ML24249A133

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Staff Presentation Slides IAEA Consultancy Meeting NRC Pre-application Engagement, Sept 10, 2024
ML24249A133
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Issue date: 09/09/2024
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NRC Pre-application engagement strategy and guidance International Atomic Energy Agency Consultancy Meeting on Approaches for Design and System Readiness Evaluation of Small Modular Reactors for near-term Deployment September 10, 2024

Mission Statement License and regulate the Nations civilian use of radioactive materials to provide reasonable assurance of adequate protection of public health and safety and to promote the common defense and security and protect the environment.

www.nrc.gov/about-nrc.html 2

Principal Legislation & Regulations Driving Timely Decisions and Outcomes

  • National Environmental Policy Act (1969)
  • Impacts ON the environment FROM licensed activities
  • Impact level
  • Disclosure document
  • Atomic Energy Act (1954)
  • Energy Reorganization Act (1974)
  • Impacts ON the facility FROM the environment
  • Risk informed
  • Reasonable assurance of adequate protection www.nrc.gov/about-nrc/governing-laws.html 3

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International Activities International agreements and treaty obligations.

Exchange regulatory security and emergency preparedness information.

Bilateral cooperation with international regulators.

Engage with multilateral organizations such as IAEA, NEA, and WINS.

Provide assistance and training support to countries who are just starting their programs.

Licensing is a Multi-Step Process, with Opportunities for Public Engagement ACRS: Advisory Committee on Reactor Safeguards NEPA: National Environmental Policy Act

  • Required for early site permits, construction permits, or combined licenses Public Participation Environmental Review ACRS Letter Draft NEPA Document Final NEPA Document Pre-Application Activities Mandatory Hearing*

Commission Decision ACRS Review Scoping Activities Comments on Draft Safety Review Safety Evaluation Report Consultations Application Opportunity for Contested Hearing 8

9 Flexible NRC Reactor Licensing Pathways 10 CFR Part 52 Vogtle AP1000, NuScale Early Site Permit, COL, Design Certification, Manuf. License 10 CFR Part 53 New licensing framework under development Technology-inclusive, risk-informed, performance-based framework Publish ahead of 2027 deadline 10 CFR Part 50 Large majority of operating power reactor and NPUF fleet Construction Permit + Operating License

10 CFR Part 50:

Two-Step Licensing Process Construction Permit Application Public Hearing Construction Permit Construction Begins Operating License Application Public Hearing Opportunity Operating License Operation Begins Construction Permit Operating License 10

11 This process may involve the following:

Combined License (COL)

Early Site Permit (ESP)

Design Certification (DC)

Standard Design Approval (SDA)

Manufacturing License 10 CFR Part 52:

Single Process with Multiple Components

10 CFR Part 53:

Transformative Regulatory Framework

  • Technology-Inclusive: Can be used for any new light water small modular reactor or non-light water reactor technology
  • Risk-Informed: Requirements scaled to risk and consequences of the facility
  • Performance-Based: Establishes clear and objective criteria to assess performance
  • Final rule expected to be issued in before deadline www.nrc.gov/reactors/new-reactors/advanced/rulemaking-and-guidance/part-53.html 12

Licensing Modernization Project As an outcome of the Licensing Modernization Project, the NRC published Regulatory Guide 1.233, "Guidance for a Technology-Inclusive, Risk-Informed, and Performance-Based Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Non-Light Water Reactors," in the Federal Register on June 9, 2020.

This regulatory guide endorsed the methodology described in NEI 18-04, Revision 1, "Risk-Informed Performance-Based Guidance for Non-Light Water Reactor Licensing Basis Development," as an acceptable approach for informing the licensing basis and determining the appropriate scope and level of detail for parts of applications for licenses, certifications, and approvals for non-LWRs.

See SECY-19-0117, "Technology-Inclusive, Risk-Informed, and Performance-Based Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Non-Light-Water Reactors," and associated Staff Requirements Memorandum for information on associated policy issues.

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ARCAP/TICAP Background Guidance for developing and reviewing technology-inclusive, risk-informed, and performance-based non-light water (non-LWR) applications Developed to support 10 CFR Part 50 and 10 CFR Part 52 applications Needed to support expected near-term non-LWR Part 50/52 applications using the licensing modernization project (LMP) process in NEI 18-04, Revision 1 The NRC staff intends to revise the guidance per the final Part 53 rulemaking language ARCAP/TICAP Public Webpage provides links to key meetings and documents associated with the development of these documents (see: https://www.nrc.gov/reactors/new-reactors/advanced/rulemaking-and-guidance/advanced-reactor-content-of-application-project.html) 14

ARCAP Background 15

  • Broad in nature and intended to cover guidance for non-LWR applications for:

combined licenses

construction permits

operating licenses

design certifications

standard design approvals

manufacturing licenses

  • Encompasses TICAP
  • TICAP is guidance for off-normal reactor states only. ARCAP encompasses everything needed for a license application.

TICAP Background 16

  • TICAP scope is governed by the LMP-based process

LMP uses risk-informed, performance-based approach to select licensing basis events, develop structures, systems, and components (SSC) categorization, and ensure that defense-in-depth is considered

  • Industry developed key portions of TICAP guidance See NEI 21-07, Revision 1, Technology Inclusive Guidance for Non-Light Water Reactors Safety Analysis Report Content for Applicants Utilizing NEI 18-04 Methodology, (ADAMS Accession No. ML22060A190)

ARCAP and TICAP - Nexus 17 Outline Safety Analysis Report (SAR) -

Based on TICAP Guidance 1.

General Plant Information, Site Description, and Overview 2.

Methodologies and Analyses and Site Information*

3. Licensing Basis Event (LBE) Analysis
4. Integrated Evaluations
5. Safety Functions, Design Criteria, and SSC Safety Classification
6. Safety Related SSC Criteria and Capabilities
7. Non-safety related with special treatment SSC Criteria and Capabilities
8. Plant Programs Additional Portions of Application
  • Technical Specifications
  • Technical Requirements Manual
  • Quality Assurance Plan (design)
  • Quality Assurance Plan (construction and operations)
  • Security Plan
  • SNM material control and accounting
  • Radiation Protection Program
  • Inservice inspection/Inservice testing (ISI/IST) Program
  • Environmental Report and Site Redress Plan
  • Financial Qualification and Insurance and Liability
  • Aircraft Impact Assessment
  • Performance Demonstration Requirements
  • Nuclear Waste Policy Act
  • Operational Programs
  • Exemptions, Departures, and Variances )

Audit/inspection of Applicant Records Calculations Analyses P&IDs System Descriptions Design Drawings Design Specs Procurement Specs Probabilistic Risk Assessment

  • SAR Chapter 2 derived from TICAP guidance as supplemented by ARCAP interim staff guidance Chapter 2, Site Information Safety Analysis Report (SAR) structure based on clean sheet approach Additional contents of application may exist only in the SAR, may be in a separate document incorporated into the SAR, or may exist only outside the SAR.

The above list is for illustration purposes only.

Additional SAR Content -Outside the Scope of TICAP

9. Control of Routine Plant Radioactive Effluents, Plant Contamination, and Solid Waste
10. Control of Occupational Doses
11. Organization and Human-System Considerations
12. Post-construction Inspection, Testing and Analysis Programs

Safety Review - Fundamental Functions Reactivity and power control Fuel Reactivity control systems Heat removal Reactor coolant system Backup cooling systems Radionuclide retention Barriers to retain radionuclides within the facility 18

Safety Review - Key Topics External hazards (nearby facilities, hydrology, seismology, etc.)

Reactor fuel Reactivity control and reactor shutdown Primary coolant and decay heat removal Instrumentation and control Radiation protection for both workers and the public Accident analyses Operational programs (emergency plan, security, operator training, etc.)

Activity Reactor Type Milestone*

Part 50 - Construction Permit All 36 months Environmental Impact Statement All 24 months Part 50 - Operating License Non-Light-Water Reactor 36 months Topical Reports All 24 months

  • Actual schedules may be shorter or longer than the generic milestone schedule based on the specific needs of the licensee or applicant and the staff's resources.

The NRC established generic schedules for completing final safety evaluations for various licensing actions Timely NRC Review Schedules www.nrc.gov/about-nrc/generic-schedules.html 20

Advanced Reactor Program Nuclear Regulatory Commission

Advanced Reactor Program Transforming the Regulatory Framework Licensing First-of-a-Kind Technologies Executing Safety Focused Reviews on Time and Budget Enabling a Sustainable Program O U R F O C U S

o Part 53 o Physical Security o Emergency Preparedness o Generic Environmental Impact Statement o Siting o Part 50/52 alignment o Construction Oversight (ARCOP) o Fees o Fusion o Guidance (TICAP/ARCAP) o Microreactors Framework Modernization T R A N S F O R M A T IO N

Advanced Reactors By the Numbers Evolving Landscape 20+

4 Potential applications by 2027 Applications currently under review Research and Test Reactors Molten Salt Reactors Small Modular and Microreactors High-Temperature Gas-Cooled Reactors Liquid Metal Cooled Fast Reactors 24 Infrastructure Improvements Many different reactor technologies Range of sizes from < 10 MWt to 600 MWt Multiple reactors on a single site Hazards vary with power level and radionuclide inventory 15+

96 Entities actively engaged in pre-application activities Topical Reports and white paper reviews completed for 7 vendors 60+

8 Guidance documents issued NRC/CNSC joint reports issued

Advanced Reactor Landscape 25 ARDP Awardees ARC-20 Demo Reactors In Licensing Review Risk Reduction Preapplication RTR Research/Test Reactor LEGEND High-Temperature Gas-Cooled Reactors (HTGR)

Liquid Metal Cooled Fast Reactors (LMFR)

Molten Salt Reactors (MSR)

TRISO Fuel Westinghouse Columbia Basin Hydromine Lead-Cooled Micro Reactors Framatome X-energy

  • StarCore MIT General Atomics*

General Atomics (EM2)

  • GEH PRISM (VTR)

Advanced Reactor Concepts

  • TerraPower/GEH Natrium*

Sodium-Cooled Kairos (Hermes l RTR)

Liquid Salt Cooled Kairos

  • ThorCon Flibe Elysium Alpha Tech Muons Southern (TP MCRE) l RTR ACU l RTR Terrestrial
  • TerraPower (MCFR)

Liquid Salt Fueled UIUC / Ultra Safe l RTR*

Stationary Oklo

BWX Technologies X-energy Radiant l RTR Transportable Small Modular Light Water Reactors (SMR)

Holtec SMR-160*

Pressurized Water Reactors Boiling Water Reactor Westinghouse AP300 GEH BWRX-300*

NuScale US600 NuScale US460 DC Design Certification

Developing Rule Language and Policies Part 53s Risk-Informed, Technology-Inclusive Regulatory Framework for Advanced Reactors Alternative Physical Security Emergency Preparedness Generic Environmental Impact Statement for Advanced Reactors Siting Part 50/52 rulemaking Fee Structure Fusion Oversight Micro-reactor Licensing and Deployment 26

Licensing First-of-a-Kind Technologies Engaging federal partners to support national projects.

Partnership Strategic collaboration facilitates common solutions/enhances efficiency.

International Colaboration Data Not a comprehensive list Early Engagement Licensing o Kairos Power o Abilene Christian Univ.

o NuScale Fuel Fabrication Facilities o X-energy Pre-Application o X-energy o Kairos Power o TVA o Oklo o ARC o Terrestrial Energy o Westinghouse o Holtec o Radiant o TerraPower o GE Hitachi o Univ. of Illinois o General Atomics Military o PELE o Eielson AFB Robust pre-application facilitates reliable and predictable reviews.

Innovative use of project management tools and data analytics Who were working with

Objective #1 Shorten Review Time Objective #3 Explain Roadmap Objective #4 Communicate & Align Purpose of the Pre-application Strategy Objective #2 Identify Technical Issues

Considering the regulatory process Understanding the Schedule Value Propositions Establishing an appropriate schedule to address testing needs early Risk-Informed, Performance-Based Reaching certainty on technological advances Regulatory Clarity Aligning on necessary assets including staffing, funding/budgeting, and timing Resources

Drop-Ins White Papers ARCAP Topical Reports Accountability Audit Summaries Pre-Submittal Reviews Guidance Documents Tools Bubble Chart Verbal Feedback Public Meetings

DANU-ISG-2022-01 Appendix A

Purpose:

Provide guidance on the benefits of robust preapplication engagement with advanced reactor developers in order to optimize both safety and environmental application reviews.

Contents:

Background

Program for Robust Pre-application Engagement A.

Topical Reports B.

Safety Review Meetings, Audits and White Papers C.

Environmental Activities D.

Pre-application Readiness Assessment E.

Safeguards Information Plan 31

DANU-ISG-2022-01 Appendix A A.

Topical Reports Principal Design Criteria LBE Selection Fuel Qualification and Testing Source Term Quality Assurance Safety and Accident Analysis Methodologies and Valuation 32

DANU-ISG-2022-01 Appendix A B. Safety Review Meetings, audits and white papers Probabilistic Risk Assessment (PRA)

Analysis of Applicable Regulations Policy Issues Novel Design Features and Approaches Consensus Codes and standards and code cases Material Qualification 33

DANU-ISG-2022-01 Appendix A C. Environmental Activities White Papers Unique methodologies and issues Alternatives to the proposed project Cooling water availability Status of permits and authorization for the proposed project Meetings Socioeconomic and community issues Ecology studies, endangered species, critical habitats Historic Properties Fuel cycle and transportation of fuel and wastes Design-specific information needed for the environmental review 34

DANU-ISG-2022-01 Appendix A D. Pre-application Readiness Assessment A voluntary activity, highly encouraged Ideally performed 6-months before application is submitted Process described in staff guidance; NRC Office Instruction LIC-116 (ML20104B698)

Can focus on whole or part of an application Allow Staff to:

Identify Information Gaps Identify major technical or policy issues not previously discussed Become familiar with the application Identify new concepts or novel features not previously discussed.

Prioritize review Estimate the review schedule 35

DANU-ISG-2022-01 Appendix A E.

Safeguards Information Plan Staff review of the applicants plan to protect safeguards information (SGI)

Allows staff to provide applicant guidance designated as SGI.

Supports requirements for applicants to consider safeguards and security in the design of the facility.

Supports the applicants development of its Physical Security Program in accordance with 10 CFR Part 73 Supports applicants development of its Aircraft Impact Assessment as required by 10 CFR 50.150 36

Questions?

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Thank you.

Acronyms and Initialisms 39 ACRS Advisory Committee on Reactor Safeguards DC design certification ADAMS Agencywide Documents Access and Management System DG draft regulatory guide ARCAP Advanced Reactor Content of Applications ESP Early site Permit ARCOP Advanced Reactor Construction Oversite Process HTGR High-Temperature Gas-Cooled Reactors ARDP Advanced Reactor Demonstration Program IAEA International Atomic Energy Agency CFR Code of Federal Regulations ISI inservice inspection CNSC Canadian Nuclear Safety Commission IST inservice testing COL combined license

Acronyms and Initialisms 40 LBE licensing basis event ONR Office for Nuclear Regulation (United Kingdom)

LMP Licensing Modernization Project PRA probabilistic risk assessment LMFR Liquid Metal Cooled Fast Reactors RTR research and test reactor MSR Molten Salt Reactor SAR safety analysis report NEA Nuclear Energy Agency SDA standard design approval NEI Nuclear Energy Institute SSC structure, system, and component NRC U.S. Nuclear Regulatory Commission TICAP Technology-Inclusive Content of Applications WINS World Institute for Nuclear Safety

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