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NEI Presentation Slides on Rapid and Large-Scale Nuclear Reactor Deployments for Remote Industrial Applications - May 14 2024 Public Meeting
	ML24130A197
Person / Time
Site:	Nuclear Energy Institute
Issue date:	05/09/2024
From:	; Nuclear Energy Institute
To:	; Office of Nuclear Reactor Regulation
References
	Download: ML24130A197 (12)
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Rapid and Large-Scale Nuclear Reactor Deployments for Remote Industrial Applications

May 14, 2024

Design Features Applications and Use Alternative Regulatory Cases Approaches

Physically small and

Remote locations

Incentivize safety simple and micro-grids enhancements

Low risks and

Industrial applications

Avoid undue consequences (heat and power) regulatory burden

Small footprint - land

Not near population

Leverage use of and environmental centers manufacturing

Safety relatively

Large volume of license or design insensitive to site deployments certification conditions

Deployment in

Technology-inclusive,

Factory construction months not years performance-based

Site assembly

No disproportionate and risk-informed

May load fuel at regulatory costs

Oversight scaled to factory and ship

Limited or no on-site the safety profile fueled fuel movements

More similar to

Fully replaceable

Limited time of used research and test modules fuel on-sitereactors

Factory Operational Testing X X NEI 2019 Paper NRC SECY 20-0093 Timing Authorize to Operate Enclosure Review Scope and Effort X (Hearing & ITAAC)

Regulatory Oversight X XReplacement at Site X Enclosure Emergency Preparedness X X General License X Physical Security X XFueled Transport Enclosure Aircraft Impact Assessment X X Storage of Used Fuel Enclosure Staffing and Training XDecommissioning Enclosure Annual Fee XMaritime Applications Enclosure Manufacturing License X Space Applications Enclosure Scope Commercial Mobile Enclosure

Status of previously identified Micro-reactor regulatory issues

Some are resolved (e. g., Emergency Preparedness)

Some are partially resolved (e. g., Annual Fees)

Some are in the process of being resolved (e. g., Remote Operations)

What s New

Interest in Oil & Gas Upstream and business needs for regulatory schedule and cost

1. Less than 180 days from specific site identification to operations

2. Regulatory costs are less than 1% of capital and O&M

Scope of effort

Clarify regulatory needs for rapid and cost effective large-scale deployments

Resolve expanded scope of regulatory issues and propose solutions

Potential acceptance criteria

Potential off-site doses very small - e.g., site boundary EPZ (EPA PAG at only a few hundred meters)

Security by design - acceptable consequences without on-site interdiction

Environmental impacts - very small and less than alternatives (e.g., diesel generators or natural gas plant)

Safety and environmental impacts independent of site conditions

Not located near population center or densely populated areas

Nuclear safety not impacted by energy conversion island or co-located industrial activities ©2024 Nuclear Energy Institute 5 Use of Alternative Approaches Depends on Licensing Basis

Potential conditions for licensing basis

Maximize use of manufacturing license / design certification to bound site review scope

Use of site parameter envelope to verify site meets pre-approved conditions

Factory fabricated prior to obtaining final site license

On-site work focused on assembly and emplacement - minimal ground disturbance or on-site concrete

Remote operations and/or monitoring, with minimal to no dedicated on-site staffing

Use of pre-existing reliable data for site characterization (e.g.,

Traditional COL or CP/OL Scope

Rulemakings General Approvals IT AAC General Site Approvals (Not Design or Site (Specific to a Design) (Closed at Factory)

Dependent)

Part 52 Fueled Micro ML or DCD Reactor General Licensee Approvals (e.g., Programs, Part 70 Seismic Isolators Financial Qual)

ANR GEIS (100 issues)

Site Specific Approval*

Site Parameter Site #1 Site #N Envelope (Confirm (Confirm GEIS Micro site site Supplement conditions conditions (21 issues) within within SPE) SPE)

2025 2030

T - 60+ Months-> T - 24 Months-> T - 18 Months-> T - 12 Months-> T - 6 Months-> T = 0->

Manufacturing License Manufacturing License Application Submitted Approved Facilities for Fabrication NRC ML Review Operational

Duration Dependent upon Scope of Novel Approaches and Site Issues Addressed

<-Application-> NRC Approval Submitted Contingency for 1st NRC (Additional NRC Review) Review 6 M onths 2 M onths

Month 1 Month 2 Month 3 Month 4 Month 5 Month 6

Application Application Accepted & NRC Approval Submitted Construction Authorized and Authorize NRC Acceptance to Operate Application Prep & and Construct NRC Verification of Compliance with Site NRC Final Approval Site Characterize Review Parameter Envelope 1 M onth 1 M onth 2 M onths 1 M onth

NRC Hearing Process (Contested)

3 M onths

Site Selected Operation Starts

Pre-Construction Construction (NRC Prior Approval) Delivery & Commissioning &

(No NRC Approval) Emplacement Startup 1 M onth 1 M onth 1 M onth2 M onths

(Actual staffing needs to be determined based on HFE and safety/security -by-design approaches)

Licensee Staffing NRC Oversight Staffing Remote Operations Center

Operations Center* Objective: Leverage RTR

Primary role: monitoring and oversight model and robust permissive operation of data environment.

automated systems

Inspect Fleet-implemented

Operators manage multiple programs and remote S i te s reactors per FTE operations

Program owners and other

Visit each site ~ once per year support concurrent w/ Licensee (w/

~70 FTEno-notice optionality)

Field Technicians* ~3 FTE incorporated into

Visit sites ~ once per weekeconomic models

Maintanence & surveillance (when not supported by digital assets)

~50 FTE

Limited/no on-s i te S taff Regulator y Topics That Potentially Need Alternative Approaches B u c ke t 1 B u c ke t 2 B u c ke t 3 B u c ke t 4 (Site License) (Technical) (Operations) (Non-Urgent)

Issue Potential Issue Potential Issue Potential Issue Potential

1) Environment High 7) Meteorolog y High 12) Lic. Review Fees High 22) ML Scope Medium Review 2 ) I TA A C High 8) Seismic High 13) Annual Fees High 23) Flooding Med-Low

3) Site License Med-High 9) Aircraft Impact Medium 14) NRC Oversight Med-High 24) Other External Hazards Low Assessment

4) Const. at High 10) Testing at the Med-High 15) On-site staffing Medium 25) Population Siting Low Docketing Factor y

5) Mandatory Med-High 11) Transport of Med-High 16) Autonomous Medium 26) Physical Security Medium Hearing Fueled Reactor operations

6) Contested High 17) Remote Medium 27) Emergency Low Hearing monitoring preparedness

18) Remote Medium 28) Insurance & Liability Low operations

19) Cyber security Medium 29) Contractors and ML Medium

20) Radiation Med-Low 30) Preclude Criticality Medium Protection

21) FFD/Access Medium 31) Loading Fuel at Factory Medium Authorization Only 16 of previously identified issues (22) are included in this scope, and some of 32) Replace Modules at Site Med-Low these 16 require expansion to address the O&G upstream business needs. 33) Storing Used Fuel at Site Med-Low Next Steps

Coordinate with Shepherd/BWXT and other companies pursuing similar technologies and applications Develop Regulatory Topics for Potential Alternative Approach

Establish basis for protecting the public health and safety

Develop performance-based alternative regulatory approach

Establish safety, security and environmental acceptance criteria

Clarify conditions for licensing approach

Identify regulatory changes to enable alternative approach Schedule

May to July: Engage NRC and stakeholders to discuss regulatory topics and alternative approaches

7/31: NEI submits proposal for regulatory alternatives

ML24130A197

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