ML24303A213
| ML24303A213 | |
| Person / Time | |
|---|---|
| Issue date: | 10/17/2024 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-0077 | |
| Download: ML24303A213 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
ACRS Regulatory Policies and Practices Subcommittee Meeting Location:
teleconference Date:
10-17-24 Work Order No.:
NRC-0077 Pages 1-117 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
(ACRS) 5
+ + + + +
6 REGULATORY POLICIES AND PRACTICES SUBCOMMITTEE 7
+ + + + +
8 THURSDAY 9
OCTOBER 17, 2024 10
+ + + + +
11 The Subcommittee met via Videoconference, 12 at 10:00 a.m. EDT, Vicki Bier, Chairman, presiding.
13 SUBCOMMITTEE MEMBERS:
14 VICKI M. BIER, Chairman 15 DAVID A. PETTI, Member-at-Large 16 RONALD G. BALLINGER, Member 17 VESNA B. DIMITRIJEVIC, Member 18 GREGORY H. HALNON, Member 19 CRAIG HARRINGTON, Member 20 ROBERT MARTIN, Member 21 SCOTT PALMTAG, Member 22 THOMAS ROBERTS, Member 23 MATTHEW W. SUNSERI, Member 24 ACRS CONSULTANT:
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 DENNIS BLEY 1
DESIGNATED FEDERAL OFFICIAL:
3 DEREK WIDMAYER 4
ALSO PRESENT:
5 JACKIE HARVEY, NRR 6
JOY JIANG, The Breakthrough Institute 7
WILLIAM "BUCK" KENNEDY, NRR 8
STEVEN LYNCH, NRR 9
MARCUS
- NICHOL, Nuclear Energy Institute 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 TABLE OF CONTENTS 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 CONTENTS 1
2 Opening Remarks, Dr. Vicki Bier, ACRS......
4 3
Staff Introduction, Steven Lynch, NRR......
7 4
Draft White Paper on Nth-of-a-Kind (NOAK)....
9 5
Micro-Reactor Licensing and Deployment 6
Considerations, William Kennedy, NRR; 7
Jackie Harvey, NRR 8
Adjourn 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 P R O C E E D I N G S 1
10:00 a.m.
2 CHAIR BIER: Today's meeting will now come 3
to order. This is a meeting of the Regulatory 4
Policies and Practices Subcommittee of the Advisory 5
Committee on Reactor Safeguards. I am Vicki Bier, 6
chair of today's subcommittee meeting.
7 ACRS members in attendance virtually are 8
Ron Ballinger, Gregory Halnon, Craig Harrington, 9
Robert Martin, Scott Palmtag, Dave Petti, Tom Roberts, 10 Matthew Sunseri, and myself. So that is almost 11 perfect attendance. Vesna Dimitrijevic may be joining 12 later or --
13 MEMBER DIMITRIJEVIC: I just joined.
14 CHAIR BIER: Oh, you just joined, perfect.
15 Thank you very much. And two of our consultants are 16 also participating virtually via Teams, Dennis Bley 17 and Stephen Schultz. So I don't think I've missed 18 anybody.
19 Derek Widmayer of the ACRS staff is the 20 Designated Federal Officer for today's meeting. No 21 member conflict of interests were identified for this 22 topic and we have a quorum for the meeting.
23 During today's meeting, the subcommittee 24 will receive a briefing on the staff's draft white 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 paper on nth-of-a-kind, NOAK, Micro-Reactor Licensing 1
and Deployment Considerations. In case there are any 2
members of the public who are unfamiliar with the 3
terminology, first-of-a-kind would be a brand-new 4
design that may require heightened scrutiny in the 5
approval process. And nth-of-a-kind is what we're 6
talking about if we're producing large numbers of 7
essentially identical reactors, so the initial 8
approval has already taken place.
9 Following this meeting and after 10 additional work, the staff's draft white paper will 11 become a SECY paper and sent to the Commission for 12 consideration. We are reviewing this paper as part of 13 the ACRS statutory obligation under Title 10 of the 14 Code of Federal Regulations Part 52, Subpart E, 15 Section 141, referral to the Advisory Committee on 16 Reactor Safeguards to report on matters that concern 17 the safety of nuclear power reactors.
18 The ACRS was established by statute and is 19 governed by the Federal Advisory Committee Act, or 20 FACA. The NRC implements FACA in accordance with its 21 regulations. Per these regulations and bylaws, the 22 ACRS speaks only through its published letter reports.
23 Therefore, all member comments during this meeting 24 should be regarded only as the individual opinion of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
6 one member, not as a committee position.
1 All relevant information related to ACRS 2
activities such as our letters, rules for meeting 3
participation, and meeting transcripts are located on 4
the NRC public website and can be easily found by 5
typing "about us ACRS" in the search field on NRC's 6
home page.
7 The ACRS, consistent with the Agency's 8
value of public transparency and regulation of nuclear 9
facilities, provides opportunity for public input and 10 comment during our proceedings. We received a request 11 to make a presentation from the Nuclear Energy 12 Institute and have made time in the agenda for them to 13 present. We have also set aside time at the end of 14 this meeting for public comments.
15 The ACRS will gather information, analyze 16 relevant issues and facts, and formulate proposed 17 conclusions and recommendations as appropriate for 18 deliberation by the full committee.
19 A transcript of the meeting is being kept 20 and will be posted on our website. When addressing 21 the subcommittee, participants should first identify 22 themselves and speak with sufficient clarity and 23 volume so that they may be readily heard. If you are 24 not speaking, please mute your computer on Teams or by 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 pressing *6 if you're on your phone. Please do not 1
use the Teams chat feature to conduct sidebar 2
discussions related to the presentations. Rather, 3
please limit use of the meeting chat function to 4
report any IT problems.
5 Since this meeting is being held entirely 6
virtually over Teams, I ask that ACRS members and all 7
other attendees use the raised hand feature of Teams 8
if you have a question or a comment, so that the 9
meeting can proceed an orderly fashion.
10 Finally, if you have any feedback for the 11 ACRS about today's meeting, we encourage you to fill 12 out the public meeting feedback form on the NRC's 13 website.
14 We will now proceed with the meeting. I 15 call on Steve Lynch, Branch Chief of the Advanced 16 Reactor Policy Branch in NRR's Division of Advanced 17 Reactors and Non-Power Production and Utilization 18 Facilities, for opening remarks.
19 Steve, the floor is yours.
20 MR. LYNCH: Thank you and good morning.
21 As Member Bier stated, I'm Steve Lynch, Chief of the 22 Advanced Reactor Policy Branch at the NRC. Today, the 23 members will be hearing from Duke Kennedy and Jackie 24 Harvey, two of our senior project managers in the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 Policy Branch.
1 We thank the members for inviting the NRC 2
staff to discuss our continued efforts to prepare the 3
NRC's regulatory framework for the future licensing 4
and anticipated rapid deployment of micro-reactors.
5 The staff recently released its draft white paper on 6
strategies for streamlining the licensing of nth-of-a-7 kind micro-reactors manufactured at a facility.
8 Today, the staff is prepared to discuss 9
several aspects of this paper with the ACRS, including 10 its proposed strategies for improving standardized, 11 operational programs. As this subject will become a 12 vote topic for the Commission in a forthcoming SECY 13 paper, the staff is looking forward to insights the 14 members have to share with us today.
15 There are also some information topics 16 that the staff will not be seeking Commission 17 direction on in this paper that we will also cover in 18 today's
- meeting, including maximal design 19 standardization, graded site characterization, 20 emergency preparedness, streamlined application 21 processing, and construction inspection.
22 Also include in the white paper and 23 forthcoming SECY is a discussion of alternative 24 approaches to environmental reviews, which is beyond 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 the scope of today's meeting. Accompanying the 1
environmental discussion in the main paper that the 2
members have seen will be an enclosure referred to as 3. This enclosure will provide additional 4
details on the NRC staff's proposals to streamline the 5
environmental review process for repetitive licensing 6
and permitting actions. The considerations associated 7
with environmental activities to be discussed and 8
evaluation in this paper and associated enclosure are 9
independent and distinct from the staff's discussion 10 today related to operational programs.
11 The NRC staff is continuing to work on 12 and for completeness will share the draft 13 version of this environmental enclosure with the 14 members when it becomes available later this month.
15 Again, thank you for your time today. We 16 look forward to a productive discussion and I will now 17 turn it over to our staff for the main presentation.
18 MS. HARVEY: All right, thanks, Steve, and 19 hi, everyone. Again, I'm Jackie Harvey, a senior 20 project member in the Advanced Reactor Policy Branch.
21 I think we are ready to share the slides if we can 22 have those presented. And while the slides are coming 23 up, I just want to reiterate what Steve said about, I 24 thank you very much for having us here today to have 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 a discussion regarding licensing and deployment 1
considerations for nth-of-a-kind micro-reactors.
2 Were looking forward to this.
3 Next slide, please. We can actually go 4
another slide forward.
5 So today we're going to be discussing the 6
motivation for the paper, some background, the 7
conceptual model for transportable micro-reactors, 8
licensing strategies for nth-of-a-kind, or NOAK, 9
micro-reactors, options for standardization of 10 operational
- programs, other
- topics, as Steve 11 mentioned, and then finishing up with stakeholder 12 engagement, and next steps.
13 Next slide.
14 So looking into the motivation for this 15 paper, for several years staff has been evaluating the 16 regulatory framework for micro-reactors and has been 17 prioritizing strategies for reliable and efficient 18 licensing. For example, staff recently provided to 19 the Commission SECY-24-0008 with options related to 20 fuel loading and operational testing at a factory. So 21 staff continues to engage with stakeholders, pre-22 applicants, and through this continued engagement, 23 stakeholders have expressed interest in an enhanced 24 clarity regarding rapid and widespread deployment of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 micro-reactors of a standard design to include having 1
operating license review time frames that are 2
significantly shorter than our current licensing time 3
frames. So staff is continuing to review the 4
regulatory framework here to identify efficiencies 5
within the licensing process, while ensuring safe and 6
thorough reviews.
7 Additionally, I'll mention the 8
accelerating deployment of versatile advanced nuclear 9
for Clean Energy Act, also know as the ADVANCE Act, 10 was signed several months ago and has provisions in 11 Section 208 to address for licensing and regulation of 12 micro-reactors. The Act directs the NRC to consider 13 unique characteristics of micro-reactors and look for 14 opportunities to enhance efficiencies.
So 15 additionally, in addition to what we were already 16 pursuing through the NOAK paper, we are also ensuring 17 that our review of the framework is taking into 18 account the direction in this Act.
19 Next slide.
20 The micro-reactors considered in this 21 paper are commercial power reactors licensed under 22 Section 103, commercial licenses of the Atomic Energy 23 Act of 1954, as amended, and are anticipated to have 24 power levels on the order of up to a few tens of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
12 megawatts thermal, small site footprints, expected to 1
have lower potential radiological consequences than 2
current large light water reactors, and may rely more 3
heavily on passive systems.
4 And then factory-fabricated transportable 5
micro-reactors are a subset. And those would rely 6
heavily on standardization of mass production.
7 So one note to mention here, I did 8
previously mention SECY-24-008 is currently under 9
consideration by the Commission, so the options 10 presented in the white paper do not assume any 11 particular Commission direction from the previous 12 paper,24-008.
13 Next slide, please.
14 So for this paper, and for purposes of 15 this presentation, the term nth-of-a-kind micro-16 reactor means the micro-reactor of a standard design 17 that has been previously approved by the NRC through 18 a design certification, a manufacturing license, or 19 through the full first-of-a-kind review for a combined 20 license or a construction permit and operating 21 license. So NOAK licensing refers to licensing micro-22 reactors really of a standard, common design for 23 operation at power reactors in a fixed site.
24 At this time, it seems like external 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
13 stakeholders are focused more on a
design 1
certification, or DC, or manufacturing license, or ML, 2
deployment model, but later on in the presentation we 3
will also discuss some potential considerations for a 4
first-of-a-kind review and a standard design approval.
5 Next slide.
6 This slide is depicting a
generic 7
deployment model considered by staff in its paper 8
where a reactor is fabricated at a factory or a 9
manufacturing facility, transported to the deployment 10 site, operated at the site, transported from the 11 deployment site, and then decommissioned.
12 I do want to point out the middle column 13 here for the deployment site power operation. This 14 column shows two models of factory fabricated micro-15 reactor deployments at the site. So the first on the 16 top is a stand-alone, self-contained, micro-reactor 17 design which incorporates essentially the entire plant 18 in one or several transportable containers and that 19 would require a
minimal site preparation for 20 construction activities.
21 And then the other model that -- or other 22 designs that staff anticipates may consist of a core 23 model which -- a core module which is comprised of the 24 core and potentially other significant reactor vessel 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 components which are then incorporated into or 1
connected to permanent structures or systems at the 2
design deployment site. For instance, that may mean 3
significant power conversion equipment.
4 I see a hand up.
5 MEMBER BALLINGER: Yes, this is Ron 6
Ballinger. Can you give us an example of one of --
7 each one of those classes that we're now thinking 8
about? I think eVinci would be of the first, right?
9 MR. KENNEDY: So I can answer that. This 10 is Dick Kennedy. So the top one there, self-11 contained, I think there's a number of designs. One 12 is proposed by Radiant Nuclear Industries and there 13 are others where the idea is that the reactor can be 14 incorporated or put into a single container that can 15 be transported by truck.
16 And regarding the bottom figure there, I 17 think the eVinci design is an example of a reactor, 18 micro-reactor design where there would be on-site 19 buildings constructed and then the reactor would be 20 transported there and housed in that building.
21 MEMBER BALLINGER: Where would Pele fit in 22 here?
23 MR. KENNEDY: So I'm not familiar with all 24 of the design specifics of Pele. My understanding is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
15 that it was to be housed in containers that would be 1
transported to a site and so I think it would probably 2
fit more on the top column or the top illustration 3
there, but again, I'm not familiar with the exact 4
design.
5 MEMBER BALLINGER: Thank you.
6 MEMBER HALNON: Before we get off this 7
slide, this is Greg Halnon. I know we focused a lot 8
on the deployment site and we've had some discussions 9
about transportation. I'm actually interested how, or 10 where your head is, relative to the factory or 11 manufacturing facility if we're actually saying that 12 we could operate a reactor there. Are we talking a 13 different type of license for that facility, maybe 14 having a potential containment building in that 15 facility as well? Would we be licensing that similar 16 to the deployment site?
17 MR. KENNEDY: So that was covered in the 18 last SECY paper that went up to the Commission in 19 January and it really depends on what the developer or 20 the manufacturing facility operator wants to do and 21 what's needed for testing of their reactor. We didn't 22 get into any of the real technical details of how that 23 would be done. It was more about the licensing 24 processes that could be used to license operational 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
16 testing at a factory or at a nearby location.
1 So I would say at least we had an option 2
where the reactor operation and licensing review would 3
be conducted more like that for a non-power reactor 4
and we had a status quo option where the reactor would 5
be reviewed against the full power reactor regulations 6
for the operations testing.
7 MEMBER HALNON: Okay. I think that we're 8
probably going to have more discussion on this because 9
I noticed that in the paper it talked about maybe 10 upwards of ten modules a year which could mean that 11 there's overlapping operations of multiple modules.
12 It could be temporary systems and other things that 13 may be maintaining cooling of a licensing-basis event, 14 but are specific to the manufacturing facility. So 15 I'll go back and look at the SECY and review it again, 16 but I think we're probably going to have to have more 17 discussion on that piece if we are actually talking 18 about operating a reactor in the manufacturing 19 facility. But thanks. I know it's premature. A lot 20 of this is conceptual at this point, but I'll be 21 interested in that front end of the cycle as well.
22 MR. KENNEDY: Is another hand up?
23 MR. BLEY: Yes, Dennis Bley. This is also 24 premature, but I wonder if you've had any hints and I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
17 haven't thought about this until just now of whether 1
the vendors, when they sell to an organization thats 2
going to operate it, will that organization provide 3
the operations report or are the vendors thinking of 4
including that in the sale? Have you heard anything 5
about that?
6 MR. KENNEDY: I think right now there are 7
many different deployment models under consideration 8
and really any of those ideas are on the table. I 9
don't want to go into the specifics of any particular 10 vendor, but there are a very wide variety of 11 deployment models and operational models under 12 consideration.
13 MR. BLEY: Okay, thanks. And I'm glad 14 you're at least hearing some of that at this point.
15 MS. HARVEY: Another hand?
16 CHAIR BIER: I don't see any, but --
17 MEMBER PETTI: Hold on. No, I was still 18 muted, sorry. This is Dave. I have a different 19 question. I know this is all about nth-of-a-kind, but 20 does the idea of streamlining licensing, given the 21 characteristics of these
- systems, impose any 22 additional requirements on the first-of-a-kind? It 23 would seem to me that it would be that you would want 24 some demonstration of these quote, I'll call them 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
18 characteristics or attributes, that are not really 1
delineated in the paper, but just kind of pointed to 2
at fairly high levels so that you had confidence that 3
the design actually meets the high levels of safety 4
and environmental characteristics that were talked 5
about in the paper, but delineated in a more concrete 6
and detailed way so that you have a technical basis 7
for saying, yes, this micro-reactor can go through 8
this nth-of-a-kind approach, but this one over here, 9
there's something in the design that we think would 10 cause a problem from being able to access this avenue.
11 MR. KENNEDY: So that's a great point. I 12 will talk a little bit later about the role of first-13 of-a-kind in achieving an nth-of-a-kind design. But 14 at a higher level, there isn't a requirement in the 15 regulations to, quote, build a first-of-a-kind before 16 you get to nth-of-a-kind, but there are requirements 17 that the NRC staff as all the necessary information to 18 make its findings of reasonable assurance of 19 protection of public health and safety. And so there 20 are also requirements related to prototyping and 21 testing new safety features.
22 And so again, while there isn't a 23 requirement for, quote, first-of-a-kind, we will need 24 to have all the necessary information to have 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
19 confidence in the safety of the reactor before they're 1
mass produced.
2 MEMBER PETTI: But is it worthwhile? I'm 3
thinking down the road in some guidance document 4
somewhere where one would kind of put together in one 5
place. What are all the attributes of the 6
characteristics that weigh in on such a decision?
7 Because I've seen numerous micro-reactor designs in 8
the last few years and some have the characteristics 9
that I think we'd all like to see as discussed in the 10 white paper, but some may not because of the 11 constraints that are relative to the mission for the 12 micro-reactor. So one has to be, I think, a little 13 bit careful at the front end. And I think having sort 14 of the rules of the road and criteria would help both 15 sides, the licensee and the NRC, going like these are 16 the things we're going to be looking for in order to 17 say that you can have this expedited process.
18 MR. LYNCH: Thank you for that. One thing 19 that I will highlight is, within the NRC regulatory 20 framework, we do have provisions that for new designs 21 that may be licensed for the first time, we do have 22 provisions under 10 CFR 50.43(e) for prototype plants 23 where we can impose additional safety criteria on such 24 facilities until they have demonstrated that they can 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
20 be operated safely and within the bounds that we would 1
expect. And we do have guidance that exists for some 2
of that in the regulatory review road map and Appendix 3
B that we put out and this lays out what is expected 4
for doing the necessary testing to make those 5
regulatory requirements. But agree that, as we are 6
looking at how this interplays with mass-produced 7
reactors, we'll need to take another look at updating 8
that guidance to make sure it is appropriate going 9
forward.
10 MEMBER PETTI: Yes, I mean a lot of this 11 stuff in the safety space and even in the -- mostly in 12 the safety space, I think we know what we're looking 13 for there. Even in mostly environmental space, but 14 there is some uniqueness with micro-reactors. They 15 leak a heck of a lot of neutrons and so the quote, 16 insult to the environment of -- would the neutrons 17 activate the dirt? Would it activate the air? And 18 what does that mean from the EIS perspective is one 19 aspect to think about. But also the operational side, 20 this is kind of new that you'd like to really change 21 some of the operational licensing programs that we've 22 had. And in my mind that just means we should know by 23 operation of the first-of-a-kind that, in fact, this 24 is actually doable and is in the interest of good and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
21 safe operation.
1 These are really different and new ideas.
2 So I'm just trying to think of ways that can help 3
everyone kind of see the rules of the road the same 4
way, if you will. Thanks.
5 MS. HARVEY: Thank you. I appreciate the 6
comments. Okay, before we move on, any additional 7
questions on this slide?
8 Seeing None, next slide, please.
9 So the white paper explores the 10 efficiencies in the operating licensing program and 11 this slide gives a high-level overview of the contents 12 of the white paper and provides the links to the 13 different -- the main paper and the enclosures.
14 So just to reiterate, staff is developing 15 two topics for Commission consideration related to --
16 the first related to the approval of standardized 17 operational programs with a design certification and 18 manufacturing license and the second being alternative 19 approaches for environmental reviews. And then these 20 topics are further discussed in Enclosure 1 for 21 operational programs and then it's restated in 22 upcoming Enclosure 2.
23 And then Enclosure 3 of the white paper 24 provides additional information on other topics that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 we will also go into more detail later.
1 Okay, and now I will turn the presentation 2
over to Duke Kennedy.
3 MR. KENNEDY: Yes, next slide, please. So 4
this slide and the next describe the anticipated 5
licensing strategy for efficient licensing of nth-of-6 a-kind micro-reactors. Later, I'll cover information 7
topics that were included in Enclosure 3 of the white 8
paper and those will provide a lot more information 9
and detail about how the licensing strategy would 10 work. But please stop me at any time if you want to 11 discuss those ideas here.
12 So the licensing strategy that we're 13 anticipating for widespread deployment of micro-14 reactors is separated into two phases. The first 15 phase is a robust, up-front approval of a standard 16 micro-reactor plant design. The second phase 17 leverages that up-front approval of the standard 18 design to streamline and accelerate the reviews of 19 applications for individual reactors. So this isn't 20 a new concept, but the design and operational 21 characteristics of micro-reactors presents a potential 22 opportunity here to dramatically reduce licensing time 23 frames while benefitting from safety enhancements that 24 standardization can provide.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
23 So Phase 1 is focused on reviewing as much 1
of the design and environmental information as 2
practicable for the complete plant and its operation.
3 This includes the maximal standardized design which 4
the NRC staff anticipates will be described in a 5
design certification or a manufacturing license 6
application, and I'll discuss what's meant by maximal 7
design standardization in more detail and information 8
topics in Enclosure 3, but just briefly what it means 9
is that the standard design is as defined in the 10 regulations in 10 CFR Part 52 The complete design 11 would be approved in a design certification or a 12 manufacturing license, or a combination of the two.
13 The design uses bounding parameters that would 14 envelope the actual site characteristics and the 15 design minimizes site-specific features and the 16 licensing application for an individual micro-reactor 17 would not include departures from the approved 18 standard design.
19 So in a couple of minutes here, Jackie 20 will cover standardized operational programs in 21 detail, but I'll just say here that an assumption in 22 this licensing strategy and the consideration of how 23 much of a reduction in the time frame for licensing 24 can be achieved, is that most operational aspects can 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
24 be approved ahead of time in this up-front approval 1
before the submission of an actual application for 2
combined license or construction permit and operating 3
license.
4 Another thing to mention here is that 5
depending on the pathway that's taken for licensing 6
the standard design, there may be mandatory hearings 7
or contested -- opportunities for contested hearings 8
or other opportunities for public engagement such as 9
the public comments on a
proposed design 10 certification.
11 Is there a hand up?
12 MR. BLEY: Yes, it's Dennis Bley again.
13 Two comments or questions here. Our history hasn't 14 been so good in being able to stick to standardized 15 designs. My interpretation is, back in the original 16 round of licenses, each of the utilities had really 17 strong leaders in the nuclear area who knew what they 18 wanted in their plants and got the vendors to design 19 them specifically to their goals. When we got to Part 20 52 which was supposed to deliver standardization, the 21 process didn't work the way it was originally 22 envisioned so the original designs had to be modified 23 once you had buyers deeply involved in the process.
24 I'm kind of guessing here, one expects the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
25 kind of buyer to be very different such that you don't 1
expect to see a lot of pressure to change design. And 2
the second part of this is, and I'm glad we'll hear 3
more about the standardized operational programs, to 4
the extent that there are procedures and emergency 5
operating procedures, the onus for that has been on 6
the operators once they buy the design. For these 7
kinds of operators, it seems to me you're going to be 8
looking for the procedures to be part of the package 9
because that's already put together.
10 Do you want to comment on that or will 11 that come out later in the talk?
12 MR. KENNEDY: Yes, I can comment briefly 13 on that, but it will come out later in the talk. And, 14 actually, this is feedback that we received from 15 stakeholders during I think our last advanced reactor 16 stakeholder meeting about the history of the reference 17 COLA and subsequent COLAs and how that worked. I 18 think for what we've heard from developers, they --
19 they're looking to be able to sell or deploy many of 20 the same design and really benefit from being able to 21 manufacture these reactors in a factory without 22 subsequent design changes and instead of customizing 23 each reactor to the needs of the buyer or the 24 deployment site, they will incorporate additional 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
26 margin in the design so that it's better suited to 1
different locations. They will seek to minimize the 2
dependence on site-specific features that would 3
require tailoring to the particular conditions of the 4
site. So I think this is something that I'll discuss 5
later and it's something that's on the mind of the 6
developers, as well as the NRC staff, as how do we 7
learn from the past and how do we effectively develop 8
this licensing strategy and make it clear how 9
applicants and developers would engage in it.
10 CHAIR BIER: Also, if I can comment. This 11 is Vicki Bier. It seems like part of the issue is a 12 different business model. The architect and engineers 13 made some of their money off of design modifications 14 and if your business model is as a manufacturer, then 15 that's not really helpful to the company in the same 16 way. So that may be part of the issue. I see there's 17 one other hand up.
18 Ed, you want to go forward?
19 MS. HARVEY: Ed Robinson, is your hand up?
20 MR. ROBINSON: I totally apologize for 21 that. I'm over here listening, but I have my arm --
22 I'm having some computer issues. Sorry about that.
23 No questions.
24 CHAIR BIER: All right.
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27 MR. KENNEDY: Thanks for the comments and 1
the feedback. So depending on the pathway for 2
licensing a standard design, again there may be 3
sharing or opportunity for other public engagement.
4 Also, each pathway will have its own time frame and so 5
in this paper we're really focused on time-frame 6
reductions and efficiency gains once you achieve the 7
nth-of-a-kind state. So we're not so focused on the 8
time frame for the Phase 1 review, but typically, the 9
processes for design certification or manufacturing 10 licenses are around 30 -- 46 months as described in 11 NRC's generic milestone schedules.
12 And finally, as has been demonstrated in 13 recent licensing reviews of advanced reactor 14 applications, pre-application engagement can really go 15 a long way to enhancing the efficiency and timeliness 16 of licensing reviews, and so the same type of pre-17 application engagement would be beneficial related to 18 the licensing activities that result in the approval 19 of a standard design.
20 Next slide, please.
21 So now we'll go on to Phase 2 which is 22 actually licensing nth-of-a-kind micro-reactors for 23 operation as power reactors of fixed deployment sites.
24 And this has leveraged the up-front approvals in Phase 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
28 1 to enhance efficiency, reliability, and clarity of 1
licensing many reactors of the same design.
2 So I want to point out that the licensing 3
of nth-of-a-kind reactors can be carried out under 4
either 10 CFR Part 50 or 10 CFR Part 52. Either of 5
the combined license under Part 52 or the construction 6
permit as an operating license under Part 50 can 7
reference a design certification rule or design that's 8
approved in a manufacturing license. So this is 9
another area where, when we developed this paper, we 10 tried to be very flexible on how we're describing all 11 the different potential options. We can't describe 12 every single iteration, but we try to describe the 13 main processes that could be used by developers and it 14 would really be up to them to decide which of these 15 licensing processes for the up-front approval, as well 16 as the licensing of individual reactors, really fits 17 best with their deployment model.
18 Part 53 that's under development can also 19 be -- will also be applicable to licensing micro-20 reactors, but that's not discussed in this case as 21 those regulations are still under development.
22 So looking at the sub-bullets here, I'll 23 cover streamlined administrative processes in more 24 detail when I get into the topics in the enclosures.
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29 I'll just skip that for now.
1 And I'll say that leveraging front review 2
should allow the reviews of individual nth-of-a-kind 3
micro-reactor license applications to be focused 4
almost entirely on licensee-specific and site-specific 5
matters. For example, the regulations in Part 50 6
require and Part 52, require information about the 7
organization, the operating organization, as well as 8
financial qualifications, so those are going to be 9
different for every application. And the other thing 10 that we're anticipating is that much of the review 11 will be the application of site-suitability, so this 12 could, for example, through the review of the 13 applicant's site characterization activities and 14 comparison of the actual site characteristics with the 15 bounding design parameters.
16 As was mentioned in the last remarks from 17 the
- members, there will need to be similar 18 verifications related to site-specific aspects of 19 operational programs such as emergency preparedness.
20 Moving to the next couple of sub-bullets 21 here, I'll cover inspections again later in the 22 discussion of the topics in Enclosure 3. And then 23 I'll just say finally, this last bullet that the 24 licensing processes under 10 CFR Part 50 and Part 52, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
30 include mandatory hearings and opportunities for 1
contested hearings, the Commission recently directed 2
the staff to modify the procedures for mandatory 3
hearings, but they will be the same procedures used 4
for both first-of-a-kind and nth-of-a-kind licensing.
5 And then finally, the enclosure to SECY 24-0008, or 6
the one that was provided in January, describes the 7
processes of timing related to opportunities for 8
contested hearings for both the Part 50 and Part 52 9
licensing processes.
10 And before I turn it back over to Jackie, 11 I just want to mention as a final point that we need 12 to be clear that the efficiency gains that we're 13 talking about here, the reduced time frames, are not 14 going to be at the expense of safety.
15 So much of the efficiency gains and timing 16 depends on the NRC staff being timely and implementing 17 its processes and making sure those processes are 18 optimized for micro-reactors, but a lot of the 19 responsibility also relies on the developers and their 20 ability to design and reliably produce standardized 21 reactors that are actually suitable for widespread 22 deployment and similarly, applicants for the member 23 micro-reactor licenses will need to provide high-24 quality applications and also follow through on their 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
31 obligations under the licensing processes in a timely 1
manner.
2 So with that, I'll turn it over to Jackie 3
to discuss operational programs.
4 MS. HARVEY: Thanks, Duke. Next slide.
5 So the first topic to discuss here, which is one for 6
Commission consideration, is related to 7
standardization of operational programs, so being able 8
to review and approve operational programs or a subset 9
of operational programs with the design certification 10 or manufacturing license. So this is really getting 11 to what Duke was saying about the Phase 1 licensing 12 strategy of what can be reviewed up front.
13 I do just want to make a note, so the 14 presentation in the white paper referred to both the 15 term operational requirements and operational program, 16 so the requirement aspect is a part of a whole program 17 and more specific to those parts that were required to 18 verify the adequacy of the design for design 19 certification.
20 So under the current framework, 21 operational programs are generally reviewed and 22 approved during the review for combined operating 23 license or a construction permit and operating 24 license. There are several design certifications in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
32 manufacturing license regulations that do require 1
portions of operational programs or operational 2
programs that support the design, but, generally, full 3
programs are not required at that stage.
4 Additionally, current Commission policy 5
does not support the review and approval of 6
operational programs in the design cert or 7
manufacturing or the application beyond those are 8
immaterial to the adequacy of the design, and I'll 9
talk about that a little bit more now with the 10 history.
11 So we're looking at the design 12 certification rules. The NRC decided to report 13 regulatory stability only to those requirements or 14
- programs, operational requirements or programs 15 material to the design. Additionally, they had to 16 have been completely reviewed and approved for the 17 rulemaking. So this regulatory stability was given 18 through and stated in the design certification rule 19 that those requirements, that met those requirements, 20 those requirements that -- material to the design and 21 completely reviewed and approved are governed by 10 22 CFR Section 50.109 which describes the back-fitting 23 requirements.
24 And then the design certification rules 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
33 also state in part that the Commission does not 1
consider operational requirements for an applicant who 2
references the design certification appendices to be 3
matters resolved within the meaning of 10 CFR 4
52.63(a)(5) which discusses finality and resolution of 5
matters within -- and resolution matters.
6 So this approach to only review and 7
approve operational programs material to the design 8
was initially approved in the Advanced Boiling Water 9
Reactor and System 80+ parts design certification 10 rule, codified as appendices in Part 52. And then 11 further, the preamble to the ABWR rule also addresses 12 stakeholder comments that was seeking finality for 13 operational programs and the NRC's response stated 14 that, in part, finality was not given because these 15 standards were not comprehensively reviewed and 16 finalized for the design certification.
17 I will also add that the Commission 18 excluded from finality information voluntarily 19 provided in the economic simplified boiling water 20 reactor design certification, so in this case, the 21 applicant included several programs that were not 22 required to provide for the adequacy of the design and 23 then the Commission excluded those operational 24 programs even though they had been voluntarily 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
34 provided.
1 So that's just to give some of the history 2
of where the current policy is, but staff in exploring 3
potential efficiencies for the COL and the CP/OL 4
licensing process is looking at that policy again for 5
nth-of-a-kind micro-reactors which, as stated, are 6
expected to have different characteristics from 7
traditional large light water reactors such as a small 8
footprint and significantly lower power levels.
9 So because of this, we anticipate that 10 these reactors may not have the site-specific systems 11 and interfaces or attributes that we traditionally 12 have seen or require operational programs of this same 13 scope that we've traditionally seen. So in that case, 14 staff anticipates that, in some cases, operational 15 programs could be reviewed, approved, and standardized 16 through a DC or an ML application review to support a 17 more efficient COL review.
18 And I know we've talked a lot about there 19 are a lot of potential deployment models, potential 20 technologies that developers are pursuing, so a lot of 21 this, a lot of the staff's assumptions that go into 22 this is the information and quality of information 23 provided by the developer because it would need to be 24 sufficient for us to -- for the staff to make a safety 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
35 finding to approve the program.
1 And I see a hand up.
2 CHAIR BIER: Yes, thanks. This is Vicki 3
Bier again. This is kind of a hypothetical or 4
counterfactual, so maybe you guys feel like you can't 5
answer this, but it seems like if we had started out 6
early in the U.S. history with these types of 7
relatively mass produced small reactors, that the 8
whole regulatory system might have been different and 9
it might have been set up to review operational 10 requirements in an ML application. Is that correct?
11 And we're now having to backfit because we came up 12 through a different approach?
13 MS. HARVEY: So I'm not sure if I can say 14 that's correct or not. We definitely came up with a 15 different approach and as we discussed previously, 16 reactors once you go -- traditionally, once you go 17 through the building, you learn and you may need to 18 make changes, I don't know, Duke or Steve, if you 19 wanted to --
20 MR. LYNCH: Jackie and Duke, would it be 21 fair to say that the existing regulatory framework is 22 really focused on the licensing of individual reactors 23 and is not necessarily looking at the connection or 24 merging of steps in licensing between reactors relying 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
36 on the same information outside of a certification?
1 So with that, what we're looking to do is 2
push the boundaries of how can we bring in some of 3
these decisions that may be made at later licensing 4
steps and pull them up in ways that allow us to give 5
a greater certainty to applicants as they're preparing 6
their information so that they can get licensed more 7
effectively. So I would not characterize this as a 8
backfit on the work that we're doing as we're really 9
just looking to find ways that we can approve of 10 information at earlier stages.
11 We do have some provisions in different 12 types of licensing that let us look at certain areas 13 and then see in construction permits and OLs, but 14 we're trying to be responsive to the proposals to have 15 design certifications in manufacturing licenses for 16 micro-reactors manufactured out of the facility.
17 Jackie, is that accurate?
18 MS.
HARVEY:
- Yes, thats a
fair 19 characterization.
20 CHAIR BIER: That's helpful. Greg, I see 21 your hand is up.
22 MEMBER HALNON: Yes, just a couple of 23 things. This is Greg Halnon.
24 And again, I realize that we're dealing 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
37 with very early in the process. However, again, back 1
to the manufacturing facility, if somebody is actually 2
operating or testing a reactor, it seems like there 3
would have to be a certain subset of operational 4
programs approved for that purpose in itself, 5
including, potentially, a subset of the EOPs, should 6
something go wrong.
7 I think we've talked about this in 8
previous meetings, about the potential for needing a 9
standardized approach to emergency operations 10 procedures, the generic technical guidelines, and 11 whatnot, recognizing there's going to be a spectrum of 12 operator roles that we'll be dealing with in all this.
13 But the second question is, I guess, more 14 of a question rather than a comment. Do you envision 15 at some point seeing maybe a small, maybe a short list 16 of operational programs that would be absolutely 17 required early on, as opposed to leaving it up to the 18 designers to say this or that is required for the 19 design?
20 MS. HARVEY: So, I think that will come 21 out more so in guidance. Because some of these 22 designs are so unique, at least for me right now, it's 23 hard to say definitively what operational programs may 24 be generally applicable to every design.
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38 Right now, we also have guidance out 1
there, the Advanced Reactor Content of Application 2
guidance that was recently published earlier this year 3
that actually walks through regulations that are 4
applicable or not applicable to light water reactors 5
versus advanced reactors or non light water reactors.
6 So, there is some guidance out there right now.
7 But I guess going back to your question, 8
it might be very possible that, if we see in the 9
future a number of, you know, one technology that has 10 a -- expect to have a broad or significant number of 11 applicants pursuing that technology for a COL or CPOL, 12 you know, we could further expand our guidance to be 13 more specific.
14 MEMBER HALNON: Yes, I think you're right.
15 I think you're going to come up and learn as we go a 16 little bit. But, certainly -- and I'm going to 17 probably beat the drum quite a bit about EOPs -- it 18 seems like you would want a standardized response to 19 emergency operations if the role of the operator is 20 such that it's an active role, rather than just a 21 passive, which, again, is going to be technology-22 specific.
23 However, if the operator does have to 24 respond to an emergency situation, you don't want one 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
39 part of the country doing it one way and another part 1
of the country doing it another way, if there's a 2
specific purpose through the design that's required.
3 So, I think that, as we see the designs, it's going to 4
become evident --
5 MS. HARVEY: Uh-hum.
6 MEMBER HALNON: -- as we go forward.
7 The other part of this was that I know we 8
look backwards at existing regulations and existing 9
guidance, but we're dealing with a whole different 10 technology and a different approach to these things.
11 I would hope that we would do what's right, and if it 12 takes rulemaking or new policy guidance, or whatever, 13 or new policies, then we would go after it and do it 14 rather than trying to force fit into old large light 15 water or even RTR-type regulations. So, I'll be 16 watching for that as well.
17 But thanks for your thoughts.
18 MS. HARVEY: Yes, thank you.
19 Any additional questions before we move 20 on?
21 All right. Next slide, please.
22 So, for review of standardized operational 23 programs up-front for the paper, and then, the 24 upcoming SECY, staff is considering two options.
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40 So, option one is status quo. So, really, 1
to review and approve only those programs material to 2
the design with regard to the ML and DC.
3 And then, option two is review and approve 4
of any operational programs that were proposed in 5
conjunction with a
design certification or 6
manufacturing license application.
7 And I'll just state here that in this case 8
the design certification applicant or manufacturing 9
license applicant would provide those at their own 10 option. So, what we're looking at right now is they 11 wouldn't necessarily be required by regulation, at 12 least at this point in time. Going back to the 13 previous comments, that could be a future change if we 14 see that.
15 So now, looking at status quo, an 16 applicant could submit today at its option a Topical 17 Report for NRC review and approval, and then, a 18 combined operating license or construction permit 19 operating license applicant could incorporate that by 20 reference in its application.
21 Alternatively, today, staff could review 22 and approve operational programs through a design-23 centered review approach, where staff would review the 24 first-of-a-kind, the entire first-of-a-kind process 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
41 through the combined license or CP and OL application 1
of a particular design. And then, that review could 2
apply to multiple other subsequent operating license 3
applications of that same design.
4 So, these regulatory tools would still 5
allow for the standardization of operational programs 6
up-front, going back to more in the phase one for 7
licensing, with the intent for the NRC staff to not 8
revisit its evaluation for the COL or CPOL applicant 9
unless there is new information/material to the 10 conclusions on the adequacy of the program or another 11 good cause.
12 But looking at this, staff had determined 13 that these reviews might not give maximum finality, 14 nor maximal efficiency benefits, as staff would be 15 reviewing, for instance, each Topical Report on its 16 own individually for applicability and appropriateness 17 specific to the design, when we would get to the 18 review for the combined license or operating license 19 stage.
20 Now, under option two, staff is exploring 21 strategies to allow really the maximum flexibility to 22 review operational programs in connection with the 23 design certification or manufacturing license. So, in 24 this case, an applicant would have the option to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
42 provide measures to satisfy an operational program not 1
required to support the design as part of the design 2
certification or manufacturing license application.
3 The NRC staff would then review these 4
programs and could approve them, as appropriate. So, 5
assuming that staff was able to make a safety finding, 6
and that the program was, essentially, complete, and 7
then, incorporate that into the design certification 8
rulemaking or the manufacturing license.
9 But again, the onus is on the applicants 10 that they would select which programs to choose to 11 provide additional information and complete 12 information on, and that they would be responsible for 13 providing the sufficient information.
14 These programs, then, would be able to be 15 referenced in the COL or CPOL application and should 16 be in an even more streamlined review at that point in 17 time, because these programs have already been 18 reviewed in the context of a design with a 19 manufacturing license or a design certification.
20 As to another -- oh?
21 CHAIR BIER: Yes, go ahead.
22 MS. HARVEY: Just the final thought is, 23 with this option, a combined operating license or a 24 construction permit operating license applicant 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
43 wouldn't necessarily be bound to an approved 1
operational program. So, if you think of a well-2 established fleet, they may want to use an operational 3
program that they have as opposed to one that a 4
developer has proposed or standardized.
5 CHAIR BIER: Okay. I do have several 6
comments or questions on this slide. This is Vicki 7
Bier.
8 First, do you envision that the agency 9
will choose one of the two options? Or is it possible 10 that both will be available pathways and that the 11 applicant will choose which process to use?
12 MS. HARVEY: So, for the purposes of the 13 Commission, the Commission consideration is that we 14 would need the Commission to tell us that option two, 15 or direct us to pursue option two. But, right now, 16 the staff fully intends, whether or not option one is 17 specified or option two, to use the regulatory tools 18 that we can currently use today, that we could discuss 19 under option one.
20 So, even if option two is directed, we 21 still expect applicants then can, additionally, choose 22 to provide Topical Reports for early review.
23 CHAIR BIER: Okay. Second, you mentioned 24 that pursuing option two would require some Commission 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 direction.
1 MS. HARVEY: Uh-hum.
2 CHAIR BIER: Do you think, following up on 3
Greg's earlier question, do you think it may require 4
rulemaking or that Commission approval of the strategy 5
would be adequate?
6 MS. HARVEY: So, that is something that I 7
think we're going to need to take a deeper dive on, 8
once the Commission provides us direction. We are 9
considering rulemaking.
For
- instance, the 10 manufacturing license regulations, you know, maybe 11 there is a more generic way to scope-in additional 12 operational programs to be reviewed, say, in the 13 manufacturing license regulations, as opposed to doing 14 it using another regulatory vehicle on an application-15 by-application basis. So, in short, yes, we are also 16 considering if rulemaking would be the best option.
17 CHAIR BIER: Okay. Yeah, I think, you 18 know, again, this is just one member's opinion, but, 19 similar to what Greg said, I don't know enough about 20 the regulatory process to know whether rulemaking will 21 be a more efficient strategy in the long run. But, 22 certainly, I would encourage doing whatever kind of 23 makes the most sense, if that means going through 24 rulemaking.
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45 The last question I have, which may be 1
more something for the Committee to ponder, but we're 2
happy to hear you guys' opinion, if you have one. It 3
seems to me that the choice between options one and 4
two, if we're only going to allow one of them, or 5
whatever, is really not a safety issue of the sort 6
that ACRS would need to opine on; that both could be 7
implemented in a way that maintains safety and that 8
the crucial ACRS safety evaluations might come at a 9
later stage, as you flesh out, for instance, what 10 kinds of operational information would and would not 11 need to be included under option two. At that point, 12 we might have strong opinions about, no, it's 13 important to include this or that aspect.
14 But I'm not sure that the choice between 15 one and two really is safety-critical at this point 16 before we know more about the operational details of 17 how they would be implemented. So again, you know, 18 right now, I think that's just something for Committee 19 members to keep in mind for a later discussion. But 20 if you want to comment on that question, I'd be happy 21 to hear your thoughts.
22 MS. HARVEY: Well, I'll just, first off, 23 say, you know, we'll absolutely defer to ACRS and what 24 you determine and decide is best.
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46 But I just wanted to reiterate the thank 1
you from earlier. I mean, the feedback is 2
appreciated.
3 MR. LYNCH: Well, I mean, I'll chime in 4
here. I think you're absolutely correct that, looking 5
at these programs as part of the early part of a 6
review, just determining the timing of when you do 7
that, it's not itself a safety issue. As you 8
correctly identified, where the safety considerations 9
come into play, so that it is detailed in the 10 operational programs themselves and how they will be 11 executed once the reactor is up and running. And, 12 yes, I think we do agree that just the timing of when 13 we perform that review is itself not a safety 14 consideration.
15 MS. HARVEY: I see another hand.
16 MR. SCHULTZ: Jackie, this is Steve 17 Schultz, consultant to the Committee.
18 You had mentioned, under option two, just 19 as you closed that discussion, that perhaps an 20 operator that had more experience or different 21 experience associated with operating a next-of-a-kind 22 design could, I'll call it, deviate from the 23 standardized operational program in some fashion.
24 Based on our previous experiences, both 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
47 with large light water reactors and, also, in the SMR 1
environment, anytime you open the door to deviations 2
from a standardized program, be it design or 3
operation, it opens the door in a regulatory 4
environment, that it becomes very complex, or has the 5
opportunity to do so.
6 So, I would suggest that we concentrate on 7
developing a standard operational program that is 8
fairly solid and that the operators of a next-of-a-9 kind design would not deviate from the standardized 10 program.
11 MS. HARVEY: So, I appreciate the 12 comments. The thought with that right now is or was, 13 I guess, to not lock COL or CPOL applicants to have to 14 use that program, but they would be able to use that 15 standardized program if they wanted, but with the 16 caveat, if they didn't use that standardized program 17 that was already reviewed, it's still going to be 18 going through the required NRC review. And you may 19 not get the nth-of-a-kind benefits that we've been 20 talking about. But I understand your comment, yes.
21 MR. SCHULTZ: That's what I would expect.
22 It can become very complex, both for the applicant as 23 well as for the staff.
24 MS. HARVEY: Right.
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48 MR. SCHULTZ: There will be a lot of 1
applicants out there for these.
2 MS. HARVEY: Uh-hum.
3 MR. SCHULTZ: And once you open the door, 4
it gets very complex rapidly.
5 MS. HARVEY: Uh-hum, right. Yes. And so, 6
the time lines that we've estimated -- and as Duke has 7
mentioned about the streamline of reviews -- you would 8
necessarily get those benefits --
9 MR. SCHULTZ: Yes.
10 MS. HARVEY: -- as we work through those 11 complications.
12 MR. SCHULTZ: Perhaps NEI will comment on 13 that later, thank you.
14 MS. HARVEY: Uh-hum.
15 And another hand?
16 MEMBER HARRINGTON:
This is Craig 17 Harrington.
18 Yes, just a comment. It does seem very 19 much like a regulatory carrot-and-stick thing; that 20 the opportunity is there; that the manufacturers and 21 the prospective purchasers and operators can take 22 advantage of all the benefits and not change a thing, 23 or they can take the slower path and do as we've done 24 in our nuclear fleet in this country for so many years 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
49 and decide you wanted a different color or a different 1
this or a different that. And so, it seems like a 2
carrot-and-stick kind of an opportunity.
3 MS. HARVEY: Okay. All right.
4 So, the last comment that I make, that 5
I'll make here -- and I had said this previously, and 6
this is before I turn it over to Duke for the 7
information slides -- is, again, just we have 8
regulatory tools right now that were discussed under 9
the status quo option. And staff fully intends to use 10 those, you know, whether we go status quo or are 11 directed to review and approve operational programs, 12 whether a DC or ML application.
13 But an important aspect of this is also 14 pre-application engagement. And so, staff just really 15 want to highlight the importance that developers or 16 COL or CPOL applicants utilize pre-application 17 engagements as much as they can.
18 All right. So, next slide.
19 Duke?
20 MR. KENNEDY: Okay. Thank you.
21 So, the next several slides cover the 22 information topics that are included in enclosure 3 to 23 the draft white paper.
24 Just as a bit of background, when we began 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
50 formulating the ideas for this paper, we had a very 1
long list of microreactor licensing and deployment 2
topics that we had developed. We went through and 3
looked at, okay, which topics can we combine that make 4
sense as a coherent paper? And those ended up being 5
the topics that led to treating nth-of-a-kind 6
licensing.
7 It was fortuitous because it very soon 8
thereafter became a focus of developers. And so, 9
then, we looked and said, well, which of these topics 10 actually require some Commission direction to achieve 11 additional efficiencies? And we pulled out the topics 12 of standardized operational programs and alternative 13 environmental reviews. And then, the topics that were 14 left that were, essentially, needed to complete the 15 roadmap for nth-of-a-kind licensing were included in 16 this enclosure. And so, I'll go through those now, 17 but the purpose of these information topics is to fill 18 out the picture of nth-of-a-kind licensing and to 19 provide additional clarity and reliability for those 20 regulatory processes.
21 So, as I mentioned before, the design 22 standardization and the benefits for streamlining 23 licensing and regulation of nth-of-a-kind 24 microreactors aren't new concepts. So, the purpose of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
51 describing maximum design standardization is more 1
setting the expectations for how design 2
standardization can work under the various licensing 3
processes and what the benefits will be for the nth-4 of-a-kind reviews. So, it's not just to create some 5
entirely new paradigm for licensing, but it's more to 6
reiterate what exists and how it can be used most 7
effectively to achieve efficiency and reduce time 8
frames for licensing nth-of-a-kind reactors.
9 So again, based on stakeholder feedback, 10 we anticipate that most licensing strategies will 11 involve up-front approval of the standard design and 12 the manufacturing license or design certification.
13 There are other regulatory pathways, such as a 14 standard design approval, or as was mentioned, the 15 licensing proceeding for a first-of-a-kind reactor.
16 But those don't provide the same level of finality and 17 standardization as the design certification or the 18 manufacturing license. And so, the focus in this 19 topic is on the design certifications and 20 manufacturing licenses.
21 And just as a quick refresher -- and maybe 22 this is coming a little bit late -- the design 23 certification is a rulemaking that codifies the 24 standard plant design.
They're included in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
52 10 CFR Part 52 as appendices. A manufacturing license 1
is a licensing action whereby the complete final 2
reactor design is approved in the manufacturing 3
license, as well as some other provisions related to 4
the organization of the manufacturing license holder 5
and aspects of transportation of a manufactured 6
reactor from the manufacturing facility to the site 7
where it's authorized to be deployed.
8 So, both manufacturing licenses and design 9
certifications can be referenced in combined licenses 10 or in construction permits and operating licenses.
11 And so, there's a variety of different ways these 12 licenses can be used in combination or connection to 13 achieve maximal design standardization and to reduce 14 the time frames for reviews at the deployment sites.
15 So, I'll go a little bit more into detail 16 now on the main tenets of maximal design 17 standardization that the NRC staff considers are 18 necessary to achieve the greatest benefits for nth-of-19 a-kind licensing.
20 So, first, the design should be usable for 21 a multiple number of units or at multiple numbers of 22 sites without reopening or repeating the review of the 23 reactor design.
24 Second, the complete plant design should 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
53 be sufficiently detailed to be approved and provide 1
finality in the design certification or manufacturing 2
license, or again, a combination of the two.
3 Third, the design should use bounding site 4
parameters that would make it suitable for licensing 5
at deployment sites with a wide variety of site 6
characteristics.
7 Fourth, to minimize the use of site-8 specific design features.
9 And then, again, fifth, applicants should 10 avoid or not take the departures from the standard 11 design in their applications for individual 12 microreactors.
13 So, on this last point, and as was already 14 mentioned, and
- also, in relation to standard 15 operational programs, departures from what's been 16 approved in the phase one up-front approval are going 17 to need to be addressed in the application for a 18 specific microreactor and reviewed by the NRC staff on 19 a case-by-case basis, which, of course, introduces 20 additional time into the review. It requires more NRC 21 staff resources.
22 And so, if a particular departure becomes 23 commonplace for a standard design, it may be 24 worthwhile for that standard design to be updated 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
54 through an amendment to the design certification rule 1
or the manufacturing license.
2 And so, this gets into an issue that we've 3
already discussed a little bit here, but that we've 4
also heard a lot about it from stakeholder through our 5
periodic meetings. It is the idea that, as 6
microreactors, our experience with microreactor 7
licensing and design grows, there are going to be 8
safety enhancements or enhancements that support 9
operational efficiency that developers want to 10 incorporate into their designs. And so, they may want 11 to iterate on a certain design over time to achieve 12 those enhancements.
13 And developers are looking to have 14 flexibility in that regard. However, the regulations 15 would require that, depending on the actual design 16 change, there would likely be a change to the design 17 certification rule or to the manufacturing license to 18 incorporate that.
19 So again, some developers have had ideas 20 that, instead of a one-size-fits-all reactor design, 21 they may have a standard basic design, and then, have 22 various models with some different features and have 23 all those models approved up-front by the NRC. So 24 that, when it comes time for deployment, they can pick 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
55 the model that best fits the actual site where it will 1
be deployed. So, the simple example is that there may 2
be two models with different resistance to seismic 3
hazards and they just pick the model that best fits 4
the actual characteristics of the deployment site.
5 So, I'll touch again on the idea that it 6
may be possible to proceed nearly directly from a 7
design certification or a manufacturing license to, 8
more or less, the nth-of-a-kind licensing process, 9
but, again, that hasn't been the experience in the 10 past. And so, it very well may take a first-of-a-kind 11 reactor to go through the complete licensing process, 12 be approved, and begin operating before it's 13 understood well enough to actually achieve the state 14 of maximal design standardization.
15 Hand up?
16 MEMBER HARRINGTON: Yes. This is Craig 17 Harrington again.
18 Just could you clarify for me, are the DC 19 and ML essentially interchangeable? Or is there 20 possibly a case where someone might obtain a DC and an 21 ML for a design? Could you just comment on how they 22 relate to each other?
23 MR. KENNEDY: Yes, yes. That's a great 24 question.
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56 So, the design certification regulations 1
and the manufacturing license regulations have a list 2
of what needs to be included in an application. And 3
they are very, very similar in terms of the technical 4
information related to the design that needs to be 5
included.
6 There are some differences when it comes 7
to the part of the nuclear plant that isn't the 8
utilization facility itself, but the part that's 9
designed to sustain the nuclear chain reaction. And 10 so, the manufacturing license is really geared towards 11 the manufacture of the utilization facility, which may 12 then require additional plant features to be at a 13 specific site in order for that utilization facility 14 to actually continue operating and produce usable 15 power. Whereas, the design certification kind of can 16 cover everything.
17 So, it is possible that there's a design 18 certification for a standard plant; there's a 19 manufacturing license that references the utilization 20 facility portion of that design certification. The 21 utilization facility is manufactured in the 22 manufacturing facility, and then, the combined license 23
- holder, for
- example, references the design 24 certification in their license. And then, that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
57 manufactured reactor is able to be brought to the site 1
covered in the combined license that authorizes 2
operation of that manufactured reactor.
3 So, there's an interplay here between the 4
different types of licenses that can be used and how 5
they can be referenced and which different licenses 6
cover different aspects of the entire plant design.
7 Does that answer your question?
8 MEMBER HARRINGTON: I think so. It sounds 9
like it's a bit of a complex interaction, and as with 10 all the rest we've talked about, ultimately, it comes 11 down to some choices and decisions by the designers, 12 the manufacturers, the users, how they want to proceed 13 through the various licensing tools.
14 MR. KENNEDY: Okay.
15 MEMBER HARRINGTON: So, thanks.
16 MR. KENNEDY: And you just stated my last 17 point on this slide. So, thank you for that.
18 And, okay, move to the next slide, please.
19 The next topic is grading the level of 20 site characterization, which is really described at a 21 conceptual level in the white paper. And the concept 22 described in the white paper is, essentially, to use 23 margins between the actual site characteristics and 24 the bounding design parameters and the margins to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
58 appropriate those reference values to assess whether 1
it would be appropriate to use alternative methods for 2
site characterization.
3 This will be done on a parameter-by-4 parameter basis. So, while some parameters, site 5
characteristics or parameters, would need to be looked 6
at in a more traditional way, other parameters might 7
be able to benefit from grading the level of 8
characterization.
9 So, just as a couple of examples for a 10 microreactor that's designed to withstand high seismic 11 hazards, site characterization through a literature 12 review or based on regional hazard maps might be 13 adequate if the literature shows that the seismic 14 hazards for that proposed site are very low. So, 15 there you have a large margin between the bounding 16 design values for the reactor and the actual site 17 characteristics.
18 Another example is that, if there is an 19 event that would be caused by exceeding some site 20 parameter, but that event has no or very low 21 radiological consequences compared to the reference 22 values, it may be adequate to grade the level of site 23 characterization for that specific parameter that 24 could potentially induce an event.
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59 There's another idea that's discussed in 1
the paper and that is that the design could be 2
insensitive to certain site characteristics. And so, 3
for example, a reactor that's located deep underground 4
might not be sensitive to meteorological conditions at 5
the site.
6 And so, for instance, in that case where 7
a reactor is not sensitive to meteorological 8
conditions or it's found that there are large margins, 9
it might not have to go through the process of 10 collecting site-specific meteorological data over a 11 long period of time. It might be adequate to, again, 12 rely on available information.
13 So, one thing I want to point out, also, 14 about this concept of grading the level of site 15 characterization is that we're here today talking 16 about nth-of-a-kind microreactors, but this is one 17 topic where the staff is considering whether these 18 approaches could be applied to other types of 19 reactors, including first-of-a-kind reviews for 20 specific reactor designs.
21 So, that's actually a larger theme in this 22 paper and in the Commission paper that went up in 23 January on factory fabrication of microreactors. But 24 we are focused right now on microreactors, but we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
60 understand that some of these ideas and concepts have 1
broader interest to other developers. And so, we're 2
considering that now and that's something that will be 3
considered in the development of guidance as well.
4 Go to the next slide, please.
5 Okay. This slide covers deployment site 6
emergency preparedness. And so, enclosure 3 of the 7
white paper includes information about emergency 8
preparedness for microreactors. That's in addition to 9
the discussion that's in enclosure 1
about 10 standardization of emergency preparedness programs.
11 So, enclosure 1 discusses considerations 12 related to standardization such as site-specific 13 considerations, efficiently addressing emergency 14 planning zone sizing, and deployment of multiple 15 microreactors at the same site.
16 So, existing regulations for emergency 17 preparedness that are in 10 CFR Part 50 and Part 52 18 apply to microreactors. And an applicant for a 19 license or in considering the development of a 20 standardized operational program could choose to use 21 the regulations that are in 10 CFR 50.47(b) and 22 appendix E,
which is emergency planning and 23 preparedness for production and utilization 24 facilities, or the requirements in 10 CFR 51.60, which 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
61 are emergency preparedness for small modular reactors, 1
non-light water reactors, and non-power production and 2
utilization facilities.
3 So again, there are choices for developers 4
to make. We are trying to stay flexible and allow for 5
developers to decide what's best for their deployment 6
models.
7 In either case, the NRC has a graded 8
approach to emergency preparedness in which 9
requirements are set commensurate to the radiological 10 risks and hazards of the facility. And so, 11 microreactor applicants can use this risk-informed 12 approach to emergency preparedness to establish 13 appropriate emergency plans and response capabilities.
14 So, finally, on emergency preparedness, 15 let's say that the staff is exploring approaches for 16 streamlining the review of emergency preparedness for 17 licensing and for the kind of microreactors based on 18 considerations such as the possibility that potential 19 accidents would result in low doses at the site 20 boundary and under certain circumstances might not 21 require extensive offsite response.
22 Yes, hand up?
23 MEMBER ROBERTS: Yes, this is Tom Roberts.
24 I noticed that your previous slide didn't 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
62 address site population. This slide has that such as 1
caveat in the second bullet that talked about the 2
possibility that the dose at the site boundary might 3
be so low that you don't need to have extensive 4
offsite response.
5 Doesn't that same thought apply to the 6
siting? And if not, what is your thought in terms of 7
a generic site population density or how would you 8
bound that in the site characterization?
9 MR. KENNEDY: Sure. Thank you for the 10 question.
11 There was a SECY paper that was presented 12 to the Commission, I want to say it was SECY 20-0045 13 on site and on population density considerations for 14 siting, in which the staff presented a few different 15 alternatives for how to determine the appropriate 16 location for siting a reactor, depending on proximity 17 to population density centers, as well as the 18 population density outside of that center.
19 And so, those alternatives included 20 consideration of microreactors. And the Commission 21 provided an SRM on that SECY paper, and then, the 22 staff proceeded to update; I believe it was Regulatory 23 Guide 4.7, I hope. That's right, isn't it? Okay.
24 So, that has been looked at.
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63 Later, I'll mention again the ADVANCE Act, 1
and the ADVANCE Act also has direction in it for the 2
NRC staff to reconsider the population density siting 3
criteria to ensure that it has taken a risk-informed 4
and performance-based approach to considering 5
population density siting criteria specifically for 6
microreactors.
7 MEMBER ROBERTS: Right. Yeah, thank you 8
for that.
9 There's two approaches one could take.
10 One is the such as caveat on this slide, which is the 11 site population density, per Reg Guide 4.7, will not 12 be a concern if the doses at the site boundary met the 13 criteria in Reg Guide 4.7. So, that's a relatively 14 elegant solution.
15 The second approach is the one I'm asking 16 about, which is, if you can't meet that, then I'm 17 wondering how you would do a
generic site 18 characterization, given that the site population 19 density would be a factor in determining whether or 20 not or how you might meet the criteria in Reg Guide 21 4.7.
22 So, it may be that your intent is to make 23 that an equivalent of an ITAAC condition for the site, 24 or it may be that you would put that in the generic 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
64 site as a boundary condition. That's what I'm trying 1
to understand, how that plays out.
2 MR. KENNEDY: Yeah, I understand the 3
question. I think all the options are on the table.
4 At this point, we're not trying to hone-in on any 5
particular one here, but in the process of developing 6
standardized programs and in any related guidance, 7
those are great considerations.
8 MS. HARVEY: And, too, with the guidance 9
that is being developed for the siting considerations, 10 that's great site care characterization.
11 MEMBER ROBERTS: Yes. Okay. Thank you.
12 MR. KENNEDY: Okay. I guess we'll move to 13 the next slide, then, please.
14 Yes, the next slide covers streamlined 15 processing of license applications and licensing 16 documents. So, the idea here is that, when you get to 17 nth-of-a-kind licensing and you're processing many 18 applications for reactors of the same design, and 19 there are a limited number of site-specific factors 20 that need to be considered, the applications will 21 generally be required to contain the same small set of 22 information and they will look similar.
23 In the same vein, the licensing documents 24 that are generated by the NRC during the licensing 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
65 process will also look very similar for microreactors 1
of a common standard design, but perhaps, also, more 2
broadly across microreactors of a certain type of 3
design. For example, the self-contained reactor 4
designs may all have very similar aspects in their 5
applications and in the documentation generated by the 6
NRC.
7 And so, the idea in this topic is really 8
to look for those new opportunities to rely heavily on 9
electronic processing of submitting applications, as 10 well as processing the applications to the latest 11 review steps, to really reduce the resource burden on 12 the NRC staff in the administrative aspects.
13 So, I just want to be clear that we're not 14 talking about artificial intelligence here or 15 replacing NRC technical staff with AI algorithms.
16 This is simply about well-established data 17 manipulation software where data can be put into a 18 database, and then, populated in templates or various 19 documents automatically to avoid manual manipulation 20 by the NRC staff.
21 Also, it can be used to compare, for 22 example, a value in a license application with the 23 bounding values that are considered in the actual 24 design approval as a first check to make sure that an 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
66 application is actually providing information that's 1
consistent with that standard design. And if it's 2
not, that may be okay. It may be indicating a 3
departure, but at least that can provide a flag for 4
the NRC staff to see that there's a discrepancy there.
5 And so, this feature can also, I think, 6
help in streamlining our process for acceptance 7
reviews as well, especially considering the smaller 8
volume of information in an application for an nth-of-9 a-kind reactor where the design has already been 10 reviewed and approved.
11 So, just like under the current process 12 where all of the NRC documentation is subject to 13 quality checks and technical verification by qualified 14 staff, this is no different. It's just using 15 electronic tools to perform a lot of the steps that 16 are now administrative and performed by hand.
17 And going back to kind of documents 18 looking similar, this is also an opportunity to rely 19 more heavily on templates than we have in the past, 20 where we're looking at individual first-of-a-kind 21 reactor designs with very large and complicated 22 reviews and needing to tailor each of the various 23 licensing documents to really fit that particular 24 design. Here we have an opportunity to do a lot more 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
67 things generically using templates and automated 1
tools.
2 Okay. Next slide, please.
3 Okay. So, the final information topic 4
that's covered in this presentation is construction 5
inspection. So, in 2023, the NRC staff provided SECY-6 23-0048 to the Commission, which covered the staff's 7
vision for the Advanced Reactor Construction Oversight 8
Program, or ARCOP.
9 So, the NRC staff's ARCOP vision looks to 10 build on its construction oversight experience while 11 remaining adaptable to future advancements in reactor 12 technologies, such as those that we're seeing 13 potentially being proposed for microreactors.
14 So, going back to what Jackie mentioned 15 earlier in the presentation about there's, generally, 16 two types of microreactors, one that's a self-17 contained design and one that relies more heavily on 18 actual site construction activities. There's an 19 important distinction there when it comes to 20 developing and performing construction inspection.
21 For designs that would be manufactured 22 almost entirely in a manufacturing facility, and there 23 may be very few site disturbances, more inspection 24 activities or the inspection program would focus on 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
68 what's being done at the manufacturing facility, in 1
addition to verification that the reactor has been 2
installed appropriately at the deployment site 3
location.
4 On the other hand, of course, for 5
microreactors of the core module design, where part of 6
the reactor is manufactured and there's still 7
substantial construction activities onsite, again, the 8
balance between the two locations in the inspection 9
program, but it may rely more on inspections that are 10 performed at the actual deployment site.
11 So, the NRC staff is considering 12 approaches for risk-informed and performance-based 13 inspections at both of these locations, the 14 manufacturing facility and the deployment site, and is 15 looking for ways to ensure that these inspection 16 activities can be carried out within the time frames 17 for construction and manufacture that will be 18 considered by the developers, so that the construction 19 inspection process doesn't become a holdup on the 20 critical path for the entire licensing process.
21 And so, through gaining experience and 22 refining the program, it's anticipated that the 23 program can be scaled over time to really hone-in on 24 the amount of inspection that's really necessary to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
69 meet the program objectives, and in this way, ensure 1
that the overall construction inspection time frames 2
and the required findings can be made within the 3
construction time lines being considered by 4
developers.
5 And so, the staff expects to communicate 6
the details of the ARCOP program in a separate paper 7
to the Commission in the future.
8 Next slide, please.
9 All right. So, just to give a little bit 10 of background on stakeholder engagement, as I 11 mentioned, we first engaged with stakeholders on the 12 concepts for this paper in December of last year, and 13 then, we engaged again in March and July on more 14 details regarding the topics that are included in the 15 paper; the ideas that the staff was considering for 16 approaches to standardized operational programs and 17 alternative environmental reviews.
18 Also in this time frame, there was a 19 session at the Regulatory Information Conference that 20 focused on factory-fabricated microreactors. And so, 21 these ideas were discussed as part of the staff 22 presentation during that session, and some of the 23 developers and other panelists also provided their 24 insights related to some of the concepts that became 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
70 part of this paper.
1 I think the feedback that we heard was 2
generally supportive of the approaches that the staff 3
were developing and about the scope of the paper. And 4
there's interest in stakeholders staying engaged in 5
the development of any guidance that would be 6
necessary to implement Commission direction on the 7
SECY paper that we're planning to prepare.
8 There were also public meetings with 9
various developers that provided additional 10 information to the NRC staff about developers' plans 11 and, also, what their anticipated licensing and 12 deployment strategies might look like.
13 We also received a paper from the Nuclear 14 Energy Institute that covers regulations of rapid, 15 high-volume, deployable reactors in remote 16 applications and other advanced reactors. And this 17 provided industry perspectives on most of the topics 18 covered in this paper, as well as other topics that 19 have been addressed or considered in previous NRC 20 papers or that are still available for future 21 consideration.
22 And then, finally, we are planning to hold 23 a public meeting dedicated to discussing this white 24 paper in early November. This is, essentially, the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
71 same thing that we did before we provided the SECY 1
paper on factory-fabricated microreactors to the 2
Commission. We had a dedicated public meeting to 3
explain what was in the paper to the public, to hear 4
any public feedback. And so, we're planning a similar 5
meeting in early November, with the exact date to be 6
determined, but the announcement for this meeting 7
should be forthcoming in the very near future.
8 Next slide, please.
9 Okay. So, next steps. So again, we're 10 planning to develop a Commission paper on nth-of-a-11 kind microreactor licensing and deployment 12 considerations that is based on this draft white 13 paper. It will request Commission direction on 14 regulatory approaches for standardizing operational 15 programs, as well as direction on options for 16 alternative environmental reviews. And it will 17 provide the information on these other topics to round 18 out the picture of nth-of-a-kind microreactor 19 licensing.
20 Finally, I wanted to provide a little more 21 detail about the ADVANCE Act and how it relates to 22 microreactors, and what the NRC staff is doing in 23 response to the congressional direction in ADVANCE 24 Act.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
72 So, Section
- 208, which is titled 1
Regulatory Requirements for Microreactors, directs the 2
NRC staff to develop and implement risk-informed and 3
performance-based strategies and guidance to license 4
and regulate microreactors.
5 And it includes eight topical areas. The 6
topical areas are staffing and operations; oversight 7
and inspections; safeguards and security; emergency 8
preparedness; risk analysis methods; decommissioning 9
funding insurance; transportation of fueled 10 microreactors, and siting. And siting includes three 11 subtopics which are considerations related to 12 population density; licensing mobile reactor 13 deployments, and environmental reviews.
14 So, the staff plans to address the ADVANCE 15 Act through the existing regulatory framework -- for 16 example, just guidance documents -- through the Risk-17 informed and Technology-inclusive Regulatory Framework 18 for Advanced Reactors that's being developed in 10 CFR 19 Part 53, and other rulemakings, as appropriate, 20 whether there are other ongoing rulemakings or we need 21 to initiate new rulemakings to fully implement the 22 direction in the ADVANCE Act.
23 So, in this respect, the staff is working 24 proactively to enhance clarity, reliability, and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
73 efficiency of its Regulatory Framework for 1
Microreactors, while maintaining a focus on safety, 2
security, and the environment. This includes 3
addressing policy topics related to microreactors, 4
such as the topics that are covered in the white paper 5
and planned Commission paper that we're discussing 6
today. Also, the topics that were covered in the SECY 7
paper in January on factory-fabricated microreactors 8
and developing new regulations and guidance for 9
advanced reactors.
10 And so, the NRC staff will continue to 11 engage with stakeholders as it identifies, develops, 12 and establishes new or revised strategies that may be 13 needed to optimize the Regulatory Framework for 14 Microreactors and fully implement the ADVANCE Act.
15 So that, I hope, gives you a little more 16 perspective on what's in the ADVANCE Act related to 17 microreactors and how the NRC staff's activities are 18 working to address the ADVANCE Act.
19 So, that concludes the presentation, and 20 thank you very much for all of your questions so far 21 and your feedback. And we will do our best to answer 22 additional questions and we'll welcome all the 23 additional insights from the ACRS. So, thank you very 24 much.
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74 So, there's a hand up.
1 MEMBER HALNON: Hi. Yes, this is Greg 2
Halnon.
3 I'm sure at the upcoming RIC we're going 4
to have sessions, if not more than one, on the 5
ADVANCED Act. Have you proposed a specific session on 6
the microreactor licensing?
7 MR. KENNEDY: I do not believe that we 8
have proposed a session on microreactor licensing as 9
of this date, but I would need to check with the 10 actual people who are responsible for developing the 11 RIC program this year.
12 MEMBER HALNON: Okay. Well, just it might 13 be good to take advantage of the momentum that we 14 have, and there's a lot of good ideas out there. At 15 some point, they all have got to come together, so you 16 guys can put together some framework. But, hopefully, 17 it won't be just embedded into a larger session 18 because I think it warrants a lot of discussion.
19 But thanks. A lot of good work going on 20 and I appreciate the presentation. I think that your 21 thought processes are very good. Thank you.
22 MR. KENNEDY: Okay. Thank you very much 23 for the feedback.
24 CHAIR BIER: Are there any further 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
75 questions for staff at this time?
1 Yes, Joy, are you -- I don't see your 2
information -- are you a member of the public or are 3
you staff, or what's your role?
4 MS. JIANG: Hello. Can you hear me?
5 CHAIR BIER: Barely. Can you speak up a 6
little bit?
7 MS. JIANG: Can you hear me now?
8 CHAIR BIER: That's better, yes.
9 MS. JIANG: Oh, good.
10 This is Joy with The Breakthrough 11 Institute nuclear team.
12 CHAIR BIER: So, we are not quite at 13 public comments yet.
14 MS. JIANG: Okay.
15 CHAIR BIER: Are you able to stay on and 16 provide your comment later?
17 MS. JIANG: Yes. Sure.
18 CHAIR BIER: Okay. That's great. Thank 19 you very much.
20 What I would propose is that we take a 21 short break now, then hear from NEI, and then, go to 22 public comments. Is that agreeable with everyone?
23 MR. KENNEDY: Yes.
24 CHAIR BIER: Okay. It sounds like 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
76 everybody is ready for a break. Can we get back at 1
12:00 Eastern or do people need an additional five 2
minutes?
3 MR. LYNCH: That's fine, Vicki.
4 MS. HARVEY: It's good with us.
5 CHAIR BIER: Okay. So, let's plan to get 6
together again at 12:00, and then, we'll start with 7
NEI and go to public comments after that.
8 MS. HARVEY: Okay. Thank you.
9 CHAIR BIER: All right. So, we're now on 10 break and we'll see everybody soon.
11 (Whereupon, the above-entitled matter went 12 off the record at 11:49 a.m. and resumed at 12:00 13 p.m.)
14 CHAIR BIER: Okay. It looks like we are 15 at 12 o'clock Eastern. So, at this point, I think we 16 can go ahead with the NEI presentation, and then, we 17 will take public comments and Subcommittee discussion 18 after that.
19 You can go ahead. Thank you.
20 MR. NICHOL: All right. Thank you, Vicki.
21 Thank you, other members of the ACRS, for letting NEI 22 present today on what we call rapid high-volume 23 deployable reactors for remote applications. I'll 24 explain that, but, largely, it's the same topic that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
77 you just heard from the NRC in that area.
1 And most of my presentation -- well, 2
almost everything I'm going to say -- is going to 3
focus on the concepts and proposals NEI developed. I 4
will note that there is a lot of alignment with what 5
the NRC just proposed or presented to you. Certainly, 6
at the big-picture, conceptual level I think there's 7
direct alignment and agreement there.
8 There are differences at the detail level.
9 I'm actually going to try not to go into those. We'll 10 save that for the public meeting that the NRC is 11 planning in November. But I will note sometimes the 12 details matter. And so, we will cover that with them.
13 The other thing I wanted to mention just 14 at a big-picture standpoint, we certainly agree with 15 the NRC that, while these efforts have started out 16 focusing on microreactors, we also agree that many of 17 these concepts could be extrapolated to other advanced 18 reactors. In fact, that's one of the things we tried 19 to do in our approach, is to make it a little bit more 20 graded.
21 So, most of what I'll talk about is on the 22 far end of the range, in which we would expect it's 23 microreactors that would be able to achieve these 24 things, but in our proposal we did establish graded 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
78 approaches, so that if other advanced reactors could 1
meet them in part, but maybe not in whole, or they 2
could meet them in whole, then they would have a 3
graded approach to that. And it's all based around 4
establishing the right performance-based acceptance 5
criteria.
6 And so, what we found is that considering 7
the potential applicability to other advanced reactor 8
types really helps to get to the right performance-9 based acceptance criteria, which are what you will 10 use, what would be used to determine who would be able 11 to utilize this approach. So, I wanted to mention 12 that.
13 So, that's why we called it the rapid 14 high-volume deployable reactors rather than 15 microreactor end-of-a-kind. We wanted to focus more 16 on the performance-based aspect of it, more about the 17 applications than a specific -- what we worried about 18 mostly and why we avoided using microreactor as much 19 as possible -- we didn't want this to be tied to a 20 specific power level, because power level is not a 21 very good proxy for levels of safety and safety and 22 security performance. So, that's why we called it 23 that.
24 Just a quick status in what's new. So, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
79 you're well familiar with all of the microreactors 1
work that the NRC has done. I've got a slide that 2
just summarizes it real quickly.
3 Really, what was new -- and we're building 4
on that -- but what was new is there's interest in oil 5
and gas beyond that. And, in particular, Shepherd 6
Power had sent a letter to the NRC articulating that, 7
in order for nuclear energy to be viable for meeting 8
their business needs and decarbonizing their 9
operations, they're looking for the NRC to support a 10 180-day or less deployment. That's from site 11 identification to operations, and then, also, to try 12 to achieve regulatory costs that are on the range of 13 1 percent of total cost on the capital and O&M.
14 And then, of course, we have the ADVANCE 15 Act, Section 208. We think that our proposal could 16 be, if the NRC agreed with it, could be a good 17 starting point for the blueprint for that regulatory 18 framework.
19 And we asked, in the letter that we sent 20 to the NRC, we asked a couple of questions.
21 One, does the NRC think that this is the 22 right scope of issues that need to be addressed to 23 enable the business model?
24 Two, did the proposals that we had in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
80 there and the broad outcomes, did they look 1
potentially achievable from where we stand today?
2 And then, three, is the NRC interested in 3
trying to address all of those.
4 So, we've asked for a response by the end 5
of the year on that.
6 I am going to go into the topics. I will 7
note that our paper tried to be comprehensive. We 8
didn't want to identify a few topics today, and then, 9
a year from now identify a few more topics. We wanted 10 to identify the entire suite of topics. So, we have 11 about 31 in our paper.
12 David Petti, I see your hand is up.
13 MEMBER PETTI: Yes. Marc, before you get 14 into that, I looked ahead and I wasn't sure. Help me 15 with the mental model of these rapid deployable. Are 16 we talking about something like a Tesla factory or 17 something more like Boeing's airplane factory? Or is 18 it even yet different again? How do you mentally 19 envision -- you know, what does it look like to you?
20 Because that, I think, helps think about you, you 21 know --
22 MR. NICHOL: Yes. It would be, yes, I 23 don't know, between Tesla and Boeing, I don't know 24 exactly which one it fits into. But the concept, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
81 maybe to describe it in words, would be that the 1
manufacturer of these microreactors are able to 2
manufacture them when they want to, and then, as a 3
customer comes in and places an order, they would be 4
able to ship them to the customer very quickly.
5 I'm avoiding off-the-shelf, as some 6
companies may want to have these stocked on shelves 7
and they just pull them off the shelf when they get 8
the order and ship them out. Some companies may want 9
to have a little bit more build-to-order. It will all 10 depend on the manufacturing timescale; how much 11 advance notice they get from the customer before they 12 need delivery.
13 So, within this model, some of the things 14 we heard is
- that, even though the specific 15 identification of the site would happen about six 16 months before they would want to initiate operations 17 of the gas well, that before that site identification, 18 they would know they need power. They just wouldn't 19 know which site they need it. Maybe they would know 20 they would need power a year before that.
21 So, there would be enough time to enable 22 the manufacturing of it, but when it gets to 23 identifying the site, there's not as much time to be 24 able to work through all the site specifics. So, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
82 similar to the NRC, we're trying to move those earlier 1
in the process, so the NRC is not part of the 2
bottleneck.
3 MEMBER PETTI: Okay. Well, thanks. That 4
helps.
5 CHAIR BIER: Another question. This is 6
Vicki Bier.
7 Again, it's probably looking ahead, and 8
maybe you were planning to get to this. But do you 9
have a definition of remote, either in terms of 10 distance or population density, or whatever? Because 11 it sounds like some of these might be truly remote, 12 you know, with no resident civilian population nearby, 13 or whatever. And other of the examples, like, you 14 know, a village in Alaska that has poor energy access 15 would be a small population, but with a local civilian 16 population that might be quite nearby.
17 So, do you have a definition in mind for 18 that?
19 MR. NICHOL: So, we don't have a specific 20 definition. The reason we picked the concept remote 21 is that we wanted to not have to include population 22 siting as one of the issues that was critical to this.
23 So, our concept for saying remote is that these would 24 be located far enough from population centers that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
83 they would be well outside the population distance 1
requirements that the NRC has.
2 Now, there's nothing precluding these from 3
someday in the future being located closer to 4
populations, but, then, they would have to address the 5
population siting requirements. And we just wanted to 6
remove those population siting requirements from these 7
considerations, so that we could focus more 8
specifically on the technical aspects.
9 CHAIR BIER: Okay. Thank you.
10 And Greg?
11 MEMBER HALNON: Yes, Marc, this is Greg.
12 Back to Dave's question, just to put a 13 period at the end, that 180 days on your slide, what 14 is your assumption going into that? Is that an off-15 the-shelf or is it independent of the manufacturing 16 piece of it?
17 MR. NICHOL: It would be, it would 18 effectively be off-the-shelf. There may be, as I 19 mentioned, if there's a long tail to the order, then 20 there could be some build-to-suit. But the idea would 21 be that site identification, that date, the reactor 22 would be manufactured, licensed or approved under a 23 manufacturing license or DC. It would be manufactured 24 and it would be ready to ship on the day when the site 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
84 was identified.
1 MEMBER HALNON: Okay. So, there's some 2
parallel work going in there, but also some work prior 3
to that 180?
4 MR. NICHOL: That's right, yes.
5 MEMBER HALNON: Okay. Thanks.
6 MR. NICHOL: Yes.
7 All right. So, moving on to the next 8
slide, just the historical work. We included the NRC 9
SECYs and all the topics they've worked on for 10 microreactors before. NEI has also submitted papers 11 on these topics in similar time frames. And so, this 12 shows which papers addressed different topics previous 13 to this.
14 Now, of those, there were 22 topics.
15 Sixteen of those topics are part of the 31 topics in 16 our RHDRA proposal. Most of those 16, as we looked at 17 the RHDRA, the business model needs, needed additional 18 work and extension on them. So, it's not to say 16 of 19 those issues were closed because of this prior work.
20 Sixteen of those issues will benefit from the prior 21 work, but will need to be extended to fully consider 22 the new business models.
23 So, this slide comes from our paper and 24 letter to the NRC. We recognize that 31 topics were 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
85 a lot to take on all at once and resources are always 1
a consideration. We also knew that we didn't have to 2
address all of them immediately; that we had time for 3
some issues to address later on.
4 So, we put together this prioritization 5
matrix, high priority versus medium or low priority, 6
and then, near-term resolution is needed versus 7
longer-term resolution is needed. And we laid out our 8
issues on that.
9 The yellow highlighting is to show where 10 the NRC's current NOAK paper maps to our issues.
11 Sometimes we use different terminology. Largely, it's 12 the same scope, but sometimes we divide scope a little 13 bit differently than the NRC.
14 But you can see that the NRC's paper, for 15 the most part, addresses all of our upper left, near-16 term urgent, high priority, with the exception of 17 operations staffing, and then, they address some 18 others in the other boxes as well.
19 Dennis, I see your hand.
20 MR. BLEY: Yes. This isn't a safety 21 issue, but I'm kind of stewing over your last slide.
22 Even now, if you need to order large 23 equipment, like a new transformer, and then, other big 24 things, you've got a long wait for it to be built.
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86 The idea that these could be even close to off-the-1 shelf implies a massive investment in inventory to me.
2 I just wonder if you guys have thought much about how 3
practical this is. I can understand why the buyer 4
would like it, but it isn't at all clear how a 5
manufacturer could do it.
6 MR. NICHOL: Yes. So, part of it rests on 7
the volume of deployments that would be expected.
8 We've heard, based on demand, that we could expect 9
hundreds and thousands of microreactors to be ordered 10 and deployed. And so, there likely would be the 11 volume of orders to be able to support something that 12 would be more like reactors on the shelf. And it may 13 not be exactly that. But the throughput at the 14 factories would be such that it could support a 15 business model where manufacturing begins before the 16 specific customer is identified.
17 MR. BLEY: Okay. Thanks.
18 MR. NICHOL: Uh-hum, yes.
19 All right. As we looked at this, just a 20 top-level conceptual, we recognized, one, that the 21 design features certainly for microreactors, but also 22 for similar type of advanced reactors that can be 23 rapidly deployed in high volumes were a lot different 24 from large light water reactors, are somewhat 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
87 different from other advanced reactors.
1 The application and use cases are 2
different. So, as you consider -- and partly, the 3
application and use cases are enabled by design 4
features -- and then, as you consider both of those, 5
it really lends itself to alternative regulatory 6
approaches that the NRC would be able to ensure public 7
health, protection of the public health and safety in 8
different ways, because the designs are different, 9
because the applications are different.
10 This showed linearly, just because I 11 wanted to have some detail on it, but if you look at 12 the lower left, really, it's sort of an iterative 13 process. So, the design features inform the 14 applications and use cases. They inform alternative 15 regulatory approaches. Those alternative regulatory 16 approaches, in turn, have a feedback loop to enable, 17 oh, the industry to think about we could do different 18 things in design space because it makes more sense.
19 Somebody earlier said it's a carrot-and-20 stick type of approach. The NRC's regulations can be 21 crafted in a way that incentivizes industry to achieve 22 safety in different ways, but even at higher levels.
23 And so, that's really important.
24 So, I see Steve Schultz's hand is up.
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88 MR. SCHULTZ: Yes, Marc. A question.
1 Both you and the NRC, where you've got on 2
this slide in the second box that there's limited time 3
of used fuel onsite, referring to the fact that the 4
reactors will be brought to the site, and then, taken 5
away. On the previous slide, you had transportation 6
to the site, but not from the site. Is that going to 7
be a high hurdle or a low hurdle in terms of 8
regulatory review and approval, the movement of the 9
used reactors away from the site --
10 MR. NICHOL: Yes.
11 MR. SCHULTZ: -- to the decommissioning 12 facility?
13 MR. NICHOL: Yes, it certainly needs to be 14 considered. I believe we do touch on it in our paper 15 "Transportation of Used Fuel."
16 It will be similar to the fresh fuel 17 transport in terms of if it's loaded in a reactor, 18 but, as you point out, there will be many other 19 considerations because it now is radioactive. It now 20 does produce heat. And so, all of those will have to 21 be considered within how they're meeting the 22 transportation requirements and doing it safely. So, 23 yes, that does need to be included.
24 MR. SCHULTZ: Yes, for both you and for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
89 the NRC staff as well. I mean, this could be a very 1
nice feature associated with the overall utilization, 2
but it ought to be something that's included for sure 3
really up-front to make sure everything is in place 4
for the whole operation of the microreactors.
5 MR. NICHOL: Yes.
6 MR. SCHULTZ: Thank you.
7 MR. NICHOL: Yes, thank you.
8 Dennis?
9 MR. BLEY: Yes, staff didn't talk about 10 this, but I'd go back to them later after you're done.
11 If your sources are correct, then there 12 might really be hundreds of thousands of purchases.
13 To me, it implies a different kind of NRC than we have 14 now for reactors, something you will likely do for 15 materials, where some of the states take over some of 16 the regulatory activities. And the staff wasn't 17 talking about these kinds of large numbers. Have you 18 guys thought about that aspect as well?
19 MR.
NICHOL:
It came up briefly.
20 Certainly, you make a good point. That could be 21 considered as one option.
22 We didn't pursue that as an option. We 23 wanted to stick more closely into the NRC itself would 24 regulate these because they're power reactors. And 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
90 because, as we looked at it and we identified, well, 1
the NRC could do this, it takes some rule changes. In 2
fact, I didn't mention this, but we identified 37 3
regulations that would need to be modified to be able 4
to fully enable this. And so, there is quite a bit of 5
rulemaking that would be needed. Exemptions could be 6
used in the interim.
7 But, yes, so it was briefly considered, 8
and then, we sort of put it to the side and wanted to 9
focus on the traditional NRC licensing.
10 MR. BLEY: Thanks. Go ahead.
11 MR. NICHOL: Yes. Okay.
12 So, one of the things we did is looked --
13 and this is a notional chart; it's relative 14 comparisons. So, these aren't strictly perfect 15 numerically. But it identified that, as you look at 16 microreactors, which is the starting point we had for 17 a lot of these ideas, they're much more similar to 18 research and test reactors, based on the relative 19 potential consequences. And we know that the NRC 20 regulates in proportionality to the potential 21 consequences.
22 And so, we looked at that and said, well, 23 if microreactors are really much more similar to 24 research and test reactors from a
potential 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
91 consequence standpoint, what could we learn from that?
1 And then, this next slide is that we looked. We 2
actually have an appendix in our paper that talks 3
about RTR regulatory framework and how the RHDRA could 4
be based on that. It might require some adaptation, 5
but certainly could be a good starting point.
6 And there's a lot of similarities, 7
especially at the rule-level language. A lot of the 8
differences are more at the guidance level. And so, 9
that was really insightful to know.
10 And when we thought through it, there's 11 really a benefit to starting with the research/test 12 reactor framework. And then, as we have traditionally 13 been looking at advanced reactors, starting from the 14 large light water reactors approach, we're naturally, 15 by human nature, we're anchored to those requirements.
16 So, it's very hard to get very far away from those 17 requirements.
18 But if we start with the research/test 19 reactors, which we know provide reasonable assurance 20 backed with protection for that class of designs, and 21 if our RHDRA designs are very similar from a 22 consequence standpoint, then we could get to a much 23 more efficient and effective regulatory framework.
24 So, that was our starting point for a lot of the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
92 concepts and proposals that we made.
1 Dennis?
2 MR. BLEY: Yes. The argument here makes 3
sense to me and, in fact, the Committee has argued 4
something similar in the past. But the key is that 5
the consequences are much smaller than you would get 6
from the large reactors.
7 Your avoidance of microreactor discussions 8
and saying safety and power are pretty much decoupled, 9
well, potential source term and power are not so 10 decoupled. And it seems to me trying to stretch this 11 to cover factors that are in many senses further away 12 from research and test reactors kind of strains the 13 credulity a bit on the other arguments.
14 MR. NICHOL: Yes, and you make a good 15 point. And in my opinion, it really heavily depends 16 on the performance-based acceptance criteria that are 17 established. And what we have proposed in our paper 18 is those performance-based acceptance criteria are 19 really consequence-based, based on doses at distances.
20 Sometimes we can look specifically at, you know, if a 21 design can achieve a site boundary emergency planning 22 zone, we think that would enable a certain approach.
23 Or sometimes we might look at it and say, well, that 24 is good, but it's not enough; we actually need that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
93 site boundary to be less than a certain distance, and 1
then, that enables something.
2 We do have some comparisons in our paper 3
on dose at distances for some research/test reactors 4
and some microreactors. So, in that respect, anywhere 5
we have proposed criteria that are very heavily 6
dependent on a dose-at-distance acceptance criteria, 7
those lend themselves toward mostly being applicable 8
to microreactors. A lot less is available as you get 9
down that graded approach. But, then, there are some 10 that are more decoupled from that acceptance criteria, 11 and you can apply more at that graded approach for 12 large reactors.
13 So, it is very topic-dependent. There's 14 not a one-size-fits-all on all these topics.
15 Greg?
16 MEMBER HALNON: Yes, thanks, Marc.
17 I agree, when you draw a circle around the 18 actual reactor plant, that your consequence and 19 radiological issues are similar to RTRs. The only 20 thing I would ask you to do is continue to keep in 21 your thought process the different commercial 22 processes that these things are being used for and the 23 pressures of requiring a profit versus RTRs don't 24 necessarily use their heat to try to make profit.
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94 And I know that's addressed in the 1
percentage of operating costs versus what you get out 2
of it. However, it's not insignificant from the 3
standpoint of commercial pressures that these might be 4
under for making a profit.
5 So, just keep that safety culture aspect 6
in mind as you go through all this. That is one, at 7
least in my mind, that is the key difference between 8
an RTR and potential use of this in the commercial 9
world.
10 MR. NICHOL: All right. Great. Thanks, 11 Greg.
12 Scott, you have your hand up.
13 MEMBER PALMTAG: Sorry, I was unmuting.
14 You mentioned that these reactors can be 15 like research reactors. And I understand the source 16 term consequences, but what about security and 17 operators? I mean, even research reactors have a 18 large staff and they have security and, actually, 19 inspections, too. Can you give me an idea? Are these 20 supposed to be, are you thinking autonomous reactors 21 that are going to be sitting out there by themselves 22 or are these going to be fully staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day?
23 Or can you give me a comment?
24 MR. NICHOL: Yes. We do have a slide 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
95 later on about the staffing, but there are different 1
models. So, there are models with a minimal amount of 2
onsite staff, and then, there are models where you 3
have nobody permanently on staff at all times.
4 Those incorporate additional technologies 5
beyond even what research/test reactors do in terms of 6
automation, remote operations, and things like that.
7 So, I've got a slide later on that will have a little 8
bit more detail.
9 MEMBER PALMTAG: All right. Thank you.
10 MR. NICHOL: Yes.
11 All right. So, I want to talk a little 12 bit about this concept the NRC presented, which is 13 maximizing the standardization, and we're aligned with 14 that.
15 We developed what we're terming "the ReLic 16 process," or Rapid Efficient Repeatable Licensing.
17 And so, we started with, what does an application 18 today look like for a particular site? And now, this 19 is Part 50 or Part 52, and this is the combination.
20 If it's Part 50, both the construction permit and 21 operating license because that's the entirety of the 22 information; Part 53, COL and 103.g findings.
23 So, those are on the order of 6 to 10 24 thousand pages today. And we said, well, 5 to 10 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
96 thousand pages, that's eight-to 10-year deployments 1
for most reactors today. We're not going to be able 2
to get to the business model needs if we keep that 3
current paradigm. So, what could we do?
4 And we had a couple of constraints in 5
here. We wanted to make sure that we're not cutting 6
corners, or I should say, we're not encouraging the 7
NRC to cut corners. We want the NRC to fully review 8
these designs just as they would today or have in the 9
past, with all the rigor and all the scrutiny.
10 But what we want to do is recognize that, 11 if there is high standardization, then if the NRC were 12 doing that for every single site design, they're going 13 to be doing a lot of repetitive review of the exact 14 same information, and that's not efficient or really 15 necessary from a safety standpoint. So, how can we 16 move all that information that would be repetitive and 17 never changing, move it into that one-time review, so 18 that the NRC could reference it and not have to repeat 19 that review over and over again?
20 And there are a couple of different 21 methods. One is approving something based on range of 22 technologies. And the advanced nuclear reactor, I 23 guess it's the new Nuclear Generic Environmental 24 Impact Statement is an example of it. This could be 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
97 done through rulemaking. So, there's a large portion 1
of this that, by rules or general approvals, could be 2
addressed one time and not have to be repeated every 3
single time.
4 There is the approval with the design.
5 This would be the maximum ML or DC that the NRC talked 6
about.
7 There would be licensee pre-approval. So, 8
this could be the operational programs, the financial 9
qualifications, all the things that a licensee 10 owner/operator would need and they would do for site 11 after site after site. That could just be, you know, 12 done once and accepted over and over again.
13 And then, what that would leave is that 14 the site itself would have a very small portion. We 15 actually envision that this would be more of a 16 confirmation that the site parameters comply with all 17 of the requirements or licensee conditions established 18 from all those earlier. And so, the NRC review would 19 be more of a confirmation that the site conforms to 20 what they've already reviewed. The idea would be to 21 try to address all of the safety and environmental in 22 those first three blocks, so that the site doesn't 23 have new safety and environmental considerations, 24 because that helps to reduce the amount of time that's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
98 needed for that.
1 And we think that it's possible to get 2
down to applications of less than 100 pages. That's 3
not a requirement; that's just anticipation. So, it 4
may not be exactly like that, and we think that that 5
can get to six months.
6 Shown in a different, maybe a little bit 7
more illustrative way -- and I won't spend time on 8
this because I have some other slides -- but it just 9
shows how these different pieces would be put together 10 to create what's called the site parameter envelope.
11 And that site parameter envelope would be the basis 12 for the NRC to confirm, yes, this site is within the 13 bounds of everything we've already approved. Or if 14 the NRC comes back and says, "Well, this site is 15 outside of what we've already approved," well, then, 16 that site is going to have to do additional things and 17 they're likely not going to be able to get this 18 accelerated schedule that we're looking at here. So, 19 that's the concept.
20 And how you put those together? So, all 21 of that early work would be that purple box up there.
22 The NRC ML review happens years or many months ahead 23 of the first actual site deployments, and then, when 24 you get to the first or the later site deployments --
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99 that's the green; that's the green arrow coming down 1
-- that's when you get into, you know, more efficient, 2
expedited reviews.
3 I wanted to show two slides. So, this 4
slide is the schedule of what we would expect the NRC 5
review to look like today if they were to receive a 6
microreactor, based on the review schedule that they 7
did for the Kairos Hermes and some of their other 8
statements in terms of how long it might take things, 9
including the recent decision on mandatory hearing 10 schedules.
11 And so, you can see that's about 49 months 12 from when the site is selected, and this would be to 13 the NRC's 103.g finding. We actually think that, 14 after that finding, the applicant needs about a month 15 to fully deploy the reactor at that site. So, this 16 would be a lot longer than the six months.
17 You'll notice there's a lot of things. If 18 you split it down the middle, on the right side, these 19 are a lot of the NRC review process. And the NRC has 20 proposed making those more streamlined in their nth-21 of-a-kind paper, just as we had proposals on how those 22 could be streamlined.
23 But if you look at the left side, site 24 characteristics, 24 months, these are meteorological 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
100 towers. These are core borings and the SSHAC process.
1 And so, we need to recognize that that is a 2
limitation. Even though it is outside the NRC's 3
review scope, it does impact the schedule of 4
deployment. So, it does need to be considered as part 5
of this effort.
6 So, the schedule, this slide shows the 7
schedule that we think is possible if our proposal was 8
accepted and implemented. And again, a lot of our 9
ideas are similar to the NRC's. Just in the details 10 is where there's some differences, but sometimes the 11 differences matter.
12 And this could get to about five months, 13 and it would allow sufficient time for the NRC to 14 review the scope that would be part of that site 15 license. Because, again, most of the information has 16 already been reviewed and approved.
17 It would allow for public interactions.
18 Here, in our paper we actually propose an Atomic 19 Energy Act change to eliminate mandatory hearing, but 20 if the mandatory hearing was still there, as well as 21 the contested hearing opportunities.
22 And then, we put in here, you know, our 23 proposal envisioned that it would be possible for some 24 designs to fully address all of the environmental 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
101 issues before they get to the site license. This 1
would be, like, we might call it a microreactor 2
supplement to the new nuclear GEIS.
3 But if there were some remaining 4
environmental issues left, there would be just minor 5
impacts to the schedule.
6 Yes, Greg?
7 MEMBER HALNON: Yes, Marc, do you think 8
there's enough time for the local government to get 9
ready? I mean, I understand there's not a lot of 10 emergency response requirements from an evacuation 11 perspective, but there's the radiological preparation 12 of the annex for the all hazards plans. If this is a 13 brand-new site and a brand-new locale, I know you talk 14 about remote, but you're still going to have to have 15 some offsite preparation. Do you think this is enough 16 time?
17 MR. NICHOL: Well, I think, if I'm 18 understanding right on emergency preparedness -- I'm 19 not an expert -- but if they have site boundary EPZ, 20 they wouldn't have offsite preplanned activities.
21 They may have interactions with the state 22 environmental management agencies to talk about 23 potential coordination and that sort of thing.
24 You know, we would have to have those 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
102 discussions directly with each state. They're all 1
going to have their own opinions. But based on my 2
understanding of the technology and the consequences, 3
I think it is possible --
4 MEMBER HALNON: Okay.
5 MR. NICHOL: -- to be able to reach those 6
agreements.
7 MEMBER HALNON: Yes. I mean, you start to 8
have emergency response from the hospitals, EMS, fire 9
protection possibly, certainly law enforcement. So, 10 there's going to be some training required --
11 MR. NICHOL: Uh-hum.
12 MEMBER HALNON: -- some planning done.
13 And if the local town, or wherever this is going to be 14 supported, doesn't have that already in place, that 15 could be a challenge. But, yes, we would probably 16 need to talk through that and make sure we had enough 17 time to do the all hazards preparations.
18 MR. NICHOL: Uh-hum. Okay. Thanks.
19 Dennis?
20 MR. BLEY: Yes, I know in your document 21 you've considered the things we call external events 22
-- winds, high winds, and fires and floods and 23 earthquakes. What I don't know, especially since 24 we're talking about transportation vehicles becoming 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
103
-- you know, not everything going into a building 1
sometimes, but just being a package that you have 2
anchored to the ground somehow. Have there been any 3
real analyses of how that sort of system can withstand 4
those external events?
5 MR. NICHOL: So, nothing generic that I'm 6
aware of. I would imagine that each developer that is 7
designing a reactor of that type would be going 8
through their analyses now. And, of course, the NRC 9
is going to have requirements with performance metrics 10 associated that they're going to have to meet. So, 11 yes.
12 MR. BLEY: Okay. So, I think I heard you 13 say, no, it hasn't been, but people are starting to 14 analyze it now?
15 MR. NICHOL: That's my understanding, yes.
16 MR. BLEY: Okay.
17 MR. NICHOL: Ron?
18 MEMBER BALLINGER: Yes, this is Ron 19 Ballinger.
20 Apropos what Greg was saying and what's 21 been mentioned at least in passing a little while ago, 22 is there a possibility that this whole process can be 23 effectuated, if you will, by -- if you've got a 24 thousand of these things, a thousand divided by 48 or 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
104 50 gets to be a large number in each state. Can there 1
be, in effect, Agreement States up-front with respect 2
to the police and fire, and all that kind of thing, 3
that would happen prior to any deployment, where the 4
so-called Agreement State, for lack of a better word, 5
would already have all of that thought process and all 6
of that stuff in place?
7 MR. NICHOL: It's a good question. I 8
don't know the answer. We can go and take a look at 9
it. Or maybe at the end of the presentation, the NRC 10 might have a response for you.
11 MEMBER BALLINGER: I mean, there's some 12 reality that has to come in here. If there's a 13 thousand of these things, they're going to be popping 14 up on street corners.
15 MR. NICHOL: Yes. Well, yes, there will 16 be a lot. There will be a different way to consider 17 these. I wouldn't necessarily say, "street corners,"
18 but, yes, I get the point of your comment.
19 All right. This is the slide that, Scott, 20 I think you asked about staffing. I did want to 21 include this. In this presentation, I didn't get into 22 a lot of details on a lot of the topics. You can 23 imagine that that would take a long time. But I did 24 want to include this one because it was the one topic 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
105 that the NRC didn't address in their current paper 1
that we identified as a high need.
2 And it's really the onsite staffing. And 3
we know that the technologies and the business models 4
lend themselves toward fewer onsite operators. And in 5
our proposal, we identify or propose a systematic way 6
of going about identifying what would be the right 7
staffing.
8 So, while potential outcomes could be one 9
operator onsite or no operator onsite with a remote 10 operations center, it's not a guarantee. You would 11 have to follow the process.
12 That process would start by identifying 13 the required operator functions through an HFE or 14 other task analysis of the reactor and all the 15 operational controls that you have. Once you identify 16 the operator functions, then the developer could go 17 through and identify where automatic operations --
18 note that I'm not saying, "autonomous operations";
19 just automatic operations -- which the NRC has 20 approved in the past and are well-established and 21 utilized today.
22 So, automatic features of the plant, 23 including, you know, emergency shutdown and things 24 like that. So, which of those functions are addressed 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
106 through automatic operations, and then, the next layer 1
would be remote operates. What functions can be 2
adequately addressed by remote operations? And then, 3
anything that's left would be required to have local 4
human actions.
5 And so, some designs may be able to get 6
down to one onsite operator. That means that they 7
could have other duties onsite, obviously, if they're 8
an operator, but they wouldn't have to be at the 9
controls all the time. But they would have to be near 10 enough to be able to check on it periodically or 11 respond if there was an alert. But they could be 12 doing other functions. And then, you know, there's no 13 onsite. There would be remote operations and things 14 like that.
15 Much longer term -- it's not really a 16 proposal in our paper; we just identify it as a 17 potential future consideration -- is that you may have 18 no operators at all with autonomous operations. I 19 would say it's so far into the future, it's really 20 aspirational, but we included it, so that autonomous 21 features, the NRC is starting to think about them and 22 how they could be applied in the future, was why we 23 included it.
24 Dennis?
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107 MR. BLEY: Just an opinion for you.
1 Concept No. 1, I can see.
2 Concept No. 3, with more thought, for some 3
designs where the physics and chemistry help you out, 4
I can almost see how that happens.
5 Concept No. 2 with remote operations is 6
one I just don't see how we ever buy into, because I 7
don't know of any communications link that hasn't 8
failed in memory.
9 MR. NICHOL: Oh, okay.
10 MR. BLEY: That one just seems like it's 11 a way to end up in real trouble with overconfidence.
12 MR. NICHOL: Yes, thanks. That's a good 13 point, and we did think a lot about that. We proposed 14 some concepts on what performance criteria would be 15 there. Certainly, a lot of work will be needed to 16 develop the performance criteria. But some of them 17 could be that, if you had the link broken with a 18 remote operations center, the plant would be able to 19 shut itself down safely.
20 The concept of operations included having 21 field operators that would visit sites periodically 22 and not be too far away from a site. So, you might 23 have a requirement for a response time. So, the plant 24 would shut itself down immediately. Somebody would be 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
108 able to respond within a certain amount of time that 1
the NRC determined safe.
2 An additional layer of defense, if it were 3
needed, is that we also framed as being located next 4
to industrial facilities. So, if you were able to 5
take credit for somebody at the industrial facility to 6
be able to go to the plant immediately, so there was 7
a faster response time, even though they're not a 8
licensed operator, but, you know, those sorts of 9
things.
10 And then, of course, I should have 11 mentioned at the beginning, this would really be 12 primarily for reactors that have such low consequences 13 that offsite doses would really be really negligible.
14 So, yes, a lot of work is going to be needed on that, 15 is the point. So, I appreciate that, that comment.
16 Scott?
17 Scott, if you're speaking, you're on mute.
18 MEMBER PALMTAG: Oh, sorry.
19 So, this is a good slide on staffing, but 20 I don't see anything about security here. That's one 21 of my concerns, is you're going to have these reactors 22 sitting there with no security, terrorism, that sort 23 of thing. Have you put any thought into how you would 24 handle that?
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109 MR. NICHOL: Yes, we did. And so, 1
security is, obviously, is part of staffing, but it 2
also has its own separate considerations. And we have 3
a proposal in there for security.
4 For, I would say, the far extreme of the 5
spectrum where you would have the most benefits, we 6
actually leaned into some ideas that the NRC had 7
proposed in Part 53 where these microreactors, if they 8
meet certain conditions, they would not have to 9
protect against the design basis threat because, 10 essentially, it would be determined that the design 11 basis threat couldn't cause any consequences of 12 concern to the public. And that would be similar to 13 how research and test reactors are treated.
14 MEMBER PALMTAG: All right. I just had a 15 followup question. This is really more of a comment 16 about the six-month time line that you're proposing, 17 and this kind of follows up on what Ron Ballinger was 18 saying.
19 I understand why you're asking for six 20 months. I just really question how realistic that is.
21 If I was a large state and someone wanted to come in 22 with -- a large state with, say, oil operations -- if 23 someone wanted to come in and put 100 reactors 24 scattered around, I would think the states would have 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
110 some pushback on that.
1 I just find it hard to believe you're 2
going to be able to identify a site and put a reactor 3
there in six months. And why this is a concern is 4
you're actually putting quite a bit of burden on the 5
NRC to come up with some way of licensing in six 6
months. This really isn't a realistic time frame. It 7
just seems like an unneeded burden on the NRC.
8 That's more of a comment, just something 9
to think about. Maybe come up with a more realistic 10 time line -- maybe a year, nine months, something like 11 that.
12 MR. NICHOL: All right. Yes, I appreciate 13 it.
14 I know that we can certainly work on the 15 state role and how long it would takes the states. I 16 do think that there could be areas where there would 17 be such large volume of deployments -- let's just take 18 the Permian Basin as an example, because we know that 19 that area wants a lot of microreactors. The states 20 could act to do, I would just say, generic approvals 21 for a large number of microreactors that would, then, 22 be supportive of a six-month schedule. So, we can 23 develop that, so that it's more clear on how it would 24 work.
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111 The other comment I'd make is that our 1
proposals in terms of the six-month schedule is not 2
too far off from what the NRC had in their NOAK paper.
3 I know they had, roughly, a 200- to 500-day schedule.
4 And so, if we just look at 200, that's longer than 120 5
days that we are proposing.
6 But if you also look at the NRC's 7
schedule, they have the construction permit and 8
operating license in series, and we have put them in 9
parallel, which we think the NRC could do. So, if you 10 take the NRC's NOAK paper, put them in parallel, I 11 think you get very close to what we're doing.
12 So, I do note and agree we don't want to 13 ask the NRC to expend resources unnecessarily for 14 anything unrealistic, but I think those two points 15 would be why I think it would still be appropriate for 16 the NRC to consider.
17 CHAIR BIER: Yes.
18 Greg, I see you have your hand up, but can 19 we make this quick, so we make sure to save a few 20 minutes for public comment, and hopefully, Committee 21 discussion?
22 MEMBER HALNON: Yes, it's just two 23 comments -- one on the security aspect of it. Just 24 because it's not on this slide doesn't mean that they 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
112 won't have asset preservation security or industrial 1
security at these places, which goes to that there 2
will be some level of security by these industrial 3
folks.
4 The other thing is, remote operations is 5
not uncommon in the industry for complex plants. So, 6
there's a lot of lessons learned from the gas-bottling 7
plants and other things that are four or five plants 8
operated by one operator, and then, they quickly shut 9
down and dispatch on any problem. So, it's not a new 10 concept in industry, maybe for nuclear. So, there's 11 a lot of lessons out there.
12 So, that's my only comments.
13 CHAIR BIER: Okay. If I can bring this 14 presentation to a close, I appreciate the information.
15 MR. NICHOL: Thank you.
16 CHAIR BIER: We're always interested in 17 learning about that. But I think now I'm going to 18 turn to public comments. Thank you.
19 So I know Joy had a comment earlier. I 20 don't know if she's still on the call.
21 Are there any other public comments?
22 And anybody who wishes to provide a 23 comment after the fact can, of course, get in touch 24 with Derek Widmayer, the Designated Official, after 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
113 the fact, just to provide comments in writing.
1 Okay. If there are no public comments at 2
this time, then I guess we can turn to Subcommittee 3
discussion. And I think the main question for the 4
Subcommittee is just, is there any perception that we 5
really should be writing a letter on this topic at 6
this time?
7 MEMBER HALNON: Vicki, this is Greg.
8 I think, in my opinion, it's a little bit 9
premature to write a letter on the draft documents.
10 I think the alignment between industry and the NRC is 11 fairly strong, but it needs to be worked out, a little 12 bit more time on some of these issues. I didn't hear 13 anything today that caused me to sit back and say, you 14 know, any red flags from the standpoint that we need 15 to make a point of.
16 But I do think that we're going to need 17 more frequent discussions at a Subcommittee level for 18 this coming year. So, I would suggest that we have 19 several meetings as milestones are reached and before 20 new SECY papers are written, and whatnot.
21 So, I think at this point it would be 22 premature to write a letter.
23 CHAIR BIER: That fits my opinion and my 24 earlier observation, that I'm not sure the choice of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
114 options at this stage has any safety implications.
1 Other Subcommittee comments?
2 MEMBER BALLINGER: Yes, this is Ron 3
Ballinger.
4 I was pondering the last slide and what 5
Dennis was saying about no operators remote, that kind 6
of thing. And I wonder if the NEI folks should talk 7
with the people doing this space-reactor-related 8
stuff. Because they're developing techniques to 9
interrogate in real time safety-related issues to 10 reactors that are definitely remote -- they're 200 11 million miles away -- and based on that interrogation, 12 be able to put the system in a safe condition.
13 So, there's a lot of work that has been 14 going on, I think, in that area that might bear on the 15 truly remote microreactors.
16 CHAIR BIER: That's a good suggestion.
17 Following up on Greg's comment, it seems 18 to me that the issues where ACRS review would be the 19 most crucial -- not necessarily the only ones -- but 20 the most important ones are anything that would 21 involve a
waiver or relaxation of current 22 requirements. So, places looking at, again, reduced 23 staffing or reduced emergency response requirements, 24 et cetera, at that level, we would certainly want to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
115 be weighing-in. But I think at the procedural level 1
of how these things are handled, most likely, no 2
letter is needed at this time.
3 Any further Subcommittee comments or 4
discussion?
5 Hearing
- None, since we were all 6
represented here today, I don't think we need to 7
repeat this briefing in full Committee week. So, 8
staff can maybe get a little bit of time off that 9
week.
10 MEMBER PETTI: Oh, Vicki? Vicki?
11 CHAIR BIER: Yes?
12 MEMBER PETTI: This is Dave. Walt was not 13 here.
14 CHAIR BIER: Oh, good point. Thank you.
15 MEMBER PETTI: Well, I think at an 16 abbreviated --
17 CHAIR BIER: Yes.
18 MEMBER PETTI: -- high level, because Walt 19 has some strong feelings on microreactors, I think.
20 And so, I think it would be worth the staff and NEI to 21 hear, you know, to give him a chance to ask some 22 questions.
23 CHAIR BIER: That's a good point. It's an 24 excellent observation.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
116 And, Derek, I guess you can deal with the 1
scheduling. It sounds like maybe two hours total, 2
counting discussion, is probably adequate or more than 3
adequate for that.
4 Any other thoughts?
5 MR. BURKHART: Yes. So, Vicki?
6 CHAIR BIER: Yes?
7 MR. BURKHART: Vicki, this is Larry.
8 CHAIR BIER: Yes?
9 MR. BURKHART: Just to let you know that 10 the FRN -- this is Larry Burkhart from the ACRS 11 staff --
12 CHAIR BIER: Yes.
13 MR. BURKHART: -- the FRN has been 14 published for the full Committee meeting in November -
15 16 CHAIR BIER: Got it.
17 MR. BURKHART: -- and this is the first 18 topic on that Wednesday. And we do have two hours for 19 presentation.
20 CHAIR BIER: Perfect.
21 MR. BURKHART: We don't have to use two 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />.
23 CHAIR BIER: Yes.
24 MR. BURKHART: And we have an hour for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
117 deliberations.
1 CHAIR BIER: Excellent.
2 MR. BURKHART: So, there is some time set 3
aside for that, yes.
4 CHAIR BIER: Great. I appreciate that 5
information.
6 And as people have said, I mean, the lack 7
of writing a letter does not reflect any lack of 8
importance or interest in the topic. It's, obviously, 9
a crucial topic for the industry and the agency going 10 forward.
11 And we appreciate all the information 12 today and look forward to staying informed in the 13 future.
14 So, if there are no further comments at 15 this time, then, I will go ahead and adjourn this 16 Subcommittee meeting. Thank you all.
17 (Whereupon, the above-entitled matter went 18 off the record at 12:55 p.m.)
19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
7+671:67(
- $6+,1*721'&
www.nealrgross.com C E R T I F I C A T E This is to certify that the foregoing transcript In the matter of:
Before:
Date:
Place:
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Court Reporter 119 ACRS Regulatory Policies and Practices Subcommittee U.S. NRC 10-17-24 teleconference
©2024 Nuclear Energy Institute Rapid High-Volume Deployable Reactors for Remote Applications ACRS Subcommittee Meeting October 17, 2024 Marc Nichol, Executive Director New Nuclear
©2024 Nuclear Energy Institute 2 Status and Whats New 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)
Whats 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 ADVANCE Act Section 208-Regulatory Framework for Micro-Reactors Scope of effort Clarify regulatory needs for rapid and cost effective large-scale deployments Resolve expanded scope of regulatory issues and propose solutions
©2024 Nuclear Energy Institute 3 Micro-Reactor Topics Previously Identified NEI 2019 Paper NRC SECY 20-0093 Review Scope and Effort X
Regulatory Oversight X
X Physical Security X
X Aircraft Impact Assessment X
X Staffing and Training X
Annual Fee X
Manufacturing License Scope X
NEI 2021 Paper NRC SECY 24-0008 Factory Fabricated X
X Factory Fuel Load (Preclude criticality)
X X
Factory Operational Testing X
X Timing Authorize to Operate (Hearing & ITAAC)
Enclosure Replacement at Site X
Enclosure General License X
Fueled Transport Enclosure Storage of Used Fuel Enclosure Decommissioning Enclosure Maritime Applications Enclosure Space Applications Enclosure Commercial Mobile Enclosure NEI 2019 Paper NRC SECY 20-0093 NEI 2022 Paper NRC SECY 24-0008 Autonomous & Remote Ops X
X Enclosure Dense Populations Sites X
Enclosure 22 Topics; 16 are part of the 31 Topics in the NEI RHDRA Proposal
©2024 Nuclear Energy Institute 4 RHDRA Regulatory Topics and Priorities NEI Paper July 31, 2024 (ML24213A337)
Near-Term Urgent Resolution Longer-Term Resolution High Priority 1 - Environmental Reviews 2 - Standardized Design Approvals 5 - Site License 10 - Meteorology and Weather Data 11 - Geologic and Geotechnical 14 - Operations Staffing 19 - Physical Security 3 - Construction Authorization Upon Docketing 6 - Contested Hearing 7 - Mandatory Hearing 17 - Remote Operations 21 - AA/FFD Medium to Low Priority 9 - AIA 13 - Fire Brigade 16 - Remote Monitoring 18 - Cyber Security 22 - Radiation Protection 23 - Oversight 25 - Use of Contractors by ML 28 - Features to Preclude Criticality 31 - Used Fuel 4 - ITAAC 8 - Licensing fees 12 - Other External Hazards 15 - Autonomous Operations 20 - Emergency Preparedness 24 - Annual Fees 26 - Loading Fuel at Factory 27 - Testing at the Factory 29 - Transport Modules to Site 30 - Replace Modules at Site Topics addressed in NRCs October 2024 NOAK White Paper
©2024 Nuclear Energy Institute 5 Adapting the Regulatory Framework to Address New Technologies and Applications Design Features
- Physically small and simple
- Low risks and consequences
- Small footprint - land and environmental
- Safety relatively insensitive to site conditions
- Factory construction
- Site assembly
- May load fuel at factory and ship fueled
- Fully replaceable modules Applications and Use Cases
- Remote locations and micro-grids
- Industrial applications (heat and power)
- Not near population centers
- Large volume of deployments
- Deployment in months not years
- No disproportionate regulatory costs
- Limited or no on-site fuel movements
- Limited time of used fuel on-site Alternative Regulatory Approaches
- Incentivize safety enhancements
- Avoid undue regulatory burden
- Leverage use of manufacturing license or design certification
- Technology-inclusive, performance-based and risk-informed
- Oversight scaled to the safety profile
- More similar to research and test reactors
©2024 Nuclear Energy Institute 6 Relative Comparison of Potential Consequences from Selected Nuclear Technologies
©2024 Nuclear Energy Institute 7 A Different Imperative Yields Different Results Work on the Margins of Large LWR Approaches RTR Apply and Adapt Non-Power Approaches Innovation -> Revolutionary Change New technologies Question past/current practices Avoid weve always done it that way Understand bases for current approaches (characteristics of technologies and assumptions)
Question whether bases are still valid, if not form new bases and new approaches Current Efforts RHDRA Proposal LLWR vs RTR vs RHDRA Same Dose Limits Same Normal/Accident Requirements RTR = Low potential consequences EPZ = 10 miles vs small site boundary Different Implementation Guidance Different Security (RTR = No DBT)
RTR = No AIA RTR = Combined CP/OL is OK RTR = USGS/NOAA data is OK RTR = No min ops staff
Rapid Efficient Repeatable Licensing (ReLic)
Current Site Licensing (Part 50 CP + OL)
(Part 52 COL + 103.g Finding)
Approved with Design (e.g., ML, DC, SDA)
Approved for Range of Technologies (e.g., GEIS, Rulemaking)
Licensee Pre-Approvals (e.g., TR)
Site Site Applications of <100 pages Enable Deployments of <6 months Site Applications of 6,000 to 10,000 pages Enable Deployments 8 to 10 years
©2024 Nuclear Energy Institute 9 Potential to Minimize Scope of Site-Specific Review Traditional COL or CP/OL Scope Rulemakings (Not Design or Site Dependent)
ANR GEIS (100 issues)
GEIS Micro Supplement (21 issues)
General Approvals (Specific to a Design)
Part 52 ML or DCD Part 70 Fueled Micro Reactor Seismic Isolators Site Parameter Envelope General Site Approvals General Licensee Approvals (e.g., Programs, Financial Qual)
Site #1 (Confirm site conditions within SPE)
Site #N (Confirm site conditions within SPE)
ITAAC (Closed at Factory)
- Site Specific Approval*
©2024 Nuclear Energy Institute 10 NRC Approval of the Design and Site T - 60+ Months->
T - 24 Months->
T - 18 Months->
T - 12 Months->
T - 6 Months->
T = 0->
Site Approval
<-Application->
Submitted NRC ML Review NRC Approval NRC Review 2 Months Manufacturing License Approved Facilities for Fabrication Operational Manufacturing License Application Submitted Duration Dependent upon Scope of Novel Approaches and Site Issues Addressed 2025 2030 Contingency for 1st (Additional NRC Review) 6 Months Design Approval
©2024 Nuclear Energy Institute 11 Y1H1 Y1H2 Y2H1 Y2H2 Y3H1 Y3H2 Y4H1 Y4H2 Site Selected Site Characterization (24 Months)
Figure 4-1: NRC Current Licensing Timeline (Expectations for NOAK RHDRA)
Accept COL Approval Submit Application Final SER (4 Months)
Draft SER (8 Months)
Final EA (4 Months)
Draft EA (8 Months)
Decision on Contentions (200 Days)
Decision on New Contentions (85 Days)
Mandatory Hearing (2 Months)
Commission Decision (45 Days)
Safety & Enviro.
Complete 49 Months ITAAC Review (90 Days)
Hearings (90 Days) 103(g) Finding Operations AEA 180 Day ITAAC Notice
©2024 Nuclear Energy Institute 12 Month 1 Month 2 Month 3 Month 4 Month 5 Month 6 Month 7 Month 8 Month 9 Site Selected Figure 4-2: NRC Licensing Timeline (Expectations for ReLic Process)
Accept Application CP/OL Approval Submit Application Final SER (15 Days)
Draft SER (45 Days)
Final EA (15 Days)
Draft EA (45 Days)
Comments/Contentions/Petitions (30 Days)
Decision on Contentions (30 Days - End if No Hearing Granted)
Mandatory Hearing - If Necessary (30 Days)
Commission Decision (30 Days)
Safety & Enviro. Complete 5 Months Site Characterization (1 Month)
Responses and Replies (30 Days)
Decision on New Contentions (60 Days)
If EA Necessary CP/OL Approval (6 Months with EA)
Issue FRN for Contested Hearing
©2024 Nuclear Energy Institute 13 On-Site Staffing Design (inherent safety features, active safety components, and technology) with functional analysis
Determines if/what role is need for human action.
Sites Concept of Operations:
- 1. One (1) on-site operator Automatic operations Away from controls/other duties Remote Monitoring Optional
- 2. No (0) on-site staff, Remote Operator Automatic and Remote Operations
- 3. No Operators - Longer-term Autonomous operations No human action, high-level oversight only (Not needed but included)
Remote Operations Automatic Operations Local Human Actions Design-Required Operator Functions
QUESTIONS?
By Third Way, GENSLER
Backup Slides
Table 2-2: Summary and Functional Grouping of Specific Issue Topics Topic Area Priority AR RTR GL AEA Reg/Pol Group 1 (Licensing Process)
- 1) Generically Resolved Environmental Considerations High Applicable Non-App Benefit Option Need
- 2) Design Approval Scope and Authorizations High Applicable Non-App Benefit Option Need
- 3) Construction Authorization Upon Docketing High Applicable Non-App Benefit Option Need
- 4) Inspections, Tests, Analyses and Acceptance Criteria Medium Applicable Non-App Benefit Option Need
- 5) Site License Scope and Purpose High Applicable Applicable Benefit Option Need
- 6) Streamlined Contested Hearing High Applicable Non-App Benefit Option Need
- 7) Elimination of Mandatory Hearing High Applicable Non-App Benefit Solution Need
- 8) Licensing Review Resources and Costs Medium Non-App Non-App Benefit Option No-Need Group 2 (Concept of Deployment)
- 9) Aircraft Impact Considerations Medium Non-App Applicable No-Benefit Option Need
- 10) Meteorology and Weather Data High Applicable Applicable No-Benefit Option No-Need
- 11) Geologic and Geotechnical High Applicable Applicable Benefit Option Need
- 12) Other External Hazards Low Non-App Non-App No-Benefit No-Need No-Need Group 3 (Concept of Operations)
- 13) Fire Brigade Medium Applicable Non-App No-Benefit No-Need No-Need
- 14) Operations Staffing High Applicable Applicable No-Benefit Option Need
- 15) Autonomous Operations Medium Applicable Non-App No-Benefit Option Need
- 16) Remote monitoring Low Applicable Non-App No-Benefit Option No-Need
Table 2-2: Summary and Functional Grouping of Specific Issue Topics (contd)
Topic Area Priority AR RTR GL AEA Reg/Pol Group 3 (Concept of Operations) - Continued
- 17) Remote operations Medium Applicable Non-App No-Benefit Option Need
- 18) Cyber security Low Applicable Non-App No-Benefit Option Need
- 19) Physical Security High Applicable Applicable No-Benefit Option Need
- 20) Emergency preparedness Low Applicable Applicable No-Benefit Option No-Need
- 21) FFD/Access Authorization Medium Applicable Applicable No-Benefit Option Need
- 22) Radiation Protection Medium Applicable Applicable No-Benefit Option No-Need
- 23) NRC Oversight Medium Applicable Applicable Benefit No-Need Need
- 24) Annual Fees Medium Non-App Applicable No-Benefit Option Need Group 4 (Total Lifecycle)
- 25) Use of Contractors By Manufacturing Licensees Medium Applicable Non-App Benefit No-Need Need
- 26) Loading Fuel at Factory Medium Non-App Non-App Benefit No-Need No-Need
- 27) Testing at the Factory Medium Non-App Applicable Benefit No-Need Need
- 28) Features to Preclude Criticality Medium Non-App Non-App Benefit No-Need No-Need
- 29) Transport of Fueled Reactor Medium Non-App Non-App Benefit No-Need Need
- 30) Replace Modules at Site Medium Non-App Non-App Benefit No-Need No-Need
- 31) Storing Used Fuel at Site Medium Applicable Non-App No-Benefit Option Need
Licensing and Deployment Considerations for Nth-of-a-Kind Micro-Reactors Advisory Committee on Reactor Safeguards October 17, 2024 Steve Lynch, Chief, Advanced Reactor Policy Branch William Kennedy, Sr. Project Manager, Advanced Reactor Policy Branch Jackie Harvey, Sr. Project Manager, Advanced Reactor Policy Branch https://www.nrc.gov/reactors/new-reactors/advanced.html
Opening Remarks and Introduction 2
Contents Motivation for the paper
Background
Conceptual deployment model for transportable micro-reactors Licensing strategy for Nth-of-a-Kind (NOAK) micro-reactors Options for standardization of operational programs Other topics related to NOAK micro-reactor licensing and deployment
- Maximal design standardization
- Graded approach to site characterization
- Deployment site emergency preparedness
- Streamlined licensing process
- Construction inspection Stakeholder engagement Next steps 3
Motivation for this Paper
- Stakeholders have expressed interest in rapid, widespread deployment of micro-reactors of a standard design on timeframes that are significantly shorter than current licensing timeframes.
- The NRC staff is currently in pre-application engagements with micro-reactor developers that are considering a wide range of deployment models with novel aspects such as standardization of operational programs and alternative site characterization.
- The NRC staff is prioritizing development of strategies to provide for the predictable and efficient licensing and regulation of these designs and operational models, and the identification and resolution of associated policy issues.
4
=
Background===
- For licensing purposes, micro-reactors are commercial power reactors licensed under Section 103 of the Atomic Energy Act of 1954, as amended (AEA).
- Micro-reactors typically use non-light-water reactor technologies, are anticipated to have power levels on the order of several tens of megawatts thermal, small site footprints, low potential consequences in terms of radiological releases, and may have increased reliance on passive systems and inherent characteristics to control power and heat removal.
- Factory-fabricated transportable micro-reactors are a subset of micro-reactors that would rely heavily on standardization and mass production to simplify licensing and deployment.*
5
- See SECY-24-0008, Micro-Reactor Licensing and Deployment Considerations: Fuel Loading and Operational Testing at a Factory, dated January 24, 2024 (ML23207A252).
=
Background===
- For the purposes of this presentation, the term NOAK micro-reactor generally means a micro-reactor of a standard design that has been previously approved by the NRC through a design certification (DC), manufacturing license (ML), or final safety analysis report for a first-of-a-kind (FOAK) combined license (COL) or construction permit and operating license (CP/OL).
- NOAK micro-reactor licensing refers to licensing micro-reactors of a standard design for operation as power reactors at fixed sites.
6
Conceptual Deployment Model for Transportable Micro-Reactors 7
NRC Staff Draft White Paper
- Describes regulatory approaches the NRC staff is developing for consideration by the Commission related to two topics:
1.
Approval of standardized operational programs 2.
Alternative approaches for environmental reviews*
- Includes Enclosure 3 with information on other topics related to licensing and deployment of NOAK micro-reactors
- The draft white paper and enclosures are available at:
Draft White Paper on Nth-of-a-Kind Micro-Reactor Licensing and Deployment Considerations (ML24268A310)
Draft White Paper on Nth-of-a-Kind Micro-Reactor Licensing and Deployment Considerations - Enclosure 1 (ML24268A314)
Standardization of Operational Programs for Nth-of-a-Kind Micro-Reactors Draft White Paper on Nth-of-a-Kind Micro-Reactor Licensing and Deployment Considerations - Enclosure 3 (ML24268A317)
Technical, Licensing, and Policy Considerations for Nth-of-a-Kind Micro-Reactors 8
- Environmental reviews are not within the scope of this meeting but are mentioned here for completeness. Enclosure 2 will discuss in detail approaches for environmental reviews.
Anticipated Licensing Strategy
- Phase 1: Robust upfront approval of a standard design
- Approval of a maximally standardized design in a DC, ML, COL, or CP/OL
- Approval of standardized operational programs, to the extent practicable
- Completion of a generic environmental review, to the extent practicable*
- Completion of hearings covering the standard design
- Timeframes will vary based on the licensing pathway and reactor design and are bounded by the generic milestone schedules established by the NRC in response to the Nuclear Energy Innovation and Modernization Act of 2019 (NEIMA).
9
- Environmental reviews are not within the scope of this meeting but are mentioned here for completeness.
Anticipated Licensing Strategy
- Phase 2: NOAK licensing leveraging the upfront approvals
- Streamlined administrative processes
- NRC staff safety and security* reviews focusing on confirmation of site suitability
- NRC staff site-specific environmental review that applies the upfront generic environmental review, as appropriate*
- Confirmatory inspections at the place of fabrication and deployment site, as appropriate
- Verification of completion of inspections, tests, analyses and acceptance criteria (ITAAC) for a COL or confirmation of compliance with license conditions for a CP/OL and conduct of readiness for operation inspections
- Completion of site-specific hearings 10
- Security and environmental reviews are not within the scope of this meeting but are mentioned here for completeness.
- Current Commission policy does not support review and approval of the operational requirements (i.e., parts or aspects of operational programs) in the context of DC or ML application review beyond those that are material to the finding on the safety of the design.
Advanced Boiling Water Reactor (Volume 62 of the FR, page 25806 (62 FR 25806)) discusses that the operational requirements were not accorded finality because the operational matters were not comprehensively reviewed and finalized for the DC.
- The NRC staff anticipates that most operational programs for a specific micro-reactor design could be standardized by an applicant for a DC or ML to support NRC review and approval.
- This would support a streamlined review of a COL or CP/OL application that referenced the approved operational programs.
11 Regulatory Approaches for Review of Standardized Operational Programs
- The NRC staff is exploring approaches to review operational matters at the design approval stage (ML or DC) for a standard micro-reactor design Option 1 (O1): Status quo Currently staff can review and approve operational programs through topical reports or the design-centered review approach Option 2 (O2): Review and approval of operational programs proposed in a DC or ML application An applicant would have the option to provide proposed measures to satisfy operational programs as part of a DC or ML application Assuming the proposed measures are fully described and constitute an essentially complete program such that staff could make a safety finding, and that the staff comprehensively reviewed the proposed measures, this would provide additional regulatory stability for those programs when referenced by COL or CP/OL applicants 12 Regulatory Approaches for Review of Standardized Operational Programs
Maximal Design Standardization The regulations in 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants, provide several regulatory pathways for design standardization, including manufacturing licenses, design certifications, and standard design approvals, under which most safety issues would be resolved.
Maximal standardization would involve approval of a standardized micro-reactor design and subsequent deployment under a COL or CP/OL without any significant departures from the standardized design.
Maximal design standardization could allow micro-reactors of a standard design to be deployed to most sites in the U.S. with minimal need for site-specific features or the associated additional NRC reviews and approvals.
13
Grading the Level of Site Characterization A standardized design for a micro-reactor could establish bounding parameters for site characteristics that are important to the safety review so that micro-reactors of the standard design could be deployed at suitable sites throughout most of the U.S.
The NRC staff is considering approaches for grading the level of site characterization for micro-reactors of a standard design (and potentially other reactors) based on the applicable hazards for the specific micro-reactor design, the amount of margin included in the design for each bounding site parameter, and the amount of margin to appropriate dose reference values.
A graded approach could focus on how a construction permit or combined license applicant can provide the required site characterization information and demonstrate that the bounding parameters are met for the candidate site.
14
Deployment Site Emergency Preparedness The existing regulations for emergency preparedness in 10 CFR Part 50, Domestic licensing of production and utilization facilities, and 10 CFR Part 52 apply to licensing micro-reactors of a common design.
The NRC staff is exploring approaches for streamlining the review of emergency preparedness for licensing NOAK micro-reactors based on considerations such as the possibility that potential accidents would result in low doses at the site boundary and, under certain circumstances, might not require extensive off-site response.
15
Streamlined Processing of License Applications and Licensing Documents Licensing applications referencing an approved micro-reactor design that leverages maximal design standardization will likely be nearly identical, with some possible minor variations related to licensee-specific or site-specific information.
NRC-generated licensing documents, such as the NRC staff safety evaluation, license, and required Federal Register notices, will likely be very similar for licensing each individual micro-reactor of a standard design.
The NRC staff is considering approaches for using electronic licensing forms, licensing document templates, and automation to streamline processing and review of micro-reactor applications to reduce the timeframes for acceptance review, docketing, safety review, concurrence, license issuance, and other steps.
16
Micro-reactors of a common design might be self-contained in that they would be almost entirely fabricated at a factory and require minimal site preparation or construction activities at the deployment site, or they might consist of a core module that is fabricated in a factory and then incorporated into or connected to permanent structures and systems constructed at the deployment site, such as a reactor building and power conversion equipment.
In either case, it will be necessary for the NRC staff to verify completion of ITAAC in support of a finding for authorization to operate under 10 CFR 52.103(g) or to verify substantial completion of construction for issuance of an operating license under 10 CFR 50.56 and 50.57(a)(1).
As discussed in SECY-23-0048*, the NRC staff is considering approaches for risk-informed and performance-based inspections at both the fabrication facility and deployment site that can be completed within the expected timeframes for licensing and deployment of NOAK micro-reactors.
17 Construction Inspection
- SECY-23-0048, "Vision for the Nuclear Regulatory Commission's Advanced Reactor Construction Oversight Program" (ML23061A086)
Stakeholder Engagement
- Public advanced reactor stakeholder meetings in December 2023 and March and July 2024
- Favorable feedback from stakeholders on the scope of the paper and the options developed by staff
- Anticipated engagement on guidance for implementation of Commission direction
- Public meetings with various micro-reactor developers and stakeholders
- Nuclear Energy Institute (NEI) proposal paper, Regulations of Rapid High-Volume Deployable Reactors in Remote Applications (RHDRA) and Other Advanced Reactors (ML24213A337) dated July 31, 2024
- Planned public meeting in early November 2024, on the NRC staffs draft white paper 18
Next Steps
- Develop a Commission paper on NOAK micro-reactor licensing and deployment considerations:
- Request Commission direction on regulatory approaches for standardizing operational programs
- Request Commission direction on options for alternative environmental reviews*
- Provide information on other topics related to NOAK micro-reactor licensing 19
- Environmental reviews are not within the scope of this meeting but are mentioned here for completeness.