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

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

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Vendor-Independent Design Requirements for a Boiling Water Reactor Safety System Upgrade

This Vendor-Independent License Amendment Request (LAR) Framework Document is a research product developed for the Idaho National Laboratory Light Water Reactor Sustainability (LWRS) Program. It was developed by MPR Associates, Inc. with technical input from LWRS and Exelon Generation personnel. To accomplish the purpose of this research, an operating plant (Limerick Generating Station [LGS]) was used as a reference to provide a concrete example and to present a "top-down" view of design concepts consistent with functional requirements baseline documents (references X and Y) also developed for this research. While this document is written in a framework to support a complete LAR submittal, its purpose is to communicate research concepts and provide an example of how to present digital information necessary to address expectations with regard to leveraging the Alternate Review Process as provided in Digital Instrumentation and Controls Interim Staff Guidance #06, Revision 2, Licensing Process. To leverage that process, this research document presupposes that a utility would select a vendor platform which has been prequalified for safety-related by the United States Nuclear Regulatory Commission. While this document is written using the Exelon Generation Limerick Generating Station (LGS) Units 1 and 2 as a baseline, this document is a research product. This document contains no commitments and makes no binding design decisions for Exelon Generation. Exelon Generation is leveraging this research to support their in-progress LGS Plant Protection System (PPS) upgrade efforts and plans to leverage it for their Redundant Reactor Control System (RRCS) replacement. The LWRS Program appreciates the research support provided by Exelon Generation in the generation of this document.

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

Wireless Sensor Modalities at a Nuclear Plant Site to Collect Vibration Data

One of the major contributors to the total operating costs of domestic nuclear fleet of reactors today is the operation and maintenance (O&M) costs. These include labor-intense preventive maintenance programs involving manually-performed inspection, calibration, testing, and maintenance of plant assets at periodic frequency and time-based replacement of assets at periodic frequency, irrespective of their conditions. This has resulted in a labor-centric business model to achieve high capacity factors. To build an optimal maintenance program, it’s time to transition from this labor-centric business model to a technology-centric business model. Fortunately, there are technologies (advanced sensor, data analytics, and risk assessment methodologies) that will support this transition. The technology-centric business model will result in significant plant life extension and reduction of time-based maintenance activities. This will drive down O&M costs as labor is a rising cost and technology is a declining cost. This approach will lay the foundation for real-time condition assessment of plant assets, allowing condition-based maintenance to enhance plant safety, reliability, and economics of operation. The goal of this project is to address challenges in the area of digital monitoring, i.e., the application of advanced sensor technologies (particularly wireless sensor technologies) and science-based data analytic capabilities to advance online monitoring and predictive maintenance in nuclear plants to improve plant performance (efficiency gain and economic competitiveness). To achieve the project goal, in partnership with Exelon Generating Company (Exelon), researchers from Idaho National Laboratory (INL) and Oak Ridge National Laboratory (ORNL) are performing research and development (R&D) to demonstrate application of wireless sensors using the distributed antenna system and advanced data analytics to achieve predictive maintenance. In the report, wireless vibration sensors, vibration data and its indicator are described. The wireless vibration sensors presented in this report support three types of wireless communication, namely, Wi-Fi, cellular, and 900 MHz. These wireless vibration sensors are considered by partner plant site for installation on plant asset to enable online vibration monitoring to replace periodic measurements. These vibration data along with other plant process data will be utilized to develop diagnostic and prognostic models.

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

Demonstration of Electrolyzer Operation at a Nuclear Plant to Allow for Dynamic Participation in an Organized Electricity Market and In-House Hydrogen Supply

This document details the execution of Cooperative Agreement DE-EE0008849, “demonstration of electrolyzer operation at a nuclear plant to allow for dynamic participation in an organized electricity market and in-house hydrogen supply” during the performance period of 10/1/2019 – 9/30/2024. The project was funded by the U.S. Department of Energy’s Office of Energy Efficiency and Renewable Energy (EERE). Constellation Energy Generation, LLC (formerly Exelon Generation Company, LLC) is the prime recipient of the award. Other members of the project team are INL, NREL, ANL and Nel Hydrogen. The main project objective was to demonstrate an end-to-end integrated grid-scale carbon-free H 2 production, storage and utilization pilot plant at a nuclear generating facility. The project also aimed to evaluate market opportunities and regulatory requirements related to the participation of integrated hydrogen production and nuclear plant facilities in organized power markets, by demonstrating dynamic control and operation of the electrolyzer and assessing the economics of dynamic participation combined with the revenue streams from hydrogen production. On March 7th , 2023 Constellation started hydrogen production at it’s Nine Mile Point Nuclear Plant in Oswego, New York. The PEM electrolyzer operating at Nine Mile Point uses 1.25 megawatt of nuclear electricity to produce 560 kilograms of clean hydrogen per day, more than enough to meet the plant’s operational hydrogen use. It will also help set the stage for possible large-scale deployments at other clean energy centers in Constellation’s fleet that would couple clean hydrogen production with storage and other on-site uses. Employing the lessons learned from the 1.25 MW demonstration-scale, nuclear-powered clean hydrogen production facility at Nine Mile Point, Constellation was a major participant in the MachH2 hydrogen hub recently selected for up to $\$$1 billion by the Department of Energy (DOE) as part of the bipartisan Infrastructure Investment and Jobs Act. Constellation will use a portion of the hub funding to build the world’s largest nuclear-powered clean hydrogen production facility at its LaSalle Clean Energy Center in Illinois. The project was featured in a number of news articles and press releases and received 2 awards. At the 2023 DOE HFTO’s Annual Merit Review meeting, the P.I. Dr. Uuganbayar Otgonbaatar and project manager Robert Beaumont were recognized for “outstanding achievements in the development and demonstration of a first-of-a-kind clean hydrogen production facility, powered by carbon-free nuclear energy, at the Nine Mile Point Nuclear Station in Oswego, New York.” The project was also awarded 2023 Nuclear Energy Institute’s Top Innovative Practice award.

08 HYDROGEN↗

Business Case Analysis for Digital Safety-Related Instrumentation & Control System Modernizations

This LWRS research seeks to assist in breaking the impasse which has precluded digital safety system upgrades by generating and demonstrating a process and related business case tool to enable a Business Case Analysis (BCA). The purpose of a BCA is to show such upgrades can be economically justified. This BCA methodology first systematically establishes a forecast of expected lifecycle costs for I&C identified for upgrade by: • Definitively bounding the scope of current I&C systems envisioned for upgrade. • Collecting historical labor and material usage data that bound cost contributors related to the systems to be upgraded. • Synthesizing and analyzing the data to establish lifecycle cost forecasts for the current systems. In collaboration with engineers familiar with the attributes of the digital equipment to be used in the upgrade and how it is envisioned to be applied, cost savings categories and expected savings in those categories are then identified and applied using the analysis tools developed for this purpose. The result is an estimate NPV of savings enabled by the upgrade. This includes both direct cost savings (e.g., surveillance labor costs) as well as cost avoidance items (e.g., inventory carrying costs). Finally, when utility-provided digital upgrade costs estimates are included, the resultant BCA provides an NPV for the upgrade project. Development of a useful BCA methodology requires a real-world basis. With the cooperation of Exelon Generation (“Owner”), an Exelon-owned 2-Unit BWR Station (“Station”) was used as the foundation for this research. Exelon is pursuing a digital upgrade of current, first-echelon, safety-related I&C systems at these units, including the following: • Reactor Protection System (RPS) • Nuclear Steam Supply Shutoff System (N4S) • Emergency Core Cooling Systems (ECCS) • Anticipated Transient Without Scram (ATWS) Mitigation System

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Safety-Related Instrumentation and Control Pilot Upgrade (Initial Scoping Phase Implementation Report)

This research report (1) describes the process followed and products developed during the SR I&C Pilot Project Initial Scoping Phase, and (2) captures lessons learned. Exelon Generation and LWRS collaborated to develop a Digital Transformation Strategy as part of a larger Advanced Concept of Operations. The proposed SR I&C Pilot Upgrade provides a foundation stone for this Digital Transformation that will improve plant safety, reliability, and operational performance while lowering plant Total Cost of Ownership (TCO). Initial Scoping Phase activities for this Pilot Project have been performed in accordance with industry processes that have been adapted to better support digital upgrades. These processes include IP-ENG-001, Standard Design Process (SDP), NISP-EN-04, Standard Digital Engineering Process (SDEP), and Electric Power Research Institute (EPRI) Report 3002011816, Digital Engineering Guide (DEG). Completing Initial Scoping Phase Engineering and Operations, Licensing, and Project Management Activities was necessary to sufficiently bound the scope, schedule, and estimated cost of the Project to enable utility management to authorize moving into the Conceptual Design Phase. A significant finding of the Business Case Analysis (BCA) methodology developed and applied as part of this effort was that the growth rate of material costs for sustaining the operation of obsolete SR I&C equipment is accelerating. This directly contributed to the Project Economic Analysis created to justify continuing the Project. Project Initial Scoping Phase lessons learned have also been captured to assist the larger industry in understanding the Digital Transformation Strategy and SR I&C Pilot Project Initial Scoping Phase efforts. This is in keeping with the public/private partnership that has been established between the Department of Energy (DOE) and Exelon for this effort with engagement from the NRC. By addressing first-of-a-kind (FOAK) risks and capturing lessons learned, the SR I&C Pilot Upgrade Project addresses technical, regulatory, and business risks to enable subsequent implementers of similar upgrade.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Safety-Related Instrumentation & Control Pilot Upgrade Initiation Phase Implementation Report

This research report (1) describes the process followed and products developed during the SR I&C Pilot Project Initial Scoping Phase, and (2) captures lessons learned. Exelon Generation and LWRS collaborated to develop a Digital Transformation Strategy as part of a larger Advanced Concept of Operations. The proposed SR I&C Pilot Upgrade provides a foundation stone for this Digital Transformation that will improve plant safety, reliability, and operational performance while lowering plant Total Cost of Ownership (TCO). Initial Scoping Phase activities for this Pilot Project have been performed in accordance with industry processes that have been adapted to better support digital upgrades. These processes include IP-ENG-001, Standard Design Process (SDP) [Reference 2], NISP-EN-04, Standard Digital Engineering Process (SDEP) [Reference 3], and Electric Power Research Institute (EPRI) Report 3002011816, Digital Engineering Guide (DEG). Completing Initial Scoping Phase Engineering and Operations, Licensing, and Project Management Activities was necessary to sufficiently bound the scope, schedule, and estimated cost of the Project to enable utility management to authorize moving into the Conceptual Design Phase. A significant finding of the Business Case Analysis (BCA) methodology developed and applied as part of this effort was that the growth rate of material costs for sustaining the operation of obsolete SR I&C equipment is accelerating. This directly contributed to the Project Economic Analysis created to justify continuing the Project. Project Initial Scoping Phase lessons learned have also been captured to assist the larger industry in understanding the Digital Transformation Strategy and SR I&C Pilot Project Initial Scoping Phase efforts. This is in keeping with the public/private partnership that has been established between the Department of Energy (DOE) and Exelon for this effort with engagement from the NRC. By addressing first-of-a-kind (FOAK) risks and capturing lessons learned, the SR I&C Pilot Upgrade Project addresses technical, regulatory, and business risks to enable subsequent implementers of similar upgrades.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

The Feasibility and the Benefits of the Advanced Nuclear Fuel Pellet Designs with Radially Varying Fuel Zoning and Burnable Poison Concentration (Final Summary Report)

As part of the work supported by the US Department of Energy (DOE) Office of Nuclear Energy (NE) Gateway for Accelerated Innovation in Nuclear (GAIN) FY 2021 Voucher, Exelon Generation, now Constellation, and Oak Ridge National Laboratory (ORNL) entered into a cooperative research and development agreement (CRADA) to evaluate and assess the feasibility and impact of various conceptual advanced nuclear fuel pellet designs (ANFPDs). The objective of this project was to perform modeling and simulation and analyses using the advanced modeling and simulation capabilities of VERA/BISON, developed by DOE, to determine the viability and benefits of numerous advanced nuclear fuel pellet design concepts in terms of fuel cycle costs, operational safety, and margin improvement. Whereas the detailed coupled neutronic and thermal hydraulic analyses performed using VERA provided in-depth knowledge in terms of fuel cycle performance, the detailed VERA results were used in subsequent fuel performance analyses using BISON. These subsequent analyses focused on several key fuel performance criteria, such as peak fuel centerline temperature (FCT), fission gas release (FGR), gap closure, plenum pressure, and cladding hoop stress. These key fuel performance criteria were analyzed for some of the conceptual fuel designs and were compared with the results obtained for UO 2 fuel. The results provided detailed information to enable better understanding of the performance of the fuel types analyzed. Understanding the advantage of loading these conceptual fuel designs into the core is important not only to Constellation but also to the entire light-water reactor (LWR) fleet in the United States.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

ATEAM4Py: An Efficient and Scalable Python-Based Model for Charging Demand

This report details the development and implementation of ATEAM4Py, a Python-based simulation model that projects demand for battery electric vehicle (BEV) charging based on adoption trends and consumer behavior. With Exelon’s support, Argonne National Laboratory converted the original Java-based Agent-based Transportation Energy Analysis Model (ATEAM) into Python, resulting in a faster and more efficient tool for forecasting the timing, location, and scale of charging demand growth. ATEAM4Py tackles key challenges in simulation efficiency and runtime, supporting the strategic development of cost-effective grid capacity expansion strategies and ensuring reliable service for stakeholders.

33 ADVANCED PROPULSION SYSTEMS↗

Region-Specific Merchant Hydrogen Market Assessment and Techno-Economic Assessment of Electrolytic Hydrogen Generation: Cooperative Research and Development Final Report, CRADA Number CRD-18-00751

Utilities need to recover value from baseload and some renewable assets even when the electricity is curtailed. The declining cost of renewables (particularly solar), the persistently low-cost of natural gas, and the declining electricity demand, have all worked to lower the price of electricity. Furthermore, the baseload assets have a high turndown cost, which is not reflected in the low market electricity prices. One option for utilizing the curtailed electricity is hydrogen generation. One important aspect of this project will be to provide a “go/no-go” recommendation on the economic feasibility of pursuing hydrogen generation vs. other markets that could offtake curtailed electricity or nuclear steam. This project will specifically assess the opportunities for hydrogen production and use in the service territories of Southern Company Services (SCS), Exelon SBC, and Xcel Energy. Each utility partner represents a different mix of generation fleets: Exelon has significant nuclear assets, Xcel is primarily renewables (wind) with some nuclear, and SCS represents both a renewables fleet and a heavily baseload fleet, which includes significant nuclear. The Contractors will conduct the study of hydrogen market opportunities by first considering the approximate electricity demand and price profiles for the year, and power generation capacity that can be used to produce hydrogen. Therefore, a profile for hydrogen generation will also be developed to better understand the quantity and timing of hydrogen production. Once the hydrogen production schedule is estimated, hydrogen storage requirements can be determined. This effort will provide sufficient information to make a go/no-go decision on moving ahead with a detailed regional case study for hydrogen production in any of the three utility areas.

08 HYDROGEN↗