ML23117A061

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Kairos Non-Power Reactor Hermes Construction Permit Application - Safety Evaluation for Chapter 14, Technical Specifications
ML23117A061
Person / Time
Site: 99902069, Hermes  File:Kairos Power icon.png
Issue date: 04/27/2023
From: Halnon G
Advisory Committee on Reactor Safeguards
To: David Petti
Advisory Committee on Reactor Safeguards
References
Download: ML23117A061 (1)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, DC 20555 - 0001 April 27, 2023 MEMORANDUM TO:

David Petti, Lead Kairos Hermes License Application Review Subcommittee Advisory Committee on Reactor Safeguards FROM:

Greg Halnon, Member Advisory Committee on Reactor Safeguards

SUBJECT:

INPUT FOR ACRS REVIEW OF THE KAIROS CONSTRUCTION PERMIT APPLICATION - DRAFT SAFETY EVALUATION FOR CHAPTER 14, TECHNICAL SPECIFICATIONS In accordance with 10 CFR 50.34(a)(5), the variables and conditions that are expected to be subject to technical specifications for the Hermes test reactor facility are provided in Chapter14 of the Preliminary Safety Analysis Report (PSAR). The variables and conditions are the result of the preliminary safety analysis described in the various sections of the PSAR. The technical specification (TS) should state the limits, operating conditions, and other requirements imposed on the facility operations to protect the environment and the health and safety of the public.

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Background===

This chapter of the PSAR provides the information required by NUREG-1537 by following ANSI/ANS 15.1-2007, The Development of Technical Specifications for Research Reactors.

One notable difference is the language in 10 CFR 50.36(c)(2)(ii)(A): a significant abnormal degradation of the reactor coolant pressure boundary is not applicable due to the unique use of a functional containment. Hence, an exemption will be sought as part of the operating license application to change the language to more appropriate significant abnormal degradation of the functional containment. The remainder of the chapter follows ANSI/ANS 15.1 and includes:

Safety Limits and Limiting Safety System Settings Limiting Conditions for Operations Surveillance Requirements Design Features, and Administrative Controls.

The detail and specificity for a construction permit phase of the application is appropriate. The details will be developed as the detailed design of the systems are developed and operability requirements identified.

SE Summary PSAR Chapter 14 provided the staff with sufficient information to conclude the level of detail and breadth of the discussion meets the applicable requirements for a construction permit. The detailed TS will be supplied with the operating license application. Since the review of such detailed TS is not required for a construction permit, the staff will provide much attention to the Final Safety Analysis Report (FSAR) chapters of the operating license application.

Discussion Although I have no concerns with the PSAR or draft SE, there are some items to document to ensure a comprehensive review will be completed upon committee review of the operating license application and FSAR. The information provided in the PSAR is very non-specific relative to the actual system setpoints, operations, and transient response of support systems. It will therefore be very important to map the support systems functional requirements, design limits, and operability requirements to any TS that may be required to meet the intent of TS control (environmental protection and public health and safety). Additionally, with the first application of a functional containment in a reactor plant, this function must be carefully assessed for interactions with other key systems/function such as coolant leakage monitoring and mission times of systems responding to transient condition. Additionally, there is a heavy reliance on natural circulation for cooling so these components must be assessed for TS controls as well, especially for pre-transient operability requirements. The unique nature of this first-of-a-kind reactor plant must not assume past TS will be inclusive of all the requirements, hence the guidance in NUREG-1537 and ANSI/ANS 15.1 should be carefully applied.

Recommendation(s)

I recommend no further action for the PSAR.

References

1. USNRC, Draft Safety Evaluation for Hermes NonPower Reactor Preliminary Safety Analysis Report Chapter 14, 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 27, 2023

SUBJECT:

INPUT FOR ACRS REVIEW OF THE KAIROS CONSTRUCTION PERMIT APPLICATION - DRAFT SAFETY EVALUATION FOR CHAPTER 14, TECHNICAL SPECIFICATIONS Package No: ML23117A000 Memo Accession No: ML23117A061 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 GHalnon DATE 4/27/2023 4/27/2023 4/27/2023 4/27/2023 OFFICIAL RECORD COPY