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Project Long Mott Docs - (External_Sender) X-energy File Replacement Request
	ML26048A325
Person / Time
Site:	05000614
Issue date:	07/25/2025
From:	; - No Known Affiliation
To:	; NRC/NRR/DANU
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	Download: ML26048A325 (0)
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From:

ext_Jessica_Maddocks Sent:

Friday, July 25, 2025 2:06 PM To:

Kenny Nguyen Cc:

Jorge Hernandez Munoz; Adrian Muniz

Subject:

[External_Sender] X-energy File Replacement Request Attachments:

Encl. 1 - SRMF WP - NRC Presubmittal Meeting - Non-Prop -

PUBLIC.pdf Kenny, X-energy needs to do a file replacement for a presentation that was submitted July 22nd for the Xe-100 Self-Reliant-Mitigation Facility Approach. Attached to this email, you will find the updated public presentation for Xe-100 Self-Reliant-Mitigation Facility Approach (10 page pdf

- matching originally submitted format).

Based on the submittal email below, I believe the Accession Number for the presentation is ML25203A357 (PUBLIC) and the other Accession Number is for the submittal letter.

Please let me know if you need any other information from me.

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

Original Message-----

From: mshd.resource@nrc.gov <mshd.resource@nrc.gov>

Sent: Tuesday, July 22, 2025 4:22 PM To: Yvonne Mirowski <ymirowski@x-energy.com>

Subject:

General Form Submission (49856) Received 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.

The NRC received your General Form submission on: 07/22/2025 at 04.22 PM. It is being tracked as submission ID# 49856.

If it is a 'Publicly Available' submission after 6 work days from today the submission's attached document(s) will be available for viewing and download from the Agency's Public Web Based ADAMS website (https://usg02.safelinks.protection.office365.us/?url=https%3A%2F%2Fadams.nrc.gov%2Fwba&data=05

%7C02%7Cymirowski%40x-energy.com%7Cf7571ccc61a14684442c08ddc95d6d0e%7Cdad817091f3941a6bc353f610ca4f67d%7C0%

7C0%7C638888125275829574%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLj AuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=NrN%2B CxO%2Bgip2XxJAS3pqDVEqOPbs8yOZjagDhGvHkTc%3D&reserved=0) by searching for the following document accession number(s): [ML25203A356, ML25203A357]. If this is a 'Non-Public Available' submission the submission's attachment(s) will be retained in NRC's document management system (ADAMS) and will not be published to the public website.

Should you have questions about this submission please contact our Help Desk by phone at 866-672-7640 or by e-mail at Meta_System_Help_Desk.Resource@nrc.gov. When doing so, please refer to the Submission ID# shown above.

Note: The Help Desk is staffed daily from 9:00AM to 6:00PM Eastern Time Monday through Friday (except for Federal holidays)

Hearing Identifier:

XeDOW_ProjectLongMott_SafPublic Email Number:

310 Mail Envelope Properties (BN0P110MB2241D94AF6C163F655212E7C9059A)

Subject:

[External_Sender] X-energy File Replacement Request Sent Date:

7/25/2025 2:05:51 PM Received Date:

7/25/2025 2:06:06 PM From:

ext_Jessica_Maddocks Created By:

/O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=BB0743AD17B046F39958AF4A985C5297-8AC523D3-F8 Recipients:

"Jorge Hernandez Munoz" <Jorge.Hernandez@nrc.gov>

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

Tracking Status: None "Kenny Nguyen" <Kenny.Nguyen@nrc.gov>

Tracking Status: None Post Office:

BN0P110MB2241.NAMP110.PROD.OUTLOOK.COM Files Size Date & Time MESSAGE 3335 7/25/2025 2:06:06 PM image001.png 3997 Encl. 1 - SRMF WP - NRC Presubmittal Meeting - Non-Prop - PUBLIC.pdf 584736 Options Priority:

Normal Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

Xe-100 Self-Reliant-Mitigation Facility Approach August 2025 Brandon Hartle, P.E., Operations Licensing X Energy, LLC

Department of Energy Acknowledgement and Disclaimer This material is based upon work supported by the Department of Energy under Award Number DE-NE0009040.

This presentation was prepared as an account of work sponsored by an agency of the United States Government.

Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof.

Meeting Agenda Topic Time (45 minutes)

Presenter Opening Remarks 2 minutes Travis Iskierka-Boggs - X-energy Introductions and Safety Moment 3 minutes Brandon Hartle Xe-100 Licensing Pathway 10 minutes Brandon Hartle Xe-100 Self-Reliant-Mitigation Facility Approach 5 minutes Brandon Hartle Xe-100 Control Room Operator Qualification 5 minutes Brandon Hartle Proposed Future Engagement 5 minutes Brandon Hartle NRC Questions and Feedback 10 minutes NRC Staff Closing Remarks 5 minutes Brandon Hartle &

IOLB Branch Chief - NRC

Xe-100 Licensing Pathway

Long Mott Energy (LME), submitted a Construction Permit Application (CPA) for the Long Mott Generating Station (LMGS) Xe-100 facility under 10 CFR Part 50

LME will submit an Operating Licensing Application (OLA) for the LMGS Xe-100 facility under 10 CFR Part 50

Prospective applicants may decide to submit applications to operate an Xe-100 facility under 10 CFR Part 50, 52, or 53 once finalized

Section 103 of the Atomic Energy Act of 1954 (AEA) classifies facility licenses as commercial

Section 106 of the AEA classifies Section 103 commercial facilities as production or utilization facilities

Therefore, the Xe-100 facility under 10 CFR 50 or 52 is currently classified as a Section 103 commercial utilization facility Brandon Hartle Xe-100 Operations Licensing

Xe-100 Licensing Pathway

Draft 10 CFR 53.800 provides the definition and criteria of the Self-Reliant-Mitigation Facility (SRMF), which is a new class of a Section 103 commercial facility As part of the NRCs approval of an applicants OLA, a Section 103 commercial nuclear plant is an SRMF if it demonstrates compliance with the criteria of draft 10 CFR 53.800(a)(1) through (a)(5)

Draft 10 CFR 53.805 through 53.820 provides the requirements of Generally Licensed Reactor Operators (GLROs)

GLROs are required to manipulate the controls of facilities that meet the criteria of draft 10 CFR 53.800(a)(1) through (a)(5)

The design of the Xe-100 facility meets the criteria of draft 10 CFR 53.800(a)(1) through (a)(5)

Therefore, X-energy is seeking a licensing pathway for the Xe-100 facility for the following:

To be classified by the NRC as a Section 103 commercial SRMF by demonstrating compliance with the criteria of draft 10 CFR 53.800(a)(1) through (a)(5)

To be classified as an SRMF for current and prospective applicants under 10 CFR 50, 52, and 53 once finalized When classified as an SRMF, applicants under 10 CFR 50 or 52 have operators that resemble GLROs via Part 55 exemptions, and applicants under draft 10 CFR 53 have GLROs Brandon Hartle Xe-100 Operations Licensing

Xe-100 Self-Reliant-Mitigation Facility Approach

For applicants of an Xe-100 facility under 10 CFR 50 or 52, and 10 CFR 53 once finalized, the OLA or combined OLA demonstrates the following:

Xe-100 safety performance criteria are met without reliance upon human action for credited event mitigation The results of the Xe-100 probabilistic risk assessment demonstrate the evaluation criteria for the analyzed events are met without reliance upon human action to achieve acceptable event mitigation The Xe-100 functional requirements analysis and function allocation demonstrate functions required for safety are not reliant upon credited human action The Xe-100 plants response to analyzed events relies exclusively on the safety features and characteristics of the Xe-100 and will not be rendered unavailable by human errors of omission or commission The Xe-100 plant design provides layered defense-in-depth that is not dependent upon any single barrier or credited human action

The Xe-100 facility meets the criteria of draft 10 CFR 53.800(a)(1) through (a)(5) for an SRMF Brandon Hartle Xe-100 Operations Licensing

Xe-100 Control Room Operator Qualification

Section 107 of the AEA requires the Commission to prescribe uniform conditions for licensing individuals as operators

For Xe-100 facility applicants under 10 CFR 50 or 52, licensed control room operators (CROs) are required per 10 CFR 55 Since the Xe-100 facility meets the criteria of an SRMF, licensing Xe-100 CROs per 10 CFR 55 is not feasible For the Xe-100 facility, many of the requirements in 10 CFR 55 meet the criteria for specific exemptions defined in 10 CFR 55.11 X-energy expects Xe-100 facility applicants to submit exemptions to 10 CFR 55 to provide for the licensing of CROs that resembles GLROs in Draft 10 CFR 53 The exemptions will allow Xe-100 facility applicants to realize the safety benefits of the Xe-100 while still meeting Section 107 of the AEA

For Xe-100 facility applicants under 10 CFR 53 once finalized, applicants will comply with the requirements of 10 CFR 53.805 through 820 once finalized for GLROs Brandon Hartle Xe-100 Operations Licensing

Proposed Future Engagement

X-energy plans to submit a white paper describing the regulatory pathway and approach to the Xe-100 facility being classified as Section 103 commercial SRMF

X-energy requests the NRCs feedback on the white paper for the following:

The Xe-100 facility can be classified by the NRC as an SRMF by demonstrating compliance with the criteria of 10 CFR 53.800(a)(1) through (a)(5) once finalized The Xe-100 can be classified as an SRMF for current and prospective applicants under 10 CFR 50, 52, and 53 once finalized When classified as an SRMF, Xe-100 facility applicants under 10 CFR 50 and 52 can have operators that resemble GLROs to promote regulatory efficiency via 10 CFR 55 exemptions When classified as an SRMF, Xe-100 facility applicants under 10 CFR 53 once finalized can have GLROs at the controls of an Xe-100

X-energy plans to submit the white paper at the end of August 2025

X-energy requests feedback on the white paper by the end of March 2026 Brandon Hartle Xe-100 Operations Licensing

Questions and Feedback

Rockville, MD 20850

ML26048A325

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