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M221208: Transcript - Overview of Advanced Reactor Fuel Activities

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1 UNITED STATES NUCLEAR REGULATORY COMMISSION

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OVERVIEW OF ADVANCED REACTOR FUEL ACTIVITIES PUBLIC MEETING

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THURSDAY, DECEMBER 8, 2022

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The Commission met in the Commissioners' Hearing Room, One White Flint North, Rockville, Maryland, at 9:00 a.m., Christopher T.

Hanson, Chair, presiding.

COMMISSION MEMBERS:

CHRISTOPHER T. HANSON, Chair JEFF BARAN, Commissioner DAVID A. WRIGHT, Commissioner ANNIE CAPUTO, Commissioner BRADLEY R. CROWELL, Commissioner ALSO PRESENT:

BROOKE P. CLARK, Secretary of the Commission BERNICE AMMON, Acting General Counsel

2 NRC STAFF:

DANIEL H. DORMAN, Executive Director for Operations JASON PIOTTER, Senior Mechanical Engineer, Division of Fuel Management, NMSS DR. WENDY REED, Metallurgist, Division of Engineering, RES MIRABELLE SHOEMAKER, International Safeguards Analyst, Division of Fuel Management, NMSS ROBERT TAYLOR, Deputy Office Director for New Reactors, NRR CHRISTOPHER VAN WERT, Senior Reactor Systems Engineer, Division of Advanced Reactors and Non-Power Production Utilization Facilities, NRR EXTERNAL PANEL:

DR. CHRISTINA BACK, Vice President, General Atomics ANDREW GRIFFITH, Deputy Assistant Secretary for Nuclear Fuel Cycle and Supply Chain, Office of Nuclear Energy, DOE DR. EDWIN LYMAN, Director of Nuclear Power Safety, Union of Concerned Scientists DR. RUSTY TOWELL, Director, NEXT Lab, Abilene Christian University SANDER VAN TIL, Lead Scientist, Nuclear Fuel Research & Innovation, Nuclear Research and Consultancy Group JAMES VOLLMER, Senior Manager Nuclear Design, TerraPower JENNIFER WHEELER, Director of Regulatory Affairs, TRISO-X

3 1 PROCEEDINGS 2 9:00 a.m.

3 CHAIR HANSON: Good morning, everyone. I convene 4 the Commission's public meeting on advanced reactor fuel activities. I thank 5 you all for joining and supporting this meeting this morning. Welcome to all 6 of our external participants, and those joining us online. I think it's very timely 7 for us to be having this meeting and discuss it in a public forum. I think there's 8 been a lot of innovation in the reactor fuels area over the last 20 years.

9 I think, for a long time, innovation in the nuclear sector, the 10 fuels were kind of the constant, and there was a lot of innovation in other parts 11 of the reactor system. And I think what we've seen is a lot of the research, 12 and development supported by DOE, NRC, and other entities kind of come to 13 fruition in the last four or five years, such that now we've got variables, if you 14 will, on kind of both sides of the equation, where reactor developers are really 15 exploring innovations and new ideas in both moderators and coolants, and 16 other kinds of materials on the one side, and in the fuels themselves.

17 So, I think this is a great time to have this meeting, and I 18 look forward to a really productive discussion. We'll hear from our first 19 external panel, we'll have a short break, then we'll hear from the staff.

20 But before we begin, I'll ask my colleagues if they have any 21 remarks they'd like to make. No? Okay. So, with that we'll begin with 22 Andrew Griffith -- I'm not used to calling you Andrew, we're in official setting.

23 Deputy Assistant Secretary for Nuclear Fuel Cycle and Supply Chain from the

4 1 Office of Nuclear Energy at the Department of Energy. Mr. Griffith, the floor 2 is yours.

3 MR. GRIFFITH: Thank you, Chairman Hanson, and thank 4 you all to the Commission. It's an honor to be here with you as always.

5 Clearly the work you do is going to be essential as we go forward, and I think 6 forums like this, where we can exchange information, are paving the way to 7 all of our success going forward. So, really appreciate all that you do, and 8 the independent regulatory oversight that you perform.

9 So, my slides, are they going to be projected? There they 10 are. So, I have a lot of substance here, I'm just going to hit the high points.

11 It will leave some room for some Q&A later on, but also our colleagues to my 12 left will also add more detail for their specific lane, if you will. So, I'm going to 13 start out with kind of a family portrait portfolio of our advanced reactor 14 demonstration awards. Then I'll follow by some of the work we're doing in the 15 advanced fuels area, and then I'll talk about the high assay LEU work that 16 we're doing, which is really, I think essential to the future. Next slide please.

17 All right, these are the two advanced reactor demonstration 18 reactors, 50/50 cost share. They are genuine Generation IV reactors, and 19 they definitely will help set the stage over the next decade, as they plan to 20 start up later this decade. Clearly they need the fuel, and we're working on 21 that. Next slide please.

22 These are the five risk reduction awards, they're kind of the 23 next wave if you will, and there's a good diversity of reactor concepts there as 24 well. Four of them do need high assay LEU, the one light water reactor

5 1 concept is the SMR-160 by Holtec. But there's a lot of work to be done here 2 to set the stage for the future beyond this decade. Next slide please.

3 And these are the three advanced reactor concepts, ARC20 4 awards under the ARDP funding opportunity announcements. Less mature 5 concepts, but this will help -- the funding that we're cost sharing with them, 6 80/20, will help prepare them for playing a role in the future beyond this 7 decade as well. Next slide please.

8 Now, I'm getting into the three basic fuel concepts that we're 9 working on in a research and development perspective. The most mature --

10 one of the most mature is the TRISO fuel. We spent two decades working 11 on this starting in the 2002 time frame. We spent over 400 million dollars 12 collectively on this over time and have made significant progress. It does 13 build on concepts that were done elsewhere in Germany before, but we're 14 coming to the point where we're at the end of the R&D phase, and ready for 15 commercial fuel fabrication and deployment. There's still some work we can 16 do to support the reactor developers and the fuel fabricators in scaling the 17 technology up, making it more economic, and so that's still some work to be 18 done.

19 But we've done, I think we've made tremendous progress in 20 this area over the last decades, and it's definitely paving the way for the future.

21 Next slide please.

22 So, the metal fuel area is one that is also mature. However, 23 the reactors that are planning on using the metal fuel for sodium fast reactor 24 applications are really based on the experimental breeder reactor two

6 1 concept, sodium bonding. There are evolutions to be implemented there to 2 develop the fuel without the sodium bonding, which as you all know is a 3 reactive component, and it requires treatment before ultimate disposition.

4 And so, that's the focus of this area and it's also building on the lessons that 5 we gained in the TRISO development area, where the efficiencies that we've 6 gained over the years of irradiation and post irradiation examination. And 7 then when you add in the capabilities of today of high performance computing, 8 the modern day post radiation examination concepts, where you get into multi-9 scale, multi-physics types of examination, data collection, and feed that into 10 the high performance computing. And then the latest kind of innovation that's 11 at play with the fuel qualification process is the instrumentation capabilities 12 that we have. Where we have instrumented test leads connected to the 13 experiments while they're being irradiated in piles. So, a lot of great 14 innovation there. The idea is that as the advanced reactors are deployed, 15 and the fuel concepts do evolve and improve, that we're able to do that, rather 16 than introducing fuel in 20 year time frame, we can get that down to under a 17 10 or 5 year time frame with the tools that we have available. So, that's a key 18 objective there. Next slide please.

19 So, molten salt, while there is some history in this, there's a 20 lot we don't know about this approach. There's a number of challenges, 21 clearly the corrosion, the criticality control, ensuring homogeneous chemistry, 22 these things are all really important challenges that have to be addressed.

23 There are more efforts today than there have been in the past to understand 24 this, because the benefits are tremendous. Again, it has high temperature

7 1 applications in both energy generation and industrial applications. And you 2 have online refueling and fission product removal, possibilities that maximize 3 the capacity factors. So, there's a lot of challenges here, but there's also a 4 lot of benefits. Next slide please.

5 And then getting to the high assay low enriched uranium 6 HALEU fuel supply, this is clearly a priority in my office. It's hard to imagine 7 the weight of the future resting on your shoulders, but really with Russia being 8 the only current supplier of high assay LEU, the alternative is us. And the 9 good news is, while we have been chipping away at this over the recent years 10 with the demonstration at Piketon, we were successful in awarding a contract 11 last month to startup and operate that demonstration cascade. That's a good 12 first step, however the big lift is incentivizing a commercial supply chain that 13 doesn't exist today, the classic chicken and egg situation, needs to be broken.

14 And we believe the government role is to establish that temporary demand 15 signal to stand up that capacity. Fortunately, with the Inflation Reduction Act, 16 we were given the resources to get started on that. Whether that's enough, 17 or not still remains to be seen. I know there's still work within the 18 administration to get additional funding on that, as well as in Congress. So, 19 we're going to continue to work toward that end, because this is so incredibly 20 important to be successful here. Next slide please.

21 So, this lays out what the Inflation Reduction Act, how the 22 700 million dollars that was appropriated under the Inflation Reduction Act, 23 how it's allocated. The first three parts are criticality benchmarking, 24 transportation package design adaptation. And support for certificates of

8 1 compliance, amendments, or improvements to existing packages that 2 obviously your agency will play a role. So, there's 100 million dollars 3 allocated toward that. Whether, or not that's all needed for that scope of work 4 is not clear, but we intend to test the waters in the coming months with a 5 funding opportunity announcement for cost-shared awards to achieve that.

6 The next grouping is essentially to provide high assay LEU 7 to the users, and that's where we're using the 500 million dollars allocated to 8 that. The last bucket, if you will, is 100 million dollars for support, and there's 9 a lot of flexibility there. The areas that come to mind on what that could be 10 used for, and again it's most likely going to be through a funding opportunity 11 announcement with cost shared awards, is things like the deconversion 12 technology to take the high assay LEU from UF6 to either oxide or metal.

13 There's some opportunities for refinement and implementation that could be 14 pursued there. The last piece is the -- that comes to mind, is new enrichment 15 technology, such as laser technology could also be something that could 16 mature under cost a cost shared award at that last bucket. Last slide please.

17 This is my summary. I think the area of fuel R&D is so 18 important. One of the sacrifices the department made, and Chairman 19 Hanson, I think you can recall this, the 2020 time frame when the ARDP 20 program was stood up. It came at a price, it came at a price of some of our 21 fundamental R&D programs, and fuel was one of the areas hit by that. And 22 it has taken us a number of years to get traction on the LIFT program for 23 accelerated fuel qualification. We hope that Congress in the coming weeks 24 can resolve the continuing resolution, and support our request there, which

9 1 supports that activity. And then beyond that, I can't overemphasize the 2 importance of our activities supporting or incentivizing commercial high assay 3 LEU supply. Thank you.

4 CHAIR HANSON: Thank you, Mr. Griffith. Next we'll go 5 online to Mr. Sander Van Til. He's a lead scientist in nuclear fuel research 6 and innovation at the Nuclear Research and Consultancy Group. Mr. Van 7 Til?

8 MR. VAN TIL: Yes, good afternoon, well good morning for 9 you. My name is Sander Van Til, I work at the NRG in Petten, Netherlands 10 in the fuel irradiation department. I will tell you a bit about what kind of 11 research and what kind of services we supply to the nuclear energy sector.

12 So, if you'll go to the next slide?

13 So, first, where are we? In the top right, you see a picture 14 of Europe, and the Netherlands is in the northwest. In the Netherlands, we 15 are in the northwest, on the shores of the North Sea in Petten. And you see 16 an aerial view of our site with two positions indicated, one being the high flux 17 reactor on the left, and on the right we have several radiological facilities, that 18 helps our laboratories in particular. Now, if you go to the next slide?

19 Some very basic specifications of our high flux reactor. It's 20 a reactor that's over 60 years old now. It's a tank and cool pipe material test 21 reactor, which basically we have a four-meter-high reactor vessel submerged 22 in a pool, as you can see on the left hand side. And on the bottom of the 23 reactor vessel is a core box where we place experiments. It's 45 megawatts 24 thermal power, and a unique feature of the high flux reactor is that we are

10 1 stable in a constant flux profile irradiation position.

2 We use our reactor mainly nowadays for isotope production, 3 that's a large part of our turnover. But besides that, we supply services to the 4 nuclear energy infrastructure for qualification of parts and components, but 5 also a fair amount of R&D work that we do. Yeah, so we operate our reactor 6 nine cycles in a year, approximately with 30 operational days per cycle.

7 Summing up to approximately 300 full power days per year, so there's a high 8 capacity factor. So, in our reactor 17 in core positions, which we use for 9 irradiations of both isotopes and materials. We have pool side facility with 12 10 positions and some bin tubes, which mostly are out of use, but we still do some 11 neutron diffractometry analyses. So, if you go to the next slide?

12 You basically see a top view schematic of the reactor core, 13 and basically the blue squares are the irradiation positions that we have, so 14 the 17 I mentioned. And the red squares are the driving fuel of the reactor, 15 and you see the control rods, we have set control rods in the reactor core 16 surrounded by beryllium reflectors. So, on the left hand side you have what 17 we call the pool side facility. It's a facility where we are able to move 18 experiments, or isotope irradiation facilities from a distance towards the core 19 box to increase the flux or the power in the experiment. So, inside the core, 20 we have these facilities -- positions where we can put irradiation experiments.

21 And from the left to the right the flux increases. So, the flow rate increases, 22 and also the thermal flux ration increases.

23 As well on the left hand side, what you call the high flux 24 region of the core, these are particularly suited for material irradiations, where

11 1 the goal is to generate DPAs, and we can reach up to seven DPAs per year 2 in that row. Fuel irradiations we typically do more on the right-hand side of 3 the core. Where for nominal LWR fuel, the building makes about 300 to 400 4 per centimeter in these first rows. Yeah, so if you go to the next slide?

5 So, this is the selection of irradiations that we do. We 6 address the various reactor types in fuels and materials. So, for fuels, one 7 running program that we have is on irradiation induced creep for LWR fuels, 8 both for UO2 and MOX. We have carried out qualification of HDR fuel 9 pebbles in the past, so these are experiments that we have carried out roughly 10 in the last decade.

11 Most fuel irradiations that we did was for the liquid metal fast 12 reactor concept, where we irradiated -- well, numerous rodlet irradiations, 13 ranging from high plutonium content MOX to nitrite fuels, and some americium 14 blanket candidates, also some matrix fuels and some other fuels.

15 Yeah, so several years ago we started molten salt irradiation 16 program, where we started irradiations on fluoride salts. And in particular we 17 look at the interaction of the fluoride salts, also with graphite and steels. And 18 also we have a separate gamma irradiation to study the radiolysis of fluoride 19 salts. So, on the materials side, we basically focus on nuclear graphite and 20 steels, where one high profile program was on lifetime extension of AGR, so 21 the advanced gas cooled reactors in the UK where we irradiate graphite 22 samples from those AGRs to fast forward the irradiation damage to estimate 23 the allowed lifetime extension. So, other irradiations that we do involve the 24 qualification of nuclear graphite for MSR and HTR applications. Steel

12 1 irradiations mainly involve aging, so reactor pressure vessel materials for long 2 term operation, but also some new grade steels, nickel based steels in 3 particular, also for MSR applications to study, for example, the helium 4 embrittlement. So, we'll go to the next slide, and we'll go to an example of 5 the HTR fuel qualification that we did.

6 So, this was for a commercial party who sent us five HTR 7 pebbles, graphite pebbles with TRISO fuels. And basically from there on we 8 assembled these fuels into the sample holder. In this particular case 9 graphite, which is then double contained, which is a condition for us for our 10 fuel irradiations, before we can put it in the HFR. So, these sample holders, 11 they are equipped with -- well, basically with any experimentation that you 12 want, which survives the radiation in the HFR. So, in this particular case, we 13 assembled these five pebbles in the containment with 48 thermocouples 14 dispersed throughout the sample holder to monitor the temperatures.

15 We have several gas handling facilities in the HFR, which 16 allows us to control the temperatures in these experiments, but also to monitor 17 the gas online. And in this particular case, we were looking at the online 18 release to birth ratio of fission gases from these pebbles. So, additional 19 instrumentation that we used was to look at the neutron fluence rates, so by 20 self-powered neutron detectors.

21 And we have neutron activation monitor sets, which we 22 retrieve after irradiation to have an accurate reconstruction of the local neutron 23 fluence in the experiments. So, by our experiment design, we were able to 24 have a very stable temperature throughout the experiment, and we have very

13 1 narrow uncertainties. In this particular case, we were able to keep the central 2 temperatures around 1050 degrees Centigrade, plus or minus 50. And we 3 can even, with material irradiation, we can even go slightly lower, and as well 4 as droplet irradiations because they're so much smaller. If you go to the next 5 slide?

6 So, one of the more general irradiations that we do are 7 droplets, which are small sections of fuel pins. We have these fuel pins that 8 we can load into again, double contained sample holders. Generally these 9 sample holders are sodium filled to have a proper heat dispersion from the 10 fuel pins. And they can be up to 700 millimeters, but normally the effective 11 height is about 500 millimeters, because beyond that the actual neutron flux -

12 - the actual flux gradient gets too steep, so it's like 500 millimeters active 13 experimental position.

14 So, depending on the fuel that you use, the application, if 15 you have a fast reactor fuel that you want to have tested, that you want to 16 tailor the fast to the thermal flux and without the faster thermal fission, we can 17 replace -- shrouds for spectrum tailoring, and we have numerous options for 18 instrumentation inside the sample holder to monitor temperatures, pressures, 19 or displacements.

20 And again, self-powered neutron detectors for fluence rates 21 locally, and the mounting sets I mentioned. So, the temperature control is 22 through a gas cap between the containment of these experiments, where we 23 can change the gas composition, and with that, the thermal conductivity of the 24 gas and steer the temperature to a target within 20 degrees Centigrade. So,

14 1 if we go to the next slide?

2 So, once you've achieved your irradiation target, we can 3 transfer the experiments to the hot salt facility on the same side, where we 4 can dismantle it and then proceed with any post irradiation examinations that 5 are desired. So, we can dismantle and move it to hot cells for example non-6 destructive testing. So, performance scanning and any current 7 measurements.

8 So, we have cell lined with flexible inner boxes, so basically 9 you can load a box with any instrumentation or equipment that you want for 10 your studies, and then carry out your post irradiation examinations. So, for 11 example the fuel dissolution studies we did in the past. And we have alpha 12 type hots aligned for further destructive analysis, for example microscopy or 13 scanning electron microscopy with EDS, WDS, and EDSD options. And so, 14 if we go to the next slide?

15 I won't name these all, but as I said, we have numerous 16 options for post irradiation examinations, and on the right hand side, you see 17 the options that we have basically for the fuels. Not all techniques are 18 available for fuels. So, we basically have the standard techniques that you 19 tend to do on irradiated fuels. And from next year on, it's envisioned to have 20 a high burst test setup ready. So, if you go to the next slide?

21 Just as a summary, so what we can do basically is just from 22 beginning to end, we can do whatever a customer wants. We can produce 23 oxide fuels in a radiological lab, and do all kinds of characterization on these.

24 Then for the design of an irradiation experiment, we have in-house, we have

15 1 teams of dedicated engineers to perform the nuclear, thermal mechanical, and 2 thermal hydraulic calculations, and we have on site, a mechanical workshop, 3 high profile mechanical workshop, which basically produces high quality 4 experiments. So, we are versatile in serving any customer, any nuclear 5 application.

6 And we have extensive options for instrumentation in the 7 high flux reactor, and we have extensive options for post irradiation 8 examinations. We also have logistics units to organize international transport 9 if that's desired, and also the waste handling, we can do. We have a disposal 10 international repository, so that's also a possibility. And if you go to the next 11 slide?

12 Just in closing, as I said, the HFR is a 60 year old reactor, 13 and it's envisioned to run into the 2030s, but after that, the follow-up reactor 14 has been defined, which is called the PALLAS reactor, and it's not known 15 exactly when it will be ready, but it's in mid-2030s. The site is being prepared 16 right now, so we are -- the design has been completed, and construction is 17 planned to begin in the coming years. Yeah, so, that's basically my 18 presentation, and thank you for your attention.

19 CHAIR HANSON: Thank you Mr. Van Til. I just would, as 20 we kind of go along here, we've got a number of other presentations to get 21 through this morning, so I just ask presenters to kind of be cognizant of the 22 time. Next we'll hear from Ms. Jennifer Wheeler, she's director of regulatory 23 affairs at TRISO-X.

24 MS. WHEELER: Good morning, thanks for letting us be

16 1 here today with you. So, TRISO-X is an applicant. I think one of the few on 2 this panel, but others are coming, for a 10 CFR 70 materials license, and you 3 can see in the first slide's picture, that our facility is going to be sited in Oak 4 Ridge, Tennessee on a 110-acre property. The processing facility in the 5 background is over 500,000 square feet with an attached office building in the 6 front.

7 The manufacturing process uses Category II special nuclear 8 material in the form of uranium oxide. We may use different enrichments 9 depending on what advanced reactor developers order, but our possession 10 limit will be up to less than 20 percent, so we'll be able to cover the whole 11 range. X-Energy's ARDP funding is actually being applied to both 12 development of the Xe-100 reactor, and the fuel facility that you see in the 13 picture here.

14 And Andy already covered some things about ARDP, so I 15 don't have to cover that again. We appreciate the funding, thank you. So, 16 tristructural isotropic based particle fuel products, or TRISO, can support a 17 variety of advanced reactors. For example, and I brought a couple of things 18 here, pebbles for Xe-100 reactor, these are all made of graphite.

19 Compacts for other types of reactors, they can be -- the 20 particles can be shaped into other shapes, not these, planks, and cylinders, 21 and other kinds of things depending on what the reactor developer wants.

22 So, of course pebble is our favorite, because that's for us, but we'll be happy 23 to make anything for anybody else as they may want it. The facility is being 24 designed for a throughput of 16 metric tons uranium per year when operating

17 1 at full capacity.

2 That equates to over 200 million pebbles produced per year 3 if that's the product that we're making at the time. And our business plan is 4 to be ready to start operations by the end of 2025. Next slide please.

5 I'll start with the bottom line up front on this slide. I'm really 6 happy to report that the TRISO license application was accepted for review by 7 the NRC staff on November 18. So, not that far back in time, just before 8 Thanksgiving. Interactions for 2022 began with an exemption request 9 submitted in February to allow submittal of our environmental report 10 separately from and after the remainder of the license application. This 11 request stemmed from an extensive site selection process with several sites 12 being considered before selection of the final site in Oak Ridge.

13 As a result, the preparation of the environmental report 14 tracked behind the remainder of the license application documents. We were 15 anxious to get started, so the staff worked very efficiently through the review 16 of that exemption request and approved that request in March. So, that 17 timing supported submittal of the license application in April, followed by the 18 environmental report submittal in September. So, as you can see on the 19 slide, steady progress was made between February and November, working 20 through the acceptance review steps. Next slide please.

21 So, previous licensing actions are some of the data points 22 that are used by applicants and licensees to predict NRC review schedules.

23 The acceptance review process did take longer than we anticipated when 24 compared to the four new enrichment facility applications that were accepted

18 1 between 2004 and 2009. But 13 years had passed by, things change, things 2 get updated, one of those things was the licensing handbook that had been in 3 place for quite some time was updated by the staff and replaced with the 4 Division instruction. And we think that part of our surprise of this was taking 5 a long time, was because acceptance review standards were updated, and 6 we should all be looking for means of continuous improvement.

7 But my point of saying this is that communication can't 8 happen too often in terms of what expectations the NRC staff has for what 9 applicants or licensees are submitting, and what level of detail is needed to 10 support reviews. We were -- typically some of the questions that we got in 11 the request for supplemental information letter that came out in August were 12 questions we would have seen in the past, during the technical review itself.

13 So, this will be -- this application is going to be an 14 opportunity for everybody to fine tune what we're doing on the applicant side, 15 on the NRC staff side, and looking for as many opportunities as we can find 16 to communicate early and often to minimize the potential for surprises on 17 either side, I think is going to be good for everybody. Next slide please.

18 So, TRISO is but one of several advanced reactor fuels 19 being explored, as you can -- evidenced by in part the slate of speakers today.

20 Next slide please.

21 And the market demand continues to grow, as more, and 22 more potential applications for use of advanced reactors are identified. Next 23 slide please.

24 So, in this rapidly changing environment, a predictable

19 1 licensing process is a key enabler for meeting both NRC metrics, and 2 applicant and licensee business plans. The existing NUREG-1520 toolbox 3 includes a number of review techniques, and tools that have been proven to 4 aid effective and efficient licensing reviews. Risk information from the 5 integrated safety analysis should be used as input to plan and prioritize what 6 needs to be inspected during construction and operational readiness reviews.

7 Next slide please.

8 If market demand does increase as predicted, more 9 applications will come after us. Whether from new applicants or existing 10 licensees expanding their capabilities. Each fuel facility may be unique due 11 to variations in the fuel types. So, use of lessons learned, improving 12 techniques from past reviews will help focus resources, improve predictability, 13 and reduce uncertainty for both NRC, and applicants or licensees.

14 Finally, at some point in the future, probably not now, 15 depending on the volume of work that comes, and when it comes, it may be 16 appropriate to revisit Division of Fuel Management staffing levels, and 17 structure to ensure timely reviews of advanced fuel applications. So, I realize 18 mine's a little bit different in that I didn't delve into the technology of TRISO, 19 but since we are an applicant, and our review is active, I thought you might 20 appreciate an update on our status, so thank you very much.

21 CHAIR HANSON: Thank you very much, Ms. Wheeler, for 22 your presentation. We'll go back to the internet, we'll hear from Dr. Christina 23 Back, who is Vice President at General Atomics. Dr. Back?

24 MS. BACK: Thank you, good morning. I really appreciate

20 1 the opportunity to present to the NRC here, and I'm very sorry I can't be there 2 in person, but GA is hosting a three-day meeting with the Department of 3 Energy here. So, I'll jump right into the slides here.

4 EM2 is an initial reactor that we proposed for a commercial 5 one-megawatt size, go to the next slide. But actually we are pursuing the fast 6 modular reactor, so there was a slight title change there relative to your 7 agenda. I'll be talking about the fast modular reactor, which actually is a 8 forerunner, and a rethink of nuclear reactor with helium gas coolant for the 9 distributed energy market. So, just as an overall philosophy, we believe this 10 technology is ready for the conceptual stage. We're in the first phase of the 11 pipeline of the advanced reactors, because we need a fast spectrum to use 12 the fuel more efficiently. We also use new materials for higher temperatures, 13 which allows us to look at the efficiencies and get higher efficiencies, as well 14 as take advantage of other aspects of the reactor design, which I'll get to in a 15 minute.

16 We use silicon carbide cladding for a higher temperature, 17 and it really comes back to the fact that you need your advanced reactors to 18 be safe. You need to be cost competitive, and you want to make sure you're 19 in the non-proliferation status with your fuel, and you want to generate as little 20 waste as possible. So, in that image you see in the upper left-hand side, we 21 use dry cooling, we have auxiliary processes. But you can see that the 22 footprint of the entire reactor, which is underground, as you see on the bottom 23 right-hand side, but the whole footprint of the reactor is much smaller because 24 we're using a direct Brayton Cycle. So, you can see the thermal power there

21 1 is 100 megawatts. The electrical output is 44 megawatts. The coolant there 2 I mentioned, helium, system pressure 7 megapascals. And the system 3 temperature, this is the helium temperature, 500 to 800 degrees Centigrade, 4 so that we can use that Brayton Cycle. So, it builds off work from the modular 5 high temperature gas-cooled reactors, and so we basically updated it, and the 6 amount of fuel that we use in total number of kilograms is about 20 percent of 7 what a usual pressurized water reactor is. So, if you could go to the next 8 slide?

9 We have a pre-licensing activity going on with the NRC, and 10 this just gives you a general timeline of where we are. As I said, we're doing 11 the initial pre-licensing, so it's the principal design criteria. So, we sent in 12 some documentation in March, and then in June/July timeframe, we submitted 13 the principal design criteria. So, we're in a very good place now, we got very 14 good feedback from the NRC. Basically, we're using a regulatory basis that 15 follows the Regulatory Guide 1.232. It also takes into account the usual 16 design criteria, plus the non-light water reactor criteria that has been 17 developed more recently, and also from the NEI documentation that helps 18 develop the technology-inclusive risk-informed performance-based process.

19 So, with both things, you can see that later in the year we'll 20 be submitting some documentation for review on the source term calculation, 21 the licensing basis events, and following what should look generally familiar 22 for an NRC process, I'll just call out a few things in particular for our reactor 23 design. Maybe you could go back to the previous slide for a moment?

24 The slight changes, which were not interpreted by the NRC

22 1 to be major changes, so we got actually very little requests for upgrading or 2 changing our submission, because of the differences. So, just going into a 3 little bit to give a sense of why an advanced reactor, and is not as deterministic 4 as a typical light water reactor, our reactor takes advantage of radiative cooling 5 because we're at such high temperature. So, for that kind of reason, words 6 like core coverage, where the coolant needs to make sure that it's covering 7 the fuel elements, that kind of language is not necessary because our passive 8 heat removal is really radiation from the silicon carbide uranium oxide fuels --

9 sorry, uranium oxide fuels inside a silicon carbide cladding, which goes as the 10 power of T4, so it's very effective at high temperature.

11 And the reactant coolant pressure boundary, which is 12 typically the language in the general design criteria becomes something more 13 broad, which is the reactor helium pressure boundary, because that's more 14 inclusive of the other structures that are needed in a helium-cooled system.

15 Then we go through the typical licensing activity, the basis. The accidents 16 basically for the loss of -- in our case, a turbine blade, a pre-cooler tube 17 rupture, pressurization loss, force cooling, subcriticality analyses, control rod 18 withdrawal accidents. So, those are all just very typical of a reactor, but in 19 our case we're looking at a fast reactor, small changes. Maybe I'll go to the 20 next slide now, which says accelerated fuel qualification.

21 The big difference here is that we are using new materials 22 to be able to take advantage of the higher temperatures, and the new 23 technologies that exist. So, I just want to put up this slide, and one more slide 24 after this to talk about how we're approaching that.

23 1 So, in general, accelerated fuel qualification is a 2 methodology to take advantage of the modeling and simulation that has really 3 come to the forefront in the last five to ten years, where multi scale modeling 4 can address on a more physics basis, the actual fuel performance and 5 behavior in accidents. So, we're bringing together, modeling, and simulation 6 with targeted experiments, which doesn't mean fewer just because we want 7 to do fewer, but really more specifically chosen experiments that are relevant 8 in the temperature and pressure regimes that are important.

9 So, the emphasis is on physics-based modeling, but it 10 doesn't change the fact that you need experiments to benchmark those, and 11 integral experiments to pull together all the separate effects and accelerated 12 experiments that may be used. So, if you look at the top arrow, typically it's 13 all empirical, so you have out of pile and in pile data, and you license your 14 fuel. And in the bottom arrow, you can see the arrow is shorter, that's to 15 represent that as we use more, and more physics basis for some of these 16 calculations to aid in the understanding of the fuel behavior, your uncertainty 17 actually goes down, your safety goes up, and ultimately you reduce the time 18 that you're needing for licensing of fuel.

19 You can see a couple papers there. One is an initial paper 20 on accelerator fuel qualification, talking about ways to use modeling in 21 simulation more intelligently with experiments, and then the NUREG that was 22 released recently. That is also along the same lines of figuring out how to 23 incorporate, especially for new materials, these processes. So, the last slide 24 I'll go through very quickly.

24 1 What I've tried to do here is to show you, in our thinking 2 through for the fuel test plan, we use both the accelerated testing and a 3 separate effects testing. In this case, a sub-integral test, and all of those 4 recognize the fact that we're having a long lifetime fuel, so it can go from 9 to 5 15 years. We have different boundaries that we calculate there, but the point 6 is the high burn-up needs you're needing to do an accelerated testing.

7 We're making use of the fast test approach that Idaho 8 National Lab is developing, and you can see we do calculations on the right-9 hand side for the fuel and the cladding, I can explain that more in detail. But 10 basically, you do have to look at what the test is actually going to see in 11 temperature and burn up, as well as the cladding. And you can't necessarily 12 meet both. But you make an intelligent choice, in our case we chose it to 13 meet the cladding. So, the orange dots are what the test will do, the blue dots 14 are the range that the experiment -- that the fuel is expected to go through in 15 terms of temperature and burn up. So, we'll meet that, we'll be able to justify 16 then and qualify the data in a faster way than if we were taking 30 years of 17 empirical data.

18 Separate effects tests is somewhat straightforward here, 19 when you think about the reactivity initiated accidents. So, we're trying to 20 mimic that in the treat facility, and then pulling those together with a sub 21 integral fuel test. Which again, we're in the pre-licensing phase, so this is 22 really to inform the fast modular reactor design.

23 So, I want to try to stay to my time, so I'm happy to answer 24 questions, and I appreciate the time to be able to present to you. Thank you.

25 1 CHAIR HANSON: Thank you Dr. Back. Next we'll hear 2 from Mr. James Vollmer, he's a Senior Manager for Nuclear Design at 3 TerraPower. Mr. Vollmer?

4 MR. VOLLMER: Thank you. Next slide please. So, since 5 the very beginning of TerraPower's history, we really realized fuel is the key 6 to advancing the technology that we need, specifically for our breed,and burn 7 designs that require very long lifetimes, and very high burn ups, and very high 8 DPAs on the fuel. Quickly after the traveling wave reactor efforts, we also 9 actually looked at the molten chloride fast reactor, and kind of pursuing --

10 better?

11 Okay. Been pursuing both reactor's designs in parallel, so 12 we've been very active in the fuel area, and actively engaging the NRC, as 13 well as part of it, and it's been very helpful for us. One key example is for the 14 SFR design or the metallic fuel design, we actually, through our regulatory 15 assistance grant from the DOE, we actually submitted white papers, and got 16 early review and engagement from the NRC. And that really helped shape 17 our plans as far as fuel qualification for the metallic fuel that we are leveraging 18 for the Natrium reactor as well. Next slide please.

19 So, this is just a quick overview showing what the metallic 20 fuel designs look like, and kind of the key thing I wanted to highlight on the left 21 panel, you see kind of pinned cross sections of the historic metallic fuel 22 designs used in EBR-II, as well as FFTF. There was a subset of metallic fuel 23 assemblies in FFTF as well. And you see just the cross section of how 24 closely our type one fuel mimics the historic designs as well, and that is

26 1 intentional because we are leveraging those historic databases to support it.

2 The bottom is actually our advanced fuel design, so that's where we want to 3 go as soon as possible, but we realized starting up a new reactor with an 4 advanced fuel is challenging enough using the historic designs.

5 We're going to go piece-wise, and go through an LTA 6 program to get to our advanced fuel design. On the right panel, you see kind 7 of the cross-section comparison to the fuel assemblies. The key things I 8 wanted to note is you see the FFTF design, look at the red fuel region 9 compared to the red fuel region in our Natrium type one fuel design. That 10 although our Natrium one fuel assembly is longer, the fuel region is actually 11 very similar in height, and that's one of the reasons we do consider these MFF, 12 metallic fuel assembles, for FFTF to be kind of our key database that we are 13 using for our operating experience. Next slide please.

14 So, this kind of shows our parallel fuel qualification 15 pathways. So, our type one fuel is to startup within our Natrium reactor, but 16 then we are trying to get to our type 1B advanced fuel as quickly as possible.

17 For the type one fuel, I mentioned the reliance on historic fuel data. So, we 18 are actually able to leverage some of the opportunities from Argonne National 19 Lab of qualifying that data from EBR-II, the metallic fuel data. So, we actually 20 are working in hand with them as part of our ARDP proposal.

21 And then in addition, I mentioned the metallic fuel pins from 22 FFTF really are very applicable to our type one fuel. There is very little PIE 23 done on those fuel pins, so we are pursuing additional PIE. Those pins have 24 been archived, and we are trying to fill in gaps with that.

27 1 Another key aspect is actually the transient testing of that, 2 that that was something that was the prism program, and the IFR programs 3 were shut down before those transient tests were performed, so we recognize 4 that gap, and we're pursuing that as well.

5 For the bottom side of it, for the advanced fuel, we really are 6 kind of filling in the gaps, relying on the advanced test reactor at Idaho National 7 Lab to get kind of fuel phenomena information, kind of separate effects, and 8 understanding gas release, other aspects of the fuel, is it behaving as we 9 expect? So, it is actually very comparable to the historic fuel from 10 performance with some key features and differences from that. We also will 11 be looking at kind of transient testing to fill gaps. And then I had mentioned 12 kind of a lead test assembly program and lead test pins. And the Natrium 13 reactor will be kind of the final qualification step before we consider that fuel 14 qualified. Next slide.

15 So, this is a high-level road map of our Natrium reactor 16 program development, just to show that we do kind of integral steps of 17 leveraging historic experience, as well as going to our initial plant, the Natrium 18 plant that is being built in Wyoming. And then through that, we'll go through 19 our lead test assembly programs to go to our advanced fuel design, to actually 20 get to more commercial plant designs that can deploy more broadly. Next 21 slide please.

22 Touching briefly on the molten chloride fast reactor 23 technology development road map, so they also received an ARDP award for 24 the risk reduction portion of it. The key aspects there is that molten chloride

28 1 reactor experiment shown. That really is kind of a critical effects test, if you 2 would, to address some of these key uncertainties about how these molten 3 fuels behave in particular the delayed neutron fraction, how that behaves 4 when it's going in, and out of the core, and how that impacts the overall reactor 5 performance.

6 And then also the integrated effects test, that's actually been 7 underway -- construction of that has been underway, and actually is starting 8 up soon in our Everett facility as well to look at more of the transient 9 performance of these molten fuels, of how they would behave during 10 transience. But again, the long-term road map for that as well to gradually 11 step up to commercial scale reactors. I believe that's it for me. Thank you.

12 CHAIR HANSON: Thank you, Mr. Vollmer, very much.

13 Next we'll hear from Dr. Rusty Towell, he's the director of the NEXT Lab at 14 Abilene Christian University. Dr. Towell?

15 DR. TOWELL: Thank you. I appreciate the opportunity to 16 come and share with you about what we're doing at Abilene Christian 17 University, about our molten salt research reactor, and the fuels that we need 18 to support that. Next slide please.

19 So, the Abilene Christian University is a private university in 20 the middle of the state of Texas. Our mission at ACU is to educate students 21 for Christian service and leadership throughout the world. The main campus 22 is in Abilene, Texas, and for the last five years, we've continued to grow in 23 size despite the pandemic and other challenges, we've increased in number.

24 But we're more excited about the quality, U.S. News, and World Report, and

29 1 many others have given us awards, and particularly relevant to this effort is 2 the focus on undergraduate teaching and research. Next slide please.

3 NEXT stands for Nuclear Energy Experimental Testing, and 4 the mission of NEXT Lab is to provide global solutions to the world's need for 5 energy, water, and medical isotopes by advancing the technology of molten 6 salt reactors while educating the future leaders in nuclear science, and 7 engineering. Shown in the image is the work force on this project at ACU; 60 8 students, and 30 faculty, and staff working together to advance the technical 9 readiness level of molten salt and to design and build this molten salt reactor.

10 We're not doing it alone though. Next slide please.

11 NEXT was started in 2016, started building salt loops and 12 working with analysis of salt, but in 2020 we formed the first-of-a-kind research 13 alliance between Abilene Christian University and three other R1 universities:

14 University of Texas, Texas A&M, and Georgia Institute of Technology all 15 joined our research alliance. The industry sponsor for all four universities is 16 Natura Resources. And so we have sponsored research agreements with 17 those that are forming this research and with the efforts across the research 18 alliance, we submitted our construction permit in August of this year, and it 19 was docketed last month, and we're expecting an 18 month review period.

20 And we're very, very excited, and appreciative of that tight time frame, 21 because we do have a goal to go critical in 2025. Next slide please.

22 The molten salt research reactor is heavily leveraging the 23 lessons learned from the molten salt reactor experiment at Oak Ridge in the 24 1960s. And so, a very quick description of our reactor, what's similar, and

30 1 what's different compared to the MSRE. In similar form, we're using uranium 2 tetrafluoride, the lithium fluoride, beryllium fluoride fuel bearing salt. A loop 3 design graphite moderated, have a drain tank that allows for safe and secure 4 shut down by draining the fuel, and the salt from the core region to a sub 5 critical shielded tank. It's all in a subterranean trench and designed for a 6 reactor lifetime that's less than what we typically think of for a reactor.

7 Where we differ, we try to make things differ where it 8 simplifies licensing and construction. So, we're using low enriched uranium 9 instead of high enriched uranium, we'll drop in power by almost an order of 10 magnitude to one megawatt thermal. Using stainless steel 316, instead of 11 some of the more exotic materials. No freeze valve, that's really one of the 12 more interesting design changes. Instead of a freeze valve, we just use 13 pneumatic pressure to keep the fuel bearing salt in the primary loop. Also, it 14 makes it easier to drain and shut down, and then of course other advances 15 over the last 50 years. But heavily leveraging the advances from MSRE in 16 our design. Next slide please.

17 The reactor is going to be put inside of the Science and 18 Engineering Research Center. And so the upper left is an architectural image 19 of this facility that's under construction. The real main feature in it is it has a 20 research bay with very high, 50-foot high walls, 40 ton crane on the top, and 21 a shielded trench in the bottom of it. 80 feet long, 25 feet deep, 15 feet wide 22 trench, and the bottom left image here is the construction of this facility, that 23 started earlier this year. And this image is from a couple months ago, so you 24 can still see the trench. Since that time, the tilt up walls have been raised

31 1 around it, and so you couldn't see that major feature in the way it is today.

2 This facility is scheduled to be finished in July of next year, and we're going to 3 take use of 10 CFR 50.10 that allows us to apply for a construction permit in 4 a pre-existing building, and this building will be pre-existing by the time our 5 construction permit is granted. Next slide please.

6 So, what are the fuel needs? Before we started this 7 project, we started dialogue with the Department of Energy, and said that this 8 is a university research reactor, and we would like to be part of the Research 9 Reactor Infrastructure Program. We need 500 kilograms of high assay low 10 enriched uranium in uranium tetrafluoride form, mixed in with FliBe salt to be 11 our fuel. And so, we got this programmatic letter of support from the 12 Department of Energy that said this research reactor would be part of the 13 University Research Reactor Infrastructure Program. Current dialogue is 14 continuing with what's the source material for this. It's a relatively small 15 amount, and we're able to accept some impurities, so some stocks that are 16 available to us are not useful to other vendors. But fuel qualification plan, 17 transport, final disposal are all things we're in continued discussion with 18 Department of Energy about partnering together, and how we're going to do 19 that. Next slide please.

20 We think that this university molten salt research reactor is 21 going to be very, very useful to the nation, and even the world. It's the only 22 advanced university research reactor submitted under review with the NRC.

23 And so, we think it's going to be important to demonstrate licensure of this new 24 technology. It'll be important to DOE to have the data that comes from that

32 1 and vendors as we want to design future and larger commercial reactors, and 2 so we think that the data, and this experience will be useful to Department of 3 Energy, NRC, and vendors alike. Next slide please.

4 I'll just end with a slide that says thank you, and 5 acknowledges Natura Resources, the Department of Energy, and other 6 funders.

7 CHAIR HANSON: Thank you very much, Dr. Towell. And 8 last, but certainly not least, we'll hear from Dr. Ed Lyman from the Union of 9 Concerned Scientists. He's the Director of Nuclear Power Safety. Dr.

10 Lyman?

11 MR. LYMAN: Yes, good morning, Chairman Hanson and 12 Commissioners. As always, UCS appreciates the opportunity to present on 13 this important topic. May I have the next slide please?

14 So, introducing new fuels and new fuel cycles are going to 15 introduce new challenges in every aspect of the fuel cycle and reactor 16 operation. And this is a self-evident statement. But what I do want to 17 impress on the Commission, is I don't think that these challenges should be 18 underestimated. And we've heard about some of the gaps already in the 19 existing databases for the range of advanced reactors that have been 20 discussed, and those gaps really need to be taken seriously, and the NRC 21 needs to ensure that there'll be adequate safety margin when these facilities 22 are licensed and operated. Next slide please.

23 So, fuel qualifications needed not only for normal operation, 24 but also to establish the source terms and behavior for design basis and

33 1 severe accidents. Also other important data that might be necessary for 2 regulatory applications would be the impact of sabotage on fuels in reactors 3 in the fuel cycle. And also given some of the military applications that are 4 being pursued, the potential impact of a military attack on reactors and these 5 advanced fuels. And certainly compared to the current light water reactor fuel 6 database, these advanced reactor fuels do not have anywhere near the same 7 level of operating experience, the thousands of reactor years that have been 8 accumulated for light water reactor fuel development operation transience, 9 and even accidents. And that experience base provides a very solid 10 foundation for light water reactor fuel safety.

11 And that is what we don't have for many of these advanced 12 reactor designs. Fuel qualification is generally a lengthy, and a costly, and a 13 painstaking process that involves trial and error, and I am skeptical about 14 efforts to accelerate fuel qualifications, especially using modeling and 15 simulation when those modeling and simulation tools have not had sufficient 16 validation. So, when you're trying to use them to extrapolate beyond the fuel 17 performance envelopes that exist, you have to do that with caution, because 18 those tools need the data to be validated if they're going to be used for 19 extrapolation. Next slide please.

20 So, my -- we have a general concern about what's been 21 going on in recent years. That the NRC will be under undue pressure to 22 accelerate approvals by weakening its standards for demonstration of fuel 23 performance and for development of accident source terms. The applicants 24 are facing externally mandated, very aggressive, and arbitrary time-lines for

34 1 one thing, and also many of these fuel designs, at least the existing 2 experimental -- or the fuel's performance within existing experimental 3 experience do not support the kind of claims for efficiency and performance 4 that the vendors are promising.

5 And so, I'm afraid that that pressure to accelerate, or to use 6 new fuels to push the burn ups well beyond the existing experience base to 7 justify the claims that the vendors are making is another source of potentially 8 undue pressure to speed the process up. And if you look at the schedules 9 for deploying fuel facilities versus reactors, there just is not sufficient time for 10 qualification. Especially the production scale as fabricated fuel. And this is 11 particularly important for TRISO fuel, where the fuel qualification must involve 12 the actual factory fabricated fuel, because of the sensitivity of the performance 13 of the product to the production conditions. And the AGR program, while 14 impressive, expensive, and very well constructed, only provided data of very 15 limited applicability.

16 And, in fact, the program did not even meet a number of its 17 own goals. So, even the data that's available is not what was originally 18 expected as far as could be used for fuel qualification. That is, qualification 19 of a particular compact or fuel form, rather than just the TRISO particles. Also 20 with regard to metallic fuel, we heard about some of the gaps there. I 21 understand there's still -- there may be the possibility of different fabrication 22 processes from historical -- for instance using extruded fuel versus casks, and 23 that would raise questions about the validity of the existing database for 24 applying that information before qualifying the fuels for this reactor. And as

35 1 a result, because of these accelerated time-lines, the demonstration reactors 2 themselves will likely serve as de facto test reactors. And that raises 3 additional issues. Next slide please. Next slide.

4 This is just all of the claims that are being made by vendors 5 that rely on the performance (audio interference) The safety concerns 6 associated with accelerated fuel qualification without due diligence for taking 7 all the steps necessary is a particular concern because of the various 8 regulatory applications that the Commission has either approved, or is (audio 9 interference) credit for radionuclide retention as part of the desired functional 10 containment concept. Then that qualification becomes even more important, 11 and so when you're talking about (audio interference) is also essential for 12 routine operation, because of course, those fuels will as a matter of (audio 13 interference) in this context of the approved partition permits (audio 14 interference) cases would eventually require (audio interference) next slide 15 please.

16 CHAIR HANSON: Dr. Lyman, you may turn your video off, 17 the audio is breaking up a little bit.

18 MR. LYMAN: Next slide, please. Sorry. (Audio 19 interference) proprietary and there are often good reasons for that, but also 20 that has to be understood that that does create gaps in the public's 21 understanding of decisions that are based on some of this (audio interference) 22 a lot of this basic data, for example what the public will see when they look at 23 some of the publicly available documents. And I'm going to end here, 24 because I think I'm taking too long, and this technical problem is an issue. I'll

36 1 look forward to your questions, I apologize for any technical problems, thank 2 you.

3 CHAIR HANSON: No worries, it happens. It's a symptom 4 of the age these days. Thanks everyone for your presentations. We'll begin 5 questions this morning with Commissioner Wright.

6 COMMISSIONER WRIGHT: Thank you, Chair. And 7 thank you for your presentations today, this is a very interesting topic, a lot of 8 things going on, and Im very excited about the test reactor at Abilene 9 Christian, that's going to be -- looking forward to coming down, and seeing it 10 at some point too.

11 So, Mr. Griffith, I'll start with you. So, you highlighted the, I 12 guess significant government funding that's available to establish the whole 13 HALEU market. I understand it's early, but can you share maybe with us any 14 near-term successes, or maybe major obstacles, or obstacles that you're 15 facing right now?

16 MR. GRIFFITH: Sure, I'll start with the successes. As I 17 mentioned, we did award a contract for the startup and operation of the high 18 assay LEU demonstration at Piketon, Ohio. It will be able to produce 900kg 19 of freshly enriched high assay LEU, demonstrate U.S. technology on U.S. soil, 20 so we consider that a big win. The challenge is it's not a commercial scale, 21 and so it's expensive.

22 However, we will benefit from performance data from the 23 machines that are in operation there. In the other side of the country, Urenco, 24 they do have an application to go up to ten percent, which is a good step in

37 1 the right direction, I think. And so, that will set the stage for their role in 2 producing high assay LEU as well. So, I think this is good momentum.

3 We still have the chicken, and the egg. Until we can 4 incentivize a commercial scale production, and recognizing that there is a role 5 for government to get started, ultimately, it will need commercial contracts.

6 And so, we have a projection of what kind of HALEU demand would be 7 required in order for us to successfully meet our climate objectives of net zero 8 carbon on the electricity grid by 2035, and net zero total energy by 2050.

9 The ramp up of HALEU demand is significant from that 10 scenario that we analyzed, but it's not reality. It's just a scenario that is put 11 out there for consideration. The real test will be in both the X-Energy, and 12 Natrium activities that are underway. PacifiCorp is evaluating five more sites 13 for Natrium deployment. How that unfolds will be a key data point. X-Energy 14 has an agreement with Dow Chemical to establish another four pack to 15 support their operations. How that becomes a certainty, not just an 16 agreement will be another clear data point. And so, those kind of commercial 17 demand signals will be really important to take it just from getting started to 18 being fully operational, and establish the marketplace that's going to be 19 necessary.

20 And let me just add that diversity is going to be a real key to 21 that. Funding limitations to us, to get started might compromise establishing 22 diversity to start with. But ultimately to be successful, the diversity of supply 23 is going to be absolutely essential. Thanks.

24 COMMISSIONER WRIGHT: You're already involved with

38 1 the NRC, and we're engaged in a lot of things right now. Are there other 2 areas that maybe we're not engaged in right now, that we're going to be 3 looking to to be engaged with?

4 MR. GRIFFITH: I sure can't think of any. The NRC staff 5 has been great, we've tried to reach out as much as possible to stay engaged.

6 I think the discussion is healthy and respectful of each of our roles in the 7 process.

8 COMMISSIONER WRIGHT: Thank you so much. Hello 9 Ms. Wheeler, how are you? So, I want to go back to your comments about -

10 - and I guess the letter that you sent back in October. I guess -- because you 11 mentioned it here, there were surprises that maybe the acceptance review 12 standards had changed. Were you aware that those standards had changed, 13 or was that one of the surprises?

14 MS. WHEELER: I think loosely aware, and I think it just 15 highlights sometimes the -- it can be either the applicant's view, or the staff's 16 view of, I'm in this, and I don't think this is much different than what we've done 17 before. But the other party may see it quite differently. So, I think that was 18 part of it, it was not for lack of trying to communicate between the staff, and 19 our team. Just the practicality of how the acceptance review played out, and 20 the level of detail in the questions were different than we were expecting. We 21 worked through it, I'm glad, but --

22 COMMISSIONER WRIGHT: Yeah, well I know in this 23 whole process in this area, or in the development of Part 53 or anything else 24 that's going on, the communication part of it has been key. And to quote you,

39 1 you said you can't -- what did you say? You said can't happen too often, 2 right?

3 MS. WHEELER: No, it cannot.

4 COMMISSIONER WRIGHT: And I believe you cannot 5 over communicate as well, but I just wanted to be -- I wanted to kind of 6 understand a little bit more what your situation, or your concerns were. I 7 mean do you think that -- you seem to think, and what you're saying, that NRC 8 staff's been open, and they've taken your feedback, and they've tried to be 9 responsive.

10 MS. WHEELER: They have been open. I think they want 11 to communicate as much as we do. We all want to be on the same page, 12 that's how we're going to get through this review, and any that follow us. I 13 think that the gap of time between the last round of new applications and now, 14 licensee and applicant people have changed. NRC staff has changed. The 15 regulations haven't changed, but as you get any new people into any equation 16 with a new project, things are going to be looked at differently, and so again, 17 back to we can't communicate often and early enough to be sure that we're all 18 headed down the same road. Make sure that we're giving the information to 19 the staff that they need to do their job.

20 COMMISSIONER WRIGHT: Absolutely, thank you. And 21 let's go to staffing for a second. You mentioned later, as you closed really, 22 that at some point you thought revisiting the whole staffing levels in the 23 Division of Fuel Management would be needed. Can you maybe give me a 24 little bit of your opinion of what that new structure and staffing level might look

40 1 like?

2 MS. WHEELER: I think it is working now because we only 3 have one application in. And they've budgeted clearly for one big thing, some 4 medium-sized things, and then some routine stuff. So, I think it's really going 5 to depend on how many more applications come, and what time frame, how 6 quickly, and do they stack up on each other, as to whether the staffing levels 7 remain good. Or need to be looked at for improving that to be able to handle 8 more business from our side. So, you can't tell that today. Nobody wants to 9 overstaff too early, we get that. But I think all we're asking really as an 10 industry, is just let's keep an eye on it, and the better we can do from the 11 industry side to communicate early as to what our plans are, when we're 12 coming with applications only helps you and your staff plan for those efforts to 13 come.

14 COMMISSIONER WRIGHT: Yes, I totally agree with that 15 part, for sure. I'm going to come to you, Doctor. So, the whole next 16 generation of workers, and stuff in this sector is big, especially here at the 17 NRC, too, as regulators. Can you talk to me a little bit more about the 18 structure of the NEXT Lab, and how the students are supported, and how do 19 you deal with the knowledge management when the students graduate?

20 DR. TOWELL: Great question. With 60 students working 21 with us, that's a lot of turn over, and so we emphasize from day one that what 22 they do only lives beyond their exit if it's written down. So, if you don't write 23 it down, it doesn't exist. So, we have that sort of policy on day one, and that's 24 part of their coming in, and as they leave, we collect notebooks and make sure

41 1 that reports and data are archived correctly. Hopefully it's been done along 2 the way, but we double check it before they leave. So, there is an entry and 3 exit method. We've also -- we have a staff of 30, so when you look at the 4 ratio, it's sort of two to one, so it's pretty easy on the average for a mentor to 5 work with two students, and make sure that they both have a good, positive 6 experience, but also that their work is archived.

7 And so, one of the advantages of Abilene Christian 8 University is we have a very long history of working with undergraduate 9 students, and so that's something that we feel very comfortable with, and 10 proud of our work with them. Give them the opportunity, but also they're 11 energetic and they do a lot of productive, good work for us, so we enjoy that.

12 COMMISSIONER WRIGHT: Thank you. And Mr.

13 Vollmer, I'm going to end with you. So, given the level of engagement that 14 you've had with the NRC, and the staff in this area already, how would you 15 gauge the NRC staff's readiness to support the advanced fuel licensing, and 16 is the agency, in your opinion, well prepared, or do we have some additional 17 work we're going to need to do?

18 MR. VOLLMER: Thus far everything has been extremely 19 positive, and very good engagements, and we've been getting useful 20 information back and forth. So, currently I don't foresee a change. I think 21 we need to do a better job, we have our regulatory engagement plan, and are 22 keeping up to date, but just doing a better job on our end probably, planning 23 to make sure that you guys can align with that.

24 COMMISSIONER WRIGHT: Thank you. Thank you, Mr.

42 1 Chair.

2 CHAIR HANSON: Thank you, Commissioner Wright.

3 Commissioner Caputo?

4 COMMISSIONER CAPUTO: Good morning. Good 5 afternoon, Mr. Van Til, thank you all for coming today. Obviously this is a 6 fascinating topic, and we're quite a bit behind. I've got several questions, but 7 if I could just ask your patience, could you just please give me as concise an 8 answer as possible so we can squeeze these in without falling further behind?

9 I'd like to start with Dr. Back. Its great to see you again.

10 MS. BACK: Hello.

11 COMMISSIONER CAPUTO: You've been a popular 12 speaker, both here and in the Senate, and I thank you for contributing your 13 expertise over the years. I'm interested about the silicon carbide cladding.

14 How robust is the testing experience behind that cladding? And just in 15 particular, the ability to contain the fission products without migration.

16 MS. BACK: Yeah, totally agree with the importance of 17 measuring that and doing those actual tests. So, we have a series of out of 18 pile tests, meaning outside of the reactor, without neutrons in the irradiation.

19 Those have all shown good behavior, and what we expect from both our 20 manufacturer and fabrication techniques with respect to the modeling, and 21 simulation. But modeling, and simulation absolutely needs to be validated in 22 a neutron irradiation environment. So, we have a series of three raw mat sets 23 going into the ATR reactor at Idaho National Lab. We've already had testing 24 at Oak Ridge for small material properties and samples. So, hardness,

43 1 strength, those things have been tested. But with the ATR being delayed a 2 little bit, we don't have that data yet, but it is coming.

3 COMMISSIONER CAPUTO: Okay, thank you very much.

4 Mrs. Wheeler mentioned the potential for unique fuel facility applications 5 resulting from various designs and fuel types, and TRISO is a fuel type for 6 which there's been a great deal of testing over the years, as Mr. Griffith 7 mentioned. And we recently approved a topical report on generic TRISO.

8 The question I have for Mr. Griffith is, are vendors 9 developing specialized variations on TRISO that might fall outside the scope 10 of that report, and do you anticipate possibly needing additional irradiation 11 testing to support qualification of these more customized types of TRISO?

12 MR. GRIFFITH: I'm not aware of the developers or 13 vendors developing TRISO fuel outside those parameters. But I can take the 14 question back and get back to you and give you a more fulsome answer.

15 COMMISSIONER CAPUTO: That would be great. I think 16 it would be really good to know whether or not we've really fully enveloped 17 everything that vendors are intending within the scope of that topical report.

18 Mrs. Wheeler and Mr. Vollmer, a question for you. So, as you are engaging 19 either in pre-application space or now in application space with the staff, how 20 important do you think it is to have in-person meetings when you're dealing 21 with some of the more complicated issues arising with these technologies?

22 MS. WHEELER: I'll go first if that's okay. I think it's 23 extremely important. Back in the 2000s, when a lot of licensing actions were 24 going on, virtual meetings weren't a thing. So, you met in person, sometimes

44 1 you had phone calls, or you didn't meet. So, I'm a big proponent of meeting 2 in-person. We actually just did a process overview briefing with Region II 3 inspection staff.

4 We went in person, now we have an advantage, we're only 5 three hours away, but we're going to do the same thing for the headquarters 6 review team in January, and we're coming in person because I think that the 7 face-to-face offerings to be able to ask questions, give answers just is -- it 8 works better in-person where you can. I realize that there are some cases 9 where maybe it's not practical, or maybe you need to do it too often, and 10 coming every day isn't the thing to do. But where possible, we're definitely 11 very supportive of in person meetings.

12 COMMISSIONER CAPUTO: Mr. Vollmer?

13 MR. VOLLMER: I definitely agree that in person is very 14 helpful. It has been nice actually having the option of remote as well, 15 because at some topics, you do get early engagement on those that may not 16 be worth a full trip out to discuss. So, it has been nice having the option of 17 both. But I do agree, especially the bigger topics, in-person is useful.

18 COMMISSIONER CAPUTO: Okay. Mr. Van Til?

19 MR. VAN TIL: Yes.

20 COMMISSIONER CAPUTO: You have a very impressive 21 facility with the high flux reactor and all the post irradiation capabilities. With 22 the closure of Halden, I would imagine your facility has gotten pretty popular.

23 Is there still availability for additional experiments and to be able to schedule 24 time in your reactor, or are you fully subscribed for some period of time?

45 1 What's the ability for people to still be able to sign up and utilize your facility 2 over the next few years?

3 MR. VAN TIL: Well, you are correct that with the closure of 4 Halden, interest in the HFR has intensified. But yeah, we expect to run 5 approximately for at least ten more years, and the availability of the core of 6 course we have, the planning has become tighter, but it also depends a lot on 7 the type of experiment that you want to do.

8 So, for example the role with the high fast flux, which is 9 typically used for material irradiations, it would be hard to get a position in the 10 coming period, I would say in a few years there is room. For the lower flux 11 positions, where you typically do the fuel irradiation qualifications there is more 12 space, because we have more experimental facilities available.

13 We also -- within the available core positions, we have 14 irradiation facilities which can hold three, or four sample holders. So, we can 15 make space in that sense.

16 COMMISSIONER CAPUTO: Thank you very much. It 17 sounds like a fascinating facility. I certainly, at this point, hope to visit at some 18 point in the future, because I'd love to learn a lot more about what you folks 19 can do.

20 Mr. Griffith, one more question for you. You talked about 21 the Inflation Reduction Act and the HALEU funding, and the activities that 22 you're going to be funding with that. Where do you see within those activities, 23 where do you see the greatest potential for schedule risk that would perhaps 24 threaten the availability of HALEU by '26?

46 1 MR. GRIFFITH: Thank you for the question, 2 Commissioner. I think that the current situation with Russia's unprovoked 3 aggression in Ukraine has put a lot of uncertainty in the enrichment market, 4 up to five percent. Clearly that has potential for impacts on our existing fleet.

5 Recognizing that all high assay LEU will depend on feed material up to five 6 percent, at least. And so, that's a dynamic that's going to be challenging to 7 navigate given on one hand we need to fuel the future. On the other hand, 8 we also need to fuel our current fleet. And so, that's going to be a challenging 9 dynamic.

10 Recognizing that while we don't have funding to do that, 11 we've certainly had some thoughts on replacing Russian supply, because our 12 existing fleet relies on about 20 percent of supply from Russia annually. And 13 that's governed by the Russian suspension agreement, managed by the 14 Department of Commerce. We'd like to wean ourselves of that, and we'd like 15 to add capacity on U.S. soil to fuel both our existing fleet, as well as prepare 16 for a sustainable commercial supply of high assay LEU. So, I think that's 17 probably the biggest challenge there, and it does --

18 COMMISSIONER CAPUTO: What challenges do you see 19 in making that happen and finding those alternatives, or getting those 20 alternatives licensed and capable of actually producing?

21 MR. GRIFFITH: I don't see many challenges in the 22 regulatory space. I think that the path that has been charted by the 23 demonstration in Piketon has certainly primed the pump if you will, for that 24 technology there. And I think the efforts that Urenco is taking to enrich up to

47 1 ten percent at their facility is helping to pave the way as well. I think the 2 biggest challenge is funding. Can we get the capacity for both HALEU, and 3 LEU replacement in a time frame that will meet our needs, and wean ourselves 4 off of unreliable partners?

5 COMMISSIONER CAPUTO: Thank you. Thank you, Mr.

6 Chair.

7 CHAIR HANSON: Thank you, Commissioner Caputo.

8 Commissioner Crowell?

9 COMMISSIONER CROWELL: Thank you, and thank you 10 all for being here today. I'm going to pick up kind of right where 11 Commissioner Caputo left off with Mr. Griffith and HALEU. You referenced, 12 and I read in the news recently, the announcement of the DOE-led consortium 13 on HALEU availability. What role do you envision for the NRC playing in that 14 consortium?

15 MR. GRIFFITH: Thank you for the question. So, the 16 legislation, the Energy Act of 2020, Section 2001 assigned the Secretary the 17 responsibility of establishing a consortium. And it's essentially organizations 18 that play a role in potentially HALEU supply or its use. From a regulatory 19 perspective, I don't see a direct role for NRC; perhaps as an observer. But 20 the specific things that are articulated in the legislation are to inform the 21 department, provide input to the department on standing up that capacity, 22 including cost recovery schedule. And so I don't see a big regulatory space, 23 but certainly from an awareness standpoint, as an observer to the inputs that 24 we receive, and your consideration of those inputs from your perspective. I

48 1 think that would be a constructive role.

2 We have been approached by other offices in the 3 department, and I imagine other agencies expressing what role could they 4 play, for example State Department. We want to keep the door open and be 5 as inclusive as possible. However, we don't want to dilute, if you will, that 6 input from what I understand to be industry input to the department on 7 solutions going forward.

8 COMMISSIONER CROWELL: Just I ask because I know 9 the legislation references government organizations participating in it, and I'm 10 curious which types of government organizations, be it regulatory, NRC policy, 11 State, whichever. So, I just want to make sure we're leveraging the 12 opportunity if it's there, and not missing the opportunity.

13 MR. GRIFFITH: And the door is always open. We don't 14 need consortium for our dialogue.

15 COMMISSIONER CROWELL: If we wrote to ask to join, 16 I'm sure the response would be positive.

17 MR. GRIFFITH: Yeah.

18 COMMISSIONER CROWELL: You referenced earlier, the 19 concern about HALEU availability through 2035 in reference to our climate 20 goals. What is the projected HALEU supply needed through 2025?

21 MR. GRIFFITH: Great question. So, our -- based on the 22 clear demand by the two-way RDB demos that are 50/50 cost shared, the 23 estimate is about 40 metric tons through 2030. Given all the fuel 24 developmental work and qualification experiments, you could add easily

49 1 another metric ton or two. But that's fairly minor. Depending on how quickly 2 the commercial activities could materialize before that time frame, it could 3 easily double by 2032-, 2033-, or 4-time frame. The legislation has the 4 program sun setting in 2034, or before. So, our preference would be to exit 5 before, if possible, recognizing that would depend on those market dynamics 6 being established.

7 COMMISSIONER CROWELL: I think the market dynamics 8 and diversification, which you mentioned previously, are critical. Because I'm 9 not great at math, but you could run multiple cascades full-time all year, and 10 you're still going to come up short on 40 plus metric tons. And so, I'm a little 11 bit concerned about how this all matches up in terms of commercialization of 12 new reactors, availability of fuel, and bending the carbon curve, which is 13 critically important that we get to that. That's why we're all here, trying to 14 advance these technologies.

15 With that kind of in mind, Ms. Wheeler I was going to ask 16 you, you referenced that now that your application has been accepted, it's 17 going to be about a 30-month review period, and I won't comment on whether 18 that's too long, or too short, or what have you. But how does it match up with 19 prospective off takes for your fuel for advanced reactors who hope to use your 20 fuel? Are they going to be ready before, are you going to be -- how does the 21 timeline match up?

22 MS. WHEELER: That timing actually fits right in with our 23 business plan at this time. Even if we just talk about the Xe-100s, and them 24 trying to be ready to receive fuel, so that they can start up in the 2027-

50 1 timeframe. Finishing the NRC's licensing review by middle of '25, and then 2 we'll follow that by physical inspections of things that we have ready, so that 3 hopefully we gain agreement that we can turn the factory on by the end of '25.

4 That timing fits right in. I will say there's not a lot of margin on our side for 5 getting our part of the project done. I think that the 30-month review period, 6 assuming we deliver good deliverable products to the staff for review, I think 7 that's reasonable, and is actually in line with most of the new applications that 8 were reviewed back in the 2004 to '9 time frame. So, even though this is a 9 different project, different technology, it's not enrichment, the timeline lines up 10 from both a business perspective, and the efforts that will be needed for the 11 licensing review.

12 COMMISSIONER CROWELL: I agree, there's little, if no 13 room for slippage of these timelines.

14 MS. WHEELER: Yes, on anybody's part.

15 COMMISSIONER CROWELL: Yeah, on anybody's part, 16 which is why the work force issues are critically important. NRC being 17 prepared to, knowing how many applications are going to come in, and when, 18 and being prepared to respond to those, and with the overhang of climate 19 change looking at us, we really can't afford any slippage if nuclear is going to 20 be a part of that solution. That being said, we've got to do it safely.

21 And Dr. Lyman, if you're still online, that leads me to you. I 22 know your presentation was broken up a little bit, but I share your concerns 23 about safety and protection of public health, environment, preserving, and 24 building public trust in the process of current and new nuclear technologies.

51 1 Given your presentation got a little broken up, I just want to 2 give you an opportunity to articulate your concerns about those public health 3 safety and environmental, and public trust issues, and how we can do a better 4 job to make sure we're meeting that standard.

5 MR. LYMAN: Thanks. I'm not sure what you heard, and 6 what you didn't unfortunately, but my main point is that qualification of these 7 fuels is an essential component of safety, and that the regulatory processes 8 that are being pursued for advanced reactors may make those even more 9 important. For instance, functional containment concepts that would put 10 more reliance on the fuel itself, like TRISO.

11 So, the concern is that trying to short-circuit the fuel 12 qualification processes may compromise safety if there's an undue push to 13 meet these timelines, which I think are artificially imposed, for instance, the 14 Advanced Reactor Demonstration Program timelines. Especially given that 15 the unavailability of HALEU is probably going to delay these demonstrations 16 anyway.

17 So, again, I would urge the Commission to make sure that 18 they did not accept accelerated fuel qualification programs if that would 19 potentially reduce safety margin, not give enough information to actually 20 validate the processes that require, for instance, mechanistic source term 21 characterization.

22 COMMISSIONER CROWELL: Okay. Just quickly with 23 the time I have remaining, do you feel like your organization and other 24 stakeholders have had an adequate opportunity to participate in the regulatory

52 1 process via the NRC?

2 MR. LYMAN: Well, yes, certainly in some instances, for 3 instance in rulemaking development of Part 53. But the other point I was 4 trying to make is when it comes to details of the fuel qualification, because so 5 much of that data is proprietary, that makes it a little harder for the public to 6 meaningfully have input.

7 And there's certainly some case to be made for excluding 8 some data as proprietary, but maybe that line needs to be adjusted, especially 9 when again, the fuel performance takes on increased emphasis in safety, and 10 especially since so much of that fuel qualification work was done with public 11 money and government facilities, the issue of what's a trade secret and what 12 should be proprietary may be a little less clear.

13 COMMISSIONER CROWELL: Thank you for that. I 14 agree that finding that right balance to strike to maintain and build public trust 15 is important. Thank you, Mr. Chairman.

16 CHAIR HANSON: Thank you, Commissioner Crowell. As 17 usual, I'll pick up on a topic that you introduced. I wanted to kind of put this 18 question to Mr. Griffith, Dr. Back, and you Dr. Lyman, really about kind of 19 accelerated fuel qualification. And I think the use of physics-based modeling 20 and simulation tools are really important. The Department of Energy, and 21 others have made a lot of progress on this in the last 15 or 20 years.

22 And yet it's important that those models be underpinned and 23 validated with empirical data. And so this question is kind of deliberately, it 24 touches on a gray area, right? But I would like to get each of your kind of

53 1 perspectives on this issue of how much empirical data is enough? What's 2 the right amount for not just accelerated fuel qualification, but maybe fuel 3 qualification writ large. And I understand that it's incumbent on kind of the 4 NRC to strike that balance or figure out where that line is. But I am interested 5 in hearing from each of you about how much is enough in this area to kind of 6 ensure the safety and performance in a variety of conditions for these types 7 of advanced fuels.

8 Mr. Griffith, you're sitting in front of me, so maybe you can 9 go first, and we can hear from Dr. Back and Dr. Lyman.

10 MR. GRIFFITH: Thanks, great question. And to be frank, 11 the objective of accelerated fuel qualification is not to shortcut anything. It's 12 to be more predictive, better predictive, so that when youre modeling, and 13 your multi-physics, multi-scale simulations point to a solution, you have to 14 validate it. So, it still requires that empirical data to validate the results of the 15 modeling in the conditions that were analyzed.

16 And then once you do that, it's not like one data point is 17 sufficient. You need to do some sensitivity analysis and sensitivity testing to 18 test the boundaries, and the limitations as well. So, I don't think there's any 19 textbook answer per se. I think the LIFT program that we're proposing helps 20 answer that question more comprehensively and ultimately, it's just that you 21 still need to validate what the computers are telling you.

22 CHAIR HANSON: Okay, thank you. Dr. Back?

23 MS. BACK: Yeah, so, okay, I'm on here. I'd like to follow-24 up with what was said already. We are not trying to accelerate to avoid

54 1 safety, right? And I think maybe it might help to think of it in two aspects.

2 There is developing models, and simulations that means taking advantage in 3 the last ten years, where there is super computers, there are new algorithms, 4 new test methods on the experimental side to bring together.

5 That is to develop the computational capability, that's 6 something that NEAMS is doing very well, as an example for uranium oxide, 7 which is the most well developed, because there is a lot of data to compare 8 against. You can do test cases, and you can look at the regime, and how 9 well it's described over a certain temperature range, for instance. Even when 10 you have that model for your particular fuel, you will still need to go, and 11 validate it with an integral test.

12 And the idea of the accelerated fuel qualification is that you 13 learn and identify those parts which are important to the sensitivity. If you 14 change the temperature and it doesn't really materially affect the performance, 15 and you can validate that over a temperature range by taking data at the low 16 boundary and the high boundary, and you understand that there is no change 17 in the physics basis.

18 Then maybe you can take just one more data point in 19 between to validate that you have a consistent performance that is understood 20 by the physics-basis in the code. So, it's very hard to give a quantitative 21 number to say you need ten points. But it's a methodology where the model 22 has to be written, described, checked out for all its various computational 23 algorithms, and so on.

24 You might describe a physics phenomena, and have it

55 1 calculated wrong. So, you get rid of that part first, that's validating a model, 2 but then you apply it. So, for every fuel, like for our fuel, we're using uranium 3 oxide and silicon carbide in the fast modular reactor. We have a series of 4 tests, which are right now in the pre-licensing state to identify those 5 boundaries. So, that when we do the integral test for actually licensing data, 6 we need to get the data that the NRC deems important for the safety case, 7 and that will be an iteration with the Commission and the people at the NRC 8 involved with our licensing application. And we go forward from there. So, I 9 think it's -- in the case of uranium oxide, it's well-developed. In the case of 10 ceramic fuels like uranium carbide that can build on uranium oxide, you have 11 to show that, and then actually test it on the fuel. So, it's very difficult to give 12 a specific number. I think it's really methodology that we're talking about.

13 CHAIR HANSON: That's okay, I didn't need a specific 14 number necessarily, I'm just kind of interested in the perspectives on that 15 question. Dr. Lyman?

16 MR. LYMAN: Yeah, I would just add I think it's very 17 technology-specific, where that line is drawn. But just to have a healthy 18 respect for uncertainty and the black art of fuel qualification, and all the things 19 are not known even with regard to TRISO, so it's clearly of all the advanced 20 reactor fuels, it probably has the most experience in development and 21 operation. Yet there still seems to be a lot of fundamental things that aren't 22 known, still surprises occur, and if you look at what happened in the AGR 23 program, you just see how glitches come up, and how difficult those 24 experiments are, how hard they are to interpret. And so it's just not easy, and

56 1 so it makes me nervous to think of possibly not respecting that uncertainty, or 2 trying to push ahead without understanding where you need to set the margin 3 to be comfortable and maintain safety.

4 CHAIR HANSON: Thank you. Mr. Griffith?

5 MR. GRIFFITH: Yeah, if I could just follow up with a 6 shameless plug for the Versatile Test Reactor. We've been unsuccessful in 7 getting sufficient funding to get that up and running. However, that would be 8 a test capability that would be invaluable in the 2030s to evolve the fuel, and 9 to provide the answer you're looking for on accelerated fuel and material 10 testing with fast neutrons.

11 CHAIR HANSON: Thank you. Mr. Vollmer, it occurred to 12 me while the others were talking, that you might have some perspective on 13 this, or thoughts you might like to share.

14 MR. VOLLMER: Just a few quick thoughts. I guess in 15 general we've struggled also, because it is -- internally it has a comfort level 16 of how much data is good enough, but we really have kind of, with our lead 17 fuel performance model, at least found a way to propagate uncertainties 18 through our full analysis. So, we can basically predict what's the probability 19 of a fuel pin exceeding this limit, or whatnot.

20 So, really our role is quantify the uncertainty for all the 21 experimental we have, and make sure that uncertainty carries through our 22 simulations as well. So, that's been kind of the balancing act we've found 23 there. But definitely all of our models are built on data, and we have a good 24 database to back those up.

57 1 CHAIR HANSON: Thank you. Thank you all very much, I 2 recognize the importance of experimental facilities like Mr. Van Til's in the 3 Netherlands, and TREAT, and other key things, and actually kind of moving 4 us forward, and being able to ensure the safety of these new technologies, so 5 thanks for that very much. I'll hand it over to Commissioner Baran.

6 COMMISSIONER BARAN: Thanks. Well, I'll thank you 7 all for being here and for sharing your thoughts. There's a lot of exciting work 8 going on in this area.

9 Andy, I had a couple questions to ask you to start with.

10 One of your slides that was talking about the Inflation Reduction Act, and kind 11 of where the HALEU funding was going to be used talked about, or noted the 12 need for additional criticality benchmark data for HALEU. Can you tell us 13 more about the work DOE and others are doing there, and how that's coming 14 along?

15 MR. GRIFFITH: Sure. I think the benchmark data that we 16 have today is sufficient. I think that the big potential that that can provide to 17 us is it can remove some of the uncertainty, some of the conservatism for 18 some of the data that we have. And from a starting point, nothing 19 materialized to us before we had this funding that was right for addressing.

20 However, now with that funding, it provides us some 21 resources, that if there is some net benefit from transportation storage 22 standards that we can achieve with a little sharper look in some specific areas, 23 we're hoping to explore those. And so, I think it's going to be very interesting 24 to see what kind of responses we get when we solicit those.

58 1 COMMISSIONER BARAN: Okay, and you actually 2 touched on another question I was going to ask you on that same slide. One 3 of the other issues is new transportation packages for HALEU. How are the 4 design and development efforts there coming along?

5 MR. GRIFFITH: So, as I understand it, there is at least one 6 current package that's in the process for each UF6, and for oxide 7 transportation that are looking to amend their existing certificates of 8 compliance, and that's great. That didn't take any funding from us, so that's 9 always a good thing that industry is taking action to address the needs of the 10 future. Because we've got more -- we do have more demands than we do 11 funding.

12 However, it does, again, it allows more of the existing 13 players to look at their packages and explore revised designs that can meet 14 the needs of the future, and that would provide diversity of transport packages.

15 So, again, diversity of supply is, I think going to be really important to move 16 forward.

17 COMMISSIONER BARAN: Okay, great, thanks. This is 18 kind of a broad question and anyone can weigh in. It builds a little bit off of 19 Commissioner Caputo's earlier question, which is just kind of a big picture as 20 you're thinking about challenges for developing and licensing advanced 21 reactor fuels. Are there any challenges you're looking at, and thinking right 22 now NRC really needs to be doing more on any of those challenges? I know 23 that's kind of a big question, but are there things that are kind of keeping you 24 up at night, and you're thinking there's a role for NRC on that challenge? And

59 1 it's okay if the answer is no. That would be a little surprising, but nice to hear.

2 MS. WHEELER: Well, I think maybe two, three years ago 3 the thought was security and material control and accountability were going to 4 be big challenges for Category II materials. While work does need to be done 5 there, and some has been accomplished; there's been an updated NUREG 6 issued for Category II material MC&A, security is being handled more on a 7 site-specific basis, which I think is appropriate. Especially since every facility 8 is not the same, every site is not the same. I think those are actually working.

9 So, at this point sitting in the applicant's chair, knowing that 10 I have documents in for eight or ten different required elements, including the 11 two that were thought to be challenging looking forward from a few years ago, 12 I think we're going to do okay. I think that working through the integrated 13 safety analysis, while the methods are no different than anyone else is using, 14 just understanding the hazards of my process versus his process, versus 15 somebody else's process, that's going to be something we have to work 16 through each and every time you get an application. So, the better we get at 17 that, I think, and irrespective of which staff persons are filling the roles, I think 18 we're going to see a lot of gains from that. But I think really, we're doing okay.

19 COMMISSIONER BARAN: Good. And Dr. Back, did you 20 have something you wanted to add?

21 MS. BACK: Yes, I did. I would like to just bring up the 22 opportunity to talk about moving into a modernized nuclear industry, which 23 has a diversity of reactors with different coolants. I see a challenge of, you 24 know, you are the NRC. We have had light water reactors, and I see as my

60 1 job, informing the NRC about our new technologies, and engaging you in 2 discussion, and figuring out what will be the necessary safety basis for this 3 case. But it is a situation where the technology, and the information about 4 that technology is not very easy to -- there's no real mechanism for the NRC 5 to bring in new technologies, and learnings.

6 So, for instance the research office, when you get an 7 application for a new reactor, that's when they engage. But there is no ability 8 of the NRC to proactively kind of learn about some of these technologies.

9 And some mechanism for that is also where understanding how to bring in 10 modeling and simulation, which is used in pretty much every other industry 11 does not mean it's less safe. We all, as a community, need to figure out how 12 to find the balance. I don't think it's just the NRC, it's all of us, to find the 13 balance to ensure its safety. But that is over and above what the NRC has 14 customarily done for light water reactors. Because it's not a water coolant, 15 and that's pretty much true for any advanced reactor. Other reactors have 16 more data, historically from the 60s. I would argue that data that you took 17 today can be more sophisticated, higher resolution, higher fidelity, and so on.

18 So, data from the 60s is not necessarily the same as the data for today.

19 But if we have to take 30 years of data to qualify any new 20 fuel, or any new material, that's obviously a challenge for the whole industry 21 in the United States. So, there needs to be some mechanism to continually 22 keep the NRC involved in the technology developments and go forward as 23 efficiently as possible. Thanks.

24 COMMISSIONER BARAN: Great, well thank you for that.

61 1 And I think on the next panel, we'll hear a little bit more about our Office of 2 Research and what they're doing in this area.

3 Ed, let me ask you, your slides mention that you served on 4 the National Academies Panel that looked at different fuel cycles and 5 technology options. And your slides flagged a few of those findings. Are 6 there any other findings of that study that you think NRC should focus on in 7 particular?

8 MR. LYMAN: Yes, I mean while there weren't too many 9 findings that addressed directly NRC activities, but I think overall, and I don't 10 have the whole list in front of me, so I don't want to speak out of pocket, but 11 focus on the particular need -- well, waste. One of the aspects of the study 12 that we were asked to consider was advanced reactor wastes. And that's 13 certainly an issue where there are going to be gaps that you're going to need 14 to fill in, both for management of different types of wastes, both with regard to 15 enrichment levels, chemical, and physical properties, and fission products.

16 So, that's certainly something where there's going to be more attention.

17 One of the things the committee noted, and again I'm 18 paraphrasing here was that the vendors largely are not putting so much 19 attention into waste issues as other aspects of reactor design. And that's 20 simply because there isn't much of a forcing function from anyone to address 21 those issues. Of course, dealing of waste has always been the can that's 22 been kicked down the road, and the committee believes that that's not 23 appropriate, that those waste issues need to be considered in a more 24 integrated fashion at the very beginning of each product.

62 1 COMMISSIONER BARAN: Okay, thanks Ed, and we'll 2 give Andy the last word, and that'll wrap up the panel.

3 MR. GRIFFITH: Thank you. Yeah, I would just like to add 4 that kicking the can down the road, we don't quite think that's an option, that 5 we do have to consider that as we make decisions today as part of the 6 evaluation process for the applications we received under the Advanced 7 Reactor Demonstration Program funding opportunity announcement. The 8 spent fuel management concepts, they had to be -- their approach had to be 9 submitted and evaluated as part of the process, so it wasn't something that 10 was not considered.

11 But I also want to point out that we just recently released a 12 study through Argonne national laboratory that my office supported, that 13 concluded that essentially you can't -- it's difficult to broad brush a broad range 14 of technologies. That you really do have to look at the specifics, and the 15 context. And that if any conclusion we have today, it's just simply that the 16 advanced reactors that we're considering for the future have roughly the same 17 challenges that our existing light water reactor fleet has. And having spent 18 some time in the spent fuel and waste disposition area, it's not a technical 19 challenge. It's more of a societal challenge that we -- I think there are 20 solutions that can be pursued, it's just a matter of patience and persistence, 21 and openness to allow communities to consider and be part of the solution.

22 Thank you.

23 COMMISSIONER BARAN: Thanks everyone, appreciate 24 it.

63 1 CHAIR HANSON: Thank you, Commissioner Baran.

2 Thanks to all our presenters in this first panel. I think we had a really good 3 discussion, and we touched on a number of really important topics. Thank 4 you all again, we're going to take a short break. We're going to try and 5 convene here at like 11:02, or something with the staff panel, and thanks all 6 again.

7 (Whereupon, the above-entitled matter went off the record 8 at 10:58 a.m. and resumed at 11:04 a.m.)

9 CHAIR HANSON: All right. Thanks, everyone. We're 10 going to reconvene here for our staff panel. With that, I'll hand it over to our 11 Executive Director of Operations Dan Dorman.

12 MR. DORMAN: Thank you, Chair. Good morning, Chair 13 Hanson and Commissioners. It's a pleasure for staff to be here to provide an 14 update on the staff's efforts to prepare for the review of applications to use 15 advanced reactor fuel technologies and an overview of the work that is being 16 done across the agency.

17 To support the efficient and predictable review and 18 regulation of advanced reactors, staff across the agency are working 19 collaboratively to ensure that we are prepared to review in-reactor fuel 20 performance, address fuel cycle, transportation, and storage issues, 21 performing independent confirmatory calculations, develop guidance, and 22 lead research to enhance our knowledge of advanced reactor fuels.

23 You will hear today that we continue to successfully 24 implement the vision and strategy for advanced reactor by developing the

64 1 necessary knowledge, skills, and capacity, computer codes and tools, and 2 review guidance needed to perform reviews of advanced reactor fuels. We 3 are ready to review advanced reactor fuels to support near-term license 4 applications and are exploring ways to optimize our infrastructure to maintain 5 safety while enhancing efficiency, clarity, and reliability. Openness through 6 early and frequent engagement with stakeholders continues to be a large 7 contributor to our early successes in reviewing and approving advanced 8 reactor fuels. And we are proactively engaging with applicants across 9 business lines and technologies. You will also hear today that inter- and 10 intra-agency partnerships, as well as international partnerships have been 11 important to our success. Next slide, please.

12 So, on this panel you will hear from Rob Taylor, the Deputy 13 Office Director for New Reactors in the Office of Nuclear Reactor Regulation, 14 or NRR. Rob will provide you with a strategic overview of advanced reactor 15 fuels activities.

16 Christopher Van Wert, our Senior Advisor on Reactor Fuel 17 Systems for the Division of Safety Systems in NRR, will discuss our readiness 18 to review in-reactor fuel performance, our engagement and collaboration 19 efforts in this area, and our recent licensing activities.

20 Jason Piotter, Acting Branch Chief for the Nuclear Analysis 21 and Risk Assessment Branch in the Division of Fuel Management in the Office 22 of Nuclear Material Safety and Safeguards, or NMSS, will discuss our 23 preparedness and recent licensing activities in the areas of enrichment, 24 fabrication, transportation and storage of advanced reactor fuels.

65 1 Mirabelle Shoemaker, an International Safeguards Analyst 2 in NMSS's Division of Fuel Management, will discuss international safeguards 3 considerations as they relate to advanced nuclear fuels.

4 And, finally, Wendy Reed, a metallurgist in the Division of 5 Engineering in the Office of Nuclear Regulatory Research, will provide an 6 overview of research activities supporting the advanced reactor fuel cycle.

7 Next slide, please. And I'll turn the presentation over to Rob.

8 MR. TAYLOR: Thank you, Dan. Good morning, Chair and 9 Commissioners. The NRC and its predecessor, the Atomic Energy 10 Commission, have over 70 years of combined experience regulating the safe 11 use of nuclear fuels throughout the entire fuel cycle. And we built -- we will 12 build on this experience to regulate advanced fuels.

13 As the state of knowledge progresses, advanced reactor 14 designs with potentially enhanced safety and operational performance are 15 being developed. The NRC is leading initiatives to keep pace with this 16 evolution in the technology, and working with external stakeholders to 17 leverage and harmonize efforts to update or develop new tools and guidance.

18 Our activities are guided by the principles of good regulation as we execute 19 our regulatory activities to accomplish our safety mission. Next slide, please.

20 Advanced reactor fuels present unique opportunities and 21 challenges as the NRC transforms its traditional regulatory framework to be 22 agile and reliable in the licensing and oversight of these technologies. The 23 NRC provides regulatory oversight for the entire fuel cycle to ensure regulated 24 activities, provide reasonable assurance of adequate protection of public

66 1 health and safety. As such, we recognize that preparing for the next 2 generation of fuel technologies requires a collaborative effort across the 3 agency. To that end, we are working to realize the vision of making the safe 4 use of these technologies possible throughout the entire nuclear fuel cycle, 5 including enrichment, fuel fabrication, transportation, in-reactor requirements, 6 and spent fuel storage.

7 Traditional light-water reactor, or LWR, fuel consists of 8 uranium oxide fuel pellets enriched to 5 weight percent uranium 235, U-235, 9 within an array of zirconium-based cladding. The nuclear industry is 10 designing reactor fuels with operational conditions that differ significantly from 11 traditional LWR fuels in that they may take different forms and include new 12 materials. For example, advanced reactor designers are considering several 13 fuel types, including fuels based on tri-structural isotropic or TRISO particles, 14 metallic uranium alloys, and liquid salt fuels, which hold potential for advanced 15 safety. To achieve the staff's vision, our work in this area of advanced reactor 16 fuels encompasses enhancing technical readiness, optimizing regulatory 17 readiness, and leveraging communication to engage with stakeholders and 18 coordinate priorities. Next slide, please.

19 In the area of technical readiness, we are focused on 20 enhancing our analytical tools, preparing our talented staff, and bolstering our 21 scientific understanding. To ensure our tools are ready, we continue to 22 partner with the Office of Nuclear Regulatory Research to develop and update 23 fuel analysis codes for new technologies, to ensure readiness for the review 24 of applications involving advanced reactor fuels.

67 1 The NRC is also working collaboratively with the 2 Department of Energy, or DOE, to prepare our analytical capabilities to model 3 the performance of these new fuels during normal and accident conditions, to 4 understand the safety margins, and the performance capabilities. Staff is 5 actively engaged in research activities to enhance our knowledge of technical 6 considerations related to advanced fuel cycle, including fresh fuel 7 transportation and spent fuel management.

8 In addition to preparing our tools, we are also investing in 9 preparing our people. To prepare our talented staff we have ongoing efforts 10 to retain, develop, and recruit highly qualified staff with the specialized skill 11 sets needed to review advanced reactor fuels. We are taking advantage of 12 various recruitment opportunities to expand our applicant pool, and we are 13 proactively enhancing our agency knowledge of advanced reactor fuel topics 14 through development of Nuclepedia resources and technical seminars.

15 We are also providing relevant training on non-LWR fuel 16 concepts and their anticipated effects on the licensing of fuel cycle facilities, 17 transportation packages, and spent fuel storage systems. It is also a priority 18 for us to establish and document the technical knowledge needed to safely 19 regulate these advanced reactor concepts. We are continually engaged in 20 efforts to identify and enhance our understanding of these advanced reactor 21 fuels through the use of phenomenon identification and ranking tables, or 22 PIRTs, literature reviews, and independent assessments of advanced fuel 23 cycle technical considerations.

24 Staff has relied on early and frequent engagements with

68 1 DOE and other external stakeholders to leverage experimental data, for 2 validating confirmatory models, and computational tools to assess 3 uncertainties and risk. Next slide, please.

4 Regarding safely regulating these advanced reactor fuel 5 concepts, the current regulatory framework is adequate to review and regulate 6 near-term use of these fuel designs, including review of applications. And 7 we're working to optimize our regulatory readiness while using data and risk 8 insights to further improve our licensing reviews, while maintaining focus on 9 safety.

10 Moreover, the staff has established guidance for the staff 11 review of non-LWR fuels qualification. And there is ongoing rulemaking effort 12 for Part 53 that would establish a technology-inclusive regulatory framework 13 for licensing reactors that use advanced fuel designs using methods of 14 evaluation that are flexible and practical for application to a variety of reactor 15 technologies. Next slide, please.

16 Consistent with our principle of openness, we are 17 performing significant outreach to our stakeholders to enhance 18 communication and continue to sharpen our focus on the latest developments 19 in the area of advanced reactor fuels. By engaging with domestic and 20 international stakeholders we are ensuring a broad spectrum of input and 21 experience, and actively working to share insights. This engagement helps 22 strengthen our technical foundation for the review of advanced reactor fuel 23 technologies. We engage in early and frequent communication with 24 stakeholders to stay informed of the industry's priorities in order to prepare the

69 1 agency with the needed near-term and long-term regulatory tools.

2 We are extensively leveraging robust pre-application 3 engagements to ensure we understand the technologies that we'll be asked 4 to review, and that the information necessary to support our review is 5 understood and included in the applications that are submitted for NRC 6 review. We are also actively participating in domestic and international 7 conferences, NRC-sponsored meetings, industry group information 8 exchanges, and periodic meetings with the Department of Energy and 9 international groups, such as IAEA and NEA.

10 We frequently update and enhance our public website to 11 share information with the stakeholders and provide them with access to our 12 recent advanced reactor activities, including updates to our fuel guidance.

13 We also leverage various forums, including our periodic advanced reactor 14 stakeholder meetings, to encourage active participation from the industry, the 15 public, other federal and state agencies, and the inter-agency and 16 international partners to enhance regulatory information exchange.

17 In the rest of the staff's presentation today, you will hear 18 greater detail about how we are building on the NRC's prior experience, 19 adapting to the current state of knowledge, and continuing to communicate 20 and engage with industry and stakeholders to ensure we are postured to 21 regulate advanced reactor fuels. Next slide, please.

22 Thank you. And I will now turn the presentation over to 23 Chris.

24 MR. VAN WERT: Thank you, Rob. Good morning, Chair

70 1 and Commissioners. I am pleased to be here today to provide an update on 2 the readiness for our application review, engagement efforts, and recent 3 licensing activities related to advanced reactor fuels. Next slide, please.

4 The staff has been actively preparing for advanced reactor 5 fuel reviews by developing guidance for fuel qualification, developing tools for 6 evaluating fuel designs, and leveraging past experience with non-LWR 7 designs, such as Peach Bottom Unit 1, Fort St. Vrain, PRISM, and the Next 8 Generation Nuclear Plant.

9 In order to reduce regulatory reviews, scheduling 10 uncertainty, and to provide regulatory clarity in terms of fuel qualification, the 11 staff developed technology-neutral advanced reactor fuel qualification 12 guidance in NUREG-2246, and contracted with Oak Ridge National 13 Laboratory to develop similar molten salt reactor specific fuel qualification 14 guidance. These documents helped designers by providing a framework that 15 would support regulatory findings associated with nuclear fuel qualification.

16 In addition to providing fuel qualification guidance, NRR 17 partnered with research to develop evaluation tools to assist in advanced 18 reactor fuel licensing reviews by updating the NRC-funded fuel performance 19 code, FAST, which stands for Fuel Analysis under Steady-state and 20 Transients. The updated FAST program models fuel behavior for several 21 advanced fuel designs. Wendy Reed from Research will discuss this more 22 in depth during her presentation.

23 These updates will increase regulatory review efficiency by 24 focusing the staff's review on topics that are of greater safety significance.

71 1 The staff has set the stage by developing guidance for non-LWR fuel 2 qualification and approving a generic TRISO particle fuel qualification topical 3 report. However, an advanced reactor developer has an important role in 4 that it must demonstrate that its fuel design is qualified for the necessary 5 operational parameters.

6 For example, applicants need to demonstrate that the 7 behavior of their fuel is well understood and can be predicted for the foreseen 8 operational and transient conditions, with consideration for the role that the 9 fuel plays in the safety analysis for a particular reactor design, fuel testing and 10 the critical path in the development of advanced reactor designs. Therefore, 11 the staff strongly encourages early engagement on fuel testing plans to reduce 12 the risk of missing data that is necessary to support fuel qualification. By 13 using pre-application engagements and available guidance, developers can 14 seek early approval of fuel designs; for example, the submission of a topical 15 report for NRC staff review. This can lead to more predictable licensing 16 reviews for advanced reactor designs. Next slide, please.

17 In order to develop guidance documents and to prepare staff 18 for advanced reactor fuel qualification reviews, the staff formed and expanded 19 engagements with domestic and international partners. The NRC has 20 developed working relationships with the advanced reactor community that 21 maintain NRC independence without isolation. These working relationships 22 enhance our understanding of the needs of potential applicants, leverage 23 available experience in national laboratories, and facilitates participation in 24 codes and standards committees that are related to advanced reactors.

72 1 For example, the NRC staff has collaborated with various 2 national laboratories to provide input to fuel qualification guidance and to 3 exercise this guidance. Additionally, NRC staff members participated as 4 observers in advanced reactor fuel working groups. As an example of this, 5 NRC staff members attended the industry-led and DOE-funded Accelerated 6 Fuel Qualification Working Group as observers to better understand the 7 concerns of the advanced reactor fuel community, and to learn about potential 8 directions that future fuel qualification licensing requests might take.

9 In addition to our domestic activities, the NRC staff actively 10 engages with various international organizations to exchange information on 11 the safety of advanced reactor fuel designs. For example, NRC staff 12 representatives led the development of the report titled "Regulatory 13 Perspectives on Nuclear Fuel Qualification for Advanced Reactors" through 14 the Nuclear Energy Agency, or NEA, which later served as the foundation for 15 the NRC's own Non-LWR Fuel Qualification Guidance, published in NUREG-16 2246. Because the staff actively collaborated on the development of the NEA 17 report and closely aligned our NRC specific guidance with it, NUREG-2246 18 enhances regulatory predictability for our fuel vendors seeking approval in 19 multiple countries. The NRC is also collaborating with the Canadian Nuclear 20 Safety Commission under the Memorandum of Cooperation to develop a joint 21 position paper on the TRISO fuel qualification. Next slide, please.

22 As mentioned previously, the NRC staff actively prepared 23 for advanced reactor fuel qualification reviews by developing guidance and 24 addressing knowledge management via international and domestic

73 1 engagement efforts. Recent licensing activities demonstrate the 2 effectiveness of our efforts. The NRC has completed, or is in the process of 3 completing, review of four advanced reactor fuel qualification and fuel 4 performance topical reports and provided feedback on three similar White 5 Papers. Perhaps more important than the number of reviews completed is 6 the method by which the staff and applicants have approached fuel 7 qualification regulatory reviews. This approach has led to a process that 8 enhances regulatory clarity and reliability.

9 This approach includes, first, engaging with the industry 10 early to identify opportunities to develop common products, such as this 11 topical report, that can support multiple advanced reactor designs with use of 12 similar fuel forms. And, second, engaging with potential applications in pre-13 application activities to increase understanding of the NRC's regulatory 14 requirements so that applicants will be -- applications will be of high quality 15 and increase the likelihood of an applicant successfully demonstrating 16 compliance with all applicable rules and regulations.

17 One example of this process is the approach which was 18 used to support TRISO-based fuel qualification regulatory reviews. Before 19 any TRISO-based advanced reactor designers were ready to engage with the 20 staff, the staff reviewed and approved a TRISO particle fuel qualification 21 topical report submitted by the Electric Power Research Institute, or EPRI, in 22 coordination with Idaho National Laboratory. The TRISO particle design 23 covered by this topical report is common amongst multiple TRISO-based 24 advanced reactor designs and therefore, the staff's approval is applicable to

74 1 similar designs which meet the conditions of the topical report. This 2 increases efficiency for licensing request applications by allowing TRISO-3 based advanced reactor designers to rely on the previously approved TRISO 4 particle, and to focus the regulatory applications on the final fuel forms; for 5 example, TRISO pebbles or prismatic core designs.

6 The staff further supported fuel qualification by encouraging 7 pre-application engagements with interested advanced reactor designers.

8 These engagements can include activities such as position papers or 9 meetings to discuss future licensing requests, and for the NRC staff to provide 10 early feedback and clarity regarding requirements for fuel qualification.

11 The approval of the EPRI TRISO fuel qualification topical 12 report and the use of pre-application engagements has supported fuel 13 qualification topical reports for applicants, including Kairos and X-energy.

14 The use of this process resulted in higher quality topical report submittals and 15 more streamlined regulatory reviews. Next slide, please. I will now turn the 16 presentation over to Jason.

17 MR. PIOTTER: Thank you, Chris. Good morning, Chair 18 and Commissioners. I am pleased to be here today to provide an update on 19 the readiness for reviewing applications relating to the front-end and back-end 20 of the advanced reactor fuel cycle. Next slide, please.

21 The staff has been actively preparing for the advanced 22 reactor fuel reviews by leveraging past licensing experience, performing 23 preliminary technical evaluations, and evaluating the regulatory framework 24 applicability to non-LWR fuel designs.

75 1 For clarity, the front-end of the fuel cycle includes 2 conversion, enrichment, and fuel fabrication facilities, as well as fresh fuel 3 transportation. And the back-end of the fuel cycle includes spent fuel 4 storage, spent fuel transportation and, ultimately spent fuel disposal, or 5 possibly recycling or reprocessing. We have made significant strides in our 6 readiness to review applications for licenses and certifications for the 7 fabrication and transportation of near-term advanced reactor fuels, and our 8 preparatory activities built upon previous experience we have licensing 9 enrichment and fuel fabrication facilities with high enrichments, and certifying 10 transportation packages with high enrichments in novel fuel designs.

11 We are actively gathering technical information for longer-12 term advanced reactor fuel concepts to support front-end fuel cycle licensing 13 reviews. We remain ready to review technical information and licensing 14 actions for the back-end of the fuel cycle, for both near-term and long-term 15 fuel concepts. Specifically, we are actively seeking technical information, 16 including fuel performance data, which will inform ongoing evaluations of the 17 regulatory framework and guidance for the back-end of the fuel cycle.

18 In 2021, the staff released seven technical reports prepared 19 for the NRC by the Center for Nuclear Waste Regulatory Analysis focusing on 20 near-term advanced reactor fuel concepts such as TRISO and metal fuels.

21 These analyses evaluated unirradiated or fresh fuel transport, storage of spent 22 fuel, irradiated or spent fuel transport, and disposal. With respect to longer-23 term advanced reactor fuel concepts, the NRC recently published a report on 24 front-end considerations for molten salt fuels, which Wendy will discuss further

76 1 in her presentation.

2 As a complementary activity to ongoing technical 3 evaluations, the NRC and Oak Ridge National Laboratory conducted a week-4 long fuel seminar late last year. This seminar focused on non-LWR high-5 assay low-enriched uranium, or HALEU, fuel concepts enriched between 10 6 and 20 weight percent U-235, and how these new technologies will affect fuel 7 cycle facility transportation package and spent fuel storage system licensing.

8 The seminar covered advanced reactor fuel technologies, including fuel types 9 using TRISO fuel, metallic uranium fuel, molten salt reactor fuel, and 10 transportable micro-reactor fuels.

11 The staff has concluded that current regulatory framework 12 for the front-end and the back-end of the fuel cycle is flexible enough to 13 accommodate near-term and advanced reactor fuels. The regulations are 14 performance-based, technology-inclusive, and are expected to be sufficiently 15 comprehensive for risk-informed licensing of advanced reactor fuel processing 16 and fabrication operations, transportation, and storage. While staff has not 17 yet identified the need to make any changes to the regulations for near-term 18 fuel concepts, such as TRISO or metal fuels, or longer-term advanced reactor 19 fuel concepts such as molten salts, we continue to assess our regulatory 20 framework to identify any challenges and/or data needs to ensure our 21 readiness. Next slide, please.

22 Consistent with our current practice, applications for 23 advanced reactor fuel facilities licensing, design certification of fresh fuel 24 transportation packages, design certification of spent fuel storage casks, and

77 1 design certification of spent fuel transportation packages must all demonstrate 2 compliance with NRC regulations such that advanced reactor fuels can be 3 safely managed in all phases of the fuel cycle. The NRC is actively reviewing 4 applications for licensing and certifying the possession and use of special 5 nuclear material enriched to less than 20 percent U-235 for the production of 6 advanced reactor fuels, higher enriched uranium hexafluoride, or UF6, 7 advanced reactor fuel fabrication, and advanced reactor fuel transportation 8 packages for the front-end of the fuel cycle.

9 For example, the NRC staff is currently reviewing the license 10 application for the TRISO-X Category II fuel fabrication facility and a certificate 11 of compliance application for the DN30-X uranium hexafluoride, or UF-6, 12 transportation package and, finally, the OPTIMUS-L fresh fuel transportation 13 package for TRISO fuel. Each of these applications are notable because, if 14 approved, they represent the first significant steps forward for near-term 15 advanced reactor fuel availability.

16 The staff's ability to review applications related to the 17 deployment of advanced reactor fuels is a direct result of our pre-application 18 activities for the front-end of the fuel cycle. We expect to engage in additional 19 pre-application activities over the next three years and beyond with 20 prospective applicants, licensees, and vendors, some of whom have already 21 notified the NRC of their intent to submit applications for fuel facilities and 22 corresponding transportation packages. Next slide, please.

23 Looking forward, staff is focusing on resolving technical 24 issues and seeking ways to enhance efficiency and effectiveness. The staff

78 1 believes that while these needs exist, they are not an impediment to licensing 2 advanced reactor fuels. Rather, they are technical or operational challenges.

3 To assist with these regulatory needs, the staff at NMSS has 4 begun to develop the advanced fuels roadmap which will provide a holistic 5 picture linking regulatory, technical, communication, and budgetary activities 6 into one complete planning and action tool. The roadmap is intended to chart 7 both the front-end and back-end of the fuel cycle for all near-term and longer-8 term fuel concepts by licensee or certificate compliance holder.

9 With respect to the front end of the fuel cycle, there are 10 potential technical challenges for HALEU feed material and advanced reactor 11 fuels, such as limited critical experiments for higher enriched material, as well 12 as potential operational challenges at fuel facilities. The additional availability 13 of critical experiments for the entire HALEU range, as well as criticality 14 benchmarks would support more efficient and effective reviews. Similarly, 15 there may also be operational challenges such as chemical hazards or 16 security requirements for the possession, use, and transportation of Category 17 II quantities of special nuclear material.

18 The staff remains ready to review applications relating to the 19 back-end of the fuel cycle for both near-term and long-term fuel concepts 20 based on the information available today. The staff will continue to gather 21 available information and develop guidance, as needed, to enhance the 22 efficiency of our reviews.

23 We will continue to evaluate the regulatory framework and 24 assess information needs to support our readiness, including potential areas

79 1 of technical focus such as source term evaluations, criticality and shielding 2 evaluations, thermal performance, material degradation considering both 3 short-term and long-term performance.

4 Finally, we are encouraged to see external stakeholders 5 starting to focus on the back-end of the fuel cycle. For example, NMSS 6 recently attended a Nuclear Energy Agency workshop on the back-end of the 7 advanced reactor fuel cycle. And we have been involved in discussions with 8 the extended storage and collaboration project headed by EPRI. These 9 activities will facilitate information gathering and will ultimately inform the 10 advanced fuels roadmap. Next slide, please. I will now turn the 11 presentation over to Mirabelle.

12 MS. SHOEMAKER: Thanks, Jason. Good morning, Chair 13 and Commissioners. I am pleased to present on the topic of international 14 safeguards, implementation of advanced reactor fuels, and international trade.

15 Next slide, please.

16 The NRC promotes and supports nuclear non-proliferation 17 through the implementation of safeguards on the commercial use of nuclear 18 material and technology. And the objective of IAEA safeguards is to deter 19 the spread of nuclear weapons through early detection of the misuse of 20 nuclear material or technology. Safeguards are a set of technical measures 21 that control and account for nuclear material to ensure it is used for peaceful 22 purposes. Safeguards work hand in hand with security to deter and detect 23 potential loss, theft, diversion, or misuse of material, equipment, and 24 technology.

80 1 Domestic safeguards are modeled from international 2 safeguards requirements that are fulfilled through a collection of information 3 through the U.S. national system of accounting for source and special nuclear 4 material. The accounting system, known as the Nuclear Materials 5 Management and Safeguards System, or NMMSS, supports the export 6 controls framework and fulfills reporting commitments under the U.S.'s various 7 agreements.

8 The NRC plays a technical role alongside other executive 9 branch agencies to implement safeguards across commercial nuclear 10 industry. The inter-agency collaborative environment and frequent 11 coordination allow the NRC to stay on the pulse of improvements and 12 advancements in safeguards. As a result, like in the area of advanced 13 reactor licensing, the NRC is proactive in safeguards implementation instead 14 of reactors developments. Next slide, please.

15 The regulatory framework is already in place to support 16 safeguards implementation at advanced reactor fuel cycle facilities. The 17 framework can apply to various technologies and types that rely on the use of 18 special nuclear material. The regulatory framework also includes 19 requirements geared towards international safeguards and compliance with 20 IAEA reporting for facility selected for safeguards.

21 The regulation will focus on tracking, accounting, and 22 reporting of special nuclear material to the NMMSS system, which is operated 23 by the Department of Energy, National Nuclear Security Administration, or 24 DOE NNSA, with NRC support through and interagency agreement. The

81 1 data currently submitted by licensees will be the same type of data to be 2 submitted by producers and users of advanced fuels. The NMMSS system 3 is prepared to track the location of these materials and create reports to fulfill 4 our safeguards commitments.

5 Complementary to the regulations, the NRC published 6 guidance for materials control and accounting at Category II facilities in July 7 2022. The guidance is specific to licensees that possess special nuclear 8 material of moderate strategic significance. And the general performance 9 objective is rapid determination of an actual loss of a significant quantity of 10 special nuclear material through a high level of safeguards awareness training 11 and conservative limits on item control and shipper/receiver differences that 12 are commensurate with the attractiveness of the material at these facilities.

13 These measures uphold principles of domestic safeguards and complement 14 existing guidance for Category I and III facilities under the graded approach 15 for material control and accounting. Next slide, please.

16 International engagement is growing in importance as 17 advanced reactors and advanced fuels enter our international trade. NRC 18 has been and continues to be actively engaged with our interagency partners 19 and international counterparts on safeguards. NRC staff is working with DOE 20 and national lab staff on the ongoing technical work related to MC&A 21 approaches for advanced reactor fuels and new facilities for advanced 22 reactors. The DOE work is focusing on challenges presented for MC&A by 23 advanced reactors where the fuel is not contained in straight assemblies, such 24 as some molten salt designs.

82 1 Now as Chris mentioned earlier, Oak Ridge National Lab 2 prepared a report for the NRC in March of 2020 that provides a model of an 3 MC&A plan for pebble bed reactors, as well as the basis, methodology, and 4 process for development of an MC&A plan, outline, and analysis. Insight 5 from these DOE analyses are helping to inform NRC staff in review 6 preparations and pre-application engagements with developers.

7 The NRC staff serves as chair of the subgroup on the 8 implementation of safeguards in the U.S. with the Departments of Energy, 9 State, Defense, and Commerce. This group, known as SISUS, allows 10 interagency discussion resolution of practical issues of safeguards 11 implementation in the U.S. for both commercial and government facilities.

12 Through SISUS, the NRC has engaged with the IAEA on priority safeguards 13 considerations for advanced reactors and the advanced fuel cycle. Working 14 hand-in-hand with the IAEA and SISUS, the NRC is able to inform advanced 15 reactor developers about international safeguards, and engage with potential 16 applicants on these topics during pre-application meetings.

17 In complement to IAEA safeguards, the NRC participates 18 with the Department of State, and DOE NNSA, in the Nuclear Cooperation 19 Authorities Group, or NCAG. This is a forum with our major nuclear trading 20 partners, Australia, Canada, the European Atomic Energy Community, Japan, 21 and the United Kingdom. The U.S. maintains bilateral agreements with each 22 of these members and is committed to tracking and reporting source and 23 special nuclear material received from our trading partners to ensure that the 24 material remains used for peaceful purposes.

83 1 International partnerships and interagency coordination 2 have ensured that safeguards are reflected in the regulatory framework and 3 effectively deployed across the nuclear industry to meet international 4 commitments. The NRC has played a pivotal role in connecting global 5 safeguards considerations with the commercial industry by welcoming 6 interagency stakeholders into public meetings and other forums with NRC 7 licensees.

8 A notable example is the recent U.S. prior government 9 approval memo to Global Nuclear Fuels America, or GNFA, in September of 10 this year where the NRC informed GNFA that its process for tracking foreign 11 obligations on low-enriched uranium is appropriate and upholds principles for 12 foreign obligation exchanges. This approval was granted in less than 90 13 days after GNFA's request for a review. And that timeline was only possible 14 due to NRC's extensive early engagement with interagency partners.

15 NRC's role in the domestic international safeguards 16 communities allows us to keep abreast of safeguards policy development and 17 to continue to provide efficient safeguards guidance and reviews for advanced 18 reactor fuels technology. Next slide, please. I will now turn the presentation 19 over to Wendy.

20 DR. REED: Thank you, Mirabelle. Good morning, Chair 21 and Commissioners. And I'm very pleased to be here today to provide an 22 update on research activities to support efforts related to the future licensing 23 of advanced fuels and fuel cycles. Next slide, please.

24 So as Chris mentioned, research staff is supporting NRR to

84 1 develop tools to perform independent analyses for new non-light-water reactor 2 fuel designs. This support includes developing a plan to update the FAST 3 fuel performance code documented in NRC non-light-water reactor vision and 4 strategy, Volume 2, Fuel Performance Analysis for Non-Light-Water Reactors.

5 Subsequently, staff has completed several of the tasks 6 outlined in the plan, including developing TRISO fuel models, FAST code, and 7 improving existing metallic fuel capabilities to perform code assessments.

8 These code assessments revealed that FAST is ready for metallic and TRISO 9 fuel confirmatory analysis. Further improvements to the code will reduce 10 uncertainty in code predictions.

11 Recent code development efforts rely on experimental data 12 for developing and validation of confirmatory models. Therefore, staff is 13 monitoring industry-led efforts on advanced modeling and simulation involving 14 atomistic and mechanistic modeling that can inform the need for experimental 15 programs and to identify testing priorities.

16 Staff also engages regularly with the DOE. NRC staff 17 members participate in DOE's monthly meetings such as the Advanced Fuels 18 Campaign and the Advanced Gas Cooled Reactor Program review meetings, 19 where the latest experimental data is presented and the latest code 20 development efforts are discussed. NRC staff members periodically meet 21 with researchers at the national laboratories to learn more about code 22 development efforts sponsored by the Nuclear Energy Advanced Modeling 23 and Simulation, or NEAMS, program to ensure that NRC's tools include the 24 relevant models for non-light-water reactor fuels.

85 1 Keeping an eye toward being ready for future technologies, 2 the staff has initiated a research activity under the Future Focus Research 3 Program on the applications of nanotechnology for claddings in advanced fuel 4 assemblies. These advanced claddings may offer superior resistance to 5 radiation damage and serves degradation to harsh coolants and high 6 temperatures. Next slide, please.

7 Research is supporting NMSS through a holistic approach 8 to assess technical considerations for advanced fuel cycles. To facilitate 9 engagement and cooperation, research developed an addendum to the 10 Nuclear Energy Innovation Capabilities Act of 2017, the NEICA memorandum 11 of understanding between NRC and DOE. The addendum signed earlier this 12 year, addresses technical coordination on activities related to the safety of 13 advanced fuel technologies and fuel cycles.

14 Staff has been conducting activities related to the front-end 15 and back-end of advanced fuel cycles. For example, as Jason discussed, 16 Research recently published a preliminary assessment of front-end activities 17 for molten salt reactors, including activities related to enrichment, production, 18 and transportation of fresh salt fuel for reactor sites.

19 Based on the recommendations in the report, Research has 20 initiated an assessment of technical and regulatory considerations related to 21 the front-end of the molten salt reactor fuel cycle. We are also carrying out 22 an assessment to consider DOE's plans for the production or recovery of 23 HALEU fuel feed material, and options for transportation for the shipment of 24 HALEU fuel feed material to be used in advanced reactor fuels.

86 1 And as Mirabelle mentioned, advanced fuels and advanced 2 reactors can introduce new considerations for safeguards and material control 3 and accounting due to their novel designs. Modeling and simulation can help 4 to identify the best MC&A practices for nuclear facilities as part of the design 5 process in a cost-effective, risk-informed way. Staff is examining how 6 modeling and simulation can be used to help assess uncertainty in MC&A 7 measurements at different points in a facility, and prepare the NRC staff to 8 verify and validate modeling and simulation technologies.

9 In addition, staff is building on in-house work that our staff, 10 including an NRC summer intern, performed to explore the use of modeling 11 and simulation to help integrate the safeguards, security, safety, or 3S, by 12 design approach. Next slide, please.

13 So, as Jason mentioned, potential longer-term challenges 14 for the back-end of the fuel cycle need to be evaluated. And Research is 15 working to enhance the NRC's understanding of the technical considerations 16 related to the unique attributes of some spent advanced reactor fuel types.

17 Staff has recently begun work to assess the novel waste 18 streams and potential waste forms that are being considered for molten salt 19 reactors. Planned work includes analysis of off-gas management, include 20 monitoring controls needed for successful operation of the off-gas system.

21 Staff is also monitoring various advanced research project 22 agency energy, or ARPA-E programs that seek to address the challenges of 23 spent fuel waste management. One such program is optimizing nuclear 24 waste and advanced reactor disposal systems, or ONWARDs. Research

87 1 management was recently invited to speak at the kick-off meeting in Chicago 2 to provide NRC's perspectives. Additionally, staff engages regularly with the 3 DOE regarding molten salt reactors, and meets periodically with researchers 4 at the national laboratories working on monitoring, census, and 5 instrumentation for these reactor types. Thank you for your attention. Next 6 slide, please. And I'll turn the presentation back to Dan for closing remarks.

7 MR. DORMAN: Thank you, Wendy. As you've heard, the 8 staff is preparing to regulate advanced reactor fuels throughout the fuel cycle.

9 We are working with our domestic and international stakeholders to increase 10 our capacity to address these new technologies. We are working to ensure 11 that we understand the dynamic landscape in which we are regulating, and 12 we are adapting to be ready to oversee the safe and secure deployment of 13 fuels for advanced reactors.

14 We continue to encourage early stakeholder engagement 15 with us so that we can stay informed of the industry's priorities and design 16 developments in order to prepare the agency with the needed near-term and 17 long-term tools to ensure the safe and secure use of advanced reactor fuels 18 efficiently and reliably.

19 I want to thank all the panelists today and the staff who 20 supported the preparations for this Commission meeting, as well as all the 21 staff working in the challenging area of advanced reactors. Thank you again 22 for the opportunity to present today. And we look forward to your questions.

23 CHAIR HANSON: Thanks, Dan. Thanks everyone on the 24 staff for the panel. We will begin again with Commissioner Wright.

88 1 COMMISSIONER WRIGHT: Thank you, Chair. And, 2 again, thank you for your presentations. And I know you had a lot of staff 3 support to put it together, too. So, thank them as well.

4 This is a very busy agency right now in a lot of different 5 areas. And there's a lot of balls in the air. And I really appreciate the way 6 that you're dealing with it. And, you know, as we're coming out of COVID and 7 getting into just regular routine, so it's recognized. So, thank you.

8 So, Dan and Rob, maybe I'll start with you. So, you 9 mentioned that we're focused on retaining, you know, developing and 10 recruiting highly qualified staff. Talk to me a little bit more maybe about how 11 you are maintaining an agile workforce and what are -- what kind of tools are 12 you using, especially in this area, where we're developing a diverse landscape 13 in advanced fuels?

14 MR. DORMAN: So, I'll start at the agency level and then 15 I'll let Rob pick it up to the specific areas. As you know, we've had a high 16 focus on hiring over the past year. And we've made significant progress.

17 But we have a lot of work still to do. And we'll talk more about that at next 18 week's Commission meeting.

19 But one of the areas that we're looking at as we continue to 20 focus in that area of recruiting and hiring the right talent is the resources 21 available to do that in OCHCO and throughout the agency to support our hiring 22 needs, as well as our recruitment activities. And where we're recruiting and, 23 also, re-looking at our recruitment materials and making sure we're putting the 24 agency's best foot forward as a model place to work. So, that's kind of some,

89 1 some high-level general things. Let me let Rob speak to the particular area.

2 MR. TAYLOR: Thanks, Dan. It's a great question, 3 Commissioner. It's a challenging area. These four that are sitting here at 4 this table, we have a bunch behind them, but we need more. The workload 5 and where we expect it to go, we need to hire to round out our resources and 6 be prepared to be able to do multiple reviews at the same time. We're able 7 to handle the workload that we have today. But if the ARDPs come in, we'll 8 have multiple activities going on at the same time, as well as some others who 9 have indicated.

10 So, we have to recruit well and hire well. That includes 11 both people with experience outside, so we need to be competitive as we do 12 that. As well as recruit, and train, and develop the next generation as well.

13 So, we're using the NRAN program extensively to fill out our ranks as much 14 as possible. Everybody wants the NRANers they're all great.

15 So, we've first got to get them in the door, and then 16 assigned, and then get them the skill sets and the training. So, we have a 17 robust training program in advanced reactor technologies that we've been 18 putting together as part of our integrated action plan strategies over the last 19 few years. So, we're executing that. I think we're having training, was it this 20 week, I think, on molten --

21 MR. DORMAN: Thirteenth through 15th.

22 MR. TAYLOR: Thirteenth through 15th. So, on molten salt 23 reactors. So, that will bring this type of technology to further enhance staff's 24 understanding and capability. And then we have to retain them as well. This

90 1 is a competitive job market. So, we're going to leverage the tools through 2 OCHCO to use them to retain our staff. One of the things that's helpful in this 3 respect is that as more opportunities are present and our staffing members 4 increase, we now have the potential to promote staff. That hasn't been an 5 opportunity over the last few years. So, when the skill sets are needed at 6 those grade levels, we're able to post. And we've been successful in internal 7 promotions of staff, which is a very important piece for staff to feel like they 8 have a career path within the agency. So, I think it's a multi-faceted activity, 9 and we're working all the pieces at the same time.

10 COMMISSIONER WRIGHT: Yeah, thank you for that. And 11 I do, I mean, my interactions with the new people on staff to be onboard, I 12 mean, they are hungry. Right? They are, they are ready, which is really, 13 really good. It's very nice, and it's great to see.

14 Wendy, let me come to you, Doctor. So, you mentioned 15 that we have a vision and a strategy document for the fuel performance for 16 non-LWRs. Talk to me a little bit about what the next steps are in the plan?

17 And as, you know, are we focused on code development and model simulation 18 or are there other focus areas?

19 DR. REED: There's other focus areas as well. They're 20 also, you know, looking at analytical tools in general supporting codes and 21 standards development. So there's, I believe there's, you know, severa 22 volumes with regard to vision and strategy. So, you know, a general process 23 for updating these plans is to for the analytical tools and the molten salt.

24 Sorry, for modeling simulation as well, is to, you know, frequently look at our

91 1 data needs. Where are the gaps in our needs? Look at what models, what 2 data is already out there. And also look for opportunities to collaborate, 3 cooperate with Department of Energy, for instance, to make sure that we're 4 leveraging all the experience we can, that we're not duplicating efforts. And 5 so that is, it's sort of the general process with regards to the plans.

6 COMMISSIONER WRIGHT: Thank you. Jason, you heard 7 on the first panel had a little conversation with Ms. Wheeler regarding some, I 8 don't know, maybe some that were termed as surprises maybe, especially for 9 the -- maybe, and she talked communication, right, but the surprise probably 10 in the acceptance review document, a standard thing that was out there. And 11 maybe potential improvements in that process, you know, along the way, too.

12 Do you have any, well, after you heard that conversation do 13 you have any perspectives or anything you'd like to share from your 14 experience or staff's experience?

15 MR. PIOTTER: Yes. So, I think right out of the gate the 16 staff's perspective is that the entire process itself, the bifurcated process of 17 separating the environmental review from the safety review, it was actually a 18 successful process. It allowed us to do some things, to be a little bit creative 19 with some of the potential gaps that we had in the acceptance review process 20 to find a path forward for that. And having that flexibility, I think, is an 21 important thing to have. Now, it may be slightly different than what we're used 22 to, right? And so I think that's an issue of, somewhat of perception and sort 23 of point of view issues. So, I think that was really a positive thing.

24 I think we're a lot closer, a lot more closely aligned than one

92 1 would expect out of the gate in that I think we all have the same goals with the 2 acceptance review. I think there's, again, different interpretations. But at the 3 end of the day -- and I want to come back to this because I think this point is 4 very important -- that communication piece for acceptance reviews is 5 incredibly important. And I think you mentioned it as well, that over-6 communication in particular. When you're dealing with a novel fuel facility, or 7 any novel activity that we're working on, having those early and often 8 communications and in-depth communications are absolutely crucial so that 9 you can get past some of these perceptual differences.

10 COMMISSIONER WRIGHT: Sure. Great. Thank you.

11 And part of the conversation that we had on the first panel had to do with on 12 the back-end of the fuel cycle. Right? So, talk to me a little bit more about 13 the timing of having that pathway on the back-end. Is an applicant going to 14 have to know how they're going to dispose of their fuel on day one, or is this 15 something that can be done later in the process?

16 MR. PIOTTER: So, as we currently operate now, it's later in 17 the process. There's not a requirement in any of our processes for licensing 18 and certification that requires a specific date for availability for disposal.

19 COMMISSIONER WRIGHT: Okay. Thank you so much.

20 So, Chris, before the panel started, Rob said that you were the guru on some 21 of this, and that I should let you have the questions.

22 MR. VAN WERT: Thanks, Rob.

23 COMMISSIONER WRIGHT: So, you know, HALEUs was 24 discussed a few times in Jason and Wendy's presentation. And I'm curious

93 1 if you had any insights regarding how the staff's, how they plan to handle 2 reviews of HALEU and what makes it different or more challenging from a 3 regulatory and technical perspective?

4 MR. VAN WERT: Of course. Yeah, as you heard this 5 morning, it's HALEUs on everyone's mind, Department of Energy, us, industry, 6 et cetera. From a reactor licensing perspective, there's not a huge challenge 7 there because we don't have a lot of specific regulations tied to it. The only 8 place in Part 50 where a by weight percent enrichment limit is mentioned is in 9 50.68, which is related to spent fuel pool criticality. That is a regulation that 10 you can choose to follow, and it provides a lot of benefits to an applicant or to 11 an operator. But you can also, instead, use the Part 70 requirements that are 12 kind of associated with it. So, it's not a requirement to follow 50.68.

13 So, once you take that out, then you come back to what are 14 maybe some of the technical challenges. And those mostly revolve around 15 validation. I think you heard a lot about that this morning, so.

16 COMMISSIONER WRIGHT: Right. Very quickly, I've got 17 just a few seconds left. In the discussion of generic guidance, right, you 18 mentioned the important role of developers in demonstrating that their fuel 19 behavior is well understood, right, and can be predicted.

20 MR. VAN WERT: Uh-huh.

21 COMMISSIONER WRIGHT: Can you elaborate on how 22 developers are going to be able to achieve this understanding in cases where 23 reactor designs are still, you know, preliminary?

24 MR. VAN WERT: Yes. Yes. And it depends to some

94 1 extent I would say on what technology they've chosen to proceed with. Some 2 technologies have quite a bit of history behind them, you know, TRISO being 3 one of them. And with that in mind, maybe they want to extend, you know, 4 say, a hypothetical design wants to extend the operation outside of the past 5 history. They would be able to leverage the pervious history and then maybe 6 do a limited set of testing to develop that database necessary for the desired 7 operability range they have.

8 For a more novel approach, a new design that maybe we 9 haven't considered in the past, before they come in for licensing, of course, 10 they're going to be doing their own internal testing program to just identify the 11 characteristics of the fuel which are most important to safety. And by doing 12 that they will identify those characteristics. And that information will help 13 them go through the process.

14 And I mentioned NUREG-2246, which is kind of a 15 technology-inclusive approach. And using that, they will help identify maybe 16 missing data areas. And then that will dictate the further testing that they will 17 need to support their licensing efforts.

18 COMMISSIONER WRIGHT: Okay, thank you.

19 CHAIR HANSON: Thank you. Commissioner Caputo.

20 COMMISSIONER CAPUTO: Thank you all for being here.

21 It's quite a big panel, but certainly we appreciate all your contributions. Mr.

22 Van Wert, I'm going to start with you. We have one operational uranium 23 enrichment facility here in the U.S. If that facility chose to pursue 19 percent 24 enrichment, that would be a Cat II facility; correct? Or maybe Mr. Piotter?

95 1 MR. VAN WERT: That would be more of a Jason question.

2 COMMISSIONER CAPUTO: Okay, Jason.

3 MR. PIOTTER: Yeah. Correct.

4 COMMISSIONER CAPUTO: Okay. So, would that mean 5 that would require a new application or would it be a license amendment?

6 MR. PIOTTER: As I understand it right now, it would be a 7 license amendment.

8 COMMISSIONER CAPUTO: And how long would it take 9 the staff to review that?

10 MR. PIOTTER: It depends on the quality of the application, 11 but typically 30 to 36 months is a rough timeframe.

12 COMMISSIONER CAPUTO: Okay. Thank you. I'll just 13 stay with you, Jason.

14 MR. PIOTTER: Sure.

15 COMMISSIONER CAPUTO: And perhaps Rob. So we 16 heard from Mrs. Wheeler one of the things that she mentioned was the staff's 17 request for supplemental information during the application acceptance review 18 and how detailed those information requests were.

19 Rob, I know that this is something that we struggle with in 20 application space in general, but between the two of you, how are you 21 managing the request for additional information process in general in terms of 22 making sure that questions are only asked once? In this case, I hope since 23 they were asked in acceptance space, they're not going to be asked again 24 now that you're into the review.

96 1 And how are you also looking to tailor the scope of those to 2 ensure that the questions that are being posed are actually necessary to make 3 a safety or security finding?

4 MR. PIOTTER: Yeah. Ill go ahead and start. So I think, 5 you know, initially, when we're -- when we're looking at RSIs in particular, there 6 are several layers of review that happens. You know, the staff obviously 7 produces them, they get reviewed at the branch chief level, and depending 8 upon the actual application that we're looking at, sometimes they go up to the 9 Division Director level.

10 So there are several layers of review, multiple branch chiefs.

11 That process, I think, helps us to sort of weed out some of those questions 12 that may not rise to the level of RSIs. They may be too technically focused 13 or they may be something that we need to address as an observation. So 14 that's one way that we sort of meter out what we're doing with respect to the 15 scope of the questions themselves.

16 In terms of whether or not they get into technical review 17 space, it sort of depends on what the answer looks like and what the process 18 that we're following is, because I think if you look at, in this case with TRISO-X, 19 some of the acceptance review activities have actually bled over into the 20 technical review space, just by using some of the flexibilities in the acceptance 21 review itself.

22 So there will be some things I think that get addressed in 23 technical review space that weren't covered fully in that acceptance review 24 phase. And so that, again, was part of that flexibility that was sought to be

97 1 able to accept this. And I think the one area that was brought up was digital 2 I&C, for example, where the entire design wasn't present at the time that the 3 application was submitted, and that we're going to be pursuing additional 4 activities during technical review space to resolve those -- that particular issue.

5 With respect to RAIs, we have created a culture within DFM 6 to be very, very sensitive to the fact that we only want to ask a question once.

7 We don't want to miss it in the first round of RAIs and then have to ask it in the 8 second round of RAIs. And we don't want to belabor a particular point if we 9 don't need to. And, again, that goes to that same level of review at multiple 10 levels within DFM, to ensure that we're not either being duplicative or asking 11 questions that are out of scope.

12 COMMISSIONER CAPUTO: Okay. Thank you. Dan 13 and Rob, I'm going to ask you a quick high-level question, given that staffing 14 has come up. Considering the agency finished out fiscal year '22 with $92 15 million in carryover, clearly resources are not a constraint in hiring. Can you 16 just briefly discuss the factors within the scope of this area, considering that 17 there is a lot of -- a lot of work going on here, and that this work is potentially 18 critical path for advanced reactors themselves. Can you just discuss the 19 factors that are constraining your ability to staff here?

20 MR. DORMAN: Yes. I think Rob touched on the 21 competitive nature. You know, there are 17 developers in pre-application 22 discussion, as well as the existing fleet and a number of other entities that 23 we're competing with for the same talent. So that's a factor. I see --

24 COMMISSIONER CAPUTO: Do you have enough

98 1 flexibility in our hiring practices to offer the levels of compensation that you 2 believe you need to to compete?

3 MR. DORMAN: We have -- we have both resources and 4 processes to apply to that, and I think I'll let Rob jump in on any specifics.

5 MR. TAYLOR: So a couple things to your question. It's a 6 really good question, Commissioner. There are flexibilities and tools and 7 we're executing them. So, you know, when it comes to negotiating salary, 8 that's a huge thing with folks. We have tools that allow us to assess and 9 adjust the salary offer that we make to individuals to be competitive. We have 10 also adapted to enhance the ability to use full-time telework in our recruitment 11 processes, which is very important to a lot of people that we're recruiting today.

12 So we're adding those flexibilities to those things.

13 To the execution and the dollars, the understaffing that we 14 had in fiscal year '22 did require us to prioritize work to some degree. We 15 emphasized ongoing licensing work as our highest priority. So things like the 16 Kairos review and the pre-application engagement where we're trying to 17 approve topical reports and get feedback on white papers, it has caused some 18 slips in some guidance that we had hoped to have finished. But we made the 19 conscious decision to apply the resources elsewhere because we still felt we 20 had the time to do the guidance where we needed to do it.

21 So we have had to make some decisions here and there 22 based on staffing levels relative to it. We haven't missed any major 23 milestones yet, but we certainly need to hire and staff to make sure we can do 24 all the work that we do plan to have on our plate.

99 1 COMMISSIONER CAPUTO: Okay. And since you 2 mentioned telework, we heard from two panelists earlier about the importance 3 of having in-person meetings --

4 MR. TAYLOR: Agreed.

5 COMMISSIONER CAPUTO: -- when dealing with 6 complicated issues. When you are utilizing this telework flexibility in hiring 7 people, how are you balancing the need for adequate in-person time given the 8 technical nature of this work?

9 MR. TAYLOR: So part of the agreement is there is an 10 expectation to come to the office when it's presence with a purpose from the 11 standpoint of 12 COMMISSIONER CAPUTO: Thank you.

13 MR. TAYLOR: -- engagement. Yes.

14 COMMISSIONER CAPUTO: Ms. Shoemaker, I have an 15 MC&A question. So just had an announcement from BWXT that they have 16 restarted fabrication of TRISO fuel, and we now have an application under 17 review for TRISO-X. So I have questions about just the nature of MC&A 18 procedures. Are the procedures that are in place for BWXT -- will they fully 19 translate to TRISO X, or is there further MC&A work that's going to need to be 20 done to support the licensing of that facility?

21 MS. SHOEMAKER: Sure. So I haven't seen the specifics 22 of this one, but what I can speak to on MC&A is that the staff put out the 23 guidance for Cat II facilities. So the approach for MC&A review will be to 24 apply Part 74 requirements, depending on the attractiveness of the material

100 1 at the site. And we believe that the requirements for current light water fuel 2 technology can still apply to the advanced reactor technology types under the 3 current regulations.

4 COMMISSIONER CAPUTO: Okay. But we still need to 5 do research on MC&A in general, so I'm looking for some clarification here.

6 Are we sort of covered in terms of fabrication facilities and our MC&A work is 7 focused on reactors themselves and the nature of, you know, tracking the 8 difference between fresh and irradiated as these materials circulate in a 9 system?

10 MS. SHOEMAKER: So if I understand your 11 question -- and, if not, I will take it back to the MC&A staff. I think you know 12 our team is five folks, three that do international safeguards and two that focus 13 specifically on the domestic safeguards application. So I'll take it back if I 14 don't fully answer your question. But we're working -- in terms of research, 15 we're working with DOE to leverage current research underway for advanced 16 reactor technology types. I don't have more, you know in-depth knowledge 17 on --

18 COMMISSIONER CAPUTO: Okay.

19 MS. SHOEMAKER: -- the BWRX application. So I'll take 20 that one back --

21 COMMISSIONER CAPUTO: Okay.

22 MS. SHOEMAKER: -- to our staff.

23 COMMISSIONER CAPUTO: All right. Jason, I'll come 24 back to you with another question, just about criticality. But, first, I'd be

101 1 remiss if I didn't start this question by saying Go Badgers, seeing as how 2 you're sporting your Hawkeyes spirit today.

3 (Laughter.)

4 COMMISSIONER CAPUTO: Just sort of slide that right in 5 there.

6 MR. PIOTTER: I'm from Wisconsin.

7 COMMISSIONER CAPUTO: Well, what went wrong?

8 MR. PIOTTER: Madison didn't like me very much.

9 (Laughter.)

10 COMMISSIONER CAPUTO: Well, that's too bad. So Mr.

11 Griffith mentioned in the previous panel that he thought there was adequate 12 nuclear criticality data. You mentioned the need for nuclear criticality data as 13 a foundation for licensing decisions with regard to HALEU. So do we have 14 the right capabilities and capacity to review licensing submittals? Do we have 15 enough of what we need in criticality space?

16 So when I look across all of these applications, whether it's, 17 you know, transportation, fuel facilities, reactors, et cetera, you know, there 18 are a lot of criticality analysis needs here. Are we going to have the data and 19 the people that we need? Because this is one heck of a specialty.

20 MR. PIOTTER: It really is. And so, you know, to start 21 with, I'm going to answer the question as, yes, we have what we need. And 22 even our criticality reviewers for both fuel facilities and for storage and 23 transportation echo that sentiment.

24 I think what we're talking about in terms of challenges really

102 1 comes down to efficiency and effectiveness of reviews, not the ability to 2 actually do the reviews themselves. So we do have an application in-house 3 for up to 20-weight percent for TRISO-X. We have an application in-house 4 for UF6 transportation package for up to 20-weight percent enriched. So we 5 have the capability to actually license those at the current time.

6 Now that focuses on, obviously, TRISO fuel in UF6. Further 7 down the road, we may need to reevaluate that to see additional information 8 that we need. But I think Mr. Griffith pointed out quite well that if we have the 9 opportunity to expand the database of critical experiments, we would be 10 remiss not to do that, because what it allows us to do is it allows us to be more 11 efficient in our reviews. It allows us to take away some of the uncertainty that 12 we have in those reviews, and then also perhaps remove some of the margin 13 that we have had to add to account for the fact that we don't have those critical 14 experiments through the full range of HALEU.

15 COMMISSIONER CAPUTO: Okay. Great. Thank you 16 very much.

17 CHAIR HANSON: Thank you. Commissioner Crowell?

18 COMMISSIONER CROWELL: Thank you. Thank you all 19 for the presentation today. It is you and your staffs that are going to make 20 this heavy, heavy lift possible, and I want to make sure you have all the 21 resources you need. I'm not planning on asking any questions about 22 workforce, but I did want to make a comment on it before I jump into my 23 questions.

24 Picking up on Commissioner Caputo's question about

103 1 telework, I think there's an implicit understanding that people on telework will 2 be in the vicinity of headquarters or a regional office, so that they can come in 3 as needed. And I think that's going to artificially limit our ability to recruit from 4 a limited pool of talent out there. Do I have that correct?

5 MR. DORMAN: Not quite. Even before the pandemic, we 6 have employees who have been on full-time remote work agreements from 7 outside of any geographic area in which we have offices. So, in that sense, 8 there are exceptions.

9 So as we work with NRR in their recruiting needs -- and as 10 Rob mentioned, are looking at having location TBD in some of our postings 11 based on the challenges we have experienced -- there is the potential that we 12 would have experts that we would hire who are outside of the geographic area.

13 But going to the point that Commissioner Caputo raised, management has the 14 prerogative in all of those cases to say, "For this meeting with the licensee, 15 we're going to get in a room and roll up our sleeves, and you're going to come 16 to the meeting." So it doesn't preclude that.

17 COMMISSIONER CROWELL: And I know it comes at a bit 18 of a burden to the employee and a cost to the agency, but I think it's worth it if 19 they need to be here and -- to do that and have the talent. So --

20 MR. TAYLOR: It's part of the hiring agreement is when you 21 put the full-time telework in place, it says that you need to be able to come to 22 the office for routine and important meetings. So we emphasize that as we 23 do our work.

24 COMMISSIONER CROWELL: Thank you. And just -- it's

104 1 all within the realm of -- there is no one-size-fits-all to solve this issue.

2 A couple table-setting questions that I have been hoping to 3 ask. And, Dan, I'll give these to you. You can farm them out to whomever 4 you think appropriate. But do light water SMRs use advanced fuels as 5 defined by NRC?

6 MR. DORMAN: I'm going to go to Chris and make sure that 7 I'm right on this. But I know -- I know, for example, one of the selling points 8 that GE has for the BWRX-300 is they are using a qualified fuel. NuScale, I 9 think if it's not, it's well within the range, and we have already completed the 10 review on it and approved it. So I think there's not these kind of challenges 11 when we talk about the LWRs that are in front of us. I'm not sure where we 12 are in the Holtec, SMRs and maybe others. Chris?

13 MR. VAN WERT: Yeah. So I think, in general, when you 14 think of light water reactor SMRs, you are looking at more traditional type of 15 materials. You know, you're looking at a zirconium-based cladding, UO-2 16 fuel pellets. I am aware peripherally because it's not my background, but I'm 17 aware that there are some discussions of maybe using ATF in the future. But 18 to the best of my knowledge, none of the applications that have come in to 19 date have any sort of advanced -- or something close to advanced reactor fuel 20 in a light water reactor environment.

21 COMMISSIONER CROWELL: So in those cases, would 22 those light water SMRs be considered advanced reactors?

23 MR. VAN WERT: Do you mean if they used ATF fuel?

24 COMMISSIONER CROWELL: No. In the ones that --

105 1 MR. VAN WERT: Oh. No. No, that's --

2 MR. TAYLOR: We typically use the term advanced 3 reactors to refer to non-light water reactor technologies. The international 4 community uses SMRs to cover both light water and non-light water 5 technologies. So it's a distinction only that we make. It doesn't matter. Our 6 approach as to how we're going to do the reviews and the activities we're 7 going to do, we're applying all the same principles and concepts, whether they 8 are light water SMR or non-light water. It's dealing -- we'll just deal with the 9 fuel type and what the performance standards of that fuel type need to be for 10 that technology.

11 COMMISSIONER CROWELL: Okay. It's still confusing 12 to me, and I think it's confusing to the external world, to understand the 13 difference between traditional reactors and advanced reactors. But let's 14 continue to work on it and get it a little bit more crisp.

15 That said, you teed me up nicely for my next question to 16 you, Rob. In your presentation, you said the current regulatory framework is 17 adequate to review and regulate the near-term use of these fuel designs, 18 including review of the applications. If that's true, why is Part 53 necessary?

19 MR. TAYLOR: So it's adequate, but it doesn't fit perfectly.

20 It's 50.46, the requirements in Part 50.52 are very prescriptive, right? And 21 the technologies, they are designed for zirconium clad, five-weight percent 22 fuel, and they provide very specific performance criteria for the fuel during 23 accident conditions. Those aren't going to be applicable to non-light water 24 reactor technology. So we'll set those aside and use the exemption process

106 1 and other techniques to be able to set the performance standards for those 2 reactors.

3 So one of the things you heard in the first panel is set what 4 the PDCs -- principal design criteria -- will be for those technologies, what do 5 they need to demonstrate early on in the review, and then you review them 6 against those standards and the performance. You go to the data. You go 7 to the testing to demonstrate that they can do it. So the tools work, and we're 8 to set aside the requirements that aren't going to be necessary for those 9 reactors and apply the right standards for safety relative to that. So that's 10 what I mean by that.

11 So we'll have the infrastructure of the research, the testing, 12 the things that we're doing, the codes, to be able to do all that work, we'll just 13 apply a different regulatory standard based on what is really appropriate for 14 that technology.

15 COMMISSIONER CROWELL: And you'll give guidance to 16 the applicants to which regulatory pathway they are -- is most appropriate for 17 them to pursue.

18 MR. TAYLOR: Well, they can choose to use any -- 50, 52, 19 or 53 will all be voluntary. They can choose whichever pathway they want to.

20 They will -- they may choose for business reasons one has a different benefit 21 over another. But we can give them guidance about how to move through 22 the process and what would need to be demonstrated. That's what we're 23 talking about with the pre-application is, okay, tell us about your technology.

24 One of the first things we want to do is go through what the applicability of the

107 1 regulations are to your technology.

2 COMMISSIONER CROWELL: My understanding of Part 3 53, though, is that it incorporates the elements of 50 and 52 into one of the 4 two frameworks.

5 MR. TAYLOR: The licensing process -- so whether you 6 have a construction permit or not, you can do that in Part 53. Absolutely. Or 7 whether you want to go with a combined license. You can do that in Part 53.

8 MR. DORMAN: But not necessarily the prescriptive 9 requirements in Part 50.

10 MR. TAYLOR: Not the prescriptive requirements.

11 COMMISSIONER CROWELL: And I'm going down this 12 pathway because I don't understand that well, but also because I'm worried 13 about our workload. And if you have Part 50, if and when Part 53 gets 14 finalized, and yet Part 50 and 52 are still open for business, I don't think that 15 helps our effort to get things done. I think it makes it a more confusing -- like 16 pick-your-own-adventure regulatory framework, and I don't think that helps 17 when we don't have a lot of staff to do this stuff. So I'd -- just take that under 18 advisement. I don't necessarily need an answer to it. But it doesn't make 19 sense to me necessarily. You're off the hook for the moment.

20 Jason, I'm very interested in the back-end of the fuel cycle 21 and what we're doing there to be prepared for the back-end on the advanced 22 reactors. Let me say advanced fuels, use of advanced fuels in whatever kind 23 of reactor. Do you have any plans in your shop for new regulations related 24 to management of the back end of the fuel cycle for advanced reactors?

108 1 MR. PIOTTER: Regulations?

2 COMMISSIONER CROWELL: For advanced fuels.

3 Yeah, regulations.

4 MR. PIOTTER: For regulations, we do not.

5 COMMISSIONER CROWELL: Okay. Do you think they 6 are going to be necessary at some point? Can you envision it, depending on 7 as you learn more about the technical aspects of the fuel and demonstration, 8 et cetera?

9 MR. PIOTTER: I don't think we can rule it out, but I think 10 the way that we're phasing our prioritization with respect to what are known 11 technologies that are coming down the pike, such as metal, fuels, or TRISO, 12 we're focusing on those first. And then, of course, molten salts coming 13 on -- behind that, and we're focusing on the front-end of that.

14 So as we phase in these new technologies, as they become 15 available, we'll have to look at that. I think we need to be careful of not 16 jumping too soon, if we don't know that we're going to need back-end either 17 transportation or storage for those particular technologies.

18 So it really is highly dependent on what kind of 19 communication and demand signals that we get from industry as to what we 20 potentially need to do. But our goal is to actively monitor whatever the 21 situation on the ground is with respect to new technologies. And if we see 22 something where we're going to need to make some changes, we will actively 23 pursue that.

24 COMMISSIONER CROWELL: Okay. Along those lines,

109 1 and this is either for you or Dr. Reed, have either of your shops reviewed the 2 Stanford letter, the Argonne-led reports on waste from advanced reactors?

3 And, if so, how are you incorporating it into your thinking and review and 4 guidance? Or it just looks like a mess to me of confusion about what the 5 back-end of the advanced fuel and advanced reactor looks like. And I'm just 6 wondering how we're navigating those waters.

7 MR. PIOTTER: So I'll say that I'm familiar with the Stanford 8 report. I haven't read it personally myself. And we're aware of it, both within 9 DFM and NMSS, as well as NRR being aware of it. And so we'll actively take 10 that into consideration as we're moving forward with back-end considerations.

11 COMMISSIONER CROWELL: Okay. Dr. Reed, anything 12 to add?

13 DR. REED: No. Like Jason, I am aware of the report.

14 We haven't had to read it yet, but we are, you know, aware of the diversity of 15 the fuel types and the -- you know, the challenges and the considerations we 16 need to make regarding the varied fuels and novel waste forms that have the 17 potential to be developed.

18 COMMISSIONER CROWELL: Yeah. Thank you.

19 Thank you, Mr. Chair.

20 CHAIR HANSON: Thank you. Chris, let me just start with 21 you real quick. You know, I brought up in the previous panel about 22 accelerated fuel qualifications. So I just wanted to kind of get your thoughts 23 about kind of what are the challenges or key technical issues from NRC's 24 perspective with the application of an accelerated fuel qualification model?

110 1 MR. VAN WERT: And I think you're going to hear kind of a 2 little bit of the same refrain, in that validation is a key challenge. You know, 3 if you get to a first principle modeling capability, it's great. But how do you 4 know that that model works properly? So you need to have some sort of 5 validation program, and I don't think anyone is saying that they won't have it.

6 It's just what will that validation program look like. So that's going to be 7 ongoing discussion between us and the industry.

8 CHAIR HANSON: Okay. Yeah. Fair enough. Thank 9 you. I think this -- let me go to you, Jason. I was really interested in this 10 slide about the advanced fuels roadmap --

11 MR. PIOTTER: Okay.

12 CHAIR HANSON: -- at NMSS. And I definitely appreciate 13 your answer to Commissioner Crowell's question about whether or not we 14 would actually need any changes to our regulations to be able to kind of deal 15 with the materials issues around these advanced fuels. And yet we're kind of 16 still in this situation where we have to -- and I think you've identified on this 17 slide a number of really good issues that we have to kind of tackle, because if 18 all of our work is kind of on the reactor side, and we haven't done some of this 19 other work on the materials side, well, then, we may find ourselves kind of 20 stuck.

21 So I -- tell me a little bit more about the roadmap. I'm really 22 interested about what the content of that is going to be, whether it's going to 23 include kind of resource needs and nominal schedules or milestones that are 24 going to be identified, et cetera.

111 1 MR. PIOTTER: You described it perfectly. I mean, that's 2 exactly -- that's exactly what it's going to have.

3 CHAIR HANSON: Okay.

4 MR. PIOTTER: You know, and part of the goal, I mean, the 5 roadmap is really -- you know, it has been in the making for quite some time, 6 even before I came on in my role for advanced reactors in ATF. It has really 7 been the brainchild of staff that have come before me. What we're trying to 8 do now is actually utilize some of our information tools that we have to be able 9 to look at this information in aggregate and then layer it to see how we might 10 see different effects with budgetary constraints, for example, and then where 11 that -- where that fits with perhaps a research timeline.

12 And so all of this information is intended or at least 13 envisioned to be in this roadmap that you can then manipulate and see what 14 the effects are, whether or not you have, again, the budget for a fuel facility or 15 multiple fuel facilities, for example, out to 2026 as one example. And so that's 16 the goal for this is it to be all-compassing, to be a repository of all our 17 information, of all of the different fuel types that we might see, all the different 18 vendors that we might see, licensees that we might see coming in, for all of 19 these activities. So, yeah, I think you framed it very, very well as far as what 20 we intend to do with it.

21 CHAIR HANSON: Okay. I think that would be really 22 helpful. Am I -- if I could provide a little impact? I mean, I think security could 23 be added -- it could be added to the fuel cycle back-end here, particularly if 24 we're talking about different kinds of fuel types that at least in theory, even if

112 1 they're self-protecting, you could put in your hand --

2 MR. PIOTTER: Sure.

3 CHAIR HANSON: -- or in your backpack or something 4 else, right? Maybe it's a robotic hand, I don't know. But I guess I would ask, 5 you know, that as that roadmap gets developed, do you have a timeframe for 6 kind of when that would be completed? I'm sure it's a -- probably an iterative 7 process, but --

8 MR. PIOTTER: It is an iterative process, and some of it is 9 dependent on what tools are available to us in terms of technology. But we've 10 got a draft of it working right now.

11 CHAIR HANSON: Okay.

12 MR. PIOTTER: And we're working to build that up over 13 time. We don't necessarily have a timeline, but it is a high priority within our 14 division to get a draft of that completed and get it operational.

15 CHAIR HANSON: Okay. You know, it -- I'll leave it to you 16 about when the -- when the ripeness of that draft is ready, but I think delivering 17 that to the Commission would be helpful, and actually having a CA brief on it 18 as well about that roadmap would be -- would be greatly appreciated on this.

19 So thank you.

20 You know, it's funny, I'm at this place again where I guess, 21 Mirabelle, I'll just go to you real briefly. You know, one of the things that -- one 22 of the slides I think we didn't get to with Dr. Lyman at the end of the last slide 23 was about safeguards by design. And I'm interested in that, about how those 24 principles are going to kind of be reflected then, in design reviews, whether

113 1 we're talking about design certification or whether we're actually talking about 2 design reviews, reactor systems analyses, you know, in Part 53 or 52 or 50, 3 or whatever. So could you talk to me a little bit about that?

4 MS. SHOEMAKER: So the staff agrees with the 5 Commission about having these conversations about safeguards by design 6 early with developers. The principles are not articulated directly in the 7 regulations, but -- so they're not considered under the application review, 8 which is a challenge.

9 And that's why, as we said earlier in our presentations, that 10 we're looking towards utilizing those in-person meetings and having early 11 discussions with the developer, so we can underscore the importance of 12 safeguards by design considerations early on. It promotes the safety 13 principles, but it also -- it actually facilitates the application of safeguards more 14 early on. Since safeguards follows the process, the flow of material, these 15 considerations could happen on the front end, and then it makes the 16 application much easier on -- once the site is operational.

17 CHAIR HANSON: Well, I'll just put you on the spot and 18 kind of ask you, I mean, as you noted, right, safeguard by design isn't in the 19 regulations. Should it be? You can defer to Dan or anybody. You 20 can -- you can phone a friend on that.

21 (Laughter.)

22 CHAIR HANSON: I'm sorry. That's what --

23 MS. SHOEMAKER: There are superiors who have had 24 that conversation well before me to consider.

114 1 CHAIR HANSON: Yeah.

2 MS. SHOEMAKER: I mean, at this point, 3 safeguards -- domestic safeguards follow international safeguards protocols.

4 And our domestic safeguards are very adequate and robust, and they inform 5 our application of --

6 CHAIR HANSON: Okay.

7 MS. SHOEMAKER: -- international safeguards in '75. So 8 I would say right now, you know, we are prepared to be able to license and 9 implement safeguards at -- for applications that we receive, and, you know, 10 whatever happens down the pike, I'll be here to support it, but -- yeah.

11 CHAIR HANSON: For the record, I have no -- I have no 12 problem with that answer, right, because of all of the other things that we've 13 heard about today about how we're accounting for these issues in other places 14 that kind of, in a sense, add up to a safeguards of security by design, almost 15 kind of review, right, where we're -- when we're talking about MC&A and other 16 kinds of things. So I don't want you to think that -- that I was -- it was a 17 genuinely honest question for you on that. With that, I will just -- I think I 18 will -- I will surrender or otherwise yield my time to Commissioner Baran.

19 COMMISSIONER BARAN: Well, thank you for your 20 presentations and for your work to get NRC ready to review advanced reactor 21 fuel applications. It has been a good discussion, so I also will try to be brief 22 and get folks to lunch. Chris, you mentioned NRC's collaboration with the 23 Canadian Nuclear Safety Commission to develop a joint position paper on 24 TRISO fuel qualification. I think that kind of technical cooperation could be

115 1 very valuable. Can you give us a quick update on that effort?

2 MR. VAN WERT: Yes. So, so far we have released two 3 interim reports. I believe we are finishing up the third interim report right now.

4 I know we provided a draft in the last advanced reactor stakeholders' meeting.

5 I believe the schedule for the final report is sometime next year, so we're well 6 on our way for that.

7 And, yes, it is -- I saw the hand reaching for the -- so the -- I 8 would say that we found it to be very useful from the standpoint that we're able 9 to leverage the experience of experts on their side of the border as well as 10 ours. And then it also provides a benefit to the applicants who might want to 11 license a reactor on both sides. So --

12 MR. TAYLOR: Yeah. So the schedule is the third interim 13 report by the end of this month, and then trying to tie it all up by March of next 14 year. And this is a great example where we've expanded the MOC just a little 15 bit and invited our O&R colleagues from the U.K. to observe this activity, 16 because there are TRISO uses envisioned in the U.K., although the form is 17 slightly different in what they're going to do in U.K. So it's a good opportunity 18 to continue to foster international cooperation.

19 COMMISSIONER BARAN: Great. Let me ask a broad 20 question about research, and this could be Wendy or Rob or whoever makes 21 sense. You know, there's obviously a lot of research going on outside of NRC 22 on advanced reactor fuels. We heard a bit about that on the last panel.

23 Does the staff see any research gaps that NRC needs to fill in the short term 24 to be ready? Is there research we should be doing to better prepare for the

116 1 applications we are expecting? And I don't know whether the shutdown of 2 Holden has any kind of effect on that outlook. Any thoughts there? Any 3 gaps we're seeing?

4 DR. REED: I can take that question. Well, as you know, 5 the advanced reactor environment is extremely varied. You know, the 6 different designs, the different stages of development, and so it's a very 7 dynamic environment. So to answer your question, it is very hard to pinpoint 8 something that, you know, is near-term. I mean, we are constantly -- because 9 of this dynamic environment, we are constantly revising our research priorities 10 and our research needs. You know, we are obviously looking to leverage as 11 much information, coordination, that we can.

12 For example, we have utilized a lot of data from the 13 molten-salt reactor experiments which operated in the 1960s at Oak Ridge, 14 but we are also leveraging DOE programs on metallic fuels and TRISO fuels 15 that are ongoing now, so that, you know, we have the best information to make 16 good decisions regarding research priorities.

17 As to your question about Holden, the NRC's, you know, 18 Research is looking for opportunities to get -- you know, other places to get 19 irradiation data. One good example is the NEA International Framework, 20 FIDES -- I hope I have pronounced that correctly -- the Framework for 21 Irradiation Data, which really seeks to help that gap with fuels and materials 22 testing data and to facilitate coordination and the utilization of international 23 facilities throughout the world to collect experimental data.

24 COMMISSIONER BARAN: Okay. Great. Well, I could

117 1 go on, but I'm not going to. I am just going to stop there, and we can move 2 on with our day.

3 (Laughter.)

4 CHAIR HANSON: It's a target-rich environment. I 5 completely agree. Well, thank you all very, very much, for a set of very 6 engaging presentations, a lot of really good information. I think, as usual, we 7 have -- we have touched on a lot of really important issues from staffing to 8 data requirements to requisite analytical capabilities, international 9 cooperation, et cetera. Thanks again to our external panel. Very much 10 appreciate everyone's participation and engagement today. With that, we're 11 adjourned.

12 (Whereupon, the above-entitled matter went off the record 13 at 12:29 p.m.)