ML23116A183
| ML23116A183 | |
| Person / Time | |
|---|---|
| Site: | 99902100 |
| Issue date: | 05/09/2023 |
| From: | Proffitt J NRC/NRR/DANU/UAL1 |
| To: | George Wilson TerraPower |
| Devlin-Gill S | |
| Shared Package | |
| ML23116A179 | List: |
| References | |
| EPID L-2022-TOP-0054, CAC 000431, TP-QA-PD-0001 | |
| Download: ML23116A183 (6) | |
Text
Enclosure TERRAPOWER, LLC - SAFETY EVALUATION OF QUALITY ASSURANCE TOPICAL REPORT TP-QA-PD-0001, TERRAPOWER QA PROGRAM DESCRIPTION, REVISIONS 13 AND 14 (EPID L-2022-TOP-0054/CAC 000431)
SPONSOR AND SUBMITTAL INFORMATION Sponsor:
TerraPower, LLC Sponsor Address:
15800 Northup Way Bellevue, WA 98008 Docket/Project No.:
99902100 Submittal Date:
September 23, 2022 Submittal Agencywide Documents Access and Management System (ADAMS)
Accession No.: ML22266A286 Brief Description of the Topical Report:
By letter dated September 23, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22266A286), TerraPower, LLC (TerraPower) submitted for the U.S.
Nuclear Regulatory Commission (NRC) staff review and approval Quality Assurance Topical Report (QATR) TP-QA-PD-0001, TerraPower QA Program Description, Revision 14, according to Title 10 of the Code of Federal Regulations (10 CFR) 50.4(b)(7)(ii). QATR TP-QA-PD-0001 addresses the activities associated with the design and construction of TerraPowers advanced nuclear power reactor and is based on the applicable portions of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, and American Society of Mechanical Engineers (ASME) NQA-1-2015, Quality Assurance Requirements for Nuclear Facility Applications, as endorsed by NRC Regulatory Guide 1.28, Revision 5, Quality Assurance Program Criteria (Design and Construction), dated October 2017 (ML17207A293). Revision 12 of QATR TP-QA-PD-0001 was previously approved by the NRC staff in a safety evaluation dated January 2022 (ML21263A236). Therefore, the NRC staff reviewed the changes between Revision 12 and Revision 14, including Revision 13.
The results of this review are summarized in the following sections of this safety evaluation.
REGULATORY EVALUATION Appendix B to 10 CFR Part 50 establishes QA requirements for the design, fabrication, construction, testing, and operation of structures, systems, and components (SSCs) of a nuclear power plant. The pertinent requirements of Appendix B to 10 CFR Part 50 apply to all activities affecting the safety-related functions of those SSCs and include designing, purchasing,
fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying SSCs.
TECHNICAL EVALUATION Revision 13 of QATR TP-QA-PD-0001 includes four changes from Revision 12 related to the clarification of: (1) engineering roles and responsibilities; (2) safety classifications; (3) review of specifications by the QA organization; and (4) suppliers not holding accreditation by an accrediting body recognized by the International Laboratory Accreditation Cooperation Mutual Recognition Arrangement. In addition, Revision 14 of QATR TP-QA-PD-0001 includes changes throughout from Revision 13 for the consistent use of the title CEO/President.
The format and content of QATR TP-QA-PD-0001 for design and construction was previously evaluated in accordance with NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, Standard Review Plan (SRP), Section 17.5, Revision 1, Quality Assurance Program Description - Design Certification, Early Site Permit and New License Applicants, dated August 2015 (ML15037A441). The acceptability of the level of detail in QATR TP-QA-PD-0001 is determined, in part, by its adequacy in addressing the acceptance criteria of SRP Section 17.5.
1.0 Format and Content of the QATR The format used for the following evaluation follows the sequence of the 18 criteria of Appendix B to 10 CFR Part 50 and the acceptance criteria of SRP Section 17.5.
With respect to the changes throughout Revision 14 of QATR TP-QA-PD-0001 for the consistent use of the title CEO/President, the NRC staff determined that these changes are administrative in nature and have no impact on current commitments in the QATR, which were previously accepted by the NRC staff. Therefore, the NRC staff finds the proposed changes acceptable.
1.1 Organization Section 1, Organization, of QATR TP-QA-PD-0001, Revision 13, includes the following revision:
Subsection 1.4, Engineering and Technical Authority, clarifies the engineering roles and responsibilities to adequately reflect TerraPowers current organization.
The NRC staff determined that this change is administrative in nature and has no impact on current commitments in the QATR, which were previously accepted by the NRC staff. The NRC staff concludes that there is reasonable assurance that the requirements of Criterion I, Organization, of Appendix B to 10 CFR Part 50 continue to be met. Therefore, the NRC staff finds the proposed change acceptable.
1.2 Quality Assurance Program Section 2, Quality Assurance Program, of QATR TP-QA-PD-0001, Revision 13, includes the following revision:
In Subsection 2.9, Application of [Quality Assurance Program Description] Based on Quality Level, the Department of Energys safety classification of Safety Significant was moved from Quality Level 2 to Quality Level 1.
TerraPowers QATR Quality Levels are a designation that indicates the compliance basis for complete work and considers regulatory and customer requirements. The NRC staff determined that moving this safety classification has no impact on current commitments in the QATR, which were previously accepted by the NRC staff. The NRC staff concludes that there is reasonable assurance that the requirements of Criterion II, Quality Assurance Program, of Appendix B to 10 CFR Part 50 continue to be met. Therefore, the NRC staff finds the proposed change acceptable.
1.3 Design Control Section 3, Design Control, of QATR TP-QA-PD-0001, Revision 13, includes the following revision:
Section 3 clarifies that specifications will be reviewed by the QA organization as defined in the implementing procedures or as requested by Engineering.
The NRC staff determined that this clarification has no impact on current commitments in the QATR, which were previously accepted by the NRC staff. The NRC staff concludes that there is reasonable assurance that the requirements of Criterion III, Design Control, of Appendix B to 10 CFR Part 50 continue to be met. Therefore, the NRC staff finds the proposed change acceptable.
1.4 Procurement Document Control In Section 4, Procurement Document Control, of QATR TP-QA-PD-0001, Revision 14, TerraPower made no changes to the QATR, which was previously accepted by the NRC staff, related to procurement document control.
1.5 Instructions, Procedures, and Drawings In Section 5, Instructions, Procedures and Drawings, of QATR TP-QA-PD-0001, Revision 14, TerraPower made no changes to the QATR, which was previously accepted by the NRC staff, related to instructions, procedures, and drawings.
1.6 Document Control In Section 6, Document Control, of QATR TP-QA-PD-0001, Revision 14, TerraPower made no changes to the QATR, which was previously accepted by the NRC staff, related to document control.
1.7 Control of Purchased Material, Equipment, and Services In Section 7, Control of Purchased Items and Services, of QATR TP-QA-PD-0001, Revision 14, TerraPower made no changes to the QATR, which was previously accepted by the NRC staff, related to control of purchased material, equipment, and services.
1.8 Identification and Control of Materials, Parts, and Components In Section 8, Identification and Control of Items, of QATR TP-QA-PD-0001, Revision 14, TerraPower made no changes to the QATR, which was previously accepted by the NRC staff, related to identification and control of materials, parts, and components.
1.9 Control of Special Processes In Section 9, Control of Special Processes, of QATR TP-QA-PD-0001, Revision 14, TerraPower made no changes to the QATR, which was previously accepted by the NRC staff, related to control of special processes.
1.10 Inspection In Section 10, Inspection, of QATR TP-QA-PD-0001, Revision 14, TerraPower made no changes to the QATR, which was previously accepted by the NRC staff, related to control of inspection.
1.11 Test Control In Section 11, Test Control, of QATR TP-QA-PD-0001, Revision 14, TerraPower made no changes to the QATR, which was previously accepted by the NRC staff, related to test control.
1.12 Control of Measuring and Test Equipment Section 12, Control of Measuring and Test Equipment, of QATR TP-QA-PD-0001, Revision 13, includes the following revision:
Subsection 12.3, Calibration and Control, clarifies that when purchasing calibration services from a laboratory not holding accreditation by an accrediting body recognized by the International Laboratory Accreditation Cooperation Mutual Recognition Arrangement, reference standards shall have a minimum accuracy four times greater than that of the measuring and test equipment being calibrated to ensure that the reference standards contribute no more than one-fourth of the allowable calibration tolerance.
The NRC staff determined that this clarification has no impact on current commitments in the QATR, which were previously accepted by the NRC staff. In addition, requiring reference standards to have a minimum accuracy of four times greater than that of the measuring and test equipment being calibrated is a widely adopted industry convention. The NRC staff concludes that there is reasonable assurance that the requirements of Criterion XII, Control of Measuring and Test Equipment, of Appendix B to 10 CFR Part 50 continue to be met. Therefore, the NRC staff finds the proposed change acceptable.
1.13 Handling, Storage, and Shipping In Section 13, Handling, Storage, and Shipping, of QATR TP-QA-PD-0001, Revision 14, TerraPower made no changes to the QATR, which was previously accepted by the NRC staff, related to handling, storage, and shipping controls.
1.14 Inspection, Test, and Operating Status In Section 14, Inspection, Test, and Operating Status, of QATR TP-QA-PD-0001, Revision 14, TerraPower made no changes to the QATR, which was previously accepted by the NRC staff, related to inspection, test, and operating status.
1.15 Nonconforming Materials, Parts, or Components In Section 15, Control of Nonconforming Items, of QATR TP-QA-PD-0001, Revision 14, TerraPower made no changes to the QATR, which was previously accepted by the NRC staff, related to nonconforming materials, parts, or components.
1.16 Corrective Action In Section 16, Corrective Action, of QATR TP-QA-PD-0001, Revision 14, TerraPower made no changes to the QATR, which was previously accepted by the NRC staff, related to corrective action.
1.17 Quality Assurance Records In Section 17, Quality Assurance (QA) Records, of QATR TP-QA-PD-0001, Revision 14, TerraPower made no changes to the QATR, which was previously accepted by the NRC staff, related to quality assurance records.
1.18 Audits In Section 18, Audits, of QATR TP-QA-PD-0001, Revision 14, TerraPower made no changes to the QATR, which was previously accepted by the NRC staff, related to audits.
CONCLUSION The NRC staff has completed its review of TerraPowers QATR TP-QA-PD-0001, Revisions 13 and 14. The QATR continues to adequately describe how the requirements of Appendix B to 10 CFR Part 50 will be implemented. Based on its evaluation of the QATR TP-QA-PD-0001, Revision 14 submittal, the NRC staff concludes that the QA program described in QATR TP-QA-PD-0001 satisfies the Commissions requirements for QA programs as established by Appendix B to 10 CFR Part 50.
Project Manager: Mallecia A. Sutton Principal Contributor(s): Yamir C. Diaz-Castillo Greg S. Galletti