ML24102A181

Cover Letter - Summary of Meeting on April 9, 2024, with TRISO-X LLC, to Discuss Supplement Responses to Structural Programmatic Requests for Additional Information

ML24102A181
Person / Time
Site:	Triso-X
Issue date:	04/24/2024
From:	Matt Bartlett NRC/NMSS/DFM/FFLB
To:	Lav S NRC/NMSS/DFM/FFLB
Shared Package
ML24102A180	List: ML24102A181 ML24102A182
References
EPID L-2022-PMP-0005
Download: ML24102A181 (1)

Text

OFFICIAL USE ONLY - SECURITY RELATED INFORMATION OFFICIAL USE ONLY - SECURITY RELATED INFORMATION UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 MEMORANDUM TO:

Samantha Lav, Chief Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards FROM:

Matt Bartlett, Senior Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards

SUMMARY

OF MEETING ON APRIL 9, 2024, WITH TRISO-X LLC, TO DISCUSS SUPPLEMENT FOR RESPONSES TO STRUCTURAL PROGRAMMATIC REQUESTS FOR ADDITIONAL INFORMATION, (ENTERPRISE PROJECT IDENTIFIER L-2022-PMP-0005)

The U.S. Nuclear Regulatory Commission (NRC) hosted a closed Microsoft Teams meetings with TRISO-X, LLC (TRISO-X) on April 9, 2024, from 8:00 a.m. until 10:00 a.m. The purpose of the meeting was to discuss the NRC staff request for TRISO-X to supplement their responses to the requests for additional information (RAIs) related to the structural portion of the review that was issued via letter dated November 17, 2023 (Agencywide Documents Access and Management System Accession No. ML23313A110). TRISO-X provided their initial responses to the RAIs via letter dated December 15, 2023 (ML23349A208). TRISO-X provided justification for their design basis which does not resolve the RAI. The TRISO-X original application was received April 5, 2022 (ML22101A200) and was supplemented by letters dated October 13, 2022 (ML22286A144), November 4, 2022 (ML22308A251) and February 29, 2024 (ML24060A239).

TRISO-Xs response was reviewed by the NRC staff and the issue raised in RAI 2 of Set 6, that relates to how they are applying their choice of building code requires additional information for resolution. A draft of the NRC staff concerns was shared with TRISO-X prior to the meeting, see enclosure 3. During the meeting, TRISO-X presented slides to provide additional context and justification of the design basis. TRISO-X agreed to upload the slides to the TRISO-X document portal after the meeting.

CONTACT: Matt Bartlett, NMSS/DFM 301-415-7154 Enclosures 2 and 3 transmitted herewith contain Security-Related Information. When separated from Enclosures 2 and 3, this document and are decontrolled.

April 24, 2024 Signed by Bartlett, Matthew on 04/24/24

OFFICIAL USE ONLY - SECURITY RELATED INFORMATION S. Lav 2

OFFICIAL USE ONLY - SECURITY RELATED INFORMATION The NRC staff stated that the American Society of Civil Engineers (ASCE) 7-16 building risk category (RC) III is not sufficiently robust to demonstrate compliance with the basic design criteria in 10 CFR 70.64 and the performance criteria in 10 CFR 70.61. The building code and design basis criteria that TRISO-X uses for their structural design must account for the nuclear hazards at these facilities, which include numerous radiological, criticality, chemical, fire, etc.

hazards for workers and the public. The NRC staff explained that the agency has consistently required structural design basis criteria to account for the risks associated with nuclear hazards to demonstrate reasonable assurance for meeting 10 CFR 70.61 and 70.64 in order to protect against natural phenomena hazard events. For example, the NRC staff provided the following representative sample of fuel cycle facilities that utilize ASCE 7 with building Risk Category IV or equivalent: Global Nuclear Fuels - Americas, LLC (ML17261A082), Westinghouse Columbia Fuel Fabrication, LLC (ML16231A303), Louisiana Energy Services, LLC (ML091240479),

Nuclear Fuel Services, Inc. (ML17191A640, page 5), and the proposed General Electric-Hitachi Global Laser Enrichment LLC (ML11230A115).

The NRC staff provided examples of acceptable building codes or standards that can be used by nuclear fuel cycle facilities including ASCE 43, Seismic Design Criteria for Structures, Systems, and Components in Nuclear Facilities (ASCE/SEI 43-05), and DOE-STD-1020, DOE-STD-1020-2016, Natural Phenomena Hazards Analysis and Design Criteria for DOE Facilities, etc. TRISO-X stated their operations are more consistent with a chemical industrial facility, believe a commercial grade code should be acceptable, and asked if they could use the ASCE-7 commercial code for TRISO-X. The NRC staff stated that although ASCE-7 is a commercial grade code that does not include nuclear considerations, it can be used with a building risk category IV for structures designated as Essential Facilities. This designation provides the additional robustness in the design to support reasonable assurance to protect against exposures to hazardous materials during and after occurrences of natural phenomena hazards for the workers and the public. The NRC staff and TRISO-X agreed to consider holding additional discussions on this topic, if needed.

A list of participants is provided as an Enclosure 1.

Docket No. 07007027

Enclosures:

1. Participant List (public)

2. Additional meeting summary (non-public)

3. NRC Staff Perspective Regarding TRISO-X Use of Structural Building Codes (non-public) cc: trisox@listmgr.nrc.gov

ML24102A180 (pkg); ML24102A181 (ltr);

ML24102A182 (encl 1); ML24102A183 (encl 2, non-public);

ML24102A184 (encl 3, non-public)

OFFICE NMSS/DFM/FFLB NMSS/DFM/FFLB NMSS/DFM/FFLB NAME JRudd SPoy MBartlett DATE 4/11/2024 4/15/2024 4/15/2024 OFFICE NMSS/DFM/FFLB NMSS/DFM/FFLB NMSS/DFM/FFLB NAME JGoodridge SLav MBartlett DATE 4/16/2024 4/19/2024 4/24/2024