ML24344A100
| ML24344A100 | |
| Person / Time | |
|---|---|
| Site: | 99902117 |
| Issue date: | 12/19/2024 |
| From: | Jeremy Bowen NRC/NRR/DANU |
| To: | Vaughn S X-Energy |
| Ondra Dukes, NRR/DANU | |
| Shared Package | |
| ML24344A095:ML24344!095 | List: |
| References | |
| Download: ML24344A100 (1) | |
Text
Mr. Stephen Vaughn Licensing Manager, Project Long Mott X Energy, LLC.
801 Thompson Avenue Rockville, MD 20852
SUBJECT:
FOCUSED PREAPPLICATION READINESS ASSESSMENT REPORT OF PROJECT LONG MOTT XE-100 PRELIMINARY SAFETY ANALYSIS REPORT
Dear Mr. Vaughn:
The U.S. Nuclear Regulatory Commission (NRC) staff, per requests from the Dow Chemical Company (Dow) and X Energy, LLC (X-energy), have completed two preapplication readiness assessments of the Project Long Mott draft preliminary safety analysis report (PSAR). These readiness assessments support the planned construction permit (CP) application to build a four unit, Xe-100 nuclear power facility at the Dow Seadrift Site in Calhoun County, Texas. The initial readiness assessment was requested on July 14, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. (ML23195A107), and the associated NRC staff report was issued on February 7, 2024 (ML24011A071).
Dow and X-energy requested the second readiness assessment in a letter dated August 15, 2024 (ML24228A282), which identified the scope and specific sections of the draft PSAR content to be evaluated (hereinafter referred to as focused readiness assessment). This focused readiness assessment was limited to: (1) portions of the draft PSAR related to Xe-100 design changes made after the completion of the previous readiness assessment, and (2) portions of the draft PSAR revised by X-energy to address some of the Category A observations from the previous readiness assessment (ML24011A071). The NRC staff notes that the design changes impact other PSAR sections that were not included within the scope of this readiness assessment. In addition, the NRC staff notes that there were additional observations from the previous readiness assessment for which additional or revised content was not included in this focused readiness assessment. The NRC staff issued the associated readiness assessment plan on August 26, 2024 (ML24250A183), with a targeted completion of the week of September 27, 2024.
The goals for the focused readiness assessment were: (1) identification of information gaps between the draft PSAR and the technical content required for the final application submitted to the NRC staff, as set forth in Title 10 of the Code of Federal Regulations (10 CFR) section 50.34, Contents of applications; general information, (2) identification of technical or regulatory issues that may complicate the acceptance or technical reviews of the application, and (3) familiarity with the PSAR, particularly in areas where Dow and X-energy are proposing new concepts or novel design features.
December 19, 2024
S. Vaughn The NRC staff conducted the readiness assessment via X-energys Electronic Reading Room (eRR) in accordance with NRCs Office Instruction LIC-116, Pre-application Readiness Assessment (ML20104B698). After conducting an initial assessment of the information provided by X-energy in the eRR, the NRC staff identified that some of the files did not contain PSAR content but rather descriptions of approaches for PSAR development. After its discussion with the NRC staff, X-energy requested, in an email dated September 16, 2024 (ML24277A144), that these files be removed from the scope of this focused readiness assessment for NRC feedback. This allowed the NRC staff to commence their assessment of the information and engage in a series of meetings to discuss draft questions and observations beginning on September 24, 2024. In follow-up emails dated October 22, 2024 (ML24298A222),
and October 25, 2024 (ML24299A224), X-energy requested that the NRC staff reassess certain PSAR sections (section 8.1, Quality Assurance (QA), section 8.5, Environmental Qualification Program, and section 7.3.1.1.1, Shield Structure Functions and Design Criteria) where additional information was provided by X-energy. The NRC staff held the final meeting to discuss the draft PSAR observations on November 7, 2024.
The enclosed table (ML24344A099) provides the NRC staffs observations of the selected portions of the draft PSAR provided by Dow and X-energy in the eRR during the focused readiness assessment. The NRC staff categorized each of the observations to assist Dow and X-energy in understanding the potential impact. Each observation was assigned one of three categories. Category A, PSAR Gap, includes information that the NRC staff expects will be required to meet the information requirements in 10 CFR 50.34(a) but was not provided in the draft PSAR. Category B, Items Requiring Additional Information, includes the NRC staffs observations regarding items provided in the draft PSAR, but for which further justification or additional information will be needed to support a regulatory finding or which could impact the schedule and resources estimate for the NRC staffs review. Category C, Other, includes other observations that should be addressed or considered by X-energy to support the clarity or quality of the application. If unaddressed, together, they could negatively impact the NRC staffs review of the application, including resources and schedule.
In addition to the readiness assessments, the NRC staff engaged with Dow and X-energy in a series of meetings earlier this year to discuss certain Xe-100 design changes (ML24303A143).
Some of the PSAR sections impacted by these design changes were not included by Dow and X-energy within the scope of this focused readiness assessment. Dow and X-energy should consider the NRC staffs feedback associated with PSAR sections impacted by the design changes in development of the CP application. The NRC staff also notes that neither PSAR chapter 2, Site Characteristics, nor the Environmental Report were included within the scope of either readiness assessment.
The NRC staff recommends that Dow and X-energy consider and address the NRC staffs observations across all interactions when finalizing the PSAR. Addressing this feedback would enhance the CP application and support the NRCs ability to docket the application and establish a timely review schedule. Based on the scope of the interactions to date, additional items may be identified during the acceptance review that were not identified during the readiness assessment. The NRC staff remains committed to working with X-energy in ongoing and future licensing activities and encourages X-energy to continue engaging on topics deemed significant or where additional clarity is needed to support the development of a quality CP application.
S. Vaughn If you have any questions, please contact Adrian Muniz, Senior Project Manager, at 301-415-4039 or via email at Adrian.Muniz@nrc.gov.
Sincerely, Jeremy Bowen, Director Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Project No.: 99902117
Enclosure:
As stated cc: Distribution via X-Energy Xe-100 JMaddocks@x-energy.com Signed by Bowen, Jeremy on 12/19/24
Package: ML24344A095 Letter: ML24344A100
Enclosure:
ML24344A099 NRR-106 OFFICE NRR/DANU/UAL2:PM NRR/DANU/UAL2:PM NRR/DANU/UAL2:LA NAME ODukes AMuniz CSmith DATE 12/10/2024 12/10/2024 12/12/2024 OFFICE NRR/DANU/UTB1:BC NRR/DANU/UAL2:BC NRR/DANU:D NAME GOberson JSegala JBowen DATE 12/16/2024 12/16/2024 12/19/2024