ML24115A245

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Enclosure 1 - RAI Status Update for the Safety and Safeguards Requests for Additional Information for the TRISO-X License Application
ML24115A245
Person / Time
Site: Triso-X
Issue date: 05/08/2024
From: Matt Bartlett
NRC/NMSS/DFM/FFLB
To: Wheeler J
Triso-X
Shared Package
ML24089A200 List:
References
EPID L-2022-NEW-0005
Download: ML24115A245 (9)
v • d • e


Text

Status of the Safety and Safeguards Requests for Additional Information as of April 2024 for the TRISO-X License Application Review

Table of Contents BACKGROUND:...........................................................................................................................1 GENERAL INFORMATION:.........................................................................................................1 GEOTECHNICAL:........................................................................................................................2 HYDROLOGY:..............................................................................................................................2 STRUCTURAL:.............................................................................................................................3 ORGANIZATION AND ADMINISTRATION:................................................................................3 INTEGRATED SAFETY ANALYSIS

SUMMARY

........................................................................4 HUMAN FACTORS:.....................................................................................................................5 RADIATION PROTECTION:.........................................................................................................5 NUCLEAR CRITICALITY SAFETY:.............................................................................................5 CHEMICAL PROCESS SAFETY:................................................................................................6 ELECTRICAL/DIGITAL INSTRUMENTATION AND CONTROL:................................................6 FIRE SAFETY:..............................................................................................................................6 EMERGENCY MANAGEMENT:...................................................................................................6 ENVIRONMENTAL PROTECTION:.............................................................................................7 DECOMMISSIONING/FINANICAL ASSURANCE/FINANCIAL QUALIFICATION:....................7 MANAGEMENT MEASURES AND QUALITY ASSURANCE:....................................................7 MATERIAL CONTROL AND ACCOUNTING:..............................................................................7 SECURITY - PHYSICAL PROTECTION:....................................................................................8 SECURITY - TRANSPORTATION:.............................................................................................8 ENVIRONMENTAL REVIEW - NEPA:.........................................................................................8

Enclosure 1

Background:

This document provides a list of the Requests for Additional Information (RAI) grouped by technical area that have been issued as of May 1, 2024, by the U.S. Nuclear Regulatory Commission (NRC) staff to support the TRISO-X, LLC (TRISO-X) license application review.

The NRC staff notes that the in-depth reviews for Integrated Safety Analysis (ISA) Summary, Criticality, Structural, Management Measures and Quality Assurance, and Electrical, Instrumentation and Control are pending. In addition, the NRC staff anticipates issuing a second round of RAIs to support the updated license application TRISO-X plans to submit in December 2024 to support a new source of high-assay low enriched uranium (HALEU) feedstock and to resolve the existing RAIs.

GENERAL INFORMATION:

RAI Information:

RAIs Resolved: RAI-1, 3, 4, 6, 7, 8, 12, and 15 RAIs Open: RAI-2, 5, 9, 10, 11, 13, and 14

  • RAI Nearby Roads, Trails, and Structures: TRISO-X needs to include the environmental report reference in the license application that was provided in the RAI response.
  • RAI Population Near the Site: TRISO-X needs to include the census data that was provided in the RAI response into the safety analysis report directly or by reference to the environmental report.
  • RAI High Efficiency Particulate Air Filtration and the Facility Stack: Dry scrubber filtration is referenced in the RAI response as being addressed in the ISA Summary Section 3.5, but some clarification should be added to the application.
  • RAI-10 and 11 - Source and Byproduct Material: TRISO-X needs to clarify in the application that the byproduct and source material will be licensed by the State of Tennessee.
  • RAI Research and Development

Description:

Clarify that the scope of the research and development is focused on fuel fabrication activities related to existing operations (e.g., does not include spent fuel evaluation). This language needs to be added to the license application documents (e.g., license application 1.2.4 and ISA Summary 3.11).

  • RAI See parts A and B.

A. Exemptions: Incorporate the information provided in the RAI response into the license application. In addition, please clarify in the application how a reduction of cost provided in response to the RAI would be a benefit to the public.

B. Exemptions: Incorporate the RAI response on why the exemption is acceptable by law into the license application.

1 GEOTECHNICAL:

RAI Information:

  • TRISO-X response received November 8, 2023 ( ML23312A338)

RAIs Resolved: RAI-1, 2, 4, and 6

RAIs Open: RAI-3 and 5

  • RAI Foundation of the Process Building: (Bearing Capacity and Settlement of the process building (PB) foundation) - TRISO-X needs to provide the requested specific details [REDACTED]
  • RAI Differential Settlement Across the Process Building (Differential Settlement):

TRISO-X needs to summarize the results of an assessment showing that the foundation design achieves the goal of acceptable differential settlement throughout the Process Building.

[REDACTED]

HYDROLOGY:

RAI Information:

  • TRISO-X response received November 8, 2023, ( ML23312A338)

RAIs Resolved: RAI-1, 2, 5, and 6

RAIs Open: RAI-3 and 4

  • RAI Revise the Stormwater Pollution Protection Plan (SWPPP) Table 2: The TRISO-X Response to RAI-3 states that, Depending on the condition of the depressed sinkhole area, during some storm events when the sinkhole depression is full, water will overflow to an unnamed tributary of East Fork Poplar Creek. TRISO-X needs to provide sources/references documenting the unnamed tributary of the East Fork Poplar Creek into which water will flow if the sinkhole depression is full during some storm events.
  • RAI Volumetric Runoff Rate: The TRISO-X Response to RAI-3 provided Table 1, Comparison of Pre-and Post-developed Condition Results. The runoff volume (acre-feet) for both storm events analyzed showed greater discharge for the Allowable Pre-Developed Discharge than the Post-Developed Discharge.

Clarification is needed on how the calculations were performed for the runoff volumes in Table 1 since both the SWPPP, and TRISO-X response to RAI ER-GW-2, state that the resulting increase in overall impermeability produces an increase in runoff volume. NRC staff is requesting information on how the annual surface water runoff collected in the Horizon Center Sites (HCS) subsurface and surface drainage system will be discharged outside of the HCS boundaries. For example, NRC staff is interested in estimated annual volumes: i) of water flowing into the forebay designed to collect the runoff from the entire permanent site areas, ii) of water infiltrating

2 downward from the forebay area and percolating to the groundwater, ii) of water flowing from the forebay into the main Section of the detention basin, iv) of water discharging from the main Section of the detention basin via the West Outlet, and v) of water leaving the boundary of the HCS by any other means (e.g.,

evapotranspiration, etc.).

  • RAI Runoff Water Quality: The TRISO-X Response to RAI-4 provided additional information on water quality. The technical basis given as to why all constituents within stormwater runoff are expected to be at or below the allowable limits was water quality treatment that allows sediment and site generated total suspended solids (TSS) to settle at the bottom of the forebay. Although this may be true for the heavier than water contaminants (e.g., metals, etc.), typical parking-lot contaminants such as oil, grease, other petroleum products generally float within the water and therefore may not settle at the bottom of detention ponds. Other potential contaminants (e.g., antifreeze) may dissolve into solution and also not settle out.

STRUCTURAL:

RAI Information:

RAIs Resolved: RAI-1.1, 1.2, and 2.1

RAIs Open: RAI-2.2

  • RAI-2.2 - Building Risk Category - Supplement

ORGANIZATION AND ADMINISTRATION:

RAI Information:

  • TRISO-X response received August 25, 2023, ( ML23237B484)

RAIs Resolved: RAI-2, 4, and 6

RAIs Open: RAI-1, 3, 5, 7, and 8

  • RAI Management Hierarchy: The current application does not provide sufficient description of the management structure to be understood by someone unfamiliar with the planned structure. TRISO-X identified one plant manager and then several management teams (see license application Section 2.2). There is insufficient information on of how these teams function or if there is a hierarchy for making decisions. It is also unclear if there are four teams based on figure 2.2 or if the there is one team with four members.

3 Also, TRISO-X needs to clarify the hierarchy relationship between the various management teams and positions they identify in the application (e.g., plant manager, discipline, function, analyst, individual(s) responsible).

  • RAI-3/5 - Role of Regulatory Affairs on the Screening/Safety Committee: The RAI response provides sufficient information on the role of the Regulatory Affairs manager in the Screening Committee, however the description of who serves on the safety review committee and their required qualifications in license application Section 2.4 is difficult to follow (e.g., members have to be qualified as directors, the Director has to be qualified as the regulatory affairs function, and all have to have completed training in incident investigation methods).
  • RAI Experience for the Manufacturing Function: The added language provided in the RAI response includes the statement, When substituting type of work experience, two years of non-nuclear experience is equivalent to one year of nuclear experience. This statement appears inappropriate for certain positions involving safety or security, (e.g., two years of years business experience would not equate to one year of experience in regulatory affairs, radiation protection, criticality, security, etc.) This sentence should be removed or clarified with additional criteria to provide reasonable assurance that staff are appropriately qualified for their positions.
  • RAI Transition to Operations: The response is mostly acceptable except that TRISO-X should consider adding information on how problems will be dispositioned and tracked to resolution (e.g., reported to a corrective action program and confirmed as resolved prior to proceeding to operations).

INTEGRATED SAFETY ANALYSIS

SUMMARY

RAI Information:

  • TRISO-X responses received October 12, 2023 ( ML23285A344)

RAIs Resolved: None

RAIs Open: RAI-1, 2, 3, 4, 5, 6, 7, 8, 9, and 10

  • RAI Definition of Unlikely for Application of the Double Contingency Principle (DCP) - Supplement
  • RAI Definition of Credible/Not Credible Event - Supplement
  • RAI Inherently Safe Active Engineered Control - Supplement
  • RAI Consequences Requiring Evaluation - Supplement
  • RAI Definitions of Highly Unlikely and Unlikely - Supplement
  • RAI Likelihood Index Score Method, Failure Probability Versus Frequency - Supplement
  • RAI Likelihood Index Score Method for Initiating and Enabling Events - Supplement
  • RAI Likelihood Index Score Method for IROFS - Supplement
  • RAI Critical Non-structural Components - Supplement

4

  • RA Likelihood Definitions and 10 CFR 70.61 compliance evaluations for Natural Phenomena Hazards

HUMAN FACTORS:

RAI Information:

  • Human factors NRC set 1, issued 1 programmatic 1 RAI on May 31, 2023 (ML23127A011)

RAIs Resolved: RAI-1

RAIs Open: None

RADIATION PROTECTION:

RAI Information:

  • TRISO-X response received December 9, 2023 ( ML23343A002)

RAIs Resolved: RAI-1, 2, 3, 4, 5, 6, 7, 8, 9, and 10

RAIs Open: None

NUCLEAR CRITICALITY SAFETY:

RAI Information:

  • Under development.

RAIs Resolved: To Be Determined

RAIs Open: To Be Determined

1 The term programmatic RAIs is used to indicate methodology items that needs to be resolved before the detailed technical review can proceed.

5 CHEMICAL PROCESS SAFETY:

RAI Information:

  • TRISO-X response received December 9, 2023, ( ML23343A002)

RAIs Resolved: RAI-1, 2, 3, 4, 5, 6, 7, 8, 10 and 11

RAIs Open: RAI-9

  • RAI Low Estimates of Indoor Chemical Concentration, Methodology: TRISO-X made general commitments about analysis of indoor chemical exposure events. The staff will have to review the updated chemical accident sequences and indoor chemical exposure consequence estimates to determine if the results are reasonable and provide reasonable assurance that the proposed operations will meet the chemical safety performance requirements of 10 CFR 70.61.

ELECTRICAL/DIGITAL INSTRUMENTATION AND CONTROL:

RAI Information:

  • Under development.

RAIs Resolved: To Be Determined

RAIs Open: To Be Determined

FIRE SAFETY:

RAI Information:

  • TRISO-X response received December 15, 2023 ( ML23349A208)

RAIs Resolved: RAI-1, 2, 3, 4, 5, 6, 7, and 8

RAIs Open: None

EMERGENCY MANAGEMENT:

RAI Information:

  • TRISO-X response received August 25, 2023 (ML23237B484)

RAIs Resolved: RAI-1, 2, and 3

RAIs Open: None

6 ENVIRONMENTAL PROTECTION:

RAI Information:

  • NRC Set 7, issued 4 RAIS on February 26, 2024 (ML23321A041)
  • TRISO-X response received March 27, 2024 ( ML24087A235)

RAIs Resolved: RAI-1, 2, 3 and 4

RAIs Open: None

DECOMMISSIONING/FINANICAL ASSURANCE/FINANCIAL QUALIFICATION:

RAI Information:

  • None at this time.

MANAGEMENT MEASURES AND QUALITY ASSURANCE:

RAI Information:

RAIs Resolved: RAI-3 and 5

RAIs Open: RAI-1, 2, and 4

  • RAI 1 Construction Qualifications - Supplement
  • RAI 1 Quality Standards for IROFS - Supplement
  • RAI 1 Quality Assurance Elements for IROFS - Supplement

MATERIAL CONTROL AND ACCOUNTING:

RAI Information:

  • TRISO-X response received December 15, 2023 ( ML23349A208)

RAIs Resolved: RAI-2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 13, 14, and 15.

RAIs Open: 1 and 12

  • RAI Checks and Balances - In the response to RAI-1, the words unauthorized diversion is used. This implies the existence of such a thing as an authorized diversion. The reviewer needs clarification on this term.
  • RAI Item Storage Areas and Controls - The information provided by TRISO-X in Section 8.3 of the Fundamental Nuclear Material Control Plan (FNMCP) needs to provide additional information regarding storage controls used to ensure the validity of prior measurements.

7

  • Observation - Shipper-Receiver Difference Exemptions - Throughout Section 4.0 of the draft FNMCP Rev 2, references to the Segmented Gamma Scanner (SGS) measurement system have been deleted. However, in Table 9 on page 46, the SGS system is still listed. If TRISO-X intends to delete, please remove reference to the SGS measurement system, otherwise, explain why a reference to the system is included in Table 9.

SECURITY - PHYSICAL PROTECTION:

RAI Information:

  • TRISO-X response received October 12, 2023 (ML23285A344)

RAIs Resolved: RAI-1, 2, 3, 4, 5, 6, 7, 8, 9, 10, and 11

RAIs Open: None

SECURITY - TRANSPORTATION:

RAI Information:

  • TRISO-X response received October 12, 2023 (ML23285A344)

RAIs Resolved: RAI-1

RAIs Open: None

ENVIRONMENTAL REVIEW - NEPA:

RAI Information:

and Set 4 on April 4, 2024 (ML24095A341).

RAIs Resolved: RAI-1-37 Resolved:

RAIs Open: RAI 38

  • The information provided by TRISO-X did not include the estimated volumes of non-hazardous, nonindustrial municipal waste generated during operations.

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