ML23023A276
| ML23023A276 | |
| Person / Time | |
|---|---|
| Site: | 99902094 |
| Issue date: | 01/27/2023 |
| From: | Adrian Muniz NRC/NRR/DANU/UAL2 |
| To: | Brooks C Terrestrial Energy |
| Muniz A | |
| References | |
| EPID L-2022-NFN-0004 | |
| Download: ML23023A276 (5) | |
Text
Dr. Caleb S. Brooks, Associate Professor University of Illinois at Urbana-Champaign Department of Nuclear, Plasma, and Radiological Engineering Talbot Laboratory, Room 111C, MC-234 104 South Wright St.
Urbana, IL 61801
SUBJECT:
UNIVERSITY OF ILLINOIS AT URBANA-CHAMPAIGN - REQUEST FOR ADDITIONAL INFORMATION REGARDING QUALITY ASSURANCE PROGRAM DESCRIPTION (EPID NO. L-2022-NFN-0004)
Dear Dr. Brooks:
By letter dated October 20, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22320A086), the University of Illinois at Urbana-Champaign (UIUC) submitted; pursuant to Title 10 of the Code of Federal Regulations (10 CFR)
Sections 50.34(a)(7) and 50.34(b)(6)(ii); its Quality Assurance Program Description (QAPD) for its proposed non-power reactor to the U.S. Nuclear Regulatory Commission (NRC) staff for its review and approval.
The NRC staff identified additional information needed to continue its review of the QAPD, as described in the enclosure to this letter. As discussed, provide a response to the request for additional information (RAI) within 30 days of the date of this letter. Following receipt of the complete response to the RAI, the NRC staff will continue its review of the QAPD.
The response to the RAI must be submitted in accordance with 10 CFR 50.4, Written communications, and pursuant to 10 CFR 50.30(b), Oath or affirmation, and be executed in a signed original document under oath or affirmation. Information included in the response that you consider sensitive or proprietary, and seek to have withheld from public disclosure, must be marked in accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding. Any information related to safeguards should be submitted in accordance with 10 CFR 73.21, Protection of Safeguards Information: Performance Requirements.
January 27, 2023
Dr. C. Brooks If you have any questions regarding the NRC staffs review or if you intend to request additional time to respond, please contact me at (301) 415-4093 or via e-mail at Adrian.Muniz@nrc.gov.
Sincerely, Adrian Muniz, Senior Project Manager Advanced Reactor Licensing Branch 2 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Project No. 99902094
Enclosure:
As stated Signed by Muniz Gonzalez, Adrian on 01/27/23
ML23023A276 NRR-088 OFFICE NRR/DANU/UAL2:PM NRR/DANU/UAL2:LA NRR/DRO/IQVB:BC NRR/DANU/UAL2:BC NRR/DANU/UAL2:PM NAME AMuniz CSmith KKavanagh MWentzel AMuniz DATE 1/23/2023 1/25/2023 1/25/2023 1/26/2023 1/27/2023
Enclosure REQUEST FOR ADDITIONAL INFORMATION QUALITY ASSURANCE PROGRAM DESCRIPTION FOR THE UNIVERSITY OF ILLINOIS AT URBANA-CHAMPAIGN NON-POWER REACTOR DOCKET NO. 99902094 EPID NO. L-2022-NFN-0004
Background:
By letter dated October 20, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22320A086), the University of Illinois-Champaign (UIUC) submitted its Quality Assurance Program Description (QAPD) topical report for its proposed non-power reactor for approval. UIUC submitted the topical report pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Sections 50.34(a)(7) and 50.34(b)(6)(ii). The NRC staff has reviewed the topical report and has identified that additional information is needed to complete its review as discussed in the requests for additional information (RAIs) and request for confirmation of information (RCI) below.
The regulation in 10 CFR 50.34(a)(7), requires that a preliminary safety analysis report include
[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. In addition, the regulation in 10 CFR 50.34(b)(6)(ii) requires a final safety analysis report to include managerial and administrative controls to be used to assure safe operation of the facility.
Guidance in NRC Regulatory Guide (RG) 2.5, Quality Assurance Program Requirements for Research and Test Reactors, Revision 1, dated June 2010 (ADAMS Accession No. ML093520099), which states that the general requirements for establishing and executing a quality assurance program for the design, construction, testing, modification, and maintenance of research and test reactors in American National Standards Institute/American Nuclear Society (ANSI/ANS)-15.8-1995, Quality Assurance Program Requirements for Research, provide an acceptable method for complying with the program requirements of 10 CFR 50.34, Contents of Applications; Technical Information. UIUC states in the topical report that the QAPD describes the methods and establishes quality assurance (QA) and administrative control requirements that meet 10 CFR 50.34, based on the criteria of ANSI/ANS15.8 as endorsed by RG 2.5, Revision 1. Therefore, the NRC staff used ANSI/ANS-15.8-1995 (Reaffirmed 2013) as the basis for evaluating the acceptability of the UIUC QAPD in conformance with the provisions of 10 CFR 50.34(a)(7) and 50.34(b)(6)(ii).
RAIs and RCI:
RAI-1: Section 2.2, Quality Assurance Programs of the QAPD states, in part, that This QAP provides for the use of a graded approach to quality. The measures applied to a particular engineered or administrative control or control system may be graded commensurate with the reduction of the risk attributable to that control or control system. This approach to achieving levels of quality is described in the QAPD and related implementing documents. However, the QAPD topical report does not seem to discuss this graded approach to quality. Therefore, the NRC staff is requesting that UIUC provide additional information on this approach and how it plans to assign quality levels to the SSCs and activities.
RAI-2: Section 2.1.4, Engineering Support and Operations Manager of the QAPD states, in part, that the Engineering support and operations manager is responsible for providing oversight of outside organizations or support contractors and suppliers. Section 2.1.7, Quality Assurance Manager of the QAPD states, in part, that the QA manager is responsible for ensuring that the suppliers provide quality services, parts and materials that conform with applicable QA requirements.
Provide additional information on the roles and responsibilities of the engineering and QA organizations as it pertains to adequate supplier oversight responsibilities as described in ANSI/ANS-15.8 Section 2.7, Control of Purchased Items and Services.
RAI-3: Section 55.4 to 10 CFR, provides a definition of operator. QAPD Section 1.2, Definitions include the following definitions:
a.
Certified operator - An individual authorized by the chartering or licensing organization to carry out the duties and responsibilities associated with the position requiring the certification.
b.
Licensed operator - see certified operator Describe the authorizations required to certify or license an operator for UIUC.
RAI-4: ANSI-ANS 15.8, Section 2.10, Inspection states, in part, that The inspection program shall apply to procurement, construction, modification, maintenance, and experiment fabrication.
The NRC staff notes that the UIUC QAPD does not address experiment fabrication activities.
Please clarify whether the QAPD will cover experiment fabrication activities or address why not.
RCI-1: Section 2.7 of ANSI/ANS-15.8, Control of Purchased Items and Services, as reflected in QAPD 2.7 states, in part, that The procurement of items and services shall be controlled to ensure appropriate procurement planning, source evaluation and selection, evaluation of objective evidence of quality furnished by the supplier, source inspection, audit, and examination of items or services for acceptance upon delivery or completion.
QAPD Section 2.18, Assessments, consistent with Section 2.18 of ANSI/ANS-15.8, states, in part, that UIUC conducts periodic assessments of qualityaffecting activities during design, construction, modification, and operations to evaluate the effectiveness of the asimplemented quality program. Assessments shall be performed in accordance with written procedures or checklists.
Please confirm that the terms assessment and audit can be used interchangeably within the UIUC QAPD.