ML18019A158
| 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