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,
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)
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
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
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