ML21011A094
| ML21011A094 | |
| Person / Time | |
|---|---|
| Site: | 99902088 |
| Issue date: | 01/25/2021 |
| From: | Edward Helvenston NRC/NRR/DANU/UNPL |
| To: | Abilene Christian University |
| Helvenston E M/NRC/NRR/DANU/UNPL | |
| References | |
| EPID L-2020-NFN-0000 | |
| Download: ML21011A094 (7) | |
Text
APPLICANT: Abilene Christian University
SUBJECT:
SUMMARY
OF DECEMBER 10, 2020, MEETING WITH ABILENE CHRISTIAN UNIVERSITY (EPID NO. L-2020-NFN-0000)
On December 10, 2020, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Abilene Christian University (ACU) via webinar. The purpose of this meeting was to discuss licensing topics regarding ACUs planned molten salt research reactor (MSRR) project. This was the fourth public meeting related to the proposed ACU MSRR. The meeting notice and agenda, dated November 30, 2020, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML20335A109. ACUs presentation used in the meeting is also available in ADAMS at Accession No. ML20350B491. A list of meeting attendees is provided as an enclosure to this summary.
During the previous public meeting held on November 10, 2020 (ADAMS Accession No. ML20330A287), ACU stated that it plans to begin construction of its Science and Engineering Research Center (SERC), a multi-purpose building that could later house the MSRR, without an NRC construction permit (CP) for the MSRR, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.10, License required; limited work authorization. By letter dated November 30, 2020 (ADAMS Accession No. ML20366A053), ACU submitted, to the NRC, a request for regulatory interpretation of 10 CFR 50.10 with respect to ACUs plans to build the SERC. ACU requested this follow-up meeting to discuss its regulatory interpretation request.
During the meeting, ACU discussed the four questions it had submitted in its November 30, 2020, regulatory interpretation request letter. ACU also responded to NRC staff questions regarding the letter and ACUs overall plans for the SERC and MSRR.
The NRC staff asked whether ACU considers the statement in ACUs letter that the MSRR will have a liquid core loading means the same as liquid fuel loading in the 10 CFR 50.2, Definitions, definition of testing facility. ACU responded that it considers the terminology liquid core loading and liquid fuel loading to be equivalent with respect to the MSRR, and that the MSRR would have a liquid fuel loading as used in the testing facility definition.
The NRC staff asked ACU to elaborate on the MSRR activities that ACU plans to conduct that will make the MSRR useful in the conduct of research and development activities of the types specified in section 31 of the Atomic Energy Act, as stated in ACUs letter. ACU stated that it is still developing the specific details related to how the MSRR will meet this criterion to be licensed under Section 104.c of the Atomic Energy Act of 1954, as amended (AEA), and that it would describe these details in its CP and/or operating license (OL) applications.
The NRC staff asked ACU whether the SERC would be built to local building codes or would exceed local codes, and if it would be built to exceed local codes, whether this would be done January 25, 2021
2 for the specific purpose of accommodating a potential future reactor. The NRC staff also asked ACU to elaborate on possible uses of the SERC research bay, other than the installation of the MSRR (ACUs letter mentioned an accelerator or other research apparatus), and whether these other uses would require an NRC or state license. ACU stated that, as a research facility, the SERC would be built above local building codes. ACU stated that SERC research bay uses other than installation of the MSRR could potentially require an NRC or state license, but it did not anticipate that any of these alternate uses would require a 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, NRC license. ACU stated that it expected the possible installation of the MSRR to be bounding in terms of building design needs because the MSRR could require more robust building features (e.g., maximum floor loading) than other possible research bay uses. ACU also stated that, although the installation of the MSRR in the research bay is not a certainty, ACU plans to design and build the SERC such that no building limitations would preclude MSRR installation. ACU stated that it planned to construct the SERC with tolerances (in parameters such as maximum floor loading) that account for uncertainties in the actual MSRR design, because the final MSRR design is not complete.
The NRC staff asked what ACU considered the threshold as to when construction of a building (with a research bay that could accommodate a potential future research reactor) would become construction that requires a CP. ACU indicated that, based on its reading of the text of 10 CFR 50.10 and the history of that regulation, it did not identify any specific threshold beyond which a CP is required, but stated that, as discussed in its letter, ACU did not believe the construction of its SERC would require a CP.
The NRC staff asked ACU to elaborate on the statement in ACUs letter that the SERC research bay would serve as the confinement for the reactor facility. ACU clarified that the research bay would be a natural confinement boundary in that it would generally limit air movement between the inside of the room and the outside. However, whether the research bay would serve any safety purpose as a confinement, or whether it would be a safety-related structure, system, or component (SSC) for the MSRR, was uncertain, pending the completion of the final design and safety analyses for the MSRR. ACU stated that its CP and/or OL applications would provide additional information on any safety role of the research bay, including as a possible confinement for the MSRR.
ACU emphasized that, although some features of the SERC research bay could later become safety-related SSCs for the MSRR, it only plans to build the minimum research bay features (e.g., floor, walls, roof, ventilation, security) needed as part of a fully-functioning room that could later be put to various possible uses.
The NRC staff asked ACU if SERC building features, outside the research bay, could potentially become MSRR SSCs. ACU stated that this could occur if ACU decides to install the MSRR in the SERC, because if the MSRR is installed in the SERC, ACU plans to locate the reactor control room, space for reactor support equipment, and a counting room outside the research bay.
Regarding Question 4 in ACUs letter, the NRC staff noted that a CP does not normally constitute approval of SSCs or other parts of a reactor facility design, unless an applicant specifically requests approval of all or part of facility a design in its CP application and such approval is incorporated in the CP. ACU stated that, if it decides to install the MSRR in the SERC and to rely on parts of the SERC as MSRR SSCs, its CP application may seek final design approval of SSCs that are already installed in or part of the completed SERC building.
ACU stated that it understands that its CP application must specifically request final design
3 approval, and any approval granted would be in the CP. ACU indicated that Question 4 seeks to understand whether an NRC CP review would evaluate any parts of the SERC research bay that ACU relies on (in its CP application), in whole or in part, as MSRR SSCs.
The NRC staff also asked ACU whether the intent of Question 4 was to ask if ACU would have to remove and re-install an SSC solely because it had been installed during SERC construction and prior to CP issuance, or to ask if ACU might have to remove and re-install an SSC installed prior to CP issuance for other reasons. ACU stated that Question 4 only seeks to understand if the NRC would require SSC removal and re-installation (identically to the removed SSC) solely because an SSC had been installed prior to CP issuance. ACU indicated that it understood that, if a CP were issued, an SSC might need to be removed and re-installed (after CP issuance) for other reasons, such as MSRR design changes in ACUs OL application; requirements imposed as a result of an OL review; and insufficient documentation of the construction/installation of any SERC features, if the lack of documentation could affect ACUs ability to demonstrate the SSC would meet design requirements or perform its intended function.
Noting that ACUs letter indicated that SERC construction records, to the extent available, would support ACUs CP application analysis that any SERC features relied on as MSRR SSCs meet design requirements, the NRC staff asked about ACUs plans for records, and how ACU would ensure that those records are sufficient to support ACUs evaluation that any as-built SSCs meet the necessary performance standards. The NRC staff also asked ACU whether ACUs CP application would describe the SERC construction records, and justify the sufficiency of those records. Additionally, the NRC staff asked ACU whether ACU plans to include SERC construction (and maintenance of SERC construction records) within the scope of its quality assurance program (QAP). The NRC staff noted that during the previous public meeting held on November 19, 2020 (ADAMS Accession No. ML20330A282), ACU stated that it plans to submit a QAP description for NRC review and approval in early 2021.
ACU stated that it would likely begin SERC construction, including research bay construction, before the NRC completes its review of ACUs QAP description. The NRC staff noted that NRC construction inspection, including any inspection activities related to verification of construction activities being conducted in accordance with an NRC-approved QAP description, would not occur until after the issuance of a CP. ACU stated that, regardless of whether its QAP description has been approved yet, and also regardless of whether it formally designates research bay construction as being within the scope of its QAP, it planned to conduct research bay construction activities, and any other SERC construction activities that could involve possible future MSRR SSCs, in general accordance with its QAP. ACU stated that it plans to do this to help ensure that SERC features that may later be relied on as SSCs are constructed to appropriate standards, and that there is appropriate documentation of construction. ACU stated that it does not plan to use its QAP during construction of SERC areas (such as offices and laboratory spaces) that would not constitute or contain potential MSRR SSCs. ACU stated that, although not applicable to building construction prior to the issuance of a CP, it may also consider information in NRC construction inspection manual chapters and procedures in ensuring that possible future SSCs are appropriately constructed. ACU stated that in its CP application, it plans to summarize SERC construction records related to SERC features that become SSCs, and to justify why those records are sufficient to show that the SSCs will meet necessary performance standards.
The NRC staff thanked ACU for answering the NRC staffs questions related to the regulatory interpretation request and ACUs tentative plans. The NRC staff stated that it is considering ACUs request and working to provide a timely response, and that the NRC staff would notify
4 ACU if ACU needed to submit any additional information to support the interpretation request, or if the NRC staff anticipates any significant delays in the timing of a response. The NRC staff noted that ACU had requested that the NRC staff provide responses to ACUs four questions as they are determined by NRC, rather than waiting for all questions to be answered before replying; the NRC staff stated that it would consider this request, but given that the questions are interrelated, a consolidated request could be more informative.
Please direct any inquiries to me at 301-415-4067, or by electronic mail at Edward.Helvenston@nrc.gov.
Edward Helvenston, Project Manager Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Project No. 99902088
Enclosure:
As stated cc: See next page Signed by Helvenston, Edward on 01/25/21
Abilene Christian University Project No. 99902088 cc:
Dr. Rusty Towell Director of NEXT Lab Abilene Christian University ACU Box 27963 Abilene, TX 79699 Phil Schubert, Ed.D.
President Abilene Christian University Office of the President 206 Hardin Administration Building ACU Box 29100 Abilene, TX 79699-9100 Test, Research and Training Reactor Newsletter Attention: Ms. Amber Johnson Dept. of Materials Science and Engineering University of Maryland 4418 Stadium Drive College Park, MD 20742-2115
ML20335A109 Mtg. Notice ML20350B491 Mtg. Slides ML21011A094 Mtg. Summary NRC-001 OFFICE NRR/DANU/PM NRR/DANU/LA NRR/DANU/BC NRR/DANU/PM NAME EHelvenston NParker GCasto EHelvenston DATE 1/15/2021 1/15/2021 1/22/2021 1/25/2021
Enclosure LIST OF ATTENDEES DECEMBER 10, 2020, MEETING WITH ABILENE CHRISTIAN UNIVERSITY 11:00 A.M. - 12:30 P.M.
Name Organization Michael Balazik U.S. Nuclear Regulatory Commission Benjamin Beasley U.S. Nuclear Regulatory Commission Patrick Boyle U.S. Nuclear Regulatory Commission Tison Campbell U.S. Nuclear Regulatory Commission Greg Casto U.S. Nuclear Regulatory Commission Molly-Kate Gavello U.S. Nuclear Regulatory Commission Edward Helvenston U.S. Nuclear Regulatory Commission William Kennedy U.S. Nuclear Regulatory Commission Steve Lynch U.S. Nuclear Regulatory Commission Elizabeth Reed U.S. Nuclear Regulatory Commission Kevin Roach U.S. Nuclear Regulatory Commission Jennifer Scro U.S. Nuclear Regulatory Commission Brian Smith U.S. Nuclear Regulatory Commission Mary Frances Woods U.S. Nuclear Regulatory Commission Megan Wright U.S. Nuclear Regulatory Commission Mitzi Young U.S. Nuclear Regulatory Commission Alexander Adams Abilene Christian University Tony Hill Abilene Christian University Tom Moreno Abilene Christian University Jonathan Scherr Abilene Christian University Rusty Towell Abilene Christian University Pavel Tsvetkov Texas A&M University Derek Haas University of Texas at Austin