ML20092L465

April 2, 2020 Advanced Reactor Stakeholder Meeting Presentation Slides

ML20092L465
Person / Time
Issue date:	04/02/2020
From:	NRC/NRR/DANU/UARP
To:
Hoellman J,NRR/DANU/UARP,415-5481
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Download: ML20092L465 (116)

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Advanced Reactor Stakeholder Public Meeting April 2, 2020 Telephone Bridgeline: (800) 857-9764 Passcode: 2899200#

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Time Topic Speaker 9:00 - 9:10 am Opening Remarks NRC/NEI Update on Status of NRC draft Interim Staff Guidance (ISG) for M. Sutton and J.

9:10 - 10:00am Environmental Reviews and Generic Environmental Impact Cushing, NRC Statement (GEIS) Commission Paper Discussion of PNNL Reports on Approach to Determine the 10:00 - 10:30 am Environmental Data for Table S-3 of 10 CFR 51.51 and Table S-4 D. Palmrose, NRC of 10 CFR 51.52 for Non-LWRs NRC Feedback on NEI White Paper, Recommendations for 10:30 - 10:50 am K. Erwin, NRC Streamlining NRC Environmental Reviews 10:50 - 11:00 am Break All Overview of NEI's Comments on Council of Environmental Quality 11:00 - 11:30 am K. Austgen, NEI (CEQ) Proposed NEPA Rulemaking 11:30 - 12:00 pm U.S. Nuclear Industry Council (USNIC) Discussion of Policy Issues J. Merrifield, USNIC 12:00 - 1:00 pm Lunch All NMSS Discussion of Potential Advanced Reactor Fuel Cycle M. Diaz Maldonado 1:00 - 2:00 pm Activities (Front End and Back End) and R. Torres, NRC Overview of Draft Design Review Guide (DRG) for Instrumentation J. Hoellman and J.

2:00 - 2:30 pm and Controls (I&C) Reviews for Non-LWRs Ashcraft, NRC 2:30 - 2:45 pm Break All Discussion of NRC Interest to Engage Advanced Reactor Vendors L. Lund and T. Boyce, 2:45 - 3:15 pm regarding Codes and Standards NRC Discussion of Financial Qualification, On-site Insurance, Price-3:15 - 3:45 pm B. Reckley, NRC Anderson Act Considerations for Non-LWRs 3:45 - 4:00 pm Closing Remarks and Future Meeting Planning NRC/NEI Opportunities for public comments and questions at designated times 2 of 116

Advanced Reactor Preparations for Environmental Reviews Mallecia Sutton Senior Project Manager Division of Advanced Reactors and Non-Power Production and Utilization Facilities Advanced Reactor Stakeholders Meeting April 2, 2020 3 of 116 International Conference on Radioecology and Environmental Radioactivity, Bergen, 1 Norway

Status on Environmental Activities

• Status update on:

• Interim Staff Guidance for the environmental review of micro- reactors

• GEIS for Advanced Reactors

• Guidance on addressing Table S-3 of 10 CFR 51.51 and Table S-4 of 10 CFR 51.52 for Non-LWRs

• Comments on NEI White Paper on Streamlining NRC Environmental Review 4 of 116

ISG

• How to adapt the best practices to licensing micro-reactors?

• How to scale the practices to reflect reduced potential for adverse environmental impacts?

• How to streamline the practices while maintaining necessary rigor?

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GEIS

• Narrowing scope of environmental reviews as appropriate while still meeting NEPA (and associated rules, regulations, and laws)

• Apply results from participation in other government efforts (FAST-41, EO13807, Part 51 update, CEQ Regulations Update) 6 of 116

Environmental Impacts of Non-LWR Fuel Cycle and Transportation

• The NRC regulations under 10 CFR 51.50(b)(3) and 51.50(c) require:

For other than light-water-cooled nuclear power reactors, the environmental report must contain the basis for evaluating the contribution of the environmental effects of fuel cycle activities for the nuclear power reactor.

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Environmental Impacts of Non-LWR Fuel Cycle and Transportation (Cont.)

• Table S-3 of 10 CFR 51.51 and Table S-4 of 10 CFR 51.52 determined the impacts from the fuel cycle and transportation of and waste for large light water reactors (LWRs).

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Comments on NEI Paper

• Staff is reviewing the NEI White Paper

• Staff will discuss the NEI White Paper 9 of 116

Discussion of Advanced Reactor Generic Environmental Impact Statement Jack Cushing Senior Environmental Project Manager Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Advanced Reactor Stakeholders Meeting April 2, 2020 10 of 116 International Conference on Radioecology and Environmental Radioactivity, Bergen, 1 Norway

Background

• SECY Paper 20-0020 informed Commission that the staff would develop a Advanced Reactor GEIS

• Use of a technology-neutral PPE approach

• bound any reactor design with a generating output up to approximately 30 Mwt per reactor with a small site environmental footprint.

• Exact power level would be determined during scoping for GEIS 11 of 116

What Would an Advanced Reactor Generic Environmental Impact Statement (GEIS) Address

• Define the scope of the environmental effects of the construction and operation of advanced reactors

• Identify and determine generic and site-specific environmental impacts 12 of 116

Next Steps

• Tentative GEIS schedule

• May 1, 2020 - Notice of intent to prepare GEIS with 60 day comment period

• May 1, 2021 -Draft GEIS issued for comment

• May 1, 2022 Final GEIS issued 13 of 116

How Would an Advanced Reactor GEIS Streamline the Environmental Review?

• GEIS process used effectively in license renewal Resolved a majority of issues generically

• GEIS for advanced reactors may provide similar efficiencies 14 of 116

Reactor Technologies Lead-Cooled Fast Reactor Compact Fast Reactor High-Temperature Gas Reactor Sodium Fast Reactor Molten Salt Reactor 15 of 116

Discussion & Questions 16 of 116 7

Advanced Reactor Stakeholders Meeting April 2, 2020

Discussion of PNNL Reports on Table S-3 of 10 CFR 51.51 and Table S-4 of 10 CFR 51.52 for Non-LWRs Donald Palmrose, PhD, Senior Nuclear Engineer Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Advanced Reactor Stakeholders Meeting April 2, 2020 17 of 116 International Conference on Radioecology and Environmental Radioactivity, Bergen, 1 Norway

Regulations

• 10 CFR 51.51, Uranium Fuel Cycle

• 10 CFR 51.52, Transportation of fuels and wastes

• 10 CFR 51.50(c), Environmental Report, Combined license stage

• 10 CFR 51.41, Requirement to submit environmental information 18 of 116 2

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Purpose of the Papers

• Not possible to determine the impacts from Tables S-3 and S-4 for non-LWRs

• Developed technology-neutral methodologies to determine the environmental impacts from the fuel cycle and from the transportation of fuel and wastes for all types of non-LWRs

• For use by an applicant and by the NRC in their respective evaluations 19 of 116 3

Advanced Reactor Stakeholders Meeting April 2, 2020

Non-LWR Fuel Cycle Environmental Data

• Applicants Environmental Reports for non-LWRs should contain the basis for evaluating the contribution of the environmental effects of fuel cycle activities

• An approach has been developed to assist with the estimation of non-LWR fuel cycle impacts in terms of natural resource use and emissions 20 of 116 4

Advanced Reactor Stakeholders Meeting April 2, 2020

Transportation Analysis for non-LWRs

• The applicants Environmental Report must contain sufficient information for the NRC to evaluate the transportation impacts for non-LWRs.

• An approach has been developed to provide additional guidance for evaluating transportation impacts for non-LWRs.

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Advanced Reactor Stakeholders Meeting April 2, 2020

Transportation Analysis for non-LWRs (Cont.)

• In general, the methods for non-LWRs are similar to the methods that are used to evaluate transportation impacts for LWRs

• Analysis of transportation impacts must include:

- Transportation of unirradiated fuel.

- Transportation of spent fuel.

- Transportation of radioactive waste.

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Advanced Reactor Stakeholders Meeting April 2, 2020

Closing Remarks

• Developed non-LWR guidance for assessing fuel cycle and transportation environmental impacts

• Community feedback will be important

• If developing an application, NRC encourages pre-application meetings under 10 CFR 51.40 to discuss these topics 23 of 116 7

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Discussion & Questions 24 of 116 8

Advanced Reactor Stakeholders Meeting April 2, 2020

Discussion of NEI White Paper on Recommendation for Streamlining NRC Environmental Reviews Kenneth Erwin Branch Chief Division of Rulemaking, Environmental, and Financial Support Advanced Reactor Stakeholders Meeting April 2, 2020 25 of 116 International Conference on Radioecology and Environmental Radioactivity, Bergen, 1 Norway

Comments on NEI Paper

• NRC Staff has been concurrently pursuing multiple ways to streamline environmental reviews including, but not limited to:

• Developing ISG-029 to tailor environmental reviews to micro-reactors

• Developing an Advanced Reactor GEIS

• Assigning a Tiger Team to streamline EISs for large light-water reactors 26 of 116

Comments on NEI Paper (Cont.)

• Use of electronic reading rooms to expedite research and analyses

• Use of enhanced webinar type public meetings to minimize travel costs

• Use of best practices from previous EISs, including extended audits and minimization of RAIs, where appropriate 27 of 116

Comments on NEI Paper (Cont.)

• Narrowing scope of environmental reviews as appropriate while still meeting NEPA (and associated rules, regulations, and laws)

• Participation in other government efforts (FAST-41, EO13807, CEQ Regulations Update) 28 of 116

Comments on NEI Paper (Cont.)

• NRC staff is seeking to continue to closely coordinate environmental and safety reviews

• NRC staff is seeking ways to institute lessons learned regarding document production 29 of 116

Comments on NEI Paper (Cont.)

• NRC Staff will consider removing regulatory EIS requirement for new power reactors and subsequent license renewals when it performs future rulemaking for 10 CFR Part 51

• NRC Staff is developing a Generic EIS addressing microreactors and other very small reactors 30 of 116

Comments on NEI Paper (Cont.)

• Existing regulations allow for incorporation by reference (IBR) from existing technical reports and analyses, including the applicants environmental report (ER)

• NRC Staff is exploring opportunities to increase use of IBR from all sources, including but not limited to ERs

• NRC Staff is exploring whether the consideration of alternatives with respect to non-nuclear energy sources is outside of the scope of its environmental reviews 31 of 116

Discussion & Questions 32 of 116 8

Advanced Reactor Stakeholders Meeting April 2, 2020

Break Meeting/Webinar will begin shortly Telephone Bridgeline: (800) 857-9764 Passcode: 2899200#

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Overview of NEI Comments on CEQ Notice of Proposed Rulemaking Kati Austgen April 2, 2020 34 of 116

©2020 Nuclear Energy Institute

Council on Environmental Quality (CEQ)

Issued a notice of proposed rulemaking on potential revisions to the Councils implementing regulations for the National Environmental Policy Act (NEPA)

NEI submitted comments considering:

• ongoing government-wide initiatives to streamline administrative reviews

• the nuclear energy industrys historical experiences with NRC NEPA reviews NEI comments are consistent with our March 2020 White Paper, Recommendations for Streamlining Environmental Reviews for Advanced Reactors 35 of 116

©2020 Nuclear Energy Institute 2

CEQs Overarching Objective revising its NEPA regulations to facilitate more efficient, effective, and timely NEPA reviews by:

1) simplifying and consolidating regulatory requirements while eliminating obsolete provisions,

2) codifying certain guidance and federal case law relevant to the proposed regulations,

3) updating the regulations to reflect current technologies and agency practices, and

4) improving the format and readability of the regulations 36 of 116

©2020 Nuclear Energy Institute 3

Streamlining the NEPA Review Process CEQs proposed regulations, if adopted in their current form and implemented by the NRC (among other agencies), would shorten the NEPA review process, thereby facilitating agency compliance with the deadlines set out by EO 13807 and expediting future NRC licensing proceedings.

NEI provided comments in eight areas of NEPA regulations where CEQ should make changes to further facilitate more efficient, effective, and timely NEPA reviews. 37 of 116

©2020 Nuclear Energy Institute 4

Establishing time limits for agency review and page limits for review documents 1/2 Initiate NEPA review process at the earliest reasonable time Consistent with:

NEPAs rule of reason the Administrations focus on expediting NEPA reviews the NRCs own frequent use of preapplication/pre-scoping activities Early and effective pre-application engagement with NRC and other agencies promotes a more timely and efficient environmental review process.

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©2020 Nuclear Energy Institute 5

Establishing time limits for agency review and page limits for review documents 2/2 Incorporation of presumptive time limits for EIS and EA completion in CEQs regulations COL licensing process and associated NEPA documents were very lengthy NRCs recent success completing NEPA reviews for several significant licensing actions (ESP and SLR issuances) in under 24 months CEQs proposed 2-year presumptive time limit for EISs is reasonable and achievable.

Justification for use of presumptive page limits is also well supported 39 of 116

©2020 Nuclear Energy Institute 6

Expanding use of categorical exclusions, mitigated CEs, and mitigated FONSIs Agencies should use a practical and flexible decisional framework for assessing proposed actions and choosing the appropriate level of environmental review.

It should not be presumed that all advanced reactor license applications require preparation of an EIS.

Current NRC regulations do notbut shouldprovide for the flexibility afforded by CEQs proposed mitigated CE approach.

Mitigated FONSIs provide a valid and useful mechanism for expediting advanced reactor projects while still seeking to prevent or eliminate damage to the environment.

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©2020 Nuclear Energy Institute 7

Optimizing the use of tiering, incorporation by reference, and adoption Well-established practices serve to expedite the preparation and reduce the length of both EISs and EAs.

NRC already endorses the use of these practices NRC can and should use work done by state or local authorities The NRC need not redo or duplicate prior analyses, or conduct new studies of its own.

NRC would continue to exercise independent judgement in relying on that information for purposes of its NEPA evaluation 41 of 116

©2020 Nuclear Energy Institute 8

Improving coordination between lead and other agencies Encourage the CEQs efforts to help agencies coordinate and synchronize their NEPA processes NRC licensing actions typically require the NRC staff to consult or confer with numerous other agencies.

Interagency consultations have at times delayed portions of the NRCs NEPA review.

Agencies need to better coordinate and synchronize their NEPA processes to ensure an efficient environmental review that does not cause delays.

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©2020 Nuclear Energy Institute 9

Clarifying that reasonable alternatives must be technically and economically feasible and meet the purpose and need for the proposed action CEQs proposal that the statement of purpose and need be based on the goals of the applicant and the agencys authority is consistent with federal and NRC case law.

Agency analyses of alternatives to proposed actions have become unnecessarily complex and expansive in scope.

Agencies should consider only alternatives that will accomplish the underlying purpose of the proposed action as defined by the applicant.

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©2020 Nuclear Energy Institute 10

Simplifying the definition of effects and explicitly requiring a reasonably close causal relationship to the proposed action Focuses agency analyses and resources on those effects of most significance those that would be directly caused by approval of the proposed action under consideration 44 of 116

©2020 Nuclear Energy Institute 11

Promoting increased agency use of environmental reports prepared by project applicants or sponsors as the basis for agencys draft EA or EIS Support CEQs proposal to allow applicants to assume a greater role in contributing information and material to the preparation of environmental documents subject to the independent verification of the agency NRCs EIS preparations to a large degree duplicate the applicants efforts.

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©2020 Nuclear Energy Institute 12

Streamlining the public comment process Can be conducted in a more efficient manner that reduces agency burden and related schedule delays timely submittals specific comments addressing consideration of environmental impacts and/or project alternatives agency flexibility in how they respond CEQs proposed enhancements to the public comment process should serve to better focus comments and NRC responses thereto.

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©2020 Nuclear Energy Institute 13

Estimated Timeline

~October 2020 - CEQ final rule

~October 2021 - agencies (such as NRC) develop or revise, as necessary, proposed procedures to implement the regulations in parts 1500 through 1508 within 12 months of the date of publication of the final CEQ rule in the Federal Register 47 of 116

©2020 Nuclear Energy Institute 14

U.S. Nuclear Industry Council Discussion of Policy Issues The Honorable Jerey S. Merri"eld Chairman, US Nuclear Industry Council Advanced Reactors Task Force

& NRC Commissioner, 1998-2007 2 April 2020 48 of 116

Overview

• USNIC commends NRC staff for seeking external comments from advanced reactor stakeholders on policy issues

• This presentation provides results of USNIC survey of Advanced Nuclear Developers conducted in March 2020 49 of 116

Q: How important is the NRC resolution of outstanding generic advanced nuclear licensing policy issues to your company?

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Q: Of the Policy Issues listed below, please rank their individual importance:

High Low Weighted Importance Important Importance Average 1 Appropriate Source Term, Dose Calculations, and Siting 69% 31% 0% 2.69 2 Fuel Qualification 63% 31% 6% 2.56 3 Use of Probabilistic Risk Assessment in the Licensing Process 63% 25% 13% 2.5 4 Fuel Cycle Facilities, Higher Enrichments, Transportation 63% 25% 13% 2.5 5 Functional Containment Performance Criteria 56% 31% 13% 2.44 6 Offsite Emergency Planning (EP) Requirements 63% 13% 25% 2.38 7 Advanced Reactor Licensing NRC Framework 44% 38% 19% 2.25 8 Security and Safeguards Requirements 38% 50% 13% 2.25 9 Licensing Basis Event Selection 38% 44% 19% 2.19 10 Operator Staffing for Small or Multi-Modular Facilities 25% 50% 25% 2 11 Manufacturing License Requirements 19% 63% 19% 2 12 Materials Qualification 38% 13% 50% 1.88 13 Industrial Facilities Using Nuclear-Generated Process Heat 19% 38% 44% 1.75 14 Insurance and Liability 13% 38% 50% 1.63 51 of 116 Blue for Policy Issues with higher rank than last survey; Green with lower rank than last survey 4

Q: Additional Policy Issues Endorsement of Codes & Methods for Advanced Reactors Adoption of computer codes utilized for design and analysis Accelerated Fuel Qualification using codes developed by the National Laboratories.

Clearer definition of advanced fuel qualification requirements and pathways.

Review times are too long for designs with only 3-4 safety systems Remote monitoring and operations Import of licensing basis from other jurisdictions (such as making use of licensing progress in Canada)

Generic EIS Consider licensing subcritical accelerator-driven power systems for construction and operation.

Is real-time reactivity measurement important?

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Q: Does your company intend to pursue licensing in both the United States and Canada?

Other countries: Japan, UK, Jordan, Eastern Europe (Poland, Czech Republic, Ukraine) UAE, India,53Korea, of 116 Indonesia, Ghana 6

Q: Does your company support the effort of the U.S. NRC and the Canadian CNSC to align their regulatory review processes?

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Q: In what time frame do most of these policy issues need to be resolved by the U.S. NRC and CNSC?

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Q: Are there additional actions that the NRC/CNSC and/or Industry can undertake to resolve these issues?

Ensure that the licensing process does not impose any additional burden on the applicants in the short term.

Any resolution of the policy issues within the NRC regulatory framework should be evaluated for potential synergies with CNSC and vice versa.

Licensing frameworks are quite different so helping vendors to map similar requirements would assist development of license applications that can be used in both countries Cooperation on in-reactor testing criteria and/or regimes.

Focus on advanced reactor materials and acceptability including advanced manufacturing techniques.

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Q: What is the appropriate Emergency Planning Zone for your technology?

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Q: Does your plant design require control room operators to operate the plant?

1. operators/shift (for companies giving details): 1-3 operators/shift 58 of 116 11

Q: How often do you intend to refuel?

Greater than 5 years between outages Never, we have lifetime core 59 of 116 12

Q: What is an appropriate Nuclear Regulatory Commission fee (for the current regulatory framework and desired future regulatory framework)?

The current fee structure is acceptable The government should provide a 50% cost share for the NRC activities to license our design The government should provide an 80% cost share for the NRC activities to license our design The government should impose no NRC fees for advanced reactor design reviews 60 of 116 13

Q: Do you believe the NRC should undertake a process to create a Generic Environmental Impact Statement for advanced reactor designs?

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Q: Should the NRC EIS process include a need for power analysis?

Yes, but evaluative process should be streamlined 62 of 116 15

Q: Do you plan to seek funding from DOE Loan Guarantee Program?

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Q: Was your company a recipient of the DOE GAIN (Gateway for Accelerated Innovation in Nuclear) program?

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Q: What are your views regarding the DOE GAIN program?

Good for industry and your company 50%

Funding insufficient 38%

Good for industry but not appropriate for your company 25%

Needs improvement 25%

Efficient for implementing policy 19%

Funding sufficient 0%

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Details-- What are your views regarding the DOE GAIN program?

• Overall, DOE GAIN is good for the industry. The effectiveness of the program would increase if less awards were made with higher amounts.

• It appears the GAIN initiative is striking reasonable balance between private industry and federal resources. The planning and facilitation of effective and meaningful workshops and seminars is one example of GAIN providing a very useful bridge.

• GAIN restricts funding to be spent at the National labs - for commercialization we need industry to be part of the recipients. As example, GAIN helps for R&D work in most cases, but once R&D is done we need to start commercializing and perform maneuverability studies, etc. This expertise lies with industry and not the Labs.

• Have not seen the value of GAIN program as it calls for the work to have to be done in the labs.

• Funding levels are too low for some work activities and the limitation on awards is another barrier.

• With our level of maturity, something that might help us on the supply chain, for example, would be more applicable.

• CRADA IP implications should not prohibit development / export opportunities.

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Q: Do you plan on using the DOE Office of Nuclear Energy Funding Opportunity (FOA) Awards?

Yes; have received an award Yes; have not received an award yet but hope to receive in the future No; do not expect to use this program 67 of 116 20

Q: What issues keep you up at night (multiple answers allowed)?

1 Availability of High Assay Low-Enriched Uranium 63%

Sufficient government funding for the development of 2

advanced reactor technologies 56%

Ability to sell initial 10-20 commercial units (beyond initial 3

demo unit) 56%

4 Availability of financing for domestic deployment 44%

Administration change to one that is not supportive of 5

nuclear 31%

6 Availability of financing for international deployment 31%

7 NRC reactor licensing process 25%

Sufficient domestic manufacturing resources to produce 8

your design 25%

9 Potential requirements for safeguards and security 13%

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For questions contact Jerey S. Merri"eld Chairman, US Nuclear Industry Council Advanced Reactors Task Force U.S. NRC Commissioner (1998-2007)

Je.Merri"eld@pillsburylaw.com Cyril W. Draffin, Jr.

Senior Fellow, Advanced Nuclear, US Nuclear Industry Council Cyril.Draffin@usnic.org 69 of 116 22

Lunch Meeting/Webinar will begin shortly Telephone Bridgeline: (800) 857-9764 Passcode: 2899200#

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ADVANCED REACTORS - FUEL CYCLE, TRANSPORTATION AND STORAGE REGULATORY ACTIVITIES OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS DIVISION OF FUEL MANAGEMENT 71 of 116

FUEL CYCLE ACTIVITIES MARILYN DIAZ, PROJECT MANAGER NRC/NMSS/DFM 72 of 116

TOPICS FOR DISCUSSION

• NMSS/DFM Activities

• Fuel Cycle Facilities

• Training and Preparing Staff

• Transportation and Storage

• Conclusion 3

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NMSS/DFM ACTIVITIES

• Support NRR Advanced Reactor (AR) program.

• Readiness for the review of AR fuel cycle licensing and transportation certification

• Enrichment,

• Fuel fabrication,

• Transportation package certification,

• Spent fuel storage,

• Material Control & Accounting (MC&A) 4 74 of 116

NRC READINESS - FUEL CYCLE FACILITIES

• Regulations (10 CFR Part 70) are adequate for the review of fuel enrichment and fabrication for technologies being developed at higher enrichments.

• We continue to assess our regulatory framework to identify any challenges and/or data needs.

• We are conducting technical evaluations to assess necessary updates for the guidance to account for AR designs

• Updating NRC guidance for material control and accounting for Category II fuel cycle facilities.

• Finalizing report on possible material control and accounting 5

approaches for a pebble bed reactor.

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FUEL CYCLE FACILITIES - LICENSING ACTIVITIES

• NRC is expecting the following licensing actions:

• License amendment request from an enrichment facility:

• Centrus - High Assay Low Enriched Uranium (HALEU) demonstration cascade (FY2020)

• License application for a new fuel fabrication facility

• X-Energy for a TRISO-X facility (FY2021)

• Applicants are encouraged to engage early to ensure a common understanding of the implications of new advanced reactor fuel (ARF) designs.

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TRAINING AND PREPARING STAFF

• Meetings between AR vendors will help staff gain knowledge on specific designs and technologies.

• Training sessions will provide staff with insights into significant safety features of specific designs and technologies.

• Technical reports addressing safety hazards will help staff risk inform their reviews.

• Hazards Associated with Molten Salt Reactor Fuel Processing Operations Presentation (ORNL, 2019)

• Metal Fuel Fabrication Safety and Hazards Presentation (PNNL, 2019)

• Review of Hazards for Molten Salt Reactor Fuel Processing Operations (ORNL, 2019) 7

• Metal Fuel Fabrication Safety and Hazards Final Report (PNNL, 2019) 77 of 116

TRANSPORTATION & STORAGE ACTIVITIES RICARDO TORRES, MATERIALS ENGINEER NRC/NMSS/DFM 78 of 116

NRC READINESS - TRANSPORTATION & STORAGE

• We have experience in the approval of transportation packages and storage systems for TRISO and metallic fuels.

• We are completing technical evaluations on transport and storage activities of ARF designs to identify potential information needs and determine whether additional updates to safety review guidance may be warranted.

• We encourage pre-application engagements to support an efficient review of new applications and amendments.

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PROSPECTIVE APPLICATIONS &

PRIOR OPERATING EXPERIENCE Prospective Non-LWR ARF Type Applicable Operating Experience Applicant Technology Type X-Energy High Temperature Tristructural isotropic United States: Fort St. Vrain; Peach Gas-Cooled (TRISO)-coated particles Bottom Unit 1 Reactor in pebble style fuel Germany: Thorium High Temperature Reactor (THTR-300);

Arbeitsgemeinschaft Versuchsreaktor (AVR)

China: High Temperature Reactor 10 Kairos Power Fluoride Salt- TRISO-coated particles in United States: Fort St. Vrain; Peach Cooled High- pebble style fuel Bottom Unit 1 Temperature Germany: THTR-300; AVR Reactor Oklo Sodium-Cooled, Nuclear metal fuel United States: Experimental Compact Fast (uranium-zirconium U- Breeder Reactor-II; Fast Flux Test Reactor 10Zr fuel alloy with 20% Facility cold worked-316 stainless 10 steel cladding) 80 of 116

NRC EXPECTATIONS

• The use of current NRC-approved transportation packages for new ARF designs is expected to consider the need for:

• Additional criticality evaluations for transportation of ARF at different enrichments.

• Additional evaluations to address the structural integrity of metal fuel pins and containment of fuels containing reactive sodium.

• Revisions to safety evaluations to address test conditions for normal conditions of transport (per 10 CFR 71.71) and hypothetical accident conditions (per 10 CFR 71.73).

• Applicants are encouraged to engage early as they define their plans for transportation of new ARF designs.

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SPENT FUEL STORAGE/TRANSPORTATION

• Various in-reactor degradation phenomena of ARF fuels have been identified, which may impact performance in storage/transport 12 82 of 116

CONCLUSIONS

• NMSS/DFM is proactively identifying potential technical challenges and information needs associated with the safe use of ARFs in the areas of enrichment, fabrication, transport and storage.

• NRC expects some of the efforts related to accident tolerant fuel to benefit the licensing and certification of ARFs.

• Applicants are encouraged to engage early to ensure a common understanding of the implications of new ARF designs.

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QUESTIONS 84 of 116

NMSS/DFM ADVANCED REACTOR TEAM

• James Hammelman, James.Hammelman@nrc.gov

• Ricardo Torres, Ricardo.Torres@nrc.gov

• Bernie White, Bernard.White@nrc.gov

• Tim McCartin, Timothy.McCartin@nrc.gov

• Andrew Barto, Andrew.Barto@nrc.gov

• Jeremy Munson, Jeremy.Munson@nrc.gov

• Marilyn Diaz, Marilyn.Diaz@nrc.gov 85 of 116

Design Review Guide (DRG):

Instrumentation and Controls for Non-Light Water Reactor (Non-LWR) Reviews Advanced Reactors Stakeholders Meeting April 2, 2020 86 of 116 1

Agenda

• Introduction Licensing Modernization Project Core Review Team Approach Instrumentation and Controls (I&C): Safety-Focused Review Initiative

• Overview of I&C Design Review Guide (DRG) to support NRC staffs safety evaluation of advanced non-light water reactor (non-LWR) applications Goal of DRG I&C System Review Framework Overall I&C Staff Review Approach

• Schedule Milestones 87 of 116 2

Licensing Modernization Project

• Licensing Basis Events

• SSC Classification

• Defense in Depth SSCs Including Radionuclide Barriers Safety Related (SR) Non-Safety Related Non-safety Related SSCs SSCs with Special SSCs with No Special Treatment (NSRST) Treatment (NST)

SSCs selected for required safety SSCs performing non-safety SSCs performing risk functions to mitigate DBEs within significant functions significant functions F-C Target*

SSCs selected for required safety SSCs performing functions Non-Risk functions to prevent high required Significant consequence BDBEs from entering for defense-in-depth SSCs DBE region beyond F-C target Risk Significant SSCs

• SR SSCs are relied on during DBAs to meet 10 CFR 50.34 dose limits using conservative assumptions 88 of 116 3

Core Review Team Approach

• Non-LWR Review Strategy - successfully implementing for non-LWR preapplication reviews

• Multi-disciplinary core review team supported by subject matter experts from NRR, NMSS, NSIR, RES, OGC

• Focus on the Fundamental Safety Functions

• Perform an Integrated System Design Review

• Demonstrate Compliance with Applicable Regulations 89 of 116 4

I&C Safety-Focused Review Initiative*

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• From Advanced Reactors Stakeholders Meeting Presentation on May 3, 2018 5

Evolution of I&C Review Guidance

• NUREG-0800, SRP Chapter 7

- System-based approach for LWR licensing reviews

- Guidance not suitable for non-LWRs applications

• NuScale DSRS Chapter 7

- Improved safety-focused licensing review approach

- Improved licensing reviews efficiency and effectiveness

• Design Review Guide (DRG) for I&C

- Leverages the DSRS concepts

- Leverages lessons learned from recent new reactor I&C licensing reviews 91 of 116 6

Goal of DRG for I&C

• Modernizes the I&C safety review in support of advanced reactor licensing applications Safety-focused Risk-informed Technology Neutral Performance-based

• Supports the NRCs vision and strategy for advanced reactor safety reviews

• Incorporates principles from Draft Guide (DG)-1353 92 of 116 7

I&C System Review Framework 93 of 116 8

Overall I&C Staff Review Approach

• The staff review starts at the I&C architecture level

• Ensure that the information necessary to understand the Architecture proposed I&C architecture and system functions is available

• The staff review focuses on safety/risk-significant functions and selected SSCs that support them Safety/Risk-

• Ensure that the I&C performance objectives are met Significant Functions

• The design-related review for SSCs that the staff determined are not safety-related and not risk significant should be less Functions Not

• The staff review focuses on ensuring that safety/risk-significant Safety/Risk- functions will not be impaired by such SSCs Significant 94 of 116 9

Schedule Milestones Activity Completion Date A.1 Completion of OGC fatal flaw review COMPLETE A.2 Staff to address OGC fatal flaw review comments COMPLETE A.3 Submission of draft DRG document for BC concurrence COMPLETE A.4 Submission of draft DRG document to OGC for NLO COMPLETE A.5 Deadline for Staff to address OGC NLO review comments Early April 2020 A.6 Issue draft DRG for public comments Early April 2020 A.7 Public comments in-house deadline June 2020 A.8 Addressing public comments July 2020 A.9 DRG ACRS Sub-Committee meeting June 2, 2020 A.10 DRG ACRS FC meeting July 8, 2020 A.11 Incorporate ACRS recommendations and prepare final DRG document August 2020 95 of 116 10

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Break Meeting/Webinar will begin shortly Telephone Bridgeline: (800) 857-9764 Passcode: 2899200#

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Codes and Standards for Advanced Non-Light Water Reactors Advanced Reactors Stakeholder Meeting Louise Lund, NRC Standards Executive Director, Division of Engineering Office of Nuclear Regulatory Research April 2, 2020 98 of 116

Legal and Policy Framework

• National Technology Transfer and Advancement Act (NTTAA) of 1995 (Public Law 104-113)

• OMB Circular A-119, Federal Participation in the Development and Use of Voluntary Consensus Standards and in Conformity Assessment Activities

• Management Directive 6.5, NRC Participation in the Development and Use of Consensus Standards 99 of 116

Legal and Policy Framework (Contd)

• Nuclear Energy Innovation and Modernization Act (Public Law 115-439)(Sec. 103(b)(4)(B)(iii) and (iv))

- (iii) collaboration with standards-setting organizations to identify specific technical areas for which new or updated standards are needed and providing assistance if appropriate to ensure the new or updated standards are developed and finalized in a timely fashion;

- (iv) the incorporation of consensus-based codes and standards developed under clause (iii) into the regulatory framework

• (I) to provide predictability for the regulatory processes of the Commission; and

• (II) to ensure timely completion of specific licensing actions; 100 of 116

Non-LWR Implementation Action Plan Progress Summary (SECY-20-0010)

• Strategic Area No. 4: Consensus Codes and Standards

- Supports the objective of enhancing non-LWR technical readiness and optimizing regulatory readiness.

- NRC is actively participating and supporting codes and standards development activities, including:

• ASME B&PV Code,Section III, Division 5

• ASME Qualification of Active Mechanical Equipment (QME)

Committee

• American Nuclear Society (ANS) Standards

• ASME/ANS Non-LWR PRA Standard 101 of 116

NRC Codes & Standards Program Activities

• NRC is actively participating in the development and use of consensus codes and standards across multiple SDOs

• NRC Standards Forum (ML18256A356)

Purpose:

Facilitate the identification of needed standards within the nuclear industry that are currently not being addressed by SDOs, and to collaboratively accelerate their development.

- Engages stakeholders, such as SDOs, utilities, research organizations, and NRC staff to identify and develop standards used in regulatory applications

- Next Meeting September 2020 102 of 116

American Nuclear Society (ANS) Activities

• Joint ANS/NRC Workshop on Advanced non-LWRs (May 2018)

- Workshop for industry stakeholders to develop a strategic vision for advanced reactors standards

- Several standards and codes emerged as priorities between technology groups as candidate for updating and/

or harmonization

• ANS Special Report (November 2019) - Setting the Right Bar: How Consensus Standards Help Advanced Reactor Development

- Provided recommendations to support development of advanced reactors standards in an accelerated fashion to meet the needs of industry and the NRC.

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ANS Special Report Recommendations

1. Congress should authorize and appropriate funding for a DOE program to assist SDOs and advanced reactor developers in conducting accelerated development of and/or updates to key standards needed to implement a technology-neutral licensing framework before 2027, as mandated by the Nuclear Energy Innovation and Modernization Act (NEIMA).

2. The DOE, in coordination with SDOs, should solicit input from the advanced reactor developers nongovernmental organizations, and other stakeholders to identify and prioritize key codes and standards for creation/improvement and an overall time frame for their development and regulatory acceptance.

3. The DOE should provide incentives to national laboratories to ensure proactive participation in developing the new data and methods needed to support a comprehensive overhaul of priority advanced reactor codes and standards.

4. The NRC should implement process improvements and/or provide the resources needed to ensure timely adoption of advanced reactor standards. The NRC should reevaluate the need for imposing margins in excess of the margins in endorsed standards and determine whether they are justified from a perspective of reasonable assurance of adequate protection of public health and safety.

5. The DOE and/or the NRC should establish a formal process with the SDOs for achieving harmonization of safety margins among new and/or updated consensus standards.

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ORNL Report on Sodium Fast Reactors

• ORNL/SR-2017/520: Assessment of Applicability of Standards Endorsed by Regulatory Guides to Sodium Fast Reactors (SFRs)

- Pilot program to explore the scope of work required to expand the regulatory framework to SFRs.

Provided:

• An estimate of the number of standards that need revision,

• An estimate of the levels of effort required to revise those standards, and

• A description of the process for revising or creating a new standard, and

• A description of the NRCs process for endorsing a standard.

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NEI-19-03: Advanced Reactor Codes and Standards Needs Assessment

• NEI provided an overview of the report (ML20083G488) during the February 20, 2020 Advanced Reactor Stakeholder Meeting

Purpose:

To identify and prioritize needed codes and standards for advanced non-LWRs.

• A total of 36 standards were included in the prioritization;

- 18 identified as High Priority for near-term development

• Includes ACI, ANS, ASME, and NFPA Standards

• 1 expected to be completed by Dec 2020 (i.e. non-LWR PRA Std.)

• 3 for which development/updates are ongoing

• 3 requiring limited changes

• 11 either new/new-substantive effort or existing/substantive effort required 106 of 116

Next Steps

• Gather input from utility/vendors, standards development organizations, and other stakeholders on codes and standards needs and related near term activities

- Upcoming meetings to discuss updating potential standards

• NRC to continue its participation on SDO activities for the development and or update of priority standards

• Standards Forum - September 15, 2020.

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Questions?

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Discussion of Financial Qualification, Price-Anderson Act Considerations, On-site Insurance, and Decommissioning April 2, 2020 109 of 116

Financial Qualifications

• 10 CFR 50.33 & Appendix C; 10CFR 52.77

- information sufficient to demonstrate to the Commission the financial qualification of the applicant

- reasonable assurance that it can obtain the funds necessary to construct or operate the facility

• SECY-18-0026, Proposed Rule: Financial Qualifications Requirements for Reactor Licensing (RIN 3150-AJ43),

March 15, 2018

- Applicant Financial Capacity Plan that will inform the NRC's review of whether the applicant appears to be financially qualified to engage in the proposed activities in accordance with the regulations in this part.

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Offsite Liability (Price-Anderson)

• Topic of discussion in previous periodic stakeholder meetings

- Awaiting NRC report to Congress

• Requirements:

< 10 MWt 10 CFR 140.11(1)-(3)

> 300 Mwe 10 CFR 140.11(4)

• Primary

• Secondary 10 MWt - 300Mwe 10 CFR 140.12 111 of 116

Property Insurance

• Requirements in 10 CFR 50.54(w)

Each power reactor licensee shall take reasonable steps to obtain insurance available at reasonable costs ... covering the licensee's obligation, in the event of an accident at the licensee's reactor, to stabilize and decontaminate the reactor and the reactor station site at which the reactor experiencing the accident is located, provided that:

(1) The insurance required by paragraph (w) of this section must have a minimum coverage limit for each reactor station site of either $1.06 billion or whatever amount of insurance is generally available from private sources, whichever is less.

• Discussed in previous stakeholder meetings as candidate for exemption request 112 of 116

Decommissioning

• 10 CFR 50.33(k)

- For an application for an operating license or combined license for a production or utilization facility, information in the form of a report, as described in § 50.75, indicating how reasonable assurance will be provided that funds will be available to decommission the facility.

• Requirements in 10 CFR 50.75, Reporting and recordkeeping for decommissioning planning.

• Discussed at previous stakeholder meeting as candidate for exemption request with supporting analyses 113 of 116

Annual Fees

• NRC annual fee regulations revised to address light-water small modular reactors (SMR)

• Staff initiating activity to expand regulations to address non-light-water reactors

• Current requirements (light-water SMR)

<250 MWt minimum* ($153K, 2015)

>250 MWt, <2000MWt variable

>2000MWt maximum

• average of the research and test reactor fee class and the spent fuel storage/reactor decommissioning fee class 114 of 116

Path Forward

• Determine if additional short-term actions needed

• Support interactions on any short-term actions

• Support longer-term activities, including Part 53 rulemaking 115 of 116

Future Meeting Planning and Open Discussion 2020 Tentative Schedule for Periodic Stakeholder Meetings May 7 June 18 August 6 September 24 November 5 116 of 116