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Regulatory Treatment of Low Frequency External Events under a Risk-Informed Performance-Based Licensing Pathway: Safety Criteria Evaluation

There has been recent progress in the development of risk-informed performance-based (RIPB) design and licensing approaches, which leverage the insights gained from detailed risk assessments and utilize performance-based metrics to permit flexibility and innovation. The RIPB approaches have included the probabilistic treatment of external hazards, including low frequency events that are beyond the design basis. A preceding study conducted in FY21 noted that there are certain challenges to the probabilistic treatment of low frequency external events, which are primarily the result of uncertainty in the hazard curve and the associated plant response to rare, severe events. The current work expands on the previous study by examining the regulatory safety criteria contained within draft 10 CFR Part 53 and associated draft RIPB seismic design guidance. The evaluation identified potential challenges in demonstrating satisfaction of the safety criteria for low frequency external events, with specific difficulties associated with demonstrating compliance with cumulative safety criteria metrics, such as 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 current work details this evaluation and key findings. 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.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Utilization of the LMP Methodology in Support of the VTR Conceptual Safety Design Report

The Versatile Test Reactor (VTR) is a fast spectrum test reactor currently being developed in the United States under the direction of the US Department of Energy (DOE), Office of Nuclear Energy. The VTR is utilizing a risk-informed performance-based (RIPB) approach for design support and authorization by the DOE, derived from recent efforts by the US industry led Licensing Modernization Project (LMP). This document contains an overview of the implementation of the LMP approach in support of the VTR Conceptual Safety Design Report (CSDR). The work reported here is the result of studies supporting a VTR conceptual design, cost, and schedule estimate for DOE-NE to make a decision on procurement. As such, it is preliminary. The VTR RIPB authorization approach utilizes information from the probabilistic risk assessment (PRA), coupled with deterministic analyses, to aid in decision-making regarding the identification and categorization of safety basis events (SBEs), the classification of structures, systems, and components (SSCs), and the evaluation of defense-in-depth (DID) adequacy. As part of initial reactor design efforts, a VTR conceptual design PRA was developed to support the RIPB process, which focused on at-power internal events, with scoping analyses for seismic and sodium fire hazards. In addition to supporting numerous design studies, preliminary results from the RIPB approach and the VTR conceptual design PRA were utilized as the basis of the VTR CSDR. The initial identification and categorization of SBEs, SSC classification, and DID evaluation were contained within the CSDR, which was submitted to DOE in 2019 as part of the CD-1 submittal package. Following review, DOE approved the CSDR in April 2020 and the CD-1 package in late 2020. Valuable experience was gained through the implementation of the RIPB approach for design and authorization during the VTR conceptual design phase, which is summarized in this document. To the extent possible, this experience has been shared with the advanced reactor industry, through publications and participation in licensing tabletops, in addition to informing DOE:NE advanced reactor regulatory development efforts. Furthermore, the approval of the CSDR by the DOE as part of CD-1 represents a significant milestone in the use of RIPB approaches for advanced reactor licensing.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

A model to assess Zircaloy’s mechanical property changes following a transient beyond critical heat flux

Maintaining the integrity of nuclear fuel rods is essential for ensuring public health and safety in nuclear power generation. During reactor operation, this integrity is confirmed by demonstrating compliance with established regulatory acceptance criteria. For moderate-frequency events, such as limiting transients and anticipated operational occurrences (AOOs), the current fuel integrity criterion is based on preventing boiling transition. This criterion assumes that prevention of boiling transition will prevent excessive cladding heating and, thus, fuel failure during normal operations. While conservative, this approach places significant constraints on core design, fuel cycle economics, and a plant’s ability to perform major power uprates, leading to suboptimal fuel utilization and inefficient carbon-free energy production. A more efficient approach could be achieved by revising the failure criterion to a material-specific limit rather than strictly preventing the boiling transition, since boiling transition per se is not a cause of fuel cladding failure. Here, as a result, a new licensing framework based on material properties, termed time-at-temperature (t@T), is needed. This approach would allow for brief periods of post–critical heat flux operation during an AOO without compromising safety. Implementing the t@T licensing strategy requires a robust technical foundation in material properties, which must be established through comprehensive data collection on both unirradiated and irradiated fuel and cladding materials. This foundation would enable the development of a safety basis that ensures safe operation while providing greater flexibility and efficiency for reactor operation. This paper documents a thorough review of the available data to establish a baseline knowledge that can inform the development of cladding mechanical models, as well as identify experimental data gaps that need to be addressed in future research. Machine learning and data informatics were utilized to extract the importance of parameters on the t@T parameter. Industry tools were used to perform baseline analyses to define the relevant transient conditions for data analysis. The subsequent review successfully identified applicable experimental data, as well as sufficient data to evaluate changes in cladding mechanical properties following an AOO transient. Rather than developing new models, this work coupled existing irradiation annealing and recrystallization models to calculate changes in hardness, yield stress, and ultimate tensile stress following an AOO event. The findings from this review were summarized to highlight the experimental data needs required to fill remaining gaps and support the development of future t@T licensing methodologies.

Cladding performance↗

Safety Analysis for the Versatile Test Reactor Conceptual Design

Safety analysis simulations have been carried out using the SAS4A/SASSYS-1 safety analysis code system to update the baseline set of results for the Versatile Test Reactor conceptual design. Results from a previous revision of this work provided input for the Conceptual Safety Design Report summarizing the overall safety basis for the VTR. This work will also support future analyses that will be required for Chapter 13, “Accident Analysis,” of a preliminary safety analysis report. A number of transients have been evaluated based on categories of postulated accident sequences suggested for consideration in NUREG-1537. Ultimately, the full spectrum of event initiators and subsequent accident sequences will be defined through a probabilistic risk assessment of the plant design following the implementation of the Licensing Modernization Project guidelines as described in the VTR Safety Design Strategy. Since that process is ongoing, the present analysis addresses several transients that are expected to be bounding accident scenarios that represent the three key ways to perturb a reactor: through changes to the core inlet temperature, mass flow rate, or reactivity. These correspond to a loss of heat sink (LOHS), loss of flow (LOF) or station blackout (SBO), and transient overpower (TOP), respectively. Both Protected and Unprotected versions of these transients have been evaluated, along with additional transients that include transient overpower with one stuck rod, pump coast-down failures, seismic events, and overcooling events. At the current stage of design, transient simulation results for the Versatile Test Reactor indicate that large safety margins exist for many event initiators. However, several “enabling” assumptions have been made, in terms of both design features and design limits, in order to perform the analyses; and these assumptions will need to be revised as the design matures. In addition, a larger spectrum of events needs to be evaluated as part of the on-going probabilistic risk assessment process.

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Status of SAS4A/SASSYS-1 Software Development and Application (FY2024)

SAS4A/SASSYS-1 is a simulation tool used to perform deterministic analysis of anticipated events as well as design basis and beyond design basis accidents for advanced liquid-metal-cooled nuclear reactors. With its origin as SAS1A in the late 1960s, the SAS series of codes has been under continuous use and development for over fifty years. It has been identified as a critical element of safety analysis capabilities for the U.S. Department of Energy and is utilized within industry to perform the transient safety analyses required to support the licensing of Liquid Metal-cooled Fast Reactors (LMFRs). This report summarizes the code development and update activities carried out during FY2024. In FY2024, programmatic activities focused on key improvements to software useability, such as enhanced user interfaces for reactivity feedback modeling, improvements in stability/useability of the Code Manual, and improvements to the acceptance testing infrastructure, including automation of acceptance testing and generation of the Acceptance Testing Report. To support end user applications, an open training was held, a semi-public forum was maintained, and a practical benchmarking and validation matrix was developed which allowed limitations of existing testing capabilities to be assessed. The existing fuel models were also enhanced with improved modeling capabilities and testing for the oxide and annular fuel models.

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Preliminary Analysis of Postclosure DPC Criticality Consequences

One of the objectives of the United States (U.S.) Department of Energy's (DOE) Office of Nuclear Energy's Spent Fuel and Waste Science and Technology Campaign is to better understand the technical basis, risks, and uncertainty associated with the safe and secure disposition of spent nuclear fuel (SNF) and high-level radioactive waste. Commercial nuclear power generation in the U.S. has resulted in thousands of metric tons of SNF, the disposal of which is the responsibility of the DOE (Nuclear Waste Policy Act 1982). Any repository licensed to dispose the SNF must meet requirements regarding the longterm performance of that repository. For an evaluation of the long-term performance of the repository, one of the events that may need to be considered is the SNF achieving a critical configuration. Of particular interest is the potential behavior of SNF in dual-purpose canisters (DPCs), which are currently being used to store and transport SNF but were not designed for permanent geologic disposal. A two-phase study has been initiated to begin examining the potential consequences, with respect to longterm repository performance, of criticality events that might occur during the postclosure period in a hypothetical repository containing DPCs. Phase I, a scoping phase, consisted of developing an approach intended to be a starting point for the development of the modeling tools and techniques that may eventually be required either to exclude criticality from or to include criticality in a performance assessment (PA) as appropriate; Phase I is documented in Price et al. (2019). The Phase I approach guided the analyses and simulations done in Phase II to further the development of these modeling tools and techniques as well as the overall knowledge base. The purpose of this report is to document the results of the analyses conducted during Phase II. The remainder of Section 1 presents the background, objective, and scope of this report, as well as the relevant key assumptions used in the Phase II analyses and simulations. Subsequent sections discuss the analyses that were conducted (Section 2), the results of those analyses (Section 3), and the summary and conclusions (Section 4). This report fulfills the Spent Fuel and Waste Science and Technology Campaign deliverable M2SF-20SN010305061.

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Repository-Scale Performance Assessment Incorporating Postclosure Criticality

A key objective of the United States Department of Energy’s (DOE) Office of Nuclear Energy’s Spent Fuel and Waste Science and Technology Campaign is to better understand the technical basis, risks, and uncertainty associated with the safe and secure disposition of spent nuclear fuel (SNF) and high-level radioactive waste. Commercial nuclear power generation in the United States has resulted in thousands of metric tons of SNF, the disposal of which is the responsibility of the DOE (Nuclear Waste Policy Act of 1982, as amended). Any repository licensed to dispose of SNF must meet requirements regarding the long-term performance of that repository. For an evaluation of the long-term performance of the repository, one of the events that may need to be considered is the SNF achieving a critical configuration during the postclosure period. Of particular interest is the potential behavior of SNF in dual-purpose canisters (DPCs), which are currently licensed and being used to store and transport SNF but were not designed for permanent geologic disposal. A study has been initiated to examine the potential consequences, with respect to long-term repository performance, of criticality events that might occur during the postclosure period in a hypothetical repository containing DPCs. The first phase (a scoping phase) consisted of developing an approach to creating the modeling tools and techniques that may eventually be needed to either include or exclude criticality from a performance assessment (PA) as appropriate; this scoping phase is documented in Price et al. (2019a). In the second phase, that modeling approach was implemented and future work was identified, as documented in Price et al. (2019b). This report gives the results of a repository-scale PA examining the potential consequences of postclosure criticality, as well as the information, modeling tools, and techniques needed to incorporate the effects of postclosure criticality in the PA.

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Transient Postclosure Criticality Model Development

A key objective of the United States Department of Energy’s (DOE) Office of Nuclear Energy’s Spent Fuel and Waste Science and Technology (SFWST) Campaign is to better understand the technical basis, risks, and uncertainty associated with the safe and secure disposition of spent nuclear fuel (SNF) and high-level radioactive waste. Commercial nuclear power generation in the United States has resulted in thousands of metric tons of SNF, the disposal of which is the responsibility of the DOE (Nuclear Waste Policy Act of 1982, as amended). Any repository licensed to dispose of SNF must meet requirements regarding the long-term performance of that repository. For an evaluation of the long-term performance of the repository, one of the events that may need to be considered is the SNF achieving a critical configuration during the postclosure period. Of particular interest is the potential behavior of SNF in dualpurpose canisters (DPCs), which are currently licensed and being used to store and transport SNF but were not designed for permanent geologic disposal.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Analysis of Transient Postclosure Criticality

The United States Department of Energy’s (DOE) Office of Nuclear Energy’s Spent Fuel and Waste Science and Technology Campaign seeks to better understand the technical basis, risks, and uncertainty associated with the safe and secure disposition of spent nuclear fuel (SNF) and high-level radioactive waste. Commercial nuclear power generation in the United States has resulted in thousands of metric tons of SNF, the disposal of which is the responsibility of the DOE (Nuclear Waste Policy Act of 1982, as amended). Any repository licensed to dispose of SNF must meet requirements regarding the long-term performance of that repository. For an evaluation of the long-term performance of the repository, one of the events that may need to be considered is the SNF achieving a critical configuration during the postclosure period. Of particular interest is the potential behavior of SNF in dual-purpose canisters (DPCs), which are currently licensed and being used to store and transport SNF but were not designed for permanent geologic disposal.

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Initial Development of Fusion Magnet Simulation Capabilities for Performance and Safety Evaluation Using the MOOSE Framework

Fusion energy holds the promise of being a transformative technology as a carbon-neutral, sustainable source of energy. Whole device modeling and the development of fusion digital twins will be increasingly important for emerging fusion device concepts at both national laboratories and within the commercial fusion industry. However, meeting the challenge of whole device modeling of fusion energy devices requires robust, multiphysics, multiscale modeling and simulation technologies capable of running on large-scale supercomputers. Detailed analysis of individual systems at-scale is also required to ensure safe and efficient operation as well as provide the safety basis for future device designs and licensing activities. In a tokamak, toroidal and poloidal magnets confine and shape the fusion plasma to promote the fusion reaction. High plasma temperatures and high magnetic field requirements in modern design concepts (leading to high amounts of energy stored within each magnet) impose electrical, thermal, and mechanical loads on the magnet components, which in turn impacts the safety considerations of the magnet and their supporting systems. Idaho National Laboratory (INL) has a history of working in this space, including development and benchmarking of the Magnetic System Circuitry Analysis Program (MSCAP) and Magnet Arcing (MAGARC) codes to study magnet quench events; notably, MAGARC was used to study quenching during the ITER Engineering Design Activity. However, these legacy codes and capabilities are not parallel and scalable, and new tools are required for future advances in this area, which leads to the INL-developed Multiphysics Object-Oriented Simulation Environment (MOOSE) framework. Developed originally for fission reactor systems under United States Department of Energy, Office of Nuclear Energy modeling and simulation programs, the MOOSE framework has been well-suited to multiscale, multiphysics modeling and simulation needs for nuclear systems. The framework is open-source, well-tested, under continuous development and deployment, and developed to a Nuclear Quality Assurance, Level 1 software quality standard. MOOSE has also been used in the fusion space previously in several projects: INL’s Tritium Migration Analysis Program, Version 8 (TMAP8) for tritium migration, UK Atomic Energy Authority’s A Unified Resource for OpenMC (fusion) Reactor Applications (AURORA) code for fusion thermo-mechanical and neutronics analysis, and Argonne National Laboratory’s Cardinal for high-fidelity computational fluid dynamics and neutronics. However, to model superconducting magnets, several MOOSE enhancements are required: additions to the current MOOSE electromagnetic capabilities, new material libraries for superconductors of interest (such as YBCO), as well as fusion-specific models for thermo-mechanics. This talk will discuss initial development activities to build these capabilities in MOOSE, focusing on initial validation and benchmarking activities. Proposed coupling workflows and future work to support the simulation of fusion magnets and magnet structural assemblies for performance and safety evaluation in MOOSE will also be discussed.

70 - PLASMA PHYSICS AND FUSION TECHNOLOGY↗

Qualification of System-Level Advanced Reactor Safety Analysis Software for Lead Systems: Final CRADA Report

SAS4A/SASSYS-1 is a simulation tool used to perform deterministic analysis of anticipated events as well as design basis and beyond design basis accidents for advanced liquid-metal-cooled nuclear reactors. With its origin as SAS1A in the late 1960s, the SAS series of codes has been under continuous use and development for over forty-five years and represents a critical investment in safety analysis capabilities for the U.S. Department of Energy. Although SAS4A/SASSYS-1 was developed to support the analysis of any liquid-metal-cooled nuclear reactor, it has primarily been utilized to design and analyze Sodium Fast Reactors (SFRs). As a result, most of the qualification basis for SAS4A/SASSYS-1 has utilized sodium as a coolant and geometry descriptions that are prototypic of SFR configurations. In this project, which partnered with Westinghouse Electric Company, LLC, the initial foundation for a qualification basis centered on prototypic pool-type lead-cooled systems has been established, where the end goal is to extend support for utilization of SAS4A/SASSYS-1 in Lead Fast Reactor (LFR) licensing or authorization. This project included three fundamental technical tasks: LFR V&V test suite development (Task 1); qualification support for LFRs (Task 2); and LFR modeling capabilities evaluation and improvement (Task 3)

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Root Cause Correlation Analysis of Software Failures via Orthogonal Defect Classification and Natural Language Processing

Systems theoretic process analysis (STPA) is becoming an increasingly popular technique to assess how complex digital software systems can fail. Rather than defining failures by their observable failure events, which may be sparse especially for safety rated nuclear digital instrumentation and control systems (DI&C), failures are defined as postulated unsafe actions under specific contextual conditions. This permits a top-down analysis of system hazards and identifies whether imposed constraints and requirements can sufficiently address undesirable hazards. However, STPA is a qualitative approach at identifying inadequacies in the development process and cannot currently be used to quantify unsafe action likelihoods for probabilistic risk assessment. Therefore, in this work, we examine the root causes of software failure and explore whether a consistent correlation can be linked to specific unsafe action classes. We implement Lbl2Vec, an unsupervised document classification and retrieval algorithm, on a database of 4,096 software defect reports acquired from various open-source software systems. By analyzing sentence structure, embedded labels, and word vectors, we show that certain defect types positively correlate to specific unsafe action classes over others. The correlations developed can be used to estimate the failure probability of safety intended DI&C systems which provides a licensing basis for nuclear plant modernization efforts.

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Root Cause Correlation Analysis of Software Failures via Orthogonal Defect Classification and Natural Language Processing

Systems theoretic process analysis (STPA) is becoming an increasingly popular technique to assess how complex digital software systems can fail. Rather than defining failures by their observable failure events, which may be sparse especially for safety rated nuclear digital instrumentation and control systems (DI&C), failures are defined as postulated unsafe actions under specific contextual conditions. This permits a top-down analysis of system hazards and identifies whether imposed constraints and requirements can sufficiently address undesirable hazards. However, STPA is a qualitative approach at identifying inadequacies in the development process and cannot currently be used to quantify unsafe action likelihoods for probabilistic risk assessment. Therefore, in this work, we examine the root causes of software failure and explore whether a consistent correlation can be linked to specific unsafe action classes. We implement Lbl2Vec, an unsupervised document classification and retrieval algorithm, on a database of 4,096 software defect reports acquired from various open-source software systems. By analyzing sentence structure, embedded labels, and word vectors, we show that certain defect types positively correlate to specific unsafe action classes over others. The correlations developed can be used to estimate the failure probability of safety intended DI&C systems which provides a licensing basis for nuclear plant modernization efforts.

22 - GENERAL STUDIES OF NUCLEAR REACTORS↗

Approach and Model Used to Represent a Timeline Analysis for Security Design Enhancements

Next-generation reactors will be able to use risk to inform and performance base the licensing of many aspects of the reactor, facility, and site design, including attributes of physical security. There are several factors related to security, including site topography, reactor design, and physical protection system components, to consider when designing the physical protection system into the overall facility design and plan of operation. With the versatility of advanced reactors, especially micro reactors, methods are needed to simplify and quickly evaluate potential timelines for designing a site configuration. This report describes an approach to generate qualitative and quantitative insights using a risk-informed simulation. The modeling process is described in detail, focusing on three aspects: (1) the facility mission time (the time required to control the plant until safe), (2) the attacker timeline (the time to potential sabotage), and (3) the response timeline (the time to counter the facility attack). The modeling capabilities also are extended to include facility physical phenomena such as thermal-hydraulics and heat transfer to capture realistic representation of dynamic changes to a facility. While the plant models and examples are hypothetical and do not represent a real facility, these modeling approaches could be used for future security-by-design engineering in advanced reactors. The outputs and insights from the modeling approach may be used to modify and optimize the security posture of a facility by efficiently making modifications to the model and seeing the overall impact from the modification. Lastly, use of the approach described in this report can also provide the technical basis for a physical protection program, describing how the facility and security strategy will cope with off-normal events.

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An Overview of the State-of-the-Art Reactor Consequence Uncertainty Assessment Accident Progression Insights

The U.S. Nuclear Regulatory Commission (NRC) with Sandia National Laboratories (Sandia) have completed three uncertainty analyses (UAs) as part of the State-of-the-Art Reactor Consequence Analyses (SOARCA) program. The SOARCA UAs included an integrated evaluation of uncertainty in accident progression, radiological release, and offsite health consequence projections. The UA for Peach Bottom, a boiling-water reactor (BWR) with a Mark I containment located in the State of Pennsylvania, analyzed the unmitigated long-term station blackout SOARCA scenario. The UA for Sequoyah, a 4-loop Westinghouse pressurized-water reactor (PWR) located in the State of Tennessee, analyzed the unmitigated short-term station blackout SOARCA scenario, with a focus on issues unique to the ice condenser containment and the potential for early containment failure due to hydrogen deflagration. The UA for Surry, a 3-loop Westinghouse PWR with a sub-atmospheric large dry containment located in the State of Virginia, analyzed the unmitigated short-term station blackout SOARCA scenario including the potential for thermally-induced steam-generator tube rupture. These three UAs are currently documented in three NUREG/CR reports. This report provides input to planned NRC documentation on the insights and findings from the SOARCA UA program. The purpose of the summary report is to provide a useful reference for regulatory applications that require the evaluation of offsite consequence risk from beyond design basis event severe accidents. This report focuses on the accident progression and source term insights developed from the MELCOR analyses. MELCOR is the NRC's best-estimate, severe accident computer code used in the SOARCA UAs. In anticipation of the SOARCA UA insights work, NRC and Sandia benchmarked the response of the Peach Bottom model to selected reference calculations from the Peach Bottom SOARCA UA. Peach Bottom was the first SOARCA UA performed and was completed in 2015 using the MELCOR 1.8.6 code. The PWR SOARCA UAs evolved the original methodology and utilized the updated MELCOR 2.2 computer code. The Peach Bottom model has been systematically updated for other NRC research efforts and has been updated to MELCOR 2.2. computer code. The findings from the new reference calculations using the updated model with the MELCOR 2.2 code are also integrated into the report. A second objective is an assessment of the applicability of the results to the other nuclear reactors in the U.S. As the key findings are reviewed, judgments are presented on the applicability of the results to other U.S. nuclear power plants. An important objective of the SOARCA program relied on high- fidelity plant-specific modeling. However, the nature of the insights and conclusions allowed judgements to be made on the applicability of the various insights to the same general classification of plant (i.e., BWR or PWR) or the entire fleet of plants. Finally, the results from the SOARCA UA accident progression calculations contain a wealth of information not previously documented in the NUREG/CRs. This report includes new but related information that can be used to benchmark past or support future regulatory decisions related to severe accidents. The new work includes a benchmark of the NUREG-1465 licensing source term definitions, the variability of key accident progression events and timing to radionuclide release, and an improved understanding of the timing and source terms from consequential steam generator tube ruptures. iii ACKNOWLEDGEMENTS The Sandia authors gratefully acknowledge the significant technical and programmatic contributions from the NRC SOARCA team which are reflected throughout the report. Dr. Tina Ghosh has been involved throughout the SOARCA UAs, providing the primary managerial and technical oversight. The long lists of NRC and Sandia contributors from the SOARCA UAs are cited in the three NUREG/CRs and are also gratefully acknowledged by the small team of authors compiling the results of their efforts. Significant technical contributions, advice, and reviews were provided by Dr. Hossein Esmaili, Dr. Alfred Hathaway, and Dr. Edward Fuller (retired) of the NRC. Dr. Randal Gauntt (retired), Mr. Patrick Mattie, Mr. Joseph Jones (retired), and Dr. Doug Osborn from Sandia are recognized as the SOARCA UA managers guiding the past efforts. There is a comparable list of project managers at the NRC including Ms. Patricia Santiago, Dr. Salman Haq, and Mr. Jon Barr. Sadly, we have lost Mr. Charlie Tinkler and Mr. Robert Prato, who were important contributors to the original SOARCA project. Finally, Mr. Kyle Ross and Mr. Mark Leonard have also retired but were significant technical contributors. Mr. Kyle Ross was the technical lead on all three SOARCA UAs and the original pressurized water reactor SOARCA study. Mr. Leonard was the technical lead on the original boiling water reactor SOARCA study and a key contributor to the first Peach Bottom SOARCA UA. iv

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