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Panel Session 3A: Do Non-Conventional Geothermal Developments Need a Specialized Legal Framework?

This presentation was given as part of a panel session at GRC 2023 entitled: Do Non-Conventional Geothermal Developments Need a Specialized Legal Framework? The presentation includes an overview an NREL publication titled, "Topics and Considerations for Developing State Geothermal Regulations," in addition to specific considerations as related to EGS/AGS technologies with relevant state and U.S. Federal statute examples.

advanced geothermal systems↗

Reducing the Overnight Capital Cost of Advanced Reactors Using Equipment-Level Seismic Protective Systems

Consideration of the effects of earthquake shaking on the design and construction of nuclear power plants adds substantially to the overnight capital cost, with anecdotal estimates as high as 35+%, attributed to additional construction materials, need for one-off and sub-optimal designs of equipment due to conflicting design choices, the high cost of seismic qualification of equipment, and regulatory review. Safety-critical equipment in large light water reactors is designed and qualified for seismic demands imposed by the supporting reactor building, optimal mechanical designs are not possible, and designs of a given piece of equipment may vary with height above grade. Similar negative impacts are expected for advanced reactors unless the seismic design paradigm is changed. The overarching goal of this transformational MEITNER project, which involved a multidisciplinary engineering team and designers of three fundamentally different advanced reactors, was to adapt proven seismic isolation and damping technologies to operationalize modular protective systems for safety-class equipment inside advanced reactor buildings. Such seismic protective systems would be tightly integrated into design development for reactor support systems and balance-of-plant construction. The adoption of the technology, which is widely used in non-nuclear sectors, would simplify plant design, enable the use of standardized equipment and buildings, optimized for operational performance, and reduce plant size and weight. The need for site-specific equipment would be eliminated, enabling identical equipment to be used across multiple plants sited across the US and economies of scale, and catalyzing new interest and investment. The equipment-based protective systems would allow siting of advanced reactors in regions of high seismic hazard.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Perspectives for artificial intelligence in bioprocess automation

Recent advances in artificial intelligence (AI) have rapidly changed the lab automation landscape, promoting self-driving laboratories (SDLs) that enable autonomous scientific discovery. These trends are increasingly applied in bioprocess development, yet bioprocessing faces unique challenges - biological complexity, regulatory and safety requirements, and multiscale experimentation - that distinguish it from other automation domains. Rather than pursuing full autonomy, we foresee that hybrid SDLs, combining AI-driven decision-making with sustained human oversight, represent the most practical near-term trajectory. This review examines three interconnected perspectives: (i) hybrid human-machine decision-making for bioprocessing; (ii) laboratory design considerations in the era of AI; and (iii) scale-up challenges when transitioning from screening to manufacturing. We highlight critical gaps in data standardization and the required community efforts necessary to realize autonomous bioprocess innovation.

Helleckes, Laura Marie↗

Engineered Solutions Group's SMR Containment Cable and Electrical Penetration Assembly System

GAIN Project CRADA Number NFE-21-08839, entitled “SMR Containment Cable and EPA System” was initiated by the partnership of Oak Ridge National Laboratory (ORNL) and Engineered Solutions Group (ESG) to test an ESG-designed Electrical Penetration Assembly and Containment Cabling System Qualified for not only legacy LWR designs, but also Small Modular Reactors designs currently being designed by several different suppliers. This project was undertaken to fill the equipment gap of EPA and Cabling Systems that require much more severe environmental requirements than legacy plant applications present due to their smaller containment volumes that result in high energy densities compared to legacy designs. This high energy density results in severe accident environments and more severe normal operating conditions as well. We developed two approaches to qualify Electrical Penetration Assembly (EPA) and Containment Cabling Systems for SMRs and Advanced Reactors. We take into consideration the more severe environmental parameters found with SMR designs. The system will need to meet a qualification test program addressing wear/cyclic aging, potential radiation exposure, thermal aging, vibration aging, thermal cycling, seismic qualification, electrical fault testing (per IEEE 317) and accident simulation. The equipment must meet the requirements of 10CFR50.49, GDC 50 in 10CFR50 Appendix A, and 10CFR50 Appendix J. NRC Regulatory Guides (RGs) identify an acceptable way of meeting regulatory requirements. RGs frequently endorse a standard for meeting these requirements. Specific to this review, equipment would be qualified in accordance with the following IEEE Standards. • IEEE 317-2013 (Electrical Penetration Assemblies), which is endorsed by RG 1.63, Rev. 3, • IEEE 323-2003 and the more current IEC/IEEE 60780-323 (Environmental Qualification of 1E Equipment) which is endorsed by RG 1.89. IEEE 323-2003 is endorsed by RG 1.209, • IEEE 344-2020 (Seismic Qualification. The 2013 version endorsed by RG 1.100, Rev. 4, with exceptions), • IEEE 383-2015 (Electrical Cables) (which is endorsed by RG 1.189 Rev. 4 and the -2003 version endorsed by RG 1.211 rev. 0), • IEEE 572-2019 (Electrical Connectors and Assemblies), which is endorsed by 1.156 Rev 1, and • [IEEE 1202 (endorsed by RG 1.189) would normally be applicable but the advanced cable designs are impervious to this cable flame test.] The primary goal of such a program is to provide an EPA design that can meet the qualification requirements for all legacy light water reactor plants currently operating as well as new plant designs including light water Small Modular Reactors. Thus, these requirements are applicable to plants licensed under 10CFR50 and 10CFR52. Other reactor designs may be evaluated, and this test system and qualification method applied to those applications if the requirements would satisfy the requirements of the intended plant. A secondary benefit of this work is to document some of the history and background in these requirements as there have been recent delays in an SMR licensing process due to NRC Requests for Additional Information in this subject matter area.

42 ENGINEERING↗

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.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Mono-/Bimetallic Doped and Heterostructure Engineering for Electrochemical Energy Applications

Designing efficient materials is crucial to meeting specific requirements in various electrochemical energy applications. Mono-/bimetallic doped and heterostructure engineering have attracted considerable research interest due to their unique functionalities and potential for electrochemical energy conversion and storage. However, addressing material imperfections such as low conductivity and poor active sites requires a strategic approach to design. This review explores the latest advancements in materials modified by mono-/bimetallic doped and heterojunction strategies for electrochemical energy applications. It can be subdivided into three key points: (i) the regulatory mechanisms of metal doping and heterostructure engineering for materials; (ii) the preparation methods of materials with various engineering strategies; and (iii) the synergistic effects of two engineering approaches, further highlighting their applications in supercapacitors, alkaline ion batteries, and electrocatalysis. Finally, the review concludes with perspectives and recommendations for further research to advance these technologies.

37 INORGANIC, ORGANIC, PHYSICAL, AND ANALYTICAL CH↗

Insights from Surrogate Industries on Remote Operations for Advanced Reactors

With development of advanced reactors, understanding the human factors considerations related to remote operations remains an important topic. This work presents insights captured from reviewing relevant surrogate industries with remote operations, as they may apply to advanced reactor development. This work provides insights into important human factors considerations for remote operations to ensure safe and reliable adoption of these prospective reactor technologies.

99 - GENERAL AND MISCELLANEOUS↗

Grid Reliability and U.S. Coal Fleet Attributes: Considerations for State Regulators

This briefing paper provides state utility regulators with a comprehensive and current understanding of the reliability attributes of coal as a generation resource, potential reliability impacts associated with near-term coal plant retirements, and possible mitigation strategies to ensure a stable and resilient energy system.

01 COAL, LIGNITE, AND PEAT↗

Illinois Storage Corridor - CarbonSAFE Phase III: Policy, Regulatory, Legal and Permitting Characteristics; Subtask 5.5

The Illinois Storage Corridor (ISC) project aims to advance the commercial development and implementation of carbon capture and storage (CCS) technologies within a region in Illinois of suitable geology for carbon dioxide (CO 2 ) storage in deep saline aquifers. The project partners have annual emissions greater than 6.5 million tonnes per year; storage hubs are being explored at two sites—one near the One Earth Energy facility in east-central Illinois, and one near the Prairie State Generating Company campus in southwest Illinois. To implement the technology, legal, policy, and economic considerations must be explored. The United States Environmental Protection Agency (US EPA) administers the Underground Injection Control (UIC) program and is responsible for issuing Class VI permits to construct and operate CO 2 injection wells, i.e., a UIC Class VI well permit is required to inject CO 2 into the subsurface for geologic sequestration. The largest consideration of the Class VI well requirements is to protect underground sources of drinking water (USDWs). Additionally discussed are considerations for Class VI permits relating to public engagement. Besides permitting, property rights to storage sites, subsurface pore spaces, and areas for pipeline transportation must be secured. Pore space rights is still a novel concept being explored and not yet addressed by the Illinois legislature. It is believed that surface property rights are required for the subsurface pore space below, so long as there is not a separated mineral estate in the subsurface. Illinois legislature has addressed securing rights-of-way for CO 2 transportation, allowing for easements and the exercise of eminent domain to secure such rights. Economically, the incentives for CCS are ever-expanding. Recently, the federal government broadened the availability and increased the dollar-amounts for the § 45Q tax credits for geological storage of carbon oxides. Congress has also authorized the Advanced Industrial Facilities Development Program which allocates billions of dollars in funds to installing technology at industrial facilities to reduce greenhouse gas emissions. On the state level, Illinois has had its own incentives for CCS projects since 2009 and expanded its emission-related goals again in 2021. The law enacted in 2021 specifically creates a commission to explore implementing CCS at Prairie State Generating Company, a partner on the Illinois Storage Corridor project.

54 ENVIRONMENTAL SCIENCES↗

Resource Adequacy for State Utility Regulators: Current Practices and Emerging Reforms

This report was developed by staff in the National Association of Regulatory Utility Commissioners (NARUC) Center for Partnerships and Innovation (CPI). Additional support was provided from commissioners, commission staff, and other technical experts to provide foundational information for state utility regulators on the evolving nature of resource adequacy for the electric system. With the changing nature of the system, state commissioners will continue to play a vital role in their respective jurisdictions. Their roles in overseeing resource decisions are growing in complexity, with consideration for customer costs, state and federal environmental requirements, extreme weather events, fuel supply limitations, generation retirements, shifting requirements for system operators, and growing levels of intermittent and energy-limited resources (e.g., wind, solar, and battery storage). Reliability concerns continue to be an urgent and immediate priority for utility regulators in most parts of the United States. The information in this report is designed to support state commissioners and their respective staff members as they navigate an evolving resource adequacy landscape to maintain reliability amidst a rapidly changing system.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

Valuing Resilience for Microgrids: Challenges, Innovative Approaches, and State Needs

The United States depends on the delivery of reliable, affordable, clean, and safe electricity. Electric utilities invest billions of dollars each year in generation, transmission, and distribution assets to meet this need. However, experiences with recent natural disasters of increasing frequency and duration demonstrate the shortcomings of this approach in the face of modern threats. Further, as customers rely on electricity for a broader range of important needs, such as transportation, as well as critical life-saving services and mission critical facilities such as water treatment, medical care, shelters, telecommunications, and more, the need to minimize the likelihood and impacts of outages grows. Against this backdrop, resilience has emerged as a key consideration to guide electricity spending, whether from utilities, customers, or taxpayers. Although reliability has been defined and measured for decades with broadly accepted metrics that measure how many customers lose power and at what frequency and duration, resilience considers the electricity system’s response to a disruption and its subsequent impacts on customers. Developing tools and methods to accurately assess the costs and benefits of resilience investments is a critical step toward the goal of mitigating the impacts of outages on customers and society. Today, electric system resilience is largely treated as an externality due to challenges estimating the costs of long-duration outages, impacts of outages on society, and increasing reliance on electricity for a growing set of interdependent services. These interdependencies include the water, wastewater, telecommunications, natural gas, and health sectors. Without knowing how much a given resilience investment will benefit customers or society more broadly, investors, policymakers, and regulators are less likely to make or approve such investments, and less able to prioritize those investments. State Energy Offices and public utility commissions (PUCs) lead the development of state-level energy policy and utility regulation, respectively, and each has interests in encouraging appropriate public and private investments in resilience. To this end, the National Association of State Energy Officials (NASEO) and National Association of Regulatory Utility Commissioners (NARUC), with the support of the U.S. Department of Energy (DOE) Office of Electricity (OE), formed a joint Microgrids State Working Group to explore the costs and benefits of microgrids, barriers to broader deployment of microgrids to meet resilience and other objectives, and policy and regulatory strategies to optimize investments in resilience, including but not limited to microgrids. Although no universally accepted valuation tool for resilience exists, National Laboratories, utilities, researchers, and state and federal agencies have collaborated to develop, apply, and improve a number of approaches to quantify resilience, several of which are still in progress at the time this report is published. This report seeks to share these important advances by discussing current definitions of resilience (Section 1), how microgrids are defined and used to meet resilience objectives (Section 2), new approaches to valuing resilience (Section 3), steps State Energy Offices and PUCs have taken to further resilience valuation efforts (Section 4), and finally, considerations and suggested next steps for State Energy Offices and PUCs (Section 5). Relevant examples of specific microgrid projects and resilience valuation efforts are included throughout the report. While this report is written specifically for NASEO and NARUC members, it may be useful for utilities, local governments, and individual customers interested in improving the way public and private dollars are spent to achieve resilience outcomes.

24 POWER TRANSMISSION AND DISTRIBUTION↗

Estimating the Contributions to Human Error Probability from the Convolution of the Distribution of Time Available and Time Required

As part of their duties, Human Reliability Analysis must often evaluate if crews in nuclear power plants (NPPs) can complete tasks associated with a human-failure event within time limits. For example, the time required in NPP scenarios is determined by systematic and structured walkthroughs, feasibility studies, recorded times from training exercises, and interviews with experienced operators and experts. Typically, a point estimate is derived for the estimate (mean, maximum, or 95th percentile of time required). Using point-estimate values can mask the risk associated with variability among crews, plant conditions and set-up, environmental conditions, and other impact factors under which these actions are executed. While point estimates for time required and time available have served the industry well, without considering the uncertainty they could lead to biased understanding about the risk. The Integrated Human Event Analysis System - General Methodology (IDHEAS-G) model (developed by the US Nuclear Regulatory Commission, NRC) for human error probability calculates human error probability by summing two probabilities: insufficient time and cognitive error. As such, the model takes a more holistic approach by considering the full distributions for time required and time available to calculate the human error probability because the time available to complete the task is insufficient. In this study, we expand on the work of the NRC and discuss methods for estimating these time considerations. For example, for the time required, the impact of Performance Influencing Factors (PIFs) on the distribution was divided into impacts that are aleatory in nature, such as crew-to-crew variability, and those that are epistemic (i.e., the PIFs). Starting with the factors that introduce aleatory uncertainty, a first-order distribution was developed from a large set of time required (i.e., NPP task completion times) data for the range of operator actions that occur in the NPP control room under simulated accident conditions. The first-order distribution can then be adjusted to account for epistemic uncertainty using research associated with the impact of applicable PIFs on the time required. We also develop guidance for analysts to address the probability distributions for the time available. The guidance we developed on how to estimate time required and time available distributions is based on the identification of pertinent research and data, data analyses, and expert knowledge elicitation.

human error probability, human performance, time e↗

Environmental Concerns and Mitigation Associated with Geothermal Resource Confirmation Drilling Activities

In 2017-2018, the Bureau of Land Management's National Renewable Energy Coordination Office, through its Geothermal Program, funded the National Renewable Energy Laboratory (NREL) to analyze technical and environmental considerations related to geothermal resource confirmation drilling. NREL solicited input from a group of technical and environmental experts in the geothermal industry, along with analyzing National Environmental Policy Act of 1969 (NEPA) documentation for previously approved projects. The collected data and analysis will be used by the Bureau of Land Management to examine the possibility of developing a new classification of wells and/or expediting the NEPA compliance process, which could potentially reduce permitting and regulatory compliance timelines when compared to the current process for obtaining a geothermal drilling permit for resource confirmation drilling activities.

15 GEOTHERMAL ENERGY↗

Proposed guidance for preparing and reviewing a molten salt non-power production or utilization facility application

Development of non-power molten salt reactors (MSRs) are under consideration to further establish an MSR experience base, support the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.43(e), and provide any additional analyses needed for development of a full-scale MSR. Guidance provided in this report is based on MSRs operating with liquid fuel (i.e., fuel dissolved within a molten salt). These reactors, unless owned by the DOE or DOD, will require licensing by the US Nuclear Regulatory Commission (NRC) staff. Standard review plan (SRP) guidance for large light water reactors (LWRs) is available in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants; Light Water Reactor (LWR) Edition. However, NRC staff observed that NUREG-0800 is very cumbersome to apply to non-power reactors “because of the great differences in complexity and hazards between non-power reactors and nuclear power plants.” Therefore, a program to develop performance-based guidance applicable to non-power reactors was initiated. In 1996, NUREG-1537, Parts 1 and 2, Guidelines for Preparing and Reviewing Applications for the Licensing of Non-Power Reactors, was published. Part 1, the format and content guide, suggests a uniform format for presenting information in non-power reactor applications that is acceptable to the NRC staff, but conformance with the format and content is not required. Part 2, the SRP, ensures the quality and uniformity of the staff review of an application. Unfortunately, the application guidelines and SRP do not provide adequate guidance for all advanced non-LWR technologies and applications. This discrepancy eventually led to the 2012 development of interim staff guidance (ISG) for NUREG-1537, which includes criteria for describing and reviewing aqueous homogeneous reactors (AHRs). Specifically, NUREG-1537 ISG, 2012 expanded the original document to address three areas: 1. updated criteria for heterogeneous non-power reactors, 2. criteria for licensing AHRs, and 3. criteria for licensing a Part 50-licensed isotope production facility. In 2015, the US Department of Energy (DOE) opted to build on the AHR NUREG-1537 ISG experience by performing a gap analysis of the guidance that would be used to license a non-power MSR. MSRs represent one of the advanced non-LWR technologies selected by DOE for development through a multiyear cost share award with Southern Company Services. Under this Advanced Reactor Concepts 2015 (DOE Advanced Reactor Concepts [ARC] 15) award program, the DOE tasked Oak Ridge National Laboratory (ORNL) to evaluate the guidance changes that the NRC may need to consider when licensing an MSR non-power reactor. ORNL staff, with support from Boston Government Services, LLC, focused on five system-related chapters in NUREG-1537 that were considered most relevant to inform the effort that would be required for a non-power MSR applicant. ORNL documented this review in a technical report, ORNL/TM-2018/834, Proposed Guidance for Preparing and Reviewing Molten Salt Non-Power Reactor License Applications (NUREG-1537). The report was subsequently shared with industry and the NRC. The 2018 review was limited in scope, focusing on key system chapters based on the expected significance of each chapter relative to expected differences in addressing advanced non-LWR technologies, specifically non-power MSRs, compared with heterogeneously fueled non-power reactors. In the ORNL report, proposed generic adaptations were suggested for the following NUREG-1537 chapters: Chapter 4, “Reactor Description”; Chapter 5, “Reactor Coolant Systems”; Chapter 6, “Engineered Safety Features”; Chapter 9, “Auxiliary Systems”; Chapter 11, “Radiation Protection Program and Waste Management” The inclusion of Chapter 11 in the previous review effort was intended to provide guidance for categorizing the waste-handling process for an MSR operating with homogenous fuel. The introductions from Parts 1 and 2 of the 2012 NUREG-1537 ISG provide guidance for the application and review of production facilities. After a period of operation, non-power MSRs with homogenous fuel will include gaseous and soluble fission products. The gaseous fission products will be collected and held for decay in an off-gas system. There might also be an initiative to polish or filter the soluble fission products in the fuel salt by some mechanical or chemical means. The treatment and handling of fission products in the non-power MSR fuel salt and the description of this process in the safety analysis report (SAR) must be very precise to avoid the waste treatment facility being construed as a co-located special nuclear material (SNM) fuel cycle facility (see Section 2.3 of this report). Subsequent to the release of ORNL/TM-2018/834, NRC staff expressed a desire to continue the regulatory gap analysis that was begun in that report. This would provide additional clarity and information addressed in certain sections of the original report, while also providing new guidance on certain topics not addressed in the original report. This revision would benefit the NRC staff reviewing applications involving non-power MSR designs and would help developers understand how the NRC staff might approach the review of such applications. The focus of this report is to provide infrastructure support to the NRC staff for the regulatory review of non-power MSRs.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Aquapv

This project brings together a multidisciplinary team to develop tools and analysis that will help U.S. industry accelerate deployment of floating PV on reservoirs and estuaries through producing: • A tool to assess potential environmental interactions of FPV on reservoirs and estuaries and thresholds for corresponding impacts. • A tailored FPV-specific techno-economic tool to guide users on financial performance and corresponding design considerations. • A synthesized tool, AquaPV, that combines the environmental and economic tools. • A set of case studies on an open-loop reservoir with a traditional hydropower plant (i.e., connected to a natural waterbody), closed-loop reservoir with a proposed pumped storage hydropower plant (i.e., manmade and disconnected from a natural waterbody), and a marine estuary (i.e., where a river meets the ocean), with an FPV system designed and modeled for each site. • A review of regulatory, environmental, and stakeholder opportunities and challenges to identify clear regulatory and environmental pathways to siting FPV on U.S. reservoirs. • A novel, high-fidelity geospatial resource assessment to estimate FPV technical potential on reservoirs in the United States.

Phillips, TylerB. [Idaho National Laboratory (INL)↗

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

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

22 - GENERAL STUDIES OF NUCLEAR REACTORS↗

Large Power Transformer Supply Chain Gap Analysis and Domestic Content Strategies for Hydropower Rehabilitation: Supplemental Report

Large Power Transformers (LPTs) are indispensable to U.S. hydropower operations, serving as generator step-up (GSU) units that interconnect hydro facilities to the transmission grid. Yet the LPT supply chain faces mounting stress from aging infrastructure, limited domestic production, and long lead times. Currently, more than 80% of LPT demand is met through imports, with primary suppliers including Mexico, South Korea, Brazil, Austria, and Canada. Domestic manufacturers supply only about 20% of units, constrained by bottlenecks in high-grade Grain-Oriented Electrical Steel (GOES), copper conductors, bushings, and on-load tap changers (OLTCs). Hydropower rehabilitation projects in particular face additional challenges due to custom design requirements, remote siting, and regulatory needs around domestic content. Regional cost disparities, driven by transportation logistics, labor markets, and import price volatility, further exacerbate project risks. To address these vulnerabilities, coordinated action is required: strengthening domestic capacity for GOES and secondary components, developing near-site assembly hubs, and leveraging IRS domestic content safe harbors to incentivize U.S. manufacturing. This addendum refines the 2024 NREL Hydropower Supply Chain Gap Analysis by focusing specifically on critical issues related to LPT domestic manufacturing capacity and key considerations for hydropower developers and asset owners.

13 HYDRO ENERGY↗

Building kinetic models for metabolic engineering

Kinetic formalisms of metabolism link metabolic fluxes to enzyme levels, metabolite concentrations and their allosteric regulatory interactions. Though they require the identification of physiologically relevant values for numerous parameters, kinetic formalisms uniquely establish a mechanistic link across heterogeneous omics datasets and provide an overarching vantage point to effectively inform metabolic engineering strategies. Advances in computational power, gene annotation coverage, and formalism standardization have led to significant progress over the past few years. However, careful interpretation of model predictions, limited metabolic flux datasets, and assessment of parameter sensitivity remain as challenges. In this study we highlight fundamental considerations which influence model quality and prediction, advances in methodologies, and success stories of deploying kinetic models to guide metabolic engineering.

59 BASIC BIOLOGICAL SCIENCES↗