ML21258A320
| ML21258A320 | |
| Person / Time | |
|---|---|
| Issue date: | 09/16/2021 |
| From: | Juan Uribe Office of Nuclear Reactor Regulation |
| To: | |
| Uribe J | |
| References | |
| Download: ML21258A320 (66) | |
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Developing a Regulatory Framework for Fusion Energy Systems NRC Public Meeting September 16, 2021 1 of 66
Time Speaker Topic 10:00-10:15am NRC Welcome/Introductions/Opening Remarks 10:15-10:20am United Kingdom Atomic Energy Authority (UKAEA)
Dr. Sally Forbes
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Introduction:==
The regulatory journey for future fusion power reactors in the UK 10:20-10:35am UKAEA Dr. Sally Forbes Fusion technologies being developed in the UK and accident scenario studies 10:35-10:50am Health & Safety Executive (HSE)
James Taylor HSE and the regulation of fusion 10:50-11:05am Environment Agency (EA)
Ian Streatfield EA and the regulation of fusion 11:05-11:20am Regulatory Horizons Council (RHC)
Parag Vyas RHCs Report on Fusion Energy Regulation 11:20-11:35am Department of Business, Energy &
Industrial Strategy (BEIS)
Edward Lewis-Smith Government consultation on fusion regulation 11:35-11:50am All General Discussion - Insights on Regulatory Approaches 11:50-12:00pm Break 12:00-12:15pm NRC Status of Recent Activities and Insights on Regulatory Approaches 12:15-12:30pm All Questions/Closing Remarks/Next Steps Agenda 2 of 66
l NRC Public Meeting on Fusion Regulation September 2021:
The Regulatory Journey for Future Fusion Power Reactors in the UK Dr Sally Forbes Fusion Safety Authority 3 of 66
l Fusion technologies - Current developments in the UK Fusion hazards - Radiological accident scenarios Health & Safety Executive (HSE) - Regulation of fusion Environment Agency (EA) - Regulation of fusion Regulatory Horizons Council (HSE) - Report on Fusion Energy Dept of Business, Energy & Industrial Strategy (BEIS) - Government consultation Introduction 2
NRC Public Meeting on Fusion Regulation - September 2021 4 of 66
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© 2021 Tokamak Energy Spherical Tokamak High Temperature Superconductors Smaller, cheaper, faster...... with strong competitive advantage Squashed shape, highly efficient High magnetic fields Commercial Fusion Power Two technologies unlock Commercial Fusion 5
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© 2021 Tokamak Energy ST40 Device and Powerful Magnets 8 of 66
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First Light Fusion
- University of Oxford spin-out, fusion energy pioneer
- Ground breaking R&D in many areas including: pulsed power; simulation; and fusion plant engineering
- $25m of funding in 2020 from both specialised cleantech and global institutions
- Sidesteps major known challenges of fusion engineering
- Offers a simpler route to a commercial power plant
- Has the potential to generate energy at very competitive LCOE Projectile-driven inertial fusion Advanced capabilities
- World-class plasma simulation tools that are regularly validated against boundary-pushing experiments
- Machine 3s advanced engineering accelerates our projectile from zero to >15 km/s in less than 1 cm.
Cooperation is key
- Collaborating with UKAEA, academia and power plant engineering consultants
- Unique opportunities for collaboration in balance of plant and fusion island development 9 of 66
l fusion fundamental proof gain more energy out than in conceptual design substantial progress with regulator FOAK first reactor connected to grid 2020s 2030s core technology proof FOAK build, revenue options our simpler technology enables a realistic faster timeline reactor development 10 of 66
General Fusions Magnetized Target Fusion technology The fusion equivalent of a diesel engine: practical, durable, cost-effective 3
Plasma Injector Pistons Fusion Liquid metal Set up Compression system launch Plasma injection Fusion and energy conversion Simultaneously, a hot magnetized plasma at 5 million degrees Celsius is formed by a plasma injector and inserted into the chamber cavity.
Confined within the collapsing metal cavity, the plasma is compressed and heated to over 100 million degrees Celsius, creating fusion conditions.
The inner chamber cavity is quickly pushed inwards by the precisely synchronized pistons.
Timing and pressure variations in the pistons pushes the liquid metal from a cylinder into a spherical cavity to compress the plasma.
An inner chamber cavity of approximately four meters in diameter is formed by rotated liquid metal inside the fusion vessel, surrounded by a phased array of several hundred pistons.
Fusion energy is released and absorbed into the surrounding liquid metal, heating it to about 500 degrees Celsius.
Hot liquid metal is extracted and converted to steam. The steam drives a turbine to produce electricity and recharges the pistons for the next cycle.
Then, the cavity reopens, pistons reset, and cycle repeats one time per second.
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The Fusion Demonstration Plant Refine commercial fusion power plant economics, based on actual FDP performance Demonstrate, at power plant-scale, that fusion conditions can be practically achieved using General Fusions technology The FDP has 2 key goals:
70% scale of commercial power plant 1 pulse per day repetition rate Off-grid demonstration prototype 12 of 66
Commence design and build of the Fusion Demonstration Plant at UKAEAs Culham Campus Initiate the design of the CPP Outreach in key markets to engage with potential customers to gain insight into the deliverables required of General Fusions technology Engagement with governments for funding and regulation of fusion energy Commercializing Magnetized Target Fusion 2021 - 2025 Fusion Demonstration Plant starts operations and evaluation in 2025 General Fusion engages with early customers Continue to evolve the design and technology of the CPP Ongoing engagement with governments to build out the regulatory framework Start of construction on the first CPP 2025 - 2030 CPP commences operations 2030 - 2035 The Fusion Demonstration Plant will confirm the performance and economics of Magnetized Target Fusion The next step will be a full-scale Commercial Pilot Plant (CPP) that will generate electricity 13 of 66
l Fusion Hazards - Radiological Accident Scenarios Dr Sally Forbes Fusion Safety Authority 14 of 66
l UKAEA has been providing technical expertise in the areas of fusion safety, security, environment and waste Collated information from published safety studies into early concept designs for fusion power plant
- These have estimated potential public doses in bounding and hypothetical worst case scenarios (eg. loss of coolant accidents with breach of confinement barriers, resulting in release of tritium and activated dust to the environment)
Show that potential public doses in these scenarios are much less than for the worst case fission power station accidents (ie. Chernobyl / Fukushima)
Supports a hazard / risk based approach to a proportionate regulatory framework for fusion Radiological accident scenarios 7
NRC Public Meeting on Fusion Regulation - September 2021
- eg. European Safety and Environmental Assessment of Fusion Power (SEAFP)/Power Plant Conceptual Study (PPCS) eg. also HYLIFE & SOMBRERO inertial fusion design, ARIES stellerator design 15 of 66
l Series of IAEA Technical Meetings on Safety for Fusion Published TECDOC on Safety Classification of Mechanical Components for Fusion Applications Next step is to produce TECDOCs on:
Fusion Power Plant Regulation (led by UKAEA)
Safety Assessment and Design Guidelines for Fusion Power Plant (led by ITER)
International Atomic Energy Agency 8
NRC Public Meeting on Fusion Regulation - September 2021 16 of 66
James Taylor Principal Specialist Inspector (Radiation)
HSE and the Regulation of Fusion 17 of 66
HSE Aims As a regulator, we aim to prevent workplace death, injury or ill health by:
- providing advice, information and guidance
- raising awareness in workplaces by influencing and engaging
- operating permissioning and licensing activities in major hazard industries
- carrying out targeted inspections and investigations
- taking enforcement action to prevent harm and hold those who break the law to account 18 of 66
How HSE Operates HSE applies these principles when conducting its activities:
- Prioritise according to risk
- Proportionality in how we apply the law and secure compliance
- Targeting of our enforcement action
- Consistency of our approach
- Transparency about how we operate and what an employer can expect
- Accountability for our actions 19 of 66
Fusion: Hazard and Risk
- Low general risk compared to other activities regulated by HSE e.g.
- Oil and gas
- Petrochemicals
- Similar or lower risk to other HSE regulated radiation practices such as
- Cyclotrons used for radioisotope production
- Betatrons used for industrial radiography
- Large scale industrial sterilisation plants 20 of 66
Fusion: Hazard and Risk
- No runaway reactions
- No very long-lived radioactive waste
- Small external dose rates
- Aim for <1mSv h-1 outside biological shielding
- Tritium characteristics
- 12.3 y half-life
- 10 day biological half-life
- Low radiotoxicity 21 of 66
The Regulation of Fusion Technology: Legislation (1)
General Duties:
Primary Legislation:
The Health and Safety at Work etc Act 1974 (HSWA)
Duty to control risk so far as is reasonably practicable Secondary Legislation The Management of Health and Safety at Work Regulations 1999 (Management Regs)
- Duty to carry out a risk assessment to reduce risks as low as reasonably practicable Current Regulatio ns 22 of 66
The Regulation of Fusion Technology: Legislation (2)
The Radiation Hazard:
Ionising radiation:
The Ionising Radiation Regulations 2017 (IRR 17) relevant because of the use of tritium, the generation of neutrons and the likely production of radioactive activation products The Radiation (Emergency Preparedness and Public Information) Regulations 2019 (REPPIR 19) relevant because of the storage of tritium on site Non-ionising radiation The Control of Electromagnetic Fields at Work Regulations 2016 controls the risks associated with the high magnetic fields in and around a fusion reactor The Control of Artificial Optical Radiation at Work Regulations 2010
- Controls the risks associated with the use of lasers for fusion purposes Current Regulatio ns 23 of 66
Regulatory Approach Primary responsibility for managing workplace risks lies with the business or person that creates the risk.
As a regulator, HSEs role is to determine that businesses are effectively and proportionately managing their health and safety risks to workers and others The general duties require risks to workers and others health and safety are controlled so far as is reasonably practicable.
HSWA is firmly goal-setting and outcome focussed establishing goals to be achieved rather than absolute standards to be met and approaches to be followed.
Employers are encouraged to be active managers of their risks rather than passive recipients of instruction.
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Future Fusion
- HSE considers current goal setting regulatory regime is adequate (and has been successful in regulating experimental fusion reactors)
- The IRR17, REPPIR19 and the regulations applicable to non-ionising radiation have been and will be adequate to control any radiological risks
- A new proposed consent system will add an additional layer of reassurance - the submission of a safety assessment(s) and its review by HSE is likely to be required
- HSE will work closely with operators and other regulators to further define standards and assist operators during the design, operation and decommissioning phases.
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Environment Agency regulation of fusion Ian Streatfield Manager, Advanced Nuclear Technologies 16 September 2021 26 of 66
What we do: We protect and improve the environment We protect and improve the environment 2
We improve the quality of our water, land and air by tackling pollution.
We help people and wildlife adapt to climate change and reduce its impacts.
We work as part of the Defra group to create a better place for people and wildlife.
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Our principles: how we make choices 3
Support local priorities.
Focus on the 20%
that makes 80%
of the difference.
Put people and wildlife first.
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Environmental regulators 29 of 66
Our Role Environmental and security regulator for non-nuclear radioactive substances users in England
- We permit keeping and use of radioactive substances and accumulation and disposal of radioactive waste Environmental regulator for the nuclear industry in England
- We permit disposal of radioactive waste from nuclear power station including the waste arising from decommissioning 5
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BEIS Advanced Modular Reactor (AMR) Competition 6
High temperature reactor High temperature reactor High temperature reactor Sodium-cooled fast reactor Lead-cooled fast reactor Lead-cooled fast reactor Molten Salt Reactor Fusion Reactor Phase 2 (Design Development): a share of up to £40 million was available for selected projects from phase 1 to undertake development activities. A further £5 million may also be made available for regulators to support Phase 1 (Feasibility Study): Up to £4 million funding to carry out a series of feasibility studies for AMR designs (to January 2019) 31 of 66
Future fusion in the UK 7
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Current and future initiatives related to fusion
- Reviewed existing regulatory framework
- Review charging (consultation to move to time and materials basis)
- Continue to build capacity and capability
- Review and revise guidance
- Review how to enable innovation through regulation and influence 8
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Working with others (1)
Regulators
- Long established working relationships with both HSE and ONR, underpinned by Memoranda of Understanding
- Clear responsibilities
- Coordinated engagement with Operators where appropriate
- Consider joint guidance where appropriate 9
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Working with others (2)
Operators
- Significant experience regulating Culham Centre for Fusion Energy
- Early engagement / pre-permitting is key
- Enabling, Yes if approach, clarifying regulatory expectations
- Learning from wider regulation of other industrial sectors Other stakeholders
- Experience of regulating sites of high public interest
- Public consultation is a key aspect of environmental permitting regulations 10 35 of 66
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NRC Public Meeting on Fusion Regulation 16 September 2021 37 of 66
About the RHC The Regulatory Horizons Council 22 RHC Charter The Regulatory Horizons Council (RHC) is an independent expert committee that identifies the implications of technological innovation, and provides government with impartial, expert advice on the regulatory reform required to support its rapid and safe introduction.
In developing ideas and recommendations, the Council will engage openly and transparently with research institutions, business, civil society, policymakers, regulators and other contributors as appropriate. It will draw on a broad range of expertise, help build consensus and ensure recommendations are sufficiently contextualised.
The government will [publish] a formal response to all the recommendations contained in the Councils reports, stating clearly whether the government accepts or rejects the recommendations; giving reasons where it disagrees with the Councils recommendations, and where appropriate presenting an alternative proposal for enabling the proposed innovation; and providing timelines for implementation where it agrees with the Councils recommendations, and making clear which commitments are new policies.
RHC Charter: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/881237/RHC_Charter.pdf About the RHC Newly constituted body, one year old Five council members plus Chair, drawn from diverse industrial, academic and public backgrounds Agile and cross-disciplinary Report on Fusion Energy, 31st May 2021 https://www.gov.uk/government/groups/regulatory-horizons-council-rhc 38 of 66
Overarching Exam Question How can the UK continue to move towards an innovation friendly, long-term regulatory framework for fusion?
First Deliverable Through participatory engagement the RHC will produce a report to influence on the decision to select a Fusion Regulator for STEP (Spherical Tokamak for Energy Production).
Secondary Deliverable The RHC to produce a report on the broader topic of what a fusion regulatory framework should look like, particularly on a commercial basis. This report will build on and complement work done on the STEP question.
Supplementary Question (Ongoing)
How can the RHC contribute towards promoting an international regulatory framework that facilitates the long-term future trade of fusion energy?
Exam Question The Regulatory Horizons Council 23 39 of 66
Objectives The Regulatory Horizons Council 24 40 of 66
Key criteria The Regulatory Horizons Council 25
- 1. Proportionate and agile
- 2. Perception and trust
- 3. Lessons learnt and understanding
- 4. Experimentation and forward-looking
- 5. Support and collaboration 41 of 66
Recommendations The Regulatory Horizons Council 26 Main Recommendation The RHC recommends that the UK champions the way for a non-fission approach, by setting out and consulting on a bold, forward-looking vision of how the Health and Safety Executive (HSE) and Environment Agency (EA) could lead and evolve the regulatory approach for STEP.
The RHC found that although changes, potentially including legislation, will be needed, STEP does not require a different regulatory approach from that which has worked well for fusion in the UK to date. The EA and HSE provide the proportionate framework for regulation of STEP commensurate with the hazards presented by the technology.
Second Recommendation Guidance on the EA and HSE regulatory approach to fusion should be produced to explain to stakeholders and the public how this works in practice. The guidance would help provide both clarity and reassurance concerning the UKs regulatory approach for STEP.
Government Response The Regulatory Horizons Council 27 The Government agrees with the RHC that the lower intrinsic hazard of the fusion process when compared to fission is an incredibly important factor in considering the regulatory framework for fusion.
It is also important to recognise the hazards in the fusion process and the overall technical uncertainty given that fusion is still a developing technology. The complexity of this issue means that the Government cannot yet take a firm view on the RHCs recommendations. However, BEIS commits to respond fully, in line with the RHC Charter, once it has considered responses to the forthcoming consultation in early 2022.
I am very grateful to the Regulatory Horizons Council for their important and valued contribution to the subject of fusion regulation, and for helping to show that the UK is serious about fusion and unleashing innovation across the UK.
AMANDA SOLLOWAY MP Parliamentary Under Secretary of State - Minister for Science, Research and Innovation https://www.gov.uk/government/publications/government-response-to-the-regulatory-horizons-councils-report-on-fusion-energy 43 of 66
l OFFICIAL-SENSITIVE: COMMERCIAL OFFICIAL-SENSITIVE: COMMERCIAL NRC Public Meeting on Fusion Regulation September 2021:
The Regulatory Journey for Future Fusion Power Reactors
Edward Lewis-Smith
BEIS - Domestic Fusion Policy 44 of 66
Undertaking a review of the current fusion regulatory framework in the UK, to consider how best to support innovation in fusion Supported by UKAEAs Fusion Safety Authority and the regulators BEIS review of the regulatory framework 2
euro-fusion.org As progress from experimental facilities to demonstration facilities on the path to commercial fusion power reactors, level of hazard will change - tritium inventory, activated materials, radioactive waste 45 of 66
The Government agrees with the RHC that the lower intrinsic hazard of the fusion process when compared to fission is an incredibly important factor in considering the regulatory framework for fusion.
It is also important to recognise the hazards in the fusion process and the overall technical uncertainty given that fusion is still a developing technology.
The Government plans to publish a full consultation on Fusion Regulation later this year, enabling all stakeholders and the public the chance to have their say.
Government response to RHC 3
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Importance of Engagement 4
Regulatory harmonisation will be essential for global development and deployment of fusion - this requires sustained engagement To successfully commercialise fusion, public understanding of and support for fusion energy is crucial. Trust in regulatory measures will be a key factor in that support.
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BEIS operates a Public Attitudes Tracker to gauge UK public opinion on a range of issues.
Fusion was included for first time in September 2020 (next in September 2021)
Opposition to fusion is very low (5%), but knowledge of fusion is relatively low too (24%)
Increased awareness and knowledge of fusion strongly correlates with increased support Current Engagement 5
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l We thank the NRC reaching out to the UK to share its regulatory journey for fusion It has come at the right time as the fusion community is rapidly mobilising to move from R&D facilities to the development of prototype /
demonstration fusion power reactors on the path to commercialisation Having a proportionate and enabling regulatory framework is a key part of this journey We have a growing international fusion regulatory community - the work being undertaken by the IAEA in these areas will hopefully provide an international platform for ongoing collaboration and harmonisation Summary 33 NRC Public Meeting on Fusion Regulation - September 2021 49 of 66
ll 34 Thank you !
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Discussion - International Perspectives 51 of 66
Developing a Fusion Framework:
Recent Activities and Insights on Regulatory Approaches.
September 16, 2021 52 of 66
Agenda 1.
Overview of white paper: Preliminary Options for a Regulatory Framework for Fusion Systems.
2.
Insights into Decision-Making Graded Criteria.
3.
Next Steps/Future Activities.
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White Paper: Preliminary Options for a Regulatory Framework for Fusion Systems1
- Issued April 21, 2021, to support interactions with the Advisory Committee on Reactor Safeguards (ACRS).
- ACRS reviews and advises the Commission on technical and policy issues related to Advanced Nuclear Reactors (among other things).
- Per NEIMA2 definition, Advanced Nuclear Reactor means a nuclear fission or fusion reactor.
1 White Paper: Preliminary Options for a Regulatory Framework for Fusion Systems is available at Agencywide Document Access and Management System (ADAMS) Accession No. ML21118A081 2 Nuclear Energy Innovation and Modernization Act (NEIMA) - PUBLIC LAW 115-439JAN. 14, 2019 54 of 66
White Paper:
Preliminary Options for a Regulatory Framework for Fusion Systems White paper reflects preliminary options for the regulatory treatment of fusion systems being considered by the NRC.
Concepts and high-level regulatory options have been previously shared with stakeholders during public meetings and will continue to be developed.
White paper reflects input received from external stakeholders via letters and public forums. This will be critical in informing the final regulatory options SECY paper.
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White Paper: Preliminary Options for a Regulatory Framework for Fusion Systems White paper reflects the challenges associated with developing possible options for a regulatory framework for fusion energy systems.
Notable Legal Challenges:
Are fusion systems of significance to the common defense and security, or could affect the health and safety of the public?
Does the current definition of Utilization Facility in Section 11 of the Atomic Energy Act (AEA) of 1954, as amended, support inclusion of fusion systems?
Does the current definition of Byproduct Material in Section 11 of the AEA, as amended, support inclusion of fusion systems?
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White Paper: Preliminary Options for a Regulatory Framework for Fusion Systems
- Notable Technical Challenges:
Fusion Confinement Approach (i.e.: Magneto, Inertial, Magneto-Inertial).
Fuel Type (neutronic [DT, DD, TT] or aneutronic [DHe3, pLi6, pB11]).
Understanding Offsite Dose Consequence scenarios.
Understanding limits/targets on byproduct material types and quantities.
Understanding required safety systems and potential accident scenarios to ensure reasonable assurance of adequate protection.
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Graded Approach What insights can we use and leverage such that all the regulatory options presented are commensurate with the anticipated risk/hazards of fusion system facilities?
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Insights into a Graded Approach
- Although there are some differences in the regulatory processes associated with utilization facilities and byproduct materials, the technical bases for assessing fusion energy systems are expected to be similar in both approaches.
- For example, in either approach the design and hazard analysis will determine the scope of requirements needed for a license for the safe use of radioactive materials and similar information will be needed to evaluate the design and radiological hazards associated with a particular commercial fusion facility.
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Insights into a Graded Approach A scalable approach could be developed from an existing regulatory framework, or entirely new. For example:
- Elements of a utilization facility approach under 10 CFR Part 50, 52 or 53 could be scaled down.
- Elements of a byproduct approach under 10 CFR Part 30 could be scaled up.
- A hybrid approach (fragmented or consolidated) needs to be scalable to balance regulatory requirements against a wide variety of designs. (i.e:
aneutronic system (2MWe) and neutronic system 300 MWe or beyond).
Any scalable approach needs clear and predictable decision-making criteria to ensure consistency and regulatory certainty.
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In the context of having a technology-inclusive, regulatory framework that is graded such that regulatory compliance is commensurate with associated risk:
What advantages/disadvantages would stem from categorizing fusion systems based on estimated offsite consequences as one of the many different decision-making criteria tiers? What are examples of potential tiers based on estimated offsite consequence for staff consideration?
What advantages/disadvantages would stem from categorizing fusion systems based on inventory limits of byproduct material (such as tritium) as one of the many different decision-making criteria tiers? What are examples of potential tiers based on inventory limits of byproduct material for staff consideration?
What advantages/disadvantages would stem from categorizing fusion systems based on power output (MWe) as one of the many different decision-making criteria tiers? What are examples of potential tiers based on power output for staff consideration?
What advantages/disadvantages would stem from categorizing fusion systems based on the fusion reaction being applied (neutronic [DT, DD, TT] or aneutronic [DHe3, pLi6, pB11]) as one of the many different decision-making criteria tiers? What would be the expected difference in the level of safety systems between fusion facilities for these two types of fusion reactions?
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Insights into a Graded Approach The questions shown on the previous slide are meant to enhance the discussion of future meetings. The NRC is not seeking formal responses to these questions from stakeholders.
(Paperwork Reduction Act)
NRC staff will continue to engage stakeholders via public meetings and any other regulatory vehicles to better understand concepts for decision-making criteria.
External stakeholders can provide valuable insights and feedback to allow for a better understanding of:
- The fusion technologies and their risks,
- Insights into methodical and risk informed approaches commensurate with fusion technologies.
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Stakeholder Comments You may submit any comments and feedback related to fusion by any of the following methods:
Federal Rulemaking Website: Go to https://www.regulations.gov and search for Docket ID NRC-2019-0062. Address questions about NRC dockets to Dawn Forder; telephone: 301-415-3407; email:
Dawn.Forder@nrc.gov Email comments to:
Rulemaking.Comments@nrc.gov If you do not receive an automatic email reply confirming receipt, then contact 301-415-1677.
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Next Steps and Future Activities Continue stakeholder interactions to better inform the development of the SECY paper. Fusion public meeting tentatively planned for mid to late October.
NRC staff is assessing the current SECY paper completion schedule of May 2022 and evaluating the impacts of a potential extension.
Additional information: https://www.nrc.gov/reactors/new-reactors/advanced/fusion-energy.html 64 of 66
Discussion - Insights on Regulatory Approaches 65 of 66
Questions/Closing Remarks Thank You!
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