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At least 271 records · Page 15

Explicate '78: Uncovering the Implicit Assurance Case in DO-178C

For about two decades, compliance with Software Considerations in Airborne Systems and Equipment Certification (DO-178B/ED-12B) has been the primary means for receiving regulatory approval for using software on commercial airplanes. A new edition of the standard, DO-178C/ED-12C, was published in December 2011, and recognized by regulatory bodies in 2013. The purpose remains unchanged: to provide guidance 'for the production of software for airborne systems and equipment that performs its intended function with a level of confidence in safety that complies with airworthiness requirements.' The text of the guidance does not directly explain how its collection of objectives contributes to achieving this purpose; thus, the assurance case for the document is implicit. This paper presents an explicit assurance case developed as part of research jointly sponsored by the Federal Aviation Administration and the National Aeronautics and Space Administration.

Holloway, C. Michael↗

A Systems Analysis Approach to Understanding the Physiological Adaptation to Spaceflight

This book is a summary of interdisciplinary research (physiology, space medicine, engineering, computer science, mathematics) that spans two decades (1972-1992). The research was an attempt to use systems analysis, mathematical modeling, computer simulations, and database systems to integrate the biomedical spaceflight data that was being collected during this period. The goal of the effort was to achieve a better understanding of the human physiological response to short-term and long-term space travel. The activity was primarily devoted to analyzing the biomedical results of Skylab (1973-74), a series of three space missions which is still ranked as the most comprehensive of all long-term biomedical space studies to date. This work was begun as a coordinated effort between the National Aeronautics and Space Administration (Johnson Space Center) and the General Electric Company’s Space Division (Houston, TX). It was the intent that this multidisciplined, integrative approach could reveal aspects of the then-new science of microgravity adaptation that were not obvious by adhering to the traditional methodology of examining each organ system in isolation. Some joint work with the Russians, including the Apollo-Soyez test project and a joint bedrest study was also supported during this period. In the 1980’s the systems analysis group’s effort was redirected to support the science management of human and animal experiments on the Space Shuttle. A few examples from this era are also included in the book. Parts of this work have been published elsewhere, presented at technical meetings, and documented in reports with limited distribution. These publications will be referenced throughout the text and the interested reader is advised to use these as resource material where additional details are desired. The intent of this book is not to reproduce these documents but rather to present a coherent view of the integrative analysis under one cover. This volume contains the first detailed publication (other than in internal reports) of an extensive metabolic balance analysis of Skylab data, the development and validation of the “Whole-Body Algorithm,” and simulation studies of diverse hypogravic environments. An analysis of cardiovascular deconditioning and a description of the calcium regulatory model are also new. A long period has passed between the completion of the main body of work represented in this book and its publication in this form. It was inevitable that new research efforts would lead to developments related to the spaceflight problems addressed and thereby make some of our biomedical conclusions obsolete. Although in some cases reference to more recent work have been included, for the most part this book should be considered an historical summary demonstrating the approach and utility of systems analysis and computer modeling in the NASA Life Sciences program at the time the studies were conducted.

Leonard, Joel I.↗

Maximizing Demand Flexibility with Buildings and FERC 2222

In 2020, the Federal Energy Regulatory Commission (FERC) approved a rule, Order 2222, that requires market operators to create pathways enabling distributed energy resource aggregators (DERAs) to compete in all regional organized wholesale electric markets. The goal is to encourage various forms of distributed energy resources (DERs) to participate in electricity markets in a way that would enhance competition, encourage innovation, and drive down costs for consumers. In this document, we briefly discuss how FERC Order 2222 affects the opportunities for participation in electricity markets for building owners and operators, the role of aggregators, and the involvement of buildings in the electricity market.

demand flexibility↗

Assessment of Acoustic Sensor Application to Structural Health Monitoring of Reactor Components

The objectives of SHM of advanced fission reactors include the following: (1) Maintain safe, reliable, and efficient operation of structures, systems, and components in accordance with design intent; (3) Reduce cost; (4) Improve the comprehensive life management of structures, systems, and components; and (5) Extend the operational life of a power system through retirement for cause. Advanced reactor designs currently being considered are expected to operate at higher temperatures than light water-cooled reactors and to support missions beyond baseload electricity generation. Methods to monitor and detect for these mechanisms will require structural health monitoring (SHM) techniques, with ultrasonic methods an ideal candidate given their widespread use for NDE. This document summarized the state of technology for ultrasonic technologies, as part of an assessment of technology gaps and needed research. The great majority of sensor development to date addresses elevated temperatures and radiation tolerance, and more work is needed in both areas. Little data exists regarding corrosion effects of advanced coolants on sensor materials and couplants. Of high importance is the need for ARDs and regulatory bodies to engage and define what level of SHM is needed for autonomous or semi-autonomous control of reactors.

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

Dynamic Model Agnostic Reliability Evaluation of Machine-Learning Models Integrated in Instrumentation & Control Systems

In recent years, the field of machine learning (ML), specifically neural networks, has grown significantly and has spurred research in its applicability to digital instrumentation and control systems (DI&C). While ML models have shown promise in operational contexts, the trustworthiness of using such algorithms has not been adequately assessed. Failures of ML integrated systems are not well understood, and the lack of comprehensive risk modeling can degrade the trustworthiness in these systems. In recent reports by the National Institute for Standards and Technology (NIST) [1] and the Nuclear Regulatory Commission (NRC) [2], they indicate that trustworthiness in ML is a critical barrier and will play a vital role in the safe, accountable, and secure operation of intelligent systems. Thus, in this work, we demonstrate a dynamic model-agnostic method to quantify the relative reliability of AI/ML predictions by incorporating out-of-distribution (OOD) detection on the training dataset. It is well documented that most ML algorithms excel at interpolation (or near-interpolation) tasks but experience significant performance degradation at extrapolation. The method, referenced as the Laplacian distributed decay for reliability (LADDR), determines the difference between the operational and training datasets which can used to the relative reliability of AI/ML predictions. LADDR is then demonstrated on a feedforward neural network based digital twin used for the prediction of safety significant factors during a loss-of-flow transient. LADDR is used to demonstrate how training data can be used as evidence to support the relative reliability of ML/AI predictions enhancing the overall trustworthiness of the system.

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

Joint Work Plan for DPC Filler Testing

The US generates approximately 2,000 Metric Tons of Heavy Metal (MTHM) of commercial spent fuel (SNF) each year and currently stores ~ 85,000 MTHM of commercial SNF at 70+ reactor sites, the disposal of which is the responsibility of the US Department of Energy (DOE). SNF is initially stored in spent nuclear fueld pools (SFPs). SFPs were initially constructed by US utilities for temporary fuel storage, but with no final disposal pathway available, SFPs are reaching capacity. To allow continued operation of the nation's commercial nuclear reactor fleet, utilities started transferring SNF from SFPs (wet storage) to dry cask storage systems, typically using dual-purpose (storage and transportation) canisters (DPCs). And while DPCs were designed, licensed and loaded to meet Nuclear Regulatory Commission (NRC) requirements that preclude the possibility of a critical event during SNF storage and transport, they 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). DPC filler option criteria are detailed and materials that exhibit these attributes are explored. This document is an update of the SNL Joint Workplan on Filler Investigations for DPCs.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Hybrid automated reliability predictor integrated work station (HiREL)

The Hybrid Automated Reliability Predictor (HARP) integrated reliability (HiREL) workstation tool system marks another step toward the goal of producing a totally integrated computer aided design (CAD) workstation design capability. Since a reliability engineer must generally graphically represent a reliability model before he can solve it, the use of a graphical input description language increases productivity and decreases the incidence of error. The captured image displayed on a cathode ray tube (CRT) screen serves as a documented copy of the model and provides the data for automatic input to the HARP reliability model solver. The introduction of dependency gates to a fault tree notation allows the modeling of very large fault tolerant system models using a concise and visually recognizable and familiar graphical language. In addition to aiding in the validation of the reliability model, the concise graphical representation presents company management, regulatory agencies, and company customers a means of expressing a complex model that is readily understandable. The graphical postprocessor computer program HARPO (HARP Output) makes it possible for reliability engineers to quickly analyze huge amounts of reliability/availability data to observe trends due to exploratory design changes.

Bavuso, Salvatore J.↗

Advancing Development of Emissions Detection (Final Report)

This document is the final report to the U.S. Department of Energy (DOE for contract DE-FE0031873) awarded to Colorado State University (CSU). CSU and partners at Harrisburg University of Science and Technology, University of Texas Arlington, and University of Texas at Austin organized several testing rounds to provide knowledge focused on advancing the detection capabilities of emissions monitoring devices. With this funding opportunity the research group began by establishing the Advancing the Development of Emission Detection (ADED) program, with the goal focused on enhancing the accuracy, reliability, and field applicability of methane detection technologies. This effort aimed to address the critical challenges of identifying and quantifying methane emissions while enabling industry stakeholders to meet regulatory compliance and environmental sustainability goals. The program engaged with industry, government, and technology stakeholders to promote adoption and consensus on testing techniques for methane detection solutions. Methane, a potent greenhouse gas, contributes significantly to global warming, and the oil and natural gas (O&G) sector is a primary source of methane emissions. Regulatory measures such as leak detection and repair (LDAR) programs have been implemented to address emissions. However, traditional LDAR approaches, reliant on handheld and component-level measurements, are resource-intensive. To address these limitations and move with evolving regulations, advanced methane technologies are emerging. These solutions include ground-based sensors, mobile systems (e.g., drones, vehicles, and aircraft), and satellite-based platforms. They offer innovative capabilities for autonomous monitoring, larger spatial coverage, and emission quantification using methods such as tracer gas techniques and inverse modeling with Gaussian plume analysis. The ADED program began with creating protocols for methane controlled release (CR) testing these continuous monitoring (CM) and survey technologies that detect and monitor methane emissions at O&G facilities. The protocols were then implemented throughout testing of CM and survey devices at CSU’s Methane Emissions Technology Evaluation Center (METEC) facility from 2021 through 2024. As apart of the protocol, solutions that tested under the ADED program installed their solutions at METEC, documented their system under test, and provided detection reports to the METEC team for analysis. The METEC team would provide the solutions with analyzed reports of their emissions and ground truth data of the releases conducted during their testing session. Under the ADED program, CMs were also tested at O&G facilities for a six week test run of challenge release (ChR) releases. The findings from the ADED program underscore the critical role of collaborative research and innovation in tackling methane emissions, offering a pathway for the oil and gas sector to achieve significant environmental and economic benefits. Results from METEC testing saw improvement of performance and accuracy across all solutions over the extent of the ADED experiments. The results also showed a variance in CM solution performance between CRs and ChRs. That variance pushed the team to further analyze the differences between CR testing environments and field conditions. With the drive from regulations and that variance in field conditions, the ADED team began designing a new CR testing protocol and additions to the METEC testing facility. The METEC team is furthering the progress made through the ADED program with awarded funding from DE-FE0032276. This funding pushes the development of METEC’s addition with new equipment, allowing for an updated facility layout. METEC still facilitates for traditional facilities, with a legacy pad, while expanding an new design based on how O&G infrastructure has Final Report - Contract Number: DE-FE0031873 been changed over the last decade. Throughout the ADED program the team has also been working with international partners to ensure staying in the trend globally. International partners have been essential in moving the new protocol forward to implement into CR testing at the METEC facility in Spring 2025.

42 ENGINEERING↗

Review of Software Packages for Local Intense Precipitation Flood Modeling

This report documents the review of the hydrologic and hydraulic modeling approaches used to estimate local intense precipitation (LIP) flooding and their implementation in readily available simulation software packages. The review focused on a few representative simulation software packages because of the similarity of their underlying mathematical bases and the rainfall-runoff and hydraulic processes included. Their availability for use in estimating LIP flood hazards and for U.S. Nuclear Regulatory Commission staff review of these estimates at the nuclear power plant (NPP) site scale were also considered.

54 ENVIRONMENTAL SCIENCES↗

Topics and Considerations for Developing State Geothermal Regulations

The intent of this document is to provide guidance to states for developing geothermal regulations that would be inclusive of all geothermal technologies (e.g., conventional and non-conventional power production and direct-use applications) with applicability in all states. As part of this project, the NREL project team reviewed and catalogued existing state and federal geothermal regulations, compiled best practices from geothermal and other extractive industries, and established a Geothermal Regulatory Stakeholder Working Group (SWG) to advise and review the geothermal regulatory guidance. The SWG met approximately monthly over the course of one year to review and discuss specific topics as relevant to this geothermal regulatory guidance. This report is broken into five main sections, which were identified in coordination with the SWG as the main topics for inclusion. Within these sections, a list of considerations within each category were identified and, in some cases, relevant examples from existing state and federal geothermal regulations are included to further illustrate the proposed considerations. This report includes the following topics: geothermal resource definition; leasing process; exploration approval process; drilling/wellfield development approval process; and underground injection control process.

15 GEOTHERMAL ENERGY↗

Topics and Considerations for Developing State Geothermal Regulations

The intent of this document is to provide guidance to states for developing geothermal regulations that would be inclusive of all geothermal technologies (e.g., conventional and non-conventional power production and direct-use applications) with applicability in all states. As part of this project, the NREL project team reviewed and catalogued existing state and federal geothermal regulations, compiled best practices from geothermal and other extractive industries, and established a Geothermal Regulatory Stakeholder Working Group (SWG) to advise and review the geothermal regulatory guidance. The SWG met approximately monthly over the course of one year to review and discuss specific topics as relevant to this geothermal regulatory guidance. This report is broken into five main sections, which were identified in coordination with the SWG as the main topics for inclusion. Within these sections, a list of considerations within each category were identified and, in some cases, relevant examples from existing state and federal geothermal regulations are included to further illustrate the proposed considerations. This report includes the following topics: 1) Geothermal Resource Definition; 2) Leasing process; 3) Exploration approval process; 4) Drilling/wellfield development approval process; 5) Underground injection control process In addition, a list of 'key considerations' summarized from this report are included below. This list is not meant to be exhaustive as each state's regulatory landscape is unique, rather these are meant to be concepts that can be considered when developing and/or updating existing geothermal regulations.

drilling↗

Startup Test Plan and Predictions for Highly Enriched Uranium to Low-Enriched Uranium Fuel Conversion at the University of Missouri Research Reactor

Nonpower reactors licensed by the U.S. Nuclear Regulatory Commission require a startup test plan as part of any facility modification to verify operability prior to resumption of operations. In order to support conversion of the University of Missouri Research Reactor from the use of highly enriched uranium to low-enriched uranium (LEU) fuel, a startup test plan has been devised to measure certain reactor physics parameters for the initial all-fresh LEU core licensing documentation that will be submitted. These parameters include the approach to critical, primary coolant void coefficient of reactivity, flux trap void coefficient of reactivity, determination of flux trap sample reactivity worth, radial and axial thermal neutron flux mapping, control blade worth calibration, primary and pool coolant temperature coefficient of reactivity, and flux mapping of experimental positions. Here, predictions for these parameters made using the Monte Carlo N-Particle Version 5 (MCNP5) radiation transport code are reported. These predictions will support the startup tests by providing a baseline set of expectations and additional insight into the performance of the LEU core.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Hazardous Chemical Inventory Guidelines, Purpose, and Process

The Environment, Safety, and Health Planning department at Sandia National Laboratories is interested in the purchase and storage of chemicals and their potential impact following an uncontrolled release. The large number of projects conducted at SNL make tracking every chemical purchase impractical; therefore, attention is focused on hazardous substances purchased in large quantities. Chemicals and quantities of concern are determined through regulatory guidelines; e.g., the OSHA Process Safety Management list, the EPA Risk Management Plan list, and the Department of Energy Subcommittee on Consequence Assessment and Protective Actions Emergency Response Planning Guidelines. Based on these regulations, a list of chemicals with quantities of concern was created using the Aerial Locations of Hazardous Atmospheres (ALOHA) and SCREEN View chemical dispersion modelling software. The nature of this report does not draw conclusions, rather it documents the logic for a chemicals of concern list to ensure compliance with various regulations and form the basis for monitoring chemicals that may affect hazard classification. Hazardous Chemical Inventory Guidelines, Purpose, and Process 4 This page left blank.

37 INORGANIC, ORGANIC, PHYSICAL, AND ANALYTICAL CH↗

Safety-Related Instrumentation and Control Pilot Upgrade: Conceptual - Detailed Design Phase Report and Lessons Learned

Historically, regulatory barriers have precluded nuclear plant safety-related (SR) Instrumentation and Control (I&C) system modernizations. These barriers have been largely addressed by industry and United States Nuclear Regulatory Commission (NRC) efforts, including development of the License Amendment Request (LAR) Alternate Review (AR) process for digital I&C upgrades. The U.S. Department of Energy (DOE) and the Idaho National Laboratory (INL) are supporting a SR I&C pilot upgrade at the Limerick Generating Station (LGS) to demonstrate this process and capturing associated lessons learned for the benefit of industry. In 2021, a paper summarizing lessons learned as captured in INL/EXT-20-59809, Safety Related Instrumentation & Control Pilot Upgrade Initial Scoping Phase Implementation Report and Lessons Learned was presented at the 12th NPIC & HMIT conference. It is recommended that readers of this paper review reference 1 or the associated Nuclear Journal paper for context. This paper summarizes activities performed and lessons learned for the conceptual design phase and portions of the detailed design phase as captured in INL/RPT-23-XXXX, “Safety-Related Instrumentation and Control Pilot Upgrade: Conceptual - Detailed Design Phase Report and Lessons Learned.” The portions of the effort covered by reference 2 include conceptual design phase activities from December 2020, through completion in November 2021, and detailed design activities through September 2022. These efforts and associated detailed documentation in reference 3 are intended to support similar industry upgrades as a foundation stone for a Digital Transformation that will improve plant safety, reliability, and operational performance while lowering plant total cost of ownership.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

MELCOR 2.2 Benchmarks of Peach Bottom NUREG/CR 7155 Uncertainty Analysis

The U.S. Nuclear Regulatory Commission (NRC) performed a first-of-a-kind uncertainty analysis (UA) of the accident progression, radiological releases, and offsite consequences for the State-of- the-Art Reactor Consequence Analyses (SOARCA) of an unmitigated long-term station blackout (LTSBO) severe accident scenario at the Peach Bottom Atomic Power Station. The objective of the UA was to evaluate the robustness of the SOARCA deterministic "best estimate results and conclusions documented in NUREG-1935, and to develop insight into the overall sensitivity of the SOARCA results to uncertainty in key modeling inputs. The study was completed in 2015 and documented in NUREG/CR-7155. Since 2015, two other SOARCA UAs were completed for two pressurized water reactor (PWR) plants. The PWR UAs incrementally updated the approach and methodology, including using the latest release of the MELCOR 2.2 computer code. There were also advances made in the state-of-the-art modeling related to NRC efforts using the Peach Bottom model in NUREG-2206, which provided the technical basis for the containment protection and release reduction rulemaking for boiling water reactors with Mark I and Mark II containments. This report documents the input model changes from the NUREG/CR-7155 study and performs a small number of reference calculations to assess the changes of the new computer code and the model input updates. The objective of the work is to verify whether the updated Peach Bottom MELCOR model and updated version of MELCOR support the conclusions formed in the Peach Bottom SOARCA UA by performing these representative calculations.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

Carbon Utilization and Storage Partnership of the Western United States

This technical report documents research conducted under DOE Award No. DE-FE0031837 focused on evaluating the feasibility of carbon capture, utilization, and storage (CCUS) systems in the central and western United States. The project integrated geologic characterization, reservoir simulation, infrastructure modeling, and economic analysis to assess CO₂ storage potential near industrial sources and develop strategies for transport and sequestration. The work included subsurface modeling, risk assessment, monitoring and verification (MRV) planning, and evaluation of regulatory pathways such as EPA Underground Injection Control (UIC) Class VI permitting and IRS 45Q tax credit eligibility. Results demonstrate the viability of multiple storage approaches, including saline formations, enhanced coalbed methane recovery, and basalt mineralization, supported by data-driven workflows and regional analyses. The project also produced permitting templates, technology transfer activities, and stakeholder engagement efforts to support deployment readiness. These findings contribute to the development of scalable, economically viable CCUS systems and provide a repeatable framework for future carbon management projects.

20 FOSSIL-FUELED POWER PLANTS↗

National Campaign (NC)-1 Strategic Conflict Management Simulation (X4) Community Based Rules

Projected demand for transportation services in the urban environment has led to the development of several Concepts of Operation for Urban Air Mobility, or UAM. UAM is a concept for the transportation of people and goods in the metropolitan environment using small, efficient aircraft over short distances as part of an expanding multimodal transportation network. UAM will leverage emerging technologies including electric Vertical Takeoff and Landing (eVTOL) aircraft, increasing levels of automation and a new operational paradigm in dense airspace where a set of agreed-upon rules govern the procedures and interactions defining a cooperative environment in which operators are entrusted with a range of functions typically conducted by Air Traffic Control (ATC). These rules, proposed in the FAA NextGen Office’s UAM Concept of Operations [1], were originally termed Community Based Rules or Community Business Rules (CBRs), and will in the future termed Cooperative Operating Practices (COPs); this document uses the original term, CBR. CBRs are a set of rules, developed by the UAM community and (where necessary) approved by the FAA that govern the interactions between UAM entities and limit the need for ATC services including, but not limited to, separation control by ATC, addressing a fundamental challenge to scaling UAM operations. UAM community development of CBRs is anticipated to accelerate the adoption of new practices while retaining the regulatory authority of the FAA within required domains (e.g., NAS safety, security and equal access). However, there currently exists no agreed industry forum or defined procedures for CBR development. Investigation of best practices for the development of UAM CBRs was identified by NASA and the FAA NextGen Office as a research need. In collaboration with seven industry partners, NASA participated in a series of simulations that investigated elements of the envisioned UAM operations, with a primary focus on Strategic Conflict Management (SCM). The development and conduct of cooperative UAM simulations with seven industry partners provided a unique opportunity to investigate CBR development practices. Development of CBRs for the UAM SCM simulations was conducted in parallel with simulation capability development and was closely related to requirements definition for the simulations. As such, the CBR development effort presented herein had two objectives: explore CBR development practices in collaboration with the industry partners and develop an initial set of UAM CBRs to support simulation requirements definition and development. Consensus was achieved among NASA and the industry partners on 24 CBRs that were developed to support the cooperative simulation operations across five topic areas: General (related to test requirements), Operational Intent, Conformance Monitoring, Demand Capacity Balancing, and Airspace Constraint Management. Additional topic areas and CBRs were discussed but were deemed outside the scope of the simulation; these are included in the appendices. A collaborative, iterative process was employed for developing the CBRs engaging both NASA and Industry; because CBR development is envisioned to be community-driven, opportunities were sought that provided industry partners leadership roles in developing CBRs. The following key observations and recommendations may aid the UAM industry in future CBR development efforts: - The lack of a defined process proved challenging initially. Stakeholder engagement in the early stages of CBR development was intermittent and may have been due to the lack of a clear definition of roles and responsibilities of those involved in the effort. - Industry leadership of CBR topic areas proved successful. Discussions in these topic areas were engaging, with alternate viewpoints freely discussed and detailed CBRs resulting. This points to the importance of identifying the best-suited leadership in technical areas for CBR development. - Discussions within a CBR topic area were typically dominated by only a few participants. Whereas all industry partners contributed to CBR development, within each topic area, technical leadership was evident even when not formally established. This observation may indicate that smaller, focused groups may be more effective in initial CBR development than an open forum or large standards development effort (although both maybe required prior to FAA review and approval for some CBRs). - Identifying suitable forums for initial UAM CBR development and identifying the most effective industry participants and leadership will be crucial for successful CBR development. Although the operational need for UAM CBRs may not be immediate, establishing the forums and leadership to define the processes for CBR development is a prudent early step to UAM realization.

Community Based Rules↗

Safety-Related Instrumentation and Control Pilot Upgrade: Initial Scoping Phase Implementation and Lessons Learned

In May 2016, the U.S. Nuclear Regulatory Commission (NRC) staff provided a digital instrumentation and control (I&C) regulatory infrastructure integrated action plan to the NRC for approval. One of the objectives of that plan was to establish a clear regulatory structure with reduced regulatory uncertainty to enable the expanded safe use of digital I&C in commercial nuclear reactors while continuing to ensure safety and security. To achieve this end, the NRC, with collaboration from industry, developed a streamlined License Amendment Request Alternate Review (AR) process for safety-related (SR) digital I&C upgrades. In spite of this effort, the industry has remained reluctant to perform such I&C upgrades because of perceived regulatory and financial risks associated with being the first or an early adopter of the AR process for SR I&C upgrades. The U.S. Department of Energy Light Water Reactor Sustainability Program at the Idaho National Laboratory performed Initial Scoping Phase research to help break this impasse by supporting a SR I&C Pilot Upgrade, working with MPR Associates, ScottMadden Inc., and Exelon Generation. Exelon’s Limerick Generating Station (LGS) was selected as the target for this research. This paper summarizes the Initial Scoping Phase engineering and operations, licensing, and project management activities necessary to bound the scope, schedule, and estimated cost of the project sufficiently to enable utility management authorization of Conceptual Design Phase activities. These efforts and associated products are intended to provide a template to support larger industry efforts to perform similar upgrades as a foundation stone for a digital transformation that will improve plant safety, reliability, and operational performance while lowering plant total cost of ownership. As a result of the combined effort of Exelon Generation and research participants, Conceptual Design Phase activities for the subject upgrade at LGS were approved by Exelon. Further, the U.S. Department of Energy also awarded a $50 million cost share award to Exelon in order to pave the way for SR I&C modernization and associated control room upgrades across the U.S. nuclear fleet. Additional research reports are planned for the Conceptual Design Phase, Detailed Design Phase, and the Implementation Phase of the LGS project to document the process followed and promulgate lessons learned to industry.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗