ML25339A165

Final Kairos Operator Training TR and Exemption Audit Plan

ML25339A165
Person / Time
Site:	Hermes  File:Kairos Power icon.png
Issue date:	01/13/2026
From:	Cayetano Santos NRC/NRR/DANU/UAL1
To:
References
Download: ML25339A165 (0)

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KAIROS POWER, LLC - AUDIT PLAN FOR THE TOPICAL REPORT, OPERATOR TRAINING AND TESTING PROGRAM FOR THE NON-POWER KAIROS POWER FLUORIDE SALT-COOLED HIGH-TEMPERATURE REACTORS, AND EXEMPTION REQUEST FROM CERTAIN REQUIREMENTS IN 10 CFR PART 55 (EPID NOS. L-2025-TOP-0026 and L-2025-LLE-0021)

Applicant:

Kairos Power, LLC Applicant Address:

707 W. Tower Ave, Suite A Alameda, CA 94501 Plant Name(s) and Unit(s):

Hermes 1 Test Reactor Facility Hermes 2 Test Reactor Facility Docket Nos.:

05007513 05000611 05000612

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 (KP-FHR) in October 2018. In December of 2020, Kairos announced that the Hermes test reactor would be used to support future development of the KP-FHR. Kairos was issued a construction permit (CP) on December 14, 2023, for the Hermes 1 test reactor to be located at a site in Oak Ridge, Tennessee (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23338A260). Kairos was issued two CPs on November 21, 2024, for the Hermes 2 test reactor facility located at an adjacent site (ML24324A019). As discussed in public meetings held on September 27, 2024 (ML24282A673), December 4, 2024 (ML25006A023), April 16, 2025 (ML25105A041), and April 28, 2025 (ML25105A044), Kairos planned to submit both a topical report (TR) on the operator training and testing program for the KP-FHR test reactors as well as an exemption request from certain requirements in Title 10 of the Code of Federal Regulations (10 CFR) Part 55, Operators Licenses.

By \

letter dated July 11, 2025, Kairos submitted KP-TR-026-NP, Operator Training and Testing Program for the Non-Power Kairos Power Fluoride Salt-Cooled High-Temperature Reactors, (ML25192A231). By \

letter dated July 30, 2025, Kairos submitted requests for exemptions from certain requirements in 10 CFR Part 55 (ML25211A317). The NRC staff determined that the TR and exemption request presented sufficient information to begin a detailed technical review (ML25210A446 and ML25273A286).

The TR describes for KP-FHR test reactors the initial training and testing for reactor operator applicants, the requalification for licensed reactor operators, and the simulation facility used for

2 the training and testing programs. The associated exemptions were submitted because the training and testing program described in the TR does not meet all of the non-power reactor requirements in 10 CFR Part 55. The July 30, 2025 request is divided into four enclosures:

• requests an exemption from certain requirements in 10 CFR 55.40(d) to allow a non-power KP-FHR facility to prepare, proctor, and grade written examinations and operating tests for licensed operator applicants.

• requests an exemption from 10 CFR Part 55 medical certification requirements for KP-FHR facility operator applicants and the requirements for documenting medical records, reporting medical conditions, and completing medical examinations every two years.

• requests an exemption from certain requirements in 10 CFR 55.31(a)(5) to allow a non-power KP-FHR facility to determine the appropriate number of reactivity manipulations to demonstrate proficiency and conduct these reactivity manipulations on a Commission-approved simulator.

• requests an exemption from certain requirements in 10 CFR 55.55(a) and 55.59(a)(1) to allow a non-power KP-FHR facility to extend the operator license expiration to 12 years and extend the requalification program periodicity to 36 months.

Purpose:

Since the TR and exemption requests are related and being reviewed in parallel, the NRC staff is conducting a single regulatory audit for both licensing actions. The purpose of this audit is for the NRC staff to gain a better understanding of KP-TR-026-NP and the associated exemptions by providing an opportunity to review and discuss material used to support statements and conclusions in both the TR and exemption request. The 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 internal documents, draft implementing procedures, and other information needed to verify information and conclusions in the TR and exemption request. If the NRC staff identifies information that is needed to support a finding for the TR or exemption requests, Kairos will need to submit that information on the docket.

Regulatory Audit Basis:

The TR requests NRC review and approval of an initial licensed operator training and testing program as well as the licensed operator requalification program. Therefore, the basis for the audit includes the regulatory requirements in 10 CFR Part 55 which establish procedures and criteria for the issuance of licenses to operators and senior operators for utilization facilities. The TR also describes the simulation facility used for conducting the operating tests. Simulation facility requirements are described in 10 CFR 55.46, Simulation facilities. The requested exemptions are also from various requirements in 10 CFR Part 55.

Regulatory Audit Scope:

The audit team will review implementing procedures and other documents that provide technical support to KP-TR-026-NP and the associated exemptions. The audit scope will cover all the chapters and appendices in the TR as well as the four enclosures to the July 30, 2025, exemption request.

3 Information and Other Material Necessary for the Regulatory Audit:

The NRC staff requests that the information described below be made available for audit.

Internal documents that describe the following:

o commitments to systematic analysis o contributor training o examination security o expected content in training procedures o expected content in procedures for preparing, proctoring and grading exams o specific simulator configuration or design such as pictures or diagrams and how operators will interact with the simulator/main control room Draft implementing procedures for developing the following:

o knowledge, skills, and abilities o learning objectives o examination bank o training of operators o preparing, proctoring, and grading license examinations Other documents:

o verification and validation procedures for the simulation facility and a description of the results (include any software test procedures and acceptance criteria that will be used to perform the testing in the future) o procedures used to establish the simulator design, fidelity, testing, examination security and maintenance of the facility The NRC staff may request additional documents as needed.

Exam Security:

1. Section 2.2, Responsibilities, lists the organizational structure and outlines some of the roles and responsibilities of the various entities.

Please provide a more detailed organization structure (e.g. a chart), with a defined hierarchy (who reports to whom) that illustrates the separation of training, examination support, and operations personnel.

What are the distinctions between initial license training (ILT) and the requalification roles and responsibilities described in section 3.2, Responsibilities?

2. Please provide a discussion on certification/training/qualification of certified examiners (CEs) in section 2.6.1, Examiner Selection including education requirements, criteria for selection, key points of training, how qualifications are maintained, who they report to, how many are involved in each exam (including development and administration), and where in the exam development process they participate.

3. Section 2.6.1 states that examiners will be adequately educated and/or experienced to administer their assigned section of an examination.

How will exam security be maintained if multiple examiners are performing different areas of the exam?

Will the CEs have access to all the exam materials, or just their specific section?

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4. Section 2.6.1 states If a conflict of interest is found after beginning an examination or if a breach of ethics is found at any point of the examination process, the affected parts of the examination is withdrawn and remade. Why does this not affect the whole exam? If a conflict of interest arises prior to the beginning of an exam, how does this affect the prepared exam as this could challenge or call into question the integrity of the exam overall?

5. The TR discusses measures for mitigating exam security vulnerabilities in the simulation facility. Other exam security measures are discussed in section 2.6.2, Examination Security. It appears that people other than examiners who may be involved in exam development do not have to be on the exam security agreement or equivalent. Is this intended? If so, please provide justification.

6. Section 2.6.4.2, Operating Tests, states, The examiner may choose to annotate procedures with clarifying comments on how to execute particular steps, as well as identifying critical steps.

Are these annotated procedures just for the CE or are they also provided to the candidate? If they are, why? Would this alter the integrity of the test, or lead the candidate to a specific answer or in a specific direction? Why do candidates need to have critical steps identified for them? Would this be giving away the answer?

7. Section 2.6.3, Examination Question Bank, identifies qualified contributors and subject matter experts who develop and review the questions to be put in the question bank.

Please provide a more detailed description of these positions. Specifically, how do they differ from CEs and instructors in terms of roles and responsibilities? What qualifications are required for these positions, and to whom do they report? Additionally, are they expected to sign ethics agreements and comply with exam security protocols?

What measures are in place to maintain exam security, given the number of individuals contributing to exam development process?

Please provide a full, complete list of positions that have access to the official question bank, including those that contribute to it.

8. Section 2.6.3 states, in part instructors may have access to the question bank to develop assessments for the initial operator training and for requalification training.

Given this access and its use, how will adequate sequestration of training and exams be established?

9. In section 2.6.3 security of the question bank is briefly discussed.

Which individual (i.e., position) is responsible for granting permission to use a question?

What limitations do the exam authors have on how often they can repeat questions on exams that have been used on past exams and/or on current and past training assessments? How is this enforced/monitored?

What are the limitations on questions from the bank being used in training assessments?

Are the exam authors putting together the initial training assessments? If the operations training team has access to the whole bank, would this limit the ability to create original exam content and ensure adequate exam security?

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10. Section 2.6.4, Examination Preparation, states After the written examination and operating tests are prepared, an internally appointed and qualified exam reviewer is assigned for the review and approval of written examination and operating test content.

The individuals listed below have access to the Exam Question Bank and five of the six positions collaborate on exam development. Why is an integrity agreement sufficient for these individuals? Who do these individuals report to? How are their qualifications determined or defined?

o Qualified contributors (undefined) o Subject matter experts (undefined) o Exam developers (undefined) o Internal Exam Reviewer (undefined) o Examiners o Operations Instructors

11. Section 2.6.6.1, Written Examination, makes the following statements:

The written examination may be administered digitally. Will there be a requirement to sandbox the digital examination to prevent opening unauthorized tabs? How are examinees prevented from previewing, downloading, or saving the exam?

Certified examiners, who may or may not be exam authors Please clarify whether the CEs are exam authors.

12. Section 2.6.6.2, Operating Tests, makes the following statements:

Except for examiners, no other member of the facility training or operations staff are allowed to witness an operating test without the permission of the plant manager. Other than CEs what other observers would be able to witness an operating test?

Videotaping the administration of initial examinations is not allowed. Would audio recording be permitted?

At the discretion of the proctor, some examination questions may be better suited to ask during the facility walkthrough or during the simulator facility portion of the exam. Who is the exam proctor? Is this different from the CE? Please define this individual, their role, qualifications, and exam security requirements.

13. Section 2.6.8, Post-examination Activities, states Any indications or suggestions that examination security may have been compromised is reported immediately to the NRC, even if the identified situation is corrected before submittal of examination materials. Would compromised exam security identified prior to submittal of exam materials compromise the entire exam?

14. Section 2.7, New Facility Operator Licensing Plan, states Prior to initial criticality at new facilities, the first class of operator candidates undergo extensive on-the-job training on reactor facility systems and iterative technology development. This may include reactor facility construction job tasks, reactor facility or skid walkthroughs, operation and walkthroughs of iterative non-nuclear test units, and training on a Commission-approved simulator facility... Subject matter experts will be the initial licensing examiners and authors for the first class of new facility applicants. Examiners for the first class of new facility applicants will be certified using the certification plan in this program.

How will these subject matter experts (SMEs) be certified?

How will exam bank access be controlled during this time?

6 Who is contributing to the exam bank for this first class? Will these individuals continue to have access to the bank after this first class?

How will the first exams be structured, developed, written, administered, proctored, and graded?

What subjects would these SMEs be knowledgeable? Will these SMEs then become CEs? How are these SMEs different from the future CEs?

15. Section 3.3.6, Requalification Examinations, states The requalification examinations, as prepared, proctored and graded by the examiners, follow the same guidance as the initial licensing examinations and testing, as detailed in chapter 2, initial licensed operator training and testing. This includes examination security, certified examiners, and the examination bank.

Are the requalification examiners the same examiners who conduct ILT exams?

Are the rules/requirements/guidelines for the ILT examiners different from those of requalification examiners? How are the rules/requirements/guidelines for requalification examiners established?

Is the same exam bank being used for requalification exams?

Do individuals in ILT also have access to requalification written exams as part of their study materials?

How is ILT exam security maintained if the same exam bank is used for ILT training, requalification, and exam development?

Deviations from NUREG-1478, Operator Licensing Examiner Standards for Research and Test Reactors, Revision 2:

16. Section 2.4.1, Training Content, indicates a distinction between required level of knowledge for reactor operators (ROs) and senior reactor operators (SROs), however, the list of information ROs are required to know is not inclusive of all topics included in NUREG-1478 or covered by current RO exams. Please elaborate and explain why ROs are not required to be knowledgeable of the following topics:

conditions and limitations in facility license facility operating limits in Technical Specifications and bases procedures required to obtain authority for design and operating changes means normal and abnormal radiation hazards facility condition assessments and selection of appropriate procedures fuel handling

17. Section 2.6.4.1, Written Examination, indicates there will be separate RO and SRO written exams, and that there will be a senior reactor operator - upgrade (SRO-U) written exam.

Both points appear to contradict section 2.6.5, Level of Exam by License Type. Please clarify.

18. Section 2.6.4.2, Operating Tests, of the TR discusses the operating exams.

The TR states The operating test is divided into two testing segments: a simulation facility examination, using an NRC-approved simulation facility, and a plant walkthrough examination. Both segments together fully cover all content below without significant overlapping of content between the two examinations. The division of the content between the two segments may change from year to year The NRC staff notes that

7 there is usually some overlap between Categories A, B, and C on the operating exam.

Please explain the intent to avoid overlap. Please elaborate on the statement, The division of the content between the two segments may change from year to year.

The TR provides an outline for the required topics to be covered in Category A. This list does not appear to cover all the necessary items indicated in NUREG-1478. However, the administrative topics associated with operation do not include 10 CFR 50.59, surveillance, operating limits, and startup requirements in accordance with NUREG-1478. Also, radiation protection does not include radiation sources and hazards, radiation work permits, portable detectors (not installed instrumentation) and dosimetry, dose limits, and posting requirements in accordance with NUREG-1478. Please explain the basis for excluding those topics. Additionally, passive observation is acceptable for facility operations portions of Category C. How is passively observing the operator adequate to assess all areas required to be tested under NUREG-147 requirements in Category A, Subcategory A.2, security, and startup?

The TR provides an outline for the required topics to be covered in Category B. Please provide a complete list of all testable systems within the topics described in Category B.

The TR states Reactivity evolutions: Examples include reactor startup, power maneuvering, and experiment manipulation. This situation is usually covered by performing the startup. Will there be reactivity evolutions covered in addition to startup above the point of adding heat such as a power change?

The TR states There are typically 2-3 scenario walkthroughs per operating test. Please explain how a component failure, instrument failure, and a major transient (with or without implementation of the Emergency Plan) could be covered in two scenarios.

The TR states Once the scenarios are concluded, the candidate simulates shut down.

Are the candidates simulating a shutdown because they are on the simulator, or does simulate mean actually not perform, even on the simulator?

The TR states In addition to correctly responding and walking through the prepared scenarios on the simulator facility, the examiner also watches the applicant for general operator competencies. Although these competencies are less significant to consider while writing scenarios, its important to keep them in mind during the entire examination process. Are general operator competencies written into the scenario and considered during the testing? How are the scenarios scripted to capture things such as which cues/alarms/trends were responded to and when; how were conditions diagnosed; what procedures were used; when, how, and why; and control board basics?

The TR states Normal evolutions can be used as a backdrop upon which to stage the emergency or abnormal situations. For example, an examiner may provide verbal cues that an indication is not responding to a normal power change. Why are verbal cues needed if a simulator is used for the exam?

The TR states Selected short surveillances may be used to examine control screen dexterity and should be combined with other activities, such as a reactor startup. What is the importance of "control screen dexterity"? Can this be demonstrated through normal reactor operations? What aspect of the operations test would these short surveillances cover?

19. Section 2.6.5, Level of Exam by License Type, provides table 2.6-2, Level of Operating Test by License Type, which appears to cover Category A topics. Why doesnt this table

8 include topics such as 10 CFR 50.59, surveillances, startup requirements, information dissemination, and operational limits?

Radiation Protection - Why doesnt this topic align with NUREG-1478?

Emergency Plan and Procedures - Please clarify the intended deviation from NUREG-1478 regarding RO and SRO responsibility.

Fuel Handling - Will fuel inspection activities be included?

20. Section 2.6.7.2, Operating Test states, An applicant must earn a 2.4 value out of 4.0 points to receive a satisfactory marking in that competency. The 2.4 cutscore is a significant deviation from NUREG-1478, where a 3.0-point system is used (with a min score of 1.80 required). Please provide justification for this deviation.

What is the purpose of adding a 4th grading tier?

Would this add more subjectivity to grading by adding a second "some deficiencies" tier, rather than a straightforward "no deficiencies," "some deficiencies but no adverse consequence," and "major deficiencies with adverse consequences"? Why wouldnt a 3-tier grading system be sufficient for a self-reliant mitigation facility?

The TR states When grading categories, A and B, topics that are unsatisfactory require written justification from the facility examiner. Please describe how exam results are documented.

21. Please elaborate on the distinctions among the grading scores 1 through 4 shown in table 2.6-5, Operating Test Category C Rubric, with a particular focus on the questions below:

C.1.c(2), How is prioritized correctly and attentive compatible with the phrase "major inaccuracies"?

C.2.a(2), This criterion states Difficulties diagnosing, with many errors that required correction. Who provided the correction? Is the CE interjecting into the exam? Are there any adverse consequences as a result of the many errors that required correction?

C.2.b(2), This criterion states Delayed reports impacting emergency response. Are there adverse consequences to the emergency response? What kinds of impacts?

C.2.c(3), What does corrections taken mean? Who is correcting the candidate? Why?

When is it determined that corrections need to be provided?

C.2.c(2), Why is this not a 1? How are there no adverse impacts here? Who is giving/making corrections?

C.3.a(2) and C.3.a(1), Please explain missed internal requirement in C.3.a(2). How does this not also result in a missed federal requirement in C.3.a(1)?

C.3.b(2), How does a no correction made not result in adverse impacts?

C.3.c(2), How does incorrect documentation used not result in adverse impacts?

C.3.c(1), Failure to locate or use appears the same as incorrect documentation used.

Please justify how this is different than C.3.c(2).

C.4.a(2), Will there be a time limit on how long a candidate can struggle before a C.4.a(3) becomes a C.4.a(2)?

C.4.b(1) and C.4.b(2), How is Appeared without knowledge or regard to in C.4.b(1) different from major misunderstanding in C.4.b.(2)?

C.4.c(2), This criterion states Seemingly dependent on automatic functions, required prompting to take manual control. Who is prompting the candidates? Are examiners or licensed operators in attendance coaching, prompting, correcting, or cuing the candidates?

9 Requalification:

22. Please clarify the requalification program plan responsibilities for all roles in section 3.2, Responsibilities. Additionally, please define the following terms Licensed Operator Continuing Training Program Operator training program Examiner (for requalification, if different from ILT)

Licensed Operator Accelerated Requalification Remediation plan Training program performance criteria

23. Please list the specific Licensed Operator Continuing Training Program requirements.

24. In section 3.2, Responsibilities, the responsibilities of the Learning and Development Management are described. Why is approving the certification of examiners listed here? Is there continuing training for CEs?

25. In section 3.2, the responsibilities of the Operations Instructors are described.

Bullet 3 appears more appropriate for ILT than requalification. Please explain and clarify this bullet.

What is the Candidate Performance Evaluation? Please define this term.

26. In section 3.2, the responsibilities of the Licensed Operators are described.

How will attendance and completion of requalification (including retraining and remediation) be tracked? Is it the individuals responsibility to be current in requalification?

Why would licensed operators need to notify management of health changes if there are no medicals?

27. In section 3.2, the responsibilities of the Examiners are described.

Are CEs also responsible for preparing, proctoring, and grading requalification exams?

If so, how will they do this? Will the exam preparation and development be from the same resource pool as the ILT? How will exam security be maintained? How will this factor into ILT exam development? Will there be limits on the number of questions used on requalification exams for ILT exams?

28. Section 3.3, Requalification Training, states Requalification provides the means to train licensed reactor operators and licensed senior reactor operators in the knowledge, skills, and abilities required to maintain proficiency to perform their functions safely and effectively commensurate with their level of responsibility. However, the objectives of requalification as described state that the areas of focus will be on infrequent operation, facility and procedural changes, subject matter not reinforced by direct use, and to improve in areas of performance weakness, which does not appear to be consistent with the initial statement. Please clarify the objectives.

Are all the objectives of requalification listed in the TR? Since requalification is continuing training, why isnt all RO/SRO knowledge continually enforced?

10 Does the objective To improve in areas of performance weakness refer to an individual or a team/shift? How will the distinction be made? If areas of performance weakness are not the same from team to team, how would this be addressed?

29. Section 3.3, Requalification Training, provides table 3.3-1, Requalification Training Requirement Frequency Minimums. In section 3.3.4, Documentation of Proficiency Through Licensed Hours, the TR states [t]o maintain an active status with an operating license, the licensed operator performs the function of a licensed reactor operator or licensed senior reactor operator for a minimum of four hours per calendar quarter.

Why are on-the-job training and Emergency Plan/Procedure reviews and drills not listed?

Why are some requirements in 10 CFR 55.59(c)(2) and (c)(3) not included?

Why are some of the evaluation criteria in 10 CFR 55.59(c)(4) not included?

The staff notes that Four Hours of Licensed Duties is a requirement in 10 CFR 55.53, Conditions of licenses, but not in 10 CFR 55.59, Requalification. Will this be written into the requalification plan as an additional requirement separate from 10 CFR 55.53?

Table 3.3-1 lists refresher training (training lectures and facility changes) as a quarterly requirement. Please justify how quarterly lectures meet the intent of "continuous," or "on a regular and continuing basis" per 10 CFR 55.59(c)(2). Are the lectures preplanned as required per 10 CFR 55.59(c)(2)? Is the quarterly periodicity requirement for both lectures (55.59(c)(2)) AND facility changes (55.59(c)(3))? Are these requirements satisfied independently?

Table 3.3-1 lists reactivity manipulations as an annual requirement. What are the specific requirements regarding reactivity manipulations (e.g., number and type)?

Does the requalification training plan require that operating tests and written examinations not exceed 12 months and 36 months, respectively?

30. Section 3.3.1, Schedule, states, the licensed operators are provided or accomplish refresher training, written examination, and reactivity manipulation opportunities. Every 12-month period, the licensed operators complete an operating test and review documents (this includes infrequent procedures such as abnormal or emergency procedures).

Please describe what refresher training will be provided to operators and what training operators will be required to accomplish on their own.

Will the training be conducted in accordance with 10 CFR 55.59(c)(1) - (c)(6)? Will lectures be preplanned and conducted on a regular and continuing basis? Could self-study replace a preplanned lecture? Would the program allow an operator to complete requalification entirely by self-study only?

31. Section 3.3.2, Continued Training, states The specific content of the continued training is based on items that have been identified as weaknesses in the training or operator knowledge. These weaknesses may be identified through exam results, observed operator knowledge and performance gaps, facility changes, or operating experience.

Will the training content also include previously examined/tested/trained subject areas?

How will observed operator knowledge gaps and performance be measured? What metrics or milestones be used?

How will weaknesses be identified through facility changes?

11 Does operating experience consider the facility, industry, or both? How will it be incorporated?

Are continuing training topics addressed through lectures that occur on a regular and continuing basis and cover all the topics listed?

For items 6 and 7 in section 3.3.2, are the listed items fully inclusive?

How will other facility training, as applicable, be determined? Who will be making this determination?

32. Section 3.3.3, Refresher Training in Areas of Infrequent Operation, states Refresher training also includes document reviews. Please define and describe what refresher training entails in addition to document reviews.

33. Regarding section 3.3.4, Documentation of Proficiency Through Licensed Hours, what does Kairos consider to be a licensed activity?

34. Section 3.3.6, Requalification Examinations, states, The written examination (every three years) samples items specified in 10 CFR 55.41 and 10 CFR 55.43, with an emphasis on licensed activities and changes in design and procedures.

If an emphasis is placed on licensed activities and changes in design and procedure, how will this meet the requirements in 10 CFR 55.41 and 55.43?

For the written exam, what is the passing criteria overall?

35. Section 3.3.6 states:

The annual operating test consists of a minimum of five tasks, with a minimum of two questions per task. The operating test samples items specified in 10 CFR 55.45. These tasks and questions can appropriately be pulled from the examination bank or previously administered licensing examinations. Four tasks will include one from each of the following:

• Reactivity task: Tasks that have the operator perform a startup, significant power change, or shutdown.

• Abnormal event: Tasks that have the operator respond to an instrument failure, component failure, radiation monitor alarm, or similar problem.

• Emergency event: Tasks that have the operator respond to events such as a building evacuation or high-radiation levels.

• Outside event: Tasks that have the operator perform duties outside the control room, such as surveillances, including local radiation monitors or diesel generators.

An additional task will be randomly selected from one of the above categories for a total of five tasks.

How are five tasks a true representative sample of the requirements in 10 CFR 55.45?

How do the items listed above satisfy the requirements in 10 CFR 55.45?

What is the basis for the minimum of two questions per task? What guidance is used to determine whether questions are adequate for an operations exam?

The TR states that the reactivity task is just one of either a startup, power change, or shutdown. Please justify how this is sufficient. How is the facility defining startup? How is a shutdown from power an acceptable evaluation of an operator's proficiency on the console?

How does the abnormal event task meet the requirements in 10 CFR 55.45?

12 How are emergencies defined at the facility? For emergency events, what tasks, other than responding to building evacuations and high radiation levels, are expected of operators?

Please elaborate on the operator tasks associated with the Outside event. Do the surveillances include operation of components?

36. Section 3.3.7, Post Requalification Examination, states Operations instructors review the results of all operating tests and written examinations with the operators, including the correct responses to commonly missed questions and the objectives that were not demonstrated satisfactorily in operating and written tests. This can be a subject reviewed during requalification meetings or lectures. Would the review of the operations tests and written exams be a preplanned lecture, or a supplement to a preplanned lecture? This is not one of the lecture topics that is listed in 10 CFR 55.59(c)(2).

37. Section 3.3.7.1, Exemptions, states Licensed individuals designated to develop and administer the operating tests, or written examination may be exempted from the tests/examination as described at the discretion of Operations management. Why would this be necessary if CEs are developing and administering requalification exams? Are CEs also licensed operators?

Simulator

38. Section 1.1.3, Regulatory Information, and limitation 9 in section 5.2, Limitations, indicate that approval of the final simulation facility design details and performance testing results is required prior to use of the simulation facility for operating tests and for experience requirements. The NRC staff notes the following: The simulator must be approved as a Commission approved simulator (CAS) before it can be used for operating tests, and the staff must also find it to be suitable for completing the experience requirements (i.e., control manipulations) to grant an exemption from the requirements of 10 CFR 55.31(a)(5), which must occur prior to it being used to meet experience requirements. Performance test results must be submitted with the CAS request, along with the description of components of the simulator and their intended use and the procedures for exam security. Information in the TR can be cited in the CAS request and the CAS request may point to the TR. Please provide justification for not including a limitation similar to limitation 4 for use of a Commission approved simulator for completing the experience requirements (i.e., a limitation that the exemption must be approved to allow the Commission approved simulator to be used for meeting experience requirements).

39. The exemption request from certain requirements in 10 CFR 55.31(a)(5) says The Facilitys operator applicants perform the necessary number of manipulations to demonstrate competency in reactivity manipulations, in accordance with the rest of 10 CFR 55.31(a)(5).

The number of manipulations performed may be less than five. It also states in part, a non-power KP-FHR relies on passive safety features that are independent of operator interactions (including acts of commission or omission) to mitigate the consequences of postulated events. With the reduced reliance on operators, a decrease in the number of required reactivity manipulations and the use of a Commission-approved simulator would not cause operational errors endangering public health or safety. It additionally states, Since the regulation prescribes the number of reactivity manipulations, the Facilitys operators would have to meet the requirements prescribed minimum number prior to submitting their applications to the NRC. This does not consider that some operators may

13 already be qualified without reaching the prescribed minimum number of reactivity manipulations.

The exemption request does not explain what method(s) would be used to determine the minimum number of manipulations needed for each applicant. It appears that information is discussed more in the TR. Section 2.4, Initial Training, of the TR states, in part, The Initial licensed operator training is based on a systems approach to training that focuses on the knowledge, skills and abilities required for ROs and SROs to safely perform their functions.

In accordance with 10 CFR 55.31(a), the initial training program establishes the required evidence for the candidate to apply for a reactor operator or senior reactor operator license.

Specifically, in accordance with 10 CFR 55.31(a)(5), each candidate will complete the necessary number of manipulations to demonstrate proficiency in reactivity manipulations.

The manipulations may utilize either an approved simulation facility (see chapter 5) or the reactor facility, subject to an approved exemption to 10 CFR 55.31(a)(5) (Limitation 8). SRO-U candidates may directly supervise and direct reactivity control manipulation to receive credit equivalent to actual performance.

The explanation in the TR is directly applicable to the exemption request, since it explains the method used to determine how many manipulations will need to be done by each applicant (i.e., a program based on the SAT process). For the exemption request, please clarify what method is used to determine the number of manipulations an applicant must perform as part of the license training process? Please describe the specific process or criteria that will be used in the systems approach to training (SAT)-based training program to determine how Kairos will assess the applicants to determine if fewer than five manipulations are acceptable.

If Kairos expects the number of reactivity manipulations performed by the operator applicants to demonstrate competency to be zero, then an exemption from all of 10 CFR 55.31(a)(5) requirements may be needed. Since the exemption request is limited only to certain requirements of 10 CFR 55.31(a)(5), it appears that is not the intention (i.e., the minimum is one). Please clarify.

The NRC staff notes that both NUREG-1478 and NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 12 emphasize that manipulations should be diverse - e.g., startups, shutdowns, and power maneuvers. Will Kairos ensure applicants perform a diverse set of manipulations that are a representative sample of the types of manipulations applicants will do once licensed and if not, why?

Section 3.3.5, of the TR states licensed operators will do at least five manipulations during the 36-month requalification cycle, in any combination of startups, shutdowns, and reactivity or power level changes. Is the basis for five licensed operations in requalification consistent with the process that will be used to determine the minimum number needed for applicants?

40. Table A-2 discusses ANSI/ANS-3.5-2009 section 3.1.3, Steady-State and Normal Evolutions, and states The KP-FHR simulation facilities use a simulator engine that generates plant physics parameters based on an Ex-vessel physics model and corresponding reactor core physics models and changes the parameters based on inputs from the operators. The simulation facilities display these parameters through the human machine interface on the displays as an exact replica of the KP-FHR reference unit display with the use of identical programmable logic controllers used for the KP-FHR reference unit controls. Are the simulator controls also exact replicas, such that all the controls in the main

14 control room of the plant will be modeled in the simulator? Why is the applicability of section 3.1.3 partial instead of full?

41. Section 4.1.1, Static Components, states that the components are visually inspected prior to establishing the simulator in accordance with the provided bullets and documented design of the reference unit control room but does not state the criteria to be used nor how this inspection will be documented. Table A-2 indicates that ANSI/ANS-3.5-2009 section 4.2.1.4, Assessment of Deviations, is fully applicable and that the criteria listed therein will be the criteria used. Is this correct? Please explain the mechanism for how this inspection and its results will be documented and used.

42. Section 4.1.2, Dynamic Components, states, For parameters not modeled by KP-SAM, validation testing compares simulator engine results to other best estimate methods. What kinds of information would this include?

43. Table A-2 states that ANSI/ANS-3.5-2009 sections 3.4, Simulator Testing, is fully applicable, and simulator testing requirements in section 4.1, Simulator Capabilities Criteria, are partially applicable, because the plant parameters listed in ANSI/ANS-3.5-2009 sections 4.1.3.1.1 - 4.1.3.1.3 are not applicable to the plant design. In table A-2 Kairos identified those parameters that are. Please explain how these parameters were selected.

Was this tied to other plant design processes?

44. Section 4.2.1, Operability Testing, of the TR says, Evolutions or malfunctions listed in ANS-3.5-2009 Criteria 3.1.3 and 3.1.4 that do not match the systematic approach to training KP-FHR operators will be addressed according to the testing. What does this mean?

45. Table A-2 indicates that ANSI/ANS-3.5-2009 sections 4.4.3.1, Simulator Operability Testing, is partially applicable and refers to three years for core performance testing. What is the basis for three years?

46. Table A-2 indicates that ANSI/ANS-3.5-2009 section 4.4.3.3, Simulator Reactor Core Performance Testing, is partially applicable. What does the simulator core model use as its design data?

47. Will the simulation facility have the capability to record plant parameters during exams? The NRC staff notes that this is an important function for examinations as it allows for later reference to the information if needed to confirm grading of the applicants performance.

Although the TR is for a non-power reactor, the only current guidance for use of simulators in examinations is found in NUREG-1021, which is the examination standard for power reactors. This guidance discusses the need for the simulator to record applicable plant parameters for scenarios.

48. Section 4, Simulation Facility, states that the simulation facility will be used for both initial and requalification training. Section 4.1.2, Dynamic Components, discusses how the simulator scope covers all 13 items from 10 CFR 55.45(a). What about applicable items from 10 CFR 55.59(c)(3)?

49. Section 4.4.1, Design Database, states that simulator engine is updated to reflect reference unit modifications within 30 months of commissioning and then every 24 months thereafter. The initial reference unit data update occurs within the first 18 months of

15 commissioning and then every 12 months thereafter. How were these intervals determined? How is 24 months appropriate for a significant modification? Is there a procedure that would drive implementing an update sooner than 24 months or cause some other alternative action such as a training needs analysis? Is there a procedure that would drive implementing an update sooner than 12 months for reference unit data? How do these statements align with section 4.4.2, Discrepancies, which states that discrepancies will be tracked, and if rejected, will be assigned an action plan and addressed within reasonable timeframes? Are reference unit modifications considered discrepancies? How does the facility define a discrepancy? What is done with discrepancies that are considered not significant? Are they part of the 24-month update?

50. Table A-2, discusses ANSI/ANS-3.5-2009, section 4.2.1.1, Scope of Panel Simulation.

Please describe the criteria used to evaluate design items that were determined to not need full replication to prevent negative training (i.e., exact same size, shape, color).

51. Section 2.4, states in part, SRO-U candidates may directly supervise and direct reactivity control manipulation to receive credit equivalent to actual performance. SRO-U applicants are not required to perform the minimum control manipulations as part of their application.

By definition on NRC Form 398, an SRO upgrade applicant is a holder of an RO license who is seeking to upgrade to an SRO license at the same facility. Why would they need to receive credit equivalent to actual performance?

Miscellaneous

52. The \

July 30, 2025 letter included four exemption requests. What specific entities would these exemptions apply? The NRC staff notes that the requirements in 10 CFR Part 55 are applicable to Part 55 licensees (i.e., holders of operators licenses) or any facility licensee (i.e., part 50/52 license holders).

The NRC staff may ask additional questions during the review.

Team Assignments:

Amy Beasten Reactor Engineer (Audit Lead)

Michele DeSouza Reactor Engineer Lauren Nist Reactor Engineer Theresa Buchanan Senior Reactor Engineer Pravin Sawant Senior Nuclear Engineer Cayetano Santos Jr. Senior Project Manager Additional audit team members may be added as needed.

Logistics:

Entrance Meeting:

January 2026, estimated and subject to change Exit Meeting:

July 2026, 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 the technical information. Use of the online reference portal is acceptable

16 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 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 project managers for the audit will provide Kairos with the names of additional NRC staff who should be granted access.

The NRC staff requests that Kairos make their technical staff and subject matter experts available to answer questions during the audit.

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. Audit meetings will be scheduled on an as-needed basis after the entrance meeting and once the NRC staff has reviewed the documents placed in the online reference portal. If a site visit is needed, review topics will be provided to Kairos and mutually agreeable dates will be established.

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 an earlier issuance. The NRC staff may issue separate audit summaries for the reviews associated with the TR and exemptions. Any audit summary will be declared and entered as an official agency record and be made publicly available for viewing through ADAMS.

References:

Title 10 of the Code of Federal Regulations NRR Office Instruction LIC-111, Regulatory Audits If you have questions about this audit, please contact me at 301-415-7270 or by email at Cayetano.Santos@nrc.gov.

Date: January 13, 2026 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: 2026.01.13 11:54:14 -05'00'

ML25339A165 OFFICE NRR/DANU/UAL1:PM NRR/DANU/UAL1:LA NRR/DANU/UNPO:LEAD NAME CSantos DGreene ABeasten DATE 12/11/2025 12/16/2025 12/11/2025 OFFICE NRR/DANU/UNPO:BC NRR/DRO/IOLB:BC NRR/DANU/UAL1:BC NAME TBrown JAnderson JBorromeo DATE 01/12/2026 01/07/2026 01/13/2026 OFFICE NRR/DANU/UAL1:PM NAME CSantos DATE 01/13/2026