ML23243B065
| ML23243B065 | |
| Person / Time | |
|---|---|
| Site: | 99902071 |
| Issue date: | 09/15/2023 |
| From: | Jon Greives NRC/NRR/DANU |
| To: | Chapman T X-Energy |
| Muniz A | |
| References | |
| Download: ML23243B065 (1) | |
Text
Mr. Travis Chapman Director, Reactor Licensing And Regulatory Affairs X Energy, LLC 801 Thompson Avenue Rockville, MD 20852
SUBJECT:
PREAPPLICATION READINESS ASSESSMENT PLAN - DOW CHEMICAL COMPANY AND X ENERGY, LLC CONSTRUCTION PERMIT APPLICATION
Dear Mr. Chapman:
By letter dated July 14, 2023 (Agencywide Documents Access and Management System Package Accession No. ML23195A107), the Dow Chemical Company (Dow) and the X-energy Reactor Company, LLC (X-energy) requested the U.S. Nuclear Regulatory Commission (NRC) staff to conduct a preapplication readiness assessment of the draft preliminary safety analysis report (PSAR) portion of its planned application for a construction permit in accordance with Title 10 Code of Federal Regulations (10 CFR), Part 50. The NRC staffs preapplication readiness assessment plan is attached for your information.
The NRC staff notes that a readiness assessment is not intended to determine whether the eventual application is acceptable for docketing, as would be required by 10 CFR, Part 2 for a tendered application. Rather, the readiness assessment will allow the NRC staff to understand the level of detail in the draft PSAR and provide feedback to X-energy on major issues or information gaps between the draft PSAR and the technical content required to be included in the application submittal, as set forth in 10 CFR 50.34.
If you have any questions regarding this matter, please contact Adrian Muniz, Senior Project Manager, at (301) 415-4093 or Adrian.Muniz@nrc.gov.
Sincerely, Jonathan Greives, Deputy Division Director Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Project No.: 99902071 cc: Distribution via GovDelivery - X-Energy Xe-100 September 15, 2023 Signed by Greives, Jonathan on 09/15/23
ML23243B065 NRR-106 OFFICE NRR/DANU/UAL2:PM NRR/DANU/UAL2:LA NRR/DANU/UTB1:BC NAME AMuniz CSmith GOberson DATE 9/1/2023 9/6/2023 9/7/2023 OFFICE NRR/DANU/UAL2:BC NRR/DANU:DD NAME MWentzel JGreives DATE 9/15/2023 9/15/2023
Enclosure PREAPPLICATION READINESS ASSESSMENT PLAN OF THE DRAFT PRELIMINARY SAFETY ANALYSIS REPORT PORTION OF THE CONSTRUCTION PERMIT APPLICATION FOR THE DOW SITE LOCATION:
X-energy Electronic Reading Room (eRR)
PURPOSE:
The Dow Chemical Company (Dow) and the X-energy Reactor Company, LLC (X-energy) have voluntarily agreed to engage with the U.S. Nuclear Regulatory Commission (NRC) staff in a preapplication readiness assessment (hereinafter readiness assessment) of the draft preliminary safety analysis report (PSAR) portion of the application for a construction permit (CP) for the Dow site in Seadrift, Texas, in accordance with Title 10 Code of Federal Regulations (10 CFR), Part 50.
The readiness assessment is not intended to determine whether the eventual application is acceptable for docketing, as would be required by 10 CFR, Part 2 for a tendered application.
Rather, the NRC staffs observations from the readiness assessment will inform Dow and X-energy in finalizing the application and will assist the NRC staff in determining the resources needed for the application review. During the readiness assessment, the staff will:
identify information gaps between the draft application and the technical content required in the application submitted to the NRC, as set forth in 10 CFR 50.34,
identify major technical or policy issues that may adversely impact the docketing or technical review of the application, and
become familiar with the application, particularly in areas where Dow and X-energy are proposing new concepts or novel design features.
BACKGROUND:
By letter dated July 14, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23195A107), Dow and X-energy requested that the NRC staff conduct a preapplication readiness assessment of the draft PSAR and Part V, Non-Applicabilities and Requested Exemptions, of the planned CP application. In an email dated August 15, 2023 (ML23237B426), X-energy described a phased readiness assessment of certain chapters and sections of the draft PSAR.
READINESS ASSESSMENT SCOPE AND SCHEDULE:
The X-energy email dated August 15, 2023, identifies portions of the draft PSAR for the NRC staffs readiness assessment review. X-energy requested that the NRC staff conduct a readiness assessment according to the following schedule:
Phase 1: October 2 - November 3, 2023 (Chapter 1, portions of Chapter 3, Chapter 4, Chapter 5, portions of Chapter 6, portions of Chapter 7, Chapter 10, Chapter 11, Chapter 12, Part V of the CP application)
Phase 2: November 3 - December 15, 2023 (remaining sections of Chapters 3, 6, and 7, and Chapters 8 and 9)
Per Dow/X-energys request, the Environmental Report and Chapter 2 of the PSAR are excluded from this readiness assessment. In its email, X-energy proposed that the NRC staff would need 300 hours0.00347 days <br />0.0833 hours <br />4.960317e-4 weeks <br />1.1415e-4 months <br /> to complete its assessment. However, based on X-energys proposed scope, the NRC staff estimates that this readiness assessment will require approximately 450 staff hours to complete. The staff may, during the course of the assessment, propose adding additional resources to the review if there is a determination that additional benefit will be had by all participants. Although the staff believes that there is sufficient time and resources in place to accomplish the objectives of the readiness assessment described above, it is possible that there may be issues with the application that will not become fully apparent given the defined scope and schedule.
In accordance with the proposed schedule, X-energy will upload the relevant information for each phase of the readiness assessment on the eRR no later than the entrance meeting date for that phase of the readiness assessment. During the entrance meeting for each phase, Dow and X-energy will provide a presentation to describe the relevant material that will be assessed by the NRC staff. Throughout the readiness assessment, the NRC staff, Dow, and X-energy subject matter experts will engage, as necessary, to discuss questions that arise from the NRC staffs assessment.
READINESS ASSESSMENT TEAM:
The following table identifies the NRC resources for each readiness assessment area. However, it should be noted that during the readiness assessment, the NRC staff may determine that additional resources are needed to complete the readiness assessment. The NRC staff will communicate the need and impact on resources to Dow and X-energy accordingly.
Phase 1:
Review Area NRC Resources PSAR Chapter 1, General Plant and Site Description PSAR Chapter 3, Licensing Basis Events [including Methodologies and Analysis]
(Sections 3.2, 3.3, 3.7, 3.12, 3.13)
PSAR Chapter 4, Integrated Evaluations Core Team and subject matter experts1 on selected areas 1 Expected expertise areas may include human factors, instrumentation and control, electrical, specific operational programs, quality assurance, fire protection, external hazards (e.g., seismic), emergency planning, and siting considerations.
PSAR Chapter 5, Safety Functions, Design Criteria, and SSC Classification PSAR Chapter 6, Safety-Related SSC Criteria and Capabilities (Sections 6.1-6.3)
PSAR Chapter 7, NSRST SSC Criteria and Capabilities (Sections 7.1-7.2)
PSAR Chapter 10, Control of Occupational and Public Dose Source Term and Accident Analysis staff PSAR Chapter 11, Conduct of Operations Operator Licensing and Human Factors staff PSAR Chapter 12, Initial Startup and Test Programs Part V, Non-Applicabilities and Requested Exemptions Core Team with subject matter experts on selected areas Phase 2:
Review Area NRC Resources PSAR Chapter 3 (Remaining Sections)
PSAR Chapter 6 (Remaining Sections)
PSAR Chapter 7 (Remaining Sections)
PSAR Chapter 8, Plant Programs Core Team with subject matter experts on selected areas PSAR Chapter 9, Radioactive Waste Management Source Term and Accident Analysis staff LOGISTICS:
The NRC staff plans to conduct the readiness assessment on X-energys eRR. A virtual entrance meeting to start Phase 1 of the readiness assessment is scheduled for October 2, 2023. The NRC staff will access the readiness assessment documents in accordance with the X-energy Online Reference Portal Information Access Agreement, dated December 12, 2022 (ML23011A328). The NRC staff will conduct exit meetings after completion of readiness assessments of each chapter or section, as appropriate.
NRC STAFFS APPROACH TO CONDUCTING THE READINESS ASSESSMENT:
The readiness assessment will be conducted in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-116, Preapplication Readiness Assessment, for the readiness assessment, with the understanding that:
Dow/X-energy have voluntarily requested a readiness assessment be performed by the NRC staff, the NRC staff will control the readiness assessment approach and participation and will specify appropriate charging codes for technical reviewers,
the NRC staff will implement the assessment in an integrated approach led by the core team, consistent with the chapter format under the draft Advanced Reactor Content of Application Project (ARCAP) guidance (ML22048A520) and draft Technology Inclusive Content of Application Project (TICAP) guidance (ML23194A194)2,
Dow/X-energy will provide tailored presentations and discussions to the NRC staff, as needed, and
the NRC staff will implement timely/real-time problem/issue identification.
COMMUNICATION OF THE READINESS ASSESSMENT OBSERVATIONS:
The NRC staff will share any technical concerns or major information gaps with X-energy that are identified during the readiness assessment as soon as they are identified. At the completion of each phase, the NRC staff will provide preliminary observations to X-energy. Additionally, within 45 calendar days after the completion of the readiness assessment, the NRC staff will issue a publicly available report that will summarize the NRC staffs observations and feedback for all phases of the readiness assessment.
If it is necessary to include proprietary information in the readiness assessment report, the NRC staff will issue a proprietary version of the readiness assessment report. The NRC staffs expectation is that Dow/X-energy will consider addressing the readiness assessment observations before submitting the CP application including the PSAR. The staff will take into consideration the results of the readiness assessment when developing the resource and schedule estimates for the review of the CP application.
2 The draft ARCAP guidance documents were issued for public comment on May 25, 2023, and the comment period for these draft guidance documents ended on August 10, 2023. Revision 1 to the TICAP guidance document was publicly released on September 1, 2023. The NRC staff is assessing comments that it received on the ARCAP guidance documents, TICAP revision 0, and will address as appropriate, comments on TICAP Revision 1. Because the final version of these documents will not be available at the time of the readiness assessment the NRC staff intends to use the best available draft guidance to support the readiness assessment.