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At least 37 records · Page 2

Risk-Informed Initiating Events and Accident Response

Emerging nuclear technologies and advanced reactor developments have brought proposed changes to the regulatory framework which can be leveraged to improve safety implementation and regulatory oversight processes at existing operating nuclear power plants. Specifically, opportunities exist to make plants’ regulatory compliance processes more efficient. This can be done by decreasing reliance on purely deterministic and prescriptive approaches and expansion of the use of risk informed and performance-based approaches to demonstrate reactor safety while achieving economic gains and efficiencies. In this report, we researched possibilities of economic benefits potentially available from the application of concepts associated with a modernized regulatory framework developed for advanced reactors to the existing light water reactors. We used timing factors to demonstrate the complexity of the existing risk assessments and described how these complexities affect regulatory compliance activities at the plants. We also investigated regulatory framework for both existing and new reactors and provided an overview of potential improvements. Lastly, we evaluated various areas of existing plant operations where modernization of compliance activities can offer substantial benefits.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Risk-Informed Approach for Regulatory Approval of Microreactor Transport

Pacific Northwest National Laboratory (PNNL) is addressing the challenges associated with safe transport of microreactors including the development and evaluation of regulatory options. PNNL developed a risk-informed regulatory framework for the licensing of the transportation of microreactors in which irradiated nuclear fuel is part microreactor transportation package. The framework lays out a viable regulatory pathway, including decision points for regulatory options and the supporting technical evaluations for those options in phases from near to long term. A microreactor and its contents will likely not be able to meet all the federal regulatory requirements as a Type B or fissile material transportation package under 10 CFR Part 71 (“Packaging and Transportation of Radioactive Material”). However, the regulatory framework developed by PNNL lays out a viable risk-informed licensing options that are safe and feasible. Risk assessment such as probabilistic risk assessment (PRA) can be used to show comparable safety to that provided by a Type B or fissile material package for surface transport. The framework includes guidance on applicable regulations and discusses historical precedence in using risk information for transportation licensing. The framework includes guidance for performing a microreactor transportation PRA, use and development of risk evaluation criteria, and factors such of defense-in-depth and safety margin concepts. Key advantages of using the approach are (1) increasing the likelihood of successfully obtaining regulatory transportation package approval, (2) informing the design on the relative risk significance of microreactor containment and shielding, and (3) informing the need for transportation compensatory measures. This paper focuses on two primary elements of the framework which are development of a transportation PRA for microreactor packages and development of the risk acceptance guidelines to assess the results of the PRA for regulatory decision-making.

microreactor, micro nuclear power plant, MNPP, ris↗

Proposed Classifications of Remote Operations for Nuclear Reactors Based on Physical and Cybersecurity Considerations

The incorporation of remote operations into reactor operations is a topic of high interest among advanced and small modular reactor (A/SMR) vendors, with some considering it essential to the success of their business models. However, remote operations are a concept novel to the nuclear industry. While various technical aspects of remote operations have been explored, a significant gap remains in understanding the security implications of integrating remote operations into reactor designs, particularly concerning the security requirements for remote-operations facilities and infrastructure. This report aims to address this gap by first defining classes of remote operation based on the extent of remote access to reactor control systems and grounded in the existing regulatory framework with compatible terminology. Secondly, the report outlines the physical and cybersecurity requirements applicable to remote-operations facilities and infrastructure at each defined class. These requirements are based on existing licensing frameworks provided by 10 Code of Federal Regulations (CFR) Part 50 and 10 CFR Part 52, as well as the upcoming A/SMR licensing framework in the proposed Part 53. The assessment focuses specifically on security regulations, such as 10 CFR Part 73, which includes provisions for both cybersecurity (§ 73.54) and physical security (§ 73.55). This report proposes five classes of remote reactor operations. Class 1 involves remote monitoring only, with no control over reactor systems. Class 2 allows for the remote issuance of allowlisted commands to the reactor facility. Class 3 extends control to non-safety-significant, non-safety-related, or not important to safety systems and equipment. Class 4 permits remote control of safety-significant systems. Finally, Class 5 allows remote control of safety-related systems. It is important to note that these classes were defined purely with functionality in mind, without considering the practicality or feasibility of implementation for each class under current or upcoming regulatory guidance. The intention behind this approach is to enable an assessment of which security requirements apply to each class, allowing readers to evaluate the implementation possibilities for their specific use cases. Following the definition of remote-operation classes, the report assesses the specific physical and cybersecurity requirements applicable to the remote-operations facility and infrastructure within each defined class. This includes defining the types and locations of operators that are possible at each class of operation and, based on operator type and location, as well as functionality within each class, outlining the physical and cybersecurity requirements. By detailing the security requirements by class, the report provides readers with the information needed to determine the type of security program they may need to implement for their desired concept of operation. The next contribution of this report was to assess the practicality of implementing each proposed class of remote operations based upon the security requirement assessment. In short, three of the five proposed remote-operation classes were found to possibly have a practical path forward to implementation under the U.S. regulatory framework. Class 1 remote operations are currently in use in the U.S. while Class 2 and 3 remote operations may be logistically possible to implement under the U.S. regulatory framework. The final two Classes, 4 and 5, would likely be logistically difficult, if not infeasible to implement within the current U.S. physical- and cybersecurity regulatory framework. Given the results of the feasibility assessment, an example architecture is proposed for both Class 2, remote allowlisted commands, and Class 3, remote control of non-safety systems as well as security implication assessments of each architecture. These example implementations are not meant to be prescriptive in terms of how Class 2 or Class 3 remote operations should be deployed; instead, they are intended to be informative to stakeholders on how Class 2 or Class 3 could potentially be applied in order to inform their system design. An example architecture for Class 1 remote monitoring was not provided as Class 1 in already in use in U.S. nuclear operations. Example architectures for Class 4 and Class 5 were not provided due to their assessment of being likely infeasible to implement. The final contribution is an assessment of the physical- and cybersecurity implications of introducing autonomous operations into an A/SMR. What was found was that the security implications can be separated into two cases. Autonomous operations supported by SSCs located only at the reactor site, and autonomous operations supported by SSCs outside of the reactor site. For the first case, the introduction of autonomous systems will likely not change the facility’s requirement to comply with existing cyber and physical security regulation

22 - GENERAL STUDIES OF NUCLEAR REACTORS↗

Viable Economic Frameworks and Regulatory Barriers for Community Microgrids

Community microgrids – microgrids with more than one piece of customer- and utility-owned distribution equipment contained in the isolation boundary – are an option for providing resilience to meet targeted community and utility needs. Because multiple investors, including customers, are involved there is a lack of clarity around viable ownership models, roles and responsibilities, and compensation mechanisms. Together, these aspects describe an economic framework. To be viable, an economic framework not only needs to provide the possibility of all parties agreeing to the microgrid but also needs to meet regulatory guidelines. This report contains learnings from present-day community microgrid tariffs and programs, regulatory filings, and experiences shared within an interest group to highlight regulatory barriers to community microgrids and identify several viable economic frameworks for community microgrids.

24 POWER TRANSMISSION AND DISTRIBUTION↗

Battery Energy Storage System (BESS) Licensing and Permitting [Slides]

This presentation provides an overview of the licensing, permitting, and regulatory frameworks governing Battery Energy Storage Systems (BESS) across multiple international contexts. It outlines foundational permitting considerations - including safety standards, siting requirements, regulatory and environmental obligations, and interconnection processes - alongside typical pathways for installation, approval, and inspection. The presentation summarizes key technical standards such as NFPA 855 and IEEE guidelines, and emphasizes best practices for safe and effective deployment. A series of detailed case studies from South Africa, Chile, Mexico, Brazil, Costa Rica, Honduras, and the Dominican Republic illustrates how different countries structure approval authority, evaluate environmental impacts, and integrate BESS into national grid systems. The deck concludes with insights on emerging challenges, including evolving regulatory frameworks, financial viability, and the need for pricing mechanisms that accurately value storage services.

24 POWER TRANSMISSION AND DISTRIBUTION↗

A structural description of the evolution of stakeholders and risk communication in the Department of Energy's defense nuclear facilities: Historical perspective, major stakeholders, and external events

Regulators and policymakers are routinely challenged with explaining complex concepts concerning risk. Part of the challenge is helping external and internal stakeholders to understand the context behind risk-related information and decisions. Here, this paper will describe the historical evolution of the safety and regulatory framework for an important category in the nuclear industry—defense nuclear facilities owned and operated by the US Department of Energy. In parallel with describing this evolution, three major events which occurred external to the complex of defense nuclear facilities will be summarized, and their impact on the maturation of the Department's safety and regulatory framework will be discussed. Finally, integrated with these two threads of discussion will be a chronicle of the changing set of involved organizations and the expanding set of external stakeholders involved in risk decisions—and therefore, the risk communications ecosystem surrounding defense nuclear facilities. It will be noted that this system was once describable as a classic “iron triangle,” but now has progressed to a complex network of federal and state organizations, numerous congressional committees, and expanding sets of external stakeholders. It is hoped that a comprehensive discussion of the context of risk assessment in the defense nuclear facilities complex—addressing historical insights, organizational evolution, and the maturing structure of regulation—will provide enhanced opportunities for building trust and understanding in this complex environment.

98 NUCLEAR DISARMAMENT, SAFEGUARDS, AND PHYSICAL P↗

CCUS Perspectives: Assessing Historical Contexts, Current Realities, and Future Prospects

CCUS technologies are crucial solutions for mitigating climate change by reducing CO2 emissions from industrial operations and energy sectors. This review critically examines the current state of CCUS technologies, and highlights advancements, challenges, regulatory frameworks, and future directions. It comprehensively analyzes carbon capture methods, such as pre-combustion, post-combustion, and oxy-fuel combustion capture, while comparing their efficiencies and limitations. The review also explores carbon utilization techniques, such as direct and indirect utilization, emphasizing their potential applications and technological constraints. Additionally, it assesses various carbon storage methods, focusing on geological, ocean, and mineralization storage, and discusses their capacity, feasibility, and environmental implications. The study reviews the policy and regulatory frameworks, economic viability, market trends, and environmental sustainability of CCUS. By identifying research gaps and recommending future research priorities, this review aims to guide the development of more efficient/effective, and cost-effective CCUS technology, ensuring their role in a sustaining low-carbon future. This review provides a forward-looking perspective, a critical and interdisciplinary analysis that assesses the current state of CCUS technologies, and further provides a roadmap for future development.

Energy & Fuels↗

Soil Desiccation Treatability Testing at BC Waste Disposal Cribs

During Hanford’s production period, low-level waste products generated from chemical processing of uranium fuel rods were discharged directly to the ground through a system of cribs and trenches located in the 200-BC-1 Operable Unit (OU). The site consists of 6 cribs and 20 trenches that received more than 117,000 m3 of radioactive liquid waste discharged to the soil. These unlined infiltration galleries held volumes of liquid waste while it seeped into the ground, with the understanding that the 100 m (330 ft) thick vadose zone in the area would effectively capture the effluent and prevent groundwater impacts. A conceptual model showing the operation of cribs and trenches is shown in Figure 1. Data show effluent from the 26 cribs and trenches containing about 410 curies of Technetium-99 (Tc-99) is primarily located between 30 m and 70 m (98 ft and 230 ft) depth (Corbin et al., 2005; Ward et al., 2004). Despite no evidence indicating that the contamination has reached the groundwater at BC cribs and trenches, the mobility of Tc-99 had been demonstrated in laboratory tests and was recognized as a threat to groundwater at the site. Using data from numerical models, laboratory analyses, field investigations, and information on historical discharges, the EPA and Ecology identified Tc-99 and U contamination of the vadose zone as a remediation priority. The U.S. DOE was notified by EPA and Ecology regarding risks associated with Tc-99 contamination in a letter requesting development of a strategy for improved methods to understand the nature and extent of vadose zone contamination, specifically Tc-99, and to develop remedial options for addressing such contamination. To develop the appropriate technology for characterizing, remediating, and monitoring the deep vadose zone Tc-99 contamination, the U.S. DOE worked with the EPA and Ecology to create a Treatability Test Plan under a Remedial Investigation/Feasibility Study (RI/FS) for the Hanford 200 Areas. Under this RI/FS, it was determined that a treatability test for soil desiccation should be carried out as it was identified as a promising in-situ treatment technology for mitigating risks posed by Tc-99 contamination to the groundwater table. The BC Cribs and Trenches site was identified as a representative site for Tc-99 and U contamination and selected for the soil desiccation treatability test. In this chapter, we summarize the overlying regulatory framework of RI/FS and treatability tests and illustrate how development and experimentation supported the evaluation of selected remedies. We briefly discuss the RI/FS for the 200 Areas of the Hanford Site and focus on the soil desiccation treatability testing performed at the BC cribs and trenches site under the Deep Vadose Zone Treatability Test Plan for the Hanford Central Plateau (DVZ-TT). The DVZ-TT is one component of the remedial investigation/feasibility study for the Hanford 200 Areas and represents the underlying regulatory framework that drives site operations towards records of decision and site closure.

Mangel, Adam R.↗

Evaluating Probability of Containment Effectiveness at a GCS Sites using integrated assessment modeling approach with Bayesian decision Networks

Improved scientific and engineering understanding of the behavior of geologic CO2 storage together with established regulatory framework and incentive structures raise the prospects for accelerated, large-scale deployment of this greenhouse gas emissions reduction approach. Incentive structures call for the establishment of appropriate verification and accounting approaches to support claims of the integrity of a geologic storage complex and to justify taking credit for long-term storage. In this study, we present a framework for assessing the probability of containment effectiveness over the lifetime of a geologic carbon storage site (e.g., after 70 years of injection and post-injection site performance) using forward stochastic model realizations based on site characterization data and using a monitoring-informed Bayesian network based on hypothetical detectability from surface seismic surveys over the site injection and post-injection phases. The National Risk Assessment Partnership’s open-source Integrated Assessment Model (NRAP-Open-IAM) was utilized to develop an ensemble of 10,000 a priori stochastic forecasts of CO2 containment. Those simulations were used to train the Bayesian network model to estimate the prior probabilities of the CO2 leakage mass into overlying, monitorable aquifers considering the uncertainties in the reservoir properties, permeability of potentially leaky wells and the overlying aquifers. The conditional probabilities in the Bayesian network were either learned from the NRAP-Open-IAM simulations or derived from the predefined detection thresholds for the monitoring method. Observations obtained from monitoring, over time during the site operation phases were then used to generate updated posterior probabilities of containment (and any loss from containment) in the Bayesian network by propagating the prior probabilities through the conditional probabilities. We demonstrate how to construct and use the Bayesian network for verifying the long-term storage complex effectiveness informed by monitoring based on the NRAP-Open-IAM simulations previously developed for the FutureGen 2.0 site. This approach may have relevance for stake holders to demonstrate secure geologic storage, provide a defensible, probabilistic approach to claim credit for geologic storage, and to estimate the likelihood that any fraction of the claimed credit may need to be refunded to the creditor based on available monitoring information.

Bayesian network, Risk assessment, Monitoring, car↗

Applicability of the Milestones Approach to Deployments of Transportable Nuclear Power Plants (TNPPs)

Transportable nuclear power plants (TNPPs) can provide potential benefits to countries embarking on nuclear programs, offering reduced infrastructure requirements, shorter timeframes for implementation, cost savings and greater deployment flexibility than larger conventional reactors. However, the deployment of a TNPP in a Host State comes with the obligation to establish sufficient regulatory, institutional, and technical infrastructure, which, among others, includes a legal and regulatory framework and a competent regulatory body to implement a State’s safeguards obligations. This paper considers how the unique technical and deployment features of TNPPs may affect the process of preparing for and implementing safeguards in nuclear newcomer countries. Evaluating this issue through the lens of the IAEA’s Milestones Approach, this paper discusses some potential implications arising from the shortening of some milestones phases due to reduced construction or licensing time for TNPPs, and the need for increased cooperation between Host States and Supplier States in preparing for and meeting certain safeguards obligations. These considerations are potentially relevant to various stakeholders: newcomer States considering TNPP deployment; the States and companies that supply such reactors; as well as organizations that support international safeguards capacity building.

Siserman-Gray, Ioana-Cristina↗

Reliability and Integrity Management Scoping Study

The U.S. Nuclear Regulatory Commission (NRC) is developing the regulatory framework and technical expertise to support regulatory review of advanced non-light water reactor (ANLWR) designs. The NRC staff expects most of these designs to use the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC) Section XI, Division 2 “Requirements for Reliability and Integrity Management (RIM) Programs for Nuclear Power Plants” for developing and implementing pre-service inspection (PSI) and in-service inspection (ISI) programs. The NRC recently endorsed ASME BPVC Section XI, Division 2 (BPV XI-2) in Regulatory Guide (RG) 1.246. This new ASME code is yet to be used in any applications submitted for NRC review. This report provides an overview of the current state of knowledge and practices within the industry for the use of BPV XI-2 for the development and implementation of a PSI and ISI program for non-light water reactors.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Application of Electrochemical Methods to Molten Salt Reactors: Draft TLR Documenting Assessment of Electrochemical Monitoring

Nuclear Regulatory Commission (NRC) is developing the regulatory framework and technical expertise to support regulatory review of advanced non-water reactors, including molten salt reactors (MSRs). In an MSR, it is essential that the salt chemistry be maintained in a desired range in terms of redox potential for reliable operation and mitigation of corrosion to structural materials in the reactor, particularly the reactor vessel and heater exchanger. Measuring the redox potential of the salt in the reactor would also allow for the material lifetimes to be predicted more accurately, and chemical issues to be diagnosed more quickly. In addition to the chemical composition analysis by ICP-MS, electrochemical methods including potentiometry and linear wave scanning (LSC) were also used in molten salt reactor experiment (MSRE) for redox potential monitoring purposes. Electrochemcial methods offers unique advantages such as quick turnaround in results and unique capability of in-line monitoring of redox potential, and are considered popular electroanalytical techniques that can be used to monitor redox potentials and salt chemistry including impurities. The last two decades have seen significant advances in science and engineering of electrochemical methods for potential application to molten salts. The primary goal of this report is to assist NRC in understanding the monitoring of the salt chemistry by electrochemical methods and provide NRC reviewers with necessary information and tools to support regulatory review of MSR designs. This reports consists of two majors parts—Part 1, chemical potential of molten salts and effects by fission process in MSR; Part 2, assessment of electrochemical methods for application to MSRs. The TRLs of the typical relevant electrochemical methods for molten salts were evaluated based on the DOE TRL guidelines and upon a review of the current status of the electrochemical methods for two typical salt systems, fluoride and chloride, for MSRs.

11 - NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Regulatory Considerations Regarding Potential High Temperature Fluid Releases in Advanced Reactor Designs

The current effort is supported by the U.S. Department of Energy (DOE), Advanced Reactor Demonstration Program (ARDP) Regulatory Development, Regulatory Framework Modernization area, which seeks to address potential regulatory challenges for advanced reactor vendors that are currently or will soon be initiating the licensing process. In pursuit of this goal, this effort seeks to aid the advanced reactor industry and regulatory bodies in understanding and addressing the potential occurrence of high-temperature fluid releases in advanced reactor designs as part of licensing and regulatory oversight of operation. Improving the awareness and understanding of the behavior and potential consequences associated with high-temperature fluid release events can ensure that they are appropriately considered and addressed.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Waste Management Project Success - Regulatory Assurance Systems - 20118

Waste management (WM) and remediation projects are essential within a restorative environmental culture. Despite years of experience, challenges and obstacles associated with efficient and effective WM project execution remain. Although some obstacles are project specific, a common challenge is navigating the regulatory landscape from planning through execution, particularly with first of a kind (FOAK) and first in a while (FIAW) projects. The absence of a comprehensive regulatory assurance strategy places significant hurdles in the path of project success. To clear a path for the successful execution of increasingly complex WM projects, this paper focuses on development of a comprehensive regulatory assurance strategy and implementation plan that effectively engages stakeholders, agencies, and performers to produce project plans that fully and cost effectively integrate applicable regulatory requirements. The most reliable way to align regulatory processes and decisions needed for mission success is through a regulatory assurance system. This system establishes a healthy interface with regulatory decision makers, to work in a collaborative manner, to create a common vision for regulatory decisions on an agreed upon schedule. A regulatory assurance system consists of several elements. Although the mission may vary from cleanup to site closure to nuclear component production, the elements of a regulatory assurance system remain essentially constant and must include: 1) identifying a common vision or end state, 2) developing a long-term, integrated strategy and schedule, 3) establishing a regulatory partnering team consisting of key decision-makers, 4) regular and frequent communication with decision-makers, 5) ensuring consistent surveillance for early identification of issues and changes that may impact the project, 6) quick resolution of emerging issues to prevent schedule impact, 7) identifying core compliance functions, 8) periodically assessing progress of the project as it relates to regulatory assurance and, 9) providing constructive feedback to improve the process. A regulatory assurance system provides a living, multi-faceted approach to planning, visioning, communicating and tracking to avoid surprises and ensure smooth and timely progress to the project. The overall success measures will be whether the system produces common sense regulatory decisions supporting the vision on time without appeal. Effective regulatory frameworks rarely happen on their own. Balanced, common-sense regulatory decisions stem from teams that are trained to work together to achieve shared goals. In this paper, particular attention is placed on the importance of starting with a shared vision for a regulatory assurance and execution strategy that leverages experience to establish optimal approaches. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Challenges in Demonstrating Safety Criteria Satisfaction for External Events under a Risk-Informed Performance-Based Framework

The NRC is currently developing 10 CFR Part 53 that would establish a technology-inclusive regulatory framework for use by applicants for new commercial advanced nuclear reactors. The new draft rule language brings new explicit regulatory requirements of the quantitative health objectives (QHOs) as a constraint on plant risk and safety criteria for the plant design, including external hazards. Historically, light water reactors (LWRs) have demonstrated satisfaction of the QHOs through the use of surrogates in the form of CDF/LERF. However, these risk surrogates are not broadly applicable for all advanced reactor types, and for advanced reactors where external events are likely to be the dominant contributor to plant risk, a direct calculation of the QHOs in terms of offsite consequence is likely necessary. While the detailed analysis of low frequency events provides insights that can help justify alternative treatments to past conservatisms, the findings are dependent on the quality and confidence associated with the analyses. The assessment of external hazards presents a unique challenge, as their potential frequency of occurrence, especially of largemagnitude events, is inherently uncertain given the long return periods in question. This paper evaluates the QHOs and their potential role as safety criteria in evaluating external event risk as it applies to advanced reactors to aid in the development of consistent and appropriate analysis methodologies.

Chen, Ben↗

Regulatory Considerations for Domestic Reprocessing Facility Physical Security

U.S. advanced non-light-water reactor vendors may pursue collocated on-site reprocessing activities. Therefore, these facilities are likely to possess formula quantities, or Category I quantities, of special nuclear material (SNM) during normal operations. The U.S. Nuclear Regulatory Commission (U.S. NRC) has yet to formally establish a regulatory framework for commercial reprocessing. While Category I requirements would explicitly not apply in this circumstance under current regulatory requirements, regulatory certainty does not exist. A novel framework should be developed to ensure public health and safety while also risk-informing the physical security requirements. This report reviews the relevant background of related rulemaking activities and proposes risk-informed physical protection requirements to satisfy these objectives. Insights from NRC security-related rulemaking activities provide a substantial technical basis to approach potential establishment of physical security requirements for reprocessing facilities. If a licensee can provide justification that the material satisfies a sufficient self-protecting radiation dose threshold, the material may not be subject to theft or diversion requirements and only potential sabotage requirements would apply. Furthermore, if the material can be justified to be moderately dilute, a set of risk-informed requirements could provide adequate protection of public health and safety. A revised performance objective for prevention of theft of moderately dilute Category I SNM may be detection to allow prompt recovery by a local law enforcement agency. However, a significant caveat to the proposed categorization scheme is the unknown integration of radiological sabotage with requirements for the protection against theft. Future licensees should consult with the NRC regarding treatment of this regulatory topic. Additionally, the self-protecting radiation dose threshold (either the existing or a proposed future threshold) would need to be considered. An integrated approach may apply graded potential requirements for protection against the design basis threat of radiological sabotage currently applicable to commercial nuclear power plants and Category I SNM facilities defined within 10 CFR 73.1(a).

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

A Community Guide to Regulatory Barriers Affecting Microgrids (Reports 1-3)

In response to growing risks of power outages from extreme weather and aging infrastructure, communities are increasingly exploring the potential of microgrids to provide reliable energy access. Microgrids offer promising solutions to meet this challenge but face a complex landscape of non-technical barriers, particularly regulations concerning the provision and distribution of energy. Most existing legal and regulatory frameworks were designed for a centralized, one-way power system, and are often poorly suited to handle systems that independently balance distributed energy resources with local load. This three-part report series provides a strategic analysis of existing regulatory and legal factors affecting microgrid deployments to help non-technical community leaders and decision-makers better understand the feasibility of a microgrid in their community. -Report No. 1: Foundational Issues Facing Microgrids details the universal policy barriers all microgrids face, including utility interconnection processes, rate structures, and local permitting. -Report No. 2: Single Property Microgrids outlines how direct asset ownership and operating behind-the-meter can bypass some regulatory oversight, using the Blue Lake Rancheria microgrid as a case study. -Report No. 3: Multi-Property Microgrids tackles the complex challenges of crossing public rights-of-way and navigating utility franchise rights, highlighting the Coventry microgrid project. The series equips decision-makers with phased frameworks to navigate financial and regulatory complexities, engage effectively with local utilities and Authorities Having Jurisdiction (AHJs), and structure successful microgrid projects.

24 POWER TRANSMISSION AND DISTRIBUTION↗

Regulatory Treatment of Low Frequency External Events under a Risk-Informed Performance-Based Licensing Pathway: Enhanced SPRA-based Margins Assessment

Recently there has been development in the field of risk-informed performance-based (RIPB) design and licensing approaches, which leverage detailed risk assessments and performance-based metrics to allow flexibility and innovation. These RIPB approaches include the probabilistic treatment of external hazards, including low frequency events that are beyond the design basis. However, there are certain challenges that have been identified to the probabilistic treatment of low frequency external events, primarily due to uncertainty in the hazard curve and the associated plant response to rare, severe events. The NRC is currently developing 10 CFR Part 53 that would establish a technology-inclusive regulatory framework for use by applicants for new commercial advanced nuclear reactors. By examining the regulatory safety criteria contained within draft 10 CFR Part 53 and associated draft RIPB seismic design guidance, potential challenges were identified in demonstrating satisfaction of the safety criteria for low frequency external events, with specific difficulties associated with demonstrating compliance with the quantitative health objectives (QHOs). Non-LWRs are expected to utilize the direct calculation of offsite consequence, rather than use surrogates, for comparison to the QHOs, which can be particularly challenging as the previously identified uncertainties are compounded by uncertainties in the response of the neighboring population. The central recommendation from this effort is that it is necessary to develop an approach for demonstrating compliance with the safety criteria in draft Part 53 that addresses the key challenges while providing flexibility to applicants. This paper summarizes key findings, establishes a series of high-level goals, and reviews a newly developed approach to address the major challenges associated with assessing compliance with QHOs, with avenues to demonstrate compliance based on either the estimated consequence or the available margin to event occurrence, while also building on existing experience of seismic margins assessments. The paper also provides examples to demonstrate the application of the approach, as well as recommendations and potential future work.

external hazards↗