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,'*111,1111, ,,,\ ,. /' I;' ,..._..,

__________

_, WANDA HOLBROOK

Notary Public Anne Arundel County Maryland

' -~ \ ' ' .. ..:. , ... .. My Commission

Expires:

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