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Project Long Mott Docs - (External_Sender) Re Re X-energy Emergency Planning White Paper Presentation
	ML26045A029
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Site:	05000614
Issue date:	07/11/2023
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To:	; NRC/NRR/DANU
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From:

ext_Jessica_Maddocks Sent:

Tuesday, July 11, 2023 11:11 AM To:

Adrian Muniz Cc:

Zackary Stone (He/Him/His); Jorge Hernandez Munoz; Jeanette Arce; Edward Robinson

Subject:

[External_Sender] RE: RE: X-energy Emergency Planning White Paper Presentation Attachments:

7.11.23.EP WP.pptx Thanks, Adrian. Brandon noticed a typo during his presentation, and he has corrected it. See attached.

Jessica Maddocks Licensing Project Manager jmaddocks@x-energy.com This message (including any attachments) is intended only for the use of the individual or entity to which it is addressed and may contain information that is non-public, proprietary, privileged, confidential, and exempt from disclosure under applicable law or may constitute attorney work product. If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, notify us immediately and delete this message immediately. Thank you. X Energy, LLC From: Adrian Muniz Sent: Tuesday, July 11, 2023 10:06 AM To: Jessica Maddocks Cc: Zackary Stone (He/Him/His) ; Jorge Hernandez Munoz (He/Him) ; Jeannette Arce ; Edward Robinson

Subject:

RE: RE: X-energy Emergency Planning White Paper Presentation We will add these slides to ADAMS as a public document and will include them as part of the meeting summary.

Thanks, Adrian Muniz Senior Project Manager Advanced Reactor Licensing Branch 2 (UAL2)

Division of Advanced Reactors and Non-Power Production and Utilization Facilities (DANU)

From: Jessica Maddocks <jmaddocks@x-energy.com>

Sent: Tuesday, July 11, 2023 9:41 AM To: Adrian Muniz <Adrian.Muniz@nrc.gov>; Edward Robinson <Edward.Robinson@nrc.gov>

Cc: Zackary Stone (He/Him/His) <Zackary.Stone@nrc.gov>; Jorge Hernandez Munoz (He/Him) <Jorge.Hernandez@nrc.gov>; Jeannette Arce <Jeannette.Arce@nrc.gov>

Subject:

[External_Sender] RE: X-energy Emergency Planning White Paper Presentation Notice: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Adrian, See the slides with the proprietary disclaimer slide removed. I talked with the presenter and this information is not proprietary, but there is some business sensitive information we are okay with the public seeing. Sorry for any confusion that might have caused.

Jessica Maddocks Licensing Project Manager jmaddocks@x-energy.com This message (including any attachments) is intended only for the use of the individual or entity to which it is addressed and may contain information that is non-public, proprietary, privileged, confidential, and exempt from disclosure under applicable law or may constitute attorney work product. If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, notify us immediately and delete this message immediately. Thank you. X Energy, LLC From: Jessica Maddocks Sent: Tuesday, July 11, 2023 9:22 AM To: Adrian Muniz <Adrian.Muniz@nrc.gov>; Edward.Robinson@nrc.gov Cc: zackary.stone@nrc.gov; jorge.hernandez@nrc.gov; Jeannette.Arce@nrc.gov

Subject:

X-energy Emergency Planning White Paper Presentation

Adrian, I was just informed the slides for the emergency planning white paper meeting this morning were never sent. See attached. Apologies these were not sent over earlier.

Jessica Maddocks Licensing Project Manager jmaddocks@x-energy.com This message (including any attachments) is intended only for the use of the individual or entity to which it is addressed and may contain information that is non-public, proprietary, privileged, confidential, and exempt from disclosure under applicable law or may constitute attorney work product. If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, notify us immediately and delete this message immediately. Thank you. X Energy, LLC

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[External_Sender] RE RE X-energy Emergency Planning White Paper Presentation Sent Date:

7/11/2023 11:10:41 AM Received Date:

7/11/2023 11:11:58 AM From:

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Tracking Status: None "Adrian Muniz" <Adrian.Muniz@nrc.gov>

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PH1P110MB1330.NAMP110.PROD.OUTLOOK.COM Files Size Date & Time MESSAGE 4650 7/11/2023 11:11:58 AM image001.png 3997 7.11.23.EP WP.pptx 12136508 Options Priority:

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Affordable Xe-100 Emergency Planning Approach Brandon Hartle, P.E., Xe-100 Operations Licensing July 11, 2023

Meeting Agenda Topic Time (60 minutes)

Presenter Opening Remarks 2 minutes Brandon Hartle - X-energy NSIR Branch Chief - NRC Introductions and Safety Moment 3 minutes Brandon Hartle - X-energy Brief Technology Overview 5 minutes Brandon Hartle Xe-100 Emergency Preparedness Approach 10 minutes Brandon Hartle Emergency Planning Zone Methodology 5 minutes Brandon Hartle Emergency Response Organization Methodology 5 minutes Brandon Hartle Emergency Action Levels Methodology 5 minutes Brandon Hartle Proposed Future Engagement 5 minutes Brandon Hartle NRC Questions and Feedback 15 minutes NRC Staff Closing Remarks 5 minutes Brandon Hartle &

NSIR Branch Chief - NRC

Brief Technology Overview Brandon Hartle Xe-100 Operations Licensing 200 MWt Pebble Bed High Temperature Reactor as the nuclear heat source UCO TRISO particle fuel embedded in a graphite matrix spherical fuel element (i.e., pebble)

Helical coil Steam Generator for producing high quality steam (565 deg C at 16.5 Mpa)

Standard plant has 4 reactor units that are controlled from a single control room with 3 operators Steam headers can be connected to steam turbines or can provide process heat directly to a plant requiring process steam or heat

Brief Technology Overview Brandon Hartle Xe-100 Operations Licensing X-energy anticipates the projected dose will not exceed 1 rem total effective dose equivalent (TEDE) over 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months from the time of release at the site boundary TRISO particle fuel has a proven pedigree -

more than 30 years of operational and fuel fabrication experience Tested to 1800 deg C - remains safe and cannot melt even without active cooling Each pebble contains approximately 19,000 TRISO fuel particles Each particle retains

~99.999%

of fission products, equivalent to each particle being its own functional containment vessel These particles replace the need for many complex safety systems required in the current LWR fleet

Xe-100 Emergency Preparedness Approach X-energy is submitting a Construction Permit Application (CPA) and Operating License Application (OLA) under 10 CFR Part 50 For the CPA, X-energy is developing the preliminary plan to cope with emergencies at the Xe-100 plant in accordance with 10 CFR 50.34(a)(10)

The preliminary plan to cope with emergencies is compliant with the regulatory requirements of the following, with no anticipated exemptions:

10 CFR 50.33(g) 10 CFR 50.47 Appendix E.II to 10 CFR 50 For the OLA, X-energy is developing the plan to cope with emergencies at the Xe-100 plant in accordance with 10 CFR 50.34(b)(6)

The plan to cope with emergencies must demonstrate compliance with the regulatory requirements of the following:

10 CFR 50.33(g) 10 CFR 50.47 Appendix E.III and E.IV to 10 CFR 50 Brandon Hartle Xe-100 Operations Licensing

Xe-100 Emergency Preparedness Approach

To allow for the development and implementation of emergency plans commensurate with the significantly reduced risk of the Xe-100 technology, X-energy anticipates several exemptions from the previously listed regulations

From draft rule 10 CFR 50.160 and accompanying draft Regulatory Guide (RG) 1.242, X-energy can realize the benefits of performance-based emergency preparedness This rule would allow X-energy to develop the plan to cope with emergencies at the Xe-100 without complicated, costly, and time-consuming exemption requests X-energy will adhere to the guidance in RG 1.242 to meet the regulations of 10 CFR 50.160 with no anticipated exemptions

X-energy plans to submit the Xe-100 Emergency Preparedness White Paper to discuss this approach as well as introduce the methodologies for three aspects of Xe-100 Emergency Preparedness Brandon Hartle Xe-100 Operations Licensing

Emergency Planning Zone Methodology

X-energy will submit a Plume Exposure Pathway Emergency Planning Zone (EPZ) Methodology licensing topical report (LTR)

This LTR will provide the technical basis for the Xe-100 EPZ sizing methodology

X-energy projects the public dose to be less than 1 rem TEDE over 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months at the site boundary for postulated Licensing Basis Events (LBEs). Therefore, X-energy anticipates the Xe-100 EPZ is coincident with the site boundary X-energy is adhering to RG 1.194 and RG 1.145 for dose calculations X-energy will be requesting exemptions from the applicable parts of 10 CFR 50.47(b) and 10 CFR 50 Appendix E If the final rule is published, X-energy will also adhere to RG 1.242, and would anticipate no exemptions from 50.160 for EPZ sizing methodology

A comprehensive regulatory analysis on all NRC-approved guidance that X-energy is following will be provided in the upcoming white paper Brandon Hartle Xe-100 Operations Licensing

Emergency Response Organization Methodology X-energy will submit an Emergency Response Organization (ERO) Methodology LTR This LTR will provide the technical basis for the appropriate number of on-shift and augmenting ERO positions necessary to respond and cope with an emergency in the event of an emergency declaration Regardless of the regulatory pathway (exemptions from 10 CFR 50 or compliance with 10 CFR 50.160), X-energy will provide the standard methodology of ERO staffing for the Xe-100 plant for NRC approval X-energy anticipates following the NRC-endorsed guidance of NEI 10-05 Based on the significantly reduced risk of the Xe-100 design, X-energy anticipates the ERO staffing levels for the Xe-100 to be smaller than the current light water reactor (LWR) fleet A comprehensive regulatory analysis on all NRC-approved guidance that X-energy is following will be provided in the upcoming white paper Brandon Hartle Xe-100 Operations Licensing

Emergency Action Levels Methodology

X-energy will submit an Emergency Action Levels (EAL) Methodology LTR

This LTR will provide the technical basis and methodology for determining the thresholds corresponding to each emergency classification scheme and associated EAL

Due to the design and safety features of the Xe-100, X-energy anticipates the threshold for a General Emergency declaration will not be met for postulate LBEs

Therefore, existing industry guidance may be of little use for developing the Xe-100 EALs

A comprehensive regulatory analysis on all NRC-approved guidance that X-energy is following will be provided in the upcoming white paper Brandon Hartle Xe-100 Operations Licensing

© 2023 X Energy, LLC, all rights reserved 10 Proposed Future Engagement Brandon Hartle Xe-100 Operations Licensing X-energy Deliverable Submittal Date NRC Review Xe-100 Emergency Preparedness White Paper August 2023 45-day comment period EPZ Methodology LTR June 2024 1 year review with SER ERO Methodology LTR December 2024 1 year review with SER EAL Methodology LTR June 2025 1 year review with SER

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