ML21195A209

July 15, 2021 Final Slides Advanced Reactor Stakeholder Public Meeting

ML21195A209
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Issue date:	07/15/2021
From:	O'Banion M Office of Nuclear Reactor Regulation
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O'Banion M
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Download: ML21195A209 (146)

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Advanced Reactor Stakeholder Public Meeting July 15, 2021 Microsoft Teams Meeting Bridgeline: 301-576-2978 Conference ID: 446 067 450#

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Time Agenda Speaker 10:00 - 10:20 am Opening Remarks - NRC Advanced Reactor Public Website Updates NRC 10:20 - 10:45 am Advanced Reactor Generic Environmental Impact Statement (GEIS) Update NRC/NMSS 10:45 -11:15 am Annual Fees for Non-Light-Water Reactors NRC/OCFO 11:15 am - 12:00 pm Technology-Inclusive Content of Application Project (TICAP) and Advanced NRR/DANU Reactor Content of Application Project (ARCAP) Updates 12:00 - 1:00 pm Break All 1:00 - 1:30 pm Applicability of Regulations to Non-Light-Water Reactors NRR/DANU 1:30 - 2:30 pm ANL Report for Non-Light-Water Reactor Vessel Cooling Systems NRR/DANU and ANL 2:30 - 3:30 pm Best Practices for Conducting Part 50 Reviews and Lessons Learned from the NRR/DANU SHINE Application Reviews 3:30 - 3:45 pm Concluding Remarks and Future Meeting Planning NRC/All Page 2 of 146

Advanced Reactor Integrated Schedule of Activities https://www.nrc.gov/reactors/new-reactors/advanced/details#advSumISRA Page 3 of 146

Updates to the NRC Public Webpage on Pre-application Activities Advanced Reactor Licensing Branch Division of Advanced Reactors and Non-Power Production and Utilization Facilities U.S. Nuclear Regulatory Commission Page 4 of 146

Updated Webpage on Pre-application Activities

• The NRC staff has updated public webpages on advanced reactors:

https://www.nrc.gov/reactors/new-reactors/advanced.html

• New information on pre-application activities https://www.nrc.gov/reactors/new-reactors/advanced/ongoing-licensing-activities/pre-application-activities.html

- Design

- Activities

- NRC project manager

• Draft White Paper on Pre-Application Engagement Draft Pre-application Engagement to Optimize Advanced Reactors Application Reviews 2

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Questions?

Contact me by e-mail at Mallecia.Sutton@nrc.gov or by telephone at (301) 415-0673 3

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Advanced Reactor Generic Environmental Impact Statement and Rulemaking Laura Willingham, Environmental Project Manager Environmental Center of Expertise, U.S. NRC Dan Barnhurst, Hydrologist Environmental Center of Expertise, U.S. NRC Page 7 of 146

Current Status

• On September 21, 2020, the Commission approved development of the ANR GEIS and directed the staff to codify the results through rulemaking (SRM-SECY-20-0020, ADAMS Accession No. ML20265A112).

• Scoping Summary Report issued on September 25, 2020 (ADAMS Accession No. ML20260H180).

• Staff has completed writing sections of the draft ANR GEIS.

• Staff is developing the proposed rule package, which includes: proposed rule language, revisions to guidance documents, regulatory analysis, and other related rulemaking documents.

• Proposed rule package due to the Commission in November 2021.

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Key Framework

• The ANR GEIS uses a technology neutral, performance-based approach that utilizes a plant and site parameter envelope (PPE/SPE).

• Most environmental issues are decoupled from reactor power level.

• The PPE/SPE values and assumptions were developed to bound a maximum number of designs and sites.

• Category 1 issues are environmental issues that are generically resolved as SMALL; while Category 2 issues impacts cannot be determined and are not analyzed in the ANR GEIS because they are project-specific.

• It is anticipated that an applicant for any advanced reactor would be able to use the ANR GEIS (LWRs, Non-LWRs, SMRs, fusion reactors).

• The ANR GEIS evaluates both construction and operation for 16 resource areas such as land use, visual, ecology, air quality, water use, socioeconomics, noise, decommissioning, fuel cycle, transportation of fuel, and continued storage.

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Implementation

• ANR applicants may use GEIS findings in the Environmental Report provided:

• reactor and site meet the plant and site parameter envelope (PPE/SPE) values and assumptions used in the GEIS, and

• there is no new and significant information between the time the GEIS is finalized and when the applicant submits their application.

• NRC Staff would:

• verify the PPE/SPE demonstration for Category 1 issues,

• audit the applicants new and significant process,

• produce a Supplemental EIS that focuses on Category 2 issues and issues that could not meet the PPE/SPE values and assumptions while incorporating the demonstrated ANR GEIS findings.

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PPE/SPE Values and Assumptions

• The PPE and SPE values and assumptions were developed by an interdisciplinary team of Subject Matter Experts assigned to prepare the GEIS.

The SMEs developed the values and assumptions based on one or more of the following:

• regulatory limits and permitting requirements relevant to the resource as established by Federal, State, or local agencies;

• relevant information obtained from other NRC GEISs, including the License Renewal GEIS and the Continued Storage GEIS;

• empirical knowledge gained from conducting evaluations and analyses for past new reactor EISs;

• values and assumptions derived from other documents applying a PPE/SPE approach (such as the National Reactor Innovation Center PPE Report); and

• subject matter expertise and/or development of calculations and formulas based upon education and experience with the resource.

• PPE and SPE values and assumptions were set broadly enough to make the GEIS a useful licensing tool, while still ensuring that project-specific analyses evaluate and document significant environmental impacts for the public and decision-makers and ensure that NRC's NEPA requirements (and related laws, rules, and regulations) are met.

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PPE/SPE Values and Assumptions PPE/SPE Values and Assumptions Table includes parameters applicable to the resource area issues can be found at ML21189A176.

DRAFT - PRELIMINARY TEXT Parameter Values and Assumptions Basis/Methodology Cooling Towers 1. No natural draft cooling towers Various past new reactor EISs indicate that natural draft cooling towers are tall structures

2. Would be equipped with drift eliminators over 200 ft in height that may be visible from

3. Makeup water would be fresh (salinity less than substantial distances and from which salt drift 1 ppt) and fogging may affect substantial areas of offsite land.

Other Cooling 1. No once-through cooling Once-through cooling systems have a Features substantial potential for significant impacts on

2. No new cooling ponds aquatic biota from entrainment and

3. No new reservoirs impingement and are essentially not possible

4. No spray irrigation ponds due to Section 316(b) of the Clean Water Act (33 U.S.C. § 1326-TN4823). Operation of cooling ponds can have potentially significant effects on aquatic and terrestrial biota. Building reservoirs can affect large areas of aquatic and terrestrial habitats, including sensitive wetland, floodplain, and riparian habitats.

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Environmental Issues

• A complete list of Environmental Issues for Each Resource Area are in the background slides.

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Category 2 Issues

• Staff determined 19 resource area issues require a site or project specific analysis.

Surface Water Quality Degradation Due to Chemical and Thermal Discharges (Operation)

Terrestrial and Aquatic Endangered Species and Habitats (Construction and Operation)

Aquatic Thermal Impacts on Aquatic Biota (Operation)

Other Effects of Cooling-water Discharges on Aquatic Biota (Operation)

Historic and Cultural Resources (Construction and Operation)

Severe Accidents (Operation)

Environmental Justice (Construction and Operation)

Cross Cutting Issues- Climate Change and Cumulative Non-Resource Related Issues Purpose and Need Need for Power Site, Energy and System Design Alternatives 8

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Air Quality Example

• Emissions of Criteria Pollutants and Dust During Construction PPE/SPE values and assumptions The site size is 100 ac or less.

The permanent footprint of disturbance is 30 ac or less of vegetated land and the temporary footprint of disturbance is an additional 20 ac or less of vegetated land.

New offsite ROWs for transmission lines, pipelines, or access roads would be no longer than 1 mi and have a maximum ROW width of 100 ft.

Criteria pollutants emitted from vehicles and standby power equipment during construction are less than Clean Air Act de minimis levels set by the EPA if the site is located in a nonattainment or maintenance area, or the site is located in an attainment area.

The site is not located within 1 mi of a mandatory Class I Federal area where visibility is an important value.

The level of service determination for affected roadways does not change.

Mitigation necessary to rely on the generic analysis includes implementation of BMPs for dust control.

Compliance with air permits under State and Federal laws that address the impact of air emissions during construction.

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Fuel Cycle Example

• Summary of PPE values and assumptions Table S-3 is expected to bound the impacts for ANR fuels, because of changes since WASH-1248, including:

Increasing use of in situ leach uranium mining Current light-water reactors are using nuclear fuel more efficiently Less reliance on coal-fired electrical generation plants Transitioning of U.S. uranium enrichment technology from gaseous diffusion to gas centrifugation Reprocessing capacity up to 900 MTU/yr Waste and spent fuel inventories, as well as their associated certified spent fuel shipping and storage containers, are not significantly different from NUREG-2157 Must satisfy the regulatory requirements of 10 CFR Parts 40, 70, 71, and 73 10 Page 16 of 146

Regulatory Guide 4.2 Revisions

• Regulatory Guide 4.2 provides guidance to applicants on the preparation of environmental reports Guidance for ANR applicants mostly contained in Appendix C of RG 4.2.

General guidance for ERs referencing the ANR GEIS Additional guidance for ANR applications Demonstration method of PPE/SPE values and assumptions If PPE/SPE value or assumption not met, then follow guidance in RG 4.2 Main Body 11 Page 17 of 146

Regulatory Guide 4.2 - Air Quality Demonstration

• The site size is 100 ac or less.

Document site acreage and include a scaled map or drawing outlining the site boundaries. Demonstrate that the site is large enough to accommodate the proposed reactor and supporting facilities, the exclusion area as defined in 10 CFR Part 100, and any lands (other than offsite ROWs) permanently or temporarily needed for construction and operation of the proposed reactor and supporting facilities.

• Criteria pollutants emitted from vehicles and standby power equipment during construction are less than Clean Air Act de minimis levels set by the EPA if the site is located in a nonattainment or maintenance area, or the site is located in an attainment area.

Provide the attainment status in the region for all the criteria pollutants. If the proposed project is in an attainment area, then the applicant does not need to provide estimates of criteria pollutants emitted for the project. Applicants should provide an applicability analysis that contains the estimates of potential emissions of criteria pollutants to demonstrate emissions would be below de minimis level thresholds provided in 40 CFR 93.153(b) for non-attainment & maintenance areas.

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Regulatory Guide 4.2 - Fuel Cycle Demonstration

• Verify the following:

Use of in situ uranium recovery Use of gas centrifuges for enrichment Anticipated levels of fuel burnup Less reliance on coal fired electrical generation plants Planned reprocessing capacity less than or equal to 900 MTU/yr Waste and spent fuel inventories, as well as their associated certified spent fuel shipping and storage containers, are not significantly different from NUREG-2157 Meet 10 CFR Parts 40, 50, 70, 71, 72, and 73

• If not bounded by the GEIS, provide information PNNL-29367 Rev. 2, Non-LWR Fuel Cycle Environmental Data (ML20267A217) 13 Page 19 of 146

Rulemaking Schedule November

• Proposed rule submitted to Commission 2021

• Proposed rule publication for 60-day May 2022 (estimated) comment period May 2023

• Final rule submitted to Commission (estimated)

Jan 2024

• Final rule publication (estimated) 14 Page 20 of 146

Questions?

15 Page 21 of 146

Background Slides 16 Page 22 of 146

Environmental Issues DRAFT - PRELIMINARY TEXT Issue Category Land Use Impacts Construction Onsite Land Use 1 Offsite Land Use 1 Impacts to Prime and Unique Farmland 1 Coastal Zone and Compliance with the Coastal Zone Management Act 1 Operation Onsite Land Use 1 Offsite Land Use 1 Visual Impacts Construction Visual Impacts in Site and Vicinity 1 Visual Impacts from Transmission Lines 1 Operation Visual Impacts During Operations 1 Air Quality Impacts Construction Emissions of Criteria Pollutants and Dust During Construction 1 Greenhouse Gas Emissions During Construction 1 Operation Emissions of Criteria and Hazardous Air Pollutants during Operation 1 Greenhouse Gas Emissions During Operation 1 Cooling System Emissions 1 Emissions of Ozone and NOx during Transmission Line Operation 1 17 Page 23 of 146

Environmental Issues (Contd)

DRAFT - PRELIMINARY TEXT Issue Category Water Resource Impacts Construction Surface Water Use Conflicts during Construction 1 Groundwater Use Conflicts due to Excavation Dewatering 1 Groundwater Use Conflicts due to Construction-Related Groundwater Withdrawals 1 Water Quality Degradation due to Construction-Related Discharges 1 Water Quality Degradation due to Inadvertent Spills during Construction 1 Water Quality Degradation due to Groundwater Withdrawal 1 Water Quality Degradation due to Offshore or In-Water Construction Activities 1 Water Use Conflict Due to Plant Municipal Water Demand 1 Degradation of Water Quality from Plant Effluent Discharges to Municipal Systems 1 Operation Surface Water Use Conflicts during Operation due to Water Withdrawal from Flowing Water Bodies 1 Surface Water Use Conflicts during Operation due to Water Withdrawal from Non-flowing Water Bodies 1 Groundwater Use Conflicts Due to Building Foundation Dewatering 1 Groundwater Use Conflicts Due to Groundwater Withdrawals for Plant Uses 1 Surface Water Quality Degradation Due to Physical Effects from Operation of Intake and Discharge Structures 1 Surface Water Quality Degradation Due to Changes in Salinity Gradients Resulting from Withdrawals 1 Surface Water Quality Degradation Due to Chemical and Thermal Discharges 2 Groundwater Quality Degradation Due to Plant Discharges 1 Water Quality Degradation due to Inadvertent Spills and Leaks during Operation 1 Water Quality Degradation due to Groundwater Withdrawals 1 Water Use Conflict from Plant Municipal Water Demand 1 Degradation of Water Quality from Plant Effluent Discharges to Municipal Systems 1 18 Page 24 of 146

Environmental Issues (Contd)

DRAFT - PRELIMINARY TEXT Issue Category Terrestrial Ecology Impacts Construction Permanent and Temporary Loss, Conversion, Fragmentation, and Degradation of Habitats 1 Permanent and Temporary Loss and Degradation of Wetlands 1 Effects of Building Noise on Wildlife 1 Effects of Vehicular Collisions on Wildlife 1 Bird Collisions and Injury from Structures and Transmission Lines 1 Important Species and Habitats - Resources Regulated under the Endangered Species Act of 1973 2 Important Species and Habitats - Other Important Species and Habitats 1 Operation Permanent and Temporary Loss or Disturbance of Habitats 1 Effects of Operational Noise on Wildlife 1 Effects of Vehicular Collisions on Wildlife 1 Exposure of Terrestrial Organisms to Radionuclides 1 Cooling Tower Operational Impacts on Vegetation 1 Bird Collisions and Injury from Structures and Transmission Lines 1 Bird Electrocutions from Transmission Lines 1 Water Use Conflicts with Terrestrial Resources 1 Effects of Transmission Line ROW Management on Terrestrial Resources 1 Effects of Electromagnetic Fields on Flora and Fauna 1 Important Species and Habitats - Resources Regulated under the ESA of 1973 2 Important Species and Habitats - Other Important Species and Habitats 1 19 Page 25 of 146

Environmental Issues (Contd)

DRAFT - PRELIMINARY TEXT Issue Category Aquatic Ecology Impacts Construction Runoff and sedimentation from construction areas 1 Dredging and filling aquatic habitats to build intake and discharge structures 1 Building transmission lines, pipelines, and access roads across surface water bodies 1 Important Species and Habitats - Resources Regulated under the ESA and Magnuson-Stevens Fishery 2 Conservation and Management Act Important species and habitats - Other Important Species and Habitats 1 Operation Stormwater runoff 1 Exposure of aquatic organisms to radionuclides 1 Effects of refurbishment on aquatic biota 1 Effects of maintenance dredging on aquatic biota 1 Impacts of transmission line ROW management on aquatic resources 1 Impingement and entrainment of aquatic organisms 1 Thermal impacts on aquatic biota 2 Other effects of cooling-water discharges on aquatic biota 2 Water use conflicts with aquatic resources 1 Important Species and Habitats - Resources Regulated under the ESA and Magnuson-Stevens Act 2 Important species and habitats - Other Important Species and Habitats 1 20 Page 26 of 146

Environmental Issues (Contd)

DRAFT - PRELIMINARY TEXT Issue Category Historic and Cultural Resources Impacts Construction Construction impacts on historic and cultural resources 2 Operation Operation impacts on historic and cultural resources 2 Radiological Environment Impacts Construction Radiological dose to construction workers 1 Operation Occupational doses to workers 1 Maximally exposed individual annual doses 1 Total population annual doses 1 Nonhuman biota doses 1 Nonradiological Environment Impacts Construction Building impacts of chemical, biological, and physical nonradiological hazards 1 Building impacts of Electromagnetic Fields N/A Operation Operation impacts of chemical, biological, and physical nonradiological hazards 1 Operation impacts of Electromagnetic Fields N/A Noise Impacts Construction Construction-related noise 1 Operation Operation-related noise 1 21 Page 27 of 146

Environmental Issues (Contd)

DRAFT - PRELIMINARY TEXT Issue Category Radiological Waste Management Impacts Operation Low-level radioactive waste 1 Onsite spent nuclear fuel management 1 Mixed waste 1 Nonradiological Waste Management Impacts Construction Construction nonradiological waste 1 Operation Operation nonradiological waste 1 Postulated Accidents Impacts Operation Design Basis Accidents Involving Radiological Releases 1 Accidents Involving Releases of Hazardous Chemicals 1 Severe Accidents 2 Severe Accident Mitigation Design Alternatives 1 Acts of Terrorism 1 Socioeconomics Impacts Construction Community Services and Infrastructure 1 Transportation Systems and Traffic 1 Economic Impacts 1 Tax Revenue Impacts 1 Operation Community Services and Infrastructure 1 Transportation Systems and Traffic 1 Economic Impacts 1 Tax Revenue Impacts 1 22 Page 28 of 146

Environmental Issues (Contd)

DRAFT - PRELIMINARY TEXT Issue Category Environmental Justice Impacts Construction Construction Environmental Justice Impacts 2 Operation Operation Environmental Justice Impacts 2 Fuel Cycle Impacts Operation Uranium Recovery 1 Uranium Conversion 1 Enrichment 1 Fuel Fabrication(a) 1 Reprocessing 1 Storage and Disposal of Radiological Wastes 1 Transportation of Fuel and Waste Impacts Operation Transportation of Unirradiated ANR Fuel 1 Transportation of Radioactive Waste from ANRs 1 Transportation of Irradiated Fuel from ANRs 1 Decommissioning Impacts Decommissioning 1 Issues Applying Across All Resources Climate Change 2 Cumulative Impacts 2 Non-Resource Related Issues Purpose and Need 2 Need for Power/Project 2 Site Alternatives 2 Energy Alternatives 2 System Design Alternatives 2 ROW = right-of-way.

(a) Fuel fabrication impacts for metal fuel and liquid fueled molten salt are not included in the staffs generic analysis 23 Page 29 of 146

Annual Fees for Non-Light-Water Reactors July 15, 2021 Page 30 of 146

Annual Fee Alternatives for Non-LWRs including Micro-reactors

• The Alternatives described herein were developed at the NRC staff level participating in a multi-discipline work group with stakeholder input obtained through public meetings

• The Alternatives have not been presented to the Commission for review, comment, or decision Page 31 of 146

Annual Fee Alternatives for Non-LWRs including Micro-reactors

• Alternative 1:

- Change the SMR definition to include non-LWRs

- Micro reactors pay the minimum SMR fee if the bundled units have a total licensed thermal power rating 250 MWt

- The bundled units concept would apply

• Alternative 2:

- Change the SMR definition to include non-LWRs

- Include a separate minimum fee in the SMR variable fee structure for power reactors 20 MWt

- The bundled units concept would apply Page 32 of 146

Annual Fee Alternatives for Non-LWRs including Micro-reactors

• Alternative 3:

- Change the SMR definition to include non-LWRs and to exclude power reactors 20 MWt

- Add definition of micro-reactors 20 MWt for the purpose of annual fees

- Include a set fee for power reactors 20 MWt

- The bundled units concept would not apply to power reactors 20 MWt

• Alternative 4:

- Change the SMR definition to include non-LWRs

- Include a separate minimum fee in the SMR variable fee structure for power reactors 20 MWt

- Apply a revised variable fee formula to the >20 MWt 250 MWt thermal power level

- The bundled units concept would apply Page 33 of 146

Annual Fee Alternative 1 Bundled Unit Thermal Power Rating Minimum Fee

• Variable Fee

• Maximum Fee First Bundled Unit - cumulative MWt 0 MWt 250 MWt $158.5K (a) N/A N/A

>250 MWt 2,000 MWt $158.5K (a) Variable Rate 2 (c) N/A

>2,000 MWt 4,500 MWt N/A N/A $4,986K (b)

Additional Bundled Units - cumulative MWt (above the first bundled unit of 4,500 MWt) 0 MWt 2,000 MWt N/A Variable Rate 3 (d) N/A

>2,000 MWt 4,500 MWt N/A N/A $4,986K (b)

• FY 2021 Final Annual Fees used as an Illustration.

>>> Expands the SMR variable annual fee rule, which was first published in 2016; the bundled units concept applies.

a) Micro Reactors Maximum Fee: Equals the average of the annual fees for Spent Fuel Storage/Reactor Decommissioning (SFS/RD) and Non-Power Production or Utilization Facilities (NPUFs) b) OR Maximum Fee: Equals the annual fee paid by the Operating Power Reactor Fee Class c) Variable Rate 2: Equals [(OR Max Fee - Micro Reactors Max Fee) /1,750] x the difference between 250 MWt for the first bundled unit(s) and the actual cumulative MWt rating up to 2,000 MWt d) Variable Rate 3: Equals [(OR Max Fee - Micro Reactors Max Fee) /2,000] x the difference between 4,500 MWt for the first bundled unit(s) and the total actual cumulative MWt rating up to 2,000 MWt Page 34 of 146

Annual Fee Alternative 2 Bundled Unit Thermal Power Rating Minimum Fee

• Variable Fee

• Maximum Fee

• First Bundled Unit - cumulative MWt 0 MWt 20 MWt $80K (a) N/A N/A

>20 MWt 250 MWt $158.5K (b) N/A N/A

>250 MWt 2,000 MWt $158.5K (b) Variable Rate 2 (d) N/A

>2,000 MWt 4,500 MWt N/A N/A $4,986K (c)

Additional Bundled Units - cumulative MWt (above the first bundled unit of 4,500 MWt) 0 MWt 2,000 MWt N/A Variable Rate 3 (e) N/A

>2,000 MWt 4,500 MWt N/A N/A $4,986K (c)

• FY 2021 Final Annual Fees used as an Illustration

>>> Adds a Thermal Power Level and fee for 0 MWt 20 MWt; the bundled units concept applies.

a) Micro Reactors Minimum Fee: Equals annual fee paid by NPUF Fee Class b) Micro Reactors Maximum Fee: Equals the average of the annual fees for Spent Fuel Storage/Reactor Decommissioning (SFS/RD) and Non-Power Production or Utilization Facilities (NPUFs) c) OR Maximum Fee: Equals the annual fee paid by the Operating Power Reactor Fee Class d) Variable Rate 2: Equals [(OR Max Fee - Micro Reactors Max Fee) /1,750] x the difference between 250 MWt for the first bundled unit(s) and the actual cumulative MWt rating up to 2,000 MWt e) Variable Rate 3: Equals [(OR Max Fee - Micro Reactors Max Fee) /2,000] x the difference between 4,500 MWt for the first bundled unit(s) and the total actual cumulative MWt rating up to 2,000 MWt Page 35 of 146

Annual Fee Alternative 3

• Define micro-reactors, for the purpose of annual fees, as power reactors with thermal power ratings of less than or equal to 20 MWt

• Modify the SMR variable fee structure to be technology inclusive and to begin with > 20 MWt 250 MWt

• Under this alternative, the bundled unit concept applied to small modular reactors would not be applied to micro-reactors Thermal Power Rating for Each Unit Fee for Each Unit

• 0 MWt 20 MWt $ 80K (a)

• FY 2021 Final Annual Fees Used as an Illustration (a) Equals the annual fee paid by the NPUF Fee Class.

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Annual Fee Alternative 4 Bundled Unit Thermal Power Rating Minimum Fee

• Variable Fee

• Maximum Fee

• First Bundled Unit - cumulative MWt 0 MWt 20 MWt $80K (a) N/A N/A

>20 MWt 250 MWt $80K (a) Variable Rate 1 (d) N/A

>250 MWt 2,000 MWt $158.5K (b) Variable Rate 2 (e) N/A

>2,000 MWt 4,500 MWt N/A N/A $4,986K (c)

Additional Bundled Units - cumulative MWt (above the first bundled unit of 4,500 MWt) 0 MWt 2,000 MWt N/A Variable Rate 3 (f) N/A

>2,000 MWt 4,500 MWt N/A N/A $4,986K (c)

• FY 2021 Final Annual Fees used as an Illustration

>>> Adds a variable rate for the >20 MWt 250 MWt level; the bundled units concept applies.

a) Micro Reactors Minimum Fee: Equals annual fee paid by NPUF Fee Class b) Micro Reactors Maximum Fee: Equals the average of the annual fees for Spent Fuel Storage/Reactor Decommissioning (SFS/RD) and Non-Power Production or Utilization Facilities (NPUFs) c) OR Maximum Fee: Equals the annual fee paid by the Operating Power Reactor Fee Class d) Variable Rate 1: Equals [(Micro Reactors Max Fee - Micro Reactors Min Fee) /230] x the difference between 20 MWt for the first bundled unit(s) and the actual cumulative MWt rating up to 250 MWt e) Variable Rate 2: Equals [(OR Max Fee - Micro Reactors Max Fee) /1,750] x the difference between 250 MWt for the first bundled unit(s) and the actual cumulative MWt rating up to 2,000 MWt f) Variable Rate 3: Equals [(OR Max Fee - Micro Reactors Max Fee) /2,000] x the difference between 4,500 MWt for the first bundled unit(s) and the total actual cumulative MWt rating up to 2,000 MWt Page 37 of 146

Next Steps

• Staff will consider any additional feedback received today and will proceed with next steps

• Staff will present alternatives to management

• Based upon the anticipated schedule for new facilities, the staff is considering proposing the policy to the Commission for FY 2023 Page 38 of 146

Input on Annual Fees U.S. Nuclear Industry Council Cyril W. Draffin, Jr.

Senior Fellow, Advanced Nuclear U.S. Nuclear Industry Council 15 July 2021 Page 39 of 146

USNIC 2021 Survey question: What is an appropriate Nuclear Regulatory Commission fee?

(for the current regulatory framework and desired future regulatory framework)

The current fee structure is acceptable If not the current structure, what fee structures would you recommend for licensing review fees, and annual fees?

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Input on Annual Fees Annual Fee Comments from 2021 USNIC Advanced Nuclear Survey

• Under the current structure, microreactor annual fees should be no greater than those applied to research and test reactors

• Fee should be scaled to power level and plant safety profile

• Annual fees should be revisited for whether they are truly necessary. Recent reports suggested alternative fee structures be looked at for applicability, including EPA, FDA, and FAA. These structures recognize the public benefit incurred as a result of the associated reviews, and therefore set the expectation that public share in regulatory costs associated with such activities.

• Legislation should be pursued to recognize the zero carbon societal benefit of nuclear and to make cost recovery commensurate or favorable when compared to carbon producing technologies.

Without legislative action, annual fees should reflect the level of staff effort as this is a zero sum game and no licensee should be disproportionately burdened by other licensees.

• Getting a non-LWR fee expectation in place is important to developers ability to effectively make cost estimates and communicate what the on-going costs of a prospective plant are. Some have been using the Light water SMR calculations as a guide, but thats not going to provide the same confidence as clear rule language.

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Input on Annual Fees From USNIC member made at 15 April 2021 Stakeholders Meeting

• Current annual fee structure with thresholds and tiers is overcomplicated

• Customers care about levelized cost of electricity

• Suggest 0-4500 MW thermal sliding scale

• Rather electric power because some Advanced Reactor deployments could be for process heat

• No tiers; avoids discontinuity that penalizes reactors just larger then the threshold (e.g. 300 MW)

• Fully sliding scale would be predictable and equitable per reactor for every unit

• Recognize it would be a substantial change that would impact all power reactors; some winners and losers so would need operating fleet stakeholder input Page 42 of 146 3l

Advanced Reactors Overview of ARCAP Roadmap ISG and TICAP DG White Papers Page 43 of 146

Advanced Reactor Content of Application (ARCAP)

To ensure review readiness to regulate a new generation of advanced reactors, a key element of a flexible regulatory framework is to provide guidance for the development of content of an advanced reactor application.

NRC Staff Stakeholders Lessons Learned

• Ensures consistency of staff

• Makes information about

• Apply lessons learned from LWR application reviews, regulatory matters widely reviews, available,

• Presents a well-defined base for

• Technology Inclusive, scope and requirements of

• Improves communication and understanding of the staff review

• Risk-Informed Performance-Based.

reviews.

process by interested members of the public and the nuclear power industry.

Page 44 of 146

ARCAP

Background

Purpose Provides a roadmap for developing a tech-inclusive, risk-informed application. Leverages existing guidance or guidance that is under development.

Broad Encompasses industry-led technology-inclusive content of application project (TICAP).

Need for Additional Guidance Roadmap also identifies areas where additional guidance is needed (i.e.: Technical Specifications).

Regulatory Applicability (As applicable) 10 CFR Parts 50, 52, and informs 53.

Streamlined Review Process ARCAP guidance document not intended to replicate NUREG-0800, Standard Review Plan for LWRs.

Previous Discussions ARCAP overview discussed at August 2020, October

2020, Page 45 and of 146 February 2021 public meetings.

ARCAP Roadmap ISG - Outline Identifies all Provides Provides Provides pointers to Adv. Rx background and endorsements, key guidance in application overview of clarifications, support of topics. expected supplements info, or application topic.

information for each points of emphasis.

topic.

Page 46 of 146

TICAP

Background

Purpose

• TICAP is industry-led guidance focused on describing the scope and level of detail for portions of an application consistent with the LMP.

• LMP is described in NEI18-04, as endorsed by RG 1.233.

• Industry-led TICAP guidance only applicable to portions of first 8 SAR chapters.

• Aims to minimize burden of generating and supplying non-safety significant information.

Regulatory Applicability (As applicable) 10 CFR Parts 50, 52, and informs 53.

Methodology Scope is governed by the LMP-based safety case. LMP process is one approach to select licensing basis events, develop SSC categorization and ensures defense-in-depth is considered.

Page 47 of 146

TICAP draft DG- Outline Endorses Provides additional Provides further Includes appendices LMP-based clarifications, exceptions, information needed to key guidance in NEI 21-xx points of emphasis from outside of LMP-based support of FSAR TICAP information described in affirmative safety case development for first document. NEI 21-xx. for first 8 chapters. 8 chapters.

Page 48 of 146

ARCAP and TICAP - Nexus Page 49 of 146 Pagediscussion.

• Additional contents of application outside of SAR are still under 49 of 146 The above list is draft and for illustration purposes only.

NRC ARCAP/TICAP Guidance Other Insights Efficiency Adaptable NRC ARCAP/TICAP guidance being developed in parallel to 1 4 ARCAP guidance includes placeholders for guidance under development (e.g.,

industry, Applicability of Regs),

Openness Endorsement 2 5 Main purpose of NRC TICAP white paper releasing draft endorses, as documents is to solicit appropriate, industrys stakeholder feedback TICAP document, on proposal, Initial Thoughts Supplements 3 6 The guidance structure, NRC TICAP white paper not detailed content, is supplements, as the focus of stakeholder appropriate, information interactions, not addressed in industrys TICAP document (i.e.: Fuel Qual and ASME Sec III, Div 5).

Page 50 of 146

ARCAP Roadmap ISG - Example 1

• FSAR structure developed as a result Contents of an Advanced Reactor Application*

of extensive stakeholder engagement.

• Consists of 12 main chapters.

• Provides the most safety-significant information at the forefront (ASC).

• Focus on the most relevant safety information while removing unnecessary details.

• Additional information/background is available for audit/inspection by NRC.

Page 51 of 146

• Contents of application are still under discussion. List represents a draft outline

Note: SAR Chapters 1-8 addressed by TICAP. SAR Chapters 9-12 addressed by ARCAP.

Page 52 of 146

Our Ch. 1- General Plant Information, site description, and overview of safety case (TICAP)

Information should provide an understanding of the overall facility (type of application, the number of plant units, a brief description of the proposed plant location, and the type of advanced reactor being proposed). The site description should provide an overview of the actual physical, environmental and demographic features of a site, and how they relate to the affirmative safety case.

Clarifies Endorses Key Guidance Supplements

• Roadmap clarifies

• RG 1.2xx Guidance For A

• Chapter 1 of NEI

• Construction Permit that guidance Technology-inclusive Content 21-xx (TICAP) as one Information in NEI applicable to Of Application Methodology acceptable method. 21-xx by including chapter 1 is To Inform The Licensing Basis Appendix A for info And Content Of Applications described in NEI outside LMP for first For Licenses, Certifications, 21-xx - TICAP And Approvals For 8 chapters.*

document. Advanced Reactors.

Note: CP information for all other portions of the application are described in Appendix E of the ARCAP roadmap ISG)

Page 53 of 146

Our Ch. 2- Methodologies and Analyses (TICAP)

Certain analyses are common to several licensing-basis event analyses. Information should describe the process and methods used to develop baseline information related to the probabilistic risk assessment (overview of the PRA), source-term analysis, and design-basis accidents (DBAs) analytical methods.

Clarifies Endorses Key Guidance Supplements

• Roadmap clarifies

• RG 1.2xx Guidance For A

• Chapter 2 of NEI

• Site Information that guidance Technology-inclusive Content 21-xx (TICAP) as one draft ISG previously applicable to Of Application Methodology acceptable method. released.

chapter 2 is To Inform The Licensing Basis

• Staff positions on And Content Of Applications described in NEI For Licenses, Certifications, additional 21-xx - TICAP And Approvals For considerations to document. Advanced Reactors. document information.

Page 54 of 146

Our Ch. 10 - Control of Occupational Dose Information should include facility and equipment design, radiation sources, and operational programs that are necessary to ensure that the occupational radiation protection standards set forth in 10 CFR Part 20 are met. The information should also include any commitments made by the applicant to develop the management policy and organizational structure necessary to ensure occupational radiation exposures are as low as (is) reasonably achievable (ALARA).

Clarifies Endorses Key Guidance Supplements

• Guidance is included

• DANU-ISG-2021-XX,

• RG 8.8 for chapters 9-12. Control of Occupational

• RG 8.10 Dose.

• ANSI/ANS 18.1-1999

• Released on prior

• NEI 07-08A ARCAP/TICAP public

• Draft list released in meeting. prior public meeting.

Expected to evolve.

(MLxyz123).

Page 55 of 146

ARCAP Roadmap ISG - Example 2

• Ongoing Emergency Preparedness Requirements for Contents of an Advanced Reactor Application*

Small Modular Reactors and Other New Technologies rulemaking.

• Rule would amend the NRCs regulations to add new emergency preparedness requirements for small modular reactors, non-light-water reactors and non-power production or utilization facilities.

• Rule would adopt a scalable plume exposure pathway emergency planning zone approach that is performance-based, consequence-oriented, and technology-inclusive.

Page 56 of 146

• Contents of application are still under discussion. List represents a draft outline

Our Emergency Preparedness Plan This rulemaking would develop a dose-based, consequence-oriented framework for future SMR applicants and licensees with respect to offsite EP that would reduce the need for exemptions related to regulations associated with large LWRs.

- SECY-16-0069 (ML21007A330)

Clarifies Endorses Key Guidance Supplements

• Ongoing rulemaking.

• DG-1357, Emergency Response Planning and Preparedness for Nuclear Power Reactors.

• SECY-18-0103 Page 57 of 146

Key Messages Whats Next?

TICAP draft RG, ARCAP Draft roadmap ISG, and ARCAP selected chapters (e.g., site information, technical specifications) released as white-paper to solicit stakeholder feedback. Further iterations expected.

Draft documents provided in Table 2 of ARCAP/TICAP public webpage https://www.nrc.gov/reactors/new-reactors/advanced/details.html#advR xContentAppProj Some sections are primarily aligned with the Licensing Modernization Project (LMP), however:

• the concepts and general information may be used to inform the review of an application submitted using other methodologies (as applicable) such as a maximum hypothetical accident, or deterministic approaches.

Page 58 of 146

Timeline for Technology Inclusive Content of Application Project (TICAP) Guidance and Advanced Reactor Content of Application Project (ARCAP) Guidance (rev 7/13/2021)

NRC Comments based on TICAP Workshops 6/10/2021 NRC/Industry update ACRS Subcommittee on status of ARCAP/TICAP guidance documents 7/21/2021 TICAP Tabletop Exercises NEI Revision 1 of TICAP Guidance 2/1/2021 4/2/2021 Southern Revision C of TICAP Document Guidance Document 1/19/2022 8/3/2021 NRC/Industry brief ACRS Subcommittee NEI Revision 0 of TICAP Guidance on final ARCAP/ TICAP guidance Legend TICAP Workshops Document 2/9/2022 5/26/2021 8/27/2021 Industry Action 5/2/2021 NRC/Industry brief ACRS Full NRC TICAP Regulatory Guide (Draft) Committee on final TICAP 9/10/2021 guidance NRC Staff Action 3/3/2022 NRC/Industry brief ACRS Subcommittee on Industry/NRC Southern Revision B of TICAP Guidance ARCAP/TICAP guidance documents (NEI, NRC TICAP Regulatory Joint Action Document Rev0 and Staff Draft RG) Guide 4/15/2021 10/12/2021 3/25/2022 Jan Mar May Jul Sep Nov 2022 Mar 2022 1/30/2021 9/10/2021 Draft ARCAP Roadmap ISG, ARCAP ISG for ARCAP Application Outline Updated to be "Site Information," and ARCAP Chapters 9, Consistent with TICAP outline 10, 11, 12, and Technical Specifications issued Page 59 of 146 17

Next Steps - Future Milestones TICAP Near-Term Milestones Target Date Southern Revision C to TICAP Guidance Early August 2021 Document NEI Revision 0 of TICAP Guidance Late August 2021 Document Update of NRC Draft Guidance Documents September 2021 ACRS Future Plant Subcommittee Meeting October 2021 on ARCAP/TICAP Guidance Documents Page 60 of 146 18

Backup Slides Page 61 of 146

Technology-Inclusive Content of Application (TICAP) and Advanced Reactors Content of Application (ARCAP)- Nexus to Part 53 Part 53- Proposed Structure Subpart H - Licenses, Cert, and Approvals This subpart is envisioned to address requirements for initial applications for licenses, certifications, or approvals. The A- General Provisions subpart will support either licensing under the Part 50 or Part 52 frameworks. Assessment and update of manufacturing licenses is possible.

B- Tech-Incl Safety Requirements C- Design and Analysis Req.

D- Siting ARCAP-Guidance for Content of Application Guidance (Roadmap)

E- Const. and Manufacturing TICAP - LMP-based F- Operations portions of FSAR that are Guidance under Development examples:

related to:

• Fuel Qualification

• LBEs G- Decommissioning

• Safety classification

• ASME Section III, Division 5

• Defense in Depth

• EP rulemaking H- Licenses, Cert, and Approvals

• Security ARCAP specific chapter Rulemaking guidance - examples:

I- Maintaining/Revising LB Info

• Site information Existing

• ARCAP chapters 9, Regulatory 10, 11, and 12 Guidance J- Administrative requirements Page 62 of 146 Note: The illustrated content structure for Part 53 (including Subpart H) is part of ongoing work and subject to change. 20

Industry-led TICAP NRC-led TICAP

• Focused on portions of the license

• NRC plans to issue a RG application Safety Analysis Report endorsing TICAP that also focuses Chapters 1-8 (SAR) for non-LWR designs related on providing exceptions to the Licensing Modernization and/or clarifications on TICAP.

TICAP Project (LMP)-based affirmative safety case.

• Include supplemental TICAP guidance for areas outside of the LMP for the first 8 SAR chapters. Examples includes site FSAR information, ASME Section III, Division 5 Chapters 9-12 NRC-led SAR Guidance ARCAP*

• Focused on remaining portions of the license application Safety Analysis Report (SAR) not related to LMP.

• ARCAP ISGs under development that include an overall roadmap ISG and separate ISGs for FSAR Chapters 2, 9, 10, 11, and 12 Additional

• For example:

o Technical Specifications, Contents of o QA Plan, Application o Fire Protection, etc.

• Staff plans to issue an ARCAP Roadmap ISG that would provide pointers to various guidance documents developed/issued.

Page 63 of 146 21

Key Part 53 Guidance by Subpart Subpart A: General Provisions Existing / Ongoing Guidance Additional Guidance N/A Subpart B: Safety Criteria Existing / Ongoing Guidance Additional Guidance Further explanation of criteria and structure N/A in the Statements of Consideration Subpart C: Design and Analysis Existing / Ongoing Guidance Additional Guidance NEI 18-04 & RG 1.233 (LMP)

ANS/ASME-RA-S-1.4 (Non-LWR PRA Standard) ISG on PRA for Initial Licensing Industry PRA Peer Review Guidance for Non- RG 1.247 Endorsing Non-LWR PRA Standard LWRs (NEI 20-09) and NEI Peer Review Guidance ANS/ASME Standards Application of Analytical Margins Fuel Qualification Treatment of Chemical Hazards RG 1.232 (ARDCs)

Subpart D: Siting Requirements Existing / Ongoing Guidance Additional Guidance SECY-20-0045/RG 4.7 External Hazard Updates N/A Risk-Informed Seismic Design; ANS 2.26 22 Page 64 of 146

Key Part 53 Guidance by Subpart Subpart E: Construction and Manufacturing Existing / Ongoing Guidance Additional Guidance Manufacturing Guidance N/A QA Alternatives Subpart F: Operations SSCs Existing / Ongoing Guidance Additional Guidance Technical Specifications Special Treatment NEI 18-04 & RG 1.233 (LMP)

Maintenance, Repair & Inspection Facility Safety Program Personnel Existing / Ongoing Guidance Additional Guidance DRO Paper/preliminary ISG Concept of Operations Programs Existing / Ongoing Guidance Additional Guidance Emergency Preparedness EPZ Draft Final Rule, RG 1.242 Security Programs Radiation Protection (ARCAP)

Integrity Assessment Program 23 Page 65 of 146

Key Part 53 Guidance by Subpart Subpart G: Decommissioning Existing / Ongoing Guidance Additional Guidance N/A N/A Subpart H: Licensing Existing / Ongoing Guidance Additional Guidance TICAP Manufacturing Licenses ARCAP Subpart I: Maintaining Licensing Basis Existing / Ongoing Guidance Additional Guidance 50.59 Equivalent N/A FSAR/PRA Updates Subpart J: Administrative/Misc.

Existing / Ongoing Guidance Additional Guidance Reporting Requirements N/A Financial/Liability 24 Page 66 of 146

Advanced Reactor Stakeholder Public Meeting Break Meeting will resume at 1pm EST Microsoft Teams Meeting Bridgeline: 301-576-2978 Conference ID: 446 067 450#

Page 67 of 146

NRC Staff Draft White Paper -

Analysis of Applicability of NRC Regulations for Non-Light Water Reactors July 2021 Page 68 of 146

Purpose

• Discuss Updated NRC Staff Draft White Paper - Analysis of Applicability of NRC Regulations for Non-Light Water Reactors

• Outline high level changes to the white paper since the last released version

• Describe path forward for final paper 2

Page 69 of 146

Background

• Will discuss revisions to Updated NRC Staff Draft White Paper -

Analysis of Applicability of NRC Regulations for Non-Light Water Reactors, first issued in 9/2020

• Stakeholders provided feedback regarding the NRC draft white paper in correspondence and public meetings; NRC staff has considered the feedback and made changes to improve clarity

• Paper layout has been reworked, a flowchart has been added for additional clarity, tables have been renumbered and additional context has been added on some items 3

Page 70 of 146

Flowchart 4

Page 71 of 146

New Table Flow

• Table 1: 10 CFR Part 50 Requirements, as applicable to applications under Part 50 for non-LWRs

• Table 2: Selected 10 CFR Part 52 Requirements, as applicable to non-LWR Standard Design Certifications, Combined Licenses and Standard Design Approvals applications

• Table 3: Other regulations that may apply to non-LWRs

• Table 4: Applicability of 10 CFR 50.34(f) TMI Requirements to non-LWRs under Part 52

• Table 5: Areas with anticipated exemptions

• Table 6: Part 52 Regulations Referencing Part 50 Regulations Limited to LWRs

• Tables contain additional footnotes clarifying various items based on feedback 5

Page 72 of 146

Appendix: Examples - Regulatory Compliance and Exemptions

• The revised Appendix content now contains examples (some new) related to regulatory compliance and requesting exemptions.

• Content related to the concept of compliance and specifics related to exemption request content have been moved to the main body of the white paper.

• Exemption examples are provided as a starting point; NRC staff expects that specific applications will further explore these areas. NRC encourages early engagement on these topics.

6 Page 73 of 146

Issuance of White Paper and Final Guidance

• The version issued in support of this meeting represents the final content expected as part of the staff white paper to support regulatory applicability for non-LWRs

• Plan for final issuance of the white paper content involves integrating the paper as an appendix to the planned TICAP/ARCAP interim staff guidance 7

Page 74 of 146

Questions/Discussion 8

Page 75 of 146

AN OVERVIEW OF NON-LWR VESSEL COOLING SYSTEMS FOR PASSIVE DECAY HEAT REMOVAL erhtjhtyhy Author / Speaker: Darius Lisowski Co-Authors: Qiuping Lv, Bogdan Alexandreanu, Yiren Chen, Rui Hu, and Tanju Sofu Imtiaz Madni, NRC Senior Reactor Systems Engineer; Task Lead Maryam Khan, NRC Project Manager; Contracting Officers Representative Joseph Sebrosky, NRC Senior Project Manager; Alternate Contracting Officers Representative NRC Periodic Advanced Reactor Stakeholder Meeting July 15th 2021 Page 76 of 146

INTRODUCTION AND OBJECTIVES 2 Page 77 of 146

MOTIVATION One of the leading focus areas in the development of advanced reactor concepts is the use of passive safety systems as a primary means for decay heat removal.

The design and use of such technologies date to the earliest high-temperature gas-cooled reactors, which were built and operated in the 1950s.

- With the introduction of new and alternative reactor types, these systems have been adapted to meet specific operational and safety needs For any vessel cooling system to serve as a viable feature for safety basis reactor licensing, vendors will have to defend their ability to maintain the intended safety function throughout the operating life of the reactor 3 of 146 Page 78

MOTIVATION, CONTD To answer this question, there is a need to conduct a technical review to provide an assessment of the maturity, performance, and viability of reactor vessel cooling systems for decay heat removal in advanced non-LWR reactor concepts This review should focus on air- and water-based reactor vessel cooling systems, such as Reactor Vessel Auxiliary Cooling System (RVACS) and Reactor Cavity Cooling Systems (RCCS)

- In-vessel decay heat removal such as the Direct Reactor Auxiliary Cooling System (DRACS) not included in the scope

- Focus on future advanced, non-LWR concepts Ultimately, the question to be addressed is how such systems are designed to perform and how degraded conditions can impact their safety function 4 of 146 Page 79

PROJECT OBJECTIVES Interagency agreement with the Nuclear Regulatory Commission (NRC) and Argonne National Laboratory (Argonne), performance period spanning 12-mo.

Technical review of design concepts for vessel cooling systems

- Summary of vessel cooling design options

- Design history and maturity

- Applicability to various reactor types Evaluation and Assessment

- Operating characteristics during normal operation and accident conditions

- Performance during degraded operation and impact on design function

- Discovery of available data 5 of 146 Page 80

APPROACH & METHODOLOGY Literature review & compilation of reference works Technical review of discovered literature Extract information from narratives on Sort reference tables various proposed DHR design concepts, to generate focused compile into general summary descriptions comparisons Assess performance and Assess breadth of reliability of DHR generated data Evaluate against metrics for full scale viability and longevity 6 of 146 Page 81

LITERATURE SEARCH Database was generated from openly available publications related to the design, analysis, testing, and optimization of decay heat removal systems Sources included:

- OSTI

- ResearchGate

- ScienceDirect

- Society conferences (ANS, etc.)

- IAEA

- US National Laboratory reports Earliest available publication dating back to 1979 and the most recent publication from 2020 2021 Zotero was used as database manager, allowing access and searching of ~500 collected records 7 of 146 Page 82

DECAY HEAT REMOVAL OVERVIEW 8 Page 83 of 146

SAFETY GRADE DECAY HEAT REMOVAL Role of decay heat removal systems is to remove core afterheat in the case of failure or unavailability of primary cooling systems The decay heat removal system designs feature any number of passive, highly-reliable, and/or redundant features to accomplish their heat removal function When inherent hazards cannot be eliminated, engineered safety systems help to establish sufficient confidence in the reliability and performance of these safety systems decay heat removal function across normal and accident conditions

[4] Preliminary Safety Information Document for the Standard MHTGR (No. HTGR-86-024), 1992 Page 9 of 146 84

SAFETY GRADE DECAY HEAT REMOVAL, CONTD

- Maintain fuel and reactor vessel temperatures within safe limits

- Passive mode of operation during safety-related accident conditions

- Reliable operation during both accident transients and over the course of plant life

- Heat removal rate commensurate with rate of decay 10 of 146 Page 85

OVERVIEW OF DHR CONCEPTS Ex-vessel Secondary 11 of 146 Page 86

EX-VESSEL COOLING SYSTEMS (VCS)

The design of these systems, including the RCCS, RVACS, and their hybrid variations, share a commonality in the use of conductive, radiative and convective cooling from the walls of an reactor vessel (RV) to a network of cooling channels In addition to design choices of air or water as the primary coolant, geometry and design of the individual cooling channels such dimensions of air or water pipes, vary widely across reactor designs 12 of 146 Page 87

EXAMPLES OF VARIOUS VCS CONCEPTS 13 of 146 Page 88

RCCS DESIGN OVERVIEW 14 Page 89 of 146

RCCS DESIGN OVERVIEW RCCS is a passive safety system that has been proposed for use in high-temperature gas reactors and their variants, and have been included as a primary design choice in concepts dating back to the 1950s Different RCCS concepts have been proposed for the range of reactor designs, with primary differences in their working fluid and passive mode of operation

- The air-based RCCS features unlimited supply of the ambient air cooling but may be susceptible to certain ambient effects, e.g., strong winds

- The water-based RCCS exhibits a superior efficiency in heat transfer due to two-phase boiling, but its cooling capability is limited by the capacity of the water inventory tank Fig. Generic water-based RCCS operating principal [72]

[4] Preliminary Safety Information Document for the Standard MHTGR (No. HTGR-86-024), 1992

[72] Lisowski, D., 2013. Thermal Hydraulic Analysis of an Experimental Reactor Cavity Cooling System with Water: Performance and Stability (Thesis). University of Wisconsin - Madison, Page 15 of 146 90

GA-MHTGR AIR-COOLED RCCS The GA-MTHGR employs an air-based RCCS which draws cold air from the ambient environment and into channels within the cavity by natural circulation Decay heat is rejected from the RV to the RCCS cooling channels by thermal radiation and natural convection This RCCS design is always on, and it is completely passive with no valves or active components 16 of 146 Page 91

GA-MHTGR AIR-COOLED RCCS, CONTD 17 of 146 Page 92

GA-MHTGR AIR-COOLED RCCS, CONTD

[4] Preliminary Safety Information Document for the Standard MHTGR (No. HTGR-86-024), 1992 18 of 146 Page 93

FRAMATOME SC-HTGR WATER-COOLED RCCS The SC-HTGR RCCS comprises many water tubes joined to form a single cooling panel which surround the reactor vessel These tubes are connected to multiple water storage tanks at higher elevations Power from the reactor vessel heats up the water inside the cooling panel and establishes natural circulation flow across the network of piping This RCCS design is always on, with active cooling during normal operation and passive heat-up with boil-off during accident scenarios 19 of 146 Page 94

FRAMATOME SC-HTGR WATER-COOLED RCCS 20 of 146 Page 95

FRAMATOME SC-HTGR WATER-COOLED RCCS

[6] Lommers, L., Shahrokhi, F., Iii, J.M., Southworth, F., 2014. AREVA Modular Steam Cycle - High Temperature Gas-Cooled Reactor Development Progress 10. Page 21 of 146 96

REACTOR DESIGNS FEATURING RCCS Reactor Decay Heat Removal System Reactor Year Ref.

Country Vendor Power Coolant Decay heat removal approach Capacity Fluid Circulation UHS Philadelphia Reactor-vessel cooling panels, secondary Peach Bottom 1 1967 115 MWt Helium n/a n/a n/a n/a [113]

Electric system General MHTGR 1986 560 MWt Helium Reactor cavity cooling system with air 1.5 MW Air Natural Atmosphere [4]

Atomics Radiation heat transfer from vessel to cooling VGM 1989 OKMB 200 MWt Helium 1.3 MW Water Natural Atmosphere [100]

tubes with back mounted fins Siempelkamp/ Radiation heat transfer from vessel to cooling HTR Module 1993 200 MWt Helium 890 kW Water Natural Atmosphere [23]

Siemens tubes, natural to atmosphere, dry air cooling Radiation heat transfer from reactor vessel to Cooling HTTR 1998 JAEA 30 MWt Helium 0.3 MW Water Forced [12]

cooling tubes, forced convection to water water General Water-cooled panels surrounding reactor vessel, Natural and NPR-MHTGR 1998 350 MWt Helium n/a Water Atmosphere [115]

Atomics cooled by HXG above grade forced Tsinghua Radiation heat transfer from reactor vessel to HTR-10 2000- 10 MWt Helium 200 kW Water Natural Atmosphere [103]

University cooling tubes, forced convection to water Radiation heat transfer from RV to water pool, Forced air PBMR 2009 PBMR (Pty) 265 MWt Helium 3.1 MW Water Atmosphere [13]

forced air circulation, evaporation or boiling circulation Radiation heat transfer from RV to cooling SC-HTGR 2010 Framatome 625 MWt Helium 2.1 MW Water Natural Atmosphere [22]

panel with natural circulation of water inside GA & Liquid metal filled reactor cavity to cool reactor GT-MHR 2010 600 MWt Helium 1.5 MW Air Natural Atmosphere [101]

MINATOM vessel, and passive air from reactor cavity.

Huaneng Radiation heat transfer from reactor vessel to HTR-PM under cont. 458 MWt Helium 1.1 MW Water Natural Atmosphere [102]

Group cooling tubes, forced convection to water Page 9722 of 146

RVACS DESIGN OVERVIEW 23 Page 98 of 146

RVACS DESIGN OVERVIEW The RVACS is designed to remove decay heat by radiative and convective cooling to natural circulation driven airflow across a guard vessel Unlike the RCCS concept, air travels directly within the containment and requires special design constraints for potential fission product release and material activation The design is uniquely tailored toward the design of advanced liquid metal cooled reactors because the high conductivity of the coolant allows for effective heat transmission to the vessel and guard walls 24 of 146 Page 99

GE-HITACHI PRISM RVACS The GE PRISM RVACS is designed to maintain reactor temperatures well below design limits using only air-based natural circulation to remove heat from the reactor guard vessel

- Atmospheric air is drawn into the reactor building and flows over the outside of the containment vessel. The warm air then returns to the stack and is exhausted Heat loss to the RVACS during normal full power conditions, with the associated lower temperatures, is <0.2% because thermal radiation between the reactor and containment vessels controls the heat transfer rate 25 of 146 Page 100

GE-HITACHI PRISM RVACS, CONTD Similar to the air-based RCCS, the RVACS is..

- Always on and operating

- Requires no actuations

- Sized to remove the full decay heat load

- Employs redundant chimney networks

• x8 inlets, x4 outlets Differences are primarily

- Surface of heat transfer from the internal fuel (guard vessel vs reactor vessel)

- Single continuous flow area for hot air instead of multiple individual channels 26 of 146 Page 101

REACTOR DESIGNS FEATURING RVACS Reactor Decay Heat Removal System Name Year Capacity, Ref.

Country Vendor Power Coolant DHR Approach Mode Fluid

% Full Power Radiation heat transfer across safety vessel by natural convection of Water, Phenix 1973 CEM 840 MWt Sodium 0.4 (0.7) Forced [36]

atmospheric air; in 2002 was converted to air Air Super Phenix 1985 Novatome 3000 MWt Sodium Radiation heat transfer across safety vessel by natural convection of 0.2 Forced Water [36]

atmospheric air SAFR 1988 Rockwell 900 MWt Sodium Radiation heat transfer across safety vessel by natural convection of 0.6 Natural Air [31]

atmospheric air PEACER 2000 SNU 850 MWt Lead Radiation heat transfer across safety vessel by natural convection of unknown Natural Air [111]

atmospheric air in tubes SSTAR 2004 LLNL 45 MWt Lead Radiation heat transfer across safety vessel by natural convection of unknown Natural Air [107]

atmospheric air in tubes Molten Radiation heat transfer across safety vessel by natural convection of AHTR 2004 ORNL 2400 MWt unknown Natural Air [33]

Salt near atmospheric air channel ELSY 2006 Euratom 600 MWt Lead Radiation heat transfer from safety vessel by natural convection of unknown Natural Air [50]

atmospheric air in tubes PRISM 2010 General Electric 840 MWt Sodium Radiation heat transfer across guard vessel to a free convecting 0.7 Natural Air [47]

atmospheric air stream (air channel)

ASTRID 2014 CEA 1500 MWt Sodium Radiation heat transfer across safety vessel by natural convection of unknown Natural Oil [27]

oil CLEAR-I 2014 CAS 45 MWt Lead Radiation heat transfer from safety vessel by natural convection of 0.2 Natural Air [49]

atmospheric air in four independent loops of U-shaped tubes W LFR 2018 Westinghouse 400 MWt Lead Radiation heat transfer across guard vessel by natural convection of unknown Natural Air [98]

atmospheric air channel Molten Internal RVACS, heat transfer by a closed cycle flow of nitrogen IMSR 2019 Terrestrial 400 MWt unknown Natural Nitrogen [35]

Salt to a false roof acting as a heat exchanger above the structural roof Natrium 2021 Terrapower 345 MWt Sodium Radiation heat transfer across safety vessel by natural convection of unknown Natural Air [114]

atmospheric air channel Page 102 of 146 27

EVALUATION OF AVAILABLE DATA 28 Page 103 of 146

KNOWN ANALYTICAL TOOLS FOR RCCS/RVACS 29 of 146 Page 104

KNOWN EXPERIMENTAL EFFORTS ON RCCS/RVACS 30 of 146 Page 105

BEHAVIOR DURING OFF-NORMAL AND DEGRADED CONDITIONS 31 Page 106 of 146

PARTIAL BLOCKAGES OF RVACS In the early 1990s GE Nuclear Energy, Advance Reactor Programs division, used COMMIX to analyze the RVACS performance during varying degrees of flow area blockage

- Blocking each of the four air inlet openings 75% and each of the four air outlets also by 75% causes an increase in the maximum core outlet temperature of 32°F

[47] Boardman, C.E., Hunsbedt, A., 1991. Performance of ALMR passive decay heat removal system.

Page Presented at the IAEA-IWGFR specialists meeting on passive and active safety features of LMFRs, 32 of 146 107 PNC, JAPAN, pp. 113-120.

COMPLETE BLOCKAGE OF RVACS More severe postulated events for an operating RVACS were evaluated including complete blockage of all air inlets while the four air outlets remain fully open, and visa-versa Several assumptions subject to experimental verification were made in the analysis of this case, with a significant uncertainty of 100% to reflect the lack of experimental information about the air-side flow distribution and the adequacy of the assumed U-flow model Block inlets

- The maximum core sodium outlet temperature increases to 1168°F (631°C), only 43°F (24°C) higher than that expected for the normal RVACS event Block outlets

- Results of the transient analysis for the blocked outlets case show that the maximum core outlet temperature reached exceeds the service level D limit and is unacceptable from a structural point of view Fig. Core sodium outlet temperature for blocked inlets [47]

33 of 146 Page 108

PARTIAL BLOCKAGE OF RCCS RISERS

- The heated plate temperature, representing the walls of an RV, averaged 279°C for the normal, fully open operation

- Increased to 282°C, 288°C, and 292°C at 16%, 33%, and 50% blockage flow areas

[58] Lisowski, D., Lee, T., et al., 2016. Final Project Report on RCCS Testing with the Air-based Natural convection Shutdown heat removal Test Facility, ANL-ART-47, Argonne National Laboratory Page 34 of 146 109

SHORT CIRCUIT OF RCCS INLET / OUTLET

[58] Lisowski, D., Lee, T., et al., 2016. Final Project Report on RCCS Testing with the Air-based Natural convection Shutdown heat removal Test Facility, ANL-ART-47, Argonne National Laboratory Page 35 of 146 110

INGRESS OF NON-AIR GAS

1. System flow rates that quickly fell to nearly zero in about ninety seconds after initiation of the argon ingress sequence

2. Facility experienced near-total flow stagnation for a period of approximately eighteen minutes

3. Due to the cessation of bulk fluid movement and subsequent failure of its heat removal function, fluid and structural temperatures began to rise sharply

4. After approximately eighteen minutes, fluid temperatures in the riser tubes rose to a level sufficient to allow re-establishment of buoyancy-driven system Fig. Stagnation of system flow and subsequent rise in RV temperature [77]

flow Fig. Riser inlet (top) and outlet (bottom) temperatures during non-air gas event [77]

[77] Lisowski, D., Kraus, A., Lv, Q., Hu, R., 2021. Behavior of an air-cooled thermosiphon during a non-air gas ingress event. International Journal of Heat and Mass Transfer 175, 121155. Page 36 of 146 111

EVALUATION OF RELIABILITY AND PERFORMANCE 37 Page 112 of 146

SYSTEM LONGEVITY OVER PLANT LIFETIME The ability of an ex-vessel VCS installation to maintain intended function throughout the 40- or 60-year life of a commercial reactor could be contingent on the corrosion and structural integrity of material components.

38 of 146 Page 113

METEOROLOGICAL INFLUENCES (AIR-BASED)

For air-based ex-vessel cooling systems that rely on engineered chimney stacks to provide an intake of ambient air and discharge of heated exhaust, the influence of weather can play a major factor in influencing the behavior of airflow within the channels and cooling system 39 of 146 Page 114

WIND EFFECTS (AIR-BASED)

Wind direction will likely impact air-based RCCS and RVACS performance

- May influence flow velocities and/or symmetry across parallel paths

- Under severe conditions, can cause flow reversals within chimney stacks 40 of 146 Page 115

TWO-PHASE PHENOMENA (WATER-BASED)

Studies suggest the heat removal performance of water-based natural circulation systems may remain unaffected by two-phase and boiling-induced flow instabilities Thus, heat is likely to continue being effectively transferred from the core to an ultimate heat sink However, given the complexity inherent to a two-phase natural circulation system, there is a need to ensure understanding of all phenomena that may occur in these water loops 41 of 146 Page 116

BOILING INSTABILITIES Though heat removal performance has been shown to be relatively unaffected by system-wide oscillations, these instabilities do pose unique structural challenges If large magnitude vibrations are sustained, piping supports, bolted mating assemblies, loosened securement hardware, etc. are at risk and must be engineered accordingly 42 of 146 Page 117

SUMMARY

43 Page 118 of 146

SUMMARY

This review included previously published works available in the public domain, focusing on ex-vessel designs such as RCCS, RVACS, and hybrid iterations, using both air and water cooling to achieve their decay heat removal function The findings from this review identified a large number of studies that have produced a wide breadth of experimental data and computational tools in support of various ex-vessel cooling designs These studies, ranging from 1979 to the present day, have been led by both independent and collaborating institutions and resulted in the construction of several scaled experimental test facilities as well as the availability of numerous validated computational and analytical tools 44 of 146 Page 119

EVALUATION OF RCCS Based on an evaluation of the available data for the RCCS concept, many studies were identified that examined the role of design variations and operating conditions on the performance, heat removal function, and stability of these systems These were conducted across several institutions and resulted in the construction of a broad set of test facilities across multiple scales, using both air-and water-based cooling designs Computational modeling tools include diverse suite of analytical, system, and CFD level codes

- Modeling of air systems is mature and able to provide accurate predictions

- Challenges identified when modeling water-based systems that operate at low pressures and in two-phase or boiling flow regimes 45 of 146 Page 120

EVALUATION OF RCCS, AIR-BASED Studies of air-based RCCS concepts observed stable and adequate levels of heat removal performance when operating under steady conditions at normal or design basis accident levels of decay heat load Furthermore, the studies indicate that these systems can maintain their function during many off-normal scenarios, including blocked riser channels, transient chemical ingress, and asymmetries in heated profiles However, under start-up, low-power, or strong wind conditions, some studies observed natural circulation phenomena that challenged the systems ability to maintain symmetric flow within parallel channels 46 of 146 Page 121

EVALUATION OF RCCS, WATER-BASED Studies of RCCS systems that used water-based cooling observed a more stable response to external factors that readily degraded the operation of air-based concepts However, these water-based designs rely on a finite supply of cooling inventory that must be replenished during extended accident scenarios For systems that extend their operation into a boiling flow regime, they exhibit unique sensitivity to complex two-phase flow phenomena, which may induce large amplitude flow oscillations and create vibration concerns for structural components 47 of 146 Page 122

EVALUATION OF RVACS Studies that examined the capacity and heat removal performance of RVACS indicate that a high level of reliability and heat removal function can be expected during normal, accident, and degraded operating conditions Analytical predictions of the RVACS performance during unique off-normal scenarios, including partial and total blockage of air inlets and outlets, flooding, etc., yielded results that support the system's high tolerance and robust function However, these studies identified the need for additional experimental information about the air-side flow distribution, which authors indicate are necessary to verify the adequacy of the models used to represent these extreme scenarios Assessment of current and past experimental data produced for the RVACS design suggests a gap in the availability of multiple-scale test facilities that are similarly designed and share features common 48 of 146 Page 123 to a full prototypic concept

CLOSING REMARKS 49 Page 124 of 146

ACKNOWLEDGEMENTS Support provided by the Nuclear Regulatory Commission Office of Nuclear Reactor Regulation, under Task Order 31310020F0033 Project report published in public domain and available for access via OSTI Guidance and direction by NRC staff:

- Imtiaz Madni, Sr. Reactor Systems Engineer; Task Lead

- Maryam Khan, Project Manager; Contracting Officers Rep.

- Joseph Sebrosky, Sr. Project Manager; Atl. Contracting Officer Argonne co-authors:

- Qiuping Lv

- Bogdan Alexandreanu

- Yiren Chen

- Rui Hu

- Tanju Sofu 50 of 146 Page 125

THANK YOU www.anl.gov Page 126 of 146

Advanced Reactor Stakeholder Meeting Insights on Adapting Licensing Frameworks to New Non-Power Technologies Steven Lynch, Senior Project Manager Non-Power Production and Utilization Facility Licensing Branch Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission July 2021 Page 127 of 146

Non-Power Facility Licensing and Oversight

• U.S. Nuclear Regulatory Commission (NRC) responsible for 31 non-power reactors Routine licensing actions License renewal reviews Digital instrumentation and control upgrades Highly enriched uranium to low-enriched uranium fuel conversions Inspection and operator licensing

• Licensing infrastructure and policy Guidance development American Nuclear Society standard committee participation Advanced reactor licensing support Rulemaking development and support

• International activities, including International Atomic Energy Agency support

• Initial licensing reviews for medical radioisotope facilities Page 128 of 146 2

Status of United States Supply

• Currently, limited domestically-produced molybdenum-99 (99Mo) supply

• The United States 99Mo policy objectives are to:

1) Ensure a reliable supply of 99Mo

2) Eliminate highly-enriched uranium use in 99Mo production, and

3) Eliminate market subsidies

• Production encouraged by cost-sharing cooperative agreements between National Nuclear Security Administration and commercial partners Page 129 of 146 3

Supporting 99Mo Production

• NRC staff committed to efficient reviews of applications and inspections in accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR)

• Licensing and oversight activities support U.S. national security interests and nuclear nonproliferation policy objectives of establishing a domestically-available and reliable supply of 99Mo without the use of highly-enriched uranium

• Applications include initial license and license amendment requests for facilities proposing to manufacture, irradiate, and process low enriched uranium and molybdenum targets

• Oversight activities focused on preparation for construction inspection Page 130 of 146 4

Regulated Production Processes

• Target manufacturing Preparation of low enriched uranium (LEU) targets for irradiation

• Target irradiation Nuclear reactors Subcritical operating assemblies Accelerators

• Target processing Hot cell separation of 99Mo from irradiated LEU targets

• Medical uses of byproduct material Generators for extracting technetium-99m from 99Mo Page 131 of 146 5

Similarities to Existing Facilities

• Safety considerations comparable to non-power reactors:

Fission heat removal Fission product buildup Decay heat generation Accident scenarios Fission gas release

• and fuel cycle facilities:

Target manufacturing Criticality control Radiation protection Chemical hazards Material processing Page 132 of 146 6

Non-Power Licensing Process

• Applications contain both general and technical information

• Construction permit application Environmental report Preliminary safety analysis report (PSAR)

• Operating license application Update to environmental report, as necessary Final safety analysis report (FSAR)

• Applications may be submitted separately or together

• Testing facilities and commercial facilities may request limited work authorization to allow certain construction activities prior to the issuance of a construction permit Page 133 of 146 7

Regulatory Guidance and Acceptance Criteria

• NUREG-1537, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors

• Interim Staff Guidance Augmenting NUREG-1537 Radioisotope production facilities Incorporates relevant non-reactor guidance from NUREG-1520, Standard Review Plan for the Review of a License Application for a Fuel Cycle Facility, Rev. 1

• Other guidance (e.g., regulatory guides and ANSI/ANS standards) and engineering judgement used, as appropriate, to determine what is necessary for construction permit Page 134 of 146 8

NUREG-1537 Review Areas

1. The Facility/Introduction 11. Radiation Protection and Waste

2. Site Characteristics Management

3. Design of Structures, Systems, 12. Conduct of Operations and Components 13. Accident Analysis

4. Facility Description 14. Technical Specifications

5. Coolant Systems 15. Financial Qualifications

6. Engineered Safety Features 16. Other License Considerations*

7. Instrumentation and Control 17. Decommissioning*

8. Electrical Power Systems 18. Uranium Conversions*

9. Auxiliary Systems 19. Environmental Review

10. Experimental Facilities*

• May not be applicable to construction permit application for 99Mo facility Page 135 of 146 9

NRC Review Methodology

• For a construction permit application review, level of detail needed in application different than for an operating license application

• For the purposes of issuing a construction permit, the facility may be adequately described at a functional or conceptual level in the PSAR

• Applicants may defer providing many design and analysis details until the submission of its final safety analysis report (FSAR) with its operating license application

• Staffs review tailored to unique and novel technology described in construction permit application using appropriate regulatory guidance Page 136 of 146 10

Resolving Technical Issues of Preliminary Designs

• For technical areas requiring additional information, the staff has several options:

The staff may determine that such technical issues must be resolved prior to the issuance of a construction permit The staff may determine that such information may be left until the submission of the FSAR The staff may require that such technical issues be resolved prior to the completion of construction, but after the issuance of the construction permit

• In all cases, staff may issue requests for additional information

• In the second and third options, staff may track regulatory commitments or identify necessary license conditions Page 137 of 146 11

SHINE Operating License Application Review

• 99Mo produced by fissioning of low enriched uranium (LEU) solution using eight accelerator-driven subcritical operating assemblies

• 99Mo recovered by processing irradiated solution in three hot cells

• Facility to be located in Janesville, Wisconsin

• Operating license application submitted in July 2019 and accepted for review in October 2019 Page 138 of 146 12

Northwest Medical Isotopes

• NWMI proposes to manufacture and process LEU targets for 99Mo production Target manufacturing LEU targets irradiated at existing research reactors, including Oregon State University Irradiated targets returned to NWMI for processing Oregon State University TRIGA Reactor Source: OSTR Webpage Page 139 of 146 13

Prospective Applicants

• Niowave Accelerator-driven subcritical operating assembly, target processing facility, and target fabrication facility Currently conducting proof-of-concept technology demonstrations under an NRC materials license

• Eden Radioisotopes 2-megawatt thermal reactor with hot cell and target fabrication facilities to produce medical radioisotopes Joint construction permit and operating license application, including target fabrication activities, under development

• Atomic Alchemy Four non-power, pool type reactors and processing facility Quality assurance program under review Page 140 of 146 14

Licensing Accomplishments

• Issued two construction permits SHINE Medical Technologies (February 2016)

Northwest Medical Isotopes (May 2018)

Reviews completed in under two years from time of application docketing

• Published guidance in 2018 for medical use applicants and licensees possessing the NorthStar Medical Radioisotopes RadioGenix system Supported first commercial domestic production of 99Mo since Cintichem ceased operations in 1989

• Issued license amendment to OSU in 2016 for demonstration of 99Mo production in small nuclear reactor with experimental uranium targets

• Issued materials license to Niowave in 2015 License amendments issued increased LEU possession limit and supported irradiation of natural uranium targets using superconducting linacs for proof of concept Page 141 of 146 15

Construction Inspection

• NRC staff developed IMC 2550 in 2015 for construction inspection of new non-power facilities, consisting of three inspection procedures:

IP 69020 for safety-related structures, systems, and components (SSCs)

IP 69021 for quality assurance program IP 69022 for programmatic inspections

• Inspections commensurate with risk of facility, focusing on most safety-significant SSCs SHINE Construction Site in February 2020

• Formal construction activities began in October 2019 with the initial pouring of subgrade concrete.

Page 142 of 146 16

Reflecting Back

• For novel technologies, early interactions between NRC staff and applicants support efficient application processing and review

• Public pre-application meetings Promote engagement between NRC and potential applicant Inform the development of high-quality applications Inform budgeting and resource allocation Inform public of NRC process

• Best practices from construction permit application reviews:

Emphasis on most safety-significant technical aspects Focused requests for additional information Weekly status calls Page 143 of 146 17

And Looking Forward

• Continuing review of SHINE operating license application

• Updating licensing framework

• Anticipating technical and licensing challenges

• Engaging with potential construction permit applicants

• Supporting ongoing activities related to materials and medical use licensees

• Continuing interactions with construction permit holders on facility-specific conditions and annual reports Page 144 of 146 18

Impact of Medical Radioisotope Facility Reviews

• Experience gained from reviews supporting a more responsive and efficient technology-inclusive regulatory framework at the NRC

• Considering initial licensing of technologies beyond light water and non-power reactors

• Review of construction permit applications setting example for future advanced reactor reviews

• Success made possible through technical and licensing expertise provided by inter-office working group

• Updates on medical radioisotope facility activities available through NRC public website:

http://www.nrc.gov/reactors/medical-radioisotopes.html Page 145 of 146 19

Future Meeting Planning

• The next periodic stakeholder meeting is scheduled for August 26, 2021

• If you have suggested topics, please reach out to Margaret.O'Banion@nrc.gov Page 146 of 146