ML20329A145
| ML20329A145 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 11/20/2020 |
| From: | Mallecia Sutton NRC/NRR/DANU/UARP |
| To: | |
| Sutton M | |
| Shared Package | |
| ML20329A139 | List: |
| References | |
| EPID L-2020-TOP-0043 | |
| Download: ML20329A145 (4) | |
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Email U.S. NUCLEAR REGULATORY COMMISSION PRELIMINARY QUESTIONS ON THE ASSESSMENT OF THE QUALITY ASSURANCE PROGRAM DESCRIPTION FOR THE TERRAPOWER, LLC QUALITY ASSURANCE TOPICAL REPORT EPID L-2020-TOP-0043 By letter dated August 5, 2020 (Agencywide Documents Access and Management System Accession No. ML20218A590), TerraPower, LLC (TerraPower) submitted for U.S. Nuclear Regulatory Commission (NRC) staff review, Topical Report (TR) TP-QA-PD-0001, Rev. 9A Quality Assurance Program Description. The NRC staff has completed an initial review of the TR and developed a set of preliminary questions to improve its understanding of the information presented in the Quality Assurance Topical Report (QATR). 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 TerraPower propose times to discuss the attached preliminary questions in a public meeting. Based on the outcome of its discussions with TerraPower on the topics identified below, the NRC staff may develop formal requests for additional information to complete its review of the TR.
The NRC staff reviewed TerraPowers QATR based on TerraPower's plans to submit a construction permit. 10 CFR 50.34(a)(7), Contents of applications; technical information, states that:
A description of the quality assurance program to be applied to the design, fabrication, construction, and testing of the structures, systems, and components of the facility.
Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, sets forth the requirements for quality assurance programs for nuclear power plants and fuel reprocessing plants.
The description of the quality assurance program for a nuclear power plant or a fuel reprocessing plant shall include a discussion of how the applicable requirements of appendix B will be satisfied.
Regulatory Guide (RG) 1.28, Quality Assurance Program Criteria (Design and Construction),
Revision 5, dated October 2017, endorses NQA-1, Quality Assurance Requirements for Nuclear Facility Applications, as one acceptable method to meet the requirements of Appendix B to 10 CFR Part 50. NQA-1 provides the how to details to meet the requirements of 10 CFR 50.34(a)(7). When an applicant submits the QATR as part of a licensing request, the NRC staff will determine if the applicant has established the necessary controls to comply with the applicable requirements of Appendix B to 10 CFR Part 50, consistent with the criteria contained in NUREG-0800, Standard Review Plan, Section 17.5, Quality Assurance Program 1
Description - Design Certification, Early Site Permit, and New License Applicants, Revision 1, dated August 2015.
Although NUREG 0800 is guidance for the NRC staff related to the review of light-water reactor (LWR) applications, the QA program guidance in Section 17.5 can also be applied to non-LWRs, as the guidance is not design based.
GENERAL Question-1: 10 CFR 50.34(a)(7), Contents of applications; technical information, states that A description of the quality assurance program to be applied to the design, fabrication, construction, and testing of the structures, systems, and components of the facility. Appendix B to 10 CFR Part 50 sets forth the requirements for quality assurance programs for nuclear power plants and fuel reprocessing plants. RG 1.28 endorses NQA-1 as one acceptable method to meet the requirements of Appendix B to 10 CFR Part 50. NQA-1 provides the how to details to meet the requirements of 10 CFR 50.34(a)(7).
TerraPowers Quality Program Policy states, in part, that TerraPower (TP) has established a Quality Assurance Program that complies with 10 CFR 50 Appendix B, 10 CFR Part 21, ASME NQA-1-2015, and RG 1.28, Revision 5 for all nuclear safety related work (nuclear reactor projects), and in a graded manner to all other TP work, when applicable.
For each of the 18 criteria of Appendix B to 10 CFR Part 50, clarify whether TerraPower commits to complying with NQA-1-2015 for the implementation of TerraPowers QA program without further clarifications or exceptions. If clarifications or exceptions are needed for compliance with NQA 2015, specify the clarifications or exceptions as applicable.
ORGANIZATION Question-2: Criterion I, Organization, of Appendix B to 10 CFR Part 50 states, in part, that The persons and organizations performing quality assurance functions shall have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.
Paragraph II.A.12 in Subsection II.A of SRP 17.5 states, in part, that Provisions are established for the resolution of disputes involving quality, arising from a difference of opinion between QA personnel and other department (engineering, procurement, manufacturing, etc.) personnel.
Clarify how TerraPowers QAPD addressed the establishment of provisions for the resolutions of disputes involving quality arising from a difference of opinion between QA personnel and other department personnel.
QUALITY ASSURANCE PROGRAM Question-3: Criterion II, Quality Assurance Program, of Appendix B to 10 CFR Part 50 states, in part, that The applicant shall identify the structures, systems, and components to be covered by the quality assurance program...
Paragraph II.B.5 in Subsection II.B, Quality Assurance Program, of SRP Section 17.5 states, in part, that A list of the SSCs and/or activities under the control of the QA program is required to be established and maintained at the applicants or holders facility.
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Clarify TerraPowers plans to establish and maintain a list that identifies the structures, systems, and components (SSCs) to be covered by the QA program.
TEST CONTROL Question-4: Criterion XI, Test Control, of Appendix B to 10 CFR Part 50, states that A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. The test program shall include, as appropriate, proof tests prior to installation, preoperational tests, and operational tests during nuclear power plant or fuel reprocessing plant operation, of structures, systems, and components. Test procedures shall include provisions for assuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions. Test results shall be documented and evaluated to assure that test requirements have been satisfied.
Subsections 11.1, Test Requirements, 11.3, Computer Program Test Procedures, and 11.6, Computer Program Test Records, in Section 11 Test Control, of TerraPowers QAPD, provide information on controls for computer program testing.
Clarify if TerraPowers proposed QAPD commits to following Subpart 2.7, Quality Assurance Requirements for Computer Software for Nuclear Facility Applications, for computer program testing.
QUALITY ASSURANCE RECORDS Question-5: Criteria XVII, Quality Assurance Records, of Appendix B to 10 CFR Part 50, states that Sufficient records shall be maintained to furnish evidence of activities affecting quality. The records shall include at least the following: Operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses. The records shall also include closely-related data such as qualifications of personnel, procedures, and equipment.
Inspection and test records shall, as a minimum, identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted. Records shall be identifiable and retrievable. Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, such as duration, location, and assigned responsibility.
Section 17, Quality Assurance (QA) Records, of TerraPowers QAPD states, in part, that TP implements electronic retention of QA records and complies with NRC Regulator Guide 1.28, Revision 5, Section B, third paragraph (cites Generic Letter 88-18 and Regulatory Issue Summary 2000-18).
Subsection 17.3, Classification, in Section 17 of TerraPowers QAPD states, in part, that Records for safety related work shall be classified as lifetime or nonpermanent and maintained by TP, or authorized agent, using the guidance provided in ASME NQA-1-2015, Appendix 17A-1. In addition, this section also states, in part, that Nonpermanent records shall be maintained for the identified retention period based on guidance provided in NQA-1 (2015) Part III, Non-mandatory Subpart 3.1-17.1, Guidance on Quality Assurance Records, Paragraph 200.
The NRCs regulatory positions for the classification and retention of lifetime and nonpermanent records as well as for managing QA records in electronic media when implementing a QA program 3
based on NQA-1-2015 are described in Regulatory Positions C.3.a, Lifetime and Nonpermanent Records, and C.3.b, Managing Quality Assurance Records in Electronic Media, of RG 1.28, Revision 5, which include references to the Nuclear Information and Records Management Association technical guides. Clarify if TerraPower is committed to implementing regulatory positions C.3.a and C.3.b as described in Revision 5 of RG 1.28 for the implementation of TerraPowers QA program.
NONSAFETY-RELATED STRUCTURES, SYSTEMS AND COMPONENTS CREDITED FOR REGULATED EVENTS Question-6: In 10 CFR 50.48(a)(1), the NRC states that Each holder of an operating license issued under this part or a combined license issued under part 52 of this chapter must have a fire protection plan that satisfies Criterion 3 of appendix A to this part.
Paragraph II.U.2.a in Subsection II.U, Nonsafety-Related SSC Quality Controls, of SRP Section 17.5 states that The applicant or holder commits to implement quality requirements to the fire protection system in accordance with Regulatory Position 1.7, Quality Assurance, in RG 1.189, Fire Protection for Operating Nuclear Power Plants.
Subsection 20.1, Fire Protection, in Section 20, Non-Safety related Structures, Systems, and Components Credited for Regulatory Events, of TerraPowers QAPD states, that TP implements quality requirements for the fire protection system in accordance with Regulatory Position 1.7, Quality Assurance, in RG 1.189 Revision 2, October 2009, Fire Protection for Operating Nuclear Power Plants.
Since the NRC revised RG 1.189 (Revision 3) in February 2018, clarify why the TerraPower QAPD does not commit to meeting the latest revision of RG 1.189 (Revision 3).
QUALITY ASSURANCE PROGRAM COMMITMENTS Question-7: In 10 CFR 50.34(b)(6)(ii), the NRC states that Managerial and administrative controls to be used to assure safe operation. Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, sets forth the requirements for such controls for nuclear power plants and fuel reprocessing plants. The information on the controls to be used for a nuclear power plant or a fuel reprocessing plant shall include a discussion of how the applicable requirements of appendix B will be satisfied.
Subsection V, Quality Assurance Program Commitments, of SRP Section 17.5, provides a list of RGs, Generic Letters (GLs), and QA standards used to supplement and support the implementation of an applicants Appendix B to 10 CFR Part 50 QA program, as applicable (Note:
the list provided in this section is not all-inclusive and may not reflect the latest revision of the documents listed).
TerraPowers QAPD did not provide a list of commitments for the implementation of its QA program. The NRC staff acknowledges that because of the substantial differences between TerraPowers plant design and a LWR design, direct commitment to these RGs may not be appropriate. However, the QAPD should document those RGs, GLs, and other QA standards that are applicable and provide a justification for guidance that may not be applicable due to unique design considerations.
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