ML24352A092

Memo - Summary of November 15, 2024, Meeting with TRISO-X, LLC for Supplemental Information for RAIs Regarding Chapter Two of the License Application

ML24352A092
Person / Time
Site:	Triso-X
Issue date:	12/20/2024
From:	Matt Bartlett NRC/NMSS/DFM/FFLB
To:	James Downs NRC/NMSS/DFM/FFLB
Shared Package
ML24352A091	List: ML24352A092 ML24352A093
References
EPID L-2022-NEW-0005
Download: ML24352A092 (1)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 20, 2024 MEMORANDUM TO:

James Downs, Acting 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 NOVEMBER 15, 2024, MEETING WITH TRISO-X, LLC TO DISCUSS SUPPLEMENTAL INFORMATION FOR REQUESTS FOR ADDITIONAL INFORMATION REGARDING CHAPTER TWO OF THE LICENSE APPLICATION (ENTERPRISE PROJECT IDENTIFIER L-2022-NEW-0005)

The U.S. Nuclear Regulatory Commission (NRC) staff held a meeting with a representative from TRISO-X, LLC (TRISO-X) on November 15, 2024. The purpose of the meeting was to discuss supplemental information to resolve requests for additional information (RAIs) regarding chapter-2 of the license application (LA). The RAIs were issued on July 27, 2023, (Agencywide Documents Access and Management System [ADAMS] Accession No. ML23198A257) and the responses were received August 25, 2023 (ML23237B484).

The NRC staff informed TRISO-X that the responses for RAIs 1, 3, 5, 7, and 8 required supplemental information via letter dated May 8, 2024 (ML24089A200). In preparation for the meeting on November 15, 2024, the NRC staff provided several slides to inform the discussions on the supplemental response needed for each RAI.

Discussion on RAI 1, Management Hierarchy The NRC staff identified that a range of terms are used for manager positions throughout chapter 2 of the LA. The organization of the major management positions are listed as discipline and function leads in the LA on figure 2-1, Functional Organization Chart. During the discussions, TRISO-X clarified that the positions listed in the first line below the Plant Manager are the four major disciplines of the facility, each overseen by an assigned manager. All the boxes below these four disciplines are functional areas of the facility, which will also be led by a functional manager. TRISO-X indicated they would consider how to distinguish between the disciplines and the functions on the chart.

CONTACT: Matthew Bartlett, NMSS/DFM 301-415-7154 Signed by Bartlett, Matthew on 12/20/24

J. Downs 2

They also agreed to refine the description of the various management positions throughout chapter 2 to make them more consistent and ensure they align with figure 2.1. The NRC staff also requested that TRISO-X clarify whether the disciplines and functions will have an assigned manager to oversee each organizational group. TRISO-X pointed out that multiple functions may be led by the same manager. The NRC staff agreed this was acceptable, provided the responsibilities and qualifications for each position is met.

Discussion on RAI 3 and 5, Role of Regulatory Affairs on the Screening Committee The NRC staff asked TRISO-X to clarify the manager positions that would be represented on the safety committee. TRISO-X stated that five individuals will serve on the safety committee as represented by the darkened boxes in figure 2.1. This includes the two discipline managers from manufacturing and engineering; the regulatory affairs manager or designee; and the manager of the Safety and Regulatory function and the Safeguards function. The NRC staff asked TRISO-X to clarify in the text that these five individuals would serve on the safety committee. The NRC staff also pointed out that the training requirements for the safety committee need to be clarified.

TRISO-X indicated the safety committee would have training on their responsibilities in the committee.

Discussion on RAI-7 Experience for the Manufacturing Function, etc.

The NRC staff pointed out that the qualification requirements for the various discipline managers and function managers needs to be clarified. As currently written, the qualification requirements appear to apply to all members of the discipline or functions. TRISO-X agreed the language would be updated. They intend that all members of a discipline or function will be appropriately trained for their specific roles, but the qualifications described in chapter 2 of the LA only apply to the individual managers of the disciplines and functions. TRISO-X also pointed out that some specific technical positions have training requirements. The NRC staff stated that business experience should not be used in place of nuclear experience, without some additional support from individuals with nuclear experience. The NRC staff indicated that those criteria need to be described in the LA. The TRISO-X staff agreed and clarified that business experience would only be used as a substitute for other experience when appropriate (e.g.,

management experience).

Discussion on RAI-8 Transition to Operations The NRC staff pointed out that TRISO-X needs to demonstrate that the construction of safety related systems will have appropriate oversight from the regulatory affairs discipline. TRISO-X agreed and pointed out that several revisions to the LA were submitted in response to the RAI for the management measures and quality assurance program.

At the conclusion of the meeting, the NRC and TRISO-X staff agreed that the supplemental information to the RAIs would be incorporated into the revised LA to be submitted in December 2024. The NRC staff considers that the supplements agreed during the call should be sufficient to resolve these RAI, provided the issues are incorporated in the revised LA, as agreed.

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The meeting participants include the following individuals:

NRC Staff TRISO-X Staff Matt Bartlett, Senior Licensing Project Manager Jennifer Wheeler, Vice President of Regulatory Affairs James Downs, Acting Branch Chief, Fuel Facility Licensing Branch Docket No.: 07007027

Enclosures:

1. NRC Slides

ML24352A091(pkg), ML24352A092(memo), ML24352A093(encl)

OFFICE NMSS/DFM/FFLB NMSS/DFM/FFLB NMSS/DFM/FFLB NMSS/DFM/FFLB NAME MBartlett JGoodridge JDowns MBartlett DATE 12/19/2024 12/20/2024 12/20/2024 12/20/2024