ML23066A287
| ML23066A287 | |
| Person / Time | |
|---|---|
| Site: | 99902071 |
| Issue date: | 06/06/2023 |
| From: | Stephanie Devlin-Gill NRC/NRR/DANU/UAL1 |
| To: | Proffitt J NRC/NRR/DANU/UAL1 |
| Devlin-Gill S | |
| References | |
| Download: ML23066A287 (4) | |
Text
MEMORANDUM TO:
Joseph A. Proffitt, Acting Chief Advanced Reactor Licensing Branch 1 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation FROM:
Stephanie Devlin-Gill, Senior Project Manager Advanced Reactor Licensing Branch 1 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE DECEMBER 2, 2022, PARTIALLY CLOSED PRE-SUBMITTAL, MEETING WITH X-ENERGY, LLC., REGARDING THE XE-100 SPENT FUEL LICENSING APPROACH AND REGULATORY ANALYSIS WHITE PAPER On December 2, 2022, the U.S. Nuclear Regulatory Commission (NRC) staff held a partially closed (open and closed sessions), pre-submittal meeting with representatives from X Energy, LLC (X-energy). The purpose of the meeting was to discuss X-energys Xe-100 Spent Fuel Licensing Approach and Regulatory Analysis white paper, which X-energy stated it plans to submit to the NRC staff for their review by December 21, 2022. During the meeting, X-energy provided an overview of the proposed Xe-100 spent fuel storage system and described X-energys approach to comply with the NRCs Regulations.
The meeting was noticed on November 18, 2022, and the meeting notice is available in the Agencywide Documents Access and Management System (ADAMS) under accession number ML22322A101. The publicly available presentation materials can also be found in ADAMS (ML23011A324) (open and closed session).
The meeting was conducted as an online meeting with attendees joining via Microsoft Teams.
There were members of the public in attendance during the open session of the meeting, but they made no comments nor asked questions during the meeting. A list of meeting attendees is enclosed.
During the open session of the meeting, X-energy representatives provided the NRC staff an overview of the Xe-100 site layout, the fuel design, and the spent fuel storage system (SFSS).
Regarding the plant layout, X-energy stated that everything necessary to operate Unit 1 will be installed at the same time, including common plant services, equipment, and buildings, and that the construction of Unit 1 includes a spent fuel intermediate storage facility (SFISF) for storage of spent fuel. X-energy stated that subsequent units will be installed and connected to common plant services, equipment, and buildings.
June 6, 2023 Signed by Devlin-Gill, Steph on 06/06/23
J. Proffitt Regarding the fuel design, X-energy stated that the Xe-100 is a graphite moderated pebble bed, helium gas-cooled, high temperature gas-cooled reactor. X-energy stated that each Xe-100 reactor is planned to generate 200 megawatts thermal and approximately 80 megawatts electric. X-energy stated that the Xe-100 reactor will utilize the tri-structural isotropic (TRISO) particle nuclear fuel design, with high-assay low enriched uranium (HALEU) enriched to 15.5 percent in the form of a uranium oxide-carbide mixture. X-energy stated that there are approximately 220,000 fuel spheres in the core at any given time, with up to 1,020 fuel spheres per day circulated through the Fuel Handling System (FHS). X-energy stated that fuel spheres will travel through the core an average of up to 6 times over 1,320 days before being discharged. X-energy said that at full power, 170 to 179 fresh fuel spheres will be added to the core daily and the same number of burned-up (spent) fuel spheres are removed. X-energy described that the FHS will extract spent fuel spheres and load them into spent fuel canisters (SFCs).
X-energy described the design of the SFSS and stated that all movement of SFCs between the reactor building and the SFISF occurs below-grade via the inter-unit access tunnel (IUAT).
Next, X-energy discussed whether it plans to apply Part 50, Domestic Licensing of Production and Utilization Facilities, or Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste, of Title 10 of the Code of Federal Regulations (10 CFR) to the Xe-100 spent fuel management. X-energy stated that it has selected Part 50 as the more applicable regulation, because Part 72 requires spent fuel to be aged for at least 1 year before being placed in the independent spent fuel storage facility and the Xe-100 SFSS loads spent fuel canisters directly into each SFISF with less than 1 year of decay.
X-energy discussed the applicable review guidance stating that 10 CFR 50.34, Contents of applications; technical information, is the applicable regulation for licensing the Xe-100 SFSS, where 10 CFR 50.34(a)(3)(i) and (ii), inform the Xe-100 application content for the preliminary safety analysis report (PSAR) and the 10 CFR 50.34(b)(2) and (10), inform the Xe-100 application content for the final safety analysis report (FSAR). Because of the similarity of the SFISF to an independent spent fuel storage facility, X-energy suggested the use of NUREG-2215, Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities guidance, instead of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, for the Xe-100 PSAR and FSAR applications.
X-energy then described its post-operating license regulatory framework stating that, while the 10 CFR Part 50 Operating License (OL) is specified for 40 years, the Xe-100 reactor design will accommodate a renewed OL for an additional 20 years with 10 CFR Part 54, Requirements for renewal of operating licenses for nuclear power plants, aging management of the SFISF and building contents maintained. X-energy stated that it designed the SFISF and the spent fuel canisters to maintain function for an 80-year period from initial issuance of the OL. X-energy stated that, prior to the expiration of the OL, the Xe-100 reactor will be defueled with canisters loaded into an SFISF. X-energy stated that after the expiration of the OL, the 10 CFR Part 54 aging management will continue to apply to the SFISF and building contents until the spent fuel transfer to the Department of Energy (DOE) and that the spent fuel management will be conducted in accordance with 10 CFR 50.51, Continuation of license, subsection (b), which authorizes continued storage, control, and maintenance of spent fuel in a safe condition. During the 20-year decommissioning period, X-energy stated it will retain custody of special nuclear material under its 10 CFR Part 70, Domestic licensing of special nuclear material, license until the spent fuel canister transfer to DOE. X-energy also stated that it has engaged with the DOE
J. Proffitt to strategize the DOEs acceptance of all spent fuel within the 80-year period.
For the last topic covered during the open session, X-energy discussed its strategy for compliance with 10 CFR 50.68, Criticality accident requirements. X-energy stated it does not intend to pursue a compliance strategy based on 10 CFR 50.68(a), but does intend to pursue a compliance strategy of meeting 10 CFR 50.68(b) with partial exemptions based on Xe-100 SFSS design considerations. X-energy stated that it plans to submit the exemption requests during the FSAR phase of the NRCs 10 CFR Part 50 OL review.
After X-energys presentation, the NRC staff and X-energy had a discussion about how X-energy plans to use probabilistic risk assessment (PRA). X-energy stated that initially the Xe-100 PRA will focus on in-core radiological sources (reactor, connected systems), but that X-energy acknowledged that there are other sources of radionuclides. X-energy stated that for the construction permit (CP) application under 10 CFR Part 50, it will not have PRA-informed risk numbers and that at the time of the meeting, X-energy has an initial analysis of fuel handling events that it is starting to incorporate into its PRA. The NRC staff made a comment to draw X-energys attention to 10 CFR 50.34 and 10 CFR 50.35 Issuance of construction permits, subsection (a) and the NRCs PRA adequacy white paper. The NRC staff asked if X-energy had event scenarios and events being addressed, or any classifications of equipment for the purpose of the CP application. X-energy stated that it has a list of events which were deterministically formed and that it is working to determine if they are not missing any licensing basis event. X-energy stated that this information will be in SAR as part of the CP application.
The NRC staff asked questions related to crane failures and whether X-energy is analyzing for crane failures in the design bases of the spent fuel system. X-energy stated that the events and consequences are formulated by the design team.
The NRC staff asked X-energy when it plans to submit its white paper on the spent fuel licensing approach and regulatory analysis. X-energy stated that it plans to submit the white paper to the NRC by December 21, 2022.
During the closed session of the meeting, X-energy presented more information about the automation of fuel canister carts that are shown on slide 8 from the open session.
No regulatory decisions were made as a result of this meeting.
Please direct any inquiries to me at 301-415-5301, or via e-mail at Stephanie.Devlin-Gill@nrc.gov Docket No.
99902071
Enclosure:
List of Meeting Attendees CONTACT:
Stephanie Devlin-Gill, NRR/DANU/UAL1 (301) 415-5301
ML23066A287 NRC-001 OFFICE NRR/DANU/UAL1:PM NRR/DANU/UAL2:LA NRR/DANU/UAL1:BC NRR/DANU/UAL1:PM NAME SDevlin-Gill CSmith JProffitt SDevlin-Gill DATE 3/7/2023 5/31/2023 6/6/2023 6/6/2023
Enclosure List of Meeting Attendees Partially Closed, Pre-Submittal Meeting with X-Energy Regarding the Xe-100 Spent Fuel Licensing Approach and Regulatory Analysis White Paper December 2, 2022 Name Organization Devlin-Gill, Stephanie U.S. Nuclear Regulatory Commission (NRC)
Diaz Sanabria, Yoira NRC Dowling, Kate NRC Ezell, Julie NRC Jung, Ian NRC Travis, Boyce NRC Vechioli Felician, Lucieann NRC White, Bernie NRC Wise, Brandon NRC Beville, Tim X Energy, LLC (X-energy)
Chapman, Travis X-energy Facemire, Jon X-energy Gibboney, Sarah X-energy Kohanbash, David X-energy Lyford, Scott X-energy Nordby, Ingrid X-energy Staiger, Maggie X-energy Steh, Wesley X-energy Stuhldreher, Timothy Department of Energy (DOE)
Natale, Mark DOE Friesen, Carl DOE Orf, Trace Oklo Moore, Ross Oklo Bergman, Jana Curtiss-Wright Corporation Korb, Elliott Radiant Nuclear