ML25006A023
| ML25006A023 | |
| Person / Time | |
|---|---|
| Site: | 99902069 |
| Issue date: | 02/04/2025 |
| From: | Michael Orenak NRC/NRR/DANU/UAL1 |
| To: | Joshua Borromeo NRC/NRR/DANU/UAL1 |
| References | |
| Download: ML25006A023 (1) | |
Text
February 4, 2025 MEMORANDUM TO:
Josh Borromeo, Chief Advanced Reactor Licensing Branch 1 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation FROM:
Michael Orenak, Senior Project Manager Advanced Reactor Licensing Branch 1 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE DECEMBER 4, 2024, PRE-APPLICATION OBSERVATION MEETING WITH KAIROS ON THE TOPICAL REPORT, OPERATOR TRAINING AND TESTING PROGRAM FOR THE KAIROS POWER FLUORIDE SALT-COOLED HIGH-TEMPERATURE TEST REACTORS, AND THE ASSOCIATED EXEMPTION Meeting Information:
Applicant: Kairos Power LLC (Kairos)
Project No.: 99902069 Meeting Type: Observation Meeting Public Meeting Notice: Agencywide Documents Access and Management System (ADAMS)
Accession No.: ML24309A227
Contact:
Michael Orenak, NRR/DANU 301-415-3229 MICHAE L
ORENAK Digitally signed by MICHAEL ORENAK Date:
2025.02.04 08:18:11 -05'00'
J. Borromeo 2
Meeting Summary:
On December 4, 2024, an observation meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Kairos Power, LLC (Kairos) to discuss NRC staff feedback on the forthcoming topical report (TR), Operator Training and Testing Program for the Kairos Power Fluoride Salt-Cooled High-Temperature Test Reactors, and the exemption that will be necessary to implement the approach detailed in the TR.
Below is a summary of the comments and discussions:
The first comment made by the NRC staff was an overall comment on the draft TR regarding the lack of NRC involvement in the proposed process. The draft TR suggests that the facility would develop, administer, and grade the licensing exams. The NRC staff stated that allowing the facility to administer and grade the operating test would be contrary to any current reactor licensing process (whether non-power or power). The NRC staff stated that NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 12 (ML21256A276), is the guidance for power reactor licensing and suggested that, because NUREG-1021 contains processes for facility development of exams, it is recommended Kairos review it for guidance on how to structure their requested approach since it resembles that used for power reactors in some regards.
The NRC staff also commented that the information in the draft TR appears to contain deviations from established guidance that would preclude uniform conditions for licensing individuals as directed per section 107 of the Atomic Energy Act o NRC is the licensing authority and should not be excluded from the process o Several inconsistences with NUREG-1478, Operator Licensing Examiner Standards for Research and Test Reactors, Revision 2 (ML072000059) were identified Kairos asked if NUREG-1478 provides the administrative details for developing the licensing exam. The NRC staff responded that NUREG-1478 does not contain the framework for the process of facilities developing operator licensing exams for NRC approval.
The NRC staff discussed the process for developing power reactor licensing exams. A brief summary of those highlights is as follows:
o The NRC develops a written exam sample plan and provides it to the facility.
o The facility develops operating test outlines and provides them to the NRC for approval.
o The facility uses the written sample plan and approve operating test outlines to develop both the written exams and operating tests.
o The facility-developed written exams and operating tests are submitted to NRC for review.
o The facility and NRC jointly conduct a validation of the operating test.
o Following incorporation of any needed changes to the operating test and written exam, the NRC approves the exam.
o The NRC then administers and grades the operating test.
o The written exam is administered by the facility and sent to the NRC for formal grading.
J. Borromeo 3
Kairos asked how a discussion of NRC inspections could be incorporated into the proposed TR. The NRC staff stated that the TR could discuss that the NRC would review and approve of the facility-developed exam in a manner comparable to that described in NUREG-1021. The TR could also describe what documents, and information will be made available for review by the NRC.
The NRC staff stated that the draft TRs description of the chief examiner selection and training should include more detail to support NRC review. The NRC staff additionally stated that more details on exam security are needed to include independence between the training staff and the certified examiner staff (e.g. the draft TR indicates training staff will have access to the examination question bank, which is inconsistent with NUREG-1021 requirements and exam security practices). The NRC staff reiterated that, for purposes of comparison, current U.S. power reactor facilities do not administer operating tests to applicants and that this function is implemented by NRC examiners.
The NRC staff stated that the training program and requalification program structure should ensure that all regulations are met. The NRC staff stated that information contained in the draft TR appears to be contradictory to federal regulations and guidance documents.
o Specifically, some training components are listed as senior reactor operator (SRO) only, whereas they should also apply to reactor operators.
o Reactivity manipulations for SROs should meet 10 CFR 55.59(c)(3)(ii) requirements.
o The annual requalification operating exam should align with 10 CFR 55 and NUREG-1478 requirements, including documentation, aspects which may be simulated, etc.
o Some aspects of requalification program as described in draft TR may conflict with 10 CFR 55.53(e) and 10 CFR 55.53(f).
The NRC staff stated that the TR should be clear on the NRC involvement on medical waiver, excusals, and/or deferral approval authority.
The NRC staff stated that research and test reactors (RTRs) do not currently have an approved simulator.
The NRC staff stated simulator processes exist on the power reactor side that may provide some assistance with developing one for non-power production or utilization facilities.
The NRC staff stated that current NRC RTRs utilize the facility (plant) itself for the operating tests.
The NRC staff asked for added details about the scope of the simulator to determine whether it would be more appropriate to approach it from the standpoint of being either a Commission-approved simulator or rather a part-task simulation facility that would be used in conjunction with the plant itself. The NRC staff provided a discussion of part-task simulators and noted that for test reactors, besides using the facility itself, both Commission-approved and part-task simulators are also options that provide flexibility for applicants. Kairos asked for further information on part-task simulators, to which the NRC staff provided the following references:
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o 10 CFR 55.4 mentions part-task in the definition of a simulation facility.
o ANSI/ANS-3.5-2009 has guidance on part-task simulators in appendix D, however, this guidance is not considered part of the standard (rather it is provided for information only) and is not endorsed by the NRC.
o 10 CFR 55.45(b) discusses the use of Commission-approved simulation facilities or the plant itself.
o 10 CFR 55.46(b)(1) discusses requirements for using a simulation facility other than a plant-referenced simulator or the plant.
o 52 FR 9453-9469, issued in 1987 described envisioned alternatives for simulation facilities, including part-task simulators.
The NRC staff stated that a part-task simulator could be acceptable in conjunction with a plant and other simulation devices. The NRC staff is willing to have further discussion with Kairos about plant simulators before submittal of the TR. Kairos stated that they are interested in having further discussions about simulators and will consider using a hybrid approach.
The NRC staff discussed three high-level elements that are needed for a commission-approved simulator:
o Performance testing as per 10 CFR 55.46 o Having adequate scope and fidelity to allow for a representative sample of the required items from both 10 CFR 55.45 and 10 CFR 55.59 o Differences and deviations from the actual plant must be identified and determined to be of an acceptable nature The NRC staff asked if Kairos plans on implementing the systems approach to training (SAT) methodology. Kairos responded that their analysis, design, development, implementation, and evaluation (ADDIE) model is based on the SAT methodology and is being implemented. The NRC staff stated that a discussion of the Kairos ADDIE model approach would be useful to have in the TR.
There were no comments during the public comment period.
Enclosure:
List of Attendees cc: Kairos Power Hermes via GovDelivery
J. Borromeo 5
SUBJECT:
SUMMARY
OF THE DECEMBER 4, 2024, PRE-APPLICATION OBSERVATION MEETING WITH KAIROS ON THE TOPICAL REPORT, OPERATOR TRAINING AND TESTING PROGRAM FOR THE KAIROS POWER FLUORIDE SALT-COOLED HIGH-TEMPERATURE TEST REACTORS, AND THE ASSOCIATED EXEMPTION DATED: FEBRUARY 4, 2025 DISTRIBUTION:
PUBLIC RidsACRS_MailCTR Resource RidsNrrDanuUal1 Resource RidsNrrDanu Resource JBorromeo, NRR DGreene, NRR MOrenak, NRR TTate, NRR MDeSouza, NRR ABeasten, NRR JSeymour, NRR JAnderson, NRR EHelvenston, NRR MBalazik, NRR JNadel, NRR ADAMS Accession Number: ML25006A023 NRR-109 OFFICE NRR/DANU/UAL1:PM NRR/DANU/UAL1:LA NRR/DANU/UAL1:BC NRR/DANU/UAL1:PM NAME MOrenak DGreene JBorromeo MOrenak DATE 1/6/2025 1/30/2025 2/4/2025 2/4/2025 OFFICIAL RECORD COPY
Enclosure List Of Attendees Summary of Meeting with Kairos on the Topical Report, Operator Training and Testing Program for the Kairos Power Fluoride Salt-Cooled High-Temperature Test Reactors, and the Associated Exemption December 4, 2024 Name Organization Michael Orenak U.S. Nuclear Regulatory Commission (NRC)
Ed Helvenston NRC Travis Tate NRC Amy Beasten NRC Michele DeSouza NRC Jesse Seymour NRC Mike Balazik NRC Jared Nadel NRC Drew Peebles Kairos Power LLC (Kairos)
Rachel Lynch Kairos Darrell Gardner Kairos Austin Clark Kairos Jaclyn Rodriguez Kairos Anthonie Cilliers Kairos Chris Poresky Kairos Shane Gallagher Kairos Anna Downing Kairos Hope Palmer Kairos Jana Bergman Curtiss-Wright Timothy Polich RoPower Nuclear