ML23300A144

Kairos Power Response to Hermes 2 General Audit Question 1.5-2

ML23300A144
Person / Time
Site:	Hermes  File:Kairos Power icon.png
Issue date:	10/27/2023
From:	Hastings P Kairos Power
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
KP-NRC-2310-006
Download: ML23300A144 (1)

Text

KP-NRC-2310-006 Kairos Power LLC www.kairospower.com 707 W Tower Ave, Suite A 5201 Hawking Dr SE, Unit A 2115 Rexford Rd, Suite 325 Alameda, CA 94501 Albuquerque, NM 87106 Charlotte, NC 28211 October 27, 2023 Docket No. 50-0611 Docket No. 50-0612 US Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Kairos Power LLC Kairos Power Response to Hermes 2 General Audit Question 1.5-2

References:

1. Letter, Kairos Power LLC to Document Control Desk, Submittal of the Preliminary Safety Analysis Report for the Hermes 2 Kairos Power Fluoride Salt-Cooled, High Temperature Non-Power Reactor (Hermes 2), Revision 0, July 14, 2023 (ML23195A122)

2. Audit Plan, Nuclear Regulatory Commission, Kairos Power LLC - Plan for a General Audit of the Hermes 2 Construction Permit Application, October 3, 2023 (ML23268A446)

3. Email, Nuclear Regulatory Commission, Samuel Cuadrado de Jesus to Darrell Gardner and Drew Peebles, General and Accident Analysis Audit Reports-Hermes Construction Permit PSAR (Docket Number 05007513), June 9, 2023 (ML23160A287)

4. Email, Nuclear Regulatory Commission, Matthew Hiser to Drew Pebbles and Darrell Gardner, Hermes Audit Reports, April 25, 2023 (ML23115A480)

In July 2023, Kairos Power submitted a Preliminary Safety Analysis Report (PSAR) (Reference 1) as part of the Construction Permit Application (CPA) for the Hermes 2 test reactor. This letter transmits a response to NRC Question 1.5-2 from the Hermes 2 general audit (Reference 2) regarding the applicability of Hermes CPA audit reports to the Hermes 2 CPA. Kairos Power requests NRC review of the response in support of continued review of the Hermes 2 test reactor construction permit application.

Kairos Power reviewed the Hermes PSAR audit reports (References 3 and 4) to determine their applicability to the Hermes 2 CPA. Kairos Powers review of the audit reports included consideration of the Kairos Power internal documents provided for NRC audit, internal meeting note summaries of discussions between the NRC and Kairos, and Kairos Power notes regarding responses to audit questions. As part of this review effort, the prior Hermes audit responses were considered applicable to Hermes 2 if the general conclusion that was drawn from the response remained the same. For example, a response that committed to Hermes CPA changes was considered applicable to the Hermes 2 CPA if that content remained valid for the Hermes 2 design and was provided in the Hermes 2 CPA.

The documents that the NRC staff identified as audited and the summaries of discussions in each audit report were found to be applicable to the Hermes 2 CPA. Kairos Power considers the responses to audit questions in References 3 and 4 to be applicable to Hermes 2 with the exception of two questions in the General Audit, which require additional clarification:

KP-NRC-2310-006 Page 2 Hermes General Audit Question 1.3.9 The NRC staff conclusion in Reference 3 that the research and development activities identified in PSAR Chapter 1 will be completed by the completion of construction is applicable to Hermes 2; however, the anticipated date for completion of construction for Hermes 2 is December 2027 as described in Enclosure 1 of Reference 1.

Hermes General Audit Question 9.6 The NRC staff question for Hermes identified text that referred to tritium in the secondary coolant. Kairos subsequently removed this text from the Hermes CPA after the secondary coolant loop was removed from the design prior to completion of the Hermes CPA review. While removal of the text was appropriate for the Hermes design, the Hermes 2 design does include a secondary coolant loop; therefore the cited text is included in the Hermes 2 CPA.

If you have any questions or need any additional information, please contact Nicole Schlichting at schlichting@kairospower.com or (980) 215-9252, or Darrell Gardner at gardner@kairospower.com or (704) 769-1226.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on October 27, 2023 Peter Hastings, PE Vice President, Regulatory Affairs and Quality

Enclosure:

None cc:

William Jessup, Chief, NRR Advanced Reactor Licensing Branch Michael Orenak, Project Manager, NRR Advanced Reactor Licensing Branch Matthew Hiser, Project Manager, NRR Advanced Reactor Licensing Branch Edward Helvenston, Project Manager, NRR Advanced Reactor Licensing Branch Samuel Cuadrado de Jesus, Project Manager, NRR Advanced Reactor Licensing Branch