ML24269A202
| ML24269A202 | |
| Person / Time | |
|---|---|
| Site: | 99902069 |
| Issue date: | 09/25/2024 |
| From: | Cayetano Santos NRC/NRR/DANU/UAL1 |
| To: | |
| References | |
| EPID L-2024-TOP-0022 | |
| Download: ML24269A202 (1) | |
Text
KAIROS POWER, LLC - SAFETY ANALYSIS METHODOLOGY FOR THE KAIROS POWER FLUORIDE SALT-COOLED HIGH-TEMPERATURE TEST REACTOR TOPICAL REPORT AUDIT PLAN (EPID NO. L-2024-TOP-0022)
Applicant:
Kairos Power, LLC Applicant Address:
707 W. Tower Ave, Suite A Alameda, CA 94501 Project No.:
99902069
Background:
Kairos Power LLC (Kairos) began pre-application discussions with the U.S. Nuclear Regulatory Commission (NRC) staff on its proposed Kairos Power Fluoride-Salt-Cooled, High-Temperature Reactor design (KP-FHR) in October 2018. Since that time, Kairos submitted two construction permit (CP) applications for two test reactor facilities: 1) Hermes, a single unit facility (henceforth known as Hermes 1 for clarity) and 2) Hermes 2, a two-unit facility (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML23151A743 and ML24144A090, respectively). On December 14, 2023, the NRC staff issued a CP for Hermes 1 (ML23338A260). The NRC staff review of the Hermes 2 CP application is ongoing. Both facilities will be used to support future development of the KP-FHR commercial power reactor.
Since 2018, Kairos submitted several topical reports (TRs) and technical reports that apply to both Hermes 1 and Hermes 2, as well as the KP-FHR commercial power reactor.
During a public meeting on held on February 20, 2024 (ML24061A113), Kairos indicated its plans to submit a TR on their safety analysis methodology in support, in part, of a future application for an operating license (OL) for Hermes 1 in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities. A pre-submittal audit of Kairos draft TR, KP-TR-020-P, Safety Analysis Methodology for the Kairos Power Fluoride Salt-Cooled High-Temperature Test Reactor, was conducted by the NRC staff and documented in a report dated June 20, 2024 (ML24172A201).
The purpose of the pre-submittal audit was to assess the readiness of the draft TR before it was submitted for the NRC staffs review.
By letter dated June 4, 2024, Kairos submitted KP-TR-020-P for NRC staff review and approval (ML24156A162). On July 3, 2024, the NRC staff determined that the TR presented sufficient information to begin a detailed technical review (ML24184A052).
Purpose:
The purpose of this audit is for the NRC staff to gain a better understanding of KP-TR-020-P by reviewing and discussing the material used to support statements or conclusions in the TR. The
2 audit is expected to facilitate a more effective and efficient review by allowing the NRC staff to review and discuss supporting material with the objective of improving communication and eliminating unnecessary requests for additional information. The NRC staff plans to audit documentation, calculations, and computer code information needed to verify information and conclusions in the TR. If the NRC staff identifies information that is needed to support a finding, Kairos will need to submit that information on the application docket.
Regulatory Audit Basis:
The bases for the audit are the regulations in 10 CFR pertinent to the NRC staffs review of a future Hermes OL application, particularly 10 CFR Part 50, sections 50.34, Contents of applications; technical information, 50.40, Common standards, and 50.57, Issuance of operating license.
Regulatory Audit Scope:
This audit team will review documentation and calculations that provide supporting information for KP-TR-020-P, Safety Analysis Methodology for the Kairos Power Fluoride Salt-Cooled High-Temperature Test Reactor. The audit scope consists of all chapters and appendices of the TR.
Information and Other Material Necessary for the Regulatory Audit:
At this time, the staff requests that the following documents be made available for audit.
Additional documents may be requested during the review:
Provide any references or internal documentation related to the justification for changing the radionuclide groupings provided in KP-TR-012, KP-FHR Mechanistic Source Term Methodology, (ML22136A291)
Kairos Power Materials Handbook Kairos Power Systems Analysis Code (KP-SAM) input model and calculation notebook Audit questions are included in Appendix A to this audit plan (additional questions may be asked during the review).
Team Assignments Pravin Sawant - Senior Nuclear Engineer, Audit Lead (responsible for audit summary report preparation)
Alex Siwy - Senior Nuclear Engineer Alexander Chereskin - Materials Engineer Andrew Bielen - Senior Reactor Systems Engineer (Neutronics)
Ben Adams - General Engineer Brian Bettes - Project Manager (responsible for audit logistics and audit summary report preparation)
Cayetano Santos Jr. - Senior Project Manager Michelle Hart - Senior Reactor Engineer Tarek Zaki - Reactor Systems Engineer Additional audit team members may be added as needed.
3 Logistics Entrance Meeting:
October 2024, estimated and subject to change Exit Meeting:
December 2024, estimated and subject to change The NRC staff requests that all the documents in the audit scope be provided by Kairos on an online reference portal. An online reference portal, established by Kairos, would allow the NRC staff access to technical information. Use of the online reference portal is acceptable provided that Kairos establishes measures to limit access to specific NRC staff (e.g., based on NRC e-mail addresses or the use of passwords which will only be assigned to the NRC staff directly involved in the audit on a need-to-know basis) and to make the documents view-only (i.e.,
prevent the NRC staff from saving, copying, downloading, or printing any documents). The conditions associated with the online reference portal must be maintained throughout the audit process. The NRC staff who should initially be granted access to the portal are listed in the Team Assignments section. The NRC staff audit project managers will provide Kairos with the names of additional NRC staff who should be granted access.
The audit will follow the guidance in the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, Regulatory Audits (ML19226A274). Audit meetings will take place primarily in a virtual format, using Microsoft Teams, or via other, similar platform. Audit meetings will be scheduled on an as-needed basis after the entrance meeting and once the NRC staff has had the opportunity to review any documents placed in the online reference portal. The NRC staff requests that Kairos make their technical staff and subject matter experts available to answer questions during the audit. If a site visit is needed, review topics will be provided to Kairos and mutually agreeable dates will be established.
The audit duration is anticipated to be approximately three months with activities occurring intermittently during that period. The audit period may be reduced or extended, depending on the progress made by the NRC staff and Kairos in addressing audit questions.
Special Requests None Deliverables At the completion of the audit, the audit team will issue an audit summary within 90 days after the exit meeting but will strive for a shorter duration. The audit summary will be declared and entered as an official agency record in ADAMS and be made available for public viewing through the publicly available records component of ADAMS.
References Title 10 of the Code of Federal Regulations NRR Office Instruction LIC-111, Regulatory Audits
4 If you have any questions regarding this matter, please contact me at 301-415-7270 or via email at Cayetano.Santos@nrc.gov.
Date: September 25, 2024 Cayetano Santos Jr., Sr. Project Manager Advanced Reactor Licensing Branch 1 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation CAYETANO SANTOS Digitally signed by CAYETANO SANTOS Date: 2024.09.25 16:31:17 -04'00'
ML24269A202 OFFICE NRR/DANU/UAL1:PM NRR/DANU/UAL1:LA NRR/DANU/UTB1:LEAD NAME CSantos DGreene PSawant DATE 9/4/2024 9/5/2024 9/5/2024 OFFICE NRR/DANU/UTB2:BC NRR/DANU/UAL1:BC NRR/DANU/UAL1:PM NAME CdeMessieres JBorromeo CSantos DATE 9/25/2024 9/25/2024 9/25/2024