ML24331A143
| ML24331A143 | |
| Person / Time | |
|---|---|
| Issue date: | 11/06/2024 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-0096 | |
| Download: ML24331A143 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Docket Number:
(n/a)
Location:
teleconference Date:
Wednesday, November 6, 2024 Work Order No.:
NRC-0096 Pages 1-94 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 720TH MEETING 4
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
(ACRS) 6
+ + + + +
7 WEDNESDAY 8
NOVEMBER 6, 2024 9
+ + + + +
10 The Advisory Committee met via 11 teleconference at 8:30 a.m., Walter L. Kirchner, 12 Chair, presiding.
13 COMMITTEE MEMBERS:
14 WALTER L. KIRCHNER, Chair 15 GREGORY H. HALNON, Vice Chair 16 DAVID A. PETTI, Member-at-Large 17 RONALD G. BALLINGER, Member 18 VICKI M. BIER, Member 19 VESNA B. DIMITRIJEVIC, Member 20 CRAIG A. HARRINGTON, Member 21 ROBERT P. MARTIN, Member 22 SCOTT P. PALMTAG, Member 23 THOMAS E. ROBERTS, Member 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
2 ACRS CONSULTANTS:
1 DENNIS BLEY 2
4 DESIGNATED FEDERAL OFFICIAL:
5 DEREK WIDMAYER 6
8 9
10 11 12 13 14 15 16 17 18 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
3 CONTENTS 1
PAGE 2
Opening Remarks by the ACRS Chairman 4
3 Draft White Paper "Nth-of-a-Kind 4
Micro-Reactor Licensing and 5
Deployment Considerations" 7
6 Committee Deliberation on Draft White Paper 7
"Nth-of-a-Kind Micro-Reactor Licensing 8
and Deployment Considerations"
...... 45 9
Break...................... 69 10 Triennial Review and Evaluation of NRC Safety 11 Research Program/Preparation of Reports.. 70 12 13 14 15 16 17 18 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
4 P-R-O-C-E-E-D-I-N-G-S 1
(8:30 a.m.)
2 CHAIR KIRCHNER: Okay. The meeting will 3
now come to order. This is the first day of the 720th 4
meeting of the Advisory Committee on Reactor 5
Safeguards, ACRS. I'm Walt Kirchner, Chair of the 6
ACRS.
7 ACRS members in attendance in person are 8
Ron Ballinger, Greg Halnon, Craig Harrington, Bob 9
Martin, Scott Palmtag, Dave Petti and Tom Roberts.
10 ACRS members in attendance virtually via 11 Teams are Vicki Bier and Vesna Dimitrijevic. And ACRS 12 consultants also via Teams are Dennis Bley and I 13 expect Steve Schultz to join us as well. If I missed 14 anyone, either ACRS members or consultants, please 15 speak up at this point.
16 Derek Widmayer, the ACRS staff, is the 17 designated federal officer for this morning's full 18 committee meeting.
19 No member conflicts of interest were 20 identified for today's meeting and I note that we have 21 a quorum.
22 The ACRS was established by statute and is 23 governed by the Federal Advisory Committee Act, or 24 FACA. The NRC implements FACA in accordance with its 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 regulations.
1 For these regulations and the Committee's 2
bylaws, the ACRS speaks only from its published letter 3
reports. Therefore, all member comments should be 4
regarded as only the individual opinion of that member 5
and not a committee position.
6 All relevant information related to ACRS 7
activities, such as letters, rules for meeting 8
participation and transcripts, are located on the NRC 9
public website and can be easily found by typing 10 "About Us ACRS" in the search field on the NRC's home 11 page.
12 The ACRS, consistent with the Agency's 13 value of public transparency in regulation of nuclear 14 facilities, provides opportunity for public input and 15 comment during our proceedings.
16 We have received no written statements or 17 requests to make an oral statement from the public; 18 however, and, in addition, written statements may be 19 forwarded to today's designated federal officer. We 20 have also set aside time at the end of this meeting 21 for public comments.
22 A transcript of the meeting is being kept 23 and will be posted on our website. When addressing 24 the Committee, participants should first identify 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 themselves and speak with sufficient clarity and 1
volume so that they may be readily heard.
2 If you are not speaking, please mute your 3
computer on Teams. If you're participating by phone, 4
press *6 to mute your phone and *5 to raise your hand 5
on Teams.
6 Please do not use the Teams' chat feature 7
to conduct sidebar discussions related to 8
presentations. Rather, limit use of the meeting chat 9
function to report IT problems.
10 For everyone in the room, please put all 11 of your electronic devices in silent mode and mute 12 your laptop microphone and speakers.
13 In
- addition, please keep sidebar 14 discussions in the room to a minimum since the ceiling 15 microphones are live.
16 For presenters, your table microphones are 17 unidirectional and you'll need to speak into the front 18 of the microphone to be heard online.
19 Finally, if you have any feedback for the 20 ACRS about today's meeting, we encourage you to fill 21 out the Public Meeting Feedback Form on the NRC's 22 website.
23 During today's meeting, the Committee will 24 consider two topics. In the morning session, we will 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 discuss the Draft White Paper "Nth-of-a-Kind Micro-1 Reactor Licensing and Deployment Considerations."
2 And in our afternoon session that will 3
begin at 1:00 p.m., we will discuss the Triennial 4
Review and Evaluation of the NRC Safety Research 5
Program.
6 Tomorrow morning, the Committee will 7
discuss the TerraPower Natrium Topical Report on Plume 8
Exposure Pathway Emergency Planning Zone. And 9
tomorrow afternoon, the Committee will have its 10 monthly planning and procedures meeting.
11 Before I turn over the Committee's 12 deliberations to Vicki Bier, who chairs our Regulatory 13 Rulemaking and Policies Subcommittee, I'll ask members 14 if they have any opening statements or comments for 15 the record.
16 (Pause.)
17 CHAIR KIRCHNER: Okay. Hearing none, 18 we'll turn now to the Draft White Paper on Nth-of-a-19 kind micro-reactor licensing and deployment 20 Considerations.
21 Vicki, the floor is yours.
22 MEMBER BIER: Thank you very much, Walt.
23 As Walt mentioned, the Subcommittee on 24 Regulatory Policies and Practices heard a detailed 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 briefing on the staff's Draft White Paper on Nth-of-a-1 kind micro-reactor licensing at its subcommittee 2
meeting a couple of weeks ago and this draft is 3
planned to become a SECY paper and sent to Commission 4
for consideration.
5 So, we are reviewing the paper, as part of 6
our obligations, under Title 10 of CFR to report on 7
matters concerning the safety of nuclear power 8
reactors.
9 At the subcommittee meeting, all but one 10 of the ACRS members were present. We had some 11 detailed discussion at the time and it was recommended 12 that most likely a letter would not be needed at this 13 time.
14 We may have comments on Nth-of-a-kind 15 reactor licensing and deployment later as the process 16 develops and becomes more detailed, but that at this 17 time we most likely will not write a letter.
18 So, therefore, the plans for today are to 19 have a short briefing summarizing some of the status 20 of this effort on the part of the staff.
21 After that, there may be some discussion 22 among the Committee Members and time for public 23 comment.
24 I anticipate that this meeting will most 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 likely end fairly early, you know, not go the full 1
morning session.
2 Anyway, with that, I apologize for not 3
being in the room in person today. So, I'm not sure 4
who is the lead presenter this morning, but whoever is 5
opening for the staff can go ahead and begin their 6
remarks.
7 MR. LYNCH: Good morning. This is Steve 8
Lynch, Chief of the Advanced Reactor Policy Branch.
9 I just wanted to thank the members again for the 10 opportunity to come and discuss the important work 11 that we are doing to prepare our regulatory framework 12 for the rapid advanced deployment of micro-reactors.
13 The staff here is going to share a summary 14 of the work that we have done by addressing 15 operational programs and reviewing of the 16 standardization of those to facilitate more effective 17 licensing Nth-of-a-kind micro-reactors.
18 We look forward to answering any questions 19 that the Committee may have for us today to further 20 inform the work that we're doing as our next milestone 21 with this effort is to prepare a policy paper for the 22 Commission.
23 We are still in the feedback stage of 24 developing this paper. So, getting feedback from 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
10 members today will be taken into account in our 1
continued work, and the staff is further engaging with 2
stakeholders at a public meeting later this afternoon 3
to get additional perspectives on the paper.
4 So, thank you, again, for your time. I 5
will now turn it over to our presenters Duke Kennedy 6
and Jackie Harvey.
7 MR. KENNEDY: Okay. Thank you, Steve.
8 Good morning, members of the ACRS.
9 Pleasure to be here today to talk to you about our 10 paper on Nth-of-a-kind micro-reactor licensing and 11 deployment considerations.
12 So, the contents of our presentation today 13 will include the motivation for the paper, the 14 background, we'll talk about the conceptual deployment 15 model for transportable micro-reactors, the 16 anticipated licensing strategy for Nth-of-a-kind 17
- reactors, and we'll cover the options for 18 standardization of operational programs and their 19 review concurrent with the design stage.
20 And then there are five other topics 21 related to Nth-of-a-kind micro-reactor licensing and 22 deployment that we'll discuss that relate to enhancing 23 the efficiency of Nth-of-a-kind licensing. And then 24 we'll wrap up with brief notes on stakeholder 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 engagement and next steps.
1 Our motivations for the paper. We've been 2
working for several years to evaluate the regulatory 3
framework for micro-reactors and prioritizing 4
strategies for reliable and efficient licensing of 5
micro-reactors.
6 We continue to engage those stakeholders 7
and pre-applicants through periodic stakeholder 8
meetings as well as dedicated pre-application 9
engagement activities.
10 We are prioritizing these strategies for 11 predictable and efficient licensing and regulation of 12 micro-reactor designs and the new operational models 13 that they present, and have been working to identify, 14 prioritize, and take steps to address and resolve 15 associated policy issues.
16 So, for licensing purposes, micro-reactors 17 are commercial power reactors licensed under Section 18 103 of the Act.
19 Based on feedback and information from 20 developers, they're typically planning to use non-21 light-water reactor technologies, power levels 22 anywhere from a few megawatts to several tens of 23 megawatts.
They have anticipated small site 24 footprints which could be just a single container 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
12 the reactor is contained in or a small site with 1
simple instruction activities and buildings to support 2
operations.
3 It is anticipated they'll have lower 4
potential consequences in terms of radiological 5
releases and increased reliance on passive systems and 6
inherent characteristics to control power and heat 7
removal compared to the large light-water reactors 8
that are in operation today.
9 So, factory-fabricated transportable 10 micro-reactors are a subset of micro-reactors that 11 would rely heavily on standardization and mass 12 production to simplify licensing and deployment.
13 We covered other topics related to 14 factory-fabricated transportable micro-reactors in the 15 SECY paper provided to the Commission in January of 16 this year that focused on licensing and -- options for 17 licensing and regulation of fuel loading and 18 operational testing in a factory as well as a concept 19 of features to preclude criticality that would allow 20 a reactor loaded with fuel to be considered not to be 21 in operation, which would facilitate transportation 22 and other activities under the current regulatory 23 framework.
24 For the purposes of this presentation, 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
13 term "Nth-of-a-kind micro-reactor" generally means a 1
micro-reactor of a standard design that has been 2
previously approved by the NRC. This could be through 3
a design certification, a manufacturing license, as 4
well as through a first-of-a-kind licensing effort.
5 Any of these can then be referenced in a subsequent 6
application for an Nth-of-a-kind reactor.
7 And so, Nth-of-a-kind micro-reactor 8
licensing refers to the licensing of micro-reactors of 9
the standard pre-approved design for operation as 10 power reactors at fixed sites.
11 Here's our conceptual deployment model.
12 This is the same deployment model that we developed 13 for the SECY paper provided to the Commission in 14 January.
15 It starts with a manufacturing facility or 16 factory where the reactor is fabricated. And 17 depending on Commission direction on the previous 18 SECY, it could be loaded with fuel or potentially 19 operated for functional testing, including nuclear 20 testing.
21 Then the reactor would be transported to 22 a deployment site where it would be either set up as 23 a standalone, self-contained design or incorporated 24 into buildings and structures and equipment 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
14 constructed onsite.
1 And so, the paper that we're discussing 2
today really focuses on the process for licensing that 3
operation at the deployment site, in the middle column 4
there.
5 And then following operation, reactors may 6
be transported offsite and decommissioned elsewhere.
7 They may be decommissioned onsite or they may be 8
refurbished and refueled and redeployed.
9 So, what's in the Draft White Paper? We 10 have two vote topics. One is approval of standardized 11 operational programs at the design stage concurrent 12 with a manufacturing license or design certification.
13 Then we also have alternative approaches 14 for environment reviews, which we are not going to 15 discuss today, but we have released an enclosure last 16 week that covers more information about environmental 17 reviews.
18 There's another enclosure, Enclosure 1, 19 that provides additional information about operational 20 programs and how they might be standardized for micro-21 reactors.
22 And so, that enclosure includes a lot of 23 information about the staff's thinking of what might 24 be able to be standardized for micro-reactors and what 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 benefits could be achieved by approving standardized 1
operational programs early in the licensing process 2
concurrent with a design review.
3 And then Enclosure 3
includes six 4
additional information topics related to efficient 5
Nth-of-a-kind license.
6 So, next we'll talk about the anticipated 7
licensing strategies. Phase 1 is a robust up-front 8
approval of a standard design. Listed there are 9
numerous pathways through which this could be 10 accomplished.
11 Also, approval of standardized operational 12 programs to the extent practicable, and completion of 13 a generic environmental review, to the extent 14 practicable, and also completion of hearings that are 15 necessary to cover the standard design or the 16 rulemaking process for design certification.
17 So, these up-front approval activities 18 would resolve many technical and other issues 19 generically and then would be able to be referenced in 20 the Nth-of-a-kind review.
21 The last bullet here is the time frames 22 for these different pathways for achieving the 23 standardized design. It can be varied.
24 We have generic milestones published 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
16 how long these processes take and these -- the route 1
that's chosen for approval of a standard design can 2
also affect the time frames for Nth-of-a-kind 3
licensing. We'll touch on that a little bit more 4
later.
5 So, Phase 2 of the process is the actual 6
Nth-of-a-kind licensing which would leverage the up-7 front approvals.
8 Because these reactor -- the reactor 9
design would be essentially approved up front, we 10 think there's an opportunity to take advantage from 11 streamlined administrative processes. I'll touch on 12 that a little bit later.
13 There would also need to be safety and 14 security reviews that focus on confirmation of site 15 suitability.
16 So, the level of standardization achieved 17 in Phase 1 will determine the effort that's necessary 18 to do these reviews for confirming site suitability.
19 There will also be site-specific 20 environmental reviews, confirmatory inspections at the 21 place of fabrication and also at the deployment site.
22 And, again, this will depend on a 23 developer's deployment model and whether they're 24 taking advantage of manufacturing the reactor at a 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 manufacturing facility or how much onsite construction 1
is necessary to -- for the reactor design.
2 Then for Part 52, licensing there would be 3
a verification of completion of the inspections, tests 4
and analyses and satisfying the acceptance criteria, 5
6 And then for Part 50, there will also be 7
readiness inspections for operations and verification 8
that the reactor has been -- construction has been 9
substantially completed.
10 And then both Part 52 and Part 50 include 11 site-specific hearings that are mandatory hearings as 12 well as opportunities for contested hearings.
13 VICE CHAIR HALNON: Duke, this is Greg 14 Halnon. One of the things that at least I'm 15 struggling with, and I think a few of the members may 16 be, I understand that security is not in the purview 17 here; however, the effects of a security event could 18 very much affect what we decide and talk about around 19 this table relative to source terms and effect on the 20 public and other things.
21 In addition, I get that the environmental 22 review you say is not in our -- necessarily part of 23 this meeting, but the effects on the environment are.
24 So, when we try to exclude those from our discussion, 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 we're incomplete in some things.
1 So, bear with us if we talk about those 2
things, maybe not how we protect, but what happens if 3
something from a security event, if you will, occurs 4
because that's a big piece of the discussion when 5
you're transporting and fueling and operating these 6
things all across our land.
7 So, I just wanted to make that comment at 8
this point so that if we don't come back and put our 9
hand on this thing, we can't talk about that, we may.
10 MEMBER PALMTAG: This is Scott Palmtag. I 11 just want to follow. I agree with what Greg said.
12 Environmental review is not part of this review.
13 Is it going to be? Are we going to see 14 this in the future? Is there a plan to hear about the 15 environmental review?
16 (Pause.)
17 MEMBER PALMTAG: I'm going to take that as 18 a no, but I do agree. I'm very curious how that's 19 going to work out. So, I'd like to hear something 20 about the environmental review when it is ready.
21 MEMBER MARTIN:
This is Bob.
22 Environmental is kind of outside the scope of ACRS, 23 typically, right?
24 VICE CHAIR HALNON: Yes.
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 MEMBER MARTIN: Yeah. So, we --
1 (Simultaneous speaking.)
2 MEMBER PALMTAG:
It's part of the 3
licensing, though.
4 MEMBER MARTIN: Yes, it's part of the 5
licensing, but I don't think it's part of ACRS --
6 (Simultaneous speaking.)
7 VICE CHAIR HALNON: Maybe our staff can 8
help us, nor does it exclude us from looking at 9
environmental --
10 MR. WIDMAYER: So, hey, you guys. This is 11 Derek Widmayer. What we're excluded from doing is the 12 NEPA review, the mandated NEPA review.
13 So, that -- and that's basically what they 14 are addressing in Enclosure 2 is how they want to do 15 that.
16 You're not excluded from talking about 17 appropriate environmental impacts as they relate to 18 safety, but we're talking about the mandated legal 19 review as something that you guys don't have to get 20 involved in or are not supposed to get involved in.
21 CHAIR KIRCHNER: Right. So, we don't weigh 22 in in the NEPA process directly, but certainly the 23 safety review that the staff performs for any concept 24 informs the environmental review in many different 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 ways.
And so, it's part of our statutory 1
responsibility in reviewing safety issues.
2 Indirectly, we will look at environmental 3
impact, but we do not participate formally in the NEPA 4
process.
5 MEMBER PALMTAG: Thank you. This is Scott 6
Palmtag again. I understand that. The one area I 7
have is in the schedule in that, my understanding, you 8
still have to go through the environmental review.
9 And if the environmental review is still 10 going to take something, I mean we're at a year or 11 more, it seems like unrealistic expectations to try to 12 get our licensing approval done in six months.
13 So, specifically I have questions about 14 it. I don't want to do oversight of the environmental 15 review, but I'm curious how they plan on getting the 16 time frame for the environmental review down to six 17 months like we're expected to.
18 MR. LYNCH: This is Steve Lynch, Chief of 19 the Advanced Reactor Policy Branch, just to speak 20 briefly on the environmental review piece of this.
21 So, the NRC does have parallel actions 22 that it is taking right now looking at how we are 23 conducting environmental reviews particularly in 24 response to the Fiscal Responsibility Act that does 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 direct the NRC to look at streamlining activities that 1
we could take to improve our efficiency in conducting 2
environmental reviews.
3 So, we do expect that there will be 4
continued efficiencies identified in some of our 5
parallel actions that we will coordinate with our 6
micro-reactor efforts.
7 MEMBER PALMTAG: Thank you.
8 MEMBER ROBERTS: Yes. Tom Roberts.
9 Following up with what Greg and Derek said, part of 10 the environmental assessment is the Severe Accident 11 and Management Alternative -- the Severe Accident 12 Mitigation Design Alternatives and that's an area that 13 I would think we would want to look at that just 14 generically is that that's where that type of 15 assessment shows up.
16 Maybe everybody has a different view on 17 that, but that's one area it seems that we should 18 just, you know, inherently review.
19 MR. LYNCH: Steve Lynch again just to speak 20 on severe accidents. In the guidance that the NRC has 21 developed for advanced reactor environmental reviews 22 to include micro-reactors, that is a topic that we 23 have aggressed in looking in making sure that the 24 staff is aware of differences and how we may look at 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 SAMDAs compared to previously licensed large light-1 water reactors. So, there are efforts looking at 2
that.
3 For the current paper that we're working 4
on, you know, looking at the operational programs and 5
more on that administrative side, that is exciting to 6
hear.
7 But as we continue to implement strategies 8
moving forward consistent with legislative direction, 9
whether that be NEIMA, the Fiscal Responsibility Act, 10 or the ADVANCE Act, the NRC staff will continue to 11 look at the hazards associated with the operation and 12 siting of these micro-reactors.
13 And to the extent that we have issues that 14 come up that we are looking to address that are unique 15 to these facilities, we will bring them to the ACRS to 16 discuss. So, thank you.
17 MR. KENNEDY: Okay. Thank you. I will 18 just also mention that the regulations for 19 manufacturing licenses and design certifications 20 require the NRC to prepare an environmental assessment 21 that directly address SAMDA.
22 That's one environmental issue that is 23 reviewed as part of proceeding for a manufacturing 24 license or a design certification.
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 I think I'll also offer with respect to 1
the question on the timing of the entire process, we 2
have laid that out in the White Paper, some 3
illustrative time frames for what we think could be 4
sort of minimal overall process time frames for parts 5
of the licensing process that are directly under NRC 6
control, as well as -- I don't want to say "maximum" 7
time frames, but longer time frames.
8 And in developing those illustrative time 9
frames, when you get to the lower ends, you're talking 10 about situation where reactors are fully standardized.
11 They're being produced without any departures from the 12 approved design.
13 And then, also, the environmental review 14 has been pared down to a streamlined environmental 15 assessment or even a categorical exclusion.
16 So, those are the options that are 17 discussed in the paper that would help to achieve the 18 shortest time frames, but, if you read Enclosure 2, 19 you'll see a fulsome discussion of the staff's overall 20 strategy for conducting its NEPA reviews and how it 21 might be phased over time to take advantage of gaining 22 experience with licensing a particular design.
23 So, I'll just say that we have considered 24 how the environmental review can be streamlined 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
24 the overall time frame shortened would be aligned with 1
the time frame that we think would be necessary to 2
conduct the safety portion of the review. So, we've 3
considered both in our illustrative time frames.
4 Okay. So, now I'm moving into approaches 5
for review of standardized operational programs. So, 6
this is the first vote topic that would be presented 7
in the SECY paper and that's discussed in the White 8
Paper.
9 There are two options the staff has 10 considered and the first option -- let's go here to 11 the next page -- the first option is the status quo 12 that's currently applicants can submit operational 13 programs as topical reports or they could also 14 reference operational programs that have already been 15 approved in a previous reactor licensing review. So, 16 those are available at this time.
17 The second option the staff has been 18 considering is the review and approval of operational 19 programs in parallel or as part of a design 20 certification or -- sorry, as part of the design 21 certification or manufacturing license application.
22 So, this would allow applicants to propose 23 standardized operational programs in the ML or DC 24 application for the NRC staff to review and approve 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 those at the design stage, which would essentially 1
allow applicants for Nth-of-a-kind reactors to 2
reference those programs and not have them have to be 3
part of the extensive review of a COL application.
4 So, the thinking here is that by having 5
those programs pre-approved as part of the ML or DC, 6
that the time frame for Nth-of-a-kind licensing can be 7
reduced by saving the time needed to review those 8
programs with a review of each combined license or 9
construction permit and operating license application.
10 VICE CHAIR HALNON: So, did you envision 11 change process for customization similar to the 5059-12 type process later down the road? The company buys 13 one of these and then they make a small change to 14 these standardized programs?
15 MR. KENNEDY: So, there are change control 16 processes specified in the regulations and as part of 17 the design certification rulemaking. One of the 18 appendices usually includes a discussion of the 19 processes needed for change control.
20 I don't know, Jackie. Did you want to add 21 anything here?
22 MS. HARVEY: Yes. This is Jackie Harvey.
23 So, that is something that we are going to explore, if 24 directed by the Commission, to pursue Option 2.
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26 VICE CHAIR HALNON: But we saw recently in 1
a discussion we had on SMR that the degree of 2
standardization during the approval process sometimes 3
was left up to the COL applicant where it put into 4
question what the definition of "standard" was, 5
basically, and we struggled a little bit with how deep 6
to go with that.
7 So, on this will you have a list of at 8
least the minimum set of programs required to be 9
standardized or is it going to be left up to -- is 10 that just nebulous at this point?
11 MS. HARVEY: Yeah, this is Jackie Harvey 12 again. So, there are a lot of different deployment 13 models that are being discussed right now.
14 So, we're trying, at least at this point 15 in time, to allow staff the flexibility to make that 16 decision in the future to see what developers are 17 going to do.
18 VICE CHAIR HALNON: So, it could be 19 reactor-specific?
20 MS. HARVEY: Exactly.
21 VICE CHAIR HALNON: Okay. Thanks.
22 MR. KENNEDY: Thank you. So, one other 23 thing to mention, and this goes to your question, is 24 that there is some uncertainty about how fully 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
27 applicant could describe its programs and how much 1
reliance there would actually be on site-specific 2
features.
3 And so, this approach would allow the 4
staff to prove these programs up front if they're 5
fully described.
6 MS. HARVEY: Um-hm.
7 MR. KENNEDY: And if a full program isn't 8
described, there may be the ability to approve some 9
aspects or requirements within that program on a 10 generic basis and then focus the Nth-of-a-kind review 11 of those programs on filling in the site-specific 12 considerations.
13 The idea is that a future applicant, if 14 Option 2 were available, could still choose to do 15 Option 1. It really depends on what's appropriate for 16 their deployment model.
17 And so, this -- the options that we're 18 considering for the paper are really to provide 19 additional flexibility for the staff and for 20 applicants to be able to implement their desired 21 deployment models and we think that there's going to 22 be a wide variety of what applicants end up wanting to 23 do.
24 Okay. So, now moving to the information 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 topics that are presented in the paper, the first is 1
maximum design standardization.
2 And this isn't really anything new; 3
however, micro-reactors having typically simpler 4
designs and smaller site footprints, perhaps much less 5
reliance on site-specific construction activities, 6
really offer kind of a new opportunity to take 7
advantage of design standardization in making Nth-of-8 a-kind licensing more efficient.
9 So, again, there are various pathways by 10 which a standardized design could be approved. Could 11 be a manufacturing license, which really provides the 12 greatest level of standardization for a reactor that 13 can be fully manufactured in a factory.
14 The regulations for design certifications 15 cover the entire plant. And so, the whole-plant 16 design could be standardized through a design 17 certification which could include things that would be 18 constructed at the site as opposed to just things 19 manufactured in the manufacturing facility.
20 And then there is also standard design 21 approval that can be used for entire portions of a 22 plant; however, that doesn't really achieve the same 23 level of standardization in terms of regulatory 24 stability and finality of the proceeding on the design 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
29 approval.
1 And then, again, there's also the ability 2
to standardize through first-of-a-kind reactor design 3
that could be referenced in subsequent applications.
4 But when we're talking about maximal 5
design standardization, we're really focusing on 6
manufacturing licenses and design certifications that 7
provide the greatest level of finality and regulatory 8
stability of the design.
9 MEMBER PALMTAG: This is Scott Palmtag 10 again. This is just a follow-on to Craig's comment 11 from before, but there's -- as we discussed yesterday, 12 there's different kinds -- there's standard designs 13 and then there's as-built designs.
14 When you say the standard designs, are you 15 saying the standard designs or something that fully is 16 or another category that's fully built, all the piping 17 diagram concerned, et cetera, et cetera?
18 MR. KENNEDY: Yeah. So, maximal design 19 standardization, in this paper, is what would be 20 needed in order to achieve the shortest time frames.
21 And we're talking about a design that's 22 fully -- a final design that's fully approved and that 23 each individual reactor deployment does not take any 24 departures from that design.
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30 So, it's not a -- when I hear "as-built,"
1 I think of when you get to the end of construction and 2
you're ensuring that you've followed the design 3
exactly.
4 If there are any departures that require 5
additional analysis, that's not maximal design 6
standardization.
7 MEMBER PALMTAG: This is Scott again. You 8
could have a standard design, but people could still 9
make changes. It's a category below that standard 10 design, for example where the pipes go, et cetera, et 11 cetera.
12 Is there any -- is there a separate 13 category for that? I would think if you're going to 14 do an Nth-of-a-kind, you'd sort of want the same 15 reactor going out the door not changing the small 16 things, is there?
17 MR.
KENNEDY:
So, there are some 18 flexibilities depending on how the final design is 19 described; however, what we're looking at here is a 20 case where every reactor is essentially identical.
21 If an individual applicant wanted to make 22 changes to that design for some reason to account for 23 some specifics of the site, that would open up that 24 portion to review again as part of the COL review 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
31 the CBOL review which would necessarily extend the 1
licensing process. So, somewhat compared to if the 2
design fit the criteria of maximal design 3
standardization.
4 MEMBER PALMTAG: My concern is that 5
standard design does not mean identical designs. Just 6
something to think about.
7 MR. KENNEDY: Thank you. And one thing 8
that we've heard from developers, also, is that they 9
may actually have more than one model of a standard 10 design where -- depending on where the reactor -- the 11 characteristics are the same where the reactor could 12 be deployed.
13 They may have different, for example, 14 seismic protection equipment, a model A reactor that 15 goes in lower seismic hazard zones and a model B 16 reactor that could go in higher seismic hazard zones.
17 And so, there are ways that a single 18 reactor design, the basic design, could be -- could 19 have variants approved ahead of time so that we get to 20 the site-specific licensing and you, again, you don't 21 have to go back and review that aspect if the correct 22 model and reactor is chosen for the site that part is 23 going to be deployed. So, that's one strategy that 24 we've heard from stakeholders.
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32 Okay. The next topic is grading the level 1
of site characterization. So, the thought behind 2
this, and it's being presented at a conceptual level 3
in the paper, there would need to be -- or likely be 4
guidance developed on how to implement this and that 5
would be something coordinated with stakeholders, but 6
the idea -- the conceptual idea presented is that for 7
micro-reactors and considering their design 8
characteristics, it may be possible based on a 9
comparison of the bounding design parameters of the 10 reactor and the actual site characteristics and the 11 margin between those, the design parameters and the 12 site characteristics, and also considering the margin 13 between the actual consequences of potential accidents 14 and the regulatory criteria for
- doses, that 15 considering those margins it may be possible to do the 16 site characterization in a way that's different from 17 how we do it now and integrate it based on considering 18 those margins.
19 So, for example, if the consequences of a 20 potential accident are very low and the margin between 21 the design limit and the site characteristics is very 22 low, may be possible just to rely on existing data 23 that's available in vetted public sources, USGS maps, 24 instead of doing detailed onsite investigations.
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33 That's one illustrative example.
1 This would have to be done on a 2
characteristic-by-characteristic basis. So, each site 3
characteristic would be evaluated with respect to the 4
margin between that characteristic and the design 5
value. Also, consider the consequences of accidents 6
that could potentially result from site-specific 7
hazards and then determine if there was a -- if there 8
was enough reliable data that already existed or if 9
there needed to be some site characterization 10 activities to supplement that.
11 And you may find that, in the end, you 12 need to do the same level of site characterization as 13 we're currently doing.
14 MEMBER MARTIN: This is Member Martin. I 15 appreciate of course the amount of high level of what 16 you've written down, but I'd like to emphasize the 17 point thats been made a couple times about novel 18 deployment.
19 I can't help but believe that kind of a 20 business case for micro-reactors is all about the 21 novel and we're still thinking kind of in the old way 22 with site characterizations and operations and what 23 have you, you know.
24 I, you know, events like, you know, 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 Hurricane Helene or, you know, any natural disaster, 1
you know, brings up the thought that you might want a 2
micro-reactor, transportable reactor, to respond to 3
national emergencies, novel deployment situations 4
where you wouldn't have time to do, you know, a 5
thorough site characterization in the sense that we 6
normally would do.
7 When do we address those novel situations, 8
because I think they're going to be more common with 9
these things particularly considering, you know, 10 micro-reactors are a more expensive option.
11 So, when is that option the right option?
12 And certainly we can think of, you know, emergency 13 situations, quote situations, what have you, but 14 transportation is a big part of it.
15 And, you know, there isn't, you know, a 16 lot in the white paper on novel, but I know it has to 17 be on your minds.
18 When does that come in? We've just been 19 trying to tweak regulations that we have now with an 20 eye towards the future and then expecting other 21 incremental changes as we get more clarity or is there 22 some activity to really focus on some of these novel 23 deployment scenarios?
24 MR. KENNEDY: Thank you for your question.
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35 So, this paper focuses on fixed site deployment and 1
really where the reactor would be reviewed and 2
licensed at a single fixed site, but that doesn't 3
preclude a single reactor from actually being licensed 4
at other sites as well, but that is not the focus of 5
this paper.
6 There is legislation that was signed 7
earlier this year of the accelerating deployment of 8
advanced nuclear -- versatile advanced nuclear for 9
clean energy or ADVANCE Act, and that has a section, 10 Section 208, and that covers micro-reactor licensing 11 and regulation.
12 Section 208 has eight topics. One of the 13 topics is siting and the siting has three subtopics.
14 Those are considering the population density criteria 15 that was described in a staff paper to the Commission 16 in 2020, and also to consider siting in relation to 17 licensing mobile deployment of micro-reactors, and 18 siting in relation to environmental reviews.
19 And so, the ADVANCE Act directs the NRC to 20 develop risk-informed, performance-based strategies 21 and guidance in these areas that are called out in 22 Section 208. And so, mobile -- licensing mobile 23 deployment is one of those areas.
24 And so, those strategies and guidance are 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 to be developed within 18 months of signature of the 1
law, which was in July. So, that would be January 2
2026.
3 And then to have those strategies and 4
guidance implemented by -- within three years, which 5
would be July of 2027. So, that is coming.
6 MEMBER MARTIN: So, what will we expect in 7
18 months? I mean, a white paper or is there more 8
there?
9 MR. KENNEDY: So, I think it's too early 10 to say specifically on that topic.
11 MEMBER MARTIN: All right. Thank you.
12 MR. LYNCH: Real quick. This is Steve 13 Lynch, Chief Advanced Reactor Policy Branch. When it 14 comes to implementation of specific strategies under 15 the ADVANCE Act method of transportation, the NRC 16 staff has taken a coordinated approach as an agency in 17 working methodically to develop reports and 18 implementation strategies acquired.
19 At this time, the NRC staff is still 20 assessing what the strategies are that we would like 21 to implement.
22 We intend by early 2025, as directed by 23 the legislation, to have identified the areas and 24 strategies that we will be working towards to support 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 micro-reactor licensing and in line with the Act we 1
have three years to work toward implementation.
2 So, as we have those implementation 3
strategies identified, we do expect additional 4
engagement of the ADVANCE Act.
5 CHAIR KIRCHNER: I would just interject at 6
this point that I requested our staff to arrange with 7
my teams leading that effort to respond to the ADVANCE 8
Act, as Steve just outlined, and we'll have a 9
presentation at the ACRS in February time frame.
10 And that will go into detail on -- well, 11 as they formulate their strategies and timelines, 12 they'll share what's available then in February.
13 MEMBER ROBERTS: Yes. This is Tom 14 Roberts. I think the answer to Bob's question is the 15 comment that Greg had made at the subcommittee, which 16 is there are a lot of topics that need to be reviewed 17 and some of them were described as future in the 18 earlier this year SECY paper.
19 To get them all resolved in the next 18 --
20 well, 14 months, right? We've already got four 21 months, you know, behind us.
22 There's been a lot of interaction, I 23 think, with us to try to make sure we're up to speed 24 on what it is you're doing in a way that doesn'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
38 interfere with the schedule.
1 I'm sure you're working that out in terms 2
of how you guys interact with us as part of the 3
overall timeline.
4 It's a very aggressive timeline. There's 5
a lot of topics in there. I don't envy you at all 6
for, you know, great challenge, I guess, I was going 7
to say for you to come through that, but just we want 8
to be caught at the appropriate time so we're not 9
limited at the end.
10 VICE CHAIR HALNON: Yeah, and there's a 11 double reason for that. One, that Tom just said. The 12 other reason is we need to establish, in parallel, 13 what our process of review is going to be for Nth-of-14 a-kind reactors as well.
15 So, we want to complement what you're 16 doing to make sure that our -- down the road our 17 reviews are as efficient as your review is going to 18 be.
19 So, it's -- there's a double reason there 20 for our process as well, not just the topical aspects.
21 MR. KENNEDY: Okay. Thank you. The next 22 topic is deployment site emergency preparedness. So, 23 there's information in Enclosure 1 that talks about 24 standardization in emergency preparedness programs 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
39 micro-reactors.
1 But in Enclosure 3 in the information 2
topic it provides some additional information related 3
to what emergency preparedness looks like for Nth-of-4 a-kind micro-reactors at the deployment site.
5 And so, the regulations in -- the existing 6
regulations in 10 CFR Part 50 and 10 CFR Part 52 apply 7
to micro-reactors of a common design.
8 And the NRC staff is exploring approaches 9
for streamlining the review of emergency preparedness 10 for licensing Nth-of-a-kind micro-reactors based on 11 several considerations. And these include the 12 possibility that potential accidents would result in 13 low doses at the site boundary and, under certain 14 circumstances, might not require extensive offsite 15 response.
16 So, the particular characteristics of 17 micro-reactors come into play here as well as the 18 level of reliance onsite or interfaces with the site 19 and what site-specific factors might need to be 20 considered under emergency preparedness depending on 21 the specific design of the reactor and what can be 22 approved ahead of time in the manufacturing license or 23 design certification or result in a first-of-a-kind 24 licensing proceeding.
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40 VICE CHAIR HALNON: So, just one followup 1
on this because I don't think there's any concern 2
about the classic emergency preparedness.
3 We know it's going to be a lot less 4
impactful than obviously what we used to with the 5
light-water reactors and whatnot. So, that's not a 6
problem.
7 But I would hope that in the conversation 8
that you guys have about emergency preparedness, you 9
talk about maybe the non-classic stuff. I mean, stuff 10 like, you know, we've lost RT sources. People have 11 put them in their pocket and had problems and things 12 like that.
13 I'm not saying that you're going to get a 14 micro -- even though it says "micro," you're not going 15 to put a micro-reactor in your pocket, but there may 16 be some things from an offsite preparedness 17 perspective that may need to be done even though an 18 offsite response is not required.
19 For example, at least some training and 20 other things. You look at those things that are not 21 just licensed-based events, I mean, that's very small, 22 it's not going to be a problem from a dose 23 perspective, but there may be some other things based 24 on reactor-specific issues that could affect at least 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 the offsite locale.
1 So, it may be just a legal discussion from 2
that vantage to make sure that there's nothing that 3
we're introducing that could be harmful to the public, 4
I mean, not deadly or could cause impairment or a 5
response or something to that affect, but still 6
something that may be there that we need to prepare 7
for.
8 MR. KENNEDY: Thank you for your comment.
9 The next topic is streamlined processing of license 10 applications and licensing documents.
11 I won't go into this in depth, but the 12 basic idea is that when you're getting to Nth-of-a-13 kind in licensing the same reactor over and over, 14 you're generating very similar documentation both on 15 the applicant side and the NRC side and there's an 16 opportunity there using additional electronic tools to 17 reduce the processing time frame for these documents.
18 So, unless there are questions, I'll just 19 move on.
20 (Pause.)
21 MR. KENNEDY: Okay. Next is construction 22 inspection. So, as I showed in the deployment model, 23 there is a category or type of designs where the 24 reactor is essentially self-contained and that it'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
42 fully manufactured in a factory or manufacturing 1
facility and then it's transported in one or several 2
containers that are placed at the site and maybe 3
interconnected and then connected to a load and 4
started up.
5 And then there is the other model where 6
the core and perhaps the vessel and some internals are 7
fabricated in the factory and then essentially plugged 8
into permanent structures and systems that are 9
constructed onsite.
10 So, this creates a situation where there 11 will be a need for some inspection activities at a 12 manufacturing facility or where the reactor is 13 manufactured as well as the site.
14 And so, the staff's goal in implementing 15 such an inspection program is to ensure that these 16 inspections can be conducted within the deployment 17 time frames that developers are looking at and that 18 these programs can be put into place in a way that 19 they would take advantage of experience that's gained 20 as the same reactor is manufactured and constructed 21 repeatedly.
22 And so, there are requirements, of course, 23 that I mentioned earlier in Part 52 that before a 24 reactor is placed into operation, the NRC verifies 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 that the ITAAC have been completed or that the reactor 1
is substantially -- sorry, construction of the reactor 2
is substantially complete and ready for operation.
3 And so, these -- so, there's a site-4 specific component as well as a component that would 5
take place at a manufacturing facility.
6 So, there was a SECY paper that was issued 7
last year that was the vision for the Nuclear 8
Regulatory Commission's Advanced Reactor Construction 9
Oversight Program.
10 And so, that considers risk-informed and 11 performance-based approaches. And so, that will be 12 leveraged in developing appropriate inspections for 13 these different types of deployment models.
14 Okay. Finally, consistent with what we 15 did for the SECY paper provided to the Commission in 16 January of this year, we had numerous meetings with 17 stakeholders and the public to discuss the topics that 18 we are considering putting in this paper and then to 19 follow up with information about the potential 20 strategies that we were looking at.
21 And through these meetings we received 22 favorable feedback from stakeholders on the scope of 23 the paper and the options that were being developed.
24 And, again, we anticipate there will 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
44 additional engagement then as the staff implements 1
Commission direction on the paper.
2 We also received a letter from the Nuclear 3
Energy Institute on "Regulations of Rapid High-Volume 4
Deployable Reactors in Remote Applications and Other 5
Advanced Reactors" and there was a presentation by NEI 6
at the subcommittee meeting on their paper.
7 As mentioned, this afternoon we'll be 8
having a public meeting to -- dedicated to discussion 9
of this paper with stakeholders.
10 Then
- finally, next steps.
We're 11 developing a Commission paper based on this draft 12 white paper and we'll be requesting Commission 13 direction on two policy issues.
14 One is the approval of standardized 15 operational programs. The other is options for 16 alternative environmental reviews.
17 And we will include the -- Enclosure 3 on 18 the information topics that support efficient Nth-of-19 a-kind licensing. Several of which include strategies 20 and information that would be useful for enhancing 21 clarity for developers as they continue to work on 22 their designs, licensing strategies and deployment 23 models.
24 So, thank you very much for your time 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
45 for your comments and that concludes the staff's 1
presentation.
2 MEMBER BIER: Okay. Thank you very much.
3 This is Vicki Bier again, subcommittee chair. I 4
wanted to make a couple of quick comments mainly for 5
members of the public who may not have tuned into the 6
subcommittee meeting.
7 The reason that the subcommittee 8
recommended not writing a letter is not because we 9
don't appreciate the importance of Nth-of-a-kind 10 reactors and not because we don't think there could be 11 important safety implications in how that's done, but 12 simply because in the current stage of development 13 where the main choice is between Option 1 and Option 14 2 or whether to allow both options, we didn't see a 15 safety implication at that level that our sense was 16 that either Option 1 or Option 2 could be implemented 17 in a way that protects public health and safety and 18 that the situations where ACRS might have more 19 detailed substantive comments would come later as 20 those approaches are developed in more detail and 21 finalized.
22 So, that's just kind of to lay the land 23 that this is -- looks fine for now, I think, in my 24 personal opinion, but ACRS may obviously have comments 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
46 later on as the process evolves.
1 We had quite a bit of lively discussion 2
already. So, if there is further discussion now by 3
members of the Committee or consultants, I am happy to 4
take that.
5 CHAIR KIRCHNER: Vicki, this is Walt.
6 MEMBER BIER: Great.
7 CHAIR KIRCHNER: I'd like to just make some 8
observations, not questions of the staff.
9 MEMBER BIER: Super.
10 CHAIR KIRCHNER: So, going back to, I 11 think, earlier discussion, Greg and Scott, what I 12 would just note here is that there's a nexus between 13 safety, safeguard, security, and environment. And for 14 the deployment considerations, that's a pretty tight 15 coupling.
16 So, the first-of-a-kind licensing in this 17 instance is the most important because you're going to 18 look at the robustness of the technology that's 19 proposed for deployment. And that's -- the deployment 20 is actually a big challenge for this concept of using 21 micro-reactors. So, let me provide some context and 22 background.
23 40 years ago I led a design team that was 24 tasked with designing a reactor to power radar sites 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 on the arctic circle called the North Warning System.
1 There was a proposal to power 13 sites 2
that strung from Alaska to Greenland with small -- not 3
called micro-reactors then, but small reactors for the 4
radar stations.
5 The biggest challenge that we saw right 6
off was the robustness of the technology for the 7
deployment concept.
8 It included the transportation of the 9
modules, the safe transportation. The presumption was 10 they would be fueled and essentially intact.
11 They had to operate in a very harsh 12 environment and they had to withstand the external 13 hazards that we expect in any reactor deployed to 14 accommodate.
15 So, at the time, just to -- without making 16 a technology recommendation, I'll just say what we 17 consider in the prototype that we built was a TRISO-18 fueled graphite-moderated reactor using heat pipes for 19 the power conversion and thermoelectric. So, 20 essentially a very passive design.
21 We partnered with the AECL. Most of the 22 sites were on Canadian territory and the environmental 23 impact was a major consideration.
24 So, we wanted the minim footprint in terms 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
48 of when you're done with the deployment, any residual 1
contamination, and of course there was the concern 2
about leakage of radionuclides during operation. So, 3
effluents, et cetera.
4 Those were all drivers and considerations, 5
but it turned out the deployment considerations were 6
the biggest.
7 So, when we leave that behind, we did not 8
deploy those reactors at 13 sites. The North Warning 9
System Project was cancelled because technology 10 advanced and we went to satellites instead of fixed 11 radar installations.
12 But, I mean, forward to today, what I 13 would point out is unlike large reactors, including 14 SMRs that are being considered, fixed installations, 15 to first order they're naturally hardened by design 16 and the external hazards and other considerations, 17 manmade hazards and sabotage, are much more of a 18 challenge for a micro-reactor than for a large reactor 19 with large fixed containment shielding and such.
20 So -- and let me give you some examples of 21 considerations and why I feel the first-of-a-kind 22 licensing activity is the most important in going 23 forward with deployment.
24 Small reactors, for example -- I'll just 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 give you a few examples for consideration. Small 1
reactors tend to be leaky because they're small. They 2
are leaking neutronically.
3 So, if you immerse a small reactor, this 4
is a big consideration with small reactors that face 5
applications, they actually -- you add reactivity. If 6
you flood the internals in one of these reactors, you 7
add reactivity in most designs that are being 8
considered.
9 So, flooding in a large LWR, yes, is a 10 concern. You worry about loss of equipment, 11 auxiliaries, and so on, but it doesn't add a 12 reactivity component to the reactor. So, that's just 13 one example.
14 Another example that I point to is that 15 the external hazards like tornado-driven missiles, 16 telephone poles, cars and such are a much bigger 17 hazard for a small reactor that isn't encapsulated in 18 a hard containment like an LWR, et cetera.
19 So, what I would point you to is that the 20 technology selection up front is very critical. You 21 need a very robust design and that robustness should 22 also take into account safeguards and security 23 considerations as well.
24 Fixed
- fuel, for
- example, is much 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 preferable through a liquid fuel system when it comes 1
to safeguards and other related issues.
2 So, all those things, I think, are very 3
important considerations up front. So, I think the 4
first-of-a-kind licensing is the bigger challenge than 5
the Nth-of-a-kind.
6 I think the Nth-of-a-kind becomes a 7
challenge when you look at the individual sites that 8
are considered.
9 So, if the developer, for example, to 10 maximize the opportunity for deployment has to be 11 thinking about things like environmental 12 qualifications.
13 Most -- if you think about a large LWR, 14 most of the equipment is protected within the 15 containment.
16 It's in a hot environment, but it's 17 shielded. So, the environmental qualifications aren't 18 as demanding as they will be for deployment of these 19 small reactors.
20 I'll give you a few examples. Temperature 21 becomes a big issue especially in the Arctic. We had 22 to worry about the reliability and functionality of 23 things like control systems.
24 These systems have similar considerations 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 because they're not -- well, we'll see. We'll see 1
what the developers propose in terms of building fixed 2
installation versus something that's very -- be 3
transported with a modest amount of protection. So, 4
that -- I just want to highlight some of those issues 5
that will be critical.
6 So, in my opinion, again, the first-of-a-7 kind activity, the robustness of the technology given 8
all these considerations, external
- hazards, 9
environmental qualification, diversion of materials, 10 et cetera, are really critical for the success --
11 potential success and deployment at scale.
12 And then the other thing that the agency 13 needs to be considering is the proliferation of risk 14 if there's a large-scale deployment of these -- of 15 this technology and how it's going to protect that.
16 With a large LWR you have -- again, you've 17 got the containment. You've got a large exclusionary 18 or boundary. You have a large guard pro force.
19 I think many of the proponents of these 20 technologies are thinking minimal manning, if not 21 unmanned. We were looking at unmanned operation of 22 those Arctic sites. So, those are the considerations.
23 So, I see the deployment aspects are the 24 harder challenge for the agency than the actual 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 technology itself.
1 Getting to Nth-of-a-kind is -- if the 2
proponents stick to a standard design, as Scott was 3
pointing out, I don't think the Nth-of-a-kind 4
licensing is the issue. The issue is going to be the 5
deployment, the site, and the environmental aspects 6
that go with it presuming you really have a robust 7
technology going forward. So, with that, I'll wind up 8
my comments.
9 MEMBER BIER: Thanks for the comment, 10 Walt. One followup, especially kind of in regards to 11 Bob Martin's comment, is that I think one of the 12 things we see in this whole process is the agency 13 trying to adapt regulations that were developed for 14 large fixed reactors to a totally different context.
15 And if we had started out with 16 manufactured micro-reactors back, you know, several 17 decades ago, the entire regulatory system might look 18 very different.
19 And, you know, we're kind of playing 20 catchup for not having designed this -- the regulatory 21 system with this in mind. So, that's where I think 22 some of the complexities are going to come from.
23 I see that Dennis has his hand raised.
24 DR. BLEY: He does. Hi. A couple things 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 have been eating at me and they don't really apply to 1
the current white paper and whether the Committee 2
decides to write a letter or not -- well, you're not 3
writing one.
4 Walt and Greg kind of read my mind 5
yesterday. Walt talked a little bit about the fact 6
that the reviews of TMI -- well, if you haven't read 7
the Rogovin report and the Kemeny report ever or in 8
the last 20 or 30 years, it's worth going back and 9
reading them.
10 I did a couple years ago and they hit a 11 lot of interesting things, but both pointed to the 12 creation of some problems because there wasn't 13 standardization in the industry.
14 I understand under the law and the rules 15 the staff has to look at any application that comes to 16 them. So, there's no way for the staff to force 17 standardization, but, you know, in a few other 18 meetings it's really become clear that standardization 19 is kind of hard to get to because everybody wants to 20 make some changes and yet everybody, individual 21 applicants, aren't really thinking about -- aren't 22 being controlled by thoughts about how this affects 23 the overall process of licensing.
24 Now, Greg pointed out there's a strong 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 connection between standardization and safety. And I 1
think that's true and the link is, for me, unintended 2
consequences.
3 In the individual members and the 4
chairman's discussions with the commissioners, this 5
might be something to discuss.
6 Somehow making it clear publicly that the 7
lack of standardization involves additional review and 8
complicates the review process, but needs to come 9
across and be understood because there's lots of 10 forces trying to push us to standardization and I 11 suppose economic forces taking us away from that.
12 Maybe it will be different with micro-13 reactors, and Vicki made some really good points 14 there, but I think this is something the Committee 15 needs to think about and think about how they interact 16 with the NRC.
17 They're a statutory committee, which means 18 Congress made you very special compared to all the 19 other committees around the government, and they're 20 really creatures of the legislature, too.
21 So, somehow getting the word out about how 22 this problem -- how this might create problems in the 23 future is important.
24 I don't have an answer for you, but 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
55 think it's worthy of thought in the future as you go 1
forward. It doesn't have anything really to do with 2
what you're doing today. That's all.
3 MEMBER BIER: Thank you, Dennis. And one 4
other thing that I've been thinking kind of just in 5
the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> since our discussion yesterday, if 6
you look at the manufacturing industry across the 7
board, we started off with, you know, you could get 8
any color Ford you want as long as it's black, and you 9
now have mass customization for cars or other consumer 10 product, but it tends to be along very limited lines.
11 You don't get to redesign the chassis when 12 you go buy a Ford. You get to choose the upholstery 13 and the sound system and whatever and it took, I 14 think, quite a long time for industry to develop the 15 management capabilities to manage that mass 16 customization cost effectively.
17 And, you know, it's well beyond our 18 purview as a committee, but I think, you know, 19 industry needs to think about how much customization 20 do they want to allow and can it be kind of pre-21 standardized where you can customize certain things 22 that don't affect the safety and regulation of the 23 plant in a major way, et cetera.
24 So, anyway, that's kind of random comments 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
56 from my last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. But since I'm not in the room, 1
I'm not aware if there are other people wanting to 2
make comments or ask questions right now.
3 CHAIR KIRCHNER: Thank you, Vicki. I'm 4
just looking across the table.
5 Any further comments from the members?
6 MEMBER PETTI: I'll just add to some of 7
yours, Walt. The fact that it's leaky does other 8
things.
9 There's Argon-41 activation that has to be 10 considered, but there's also activation of the 11 surrounding -
12 (Simultaneous speaking.)
13 MEMBER PETTI: -- and the dirt, you know, 14 that you put it on.
15 I mean, that's not a problem with the 16 current fleet, you know. There's plenty of shielding.
17 So, there are these unique -- and that should come up 18 in the environmental stuff, I would think, but, again, 19 it's not something that we standardly think about.
20 So, you have to think about they systems a little 21 differently.
22 CHAIR KIRCHNER: Occupational exposure 23 becomes a challenge --
24 MEMBER PETTI: Yes.
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57 CHAIR KIRCHNER: -- because you get a fair 1
amount of shine from the designs that are being 2
considered vis-a-vis a large LWR system.
3 Obviously, a much larger LWR system has a 4
significant shielding challenge and they deal with 5
that, but it's a fixed installation, so to speak.
6 But from what we've seen to date of the 7
concepts being considered, that will be something that 8
you'll have to look at, occupational exposure and, as 9
Dave pointed out, the activation of the environment as 10 well.
11 These are all manageable things, by the 12 way, so -- but the -- it goes back to the point I was 13 making about having a robust design and looking at all 14 these considerations and it goes beyond just having a 15 mass manufactured module.
16 The deployment is going to be, I think, 17 more of a challenge for the agency than once you get 18 by the first-of-a-kind if the -- if the vendor or the 19 proponent sticks to the standard design, then the 20 attention will quickly shift to the siting issues.
21 MEMBER BIER: Okay. Walt, are there 22 additional questions or comments in the room?
23 CHAIR KIRCHNER: I do not see any at this 24 point. So, Vicki, maybe we should turn to public 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 comment.
1 MEMBER BIER: Yes. I would be happy to 2
take public comments. And, again, I guess if you're 3
online, you should be able to raise your hand. If 4
not, on the phone press *6 and just unmute yourself.
5 Also, please identify yourself before any comment.
6 Yes, Spencer. Go ahead.
7 MS. TOOHILL: Hi, there. Good morning.
8 Can you all hear me?
9 MEMBER BIER: Yes.
10 MS. TOOHILL: Hi. My name is Spencer 11 Toohill. Thank you so much for such a thoughtful 12 discussion so far today.
13 I am an analyst with the Breakthrough 14 Institute and my comment is for efficiency and 15 regulatory stability. We -- I and the Breakthrough 16 Institute are urging consideration of how this effort 17 meshes in context and in timing to the ADVANCE Act 18 requirements related to micro-reactors, as well as the 19 Part 53 development, to avoid creating a situation in 20 the near term that creates new impediments for Nth-of-21 a-kind licensing efficiency in the medium and long-22 term.
23 And just -- well, that was my first 24 comment and then just a brief addition to 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
59 comment.
1 We believe that a generally standardized 2
design, more appropriately referred to as a core 3
design that's not identical, but that still meets the 4
threshold for a note design, is definitely preferable 5
to us and we'd definitely like to see that in the 6
future.
7 We would love to hear any thoughts and any 8
-- share any thinking on these topics would be great.
9 Thank you so much.
10 MEMBER BIER: Thank you for the comment.
11 Any additional public comments?
12 (Pause.)
13 MEMBER BIER: If not, then I think we can 14 be ready to close this session. So, I will hand it 15 back to you, Walt.
16 CHAIR KIRCHNER: Thank you, Vicki. One 17 thing that occurs to me while the staff is still here 18 is, Steve, when does the -- you sent that paper up in 19 January to the Commission.
20 What's the status currently of that?
21 MR. LYNCH: So, at this time the 22 Commission is still reviewing that paper. That is all 23 the status that we have from them.
24 CHAIR KIRCHNER: And do you expect an SRM 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 out of that?
1 MR. LYNCH: Yes, we are expecting -- we 2
provided options to the Commission. We are expecting 3
direction from the Commission when they have completed 4
their review, on how to proceed with factory 5
fabrication considerations and factory testing of 6
micro-reactors.
7 CHAIR KIRCHNER: Thank you.
8 VICE CHAIR HALNON: So, will that be a SECY 9
paper after that? I mean, it seems like they're doing 10 a lot of things in sequence that isn't normal in 11 sequence.
12 I mean, normally they don't give an SRM on 13 a white paper, do they?
14 MR. LYNCH: So, the current paper that is 15 with the Commission is a SECY paper and the strategies 16 that were proposed and recommended to the Commission 17 the staff can implement under its existing regulatory 18 frameworks without needing to go through rulemaking at 19 this time.
20 The white paper that was discussed today, 21 the staff is in the process of converting this into a 22 SECY paper to deliver to the Commission with the 23 recommendations on how to address these items.
24 VICE CHAIR HALNON: And the other items 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 that you have in your last bullet was we're thinking 1
about other steps, too. I assume that it's all in 2
play.
3 When do you anticipate that we might be 4
able to get reengaged to having a further discussion 5
on this?
6 MR. LYNCH: So, I think, and I'll also 7
give my staff an opportunity to weigh in, I think at 8
this point our next stage is looking at how we move 9
forward taking into consideration the direction that's 10 been provided in the ADVANCE Act, because that has 11 introduced some direction on specific topics that the 12 staff had not been focused on such as mobile reactors 13 as they have primarily been in the military space.
14 So, we are currently in the process of 15 assessing how we want to prioritize the next set of 16 topics that we'll be moving forward with. And once 17 we've got that prioritization identified, we can 18 engage with the ACRS and provide some timelines on 19 when we may be engaging on those next topics.
20 VICE CHAIR HALNON: Okay. I'm fairly 21 interested in how the public meeting comes out this 22 afternoon on the NEI white paper, which was quite 23 extensive, known as a real white paper. It's 300 24 pages or so.
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62 So, our next engagement I'd like to see 1
where we're -- maybe a summary of where we're at with 2
that white paper where we deviate from the industry, 3
you know, if we're at any kind of disagreement or 4
maybe strong agreements, so that we stay in line with 5
the manufacturers so that we understand, you know, 6
both the direction of the construction part of the 7
deployment, development and regulatory process because 8
we're beginning 53 -- Part 53 discussions coming up, 9
too, and all these are significant changes to 10 regulations. And we want to make sure that we don't 11
-- we don't collide down the road with something that 12 is doable, but now unconventional.
13 In other words, someone may be on the 14 verge of maybe it's not a micro, maybe it's a small 15 modular, but it's transportable.
16 The more options we give, the less 17 regulatory certainty we're going to have, especially 18 from the timeline of six months or less trying to get 19 these things licensed.
20 So, what I'm concerned about is that we're 21 going to have so many different options that every 22 first-of-a-kind is going to come in with a different 23 pathway.
24 And much like, you know, we put 52 into 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
63 the new reactors, but many are going back to Part 50 1
because it's more familiar to the customer.
2 With Part 53 coming up, maybe someone will 3
want to go under Part 50. So, we're going to continue 4
to give them regulatory paths to licensing and it's 5
going to get confusing, which is what we're in, 6
because right now I think we have Part 52, Part 50, 7
we've got research, test reactors, we have NUREG 1537, 8
all different types of valid pathways.
9 And then we're talking about manufacturing 10 licenses for the micro, we're talking a lot of 11 different things that we're streamlining into existing 12 regulations or writing new ones and just want to make 13 sure that we're not providing this landscape of 14 confusion about where we need to go for this.
15 So, that's why I wanted to stay in tune 16 with where the industry is going. What is their 17 preferred path? Why is it preferred? How is the 18 agency dealing with that and make sure that we don't 19 get into sort of a logjam because we have so many 20 different options.
21 MR. MOORE: Chair Bier, this is Scott 22 Moore, the Executive Director of the ACRS. Just so 23 all the members understand and, Steve, correct me if 24 I'm wrong, I think the staff -- the NRC staff's plan 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 is to send up discrete white papers on specific issues 1
regarding the kind of micro-reactors as they come up.
2 The January paper was the first of those.
3 This would turn into another paper and they're being 4
presented to the Committee's white papers, but they 5
will be turned into SECY papers when they go to the 6
Commission.
7 MR. LYNCH: That is correct.
8 VICE CHAIR HALNON: That makes more sense.
9 CHAIR KIRCHNER: Go ahead.
10 MR. KENNEDY: This is Duke Kennedy. I 11 think maybe in my haste to try to get through this 12 presentation I overlooked one important point, and 13 that is the staff has been working on micro-reactor 14 issues for a number of years.
15 And just over the past two years we've 16 developed and provided the Commission this SECY paper 17 in January that had three policy topics and ten 18 information topics.
19 And now we have this paper under 20 development that has two policy issues and six 21 information topics, but we have another group of 22 topics that we've identified and prioritized.
23 And so, our strategy has always been to 24 look at the -- holistically what are all the micro-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 reactor topics that we know about and work on as 1
industry continues to develop their deployment models 2
and designs.
3 We've been looking holistically what are 4
all the micro-reactor topics that we know about and 5
where do we see the most benefit in getting policy 6
direction at this time with the information that we 7
know?
8 And because there are so many topics, 9
we've had to, as Scott mentioned, bundle them in a way 10 that makes sense so that we're not getting ahead of 11 the state of our knowledge and we're not presenting 12 too many different issues at once to confuse, you 13 know, create additional confusion.
14 So, we're really trying to take a 15 deliberate approach in how we're going about 16 addressing these topics to try to provide clarity to 17 the developers, enhance the reliability of our 18 regulatory processes in a way that meets the immediate 19 needs and the emerging needs and also takes a longer 20 look at, you know, where are we going to be down the 21 road as the landscape continues to change.
22 And so, there are a lot of topics on the 23 table. We've been engaging with the industry and 24 stakeholders frequently on this matter.
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66 In a subcommittee meeting, one point that 1
came up is that although the list of topics that was 2
identified by the industry in its letter is fairly 3
consistent with the list of all topics the NRC staff 4
has also developed and that the NRC staff priorities 5
have aligned well with what the industry priorities 6
are.
7 There's more engagement to be had, of 8
course, and we will continue to do that, but I just 9
want to state clearly that we have a very broad 10 landscape of topics that are taking a deliberate 11 approach to addressing them in a way that doesn't 12 cause more internal conflicts.
13 For example, the SECY that went up in 14 January, those topics and how the Commission decides 15 to vote on them doesn't directly affect the policy 16 topics we're presenting here because we don't -- we 17 want to avoid those conflicts, right?
18 And we also have Part 53 going on and 19 we're making sure we stay consistent with what's 20 happening there as well. So, I just want to be --
21 VICE CHAIR HALNON: Yeah, I appreciate 22 that. That makes me more confident we're not in 23 silos. That was the real point, to make sure we're 24 not in silos.
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67 CHAIR KIRCHNER: Okay. Any further 1
comments?
2 MEMBER HARRINGTON: One quick question.
3 This is Craig Harrington. Do you get the sense from 4
the -- your prior public engagements and maybe from 5
the one this afternoon, that this concept of six 6
months has become -- that industry will become fixated 7
around that and expect that kind of turnaround 8
regardless of how standardized they actually go with 9
the plethora of different paths and is it exactly 10 fixed so that everyone is the same, very cookie 11 cutter, or somebody wants it blue, somebody else wants 12 it green?
13 Do they understand that standardization 14 might get them to six months, but any deviation is 15 going to realistically extend that window? Have you 16 gotten any sense for that? Probably an impossible 17 question to answer.
18 MR. KENNEDY: Obviously, I can't speak for 19 the industry, but in our paper we've tried to be clear 20 that in order to achieve the shortest time frames, 21 that it's going to need to be standardized. There 22 won't be room for departures.
23 I think we've been clear that departures 24 are going to extend time frames and require 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
68 resources for individual reviews, but, again, we're 1
trying to lay out in this paper what are the 2
assumptions, what are the expectations to provide 3
clarity to the industry and what is really needed to 4
achieve these aggressive time frames.
5 And we're not committing to the time 6
frames in the papers -- in the paper. We're laying 7
out thoughts about what types of time frames might be 8
achievable under different circumstances.
9 And so, the goal is to be clear in that 10 communication to industry on what are the assumptions 11 so that they can use that as they develop their 12 licensing strategies and deployment models.
13 MEMBER HARRINGTON: Thanks.
14 CHAIR KIRCHNER: Okay. We've just come to 15 ten o'clock where we would normally take a break, but 16 at this point we will recess until this afternoon and 17 at one o'clock Eastern Time we'll take up our 18 Triennial Review and Evaluation of the NRC Safety 19 Research Program.
20 So, with that, we're in recess until one 21 o'clock and I thank you, NRC staff, for your 22 presentation today, Steve, and your team. Thank you 23 very much.
24 And with that, we are recessed.
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69 (Whereupon, the above-entitled matter went 1
off the record at 10:01 a.m. and resumed at 1:01 p.m.)
2 CHAIR KIRCHNER: Okay. We are back in 3
session. This is the afternoon session of the 720th 4
meeting of the Advisory Committee on Reactor 5
Safeguards.
6 I'm Walt Kirchner, Chair of the ACRS.
7 ACRS members in attendance in person are Ron 8
Ballinger, Greg Halnon, Craig Harrington, Bob Martin, 9
Scott Palmtag, Dave Petti and Tom Roberts.
10 ACRS members in attendance virtually via 11 Teams are Vesna Dimitrijevic and Vicki Bier. And I 12 believe our consultants, Dennis Bley and Steve 13 Schultz, are all with us this afternoon.
14 If I missed anyone, please speak up at 15 this time.
16 (Pause.)
17 CHAIR KIRCHNER: Hearing none, the hearing 18 may proceed. Hossein Nourbakhsh of the ACRS staff is 19 the designated federal officer for this afternoon's 20 opening meeting.
21 Again, a reminder that all member comments 22 should be regarded as only the individual opinion of 23 that member, not a Committee decision.
24 All relevant information related to ACRS 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 activities such as letters, rules for meeting 1
participation and transcripts are located on the NRC 2
public website and can be easily found by typing 3
"About Us ACRS" in the search field on that NRC home 4
page.
5 I'd like to turn to Member-at-Large Dave 6
Petti who has been leading our review of the safety 7
research program at NRC. And with that, Dave, I'll 8
turn the floor over to you.
9 MEMBER PETTI: Thank you, Walt. So, I do 10 have a letter. But before that, I thought I wanted to 11 thank the members that provided the appendices that 12 will be attached to the letter which is really where 13 all the meat is.
14 It's a good, at least, 25 pages, I think, 15 when all is said and done. As we say, it was 11 R&D 16 topics, six different research meetings over the last 17 couple of years.
18 Before I go to the letter, I just wanted 19 to; A, thank Hossein. He was the person that kind of 20 made sure that the appendices have common format, have 21 a common theme and structure. That was a big effort 22 and I wanted to thank Hossein for all of that.
23 Do any of the members who wrote anything 24 on their appendices want to say something about what 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 they've done?
1 (Pause.)
2 MEMBER PETTI: Okay. If not, let's get 3
into the letter.
4
Dear Chair Hanson,
During the 720th 5
meeting of the Advisory Committee on Reactor 6
Safeguards, November 6th through 8th, 2024, we 7
completed our triennial review and evaluation of the 8
NRC safety research program, which is primarily 9
conducted by the NRC Office of Nuclear Reactor 10 Research, RES. Our review also considered deep dives 11 on 11 R&D topics across RES in 16 separate meetings.
12 A summary of each of these deep dives is provided in 13 Appendices to the letter. Our high-level observations 14 are provided in this letter.
15 Executive Summary. The depth, breadth, 16 and scope of the ongoing safety research program 17 continues to meet the Agency's current needs for 18 anticipated regulatory decisions. The research 19 program enables staff to maintain core competencies 20 and prepare for reviews of anticipated submittals. We 21 note that RES has evolved from what was a static 22 reactive organization over a decade ago to a more 23 dynamic forward-looking one. RES uses a systematic 24 approach to prioritize research emphasizing 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 "enterprise risk" in project selection, evaluation, 1
and termination. The use of the future focused 2
research program, the establishment and implementation 3
of integrated action plans, and the recent RES 4
leadership of agency-wide initiatives, are enabling 5
the Agency to become agile and more proactive in 6
preparing for emerging technologies associated with 7
future licensing submittals. The result is an 8
organization that is having greater impact on agency 9
priorities. These activities are all signs of a 10 healthy research organization and should support the 11 Agency's broader efforts to transform itself into a 12 modern, efficient risk-informed regulator.
13 Background. Our research reviews consider 14 the 1997 Commission direction to examine the need, 15 scope, and balance of the safety research program. We 16 also considered how well RES anticipates research 17 needs and how it positions the Agency to understand 18 the regulatory implications of new technologies being 19 developed by industry. In this letter report, we 20 focused our efforts on (a) determining if the RES 21 research portfolio is meeting current and can meet 22 future agency needs and (b) on evaluating the impact 23 that the portfolio is having on the NRC mission.
24 NRC research activities include conducting 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 confirmatory analyses, developing technical bases to 1
support safety decisions, and preparing the agency to 2
evaluate the safety aspects for new technologies.
3 Through this process, staff competencies are improved, 4
and agency transformation is facilitated.
5 Discussion. The research report -- of the 6
report highlights selected high-level findings from 7
our deep dives of the following research projects:
8 Source term-related activities; digital twins; 9
materials harvesting; Level 3 PRA; risk assessment and 10 human factors for non-LWRs; artificial intelligence; 11 fuel fragmentation, relocation, and dispersal; 12 advanced manufacturing technologies; artificial 13 intelligence and machine learning in NDE and ISE; 14 computer code development and validation for non-15 light-water reactors and high energy arc faults.
16 These deep dives span the three RES 17 divisions: Division of Risk Analysis; the Division of 18 Safety Analysis; and the Division of Engineering.
19 Summaries of our detailed findings, conclusion, and 20 recommendations are provided in the Appendices.
21 Overall, the portfolio looks well-balanced 22 and appropriate in light of the major regulatory 23 challenges facing the Agency over the next three to 24 five years: Subsequent license renewal; higher-burnup 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
74 higher-enrichment fuels for the current fleet; and 1
advanced non-LWR reactor licensing applications. We 2
note the work on HEAF has been completed resulting in 3
not only improved modeling approaches, but also plant 4
maintenance and design recommendations to enable 5
reducing risk from HEAF events. Beyond these general 6
observations, we provide comments on the following 7
five themes that arose repeatedly during our meetings:
8 focus and communication; engagement; education; 9
impact; and future activities.
10 Focus and Communication. We observed 11 excellent linkage between the NRR staff, focusing on 12 their needs, and the RES staff managing the projects.
13 This linkage enhances communication and allows for 14 focused mission-driven research that will provide the 15 greatest probability of success in terms of 16 actionable/impactful results for regulatory decision 17 making and NRC safety review activities.
18 Engagement. We observed that the research 19 personnel are well-engaged with parallel activities 20 underway in industry (e.g., EPRI, ASME, IEEE). This 21 engagement helps the research team have a more 22 complete understanding of industry plans and allows 23 industry to appreciate the corresponding regulatory 24 needs for any anticipated upcoming licensing actions.
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75 The engagement also helps the research team not 1
duplicate industry activities, but instead perform the 2
confirmatory research necessary from a regulatory 3
perspective.
4 Education. The research portfolio is 5
helping the NRC staff become better informed about new 6
technologies that industry is considering using, 7
through
- example, artificial intelligence/machine 8
learning for inspection; digital twins; 9
additive/advanced manufacturing; and new reactor 10 technologies in future applications by industry in a 11 deeper way, building useful experience and expertise 12 for the staff. Other projects such as the Level 3 PRA 13 and the work being done on nonreactor risk 14 applications are providing unique insights and a 15 plethora of risk data that will serve the agency well 16 as it becomes a modern risk-informed regulator and 17 begins to use risk in decision making beyond the realm 18 of power reactors. The development of reference plant 19 models for each of the advanced reactor technologies 20 has been extremely valuable for the staff to 21 understand these systems in advance of licensing 22 applications. Today, the staff is ready to perform 23 confirmatory analysis for anticipated near-term 24 advanced reactor applications. This will require 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
76 agreement of continued financial commitment from NRC 1
for the codes and DOE for the underlying computational 2
framework to meet current anticipated licensing 3
timelines. Because experience informs judgment, 4
developing this experience is critical in light of the 5
large turnover in the staff, and it supports the 6
agency's overall knowledge transfer. The quality of 7
research staff that we heard from in our deep dives is 8
excellent.
9 Impact. The RES research portfolio is 10 having real impact on regulatory decision making and 11 reducing unnecessary uncertainty in technical areas 12 including: Providing the technical basis for source 13 terms from MELCOR severe accident calculations to 14 support an upcoming revision of Reg Guide 1.183; 15 supporting regulatory decisions by performing scoping 16 calculations using RES developed non-LWR system 17 analysis tools for advanced reactor applications like 18 Hermes; highlighting potential safety issues via 19 synthesis of the existing database associated with 20 FFRD in a timely manner as the industry plans for 21 higher burnups and higher enrichments and as the staff 22 is working on rulemaking language associated with 23 higher enrichment fuels for the current LWR fleet; 24 informing Part 53 operator training requirements 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 through human factors research; leveraging unique 1
irradiated materials samples (a/k/a harvesting) to 2
support vessel embrittlement database and associated 3
regulatory evaluations; developing the technical bases 4
for informing NDE and inspection activities using 5
machine learning and artificial intelligence; and 6
resolving an important safety issue associated with 7
high energy arc faults, a real success story 8
illustrating how research can impact safety decisions.
9 Future Activities. Some projects that are 10 just starting, for example, digital twins, AI, 11 additive manufacturing, appear reasonable and should 12 provide impact in out years. Other projects like the 13 non-LWR code development require additional efforts 14 related to verification and validation and 15 transformation into useful evaluation models to 16 support confirmatory analyses in support of efficient 17 and timely NRC reviews of anticipated non-LWR license 18 applications. Updates to LWR source terms and the 19 impact of FFRD at higher LWR burnups on licensing 20 options are also anticipated as part of the increased 21 enrichment rulemaking. We look forward to additional 22 briefings on these topics as the results become 23 available. Sincerely, Walt.
24 I can see some words need help. When you 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 read it out loud, it's never like reading it -- just 1
reading it.
2 CHAIR KIRCHNER: Thank you, Dave.
3 Members, this is a little bit unusual 4
because typically, in the
- past, we've had 5
presentations from Research and we intentionally chose 6
to forego that and just cut to the bottom line.
7 So, the discussion that was going on in 8
the background is we're going to release the court 9
reporter. So, is there any high-level comments that 10 you want to make before we go to line-by-line review?
11 I think this would be an appropriate time 12 to make those comments, and then I would turn and 13 afford the public an opportunity to make any 14 observations or comments as well.
15 So, members?
16 VICE CHAIR HALNON: The only thing I would 17
-- Dave, is there any of the -- and I didn't go 18 through the appendices in detail. So, I apologize for 19 that, but is there any high-level findings or 20 conclusions that we buried into the -- in the 21 appendices that may warrant raising it up because it's 22 a very glowing, nothing is wrong, everything is cool.
23 And if you start with the letter, it seems like 24 there's -- it's just all rainbows and unicorns.
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79 MEMBER PETTI: Not of things we haven't 1
written a letter on. So, we don't -- I'd say, what, 2
maybe half of these resulted in a letter and that's in 3
the appendix.
4 VICE CHAIR HALNON: Should we mention that 5
letters have already been written on these then and --
6 MEMBER PETTI: On some of them.
7 VICE CHAIR HALNON: On some of them that 8
highlight our major --
9 MEMBER PETTI: Maybe that would be --
10 CHAIR KIRCHNER: Are there references that 11
-- for example, Bob wrote a letter on the code 12 development work. Is that referenced here in the 13 references and should we highlight that one? That's 14 one that comes to mind, Greg, in terms of --
15 MEMBER MARTIN:
Conclusions, 16 recommendations and stuff that may look like a normal 17 format of our letters.
18 CHAIR KIRCHNER: Microphone.
19 MEMBER MARTIN: Sorry. I think just that 20 the letter had a traditional form of conclusions, 21 recommendations, to kind of address Gregs point 22 there.
23 VICE CHAIR HALNON: Maybe not anything 24 specific, but we can say throughout this process 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
80 wrote letters on our more significant interactions or 1
something to that effect.
2 MEMBER PETTI: Yeah, yeah, yeah.
3 VICE CHAIR HALNON: Okay.
4 CHAIR KIRCHNER:
I know that Dave 5
highlighted that HEAF and -- I would just observe that 6
when I joined the Committee now eight years ago, we 7
were -- we had presentations from Research. They were 8
more -- they were informative about the problem.
9 It looked like a topic that, from a 10 research standpoint, was almost intractable. And what 11 was done by Research, I think, is just -- just first-12 rate piece of work to address that.
13 There was a lot of concern, I think, from 14 the industry and other stakeholders that the Agency 15 would go off on some tangent and I think Research 16 actually did an excellent job in coming up with 17 methods to address this in a practical way.
18 So, that's one that Dave already cited in 19 the letter and you did put in a note about the 20 continued support for the code development.
21 And as they go through V&V, are there any 22 others, in light of Greg's comment, that we should 23 highlight further? Anything that comes to mind from 24 your perspective?
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81 MEMBER BALLINGER: I was -- the FFRD thing 1
I thought worked out pretty well. I actually made a 2
few changes today because of my initial thoughts on 3
what they were going to do with the increased 4
enrichment.
5 Now, they're going to choose Option 2.
6 So, I went and changed it so that it wasn't -- I'm 7
saying I think you made --
8 (Simultaneous speaking.)
9 MEMBER BALLINGER:
I wasn't that 10 enthusiastic about the NDE and the AI stuff and I said 11 so in the letter in my response because I think that 12 nowadays -- and I actually confirmed this last week.
13 I was at the EPRI NDE center. I talked to 14 Greg Selby, but we're down to the point now where 15 everything is controlled by the microstructure.
16 We have enough resolution so that the 17 microstructure pretty much defines it and we're 18 basically in the soup over CAS materials. We can't 19 really do much with CAS materials.
20 And so, I was kind of hoping that they 21 would say something about if you make false-positive 22 calls, that costs you money. If you make false-23 negative calls, that costs you downtime because you 24 can get a failure of that.
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82 And so, they didn't say too much about 1
that in there, but I don't know that they were 2
supposed to. So, I kind of went off on a bit of a 3
tangent when I wrote --
4 MEMBER PETTI: You know, I didn't take it 5
as a negative. You highlighted, you know, some 6
concerns that --
7 MEMBER BALLINGER: Yeah. Okay.
8 MEMBER PETTI: -- they'll have to be aware 9
of.
10 MEMBER BALLINGER: Yeah.
11 MEMBER PETTI: Because, again, this was 12 still pretty early in their research. It's --
13 MEMBER BALLINGER: The AI and the NDE stuff 14 was just a survey. They hired PNNL, I guess, to just 15 go out and survey what's been done and what commercial 16 packages are available.
17 And then they did some evaluations and 18 there was no real research part of it, I don't think, 19 other than doing the survey.
20 VICE CHAIR HALNON: The other comment that 21 I had, just a question, do you think that we gave 22 enough press to maintaining the funding as necessary?
23 That was -- seemed to be a theme of the 24 supervisors and branch chiefs, whatnot, that 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
83 amount of funding needs to continue flowing to us to 1
keep --
2 MEMBER PETTI: It's said twice now.
3 VICE CHAIR HALNON: Is it?
4 MEMBER PETTI: It says, in the future 5
activities, acquire additional efforts, but then the 6
funding I mentioned earlier that it required a 7
continued commitment or something.
8 VICE CHAIR HALNON: Okay. I was looking 9
and I couldn't find it.
10 CHAIR KIRCHNER: Do we have --
11 MEMBER PETTI: I added that right before we 12 started lunch. So, depending on --
13 (Simultaneous speaking.)
14 MEMBER BALLINGER: By the way, I'm not sure 15 what kind of research they could do in the area of 16 NDE. That's being done by industry.
17 MEMBER PETTI: Right. Well, I mean --
18 MEMBER BALLINGER: So, other than doing 19 another survey and evaluating things, I'm not sure 20 what they can do.
21 MEMBER PETTI: I think it was just to get 22 smarter about what's out there --
23 MEMBER BALLINGER: Yeah, okay.
24 MEMBER PETTI: -- to know what industry 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
84 doing. I mean, you know, we didn't see anybody 1
duplicating what industry was doing.
2 MEMBER BALLINGER: Yeah.
3 MEMBER PETTI: I mean, they're very well-4 aligned, you know.
5 MEMBER BALLINGER: Yeah.
6 MEMBER PETTI:
These items that I
7 highlighted was just at one of the meetings. I kept 8
jotting the same sort of comments down. Boy, these 9
guys, they're well-linked. They, you know, they --
10 remember we had people -- they had brought in -- they 11 had industry colleagues in sometimes, you know.
12 From a pure research perspective, someone 13 who's read a lot at the R&D organization, I mean, 14 these are the things you want to look at, you know.
15 You're not duplicating it, you know what the issue is, 16 that you're focused, and it's not just research for 17 research's sake, you know. It supports the mission.
18 I mean, all those things, I just kept 19 seeing them over and over again and that's what made 20 me think that this is sort of a letter. And then if 21 people are interested, they can go onto each of the 22 appendices for the specifics.
23 We have changed how we've done this letter 24 substantially, you know.
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85 CHAIR KIRCHNER: Yeah. For the newer 1
members, we previously would do, candidly, just like 2
a repeat and it was voluminous.
3 MEMBER PETTI: 80 pages was not uncommon.
4 CHAIR KIRCHNER: Yeah. Repeat of a 5
summary of all the research that is being conducted 6
without any really critical assessment of -- we did 7
identify, in the past, things that we thought should 8
be terminated, that -- where a continued investment 9
wasn't going to be a payoff for the Agency, but what 10 Dave has done here, I think, is a marked improvement 11 in focusing into the future and addressing relevance 12 and need for the Agency to be prepared.
13 I mean, one of the large words that we had 14 from the research presentations was, you know, 15 "readiness" particularly in the areas like code 16 development so that they would have the tools on hand 17 to be able to do the kind of confirmatory analysis 18 necessary. And to that extent, they've done quite 19 well, I think.
20 MEMBER PETTI: I mean, to me, that, the 21 HEAF work and the FFRD and source term, I mean, you 22 know, they've done quite a bit of work and those are 23 major initiatives.
24 MEMBER BALLINGER: You know, we didn't say 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
86 it, but that FFRD stuff is resulting and will result 1
in a sea-change in the way industry approaches 2
accident analysis because of the new burst and all 3
that kind of stuff.
4 It really has made a huge impact on the 5
way people have especially with increased 6
enrichment. So, that's a -- that may have been an 7
unintended consequence of pointing out FFRD, but it 8
sure is making a difference.
9 MEMBER MARTIN: I think the unintended 10 consequences apply to HEAF also. That EPRI wanted to 11 develop maintenance improvements make HEAF less likely 12 because the problems were shown to be a big deal.
13 MEMBER BALLINGER: Yeah.
14 MEMBER MARTIN: Not necessarily because of 15 the research, but it's tied to the research.
16 MEMBER PETTI: Vicki?
17 VICE CHAIR HALNON: Dennis was up first.
18 MEMBER BIER: You can let Dennis go first 19 if he wants. That's fine.
20 MEMBER PETTI: Okay.
21 DR. BLEY: I don't particularly want, but 22 I will. You've touched on something that, you know, 23 the Commission often addressed us about where can we 24
-- where is the research finished, in your opinion, 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 and where should we stop spending money and it seems 1
we just touched on that lightly.
2 I don't know if you found anything else, 3
but that would have been something to elevate up into 4
the main report if, in fact --
5 MEMBER PETTI: So, I did have something in 6
there in Matt's area, the material harvesting. Not 7
that it's not adding value, but a cost benefit.
8 It's expensive to do and given all the 9
data we have on vessel embrittlement, you know, in 10 that broad effect, is it worth spending money there?
11 MEMBER BALLINGER: I'm glad I didn't -- you 12 didn't ask me to write something -- you didn't ask me 13 to write something on that because it would not have 14 been complementary, especially with the new 15 correlations that are --
16 MEMBER PETTI: Yeah.
17 (Simultaneous speaking.)
18 MEMBER BALLINGER: The old correlations, 19 that 1.99 stuff, that correlation was going to go 20 south on us and have influence, but the new one 21 doesn't and it's way past eight years. So, we're --
22 I don't know why we need to take more samples.
23 MEMBER PETTI: So, I mean, if you think 24 about, I mean, if people feel that way, I can put 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
88 sentence back in. I had it in an earlier version.
1 MEMBER BALLINGER:
- Yeah, these are 2
extremely expensive.
3 MEMBER PETTI: Yeah, for sure.
4 MEMBER HARRINGTON: I wasn't here to 5
participate in that discussion, but was the harvesting 6
presentation from Research directly focused on vessel 7
integrity or was it much broader than vessel integrity 8
because the industry regulatory collaborative 9
activities worldwide on harvesting are much broader 10 than just vessel integrity.
11 A continuing effort very broadly to look 12 at the full range of materials issued and any time a 13 plant is being decommissioned it's looked at. Is 14 there something here of value?
15 And so, those are highly-leveraged 16 projects across a number of organizations.
17 MEMBER PETTI: I'm just looking at the 18 writeup. I don't know that Matt's on it. There was 19 some cable, electrical cable, which is a big deal.
20 And we had a comment about availability of splices.
21 Staff reported that in some cases 22 documentation for the harvested materials is 23 nonexistent, difficult to retrieve or has no longer 24 been retained by the owner. Loss of the pedigree 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 diminishes its value, you know.
1 And it says research conducted using 2
harvested materials continues to be a relatively 3
expensive, opportunistic endeavor, not necessarily 4
systematic regarding strategic needs or priorities; 5
however, RES has been able to participate in a few 6
projects.
7 Research on harvested unique rated 8
materials can be leveraged to improve industry 9
initiatives such as vessel embrittlement and other 10 life limited components.
11 So, maybe I don't want to say anything 12 because materials harvesting is too broad and this is 13 a subset of that. But if questioned, we could bring 14 up the embrittlement example, but another area that's 15 still very valuable. Depends on what the problem is, 16 I guess.
17 DR. BLEY: This is Dennis. I have one 18 other comment. I like Dave's letter and I like the 19 emphasis on high-energy arc faults, but I just wanted 20 to mention that some years ago after we had then 21 enthusiastically supported the staff's work on HEAF, 22 NRC cut it out of the budget for a number of years 23 before it came back in -- NRC -- the Commission cut it 24 out of the budget for a few years.
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90 CHAIR KIRCHNER: Vicki?
1 MEMBER BIER: Thanks. I wanted to get back 2
to Greg's question about is this really like unicorns 3
and candy and if -- looking at the first sentence on 4
line 148, I don't have any expertise on additive 5
manufacturing.
6 With regard to both digital twins and AI, 7
I don't disagree with the sentence that we have, but 8
I would describe it as polite. And that if you look 9
at the actual situation especially in the AI area, the 10 staff is very limited by personnel and budget.
11 And, yes, they are doing reasonable things 12 that may have impact, but they are very incremental 13 and very dependent on work done by other agencies or 14 the national labs or whatever that have bigger budgets 15 to address it.
16 And so, I don't know if it's worth 17 revising to make that sentence more critical because 18 I don't know that I would necessarily argue for huge 19 budgets in those areas, that there's a reason the 20 staff is constrained by budget, but it's just 21 something to think about that, you know, given the 22 limitations of budget and personnel, there may not be 23 huge impact and the agency is going to kind of 24 continue being dependent on other actors with greater 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 resources.
1 CHAIR KIRCHNER: Vicki, this is Walt. I 2
would concur with you. I mean, let's pick one.
3 Digital twins. I mean, this is something that the 4
private sector actually has made large investments in, 5
but was even as far back as 10 or 15 years ago called 6
"big data" and ties into AI and machine learning.
7 So, maybe some of the words you just used 8
are appropriate there to, you know, Research often can 9
do a number of things and Dave, in earlier sections of 10 the letter, touches on this.
11 Sometimes it's maybe a modest investment 12 in these areas, is just necessary for educational 13 purposes and keeping the staff informed and, you know, 14 up to speed with what's going on in the private sector 15 or in the labs and universities.
16 So, maybe we can temper that sentence with 17 some of the words that you just used.
18 MEMBER BALLINGER: I took notes.
19 MEMBER BIER: Yeah.
20 MEMBER BALLINGER: In all of those areas, 21 they're only going to be able to keep up with what's 22 going on, what's educational, so that they understand 23 the lingo when somebody comes in and says, here's what 24 we're doing.
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92 CHAIR KIRCHNER: Right, and the state of 1
the art and so on, but not necessarily doing --
2 MEMBER PETTI: A watch and review, but they 3
should -- gosh. They should have enough knowledge to 4
be able to ask questions that are probing enough to 5
get an answer that's meaningful.
6 They should, you know, not super -- they 7
shouldn't be just superficial, but they should be a 8
little bit better than that so that they can 9
understand what's going on and ask probing questions.
10 MEMBER BIER: Yeah. And I think, from that 11 perspective, what the staff is doing is reasonable for 12 that purpose.
13 They are getting their feet wet. They're 14 playing around. They're learning about what's going 15 on elsewhere. They're trying things out and, you 16 know, getting to a position where they can evaluate 17 those kinds of issues, but it's not going to be 18 impactful compared to what the labs are doing or 19 industry or other groups. So --
20 MEMBER PETTI: We can deal with that line 21 by line.
22 CHAIR KIRCHNER: Thank you, Vicki. Other 23 comments? Dennis, I think your hand is still up or 24 it's back up.
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93 DR. BLEY: It's back up and I had trouble 1
getting my mic open. There's one area and, Dave, I 2
might have missed it.
3 Back just before Obama left office, he 4
issued an executive order requiring all the agencies 5
to look at geomagnetic storms and figure out the 6
impact on the things they regulate.
7 The last we heard on that there was some 8
kind of interagency research work looking at 9
geomagnetic storms that -- did you talk about that at 10 all or should that be something that the Committee 11 might prod the staff on where they stand now on what 12 kind of things could be significant to the industry?
13 MEMBER PETTI: Yeah. We didn't hear 14 anything about that. So, it's worth putting on the 15 list, I guess.
16 MEMBER BALLINGER: If you get aviation 17 fleet like I do, you'll discover that there was a lot 18 of work going on in that and all of a sudden it got 19 classified --
20 MR. MOORE: This is Scott Moore.
21 (Simultaneous speaking.)
22 MEMBER BALLINGER: Gone.
23 MR. MOORE: So, yeah, you make a good 24 point. My understanding is that the Office 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
94 Research wasn't doing that kind of work. I think 1
Office of Nuclear Security Incident Response has 2
followed up on that topic.
3 CHAIR KIRCHNER: Okay. At this point, 4
let's turn to see if there is any members of the 5
public who wish to make a comment.
6 If so, please unmute your mic and state 7
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9 (Pause.)
10 CHAIR KIRCHNER: Hearing none, then, 11 James, our court reporter, I think we are finished 12 with you for this afternoon and we'll look forward to 13 you joining tomorrow morning at 8:30 Eastern Time.
14 Thank you.
15 (Whereupon, the above-entitled matter went 16 off the record at 1:37 p.m.)
17 18 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
Licensing and Deployment Considerations for Nth-of-a-Kind Micro-Reactors Advisory Committee on Reactor Safeguards November 6, 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
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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 2 (ML24302A292)
Environmental Reviews 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 November 6, 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.