ML21299A313

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Fusion Public Meeting 10272021 - Final Pdf Slides
ML21299A313
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Issue date: 10/27/2021
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Developing a Regulatory Framework for Fusion Energy Systems NRC Public Meeting October 27, 2021

Time Speaker Topic 9:30-9:45am NRC Welcome/Introductions/Opening Remarks 9:45-10:15am General Fusion Michael Cappello Updates on plans for Fusion Demonstration Plant in the UK -

UKAEA Culham Campus 10:15-10:30am Oxford Sigma Thomas Davis Overview and establishment of the American Society of Mechanical Engineers (ASME)Section III Division 4 (Fusion Energy Devices) subcommittee Special Working Group for Fusion Stakeholders (SWGFS) 10:30-10:45am Commonwealth Fusion Systems Updates on the advancement of High-Temperature Superconducting Electromagnet Technology 10:45-11:15am Fusion Industry Association Insights on decision-making criteria for a graded approach 11:15-11:45am NRC 10 CFR Part 30 - Examples of Regulatory Scalability 11:45-12:15pm NRC 10 CFR Part 53 - Overview of the proposed Advanced Reactor rulemaking 12:15-12:30pm All/NRC Questions/Closing Remarks/Next Steps Agenda

CONFIDENTIAL CONFIDENTIAL Fusion Demonstration Plant NRC Briefing October 27, 2021 Michael Cappello - Senior Vice President Technology Delivery October 2021

  • NRC confirmed with General Fusion no confidential information is contained in this presentation.

CONFIDENTIAL 2

Companys innovative and protected technology is the result of 15 years of development and 200+ patents and patents pending One of the largest, most advanced, privately funded Magnetized Target Fusion (MTF) technology companies Rapid innovation, development and testing laboratories headquartered in Vancouver, Canada, with offices at Oak Ridge and Culham UK 15+ years and 200,000+ fusion plasma experiments conducted to date Dr. Michel LaBerge founded General Fusion (GF) in 2002 in a local garage GF has now grown to more than 145+

scientists, engineers, technicians and support staff Common Fusion Industry Visions and Goals committed to reducing global carbon emissions by transforming the energy supply through clean, safe, economical and abundant fusion energy

CONFIDENTIAL 3

A Spectrum of Fusion Technology Pathways ITER scale Magnetic Confinement Fusion (MCF)

Magnetized Target Fusion (MTF)

NIF scale Inertial Confinement Fusion (ICF)

All Confinement Hybrid All Compression Very large, low-density plasma Continuous Plasma and Control Massive, expensive SC magnets 1st wall materials challenges External plasma heating systems Break Even System: >$25B (ITER)

US Naval Research Labs (NRL) -

Linus Program 1971-early research Compact, medium density plasma Slower compression pulses (ms)

No large SC magnets or lasers Few materials and control issues Break Even System: <$1B Very small, high-density plasma Super fast compression pulses (µs)

Expensive high-powered lasers for compression and heating Extreme sensitivity to uniformity Manufactured fuel targets Break Even System: >$5B (NIF)

MTF technology optimal hybrid of magnetic confinement and inertial compression

CONFIDENTIAL 4

$ Cost of Confinement

$ Cost of Driver Driver Power Plasma Energy Magnetized Target Fusion (MTF) and GFs Targeted Regime

CONFIDENTIAL 5

ITER (Magnetic Confinement)

National Ignition Facility-NIF (Inertial Confinement)

CONFIDENTIAL 6

How MTF Technology Works 6

Plasma Injector Pistons Fusion Liquid metal Cavity formation Compression system launch Plasma injection Fusion and energy conversion Simultaneously, a hot magnetized tokamak plasma at 5 million degrees Celsius is formed by a plasma injector and magnetically injected into the compression vessel chamber cavity Confined within the collapsing metal cavity, the plasma is compressed (~9:1) within 4ms and heated to over 100 million degrees Celsius, creating plasma temperatures and densities with requisite confinement timeframes generating significant numbers of fusion events The inner liquid metal liner is quickly pushed inwards by the precisely synchronized array of several hundred compression pistons Timing control and pressure variations in the piston launch system forms the liquid metal into a spherical cavity for plasma compression A robustly designed central compression vessel with a rotating inner vessel containing liquid metal. A chamber cavity of approximately three meters in diameter is formed by rotating the liquid metal inside the central vessel, which is surrounded by an array of several hundred compression pistons Fusion energy is released and absorbed into the surrounding liquid metal liner, heating it to about 500 degrees Celsius The hot liquid metal is circulated through a heat exchanger and converted to steam. The steam drives a turbine to produce electricity and recharges the pistons for the next cycle The cavity reopens, pistons reset, and this cycle repeats one time per second for the commercial power plant

CONFIDENTIAL 7CONFIDENTIAL The fusion equivalent of a diesel engine: practical, durable, cost-effective 7

CONFIDENTIAL 8

MTF Technology Advantages 1.

Liquid metal liner resolves most high energy neutron challenges for first wall materials, it is also the heat transfer medium, the tritium breeding blanket, dose shielding, etc.

2.

MTF does not require fist wall replacements 3.

External plasma heating systems are not required (ICRH, RH, neutral beam systems, etc.)

4.

Superconducting magnets or liquid helium plants not required 5.

MTF has a high-density plasma with strong magnetic field as a result of compressed plasma flux 6.

Pulsed approach, does not require complex high speed continuous plasma control systems 7.

Diverters are not required 8.

MTF has good tritium breeding ratio contained in liquid metal (1.4) allows for very small inventory quantities on site (~2g inventory for CPP vs. 4kg for ITER) 9.

High Technology Readiness Levels (TRL) of key components

10. Lower parasitic electrical loads required for power plants
11. Lower capital costs projected for power plants
12. Very competitive LCOE for base load power generation Biggest Challenges for MTF:
  • Liquid metal wall interface with plasma (interactions?)
  • Repetition of compressions for CPP @ 1 /sec

CONFIDENTIAL 9

MTF Phased Development and Commercialization Program 2003 - 2008 2009 - Present System Development Proof-of-Concept Prototype Representative Plasma Compression Science Plasma Stability Compression Heating Repetition Rate Closed DT Fuel Cycle High Reliability & Availability Integrated System Solution Fusion Relevant Temperatures Repeatability Concept Exploration Compression Neutronic studies Science and Technology Development Early Experiments Integrated Large Scale Prototype Commercial System Fusion Demonstration Plant (FDP)

Operations Start 2025 CPP Unit 1 Construction 2030

CONFIDENTIAL 10 Plasma Injection Systems High quality plasmas can be reliably generated, and the PI custom designed for optimum plasma performance. Design adjustments available for magnetic fields, high vacuum and purity levels, injected plasma energies and temperatures, plasma density, etc.

One of the largest, fully operational plasma injectors in the world, at 10+ MJ pulsed power supply, 5MoC plasma injection temperatures, and exceeding 20 ms plasma lifetimes (FDP compression pulse ~4ms)

CONFIDENTIAL 11 Compression Systems Demonstrated integrated compression technologies at prototype-relevant scale and successfully operated for 2 years of testing Demonstrating liquid metal liner performance on multiple different test fixtures and configurations FDPs large central compression vessel and spinning internal rotor under development with top industry partners FDP compression pistons with accumulator systems in design

(>500-unit array)

CONFIDENTIAL 12 The MTF Fusion Demonstration Plants (FDP) Purpose Refine commercial fusion power plant economics and next steps based on actual FDP performance Demonstrate at relevant power plant-scale, that fusion conditions can be practically achieved using General Fusions MTF technology The FDP Program has 3 primary goals:

70% scale of commercial power plant 1 pulse per day repetition rate Off-grid demonstration prototype Establish science and engineering collaborations with UKAEA and others, along with establishing General Fusions UK and European HQ Integrate all key technologies for MTF fusion: Plasma injection, compression vessel, rotor, pistons, liquid metal & diagnostics

CONFIDENTIAL 13 3 m Diameter cavity 3.9 ms Plasma compression time 12MWe Power Req.

3000 tons 500+ drivers 20-40 MPa Accumulator pressures Approx. 17m in diameter, 13m in height 10.6 m3 Pre-shot plasma volume 1.06 m3 Post-shot plasma volume FDP MTF Fusion Machine

CONFIDENTIAL 14 FDP Facility and BOP Project, Engineering and Design Team RIBA Stages A

B A

B Design Lead, Canadian HQ, UK office Architectural Partner, UK based Engineering Partner, Canadian HQ, UK offices Engineering & Sustainability, UK based Quantity Surveyor Specialist, UK based Site and Building Owner & Project Sponsor

CONFIDENTIAL 15 BREEAM Excellent Standard Major design drivers FDP Facility Design Principles - Form Follows Function Isolate the hazards - lithium fire protection confinement boundary Serve GF needs now, and potential future tenants. Flexible capabilities, heavy lift /

craning, services, labs, processes, offices, etc.

Optimize functionality, adjacencies and efficiencies for testing, process systems, and rapid prototyping Adequate space to install, commission, operate, service, repair and modify MTF machine

CONFIDENTIAL 16 FDP Industrial Scale Facility Hazard's analysis, safety case drafted, lithium fire protection primary risk concern Operations and Safety Plans being drafted Site Services, electrical = 12MWe Service water = 17 L/s, Fire = 126 L/s Total area = 9,940 m2 60 persons operation staff, 80 parking spots allocated Highbay height = 32 m Major facility parameters Total est. Lithium = 20 tons, Helium = 5 tons Total steel est. = 914 tons, concrete est. = 7,875 m3

CONFIDENTIAL 17 Major Design Efforts Completed:

RIBA Stage 2.5 Design Report finalized, approved and distributed Preliminary Safety Case drafted, submitted and reviewed by UKAEA (HS&E requirements)

Preliminary fire mitigation strategy completed Currently being reviewed by ARUP to ensure we meet appropriate local fire codes and regulations.

Consultations with local fire bigrade to follow Preliminary flood risk assessment report completed Currently working with Hatch, ARUP and McBains to determine flood mitigation requitements Soils Sampling and GeoTech Reports underway Confirmation on soils loading and for final foundation designs Preliminary noise impact assessment completed Currently completing the full community noise impact assessment with site samples, in support of planning

CONFIDENTIAL 18 Selected Site at UKAEA Culham Science Center London Oxford Culham (UKAEA)

JET FDP Future STEP Test Facility Cambridge H3AT Liquid Metal Test Lab

CONFIDENTIAL 19 Fusion Demonstration Plant Siting Selection

  • Fusion represents a safe, clean, sustainable, and environmentally friendly process for carbon-free base load energy generation. Power market studies show there exists a multi-trillion $ worldwide market for carbon-free replacement power generation over the next 20 to 30 years - UK is, and near early adopter markets.
  • The UK and UKAEA have an aggressive modern fusion research effort underway with multiple projects, mature supply chain, and a fit for purpose regulatory environment for commercial fusion technology development companies.
  • UKAEAs Culham Science Center and Harwell, along with major universities Oxford, Cambridge, Imperial, etc. have a rich history of fusion research, and current robust fusion sciences education programs for future resources.
  • Building the FDP at the UKAEA Culham Science Center affords General Fusion access to significant world-class fusion energy and plasma research expertise in one location. Many science collaborations with UKAEA are being explored.

CONFIDENTIAL 20 Onsite Geotech Drilling Underway

CONFIDENTIAL 21

CONFIDENTIAL 22

CONFIDENTIAL 23

CONFIDENTIAL 24

CONFIDENTIAL 25 Regulation Considerations-FDP and Commercial Power Plant (CPP)

  • FDP-deuterium fueled only plasma
  • FDP- @1 pulse/day, lower energies will generate no activated fusion machine components, or dose beyond machine wall
  • All particle energies are below 50 MeV
  • CPP - high energy neutron pulses are surrounded in 4p by liquid metal (molten lead with small fraction of lithium for tritium breeding)
  • CPP-some fusion machine components will experience low-level activation
  • CPP-no dispersible first wall activated dusts, or off-site radiological hazards
  • An appropriate radiation protection program will be utilized for both facilities (i.e. NCRP Report 144)

CONFIDENTIAL 26 Neutron Yields System Fuel Starting Plasma Diameter Starting Plasma Density Neutrons per pulse Operating Frequency PCS (Plasma Pulse Verification Program)

Deuterium 0.4 m 1e14 cm-3 1e10 1 to 2 /year Fusion Demonstration Plant (FDP)

Deuterium 3 m 2e13 cm-3 1e13

~1 /day Commercial Power Plant (CPP)

Deuterium

- Tritium 4.4 m 2e14 cm-3 2e20

~1 /s By comparison: Thermo Scientific P 385 produces 3 x 108 n/s.

Running for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> it will produce 9 x 1012 neutrons in a day GF has a CNSC Class 2 License for experiments

CONFIDENTIAL 27 Regulation Considerations - FDP and Commercial Power Plant (CPP)

1) High bound estimate on maximum yield for 1,000 shots on FDP.
2) Not including possible additional couple of grams of tritium stored in getter beds for restarts.
3) http://www.iter.org/faq#What_will_be_the_total_amount_of_tritium_stored_on_site_What_are_the_procedures_foreseen_to_confine_a nd_control_the_stock_

Tritium management of very low volumes:

FDP: Deuterium fuel only, one 4ms pulse a day CPP: Total inventory of tritium2 2g (1.9 x 104 Ci)

CPP: Tritium self-contained throughput 76 g per day (~3oz)

CPP: High tritium breeding ratio of 1.4, no additional tritium required CPP: Tritium is maintained in a closed loop monitored process Initial small volume of start-up tritium purchased commercially Total tritium inventory of ITER3 4 kg (3.9 x 107 Ci)

Bruce Pwr. (A,B,NPP) 2015 Emissions ~37.5 g (liquid/steam)

Mature commercial tritium handling control and monitoring practices exist.

In CPP real time tritium control, monitoring and tracking will be utilized. No planned effluents, off-normal release should be minimal (mg) and below NRC unrestricted release limits of I00 millirem per year, (100 - 500 Ci liquid and 100 Ci gaseous ) (EPA drinking water limits for Tritium 20k pCi/liter)

CONFIDENTIAL 28 Fusion Technology Requirements-Utility Perspective EPRI Fusion Technology Study and Report -

Criteria for Practical Fusion Power Systems Electric utilities are keenly interested in the promise of fusion: large-scale electricity production anywhere, with virtually no natural resource depletion or environmental pollution. To expedite development of commercially viable fusion systems, the Electric Power Research Institute (EPRI) - theR&D wing of theU.S. electric utility industry - conveneda panel of top utility R&D managers and executive officers1 to identify the key criteria that must be met by fusion plants in order to be acceptable to utilities.

This panels findings:

(1) Economics (2) Public Acceptance (3) Regulatory Simplicity 1 Present and former utility industry executives selected for their experience in managing the introduction of major new powergeneration technologies.

CONFIDENTIAL 29 Fusion Technology Requirements - Utility Perspective - continued

1. Economics To compensate for the higher economic risks associated with new technologies, fusion plants must have lower life-cycle costs than competing proven technologies available at the time of commercialization.
2. Public Acceptance Public acceptance and customer satisfaction will be essential to the commercial success of future fusion power plants. A positive public perception can be best achieved by maximizing fusion powers environmental attractiveness, economy of power production, and safety.
3. Regulatory Simplicity Because fusion is so different from existing fossil and nuclear power generation technologies, existing regulatory requirements for those technologies are not likely to be relevant to fusion. Appropriate regulation for fusion power plants should be determined by characteristics of the technology, the need for an expeditious and efficient regulatory process, and the obligation to minimize unnecessary barriers to fusion development.

CONFIDENTIAL 30 Regulation Summary If required, any new regulations must be simple and fit for purpose based on specific technology, appropriate for the specific hazards - generic enveloping or prescriptive regulations, make it easier or more familiar for the regulator, but will hurt the fusion industry.

Fusion has little to no radiological hazards to the public, as compared to fission nuclear. Fusion technology is much more like accelerators and irradiators - existing regulations are sufficient.

Safe, carbon-free fusion energy power markets are worldwide. Private companies will migrate to least resistance, early adoption markets.

Time is of the essence for the fusion industry.

Fusion energy technologies are not reactors or utilization facilities - no SNM involved.

31 Twitter

@generalfusion Instagram

@generalfusion LinkedIn general-fusion Website generalfusion.com

Overview and establishment of the ASME Section III Division 4 (Fusion Energy Devices) subcommittee Special Working Group for Fusion Stakeholders (SWGFS)

Dr Thomas Davis Chairman of the Special Working Group for Fusion Stakeholders Member of ASME Section III Division 4 President & CTO of Oxford Sigma Email: thomas.davis@oxfordsigma.com NRC Public Fusion Forum - 27th October 2021 via MS Teams OS DOCID: R-179

Background - Codes and Standards The purpose of nuclear codes and standards is to establish national or international standards that consist of a set of rules based on state-of-the-art knowledge, experience, and experimental feedback from nuclear facilities.

The design and construction of any nuclear reactor should make use of appropriate nuclear codes and standards to provide reassurance and quality control for the structural integrity and safety of these plants.

The codes provide the bridge between different suppliers, participants, researchers, designers, manufacturers, and regulators.

The documents can be viewed as a live document that is updated as better operational experience, knowledge, and scientific advancement is made available.

American Society of Mechanical Engineers (ASME) Boiler &

Pressure Vessel Code (BVPC)Section III is designed for nuclear reactors since the 1956 2

ASME BPVC Section III Division 4 Existing nuclear codes and standards for construction do not adequately cover the design, manufacturing or construction of fusion energy devices that are currently being considered for future constructions. They also do not provide support for the on-going projects, such as ITER.

The goal of Division 4 is to develop a recognized fusion construction code and standard to be issued by ASME.

This new construction code would be used in the USA and/or globally as an acceptable basis for nuclear regulators for the construction, licensing and operating of new fusion facilities, such as the Compact Pilot Plant, DEMO, etc.

3

Organisation 4

Section III Standards Committee Division 4 Subgroup for Fusion Energy Devices WG General Requirements WG Magnets WG Vacuum Vessel WG Materials WG In-Vessel Components Special Working Group for Fusion Stakeholders WG = Working Group

Membership of Division 4 as of 27 October 2021 5

ASME BPVC Section III Division 4 These new rules for fusion energy devices apply to safety classified components such as:

Vacuum vessels Cryostats Resistive / superconductor magnet structures In-vessel Components (Divertors, Breeders, First-wall tiles)

And their interaction with each other.

Other related support structures, including metallic and non-metallic materials, containment or confinement structures, piping, vessels, valves, pumps, and supports will also be covered.

Division 4 is also working with the ASME Section XI Division 2 In-Service Inspection Operations Code in applying the use of the Reliability and Integrity Management (RIM) program 6

Division 4 Draft Standard Division 4 issued in November 2018 as a Draft Standard for Trial Use of proposed code rules entitled Rules for Construction of Fusion Energy Devices ASME FE.1-2018 for 3 years.

The Draft Standard is not an approved consensus standard. ASME has approved its issuance and publication as a Draft Standard only.

3 years will end in November 2021. Consensus approval is expected.

Changes since October 2021 Discussion on the plethora of approaches to fusion devices:

Magnetic confinement fusion Magneto-Inertial Fusion Inertial Fusion Energy Based on engineering principles and operational experience (so tokamak focused for now).

Provide pathway for future edits to develop the code over the decades.

Preparation for ASME acceptance as a new Division within Section III 7

SWG - Fusion Stakeholders Dr Thomas Davis Chairman of the Special Working Group for Fusion Stakeholders Member of ASME Section III Division 4 President & CTO of Oxford Sigma Email: thomas.davis@oxfordsigma.com NRC Public Fusion Forum - 27th October 2021 via MS Teams ASME 2021

9 Thank you to Dr Sutherland at CTFusion Inc for permission to use this figure

© CTFusion Inc

SWG - Fusion Stakeholders Scope The SWGFS subcommittees aim is to provide a venue for stakeholders to voice their needs and development direction, provide comments and suggest input on the development of rules for the construction of fusion energy devices within ASME Section III, Division 4 Fusion Energy Devices code.

SWGFS shall identify the research and development efforts required to support the technical development of the code rules within other subcommittees.

Interface with BPVC XI Division 2 on Inservice Inspection issues is expected.

Stakeholders:

Private fusion companies / Vendors Operators Supply chain National regulators National Laboratories Government Universities 10 Balanced and representative view I am looking for members -

please reach out on thomas.davis@oxfordsigma.com

SWG - Fusion Stakeholders ASME Code Week The Boiler Code Week is a forum for business leaders, engineers, scientists, and policymakers to discuss code changes and high-level topics related to the ASME BPVC concerning the design, fabrication, and inspection of boilers, pressure vessels, and nuclear power plant technologies.

These meetings occur in February, May, August, and November (4 times a year).

Free and public.

Held in person in the USA (COVID has made them virtual until May 2022).

11 Inaugural SWG Fusion Stakeholders Meeting 1st November 2021 8:30 AM - 10:30 AM EST https://asme.zoom.us/j/99565408032?pwd=M1VF QWd0N1B6cnhOU2dnVWpZeFRhUT09

Overview and establishment of the ASME Section III Division 4 (Fusion Energy Devices) subcommittee Special Working Group for Fusion Stakeholders (SWGFS)

Dr Thomas Davis Chairman of the Special Working Group for Fusion Stakeholders Member of ASME Section III Division 4 President & CTO of Oxford Sigma Email: thomas.davis@oxfordsigma.com NRC Public Fusion Forum - 27th October 2021 via MS Teams OS DOCID: R-179

10/25/2021 1

Copyright Commonwealth Fusion Systems CFS creates viable path to commercial fusion energy with worlds strongest HTS magnet Tyler Ellis

10/25/2021 2

Copyright Commonwealth Fusion Systems

  • 2020 DOE FESAC Report on Fusion
  • Important technological breakthroughs include high-temperature superconductors (HTS) that enable the advances in magnet technology required to achieve that confinement. - Page 2 Importance of HTS magnets for fusion is well established
  • 2021 National Academies of Science Report on Fusion
  • the higher magnetic field made possible by the development of demountable high temperature superconducting magnets was identified as a key enabling technology that provides a potential path, when combined with advanced operating scenarios, to a compact fusion pilot plant with high fusion power density. - Page 59

10/25/2021 3

Copyright Commonwealth Fusion Systems CFS path to commercial fusion energy COMPLETED Proven science Alcator C-Mod CONSTRUCTION UNDERWAY Operation in 2025 Achieve net energy from fusion Early 2030s Fusion power on the grid Pelectric~200MW COMPLETED September 2021 Demonstrate groundbreaking magnets HTS Magnets SPARC ARC COMPLETED October 2020 Published peer-reviewed SPARC physics basis in Journal of Plasma Physics

10/25/2021 4

Copyright Commonwealth Fusion Systems New class of magnets for fusion energy

CFS is building advanced large-bore, HTS magnets using scalable manufacturing techniques

Our HTS magnet is made up of 16 staked pancakes; each pancake by itself is the largest HTS fusion magnet in the world

High field approach reduces fusion power plant size by a factor of 40

HTS magnets combined with the proven fusion science and engineering of tokamaks enables smaller, lower-cost fusion power plants faster

HTS magnet technology will be used in SPARC, the worlds first net energy from fusion device, and then ARC, the first fusion power plant

10/25/2021 5

Copyright Commonwealth Fusion Systems Highly capable integrated coil test stand

10/25/2021 6

Copyright Commonwealth Fusion Systems

  • Fully representative of SPARC coil operation
  • 20T peak magnetic field on coil, well beyond what LTS can do
  • Largest HTS magnet in the world by a factor of 100x
  • >100MJ,
  • >250 km of HTS
  • >100A/mm^2,
  • >2m size
  • Successfully tested on September 5, 2021 Successful test of fusion magnet

10/25/2021 7

Copyright Commonwealth Fusion Systems SPARC design has progressed and construction started

  • HTS means smaller tokamaks with lower tritium inventories and smaller low-level waste generation
  • This confirms future fusion energy facilities fit comfortably within 10 CFR 30
  • Applied agile practices from industries like space - systematic de-risking
  • Long-lead procurement begun
  • Site settled and build started

10/25/2021 8

Copyright Commonwealth Fusion Systems Domestic burning plasma by 2025 Acquired land: Spring 2021 Total size: 47 acres Location: Devens, MA Initial magnet manufacturing facility: 160,000 sf Manufacturing operations: 2022 SPARC operations: 2025

10/25/2021 9

Copyright Commonwealth Fusion Systems Construction is underway (progress as of 10-22-2021)

CFS Headquarters and HTS Magnet Factory SPARC

10/25/2021 10 Copyright Commonwealth Fusion Systems Construction is underway (progress as of 10-22-2021)

10/25/2021 11 Copyright Commonwealth Fusion Systems DEMO (World)

JET (UK)

ITER (World)

ARC First Power plant C-MOD Plasma physics SPARC Net-energy Government plans prior to advances 2015 2020 2025 2030 2035 2040 2045 2050 2055 2060 Plans that accelerate fusion energy CFS timeline is similar to the other commercial efforts

~ to scale Acceleration of the plans due to breakthroughs in magnets, materials, controls and commercial interest

10/25/2021 12 Copyright Commonwealth Fusion Systems

  • CFSs successful magnet test is a major milestone towards the goal of demonstrating net fusion energy by 2025 and putting fusion megawatts on the grid by the early 2030s
  • As noted in the October 2021 PCAST public meeting, successful commercialization of fusion requires appropriate regulatory treatment
  • CFS believes the current byproduct material regulatory model (10 CFR 30) is sufficient to ensure a safe and cost-effective fusion energy industry
  • Part 30 is inherently flexible and offers a reasonable balance between predictability for developers while providing regulatory flexibility as the fusion industry matures
  • Establishing subjective and arbitrary regulatory limits in a hybrid model creates confusion among stakeholders without improving safety or environmental protection Summary

10/25/2021 13 Copyright Commonwealth Fusion Systems The fastest path to limitless, clean energy

FIA Members

The Stakes of NRC Fusion Decision The world is racing to be ready for fusion energy power plants

  • UK Green Paper on Fusion Regulation
  • European Commission Study: Towards a specific regulatory framework for fusion facilities
  • IAEA TECDOCs on regulation and safety of fusion facilities

The NRCs Four Questions 1.

Offsite Consequences What advantages/disadvantages would stem from categorizing Fusion Systems based on estimated offsite consequences as one of the many different decision-making criteria tiers? What are examples of potential tiers based on estimated offsite consequence for staff consideration?

2.

Byproduct Materials Inventory What advantages/disadvantages would stand from categorizing Fusion Systems based on inventory limits of byproduct material such as tritium as one of the many different decision-making criteria tiers? What are examples of potential tiers based on inventory limits of byproduct material for staff consideration?

3.

Power Output What advantages/disadvantages would stem from categorizing Fusion Systems based on power output (MWe) as one of the many different decision-making criteria tiers? What are examples of potential tiers based on power output for staff consideration?

4.

Fusion Reaction Type / Fuel Choice What advantages/disadvantages would stem from categorizing Fusion Systems based on the fusion reaction being applied(neutronic (DT, DD, TY) or aneutronic) as one of the many different decision-making tiers? What would the expected difference in the level of safety systems between fusion facilities for these two types of fusion reactions?

Overall comments on NRC questions The NRCs questions appear to presuppose the creation of a new regulatory framework with a tiered system of regulation Utilizing Part 30 is the most effective, risk informed, and tailored method to address the regulation of Fusion facilities Part 30 has proven itself flexible enough to handle an incredibly wide range of byproduct-based technologies with varying degrees of risk Part 30 is well established and provides regulatory predictability for fusion energy developers Part 30 also provides the NRC flexibility as fusion technologies mature

Overall comments on NRC questions In general, the Part 30 regime already provides sufficient flexibility to allow the NRC to tailor the requirements to individual fusion designs based on their risk - This is a graded approach to regulation and risk Part 30 already contains appropriate gradations, and can be adapted to support any gradations needed.

Regulatory requirements for emergency planning, decommissioning, and other factors impacting health and safety are contained in Part 30 Part 30 requirements already vary depending on issues such as offsite consequences, waste, facility design, and inventory limits There are no potential fusion facilities which need a higher grade of regulation than what is already provided by Part 30 Imposing a graduated approach to capture hypothetical technologies that no utility or vendor would ever want to order or build drives unnecessary conservatism in the overall regulatory approach

Offsite Consequences Offsite impact is an appropriate decision-making category for fusion regulation NRCs core mission: protecting public health, safety, and the environment Provides the NRC flexibility to evaluate individual facilities Flexible method that can evolve over time as fusion technologies develop further Fusion facilities will present similar offsite impacts to many other byproduct materials facilities. Therefore, this category can build on previous regulatory decisions There is a well-established framework under Part 30 for evaluating offsite consequences for many different types of facilities

Offsite Consequences There is no need to develop any new regulations for estimating offsite consequences for fusion facilities FIA believes the specific licensing guidance in Part 30 is sufficient for purposes of estimating offsite risk There is no health, safety, regulatory or other advantage in developing a new method for calculating the offsite consequences for fusion energy projects Part 30 already categorizes materials licensees based on their potential offsite consequences Part 30 establishes certain offsite exposure limits for members of the public Example: emergency planning requirements contain grades depending on the license applicants ability to demonstrate maximum offsite dose. Licensees which exceed certain thresholds must create an emergency plan, and the NRC can require additional details or mitigation is necessary to address offsite consequences.

Offsite Consequences Probabilistic Risk Assessments are not appropriate or necessary for fusion facilities The maximum possible risk presented by fusion facilities is not significant enough to require PRAs The Commissions Policy Statement on Use of Probabilistic Risk Assessment Methods in Nuclear Regulatory Activities (60 FR 42622) recognized that there may be situations with material users where it may not be cost-effective to use PRA in their specific regulatory applications.

At its current stage of development, requiring fusion licensees to conduct Probabilistic Risk Assessments would introduce significant regulatory uncertainty, unnecessarily hamper designers, and impose unsustainable costs on developers, effectively precluding many fusion energy developers from building their demonstration devices in the U.S.

Inventory Limits Inventory limits are reasonable for consideration in context of evaluating offsite risks, but not as independent criteria One exception - potential to establish exemptions based on certain very low inventory limits An independent focus on inventory limits would not adequately consider differences in facility design or types if inventory Part 30 regulations are currently sufficient to accommodate the anticipated inventory limits any potential commercial fusion facility There is no need to create new inventory limits above which a new regulatory regime for fusion facilities would apply

Inventory Limits

  • The NRC should consider establishing inventory limits below which certain exemptions would be granted, such as for fusion facilities which do not use tritium Some potential designs do not involve any tritium, and should receive broad exemptions as they pose even smaller radiological risks

Power output

  • There are no advantages to basing regulatory requirements on thermal power output MWt output does not relate to risk, potential offsite dose, decommissioning planning, or any other radiological factor MWt does not consider technological differences Categorizing fusion devices by MWt would impose arbitrary constraints on fusion developers

Fusion Reaction Type/Fuel Choice Other than its relevance to an overall evaluation of offsite impacts or decommissioning planning, fusion reaction and fuel choice are not appropriate methods to categorize fusion devices While some fusion reactions may involve no byproduct material, and be eligible for regulatory exemptions, the level of offsite risk is more inherent in the specific facility design rather than the reaction type From a risk-informed perspective, all of the conceived fusion reaction types or fuel choice present risks that can be appropriately regulated under existing Part 30 regulations Some types of fusion reactions may involve no byproduct material, and be eligible for exemptions, but there is no basis for establishing more stringent regulatory requirements based on reaction type

Closing Even though both technologies are intended to produce electricity, fusion devices and fission reactors share few common risks or radiological hazards Fusion devices do not use or produce special nuclear material, high level waste, or spent nuclear fuel, and cannot have a criticality event Fusion devices fundamentally are not utilization facilities Part 30 is the appropriate regulatory framework for fusion devices Fusion devices have much more in common with devices such as accelerators and cyclotrons, which are appropriately regulated under Part 30 Although no developers are planning large facilities, even very large fusion facilities would be most appropriately managed under Part 30, rather than being subject to utilization facility requirements Part 30 already contains risk-informed grades of regulation, and can be easily amended to incorporate further, that can be applied to specific facilities based on a variety of factors

THANK YOU

  • FIA continues to encourage the NRC Staff to engage in monthly meetings with NRC members to further build its understanding of fusion technologies while it works to develop an options paper for the Commission
  • Read our FIA Regulatory White Paper at:

www.fusionindustryassociation.org

/post/fusion-regulatory-white-paper

10 CFR Part 30 - Examples of Regulatory Scalability Duncan White (NRC)

Diego Saenz (Wisconsin)

Huda Akhavannik (NRC)

Donald Palmrose (NRC)

October 27, 2021 1

Overview of a Part 30 Approach

  • Part 30 licensing has key frameworks that may be leveraged or extended to license fusion facilities

- Examples: Emergency Planning, Effluents, Training

  • Categorization criteria for fusion facilities
  • Could be used in combination with other regulatory mechanisms for a graded approach
  • Any scalable approach needs clear and predictable decision-making criteria to ensure consistency and regulatory certainty 2

3

Effluents Facilities with robust radiological effluent control systems are licensed to have less than 10% of the 10 CFR 20, Appendix B, release requirements.

4 Facility Type Inventory Nuclear Pharmacy I-131, Mo-99 Medical Isotope Production I-131, Mo-99 Fusion R&D (proposed)

H-3, Lu-177, Yb-175, Yb-177 Source Manufacturing H-3, Co-60, Cs-137, Ir-192, Am-241 Fusion Energy R&D H-3 Rare Earth Processing U-238, Th-232

Training Features of Part 30

  • Based on role and level of interaction with material
  • Individual named on the license could be the supervisor or the primary handler/operator

- Following table focuses on individuals named on the license or on licensee-maintained list

  • Designed to fit industry involved

- Medical use heavily leverages Medical Boards and Licensure

- Industrial radiography leverages third-party certifiers such as American Society of Nondestructive Testing, Inc (ASNT) 5

Portable/Fixed Gauges Diagnostic Medical R & D (incl.

Fusion)

Manufacturer

& Distributor Well Logging Radiation Oncology Industrial Radiography Panoramic Irradiators Transferable X

X X

X X

X X

X Refresher Training X

X X

X X

X X

X OJT X

X X

X X

X X

X Specific number of hours X

varies varies X

X Device Specific Training varies varies X

X X

X Requires AUs physical presence C

varies varies X

X, C X

X 3rd Party User Examination C

C X (periodic renewal required)

Review Past Events X

C X

X Simulated Events X, C X, C X

C - Commonly used to meet regulatory criteria or commonly required by licensee tie-downs X - Required by regulation or included in Licensing Guidance 6

Categorization Considerations 7

Tritium inventory already used in regulations Radionuclide form (gaseous, liquid, bound, unbound) affects offsite consequences, not just activity.

Megawatts electric (MWe) or thermal (MWth) may not correlate to radiological risk for fusion facilities Tritium handling system may account for a large fraction of tritium inventory and inventories could widely vary Wide range of facility types, including aneutronic fusion

Agreement State Considerations

  • Agreement States may be willing and able to maintain on-site inspection staff (e.g.,

Resident Inspectors)

- Illinois Emergency Management Agency currently maintains Resident Inspectors at their nuclear power plants

  • Agreement States may follow NRC practice of consulting with DOE National Laboratories and other contractors for portions of licensing review 8

Conclusion 9

STAFF IS CURRENTLY CONSIDERING PART 30 AS A POTENTIAL APPROACH.

CURRENT APPROACH TO TRAINING, EFFLUENTS, AND EMERGENCY PLANNING ARE ALL APPLICABLE TO FUSION FACILITIES.

CATEGORIZATION CRITERIA MAY BE APPLICABLE TO FUSION LICENSING UNDER PART 30.

AGREEMENT STATES WOULD BE KEY PARTNER IN REGULATION OF FUSION FACILITIES.

10 CFR PART 53 Overview and Status

Part 53 Relationship to Fusion Energy Systems Nuclear Energy Innovation and Modernization Act (NEIMA) and Commission Direction o advanced nuclear reactor means a nuclear fission or fusion reactor, o SRM-SECY-20-0032 approved staffs approach for Part 53 rulemaking and directed the staff to consider the appropriate treatment of fusion reactor designs in our regulatory structure by developing options for Commission consideration o July 15, 2021, NEIMA Section 103(e) Report to Congress on Part 53 Rulemaking Staffs Response to SRM-SECY-20-0032 and Path Forward o Continue interactions in public forums with U.S. Department of Energy (DOE) and Fusion Industry Association (FIA) o Develop options for regulatory approaches for fusion in parallel with Part 53 rulemaking o Part 53 primarily fission-based; technology-inclusive concepts may accommodate fusion technologiesmaintain flexibility for future Commission direction

Part 53 is an option to be presented to the Commission

Transformative Aspects of Part 53 o Establishment of technology-inclusive safety criteria o Risk-informed approach to safety criteria to provide predictability for the classification of plant equipment and controls over that equipment during operation o Approach to the selection of design basis accidents (DBAs) that provides flexibility to designers to designate which equipment will be classified as safety-related o Allowances for applicants to credit analytical safety margins in their design to gain operational flexibilities in areas such as EP and plant siting o Quality assurance requirements that would allow use of a broader set of codes and standards o Proposal to address manufactured reactors that would be fueled at the manufacturing facility and transported to the reactor site

Part 53 Development The staff continues its novel approach of releasing preliminary rule language to facilitate early stakeholder engagement Publishing Optimizing future public and ACRS meetings to be more topic-specific to enable richer focused dialogue on specific issues (e.g., staffing, role of PRA)

Engaging Continuing to consider input from numerous stakeholders, the public, and ACRS, as we evaluate changes to the preliminary language Responding Developing options for technology-inclusive alternatives that do not rely on PRA in a leading role to address stakeholder comments Evolving Developing the path forward to achieve the objectives of the approved rulemaking plan while addressing stakeholder comments Assessing

Part 53 Outline Plant Documents (Systems, Procedures, etc.)

Analyses (Prevention, Mitigation, Compare to Criteria)

Plant/Site (Design, Construction, Configuration Control)

Retirement Staffing &

Human Factors Configuration Control Surveillance Maintenance Operation Construction/

Manufacturing Construction Siting Design and Analysis LB Documents (Applications, SAR, TS, etc.)

Project Life Cycle System

& Component Design Analysis Requirements Subpart B Subpart C Subpart D Subpart E Subpart G Subparts H & I Safety Categorization &

Special Treatment External Hazards Site Characteristics Environmental Considerations Ensuring Capabilities/

Reliabilities Change Control Environmental Considerations Programs Security, EP Facility Safety Program 5

Requirements Definition

  • Safety Objectives
  • Safety Criteria
  • Safety Functions Other Subpart J Admin &

Reporting Clarify Controls and Distinctions Between Subpart F Subpart A General Provisions

Part 53Rulemaking Status Stakeholder Engagement o 8 public meetings and 9 ACRS meetings o Future meetings will be topic focused o Recent meetings:

This week: 10/26 on Personnel (Subpart F); 10/28 on Technology-Inclusive Deterministic Alternative

Public: 9/15 on 50.59-like change process; 8/26 on graded PRA; 6/10 on Security and EP

ACRS: 9/23 ACRS meeting; 7/21 on EP/Licensing Modernization Project Focus Areas o Continue stakeholder engagement o Continue preliminary release of rule language o Develop the rule package o Work on the supporting guidance Recent Industry Input o NEI letter presenting unified industry positions (July 14) o USNIC letter (July 15) o NEI Manufacturing Licenses white paper (July 16) o NEI comments on security sections (August 31) o NEI Role of PRA white paper (September 28)

Rule Language o Early Release: (A) definitions, (B) safety criteria, (C) design and analyses, (D) siting, (E) construction &

manufacturing, (F) operations, programs, (Part 73) security and EP.

o Recent Release: revision to (B) safety criteria and (C) design and analyses; new language for (H) licensing processes, (I) maintenance of the licensing basis, and (J) reporting and financial o Nearing completion of 1st iteration of all Part 53 subparts and Technology-Inclusive Deterministic Alternative

7 Site selected Part 50 Part 52 Part 53 Leveraging and Combining Existing Licensing Processes Operating License (OL)

CP based on SDA, ML or DC Construction Permit (CP)

Operations Site selected Site selected Fuel Load Combined License (COL)

Manufacturing License (ML)

Standard Design Approval (SDA)

Use OL or custom COL to develop a subsequent DC Design Certification(DC)

CP and COL may reference Early Site Permit (ESP) or site suitability review (SSR)

Next Steps Continue ongoing activities o Part 53 development and stakeholder engagement o Continue public forums with DOE and FIA Deliver options paper to Commission - informed by stakeholder interactions Incorporate fusion technologies into a technology-inclusive regulatory framework by 2027 in manner directed by Commission Key documents related to the Part 53 rulemaking, including preliminary proposed rule language and stakeholder comments, can be found at Regulations.gov under Docket ID NRC-2019-0062

Thank You

Discussion/Questions

Schedule/Next Steps The timeline for providing options to the Commission on the licensing and regulations of Commercial fusion power plants is being done in parallel, but on a separate schedule from the development of the draft proposed 10 CFR 53.

A separate schedule means that if the NRC pursues rulemaking to address fusion facilities, the schedule could extend beyond 2024, but would be completed before 2027 to comply with the Nuclear Energy Innovation and Modernization Act.

Rulemaking is done via a comprehensive, multi-step process. Additional information:

https://www.nrc.gov/about-nrc/regulatory/rulemaking/rulemaking-process.html The NRC would consider extending the May 2022 SECY paper target date should an extension to the 10 CFR 53 schedule occur.

Extending the proposed SECY aligns well with industrys desire to have a series of workshops to allow for greater engagement and understanding of fusion technology, risk, and legal requirements.

Closing Remarks Thank You!

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