ML21299A313

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Fusion Public Meeting 10272021 - Final Pdf Slides
ML21299A313
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Issue date: 10/27/2021
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Developing a Regulatory Framework for Fusion Energy Systems NRC Public Meeting October 27, 2021

Agenda Time Speaker Topic 9:30-9:45am NRC Welcome/Introductions/Opening Remarks General Fusion Updates on plans for Fusion Demonstration Plant in the UK -

9:45-10:15am Michael Cappello UKAEA Culham Campus Overview and establishment of the American Society of Mechanical Engineers Oxford Sigma 10:15-10:30am (ASME)Section III Division 4 (Fusion Energy Devices) subcommittee Special Thomas Davis Working Group for Fusion Stakeholders (SWGFS)

Updates on the advancement of High-Temperature 10:30-10:45am Commonwealth Fusion Systems Superconducting Electromagnet Technology 10:45-11:15am Fusion Industry Association Insights on decision-making criteria for a graded approach 11:15-11:45am NRC 10 CFR Part 30 - Examples of Regulatory Scalability 11:45-12:15pm NRC 10 CFR Part 53 - Overview of the proposed Advanced Reactor rulemaking Questions/Closing Remarks/Next Steps 12:15-12:30pm All/NRC

Fusion Demonstration Plant NRC Briefing October 27, 2021 Michael Cappello - Senior Vice President Technology Delivery October 2021 *NRC confirmed with General Fusion no confidential information is contained in this presentation.

CONFIDENTIAL CONFIDENTIAL

One of the largest, most advanced, 15+ years and 200,000+ fusion plasma privately funded Magnetized Target Fusion experiments conducted to date (MTF) technology companies Common Fusion Industry Visions and Dr. Michel LaBerge founded General Rapid innovation, development and testing Goals committed to reducing global Fusion (GF) in 2002 in a local garage laboratories headquartered in Vancouver, carbon emissions by transforming the Companys innovative and protected technology is the Canada, with result offices of 15Ridge at Oak years energy supply andof development and through clean, safe, 200+ patents and GF has now grown to more than 145+ Culham UK economical and abundant fusion patents pending energy scientists, engineers, technicians and support staff CONFIDENTIAL 2

A Spectrum of Fusion Technology Pathways ITER scale Magnetic NIF scale Inertial Confinement Fusion (MCF) Magnetized Target Fusion (MTF) Confinement Fusion (ICF)

All Confinement Hybrid All Compression

  • Very large, low-density plasma
  • US Naval Research Labs (NRL) -
  • Very small, high-density plasma Linus Program 1971- early research
  • Super fast compression pulses (µs)
  • Continuous Plasma and Control
  • Compact, medium density plasma
  • Expensive high-powered lasers for
  • Massive, expensive SC magnets
  • Slower compression pulses (ms) compression and heating
  • 1st wall materials challenges
  • No large SC magnets or lasers
  • Extreme sensitivity to uniformity
  • External plasma heating systems
  • Few materials and control issues
  • Manufactured fuel targets
  • Break Even System: >$25B (ITER)
  • Break Even System: <$1B
  • Break Even System: >$5B (NIF)

MTF technology optimal hybrid of magnetic confinement and inertial compression CONFIDENTIAL 3

Magnetized Target Fusion (MTF) and GFs Targeted Regime Plasma Energy Driver Power

$ Cost of Confinement

$ Cost of Driver CONFIDENTIAL 4

ITER (Magnetic Confinement)

National Ignition Facility- NIF (Inertial Confinement)

CONFIDENTIAL 5

How MTF Technology Works Cavity formation Compression system Plasma injection Fusion and energy launch conversion Plasma Injector Liquid metal Pistons Fusion A robustly designed central compression The inner liquid metal liner is quickly Simultaneously, a hot magnetized tokamak Fusion energy is released and absorbed vessel with a rotating inner vessel pushed inwards by the precisely plasma at 5 million degrees Celsius is into the surrounding liquid metal liner, containing liquid metal. A chamber cavity synchronized array of several hundred formed by a plasma injector and heating it to about 500 degrees Celsius of approximately three meters in diameter compression pistons magnetically injected into the compression is formed by rotating the liquid metal vessel chamber cavity The hot liquid metal is circulated through Timing control and pressure variations in inside the central vessel, which is a heat exchanger and converted to the piston launch system forms the liquid Confined within the collapsing metal cavity, surrounded by an array of several steam. The steam drives a turbine to metal into a spherical cavity for plasma the plasma is compressed (~9:1) within 4ms hundred compression pistons produce electricity and recharges the compression and heated to over 100 million degrees pistons for the next cycle Celsius, creating plasma temperatures and densities with requisite confinement The cavity reopens, pistons reset, and timeframes generating significant numbers this cycle repeats one time per second of fusion events for the commercial power plant CONFIDENTIAL 66

The fusion equivalent of a diesel engine: practical, durable, cost-effective CONFIDENTIAL 77

MTF Technology Advantages

1. Liquid metal liner resolves most high energy neutron challenges for first wall materials, it is also the heat transfer medium, the tritium breeding blanket, dose shielding, etc.
2. MTF does not require fist wall replacements
3. External plasma heating systems are not required (ICRH, RH, neutral beam systems, etc.)
4. Superconducting magnets or liquid helium plants not required
5. MTF has a high-density plasma with strong magnetic field as a result of compressed plasma flux
6. Pulsed approach, does not require complex high speed continuous plasma control systems
7. Diverters are not required
8. MTF has good tritium breeding ratio contained in liquid metal (1.4) allows for very small inventory quantities on site (~2g inventory for CPP vs. 4kg for ITER)
9. High Technology Readiness Levels (TRL) of key components
10. Lower parasitic electrical loads required for power plants
11. Lower capital costs projected for power plants
12. Very competitive LCOE for base load power generation Biggest Challenges for MTF:
  • Liquid metal wall interface with plasma (interactions?)
  • Repetition of compressions for CPP @ 1 /sec CONFIDENTIAL 8

MTF Phased Development and Commercialization Program Fusion Demonstration Plant (FDP) CPP Unit 1 2003 - 2008 2009 - Present Operations Start 2025 Construction 2030 Science and Technology Integrated Large Scale Commercial Early Experiments Development Prototype System Concept Exploration System Development Integrated System Solution Repetition Rate Compression Neutronic studies

  • Proof-of-Concept Fusion Relevant Temperatures Closed DT Fuel Cycle
  • Prototype Representative Repeatability High Reliability & Availability Plasma Compression Science
  • Plasma Stability
  • Compression Heating CONFIDENTIAL 9

Plasma Injection Systems One of the largest, fully operational plasma injectors in the world, at 10+ MJ pulsed power supply, 5MoC plasma injection temperatures, and exceeding 20 ms plasma lifetimes (FDP compression pulse ~4ms)

High quality plasmas can be reliably generated, and the PI custom designed for optimum plasma performance. Design adjustments available for magnetic fields, high vacuum and purity levels, injected plasma energies and temperatures, plasma density, etc.

CONFIDENTIAL 10

Compression Systems Demonstrated integrated compression technologies at prototype-relevant scale and successfully operated for 2 years of testing Demonstrating liquid metal liner performance on multiple different test fixtures and configurations FDPs large central compression vessel and spinning internal rotor under development with top industry partners FDP compression pistons with accumulator systems in design

(>500-unit array)

CONFIDENTIAL 11

The MTF Fusion Demonstration Plants (FDP) Purpose Integrate all key technologies for MTF fusion: Plasma injection, compression vessel, rotor, pistons, liquid metal & diagnosti cs The FDP Program has 3 primary goals:

70% scale Demonstrate at relevant power of commercial power plant-scale, that fusion conditions plant can be practically achieved using General Fusions MTF technology 1 pulse per Refine commercial fusion power plant economics and next steps day based on actual FDP performance repetition rate Establish science and engineering collaborations with UKAEA and Off-grid others, along with establishing demonstration General Fusions UK and European prototype HQ CONFIDENTIAL 12

FDP MTF Fusion Machine Approx. 17m in diameter, 13m in height 3m 3.9 ms Diameter cavity Plasma compression time 10.6 m3 1.06 m3 Pre-shot plasma volume Post-shot plasma volume 12MWe 3000 tons Power Req.

500+ drivers 20-40 MPa Accumulator pressures CONFIDENTIAL 13

FDP Facility and BOP Project, Engineering and Design Team Site and Building Owner & Project Sponsor Design Lead, Canadian HQ, UK office Architectural Partner, UK based Engineering Partner, Canadian HQ, UK offices Engineering & Sustainability, UK based Quantity Surveyor Specialist, UK based RIBA Stages A B A B CONFIDENTIAL 14

FDP Facility Design Principles - Form Follows Function Major design drivers Adequate space to install, commission, operate, service, repair and modify MTF machine Optimize functionality, adjacencies and efficiencies for testing, process systems, and rapid prototyping Isolate the hazards - lithium fire protection confinement boundary Serve GF needs now, and potential future tenants. Flexible capabilities, heavy lift /

craning, services, labs, processes, offices, etc.

BREEAM Excellent Standard CONFIDENTIAL 15

FDP Industrial Scale Facility Major facility parameters Total area = 9,940 m2 Highbay height = 32 m Total steel est. = 914 tons, concrete est. = 7,875 m3 Total est. Lithium = 20 tons, Helium = 5 tons Site Services, electrical = 12MWe Service water = 17 L/s, Fire = 126 L/s 60 persons operation staff, 80 parking spots allocated Hazard's analysis, safety case drafted, lithium fire protection primary risk concern Operations and Safety Plans being drafted CONFIDENTIAL 16

Major Design Efforts Completed:

  • RIBA Stage 2.5 Design Report finalized, approved and distributed
  • Preliminary Safety Case drafted, submitted and reviewed by UKAEA (HS&E requirements)
  • Preliminary fire mitigation strategy completed
  • Currently being reviewed by ARUP to ensure we meet appropriate local fire codes and regulations.

Consultations with local fire bigrade to follow

  • Preliminary flood risk assessment report completed
  • Currently working with Hatch, ARUP and McBains to determine flood mitigation requitements
  • Soils Sampling and GeoTech Reports underway
  • Confirmation on soils loading and for final foundation designs
  • Preliminary noise impact assessment completed
  • Currently completing the full community noise impact assessment with site samples, in support of planning CONFIDENTIAL 17

Selected Site at UKAEA Culham Science Center H3AT Liquid Metal Test Lab Future STEP Test Facility FDP JET Cambridge Culham Oxford (UKAEA)

London CONFIDENTIAL 18

Fusion Demonstration Plant Siting Selection

  • The UK and UKAEA have an aggressive modern fusion research effort underway with multiple projects, mature supply chain, and a fit for purpose regulatory environment for commercial fusion technology development companies.
  • UKAEAs Culham Science Center and Harwell, along with major universities Oxford, Cambridge, Imperial, etc. have a rich history of fusion research, and current robust fusion sciences education programs for future resources.
  • Building the FDP at the UKAEA Culham Science Center affords General Fusion access to significant world-class fusion energy and plasma research expertise in one location. Many science collaborations with UKAEA are being explored.
  • Fusion represents a safe, clean, sustainable, and environmentally friendly process for carbon-free base load energy generation. Power market studies show there exists a multi-trillion $ worldwide market for carbon-free replacement power generation over the next 20 to 30 years - UK is, and near early adopter markets.

CONFIDENTIAL 19

Onsite Geotech Drilling Underway CONFIDENTIAL 20

CONFIDENTIAL 21 CONFIDENTIAL 22 CONFIDENTIAL 23 CONFIDENTIAL 24 Regulation Considerations- FDP and Commercial Power Plant (CPP)

  • FDP- deuterium fueled only plasma
  • FDP- @1 pulse/day, lower energies will generate no activated fusion machine components, or dose beyond machine wall
  • All particle energies are below 50 MeV
  • CPP - high energy neutron pulses are surrounded in 4p by liquid metal (molten lead with small fraction of lithium for tritium breeding)
  • CPP- some fusion machine components will experience low-level activation
  • CPP- no dispersible first wall activated dusts, or off-site radiological hazards
  • An appropriate radiation protection program will be utilized for both facilities (i.e. NCRP Report 144)

CONFIDENTIAL 25

Neutron Yields Starting Starting Neutrons Operating System Fuel Plasma Plasma per pulse Frequency Diameter Density PCS (Plasma Pulse Verification Deuterium 0.4 m 1e14 cm-3 1e10 1 to 2 /year Program)

Fusion Demonstration Plant (FDP) Deuterium 3m 2e13 cm-3 1e13 ~1 /day Deuterium Commercial Power Plant (CPP) 4.4 m 2e14 cm-3 2e20 ~1 /s

- Tritium By comparison: Thermo Scientific P 385 produces 3 x 108 n/s.

Running for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> it will produce 9 x 1012 neutrons in a day GF has a CNSC Class 2 License for experiments CONFIDENTIAL 26

Regulation Considerations - FDP and Commercial Power Plant (CPP)

Tritium management of very low volumes:

  • FDP: Deuterium fuel only, one 4ms pulse a day
  • CPP: Total inventory of tritium2 2g (1.9 x 104 Ci)
  • CPP: Tritium self-contained throughput 76 g per day (~3oz)
  • CPP: High tritium breeding ratio of 1.4, no additional tritium required
  • CPP: Tritium is maintained in a closed loop monitored process
  • Initial small volume of start-up tritium purchased commercially
  • Total tritium inventory of ITER3 4 kg (3.9 x 107 Ci)
  • Bruce Pwr. (A,B,NPP) 2015 Emissions ~37.5 g (liquid/steam)

Mature commercial tritium handling control and monitoring practices exist.

In CPP real time tritium control, monitoring and tracking will be utilized. No planned effluents, off-normal release should be minimal (mg) and below NRC unrestricted release limits of I00 millirem per year, (100 - 500 Ci liquid and 100 Ci gaseous ) (EPA drinking water limits for Tritium 20k pCi/liter)

1) High bound estimate on maximum yield for 1,000 shots on FDP.
2) Not including possible additional couple of grams of tritium stored in getter beds for restarts.
3) http://www.iter.org/faq#What_will_be_the_total_amount_of_tritium_stored_on_site_What_are_the_procedures_foreseen_to_confine_a nd_control_the_stock _

CONFIDENTIAL 27

Fusion Technology Requirements- Utility Perspective EPRI Fusion Technology Study and Report -

Criteria for Practical Fusion Power Systems Electric utilities are keenly interested in the promise of fusion: large-scale electricity production anywhere, with virtually no natural resource depletion or environmental pollution. To expedite development of commercially viable fusion systems, the Electric Power Research Institute (EPRI) - the R&D wing of the U.S. electric utility industry - convened a panel of top utility R&D managers and executive officers1 to identify the key criteria that must be met by fusion plants in order to be acceptable to utilities.

This panels findings:

(1) Economics (2) Public Acceptance (3) Regulatory Simplicity 1 Present and former utility industry executives selected for their experience in managing the introduction of major new power generation technologies.

CONFIDENTIAL 28

Fusion Technology Requirements - Utility Perspective - continued

1. Economics To compensate for the higher economic risks associated with new technologies, fusion plants must have lower life-cycle costs than competing proven technologies available at the time of commercialization.
2. Public Acceptance Public acceptance and customer satisfaction will be essential to the commercial success of future fusion power plants. A positive public perception can be best achieved by maximizing fusion powers environmental attractiveness, economy of power production, and safety.
3. Regulatory Simplicity Because fusion is so different from existing fossil and nuclear power generation technologies, existing regulatory requirements for those technologies are not likely to be relevant to fusion. Appropriate regulation for fusion power plants should be determined by characteristics of the technology, the need for an expeditious and efficient regulatory process, and the obligation to minimize unnecessary barriers to fusion development.

CONFIDENTIAL 29

Regulation Summary Fusion has little to no radiological hazards to the public, as compared to fission nuclear. Fusion technology is much more like accelerators and irradiators - existing regulations are sufficient.

Fusion energy technologies are not reactors or utilization facilities - no SNM involved.

If required, any new regulations must be simple and fit for purpose based on specific technology, appropriate for the specific hazards - generic enveloping or prescriptive regulations, make it easier or more familiar for the regulator, but will hurt the fusion industry.

Safe, carbon-free fusion energy power markets are worldwide. Private companies will migrate to least resistance, early adoption markets.

Time is of the essence for the fusion industry.

CONFIDENTIAL 30

Website Twitter Instagram LinkedIn generalfusion.com @generalfusion @generalfusion general-fusion 31

Overview and establishment of the ASME Section III Division 4 (Fusion Energy Devices) subcommittee Special Working Group for Fusion Stakeholders (SWGFS)

Dr Thomas Davis Chairman of the Special Working Group for Fusion Stakeholders Member of ASME Section III Division 4 President & CTO of Oxford Sigma Email: thomas.davis@oxfordsigma.com NRC Public Fusion Forum - 27th October 2021 via MS Teams OS DOCID: R-179

Background - Codes and Standards

  • The purpose of nuclear codes and standards is to establish national or international standards that consist of a set of rules based on state-of-the-art knowledge, experience, and experimental feedback from nuclear facilities.
  • The design and construction of any nuclear reactor should make use of appropriate nuclear codes and standards to provide reassurance and quality control for the structural integrity and safety of these plants.
  • The codes provide the bridge between different suppliers, participants, researchers, designers, manufacturers, and regulators.

The documents can be viewed as a live document that is updated as better operational experience, knowledge, and scientific advancement is made available.

  • American Society of Mechanical Engineers (ASME) Boiler &

Pressure Vessel Code (BVPC)Section III is designed for nuclear 2 reactors since the 1956

ASME BPVC Section III Division 4

  • Existing nuclear codes and standards for construction do not adequately cover the design, manufacturing or construction of fusion energy devices that are currently being considered for future constructions. They also do not provide support for the on-going projects, such as ITER.
  • The goal of Division 4 is to develop a recognized fusion construction code and standard to be issued by ASME.
  • This new construction code would be used in the USA and/or globally as an acceptable basis for nuclear regulators for the construction, licensing and operating of new fusion facilities, such as the Compact Pilot Plant, DEMO, etc.

3

Organisation Section III Standards Committee Division 4 Subgroup for Fusion Energy Devices Special Working WG General WG Vacuum WG In-Vessel WG Magnets WG Materials Group for Fusion Requirements Vessel Components Stakeholders WG = Working Group 4

Membership of Division 4 as of 27 October 2021 5

ASME BPVC Section III Division 4

  • These new rules for fusion energy devices apply to safety classified components such as:
  • Vacuum vessels
  • Cryostats
  • Resistive / superconductor magnet structures
  • In-vessel Components (Divertors, Breeders, First-wall tiles)
  • And their interaction with each other.
  • Other related support structures, including metallic and non-metallic materials, containment or confinement structures, piping, vessels, valves, pumps, and supports will also be covered.
  • Division 4 is also working with the ASME Section XI Division 2 In-Service Inspection Operations Code in applying the use of the Reliability and Integrity Management (RIM) program 6

Division 4 Draft Standard

  • Division 4 issued in November 2018 as a Draft Standard for Trial Use of proposed code rules entitled Rules for Construction of Fusion Energy Devices ASME FE.1-2018 for 3 years.
  • The Draft Standard is not an approved consensus standard. ASME has approved its issuance and publication as a Draft Standard only.
  • 3 years will end in November 2021. Consensus approval is expected.

Changes since October 2021

  • Discussion on the plethora of approaches to fusion devices:

- Magnetic confinement fusion

- Magneto-Inertial Fusion

- Inertial Fusion Energy

  • Based on engineering principles and operational experience (so tokamak focused for now).
  • Provide pathway for future edits to develop the code over the decades.
  • Preparation for ASME acceptance as a new Division within Section III 7

SWG - Fusion Stakeholders Dr Thomas Davis Chairman of the Special Working Group for Fusion Stakeholders Member of ASME Section III Division 4 President & CTO of Oxford Sigma Email: thomas.davis@oxfordsigma.com NRC Public Fusion Forum - 27th October 2021 via MS Teams ASME 2021

Thank you to Dr Sutherland at CTFusion Inc for permission to 9 © CTFusion Inc use this figure

SWG - Fusion Stakeholders Scope

  • The SWGFS subcommittees aim is to provide a venue for stakeholders to voice their needs and development direction, provide comments and suggest input on the development of rules for the construction of fusion energy devices within ASME Section III, Division 4 Fusion Energy Devices code.
  • SWGFS shall identify the research and development efforts required to support the technical development of the code rules within other subcommittees.
  • Interface with BPVC XI Division 2 on Inservice Inspection issues is expected.

Stakeholders:

  • Private fusion companies / Vendors
  • Operators I am looking for members -
  • Supply chain Balanced and representative please reach out on
  • National regulators view thomas.davis@oxfordsigma.com
  • National Laboratories
  • Government
  • Universities 10

SWG - Fusion Stakeholders ASME Code Week

  • The Boiler Code Week is a forum for business leaders, engineers, scientists, and policymakers to discuss code changes and high-level topics related to the ASME BPVC concerning the design, fabrication, and inspection of boilers, pressure vessels, and nuclear power plant technologies.
  • These meetings occur in February, May, August, and November (4 times a year).
  • Free and public.
  • Held in person in the USA (COVID has made them virtual until May 2022).

Inaugural SWG Fusion Stakeholders Meeting

  • 1st November 2021

Overview and establishment of the ASME Section III Division 4 (Fusion Energy Devices) subcommittee Special Working Group for Fusion Stakeholders (SWGFS)

Dr Thomas Davis Chairman of the Special Working Group for Fusion Stakeholders Member of ASME Section III Division 4 President & CTO of Oxford Sigma Email: thomas.davis@oxfordsigma.com NRC Public Fusion Forum - 27th October 2021 via MS Teams OS DOCID: R-179

CFS creates viable path to commercial fusion energy with worlds strongest HTS magnet Tyler Ellis 10/25/2021 Copyright Commonwealth Fusion Systems 1

Importance of HTS magnets for fusion is well established

  • 2020 DOE FESAC Report on Fusion
  • Important technological breakthroughs include high-temperature superconductors (HTS) that enable the advances in magnet technology required to achieve that confinement. - Page 2
  • 2021 National Academies of Science Report on Fusion
  • the higher magnetic field made possible by the development of demountable high temperature superconducting magnets was identified as a key enabling technology that provides a potential path, when combined with advanced operating scenarios, to a compact fusion pilot plant with high fusion power density. - Page 59 10/25/2021 Copyright Commonwealth Fusion Systems 2

CFS path to commercial fusion energy COMPLETED COMPLETED COMPLETED CONSTRUCTION Early 2030s Proven science October 2020 September 2021 UNDERWAY Fusion power on the Alcator C-Mod Published peer- Demonstrate Operation in 2025 grid Pelectric~200MW reviewed SPARC groundbreaking Achieve net energy from physics basis in magnets fusion Journal of Plasma Physics HTS Magnets SPARC ARC 10/25/2021 Copyright Commonwealth Fusion Systems 3

New class of magnets for fusion energy

  • CFS is building advanced large-bore, HTS magnets using scalable manufacturing techniques
  • Our HTS magnet is made up of 16 staked pancakes; each pancake by itself is the largest HTS fusion magnet in the world
  • High field approach reduces fusion power plant size by a factor of 40
  • HTS magnets combined with the proven fusion science and engineering of tokamaks enables smaller, lower-cost fusion power plants faster
  • HTS magnet technology will be used in SPARC, the worlds first net energy from fusion device, and then ARC, the first fusion power plant 10/25/2021 Copyright Commonwealth Fusion Systems 4

Highly capable integrated coil test stand 10/25/2021 Copyright Commonwealth Fusion Systems 5

Successful test of fusion magnet

  • Fully representative of SPARC coil operation
  • 20T peak magnetic field on coil, well beyond what LTS can do
  • Largest HTS magnet in the world by a factor of 100x
  • >100MJ,
  • >250 km of HTS
  • >100A/mm^2,
  • >2m size
  • Successfully tested on September 5, 2021 10/25/2021 Copyright Commonwealth Fusion Systems 6

SPARC design has progressed and construction started

  • HTS means smaller tokamaks with lower tritium inventories and smaller low-level waste generation
  • This confirms future fusion energy facilities fit comfortably within 10 CFR 30
  • Applied agile practices from industries like space - systematic de-risking
  • Long-lead procurement begun
  • Site settled and build started 10/25/2021 Copyright Commonwealth Fusion Systems 7

Domestic burning plasma by 2025 Acquired land: Spring 2021 Total size: 47 acres Location: Devens, MA Initial magnet manufacturing facility: 160,000 sf Manufacturing operations: 2022 SPARC operations: 2025 10/25/2021 Copyright Commonwealth Fusion Systems 8

Construction is underway (progress as of 10-22-2021)

CFS Headquarters and HTS Magnet Factory SPARC 10/25/2021 Copyright Commonwealth Fusion Systems 9

Construction is underway (progress as of 10-22-2021) 10/25/2021 Copyright Commonwealth Fusion Systems 10

Plans that accelerate fusion energy Government plans prior to advances JET (UK) ITER DEMO (World) (World)

~ to scale 2015 2020 2025 2030 2035 2040 2045 2050 2055 2060 C-MOD SPARC ARC First Plasma Net-energy Power Acceleration of the plans due to physics plant breakthroughs in magnets, materials, controls and commercial interest CFS timeline is similar to the other commercial efforts 10/25/2021 Copyright Commonwealth Fusion Systems 11

Summary

  • CFSs successful magnet test is a major milestone towards the goal of demonstrating net fusion energy by 2025 and putting fusion megawatts on the grid by the early 2030s
  • As noted in the October 2021 PCAST public meeting, successful commercialization of fusion requires appropriate regulatory treatment
  • CFS believes the current byproduct material regulatory model (10 CFR 30) is sufficient to ensure a safe and cost-effective fusion energy industry
  • Part 30 is inherently flexible and offers a reasonable balance between predictability for developers while providing regulatory flexibility as the fusion industry matures
  • Establishing subjective and arbitrary regulatory limits in a hybrid model creates confusion among stakeholders without improving safety or environmental protection 10/25/2021 Copyright Commonwealth Fusion Systems 12

The fastest path to limitless, clean energy 10/25/2021 Copyright Commonwealth Fusion Systems 13

FIA Members The Stakes of NRC Fusion Decision The world is racing to be ready for fusion energy power plants

  • UK Green Paper on Fusion Regulation
  • European Commission Study: Towards a specific regulatory framework for fusion facilities
  • IAEA TECDOCs on regulation and safety of fusion facilities

The NRCs Four Questions

1. Offsite Consequences 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?
2. Byproduct Materials Inventory What advantages/disadvantages would stand 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?
3. Power Output 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?
4. Fusion Reaction Type / Fuel Choice What advantages/disadvantages would stem from categorizing Fusion Systems based on the fusion reaction being applied(neutronic (DT, DD, TY) or aneutronic) as one of the many different decision-making tiers? What would the expected difference in the level of safety systems between fusion facilities for these two types of fusion reactions?

Overall comments on NRC questions

  • The NRCs questions appear to presuppose the creation of a new regulatory framework with a tiered system of regulation
  • Utilizing Part 30 is the most effective, risk informed, and tailored method to address the regulation of Fusion facilities
  • Part 30 has proven itself flexible enough to handle an incredibly wide range of byproduct-based technologies with varying degrees of risk
  • Part 30 is well established and provides regulatory predictability for fusion energy developers
  • Part 30 also provides the NRC flexibility as fusion technologies mature

Overall comments on NRC questions

  • In general, the Part 30 regime already provides sufficient flexibility to allow the NRC to tailor the requirements to individual fusion designs based on their risk - This is a graded approach to regulation and risk
  • Part 30 already contains appropriate gradations, and can be adapted to support any gradations needed.
  • Regulatory requirements for emergency planning, decommissioning, and other factors impacting health and safety are contained in Part 30
  • Part 30 requirements already vary depending on issues such as offsite consequences, waste, facility design, and inventory limits
  • There are no potential fusion facilities which need a higher grade of regulation than what is already provided by Part 30
  • Imposing a graduated approach to capture hypothetical technologies that no utility or vendor would ever want to order or build drives unnecessary conservatism in the overall regulatory approach

Offsite Consequences

  • Offsite impact is an appropriate decision-making category for fusion regulation
  • NRCs core mission: protecting public health, safety, and the environment
  • Provides the NRC flexibility to evaluate individual facilities
  • Flexible method that can evolve over time as fusion technologies develop further
  • Fusion facilities will present similar offsite impacts to many other byproduct materials facilities. Therefore, this category can build on previous regulatory decisions
  • There is a well-established framework under Part 30 for evaluating offsite consequences for many different types of facilities

Offsite Consequences

  • There is no need to develop any new regulations for estimating offsite consequences for fusion facilities
  • FIA believes the specific licensing guidance in Part 30 is sufficient for purposes of estimating offsite risk
  • There is no health, safety, regulatory or other advantage in developing a new method for calculating the offsite consequences for fusion energy projects
  • Part 30 already categorizes materials licensees based on their potential offsite consequences
  • Part 30 establishes certain offsite exposure limits for members of the public
  • Example: emergency planning requirements contain grades depending on the license applicants ability to demonstrate maximum offsite dose. Licensees which exceed certain thresholds must create an emergency plan, and the NRC can require additional details or mitigation is necessary to address offsite consequences.

Offsite Consequences

  • The maximum possible risk presented by fusion facilities is not significant enough to require PRAs
  • The Commissions Policy Statement on Use of Probabilistic Risk Assessment Methods in Nuclear Regulatory Activities (60 FR 42622) recognized that there may be situations with material users where it may not be cost-effective to use PRA in their specific regulatory applications.
  • At its current stage of development, requiring fusion licensees to conduct Probabilistic Risk Assessments would introduce significant regulatory uncertainty, unnecessarily hamper designers, and impose unsustainable costs on developers, effectively precluding many fusion energy developers from building their demonstration devices in the U.S.

Inventory Limits

  • Inventory limits are reasonable for consideration in context of evaluating offsite risks, but not as independent criteria
  • One exception - potential to establish exemptions based on certain very low inventory limits
  • An independent focus on inventory limits would not adequately consider differences in facility design or types if inventory
  • Part 30 regulations are currently sufficient to accommodate the anticipated inventory limits any potential commercial fusion facility
  • There is no need to create new inventory limits above which a new regulatory regime for fusion facilities would apply

Inventory Limits

  • The NRC should consider establishing inventory limits below which certain exemptions would be granted, such as for fusion facilities which do not use tritium
  • Some potential designs do not involve any tritium, and should receive broad exemptions as they pose even smaller radiological risks

Power output

  • There are no advantages to basing regulatory requirements on thermal power output
  • MWt output does not relate to risk, potential offsite dose, decommissioning planning, or any other radiological factor
  • MWt does not consider technological differences
  • Categorizing fusion devices by MWt would impose arbitrary constraints on fusion developers

Fusion Reaction Type/Fuel Choice

  • Other than its relevance to an overall evaluation of offsite impacts or decommissioning planning, fusion reaction and fuel choice are not appropriate methods to categorize fusion devices
  • While some fusion reactions may involve no byproduct material, and be eligible for regulatory exemptions, the level of offsite risk is more inherent in the specific facility design rather than the reaction type
  • From a risk-informed perspective, all of the conceived fusion reaction types or fuel choice present risks that can be appropriately regulated under existing Part 30 regulations
  • Some types of fusion reactions may involve no byproduct material, and be eligible for exemptions, but there is no basis for establishing more stringent regulatory requirements based on reaction type

Closing

  • Even though both technologies are intended to produce electricity, fusion devices and fission reactors share few common risks or radiological hazards
  • Fusion devices do not use or produce special nuclear material, high level waste, or spent nuclear fuel, and cannot have a criticality event
  • Fusion devices fundamentally are not utilization facilities
  • Part 30 is the appropriate regulatory framework for fusion devices
  • Fusion devices have much more in common with devices such as accelerators and cyclotrons, which are appropriately regulated under Part 30
  • Although no developers are planning large facilities, even very large fusion facilities would be most appropriately managed under Part 30, rather than being subject to utilization facility requirements
  • Part 30 already contains risk-informed grades of regulation, and can be easily amended to incorporate further, that can be applied to specific facilities based on a variety of factors

THANK YOU

  • FIA continues to encourage the NRC Staff to engage in monthly meetings with NRC members to further build its understanding of fusion technologies while it works to develop an options paper for the Commission
  • Read our FIA Regulatory White Paper at:

www.fusionindustryassociation.org

/post/fusion-regulatory-white-paper

10 CFR Part 30 - Examples of Regulatory Scalability Duncan White (NRC)

Diego Saenz (Wisconsin)

Huda Akhavannik (NRC)

Donald Palmrose (NRC)

October 27, 2021 1

Overview of a Part 30 Approach

  • Part 30 licensing has key frameworks that may be leveraged or extended to license fusion facilities

- Examples: Emergency Planning, Effluents, Training

  • Categorization criteria for fusion facilities
  • Could be used in combination with other regulatory mechanisms for a graded approach
  • Any scalable approach needs clear and predictable decision-making criteria to ensure consistency and regulatory certainty 2

3 Effluents Facility Type Inventory Nuclear Pharmacy I-131, Mo-99 Facilities with robust Medical Isotope Production I-131, Mo-99 radiological effluent control H-3, Lu-177, Yb-175, systems are licensed to have Fusion R&D (proposed) Yb-177 less than 10% of the 10 CFR H-3, Co-60, Cs-137, 20, Appendix B, release Source Manufacturing Ir-192, Am-241 requirements. Fusion Energy R&D H-3 Rare Earth Processing U-238, Th-232 4

Training Features of Part 30

  • Based on role and level of interaction with material
  • Individual named on the license could be the supervisor or the primary handler/operator

- Following table focuses on individuals named on the license or on licensee-maintained list

  • Designed to fit industry involved

- Medical use heavily leverages Medical Boards and Licensure

- Industrial radiography leverages third-party certifiers such as American Society of Nondestructive Testing, Inc (ASNT) 5

Portable/Fixed Diagnostic R&D Manufacturer Well Radiation Industrial Panoramic Gauges Medical (incl. & Distributor Logging Oncology Radiography Irradiators Fusion)

Transferable X X X X X X X X Refresher X X X X X X X X Training OJT X X X X X X X X Specific X varies varies X X C - Commonly used number of to meet regulatory hours criteria or commonly Device varies varies X X X X required by licensee Specific tie-downs Training X - Required by Requires C varies varies X X, C X X regulation or AUs physical included in Licensing presence Guidance 3rd Party C C X (periodic User renewal Examination required)

Review Past X C X X Events Simulated X, C X, C X Events 6

Categorization Considerations Radionuclide form (gaseous, liquid, bound, Tritium inventory already used in unbound) affects offsite consequences, not regulations just activity.

Tritium handling system may account for a Megawatts electric (MWe) or large fraction of tritium inventory and thermal (MWth) may not correlate to inventories could widely vary radiological risk for fusion facilities Wide range of facility types, including aneutronic fusion 7

  • Agreement States may be willing and able to maintain on-site inspection staff (e.g.,

Resident Inspectors)

Agreement - Illinois Emergency Management Agency currently maintains Resident Inspectors State at their nuclear power plants

  • Agreement States may follow NRC practice Considerations of consulting with DOE National Laboratories and other contractors for portions of licensing review 8

Conclusion STAFF IS CURRENTLY CURRENT APPROACH TO CATEGORIZATION CRITERIA AGREEMENT STATES TRAINING, EFFLUENTS, AND CONSIDERING PART 30 AS MAY BE APPLICABLE TO WOULD BE KEY PARTNER EMERGENCY PLANNING ARE A POTENTIAL APPROACH. FUSION LICENSING UNDER IN REGULATION OF ALL APPLICABLE TO FUSION PART 30. FUSION FACILITIES.

FACILITIES.

9

10 CFR PART 53 Overview and Status

Part 53 Relationship to Fusion Energy Systems Nuclear Energy Innovation and Modernization Act (NEIMA) and Commission Direction o advanced nuclear reactor means a nuclear fission or fusion reactor, o SRM-SECY-20-0032 approved staffs approach for Part 53 rulemaking and directed the staff to consider the appropriate treatment of fusion reactor designs in our regulatory structure by developing options for Commission consideration o July 15, 2021, NEIMA Section 103(e) Report to Congress on Part 53 Rulemaking Staffs Response to SRM-SECY-20-0032 and Path Forward o Continue interactions in public forums with U.S. Department of Energy (DOE) and Fusion Industry Association (FIA) o Develop options for regulatory approaches for fusion in parallel with Part 53 rulemaking o Part 53 primarily fission-based; technology-inclusive concepts may accommodate fusion technologiesmaintain flexibility for future Commission direction Part 53 is an option to be presented to the Commission

Transformative Aspects of Part 53 o Establishment of technology-inclusive safety criteria o Risk-informed approach to safety criteria to provide predictability for the classification of plant equipment and controls over that equipment during operation o Approach to the selection of design basis accidents (DBAs) that provides flexibility to designers to designate which equipment will be classified as safety-related o Allowances for applicants to credit analytical safety margins in their design to gain operational flexibilities in areas such as EP and plant siting o Quality assurance requirements that would allow use of a broader set of codes and standards o Proposal to address manufactured reactors that would be fueled at the manufacturing facility and transported to the reactor site

Part 53 Development Publishing Engaging Responding Evolving Assessing The staff Optimizing future Continuing to Developing options Developing the continues its novel public and ACRS consider input for technology- path forward to approach of meetings to be from numerous inclusive achieve the releasing more topic-specific stakeholders, the alternatives that objectives of the preliminary rule to enable richer public, and ACRS, do not rely on PRA approved language to focused dialogue as we evaluate in a leading role to rulemaking plan facilitate early on specific issues changes to the address while addressing stakeholder (e.g., staffing, role preliminary stakeholder stakeholder engagement of PRA) language comments comments

Part 53 Outline Subpart B Subpart C Subpart D Subpart E Subpart F Subpart G Project Life Cycle Requirements Design and Siting Construction Operation Retirement Definition Analysis External Construction/ Facility Safety

  • Safety Objectives System Hazards Manufacturing Program
  • Safety Criteria

& Component

  • Safety Functions Design Site Ensuring Surveillance Characteristics Capabilities/ Maintenance Analysis Reliabilities Requirements Environmental Configuration Considerations Change Control Control Safety Categorization & Staffing &

Special Human Factors Treatment Environmental Considerations Programs Security, EP Other Plant/Site (Design, Construction, Configuration Control)

Clarify Subpart A Analyses (Prevention, Mitigation, Compare to Criteria)

General Controls Provisions and Plant Documents (Systems, Procedures, etc.) Distinctions Subpart J Between Admin &

Reporting LB Documents (Applications, SAR, TS, etc.) Subparts H & I 5

Part 53Rulemaking Status Rule Language Stakeholder Engagement o Early Release: (A) definitions, (B) safety criteria, o 8 public meetings and 9 ACRS meetings (C) design and analyses, (D) siting, (E) construction & o Future meetings will be topic focused manufacturing, (F) operations, programs, o Recent meetings:

(Part 73) security and EP. This week: 10/26 on Personnel (Subpart F); 10/28 on o Recent Release: revision to (B) safety criteria and Technology-Inclusive Deterministic Alternative (C) design and analyses; new language for (H) licensing Public: 9/15 on 50.59-like change process; 8/26 on processes, (I) maintenance of the licensing basis, and graded PRA; 6/10 on Security and EP (J) reporting and financial ACRS: 9/23 ACRS meeting; 7/21 on EP/Licensing o Nearing completion of 1st iteration of all Part 53 subparts Modernization Project and Technology-Inclusive Deterministic Alternative Recent Industry Input Focus Areas o Continue stakeholder engagement o NEI letter presenting unified industry positions (July 14) o Continue preliminary release of rule language o USNIC letter (July 15) o Develop the rule package o NEI Manufacturing Licenses white paper (July 16) o Work on the supporting guidance o NEI comments on security sections (August 31) o NEI Role of PRA white paper (September 28)

Leveraging and Combining Existing Licensing Processes Operations Fuel Load Operating License Site (OL) selected Combined License (COL)

Use OL or custom Site COL to develop a CP based on subsequent DC SDA, ML or DC selected Standard Design Manufacturing Design Approval (SDA) License (ML) Certification(DC)

Part 50 Construction Part 52 Site selected CP and COL may reference Early Site Permit Permit (CP) Part 53 (ESP) or site suitability review (SSR) 7

Next Steps

  • Continue ongoing activities o Part 53 development and stakeholder engagement o Continue public forums with DOE and FIA
  • Deliver options paper to Commission - informed by stakeholder interactions
  • Incorporate fusion technologies into a technology-inclusive regulatory framework by 2027 in manner directed by Commission
  • Key documents related to the Part 53 rulemaking, including preliminary proposed rule language and stakeholder comments, can be found at Regulations.gov under Docket ID NRC-2019-0062

Thank You Discussion/Questions Schedule/Next Steps

  • The timeline for providing options to the Commission on the licensing and regulations of Commercial fusion power plants is being done in parallel, but on a separate schedule from the development of the draft proposed 10 CFR 53.
  • Rulemaking is done via a comprehensive, multi-step process. Additional information:

https://www.nrc.gov/about-nrc/regulatory/rulemaking/rulemaking-process.html

  • The NRC would consider extending the May 2022 SECY paper target date should an extension to the 10 CFR 53 schedule occur.
  • Extending the proposed SECY aligns well with industrys desire to have a series of workshops to allow for greater engagement and understanding of fusion technology, risk, and legal requirements.

Thank You!

Closing Remarks

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