ML23198A258
| ML23198A258 | |
| Person / Time | |
|---|---|
| Site: | Triso-X |
| Issue date: | 07/27/2023 |
| From: | NRC/NMSS/DFM/FFLB |
| To: | Triso-X |
| Shared Package | |
| ML23198A257 | List: |
| References | |
| Download: ML23198A258 (1) | |
Text
MBartlett - Chapter 1 (Administrative Portion)
Chapter 1 Request for Additional Information for the TRISO-X License Application Review
RAI-1 Facility Layout Information:
Regulatory Basis:
The information below is necessary to demonstrate compliance with the regulations in Title 10 to the Code of Federal Regulations (10 CFR) 70.22, Contents of applications, subsection (a)(2), which states, The activity for which the special nuclear material is requested, or in which special nuclear material will be produced, the place at which the activity is to be performed and the general plan for carrying out the activity. It is also needed to demonstrate compliance with 10 CFR 70.65, Additional content of applications, subsections (b)(2-4), which state, (2) A general description of the facility with emphasis on those areas that could affect safety, including an identification of the controlled area boundaries; (3) A description of each process (defined as a single reasonably simple integrated unit operation within an overall production line) analyzed in the integrated safety analysis in sufficient detail to understand the theory of operation; and, for each process, the hazards that were identified in the integrated safety analysis pursuant to § 70.62(c)(1)(i)-(iii) and a general description of the types of accident sequences; and (4) Information that demonstrates the licensee's compliance with the performance requirements of § 70.61, including a description of the management measures; the requirements for criticality monitoring and alarms in § 70.24; and, if applicable, the requirements of § 70.64 also requires a description of the process with sufficient detail to understand their function.
Guidance on demonstrating compliance with these regulations is provided in NUREG-1520, revision 2, Standard Review Plan for Fuel Cycle Facilities License Applications (NUREG-1520) in sub-section 1.1.4.3.1 Facility Layout Description, acceptance criterion 1 which states, The application presents information at a level of detail that is appropriate for general familiarization with and understanding of the proposed facility. This information should be consistent with that presented in the Integrated Safety Analysis (ISA) Summary but may be less detailed, and acceptance criterion 2 which states, The overview should describe the relationship of specific facility features to the major processes that will be ongoing at the facility.
Describe Issue:
The facility layout descriptions in License Application (LA) section 1.1.2, ISA Summary section 1.0, LA figure 1-2, and ISA Summary figure 1-2 identify 4 main buildings for the site but do not provide information on the role of these buildings, how they fit in the overall process, their location on the site, their size, etc. In addition, the buildings are difficult to identify in the LA figure 1-2 and ISA Summary figure 1-2, particularly for the security building. In addition, the figures include an incomplete legend and do not provide a scale measure of the grid on the figure. This makes it difficult for the reviewer to obtain a general understanding of the footprint/size and location of the buildings with respect to the other buildings and the site boundary.
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Information Needed:
Provide additional information on the facility layout in the LA. Describe the primary structures on the plant site, their purpose, locations on the site, how they fit into the operations of the facility. Include a cross reference in the LA and ISA Summary to the layout descriptions in supporting documents (e.g., environmental report, emergency plan). Clarify the layout of the LA figure 1-2 and ISA Summary figure 1-2 to distinguish the 4 main site buildings, ensure they are included in the legend, clarify the items labeled on the figures but not identified on the legend (e.g., CB-1, MH-1), add a scale measure, and clarify the location of the security building.
RAI-2Nearby Roads, Trails, and Structures:
Regulatory Basis:
This RAI has the same regulatory basis as RAI 1.
Guidance on demonstrating compliance with these regulations is provided in NUREG-1520, revision 2, Standard Review Plan for Fuel Cycle Facilities License Applications (NUREG-1520) in sub-section 1.1.4.3.3 Site Overview. This section states, The license application summarizes the site information contained in the ISA summary. This includes descriptions of the overall facility layout and the drawings to support such descriptions. The license application describes the sites geographical characteristics and facility structural features (such as buildings, towers, and tanks),
transportation rights of way, and proximity to nearby populations. The license application fully describes the facility location. These descriptions are consistent with the information in chapter 8 of this SRP.
Describe Issue:
The LA figures 1-1 and 1-2, ISA Summary figures 1-1 and 1-2 are not sufficiently detailed to get an understanding of the roads and trails near the facility. Emergency Plan (EP) figures 1.3-3 and 1.3-4 provide some information on local trails, roads and nearby structures but the image quality is low and difficult to read, and there is minimal visual distinction between trails and roads.
Information Needed:
Provide additional information in the LA and ISA Summary on the local roads, nearby structures outside the site boundary, and hiking trails. Provide corresponding changes to the figures in the LA (e.g., section 1-2, Site Plan, ISA Summary figure 1-2, Site Layout, EP figures 1.2-1, EP figure 1.3-4) to improve readability, and allow the reviewer to identify nearby roads, buildings, and pedestrian trails. If the information is provided outside of the LA, provide references to the relevant information.
RAI-3Process Overview
Description:
Regulatory Basis:
This information is necessary to demonstrate compliance with the regulations in 10 CFR 70.22(a)(2 and 4), which require the application to contain a description of (2) The
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activity for which the SNM is requested, or in which SNM will be produced, the place at which the activity is to be performed and the general plan for carrying out the activity and (4) The name, amount, and specifications (including the chemical and physical form and, where applicable, isotopic content) of the SNM the applicant proposes to use or produce. The information is also needed to demonstrate compliance with 10 CFR 70.65, Additional content of applications, subsection (b)(2-4), which also requires a description of the process with sufficient detail to understand their function.
Guidance on demonstrating compliance with this regulation is provided in NUREG-1520, 1.1.4.3.1 criterion (1) which states, The application presents information at a level of detail that is appropriate for general familiarization with and understanding of the proposed facility.. And NUREG-1520, 1.1.4.3.1 (2) which states, The overview should describe the relationship of specific facility features to the major processes that will be ongoing at the facility. Additional guidance is provided in NUREG-1520 subsection 1.1.4.3.4 criterion (1) Descriptive Summary of Licensed Material, which states, The summary should describe chemical and physical forms of SNM in process; the maximum amounts of SNM in process in various building locations; and 1.1.4.3.4 criterion (3) If applicable, the applicant has marked portions of the application to identify any proprietary or sensitive information (e.g., possession limits).
Describe Issue:
The description of the TRISO-X process is provided in several locations: LA section 1.1.3, ISA Summary section 2.1, ISA Summary section 3.0, EP section 1.1.1, environmental report section 2.1.2.1.3, etc. The process overview provided in the LA and ISA Summary are high level and do not provide sufficient information to understand the major steps involved in manufacturing.
Information Needed:
Provide in the LA a complete overview of the TRISO-X process from receipt of material through manufacturing, storage, and shipment of product. Include information similar to the manufacturing process provided in the environmental report section 2.1.2.1.3.
Include a description of the chemical and physical forms of the SNM as it moves from arrival on site, through the major steps in manufacturing, to storage and shipment off-site. Clarify that the amount of material throughout the process is controlled and tracked by an inventory system with appropriate procedures.
RAI-4Fuel Kernels and Process Description
Regulatory Basis:
The following information is necessary to demonstrate compliance with 10 CFR 70.22(a)(4), which requires the application to include, The name, amount, and specifications (including the chemical and physical form and, where applicable, isotopic content) of the SNM the applicant proposes to use or produce.
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Describe Issue:
The term fuel kernel is used several times throughout the application in the LA (e.g.,
section 1.1.3 General Process Description), ISA Summary and EP; however, the term is not well defined. In addition, the ISA Summary section 3.4 and EP section 1.1.4 indicate the fuel kernel needs to meet certain quality assurance criteria, which indicates these criteria are important to the process, but there is no indication of how quality assurance is important, if it impacts safety, or what are the quality assurance criteria.
Information Needed:
Provide a definition for fuel kernel used in the LA. In addition, clarify the importance of the quality assurance checks for the kernel described in the ISA Summary section 3.4 and EP sections 1.1.4 and 1.1.5, etc. Clarify the meaning of the phrase -
non-conforming products.
RAI-5Population Near the Site:
Regulatory Basis:
The following information is necessary to demonstrate compliance with the regulations in 10 CFR 70.65(b)(1-2), (1) A general description of the site with emphasis on those factors that could affect safety (i.e., meteorology, seismology); and (2) A general description of the facility with emphasis on those areas that could affect safety, including an identification of the controlled area boundaries.
Guidance on demonstrating compliance with this regulation is provided in NUREG-1520 sub-section 1.1.4.3.3 Site Overview which states, The LA summarizes the site information contained in the ISA Summary. This includes descriptions of the overall facility layout and the drawings to support such descriptions. The LA describes the sites geographical characteristics and facility structural features (such as buildings, towers, and tanks), transportation rights of way, and proximity to nearby populations. The LA fully describes the facility location. These descriptions are consistent with the information in Chapter 8 of this SRP. NUREG-1520 also states in section 1.3 (2), The summary provides population information on the basis of the most current available census data.
To the extent possible, data reflect observations and measurements made over a period of years, especially for conditions that are expected to vary seasonally (e.g.,
precipitation, windspeed, wind direction, and groundwater levels).
Describe Issue:
The LA section 1.1.1.1, ISA Summary section 1.2 and EP figure 1.3-3 identify the distance to nearest population and major population centers. They do not indicate a breakdown of the population based on designated distances from the facility, e.g.,
designated radii from the site. Information on the closest distance to sensitive population groups (e.g., schools, hospitals), see EP section 1.3, is incomplete because it does not indicate the direction. Also, the statement is unclear as to whether the distances are based on a straight line or via road. In addition, LA section 1.1.1.1 identifies critical population near the site including hospitals and schools. The list in the application appears to be incomplete and the distances appear inconsistent with straight line distances based on Google maps (e.g., the closest schools appear to be Dyllis Springs
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Elementary, 3.5 miles to the northwest, and Linden Elementary School, 4.2 miles to the northwest of the facility).
Information Needed:
Provide additional census data on the population surrounding the site including indication of the population rows (e.g., population within 0.5 miles, 1 mile, 2 miles) based on distance from the site and indicate the basis for the values utilized (e.g., 2020 U.S.
Census). Ensure that straight line distances are used and provide the relative direction from the facility to the sensitive population group (e.g., northwest, south, east).
Clarify in the application what is the closest school to the facility (e.g., Dyllis springs elementary school) and discuss what other sensitive populations groups (e.g., schools -
including pre-schools) were considered based on safety considerations (e.g., exposure risk, notifications during an event). Clarify what these criteria are for determining the sensitive populations identified. Describe the program that will be used to maintain awareness of the sensitive populations over time.
RAI-6Transportation Infrastructure:
Regulatory Basis:
This RAI uses the same regulatory basis as RAI 5.
Describe Issue:
The transportation paragraph provided at the end of LA section 1.1.1.1 is not sufficiently detailed and only lists some of the roads near the site. There are some references to the roads near the site spread throughout section 1.1.1 (e.g., access road in section 1.1.1, Poplar Creek Road in section 1.1.1.1, Renovare Boulevard in section 1.1.1.1, TN 95 in 1.1.1.1, I-40 and I-75 in 1.1.1.1), but they do not provide a complete picture of the transportation options and preferences to access the facility and minimize risk to the community due to shipments and potential events. In addition, information on other transportation options indicated by LA figure 1.1 such as airports, railroads, and water traffic, appear incomplete.
Information Needed:
Update the application documents (e.g., LA section 1.1.1.1) to provide additional information on the primary routes used to service the site including general direction and distance to major highways or interstates. Clarify whether the shipping routes to and from the site will seek to minimize travel through local population centers (e.g., Oak Ridge).
In the descriptions for the airports (e.g., LA section 1.1.1.1), describe the types of airports and if the prevailing traffic is near the facility. Also, figure 1.1 appears to show a railroad near the site that is not mentioned in the transportation paragraph. Add relevant information on the railroads near the facility, their use in shipping to the facility, and if they were analyzed as part of the ISA. LA figure 1.1 appears to show several bodies of water in the vicinity of the facility; describe if there is any commercial or recreational use of waterways near the site.
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RAI-7Uses of Ground Water:
Regulatory Basis:
This RAI uses the same regulatory basis as RAI 5.
Describe Issue:
The LA section 1.1.1.3, Hydrology, states that there are no known uses of groundwater down gradient from the site. The application does not specify how far from the site is included by the phrase down gradient. The statement appears to extend from the facility indefinitely (e.g., to the ocean).
Information Needed:
Provide the distance applicable for the statement that there are no uses of groundwater down gradient from the site and describe the basis for this statement (e.g., TRISO-X surveys, state, and local records) in the LA.
RAI-8Wastewater Disposal
Regulatory Basis:
The following information is necessary to demonstrate compliance with the regulations in 10 CFR 70.22(a)(4), The name, amount, and specifications (including the chemical and physical form and, where applicable, isotopic content) of the SNM the applicant proposes to use or produce.
Guidance on demonstrating compliance with these regulations is provided in NUREG-1520 sub-section 1.1.4.3.4 criterion (1), Descriptive Summary of Licensed Material which states in part that the application should include the types, amounts, and discharge points of waste materials discharged to the environment from the processes.
Describe Issue:
There is an apparent inconsistency between the liquid waste description in the LA section 1.1.4(5) and wastewater description in the ISA Summary section 2.6.6, Wastewater, and the ISA section 3.13.3 Process Description - Liquid Recovery and Waste. The LA section 1.1.4(5) describes processing of solutions contaminated with uranium. It also states, liquid wastes that have been handled/treated can be sampled and discharged through an inline monitor to shipping packages or conveyances for offsite disposal. This statement is unclear because conveyance to off-site disposal is not well defined and appears to include the sanitary sewer. The statement appears to contradict language in ISA Summary section 2.6.6 Wastewater, which states, The Wastewater System accepts liquid waste from systems and equipment in the non-radiological areas of the facility.
In addition, the ISA Summary section 3.13.3, Process Description - Liquid Recovery and Waste, describes the processing of liquids containing uranium but does not provide
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a clear description of how waste liquids are handled. The ISA Summary section 3.13.3 description of Recycled Water and Waste Quarantine Columns, on page 44 of 60 (adobe 93) states that wastewater must go through quarantine pumps and inline monitoring to ensure the solution is below the transfer limit. There is no description of where the water is being transferred. There is also no indication of what criteria are used to determine when a transfer is appropriate. The LA section 9.3 states that radiological liquid effluents do not occur, but there is no description of an effective monitoring program to ensure liquid effluents do not contain contaminants prior to release offsite.
Information Needed:
Update the various descriptions of liquid waste and wastewater handling throughout the LA and ISA Summary (any other) to clarify that water that may contain uranium is maintained separate from other process waters (e.g., cooling water, sanitary sewer).
Clarify in the LA (e.g., section 1.1.4 (5)) and the ISA Summary (e.g., section 3.13.3) how the transfers of liquids fit within the final disposition of the liquid wastes and effluents.
Describe the monitoring programs to be used to assess contaminants in liquid effluents prior to final disposition off-site.
RAI-9HEPA Filtration and the Facility Stack
Regulatory Basis:
The following information is necessary to demonstrate compliance with the regulations in 10 CFR 70.22(a)(7), which require the license application to include A description of equipment and facilities which will be used by the applicant to protect health and minimize danger to life or property (such as handling devices, working areas, shields, measuring and monitoring instruments, devices for the disposal of radioactive effluents and wastes, storage facilities, criticality accident alarm systems, etc.).
Guidance on one acceptable approach for demonstrating compliance with these regulations is provided in NUREG-1520 sub-section 1.1.4.3.4 criterion (1) which states in part, that the application should include the types, amounts, and discharge points of waste materials discharged to the environment from the processes.
Description of Issue:
LA section 1.1.4(6) and EP section 1.2.1, state that the facility has multiple effluent stacks. However, the description is unclear on the number and height of each stack. In addition, LA section 1.1.4(6) states that the airborne effluents are sent to the appropriate stacks, but there is no indication of which stack. In addition, the application indicates that HEPA filtration will be used as needed but is unclear on the criteria for determining when filtration is needed.
LA section 9.2.2, High-Efficiency Particulate Absolute (HEPA) Filtration states in the first sentence that HEPA filtration is used on stack effluent if it contains radiological contamination. However, the second sentence states that at least one HEPA filter will be used on all effluents. These statements appear contradictory.
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Information Needed:
Provide additional information on the stacks to be used at the facility (e.g., location, number, purpose, height). Clarify when HEPA air filtration will be used on stack effluents.
Clarify in the LA and ISA Summary when exhaust air will be passed through HEPA filtration. For example, clarify the seemingly contradictory language in the LA section 1.1.4(6) to use HEPA filtration as needed to remove radioactive particulates and chemicals from airborne effluents, and in LA section 9.2.2 that all exhaust air will pass through at least one HEPA filtration.
Describe in the LA the program for changeout, tracking, monitoring, etc. for the use of HEPA filtration and clarify the conditions under which dry scrubber filtration is utilized (e.g., LA 1.1.4(6)).
RAI-10Source and Byproduct Material:
Regulatory Basis:
The following information is necessary to demonstrate compliance with the regulations in 10 CFR 70.21(b), which states, An application for license filed pursuant to the regulations in this part will be considered also as an application for licenses authorizing other activities for which licenses are required by the Act, provided the application specifies the additional activities for which licenses are requested and complies with regulations of the Commission as to applications for such licenses. In addition, 10 CFR 70.22(a)(4) requires the application to include, The name, amount, and specifications (including the chemical and physical form and, where applicable, isotopic content) of the SNM the applicant proposes to use or produce;
Guidance on one acceptable approach for demonstrating compliance with these regulations is provided in NUREG-1520 sub-section 1.2.4.3.3 Characteristics of the Material, The application identifies the elemental name, maximum quantity, and specifications, including the chemical and physical form(s), of the licensable material that the applicant proposes to acquire, deliver, receive, possess, produce, use, transfer, or store. For such material, the specifications include the isotopic content and amount of enrichment by weight percent.
Describe Issue:
The LA section 1.2.4 states in the opening sentence that the section only applies to SNM, but it references 10 CFR parts 30 and 40 for byproduct material and source material, respectively. Since the TRISO-X facility is located in the Agreement State of Tennessee, has TRISO-X consulted with the State of Tennessee to determine if the byproduct (10 CFR 30) and source (10 CFR 40) materials can be regulated under the NRC license? Please also note the statement that SNM is regulated under 10 CFR 30 and 40 is not accurate.
Information Needed:
Please clarify if the State of Tennessee is in agreement in having the byproduct and source material licensed by the NRC. If so, please provide documentation that shows
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the States agreement to have byproduct and source material licensed by the NRC.
Ensure that only items to be regulated by the NRC license are listed in LA section 1.2.4.
RAI-11Type, Quantity, and Form of Licensed Material:
Regulatory Basis:
This RAI uses the same regulatory basis as RAI 10.
Describe Issue:
As discussed in RAI 10, typically byproduct and source material are regulated by the Agreement State. The application should include a justification for including byproduct and source material on the NRC license and confirmation of support from the Agreement State. Without this justification, materials regulated by the Agreement State should be removed from LA section 1.2.4, as follows:
The first 4 items are SNM and should be licensed by the NRC.
Item 5 should be licensed by the State.
Item 6 is strictly byproduct material (although its states licensed material) and should be rewritten similar to the following for licensing by the State:
o 2 millicuries of any byproduct material between atomic numbers 3 and 83 as sealed and unsealed radioactive sources for use in measurement and detection instruments, check sources, instrument response standards, and counting and calibration standards.
Item 7 would need to split into two parts, one to be submitted to NRC and the second to be submitted to the State since atomic numbers 84 to 96 includes byproduct, source, and SNM.
o Item 7a (NRC application) 1 microcurie of any SNM as sealed and unsealed radioactive sources for use in measurement and detection instruments, check sources, instrument response standards, and counting and calibration standards; o Item 7b (State application) 1 microcurie of any byproduct or source material between atomic numbers 84 and 95 as sealed and unsealed radioactive sources for use in measurement and detection instruments, check sources, instrument response standards, and counting and calibration standards.
Information Needed:
Provide a justification for including source and byproduct material on the NRC license and include confirmation of support from the Agreement State. Modify the type, quantity, and form of licensed material identified in the LA (e.g., section 1.2.4) to only include those items to be regulated by the NRC.
RAI-12Possession Limit for Transuranic Materials:
Regulatory Basis:
This RAI uses the same regulatory basis as RAI 10.
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Describe Issue:
LA section 1.2.4 indicates that transuranic materials will be present in the form of impurities at a specific concentration per gram. There is no basis stated for this level of concentration or indication of how this level of concentration will be verified (e.g., prior to receipt or via TRISO-X testing). There should be a discussion of how materials that exceed the limit will be handled. As currently stated, receipt of material that exceeds the threshold for transuranic materials would result in a violation of the license. There is no corresponding possession limit for transuranic materials.
Information Needed:
Provide the possession limits for transuranic materials, including the bases for the limits.
Also, describe the process that will be used to ensure compliance with these limits, i.e.
how the limits will be verified (e.g., testing program, shipping manifest), and what actions will be taken if the limits are exceeded (e.g., returned, reported, logged).
RAI-13Research and Development
Description:
Regulatory Basis:
The following information is necessary to demonstrate compliance with the regulations in 10 CFR 70.22(a)(2) which require the application to describe, The activity for which the special nuclear material is requested, or in which special nuclear material will be produced, the place at which the activity is to be performed and the general plan for carrying out the activity;
Guidance for demonstrating compliance with these regulations is provided in NUREG-1520 sub-section 1.2.4.3.4 Authorized Uses, which states, The application includes a summary, nontechnical narrative description for each activity or process in which the applicant proposes to acquire, deliver, receive, possess, produce, use, process, transfer, or store SNM. The authorized uses of SNM proposed for the facility are described and are consistent with the Atomic Energy Act of 1954, as amended. The description is consistent with more detailed process descriptions submitted as part of the ISA Summary reviewed in chapter 3 of this SRP.
Describe Issue:
The research and development process mentioned in LA section 1.2.5 (3) and ISA Summary section 3.11 is high level. The ISA Summary section 3.11 states that the research activities will be located in a separate room, but the location is unclear based on ISA Summary figure 2-1. The method for keeping research activities separate from routine activities is not described. In addition, the ISA Summary section 3.11 describes the potential for, unique safety controls and case specific IROFS, which seems to indicate the potential for new accident conditions that may require pre-approval by the NRC through the amendment process. It is unclear based on the descriptions in LA section 1.2.5 (3) and ISA Summary 3.11, what the routine operations of the experimental process will involve, if they will be analyzed for requiring or not requiring NRCs pre-approval under 10 CFR 70.72, and if they will be operated under written and approved procedures.
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Information Needed:
Describe in the LA how the research activities will have appropriate oversight, utilize written procedures, and have changes evaluated consistent with the requirements in 10 CFR 70.72. Clarify how the research activities will be maintained independent from routine activities and identify where they will be conducted (e.g., manufacturing building).
If they are conducted in the manufacturing building, clarify their location on the ISA Summary figure 2-1.
RAI-14Exemptions:
Regulatory Basis:
The following information is necessary to demonstrate compliance with the regulations in 10 CFR 70.17 Specific exemptions, section (a) states, The Commission may, upon application of any interested person or upon its own initiative, grant such exemptions from the requirements of the regulations in this part as it determines are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest.
Guidance for demonstrating compliance with these regulations is provided in NUREG-1520 sub-section 1.2.4.3.5 Special Exemptions or Special Authorizations, which states, in part, The license application clearly describes any proposed exemptions, and authorizations of an unusual nature and adequately justifies them for the NRCs consideration.
Describe Issue:
Several of the exemptions requests in the application are missing one or more of the required criteria in 10 CFR 70.17 (e.g., authorized by law, will not endanger life or property or the common defense and security, and are otherwise in the public interest).
14.A Describe Issue:
The exemption in LA section 1.3.1.2 Posting and Labeling, does not provide a basis for why the exemption is in the public interest.
14.A. Information Needed:
Provide a basis to the exemption in LA section 1.3.1.2 Posting and Labeling, for why the exemption is in the public interest.
14.B Describe Issue:
The exemption in LA section 1.3.1.5, Certain Unplanned Contamination Events, does not provide a basis for why the exemption is authorized by law.
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14.B. Information Needed:
Provided a basis to the exemption in LA section 1.3.1.5, Certain Unplanned Contamination Events, for why the exemption is authorized by law.
RAI-15Development of the Horizon Industrial Park:
Regulatory Basis:
The following information is necessary to demonstrate compliance with the regulations in 10 CFR 70.65(b)(1 and 2) which states that the integrated safety analysis summary must contain, (1) A general description of the site with emphasis on those factors that could affect safety (i.e., meteorology, seismology); (2) A general description of the facility with emphasis on those areas that could affect safety, including an identification of the controlled area boundaries.
Guidance for demonstrating compliance with these regulations is provided in NUREG-1520 section 1.3(1), Site Description, which states in part, The summary briefly describes site geography, including its location relative to prominent natural and manmade features (such as mountains, rivers, airports, population centers, schools, and commercial and manufacturing facilities). The summary also describes the site boundary and the controlled area. It also states in section 1.3 (2), The summary provides population information on the basis of the most current available census data. To the extent possible, data reflect observations and measurements made over a period of years, especially for conditions that are expected to vary seasonally (e.g., precipitation, windspeed, wind direction, and groundwater levels).
Describe Issue:
LA section 1.1.1.1, Population, Nearby Land Uses, and Transportation describes the Horizon Center Industrial Park that has multiple undeveloped plots surrounding the TRISO-X facility. The application does not discuss the potential external hazards from industrial operations surrounding the site and if they were considered in the design and layout.
Information Needed:
Describe how development of the Horizon Center Industrial Park surrounding TRISO-X would impact the facilities protection of safety, security, or protection of the environment.
Describe how future developments will be appropriately assessed in the integrated safety analysis.
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Observation 1 - Estimates of Financial Ability to Operate:
Regulatory Basis:
The following information is necessary to demonstrate compliance with the regulations in 10 CFR 70.22(a)(8) which states, Note: Where the nature of the proposed activities is such as to require consideration of the applicant's financial qualifications to engage in the proposed activities in accordance with the regulations in this chapter, the Commission may request the applicant to submit information with respect to his financial qualifications and 70.23(a)(5), Where the nature of the proposed activities is such as to require consideration by the Commission, that the applicant appears to be financially qualified to engage in the proposed activities in accordance with the regulations in this part.
Guidance for demonstrating compliance with these regulations is provided in NUREG-1520 sub-section NUREG-1520 sub-section1.2.4.3.2 Financial Qualifications, which states, Such information could include income statements for three or more of the most recent fiscal years. In addition, the information could include balance sheet forecasts for 3 or more years into the future.
Description of Issue:
The enclosure 9 section, Financial Ability to Operate the TRISO-X Fuel Fabrication Facility indicates the estimates are for 3 years but the table 3A-1 and 3A-2 appear to be for 5 years.
Information Needed:
Clarify the apparent discrepancy in the LA enclosure 9 section entitled, Financial Ability to Operate the TRISO-X Fuel Fabrication Facility, that indicates 3 years of data in attachment 3, while the tables in the attachment appear to contain 5 years of data.
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