ML23117A069
| ML23117A069 | |
| Person / Time | |
|---|---|
| Site: | 99902069, Hermes |
| Issue date: | 04/27/2023 |
| From: | Halnon G Advisory Committee on Reactor Safeguards |
| To: | David Petti Advisory Committee on Reactor Safeguards |
| References | |
| Download: ML23117A069 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, DC 20555 - 0001 April 27, 2023 MEMORANDUM TO: David Petti, Lead Kairos Hermes License Application Review Subcommittee Advisory Committee on Reactor Safeguards FROM: Greg Halnon, Member Advisory Committee on Reactor Safeguards
SUBJECT:
INPUT FOR ACRS REVIEW OF THE KAIROS CONSTRUCTION PERMIT APPLICATION - DRAFT SAFETY EVALUATION FOR CHAPTER 17, DECOMMISSIONING AND POSSESSION-ONLY LICENSE AMENDMENTS In response to the Subcommittees request, I have reviewed the NRC staffs draft safety evaluation (SE) with no open items for Chapter 17, Decommissioning and Possession-Only License Amendments. The following is my recommended course of action concerning further review of this chapter and the staffs associated draft SE.
Background
This chapter provides the details for decommissioning plans and post-operation periods of storage of radioactive materials that may require a possession-only license. Since the chapter is only applicable to operation license applications, no detailed or specific information is required for a construction permit application.
SE Summary NUREG 1537, Part 2, indicates that decommissioning plans and applications for possession-only licenses are submitted by nonpower reactor licensees who wish to terminate operations and decommission their facilities. Staff concluded that since Kairos is not seeking a possession-only license and seeks a construction permit, no decommissioning information or possession-only amendment request needs to be provided in the Preliminary Safety Analysis Report (PSAR).
Concerns Throughout the PSAR systems descriptions, there are commitments made to establish the designs taking 10 CFR 20.1406, Minimization of contamination, in consideration. As very little design details have been provided, it will be important to keep this standard visible during the future Final Safety Analysis Report review for the safe, economic, and ease of decommissioning is largely dependent on the application of this standard. Also, being on a former site that contained nuclear materials, characterization of the previous radiation dose and contamination levels will be an important understanding when developing the decommissioning plan.
D. Petti The operating license will be for a four-year life. Some decommissioning activities have a window that starts 5 years prior to end of operation or permanent shutdown. For example, the Decommissioning Plan must be submitted within this five-year window. The decommissioning regulations should be carefully reviewed, specifically but not limited to 10 CFR 50.75 and 50.82, to ensure there will be no conflict with compliance given the short operating life of the reactor upon issuance of an operating license.
I have no concerns with either the applicants description or the staffs conclusion. No further review is necessary unless the conditions are changed by the applicant.
Recommendation(s)
I recommend no further action.
References
- 1. USNRC, Draft Safety Evaluation for Hermes NonPower Reactor Preliminary Safety Analysis Report Chapter 17, January 2023 (ML23017A120)
- 2. Kairos Power LLC, Submittal of the Preliminary Safety Analysis Report for the Kairos Power Fluoride Salt-Cooled, High Temperature Non-Power Reactor (Hermes), Revision 2, February 2023 (ML23055A672)
- 3. USNRC, NUREG-1537, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Format and Content, issued February 1996 (ML042430055)
- 4. USNRC, NUREG-1537, Part 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Standard Review Plan and Acceptance Criteria, issued February 1996 (ML042430048)
- 5. 10 CFR Part 20 - Standards for Protection Against Radiation, U.S. Nuclear Regulatory Commission, Washington, DC.
D. Petti April 27, 2023
SUBJECT:
INPUT FOR ACRS REVIEW OF THE KAIROS CONSTRUCTION PERMIT APPLICATION - DRAFT SAFETY EVALUATION FOR CHAPTER 17, DECOMMISSIONING AND POSSESSION-ONLY LICENSE AMENDMENTS Package No: ML23117A000 Memo Accession No: ML23117A069 Publicly Available Y Sensitive N Viewing Rights: NRC Users or ACRS Only or See Restricted distribution *via e-mail OFFICE ACRS/TSB* SUNSI Review* ACRS/TSB* ACRS*
NAME WWang WWang LBurkhart (WWang for) GHalnon DATE 4/27/2023 4/27/2023 4/27/2023 4/27/2023 OFFICIAL RECORD COPY