Text

Advanced Reactor Stakeholder Meeting December 12, 2024 Master Deck Slides.Final
	ML24344A289
Person / Time
Issue date:	12/12/2024
From:	Hughes A, Subbaratnam R; NRC/NRR/DANU/UARP
To:	;
References
	Download: ML24344A289 (74)
	v • d • e

Advanced Reactor Stakeholder Public Meeting December 12, 2024

Time Agenda Speaker 10:00 - 10:15 am Opening Remarks NRC 10:15 - 10:45 am ADVANCE Act Section 207 - Combined License Review Procedures NRC 10:45 - 11:30 am CNSC-NRC Memorandum of Cooperation: Joint Report on Classification of Structures, Systems, and Components NRC 11:30 am - 12:00 pm NEI White Paper Discussion on Selection of a Seismic Scenario for an EPZ Boundary Determination NEI/NRC 12:00 - 1:00 pm LUNCH 1:00 - 3:00 pm ADVANCE Act Section 203 - Nonelectric Uses of Nuclear Technology NRC/DOE 3:00 - 4:00 pm Risk-Informed, Performance-Based Regulatory Approaches NRC 2

Time Agenda Speaker 4:00 - 4:15 pm Public Comment Period Public 4:15 pm Closing Remarks/Adjourn NRC

Opening Remarks

Advanced Reactor Program Highlights

Recent Accomplishments:

Issued construction permits for the Hermes 2 test reactor facility to Kairos Power LLC on November 21, 2024

Updates:

Comment period for Part 53 proposed rule closes on 2/28/25. Publication of the final rule is expected by 4/30/2027, ahead of December Nuclear Energy Innovation and Modernization Act (NEIMA) deadline.

Policy paper on nth-of-a-kind licensing expected to be released in early 2025

White paper of draft regulatory guide endorsing NEI 22-05, Technology Inclusive Risk Informed Change Evaluation (TIRICE) to be issued this month. Public meeting to follow in early 2025

White paper of policy paper on alternatives to Part 53 Framework B to be issued this month. Public meeting to follow in January.

Upcoming Public Meetings:

Discussion with NEI on Operator Cold License Training December 19 from 10 a.m. - 12 p.m.

Part 53 Public Meeting January 8 - 9 5

Regulatory Frameworks and TechnicalApproaches to Ensure Appropriate Qualification and Through-Life Performance of Non-Light Water Reactor Materials General qualification Qualification of advanced manufacturing technologies, graphite, and composites General through-life performance Through-life performance of advanced manufacturing technologies, graphite, and composites The NEA Working Group on New Technologies (WGNT) is developing a report on qualification and through-life performance of NLWR materials. The report will include workshop conference proceedings and summarize best practice attributes for addressing regulatory needs.

Workshop time and location: June 3-5, 2025, in Rockville, MD (hybrid option available)

The call for abstracts has been released Topics Tentative Timeline To receive the call for abstract, be included on future distributions, or for more information, please contact ryann.bass@nrc.gov and wendy.reed@nrc.gov Feb. 17, 2025 - Abstract submission May 12, 2025 - Paper submission May 28, 2025 - Presentation submission June 3-5, 2025 - Workshop July 21, 2025 - Final paper submission 2026/2027 - Report completed

ADVANCE Act of 2024, Section 207 Combined License Review Procedure (2) shall propose to construct the new nuclear reactor on a site (A) on which a licensed commercial nuclear reactor operates or previously operated; or (B) that is directly adjacent to a site on which a licensed commercial nuclear reactor operates or previously operated and has site characteristics that are substantially similar to that site; and (3) may not be subject to an order of the Commission to suspend or revoke a license under section 2.202 of title 10, Code of Federal Regulations (or any successor regulation).

ADVANCE Act of 2024, Section 207 Combined License Review Procedure (c) EXPEDITED PROCEDURE.With respect to a combined license for which the applicant has satisfied the requirements described in subsection (b), the Commission shall, to the maximum extent practicable (1) not later than 18 months after the date on which the application is accepted for docketing (A) complete the technical review process and issue a safety evaluation report; and (B) issue a final environmental impact statement or environmental assessment, unless the Commission finds that the proposed agency action is excluded pursuant to a categorical exclusion in accordance with the National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.);

ADVANCE Act of 2024, Section 207 Combined License Review Procedure (2) not later than 2 years after the date on which the application is accepted for docketing, complete any necessary public licensing hearings and related processes; and (3) not later than 25 months after the date on which the application is accepted for docketing, make a final decision on whether to issue the combined license.

ADVANCE Act of 2024, Section 207 Combined License Review Procedure (d) PERFORMANCE AND REPORTING.

(1) DELAYS IN ISSUANCE.Not later than 30 days after the applicable deadline, the Executive Director for Operations of the Commission shall inform the Commission of any failure to meet a deadline under subsection (c).

ADVANCE Act of 2024, Section 207 Combined License Review Procedure (2) DELAYS IN ISSUANCE EXCEEDING 90 DAYS. If any deadline under subsection (c) is not met by the date that is 90 days after the applicable date required under that subsection, the Commission shall submit to the appropriate committees of Congress a report describing the delay, including a detailed explanation accounting for the delay; and a plan for completion of the applicable action.

NRC Staff Plans to Address ADVANCE Act Section 207

The NRC staff has initiated seeking stakeholder input on an expedited review procedure for COL applications.

The NRC staff plans to conduct a comment-gathering meeting in early 2025.

The NRC staff is considering issuing a Regulatory Issue Summary to address the requirements in Section 207.

NRC Public Website for ADVANCE Act of 2024

To Stay Informed of Progress Follow NRCs ADVANCE Act implementation with this Dashboard

For Upcoming and Past Meetings For NRCs public meeting information on ADVANCE Act 15

For Your Questions and Ideas Contact us with ADVANCE Act questions, comments and ideas 16

Steve Jones Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation CNSC-NRC Memorandum of Cooperation:

Joint Report on Classification of Structures, Systems, and Components 18

AGENDA

Work Plan

Scope of Safety Classification Project

Findings Safety Significance Determination Classification of Structures, Systems, and Components Engineering Design Rules and Specifications

Use in Application Development 19

WORK PLAN OBJECTIVES

Identify key similarities and differences in the safety significance determination process, the scope of SSCs subject to the process, and the process outcomes

Identify key similarities and differences in the engineering design rules and specifications applied to each safety class and how this impacts the outcomes

Review how each organization applies existing codes and standards and interacts with Standards Development Organizations (SDOs) to verify appropriate codes and standards are being developed, applied, and endorsed.

20

SCOPE

New Water-Cooled Small Modular and Advanced Non-Water-Cooled Reactors

Safety Significance Determination and SSC Classification 21

Design rules and specifications Reliability Programs SSC Design Hazard Protection

REGULATORY BACKGROUND 22

CNSC places detailed requirements in license

NRC has more detailed regulations Many regulations specific to LWRs Exemption process provides flexibility

SAFETY ANALYSIS APPROACHES 23 Element CNSC NRC Traditional NRC LMP Use of PRA Level 2 -

Complementary to deterministic analysis Level 1 - Confirmatory and identification of risk insights Level 3 - Foundational; supported by deterministic analyses Defense in Depth Structured defense-level review Established by design criteria and special regulations Structured review of capabilities and programs Safety classification Applicant designated classifications of important to safety SSCs; safety systems selected for accident mitigation Safety-related SSCs selected to mitigate accidents; important to safety for defense in depth functions Safety-related SSCs selected to mitigate accidents; nonsafety-related with special treatment for defense in depth functions Accident Classification Sequence frequency Guidance (Qualitative assessment)

Sequence frequency

SAFETY SIGNIFICANCE DETERMINATION 24 Similarities and Differences AOO Baseline/ GDC 13/ LMP essentially the same AOO conservative analysis captured among LMP DBEs DBA analysis methods reasonably consistent LMP dose/consequence target at DBE/BDBE boundary inconsistent with CNSC DBA dose criterion NRC Traditional Approach limiting LWR analyses (LOCA, GDC 28 reactivity accidents, maximum hypothetical accident [MHA], and regulated events) help with DID in absence of quantitative risk criteria Containment bounding analysis (maximum hypothetical accident - MHA) for traditional NRC vs. mechanistic DBA (CNSC and LMP)

CNSC Design Extension substantially overlaps with NRC BDB regulations and LMP BDBE analysis

SAFETY CLASSIFICATION 25

CNSC Safety System performs DBA prevention/mitigation function like NRC Safety-Related

Risk-informed NRC classification schemes better aligned with CNSC graded classification

Safety classification has more prescriptive relationship with engineering design rules under NRC regulations than under CNSC.

SPECIAL TREATMENT SCOPE 26 Special Treatment Similarity Important Considerations Quality Assurance Substantial Improved by NRC risk-informed programs Operational Reliability High Identical for TSs; risk-based availability monitoring scope for CNSC; flexible testing and condition monitoring scope supports alignment Pressure-Retaining High Similar quality group definitions Electrical / I&C High Same types of electrical and I&C components Civil Structures High Structures perform identical functions Seismic Qualification Moderate CNSC qualifies more defense-in-depth SSCs Fire protection High Similar goals to control and confine fires Environmental Qualification High Similar definitions of required scope

SPECIAL TREATMENT EXTENT 27 Special Treatment Similarity Important Considerations Quality Assurance Substantial Appendix B more prescriptive; NRC &CNSC support graded application of QA measures Operational Reliability High Similar programs for availability, performance, and condition monitoring; ASME Code ISI/IST Pressure-Retaining High Equivalent reliance on ASME Code Electrical / I&C High Many overlapping IEEE and IEC standards Civil Structures Substantial Overlapping standards; but many country-specific standards as well.

Seismic Qualification High Similar qualification process and standards Fire protection High Overlapping standards and program goals Environmental Qualification High Overlapping standards

USE IN APPLICATIONS 28 Compliance with regulatory requirements:

Good agreement on design criteria (Appendix A of report)

CNSC approach flexibility supports alignment of SSCs with highest safety significance to those classified as safety-related (risk-informed classification)

CNSC design-extension aligned with NRC special regulations and LMP BDBEs Defense-in-depth:

Evaluation necessary to ensure NRC traditional approach supports structured defense-level evaluation

LMP aligns with CNSC; provides structured evaluation Assignment of design rules:

Significant commonality in scope and extent of design rules supported by many shared standards

Conservative use of Appendix B to Part 50 for quality assurance of SSCs with highest safety significance (Appendix B of Report)

Justification of seismic qualification scope and civil structure standards may be necessary

AVAILABILITY OF JOINT REPORT 29 Expected to be available on NRC and website December 2024 Availability will be under the following link:

https://www.nrc.gov/reactors/new-reactors/advanced/who-were-working-with/international-cooperation/nrc-cnsc-moc/joint-reports.html

Response to NRC Comments & Questions on Subject NEI White Paper

©2024 Nuclear Energy Institute 32 Please discuss how the approach can be implemented at the construction permit stage The design of the SSCs will already be at the stage where a margin assessment can be performed. This being the case, the fragility parameters will be available that are needed to perform the calculation of C10%. This will be shown in a Tabletop.

Level-3 PRA is not required. All that is needed is a source term and dose calculation model that can be set up to evaluate the specified seismic scenario (plant damage state). This will be shown in the Tabletop.

Comment/Question #1

©2024 Nuclear Energy Institute 33 Please discuss (i) appropriateness of C10% criterion (2 x GMRS), and (ii) assumption that any SSC that has C10% capacity greater than 2 x GMRS is considered fully successful (i) is shown to be appropriate through the detailed analysis provided in Section 5 of the NEI White Paper. As explained, a holistic consideration of the insights from past SPRAs with knowledge of the safety improvements in new plant designs indicates that a scenario based on 2 x GMRS adequately represents the conditions where emergency response should be required.

(ii) is based on the approach approved by NRC for use in the assessment of seismic MSA per R.G. 1.226, which endorses NEI 12-

06. The use of the C10% as a pass-fail criterion for success is a fundamental part of Appendix H of NEI 12-06.

Comment/Question #2

The check for cliff edge effects is discussed in Section 10 of the NEI White Paper. The scenario (plant damage state) will add the additional failures of any SSCs whose C10% is within 10% of 2 x GMRS. This captures the concept of what would be the impact on the results of a step increase in the earthquake severity.

This will be illustrated in the Tabletop.

Comment/Question #2 (continued)

It will be stated that the GMRS to be used is that specified in R.G.

1.208, i.e., a site-specific, performance-based GMRS, satisfying the requirements of paragraphs (c), (d)(1), and (d)(2) of 10 CFR 100.23, and leading to the establishment of an SSE to satisfy the design requirements of Appendix S to 10 CFR Part 50.

This is what was used as the basis for the evaluations in the NEI White Paper.

Comment/Question #3

©2024 Nuclear Energy Institute 36 It is not clear why the cut-o of 1.0g PGA is needed and is appropriate for sites with higher seismicity. In addition, PGA, as a ground motion measure, is by itself, not a good determinant for damage.

As discussed in Section 6 of the NEI White Paper, there is a need to establish some upper severity above which Emergency Planning is not practical, accounting for the post-earthquake status of the necessary infrastructure to support implementation.

While PGA is used as a common reference point for ease of understanding (which has always been the practice), all of the analysis done for the NEI White Paper used the entire spectral shape.

Comment/Question #4

Comment/Question #5 (1/3)

©2024 Nuclear Energy Institute 40 Please provide examples that show how the C10% criterion is applied at a cutset level, how a plant damage state is determined, and how the doses were calculated. The examples should also include evaluation of cli-edge eects.

This will be illustrated in the Tabletop.

The examples should include sensitivity studies considering various design options under the non-LLWR RIPB based seismic design.

We believe that the single design example in the Tabletop will be adequate to demonstrate the approach.

Comment/Question #6

A single scenario.

This will be demonstrated in the Tabletop.

Comment/Question #7

ANL_NSE-21-56 does not actually propose an approach, but rather investigates using a PRA-based margin assessment for the purpose of determining the challenges, opportunities, and next steps.

ANL and NEI have been exchanging information, and the NEI White Paper was one input to ANL_NSE-24-42, the next steps from ANL_NSE-21-56 are currently in draft.

ANL_NSE-24-42 proposes to use the same 2 x GMRS and C10% as its check on cliff-edge effect. This is the base case for the NEI White Paper, which has then a further, stricter cliff-edge check.

Difference is that ANL_NSE-24-42 is intended to develop plant-level safety insights per Part 53; the NEI White Paper is intended to identify the single scenario required for EPZ determination.

Comment/Question #8

NuScale considers their approach to be proprietary and has chosen not to make it available to NEI or other industry organizations.

As a note, we expect that the NuScale approach (while it could probably be adapted to other designs in some way) was designed specifically for use with that design. The NEI White Paper is intended to be technology neutral with regard to any light-water or non-light-water SMR.

Comment/Question #9

The NEI White Paper is not a stand-alone document for compliance with 10 CFR 50.160. The result is simply one input into the overall risk-informed, performance-based approach to emergency planning described in NEI 24-05.

The white paper is limited to describing the approach to defining the seismic scenario and plant damage state to be used in the overall assessment (i.e., it feeds into Chapter 4, Section 4.3.4, of NEI 24-05 as an Alternative Hazard Event).

All other interfaces with the rule are handled identically to the other EPZ scenarios as described in NEI 24-05.

Comment/Question #10

The approach in the NEI White Paper is only for the purpose of determining the boundary of the EPZ.

The need for changes would be addressed in accordance with Section 5.1 of NEI 24-05, Maintenance of Performance -

50.160(b)(1)(i).

Comment/Question #11

Discussion

47 LUNCH BREAK Meeting will resume at 1:00 pm EST December 12, 2024 Microsoft Teams Meeting Bridge line: 301-576-2978 Conference ID: 765 241 117#

ADVANCE Act Section 203 Nonelectric Uses William Reckley Ryan Mott December 12, 2024

Scope of Meeting

Accelerating Deployment of Versatile, Advanced Nuclear for Clean Energy (ADVANCE) Act of 2024

#ADVANCENRC Todays Discussions

Section 203 - Licensing Considerations Relating to the Use of Nuclear Energy for Nonelectric applications

Seeking insights into unique licensing issues or requirements

Added to stakeholder meeting agenda on November 28, 2024

To Stay Informed of Progress Follow NRCs ADVANCE Act implementation with this Dashboard

For Upcoming and Past Meetings For NRCs public meeting information on ADVANCE Act 51

For Your Questions and Ideas Contact us with ADVANCE Act questions, comments and ideas 52

Section 203 - Nonelectric Applications ADVANCE Act § 203.

LICENSING CONSIDERATIONS RELATING TO USE OF NUCLEAR ENERGY FOR NONELECTRIC APPLICATIONS.

- General Issues

- Specific Applications

- Framework (a) IN GENERAL. Not later than 270 days after the date of enactment of this Act, the Commission shall submit... a report addressing any unique licensing issues or requirements relating to (1) the flexible operation of advanced nuclear reactors, such as ramping power output and switching between electricity generation and nonelectric applications; (2) the use of advanced nuclear reactors exclusively for nonelectric applications; and (3) the colocation of nuclear reactors with industrial plants or other facilities.

Section 203 - Nonelectric Applications Key Topics Siting

- Onsite. Within boundaries of NRC licensed facility.

- Offsite. In proximity to but outside boundaries of NRC licensed facility.

Routine operations (effluents)

Postulated accidents

Section 203 - Nonelectric Applications BACKGROUND - Licensing and Siting Nuclear Plants

Reactor Design Reviews

Light-Water Reactor (LWR) Standard Review Plan (NUREG-0800)

Non-Light-Water Reactor (non-LWR) Advanced Reactor Content of Applications Project (ARCAP) Roadmap (ISG-DANU-2022-01)

Plant Systems Designed Considering External Hazards

- Natural Hazards (e.g., seismic, flooding, winds, precipitation)

- Constructed Hazards (e.g., industrial, military, transportation)

Siting Considerations

Site Characteristics - External Hazards

Population Considerations

Environmental Reviews

Section 203 - Nonelectric Applications ADVANCE Act § 203.

LICENSING CONSIDERATIONS RELATING TO USE OF NUCLEAR ENERGY FOR NONELECTRIC APPLICATIONS.

- General Issues

- Specific Applications

- Framework (c) CONTENTS.

(1) IN GENERAL.The report under subsection (a) shall describe (A) any unique licensing issues or requirements relating to the matters described in paragraphs (1) through (3) of subsection (a), including, with respect to the nonelectric applications referred to in paragraphs (1) and (2) of that subsection, any licensing issues or requirements relating to the use of nuclear energy

- for specific applications

Section 203 - Nonelectric Applications ADVANCE Act § 203.

LICENSING CONSIDERATIONS RELATING TO USE OF NUCLEAR ENERGY FOR NONELECTRIC APPLICATIONS.

- General Issues

- Specific Applications

- Framework (c) CONTENTS.

Specific applications under (c)(1)(A):

i.

for hydrogen or other liquid and gaseous fuel or chemical production; ii.

for water desalination and waste water treatment; iii.

for heat used for industrial processes; iv.

for district heating; v.

in relation to energy storage; vi.

for industrial or medical isotope production; and vii.

for other applications, as identified by the Commission

Section 203 - Nonelectric Applications ADVANCE Act § 203.

LICENSING CONSIDERATIONS RELATING TO USE OF NUCLEAR ENERGY FOR NONELECTRIC APPLICATIONS.

- General Issues

- Specific Applications

- Framework From DOE report Pathways to Commercial Liftoff: Advanced Nuclear

Section 203 - Nonelectric Applications ADVANCE Act § 203.

LICENSING CONSIDERATIONS RELATING TO USE OF NUCLEAR ENERGY FOR NONELECTRIC APPLICATIONS.

- General Issues

- Specific Applications

- Framework (c) CONTENTS.

(1) IN GENERAL.The report under subsection (a) shall describe (B) options for addressing those issues or requirements i.

within the existing regulatory framework; ii.

as part of the technology-inclusive regulatory framework required under subsection (a)(4) of section 103 of [NEIMA]; or iii.

through a new rulemaking;

Section 203 - Nonelectric Applications ADVANCE Act § 203.

LICENSING CONSIDERATIONS RELATING TO USE OF NUCLEAR ENERGY FOR NONELECTRIC APPLICATIONS.

- General Issues

- Specific Applications

- Framework (c) CONTENTS.

(1) IN GENERAL.The report under subsection (a) shall describe (C) the extent to which Commission action is needed to implement any matter described in the report.

(2) COST ESTIMATES, BUDGETS, AND TIMEFRAMES.The report shall include cost estimates, proposed budgets, and proposed timeframes for implementing risk-informed and performance-based regulatory guidance in the licensing of nuclear reactors for nonelectric applications.

Risk Informed Performance Based Regulation Ryan Mott Jackie Harvey Advanced Reactor Policy Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities https://www.nrc.gov/reactors/new-reactors/advanced.html December 12, 2024

Content

Background

Development of the RIPB Approach

Current Approach

Questions 63

=

Background===

The purpose of this presentation is to provide an overview of the NRCs risk-informed, performance-based (RIPB) approach to regulation for advanced reactors.

The NRC uses this approach for regulatory decision-making for advanced reactors.

The NRC continues to welcome feedback on the topic and aims to engender an open dialogue with stakeholders.

64

Development of the RIPB Approach 1997

- SRM, January 22, 1997. Commission decision to include performance-based strategies as part of the risk-informed regulatory decision-making process (SECY-96-218) 1999

- SRM, March 1, 1999. Commission approves publication of white paper describing RIPB framework (SECY-98-144) 2006

- SRM, June 1, 2006. Commission instructs Staff to adopt implementation plan to reach a holistic, risk-informed and performance-based regulatory structure. (See: SECY-06-0217, SECY-07-0074) 65

Development of the RIPB Approach Deterministic Risk-Informed Prescriptive Performance-Based 66

Current Approach with the Advanced Reactor Program

Risk-informed and performance-based

Does not entirely replace deterministic and prescriptive approaches

Flexible, holistic approach

E.g., ARCOP, Part 53, functional containment and ARCAP/TICAP A risk-informed, performance-based regulation is an approach in which risk insights, engineering analysis and judgment (including the principle of defense-in-depth and the incorporation of safety margins), and performance history are used, to (1) focus attention on the most important activities, (2) establish objective criteria for evaluating performance, (3) develop measurable or calculable parameters for monitoring system and licensee performance, (4) provide flexibility to determine how to meet the established performance criteria in a way that will encourage and reward improved outcomes, and (5) focus on the results as the primary basis for regulatory decision-making.

(1999 White Paper) 67

Questions?

68

Traditional deterministic and heavily Risk-Informed (LMP) should be OK Risk - Informed NEI White Paper: Technology-Inclusive, Risk-Informed, Performance-Based Approaches Sept 2021

Performance - Based Prescriptive (Current Proposed Part 53)

More Performance-Based (NEI Proposals)

Performance-Based (Informed by NUREG-0303) 53.450(a) requires PRA assessing internal and external hazards Current draft comment suggests a Risk Evaluation allowing flexibility to use PRA or other risk-informed and/or performance-based methods.

Subpart B - Technology-Inclusive Safety Requirements defines Performance-Objectives (currently including Part 20, traditional DBA - 25 rem, and comprehensive risk metrics).

Analysis methodologies in Subpart D to meet those criteria are not needed and can be handled in guidance 53.530(c) prescribes siting away from population centers regardless of risk profile Current draft comment suggests deleting prescription including 25,000 in 53.020 population center distance definition Dose requirements in Subpart B would be informed by siting which can be considered in guidance.

Much more information on these topics in the February 2021 Part 53 Industry Concerns and Alternative (ML21042B889),

December 2020 Industry Comments on Part 53 Rulemaking (ML20363A227), and the October 2020 Industry Comments on Part 53 Rulemaking Plan

Open Discussion 72

Public Comments

Closing Remarks

ML24344A289

Text

=

Navigation menu

Search