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At least 145 records · Page 8

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

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

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Comparison Between Pin-by-Pin Subchannel and System Level Thermal Hydraulic Results for High Burnup Loss-of-Coolant Applications

This milestone report summarizes recent work to investigate higher fidelity modeling and simulation practices for large-break loss-of-coolant accident (LBLOCA) analysis in high-burnup pressurized water reactor (PWR) cores. Because of current industry interest in extending fuel cycle lengths ranging from 18 to 24-months, the Nuclear Energy Advanced Modeling and Simulation (NEAMS) program has been investigating the susceptibility of high-burnup core designs to fuel fragmentation, release, and dispersal (FFRD) during accident conditions such as LBLOCA. This work has prioritized developing and demonstrating a methodology for calculating core-wide susceptibility to FFRD and addressing uncertainties identified in the analysis and the US Nuclear Regulatory Commission (NRC) Research Information Letter on FFRD. Part of this investigation seeks to quantify differences between system-level thermal hydraulic behavior and higher fidelity subchannel modeling methods to identify potential safety concerns or opportunities to minimize FFRD susceptibility. To this end, the NEAMS subchannel code, CTF, is being used, along with the NRC system analysis code TRACE, for analysis of LBLOCA in a core containing high-burnup fuel. This project includes two thrusts: (1) improving on the existing TRACE model for a 4-loop PWR for LBLOCA so that the model is higher fidelity and consistent with current USNRC best practices, and (2) using CTF to perform pin-resolved modeling of the core region of the reflood phase of a LBLOCA in a high-burnup PWR.

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Development of a CRAB-MELCOR Framework for Utilization in Support of Estimating a Realistic Mechanistic Source Term for Microreactors

Research and development activities are being performed to link important advanced non-light-water microreactor technology research and development activities sponsored by the U.S. Department of Energy’s Office of Nuclear Energy with regulatory requirements and critical licensing needs likely to impact the deployment of a domestic commercial microreactor fleet. This report presents the progress of ongoing work to perform a gap analysis of the coupling of the Nuclear Regulatory Commission’s Comprehensive Reactor Analysis Bundle code suite and MELCOR code. This key Fiscal Year 2023 research reflects microreactor regulatory needs and challenges noted by industry, Department of Energy, and Nuclear Regulatory Commission stakeholders.

99 GENERAL AND MISCELLANEOUS↗

SAS4A/SASSYS-1 Commercial Grade Dedication Example Report for a Generic Sodium Pool-Type Fast Reactor Application

In the U.S., a key component of the commercialization of advanced reactors is completion of a license application, which must ultimately be approved by the Nuclear Regulatory Commission (NRC). The approval of the license application by the NRC is contingent on satisfactory demonstration of the design basis and the response of the advanced reactor design to transient and accident scenarios using accepted codes and methods. This report describes the qualification and dedication requirements that the advanced reactor safety analysis system software SAS4A/SASSYS-1 are expected to need to fulfill to be used for sodium-cooled pool-type fast reactor licensing. The qualification and dedication requirements are identified through performance critical characteristics and evaluation model acceptance criteria representative of the advanced reactor design considered for licensing. This document captures, additionally, the verification process developed to demonstrate that the software fulfills the qualification and dedication requirements for a generic sodium-cooled pool-type fast reactor as part of the commercial grade dedication process. Like most software that has primarily existed in the research and development space, the most significant challenge facing SAS4A/SASSYS-1 for use in a licensing framework is the availability of a documentation basis describing the code pedigree. SAS4A/SASSYS-1 has been used for licensing of the fast flux test facility (FFTF) and the JOYO sodium-cooled fast reactor in Japan, as well as the design of the CRBR Plant. However, the historical verification and validation (V&V) activities supporting SAS4A/SASSYS-1 development do not align with modern software quality assurance (SQA) and V&V requirements. Two approaches to use of SAS4A/SASSYS-1 in a commercial licensing framework have been identified: commercial-grade dedication (CGD) and software qualification. The methods and requirements prescribed in the ASME NQA-1-2008/2009 Standard and Regulatory Guide 1.203 on the evaluation model development and assessment process (EMDAP) have been used as guidance to define the CGD and qualification processes, respectively. A qualification and dedication requirements matrix has been developed which utilizes fundamental software verification. In this process, software verification is defined as a software quality process aimed at defining software requirement specifications, developing software design documentation, and performing and documenting acceptance testing of the code against requirements. A key element of software qualification and dedication includes determination of software acceptance with respect to critical characteristics relevant to the functional requirements of the software. To assist with identification of cross-cutting transient phenomena and functional requirements, domestic SFR vendor designs have been reviewed to identify a reference SFR design. For this report, the reference design is defined as a pool-type reactor with metal alloy fuel, a liquid-metal intermediate heat transport system, and passive decay heat rejection systems. Given this reference, a series of high-level cross-cutting phenomena was identified for a general class of single-fault undercooling or reactivity insertion transients that scopes the design basis space, with the goal of assisting with prioritization of documentation development efforts for key transient models in SAS: 1) Reactivity feedback response prior to scram; 2) System-wide thermal inertia; 3) Transition in natural circulation flow regime in heat removal systems; 4) Decay heat generation; 5) Steady-state fuel characterization; 5) Clad/fuel behavior at elevated temperatures; 6) Point kinetics and decay heat; 7) Pump coastdown behavior; 8) Core flow redistribution in loss of forced convection; 9) Pool stratification. As a demonstration of CGD of SAS4A/SASSYS-1 for a sodium pool reactor, a software qualification and dedication gap analysis as it relates to code documentation has been performed. This effort leverages the framework established as part of the SAS4A/SASSYS-1 SQA Program. This CGD demonstration provides a framework that vendors can build upon to demonstrate the applicability of the SAS4A/SASSYS-1 software for licensing a sodium-cooled pool-type fast reactor.

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Assessment of Sodium Fast Reactor Specific Consensus Standards and Recommendations for Future Regulatory Development for Standards Activities

The U.S. has designed, constructed, and operated several sodium fast reactors (SFRs). To support these efforts and to document best practices, activities associated with the development of standards and consensus standards were carried out, however, the vast majority of those SFR standards are currently in a withdrawn or inactive status. Consensus standards are useful during design and licensing of reactors, as is evident in the current nuclear power generation fleet. Consensus standards provide certainty and predictability between stakeholders during licensing and other regulatory interactions. These standards offer guidance, reflect expert positions, and establish effective practices for a wide range of topics. Consensus standards are developed by committees with representation from a broad cross-section of industry, organizations, professional societies, and government agencies. However, most existing consensus standards applicable to nuclear power plants were developed specifically for light-water reactor (LWR) designs and may not adequately address specific advanced non-LWR design topics such as those related to SFRs.

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NRIC Annual Report FY 2025

The National Reactor Innovation Center (NRIC), established in August 2019, is a national United States (U.S.) Department of Energy (DOE) program. NRIC’s mission is to partner with industry and national laboratories to bridge the gap between concept, demonstration, and commercialization of advanced nuclear technology. NRIC accomplishes this through building or enhancing existing DOE infrastructure to support testing of components and systems that are key to successfully deploying advanced nuclear technology. NRIC’s vision is that by 2028, NRIC will be partnered with industry and accelerating the demonstration and deployment of advanced nuclear technology using DOE national laboratory infrastructure and expertise. NRIC will establish four new experimental facilities and two large reactor test beds for integrated technology demonstrations and experimentation by 2028 and complete two advanced nuclear technology tests by 2030. Achieving this vision will enable urgently needed abundant and affordable clean energy both domestically and internationally. NRIC’s success will inspire our nation and the global community to embrace the promising contribution of innovative nuclear reactor technologies to the clean energy economy and re-establish the U.S. as the global leader in advanced nuclear energy. NRIC is tasked with expediting the development of advanced nuclear energy technologies by bringing together private-sector technology developers and the world-class capabilities of the DOE national laboratory system. Through this program, the U.S. private sector is given access to the physical infrastructure available at DOE national laboratories to test and demonstrate their reactor concepts. NRIC works closely with the DOE-Nuclear Energy (NE) program that grants access to technical, regulatory, and financial support for commercializing nuclear energy. NRIC builds upon these new reactor concepts and technology successes to effectively strengthen U.S. nuclear leadership.

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AFC Metallic Fuel Research and Development 5-Year Plan

The mission of the U.S. Department of Energy (DOE) Advanced Fuel Campaign (AFC) program is conducting R&D on nuclear fuel technology that enables near- and long-term implementation of the reactor systems necessary to meet national nuclear energy objectives. Its primary goals align with goals of the DOE Office of Nuclear Energy in sustaining the current LWR fleet through Accident Tolerant Fuels program and Enabling Advanced Reactors. The latter goal is to be achieved through the following subgoals in order of logistical priority: • Establish the qualification basis for reference metallic fuel designs for sodium-cooled fast reactors. • Develop next generation metallic fuel fabrication and design for improved fissile utilization and management. • Develop accelerated fuel development and qualification methodologies. • Identify next generation fuel technologies. The purpose of this document is to serve as a five-year research and development (R&D) plan to achieve the goals identified to support enabling advanced reactor deployment related to metallic fuels starting in 2025. The specific objectives of this document are to: • align program R&D work across technical areas, national laboratories, and with stakeholder interests, and • aid yearly and outyear scope and budgetary planning activities. This plan lays the foundation of databases, capabilities, expertise, and research-commercial-regulatory integration for launching next-generation initiatives in advanced fuel technologies (fuel and cladding) and improved methodologies for achieving accelerated qualification of next generation fuel technologies.

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Supporting New Advanced Nuclear Technologies for Commercial-Maritime Applications

The ANS summary doesn't require an abstract, but I will produce one for the purpose of LRS: The large demand for maritime nuclear power underscores the need for experimental campaigns and modeling and simulation of new advanced reactors, which offer numerous advantages in terms of safety, efficiency, and compactness. INL, through the work conducted by NRIC and ABS, has addressed some of the technical, regulatory, and economic aspects of potential nuclear commercial maritime applications. However, on the technical side, there remain important physical phenomena, particularly for advanced reactors, that are not yet fully understood. Addressing these knowledge gaps requires a combination of experiments and advanced modeling and simulation techniques. INL possesses significant expertise in Multiphysics modeling and simulation. By collaborating with INL, the maritime nuclear sector can leverage this expertise to advance the development and deployment of innovative nuclear technologies.

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U.S. Domestic Pebble Bed Reactor: Security-by-Design

U.S. nuclear power facilities face increasing challenges in meeting dynamic security requirements caused by evolving and expanding threats while keeping cost reasonable to make nuclear energy competitive. The past approach has often included implementing security features after a facility has been designed and without attention to optimization, which can lead to cost overruns. Incorporating security in the design process can provide robust, cost effective, and sufficient physical protection systems. The purpose of this work is both to develop a framework for the integration of security into the design phase of High Temperature Gas Reactors (HTGRs) that utilize pebble-based fuels and increase the use of modeling and simulation tools to optimize the design of physical protection systems. Specifically, this effort focuses on integrating security into the design phase of a model HTGR that meets current Nuclear Regulatory Commission (NRC) physical protection requirements and providing advanced solutions to improve physical protection and decrease costs. A suite of tools, including SCRIBE3D©, PATHTRACE© and Blender© were used to model a hypothetical, generic domestic HTGR facility. Physical protection elements such as sensors, cameras, barriers, and guard forces were added to the model based on best practices for physical protection systems. Multiple outsider sabotage scenarios were examined with four-to eight adversaries to determine security metrics. The results of this work will influence physical protection system designs and facility designs for U.S. domestic HTGRs. This work will also demonstrate how a series of experimental and modeling capabilities across the Department of Energy (DOE) Complex can impact the design of and complete Safeguards and Security by Design (SSBD) for SMRs. The conclusions and recommendations in this document may be applicable to all SMR designs.

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

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

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Xe-100 Pebble Bed Small Modular Reactor: Solving Critical Challenges to Enable the Xe-100 Pebble Bed Advanced Reactor Concept (ARC) (Final Scientific and Technical Report)

This is the final progress report for the Department of Energy (DOE) – X Energy, LLC cooperative agreement DENE0008472. This report provides a high-level summary of the work performed during the entire period of performance, running from July 1, 2016 – June 30, 2022. This span of time covers the original 5-year award and a one year no-cost extension. There were four tasks within this project: (1) project management, (2) reactor design furtherance, (3) fuel development, and (4) Nuclear Regulatory Commission (NRC) engagement. Detailed reporting during execution of the project was provided by a total of 23 quarterly reports, 42 X-energy technical reports, and voluntary monthly update presentations. Other technical work products include 2 white papers and 2 Topical Report submitted to the Nuclear Regulatory Commission, 15 Potential Inventions documented, 4 patents issued, 3 patents pending, 8 peer reviewed journal articles, and 2 Oak Ridge National Laboratory Technical Manuscripts. All the X Energy milestones/deliverables were met early or on time and are archived in the DOE Office of Nuclear Energy’s Program Information Control System: Nuclear Energy under Fiscal Year 2016, Work Breakdown Structure 2.07 – X-Energy. All other work products are available to DOE upon request.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Survey of Modeling and Simulation Techniques for Advanced Manufacturing Technologies Volume I – Predicting Initial Microstructures

This report summarizes the current state of modeling and simulation methods for predicting the initial structure and properties of material in components assembled using advanced manufacturing technologies (AMTs). The report is the first volume in a two-volume series. This first volume focuses on predicting initial microstructures of AM material. The second volume discusses predicting material properties given the initial microstructure. The focus is on technologies of particular relevance to the design and manufacture of nuclear reactor components. The purpose of the report is to help develop the technical knowledge base to support regulatory decisions that will be needed to assess nuclear components manufactured with AMTs as these components are installed at nuclear power plants (NPPs). The report develops a list of AMTs of particular interest to the NRC and summarizes the key microstructural features and corresponding processing parameters relevant to each technology. Further sections describe available physically-based and data-driven prediction methods and survey widely available software tools. The report concludes with a summary of gaps that may be of particular interest to the NRC when evaluating modeling and simulation methods for AMTs.

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TRANSPORTATION CONSIDERATIONS FOR USED FUEL AND ADVANCED NUCLEAR ENERGY TECHNOLOGIES

This study focuses on requirements and challenges pertaining to advanced transportable nuclear energy systems, which are currently in development and feature varying degrees of mobility. These reactors mostly use high-assay low-enriched uranium (HALEU) fuel, and only limited refueling is required during their lifecycles. Due to the smaller source terms, higher burnup fuel, and potentially higher thermal efficiency involved, the waste inventory will be less than that generated by conventional light-water reactors. However, the relevant regulatory requirements must be met when transporting HALEU fuel (whether fresh or used) inside the reactor vessel—mainly the fuel material transportation, siting, and physical protection requirements outlined in US Nuclear Regulatory Commission (NRC) regulations 10 CFR 71 and 73. Spent nuclear fuel (SNF), as well as irradiated fuel (used during any interval of reactor operation), contains highly radioactive materials that generate heat and necessitate special precautions during transportation. This study addresses the challenges that this incurs, and outlines potential solutions.

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Technical Basis for Advanced Artificial Intelligence and Machine Learning Adoption in Nuclear Power Plants

The research and development reported here is part of the Technology Enabled Risk-Informed Maintenance Strategy project sponsored by the U.S. Department of Energy’s Light Water Reactor Sustainability program. The primary objective of the research presented in this report is to produce a technical basis for developing explainable and trustable artificial intelligence (AI) and machine learning (ML) technologies. The technical basis will lay the foundation for addressing the technical and regulatory adoption challenges of AI/ML technologies across plant assets and the nuclear industry at scale and to achieve seamless cost-effective automation without compromising plant safety and reliability.

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

Updates to Nek5000: RANS wall functions, NRC support, and documentation

As a key part of the U.S. Department of Energy’s Nuclear Energy Advanced Modeling and Simulation program (NEAMS), the next generation of tools for nuclear reactor design are being developed. A primary metric for success of this program is the adoption of those tools by industry stakeholders. To help meet this metric for Nek5000, development efforts this year have focused on the expansion of the available Reynolds-averaged Navier-Stokes (RANS) turbulence models to include wall function models, continued support of the U.S. Nuclear Regulatory Commission in simulating a hydrogen mitigation benchmark experiment, and expansion of the Nek5000 documentation to enhance the code’s usability. The implementation of wall functions is intended to significantly decrease time to-solution for a wide range of problems and it has been identified as an important feature by stakeholders across the nuclear community. The initial implementation of standard and pressure corrected wall functions has been tested in Nek5000 on the classical problems of channel flow and a backward facing step. It has also been tested on a 2D molten salt fast reactor core and a T-junction. The recommended formulation of choosing y + = 30 as a boundary value combined with a Neumann-Neumann formulation of the boundary condition for k and τ produces the most consistent results compared to a wall resolved approach. The collaboration with the NRC is a continuing exercise that has been ongoing for multiple years. This year we have concluded investigations into appropriate inlet conditions, showing that fully developed turbulent conditions are adequate for the full PANDA domain. We have also concluded simulations for an unobstructed jet and are now refocusing to the original obstructed jet case. The expansion of the code documentation has also been an ongoing effort over the past few years to address feedback from the various stakeholders. The documentation now more fully covers many of the available features and closes identified SQA gaps. Finally we report on three training sessions that were offered over the past year in an effort to expand the Nek5000 user base.

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Small Nuclear Reactors for Maritime Ports

Maritime ports are entering a period of sharply rising electricity demand as operations are electrified, shore power adoption grows, and energy-intensive industries expand near ports. This report evaluates the feasibility of small nuclear reactors at U.S. ports, which could offer stable baseload power and reduced dependence on regional grids. The report describes the current state of advanced reactor technologies and other factors important for future deployment such as safety and operations, siting requirements, regulatory environments and policy, and other co-benefit considerations. A structured evaluation across a diverse group of U.S. ports highlights the wide variation in feasibility. Fifteen ports were analyzed through port interviews and data collection to assess the port-specific conditions that most impact advanced reactor deployment. The analysis found that the most feasible ports for deployment have favorable geotechnical stability, supportive regulatory environments, and substantial energy loads in a grid-constrained environment. Additionally, an initial reactor size matching was done for the ports based on their reported energy consumption across different modes of operation. However, further analysis and detailed data will be required in the future to determine the optimal reactor-port matching. The economic viability to adopt this technology will be dictated by competitive cost of nuclear-generated electricity compared to other alternatives. Overall, small nuclear reactors present a promising but highly site-dependent pathway for ports seeking resilient, high-capacity energy solutions that support future energy demands. This report identifies key areas for future research and highlights ports that warrant further evaluation to assess the viability of small nuclear reactor implementation. By establishing these priorities, the analysis provides support for the development of informed strategies for potential advanced nuclear technology deployment. The inclusion of ports in this report does not imply their endorsement of nuclear energy generation, and the authors are grateful for the information, expertise, and perspectives they contributed.

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Capability Building Progression of an Insider Threat Mitigation Program at an International Research Reactor

The nuclear industry recognizes the difficulties involved in developing effective managerial and leadership skills in a highly technical and proficient workforce such as that found in nuclear facilities. Implementing an insider threat mitigation program (ITMP) within the nuclear industry is a complex and ongoing process that demands a comprehensive understanding of human behavior, an organization’s security culture, and rigorous regulatory requirements yet also accounts for facility characteristics, physical security, material flow, and activities involving nuclear material. Given the high-consequence nature of research reactor operations, even minor lapses can lead to safety, security, and reputational risks. An effective ITMP requires a defense-in-depth approach that incorporates behavioral analysis, robust vetting procedures, continuous monitoring, and cross-disciplinary coordination. It must also promote a culture of vigilance and accountability at all levels up to and including executive leadership but be flexible enough to adapt to evolving global threats and technological advances. Insider threat mitigation is not a one-time effort but rather a sustained commitment to excellence in safety and security. Establishing a culture in which personnel proactively report incidents and issues that could affect nuclear safety and security is vital to maintaining a safe and secure operational environment. This document was developed to guide senior management and research reactor organizations in creating comprehensive programs to effectively manage and mitigate insider threat behaviors and actions. It focuses on the key pillars of an effective ITMP, including the national legal framework, security culture, preventive and protective measures, cyber security, and performance evaluation. By using a systematic approach during implementation, facilities can foster environments conducive to insider threat detection and support long-term program sustainability. The document also provides strategies for improving communication across all levels of an organization, helping to eliminate barriers that hinder the development of robust ITMPs and enhance overall security culture. In today’s organizations, the concept of leveraging safety and security culture lessons to facilitate knowledge transfer is rapidly evolving to expedite insider threat management and security culture improvements. This document outlines the rationale for evaluating an ITMP based on national customs, culture, and stakeholders. The elements are all germane to reliability and trustworthiness and relate to security concerns that states may encounter. The document focuses not only on individual perceptions regarding security issues and capability building but also on team building and how to resolve concerns. The implementers of a facility’s ITMP may zero in on indicators of insider threats within their enterprise. This material will benefit organizations when it is applied using a systematic and structured approach as demonstrated throughout the document.

98 NUCLEAR DISARMAMENT, SAFEGUARDS, AND PHYSICAL P↗

TCR Input to NUREG-1537 Process for Advanced Nuclear Technologies Derived from Additive Manufacturing

There has been a renewed interest by several advanced reactor developers to use NUREG-1537 “Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors” as a basis for their safety analysis report content and organization. Recently, SHINE Medical Technologies, LLC (SHINE), which is a non-power, Aqueous Homogenous Reactor design radioisotope production facility, received a construction permit based around their NUREG-1537 safety evaluation report (ADAMS No. ML16229A140). Advanced reactor developers are interested in using NUREG-1537 as a basis for their safety analysis report content and organization because of its successful application towards research reactors, graded approach, and simplicity in structure and requirements. However, NUREG-1537 is still largely geared toward light water reactors (LWRs) and many improvements could be made or supported through guidance documents for advanced reactors. For nuclear power to play a role in the future zero-carbon energy portfolio, a supportive regulatory structure is needed to lower regulatory uncertainty and barriers to deployment. At the time of this report, no such document or pathway exists for advanced nuclear technologies, including those derived from nontraditional technology such as advanced manufacturing technology (AMT) and, specifically, additive manufacturing. This report will explore and provide recommendations as to how advanced nuclear technologies derived from additive manufacturing technologies could employ the use of an ISG, other guidance document, or revisions to NUREG-1537 to lower the regulatory uncertainty and barriers for adoption.

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