ML21073A003
| ML21073A003 | |
| Person / Time | |
|---|---|
| Issue date: | 03/17/2021 |
| From: | Cuadrado S NRC/NRR/DANU/UARL |
| To: | Benjamin Beasley NRC/NRR/DANU/UARL |
| Cuadrado de Jesus S | |
| References | |
| Download: ML21073A003 (4) | |
Text
March 17, 2021 MEMORANDUM TO: Benjamin Beasley, Chief Advanced Reactor Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation FROM: Samuel Cuadrado, Project Manager Advanced Reactor Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF NOVEMBER 19, 2020, PUBLIC MEETING TO DISCUSS KAIROS POWER LLCS QUALITY ASSURANCE PROGRAM TOPICAL REPORT CLARIFICATION QUESTIONS SET 2 On November 19, 2020 (Agencywide Documents Access and Management System (ADAMS) under Accession No. ML20315A525), the U.S. Nuclear Regulatory Commission (NRC) staff held a virtual Category 1 public meeting with Kairos Power LLC (Kairos) using the Microsoft Teams platform. The purpose of the meeting was to discuss with Kairos the second set of NRCs clarification questions regarding Kairos Quality Assurance (QA) Program topical report (TR). The NRCs clarification questions can be found in ADAMS under Accession No. ML20311A208. The list of attendees is provided as an enclosure to this document. Members of the public were not in attendance.
The NRCs second set of clarification questions had four questions that were shared with Kairos via email on October 29, 2020 (ADAMS Accession No. ML20311A231), prior to the public meeting. During the meeting Kairos and the NRC staff discussed each of the four clarification questions.
Question 1 requested clarification on Kairos TR Section 2.5 regarding the regulatory process that would be used by Kairos to handle changes to NRC-accepted QA TRs.
Kairos stated that based on the February 19, 2020 (ADAMS Accession No. ML20092J195),
public meeting discussion with the staff and the staffs safety evaluation report (SER) on Westinghouse QA TR (ADAMS Accession No. ML19246A008) that it understood that in addition to the Title 10 of the Code of Federal Regulations (10 CFR) 50.4 process it could use the 10 CFR 50.54(a) regulatory process to make changes to its QA TR.
CONTACT: Samuel Cuadrado, NRR/DANU 301-415-2946
B. Beasley 2 The NRC staff stated that Westinghouse has had an established and mature program for many years that has been inspected many times and for which the staff has lots of oversight, and due to these facts the methodology proposed by Westinghouse to evaluate changes to its QA TR was approved by the staff.
The NRC staff noted that as a non-licensee, changes to an approved Kairos QA TR by Kairos are pursuant to 10 CFR Section 50.4.b.7, which states, in part, that change to an NRC-accepted quality assurance topical report from non licensees must be submitted for approval.
Kairos stated that they will discuss this question internally and may need to have further discussions with the staff on this matter in another public meeting.
Question 2 requested clarification on Kairos QA Program Independent Review Group reporting.
Kairos stated that to address this question it plans to make some editorial changes to its QA TR. These revisions to the TR will be provided to the staff in an upcoming submittal of the revised QA TR. The staff stated that it was okay with the proposed approach.
Question 3 requested clarification on Kairos QA TR Section 2.6, Personnel Training and Qualifications, alignment with the time requirement of 18 months described in 10 CFR 50.120, Training and qualification of nuclear power plant personnel. Kairos stated that the 18-month time requirement from 10 CFR 50.120 must be met irrespective of the commitments to the National Nuclear Accrediting Board of the National Academy of Nuclear Training (NNAB/NANT) accredited programs. The staff stated that it will discuss internally to determine if the clarification provided by Kairos is enough to address the staffs question or if the information would need to be provided on the docket.
Question 4 requested clarification regarding Kairos QA program tracking of dates of certification or recertification and date of certification expiration to be maintained for training and certification records. Kairos stated that its QA program description requires that the date of certification (or recertification) be recorded in the subject records of qualification. Kairos also stated that its QA program description does not require the recording date of certification expiration, this remains optional. The Kairos QA program description conforms to the remaining provisions of NQA-1-2015, Requirement 2, Section 401. The staff stated that Kairos clarification addressed its concern.
Kairos asked what the planned timeline for receipt of additional clarification questions from the staff was. The NRC staff stated that if no major issues come up during the remaining review of Kairos QA TR, staff plans to have its next and last set of clarification question to Kairos by January 2021. In closing the staff stated that, if possible, it plans to discuss the next set of clarification questions with Kairos during a public meeting to be held by January 2021.
Project No. 99902069
Enclosure:
List of attendees
ML21073A003 NRC-001 OFFICE NRR/DANU/UARL/PM NRR/DANU/UARL/LA NRR/DANU/UARL/BC NRR/DANU/UARL/PM NAME SCuadrado SLent BBeasley SCuadrado DATE 3/15/21 3/15/21 3/17/21 3/17/21 List of Attendees NAME ORGANIZATION John Price Kairos Power LLC (Kairos)
Darrell Gardner Kairos Peter Hastings Kairos Zack Rad Kairos Kerri Kavanagh U.S. Nuclear Regulatory Commission (NRC)
Stu Magruder NRC Jonathan Ortega NRC Paul Prescott NRC Samuel Cuadrado NRC Enclosure