ML20311A208
| ML20311A208 | |
| Person / Time | |
|---|---|
| Site: | 99902069 |
| Issue date: | 11/06/2020 |
| From: | Cuadradodejesus S NRC/NRR/DANU/UARL |
| To: | |
| CuadradoDeJesus S | |
| References | |
| KP-TR-007-NP | |
| Download: ML20311A208 (3) | |
Text
U.S. Nuclear Regulatory Commission Preliminary Questions on Kairos Power LLC Quality Assurance Program Topical Report (KP-TR-007-NP)
By letter dated May15,2020, Kairos Power LLC (Kairos) submitted for U.S.Nuclear Regulatory Commission (NRC) staff review KP-TR-007-NP, Quality Assurance Program for the Kairos Power Fluoride Salt-Cooled High Temperature Reactor (Agencywide Documents Access and Management System (ADAMS) Accession No.ML20136A414). In this letter, Kairos requested NRC staff approval of the topical report to be used to satisfy quality assurance requirements for use by applications submitted in accordance with 10 CFR 50 and 10 CFR 52:
- Limited Work Authorizations (LWA) pursuant to 10 CFR 50.10(d)(3)(i)
- Construction Permit (CP) Applications pursuant to 10 CFR 50.34(a)(7)
- Operating License (OL) Applications pursuant to 10 CFR 50.34(b)(6)(ii)
- Early Site Permit (ESP) Applications pursuant to 10 CFR 52.17(a)(1)(xi)
- Design Certification (DC) Applications pursuant to 10 CFR 52.47(a)(19)
- Combined License (COL) Applications pursuant to 10 CFR 52.79(a)(25)
- Standard Design Approval (SDA) Applications pursuant to 10 CFR 52.137(a)(19)
By letter dated August 5, 2020 (ADAMS Accession No. ML20213C698) the NRC staff found that the material presented provides the technical information in sufficient detail to enable the staff to complete a detailed technical review.
The NRC staff has completed an initial review of the topical report and developed a set of preliminary questions to improve its understanding of the information presented in the report. The questions are intended to:
- Obtain clarification regarding material in the topical report
- Promptly identify areas where additional information may be needed
- Facilitate discussions and continue effective communication The NRC staff requests that Kairos propose times to discuss the attached preliminary questions in a public meeting. Based on the outcome of its discussions with Kairos on the topics identified below, the NRC staff may develop formal requests for additional information to complete its review of the topical report.
Set 2 Questions:
- 1. Section (b)(7)(ii) of 10 CFR 50.4, Written Communications, states that [a] change to an NRC-accepted quality assurance topical report from nonlicensees (i.e., architect/engineers, NSSS suppliers, fuel suppliers, constructors, etc.) must be submitted to the NRC's Document Control Desk. If the communication is on paper, the signed original must be sent.
- a. Kairos QAP, Section 2.5, Issuance and Revision to Quality Assurance Program, states that [a]s a licensee (including ESP, LWA, CP, OL, COL), changes made to the QAP by Kairos Power that do not reduce the commitments will be submitted to the NRC in accordance with 10 CFR 50.54(a)(3) or 10 CFR 50.55(f)(3), as applicable. Section 2.5 also states that [w]ith respect to the performance of non-licensee activities (including DC, SDA, topical reports), changes made to the QAP by Kairos Power will be submitted to the NRC in accordance with 10 CFR 50.4(b)(7)(ii). Changes that reduce the commitments in the QAP will be submitted to the NRC for approval, prior to
implementation. Kairos Power may make changes to the QAP without prior NRC approval, provided the change does not result in a reduction in its commitments subject to the following:
Kairos Power will evaluate a change against the requirements of 10 CFR 50.54(a)(3)(i) through 50.54(a)(3)(vi) to determine there is no reduction in commitment to the existing QAP description.
Changes to the QAP that do not reduce the commitments will be submitted to the NRC in accordance with the requirements of 10 CFR 50.4(b)(7)(ii) within 90 days of implementing the change and include a summary of the evaluation of the change.
Changes to the Kairos Power QAP will be regarded as accepted by the Commission upon receipt of a letter to this effect from the appropriate reviewing office of the Commission or 60 days after submittal to the Commission, whichever occurs first.
- i.
Section 2.5 of the QAP seems to be combining the regulatory requirements of §50.4, §50.54, and §50.55. Clarify which regulatory process would be used to handle changes to NRC-accepted quality assurance topical report as the mechanism to handle these changes are different for some of these applications within the scope of the QAP.
- 2. SRP 17.5 Section II.B.13.b.2, states that [t]he independent review committee reports to a management level above the plant manager.
- a. Kairos QAP Section 2.2, subsection Independent Review Group, states that [a]n Independent Review Group is assigned independent review responsibilities and reports to Operations Management.
- i. Clarify to whom within the organizational structure for Operations Management the Independent Review Group reports to.
- 3. 10 CFR 50.120, Training and qualification of nuclear power plant personnel, states, in part, the following:
(a) Applicability. The requirements of this section apply to each applicant for and each holder of an operating license issued under this part and each holder of a combined license issued under part 52 of this chapter for a nuclear power plant of the type specified in §50.21(b) or §50.22.
(b) Requirements. (1)(i) Each nuclear power plant operating license applicant, by 18 months prior to fuel load, and each holder of an operating license shall establish, implement, and maintain a training program that meets the requirements of paragraphs (b)(2) and (b) (3) of this section.
(ii) Each holder of a combined license shall establish, implement, and maintain the training program that meets the requirements of paragraphs (b)(2) and (b)(3) of this section, as described in the final safety analysis report no later than 18 months before the scheduled date for initial loading of fuel.
- a. Kairos QAP Section 2.6, Personnel Training and Qualifications, states that, [t]raining for positions identified in 10 CFR 50.120 is accomplished according to programs accredited by the National Nuclear Accrediting Board of the National Academy of Nuclear Training that implement a systematic approach to training. (This paragraph does not apply to non-operations activities.)
- i.
Clarify if the time requirement of 18 months, as described in §50.120, is part of the requirements that would be established by those programs accredited by the National Nuclear Accrediting Board of the National Academy of Nuclear Training.
- 4. SRP 17.5 Section II.T.4.i, states that [d]ate of certification or recertification and date of certification expiration, are maintained for training and certification records.
- a. Kairos QAP Section 2.7 describe the NQA-1 commitments and exceptions which states,
[s]ections 401 (e) and (g) require the date of certification expiration be included on the qualification record. Kairos Power considers the certification expiration date to be the date from the certification or recertification date plus the certification interval time and its inclusion on the qualification record is optional.
- i. Clarify how the date(s) is/are going to be tracked, it is not clear what date(s) is/are going to be included on training records for inspection and test personnel?