ML22217A097
| ML22217A097 | |
| Person / Time | |
|---|---|
| Site: | 99902071 |
| Issue date: | 09/13/2022 |
| From: | Vechioli-Feliciano L NRC/NRR/DANU/UAL1 |
| To: | Greg Oberson NRC/NRR/DANU/UAL1 |
| Vechioli-Feliciano L | |
| References | |
| Download: ML22217A097 (9) | |
Text
1 Clean
- Safe
- Secure
- Affordable Change Summary July 11, 2022 X-energy Quality Assurance Program Description Rev. 4
2 Quality Assurance Program Description (QAPD) Revision 4
- Document changes primarily address QAPD scope expansion to include X-energy functions beyond Xe-100 reactor design certification
- Construction and Operation Phases of Xe-100 operating plants
- Development of Triso-X fuels
- Updates to the X-energy organization
- Incorporate Quality Program audit flexibility under exigent conditions
3 QAPD Revision 4 Changes Part I - INTRODUCTION Revised to address quality program integration with management systems resulting from the QAPD scope expansion to include fuels development, and construction and operations project phases Part II - QUALITY ASSURANCE PROGRAM DESCRIPTION DETAILS
- Section 1 Organization Revised to reflect changes in the X-energy Organizational structure and responsibilities resulting from scope expansion to include the construction and operations phases, and development of Triso-X Fuels
- Section 2 Quality Assurance Program Discussions include expanded construction and operations phase applicability and responsibilities.
Added discussion for applying extended grace periods under exigent conditions. This fully remote exigent allowance was presented in ML21160A245 and approved by SER in ML20216A681.
Included applicable requirements of 10 CFR 50.54 to reflect regulatory requirements resulting from expanded scope.
4 QAPD Revision 4 Changes (Continued)
- Section 3 Design Control Revised to include requirements for temporary modifications, setpoint control and NQA-1-2015 Subpart 20 subsurface investigation requirements
- Section 6 Document Control Revised to include additional controls and temporary procedure changes in construction and operations phases Part III - NONSAFETY-RELATED SSC QUALITY CONTROL Revised to reflect unique requirements of the Xe-100 HTGR design, and applicability to construction and operations phases
5 QAPD Revision 4 Changes (Continued)
Part IV - REGULATORY GUIDES AND STANDARDS Revised to include discussion of conformance of standards to license applications in accordance with 10 CFR 50 and 10 CFR 52 as applicable Part V - ADDITIONAL QUALITY ASSURANCE AND ADMINISTRATIVE CONTROLS FOR THE PLANT OPERATIONAL PHASE Added to establish the necessary measures and governing procedures for the operational phase of the nuclear plant RAI RESPONSE INCORPORATION RAI-4 Section 7.1:
Removed discussion regarding auditing of National Labs based on post Rev 3 submittal discussion with NRC RAI 5 Section 16.1:
Expanded phase applicability required identifying possible requirements for each phase.
X-energy has appropriate interfaces between the QAP, for corrective actions, and the non-QA Reporting Program to satisfy the requirements of 10 CFR 52, 10 CFR 50.55 and/or 10 CFR 21 during ESP/CP/COL design and construction, and 10 CFR 21 during operations.
6 QAPD Revision 4 Changes (Continued)
RAI RESPONSE INCORPORATION (continued)
RAI-6 Section 8.0:
Discussion was modified as a result of phase expansion. Original content was used for justification only during DC.
Statement deleted-as X-energy will be purchasing materials, parts and components for test purposes (includes fuel and graphite irradiation testing that will be performed by X-energy suppliers)
RAI-7 Section 9.0:
Discussion on XE suppliers was deleted consistent with response in Section 8.0.
Discussion of qualification records control was not necessary to this section.
as X-energy suppliers will be performing destructive and nondestructive testing for test purposes (includes fuel and graphite irradiation testing).
7 QAPD Revision 4 Changes (Continued)
RAI RESPONSE INCORPORATION (continued)
RAI-9 Section 11.0:
The subject of the RAI for inclusion of an item to address suitable environmental conditions, was not altered. The deletion of the supplier testing performance is consistent with deletions in other sections and data integrity per NQA-1 is sufficiently identified in the Section 11 Commitment discussions.
Included discussion on Initial Start-up test program:
The initial start-up test program is planned and scheduled to permit safe fuel loading and start-up; to increase power in safe increments; and to perform major testing at specified power levels. If tests require the variation of operating parameters outside of their normal range, the limits within which such variation is permitted will be prescribed. The scope of the testing demonstrates, insofar as practicable, that the plant is capable of withstanding the design transients and accidents. For new facility construction, the suitability of facility operating procedures is checked to the maximum extent possible during the pre-operational and initial start-up test programs.
8 QAPD Revision 4 Changes (Continued)
RAI RESPONSE INCORPORATION (continued)
RAI-12 Section 14.0:
Discussion was modified as a result of phase expansion. Original content was used for justification only during DC Deleted: - as X-energy suppliers will perform testing and irradiation for test purposes (includes fuel and graphite irradiation testing)
RAI-13 Section 15.0:
Discussions on personnel performing evaluations, and disposition of nonconforming items have been included. Examples and supplier supplemental info are excluded RAI-14 PART IV:
Regulatory Guides revised consistent with expanded phases and unique needs of the Xe-100 HTGR
9 x-energy.com @xenergynuclear X Energy, LLC