ML25253A247
| ML25253A247 | |
| Person / Time | |
|---|---|
| Site: | 99902128 |
| Issue date: | 09/11/2025 |
| From: | Hernandez J Office of Nuclear Reactor Regulation |
| To: | Alissa Neuhausen Office of Nuclear Reactor Regulation |
| References | |
| EPID L-2025-TOP-0016 | |
| Download: ML25253A247 (1) | |
Text
September 11, 2025 MEMORANDUM TO:
Alissa Neuhausen, Chief Advanced Reactor Licensing Branch 2 Division of Advanced Reactors and Non-power Production and Utilization Facilities Office of Nuclear Reactor Regulation FROM:
Jorge Hernandez, Project Manager
/RA/
Advanced Reactor Licensing Branch 2 Division of Advanced Reactors and Non-power Production and Utilization Facilities Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE JULY 24, 2025, PUBLIC MEETING WITH AALO ATOMICS, QUALITY ASSURANCE PROGRAM DESCRIPTION TOPICAL REPORT CLARIFYING QUESTIONS (EPID NO. L-2025-TOP-0016)
Meeting Information:
Applicant: Aalo Atomics Docket/Project No.(s): 99902128 Public Meeting Notice Agencywide Documents Access and Management System (ADAMS)
Accession No.: ML25199A238 Applicant Presentation Slides ADAMS Accession No.: ML25245A262 NRC Staff Presentation Slides ADAMS Accession No.: N/A Meeting Attendees: See the enclosure for a list of meeting attendees.
CONTACT:
Jorge Hernandez, NRR/DANU 301-287-9096
Background:
By letter dated April 9, 2025 (ML25099A311), Aalo Atomics (Aalo) submitted for U.S. Nuclear Regulatory Commission (NRC) staff review Topical Report (TR) No. AALO-QAP-001, Quality Assurance Program for Aalo Atomics, Revision 1, dated March 20, 2025. The TR describes Aalos quality assurance program applicable to research and development, design, construction, operation, and decommission activities. The NRC staff determined that the TR was acceptable for review on May 23, 2025 (ML25142A234). The NRC staff reviewed the topical report and identified clarifications needed to finalize its evaluation.
Meeting Summary:
The NRC staff conducted the meeting in accordance with NRCs Management Directive 3.5, Attendance at NRC Staff-Sponsored Meetings, (ML21180A271). The purpose of the meeting was to discuss staff requests for clarification on certain portions of the TR. The staff requests and Aalos responses are summarized as follows:
With regard to Subsections 2.1.3, 2.1.9, and 2.1.10, the NRC staff requested Aalo to clarify how it plans to use the joint utility audits performed by members of the Nuclear Procurement Issues Corporation (NUPIC) to ensure that Aalos vendors are meeting the requirements of Appendix B, Quality Assurance Program Criteria for Nuclear Power Plants and Reprocessing Plants, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, given that Aalo is not a member of NUPIC.
o Aalos response: All three sections will be modified to include the Nuclear Industry Assessment Corporation (NIAC) as alternative industry group that may be used to perform vendor audits.
With regard to Subsection 2.2.5, the NRC staff requested Aalo to confirm that any changes to Aalos Quality Assurance Program Description (QAPD) will be submitted to the NRC for review and approval in accordance with the requirements of 10 CFR 50.4(7)(ii), which is the applicable regulation for non-licensees, instead of 10 CFR 50.55(f) and 10 CFR 50.54(a), which are cited in the TR but are only applicable to NRC licensees.
o Aalos response: Subsection 2.2.5 will be modified to replace references to 10 CFR 50.55(f) and 10 CFR 50.54(a) with a reference to 10 CFR 50.4(7)(ii).
The NRC staff requested Aalo to clarify if the QAPD is committed to meeting the regulatory positions documented in Revision 6 of Regulatory Guide (RG) 1.28 (ML23177A002), Quality Assurance Program Criteria (Design and Construction), dated September 2023, for Requirements 2 and 7 of NQA-1-2022, Quality Assurance Requirements for Nuclear Facility Applications, consistent with similar statements used in Subsections 17 and 18.
o Aalos response: Confirmed conformance with the regulatory positions in Revision 6 of RG 1.28.
With regard to Subsection 2.7.1, the NRC staff requested Aalo to clarify what industry
programs may be used as a basis for supplier qualification, given that Aalo is not a member of NUPIC or any other utility groups, and American Society of Mechanical Engineers (ASME) audits are confidential.
o Aalos response: Subsection 2.7.1 will be revised to include NIAC as an alternative for supplier qualification and will revise the language to be consistent with the scope of the organizations listed (e.g., use of the word applied will be revisited).
With regard to Subsection 2.7.2, the NRC staff requested Aalo to remove the word other given that its use implies that Aalo is already the holder of an NRC license, which it is not.
o Aalos response: Agree to remove the word other.
With regard to Subsection 2.7.2, the NRC staff requested Aalo to clarify if the QAPD is committed to implementing Nuclear Energy Institute (NEI)14-05A, Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services, Revision 1, dated September 2020.
o Aalos response: Agree to clarify that the QAPD is committed to implementing NEI 14-05A, Revision 1, and also clarify that commercial grade is for the purpose of calibration and testing services.
With regard to Section 2.11, the NRC staff requested Aalo to clarify if the QAPD plans on providing measures to assure that testing is performed under suitable environmental conditions in accordance with 10 CFR Part 50 Appendix B, Criterion XI, Test Control.
o Aalos response: Section 2.11 will be revised to clarify that testing will be performed under suitable environmental conditions.
With regard to Section 2.12, the NRC staff asked Aalo to clarify if the QAPD plans to address: (1) how the calibration status will be indicated and traceability maintained; (2) how often the measuring and test equipment (M&TE) will be calibrated and whether calibration will be against national standards; (3) what happens when there arent any nationally recognized standards; and (4) what actions Aalo will take when M&TE is found to be out of calibration.
o Aalos response: Section 2.12 will be modified to address the conditions identified by the staff.
With regard to Section 2.15, the NRC staff asked Aalo to clarify if the QAPD plans on providing measures to disposition nonconforming items in addition to repair or use-as-is and whether the disposition, and the associated technical justification, as applicable, will be identified and documented, as required by Criterion XV, Nonconforming Materials, Parts, or Components, of Appendix B to 10 CFR Part 50.
o Aalos response: Section 2.15 will be modified to include all dispositions identified in Criterion XV of Appendix B to 10 CR Part 50.
With regard to Section 4, the NRC staff noted that there are various RGs and standards that are not listed but are applicable to quality assurance. For example: RG 1.8 (ML19101A395), RG 1.28 (ML23177A002), RG 1.29 (ML21155A003), RG 1.33 (ML13109A458), RG 1.164 (ML24038A310), RG 1.231 (ML16126A183), RG 1.234 (ML24038A311), and Revision 1 of NEI 14-05A. The NRC staff asked Aalo to confirm that it plans to identify conformance in the QAPD or, if indicating conformance at this point is not practical, that it plans to include a list of these documents in the topical report and explain that conformance and exceptions for the applicable regulatory position provided in the RGs and the quality assurance standard will be provided in the applicable license applications.
o Aalos response: Aalo requested more time to address this question.
Subsequent to the meeting, on September 2, 2025, Aalo submitted a response to this question (ML25245A262). In its response, Aalo stated that it will identify conformance with the applicable regulatory position guidance in RG 1.29 in specific license applications. Aalo will update Section 4.1 to include RG 1.28, RG 1.8, RG 1.33, RG 1.164, RG 1.231, RG 1.234 and Section 4.2 to include NEI 14-05 Rev 1.
No regulatory decisions were made as a result of this meeting.
Docket No. 99902128
Enclosure:
List of Meeting Attendees cc: Aalo Atomics - Idaho Nuclear Project via GovDelivery
SUBJECT:
SUMMARY
OF THE JULY 24, 2025 PUBLIC MEETING WITH ABILENE CHRISTIAN UNIVERSITY, FUEL QUALIFICATION METHODOLOGY WHITE PAPER (EPID NO. L-2025-TOP-0016) DATED: SEP 11, 2025 DISTRIBUTION:
PUBLIC RidsNrrDanuUal2 Resource RidsNrrDanu Resource KRoche YDiaz-Castillo KKavanagh GOberson ADAMS Accession Number: [ML25253A247] NRR-001 OFFICE NRR/DANU/UAL2/
PM NRR/DANU/UTB1/
BC NRR/DANU/UAL2/
BC NRR/DANU/UAL2/
PM NAME JHernandez GOberson ANeuhausen JHernandez DATE 09/10/25 09/11/25 09/11/25 09/11/25 OFFICIAL RECORD COPY
Enclosure List of Meeting Attendees For the July 24, 2025 Public Meeting with Aalo Atomics, Quality Assurance Program Description September 11, 2025 Name Organization Jorge Hernandez U.S. Nuclear Regulatory Commission (NRC)
Kerri Kavanagh NRC Kevin Roche NRC Stephen Philpott NRC Yamir Diaz-Castillo NRC Asmaa Farag Aalo Atomics Egemen Aras Aalo Atomics Les Taggart Aalo Atomics Lynn Hernandez Aalo Atomics Partha Chandran Aalo Atomics Richard Williams Aalo Atomics Wheeler Gibson Aalo Atomics Phil Pfeiffer Walsh Engineering Ryan Marcum Member of the Public