ML24031A628
| ML24031A628 | |
| Person / Time | |
|---|---|
| Site: | 99902094 |
| Issue date: | 01/24/2024 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML24031A626 | List: |
| References | |
| EPID L-2022-NFN-0008 | |
| Download: ML24031A628 (1) | |
Text
Public Meeting with the University of Illinois at Urbana-Champaign Regarding Applicability of Regulations Topical Report January 24, 2024
Introductions
2
Agenda
- Review requested action and proposed methodology
- Identify areas for discussion
- Discuss example regulations
- 10 CFR 50.44, Combustible gas control for nuclear power reactors
- 10 CFR 50.68, Criticality accident requirements
- Open discussion
- Questions 3
UIUC Requested NRC Review and Approval of:
- The process for determining applicability of regulations to the UIUC micro modular reactor (MMR)
- Applicability/non-applicability of specific regulations identified in the topical report as the licensing basis for the MMR at UIUC
- The methodology for identifying and justifying regulatory exemptions 4
Methodology (Table 5.1) 5 Step How Applicability of Regulations Evaluated 1
Search 10 CFR 50 Parts 1 to 199 for key distinguishing terms such as "non-power, "NPUF," power plant, "water-cooled, "pressurized water," etc. to identify entry conditions to create a list of potentially excluded regulations.
2 Compare to Kairos TR test reactor list and the NRC response and reconcile differences.
3 Compare to guidance in the NRC staff draft white paper tables
- 1) 10 CFR 50 regulations potentially applicable to non-LWRs [Table 2 addresses Part 52]
- 3) Regulations other than 10 CFR 50 and 52
- 4) 10 CFR 50.34(f) TMI requirements
- 5) areas with anticipated exemptions Reconcile differences.
4 Compare to NUREG-1537 Appendix A listing of regulations applicable to nonpower reactors, including test reactors and reconcile differences.
5 For a few regulations where some question remained, review licensed research reactor safety analysis and evaluation reports and/or look for other NRC guidance.
Discussion Topics
- Principles applied to resolve differences in entry conditions described in the regulation heading, regulation text, and associated Federal Register notice.
- Consideration applied to date of either issuance or significant revision to regulation during comparison with guidance (i.e., NUREG 1537) within topical report.
- Principles applied to resolve differences with other sources of relevant information, including the Kairos Power LLC Topical Report, Regulatory Analysis for the Kairos Power Fluoride Salt-Cooled High Temperature Reactor - TR, Revision 4 (ML22018A161).
6
10 CFR 50.44, Combustible Gas Control
- Initially issued in 1978 to ensure margin for degraded cooling system mitigation of design basis loss of coolant accidents
- Amended in 1980s to address post-TMI concerns with degraded core accidents in large light-water reactors
- Selected as pilot regulation for risk-informed initiative (SECY 00-0086); proposed rule addressed large light-water reactors
- Revised 2003 regulation added paragraph (d) to address comment regarding non-water-cooled reactors (68 FR 54134)
- Both 50.34(g), which refers to 50.44, and 50.44(d) state applicability to all reactor applicants
- Burden of regulation is low if issue not technically relevant; containment reliability important to all reactors 7
10 CFR 50.68, Criticality Prevention
- Acts as a codified exemption to 10 CFR 70.24 for criticality monitoring requirements
- Statements of consideration (63 FR 63127) state applicability to holders of licenses to construct or operate light water power reactors
- As indicated in updated Staff White Paper addressing applicability of regulations to non-LWRs (ML21175A287):
the technical basis of 10 CFR 50.68 applies to LWR conditions (i.e., metal clad fuel in a water moderator) non-LWR applicants could provide similar criteria (i.e., similar to 10 CFR 50.68 (b)(1) through (b)(8)) for specific non-LWR fuel designs through specific exemptions
- 10 CFR 70.17 provides for specific exemptions from Part 70 8
- Open discussion
- Questions 9