ML24198A235

Memorandum - Summary of Meeting Held on June 17 2024 with TRISO-X to Align on NRC Supplement Responses to Management Measures Requests for Additional Information

ML24198A235
Person / Time
Site:	Triso-X
Issue date:	08/26/2024
From:	Matt Bartlett NRC/NMSS/DFM/FFLB
To:	Lav S NRC/NMSS/DFM/FFLB
Shared Package
ML24198A233	List: ML24198A234 ML24198A235
References
EPID L-2022-PMP-0005
Download: ML24198A235 (1)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 MEMORANDUM TO: Samantha Lav, Chief Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards FROM: Matthew Bartlett, Sr. Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards

SUMMARY

OF MEETING ON JUNE 17, 2024, WITH TRISO-X LLC, TO ALIGN ON NRC SUPPLEMENTAL RESPONSES TO MANAGEMENT MEASURES REQUESTS FOR ADDITIONAL INFORMATION, (ENTERPRISE PROJECT IDENTIFIER L-2022-PMP-0005)

The U.S. Nuclear Regulatory Commission (NRC) staff hosted additional discussions in a closed Microsoft Teams meeting with TRISO-X, LLC (TRISO-X) on June 17, 2024, from 1:30 p.m. to 3:00 p.m. The purpose of the meeting was a routine technical call to align on TRISO-Xs draft responses to the need to supplement the TRISO-X responses to the management measures and quality assurance (MM/QA) requests for additional information (RAIs) submitted via letter dated March 13, 2024 (Agencywide Documents Access and Management System Accession No. ML24002A825). The TRISO-X original application was received April 5, 2022 (ML22101A200) and was supplemented by letters dated October 13, 2022 (ML22286A144),

November 4, 2022 (ML22308A251) and February 29, 2024 (ML24060A239).

The NRC staff has held two meetings with TRISO-X to discuss the supplemental information needed to resolve the MM/QA RAIs including on December 18, 2023 (ML24002A825), and January 25, 2024 (ML24066A181). This meeting continues these discussions, as summarized below.

CONTACT: Joseph Rudd, NMSS/DFM 301-415-5039August 26, 2024 Signed by Bartlett, Matthew on 08/26/24

S. Lav 2

The NRC staff discussed the draft supplements and informed TRISO-X that the minor revision they incorporated into the previous RAI responses needs to be expanded. TRISO-X stated that the regulations do not require them to submit a quality assurance program for NRC approval.

Although the NRC staff agrees that facilities licensed under Title 10 of the Code of Federal Regulations (10 CFR) Part 70 are not required to comply with quality assurance in 10 CFR Part 50, Appendix B, the Part 70 regulations do require appropriate quality assurance applied to safety systems (e.g., item(s) relied-on for safety [IROFS] and management measures) see NUREG-1520, Rev. 2 Section 11.4.1, Regulatory Requirements (ML15176A258). The NRC staff pointed out that the current application and proposed updates do not provide commitments to quality assurance codes. Instead, they use flexible terms like may and consistent with for use of codes. In addition, TRISO-X needs to provide the following: clarify if they plan to use a graded approach for applying management measures to IROFS; a description of the quality assurance for construction; commitments to the experience and qualifications for quality assurance managers, information on the quality assurance program for procurement of items related to IROFS and management measures; and a commitment to a program to retain and maintain records.

TRISO-X stated that most of the examples the NRC staff has provided of acceptable assurance programs apply to reactors. The NRC reiterated the recommendation to look at International Atomic Energy Agency standards on quality assurance that apply to all nuclear facilities, Regulatory Guide 7.10, Establishing Quality Assurance Programs For Packaging Used In Transport Of Radioactive Material and NUREG/CR-6407, Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety. Although these and other reactor guidance on QA programs do not apply directly to fuel cycle facilities, the NRC staff indicated that TRISO-X could draw language from them to inform their QA program.

The NRC staff emphasized the need to provide sufficient description of their quality assurance program for the NRC staff to have reasonable assurance of adequate protection, consistent with the regulations in 10 CFR Part 70. The high-level concept description currently provided in the license application and supplements is not sufficient for the NRC to proceed with a detailed review.

The NRC staff and TRISO-X agreed to take an additional several days to evaluate how to better communicate the information needed. TRISO-X also agreed to consider if they can provide some additional detail in their proposed supplement. A follow-up management measures meeting will be considered in the coming weeks.

A list of participants is provided as an enclosure.

Docket No. 07007027

Enclosure:

Participant List (public)

cc: trisox@listmgr.nrc.gov

ML24198A233; Memo ML24198A235

• via email OFFICE NMSS NMSS/DFM/FFLB NMSS/DFM/FFLB NMSS/DFM/FFLB*

NAME JRudd JR SPoy SPMBartlett MB SLav SL DATE Jul 17, 2024 Jul 19, 2024 Aug 22, 2024 Aug 26, 2024 OFFICE NMSS/DFM/FFLB NAME MBartlett MB DATE Aug 26, 2024