ML24039A164

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Uiuc – Safety Evaluation for Topical Report Related to Event Sequence Identification and Safety Classification Methodology (EPID No. L-2023?NFN?0011)
ML24039A164
Person / Time
Site: 99902094
Issue date: 03/07/2024
From: Holly Cruz
NRC/NRR/DANU/UNPL
To: Brooks C
University of Illinois
Edward Helvenston, NRR/DANU
References
EPID L-2023-NFN-0011
Download: ML24039A164 (1)


Text

Dr. Caleb S. Brooks, Associate Professor Department of Nuclear, Plasma, and Radiological Engineering University of Illinois at Urbana-Champaign Talbot Laboratory, Room 111C, MC-234 104 South Wright St.

Urbana, IL 61801

SUBJECT:

UNIVERSITY OF ILLINOIS AT URBANA-CHAMPAIGN - SAFETY EVALUATION FOR TOPICAL REPORT RELATED TO EVENT SEQUENCE IDENTIFICATION AND SAFETY CLASSIFICATION METHODOLOGY (EPID NO. L-2023NFN0011)

Dear Dr. Brooks:

By letter dated September 7, 2023, the University of Illinois at Urbana-Champaign (UIUC) submitted the topical report (TR) University of Illinois Urbana-Champaign High Temperature Gas-cooled Research Reactor: Event Sequence Identification and SSC Safety Classification Methodology, Revision 0 (Agencywide Documents Access and Management System Accession No. ML23250A318) for U.S. Nuclear Regulatory Commission (NRC) staff review. As part of its review of the TR, the NRC staff sent requests for additional information (RAIs) to UIUC by email dated December 19, 2023 (ML23354A009). By letter dated January 17, 2024 (ML24017A307), UIUC submitted responses to the RAIs, including marked-up pages with proposed edits to the TR. UIUC submitted Revision 1 of the TR, incorporating the proposed edits, by letter dated February 20, 2024 (ML24053A336).

The NRC staffs safety evaluation (SE) for the TR, Revision 1, is enclosed. The enclosed SE will be made publicly available.

The NRC staff requests that UIUC publish an accepted version of the TR within 3 months of receipt of this letter. The accepted version should incorporate this letter and the enclosed SE after the title page. The accepted version should include an -A (designating accepted) following the TR identifier.

March 7, 2024

C. Brooks If you have any questions, please contact Edward Helvenston at (301) 415-4067, or by email at Edward.Helvenston@nrc.gov.

Sincerely, Holly D. Cruz, Acting Chief Non-Power Production and Utilization Facility Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation Project No.: 99902094

Enclosure:

As stated cc: GovDelivery Subscribers Signed by Cruz, Holly on 03/07/24

ML24039A164 NRR-106 OFFICE NRR/DANU/UNPL/PM NRR/DANU/LA NRR/DANU/UTB1/BC NAME EHelvenston NParker GOberson DATE 02/12/2024 02/13/2024 02/14/2024 OFFICE OGC/NLO NRR/DANU/UNPL/BC(A)

NAME JWachutka HCruz DATE 03/01/2024 03/07/2024

Enclosure UNIVERSITY OF ILLINOIS AT URBANA-CHAMPAIGN - SAFETY EVALUATION OF REVSION 1 OF TOPICAL REPORT UNIVERSITY OF ILLINOIS URBANA-CHAMPAIGN HIGH TEMPERATURE GAS-COOLED RESEARCH REACTOR: EVENT SEQUENCE IDENTIFICATION AND SSC SAFETY CLASSIFICATION METHODOLOGY (EPID NO. L-2023-NFN-0011)

APPLICANT INFORMATION Applicant:

University of Illinois at Urbana-Champaign Applicant Address:

104 South Wright St.

Urbana, Illinois 61801 Docket /Project No(s).:

99902094 APPLICATION INFORMATION Submittal Date: September 7, 2023 Submittal Agencywide Documents Access and Management System (ADAMS) Accession No.: ML23250A318 (Reference 1)

Supplement and Request for Additional Information (RAI) response ADAMS Accession Nos.: ML24017A307 (Reference 2); ML24053A336 (Reference 3)

Brief Description of the Topical Report: The topical report (TR) University of Illinois Urbana-Champaign High Temperature Gas-cooled Research Reactor: Event Sequence Identification and SSC Classification Methodology, Revision 1 (Reference 3), describes the event sequence identification methodology and safety classification methodology to be applied to the University of Illinois at Urbana-Champaign (UIUC) Micro Modular Reactor (MMR) research reactor. UIUC would utilize these two methodologies when providing details of design aspects of the MMR, designed by Ultra Safe Nuclear Corporation, in a preliminary safety analysis report and final safety analysis report for the proposed UIUC MMR.

As discussed in TR section 2.1, UIUCs stated purpose of the event sequence identification methodology in the TR is to identify event sequences for the UIUC MMR safety analysis that will be intended to meet Title 10 of the Code of Federal Regulations (10 CFR) 50.34(a)(4). As discussed in TR section 2.3, the elements of the event sequence identification methodology are:

identifying postulated initiating events (PIEs), screening PIEs on a deterministic basis, defining event sequences, and grouping event sequences into accident categories, guided by NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors (Reference 4), that have been adapted for use in the high-temperature gas-cooled MMR. TR section 2.3.1 describes PIE identification as a three-phase process: an initial phase that provides a list defined through historical information, regulatory documentation, and engineering judgement; a top-down phase that determines causes by analyzing design function trees created from master logic diagrams (MLDs); and a bottom-up phase to verify that a more developed design can result in the identified PIE.

As discussed in TR section 3.1, in preparation for the submission of construction permit (CP) and operating license (OL) applications, UIUC has identified requirements in 10 CFR 50.34(a)(4) and 10 CFR 50.34(b)(4) for analyses and evaluation of structures, systems, and components (SSCs). UIUC also details in TR sections 3.2 and 3.3 its intended method for identification of SSCs. SSCs will be categorized as either safety-related (SR) or non-safety-related (NSR). SSCs that have been connected to the reliable operation of safety functions will be defined as SR SSCs. The methodology for safety classification of SSCs will be performed by identifying limiting event sequences connected to safety classification, listing the required SSCs to fulfill a safety function during the developed event sequence, and assigning these identified SSCs as SR with all others as NSR.

For additional details on the submittal, refer to the documents available at the ADAMS Accession Nos. identified above.

EVALUATION CRITERIA As discussed in TR sections 1.0 and 1.4, UIUC plans to apply for licensing of the MMR design under the provisions of 10 CFR 50.21(c), as a Class 104(c) research reactor. Specifically, UIUC plans to provide CP and OL applications in the future for U.S. Nuclear Regulatory Commission (NRC) staff review to support licensing the construction and operation of the UIUC MMR, respectively. Because the MMR would be a non-light-water reactor (non-LWR), and the UIUC MMR would also be a Class 104(c) research reactor, the NRCs regulations specifically pertaining to light-water reactors (LWRs) may not be applicable. UIUC has submitted and the NRC staff is currently evaluating a separate TR entitled, University of Illinois Urbana-Champaign High Temperature Gas-cooled Research Reactor: Applicability of Nuclear Regulatory Commission Regulations (Reference 5). As of the date of this SE, the NRC staffs review of the regulatory applicability TR is still in progress.

To support the review of this TR, the NRC staff considered the regulations it expected to be applicable to the UIUC MMR based on insights from its review of the TR and from general information provided by UIUC regarding the proposed MMR in UIUCs Regulatory Engagement Plan submitted to the NRC by letter dated June 26, 2023 (Reference 6). The evaluation criteria section in this SE, continued below, describes regulations and guidance that the NRC staff determined to be appropriate to support the review and approval of this TR.

The regulations at 10 CFR 50.34(a)(3) require, in part, that applications for CPs include principal design criteria (PDC), which are discussed later in this SE section. In addition, the regulations at 10 CFR 50.34(a)(4) and 10 CFR 50.34(b)(4) require that CP and OL applications, respectively, include analyses and evaluation of SSCs. The NRC staff anticipates that an eventual UIUC MMR application would reference the contents of this TR and SE and would be subject to the provisions of 10 CFR 50.34. Therefore, the staff considered sections of 10 CFR 50.34, particularly 10 CFR 50.34(a)(3), 10 CFR 50.34(a)(4), and 10 CFR 50.34(b)(4), in reviewing the TR and developing this SE.

NRC Regulatory Guide (RG) 1.232, Guidance for Developing Principal Design Criteria for Non-Light-Water Reactors, Revision 0 (Reference 7), outlines example PDC formulated to be generally applicable to non-LWR designs. Appendix C of RG 1.232, in particular, contains a set of PDC specifically tailored to modular high-temperature gas-cooled reactor (MHTGR) designs, such as the MMR. RG 1.232 states that an applicant may use the RGs guidance to develop all or part of a reactor designs PDC. The proposed PDC for the UIUC MMR design is the subject of a separate TR, University of Illinois Urbana-Champaign High Temperature Gas-cooled Research Reactor: Micro Modular Reactor (MMRTM) Principal Design Criteria (Reference 8). As of the date of this SE, the NRC staffs review of the PDC TR is still in progress. In its PDC TR, UIUC generally applied the PDC developed for MHTGRs in appendix C of RG 1.232, with minimal adaptation as needed, to the UIUC MMR design. Although the staff has not made a final determination on the UIUC PDC TR, the staff considered the general characteristics of the proposed PDC in the PDC TR as well as in appendix C of RG 1.232 to inform its review of this TR. Two of the proposed UIUC PDC that the staff considered most applicable to the subject matter of this TR review are listed below (reproduced from Reference 8):

UIUC MMR PDC 2, Design bases for protection against natural phenomena, which states, in part, that [SSCs] important to safety shall be designed to withstand the effects of natural phenomena without loss of capability to perform their safety functions.

UIUC MMR PDC 10, Reactor design, which states that [t]he reactor system and associated heat removal, control, and protection systems shall be designed with appropriate margin to ensure that specified acceptable system radionuclide release design limits [SARRDLs] are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences [AOOs].

Additionally, the NRC staff noted that multiple other proposed PDCs in the UIUC PDC TR include specific information regarding the design of SSCs used to ensure that the consequences of postulated accident conditions do not exceed SARRDLs.

NUREG-1537, Part 1, Format and Content, and Part 2, Standard Review Plan and Acceptance Criteria, provide guidance for preparing and reviewing, respectively, applications for non-power reactors. The most relevant guidance with respect to this TR is contained in chapter 6, Engineered Safety Features, and chapter 13, Accident Analyses, of Parts 1 and 2.

In these chapters, NUREG-1537 describes, in part, the engineered safety features (ESFs) approach and how ESFs are identified for a design, if required, and incorporated in the safety analysis report (SAR). The approach includes identification and evaluation of postulated accidents, including a maximum hypothetical accident (MHA) for which potential consequences are shown to exceed and bound all credible accidents. These accidents are evaluated against the applicable regulatory limits regarding radiological consequences (e.g., public dose limits in 10 CFR Part 20). NUREG-1537, Parts 1 and 2, chapter 13, identifies some specific types of accident scenarios (e.g., reactivity insertion, loss of coolant) that should be discussed by the applicant in the SAR.

TECHNICAL EVALUATION Scope of Review Section 1.5 of the TR requests NRC review and approval of the methodologies presented in TR sections 2 and 3. Therefore, TR sections 2 and 3 were the focus of the NRC staffs review as summarized in this SE. Section 2 of the TR describes the methodology that UIUC plans to use to identify the event sequences that will be evaluated and described in the UIUC MMR safety analysis that will be provided as part of future licensing submittals. TR sections 1.4 and 2.1 state that the specific method(s) that UIUC will use to perform safety evaluations of the event sequences will also be subject to a future licensing submittal. Section 3 of the TR describes the methodology that UIUC plans to implement to determine the appropriate safety classification of the UIUC MMR SSCs.

The NRC staff notes that TR section 1.5 states that preliminary lists of PIEs and SSC safety classifications are provided in TR appendices A and B, respectively, but that these appendices are for informational purposes only. Therefore, the staff did not consider the preliminary information in TR appendices A and B to be within the scope of its review, and makes no regulatory findings associated with the preliminary information in TR appendices A and B.

In addition, the NRC staff notes that the results generated by UIUC through its implementation of the methodologies described in the TR will be subject to future review as part of future licensing application(s). Therefore, ultimate approval of the implementation of the methodology, the event sequences that are identified, and the classifications that are assigned to UIUC MMR SSCs will be subject to the appropriate future licensing submittal(s), and is not provided in this SE. The staff accordingly imposed Limitation 1 on its approval of this TR. Limitation 1 is listed in the Limitation section of this SE.

Event Sequence Identification Methodology Section 2 of the TR describes the event sequence identification methodology, which is a process used to identify and assess PIEs throughout the development of the UIUC MMR design, screen the identified PIEs, and define and group the resulting event sequences.

PIE Identification As discussed in TR section 2.3.1, the event sequence identification process begins with identifying PIEs using a multi-phase approach. The initial phase considers historical and regulatory sources, and engineering judgement applied to the UIUC MMR conceptual design to establish a preliminary set of PIEs (included for informational purposes in TR appendix A). The next phase employs a top-down approach as the design becomes mature enough to support the approach. Specifically, the top-down phase uses MLDs to analyze three high-level fundamental safety functions: reactivity control, reactor heat removal, and control of release of radioactive material that could exceed public dose limits. The insights from these analyses are then used to confirm or extend the PIEs identified during the initial phase, leading to more specific initiating events.

TR section 2.3.1 states that the third phase of PIE identification employs a bottom-up approach when the design is sufficiently detailed such that failures can be more readily determined. This phase verifies and expands on the details that resulted from the top-down phase using unique methodologies for each type of PIE identified. The PIE types, defined in TR section 2.2.1, include piping system breaches, transients, and internal and external hazards. TR section 2.3.1 states that the bottom-up methodology related to piping system breaches assesses design description information to determine whether a breach can result in an AOO or accident conditions. For transients, the bottom-up phase consists of performing failure modes and effects analyses (FMEAs) to identify PIEs. TR section 2.3.1 states that details on the FMEA methodology and results will be provided in a future UIUC MMR OL application. The internal and external hazards methodologies will both rely on hazard analysis used to identify hazard-induced PIEs. TR section 2.3.1 states that details on the internal and external hazard analyses will also be provided in a future UIUC MMR OL application.

The NRC staff reviewed the above information and finds that the multi-phase approach for identifying PIEs described in the TR is acceptable on the basis that implementation of the approach can reasonably be expected to result in a sufficiently comprehensive list of PIEs that could be used to adequately identify limiting event sequences and appropriately identify required ESFs in alignment with the guidance described in NUREG-1537. Additionally, the staff notes that the iterative nature of the approach allows the list of PIEs to be expanded, as needed, as the details of the UIUC MMR design continue to be determined and/or finalized.

As noted above, the TR states that specific information regarding MLD, FMEA, and internal and external hazards analysis methodologies was not included in this TR but will be included in a future UIUC MMR OL application and be subject to future licensing review. The NRC staff acknowledges that the final methodologies and results obtained would be included in the review of a UIUC OL application. However, the staff notes that preliminary information regarding MLDs, FMEAs, and hazards analyses, beyond what is provided in this TR, may also be appropriate to be included as part of any future UIUC MMR CP application. The staff notes that such information could help to ensure that the proposed preliminary design adequately considers the appropriate PIEs and resultant event sequences, including those materially influenced by internal and/or external hazards.

PIE Screening As discussed in TR section 2.3.2, each PIE identified following the three-phase approach is then screened for credibility on a deterministic basis. PIEs related to SSC failures are evaluated based on the specifics of the failure and/or the engineering design rules applied to the SSCs.

For PIEs related to external hazards, the specifics of the external hazard assessment will also be considered. PIEs that are determined to not be credible are screened out of the remainder of the process. PIEs that do not have sufficient supporting information to screen out will be retained as part of the licensing basis, unless further information later supports a determination that the PIE is not credible.

The NRC staff reviewed the above information and finds that the approach of screening PIEs for credibility is acceptable because it is consistent with NUREG-1537 guidance that only credible events should be considered and grouped when identifying limiting event sequences.

Additionally, the staff notes that NUREG-1537 guidance regarding non-credible events is limited to establishing an MHA, which is not within the scope of this TR review. The staff expects that, consistent with the approach discussed in NUREG-1537, the screening of PIEs for credibility can reasonably be performed on a deterministic basis through the application of appropriate engineering principles. However, the staff also expects that any future licensing submittal detailing the results of the PIE screening process would likely need to describe the deterministic bases used to conclude that screened PIEs are not credible. The staff also notes that the acceptability of the screening process results would be subject to the review of that submittal.

Defining and Grouping Event Sequences As discussed in TR section 2.3.3, after PIEs are identified and screened, the remaining credible PIEs are used to determine which SSCs are required to mitigate the consequences of the PIEs.

The safety classification methodology is used to establish which SSCs are considered SR. The SR SSCs associated with the PIEs then determine the plant response to each PIE (or combination of PIEs) to define event sequences. Safety analyses will be performed on the event sequences, considering the worst-case single failure of an active component. Additionally, as discussed in TR section 2.3.4, the event sequences will be grouped into categories that largely align with those listed in NUREG-1537, with some adaptation to accommodate the MMR design, as summarized in TR table 2-1. UIUC states in TR section 2.3.4 and its response to RAI-2 (Reference 2) that limiting event sequence(s) will be identified for each event sequence group.

Event sequences bounded by a limiting event sequence will rely upon the same SSCs; event sequences that rely on differing sets of SSCs will have different limiting event sequences identified. Therefore, event sequence groups may result in multiple limiting event sequences, such that all SSCs performing safety functions will be identified during implementation of the safety classification methodology.

The NRC staff reviewed the above information and finds the described approach of defining and grouping event sequences to be acceptable on the basis that it aligns with the approach and guidance provided in NUREG-1537, Parts 1 and 2, chapters 6 and 13, including the guidance that accident scenarios should be categorized by type and likelihood of occurrence, and that limiting events should be identified for each group. The staffs review of the safety classification methodology for UIUC MMR SSCs (TR section 3) is discussed in the next SE section.

The NRC staff notes that TR table 2-1 includes an MHA but the methodology to determine and analyze that MHA is not included in the TR. However, TR section 1.4 explains that the methodology to identify and evaluate the MHA will be subject to a future licensing submittal.

Therefore, the staff finds that UIUCs general approach of identifying and analyzing an MHA is acceptable on the basis that it aligns with NUREG-1537 guidance, but the staff makes no determination regarding any specific MHA sequence or methodology for identification or evaluation of the MHA in this SE.

Safety Classification of SSCs Section 3 of the TR defines two safety classification groups, SR and NSR, and describes UIUCs methodology used to classify each UIUC MMR SSC into one of the groups. Additionally, section 3 of the TR defines the term safety function and lists three fundamental safety functions for SR SSCs in the UIUC MMR.

Safety Functions The term safety function is defined in TR section 3.2.1 as a specific purpose that must be accomplished for safety for a facility or activity to prevent or to mitigate radiological consequences of normal operation, anticipated operational occurrences, and accident conditions. The NRC staff finds that this definition is acceptable on the basis that it aligns with previous such definitions associated with other existing research reactors, and that the definition provides enough specificity to ensure that appropriate safety functions can be identified.

Three fundamental safety functions are identified in TR section 3.2.1 for the UIUC MMR SR SSCs: control of reactivity (including reactor shutdown), removal of heat from the reactor, and control of release of radioactive material that could exceed public dose limits. The NRC staff finds that the fundamental safety functions identified are acceptable on the basis that they appear to represent a reasonable set of functions that could be used to support the UIUC MMR safety classification methodology and definition of SR. Specifically, the staff finds that the three safety functions identified appear to form a sufficiently comprehensive basis to evaluate the performance of SSCs during PIEs and identify those SSCs that should be classified as SR, consistent with the guidance in NUREG-1537. Additionally, the staff notes that, while not specifically applicable to the UIUC MMR, the 10 CFR 50.2 definition of SR SSCs includes a list of functions that is similar, although tailored to LWRs. This similarity between the approaches further supports the staffs finding that the UIUC approach is reasonable and acceptable.

Safety Classification Groups As discussed in TR section 3.2.2, the UIUC MMR safety classification methodology includes two classifications: SR and NSR. SSCs that have an impact on safety and are relied upon to remain functional to meet at least one of the three fundamental safety functions during and following all event sequences that are part of the plant design basis are considered SR. All other SSCs are considered NSR. In its response to RAI-1 (Reference 2), UIUC clarified that shutdown from normal operation is encompassed by the fundamental safety function of control of reactivity, and, therefore, SSCs relied upon for normal shutdown (and not only those needed, for example, to maintain the reactor shutdown during and following an event sequence) would be included as SR. The NRC staff finds that the definitions provided for the terms SR and NSR are acceptable on a basis similar to that discussed in the previous SE section related to safety functions.

Specifically, the staff finds that the definitions reasonably align with research reactor precedents, provide adequate specificity, can be expected to adequately support the implementation of the UIUC MMR safety classification methodology, and generally reflect the analogous 10 CFR 50.2 definition of SR SSCs for LWRs.

Safety Classification Methodology TR section 3.3 discusses the overall safety classification methodology for the UIUC MMR. The methodology used to classify UIUC MMR SSCs begins with the identification of PIEs, and then limiting event sequences, as described in TR section 2. As discussed in TR section 3.3.2, the limiting event sequences will then be evaluated considering the three fundamental safety functions to identify the SSCs that are required to achieve those safety functions. As discussed in TR section 3.3.3, all SSCs that are identified as required to provide one or more of these fundamental safety functions will be classified as SR. The remaining SSCs will be classified as NSR.

In its response to RAI-2.a (Reference 2), regarding how UIUCs limiting event sequences would be determined to be limiting, UIUC clarified that radiological consequence or other surrogate characteristics (i.e., fuel temperature, helium pressure, etc.) would be used as a figure of merit.

The NRC staff reviewed the above information and finds that the overall safety classification methodology described by UIUC is acceptable on the basis that it aligns with the definitions provided in the TR and the guidance provided in NUREG-1537 and, therefore, can be expected to result in UIUC MMR SSC classifications that can be consistent with the regulations and guidance discussed in the Evaluation Criteria section of this SE.

An example of an event sequence evaluation (associated with a pipe break PIE) is provided in TR section 3.3.2. The NRC staff notes that the example appears to demonstrate event sequence evaluation methodology described in the TR in a reasonable manner, but the staff makes no determination on the specific details of the example PIE itself due to the preliminary nature of the information. In addition, TR section 1.5 states that this example is provided for information purposes only.

LIMITATION The NRC staff imposes the following limitation on the acceptance of this TR:

1.

The NRC staff finds the methodology described acceptable on the basis that the presented approach appears to be a reasonable way to identify event sequences and classify SSCs. However, the staff notes that the methodology is iterative in nature as the design process continues, and has not yet been fully implemented, and the resulting SSC safety classifications, event sequences, and PIEs have not yet been finalized.

Therefore, the staffs approval is limited to the methodology approach itself. Approval of the specific implementation of the methodology and the resulting event sequences and SSC classifications obtained as they pertain to the UIUC MMR would be subject to future licensing submittals.

CONCLUSION The NRC staff concludes that UIUC TR University of Illinois Urbana-Champaign High Temperature Gas-Cooled Research Reactor: Event Sequence Identification and SSC Safety Classification Methodology provides acceptable methodologies to identify PIEs and limiting event sequences, and to classify UIUC MMR SSCs depending on their involvement in the identified limiting event sequences. The staff based this conclusion on the alignment between the proposed approach and the applicable guidance in NUREG-1537. Specifically, the staff determined that the methodologies described in the TR represent a well-defined approach that could reasonably be expected to be implemented in a manner that would align with the intent of the NUREG-1537 guidance and be consistent with the requirements of the portions of 10 CFR 50.34 discussed in the Evaluation Criteria section of this SE. Approval of this TR is subject to Limitation 1 in the above SE section.

REFERENCES 1.

Letter from UIUC to NRC, Submittal of University of Illinois Topical Report, Event Sequence Identification and SSC Safety Classification Methodology, dated September 7, 2023 (ML23250A318).

2.

Letter from UIUC to NRC, Written communication as specified by 10 CFR 50.4 regarding responses to the Request for Additional Information - University of Illinois Urbana-Champaign High Temperature Gas-cooled Research Reactor: Event Sequence Identification and SSC Safety Classification Methodology, Topical Report, dated December 19, 2023, dated January 17, 2024 (ML24017A307).

3.

Letter from UIUC to NRC, Submittal of the revised University of Illinois Urbana-Champaign High Temperature Gas-cooled Research Reactor: Event Sequence Identification and SSC Safety Classification Methodology Topical Report, Release 02, dated February 20, 2024 (ML24053A336).

4.

NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, Part 1, Format and Content, and Part 2, Standard Review Plan and Acceptance Criteria, dated February 1996 (ML042430055 and ML042430048).

5.

Letter from UIUC to NRC, University of Illinois Topical Report Submission, University of Illinois Urbana-Champaign High Temperature Gas-cooled Research Reactor:

Applicability of Nuclear Regulatory Commission Regulations, dated December 9, 2022 (ML22343A282).

6.

Letter from UIUC to NRC, USNRC Project No. 99902094: UIUC Regulatory Engagement Plan revision submission, dated June 26, 2023 (ML23178A259).

7.

NRC Regulatory Guide 1.232, Guidance for Developing Principal Design Criteria for Non-Light-Water Reactors, Revision 0, dated April 2018 (ML17325A611).

8.

Letter from UIUC to NRC, Submittal of University of Illinois Urbana-Champaign High Temperature Gas-cooled Research Reactor: Micro Modular Reactor (MMRTM) Principal Design Criteria Topical Report, dated November 15, 2023 (ML23319A407).

Principal Contributors:

D. Beacon, NRR L. Kingsbury, NRR Date: March 7, 2024