ML24008A080
| ML24008A080 | |
| Person / Time | |
|---|---|
| Site: | 99902069, 05000611, Hermes, 05000612 |
| Issue date: | 01/08/2024 |
| From: | Edward Helvenston NRC/NRR/DANU/UNPL |
| To: | Jessup W NRC/NRR/DANU/UAL1 |
| References | |
| EPID L-2018-LRM-0071 | |
| Download: ML24008A080 (1) | |
Text
W. Kenned UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 8, 2024 MEMORANDUM TO: William Jessup, Chief Advanced Reactor Licensing Branch 1 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation FROM: Edward Helvenston, Project Manager /RA/
Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE NOVEMBER 2, 2023, PUBLIC MEETING BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION STAFF AND KAIROS POWER LLC TO DISCUSS MATERIAL CONTROL AND ACCOUNTING (EPID NO. L-2018-LRM-0071)
Meeting Information:
Applicant: Kairos Power LLC (Kairos)
Docket Nos.: 50-7513, 50-611, 50-612 Project No.: 99902069 Public Meeting Notice Agencywide Documents Access and Management System (ADAMS)
Accession No.: ML23276A637 Applicant Presentation Slides: ML23304A003 Meeting Attendees: See the enclosure for a list of meeting attendees.
CONTACT: Edward Helvenston, NRR/DANU/UNPL (301) 415-4067
Meeting Summary:
On November 2, 2023, a public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Kairos Power LLC (Kairos) via webinar. The purpose of this meeting was to discuss Kaiross plans for developing special nuclear material (SNM) control and accounting (MC&A) programs that would be described in future operating license (OL) applications for Kairos proposed Hermes, Hermes 2, and commercial power reactor projects using the Kairos Power fluoride high temperature reactor (KP-FHR) technology.
The meeting notice indicated that the meeting may be partially closed to allow for discussion of potentially security-related information. However, it was not necessary to close any portion of the meeting. A list of meeting attendees is provided as an enclosure to this summary.
During the meeting, Kairos provided a presentation that began with an overview of its KP-FHR technology and the pebble handling and storage system (PHSS) used in KP-FHR designs.
Kairos noted that its reactors would contain fuel pebbles with a mix of different enrichment as well as fuel and moderator pebbles. During initial reactor startup and early operation, primarily natural uranium fuel pebbles would be used and higher enrichment fuel pebbles would be added later. Therefore, the mix of enrichments in canisters of pebbles discharged from the reactor would vary over time. Kairos stated that it does not plan to separate pebbles of different enrichment once they are added to the reactor.
Kairos discussed its understanding of the NRC regulations that would be applicable to its reactors in the areas of MC&A as well as international safeguards. The NRC staff noted that Title 10 of the Code of Federal Regulations (10 CFR) Part 74, Material Control and Accounting of Special Nuclear Material, applies to any person possessing 1 gram or more of SNM. Subpart B, General Reporting and Recordkeeping Requirements, of 10 CFR Part 74 applies to all persons subject to 10 CFR Part 74, while other subparts include some exclusions for reactors.
Kairos also presented an overview of the MC&A plan it is developing for its proposed Hermes test reactor. Kairos stated that, although primarily intended for power reactors, Kairos plans to use NRC Regulatory Guide (RG) 5.29, Special Nuclear Material Control and Accounting Systems for Nuclear Power Plants (ML13051A421), to provide format and content guidance for its Hermes MC&A plan. Kairos noted that it intends for the plan to be high level, and detailed implementation information will be located in Kairos internal procedures. The NRC staff recommended that Kairos ensure that its plan covers potential loss of material, as well as potential theft or diversion, and recommended that the plan list and describe internal procedures, as appropriate.
Kairos highlighted some areas where it plans to deviate from RG 5.29 in developing its Hermes MC&A plan (e.g., parts where Kairos has determined that RG 5.29 is more applicable to a typical power reactor site). Kairos noted that it plans to use bulk accounting for MC&A in-process pebbles, and item accounting for used pebbles discharged from the reactor and stored in canisters. Kairos noted that it plans for Hermes to have a single material balance area for the purposes of Nuclear Materials Management and Safeguards System (NMMSS) reporting, but there will be separate areas within this larger area, for example, to account for the bulk versus item accounting.
Kairos also referred to other guidance, including NUREG-2159, Acceptable Standard Format and Content for the Fundamental Nuclear Material Control Plan Required for Special Nuclear Material of Moderate Strategic Significance (ML22143A963), and American National Standards Institute (ANSI) N15.8-2009, Methods of Nuclear Material Control - Material Control Systems -
Special Nuclear Material Control and Accounting Systems for Nuclear Power Plants, as guidance it planned to consider in developing its Hermes MC&A plan. The NRC staff noted that, although primarily developed for fuel cycle facilities, other guidance that Kairos could consider using includes NRC RG 5.88, Physical Inventories and Material Balances at Fuel Cycle Facilities (ML17167A292), and NRC RG 5.51, Independent Assessment of Nuclear Material Control and Accounting Systems (ML16223A915).
Following Kaiross discussion of its proposed Hermes MC&A plan outline, the NRC staff also recommended that Kairos consider the requirement under 10 CFR 73.60(f) in developing its Hermes MC&A plan. Additionally, the NRC staff recommended that Kairos consider whether the MC&A plan should include a chapter on investigating indicators of theft, loss, or diversion of SNM consistent with guidance in NUREG-2159.
Kairos noted the Rulemaking for Enhanced Security of Special Nuclear Material regulatory basis document published by the NRC in 2015 (ML14321A007), which discusses an approach for applying physical security requirements for facilities with Category III quantities of SNM, instead of Category II quantities, if the material is sufficiently dilute (the Hermes facility would have a Category II quantity of SNM). Kairos noted that the NRC recently approved an exemption to allow a fuel cycle facility to use this approach for applying physical security requirements and asked whether it may be possible to use a similar approach for MC&A (i.e.,
whether a facility with sufficiently dilute SNM may be able to get an exemption to apply Category III instead of Category II requirements for MC&A). The NRC staff noted that this regulatory basis document is specific to physical security and that for MC&A, 10 CFR Part 74 already applies a graded approach based on SNM type and quantity (and reactors are excepted from certain subparts of 10 CFR Part 74). However, the NRC staff noted that this may be an area for further discussion.
Kairos concluded the meeting with a brief discussion of its preliminary understanding of the NMMSS reporting requirements that would apply for its reactors. The NRC staff noted that, generally, NMMSS should have the flexibility to accommodate Kaiross planned reactors, although some adjustments may potentially be needed, considering some differences in the designs compared to existing reactors. Representatives of the NMMSS group at the National Nuclear Security Administration (NNSA) who were present at the meeting also stated that they could separately meet with Kairos to provide an overview of NMMSS capabilities.
No regulatory decisions were made during this meeting.
Enclosure:
List of Attendees cc: Kairos Power via GovDelivery
ML24008A080 NRC-001 OFFICE NRR/DANU/UNPL:PM NRR/DANU/UAL1:BC NAME EHelvenston WJessup DATE 1/8/2024 1/8/2024 List of Meeting Attendees
SUMMARY
OF THE NOVEMBER 2, 2023, PUBLIC MEETING BETWEEN THE U.S.
NUCLEAR REGULATORY COMMISSION STAFF AND KAIROS POWER LLC TO DISCUSS MATERIAL CONTROL AND ACCOUNTING (EPID NO. L-2018-LRM-0071)
Name Organization Edward Helvenston U.S. Nuclear Regulatory Commission (NRC)
James Rubenstone NRC Suzanne Ani NRC Glenn Tuttle NRC Mirabelle Shoemaker NRC Andrew Waugh NRC Beth Reed NRC Michael Orenak NRC Seamus Flanagan NRC Cayetano Santos NRC Chuck Teal NRC Matthew Hiser NRC Samuel Cuadrado de Jesus NRC Carolyn Wolf NRC Margaret Ellenson Kairos Power LLC (Kairos)
Per Peterson Kairos Darrell Gardner Kairos Gareth Walcott Kairos Matthew Strangeway Kairos Guy Symonds Kairos Andrew Lingenfelter Kairos Ahmed Moustafa Kairos Steve Yang Kairos Brian Song Kairos Mitch Hembree National Nuclear Security Administration (NNSA)
Loida Begley NNSA Genevieve Weaver NNSA Elaine Beacom NNSA Marcos Crabtree NNSA RL Carbo NNSA Ali Tabatabai NNSA Timothy Polich RoPower Nuclear Charlyne Smith Breakthrough Institute Andrew Brenner Holtec International Inc.
Enclosure