ML25058A125
| ML25058A125 | |
| Person / Time | |
|---|---|
| Issue date: | 02/11/2025 |
| From: | NRC/OCM |
| To: | |
| References | |
| NRC-0212 | |
| Download: ML25058A125 (150) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Meeting on Application of Commercial Codes and Standards by Advanced Reactor Vendors and Applicants Docket Number:
(n/a)
Location:
teleconference Date:
Tuesday, February 11, 2025 Work Order No.:
NRC-0212 Pages 1-151 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
1 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 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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MEETING ON APPLICATION OF COMMERCIAL CODES AND STANDARDS BY ADVANCED REACTOR VENDORS AND APPLICANTS
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- TUESDAY, FEBRUARY 11, 2025
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The meeting was convened via Video conference, at 1:00 p.m. EST, Ramon L. Gascot, Facilitator, presiding.
PRESENT:
RAMON L. GASCOT, Facilitator CHRISTIAN ARAGUAS, NRC JOSEPH BASS, NRC CHRISTOPHER COOK, NRC RAJ IYENGAR, NRC
2 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 ALSO PRESENT:
BEN BEASLEY, Abilene Christian University JASON CHRISTENSEN, Idaho National Laboratory DON EGGETT, Eggett Consulting STUART KELLNER, Westinghouse Electric Company JAMES ROLL, X-energy JACK SHOEMATE, Natura Resources STEVE UNIKEWICZ, TerraPower
3 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 CONTENTS Welcome and Introduction...........................4 Opening Remarks....................................7 NRC Perspectives on the 2023 ASME Section III Division 5 Endorsement and Technical Considerations for Application of Commercial Standards...........20 Perspectives from Abilene Christian University and Natura Resources..............................38 Perspectives from X-Energy........................50 Results from the Advanced Reactor Codes & Standards Collaborative Needs Assessment....................69 Perspectives from TerraPower......................84 Perspectives from INL Staff and NRIC on the Application of DOE Standards......................98 Perspectives from Westinghouse-eVinci Microreactor..............................117 Open Discussion..................................129 Closing Remarks..................................130 Adjourn
4 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 P-R-O-C-E-E-D-I-N-G-S (1:01 p.m.)
MR. GASCOT: Good afternoon. I want to thank everyone, and thank you for participating in today's public meeting, Application of Commercial Codes and Standards by Advanced Reactor Vendors and Applicants.
My name is Ramon Gascot. I'm from the NRC Office of Nuclear Regulatory Research and will serve as the facilitator for today's meeting.
This is an information meeting with a question-and-answer session. The purpose of this meeting is for the NRC staff to meet directly with individuals to discuss regulatory technical issues.
After this, we will have the opportunity to ask questions of the NRC staff and make comments about the issues discussed, but we ask the applicants to wait until the end of the presentation.
Each presenter will have fifty minutes for his presentation, and then in a Q&A session of five minutes.
At the end of the meeting, we will have an open discussion session, where questions can be answered as well.
The purpose of today's meeting is identify
5 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 priorities, commercial non-nuclear consensus codes and standards used by the Advanced Reactor designers, vendors, and applicants, that are currently not endorsed by the NRC in any regulation, or guidance.
Information regarding priority codes and standards under active development is highly encouraged.
For this meeting, we are using Microsoft Teams.
To minimize distractions during the meeting, we ask everyone to please mute themselves when they're not speaking, and to do our best to not speak over each other.
To facilitate the discussion during this meeting, we request to utilize Price & Fisher in Teams, so we can identify who will speak next. The staff or myself will then ask their question.
Please raise the hands button, which is located at the -- it's the mod-shaped hand located at the top of the Teams display area. You can also use the chat to alert us if you have a question.
If you joined the meeting using the Microsoft Teams bridge line, we will like you to ask your question or provide your comment. You'll need to press the [Star][6] to unmute your phone, and then
6 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 to mute yourself back. So, if you want to ask a question and you're on the bridge line, you'll use the [Star][6]
to mute or unmute yourself.
For today's meeting, as I mentioned, using the chat, I put ML number of the slides so it's already public available in our ADAMS system, so you can download -- The ML number will be ML25042H (as a letter) 089 (ML25042H089).
Today's agenda, we will start with Christian Araguas and Chris Cook. They will talk about our action items on the advanced codes and standards of the NRC, followed by Joseph Bass and Raj Iyengar.
They will talk about the perspective of the 2023 ASME Section III Division 5 Endorsement and Technical Considerations for application of Commercial Standards.
After then, jack Shoemate and Ben Beasley will talk about the Perspectives of the Abilene Christian University and Natura Resources, followed by James Roll and the Perspectives from X-Energy.
And following the last session of our first block of this meeting will be Don Eggett. He will talk about the Advanced Reactor Codes and Standards Collaborative Needs Assessment Survey.
We will take a break around 2:40 -- from
7 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 2:40 to 3:00.
After the break, Steven Unikewicz will talk about TerraPower's perspectives, followed by Jason Christensen, talking about the Perspectives from INL and the application of DOE standards.
And the last meeting for today will be Stuart Kellner and the Perspectives of Westinghouse, eVinci Microreactors.
After this meet with Stuart Kellner presentation, we will have an open discussion, and closing remarks will be around 4:25, 4:30, depending on how many questions we need to answer.
This meeting also will be transcribed and the transcript will be available after the meeting.
Now, without further ado, I will turn to Mr. Christian Araguas, NRC Standards Executive and Division Director of the Division Engineering of the Office of Nuclear Regulatory
- Research, and Dr. Christopher Cook, which is a Special Assistant to the NRC Standards Executive, with some open remarks and his presentation. Thank you.
MR. ARAGUAS: Thanks for that, Ramon. And let me just do a check. Can everybody hear me?
(Simultaneous speaking.)
MR. ARAGUAS: Good to go there, so thanks.
8 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 So, first, I just want to welcome everybody to the NRC's public meeting, as you heard on the Application of Commercial Codes and Standards to Support Advanced Reactors.
And I want to thank everybody for their flexibility on accommodating the change to an all-virtual meeting. With the impending whether that's coming here this afternoon, we felt it was prudent to get out ahead of that early last week, or I guess late last week but early for this week, and really to accommodate people's change in plans.
And so, special thanks to our presenters and putting them in a precarious position to kind of have to change their plans on the fly. So, thanks again for that.
And so, with that, as you saw Ramon highlighted, we've got a packed agenda with a really, really tight time line to get through. So, I'm going to try to move us quickly with some opening remarks.
And Ramon, if you can move us to the next slide.
So, to start with sort of the obvious, why are we here? And as we all know, for the last several years we've seen a resurgence in the desire for new nuclear, to address the rapidly increasing energy
9 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 demands across the country.
We see it all over the news, even recently, with increased desire. And so, these designs that are being developed are significantly differently, as we know, from the large light water reactors and operation, and that they use a variety of different coolants, and operate at much higher temperatures, among several other differences that I won't obviously cover here.
And so therefore, the NRC has been aggressively working to update our regulatory framework to support timely and efficient licensing of these designs to enable their future use and deployment.
And that brings us to today's meeting, where the NRC is focused on enhancing our Codes and Standards Program in support of these Advanced Reactor technologies.
So, while the existing Codes and Standards Program has served us well over the past, we know that today's endorsed standards are predominantly focused on large light water reactor designs, and predominantly rely on deterministic approaches.
In addition, many of today's endorsed standards don't facilitate efficient construction, or the rapid large-scale deployment envisioned by today's Advanced Reactor developers.
10 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 So, the staff recognized the evolving desire for endorsing more technology-inclusive codes and standards that accommodate the diverse landscape of nuclear innovations, particularly those for advanced reactors.
So, by promoting innovative solutions to endorse high-priority codes and standards, we believe an enhanced NRC program could ensure that the regulatory frameworks remain relevant, timely, and effective.
And so, to that end we developed an action plan that we are working to implement to help realize the necessary changes to our program.
And Chris Cook, who you'll hear from shortly, he's a branch chief in my division and is doing a fantastic job spearheading our efforts to enhance our Codes and Standards Program.
And so, that kind of brings us to his presentation. You're going to hear a light touch about the action plan that we have. But really, you're going to hear a more focused attention on one of the specific items, which gets to really canvassing the industry on what are the needs and commercial standards space, and really taking that input today and what may come after this, and helping to prioritize our activities and how we engage in the various SDOs and how we
11 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 prioritize our resources.
So, with that, Chris Cook, I turn it to you.
MR. COOK: Very good. And Christian, you can hear me okay, correct?
MR. ARAGUAS: Yes, I can. Thanks.
MR. COOK: Fantastic. Thank you so much for that. And Ramon, if you could please go to the next slide.
So, as Christian mentioned, I'm going to be setting the stage for this particular meeting that we're having today.
And in the backdrop for all that is the codes and standards plan that the NRC issued in August of 2024. That action plan was developed with a broad input from stakeholders, primarily through a workshop that we held on April 4th that was there.
And what we came away from was really a great bit of work that helped us to identify seventeen different items that fall into three different program areas that could really be used to enhance the Codes and Standards Program.
The Codes and Standards Program at the NRC has been ongoing for a long time. So, this is not something new, but we really realized that enhancements
12 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 needed to be made in order to improve things for new and advanced reactors.
Those three program areas you can see sort of in the figure on the left, development process improvements, endorsement enhancements, and leveraged commercial standards.
These seventeen items were to help the NRC really focus on increasing timeliness, efficiency, and promoting the risk-informed, performance-based activities, and really to help the agency move forward with licensing.
The different action items as well have three different time frames. Some are swift actions, meaning that they're supposed to be completed in 2025, others are intermediate activities going on until 2027, and then program enhancements that are ongoing.
If anyone's interested in reading the action plan and looking at all the items, I put the ML number there on the screen so you can see it.
But the focus for today is really to be talking about codes and standards and prioritization of those standards.
And there were two action items that really deal with prioritization of effort for the NRC to be looking at what codes and standards we're going to be
13 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 really focused in on for this effort.
One of those was under the development process improvement that was action plan item 1.1.
And that was really our traditional standards.
And then there was action item 3.1, which falls under the leveraged commercial standards. And that's the purpose of today's meeting, is to really kick off that action item and to talk about what that particular action item means. Go to the next slide, Ramon? Thank you.
So, today's meeting, and what we're going to be talking about, is action item 3.1. As I mentioned, it actually falls, there are three buckets -- swift actions, intermediate actions, and program enhancements. This falls into the swift action category. So, something for us in 2025.
And I thought it was important to sort of show the text that is from that action plan, the MLs on the previous slide, so you could sort of see the exact specifications with requirements that we put in there about what this action plan item was about.
As you can see, it discusses alternatives to the traditional nuclear-specific standards. It also was talking about then commercial standards that in a number of them were identified in the April 4th
14 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 meeting that we had.
On page 3 of the action plan, you can see where I've highlighted leveraging the commercial non-nuclear consensus standards that were there.
And then on page 6, you can see where we had our tables that were in there. We have action plan item 3.1 and 3.2. And they are sort of linked together.
So, 3.1, which is the focus today, so listed out again, commercial standards, but then it also says underneath that was guidance from research organizations, and also guidance from nuclear-focused non-standard organizations. And I think a lot of us were thinking of DOE at that point in time.
So, from this action plan really, there are a couple of key words that I just wanted to point out on. You can see the word "alternative,"
"traditional," it's an alternative to the traditional.
So, the traditional ones were action item 1.1. These were alternatives to that commercial research organizations, and nuclear-focused standards from not your typical standards organizations.
Okay, so that's the guiding framework that we had. So, next slide.
So, I think when the April 4th workshop concluded, everyone in the room had a sense of what
15 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 we meant by the phrase, "commercial non-nuclear standards," as we wrote down and as was captured in the meeting, and then as we put into the action plan.
However, when it came time for us to start implementing this and thinking about really the specifics of what are commercial standards, or what are the traditional ones, we really found that it was important to add some clarity and to define it a little bit better.
What we found talking about it internally was that some staff would put certain codes and standards into action plan 1.1, and others would put it into 3.1.
And so, this is where we wanted to come up with discussion and a definition that we're going to be using for this.
And it was one of the key things that we wanted to get across in this public meeting, was to sort of let everyone else know what we were using for the definition of "commercial non-nuclear standards,"
for action item 3.1, with all the rest of them that are sort of our more traditional, going into that action item 1.1.
So, Ramon read a bit of this, but I'll just highlight again the words so you can see in front of
16 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 you, this is really a catch-all phrase for the alternative traditional standards NRC has endorsed through regulation or guidance. So, that's straight from the action plan.
You can also see its importance. It was identified numerous places. And as you'll be seeing by the speakers today that I think have done a great job of identifying a lot of codes and standards that they're looking at that would fall in this category, it's very important for us to be looking at commercial standards.
Specific standards that we think would fall into this category are, of course, standards and guidance published by research organizations, ANS 2.6.
I just picked out that particular ANS standard because it seems to be having a lot of discussion these days.
Also, guidance used for the design and construction of the demonstration facilities that are going on with DOE; ASME,Section VIII, as well as the B31 series that are there; their whole suite of civil construction standards that were in there; and then also sort of general construction standards that would be used for critical infrastructure. This is what you'd use for hospitals and other critical infrastructure.
17 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 So, that's really our definition of this particular action item. These are the codes and standards that would fall underneath it. All right, next slide, please.
So, with that as sort of the background of the definition for what we're looking at in this public meeting today, I had reached out and I've discussed this definition with all the presenters.
So, hopefully -- and I think we are looking at their slides, we're all sort of on the same page regarding the definition that we're using that's in there.
And I think it really gets to, now, the importance of this action plan item, why we're doing this.
It's one of the things that's been emphasized over and over, is that the whole idea of us looking at this topic and doing it -- the premise, if you will, for why this is important -- is because we feel that if we're able to make sure that NRC staff and participants are participating in the standards workgroup meetings.
That is really the preferred place to be hashing out technical differences that exist and those technical concerns.
If we can try to hash those out there, that
18 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 is probably the best place for it, versus later, after the standard is complete. It's hard to change a standard then.
And even seemingly minor things, like definitions and assumptions, can lead to delays, miscommunications later, when the NRC tries to endorse it. And endorsing a standard is actually, it can be a very time-consuming process for us to do. A clean regulatory guide.
I've talked about this with a number of people in the public. Summary actor vendors don't really understand that endorsing a standard via a reg guide, all the steps that are involved in developing that reg guide.
For us to do that takes quite a bit of time because of the controls that are in place for that.
When we develop a draft reg guide, in addition to do that we also develop a regulatory analysis. There's a Federal Register notice, there are advisory committees, such as ACRS, that we need to go to.
And that's just for the draft. Then we have public comments, we have to resolve the comments, and then the whole cycle starts over again for us to get that developed and out.
19 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 So, it can take us, moving efficiently on it, a year to several years to develop a regulatory guide.
And so, this is why having something that's clean -- a clean endorsement -- is beneficial. I think it reduces the delays that could be in there, and really hashing out any details in the committee is the ideal place for that.
So, with that sort of as a preamble for why we're meeting today and what we're discussing, I also asked a number of the speakers to talk about examples where they think that commercial standards, how well it's worked to date.
I think some of the presenters today actually have examples that are relevant where they have some lessons learned on that and would be good to pass on to everyone, about how that went and what that did.
So, I asked to talk about the challenges and also how they've overcome. So, accomplishments.
And then finally, I just wanted to remind all the speakers, we have a number of advanced reactor developers and vendors here today that have applications and things before the NRC.
Just remind everyone that the activities
20 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 and examples, please only discuss items that are resolved. This is not a meeting to discuss any items that are currently under review by the staff.
So, I think that's my last side, Ramon.
So, I'm going to turn it back over to you. Thank you very much.
MR. GASCOT: Well, now we have Joe Bass and Raj Iyengar regarding the slides I'm working on.
I got the email from the processing center that is public-available that I was working on. So, probably by the end of the meeting we will have the slide book.
So, you're on, Raj.
MR. IYENGAR: Yeah, wonderful. Thank you so much, Ramon. Thank you, Christian and Chris.
Good afternoon, I'm Raj Iyengar, from the Division of Engineering, Office of Nuclear Regulatory Research and RC.
I'm very honored to serve at the NRC, especially during this exciting time of advancing the nuclear energy future with safe and sound advanced reactors.
It's also gratifying to be a small contributor to relative topics related to advanced reactor deployment and licensing, including the codes and standards initiative for advanced reactors.
21 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 Today, my colleague Joe and I will highlight some staff accomplishments that fulfill some of the commitments made in the action plan to enhance NRC codes and standards. Next slide, please.
Since the issuance of NRC vision's clarity and implementation action plan a while ago to license and regulate advanced non-light water reactors, staff has fully realized many of the actions to dissent.
Pertaining to the topic of interest in this presentation today, staff has proactively engaged in the assessment of technical issues and regulatory impacts related to the application items and materials and components for advanced reactors.
Why? Because material selection and qualification for new designs, a long lead and design-limiting concentrations. We need quite sometime beforehand to resolve these things.
Staff has made significant progress through issuance of technical reports on molten salt compatibility, high-temperature materials and component integrity, graphite performance, and assessment of ASME code related to materials qualification and performance. These efforts enable building a solid and sound knowledge base.
The QR code on the side can take you to
22 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 many of our reports. Staff completed an expansive and independent assessment of the ASME Section III, Division 5, design and construction rules for items and materials, resulting in the first endorsement of the 2017 ASME Section III, Division 5.
Staff developed computational assessment tools for confirmative reviews of high-temperature, metallic and graphite components, based on ASME design rules, to enable staff efficient review of licensing actions.
And these tools can also be used to verify alternative approaches to materials qualification, based on render-specific design.
Staff engagement with code committees and workshops enable building new capabilities in advanced materials for high-temperature applications, and support identification resolution of key challenges.
So, what does this all buy us? These preparatory efforts advance staff foundation knowledge of advanced materials and components for high-temperature reactors, facilitating the staff's focus on operation safety and components, with an understanding of risk mitigation and uncertainty reduction.
Further, these efforts resulted in updated
23 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 2023 ASME code for Section III, Division 5, through an experienced student and experience-based approach.
I'm glad to note that we completed this updated proposed endorsement expeditiously, under a year, with optimal resources.
I want to add that the current endorsement is not a mere delta update from the previous endorsement. Rather, as Joe will detail, the staff has endorsed construction rules for composite materials for the first time.
In addition, the current endorsement also includes staff perspectives on alternate approaches to Non-Destructive Evaluation of certain components.
This endorsement was included in the current draft reg guide, within an extremely short period of time after the relative code case was issued by ASME.
Understanding the interest from various vendors and potential licensees in the use of commercial non-nuclear codes, staff is exploring the use of such codes commensurate with safety and risk.
To the same, Joe will highlight a couple of examples that may open the aperture and appetite for safe use of commercial non-nuclear code for advanced reactors.
24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com With this, I want to pass it on to Joe to provide additional details. Thank you so much.
MR. BASS: Thanks so much, Raj. Next slide? All right.
On this slide, I'll be touching on some of the activities the NRC staff are taking in order to accelerate endorsement of code and standards.
The NRC understands the value of fast, effective, and efficient review, our working code space, and the subsequent development of regulatory guidance and regulations, as a path towards improving our ability to review applications and work with vendors.
By understanding the methodologies within the code and understanding how the codes are evolving, we able to reduce code review time and accelerate code endorsement.
While the NRC staff are heavily engaged with multiple codes and standards, I'm familiar with the work in the ASME Boiler Pressure Code,Section III,
- 5. So, this discussion will mainly focus there.
But there are many other codes and standards within the NRC that the staff are pursuing.
By heavily engaging in the development of codes and standards, we provide ourselves with multiple
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 advantages. That allows NRC staff to provide the code committees with input from the regulatory perspective.
In addition, by being part of the process for updating the codes, we know what changes are in the next edition of the codes, and the lift for updating our regulatory guidance is substantially reduced.
This is because the NRC staff has a better understanding of why the code changes are made and enables the NRC staff to better understand the basis that the committees use to make these changes.
By keeping on top of the changes and the code, we're able to identify topics where the NRC staff may benefit from additional information.
As the industry looks to new materials, fabrication methodologies, risk-informed approaches and other topics, we need to have a solid technical basis for regulatory decisions.
One method the NRC staff uses to address this is through development of technical reports.
These support our ability to update our endorsement and provide industry with the NRC staff's current understanding of new and important topics.
As Raj mentioned, a QR code is provided in the previous slide, which is a link to the Library of Technical Letter Reports provided by the Office of
26 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 Research. Next slide, please?
I'll be discussing how we accelerated our endorsement of Section III, Div. 5, and Regulatory Guide 1.7. But before that, I want to provide some background on this reg guide.
Regulatory Guide 1.7 provides the NRC staff's endorsement of Section III, Div. 5, of the ASME Boiler Pressure Vessel Code for non-light water reactors.
Section III of the ASME contains the rules for nuclear construction, and Div. 5 contains the rules for high-temperature reactors.
It should be noted that this is a regulatory guide, which means that it presents one possible avenue to meet the regulations, and following the rules within Section III, Div. 5, is not a requirement.
Later in this presentation, I'll be discussing what the NRC staff is doing for non-nuclear codes. But please note that Section III, Div. 5, is a nuclear code, according to the definitions discussed previously.
The NRC staff had originally endorsed the 2017 edition of Section III, Div. 5, and Regulatory Guide 1.87, Rev. 2.
As Raj mentioned, this was a substantial
27 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 effort where the NRC hired multiple contractors, including National Laboratories and other technical experts, to provide information which would be helpful for the endorsement.
The Reg Guide, Rev. 2, was published in 2023 and took around four years.
After Rev. 2 was published, the NRC staff sent the ASME a letter expressing their intent to re-review Section III, Div. 5, as well asSection XI, Div. 2, which is on RIM -- reliability integrity management -- every two years, starting with the 2023 edition, which is the current edition we have now.
Next slide, please.
The code rules within the 2023 edition were reviewed by the NRC staff and was determined that updating Reg Guide 1.7 was appropriate.
The NRC staff is currently in the process of updating our endorsement. The proposed update for Regulatory Guide 1.7 for the 2023 edition can be found in Draft Guide 1436. Please note that the public comment period for the draft guide is still open. And if you have interest, please review the draft guide and submit any comments you have online before February 26th.
In our current effort to update 1.7, we
28 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 employed all the accelerant avenues I mentioned previously.
We had substantial code participation.
The NRC staff has a member and alternate member in almost all of the working groups under subgroup High-Temperature Reactors within the ASME.
We also participate in all of the quarterly code week meetings, and we have membership in many of the task groups which are looking to develop additional guidance as the code is developed.
As a specific example of how this was helpful in Regulatory Guide 1.7, participation within the Non-Metallics Group was vital for the NRC staff to prove the design-by-analysis methods within Section HHA of the code.
These design methods have had a lot of work done between 2017 and 2023, and the Non-Metallic design material group was very involved and a lot of information had been developed in order to make these updates.
Understanding this and being part of that group was very invaluable for accelerating our endorsement in Reg Guide 1436.
Between the 2017 and 2023 edition of the code, as Raj mentioned, the composites were added.
29 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 This was an area where we knew that additional information would be needed. And as such, we looked to develop a technical report which would help us with our endorsement work with Argonne National Laboratory, help with this technical basis development, and help accelerate our proposed endorsement in Draft Guide 1436.
I can list plenty of other examples, but suffice it to say that both code participation and technical basis development were key factors in accelerating the NRC staff proposed endorsement in Draft Guide 1436.
Oh, I would also like to mention that there's a public meeting on Draft Guide 1436 on February 21st, which will provide industry the opportunity to provide clarifications on the comments which have been submitted for the draft guide.
If you have detailed questions or comments on the draft guide, I'd suggest attending that meeting and discussing those at that forum. Next slide, please.
Changing gears slightly, the second topic I'll be touching on today is how the NRC staff currently addresses commercial codes, and some efforts we currently have on the topic.
30 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 Currently, limited guidance exists on the use of non-nuclear codes and standards for non-LWRs.
Regulations do not require the use of any specific codes and standards for non-LWRs.
Some other kind of important topics I'd like to bring up. One is that the use of commercial non-nuclear codes is likely viable for at least some components. Some guidance on this is provided in Appendix A, Regulatory Guide 1.7.
As I mentioned a little earlier, limited guidance exists for non-nuclear standards. Staff will in the future be considering what is the most efficient and effective means, i.e., RPG-endorsement or an alternative to endorsement, to provide regulatory clarity on this topic.
Additionally -- and this may be one of the most important points -- early vendor engagement with NRC on the selection of codes and standards is crucial for efficient licensing.
The NRC staff requires time to review new codes. So, proactive engagement on non-endorsed, non-nuclear codes, will support a timely review. Next slide?
As I noted, early engagement with the NRC is essential for efficient reviews.
Through
31 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 interactions with vendors, the NRC staff are aware that applicants are interested in the use of Section VIII of the ASME code.
To be fair for submittals that use Section VIII, the staff is focused on development of technical bases.
Currently, staff is assessing the use of Section VIII to understand its applicability to high-temperature failure modes, which may be present in non-light water reactor components.
In addition, staff is performing a comparison of the code rules in Section III, Div. 5, and Section VIII, which is intended to help identify potential topics which may need to be further considered in using Section VIII.
This comparison between the codes also allows us to understand design space where Section VIII and Section III, Div. 5, overlap.
The final major topic that this effort is seeking to address is potential supplementation for Section VIII.
For
- example, the applicability of Section VIII may be limited to higher temperatures due to pre-fatigue effects. So, this effort is looking to address potential applicability of negligible creep,
32 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 or negligible fatigue criteria, in order to extend the applicability of Section VIII.
In addition to Section VIII effort I was talking about, I also have to bring up Code Case 940.
This is one of the new code cases which was just added to the proposed Revision 3 of Reg Guide 1.87, and Draft Guide 1436.
The code case provides alternative rules for NDE and testing, which would drive industrial codes.
The intent to apply NDE, commensurate with the components contribution to safety and risk, this requires the NRC staff to review some industrial standards in order to develop the guidance which we have published in Draft Guide 1436.
The NRC staff are constantly looking to improve the efficiency and effectiveness of our reviews. I hope this discussion and some of the examples I provided gave some helpful background.
Thank you.
MR. GASCOT: So, we have three minutes, maybe more, for question. Any question? Joe and Raj?
MR. IYENGAR: I don't have questions. So, I did want to again reemphasize we will not be able to answer any questions related to the draft guide issued.
33 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 As Joe mentioned, we have a public meeting on February 21st. We can address them there. But any general questions or comments are certainly welcome.
MR. GASCOT: Okay. Tom, feel free to unmute yourself.
MR. BASSO: Yeah, hi. This is Tom Basso from NEI. I was glad to hear some of the things that you did to move some of these code endorsements along.
Are you looking to change any of the NRC's procedures or policies, to kind of put them into effect to move other such code changes along in an expedited manner?
And what I'm mostly getting at is, I know you're limited as to resources you can send to the code meetings. And there are times when the representative comes back, and he or she comes back with comments from the staff and may not be able to express all of the details of those comments.
So, your thought about where someone has a particular significant technical issue, either having them come to the subsequent committee meeting, or maybe potentially hold a separate public meeting if there are specific technical issues that need to be discussed.
MR. IYENGAR: Yeah, it's a good point.
I think it's always room for increased efficiency and
34 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 enhancement, which we are looking at. And I did want to tell you, Tom, I think we did precisely what you said in relation to the record 23-15, which became the 940 Code Case.
We did have some public engagement, as you may recall, you were there and we exchanged a dialogue and the result of that was an expeditious endorsement of that code case in this recent reg guide.
So, we do have that. We do have that ongoing. But certainly if there are instances where additional clarity is needed on some technical comments, I think we just want to hear from you. And I think they're open to this public engagement, making sure that the development process is clear and speedy.
MR. BASSO: Thank you.
MR. IYENGAR: Thank you.
MR. EGGETT: Ramon, this is Don Eggett.
I have a personal issue here. I can barely see the slides that are being presented. It has been shrunk and I'm seeing everybody's good looking faces okay in big, bold pictures now.
So, I don't know what's happened. Was it on your side, or it is on my side?
MR. GASCOT: It's on your side.
MR. EGGETT: Okay. Well, I'll have to
35 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 figure it out here, because --
MR. GASCOT: Yeah, click twice on the presentation to see if you can increase that.
MR. IYENGAR: Or you can fit to print it or something. Yeah, I think all of us don't have the issue.
(Simultaneous speaking.)
MR. EGGETT: I'll have to figure it out over here then. Anyway, thank you. Thank you.
MR.
GASCOT:
Okay.
- Keller, last question?
MR. KELLER: Who was that directed at?
MR. GASCOT: Myself.
MR. KELLER: Oh.
MR. GASCOT: Ramon. Any question you have for them? I see you raised your hand.
MR. KELLER: Yeah, this is Mike Keller with Hybrid Power Technologies. Just a few observations.
We can't usually use a guidance document to impose requirements on an applicant and you guys alluded to that.
By law, the NRC is required to work with industry in the development of consensus codes and standards. And that's the Nuclear Modernization Act of 2019.
36 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 And that's actually occurring, which is great. Relative to endorsements, or otherwise approvals, that's a softer area relative to the law.
And I think that's part of the problem, given the breadth of codes and standards that are routinely used with nuclear power plants.
And I think that's probably the biggest sticking point in a lot of this. What if you're using some code standard that's "not endorsed," but historically it's never been endorsed? And you know that's a head-scratcher.
It seems to me that if the NRC has been a part of the consensus development of a code standard and the NRC is dying with the code standard by virtue of typically they would state they agree within a consensus standpoint with the code standard, then that code standard should be suitable for use.
So, the question is, does the NRC have a list of code standards with which they have been a part of the consensus effort, and have accepted the code standard?
Where I'm really going with this is, it would greatly facilitate efforts to move the licensing arena forward, because there already would be a list that the applicants could see and say, okay, we're good
37 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 to go and still on the list. And it would, in some sense, get around the endorsement issue, which is going to create, and is creating, pretty knotty hurdles to get around.
Basically, you end up spending huge amounts of time B all parties do -- and things grind to a halt.
But anyway, just some thought. Thank you.
MR. IYENGAR: Yeah, thank you. We're going to consider it. I'm sure that list does exist and we'll make sure that things are made more publicly available in terms of the listing.
MR. GASCOT: Thank you, Raj. Thank you, Joe. Now, moving on to the next part of the session, and that will be Jack Shoemate and Ben Beasley. Jack and Ben, floor is yours.
MR. BEASLEY: Thank you. Good afternoon.
Can I get a sound check? Thumbs-up that you can hear me?
MR. GASCOT: Yes, I can.
MR. BEASLEY: Very good. So, I am Ben Beasley. I'm the Director of Licensing for the Molten Salt Research Reactor, and I will open us up with an overview, and then Jack Shoemate, who is our Chief Engineer, will cover our specific experience during our construction permit review. So, if you could go
38 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 to the next slide?
So, a quick outline of what we're going to do. As I said, I will cover introduction and I will describe the molten salt research reactor briefly, it's design, and then Jack's going to talk about the materials we're planning on using for the research reactor, and about the NRC review of our fuel handling system, which was a special case for us, and then some potential options for more materials in the future.
So, next slide.
And knowing that we're on a time scale, I'm going to talk fairly quickly. I won't say a whole lot, but do want to give a little background on Abilene Christian University.
ACU is growing in numbers and in academic strength. It has had seven consecutive years of increasing enrollment and ranks highly in the U.S. News and World Report measures.
ACU is one of only twenty-six U.S.
institutions ranked in the top-50 in both undergraduate research and undergraduate teaching. ACU is one of fifty-four universities in the country to receive a Forbes financial grade of A for the financial health of the university, and ACU's next lab has a mission to provide global solutions to the world's need for
39 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 energy, clean water, and medical isotopes, by advancing the technology of molten salt reactors, while educating future leaders in nuclear science and engineering.
So, as you can see, we're pretty excited about the work at ACU and are thrilled that we've been granted a construction permit by the NRC. So, let's go to the next slide.
So, ACU is not doing this all on their own.
We're working very closely with Natura Resources.
ACU and Natura have a very strong and productive partnership.
You can see the Natura mission to provide reliable energy, medical isotopes, and clean water, is very similar to the ACU NEXT Lab Mission.
In addition to ACU, the University of Texas, Texas A&M University, and Georgia Tech, formed the Natura Resources Research Alliance and the alliance is very proud to be exercising technology that has not been used in almost 60 years.
We are expanding student opportunities, we are collecting data to support commercialization of molten salt reactors, and we are providing a training platform for commercial MSRs. So, next slide.
So, the molten salt research reactor at ACU is a simplified version of the molten salt reactor
40 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 experiment that was built in Oak Ridge by Oak Ridge National Laboratory.
As you can see, it operated from 1965 to 1969 on two different enrichments of uranium. Not enrichments, but two different isotopes of uranium --
235 and 238.
The MSRE logged more than 13,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> at full power. And in my mind, unfortunately, in 1973 the Atomic Energy Commission decided to focus on other designs. So, no further work was done on molten salt reactors. Next slide, please.
So, this is the quick comparison of our research reactor to the molten salt reactor experiment in Oak Ridge.
As I mentioned -- I didn't mention, but the thermal output of the MSRE in Oak Ridge was about ten megawatts. The research reactor we're building will only have a thermal output of one megawatt.
We will be using 19.7-enriched 235. The MSRE used 33 percent enrichment of 235. Both of us are using a graphite moderator.
The molten salt is similar. The research reactor at ACU will use FLiBe with uranium tetrafluoride. The MSRE used FLiBe with zirconium tetrafluoride, along with the uranium tetrafluoride.
41 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 The construction material of the MSRE was Hastelloy-N and the construction material of the research reactor is stainless steel 316-H.
For the research reactor, we do have passive shutdown and cooling and it will operate near atmospheric pressure, and we expect it to be operational in a couple of years. So, next slide, please.
I just wanted to give you a quick picture to keep in your mind. On the left is a rendering of the reactor bay and the systems pit.
You can see down underground and to the left of the reactor bay are the laboratories and the control room. And on the right is an actual photograph of the systems pit at ACU. So, next slide.
So, this is a cartoon of our reactor, just so, again, you have an image in your mind of how it works.
If we start on the top-left for the labels, there's a reactor access vessel, which is essentially an expansion tank at the top of the reactor. Then below that is the reactor vessel. You'll see a label for the reactor trip line.
Up on the top-right side, the label for the reactor trip valves, that's how we shut down the reactor. If you open that reactor valve, that will
42 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 equalize the pressure between the reactor access vessel and the drain tank which is at the bottom, and all of the molten salt just drains out of the reactor.
So, that is how we achieve shutdown. And then on the right side, you see labels for the pump, the heat exchanger, of course we have a graphite moderator in the core.
The next label is the reactor thermal management system. Essentially, we are building an oven around this reactor, so everything inside that case will be at the operating temperature.
And then down at the bottom are helium tanks. And again, the helium is what is used as the cover gas and that is how we, with pneumatic pressure, raise the molten salt up into the reactor, or open the reactor trip valve and let it drain out. So, next slide, please.
And I put this slide in there, not to give more description of the reactor system, but to show you that we do have three different cells in the systems pit. The reactor system is in the middle, the cooling system is on the right, and then the fuel-handling system is on the left. And the reason I wanted to show this was because we are primarily going to be talking about the fuel-handling system in a few minutes. So,
43 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 next slide. And I think this is where Jack takes over for me.
MR. SHOEMATE: Thank you, Ben. I'll very briefly talk about the materials that we used for the various components.
Primarily throughout the research reactor, we used 316 stainless steel. And obviously for the high-temperature areas, we used 316-H.
We do have one area in the fuel-handling system where we do salt purification. That's a hydrogen fluoride sparging process. It's very corrosing to stainless steel and nickel is the preferred material for that particular vessel. But it's not included in Section V, Div. 3. Next slide.
That particular vessel material 201 nickel is listed in Section VIII, but that's not endorsed by the NRC. And some of the concerns expressed by the NRC staff was creep with the high temperatures, fatigue, the bi-metallic effects due to connecting of stainless steel popping to the nickel vessel, and any undetected degradation mechanisms, as well as the materials that we're going to use from welding. Next slide.
The resolution we worked out with the NRC is that they accepted the nickel material using Section VIII of the code, with some qualifications.
44 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 And first of all, this vessel is only used a small fraction of the operating time. It'll be used at initial startup to purify the salt. At that point in time, there won't be any fission products.
But it may also be used, and probably will be used, after the reactor has operated for some extended period of time, to pull the salt out of the reactor, purify it, and then put it back in.
And the purification at this point is primarily to remove oxygen, although we do plan to do some filtering to remove some other constituents.
The other agreement with the NRC was that we would use the lethal service requirements of Section VIII, which are more strict than if we didn't use that.
And we also have a very similar --
virtually identical -- vessel that we're using in the coolant salt system, which will never see radioactive material. And so, we're using that vessel as a lead specimen, so that it will always have more hours of operation on it than the one used with fuel-handling systems. Next slide.
Some needs for commercial reactors --
specifically, molten salt reactors -- that would be extremely helpful to us, is if the NRC had a means of
45 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 accepting nickel as an appropriate material for safety-related components, at least up to the temperatures that they are recognized in Section VIII.
Also, any other materials that the NRC can endorse that are good for high-temperature service, would provide a lot more flexibility for our designers.
I've listed here four possible materials that could be looked at and how they are currently referenced in various codes.
Basically, with our
- reactor, we're operating at extremely low pressure, but very high temperature.
So, any material that can be accepted for very high temperature with low pressure, and therefore, low stress levels, would certainly be very beneficial to us, to give the people doing the detail design more flexibility in what materials to use. Next slide.
Just sort of to summarize what we've said, the designers do need more flexibility in materials.
And that flexibility in their design requires more choices in materials that they can use.
And advanced reactors have different safety needs than liquid water reactors. And for safety applications, again we're looking at very low pressure, but high temperatures. So, the needs are
46 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 different.
And I would also suggest that the NRC consider how -- and you've already said that you're doing this -- how the use of materials outside of Section III can be allowed for some safety-related SSCs.
And with next slide, I think that's the last one. Appreciate your attention today and open it up with any questions.
MR. GASCOT: Thank you, Jack and Ben. Any questions?
MR. BEASLEY: If there's no questions I'll just make one additional, add one additional thought.
And that's that the flex, if we can give the designers flexibility that helps us to be able to achieve safer solutions to our design challenges. So it's not just operational considerations we're looking for, we're looking for safer designs and so the flexibility is important to us from a safety standpoint as well.
MR. GASCOT: Thank you, Ben. Now we have several questions. Steve, you have five minutes to all over so let's try to go over quick. Steve?
MR. JONES: Quick question on the, have you considered approaching the nuclear codes and standards under Section III for approval of these other
47 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 materials, and is there like, or do you have a research phase that's developed to support these materials under, you know, low pressure applications?
MR. SHOEMATE: We're certainly thinking about that but we've not made any efforts in that regards at this point.
MR. GASCOT: Thank you.
MR. JONES: Okay, thanks.
MR. GASCOT: Okay. Keller?
MR. KELLER: Yes. This is Mike Keller with Hybrid Power. In theory I supposed you could use Section VIII and apply special treatments to it, although that, you know, basically significantly more stringent quality assurance measures, maybe. But I'm not sure that's a real great idea when you're using a safety related pressure boundary but it is a, it is a path that actually does exist under current licensing.
But it could be pretty hard to do. Just an observation.
MR. GASCOT: Thank you. Then Andrew Sowder.
MR. SOWDER: Yes. Andrew Sowder with EPRI. Just a quick question on your general design and philosophy. I didn't see any mention of control narratives for reactivity, active reactivity control.
48 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 You know, obviously the design is very stable, I have a lot of great feedback for controlling on reactivity, but I was wondering, have you, are you designing in control rods or other active control mechanisms because MR. BEASLEY: Yes.
MR. SOWDER: -- you might want to turn it down otherwise.
MR. BEASLEY: Yes. We are, we do have control rods. The director of the lab likes to refer to them as suggestion rods. We do not need them for shutdown but we do have control rods to control the power level reactivity.
MR. GASCOT: And finally Jan Boudart.
MS. BOUDART: All right. Yes, you can hear me?
MR. GASCOT: Yes.
MS. BOUDART: Okay. My question is about the temperatures of the metals that are used in the reactor vessel. And when the temperatures, when you have a metal that is amenable to very high temperatures, and you mentioned even 900 degree Celsius, if you're using those metals in the reactor vessel, and like you said, you are not, the machine is not being used all the time, does the temperature go up and down?
49 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 And as you get metals that are tolerable for higher temperatures, is there more of a problem with brittleness with the higher temperature metals then there are with lower temperature metals? That's my question.
MR. SHOEMATE: Well, a couple of things.
First of all, we're not going to 900 degrees C. The 316H is limited to 704, I believe it is, and will be substantially below that in actual operation. The 316H, which is what we're planning to use for those high temperature components, except for that one vessel, has really good ductility properties at those higher temperatures.
Of course ductility is a consideration for any other metal that we might want to look at to use in the future, but we don't think it's a significant issue with the 316H.
MS. BOUDART: Okay, thanks.
MR. SHOEMATE: Certainly one of the things that has to be considered.
MS. BOUDART: Okay, I really do appreciate that answer. Thank you. Did you still hear me?
MR. GASCOT: Yes, we can.
MR. SHOEMATE: Yes.
MS. BOUDART: Oh. Okay. I'm turning off
50 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 my microphone.
MR. GASCOT: Well, thank you, Ben, thank you Jack. Now moving on, we have James Roll. James, floor is yours. Thank you very much.
MR. ROLL: Good afternoon. Mic check, can you all hear me?
MR. GASCOT: Yes.
MR. ROLL: All right. Thank you for the opportunity to present at this session. As a high temperature reactor designer we are very interested in engaging with the Industry and with the NRC Staff in ensuring that we help move together on the commercial codes and standards that are going to be useful for our next generation of advance reactors.
So my name is James Roll and I'm the senior manager for the mechanical engineering design team at X-Energy. And that consists of mechanical designs, structural analysis, thermal systems and thermal hydraulics.
And if you can expanse the slides please.
And what we're working on is, we have several reactors in the works. The principle ones here are the Xe-100 small module reactor and the XENITH microreactor. I'll cover mostly from the perspective of the Xe-100 small module reactor as that one is close to submitting a
51 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 construction permit application and we're working hard to get that prepared for submittal.
And so this is a review of the commercial codes and standards for a high temperature gas reactor from that perspective. And that, for some awareness of technology, we don't have a great deal of material on the technology itself, but just to highlight it that includes for graphite structures, high temperature metallics, helium as the primary coolant, TRISO particles in the fuel pebbles.
And so, I did want to very briefly highlight as, let's say a contextual for this presentation. The, let's say differences in the advance reactor generation for technologies as we might distinguish them from the generation 2 and generation 3 and 3+ technologies out there and how we fit that into the regulatory and codes and standards framework and how do we leverage the commercial codes and standards effectively for advanced designs where the technology readiness level is still being developed.
And I want to highlight that that's our fuel pebble. The spherical shiny object there. It's about the size of a billiard ball. That will be used for the Xe-100 reactor. And that itself has TRISO, many thousands of TRISO particles. TRISO particles
52 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 are spherical in shape. And they themselves actually
- have, within the
- particle, several layers of defense-in-depth. And I'm repeating to some extent some of the information I shared at the April 4th session.
So if you compare that with the traditional light water reactor fuel where you got the fuel and iridium oxide pellets which has, as its primary boundary against radionuclide release is the fuel cladding.
And then the second boundary could be the vessel. And then the third boundary might be the containment structure, the building.
So we'll distinguish that from our TRISO Xe particles have already two or three layers within the particle and then another layer in the pebble itself. So you get to the vessel, and that's already not the second layer, but the fourth or more layer for radionuclide release.
And so this is where some of the foundational, some of the foundational context for the development of structural integrity related codes and standards is based on the premises of a physical containment. And we want to help adapt industry best practices for using codes and standards in other spaces that have been effective.
53 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 And so, I'll focus this presentation on sharing with the NEI 18-04 risk-informed performance-based perspective where alternatives for special treatments might be effective in deploying advance reactor technologies for, and when they particularly might be useful for leveraging commercial standards.
Next slide please. So there's a lot of discussion in this community about special treatments.
And so, what is a special treatment?
Well, the selection of codes and standards is one option for a special treatment that a designer can make based on what's appropriate for the risk-informed performance-based specific to their technology. And so this is from, the italicized quote is from NEI 18-04, as endorsed by regulatory guide 1.201. Special treatment refers to those requirements that provide increased assurance beyond normal industrial practices that structure systems and components perform their design basis functions.
And so, I made an attempt here to illustrate, visually, a general philosophy for cost effective construction using the risk-informed performance-based approaches. And this is no easy task because there are a large number, as you'll see, of
54 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 codes and standards that advance reactor designs need to use.
But, and this is certainly not to scale, but work with me here and we'll try to make it make sense. So if you start from the right of the figure, no special treatment. This is where industrial best practice codes and standards are the baseline. They are the appropriate means that would be used if you were building something that wasn't a nuclear reactor.
We have many thousands of industry examples, chemical facilities, gas plants, fossil plants that are operating at high temperatures and pressures. And they are using industrial best practice codes and standards.
And then if you slide to the middle, this is where you start to see the red intersect. This is where, for some components, where the designer concludes that it is important to the safety related aspects of their design. They may choose to select nuclear industry codes and standards to augment the industrial best practice codes and standards.
And then further to the left we get the safety related classification. For these components these, the majority of them, it is appropriate to use the traditional nuclear industrial codes and standards.
55 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 A couple caveats here, you'll see on the bottom left the blue industrial standards doesn't quite cover all the it doesn't, it's not subsumed entirely by the red. What does that mean? Well there may be cases, and market, we believe there are cases where industrial best codes and standards are appropriate for safety related design and construction. And also, there may be codes and standards needed for advance reactor technologies that aren't available as nuclear standards and so something else must be used.
And then, what's the purple line? So there are some codes and standards already available with a graded approach. And these could be used across multiple different safety classifications. This is where our civilian engineering colleagues have been leading the pack in the industry for mission critical infrastructure, and they've developed in some of their codes and standards a graded approach to design that accommodates different safety classifications as they defined it.
Next slide please. So the following slides are a series of tables where I'm summarizing the high points with the details focusing on trying to put some words to these, these codes and standards which just have letters and numbers and try to really
56 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 talk about their potential uses in advance reactor design. And also, the potential NEI 18-04 applications to try to give some context to why we would recommend that they be considered as important commercial codes and standards.
And these are examples from X-Energy's perspective only, other stakeholders, other designers might reach different conclusions based on how they plan to use them for their own technologies. And I should not also, the focus here is on mechanical and civil structural engineering standards as these have the highest cost impact and cost and practical construction.
So I have though included in the appendix to this slide deck which will be available with the slides an appendix of additional codes and standards.
And a large number of electrical codes and standards would be available for those interested there.
So on this slide, highlighting the American Concrete Institute, ACI Standards 318. Why there's two of them? Well, the Addition 2008 is a parent code for ACI 349, the nuclear code in the standard. And so, if the designer wants to use ACI 349 they will also use ACI 318 by implication.
But there are some more recent versions
57 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 of ACI 318 that could be useful for an advance reactor design. We recommend the 2014 edition. This is the latest edition consistent with the major format of ACI 318 and 2008. And a major reorganization of the code format did occur in the next edition. So this code could be use for industrial best practice of concrete structures, embedment plates and anchorages, foundation, slabs and post-installed anchors. It might be appropriate for NSRST or non-special treatment structures.
And then down at the bottom there, AISC RCSC spec. That could be used for designed fabrication, erection and bolting of high strength bolts. And this could be used for any classification.
Next slide please. A little bit more quickly after this slide. I think I want to highlight the international building code as this is a standard for the minimum requirement to safe guide the public on new and existing structures. And using perspective and performance related provisions.
So this international building code was developed with raw-based principles that make the possible use of new materials and new building designs.
And it could be appropriate for NSRST structures.
Then we have a couple of ANSI-AISC
58 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 standards listed. Drawing your attention to AIC 341.
Guidance is needed to confirm concurrence of the acceptability for this standard for seismic provisions for structural steel buildings. And that might be appropriate for NSRST structures as well.
Now let's talk about AISC 360 versus N-690.
There is the endorsement of the N690 18 edition indicated reference guide, but it might be useful for any NEI 18-04 classification. Depending on how the designer might choose to use them.
Next slide please. Talking now about ASCE
- 24. The 2014 code year is recommended here for flood resistant design construction because that is the one that correlates with the international building code 2018 edition.
And so this is the specification for determining minimum design and construction of structures located in flight hazard areas. Hazardous estimate for a design might be different depending on where the facility is located. You know, can share that the Xe-100 is going to be built in Project Long Mott with our partners Dow Chemical in Seadrift, Texas.
And so we are very interested in ensuring that we properly account for the flood hazard.
ASCE/SEI 4, 43 and 7 are the cornerstones
59 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 of the civil engineering design. And ASCE 4 is the nuclear standard but this has not been endorsed. We want to underline that comment here that RIL 2021-05 does comment on it but that it's not yet endorsed in the regulatory guide to our knowledge. This provides requirements to determine the safety of nuclear structures that encounter earthquakes.
That's also true for ASCE 43 at the 2019 edition. And so, the 2019 edition has been in the course of review. And wants to really emphasize its importance in the safety related or NSRST design of structures for an advance reactor.
ASCE 7, this is an industry best practice specification for determining the minimum loads for buildings. And it should be noted too that ASCE 7-22 has major updates on seismic hazards. So I've listed that in the comments in addition to the edition 2016 listed.
So next slide please. We'll get back to our mechanical engineering bread and butter here with ASME B31.1 power piping and 31.3 process piping.
So these are American standards for power and process piping. These are industry standard best practices. And, you know, advance reactor designers, I think it's been noted through other presentations
60 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 here that such as ASME Section 8 and B31.1 and 3 are sufficient, or could be sufficient, for meeting the PRA safety functions as a special treatment. And so, we've listed them as potentially useful for NSRST or NST applications.
And then a number of other partner standards are listed here for B31 and through 71.3, I'll move on. Those are for reference.
Next slide please. We've discussed already thisSection III, Division 5. Why is this important to X-Energy? The non-metallics section that was discussed earlier is a, an important avenue that we're engaging with the ASME code committees with as there is no other codes and standards that is sufficiently detailed for the design construction of graphite in a nuclear reactor, to our awareness. And so we are working hard to work with the code committees to make sure that real feedback is shared and that the code evolves in a way that is useful for the designers and for the whole community of industry.
Section VIII, Division 1 and 2, again, listed that these could be sufficient from meeting the PRA safety functions as a special treatment.
And we've got Section XI, Div 2 and Section XIII, rules for over pressure protection. This may
61 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 be useful for any NEI 18-04 application but it is not actually endorsed. And so, maybe that could be of interest to the community.
Next slide please. ASME OM2, the code on component testing requirements. This has rules for in-service testing requirements for pumps, valves, dynamic restraints in nuclear facilities. And it could be implemented as part of a RIM program for safety related or NSRST components if the designer deems that appropriate. And so, draft guidance is in review.
And wanted to underscore that this is a priority one for industry.
ASME PTC 25, and some of these others here, are supporting ASME standards for, depending on the technology of interest. If you were designing a high temperature industrial facility you might be interested in these standards as well.
Next slide please. I will move a little bit more quickly through these. These are supporting slides. I think these are good examples that ASTM references where there is no, for some of them, no regulatory endorsement or other avenue by which to think about how to go about a nuclear safety related component for this area. And so these may be of interest as we think about how we take commercial codes and standards
62 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 to advance technologies.
Next slide please. And then here we have another set of some other standards. Fuel electrical standards, NEMA and the IEEE standards. And these are some of the API standards that are design codes for venting, low pressure storage tanks, steam generators and heat exchangers. And these are, again, general industry best practice standards that we are including for a completeness of awareness in our list of recommendations for the staff to consider.
Next slide please. And last, but not least, we have the quality standards. And ASME NQA-1 quality assurance requirements for nuclear facility applications.
This may be appropriate for safety related or NSRST components. But also ISO-9001 might be appropriate as a quality standard for any NEI 18-04 applications. Now that may need to be augmented with additional practices in the management organization, but it may be sufficient for cost effective procurement of components.
And that concludes the material I prepared.
You want to go to the next slide? I have, well, maybe let's move forward for completeness.
I have a laundry list of other codes and
63 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 standards that the team has recommended that we include in this. Next slide please too. These include ANSI and ASTM standards that could be generally of interest to the community. IEC and IEEE standards that are industry best practices.
Next slide please. As well as, finally the last slide. Second to the last slide. And some of the other industry best practice standards. We were including these as, for information, and potentially of interest to the industry. And these are available with the slides.
All right. So if you want to go ahead to the final slide that's the conclusion of my presentation. Thank you for the opportunity. And thank you for the Staff and your consideration.
I think it's very, it's very great to see this meeting and I'm eager to see this as a key listening and continuing engagements as a key way that we continue to work towards the new mission statement with the NRC Staff, which was revised in January 2025 to note that the NRC protects the public health and safety and advances the nations common defense and security by enabling the safe and secure use and deployment of civilian nuclear industry technologies, et cetera.
And I think this particular form, and forms that will
64 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 follow, are a very good example of how the Staff are working to enable these technologies through that mission. Thank you for your time.
MR. GASCOT: Thank you, James. Any question for Mr. Roll? Mike?
MR. BENSON: Yes. And forgive me if I misunderstood your slide, but you had Section XI, Division 2 listed, but that standard has been endorsed by NRC in Reg Guide 1.246 and I was just wondering, did I miss something or is there something specific that you're looking for from the Staff there?
MR. ROLL: Thanks, Michael. And I apologize, there is hundreds of standards listed and I apologize if I missed an endorsement. But could you share, what is the addition that is endorsed?
MR. BENSON: I would have to go back and look I don't know off the top of my head.
MR. ROLL: So if it was, that might be what has distinguished it is that maybe we were referencing a more recent year or edition.
MR. BENSON: Okay. I could look into that. And maybe I'll put something into the chat.
Thanks.
MR. ROLL: Thank you.
MR. GASCOT: Okay. John Richards?
65 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 MR. RICHARDS: Yes, this is John Richards with EPRI and I just want to mention that we are doing some work on risk-informed codes and standards for advance reactors focusing really on the civil structural aspects of it. And we agree very much with what James mentioned on the application of commercial codes and standards for even nuclear safety related structures.
There is a graded process within the standards and they can achieve the performance targets that are necessary. If you need to add a special treatment, such as an extra margin of safety or something, we believe there is a way to achieve that.
So I just endorse that idea and we're going to continue to do some work in that area.
MR. GASCOT: Thank you, John. And, Sheila?
MS. RAY: James, it was very helpful. My name is Sheila Ray, I'm an electrical engineer at the NRC. It was very helpful to get some of the IEEE documents related to the electrical systems. I just wanted to let you know we have endorsed IEEE 1205 in Reg Guide 1.248. I think that was missing in your table so I just wanted to let you know.
MR. ROLL: I appreciate that. And
66 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 apologies again for any omissions or errors. We pulled this together very quickly.
MS. RAY: No worries. I appreciate all the information you provided. Thanks.
MR. GASCOT: Thanks, Sheila. Now Mita.
MS. SIRCAR: (No audible response.)
MR. ROLL: If you're talking you're muted.
MR. GASCOT: Yes, Mita, you're muted. Let me see if I can unmute you. That's weird. Let me see if I can do it from here. Let me see if I can --
MS. SIRCAR: Can you hear me now?
MR. GASCOT: Yes.
MR. ROLL: Faint.
MR. GASCOT: Yes, barely. Yes.
MS. SIRCAR: Barely? Okay, now, how about that?
MR. GASCOT: Now we can hear you. Thank you.
MS. SIRCAR: Okay. I was only part way.
And so let me, yes, it's full. I just wanted to inform, James, thanks. Thank you very much. This is very informative.
And I just wanted to mention that ACI 349, latest version 2023 has been published last October 2024. And that, as you are intending to use that ACI
67 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 318 2014, the latest code, tariff code is 2014 and some limited provisions has been also taken from 2019 of 318.
MR. ROLL: Okay, thank you for the comment.
MR. GASCOT: Okay. There's another question? Okay, Robert.
MR. TREGONING: NRC Staff. We really appreciate the presentation and you listing sort of the whole scope of standards that you're interested in.
Have you done any sort of prioritization to figure out, you know, which of the standards that you sort of, that are the highest priority in terms of either gaps or nearest term needs?
One of the things we're trying to do is, we've obviously got to marshal our resources appropriately. So if we understand, it's one thing to say, hey, we're going to use all these standards, but we'd also like to focus on the ones that are the biggest needs and then might have the biggest gaps with existing nuclear standards.
So have you done that kind of exercise on these various tables to really see, you know, which ones are sort of the biggest sticking points if they haven't been endorsed?
68 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 MR. ROLL: Thanks for the question. I would emphasize the material that I put in the front matter. Any, all of the codes and standards listed in this front matter, that are not in the appendix, are the ones we believe to be really the highest priority. And especially the ones where I provided commentary with the asterisks. So certainly invite those to be looked at with the highest level of importance.
MR. TREGONING: Okay, I'm sorry if I missed that earlier so apologize.
MR. ROLL: No worries.
MR. GASCOT: Well, if there are no other questions, then thank you, James for your time and your presentation, really appreciate that. And now Mr. Don.
Are you able to unmute? I know you were having problems with your screen. Are you able to solve your problem Don? Are you able to --
MR. EGGETT: I did. I did, thank you.
MR. GASCOT: Okay, perfect. So the floor is yours. Thank you very much.
MR. EGGETT: Yes. Thank you, Ramon. And I thank the NRC for this opportunity. This is going to be a little different presentation. We've heard an awful lot of technical information. Very, very
69 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 useful. I'm going to be a little shifting over on what we did in evaluating some of the existing standards and gaps that may exist that would be somewhat of a shortfall to the designers in their needs, okay, for advance, their advance reactor designs and stuff like that.
So, anyway, I'm currently, okay, the chair of the advance codes and standards collaborative. And also the immediate past chair of the ANS standards board.
Next slide please. We kind of honed in on three of the objectives that the NRC was looking for with the public meeting. And they're listed here on the right side. Identifying high priority standards, identifying resources that we would be looking for. That is the SDOs and others affiliated with the ARCSC initiatives. And also where endorsement for high priority standards really need to exist.
You will note a slight asterisks on the left there that we typically have not at all focused, per se, on commercial standards but we believe that the information you're going to hear today definitely has generic applications. And a lot of it is going to be somewhat repetitive from the previous speakers.
So there is some complimentary information, if you
70 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 will. We're kind of like thinking along the same path so I guess that's a good omen.
Next slide please. I wanted to mention, the NRC Advance Act of 2024, their actual focus on actions align very well with the ARCSC objectives.
And they're listed here. And one of the things in the third bullet down there is that the NRC developed performance-based graded actions in its regulatory framework to increase stability.
And with ARCSC we keep that in mind when we move forward on some of the action items that we have, and been given to us, in trying to capture the needs for the advance designers. So it's important to understand the Advance Act and how that aligns okay I guess with industry initiatives.
Next slide please. Just very briefly, ARCSC, we were formed in early 2022. We've come a long ways where we've actually identified gaps in current standards and set some time lines for completion where we know there's going to be a need. That was in Survey 1 back in November of 2023. Just a few months ago we went through a Survey 2 looking for feedback from the advance reactor designers. And I'll talk a little bit more about that later on.
We won't spend much time at all talking
71 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 about the action item on 2, which is to demonstrate risk-informed and performance-based approaches. But a lot of the things I'll be talking about there is synergy in correlation between the two.
Next slide please. What is shown here is our charter and what our objectives are in those four blocks there. And you'll be seeing how these will be tied into the information that I'll be providing. A lot of sharing of information. Identifying codes and standards needs, complimenting others efforts going on in the industry and then aligning the actions with the North American Advance Reactor Roadmap which came out in May of 2023. And they'll will be in the process of updating that during the year of 2025.
Next slide please. The next three slides list the members of the ARCSC collaborative. And I won't go into any detail here. It's for your information. There is nearly 40 members, okay, of ARCSC. It's pretty well attending. And there's been an awful a lot of interest from different organizations within the industry that have a footprint, if you will or a hand in what we're doing.
Next slide please. Next slide please.
And one more. Thank you. Again, a little bit more in detail of what ARCSC's charters and goals are. You
72 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 can read them there.
What I do want to mention here is the last one there, input to the roadmap implementation board.
There is an implementation board that ARCSC is part of and is a member of. And we're aligning our actions with the advance reactor roadmap report, that I just mentioned, and the action items that were given to us to actually carry out on codes and standards in support of the designers.
Next slide please. Survey 1, or CS-01, was to identify gaps. And that's really what initiated this, if you will, to determine where the gaps were in standards and do an assessment on that. And there was an awful lot of interesting points that came out that I will share in some highlighted points through this presentation.
Next slide please. Through the actual gap assessment, as it's termed, we actually identified a number of standards. And this was through the SDO's, or the standard development organizations comprised of ANS, ASME, IEEE, ASC, et cetera. And it took us through this particular evaluation process here where we determined, you know, there was an actual gap identified and if there was, what priority did we need to put on it and where would the resources actually
73 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 be that we could use to support moving forward with it, getting funding, if necessary, from appropriate organizations and capture them that the actual, that this particular package would be useful to all the designers for their actual designs.
Next slide please. So, from the ANS standards that were evaluated for gap assessment there were six that were identified. And I wanted to mention that 2.26 is all about seismic. And it's a big player in the industry. And it cross-pollinates, if you will, across the industry in a lot of different ways. And I'll mention these as we go through the presentation a little bit more.
But another one too, it's 54.8, at the bottom, of liquid metal fire protection. We're going through a process right now of approving an actual historical standard from 1988 and we're going to even make it a Revision 1 to that particular one to bring in risk-informed performance-based initiatives as appropriate. But this one that was requested by some of the responders that they needed this particular standard and what they're doing right now in a lot of their planning and designing, et cetera. So I wanted to mention 54.8.
Next slide please. A lot of this we
74 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 already heard about through previous presentations that were very, very good. ASME priorities from the gap survey. I think they compliment what you kind of heard, but these are more on the high-level.
Next slide please. ASCE. There really wasn't any specific priorities from the gap survey that we actually came back and they were identified, but members of the ASCE, and others, saw the need to merge SEI 4 along with SEI 43. And that's in the process of moving forward right now.
Next slide please. So I mentioned Survey
- 1. This is Survey 2. And Survey 2 was to get feedback from the actual designers to evaluate, not evaluate, but to validate and verify what the SDO's actually did in setting priority of standards that actually came out of the Survey 1, and now we're asking in Survey 2 for the design to do a, if you will, a balance check.
And what we came up with, and what they knew and what they think they will be needing, as they move forward in their designs. So that's what Survey 2 is about.
Next slide please. Here's an example of ANS 2.26. SSCs components for seismic design. And ARCSC proposed a high prioritization on this. There is a lot of information here. What I do want to mention is that the criteria that was used to determine which
75 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 standards, or standards that had gaps in, needed priorities put on them, it was based on the criteria from an NEI document where you look to see, does the standard actually support the design, the licensing perspective, O&M costs, facility construction, et cetera.
And how that ever fell out what would the responders or designers, when would they need such changes to 2.26. And that was based upon a one year, a three year, a five year, et cetera. And a lot of it actually panned out that way, both for ANS, IEEE and ASME standards.
Next slide please. We received 14 responses from Survey 2. And that was as of November 25th, 2024. And they're listed here. We even got comments back from NEI. Very interesting comments there.
But this is the list of the ones that we got back. And I believe that we sent out this particular survey to roughly three dozen organization, design organizations, or organization data. A major involvement in this exercise to respond back as a V&V, if you will, to what the SDOs came up with.
Next slide please. This just shows in a graphical way the priority of 2.26. What we want to
76 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 point out, the NRC is looking for, are they supporting committees or working groups right now and where might they need to support them and put people onto support this. We identified, for at least for 2.26, very active in the industry, along with others, that we do have two representatives from the NRC and endorsement will be sought.
Next slide please. This is a summary of some of the priorities that came out from SME.Section III, Division 5. And the graphic really tells their priorities, the needs, et cetera. And a lot of the information on the right side gives you a little bit more details on where the gaps and comments came in from some of the responders.
Next slide please. AISC 690 related to the steel structures for nuclear facilities. And we kind of heard in previous presentations a lot of these could be applicable, both for non-nuclear, or those that are non-nuclear or commercial could be used for even the nuclear side if you actually captured it in the way you needed it.
What we provided here, what we have, or what's going on with AISC 690, the working group, they've had good representation from the NRC for a number of years. So this is pretty well full and has
77 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 an awful lot of involvement and engagement. And it's basically kept up to date as we move forward.
Next slide please. More on the commercial side. You've seen this a little bit before, again, in previous presentations. Right-sizing codes and standards for civil structures. There is ASCE 7, 41, 318, 360, 341. And it breaks down the actual focus for those particular commercial, commercial standards, et cetera.
So from the nuclear standpoint there is ASCE 92, which actually is going to right now, it's involving and supporting RIPB, a risk-informed performance-base design. And also, 349 from the concrete, or structural standpoint if you will, there is actual focus in ongoing activities right now that really, okay, even though they're nuclear they're also applicable to the commercial side from the perspective that we see.
Next slide please. Again, more on the non-nuclear standard, this is ASCE 7. A lot of the information in detail is given here. It's very useful information and it's kept onboard right now.
Next slide please. ACI 318. A lot of this information, you know, in our use as designers or operators, or however you want to term it okay, we are
78 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 familiar with a lot of this phraseology and the needs to keep them up to date and use them where appropriate.
And we're very flexible in doing that. ACI 318, non-nuclear, but it's definitely okay where it can be used for nuclear.
Next slide please. Here is some points made on IEEE standards for advance reactors. And you'll find out on the following, well maybe not on the following slide, but I have a backup slide of some IEEE standards that are, if you will, ongoing, more on the top-shelf right now top priorities and stuff like that.
And this is really coordinated through NPEC. The nuclear power committee. Electrical committee. And they provided some information here on where standards are applicable to the advance reactors, or could be.
Next slide please. Some future actions.
And before I actually get to that I wanted to mention one other thing.
Next slide please. We actually went through and determined, there was six subject areas that we thought were critical to evaluating this gap assessment. And they were design and construction, management and QA, operations and maintenance, safety
79 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 and risk, et cetera. And there were six, but outside of that these also were included as part of the initial lists. So the question is, are these topical areas, do these require a gap assessment also?
There's a lot of information out there.
There is documentation in a lot of these areas. And if you just browse through them you kind of, you know, you kind of ask yourself is this something that we need to take a look at closer. And this is one of the action items that ARCSC will be taking forward in 2025. If we get support from the industry and the designers then it becomes more of a higher priority.
Next slide. So we kind of captured what we think our future actions are for ARCSC. And in no particular order, but if you go in the top left-hand corner we're going to evaluate the needs for non-nuclear commercial standards because this was really the focus of what the NRC is looking for. And since we, ARCSC, with all the SDOs involved, have a big hand into what standards are out there because we produced them, we're going to determine the appropriateness for ARCSC to address the commercial side non-nuclear and how these could actually become involved and support the standards.
And then if you go across, you know,
80 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 analysis of the survey feedback and get back to the actual implementation board on where we think the priorities need to be and where do the resources really need to come from. So these particular seven future actions is what we're proposing that ARCSC take forward in 2025 and beyond as necessary.
And you will notice in the right side under the orange ball there, support the industry in the use of risk-informed performance-based methods. I just want to mention that because this was an area in the survey that we got back where there was an awful lot of interest, needs and responses to say that something really needs to be out there. Like maybe a generic document, maybe a generic standard. Maybe just a generic guideline that really would parallel what came out with the NRC's NEIMA in 1998.
So, if you have any questions, you want to follow-up, the next slide really lists the contacts, if you will. And you're more than welcome to get back to us outside of this meeting for anything that you may want to pursue in discussions. And with that I'd like to thank you for this opportunity. And I turn this back over to Ramon.
MR. GASCOT: Thank you, Don. Questions for Don? Angie, floor is yours. Let me see if I can
81 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 unmute you.
MS. BUFORD: Am I on mute?
MR. GASCOT: Yes, now we can hear you.
MR. EGGETT: You're on. Yes.
MS. BUFORD: Okay. Yes. No, just saying that I really appreciate this. And I led the development of the Advance Act Report that is going to be looking at how we implement some of the actions, and so I will certainly take you up on a further engagement in getting a little bit like more granular on where we need to focus and prioritize. So, just appreciate it. And I will --
MR. EGGETT: Thank you, Angie.
MS. BUFORD: -- I'll reach out.
MR. EGGETT: Yes, thank you. Yes, that would be great. Thank you. The other thing I'd like to mention, Ramon, the backup slides are available as part of the material that can be sent out to all the participants. And that was just supporting material in case I needed to refer to it, but it was way too lengthy for the time allotted. So anyway, it's just point of reference for everybody to use.
MR. GASCOT: Okay, perfect. I believe --
MR. PIRES: Hi, this Jose.
MR. GASCOT: Jose, go ahead. Yes.
82 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 MR. PIRES: Yes. I just want to say that we are already doing some of these. You know, we have been engaged since 690 committee. And we're already preparing a plan for the endorsement, the update of the Reg Guide 1.240 for the new addition of the standard.
And it probably will not require many changes. We are quite familiar with what is in the new version, with the N690. So I think it should be an efficient process I think.
MS. BUFORD: And --
MR. PIRES: Just an example.
MS. BUFORD: I'll just add to Jose, Jose, excuse me, that we are implementing stuff but also we want to do more. You know, I'll say that. So we're just trying to look, you know, trying to push forward as much as possible too. So we'll, you know, we're looking forward to both completing the actions that are in place but also moving forward on some ideas that we have had in house and that we're going to move forward with those as well, so.
MR. EGGETT: You know, that would be great.
Thank you, Angie. And I do want to mention that ARCSC is in conversations continuously with Christian and with Chris regarding standards of priorities. They have asked us to provide, as collectively through ARCSC,
83 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 but more importantly through the individual standard development organizations, or SDOs, to provide a list of the high priority standards for the benefit of the NRC so they can set priorities and determine which ones, if you will, are above the bar. So I do want to mention that.
MS. BUFORD: Yes. Yes. Yes, let's have a fulsome discussion on that for sure. Thank you.
MR. GASCOT: Well, if there are no other questions, it seems like not, so now we have a break.
So we'll be back at 3:10. I will update this. So gives you 20 minutes. So see you back around 3:10.
Thank you.
(Whereupon, the above-entitled matter went off the record at 2:51 p.m. and resumed at 3:10 p.m.)
MR. GASCOT: So welcome back. Now we move to TerraPower. And Steve Unikewicz.
MR. UNIKEWICZ: Okay. Thank you.
MR. GASCOT: Unikewicz, sorry about the last name.
MR. UNIKEWICZ: So --
MR. GASCOT: Unikewicz will go over his presentation. Thank you, Steve.
MR. UNIKEWICZ: Yes.
MR. GASCOT: Floor is yours.
84 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 MR. UNIKEWICZ: So thank you very much.
One of the things I'll tell you is that I'm one of the chief engineers for TerraPower Natrium Project. I will fully admit that I am a member of Board on Nuclear Codes and Standards, I'm a member of QME, I'm a member of OM, and I'm also a member of ARCSC. So I'm not going to go over a lot of the same stuff that's already been talked about today.
I will give you some ideas and some thoughts here going forward.
Next slide. Next slide please? So what does success look like? And we've kind of talked about this a little bit. And what we think success looks like is a little bit improved alignment with Part 53 in NEI 18-04.
We think there could be a real reduction in effort as requirements, commercial codes become fewer or even perhaps, perhaps even unnecessary. From code applicability point of view, we'd like to see NRC endorsement without exception. That's kind of the preferred fruit. If not, then perhaps there may be some added requirements on occasions and some NRC review.
We do expect to see some limitations and conditions identified and finalized in code meetings.
85 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 I do recognize that there is roughly 30 to 40 people right now in TerraPower that are actively involved in code committee meetings. And we do spend an awful a lot of time interacting with NRC Staff. So this is, by no means, exclusive. I think we'll work very closely with Staff and we really appreciate that effort.
Next slide. What are some of the priority commercial code centers not get that are fully endorsed?
Well, we did put out a white paper about two years ago on May 10th. And we also did receive response back from the NRC. Currently in Table 7 of that white paper there are 17 standards with no previous NRC acceptance in the reg guides. And in Table 8 there are 14 sodium-related standards with no previous NRC acceptance.
You will see, however, ARCSC goes through, most of them are identified through the ARCSC process.
You saw we had four of us comment on the ARCSC process.
So we think they are being covered. We think they're being addressed they're just not, they're just not there quite yet.
Next slide. What are the ones for us that propose significant risk? Well, we talked about ASME Section III, Division 5 an awful lot. Right now our design of plant is for 60 years, the current code only
86 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 supports 34 years. We do recognize that's an ongoing effort, but that truly is something that's at risk for us.
We did provide comments directly with the NRC for Draft Guide 1436. And those I think, as we said, we're going to discuss perhaps next week or a week after at the public meeting. So we're not going to go talk about them, them here.
Next slide. What are some of the positive things the NRC has been doing? As we talked about, as we mentioned earlier, OM-2 has been approved. There is a pending draft reg guide to endorse it. We really do appreciate all that effort considerably, it's going to go a long way for us as we're developing our in-service testing program and all other programs going forward.
We do recognize the pending revision of Reg Guide 100 with QME hopefully 1-2025 coming out.
And IEEE 344-2020. And there were a couple others there as well.
I am going to talk a little bit about the NRC action plan, Item 3.1. And I think these are going to really make a, have a positive impact on our advance reactor community.
We'll go to item, Action Item 2.3 on the
87 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 next slide. So we do recognize that the staff is updating management directive 6.5. We think there could be some potential improvements in Sections II.E and Section III.
You know, Staff is required to attempt to resolve topics before the consensus standard comes to a final vote. Again, as I mentioned, we do normally do that. The NRC Staff involvement in a lot of our codes and standards, whether it's IEEE, NFPA, ASME, ANS standards has really been working out very, very well.
I will point out particularly in my experience the Staff involvement with OM-2 and QME has truly been one of the, I think the more enjoyable pieces that I've done over the last couple of years. And I think because of that those two standards are really fantastic standards.
We do recognize that resolutions are not necessarily required during code meetings but it does present good opportunities for us. And I do, I think our informal conversations on a generic letter during code meetings has been a huge help for us going forward.
One of the hard parts has been the limitations and the conditions really aren't always mentioned during code meetings. And I recognize, we
88 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 recognize that that is something generally the Staff has to do internally. It would be helpful for us to quite understand what the limitations and conditions on an endorsed code of standard will be prior to it being issued. I think that it also could perhaps help in the putting together of the particular code section.
We do get negatives sometimes during code committee meetings. And we do try to address them.
It's not always clear what the communications that NRC is going to put on them, either in the reg guide or formally in 10 CFR 50.55(a). So again, we kind of hope that happens going forward in the future.
Next slide. So one of the things that we did talk about is that NST and NSRST is a feature.
It's really not a flaw.
We are trying to work very hard through NEI 18-04 and Reg Guide 1.233. And LMP does allow us to draw some system boundaries and codes and standards based upon a risk-informed safety evaluations.
However, we are sometimes left with using deterministic methods. And although I wish I could say that we use risk-informed for everything, a lot of times we do fall back on risk-informed deterministic methods.
That will come out a little bit. Whether I talk about seismic or not, but seismic is another
89 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 aspect where sometimes deterministic is a little bit better to deal with than six categories of risk-informed seismic categories.
They're safety significant but not safety related. But quite frankly we've been doing this for about 40 years with safety significant versus non-safety related. We've been doing this with certain systems, we've been dealing with a lot of other systems in the plant. It's really not a new concept or a new process for us, we've been doing it for a long time.
I think the hard part with this has been, how do you codify or put something together that you've been doing via a generic letter or those types of things over a number of years. We, in particular with some of our older plants went to that.
With the newer plants it becomes a little more difficult I think. We do use special treatments.
And the special treatments are going to come out of codes and standards. And they'll come out of how we're treating them. So again, I think we see NSRST and NST as truly a feature of the advance plants and not really a flaw going forward.
Next slide. So, what special treatment does is provides increased assurance beyond the normal industrial practices. So although we may use
90 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 commercial codes and standards in some applications we likely are going to put special treatments on depending on how that fits together.
The example I'll give, again, is that in the past coming up over the years we've had rad waste QA, we've had PA-QA, we've had ATWS QA. And what did those special treatments do? They really put additional requirements on that we, as an industry, thought were necessary to make sure that things were better from a fire protection point of view, from an ATWS point of view or from rad waste point of view.
So again, this stuff really isn't something new to us. I think it's just a different way of characterizing it. And I do think sometimes we get wrapped around the words and the meaning for special, for treatment.
Endorsing commercial codes and standards as acceptable in normal industry. It helps us provide the appropriate qualification and special treatment we think for things going forward. That's not always a clear, how to do that.
All
- right, next slide please.
Harmonization. I'm going to talk two things. One is Part 53 rulemaking. And I think Part 53 rulemaking generally says, design license should use generally
91 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 accepted consensus standards.
Again, we get wrapped around the axle of what does generally accepted mean. I'm not sure any of us quite know what that means. It means accepted.
We do design using generally accepted consensus standards. As other folks have mentioned, it's we use the bits and pieces and parts that we think are needed in parts that are used.
One of the other difficult things has been the use of international codes and standards not previously used in the NRC licensing. Some of that I think comes up with the difficulty that some of the IEEE standards are now international standards just in their nomenclature.
And there are some opportunities, I think, for us to use the other international standards.
The difficult part for us is we have to recognize that we're not only a U.S. reactor supplier we're also a world-wide reactor supplier. So I think some effort and some challenges that maybe used in those accepted standards could be really helpful. It could be through generic endorsements, it could be through online application specific basis, which is kind of what we're doing right now. It's going to be online, going to be application specific basis.
92 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 And I think the other hard part to this is, as we mentioned earlier in a couple of these presentations, there are multiple areas where clients exists of using various different standards. A couple IEEE standards come to mind. There is other standards as well.
Next slide. We do recognize that regulations, our codes and the standards, aren't always consistent. In fact, one of the difficulties we have is the application IEEE 323 which, depending on the reg guide you look at, depending on how it all fits together, they're not consistent. And we recognize that. That's just a part of what we're doing.
There is some harmonization trying to go.
I doubt if we'll ever make sure that Section III, Division 11 agrees with OM QME. Those are the nuclear standard sides, but it also kind of goes with such things, AG-1, where we talked about a little bit, about dampers and how do we deal with dampers.
I think we're working towards that. We're not there yet. This will be a long, long process.
Again, ARCSC is doing a great job with trying to, trying to do that.
I already mentioned the Part 53 and IAEA codes. And the piece I do appreciate, what James did,
93 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 was he did a great job putting together all of those codes and standards. I think probably 95 percent of those that he mentioned are applicable to all those advance reactor designers. Again, I had an idea what he was going to present so I didn't really go back over them what it means.
This doesn't mean, however, that all requirements are ways of two outcomes have to be identical. There is a typical design approach difference, whether you look at some of the IAEA codes, if you look at some of the general codes. We all have a little bit of a different design perspective. I think that's the hard part in sort of determining which particular codes in the standards to use.
I think this would help both applicants and regulatory staff in the licensing process. I'm not going to say it's going to make it easier, I'm just going to say it's going to help. So, and I think as we struggle through the risk-informed probability basis, probabilistic methods, it may help us as well because I tell you, we are struggling with risk-informed and codes and standards. Codes and standards tend to be very deterministic and very set in their ways.
Risk-informed perhaps not so much.
Next slide. So, what is sort of the human
94 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 element, how does it impact the quality group classifications? As I kind of mentioned before, if we can't figure out how to do the risk-informed piece we tend to go back to deterministic methods. I think seismic is probably a good example. Draft Guide 1436 is a fairly decent example.
18-04 in Reg Guide 1.233 is not necessarily consistent with other regulations as well. Safety significant functions, rather than overall safety classifications, again, that has been a challenge for us. Even in particular of deciding which code and standards to use. I think there perhaps exists the potential for new proposed requirements to do a broader scope. And I think that's going to come with more, I think discussion with NRC over the next few years as we go towards commercial application.
Next slide. So what is Natrium doing?
We do have a non-nuclear code of record. And specifically the things that we called out were things that are for the energy island. They're saying we have nuclear island, we have an energy island.
We do have a code of record action plan.
We are considering all IEEE and other standards as part of our electrical and I&C design. Our difficulty with our non-nuclear code of record and our code of
95 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 record action plan that we're struggling with is sometimes we use different versions of the same code.
For instance, if a code has been endorsed by the NRC for the nuclear island, however, we have a very similar component on the energy island.
We do tend to use later edition if it makes sense for us. It just becomes I think a hard part if Bechtel for us for example, is doing construction on both sides. Or for us doing procurements. It really would be a big help for us to do procurements if we can somehow resolve a non-nuclear code of record with a code of record. We haven't quite figured out what we're going to do with that but I think we're on a good path. But understand that the same, a different edition to the same code for different parts of the plant becomes difficult as we try to standardize components across the enterprise.
Next slide. I really tried to keep this to the 15 minutes, I think I went 16 so I think I'm all right. Do we have any questions for me?
MR. GASCOT: Dave.
MR. UNIKEWICZ: Yes, Dave.
MR. RUDLAND: Hey, Steve, it's Dave Rudland. I'm kind of wondering why does that happen that you have different versions of the code, is it
96 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 just because things were being designed at different times?
MR. UNIKEWICZ: No.
MR. RUDLAND: Why do you --
MR. UNIKEWICZ: I think it's because there were some of the older codes that are endorsed by the reg guide and some of the newer better editions of the code are being used in the commercial end of it. That's all.
MR. RUDLAND: Okay. All right.
MR. UNIKEWICZ: So, and it's really just a matter of, how do we ask you to update a reg guide if we're the only people using it, right?
MR. RUDLAND: Yes. Yes.
MR. UNIKEWICZ: I think it becomes difficult ask sometimes. But understand, it does become difficult from us from trying to keep costs low on a commercial island versus on a nuclear island, so.
MR. RUDLAND: Okay. Yes, thanks.
MR. GASCOT: Any other questions for Steve? Bill?
MR. RECKLEY: I was just wondering, at what point during the licensing process do you fully commit to a code or standard? You know, you have a CPE application and now there is somewhat unresolved
97 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 issues, so when does that --
MR. UNIKEWICZ: It's going to be --
MR. RECKLEY: -- does --
MR. UNIKEWICZ: It's going to be an FSAR submittal. We'll have those discussions with NRC Staff. We don't expect an awful lot of changes, we do expect some code changes. So, which will be upon an FSAR submittal.
MR. RECKLEY: Thank you.
MR. GASCOT: Any other questions? Okay, thank you Steve.
MR. UNIKEWICZ: Thank you.
MR. GASCOT: And we'll go with Jason.
Jason, are you here? I see you but I don't hear you.
MR. CHRISTENSEN: I am here.
MR. GASCOT: Okay, perfect. The floor is yours. Thank you very much now. Now, Jason Christensen from INL.
MR. CHRISTENSEN: Hey, good afternoon, everyone. I know my title here is a little different than what we had on the agenda and I'll get to that in just a second.
So, yes, my name's Jason Christensen. I'm Senior Regulatory Engineer from Idaho International Laboratory. And I've been working with Chris Cook and
98 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 Christian, you know, on this collaborative effort.
And so, I'm going to talk a little bit about codes and standards and licensing activities today and what we -- part of that is going to entail how we plan to complement or assist NRC in their action plan in this area.
You know, this whole thing -- you can go to the next slide, please?
Yes, so, the collaborative effort was really developed in 2023. And we've talked about this before with our then NRC Chair Chris Hanson and the INL Director, John Wagner.
So, really, what we are doing is getting, you know, getting together with NRC and working on looking for new and novel ways to endorse codes and standards more efficiently. I won't spend a lot of time here because we've discussed this before.
Next slide, please?
So, as Chris talked earlier, the NRC action plan, you know, the categorization of items into the three different areas, the development of process improvements, endorsement enhancements, and leveraging commercial and nuclear consensus standards and other efforts. The 17 actions sorted in those three areas.
99 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 So, I'm going to talk now for the next few minutes about how we plan to compliment that and then what -- one of the big pieces that I think the lab and the DOE side of things can do going forward to support this effort, and specifically support what we're talking about here today.
So, next slide, please?
So, we're going to talk about situations to avoid being addressed by the collaboration. And Chris and Christian talked about this earlier.
You know, I think the big one to really emphasize here is avoiding making it all the way to NRC endorsement time where there are major disconnects between the code and what NRC has in mind there.
So, you know, the big thing is getting out in front of this and becoming more proactive and active in the code development process so that that endorsement process at the end becomes smoother and more efficient.
Next slide, please?
So, when I developed our action plan, I really put it into four major areas. So, number one being the unified priority list. And this goes right along with the NRC action plan.
We have lists, and you saw the vendors today discussing their areas of need and ARCSC today, you
100 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 know, has developed a large list of that. And I think what, you know, I would like to focus on going forward and working with NRC is where we get a couple items to start.
And you know, we've talked about some ideas there, but, you know, opportunities like this help us kind of narrow that list and get a specific item or two that can really be the stepping stone for implementing the NRC's action plan and getting, you know, things a little more efficient.
So, we're going to help develop that priority list. You can see, there's a lot of different areas. These things come from a lot of which today we've seen in the presentations here.
So, presentations like today really assist in the development.
Next slide, please?
So, one of the areas that I know can really actively participate and utilize is our broad resources and the National Lab complex as a whole, but specifically what INL -- the capabilities that INL has in house.
So, you know, from the determination of these codes and standards, we can really take a look at where we're having an impact currently and where
101 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 maybe we need to refocus that impact or get some support, you know, with that committee where we can kind of, you know, break the ice between, you know, utilize our capabilities to help drive a more efficient licensing
-- or codes of standards process and then get it with NRC and support the actual endorsement of that process.
So, and we have a lot of capabilities at the lab and across the complex. Specifically, you know, I work for the Regulatory Development Program.
We have a lot of capabilities in that program to utilize different National Laboratories and all the capabilities across those labs.
So, you know, one of the big things for us would be to, as we identify these items, develop a deliverable and a work package through DOE to actually fund that activity through the National Lab program and help endorse -- or excuse me, and develop that code and standard and work across industry and the NRC and DOE to get that implemented.
Next slide, please?
So, the third part is really just providing assistance to the NRC. And I know that's very generic, but again, you know, have the wide range of capabilities across INL and the National Lab complex and we're experienced in how this process works.
102 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 So, you know, between assisting in the development of the code and then, you know, moving towards a regulatory development type program where we assist the NRC and any enhancement -- or in their endorsement, excuse me, of the code or standard, you know.
One of the big areas is we have the capability to kind of test out some of these codes and standards. And a couple years back, we did a program where we had a work package that developed an accelerated materials deployment process. And we're looking at potentially getting back into that, so --
and developing it further.
But that was really the good starting point for how do we endorse, say, a material -- how would NRC endorse a material that maybe hasn't gotten the full testing ability while -- or the testing range of data that's necessary?
But allowing industry to take on the risk of utilizing a material, knowing that we're getting that data -- that operational data as we go along in analyzing it as the reactor is operator is operating down the road, and then making a decision as to whether that material's still safe after so many hours, collecting that data, and utilizing it towards a full
103 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 endorsement so that material's standard.
So, you know, another area assisting in the development of reg guides and that endorse these commercial codes and standards. So, we're really looking to be an assistant to the NRC in their process of enhancement and getting involved in codes and standards.
So, next slide, please?
And again, back to leveraging the INL capabilities, you know, coming through the laboratory, you know, we have a lot of capabilities, both, you know, testing and materials. You know, everything from the advanced test reactor to the NLC complex, and so much more.
Wee also host the National Reactor Innovation here under Brad Tomer. So, that's under the Nuclear Science and Technology directorate here at INL. So, that program is specifically developed to, you know, actually build and assist in the actual testing and deployment of these reactors and do work associated with the actual, you know, development of new processes going forward to get these reactors moving and tested.
The DUN facility, for example, the Lotus facility out at the Materials and Fuels complex, ALDA
104 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 support, DOE authorization and testing of new reactors.
So, one of the test cases we have ongoing that's funded by DOE-NE for the regulatory development program right now, well, it's a potential test case for this item. But it's something that is actually ongoing is the revision and support of the endorsement of the sodium fire consensus standard, ANS 54.8.
So, that was previously endorsed in 1988.
It was withdrawn because it was not necessary anymore in 2000. But with the new advancements in technology here, it's becoming clear that this is a necessary code to be endorsed again.
So, we have funding and that's actually working through Argonne National Lab pretty heavily.
And so, if anybody needs more information on that or would like to talk more about that, please feel free to reach out to me. You know, the progress is going well, so we're looking at having that done in the next, I believe, fiscal -- in the next fiscal year.
So, next slide, please?
And just a sampling I wanted to throw in here of the capabilities that we have at the lab to support these processes.
You can go to the next slide, please.
So, a little taste of the DOE authorization
105 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 process versus the NRC licensing process when it comes to codes and standards activities.
So, 10 CFR Part 830 is the DOE Reactor Authorization and Oversight part. So, I'm not heavily experienced in that area, but becoming a little more dangerous every day in it.
So, we're moving toward, you know, working between the two processes and trying to determine where they match, where they don't match, and where areas of efficiency can be gained here.
So, the DOE process allows for alternative methodologies to demonstrate the safety and compliance of a new reactor. So, things that are listed under Part 830, excuse me, as well as methods that the NRC has, such as Part 50 or 52, Licensing Modernization Project, et cetera.
And then, it also allows a combination of both these methods from both the DOE and NRC methods here.
So, really, efforts are underway to utilize and pilot the NRC advanced reactor licensing approaches and gain efficiencies with future NRC licensing here.
So, again, and we're all familiar with the NRC licensing process here under Parts 50 or 52, and then, coming up with Part 53. So, the codes and
106 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 standards endorsements under 50.55(a) in the regulatory guides for endorsement of certain codes and standards there.
So, next slide, please?
So, really, there's two questions when it comes to moving from a DOE authorization to an NRC design certification and license.
And I will admit that I thought answering these questions would be a lot easier than they have been. And so, today, I'm going to give an intro into what we're looking at. And then, I'm going to give some possibilities or work going forward -- that we're considering for work going forward.
So, really, what is the transition path from a DOE authorization or DOE authorized reactor to an NRC licensed reactor?
And that really hasn't been mapped out fully. So, is there an efficient and effective pathway?
And then, you know, what can we do -- is there a potential activity going forward under DOE funding for the development of, say, a crosswalk between a DOE authorization and NRC licensing?
So, that's one of the items going forward that's being discussed and considered.
107 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 And then, the second, you know, the second area's really a major question for the future exploration. You know, what codes and standards are acceptable for use in the DOE authorization that maybe would not be accepted for us in NRC certifications or licensing applications?
So, you know, the one big example that I get a lot from INL staff is the use of USGS surveys for siting evaluation. Again, not my area of expertise, but it's one that I get a lot. So, you know, that's a good starting point for me and for people working down the road here.
So, really, what we want to do is identify where the gaps are here or where the differences may lie and then, present them and see, you know, how do we really move from a testing platform under a DOE authorization to an NRC certification or license most efficiently?
So, next slide, please?
So, really, our path forward, we've discussed a little bit of this before, is really assisting the NRC. You know, they're -- the NRC's the lead here. I want to, you know, emphasize that we're in a support role.
You know, the NRC is the licensing
108 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 authority and, therefore, we want to be able to support and help make things more efficient and productive.
So, our path forward is going to continue these collaborative efforts with the NRC and will really include coordination with industry and other organizations. And that's through public meetings like this and through industry opportunities, you know, with NEI and other organizations.
So, we're going to continue that work to revise and support the NRC endorsement of the sodium fire consensus standard, ANS 54.8. As I said, that is underway and is moving quite well. And I'd be happy to discuss that further or put you in contact with the folks are Argonne that are doing the work there.
And one thing is we're going to explore that possibility of DOE funding or a crosswalk between a DOE authorization and an NRC license of advanced reactors and micro reactors.
So, what we're -- one of the items we're looking is where that's best funded and where it's best performed. Would that be under the regulatory development program or would that be under the National Reactor Innovation Center? We have a lot of discussion to go forward on that and see if it's a good possibility for work in the future.
109 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 And then, finally, we're just going to continue exploring which codes and standards would be acceptable for a DOE authorization that maybe would not be accepted or would be treated differently for an NRC certification or license.
And again, I want to emphasize that saying one is acceptable for one -- for a DOE authorization and not NRC doesn't mean one is a better pathway or, you know, it's just mostly just how information is used and what's required to be independently done in that?
So, you know, we want to really figure that out and we're soliciting your input for this. Again, I've gotten a lot of information on the USGS surveys, but, you know, we really want to solicit from the industry, from organizations like NEI, and breakthrough and the NRC, you know, areas where we know that there are differences and opportunities for gained efficiencies across the two processes.
So, with that, that's my last slide and I want to thank you for the opportunity today and I will turn it back over to Ramon.
MR. GASCOT: Thank you, Jason.
Any questions for Jason from the -- okay, Chris?
MR.
FANNING:
Appreciate your
110 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 conversation on what INL's doing.
I'm from Radiant Nuclear. We're working with INL and he UNRA team to bring a micro reactor to the DON facility. And so, the topic of DOE authorization and how that can translate to an NRC licensing is of great interest.
You mentioned you're trying to decide who will lead and fund that effort. And I guess what I'm interested in is what is the time frame? Like, can you get that done this year? Will it be done next year?
And what would the final product be? Would it be a topical report or a white paper? How do you envision that?
MR. CHRISTENSEN: So, you know, when it comes to funding, as you all are probably fully aware, you know, we have -- we do get our funding from DOE and that is sometimes a tricky process.
We've been on a continuing resolution, which means our funding's going to stay the same over the past few years. So, this was not an item that we targeted for this fiscal year.
However, with the opportunity that a budget may come around, you know, it's going to open up opportunities for us to present this.
So, I would say, you know, we're looking
111 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 at within the next -- getting started, you know, this year or in the next fiscal year on that type of a process.
But we do have to look going forward and see --
determine who's going to -- who would do the work.
It would likely be, you know, a joint project with a couple of different folks. But, you know, we do have to look going forward as to when we can fund that and who would do the work.
So, my hope would be to done soon, for sure.
You know, it may involve waiting until the beginning of fiscal year '26, but I would really like to push this forward and develop the idea more thoroughly in the near future.
MR. FANNING: Thank you.
MR. GASCOT: Jan?
MS. BOUDART: Yes, somebody unmuted me, okay.
My question is -- oh, there's a lot of feedback. Is it -- can you understand me okay with the feedback?
MR. CHRISTENSEN: Yes, I can hear you.
MS. BOUDART: Okay, my question was about the seismic standards for the DOE and the NRC. And I'm wondering if you could give me any example of the difference between the DOE standard and the NRC
112 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 standard?
And there must be a document from the DOE and from the NRC that outlines these standards and where would I go to look for that? Or can you give an example?
MR. CHRISTENSEN: Yes, so, this is one, unfortunately, I'm not a seismic guy, but going, you know, in the very, very near future, I will be digging into this and I would be happy to reach back out to you with more of that information.
But right now, what I've been told across the laboratory is, you know, there is a difference there and I think it just comes down to where you get your information and the independents behind the siting process.
MS. BOUDART: Okay.
MR. CHRISTENSEN: So, I would be happy to provide more information as I do my research and dig into this further. So, if you want to reach out, that would be perfectly fine and I will get that as soon as possible to you.
MS. BOUDART: Okay.
Do you want my email or do you want to give me yours?
MR. CHRISTENSEN: Mine is in the last slide if you want to take that. I believe it's in there.
113 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 I think I put it in there, if we can go back one? Yes, it's in the last slide there before the INL slide.
MS. BOUDART: Oh, there it is, Jason Christensen at INL dot gov (jasonchristensen@inl.gov).
MR. CHRISTENSEN: Yes.
MS. BOUDART: Jason Christensen, thank you.
MR. CHRISTENSEN: It looks like we have a comment in your -- with the DOE side of things as well.
I was hoping to have more research done coming into this meeting, but, you know, still working on it.
And it looks like Chip indicated, it's DOE Handbook 10/20/2016. That's a good place for me to start here.
MR. LAGDON: Yes, DOE Standard 10/20/2016, Natural Phenomenon Hazards, DOE uses a graded approach as defined in DOE Order 420 because reactors have higher mar than the typical DOE facility, so they use a graded approach. But they reference the same standards that the NRC uses.
MR. CHRISTENSEN: Great, thank you.
MR. GASCOT: Chip, so, Don?
MS. BOUDART: So, what would be the NRC
114 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 book or rule to look at?
MR. CHRISTENSEN: I will have to get back to you on that one.
MS. BOUDART: Okay.
MR. GASCOT: And Don, you have a question?
MR. EGGETT: Yes, it's more of a comment back to Jason.
Currently, and I thought I alluded to that in my presentation earlier that ANS 54.8 has been, if you want to call it, resurrected and it's going through the process, okay, of being revised on an expeditious basis.
So, the users, okay, will have it hopefully by midyear of 2025. That's the goal right now.
And then, once that is complete, the intent and objective is to take that same standard and employ risk informed performance based approaches and methods into that particular standard where it may be appropriate and revise that. And that's scheduled for 2026.
So, I wanted to share that with you, Jason.
And if there's some way that, you know, if we're all working together on that, and there's, let's say, Argonne representative on the working group or consensus committee, that's great. I just don't know
115 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 specifically.
MR. CHRISTENSEN: Yes, I know that Dave Grabaskas and the INL -- or the ANL, Argonne National Lab, team have been the lead in that project.
MR. EGGETT: Good, okay.
MR. CHRISTENSEN: I, you know, I'd definitely be happy to put you in contact.
And Jan, it looks like Jon Facemire has identified the reg guides that that is in. So, thank you, Jon, I appreciate that.
MR. GASCOT: Jon, we just got two reg guides in the chat. Do you have any other questions?
(No audible response.)
MR. GASCOT: I cannot unmute here, so I don't know if she has a question or not.
MS. BOUDART: No, I don't have other questions.
MR. GASCOT: Okay.
MS. BOUDART: The note in the chat, I have copied.
MR. GASCOT: Okay, perfect, thank you.
So, thank you, Jason, for your time and your representation.
MR. CHRISTENSEN: Thanks, everyone.
MR. GASCOT: Now, we're moving to the last
116 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 presentation today which is from Westinghouse and it's going to be from Stu Kellner. Stu, are you here?
MR. KELLNER: I'm here, can you hear me?
MR. GASCOT: Yes, we can, thank you very much, the floor is yours.
MR. KELLNER: Great, thanks, Ramon, and thanks for the opportunity to present here today.
My name's Stu Kellner, I'm a principle engineer. I'm in the Test Reactor Engineering Group at Westinghouse. And I'll be talking about perspectives on non-nuclear standards for advanced reactor development, specifically for the eVinci Micro reactor.
Next slide, please?
So, I think it's helpful to set the stage on some of the differences in the design solution.
So, our particular reactor, the eVinci, is a five-megawatt electric micro reactor.
It's a heat pipe reactor, so, it's passively cooled and it's at low pressure. So, high temperature but low pressure which creates some differences in current codes and standards out there today.
We are using TRISO fuel as part of the safety case. And again, it's a five-megawatt electric
117 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 reactor. We're looking at -- if you go down to the figure at the bottom of the screen, we use control drums to control reactivity.
We have diverse and redundant reactivity control with control drums and shut down rods with the export housing sticking out on the left hand side of that figure.
The core in the middle with the heat pipes extending through a graphite moderated core and into our heat exchanger which goes out to a Brayton cycle for power conversion.
The TRISO is 19.75 percent enriched U2-35.
So, there's some significant differences whenever we look at this particular design solution compared to conventional light water reactor designs. And that's been a theme throughout.
And it is important to note whenever we get into differences and reasons why we're looking at some of these different codes and standards and ways in which they get endorsed for the specific design solution with the limit states that are applicable for these particular safety cases.
So, the next slide, please?
So, hopefully not sounding like too much of a broken record, but I think a lot of the themes
118 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 here on my slide are similar to what other presenters brought up earlier today.
So, with regards to eVinci, we are utilizing commercial codes and standards. We're classifying our SSCs using risk informed performance based licensing modernization methodology.
I think James did a great job of outlining a lot of the commercial codes and standards that are being used. We're using a lot of similar codes and standards.
We're planning using similar codes and standards. I listed some of those here, AISC, ACI, ASCE, ASME, both Section 8 and B31, and in B31-3.
We are augmenting these with special treatments and we have developed a process to bring those in through requirements management process where we're bringing those in specifically as engineering requirements.
I think this is extremely important whenever you develop a design because the design staff working might be familiar with the design code, but might not be familiar with the specific special treatment. So, it's important to emphasize to the design office what are those special treatments and how they get implemented so everybody's on the same
119 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 page whenever they work through the design details.
We're also developing eVinci specific qualification methods. So, this is extremely important and it's necessary because of the differences in the safety case. We mentioned TRISO, but being at low temperature and high pressure, you end up with different limit states than what are in current codes and standards, both on the nuclear and non-nuclear side.
So, it's important whenever you're working through these that there's flexibility and understanding, one, what is the specific design solution? What are the limit states that are applicable in the codes and standards? How are you going through and justifying for your particular safety case? How you're meeting, you know, principle design criteria that's applicable across the board?
But I think a theme that I wanted to bring up here is that there is flexibility and it's necessary whenever you go into and look at qualification methods that are unique to specific technologies.
So, we've kind of been through this. I think one example from Westinghouse's perspective is working through AP1000 on structural modules. And there's a few examples from AP1000.
But that's a good one where there wasn't
120 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 a code or standard developed whenever we went through RDCD for structural modules. So, we worked with industry. There's a lot of testing that happened both from AP1000 and prior.
So, standing on the shoulders of giants and the codes standards that have been developed, but augmenting and understanding exactly how it applies to your technology is important.
And then, having that as a basis to support inclusion into codes and standards is a use case that Westinghouse has been through in the past and industry's very familiar with that process.
This isn't entirely something new, it's just how it applies to these advanced reactors is new.
There's a bullet below as well for the DRAP and RTNSS work we've done in the past. So, the reliability assessment and regulatory treatment of non-safety systems.
So, whenever we looked through and look at special treatments, those are examples of places where the equivalent of special treatments were utilized in the past for AP1000.
The next bullet point
- there, so, Westinghouse, like some of the other speakers mentioned, we are active in a lot of the nuclear codes
121 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 and standards, so ASME, significant involvement and volunteering in Section 3 and a lot of work and volunteer work in Section 3 V5 to support that development.
AISC, ACI, ASCE, IEEE, we try and stay active in those codes and standards committees. And they do have a sister commercial codes that where applicable information flows between them. It's not a seamless communication, but as information gets brought up in committees, there is communication between nuclear and non-nuclear codes and standards.
So, I mentioned the DRAP and RTNSS program in the licensing from AP1000, using that experience for the eVinci and its development.
What we've been doing with eVinci, and I think it's key is getting everybody on the same page early in the process, so pre-application, regulatory engagement through white papers is something we've been utilizing. I have a slide on some of those, but we've presented on those in the past.
It's important to understand and get on the same page of what that safety case is, what's important, you know, what margins are available, how you're going in developing your qualification methods and the testing that's going to be used to support those methods for qualification so that you can understand
122 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 what the priorities are, what may be the bottlenecks early in the process so that both sides -- all sides can understand where to prioritize the work that's necessary in codes and standards or internally to the vendor.
And the last thing I wanted to bring up was we are working with INL, NRIC, and DOE to develop a nuclear test reactor, that's my group and what we're responsible for delivering.
So, there is a significant benefit in going through use cases of a test reactor and working through a process for that test reactor that's at lower power, scaled for and authorized under DOE.
So, we've gone through multiple rounds of electrical demonstration units as well. So, it's really helpful to take those steps and understanding and identifying gaps so that you can really, as you get into more and more detailed final design for the commercial product, you really understand what those priorities are, where you want to prioritize resources and understand truly what the gaps are.
So, with that, I think I have two more slides. The next one, I think we can run through probably both of these and I can open up for questions.
But these are just the list of our white
123 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 papers that we've developed for pre-application engagement with the NRC. And we've appreciated all the feedback we've got on these and the interactions we've had so far.
And then, this is just the slide of our electrical demonstration unit and taking those steps along the way to really understand what codes and standards, where the gaps are, what we really need to develop. And then, also having the data that's necessary in some of these cases where justification outside may be what's in a code or standard explicitly is necessary in order to get by them.
I think I have one more slide, but I think it's just a -- yes, it's a closing slide.
So, again, I want to thank the NRC for the opportunity to present the Westinghouse perspectives today. And if anybody has any questions, I'm ready to field those.
MR. GASCOT: Any questions for Stu from the audience?
Tom?
MR. ROBERTS: Hi, I'm Tom Roberts. I'm actually the Chair of Section 11, Division II.
I'd like to tag on to Stuart's presentation. But to all the other presentations,
124 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 because I've heard the same thing discussed several times.
And although everyone -- well, not everyone
-- many of the presentations said it, they didn't focus on one of the very different philosophical changes that at least the nuclear codes and standards need to recognize as part of future development.
And what I'm getting at is this, the ASME Boiler Pressure Vessel codes for decades has focused virtually exclusively on pressure loads out of concern from a situation of say some sort of catastrophic event, whether it's nuclear or otherwise.
With the advent of the advanced reactor community, there are many designs, you see where it says one, right, but there's others that are essentially operating at basically atmospheric pressures, where the Section 3 as well as Section 11 in service standards historically were never focused on.
It's entirely different safety case. It's an entirely different set of parameters that need to be evaluated.
So, I'm not criticizing because everyone said it -- well, not everyone -- many of the presentations said the same thing, but this is really more for the staff as well as other ASME members who
125 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 may be in the presentations today, that the inspection line at Division 2 has recognized this a long time ago.
We're working on that diligently to get the mind set off of pressure retaining considerations as the exclusive domain of the code, because that may or may not be appropriate for some designs.
It may be appropriate for some advanced reactors, that's true. But as the universal constant which is historically where the ASME Boiler Pressure Vessel code has always focused, it may be an inappropriate mind set to develop for future code actions.
And with that, I'd like to thank all the presenters here. It's been most informative to me.
MR. KELLNER: Thanks, Tom, great comments.
MR. GASCOT: Any comment or -- okay, Jack, go ahead. Jack, can you unmute yourself?
MS. BOUDART: Are you talking to me?
MR. GASCOT: No, to Jack, you'll go next.
MS. BOUDART: Oh, Jack, sorry.
MR. SHOEMATE: Jack Shoemaker with Material Resources.
I just wanted to echo what Tom said. He said it much more eloquently than I would have. But it is paramount that we focus on the true safety issues
126 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 with high temperature when we have virtually no pressure stresses on these vessels and pipe systems.
Thank you.
MR. GASCOT: Thank you, Jack.
Jan, now is your turn.
MS. BOUDART: Okay, I would echo that because the high temperature would lead to a probable ductility problems.
But my question is, do any of these safety cases apply to the production of the 19.75 enrichment of uranium that is going on in Pike County, Ohio? And how do you justify the use of this high enrichment among the people in Pike County who are in the area where this enrichment is taking place?
MR. KELLNER: Jan, I can speak for the eVinci. The enrichment is a part of the safety case.
So, the high assay, low enriched uranium that's part of the TRISO fuel that we intend on using is developed as part of our reactor specific safety case.
So, I can speak to the safety case aspect in that regard.
MS. BOUDART: Thank you.
So, I meant, not high enrichment, was it high enrichment, low -- no, I'm sorry --
MR. KELLNER: Yes, high assay, low
127 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 enriched.
MS. BOUDART: Okay, so is this called low enrichment when it's 19.75?
MR. KELLNER: Yes, the acronym for HALEU is the high assay, low enriched. So, it's on the high end of low enriched.
MS. BOUDART: Oh, I get it, thank you.
MR. GASCOT: Any other questions for Stu or comments?
(No audible response.)
MR. KELLNER: Thanks, again, for the opportunity, Ramon.
MR. GASCOT: Thank you, Stu.
So, now, we are moving to our open discussion.
So, Chris, go ahead. I think Jan just kept the hand.
MR. COOK: I think her hand's remained up.
MR. GASCOT: Yes, yes.
MR. COOK: You may be able to lower it, Ramon.
MR. COOK: I just wanted to, at the beginning of the open discussion section, first of all, thank all the speakers.
You know, really, it's the -- it's just
128 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 been fantastic, I think, to have this discussion up to this point.
I appreciate everyone accommodating, you know, our change, you know, so that, you know, we were having the meeting entirely virtually.
I'm very thankful, I've been watching the snow coming down here at the NRC. The building was a little closed up this afternoon, so I'm glad we worked ahead of time to have this all be virtual.
And I'm so pleased at the turnout. We got up to about, you know, 146 at one point. And we still have 108 people that are here. So, this is fantastic team as we get through the discussion.
So, I just wanted to take a minute just to thank everyone before we sort of have a period of time where we have some open discussion, looking more back at trying to, you know, digest what the presenters had together.
You know, there were a lot of themes, a lot of commonalities as you look at some of the priorities that were in there. But that was really, I think, the purpose of this time was to have an opportunity to just to have an open discussion.
Christian, I see that you're on as well.
I don't know if there's anything you wanted to add
129 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 before we jump into the open discussion just to kick us off and get us going?
MR. ARAGUAS: Yes, no, I think you've captured it. You kind of stole my thunder for the closing remarks, so I appreciate you doing that.
I think that this really covered what I think we were collectively, we, the NRC, we collectively looking to accomplish. And again, we'll have some more discussion here, hopefully, and see what more we learn.
But I think getting a sense of where the industry is and their desires to really help us inform what we may do and where we can help.
I think a lot of great information coming out of today's discussion. Some, of course, things we've known, but I think, also, just good to solidify that. And certainly, sharing that information among this collective group I think is also a tremendous benefit.
So, again, I think I also really appreciate the presentations.
And so, with that, Chris, I'll turn it back to you or Ramon to see what additional questions, comments, discussion that we want to have.
MR. GASCOT: All right, we don't have any pending questions, so any new questions that we have?
130 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 Okay, Tom, go ahead.
MR. BASSO: Yes, again, Tom Basso from NEI.
You know, after hearing a lot of the discussion and topic, I'm just wondering, is the NRC considering putting out any different guidance to the staff on the review of codes and standards, particularly as it applies to the advanced reactors who are, you know, we hear, you know, that the advanced reactors, the focus, in a lot of cases, shouldn't -- should not be on pressure retaining device or, you know, performance.
So, how do we get a different mind set or approach than the light water reactor approach that we implemented for the last 50, 60, whatever years?
And the review and the focus and what should be paid attention to so that, you know, some of these codes and standards can get endorsed and approved in a more swift manner?
And/or does the NRC considering the whole different approach coming out of the executive orders on is there a more streamlined way or a way that says, hey, we're part of the consensus process, we've voted positively on these things, why does it have to go through any type of regulatory approval?
So, those are kind of my higher level
131 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 thoughts and to just to see if there's any discussion on that and consideration.
Thanks.
MR. ARAGUAS: I'm happy to take the first stab at that and, Tom, thanks for your question.
So, let me maybe go to the last part of your question. So, I don't know that we're prepared to talk about sort of the approach for any of the executive orders.
But I think if I go back to your first question about any additional guidance to the NRC and how we engage on codes and standards or even streamline our processes, so I think what I would point you to, and I think you had mentioned it in one of your earlier questions you were alluding with Management 6.5.
So, that is the directive that we use for how we engage and how we manage our codes and standards program. So, we are looking to update our management directive. And if I kind of point out some of the things that we're looking to do, I tie it back to the NRC's action plan that talks about some of various activities.
And so, some of those we're looking at, you know, streamlining the endorsement process. I think Jason mentioned some of those.
I think even thinking outside of
132 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 endorsement, you know, how can we give some sense of NRC approval early -- earlier in the process?
And so, I think it's all on the table for us. I would expect us to issue some new guidance for staff for how we engage. But that's what we're looking at.
And so, some of the other things that we were looking into is how we engage on the various codes and standards committees? You know, I think it was either you or somebody else mentioned making sure that we have individuals that are bringing the collective NRC views to make sure that we're addressing concerns early to minimize or mitigate the use of some of the conditions that we see through the endorsement process, which can really delay the endorsement process in certain cases.
You know, I think that's an area where what we're trying to do under this focus on advanced reactors, primarily what we're trying to is get our hands around where are those priority standards?
You know, I just signed out to a handful of the SDOs letters today asking for what those priority standards are that Don, I think, alluded to.
So, we're looking to get this information here from this public meeting, future engagements,
133 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 feedback we get from those letters to think about how we prioritize the resources we have and then, also making sure that we're putting the right individuals to be engaged and we'll make sure that there's clarity on the roles and responsibilities they have and how they engage with NRC staff to bring those thoughts back and represent the NRC well.
So, I think, you know, the model's on the table MR. BASSO: Hey, Chris?
MR. ARAGUAS: I'm sorry, go ahead, Tom.
MR. BASSO: Go ahead, go ahead, I just had one more follow up, but go ahead, please.
MR. ARAGUAS: Yes, and so, where I was going to wrap up is, you know, we really are trying to look at how we can enhance and that kind of takes from the beginning of how we engage to -- and the various SDOs to -- toward the tail end of how we do our endorsement or even provide the funds up on, you know, what we think's acceptable for a code or a standard.
MR. BASSO: Hey, my follow up question is, I know that you guys, every year, look at your research and your research funding and where that's going to.
Is this going to play into it for 2025 or
134 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 is it too late for 2025? Or do you have the ability to kind of adjust what you're putting your resources on, if, in fact, some funding needs to go towards either material research or, you know, resources towards endorsing the priorities that are going to come out of this meeting?
MR. ARAGUAS: Well, that's a -- so, that's a great question. And I can't speak to the exact specifics.
You know, we do have some resources in '25 for research on various areas that support codes and standards. We have some for what, you know, what we need to manage the program.
You know, we'll look at direction we get as we get our budget. I will say, there are some flexibilities that we look to employ every year at the beginning of our fiscal year where we're able to --
we call a re-baselining of our budget, essentially where we're looking at what the needs are.
And so, there are always opportunities to course correct and we use those to the maximum extent possible once we know what the priorities are. And so, we'll continue to use those.
MR. BASSO: Okay, thank you, very good meeting, appreciate it.
135 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 MR. ARAGUAS: well, thank you for that.
MR. GASCOT: Mike Keller?
MR. KELLER: Yes, this is Mike Keller with Hybrid Power Technologies.
I'd just like to, along the lines of the two previous speakers, I'd like to put on the table a possible solution.
What we would suggest is list, say on the NRC website, consensus code standards involving NRC staff. It's just a simple statement of fact.
The applicant identifies their key consensus codes and standards including a summary of their special treatments.
Staff reviews are grounded in risk informed as linked to the applicant's PRA.
The approach sidesteps the endorsement approval effort which we view as a complete can of worms and keeps the efforts moving forward. In our opinion, the endorsement approval issue is a fatal flaw that causes licensing efforts to become badly wrapped around the axle.
Costs for all parties becomes stupefyingly and unnecessarily expensive. The efficiency of the Licensing effort plummets.
Now, this actually, in our view, pretty
136 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 simple to accomplish. It really doesn't require any particular regulatory efforts and bypassing 10 CFR 50.52, you can do this sort of thing, you know, if you say that's what you want to do.
But knowing what the consensus codes and standards are that have been reviewed by the staff, not necessarily endorsed but just that they're part of the process helps the effort quite a bit because now you have something you can deal with.
We have formally placed this approach on the table in conjunction with the proposed 10 CFR 53 comment process. So, it's, perhaps, an out of the box approach, but we think it's a practical way to keep moving and that's key if nuclear power is to actually be successful.
You know, we need to make the process more efficient if licensing is new advanced reactors. And right now, that doesn't -- that really isn't the case at all.
Thank you.
MR. ARAGUAS: Thanks for that comment, Mike.
MR. GASCOT: Thanks, Mike, for the comment.
Now, moving to Jon.
137 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 MR. FACEMIRE: Yes, this is Jon Facemire with the Nuclear Energy Institute.
I guess I want to ask one broader question before I get into the comment. How does the NRC look at codes and standards differently for NSRST SSCs versus safety related SSCs? And then, I'll ask my follow up.
MR. ARAGUAS: And the pause, so, Jon, thanks for the question. I'm going to see if there's somebody from the NRC here that can address that question. So, give it a moment to see if somebody pops on.
MR. COOK: Kamal just raised his hand.
MR. ARAGUAS: Kamal?
MR. MANOLY: Yes, Kamal Manoly with NRR.
The review of the standard will be commensurate with the type of application they intend it for. So, again, it's really, we expect consistent with what Christopher mentioned, the first thing, we like to know what the applicant or the vendor is asking for.
And then, the review be following depending on what -- is it pressure boundary or stuff that falls within Section 3 or ANSI. So, it really depends on what the applicant is proposing to use.
Am I getting your question correctly?
138 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 MR. FACEMIRE: Yes, I guess some functions are more important than others, right, they're the functions that are required safety function under LMP that are necessary to meet the design basis accident criteria.
And then, there are some functions that may be NSRST that are only safety significant from a defense in depth perspective.
So, I think about some of the designs that are using functional containment, they're using TRISO fuel, so a primary coolant fluke might be -- it might still have the same function of pressure retention, but that pressure retention function is far less important if it is not, you know, performing a containment function as well anymore.
MR. MANOLY: So --
MR. FACEMIRE: And that -- go ahead.
MR. MANOLY: But I guess as an applicant, you will identify what standard you'd like to -- what code you want to use, what standard you want to use.
That's -- we don't tell the applicants what to use, they tell us what they're looking for and then, our review is commensurate with what they're looking for.
MR. FACEMIRE: Yes, so, I guess I'll get on to my follow on question.
139 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 Right now, Part 53 as written requires NRC endorsed codes and standards for both safety related and non-safety related but safety significant SSCs.
As part of our common package that we intend to send in shortly, we do not think that that is appropriate. We believe that it should be limited to safety related and that appropriate special treatment for NSRST SSCs should be assessed in a given application. Right? There shouldn't be a blanket requirement that endorsed codes and standards be applied to all NSRSS SSCs. And so, that's a statement.
And then, the follow on question is, could the NRC see a path forward where building on the NEI 18-04 guidance, right, if an applicant follows a process for identifying their codes and standards linked to the functions and linked to provisions and codes and standards, basically, these -- is there a path to the special treatment process being the scope of the NRC review for NSRST SSCs as opposed to the specific application of a code and standard for NSRST SSCs?
MR. ARAGUAS: And I'm going to see if there's anybody -- thanks, Jon, thanks for that question. Let's see if there's anybody from the NRC that -- oh, our expert, Mr. Reckley?
MR. RECKLEY: Thank you, Christian.
140 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 I won't comment on the Part 53, Jon, you know you can submit that as a comment and we look forward to it.
I will offer just I think we're seeing --
it was evident in some of the presentations today, and also in some of the ongoing reviews that we have in both pre-application and application space that it would be useful for us to engage you on special treatment and how it's used in NEI 18-04, 21-07, and the related reg guides and to try to clarify what is the special treatment.
Like you're saying, and what some of the presenters said today, the actual normal industrial practice is to use a consensus code and standard. So, it's not a special treatment. That's one way to look at it.
Another way would be, no, using a consensus code and standard is a form of special treatment.
We need to clarify what that means and then, what is the special treatment? For example, you --
could you just use the commercial code as a standard industrial practice? And the special treatment is more performance monitoring, less on the design side, more on the performance monitoring side.
So, I think what we'll do is, us and NRR,
141 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 DANU, will engage you, Jon, to say, let's have some meetings, let's talk about what guidance we might be able to develop to help in this area, special treatment, including commercial grade, commercial codes and standards.
MR. FACEMIRE: Yes, and I do have, based on recent reviews, right, that more has been asked beyond the commercial code and standard and identifying what is enough, using the term from Rev Guide 14-36, what is appropriate justification?
MR. RECKLEY: Right, so, let's -- I'll take that as an action and we'll engage Ramon and Christian and Chris and others to make sure we, you know, we're coordinated. But this is also an activity, I think, that we're seeing an ongoing reviews for both TerraPower, Xenergy, and others.
MR. GASCOT: Okay, now it's Don.
MR. EGGETT: Thank you, Ramon.
Just a general comment, I think, to everyone still, okay, on the call. I understand this was orientated toward commercial standards, and that's great to learn more about it and how the application could be really applied to, you know, designs for advanced reactor technology, et cetera.
I didn't hear too much about risk informed,
142 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 performance based. And I realize this wasn't the topic for the discussion. It came up in a few of the presentations or maybe all of the presentations, but
-- and it's also come, okay, in 53.1, or I should say, Part 53 rule.
And it's an option, and it's a flexible option, too, the licensees.
We have an action item, that is, ARCSC has an action item to get our hands around it, if you will, and determine if there's a really a need for a generic industry document on RIPB that, collectively, the industry, together, see the need for it.
I think we do, and I do know that the NRC believes that, too. And I do know that NEI does, too.
It's just a reminder for all of us to be on the same page and kind of like move forward together.
And it's significant in its own entity, if you will.
So, I think, in the long run, it'll be a valuable, you know, product, if you will, for the designers, those who wish to use it, even for those, okay, are still operating, you know, their current of plants, et cetera.
So, just wanted to make that comment and leave it with everyone to think about.
MR. ARAGUAS: Thanks, Don.
143 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 MR. GASCOT: Thanks, Don.
So, now, I'll move to Fred.
MR. GRANT: This is Fred Grant from Simpson, Gumpertz, and Heger for an engineering firm working with some of the advanced reactor developers and help creating risk informed, performance based designs, and so on.
Thanks for taking my question, I realize I'm a couple minutes over, so I'll try to keep it short.
I'll actually frame it more like a comment.
You know, as I'm listening to this workshop, I was trying to get some clarity on exactly what the scope or objective is here. Right?
We're talking about maybe NRC endorsement of commercial codes and standards for use in advanced reactor design deployment. I'm not clear yet whether we're talking about NRC endorsing commercial codes and standards for like NSR structures, non-safety related, which I think probably isn't necessary because, you know, nuclear power plants have used commercial codes and standards for non-safety related stuff for a long time.
Turbine buildings are built to building codes and there's no problem there.
Maybe we're talking about commercial codes
144 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 and standards for non-safety related with special treatments. That gets back to Jon Facemire's question and the answer there.
And I think the answer I heard was that the NRC will review the proposed codes and standards on a case by case or application specific basis which kind of makes sense to me. But it also obviates the need for an NRC endorsement of a commercial code and standard for that application.
So, maybe the answer is, we're looking at NRC endorsement for commercial codes and standards specifically as they are used to define special treatments. But that sounds like it would be really hard thing to do. It would never be sort of a stay endorsement of a code, right, because like the commercial codes and standards are not developed or intended for use in special treatments for nuclear plants. Right? They're intended for other non-nuclear purposes.
So, that could be kind of complicated.
I like the idea that was brought up just in the previous speaker about the industry working with NRC to develop some guidance on, you know, how do we use commercial codes and standards to develop special treatments.
And then, you know, I guess maybe what we're
145 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 talking about, lastly, is commercial codes and standards for use in, you know, design construction of safety related SSCs. That makes sense to me and maybe there's some room there.
But I didn't quite get the signal here from any of the presentations yet which of those options are we talking about? Are we talking about endorsing commercial codes and standards for safety related, non-safety related, special treatment, just the special treatments or non-safety related?
MR. COOK: Christian, you want me to take this one?
MR. ARAGUAS: Sure.
MR. COOK: So, I'm going to take you back in time to we had a workshop on April the 4th. And in that workshop, we were there looking at the codes and standards program. And that was really what was the genesis and started us with this code and standards action plan and we published that in August.
And now, we're looking at the 17 items that were in there.
And I think your question dovetails in exactly where I think we sort of set up the purpose for this meeting was to have that discussion. Because I think no one articulated what you just commented on
146 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 and we have a court reporter that is recording it, that that is a great nugget that we need to take back.
We need it, you know, to also define, well, what is the difference between, you know, a traditional standard and commercial standard, let alone commercial applied to, you know, a special treatment structure.
So, we're evolving as we go through this and I think that's what you're finding.
And so, I'm going to, you know, we need to take that back and go in because I think you're spot on, and especially as we look at trying to, you know, have staff effort, you know, pulled in.
I mentioned earlier how much of a process it is to endorse something through a reg guide. You know, we're also looking at what would be more efficient.
So, this is the whole part of what we're doing is looking at the health and how to enhance the program. And I think your question falls right into really where we need to go to start looking at efficiencies.
So, I thank you for question, the comment, and yes, it's right on. And I think this workshop is, you know, serving its purpose because we're bringing these things out. So, thank you, Fred.
147 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 MR. GRANT: Okay, thanks, Chris.
MR. ARAGUAS: I know, Ramon, we're over, so we probably need to cap it and be respectful of peoples' time. I see that Mike Keller has another question. And then, we'll see if Kamal had anything he wanted to add to the responses that we had.
MR. KELLER: Yes, yes, we agree with the NRC that the applicant needs to link specific safety functions to their codes and standards, including the special treatments that they want to apply.
We think the roadblock is the endorsement of approval process that is really time consuming.
I think we collectively need to come up with a more efficient way to get out of this, what we view as kind of a box canyon.
Thank you.
MR. GASCOT: Okay, Kamal, any comment?
MR. MANOLY: Yes, just specifically, with regard to the need for standards to address the risk informed, performance based, that's precisely what Section 3 recognized in considering the creation of new Division 6.
And that was discussed in the last ASME meeting and will be the topic of the first discussion in the May meeting. ASME recognized that need and we
148 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 support that endeavor and definitely be strongly participate in that.
MR. ARAGUAS: Okay, thanks for that, Kamal.
And I'm going to bring us to a close. So, I know we're eight minutes over. I want to thank everybody for allowing us to go a few minutes over to continue that dialogue.
You know, Chris mentioned it, Ramon mentioned it, I think this has been a really, really fruitful discussion and I
appreciate all the presenters' time and I appreciate all of those that spoke up, asked questions, provided comments, all of that is extremely helpful for us to kind of flesh out what, you know, how we want to proceed and how we go forward.
So, you know, we will, as you heard, this is being transcribed. We will have a meeting summary that will accompany this as well. So, for anybody that wants to see either the presentation material or a recap of the discussions, I think that'll be really helpful.
And in the meantime, you know, Chris and I will continue to look for engagements over the fiscal year as we move out on looking at opportunities to enhance our codes and standards program.
149 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 So, I would ask that you keep looking out, we'll find a place to make sure that we share that information publically and other opportunities to engage. And I just ask and urge all of you that are still here to continue to engage and give us that feedback.
And I'll put a plug for, I think, the next engagement, we do have the NRC's Regulatory Information Conference that'll be coming up here in mid-March.
And there will be a session on codes and standards as well. So, I certainly invite those of you to participate in that discussion as well.
And with that, I bring us to a close. And again, thanks to everybody and stay warm. Take care, everybody.
(Whereupon, the above-entitled matter went off the record at 4:39 p.m.)