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Recommendations to Improve Nuclear Licensing: Update to INL/RPT-23-72206, Recommendations to Improve the Nuclear Regulatory Commission Reactor Licensing and Approval Process

In 2023, various stakeholders had asked for BEA’s thoughts and recommendations to improve the U.S. Nuclear Regulatory Commission’s (NRC) licensing review and approval process. This included an April 14, 2023 request from the House Committee on Energy and Commerce on “information and recommendations to improve the licensing review and approval process, . . . as well as the siting, licensing, construction, and oversight of advanced nuclear reactor technologies.” In response to these requests, BEA prepared and published INL/RPT-23-72206, Recommendations to Improve the Nuclear Regulatory Commission Reactor Licensing and Approval Process (2023 Report). The 2023 Report included 13 recommendations related to streamlining NRC hearings, expediting NRC safety and environmental reviews, otherwise improving NRC licensing, and providing financial benefits to new reactor projects. Many of these earlier recommendations were addressed through various legislative actions or changes made by the NRC. Section 2 of this report addresses the current status of those earlier recommendations. BEA recently received a new request from the House Committee on Energy and Commerce seeking any suggestions for additional areas to examine or potential reforms “that may assist in modernizing the licensing and regulatory process that affects civil nuclear deployment.” Additionally, the new Secretary of Energy has identified initial DOE actions to support unleashing the golden era of American energy dominance, including “Unleash Commercial Nuclear Power in the United States” and “Streamline Permitting and Identify Undue Burdens on American Energy.” Given these developments, BEA has prepared a new set of updated recommendations in this report. The recommendations include updated versions of recommendations from the 2023 Report which have not been fully adopted, as well as entirely new recommendations. This set of recommendations has a slightly broader focus with some recommendations focused on DOE authorizations and some recommendations related to nuclear licensing beyond new reactors. Each recommendation below also identifies whether the recommendation would require legislative action or could be addressed directly by the respective agency.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Recommendations to Improve the Nuclear Regulatory Commission Reactor Licensing and Approval Process

Due to the urgency around climate change and associated goals for clean energy transition, and Battelle Energy Alliance's (BEA) and Idaho National Laboratory's (INL) role as the nation's nuclear energy laboratory, numerous stakeholders have asked for BEA’s thoughts and recommendations to reduce the time and costs associated with licensing new reactors at the U.S. Nuclear Regulatory Commission (NRC). As an M&O contractor for an FFRDC, BEA is a long-term partner with the Government in seeking to achieve clean energy goals, yet has a level of independence needed to appropriately evaluate this topic. The views herein are informed by extensive BEA experience supporting nuclear energy endeavors including ongoing discussions with current and former regulators, applicants, and licensees. With this background in mind, the United States benefits from having an agency such as the NRC, which is viewed internationally as the leader in nuclear safety licensing and regulation. Nonetheless, while acknowledging the important nuclear safety role satisfied by the NRC, it is apparent that one of the most significant time and resource intensive activities for new reactor developers is the NRC licensing process. The time and cost to obtain NRC licenses add significant financial stress for new reactor projects and may result in abandonment of projects or failure to even begin new projects. The challenge is particularly acute for advanced reactors which may raise unique or new regulatory questions and may be smaller in size, resulting in a much higher proportional impact from regulatory and cost challenges. This situation presents a particularly troublesome risk for the nation given the urgency in which utilities are working to transition to clean, non-carbon-emitting energy sources like nuclear energy. Reforms to the NRC licensing process have the potential to greatly increase certainty and support the successful progress of new reactors. The NRC can retain its world-class nuclear safety reputation while becoming a world leader for regulatory efficiency and a critical enabler to the clean energy transition. This report describes potential NRC reforms, focusing on those with a statutory connection. Recognizing the potential tradeoffs with any proposed changes, the report attempts to highlight those considerations in the analysis of the reforms. The recommendations are presented as a set of options for consideration. Unless noted, they are independent options, offering stakeholders the option to select a subset for further consideration. Although difficult to calculate precise time improvements for some of the changes, the reforms have the potential for substantial improvements, perhaps even by a factor of two.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

Conceptual Design of Engineering-Scale Molten Salt Spill Tests to Support Molten Salt Reactor Licensing

Nuclear accident progression analysis codes for reactor licensing must be validated using experimental data that was generated at a large enough scale so that the results are representative of full-scale accidents. This report describes a conceptual design of engineering-scale molten salt spill tests that will provide the necessary datasets to support molten salt reactor (MSR) licensing. Design considerations, salt compositions, test variables, processes to be quantified, and suitable measurement techniques are presented and discussed. Aspects of the conceptual engineering-scale molten salt spill test design presented in this report were made using insights from recent laboratory-scale molten salt spill tests conducted at Argonne. Additional input from model developers, MSR vendors, and technical experts will benefit the design of the proposed engineering-scale molten salt spill tests.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Preliminary Design of Engineering-Scale Salt Accident Analysis Facility to Support Molten Salt Reactor Licensing

Systems-level nuclear accident analysis codes for reactor licensing must be validated using experimental data that represent behaviors expected during actual full-scale accidents. Some behaviors may arise from coupled processes and only manifest at large scales. This report presents the preliminary design of the Salt Accident Analysis Facility (SAAF, pronounced “safe”), which is an experimental test facility to be constructed at Argonne that can be used to conduct integrated salt accident tests at an engineering scale. The measurement capabilities of the SAAF are based on previously developed methods and will provide the representative datasets that are needed to support molten salt reactor (MSR) licensing. Details of the design, the processes to be quantified, the measurement techniques for quantifying the processes, the variables that can be adjusted to simulate different accident scenarios, and operational considerations are presented herein. This report provides stakeholders the opportunity to give feedback on the test facility capabilities and planned analyses before it is constructed.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Modeling and simulation functional needs for molten salt reactor licensing

The modeling and simulation functional needs to license and design molten salt reactor concepts were assessed and an evaluation methodology was developed using a licensing-focused approach considering the modeling and simulation components that contribute to a molten salt reactor safety analysis report. These functional needs were prioritized by identifying the relationships between functional needs and using a quantitative weighting method to identify the most critical components to build a licensing case. This novel weighting method provided a list of functional needs prioritized relative to key advanced reactor licensing outcomes. In addition, functional need inputs were ranked to reveal those that feed the most modeling and simulation components. The findings from this prioritization effort were used to inform the modeling and simulation goals of the US Department of Energy Office of Nuclear Energy (DOE-NE) Molten Salt Reactor campaign.Modeling and simulation needs were grouped into three main categories: (1) source term definition, material accountancy, and radiological consequences, (2) safety analysis, and (3) steady-state neutronics and thermal hydraulics. Here, five near-term goals were identified among these focus areas that add value: (1) deploying a systems and safeguards analysis computational tool, (2) defining source terms for molten salt reactor analysis and interfacing with the US Nuclear Regulatory Commission on accident progression analysis, (3) developing point designs for liquid-fueled thermal-spectrum and fast-spectrum molten salt reactors, (4) building safety analysis specifications and reference solutions for Molten Salt Reactor Experiment transients, and (5) interfacing with the thermophysical and thermodynamic salt chemistry databases.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Modular High Temperature Gas-Cooled Reactor: Licensing Part III

Recent Licensing Experience- Advanced and Micro- Reactors Recent Designs Additional Designs Licensing Challenges for advanced reactors Functional Containment Emergency Planning Zones Autonomous and Remote Operation Transportation Manufacturing Licenses NRC License vs. DOE Authorization Siting and Environmental Impact

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Advanced Reactor Licensing

This is the licensing presentation for the Waste Management Symposia 2023. It covers licensing activities, LMP, and manufacturing licenses.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Modular High Temperature Gas-Cooled Reactor: Licensing Part I

NRC PRA Policy Statement motivates risk-informed, performance-based (RIPB) approach to modular High Temperature Gas-cooled Reactor (HTGR) licensing Complements traditional deterministic design approach to increase use of risk insights in design and licensing decisions Risk-informed approach: Explicit consideration to a broader set of challenges Logical prioritization of challenges Consideration of broader set of resources to defend against challenges Explicitly identifying and quantifying sources of uncertainty Better decision making by testing for sensitivity to key assumptions Performance-Based Approach: Measurable (or calculable) parameters for monitoring Objective criteria to assess performance

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Standard review plan for evaluating nuclear power reactor license termination plans

This standard review plan (SRP) guides the staff of the U.S. Nuclear Regulatory Commission (NRC) in conducting safety reviews of license termination plans (LTPs). The principal purpose of this SRP is to ensure the quality and uniformity of NRC staff reviews and to present a well-defined base from which to evaluate the requirements for terminating the license of a nuclear power plant. It is also the purpose of this SRP to make information about regulatory matters widely available, so that interested members of the public and the nuclear industry can gain a better understanding of the NRC staff's review process. Specific guidance for licensees is included in Regulatory Guide 1.179, "Standard Format and Content of License Termination Plans for Nuclear Power Reactors." Licensees may also use this SRP to assist in developing an LTP. The SRP presents the acceptance criteria for all areas of review for license termination, and identifies the matters to be reviewed, the basis for the review, and the conclusions that are sought. For example, NUREG-1757, "Consolidated Decommissioning Guidance" offers additional guidance on how to demonstrate compliance with the unrestricted release, restricted release, and alternative criteria for license termination, in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 20, "Standards for Protection against Radiation," Subpart E, "Radiological Criteria for License Termination." To avoid duplication of information, this SRP references applicable sections of NUREG-1757 for additional guidance. In addition, the NRC has issued supplemental guidance that will subsequently be consolidated into NUREG-1757 to address partial site release before LTP approval, and compliance with 10 CFR Part 20, Subpart E. It should be noted that the memorandum of understanding (MOU) between the Environmental Protection Agency and NRC may contain consultation triggers for some radionuclides that may be lower than the NUREG-1757 Vol. 2 Revision 1, Appendix H screening values.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Risk-Informed Performance-Based Technology. Inclusive Guidance for Advanced Reactor Licensing Basis Development (NEI 18-04)

This guideline presents a modern, technology-inclusive, risk-informed, and performance-based (TI-RIPB) process for selection of Licensing Basis Events (LBEs); safety classification of structures, systems, and components (SSCs) and associated risk-informed special treatments; and determination of defense-in-depth (DID) adequacy for non-LWRs. This guidance document provides one acceptable means for addressing the aforementioned topics as part of demonstrating a specific design provides reasonable assurance of adequate radiological protection.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Comparison of atmospheric radionuclide dispersion models for a risk-informed consequence-driven advanced reactor licensing framework

Current nuclear facility emergency planning zones (EPZs) are based on outdated distance-based criteria, predating comprehensive dose and risk-informed frameworks. Recent advancements in simulation tools have permitted the development of site-specific, dose, and risk-based consequence-driven assessment frameworks. This study investigated the computation of advanced reactor (AR) EPZs using two atmospheric dispersion models: a straight-line Gaussian plume model (GPM) and a semi-Lagrangian Particle in Cell (PIC). Two case studies were conducted: (1) benchmarking the NRC SOARCA study for the Peach Bottom Nuclear Generating Station and (2) analyzing an advanced INL Heat Pipe Design A microreactor's end-of-cycle inventory. The dose criteria for both cases were 10 mSv at mean weather conditions and 50 mSv at 95th percentile weather conditions at 96 h post-release. Results demonstrated that GPM and PIC estimated similar mean peak dose levels for large boiling water reactors in the farfield case, placing EPZ limits beyond current regulations. For ARs with source terms remaining in the nearfield, PIC modeling without specific nearfield considerations could result in excessively high doses and inaccurate EPZ designations. PIC dispersion demonstrated an order of magnitude higher estimate of nearfield inhalation dose contribution when compared to GPM results. Furthermore, both models significantly reduced EPZ sizing within the nearfield. Thus, reductions in the AR source term may eliminate the need for a separate EPZ.

63 RADIATION, THERMAL, AND OTHER ENVIRON. POLLUTAN↗

Modernization of Technical Requirements for Licensing of Advanced Non-Light Water Reactors: Risk-Informed and Performance-Based Evaluation of Defense-in-Depth Adequacy

This document supports the work contained in Nuclear Energy Institute (NEI) 18-04 “Risk-Informed Performance-Based Technology Inclusive Guidance for Advanced Reactor Licensing Basis Development” Revision 0. NEI 18-04 presents a modern, technology-inclusive, risk-informed, and performance-based (TI-RIPB) process for selection of Licensing Basis Events (LBEs); safety classification of structures, systems, and components (SSCs) and associated risk-informed special treatments; and determination of defense-in-depth (DID) adequacy for non-LWRs. The NEI guidance document provides one acceptable means for addressing the aforementioned topics as part of demonstrating a specific design provides reasonable assurance of adequate radiological protection. This report provides the framework and associated methodology guidelines and discussion for establishing, then evaluating, confirming, and documenting the adequacy of defense-in-depth (DID) for advanced non-light-water reactor technologies. It was developed as part of the Licensing Modernization Project led by Southern Company and cost-shared by the United States Department of Energy and has benefited from considerable NRC formal reviews and public workshops. The methodology converts the DID philosophy into a structured process that is implementable, embraces existing United States and international definitions and philosophies of DID that set the foundation for the process. It builds on the DID framework developed in the Department of Energy Next Generation Nuclear Plant Project and earlier works on this subject. The approach to establishing DID adequacy involves the incorporation of DID attributes into the plant capabilities and programmatic elements of DID. The integrated evaluation of DID adequacy includes both quantitative elements to incorporate risk-informed and performance-based (RIPB) considerations and qualitative elements that address uncertainties and limitations in the quantitative models and supporting data. Demonstration of DID adequacy ensures that there are multiple layers of defense for risk-significant challenges to the design and that the plant capabilities and programs that support each layer are provided in a manner that minimizes dependencies among these layers. The focus of this report is assurance of DID adequacy with respect to protection of the public from radiological exposures resulting from accidental releases of radioactive material. While other hazards are not specifically addressed, this methodology is expected to be beneficial for determining DID adequacy for them as well. Risk-informed evaluation of DID considers the integrated performance of all plant SSCs and associated programs to manage daily operational activities, transients, and accidents, including the evaluation of strategies for accident prevention and mitigation. The RIPB LBE scenario methodology used in this evaluation defines the challenges to the plant safety features included in the plant design basis and beyond, and the scope of all deterministic and probabilistic safety evaluations. By examining event sequences across the whole spectrum of LBEs, a systematic assessment of DID can be accomplished.

42 ENGINEERING↗

Proposed Activities to Address Regulatory Gaps and Challenges for Licensing Advanced Reactors Using Seismic Isolation

Over the last decade, particularly since implementation of the certified design regulatory approaches outlined in 10 CFR 52, “Licenses, Certifications, and Approvals for Nuclear Power Plants,” interest has been increasing in the use of seismic isolation (SI) technology to support seismic safety in nuclear facilities. In 2009, the United States (U.S.) Nuclear Regulatory Commission (NRC) initiated research activities to develop new guidance targeted at isolated facilities because SI is being considered for nuclear power plants in the U.S. One product of that research, which was developed around a risk-informed regulatory approach, is a draft NRC NUREG series (NUREG/CR) report that investigates and discusses considerations for use of SI in otherwise traditionally founded large light water reactors (LWRs). A coordinated effort led to new provisions for SI of LWRs in the American Society of Civil Engineers standard ASCE/SEI 4-16, “Seismic Analysis of Safety Related Nuclear Structures.” The risk-informed design philosophy that underpinned development of the technical basis for these documents led to a set of proposed performance objectives and acceptance criteria intended to serve as the foundation for future NRC guidance on the use of SI and related technology. Although the guidance provided in the draft SI NUREG/CR report and ASCE/SEI 4 16 provides a sound basis for further development of nuclear power plant designs incorporating SI, these initial documents were focused on surface-founded or near-surface-founded LWRs and were, necessarily, limited in scope. For example, there is limited information in both the draft NUREG/CR report and ASCE/SEI 4-16 related to nonlinear analysis of soil-structure systems for deeply-embedded reactors, the isolation of components, and the use of vertical isolation systems. Also not included in the draft SI NUREG/CR report are special considerations for licensing of isolated facilities using the certified design approach in 10 CFR 52 and a detailed discussion of seismic probabilistic risk assessments for isolated facilities.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

Modernization of Technical Requirements for Licensing of Advanced Non-Light Water Reactors: Risk-Informed and Performance-Based Evaluation of Defense-in-Depth Adequacy

This document supports the work contained in Nuclear Energy Institute (NEI) 18-04 “Risk-Informed Performance-Based Technology Inclusive Guidance for Advanced Reactor Licensing Basis Development” Revision 0.[19] NEI 18-04 presents a modern, technology-inclusive, risk-informed, and performance-based (TI-RIPB) process for selection of Licensing Basis Events (LBEs); safety classification of structures, systems, and components (SSCs) and associated risk-informed special treatments; and determination of defense-in-depth (DID) adequacy for non-LWRs.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

The Release of the Simplified Radionuclide Transport (SRT) Code (V.2.1)

Reactor licensing centers on the protection of the public and environment from the inadvertent release of radioactive material. Therefore, mechanistic source term analysis, or the realistic evaluation of radionuclide transport from the source to the environment for specific transient scenarios, is vital to reactor licensing efforts. Developed to resolve a gap in mechanistic source term modeling capabilities for sodium fast reactors (SFRs), the Simplified Radionuclide Transport (SRT) code created by Argonne National Laboratory (Argonne) is now utilized by advanced reactor vendors, universities, and research institutions to support a multitude of design, licensing, and research efforts. Recently, SRT version 2.1 was released, which includes improvements to code models and verification and validation (V&V) suite to support the SRT user community. The following work provides an overview of the improvements made as part of the release of SRT version 2.1. This effort is supported by the U.S. Department of Energy Office of Nuclear Energy (DOE:NE) Advanced Reactor Technologies (ART) Fast Reactor Program (FRP), as part of the program’s support of national laboratory design and safety analysis computer codes utilized by the fast reactor industry. The expansion of SRT code capabilities and improvements to code V&V associated with version 2.1 are in response to user requests and lessons learned from recent source term analyses performed by Argonne and advanced reactor vendors. They also align with the evolving role of SRT, from research and development tool to software utilized for reactor licensing calculations. The report is structured in alignment with the code improvements, as outlined in Figure 1-1. Section 2 provides background information on SRT, including its history, capabilities, and utilization. Section 3 details new code capabilities as part of version 2.1, while Section 4 focuses on the expansion of the code’s V&V suite. Lastly, Section 5 provides a summary and discussion of next steps.

73 NUCLEAR PHYSICS AND RADIATION PHYSICS↗