ML25105A041
| ML25105A041 | |
| Person / Time | |
|---|---|
| Site: | 99902069 |
| Issue date: | 06/05/2025 |
| From: | Cayetano Santos NRC/NRR/DANU/UAL1 |
| To: | Joshua Borromeo NRC/NRR/DANU/UAL1 |
| References | |
| Download: ML25105A041 (1) | |
Text
June 5, 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:
Cayetano Santos Jr., 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 APRIL 16, 2025, MEETING WITH KAIROS ON THE PROPOSED 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: Hybrid Observation Meeting Public Meeting Notice: Agencywide Documents Access and Management System (ADAMS)
Accession No.: ML25093A175 Applicant Presentation Slides: ML25099A187
Contact:
Cayetano Santos, NRR/DANU (301) 415-7270 CAYETAN O SANTOS Digitally signed by CAYETANO SANTOS Date: 2025.06.05 15:38:10 -04'00'
J. Borromeo 2
Meeting Summary:
On September 27 and December 4, 2024, observation public meetings were 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. The summaries for the September 27 and December 4, 2024, meetings can be found at ML24282A673 and ML25006A023, respectively.
These discussions continued during another observation meeting on April 16, 2025. Below is a summary of the comments and discussions:
The NRC staff described concerns with the draft TR not identifying NRC oversight or involvement in (1) the review and approval of the facility developed written examination and operating tests and (2) the administration and grading of the operations tests.
Under the current licensing framework, the NRC has the responsibility to prepare the examinations and tests in lieu of licensees and to exercise its discretion and reject a facility licensees determination to prepare, proctor, and grade the written examinations and prepare the operating tests. To ensure that NRC standards for quality are maintained, the facility licensee must receive Commission approval of its proposed written examinations and operating tests before they are given. Kairos stated that they did not want to define the NRCs regulatory activities, so the TR identifies documents and records that would be kept allowing the NRC staff to identify the appropriate regulatory activity (e.g., audit or inspection).
The NRC staff suggested approaching Title 10 of the Code of Federal Regulations (10 CFR) 55.40, Implementation, similarly to that used by power reactors (e.g.
10 CFR 55.40(b) and (c) in lieu of (d), and structuring exams around NUREG-1478, Operator Licensing Examiner Standards for Research and Test Reactors, instead of NUREG-1021, Operator Licensing Examination Standards for Power Reactors). The NRC staff described concerns with the draft TRs deviations from NUREG-1478 as they do not conform to uniform conditions pursuant to the Atomic Energy Act as utilized at other non-power production and utilization facilities (NPUFs). Examples of these deviations include the following:
o Category A topics are not inclusive of all subjects required per NUREG-1478.
o Passively observing Category A activities alone is insufficient to demonstrate understanding of critical areas in most topics. NUREG-1478 does not include this as acceptable practice.
o Category C operating exam grading is inconsistent with NUREG-1478.
Kairos staff asked if the comments raised by the NRC staff could prevent the NRC from formally accepting the TR for a detailed review. The NRC staff commented that they would need to discuss the internally and provide feedback to Kairos at a future date.
The NRC staff commented that the draft TR is essentially requesting approval of a training program.
J. Borromeo 3
The NRC staff noted that there are methods available to quantifiably analyze the reliability of an exam.
The NRC staff noted the importance of uniformity of conditions for licensing operators, but it is unclear how uniformity would apply among advanced reactors.
Kairos staff stated that they plan to submit the exemption request and TR at the same time.
There were no comments from members of the public.
Enclosure:
List of Attendees cc: Kairos Power Hermes via GovDelivery
J. Borromeo 4
SUBJECT:
SUMMARY
OF APRIL 16, 2025, MEETING WITH KAIROS ON THE PROPOSED TOPICAL REPORT, OPERATOR TRAINING AND TESTING PROGRAM FOR THE KAIROS POWER FLUORIDE SALT-COOLED HIGH-TEMPERATURE TEST REACTORS, AND THE ASSOCIATED EXEMPTION DATED: JUNE 5, 2025 DISTRIBUTION:
PUBLIC RidsACRS_MailCTR Resource RidsNrrDanuUal1 Resource RidsNrrDanu Resource JBorromeo, NRR CSantos, NRR DGreene, NRR ABeasten, NRR MDeSouza, NRR TBrown, NRR MOrenak, NRR EHelvenston, NRR TBuchanan, NRR BBettes, NRR ADAMS Accession Number: ML25105A041 NRR-109 OFFICE NRR/DANU/UAL1:PM NRR/DANU/UAL1:LA NRR/DANU/UAL1:BC NRR/DANU/UAL1:PM NAME CSantos DGreene JBorromeo CSantos DATE 5/9/2025 5/14/2025 6/5/2025 6/5/2025 OFFICIAL RECORD COPY
Enclosure List Of Attendees Summary of Meeting with Kairos April 16, 2025 Name Organization Cayetano Santos U.S. Nuclear Regulatory Commission (NRC)
Michael Orenak NRC Amy Beasten NRC Michele DeSouza NRC Tony Brown NRC Ed Helvenston NRC Brian Bettes NRC Theresa Buchanan NRC Rachel Lynch Kairos Power, LLC (Kairos)
Drew Peebles Kairos Michael Ellett Kairos Jaclyn Rodriguez Kairos Hope Palmer Kairos Anna Downing Kairos Anthonie Cilliers Kairos Shane Gallagher Kairos Christopher Poresky Kairos Keith Ashley Kairos Jana Bergman Member of the Public Christine DiMuzio Member of the Public Christopher Maxwell Member of the Public Lester Towell Member of the Public PJ Steel Member of the Public Mike Montecalvo Member of the Public Brett Jebbia Member of the Public