ML23117A050
| ML23117A050 | |
| Person / Time | |
|---|---|
| Site: | 99902069, Hermes File:Kairos Power icon.png |
| Issue date: | 04/29/2023 |
| From: | Matthew Sunseri Advisory Committee on Reactor Safeguards |
| To: | David Petti Advisory Committee on Reactor Safeguards |
| References | |
| Download: ML23117A050 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, DC 20555 - 0001 April 29, 2023 MEMORANDUM TO:
David Petti, Lead Kairos Power Licensing Subcommittee Advisory Committee on Reactor Safeguards FROM:
Matthew Sunseri, Member Advisory Committee on Reactor Safeguards
SUBJECT:
INPUT FOR ACRS REVIEW OF KAIROS NON-POWER REACTOR HERMES CONSTRUCTION PERMIT APPLICATION - DRAFT SAFETY EVALUATION FOR CHAPTER 12, CONDUCT OF OPERATIONS In response to the Subcommittees request, I have reviewed the NRC staffs draft safety evaluation (SE) with no open items, and the associated section of the applicants Preliminary Safety Analysis Report (PSAR), for Chapter 12, Conduct of Operations. The following is my recommended course of action concerning further review of this chapter and the staffs associated safety evaluation.
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Background===
Chapter 12 of the SE documents the staffs review of conduct of operations, quality assurance, emergency planning, material control and accounting and start up planning.
SE Summary The SE documents the staffs evaluation of the applicants design for compliance with applicable regulations and standards. The NRC staff evaluated the descriptions and discussions of Kaiross proposed conduct of operations, operator training, quality assurance program, emergency plan and startup plan. The NRC staff found that the descriptions and discussions of Kairos proposals are sufficient and meet the applicable regulatory requirements and guidance, and acceptance criteria, for the issuance of a construction permit.
Discussion I observe that the application was well documented, and the staffs evaluation thorough. I did not identify any specific deficiencies in my review. I do have a few observations worth noting; however, none are considered needing further review as a cross-cut focus area topic.
Matthew W.
Sunseri Digitally signed by Matthew W.
Sunseri Date: 2023.04.29 08:34:32 -04'00'
The plant manager has responsibility for protecting personnel from exposure to radiation; however, the radiation protection and chemistry functions report to the manager of technical services. This alignment is likely satisfactory for the construction phase; however, consideration should be given to aligning the radiation protection and chemistry functions with the plant manager for the operations phase.
Kairos stated that the operator training program will comply with 10 CFR Part 55 and will be submitted with the application for an operating license.
There is a minor discrepancy between chapter 12.1 of the PSAR and chapter 2 of the Hermes Quality Assurance plan. Chapter 12 depicts a reporting line through the Site Executive. Chapter 2 shows that quality assurance reports through the safety and quality assurance function to the Chief Executive Officer. Chapter 2 includes a footnote that states QA function has direct access to levels of management necessary to assure effective execution of the QA program irrespective of the organization structure. The Hermes Quality Assurance plan is the controlling document and accurately reflects the authority of the quality assurance function. It would be beneficial to add a similar footnote to PSAR Chapter 12 for clarity and consistency.
A noted positive aspect of the emergency plan is the early engagement with the City of Oak Ridge and Oak Ridge Central Fire Station, Oak Ridge Police Department, Oak Ridge Methodist Medical Center, county agencies, the State of Tennessee, and other federal agencies.
Kairos did not provide information on nor did the staff evaluate material control and accountability. A detailed material control and accountability plan will be presented by Kairos during the operating license application.
Kairos stated that a startup plan will be submitted with the application for an operating license.
Recommendation As lead reviewer for Hermes SE Chapter 12, I recommend that no additional Committee reviews are necessary for Conduct of Operations.
References
- 1. USNRC, Draft Safety Evaluation for Hermes NonPower Reactor Preliminary Safety Analysis Report Chapter 12, January 2023 (ML23017A120)
- 2. Kairos Power LLC, Submittal of the Preliminary Safety Analysis Report for the Kairos Power Fluoride Salt-Cooled, High Temperature Non-Power Reactor (Hermes), Revision 2, February 2023 (ML23055A672)
- 3. USNRC, NUREG-1537, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Format and Content, issued February 1996 (ML042430055)
- 4. USNRC, NUREG-1537, Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Standard Review Plan and Acceptance Criteria, issued February 1996 (ML042430048)
April 29, 2023
SUBJECT:
INPUT FOR ACRS REVIEW OF KAIROS NON-POWER REACTOR HERMES CONSTRUCTION PERMIT APPLICATION - DRAFT SAFETY EVALUATION FOR CHAPTER 12, CONDUCT OF OPERATIONS Package No: ML23117A000 Memo Accession No: ML23117A050 Publicly Available Y Sensitive N Viewing Rights:
NRC Users or ACRS Only or See Restricted distribution *via e-mail OFFICE ACRS/TSB*
SUNSI Review*
ACRS/TSB*
ACRS*
NAME WWang WWang LBurkhart MSunseri DATE 4/27/2023 4/27/2023 4/27/2023 4/29/2023 OFFICIAL RECORD COPY