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Muhlheim, Michael D.

Publications and source records attributed to Muhlheim, Michael D..

Status Report on Regulatory Criteria Applicable to the Use of Artificial Intelligence (AI) and Machine Learning (ML)

Although the interest in the use of artificial intelligence (AI) and machine learning (ML) in nuclear energy is increasing rapidly, at present their implementation is limited. This rapid increase in interest is not surprising considering that implementing AI and ML technology would allow for continuous monitoring, facilitate the implementation of predictive maintenance with optimized staffing plans, enable automation and autonomy opportunities that could drastically reduce fixed operation and maintenance costs, and provide training for operations and maintenance. Other industries are using AI for construction, and in the nuclear arena AI could provide great benefit in decommissioning activities. The ability of AI and ML to operate in real time vastly increases their potential impact. Before AI can be used in design, operations, or as a regulatory tool, the specifics on the regulations applicable to the use of AI for nuclear power applications need to be established. The difficulty is that the specific use cases will dictate the applicability of regulations. For example, even within the application domain associated with operations, the regulations might vary if the AI is used to create a virtual reference for plant operations or is used for training, optimization of maintenance intervals, prioritization of maintenance activities, etc. Different still is if the AI is to be used for design or setting technical specifications, which will introduce additional requirements. US Nuclear Regulatory Commission (NRC) licensing reviews are based on an applicant’s design meeting its performance assessment based on (1) safety goals and objectives, (2) deterministic and/or probabilistic analysis of accident scenarios, and (3) quantitative assessment of design alternatives against the safety goals and objectives using accepted engineering tools, methodologies, and performance criteria. The current regulatory framework does not explicitly address AI or autonomous control. However, as implementing AI technology will require the use of a digital platform, it must meet the requirements of an instrumentation and control (I&C) system. The regulatory requirements for AI, which will be incorporated into the I&C system, will be very dependent on how it is used (i.e., its functionality, safety classification, etc.). The licensing process is primarily risk-based with the identification of components and systems as nonsafety, important to safety, or safety related. A risk-informed approach allows further gradation of components and systems based on risk metrics such as core damage frequency or large early release fractions. Thus, the use cases and the risk categorization of impacted systems and components will determine the regulatory requirements. Regardless of how AI is used it presents new opportunities for risk-informing operating, maintenance, and regulatory decisions. Trustworthiness, transparency, and the ability to validate and verify the results will be paramount in showing that the systems and plant still meet their performance requirements. This report describes the results of research to identify regulatory implications of AI technologies and their uses. Specifically, this report reviews current regulatory guidance relevant to the application of AI for design (including design changes or new designs including advanced reactors), construction, operations, training, maintenance, research, testing, and as a regulatory tool. AI can be automated at different levels from purely informative purposes to autonomous controls. The focus of this review included determination of constraints on the application of AI technology, identification of any regulatory gaps or uncertainties, and clarification of anticipated technical basis information likely to be important for regulatory acceptance of these technologies. Currently, any use of AI at nuclear power plants is focused on nonsafety-related applications. The NRC and other regulatory bodies are evaluating providing guidance to address gaps rather than create new regulations to address the use of AI and ML. This approach seems to be the best to encourage AI development without adding regulatory uncertainty.

97 MATHEMATICS AND COMPUTING↗

Assessment of Adequacy and Completeness of Standards Endorsed by Regulatory Guides to Molten Salt Reactors

The benefits of using voluntary consensus standards and industry guidance documents and reports are evident in the design and licensing of the current generation of nuclear power plants. The use of voluntary consensus standards and industry guidance and reports facilitates the design and licensing of advanced reactors to improve the effectiveness and efficiency of the licensing and regulation of non-light-water reactor (non-LWR) technologies. Most of the regulations, guidance, and standards applicable to nuclear power plants were developed for water-cooled plants, so they may not adequately address factors such as the coolants, materials, temperatures, operations, testing, and maintenance proposed for advanced reactors.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Criteria for Determining the Safety of Wireless Technologies at Nuclear Power Plants

This report provides an initial discussion of the potential impact to safety-related/important-to-safety (SR/ITS) systems by the possible expanded use of wireless technologies. One aspect of this discussion is focused on a review of Regulatory Guide (RG) 1.180 Rev. 2 to determine whether any revisions are necessary to reflect the current state of practice in evaluating and protecting instrumentation and control (I&C) systems and components from electromagnetic interference (EMI) or radiofrequency interference (RFI) on safety and nonsafety I&C. Electromagnetic compatibility (EMC) is the ability of a device or system to function satisfactorily in its electromagnetic (EM) environment, which is achieved by limiting the unintentional generation, propagation, and reception of EM energy that may cause unwanted effects such as EMI. The goal of EMC is to ensure the correct operation of different types of equipment in a common EM environment.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

Status Report on Regulatory Criteria Applicable to the Use of Digital Twins

This report describes the research results to date to identify regulatory implications of DT technologies and their uses. Specifically, this report reviews current regulatory guidance relevant to the application of predictive maintenance DTs, artificial intelligence (AI), and automation. The focus of this review included determination of constraints on the application of DT technology, identification of any regulatory gaps or uncertainties, and clarification of anticipated technical basis information likely to be important for regulatory acceptance of these technologies. The research included review of topical reports and other submissions to the US Nuclear Regulatory Commission (NRC) on technologies relevant to using DTs for predictive maintenance, NRC safety evaluation (SE) reports, and other relevant literature to identify specific regulatory concerns.

97 MATHEMATICS AND COMPUTING↗

Molten Salt Reactor Fundamental Safety Function PIRT

The phenomenon identification and ranking table (PIRT) process was employed to evaluate the current capability to assess the ability of liquid-salt–fueled molten salt reactors to achieve their fundamental safety functions (FSFs). The PIRT process provides a structured mechanism to elicit and document expert opinions on the most important phenomena and the corresponding level of knowledge with regard to achieving the FSFs. The PIRT panel included reactor developers, accident progression evaluation tool developers, US Department of Energy (DOE) national laboratory technical staff, university researchers, and US Nuclear Regulatory Commission (NRC) staff. The information-gathering process concentrated on phenomena related to accidents in which the fuel salt—including any in the cover gas—has been released from the first barrier layer. This information-gathering process included identifying all potential accidents that could result in the release of a substantial amount of radionuclides that could breach or bypass the first barrier. The PIRT did not identify any previously unrecognized systemic vulnerabilities. However, the elicitation process identified several areas with low levels of knowledge and significant potential impact on accident progression. These areas either require additional research to improve the state of knowledge or additional design conservatism to accommodate the remaining unknowns.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

Proposed guidance for preparing and reviewing a molten salt non-power production or utilization facility application

Development of non-power molten salt reactors (MSRs) are under consideration to further establish an MSR experience base, support the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.43(e), and provide any additional analyses needed for development of a full-scale MSR. Guidance provided in this report is based on MSRs operating with liquid fuel (i.e., fuel dissolved within a molten salt). These reactors, unless owned by the DOE or DOD, will require licensing by the US Nuclear Regulatory Commission (NRC) staff. Standard review plan (SRP) guidance for large light water reactors (LWRs) is available in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants; Light Water Reactor (LWR) Edition. However, NRC staff observed that NUREG-0800 is very cumbersome to apply to non-power reactors “because of the great differences in complexity and hazards between non-power reactors and nuclear power plants.” Therefore, a program to develop performance-based guidance applicable to non-power reactors was initiated. In 1996, NUREG-1537, Parts 1 and 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, was published. Part 1, the format and content guide, suggests a uniform format for presenting information in non-power reactor applications that is acceptable to the NRC staff, but conformance with the format and content is not required. Part 2, the SRP, ensures the quality and uniformity of the staff review of an application. Unfortunately, the application guidelines and SRP do not provide adequate guidance for all advanced non-LWR technologies and applications. This discrepancy eventually led to the 2012 development of interim staff guidance (ISG) for NUREG-1537, which includes criteria for describing and reviewing aqueous homogeneous reactors (AHRs). Specifically, NUREG-1537 ISG, 2012 expanded the original document to address three areas: 1. updated criteria for heterogeneous non-power reactors, 2. criteria for licensing AHRs, and 3. criteria for licensing a Part 50-licensed isotope production facility. In 2015, the US Department of Energy (DOE) opted to build on the AHR NUREG-1537 ISG experience by performing a gap analysis of the guidance that would be used to license a non-power MSR. MSRs represent one of the advanced non-LWR technologies selected by DOE for development through a multiyear cost share award with Southern Company Services. Under this Advanced Reactor Concepts 2015 (DOE Advanced Reactor Concepts [ARC] 15) award program, the DOE tasked Oak Ridge National Laboratory (ORNL) to evaluate the guidance changes that the NRC may need to consider when licensing an MSR non-power reactor. ORNL staff, with support from Boston Government Services, LLC, focused on five system-related chapters in NUREG-1537 that were considered most relevant to inform the effort that would be required for a non-power MSR applicant. ORNL documented this review in a technical report, ORNL/TM-2018/834, Proposed Guidance for Preparing and Reviewing Molten Salt Non-Power Reactor License Applications (NUREG-1537). The report was subsequently shared with industry and the NRC. The 2018 review was limited in scope, focusing on key system chapters based on the expected significance of each chapter relative to expected differences in addressing advanced non-LWR technologies, specifically non-power MSRs, compared with heterogeneously fueled non-power reactors. In the ORNL report, proposed generic adaptations were suggested for the following NUREG-1537 chapters: Chapter 4, “Reactor Description”; Chapter 5, “Reactor Coolant Systems”; Chapter 6, “Engineered Safety Features”; Chapter 9, “Auxiliary Systems”; Chapter 11, “Radiation Protection Program and Waste Management” The inclusion of Chapter 11 in the previous review effort was intended to provide guidance for categorizing the waste-handling process for an MSR operating with homogenous fuel. The introductions from Parts 1 and 2 of the 2012 NUREG-1537 ISG provide guidance for the application and review of production facilities. After a period of operation, non-power MSRs with homogenous fuel will include gaseous and soluble fission products. The gaseous fission products will be collected and held for decay in an off-gas system. There might also be an initiative to polish or filter the soluble fission products in the fuel salt by some mechanical or chemical means. The treatment and handling of fission products in the non-power MSR fuel salt and the description of this process in the safety analysis report (SAR) must be very precise to avoid the waste treatment facility being construed as a co-located special nuclear material (SNM) fuel cycle facility (see Section 2.3 of this report). Subsequent to the release of ORNL/TM-2018/834, NRC staff expressed a desire to continue the regulatory gap analysis that was begun in that report. This would provide additional clarity and information addressed in certain sections of the original report, while also providing new guidance on certain topics not addressed in the original report. This revision would benefit the NRC staff reviewing applications involving non-power MSR designs and would help developers understand how the NRC staff might approach the review of such applications. The focus of this report is to provide infrastructure support to the NRC staff for the regulatory review of non-power MSRs.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗