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Management of Risks Associated with Application of Novel Materials in Novel Operating Environments in Novel Reactor Designs

There is currently no widely agreed, detailed general method for licensing a novel plant incorporating novel materials (or materials being deployed in novel environments); in many such situations, there are no directly applicable engineering code cases for decision-makers (including regulators) to rely on. This paper discusses a framework for solving this problem that is based on the Reliability and Integrity Management (RIM) approach delineated in ASME BPVC Section XI Division 2. NRC Regulatory Guide 1.246, Rev. 0, endorses, with conditions, the subject portion of the ASME Code. The proposed framework is meant to support development of a licensing case by addressing certain technical challenges. The framework discussed here is compatible with the Licensing Modernization Project, but applying it in a specific case will call for advances in the state of practice, if not the state of the art. The RIM approach calls for applicants to (a) allocate reliability targets to plant structures, systems, and components (SSCs), (b) show that they are able to relate the currently observed physical condition of each SSC in the program to its failure probability well enough to determine whether the target reliability allocations are being satisfied, allowing for uncertainty related to the novelty of the materials/designs/operating environments, and (c) be able to demonstrate that the proposed program of surveillances will reliably detect unacceptable degradation of an SSC before SSC failure occurs. These challenges are discussed in the paper, and a potentially applicable modeling approach based on cumulative damage rather than failure rates is briefly illustrated.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

New Report Can Help Reduce Time and Cost to Advance Hydropower

With funding from the U.S. Department of Energy's Water Power Technologies Office, researchers at the National Renewable Energy Laboratory and Oak Ridge National Laboratory examined which regulatory bottlenecks can impact the time, costs, or risks of launching new or refurbishing old hydropower projects. A new report, titled "An Examination of the Hydropower Licensing and Federal Authorization Process," can help hydropower developers navigate complex regulatory currents.

HYDRO ENERGY↗

ARC-100 Reactor Security-by-Design Summary

This report applies the security-by-design methodology developed in a previous National Nuclear Security Administration–sponsored work to the Advanced Reactor Concepts 100 (ARC-100) sodium-cooled fast reactor (SFR) design. The report contains no proprietary information specific to the ARC 100 reactor. The insights developed in this report are high-level, and generally applicable to other sodium fast reactor designs. The information presented here is the result of a qualitative safety-based analysis and would not inform any potential adversary beyond what would be found in a docketed safety analysis report. The scope of this present report covers ARC-100’s reactor core, used fuel storage, and used fuel assembly wash station. These systems are also compared to a generic SFR design assumed in the previous study. The security assessment results show changes in structures, systems, and components (SSCs) safety importance relative to the generic SFR SSCs. However, the consequence assessment results are the similar to a previously assessed generic SFR. Several SSCs have higher importance rankings than others, and it is recommended that protection efforts are prioritized for these SSCs. This work will continue in the Fiscal Year 2025 for the remaining ARC-100 systems, including cesium trap, sodium cold trap, noble gas decay tanks (dewar bottles), and used fuel dry storage facility, to provide safety-and-security-by-design insights and recommendations on non-core systems. Results from this work will furnish a technical justification for the feasibility of these solutions for the ARC reactor's design and, where applicable, identify any regulatory benefits conferred by the proactive design aspect within a risk management framework. This initiative will contribute to a more secure design of the ARC reactor and support its licensing process.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

ARC-100 Reactor Security-by-Design Summary 2025

This report applies the security-by-design methodology developed in a previous National Nuclear Security Administration–sponsored work to the ARC-100, a sodium-cooled fast reactor (SFR) being developed by ARC Clean Technology, Inc (ARC). The report contains no proprietary information specific to the ARC 100 reactor. The insights developed in this report are high-level, and generally applicable to other sodium fast reactor designs. The information presented here is the result of a qualitative safety-based analysis and would not inform any potential adversary beyond what would be found in a docketed safety analysis report. The scope of this present report covers ARC-100’s reactor core, used fuel storage, used fuel assembly wash station, cesium trap, sodium cold trap, noble gas decay tanks, used fuel dry storage facility, damaged fuel storage facility, and radioactive waste building. These systems are also compared to a generic SFR design assumed in the previous study. The security assessment results show changes in structures, systems, and components (SSCs) safety importance relative to the generic SFR SSCs. Several SSCs have higher importance rankings than others, and it is recommended that protection efforts are prioritized for these SSCs. Results from this work will furnish a technical justification for the feasibility of these solutions for the ARC reactor's design and, where applicable, identify any regulatory benefits conferred by the proactive design aspect within a risk management framework. This initiative will contribute to a more secure design of the ARC reactor and support its licensing process.

21 - SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLAN↗

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↗

HAZARD ANALYSIS OF DIGITAL ENGINEERED SAFETY FEATURES ACTUATION SYSTEM IN ADVANCED NUCLEAR POWER PLANTS USING A REDUNDANCY-GUIDED APPROACH

Replacing the existing aging analog instrumentation and control (I&C) systems with modern safety control and protection digital technology offers one of the foremost means of performance improvements and cost reductions for the existing nuclear power plants (NPPs). However, the qualification of digital I&C systems remains a challenge, especially considering the issue of software common-cause failures (CCFs), which are difficult to address. With the application and upgrades of advanced digital I&C systems, software CCFs have become a potential threat to plant safety because most redundant designs use similar digital platforms or software in the operating and application systems. With complex designs of multilayer redundancy to meet the single-failure criterion, digital I&C safety systems (e.g., engineered safety-features actuation system [ESFAS]) are of a particular concern in the U.S. Nuclear Regulatory Commission (NRC) licensing procedures. This paper applies a modularized approach to conduct redundancy-guided systems-theoretic hazard analysis for an advanced digital ESFAS with multilevel redundancy designs. Systematic methods and risk-informed tools are incorporated to address both hardware and software CCFs, which provide guidance to eliminate the triggers of potential single points of failure in the design of digital safety systems in advanced plant designs.

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

Intellectual Property and Licensing in the Commercial Space Age

The commercial space industry is undergoing a paradigm shift from the time when governments and very large space companies dominated the industry. A confluence of laws allowing commercial space companies to operate in unprecedented ways, new technologies enabling new commercial space applications, and an influx of risk capital has drastically changed the space industry landscape. As small and medium-sized companies enter the commercial space realm, they will seek a competitive advantage, and universities and the NASA space centers are positioned to offer such advantages. The commercial space industry has recently become an active area of technology partnering and licensing, even for technologies that have experienced poor licensing performance in the past. The Jet Propulsion Laboratory is seeing unprecedented technology transfer activity in the areas of spacecraft navigation, mission design, space antennas, thrusters, radio occultation, and specialized satellites. Intellectual property rights and partnering play a crucial role in the ability of the private sector to invest in these technologies and to drive space technologies forward. Participants in this burgeoning field seek the most cutting-edge innovations to attain a competitive advantage, and it is crucial for those in the university and public sector to gain an understanding of the market forces that are driving the commercial space business.

Broderick, Daniel↗

Intellectual Property and Licensing in the Commercial Space Age

The commercial space industry is undergoing a paradigm shift from the time when governments and very large space companies dominated the industry. A confluence of laws allowing commercial space companies to operate in unprecedented ways, new technologies enabling new commercial space applications, and an influx of risk capital has drastically changed the space industry landscape. As small and medium-sized companies enter the commercial space realm, they will seek a competitive advantage, and universities and the NASA space centers are positioned to offer such advantages. The commercial space industry has recently become an active area of technology partnering and licensing, even for technologies that have experienced poor licensing performance in the past. The Jet Propulsion Laboratory is seeing unprecedented technology transfer activity in the areas of spacecraft navigation, mission design, space antennas, thrusters, radio occultation, and specialized satellites. Intellectual property rights and partnering play a crucial role in the ability of the private sector to invest in these technologies and to drive space technologies forward. Participants in this burgeoning field seek the most cutting-edge innovations to attain a competitive advantage, and it is crucial for those in the university and public sector to gain an understanding of the market forces that are driving the commercial space business.

Broderick, Daniel↗

SMR Current Status: Development Needs and Global Perspectives

Defined as nuclear reactors with a power output up to 300 megawatts electrical (MWe) by the International Atomic Energy Agency (IAEA) and targeted for multipurpose applications, small modular reactors (SMRs) have been recognized as a very promising, clean, affordable, and sustainable energy source by many countries. At present, more than 80 SMRs are under design, development, demonstration, deployment, and beyond (4D+) phases worldwide. This study focuses on the current world status of SMRs and focuses on the necessary developments to accelerate the process of adopting SMRs as a major energy source globally. SMRs are not a new concept, but they do represent a new vision for older concepts if the challenges inherent within them are mitigated with strategic and realistic solution approaches. The major challenges for SMRs 4D+ like any new reactors are: (a) qualifying the advanced fuel-to-reactor design; (b) supporting rapid scaled/prototypic experimentations; (c) maintaining local and global codes, standards, and licensing; (d) supply chain issues;(e) effective cradle-to-grave nuclear fuel cycle and fuel material transportation, and (f) mitigating financial and environmental risks. These upfront challenges can be mitigated with a synergistic solution approach among the various stakeholders: industry, academia, research, government, and international entities.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

Presentation: SMR Current Status: Development Needs and Global Perspectives

Defined as nuclear reactors with a power output up to 300 megawatts electrical (MWe) by the International Atomic Energy Agency (IAEA) and targeted for multipurpose applications, small modular reactors (SMRs) have been recognized as a very promising, clean, affordable, and sustainable energy source by many countries. At present, more than 80 SMRs are under design, development, demonstration, deployment, and beyond (4D+) phases worldwide. This paper focuses on the current world status of SMRs and focuses on the necessary developments to accelerate the process of adopting SMRs as a major energy source globally. SMRs are not a new concept, but they do represent a new vision for older concepts if the challenges inherent within them are mitigated with strategic and realistic solution approaches. The major challenges for SMRs 4D+ like any new reactors are: (a) qualifying the advanced fuel-to-reactor design; (b) supporting rapid scaled/prototypic experimentations; (c) maintaining local and global codes, standards, and licensing; (d) supply chain issues; (e) effective cradle-to-grave nuclear fuel cycle and fuel material transportation, and (f) mitigating financial and environmental risks. These upfront challenges can be mitigated with a synergistic solution approach among the various stakeholders: industry, academia, research, government, and international entities.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

SMR Current Status: Development Needs and Global Perspectives

Defined as nuclear reactors with a power output up to 300 megawatts electrical (MWe) by the International Atomic Energy Agency (IAEA) and targeted for multipurpose applications, small modular reactors (SMRs) have been recognized as a very promising, clean, affordable, and sustainable energy source by many countries. At present, more than 80 SMRs are under design, development, demonstration, deployment, and beyond (4D+) phases worldwide. This study focuses on the current world status of SMRs and focuses on the necessary developments to accelerate the process of adopting SMRs as a major energy source globally. SMRs are not a new concept, but they do represent a new vision for older concepts if the challenges inherent within them are mitigated with strategic and realistic solution approaches. The major challenges for SMRs 4D+ like any new reactors are: (a) qualifying the advanced fuel-to-reactor design; (b) supporting rapid scaled/prototypic experimentations; (c) maintaining local and global codes, standards, and licensing; (d) supply chain issues;(e) effective cradle-to-grave nuclear fuel cycle and fuel material transportation, and (f) mitigating financial and environmental risks. These upfront challenges can be mitigated with a synergistic solution approach among the various stakeholders: industry, academia, research, government, and international entities.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

Integrating Safety, Security, and Nuclear Operations for Advanced Reactors

The traditional separation between safety, security, and operations teams has created significant barriers to achieving optimal outcomes. When security considerations are introduced late in the design process, they often conflict with already-established architectural, operational, or engineering parameters. Retrofitting security measures can lead to increased costs, schedule delays, and compromises in security effectiveness. For instance, the need to retrofit physical barriers or surveillance systems often results in trade-offs that could have been avoided with earlier input from security professionals. Delayed integration can also affect regulatory processes and result in licensing delays. Security reviews conducted at later stages frequently identify gaps that necessitate significant redesign efforts, impacting not only scope, schedule, and budget, but also adding risk and lowering stakeholder confidence in the project. This paper aims to address these challenges by identifying practical opportunities for integrating security considerations seamlessly with design and operations teams throughout the entire lifecycle of nuclear facilities—from conceptual design to commissioning and beyond. The research emphasizes the value of early and continuous collaboration among stakeholders to ensure that security measures are robust, operationally effective, and cost-efficient. By examining case studies, analyzing past incidents, and leveraging best practices from other high-security industries, this study highlights actionable strategies for bridging the gap between safety, security, and operations teams.

Zineddin, Dr. Z. [ORNL] (ORCID:0009000848740725)↗

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

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

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Root Cause Correlation Analysis of Software Failures via Orthogonal Defect Classification and Natural Language Processing

Systems theoretic process analysis (STPA) is becoming an increasingly popular technique to assess how complex digital software systems can fail. Rather than defining failures by their observable failure events, which may be sparse especially for safety rated nuclear digital instrumentation and control systems (DI&C), failures are defined as postulated unsafe actions under specific contextual conditions. This permits a top-down analysis of system hazards and identifies whether imposed constraints and requirements can sufficiently address undesirable hazards. However, STPA is a qualitative approach at identifying inadequacies in the development process and cannot currently be used to quantify unsafe action likelihoods for probabilistic risk assessment. Therefore, in this work, we examine the root causes of software failure and explore whether a consistent correlation can be linked to specific unsafe action classes. We implement Lbl2Vec, an unsupervised document classification and retrieval algorithm, on a database of 4,096 software defect reports acquired from various open-source software systems. By analyzing sentence structure, embedded labels, and word vectors, we show that certain defect types positively correlate to specific unsafe action classes over others. The correlations developed can be used to estimate the failure probability of safety intended DI&C systems which provides a licensing basis for nuclear plant modernization efforts.

22 - GENERAL STUDIES OF NUCLEAR REACTORS↗

Nuclear Safety [Vol. 30, No. 3, July-September 1989]

Nuclear Safety is a review journal that covers significant developments in the field of nuclear safety. Its scope includes the analysis and control of hazards associated with nuclear energy, operations involving fissionable materials, and the products of nuclear fission and their effects on the environment. Primary emphasis is on safety in reactor design, construction, and operation; however, the safety aspects of the entire fuel cycle, including fuel fabrication, spent-fuel processing, nuclear waste disposal, handling of radioisotopes, and environmental effects of these operations, are also treated. Table of Contents for this issue follows. GENERAL SAFETY CONSIDERATIONS: 325 Safety of Framatome Advanced Nuclear Steam Supply Systems Designs by J. A. Charles and D. Lange, 333 Book Review of Nuclear Accidents: Intervention Levels for the Protection of the Public by H. B. Piper; ACCIDENT ANALYSIS: 335 Living PRA Computer Systems by S. C. Dinsmore and H.-P. Balfanz, 343 Summary of ICAP Assessments of RELAP5/MOD2 by W. E. Driskell and R. G. Hanson; CONTROL AND INSTRUMENTATION: 352 Thermal Performance Monitoring System at Maanshan Nuclear Power Plant by H.-J. Chao, Y.-P. Lin, G.-H. Jou, L.-Y. Liao, and Y.-B. Chen; DESIGN FEATURES: 358 Warning Systems for Nuclear Power Plant Emergencies by J. H. Sorensen and D. S. Mileti; WASTE AND SPENT FUEL MANAGEMENT: 371 Activities Related to Waste Management Compiled by E G. Silver; OPERATING EXPERIENCES: 382 Steam Generator Tube Performance: Experience with Water-Cooled Nuclear Power Reactors During 1985 by O. S. Tatone and R. L. Tapping, 400 Systems Interaction Analyses: Concepts and Techniques (Part II) by M. D. Muhlheim and G. A. Murphy, 413 Reactor Shutdown Experience Compiled by J. W. Cletcher, 416 Operating U.S. Power Reactors Compiled by E G. Silver; RECENT DEVELOPMENTS: 440 General Administrative Activities Compiled by E G. Silver, 460 Reports, Standards, and Safety Guides by D. S. Queener, 466 Status of Power-Reactor Licensing Activities Compiled by E G. Silver, 470 Proposed Rule Changes as of Mar. 31, 1989; ANNOUNCEMENTS: 334 Proceedings Published, 351 CEC Seminar on Methods and Codes for Assessing the Off-Site Consequences of Nuclear Accidents, 357 Short Course on Multiphase Flow and Heat Transfer: Bases and Applications in A: The Nuclear Power Industry B: The Process Industries, 357 International Conference on Probabilistic Safety Assessment and Management, 478 International Topical Meeting on the Safety, Status, and Future of Non-Commercial Reactors and Irradiation Facilities, 475 The Authors.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

ANDRA's Underground Research Laboratory in Bure: Major Role in the Cigeo Development - 20005

The Industrial Center for Geological Disposal, also called Cigeo, is the deep geological disposal facility project developed by Andra since 1991. It is intended for the final disposal of High-Level Waste (HLW) and Intermediate Level Waste-Long Lived (ILW-LL) generated in France by the nuclear industry. Cigeo is located in the east of France (Meuse/Haute-Marne site). The disposal will be implemented in a 140 to 160 m thick clay layer at about 500 m depth. The license application file will be submitted in 2020. If the license is granted, the construction of the pilot phase of Cigeo (ramp, shafts, drifts, initial disposal vaults) could start in 2025 at the earliest. Since 2000, the development of the safety case of Cigeo for post closure has been supported by a three-stage construction, design, and scientific and technological experiment program performed in the French Underground Research Laboratory (URL) in Bure. These stages of the URL activities supported the iterative interactions between the knowledge acquired by scientific and technological R and D program, the design process and the safety assessment. The stages focused on assessing the suitability of the disposal concept, providing the basis for safety options and construction design, and preparing for licensing using large scale demonstrations. Recently, Andra launched the fourth development stage of the URL to implement a new set of technological experiments aiming at consolidating the design options of disposal cells and galleries for the pilot phase of Cigeo and at assessing monitoring technologies. Recently, Andra launched the fourth development stage of the URL to implement a new set of technological experiments aiming at consolidating the design of the pilot phase of Cigeo and at assessing design options and monitoring technologies. Removal of a segment ring, construction of an X drift crossing, improved construction techniques for HLW vaults, and construction of an ILW-LL prototype disposal vault are example activities during the fourth phase. In the future, the URL in Bure will remain a unique location to carry out research on promising technical solutions, to reduce Cigeo's construction and operation risks and strengthen the long-term safety assessment. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

A Systematic Evidence Based Performance Approach to Regulation of Nuclear Sites in England and Wales - 20058

The Environment Agency for England has developed a systematic evidence-based approach to pursue our strategic environmental objectives for the regulation of nuclear sites. We use an annual evidence review process to ensure effective and efficient targeting of limited resources to achieve those objectives. Over the last 8 years, we have been developing and refining this approach to ensure risk-based and value driven regulation. The approach comprises nuclear site and nuclear sector review processes known as Site Environment Review (SER) and Nuclear Environment Review (NER). This approach complements our regulation of nuclear site permit holders under the Environmental Permitting Regulations (EPR). We deliver our regulation of nuclear sites in England and Wales alongside the Office for Nuclear Regulation. The SER process involves the lead regulator for each nuclear site assessing the permit holder's environmental performance across 14 themes, set within the context of the site's main activities and associated waste disposals. Our themes include environmental leadership, resources and climate change, radioactive waste management, facility management and decommissioning, groundwater, and environmental radiological protection. We use evidence from site inspections and working within our subject matter groups to grade current and predicted future environmental performance. We are particularly interested in sustainability and the application of Best Available Techniques (BAT) to prevent the creation, and minimise the disposal, of radioactive wastes. We use risk analysis (strengths, weaknesses, threats and opportunities) to examine performance against our strategic environmental objectives, which are set out, in our 5-year Nuclear Delivery Plan (NDP). The output supports the targeting of our resources at each nuclear site. We consult the relevant permit holders on the SER priorities and use their feedback to refine our plans. We expect all permit holders to take account of our priorities when considering their own programmes of work, objectives and plans. The NER process brings together what we learn and achieve through regulation across the sector. It provides input to planning priorities, supported by qualitative and semi-quantitative evidence. It covers the 28 nuclear sites in England and Wales and spans the same 14 environmental themes. During the process we collate, compile and summarise evidence from the SERs and other sources such as inspection reports and evidence from our other nuclear work programmes. The output is the NER annual report. This provides a snapshot of the status of the nuclear sector and gives insights to enable us to regulate more efficiently and effectively. It also takes account of cross-cutting issues and risks such as changes in international standards, domestic policy, regulatory framework, domestic standards and guidance, learning from experience such as incidents, events and good practice, and innovation, research and development. It provides graphics that illustrate the grading of environmental performance for the nuclear sector across the fourteen environmental themes. This analysis allows benchmarking of nuclear site's environmental performance and the visualisation provides a convenient comparison of performance across themes, sites, and over time. We use this intelligence to inform our investment in training and development of our staff, and our cross-cutting engagement on strategic issues with government, the Nuclear Decommissioning Authority (NDA) and other corporate organisations. Adopting this approach can provide benefits with organisational reputation, stakeholder participation and ensuring value from the public investment. This paper describes the history of the SER/NER process, a selection of outputs from the process and ideas for improvement. The paper will be of interest to other regulators and organisations across the world that are interested in supporting continuous improvement. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Computational Thermal Hydraulics of a High-Performance Low-Enriched-Uranium Annular Target for HFIR Irradiation

Molybdenum-99 has historically been generated via isolation from fissioned highly enriched uranium (HEU) targets. Here, this isotope is in high demand due to its daily use across the world in radiopharmaceutical medical procedures. The primary objective of this work was to design and analyze an experimental target assembly containing one low-enriched-uranium (LEU) annular target for irradiation at the High Flux Isotope Reactor (HFIR). Efforts included incorporating spatially dependent energy sources from neutron and gamma interactions, quantifying thermal contact conductance at material interfaces, performing grid-independent studies, comparing turbulence models, and simulating various steady-state and transient scenarios relevant for irradiation qualification and eventual insertion. These models provide velocity, pressure, and temperature distributions in both space and time. Such results enable the selection of an appropriate irradiation location, fission rate density, and flow-limiting orifice size and demonstrate compliance with HFIR safety requirements such that insertion into the reactor can be approved. This analysis shows that across all scenarios, wetted surface temperatures remain below the coolant saturation temperature with no net vapor formation in the coolant. In every scenario, all components stay below 30% of the aluminum 6061 melting temperature. Computational fluid dynamics and system-level models predict peak target temperatures that agree within 4%, though the predicted axial location of the peak differs by about 10% of the heated length due to differences in flow development length. These results de-risk the irradiation of LEU (annular targets) and strengthen a domestic, HEU-independent 99 Mo supply by providing important fuel performance data to form the foundation for a robust licensing basis.

Molybdenum-99↗