ML24144A091

Kairos Power, LLC - Submittal of the Hermes 2 Preliminary Safety Analysis Report for the Kairos Power Fluoride Salt-Cooled, High Temperature Non-Power Reactor, Revision 1, and the Postulated Event Analysis Methodology Technical Report, Revi

ML24144A091
Person / Time
Site:	Hermes  File:Kairos Power icon.png
Issue date:	05/23/2024
From:	Hastings P Kairos Power
To:	Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML24144A090	List: ML24144A091 ML24144A092 ML24144A094
References
KP-NRC-2405-008
Download: ML24144A091 (1)

Text

KP-NRC-2405- 008

May 23, 2024 Docket No. 50-611 Docket No. 50-612

US Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Kairos Power LLC Submittal of the Hermes 2 Preliminary Safety Analysis Report for the Kairos Power Fluoride Salt-Cooled, High Temperature Non-Power Reactor, Revision 1, and the Postulated Event Analysis Methodology Technical Report, Revision 1

References:

Letter, Kairos Power LLC to Document Control Desk, Submittal of the Construction Permit Application for the Hermes 2 Kairos Power Fluoride Salt-Cooled, High Temperature Non-Power Reactor, July 14, 2023 (ML23195A122)

In July 2023, Kairos Power submitted Revision 0 of the Preliminary Safety Analysis Report (PSAR) and Revision 0 of the Postulated Event Analysis Methodology Technical Report, KP-TR-022, as part of the Construction Permit Application (CPA) for the Hermes 2 non-power test reactor (referenced above).

Kairos P ower has s ubmitted d iscrete changes to the PSAR and t o KP -TR-022 to a ddress N RC f eedback as part of the Hermes C PA r eview. Th is l etter tr ansmits a form al revision o f bot h th e PSAR and t echnical report to r eflect the integratio n of p reviously s ubmitted c hanges.

Portions of t he Hermes 2 Postulated E vent A nalysis Methodology T echnical Report are considered proprietary, an d K airos Power requests those portions be w ithheld f rom p ublic d isclosure in ac cordance with t he p rovisions o f 1 0 CFR 2. 390. Revision 1 o f t he H ermes 2 PSAR i s p rovided a s E nclosure 1. A proprietary v ersion o f the t echnical r eport ( KP-TR-022- P, Revision 1 ) is p rovided i n E nclosure 2 . A non-proprietary v ersion o f this t echnical report (KP -TR-022- NP, R evision 1 ) is p rovided i n E nclosure 3 . An affidavit s upporting the w ithholding request i s provided i n E nclosure 4 . Additionally, the in formation indicated a s p roprietary has a lso b een d etermined to contain E xport Controlled I nformation. T his information m ust be protected f rom d isclosure p ursuant t o t he r equirements o f 10 C FR 8 10.

If you have questions or need additional information, please contact Drew Peeb les at peeb les@kairospower.com or (704) 275-5 388, or Darrell Gardner at gardner@kairospower.com or (704) 769-1 226.

I d eclare u nder p enalty o f perjury t hat t he f oregoing is t rue a nd correct.

Executed o n May 23, 2024

Sincerely,

Peter Hastings, PE Vice President, Regulatory Affairs and Quality

Kairos Power LLC www.kairospower.com 707 W Tower Ave, Suite A 5201 Hawking Dr SE 2115 Rexford Rd, Suite 325 Alameda, CA 94501 Albuquerque, NM 87106 Charlotte, NC 28211 KP-NRC-2405-008 Page 2

Enclosures:

1) Hermes 2 Preliminary Safety Analysis Report , Revision 1 (Non-proprietary)

2) KP-TR-022-P Hermes 2 Postulated Event Methodology , Revision 1 (Proprietary)

3) KP-TR-022-NP Hermes 2 Postulated Event Methodology , Revision 1 (No n-Proprietary)

4) Kairos Power LLC Affidavit and Request for Withholding from Public Disclosure (10 CFR 2.390)

xc (w/enclosure):

Joshua Borromeo, Chief, NRR Advanced Reactor Licensing Branch Michael Orenak, Project Manager, NRR Advanced Reactor Licensing Branch Matthew Hiser, Project Manager, NRR Advanced Reactor Licensing Branch Edward Helvenston, Project Manager, NRR Advanced Reactor Licensing Branch Samuel Cuadrado de Jesus, Project Manager, NRR Advanced Reactor Licensing Branch Cayetano Santos Jr., Project Manager, NRR Advanced Reactor Licensing Branch Brian Bettes, Project Manager, NRR Advanced Reactor Licensing Branch

KP-NRC-2405- 008

Enclosure 1

Hermes 2 Preliminary Safety Analysis Report, Revision 1 (Non-Proprietary)

KP-NRC-2405- 008

Enclosure 2

KP-TR-022-P Hermes 2 Postulated Event Methodology , Revision 1 (Proprietary)

KP-NRC-2405- 008

Enclosure 3

KP-TR-022-NP Hermes 2 Postulated Event Methodology , Revision 1 (Non-Proprietary)

KP-NRC-2405- 008

Enclosure 4

Kairos Power LLC Affidavit and Request for Withholding from Public Disclosure (10 CFR 2.390)

I, Peter Hastings, hereby state:

1. I am Vice President, Regulatory Affairs and Quality, at Kairos Power LLC (Kairos), and as such I have been authorized by Kairos to review information sought to be withheld from public disclosure in connection with the development, testing, licensi ng, and deployment of the Kairos reactor and its associated structures, systems, and components, and to apply for its withholding from public disclosure on behalf of Kairos.

2. The information sought to be withheld, in its entirety, is contained in Kairos Enclosure 2 to this letter.

3. I am making this request for withholding, and executing this affidavit in support thereof, pursuant to the provisions of 10 CFR 2.390(b)(1).

4. I have personal knowledge of the criteria and procedures utilized by Kairos in designating information as a trade secret, privileged, or as confidential commercial or financial information.

Some examples of information Kairos considers proprietary and eligible for withholding under

§2.390(a)(4) include:

a. Information which discloses process, method, or apparatus, including supporting data and analyses, where prevention of its use by Kairos competitors without license or contract from Kairos constitutes a competitive economic advantage over other companies in the industry;

b. Information, which if used by a competitor, would reduce his expenditure of resources or improve his competitive position in design, manufacture, shipment, installation, assurance of quality;

c. Information which reveals cost or price information, production capacities, budget levels, or commercial strategies of Kairos, its customers, its partners, or its suppliers;

d. Information which reveals aspects of past, present, or future Kairos or customer funded development plans or programs, of potential commercial value to Kairos;

e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection; and/or

f. Information obtained through Kairos actions which could reveal additional insights into reactor system development, testing, qualification processes, and/or regulatory proceedings, and which are not otherwise readily obtainable by a competitor.

5. Kairos information contained in Enclosure 2 to this letter contains details of Kairos postulated event methodology for a Kairos Power fluoride salt-cooled high-temperature reactor. These details could provide a competitor with a commercial advantage if the information were to be revealed publicly.

KP-NRC-2405- 008

6. Pursuant to the provisions of §2.390(b)(4), the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld:

a. The information sought to be withheld from public disclosure is owned and has been held in confidence by Kairos.

b. The information is of a type customarily held in confidence by Kairos and not customarily disclosed to the public. Kairos has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitute Kairos policy and provide the rational basis required.

c. The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR 2.390, it is to be received in confidence by the Commission.

d. This information is not readily available in public sources.

e. Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Kairos, because it would enhance the ability of competitors to provide similar products and services by reducing their expenditure of resources using similar project methods, equipment, testing approach, contractors, or licensing approaches. This information is the result of considerable expense to Kairos and has great value in that it will assist Kairos in providing products and services to new, expanding markets not currently served by the company.

f. The information could reveal or could be used to infer price information, cost information, budget levels, or commercial strategies of Kairos.

g. Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Kairos of a competitive advantage.

h. Unrestricted disclosure would jeopardize the position of Kairos in the world market, and thereby give a market advantage to the competition in those countries.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: May 23, 2024

Peter Hastings Vice President, Regulatory Affairs and Quality