ML18019A158

X-Energy, LLC - Updated Design and Licensing Submittal Information NRC Regulatory Issue Summary (RIS) 2017-08 - Process for Scheduling and Allocating Resources for Fiscal Years 2020 Through 2022 for the Review of New Licensing Applications

ML18019A158
Person / Time
Site:	PROJ0818
Issue date:	01/16/2018
From:	Bowers H X-Energy
To:	Amy Cubbage Document Control Desk, Office of New Reactors
References
RIS 2017-08, XE00-R-R1-RD-L-000027
Download: ML18019A158 (5)

See also: RIS 2017-08

Text

X-energy January 16, 2018 Ms. Amy Cubbage U.S. Nuclear Regulatory

Commission

ATIN: Document Control Desk Washington, D.C. 20555-0001

Subject: UPDATED DESIGN AND LICENSING

SUBMITIAL

INFORMATION

NRC REGULATORY

ISSUE SUMMARY (RIS)2017-08

PROCESS FOR SCHEDULING

AND ALLOCATING

RESOURCES

FOR FISCAL YEARS 2020 THROUGH 2022 FOR THE REVIEW OF NEW LICENSING

APPLICATIONS

FOR LIGHT-WATER

REACTORS AND NON-LIGHT-WATER

REACTORS X Energy, LLC 7701 Greenbelt

Road Suite 320 Greenbelt, MD 20770 +1301-358-5600

XEOO-R-Rl-RD-L-000027

The purpose of this letter is to submit responses

to Regulatory

Issue Summary (RIS) 2017-08 on behalf of X Energy, LLC (X-energy").

This submission

also updates the prior X-energy submitted

responses

to RIS 2015-07 (response

dated November 23, 2015) and RIS 2013-18 (response

dated March 28, 2014). X-energy is a private, wholly-owned

U.S. company that is pursuing the commercialization

of an advanced high temperature

gas-cooled

pebble bed reactor (HTGR), designated

as Xe-100 (X-energy

200 MWt), using U.S.-developed

uranium oxicarbide (UCO) TRISO-coated

particle fuel, in conjunction

with NRC approval.

X-energy's

design approach leverages

over 50 years of research, proven design, and operational

experience

in HTGR using a pebble bed architecture.

In addition to developing

the design of the Xe-100 pebble bed reactor, X-energy, through a US DOE cooperative

agreement, is actively fabricating

UCO based kernels, TRISO particles, and spherical

pebble fuel elements in a well-equipped, X-energy operated facility at the Oak Ridge National Laboratory (ORNL). In the future, this work in TRISO-based

fuel element production (referred

to as our "TRISO-X" program) will be spun off into a separate fuel fabrication

company that will ultimately

provide fuel for all UCO TRISO-based

reactor designs, which may include some Accident Tolerant Fuel (ATF) designs applicable

to the existing fleet of light water reactors.

The Xe-100 design and TRISO fuel manufacturing

are well aligned with, and leverage, the Department

of Energy's (DOE) Next Generation

Nuclear Plant (NGNP) and Advanced Gas Reactor (AGR) fuel qualification

initiatives, _with the fuel qualification

program established

as the number 1 priority by the Energy Policy Act of 2005 (EPACT2005).

In fact, the on-going TR ISO-based

fuel fabrication

activities

at ORNL take place in the laboratory

previously

used to produce AGR qualification

test articles.

The Xe-100 utilizes intrinsically

safe features with a simplified

plant design to assure enhanced safety and security.

Furthermore, the Xe-100 offers several inherent features reducing proliferation

risks and, with the potential

to utilize a future thorium-based

fuel cycle, has the capacity to recycle spent fuel and reduce current stockpiles

of plutonium

with the very high burn-ups inherent to the Thorium fuel cycle. X-energy has no affiliation, official or otherwise, with any other company working on the pebble bed approach to HTGRs. X-energy is U.S.-owned

and operates out of facilities

in Greenbelt, Maryland and Oak Ridge, Tennessee.

MD O:) y&ol {\) f_ 0

U.S. Nuclear Regulatory

Commission

January 16, 2018 X-energy's

responses

to RIS 2017-08 contains commercially

sensitive

proprietary

information

and, as such, we are requesting

that this information

be withheld from public disclosure

in accordance

with 10 CFR 2.390, "Public inspections, exemptions, request for withholding," paragraph (a)(4). Since Commercially

Proprietary

information

constitutes

much of replies herein, a public version is not being submitted.

Accordingly, Enclosure

1 is the Non-Public

version of energy's responses

to RIS 2017-08 which contains non-redacted

sensitive

information.

This proprietary

information

is appropriately

marked and an affidavit

providing

the basis for this request is provided in Enclosure

2. Sincerely, President

X Energy, LLC Cc: Amy Cubbage, NRC, TWFN (NRO/DSRA/ARPB)

James Hammelman, NRC, TWFN 4 A60 John Monninger, NRC TWFN 9 F41 John Segala, NRC, TWFN (NRO/DSRA/ARPB)

Brian Smith, NRC, RGN-1 (R-I/DRP/PB4/BRO)

Enclosures:

1) Response to RIS 2017-08 2) Affidavit

Page 2 of 20

X-energy Affidavit

Page 18 of 20 Enclosure

2 to X-energy Letter XE-X1-LD-GO-L03-100264

X-energy Enclosure

2 to X-energy Letter XE-X1-LD-GO-L03-100264

I, Harlan W. Bowers, President

of X-Energy, LLC (X-energy)

do hereby affirm and state: 1. I am authorized

to execute this affidavit

on behalf of X-energy.

I am further authorized

to review information

submitted

to or discussed

with the Nuclear Regulatory

Commission (NRC) and apply for the withholding

of information

from disclosure.

The purpose of this affida-vit

is to provide the information

required by 10 CFR 2.390(b) in support of X-energy's

request for proprietary

treatment

of certain commercial

information

submitted

in enclosure

1 to X-energy's

letter, XE-X1-LD-GO-L03-100264, from myself to the NRC which provides response to Regulatory

Issues Summary (RIS) 2017-08. 2. I have knowledge

of the criteria used by X-energy in designating

information

as sensitive, proprietary, or confidential.

3. Pursuant to the provision

of paragraph (a)(4) of 10 CFR 2.390, the following

is furnished

for consideration

by the NRC in determining

whether the information

sought to be withheld from public disclosure

should be withheld.

a. The information

sought to be withheld from public disclosure

in Enclosure

1 is owned by X-energy, its affiliates

or third parties to whom X-energy has an obligation

to maintain its confidentiality.

This information

was prepared with the explicit understanding

that the information

itself would be treated as proprietary

and confidential

and has been held in confidence

by X-energy.

b. The information

sought to be protected

in Enclosure

1 is not available

to the public to the best of my knowledge

and belief. c. The information

contained

in Enclosure

1 is of the type that is customarily

held in confidence

by X-energy, and there is a rational basis for doing so. The information

X-energy is requesting

to be withheld from public disclosure

includes commercial

information

related to on-going and planned activities

associated

with our Xe-100 high temperature

gas pebble bed reactor design and the X-energy TRISO-X fuel program. X-energy limits access to this privileged

information

to maintain confidentiality.

d. Enclosure

1 contains information

about the planned activities

of X-energy related to the creation and submittal

of licensing

activities, forecast design development

timeframes, fuel fabrication

facility deployment

plans, and commercial

strategy of our Xe-100 advanced reactor. Public disclosure

of the information

contained

in Enclosure

1 would create substantial

harm to X-energy because it would reveal valuable business information

regarding

X-energy's

competitive

expectations, assumptions, current position and strategy.

Its use by a competitor

could substantially

improve their competitive

position in the design, manufacture, licensing, construction

and operation

of a similar product. Page 19 of 20

X-energy Enclosure

2 to X-energy Letter XE-X1-LD-GO-L03-100264

e. The Proprietary

Information

contained

in Enclosure

1 is transmitted

to the NRC in confidence

and under the provisions

of 10 CFR 2.390; it is to be received in confidence

by the NRC. The information

is properly marked. I declare under the penalty of perjury that the foregoing

is true and correct. Executed on J af'M,UN~ [1 j 20 ( 8 [Month Day, Year] Harlan W. Bowers President

X Energy, LLC Subscribed

and sworn to before me, Notary Public, this/?'" day oifo "'"jP My Commission

expires: \' 11,l,'*1 1 1 , 1111 , ,,,\ ,. /' I;' ,..._.., __________

_, WANDA HOLBROOK Notary Public Anne Arundel County Maryland ' -~ \ ' ' .. ..:. , ... .. My Commission

Expires: g-; d-~:. '. I Page 20 of 20