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Recommendations to Improve the Nuclear Regulatory Commission Reactor Licensing and Approval Process

Due to the urgency around climate change and associated goals for clean energy transition, and Battelle Energy Alliance's (BEA) and Idaho National Laboratory's (INL) role as the nation's nuclear energy laboratory, numerous stakeholders have asked for BEA’s thoughts and recommendations to reduce the time and costs associated with licensing new reactors at the U.S. Nuclear Regulatory Commission (NRC). As an M&O contractor for an FFRDC, BEA is a long-term partner with the Government in seeking to achieve clean energy goals, yet has a level of independence needed to appropriately evaluate this topic. The views herein are informed by extensive BEA experience supporting nuclear energy endeavors including ongoing discussions with current and former regulators, applicants, and licensees. With this background in mind, the United States benefits from having an agency such as the NRC, which is viewed internationally as the leader in nuclear safety licensing and regulation. Nonetheless, while acknowledging the important nuclear safety role satisfied by the NRC, it is apparent that one of the most significant time and resource intensive activities for new reactor developers is the NRC licensing process. The time and cost to obtain NRC licenses add significant financial stress for new reactor projects and may result in abandonment of projects or failure to even begin new projects. The challenge is particularly acute for advanced reactors which may raise unique or new regulatory questions and may be smaller in size, resulting in a much higher proportional impact from regulatory and cost challenges. This situation presents a particularly troublesome risk for the nation given the urgency in which utilities are working to transition to clean, non-carbon-emitting energy sources like nuclear energy. Reforms to the NRC licensing process have the potential to greatly increase certainty and support the successful progress of new reactors. The NRC can retain its world-class nuclear safety reputation while becoming a world leader for regulatory efficiency and a critical enabler to the clean energy transition. This report describes potential NRC reforms, focusing on those with a statutory connection. Recognizing the potential tradeoffs with any proposed changes, the report attempts to highlight those considerations in the analysis of the reforms. The recommendations are presented as a set of options for consideration. Unless noted, they are independent options, offering stakeholders the option to select a subset for further consideration. Although difficult to calculate precise time improvements for some of the changes, the reforms have the potential for substantial improvements, perhaps even by a factor of two.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

Progress Report: Continued Development and Advanced Testing of DPC Filler Cements

Commercial generation of energy by nuclear power plants in the United States (U.S.) has produced thousands of metric tons of spent nuclear fuel (SNF), the disposal of which is the responsibility of the U.S. Department of Energy (DOE). Utilities typically utilize the practice of storing this SNF in dual-purpose canisters (DPCs). DPCs were designed, licensed, and loaded to meet Nuclear Regulatory Commission (NRC) requirements that preclude the possibility of a criticality event during SNF storage and transport, but were not designed or loaded to preclude the possibility of a criticality event during the regulated post-closure period following disposal, which could be up to 1,000,000 years (Price, 2019).

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Duke Energy’s Integrated System and Operations Planning: A comparative analysis of integrated planning practices

Lawrence Berkeley National Laboratory and the National Renewable Energy Laboratory provided technical assistance to the South Carolina Office of Regulatory Staff to examine how Duke Energy’s Integrated System Operations Planning (ISOP) framework interacts with other electricity planning processes in South Carolina. While this report was prepared for the South Carolina ORS, the information contained herein may be useful to audiences in other states who are interested in IDP, including public utility commissions, state energy offices, other state agencies, utilities, and stakeholders. The report discusses how to access the ISOP process diagram created for the report, provides observations about Duke Energy’s ISOP from our interviews and review of publicly available materials; and assesses ISOP, based on best practices for integrated distribution planning.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

Modeling a Hypothetical Fusion Blanket Design Using MELCOR-TMAP

MELCOR (not an acronym) is a nuclear safety code developed by Sandia National Laboratories for the Nuclear Regulatory Commission. Idaho National Laboratory collaborates with Sandia to maintain and develop a version of MELCOR specifically for fusion device applications. Most recently, the tritium migration analysis program (TMAP) has been incorporated into MELCOR for fusion, in a version called MELCOR-TMAP. We show the results applying MELCOR-TMAP to model steady-state inventory and tritium retention in a liquid immersion blanket design for a hypothetical fusion device under steady-state operation.

70 PLASMA PHYSICS AND FUSION TECHNOLOGY↗

Past Approaches for Spent Nuclear Fuel, High-Level, and Transuranic Waste Disposal in the United States—Part 1: Safety Criteria and Treatment of Uncertainty

The United States (US), with its 50-year experience in developing deep geologic disposal for transuranic waste, spent nuclear fuel (SNF), and high-level radioactive waste (HLW), has much to share with other countries. Yet, other countries are better able to translate the US experience and corresponding policy decisions into solutions sensible for their country when they understand the compliance requirements in US laws and regulations. This paper presents past approaches in the generic and site-specific standards of the US Environmental Protection Agency (EPA) and implementing regulations of the US Nuclear Regulatory Commission (NRC) using the framework provided by (1) key questions of the Blue Ribbon Commission on America’s Nuclear Future, and (2) international consensus standards. Both the 1985 EPA generic standards, as updated in 1993 and applied at the operating Waste Isolation Pilot Plant in southern New Mexico for transuranic waste from atomic energy defense activities, and the EPA 2008 site-specific standards and implementing regulations, as applied at the proposed Yucca Mountain repository in southern Nevada for SNF and HLW, adopt the strategy of using quantitative, probabilistic analysis to assess performance and compliance.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

SCALE 6.3.3 User Manual

SCALE is a comprehensive modeling and simulation suite for nuclear safety analysis and design developed and maintained by Oak Ridge National Laboratory under contract with the U.S. Nuclear Regulatory Commission, U.S. Department of Energy, and the National Nuclear Security Administration to perform reactor physics, criticality safety, radiation shielding, and spent fuel characterization for nuclear facilities and transportation/storage package designs.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Pellet cladding mechanical interaction as a potential failure mechanism during a control rod drop accident in a boiling water reactor

Boiling water reactors (BWRs) represent approximately one-third of the operating fleet in the United States, contributing significantly towards the global effort in reducing carbon emissions. Even though most of the operating fleet has been in operation for quite some time, continued advancements in new nuclear fuel (such as accident tolerant fuel) or operating regimes (such as power up-rates and higher burnup operation) necessitates similar advancements in modeling and simulation capabilities. Bison, a component of the Virtual Environment for Reactor Applications (VERA), is a high-fidelity fuel performance code able to explore the fuel performance of a wide variety of fuel types in one-, two-, and three-dimensions. Until recently, the code had not been used for analyses of BWRs. Modeling capabilities have been added for Gd-bearing UO{sub 2} and pure zirconium liners. New models have been added based upon the U.S. Nuclear Regulatory Commission (NRC) guide-lines for hydrogen pickup in Zircaloy-2 claddings and pellet-clad mechanical interaction (PCMI) failure during a reactivity insertion accident (RIA), known as a rod drop accident (CRDA) in BWRs. Implementing and/or improving Bison modeling capabilities extended its analytical reach to areas beyond its original intended purpose. This paper demonstrates one of these capabilities as a proof of concept. Recently developed models enable Bison to provide an alternate approach for cladding integrity determination in CRDA evaluations, which currently use bounding conservative estimates. As part of this demonstration, NRC guidance on hydrogen-pickup and PCMI failure models were utilized in this research. Even though more research is needed in establishing right inputs and process in this area, this paper demonstrates Bison's ability to determine cladding integrity in a CRDA evaluation. This first of a kind demonstration is a proof of concept in this area, which could potentially be extended to a number of other areas where a more accurate cladding integrity determination would be needed. (authors)

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

PSA 2025 DPRA for Cyber Optimization

Cyberattacks can have many different attack paths, durations, and goals. There are also many different mitigation options involving hardware, software, and/or humans. Evaluating defense options should include quantitative evaluation of overall effectiveness to make cost and risk-informed decisions. Typical cyberattack modeling methods only provide a qualitative evaluation and have difficulty with time dependent scenarios. The main areas of cybersecurity are confidentiality, integrity, and availability. For companies with cyber-physical systems such as advanced nuclear reactors, cyber-related integrity is a requirement set by the U.S. Nuclear Regulatory Commission. But companies are also concerned about availability or reliability as a business case. As cyber threats are evolving to a business-for-hire structure, more attacks focus on disrupting business success and reliability, causing financial and economic stability risk. Companies want reliability analysis while optimizing cost, which requires more than safety modeling methods. Dynamic-state-based and Markov-based modeling provides a method for better cyber scenario modeling with timing and conditional features not found in other numerical evaluation methods. EMRALD (Event Modeling Risk Assessment using Lined Diagrams) is a dynamic risk analysis modeling and simulation tool and has features that reduce modeling issues such as state-base explosion found in Markov-based tools. It has been used to model different time-dependent events including plant behavior and operator procedures. As a general modeling tool, EMRALD can also be used to model cyberattack scenarios with varying mitigation options and quantify effectiveness, producing numerical data for risk-informed decisions. This paper uses EMRALD to demonstrate that dynamic risk analysis can be used for cyber threat modeling to provide insights for design decision-making and optimize defense strategies.

97 - MATHEMATICS AND COMPUTING↗

Integral LOCA fragmentation test on high-burnup fuel

Increasing the fuel burnup limit in light water reactors is sought to enhance fuel cycle economics and requires establishing a technical basis. Experimental observations of severe fuel fragmentation under loss-of-coolant-accident conditions at Halden and Studsvik had raised the need for additional considerations during the development of this technical basis. These test data suggested that the burnup threshold for high burnup fuel fragmentation may be influenced by pre-transient power. Additional loss-of-coolant-accident test data is therefore valuable to complement these tests and enhance the current state of understating. Oak Ridge National Lab has developed the Severe Accident Test Station capable of examining the oxidation kinetics and accident response of irradiated fuel and cladding materials for design basis accident and beyond design basis accident scenarios. Severe Accident Test Station provides various temperature profiles, steam, and the thermal shock conditions necessary for integral loss of coolant accident testing, defueled oxidation quench testing, and high-temperature beyond design basis accident testing. Severe Accident Test Station has been successfully installed and demonstrated in the Irradiated Fuels Examination Laboratory at Oak Ridge National Lab. Furthermore, descriptions of the in-cell re-fabrication capabilities and assembly of the loss-of-coolant-accident test train are provided. Installation of the Severe Accident Test Station system and in-cell re-fabrication restores United States capability to examine postulated and extended loss-of-coolant-accident conditions on spent fuel and cladding and provides a platform for evaluating advanced fuel and accident-tolerant fuel cladding concepts. Lastly, three in-cell integral loss-of-coolant-accident test were performed in the Severe Accident Test Station and compared to the Nuclear Regulatory Commission sponsored loss-of-coolant-accident test as well as the original loss-of-coolant-accident test performed at Argonne National Lab. Finally, the results of these tests as well as all publicly available integral loss-of-coolant-accident test were used to validate a threshold for high burnup fuel fragmentation.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Alaska Observed Hydropower Generation

This dataset contains compiled observed hydropower generation for hydropower plants in Alaska. Data have been compiled from data provided to the Energy Information Administration by asset owners, data contained in annual reports produced by the Institute of Social and Economic Research at the University of Alaska Anchorage (Alaska Electric Power Statistics and Alaska Energy Statistics) and data provided to the Federal Energy Regulatory Commission by asset owners. This dataset provides available generation data from all sources in monthly and annual files, with quality flags, and generation data identifying the highest quality source in monthly and annual files.

Broman, Daniel [Pacific Northwest National Laborat↗

Floating Photovoltaics in Hydropower Reservoirs in the United States

This report presents a comprehensive analysis of the feasibility of floating photovoltaics (FPV) in federally regulated reservoirs within the continental United States (CONUS) and to present a methodology for capturing the true costs of deployment, potential environmental impacts, and regulatory pathways for open-loop hydropower reservoirs. It is intended for stakeholders who may not be solar industry experts but who are interested in exploring the potential for FPV in their reservoirs. While there are promising opportunities, particularly in enhancing dissolved oxygen (DO) levels and potentially improving compliance with existing hydropower licenses, the current capital costs of FPV are not yet competitive with traditional land-based solar installations at the utility-scale when comparing the LCOE results. A competitive financial outlook is achievable when applying a 30% Investment Tax Credit (ITC) and considering a 5% reduction from the baseline capital expenditures (CapEx) at the Tuckertown Reservoir in North Carolina case study. The study is structured around three key pillars of research: technical potential, environmental impacts and regulatory considerations, and technoeconomic analysis. This report provides a nationwide assessment of the opportunities for FPV in terms of capacity, measured in direct current megawatts (MWDC), in reservoirs managed by the U.S. Bureau of Reclamation (USBR), the U.S. Army Corps of Engineers (USACE), and the Federal Energy Regulatory Commission (FERC). Additionally, the report introduces a heuristic model for estimating the CapEx of utility-scale FPV projects (1–100 MW), offering a baseline cost estimate for stakeholders. Finally, the report applies these models to a case study of a hydropower reservoir in North Carolina to present site-specific results.

13 - HYDRO ENERGY↗

Development and demonstration of a methodology to evaluate high burnup fuel susceptibility to pulverization under a loss of coolant transient

For economic reasons, the US nuclear industry is renewing efforts to build a technical basis to extend rod average burnup limits above the current regulatory burnup limit of 62 GWd/MTU. The primary driver is to increase pressurized water reactor cycle lengths to 24 months, reducing the number of fresh fuel assemblies and core design constraints, thereby making core energy utilization more efficient. However, fuel pellet fragmentation and pulverization, termed high burnup fuel fragmentation (HBFF), has been observed in the high burnup (>90 GWd/MTU) Halden loss-of-coolant-accident (LOCA) integral test series. The issue gained attention when fuel fragmentation and pulverization were also observed closer to the current US regulatory limit during the US Nuclear Regulatory Commission (NRC) sponsored out-of-core integral test at Studsvik Nuclear in early 2011. This led to NRC concerns with potential changes to fuel and core designs relative to fuel pellet pulverization. In a letter to the NRC Commissioners, the staff specifically identified a need to “…define the boundary of safe operation for key fuel design and operating parameters,” stating that “the staff is challenged to evaluate the acceptability of future fuel design advancements and fuel utilization changes.” As such, it can be concluded that HBFF and potential dispersal into the reactor coolant system introduces additional complications in light-water reactor (LWR) fuel safety evaluations. However, it is not clear how much fuel will be susceptible to HBFF; nor has there been a methodology developed to evaluate fuel susceptibility to HBFF. To that end, this paper proposes an analysis methodology to assess fuel susceptibility to HBFF during LOCA scenarios. The work presented here uses the BISON fuel performance code to evaluate a representative pressurized water reactor fuel rod exposed to a rod average burnup of 75 GWd/MTU. Sensitivity studies investigated the impact of the peak cladding temperature, transient fission gas released, and pre-transient fission gas release on cladding ballooning and burst timing. Subsequently, a methodology to assess fuel susceptibility to HBFF will be developed based on experimental data published in the open literature. The methodology will then be demonstrated by calculating the mass of fuel susceptibility to HBFF. The BISON results conclude that increasing peak cladding temperature drastically decreased time to failure, and decreased balloon size both of which have been confirmed experimentally. Additionally, the effect of pre-transient and transient fission gas release affected cladding balloon size and burst timing. Finally, fuel susceptibility to HBFF significantly decreased as a function of peak cladding temperature.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Challenge of Fielding Experiments at the Annular Core Research Reactor

Conference is the annual Test, Research &Training Reactors (TRTR) meeting. Typically attended by dozens of research reactor operators, educators, trainers, maintenance & service contractors Also, members of the Nuclear Regulatory Commission (NRC) attend. Presentation highlights ACRRs capability and the process used to submit and approve experimental activities. This presentation is adapted from my previous presentation to the Material Test and Research conference, SAND2025-1775526.

Martin, Lonnie E. [Sandia National Laboratories (S↗

Water reactive polyurethane grouting for deep vadose zone contaminant immobilization

Contaminants in the deep vadose zone (DVZ) pose a long-term threat to groundwater, human health, and the environment. Polyurethane grouting is a type of chemical grouting that is potentially advantageous in immobilizing contaminants in DVZs. Polyurethane resin has low viscosity that makes it feasible to penetrate and fill the pore space between fine particles. Here, in this study a series of laboratory pressure grouting and leaching tests were conducted to simulate and assess the effectiveness of polyurethane grouting for immobilizing contaminants in DVZs. Soil with fine particles was prepared with 127 I (as iodide) that served as a non-radioactive surrogate for radioactive 129 I. After grouting and curing, leaching tests were used to measure and compare contaminant diffusivity and leachability index values. Additionally, changes in porosity and saturated hydraulic conductivity of grouted soil were measured. X-Ray Computer Tomography (XCT) results showed that the cured polyurethane was distributed nearly homogeneously and approximately half of the voids were filled with cured polyurethane. Grouting reduced the saturated hydraulic conductivity of soil by 37 %. The effective diffusivity decreased by more than 80 % as compared with the ungrouted soil. The leachability index of the grouted soil was 6.5; meeting the criteria established by the U.S. Nuclear Regulatory Commission (NRC) standard. The results obtained in this study provide a valuable assessment of polyurethane grouting for iodide immobilization in the DVZ and indicate this approach may be a viable method for contaminant remediation in DVZ soils.

Contaminant Diffusion↗

Pressurized Water Reactor Containment Aerosol Settling Rate for Accident Source Terms

This report documents results from MELCOR calculations performed to determine the aerosol settling rate in pressurized water reactor containments in support of the Nuclear Regulatory Commission (NRC) Regulatory Guide (RG) 1.183, “Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors,” which is the methodology for determining alternate source terms in design basis accidents at nuclear power reactors.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Performing Numerical Analysis of Cybersecurity Options Using Dynamic Risk Analysis Tool EMRALD

Cyberattacks can have many different attack paths, durations, and goals. There are also many different mitigation options involving hardware, software, and/or humans. Considering a cyber threat should involve defense-in-depth methods and a quantitative or numerical evaluation of overall effectiveness against dynamic, time-dependent attacks to make cost and risk-informed decisions. Typical cyberattack modeling methods only provide a qualitative evaluation. The main areas of cybersecurity are confidentiality, integrity, and availability. For companies with cyber-physical systems such as advanced nuclear reactors, cyber-related safety is a requirement set by North American Electric Reliability and the U.S. Nuclear Regulatory Commission. They are also concerned about availability or reliability as a business case. As cyber threats are evolving to a business-for-hire structure, more attacks may focus on disrupting business success and reliability, causing financial and economic stability risk. Companies want to know business reliability and recovery from those threats, and that requires modeling physical behavior of the targets. Dynamic-state-based and Markov-based modeling provides a method for better cyber scenario modeling with different tools having issues such as state-base explosion. Dynamic modeling enables time and conditional features not found in other numerical evaluation methods. EMRALD (Event Modeling Risk Assessment using Lined Diagrams) is a dynamic risk analysis modeling and simulation tool and has features that reduce modeling issues. It has been used to model different time-dependent events including plant behavior and operator procedures. As a general modeling tool, EMRALD can also be used to model cyberattack scenarios with varying mitigation options and quantify effectiveness, producing numerical data for risk-informed decisions. This paper uses EMRALD to demonstrate that dynamic numerical risk analysis can be used for cyber threat modeling to provide insights for design decision-making and optimize defense strategies. Keywords: cyber modeling; cyber-physical systems; numerical cyber modeling

97 - MATHEMATICS AND COMPUTING↗

FERC Order No. 2222 and Considerations for Distributed Wind

The Federal Energy Regulatory Commission (FERC) issued Order No. 2222 in October 2020. The rule directs Regional Transmission Organizations and Independent System Operators (ISOs) to amend their tariffs and participation models to accommodate heterogeneous distributed energy resource (DER) aggregations in the wholesale energy markets that they operate, including capacity, energy, and ancillary service markets. The Commission issued the rule to better capture the benefits provided by DERs deployed in the United States, whose use has been expanding rapidly. The Commission defines DERs as “any resource located on the distribution system, any subsystem thereof or behind a customer meter,” including but not limited to “electric storage resources, distributed generation, demand response, energy efficiency, thermal storage, and electric vehicles and their supply equipment.” The rule aims to increase DER participation in wholesale markets by allowing the creation of DER aggregations, in which multiple DERs that are too small to meet minimum capacity requirements for wholesale markets individually would be able to participate in markets as a single unit. As of June 20, 2023, all ISOs have filed initial compliance plans and a number have begun implementation. Compliance dates range from 2024 to 2029, with Midcontinent ISO having the latest date of compliance proposed for 2029. Southwest Power Pool still has an outstanding date, having no final order yet from FERC, but a target date of the third quarter of calendar year 2025. The rule, which is technology agnostic and requires ISOs to create participation plans that accommodate different DERs, provides an opportunity for distributed wind market expansion. In addition, distributed wind can bring benefits to heterogenous DER aggregations. These benefits include resource diversity (i.e., a complementary generation profile to other types of distributed generation), its small footprint and ability to be co-located with load, and its potential to provide frequency response, voltage support, and black start services, among other ancillary services. This report provides a status update on FERC Order No. 2222, the current state of ISO compliance, and information relevant to the distributed wind industry as DER aggregators and other stakeholders expand their participation to wholesale energy markets.

17 WIND ENERGY↗

A Decision Support System to Compile Environmental Mitigations from Hydropower Licensing Documents

The process of deciphering, extracting, and compiling information from texts dense with domain-specific terminology and technical jargon is a challenging endeavor. It demands considerable expertise and deep knowledge in the respective field, resulting in a labor-intensive process when executed by humans. Furthermore, the task of identifying multiple class labels in extensive texts presents a challenge due to intra- and inter-reader variability, making the process time-consuming and costly.We’re introducing a user-friendly graphical interface, fortified with a BERT model-powered decision support system. This advanced system aims to augment efficiency, curtail data collection time, and sustain high precision in data acquisition. It is instrumental in deciphering and synthesizing intricate texts teeming with a spectrum of expressions, even within similar mitigation categories. Such tasks traditionally demand substantial human effort and specialized knowledge in the domain.Our system is specifically engineered for the task of extracting environmental mitigation information to promote sustainable hydropower development from licenses issued by the Federal Energy Regulatory Commission (FERC). These license documents are comprehensive, each containing over 15,000 words and requiring the identification of 135 different class labels. We anticipate that our system will boost reading speed, improve the consistency of classification outputs among readers, and contribute to the development of a robust scientific database of environmental mitigations associated with the 2,000+ non-federal hydropower facilities licensed by FERC in the United States.

Yoon, Hong-Jun [ORNL] (ORCID:0000000254505878)↗