ML24254A409

Memo - Summary of Meeting on August 28, 2024, with TRISO-X, LLC to Align on the Supplement Responses to the Management Measures and Quality Assurance Requests for Additional Information (Public)

ML24254A409
Person / Time
Site:	Triso-X
Issue date:	10/08/2024
From:	Stephen Poy NRC/NMSS/DFM/FFLB
To:	Lav S NRC/NMSS/DFM/FFLB
Shared Package
ML24254A408	List: ML24254A409 ML24254A410
References
EPID L-2022-PMP-0005
Download: ML24254A409 (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:

Stephen Poy, Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards

SUMMARY

OF MEETING ON AUGUST 28, 2024, WITH TRISO-X, LLC, TO ALIGN ON THE SUPPLEMENT RESPONSES TO THE MANAGEMENT MEASURES AND QUALITY ASSURANCE REQUESTS FOR ADDITIONAL INFORMATION, (ENTERPRISE PROJECT IDENTIFIER L-2022-PMP-0005)

The U.S. Nuclear Regulatory Commission (NRC) staff conducted a closed Microsoft Teams meeting with TRISO-X, LLC (TRISO-X) on August 28, 2024, from 2:00 p.m. until 4:00 p.m. to discuss their management measures and quality assurance (MM/QA) program. The purpose of the meeting was to align on TRISO-Xs development of a supplement to support the response to requests for additional information (RAIs) that were submitted via letter dated July 28, 2023 (Agencywide Documents Access and Management System Accession No. ML23209A821). The TRISO-X original application was received April 5, 2022 (ML22101A200 - package) and was supplemented by letters dated October 13, 2022 (ML22286A144 - package), November 4, 2022 (ML22308A251 - package), and February 29, 2024 (ML24060A239).

The NRC staff has held a number of meetings with TRISO-X to discuss the supplemental information needed to resolve the RAIs including May 17, 2023 (ML24053A029), December 18, 2023 (ML24002A825), January 25, 2024 (ML24066A181 - package), June 17, 2024 (ML24198A233 - package), and July 17, 2024 (ML24228A125 - package). This meeting continues these discussions, as summarized below.

CONTACT: Matt Bartlett, NMSS/DFM 301-415-7154 October 8, 2024 Signed by Poy, Stephen on 10/08/24

S. Lav 2

The meeting involved additional discussion on the following open management measures (MM)

RAIs:

RAI 1 Construction Qualifications, RAI 1 Quality Standards for Items Relied on for Safety (IROFS), and RAI 1 Quality Assurance Elements for IROFS.

The NRC staff provided a list of issues to help resolve the RAIs.

To resolve MM/QA methodology RAI-1, Construction Qualifications, TRISO-X should revise the proposed response to section 2.6 entitled, Transition from Design and Construction to Operations, of the License Application (LA) to provide additional information on the construction of IROFS to ensure they receive appropriate quality assurance during construction. Although this additional information wont fully resolve the NRC staffs RAI, it would provide sufficient information for the NRC staff to close out the methodology RAI and move forward to development of detailed technical RAIs.

TRISO-X added the language, and at least one year of relevant experience related to applicable technical discipline, scope, and complexity of the construction oversight assignment to LA Section 2.6. The NRC staff reiterated that some positions may require additional training, qualifications, or experience to engage in the proposed activities. The NRC staff indicated that additional RAIs on specific positions could be requested during the detailed review.

With regards to MM/QA methodology RAI-2, Quality Standards for IROFS, the following additional information is needed:

If TRISO-X is using or meeting a specific quality code and standard (e.g., ISO 9001:2015) to meet regulatory requirements for management measures, they should commit to meeting the standard. TRISO-Xs LA says that their program is based on ISO 9001 but they do not commit to meeting it. If TRISO-X intends to use ISO 9001 to support their quality assurance program, they should revise their LA to include a statement that their QA program is committed to ISO 9001:2015 with additional supplementary information provided in the implementation documents.

The LA does not currently identify industry consensus codes and standards as part of the process safety information or commitments for specific IROFS. If codes and standards are used as part of the process safety information or are a feature of an IROFS, TRISO-X needs to identify those codes and standards.

The NRC staff noted that the draft supplementary RAI response indicates TRISO-X may use certain codes and standards, which is not an adequate commitment to resolve the RAI.

TRISO-X indicated that they intend to update and add additional codes and standards to the list in the ISA Summary Section 4.5. TRISO-X staff also indicated they do not currently have a complete list of information on the codes and standards that will be applied to each IROFS.

They plan to place additional IROFS information in the facility design packages, which are equivalent to the IROFS boundary packages described in NUREG 1520, Revision 2. The NRC staff requested TRISO-X state in the final supplement their plans for documenting the codes in the design packages, which would provide the information necessary for the NRC staff to close out this methodology RAI and move forward with the detailed review.

S. Lav 3

With regards to methodology RAI-4, Quality Assurance Elements for IROFS, TRISO-X stated they will remove references to a graded approach to quality for all IROFS and clarify that all IROFS will be designed and constructed to the same highest-level of importance to safety quality standards. TRISO-X indicated it would remove all references to a graded approach, and indicated they would clean up the introductory paragraph in LA Section 11.8, Other Quality Assurance Elements for IROFS, to state the same level of management measures are uniformly and consistently applied to IROFS irrespective of whether they are needed to prevent or mitigate high consequence events. The NRC staff indicated that this issue appears moving toward resolution.

The NRC and TRISO-X staff agreed that a revised supplemental response with the information discussed would provide enough information to allow the NRC staff to close out the methodology RAIs for MM/QA and move forward with a detailed review and development of technical RAIs. The detailed review will include more specific questions to address any remaining information needs from the methodology RAIs. The parties agreed the RAI supplement would be due September 6, 2024.

A list of participants is provided as an Enclosure.

Docket No. 07007027

Enclosure:

Participant List (public) cc: trisox@listmgr.nrc.gov

ML24254A408(pkg), ML24254A409(memo),

ML24254A410(encl)

OFFICE NMSS/DFM/FFLB NMSS/DFM/FFLB NMSS/DFM/FFLB NMSS/DFM/FFLB NAME SPoy JRudd SPoy MBartlett DATE 9/11/2024 9/12/2024 9/12/2024 9/17/2024 OFFICE NMSS/DFM/FFLB NMSS/DFM/FFLB NMSS/DFM/FFLB NMSS/DFM/FFLB NAME JGoodridge JDowns for SLav MBartlett SPoy DATE 9/17/2024 10/7/2024 10/8/2024 10/8/2024