ML24067A282
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| Issue date: | 03/07/2024 |
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Text
1
UNITED STATES
NUCLEAR REGULATORY COMMISSION
+ + + + +
MEETING: UPDATE ON RESEARCH AND TEST REACTORS
REGULATORY PROGRAM
+ + + + +
THURSDAY,
FEBRUARY 22, 2024
+ + + + +
The Commission met in the Commissioners' Hearing Room,
at 9:02 a.m. EST, Christopher T. Hanson, Chair, presiding.
COMMISSION MEMBERS:
CHRISTOPHER T. HANSON, Chair
DAVID A. WRIGHT, Commissioner
ANNIE CAPUTO, Commissioner
BRADLEY R. CALDWELL, Commissioner
ALSO PRESENT:
CARRIE M. SAFFORD, Secretary of the Commission
BROOKE P. CLARK, General Counsel
2
EXTERNAL PANELISTS:
AMBER JOHNSON, Secretary, National Organization of Test, Resear ch
and Training Reactors and Director, Nuclear Reactor
and Radiation Facilities, University of Maryland
RUSTY TOWELL, Director, Nuclear Energy eXperimental Testing (NE XT) Lab
Abilene Christian University
CALEB BROOKS, Director, Illinois Microreactor RD&D (IMRD2) Cent er
University of Illinois at Urbana-Champaign
ANDREW BOULANGER, University Fuel Services Program Manager,
Department of Energy (DOE)
JOANIE DIX, Deputy Director, Office of Conversion
National Nuclear Security Administration (NNSA)
NRC STAFF:
SCOTT MORRIS, Deputy Executive Director for Reactor and Prepare dness
Programs
ROB TAYLOR, Deputy Director for New Reactors and Advanced React ors
JOSH BORROMEO, Branch Chief
REBECCA OBER, Security Specialist (RTR)
HOLLY CRUZ, Senior Project Manager
AMY BEASTEN, RTR Examiner CONTENTS 3
PROCEEDINGS
(9:02 a.m.)
CHAIR HANSON: Good morning, everyone. I convene the
Commission's public meeting on the NRC's Research and Test Reac tor
Regulatory Program, including medical isotope facilities and their interface with
advanced reactors.
We sometimes refer to facilities under this program as non-
power production or utilization facilities, or, colloquially, N PPUFs. Ensuring a
robust NPPUF program is important to our nation on many levels, including
development of future nuclear workforce, supporting neutron research, medical
isotope production, as well as acquiring data to support new re actor and other
technologies.
I look forward to engaging in a fruitful dialogue and receiving
feedback on our regulatory program this morning.
We have two panels today, and we will hear from our external
panel first. Following that, we 'll have a short break, and then we'll hear from the
NRC staff.
Before we start, I'll ask my colleagues if they have any
remarks they'd like to make.
Okay. So with that, we'll begin with our external panel. We'l l
proceed in the order you all are listed on the public notice of the meeting. We
will begin with Ms. Amber Johnson, who is Secretary of the Nati onal
Organization of Test, Research, and Training Reactors, and the Director of
Nuclear Reactor and Radiation Facilities at the University of M aryland.
Ms. Johnson, the floor is yours.
MS. JOHNSON: Perfect. Okay. Cool. Good morning, Chair,
Commissioners, my fellow panelists, and all that are participating either virtually 4
on in person. On behalf of the National Organization of Test R esearch and
Training Reactors, I would like to thank you for this opportuni ty to provide an
overview of the existing facilities, including our regulatory a nd operational
experiences.
Next slide, please.
The National Organization of Test Research and Training
Reactors, or TRTR, represents the shared interests of research reactors
operated by the government, national labs, universities, and in dustry. TRTR
membership includes directors, managers, and operators at research reactors,
along with educators, administrators, regulators, research scie ntists, and
engineers.
TRTR's primary mission is to coordinate the sharing of
operating experiences related to the use of research reactors f or education,
training, and research.
Next slide, please.
As a member of TRTR, you gain access to a shared
knowledge base of best practices and expert advice. We have a quarterly
newsletter that is sent to our email Listserv and published on our website that
tracks inspection reports, along with any violations or finding s, reportable
occurrences, and follow-up corrective actions, and also relevan t
communications from agencies with scientific and technical expe rtise in the
nuclear field.
So member facilities may request an audit or peer review of
their operations by contacting our Executive Committee, who wil l convene a
group of experts to identify and propose program improvements. Our members
also work hard to develop and refine ANSI ANS Series 15 standar ds that cover
topics like the selection and training of personnel and the format and content for 5
safety analysis reports.
But perhaps our most important forum for the exchange of
information is our annual meeting. Each year TRTR members gath er near a
host facility to share our skills, procedures, and experiences in operating our
non-power reactors.
Next slide, please.
So research reactors provide excellent educational and
training opportunities for staff, students, and researchers, as well as radiation
protection and regulatory personnel. These reactors offer well -understood
environments for experiments designed to study the behavior of materials
through the interaction of neutrons and other forms of ionizing radiation.
In addition to enabling critical research in many disciplines,
research reactors are crucial for workforce development through reactor
operations, engaging the public on the peaceful uses of nuclear power, and the
development of advanced reactor technologies.
With 30 research and test reactors currently licensed by the
NRC, we make up about 25 percent of active NRC licenses. Certa inly, this is a
number we would like to see increase. We also hold approximate ly 350
operator licenses, almost 10 percent of current licensees. And a large portion
of these operator licenses are held by undergraduate students. These students
gain valuable experience with nuc lear safety culture and working in a regulated
environment, making them well-equipped to join the nuclear work force of the
future.
Next slide, please.
So TRTR appreciates the support of the NRC staff from the
Division of Advanced Reactors and Non Power Production and Util ization
Facilities to advance our shared goals of applying the minimum amount of 6
regulation necessary to provide adequate protection, public hea lth and safety,
to promote a common defense and security, and to protect the en vironment
from the Atomic Energy Act, as amended.
So I would like to highlight a recent collaboration that
produced guidelines for 10 CFR 50.59 implementation at non-power production
or utilization facilities and led to endorsement in a regulator y guide.
Building upon the success of this document, the working
group has drafted expanded guidelines to include digital I&C, w hich is currently
under review. Prior to this, the only guidance that existed wa s for powerplants
and not at all applicable to research and test reactors.
We also maintain an open line of communication through the
use of quarterly calls that track the progress of NUREGs, rulem akings, and
other items of shared interest. And for issues of particular s ignificance,
additional public meetings with a specific focus on research reactors have been
requested and were conducted.
I would also like to acknowledge the use of Phase 0 meetings
to ensure INPO staff and licensees have a clear understanding o f the licensing
request prior to submission of any documents. And, finally, I would like to
emphasize the importance of NRC Day at our annual meeting. Thi s is an
opportunity for TRTR members to engage with our project manager s and
inspectors in a collegial environment, and we hope to see every one at our
meeting next fall.
Next slide, please.
So a rulemaking that is of considerable interest to TRTR
members is the non-power production or utilization facility lic ense renewal, or
NPPUF rule. This rulemaking has been with the Commission for a lmost five
years, and we would like to understand what additional question s or concerns 7
prevent its approval.
The NPPUF rule would create a more efficient and responsive
renewal licensing process by rem oving the 20-year license renew al terms and
requiring that facilities submit an updated safety analysis rep ort every five
years. Finally, this rulemaking would establish an accident do se criterion that
takes into consideration the low-risk profile of research react ors rather than an
arbitrator 10 megawatt thermal power threshold.
The items in this rulemaking consider that research and test
reactors present a limited risk to the public and environment t hrough our
relatively simple but robust designs, low nuclear material inve ntory, small
physical size, and low power levels.
Next slide, please.
I look forward to today's discussion. Thank you.
CHAIR HANSON: Thank you, Ms. Johnson.
Next we'll hear from Mr. Rusty Towell. He is Director, Nuclear
Engineering eXperimental Testing Lab, the NEXT Lab, at Abilene Christian
University.
Dr. Towell.
DR. TOWELL: Good morning, Commissioners. I appreciate
the opportunity to be with you and to talk to you about the rol e of research and
test reactors in development of advanced reactor technologies.
Next slide, please.
NEXT Lab at Abilene Christian University stands for Nuclear
Energy eXperimental Testing. It's a lab whose mission is to pr ovide global
solutions to the world's needs for energy, water, and medical i sotopes by
advancing technology of molten salt reactors while educating fu ture leaders in
nuclear science and engineering.
8
What's shown on this picture is summer workforce from this
past summer at ACU. It was about 80 people -- undergraduates, faculty, staff --
working together. However -- next slide -- we're not doing thi s alone. We're
working as part of a research alliance.
So Abilene Christian University, along with the University of
Texas, Texas A&M, and Georgia Institute of Technology, are all brought
together by Natura Resources to essentially be the research and development
arm of that company to develop the molten salt reactors.
So, in 2022, we submitted our construction permit for the
molten salt research reactor, and we have a goal of making it o perational by
2026.
Next slide, please.
The molten salt research reactor is -- has safety built into it b y
its technology. There's many layers, starting with the salt, w hich will retain the
fuel and most of the fission fragments. Then that's surrounded by a primary
fueled salt loop pressure boundary, and then there is -- outside of that there is a
reactor thermal management system with a catch pan, so if there is any -- if it
ever leaked that would catch the leak of salt.
And outside that there is a reactor enclosure, another
pressure boundary, and following that is the reactor cell, whic h is a concrete
containment for biological shielding. Of course the whole syst em is low
pressure. It shuts down via a drain from the core, and passive heat removal
during shutdown, so it's inherently safe in its construction.
Next slide, please.
The molten salt research reactor is very, very similar to the
molten salt reactor experiment that was built at Oak Ridge in t he '70s. Shared
concepts include the same salt, the same fuel, graphite-moderat ed, loop 9
design, trench-based radiation protection, short lifetime, and low pressure.
We have simplified it in several areas to make it even easier
to license. We have dropped from high enriched uranium to belo w 20 percent.
We dropped the power down to 1 megawatt thermal, used nuclear qualified 316
as the primary construction material, removed the free valve, j ust using
pneumatic pressure to keep the salt and the fuel in the core, a nd we have --
therefore, the control rods aren't safety-related and there is no water in the
system. So all this together simplifies the reactor.
Next slide, please.
The plan is to install the molten salt research reactor in a
facility that was just constructed at ACU. It's the Science an d Engineering
Research Center. It's a 28,000-square-foot facility that has a research bay.
The 6,000-square-foot research bay has a major feature a trench that's 80 feet
long and 20 feet deep that's a primary spot for deploying advan ced reactors.
So this facility is truly the nation's first advanced reactor t est
bed site, and we are very excited to have it open on the ACU ca mpus.
Next slide, please.
So I gave you that background so that when I'm talking about
research and test reactors you know I'm kind of biased to the o ne that I'm
helping lead. But I think what I have to say is applicable to all research and test
reactors in how they help prepare for advanced reactors.
The first thing I would say is that you really can decrease the
risk for advanced reactor deployment if we start with smaller, safer research
and test reactors. And several ways we can decrease the risk, there is of
course the risk to -- of a regulatory risk. Can we get a licen se for a reactor?
And that's a risk that is maybe not as big a concern for this
room, but it's a concern for people to want to fund the technol ogy. So investors 10
and financers are very concerned on whether or not we can -- we can license it.
So demonstrating that we can license a research and test react or will give
them confidence that the NRC can license a non-light-water reac tor.
And then when we think about licensing a commercial reactor,
where the source term will be higher, we need to have better da ta. And so to
move beyond the sort of minimal requirement required for a rese arch reactor
means we need to collect better data on materials and fuel and the way the
reactor operates.
Ms. Johnson mentioned the current research reactors are
well-defined environments, and that's true. The current resear c h reac tors are
very, very well understood. The research reactor we're buildin g is not so well
understood, but that's the point of building it, so we can unde rstand it, collect
the data, and use that data to help deploy advanced reactors. And that's
precisely the reason why Natura Resources is sponsoring the work, so that they
can collect the data and move on to commercial deployment.
The second area of risk is risk to the supply chain. Obviously,
if we build something, it tests the supply chain out. Can we g et the materials,
the raw materials? Can we get the components? Are vendors wil ling to design
new components? And if you demonstrate that there's a need for it, that's
helpful.
And then a third risk I would mention is a risk of, do we have a
qualified nuclear workforce? And also, as mentioned in the previous talk, these
reactors, these research and training reactors, do just that. They train the
future generation of reactor workers. So whether we're talking about qualified
nuclear workforce for being regulators or reactor designers or operators, we
need more sites where we can train advanced reactor operators.
And so we're -- that's another purpose for -- of building 11
starting with research and test reactors before moving straight to commercial
reactors.
And the final thing I would say is that by actually building
some of these advanced reactors, we will be able to see that nu clear reactors
can do more than just produce electricity. I think in the past we have used --
commercial reactors have primarily been used only to produce el ectricity, but
new higher temperature reactors, like our molten salt research reactor, will be
able to produce high temperature process heat that will allow u s to serve the
needs of many different industry partners that need that high p rocess -- high
temperature process heat.
We will also be able to produce medical isotopes and
isotopes for nuclear batteries and other purposes, and so we'll be able to show
and demonstrate the multi-functional purpose of advanced reacto r.
And so because of these -- because of all -- because we can
achieve all of this with a smaller source term, then that means we are -- it's a --
there is less risk involved through the whole process to start with a research
and test reactor.
Next slide, please.
I'll show this slide from Idaho National Lab. It shows the
deployment of advanced reactors. I modified it by adding the A CU SERC on
the very bottom left. That's the first of the test beds, follo wed by Dome and
Lotus at Idaho. But what I'll see on this is that many -- many, if not all, reactor
developers have come back off of their desire to first deploy a commercial
reactor and have come with a smaller reactor.
So TerraPower is coming in with MCRE to gain the data and
experience. Kairos is developing Hermes. Natura has always st arted with a
desire to build a research and test reactor. So you see the mo lten salt research 12
reactor on this deployment path.
So I think that research and test reactors have a huge role to
play in developing advanced reactors.
Next slide?
I thank you for your time, and I look forward to discussion.
CHAIR HANSON: Thank you very much, Mr. Towell.
Next we will hear from Mr. Caleb Brooks. He is the Director of
the Illinois Microreactor RD&D Center at the University of Illi nois at Urbana-
Champaign.
Mr. Brooks?
MR. BROOKS: Thank you, Chair Hanson, and the
Commission, for the opportunity to join you today. At the Univ ersity of Illinois,
we believe that advanced reactors need advanced research reactors to lead the
way towards expanding safe, peaceful uses of nuclear power.
Our project is a partnership with Ultra Safe Nuclear
Corporation, USNC, to deploy a commercializable advanced reacto r on our
campus as an advanced research reactor. This MMR technology is a p r i s m a t i c,
gas-cooled reactor, TRISO fuel, is encapsulated into annular pe llets of silicon
carbide to provide superior performance and fission product ret ention.
The reactor will sit below grade as shown in the rendering,
adjacent to the existing campus power plant. Heat generation f rom the reactor
is transferred to a closed molten salt thermal storage system. From this
integrated thermal source system, energy can be dispatched in t he form of
steam through a steam generator. This thermal storage system e ffectively
decouples the reactor operations from the process heat side.
In our case, steam from the molten salt steam generator will
feed the main steam header of our existing campus power plant d emonstrating 13
the ability to integrate advanced reactor systems with existing fossil fuel
infrastructure. The campus power plant feeds the university-ow ned and
operated utility system, which demands roughly 60 megawatts of steam and 55
megawatts of electricity.
Our mission -- next slide, please.
Our mission is to de-risk advanced reactor technology
through education, research, and at-scale demonstration. New a dvanced
nuclear can enable a paradigm shift in all aspects of nuclear, how we build it,
how we operate it, how we regulate it, and utilize it. But it will require
deployment in a setting that can bring all stakeholders togethe r.
Next slide, please.
We have two core missions and a cross-cutting mission. Our
first core mission is educati on, training, and public engagement. New research
reactors are needed to train the advanced reactor workforce, bu t also, maybe
more importantly, new -- a new nuclear workforce will be requir ed at the
interface of new nuclear and new end use applications.
Furthermore, I believe that university reactors are
underappreciated for their role in public engagement. For nucl ear power, all
roads go through public engagement. This project has and will continue to
work towards redeeming public perception of nuclear power.
Our second core mission is research and development. Here
we are focused on the research needs that will enable a paradig m shift in
advanced nuclear deployment, including technology optimization, improved
modeling and simulation, new approaches to operation, including
instrumentation and controls that can address the operation and maintenance
challenges of the current nuclear fleet.
Our focus here is largely in the critical enabling technologies 14
around the reactor that can maximize safe economic deployment o f advanced
nuclear power.
Lastly, our cross-cutting mission of at scale demonstration is
really under the umbrella of education and research. This focu s is to perform
the necessary role of demonstrating the capability of advanced nuclear power
to address new markets that require clean energy, including mic ro-grids,
hydrogen generation, decarbonizing existing fossil fuel infrast ructure. Bottom
line is the world needs decarbonization without disruption.
And for many heavy energy users this can only be done with
nuclear. Moving nuclear power beyond just putting electrons on the centralized
grid will require education, research, and at-scale demonstrati on.
Next scale -- next slide, please.
These mission areas were inspired by the definition of
research in the Atomic Energy Act, which provide the guiding al lowable
activities for a 104(c) license. The mission areas, as describ ed, align with four
of the five definitions of research in Section 31.
I highlight Item 4, which includes the "demonstration of
advances in the commercial or industrial application of atomic energy," which is
the foundation of our cross-cutting mission for at scale demons tration and was
outlined in a white paper submitted to the NRC staff.
Next slide, please.
Lastly, here I summarize our pre application engagement to
date with NRC. Our safety methodology report has been delayed, but that is
the last of the plan documents to put in front of NRC for revie w. We have had
some delays, mostly due to design changes on our side.
Overall, our engagement with NRC has been very positive.
We found it to be very appropriate in the level of communicatio n. Requests for 15
additional information have been r easonable and very clearly stated. Flexibility
in scheduling and availability of the staff for public meetings has been
exceptional.
We have seen some turnover in our engagement from the
NRC staff, and in those cases it was very well executed.
Overall, I look forward to continuing interaction with NRC on
this project and hopefully submission of the construction permi t application this
year.
Thank you very much.
CHAIR HANSON: Thank you, Mr. Brooks, very much for your
presentation.
And next we'll hear from Mr. Andrew Boulanger. He is
University Fuel Services Program Manager at the Department of Energy.
Mr. Boulanger?
MR. BOULANGER: Good morning, and thank you for the
opportunity to provide an overview of the DOE's -- or Department of Energy's
University Fuel Services Program. My name is Andrew Boulanger. I am the
University Fuel Services Program Manager under the DOE's Office of Nuclear
Energy, and I'll be providing an overview of university fuel se rvices, or UFS,
followed by the operations and impact the program has had acros s the U.S.
I'll be providing an overview of the role university fuel services
has -- and by touching on a few topics, such as the connection to isotope
production, advanced reactor fuel services, security postures, possession-
limited challenges, all of which are relevant to this program.
Next slide, please.
From a high level, the University Fuel Services Program
provides the U.S. government -- U.S. government-owned fuel to 2 5 NRC-16
licensed university-based research and test reactors at low or no cost to the
university. Typically, spent nuclear fuel is returned to the U.S. government for
disposition through the program, and some of the fuels -- fuel services may also
include transfers between universities as needed. For example, this past year
Penn State University transferred fuel to U.C. Davis where it c ould be used
more readily for their research.
University fuel services indirectly supports some domestic
isotope production. For example, University of Missouri at Col umbia produces
medical isotopes, which can -- which depends on fuel procured t hrough the
program. And UFS is aware that other universities have express ed interest in
radioisotope production, which has usually been in the research level
quantities.
So for some clarity I'd like to highlight the activities that a re
beyond the scope of the University Fuel Services Program. List ed here under
the last bullet, the program does not currently develop new fue l types for NRC
review and approval for advanced reactors. The program also does not provide
reactor operating equipment, such as consoles. That kind of upgrade is usually
performed through -- either privately through the university or through other
competitive funding opportunity grants.
UFS does not provide enriched uranium directly to
universities. That is performed through other mechanisms outsi de of this
program. And, finally, we do not provide universities with com ponents related
to fuel fabrication or assembly. For example, UFS would not pr ovide casking
equipment for making their own dispo fuel.
And so to summarize at a high level, the University Fuel
Services Program is primarily a procurement program of commercially available
research reactor fuel, and UFS disposes of the fuel after unive rsities are done 17
with it.
Next slide, please.
Currently, the university fuel services are contracted through
the Idaho National Lab, or INL. This arrangement for fuel serv ice has been
implemented through INL since 1977 under different names over t he decades.
A recent name change occurred on the program, was in 2022, to help clarify the
role of the program at a glance. The previous name was called the Research
Reactor Infrastructure Program. Functionally, the purpose has not changed,
which is to provide fuel to existing university research reacto rs across the U.S.
INL has subcontracts with all 24 universities to supply the
fresh fuel and dispose of the used or spent fuel. Half the fle et, or 12 of the
reactors, use TRIGA, or Training, Research, Isotopes, General A tomics fuel.
The next largest portion are eight reactors which use a plate-t ype fuel, and the
five remaining reactors are a mixture of different types of rea ctors and fuel
types.
Next slide, please.
The program recently delivered 30 newly manufactured
TRIGA elements to Penn State University in September 2023. Thi s marks the
first delivery of fresh TRIGA fuel in about a decade. Since 20 13, the DOE has
been supporting the restart of the TRIGA manufacturing line. We anticipate fuel
production to continue over the next decade, which should provi de enough fuel
for the 12 university research reactors until their respective decommissionings.
The intention is to store the newly manufactured TRIGA fuel
at INL to avoid encroaching on nuclear -- on existing nuclear m aterial
possession limits at each prospective university. UFS works with universities to
stay within these possession limits, and, by extension, their r espective
safeguard categories by moving fuel to other universities or di sposition 18
locations.
Although these movements are within the operating scope of
the program, it will become more challenging as fresh fuel deli veries increase
over the coming decades. The restart of the TRIGA fabrication line means
several hundred more TRIGA fuel elements will be -- that are in tended to be
produced that will eventually be distributed to universities.
The increasing fuel or nuclear material quantities across
universities will decrease fuel movement flexibility and may co nflict with
university specific security postures based on the quantity of specific materials
onsite. This scenario will need to be addressed as we move for ward to
continue to support university research reactors while maintain ing compliance
with the appropriate regulations.
So next slide.
Advanced research reactors at universities have a significant
potential to be -- for it to be good opportunities for several items, including
workforce development, teaching tools, the potential production of isotopes,
and research opportunities, both federal and private.
Recent changes in congressional authorization show promise
in supporting advanced research reactors. Specifically, the CH IPS Act of 2022
authorized the establishment of no more than four research reac tors. And,
more recently, the National Defense Authorization Act of 2023 a mended the
Energy Policy Act of 2005, which clarifies that fuel services s hall be expanded
to research reactors.
In order for UFS to provide new fuel types for new research
reactors, the reactor must be licensed. The DOE would need to receive
adequate appropriations. A fuel supplier must be authorized an d/or licensed to
provide the fuel. And, finally, there must be a plan for dispo sition of the spent 19
fuel. Despite these challenges, DOE is excited and looking for ward to working
towards the benefits of advanced research reactors that will br ing to the
research communities.
And with that, I conclude my presentation. Thank you very
much.
CHAIR HANSON: Thank you, Mr. Brooks.
We will conclude this first panel with Ms. Joanie Dix. She is
the Deputy Director for the Office of Conversion at the Nationa l Nuclear
Security Administration.
Ms. Dix.
MS. DIX: Good morning, Chair. Good morning,
Commissioners. Thank you very much for having me here today on this panel.
I am going to go ahead and talk a little bit about both resear ch reactors as well
as medical isotope production from our side of the house.
So next slide, please.
As a quick overview of what our office works on, we do fall
within the Office of Defense Nuclear Nonproliferation. So we a re a
nonproliferation-focused office. However, there is a lot of in tersection between
the work that we do and the NRC.
My office's objective is to modify or convert facilities to
eliminate the need for or production of weapons-usable nuclear material in
civilian applications while maintaining critical mission perfor mance of those
facilities. We do that in a number of ways. Those are listed here on the left of
the slide.
But for my presentation here today I'm really only going to
focus on the conversion of research reactor fuel from highly-en riched uranium
to high-assay low-enriched uranium, or HALEU, the qualification and fabrication 20
of new high-density HALEU fuels, and the production of non-HEU-based Moly
99.
Next slide, please.
So to start with, I wanted to talk a little bit about our effor ts on
Molybdenum-99 or Moly 99. This is a critical medical isotope t hat is used in
over 40,000 procedures each day here in the United States and e ven more
globally. Historically, the U.S. has always imported its Moly-99 from
international producers, which was traditionally made using hig hly-enriched
This is why my office got involved in the matter was to help
assist these global producers to transition from using highly-e nriched uranium
targets to HALEU targets. We have made significant progress an d had a great
achievement. Just last year all major global Moly-99 producers now only use
HALEU targets, which is a great success.
With this, there was a joint secretarial certification between
the Secretary of Energy and the Secretary of Health and Human S ervices that
certified there was a sufficient global supply of Moly-99 that is produced without
the use of highly-enriched uranium to meet patient needs here i n the United
States. And what this certification supported the U.S. government and the NRC
in doing is that we no longer can export HEU for the use of med ical isotope
production.
So for my office, that's a big deal, and maintaining that supply
while being able to do this is kind of an amazing achievement.
Simultaneously with our international efforts we also have
domestic efforts here in the United States to help support the establishment of
commercial production of Moly-99 without the use of HEU. We ha ve provided
financial and technical support to a variety of U.S. companies over the years, 21
and these industry partners have made significant progress in e stablishing
production infrastructure.
However, recently they have experienced severe challenges
with both financing and commercialization. These issues reflec t a combination
of both project-specific issues by individual companies but als o market-wide
challenges. NNSA is continuing to support our remaining cooper ative
agreement partner while also working with other U.S. government agencies to
assess whether policy changes are needed to make domestic produ ction of
Moly-99 more commercially sustainable.
Next slide, please.
Changing over to the reactor conversion side, similar to the
international work that we do on Molybdenum-99, we are really focused here on
converting the research reactor fuel from highly enriched urani um to HALEU.
We do this both domestically and internationally. And to date we have -- 109
facilities no longer use HEU fuel or targets.
On the international reactor conversion front, we are engaging
with a number of international partners. This includes Belgium, France,
Germany, Italy, Japan, and Kazakhstan. And as these conversion s continue,
the use and exports of HALEU fuel are expected to steadily incr ease. So we
greatly appreciate the NRC's role in these exports of HALEU to make sure that
these international research reactors and medical isotope produ cers can
continue their missions and continue to provide the medical iso topes that we
need here.
On the domestic front, NNSA is working towards converting
the six high performance research reactors from HEU to HALEU fu el. The first
three conversions will be those that are regulated by the NRC, which include
the Massachusetts Institute of Technology, the University of Mi ssouri research 22
reactor, and the National Bureau of Standards reactor at the Na tional Institute
of Standards and Technology Center.
All of these what we call U.S. HPRRs, the high performance
research reactors, are a challenge for my office as no existing fuel can be used
to convert these reactors while maintaining their mission space. So our office
has been working over the years to develop, fabricate, and qualify a new fuel so
that these reactors can convert to a HALEU fuel while maintaining their mission
performance.
So we have begun and will continue to carry out a
comprehensive set of irradiations over the next four years for the new uranium
Molybdenum monolithic fuel, otherwise known as U-10Moly, to dem onstrate its
performance and safety and to, therefore, allow the subsequent conversion of
these reactors.
NNSA and the NRC have signed an MOU to help facilitate
qualification of this new fuel, and the subsequent review and hopefully approval
of the license applications to convert these three reactors. W e are hoping to
provide this U-10Moly qualification report to the NRC in 2028, which will follow
in 2030, hopefully, by the MIT reactor as the first reactor to submit a license
amendment request.
So thank you very much, and I look forward to your questions.
CHAIR HANSON: Thank you very much, Ms. Dix. And thank
you all for your presentations this morning.
We'll begin questions with Commissioner Caputo.
COMMISSIONER CAPUTO: Good morning. Thank you all
for being here. It's a very interesting and engaging topic, re search reactors. It
has been quite a while since I sat at the panel one, so it's in teresting to see the
developments that are going on now and the technologies that yo u folks are 23
pursuing. So very exciting development here as you all push fo r the
advancement of nuclear technology understanding.
So given the advancements that are going on, non-power
utilization facilities are definitely receiving more attention now than they have for
a while, and of course this agency issued a construction permit for Hermes.
We have the application undergoing review for Abilene Christian and ongoing
work with Illinois.
So we're also seeing a number of papers and some policy
issues that are coming up involving NPPUFs and advanced reactor s. One of
the recent ones we've gotten is a paper on micro reactor licens ing with an
option for micro reactors to be developed under a manufacturing license using
Part 50 construction permits and operational licenses.
We also have Part 53 where staff is proposing the same sorts
of reactors should only be allowed to be licensed at their ulti mate sites using
combined licenses, and then restrictions in Part 52 against usi ng combined
licenses for non-power utilization facilities.
So I'm struggling a little bit. I recognize that this is perhaps at
the periphery of this meeting, but I'm struggling a little bit with just the nature of
how I think in pursuing multiple different efforts we now have a slight
inconsistency in terms of our policy and approach.
So this is something that I definitely think the staff should
conduct a holistic review of the -- of advanced reactor project s to make sure
that our policies in this area are aligned going forward.
On a separate issue, this is also pending before the
Commission, has to do with the use of PRA in construction permi ts. And while
that is also at the periphery of the substance of this meeting, I do want to raise
a question considering we have an applicant at the table who is pursuing a 24
construction permit.
I'm a strong proponent of using risk information design in
licensing, but I'm sort of struggling with how appropriate it i s to delve into
requiring a PRA in construction permit space.
So, Dr. Towell, as a Part 50 applicant undergoing that
process now, how would you envision such a requirement impactin g the nature
of how you pursue your permit and any complications you might f oresee?
DR. TOWELL: Thank you for the question. I think that we
believe that research reactors, and specifically our molten salt research reactor,
is -- has a safe enough profile that it's licensable in many wa y s. B u t I t h i n k t h a t
the requirement to do a PRA for it is something that we don't f eel necessary.
It's currently -- we're currently not pursuing that, and so we' re content to file
through the Part 50.
I guess I wouldn't speak for others and think of -- and try to
decide if that would be helpful to them.
COMMISSIONER CAPUTO: So how -- given the nature of
pursuing a construction permit, how simple would it be for you to develop a
PRA? And what benefits would it really have given the fairly s imple technology
that you're pursuing and the ability to simply pursue it from a deterministic
standpoint?
DR. TOWELL: We see no benefit in doing that -- the PRA
forward. And so we haven't pursued that, and I think that woul d just be -- it
would be another burden on us I think sort of bluntly. So we w ould prefer not to
have to do it.
COMMISSIONER CAPUTO: Okay. Well, as it stands now,
it's not -- it's not currently a requirement for NPPUFs. But I also don't think that
it's without -- it's going to have complications. I think one of them is certainly 25
the lessons that I learned in watching Vogtle 3 and 4 proceed is once applicants
are into construction space, there are changes that happen during construction
space. And the nature of trying to maintain a PRA in that cont ext I think would
be fairly complicated.
And as you have outlined, not necessarily a benefit if there is
a fairly simple profile that can be addressed deterministically. So as we seek to
expand our use of risk, I do think it's important to have a bal ance in terms of risk
and use of deterministic practices. So thank you for that.
I have no further questions.
CHAIR HANSON: Thank you.
Commissioner Crowell.
COMMISSIONER CROWELL: Thank you, Mr. Chair. Thank
you to all the panelists. This has been educational for me, an d it's good to see
some of you again, meet some of you for the first time.
Ms. Johnson, it's good to see you again. I will keep my
promise to you to come visit at some point. I made the same co mmitment to
Dr. Towell the other day. And, Caleb, since you're sitting her e, I'll do the same.
(Laughter.)
COMMISSIONER CROWELL: And I've been to Forestal
many times, so I'm not going.
(Laughter.)
COMMISSIONER CROWELL: So, you know, you Ms.
Johnson, you mentioned that you want to -- hope to see the number of research
and test reactors expand in the coming years. What do you see on the horizon
over the next 5 or 10 years in terms of potential expansion of -- or new RTRs
looking to be developed and licensed?
MS. JOHNSON: Do you mean like my panelists next to me?
26
I'd certainly love to see Abilene Christian and UI-UC join us.
COMMISSIONER CROWELL: Like ones we haven't heard of
maybe that are --
MS. JOHNSON: Oh.
COMMISSIONER CROWELL: -- like on the horizon or
something that is at its infancy that you expect to see the num ber grow from 30
to something large.
MS. JOHNSON: Oh. I would -- wow, I haven't given that
much thought. So I'll have to think about it and put that in t he next newsletter.
COMMISSIONER CROWELL: I thought that's what you were
implying when --
MS. JOHNSON: Oh. I wanted to see --
COMMISSIONER CROWELL: -- when you said you do look
to grow.
MS. JOHNSON: So I do want to see at least two more join
us, so I'm happy to see two in the -- in the pipeline --
COMMISSIONER CROWELL: Yeah.
MS. JOHNSON: -- I suppose.
COMMISSIONER CROWELL: Okay.
MS. JOHNSON: And so referencing back to previous
Commission meetings in 2014, it's nice to see new people at the table. I want
to see them continue to be at the table, so --
COMMISSIONER CROWELL: Great.
MS. JOHNSON: -- that's fine.
COMMISSIONER CROWELL: And a somewhat related
question I think for you, or whoever, but maybe Dr. Towell as w ell. On
workforce issues, how -- obviously, we -- all parts of the -- y ou know, workforce 27
is an issue for all of us, whether you're at the production sta ge, you know,
research, tests, whatever.
How transferable are the training and skills your students are
learning from some of the novel technologies to other technolog ies? I mean, is
it going to be a very technology-specific workforce? Or is it going to be a
workforce that can mix and match with different new technologie s?
MS. JOHNSON: Oh, I certainly think it's applicable across the
board, the skills they learn operating a research reactor. We certainly do see a
lot of our previous operators to the NRC for employment, and th at's great, but
we also see them with those skills -- certainly like the nuclea r safety culture is
broadly applicable to many industries.
COMMISSIONER CROWELL: Yeah. Mr. Towell, did you
want to add anything?
DR. TOWELL: I agree completely. You know, I think that if
you teach someone problem solving and critical thinking and do that in a safety
culture, then I think that's applicable to any advanced technol ogy. And I think
that maybe the Navy's nuclear program is a great example of the w a y w e t a k e
their operators from one type of reactor and we're able to empl oy them in
commercial reactors.
So I think that the skillset is very transferrable.
COMMISSIONER CROWELL: Okay. So there will be good
competition amongst your map of projects. Yes. Okay.
Mr. Brooks, you mentioned something that I'm very interested
in, which is I think you all roads go through public engagement. I like that term.
You happen to be based at a -- at a university in a research reactor that is in a
highly populated area. So I think that is even more of an impo rtance to do
public engagement.
28
Can you tell us a little bit about how you guys do public
engagement and the value and how broad it is, whether it's just the university
community or far it expands outward?
MR. BROOKS: Yeah. Thank you for that question, and I
think it's -- it's worth highlighting because that will be mayb e the challenge for
advanced reactors to realize their full potential.
And so the University of Illinois, since becoming public about
our intentions to deploy an advanced reactor on our campus, we have seen
various levels of engagement. We have held many different public settings and
forums for the community and for the students.
We have regular monthly meetings that are open to the public
to come and ask any questions or get any insight into the proje ct or the status
of the project. It's really quite a coordinated effort, and it goes all the way up to
the communications office within our university to put a strate gic plan together
to make sure that all of the stakeholders have an opportunity t o provide input.
We do kind of countless engagements with media outlets to
make sure that people feel like they understand the overall tim elines, and in
particular what is new about the technology, because I think th at's where it has
been really fun to engage the public.
What most people think of with nuclear power is 1970s
technology. And just like our phones, we have come a long way, right, since
1970. And even like our phones, we don't just make calls, or m aybe we don't
even make calls anymore with phones, right? And I think advanc ed reactors
are similar in that, you know, the smartphone analogy really wo rks.
We've come a long way in the technology, the way we'll
deploy the technology, how we'll use the technology, and so it has been -- it has
been exciting to engage the public, share those advances, but unfortunately we 29
have stumbled I think as a -- as an industry in rolling that ou t, putting that --
those advancements in front of the people, so they can really w itness and see
the benefits of advanced nuclear.
COMMISSIONER CROWELL: Let me --
MR. BROOKS: So I think --
COMMISSIONER CROWELL: Can I press you on that point -
MR. BROOKS: Yes.
COMMISSIONER CROWELL: -- a little bit? Unfortunately,
this speculates somewhat, but how much does your public engagem ent at the
university level in the research stage -- do you think it will translate to broader
public acceptance of these types of reactors at the commercial phase?
MR. BROOKS: Yeah. So our project from the beginning has
been focused on deploying a commercializable technology as a -- as an
advanced research reactor. I'm an academic. I can fall into t he trap of having
yet another paper reactor. But from the very get-go, we decide d against that.
And, particularly, we want to deploy a technology that will be
deployed commercially around the -- around the country, around the world, so
that people can come and see that technology, see how it operat es, see its
benefits, right, see its transformation compared to what they'r e used to with
current -- the current fleet of nuclear.
And the role of advanced -- of research reactors around the
country to demystify nuclear for the general public is well est ablished, and I
think is underappreciated, but advanced reactors are going to and can enable
a new wave of that engagement with the public to just see, you know, how far
we've come in over 50 years now.
COMMISSIONER CROWELL: I'm going to ask you an unfair 30
question, and you can pass it to either person your left.
(Laughter.)
COMMISSIONER CROWELL: How much do you highlight
the spent fuel conundrum of -- at research and test reactors?
MR. BROOKS: Yeah. So engaging the public, just to tie
these two questions together, engaging with the public, the questions that come
up, of course the safety questions I think are -- we have -- we have been able to
address those quite clearly. That's every -- every nuclear eng ineer has
developed in this environment of utmost importance on safety, a nd the
advanced reactors have been designed to address those safety is sues.
With waste, unfortunately, I think that's largely a policy -- a
policy question. But it highlights the benefit of the universi ty pathway. In the
case of the university research reactors, the university never owns the fuel. It's
on a lease agreement with the Department of Energy, and so the ultimate -- the
ultimate path for the fuel beyond its useful life in the reacto r is to go back to
DOE.
Unlike commercial reactors that still have questions about
what is the location of that final fuel, DOE has never not come and picked up
the fuel after its use in a university research reactor. So th e university I think
provides a precedent for a pathway that addresses, I mean, both the safety
concerns of the public with nuclear, the waste concerns of the public with
nuclear, and then ultimately hopefully the scheduling and cost concerns of the
public.
COMMISSIONER CROWELL: Okay. Thank you.
With the little time I have left, Mr. Boulanger, can you talk a
little bit more about the hurdles for DOE when they pick up the fuel and finding
places to safely accommodate it?
31
MR. BOULANGER: So currently there is two locations where
we dispose of or send the fuel for disposition. They are curre ntly the Savannah
River Site in South Carolina, and then Idaho National Labs for -- and that was
decided or established in the 1990 -- NEPA action for 1995, whi ch was done
under an environmental impact statement and a record of decisio n.
Currently, the way that's divided up is aluminum clad spent
fuel is sent to Savannah River, and stainless clad is sent to I daho National
Labs. If we're talking about new reactors, DOE would have to p erform what we
call a NEPA action and establish -- either amend the existing record of decision,
environmental impact statement, or create an entirely new one.
So there are challenges that are involved in establishing
these new fuel types and fuel forms.
COMMISSIONER CROWELL: Would it potentially be a site
other than Idaho or Savannah River, or would it be one of those two sites?
MR. BOULANGER: I couldn't comment on that. I would have
to get back to you on that.
COMMISSIONER CROWELL: But something in the DOE
complex.
MR. BOULANGER: That would -- potentially. I don't know at
this time, but I can get back to you and -- on that topic.
COMMISSIONER CROWELL: Great. Thank you.
Thank you, Mr. Chair.
CHAIR HANSON: Thank you, Commissioner Crowell.
Thank you all for being here this morning. It's a real pleasur e
to hear from everyone. And, you know, I have a lot of favorite parts of my job,
but I think one of the favorite favorite parts is actually goin g around to
universities and meeting students and getting to see test react ors and 32
understanding better how these facilities are being used to edu cate students to
-- you know, particularly as Ms. Johnson, Dr. Towell, and Mr. B rooks all
mentioned about, you know, getting students into nuclear safety culture, getting
them to understand, you know, the basics of nuclear reactor phy sics and other
kinds of things.
And, you know -- and whether that's something new, you
know, Dr. Towell, when I was out at Abilene Christian, that was a great visit,
and getting to see how students were working with the molten sa lt and how that
worked at high temperatures and that test bed in that ancillary facility.
I haven't been out to Purdue yet, but I'm interested in that,
and as a demonstrator for some digital I&C type equipment there and the role
that they have played. I was out at Kansas State just about th is time last year,
and they had modified their TRIGA to have a neutron beam off th e side. And
they were doing neutron -- they were, you know, working with st udents to do
neutron activation experiments, which I thought was a really gr eat modification
to that to get additional use and additional educational benefit out of that facility.
And I really enjoy seeing this kind of thing.
I do want to dive in on a couple of issues, and I think it kind o f
has to do around with the fuel, and so forth. I don't know if it was Mr. Boulanger
or Mr. Brooks, you mentioned -- so, you know, University of Ill inois has this
agreement with USNC. USNC has their own -- I think has their o wn propriety
fuel that they are going to manufacture or contract with someon e to
manufacture themselves.
How does that work between you guys, USNC, and then DOE
in terms of, you know, is DOE going to buy that from USNC and g ive that to you
guys? How does that -- how is that going to kind of work?
MR. BOULANGER: Well, I'll tell you how we expect it to work 33
based on --
CHAIR HANSON: Okay.
MR. BOULANGER: -- precedent.
(Laughter.)
MR. BOULANGER: We'll see how it works. I mean,
everything -- I mean, the fine print of it all is it pens appro priations. Maybe
that's the fine print of everything here is penning appropriati ons.
But what we expect is that the stock material would be
supplied to USNC under that lease agreement and shipped to USNC at USNC's
fuel fabrication facilities. That's when -- that's where they would fabricate the
TRISO fuel. And then they would take the TRISO fuel and they w ould form
their FCM pellets, which is an annular fuel form with -- encaps ulated in the
silicon carbide. And those pellets would then be loaded into t he assemblies,
and then assemblies would be shipped separately to site to be - - to be put into
the reactor.
So based on past precedent, the expectation from our side is
that through appropriations and through the University Fuel Ser vices Program,
they would supply the stock material, they would supply the cos t of shipping
and manufacturing to the fuel form, just like they do for all o ther university
reactors, and then ultimately put into the reactor for its oper ation.
In our case, we'll have upwards of 20 years of operation with
our reactor without the need of refueling.
CHAIR HANSON: Ah. Okay. Thank you. That's very
interesting.
If I could, I want to -- I'm interested in exploring, Ms. Johns on
and Mr. Boulanger, this -- I was glad to see DOE getting back in the TRIGA -- or
the U.S. just getting back into kind of the TRIGA fuel manufacturing business at 34
And, you know, as I visited a couple of these facilities, you
know, they are now in some cases 50-plus years, and the TRIGA f uel that's in
that is kind of reaching its life and so there is -- it seems l ike to me, maybe I'm
misunderstanding, but there is a lot of refueling that could go on, not
necessarily whole course but partial course coming up.
And I guess I'm wondering, Ms. Johnson, if the -- if the RTR
organization has kind of mapped out fuel needs and kind of marr ied that with
production at DOE, and how that's going to kind of happen.
MS. JOHNSON: Oh, yes. We worked very closely with the
Risk --
CHAIR HANSON: Okay.
MS. JOHNSON: -- Service, and we are so excited to be on
their list. So I'm sure Andrew has this all in priority.
CHAIR HANSON: Yeah.
MR. BOULANGER: If we're talking about specifically TRIGA
fuel, it's manufactured in Romans, France, under --
CHAIR HANSON: Yeah.
MR. BOULANGER: -- a joint agreement with General
Atomics and Framatome. And so, yes, we do actually -- we follo w up with the
university needs, and we have it mapped out for currently the - - through their
respective decommissionings or when that anticipated date could be.
Right now we are planning on -- the intention is to acquire all
of the fuel that's needed over the next decade or so, and then from there we
would distribute it to the universities. So the fuel would com e -- the intention is
for it to come to the Idaho National Labs and be stored, and th en when the
need comes we will transition it to the university as it's need ed.
35
CHAIR HANSON: Okay. Got it. Thank you. No. I was just -
- I'm interested in that whole process because I think it would be a real shame if
a university kind of came along and said, well, we're not reall y sure, you know,
if they kind of gave thought to maybe not continuing with the r eactor program
because there was some hiccup along the way.
And I don't think that's exclusively related to TRIGA. Mr.
Brooks, while you were talking, I thought, ah, okay, we need a transportation
package for that TRISO fuel to get from wherever it's going to be produced to
Urbana-Champaign.
You know, there is one more need in there, somebody to both
make it but also then come to the NRC to get the certificate of compliance for
that as well. So there's a lot that's implied here.
I want to pick up on one thing that Commissioner Crowell
brought up in terms of spent fuel. And, Mr. Boulanger, you men tioned, you
know, aluminum clad fuel going to Savannah River and steel s t a i n l e s s g o i n g
to Idaho. A few years back there was a concern I think at Sava nnah River
about capacity in what was known as L Basin in terms of the abi lity to continue
to take either foreign repatriated spent fuel or domestic resea rch reactor fuel.
I don't know if this is a question for you or maybe a question
for Ms. Dix about how NNSA, or since you guys are now in charge of -- now
that NNSA is in charge of Savannah River, how is that problem b eing resolved,
has it been resolved, et cetera.
MR. BOULANGER: So the fuel that gets shipped to
Savannah River, we work closely with the DOE EM, or environment al
management. To kind of simplify it, we effectively drop it off at their door.
(Laughter.)
MR. BOULANGER: But there's more -- there's more 36
intricacies other than that. But I think Joanie might have a l ittle bit more than
myself.
MS. DIX: Unfortunately, I don't have a lot more to offer than
Andrew. It's outside of the scope that we work in. We essenti ally make sure
that we can fit the converted fuel into the same requirements, so that there is a
disposition pathway of that fuel.
So we work kind of within existing constraints, but we don't
handle the return of the -- the foreign returns is another offi ce within our
Department.
But I can certainly get that information to the Commission and
to you later, but I don't have that answer now.
CHAIR HANSON: Okay. Thank you. But it's a great
transition because I have some questions for you.
You know, you mentioned the uranium Molybdenum
monolithic fuel type. And, you know, trying to reach back into the recesses of
my brain on the conversion program, the three reactors that you are kind of
focused on first -- MIT, University of Missouri, and our friend s at NIST -- are all
pretty different reactors, right? They are designed to do real ly different things.
Is it a single fuel type that you're looking at for all three o f
those? And how does that work?
MS. DIX: Yes. It's a single fuel type for all of those reacto rs.
It will also be used for the advanced test reactor at Idaho Nat ional Lab. The
high-flex isotope reactor down at Oak Ridge will take a differe nt fuel, so that
fuel will be a silicide form, so that's kind of a separate fuel development/
fabrication/qualification activity that we have ongoing.
Really, the challenge is the fuel itself. Of course, each of t he
reactors has a different form that their fuel is arranged in, s o we work really 37
closely with the reactor operators and with all of our national labs to make sure
that the fuel that we develop will meet their requirements and that it can be
fabricated in the form that works for their reactor.
CHAIR HANSON: How is the irradiation testing going?
Where is it --
MS. DIX: Sure.
CHAIR HANSON: Where is that happening now, given, you
know, we've heard a lot I think on the Commission and other pla ces about the
dearth of in pile or even -- or irradiation testing kind of acr oss the -- across the
w o r l d, r e a l l y. H o w i s t h a t h o w i s t h a t g o ing? And how engaged are you with
NRC staff on the data that's coming out of that?
MS. DIX: So the irradiation testing is going really, really we ll.
We're at a really exciting point actually in our testing progr ession. We have
been doing what we call kind of mini-plate irradiations. So they're smaller forms
of the fuel meet and cladding.
We are transitioning to full-sized plates, so that's a -- that' s a
big transition. Fabrication is going well. Irradiation is goi ng really well. We do
irradiation in two places. We do it at the advanced test react or out at Idaho
National Laboratory, and then we also do some testing out at th e BR-2 reactor
in Belgium.
CHAIR HANSON: Oh. Okay. All right. Thank you.
I just wanted to clarify one last thing. You had said 2028, a
product to the NRC. Is that going to be a topical report that then kind of
approves that fuel form? That then MIT can reference in their license
amendment request in 2030? I just -- I want to translate this a little bit into NRC
speak, so staff know what to expect and we can hold them accoun table to that.
MS. DIX: Yeah. So I know there has been conversation kind 38
of at the -- at the staff level in terms of what was the right way to submit the
correct documentation. When I asked my team about this, they s aid that the --
kind of the single most important activity for the NRC to help prepare for this is
of course to have your experts available and ready to review th e base fuel
qualification report and subsequent reactor-specific conversion application.
So I don't know one for one how it specifically translates to
the exact documents, but I'll try and do the translation betwee n our two
agencies and figure out what the document is called.
C H A I R H A N S O N : T h a n k s. W e l l, i t m i g h t - - a s y o u s a i d, e a c h
one of these reactors, the three, are all really different.
MS. DIX: Yeah.
CHAIR HANSON: And so it's not going to be even physically
a single form, even if potentially the uranium content is the s ame amongst
them.
MS. DIX: Right. So, yeah, it would be two submissions. The
one in 2028 would be strictly for the fuel itself.
CHAIR HANSON: Got it.
MS. DIX: This will be the first fuel that -- new fuel that we' ve
had developed in quite a long time. So that will be the new fu el itself, and then
each reactor will do their license to adjust to that fuel after that. So --
CHAIR HANSON: Great. Looking for to it. Thank you.
Thanks for the extra time.
Commissioner Wright.
COMMISSIONER WRIGHT: You're welcome.
Thank you, Chair. It's been fun so far. Right?
(Laughter.)
COMMISSIONER WRIGHT: So thank you for your 39
presentations. You know, I really find the RTR world exciting. It's unique. It's
just -- and very interesting, and this is a really -- it's an i mportant time to be in
this space. So, I mean, you're on the cutting edge of pretty m uch everything,
right? Plus on top on that you -- you're in the unique positio n of being able to
inspire a whole new generation of people to get into the nuclea r space and find
their way and make a difference. So I really appreciate you be ing here today.
And the advantage of going last is that I always find that I
might have some questions to follow up on, you know, because so me of the
ones that I had possibly have been answered, right?
So I wanted to follow up quickly on the conversation that the
Chair had started with you. And he was questioning Mr. Brooks and Mr.
Boulanger, so I was coming to you, because I had -- there is a question about
HALEU. You know, how do you see the need for HALEU for researc h reactors
interplaying with the need for HALEU for advanced reactors? Do you think
there is -- I mean, are these complementary efforts? Or do you think there may
be competition for what people may think is going to be a limit ed supply of
MS. DIX: That's a really great question. It has been a very
interesting couple of years as this area has expanded within th e community.
The interest in HALEU originally was pretty much limited only t o research
reactors and medical isotope production. So we've had kind of this little niche
area in HALEU that now is seeing a huge growth with advanced re actors and
small modular reactors entrusted in it.
I think people will see it as a competition at the very beginning
because it is a limited resource at this point in time. But, i n reality, I think they
are very complementary and very beneficial, what -- you know, w ith the
expansion of advanced reactors and SMRs, we will see the growth of the 40
HALEU supply chain, and that is only beneficial for the researc h reactors and
medical isotope producers.
Right now, where HALEU comes from is form our work down-
blending highly-enriched uranium that we own at DOE and NNSA. So that is a -
- that is a limited stock, a limited resource, so that has been focused on being --
down-blending and providing it to research reactors and medical isotope
producers. We are very confident in that supply.
Similar to a question that was asked earlier, twice a year we
update our analysis for what the needs are for all of the diffe rent reactors for
their life cycle, so we have a good handle on that. But, simul taneously, the
entire Department -- and this includes nuclear energy as well a s NNSA and
others in the Department -- have really been working to help st and up the
supply chain for HALEU, and that's going to benefit everyone in this room for
research reactors and isotope producers, but also for all of th e new advanced
reactors, SMRs, whether they're at universities or whether they 're strictly
commercial. So --
COMMISSIONER WRIGHT: Okay.
MS. DIX: -- I'm excited to see where it goes.
COMMISSIONER WRIGHT: Good. Thank you for the
answer. Thank you.
Dr. Towell, the -- one it's good to see you again. You know, I
had the opportunity to go to Abilene Christian in December, and it was a great
visit and I spent the full -- I had -- gave a full day, stayed -- toured the facility,
met with students, met with staff, talked with faculty deeply a bout some
different, you know, issues that were of concern to me and of c oncern to them,
right, about the whole NRC process. And then I got to go to th e basketball
game. That was highlight.
41
(Laughter.)
COMMISSIONER WRIGHT: That was a lot of fun. Texas is a
great state, and it was a real treat to get to spend some time with you and the
President and the rest of the team down there. And I highly re commend the
visit. Highly recommend it.
So my question is a follow-up, all right, to Commissioner
Crowell's question to Mr. Brooks, right? He was asking about t he public
engagement, and he was asking about the disposition of spent fu el. Did you
have any comments? Did you -- maybe you could follow up on the same kind
of question. I'll give you that opportunity. Right?
DR. TOWELL: Thank you. Thank you for your visit. We
appreciate it anytime a commissioner is able to come. And so w e're two down,
two to go. The invitation is there.
(Laughter.)
DR. TOWELL: Obviously, public engagement, I couldn't
agree more with everybody Caleb said. It's important. It's a -- you know, if you
want the -- if you want the public to accept advanced nuclear, you need to
educate them and teach them about the advantages and demystify it and
explain the benefits.
And so, yeah, a lot -- safety and waste are usually the top two
concerns, and so, you know, you go through the safety profile a nd explain how
we're keeping it safe, and then you have to address waste. And so, you know,
like Caleb, we hope that the Department of Energy will both pro vide our fuel
and then take our spent fuel at the end of the day.
I will say, you know, with the technology of liquid fuel, molte n
salt cooled reactors, the amount of waste you produce is drasti cally reduced,
and, in fact, at some level there is nothing that goes to the w aste stream 42
because any leftover fuel goes into the next reactor. And so t hat's an
advantage, and that's something that we talk about, but public engagement is
very, very important.
And we have spent a lot of time -- a lot of the things Caleb
talked about we're doing in Abilene also, and so the -- you kno w, never pass up
a chance up to talk to the Kiwanis Club or Rotary Club or any g roup that wants
to know what we're doing in that big building.
COMMISSIONER WRIGHT: Right. So thank you for the
answer. I wanted to stay with you, too, for a second, Caleb and Rusty, because
I think the next couple of questions maybe you both could answe r about your
own experiences.
First, is our staff appropriately, in your opinion, implementin g
the AEA directive on research reactors to impose only the minim um --
"minimum amount of regulation" needed to -- for reasonable assu rance of
safety as you had on our slide, but I'll let you comment on it as well.
DR. TOWELL: So we of course understand the challenges of
bringing the first research reactor for construction written in decades, and the
first, you know, non-light-water reactor to think about as bein g a research
reactor. So we understand the challenges there, and we're very thankful for the
careful review.
Are there places where some of the questions are probably
leaning -- are there times where we probably get into issues th at should be
pushed off to the operating license or pushed off for a commerc ial reactor? I
believe so. We're continuing to answer those questions because that's the
fastest path to getting a permit approved.
So I think it's a challenge for all of us, and we're -- we
appreciate the opportunity to be in the dialogue, especially in audit space, and 43
to have the dialogue back and forth. But it's a challenge for all of us.
MR. BROOKS: Yeah. So our engagement to date with NRC
has been very good on that question. I think they have stuck t o that additional
piece of research reactors that has minimal regulation. We hav e seen a good
response from industry on that. And I think it highlights the fact that NUREG-
1537 does provide guidance that's maybe more prototype-friendly to allow for
advanced reactors to efficiently get through NRC licensing proc ess.
So I would say, you know, even going back to the PRA
question, right, we are providing an opportunity for a faster p ath, we think a
more efficient path, a clearer path, to licensing with NRC wher e then you can
get the data, you can get the understanding for that leap to co mmercial
operation, get the data needed for the PRA, in order to make th at -- again, it's a
very powerful tool, which currently is in the -- is in more of the technology
development side, but PRA becoming a very valuable tool even on the
regulation side.
So I think we're -- what we're trying to provide here, and I
think the NRC staff and our project gets that, is that we can w ork under a
guidance framework that is much more prototype friendly than we would see
with a direct commercial type of application.
COMMISSIONER WRIGHT: Okay. And with the time I've got
left, I'm going to ask one more question here, because I'm goin g to stay kind of
on this topic. As you know, the staff has been using core team s, right? And
this is a major strategy that we have -- that they have implemented on trying to -
- for these reviews, right, and for the advanced reactor licens ing.
So what are your views on how the core team is working --
and I'll come to you first, Rusty, and then back to you, Caleb -- considering what
you just told me about, you know, the -- maybe getting beyond t he scope a little 44
bit, right? Can you address that?
DR. TOWELL: Well, I should say we have appreciated the
partnership -- I shouldn't -- we've appreciated the collaborative desire to reach a
positive resolution of a safe approval. So we have been workin g well. I don't
want to -- I don't want to mislead anybody that things aren't p rogressing well.
It's just challenging because of --
COMMISSIONER WRIGHT: Sure.
DR. TOWELL: -- first of a kind, in that nature. Core teams is
a great concept. I mean, when you have inherent safety built i nto a technology
and you have -- you know, as I understand the concept of a core team, you
have a core team that understands that and can help guide people that are less
familiar with that technology do an appropriate level safety ev aluation. It feels
like there is room for growth there.
Partly, we have also had a turnover. We've had three
different technical reviewers leading our construction permit r eview. So part of
it is the turnover of people that might be working against this. Part of it is just
the first-of-a-kind nature. I think we're on a good path, but I guess there is also
always room for improvement.
COMMISSIONER WRIGHT: Sure.
Do you have any --
MR. BROOKS: Yeah. I haven't seen friction come from this
model. Of course, we're not deep into the construction permit application
review.
COMMISSIONER WRIGHT: Right.
MR. BROOKS: But so far the request for additional
information that we have received on our topical reports have b een -- have
been reasonable. They have been very clearly communicated to u s. I t h i n k w e 45
have seen consistency across topics of our topical reports that have also been
reviewed from other applicants, like was mentioned with Kairos.
There is a wake that is being formed, and I think we are all
moving nicely in that wake as applications move forward. But maybe I'll reserve
my full answer after we're in the construction permit review. Thanks.
(Laughter.)
COMMISSIONER WRIGHT: All right. Thank you so much.
CHAIR HANSON: Thank you, Commissioner Wright.
All right. We have reached the end of the first panel. We're
going to take a short break. We will convene -- oh, I don't kn ow, the two clocks
are different. I think it's triggering my OCD a little bit. B ut let's say 10:25.
For those of you who find yourselves underfed or
undercaffeinated, I am pleased to announce that we now have a c offee
bar/coffee stand here in the building. I think you will find i t off to my right, down
the hall, and they have your -- everything to meet your caffein e or sugar needs.
So that's my plug, and we'll be back shortly. Thank you.
(Brief recess.)
CHAIR HANSON: All right. Thank you, everyone. Welcome
back for our second panel. We are going to recommence with the NRC panel.
We'll be led off by our Deputy Executive Director for Reactor and Preparedness
Programs, Scott Morris. I look forward to another good discuss ion. Scott, the
floor is yours.
MR. MORRIS: Thank you, Chair, Commissioners. We are
pleased to be here today to provide an update on the Agency's r esearch and
test reactor activities.
As you heard in the first panel, RTRs are important tools in
the advancement of nuclear research and development. They incr ease the 46
understanding of nuclear technology, create opportunities for training the future
workforce, provide services for various applications and are ke y in the
development of advanced reactors.
So I will go a little bit off script here and say there is a lo t of
what you will hear today will echo some of the sentiments expre ssed this
morning with a little bit of, obviously, the staff perspective.
The very low risk presented by these facilities is recognized in
the Atomic Energy Act, which we also have talked about in the f irst panel, and
has been demonstrated by many decades of safe operation.
The Act directs the Commission to impose the minimum
amount of regulation to RTRs that will provide a reasonable ass urance of
adequate protection in public health and safety and promote the common
defense and security and protect the environment.
As such, the NRC regulates these facilities by applying
technology appropriate requirements commensurate with the risk to the public
and the environment.
This technology neutral, risk-in formed, regulatory framework
is also being used in the licensing of new technologies and is informing the way
we regulate advanced reactors.
May I have the next slide please? So I will now introduce the
panelists, who will talk about some specific agency activities related to RTRs.
Our first speaker this morning will be Rob Taylor, Deputy Direc tor for New
Reactors in the Office of Nuclear Reactor Regulation, or NRR. And he will
provide the Agency's strategic vision for regulating RTRS.
Rob will be followed Josh Borromeo, to my right, Branch Chief
in the Division of Advanced Reactors and Non-Power, Production and
Utilization Facilities, commonly known as DANU. And Josh will describe the 47
staff's risk-informed licensing and oversight approach for RTRs.
Next Rebecca Ober to my left is a project manager in DANU
with experience in nuclear security and will share information on RTR security
considerations and some recent policy issues.
Next will be Holly Cruz, to Rebecca's left, Senior Project
Manager in DANU and her overview on licensing activities for me dical isotope
facilities and advanced RTRs, including best practices and chal lenges.
And finally we will conclude the panel presentations with Amy
Beasten. She is an RTR examiner in DANU, and her presentation will focus on
the oversight and operator licensing activities for RTRs.
This concludes my opening remarks. So I will now hand over
the presentation to Rob, and we will take the next slide.
MR. TAYLOR: Yup. Thank you, Scott. Good morning, Chair
and Commissioners. Today I will provide you with an overview o f the Agency's
strategic vision for the regulation of non-power production and utilization
facilities.
Next slide, please. Nuclear research and test reactors, also
called non-power reactors, are a type of non-power production a nd utilization
facility, also referred to as NPUF. The primary use is for res earch, training and
development to support science and education and nuclear engine ering,
physics, chemistry, biology, anthropology, medicine, material s cience and
related fields.
These reactors are designed with significant safety margins
and have supported the NRC's licensing of over 100 RTRs and overseeing over
50 years of safe and secure operation.
Even in the rare case of an event such as the 2021 fuel melt
accident at the National Institutes of Standards and Technology, or NIST, the 48
design safety margins and regulatory approach ensure the protec tion of public
health and safety.
These reactors are very different from their large lightwater
counterparts. The smallest RTRs are 5 watts, which is the equi valent of an
LED light bulb. The largest, NIST, is 20 megawatts. Further, more than 80
percent of the operating facilities are less than 2 megawatts, which is
considered low, even by RTR standards.
For perspective, NIST is approximately 88 times small than a
typical large lightwater reactor such as the Canadian Nuclear P ower Plant and
170 times smaller than the newest lightwater reactors, the AP-1 000s at Vogtle.
The difference is in size and purpose provide an opportunity
to apply a graded risk-informed approach for applicable licensing and oversight
requirements of each NPUF.
It is important to state that our mission for the licensing and
oversight of these facilities remains the same, reasonable assu rance of
adequate protection of public health and safety. But our appro ach to achieving
that must be different.
While the major regulatory processes of NPUF licensing are
similar to power reactors, such as construction permits, operating licensing and
the 5059 change process, given the design differences, only a s ubset of our
regulations are applicable, which Josh will discuss further in his presentation.
Next slide, please. There are a total of 30 RTRs licensed and
currently operating in the United States. RTRs are regulated i n accordance
with the Atomic Energy Act, which requires the Commission only apply the
minimum amount of regulation necessary to ensure the safe operation of these
facilities.
The NRC's regulatory infrastructure employs a graded and 49
risk-informed approach that allows flexibility for various tech nologies to provide
reasonable assurance of safe operation.
The current operating fleet of RTRs is primarily composed of
open pool and tank designs. Trigger reactors are training rese arch isotopes,
general atomic reactors are an open-pool type design utilizing various fuel
types and mostly operate at low power.
AGNs, or aerojet general nucleonics, are a tank design and
are even smaller, which operate at 5 watts.
There are also a handful of one-of-kind technologies currently
licensed. And the NRC has also licensed about a dozen aqueous
homogeneous reactors.
Staff continues to look for opportunities to make
improvements in the security and oversight, which Becca and Amy will discuss
further. While maintaining safety, the NRC staff uses a perfor mance-based
approach to regulating RTRs commensurate with their risk and re flective of
their resources and infrastructure.
The staff also communicates regularly with the RTR
community to share information, address concerns and optimize t he licensing
and oversight programs.
Next slide, please. RTRs are vital for the nuclear workforce in
the country and support the future of advanced reactors. The N RC supports
building this workforce through the grants program, led by the Office of Nuclear
Regulatory Research. This provides us with an opportunity to g ain insights
from the technology and move forward in the advanced reactor fi eld.
The Agency is optimizing the integration of RTR and
advanced reactor staff so the past informs the future.
Furthermore, leveraging international engagement in RTRs is 50
critical to continue supporting the RTR's safe and secure opera tion around the
world. Holly will elaborate on this international engagement.
I will now turn it over to Josh Borromeo. Next slide, please.
MR. BORROMEO: Thanks, Rob. I will be highlighting the
key aspects of the safety of these facilities and how our regu latory framework
is structured to ensure the reviews are risk-informed and right -sized to
accomplish the NRC mission.
Next slide, please. There are a variety of type of RTRs and
more broadly NPUFs that implement different technologies to ach ieve their
operational objectives and include design features to ensure the y a r e l o w r i s k t o
the public. This safety provides the foundation on how we regu late these
facilities.
One of the primary design features that contributes to the
safety of these facilities is their low power levels. The lowe r power translates
into low system temperatures and pressures, which reduce the se verity of and
the equipment requirements to mitigate potential accidents.
For example, most of the research and test reactors should
not require an emergency core cooling system to mitigate a loss of coolant
accident because the lower power and the fuel are designed so t hat air cooling
is sufficient to preclude any fuel damage.
Additionally, the low inventory of nuclear material needed for
operation contributes to a small source term for these faciliti es. This results in
accident consequences that are very low.
These design features contribute to the facility have simplified
structures, systems and components, large margins to safety and limit the risk
to public health and safety.
Both the licensing and oversight framework are tailored to the 51
risk of these facilities and provide the flexibility to adjust when necessary.
One of the primary objectives of licensing is to ensure the
design features demonstrate significant safety margin. This is achieved in part
by the evaluation of a maximum hypothetical accident. This is an accident that
is intended to bound all credible accidents for the facility.
Many RTRs have sufficient margins that engineering safety
features are not required even for their maximum hypothetical a ccident.
Oversight of the RTRs ensures that the systems and
programs credited during licensing are appropriately implemente d and the
licensee continues to meet the required regulations.
Next slide, please. To implement the direction from the
Atomic Energy Act, only a subset of the power reactor requireme nts in 10 CFR
Part 50 are applicable to NPUFs. These requirements are also a pplied with a
graded approach. For example, an NPUF over 10 megawatts is cur rently
defined as a test reactor.
The regulations require a test reactor to meet the Part 100
setting requirements, have an independent review by the Advisor y Committee
on Reactor Safeguards and a mandatory hearing during licensing. However,
these requirements are not applicable for lower power research reactors.
Our guidance documents complement the regulatory
requirements to ensure all areas that could impact safety are a ddressed and
provide guidance to further implement a graded approach. This allows for a
regulatory framework that is flexible and adaptable to various technologies and
the risk for each facility.
For licensing, our primary guidance is found in NUREG 1537
titled, Guidelines for Preparing and Reviewing Applications for Non-Power
Reactors, which provides guidance for both the review of constr uction permit 52
and operating license.
NUREG 1537 was a frontrunner in the guidance that is
technology neutral. Because the potential hazards may vary wid ely among
NPUFS, the guidance provides a roadmap for applicable regulatio ns and
acceptance criteria that is broadly applicable to different des igns.
We use this document in licensing of a variety of technologies
in our operating fleet and are successfully using it in our rev iew of new
advanced NPUF technologies.
Like licensing, our oversight of the RTRs is implemented
using a graded approach. The guidance uses the power level to determine the
base frequency of inspection activities for each facility. Rea ctors above 2
megawatts are inspected annually. Below that, and if they are operating,
reactors are inspected every other year.
However, the guidance provides provisions for the staff to
adjust the frequency of inspecti on activities when performance deficiencies are
identified.
Finally, RTR operator licensing regulations and guidelines are
also commensurate with the risk of the facility. 10 CFR Part 5 5 contains
specific requirements for licensing RTR operators. Most of the s e r e a c t o r s a r e
located on university campuses and are significantly smaller th an power
reactors and can be staffed by one or two licensed operators, w hich may
consist of students.
Next slide, please. The staff continues to make
improvements in how we regulate NPUFs. Some of these improvements were
developed to improve the review efficiency for new technologies. Others
provide benefit and clarification to the operating fleet of rea ctors and lessons
learned from events.
53
The staff has recently issued a key guidance document to
support our licensee's 10 CFR 5059 change process reviews. Thi s guidance
has been tailored to be specific for NPUFs, and the staff has observed
improvements when our licensees exercise these evaluations.
Additionally, the staff developed and has implemented
guidance to streamline license renewal reviews based on the ris k to the facility.
The staff has developed enhancements to our current
guidance to improve the efficiency in the review of new technol ogy. Holly will
highlight some of the key updates to support the licensing of t he SHINE
Technologies medical isotope facility and molten salt RTRs.
Moreover, the staff is furthering our risk-informed regulations
of these facilities in our dev elopment of new regulations. The staff has made
substantial progress in right-sizing rules for security which B ecca will highlight
in her presentation. And the final draft NPUF rule that is cur rently with the
Commission will provide efficiency improvements in how we regul ate NPUFs.
We have recently identified enhancements to our oversight of
NPUFs following our introspective review of the NIST fuel damag e event.
While the staff did not identify any significant gaps in the
current program, the staff is adding emphasis in several key ar eas that will
support increased observations of risk significant activities, enhanced training of
the staff and add provisions to formalize assessments at the pr ogram.
One area the staff is focusing on to make improvements is
how annual fees are assessed for NPUFs. In the near future, th ere will only be
two licensees that are required to pay annual Part 171 fees. S o if we don't
recover all of our budgeted resources, which now includes large licensing
projects, the financial burden for these two facilities can be significant.
The staff is actively working on mitigating solutions and is 54
planning engagement with the Commission on a proposal to resolv e this issue.
Next slide, please. The non-power production or utilization
facility license renewal rule, or commonly referred to as the N PUF rule,
establishes a more efficient, effective and focused regulatory framework and it
incorporates innovative and transformative approaches which are consistent
with the principles of good regulation.
The objectives of the NPUF rule clarify regulations affecting
applicants for new non-power advanced reactors, medical isotope facilities and
existing RTR licensees, including clarifying terminology and de finitions.
A few of the key changes include a new performance-based
accident dose criteria or 1 rem. This criterion was established based on the
Environmental Protection Agency's protective action guidelines and will provide
regulatory clarity for new and advanced non-power applications.
This criterion will also serve as the transition between a
research reactor and a test reactor, which allows this critical difference in
classification to be directly driven by the risk of the facilit y.
Additionally, the rule eliminates license terms for research
reactors and clarifies the license renewal process for commerci al NPUFs and
testing facilities.
This will provide resource savings for both the licensee and
the staff. The staff will be able to maintain an awareness of facility changes
important to safety through required periodic final safety anal ysis report update
submittals and a reasonable assurance of adequate protection ca n be
maintained even without license terms.
These improvements and other established in the NPUF rule
will bring clarity and reduce resources while promoting increas ed risk-informed
regulation that still protects public health and safety.
55
I will now turn the presentation over to Becca. Next slide
please.
MS. OBER: Thank you, Josh. Next slide, please. The
first security requirements applicable to RTRs were established in 1979 to
address the theft and diversion threat to special nuclear material used onsite at
RTRs.
This update also provided an exemption for SNM, which is not
readily separable and which has a dose rate in excess of 100 re m per hour at a
distance of 3 feet without intervening shielding. Also known as a self-protecting
exemption.
Both of these updates accounted for differences in
infrastructure and the associated risks as well as the safety o f RTRs.
In 1993, regulations were added to manage potential
radiological sabotage risks for RTRs with a power output equal or greater than
2 megawatts. Studies had determined that there was no significant radiological
sabotage if an RTR operates under 2 megawatts.
This was the first time RTR security requirements were based
on the type of facility instead of the type and quantity of SNM used or
possessed.
After the terrorist attacks of September 11, 2001, the
Commission directed staff to reevaluate security requirements for all facility
types. Additional security measures were implemented for power reactors and
fuel cycle facilities with Category 1 or 3 quantities of SNM us ing orders.
Because there were no power reactors or fuel cycle facilities
with Category 2 quantities of SNM, no evaluation was completed and no
additional security measures were developed.
Additional security measures for RTRs were implemented 56
using confirmatory action letters although most licensees have since
incorporated them into license conditions.
In general, these additional security measures included
enhancements such as vehicle barriers, personnel background che cks,
coordination and communication with local law enforcement, vehi cle and
personnel searches and visitor escorting.
Recognizing the unique safety and security attributes of
RTRs, the Commission directed NRR to assume the lead of securit y for RTRs.
This direction continues to s upport effective licensing and oversight of RTRs as
well ensuring RTR security requirements are right-sized for the threat
environment.
In addition, many RTR licensees have worked with the
Department, through the National Nuclear Security Administratio n's voluntary
security enhancement program to fund security enhancements that are
consistent with and supplementar y to the NRC's regulations in 10 CFR Part 73.
In this program, DOE and NSA conducts an onsite
assessment of a facility, funds any security related updates and offers response
force training. As appropriate, some RTR licensees voluntarily updated the
physical security plans to reflect these enhancements.
The close coordination between NRC and DOE and NSA
ensures that any changes to RTR technology, material possession or threat
environment are efficiently and effectively addressed.
Next slide, please. In 2013, SHINE Technology submitted an
application to construct a first of the kind medical isotope fa cility utilizing
Category 2 quantities of SNM.
Staff proactively began assessing the potential threats to this
type of material and facility to allow early engagement with SH INE on 57
appropriate security measures for its facility prior to and during the construction.
Ultimately, staff developed a list of risk-informed supplemental
security measures that were approved by the Commission. Some o f the
supplemental security measures include, but are not limited to, timeliness of
detection, increase of communication capabilities and robust re sponse
capabilities.
Appropriate supplemental security measures are determined
using a methodology that implements the requirements needed for the
commensurate risk.
Recently, multiple non-lightwater reactor applicants have
submitted plans and applications for various types of facilitie s that will use or
possess Category 2 quantities of SNM.
Building on its experience with SHINE, staff has engaged with
prospective applicants and licensees such as Abilene Christian University and
Kairos Power on security considerations through discussions and site visits.
This engagement will support a timely and efficient review of s ecurity
information because the applicant is aware of potential supplem ental security
measures and can account for that during the design and constru ction phases
as well as during the development of license Applications and security plans for
proposed non-lightwater reactors.
In parallel, staff is proactively looking to implement a process
that can be applied more generically to new applicants looking to use or
possess Category 2 quantities of SNM instead of needing to comp lete security
assessments on a case-by-case basis.
The staff is committed to preparing and implementing
technology and threat specific sec urity measures to facilitate timely licensing of
new facilities demonstrating an ongoing ability to readily adap t our licensing 58
framework to advanced technologies.
I will now turn it over to Holly Cruz to discuss licensing
activities. Next slide, please.
MS. CRUZ: Thanks, Becca. Next slide, please. NUREG
1537 includes performance-based guidance that is technology neu tral, the
regulatory infrastructure is sufficiently flexible to licensed advanced RTRs and
medical isotope facilities. Additionally, since many 10 CFR Pa rt 50 regulations
include specific entry conditions that are only applicable to p ower reactors, the
NRC doesn't have as many prescriptive requirements for advanced R T R s. T h i s
contributes to the flexible regulatory infrastructure.
For example, to support advanced reactor development, the
staff used NUREG 1537 for the recent Kairos Hermes construction permit
review. Since the NUREG is technology neutral and provides the flexibility to
consider unique design aspects, the staff was able to apply it in the review of
the functional containment approach, which is a design feature that is not
explicitly included in the guidance.
The staff has expanded this guidance and exercised
regulatory exemptions were necessary just to support these reviews. However,
since the RTR licensing framework is flexible, the NRC hasn't n eeded to grant
many exemptions.
To date, the NRC has granted exemptions allowing applicants
to submit environmental and safety assessments supporting a con struction
permit application independently and allowing an applicant to b egin
construction of their target fabrication facility prior to this middle of an
Application. Staff is also exploring opportunities to use exem ptions to
streamline the environmental process using shorter yet equally effective
documents, such as environmental assessments in lieu of environ mental 59
impact statements.
In 2012, the staff issued an interim staff guidance augmenting
NUREG 1537 for licensing radioisotope production facilities and aqueous
homogenous reactors. In 2020l the staff also endorsed an adapt ation of
NUREG 1537 prepared by Oakridge National Laboratory as guidance for use
by applicants for non-power liquid fuel molten salt reactors.
In addition, the staff is currently preparing a revision and
update of NUREG 1537, which would incorporate guidance develope d for
molten salt reactors, aqueous homogenous reactors and productio n facilities
and provide guidance for preparing environmental reports.
Next slide, please. Advanced RTR reviews are affirming our
approach to commercial advanced reactors. As an example, the t echnology
inclusive in advanced reactor content of application projects e mulate the
flexibilities of the NRC approach to RTR reviews and oversight. This
technology-inclusive, risk-informed and performance-based guidance will inform
upcoming advanced reactor application preparation and NRC revie ws.
The staff is also gaining valuable insights into the advanced
reactor technologies such as molten salt fuel and TRISO fuel.
These RTRs serve as a proof of concept for advanced power
reactors and their design, licensing, construction and operatio n can provide
data that will be used to support the reviews of advanced react ors such as
characterization of fuel performance and containment, model ver ification in the
area of neutronics and thermal hydraulics, information on performance of safety
systems, information relevant to the design and development of instrumentation
and controls, operating experience and data that informs identi fication of
research and development activities.
Designers may choose to construct and operate a small 60
facility, such as a research or a test reactor prior to a full scale commercial
facility based on factors such as data needs, cost, safety and time.
Data obtained from a research or test reactor could be used
to fulfill the testing requirements in the regulations during s ubsequent
application for a license approve or certification for a commer cial reactor.
Any data obtained using a research or test reactor and
subsequently used to support a commercial nuclear power plant d esign would
need to meet the quality assurance requirements set forth in 10 CFR Part 50,
Appendix B.
The staff plan to gather information from a licensing,
construction and operation to aid in the efficiency of future a dvanced power
reactor reviews.
Next slide, please. Medical isotope facilities will be key to
ensuring a domestic supply of critical medical isotopes. Current RTR licensees
such as the University of Missouri research reactor have used n eutron capture
to produce diagnostic medical isotopes.
The University of Missouri has also announced an initiative for
a new reactor dedicated to the production of medical isotopes.
Oregon State University has performed experiments for
medical isotope proof of concept and other RTRs are pursuing ot her methods
to produce therapeutic medical isotopes.
SHINE Technologies will produce vision-based molybdenum-
99, the parent isotope of technetium-99, which is used for diag nostic imaging.
SHINE is also pursuing therapeutic medical isotopes. The
facility consists of eight accelerator driven, subcritical irra diation units in a
production facility containing hot cells used for isotope separ ation from the
irradiated special nuclear material target.
61
The staff employed several novel approaches to the SHINE
review, which allowed flexibility and will help to ensure safe operations such as
the following.
We granted an exemption to SHINE allowing them to submit
their environmental and safety review applications separately, leveraged review
insights from fuel cycle facilities to support the review of th e production facility,
identified conditions for the licensing of operators and approv ed a phased
approach for the facility start up.
These approaches not only allowed the staff to address
aspects of the review unique to the SHINE design, but also meet the schedule
and complete the review within the established budget.
The staff is using lessons learned from the SHINE application
to inform the review of the Kairos Hermes, University of Illino is Urbana-
Champaign and other advanced RTR applications.
Other applicants have also initiated pre-application
engagement for construction permit activities related to the pr oduction of
medical isotopes.
Next slide, please. The NRC is engaging international and
setting the benchmark for other countries looking to establish new or expand
existing RTR programs.
There are currently 225 operating research reactors in 54
countries with another 20 on the horizon. The NRC staff has pa rticipated and
provided presentations at various international Atomic Energy A gency
workshops to share our best practices while affording member st ates the
opportunity to ask questions applicable to their programs.
The NRC also participates in missions with the IAEA to
provide member state recommendations for safety improvements as well as 62
periodic reviews of IAEA safety standards and other IAEA public ations.
The staff continues to engage with our counterparts at the
Canadian Nuclear Safety Commission to share knowledge supportin g
advanced reactor reviews. These interactions allow for us to s hare our
processes with our counterparts, promote international collabor ation and
support an efficient review process.
I will now turn the presentation over to Amy. Next slide,
please.
MS. BEASTEN: Thanks, Holly. Next slide, please. The staff
has made many improvements to the RTR inspection and examination program
from updating inspection guidance documents to leveraging elect ronic tools to
support operator licensing exami nation, development and adminis tration.
Notably, we have developed an RTR specific reactive
inspection guidance to augment Management Directive 8.3, Incide nt
Investigation Program for Event Response and Reactive Inspectio ns.
This guidance includes considerations of the unique set of
circumstances and associated risks for the event when recommending the level
of response, improvement in documentation of the recommendation to include
the basis for the level of response and enhanced clarity for do cumenting the
decision-making process for a reactive inspection.
The inspection staff is updating guidance to streamline the
level of detail in inspection reports consistent with other NRC programs.
This effort is also being coordinated with implementation of
the program into the reactor program system also known as RPS t o allow the
use of the report generator tool, which will increase the effic iency and
timeliness and issuance of inspection reports.
The staff routinely reviews inspection procedures and 63
guidance documents to enhance guidance for inspectors based on lessons
learned during inspections and events at RTR facilities.
The staff plans to formalize this review process following
feedback from the recent OIG inquiry. The observation of risk significant
activities is being reemphasized in the inspection scheduling t o ensure direct
NRC oversight of activities such as reactor operations, fuel mo vements and
significant maintenance activities.
The operator licensing staff is implementing improvements to
modernize the program, including efforts to provide the ability to conduct
electronic examinations using the collaborative learning enviro nment, CLE.
The CLE is an existing training tool used by the office of the
Chief Human Capital Officer. Operator licensing staff currentl y use the CLE to
develop living exam question banks for each RTR facility to all ow for more
efficient exam development. And the staff plans to transition the capability to
perform electronic written exam administration and grading.
Both the oversight and operator licensing teams are
leveraging the use of RPS to allow for enhanced tracking of act ivities and
management of performance.
Next slide, please. During the COVID-19 public health
emergency, staff maintained oversight of RTR facilities through a combination
of onsite and remote inspections. Inspectors maintained awaren ess of local
health conditions and various positions and policies taken on c ampuses in
response to the public health emergency and adjusted accordingl y to ensure
the agency continued to successfully meet the mission for RTR o versight
program.
The operator licensing staff continued to conduct exams and
issue licenses, prioritizing facilities identified as critical infrastructures.
64
Although we continued to issue operator licenses during the
public health emergency, there were delays with the issuance of the associated
certificates, which created a backlog of unissued operator lice nse certificates.
The staff has eliminated this backlog while ensuring a new
backlog was not created, which addressed an ongoing concern of our
licensees.
Consistent with actions taken for power reactors during the
public health emergency, the staff utilized a streamlined exemp tion process to
allow facilities to maintain compliance with regulations.
Inspectors and examiners worked closely with RTR facilities
to identify areas of responsibility and requirements impacted b y the emergency
and then pursued exemptions that permitted continued safe opera tion without
undue risk to the public.
Inspection guidance and policy continued to recognize and
accommodate the wide diversity in range of existing and future NPUFs. Event
tracking has improved through efforts with the operating experi ence group to
increase awareness of RTR events.
Enhanced cross-communication among staff and the
community of the National Organization of Test Research and Training Reactor,
TRTR, improves the effectiveness of event response and provides an
opportunity for staff and the TRTR community to incorporate les sons learned
and do training and procedures.
Additionally, the staff and TRTR community have enhanced
approaches for identifying and addressing safety culture issues observed in
events through the increased communication among all interested parties.
Next slide, please. The oversight and operator licensing
teams are placing emphasis within their respective programs to transfer 65
knowledge of the RTR program to other areas of the agency.
Both the inspection and operator licensing program staff are
focused on including a wide diversity of backgrounds and experi ences,
including hiring staff with previous RTR experience and power r eactor
inspection experience.
Additionally, staff has conducted knowledge management
training on various RTR related topics to encourage greater fam iliarity with
inspection and licensing processes and procedures and cross-tra ining for
interested individuals is encouraged.
In response to recent RTR events, the staff plans to enhance
the oversight program through improvements to training and guid ance to
include knowledge and chances of recognizing precursors that co uld lead to
fuel element damage.
The staff is utilizing these activities to support the
development of programs for advanced reactors.
Next slide, please. The inspection and operator licensing
teams have enhanced communications with both internal and exter nal
stakeholders. Internally, the oversight operator licensing and licensing staff
coordinate and share information on a routine basis.
Additionally, the RTR staff ensures regions are informed of
oversight and operator license examination activities that occu r at facilities
within respective regions.
To improve communications and access to RTR information
with external stakeholders, the staff developed an RTR inspecti on report link
within the NRC's public website, increasing transparency and co mmunication
with the public and other external stakeholders.
The staff issued Information Notice 202303, Recent Human 66
Performance Issues at Non-Power Production and Utilization Facilities, to share
operating experience and highlight recent events at RTRs that i dentified issues
related to safety culture.
The RTR staff and management conduct routine meetings
with the TRTR community to discuss regulatory and operational i ssues. The
staff has increased communications with state and federal agenc ies and has
hosted state representatives and the Department of Energy RTR fuels program
management on inspections at RTR facilities.
The NRC staff has taken steps to increase the sharing of
information with RTR licensees by providing access to the IAEA operating
experience database known as the Incident Reporting System for Research
Reactors, IRSRR.
The IRSRR allows the NRC and international organizations to
share operating experience in a single database. Enhancing com munication
domestically and internationally and provides opportunities to identify
commonalities among events reported globally.
The staff utilizes various forms to share information on RTR
events through participation in various forums such as the Amer ican Nuclear
Society conferences and the NRC hosted Annual Regulatory Inform ation
Conference.
I will now turn it back over to Scott for closing remarks.
MR. MORRIS: Thank you, Amy. So in conclusion the staff
recognizes the vital role that RTRs play in training the future nuclear workforce
providing services for a variety of applications in the advance ment of science
and technology.
They have relatively low source terms and are designed and
operated with significant safety margins. Accordingly, our reg ulatory approach 67
to licensing oversight of RTRs is graded and risk-informed. Th e staff continues
to make progress developing regulations and guidance to provide further
enhancements in how we regulate these facilities while maintain ing their safe
operation.
That concludes the staff's remarks and we look forward to
your questions.
CHAIR HANSON: Thanks, Scott. And we will begin again
with Commissioner Caputo.
COMMISSIONER CAPUTO: Thank you all for being here this
morning and for the very thorough presentations.
It is quite timely given the current licensing work with
advanced reactors in this area and the policy issues that are being presented to
the Commission with regard to research and test reactors.
I also want to point to current paper pending before the
Commission on microreactor licensing that proposes to use some research and
test reactor processes with regard to testing fueled, manufactu red
microreactors at a factory.
This is the type of innovative thinking that I am really excite d
to see happening within the Agency. Of course, the devil is in the details as to
how this is going to work.
So once aspect is how we formalize a disciplined process for
considering potential changes to regulatory requirements for li censees.
For non-power utilization facilities, it is fairly straightforw ard
for a majority of them. As we have discussed a couple times al ready this
morning, the Atomic Energy Act tells the Agency to impose the m inimum
amount of regulation on these licensees for research and development licenses
under Section 104.
68
For other utilization facilities, we have formal requirements
under the backfit rule the Agency uses when it is considering i mposing
regulatory changes.
There is, however, a longstanding interpretation that the
backfit does not apply to non-power reactors. And that interpr etation is
generally not an issue because most of them qualify for the minimum regulation
provisions. However, things are beginning to change in this ar ea.
So one of these changes already is the existence of a
licensee for a non-power medical isotope utilization facility u nder Section 103
rather than Section 104. And there is the prospect of potentia l additional
licensees.
So if we continue with the interpretation that the backfit rule
only applies to power reactors, such facilities would neither have the backfit rule
nor the minimum regulation provision under Section 104 when it comes to
scrutinizing potential regulatory changes.
So former Chairman Svinicki expressed these concerns in her
vote on the Paper 1962 regarding non-power utilization faciliti es and licensed
renewal. And I share those concerns. But that's not the end o f it.
As I mentioned earlier, microreactor licensing, the paper
pending before the Commission proposes an option for licensing microreactors
under 103 and treating them as non-power utilization facilities for the purposes
of operational testing.
So given my focus on having discipline processes for
considering regulatory changes, this raises additional question s under the
application of the backfit rule. So there are some aspects of the design of a
manufactured reactor that would be controlled under the backfit rule during the
testing.
69
A microreactor itself would eventually be controlled under the
backfit rule once it is licensed as a power reactor. But if we treat it as an NPUF
during operational testing, portions of the facility as a whole that are not part of
the manufactured reactor design would be an NPUF licensed under Section
103 without the minimum regulation requirement.
So it strikes me as an untenable situation for manufacturers of
microreactors and medical isotope non-power utilization facilit y licensees if we
persist in this interpretation that the backfit rule only appli es to power reactors
given that NPUFs have no explicit controls on regulatory change s under
Section 103. So the backfit rule itself does not include a lim itation to power
reactors anywhere in the text and it would be simple to apply t o additional
facilities.
I believe the staff should re-examine the applicability of the
backfit rule to all production utilization facilities licensed under 50 and 52 and
harmonize the interpretation of the wording of the regulation i n order to provide
improved regulatory certainty for all NPUFs and avoid establish ing barriers to
entry for potential microreactor manufacturing licensees.
I believe this could be accomplished through some form of an
interpretive rule or generic communication and should be follow ed by making
durable changes to NUREG 1409.
Scott or Rob, can you just give me your views on the issue?
MR. MORRIS: I will just start and then I will hand it off to
Rob.
So I think you are correct. There is nothing explicitly writte n
into the rule that would preclude RTRs being covered. But as y ou pointed,
historically we haven't.
So with that as -- so we could. We just haven't. But given the 70
context that you just described, maybe Rob, you can share what we've been
thinking about in this arena.
MR. TAYLOR: Yeah. So I think your point about the
principles of good regulation and clarity and reliability in our regulatory decision
is a very good point. And I think that if that's something we need to add to
assist the development of these technologies, we certainly coul d explore that.
I think in practice, the staff's position is that we're not going to
move forward with proposing or implementing or forcing changes on NPUF
facilities licensed under 104 wit hout going through a very rigorous process akin
to the backfit rule.
We recognize the stability and im portance of our decisions.
And absent a substantial safety issue or an adequate protection issue, I think
we would apply the same rigor. If it is important to put that into durable
guidance or requirements, I think we can certainly pursue and c onsider that.
CHAIRMAN CAPUTO: Well, I think putting it into durable
guidance is probably important just for the sake of clarity and reliability for
applicants.
Just to be clear that they will not be put in a situation where
our regulations are perhaps influx in a way that was not antici pated. Thank
you.
CHAIR HANSON: Thank you. Commissioner Crowell?
COMMISSIONER CROWELL: Thank you, Chair. Thank you
to all of our panelists today. I always learn something from t hese discussions.
I'm going to ask a couple of questions, and I will just preface that any of you are
welcome to use Scott as your lifeline and have him answer it if you don't like the
sound of it.
Rob, I'll start with you. So in listening to your presentation 71
and looking at some of your slides, it's clear that power level p l a y s a k e y r o l e i n
the level of risk and in regulatory oversight you apply for RTR s.
But even to someone as simple as mean, it seems a little bit
basic to just look at it through that framework. And there is a pretty wide variety
of technologies in the RTR world. So tell me why power level i s so central but
also what other considerations are made so that I can have fait h that it's a
fulsome risk evaluation.
MR. TAYLOR: Thank you for the question, Commissioner.
You are correct that the regulations were built, and our guidan ce was originally
built, on power levels. That was a convenient way to do it.
I think if you look at what we're trying to do it today, we're
more consequence oriented. What's the risks to public health and safety? And
the power levels are less important. And we're happy to look a t how to adjust
those as we go forward to remove arbitrary thresholds on power level that may
not be reflective of the diverse technologies, right?
It should be really based on the relative risk of the facility and
the source term that's there. And that's what we should really be making our
decisions on.
So, yes, we have a framework that was originally based on
that 30, 40 years ago and stuff. But I think we're moving all of our thinking
towards a more dose-oriented public health and safety consequen ce
framework.
COMMISSIONER CROWELL: Josh, I'm going to go to you
next. You know, unless you have an RTR in your backyard or may be you went
to a university that had one and you're aware of it, you know, most folks
generally aren't too familiar with these types of reactors or e ven their existence.
But those outside of the groups that I mentioned who may be 72
familiar with it, are probably familiar because of the event at NIST. And from
the presentation, it doesn't sound like we changed too many thi ngs as a result
of NIST overall in looking at safety and oversight.
So just tell me how you would communicate to someone who
doesn't have familiarity with reactors and research and test re actors, why they
shouldn't be concerned that if one were established in their co mmunity that an
event like NIST is going to happen there?
MR. BORROMEO: So is your question relative to, you know,
what we changed or the risk to the facility or a little bit of both? I can answer
both ways.
COMMISSIONER CROWELL: Both. But if I'm in, you know,
rural Alaska, and that's not a great example, and there was a p roposal to build
a research test reactor there, and I'm like, well, then we're j ust going to have an
issue they had at NIST. Why is that not (simultaneous speaking )?
MR. BORROMEO: So somewhat to what Rob was
mentioning, right, and what you asked about power level, right? We've used
power level as a surrogate for risk for many years, right, the 2 megawatt
threshold for our oversight, you know, has really kind of been something that
has driven the amount of inspection that we have to do.
And so the lower power translates into low source term, right?
And we can have, like, emergency planning areas that are very small. You
know, NIST is at its fence line. But a lot of these universiti es have emergency
planning areas that are within the building itself.
So, you know, someone can be at the site boundary, right,
which could be the building during an event and be well below t he concern for
safety.
COMMISSIONER CROWELL: Okay. Do you want to add to 73
that?
MR. MORRIS: Yeah, thanks, Josh. I would just add that it's
not that there weren't -- I know you didn't say this. It's not that there weren't any
changes to our oversight program. There were. The key ones st emming from
NIST were focused on looking at risk significant activities tha t occur, like,
refueling for example and actually having eyes on during those where as in
historically we didn't necessarily do that.
So these are some of the fine-tunings that we're doing, just to
our oversight program. So there were lessons learned, I guess, is the point.
And there are changes that have been incorporated.
COMMISSIONER CROWELL: And if you don't remember,
the public asked, was NIST the result of technology deficiency, operator error or
lacks oversight? What would the answer be?
MR. BORROMEO: The latter two mostly, I would say, right?
So that's why we wrote the confirmatory order to have NIST take a look at
things like their problem identification and resolution proces ses, their
leadership accountability.
So they are, you know, working on improving those. We are
remaining close oversight of those improvements as well as ensu ring that
they're operating safely whenever they're, you know -- as they're trying to
recover from the event.
COMMISSIONER CROWELL: And I would just, as a general
matter, the -- well, you know, some of these advanced reactors and certainly at
the research testing size and scale can have a relatively small site boundary
because of the relative risk, you know, that's well justified, you know, from a
technical and risk perspective, but from a psychological perspe ctive for the
public, it's hard to get your head around that you can be in an other room next to 74
a reactor and not have an undue amount of risk.
And so it's important to be able to characterize these things
and put it in context for people who don't, you know, fully app reciate all of the
advanced science and engineering things that even your staffs d o.
Moving on here, Rebecca, it was very helpful to hear the
history of our security framework. And I'm wondering if in ret rospect there is
any regret post-911 for not doing a review of Cat 2 facilities as well as Cat 1
and 3. And you would think that if you did it for the one lowe r and the one
higher that you could capture the one in the middle.
So tell me if that was an oversight in retrospect given what we
are dealing with now with Cat 2 facilities coming onboard?
MS. OBER: Yes, I mean, I think in retrospect where we are
now, if we had addressed it then, it would definitely simplify things at this time.
However, I will point out we are, you know, 20 years past that.
The technologies have changed. The threat environment has cha nged. And
so completing this review now is probably the most accurate rep resentation of
the necessary supplemental security requirements that those sor ts of facilities
should use in terms of the threat in technology.
Scott was there at the time --
MR. MORRIS: Ouch.
(Simultaneous speaking.)
MR. MORRIS: So absolutely, you know, I don't want to say
Monday morning quarterback -- I don't want to -- I just did.
At the time, I can just tell you that we were resource
constrained, and there were a lot of things coming at us as an agency,
particularly in the security realm.
And so we had to make choices about where we are going to 75
spend our resources and where we weren't, and that was one of t hem.
(Simultaneous speaking.)
MR. TAYLOR: A big benefit today to taking this on is that you
actually have facilities that are going to possess the Cat 2. So you now
understand the business models and the needs of those facilitie s.
So building a program today with that understanding, you
build a better box for it than you do when you try to take it o n generically and
guess at what the needs are going to be. So the pros and cons to both
approaches is something, and I find that the industry shares a lot of information
that helps us build these better.
COMMISSIONER CROWELL: And I don't disagree with you
at all, Robert, but I think even a generic look given that you' re capturing Cat 1
and 3. In any event, here we are.
Rebecca, one more question for you. I know that's important
to have as much, you know, consistency and predictability for l icensees and
applicants of what their security requirements are going to be. That being said,
there is a lot of variety of technologies and new technologies in the world of
RTRs so I could also argue that an ad hoc approach is appropria te in some
instances because of the uniqueness of the facility. So tell m e how you
balance those competing kind of priorities.
MS. OBER: Yes. So I guess in terms of specifically the Cat 2
SNM security requirements, as we stated, those are the ones tha t we have yet
to really address in terms of additional security measures.
The first facility that came in was SHINE obviously. And so
based on that, we did look at the threat level, the risk to tha t technology and
developed a methodology and supplemental security measures that we
reviewed and approved by the Commission that we, as staff, are planning to 76
use as a basis in looking forward to future technologies.
We recognize that when these new technologies come in,
there will be some sort of a case-by-case analysis, but the ide a is to have a
general process and methodology that we can start with as well as a list of
supplemental security measures that are appropriate for that ty pe of material.
And then we can reevaluate each licensee at that time, but
we are starting with the framework, we're starting with the methodology that will
ideally make that review more efficient.
COMMISSIONER CROWELL: And then that will evolve or be
memorialized over time as we gain experience and there's --
MS. OBER: Yes. Yup, lessons learned are always, you
know, implemented.
COMMISSIONER CROWELL: Okay. Thank you. I
appreciate it. Thank you, Mr. Chair.
CHAIR HANSON: Thanks, Commissioner Crowell. Thanks,
everybody, for the presentations this morning. You know, I wan ted to start off
echoing something Commissioner Caputo said, I thought on a firs t read
through, I thought the microreactor paper was very good, and it had a lot of
really novel and interesting concepts.
And it admits in that paper, it's a first step towards thinking i n
novel ways about our existing regulations in order to support k ind of multiple
deployments of standardized designs.
And I think the issues that Commissioner Caputo raised as
well about backfit and 103 versus 104 and so forth are also rea lly worth diving
into and exploring. And I look forward to, you know, all four of us working
together and with the staff to turn the microreactor paper and also the NPUF
final rule as well.
77
With that, I want to dive in a little bit, Rob, I think on this 104c
issue and the notion of minimal regulation. I mean, Dr. Towell was very
diplomatic, and I appreciate that. But there is also -- I gues s I think I need you
to paint picture or have some context for me around the audit p rocess with
Abilene Christian in particular but also within, you know, any reactor.
And the number that really sticks with me is the kind of 300
audit questions. And what those were about, how necessary, you know, why
did the staff think that those particular areas were necessary or that particular
volume was necessary at this stage in the process.
You know, I still echo my remarks, I think, about the Kairos
review, Rob, and I think the outstanding job the staff did in t erms of structuring
that, but also really focusing on that, right? Both from a 52 to 50 perspective
but also a CP versus OL perspective. So can you kind of put so me context
around that for me, please?
MR. TAYLOR: Yeah, certainly. The audit process is a
phenomenal tool to allow the staff to have a full understanding of the design
and the technology.
So you will see a number like 300 questions. A lot of that is
confirmatory. Do we understand what your application says and making sure
that we fully understand the safety profile and the basis for t he facility. And
what that leads to is very few requests for additional informat ion because we
don't have to go seeking that i nformation in a request for additional information.
So we usually deal with those questions in a dialogue format.
And we'll put the question out so that they're ready to addres s it. And a lot of
them go away very, very quickly in a dialogue during the audit.
So we'll ask questions making sure we have the full picture of
the safety case and the safety basis decision that we need to m ake. And then 78
only the subset where we say, hey, we need something on the doc ket that isn't
in your application. Do we proceed to the RAI process? So the n we're very
rigorous in what things are and how much we ask for and what's necessary.
With regards to the ACU application, I think overall it's going
well in that respect. Specific to the areas where we might hav e a little bit of
disagreement, they are around design changes that ACU is making to specific
materials in the safety-related case of the facility, so safety-related components
in the facility.
And those were environments where there is data that
demonstrates there is potential for degradation. And we want to make sure that
we have enough information at the CP stage to understand whethe r there is a
true long-term degradation concern in that environment because if we approve
the material now, we want to be reliable and not come back at t he operating
licensing stage and say, hey, the data says you don't have enou gh of a basis to
support the safety related case of that component.
So we're trying to get to that right threshold. I can understand
why different perspectives may exist on how much is needed. Bu t as a safety-
related component in the facility that there is data and there is information that
says, hey, this environment that it's going to be in might pose degradation risks.
We want to make sure we have enough information to say that's manageable
over the lifetime of the facility.
CHAIR HANSON: Yeah, look, that's super helpful. I mean, I
want to recognize from where I sit, you know, the really limite d ability that I'm
going to have about specific technical related questions that a re kind of under
review. But you can also understand that, like, 300 sounds lik e a big number.
MR. TAYLOR: Mm-hmm.
CHAIR HANSON: You know? And I think it's important, too, 79
from my perspective, and I hope my colleagues will agree that, you know,
having these really focused and efficient reviews under 104c an d the minimal
regulations is really important.
And I think it's really important for really kind of the future of
risk informing subsequent reviews as well, right? Because what happens then?
We issue a CP. They go put a shovel in the ground, hopefully get an OL. And
that's how we're going to learn, and that's how we're going to get data that's
going to actually benefit everybody.
And so asking the right kinds of questions up front is really
important in order to ensure public health and safety, but also allowing that
progressive path forward to really get to in a way that the pay off, which is the
operating data that we're going to see and the real data that w e're going to see
from some of these degradation mechanisms that we kind of want to probe up
front. Yeah, okay. Good. Thank you.
Josh, can you give me a sense of where we kind of stand with
license renewals for research reactors? I've heard various thi ngs over the
things about kind of where we are, how many, how long they're t aking, you
know, the capabilities of our licensees, et cetera?
MR. BORROMEO: Sure. Yeah, so staff has been working
really hard over the past few years to really work down all the renewals. And
right now we have two in-house right now. So those two we are progressing
along very well with only a handful of sections remaining on th ose. So we're
making good work on those.
With the university licensees, and I think it was mentioned in
the last panel, they only have a handful of staff, right? So w hen we do ask a
question sometimes it -- you know, getting the right resources in place can take
a little bit longer which is why sometimes, you know, the revie ws get a little 80
lengthy.
But we're being told by our licensees what would really help
that out would be the NPUF rule, right, and the non-expiring li censes which
would really provide a benefit for them resource-wise as well a s the NRC staff.
CHAIR HANSON: I really like this concept in the final NPUF
rule of not having an expiration on some of these, particularly, right, if you go
out and see these reactors. They've been in place since the late 60s, early 70s.
They've operated safely at low powers for a really long time. They're going to
continue to do that under the right conditions, et cetera.
I guess I do want to -- the other aspect of that final NPUF rul e
thought is the periodic submission of final safety evaluation r eports, basically
updating that on occasion.
Can you just remind us the frequency there and that we
haven't -- you know, kind of what's the trigger resubmitting an d FSAR for
licensees?
MR. TAYLOR: Right. So in the NPUF rule, initially we are
going to issue orders to have our licensees kind of stagger the submittal of their
first FSAR. But then after that, it's going to be on a five ye ar basis, right, and
they are going to be required to submit it on that periodicity.
Within that, they will have to include any changes that they
made under 5059 and will be able to remain, you know, aware of anything
significant, right? And during that time, we'll provide oversi ght, right, for those
changes, too.
C H A I R H A N S O N : I s e e. S o i t ' s k i n d o f a - - t h a t ' s v e r y h e l p f u l.
I mean, if nobody had made changes for example under 5059 beca use they
didn't have a need to, they could ostensibly resubmit the FSAR that they had
previously submitted and said, look. Everything is still good. We've learned a 81
few things. You know, here are kind of the updated sections, e t cetera. It is
really a management -- it's a regulator oversight by the differ ences the?
Do I have that right?
MR. TAYLOR: Yup, yup, yup. Absolutely.
CHAIR HANSON: Okay. All right. Very good. Thank you.
Let's see.
I think I'm just going to wrap it up there. Thank you all very
much. I am going to hand it over to Commissioner Wright, which is never a bad
idea.
COMMISSIONER WRIGHT: Happy I'm last. So good
morning and thank you for your presentations and the work that went behind it
to get ready. So thank you and everybody on your team who supported you.
So as I told the first panel, you know, the RT world to me it's
kind of unique. It's interesting. And that's absolutely neces sary. It's needed as
we advance the safe deployment and safe use of nuclear technolo gies, right?
Regardless of their use, commercial, research, medical, whateve r. So I really
appreciate all that you and your staff are doing in this area. And it is helpful.
You know, we have a mission and we're trying to get really focu sed on this.
Before I actually get to the questions, I wanted to ask
something here a little bit different just because I'm curious. Has anyone here
on the panel today, do you have any personal experience through RTRs at
school? Did any of you do that m aybe as part of your college s tuff?
MS. BEASTEN: I did. I was a senior reactor operator at the
University of Maryland, actually.
COMMISSIONER WRIGHT: So is there any part of that
experience you would like to share maybe? How do you bring tha t insight and
experience to your job here?
82
MS. BEASTEN: So to make a really long story short, the fact
that the University of Maryland had a training reactor was the reason I decided
to go there for graduate school. It would have been an invalua ble opportunity
to learn how to operate it and use it for my PhD thesis researc h. You know not
a lot of people get that opportunity.
And I knew I wanted to do something in the nuclear field, and
that was the best thing I could have thought of to get me a leg u p t o e x p l o r e a l l
of the options available that existed in the industry. I wound up here with the
NRC, which has been a great way to translate what I learned from operating the
reactor to what I do day to day.
COMMISSIONER WRIGHT: Was there like an RTR college
team group here at the NRC?
MS. BEASTEN: No, but I did want to start a fantasy football
league.
COMMISSIONER WRIGHT: Okay. Very good. I want to
thank you for that. And I'm going to stay with you for a secon d. Because
during some of my trips to RTRs over the last couple years, lic ense certificates
were a big deal. And it became a big concern of mine, and I st ayed on top of it
because some of them graduated and never got their certificates. And that's an
important accomplishment, right?
So I just want to recognize the staff and thank them and thank
you for prioritizing that and to clearing that backlog and try to keep it clear. And
if I could ask, how did you go about clearing it? What did you have to do and,
you know, are those actions still in place, you know?
MS. BEASTEN: So processing the certificates requires a
certain amount of onsite presence, which is why struggled with it during the
COVID-19 health emergency. We didn't have a lot of staff here to facilitate the 83
issuance of the certificates.
So we also previously issued them in batches. And now we
issue them as soon as the operator license is issued. So, you know, we've
taken steps to just stay on top of it.
COMMISSIONER WRIGHT: All right. Well, thank you.
Because it's helpful when people notice it.
Holly, how are you this morning? So the first panel touched
on sharing, you know, operating experience across members. So how does the
staff ensure that it's consistently receiving and incorporating the latest and
greatest operating experience? And how does the NRC share that information
it receives from one facility on operating experience across th e RTR industry?
MS. CRUZ: Thank you, Commissioner. The event tracking
has improved efforts with the OPI group to increase awareness o f RTR events.
We've also enhanced cross-communication among staff and the community of
TRTR. That has improved the effectiveness of event response and provides an
opportunity for the staff and the TRTR community to incorporate lessons
learned and to training and procedures.
RTR staff and management conduct routine meetings with
TRTR community to discuss regulatory and operational issues. I think Amber
mentioned that this morning as well. And the staff has increas ed
communications with state and federal agencies to host state re presentatives
and the DOE RTR fields program management on inspections at our DR
facilities.
And Amy had mentioned the operating experience database
the NRC has taken steps to increase sharing of information with NRC's
licensees by providing access to the IAEA database. And the IR SRR allows
the NRC international organizations to share operating experience in a single 84
database and that enhances communications domestically and inte rnationally
and provides opportunities to identify commonalities among even ts report
globally.
And then finally the staff utilizes various forms to share
information on RTR events through participation in various form s such as ANS
conferences and through the RIC.
COMMISSIONER WRIGHT: Right, right. Thank you. Scott?
MR. MORRIS: I just wanted to briefly add. It didn't come up
in this morning's panel, I don't think, and it didn't come up i n ours. But there's
an analog to the TRTR. It's called IGOR. And I'm not going to remember what
that acronym means, but it's an international group of research reactors. Let's
just say that's what it is. I think that's what it is.
But they also meet annually with the national TRTR here. So
that's yet another opportunity to expand that.
COMMISSIONER WRIGHT: Good, great. Thank you. So
my colleagues were asking some questions earlier, and I think the Chair started
when he came to you about, you know, the 104c stuff and minimum amount of
regulation and all that. So I'm not going to go there.
But in the first panel we heard a mention that we've had some
turnover. And we've had turnover everywhere, right? And I thi nk they
specifically said they lost three people on a core team if I he ard that right?
MR. TAYLOR: The team lead changed over three times.
COMMISSIONER WRIGHT: They did?
MR. TAYLOR: Mm-hmm.
COMMISSIONER WRIGHT: So it does raise a little bit of a
concern because the core team, we're supposed to -- the whole i ntent of that
purpose is to keep that consistency, that familiarity, and the same people, same 85
thing, move it start to finish, right?
So when we lost those people and they turned over, was it
because of retirements, or did people go to different agencies or did they go
somewhere else within the NRC? I mean --
MR. TAYLOR: So we lost one externally to a vendor for an
advanced reactor. We lost one to a great promotion opportunity inside the
agency. And then we lost a third to a commission office so.
COMMISSIONER WRIGHT: I was afraid you were going to
say that. Yeah, yeah. I resemble that remark. Yeah. But it does, it speaks to
just the number of people we have, right, and the resources?
MR. TAYLOR: And they are all nuclear engineers, which is a
very critical skill set and a challenge for us. And it continu es to be a challenge
for us.
The beauty of the core team, though, is they're a team. So
just because I lose a piece of the puzzle, the rest of the puzz le is still there. So
I need to get a new piece and put it in there. And there's a k nowledge
management and come up to speed. But it's not like that work j ust
disappeared, right? That work is still with all the rest of th e core team because
they're doing the review together.
COMMISSIONER WRIGHT: Right.
MR. TAYLOR: So it actually helps us in some respects when
we do have turnover. The core team adds a value in that functi on.
COMMISSIONER WRIGHT: Right. And if I could follow up
on that, so when you're building your core team, you know, I kn ow that we've
hired, what, roughly 600 people in the last couple years.
And it takes a while to get them acclimated and ingrained into
the NRC way of doing -- sometimes three years or so, right? Bu t they still don't 86
have the experience. They're just building that knowledge base.
So where are you pulling your core teams from? I mean, is
that pool of talent like really small now and how long will it take to grow that
pool?
MR. TAYLOR: So the core teams are principally in our
advanced reactor DANU Division. They are staffed within that division already.
So they're inculcated with the thinking, the approach that we want to take from
the beginning. So they're constantly getting trained and broug ht up to speed
even before they're put on a core team relative to that.
So we have a constant training and development program as
part of those activities. And then when we build the core team, w e t r y t o m a k e
sure that core team has a lot of diversity with regards to expe rience and
capabilities and backgrounds and things like that so we that we come at a
project from all aspects and that we challenge ourselves suffic iently.
So, yes, it's a challenge. We put the best mitigating
measures we think we can in place.
COMMISSIONER WRIGHT: So one of the things -- the
reason I'm bringing it up and wanted to kind of address it. Bu rnout has been
something that I've heard that you've had people who have been really
intensely engaged in maybe rulemakings and other things that th ey are tasked
with, right?
And then on top of that, they're doing this. And so you take a
burned out person here, and they're already burned out when the y're going to
work for something else. Is that really being addressed now wh ere we're
relieving that?
MR. TAYLOR: So we're doing our best. Staffing continued to
be a challenge. We're understaffed relative to the budget as w e try to hire the 87
critical skill set. So we've done a great job of hiring. I th ink we need more work
on some critical skill sets as we work on it.
And those are the ones that are very difficult to compete with
externally. So, yes, there are staff who are highly capable, v ery talented and
can work on multiple projects. And we try to manage the burnou t and we try to
keep, you know, that positive work-life balance going and stuff like that.
So we focus on it, and we do the best that we can. And if it
ever comes to a person versus schedule, we're going to make the decision to
protect the person. We care about our people enough. We need them in the
long-term. We can't ruin them in the short-term just for one s uccess.
We'll adjust. We'll figure it out and balance.
COMMISSIONER WRIGHT: Well, I appreciate it. And I know
it's difficult. And we're aware, you know, at the Commission level. And, again, I
know I'm not speaking for all of them because I can't, but I kn ow they probably
share the same feeling. And that is whatever we have to addres s that we need
to do to help there, please keep us informed on that because so metimes I feel
like we get to it late, you know? And I don't think it's on pu rpose, but we want to
help in any way we can.
MR. TAYLOR: I think one of the most important things is to
collect the data on why staff leave and understand that data an d then figure out
how to act on the data.
MR. MORRIS: This is a segue of what I was going to offer is
that it's not just about hiring and training. It's about reten tion. And you now,
because we've had the conversation about retention related acti vities. We're
doing another critical skills for other critical skill sets. B ut this is one of them.
COMMISSIONER WRIGHT: Okay. Thank you so much.
CHAIR HANSON: Thank you. Thank you all for your 88
presentations. Thanks for our first panelists. Many of them a re still here in the
room. Thanks to my colleagues. I think we had a good discussi on this
morning. We covered a lot of really meaty topics. I think thi s is a really
intriguing area and there is a lot of growth and innovation tha t is happening
here. I think we're really seeing the benefits of a lot of the students who are
engaged in this.
I mean, one of the great things about the University of
Maryland program is not only can you use that little reactor to do your PhD
work, but if I remember correctly, Amber told me once that even at, you know, a
reprobate humanities major like me can go and get a reactor lic ense, an
operator license at the University of Maryland, which is pretty great as well in
terms of bringing students into this field.
So I really appreciate the discussion and with that, we are
adjourned.
(Whereupon, the above-entitled matter went off the record.)