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May 3, 2018 Public Stakeholder Meeting on Possible Regulatory Process Improvements for Non-Light Water Reactors, Slide Presentations
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Public Meeting on Possible Regulatory Process Improvements for Advanced Reactor Designs May 3, 2018 Telephone Bridge (888) 793-9929 Passcode: 6479346 1

Public Meeting

Telephone Bridge (888) 793-9929 Passcode: 6479346 Opportunities for public comments and questions at designated times 2

Outline

Introductions

Insights from NuScale Power Standards Workshop DOE Update Guidance for MSR Research/Test Reactors Safety Focused Review of I&C Licensing Modernization Project Guidance Other Needed Guidance ?

Regulatory Engagement Plans Siting Issues Policy Issues, Future Meetings, Public Discussion 3

Insights from NuScale Power NuScale Slides 4

Standards Workshop 5

DOE Update DOE SLIDES 6

Guidance for Molten Salt Reactor Research and Test Reactors ORNL SLIDES 7

Safety Focused Review Instrumentation and Control I&C SLIDES 8

Licensing Modernization Project Guidance Document Technology Inclusive Risk Informed Performance Based ML18120A321 9

Other Needed Guidance Documents

?

10

Scope and Level of Detail Integrated Approach 11

Regulatory Engagement Plans ML18122A293 REP SLIDES 12

Siting Issues NEI SITING SLIDES 13

Policy Table, Future Meetings

& Public Discussion Comments on Stakeholder Meetings from Michael Keller, Hybrid Power Technologies

Untimely Announcement of Meetings

Public Participation Not Welcome

Request for Presentation to be Placed In Public Record

ML18122A250 14

Policy Table Previous Version ADAMS Acc. No. ML18010A484 Updated Version Work in Progress 15

Future Stakeholder Meetings Topics ?

June 4-5 Public Meeting - Licensing Modernization Emergency Planning Zones Fuel Cycle / Transportation June 14 Environmental Reviews July 26 Sept 13 Oct 25 Dec 13 16

ACRS Schedule (tentative)

Date Committee Topic June 19 Sub RIPB Guidance Aug 22 Sub EP Rulemaking Oct Full EP Rulemaking Oct 30 Sub RIPB Guidance 17

Public Comments / Questions 18

Acknowledgement & Disclaimer This material is based upon work supported by the Department of Energy under Award Number DE-NE0000633.

This report was prepared as an account of work sponsored by an agency of the United States (U.S.) Government. Neither the U.S. 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 U.S. Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the U.S. Government or any agency thereof.

DCA Review At-A-Glance Review Progressing Well Phase 1 was completed on schedule April 16 Phase 3 ACRS meetings beginning Chapter 7 and 8 first to Phase 3 (Summer 2018)

Expect to see SER with open items month or so before meeting Informed that Chapter 7 has no open items Fewer questions than prior DCAs Expect <1,500 RAIs

>1,000 RAI responses submitted 28 of 35 audits completed 5 of 14 DCA-related topical reports (LTRs) approved Total cost of review at high end of forecast

>115,000 NRC review hours Improved management by NRC of review Management plans for key issues RAI review metrics 3

NuScale Baseline DC Review Completed P3 - ACRS review of DCA SER w/OIs P5 - ACRS review 12/31/16 8/27/19 Adv SER w/no OIs 6/23/20 Rulemaking P1 - PSER and RAIs Jan 2021 4/16/18 2017 2018 2019 2020 2021 P2 - SER w/OIs NRC 5/16/19 P6 - FSER Accepted 9/08/20 Design Certified 3/15/17 Jan 2021 P4 - Adv SER w/no OIs 12/12/19 Total projected duration for NRC review and approval - 46 months 4

Key Accomplishments Since Docketing Highly integrated protection system (HIPS) LTR approved in May 2017 Non-1E LTR approved Dec 2017 Applicability of AREVA fuel methods LTR approved Nov 2017 DCA Revision 1 Submitted March 15 Revised all 10 parts of the DCA Incorporated 973 change packages EPZ Methodology LTR Rev 1 Submitted March 12 Added method for determining defense-in-depth Addressed all known NRC staff issues 5

Key Accomplishments (Contd)

Achieved alignment with NRC on Failed Fuel Fraction 0.066% for normal and accident conditions (compared to typical 0.25/1.0%)

Based on latest EPRI PWR fuel performance data Benefits include normal operations shielding calculations Retaining, for now, current SAR Chapter 15 assumption of 0.32% as operating margin Proposal to define credible in terms of regulations Simplifies approach across a number of regulations NRC appears open to proposal, though likely Policy Issue If accepted, would result in no credible events leading to core damage for NuScale design (DBE and BDBE)

Retain core damage scenario for EPZ regardless of likelihood 6

Ensuring Review Progresses Management Plans for key issue resolution Milestones - what, who and when will be accomplished Get alignment with NRC at least monthly Request for Additional (RAI) Information Metrics Track internal progress - update daily Track NRC progress - align monthly Licensing Audit progress Use of audit plans, periodic meetings, exit meetings NRC Safety Evaluation Report progress Track changes in review phase at chapter level Review drafts when available for proprietary review 7

RAI Metrics 8

RAI Metrics - Contd 9

EPZ Technical and Policy Issues Technical Core damage frequency cut-off justification (Black Swan)

Defense-In-Depth Near field source term dispersion External natural events Consistency with existing LLWR EPZ basis Accounting for analytical uncertainty Crediting non safety related SSCs Multi-module effects (if applicable)

Policy Alignment with SMR/ONT EPZ rulemaking Last line of defense and public protection consideration Public perception FEMA, state and local government dimensions 12 PM-0318-59093 NuScale Nonproprietary Revision: 0 Copyright © 2018 by NuScale Power, LLC Template #: 0000-20955-F01 R5

Pre-Application NRC Engagement LL Document pre-application agreements to avoid staff and management turnover issues during the review Key agreements on DCA level of detail, content of B2 SSCs (e.g. BOP), and means of documenting NRC approval Focus on Test Program PRA Simulator Seismic/Structural Unique Design Features - allow time for sufficient communication requires earliest scheduled multiple engagements Regulatory Gap Analysis Technical and Topical Reports (especially methodology) 13 PM-0318-59093 NuScale Nonproprietary Revision: 0 Copyright © 2018 by NuScale Power, LLC Template #: 0000-20955-F01 R5

Pre-Application NRC Engagement LL Attendance at NRC Pre-Ap meetings Right NRC and applicant technical and projects staff NRC management When policy-related, OGC Document detailed meeting minutes; compare with and provide input to NRC meeting summary 14 PM-0318-59093 NuScale Nonproprietary Revision: 0 Copyright © 2018 by NuScale Power, LLC Template #: 0000-20955-F01 R5

DCA Post-Submittal NRC Engagement RAIs Appropriate regulatory basis and operating experience Appropriate level of detail for a DCA and an NRC safety finding Clarification calls for both technical and regulatory reasons Document all NRC telecons Track similar RAI responses by previous DCAs Electronic Reading Room (eRR)

Supports audits Allows NRC access to read only, no printing, copying, or saving Audits Focused scope in audit plan with control during audit execution Reasonable schedule with defined documented milestones Appropriate level of detail for DCA review and safety finding 15 PM-0318-59093 NuScale Nonproprietary Revision: 0 Copyright © 2018 by NuScale Power, LLC Template #: 0000-20955-F01 R5

Licensing Advice to ARWG Closely follow NuScale RAIs and RAI responses Involve NRC in all ongoing and planned test plans and reports (e.g. topical, technical, white papers)

Develop a pre-application engagement plan and vet it with the NRC Commit real resources to NEI initiatives (e.g.,

ITAAC and physical security)

Obtain high-fidelity source documents with international experience on similar technology Obtain NRC agreement on IAEA SSC Classification 16 PM-0318-59093 NuScale Nonproprietary Revision: 0 Copyright © 2018 by NuScale Power, LLC Template #: 0000-20955-F01 R5

Summary Overall NuScales DCA review is going well NRC is executing its published schedule Generally appears to be improved NRC management discipline over review processes Further improvement in review processes can be achieved Clarification of review risks during pre-application critical 17 PM-0318-59093 NuScale Nonproprietary Revision: 0 Copyright © 2018 by NuScale Power, LLC Template #: 0000-20955-F01 R5

6650 SW Redwood Lane, Suite 210 Portland, OR 97224 971.371.1592 1100 NE Circle Blvd., Suite 200 Corvallis, OR 97330 541.360.0500 11333 Woodglen Ave., Suite 205 Rockville, MD 20852 301.770.0472 2815 Coliseum Centre Dr., Suite 230 Charlotte, NC 28217 980.349.4804 1933 Jadwin Ave., Suite 130 Richland, WA 99354 1st Floor Portland House Bressenden Place London SW1E 5BH United Kingdom

Trevor Cook Summary of DOE Advanced Reactor Activities Manager, Advanced Reactor Licensing Program Office of Nuclear Energy NRC Public Meeting on Advanced Reactors U.S. Department of Energy May 3, 2018

DOE-NE MISSION AND PRIORITIES DOE-NE MISSION MISSION PRIORITIES

Advance nuclear power as a resource capable of making major contributions in meeting our Nations energy supply, environmental and Existing Fleet energy security needs

Seek to resolve technical, cost, safety security, and regulatory issues through RD&D Advanced Reactor Pipeline

By focusing on the development of advanced nuclear technologies, support the goals of providing domestic sources of secure energy, Fuel Cycle Infrastructure reducing greenhouse gases, and enhancing national security.

RD&D INFRASTRUCTURE TREAT VTR ADVANCED REACTORS LWR LIFE EXTENSION (80 yrs) NUCLEAR HYBRID ENERGY LWR LIFE EXTENSION (60 yrs) ADVANCED LWR FUELS SUSTAINABLE FUEL CYCLE USED FUEL STORAGE SMALL MODULAR REACTORS GEOLOGIC REPOSITORY 2010 2020 2030 2040 2

ADVANCED REACTOR TECHNOLOGIES FOCUS AREAS Advanced Light Water Reactors Fast Reactor Technologies

Demonstrate feasibility of advanced systems and component technologies

Methods and code validation to support design and licensing

Advanced alloy materials qualification for metal-cooled systems TerraPower Gas Reactor Technologies MCFR

Advanced alloy and graphite materials qualification for high temperature gas-cooled systems

Scaled integral experiments to support design and licensing

TRISO-coated particle fuel development and qualification Molten Salt Reactor Technologies

Investigate fundamental salt properties GA Gas-cooled

Materials, models, fuels and technologies for salt-cooled and salt-fueled Fast Reactor reactors Cross-Cutting technologies

Advanced energy conversion

Supercritical Carbon Dioxide (sCO2) Brayton Cycle

Micro reactors for remote defense and commercial applications NuScale PWR GE Hitachi PRISM 3

VERSATILE TEST REACTOR (VTR)

IN SUPPORT OF ADVANCED REACTOR TECHNOLOGIES NEAC Advice:

The need for a VTR was established through a series of independent surveys of the potential U.S. user community (industry, DOE programs) and support from international partners resulting in a NEAC report (Assessment of Missions and Requirements for a new U.S. Test Reactor 2/2017); it states that The Ad Hoc NEAC subcommittee recommends that DOE-NE proceed immediately with pre-conceptual planning activities to support a new test reactor (including cost and schedule estimates).

Goals:

3 year R&D effort, along with appropriate reviews and planning, leading to an operational VTR by 2026

VTR would support accelerated development of advanced fuels and materials for U.S.

advanced reactor vendors, as well as to provide the capability for testing those fuels and materials to support licensing by the Nuclear Regulatory Commission.

VTR with a high fast neutron flux would revitalize our research infrastructure and remove a critical impediment for U.S. developers of advanced nuclear energy technologies.

Constructed and operated under DOE authority, in close collaborations with NRC.

$35 million in 2017 Omnibus Bill for versatile fast test reactors R&D activities to achieve CD-0 in January 2019. 4

DRAFT REQUIREMENTS/ASSUMPTIONS OF VERSATILE TEST REACTOR (VTR)

1. Approach to Design: Conducting a 3 year research & development effort on core design.

2. Reach fast flux of approximately 4.E15 n/cm2-s, with prototypical spectrum

3. Load factor: as large as possible (maximize dpa/year to > 30 dpa/year)

4. Provide flexibility for novel experimental techniques

5. Be capable of running loops representative of typical fast reactors (Candidate Coolants: Na, Lead, LBE, Gas, Molten Salt)

- May be a single location with replaceable loops.

6. Effective testing height 1 m

7. Ability to perform large number of experiments simultaneously 4

8. Metallic driver fuel (possible options: LEU, Pu, LEU+Pu) 5

NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors Overview of Proposed Revision for Nonpower Molten Salt Reactors Randy Belles, ORNL George Flanagan, ORNL Marcus Voth, Boston Government Services Advanced Reactor Meeting, May 3, 2018 ORNL is managed by UT-Battelle for the US Department of Energy

Development of nonpower MSR test facilities is under consideration to support the multiple analyses needed for development of full-scale MSRs

Generates a need to look at the applicability of existing licensing guidance to non-power liquid-fueled molten salt reactors (MSRs)

Presentation Outline

- Background on NUREG-1537

- Chapters proposed for revision

- History of Aqueous Homogeneous Reactor (AHR) Interim Staff Guidance (ISG)

- MSR issues and challenges

- Summary of major changes to each chapter 2 Overview of NUREG-1537 Proposal for MSRs

NUREG-1537 is used by an applicant or licensee of a non-power reactor for a new license, license renewal, or license amendment

Covers all aspects of non-power reactor licensing (issued 1996)

- No GDCs

- No PRA

Part 1 describes acceptable format and content of the safety analysis report (SAR) to be submitted to the NRC by an applicant or licensee

- Corresponds to RG 1.206/RG 1.70 for commercial power reactors

Part 2 gives criteria to assist NRC staff reviewers in performing comparable, complete, and consistent reviews of licensing applications

- Corresponds to NUREG-0800 for review of LWRs 3 Overview of NUREG-1537 Proposal for MSRs

NUREG-1537 content is similar to NUREG-0800 Table of Contents 10 - Experimental Facilities 1 - Facility 11 - Radiation Protection and Waste 2 - Site Characteristics Management 3 - Design of SSC 12 - Conduct of Operations 4 - Reactor Description 13 - Accident Analyses 5 - Reactor Coolant Systems 14 - Technical Specifications 6 - Engineered Safety Functions 15 - Financial Qualifications 7 - Instrumentation and Controls 16 - Other Licensing Considerations 8 - Electrical Power Systems 17 - Decommissioning 9 - Auxiliary Systems 18 - HEU to LEU Conversions 4 Overview of NUREG-1537 Proposal for MSRs

Most NUREG-1537 Chapters are applicable as-is Table of Contents 10 - Experimental Facilities 1 - Facility 11 - Radiation Protection and Waste 2 - Site Characteristics Management 3 - Design of SSC 12 - Conduct of Operations 4 - Reactor Description 13 - Accident Analyses 5 - Reactor Coolant Systems 14 - Technical Specifications 6 - Engineered Safety Functions 15 - Financial Qualifications 7 - Instrumentation and Controls 16 - Other Licensing Considerations 8 - Electrical Power Systems 17 - Decommissioning 9 - Auxiliary Systems 18 - HEU to LEU Conversions 5 Overview of NUREG-1537 Proposal for MSRs

NUREG-1537 Chapter 13, Accident Analyses, was considered for revision

Chapter 13 subjected to a preliminary gap analysis review

Determined that further design-specific accident analysis information is necessary

Unfortunately, design-specific information is closely held by the active vendors

Accident analyses for the Molten Salt Reactor Experiment is available and informative, but is not appropriate for all design variations

Opted not to make any recommendations regarding Chapter 13 6 Overview of NUREG-1537 Proposal for MSRs

Proposed MSR revision of NUREG-1537 is based on 2012 AHR Interim Staff Guidance

In 2010 NRC initiated a multi-laboratory effort headed by BNL, supported by ORNL and ANL, to revise NUREG-1537 in anticipation of an AHR application to produce medical isotopes

Several chapters (4,5,6,9 and 13) were deemed design specific and were revised by the laboratory team

- Both volumes 1 and 2 were revised

- Extensive revisions were required to address the unique aspects of AHR designs 7 Overview of NUREG-1537 Proposal for MSRs

Report BNL 94462-2010 was submitted to NRC for consideration as an input for NUREG-1537 ISG

NRC used report information as a basis for the NUREG-1537 ISG

In 2012, NRC issued an ISG document for NUREG-1537 which contained revisions needed to review AHR submittals

AHRs have several features similar to liquid-fueled MSRs

- Fuel is in a liquid form

- Reactor vessel forms the first boundary to prevent release of fission products

- Off gas systems collect and treat volatile fission products including noble gases

- Systems for draining, refilling and polishing the fuel exist in AHRs

MSRs have unique aspects not found in AHRs, so it was necessary to revise the ISG to reflect these features 8 Overview of NUREG-1537 Proposal for MSRs

Proposed MSR update introduced issues to be addressed

AHR ISG influenced the proposed MSR update to NUREG-1537 ORNL/TM-2018/834 Limited distribution as ORNL/SR-2017/313-R1 9 Overview of NUREG-1537 Proposal for MSRs

Retained same document format, but this led to some difficulties

Current chapter content did not consistently conform to MSR technology

- Fuel

- Coolant

- Heat transfer

Unique MSR attributes were not covered

- Arbitrarily inserted system and process discussions

- May need to consider revised organization for a more optimized review

No generic MSR design

- Nothing is design-specific; designs protected by NDAs

- Different salts and neutron spectrums to consider 10 Overview of NUREG-1537 Proposal for MSRs

Generic MSR definitions are necessary

Consistent system and component references

Heat transfer loop references

Proposed several fundamental process definitions for discussion:

- Heat Dissipation System

- Active Reactor Core

- Neutron Moderator

- Coating

- Primary Cooling System

- Control Element

- Reactor Fuel

- Emergency Cooling System

- Vessel

- Fission Product Barrier

- Fuel Barrier

ANS 20.2, MSR Standard, will

- Fuel System Boundary be the ultimate document for definitions 11 Overview of NUREG-1537 Proposal for MSRs

MSRs have unique reactor control issues

Delayed neutron drift

- Flowing fuel salt will cause some fraction of delayed neutrons to be born outside the active reactor core

- Impact on ability to control the reactor

Flow changes

Fuel composition changes MSRE Control Elements Source: ORNL-4123

Discussion - chapter 4

Control elements

- Act through fuel displacement, neutron absorption, neutron reflection, neutron spectral adjustment, or a combination of these methods

- Solids, liquids, or gases

System discussion - chapter 4

System cooling - chapter 5 or 9 - no specific reference except in chapter 4 12 Overview of NUREG-1537 Proposal for MSRs

MSRs are chemistry-based machines

Off gas from fission products

- Affects core geometry/density/power

- Leads to need for a gas management system

System discussion - chapter 4; System cooling - chapter 9 MSRE Mark 1 Offgas Particle Trap

Fuel cleanup or polishing system

- Optional depending how designer chooses to address fission product poisons

- Coordinates with online fuel additions, salt makeup, and fuel chemistry

Impact on fuel chemistry - chapter 4 under Nuclear Design

System description - chapter 5; System cooling - chapter 9

Fuel salt chemistry

- Need to understand the short-term and long-term changes in chemistry

- Fuel Technical Specifications

Importance - chapter 4 under Reactor Fuel 13 Overview of NUREG-1537 Proposal for MSRs

MSR Reactor Description and Reactor Coolant Systems are Intertwined

Fuel and coolant are a homogenous mixture

- No cladding Secondary

- Importance of fuel salt system boundary integrity Heat Exchanger

- Fuel salt heat transport Primary Coolant Loop

Thermal-hydraulics - chapter 4

System description - chapter 5 Ultimate Heat

- Primary cooling system Primary Heat Sink

System description - chapter 5 Exchanger Fuel Salt

- Heat Dissipation System Active

Ultimate heat sink Reactor Core

System description - chapter 5 14 Overview of NUREG-1537 Proposal for MSRs

Support systems must be considered

Drain Tanks

- Need for maintenance and possibly as an ESF system (MSRE)

- Consideration for fuel salt and coolant salt

System discussion - chapter 5 Waste Storage

System cooling - chapter 9 Natural ion F iss s Uranium ile ct lat ocdu

Waste treatment and storage o

V Pr FS-MSR

- Describe process - no intention of producing special Salt Core nuclear material (SNM)

- Production versus Utilization Facility Particle Filter No Salt ble

System discussion - chapter 11 Pro Fis du sion cts

System cooling - chapter 9 Waste Storage 15 Overview of NUREG-1537 Proposal for MSRs

Fuel handling presents challenges

New and Used Fuel

- Criticality concerns

- Stability

- Solid or liquid

- Safeguards

- Receipt, storage, dissolution, blending

System discussion - chapter 9

System cooling - chapter 9 ORNL Review 16 Overview of NUREG-1537 Proposal for MSRs

Wrap-up with a brief look at the updated chapters 17 Overview of NUREG-1537 Proposal for MSRs

The distinction between Chapters 4 (Reactor Description) and 5 (Reactor Coolant Systems) blurs for MSRs chapter 4

Chapter 4 focus is on heterogeneous fuel elements consisting of fuel rods and fuel cladding acting as the initial fission product barrier

- Protect the clad (AOOs) and maintain cooling (DBAs)

MSRs operate with homogeneous liquid fuel and no cladding

- Initial fission product barrier shifts out to the fuel salt boundary

- Maintain the fuel salt system boundary

- Control fuel salt chemistry / redox control

MSR core conditions change over core life with fuel composition changes, fissile material buildup, and poisons

- Use of control elements

- Delayed neutrons 18

- Gas management Overview of NUREG-1537 Proposal for MSRs

The distinction between Chapters 4 (Reactor Description) and 5 (Reactor Coolant Systems) blurs for MSRs chapter 5

Chapter 5 focus is on the transfer of heat from the heterogeneous fuel elements to the ultimate heat sink

Maintain cooling to assure fission product barrier remains intact

The MSR fuel salt provides initial heat transfer to a coolant salt loop

Fuel salt cleanup, salt makeup, fuel makeup considered

Drain tank discussion added

Fuel salt loop

Coolant salt loop (primary cooling loop) 19 Overview of NUREG-1537 Proposal for MSRs

Chapter 6 (ESF) equipment may simply consist of one or more containment structures

Multiple confinement or containment boundaries might be included for an MSR design depending on the relative location of the gas management system and other cleanup systems

DRACS or drain tank could be ESF or analyses may show none needed Source: ORNL-TM-728 ECCS Equivalent Containment 20 Overview of NUREG-1537 Proposal for MSRs

MSR auxiliary systems discussed in Chapter 9 will need to evolve and expand to accommodate MSRs

Consider MSR fuel handling and storage of SNM used for reactor fuel (both new and irradiated)

- Systems (tanks, valves, pumps, instrumentation, controls), processes (chemical blending, SNM transfers, waste storage, preparation for shipment), criticality monitoring, vaults, shielding, and contamination control

Quantity of byproduct, source, and SNM differ from the use of heterogeneous fuel elements

- An effective means should be defined for limiting the SNM at the reactor site to establish an envelope used for safety and security analyses

- The mission of a test MSR facility should be evaluated to determine limits on the quantity of byproduct materials created by experiments and routine operation

Additional cooling systems should be described:

- Gas management system

- Drain tanks

- Other design-specific systems 21 Overview of NUREG-1537 Proposal for MSRs

Waste handling needs to be considered in Chapters 9 (Auxiliary Systems) and 11 (Waste Management)

Once operated, MSRs will contain gaseous, soluble and non-soluble fission products in the fuel salt

Some MSR designers will opt to remove gaseous and/or soluble fission products from the fuel salt

Without careful consideration in the SAR, the separation of fission products could possibly be viewed as a colocated SNM fuel cycle facility

This could lead to a complex licensing scenario

- 10 CFR 50 utilization facility Offgas Piping Near Pump and Overflow Tank

- 10 CFR 50 production facility (AHR ISG guidance) Source: ORNL-TM-3039

- 10 CFR 70 fuel cycle facility

- What is the process? What is the intent?

22 Overview of NUREG-1537 Proposal for MSRs

Summary

NUREG-1537 documents a performance-based approach for establishing design criteria and ensuring they are met

- Based on more than 50 years of experience with commercial and nonpower reactors using heterogeneous fuel

Adaptations for MSR technology must consider review processes that ensure the adequacy of proposed designs while recognizing the reduced operating experience with MSR designs

Proposed update provides clarity for performance-based MSR review by removing some of the ambiguity created when transitioning from discussion of heterogeneous fuels to homogeneous fuels

Proposed revisions will support DOE effort to assist MSR vendors with test facility licensing

- Reduce regulatory uncertainty 23 Overview of NUREG-1537 Proposal for MSRs

Instrumentation and Controls:

Safety-Focused Review Initiative Advanced Reactors Stakeholders Meeting May 3, 2018 Ian Jung, Chief Instrumentation, Controls and Electronics Engineering Branch Division of Engineering and Infrastructure Office of New Reactors 1

The staff is transforming I&C reviews Credit: br.depositphos.com 2

I&C: Instrumentation and controls

The I&C regulatory infrastructure is not optimal for future designs

Large light Industry Documents water reactors NUREGs Generic Communications

Increased Standards Regulatory Guides complexity and Interim Staff Guidance volume Standard Review Plan Regulations

Opportunities for safety focus, risk-informing, and simplicity What is the safety issue?

3

The staff innovated its review approach for SMRs US-APWR

Lessons learned from ESBWR U.S.EPR reviews of other large light AP1000 water designs ABWR

Design-Specific Review Standard (DSRS) Chapter 7

- Grassroots

- SRM-SECY-11-0024

- New

- NuScale

- Generically applicable

- Mindset/cultural change

- Cooperation with applicants 4

SRM: Staff Requirements Memorandum

DSRS Chapter 7 is simpler and more safety-focused

Emphasis on fundamental design principles

Risk-informed/safety focused review

Removed inapplicable items and duplications

Restructured staff guidance Simplicity in NUREG-0800

Lessons learned applied A1 A2 B1 B2 5

The new approach has been a huge success for NuScale

Highly effective

- Demonstrated principles

- Simplicity

- Easily understandable/explainable

Highly efficient

- 95% reduction of RAIs

- Significant reduction of staff hours and below the estimated

Significantly ahead of schedule

Applicant doing its part

- Cooperation with staff

- Cultural/mindset change 6

The Commission directed the staff to modernize

Integrated Action Plan

- SRM-SECY-16-0070

Regulatory infrastructure

- simpler, streamlined, and agile for new and advanced reactors.

- Principles/attributes, e.g.,

Performance-based

Technology-neutral

Consistent, durable, predictable, scalable

Unambiguous

Safe and secure 7

The staff is getting ready for future designs Near-term

Additional lessons learned and new DSRS DRS opportunities

New initiative started

- Create new, improved guidance for future design reviews in a timely manner ARS

- Building on DSRS

Close coordination Longer-Term

- Advanced reactors

- I&C modernization

- Innovation and transformation at the NRC 8

The staff plans to issue DRS in time for advanced reactors

Lessons learned from NuScale and APR1400

More: 1. What can go wrong?

- Risk-informed and 2. How likely is it?

performance-based 3. What are the consequences?

- Safety focus

- Technology-neutral

- Principles-based

- Agile/flexible

- Efficient/predictable

Balancing with defense-in-depth strategy 9

Success is ensured when

Success factors

- Cultural If you do what youve always done, you will get

- Initiative what youve always gotten. -Tony Robbins

- Applicant cultural/mindset change

Fundamentals

- Regulatory

- Technical

Principles

- Safety engineering

- Safety design 10

In summary

The staff initiated an innovative, safety-focused approach for I&C reviews applying lessons learned

The approach has been a huge success for NuScale

The staff is further transforming I&C reviews for future designs

The staff and stakeholders must work closely 11

Peter Hastings NRC STAFF COMMENTS ON REGULATORY May 03, 2018 ENGAGEMENT PLAN GUIDANCE DRAFT NRC Advanced Reactors

REGULATORY ENGAGEMENT PLAN (REP)

INTRODUCTION

Project scope: develop draft of REP template for industry and NRC review

Approach o Informed by prior licensing project plans, annual new reactor planning Reg Issue Summaries o Guidance: FAQ-like descriptions of underlying elements of template, including options

Overarching assumptions o Optional product o Flexible content & format

REP GUIDANCE DRAFT NRC STAFF COMMENTS

Comments received on draft revision 0M

Vast majority of comments incorporated, including overarching comment that comprehensiveness of guidance document could be intimidating

Few comments for discussion

COMMENTS

Developers should prepare a regulatory engagement plan as an early step in the overall program[and] should pay particular attention to near-term activities needed to support the critical decision process o Agreed; will include o Consistent caveats to reinforce REP as optional

The regulatory engagement plan and the associated NRC review plan should define the expected outcomes from early interactions (e.g., initial, conditional, conclusive, or final) and related matters such as costs and schedules.

o Agreed; will include o Clarify expectation for separate staff "review plan

COMMENTS (continued)

Documentfocuses more on licensing and the phase close to licensing rather than early engagement on pre-conceptual, conceptual, and preliminary designs. The staff encourages early interactions and dont want people to wait until close to the licensing stage.

o Not the intent o Section 4 focused on pre-application engagement o Specific suggestion to increase emphasis?

Pg 4, Sec 1.3: not clear whether paper suggests both RIS response and REP; staff prefers both o Industry prefers at least option not to require both o REP should not represent net increase in regulatory burden

COMMENTS (continued)

Pg 6: QA Program should reference NRC RG-1.28 Rev 5 (more recent than the NQA version cited in NEI 11-04A) o Will elevate existing footnote o Clarify NEI 11-04A is still valid point of departure o Other suggested edits helpful

Pg 12: RG 1.70 is out of date, largely superseded by RG 1.206 o RG-1.70 cited only for Part 50 applications o Discussion earlier on NRC's plans for transitioning to NUREG-0800/

RG-1.206 o Will clarify benefit of additional discussion with staff for Part 50 application content

COMMENTS (continued)

Consider adding section on electronic submittals o Refer to Sec 5.2, second paragraph

Sec 3.1, application type: adaptation of SRP does not comport with NEI transformation letter o Adaptation of existing guidance does not obviate new guidance in longer term; NEI letter not intended to delay modernized regulatory framework o Industry considers LMP to include adaptation of existing guidance o Existing guidance at least point of departure for design-specific changes o Document intended to suggest prospective applicants discuss topic early in pre-application engagement

COMMENTS (continued)

Pp 40/41 presumes staff will maintain 6-phase review, 42-month DCA review, and 30-month COLA review o Guidance document does not presume these o States explicitly:

Review typically is described in review phases

Baseline assumptions [for review schedules]will vary as a result of design, NRC staff resource availability, etc

NRC staffs convention for review phases may change over time

REP NEXT STEPS

Incorporate NRC staff comments

Address other minor editorial errors

Publish guidance document

QUESTIONS/COMMENTS ARRTF / SMRWG Kati Austgen Sr. Project Manager, New Plant, FEEDBACK ON SMR & Advanced Reactors SITING May 3, 2018 CONSIDERATIONS RELATED TO POPULATION

RG 4.7 SHOULD BE UPDATED

Important to enable expected benefit of EP rulemaking o Scale with source term, like emergency planning zones o Additional time to potential release o Much lower probability of such a release

SCALE WITH SOURCE TERM RG 4.7 population density guidance of less than 500 persons per square mile out to 20 miles could be adjusted to scalable guidance based on source term of SMRs and non-LWRs.

Smaller source term o Scale up number of persons per square mile o Scale down the 20 mile radius for population density

TIME TO POTENTIAL RELEASE RG 4.7 population density guidance of less than 500 persons per square mile out to 20 miles could be adjusted to scalable guidance based on additional time to potential release for SMRs and non-LWRs.

Longer time to potential release o Scale up number of persons per square mile o Scale down the 20 mile radius for population density

PROBABILITY OF RELEASE RG 4.7 population density guidance of less than 500 persons per square mile out to 20 miles could be adjusted to scalable guidance based on the much lower probability of release for some SMRs and non-LWRs.

Much lower probability of release o Scale up number of persons per square mile o Scale down the 20 mile radius for population density

RECOMMEND RG 4.7 UPDATE

Important to enable expected benefit of EP rulemaking

Opportunities for scalability of population density guidance

Defense-in-depth achieved in design development

We are gathering resources and assessing timing of next steps

May 2018 UPDATE: Policy Issues - Non-Light Water Reactors Policy Issues - Non-Light Water Reactors Issue as presented on web page & previous meetings - Updated Note/Status to specifically address raised questions related to applicability for LWR SMRs and non-LWRs activities related to non-LWRs Issues with Ongoing Activities for non-LWRs License for Prototype Reactors NRC staff drafting white paper Action Complete Discussion incorporated (Enclosure 1) into NRCs A Regulatory Review Roadmap for Non-Light Water Reactors (ML17312B567)

Appropriate Source Term, Dose SECY-16-0012, Accident Source Parts of this topic related to Licensing Calculations, and Siting Terms and Siting for Small Modular Modernization Project (LMP) and other activities.

Reactors and Non-Light Water Reactors, A draft white paper (ML17333B158) related to siting in relation to population centers and population density discussed during December 14, 2017 and May 3, 2018 stakeholder meetings. NEXT STEPS ?

Key Component and System Design Related to LMP and white paper on SSC safety Issues classification (ML17290A463) and RIPB guidance document (report with staff comments

- ML18120A321)

Offsite Emergency Planning (EP) SECY-15-0077 Regulatory Basis (ML17206A265) completed for Requirements Drafting Regulatory Basis the emergency preparedness rulemaking with regard to small modular reactors and other new technologies. NRC staff preparing proposed rule and related guidance with planning milestone of providing to Commission by October 2018.

Agenda item for June 14th stakeholder meeting Insurance and Liability Evaluating for periodic report to Issue discussed during November 2, 2017 Congress on Price-Anderson Act stakeholder meeting, including presentation from American Nuclear Insurers. Under review No short-term actions by NEI Advanced Reactor Working Group (ARWG) or other stakeholders; 1

May 2018 UPDATE: Policy Issues - Non-Light Water Reactors NRC staff to prepare Commission paper for report to Congress and engage stakeholders during its development.

Use of Probabilistic Risk Assessment in SRP Revisions This topic is related to LMP and white the Licensing Process (safety focused review) papers/guidance (ML17158B543). Also related to NRC participation in development of non-LWR PRA Standard (ASME/ANS) - see NRC response to NEI white paper (ML17233A187) and RIPB guidance document (report with staff comments - ML18120A321)

Implementation of Defense-In-Depth SECY-15-0168 This topic is related to LMP and white (DiD) Philosophy for Advanced Reactors (part of licensing framework) papers/guidance (ML17354B174). NRC staff preparing comments and questions and RIPB guidance document (report with staff comments

- ML18120A321)

Security and Safeguards Requirements NRC White Paper Current topic of interactions between NRC staff for SMRs and stakeholders in context of NRC white paper (ML17333A524) and discussions during public meeting on December 13, 2017 (ML17354B266).

NRC staff preparing Commission paper with expected completion in early mid 2018 NRC security design considerations issued for public comment (NRC-2017-0073) and currently on hold.

Licensing Basis Event Selection Ongoing discussions This topic is related to LMP and submitted white paper (ML17104A254) and related NRC staff comments/questions (ML17145A531) and RIPB guidance document (report with staff comments

- ML18120A321) 2

May 2018 UPDATE: Policy Issues - Non-Light Water Reactors Fuel qualification, materials qualification Issues vary by fuel type and reactor Ongoing discussions with advanced reactor technology technology groups and developers. This topic was discussed during August 3rd stakeholder meeting (ML17229B317; slides ML17220A315)

Update ?

Fuel cycle facilities (front end) Ongoing discussions NEI provided a draft white paper on issues related to industry acquisition and use of higher

Increased enrichments assay low enriched uranium (HALEU) and fuel cycle facilities needed to support advanced reactors (ML17341A604)

The specific issues identified in the NEI white paper as needing NRC support are listed below along with current staff activities and/or planned interactions 3

May 2018 UPDATE: Policy Issues - Non-Light Water Reactors (1) Finalization of the Material See Supplement to Fuel Cycle Program Control and Accountability (MC&A) Integrated Schedule - December 19, rulemaking and associated 2017.(ML17355A040) for NRC status and NRC regulatory guidance document webpage Planned Rulemaking Activities -

(NUREG-2159) for Category II Rules.

Special Nuclear Material (SNM).

(2) Development of guidance for Staff activities currently on hold pending further implementing a Physical Security Commission direction. See Supplement to Fuel plan at a Category II SNM facility. Cycle Program Integrated Schedule - December This will require that the NRC and 19, 2017.(ML17355A040) and NRC webpages DOE to work together to finalize a Security-Related Rulemaking to Update 10 CFR consistent approach for addressing Parts 73 and 26 for NRC status and Planned material attractiveness. Completing Rulemaking Activities - Rules.

this work will enable determination of the need to continue with security rulemaking (10 CFR Part 73) and development of associated implementation guidance.

3) Collaboration with DOE and other NRC agrees that additional criticality benchmark involved parties on development of: data could facilitate criticality reviews. Decision on what criticality experiments to conduct is seen (a) criticality benchmark data and as an industry and DOE decision. Industry proposed design defines the data needs to support facility or transportation package design, DOE capability define the criticality experiments that can be conducted. NRC will collaborative with industry and DOE.

(b) HALEU shipping package and NRC is prepared to review industry submitted transporter certifications. shipping package and transporter applications.

4

May 2018 UPDATE: Policy Issues - Non-Light Water Reactors New Policy Issues - Warranting Immediate Actions?

5

May 2018 UPDATE: Policy Issues - Non-Light Water Reactors Policy Issues - Non-Light Water Reactors Issue as presented on web page & previous meetings - Updated Note/Status to specifically address raised questions related to applicability for LWR SMRs and non-LWRs activities related to non-LWRs Open Issues for non-LWRs but no current activities Annual Fees Final Rule Part 171 definitions:

(May 2016) Small modular reactor (SMR) for the purposes of calculating

- Annual fees scalable based on fees, means the class of light-water power reactors having a licensed thermal power rating less than or equal to licensed thermal power rating, 1,000 MWt per module. This rating is based on the thermal applicable only to LWR SMRs power equivalent of a light-water SMR with an electrical power generating capacity of 300 MWe or less per module.

Expect that changes will be needed to address non-LWRs Manufacturing License Requirements Pending determination of possible SECY-14-0095 states no interest in obtaining a interest from non-LWR developers manufacturing license from near-term SMR applicants was expressed. Questions raised by stakeholders regarding possible approaches for non-LWRs given desire to use manufacturing/modular approaches Industrial Facilities Using Nuclear- SECY-11-0112 Expect that additional guidance will be needed to Generated Process Heat (assess as necessary) address non-LWRs and possible process heat applications (also tied to siting and EP issues)

Fuel cycle facilities (front in) Ongoing discussions One issue (increased enrichments) has been moved to ongoing activities portion of the table Waste Issues (back end) Ongoing discussions Generally deferred to NRC mid-term IAP activities pending specific needs/timeline for technology or design-specific licensing and deployment.

6

May 2018 UPDATE: Policy Issues - Non-Light Water Reactors New Policy Issues - Not Warranting Immediate Actions?

7

May 2018 UPDATE: Policy Issues - Non-Light Water Reactors Policy Issues - Non-Light Water Reactors Issue as presented on web page & previous meetings - Updated Note/Status to specifically address raised questions related to applicability for LWR SMRs and non-LWRs activities related to non-LWRs Issues with no current plans to undertake activities (resolved or need input from stakeholders)

License Structure for Multi-Module SECY-11-0079 Staff committed to provide Commission with a Facilities specific proposal using an actual SMR application for insights, status updated in SECY-14-0095 Operator Staffing for Small or Multi- SECY-11-0098 Long term solution to possibly include changes to Module Facilities (flexibility w/ existing guidance) NRC regulations (rulemaking), status updated in SECY-14-0095 Operational Programs for Small or SECY-11-0112 Confirmed in SECY-14-0095 Multi-Module Facilities (flexibility w/ existing guidance)

Installation of Reactor Modules During SECY-11-0112 Confirmed in SECY-14-0095 Operation of Multi-Module Facilities (existing guidance)

Decommissioning Funding Assurance SECY-11-0181 Long term solution to possibly include changes to (Site-specific exemptions) NRC regulations (rulemaking), status updated in SECY-14-0095 Aircraft impact assessments Final rule ( June 2009) Confirmed in SECY-14-0095 8

ML18130A688

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