ML25266A087
| ML25266A087 | |
| Person / Time | |
|---|---|
| Site: | 99902130 |
| Issue date: | 09/25/2025 |
| From: | Daniel Barnhurst NRC/NMSS/DREFS/EPMB3 |
| To: | Linda Williams Energy Northwest |
| References | |
| Download: ML25266A087 (1) | |
Text
Lisa Williams Operations, Licensing and Environmental Manager Energy Northwest 345 Hills Street Richland, WA 99352
SUBJECT:
PRE-APPLICATION READINESS ASSESSMENT ACTIVITIES AND AUDIT PLAN FOR THE ENERGY NORTHWEST NEW NUCLEAR DRAFT APPLICATION
Dear Lisa Williams:
Energy Northwest New Nuclear (ENNN) requested initiation of pre-application interactions with the U.S. Nuclear Regulatory Commission (NRC) by submitting a Regulatory Engagement Plan dated August 26, 2024 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML24239A815) in support of a potential construction permit application for 12 Xe-100 reactors at the Hanford Site. Pre-application interactions to support development of an application for submission to the NRC can involve discussion of technical and regulatory issues during public meetings as well as examination of preliminary application information during regulatory audits conducted by the NRC. Audits of preliminary application information may be conducted using an applicants electronic reading room as well as at a physical location controlled by an applicant. Lastly, the NRC staff may interact with other Federal, State, county, and Tribal governments as part of its pre-application interactions and preparations. ENNN may be requested to support some of these interactions.
The NRCs audit process is part of the NRCs official pre-application review process. The audit of the draft application will allow the NRC staff to view its contents (in a read-only manner) and the level of detail in the draft application and identify any major issues or information gaps between the draft application and the technical content required to be included in the application submitted to the NRC. Therefore, the observations from these audits will inform the documents being prepared but will not predetermine whether the document and/or the application will be docketed.
The attached pre-application audit plan provides the details and logistics for the pre-application audit activities.
September 25, 2025
L. Williams 2
If you have any questions regarding this matter, please contact Madelyn Nagel, Environmental Project Manager, at 301-415-0371 or Madelyn.Nagel@nrc.gov.
Sincerely, Daniel Barnhurst, Chief Environmental Project Management Branch 3 Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Materials, Safety and Safeguards Docket No.: 99902130
Enclosure:
As stated cc: Theresa Howell Don Gregoire Nathan Clarke Signed by Barnhurst, Daniel on 09/25/25
- via email OFFICE NMSS/REFS/EPMB3 NMSS/REFS NMSS/REFS/EPMB3 NAME MNagel MCampestrin DBarnhurst DATE 9/23/2025 9/24/2025 9/25/2025
Enclosure PRE-APPLICATION AUDIT PLAN OF THE HANFORD SITE DRAFT APPLICATION September 2025 Docket No. 99902130 PROCESS and LOCATION The audit process will include a review of material on the Energy Northwest New Nuclear (ENNN) online reference portal (also known as the Electronic Reading Room or eRR) in a read-only manner and will help inform any associated discussions during audits (either in-person or virtual) at locations to be determined or, during site visits at the Hanford Site in Richland, WA as appropriate.
PURPOSE ENNN has voluntarily agreed to engage with the U.S. Nuclear Regulatory Commission (NRC) staff in a preapplication audit for the draft Hanford Site Construction Permit Application (CPA) before the application is submitted for a formal NRC review.
The audit will allow the NRC staff to:
View documents in ENNNs eRR to identify information gaps between the draft application and the technical content required in the application submitted to the NRC, View documents in ENNNs eRR to identify major technical or policy issues that may adversely impact the docketing or technical review of the application, and View documents in ENNNs eRR to become more familiar with the application, particularly in areas where ENNN is proposing new concepts.
The observations from the audit will inform ENNN in finalizing the application and assist the NRC staff in planning NRC resources in preparation for the formal application.
BACKGROUND ENNN began pre-application planning discussions with the NRC staff on their preparation for the Hanford Site in August 2024. In October 2024, ENNN announced a partnership with Amazon to support future development of the Xe-100 on the Hanford Site. As discussed in public meetings held on August 9, 2024, October 24, 2024, August 14, 2025, and September 5, 2025, ENNN plans to submit an application for a construction permit, including a Preliminary Safety Analysis Report and an Environmental Report (ER).
The NRC will conduct the audit of the draft ER and associated information using ENNNs eRR and will share observations during virtual audits or site visits until the CPA is submitted.
2 SCOPE OF THE AUDIT The NRC staff will use NRCs Office Instruction LIC-111 Regulatory Audits (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19226A274), as guidance for conducting this audit. In addition, the NRC staff will use appropriate portions of LIC-116, Pre-application Readiness Assessment (ML20104B698) and Pre-application Engagement to Optimize Advanced Reactors Application Reviews: Draft Report in its other pre-application interactions with ENNN (ML21145A106).
This audit will cover all the chapters of the ER including appendices. Associated appendices are anticipated to cover topics such as environmental consultations and environmental permitting and authorizations. The audit of ENNNs draft application could cover the draft ER Chapters 1 through 10 and related information.
INFORMATION AND OTHER MATERIAL NECESSARY FOR THE PRE-APPLICATION AUDIT The staff discussed with ENNN what is needed for the audit. The following is needed to support the audit: Chapters 1 through 10 of the ER of the draft application, all available supporting topical reports, all major supporting technical reports, examples of important calculations, and staff who can answer questions related to these documents. The table below lists the technical review areas for the ER Audit Teams, respectively.
AUDIT TEAM Environmental Report Review Area Staff Chapter 2, Proposed Site and Affected Environment Chapter 3, Site Layout and Project Description Chapter 4, Environmental Impacts of Construction Chapter 5, Environmental Impacts of Operation Chapter 6, Fuel Cycle, Transportation, and Decommissioning Impacts Chapter 7, Cumulative Impacts Chapter 8, Need for Power Chapter 9, Alternatives for the Proposed Action Chapter 10, Conclusions Madelyn Nagel Jennifer Davis PNNL contractors Other technical support, as needed LOGISTICS The audit will be conducted in a number of phases and will involve examination of documents and materials via ENNNs eRR and could include visits to the Hanford Site or ENNN facilities.
The initial audit planning and engagement with ENNN will be scheduled for September 2025, beginning with a virtual entrance meeting, following the posting of the annotated ER chapter outlines for the first phase in the eRR, and ending with a virtual exit meeting at the conclusion of the last phase of pre-application. ENNN will be briefed on the observations of the phase of the assessment upon completion of each phase.
3 REVIEW APPROACH The readiness assessment will be conducted by NRC reviewers or contractors who are technical experts in their assigned review areas. The NRC readiness assessment team will conduct an assessment that includes the following attributes:
NRC will control phase and session attendance and will specify charging codes for technical reviewers, NRC will implement the assessment generally in three-week phases on specified technical engagements (i.e., on chapters and/or topics),
NRC will engage with State and Federal government stakeholders involved in the proposed project during readiness meetings, which includes Washington Energy Facility Site Evaluation Council and Department of Energy Hanford Field Office, ENNN will provide tailored presentations and discussions to technical staff as needed, NRC will implement real-time problem/issue identification and documentation via SharePoint.
AUDIT OBSERVATIONS The NRC will send the audit observations, including any identified technical concerns or major information gaps, to ENNN in a publicly available report that will also summarize the scope of the audit activities. NRC Office Instruction LIC-111 (ML19226A274) delineates the timeline for the final report to be completed within 45 calendar days of completion of the audit. The Audit Team will endeavor to complete the final report within 45 days using the streamlined process described above. To protect the applicants proprietary information, if needed, the staff will issue a proprietary version of the audit report. The staffs expectation is that ENNN will consider the observations from the audit while finalizing the application and will reevaluate the application submission date based on its evaluation of the time to address the audit observations.