ML25239B565
| ML25239B565 | |
| Person / Time | |
|---|---|
| Site: | 99900507 |
| Issue date: | 09/03/2025 |
| From: | James Smith Licensing Processes Branch |
| To: | Mcintyre J Sargent & Lundy |
| Shared Package | |
| ML25239B563 | List: |
| References | |
| SL-TR-1, Rev. 28, EPID L-2025-TOP-0027 | |
| Download: ML25239B565 (1) | |
Text
FINAL SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SARGENT & LUNDY TOPICAL REPORT SL-TR-1, REVISION 28, NUCLEAR QUALITY ASSURANCE PROGRAM DOCKET NO. 99900507 EPID: L-2025-TOP-0027
1.0 INTRODUCTION
By letter dated July 15, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25183A273), Sargent & Lundy, LLC (S&L), requested approval of proposed changes to its Nuclear Quality Assurance Program, Topical Report (TR) SL-TR-1 Rev. 28 (Ref. 1) (hereafter referred to as the QATR). The proposed revisions are considered changes to the U.S. Nuclear Regulatory Commission (NRC)-accepted quality assurance (QA)
TR from non-licensees (i.e., architect/engineers, nuclear steam supply system (NSSS) suppliers), in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, 50.4(b)(7)(ii). The proposed changes reflect recent organizational changes.
2.0 REGULATORY BASIS The NRC's regulatory requirements related to QA programs are set forth in Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, and 10 CFR 50.4(b)(7), Quality Assurance related submission, Item (ii). The regulation at 10 CFR 50.4(b)(7)(ii) states, in part, a change to an NRC-accepted quality assurance topical report from non-licensees (i.e., architect/engineers, NSSS suppliers, fuel suppliers, contractors, etc.) must be transmitted to the NRC Document Control Desk. The NRC will review the proposed QATR for acceptability to ensure the applicable requirements of Appendix B to 10 CFR Part 50 will be satisfied.
Appendix B to 10 CFR Part 50 establishes QA requirements for the design, fabrication, construction, testing, and operation of structures, systems, and components (SSCs) for the facility. The pertinent requirements of Appendix B to 10 CFR Part 50 apply to all activities affecting the safety-related functions of those SSCs and include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying SSCs.
Regulatory Guide (RG) 1.28, Revision 4, Quality Assurance Program Criteria (Design and Construction) (Ref. 2), identifies the American Society of Mechanical Engineers (ASME)
Nuclear Quality Assurance (NQA)-1-2008 and the NQA-1a-2009 Addenda Quality Assurance Requirements for Nuclear Facility Applications, as an acceptable basis for complying with the requirements of Appendix B to 10 CFR Part 50 with some exceptions.
3.0 EVALUATION 3.1 Proposed Changes In evaluating the adequacy of the proposed change, the NRC staff considered the guidance of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Chapter 17.5, Quality Assurance Program Description - Design Certification, Early Site Permit and New License Applicants, Revision 1 (Ref. 3) (hereafter referred to as SRP Section 17.5).
The NRC staff utilized the guidance contained in SRP Section 17.5, which provides acceptance criteria for QA programs. SRP Section 17.5 is based on the NQA-1-2008/2009, as supplemented by additional regulatory and industry guidance for nuclear operating facilities.
NQA-1-2008/2009, upon which the S&L QATR, Revision 28, is based, incorporates the supplemental guidance into a single document, and is therefore aligned with SRP Section 17.5.
In addition, NQA-1-2008/2009 is endorsed by RG 1.28, Revision 4.
S&L proposed changes to the organization section of the S&L QATR to reflect recent organizational changes. S&L added an additional functional support group, Technology, to show three functional support groups:
Operations, Technology, and Financial The following positions will report to the Chief Executive Officer:
Director of Operations Chief Technology Officer (CTO)
Executive Vice President (EVP) of Finance & Legal The following positions will report to the Director of Operations:
Director of Engineering & Innovation Construction Support Director Director of Learning and Organizational Change Design Director Director of Project Controls & Project Management Office Services Manager of the Electrical Analytical Division Manager of the Cost Information Division Administrative Services Division The CTO oversees the Technology Business Operations Division and is responsible for information management including enterprise content management support services. The Technology Business Operations Division is responsible for the configuration control of software used in production, including the filing of software documentation.
The following positions will report to the EVP of Finance & Legal:
Chief Financial Officer Director of Human Resources General Counsel & Director of Legal Services.
The division of Human Resources is responsible for aspects of access authorization and fitness for duty.
The Information Security Division, led by the CTO, establishes rules for passwords to be used for electronic signatures.
The NRC staff reviewed the proposed changes and concluded that:
S&L QATR continues to ensure that persons and organizations performing QA functions have the required authority and organizational freedom and remain sufficiently independent from cost and schedule when opposed to safety considerations.
S&Ls commitment to Part I and Subparts 2.2, 2.4, 2.5, 2.7, 2.8, and 2.14 of Part II of NQA-1-2008/2009 remains unchanged and no new exceptions to NQA-1-2008/2009 are included in this revision.
The revision of S&Ls QATR, Revision 28, does not reduce commitments in the QATR as previously accepted by the NRC.
3.2 Clarification on Section 7.4 of the QATR:
QATR Section 7.4 includes the following statement associated with supplier audit extension during exigent conditions: During exigent conditions, an extension of 25% may be applied to the triennial frequency for external audits/surveys where performance is not feasible. This 25%
extension is applicable to domestic and international suppliers. Priority shall be given to completing audits/surveys of affected suppliers in order of the expiration of the triennial audit frequency.
The use of the 25 percent frequency extension for audits and commercial-grade surveys during extenuating circumstances was previously approved in the NRC staffs SE for a change to Callaway Plants Operating Quality Assurance Manual dated August 6, 2020 (ML20216A681).
The NRC staff notes that the Coronavirus Disease 2019 (COVID-19) related public health emergency expired on May 11, 2023; therefore, the provisions for audit extension under exigent conditions, as described above, can no longer be used unless new exigent conditions exist.
3.3 Change Consistency S&L submitted an update to the QATR to correct a typographical error that resulted in a conflict in reporting structure for some positions specified in Section 3.1. The NRC staff confirmed that this correction does not materially change the requirements. The NRC staff finds that the proposed change is consistent with SRP Section 17.5 and, therefore, is acceptable.
4.0 CONCLUSION
The NRC staff used the acceptance criteria of NUREG-0800, SRP Section 17.5, as the basis for evaluating the acceptability of the S&Ls QATR, Revision 28, for conformance with the applicable requirements of Appendix B to 10 CFR Part 50. The NRC staff concludes that S&Ls QATR, Revision 28, follows the NRC guidance contained within and conforms to the format of NUREG-0800, Section 17.5, and concludes that there is reasonable assurance that S&Ls QATR, Revision 28, will continue to meet the requirements of Appendix B to 10 CFR Part 50.
Therefore, the NRC staff finds the S&Ls proposed changes in the QATR, Revision 28, acceptable.
5.0 REFERENCES
- 1. Sargent & Lundy, LLC, Topical Report SL-TR-1 Nuclear Quality Assurance Program, July 2025 (ML25183A273).
- 2. Regulatory Guide 1.28, Quality Assurance Program Criteria (Design and Construction),
Revision 4, September 2023 (ML100160003).
- 3. NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, August 2015 (ML15037A441).
Principal Contributor: Frankie Vega Date: 9/3/2025