ML25196A082
| ML25196A082 | |
| Person / Time | |
|---|---|
| Site: | Triso-X |
| Issue date: | 07/25/2025 |
| From: | Lav S NRC/NMSS/DFM/FFLB |
| To: | Wheeler J Triso-X |
| References | |
| Download: ML25196A082 (1) | |
Text
Jennifer K. Wheeler, Director Regulatory Affairs TRISO-X, LLC 801 Thompson Avenue Rockville, MD 20852
SUBJECT:
SET 19 REQUEST FOR ADDITIONAL INFORMATION REGARDING ENVIRONMENTAL SAFETY CHAPTER 9 OF THE LICENSE APPLICATION FROM TRISO-X, LLC FOR A SPECIAL NUCLEAR MATERIAL LICENSE FOR A FUEL FABRICATION FACILITY IN OAK RIDGE, TENNESSEE (DOCKET NO. 70-7027)
Dear Jennifer Wheeler:
The U.S. Nuclear Regulatory Commission (NRC) staff received a revised supplement to an application for a special nuclear material license for use at a TRISO-X, LLC (TRISO-X) Fuel Fabrication Facility in Oak Ridge, Tennessee. TRISO-X submitted revisions to chapter 9 of the application to address a revised design of the proposed facility. The revised chapter was submitted on December 30, 2024 (Agencywide Documents Access and Management System
[ADAMS] Accession No. ML24365A256).
The NRC staff is conducting a detailed technical review of your application and has determined that additional information is necessary in connection with its review and development of a safety evaluation chapter 9. The information needed by the staff is discussed in the enclosed request for additional information. We request that you provide responses by August 6, 2025, 30 days from the date we emailed the draft of the request for additional information sent on July 7, 2025. This will avoid delays finalizing the staffs review and impacting the review schedule.
In accordance with Title 10 of the Code of Federal Regulations Section 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records component of the NRCs ADAMS. ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. The PDR is open by appointment.
To make an appointment to visit the PDR, please send an email to PDR.Resource@nrc.gov or call 1-800-397-4209 or 301-415-4737, between 8 a.m. and 4 p.m. eastern time (ET), Monday through Friday, except Federal holidays.
July 25, 2025
J. Wheeler Please reference Docket No. 70-7027 in future correspondence related to the technical review for this licensing action. If you have any questions, please contact the Project Manager, Steve Poy of my staff by phone at (301) 415-7135 or via email at Stephen.Poy@nrc.gov.
Sincerely, Samantha Lav, Chief Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 70-7027
Enclosure:
- 1. RAI Chapter 9 Supplement cc: A. Desrosiers, Numark Associates Siurano-Perez, Osiris signing on behalf of Lav, Samantha on 07/25/25
ADesrosiers - Set 19 Environmental Safety Chapter 9 - RAIs Enclosure SET 19 REQUEST FOR ADDITIONAL INFORMATION CHAPTER 9 FOR THE TRISO-X, LLC, SUPPLEMENTAL APPLICATION FOR A PROPOSED FUEL FABRICATION FACILITY IN OAK RIDGE, TENNESSEE The purpose of these requests for additional information (RAIs) presented below is to obtain additional data and information from TRISO-X, LLC (TRISO-X), for the U.S. Nuclear Regulatory Commission (NRC) staff in support of the NRCs evaluation of the environmental safety portion of the TRISO-X license application (LA) for special nuclear material at a Fuel Fabrication Facility in Oak Ridge, Tennessee.
RAI-1 Transuranic and Fission Product Contaminants in Effluents Regulatory Basis:
Title 10 of the Code of Federal Regulations (10 CFR) Section 20.1302(a) states The licensee shall make or cause to be made, as appropriate, surveys of radiation levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public in § 20.1301. The dose limits in § 20.1301 apply to the total effective dose equivalent from the licensed operation.
Description of Issue:
The applicant stated that feed material may contain transuranic and fission product contamination. Although the survey program is described in LA chapter 4, there is limited information on the monitoring of transuranic and fission product activities in effluents. Additional information is needed to evaluate the proposed emissions controls with respect to transuranic and fission product contamination.
Information Needed:
Incorporate in the LA or by cross reference a sufficient description of the methods, such as action levels related to receipt of contaminated feed material, to determine when it is appropriate to survey for transuranic or fission product contamination in effluents.
RAI-2 Frequency and Type of Ambient Air Sampling and Analysis Regulatory Basis:
As stated in 10 CFR 20.1302(b), a licensee shall show compliance with the annual dose limit in
§ 20.1301 by (1) demonstrating by measurement or calculation that the total effective dose equivalent to the individual likely to receive the highest dose from the licensed operation does not exceed the annual dose limit; or (2) demonstrating that the annual average concentrations of radioactive material at the boundary of the unrestricted area do not exceed values specified in table 2 of appendix B to part 20.
The guidance in Section 9.4.3.2.2 (A5) of NUREG-1520, Rev. 2, Standard Review Plan for Fuel Cycle Facilities License Applications, states that sampling and analysis frequencies must be
ADesrosiers - Set 19 Environmental Safety Chapter 9 - RAIs 2
appropriate. Section 9.4.3.2.2 (A6) of NUREG-1520, Rev. 2 states that radionuclide specific analyses are required. Section 9.4.3.2.2 (A4) states that monitoring for all routine and nonroutine events should be performed quarterly.
Description Issue:
The applicant currently proposes collecting weekly effluent samples from the stacks and analyzing the samples for isotopic uranium. This commitment satisfies the identified regulatory requirements for stack releases. Ground level ambient air sampling is the method proposed by the applicant for monitoring potential environmental doses associated with nonroutine events that result in ground level releases. Furthermore, the applicant has committed to perform ambient air measurements as a method for early detection of nonroutine ground level releases.
The methods for analyzing uranium in ambient air should be able to distinguish potential releases from the licensed facility from natural background or nearby sources. The simple and reliable method for distinguishing the licensees uranium releases from background or nearby sources is the isotopic ratio of U-234/U-238 in high assay low enriched uranium feedstock.
The applicants commitment to early detection could be satisfied by more frequent sampling, such as sampling ambient air weekly and measuring gross alpha and gross beta weekly.
Monthly sampling for gross radioactivity appears to be inconsistent with a commitment for early detection.
Section 9.5 of the revised LA states that ambient air samplers verify the absence of routine ground level gaseous effluent releases and provide a method for early detection of nonroutine ground level gaseous effluent releases. Table 9-1 shows that stack discharges are sampled weekly, but ground level ambient air is sampled monthly and that isotopic uranium analyses are not required for ambient air samples. The methods for analyzing uranium in ambient air does not identify a method to distinguish potential releases from the licensed facility from natural background or nearby sources. Measurements, such as quarterly specific isotopic analyses of composite ambient air samples, should be performed on ambient air samples consistent with guidance in NUREG-1520, Rev. 2 to identify the source of uranium measured in ambient air.
Information Needed:
Update the LA to clearly explain how TRISO-X effluent monitoring will ensure early detection of potential nonroutine releases from ground level events and identify releases that are specific to the TRISO-X facility.