ML25343A241
| ML25343A241 | |
| Person / Time | |
|---|---|
| Site: | Triso-X |
| Issue date: | 11/28/2025 |
| From: | Porterfield D - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 90FR48508 00011, NRC-2022-0201 | |
| Download: ML25343A241 (0) | |
Text
PUBLIC SUBMISSION As of: 12/9/25, 10:25 AM Received: November 28, 2025 Status: Pending_Post Tracking No. mij-j962-sknk Comments Due: December 08, 2025 Submission Type: Web Docket: NRC-2022-0201 Notice of Intent to Conduct Scoping Process and Prepare Supplement to Draft Environmental Impact Statement TRISO-X Fuel Fabrication Facility Comment On: NRC-2022-0201-1774 TRISO-X, LLC; Special Nuclear Material License Application for the TRISO-X Fuel Fabrication Facility; Draft Environmental Impact Statement Document: NRC-2022-0201-DRAFT-1783 Comment on FR Doc # 2025-19646 Submitter Information Name: Donivan Porterfield Address:
Los Alamos, NM, 87544 Email:donivanporterfield@hotmail.com General Comment See attached file(s)
Attachments TRISO-X_EIS_comment_porterfield_2025nov28 12/9/25, 10:26 AM NRC-2022-0201-DRAFT-1783.html file:///C:/Users/BHB1/Downloads/NRC-2022-0201-DRAFT-1783.html 1/1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD Jill Caverly, Antoinette Walker-Smith, Mary Neely Comment (11)
Publication Date:
10/23/2025 Citation: 90 FR 48508
Mr. Donivan Porter"eld November 28, 2025 Office of Administration, Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Program Management, Announcements and Editing Staff Re: Docket ID NRC-2022-0201 In response to the invitation for public comments in the Federal Register (Vol. 90, No. 219, page 51412, Monday, November 17, 2025) on the Environmental Impact Statement (EIS) for a Special Nuclear Material License Application for the TRISO-X Fuel Fabrication Facility, I provide the following.
Comment 1 Acronyms and Abbreviations EPA U.S. Environmental Protection Agency Comment 2 1.0 - Introduction The NRC and the U.S. Department of Energy (DOE), Office of Clean Energy Demonstrations entered into a cooperating agreement to prepare an EIS evaluating the effects of the TRISO-X license application.
1.5 - Cooperating Agencies The NRC entered into a cooperating agreement with the U.S. DOE Office of Clean Energy Demonstrations for the TRISO-X Special Nuclear Material License Application to be used at a fuel fabrication facility (NRC and DOE, 2024).
Do these mentions need to be updated or footnoted to address recent DOE organization changes?
Comment 3
Mr. Donivan Porter"eld 2.1.2.1 - Fuel Fabrication The feedstock for the process would be U3O8 powder enriched to less than 20 weight percent uranium-235. TRISO-X would obtain the U3O8 powder through deliveries to the FFF by external suppliers; by converting dilute uranyl nitrate, delivered to the FFF by external suppliers, into U3O8 powder; and by recovering uranium from damaged, degraded, or otherwise non-conforming product materials through a variety of batch operations during the fuel fabrication process and converting the recovered uranium to U3O8 powder.
The noted content does not clearly address whether the speci"cations for uranium accepted by the FFF would only allow virgin uranium or might also include uranium that is recycled or that has become incidentally contaminated with radionuclides such as 99Tc, 232U, 233U, 236U, 237Np, 239Pu, 240Pu, and/or 241Am? If such other radionuclides were present in the received by FFF, how might they impact worker dose, be emitted to the environment by the FFF, be included in the produced fuel, or require other disposition?
Comment 4 2.1.2.2 - Chemical Receipt, Storage, and Handling The liquid and gaseous chemicals stored and consumed in the production of the fuel are provided in the TRISO-X environmental report (ER; tables 2.1-1a through 2.1-1e of TRISO-X, 2025b).
The content of the four noted tables consists only of the following text: See the TRISO-X Fuel Fabrication Facility Site Emergency Plan and/or TRISO-X Fuel Fabrication Facility Integrated Safety Analysis Summary. It is my presumption that those documents are withheld from public disclosure due to information that is considered Security-Related, Export Controlled, and/or Proprietary.
I was able to locate in tables 4.12.2-1 (Summary of Potential Health Impacts Associated with Releases of Non-Radiological Materials Used in Production and Stored Outdoors at the TRISO-X Fuel Fabrication Facility) and 4.12.2-2 (Summary of Potential Health Impacts Associated with Exposure to Non-Radiological Materials Used in Production and Stored Indoors at the TRISO-X Fuel Fabrication Facility) a list of liquid and gaseous chemicals.
However, it is not clear whether both sets of tables are consistent with each other in terms of listed liquid and gaseous chemicals.
It is difficult to say whether the above situation is meant to obstruct an effective public review or is simply a poor organizational effort.
Comment 5
Mr. Donivan Porter"eld A recent Federal Register (Vol. 90, No. 178/Wednesday, September 17, 2025, pp 44772 -
44781) titled Trichloroethylene; Regulation Under the Toxic Substances Control Act (TSCA); Compliance Date Extension that contained the following relevant TRISO information.
TCE as a Processing Aid in the Manufacture of Nuclear Fuel - EPA identi"ed "ve companies that have capabilities to produce Tri-structural Isotropic (TRISO) particle fuel, with only a single primary producing company capable of production at scale.
That company uses TCE as a forming "uid. One company may also be using TCE to produce TRISO fuel, although they are not currently licensed by NRC and are not producing TRISO fuel at production scale but would need to transition to a TCE alternative to comply with the 2024 "nal rule. EPA presumes that the transition costs for this company would be smaller than the costs for the at scale producer because their production is smaller capacity.
The primary producing company estimated that the costs of executing the testing of the manufacturing ability of alternatives and fuel quality analysis studies would be approximately $4 million (Ref. 4). The company notes that there would be additional costs that it was unable to quantify such as equipment testing, operator training, additional irradiation testing, and fuel certi"cation (Ref. 4). The three-year delay in prohibition of TCE for this use would delay the occurrence of these transition costs.
The social costs avoided under the interim "nal rule would be those associated with the critical infrastructure and national security impacts that would occur without it.
EPA is unable to address the cost savings from avoiding the delays in the production of TRISO fuel that would occur without the interim "nal rule.
What are the past, current, and future plans of TRISO-X for use of trichloroethylene in fuel production?
Comment 6 3.13.2.1 - Radiological Accidents The provided content doesnt clearly address whether the proposed FFF design would include a Criticality Accident Alarm System.
Comment 7 3.13.2.1 - Radiological Accidents
Mr. Donivan Porter"eld Other events were either determined to be bounded by the consequences of the analyzed events or were determined, based on low likelihood, to be beyond highly unlikely and therefore to pose an acceptably low level of risk (TRISO-X, 2024). The facility design is required, under 10 CFR 70.64(b), to incorporate a defense-in-depth approach to accident prevention and mitigation.
TRISO-X has proposed engineering design features and administrative controls that would prevent the initiation of nuclear or radioactive material accidents or mitigate their consequences (TRISO-X, 2024). These include controls such as:
Design of the facility ventilation system and dissolution off-gas treatment system, including the use of "lters and scrubbers to remove radioactive vapors and particulate (TRISO-X, 2024, 2025).
Geometry of liquid collection sumps (TRISO-X, 2025).
The above noted references dont match speci"c documents in the Section 5 (References) content. All the listed TRISO documents have 2024x and 2025x identi"ers.
Comment 8 3.13.2.2 - Hazardous Chemical Accidents The chemical accidents evaluated by TRISO-X are hypothetical severe chemical accidents that bound other potential chemical accidents at the FFF. The accidents involve unmitigated releases of process chemicals, including nitric acid, hydrogen peroxide, ammonia, and carbon dioxide (TRISO-X, 2024, 2025). The results of the chemical accident analyses were compared to the threshold consequences in 10 CFR 70.61 and to the EPAs acute exposure guidelines (EPA, 2016).
+For the chemicals analyzed, the material at risk (MAR) was based on the estimated maximum inventory of each chemical at the FFF. In addition, no credit was taken for depletion or plate-out of any chemicals, either within the FFF or during transport to receptor locations (TRISO-X 2024, 2025).
The ISA determined that the "ammable gas explosion results in a high consequence for the public. The bounding MTS release would also create a high consequence for the public (TRISO-X, 2025).
In a response to NRCs requests for additional information, TRISO-X indicated that accidental releases of carbon monoxide could result in maximum offsite concentrations that exceed PAC-2 levels and accidents involving acetic acid, methyltrichlorosilane liquid or methyltrichlorosilane gas could exceed PAC-1 levels (TRISO-X, 2023).
Mr. Donivan Porter"eld These mitigations generally involve use of con"nement boundaries and barriers in process areas, to con"ne spills or releases and protect workers from liquid sprays, other active and passive engineering controls, and administrative controls (TRISO-X, 2025).
The above noted references dont match speci"c documents in the Section 5 (References) content. All the listed TRISO documents have 2024x and 2025x identi"ers.
Thank you for the opportunity to provide the above public comments.
Mr. Donivan Porter"eld Los Alamos, NM