ML23017A157

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Preliminary Hermes CP SE Chapter 12, Conduct of Operations for ACRS
ML23017A157
Person / Time
Site: Hermes
Issue date: 01/10/2023
From: Benjamin Beasley
NRC/NRR/DANU/UAL1
To:
Advisory Committee on Reactor Safeguards
References
Download: ML23017A157 (1)
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Text

12 CONDUCT OF OPERATIONS 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 conduct of operations involves the administrative aspects of facility operation (i.e., the facility organizational structure, review and audit activities, facility procedures, required actions for technical specification violations, reporting requirements, and recordkeeping), emergency planning, quality assurance, security, operator training and requalification, and startup and material control and accounting (MC&A) plans.

This chapter of the Kairos Power, LLC (Kairos) Hermes construction permit (CP) safety evaluation report (SER) describes the U.S. Nuclear Regulatory Commission (NRC) staffs (the staffs) technical review and evaluation of the preliminary information provided in Chapter 12, Conduct of Operations, of the Kairos Hermes preliminary safety analysis report (PSAR), Revision XX. The staff reviewed Kairos Hermes PSAR Chapter 12 against applicable regulatory requirements using regulatory guidance and standards to assess the sufficiency of the preliminary information on the Hermes conduct of operations for the issuance of a CP in accordance with Title 10, Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities. The staffs reviews and evaluations for areas relevant to PSAR Chapter 12, including regulations and guidance used, a summary of the application information reviewed, and evaluation findings and conclusions, are discussed in the SER sections below for each specific area of review. A summary and overall conclusion on the staffs technical evaluation of the Hermes conduct of operations are provided in SER Section 12.14, Summary and Conclusions on Conduct of Operations.

12.1 Organization Introduction Hermes PSAR Section 12.1, Organization, describes the organizational structure, functional responsibilities, levels of authority, and interfaces for establishing, executing, and verifying the organizational structure concerning facility operation. The organizational structure includes internal and external functions including interface responsibilities for multiple organizations. PSAR Section 12.1 also discusses the organizational aspects of the radiation protection (RP) program, staffing, and selection and training of personnel.

Regulatory Evaluation The applicable regulatory requirements for the evaluation of Kairos organization are as follows:

  • 10 CFR 50.34, Contents of applications; technical information, paragraph (a), Preliminary safety analysis report, including 10 CFR 50.34(a)(6), which requires that the PSAR include [a]

preliminary plan for the applicants organization, training of personnel, and conduct of operations.

The applicable guidance for the evaluation of Kairos organization is as follows:

  • 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, Section 12.1, Organization.

Technical Evaluation In PSAR Sections 12.1.1 and 12.1.2, Kairos describes the organizational structure for Hermes operations and the responsibilities for key positions at Kairos, including the positions in the organizational structure. The organizational structure is shown in PSAR Figure 12.1-1. PSAR Section 12.1.2 indicates that the Site Executive will have overall responsibility for compliance with a Hermes operating license (OL). The Plant Manager, who reports to the Site Executive, has responsibility for facility operations, maintenance, and engineering. Operations personnel such as the shift supervisor and reactor operators report to the Plant Manager. The Technical Services Manager, who has responsibility for facility services, also reports to the Site Executive. Facility services that the Technical Services Manager has responsibility for include RP. RP staff who are responsible for establishing and implementing the RP program report to the Technical Services Manager. According to PSAR Section 12.1.2 and PSAR Figure 12.1-1, the Quality Manager, who also reports to the Site Executive, is responsible for auditing for compliance with regulatory requirements and procedures and has sufficient independence to bring forward issues affecting safety and quality. The Hermes Review and Audit Committee (see SER Section 12.2), which separately reports to the Site Executive as illustrated in PSAR Figure 12.1-1, also has independent audit responsibilities that are separate from those of the Quality Assurance group.

PSAR Section 12.1.3 states that sufficient personnel resources will be provided to safely conduct Hermes facility operations, and specific details related to Hermes staffing, including minimum staffing levels, will be provided in an OL application.

PSAR Section 12.1.4 states that an indoctrination and training program will be maintained for personnel performing, verifying, or managing Hermes activities during Hermes facility operation. Kairos states that it will use the guidance in American National Standards Institute/American Nuclear Society (ANSI/ANS)-

15.4-2016, Selection and Training of Personnel for Research Reactors, as applicable, for selecting and training Hermes personnel. Kairos states that details of its training programs and required minimum qualifications for Hermes staff will be provided in an OL application.

PSAR Section 12.1.5 states that sufficient resources in terms of staffing and equipment will be provided to implement an effective RP program at Hermes. PSAR Section 12.1.2.8 states that RP has the authority to terminate unsafe activities at Hermes (facility management could subsequently overrule such a termination, based on appropriate analysis and consideration). PSAR Section 12.1.5 states that further details related to the authority of RP staff with respect to Hermes operations will be provided in an OL application.

PSAR Section 14.1 states that technical specifications (TSs), which will be provided in an OL application, will include administrative controls and the content of the TSs will be consistent with the guidance in ANSI/ANS-15.1-2007, The Development of Technical Specifications for Research Reactors. The staff notes that ANSI/ANS-15.1-2007, Section 6.1, provides guidance for TS requirements related to facility organization, including organizational structure, responsibilities, staffing, and selection and training of personnel.

The staff evaluated the sufficiency of the preliminary information on Hermes organization, as described in PSAR Section 12.1, using the guidance and acceptance criteria from Section 12.1 of NUREG-1537, Parts 1 and 2. In its evaluation, the staff also considered the preliminary information in PSAR Section 14.1 regarding the content of the TS. The staff finds that ANSI/ANS-15.1-2007, referenced by Kairos, provides guidance for facility organization that is generally consistent with the guidance in NUREG-1537.

Based on its review, the staff determined that the level of detail provided on Hermes organization is adequate and meets the applicable acceptance criteria of NUREG-1537, Part 2, Section 12.1.

Accordingly, the staff finds that Kairos commitments to develop requirements for the Hermes organization provide reasonable assurance that the Hermes organization will comply with applicable requirements.

Conclusion Based on its findings above, the staff concludes the information in Hermes PSAR Section 12.1 is sufficient and meets the applicable guidance and regulatory requirements for the issuance of a CP in accordance with 10 CFR Part 50. Further information as may be required to complete the review of the Hermes organization (e.g., detailed information on staffing and training) can reasonably be left for later consideration in the final safety analysis report (FSAR) since this information is not necessary to be provided as part of a CP application.

12.2 Review and Audit Activities Introduction Hermes PSAR Section 12.2, Review and Audit Activities, describes review and audit activities during facility operation at Hermes.

Regulatory Evaluation The applicable regulatory requirements for the evaluation of Kairos review and audit activities are as follows:

  • 10 CFR 50.34, Contents of applications; technical information, paragraph (a), Preliminary safety analysis report, including 10 CFR 50.34(a)(6), which requires that the PSAR include [a]

preliminary plan for the applicants organization, training of personnel, and conduct of operations.

The applicable guidance for the evaluation of Kairos review and audit activities is as follows:

  • NUREG-1537, Parts 1 and 2, Section 12.2, Review and Audit Activities.

Technical Evaluation PSAR Section 12.2 states that the Hermes Site Executive will establish a Review and Audit Committee and the Site Executive will ensure that appropriate technical expertise will be available for review and audit activities. The Review and Audit Committees activities will be summarized and reported to the Site Executive. Kairos states that details of review and audit activities, details of the Review and Audit Committees approval authorities, and details of how the Review and Audit Committee interacts with Hermes facility management and Kairos corporate management will be provided in an OL application.

PSAR Section 14.1 states that TSs, which will be provided in an OL application, will include administrative controls and the content of the TSs will be consistent with the guidance in ANSI/ANS-15.1-2007. The staff notes that ANSI/ANS-15.1-2007, Section 6.2, provides guidance for TS requirements related to review and audit activities, including review and audit committee composition, qualifications, charter, and rules; and review and audit committee functions (e.g., specific items to be

reviewed or audited, and reporting functions).

The staff evaluated the sufficiency of the preliminary information on review and audit activities for Hermes, as described in PSAR Section 12.2, using the guidance and acceptance criteria from Section 12.2 of NUREG-1537, Parts 1 and 2. In its evaluation, the staff also considered the preliminary information in PSAR Section 14.1 regarding the content of TSs. The staff finds that ANSI/ANS-15.1-2007, referenced by Kairos, provides guidance for review and audit activities that is generally consistent with the guidance in NUREG-1537. Based on its review, the staff determined that the level of detail provided on review and audit activities at Hermes is adequate and meets the applicable acceptance criteria of NUREG-1537, Part 2, Section 12.2. Accordingly, the staff finds that Kairos commitments to develop requirements for review and audit activities provide reasonable assurance that Hermes review and audit activities will comply with applicable requirements.

Conclusion Based on its findings above, the staff concludes the information in Hermes PSAR Section 12.2 is sufficient and meets the applicable guidance and regulatory requirements for the issuance of a CP in accordance with 10 CFR Part 50. Further information as may be required to complete the review of Hermes review and audit activities (e.g., detailed information on review and audit committee composition, qualifications, charter, and rules, and review and audit committee functions including review, approval, audit, and reporting functions) can reasonably be left for later consideration in the FSAR since this information is not necessary for the review of a CP application.

12.3 Procedures Introduction Hermes PSAR Section 12.3, Procedures, describes the use of operating procedures during Hermes facility operation.

Regulatory Evaluation The applicable regulatory requirements for the evaluation of Kairos procedures are as follows:

  • 10 CFR 50.34, Contents of applications; technical information, paragraph (a), Preliminary safety analysis report, including 10 CFR 50.34(a)(6), which requires that the PSAR include [a]

preliminary plan for the applicants organization, training of personnel, and conduct of operations.

The applicable guidance for the evaluation of Kairos procedures is as follows:

  • NUREG-1537, Parts 1 and 2, Section 12.3, Procedures.

Technical Evaluation PSAR Section 12.3 states that for activities involving safety, Hermes facility personnel will use operating procedures that are approved and that provide appropriate direction to ensure the facility is operated within the design basis and TSs. The level of detail in procedures will consider the experience, education, and training of users and the consequences of errors. Expectations for the use of procedures

will be documented and communicated to facility personnel. The general topics of procedures will be consistent with the guidance in ANSI/ANS-15.1-2007, Section 6.4, Procedures. Kairos states that more specific information on facility procedures, including the review, approval, and change processes for procedures, will be provided in an OL application.

PSAR Section 14.1 states that TSs, which will be provided in an OL application, will include administrative controls and the content of the TSs will be consistent with the guidance in ANSI/ANS-15.1-2007. The staff notes that, in addition to listing recommended topics for which procedures should be required by TSs, ANSI/ANS-15.1-2007, Section 6.4, also provides guidance for TS requirements related to review and approval of procedures and changes to procedures.

The staff evaluated the sufficiency of the preliminary information on Hermes procedures, as described in PSAR Section 12.3, using the guidance and acceptance criteria from Section 12.3 of NUREG-1537, Parts 1 and 2. The staff finds that ANSI/ANS-15.1-2007, referenced by Kairos, provides guidance for procedures that is generally consistent with the guidance in NUREG-1537. Based on its review, the staff determined that the level of detail provided on Hermes procedures is adequate and meets the applicable acceptance criteria of NUREG-1537, Part 2, Section 12.3. Accordingly, the staff finds that Kairos commitments related to procedures provide reasonable assurance that Hermes procedures will comply with applicable requirements.

Conclusion Based on its findings above, the staff concludes the information in Hermes PSAR Section 12.3 is sufficient and meets the applicable guidance and regulatory requirements for the issuance of a CP in accordance with 10 CFR Part 50. Further information as may be required to complete the review of Hermes procedures (e.g., detailed information on review, approval, and change processes for procedures) can reasonably be left for later consideration in the FSAR since this information is not necessary for the review of a construction permit application.

12.4 Required Actions Introduction Hermes PSAR Section 12.4, Required Actions, describes actions that will be taken when a safety limit is exceeded or a limiting condition for operation or surveillance requirement is not met.

Regulatory Evaluation The applicable regulatory requirements for the evaluation of Kairos required actions are as follows:

  • 10 CFR 50.34, Contents of applications; technical information, paragraph (a), Preliminary safety analysis report, including 10 CFR 50.34(a)(6), which requires that the PSAR include [a]

preliminary plan for the applicants organization, training of personnel, and conduct of operations.

The applicable guidance for the evaluation of Kairos required actions is as follows:

  • NUREG-1537, Parts 1 and 2, Section 12.4, Required Actions.

Technical Evaluation PSAR Section 12.4 states that Hermes TSs will specify the actions to be taken when a safety limit is exceeded or a limiting condition for operation or surveillance requirement is not met. PSAR Section 12.4 also states that TSs are described in PSAR Chapter 14 and will be provided in an OL application. PSAR Section 14.1 states that the TSs which will be provided in an OL application will include administrative controls and the content of the TSs will be consistent with the guidance in ANSI/ANS-15.1-2007.

The staff evaluated the sufficiency of the preliminary information on Hermes required actions, as described in PSAR Section 12.4, using the guidance and acceptance criteria from Section 12.4 of NUREG-1537, Parts 1 and 2. The staff finds that ANSI/ANS-15.1-2007, referenced by Kairos, provides guidance that is generally consistent with the guidance in NUREG-1537 for types of events that should be reportable, and required actions for reportable events. Based on its review, the staff determined that the level of detail provided on Hermes required actions is adequate and meets the applicable acceptance criteria of NUREG-1537, Part 2, Section 12.4. Accordingly, the staff finds that Kairos commitments to develop requirements for reportable actions provide reasonable assurance that Hermes reportable actions will comply with applicable requirements.

Conclusion Based on its findings above, the staff concludes the information in Hermes PSAR Section 12.4 is sufficient and meets the applicable guidance and regulatory requirements for the issuance of a CP in accordance with 10 CFR Part 50. Further information as may be required to complete the review of Kaiross required actions can reasonably be left for later consideration in the FSAR since this information is not necessary for the review of a CP application.

12.5 Reports Introduction Hermes PSAR Section 12.5, Reports, describes required routine operating reports and reporting requirements for changes to the Hermes facility or facility organization to be provided to the NRC.

Regulatory Evaluation The applicable regulatory requirements for the evaluation of Kairos reports are as follows:

  • 10 CFR 50.34, Contents of applications; technical information, paragraph (a), Preliminary safety analysis report, including 10 CFR 50.34(a)(6), which requires that the PSAR include [a]

preliminary plan for the applicants organization, training of personnel, and conduct of operations.

The applicable guidance for the evaluation of Kairos reports is as follows:

Technical Evaluation PSAR Section 12.5 states that the Hermes TSs will specify the required routine operating reports and

reporting requirements for changes to the facility or facility organization to be provided to the NRC, and that TSs are described in PSAR Chapter 14 and will be provided in an OL application. PSAR Section 14.1 states that TSs, which will be provided in an OL application, will include administrative controls and that the content of the TSs will be consistent with the guidance in ANSI/ANS-15.1-2007.

PSAR Section 12.4 also states that the Hermes TSs will specify actions to be taken for a TS violation, which the staff expects would include reports to the NRC, consistent with NRC reporting requirements.

The staff evaluated the sufficiency of the preliminary information on Hermes reports, as described in PSAR Sections 12.4 and 12.5, using the guidance and acceptance criteria from Section 12.5 of NUREG-1537, Parts 1 and 2. The staff finds that ANSI/ANS-15.1-2007, referenced by Kairos, provides guidance for reports, including routine operating reports, and special reports (e.g., reports of TS violations or facility personnel changes), that is generally consistent with the guidance in NUREG-1537. Based on its review, the staff determined that the level of detail provided on Hermes reports is adequate and meets the applicable acceptance criteria of NUREG-1537, Part 2, Section 12.5. Accordingly, the staff finds that Kairos commitments to develop requirements for reports provide reasonable assurance that Hermes reportable actions will comply with applicable requirements.

Conclusion Based on its findings above, the staff concludes the information in Hermes PSAR Section 12.5 (supported by information in PSAR Section 12.4) is sufficient and meets the applicable guidance and regulatory requirements for the issuance of a CP in accordance with 10 CFR Part 50. Further information as may be required to complete the review of Hermes reports can reasonably be left for later consideration in the FSAR since this information is not necessary for the review of a CP application.

12.6 Records Introduction Hermes PSAR Section 12.6, Records, describes the process for managing test reactor facility records.

Regulatory Evaluation The applicable regulatory requirements for the evaluation of Kairos records are as follows:

  • 10 CFR 50.34, Contents of applications; technical information, paragraph (a), Preliminary safety analysis report, including 10 CFR 50.34(a)(6), which requires that the PSAR include [a]

preliminary plan for the applicants organization, training of personnel, and conduct of operations.

The applicable guidance for the evaluation of Kairos records is as follows:

Technical Evaluation PSAR Section 12.6 states that the Hermes TSs will specify for facility operation the required records to be maintained, where and how they are maintained, and the length of retention. PSAR Section 12.6 also

states that TSs are described in PSAR Chapter 14 and will be provided in an OL application. PSAR Section 14.1 states that TSs, which will be provided in an OL application, will include administrative controls and the content of the TSs will be consistent with the guidance in ANSI/ANS-15.1-2007.

PSAR Section 12.6 also states that a records management program is implemented as part of the Quality Assurance Program described in PSAR Section 12.9.

The staff evaluated the sufficiency of the preliminary information on Hermes operational records, as described in PSAR Section 12.6, using the guidance and acceptance criteria from Section 12.6 of NUREG-1537, Parts 1 and 2. The staff finds that ANSI/ANS-15.1-2007, referenced by Kairos, provides guidance for operational records that is consistent with the guidance in NUREG-1537. Based on its review, the staff determined that the level of detail provided regarding Hermes operational records is adequate and meets the applicable acceptance criteria of NUREG-1537, Part 2, Section 12.6.

Accordingly, the staff finds that Kairos commitments to develop requirements for records provide reasonable assurance that Hermes records will comply with applicable requirements. The records management program during construction, as described in Kairos Quality Assurance Program Description, is discussed in SER Section 12.9.

Conclusion Based on its findings above, the staff concludes the information in Hermes PSAR Section 12.6 is sufficient and meets the applicable guidance and regulatory requirements for the issuance of a CP in accordance with 10 CFR Part 50. Further information as may be required to complete the review of Hermes records can reasonably be left for later consideration in the FSAR since this information is not necessary for the review of a CP application.

12.7 Emergency Planning Introduction Hermes PSAR Section 12.7, Emergency Planning, discusses emergency planning. The Hermes PSAR provides a description of the preliminary plans for addressing emergencies in Appendix A, Description of the Emergency Plan, of Chapter 12, Conduct of Operations, which is referenced in PSAR Section 12.7.

Regulatory Evaluation The applicable regulatory requirements for the evaluation of Kairos preliminary plans for coping with emergencies are as follows:

  • 10 CFR 50.34, Contents of applications; technical information, paragraph (a), Preliminary safety analysis report, including 10 CFR 50.34(a)(10), which requires that the PSAR include [a]

discussion of the applicant's preliminary plans for coping with emergencies.

  • 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities,Section I, Introduction, and Section II, The Preliminary Safety Analysis Report.

The applicable guidance for the evaluation of Kairos preliminary plans for coping with emergencies is as follows:

  • NUREG-1537, Parts 1 and 2, Section 12.7, Emergency Planning.
  • NRC Regulatory Guide (RG) 2.6, Emergency Planning for Research and Test Reactors and Other Non-Power Production and Utilization Facilities, Revision 2.

American National Standards Institute/American Nuclear Society standard (ANSI/ANS) 15.16-2015, Emergency Planning for Research Reactors.

The regulation 10 CFR Part 50, Appendix E, Section I.3, states, in part, that the potential radiological hazards to the public associated with the operation of test reactors licensed under 10 CFR Part 50 involve considerations different than those associated with nuclear power reactors and that consequently, the size of emergency planning zones (EPZs) for test reactors, and the degree to which compliance with the requirements of Appendix E is necessary, will be determined on a case-by-case basis. Accordingly, the staff evaluated Kairos preliminary emergency plan for compliance with 10 CFR Part 50, Appendix E, Section II, using the criteria in the research and test reactor-specific guidance listed above.

Technical Evaluation The staffs technical evaluation of the preliminary emergency plan for Hermes is detailed in the following subsections. The technical evaluation is organized into subsections documenting the staffs review and evaluation for each 10 CFR Part 50, Appendix E, Section II, PSAR requirement.

Facility Design Features, Site Layout, and Site Location (10 CFR Part 50, Appendix E, Section II General)

PSAR Chapter 2, Site Characteristics, and Chapter 12, Appendix A provide a description of the Hermes reactor site layout and location, consideration of access routes, surrounding population distribution, land use, and jurisdictional boundaries. This information is graphically shown on PSAR Figure 2.1-2, Prominent Features in Site Area, and Figure 2.1-3, Project Site Area and Zones Associated with the Facility.

The staff reviewed PSAR Chapter 2, Site Characteristics, and Chapter 12, Appendix A, including associated figures, site layout, and maps. The staff conducted its review to determine if sufficient information was provided to meet the PSAR emergency plan requirements of 10 CFR Part 50, Appendix E, Section II, as it pertains to the facility design features, site layout, and site location with consideration of access routes, surrounding population distributions, land use, and local jurisdictional boundaries for the EPZs. The staff used the guidance in ANSI/ANS15.16-2015, Section 3.1, Introduction, and the guidance evaluation items contained in NUREG-0849, Section 1.0, Introduction, to perform the evaluation for compliance with the 10 CFR Part 50, Appendix E, Section II, PSAR regulations. Based on its review, the staff finds that the information in the PSAR concerning the site layout and location, consideration of access routes, surrounding population distribution, land use, and jurisdictional boundaries addresses the applicable guidance in ANSI/ANS15.16-2015 and the applicable guidance evaluation items contained in NUREG-0849. Therefore, the staff finds that this emergency plan preliminary information is sufficient and meets the applicable PSAR regulatory requirements of 10 CFR Part 50, Appendix E, Section II.

The staff notes that for an OL application, consistent with the applicable guidance in ANSI/ANS15.16-2015 and the emergency planning evaluation items contained in NUREG-0849, complete and detailed emergency plan descriptions, such as a description of the location of the reactor facility, including access routes, should be included within the emergency plan.

Emergency Response Organization, Notification, and Documented Arrangements (10 CFR Part 50, Appendix E, Sections II.A and II.B)

PSAR Chapter 12, Appendix A, Section A.1, Facility Organization, and Section A.2, Authorities and Responsibilities of Facility Emergency Personnel, state that upon declaration of an emergency, designated members of the Hermes facility emergency personnel staff will fulfill corresponding roles in responding to the emergency. In the event of an emergency, the senior individual on-shift will become the Emergency Director and will be responsible for assessing and declaring an emergency and assuming command and control responsibilities following an emergency declaration. Likewise, upon declaration of an emergency, designated health physics personnel will undertake RP activities and designated engineering personnel will focus on plant assessment and technical support for operations.

The Emergency Director, who will be the senior individual on-shift, will fulfill this role until their emergency response duties are transitioned to the dedicated replacement.

During the General Audit, Kairos confirmed that it will provide further information on emergency organization to address the below bulleted items in NUREG-0849, Section 3.0, guidance in the updated Hermes emergency plan that will be submitted as part of a Hermes OL application:

  • The reactor's emergency organization, including augmentation of the reactor staff to provide assistance for coping with the emergency situation, recovery from the emergency, and maintaining emergency preparedness.
  • The capability of the emergency organization to function around the clock for a protracted period of time following the initiation of emergencies that have or could have radiological consequences requiring around the clock emergency response.
  • A block diagram that illustrates the interrelationship of the facility emergency organization to the total emergency response effort. Interfaces between reactor and other onsite emergency organization groups and offsite local support organizations and agencies should be specified.

PSAR Chapter 12, Appendix A, Section A.3, Means for Notifications, states that the capability for 24-hour notification to onsite and offsite organizations, including a primary and backup means to accomplish the required notifications will be provided. In addition, PSAR Chapter 12, Appendix A, Section B.2, State Agencies, states that the methods used to notify the Tennessee Emergency Management Agency (TEMA) and the information to be provided to TEMA will be established in coordination with TEMA.

PSAR Chapter 12, Appendix A, Section B, Authorities and Responsibilities of Governmental Agencies, describes the authorities, responsibilities, support functions, and the available emergency assistance provided from Federal, State, county, and local governmental agencies in an emergency situation.

During the General Audit, Kairos confirmed that in the updated Hermes emergency plan that will be submitted as part of a Hermes OL application, it will provide further information to address the NUREG-0849, Section 3.0, guidance on arrangements and agreements, confirmed in writing, with local support organizations that would augment and extend the capability of the Hermes emergency organization The staff reviewed PSAR Chapter 12, Appendix A, Sections A and B to determine if sufficient information was provided to meet the PSAR emergency plan requirements of 10 CFR Part 50, Appendix E, Section

II.A and Section II.B. The staff used the guidance in ANSI/ANS15.16-2015, Section 3.3, Organization and Responsibilities, and the guidance evaluation items contained in NUREG-0849, Section 3.0, Organization and Responsibilities, to perform the evaluation. Based on its review, staff finds that the information in the CP application concerning the Hermes emergency response organization and the means for notification, in the event of an emergency, of persons assigned to the emergency organizations, addresses the applicable guidance in ANSI/ANS15.16-2015 and the applicable guidance evaluation items contained in NUREG-0849. Therefore, the staff finds that this emergency plan preliminary information is sufficient and meets the applicable PSAR regulatory requirements of 10 CFR Part 50, Appendix E, Section II.A and Section II.B.

As discussed above, Kairos committed to providing additional information on the Hermes emergency response organization and Kairos documented arrangements with local, State, and Federal governmental agencies that have responsibility for coping with emergencies in the updated emergency plan that will be submitted with a Hermes OL application. Following receipt of the updated Hermes emergency plan and FSAR to be submitted with the OL application, the staff will confirm that the updated emergency plan information contains sufficient information to address the applicable guidance and meet the applicable regulations.

Protective Measures to be Taken within the Site Boundary and within Each EPZ (10 CFR Part 50, Appendix E, Section II.C)

PSAR Chapter 12, Appendix A, Section C, Protective Measures, states that the Hermes reactor EPZ is coincident with the site boundary, describes the steps for taking protective action within the EPZ during an emergency, and states that the public address system and action specific alarms (e.g., site evacuation) can be used to communicate appropriate protective actions.

During the General Audit, Kairos confirmed that in the updated Hermes emergency plan that will be provided as part of a Hermes OL application, it will provide further information on emergency classification to address NUREG-0849, Section 4.0, guidance, specifically, an emergency classification system that is consistent with the guidance.

The staff reviewed PSAR Chapter 12, Appendix A, Section C. The staff conducted its review to determine if sufficient information was provided to meet the PSAR emergency plan requirements of 10 CFR Part 50, Appendix E, Section II.C. The staff used the guidance in ANSI/ANS15.16-2015, Section 3.4, Emergency Classification System, and the guidance evaluation items contained in NUREG-0849, Section 4.0, Emergency Classification System, to perform the evaluation. Based on its review, the staff concludes that the information in the CP application concerning the Hermes protective measures to be taken within the EPZ in the event of an accident addresses the applicable guidance in ANSI/ANS15.16-2015 and the applicable guidance evaluation items contained in NUREG-0849. Therefore, the staff finds that this preliminary information on protective measures is sufficient and meets the applicable PSAR regulatory requirements of 10 CFR Part 50, Appendix E, Section II.C.

As discussed above, Kairos committed to providing additional information on the Hermes emergency classification system in an updated emergency plan that will be submitted with a Hermes OL application.

Following receipt of the updated Hermes emergency plan and FSAR to be submitted with the OL application, the staff will confirm that the updated emergency plan information contains sufficient information to address the applicable guidance and meet applicable regulations.

Emergency Treatment, Transportation, and Decontamination for Injured Individuals (10 CFR Part 50, Appendix E, Sections II.D and II.E)

PSAR Chapter 12, Appendix A, Section D, First Aid, Decontamination, and Emergency Transportation,

states that contaminated personnel will be kept in an area isolated from other personnel activities to avoid the spread of contamination and that injured personnel will be decontaminated if possible and then dispatched to either the Oak Ridge Methodist Medical Center or the University of Tennessee Hospital.

Injured persons are monitored and cared for first and then uninjured personnel will be checked for contamination and any necessary actions will be taken to remove whatever contamination is detected.

Personnel with serious injuries and that are contaminated will be transported by ambulance directly to the emergency room at Oak Ridge Methodist Medical Center or the University of Tennessee Hospital.

Showers are available onsite that can be used for personnel decontamination and there are personnel decontamination facilities located offsite at Oak Ridge Methodist Medical Center and the University of Tennessee Hospital. In addition, first aid and decontamination kits will be available throughout the Hermes facility. PSAR Chapter 12, Appendix A, Section E, Offsite Treatment, also states that the Oak Ridge Methodist Medical Center and the University of Tennessee Medical Center have standard operating procedures for dealing with radiological emergencies, including contaminated patients.

The staff reviewed PSAR Chapter 12, Appendix A, Sections D and E. The staff conducted its review to determine if sufficient information was provided to meet the PSAR emergency plan requirements of 10 CFR Part 50, Appendix E, Section II.D and Section II.E. The staff used the guidance in ANSI/ANS15.16-2015, Section 3.8, Emergency Facilities and Equipment, and the applicable guidance evaluation items contained in NUREG-0849, Section 8.0, Emergency Facilities and Equipment, to perform the evaluation. Based on its review, the staff finds that the information in the CP application concerning Hermes facility onsite emergency first aid, decontamination, emergency transportation, and treatment at offsite facilities for individuals injured at the Hermes facility, addresses the applicable guidance in ANSI/ANS15.16-2015 and the applicable guidance evaluation items contained in NUREG-0849.

Therefore, the staff finds that the onsite emergency first aid, decontamination, emergency transportation, and treatment at offsite facilities for injured individuals are sufficient and meet the applicable PSAR regulatory requirements of 10 CFR Part 50, Appendix E, Sections II.D and II.E.

Provisions for a Training Program (10 CFR Part 50, Appendix E, Section II.F)

PSAR Chapter 12, Appendix A, Section F, Training, states that an initial training and periodic retraining program will be conducted at Hermes to maintain the ability of emergency response personnel to perform their assigned functions. Section F also states that the personnel involved in the training program would include facility personnel responsible for decision-making and transmitting emergency information. In addition, offsite personnel, and agencies whose assistance is needed in responding to an emergency, will be provided training, such as briefings or site orientation visits, as appropriate.

The staff reviewed PSAR Chapter 12, Appendix A, Section F. The staff conducted its review to determine if sufficient information was provided to meet the PSAR emergency plan requirements of 10 CFR Part 50, Appendix E, Section II.F. The staff used the guidance of ANSI/ANS15.16-2015, Section 3.10, Maintaining Emergency Preparedness, and the guidance evaluation items contained in NUREG-0849, Section 10.0, Maintaining Emergency Preparedness, to perform the evaluation. Based on its review, the staff finds that the information in the CP application concerning Hermes facility training provisions addresses the applicable guidance of ANSI/ANS15.16-2015 and the guidance evaluation items contained in NUREG-0849. Therefore, the staff finds that the provisions for training are sufficient and meet the applicable PSAR regulatory requirements of 10 CFR Part 50, Appendix E, Section II.F.

Preliminary Analysis of Radiological Consequences of Emergency Situations (10 CFR Part 50, Appendix E, Sections II.G and II.H)

PSAR Chapter 12, Appendix A, Section H, Emergency Equipment and Facilities, states that a preliminary analysis indicates the Hermes EPZ is coincident with the site boundary (PSAR Figure 2.1-3, Project Site Area and Zones Associated with the Facility, shows the Hermes site boundary with respect

to the proposed Hermes reactor building), and that there is no offsite release above the Environmental Protection Agency protective action guides (1 rem whole body or 5 rem thyroid). PSAR Chapter 12, Appendix A, Section H, concludes that there is no need for offsite monitoring teams, a technical support center (TSC), or an emergency operations facility (EOF). PSAR Chapter 12, Appendix A, Section A, also concludes that no offsite emergency organization or offsite emergency plan actions are required to cope with emergencies at the Hermes facility. However, PSAR Chapter 12, Appendix A, Section H, states that timely notification will be made to the public for a declared emergency. PSAR Chapter 12, Appendix A, Section G, also states that state and local governments will be notified as appropriate. PSAR Chapter 12, Appendix A, Sections A.3, B, and C provide preliminary information on the means and timing for notification to state and local government organizations. PSAR Chapter 12, Appendix A, Section H, provides a representative listing of radiation monitoring instruments, portable air samplers, and specific radionuclide identification and analysis instrumentation available for use during an emergency. PSAR Chapter 12, Appendix A, Section H, states that a listing of the current locations for emergency equipment cabinets and other emergency equipment storage areas, plus the representative equipment inventories for these storage locations that will also specify the actual equipment in the Hermes facility, will be provided in a Hermes OL application.

PSAR Chapter 12, Appendix A, Section G, states that 10 CFR Part 50, Appendix E, Section II.G, which contains the requirement that the PSAR include discussion of preliminary analyses projecting the time and means to be employed in the notification of State and local governments and the public in the event of an emergency, is not applicable to Hermes because it is not a nuclear power reactor. However, the staff notes that 10 CFR Part 50, Appendix E, does not preclude applicability of this portion of Section II.G for non-power reactors as appropriate, and therefore the degree to which compliance with this requirement is necessary for a non-power reactor is determined on a case-by-case basis as discussed above.

The staff reviewed PSAR Chapter 12, Appendix A, Section H, and relevant information in other sections of PSAR Chapter 12, Appendix A. The staff conducted its review to determine if sufficient information was provided to meet the PSAR emergency plan requirements of 10 CFR Part 50, Appendix E, Section II.G and Section II.H. The staff used the guidance contained in ANSI/ANS15.16-2015, Section 3.5, Emergency Action Levels (EAL), Section 3.6, Emergency Planning Zones, Section 3.7, Emergency Response, and Section 3.8, Emergency Facilities and Equipment, and the guidance evaluation items contained in NUREG-0849, Section 5, Emergency Action Levels, Section 6, Emergency Planning Zones, Section 7, Emergency Response, and Section 8, Emergency Facilities and Equipment, to perform the evaluation. Based on its review, the staff finds that the information in the CP application discussing Kairos preliminary analysis reflecting the need to include facilities, systems, and methods for identifying the degree of seriousness and potential scope of radiological consequences of emergency situations; reflecting the role of an onsite TSC and the EOF in assessing information, recommending protective action, and disseminating information to the public; and projecting the time and means of offsite notifications, addresses the applicable guidance in ANSI/ANS15.16-2015 and the applicable guidance evaluation items contained in NUREG-0849. Therefore, the staff finds that the information on preliminary analysis of radiological consequences of emergency situations is sufficient and meets the applicable PSAR regulatory requirements of 10 CFR Part 50, Appendix E, Sections II.G and II.H.

Conclusion Based on its evaluation of the information in PSAR Section 12.7 and PSAR Chapter 12, Appendix A, and information in PSAR Chapter 2 as discussed above, the staff finds that the descriptions of Kairos preliminary plans for coping with emergencies address the applicable guidance in ANSI/ANS15.16-2015 and the applicable guidance evaluation items contained in NUREG-0849, and are also consistent with the guidance in NUREG-1537, Parts 1 and 2, and NRC RG 2.6, Revision 2, as applicable. Therefore, the staff concludes that Kairos preliminary plans for coping with emergencies are sufficient and comply with

the applicable requirements of 10 CFR Part 50, Appendix A, Section II, and 10 CFR 50.34(a)(10), which requires that an applicant for a CP provide preliminary emergency planning information. Accordingly, the staff concludes that the emergency planning information in the PSAR is sufficient and meets the applicable guidance and regulatory requirements for the issuance of a CP in accordance with 10 CFR Part 50. Further information as may be required to complete the review of Hermes emergency planning can reasonably be left for later consideration in the FSAR since this information is not necessary for the review of a CP application.

12.8 Security Introduction PSAR Section 12.8, Security, describes the security plan for the Hermes facility.

Regulatory Evaluation The applicable regulatory requirements for the evaluation of Kairos security planning are as follows:

The applicable guidance for the evaluation of Kairos security planning is as follows:

  • NUREG-1537, Parts 1 and 2, Section 12.8, Security Planning.

Technical Evaluation Kairos did not submit a security plan for its CP application. As stated in PSAR Section 12.8, [a]

description of the security plan will be provided with the application for an [o]perating [l]icense consistent with 10 CFR 50.34(c) and will consider the guidance provided in Regulatory Guide (RG) 5.59, Standard Format and Content for a Licensee Physical Security Plan for the Protection of Special Nuclear Material of Moderate or Low Strategic Significance, Revision 1.

The staff evaluated the sufficiency of the preliminary information on security planning, as described in Kairos Power PSAR Section 12.8, using the guidance from Section 12.8, Security Planning, of NUREG-1537, Parts 1 and 2. The staff notes that a security plan is not required by NRC regulations to be submitted for a CP application. The staff also notes that the regulation 10 CFR 50.34(c), referenced by Kairos, may not be applicable to require Kairos to submit a security plan with an OL application because Hermes would utilize low-enriched uranium fuel and would not be a nuclear power reactor, but that Kairos would be required to submit and implement a security plan for Hermes operation consistent with other applicable NRC regulations (e.g., 10 CFR 70.22(k) and 73.67(c)(1)) and OL conditions, as appropriate. Based on its review, the staff determined that the level of detail provided on Hermes security planning is adequate and meets the applicable guidance in NUREG-1537. Accordingly, the staff finds that Kairos commitments to develop a security plan considering the guidance in RG 5.59, Revision 1, provide reasonable assurance that Hermes security planning will comply with applicable requirements.

Conclusion Based on its findings above, the staff concludes the information in Hermes PSAR Section 12.8 is sufficient and meets the applicable guidance and regulatory requirements for the issuance of a CP in accordance with 10 CFR Part 50. Further information as may be required to complete the review of

Hermes security planning can reasonably be left for later consideration in the FSAR since this information is not necessary for the review of a CP application.

12.9 Quality Assurance Introduction Hermes PSAR Section 12.9, Quality Assurance, describes quality assurance for the Hermes facility, and states that the description of Kairos quality assurance (QA) program for the design, construction, and operation of Hermes is based on ANSI/ANS 15.8-1995 (R2005), Quality Assurance Program Requirements for Research Reactors, and the guidance in RG 2.5, Quality Assurance Program Requirements for Research and Test Reactors, Revision 1. Kairos provided its Quality Assurance Program Description (QAPD) as Appendix B to PSAR Section 12 (i.e., PSAR Appendix 12B).

Regulatory Evaluation The applicable regulatory requirements for the evaluation of Kairos quality assurance program are as follows:

  • 10 CFR 50.34, Contents of applications; technical information, paragraph (a), Preliminary safety analysis report, including 10 CFR 50.34(a)(7), which requires that the PSAR include [a]

description of the quality assurance program to be applied to the design, fabrication, construction, and testing of the structures, systems, and components of the facility.

The applicable guidance for the evaluation of Kairos quality assurance program is as follows:

  • NUREG-1537, Parts 1 and 2, Section 12.9, Quality Assurance.
  • NRC RG 2.5, Quality Assurance Program Requirements for Research and Test Reactors, Revision 1.

Technical Evaluation PSAR Appendix 12B provides the Kairos Hermes QAPD. The staff reviewed the information in the QAPD using the guidance in ANSI/ANS-15.8-1995, which is endorsed by NRC RG 2.5, Revision 1. As discussed below, the staff evaluated QAPD Section 1, Introduction, and Section 2, Design, Construction, and Modifications, for the issuance of a CP because those sections apply to Hermes design, fabrication, construction, and testing. However, the staff did not evaluate QAPD Section 3, Facility Operations, because it applies to Hermes operation and is therefore not required for the issuance of a CP. The staffs review and findings for each section of the QAPD are discussed under the headings below.

QAPD Section 1, Introduction Based on its review of QAPD Section 1, Introduction, the staff determined that the description of the scope, applicability, and definitions for the Kairos Hermes QAPD is consistent with the guidance provided in Section 1 of ANSI/ANS-15.8-1995, because it includes information specified in Section 1 of the ANSI/ANS standard regarding matters affecting quality of the structures, systems, and components (SSCs) in the Hermes plant, including the design, fabrication, construction, and testing and states that the terms used in the QAPD are as defined in the ANSI/ANS standard. Therefore, the staff finds the

description in QAPD Section 1 acceptable.

QAPD Section 2, Design, Construction, and Modifications Based on its review of QAPD Section 2.1, Organization, the staff determined that organizational controls described in QAPD Section 2.1 are consistent with the guidance provided in Section 2.1 of ANSI/ANS-15.8-1995, because QAPD Section 2.1 provides an organizational structure and definitions of roles and responsibilities that help ensure the achievement and maintenance of quality by those assigned to perform work. Therefore, the staff finds the description in QAPD Section 2.1 acceptable.

Based on its review of QAPD Section 2.2, Quality Assurance Program, the staff determined that the general QA program requirements in QAPD Section 2.2 are consistent with the guidance provided in Section 2.2 of ANSI/ANS-15.8-1995, because QAPD Section 2.2 states that the Hermes QA program will be established in accordance with the QAPD requirements and be established at the earliest time consistent with Hermes schedule for accomplishing quality-affecting activities. This section also indicates that the QA program provides for the training necessary for Hermes staff to perform quality-affecting activities. The QAPD also applies a graded approach to all activities affecting quality, which the staff finds is consistent with the ANSI/ANS standard and will ensure that controls are applied commensurate with risks associated with controlled items. Therefore, the staff finds the description in QAPD Section 2.2 acceptable.

Based on its review of QAPD Section 2.3, Design Control, the staff determined that Kairos design controls in QAPD Section 2.3 are consistent with the guidance provided in Section 2.3 of ANSI/ANS-15.8-1995, because QAPD Section 2.3 adequately addresses the ANSI/ANS standard recommendations for design requirements, processes, verification, documents and records, verification of commercial grade items, and change controls necessary to maintain design control. The staff also determined that the QAPD Section 2.3 statement that design interfaces shall be identified and controlled, and the design efforts shall be coordinated among the participating organizations, is consistent with the ANSI/ANS standard and will help ensure appropriate coordination among all organizations participating in the design of the Hermes facility. Therefore, the staff finds the description in QAPD Section 2.3 acceptable.

Based on its review of QAPD Section 2.4, Procurement Document Control, the staff determined that Kairos procurement document controls in QAPD Section 2.4 are consistent with the guidance provided in Section 2.4 of ANSI/ANS-15.8-1995 because QAPD Section 2.4 reflects the controls recommended to maintain sufficient technical and quality requirements throughout the procurement process, and ensures that the items and services satisfy the facilitys needs as prescribed in its procurement processes or specifications. Therefore, the staff finds the description in QAPD Section 2.4 acceptable.

Based on its review of QAPD Section 2.5, Procedures, Instructions, and Drawings, the staff determined that Kairos controls for instructions, procedures, and drawings in QAPD Section 2.5 are consistent with the guidance provided in Section 2.5 of ANSI/ANS-15.8-1995, because QAPD Section 2.5 contains the measures recommended to ensure that activities affecting quality are performed in accordance with appropriate documented instructions, quality procedures, or drawings. Therefore, the staff finds the description in QAPD Section 2.5 acceptable.

Based on its review of QAPD Section 2.6, Document Control, the staff determined that Kairos document controls in QAPD Section 2.6 are consistent with the guidance provided in QAPD Section 2.6 of ANSI/ANS-15.8-1995 because they include, as recommended, processes to identify documents to be controlled and how they will be distributed; identification of responsibilities for preparing, reviewing, approving, and issuing documents; and requirements for review of documents for adequacy, completeness and correctness prior to issuance and approval. Therefore, the staff finds the description in QAPD Section 2.6 acceptable.

Based on its review of QAPD Section 2.7, Control of Purchased Items and Services, the staff determined that Kairos controls for purchased items and services in QAPD Section 2.7 are consistent with the guidance provided in Section 2.7 of ANSI/ANS-15.8-1995, because QAPD Section 2.7 includes the information recommended to ensure that suppliers are selected based on evaluation of their capabilities to provide the required items or services. Also, as recommended by ANSI/ANS-15.8-1995, Section 2.7 has measures to control the suppliers performance, establishes the responsibility of the supplier for the quality of their products, requires documented evidence of that quality in accordance with established methods, and establishes a system to ensure that purchased items and services conform to procurement specifications. Therefore, the staff finds the description in QAPD Section 2.7 acceptable.

Based on its review of QAPD Section 2.8, Identification and Control of Items, the staff determined that Kairos controls for identification and control of items in QAPD Section 2.8 are consistent with the guidance provided in Section 2.8 of ANSI/ANS-15.8-1995, because QAPD Section 2.8 provides the recommended measures for item identification and traceability control; employment of physical separation, procedural control, or other appropriate means, when physical identification of items is either impractical or insufficient; and means to identify and control items that have limited calendar or operating life. Therefore, the staff finds the description in QAPD Section 2.8 acceptable.

Based on its review of QAPD Section 2.9, Control of Special Processes, the staff determined that Kairos controls for special processes in QAPD Section 2.9 are consistent with the guidance provided in Section 2.9 of ANSI/ANS-15.8-1995, because QAPD Section 2.9 includes the recommended means to control special processes by instructions, drawings, checklists, travelers, or other appropriate means.

As recommended, QAPD Section 2.9 also indicates that Kairos and its suppliers will be responsible for complying with approved procedures and processes when performing special processes for Hermes, indicates that the procedures or instructions for the special process will include the requirements of applicable codes and standards, and specifies appropriate record maintenance requirements. Therefore, the staff finds the description in QAPD Section 2.9 acceptable.

Based on its review of QAPD Section 2.10, Inspections, the staff determined that Kairos controls for inspections described in QAPD Section 2.10 are consistent with the guidance provided in Section 2.10 of ANSI/ANS-15.8-1995, because QAPD Section 2.10 describes the recommended requirements to plan, document, and perform inspections required to verify conformance of quality affecting items or activities, including items in-process or under construction, to specified requirements. QAPD Section 2.10 also requires the recommended examination of the associated quality records for adequacy and completeness, requires that measuring and test equipment used to perform inspections be identified in the inspection documentation, and describes the qualification and training requirements, including on-the-job training, for the plant personnel performing the inspection activities. Therefore, the staff finds the description in QAPD Section 2.10 acceptable.

Based on its review of QAPD Section 2.11, Test Control, the staff determined that Kairos controls for testing in QAPD Section 2.11 are consistent with the guidance provided in Section 2.11 of ANSI/ANS-15.8-1995 because QAPD Section 2.11 describes the recommended formal testing requirements to verify conformance of designated SSCs to specified requirements and demonstrate satisfactory performance for service or to collect data to support design or fabrication. QAPD Section 2.11 also requires, as recommended by ANSI/ANS-15.8-1995, the documentation and evaluation of test results by a Kairos responsible authority, and that verification and validation of computer programs be performed.

Therefore, the staff finds the description in QAPD Section 2.11 acceptable.

Based on its review of QAPD Section 2.12, Control of Measuring and Test Equipment, the staff determined that Kairos controls for measuring and test equipment (M&TE) in QAPD Section 2.12 are consistent with the guidance provided in Section 2.12 of ANSI/ANS-15.8-1995, because QAPD Section

2.12 includes recommended requirements for control, calibration, and adjustment that need to be performed for tools, gauges, instruments, and other M&TE equipment used for activities affecting quality, as well as measures, consistent with ANSI/ANS recommendations, that will be taken for out-of-calibration devices, and requirements, consistent with ANSI/ANS recommendations, to maintain records of calibration data for each piece of M&TE. Therefore, the staff finds QAPD Section 2.12 acceptable.

Based on its review of QAPD Section 2.13, Handling, Storage, and Shipping, the staff determined that Kairos QAPD Section 2.13 is consistent with the guidance provided in Section 2.13 of ANSI/ANS-15.8-1995, because QAPD Section 2.13 includes the specific controls for handling, storage, and shipping recommended in the ANSI/ANS standard. Therefore, the staff finds QAPD Section 2.13 acceptable.

Based on its review of QAPD Section 2.14, Inspection, Test, and Operating Status, the staff determined that Kairos controls for inspection, test, and operating status in QAPD Section 2.14 are consistent with the guidance provided in ANSI/ANS-15.8-1995 because QAPD Section 2.14 includes ANSI/ANS standard recommended actions that allow the traceability of the status of inspection and test activities of items and avoid the installation or operation of items that have not passed the required inspections and tests. Therefore, the staff finds QAPD Section 2.14 acceptable.

Based on its review of QAPD Section 2.15, Control of Non-Conforming Items and Services, the staff determined that Kairos controls for non-conforming items and services in QAPD Section 2.15 are consistent with the guidance provided in Section 2.15 of ANSI/ANS-15.8-1995 because QAPD Section 2.15 includes the measures recommended to prevent inadvertent installation or use of non-conforming items and to allow identification, documentation, evaluation, and segregation of these items. In addition, as recommended by ANSI/ANS-15.8-1995, QAPD Section 2.15 includes requirements for documenting the technical justification for the acceptability of non-conforming items and for the reexamination of repaired or reworked items, in accordance with applicable Kairos procedures. Therefore, the staff finds QAPD Section 2.15 acceptable.

Based on its review of QAPD Section 2.16, Corrective Actions, the staff determined that Kairos controls for corrective actions in QAPD Section 2.16 are consistent with the guidance provided in Section 2.16 of ANSI/ANS-15.8-1995 because, as recommended, QAPD Section 2.16 requires the prompt identification and correction of conditions adverse to quality and requires that investigation and corrective actions be performed for conditions that are significantly adverse to quality to preclude recurrence. Therefore, the staff finds QAPD Section 2.16 acceptable.

Based on its review of QAPD Section 2.17, Quality Records, the staff determined that Kairos controls for quality records in QAPD Section 2.17 are consistent with the guidance provided in Section 2.17 of ANSI/ANS-15.8-1995 because, as recommended, QAPD Section 2.17 includes requirements to store records applicable to quality for specified periods and under appropriate conditions. Therefore, the staff finds QAPD Section 2.17 acceptable.

Based on its review of QAPD Section 2.18, Assessments, the staff determined that Kairos controls for assessments in QAPD Section 2.18 are consistent with the guidance provided in Section 2.18 of ANSI/ANS-15.8-1995. As recommended, QAPD Section 2.18 requires Kairos to conduct and document periodic assessments of quality-affecting activities during design, construction, or modification to evaluate the effectiveness of the as-implemented QA program and requires the review of such assessments by management. QAPD Section 2.18, as recommended by ANSI/ANS-15.8-1995, also requires Kairos Hermes management to investigate adverse findings, schedule corrective actions, and notify the appropriate assessing organization of any actions taken or planned. QAPD Section 2.18, as recommended ANSI/ANS-15.8-1995, further requires the maintenance of assessment records and requires that the personnel selected for assessment assignments have the requisite experience and training. Therefore, the staff finds QAPD Section 2.18 acceptable.

The staff determined that Kairos did not provide in its QAPD a description of controls for experimental equipment, as recommended by the guidance in ANSI/ANS-15.8-1995, Section 2.19, Experimental Equipment. PSAR Section 10.1 states that Hermes will not include special facilities dedicated to the conduct of reactor experiments or experimental programs. Therefore, the staff finds it acceptable that the QAPD does not include controls for experimental equipment.

Other QAPD Sections The staff notes that Kairos Hermes QAPD Section 3, Facility Operations, provides a description of elements of a QA program for the conduct of operations at Hermes. The staff also notes the QAPD did not include a description of the applicability of the QA program to existing facilities or decommissioning, as recommended by Section 4, Applicability to Existing Facilities, and Section 5, Decommissioning, of the ANSI/ANS-15.8-1995 standard. The regulation at, 10 CFR 50.34(a)(7) only requires that the applicant provide a description of its QA program that will be implemented for design, fabrication, construction, and testing. Therefore, the staff did not evaluate Section 3 of the QAPD for its CP review, because it covers operations and is not required by 10 CFR 50.34(a)(7) to be included in a CP application. Furthermore, the staff finds that ANSI/ANS-15.8-1995, Sections 4 and 5, are not applicable to the Hermes CP application, and it is acceptable that the QAPD does not include this recommended information because Kairos did not indicate that the QAPD will apply to any existing facilities and because submission of decommissioning plans and associated QA provisions is not required until a licensee applies for license termination after permanent cessation of operations. As appropriate, the staff will review information related to QA during operations and decommissioning during future reviews of a Hermes OL application and proposed decommissioning plan, respectively.

Conclusion Based on its evaluation of the Kairos Hermes QAPD, the staff finds that the QAPD discussed in PSAR Section 12.9 and provided in PSAR Appendix 12B meets the guidance relevant to design, fabrication, construction, and testing in Sections 1 and 2 of ANSI/ANS 15.8-1995, which the NRC endorsed in RG 2.5, Revision 1, and that the QAPD is also consistent with the guidance contained within Section 12.9 of NUREG-1537, Parts 1 and 2. Therefore, the staff finds that the Kairos Hermes QAPD is sufficient and complies with the requirements of 10 CFR 50.34(a)(7), which requires that an applicant for a CP provide a description of the QA program to be applied to the design, fabrication, construction, and testing of the SSCs of the facility. Accordingly, the staff concludes that the information in PSAR Section 12.9 and PSAR Appendix 12B is sufficient and meets the applicable guidance and regulatory requirements for the issuance of a CP in accordance with 10 CFR Part 50, and, as such, the Kairos Hermes QAPD is acceptable for implementation during the design and construction of the Hermes facility. Further information as may be required to complete the review of Kairos QA program for the conduct of operations and decommissioning can reasonably be left for later consideration in the FSAR (or a proposed decommissioning plan, as appropriate) since this information is not necessary for the review of a CP application.

In order to provide reasonable assurance that regulatory requirements and license commitments for QA are adequately included in the design, procurement, and construction of the Hermes facility, the staff recommends that the CP include the following condition:

Kairos shall implement the QA program described, pursuant to 10 CFR 50.34(a)(7), in Appendix 12B of Revision X of the Hermes PSAR, including revisions to the QA program in accordance with the provisions below.

Kairos may make changes to its previously accepted QA program description without prior NRC approval, provided the changes do not reduce the commitments in the QA program description as accepted by the NRC. Changes to the QA program description that do not reduce the commitments must be submitted to the NRC within 90 days.

Changes to the QA program description that do reduce the commitments must be submitted to the NRC and receive NRC approval prior to implementation, as follows:

  • The submittal of changes to the QA program description must include all pages affected by the changes and must be accompanied by a forwarding letter identifying the changes, the reason for the changes, and the basis for concluding that the revised program incorporating the changes continues to satisfy the PSAR Revision X QA program description commitments previously accepted by the NRC (the letter need not provide the basis for changes that correct spelling, punctuation, or editorial items).
  • A copy of the forwarding letter identifying the changes must be maintained as a record by Kairos for three years.
  • Changes to the QA program description shall be regarded as accepted by the Commission upon Kairos receipt of a letter to this effect from the appropriate reviewing office of the Commission or 60 days after Kairos submittal to the Commission, whichever occurs first.

12.10 Operator Training and Requalification Introduction PSAR Section 12.10, Reactor Operating Training and Requalification, describes the Hermes operator training and requalification plan.

Regulatory Evaluation The applicable regulatory requirements for the evaluation of Kairos operator training and requalification are as follows:

The applicable guidance for the evaluation of Kairos operator training and requalification is as follows:

  • NUREG-1537, Parts 1 and 2, Section 12.10, Operator Training and Requalification.

Technical Evaluation Kairos did not submit an operator training and requalification plan for its CP application. As stated in Hermes PSAR Section 12.10, [t]he operating training and requalification plan will be provided with the application for the [o]perating [l]icense, consistent with the requirements in 10 CFR 50.34(b)(8), and the plan will be developed in accordance with 10 CFR Part 55, Operators Licenses.

The staff evaluated the sufficiency of the preliminary information on operator training and requalification that Kairos provided in PSAR Section 12.10, using the guidance and acceptance criteria from Section 12.10, Operator Training and Requalification, in NUREG-1537, Parts 1 and 2. The staff notes that an operator training and requalification plan is not required by NRC regulations to be submitted for a CP application. Accordingly, the staff determined that the level of detail provided on Hermes operator training and requalification is adequate for the CP application and meets the applicable acceptance criteria in NUREG-1537, Part 2, Section 12.10. Accordingly, the staff finds that Kairos commitments to develop its operator training and requalification program in accordance with the requirements of 10 CFR Part 55 provide reasonable assurance that Hermes operator training and requalification will comply with applicable requirements.

Conclusion Based on its findings above, the staff concludes the information in Hermes PSAR Section 12.10 is sufficient and meets the applicable guidance and regulatory requirements for the issuance of a CP in accordance with 10 CFR Part 50. Further information as may be required to complete the review of Hermes operator training and requalification can reasonably be left for later consideration in the FSAR since this information is not necessary for the review of a CP application.

12.11 Startup Plan Introduction PSAR Section 12.11, Startup Plan, discusses the Hermes startup plan.

Regulatory Evaluation The applicable regulatory requirements for the evaluation of Kairos startup plan are as follows:

The applicable guidance for the evaluation of Kairos startup plan is as follows:

  • NUREG-1537, Parts 1 and 2, Section 12.11, Startup Plan.

Technical Evaluation PSAR Section 12.11 states that the startup plan will be provided with the application for the Operating License, consistent with the requirements in 10 CFR 50.34(b)(6)(iii).

The staff evaluated the sufficiency of the preliminary information on the Hermes startup plan, as discussed in PSAR Section 12.11, using the guidance and acceptance criteria from Section 12.11, Startup Plan, in NUREG-1537, Parts 1 and 2. Using the guidance in NUREG-1537, the staff considered the statement in the PSAR and concluded that further information regarding a startup plan for operation of the Hermes facility is not necessary for the issuance of a CP given that a startup plan should be based on a final design.

Conclusion

Based on its findings above, the staff concludes the information in Hermes PSAR Section 12.11 is sufficient and meets the applicable guidance and regulatory requirements for the issuance of a CP in accordance with 10 CFR Part 50. Further information as may be required to complete the review of a Hermes startup plan can reasonably be left for later consideration in the FSAR since this information is not necessary for the review of a CP application.

12.12 Environmental Report Kairos did not provide, and the staff did not review, environmental information in the PSAR as described in Section 12.12, Environmental Reports, of NUREG-1537, Parts 1 and 2. In lieu of providing environmental information in the PSAR, Kairos provided environmental information in the form of a separate Environmental Report submitted by letter dated October 31, 2021. The staffs evaluation of Kairos environmental information is documented in a Draft Environmental Impact Statement.

12.13 Material Control and Accounting Plan NUREG-1537, Parts 1 and 2, do not include guidance or acceptance criteria for MC&A plans.

Furthermore, Kairos did not provide, and the staff did not review, a MC&A plan in the PSAR.

While MC&A is not discussed in the PSAR, PSAR Section 9.6 states that Kairos plans to request authorization to possess special nuclear material (SNM) pursuant to 10 CFR Part 70, Domestic Licensing of Special Nuclear Material in the future. In accordance with 10 CFR 70.22(b), applicants requesting a license to possess SNM must submit a full description of their program for the control and accounting of SNM and show compliance with the applicable requirements of 10 CFR Part 74, Material Control and Accounting of Special Nuclear Material.

During the General Audit, Kairos confirmed that it will provide an MC&A plan with a Hermes OL application or other licensing submittal (e.g., a CP amendment) requesting authorization to possess SNM, as appropriate.

Because the CP application does not request authorization to possess SNM, and because an MC&A plan is only required for applicants requesting a license to possess SNM, the staff finds that it is acceptable that the PSAR does not include information on MC&A. Information on MC&A can reasonably be left for later consideration in a Hermes OL application or other licensing application requesting authorization to possess SNM, as appropriate.

12.14 Summary and Conclusions on the Conduct of Operations The staff evaluated the descriptions and discussions of the Hermes conduct of operations as described in PSAR Chapter 12 and finds that the preliminary plans and information on the Hermes conduct of operations meet the applicable guidelines of NUREG-1537, Part 2, allowing the staff to make findings that:

  • Kairos preliminary information and commitments to develop the Hermes organization, review and audit programs, procedures, required actions, reporting and recordkeeping requirements, security plan, and operator training and requalification plans are sufficient and meet the applicable regulatory requirements and guidance for the issuance of a CP. Further information on these items can reasonably be left for later consideration in the FSAR
  • Information on the Hermes startup plan and MC&A plan can reasonably be left for later consideration in the FSAR.
  • The preliminary information on emergency planning is sufficient and meets the applicable regulatory requirements and guidance for the issuance of a CP. Further information can reasonably be left for later consideration in the FSAR and updated emergency plan submitted with an OL application.
  • The Kairos Hermes QAPD is sufficient and meets the applicable regulatory requirements and guidance for the issuance of a CP. Further information related to quality assurance during operations and decommissioning can reasonably be left for later consideration during future reviews of a Hermes OL application and proposed decommissioning plan, respectively.

Based on these findings and subject to the condition referenced above, the staff concludes the following regarding the issuance of a CP in accordance with 10 CFR Part 50:

  • There is reasonable assurance that, 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.

12.15 References American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.1-2007, The Development of Technical Specifications for Research Reactors, American Nuclear Society, La Grange Park, Illinois.

American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.4-2016, Selection and Training of Personnel for Research Reactors, American Nuclear Society, La Grange Park, Illinois.

American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.8-1995, Quality Assurance Programs Requirements for Research Reactors, American Nuclear Society, La Grange Park, Illinois.

American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.16-2015, Emergency Planning for Research Reactors, American Nuclear Society, La Grange Park, Illinois.

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

September 2021. ADAMS ML21272A375 or XXXXX 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. ML21306A131.

Nuclear Regulatory Commission (U.S.) (NRC). Draft Environmental Impact Statement for Construction Permit for the Kairos Hermes Testing Facility. NRC: Washington, D.C. MONTH 202X. ADAMS Accession

No. MLXXXXXXXXX.

Nuclear Regulatory Commission (U.S.) (NRC). NUREG-0849, Standard Review Plan for the Review and Evaluation of Emergency Plans for Research and Test Reactors, NRC: Washington, D.C. October 1983.

ADAMS Accession No. ML062190191.

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). Regulatory Guide 2.5, Quality Assurance Program Requirements for Research and Test Reactors, Revision 1. NRC: Washington, D.C. June 2010. ADAMS Accession No. ML093520099.

Nuclear Regulatory Commission (U.S.) (NRC). Regulatory Guide 2.6, Emergency Planning for Research and Test Reactors and Other Non-Power Production and Utilization Facilities. Revision 2. NRC:

Washington, D.C. 2017. ADAMS Accession No. ML17262A472.

Nuclear Regulatory Commission (U.S.) (NRC). Regulatory Guide 5.59, Standard Format and Content for a Licensee Physical Security Plan for the Protection of Special Nuclear Material, Revision 1. NRC:

Washington, D.C. February 1983. ADAMS Accession No. ML100341301.

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.

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