ML25057A462

Memo - Summary of Meeting Held on January 16, 2025, with Triso-X LLC, to Discuss Draft Requests for Additional Information on Electrical and Instrumentation and Control

ML25057A462
Person / Time
Site:	Triso-X
Issue date:	03/10/2025
From:	Matt Bartlett NRC/NMSS/DFM/FFLB
To:	Lav S NRC/NMSS/DFM/FFLB
References
EPID L-2022-PMP-0005
Download: ML25057A462 (1)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 10, 2025 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 HELD ON JANUARY 16, 2025, WITH TRISO-X, LLC, TO DISCUSS DRAFT REQUESTS FOR ADDITIONAL INFORMATION ON ELECTRICAL AND DIGITAL INSTRUMENTATION AND CONTROL (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 January 16, 2025, from 2:00 p.m. until 2:30 p.m. to discuss draft requests for additional information (RAIs) to ensure a mutual understanding of the issues and identify revisions for clarity. Thirteen of the fifteen draft RAIs were discussed.

TRISO-X made a global comment that the RAIs were unclear on if the information needed to be added to the license application (LA) or the Integrated Safety Analysis (ISA) Summary. The NRC staff said that in many cases the information could be added to the ISA Summary, but if the information was a commitment, it needed to be included in the LA documents, which get tied down in the license. The NRC staff agreed to clarify this in the RAIs.

TRISO-X asked if the NRC staff could include a reference to the guidance for Digital Instrumentation and Control Interim Staff Guidance (ISG)-07, Digital Instrumentation and Control Systems in Safety Applications at Fuel Cycle Facilities, December 1, 2010. The NRC staff agreed this could be included. TRISO-X also pointed out that Regulatory Guide 1.152, Revision 3, Criteria for Use of Computers in Safety Systems of Nuclear Power Plants, is designed for power plants. The NRC staff agreed but pointed out that the principles could be applied to fuel cycle facilities.

CONTACT: Matthew Bartlett, NMSS/DFM 301-415-7154 Signed by Bartlett, Matthew on 03/10/25

S. Lav 2

TRISO-X noted that several of the RAIs request additional information on the codes and standards. They pointed out that a list of applicable standards is already provided in the LA. The NRC staff pointed out that the list is general, and TRISO-X needs to clarify which sections of the standards are applied to the different aspects of their program. The NRC pointed out that if TRISO-X retains a general list without an indication of how or where the codes and standards are applied, the implication is that all the referenced codes and standards apply throughout the entire facility. The NRC staff asked TRISO-X to clarify if this is their intention. TRISO-X agreed to consider the issue further, but pointed out the details of implementation are in the design packages and are not required to be included in the LA or the ISA Summary. The NRC staff is looking for TRISO-X to identify the codes and standards they plan to use and describe how the codes and standards are implemented into their programs, processes, and maintenance (e.g.,

testing, corrective), to demonstrate compliance with Title 10 of the Code of Federal Regulations 70.62(d). TRISO-X asked if they could point to commitments to LA chapter 11 on the management measures program. The NRC staff agreed that would be appropriate.

The TRISO-X staff pointed out that some of the RAIs appeared to be asking about systems required for life safety, which is not required to be included in the ISA Summary. The NRC staff pointed out that items used for life safety can impact the availability and reliability of items relied on for safety (IROFS). TRISO-X indicated that the fire hazards analysis includes much of the information requested by the NRC staff. The NRC staff agreed to look at this document to inform the revisions to the RAIs.

TRISO-X stated that some of the RAIs appeared to be asking for a detailed description of information that is in the ISA, which is maintained on site. The NRC staff clarified they need the information to understand the ISA methodology and strategy. The staff will review the detailed implementation of IROFS and management measures during the horizontal and vertical slice assessment. The TRISO-X staff agreed. For example, TRISO-X asked if they needed to provide a detailed block diagram of the safety instrumented system. The NRC staff clarified a high-level, overview diagram would be sufficient.

The TRISO-X staff stated that following the meeting, they would email a list of the cross references support the electrical and instrumentation and control review. They proposed this could be followed by a second meeting to discuss the list and review the last three RAIs which were not discussed during this meeting. The NRC staff agreed. TRISO-X indicated the follow-up call would likely need to take place in early February 2025, after submittal of their revised ISA Summary, which is due to the NRC by the end of January 2025.

S. Lav 3

Attendees:

NRC TRISO-X Stephen Poy, Licensing Project Manager Jennifer Wheeler, Vice President of Regulatory Affairs David Rahn, Sr. Electrical and Instrumentation and Control Reviewer Robert Maurer, ISA Team Lead Ming Li, Electrical and Instrumentation and Control Reviewer Burns Cunningham, Licensing Engineer Cynthia Taylor, Sr. Project Inspector Matt Bartlett, Sr. Licensing Project Manager Docket No. 07007027

ML25057A462