ML25104A260
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| Issue date: | 04/14/2025 |
| From: | NRC/OCM |
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION
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MICRO-REACTORS: CURRENT STATUS AND MOVING FORWARD
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- THURSDAY, APRIL 10, 2025
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The Commission met in the Commissioners' Hearing Room, at 9:00 a.m. EDT, David A. Wright, Chairman, presiding.
COMMISSION MEMBERS:
DAVID A. WRIGHT, Chairman CHRISTOPHER T. HANSON, Commissioner ANNIE CAPUTO, Commissioner BRADLEY R. CROWELL, Commissioner MATTHEW J. MARZANO, Commissioner ALSO PRESENT:
CARRIE SAFFORD, Secretary of the Commission BROOKE CLARK, General Counsel EXTERNAL PANEL:
2 BILL JESSUP, Director of Nuclear Technology, Shepherd Power ANTHONY SCHOEDEL, Manager, Advanced Reactors Licensing Engineering, Westinghouse Electric Company DIANA LI, Program Manager, Micro-reactor Program, Department of Energy MARC NICHOL, Executive Director of New Nuclear, Nuclear Energy Institute MOHAMMED (MO) BADAL, Program Director, Installation Nuclear Energy, Office of the Deputy Assistant Secretary of the Army for Energy and Sustainability NRC STAFF:
MIRELA GAVRILAS, Executive Director for Operations JEREMY BOWEN, Director, Division of Advanced Reactors and Non-Power Production and Utilization Facilities, Office of Nuclear Reactor Regulation WILLIAM (DUKE) KENNEDY, Senior Project Manager, Advanced Reactor Policy Branch, Division of Advanced Reactors and Non-Power Production and Utilization Facilities, Office of Nuclear Reactor Regulation CINTHYA ROMAN, Deputy Director, Division of Fuel
3 Management, Office of Nuclear Material Safety and Safeguards DAN BARNHURST, Chief, Environmental Project Management Branch 3, Division of Rulemaking, Environmental, and Financial Support, Office of Nuclear Material Safety and Safeguards JESSIE QUICHOCHO, Chief, Reactor Licensing Branch, Division of Preparedness and Response, Office of Nuclear Security and Incident Response
4 P-R-O-C-E-E-D-I-N-G-S 1
9:00 a.m.
2 CHAIRMAN WRIGHT: Good morning, everyone, and we're 3
going to call this meeting to order. At today's public meeting of the Nuclear 4
Regulatory Commission, we're going to hear from two panels.
5 The first will be an external panel that's going to provide us 6
their perspectives on the deployment and use of micro-reactors, and the second 7
is a staff panel that's going to discuss the actions the Agency is taking to 8
prepare for the licensing of micro-reactors.
9 In between the two panels, we're going to take a short break, 10 and as is our custom, we're going to hold questions from the Commission until 11 the end of each panel. So, I look forward to a good dialogue today, I really do.
12 And before we start, as is our custom, I want to ask my colleagues if they have 13 any questions before we start? Any comments?
14 Okay, since there are none, with that, we're going to get 15 started with our external panel. We're going to begin with Bill Jessup this 16 morning, who is the Director of Nuclear Technology at Shepherd Power. It's 17 good to see you again, Bill. And with that, the floor is yours.
18 MR. JESSUP: All right, yeah, thank you, Mr. Chairman, and 19 thanks to the Commission for having us here today to talk about micro-reactors.
20 Before I get into details, I wanted to give a brief introduction to Shepherd 21 Power and our parent company, NOV. I think that will provide some good 22 context for the bulk of my presentation, so next slide, please?
23 So, Shepherd Power is a wholly-owned subsidiary of NOV.
24 NOV is an oil field equipment supplier and service provider to the oil and gas 25
5 industry primarily, but fundamentally what NOV does is it solves the global 1
energy industry's challenges, and so that ultimately led us to Shepherd Power.
2 So, if you go to the next slide, please?
3 In 2020, a large oil and gas exploration and production 4
company brought a challenge to NOV and said we like micro-reactors. We 5
think micro-reactors have a place in our operations. Can you figure out how to 6
deploy these to support our remote power needs?
NOV took 7
that challenge on and ultimately formed Shepherd Power to take on a developer 8
role in micro-reactor deployment. And so, Shepherd Power's intent is to buy 9
reactors from reactor technology vendors and own and operate those reactors 10 on behalf of energy off-takers. So, I'll give a use case from the oil and gas 11 industry on the next slide, if you go to the next slide?
12 So, one of the areas where we see a lot of potential interest in 13 micro-reactor deployment is the Permian Basin you see here in west Texas and 14 New Mexico on the slide. The Permian Basin is one of the largest hydrocarbon 15 producing basins in the world. This map shows some of the general features of 16 the basin, including the wide distribution of oil and gas production activities.
17 From a regional demand standpoint, we can glean a lot from 18 a recent S&P Global report that did a deep dive into the basin's increasing 19 demand profile, a lot of which is being driven by the increase in electrification of 20 oil field activities like artificial lift and gas compression. That report found that 21 we can expect several gigawatts worth of additional demand from oil and gas 22 production activities alone over the next 10 to 20 years.
23 And I think what's notable and relevant here is that a lot of 24 demand is remotely located, and getting those loads connected to the grid has 25
6 been and will remain challenging for a variety of reasons that aren't necessarily 1
unique to the Permian Basin.
2 And at the end of the day, when you look at this map, what 3
we're ending up with are pockets of demand on the order of five to 50 4
megawatts electric. They're remotely located. They require reliable power for a 5
period of several years, perhaps decades, and they require a very low 6
operations and maintenance burden.
7 Micro-reactors align well with a lot of these requirements, but 8
the distributed nature of these loads and the need for commercially viable 9
deployment approaches, it going to require a different operating model than that 10 which we're accustomed to in the nuclear industry. Next slide, please?
11 So, what enables that operating model and how do we deploy 12 these technologies at scale? And to address those questions, I've outlined a 13 couple of considerations here.
14 And the first consideration kind of in the middle of this 15 diagram is safety focus, and it relies on some of the basic characteristics of 16 micro-reactors that we're familiar with, inherent safety, passive safety features, 17 smaller radionuclide inventories, and standardization, among others.
18 These characteristics, they suggest that, you know, micro-19 reactors are going to convey lower accident consequences should an event 20 occur, and that correspondingly, they should pose a very low risk to public 21 health and safety.
22 We need to validate these assumptions through design and 23 analysis activities, of course, but ultimately what this does is it allows us to 24 consider a different way of operating and maintaining these technologies. And 25
7 so, with that lower risk profile validated, we can move outward on that diagram 1
and start to look at the key enablers of these operating models and what can 2
help drive commercial viability here.
3 And what you see on this outer ring are some of what we 4
consider to be the key enablers, remote operations where we can pull some of 5
the operating duties out of the field and centralize them into one or more 6
facilities, centralized programs that are pre-approved and standardized, and 7
primarily that's the streamline and downstream licensing activities, using a 8
multi-skilled workforce where perhaps the same individual is performing 9
maintenance, health physics surveys, sampling. That's got some clear 10 implications from an accreditation, initial training, and continuing training 11 perspective, ensuring that facility staffing levels are commensurate with the 12 relatively low risk profile of micro-reactors, and this extends to support facilities 13 like remote operation centers.
14 Operation staffing is a significant interest here because of the 15 existing regulations related to those positions, and then physical security 16 profiles and postures that are also commensurate with that same low risk 17 profile.
18 And then last but not least, we've got to have efficient 19 licensing pathways that treat micro-reactors as products and not projects, and 20 this is where Shepherd Power has probably been the most engaged with the 21 NRC over the last year or so. Because at the end of the day, the questions we 22 have to answer for target customers are how much is this going to cost and 23 when can we get it?
24 That's it, and so viability really rests on being able to answer 25
8 those questions, and having a streamlined, predictable licensing pathway, 1
particularly for the nth-of-a-kind micro-reactors. We really see that as essential 2
to answering those questions.
3 And I think the last thing I'll add here is this is just a subset of 4
all the enablers that we think need to be addressed for commercial deployment 5
and viability, but these are top of mind for us right now, and fortunately, we see 6
a lot of overlap between what the staff's working on and what other 7
stakeholders are working on here in the policy arena. Next slide, please?
8 So, I'll wrap up with a quick discussion on how we're 9
approaching regulatory engagement with the NRC. Our initial interactions with 10 the NRC were focused on trying to understand the level of commercial risks 11 associated with micro-reactor licensing and regulation while also explaining to 12 the Agency what our commercial constraints are, again, you know, what drives 13 commercial viability here.
14 To the NRC's credit, I think the Agency has really rolled up its 15 sleeves. You know, the fact that we're sitting here today talking about this is 16 just one example, but you look at things like the staff's integrated plan and all 17 the policy work that's going on.
18 And there's a lot more work to do on everybody's part, our 19 part, NRC's part, but it's, you know, it's given us enough confidence to move 20 into more of an execution mode here where we're starting -- we submitted a 21 regulatory engagement plan. We submitted two white papers, the first of many, 22 and topical reports, and we also continue to engage with the NEI and others on 23 the policy development work that's going on.
24 And to the point I made earlier about validating the safety 25
9 case of these technologies, I think we're going to be reliant on specific analyses 1
and other evaluations to justify the implementation of some of those enablers, 2
so a lot of our subsequent white papers, topical reports, things like that, they're 3
going to become more site specific, technology specific, and all of that is in 4
anticipation of submitting our first round of license applications.
5 So, next slide, please? With that, that's my presentation.
6 Again, thanks for having us today and I look forward to the questions you all 7
have after the panel.
8 CHAIRMAN WRIGHT: Thank you so much. So, next we're 9
going to go to Anthony Schoedel, who is the Manager of Advanced Reactor 10 Licensing at Westinghouse. Mr. Schoedel, the floor is yours.
11 MR. SCHOEDEL: Thank you, Chairman. Congratulations on 12 the appointment, and Commissioner Hanson, thank you for your leadership 13 these past years, and to all of the commissioners, it's a pleasure to be here with 14 you today and to have the opportunity to speak with you on the eVinci micro-15 reactor.
16 So, I've got about four slides we'll go through here pretty 17 quickly, but the theme today, I want to talk to you about a brief overview of what 18 the eVinci micro-reactor is, technology overview highlights, share some of our 19 experiences from pre-application engagement and how we've been conducting 20 that for the last couple of years here with the NRC staff, and then leave you 21 with, you know, where we see additional areas of licensing policy issues, that 22 many of them have been noted already through various SECYs where we think 23 we still need to see continued progress to move the needle for first-of-a-kind 24 and nth-of-a-kind deployments. So, with that, next slide, please?
25
10 All right, so the eVinci micro-reactor, it's a TRISO-fueled heat 1
pipe micro-reactor. It operates with an open-air Brayton power system that's 2
capable of producing five megawatts electric in an eight effective full-power 3
year core design lifetime.
It's a graphite-moderated reactor with 4
hexagonal core blocks that house both the TRISO fuel compacts as well as the 5
heat pipes, you know, you start to see these differences between your 6
familiarity with SMRs and large light water reactors and some of the physical 7
characteristics as you go around this graphic.
8 The predominant means of reactivity control for this is a 9
series of banked control drums around the perimeter of the reactor. It's all 10 encapsulated in a canister in an inerted environment, very low pressure, 11 approximately one atmosphere. That helps, you know, safety case analyses 12 and risk consequences for this type of reactor profile.
13 The overall site is approximately three acres or less when we 14 consider total impact to site footprint, and I think that's really key as we get into 15 some of the other technical discussions through EPZ and siting, keeping that 16 small site footprint.
17 And eVinci is, you know, being a micro-reactor, one of the 18 things I expect we'll talk about a fair amount today is the deployment model for 19 what these reactors revolve around, and that's really being factory 20 manufactured, fueled in a factory, maybe some limited testing at the factory 21 before it gets to the operating site, transporting a fueled reactor to the intended 22 operating location and back following eight years of operation before 23 dismantlement, or refurbishment, or reuse. So, if we can, we'll go to the next 24 slide, please?
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11 All right, so pre-application engagement, we've been working 1
very closely with the NRC staff since 2021. A series of technical white papers 2
have been going through following the advanced reactor road map for licensing 3
from the staff. We have had, I'd say, overwhelmingly positive meetings and 4
engagement, and thanks to the NRC staff for facilitating, I would say, on time 5
reviews, on budget reviews, and I think that's reciprocal.
6 So, Westinghouse has committed through our pre-app 7
engagements to deliver what we say we're going to deliver through our 8
regulatory engagement plan, that way the staff can plan accordingly, and I think 9
we have seen that reciprocity from the on-time staff reviews for these technical 10 white papers.
11 What's the significance of the white papers? Really important 12 for, you know, a design vendor like Westinghouse with a new first-of-a-kind type 13 of technology to understand where there are potential policy issues or hurdles 14 that we are going to experience as we move through future licensing or as 15 potential future customers look to license this technology.
16 So, the de-risking in licensing space that happens through 17 feedback through those white papers has been very important for us. How are 18 we acting on that? So, we are taking that to the next step through what we view 19 as really key for starting to get approvals and de-risking some of these more 20 formally through topical reports.
21 So, 31 white papers in various areas, that's transitioned now 22 into three topical reports now approved. Two of them are I&C platform, one of 23 them on principal design criteria, another three topical reports currently under 24 review. Those technical reviews are ongoing, but all very positive to date, 25
12 utilizing the audit process and being very open and transparent.
1 I think it's very important from the Westinghouse perspective 2
that when something comes to the NRC staff in the form of a topical report in a 3
future application, that it's not going to be a surprise to the staff.
4 It should not be a surprise to the staff because of what we're 5
put forward in our technical white papers, and that's leading to some of the 6
efficiencies that I think we need to continue to build upon as we look towards 7
first-of-a-kind delivery and ultimately nth-of-a-kind delivery.
8 In parallel with topical reports and the white papers, we have 9
a robust testing program. So, we're a big proponent of the design, build, and 10 test philosophy at Westinghouse for this technology.
11 You can see on the bottom bullet there a special callout to our 12 nuclear test reactor we envision in operation in the near future at the DOME 13 complex at Idaho National Lab. That's an integrated nuclear test working 14 through, you know, our friends and partners at Idaho National Lab to get it 15 authorized with the U.S. Department of Energy for future operation.
16 So, that's an area as well that, while it's not specifically being 17 put forward in front of the NRC staff for their technical review, it's an area where 18 we're collaborating and sharing with them, you know, what we've been doing, 19 so that way they understand where we're going with those tests and how that's 20 going to potentially inform future commercial license activities.
21 So, I would say also thank you to the U.S. DOE. Recently, 22 yesterday, I think a lot of us have seen the announcement on the HALEU 23 conditional commitment. Westinghouse is lucky enough to be one of those 24 parties for the eVinci micro-reactor, and that supply is going to directly support 25
13 the nuclear test reactor for eVinci, which is a tremendous accomplishment, so 1
thank you to the DOE colleagues here.
2 As well, you know, the success is building in pre-application 3
engagement over these past years, and the confidence that that instills in future 4
potential customers and off-takers of this technology, I think, is most recently 5
envisioned by as recent as February, Penn State University has put forward a 6
letter of intent to the NRC for a research reactor, selecting the eVinci micro-7 reactor technology as an advanced reactor technology for their campus to 8
foster both continued learning and building their engineering program.
9 So, you know, these results are both important to 10 Westinghouse, but they are also equally as important to potential off-takers and 11 then users of this technology to see the licensing progress. Next slide, please?
12 All right, so I'll wrap it up here in the next two, but I want to 13 share some of these very impressive graphics. This is an array of different 14 components that we're manufacturing across various Westinghouse facilities in 15 the U.S. and Canada, and we're taking that design, build, test philosophy and 16 building off of the lessons learned in pre-application engagement to show 17 confidence in the de-risking that's happening in licensing to be able to turn this 18 design into a reality.
19 The bottom right graphic is our manufacturing demonstration 20 unit. It's a representative core section of the eVinci micro-reactor that was built 21 at our Newington facility, and it now resides in that top right building that you 22 see in this graphic.
23 That's our eVinci headquarters outside of Pittsburgh, 24 Pennsylvania where we're going to be manufacturing heat pipes. So, a lot of 25
14 great work there, an 87,000 square foot facility stood up just for this technology.
1 Next slide?
2 And then I'll close with this, and I expect that we'll have a fair 3
number of questions as we get into the Q&A portion, but critically important to 4
Westinghouse is, you know, these bulleted items on the left.
5 These are key enablers for future areas that we need to 6
continue to work with the NRC staff, with you all at the Commission to drive 7
surety in the licensing process for a first-of-a-kind and ultimately nth-of-a-kind 8
deployment of micro-reactor technologies.
9 All of these were communicated to the NRC from 10 Westinghouse in writing back as recently as 2023 in form SECY-24-0008. The 11 fuel load and manufacturing facility is the number one licensing policy item from 12 the Westinghouse eVinci perspective, and I would encourage that the staff, they 13 put that SECY in front of you all for notation vote.
14 So, I would encourage the Commission to make a vote on 15 that if we can. That would help us move forward with planning on not just first-16 of-a-kind, but ultimately nth-of-a-kind. So, I'll leave it there. I think I've eaten up 17 a little of your time, Diana, but again, thank you all for the opportunity and I look 18 forward to the Q&A.
19 CHAIRMAN WRIGHT: Thank you very much, Anthony. I got 20 a lot of questions, so I look forward to questions with you all. Next, we're going 21 to hear from Diana Li, who is the Micro-reactor Program Manager at the 22 Department of Energy.
23 MS. LI: Thank you, Chairman Wright, and thank you, 24 Commissioners, for this opportunity to speak about DOE's Office of Nuclear 25
15 Energy's efforts to demonstrate and deploy micro-reactors. Can I get the next 1
slide, please? Yes, thank you.
2 The administration has a bold and ambitious agenda to 3
unleash American energy at home and abroad to restore our nation's energy 4
dominance. In alignment with Secretary Wright's priorities, the Office of 5
Nuclear Energy is working to grow the supply of affordable, secure, and reliable 6
American energy across the entire spectrum, from R&D, to demonstration, to 7
deployment. Next slide, please?
8 The Micro-reactor Program is leveraging cross-cutting 9
research and development activities in collaboration with our national 10 laboratories and universities to achieve technological breakthroughs for key 11 features of micro-reactors, which would reduce risks and timeline to deploy 12 advanced nuclear technology, improve economic viability and licensing 13 readiness, and enable successful demonstration of multiple domestic 14 commercial micro-reactors.
15 Our R&D program is focused on four technical areas. The 16 first is system integration and analyses in which we identify the needs, 17 applications, and functional requirements for micro-reactors through market 18 analyses. This technical area also includes investigation of micro-reactor 19 supporting concepts such as modeling capabilities and research to help 20 develop the regulatory basis for micro-reactor deployment.
21 Recent work includes development of a heat pipe micro-22 reactor model for code comparison, identifying micro-reactor transportation 23 emergency response planning challenges, identifying manufacturing license 24 and factory fueling regulatory challenges, and a process to develop a bottom-up 25
16 cost estimate of a micro-reactor.
1 The second technical area is technology maturation, which 2
includes research into advanced materials such as yttrium hydride and 3
zirconium hydride for high-temperature moderators, investigation of heat 4
removal technologies such as heat pipes, heat exchangers, and deployment of 5
sensors. This year, the program is investigating methods for detecting damage 6
in graphite, which could be used as a structural material for micro-reactor cores.
7 The program also plans to demonstrate a micro-reactor start 8
sequence using MACS, the Micro-reactor Automated Control System, to adapt 9
and apply technologies for monitoring and controlling micro-reactors.
10 The third technical area is demonstration of support 11 capabilities and includes non-nuclear testing capabilities. SPHERE, or Single 12 Primary Heat Extraction and Removal Emulator, is a small, separate effects 13 testing capability primarily used to support heat pipe testing.
14 It allows us to observe the thermal performance of heat pipes 15 under a range of operating temperatures and transients. In the last year, 16 SPHERE performed transient testing of heat pipes to support verification and 17 validation of the Sockeye code.
18 We also have MAGNET, which stands for Micro-reactor AGile 19 Non-nuclear Experimental Test Bed, which allows us to simulate core thermal 20 behavior, heat pipe and primary heat exchanger performance, and decay heat 21 removal. This year, MAGNET is working to integrate a gas Brayton cycle power 22 conversion unit, as well as a graphite test article with heat pipes.
23 And the fourth technical area is micro-reactor application, and 24 the main focus in this area is our Micro-reactor Applications, Research, 25
17 Validation, and Evaluation, or MARVEL reactor. Next slide, please?
1 So, MARVEL is a very small micro-reactor that will produce 2
both electricity and process heat. It is designed to use natural convection of 3
sodium-potassium to remove heat from the core, and the fuel will be comprised 4
of uranium zirconium hydride with high-assay LAU, similar to TRIGA fuel, which 5
is known to have a high pedigree of safety.
6 This reactor will be located in the storage pit of the transient 7
reactor test facility at Idaho National Laboratory, and we will co-locate the 8
controls for the MARVEL reactor in the TREAT control room.
9 Fabrication of the guard vessel is complete and contracts 10 have been issued for fabrication of the primary coolant system and fuel. As a 11 result of the development of MARVEL, the micro-reactor industry could benefit 12 from demonstrated use of environmental assessment, which took approximately 13 six months to develop, as opposed to environmental impact statement, which 14 could take as long as two years.
15 They will also benefit from reestablishment of reactor design, 16 fabrication, and demonstration capability at Idaho National Laboratory, and 17 demonstration of a micro-reactor with a microgrid for a range of end-user 18 applications. Next slide, please?
19 The National Reactor Innovation Center or NRIC is funding 20 the establishment of demonstration test beds, and this includes support for 21 micro-reactor development by repurposing the old, experimental Breeder 22 Reactor-II facility to make the Demonstration of Micro-reactor Experiments or 23 DOME facility. Most recently, NRIC awarded $5 million to Radiant Industries 24 and Westinghouse to progress their micro-reactor designs for testing in DOME.
25
18 1
The funds will support the detailed engineering and 2
experiment planning process, which is the next phase of a larger, multi-phased 3
approach to support nuclear developers in planning for the design, fabrication, 4
construction, and testing of fueled reactor experiments. Next slide, please?
5 So, recognizing the importance of advanced reactors to 6
meeting the nation's energy security goals, NE has focused over the last 7
decade towards private-public partnerships to develop domestic advanced 8
reactor designs.
9 Since 2018, NE invested more than $400 million into more 10 than 50 projects through various industry funding opportunity awards, and 11 awardees included micro-reactor developers like Westinghouse, X-energy, and 12 BWXT.
13 Additionally, we have the Gateway for Accelerated Innovation 14 in Nuclear funds, which, sorry, GAIN, which funds micro-reactor developers in 15 the voucher program to access technical, regulatory, and financial support 16 needed to accelerate commercialization.
17 Many developers are building upon decades of R&D from 18 DOE for advanced technologies like TRISO fuel and materials, as evidenced in 19 their designs, and due to these investments, we now see industry taking the 20 lead.
21 To be competitive though, an order book of micro-reactors is 22 necessary, and DOE is looking at what is needed to achieve that, including the 23 potential to leverage federal lands to demonstration the technology or support 24 critical end users. One example already underway is the work being done at 25
19 Idaho National Laboratory to identify sites and issue site leases for reactor 1
developers.
2 DOE also recently released an RFI that looked across the 3
DOE complex and identified 16 sites that could support rapid data-centered 4
construction with innovative energy generation sources like nuclear. Next slide, 5
please?
6 So, many reactor vendors plan to demonstrate their 7
technologies by the end of this decade and will need HALEU. Currently, there 8
is no domestic commercial HALEU supply, so NE's near-term strategy is to 9
provide recovered HALEU to vendors for reactor demonstration, and our long-10 term strategy is to incentivize domestic HALEU market development.
11 As with all activities, this is subject to congressional 12 appropriations and administration support, but as mentioned yesterday, DOE 13 issued its first round of conditional commitments to five U.S. nuclear developers 14 to meet their near-term fuel needs.
15 So, in closing, we are working diligently to enable the rapid 16 deployment and export of next generation nuclear technology, and we're 17 focused on reducing barriers and bringing down costs to start building 18 advanced nuclear projects here in the United States. Thank you.
19 CHAIRMAN WRIGHT: Thank you so much. So, next is Marc 20 Nichol, who is the Executive Director of New Nuclear at the Nuclear Energy 21 Institute. Marc?
22 MR. NICHOL: Thank you, Chairman and commissioners for 23 being able to speak to you today. So, going onto my first slide, I want to start 24 with the projects that are being planned and considered in the United States.
25
20 The U.S. map, next slide, please, shows over 60 here. Key 1
things to note from this, this is double what we saw this time last year. Some of 2
these points represent more than one reactor or more than one site, like the 3
Permian Basin, and so this is indicating a wave of applications that we're 4
projecting, and the demand is expected to increase over time.
5 That led us to realize we need to have a more efficient and 6
effective way for these advanced technologies if we're going to be able to 7
respond to the demand and lean into the differences in the business models 8
and the technologies. Next slide, please?
9 So, as we looked at that, there were a couple of things we 10 tried to focus on. One is the safety aspects of these advanced technologies, 11 particularly micro-reactors, and so this shows relative potential consequences 12 of the different reactors, and it shows that micro-reactors, which was the 13 starting point of our proposal from July of last year, are much more similar to 14 research test reactors than they are to the large light water reactors. Next slide, 15 please?
16 And so, as we looked at that, we asked ourselves well, why 17 then are we continuing to try to adapt the large light water reactor regulatory 18 framework for these technologies? Wouldn't a better place be to start from the 19 research test reactor regulatory framework?
20 And as we went through that, we actually found we had many 21 more creative ideas and being able to develop alternatives, and the reason is 22 because you're tethered to your starting point, and so you're not going to get 23 very far from where you start. So, if you start from something that looks much 24 more similar to these technologies, you'll actually end up in a better spot. Next 25
21 slide?
1 And so, the other thing we looked at is, well, how can we take 2
-- this will advance a little bit, so advance? How do we take the current scope 3
of what the NRC reviews for a reactor and site, and this is represented by what 4
the NRC would review traditionally, how can we break that up such that we can 5
cover the same amount of scope, have the same amount of regulatory clarity 6
and predictability, certainty, but do it in a more efficient way? And we really 7
leaned into the idea of standardization, so advance one? Actually, advance a 8
few until you get a full rectangle on the right side. Thank you.
9 And so, we broke it up into several different areas. One, 10 there are things that the NRC could do generically across the board through 11 things like rulemaking. The new nuclear GEIS is a great example of that.
12 There are things that you can do within a particular design, whether it's a 13 standardized design approval, design certification, or manufacturing license, 14 and do it once for the design.
In fact, as we looked at this, we thought to 15 lean into that and go even beyond what was imagined before in order to 16 incorporate site aspects into that approval of the design, and if you can do that, 17 then what's left is just confirming that the site conforms to what the NRC has 18 already approved and determined is acceptable from site considerations.
19 And so, there would be two more pieces to that. One is that 20 there are many, especially programs, related to the owner-operator that the 21 NRC needs to approve. Well, the owner-operator would implement those 22 programs for a particular design the same way whether it's Site A or Site B, and 23 so those could be approved generically.
24 And that leaves us with that small little box which is particular 25
22 to the site, and as I mentioned, the scope of that is really confirming that it 1
conforms to what the NRC has already approved as acceptable. You're within 2
the bounds, sort of a site perimeter envelope type of concept.
3 And if we can do that, then the repetition over and over and 4
over for each site, for using that reactor that's already been approved, becomes 5
much smaller, much more efficient, and we can get to higher volumes of 6
deployment. Next slide, please?
7 And so, it has an effect. The size of the application and the 8
amount of information the NRC has to review has an effect on the schedule.
9 Now, there's important things to keep in mind, that there's the NRC's direct 10 review schedule, but there are also NRC requirements that impact the overall 11 deployment schedule and we know that we need to shrink all of that.
12 And so, if you look at this schedule, this is particularly for a 13 micro-reactor, what we might expect today, and it's important from an industry 14 perspective that we look at from when a site is identified to when it's in 15 operation, not just the NRC's portion of the review, but look at the whole life 16 cycle.
17 That's how you're going to look at it from a business aspect.
18 And so, it's about 49 months today for that entire process, which we know from 19 some business models, that's way too long. Next slide, please?
20 So, if we apply some of the concepts that were in our rapid 21 high-volume deployable reactor or RHDRA paper from July, we think that that 22 schedule can actually collapse to about five months, and the NRC would still 23 have the same level of review, same level of confidence because it's just been 24 done in a different, more efficient way. Next slide, please?
25
23 We do address other topics in our RHDRA paper like 1
operations, staffing, and this is just a high-level concept. We have several 2
different operational concepts in there and one is a site that might only have 3
one staff member on site to do operations plus other things.
4 Another is you might not have anybody, but you could have 5
remote operations. And then maybe long term, you know, we should ask the 6
question, could you get to a place where you don't have a human operator at 7
all? That's autonomous operations.
8 And so, we've proposed a methodological way where you 9
actually evaluate -- it's based on the design. You evaluate the design. How 10 many functions need operator actions? How many can be taken care of by 11 automatic features?
12 How many can be outsourced to a different site and how 13 many remain onsite? So, it would be dependent on the design. It's not a, you 14 know, a preapproval for designs. They have to demonstrate that they can meet 15 it. Next slide, please?
16 Within our RHDRA proposal, we have 31 topics. This is a 17 prioritization that we had laid out in terms of urgency and what is most impactful 18 to business planning, and we overlaid it with the NRC's more recent work on 19 what they call the NOAK white paper that's still being updated, and so there 20 was a lot of good overlap with that. There were also some of the other items 21 that were in prior NRC papers as well. Next slide, please?
22 So, from here, what are the next steps? Well, we want to 23 coordinate with the NRC and other stakeholders on developing the details. We 24 received the NRC's response in December to our proposal. We're very pleased 25
24 with the response. It laid out that there were no showstoppers identified, that 1
they all looked feasible.
2 There was agreement that these concepts, although they 3
originated for micro-reactors, could be applied to other larger advanced 4
reactors, SMRs, some exactly the same way and some in graded approaches 5
depending on the performance standard that needed to be met, and so the 6
NRC has been moving and you'll hear from them later.
7 We want to make sure that they're developed in performance-8 based ways. We want to avoid developing things that have an artificial power 9
level that determines whether you can or can't use these. We want them in 10 performance-based ways.
11 One of the performance-based ways that we leaned into was 12 a site boundary emergency planning zone, because it's been well-established 13 and understood, and it actually defines a level of public health protection that is 14 very stringent that could enable alternative approaches.
15 Some don't necessarily need that. So, for example, 16 meteorology, we think it's more based on the pedigree of the alternative data 17 that is the justification, and that could be used even for large reactors.
18 And then finally, there are some additional topics we're 19 looking into and we may propose those as we go along. Thirty-one is 20 comprehensive, but it may not be all-exhaustive. Thank you.
21 CHAIRMAN WRIGHT: Thank you, Marc. So, finally, we're 22 going to end the first panel with Mo Badal, who I remember seeing at the RIC 23 and we did talk, who is the Program Director for Installation Nuclear Energy in 24 the Office of the Deputy Assistant Secretary of the Army for Energy and 25
25 Sustainability. Mr. Badal?
1 MR. BADAL: Thank you, Chairman Wright. Commissioners, 2
good morning. It is my pleasure to be here and talk about Army's project, 3
Advanced Nuclear Power for Installations.
4 As you know, the U.S. Army led the nuclear power technology 5
between 1954 and '77. Since, it has been five decades that we have not talked 6
nuclear energy, but here really we are here to talk about today and in the future, 7
so next slide, please?
8 I just want to say this first, that we cannot do this alone. So, 9
what we did, we began the planning for this project July of 2023. What we did, 10 we integrated some of the lessons learned from the Air Force's Eielson project, 11 Project Pele, early learning and exploring advanced reactors.
12 And so, what we learned is that it's going to take an entire 13 village to deliver micro-reactors for installations. So, we began initial planning.
14 We formed early partnership with the Department of Energy, the Department of 15 Energy's national labs.
16 Currently, we have a partnership with six different labs where 17 we can access their expertise. We also worked with, Jeremy is in the room 18 here, John is here also, with early engagement with the Nuclear Regulatory 19 Commission to make sure we understand the need and how to deliver this 20 technology for our installations. Next slide, please?
21 The program scope is basically, it is a commercially-owned 22 and operated technology we are driving for, and of course, it will be regulated 23 by the NRC.
24 The reason I'm mentioning that, early on the planning stage, 25
26 we did look into our 91b military purposes authorization ability to permit our 1
installation nuclear projects, but after a thorough analysis, we have concluded 2
that the NRC has the right expertise to help us deliver this technology.
3 We are really seeking a full lifecycle nuclear power plant, from 4
design, construction, and operation, deconstruction and returning it to the 5
unrestricted release state, so it's a full cycle nuclear power plant we are striving 6
for.
7 What we were trying to do, achieve, is that we achieve 8
mission readiness through this with additional sorts of energy, and then beyond 9
what is available today, and also we want to make sure it's onsite, so it's 10 protected from some of the physical and natural disruptions that is happening 11 today.
12 Again, of course, we were looking for the safe, secure, and 13 reliable technology, and then simultaneously, we want to really help to stimulate 14 the nuclear reactor deployment in the United States. Next slide, please?
15 Our application and concepts that we want to employ micro-16 reactors are twofold. One, the micro at the scale from three to ten megawatt 17 electric that is behind the meters specific for our critical facilities, and then the 18 beyond critical facilities for whole installations. That's the partnership with the 19 utility providers, or we're discussing data centers that provide that additional 20 power capacity for the installation and the DOD.
21 So, in this case, I want to highlight a couple of things, our 22 partnership with the Defense Innovation Unit that is enabling us to pursue this 23 with their other transaction authority, and then with this approach, what we have 24 been able to do is talk to multiple vendors at the same time.
25
27 And I just want to make an announcement. Today, you will 1
hear Defense Innovation will announce the down selection of the vendors that 2
will proceed into the phase three. Next slide?
3 I really especially wanted to highlight our relationship with the 4
Nuclear Regulatory Commission Chairman. So, when Commissioner Hanson 5
was the chairman, we did meet with our senior leadership with the DOD to 6
discuss this, and he has told us about the NRC's support for our program. We 7
have been holding biweekly meetings.
8 Currently, we have an MOU we are working on for NEPA 9
activities in conjunction with the DOD, and then we have an existing MOU with 10 the Army Reactor Office that is strengthening up our partnership. And then, of 11 course, NRC's involvement in our acquisition process in the OTA has been 12 helpful as we look to the down selection of our vendors. Next slide, please?
13 This is my last slide, Chairman. This is really highlighting 14 some of the things that we are thinking through. How do we identify a 15 technology readiness level that can meet our timeline and mission, and also, 16 how do we match that with the regulatory path? That's been key conversations 17 we're having.
18 The other one is the cost burden for the first-of-a-kind. I know 19 we have been talking with the vendors. They're trying to come up with creative 20 financial models to deliver the first-of-a-kind and overcome that burden.
21 And one of the things that you will hear within the DOD 22 community, the regulatory path uncertainty. There is no, I would say, clear 23 published documentation identifying the micro-reactor licensing path yet. It's 24 still a work in progress, so we want to get some clarity on that in terms of how 25
28 we go forward.
1 On the fuel, we're working with our DOE, you know, partners 2
with the fuel, but there is not really unobligated fuel for commercial space yet, 3
so we understand those challenges, and then also the fuel form that we want to 4
pursue for safety for our installations, so there are some challenges there.
5 And then, of course, as we went through our vendor down 6
selection process, we learned the limited ability to manufacture the proposed 7
design and there's the challenges that exist. With that, Chairman, I conclude 8
my briefing pending your questions.
9 CHAIRMAN WRIGHT: Thank you so much, Mr. Badal, and 10 thank you all for your presentations this morning. So, we'll now go into 11 questions, and first up today is Commissioner Crowell.
12 COMMISSIONER CROWELL: Thank you, Mr. Chairman, and 13 thank you to all of our panelists. That was all very informative and 14 complementary presentations. The scope of micro-reactors is, you know, an 15 area where, in my short time, a couple of years on the Commission, I did not 16 see us being this far along, so these are positive developments, and it requires 17 the NRC to keep up and establish a safe regulatory pathway to commercialize 18 these technologies.
19 I'm going to try to get through a couple of questions, and Mr.
20 Nichol, I'm going to start with you. From a technical perspective, what's the 21 difference between a micro-reactor and an SMR?
22 MR. NICHOL: So, there's no firm definition of a micro-reactor.
23 Generally, people divide it at 50 megawatts electric and less. A lot of the 24 characteristics of a micro-reactor is its very small size and its ability to be 25
29 transported as a complete reactor with or without fuel.
1 And so, that small, small size and ability to locate it in remote 2
areas is really more the defining feature of a micro-reactor. In terms of safety, it 3
would have much fewer potential for accidents. The consequences would be 4
much, much lower than an SMR.
5 COMMISSIONER CROWELL: And Ms. Li, I was going to ask 6
you the same question, but I saw you nodding your head yes. Would you agree 7
with that distinction?
8 MS. LI: I do. I think the emphasis on ability for micro-reactors 9
to be deployed in remote locations is one of the defining features that separate 10 a micro-reactor from an SMR. They all have passive safety systems, but yes, 11 being more factory fabricated and being more transportable, I think, is the 12 correct response.
13 COMMISSIONER CROWELL: Okay, and then, Mr. Nichol, 14 back to you, now from a regulatory perspective, what is the difference between 15 a micro-reactor and an SMR in terms of how it should be treated from a 16 regulatory perspective?
17 MR. NICHOL: So, there's a couple different ways to look at 18 that. If you look at it from a potential consequence, and if they both have a site 19 boundary EPZ, whether it's a micro-reactor or an SMR, there's a lot of things 20 that you can do similarly in terms of that.
21 There are things that micro-reactors will be able to do that 22 SMRs likely won't be able to do. So, if you look at fully remote operations, that 23 may be very difficult for an SMR to do. If you look at the ability to transport with 24 fuel, that's something an SMR is probably never going to be able to do. So, 25
30 there are certain things that, in regulatory space, micro-reactors enable that 1
won't be available for SMRs, but there are many that are going to be shared.
2 COMMISSIONER CROWELL: Thank you, and I asked that 3
question just for the sake of the audience who may be listening in and people 4
who aren't as familiar with this to understand these distinctions and the different 5
applicability.
6 Mr. Schoedel, let me turn to you for a second and go to your 7
last slide, which begged lots of questions, but I'm most interested if you could 8
give a little bit more background and insight on disposal and decommissioning?
9 This is a topic related to both SMRs and micro-reactors that doesn't get 10 enough attention, so I'd love to hear what Westinghouse, how Westinghouse 11 sees this dynamic.
12 MR. SCHOEDEL: Thanks, Commissioner. So, I think it's 13 going to play off of the responses to your previous question as well. It's going 14 to come down to the deployment model for a micro-reactor. Westinghouse, 15 with eVinci, is looking at the full gamut, right?
16 So, we're looking at the beginning where you're factory 17 manufacturing, we're looking at the transportation to and from the operating 18 site, and then what happens post-operation when it comes back to a facility for 19 refurbishment or refueling, or ultimately decommissioning.
20 You know, from our view, one of the sentiments I'd like you all 21 to take away from these last couple of bullets on decommissioning is that under 22 the current regulatory regime, we perceive there are multiple licenses that are 23 required to enact such a deployment model where, as we transition beyond 24 first-of-a-kind to nth-of-a-kind licensing, we need to find a way to make it much 25
31 more efficient.
1 Get down to one license application. Can we do this under a 2
Part 70 like we're contemplating with receiving fresh fuel at the facility on the 3
front end and ultimately loading in the reactor, coupled with a manufacturing 4
license.
5 Can I do it under a Part 72 license at that type of a facility 6
instead of, right now, I would appear to have to have some type of an operating 7
license, as well as a spent fuel license, as well as a Part 70 license? So, how 8
do we simplify this as we navigate first-of-a-kind to nth-of-a-kind deployments?
9 The name of the game from my perspective on first-of-a-kind 10 is finding a path for those first few, right, eVinci micro-reactors that do not 11 require regulatory policy change or rulemaking, but that might be something 12 that we consider or contemplate through you all as we look to really enabling 13 efficient, high-volume deployments for nth-of-a-kind.
14 COMMISSIONER CROWELL: So, when we think specifically 15 about the back end of the life cycle of a micro-reactor, you know, once the unit 16 needs to go for refurbishment and it's used all of its fuel, what happens? Does 17 the unit with the irradiated fuel stay onsite for a period of time? Does it go back 18 immediately to the manufacturing site? And how is that spent fuel treated either 19 at the operational site or at the manufacturing site?
20 MR. SCHOEDEL: Yeah, great question, and thanks for it.
21 So, let me elaborate a little bit more specifically on the eVinci micro-reactor 22 deployment model, and I think this will shed some light.
23 So, eVinci, and I didn't mention this in my opening 24 presentation, but in addition to the facility that you see outside Pittsburgh for 25
32 heat pipe manufacturing, we're also going to be looking to announce the 1
establishment of a manufacturing campus where we envision at least a 2
manufacturing license like we coupled with Part 70 following the staff's risk-3 informed recommendations for SECY-24-0008.
4 That complex, we envision to have a series of multiple 5
buildings, a heat pipe building, a final assembly building where you're going to 6
be integrating all of the piece parts into a reactor module. It will have also a 7
refurbishment building, and we envision it to have an ISFSI.
8 COMMISSIONER CROWELL: So, how long will the 9
irradiated fuel or spent fuel remain onsite before it goes back to the 10 refurbishment facility?
11 MR. SCHOEDEL: Right, so there will be a cool-down period 12 of upwards of, you know, as much as a year of cool down, but that's also being 13 considered in the upfront design of what we consider a standard eVinci 14 deployment.
15 So, eVinci, when it's sited at an intended operating site, it will 16 be a two-bay standard model where reactor bay one will house the reactor 17 module one that operates for eight effective full-power years, a power 18 conversion system in the middle between the two bays, and there's a spare 19 bay.
20 So, this gets a bit also into maybe the middle of this slide with 21 licensing of replacement reactor modules where the vision is not to do onsite 22 fuel handling, minimize that impact to the site to help keep dose consequences 23 small.
24 So, to enable that, we have to be able to transport back to a 25
33 facility the fully-fueled, but now irradiated micro-reactor at the end of life. So, to 1
accomplish this, it would be the spare bay.
2 We would transport a fresh eVinci off of the assembly line, put 3
it in the new spare bay for, say, cycle two. It will do a power conversion switch 4
over, and that first operating reactor will cool down in place in its reactor bay for 5
upwards of a year until it's safe to transport.
6 And part of that transportation story, which, you know, I'll 7
mention now, is we are also designing and seek to license through Part 71 a 8
specialized transportation cask that would house the entire reactor and be 9
designed for the limiting case with end-of-life transport.
10 COMMISSIONER CROWELL: So, for the Westinghouse 11 model, do you anticipate needing an ISFSI license both at the operational site 12 and at the refurbishment facility or where do you see the licensing connection 13 for spent fuel?
14 MR. SCHOEDEL: Another great question. So, I'd love to 15 minimize the number of licenses on both the vendor as well as the end user.
16 The deployment model envisions bringing the reactor back for interim spent fuel 17 storage on an ISFSI.
18 We perceive that as a license under Part 72 that the 19 Westinghouse manufacturing campus would have, and while the reactor is still 20 onsite in its reactor operating bay, it's just, call it in no mode, right? You've 21 done a power conversion switch over and it's resting idle in its location, but we 22 would pursue not having a Part 72 license in addition at that operating site to 23 minimize the churn.
24 COMMISSIONER CROWELL: Thank you. With the little time 25
34 I have left, Mr. Jessup, I'm going to turn to you. You know, I asked the 1
irradiated fuel question intentionally because it's an important thing to figure out, 2
but Shepherd Power has talked about deploying micro-reactor technology in the 3
Permian Basin, and that could potentially be lots of small micro-reactors, and 4
therefore maybe lots of units with irradiated fuel at those sites. This is in the 5
same area that there's been a proposal for an interim waste storage facility.
6 How do you square those two things?
7 MR. JESSUP: Thanks, Commissioner Crowell. That's a 8
good question. I think I would play off of what Anthony was just talking about 9
here, is we wouldn't necessarily -- I wouldn't consider each of these facilities to 10 be its own interim storage facility.
11 If you have a shutdown micro-reactor, it is, in effect, shut 12 down. I would expect that through a license condition, technical specification, 13 LCO, something to that effect, that would control the number of reactors you 14 have onsite in operation at one time.
15 So, that takes care of the operational piece, but we also 16 envision an operating model where we're not storing spent fuel. You're 17 effectively storing a shut down module that then gets transported to a vendor's 18 location where they would hold some form of a Part 72 fuel storage license.
19 So, I don't think -- it's a good question, but we wouldn't 20 envision that each one of these is an interim storage facility, so I don't think 21 there would be a conflict with the ongoing litigation related to that matter.
22 COMMISSIONER CROWELL: Okay, appreciate it, and Mr.
23 Chairman, I appreciate the extra time. Thank you.
24 CHAIRMAN WRIGHT: Thank you, Commissioner Crowell, 25
35 and good questions. Commissioner Marzano?
1 COMMISSIONER MARZANO: Thank you, Mr. Chairman.
2 Good morning, everyone. This is a great crowd that we have in the room today, 3
and I just want to start by saying that I am incredibly excited for this 4
conversation, this topic.
5 I've been chomping at the bit to get my questions out, and I 6
can probably spend, you know, triple, maybe five times the amount of time 7
discussing all of these topics, but I do want to just thank the staff for their work 8
to prepare and execute important meetings like this one.
9 Also, I want to thank the panel for their presentations and for 10 being an essential part of this discussion on the future of nuclear energy in the 11 United States, and the work that you do and the people in this room do on a 12 daily basis to advance the safe deployment of this versatile technology 13 contributes to our nation's energy, national, and economic security.
14 As this panel has acknowledged, the deployment of micro-15 reactors represents an evolution in the way that we utilize nuclear energy 16 systems, and they have the potential to not only provide clean electricity, to 17 meet increasing demands, excuse me, but they also offer a potential solution to 18 achieve deep decarbonization of our larger energy system that powers our 19 industries and our manufacturers.
20 Proposed micro-reactor designs are far simpler, incorporate 21 passive inherent safety features, and present reduced radiological risks through 22 lower source terms compared to their larger counterparts. These may lead to 23 significant cost savings, reducing manufacturing and construction time, and 24 leveraging economies of scale.
25
36 I appreciate your ongoing interactions, coordination, and 1
collaboration with the NRC staff, and your bold visions for the rapid deployment 2
of micro-reactors. This engagement is crucial to the NRC's ability to respond 3
effectively to these novel deployment models in a timely manner.
4 The deployment and operating models for micro-reactors from 5
factory fabrication, operational testing, to transportation for operation at multiple 6
sites, are a drastic departure, as I mentioned, from the large light water 7
reactors.
8 So, we must look at new ways of doing business, especially 9
when access to this power provided by these systems can vastly improve lives, 10 and I think about remote rural communities that currently rely on things like 11 diesel generators to supply their energy needs.
12 Your continued input and sharing of ideas are fundamental to 13 the modernization of NRC's regulatory frameworks, and will help the 14 Commission fulfill its mission of enabling the safe and secure use and 15 deployment of civilian nuclear energy technologies through efficient and reliable 16 licensing, oversight, and regulation.
17 All right, now that we're through that, I can get to the fun part.
18 Mr. Jessup, we had a conversation yesterday, and it wouldn't be me if I was 19 not having a discussion about the operational side of these things, right?
20 So, you mentioned kind of this multi-skilled workforce to 21 support operation. What kind of specific challenges do you anticipate to the 22 management of the training, the qualification, and accreditation for individuals 23 that kind of serve in these cross-functional roles?
24 MR. JESSUP: Yep. No, thanks, Commissioner Marzano, it's 25
37 a good question. Let me start from a practical place.
1 If you look at just basic functional requirements, analysis, 2
function allocation, the makeup of some of these micro-reactor technologies, I 3
don't think we can envision there being teams of INC technicians, mechanical 4
maintenance techs, electricians, like you see at a current plant.
5 You have full departments for kind of each of those things. It 6
just doesn't make sense just from a practical perspective.
7 And so, you come back to a point of, okay, well it makes 8
sense for these folks to, you know, be multi-skilled, be able to do a lot of things.
9 But, then you do have to look at what do the regulations 10 require, particularly 10 CFR 51.20, the training rule. Put aside Part 55, operator 11 licensing stuff for now.
12 But, you look at what the training rule requires, how would 13 you get a program like that accredited for a jack of all trades? You know, what 14 you might have there.
15 And so, we wonder, initial training, how long does it take this 16 person, you know, to go through a training qualification program?
17 Continuing training too, does this person spend eight out of 18 their 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> days, taking CBTs to re-qualify, computer-based training to re-19 qualify and keep their skills up?
20 This is an area where we've had a lot of good engagement 21 with INPO. They perform a, you know, their goal of promoting excellence, you 22 know, all the things that they do under that umbrella, I think, the biggest overlap 23 with the NRC's accreditation. And, they've leaned in here.
24 And so, maybe that's, that's the feedback I'd give you is, 25
38 INPO is trying to help us a lot with this to figure out what does accreditation for 1
these, you know, multi-skilled folks look like?
2 COMMISSIONER MARZANO: Well, you must be reading my 3
mind, because my follow up to that question was, the fact that the Institute of 4
Nuclear Power Operations, you know, provides these vital services to the 5
existing fleet, the management of OPEX, the training accreditation, kind of a 6
standard bearer for the industry in that kind of self-policing environment there.
7 So, I mean, we already, you kind mentioned a little bit of 8
INPO's involvement. But, how do you see it, their involvement kind of 9
progressing into the advanced reactor space?
10 And, what kind of challenges do you see for the specific 11 operational needs of micro-reactors?
12 MR. JESSUP: Yeah, no. Again, it's a good follow up. And 13 so, they've been very proactive. Let me say that.
14 They want to understand what the new nuclear industry is 15 doing, micro-reactors in particular, because there are so many different 16 operating models, business models.
17 And so, we've been engaged through their new nuclear 18 accreditation working group, where we're talking about these issues. Not just 19 the multi-skilled workforce, but also the centralization piece I talked about.
20 It looks a lot different to go and accredit the training programs 21 that are done from a central location versus going to every plant, you know, 22 where kind of INPO typically operates.
23 So, those are the two areas we're working with on them of, 24 what does accreditation look like from a central delivery standpoint?
25
39 And, you know, just from a general accreditation standpoint, 1
you know, INPO accredits 12 programs at the current sites. Does that make 2
sense for the new fleet? Not just micro-reactors but otherwise.
3 So, a lot of work going on there. INPO's been very proactive.
4 I mean, my personal experience, you know, from the operating fleet, you know, 5
their promotion of excellence and everything that comes along with that, you 6
know, I think, the new nuclear fleet is going to benefit from that.
7 COMMISSIONER MARZANO: Well, thank you. Yeah, it's 8
certainly a lot of work to be done there. A lot to consider about vastly different 9
operational models for these micro-reactors.
10 Now, I want to turn to Ms. Li and Mr. Schoedel, Schoedel?
11 Sorry, how do you pronounce your name?
12 MR. SCHOEDEL: Schoedel like yodel.
13 COMMISSIONER MARZANO: Schoedel, there we go.
14 MR. SCHOEDEL: It's really easy.
15 COMMISSIONER MARZANO: Yeah, nice and easy. All 16 right. Well, this is going to be kind of a little bit, I want to feed a little bit about 17 the interaction between DOE, INL, eVinci, the DOME, and the NRC's 18 involvement.
19 So, Ms. Li, thank you for your remarks. And, I am certainly 20 appreciative of DOE's continued collaboration with the NRC to enable the 21 deployment of micro-reactors.
22 Can you kind of share a little bit of your thoughts on how we 23 can enhance our engagement, especially considering the existing MOUs 24 between the NRC and DOE that were established under the Nuclear Energy 25
40 Innovation Capabilities Act, and kind of expanded under the ADVANCE Act?
1 And, how, you know, DOE envisions the cooperation through 2
the National Reactor Innovation Center Program?
3 And, you know, in part of your answer, and Mr. Schoedel, 4
would like you to kind of comment specifically on your experiences with the 5
NRC related to the DOME.
6 But, you know, are there other kinds of practices from 7
previous collaborations in our MOUs that we can expand this work?
8 MS. LI: Thank you, Commissioner Marzano, that's a good 9
question. And, we do also appreciate the continued collaboration with NRC.
10 I think, I can think of several possibilities. For example, with 11 the MARVEL micro-reactor that is in development, we could potentially have 12 details from NRC that's similar to what's being done with NRIC.
13 I believe, there's two details from NRC for NRIC, and we can, 14 through that relationship share more details.
15 We've had recent meetings sharing our thought basis for how 16 we documented our preliminary documented safety analysis for MARVEL, and, 17 what the thinking was for that and how we could simplify that process.
18 This is all, again, based on whatever support we have 19 Congressionally. But, we are always open to more conversations and we look 20 forward to whatever we can do through the ADVANCE Act.
21 MR. SCHOEDEL: Yeah, thanks Commissioner, for the 22 question. So, I think, this plays very nicely into, you know, some of the 23 sentiments I had during my opening presentation.
24 So, Westinghouse very eagerly seeks to keep open, 25
41 transparent, clear communication between us, our partners at Idaho National 1
Lab, BEA, U.S. DOE, and Idaho office, and headquarters on our progress on 2
authorizing the eVinci nuclear test reactor for eventual operation and test in the 3
DOME.
4 How are we doing that specifically? To date, it's been through 5
one, you know, contractually organizing this through our safety design strategy 6
with INL and the DOE, to acknowledge that we fully intend to cross-7 communicate and collaborate with NRC as well as CNSC in Canada.
8 Because, we recognize the importance of the results and 9
outcome of this test reactor application for eventually validating, you know, and 10 verifying the safety analysis codes we seek to use for commercial license 11 applications in the U.S. and abroad.
12 So, contractually, it's built into our licensing authorization 13 package paperwork. More practically, how do you disseminate this good 14 information, and the knowledge, and the lessons learned as we go through 15 exercising the licensing modernization project process for our application 16 framework, not just for future eVinci commercial licensing, but, as well for our 17 nuclear test reactor authorization with DOE?
18 We're doing that through presently a series of technical 19 exchange workshops where we'll host NRC staff, CNSC staff, DOE 20 representatives, INL representatives. You know, most recently, we held one 21 last summer at our facility outside Pittsburgh.
22 We intend to host another one later this year as we continue 23 to make progress in the next authorization submissions on that test reactor.
24 COMMISSIONER MARZANO: Excellent. Thank you. And, 25
42 I'm well over my time. But, I do want to say that, you know, I leave with this, 1
that this cooperation is essential for the NRC, not just for, you know, this near 2
term work, but also as we look to adopt a more forward looking approach.
3 And, I'll kind of just leave with a little bit of looking for 4
opportunities for us, and right-sizing at what technical readiness level, you 5
know, the NRC should be stepping in and engaging to support our licensing 6
mission.
7 So, thank you, Mr. Chairman. Apologies for going over. And, 8
I appreciate the panel's presentations. Thank you.
9 CHAIRMAN WRIGHT: Thank you, Commissioner Marzano.
10 Yes, so, before I get to my questions, I had like to address a little bit about how 11 the NRC's work on micro-reactors fits within our new mission statement.
12 You know, our new mission statement, and the guidance that 13 will follow that implements it, is going to refocus our entire staff. And, it's 14 already beginning to do that.
15 As part of the refocusing and doing our part to move forward 16 the nation's goals for nuclear, by enabling, by advancing, deploying safely, 17 we're working to try to do our work a little differently, because, we're going to 18 have to.
19 And, more efficiently as well, so that we can get things 20 through the regulatory process and out the door, right?
21 They've heard me say this before here, and I've said it at the 22 RIC as well, this isn't about safety, right?
23 Because, safety is and is always going to be, our strike zone 24 of our home plate. It's the north star that we're chasing. But, it's about process 25
43 and about adapting.
1 So, as we've heard this morning, there's a desire to 2
manufacture reactors in a factory, and pre-load them with fuel. And, 3
transporting them to site and then moving them back to another facility after 4
they've gone through their life.
5 You know, by themselves, the desire of the oil and gas sector 6
to deploy hundreds of units, may require a regulatory paradigm shift just by 7
itself.
8 But, there's also industrial users, there's data centers, floating 9
reactors, commercial shipping, you name it, they're out there. And, they're all 10 active right now.
11 So, they're looking to us at the NRC, not just to meet their 12 needs, but to anticipate where they've got to be, and be ready for them when 13 they come.
14 Which means we've got to have a lot of communication, and a 15 lot of collaboration, right? And, coordination, which I've heard. On top of that, 16 all of these applicants want to go today.
17 So, I mean, we're really behind even when we talk about it 18 now. I know that we can deliver here. The NRC can do it. I know it. I believe, 19 it.
20 In fact, I've already heard you say here in this panel this 21 morning, words like flexible, the NRC staffs leaning in to be flexible. Timely, the 22 comments are beneficial, and there's been good cooperation. Right?
23 And, those are really good words to hear. Because, we're not 24 who we are being accused of being sometimes, right?
25
44 Because, we have made mistakes in the past. I will sit here 1
and acknowledge that we've been slow in some areas and we've been our own 2
roadblocks at times.
3 But, that's not happening today. All right. And, I think, it's 4
important for us to speak to that.
5 So, with that, thanking you for your presentations and stuff, I 6
want to get to a couple of questions.
7 Bill, good morning to you again. One thing that I haven't 8
heard, and maybe you and Anthony, and maybe even Mo, could address is, so, 9
first let me say we're not going to be this long pole in the tent.
10 The NRC is not going to be that. Okay? But, what I haven't 11 heard is supply chain. Right? Can you talk a little bit about supply chain?
12 And, are you ready for, if we were to grant a license in, like, I 13 mean, five months or six months, if we had to have an EA, I saw that Marc, and 14 the goal that you would have and suggest to us, would you be ready if we were 15 able to meet that deadline?
16 MR. JESSUP: I'll take that first. So, it's a good thought 17 exercise. If we had a license today, could you do it?
18 And, I think, my perspective is that's going to be a function of 19 the technology, in particular, maybe the fuel type. Because, if you look at the 20 front end of the fuel cycle, I break it into five steps, right?
21 The concentrates, the conversion services, enrichment 22 services, deconversion, fuel fabrication. There's a lot of discourse that gets you 23 up too typically the enrichment. It was good to see that the INL had, you know, 24 deconversion as kind of a long-term strategy.
25
45 But, where we are today, particularly for some of the HALEU-1 based fuels, and then fabrication of the fuel itself, the commercial scale of that 2
just, it's limited.
3 I don't want to say it doesn't exist, because, you know, it is 4
being made. But, that is where I see probably the biggest risk from a supply 5
chain perspective.
6 I would say we're in a unique position, because, NOV parent 7
company, we make lots of things. We make lots of heavy machinery.
8 And so, you know, we also engage with the vendors on that 9
front as well when they call us and say, hey, you know, does NOV have the 10 capability of making X, Y, and Z?
11 And so, we have a window into that. But, I would still say that 12 fuel likely remains the long pole in the tent, at least from where we sit.
13 MR. SCHOEDEL: Yeah. Thanks Chairman. And so, I 14 strongly echo what Bill is saying on fuel.
15 Maybe I'll give a flavor of other things that, you know, we see 16 as obstacles that we're actively working through, notably around areas of 17 materials that are intended for, you know, high temperature applications for 18 these types of reactors where, you know, we are today, maybe not fully covered 19 within existing code cases. Right?
20 So, that's an area that we've been, you know, doing I think, 21 meaningful pre-application engagements around, you know, metallics, 22 composites, and the like.
23 So, I think, one of the things though that Westinghouse has 24 as a value, as an established technology vendor, is we have a large supply 25
46 chain, you know, established already.
1 Many of the vendors for some of these, maybe more or less 2
groundbreaking, first of a kind, type of applications in code space, that's pretty 3
well established already on our end, people on our qualified supplier list or our 4
approved supplier list.
So, I think, working through those issues 5
on our materials qualifications, as we communicated to you all in our White 6
papers, as we intend to communicate to you all on our methods for qualifying 7
these types of things in future topical reports, that's all in the details in our 8
regulatory engagement plan. Known areas where we're going to work through 9
it with you all.
10 MR. BADAL: Thank you, Chairman. So, I just want to say 11 from an end-user perspective, just going through engaging at least ten leading 12 micro-reactor vendors in the nation, I want to echo with you is that there is no 13 clear pathway right now for multiple areas that can build a reactor.
14 The fuel, the factory assembly for major components, 15 materials, data points, the code you had just mentioned for safety basis for a 16 new novel solution or idea, because the temperature parameters are different 17 than existing data points.
18 So, those are the challenges that we are considering as we 19 pick our next winner, I would say. Who will be our first, you know, technology 20 that built a reactor on our installation?
21 And then, of course, I think, I must mention our relationship 22 with NRC, it's critical in this area, because a vendor without a regulatory path 23 will not be doing business with the DOD.
24 So, I just want to be very clear about that. So, as we identify 25
47 the technology, we have to figure out those challenges.
1 CHAIRMAN WRIGHT: Thank you. I've got a couple of 2
minutes left. I'm going to come to you, Ms. Li.
3 So, first off, please tell Secretary Wright that his cousin from 4
the Southeast said hello. And, I look forward to meeting him. I think, I'm 5
meeting with him in May. Hopefully I'll get to see him earlier than that.
6 And then, Ted Garrish, I know you probably know him over 7
there as well. So, please tell him hello.
8 You were talking a little bit with Commissioner Marzano, 9
about relationships and how we can work better together and things like that. I 10 want to take that a little deeper maybe.
11 As you sit here today, right now, are there any regulatory 12 changes you would maybe suggest or are looking at that could aid, you know, 13 in the advancement of the rapid and safe deployment of micro-reactors?
14 Stuff that we could work together on, or you talked about that 15 collaboration and stuff?
16 MS. LI: Thank you, Chairman. I think, I would recommend 17 we could have additional conversations about that since I'm not the expert. But, 18 we have many technical experts in that area.
19 We continue to work on identifying, you know, the regulatory 20 basis for supporting micro-reactors. We have put together a couple of reports 21 about, you know, what kind of challenges to consider.
22 But, I am not of a position today to recommend specific 23 changes to regulations.
24 CHAIRMAN WRIGHT: Yeah. Well, I'm confident that we're 25
48 already working together on this over there already.
1 But, I didn't know if there was something that had been 2
through the, just the relationship and engagement that we've had so far. Is 3
there anything that we need to be looking forward at?
4 Because, you know, we're looking at the micro-reactor letter 5
that you sent in last June, and, I think, we responded to. And, I think, there's 6
something else coming maybe this June.
7 So, you know, maybe we can, I know this is a hugely 8
important area for everybody, from the President on down. And, we need to be 9
ready to move, right?
10 So, look forward to working with you.
11 MS. LI: Yeah. We have, we are very much appreciative. We, 12 just for example, for Part 53, we have seen that NRC has been open to input 13 from industry.
14 And, as that is aligned with DOE's efforts to deploy micro-15 reactors and advanced reactors in general, we see that that is very helpful for 16 us.
17 CHAIRMAN WRIGHT: Yeah. Thank you so much. And, 18 thank you for taking my questions. And, for now, I'm going to turn it over now to 19 Commissioner Caputo.
20 COMMISSIONER CAPUTO: Thank you all for being here, 21 and for contributing to the conversation. I also want to note that all of you 22 complimented the NRC staff on their work that they're doing in this area.
23 And, I just want to thank you for those compliments and that 24 recognition. There is a lot of work that is underway and a lot that remains. And 25
49 so, I just thank you for, on their behalf, for recognizing their progress.
1 I also want to say that a lot of great questions from my 2
colleagues this morning. I'm going to come at this from a little different 3
direction.
4 People of a certain generation may remember a commercial 5
from years ago where a child hands a Tootsie pop to an owl and says, how 6
many licks does it take to get to the center of a Tootsie pop?
7 So, I'm just going to take a leap here and give a little pop quiz 8
to you speakers. How many licks does this take?
9 How many different regulatory approvals do you see before 10 we get to that first unit?
11 MR. JESSUP: I will take a first stab, Commissioner Caputo.
12 For the first unit, likely on the order of six to eight regulatory approvals.
13 And, I would say that excludes some of the materials, specific 14 approvals, Part 30, Part 40, and maybe Part 70, since those typically get 15 bundled with kind of the primary application.
16 And, that would be what I suspect when you include 17 manufacturing licenses. If you want to do in factory testing, site licenses, 18 transportation certificates of compliance, and interim storage facility.
19 So, and, that's probably a function of what the deployment 20 cycle looks like as well, do you want to do in factory testing?
21 And, I'm excluding throughout the life cycle at the site as well, 22 because, that's going to come along with more regulatory approvals, at least 23 the way we're envisioning right now.
24 Depending on whether you go the part 52 route, or the two-25
50 step Part 50 route, that will determine what regulatory approval you need at the 1
site every time you want to replace that module, so.
2 MR. SCHOEDEL: Yeah, thanks. I'm smiling here, because I 3
think, you're really hitting the nail on the head, or addressing the elephant in the 4
room, from my perspective on the stark contrast between us, you know, with 5
eVinci trying to get first of a kind available to market.
6 But, acknowledging what efficiencies, we may want to try to 7
drive for future, nth-of-a-kind solutions along the way.
8 I think, we're going to learn a lot going through the first 9
application process for delivering this technology beyond just our nuclear test 10 reactor. To answer your question specifically, I would just walk around the 11 eVinci deployment model from my last slide.
12 You know, so, if we look to assemble in a factory, and these 13 are all things that we're contemplating now as we go through, how do you bring 14 this new technology to market, you know, by 2030, for what our customers or 15 potential customers are looking to see?
16 And, by the way, they are no longer operating on a five to ten-17 year window of business planning. They're operating on a 48-month business 18 window planning in many cases, where the best I can show right now is a 19 CPOL under Part 50, or, a COL, you know, extending out to beyond those 20 timelines for their planning.
21 So, Commissioner, or Chairman
- Wright, as you 22 acknowledged, won't be the bottleneck here. This is exactly where I think, we 23 need to start focusing on how to use shrink it effectively?
24 But, stepping around the deployment model, assembly in a 25
51 factory would require, from our perspective, a manufacturing license as 1
postulated in the SECY in front of you, while for votes.
2 Maybe you couple that with a Part 70 to allow fuel load.
3 Without that, I still need some type of an operating license if I want to load fuel 4
as it is today, either a CPOL or a COL.
5 So, I'm already up to three licenses just to enable the first 6
step in that deployment process. Short of some type of risk informed, you 7
know, type of a process that is envisioned in 24-0008.
8 That also includes other things like byproducts, et cetera, that 9
I'm lumping in, but not specifically naming.
10 Transportation, as Bill mentioned, would require a Part 71 11 CoC, as well as some route-specific licenses through states and different 12 territories and localities.
13 You tend to go through the customer, or end user, 14 owner/operator is going to require their own CPOL or COL, based off of the 15 technology design that I would have approved through my ML. So, that's 16 another set of an entire licensing process to that intended operating location.
17 The transport license would, under our paradigm, support 18 back-end transportation. But then, as we talked earlier from your question, you 19 know, I would need a Part 72 type of a license application for my refurbishment 20 or storage activities, you know, whether it's at my manufacturing facility or 21 somewhere else.
22 So, you know, just hitting the highlights, all of those are right 23 now perceived as necessary. But, I think, the challenge first-of-a-kind, nth-of-a-24 kind, is going to be minimizing the replication on all of those.
25
52 I don't want an operating license at my manufacturing facility, 1
in addition to my manufacturing license, and have every customer have an 2
operating license for every module that comes off that assembly line.
3 I need to start getting this into like, a Ford assembly line 4
mentality where you call, you place an order for a vehicle, it takes a few months 5
to come off the assembly line, and you are limited by your manufacturing time 6
and the delivery time, not necessarily the licensing time and needing duplicate, 7
or in my view, duplicative licenses, just to accommodate regulation.
8 COMMISSIONER CAPUTO: Marc, I'm going to get to you in 9
just a minute. I think, both of you have mentioned a lot of items.
10 I have my own list. I think, some of us overlap. I probably 11 have a couple here that weren't mentioned.
12 But, I'll just start at the beginning. Reactor design approval, 13 manufacturing facility license, which Mr. Schoedel discussed, verification that 14 the unit was built according to requirements, transportation canister, but also, 15 transportation of the unit with fresh fuel.
16 Operation on location, sighting approval, transportation 17 canister and transportation with used fuel, license for a refurbishment refueling 18 facility, license for storage and disposal, decommissioning at the end of life.
19 And, that is in addition to what was just mentioned in terms of 20 fuel qualification and fuel manufacturing.
21 So, as Mr. Schoedel was saying, not all of these steps are 22 going to be repeated for each unit. Most of them are probably necessary for the 23 first unit.
24 Several of these steps involve ACRS reviews, environmental 25
53 reviews, and hearing opportunities. So, this is a rather torturous path for the 1
first unit, but also for, nth-of-a-kind, and, as you were just saying, whether it's 2
for one or 20.
3 So, recognizing that, you know, the way to eat an elephant is 4
one bite at a time, what I'm -- I'm raising this, because as the Chairman just 5
mentioned, you know, a paradigm shift, I believe, we need a paradigm shift 6
here.
7 Because, our principle of efficiency states, regulatory activity 8
should be consistent with a degree of risk reduction they achieve. And, for 9
micro-reactors, the risk profile is dramatically lower than what this agency has 10 typically licensed.
11 And, the nature of micro-reactors is very, very different from 12 what would have been envisioned in the Atomic Energy Act 60 years ago.
13 So, at a basic level, we need to ensure the manufacturer of a 14 safe reactor, safe operation and maintenance, safe transportation, safe storage 15 and disposal.
16 The NRC staff has identified 36 issues that need to be 17 addressed. I'm searching for a strategic approach that's going to effectively 18 navigate the necessary issues, but also ensure that the regulatory burden is 19 aligned to micro-reactor size and risk profile.
20 So, Marc, I'll start with you. Do you have suggestions as to 21 how we could go about workshops, or structuring workshops, to sort of get at a 22 strategic approach?
23 I know you mentioned earlier in your remarks, how the 24 approach that we take is going to be tethered to our starting point. And, I agree 25
54 with you that that starting point, based on the risk profile of a micro-reactor, is --
1 should be a lot closer to starting point for a research reactor or a non-power 2
facility.
3 But, even if we all agree that that's a starting point, how do 4
you work your way through these issues in a strategic manner?
5 Not necessarily what's most urgent and swatting the nearest 6
snake, but, go through this in a strategic manner that's going to sort of create 7
the predictable licensing path that Mo is highlighting as needed here?
8 MR. NICHOL: Yeah. That's a great question. I think, in your 9
question you had the answer, which is workshops.
10 This is, that's the fastest path to getting to some regulatory 11 conclusions. And, one of the points I made, is focusing on the regulatory basis 12 for these topics.
13 Because, what the regulatory basis affords, is an NRC 14 conclusion that this approach is safe.
15 Now, steps after that, we'll identify how do you implement that 16 under Part 50 and 52 today and in the future, exemptions and rulemaking?
17 How do you do it in part 53? Is it enabled now? Do you need 18 additional changes? Those things can be worked out.
19 But, if we don't have the foundation, which is the NRC 20 concluding that that approach is safe, you can go off and do that approach.
21 Until we have that, there's a lot of business risk and uncertainty.
22 And so, getting to that regulatory basis is key. And, how we 23 get to that is through workshops. Now, the NRC is embarking on a lot of work.
24 Industry and other stakeholders can embark on a lot of work 25
55 as well. Some of those topics, we've already submitted papers on, 1
meteorology, fire brigade, we have others coming.
2 And so, we can contribute to that. All the work doesn't have 3
to fall on the staff. The NRC ultimately has final decision making on that. But, 4
we can provide a lot of the details and input to help move this forward faster.
5 COMMISSIONER CAPUTO: Okay. Thank you. I just want to 6
note that clearly given what we've heard this morning, given the investment 7
that's underway, that's a clear demand signal here for micro-reactors.
8 So, I appreciate everything you're doing, all of you, to 9
advance the ball and make progress here. Because, I do think, this is going to 10 be a technology that's important to meeting the country's energy needs.
11 So, thank you.
12 CHAIRMAN WRIGHT: Thank you, Commissioner Caputo.
13 That was very good.
14 Commissioner Hanson?
15 COMMISSIONER HANSON: Thank you, Mr. Chairman.
16 Thanks for everybody for being here.
17 Mr. Schoedel, I really appreciated your kind of, breaking down 18 the various regulatory touch points, right?
19 And, Mr. Nichol, I appreciated your presentation too, about 20 what's the starting point and how do we kind of move out from that, right?
21 But, even in the case of like, RTRs, I think, that's a really, I 22 think it's a great insight, right?
23 But, they're kind of things that don't quite necessarily line up 24 and match, and the analogs aren't entirely the same. And, yet, I completely 25
56 agree with the principle that how do we kind of adjust or change the regulatory 1
touch points that we have, right?
2 So, maybe we're touching that manufacturing license and we 3
don't have to touch everything that comes off the assembly line. I love the, as a 4
Michigan guy, I love the Ford metaphor, okay?
5 Right, I mean, you know, if we're comparing, you know, micro-6 reactors to F-150s, you know, there's something to that, right?
7 Because each F-150 is, you know, there's a quality assurance 8
program that that manufacturer has. Each thing gets a VIN number. You can 9
trace that VIN number. You can trace the whatever kind of quality things that 10 go along with that.
11 I think, Caterpillar is another really great example for all of 12 their machines. Their machines basically talk to their headquarters in Peoria, 13 from all over the world.
14 They've got 1.5 million machines out there that, as a friend of 15 mine said, tweet like teenagers. You know, like basically text headquarters like 16 teenagers on everything that they're doing.
17 There's a lot of advancements in other manufacturing and 18 heavy equipment industries that I think, really have a lot of comparisons here 19 that we can also kind of draw on while we're, as the Chairman quite rightly said, 20 focused on our mission, keeping the safety piece of that front and center while 21 we're thinking about what the right regulatory footprint is.
22 And, I think, as we think about the chicken and egg problems, 23 right, that the Chairman also mentioned. I know chickens and eggs are a very 24 sensitive topic these days.
25
57 But, the regulatory kind of clarity and efficiency, is really one 1
of those. And, that's clarifying that, and getting that under wraps, is going to be 2
really important for the NRC, not only from an efficient standpoint, which I think, 3
you know, Bill, you emphasized. But, also from kind of a reliability thing.
4 And, I think, what I'd just like each of you to kind of touch on 5
is, I completely agree, Mr. Schoedel, with your thing about, you know, what are 6
the policy things?
7 What can we do by exemption? How do we get that first of a 8
kind thing? But then, how do we establish the reliability and predictability about 9
that pathway?
10 And, where does, if it needs to rulemaking or even potentially, 11 heaven forfend, statutory changes to the AA, where do those come in?
12 Because of, Mr. Nichol, as you pointed out, that there are a lot 13 of good analogies here. But, there are some also things that don't quite fit.
14 MR. NICHOL: I'll start off, in terms of how do we get to that 15 basis. I think, it's in that regulatory basis that I was talking about.
16 So, that would be the NRC's conclusion decision that this 17 approach, if done this way, is safe.
18 Now, it's not saying that it's currently allowed under the 19 regulations. It may not be currently allowed under the regulations.
20 But, we have the approach of taking exemptions if the NRC 21 determines it's safe. So, it's determining ahead of time that this particular 22 approach is safe, recognizing that exemptions may be needed near term, 23 rulemaking longer term.
24 That gives the ability for industry to come with those 25
58 approaches, with predictability that the NRC would accept them.
1 COMMISSIONER HANSON: Okay. Thanks. Anyone else?
2 MR. SCHOEDEL: Yeah, thanks Commissioner. So, a bunch 3
of thoughts. And, I'll try to keep them coherent here for the sake of time.
4 And so, I think, your emphasis on both safety and reliability, 5
so again, that's probably something I glossed over at the end of my 6
presentation. But, my last slide, that's the vision, right?
7 It's incumbent upon, you know, us as a technology vendor, as 8
we go through our design development test programs and processes, that we 9
address both safety and reliability in our design.
10 And, we make that apparent to you all and to your staff, 11 through things like pre-application engagement, White papers, through topical 12 report, piecemeal approvals, and ultimately in these first of a kind applications.
13 The affordability is the other piece of this, right? And, that's 14 where some of the licensing efficiencies we're talking about here are going to 15 have a direct play for not just first of a kind, but specifically our nth-of-a-kind.
16 Where we drive licensing efficiency to really help keep nth-of-17 a-kind affordability specifics, right?
18 So, I think, my opinion, SECY-24-0008, again, I'm a broken 19 record on that, it was partly informed by input that Westinghouse wrote to NRC 20 staff.
21 But, in there, as you contemplate those three topic areas, the 22 risk-informed options one, two, and three Bravo, I think, the staff did a nice job 23 at highlighting areas where implementation would have both risks and 24 disadvantages for long-term rulemaking concerns.
25
59 I think, you see similar aspects around that on the nth-of-a-1 kind white paper that was developed last year, when we talk about operational 2
programs or environmental review efficiencies.
3 But, those are good areas where we have examples in front 4
of you now, or soon come to you, on these areas, where it seems like, you 5
know, we could be making progress on putting out, you know, guidance, you 6
know, assuming, you know, favorable outcome from your votes, through the 7
staff to industry on some of these areas.
8 The consequence of piecemeal approvals and guidance, is 9
just that. That you don't see the big picture. And, there may be long-term 10 implications or rework or churn on that guidance, because you don't see the 11 entire thing at once.
12 But, you know, the more we can do to not handcuff the 13 industry, having to consider the entire elephant now, and give us some 14 piecemeal progress on items that I've been communicating through the eVinci 15 team since 2021, would unlock, just continued de-risking, and start, I think, to 16 yield more progress.
17 COMMISSIONER HANSON: Yeah. Super helpful. Yeah, 18 go ahead, Bill.
19 MR. JESSUP: Yeah, I would just add, I think, the way to 20 increase reliability, and drive down uncertainty in kind of the licensing approach 21 here, is just to start exercising the process.
22 There's clearly a willingness on the part of the NRC to explore 23 these areas, all these enablers we're talking about.
24 But, I think, we're going to have to start exercising the process 25
60 to see, to drive -- because, there's kind of an uncertainty band on all of them.
1 Some of them, it's like, okay, we feel pretty good about this.
2 But, collectively, we're going to have to start exercising the process.
3 It's going to take some incremental implementation, I think. I 4
think, you know, the operating model is going to have to evolve.
5 And then, the technology is going to iterate as well. I think, 6
we're going to learn things.
7 And, you know, by the end of it, I expect that the licensing 8
process will have evolved with it and, you know, we can get there.
9 COMMISSIONER HANSON: Yeah. No, I think, that's a really 10 great point. There's a great opportunity for learning on kind of both sides of the 11 table here as we move forward.
12 So, thank you all for your questions. I'm going to try and 13 squeeze in one more here. Obviously, because Mr. Schoedel was here, and 14 you guys presented your concept around Westinghouse, that was really helpful, 15 right?
16 Because, it was a specific thing that we could kind of drill 17 down into. But, there are other concepts for micro-reactors too, right?
18 We're going to have a focus on the transportable ones this 19 morning, just kind by nature of the panel that we have.
20 But, there are others where it's kind of modular construction, 21 or -- and fueling onsite. And, a lot of other things.
22 And, I guess, as we think about both the strategic, as well as 23 getting down into the details on some of these things, how much difference 24 does that make in regulatory space?
25
61 And, Marc, maybe I'll just start with you. And --
1 MR. NICHOL: Yeah. So, we can look in two directions. We 2
can look at maybe larger ones that are more constructed onsite.
3 And so, those would, in comparison to the micro-reactors we 4
have been focusing on, would have a smaller subset of issues that they would 5
look at.
6 Many of them would be able to implement the exact same 7
strategies. Some might have a different performance level that would only be 8
able to implement parts of the strategies.
9 If we look at the other direction, which would be much more 10 transportable, these might be things that you would want to deploy within days 11 or weeks rather than months.
12 The RHDRA paper that we proposed, isn't enough for them.
13 They need additional considerations. They need -- because, we got what we 14 think is the NRC's site license process down as small as we think is feasible, 15 that's about four to five months.
16 To get down to days or even a few weeks, that's going to 17 require something like a general license, where the NRC doesn't need to pre-18 approve a site. You could just go wherever you want, as long as you can 19 confirm that that site is acceptable.
20 And, this may be very important for emergency response 21 activities, for example.
22 COMMISSIONER HANSON: Thank you. Anyone else?
23 Yeah, Bill?
24 MR. JESSUP: I'll share a perspective. It relates to the very 25
62 last bullet I had on my slide deck, not the thank you slide, but the other one.
1 Which is, I think, across especially advanced reactor 2
technologies, a lot of those characteristics, inherent safety features, passive 3
safety systems, they're shared.
4 But, certainly for us, we do feel like we are quickly getting to a 5
point to where you do need to pick a technology to get regulatory certainty.
6 Remote operations may be a good one. I wouldn't expect the 7
agency to approve that as an operating philosophy, absent some rigorous 8
human factors engineering that demonstrates, yes, this is what your function 9
allocation looks like, you know, for this specific technology perhaps on this 10 specific site.
11 I think, you could do it at a technology level. You know, you 12 are going to have to do the work. And, we would expect that, you know, for the 13 NRC to actually approve something.
14 So, that's how we see the regulatory nexus here.
15 COMMISSIONER HANSON: Yeah, sure.
16 MR. BADAL: So, I was going to make a comment about like, 17 larger modular fueled onsite. For end-user perspective, we would be interested 18 in what's the timeline look like, mobilizing or, you know, deploying something 19 like that over time.
20 And then, like onsite fueling, what are some of the risk factors 21 maybe involved if we're deploying something like a military installation, right?
22 So, those considerations also may have to be thought 23 through.
24 COMMISSIONER HANSON: Okay, good. Thank you.
25
63 Thank you, Mr. Chairman.
1 CHAIRMAN WRIGHT: Thank you, Commissioner Hanson.
2 And, thank you again. This has been a great conversation. We could probably 3
go a lot longer too. I know that.
4 So, we're going to take a break. We're going to endeavor to 5
try to be back and set up for the second panel in about a quarter till.
6 So, with that, we will recess and come back, and convene in a 7
few minutes.
8 (Whereupon, the above-entitled matter went off the record at 9
10:39 a.m. and resumed at 10:47 a.m.)
10 CHAIRMAN WRIGHT: Welcome back, and good morning 11 again. Our next panel is going to be kicked off by the NRC's Executive Director 12 of Operations Mirela Gavrilas. Mirela, good morning. The floor is yours.
13 MS. GAVRILAS: Good morning, Chairman, Commissioners.
14 The topic of micro-reactors is very dear for me on a profoundly personal level. I 15 decided to be a nuclear engineer because as an undergrad, I started working at 16 the University of Maryland Research Reactor.
17 I became an SRO for that reactor in my sophomore year to 18 get to Commissioner Marzano's question about the level of training. And I 19 found small scale reactors, research reactors fascinating throughout my career.
20 I actually started my career as an executive in research reactors and the first 21 manifestations of micro-reactors of which SHINE is certainly a lead.
22 But I don't think at any point throughout my career have 23 micro-reactors have the strategic significance that they have today since the 24 very early times of our industry. And with that, I'm going to pass the baton to 25
64 Jeremy who is going to introduce the panel and lead our conversation. Jeremy.
1 MR. BOWEN: Thanks, Mirela. Good morning, Chairman.
2 Good morning, Commissioners. Thanks for the opportunity to present to you 3
this morning. So my name is Jeremy Bowen. I'm the Director of the Division of 4
Advanced Reactors and Non-Power Production and Utilization Facilities.
5 As you've already heard this morning, over the past few 6
years, there's been an increasing interest in the licensing and large-scale 7
deployment of micro-reactors. Their simplicity and scalability have the potential 8
to greatly expand the use of nuclear power. Whether they will operate as part 9
of the electric grid, serve as an independent power source, or provide thermal 10 energy for industrial applications, the NRC is engaged with the micro-reactor 11 community to enable their safe, secure, and timely deployment. Next slide, 12 please.
13 Staff has worked closely with micro-reactor developers and 14 potential end users to better understand the various technologies and planned 15 deployment models. These interactions led to the identification of potential 16 policy issues, infrastructure enhancements, and communication tools that would 17 further facilitate reliable licensing and oversight of micro-reactors. Pre-18 application engagements resulted in development of several Commission policy 19 papers with the first one in October 2020 where staff provided an early outline 20 of potential regulatory considerations and an initial licensing approach.
21 Further, stakeholder interactions indicated widespread 22 alignment that the regulatory issue of highest importance for developers was 23 the ability to load fuel and perform operational testing in a factory. In January 24 2024, the staff provided the Commission with policy options and 25
65 recommendations to enable that business model. A related information topic in 1
that paper dealt with transportation considerations.
2 Cinthya Roman, Deputy Director for the Division of Fuel 3
Management, will touch on this unique aspect of micro-reactors in a few 4
moments. Further interactions reinforce the timeline from application to 5
deployment is a vital area and needed creative thought, particularly for high 6
volume licensing. Staff is currently finalizing a paper that identifies policy and 7
process changes that would better support licensing subsequent or nth-of-a-8 kind micro-reactors. Duke Kennedy, a senior project manager in Division of 9
Advanced Reactors, will tell you more about that shortly.
10 The staff is coordinating these efforts for the development of 11 Part 53 to support micro-reactor licensing. The stakeholder interactions also 12 identified the need for further enhancements beyond policy and regulation 13 changes. Additional clarity was requested around how various processes 14 would apply to micro-reactors.
15 So to support those discussions and track progress on a large 16 scale of regulatory topics, the staff recently developed a micro-reactor public 17 website and an integrated micro-reactor activities plan. The website and plan 18 can be accessed by scanning the QR codes on the bottom right-hand corner of 19 the current and the next slide. The plan also supports the staff's response to 20 direction in the Accelerating Deployment of Versatile, Advanced Nuclear for 21 Clean Energy or the ADVANCE Act. Next slide, please.
22 Section 208 of the ADVANCE Act directs the NRC to develop 23 and implement risk informed strategies and guidance to license and regulate 24 micro-reactors in eight topical areas. These are annotated on the left-hand side 25
66 of the screen. Dan Barnhurst, an environmental projects branch chief, and 1
Jessie Quichocho, a branch chief in the Division of Preparedness and 2
Response, will discuss two examples of the staff's approach for these areas.
3 Overlapping and extending beyond the ADVANCE Act are the 4
suite of the regulatory topics identified by the staff and the micro-reactor 5
community. The staff's integrated plan provides a mechanism to facilitate a 6
systematic approach to ensuring common understanding of the various issues, 7
identifying actions to achieve the desired objectives, and tracking progress of all 8
the activities. An initial workshop was set on February 20th to obtain feedback, 9
and stakeholders expressed appreciation for the staff's efforts in development 10 of the plan and support for the proposed list of actions and their prioritization.
11 The staff will continue to engage with the micro-reactor 12 community through a series of future workshops to address these topics and 13 others outlined in the plan. Adjustments will be made as needed, and progress 14 will be communicated through the NRC's public website and public meetings.
15 The staff is excited to license micro-reactor designs in various deployment 16 models, and we are committed to further innovation in a manner that provides 17 additional flexibilities without inhibiting future evolution by the micro-reactor 18 community. I'll now turn it over to my colleagues to elaborate on these topics.
19 Next slide, please.
20 MR. KENNEDY: Good morning. I'm going to discuss the 21 NRC staff's recent policy recommendations and strategies for licensing and 22 regulation of micro-reactors, Section 208 of the ADVANCE Act, and the staff's 23 integrated micro-reactor activities plan. The NRC staff's focus in these activities 24 is on increasing the flexibility of NRC's regulatory framework to enable 25
67 deployment of developer's diverse micro-reactor technologies. Next slide, 1
please.
2 In SECY-24-0008, the NRC staff developed three policy 3
recommendations related to high priority topics for factory fabricated micro-4 reactors and provided information and near-term strategies related to ten 5
additional topics. The first policy recommendation is an approach in which a 6
micro-reactor that includes features to preclude criticality would not be in 7
operation and loaded with fuel. An operation would begin with the removal of 8
those features.
9 Under this approach, an operating license would not be 10 required just because the reactor is loaded with fuel. Because the reactor 11 would not be in operation and an operating license would not be required, this 12 would enable the staff's near-term strategy to use the existing transportation 13 regulations for fueled micro-reactors which Cinthya will cover next. The second 14 policy recommendation is an approach for authorizing only fuel loading into a 15 micro-reactor that includes features to preclude criticality.
16 Instead of requiring an operating license to load fuel, the 17 licensee would possess the reactor under a manufacturing license and possess 18 and load the fuel under a special nuclear material license. The requirements for 19 special nuclear material licenses better match the technical and safety aspects 20 of loading fuel into a micro-reactor with features to preclude criticality. And this 21 approach will reduce administrative requirements and improve timeliness of 22 licensing just fuel loading.
23 The third policy recommendation is to apply most of the safety 24 regulations for non-power reactors to authorize fuel loading and operational 25
68 testing in a factory. The NRC staff recognizes that the operational 1
characteristics and safety considerations for micro-reactors operated only for 2
testing would be like those for currently licensed non-power reactors. The 3
safety regulations for non-power reactors are well established and will reduce 4
the need to tailor power reactor safety regulations on a case-by-case basis for 5
operational testing. Next slide, please.
6 So this slide shows the staff's strategy for reducing the 7
schedule and cost of licensing nth-of-a-kind micro-reactors. It includes a policy 8
recommendation to enable the staff to review and afford technical and 9
regulatory finality to standardize operational programs at the design phase in 10 connection with the review of the standard design. The strategy also includes 11 alternative approaches for environmental reviews which Dan will discuss soon 12 and the staff's near-term strategies for other topics related to nth-of-a-kind 13 licensing.
14 The main drivers for the schedule and cost productions are 15 standardization and regulatory process enhancements. Standardization of the 16 design, operational programs, including security and emergency preparedness, 17 and generic environmental reviews will allow the NRC staff to focus its review of 18 an application for an nth-of-a-kind reactor on site-specific factors and simple 19 verification that the design is identical to one already reviewed by the NRC.
20 This will result in streamlined license applications and NRC licensing 21 documents that can be processed through an online portal to automate many 22 administrative processes.
23 The staff is also pursuing approaches for grading the level of 24 site characterization and scaling construction inspections based on experience 25
69 to focus on areas most important to safety and the environment. However, 1
departures from the standard design, selection of sites with significant 2
environmental impacts, and activities outside of the NRC staff's control could 3
limit the effectiveness of the staff's strategy. In the case where an applicant 4
makes a modification, the staff will perform a delta review as was recently done 5
for the Kairos Hermes 2 application.
6 The NRC staff anticipates that the first few deployments of a 7
standard design will take longer but still much less than recent first-of-a-kind 8
reviews. The benefits of nth-of-a-kind licensing for applicants and the NRC will 9
be realized and accumulate with success of deployments of the standard 10 design. The staff's policy recommendations and strategies described in this 11 slide and the previous one provide the regulatory flexibility to enable early 12 deployment of transportable first-of-a-kind and nth-of-a-kind micro-reactors.
13 The NRC staff chose to pursue options and strategies that 14 use the existing regulations to provide near term clarity on foundational aspects 15 of micro-reactor deployment models. However, as developer's designs and 16 deployment models mature, the staff will consider additional policy 17 recommendations and rulemaking to reach an optimal regulatory framework for 18 micro-reactors. Next slide, please.
19 Section 208 of the ADVANCE Act covers eight topical areas 20 related to regulation of micro-reactors and directs the staff to -- the NRC to 21 consider unique characteristics of micro-reactors and opportunities to address 22 redundancies and inefficiencies.
23 The staff are already addressing the ADVANCE Act through 24 completed and ongoing activities. To name a few, the Part 53 proposed rule 25
70 addresses topics such as staffing, operational programs, and decommissioning 1
funding assurance. The staff has also communicated to the Commission its 2
path forward to develop the Advanced Reactor Construction Oversight Program 3
and the proposed rule on alternative physical security requirements for 4
advanced reactors would apply to micro-reactors.
5 Ongoing work on transportation, environmental reviews, and 6
emergency preparedness that will address the ADVANCE Act with be covered 7
by Cinthya, Dan, and Jessie. The staff is taking many additional actions to fully 8
address the ADVANCE Act. Notable focus areas are remote operation and 9
autonomous operation, oversight and inspection during an operation, siting in 10 relation to licensing mobile micro-reactors and the population density criteria, 11 and alternative licensing approaches for deployment of fleets of micro-reactors.
12 As directed by the ADVANCE Act, the staff is consulting with 13 the Department of Energy, other federal agencies, technology developers, and 14 other stakeholders. This includes through public meetings and workshops on 15 specific topics, pre-application engagement, and memoranda of understanding 16 in cooperation with other federal agencies. As examples, public workshops and 17 licensing mobile deployment and alternative approaches for fleet licensing are 18 scheduled later in April and May. Next slide.
19 This slide shows the depiction of the prioritization of topics 20 included in the staff's integrated micro-reactor activities plan. The plan provides 21 a comprehensive view of current micro-reactor topics and their integration to 22 support internal and external communication and engagement on priorities and 23 actions to address them. The plan considers feedback from interested and 24 affected parties such as industry stakeholders and the public, direction in the 25
71 ADVANCE Act, ongoing rulemakings and guidance development, and 1
engagement with developers and prospective applicants.
2 Since 2020, the staff have updated and prioritized micro-3 reactor topics considering stakeholder feedback. And this guided the decisions 4
on the policy recommendations and information topics to include in the papers 5
that I discussed earlier. Finally, at the bottom of the slide is a list of micro-6 reactor policy topics.
7 The four on the left have already been or very shortly will be 8
addressed in policy papers. The staff are developing policy recommendations 9
for the two on the right largely in response to the ADVANCE Act. And what 10 aren't shown here are the policy topics that are already being addressed in 11 ongoing rulemaking activity such as staffing, security, decommissioning funding 12 assurance, and others.
13 As micro-reactor technologies and deployment models 14 continue to evolve and mature, topics being covered under the existing 15 regulatory framework in the near term, such as transportation of fueled reactors, 16 may in the longer-term benefit from policy decisions. And new topics may arise 17 that involve policy matters. The staff will engage with the Commission as 18 appropriate as it adjusts its priorities and takes actions to enable the 19 deployment of diverse micro-reactor technologies. With that, I thank you for 20 your time and turn the presentation over to Cinthya.
21 MS. ROMAN: Good morning, Chairman Wright and 22 Commissioners. Today, I'll cover transportation considerations for micro-23 reactors. Next slide.
24 The current regulatory framework for the transportation of 25
72 radioactive materials supports the licensing needs for the near term micro-1 reactor applications.
2 At this time, we have not identified the need for policy 3
changes for the transportation framework. So how it works, a vendor can 4
request a certification of a transportation package for a micro-reactor under 10 5
CFR Part 71. And if safety is demonstrated, the NRC will issue a certificate of 6
compliance.
7 There is no rulemaking involving the process like we do for 8
storage cask systems. Once the package is certified, it can be manufactured 9
multiple times and used by the general licensees at no additional cost because 10 no additional approvals are needed as long as the general licensee follow the 11 conditions of the certificate of compliance for each shipment. Also, since there 12 is no additional wait time for regulatory approval, this supports the rapid high 13 deployment of micro-reactors.
14 While the focus of my presentation is on the transportation 15 package, as you can see in the picture, there are many other aspects of 16 transportation, including effects of the environment, physical protection, and 17 emergency planning. Also, it is important to note that the NRC is not alone in 18 regulating the transportation of radioactive materials. It is a coordinated effort 19 across multiple agencies, including the Department of Transportation, the 20 Department of Energy, and Homeland Security.
21 Outside of the federal agencies, Tribal Nations, state and 22 local governments are also involved in the spent nuclear fuel transportation.
23 NRC along with all these organizations have enabled the safe and secure 24 transportation of radioactive materials for decades. And the same structure will 25
73 apply for micro-reactors. Next slide.
1 So there are some key differences in the transportation 2
approach for every micro-reactor design because micro-reactors can vary in 3
size, fuel type, deployment model, and transportation method. So let's break 4
down some of these key differences. Transportable versus mobile micro-5 reactors, transportable micro-reactors are built in a factory.
6 They are shipped to a specific site where they will operate.
7 Once in installed, they stay in place until decommissioning. Mobile micro-8 reactors are designed to move between multiple locations as needed.
9 It could be deployed for disaster relief, military operations, or 10 remote communities that need temporary power. Please note that mobile 11 doesn't mean that the reactor will operating during transportation. In fact, the 12 reactor must remain subcritical during transportation to meet existing 13 requirements.
14 There are different transportation modes, weights, and size.
15 Some micro-reactors might be small enough to fit into a standard shipping 16 container and travel by road. However, larger designs might require rail 17 transport due to size and weight constraints.
18 In some cases, transport might involve maritime shipping and 19 requiring additional considerations for port security and specific maritime 20 regulations. The chosen transportation method, weight and size will impact the 21 regulatory approvals, route planning, and package certification needs. There's 22 also new fuels.
23 Micro-reactors will use a range of different HALEU fuel 24 designs which might include TRISO and metallic fuels. And then the end-of-life 25
74 transportation micro-reactors might not store spent fuel at their site of operation.
1 Instead, they might be transported back to a manufacturing facility as we heard 2
this morning. Next slide.
3 So fueled micro-reactors will likely need to meet Type B 4
transportation package standards. As shown in this slide, Type B packages 5
must pass impact, puncture, fire, and water immersion test in sequence. The 6
test sequence encompasses more than 99 percent of possible vehicle 7
accidents. Computational models are allowed to simulate these accident 8
conditions. Next slide.
9 Some micro-reactors might need to employ novel packaging 10 strategies and approaches such as the package or portions of the package 11 being integral parts of the reactors versus the package surrounding the entire 12 reactor. Transportation regulations will work for different designs, including self-13 contained designs for the entire reactor as support systems feed into a single 14 container and other designs where the core module is manufactured and 15 shipped to a different site to support systems are constructed in place.
16 While some micro-reactor vendors have indicated that they 17 can meet the same test and conditions that I showed you before, for some of 18 them demonstrated that they can pass similar tests can be challenging.
19 However, Part 71 requirements allow for exemptions, alternative test method, 20 and special package authorizations when compliance with the standard 21 regulations is impractical. In fact, we have been implementing this requirement, 22 and I want to provide some first-of-a-kind examples. Next slide.
23 So the first example is the NAC OPTIMUS-L package for 24 TRISO fuel. This is the first NRC certified transportation package for fresh 25
75 TRISO fuel with HALEU up to 20 percent for Uranium-235. We demonstrated 1
that NRC can certify packages for new fuel types under the existing framework.
2 For this example, engagement and pre-application discussions help to ensure 3
a high-quality application, and their review was completed in 13 months and 4
using 40 percent of estimated resources.
5 Most recently, Project Pele, a micro-reactor from the 6
Department of Defense, needed an exemption from some of the provisions in 7
Part 71. The NRC review and endorse risk methodology that demonstrated that 8
the exemption would not compromise public safety. This methodology is 9
adaptable and could potentially be integrated into future transportation 10 certification applications. Next slide.
11 NRC also has experience approving special package 12 authorization for complex shipments involving large, contaminated objects. For 13 example, in 2015, we authorized a special package for a large vitrification 14 melter used for nuclear waste processing at West Valley. And more recently in 15 2023, NRC certified a package to enable the transportation of a large reactor 16 component from the Crystal River Unit 3 nuclear power plant.
17 So why do these examples matter? Some micro-reactors 18 might need similar special authorizations, particularly if they are transported as 19 a whole unit rather than disassembled. End-of-life transport might involve 20 moving an entire micro-reactor for disposal, requiring an approach similar to the 21 examples for Crystal River or West Valley. Next slide.
22 In closing, while our regulatory framework is well established, 23 we can always improve. Collaboration with developers, international 24 stakeholders, and other federal agencies allow us to share research insights 25
76 and prepare for the future. We're also focusing on knowledge management 1
programs to ensure our reviewers can continue to meet our important mission.
2 Thank you for your time, and I'll turn now the presentation over to Dan 3
Barnhurst.
4 MR. BARNHURST: Thank you, and good morning, Chairman 5
and Commissioners. Today, I'll present the steps the staff have taken to 6
develop a micro-reactor-specific environmental review approach to support 7
efficient, timely, and predictable licensing of micro-reactors. I'll provide an 8
overview of considerations that inform these efforts, outline the environmental 9
review alternatives developed by the staff, and present the staff's next steps for 10 development and implementation.
11 The staff developed a flexible approach that allows applicants 12 to select one of four review alternatives that best aligns with the design, 13 deployment model, and degree of anticipated impacts of the proposed project.
14 Staff began by assessing how previously identified and implemented efficiency 15 gains developed through a comprehensive evaluation of the entire 16 environmental review program could support efficient micro-reactor 17 environmental reviews. These gains stem from actions taken before and in 18 response to the Fiscal Responsibility Act and the ADVANCE Act, many of which 19 are still ongoing.
20 They include maximizing incorporation by reference and 21 tiering prior environmental studies, integrating requirements from recent acts 22 related to timeliness, page limits, optimized consultation, and enhanced 23 coordination with other agencies, expanding the use of environmental 24 assessments where actions where a finding of no significant impact can be 25
77 reached, and leveraging the new reactor generic environmental impact 1
statement or NRCEIS which if finalized could yield resource savings from 2
micro-reactor reviews when combined with other process improvements. Staff 3
then tailored the environmental review approach to reflect the reduced scale 4
and environmental footprint of micro-reactors and consider factors such as 5
variability and design types, reactor size, deployment models, and siting 6
characteristics, all of which ultimately influence the extent of the environmental 7
impacts in review.
8 The figures on the slide illustrate some of those variables.
9 Current designs range in size with deployment models including factory 10 manufactured transportable systems and stationary modular designs. Siting 11 approaches also vary from single reactors with minimal footprint and 12 disturbance that may be used to replace a diesel generator to multiple units at a 13 single site that may be used to support a grid.
14 This variability introduces a range of factors to be considered 15 during the NEPA review. Staff is continuing to develop planning resource 16 models for micro-reactors that incorporate efficiencies and account for this 17 variability. This effort will guide more efficient resourcing and management of 18 micro-reactor reviews and will be refined over time.
19 While we expect cost and time savings for each of the 20 approaches, use of environmental assessments and categorical exclusions if 21 applicable and approved would provide the highest efficiencies. Staff are 22 developing an online portal to streamline the process and enhance 23 communication. Next slide.
24 On the left is the first environmental review alternative which 25
78 continues the use of the current streamline process scaled for micro-reactor-1 specific reviews. Alternative 1 may appeal to applicants submitting an 2
application for a single unit at a complex site or multiple units at a proposed 3
site. This approach involves no additional development or implementation cost, 4
and resource needs are expected to decline annually as current and future 5
efficiencies take effect. Reviews may tier from the new reactor GEIS if 6
approved and could result in either an environmental impact statement or an 7
environmental assessment if a finding of no significant impact or FONSI is 8
reached and an exemption granted. This process is available now.
9 Under Alternative 2 on the right, the staff would develop a 10 design-specific generic environmental impact statement for each new standard 11 micro-reactor design at the applicant's request. This approach may suit 12 applicants planning to deploy a standard design at multiple successive sites.
13 For example, an applicant might use the same design to power data centers, 14 remote communities, work sites, military bases, or similar locations.
15 The initial review would include a design-specific GEIS 16 analyzing general environmental topics and resource impacts along with a 17 supplement addressing site-specific issues and demonstrating compliance with 18 the plant and site criteria. Subsequent applications would be significantly 19 streamlined requiring only a supplemental environmental impact statement or 20 environmental assessment tiered from the initial review and focused on issues 21 not previously addressed. Staff are ready to implement this approach upon 22 receiving a design-specific application. Next slide.
23 Alternative 3 presented on the left allows an applicant to 24 demonstrate minimal environmental impacts by meeting a bounding set of plant 25
79 and site criteria, developed specifically to envelope micro-reactor designs. This 1
is potentially the most flexible approach, enabling the streamlined review of any 2
micro-reactor and site combination that falls within those bounding values. It 3
may be especially attractive to applicants planning deployment across many 4
sites for the purposes listed earlier but who have not selected a design or 5
considering multiple designs or are working with a design that is not yet fully 6
mature.
7 This approach supports banking of sites and is modeled after 8
the general permit process used by other regulatory agencies such as the U.S.
9 Army Corps of Engineers. At both the initial and nth-of-a-kind stages, 10 applicants would submit information through an online portal to demonstrate 11 compliance with the bounding values. Staff will use this information along with 12 a template to develop a streamlined NEPA document which may be an 13 environmental assessment if bounding criteria are met. Reviews of subsequent 14 submittals would be further streamlined by tiering from the initial NEPA review.
15 Finally, Alternative 4 presented on the right would allow for 16 the use of categorical exclusions. This option would be viable once review 17 experience demonstrates that certain categories or combinations of designs 18 and deployment models constructed and operated on specific types of sites 19 results in no significant environmental impact.
20 From this experience, bounding plant and site criteria would 21 be developed. A categorical exclusion would be available to any applicant 22 whose project meets these criteria, offering the fastest and least resource 23 intensive review option. However, implementation would require rulemaking 24 under NRC regulations.
25
80 It's important to note that while Alternatives 2 through 4 1
involve initial development costs, these are expected to be quickly offset as 2
additional applications are received. Next slide.
3 Staff have already begun developing and implementing new 4
review alternatives and will prioritize and resource these efforts. In the near 5
term, staff will continue NEPA streamlining efforts and utilize the NRCEIS once 6
finalized, complete development of the online micro-reactor portal, collaborate 7
stakeholders to develop bounding sets of values for use with Alternatives 3 and 8
4, and develop templates and environmental screening worksheets to support 9
the streamline process.
10 When an initial design-specific application is submitted, staff 11 will refine the template and tailor the portal for submission of design-specific 12 information. Staff will further assess use of categorical exclusions and develop 13 the necessary infrastructure and, when feasible, initiate rulemaking to support 14 this approach. In closing, staff have consistently completed environmental 15 reviews within established project time frames and more recently have done so 16 on or ahead of deadlines set by the Fiscal Responsibility Act.
17 We expect this strong performance to continue. First-of-a-18 kind reviews will meet or beat NEPA time frames, 12 months for an 19 environmental assessments, 24 months for an environmental impact statement.
20 As relevant criteria and assumptions are developed and then met, nth-of-a-kind 21 reviews could be completed in as little as 180 days, benefitting from the 22 efficiencies built into each alternative.
23 The NRC's optimized environmental review approach for 24 micro-reactors will result in environmental reviews that are efficient, timely, and 25
81 predictable and enable the scalable and streamlined deployment of micro-1 reactors across a wide range of uses and sites. With that, I'll turn the time to 2
our next speaker, Jessie. Thank you.
3 MR. QUICHOCHO: Thank you, Dan. Good morning, 4
Chairman and Commissioners. I welcome this opportunity to describe to you 5
what the NRC staff is doing in emergency preparedness.
6 The staff has been working on emergency planning for new 7
reactors for some time now, and I look forward to describing specific actions we 8
have taken and will take for micro-reactor licensing. Next slide, please.
9 As Jeremy have pointed out earlier, the emergency 10 preparedness staff is ready to conduct reviews of micro-reactor applications 11 under current regulations. With Commission approval of the new rule for small 12 modular reactors, non-light water reactors, and other technologies, our 13 regulatory framework provides a flexible graded approach for applicants to 14 develop emergency plans commensurate to their facility risk and hazards.
15 The staff looked ahead during the development of the rule 16 and took into consideration the characteristics of new design, including those of 17 micro-reactors. The new framework establishes a performance-based 18 approach which goes beyond a review of written plans and focuses on 19 demonstration of responsive capabilities to performance necessary functions.
20 The rule is also technology inclusive and scalable in recognition of the low 21 radiological risk these micro-reactors inherently have based on smaller source 22 terms and advanced safety features.
23 Applicants may choose to comply with 50.47 and Appendix E 24 instead of 50.160 and seek exemption from certain requirements based on 25
82 differences in design characteristics and low radiological risk. If potential 1
applicants indicate that they intend to take this approach, the staff would 2
evaluate whether there is a need to develop guidance to allow for more efficient 3
exemption request reviews. Such guidance could be analogous to the use for 4
emergency planning exemption request for decommissioning nuclear power 5
plants which was issued to collect the staff experiential review and exemption 6
request for emergency preparedness for decommissioning plants and thereby 7
enhance the efficiency and consistency of future reviews. Next slide, please.
8 I'd like to discuss the activities the staff has been working on 9
that supports licensing of micro-reactor technologies. First, I want to point out 10 that the staff issued regulatory guidance in 2023 that describes the acceptable 11 methods for how applicants can meet the 50.160 rule. And staff are now 12 working to update this guidance to add clarity in support of licensing of micro-13 reactors in particular.
14 Additionally, the staff is currently developing interim guidance 15 for conducting technical reviews for new applications which will ultimately be 16 added to the standard review plan. A public meeting is expected in the near 17 term to facilitate external stakeholder feedback as far as developing this 18 guidance. The staff is also working on new inspection procedures to support 19 the 50.160 rule which will be scaled to the radiological risk of the facility and 20 focus on performance-based results.
21 In addition to these near-term guidance updates, the staff 22 continues to take a holistic look at readiness for micro-reactor licensing within 23 emergency preparedness to identify potential streamlining opportunities. For 24 example, staff is pursuing templates that applicants can use to standardize 25
83 emergency preparedness plans. Our staff is also working with the Office of 1
Nuclear Regulatory Research in the performance of analyses to support 2
simplified emergency planning zone determinations and use of existing 3
emergency plan organizations and planning for micro-reactors.
4 Finally, NRC continues to engage our partners at FEMA to 5
develop federal guidance for offsite preparedness that is right sized the 6
emergency hazards. Next slide, please.
7 Now I want to take a moment here to describe what we mean 8
by standardizing emergency planning. The staff has evaluated past technical 9
reviews and identified key functional areas in emergency preparedness that are 10 common across multiple sites.
11 Examples of common functions that could be standardized 12 include emergency response organization staffing, emergency action levels, 13 and emergency response facilities. Standardized functions that are the same 14 from site to site would facilitate nth-of-a-kind licensing that Duke described 15 earlier. In addition, based on previous licensing experience and industry 16 engagement, the NRC staff believes that the use of bounding assumptions for 17 information such meteorological data or seismic parameters can provide 18 predictability of licensing emergency preparedness at various sites.
19 Another commonly used regulatory tool is a topical report 20 process where applicants can submit for NRC review and approval the 21 methodologies that may be applied across similar reactor designs. We have 22 seen success in approving emergency preparedness topicals to support 23 efficient licensing and will continue to encourage these approaches. To 24 summarize, the staff are considering many options to support deployment of 25
84 approved technologies. Next slide, please.
1 Similar to what Jeremy mentioned earlier, stakeholder 2
interactions are key to identifying enhancements or clarity needed in the 3
regulatory processes for micro-reactors. This is an important component to 4
ensure emergency preparedness is effective and contributes to a safe and 5
secure use of civilian nuclear energy with micro-reactors. The staff has met 6
with applicants to discuss the regulatory framework and processes for 7
conducting emergency preparedness reviews.
8 These meetings are of great value because they provide 9
applicants with necessary technical information needed to address and meet 10 emergency preparedness regulations. These engagements also build public 11 trust in our regulator processes. The NRC and FEMA have worked together for 12 decades to maintain reasonable assurance in emergency preparedness 13 planning for the operating fleet.
14 For micro-reactors, the NRC and FEMA stand ready to work 15 together in effective planning for future facilities and its surrounding 16 communities. The NRC staff is committed to hearing from stakeholders and to 17 discuss any proposal to facilitate micro-reactor emergency preparedness.
18 Thank you for your time, and I'd like to turn over the presentation to our 19 executive director for operations.
20 MS. GAVRILAS: This concludes the staff's remarks. We're 21 ready for your questions.
22 CHAIRMAN WRIGHT: Thank you, Mirela. And panel, thank 23 you for your presentations. And for those people, thank them as well that backs 24 you up to get you ready. And with that, we will start questions, and we'll begin 25
85 with Commissioner Crowell.
1 COMMISSIONER CROWELL: Thank you, Mr. Chairman.
2 Thank you to all the presenters. I think it was very complementary to the first 3
panel, and I think we're all getting a better appreciation for the big picture here 4
in some of the stickier issues that need to be resolved and timelines associated 5
with that.
6 Mirela, I'm going to start with you. And first, I'll say I enjoyed 7
my recent visit to the test reactor at the University of Maryland mostly because I 8
got to see a photo of you in your sophomore year operating that reactor. And I 9
know it's true, your story.
10 But given your long experience in this area and your current 11 position, I'm going to ask you kind of a big picture question here. As we look at 12 micro-reactors and the whole life cycle from front end manufacturing, 13 transportation, operation, the back end of fuel management and transportation 14 decommissioning, in your view, where do you have the most concern for 15 protection of public health and safety? What is the most acute public health 16 and safety element of micro-reactors that we should be focused on?
17 MS. GAVRILAS: Tough question, but I'm going to be -- I think 18 we need to pay attention to security. They're small. They're going to be every 19 place. And while the consequences are modest, we still need to pay attention 20 to security aspects.
21 COMMISSIONER CROWELL: I appreciate that, and I did not 22 know what your answer is going to be. But it leads nicely into the question I 23 was going to ask Jessie next on security. For emergency planning zones, how 24 are you looking differently at a micro-reactor located in a very rural setting like 25
86 out in an oil field versus in a more urban setting? And what does that distinction 1
mean for EPZ requirements?
2 MR. QUICHOCHO: So for micro-reactors, we expect that the 3
majority of the EPZ would be at the site boundary. And with that, no necessary 4
impact to the external community, the local communities. And we will continue 5
to work with FEMA on communicating the applications of micro-reactors. The --
6 COMMISSIONER CROWELL: So you see no distinction from 7
a security or safety perspective between a 49 megawatt reactor in a dense 8
urban area, Manhattan, versus out in the Permian Basin? I mean, why is there 9
no difference there? Seems like it's an obvious thing that there'd be a different 10 parameter or at least a different response plan.
11 MR. QUICHOCHO: Yeah, so these micro-reactors, as 12 mentioned earlier, reduce radiological risk. They're smaller in megawatt and 13 power level. I worked at the University of Missouri research reactor. It's a 10-14 megawatt reactor, probably a little size higher than what was mentioned earlier 15 with the eVinci. And the response from the community and the local areas are 16 just like a normal hazard. So that's the -- it's not necessarily based on the local 17 population, whether it's urban or rural but more on the radiological risk that are 18 associated with these facilities.
19 COMMISSIONER CROWELL: I think for the average person, 20 it's hard to get their head around that idea that there is no distinction. So I would 21 just in our public engagement really encourage you to articulate why that is an 22 applicable safety -- why that parameter is applicable in both scenarios and that 23 we're thinking about it holistically. Duke, I'm going to turn to you next here.
24 In the slides, you say that, quote, the NRC staff anticipates 25
87 that the first few deployments of a standard design will take longer but still much 1
less than recent first-of-a-kind reviews. Can you tell me a little bit more about 2
what you mean by first few deployments? Is that, like, Reactors 2 and 3 of a 3
standard design? Or is it the first model? What are you getting at there?
4 MR. KENNEDY: Yeah, thanks for the question. So this is a 5
topic that we discussed a lot amongst the staff is when do you actually get to 6
nth-of-a-kind in the deployment cycle. And I think it's going to depend on a few 7
things first, the method for the review and approval of the standard design, 8
whether it's through a manufacturing license or a design certification or the first-9 of-a-kind application review. And then how do the actual developers or the 10 licensees that are deploying the reactor take any departures from that?
11 And what we've seen in the past is that the first-of-a-kind 12 takes some departures from the standard design. So I think looking at the 13 historical context, there's a chance that if there's some departures, those would 14 have to be reviewed again because they would be different than the standard 15 design that was reviewed. And then those departures could be incorporated 16 the standard design through the normal change control processes for 17 manufacturing licenses or design certifications.
18 Or additional applicants for operating licenses or combined 19 licenses could choose the same -- take the same departures. And we would 20 have a precedent for the review of those. So I think there's just a little 21 uncertainty about how quickly -- how many reactors exactly, I can't say. But 22 we're just anticipating that there's the possibility that it could take a few reactors 23 before we really reach steady state.
24 COMMISSIONER CROWELL: But the moral of the story is 25
88 that the more standardized you can be, the less of a time frame -- a shorter time 1
frame you're going to have. And so resist the temptation on Reactors 5 and 2
beyond to keep tinkering with things that will undermine the efficiencies of 3
having a standard design. Is that fair to say? Okay.
4 Cinthya, I want to come to you with my last question. I'm 5
going to read it because it's a little bit challenging and you may want to phone a 6
friend. So I'm obviously concerned about the full life cycle here of micro-7 reactors as I am about all of our reactor technologies.
8 And there's many people working on how to safely build, test, 9
and deploy a very large number of micro-reactors. But it may not be clear yet 10 what we'll do with the hundreds or even more than that of used up micro-11 reactors. So for example, if a vendor offers refueling services at a factory, then 12 micro-reactors containing spent fuel will be transported back to the factory.
13 There was a paper delivered to the Commission in August of 14 last year that was explaining a recent risk assessment by the Pacific Northwest 15 National Lab supporting the idea that the NRC could grant the necessary 16 exemptions from the current NRC transportation requirements in such a 17 scenario. But it's notable that they limited this endorsement to just one 18 transport per year, one away from and then one back to a specified location.
19 So you or anyone else on this panel, would you be willing to speculate on the 20 risk associated with transporting more than one? And should a large number of 21 reactors eventually to be deployed, would micro-reactors would have to remain 22 in place for extended periods of time to reduce overall transportation risk to an 23 acceptable level? So could you comment on that?
24 MS. ROMAN: So I'm pretty sure that all the risk experts in the 25
89 back are not going to want me to speculate. But what I can say is that, yes, for 1
Project Pele, we did consider one-time shipment. We think that methodology 2
could be adapted for used for multiple shipments. But additional information 3
would be needed.
4 Definitely, it's not the same to look at the risk of one shipment 5
versus having 20 reactors transported five times a year. We would have to look 6
at the cumulative impact of transporting the material during that time. So we 7
will also have to look at the dose.
8 We would have to look at if the transportable micro-reactor is 9
passing the same area multiple times. What would be the dose? So yes, there 10 is additional analysis that can be used and we could expand that methodology 11 for Project Pele. But I cannot say that we have looked at that level of detail, 12 like, why would we if we have multiple shipments.
13 COMMISSIONER CROWELL: So I know you mentioned a 14 little bit. But what additional kind of data would you need to make those 15 assessments? Is it just dose and routes, or is it performance under accident 16 scenarios? I mean, what kind of stuff do you need to give some assurance of 17 having more frequent transportation, particularly of irradiated fuel back to the 18 factory?
19 MS. ROMAN: I think it would be expanding our risk 20 assessment, kind of PRA information in terms of what type of information. We 21 would have to look at honestly dose and look at the --
22 COMMISSIONER CROWELL: Is NRC doing any of this 23 research themselves and should we be doing any of it if we're not?
24 MS. ROMAN: Can consider it.
25
90 COMMISSIONER CROWELL: Seems valuable. Thank you.
1 I appreciate it. Thank you, Mr. Chairman.
2 CHAIRMAN WRIGHT: Thank you, Commissioner Crowell.
3 Commissioner Marzano.
4 COMMISSIONER MARZANO: Thank you, Mr. Chairman.
5 And staff, thank you for your presentations today. Your discussions kind of 6
demonstrate how the NRC is adapting to the changes in technology and its 7
development in fabrication, testing, transportation, operation in real time.
8 So as the industry looks beyond the tradition fixed site 9
construction of large reactors and identifies opportunities to factory fabricate, 10 load fuel, and to perform operational testing at manufacturing facilities as an 11 imperative for the NRC to ensure that its regulatory framework is responsive to 12 this evolution. I commend the staff and appreciate your efforts to explore these 13 specific flexibilities that we're considering here, among many others to facilitate 14 novel licensing approaches demanded by these micro-reactor deployment 15 models. That said, in my view, I think this mindset exemplifies the model 16 through which we will achieve the shift in our culture toward accomplishing our 17 updated mission statement.
18 I encourage the staff to continue to embrace being more 19 proactive and agile to make us a more proactive and agile regulator in all of our 20 work to be responsive to the needs of the 21st century and embody the spirit of 21 the ADVANCE Act. Along those lines, let me turn a little bit to the ADVANCE 22 Act and some of the mechanics that are going on here. Jeremy, as you 23 mentioned, Section 208 of the ADVANCE Act specified several issue areas for 24 the NRC to address.
25
91 I'm glad that the NRC staff has incorporated and prioritized 1
these activities into its integrated plan for micro-reactors. So I want to ask a 2
couple of questions along these lines here. First, just kind of briefly and feel 3
free to weigh in and other folks here. Has that direction of the ADVANCE Act 4
changed staff priorities or focus areas for continued micro-reactor regulatory 5
framework development? And if so, do you see any resource challenges as a 6
result?
7 MR. BOWEN: So thank you for the question. I think the short 8
answer to your question is it's helped us focus to make sure that we've captured 9
the suite of activities that are necessary, helped us engage with stakeholders to 10 prioritize to make sure that we're capturing everything and kind of reinforced 11 that this is an urgent issue that we need to address now.
12 COMMISSIONER MARZANO: Okay. And then maybe kind 13 of turn to -- we'll go back and forth with some of the language in Section 208 14 specifically. But I understand this integrated plan that's being developed, and 15 this is kind of discussed a little bit at the external panel just before. And we 16 have this wealth of issue areas that we need to address.
17 Addressing them individually over a longer period of time is in 18 my view not really supportive of what the need is today. And so you look at 19 what we're doing right now, the integrated plan, these issue areas. We have 20 the elephant, and now we have to discuss how to eat it and the particulars of 21 that.
22 I won't extend this analogy any further. But can you speak a 23 little bit to the staff's plan to kind of hit those important topics to give this sense 24 to the developers and that folks are going to be deploying this technology?
25
92 What can we look to today that's going to inform how we move forward, 1
especially with some of the -- instead of serializing a lot of this work, how can 2
we take the most advantage of what's being done to kind of show where our 3
thinking is and we want to proceed?
4 MR. BOWEN: Thank you for the question, Commissioner 5
Marzano. That's exactly what we're trying to do. I think hopefully you took that 6
away from the panel this morning is we've got approached by stakeholders with 7
specific questions, specific concerns, specific need for certainty in the 8
regulatory process.
9 So our desire was to provide that certainty now so that they 10 can move forward with their business models, so that they can continue to 11 advance the technology, and that the regulatory is not the impediment. All of 12 these individual questions and issues that are coming up as you rightly point out 13 and I think as some of your colleagues have mentioned as well in their 14 questions to the other panel. It necessitates a paradigm shift.
15 It necessitates a what do we do next. We can address these 16 individual issues. We can provide some certainty and help them move forward.
17 But that doesn't mean we should stop there. And so I think we all recognize 18 from a safety standpoint, from a security standpoint, emergency planning, 19 everything you're hearing from this panel is this is a different technology. We 20 can address the individual questions, but then we have to think more broadly 21 about, okay, what's the next step? And we're trying to do those two things in 22 parallel to make sure that we're given that certainty but also trying to enable a 23 future that's a little bit easier.
24 COMMISSIONER MARZANO: Duke, do you want to 25
93 comment on that at all?
1 MR. KENNEDY: I'll just add that we're looking to provide 2
solutions now and also recognizing that as developers' deployment models 3
change, as new technologies come up, there will be more work to do in the 4
future to get to that optimal state. And so that's why we're trying to engage with 5
stakeholders as often as we do and provide as much -- lean as forward as we 6
can as to what it is we think that we can accomplish so that we have that 7
dialogue immediately. And we keep it ongoing to make sure that we're focusing 8
in the right places.
9 COMMISSIONER MARZANO: That's great. Thank you. And 10 so that's a good segue to my next line of questioning here. So Part 53 11 proposed rulemaking closed -- their comment period closed the end of 12 February. Can you comment on whether or not we have received any 13 comments specific to the micro-reactor regulation? And if so, do any of these 14 comments impact kind of the near-term approaches or recommendations to the 15 Commission on how to best license these facilities?
16 MR. BOWEN: So yes, we did receive some comments 17 related to micro-reactors. There were some specific questions that were 18 provided in the Federal Register specifically around micro-reactors. The short 19 answer to your question is, no, the staff is working to make sure that there is no 20 delay in licensing, providing Part 53, and making that a viable licensing path.
21 We're trying to do as much as we can to enable the language 22 that will be in Part 53 and to develop complementary guidance to support micro-23 reactors just as the previous question that we talked about, providing that 24 pathway now. But also recognizing there might be something in the future that 25
94 could make it the next iteration a little bit more clean, a little bit simpler, the 1
process a little bit more easy to navigate. But the short answer to your 2
question, no, we have no plans whatsoever to delay Part 53.
3 COMMISSIONER MARZANO: Okay. Well, that's where I 4
was going with at next. So thank you. Cinthya, I want to turn to transportation 5
topics. And I just want to set the scene here a little bit.
6 Last week, I had a chance to visit Sandia National 7
Laboratories. Those researchers out there have access to world class test 8
facilities to characterize these transport packages and the capability to perform 9
substantial research related to all of this, transportation issues surrounding fuel 10 irradiated micro-reactors, including the drop scenarios, severe accidents, et 11 cetera, that are going to inform our safety decision on those. So can you talk a 12 little bit about how we are coordinating with the Department of Energy utilizing 13 National Lab resources on some of these things that may otherwise require kind 14 of a special exemption or whatever the term? I might be getting it wrong here, 15 so yeah.
16 MS. ROMAN: Yes, so we spend a lot of time coordinating 17 with DOE. We have periodic meetings with them. We have technical 18 exchanges to try to understand the work that they are doing, especially working 19 with the National Labs. We also work with the Office of Research. They spend 20 a lot of time working with the National Labs, making sure that the research that 21 they are doing help us to get the information that we need.
22 I know that recently, DOE has been working on the 23 performance package demonstration. Maybe I changed the name. But I know 24 that that's going to be looking at potential accidents or kind of the regulations 25
95 that we have for spent fuel and transportation and seeing -- they have reached 1
out to see how that project could provide beneficial guidance for NRC like 2
validating codes and things like that. So we do leverage the relationship that 3
we have with DOE and the National Labs.
4 COMMISSIONER MARZANO: Excellent. It's quite 5
impressive, the facilities out there. I'll say that. Jessie, I want to turn to you last 6
here. I kind of want to just make a general statement and acknowledge the 7
difference between looking a large light water reactor kind of regulatory 8
envelope, especially with NRC planning, and then kind of scaling down from 9
there versus the kind of mindset of going from non-power reactor regulation and 10 scaling up to the needs of the system.
11 So I just want to kind of keep that as a focus of how to 12 potentially move forward as these things are evaluated. But my question for 13 you is, why 50 megawatts? When we're thinking about consequence, source 14 term, et cetera, all these kind of risk calculations, in general, I get the 15 understanding that we're moving away from just determining, well, this power 16 level means this, right? So maybe a little bit of back story on that value itself or 17 kind of the concept in how you're thinking about it.
18 MR. QUICHOCHO: I appreciate the question. It's a starting 19 point, right? Fifty megawatts is a starting point. And as we conduct the 20 research on the 50-megawatt thermal power level, we'll adjust. Keep in mind 21 that for, like, NPUF regulations and the EPA regulations, they both use the 22 same threshold of 1 rem.
23 The difference is that for NPUF, it's less than 1 rem. And for 24 the EPA regulations, it's greater than 1 rem to consider as part of the spectrum 25
96 of accidents. So this is kind of why we're looking at some research on seeing 1
how we can do what you've heard with expert panelists and today here is 2
bounding conditions so that we can provide additional flexibility to applicants 3
and vendors.
4 COMMISSIONER MARZANO: Thank you very much for that, 5
Jessie. And again, I could probably go on and on and on, on this. But I will 6
give it time back -- well, time I've already taken. Thank you, Mr. Chairman.
7 CHAIRMAN WRIGHT: Thank you, Commissioner Marzano.
8 It's been a good day. This is a great meeting. So Mirela, I've got a couple of 9
questions and maybe Jeremy might chime in too if you want to. We heard in 10 the first panel from Mr. Schoedel and from Mr. Jessup in a way near the end of 11 that panel when Commissioner Caputo was talking to them. Did you hear 12 anything in the first panel that was new information for you or something you 13 and staff were not aware of?
14 MS. GAVRILAS: From my perspective, I have not. I wouldn't 15 be surprised if Jeremy has, however. But that's an indication not of necessarily 16 that information develops quickly. But the fact that we have the connections 17 within the community to actually get the information pretty much live as people 18 think of it. Jeremy.
19 MR. BOWEN: Thanks, Mirela. No, no, sir. We didn't hear 20 anything new to Mirela's point. This has been a good dialogue. It's been a 21 quick dialogue with our stakeholders, but it's been a very good dialogue. And 22 it's helping -- I think it's helping with the paradigm shift that you talked about.
23 So every time we have another topic, another conversation, it's, okay, how can 24 we move this whole project and community and thinking forward?
25
97 CHAIRMAN WRIGHT: I'm going to stay with you and 1
primarily for the next few minutes here. What is our strategy going forward to 2
handle what appears like it's going to be many more applications coming in? I 3
know there's several policy and technical issues, either in front of the 4
Commission or on their way as well. So I mean, how can we assure ourselves 5
that our proposed solution for one issue doesn't conflict or interfere with 6
something else?
7 MS. GAVRILAS: Let me take it first. The question that I ask 8
because there are so many issues, technical and policy issues that we have to 9
consider. My first question is, let me know if the interface between these issues 10 becomes strong at one point.
11 Right now, we look at the issues and they're pretty much 12 standing on their own. In other words, they're very loose if any ties to any 13 adjacent issues, which means they can be handled individually. So we're all 14 paying attention when that's not going to be the case so that we can raise the 15 flag. Jeremy.
16 MR. BOWEN: Yeah, and I could go on. This is a topic I could 17 go on for days. So I'll try and keep it brief. But I think it's a combination of what 18 Mirela said about making sure we're looking at topics. Are they standalone or 19 how can we leverage it?
20 It's also looking at process and technical decisions and 21 learning from all of those. And how can we leverage that to make the next one 22 better, make the next one quicker, make the next one more efficient, making 23 sure we have the right staff in the right place at the right time? How do we fulfill 24 the principles of good regulations in the best way that we possibly can?
25
98 We're looking at staffing for our core teams for all the 1
activities that are coming in place. We're looking at budget models, and we're 2
constantly refining all those things and then trying to figure out, is there a new 3
and different and better way of doing everything that we're doing? So I think as 4
long as we're asking those questions, as long as we're willing to challenge 5
ourselves, we're moving in the right direction.
6 I don't know if we'll ever be perfect. But that's, I think, kind of 7
a weird answer to your question. But I think our desire to always be evolving is 8
what's making sure that we're going to be ready.
9 CHAIRMAN WRIGHT: Right. I'm going to stay with you for a 10 second, Jeremy. Earlier, I brought up the updated mission statement, how that 11
-- what we're looking to try to do. And I know that your team especially has 12 been out front and working to live up to that. You're an example -- a really good 13 example of what can happen inside this agency that can be hopefully -- it's 14 transferrable to other business lines to do it and approach it the same way. And 15 what would you tell people who are saying or who claim that were unwilling or 16 unable to license micro-reactors or other advanced reactors in a timely and 17 efficient manner?
18 MR. BOWEN: Thank you for the question, sir. It's something 19 I think about a lot. I know you're a fan of sports analogies. So I'll say when the 20 game is on the line, we want the ball.
21 I can understand where those comments come from. I 22 acknowledge that the NRC has not always adhered to the principles of good 23 regulation. We have certainly had missteps in our past.
24 We still have missteps today. But that doesn't mean that 25
99 we're the same agency today as we were 20 years ago. We've not even the 1
same agency as we were five years ago.
2 And we have demonstrated our willingness, our ability to think 3
differently, to change, to move forward. They're not aberrations. They're not 4
anomalies.
5 We have multiple examples of success. I think we are 6
continuing to demonstrate that. And like I said, we have new and different ways 7
of thinking about things.
8 We have examples right now where not just in micro-reactors.
9 We're thinking about recognizing that some regulations are not suited for the 10 designs that we're looking at right now. And the staff is initiating how can we 11 interpret these regulations for these types of designs.
12 How can we either take exemptions or move on? And what 13 can we do in the future? So again, I'll come back to what I said. Give us a 14 chance. Come talk to us.
15 Find out how we can -- tell us your challenges. Present the 16 information that you see as a way to move forward and let us work with you.
17 We have an independent safety mission to accomplish, but there's a lot of ways 18 to achieve safety. And so give us a chance.
19 CHAIRMAN WRIGHT: Thank you for that answer. You like 20 everybody else, you've got a lot on your plate, right? And all of it's important, 21 every bit of it.
22 And there are a lot of -- there's a number of micro-reactor 23 policy issues that you're working on in parallel too. And I recognize that. What 24 I'd like to maybe have you tell me a little bit about and my colleagues here, how 25
100 are you organizing your work so that staff activities are coordinated across the 1
large number of micro-reactor topics you have before you and making sure that 2
the Commission is properly engaged?
3 MR. BOWEN: Yes, thank you, Chairman. So the Micro-4 reactor Activities Plan, we came up with a name, but it's so hard to say. I think 5
that was a key for us in trying to make sure that we had a good understanding 6
and a good connection between all the different organizations.
7 As you said, this is touching so many things. And to make 8
sure that we have those relationships and those connections and that ability to 9
track and make sure we're making progress on all those activities. So that was 10 a good step.
11 And we already thought we kind of had a sense of what were 12 policy issues, what were stuff that the staff could take on. We're trying to -- that 13 plan also gave us an opportunity to reflect and make sure, are we identifying all 14 the policy issues? Is the picture clear for everybody?
15 I think Duke in his presentation tried to lay out, like, these are 16 the policy issues that we think are before you. Here's the ones that we know of 17 today that are remaining. So that's our intent with that plan.
18 As I mentioned, it's intended to be a living document. We're 19 already engaging with stakeholders. We just put it up yesterday in a kind of 20 searchable format on our website. We're intending to iterate and make that 21 even a more productive dashboard tool available for everybody to understand.
22 Make sure that you can connect the dots in layman's terms.
23 CHAIRMAN WRIGHT: Thank you so much. I wish you the 24 best of luck as you go forward too. Anything we can do to support. Cinthya, 25
101 how are you? And I appreciated your discussion with Commissioner Crowell 1
just a few minutes ago on the transportation part of things.
2 And recognizing that, I believe micro-reactors are different as 3
Commissioner Caputo pointed out in the first panel. How do NRC requirements 4
apply to situations that involve different modes of transportation, I mean, for 5
example, road to rail, air, maybe even by sea? And I guess really to drill a little 6
bit, how is the transportation in the micro-reactor space? How is that different 7
than what we do today, or is it?
8 MS. ROMAN: Thank you for the question. It's no different 9
from what do today. So the regulations in Part 71 apply to all the different 10 transportation modes.
11 So for us, it's in the plan. And we really focus on the 12 transportation cask. So on the other hand, DOT regulations, those are the ones 13 they regulate the carriers.
14 So our regulations point to the DOT regulations. And that's 15 how the micro-reactors would decide what method of transportation to use. But 16 our regulations are independent of the transportation mode.
17 CHAIRMAN WRIGHT: Thank you. I've run out of time, and 18 I'm going to turn it over to Commissioner Caputo.
19 COMMISSIONER CAPUTO: Good morning. Thank you all 20 for being here. Thanks for your preparations for today. Clearly, you heard my 21 comments this morning about there are a lot of issues here and a lot of good 22 progress is being made, a lot of hard work by the staff.
23 But I'm concerned about just the need for a strategic 24 approach as to how we're going to navigate that. So I guess my first question 25
102 would be given everything that you've discussed and given what's underway, 1
what does it take to hit six-month deployment of micro-reactors? What does it 2
take to actually get to the point where NEI is discussing in their RHDRA paper 3
and et cetera? What does it take for us to get to that six-month?
4 MS. GAVRILAS: So I think your question is two-fold and we'll 5
have two answers, one is how can we expedite what the NRC has to do today.
6 And you heard a lot about that. But I just wanted to lean forward a little bit and 7
say that the conversation that we've had about micro-reactors and given the 8
very unique risk profile of micro-reactor have made us think and the directions 9
from the ADVANCE Act have really made us think, is it time for us to look at a 10 cohesive regulation that would deal specifically with the risk profile that's 11 presented by micro-reactors? I think we've tried to, the graded approach, risk-12 informed because we wanted to be technology neutral. But micro-reactors 13 because they have such limited needs, perhaps make us ask the question, 14 what do we need to assure ourselves of the safe and secure operation of these 15 facilities?
16 And it's an opportunity to think, how can we cater to their 17 needs which are fixed versus mobile, manufactured versus built on site, the 18 number of licenses that they need, and all the questions and issues that came 19 up this morning. Because what we do now is we ask ourselves do they need 20 this. And could we move from do they need this and an exercise in proving a 21 negative to what do they actually need in order for us to become comfortable 22 with their license?
23 So that's becoming front and center in our thinking. And it will 24 build on everything that you heard us talk about today, all the issues that we're 25
103 walking through carefully. Jeremy.
1 MR. BOWEN: Thanks, Mirela. Commissioner, I loved your 2
analogy of the Tootsie Roll, Tootsie Pop. And I remember the commercial well.
3 And certainly we have to talk the bite. We have to take the advice of the owl 4
and just take the bite. And I think the work -- to Mirela's point, I think the work 5
that we're doing right now is going to provide that technical safety basis for us 6
to say taking the bite is okay and providing the stakeholder confidence to say 7
that's the right approach to get to the center of the Tootsie Roll.
8 COMMISSIONER CAPUTO: Okay. I guess I hear you. But 9
there are so many moving parts. And I think having workshops to address 10 particular issues or even groups of issues is one thing.
11 But I believe the staff should really have a workshop that 12 looks at everything that's underway and takes a strategic view about what does 13 it take to actually achieve a paradigm shift here and to get down to that six-14 month time frame given the nature of what's involved. So I would very much 15 encourage you to think about that. Yeah, I've mentioned in various 16 presentations just about batch licensing.
17 How do we -- given the framework that we have, given the 18 statutory language on utilization facilities, how do you get to a point where 19 someone has a license to operate a technology not to operate a particular 20 reactor and particular location? How do you get at that from a strategic 21 direction? How do you make that simpler?
22 Whether we can do that under our regulatory framework, 23 whether there might be a need for a legislative change to sort of streamline the 24 nature of how we go about that decision making. But in the end, what can we 25
104 do to bring our decision making into a time frame that's going to suit 1
deployment while still ensuring the maintenance of safety and security. I also 2
have a particular question, having to do with start of operations and the use of 3
loading of fuel as a proxy for when operations start.
4 That was how the staff went about it in the micro-reactors 5
paper that's pending before the Commission. So staff proposed that we adopt 6
something, sorry, other than loading fuel as the start of operations and features 7
to prevent criticality. Westinghouse is asking us for how we are going to treat 8
refurbishing and refueling of a micro-reactor under a Part 70 license. Under the 9
staff's approach, it kind of puts us in the position where we're going to have to 10 consider a micro-reactor that's been returned to a factory for refueling as not 11 having commenced operation which I'm kind of struggling with.
12 So I feel like we should be able to find a different way to 13 categorize this because it's going to make sense for the first one that leaves the 14 factory when it's got fresh fuel. But the nature of this construct gets pretty 15 difficult after that when it's -- after initial fuel load and the initial operating cycle.
16 So saying that it's commenced operations and then not and then it has I think 17 becomes a difficult approach for us. Are you looking at a different way to 18 categorize operation that is going to make low power testing easier in line with 19 what Westinghouse was talking about but also something that is going to be 20 flexible enough to handle the nature of refueling and refurbishment?
21 MR. BOWEN: I can start and you can jump in. Short answer, 22 yes, Commissioner. You're right. It's a challenge from -- and this is an issue I 23 think that maybe to go back to your previous question.
24 We find when we're able to -- first question we asked 25
105 ourselves is, what's safe? What's appropriate for safety? What's necessary for 1
safety? And then we find ourselves navigating a regulatory infrastructure of 2
statutory requirements and trying to figure out, okay, if it's safe, if we find it's 3
acceptable from a safety standpoint, how do we make that fit within our 4
structure and the statutory requirements?
5 For this scenario, I think the staff is looking at something 6
where the same deployment where you're introducing features to preclude 7
criticality, to enable physics testing and deployments of the site. Kind of 8
backing -- reversing that to bring it back to the factory, defueling and 9
refurbishing the unit. How that -- now is that another -- is it a new unit at that 10 point or are you testing it to send it back out?
11 Or is it necessary? We've engaged with other -- and 12 Westinghouse talked about their deployment models. There's been others that 13 have talked to us that they want a slightly different version of that model.
14 So trying to make sure they were providing the flexibility to the 15 various different models is another challenge that we're facing. But I think, yes, 16 we're trying to make sure that we're capturing all that and not introducing 17 unnecessary -- additional unnecessary burden or challenges. Duke, do you 18 want to add anything?
19 MR. KENNEDY: Yeah, I'll just add that when we had our 20 workshop in February on the integrated Micro-reactor Activities Plan, one of the 21 topics that came up was the post-operation aspects of micro-reactor 22 deployment models. And we had that prioritized as low. But through the 23 conversations in that workshop, we raised that up. And now we're looking at a 24 specific interaction in the next couple of months to go over those topics or go 25
106 over that topic because recently this has come up as a more important topic to 1
some of the developers.
2 And so while we didn't have perfect information when we 3
wrote the SECY-24-0008, we were trying to outline generalities for what might 4
be possible. I think now we're at the point where we're getting some more 5
specific details. And we can dig into these issues a little more and like you 6
suggest, try to develop strategies that really make sense for facilitating it.
7 COMMISSIONER CAPUTO: So is there a need for more 8
flexibility beyond the nature of what was proposed in the paper of the 9
Commission?
10 MR. KENNEDY: I don't think there's a need for more flexibility 11 beyond what was proposed in terms of the use of features to preclude criticality 12 to make the reactor not in operation. I think it's a matter of looking at what 13 licensing pathways that we have. And I think there's maybe some lessons to be 14 learned from reactors that have been taken out of operation and then decided 15 to put back into operation recently. And also looking at -- excuse me, looking at 16 ways that we can restructure the license that would be for particular sites to 17 facilitate reactors moving in and out of a site for a placement more easily, for 18 example.
19 COMMISSIONER CAPUTO: Okay. Thank you.
20 MR. KENNEDY: Thank you.
21 CHAIRMAN WRIGHT: Thank you, Commissioner Caputo.
22 Commissioner Hanson.
23 COMMISSIONER HANSON: Thank you, Mr. Chairman.
24 Thank you all for your presentations this morning. This is really a great 25
107 discussion. And I completely agree that it complements the first panel quite 1
well.
2 I want to just take a couple minutes at the beginning of my 3
remarks to associate myself with some things that the Chairman said during the 4
first panel as well as Commissioner Marzano during this panel about really kind 5
of the remarkable work that the staff have done, right? This has been a 6
methodical and ongoing effort now I think for a couple years. We got SECY 7 0008.
8 Last year, that represented kind of the way I think of the first 9
tier of effort, right? What are those decisions that can be made within our 10 existing authority where we have those flexibilities? We're seeing -- as an 11 enclosure to that paper, we saw the identification of some really -- I don't want 12 to call them thorny, but kind of tough issues around environmental review, 13 around siting, around operations and some other things, right?
14 Already teeing those up for kind of the next steps in that 15 paper. And while the staff have waited for that paper to resolve, you guys 16 haven't let any grass grow under your feet, right? And moving ahead with the 17 nth-of-a-kind white papers that were issued, I think, last fall, the interactions 18 with the staff, the really constructive engagement with NEI through their 19 comments last summer on this subject.
20 And while there are a lot of issues that kind of need to get 21 worked out, I think leaning in and showing how we can be proactive about this 22 and how we can be flexible about this to tackle those tough issues has been 23 really important. And I think like a lot of people these days, I'm glued to 24 business news. Because apart from whatever policy changes are going on out 25
108 there, I'm really interested in how the markets are reacting.
1 Because the markets represent real actors, serious players 2
with real money-making real investments across a whole range of areas, not 3
just nuclear. But what we've seen today is actually a couple of really -- we had 4
a couple of real data points sitting at the table that represent real investment.
5 One company saying that they've heard enough from the NRC. They're moving 6
into project execution phase.
7 Another company saying they've got major investments in 8
facilities and technology that are going on based on, in part, not just the broader 9
market out there and demand for energy but actually on the work that you all 10 are doing. And so as we move forward and continue to tackle these and 11 whether it's on an individual level for some of these things or as a more broad 12 and cohesive approach on individual regulation, I want you all to kind of hang 13 on to that and to keep going and to keep going further. So thank you all for 14 what you've done.
15 I'm sorry, Cinthya. You've gotten a lot of love today, Dan, not 16 so much, and Jessie, just a little bit. But boy, I want to pick up on 17 Commissioner Crowell because he touched on a lot of things. And of course, 18 he and I share a lot of -- share interest in the spent fuel issue and the analogies 19 there and the kinds of the things that we've learned.
20 Of course, we've got a great track record in this country of 21 moving spent fuel safely and reliably over many, many decades, right?
22 Hundreds and hundreds of shipments on the part of our operating licensees, 23 the Department of Defense, DOE, and others. So we know how to do this.
24 And Cinthya, your point about how there not really being any 25
109 difference on some of the stuff is really important. And yet on the spent fuel 1
issue, as you noted, right, there are other agencies that are involved in this, 2
right, particularly Department of Transportation. Department of Transportation 3
actually regulates transportation on these things.
4 And while maybe we didn't see the higher volume of spent 5
fuel transportation that may have once upon a time been envisioned, the micro-6 reactors provide us an opportunity to revisit some of that engagement, 7
particularly that DOE had, the Department of Energy had with DOT and state 8
governments, et cetera. So how much interaction have we had so far? And 9
with, say, DOT or the Federal Railroad Administration or the National Highway 10 Traffic Safety Administration, et cetera, how much engagement have we had 11 with those entities?
12 MS. ROMAN: So we do have periodic meetings with DOT 13 very frequently because we are co-regulators. But I have to admit on the topic 14 of what the actual carrier is going to be, we haven't engaged as much. We 15 have been talking about micro-reactors.
16 But the focus has been more on the transportation package 17 itself. So yeah, so we engage with them. But it hasn't been the topic that we 18 have been discussing often.
19 COMMISSIONER HANSON: Yeah, it almost seems like --
20 we've seen some models here for, say, factory production of a micro. Then we 21 had NOV Shepherd tell us about kind of the infield concept of operations. But 22 there's, like, this middle piece, right, of getting it from the factory to the place 23 where maybe we haven't seen as much proposals to us for concept of 24 operations. Is it useful -- are we kind of waiting for someone to bring us what 25
110 those concepts might be? Or is it useful to us to kind of have a generic concept 1
that we can kind of evaluate somehow?
2 MS. ROMAN: I would think it would be helpful for people to 3
bring these concepts to us because there is so many possibilities when we talk 4
about micro-reactors that the more we hear from what the plans are from the 5
industry, it help us to prepare. We cannot prepare for every possible scenario.
6 But we want to prepare for the credible ones. And having those engagements 7
and people come along and talking to us will really help us to prepare.
8 COMMISSIONER HANSON: Yeah. Well, the chairman had it 9
right. We were talking about multimodal transportation and the different 10 connections there and so forth. And of course, it is partly about the package.
11 But I wonder if we might as we engage with our interagency 12 counterparts kind of bring in other areas of expertise like security and 13 emergency planning and other kinds of things for that package while it's in 14 transit. Is there a -- Cinthya, I've got a specific question for you on this. And it's 15 something Commissioner Crowell actually brought up.
16 He mentioned you're shipping the reactor from the factory and 17 it's got unirradiated fuel in it. You've got the measures in there to prevent 18 criticality while it's in motion. It goes. It operates for some period of time.
19 And then you're starting to ship it back. Well, now that fuel is 20 irradiated. So on the front end, there's one kind of source term and risk hazard.
21 And on the back end, there's another kind of risk hazard.
22 Is there an opportunity there for flexibility around certificates 23 of compliance for packages? Is that a single package? Are we looking at 24 vendors to propose things to us? How are we kind of starting to get our head 25
111 around that?
1 MS. ROMAN: So part of the reason why for my presentation I 2
was presenting Type B packages is because our use for spent fuel. And part of 3
the assumption is that they're going to be doing some testing at the facility. And 4
depending on the type of testing they do, they might have to consider the fuel 5
spent fuel by the time they're going to ship for the specific location.
6 There are still possibilities for some licensees to consider the 7
fuel fresh fuel and used a Type AF package. Let's say that they do some 8
testing at low energy levels or that there is a low burn up. Maybe they can still 9
justify a fresh fuel package, AF. But yes, I think right now my assumption would 10 be that the -- many of the applicants would be interested in Type B. And maybe 11 I'll add that the type of testing that -- the video that I showed, the testing is kind 12 of similar for Type B and Type AF. But for Type F, it's a little bit more robust, 13 the type of analysis. So --
14 COMMISSIONER HANSON: Yeah, thank you.
15 MS. ROMAN: -- there is some benefit for transporting fresh 16 fuel --
17 COMMISSIONER HANSON: Yeah.
18 MS. ROMAN: -- versus spent fuel.
19 COMMISSIONER HANSON: But the Type B provides kind of 20 a boundary, right? That kind of provides almost the --
21 MS. ROMAN: Yes.
22 COMMISSIONER HANSON: -- extreme case, right? We 23 know things are safe. We've got a lot of experience with Type B packages, et 24 cetera.
25
112 MS. ROMAN: Is that F, B, F, yes.
1 COMMISSIONER HANSON: Okay. All right. Fair enough.
2 All right. I'm down to my last 30 seconds. And Dan, I mean, look, man. So I 3
appreciated your presentation, particularly kind of the four alternatives around 4
this.
5 And I guess I just wanted to ask there was the RIC session on 6
high volume licensing and the modernizing of environmental reviews. And so 7
what did you hear from those sessions on what you heard at the RIC? Kind of 8
how has that influenced the way you guys are approaching this?
9 MR. BARNHURST: I appreciate the question. One of the 10 RIC sessions specifically was presented by Dr. Don Palmrose who's here with 11 us today. And it was on this approach.
12 And so we received comments in the session, both of those 13 sessions, and also live polling that we've looked at since then. And so what we 14 heard was this. I think there's general focus of the importance of what we're 15 doing. I think there's general support for how we're doing it which I would hope 16 is no surprise because we've been working with other stakeholders in order to 17 kind of inform this approach.
18 And there are practices that are widely used from outside the 19 agency to do it in a neat and efficient manner. I guess the last thing I would add 20 to that is there's a sense of urgency, and that's no surprise. But a sense of 21 urgency for us to now go from a list of alternatives that we feel like are flexible 22 enough to handle anything that we might see from a design, a deployment site 23 characteristic standpoint to getting that framework pulled together, 24 implementing and developing it.
25
113 And I would add that we're already in discussions with micro-1 reactor applicants or potential applicants, pre-application space, where we're 2
running through these different types of alternatives with them, deciding which 3
one we think works best for them. And kind of we'll be developing and 4
implementing as we do in some cases. But this has been done before in other 5
places. We're learning the lessons from that, and I think we're well positioned.
6 COMMISSIONER HANSON: Great, thank you. Really 7
appreciate it. Thank you, Mr. Chairman. I'm sorry for delaying everybody's 8
lunchtime.
9 CHAIRMAN WRIGHT: That's okay. We're okay. Thank you.
10 So it appears that we've come to the end of our time together. I don't know 11 about you, but for some reason, I'm craving a Tootsie Pop.
12 (Laughter.)
13 CHAIRMAN WRIGHT: Seriously, it's been a great first 14 Commission meeting on micro-reactors. And there are going to be more 15 because this is a critical topic. And we're going to have to have more as we go 16 forward focusing on everything micro, including what we need to do, what 17 needs to happen to enable possibly a six-month review as Commissioner 18 Caputo paraphrased from Marc Nichol's presentation from NEI this morning.
19 So I want to thank each of you for your presentations and 20 everybody today for their participation. It was very informative. We got a lot 21 more questions probably now than we did when we came in which is a good 22 thing too. So before we close, I'd like to ask my fellow Commissioners if you 23 have any comments. Okay. With that, hearing none, we will adjourn this 24 meeting.
25
114 (Whereupon, the above-entitled matter went off the record at 1
12:18 p.m.)
2