ML22325A246
| ML22325A246 | |
| Person / Time | |
|---|---|
| Site: | 99902080 |
| Issue date: | 04/20/2023 |
| From: | Holly Cruz NRC/NRR/DANU/UNPL |
| To: | Joshua Borromeo Office of Nuclear Reactor Regulation |
| References | |
| EPID L-2022-LRM-0075) | |
| Download: ML22325A246 (1) | |
Text
MEMORANDUM TO:
Joshua M. Borromeo, Chief Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation FROM:
Holly D. Cruz, Senior Project Manager Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
SUBJECT:
REPORT ON THE PRE-SUBMITTAL REGULATORY AUDIT OF THE ATOMIC ALCHEMY, INC PRELIMINARY SAFETY ANALYSIS REPORT (EPID L 2022 LRM-0075)
Atomic Alchemy, Inc (AAI) began pre-application discussions with the U.S. Nuclear Regulatory Commission (NRC) staff on their Versatile Isotope Production Reactor (VIPR) in October 2019.
Prior to submitting the VIPR construction permit preliminary safety analysis report (PSAR), the NRC staff audited a pre-submittal version of the PSAR to assess any potential gaps relative to the applicable regulations and NRC staff guidance, identify regulatory or technical issues which may complicate the review, and enhance NRC staff knowledge of the VIPR design.
The audit plan, dated October 17, 2022, is provided in the NRCs Agencywide Documents Access and Management System at Accession No. ML22286A167. The audit was conducted from October 18 through November 29, 2022, via teleconference and documents provided in BOX.
Project No.: 99902080
Enclosure:
Audit Report CONTACT: Holly D. Cruz, NRR/DANU (301) 415-1053 April 20, 2023 Signed by Cruz, Holly on 04/20/23
ML22325A246 NRR-106 OFFICE NRR/DANU/UNPL/PM NRR/DANU/UNPL/LA NRR/DANU/UNPL/BC NRR/DANU/UNPL/PM NAME HCruz NParker JBorromeo HCruz DATE 3/30/2023 4/4/2023 4/18/2023 4/20/2023
Enclosure ATOMIC ALCHEMY, INC
SUMMARY
REPORT ON THE PRE-SUBMITTAL REGULATORY AUDIT OF ATOMIC ALCHEMY, INC PRELIMINARY SAFETY ANALYSIS REPORT October - November 2022
1.0 BACKGROUND
Atomic Alchemy, Inc (AAI) began pre-application discussions with the U.S. Nuclear Regulatory Commission (NRC) staff on their Versatile Isotope Production Reactor (VIPR) in October 2019.
Over the past several years, AAI has submitted topical reports and white papers that apply to the VIPR. As discussed in various teleconferences and in a meeting held on August 9, 2022, AAI plans to submit an application for a construction permit (CP), including a preliminary safety analysis report (PSAR), for the VIPR in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities. The staff plans to review the PSAR in accordance with NUREG-1537, Part 1, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Format and Content (Agencywide Documents Access and Management System Accession No. ML042430055), or applicable guidance.
2.0 AUDIT REGULATORY BASES The bases for the audit are the regulations in 10 CFR Part 50, Section 50.34(a), Preliminary safety analysis report, and Section 50.35, Issuance of construction permits.
3.0 AUDIT PURPOSE AND OBJECTIVES The purpose of this audit was to provide the NRC staff with an opportunity to assess the readiness of the draft PSAR before AAI formally submits the CP application. This audit allowed the NRC staff to (1) identify any required information that is missing from the application, (2) identify technical or regulatory issues that may complicate the acceptance or technical reviews of the application, and (3) become familiar with the content of the application, particularly in areas where AAI plans to propose new concepts or novel design features.
4.0 SCOPE OF THE AUDIT AND AUDIT ACTIVITIES The audit was conducted October 18, 2022, through November 29, 2022, via teleconference, and documents provided in BOX. The NRC staff conducted the audit in accordance with the pre-application audit plan dated October 17, 2022 (ML22286A167). There were no deviations from the audit plan.
2 NRC staff audit team members included:
Michael Balazik Project Manager, Division of Advanced Reactors and Non-Power Production and Utilization Facilities (DANU) Audit Lead (responsible for technical review)
Holly Cruz Sr. Project Manager, DANU (responsible for audit logistics)
Justin Hudson Project Manager, DANU Xiaosong Yin Project Manager, DANU Duane Hardesty Sr. Project Manager, DANU Michael Takacs Security Specialist, DANU Joshua Borromeo Branch Chief, DANU Laurel Bauer Geologist, Division of Engineering and External Hazards (DEX)
Kevin Quinlan Meteorologist, DEX Kenneth See Hydrologist, DEX Bryce Lehman Structural Engineer, DEX Andrew Prinaris Structural Engineer, DEX Ian Tseng Mechanical Engineer, DEX Adam Rau Nuclear Systems Performance, Division of Safety Systems (DSS)
Kevin Heller Nuclear Methods and Fuel Analysis, DSS Gordon Curran Reactor Systems Engineer, DSS Rao Karipineni Safety and Plant Systems Engineer, DSS Rossnyev Alvarado Instrumentation and Controls, DEX Norbert Carte Instrumentation and Controls, DEX Dinesh Taneja Senior Electronics Engineer, DEX Jorge Cintron-Rivera Electrical Engineer, DEX Yawar Faraz Fuel Facility Licensing, Office of Nuclear Material Safety and Safeguards (NMSS)
Charles Moulton Fire Protection Engineer, Division of Risk Assessment (DRA)
Jay Robinson Senior Fire Protection Engineer, DRA Zachary Gran Radiation Protection and Consequence, DRA Edward Robinson Senior Emergency Preparedness Specialist, Office of Nuclear Security and Incident Response (NSIR)
Kenneth Mott Emergency Preparedness Specialist, NSIR Charles Teal Materials Security, NSIR Dan Warner Cybersecurity, NSIR Andrea Keim Quality Assurance and Vendor Inspection, Division of Reactor Oversight Amy Beasten Non-Power Production and Utilization Facility Oversight, DANU Kevin Roche Non-Power Production and Utilization Facility Oversight, DANU Nancy Martinez Environmental Scientist, NMSS Glenn Tuttle Material Control and Accounting, NMSS Elijah Dickson Senior Reliability and Risk Analyst, DRA Trent Wertz Senior Financial Analyst, NMSS
3 The NRC staff audited parts of the following documents:
1.
Overall Introduction to the VIPR Design 2.
AAI PSAR Chapters 2, 3, 4a, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 16 Appendix A, 17 and 21 The NRC staff did not acquire any documents during the audit.
5.0
SUMMARY
OF OBSERVATIONS The NRC staffs general audit observations are provided below. The main purpose of the audit was to identify issues which could challenge potential acceptance of the PSAR when submitted, as well as to identify highly challenging regulatory or technical issues which may need additional documentation. A detailed summary of NRC staff comments are provided for AAI reference, as a non-public attachment to this audit report, which may help to provide a more comprehensive submittal.
General Observations:
1.
The NRC staff observed that in many instances information was not provided in the PSAR, and AAI notes that this information (sections, figures, tables, appendices, etc.)
will be further developed in the final safety analysis report (FSAR). The staffs inability to review this information limits the effectiveness of the pre-application audit. This deferred review may result in a prolonged acceptance review period. Additionally, should the FSAR provide incomplete information, the CP acceptance review may result in non-acceptance with the opportunity to supplement.
2.
The NRC staff notes that based on the draft PSAR, VIPR analysis methodologies may include significant changes from established methodologies. Accordingly, additional staff review may be necessarily during reviews of a CP and/or operating license (OL) application.
3.
The NRC staff observed that in some cases the PSAR does not clearly distinguish and/or justify what information is planned to be deferred to an OL application.
6.0 EXIT BRIEFING The NRC staff conducted an audit closeout meeting on November 30, 2022. At the exit briefing the staff reiterated the purpose of the audit and discussed the activities conducted.
7.0 REQUESTS FOR ADDITIONAL INFORMATION RESULTING FROM AUDIT The staff provided AAI questions and feedback during the audit, which AAI could consider and use to revise the PSAR prior to submittal of the CP application.
8.0 OPEN ITEMS AND PROPOSED CLOSURE PATHS Not applicable. There are no open items as a result of this audit.