ML21025A053

NRC Staff Set 3 Preliminary Clarification Questions for the Kairos Quality Assurance Program Topical Report

ML21025A053
Person / Time
Site:	99902069
Issue date:	01/15/2021
From:	Cuadrado De Jesus S NRC/NRR/DANU/UARL
To:	Gardner D, Peebles D, Price J Kairos Power
Cuadrado J
References
KP-TR-007-NP
Download: ML21025A053 (4)

Text

From:

Cuadrado de Jesus, Samuel To:

Drew Peebles; Darrell Gardner; John Price Cc:

Ortega-Luciano, Jonathan; Kavanagh, Kerri; Magruder, Stewart; Beasley, Benjamin

Subject:

NRC Staff Set 3 Preliminary Clarification Questions for the Kairos Quality Assurance Program Topical Report Date:

Friday, January 15, 2021 9:31:00 AM Attachments:

NRC Staff Set 3 Preliminary Clarification Questions for the Kairos Quality Assurance Program TR 1-15-2021.pdf Mr. Peebles,

The NRC staff has completed an initial review of Kairos Quality Assurance Topical Report and developed a third set of preliminary questions (attached) 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.

Please let me know if you have any questions.

Regards, Samuel Cuadrado de Jesús Project Manager Advanced Reactor Licensing Branch (UARL)

Division of Advanced Reactors and Non-Power Production and Utilization Facilities (DANU)

U.S. Nuclear Regulatory Commission Phone: 301-415-2946 Samuel.CuadradoDeJesus@nrc.gov

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 3 Questions:

1. Criterion V Kairos Quality Assurance Program (QAP) Part IV, Regulatory Commitments, states that Kairos commits to Regulatory Guide (RG) 1.33, Revision 3 with no exceptions.

Furthermore, in Section 3, Operational Phase Procedures, of Part V, Additional Quality Assurance and Administrative Controls for the Plant Operational Phase, states, in part, that Kairos Power follows the guidance of Appendix A to RG 1.33 in identifying the types of activities that should have procedures or instructions to control the activity.

i.

Revision 3 of RG 1.33 does not contain an appendix. Appendix A was removed from RG 1.33, and its content was incorporated into Appendix A of the American Nuclear Society (ANS) 3.2-2012, American National Standard Managerial, Administrative, and Quality Assurance Controls for the Operational Phase of Nuclear Power Plants.

Clarify if the reference to Appendix A to RG 1.33 in Section 3 of Part V is a typographical error.

2. Criterion VI Kairos QAP Section 6.1, Review and Approval of Documents, of Part II, Quality Assurance Program Description (QAPD) Details, states, in part, that To ensure effective and accurate procedures during the operational phase, applicable procedures are reviewed, and updated as necessary, based on the following conditions:

Following any modification to a system Following an unusual incident, such as an accident, significant operator error, or equipment malfunction When procedure discrepancies are found Prior to use if not used in the previous two years Results of QA audits conducted in accordance with Part II, Section 18.1 (This section does not apply to non-operations activities.)

i.

Section 3.6, "Document Control," of the American Nuclear Society (ANS) 3.2-2012, states that Plant procedures shall be reviewed by an individual (or individuals) knowledgeable in the aspects of the technical content and of human factors affected by the procedure within 6 months following startup after the first refueling outage of the unit to determine if changes are necessary or desirable. Applicable procedures shall also be reviewed following an unusual incident, such as an accident, an unexpected transient, significant operator error, or equipment malfunction, or following any modification to a system or prior to use if the procedure has not been used in the previous 2 years."

Clarify how Kairos plans to address the provisions [bold text above] contained within Section 3.6 of ANS 3.2-2012.

3. Criterion VII Kairos QAP Section 7.2, NQA-1 Commitment / Exception, of Part II commits to the 2017 Edition of ISO/IEC-17025, "General Requirements for the Competence of Testing and Calibration Laboratories."

Due to the travel restrictions resulting from the COVID-19 pandemic, the International Laboratory Accreditation Cooperation (ILAC) extended the transition period to implement the International Standard Organization (ISO) standard 17025:2017 from November 30, 2020 to June 1, 2021. Considering ILAC's extension of the transition period, the latest edition of NEI 14-05A also recognizes June 1, 2021, as an acceptable date for laboratories to transition to ISO 17025:2017 (Agencywide Documents Access and Management System (ADAMS) Accession No.: ML20325A192).

i.

The NRC staff has not endorsed the latest edition of NEI 14-05A (ISO 17025:2017) and as explained above the transition period has been extended to June 1, 2021.

Clarify if Kairos is still planning to commit to ISO 17025:2017.

4. Criterion XVIII Kairos QAP Section 18.1, Performance of Audits, of Part II, specifically the third paragraph, states that Kairos Power is responsible for conducting periodic internal to determine the adequacy of programs and procedures (by representative sampling), and to determine if they are meaningful and comply with the overall QAPD.

It seems that this sentence is incomplete. Clarify if intent of the phrase should be conducting periodic internal audits.

5. Clarifications needed for Section V, Quality Assurance Program Commitments, of SRP 17.5 SRP 17.5 Section V, first bullet, states that The reviewer shall verify that the applicant or holder commits to the most recent revision of the RGs and generic letter (GLs) listed below. Exceptions or alternatives to the specific criteria in any of these RGs and GLs may be proposed by applicants or holders provided adequate justification is provided.

i.

The following items are not included in Part IV, Regulatory Commitments, of the QAP nor an exception or justification provided:

1. GL 89-02, Actions to Improve the Detection of Counterfeit and Fraudulently Marked Products

2. GL 91-05, Licensee Commercial-Grade Dedication Programs.

Clarify if Kairos commits to or takes exception to the items listed above.