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U.S. Nuclear Regulatory Commission Historical Perspectives of Very Low-Level Radioactive Waste - 18367

The United States Nuclear Regulatory Commission (NRC), in Title 10 of the Code of Federal Regulations Part 61 (10 CFR Part 61), 'Licensing Requirements for Land Disposal of Radioactive Waste', provides licensing procedures, performance objectives, and technical requirements for the issuance of licenses for the land disposal of low-level radioactive waste. Low-level radioactive waste is divided into four categories based on its potential risk and need for isolation. Class A is the lowest category of low-level radioactive waste and poses the least risk. A large percentage of Class A low-level waste contains very low radionuclide concentrations and does not pose a significant health and safety risk. In the current regulatory framework, this waste, referred to as low-activity or very low-level waste, is managed in the same manner as much more hazardous waste. In 1986 and 1990, as a result of the Low-Level Radioactive Waste Policy Amendments Act of 1985, the NRC issued the Below Regulatory Concern (BRC) policy statement. This policy statement established an implementation plan regarding the expeditious handling of rulemaking petitions 'to exempt specific radioactive waste streams from regulation due to the presence of radionuclides in sufficiently low concentrations or quantities as to be below regulatory concern.' The BRC policy statement provided a consistent risk framework when considering regulatory exemption decisions, such as: (1) the release for unrestricted public use of lands and structures containing residual radioactivity; (2) the distribution of consumer products containing small amounts of radioactive material; (3) the disposal of very low-level radioactive waste at other than licensed disposal sites; and (4) the recycling of slightly contaminated equipment and materials. Due to concerns with the BRC policy that were raised by Congress, the States, the public, and others, Congress enacted the Energy Policy Act of 1992, which revoked the NRC's 1986 and 1990 BRC policy statements and led to the NRC's formal withdrawal of the BRC policy in 1993. Stakeholders raised concerns on NRC's potential deregulation of radioactive material. Additionally, in March 2005, the NRC staff proposed a rule to amend 10 CFR Part 20, 'Standards for Protection Against Radiation,' to include radiological criteria for controlling the disposition of solid materials with very small amounts of residual radioactivity. The NRC staff also proposed a limited disposition approach for the disposition of solid material, limiting the release of solid material meeting a 0.01 milli-Sievert per year (mSv/yr) [1 milli-rem (mrem/yr)] dose criterion, from licensed control. In June 2005, the Commission disapproved publication of the proposed rule and deferred the rulemaking until a later time, stating that the NRC's existing approach of reviewing specific cases on an individual basis was fully protective of public health and safety. This rulemaking effort was discontinued by the Commission in 2016. Recently, several nuclear power plant licensees have announced early decommissioning of their facilities. Some stakeholders have expressed concerns about the capacity and disposal costs associated with using the four existing low-level waste disposal sites for very low levels of radioactive waste (i.e., waste at the low end of the Class A category). A more risk-informed, performance based approach to waste disposal would allow more flexibility in managing this waste commensurate with its risk and hazard. A new approach would also allow the NRC to align with international standards for this type of waste. The NRC is presently conducting a scoping study to identify the actions the agency should take to strengthen its regulatory framework for very low-level waste disposal. The Very Low-Level Waste (VLLW) scoping study will consider divergent stakeholder comments; lessons learned from the BRC policy statements and the proposed rule on radiological criteria for controlling the disposition of solid materials; and best practices of other countries with respect to VLLW disposal. The NRC will also engage other government agencies to discuss regulatory options for VLLW. This paper offers a historical overview of past NRC initiatives to manage the lower end of Class A waste in a manner that is risk informed and performance based. It examines previous endeavors and discusses the regulatory challenges that arose. It also addresses lessons learned and introduces NRC's current effort regarding very low-level radioactive waste disposal. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Reliability and Integrity Management Scoping Study

The U.S. Nuclear Regulatory Commission (NRC) is developing the regulatory framework and technical expertise to support regulatory review of advanced non-light water reactor (ANLWR) designs. The NRC staff expects most of these designs to use the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC) Section XI, Division 2 “Requirements for Reliability and Integrity Management (RIM) Programs for Nuclear Power Plants” for developing and implementing pre-service inspection (PSI) and in-service inspection (ISI) programs. The NRC recently endorsed ASME BPVC Section XI, Division 2 (BPV XI-2) in Regulatory Guide (RG) 1.246. This new ASME code is yet to be used in any applications submitted for NRC review. This report provides an overview of the current state of knowledge and practices within the industry for the use of BPV XI-2 for the development and implementation of a PSI and ISI program for non-light water reactors.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Application of Electrochemical Methods to Molten Salt Reactors: Draft TLR Documenting Assessment of Electrochemical Monitoring

Nuclear Regulatory Commission (NRC) is developing the regulatory framework and technical expertise to support regulatory review of advanced non-water reactors, including molten salt reactors (MSRs). In an MSR, it is essential that the salt chemistry be maintained in a desired range in terms of redox potential for reliable operation and mitigation of corrosion to structural materials in the reactor, particularly the reactor vessel and heater exchanger. Measuring the redox potential of the salt in the reactor would also allow for the material lifetimes to be predicted more accurately, and chemical issues to be diagnosed more quickly. In addition to the chemical composition analysis by ICP-MS, electrochemical methods including potentiometry and linear wave scanning (LSC) were also used in molten salt reactor experiment (MSRE) for redox potential monitoring purposes. Electrochemcial methods offers unique advantages such as quick turnaround in results and unique capability of in-line monitoring of redox potential, and are considered popular electroanalytical techniques that can be used to monitor redox potentials and salt chemistry including impurities. The last two decades have seen significant advances in science and engineering of electrochemical methods for potential application to molten salts. The primary goal of this report is to assist NRC in understanding the monitoring of the salt chemistry by electrochemical methods and provide NRC reviewers with necessary information and tools to support regulatory review of MSR designs. This reports consists of two majors parts—Part 1, chemical potential of molten salts and effects by fission process in MSR; Part 2, assessment of electrochemical methods for application to MSRs. The TRLs of the typical relevant electrochemical methods for molten salts were evaluated based on the DOE TRL guidelines and upon a review of the current status of the electrochemical methods for two typical salt systems, fluoride and chloride, for MSRs.

11 - NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Regulatory Considerations Regarding Potential High Temperature Fluid Releases in Advanced Reactor Designs

The current effort is supported by the U.S. Department of Energy (DOE), Advanced Reactor Demonstration Program (ARDP) Regulatory Development, Regulatory Framework Modernization area, which seeks to address potential regulatory challenges for advanced reactor vendors that are currently or will soon be initiating the licensing process. In pursuit of this goal, this effort seeks to aid the advanced reactor industry and regulatory bodies in understanding and addressing the potential occurrence of high-temperature fluid releases in advanced reactor designs as part of licensing and regulatory oversight of operation. Improving the awareness and understanding of the behavior and potential consequences associated with high-temperature fluid release events can ensure that they are appropriately considered and addressed.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Applying Technology and Experience to Ensure Safe In Situ Decommissioning - 19587

Permanent entombment of a radioactively contaminated facility as a decommissioning option (In Situ Decommissioning, ISD) has been completed for DOE facilities at the Savannah River Site (P and Reactors, HWCTR reactor), Hanford (U Canyon) and Idaho (CP-601/604),and is currently being considered for implementation at a limited number of selected DOE facilities as well as for the NPD and WR-1 reactors in Canada and various facilities in the United Kingdom. A general description of an ISD project encompasses an entombed facility which in some cases is limited to just the below-grade portion of a facility with the above-ground portion being decommissioned, packaged and disposed in a conventional manner. The entombed portions of the facility are of robust construction, generally of reinforced concrete exterior, that provides a migration barrier between internal contamination and the environment with significant internal void spaces backfilled or grouted. The scope of entombment may include ancillary equipment and structures and may contain radioactive and hazardous materials and contamination within the facility and waste imported from outside the facility. ISD is most often a permanent decommissioning end-state although in some instances (e.g. the U.K.) there may be a need to revisit the ISD facility after 300 years to effect traditional decommissioning. The defined completion (the end-state) of the decommissioned facility is therefore project-specific and in conformance with environmental approval processes and planned future activities. In all cases however, the final condition is passive, meaning that there are no requirements for ongoing operational systems or equipment within the decommissioned facility. ISD projects in the USA are presumed to be under indefinite institutional control of the U.S. Government. The regulatory framework in the U.S. is currently in place to provide assurance that the risk posed by an ISD facility is within regulatory acceptance criteria. (The framework in the U.K. and Canada is evolving towards that in the USA). Special emphasis is placed on the fact that an entombed facility is not considered a waste disposal facility; rather it is a decommissioning end-state option. ISD does not eliminate the need for effective and careful management of contaminated materials and structures, nor does it serve to abandon contaminated buildings in place. Further, ISD is safe and cost-effective for a relatively small number of facilities across the DOE Complex. This paper explores the current programmatic considerations and technical aspects of the ISD process and discuss the measures taken to ensure that an 'entombed' facility is safe for both site workers and the general population. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Waste Management Project Success - Regulatory Assurance Systems - 20118

Waste management (WM) and remediation projects are essential within a restorative environmental culture. Despite years of experience, challenges and obstacles associated with efficient and effective WM project execution remain. Although some obstacles are project specific, a common challenge is navigating the regulatory landscape from planning through execution, particularly with first of a kind (FOAK) and first in a while (FIAW) projects. The absence of a comprehensive regulatory assurance strategy places significant hurdles in the path of project success. To clear a path for the successful execution of increasingly complex WM projects, this paper focuses on development of a comprehensive regulatory assurance strategy and implementation plan that effectively engages stakeholders, agencies, and performers to produce project plans that fully and cost effectively integrate applicable regulatory requirements. The most reliable way to align regulatory processes and decisions needed for mission success is through a regulatory assurance system. This system establishes a healthy interface with regulatory decision makers, to work in a collaborative manner, to create a common vision for regulatory decisions on an agreed upon schedule. A regulatory assurance system consists of several elements. Although the mission may vary from cleanup to site closure to nuclear component production, the elements of a regulatory assurance system remain essentially constant and must include: 1) identifying a common vision or end state, 2) developing a long-term, integrated strategy and schedule, 3) establishing a regulatory partnering team consisting of key decision-makers, 4) regular and frequent communication with decision-makers, 5) ensuring consistent surveillance for early identification of issues and changes that may impact the project, 6) quick resolution of emerging issues to prevent schedule impact, 7) identifying core compliance functions, 8) periodically assessing progress of the project as it relates to regulatory assurance and, 9) providing constructive feedback to improve the process. A regulatory assurance system provides a living, multi-faceted approach to planning, visioning, communicating and tracking to avoid surprises and ensure smooth and timely progress to the project. The overall success measures will be whether the system produces common sense regulatory decisions supporting the vision on time without appeal. Effective regulatory frameworks rarely happen on their own. Balanced, common-sense regulatory decisions stem from teams that are trained to work together to achieve shared goals. In this paper, particular attention is placed on the importance of starting with a shared vision for a regulatory assurance and execution strategy that leverages experience to establish optimal approaches. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Challenges in Demonstrating Safety Criteria Satisfaction for External Events under a Risk-Informed Performance-Based Framework

The NRC is currently developing 10 CFR Part 53 that would establish a technology-inclusive regulatory framework for use by applicants for new commercial advanced nuclear reactors. The new draft rule language brings new explicit regulatory requirements of the quantitative health objectives (QHOs) as a constraint on plant risk and safety criteria for the plant design, including external hazards. Historically, light water reactors (LWRs) have demonstrated satisfaction of the QHOs through the use of surrogates in the form of CDF/LERF. However, these risk surrogates are not broadly applicable for all advanced reactor types, and for advanced reactors where external events are likely to be the dominant contributor to plant risk, a direct calculation of the QHOs in terms of offsite consequence is likely necessary. While the detailed analysis of low frequency events provides insights that can help justify alternative treatments to past conservatisms, the findings are dependent on the quality and confidence associated with the analyses. The assessment of external hazards presents a unique challenge, as their potential frequency of occurrence, especially of largemagnitude events, is inherently uncertain given the long return periods in question. This paper evaluates the QHOs and their potential role as safety criteria in evaluating external event risk as it applies to advanced reactors to aid in the development of consistent and appropriate analysis methodologies.

Chen, Ben↗

Regulatory Considerations for Domestic Reprocessing Facility Physical Security

U.S. advanced non-light-water reactor vendors may pursue collocated on-site reprocessing activities. Therefore, these facilities are likely to possess formula quantities, or Category I quantities, of special nuclear material (SNM) during normal operations. The U.S. Nuclear Regulatory Commission (U.S. NRC) has yet to formally establish a regulatory framework for commercial reprocessing. While Category I requirements would explicitly not apply in this circumstance under current regulatory requirements, regulatory certainty does not exist. A novel framework should be developed to ensure public health and safety while also risk-informing the physical security requirements. This report reviews the relevant background of related rulemaking activities and proposes risk-informed physical protection requirements to satisfy these objectives. Insights from NRC security-related rulemaking activities provide a substantial technical basis to approach potential establishment of physical security requirements for reprocessing facilities. If a licensee can provide justification that the material satisfies a sufficient self-protecting radiation dose threshold, the material may not be subject to theft or diversion requirements and only potential sabotage requirements would apply. Furthermore, if the material can be justified to be moderately dilute, a set of risk-informed requirements could provide adequate protection of public health and safety. A revised performance objective for prevention of theft of moderately dilute Category I SNM may be detection to allow prompt recovery by a local law enforcement agency. However, a significant caveat to the proposed categorization scheme is the unknown integration of radiological sabotage with requirements for the protection against theft. Future licensees should consult with the NRC regarding treatment of this regulatory topic. Additionally, the self-protecting radiation dose threshold (either the existing or a proposed future threshold) would need to be considered. An integrated approach may apply graded potential requirements for protection against the design basis threat of radiological sabotage currently applicable to commercial nuclear power plants and Category I SNM facilities defined within 10 CFR 73.1(a).

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

A Community Guide to Regulatory Barriers Affecting Microgrids (Reports 1-3)

In response to growing risks of power outages from extreme weather and aging infrastructure, communities are increasingly exploring the potential of microgrids to provide reliable energy access. Microgrids offer promising solutions to meet this challenge but face a complex landscape of non-technical barriers, particularly regulations concerning the provision and distribution of energy. Most existing legal and regulatory frameworks were designed for a centralized, one-way power system, and are often poorly suited to handle systems that independently balance distributed energy resources with local load. This three-part report series provides a strategic analysis of existing regulatory and legal factors affecting microgrid deployments to help non-technical community leaders and decision-makers better understand the feasibility of a microgrid in their community. -Report No. 1: Foundational Issues Facing Microgrids details the universal policy barriers all microgrids face, including utility interconnection processes, rate structures, and local permitting. -Report No. 2: Single Property Microgrids outlines how direct asset ownership and operating behind-the-meter can bypass some regulatory oversight, using the Blue Lake Rancheria microgrid as a case study. -Report No. 3: Multi-Property Microgrids tackles the complex challenges of crossing public rights-of-way and navigating utility franchise rights, highlighting the Coventry microgrid project. The series equips decision-makers with phased frameworks to navigate financial and regulatory complexities, engage effectively with local utilities and Authorities Having Jurisdiction (AHJs), and structure successful microgrid projects.

24 POWER TRANSMISSION AND DISTRIBUTION↗

Cradle-to-Grave: Assessment Methods for Hazardous Waste Management

The Resource Conservation and Recovery Act (RCRA) was passed to set up a framework for the proper management of waste. The 40CFR260-273 regulation established the regulatory framework to handle solid and hazardous waste, from the point of generation to its disposal; or cradle-to-grave management. Per these regulations, a hazardous waste generator is responsible for its waste from initial generation through its ultimate disposal and beyond. Nothing will relinquish a generator of this responsibility. There is no expiration date or time limit, and hiring a someone else to transport and dispose of waste does not transfer responsibility. If an incident occurs at any point during the life cycle of a waste, the generator can be held liable. The first step to compliance with RCRA is proper characterization of the waste. Waste may either be listed specifically or may show a characteristic as defined in the regulation: Is my waste hazardous? Why is it Hazardous? What should I do as a generator? Plan chemical use: - Create a chemical inventory for your research project. - Use existing chemicals if available instead of ordering new ones. - Brainstorm methods that will help to reduce toxicity and minimize waste. Waste Inventory: - Label all waste bottles with: ID no., What is it, Whose is it, Hazards, and Date. - Add waste containers into the inventory log. - Initiate/complete the container sheet to describe the waste. Satellite Areas: - Store waste in containers compatible with the waste with lids on tight. - Store waste containers properly and segregate them according to their specific hazards. - Use secondary containment for liquids. Store acids and bases separately; apart from cyanides or sulfides. Acids should never be put into steel containers. Water-reactive, strong acids such as organic acid halides, organic acid anhydrides, inorganic acid anhydrides, and strong acidic salts must be kept apart from both alkalis and water. Oxidizing agents must be kept apart from reducing agents and organic compounds. Water-reactive agents must be stored apart from water, aqueous solutions, and acids. Air-reactive materials must be packed in containers that are sealed off from the atmosphere. Explosive and shock-sensitive materials present risks that require special handling.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Regulatory Treatment of Low Frequency External Events under a Risk-Informed Performance-Based Licensing Pathway: Enhanced SPRA-based Margins Assessment

Recently there has been development in the field of risk-informed performance-based (RIPB) design and licensing approaches, which leverage detailed risk assessments and performance-based metrics to allow flexibility and innovation. These RIPB approaches include the probabilistic treatment of external hazards, including low frequency events that are beyond the design basis. However, there are certain challenges that have been identified to the probabilistic treatment of low frequency external events, primarily due to uncertainty in the hazard curve and the associated plant response to rare, severe events. The NRC is currently developing 10 CFR Part 53 that would establish a technology-inclusive regulatory framework for use by applicants for new commercial advanced nuclear reactors. By examining the regulatory safety criteria contained within draft 10 CFR Part 53 and associated draft RIPB seismic design guidance, potential challenges were identified in demonstrating satisfaction of the safety criteria for low frequency external events, with specific difficulties associated with demonstrating compliance with the quantitative health objectives (QHOs). Non-LWRs are expected to utilize the direct calculation of offsite consequence, rather than use surrogates, for comparison to the QHOs, which can be particularly challenging as the previously identified uncertainties are compounded by uncertainties in the response of the neighboring population. The central recommendation from this effort is that it is necessary to develop an approach for demonstrating compliance with the safety criteria in draft Part 53 that addresses the key challenges while providing flexibility to applicants. This paper summarizes key findings, establishes a series of high-level goals, and reviews a newly developed approach to address the major challenges associated with assessing compliance with QHOs, with avenues to demonstrate compliance based on either the estimated consequence or the available margin to event occurrence, while also building on existing experience of seismic margins assessments. The paper also provides examples to demonstrate the application of the approach, as well as recommendations and potential future work.

external hazards↗

An Integrated Feasibility Study of Reservoir Thermal Energy Storage (RTES) in Portland, OR, USA

In regions with long cold overcast winters and sunny summers, Deep Direct-Use (DDU) can be coupled with Reservoir Thermal Energy Storage (RTES) technology to take advantage of pre-existing subsurface permeability to save summer heat for later use during cold seasons. Many aquifers worldwide are underlain by permeable regions (reservoirs) containing brackish or saline groundwater that has limited beneficial use due to poor water quality. We investigate the utility of these relatively deep, slow flowing reservoirs for RTES by conducting an integrated feasibility study in the Portland Basin, Oregon, USA, developing methods and obtaining results that can be widely applied to RTES systems elsewhere. As a case study, we have conducted an economic and social cost-benefit analysis for the Oregon Health and Science University (OHSU), a teaching hospital that is recognized as critical infrastructure in the Portland Metropolitan Area. Our investigation covers key factors that influence feasibility including 1) the geologic framework, 2) heat and fluid flow modeling, 3) capital and maintenance costs, 4) the regulatory framework, and 5) operational risks. By pairing a model of building seasonal heat demand with an integrated model of RTES resource supply, we determine that the most important factors that influence RTES efficacy in the study area are operational schedule, well spacing, the amount of summer heat stored (in our model, a function of solar array size), and longevity of the system. Generally, heat recovery efficiency increases as the reservoir and surrounding rocks warm, making RTES more economical with time. Selecting a base-case scenario, we estimate a levelized cost of heat (LCOH) to compare with other sources of heating available to OHSU and find that it is comparable to unsubsidized solar and nuclear, but more expensive than natural gas. Additional benefits of RTES include energy resiliency in the event that conventional energy supplies are disrupted (e.g., natural disaster) and a reduction in fossil fuel consumption resulting in a smaller carbon footprint. Key risks include reservoir heterogeneity and a possible reduction in permeability through time due to scaling (mineral precipitation). Lastly, a map of thermal energy storage capacity for the Portland Basin yields a total of 43,400 GWh, suggesting tremendous potential for RTES in the Portland Metropolitan Area.

14 SOLAR ENERGY↗

Assessment of Cloud-Based Applications Enabling a Scalable Risk-Informed Predictive Maintenance Strategy Across the Nuclear Fleet

The current light water reactor fleet uses time-based or failure-based maintenance strategies to achieve high-capacity factors. But to make nuclear more competitive in the energy market, these reactors could utilize emerging technologies in terms of artificial intelligence (AI) and cloud computing to enable a cost-effective, predictive maintenance strategy. This report examines the feasibility of cloud computing for the nuclear industry’s needs in terms of the cloud’s computing capabilities, feasibility, and regulatory concerns. The technical viability of cloud computing was analyzed using one year worth of data from a boiling water reactor’s safety relief valve. Models were hosted on a local desktop, Idaho National Laboratory’s high-performance computer, and Microsoft Azure. Data was loaded, processed, and two types of models were trained in an A/B fashion. Based on the speed at which these actions were completed, it was used to determined that cloud computing has adequate computing resources. Additionally, the computing power can scale with the demanded load. To enable cloud computing in the existing fleet, additional sensors, networks, and other requirements must be implemented to ensure a smooth transition from current maintenance strategies. However, there is a benefit as the plant no longer needs manage their own servers, software, cybersecurity, and IT support staff. Many of these features can be offloaded on to the cloud provider. A comprehensive analysis was completed that showed the current annual cost of operating is more expensive than using cloud computing resources. Lastly, the regulatory framework does not explicitly address AI or autonomous control. Currently, the NRC and other regulatory bodies are evaluating providing guidance to address gaps rather than new regulations to address the use of AI and ML. But since many of the AI applications are focused on non-safety related applications, such as balance-of-plant components, they will likely have little or no regulatory restrictions or necessary approvals. Demonstrating how AI can improve maintenance and operation of these non-safety related systems seems like the likely path forward for implementing AI and cloud computing resources inside nuclear power plants (NPPs).

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

Transforming Power Systems through Global Collaboration

Ambitious and integrated policy and regulatory frameworks are crucial to achieve power system transformation. The 21st Century Power Partnership -- a multilateral initiative of the Clean Energy Ministerial -- serves as a platform for public-private collaboration to advance integrated solutions for the large-scale deployment of renewable energy in combination with energy efficiency and grid modernization.

21st Century Power Partnership↗

Advanced Reactor Regulatory Development Status Report for FY 2018

This report provides a summary status of various INL-supported activities leading to the Nuclear Regulatory Commission (NRC) publication of regulatory guidance for advanced (non-light water reactor) designs. This regulatory guidance includes new design criteria designated as advanced reactor design criteria as proposed by a U.S. Department of Energy (DOE) national laboratory team to the NRC. The advanced reactor design criteria guidance was developed in response to requests from industry. The guidance is intended to provide a basis from which future advanced reactor developers and license applicants can build principle design criteria to address regulatory requirements in their specific license applications. In addition, this report provides the current status for a number of advanced non-light water reactor (non-LWR) regulatory framework development activities, including functional containment performance criteria, advanced reactor codes and standards development, and the Regulatory Technology Development Plan.

42 ENGINEERING↗

Code of Record: DOE Standard Canister (DOESC)

The United States Department of Energy (DOE) Spent Nuclear Fuel (SNF) Packaging Demonstration seeks to develop and demonstrate the designs, technology, processes, and regulatory framework for packaging DOE SNF for road-ready dry storage (RRDS); and establish the processes that will be used in a future production facility. The Packaging Demonstration will utilize the DOE Standard Canister (DOESC) for packaging select DOE-managed SNF types for interim storage, transportation and disposal as part of RRDS. Placing DOE-managed SNF into RRDS is part of the strategic framework for SNF on the Idaho National Laboratory (INL) site. To comply with DOE, INL and Nuclear Regulatory Commission (NRC) requirements, this Code of Record establishes the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC), Section III, Division 3 as the Code that will govern DOESC and internal support structure constructioni, with certain clarifications. This Code of Record establishes a rationale for proceeding without construction certification of the DOESC (i.e., “N-stamping) and the extent to which a Registered Professional Engineer is required for the DOE Spent Fuel Packaging Demonstration. Given the (i) standard industry practice to pursue independent licensure of commercial storage casks and transportation packages by the NRC in lieu of ASME certification and (ii) guidance provided by 10 CFR 830, DOESC construction activities need not be certified (i.e., “stamped”) to the ASME BPVC. However, additional quality assurance requirements will apply as outlined in this Code of Record.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Policy and Regulatory Environment for Utility-Scale Energy Storage: India

This report is part of a series investigating the potential for utility-scale energy storage in South Asia. The first part of the work is focused on opportunities and barriers for energy storage within existing policy and regulatory frameworks in the region. This report applies the previously-developed Energy Storage Readiness Assessment to evaluate the policy and regulatory environment for energy storage in India. Forthcoming reports will expand this analysis to other countries in South Asia. These evaluations are designed to provide insights on the opportunities and barriers for energy storage growth and deployment in each country. The second part of this work consists of techno-economic analysis to understand the drivers of energy storage investments in South Asia. Using NREL’s power system planning and operational models of South Asia, this analysis will identify potential storage applications and growth under various cost, policy, and demand growth scenarios. In addition, the regulatory and policy barriers and incentive mechanisms identified in the first task will be incorporated into the modeling task to understand their impact on energy storage deployment and operation. Together these studies will inform the applications and value of energy storage on South Asia power systems and policy and regulatory pathways to realize this value.

29 ENERGY PLANNING, POLICY, AND ECONOMY↗

Reliability and resilience of environmental flows under uncertainty: reconsidering water year types and inconsistent flow requirements in California

Abstract Environmental water allocation in California is a complex legal process involving various government agencies and stakeholders. E-flow requirements can be based on annual runoff typologies called water year types (WYTs), which dictate water volume, timing, and duration. In this study, we examined hydropower licensing documents of the major water and power projects in the Central Sierra Nevada to catalog e-flow requirements by WYT. In this study case, we identify how WYT classification systems and categories vary across and within different basins. Additionally, we assessed the impacts of climate change on hydrology, the frequency of WYTs identified, and the reliability and resilience of e-flows using future projections (2031–2060) of 10 Global Circulation Models (GCMs). We then propose a potential adaptation strategy using a 30 year moving percentiles approach to recalculate WYTs. We identified eight WYT classifications systems were identified, and their WYT distributions statistically significantly changes across all GCMs, even though most GCMs indicate no statistically significant change in hydrology. Disparities in future impacts are observed among and within hydropower projects, with some river reaches showing negative impacts on reliability and resilience. The adaptation strategy can generally boost resilience and improve reliability, but simply updating existing WYT thresholds without flexible regulatory frameworks reconsidering WYTs and e-flows thresholds, may not yield substantial improvements. Challenges in managing e-flows in California within regulatory and hydroclimatic contexts are intricate due to the lack of standardized approaches, leading to inconsistencies and potential conflicts among stakeholders, that will likely be exacerbated by climate change. Thus, we emphasize that targeted, site-specific, and adaptive management strategies are crucial, besides the need for a harmonized and consistent approach to defining and applying WYT categories and methods and/or e-flow assessments.

Environmental Sciences & Ecology↗