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May 3, 2018 Public Stakeholder Meeting on Possible Regulatory Process Improvements for Non-Light Water Reactors, Slide Presentations
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Issue date:	05/03/2018
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Public Meeting on Possible Regulatory Process Improvements for Advanced Reactor DesignsMay 3, 2018 1Telephone Bridge(888) 793-9929 Passcode: 6479346 Public Meeting

Telephone Bridge(888) 793-9929 Passcode: 6479346Opportunities for public comments and questions at designated times 2

IntroductionsInsights from NuScale PowerStandards WorkshopDOE UpdateGuidance for MSR Research/Test ReactorsSafety Focused Review of I&CLicensing Modernization Project GuidanceOther Needed Guidance ?Regulatory Engagement PlansSiting IssuesPolicy Issues, Future Meetings, Public Discussion 3Outline 4Insights from NuScale PowerNuScale Slides 5Standards Workshop 6DOE UpdateDOE SLIDES 7Guidance for Molten Salt ReactorResearch and Test ReactorsORNL SLIDES Safety Focused ReviewInstrumentation and Control 8I&C SLIDES Licensing Modernization ProjectGuidance DocumentTechnology InclusiveRisk InformedPerformance Based 9ML18120A321 Other Needed Guidance Documents

?10 11Scope and Level of DetailIntegrated Approach Regulatory Engagement Plans12ML18122A293REP SLIDES Siting Issues13NEI SITING SLIDES 14Policy Table, Future Meetings& Public DiscussionComments on Stakeholder Meetings from Michael Keller, Hybrid Power Technologies

Untimely Announcement of Meetings

Public Participation Not Welcome

Request for Presentation to be Placed In Public Record

ML18122A250 15Policy TablePrevious VersionADAMS Acc. No. ML18010A484Updated VersionWorkin Progress 16Future Stakeholder MeetingsTopics ?June 4-5Public Meeting

-Licensing ModernizationJune 14Emergency Planning ZonesFuel Cycle / TransportationEnvironmental ReviewsJuly 26Sept 13Oct 25Dec 13 17ACRS Schedule (tentative)DateCommitteeTopicJune 19SubRIPB GuidanceAug 22SubEP RulemakingOctFullEP RulemakingOct 30SubRIPB Guidance 18Public Comments / Questions NuScaleNonproprietaryCopyright © 2018 NuScale Power, LLCDesign Certification Status and NRC Licensing InsightsMay 3, 2018Steven M. Mirsky, PEManager, Regulatory Affairs 1 PM-0318-59093 NuScale NonproprietaryCopyright © 2018 by NuScale Power, LLC PM-0318-59093Revision: 0Template #: 0000

-20955-F01 R5 2Acknowledgement & DisclaimerThis material is based upon work supported by the Department of Energy under Award Number DE

-NE0000633.This report was prepared as an account of work sponsored by an agency of the United States (U.S.) Government. Neither the U.S. Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the U.S. Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the U.S. Government or any agency thereof.

-20955-F01 R5 3Review Progressing WellPhase 1 was completed on schedule April 16Phase 3 ACRS meetings beginning Chapter 7 and 8 first to Phase 3 (Summer 2018)Expect to see SER with open items month or so before meetingInformed that Chapter 7 has no open itemsFewer questions than prior DCAsExpect <1,500 RAIs>1,000 RAI responses submitted28 of 35 audits completed5 of 14 DCA

-related topical reports (LTRs) approvedTotal cost of review at high end of forecast>115,000 NRC review hoursImproved management by NRC of reviewManagement plans for "key issues"RAI review metricsDCA Review At

-20955-F01 R5 4NuScale Baseline DC Review 2017 2018 2019P5 -ACRS review AdvSER w/no OIs6/23/20Design CertifiedJan 2021Completed DCA 12/31/16 NRC Accepted3/15/17P3 -ACRS review of SER w/OIs8/27/19RulemakingJan 2021P1 -PSER and RAIs4/16/18Total projected duration for NRCreview and approval

-20955-F01 R5 5Key Accomplishments Since DocketingHighly integrated protection system (HIPS) LTR approved in May 2017"Non-1E" LTR approved Dec 2017Applicability of AREVA fuel methods LTR approved Nov 2017 DCA Revision 1 Submitted March 15Revised all 10 parts of the DCAIncorporated 973 change packagesEPZ Methodology LTR Rev 1 Submitted March 12 Added method for determining defense

-20955-F01 R5 6Key Accomplishments (Cont'd)Achieved alignment with NRC on Failed Fuel Fraction0.066% for normal and accident conditions (compared to typical 0.25/1.0%)Based on latest EPRI PWR fuel performance dataBenefits include normal operations shielding calculationsRetaining, for now, current SAR Chapter 15 assumption of 0.32% as operating marginProposal to define "credible" in terms of regulationsSimplifies approach across a number of regulationsNRC appears open to proposal, though likely Policy IssueIf accepted, would result in no credibleevents leading to core damage for NuScaledesign (DBE and BDBE)Retain core damage scenario for EPZ regardless of likelihood NuScale NonproprietaryCopyright © 2018 by NuScale Power, LLC PM-0318-59093Revision: 0Template #: 0000

-20955-F01 R5 7Ensuring Review ProgressesManagement Plans for key issue resolutionMilestones

-what, who and when will be accomplishedGet alignment with NRC at least monthlyRequest for Additional (RAI) Information MetricsTrack internal progress

-update dailyTrack NRC progress

-align monthlyLicensing Audit progressUse of audit plans, periodic meetings, exit meetingsNRC Safety Evaluation Report progressTrack changes in review phase at chapter levelReview drafts when available for proprietary review NuScale NonproprietaryCopyright © 2018 by NuScale Power, LLC PM-0318-59093Revision: 0Template #: 0000

-20955-F01 R5 9RAI Metrics

-20955-F01 R5 10RAI Metrics

-20955-F01 R5 11RAI Metrics

-20955-F01 R5 12EPZ Technical and Policy IssuesTechnicalCore damage frequency cut

-off justification ("Black Swan")Defense-In-DepthNear field source term dispersionExternal natural eventsConsistency with existing LLWR EPZ basisAccounting for analytical uncertaintyCrediting non safety related SSCsMulti-module effects (if applicable)PolicyAlignment with SMR/ONT EPZ rulemakingLast line of defense and public protection considerationPublic perceptionFEMA, state and local government dimensions NuScale NonproprietaryCopyright © 2018 by NuScale Power, LLC PM-0318-59093Revision: 0Template #: 0000

-20955-F01 R5 13 Pre-Application NRC Engagement LLDocument pre

-application agreements to avoid staff and management turnover issues during the reviewKey agreements on DCA level of detail, content of B2 SSCs (e.g. BOP), and means of documenting NRC approvalFocus on Test ProgramPRASimulatorSeismic/StructuralUnique Design Features

-allow time for sufficient communication requires earliest scheduled multiple engagementsRegulatory Gap AnalysisTechnical and Topical Reports (especially methodology)

-20955-F01 R5 14 Pre-Application NRC Engagement LLAttendance at NRC Pre

-ApmeetingsRight NRC and applicant technical and projects staffNRC managementWhen policy

-related, OGCDocument detailed meeting minutes; compare with and provide input to NRC meeting summary NuScale NonproprietaryCopyright © 2018 by NuScale Power, LLC PM-0318-59093Revision: 0Template #: 0000

-20955-F01 R5 15DCA Post-Submittal NRC EngagementRAIs Appropriate regulatory basis and operating experienceAppropriate level of detail for a DCA and an NRC safety findingClarification calls for both technical and regulatory reasonsDocument all NRC teleconsTrack similar RAI responses by previous DCAsElectronic Reading Room (eRR)Supports auditsAllows NRC access to read only, no printing, copying, or savingAuditsFocused scope in audit plan with control during audit executionReasonable schedule with defined documented milestonesAppropriate level of detail for DCA review and safety finding NuScale NonproprietaryCopyright © 2018 by NuScale Power, LLC PM-0318-59093Revision: 0Template #: 0000

-20955-F01 R5 16Licensing Advice to ARWGClosely follow NuScaleRAIs and RAI responsesInvolve NRC in all ongoing and planned test plans and reports (e.g. topical, technical, white papers)Develop a pre

-application engagement plan and vet it with the NRCCommit real resources to NEI initiatives (e.g., ITAAC and physical security)Obtain "high

-fidelity" source documents with international experience on similar technologyObtain NRC agreement on IAEA SSC Classification NuScale NonproprietaryCopyright © 2018 by NuScale Power, LLC PM-0318-59093Revision: 0Template #: 0000

-20955-F01 R5 17SummaryOverall NuScale'sDCA review is going wellNRC is executing its published scheduleGenerally appears to be improved NRC management discipline over review processesFurther improvement in review processes can be achievedClarification of review risks during pre

-20955-F01 R5 186650 SW Redwood Lane, Suite 210Portland, OR 97224971.371.15921100 NE Circle Blvd., Suite 200Corvallis, OR 97330541.360.050011333 WoodglenAve., Suite 205Rockville, MD 20852301.770.0472 2815 ColiseumCentre Dr., Suite 230Charlotte, NC 28217980.349.4804 1933 JadwinAve., Suite 130Richland, WA 99354 1stFloor Portland HouseBressendenPlaceLondon SW1E 5BHUnited Kingdom+44 (0) 2079 321700http://www.nuscalepower.comTwitter: @NuScale_Power Summary of DOE Advanced Reactor ActivitiesNRC Public Meeting on Advanced ReactorsMay 3, 2018Trevor CookManager, Advanced Reactor Licensing ProgramOffice of Nuclear EnergyU.S. Department of Energy MISSION PRIORITIES 2 2010 2020 2030 2040LWR LIFE EXTENSION (60 yrs)USED FUEL STORAGEADVANCED LWR FUELSSMALL MODULAR REACTORSADVANCED REACTORS NUCLEAR HYBRID ENERGYLWR LIFE EXTENSION (80 yrs)SUSTAINABLE FUEL CYCLEGEOLOGIC REPOSITORYTREATVTRRD&D INFRASTRUCTUREDOE-NE MISSION

Advance nuclear power as a resource capable of making major contributions in meeting our Nation's energy supply, environmental and energy security needs

Seek to resolve technical, cost, safety security, and regulatory issues through RD&D

By focusing on the development of advanced nuclear technologies, support the goals of providing domestic sources of secure energy, reducing greenhouse gases, and enhancing national security.Existing FleetAdvanced Reactor PipelineFuel Cycle Infrastructure DOE-NE MISSION AND PRIORITIES TerraPowerMCFRAdvanced Light Water ReactorsFast Reactor Technologies

Demonstrate feasibility of advanced systems and component technologies

Methods and code validation to support design and licensing

Advanced alloy materials qualification for metal

-cooled systemsGas Reactor Technologies

Advanced alloy and graphite materials qualification for high temperature gas-cooled systems

Scaled integral experiments to support design and licensing

TRISO-coated particle fuel development and qualificationMolten Salt Reactor Technologies

Investigate fundamental salt properties

Materials, models, fuels and technologies for salt

-cooled and salt

-fueled reactorsCross-Cutting technologies

Advanced energy conversion

Supercritical Carbon Dioxide (sCO2) Brayton Cycle

Micro reactors for remote defense and commercial applicationsGE HitachiPRISMGA Gas-cooled Fast ReactorADVANCED REACTOR TECHNOLOGIES FOCUS AREAS 3NuScalePWR NEAC Advice:

The need for a VTR was established through a series of independent surveys of the potential U.S. user community (industry, DOE programs) and support from international partners resulting in a NEAC report ("Assessment of Missions and Requirements for a new U.S. Test Reactor" 2/2017); it states that "The Ad Hoc NEAC subcommittee recommends that DOE

-NE proceed immediately with pre

-conceptual planning activities to support a new test reactor(including cost and schedule estimates)."Goals:*3 year R&D effort, along with appropriate reviews and planning, leading to an operational VTR by 2026*VTR would support accelerated development of advanced fuels and materials for U.S. advanced reactor vendors, as well as to provide the capability for testing those fuels and materials to support licensing by the Nuclear Regulatory Commission.

VTR with a high fast neutron flux would revitalize our research infrastructure and remove a critical impediment for U.S. developers of advanced nuclear energy technologies.

Constructed and operated under DOE authority, in close collaborations with NRC.*$35 million in 2017 Omnibus Bill for versatile fast test reactor's R&D activities to achieve CD

-0 in January 2019.VERSATILE TEST REACTOR (VTR)IN SUPPORT OF ADVANCED REACTOR TECHNOLOGIES 4

1.Approach to Design: Conducting a 3 year research & development effort on core design. 2.Reach fast flux of approximately 4.E15 n/cm 2-s, with prototypical spectrum 3.Load factor: as large as possible (maximizedpa/year to > 30 dpa/year)4.Provide flexibility for novel experimental techniques 5.Be capable of running loops representative of typical fast reactors (Candidate Coolants: N a, Lead, LBE, Gas, Molten Salt)

-May be a single location with replaceable loops.6.7.Ability to perform large number of experiments simultaneously 8.Metallic driver fuel (possible options: LEU, Pu, LEU+Pu)5DRAFT REQUIREMENTS/ASSUMPTIONS 4OF VERSATILE TEST REACTOR (VTR)

ORNL is managed by UT-Battelle for the US Department of EnergyORNL is managed by UT-Battelle for the US Department of EnergyNUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power ReactorsOverview of Proposed Revision for Nonpower Molten Salt ReactorsRandy Belles, ORNLGeorge Flanagan, ORNLMarcus Voth, Boston Government ServicesAdvanced Reactor Meeting, May 3, 2018 2Overview of NUREG-1537 Proposal for MSRsDevelopment of nonpower MSR test facilities is under consideration to support the multiple analyses needed for development of full-scale MSRsGenerates a need to look at the applicability of existing licensing guidance to non-power liquid-fueled molten salt reactors (MSRs) Presentation OutlineBackground on NUREG-1537Chapters proposed for revisionHistory of Aqueous Homogeneous Reactor (AHR) Interim Staff Guidance (ISG) MSR issues and challengesSummary of major changes to each chapter 3Overview of NUREG-1537 Proposal for MSRs NUREG-1537 is used by an applicant or licensee of a non-power reactor for a new license, license renewal, or license amendmentCovers all aspects of non-power reactor licensing (issued 1996)No GDCsNo PRAPart 1 describes acceptable format and content of the safety analysis report (SAR) to be submitted to the NRC by an applicant or licenseeCorresponds to RG 1.206/RG 1.70 for commercial power reactorsPart 2 gives criteria to assist NRC staff reviewers in performing comparable, complete, and consistent reviews of licensing applicationsCorresponds to NUREG-0800 for review of LWRs 4Overview of NUREG-1537 Proposal for MSRs NUREG-1537 content is similar to NUREG-0800Table of Contents1 Facility2 Site Characteristics3 Design of SSC4 Reactor Description5 Reactor Coolant Systems6 Engineered Safety Functions7 Instrumentation and Controls8 Electrical Power Systems9 Auxiliary Systems10 Experimental Facilities11 Radiation Protection and Waste Management12 Conduct of Operations13 Accident Analyses14 Technical Specifications15 Financial Qualifications16 Other Licensing Considerations17 Decommissioning18 HEU to LEU Conversions 5Overview of NUREG-1537 Proposal for MSRsMost NUREG-1537 Chapters are applicable as-isTable of Contents1 Facility2 Site Characteristics3 Design of SSC4 Reactor Description5 Reactor Coolant Systems6 Engineered Safety Functions7 Instrumentation and Controls8 Electrical Power Systems9 Auxiliary Systems10 Experimental Facilities11 Radiation Protection and Waste Management12 Conduct of Operations13 Accident Analyses14 Technical Specifications15 Financial Qualifications16 Other Licensing Considerations17 Decommissioning18 HEU to LEU Conversions 6Overview of NUREG-1537 Proposal for MSRsNUREG-considered for revisionChapter 13 subjected to a preliminary gap analysis reviewDetermined that further design-specific accident analysis information is necessary Unfortunately, design-specific information is closely held by the active vendorsAccident analyses for the Molten Salt Reactor Experiment is available and informative, but is not appropriate for all design variationsOpted not to make any recommendations regarding Chapter 13 7Overview of NUREG-1537 Proposal for MSRsProposed MSR revision of NUREG-1537 is based on 2012 AHR Interim Staff GuidanceIn 2010 NRC initiated a multi-laboratory effort headed by BNL, supported by ORNL and ANL, to revise NUREG-1537 in anticipation of an AHR application to produce medical isotopesSeveral chapters (4,5,6,9 and 13) were deemed design specific and were revised by the laboratory team Both volumes 1 and 2 were revisedExtensive revisions were required to address the unique aspects of AHR designs 8Overview of NUREG-1537 Proposal for MSRsReport BNL 94462-2010 was submitted to NRC for consideration as an input for NUREG-1537 ISGNRC used report information as a basis for the NUREG-1537 ISG In 2012, NRC issued an ISG document for NUREG-1537 which contained revisions needed to review AHR submittalsAHRs have several features similar to liquid-fueled MSRs Fuel is in a liquid formReactor vessel forms the first boundary to prevent release of fission productsOff gas systems collect and treat volatile fission products including noble gasesSystems for draining, refilling and polishing the fuel exist in AHRsMSRs have unique aspects not found in AHRs, so it was necessary to revise the ISG to reflect these features 9Overview of NUREG-1537 Proposal for MSRsProposed MSR update introduced issues to be addressedORNL/TM-2018/834Limited distribution as ORNL/SR-2017/313-R1AHR ISG influenced the proposed MSR update to NUREG-1537 10Overview of NUREG-1537 Proposal for MSRsRetained same document format, but this led to some difficultiesCurrent chapter content did not consistently conform to MSR technologyFuelCoolantHeat transferUnique MSR attributes were not coveredArbitrarily inserted system and process discussionsMay need to consider revised organization for a more optimized reviewNo generic MSR designNothing is design-specific; designs protected by NDAsDifferent salts and neutron spectrums to consider 11Overview of NUREG-1537 Proposal for MSRsGeneric MSR definitions are necessaryConsistent system and component referencesHeat transfer loop referencesProposed several fundamental process definitions for discussion:Active Reactor CoreCoatingControl ElementEmergency Cooling SystemFission Product BarrierFuel BarrierFuel System BoundaryHeat Dissipation SystemNeutron ModeratorPrimary Cooling SystemReactor FuelVesselANS 20.2, MSR Standard, will be the ultimate document for definitions 12Overview of NUREG-1537 Proposal for MSRsMSRs have unique reactor control issuesDelayed neutron driftFlowing fuel salt will cause some fraction of delayed neutrons to be born outside the active reactor coreImpact on ability to control the reactorFlow changesFuel composition changesDiscussion chapter 4Control elementsAct through fuel displacement, neutron absorption, neutron reflection, neutron spectral adjustment, or a combination of these methodsSolids, liquids, or gasesSystem discussion chapter 4System cooling chapter 5 or 9 no specific reference except in chapter 4MSRE Control ElementsSource: ORNL-4123 13Overview of NUREG-1537 Proposal for MSRsMSRs are chemistry-based machinesOff gas from fission productsAffects core geometry/density/powerLeads to need for a gas management systemSystem discussion chapter 4; System cooling chapter 9Fuel cleanup or polishing systemOptional depending how designer chooses to address fission product poisonsCoordinates with online fuel additions, salt makeup, and fuel chemistryImpact on fuel chemistry chapter 4 under Nuclear DesignSystem description chapter 5; System cooling chapter 9Fuel salt chemistryNeed to understand the short-term and long-term changes in chemistryFuel Technical SpecificationsImportance chapter 4 under Reactor FuelMSRE Mark 1 Offgas Particle Trap 14Overview of NUREG-1537 Proposal for MSRsMSR Reactor Description and Reactor Coolant Systems are IntertwinedFuel and coolant are a homogenous mixtureNo claddingImportance of fuel salt system boundary integrity Fuel salt heat transportThermal-hydraulics chapter 4System description chapter 5Primary cooling systemSystem description chapter 5Heat Dissipation SystemUltimate heat sinkSystem description chapter 5Active Reactor CoreFuel SaltPrimary Heat ExchangerPrimary Coolant LoopUltimate Heat SinkSecondary Heat Exchanger 15Overview of NUREG-1537 Proposal for MSRsSupport systems must be consideredDrain TanksNeed for maintenance and possibly as an ESF system (MSRE)Consideration for fuel salt and coolant saltSystem discussion chapter 5System cooling chapter 9Waste treatment and storageDescribe process no intention of producing special nuclear material (SNM)Production versus Utilization FacilitySystem discussion chapter 11System cooling chapter 9 16Overview of NUREG-1537 Proposal for MSRsFuel handling presents challenges New and Used FuelCriticality concernsStabilitySolid or liquidSafeguardsReceipt, storage, dissolution, blendingSystem discussion chapter 9System cooling chapter 9ORNL Review 17Overview of NUREG-1537 Proposal for MSRsWrap-up with a brief look at the updated chapters 18Overview of NUREG-1537 Proposal for MSRsThe distinction between Chapters 4 (Reactor Description) and 5 (Reactor Coolant Systems) blurs for MSRs Chapter 4 focus is on heterogeneous fuel elements consisting of fuel rods and fuel cladding acting as the initial fission product barrier Protect the clad (AOOs) and maintain cooling (DBAs)MSRs operate with homogeneous liquid fuel and no cladding Initial fission product barrier shifts out to the fuel salt boundaryMaintain the fuel salt system boundaryControl fuel salt chemistry / redox controlMSR core conditions change over core life with fuel composition changes, fissile material buildup, and poisonsUse of control elementsDelayed neutronsGas management 19Overview of NUREG-1537 Proposal for MSRsThe distinction between Chapters 4 (Reactor Description) and 5 (Reactor Coolant Systems) blurs for MSRs Chapter 5 focus is on the transfer of heat from the heterogeneous fuel elements to the ultimate heat sinkMaintain cooling to assure fission product barrier remains intactThe MSR fuel salt provides initial heat transfer to a coolant salt loopFuel salt cleanup, salt makeup, fuel makeup consideredDrain tank discussion addedFuel salt loopCoolant salt loop (primary cooling loop) 20Overview of NUREG-1537 Proposal for MSRsChapter 6 (ESF) equipment may simply consist of one or more containment structuresContainmentSource: ORNL-TM-728ECCS EquivalentMultiple confinement or containment boundaries might be included for an MSR design depending on the relative location of the gas management system and other cleanup systems DRACS or drain tank could be ESF or analyses may show none needed 21Overview of NUREG-1537 Proposal for MSRsMSR auxiliary systems discussed in Chapter 9 will need to evolve and expand to accommodate MSRsConsider MSR fuel handling and storage of SNM used for reactor fuel (both new and irradiated)Systems (tanks, valves, pumps, instrumentation, controls), processes (chemical blending, SNM transfers, waste storage, preparation for shipment), criticality monitoring, vaults, shielding, and contamination controlQuantity of byproduct, source, and SNM differ from the use of heterogeneous fuel elementsAn effective means should be defined for limiting the SNM at the reactor site to establish an envelope used for safety and security analysesThe mission of a test MSR facility should be evaluated to determine limits on the quantity of byproduct materials created by experiments and routine operationAdditional cooling systems should be described:Gas management systemDrain tanksOther design-specific systems 22Overview of NUREG-1537 Proposal for MSRsWaste handling needs to be considered in Chapters 9 (Auxiliary Systems) and 11 (Waste Management)Once operated, MSRs will contain gaseous, soluble and non-soluble fission products in the fuel salt Some MSR designers will opt to remove gaseous and/or soluble fission products from the fuel salt Without careful consideration in the SAR, the separation of fission products could possibly be viewed as a colocated SNM fuel cycle facility This could lead to a complex licensing scenario10 CFR 50 utilization facility10 CFR 50 production facility (AHR ISG guidance)10 CFR 70 fuel cycle facilityWhat is the process? What is the intent?Offgas Piping Near Pump and Overflow TankSource: ORNL-TM-3039 23Overview of NUREG-1537 Proposal for MSRsSummaryNUREG-1537 documents a performance-based approach for establishing design criteria and ensuring they are metBased on more than 50 years of experience with commercial and nonpower reactors using heterogeneous fuelAdaptations for MSR technology must consider review processes that ensure the adequacy of proposed designs while recognizing the reduced operating experience with MSR designsProposed update provides clarity for performance-based MSR review by removing some of the ambiguity created when transitioning from discussion of heterogeneous fuels to homogeneous fuelsProposed revisions will support DOE effort to assist MSR vendors with test facility licensingReduce regulatory uncertainty Instrumentation and Controls:

Safety-Focused Review InitiativeAdvanced Reactors Stakeholders MeetingMay 3, 2018Ian Jung, ChiefInstrumentation, Controls and Electronics Engineering BranchDivision of Engineering and InfrastructureOffice of New Reactors 1

Credit: br.depositphos.com 2The staff is transforming I&C reviewsI&C: Instrumentation and controls The I&C regulatory infrastructure is not optimal for future designsStandard Review PlanInterim Staff GuidanceRegulatory GuidesStandardsNUREGsIndustry DocumentsRegulationsGeneric CommunicationsWhat is the safety issue?

3*Large light water reactors

Increased complexity and volume*Opportunities for safety focus, risk-informing, and simplicity The staff innovated its review approach for SMRs

Lessons learned from reviews of other large light water designs

Design-Specific Review Standard (DSRS) Chapter 7

-"Grassroots"

-SRM-SECY-11-0024-New -NuScale-Generically applicable

-Mindset/cultural change

-Cooperation with applicantsAP1000ESBWRU.S.EPR US-APWRABWR 4SRM: Staff Requirements Memorandum DSRS Chapter 7 is simpler and more safety-focused*Emphasis on fundamental design principles

Risk-informed/safety focused review

Removed inapplicable items and duplications

Restructured staff guidance in NUREG-0800*Lessons learned applied 5Simplicity A1 A2B1B2 The new approach has been a huge success for NuScale*Highly effective

-Demonstrated principles

-Simplicity

-Easily understandable/explainable

Highly efficient

-95% reduction of RAIs

-Significant reduction of staff hours and below the estimated*Significantly ahead of schedule

Applicant doing its part

-Cooperation with staff

-Cultural/mindset change 6

The Commission directed the staff to "modernize"

Integrated Action Plan

-SRM-SECY-16-0070*Regulatory infrastructure

-"-simpler, streamlined, and agile- for new and advanced reactors."

-Principles/attributes, e.g.,*Performance

-based*Technology

-neutral*Consistent, durable, predictable, scalable

Unambiguous

Safe and secure 7

The staff is getting ready for future designs *Additional lessons learned and new opportunities

New initiative started

-Create new, improved guidance for future design reviews in a timely manner

-Building on DSRS

Close coordination

-Advanced reactors

-I&C modernization

-Innovation and transformation at the NRC DSRS"DRS""ARS"Near-termLonger-Term 8 The staff plans to issue "DRS" in time for advanced reactors

Lessons learned from NuScaleand APR1400

More:-Risk-informed and performance

-based-Safety focus

-Technology

-neutral-Principles

-based-Agile/flexible

-Efficient/predictable

Balancing with defense

-in-depth strategy 1.What can go wrong?2.How likely is it?3.What are the consequences?

9 Success is ensured when-

Success factors-Cultural-Initiative

-Applicant cultural/mindset change*Fundamentals

-Regulatory

-Technical*Principles

-Safety engineering

-Safety design 10If you do what you've always done, you will get what you've always gotten.

-Tony Robbins In summary

The staff initiated an innovative, safety

-focused approach for I&C reviews applying lessons learned

The approach has been a huge success for NuScale*The staff is further transforming I&C reviews for future designs

The staff and stakeholders must work closely 11

Kati AustgenSr. Project Manager, New Plant, SMR & Advanced ReactorsMay 3, 2018ARRTF / SMRWG FEEDBACK ONSITING CONSIDERATIONS RELATED TO POPULATION

RG 4.7 SHOULD BE UPDATED

Important to enable expected benefit of EP rulemaking o Scale with source term, like emergency planning zones oAdditional time to potential release oMuch lower probability of such a release

RG 4.7 population density guidance of less than 500 persons per square mile out to 20 miles could be adjusted to scalable guidance based on source term of SMRs and non

-LWRs.*Smaller source term oScale up number of persons per square mile oScale down the 20 mile radius for population densitySCALE WITH SOURCE TERM

RG 4.7 population density guidance of less than 500 persons per square mile out to 20 miles could be adjusted to scalable guidance based on additional time to potential release for SMRs and non

-LWRs.*Longer time to potential release oScale up number of persons per square mile oScale down the 20 mile radius for population densityTIME TO POTENTIAL RELEASE

RG 4.7 population density guidance of less than 500 persons per square mile out to 20 miles could be adjusted to scalable guidance based on the much lower probability of release for some SMRs and non-LWRs.*Much lower probability of release oScale up number of persons per square mile oScale down the 20 mile radius for population densityPROBABILITY OF RELEASE© 2018 NEI.All rights reserved.

RECOMMEND RG 4.7 UPDATE

Important to enable expected benefit of EP rulemaking

Opportunities for scalability of population density guidance*Defense-in-depth achieved in design development

We are gathering resources and assessing timing of next steps

1 May 2018 UPDATE: Policy Issues

- Non-Light Water Reactors Policy Issues

- Non-Light Water Reactors Issue as presented on web page & previous meetings

- raised questions related to applicability for LWR SMRs and non

-LWRs Updated Note/Status to specifically address activities related to non

-LWRs Issues with Ongoing Activities for non-LWRs License for Prototype Reactors NRC staff drafting white paper Action Complete Discussion incorporated (Enclosure 1) into NRC's "A Regulatory Review Roadmap for Non

-Light Water Reactors" (ML17312B567

) Appropriate Source Term, Dose Calculations, and Siting SECY-16-0012, "Accident Source Terms and Siting for Small Modular Reactors and Non

-Light Water Reactors,"

Parts of this topic related to Licensing Modernization Project (LMP) and other activities. A draft white paper (ML17333B158

) related to siting in relation to population centers and population density discussed during December 14, 2017 and May 3, 2018 stakeholder meeting

s. NEXT STEPS ?

Key Component and System Design Issues Related to LMP and white paper on SSC safety classification (ML17290A463

) and RIPB guidance document (report with staff comments

- ML18120A321)

Offsite Emergency Planning (EP) Requirements SECY-15-0077 Drafting Regulatory Basis Regulatory Basis (ML17206A265) completed for the emergency preparedness rulemaking with regard to small modular reactors and other new technologies. NRC staff preparing proposed rule and related guidance with planning milestone of providing to Commission by October 2018.

Agenda item for June 14 th stakeholder meeting Insurance and Liability Evaluating for periodic report to Congress on Price

-Anderson Act Issue discussed during November 2, 2017 stakeholder meeting, including presentation from American Nuclear Insurers. Under review No short-term actions by NEI Advanced Reactor Working Group (ARWG) or other stakeholders; 2 May 2018 UPDATE: Policy Issues

- Non-Light Water Reactors NRC staff to prepare Commission paper for report to Congress and engage stakeholders during its development

. Use of Probabilistic Risk Assessment in the Licensing Process SRP Revisions (safety focused review)

This topic is related to LMP and white papers/guidance (ML17158B543

). Also related to NRC participation in development of non

-LWR PRA Standard (ASME/ANS)

- see NRC response to NEI white paper (ML17233A187

) and RIPB guidance document (report with staff comments - ML18120A321)

Implementation of Defense

-In-Depth (DiD) Philosophy for Advanced Reactors SECY-15-0168 (part of licensing framework)

This topic is related to LMP and white papers/guidance (ML17354B174). NRC staff preparing comments and questions and RIPB guidance document (report with staff comments

- ML18120A321)

Security and Safeguards Requirements for SMRs NRC White Paper Current topic of interactions between NRC staff and stakeholders in context of NRC white paper (ML17333A524) and discussions during public meeting on December 13, 2017 (ML17354B266

). NRC staff preparing Commission paper with expected completion in early mid 201 8 NRC security design considerations issued for public comment (NRC-2017-0073) and currently on hold. Licensing Basis Event Selection Ongoing discussions This topic is related to LMP and submitted white paper (ML17104A254

) and related NRC staff comments/questions (ML17145A531

) and RIPB guidance document (report with staff comments

- ML18120A321)

3 May 2018 UPDATE: Policy Issues

- Non-Light Water Reactors Fuel qualification, materials qualification Issues vary by fuel type and reactor technology Ongoing discussions with advanced reactor technology groups and developers. This topic was discussed during August 3 rd stakeholder meeting (ML17229B317; slides ML17220A315

) Update ? Fuel cycle facilities (front end)

Increased enrichments Ongoing discussions NEI provided a draft white paper on issues related to industry acquisition and use of higher assay low enriched uranium (HALEU) and fuel cycle facilities needed to support advanced reactors (ML17341A604

) The specific issues identified in the NEI white paper as needing NRC support are listed below along with current staff activities and/or planned interactions

4 May 2018 UPDATE: Policy Issues

- Non-Light Water Reactors (1) Finalization of the Material Control and Accountability (MC&A) rulemaking and associated regulatory guidance document (NUREG-2159) for Category II Special Nuclear Material (SNM). See Supplement to Fuel Cycle Program Integrated Schedule

- December 19, 2017.(ML17355A040) for NRC status and NRC webpage Planned Rulemaking Activities

- Rules. (2) Development of guidance for implementing a Physical Security plan at a Category II SNM facility. This will require that the NRC and DOE to work together to finalize a consistent approach for addressing material attractiveness. Completing this work will enable determination of the need to continue with security rulemaking (10 CFR Part 73) and development of associated implementation guidance.

Staff activities currently on hold pending further Commission direction. See Supplement to Fuel Cycle Program Integrated Schedule

- December 19, 2017.(ML17355A040) and NRC webpage s "Security-Related Rulemaking to Update 10 CFR Parts 73 and 26

" for NRC status and Planned Rulemaking Activities

- Rules. 3) Collaboration with DOE and other involved parties on development of: (a) criticality benchmark data and NRC agrees that additional criticality benchmark data could facilitate criticality reviews. Decision on what criticality experiments to conduct is seen as an industry and DOE decision. Industry proposed design defines the data needs to support facility or transportation package design, DOE capability define the criticality experiments that can be conducted. NRC will collaborative with industry and DOE.

(b) HALEU shipping package and transporter certifications.

NRC is prepared to review industry submitted shipping package and transporter applications.

5 May 2018 UPDATE: Policy Issues

- Non-Light Water Reactors New Policy Issues

- Warranting Immediate Actions?

6 May 2018 UPDATE: Policy Issues

- Non-Light Water Reactors Policy Issues

- Non-Light Water Reactors Issue as presented on web page &

previous meetings

- raised questions related to applicability for LWR SMRs and non

-LWRs Updated Note/Status to specifically address activities related to non

-LWRs Open Issues for non

-LWRs but no current activities Annual Fees Final Rule (May 2016)

- Annual fees scalable based on licensed thermal power rating, applicable only to LWR SMRs Part 171 definitions:

Small modular reactor (SMR) for the purposes of calculating fees, means the class of light-water power reactors having a licensed thermal power rating less than or equal to 1,000 MWt per module. This rating is based on the thermal power equivalent of a light

-water SMR with an electrical power generating capacity of 300 MWe or less per module.

Expect that changes will be needed to address non-LWR s Manufacturing License Requirements Pending determination of possible interest from non-LWR developers SECY-14-0095 states no interest in obtaining a manufacturing license from near

-term SMR applicants was expressed.

Questions raised by stakeholders regarding possible approaches for non

-LWRs given desire to use manufacturing/modular approaches Industrial Facilities Using Nuclear

-Generated Process Heat SECY-11-0112 (assess as necessary)

Expect that additional guidance will be needed to address non

-LWRs and possible process heat applications (also tied to siting and EP issues)

Fuel cycle facilities (front in)

Ongoing discussions One issue (increased enrichments) has been moved to ongoing activities portion of the table Waste Issues (back end)

Ongoing discussions Generally deferred to NRC mid-term IAP activities pending specific needs/timeline for technology or design

-specific licensing and deployment.

7 May 2018 UPDATE: Policy Issues

- Non-Light Water Reactors New Policy Issues

- Not Warranting Immediate Actions?

8 May 2018 UPDATE: Policy Issues

- Non-Light Water Reactors Policy Issues

- Non-Light Water Reactors Issue as presented on web page & previous meetings

- raised questions related to applicability for LWR SMRs and non

-LWRs Updated Note/Status to specifically address activities related to non

-LWRs Issues with no current plans to undertake activities (resolved or need input from stakeholders)

License Structure for Multi

-Module Facilities SECY-11-0079 Staff committed to provide Commission with a specific proposal using an actual SMR application for insights, status updated in SECY 0095 Operator Staffing for Small or Multi

-Module Facilities SECY-11-0098 (flexibility w/ existing guidance)

Long term solution to possibly include changes to NRC regulations (rulemaking), status updated in SECY-14-0095 Operational Programs for Small or Multi-Module Facilities SECY-11-0112 (flexibility w/ existing guidance)

Confirmed in SECY 0095 Installation of Reactor Modules During Operation of Multi

-Module Facilities SECY-11-0112 (existing guidance)

Confirmed in SECY 0095 Decommissioning Funding Assurance SECY-11-0181 (Site-specific exemptions)

Long term solution to possibly include changes to NRC regulations (rulemaking), status updated in SECY-14-0095 Aircraft impact assessments Final rule ( June 2009)

Confirmed in SECY 0095

ML18130A688

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