ML24206A077

Memorandum - Summary of Meeting Held on June 27, 2024 with TRISO-X LAR Structural Meeting

ML24206A077
Person / Time
Site:	Triso-X
Issue date:	09/05/2024
From:	Matt Bartlett NRC/NMSS/DFM/FFLB
To:	Lav S NRC/NMSS/DFM/FFLB
Shared Package
ML24206A070	List: ML24206A074 ML24206A077
References
EPID L-2022-PMP-0005
Download: ML24206A077 (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:

Matthew Bartlett, Sr. Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards

SUMMARY

OF MEETING ON JUNE 27, 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 meeting to discuss the structural requests for additional information (RAIs) with TRISO-X, LLC (TRISO-X) on June 27, 2024, from 1:00 p.m. until 3:00 p.m. The purpose of the meeting was to discuss the NRC staff request for TRISO-X to supplement their responses to the RAIs issued via letter dated November 17, 2023 (Agencywide Documents Access and Management System [ADAMS]

Accession No. ML23313A110). TRISO-X provided their initial responses to the RAIs via letter dated December 15, 2023 (ML23349A208), in which TRISO-X justified their original submittal which did not resolve the RAIs. 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).

Previously, the NRC staff issued four structural RAIs (two RAIs were issued in the letter dated May 31, 2023 [ML23127A011] and two RAIs were issued in the letter dated November 17, 2023

[ML23313A110]). Three of the issues have been resolved and one item remains open. The item that remains open is RAI 2-2, Risk Category. This meeting was a continuation of the discussion of this RAI and the discussions from the structural RAI meetings held on January 24, 2024 (ML24030A847) and April 9, 2024 (ML24102A180).

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

September 5, 2024 Signed by Bartlett, Matthew on 09/05/24

OFFICIAL USE ONLY - SECURITY RELATED INFORMATION S. Lav 2

OFFICIAL USE ONLY - SECURITY RELATED INFORMATION At the end of the April 9 meeting, the NRC staff stated that the American Society of Civil Engineers (ASCE) 7-16 building risk category (BRC) III is not appropriate for a nuclear fuel cycle facility and demonstrating compliance with Title 10 of the Code of Federal Regulations (10 CFR) §70.61 and 70.64 using BRC III when the structure or internal structural components serve a safety function. This meetings discussions continued from this point. Additionally, the discussions focused on seismic design criteria. The BRC III represents an inadequate level of performance for demonstrating compliance with the regulations because it allows for a lower structural resistance to collapse (defined as target performance goal) during natural phenomena hazards events than is acceptable under 10 CFR 70.61 and 70.64. Selecting a lower structural performance that allows for degradation of safety-related systems under BRC III is unacceptable for a nuclear facility that processes, stores, and handles radioactive materials in a form and quantity that poses the potential for intermediate and high consequence events to the workers, the public, or the environment as documented in the TRISO-X integrated safety analysis.

The NRC staff reiterated that TRISO-X should use a building code that is applicable for nuclear facilities such as ASCE 43-19 or DOE-STD-1020-2016. The NRC staff is willing to utilize a risk informed approach to consider use of a commercial code ASCE-7-16 with the more robust BRC IV.

The NRC staff and TRISO-X agreed to consider holding additional discussions on this topic at a future meeting, if needed.

A list of participants is provided as Enclosure 1. Additional meeting summary information is provided in Enclosure 2 (non-public).

Docket No. 07007027

Enclosures:

1.

Participant List (public) 2.

Additional meeting summary (non-public) cc: trisox@listmgr.nrc.gov

ML24206A070; Memo ML24206A077 OFFICE NMSS/DFM/FFLB NMSS NMSS/DFM/FFLB NMSS/DFM/FFLB NAME SPoy JRudd MBartlett JGoodridge DATE Jul 31, 2024 Aug 1, 2024 Aug 1, 2024 Aug 6, 2024 OFFICE NMSS/DFM/FFLB* NMSS/DFM/FFLB NAME SLav MBartlett DATE Sep 3, 2024 Sep 5, 2024