ML25343A212

Memorandum - Summary on August 19, 2025, Audit to Integrated Safety Analysis Summary and Structural Requests for Additional Information for the TRISO-X, LLC, License Application

ML25343A212
Person / Time
Site:	Triso-X
Issue date:	03/10/2026
From:	Matt Bartlett NRC/NMSS/DFM/FFLB
To:	Tekia Govan NRC/NMSS/DFM/FFLB
References
EPID L-2022-PMP-0005
Download: ML25343A212 (0)

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:

Tekia Govan, Acting Chief Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards FROM:

Matt Bartlett, Senior Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards

SUMMARY

OF AUGUST 19, 2025, AUDIT TO INTEGRATED SAFETY ANALYSIS

SUMMARY

AND STRUCTURAL REQUESTS FOR ADDITIONAL INFORMATION FOR THE TRISO-X, LLC, LICENSE APPLICATION (ENTERPRISE PROJECT IDENTIFIER NUMBER L-2022-PMP-0005)

The U.S. Nuclear Regulatory Commission (NRC) staff held an on-sight audit with TRISO-X, LLC (TRISO-X), on August 19, 2025, to seek alignment on requests for additional information (RAI) related to the natural phenomena hazards (NPH) analysis. The application for a new fuel fabrication facility located in Oak Ridge, Tennessee was submitted via letter dated April 5, 2022 (Agencywide Documents Access and Management System Accession No. ML22101A200) and supplemented by letters dated October 13, 2022, (ML22286A144) and November 4, 2022, (ML22308A251) and revised license application submitted by letters dated December 30, 2024, (ML24365A254) and January 31, 2025, (ML25031A449).

The purpose of the meeting was to seek alignment on options TRISO-X could consider for resolving RAIs related to demonstrating compliance with Title 10 Code of Federal Regulations (10 CFR) Section 70.61, Performance Requirements and 10 CFR 70.64, Baseline Design Criteria for NPH related events.

CONTACT: Matt Bartlett, NMSS/DFM 301-415-7154 Enclosures 1 and 2 transmitted herewith contain Security Related Information. When separated from Enclosures 1 and 2, this document is decontrolled.

March 10, 2026 Signed by Bartlett, Matthew on 03/10/26

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION T. Govan 2

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION The meeting began with introductions and opening remarks. Both the NRC and TRISO-X staff agreed that in-person meetings support efficient resolution of complex issues. The NRC staff acknowledged that all draft RAIs had been shared with TRISO-X and would be issued after completion of the audit. The discussion focused initially on integrated safety analysis (ISA)-

related topics, including discussion on TRISO-X plans for applying the facility specific likelihood definitions to certain accident sequences, management measures and recordkeeping.

The structural portion of the meeting addressed the treatment of NPH, particularly related to tornado and wind events and the implications for the facility design. The NRC staff indicated TRISO-X RAI responses should provide additional justification for their tornado analysis, which takes into consideration the historical data for the site. The discussion also explored the option for TRISO-X to seek an exemption from designating the building as an item relied on for safety.

The NRC staff and TRISO-X discussed the scope and content of such an exemption, including how the building would be maintained under configuration management and modifications would be evaluated under 10 CFR 70.72.

Key takeaways from the meeting include:

The NRC and TRISO-X staff reached alignment on several ISA-related RAIs, with some items being deleted or moved to observations.

TRISO-X agreed to revise its responses to clarify the application of management measures, recordkeeping, and the treatment of administrative controls.

The NRC staff emphasized the need for TRISO-X to provide clear justification for the NPH related events and to demonstrate how the facility meets both the performance requirement and the baseline design criteria.

TRISO-X committed to explore additional qualitative and quantitative arguments to support its position, including potential seismic design margin, NPH hazards, and historical tornado data.

Both parties agreed that an exemption to 10 CFR 70.61(e) is a viable path forward, with the NRC staff indicating license condition language may be needed to support the availability and reliability of the site over time.

TRISO-X will provide updated RAI responses in two parts, with the first set submitted by August 29, 2025, and the remainder to follow in September.

A follow-up meeting is anticipated to occur in September to discuss draft RAI responses to ensure resolution of the remaining RAIs.

The meeting participants included the following individuals:

NRC staff:

Matt Bartlett (Licensing Project Manager),

Juan Lopez (Structural Safety Project Manager),

James Chang (ISA Summary Tech Reviewer),

Samantha Lav (Licensing Branch Chief), and Lisa Regner (Technical Branch Chief)

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION T. Govan 3

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION TRISO-X staff:

Jennifer Wheeler (Vice President of Regulatory Affairs),

Burns Cunningham, (Licensing Engineer), and Bob Maurer, (Licensing Engineer and ISA Team Lead)

Docket No.: 07007027

Enclosures:

1. Detailed Meeting Summary (non-public)

2. Draft Set 18 Structural RAIs (non-public)

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION T. Govan 4

OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION

SUMMARY

OF AUGUST 19, 2025, AUDIT TO INTEGRATED SAFETY ANALYSIS

SUMMARY

AND STRUCTURAL REQUESTS FOR ADDITIONAL INFORMATION FOR THE TRISO-X, LLC, LICENSE APPLICATION (ENTERPRISE PROJECT IDENTIFIER NUMBER L-2022-PMP-0005)

DATED: March 10, 2026 DISTRIBUTION:

JChang, RES JLopez, NMSS DJohnson, NMSS LRegner, NMSS SLav, NMSS CTaylor, RII ADAMS Accession Nos:

PKG: ML25343A211, DOC: ML25343A212, ENCL 1: ML25343A213, ENCL 2: ML25343A214 Concurrence case: 20251209-10009