ML24305A288
| ML24305A288 | |
| Person / Time | |
|---|---|
| Site: | Abilene Christian University |
| Issue date: | 10/31/2024 |
| From: | Towell R Abilene Christian University (ACU), Nuclear Energy eXperimental Testing Lab |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| Download: ML24305A288 (1) | |
Text
Finding global solutions to the worlds most critical needs.
Abilene Christian University Nuclear Energy eXperimental Testing Lab ACU Box 28208, Abilene, Texas 79699-8208 acunextlab.org October 31, 2024 Docket No. 50-610 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 205550001
Subject:
Abilene Christian University Molten Salt Research Reactor Regulatory Engagement Plan, Revision 2 Abilene Christian University submitted regulatory engagement plans for the Molten Salt Research Reactor (MSRR) in July 2020 (ML20241A071), May 2022 (ML22157A033), and January 2024 (ML24027A002). The previous engagement plans included descriptions of the MSRR and plans for submission of a construction permit application. The enclosed Revision 2 includes plans for pre-application activities and submission of an operating license application for the MSRR. The engagement plan identifies anticipated licensing submittals and is intended to aid Nuclear Regulatory Commission resource and schedule planning.
This letter and the enclosed engagement plan contain no commitments. The engagement plan does not contain any proprietary or commercially sensitive information and does not need to be withheld from public disclosure in accordance with 10 CFR 2.390. If you have questions or need additional information, please contact Benjamin Beasley at Benjamin.Beasley@acu.edu or Lester Towell at Lester.Towell@acu.edu.
Respectfully, Rusty Towell, PhD Director of NEXT Lab
Enclosure:
Regulatory Engagement Plan, Revision 2 Cc:
John Segala, Chief, NRR Advanced Reactor Licensing Branch 2 Richard Rivera, Project Manager, NRR Advanced Reactor Licensing Branch 2 Edward Helvenston, Project Manager, NRR Non-Power Production and Utilization Facility Licensing Branch Brian Bettes, Project Manager, NRR Advanced Reactor Licensing Branch 2
Enclosure Regulatory Engagement Plan Abilene Christian University Molten Salt Research Reactor Revision 2 October 2024 Prepared by:
Abilene Christian University Nuclear Energy eXperimental Testing Lab ACU Box 28208 Abilene, TX 79699-8208
Regulatory Engagement Plan for Abilene Christian Universitys Molten Salt Research Reactor Revision 2 Date Published: October 2024
Title:
Regulatory Engagement Plan Revision Number: 2 Approved By: Rusty Towell, Director Signature:
Regulatory Engagement Plan, Rev. 2 REVISION HISTORY Rev Date Reason for Revision 7/24/2020 Pre-application phase 0
5/31/2022 Construction permit activities 1
1/26/2024 Update of construction permit activities and added plans for the operating license application 2
10/31/2024 Removed construction permit activities and updated plans and schedule for the operating license application
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Contents Section Title Page 1
LICENSING HISTORY AND STATUS................................................................. 1 2
FACILITY DESCRIPTION.................................................................................... 1 2.1 Abilene Christian University................................................................................. 1 2.2 Purpose and Intended Use of the Reactor........................................................... 1 2.3 Regulatory Application Type................................................................................ 2 2.4 Geographical Location of the Site........................................................................ 3 3
REACTOR DESCRIPTION.................................................................................. 3 3.1 General Description of the MSRR........................................................................ 3 3.2 Safety Features/Functional Characteristics of the MSRR..................................... 3 4
CONSTRUCTION ACTIVITIES............................................................................ 5 5
OPERATING LICENSE ACTIVITIES................................................................... 6 5.1 Pre-application Activities...................................................................................... 6 5.2 Schedules............................................................................................................ 6
Regulatory Engagement Plan, Rev. 2 ii Acronyms and Abbreviations ACU Abilene Christian University AEA Atomic Energy Act CP Construction permit GT Georgia Institute of Technology MSR Molten Salt Reactor MSRR Molten Salt Research Reactor NEIMA Nuclear Energy Innovation and Modernization Act NRC Nuclear Regulatory Commission NRRA Natura Resources Research Alliance REP Regulatory Engagement Plan SERC Science and Engineering Research Center TAMU Texas A&M University UT University of Texas at Austin
Regulatory Engagement Plan, Rev. 2 1
REGULATORY ENGAGEMENT PLAN 1
LICENSING HISTORY AND STATUS Abilene Christian University (ACU) submitted an initial Regulatory Engagement Plan (REP) for the Molten Salt Research Reactor (MSRR) pre-application phase to the Nuclear Regulatory Commission (NRC) on July 24, 2020 (ML20241A071). A REP for the MSRR construction permit (CP) application was submitted on May 27, 2022 (ML22157A033). A CP application dated August 12, 2022 (ML22227A201) was submitted and the application was accepted for review on November 18, 2022 (ML22313A097). A CP for the MSRR was issued to ACU on September 16, 2024.
This update to the REP will address plans that support operating license pre-application activities and plans for operating license application submittal.
2 FACILITY DESCRIPTION 2.1 Abilene Christian University ACU is an accredited non-profit educational institution that has been in operation since 1906. Fall 2024 marks the seventh consecutive year for a record number of students enrolling at ACU. ACU consistently achieves high status among 1,500 universities evaluated for the annual "U.S. News Best Colleges edition.
The Nuclear Energy eXperimental Testing Laboratory (NEXT Lab) was established by ACU in 2015 to focus on Molten Salt Reactor (MSR) technology development and deployment. The mission of the NEXT Lab is to provide global solutions to the worlds need for energy, water, and medical isotopes by advancing the technology of MSRs while educating future leaders in nuclear science and engineering.
NEXT Lab is part of the Natura Resources Research Alliance (NRRA) that includes Georgia Institute of Technology (GT), Texas A&M University (TAMU), and the University of Texas at Austin (UT). All three external collaborators have years of experience with research reactors. TAMU and UT have active research reactor licenses.
2.2 Purpose and Intended Use of the Reactor The purpose of the MSRR is to accelerate the development and deployment of MSR systems through foundational research while also developing a new pipeline for a nuclear qualified workforce. ACUs large capital investment in the MSRR will provide a world-class molten salt research facility that will be utilized by large numbers of students, staff, faculty, and outside collaborators. The intended use of the MSRR is to conduct research on molten salt systems, as well as to educate and train a new generation of engineers and scientists who will be uniquely prepared to contribute to the advancement and deployment of molten salt reactors and applications. The research will generate experimental MSR data to advance the understanding of:
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generation and migration of gases and vapors in a fluid-fueled fluoride reactor, fission product behavior, including migration through gas spaces, the behavior of delayed neutron precursors during normal and off-normal operating conditions, performance of materials in a fluoride salt environment, performance of materials in the combined high temperature, radiation, and salt environment, techniques for monitoring operation of a fluoride salt reactor, and fuel salt evolution during operation.
This information can be used in the design, software validation, licensing, and regulation of commercial MSRs.
2.3 Regulatory Application Type The ACU MSRR will be a utilization facility as described in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.21(c) that is useful in the conduct of research and development activities of the types specified in Section 31 of the Atomic Energy Act of 1954, as amended (AEA), and the activities will meet the 10 CFR 50.2 definition of research and development. The MSRR will not be a commercial and industrial facility as specified in paragraph (b) of 10 CFR 50.21 or in 10 CFR 50.22. Based on these activity tests and given that the proposed MSRR is not a testing facility, ACU is seeking to obtain a license under AEA Section 104c pursuant to 10 CFR 50.21(c) as a university research reactor facility with licensed power operation at up to 1 MWth. ACU is aware of the changes made to Section 104c of the Atomic Energy Act (AEA) by the Nuclear Energy Innovation and Modernization Act (NEIMA) and believes that MSRR activities will be consistent with licensing under Section 104c of the AEA as amended by NEIMA.
The 10 CFR Part 50 license application intends to follow the appropriate guidance provided in:
NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors - Format and Content ISG-2012, Interim Staff Guidance Augmenting NUREG-1537 Part 1 for Licensing Radioisotope Production Facilities and Aqueous Homogeneous Reactors Appendix A, Part 1, Guidelines for Preparing and Reviewing Application for the Licensing of Non-Power MSRs: Format and Content, of the ORNL/TM-2020/1478 report titled, Proposed Guidance for Preparing and Reviewing a Molten Salt Non-Power Reactor Application (ADAMS Accession No. ML20219A771)
ACU intends to embed several activities subject to different NRC requirements in the primary operating license application in accordance with 10 CFR 50.31, Combining Applications, and 10 CFR 50.32, Elimination of Repetition. The application will include at least the following applicable requirements: 10 CFR Part 30, Rules of General
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Applicability to Domestic Licensing of Byproduct Material, 10 CFR Part 40, Domestic Licensing of Source Material, 10 CFR 50, Domestic Licensing of Production and Utilization Facilities, 10 CFR Part 55, Operators Licenses, and 10 CFR Part 70, Domestic Licensing of Special Nuclear Material.
2.4 Geographical Location of the Site The MSRR will be housed inside the Science and Engineering Research Center (SERC) which is on the southeast corner of the ACU main campus in Abilene, Texas.
The SERC is a 28,000-square-foot multi-level facility with space for research in chemistry, physics, and a variety of engineering disciplines. The reactor will be located below grade in a systems trench located in the SERC research bay.
3 REACTOR DESCRIPTION 3.1 General Description of the MSRR The MSRR is a single region core, loop-type, thermal spectrum reactor with a fluoride-based fuel salt that flows through a graphite moderator and stainless steel fuel circuit components. A secondary loop with flowing fluoride-based cooling salt, designed to remove 1 MWth of heat, will be used to cool the fuel circuit and expel the heat to the atmosphere. A schematic of the reactor system is provided in Figure 1. The MSRR is modeled after the 8 MWth Oak Ridge National Laboratory Molten Salt Reactor Experiment and is designed to be passively safe. The MSRR relies on intrinsic properties of molten salts and engineered safety features to ensure safe and reliable operations. The reactor can be described as a series of interconnected subsystems that include fuel handling, primary salt loop, secondary cooling loop, gas management, biological shielding, and instrumentation and controls.
3.2 Safety Features/Functional Characteristics of the MSRR There are a number of inherent safety features built into the design and materials of the MSRR. Given the low power of the reactor, the overall risk to people and the environment is limited by the small source term and the low fission product inventory.
The MSRR is significantly different from the reactors licensed in the past by the NRC and has several unique safety features not found in most solid fuel systems. As an MSR, most of the inherent safety features are a result of the formulation and properties of the salts and the movement of the salts within the system.
The MSRR salts are highly ionic compounds that are chemically stable and are compatible with the MSRR structural materials. They do not react rapidly with moisture or air. Their chemical inertness eliminates the risk of fire or explosion due to chemical interaction. Molten salts have been used for years in non-nuclear industries as heat transfer media for their inertness and safety. The MSRR salts are stable to several hundred degrees above temperatures obtainable in the reactor and remain at low vapor pressure. Because the reactor is an inert liquid system at low pressure, safety demands on the MSRR design and the SERC facility are significantly reduced.
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The MSRR fuel salt has a short and unobstructed path from the fuel loop to a drain tank, allowing the fuel salt to be completely drained in approximately one minute, even under power outages. The geometry and position of the drain tank ensure a noncritical configuration under all conditions when the entire fuel salt inventory is in it.
The reactor vessel is the only location where criticality can be reached and sustained in the MSRR. Unlike existing reactor types, only a fraction of the fuel participates in the sustained chain reaction at any given time, as the remainder is flowing through the rest of the primary circuit. The MSRR core is designed to have very low excess reactivity.
Burned fuel can be made up through occasional fuel salt additions through an access tank. Control rods capable of controlling fission rate are also included in the MSRR design. The MSRR includes a shielding system designed to protect people and the environment from radiation.
The MSRR relies on intrinsic properties of molten salts and engineered safety functions to ensure safe and reliable operations and includes:
Small source term (low power, low burnup)
Very low excess reactivity Strongly negative reactivity coefficient of temperature Redundant control rods to control criticality during normal operations Unobstructed path for fuel salt to drain during power outage Passive decay heat removal from the drain tank Defense in depth through multiple barriers minimizes release of fission products, if any, to the public and environment Located in a below grade vault, under a massive shielding system, that also adds a significant layer of protection from external events
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Figure 1 Depiction of the MSRR reactor loop inside the reactor enclosure.
4 CONSTRUCTION ACTIVITIES The detailed design of the MSRR is being finalized. ACU will coordinate with NRC construction inspection staff to plan and prepare for inspections before any components are fabricated. Component orders are expected in early 2025 with fabrication soon thereafter. Once construction schedules are finalized, they will be provided to the NRC and detailed arrangements for inspections can be established.
The development and implementation of the MSRR facility Quality Assurance Program for NEXT Lab began during the design phase and continues to be adopted by the MSRR project. The Program focuses on the development of appropriate controls that
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ensure the MSRR is properly designed, fabricated, and operated to meet regulatory and university requirements. The organizational and policy portions of the Program have been implemented. Design control is being implemented at ACU and through contractor quality assurance programs. Procurement controls will be implemented before the vendor selection process begins.
5 OPERATING LICENSE ACTIVITIES 5.1 Pre-application Activities In preparation for an operating license application, ACU is preparing the following documents for NRC review.
- A topical report on testing and methodology for qualification of fuel salt
- The Degradation Management Program as required by permit condition D(b)
ACU desires to submit a high-quality license application. Another pre-application activity that ACU would like to pursue is a staggered readiness review. As described in Section 4.3 of NRR Office Instruction LIC-116, ACU would likely only submit selected parts of the application. The review would provide groups of draft Final Safety Analysis Report chapters for audit by NRC reviewers. The audits would allow NRC reviewers to provide feedback on the completeness of the information and identify technical or regulatory issues that may complicate the application review. ACU will coordinate with NRC project managers on the length and schedule for the readiness reviews once chapter composition begins.
5.2 Schedules Figure 2 shows the month for anticipated submission of licensing documents and the desired review schedule. ACU will inform the NRC of any changes to the anticipated submission schedules. The key document submission dates are:
- November 2024 - Degradation Management Program
- December 2024 - Topical report on fuel qualification methodology
- Spring 2025 - Staggered readiness review
- Summer 2025 - Operating license application
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Figure 2 J
A S O N D J F M A M J J
A S O N D J F M A M J J
A S O N D Construction permit issued Complete design and evaluate it 9
Operational program development 9
OL Pre-application (NRC review)
Fuel qual methodology topical 14 Degradation Management Program submittal Staggered readiness reveiw 4
OL application preparation 8
Construction of reactor 18 NRC review of license application 18 Legend NRC actions are green ACU actions are purple MSRR Licensing Schedule Duration (months) 2024 2025 2026