ML25148A401
| ML25148A401 | |
| Person / Time | |
|---|---|
| Site: | Triso-X |
| Issue date: | 05/28/2025 |
| From: | Triso-X |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML25148A399 | List: |
| References | |
| TXO-REG-LTR-0071 | |
| Download: ML25148A401 (1) | |
Text
TX0-REG-LTR-0071 Enclosure - Set 13 License Chapter 1 and 2 RAI Responses Page 1 of 11 Chapter 1 RAI-1 Process
Description:
Regulatory Basis:
This information is necessary to demonstrate compliance with the regulations in the following sections:
10 CFR 70.22(a)(2), The activity for which the special nuclear material is requested, or in which special nuclear material will be produced, the place at which the activity is to be performed and the general plan for carrying out the activity; 10 CFR 70.22(a)(4) The name, amount, and specifications (including the chemical and physical form and, where applicable, isotopic content) of the SNM the applicant proposes to use or produce; and 10 CFR 70.65, Additional content of applications, subsection (b)(2-4), which also requires a description of the process with sufficient detail to understand the overall function.
Guidance on demonstrating compliance with this regulation is provided in NUREG-1520, Revision 2, Section 1.1.4.3.2 which states, The process overview is acceptable if it summarizes the major chemical or mechanical processes involving licensable quantities of radioactive material based, in part, on information presented in the ISA summary. This description should include the building locations of major process components and brief accounts of the process steps.
Describe Issue:
The process description in the license application LA Section 1.1.3, General Process Description mentions the DUNE process, but does not provide information on what it includes. The DUNE process is described in the ISA Summary Figure 3.1, TRISOX FFF Process Flow Diagram, and section 3.1, Incoming Feed Shipping and Transportation, in more detail. Its also described in the Emergency Plan Section 1.1.1.1, ADUN SNM Receipt, as part of ADUN process. In addition, the text description in the Receipt of Uranium Feedstock on LA Chapter 1 page 1-13 says the material arrives on site as uranium oxide (U3O8) but does not mention receipt of uranyl nitrate for TX-1 or include a description of the DUNE process. The description of receipt of both uranyl nitrate and U3O8 feedstock and the DUNE process needs to be consistent in the LA, ISA Summary, and Emergency plan to provide a clear understanding of how it fits in the overall fuel fabrication process.
Information Needed:
Update the descriptions of the receipt of uranyl nitrate and the DUNE process consistently throughout the license application (LA) documents (e.g., LA Section 1.1.3 and ISA Summary Section 3.1, Emergency Plan Section 1.1.1.1) in addition to the description of the U3O8 feedstock.
Ensure the LA, ISA Summary, Emergency Plan, etc. contain a consistent description of both types of feedstocks.
TRISO-X Response to RAI-1:
License Sections 1.1.3, 1.1.4, and 1.2.5 will be revised to provide a clear and consistent description of both types of uranium feedstocks. The ISA Summary, Emergency Plan, and FNMCP were reviewed and the descriptions are aligned with some intended differences based on the purpose of the information being communicated within each document. Additionally, the reference to high assay low enriched uranium will be deleted from Section 1.1.3 to remove information that is redundant with enriched to less than 20 weight percent U-235 in the same sentence.
TX0-REG-LTR-0071 Enclosure - Set 13 License Chapter 1 and 2 RAI Responses Page 2 of 11 License Changes:
1.1.3 General Process Description TRISO-X FFF manufacturing operations consist of receiving high assay low enriched uranium (HALEU) in the form of uranium oxide powder and liquid uranyl nitrate enriched to less than 20 weight percent U-235; converting uranyl nitrate into oxide; converting the oxide into a uranyl nitrate solution, into gel spheres, and then into fuel kernels; and processing the fuel kernels through coating, overcoating, fuel form pressing, and carbonization.
Third and fourth paragraphs:
Receipt of Uranium Oxide Feedstock (TX-1 and TX-2) - Incoming U3O8 feedstock enriched to less than 20 weight percent 235U arrives by truck in approved containers licensed by the NRC. Shipping packages are unloaded from the delivery truck and moved to a secure storage location inside the process buildings. Receipt measurements for Material Control and Accounting are performed, and the feedstock is transferred into portable containers and stored until ready for use in the Dissolution process.
Receipt of Liquid Uranyl Nitrate SolutionFeedstock (TX-1 only) - Incoming liquid uranyl nitrate feedstock enriched to less than 20 weight percent arrives by truck in approved containers licensed by the NRC or DOE. Shipping packages containing liquid uranyl nitrate remain on the delivery trailer while the feedstock solution is transferred through a hose to a storage tank located inside the TX-1 process building. Receipt measurements for Material Control and Accounting are performed.,
and the liquid Liquid uranyl nitrate is transferred from a storage tank to the Dilute Uranyl Nitrate Evaporation (DUNE) process where it is converted to U3O8 powder using an evaporator and a calciner. U3O8 powder from the calciner output is transferred to portable containers. by the Dilute Uranyl Nitrate Evaporation (DUNE) process The U3O8 powder is then either sent to storage or directly to the for use in the Dissolution process.
1.1.4 Raw Materials, Products, By-Products and Wastes
- 1. The uranium feed material for the TRISO-X FFF is liquid uranyl nitrate (TX-1 only) and uranium oxide powder (TX-1 and TX-2).
1.2.
The manufacturing, recovery, support, and waste packaging activities are supported by a number of non-radiological chemical materials stored in bulk quantities, as listed in the NRC-required Emergency Plan and ISA Summary.
2.3.
Finished products containing licensed material include coated particles and final fuel forms in various shapes and configurations.
3.4.
There are no byproducts as defined by 10 Code of Federal Regulations (CFR) 30.4 extracted or converted after extraction from the TRISO-X FFF for use in a commercial, medical, or research activity.
4.5.
Uranium is recovered from non-conforming product materials, process solutions, and scrap materials by processing it into a form that is suitable for use as feedstock in the manufacturing process.
5.6.
Process solutions contaminated with uranium that cannot be recovered/recycled are identified as liquid wastes. Liquid wastes are collected and sampled to determine appropriate handling/treatment steps. Treatment typically involves adjustment of pH, filtering, ion exchange, and/or precipitation. Precipitates are de-watered, and the solids are packaged for off-site disposal. If needed, liquid wastes that have been
TX0-REG-LTR-0071 Enclosure - Set 13 License Chapter 1 and 2 RAI Responses Page 3 of 11 handled/treated can be sampled and discharged through an inline monitor to shipping packages for off-site disposal. Used oils may also be sampled and containerized for shipment to a licensed disposal facility.
6.7.
Airborne effluents are discharged to the atmosphere via a number of process stacks. HEPA filtration and scrubber systems are used where needed to remove radioactive particulates and chemicals from airborne effluents to assure compliance with 10 CFR 20 and applicable State of Tennessee regulations prior to discharge to the atmosphere. See Chapters 4 and 9 for programmatic information for managing and monitoring radioactive airborne effluent discharges.
7.8.
Wastewater from systems and equipment in non-radiological mechanical equipment areas of the facility and sanitary wastes from bathrooms and showers are discharged through piping which goes to the City of Oak Ridge publicly owned treatment works (POTW). The City of Oak Ridge process for permitting discharges to the POTW will define monitoring requirements to assess potential contaminants in sanitary waste streams.
No uranium will be present in this wastewater stream.
8.9.
Solid waste materials include, but are not limited to, damaged and/or obsolete equipment, used ventilation filters and personal protective equipment, processing and waste treatment residues, and miscellaneous combustible wastes. Materials could be radiologically contaminated, non-contaminated, hazardous, or mixed (hazardous and radioactive). Solid waste materials are processed, recycled, and/or containerized for shipment to a licensed disposal facility.
1.2.5 Authorized Uses and Activities This license authorizes the use of SNM for operations involving enriched uranium pursuant to 10 CFR Part 70 as listed in this section. This also includes the support activities related to the manufacture of SNM-containing products.
- 1. Manufacturing Operations
- a. Fuel Manufacturing - Conversion of uranium oxides to uranyl nitrate solutions, conversion of uranyl nitrates to uranium oxides, and fabrication of coated particles and final fuel forms containing uranium.
Observation:
Observation 1 - Kernel Conversion:
The ISA Section 3.4, Kernel Conversion states, The dried microspheres are converted in a high temperature furnace to fuel kernels of uranium compounds, such as uranium dioxide (UO2) and uranium dicarbide (UCO) Clarify if UCO should be uranium dicarbide or uranium oxycarbide.
Observation 2 - Equivalent Experience:
LA Section 1.2.7, Terminology/Definitions under the term Equivalent Experience the definition states, For the purpose of meeting educational requirements described throughout the license, two (2) years experience is considered to be equivalent to one (1) year of postsecondary education. For example, eight (8) years of applicable experience will satisfy the requirement for a B.S. degree (4 years of post-secondary education). Please add the word applicable in front of the word experience in the first part of the definitions, similar to the language in the example.
TX0-REG-LTR-0071 Enclosure - Set 13 License Chapter 1 and 2 RAI Responses Page 4 of 11 TRISO-X Response to Observation:
Observation 1: ISA Summary Section 3.4, Kernel Conversion, and License Chapter 1, Section 1.1.3, Kernel Conversion, will be updated as follows.
The dried microspheres are converted in a high temperature furnace to fuel kernels of uranium compounds based on the fuel design being fabricated. The uranium compounds are, such as uranium dioxide (UO2) and sub-stoichiometric uranium dicarbide (UCOUC2-x),
which together are referred to as uranium oxycarbide (UCO).based on the fuel design being fabricated.
Observation 2: License Chapter 1, Section 1.2.7, Equivalent Experience, will be updated as follows.
For the purpose of meeting educational requirements described throughout the license, two (2) years applicable experience is considered to be equivalent to one (1) year of postsecondary education. For example, eight (8) years of applicable experience will satisfy the requirement for a B.S. degree (4 years of post-secondary education).
TX0-REG-LTR-0071 Enclosure - Set 13 License Chapter 1 and 2 RAI Responses Page 5 of 11 Chapter 2 RAI-1 Qualifications Regulatory Basis:
The information below is necessary to demonstrate compliance with the regulations in 10 CFR 70.22, Contents of applications, sub-section (a)(6), The technical qualifications, including training and experience of the applicant and members of his staff to engage in the proposed activities in accordance with the regulations in this chapter.
Guidance for demonstrating compliance with these regulations is provided in NUREG-1520, Revision 2, Section 2.3, Areas of Review which states in part, The applicant should also describe its qualification criteria with regard to education (i.e., degree and field), training, and experience for key management positions. Management positions for which such criteria should be described include the facility manager, operations manager, shift supervisor, and managers for various safety and environmental disciplines. Alternative named management positions could be proposed. Qualification criteria should be described generally, in terms of academic credentials, formal continuing education, and work experience. For example, bachelors degree in nuclear engineering or related scientific or engineering field, with 5 years of experience managing the operations of a nuclear fuel manufacturing facility.
In addition, NUREG-1520, Revision 2, Section 2.4.3 Regulatory Acceptance Criterion, A.1, states, The applicant has identified and functionally described the specific organizational groups that are responsible for managing the design, construction, operations, and modifications of the facility or licensed activities. The application also includes organizational charts.
Describe Issue:
The qualifications discussed in the last paragraph of LA Section 2.3.4 for the regulatory affairs manager states, The minimum qualifications for a Regulatory Affairs discipline manager are a BS/BA or advanced degree (masters or doctorate) in science or engineering and at least five years of management experience in the nuclear industry, a nuclear related field, and/or in assignments involving regulatory activities [emphasis added].
The use of the and/or (i.e., or) in the last part of the sentence means that 5 years of experience in the nuclear industry or nuclear-related field can be replaced with any experience in other regulatory activities. In addition, several of the qualifications throughout section 2.3, Organizational Responsibilities, Authority, and Qualifications use the phrase, or other highly regulated field. These statements are not clear because regulatory activities and other highly regulated fields are general terms that could include any local, state, or federal regulated activity that may include a host of activities (e.g., fishing, farming, driving, etc.), which would not be relevant to the corresponding management positions.
Information Needed:
Update the qualification sections throughout the license application documents (e.g., 2.3) to clarify the scope or processes used to ensure that experience in other regulatory activities or other highly regulated fields can be used as an adequate substitute for the required technical experience (e.g., nuclear experience). For example:
describe the process, program, or individuals that will be used to ensure the substituted experience is adequate (e.g., substituted experience is reviewed and approved through XXX [describe the process, program, or individual]);
consider stating the type of regulatory activities or highly regulated industry fields that are considered equivalent for each of the applicable technical areas (e.g., describe what equivalent experience can be used in place of nuclear experience); or
TX0-REG-LTR-0071 Enclosure - Set 13 License Chapter 1 and 2 RAI Responses Page 6 of 11 replace the phrases regulated activities and other highly regulated fields with language similar to NUREG-1520, Revision 2, Section 2.3, Areas of Review, in the last sentence of the third paragraph which states in part, or related scientific or engineering field; Note: this type of language is used for some of the existing functions in the LA (e.g.,
manufacturing).
TRISO-X Response to RAI-1:
To address example bullet 1, License Chapter 2, Section 2.3, paragraph 3, will be updated to clarify that management is involved in confirming that education and experience substitutions are adequate for the role assigned.
To address example bullets 2 and 3, the minimum qualifications portions of License Chapter 2, Section 2.3 and subsections, will be standardized to relevant non-nuclear experience to align more directly with Section 2.3, paragraph 3.
Additionally, the phrase that includes sufficient background will be deleted from Sections 2.3.2 and 2.3.3 to remove information that is redundant with content in Section 2.3, paragraph 3, that applies to all subsections.
License Changes:
License Chapter 2, Section 2.3, paragraph 3 The positions described in this section are intended to describe the license-related responsibilities and do not reflect actual job titles. The responsibilities of the positions described may be fulfilled by one or more different organizational positions as long as the minimum position qualifications specified in this chapter are met for functional area(s) he/she is responsible to oversee. Similarly, functional areas shown in Figure 2-1 and described in Sections 2.3.2, 2.2.3, 2.3.4, and 2.3.5 of this chapter may be grouped within their disciplines as needed to support the TRISO-X organization as long as the individual(s) responsible for the function(s) have a sufficient background to provide the capability for making sound safety and/or regulatory decisions. A combination of education and experience may be substituted for minimum qualifications described in this chapter if management determines that other factors provide sufficient demonstration of the ability to fulfill the duties of a position. When substituting experience for education, refer to the definition of Equivalent Experience in Section 1.2.7. When substituting type of work experience, two years of relevant non-nuclear experience is equivalent to one year of nuclear experience.
License Chapter 2, Section 2.3.2, paragraphs 2 and 3 The minimum qualifications for a Manufacturing discipline manager are a BS/BA or advanced degree (masters or doctorate) in science or engineering and at least five years of management experience in the nuclear industry, and/or a nuclear-related field; and a sufficient background in manufacturing-related activities to provide the capability for making sound safety decisions, or relevant non-nuclear manufacturing assignments.
The minimum qualifications for individual(s) responsible for oversight of manufacturing function(s) are a BS/BA or advanced degree (masters or doctorate) in science or engineering and at least three years of experience in the nuclear industry, and/or a nuclear-related field, or other relevant non-nuclear manufacturing assignments. He/she must have a sufficient background in manufacturing-related activities to provide the capability for making sound safety decisions.
TX0-REG-LTR-0071 Enclosure - Set 13 License Chapter 1 and 2 RAI Responses Page 7 of 11 License Chapter 2, Section 2.3.3, paragraphs 2 and 3 The minimum qualifications for an Engineering discipline manager are a BS or advanced degree (masters or doctorate) in engineering and at least five years of management experience in engineering-related activities, two years of which have been in the nuclear industry, and/or a nuclear-related field, and/or other highly regulated fieldrelevant non-nuclear engineering assignments. He/she must have a sufficient background in manufacturing-related activities to provide the capability for making sound safety decisions.
The minimum qualifications for individual(s) responsible for oversight of engineering function(s) are a BS/BA or advanced degree (masters or doctorate) in science or engineering and at least three years of experience in the nuclear industry, and/or a nuclear-related field, and/or other highly regulated fieldrelevant non-nuclear engineering assignments.
License Chapter 2, Section 2.3.4, paragraph 4 The minimum qualifications for a Regulatory Affairs discipline manager are a BS/BA or advanced degree (masters or doctorate) in science or engineering and at least five years of management experience in the nuclear industry, a nuclear-related field, and/or in assignments involving regulatory activities relevant non-nuclear regulatory assignments.
He/she must have appropriate understanding of the functional program(s) being managed.
License Chapter 2, Section 2.3.4.5, paragraph 2 The minimum qualifications for the individual responsible for oversight of the ISA function are a BS/BA or advanced degree (masters or doctorate) in science or engineering and at least three years of experience in licensing, regulatory compliance, safety, and/or safety analysis in the nuclear or another highly regulated industry, a nuclear-related field, and/or relevant non-nuclear regulatory assignments.
License Chapter 2, Section 2.3.4.6, paragraph 2 The minimum qualifications for the individual responsible for oversight of the licensing function are a BS/BA or advanced degree (masters or doctorate) in science or engineering and at least three years of experience in licensing, regulatory compliance, safety, and/or safety analysis in the nuclear or another highly regulated industry, a nuclear-related field, and/or relevant non-nuclear regulatory assignments.
License Chapter 2, Section 2.3.5, paragraph 2 The minimum qualifications for the Quality Assurance discipline manager are a BS/BA or advanced degree (masters or doctorate) in science or engineering and at least five years of experience in quality assurance-related activities in the nuclear or another highly regulated industry, a nuclear-related field, and/or relevant non-nuclear quality assurance assignments.
RAI-2 Construction Management Qualifications:
Regulatory Basis:
The regulatory basis for this RAI is the same as for RAI-1.
Describe Issue:
The qualification and experience requirements identified in LA section 2.6 in the third paragraph states, construction phase oversight of IROFS is provided by TRISO-X personnel within the
TX0-REG-LTR-0071 Enclosure - Set 13 License Chapter 1 and 2 RAI Responses Page 8 of 11 engineering, regulatory affairs, and quality assurance disciplines that meet the minimum requirements of a BS/BA and/or advanced degree, and at least one year of relevant experience applicable to the technical discipline, scope, and complexity of the construction oversight assignment.
The qualifications in LA section 2.6 for some positions (e.g., discipline and function managers) responsible for overseeing the construction activities appear to be lower than the qualifications requirements described in LA Chapter 2.3. TRISO-X clarified that the lower qualification requirements represent a minimum baseline that applies for TRISO-X oversight of the construction activities. Because the discipline and function managers qualifications described in LA Chapter 2.3 exceed the minimum qualifications for construction oversight described in LA Section 2.6, the requirements are not intended to be contradictory. The relationship between organizational manager qualifications in LA Section 2.3 and construction qualifications in LA Section 2.6 needs clarification.
Information Needed:
Provide additional information in the LA to clarify the relationship between the qualifications for key organizational positions described in LA Section 2.3 and the minimum qualifications for managers overseeing construction described in LA Section 2.6 to verify they are not contradictory.
Clarify in the LA which management positions (e.g., function managers, subordinate managers, any one providing oversight of construction) and under what conditions the qualification requirements in LA Section 2.6 are required (e.g., only during construction oversight).
Describe how different levels of qualifications requirements (e.g., LA 2.3 versus 2.6) for the same management positions are applied so that they do not conflict (e.g., more stringent qualifications take president, the level of qualifications in LA 2.6 are a minimum - so both can apply, lower qualifications apply to subordinates).
TRISO-X Response to RAI-2:
The minimum qualifications for TRISO-X personnel in Section 2.6 apply to individual contributors performing construction oversight activities. Another sentence will be added to clarify the minimum qualifications for management of Engineering, Regulatory Affairs, and Quality Assurance are the same as those included in Section 2.3.
License Changes:
License Chapter 2, Section 2.6, paragraph 3 Construction phase oversight of IROFS is provided by TRISOX personnel within the Engineering, Regulatory Affairs, and Quality Assurance disciplines that meet the minimum requirements of a BS/BA and/or advanced degree, and at least one year of relevant experience applicable to the technical discipline, scope, and complexity of the construction oversight assignment. When a construction management function is used, the same minimum qualifications apply. Management of the TRISO-X personnel involved in construction oversight activities is provided by individuals that meet the minimum qualifications in Section 2.3.3, 2.3.4, and 2.3.5.
TX0-REG-LTR-0071 Enclosure - Set 13 License Chapter 1 and 2 RAI Responses Page 9 of 11 RAI-3 Corrective Actions for Construction:
Regulatory Basis:
This RAI has the same regulatory basis as RAI 1.
Describe Issue:
The last sentence of the third paragraph in section 2.6 states, Issues or problems identified during construction of IROFS are referred to the incident investigations and corrective action program this statement indicates that only construction problems related to IROFS will be reported to a corrective actions program. Construction problems may also impact other safety, security, and environmental areas (e.g., safety programs, management measures, security programs, protection of the environment, etc.).
Information Needed:
Expand the scope of the commitment to apply to any construction problems that could have an impact on safety, security, and protection of the environment or explain the alternate program that will be used for non-IROFS construction issues that may have a regulatory nexus.
TRISO-X Response to RAI-3:
Construction problems that could have an impact on safety, security, and protection of the environment will also be entered in the corrective action program.
License Changes:
The last sentence of the third paragraph in Section 2.6 will be revised as shown below.
Issues or problems identified during construction of IROFS, or other issues that could have an impact on safety, security, and protection of the environment, are referred to the incident investigations and corrective action program as discussed further in Section 11.6.
RAI-4 Transition from Construction to Operations:
Regulatory Basis:
The information below is necessary to demonstrate compliance with the regulations in:
10 CFR 70.22(a)(6) The technical qualifications, including training and experience of the applicant and members of his staff to engage in the proposed activities in accordance with the regulations in this chapter; 10 CFR 70.22(a)(7) A description of equipment and facilities which will be used by the applicant to protect health and minimize danger to life or property; 10 CFR 70.22(a)(8) Proposed procedures to protect health and minimize danger to life or property; and Guidance on demonstrating compliance with this regulation is provided in NUREG-1520, Revision 2, Section 2.4.3 (4) which states, The applicant has described specific plans to commission the facilitys startup and operation, including the transition from the startup phase to operations, under the direct supervision of the applicants personnel responsible for safe operations. The application clearly describes the roles and responsibilities of the different functions engaged in these commissioning activities.
Describe Issue:
The last paragraph of LA Section 2.6 states, The turnover will include physical systems and corresponding design information and records. Following turnover, the manufacturing organization will be responsible for system maintenance and configuration control.
TX0-REG-LTR-0071 Enclosure - Set 13 License Chapter 1 and 2 RAI Responses Page 10 of 11 This turnover is not well defined and appears inconsistent with earlier statements that the same organizational structure will oversee both construction and operations. Since the existing organizational structural is already responsible for construction and operations, there is a lack of description of what will be turned over and what management structure will receive whatever is being turned over. Based on the discussion in the RAI alignment call held May 1, 2025, TRISO-X explained that the turnover refers to a change in activities from construction to operational readiness and does not represent a change in the management structure.
Information Needed:
Clarify in the RAI response what is meant by the phrase turnover identified in LA Section 2.6 in the last paragraph. Provide sufficient information to understand what is being turned and how it impacts the organizational structure or responsibilities, if at all.
TRISO-X Response to RAI-4:
The phrase turnover in License Chapter 2, Section 2.6, is intended to mean the transition process from construction activities to operational readiness, which will include both physical systems (equipment) and design information and records (documents). The phrase does not represent a change in management structure. A clarification is included below for Section 2.6, paragraph 5.
License Changes:
License Chapter 2, Section 2.6, paragraph 5 During the transition from construction to the commissioning / start-up phase, the turnover will include physical systems and corresponding design information and records will be systematically turned over from the construction contractor(s) to the TRISO-X organization.
Following turnover, the manufacturing organization will be responsible for system maintenance and configuration control. The design basis is maintained following the configuration management system described in Chapter 11, Management Measures.
Observations:
Observation 1 - Consistent Description of Functions Functional areas are described inconsistently throughout LA Chapter 2. In LA Figure 2-1, Functional Organization Chart, there are 16 functional areas identified. However, LA Section 2.3 only describes 8 of the functions including:
- nuclear criticality safety;
- radiation protection;
- environmental protection;
- industrial, chemical, and fire safety; integrated safety analysis;
- licensing;
- material control and accountability;
- security; and
The NRC staff understands that more description is provided for functions that have a nexus to safety, safeguards, and regulatory affairs. However, the absence of a description of the other functions raises questions about consistency. The NRC staff also note there is a general description of the discipline responsibilities in LA Section 2.2, but there is no corresponding general description of the functions. Consider adding a general description of the role of function managers to section 2.2, similar to that provided for discipline managers. This type of general
TX0-REG-LTR-0071 Enclosure - Set 13 License Chapter 1 and 2 RAI Responses Page 11 of 11 explanation of the purpose of functions would help resolve the absences of the more detailed discussion for those functions not addressed specifically in LA Section 2.3 (i.e., it would get across the idea that there is a general description for all disciplines and functions in 2.2 with some additional detail provided for certain key functions in 2.3).
TRISO-X Response to Observation 1:
The remaining seven functional areas shown in Figure 2-1 are discussed in Sections 2.3.2, Manufacturing, and 2.3.3, Engineering. The text of these two sections will be updated to clearly state functional areas include to be consistent with similar wording in Section 2.3.4.