ML23065A058

NRR E-mail Capture - Preliminary Hermes Construction Permit Application SE Appendix

ML23065A058
Person / Time
Site:	99902069, Hermes  File:Kairos Power icon.png
Issue date:	03/02/2023
From:	Benjamin Beasley NRC/NRR/DANU
To:	Weidong Wang Advisory Committee on Reactor Safeguards
References
Download: ML23065A058 (20)

Text

From: Benjamin Beasley Sent: Thursday, March 2, 2023 2:07 PM To: Weidong Wang; Larry Burkhart

Subject:

Preliminary Hermes CP SE Appendix Attachments: Preliminary Hermes CP SE Appendix A for ACRS.pdf

Weidong,

Attached is Appendix A from the safety evaluation for the Hermes construction permit application. This Appendix has been reviewed by branch chiefs and received a preliminary review by OGC. However, this appendix is not final because it still needs to be reviewed by division management and receive the final OGC review. Thus, this preliminary appendix could change between now and the approved SE that will be sent to ACRS for formal review.

I am sending this in advance so that members can become familiar with the safety evaluation and begin preparing for the formal review. The NRC staff is willing to answer any questions that members may have.

Ben

~~~~~~~~~~

Benjamin Beasley Senior Project Manager Advanced Reactor Licensing Branch 1 Office of Nuclear Reactor Regulation 301-415-2062

Hearing Identifier: NRR_DRMA Email Number: 1978

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Preliminary Hermes CP SE Appendix Sent Date: 3/2/2023 2:06:51 PM Received Date: 3/2/2023 2:06:00 PM From: Benjamin Beasley

Created By: Benjamin.Beasley@nrc.gov

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"Weidong Wang" <Weidong.Wang@nrc.gov>

Tracking Status: None "Larry Burkhart" <Lawrence.Burkhart@nrc.gov>

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APPENDIX A

POST CONSTRUCTION PERMIT ACTIVITIES - CONSTRUCTION PERMIT CONDITIONS AND ADDITIONAL ITEMS FOR THE OPERATING LICENSE APPLICATION

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.

A.1 Construction Permit Conditions

The U.S. Nuclear Regulatory Commission (NRC) staff (the staff) has determined that a construction permit (CP) needs to be conditioned to require that Kairos will perform analysis of excavations for safety related structures at the site, and implement its quality assurance program during construction. Therefore, the staff recommends that, should the permit be granted, the CP include the conditions set forth below. Additional details on the basis for each of these conditions appears in Chapter 2, Site Characteristics, and Chapter 12, Conduct of Operations, of the Hermes CP safety evaluation (SE).

Proposed Permit SE Section Description Condition 1 2.5, In order to confirm that the exposed bedrock does not show Geology, signs of karstic dissolution when the excavations are complete Seismology, and before the foundation is prepared, Kairos shall perform and detailed geologic mapping of excavations for safet y related Geotechnical engineered structures; examine and evaluate geologic features Engineering discovered in those excavations; and notify the Director of the Office of Nuclear Reactor Regulation, or the Directors designee, as specified in Title 10 of the Code of Federal Regulations (10 CFR), Section 5 0.4, Written communications, once excavations for safety related structures are open for examination by Staff.

2 12.9, Quality In order to provide reasonable assurance that regulatory Assurance requirements and license commitments for Quality Assurance (QA) are adequately included in the design, procurement, and construction of the Hermes facility, Kairos shall implement the QA program described, pursuant to 10 CFR 50.34(a)(7), in Appendix 12B of Revision 2 of the Hermes Preliminary Safety Analysis Report (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 Commission approval, provided the changes do not reduce the commitments in the QA program description as accepted by the Commission. Changes to the QA program description that do not reduce the commitments must be submitted to the Commission within 90 days.

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

• Changes must be submitted as specified in 10 CFR 50.4.

• 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 2 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.

A.2 Additional Items for an Operating License Application

The Hermes CP application provided a preliminary design. In the PSAR and during audit meetings, Kairos identified elements of design, analysis, and administration that require additional development or correction. The staff determined that resolution of these items is not necessary for the issuance of a CP, but that Kairos should ensure that these items are fully addressed in the Final Safety Analysis Report (FSAR) supporting an operating license (OL) application. The staff is tracking these items to ensure that significant issues are considered during the review of an OL application for the Hermes test reactor.

These items constitute information needs but do not form the only acceptable set of information for the FSAR. In addition, these items do not relieve an applicant from any requirement in the regulations that governs the application. After issuance of an OL, these items are not controlled by NRC requirements unless such items are restated in the FSAR.

PSAR Section and/or Associated Description Related Audit Question Documents Section 1.7, Compliance In PSAR Section 1.7, Kairos stated that it will with the Nuclear Waste provide additional information in the OL Policy Act of 1982 application regarding the disposition of high-level waste and spent nuclear fuel.

Section 2.2.3, Analysis of In PSAR Section 2.2.3, Kairos stated that the Potential Accidents at location and quantities of onsite chemical Facilities storage have not yet been determined, so the effects of potential hazards from onsite chemicals will be evaluated in the OL application.

Section 2.2.3.4, Fires In PSAR Section 2.2.3.4, Kairos stated that effects of potential brush or forest fires will be evaluated in the OL application.

Section 2.3.5, Long In PSAR Section 2.3.5, Kairos stated that Term Atmospheric details regarding the long term dispersion Dispersion Estimates for modeling, modeling inputs, and analysis will be Routine Releases provided in the OL application.

Section 2.4, Hydrology In PSAR Section 2.4, Kairos stated that additional information relevant to stream blockage and diversion flows will be provided in the OL application.

Section 2.4.2, Floods, PSAR Sections 2.4.2 and 2.4.3 stated that a and Section 2.4.3, probable maximum flood (PMF) study will be Credible Hydrological discussed with the application for an OL. The Events and Design Basis PM F evaluation should consider flood elevations induced by local intense precipitation and watershed wide probable maximum precipitation events.

PSAR Section and/or Associated Description Related Audit Question Documents Section 2.4.4, In PSAR Section 2.4.4, Kairos stated that Groundwater seasonal changes to groundwater levels will be addressed in the OL application.

Section 2.5.2.1, Karst, In PSAR Sections 2.5.2.1 and 2.5.4.3, Kairos and Section 2.5.4.3, stated that it will supplement the karst Karst; Site investigations with a set of tests and surveys in Characteristics Audit the OL application. These tests and surveys (ML22143B016) include site reconnaissance, light detection and Question 2.5 11 ranging imaging, and inventory of surface depressions in the site area. In addition, deeper boreholes will be drilled at the reactor location selected. Rock cores recovered will be analyzed in the laboratory to characterize the karst features. A site model of the karst features will be developed and presented with the OL application.

Section 2.5.2.3, Soil In PSAR Section 2.5.2.3, Kairos presented Borings; Site results from preliminary laboratory testing of Characteristics Audit site soil layers limited to soil index properties.

Question 2.5 3 Kairos stated that a more comprehensive characterization of the geotechnical properties of both soil and rock layers present at the proposed site will be provided in the OL application. The network of rock fractures (e.g.,

rock joints, bedding planes, small faults, etc.)

will be characterized and used to evaluate the bearing capacity and expected settlement of the reactor foundation.

Section 2.5.3, Vibratory KP-PSAR Section 2.5.3 relies on the information of Ground Motion; NRC NRC 2202 002 the Clinch River Early Site Permit applications Preliminary (ML22040A336) earthquake catalog, which ends in 2013. In KP -

Question 2.5 1 NRC 2202 002, Kairos stated that an updated (ML22024A492) earthquake catalog will be provided in the OL application to demonstrate that the assumptions and conclusions in the Clinch River probabilistic seismic hazard analysis (PSHA) remain valid.

Section 2.5.3, Vibratory In PSAR Section 2.5.3, Kairos stated the Ground Motion design response spectra will be supplemented with site response spectra analyses that rely on in situ shear wave velocity measurements derived from the Clinch River PSHA and updated as appropriate in the OL application.

PSAR Section and/or Associated Description Related Audit Question Documents Section 2.5.4.1, Surface In PSAR Section 2.5.4.1, Kairos stated that Faulting information on surface faulting will be provided in the OL application.

Section 2.5.4.2, In PSAR Section 2.5.4.2, Kairos proposed to Liquefaction Potential; place the Hermes non-safety related foundation Site Characteristics Audit mat over a fill. Kairos will address the effects of Question 2.5 16 potential liquefaction on the foundations of the non-safety related structures surrounding the reactor in the OL application.

Section 2.5.5.2.1, In PSAR Section 2.5.5.2.1, Kairos proposed to Bearing Capacity; Site provide additional details on the bearing Characteristics Audit capacity and expected settlement of the safety Question 2.5 5 related reactor foundation and the non-safety related structures in the OL application. In addition, additional details will be provided on the lateral pressure on the reactor structure and non-safety related structures.

Section 3.4.1.5, In PSAR Sections 3.4.1.5 and 3.4.1.6, Kairos Structural Model, and stated that additional details on the models, Section 3.4.1.6, including the structural model finite element Response Analysis results, assignment of the structural mass, and modeling methods and assumptions for the soil-structure interaction analysis and seismic response analysis, will be provided in the OL application.

Section 3.5.3.2.1, In PSAR Section 3.5.3.2.1, Kairos stated that it External Flood Design will provide the description of the specific Features grading and drainage features in the OL application. The impacts of the site grading and drainage on the safety related structures, systems, and components (SSCs) should be addressed.

Section 3.5.3.2.2, In PSAR Section 3.5.3.2.2, Kairos stated that it Internal Flood and Spray will specify automatic or a manual termination Design Features of flow for water sources external to the safety related portion of the Reactor Building (e.g., fire water) in the OL application.

Section 3.5.3.2.2, In PSAR Section 3.5.3.2.2, Kairos stated Internal Flood and Spray further information on the analysis of the Design Features impacts of internal flooding and spraying will be provided in the OL application.

Section 3.5.3.3.2, In PSAR Section 3.5.3.3.2, Kairos stated that it Seismic Isolation System will provide further details of the base isolation PSAR Section and/or Associated Description Related Audit Question Documents system and associated structural analysis in the OL application.

Section 3.5.3.4, In PSAR Section 3.5.3.4, Kairos stated Conformance with PDC additional detail about the structural design 2 for Other Hazards features for the safety related portion of the Reactor Building, informed by the results of the hazards analysis, will be provided in the OL application.

Table 3.6 2, Design and In footnote 6 to PSAR Table 3.6 2, Kair os Construction Codes and stated that departures from American S ociety Standards for Fluid of Mechanical Engineers ( ASME ) Code Systems requirements, if needed, will be identified in the OL application.

General Audit KP TR 013 NP, Kairos stated during the audit that the OL

( ML22039A336 ) Revision 4 application will document that safety related Question 3.6 1 (ML22263A456) metallic components in the reactor vessel system are bounded by testing conditions in referenced topical report KP TR 013 NP, Metallic Materials Qualification for the Kairos Power Fluoride Salt-Cooled High-Temperature Reactor, Revision 4.

Section 4.2.1.2, Fuel EPRI-In PSAR Section 4.2.1.2, Kairos stated that it Qualification AR 1(NP)-A will demonstrate that the fuel meets the (ML20336A052) conditions and limitations of the NRC SE for EPRI-AR 1(NP)-A, Uranium Oxycarbide (UCO)

Tristructural (TRISO)-Coated Particle Fuel Performance as part of the OL application.

Section 4.2.1.6, In PSAR Section 4.2.1.6, Kairos stated that the Evaluation of Fuel results of a laboratory testing program to Design Bases confirm that the fuels physical form is maintained during operation, the pebble remains buoyant, and there is no significant salt infiltration into the pebble will be provided in the OL application.

Section 4.2.2.3, System In PSAR Section 4.2.2.3, Kairos stated that the Evaluation Reactivity Control and Shutdown System shutdown element insertion versus time will be provided in the OL application.

Section 4.3, Reactor PSAR Section 4.3 stated that coolant purity Vessel System; General limits will be established with consideration Audit question 4.3 6 given to chemical attack and fouling of the vessel. During the audit Kairos indicated the OL application will provide relevant coolant purity PSAR Section and/or Associated Description Related Audit Question Documents limits and describe the bases for establishing the limits, required actions, and time to complete these actions.

Section 4.3 Reactor PSAR Section 4.3 stated the graphite reflector Vessel System; General will be qualified and designed to meet ASME Audit question 4.3 8 Boiler and Pressure Vessel Code Section III Division 5 requirements. During the audit, Kairos indicated the OL application will describe how all applicable requirements of the ASME Boiler and Pressure Vessel Code Section III Division 5 are met.

Section 4.3 Reactor PSAR Sections 4.3.1.1 and 4.3.1.2 state that Vessel System; General the vessel and vessel internals are designed to Audit question 4.3 11 support on-line monitoring, inspection, and maintenance activities. Kairos stated during the general audit that the OL application will provide additional details on how vessel integrity will be assured through monitoring and inspection programs and confirm the vessel is designed to allows for those programs.

Section 4.3.4, Testing In PSAR Section 4.3.4, Kairos stated that an in-and Inspection service inspection program that includes the reactor vessel and internals will be provided in the OL application.

Section 4.4.3, Biological In PSAR Section 4.4.3, Kairos stated that an Shield - Evaluation evaluation of the performance of the biological shield to meet 10 CFR Part 20, Standards for Protection Against Radiation, will be provided in the OL application.

Section 4.5.1.1, In PSAR Section 4.5.1.1, Kairos stated that Overview of Core initial startup and power ascension will be Nuclear Design discussed in the OL application.

Section 4.5, Nuclear Kairos stated during the audit that the OL Design; Accident application will provide specific details of the Analysis Audit pebble burnup monitoring.

(ML22041B665) question 67 Section 4.6.1.2, Coolant In PSAR Section 4.6.1.2, Kairos stated that Flow Path qualification or functional testing plans and results needed to validate performance assumed in the safety analysis will be provided in the OL application.

PSAR Section and/or Associated Description Related Audit Question Documents Section 4.6.3, System In PSAR Section 4.6.3, Kairos stated that the Evaluation results of analyses supporting the inherent stability of the reactor will be provided in the OL application.

Section 4.7.4, Testing In PSAR Section 4.7.4, Kairos stated that an in-and Inspection service inspection program that includes the reactor vessel support system will be provided in the OL application.

Section 5.1.1.1, Reactor KP-TR 005 NP PSAR Section 5.1.1.1 stated that the properties Coolant; General Audit A, Revision 1 of the Flibe reactor coolant can be found in KP question 5.1 13 (ML20219A591) TR 005 NP-A, Revision 1. Kairos stated during the audit that the OL application will describe how Flibe properties are confirmed.

Section 5.1.3, Primary In PSAR Section 5.1.3, Kairos stated that Heat Transport System thermodynamic data to calculate transport of radionuclides through Flibe will be justified in the OL application.

Section 5.1.3, Primary PSAR Section 5.1.3 describes a postulated air Heat Transport System; ingress event. Kairos stated during the audit General Audit question that the OL application will provide results of 5.1 4 material qualification testing related to postulated air ingress into the primary heat transport system (PHTS) and its effects on materials used in the reactor vessel system, including graphite components.

Section 5.1.4, Primary In PSAR Section 5.1.4, Kairos stated that Heat Transport System descriptions of testing and inspection of PHTS will be provided with the OL application.

Section 6.2, Functional In PSAR Section 6.2, Kairos stated that the Containment specified acceptable system radionuclide release design limits and technical specifications supporting the functional containment concept will be provided in the OL application.

Section 6.3, Decay Heat Kairos stated during the audit that the OL Removal System application will e valuate the magnitude and (DHRS) Audit effects of thermal gradient asymmetry in the (ML22039A226) question event of loss of inventory in one D HRS train.

6.3 10 Section 6.3.4, Decay In PSAR Section 6.3.4, Kairos stated that Heat Removal System descriptions of testing and inspection of DHRS will be provided with the OL application.

PSAR Section and/or Associated Description Related Audit Question Documents Section 7.2.3, System In PSAR Section 7.2.3, Kairos stated that Evaluation further analysis of the timeliness of Plant Control System (PCS) signals will be provided in the OL application.

Section 7.2.3, System In PSAR Section 7.2.3, Kairos stated that Evaluati on specific design features and the SSCs to which they are applied will be provided in the OL application.

Section 7.2.3, System In PSAR Section 7.2.3, Kairos stated that Evaluation additional information on the PCS that is dependent on the final design of reactor SSCs, such as hardware and software specifics, software flow diagrams, a description of how the operation and support requirements will be met, and the basis for PCS system reliability and reliability targets, will be provided in the OL application.

Section 7.3, Reactor In PSAR Section 7.3, Kairos stated that the Protection System final design for the neutron flux monitoring will be provided in the OL application.

Section 7.3, Reactor In PSAR Section 7.3, Kairos stated that the Protection System Reactor Protection System (RPS) alarm signals to the main control room and information on the minimum redundancy in the RPS to permit period testing without compromising RPS function will be provided in the OL application.

Section 7.3, Reactor In PSAR Section 7.3, Kairos stated that a Protection System description of how the RPS operational and support requirements will be met, including the enclosure housing the RPS cabinets, will be provided in the OL application.

Section 7.4.3.1, Main In PSAR Section 7.4.3.1, Kairos stated that a Control Room description of the analysis of operator dose will be provided in the OL application.

Section 7.4.3.2, Remote In PSAR Section 7.4.3.2, Kairos stated that Onside Shutdown Panel procedures for safe shutdown of the reactor through the remote onsite shutdown panel will be provided in the OL application.

Section 7.5.3, Sensors-In PSAR Section 7.5.3, Kairos stated that the System Evaluation number and type of RPS sensors needed to be consistent with the safety analysis and their suitability for their operating environment will be provided in the OL application.

PSAR Section and/or Associated Description Related Audit Question Documents Table 7.5 1, Parameter In PSAR Table 7.5 1, Kair os stated that the Range for Safety parameter ranges for vessel level, area Related Sensors radiation, source range neutronics, and power range neutronics will be provided in the OL application.

Table 7.5 2, Par am et er In PSAR Table 7. 5 2, Kair os stated that the Range for Non Safety parameter ranges for vessel level, area Related Sensors radiation, pressure, and flow rate in the reactor vessel will be provided in the OL application.

Section 8.3.1.1, Backup In PSAR Section 8.3.1.1, Kairos stated that a Generators list of the specific essential loads that receive backup power will be provided in the OL application.

Section 9.1.1, Chemistry In PSAR Section 9.1.1, Kairos stated that a list Control System of the specific essential loads that receive backup power will be provided in the OL application.

Section 9.1.1, Chem ist ry Kairos stated during the audit that the OL Control System; General application will provide all coolant purity Audit question 9.1 3 specifications, required actions, time to complete these actions if specifications are not met, and how the specifications are consistent with results of material compatibility testing (e.g., metallic material corrosion testing, fuel qualification testing, etc.).

Section 9.1.1, Chemistry KP-In KP-NRC 2208 007, Kairos stated that the OL Control System ; General NRC 2208 007 application will demonstrate that the Chemistry Audit question 9.1 2 (ML22231B228) Control System can measure a well mixed representative sample of the reactor coolant.

Section 9.1.4.1.1, RV In PSAR Section 9.1.4.1.1, Kairos stated that Coolant Level additional details on the inventory management Management Tank system vessel level monitoring will be provided in the OL application.

Section 9.3, Pebble In PSAR Section 9.3.1.5, Kairos stated that a Handlin g and Storage summary of the criticality analyses confirming System the Pebble Handling and Storage System (PHSS) design maintains a safe geometrical configuration will be provided in the OL application.

Sect ion 9.3, Pebble Kairos stated during the audit that the OL Handling and Storage application will provide the detailed spent fuel System ; General Audit storage canister design, including how question 9.3 2 hydrofluoric acid (HF) effects will be managed.

PSAR Section and/or Associated Description Related Audit Question Documents Section 9.3.1.5, Pebble In PSAR Section 9.3.1.5, Kairos stated that Inspection further details related to inspections for wear and damage of moderator and fuel pebbles will be provided in the OL application.

Section 9.4, Fire In PSAR Section 9.4, Kairos stated that a Protection Systems and description of the fire protection program and a Programs fire hazards analysis will be provided in the OL application.

Section 9.6, Possession In PSAR Section 9.6, Kairos stated that a and Use of Byproduct, description of the administrative procedures Source, and Special related to use of byproduct, source, and special Nuclear Material nuclear material will be provided in the OL application.

Section 9.7, Plant Water Kairos stated during the audit that the OL Systems; General Audit application will identify all auxiliary water question 9.72 systems which connect to a system containing radioactive material and will be designed to meet the requirements of 10 CFR 20.1406.

Section 9.7.3, In PSAR Section 9.7.3, Kairos stated that, for Component Cooling the Component Cooling Water System, specific Water System design features and the SSCs to which they are applied will be provided in the OL application.

Section 9.8.1, Remote In PSAR Section 9.8.1, Kairos stated that, for Maintenance and the Remote Maintenance and Inspection Inspection System System, specific design features and the SSCs to which they are applied will be provided in the OL application.

Section 9.8.4, Cranes In PSAR Section 9.8.4, Kairos stated that and Rigging further information about the design of the superstructure in the event of a fire will be provided in the OL application.

Section 11.1, Radiation In PSAR Section 11.1, Kairos stated that Protection additional details of the radiation protection (RP) programs will be provided in the OL application.

Section 11.1.1, Radiation In PSAR Section 11.1.1, Kairos stated that Sources additional details of radiation sources, including activity and external radiation fields in the facility, will be provided in the OL application.

Section 11.1.2, Radiation In PSAR Section 11.1.2 and 11.1.3, Kairos Protection Program, and stated that additional details for both the RP program and the as low as reasonably PSAR Section and/or Associated Description Related Audit Question Documents Section 11.1.3, ALARA achievable (ALARA) program will be provided Program in the OL application.

Section 11.1.4, Radiation In PSAR Section 11.1.4, Kairos stated that Monitoring and additional details of radiation monitoring and Surveying surveying, including a description of the equipment, methods, and procedures, will be provided in the OL application.

Section 11.1.5, Radiation In PSAR Section 11.1.5, Kairos stated that Exposure Control and additional details on dosimetry, radiation Dosimetry 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 the OL application.

Section 11.1.5, Radiation In PSAR Section 11.1.5, Kairos stated that an Exposure Control and effluent analysis corresponding to the final Dosimetry detailed design will be provided in the OL application.

Section 11.1.6, In PSAR Section 11.1.6, Kairos stated that a Contamination Control description of design features for the control of radioactive contamination at the Hermes facility will be provided in the OL application.

Section 11.1.7, In PSAR Section 11.1.7, Kairos stated that a Environmental description of the radiological environmental Monitoring monitoring program will be provided in the OL application.

Section 11.2.1, In PSAR Section 11.2.1, Kairos stated that a Radioactive Waste detailed description of the radioactive waste Management Program management program will be provided with the OL application.

Section 11.2.2, In PSAR Section 11.2.2, Kairos stated that a Radioactive Waste description of radioactive waste handling Handling Systems and systems design and controls will be provided in Controls the OL application.

Section 11.2.3, Release In PSAR Section 11.2.3, Kairos stated that a of Radioactive Waste description of the radioactive effluents from the facility, including points of effluent release and effluent monitoring equipment, will be provided in the OL application.

Section 12.1.3, Staffing In PSAR Section 12.1.3, Kairos stated that specific staffing considerations, minimum staffing levels, allocation of control functions, PSAR Section and/or Associated Description Related Audit Question Documents overtime restrictions, shift turnover, procedures, training, and availability of Senior Operators during routine operations will be provided in the OL application.

Section 12.1.4, Selection In PSAR Section 12.1.4, Kairos stated that a and Training of description of the training program and the Personnel required minimum qualifications for facility staff will be provided in the OL application.

Section 12.1.5, Radiation In PSAR Section 12.1.5, Kairos stated that Safety details related to the authority of the RP program staff with respect to facility operations will be provided in the OL application.

Section 12.2, Review In PSAR Section 12.2, Kairos stated that and Audit Activities details of review and audit activities and who holds the approval authority and how it communicates and interacts with facility and corporate management will be provided in the OL application.

Section 12.3, Procedures In PSAR Section 12.3, Kairos stated that a description of the facility procedures, including the review, approval, and changes processes, will be provided in the OL application.

Sections 12.4, Required In PSAR Sections 12.4, 12.5 and 12.6, Kairos Actions, 12.5, Reports, stated that technical specifications will be and 12.6, Records provided in the OL application.

Appendix 12A, Section In PSAR Appendix 12A, Section A.2, Kairos A.2, Authorities and stated that additional roles and responsibilities Responsibilities of for emergency response personnel emergency Facility Emergency classification levels and the associated Personnel protective actions will be provided in the OL application.

Appendix 12A, Section In PSAR Appendix 12A, Section B, Kairos B, Authorities and stated that the arrangements with the City of Responsibilities of Oak Ridge and Oak Ridge Central Fire Station, Governmental Agencies Oak Ridge Police Department, Oak Ridge Methodist Medical Center, and the State of Tennessee, will be obtained and documented in the OL application.

Appendix 12A, Section In PSAR Appendix 12A, Section F, Kairos F, Training stated that the details of the training program for emergency response personnel will be provided in the OL application.

PSAR Section and/or Associated Description Related Audit Question Documents Appendix 12A, Section In PSAR Appendix 12A, Section H.2, Kairos H.2, Assessment stated that a listing of the current locations for Facilities and Equipment emergency equipment cabinets and other emergency equipment storage areas, plus representative equipment inventories for these storage locations, will be provided in the OL application.

Appendix 12A, Section In PSAR Appendix 12A, Section H.5, Kairos H.5, Instrumentation for stated that the actual equipment in the Hermes Specific Radionuclide facility for specific radionuclide identification Identification and and analysis will be provided in the OL Analysis application.

General Audit question NUREG 0849, Kairos stated during the audit that the OL 12.2.7 1 Standard application will provide additional details and Review Plan for features on the Hermes reactor facility access the Review and routes following the guidance in NUREG 0849.

Evaluation of Emergency Plans for Research and Test Reactors, (M L062190191 )

General Audit question 10 CFR 50, Kairos stated during the audit that the OL 12.2.7 2a Appendix E, application will provide additional details on the Section II.A and emergency organization and the relationship NUREG 0849 with other support organizations consistent with NUREG 0849.

General Audit question 10 CFR 50, Kairos stated during the audit that the OL 12.2.7 2c Appendix E, application will provide additional descriptionsSection II.A and of organizational responsibilities, including the NUREG 0849 24-hour on-shift staff positions and lines of succession consistent with NUREG 0849.

General Audit question NUREG 0 849 Kairos stated during the aud it that the OL 12.2.7 3 application will describe agreements or arrangements with local emergency response agencies that would augment and extend the capability of the Hermes facility's emergency organization and also identify any procedures developed for emergency response coordination consistent with NUREG 0849.

General Audit question NUREG 0 849 Kairos stated during the audit that the OL 12.2.7 4 application will provide Hermes emergency classification descriptions as described in NUREG 0 849, Section 4.0.

PSAR Section and/or Associated Description Related Audit Question Documents Section 13.1, Initiating Kairos stated during the audit that the OL Events and Scenarios, application will provide dose analyses for and Section 13.2, events bounded by the maximum hypothetical Accident Analysis and accident (MHA) release, such as salt spill,

Determination of PHSS break, and seismic, along with a Consequences, Accident comparison to the acceptance criteria for the Analysis Audit question figures of merit in PSAR Table 13.1 1.

13 Section 13.1.2, Insertion In KP-TR 018 NP Section 4.5.2.2 and during of Excess Reactivity; the audit, Kairos stated that t he OL application Accident Analysis Audit will provide analyses for a range of insertion question 48 rates for insertion of excess reactivity scenarios.

Section 1 3.1.2, Insertion Kairos stated during the audit that the OL of Excess Reactivity; application will provide a just ification for t he Accident Analysis Audit conservatism of the decay heat methodology question 55 used as part of the postulated event analysis methodology and Chapter 1 3 calculations.

Section 1 3.1.2, Insertion Kairos stated during t he audit that deviations of of Excess Reactivity; component temperatures above the MHA will Accident Analysis Audit be addressed and justified case by case in the question 56 OL application.

Section 1 3.1.2, Insertion Kairos stated during the audit that the OL of Excess Reactivity; application will provide the underlying Accident Analysis Audit assumptions for mapping between nuclear question 57 design, fuel performance, and safety analysis assumptions.

Accident Analysis Audit KP-TR 018 NP Kairos stated during the audit that the question 53 8 methodology in KP TR 018 NP, Postulated Event Analysis Methodology, will be updated as part of the OL application (or in a separate topical report).

Section 13.1.4, Loss of In KP-TR 018 NP, Sec t ion 3.2.2.4, Kairos Forced Circulation stated that the OL application will provide analyses with a spectrum of reactor decay heat levels and operating power levels for long t erm overcooling scenarios.

General Audit question Kairos stated during the audit that the OL 14 3 application will provide analyses demonstrating that vessel temperature is not needed as a Limiting Safety System Setting (LSSS) because the other LSSSs will ensure that unacceptable vessel temperatures will not be reached.

PSAR Section and/or Associated Description Related Audit Question Documents Section 14.1, Technical In PSAR Section 14.1, Kairos stated that the Specifications technical specifications and parameter limits Introduction will be provided in the OL application.

Table 14.1 1, Proposed In PSAR Table 14. 1 1, Kairos stated that Variables and Conditions design features and administrative controls will for Technical be provided in the OL application.

Specifications Section 1 5. 2, Financial In PSAR Section 15.2, Kairos stated that Ability t o Operate t he e stimates of the total annual operating costs for Kairos Power Facility each of the first five years of operation of the facility will be provided in the OL application.

Section 1 5. 3, Financial In PSAR Section 15.3, Kairos stated that Ability t o Decommission information regarding funds to decommission t he Kairos Power Facility the facility and a site specific decommissioning plan will be provided in the OL application.

Section 1 5. 5, Nuclear I n PSAR Section 1 5.5, Kairos stated that it will Insurance and Indemnity obtain $1 million in financial protection in accordance with 10 CFR 140.13 prior to being licensed to possess fuel. Kairos also stated that the amounts of financial insurance required by 10 CFR 140.12(b) and documentation required by 10 CFR 140.15 will be provided in the OL a pplication.

Section 17.1, In PSAR Section 17.1, Kairos stated that a Decommissioning decommissioning report for the facility will be provided in the OL application.

KP TR 017 NP, KP FHR In KP TR 0 17 N P Section 7.1, Kairos stated Core Design and that the completion of verification and validation Analysis M ethodology, of the core design and analysis codes and Section 7.1 methodology, including uncertainties, will be provided in the OL application.

A.3 Research and Development Items

The provisions of 10 CFR 50.34(a)(8) require that the PSAR identify those structures, systems, or components of the facility that require additional research and development to confirm the adequacy of their design; and identification and description of the research and development program which will be conducted to resolve any safety questions associated with such structures, systems, or components; and a schedule of the research and development program showing that such safety questions will be resolved at or before the latest date stated in the application for completion of construction of the facility. Kairos stated it will complete the following research and development activities before the latest date of completion of construction activities in December 2026.

PSAR Section Associated Documents Description Section 4.2.1, Reactor KP -TR 0 11 N P, Fuel Perform a laboratory testing Fuel Qualification Methodology for program to confirm fuel pebble the Kairos Power Fluoride behavior.

Salt Cooled High Temperature Reactor (KP FHR), Revision 2 (ML22186A215)

Section 4.3, Reactor KP TR 0 1 3 N P, Metallic Perform testing of high temperature Vessel System Materials Qualification for the material to qualify Alloy 316H and Kairos Power Fluoride Salt ER16 8 2.

Cooled High Temperature Reactor, Revision 4 (ML22263A456)

Section 4.3, Reactor KP-TR 0 1 4 N P, Graphite Perform analysis related to Vessel System Material Qualification for the potential oxidation in certain Kairos Power Fluoride Salt postulated events for the Cooled High Temperature qualification of the graphite used in Reactor, Revision 4 the reflector structure.

(ML22259A142)

Section 4.3.4, Reactor Develop a high temperature Vessel System Testing material surveillance sampling and Inspection program for the reactor vessel and internals.

Section 4.5, Nuclear Development and validation of Design computer codes for core design and analysis methodology.

Section 4.6, Thermal Develop and perform qualification Hydraulic Design testing for a fluidic diode device.

Section 5.1.3, Primary Justification of thermodynamic data Heat Transport System and associated vapor pressure

- System Evaluation correlations of representative species.

PSAR Section Associated Documents Description Section 7.5.3, Sensors Develop process sensor technology

- System Evaluation for key reactor process variables.

Section 9.1.1, Develop the reactor coolant Chemistry Control chemical monitoring System instrumentation.