ML24222A393
| ML24222A393 | |
| Person / Time | |
|---|---|
| Site: | Hermes File:Kairos Power icon.png |
| Issue date: | 08/19/2024 |
| From: | Cayetano Santos NRC/NRR/DANU/UAL1 |
| To: | Kairos Power |
| References | |
| Download: ML24222A393 (1) | |
Text
KAIROS POWER, LLC - HERMES 1 SITE CHARACTERISTICS AND GEOLOGIC MAPPING CONDITION AUDIT PLAN (EPID NO. L -2018-LRM-0071)
Applicant: Kairos Power, LLC
Applicant Address: 707 W. Tower Ave, Suite A Alameda, CA 94501
Docket No.: 50- 7513
Background:
By letter dated September 29, 2021, Kairos Power, LLC (Kairos) submitted the Hermes 1 construction permit (CP) application and corresponding preliminary safety analysis report (PSAR) (Agencywide Documents Access and Management System (ADAMS) Accession No.:
ML21272A375). On December 14, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff issued a CP to Kairos for the Hermes 1 test reactor (ML23338A260).
On June 5, 2024, a public meeting was held between members of the NRC staff and Kairos (ML24165A242). The purpose of that meeting was to discuss the foundation design for the Hermes 1 test reactor. During this meeting, Kairos representatives described the proposed foundation construction design concept of drilled piers socketed into sound rock. This differs from the foundation design described in the Hermes 1 PSAR where the foundation mat rested on a concrete fill over the sound rock after an open excavation of the site. Kairos representatives also discussed the inspection and testing that will be implemented to meet the following geological mapping condition in the Hermes 1 CP.
Kairos shall perform detailed geologic mapping of excavations for safety related engineered structures; examine and evaluate geologic features discovered in those excavations; and notify the Director of the Office of Nuclear Reactor Regulation, or the Directors designee, as specified in 10 CFR 50.4, Written communications, once excavations for safety related structures are open for examination by the NRC.
On July 18, 2024, another public meeting was held between the NRC staff and Kairos to continue the discussion of the Hermes 1 foundation (ML24205A171). During this meeting, the NRC staff described expectations for how the permit condition could be met given the new foundation design.
Purpose:
The purpose of this audit is for the NRC staff to confirm the Hermes 1 site characteristics by reviewing the results of the detailed geologic mapping performed to satisfy the permit condition and discussing any ev aluations performed by Kairos as a result of the information gathered. The audit will facilitate a more effective and efficient review of Kaiross upcoming operating license 2
application (OLA) for the Hermes 1 test reactor by allowing the staff to identify any technical or regulatory issues that may complicate the acceptance or technical review of the OLA.
Regulatory Audit Basis:
The basis for the audit is the regulations in Title 10 of the Code of Federal Regulations (10 CFR) pertinent to the NRC staffs review of a future Hermes 1 OLA, particularly 10 CFR 50.34(b)(1) and 50.34(b)(4). The regulation in 10 CFR 50.34(b)(1) states in part that each application for an operating license shall include in the final safety analysis report (FSAR) [a]ll current information which has been developed since issuance of the CP, relating to site evaluation factors identified in part 100 of this chapter. 10 CFR 50.34(b)(4) states that the FSAR should also contain a final analysis and evaluation of the design and performance of structures, systems, and components with the objective stated in paragraph (a)(4) of this section and taking into account any pertinent information developed since the submittal of the preliminary safety analysis report.
10 CFR 100.23(c) requires information be provided on the site foundation materials.
Regulatory Audit Scope
This audit team will review the documentation and evaluations related to Kaiross fulfillment of the geologic mapping condition in the Hermes 1 CP.
Information and Other Material Necessary for the Regulatory Audit
The staff requests that geotechnical reports regarding the Hermes 1 site that are dated after the submission of the Hermes 1 PSAR be made available on the reference portal. The staff also requests that Kairos make the results of the geologic mapping surveys of the piers available for audit as they become available.
Team Assignments
- Jenise Thompson - Geologist, Audit Lead (responsible for audit summary report preparation)
- Amitava Ghosh - Physical Scientist
- Sarah Tabatabai - Geophysicist
- George Khouri - Construction Project Manager
- Anthony Ponko - Senior Construction Inspector
- Cayetano Santos Jr. - Senior Project Manager (responsible for audit logistics and audit summary report preparation)
- Michael Orenak - Senior Project Manager
- Matthew Hiser - Senior Project Manager
Additional audit team members may be added as needed.
Logistics
Entrance Meeting: September 2024, estimated and subject to change Exit Meeting: December 2024, estimated and subject to change 3
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 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 audit project managers 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 NRR, Office Instruction LIC -111, Regulatory Audits (ML19226A274). Audit meetings will take place primarily in a virtual format, using Microsoft Teams, or via other, similar platform. Audit meetings will be scheduled on an as -
needed basis after the entrance meeting and once the NRC staff has had the opportunity to review any 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.
The audit duration is anticipated to be approximately 4 months with activities occurring intermittently during that period. The audit period may be reduced or extended, depending on the progress made by the NRC staff and Kairos in addressing audit questions.
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 a shorter duration. The audit summary will be declared and entered as an official agency record in ADAMS and be made available for public viewing through the p ublicly available records component of ADAMS.
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References
- Title 10 of the Code of Federal Regulations
If you have any questions regarding this matter, please contact me at 301-415-7270 or via email at Cayetano.Santos@nrc.gov.
Date: August 19, 2024
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
ML 24222A393 OFFICE NRR/DANU/UAL1:PM NRR/DANU/UAL 1:LA NRR/ DEX/ EXHB :LEAD NAME CSantos DGreene JThompson DATE 8/9/2024 8/13/2024 8/19/2024 OFFICE NRR/ DEX/EXHB: BC NRR/DANU/UAL1:BC NRR/DANU/UAL1:PM NAME NTiruneh JBorromeo CSantos DATE 8/19/2024 8/19/2024 8/19/2024