ML25031A450

Cover Letter and Enclosure 1 (Affidavit) - Supplemental Information for TRISO-X Fuel Fabrication Facility License Application

ML25031A450
Person / Time
Site:	Triso-X
Issue date:	01/31/2025
From:	Wheeler J Triso-X
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
Shared Package
ML25031A449	List: ML25031A450 ML25031A452 ML25031A457 ML25031A458 ML25031A459 ML25031A460 ML25031A461
References
TXO-REG-LTR-0055
Download: ML25031A450 (1)

Text

TRISO-X, LLC 151 Lafayette Drive, Suite 300 Oak Ridge, TN 37830 TX0-REG-LTR-0055 THE ENCLOSURES TO THIS LETTER CONTAIN SECURITY-RELATED, EXPORT CONTROLLED, AND PROPRIETARY INFORMATION-WITHHOLD IN ACCORDANCE WITH 10 CFR 2.390 WHEN DETACHED - HANDLE THIS PAGE AS DECONTROLLED THE ENCLOSURES TO THIS LETTER CONTAIN SECURITY-RELATED, EXPORT CONTROLLED, AND PROPRIETARY INFORMATION - WITHHOLD IN ACCORDANCE WITH 10 CFR 2.390 ELECTRONIC DELIVERY January 31, 2025 Director, Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

References:

1)

Docket No. 70-7027

2)

TRISO-X letter to NRC, TRISO-X Fuel Fabrication Facility License Application Submittal, dated April 5, 2022, ADAMS Accession No. ML22101A205

3)

TRISO-X letter to NRC, TRISO-X Fuel Fabrication Facility Environmental Report Submittal, dated September 23, 2022

4)

NRC Letter from Matthew Bartlett, Senior Project Manager, Fuel Facility Licensing Branch, to Jennifer Wheeler, Director, Regulatory Affairs, Acceptance of the TRISO-X, LLC License Application for a Fuel Fabrication Facility (Enterprise Project Identification Number L-2022-NEW-0005 and L-2022-LNE-0002), dated November 18, 2022

5)

TRISO-X letter to NRC, Project Update Letter Regarding the TRISO-X License Application, dated January 20, 2024, ADAMS Accession No. ML24020A010

Subject:

Supplemental Information for the TRISO-X Fuel Fabrication Facility License Application Review (Part 2)

TRISO-X, LLC (TRISO-X) hereby submits supplemental information regarding the review of the License Application for the TRISO-X Fuel Fabrication Facility (References 2 and 3). The enclosed License Application document revisions incorporate previously submitted responses to NRC Requests for Additional Information, as well as project updates that were summarized in a letter dated January 20, 2024 (Reference 5). A revision to the Physical Security Plan is being submitted under a separate cover letter. The remainder of the Environmental Report updates will be submitted at a later date, as discussed with your staff.

TX0-REG-LTR-0055 THE ENCLOSURES TO THIS LETTER CONTAIN SECURITY-RELATED, EXPORT CONTROLLED, AND PROPRIETARY INFORMATION - WITHHOLD IN ACCORDANCE WITH 10 CFR 2.390 THE ENCLOSURES TO THIS LETTER CONTAIN SECURITY-RELATED, EXPORT CONTROLLED, AND PROPRIETARY INFORMATION - WITHHOLD IN ACCORDANCE WITH 10 CFR 2.390 WHEN DETACHED - HANDLE THIS PAGE AS DECONTROLLED Request for Withholding Portions of the enclosed submittal contain information that TRISO-X requests be withheld from public disclosure. The following regulations and guidance were consulted to develop the document markings and specific withholding requests as noted in the description of each enclosures contents.

10 CFR 2.390, Public inspections, exemptions, requests for withholding 10 CFR 110, Export and Import of Nuclear Equipment and Material, and other related regulations 10 CFR 810 and 15 CFR 730-774 NRC Regulatory Issue Summary 2005-31, Revision 1, Control of Security-Related Sensitive Unclassified Non-Safeguards Information Handled by Individuals, Firms, and Entities Subject to NRC Regulation of the Use of Source, Byproduct, and Special Nuclear Material Summary of this Submittal The following documents are included with this letter.

- Affidavit, as required by 10 CFR 2.390(b) to support TRISO-X requests to withhold the below-mentioned proprietary information.

- Integrated Safety Analysis Summary, Revision 3 contains information that is considered Security-Related, Export Controlled, and Proprietary, and TRISO-X requests that this document be withheld from public disclosure per 10 CFR 2.390(a)(4), 10 CFR 110, and NRC RIS 2005-31.

- Environmental Report, Chapter revision numbers as indicated in the document (Non-Proprietary).

- ER Submittal Section Status indicates by Chapter number the status of each section/subsection (Change in January 2025 Submittal, Change in Next ER Revision After January 2025, No Change)

TX0-REG-LTR-0055 THE ENCLOSURES TO THIS LETTER CONTAIN SECURITY-RELATED, EXPORT CONTROLLED, AND PROPRIETARY INFORMATION - WITHHOLD IN ACCORDANCE WITH 10 CFR 2.390 THE ENCLOSURES TO THIS LETTER CONTAIN SECURITY-RELATED, EXPORT CONTROLLED, AND PROPRIETARY INFORMATION - WITHHOLD IN ACCORDANCE WITH 10 CFR 2.390 WHEN DETACHED - HANDLE THIS PAGE AS DECONTROLLED If there are questions or if additional information is required, please contact me at (865) 850-0893 or jwheeler@triso-x.com.

Sincerely, Jennifer K. Wheeler, P.E.

Vice President, Regulatory Affairs TRISO-X, LLC 151 Lafayette Drive, Suite 300 Oak Ridge, TN 37830 Copy: Mr. Matthew Bartlett, US NRC, NMSS TRISO-X Regulatory Records File

TX0-REG-LTR-0055 THE ENCLOSURES TO THIS LETTER CONTAIN SECURITY-RELATED, EXPORT CONTROLLED, AND PROPRIETARY INFORMATION - WITHHOLD IN ACCORDANCE WITH 10 CFR 2.390 THE ENCLOSURES TO THIS LETTER CONTAIN SECURITY-RELATED, EXPORT CONTROLLED, AND PROPRIETARY INFORMATION-WITHHOLD IN ACCORDANCE WITH 10 CFR 2.390 WHEN DETACHED - HANDLE THIS PAGE AS DECONTROLLED ENCLOSURE 1 AFFIDAVIT

TX0-REG-LTR-0055 THE ENCLOSURES TO THIS LETTER CONTAIN SECURITY-RELATED, EXPORT CONTROLLED, AND PROPRIETARY INFORMATION - WITHHOLD IN ACCORDANCE WITH 10 CFR 2.390 THE ENCLOSURES TO THIS LETTER CONTAIN SECURITY-RELATED, EXPORT CONTROLLED, AND PROPRIETARY INFORMATION - WITHHOLD IN ACCORDANCE WITH 10 CFR 2.390 WHEN DETACHED - HANDLE THIS PAGE AS DECONTROLLED AFFIDAVIT PROPRIETARY / FINANCIAL INFORMATION I, Jennifer K. Wheeler, Vice President of Regulatory Affairs for TRISO-X, LLC, (TRISO-X) that to the best of my knowledge and beliefs, make the following representation contained herein:

A. The following documents which TRISO-X requests to have withheld from public disclosure pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 2.390 are: - Integrated Safety Analysis Summary B. The information contained in the document(s) cited in A above has been held in confidence by TRISO-X, in that it contains financial information as defined in 10 CFR 2.390(a) that is not customarily disclosed to the public.

C. The information contained in the document(s) cited in A above has been held in confidence by TRISO-X, in that it contains trade secrets or commercial information as defined in 10 CFR 2.390(a) that is not customarily disclosed to the public.

D. The public disclosure of the information contained in the document(s) cited in A above would likely cause substantial economic harm to the competitive advantage held by TRISO-X because it contains distinguishing aspects of a process, methodology, or components which provide a competitive advantage in product optimization or marketability.

E. Unrestricted disclosure of the information contained in the document(s) cited in A above would jeopardize the position of TRISO-X in the market and, thereby give a market advantage to any competitors who would benefit from access to substantial TRISO-X sensitive information related to the company's nuclear fuel manufacturing methods.

F. The public disclosure of the information contained in the document(s) cited in A above is likely to cause substantial harm to the competitive position of TRISO-X because it would enhance the ability of competitors to address similar safety, regulatory and licensing issues without commensurate expenses.

G. The information that TRISO-X requests to be withheld from public disclosure is contained in the entire document(s) as so marked. Non-proprietary versions of the documents would essentially be blank pages and are therefore not provided.

Therefore, TRISO-X requests the versions of the submitted information marked as proprietary /

financial be withheld from the public disclosure pursuant to 10 CFR 2.390(b) and Section 103(b) of the Atomic Energy Act of 1954, as amended.

TX0-REG-LTR-0055 THE ENCLOSURES TO THIS LETTER CONTAIN SECURITY-RELATED, EXPORT CONTROLLED, AND PROPRIETARY INFORMATION - WITHHOLD IN ACCORDANCE WITH 10 CFR 2.390 THE ENCLOSURES TO THIS LETTER CONTAIN SECURITY-RELATED, EXPORT CONTROLLED, AND PROPRIETARY INFORMATION - WITHHOLD IN ACCORDANCE WITH 10 CFR 2.390 WHEN DETACHED - HANDLE THIS PAGE AS DECONTROLLED The averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief:

Jennifer K. Wheeler Date Vice President, Regulatory Affairs TRISO-X, LLC 1/31/2025