ML23269A176

Kairos Hermes 2 Construction Permit Application Scheduling and Resource Letter

ML23269A176
Person / Time
Site:	Hermes  File:Kairos Power icon.png
Issue date:	10/11/2023
From:	Michael Orenak NRC/NRR/DANU/UAL1
To:	Hastings P Kairos Power
References
EPID L-2023-CPS-0000, EPID L-2023-CPE-0000
Download: ML23269A176 (1)

Text

October 11, 2023 Mr. Peter Hastings Vice President, Regulatory Affairs and Quality Kairos Power LLC 707 W Tower Ave Alameda, CA 94501

SUBJECT:

KAIROS POWER LLC - HERMES 2 CONSTRUCTION PERMIT APPLICATION REVIEW SCHEDULE AND RESOURCE ESTIMATE (EPIDS: L-2023-CPS-0000 AND L-2023-CPE-0000)

Dear Mr. Hastings:

This letter provides a summary of the schedule and a resource estimate for the detailed review of the Hermes 2 construction permit (CP) application. On September 11, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff sent Kairos Power LLC (Kairos) a letter accepting the Hermes 2 CP application for detailed review (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23233A167). A notice of the acceptance for docketing was published in the Federal Register on September 15, 2023 (88 FR 63632). The tables below provide key milestones for both the safety review and the environmental review.

Milestone Group - Safety Review Estimated Completion Draft Safety Evaluation(1)

March 11, 2024 Safety Evaluation Completion(2)

August 5, 2024 ACRS Review of Safety Evaluation(3)

September 30, 2024 Final Safety Evaluation(4)

November 11, 2024 Notes:

(1) Safety evaluation (SE) sections drafted and information gaps identified.

(2) NRC management and legal review of SE complete.

(3) Advisory Committee for Reactor Safeguards (ACRS) meetings and review complete.

(4) Final SE updated and issued.

Milestone Group - Environmental Review Estimated Completion Draft Environmental Assessment(1)

March 29, 2024 Final Environmental Assessment(2)

August 30, 2024 Notes:

(1)

Draft and legal review of Environmental Assessment (EA) sections completed. Open items resolved.

(2) Publication and issuance activities completed.

The schedule reflects historical review timelines, the NRC staffs best estimate of the level of effort needed for application review areas, similarities and differences in the Hermes 1 and Hermes 2 designs, competing resource demands for concurrent projects, and the NRC staffs understanding of Kaiross deployment timeline for Hermes 2. This schedule does not reflect any

adjustments that would need to be made if the NRC staff determines that it will need to prepare an environmental impact statement (EIS) instead of concluding a finding of no significant impact for the EA. If an EIS is necessary, the NRC staff will issue a revised schedule and resource letter and work to mitigate impacts to the overall project schedule. Additionally, this schedule does not include the hearing process, which would follow the completion of the SE and EA (or EIS, if needed).

The schedule is also based, in part, on Kaiross commitment to provide its responses to Requests for Additional Information (RAIs) within 30 days after the issuance of the RAIs and within 45 days after the issuance of the second round of RAIs, if needed. The applicant is also expected to provide support in a timely and organized manner during technical audits determined necessary by the NRC staff. To achieve this schedule, the NRC staff intends to engage Kairos frequently during the permit review to address review progress and emerging technical issues. Delays in the NRC staffs receipt of necessary information could result in changes to the review schedule. The NRC requests that Kairos inform the NRC staff in writing, as early as possible, should potential delays arise in its support of the schedule.

The NRC staff will conduct its safety-focused review in a risk-informed manner based on the guidance in NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Part 1, Format and Content (ML042430055), and Part 2, Standard Review Plan and Acceptance Criteria (ML042430048). The schedule could change due to several factors, including RAIs, unanticipated changes to the scope of the review, unsolicited supplements to the application, design changes, and other factors.

Based on Kaiross pre-application activities, the recently issued SE (ML23158A265) and EIS (ML23214A269) for the Hermes 1 test reactor, and the information provided in Kaiross Hermes 2 CP application submittal, the NRC staff has estimated that it will need approximately 10,000 NRC staff hours and $75,000 in contractor support to complete the safety and environmental reviews of the Hermes 2 CP application. While the NRC staff intends to leverage as much information as possible from the Hermes 1 safety and environmental reviews, the NRC staff also recognizes that there are several important differences between the Hermes 1 and Hermes 2 facility designs that will necessitate appropriate evaluation by the staff. Notably, the Hermes 2 test reactor includes 2 units with each having an intermediate salt loop, operate for seven years longer than the Hermes 1 test reactor, and include common turbine generator set. These design modifications will necessitate a risk-informed assessment of the staffs findings on the Hermes 1 design in select areas to support a determination of the safety of the Hermes 2 design.

If there are emergent complexities or challenges in the NRC staffs review that would cause changes to the initial forecasted completion date or significant changes in the estimated resources, the reasons for the changes, along with the new estimates will be communicated via separate correspondence. Milestones and resource estimates for hearing activities are not included in the schedule or resource estimate because hearing dates will be established by the Commission, or the Atomic Safety and Licensing Board, and new resource considerations will need to be developed.

If you have any questions specific to the safety review, please contact me at 301-415-3229 or Michael.Orenak@nrc.gov. Questions regarding the environmental review may be directed to Peyton Doub at 301-415-6703 or Peyton.Doub@nrc.gov.

Sincerely, Michael Orenak, Project Manager Advanced Reactor Licensing Branch 1 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Docket Nos.: 50-611 50-612 cc: Distribution via Gov Delivery ListServ Michael D. Orenak Digitally signed by Michael D. Orenak Date: 2023.10.11 08:53:18 -04'00'

ML23269A176 NRR-106 OFFICE NRR/DANU/UAL1:PM NMSS/REFS/ERNRB:PM NRR/DANU/UAL1:LA NAME MOrenak PDoub DGreene DATE 9/26/2023 9/26/2023 9/26/2023 OFFICE NMSS/REFS/ERNRB:BC NRR/DANU/UTB2:BC NRR/DANU/UAL1:BC NAME KErwin CDeMessieres WJessup DATE 9/27/2023 9/28/2023 9/28/2023 OFFICE NRR/DANU/UAL1:PM NAME MOrenak DATE 10/11/2023