ML23009B755

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Audit Plan for the Xe-100 Principal Design Critieria Licensing Topical Report
ML23009B755
Person / Time
Site: 99902071
Issue date: 01/19/2023
From: Michael Orenak
NRC/NRR/DANU/UAL1
To:
X-Energy
Orenak M
References
EPID L-2022-TOP-0010
Download: ML23009B755 (4)


Text

X ENERGY LLC - AUDIT PLAN FOR THE XE-100 PRINCIPAL DESIGN CRITERIA LICENSING TOPICAL REPORT (EPID L-2022-TOP-0010)

SPONSOR INFORMATION Sponsor:

X Energy, LLC Sponsor Address:

801 Thompson Avenue Rockville, MD 20852 Plant Name(s) and Unit(s):

Xe-100 High Temperature Gas Reactor 4-Unit Module Project No(s):

99902071

Background:

X Energy, LLC (X-energy) began pre-application discussions with the U.S. Nuclear Regulatory Commission (NRC) staff regarding its Xe-100 pebble-bed high temperature gas cooled reactor design in September 2018. As part of its pre-application activities, X-energy has submitted various topical reports (TRs) and white papers. By letter dated July 13, 2022, X-energy submitted to the NRC staff, Xe-100 Principal Design Criteria: Licensing Topical Report (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22195A260). The TR describes the development of the principal design criteria (PDC) for the Xe-100 reactor.

Purpose The purpose of the audit is to allow the NRC staff to: (1) efficiently gain an understanding of the detailed information supporting the TR, (2) verify information, and/or (3) identify information that will require docketing to support the development of the safety evaluation report.

Regulatory Audit Basis The basis for the audit is the regulations in Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Domestic Licensing of Production and Utilization Facilities, Section 50.34, Contents of applications; technical information. Paragraph 10 CFR 50.34(a)(3)(i) requires, in part, that an applicant for a construction permit to build a power reactor provide PDC for the facility. Similar regulatory requirements exist for design certifications, combined licenses, standard design approvals, and manufacturing licenses (10 CFR 52.47(a)(3)(i),

10 CFR 52.79(a)(4)(i), 10 CFR 52.137(a)(3)(i), and 10 CFR 52.157(a), respectively). The PDC establish the necessary design, fabrication, construction, testing, and performance requirements January 19, 2023 for structures, systems, and components important to safety; that is, structures, systems, and components that provide reasonable assurance that the facility can be operated without undue risk to the health and safety of the public.

Regulatory Audit Scope The regulatory audit will follow the guidance in NRR Office Instruction LIC-111, Regulatory Audits (ML19226A274). This audit will focus on information provided by X-energy in an online reference portal.

Information and Other Material Necessary for the Regulatory Audit During the review of the TR, the NRC staff developed preliminary questions and discussed them with X-energy during a public meeting held on November 30, 2022 (ML22321A302). X-energy provided formal responses to the questions based on the discussions during the public meeting on December 30, 2022 (ML22364A293). After the public meeting, X-energy suggested that an audit of their detailed documents could help the NRC staff gain a better understanding of the information in the TR. X-energy will make the following documents available during the audit:

XE00-P-G1ZZ-GLZZ-W-001279, Xe-100 Required Safety Functions and PRA Safety Functions, Revision 3

XE00-P-G1ZZ-GLZZ-W-001067, Xe-100 Preliminary SSC Classification List, Revision 1

XE00-P-PCDA-RPS-GL-GL-X-005767, Xe-100 Special Treatment for the Reactor Protection System, Revision 1

XE00-P-G1ZZ-GLZZ-X-002327, Xe-100 Integrated Decision-making Process Implementation Guide, Revision 2

XE00-P-G1ZZ-GLZZ-X-002108, Xe-100 Integrated Decision-making Process Panel Charter, Revision 2 The NRC staff may request to review additional documents identified during the audit.

Team Members Ian Jung Technical Reviewer Boyce Travis Technical Reviewer David Burgess General Engineer Michael Orenak Project Manager Additional audit team members may be added as needed.

Logistics Entrance Meeting February 6, 2023, at 9:00 AM EDT Exit Meeting February 10, 2023, at 2:00 PM EDT Audit meetings will take place in a virtual format, using Microsoft Teams or another similar platform. Audit meetings will be scheduled on an as needed basis after the entrance meeting and once the NRC staff has had the opportunity to read any documents placed in the online reference portal. The audit will begin February 6, 2023, at 10:00 AM EDT. The audit is scheduled to end on February 10, 2023; however, if more time is needed, the audit may be extended along with a concurrent change to the Exit Meeting date.

To improve the efficiency of the audit, X-energy and the NRC staff will use the online reference portal established by X-energy (i.e., Certrec) that allows the NRC staff limited read-only access to the material and other technical information. The use of the online reference portal is acceptable provided that X-energy establishes measures to limit access to specific NRC staff (e.g., based on the NRC staffs e-mail addresses or the use of passwords which will only be assigned to the NRC staff directly involved in the audit on a need-to-know basis), and to make the documents read-only (i.e., to prevent the NRC staff from saving, copying, downloading, or printing any documents). The conditions associated with the online reference portal must be maintained throughout the audit process. The NRC staff who should initially be granted access to the portal are those listed in the Team Members section above. As needed, the NRC Project Manager may provide X-energy with the names of additional NRC staff members who are added to the audit team and should be granted access.

Special Requests The NRC staff requests that X-energy ensure that its technical staff members are available to answer questions during the audit.

Deliverables At the completion of the audit, the audit team will issue an audit summary within 90 days after the exit meeting. The audit summary will be added to ADAMS and be made available for public viewing.

Please contact me at (301) 415-3229 or via email at Michael.Orenak@nrc.gov with any questions related to this audit.

Date: January 19, 2023 Sincerely, Michael Orenak, Project Manager Advanced Reactor Licensing Branch 1 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Signed by Orenak, Michael on 01/19/23

SUBJECT:

X ENERGY LLC - AUDIT PLAN FOR THE PRINCIPAL DESIGN CRITERIA LICENSING TOPICAL REPORT (EPID L-2022-TOP-0010)

DATED: JANUARY 19, 2022 DISTRIBUTION:

PUBLIC RidsNrrDanu Resource RidsNrrDanuUal1 Resource RidsNrrDanuUal2 Resource RidsOgcMailCenter Resource RidsACRSMailCTR Resource IJung, NRR BTravis, NRR MOrenak, NRR MHayes, NRR WJessup, NRR DGreene, NRR CSmith, NRR ADAMS Accession Number: ML230009B755 NRR-106 OFFICE NRR/DANU/UAL1/PM NRR/DANU/UAL1/LA NRR/DANU/UTB1 NAME MOrenak DGreene IJung DATE 1/10/2023 1/17/2023 1/18/2023 OFFICE NRR/DANU/UART1/BC NRR/DANU/UAL1/BC NRR/DANU/UARL/PM NAME MHayes WJessup MOrenak DATE 1/18/2023 1/19/2023 1/19/2023 OFFICIAL RECORD COPY