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Kemmerer Unit 1 - Construction Permit Application Supplemental Information on Quality Assurance Requirements
	ML25323A489
Person / Time
Site:	Kemmerer File:TerraPower icon.png
Issue date:	11/19/2025
From:	George Wilson; TerraPower
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	TP-LIC-LET-0470
	Download: ML25323A489 (1)
	v • d • e

15800 Northup Way, Bellevue, WA 98008 www.TerraPower.com P. +1 (425) 324-2888 F. +1 (425) 324-2889 November 19, 2025 TP-LIC-LET-0470 Docket Number 50-613 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Document Control Desk

Subject:

Kemmerer Unit 1 Construction Permit Application Supplemental Information on Quality Assurance Requirements

Reference:

1. TerraPower, LLC on behalf of US SFR Owner, LLC, Submittal of the Construction Permit Application for the Natrium Reactor Plant, Kemmerer Power Station, Unit 1, March 28, 2024, ML24088A060.

2.

TerraPower, LLC on behalf of US SFR Owner, LLC, Submittal of Revisions to the Construction Permit Application for the Natrium Reactor Plant, Kemmerer Power Station Unit 1, October 3, 2025, ML25276A288.

TerraPower, LLC (TerraPower), on behalf of US SFR Owner, LLC (USO), a wholly owned subsidiary of TerraPower, submitted the Kemmerer Power Station Unit 1 (KU1) construction permit application (CPA) in Reference 1. Enclosure 2 of Reference 1 contains the preliminary safety analysis report (PSAR) revision 0. TerraPower provided revisions to the KU1 CPA in Reference 2. Enclosure 1 of Reference 2 contains PSAR revision 1. of this letter provides approved changes as mark-ups to PSAR revision 1 that will be incorporated into the next revision of the PSAR. Specifically, section 8.1, Quality Assurance, and section 11.1, Organization, are modified to clarify implementation of the quality assurance program for KU1.

This letter and enclosure make no new regulatory commitments.

Date: November 19, 2025 Page 2 of 2 15800 Northup Way, Bellevue, WA 98008 www.TerraPower.com P. +1 (425) 324-2888 F. +1 (425) 324-2889 If you have any questions regarding this submittal, please contact Nick Kellenberger at nkellenberger@terrapower.com or Ian Gifford at igifford@terrapower.com.

Sincerely, George Wilson Senior Vice President, Regulatory Affairs TerraPower, LLC Mark-ups for PSAR Sections 8.1 and 11.1 cc:

Mallecia Sutton, NRC Joshua Borromeo, NRC Nathan Howard, DOE

ENCLOSURE 1 Mark-ups for PSAR Sections 8.1 and 11.1

All Rights Reserved 8.1-4 8.1.2 Responsibilities During Design and Construction US SFR Owner, LLC (USO), a wholly owned subsidiary of TerraPower, is responsible for the establishment and execution of quality assurance program requirements. USO accomplishes this through agreement with TerraPower, its direct and controlling owner, for TerraPower to be responsible to USO for all activities for Kemmerer Unit 1 using the TerraPower QAPD.

TerraPower may further delegate the work of establishing and executing the quality assurance program, or any parts thereof, but retains responsibility to USO for the quality assurance program. The USO Quality Execution Plan (QEP) governs the implementation of the TerraPower QAPD for the Kemmerer Unit 1 project, including audits of the execution of the QAPD.

TerraPower has further delegated major portions of the work of establishing and executing the quality assurance program to its project partners. GE Vernova Hitachi Nuclear Energy Americas LLC is responsible for the design of a portion of the nuclear systems and procurement of certain key components using its QA program. Bechtel Power Company is responsible for the design of Nuclear Island structures, Nuclear Island electrical systems, radioactive waste treatment systems, and the Energy Island and is designated as the Engineering, Procurement, and Construction company for Kemmerer Unit 1.

TerraPower has oversight of project partners through a project quality execution plan and procurement documents that flow quality and regulatory requirements down to the project partners and require flow down to the project partners sub-contractors. Additionally, TerraPower performs audits of the project partners to verify effective implementation of the partners quality assurance programs. A QAPD for operations will be submitted at the operating license (OL) stage.

8.1.3 Organization and Controls The QAPD describes the TerraPower QA organization and responsibilities during design and construction of Kemmerer Unit 1. The Natrium project organization and responsibilities, including those related to QA during pre-operational testing through operation, are described in Section 11.1. The director responsible for quality is independent of any TerraPower project and has the authority to stop work on any project for quality, safety, or environmental concerns. The director responsible for quality also establishes independence between the organization performing checking functions and the organization responsible for performing the function in accordance with NUREG-0800, Section 17.5, item II.A.3.

TerraPower has management controls and lines of communication for QA activities distributed among the project partners to ensure all aspects of the QA program are appropriately directed.

TerraPower utilizes a quality execution plan that flows down contractual and regulatory requirements in accordance with the QAPD and its respective program as appropriate for the associate criteria to ensure that each partners QA program meets the minimum contractual requirements based on the scope of work being executed, prior to that organization performing work on, or in support of Kemmerer Unit 1. In cases where gaps are identified, TerraPower ensures mitigating actions are in place and approved by TerraPower to ensure full contractual QA compliance in accordance with the applicable regulatory requirements and the QAPD. In cases where TerraPower determines the applicable partner organization meets or exceeds the

All Rights Reserved 11.1-1 Chapter 11 Conduct of Operations 11.1 Organization This section describes the organizational structure and key management positions in the organizations that are responsible for facility design, design review, design approval, construction management, testing, and plant operation.

TerraPower, LLC is responsibleU.S. SFR Owner, LLC (USO), a wholly owned subsidiary of TerraPower, LLC, is responsible for the design, construction, and safe operation of Kemmerer Unit 1. Through an agreement with TerraPower, its direct and controlling owner, USO has delegated to TerraPower the responsibility for the design and construction of Kemmerer Unit 1.

TerraPower has over 15 years of experience as a nuclear innovation company, which includes designing, building, and laboratory testing of advanced nuclear technologies. As described below, several executives for TerraPower are serving the same role for USO. TerraPower partners with GE Vernova Hitachi Nuclear Energy Americas LLC (GVH) as a co-developer and Bechtel Power Corporation (BPC) as an engineering and construction partner. GVH and BPC each have over 60 years of experience in the design and construction of commercial nuclear reactors. BPC has participated in the design and construction of over 150 nuclear power projects in 25 countries. TerraPower leverages the experience of its partners to ensure the safe design and construction of Kemmerer Unit 1.

The TerraPower Board of Directors has over 50 years of nuclear executive experience which it leverages to ensure a culture exists at the company where rigorous standards are maintained for nuclear safety, safety culture, and construction.

US SFR Owner, LLC (USO), a wholly owned subsidiary of TerraPower, is responsible for the safe operation of Kemmerer Unit 1 from pre-operational testing through commercial operation.

Responsibilities are assigned to an Executive Management Organization, Natrium Project Organization, Construction Organization, and Operating Organization. TerraPower is the direct and controlling owner of USO. An overview of organizational responsibilities from design to commercial operation follows.

Design: TerraPower has overall ownership, control, oversight, and authority of the design.

Construction: TerraPower partners with BPC to perform the construction of Kemmerer Unit 1. BPC executes this responsibility through the Construction Organization.

TerraPower coordinates with, and provides oversight of, BPC through the Natrium Project Organization, which continues to be the design authority. TerraPower oversight of the quality assurance program during construction is described in Section 8.1.

Pre-operational testing: USO conducts pre-operational testing, which includes fuel load and startup testing, through the Operating Organization. Overall technical support functions are provided through the oversight of TerraPower and USO.

Commercial operation: USO executes responsibilities for the daily operation of Kemmerer Unit 1 through the Operating Organization and shares technical support functions with TerraPower.

11.1.1 Executive Management Organization-TerraPower/USO Executive management has the primary responsibility for executing activities and functions for Kemmerer Unit 1. Executive management establishes expectations for quality, safety, and efficiency in plant operations and support activities performed by an organization selected and trained to meet these expectations through an effective management model. The Executive Management Organization includes the President and Chief Executive Officer (CEO) of TerraPower, the TerraPower executive responsible for project execution, the TerraPower executive responsible for regulatory affairs, the TerraPower Chief Nuclear Officer (CNO), and the director responsible for quality. The roles and responsibilities of these executives are described below. The Executive Management Organization is depicted in Figure 11.1-1.

11.1.1.1 President and CEO-TerraPower/USO The President and CEO of USOTerraPower has overall responsibility for functions involving design, construction, and operation. At present, the President and CEO of USO is the same individual as the President and CEO of TerraPower. TheIn their role as the President and CEO of TerraPower isUSO, they are responsible for the execution of the TerraPower Quality Assurance Program Description (QAPD) and its subordinate documentsestablishment and execution of quality assurance program requirements and ensuring information and resources are shared between the nuclear-oriented part of the organization and the rest of the corporate organization in a manner that prioritizes nuclear safety and security.

Responsibilities for design and construction are assigned to the executive responsible for project execution. Prior to pre-operational testing, direct control of nuclear plant operation is assigned to the CNO and the CNOs direct reports.

11.1.1.2 Executive Responsible for Project Execution-TerraPower/USO The executive responsible for project execution is responsible for the design and construction of Kemmerer Unit 1. It is the responsibility of the executive responsible for project execution to provide guidance and direction such that activities including engineering, construction, operations, maintenance, procurement, and planning during the design and construction phase are performed in accordance with the requirements of the QAPD.

The executive responsible for project execution ensures contractor support is obtained to perform principal site-related engineering studies of meteorology, geology, seismology, hydrology, demographics, and environmental effects. The results of these studies are described in Chapter 2. The executive responsible for project execution is responsible for coordination between groups performing design and construction activities, to include coordination with the nuclear reactor vendor.

At present, the executive responsible for project execution of USO is the same individual as the executive responsible for project execution of TerraPower.

All Rights Reserved 11.1-3 11.1.1.3 Executive Responsible for Regulatory Affairs-TerraPower/USO The executive responsible for regulatory affairs is responsible for the licensing, fitness-for-duty (FFD), security, and records management for Kemmerer Unit 1 during design and construction.

The executive responsible for regulatory affairs ensures licensing activities are performed in accordance with government regulations, that FFD and security requirements are met as described in Section 11.6, and that records management and document control program activities for TerraPower meet the requirements of the QAPD. The executive responsible for regulatory affairs is assisted in these activities by the director responsible for licensing, the manager responsible for cyber and physical security, and the manager responsible for records management and document control.

At present, the executive responsible for regulatory affairs of USO is the same individual as the executive responsible for regulatory affairs of TerraPower.

11.1.1.4 CNO-TerraPower/USO The CNO has direct authority and responsibility for the management, control, and supervision of the nuclear power plant and for the execution of nuclear programs, policies, and decisions. The CNO ensures the collective experience of the senior leadership team at Kemmerer Unit 1 meets the requirements of Section 4.2 of ANSI/ANS-3.1-2014 (Reference 11.1-1), as endorsed by Regulatory Guide 1.8, Qualification and Training of Personnel for Nuclear Power Plants, Revision 4. The CNO is assisted in management and technical support activities by the Plant General Manager (PGM), Director of Natrium Support Services, Procurement Manager, and the Director of Nuclear Oversight.

The CNO is the corporate executive with overall responsibility for nuclear safety and compliance.

The CNO assumes these duties prior to the commencement of pre-operational testing.

11.1.1.5 Director Responsible for Quality-TerraPower/USO The director responsible for quality reports to the President and CEO of TerraPower and is responsible for maintaining the QAPD and ensuring the design and construction of Kemmerer Unit 1 is performed in accordance with the QAPD and the Natrium Demonstration Project Quality Execution Plan. The director responsible for quality is responsible for ensuring quality audits are performed in accordance with the QAPD as well as ensuring TerraPower performs functions safely and in accordance with environmental regulations. The director responsible for quality is independent of any TerraPower project and has the authority to stop work on any project for quality, safety, or environmental concerns. The director responsible for quality also establishes independence between the organization performing checking functions and the organization responsible for performing the function in accordance with NUREG-0800, Section 17.5, item II.A.3.

At present, the director responsible for quality of USO is the same individual as the director responsible for quality of TerraPower. The director responsible for quality of USO will become independent of the director responsible for quality of TerraPower once the CNO establishes the Kemmerer Unit 1 operating organization prior to commencing pre-operational testing. This position is described in Section 11.1.4.2 as the Director of Nuclear Oversight.

All Rights Reserved 11.1-4 11.1.2 Natrium Project Organization-TerraPower/USO The Natrium Project Organization is responsible for the design and construction of Kemmerer Unit 1. TerraPower partners with BPC to execute this responsibility through the Construction Organization, which is described in Section 11.1.3. The Natrium Project Organization is the design authority for Kemmerer Unit 1.

The Natrium Project Organization is led by the executive responsible for project execution. The executive responsible for project execution is supported by the Deputy Project Director, Director Plant Delivery, Director Nuclear Fuel and Equipment Qualification, executive responsible for design, and Director of Safety and Engineering Analysis. The roles and responsibilities of the executive responsible for project execution are described in Section 11.1.1.2. The roles and responsibilities of individuals reporting to the executive responsible for project execution are described in Section 11.1.2.2 through Section 11.1.2.5. The Natrium Project Organization is depicted in Figure 11.1-2.

11.1.2.1 Deputy Project Director-TerraPower/USO The Deputy Project Director is the senior project manager and is responsible for the overall planning, direction, management, procurement activities, coordination, implementation, execution, control, and completion of construction activities related to Kemmerer Unit 1. The Deputy Project Director manages the Senior Manager, Procurement; Senior Manager, Project Planning; and Manager, Subcontractor Oversight.

11.1.2.2 Director of Plant Delivery-TerraPower/USO The Director of Plant Delivery oversees the design of safety-significant structures, systems, and components (SSCs).

11.1.2.3 Director Nuclear Fuel and Equipment Qualification-TerraPower The Director Nuclear Fuel and Equipment Qualification oversees fuel, materials, and component specification review and approval.

11.1.2.4 Executive Responsible for Design-TerraPower The executive responsible for design is responsible for configuration management of the design; establishes and maintains design processes that ensure the design meets technical and quality standards; maintains engineering design programs; and establishes qualification standards for engineering personnel.

11.1.2.5 Director of Safety and Engineering Analysis-TerraPower The Director of Safety and Engineering Analysis oversees the development of the probabilistic risk assessment, defense-in-depth, and design basis event analyses.

The Director of Safety and Engineering Analysis is supported by the Senior Manager, Safety Analysis and Risk who manages the team performing the risk analysis activities. This team leverages the experience gained from previous TerraPower projects, including the TWR. The

All Rights Reserved 11.1-10 Figure 11.1-1 Executive Management Organization Executive responsible for regulatory affairs Executive responsible for project execution Director responsible for quality Chief Nuclear Officer President/CEO

All Rights Reserved 11.1-13 Figure 11.1-4 Operating Organization and Technical Support CNO PGM Director of Operations Shift Operations Manager Fire Protection Manager Director of Training Ops Training Manager Maintenance &

Technical Training Manager Security Manager Station Sciences Manager RP Supervisor Station Sciences Tech Director of Maintenance Maintenance Execution Manager Work Management Manager Director of Org Effectiveness EP & Licensing Manager Procurement Manager Director Engineering Support Services Commissioning Manager Plant Support Engineering Design Support Engineering Director of NOS Quality Assurance Manager

ML25323A489

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