ML24250A129

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Transmittal Letter to Kairos Basic Component White Paper
ML24250A129
Person / Time
Site: 99902069
Issue date: 02/27/2025
From: Joshua Borromeo
NRC/NRR/DANU/UAL1
To: Hastings P
Kairos Power
References
EPID L-2024-LRO-0013
Download: ML24250A129 (3)


Text

February 27, 2025 Peter Hastings, Vice President Regulatory Affairs and Quality Kairos Power LLC 707 W Tower Ave, Suite A Alameda, CA 94501

SUBJECT:

U.S. NUCLEAR REGULATORY COMMISSION STAFF FEEDBACK REGARDING KAIROS POWER LLC WHITE PAPER, BASIC COMPONENT DEFINITION FOR THE HERMES NON-POWER TEST REACTORS

Dear Peter Hastings:

The purpose of this letter is to communicate the U.S. Nuclear Regulatory Commission (NRC) staffs feedback on the April 1, 2024, white paper submitted by Kairos Power, LLC (Kairos) titled, Basic Component Definition for the Hermes Non-Power Test Reactors (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24092A389). The white paper provided Kaiross perspective on the definition of the term basic component as it applies to the Hermes facilities, considering Kaiross vertically-integrated strategy of performing most safety-related design and manufacturing work internally. Kairos requested that the NRC staff review the white paper and provide written feedback to Kairos. The NRC staff provided draft feedback and observations to Kairos (ML24214A165) to support a discussion during a public meeting on August 30, 2024 (ML24250A120).

The NRC staff has completed its review, and the enclosure to this letter provides an assessment of the white paper. The staffs assessment discusses the safety importance of the reporting requirements in Title 10 of the Code of Federal Regulations (10 CFR) Part 21, Reporting of Defects and Noncompliance, and provides clarification on how these reporting requirements could be implemented for Kairos. The NRC staff acknowledges Kaiross vertically integrated structure and believes nothing in the staffs position inhibits Kaiross innovative approach. Enclosure 1 of the assessment further illustrates the NRC staffs position through a discussion of examples provided in the white paper. Enclosure 2 of the assessment contains information regarding the NRC staffs regulatory interpretation of the regulations and applicable guidance. The Office of the General Counsel has reviewed the assessment and both enclosures and has no legal objection.

If you have questions regarding this matter, please contact Cayetano Santos Jr. at (301)415-7270 or via email at Cayetano.Santos@nrc.gov.

Sincerely, Joshua Borromeo, Chief Advanced Reactor Licensing Branch 1 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Project No.: 99902069

Enclosure:

As stated cc: Kairos Power Hermes and Kairos Power Hermes 2 via GovDelivery JOSHUA BORROMEO Digitally signed by JOSHUA BORROMEO Date: 2025.02.27 14:43:59

-05'00'

PKG: ML24250A124 Letter: ML24250A129

Enclosure:

ML24250A128 NRR-106 OFFICE NRR/DANU/UAL1:PM NRR/DANU/UAL1:LA NRR/DANU/UNPL:BC NAME CSantos DGreene HCruz DATE 2/4/25 2/4/25 2/11/25 OFFICE NRR/DRO/IQVB:BC OGC NRR/DANU/UAL1:BC NAME KKavanagh AGhosh Naber JBorromeo DATE 2/10/25 2/21/25 2/27/25