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[External_Sender] Slides for Discussion 7/13 Attachments:

NRC presentation Dow Seadrift Site_Subsurface Investigation Approach - July 13 2023 (1).pdf; NRC Presentation - ARDP Env Engagement Status July 13 2023.pdf Good morning, Please find attached the slides for the discussion to be taking place July 13th.

Thank you for your patience.

Kind regards, Jessa Jessa Hultgren Licensing Project Manager Mobile: 603.818.0285 jhultgren@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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SA1P110MB1613.NAMP110.PROD.OUTLOOK.COM Files Size Date & Time MESSAGE 976 7/11/2023 11:25:47 AM NRC presentation Dow Seadrift Site_Subsurface Investigation Approach - July 13 2023 (1).pdf 5026890 NRC Presentation - ARDP Env Engagement Status July 13 2023.pdf 2540915 Options Priority:

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ARDP Dow Site Subsurface Investigations Approach Milton Gorden, Siting and Environmental Manager, X-energy Bill Elzinga, WSP Environmental Report Manager, WSP Jeff Mann, WSP PSAR Manager, WSP July 13, 2023

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

Proposed Groundwater Investigations Proposed Geology, Geotechnical, and Seismic Investigations Agenda Objectives:

NRC Staff feedback on hydrological and geotechnical approaches

Proposed Groundwater Investigations

Environmental Report 10 CFR Part 51.45 Environmental Report NUREG 1555, Regulatory Guide (RG) 4.2, Rev 3 Evaluate the effects of station building and operation on water resources Hydrology Water Use Water Quality Radiological Environmental Monitoring Program (including REMP)

Safety Analysis Report 10 CFR 50.34, 10 CFR 100.20(c), 10 CFR 100.21(d)

NUREG-0800, Chapter 2 Section 2.4.12 (hydrology, water use, parameters)

Section 2.4.13 (accidental release pathway analysis)

DANU-ISG-2022-02, Advanced Reactor Content of Application Project (ARCAP), Chapter 2, Site Information, May 2023 Consistent with current guidance Regulatory Requirements and Guidance: Groundwater

Source: Victoria ESPA Regional Stratigraphy Seadrift Site Source: USGS 2023. Geologic maps of US states.

Obtained from:https://mrdata.usgs.gov/geology/state/. Obtained: January 27, 2023.

Xe-100 Site

?

Three primary water-bearing zones at Seadrift Site:

A sands C sands E sands Hydrostratigraphy of Dow Seadrift Site Generalized East-West Cross Section - Dow Seadrift Site A Sand C Sand E Sand

Prior wells associated with Dow North Landfill (NLF) Area Other wells/borings associated with Dow Seadrift Site Borings associated with planned adjacent site investigations BH-140 Background Well Compliance Well Piezometer Existing Wells and Piezometers Adjacent to Project Site Xe-100 Project Area Existing Subsurface Information

A Sands Depth range:

20-25 ft bgs Direction of Flow:

East/Northeast Influenced by perched basins BH-140 Background Well Compliance Well Piezometer A Sands Directional Flow Geologic and Hydrologic Investigation Xe-100 Project Area

Direction of Flow:

West toward Victoria Barge Canal and Guadalupe River E Sands Depth: 110-160 ft bgs (10-30 ft thick)

Direction of Flow:

Expected to be similar to C Sands)

BH-140 Background Well Compliance Well Piezometer C Sands Directional Flow Xe-100 Project Area

1. Spatial configuration of the well array (vertical and horizontal placement) that properly allows characterization of appropriate water-bearing geologic formations.

2. Need to support data needs as per RG 4.2/NUREG 1555 for groundwater and soil physical parameters and groundwater water quality parameters.

3. Establishment of upgradient wells to act as monitoring locations for the potential constituent migration from the NLF area, and as background data for future construction and operation of the Xe-100 facility

4. Establishment of downgradient wells to facilitate monitoring of construction and operational effects.

5. Support for documentation of temporal variation in groundwater conditions.

6. Provide appropriate data for calculation of parameters for PSAR Chapter 2.

Objectives for Well Plan Development (ER and PSAR)

ER and PSAR Well Configuration Approximate Plant Development Area (includes geotechnical borings)

PSAR monitoring and testing wells SAR-1 to SAR 106 (well pairs screened in the middle and lower aquifers)

© 2023 X Energy, LLC, all rights reserved 14 Appendix A to 10 CFR 50, XE-100 Principal Design Criteria 2 Assessment of the potential impact of natural phenomena affecting the site is necessary to support a determination of adequacy of plant design and operation (same in RG 1.232 for mHTGR designs) 10 CFR 100 Reactor Site Criteria All seismic and geologic factors that may affect design/operation of proposed plant must be investigated Reg Guide 1.132, Sect C.4, Detailed Site Investigation Number and depths of core borings/ground water monitoring criteria established Reg Guide 1.208, Sect C.1, Geological, Geophysical, Seismological, and Geotechnical Investigation Comprehensive site area and regional investigations should be conducted to support performance-based approach to site specific earthquake ground motion NUREG/CR-5378, Field Investigations for Foundations of Nuclear Facilities The depth, layout, spacing of sampling borings, and sampling requirements for a site study depends on the subsurface requirements of the foundation (Also, RG 4.2, 4.7, NUREG-0800, etc.)

Regulatory Requirements and Guidance: Subsurface Investigations

Area (radius of 5 miles)

VCS STP MAT Geologic and Hydrologic Investigation Facility Approximate Distance from Site A

- Miles (kilometers)

Xe-100 at Site A n/a Matagorda (MAT) 49 (78)

South Texas Project (STP) 48 (77)

Victoria County Station (VCS) 17 (27)

Geologic and Hydrologic Investigation RG 1.132, Appendix D For favorable, uniform geologic conditions, where continuity of subsurface strata is found, the recommended spacing is as indicated for the type of structure.

At least three borings should be at locations within the footprint of every safety-related structure, unless other reliable information is available in the immediate vicinity or otherwise justifiable.

RG 1.132, Section C.5 Groundwater observation wells should be installed in as many locations as needed to adequately define the ground water environment.

Approximate Plant Development Area 0.6 mi/1 km radius

- Victoria ESP

- South Texas investigation

- Matagorda investigation

- Boring logs indicate relatively consistent soil densities and composition

- Subsurface profiles indicate relatively uniform strata thicknesses across the Seadrift area

- Including soil properties (permeabilities or transmissivities, storage coefficients or specific yields, total and effective porosities, clay content, and bulk densities)

ER and PSAR to utilize the same information, for continuity Subsurface explorations and laboratory testing will be conducted in accordance with NRC RG 1.132 to confirm the preliminary design basis evaluations and findings that will be presented in the PSAR.

These data will be incorporated into the design basis during final structural design and prior to construction.

Geotechnical Site Investigation - Historical Data

- Victoria ESP

- South Texas investigation

- Matagorda investigation

- Boring logs indicate relatively consistent soil densities and composition

- Subsurface profiles indicate relatively uniform strata thicknesses across the Seadrift area

- Including soil properties (permeabilities or transmissivities, storage coefficients or specific yields, total and effective porosities, clay content, and bulk densities)

ER and PSAR to utilize the same information, for continuity Subsurface explorations and laboratory testing will be conducted in accordance with NRC RG 1.132 to confirm the preliminary design basis evaluations and findings that will be presented in the PSAR.

These data will be incorporated into the design basis during final structural design and prior to construction.

Geotechnical Site Investigation - Historical Data

Disturbed and undisturbed sampling 24 SCPTs with select downhole geophysics Geotechnical Site Investigation App B Non-App B

P-S suspension logging

Shear wave velocity

Natural/spectral gamma

Resistivity and conductivity

Refraction and reflection

© 2023 X Energy, LLC, all rights reserved 21 Groundwater GW well for ER will be installed under 10 CFR 50 Appendix B for dual use in ER and PSAR PSAR wells installed under 10 CFR 50 Appendix B Geotechnical Meets intent of RG 1.132 Subsurface expected to be relatively uniform Number of borings driven by site layout and size of reactor building Non-Appendix B borings driven by investment protection rather than NRC guidance Seismic Shear wave velocity determination to assist in development of Probabilistic Seismic Hazard Analysis (PSHA) and Ground Motion Response Spectra (GMRS)

Summary

Rockville, MD 20852 x-energy.com @xenergynuclear X Energy, LLC

Project Definition and Execution Strategy Milton Gorden, Siting and Environmental Manager July 13, 2023

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

Safety Moment Site Overview Purpose and Need Alternatives Analysis Approach Site Characterization Activities Noninvasive Activities Meteorological Data Sources and Tower Approach to Geotechnical Investigations and Preliminary Safety Analysis Report (PSAR) -

related Groundwater Wells Environmental Report and PSAR Chapter 2 Submission Schedule Department of Energy Office of Clean Energy Demonstrations (DOE OCED) National Environmental Policy Act (NEPA) Actions Associated with the Project Agenda Objectives:

NRC Staff familiarity with the Proposed Xe-100 Site Location adjacent to Dow Seadrift Operations (SDO)

NRC feedback on use of nearby sources of data related to the South Texas Project, Victoria County Station, and nearby airports

NRC Staff familiarity with general site hazards to be assessed

NRC Staff feedback on Purpose and Need and Alternative Sites

NRC Staff update on site characterization activities and feedback on meteorological data usage

NRC Staff feedback on Environmental Report (ER) and PSAR Chapter 2 submission schedule

NRC Staff update on DOE OCED NEPA activities

Wide Variety of Hazards - Site Specific Poison oak/ivy/sumac Poisonous/dangerous animals and insects Know your site Identify Flora/Fauna that can put workers at risk Develop safety measures to minimize chance of contact Address in HASP and in daily toolbox meetings Safety Moment - Workplace Hazards Associated with Flora/Fauna

THIS IS SDO How can we work together to solve todays complex challenges?

PEOPLE EMPLOYED MANUFACTURING UNITS FOOTPRINT ANNUAL PRODUCTION

~1,400 11 Units 4700 acres 4B Lbs.

+1 iPark (Braskem/WatCo)

Construction began in 1952 with initial startup in 1954.

Joined Dow with Union Carbide Corp. Merger in 2001 of people leaders participate in Dow ERGs Site History Employee Resource Group (ERG) Participation Products 40+

Our products are shipped through rail, barge, and truck Approaching 70 years of community partnership 10 Dow ERGs 100%

Products Made Added F-Unit in 2017 (formerly DuPont)

Continuous (24 Hour) Operations ADN/MENA DEN GAAN GLAD HLN RISE PR!ME VetNet WIN ADN/MENA - Asian and middle east / north African network DEN - Disability employee network GAAN - African American network GLAD - LBGTQ+ network HLN - Hispanic Latino Network RISE - new employees PR!ME - experienced employees VetNet - veterans network WIN - Womens network

Dow Seadrift Location

Proposed Site

Distance and Elevation in Relation to Nearby Facilities Facility Approximate Distance from Site A -

Miles (kilometers)

General Elevation above Sea Level -

Feet (meters)

Xe-100 at Site A n/a 27 (8)

South Texas Project (STP) 48 (77) 29 (9)

Victoria County Station (VCS) 17 (27) 80 (24)

Victoria Regional Airport 25 (40) 115 (35)

Port Lavaca Airport 10 (16) 30 (9)

STP - Nearest operating Nuclear Power Plant. Two Westinghouse 1280 MWe Pressurized Water Reactors VCS - Exelon-proposed two 1535 MWe General Electric-Hitachi Simplified Boiling Water Reactors (application accepted by the NRC but withdrawn by Exelon in 2012)

10 CFR 50.34, Xe-100 Principal Design Criteria (PDC) 2, 10 CFR 100.20(b)(c), 10 CFR 100.21(d)(e), 10 CFR 100.23 - Requires man-made hazards and environmental hazards to be evaluated NUREG-0800, Chapter 2 Uses a traditional approach Provides guidance on evaluating man-made hazards, meteorological hazards, floods, potential dam failures, surge and seiche flooding, tsunami hazards, ice effects, seismic, etc.

Uses deterministic-based evaluations that tend to be conservative NEI 18-04 Uses a risk-informed performance-based approach (X-energy will be FOAK user)

PSAR Chapter 6 identifies the Design Basis Hazard Levels (DBHLs)

DBHLs are limits that the Safety-related (SR) SSCs must withstand Hazard screening technical requirements allow hazards to be screened out of the PRA For example, hazards < 10-7/plant-year can be screened out Draft Interim Staff Guidance, DANU-ISG-2022-02, Advanced Reactor Content of Application Project, Chapter 2, Site Information, May 2023 License Basis Event (LBE) selection methodology was addressed in the NEI 18-04 Licensing Topical Report (Revision 2 received a Safety Evaluation from the NRC). Pre-submittal meeting for Chapter 3 content planned for summer 2023.

LBE analysis methodology will be addressed more fully in Licensing Topical Report Transient and Safety Analysis Methodologies to be submitted to the NRC in November 2023.

Hazard assessment approach in PSAR Chapter 2 planned to be presented to the NRC Staff in September 2023 Hazard Analysis Regulatory Basis

PMSS event for this site would be a probable maximum hurricane Analysis will assume storm surge, high tide, and sea level rise due to climate change in next 60 years consistent with NUREG/CR-7046, Design-Basis Flood Estimation for Site Characterization at Nuclear Power Plants in the Unites States of America, Regulatory Guide (RG) 4.7, and latest technical reports from the National Oceanic and Atmospheric Administration and Intergovernmental Panel on Climate Change Probable Maximum Flood (PMF) in Streams and Rivers Will address the Guadalupe River Basin Includes wind set-up and wave run-up Uses information from Victoria County Station to develop the Design Basis Hazard Level (DBHL)

Dam Failure 29 dams on Guadalupe River in Calhoun County, TX Assume largest dam failure Will use Victoria County Station analysis as a basis to develop the DBHL Probable Maximum Precipitation (PMP)

Will assume all storm drains, culverts, and catch basins are clogged For a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, 5.33 in/hr (13.54 cm/hr) rainfall over 10 sq. miles (26 sq. km), the PMP would be 32 inches (81 cm)

Will use same approach as Victoria County Station analysis to develop the DBHL Floods

Four underground pipelines to the East of the proposed site One 12-inch ethylene liquid pipeline (probabilistic analysis)

Two 6-inch propane gas pipelines (probabilistic analysis)

One non-operational line (probabilistic analysis)

Three underground pipelines to the North-East One 30-inch natural gas pipeline (deterministic analysis)

One 6-inch propylene pipeline (probabilistic analysis)

One 6-inch propane pipeline (probabilistic analysis)

Chemical storage in Railcars Primarily ammonia Detection and isolation features and procedures can address chemical hazard concerns Chemical Hazards

© 2023 X Energy, LLC, all rights reserved 13 RG 1.91 states that an explosive overpressure of 1 psid is appropriate for a damage criterion. X-energy may be able to demonstrate some structures can withstand up to 3 psid without loss of function Stationary Blasts Per 49 CFR 179.13, chemical max. mass in a railcar would lead to 1 psid overpressure at 0.6 miles and 3 psid overpressure at 0.3 miles (0.5 km)

Dow plant information for postulated overpressures will be incorporated into Xe-100 facility analyses Flammable Vapor Clouds 49 CFR 179.13 max. railcar release has a standoff distance of 0.5 miles (0.8 km) to the lower explosive limit Ethane from a pressurized pipe has a standoff distance of 0.22 miles (0.35 km) to the lower explosive limit Ethylene from a pressurized pipe has a standoff distance of 0.67 miles (1.1 km) to the lower explosive limit For the 30-in (0.76 cm) natural gas pipeline, a probabilistic analysis is needed, but is expected to show a 0.5-mile distance is acceptable Explosive Overpressure

© 2023 X Energy, LLC, all rights reserved 15 Purpose and Need The purpose of the Xe-100 is to replace three aging natural gas cogeneration units at the Dow Seadrift Plant: (1) provide high-quality steam, (2) provide electricity, and (3) assist Dow in meeting their corporate decarbonization goal of being carbon neutral by 2050.

Basis of Consideration for Alternative Sites Delivery of Steam Limits Distance of Candidate Sites from Receiving Plant Limiting distance to about 1.5 miles (2.5 km) from interconnection point into processes at receiving plant Would keep site on current Dow-owned property Eliminates many right-of-way impediments associated with being further away Purpose and Need and Site Alternatives Analysis Approach

Largest site (344 acres [139 hectares]). Buffered on all sides by Dow property. Current use is agricultural. No historic sites within Site A. Not significantly impacted by existing Dow pipelines. Good proximity to roads. Further from railyard than Site C.

Site B:

Site is split by Dow pipelines. Further from roads than Site A.

Site C:

Adjacent to Dow southwest railyard. Smallest acreage (166 acres [67 hectares]). Potential historic resource on Site C that would need to be investigated.

Site D:

Several underground pipelines, including non-Dow-owned pipelines, would need to be relocated. Possibility of other underground obstructions. Electrical substation proposed.

Site A is the Proposed Site Alternative Site Comparisons

© 2023 X Energy, LLC, all rights reserved 19 Ecological Surveys - Winter and Spring completed. No significant observations regarding Endangered or Threatened Species Noise Survey - To be completed by end of July 2023 Historic/Cultural Survey - Plan accepted by Texas State Historic Preservation Office. Survey to be performed by end of July 2023 Surface Water Quality Sampling - Spring completed. Assuming current Dow Seadrift permitted withdrawal and discharge locations pending further analysis Meteorological Data For Construction Permit Application, intent is to rely on existing data from South Texas Project Same elevation and relative proximity to the Gulf Meteorological tower to be erected using Regulatory Guide 1.23, Meteorological Monitoring Programs for Nuclear Power Plants. Data to be used for Final SAR in Operating License Application (confirmatory)

Environmental Report-related Groundwater Wells - Installation planned to begin in August with monitoring activities beginning in September Geotechnical Investigations and Preliminary SAR-related Groundwater Wells - Boring and groundwater well installation plan drafted. Requesting feedback from the NRC week of July 10, 2023 Site A Characterization Activities

The ER would be submitted within 6 months of the CPA initial submittal. The current schedule shows submittal by June 2024 The ER will contain all content except 6 months of groundwater data and Spring aquatic data, which will be submitted as a supplement by the end of 2024 PSAR Chapter 2 This chapter would be submitted in unison with the ER in whole, with exception of a complete dataset of groundwater data Initial groundwater modeling will rely on enough data to provide a defensible analysis Groundwater data and updated modeling (if necessary) would be submitted once all data is obtained as a supplement (or can recommend quarterly submittals of data)

Note: The supplemental groundwater data for the ER and PSAR Chapter 2 would be submitted outside the 6-month window from initial submittal (target: first quarter 2024) of the PSAR as required by 10 CFR 2.101. X-energy would submit an Exemption Request under 10 CFR 50.12.

Environmental Report and PSAR Chapter 2 Submission Schedule

Completed Categorical Exclusion for Noninvasive activities (OCED09040002CX)

NEPA evaluation of subsurface characterization activities is ongoing (to include installation of groundwater wells and performing geotechnical and seismic-related investigations and meteorological tower installation)

OCED will perform a NEPA review of preconstruction activities (those activities not defined as construction, as described in 10 CFR 50.10(a)(2) and RG 1.206)

OCED is performing a streamlined Environmental Assessment to address proposed construction and operational activities associated with the Helium Test Facility, to be located at the Horizon Center in Oak Ridge, Tennessee. The HTF will be a non-nuclear facility. Performance of this NEPA review is not expected to impact the schedule for the construction and operation of the HTF.

DOE-OCED NEPA Actions Associated with the Project

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