hermes operation will be appropriately assessed, and that it meets the applicable acceptance criteria of NUREG-1537, Part 2, Section 11.1.7. The staff also determined that the environmental monitoring guidance referenced by Kairos is reasonable for use at Hermes, with consideration of the Hermes technology and as appropriate for a non-power reactor.

Accordingly, the staff finds that Kairos commitments related to environmental monitoring provide reasonable assurance that Hermes environmental monitoring will comply with applicable requirements.

Conclusion Based on its findings above, the staff concludes the information in Hermes PSAR Section 11.1 is sufficient and meets the applicable guidance and regulatory requirements identified in this chapter for the issuance of a construction permit in accordance with 10 CFR Part 50. Further information as may be required to complete the review of Hermes radiation protection can reasonably be left for later consideration in the final safety analysis report (FSAR) since this information is not necessary for the review of a construction permit application.

11.2 Radioactive Waste Management Introduction Hermes PSAR Section 11.2, Radioactive Waste Management, describes at a high-level the Hermes radioactive waste management program and preliminary facility design information for radioactive waste handling.

Regulatory Evaluation The discussion of regulatory requirements provided above for radiation protection in SER Section 11.1 is also applicable for the staffs evaluation of radioactive waste management in SER Section 11.2.

The applicable guidance for the evaluation of Hermes radioactive waste management is as follows:

• NUREG-1537, Parts 1 and 2, Section 11.2, Radioactive Waste Management.

Technical Evaluation Radioactive Waste Management Program PSAR Section 11.2.1 states that a description of the radioactive waste management program for the Hermes facility will be provided in an operating license application. PSAR Section 12.1 describes the preliminary Hermes organizational structure, including the radiation protection organization and its responsibilities.

The staff evaluated the sufficiency of the preliminary information on the Hermes radioactive waste management program, as described in PSAR Section 11.2.1 and other relevant portions of the PSAR,

using the guidance and acceptance criteria from Section 11.2.1 of NUREG-1537, Parts 1 and 2. The staff finds that Kairos appropriately identifies the need for a radioactive waste management program and finds that Kaiross plan to provide the detailed description of the radioactive waste program with an operating license application is reasonable given the preliminary nature of the design and the Hermes organizational structure. Therefore, based on its review, the staff determined that the level of detail provided on the radioactive waste management program is adequate and meets the applicable acceptance criteria of NUREG-1537, Part 2, Section 11.2.1. Accordingly, the staff finds that Kairos commitments related to the Hermes radioactive waste management program provide reasonable assurance that the program will comply with applicable requirements.

Radioactive Waste Handling Systems and Controls PSAR Section 11.2.2 describes the radioactive waste handling systems and controls, including discussion of the relevant functions and design features for the collection, packaging, storage, and dispositioning of low-level radioactive wastes in solid and liquid forms. PSAR Section 11.2.2 describes the SSCs that handle liquid and solid wastes at a functional level and identifies the relevant design bases as principal design criteria 2, 60, and 63 (see SER Chapter 3 and KPTR003NP-A, "Principal Design Criteria for the Kairos Power Fluoride-Salt Cooled, High Temperature Reactor"). PSAR Section 11.2.2 also states that radioactive waste handling systems are designed to meet the requirements of 10 CFR 20.1406 as it relates to design for the minimization of contamination and eventual decommissioning of the facility. PSAR Section 11.2.2 states that radioactive waste handling systems will be designed to meet these criteria. The radioactive waste handling systems are not safety-related but will be periodically tested for functionality.

Related to radioactive waste, the Hermes Environmental Report (ER), Section 4.10.2.4, Transportation of Nonradioactive Materials and Hazardous Waste, indicates that a total of 40 tons of Flibe would be shipped to the site for use in the reactor. The Flibe is radioactive at the end of its useful life. ER Section 4.10.2 states that there will be sufficient storage capacity onsite for the radioactive Flibe wastes, which would be allowed to cool and solidify, and would likely remain at the Hermes facility until decommissioning. Based on the description of the Inventory Management System in PSAR Section 9.1.4, if there is replacement of Flibe during Hermes operation, the used Flibe would be stored in transfer canisters in a solid state at ambient temperatures.

PSAR Section 11.2.2 states that gaseous radioactive wastes are not handled in a dedicated gaseous radioactive waste system, but are discharged to the reactor building heating, ventilation, and air conditioning system, where they are filtered and monitored prior to release to the atmosphere. PSAR Section 11.1.5 provides a screening analysis of gaseous tritium releases from Hermes, which the staff reviewed as discussed in SER Section 11.1.1.

The staff evaluated the sufficiency of the preliminary information on the Hermes radioactive waste handling system and controls, as described in PSAR Section 11.2.2 and other relevant portions of the PSAR, using the guidance and acceptance criteria from Section 11.2.2 of NUREG-1537, Parts 1 and 2.

The staff finds that Kairos has described methods by which the waste products from procedures and processes will be monitored or otherwise assessed for radioactive material contents, and when appropriate, controls will be established on the waste streams and products designed to prevent uncontrolled exposures or escape of radioactive waste. Therefore, based on its review, the staff determined that the level of detail provided on the radioactive waste handling system and controls, including the design bases and identification of relevant principal design criteria, is adequate and meets the applicable acceptance criteria of NUREG-1537, Part 2, Section 11.2.2. Accordingly, the staff finds that Kairos commitments related to the Hermes radioactive waste handling system and controls provide reasonable assurance that they will comply with applicable requirements.

Release of Radioactive Waste PSAR 11.2.3 describes at a high level the disposition of radioactive waste. Gaseous wastes are filtered and monitored before release to the atmosphere, as also described in PSAR Section 11.2.2. Liquid radioactive waste may be recycled or released to sanitary sewerage in accordance with applicable regulations. Some liquid and solid radioactive waste is expected to be packaged and disposed of using a licensed and qualified low-level radioactive waste disposal vendor.

The staff evaluated the sufficiency of the preliminary information on the release of radioactive waste at Hermes, as described in PSAR Section 11.2.3 and other relevant portions of the PSAR, using the guidance and acceptance criteria from Section 11.2.3 of NUREG-1537, Parts 1 and 2. Based on its review, the staff determined that the level of detail provided on the release of radioactive waste is adequate because it includes preliminary information on how radioactive waste from Hermes will be dispositioned appropriately and in accordance with applicable regulations, and that it meets the applicable acceptance criteria of NUREG-1537, Part 2, Section 11.2.3. Accordingly, the staff finds that Kairos commitments related to the release of radioactive waste provide reasonable assurance that releases will comply with applicable requirements.

Conclusion Based on its findings above, the staff concludes the information in Hermes PSAR Section 11.2 is sufficient and meets the applicable guidance and regulatory requirements identified in this chapter for the issuance of a construction permit in accordance with 10 CFR Part 50. Further information as may be required to complete the review of Hermes radioactive waste management can reasonably be left for later consideration in the FSAR since this information is not necessary for the review of a construction permit application.

11.3 Summary and Conclusions on Radiation Protection and Waste Management The staff evaluated the descriptions and discussions of Hermes radiation protection and waste management as described in PSAR Chapter 11 and finds that the preliminary information on and design criteria of the radiation protection and waste management programs and provisions, including the principal design criteria, design bases, and information relating to materials of construction, general arrangement, and approximate dimensions: (1) provide reasonable assurance that the final design will confirm to the design bases, and (2) meet all applicable regulatory requirements and acceptance criteria discussed in NUREG-1537. Based on these findings, the staff makes the following conclusions regarding issuance of a construction permit in accordance with 10 CFR Part 50:

• Kairos has described the proposed facility design criteria for radiation protection and waste management, including, but not limited to, the principal architectural and engineering criteria for the design, and has identified the major features or components incorporated therein for the protection of the health and safety of the public.

• Such further technical or design information as may be required to complete the safety analysis of the radiation protection and waste management programs, and which can reasonably be left for later consideration, will be provided in the FSAR.

• There is reasonable assurance that: (i) safety questions will be satisfactorily resolved at or before the latest date stated in the application for completion of construction of the proposed facility, and (ii) taking into consideration the site criteria contained in 10 CFR Part 100, the proposed facility can be constructed and operated at the proposed location without undue risk to the health and safety of the public.

• There is reasonable assurance: (i) that the construction of the Hermes facility will not endanger the health and safety of the public, and (ii) that construction activities can be conducted in compliance with the Commissions regulations.

• Kairos is technically qualified to engage in the construction of its proposed Hermes facility in accordance with the Commissions regulations.

• The issuance of a permit for the construction of the Hermes facility would not be inimical to the common defense and security or to the health and safety of the public.

11.4 References Kairos Power LLC. Hermes Non-Power Reactor Preliminary Safety Analysis Report, Revision 0.

September 2021. ADAMS ML21272A375 or XXXXX Kairos Power LLC. KPTR003NP-A, "Principal Design Criteria for the Kairos Power Fluoride-Salt Cooled, High Temperature Reactor". June 2020. ADAMS Accession No. ML20167A174.

Kairos Power LLC. KP-TR-0017, KP-FHR Core Design and Analysis Methodology. September 2021.

ADAMS Accession No. ML21272A383 (redacted version).

Kairos Power LLC. Submittal of the Environmental Report for the Kairos Power Fluoride Salt-Cooled, High Temperature Non-Power Reactor (Hermes). October 31, 2021. ADAMS Pkg. Accession No. ML21306A131.

Kairos Power LLC. Transmittal of Responses to NRC Requests for Confirmation of Information for the Review of the Hermes Environmental Report. April 22, 2022. ADAMS Pkg. Accession No. ML22115A204.

Nuclear Regulatory Commission (U.S.) (NRC). NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Part 1, Format and Content, and Part 2, Standard Review Plan and Acceptance Criteria. NRC: Washington, D.C. February 1996. ADAMS Accession Nos. ML042430055 and ML042430048.

Nuclear Regulatory Commission (U.S.) (NRC). Report on General Regulatory Audit for the Hermes Construction Permit Application Review, dated XX, 202X. ADAMS Accession No. MLXXXXXXXXX.

Nuclear Regulatory Commission (U.S.) (NRC). Regulatory Guide 4.21, Minimization of Contamination and Radioactive Waste Generation: Life-Cycle Planning, Revision 0. NRC: Washington, D.C. June 2008. ADAMS Accession No. ML080500187.

Tennessee Valley Authority. Clinch River Nuclear Site Early Site Permit Application, Part 3, Environmental Report, Revision 2. January 2019. ADAMS Pkg. Accession No. ML19030A478.