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At least 127 records · Page 7

One Man’s Pirate is Another Man’s . . . Nuclear Terrorist? Evaluating the Act of Piracy Against Floating Nuclear Power Plants on the High Seas

The lack of international consensus about whether a floating nuclear power plant is a facility or vessel presents an ambiguity about a pirate's status if they board a floating nuclear power plant, As piracy continues to be a concern for maritime security, the deployment of floating nuclear power plants (FNPPs) on the high seas raises questions about laws on piracy.

Fialkoff, Marc [Oak Ridge National Laboratory (ORN↗

A Multi-Criteria Impact Evaluation Methodology Applied to FLEX Strategies in Nuclear Power Plants

As responses to Fukushima Dai-ichi nuclear accident, several advanced, near-term technologies have been or are being introduced to enhance safety of operating nuclear power plants (NPPs) as well as improving their sustainability. Examples include Accident-Tolerant Fuel designs, Diverse and Flexible Coping Strategies (FLEX), and passive cooling system designs. The combinations of these technologies, coupled with enhancements to plant components and systems and improved fuel cycle efficiency, constitute a concept of Enhanced Resilient Plant Systems, which is proposed and being explored by Idaho National Laboratory (INL) under the Risk-Informed Systems Analysis Pathway of the U.S. Department of Energy’s Light Water Reactor Sustainability Program. To decide if introducing a technology is necessary or worthy, the impacts of this technology on NPPs should be evaluated, preferably in a quantitative manner, and provided to decision makers. This paper summarizes an on-going work conducted by the authors on developing a multi-criteria impact evaluation methodology. This methodology is expected to be applicable to evaluate a variety of technologies, while FLEX strategy is adopted as a case study for this paper.

99 GENERAL AND MISCELLANEOUS↗

Precursor Analysis Report: SQL Slammer Worm Infection of Davis-Besse Nuclear Power Plant 2003

The SQL Slammer Worm Infection of Davis-Besse Nuclear Power Plant 2003 Precursor Analysis Report leverages publicly available information about Davis-Besse’s 2003 cyber attack and catalogs anomalous observables for each technique employed in the attack. This analysis is based upon the methodology of the Cybersecurity for the Operational Technology Environment (CyOTE) program. On 25 January 2003, the SQL Slammer worm infected more than 90% of vulnerable hosts and crashed the internet in 10 to 15 minutes, making it one of the fastest spreading worms in history. SQL Slammer is a fileless, memory-resident worm that remotely exploits a stack-based buffer overflow vulnerability on local hosts to intensively scan and rapidly self-propagate across the internet. The worm infected approximately 300,000 unpatched hosts running Microsoft Structured Query Language (SQL) Server 2000 or Microsoft Desktop Engine (MSDE) 2000 with SQL Server Resolution Service. The SQL Slammer worm indirectly infected FirstEnergy’s Davis-Besse nuclear power plant by first infecting a consultant’s company network server and then propagating through an external misconfigured connection into Davis-Besse’s site network. The infection caused major network congestion, slow performance, data overloads, and the inability of local hosts to communicate with each other, which eventually caused a loss of availability and a loss of view when the Safety Parameter Display System (SPDS) and Plant Process Computer (PPC) crashed. At the time of the infection, the plant was already offline, the digital monitoring systems had redundant analog backups, and the plant control and safety functions were not affected, so there were no concerns of a safety breach. However, this incident resulted in many lessons learned and spawned important discussions about cybersecurity’s role in nuclear safety and electric power reliability regulation, policy, and guidance. Researchers and analysts identified 10 unique techniques utilized during the attack with a total of 640 observables using MITRE ATT&CK® for Industrial Control Systems. The CyOTE program assesses observables accompanying techniques used prior to the triggering event to identify opportunities to detect malicious activity. If observables accompanying the attack techniques are perceived and investigated prior to the triggering event, earlier comprehension of malicious activity can take place. Eight of the identified techniques used during Davis-Besse cyber attack were precursors to the triggering event. Analysis identified 596 observables associated with these precursor techniques, 428 of which were assessed to have an increased likelihood of being perceived in the 331 days preceding the triggering event. The response and comprehension time could have been reduced if the observables had been identified earlier. The information gathered in this report contributes to a library of observables tied to a repository of artifacts, data sources, and technique detection references for practitioners and developers to support the comprehension of indicators of attack. Asset owners and operators can use these products if they experience similar observables or to prepare for comparable scenarios.

45 MILITARY TECHNOLOGY, WEAPONRY, AND NATIONAL DEF↗

Automated Waterbox Inspection for Nuclear Power Plants Using Computer Vision - Based Change Detection

Nuclear power plant waterboxes require regular inspection for leaks, missing components, and structural damage during maintenance outages. Traditional manual inspection is time-consuming and poses safety risks from confined space entry. We developed an automated computer vision system for drone-based waterbox inspection in partnership with Florida Light and Power. Our approach uses feature detection and matching to identify critical changes between baseline and current inspection images, automatically flagging additions (leaks/debris), removals (missing plugs), and translations (displaced components) while compensating for drone movement and environmental variations. We systematically evaluated six feature matching methods, from classical approaches (SIFT+BF) to state-of-the-art neural networks (SuperPoint+SuperGlue), using both standard benchmarks (HPatches) and waterbox-specific validation with real-world augmentations. SuperPoint+SuperGlue achieved superior performance with 7.82 pixels RMSE and 100% success rate—2.8x better accuracy than our baseline. While the pre-trained model has commercial licensing restrictions for nuclear deployment, our findings validate this architecture for custom training. We implemented a real-time GUI demonstrating the SIFT+BF approach for immediate deployment, processing drone feeds at 30 FPS with color-coded change visualization. Future work includes training a custom SuperPoint+SuperGlue model on waterbox data and integrating Vision-Language Models for automated reporting and maintenance guidance.

46 - INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AN↗

Developing an AI-Powered Zero-Trust Cybersecurity Framework for Malware Prevention in Nuclear Power Plants

This study presents the development of an AI-powered Zero-Trust cybersecurity framework for malware prevention in nuclear power plants. The framework aims to enhance the security of critical systems within nuclear power plants by adopting the principles of Zero-Trust and leveraging artificial intelligence (AI) technologies. By assuming no implicit trust in any user or device and continuously authenticating and authorizing access, the framework ensures a robust defense against malware attacks. The integration of AI allows for the detection and prevention of malware through behavioral analytics, endpoint protection, network segmentation, and continuous monitoring. The paper discusses the key considerations, steps, and technologies involved in developing this framework, emphasizing the importance of regular updates, training, compliance, and auditing. The proposed framework serves as a comprehensive approach to safeguarding nuclear power plants from sophisticated malware threats and protecting the integrity and safety of critical infrastructure.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

Evaluation of ASCE 4-16 and AISC 43-18 (Draft) for use in the Risk-Informed Performance-Based Seismic Design of Nuclear Power Plant Structures, Systems, and Components

This report describes the assessment of ASCE Standards 4-16 and 43-18 (Draft) for use in the Risk-Informed Performance-Based (RIPB) seismic design of structures, systems, and components (SSCs) at nuclear power plants. This work was performed for the U.S. Nuclear Regulatory Commission (NRC) Office of Regulatory Research (RES), to support potential endorsement of these industry standards for the design of nuclear power plants based on the RIPB approach. Currently, the NRC endorses a deterministic design approach for demonstrating the design adequacy of SSCs based on the Standard Review Plan (NUREG-0800) and NRC Regulatory Guides. In the RIPB approach, the design criteria are developed to achieve a target performance goal, which is defined by the annual frequency of occurrence of the design basis earthquake (i.e., Seismic Design Category) and the acceptable level of structural performance (i.e., Limit State) for the SSCs. ASCE 4-16 provides methods for performing a seismic analysis of structures to obtain the seismic response of these structures (e.g., building displacements, accelerations, in-structure response spectra) which are used in the design of the SSCs. It also provides methods for performing seismic analysis of SSCs to determine the seismic demands (e.g. member forces and displacements) needed to design individual SSCs. ASCE 43-18 (Draft) provides the criteria for the seismic design of SSCs using the seismic demands developed in ASCE 4-16. The use of ASCE Standard 43-18 (Draft), along with ASCE 4-16, provides the criteria for the seismic design of the SSCs. ASCE 43-18 (DRAFT) relies on other consensus codes and standards such as ACI 349 for reinforced concrete, AISC/N690 for steel structures, ASME Section III for pressure-retaining mechanical components and Containments, and IEEE-344 for Class 1E equipment. The goal of this technical review was to assess the adequacy of the provisions in these standards for use by the NRC in developing regulatory guidance for design of SSCs in nuclear power plants, based on the RIPB approach. The research reported herein describes the basis for acceptance of the new standards and identifies areas where additional staff guidance is needed for the seismic design of SSCs at nuclear power plants. This technical review has determined that ASCE 4-16 and ASCE 43-18 (Draft) provide an appropriate framework for the seismic design of SSCs at nuclear power plants using a Risk-Informed Performance-Based approach. However, some of the criteria therein warrant exceptions, qualifications, and/or clarifications.

42 ENGINEERING↗

Potential of deep learning methods to enhance satellite-based monitoring of nuclear power plants focusing on remote operation evaluations

The anticipated expansion of the nuclear industry and the deployment of new nuclear reactors (200 + GW of new nuclear capacity by 2050) require the development of monitoring systems that align with safety and security concerns, providing enhanced evaluation capabilities. A remote monitoring system using satellites and deep learning techniques was evaluated for its ability to detect anomalies and capture various features of nuclear reactors independently of the conditions on the ground. Satellite images of current operational and under-construction nuclear power plants were collected from Google Earth Pro as a surrogate database. Subsequently, five datasets were created from the collected images. Transfer learning technique was used for several classification tasks utilizing VGG16, ResNet50V2, Xception, DenseNet121, and MobileNetV2 pre-trained models. In the first task, the capability of the monitoring system to detect abnormal conditions or processes in a nuclear power plant was investigated. In the second task, the ability to capture operational features remotely was examined. As an example, for the purposes of this study, these features included classifying reactors based on type, power range, or onsite condition. Several evaluation metrics were used to compare the performance of the pre-trained models and the overall monitoring system. Here, the evaluation results demonstrated that deep learning techniques and pre-trained models applied to satellite images have the potential to facilitate further and expand capabilities in monitoring systems to assess plant operation details.

22 - GENERAL STUDIES OF NUCLEAR REACTORS↗

Considerations regarding the Use of Computer Vision Machine Learning in Safety-Related or Risk-Significant Applications in Nuclear Power Plants

With the advancements made to date in the field of artificial intelligence (AI), significant potential exists to utilize AI capabilities for nuclear power plant (NPP) applications. AI can replicate human decision making and it is usually faster and more accurate than humans. For implementations that impact critical NPP applications (e.g., safety-related or non-safety systems that potentially affect overall plant risk), a deeper safety analysis of the AI methods is necessary. AI applied to NPP operations could resemble the use of digital I&C (DI&C) because such applications involve digital computer hardware and custom-designed software that input plant data, execute complex software algorithms, and output the results to a system or licensed human operator to potentially provoke an action. For AI methods to be compliant with current safety requirements for DI&C, AI compatibility must be evaluated, and AI-related gaps may exist that prevent the prompt deployment of AI in NPPs. This effort aims to evaluate how example AI technologies align with the DI&C safety framework, and discusses how they could be analyzed, modeled, tested, and validated in a manner similar to typical DI&C technologies. Because AI is a broad field that encompasses areas such as machine learning (ML), natural language processing, and computer vision, this research focused on a subset of methods categorized as the computer vision ML (CVML) methods. This report explores two CVML use cases, gauge reading and fire watch, considered relevant to the DI&C standards, as they could play a safety-critical role. For the gauge reading use case, a CVML-enabled technology that can read gauges at oblique angles is utilized. For the fire watch use case, a CVML-enabled technology is utilized that migrates fire watch from a manual (human) approach to automated fire detection. These use cases are mainly intended to give context to the CVML system discussion. This effort assumes the worst-case scenario, with the CVML system being used to replace a safety-related or risk-significant system, thus requiring evaluation. Evaluating CVML against most of the relevant safety requirements for DI&C yielded several CVML-specific considerations due to the uniqueness of its characteristics in comparison with typical DI&C systems. For example, CVML models often employ commonly used (open-source) datasets, and it is not always possible to determine the level of overlap among open-source datasets. Therefore, the independence of the developed CVML models when demonstrating diversity is questionable, therefore creating vulnerability to common cause failure (CCF). The design verification process is also impacted since the data overlap could result in overestimation of the software validation and verification (V&V) performance results. Section 2 of this report evaluates a list of the identified CVML-specific characteristics and discusses the resulting considerations and potential solutions in the context of each referenced requirement. A summation is provided in Section 3. This report is not to be used as a guideline. It was developed to identify and consider issues in the implementation of ML technologies used to augment activities that may have a bearing on plant operation. The report draws parallels to the use of DI&C technologies, for which many standards are available to guide their use in nuclear plant operation. It considers the technologies and some of the potential implications of their use in safety-related applications but is not intended to address regulatory or licensing related issues.

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

Dynamic Instructions for Nuclear Power Plant Field Workers

Most tasks conducted at a nuclear power plant are guided by a procedure in one way or another. Some tasks must be conducted by strictly adhering to the prescribed steps, while other tasks use the procedures as a reference guide. Traditionally, the procedure process in the nuclear industry has been paper heavy. In recent years however, the nuclear industry has considered adopting more dynamic solutions to improve the efficiency of their work management process, advance human and system performance, as well as reduce the cost of handling paper copies of documentation. As a first step, many nuclear utilities in the U.S. deployed solutions that electronically route the documents through the review and approval processes and where the worker in the field uses an electronic copy of the instruction or procedure on a handheld device. These electronic copies are very similar to the format of the paper instruction but do have some additional capabilities to capture recorded input and notes.

47 OTHER INSTRUMENTATION↗

Nuclear Power Plant Physical Protection Recommendation Document

This document is aimed at providing guidance to the National Nuclear Security Administration’s (NNSA) Office of International Nuclear Security’s (INS) country and regional teams for implementing effective physical protection systems (PPSs) for nuclear power plants (NPPs) to prevent the radiological consequences of sabotage. This recommendation document includes input from the Physical Protection Functional Team (PPFT), the Response Functional Team (RFT), and the Sabotage Functional Team (SFT) under INS. Specifically, this document provides insights into increasing and sustaining physical protection capabilities at INS partner countries’ NPP sites. Nuclear power plants should consider that the intent of this document is to provide a historical context as well as technologies and methodologies that may be applied to improve physical protection capabilities. It also refers to relevant guidance from the International Atomic Energy Agency (IAEA) and the U.S. Nuclear Regulatory Commission (NRC).

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

Investigating Application of LiDAR for Nuclear Power Plants

Many evaluation, assessment, and modeling tasks at nuclear power plants require spatial in-formation; this often requires physical visits to locations within the facility because the 2D or 3D schematics and current models do not contain enough detail or do not capture as-built and real-world conditions. These visits require extensive manual labor for not only the requesting party, but also support groups, such as security. Light Detection and Ranging (LiDAR) mapping is trying to solve that problem by providing very detailed 3D models for low costs. However, the use of these models can be very limited because either component reference information is missing and too costly to add or there is no way to extract specific spatial data needed for other tools. This report outlines two main efforts. First, to reduce the effort of “Tagging” data in large 3D models, a general Application Programming Interface (API) was developed to import a variety of existing plant database information into a 3D-visualization engine. Filters allow the user to have only zone-specific items listed; then, they can simply click and assign the information to a specific spot or component in the 3D model. The second part of the work is the development of an interface for importing pieces from the3D-LiDAR model into other systems needed for modeling and simulation, outlined around fire modeling. This interface allows for the retrieval of item location and boundaries, enabling the auto generation of models for varying tools.

3D Modelling↗

A Dynamic Risk Framework for the Physical Security of Nuclear Power Plants

This paper describes ongoing work within the Light Water Reactor Sustainability pathway at Idaho National Laboratory (INL) to optimize the security and cost of nuclear power plants. It introduces the dynamic risk assessment tool developed at INL, Event Modeling Risk Assessment using Linked Diagrams (EMRALD). EMRALD is leveraged to optimize the security posture of a nuclear power plant by integrating force-on-force (FOF) simulations and operator mitigation actions, including dynamic and flexible coping strategies (FLEX). To illustrate the methodology, four attack scenarios are modeled in a commercially available FOF simulation tool using a hypothetical nuclear power plant facility. The simulation results provide valuable insights into possible attack outcomes, as well as the probabilistic risk of a core damage event given these outcomes. Safety mitigation procedures are modeled in EMRALD dependent on the attack outcomes by considering human operator uncertainties. The results demonstrate that the number of armed responders can be optimized, while still maintaining the same protection level as the initial security posture. The proposed modeling and simulation framework of integrating FLEX equipment with FOF models enables the nuclear power plants to credit FLEX portable equipment in the plant security posture, resulting in an efficient and optimized physical security system.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

A Dynamic Risk Framework for the Optimization of Physical Security Posture of Nuclear Power Plants

This paper describes an ongoing work within the Light Water Reactor Sustainability pathway at Idaho National Laboratory (INL) to optimize security and cost of nuclear power plants. It introduces the dynamic risk assessment tool developed at INL, Event Modeling Risk Assessment using Linked Diagrams (EMRALD). EMRALD was leveraged to optimize the security posture of a nuclear power plant by integrating force-on-force (FOF) simulations and operator mitigation actions including the dynamic and flexible coping strategies (FLEX). To illustrate the methodology, four attack scenarios were modeled in a commercially available FOF simulation tool using a hypothetical nuclear power plant facility. The simulation results provide valuable insights into possible attack outcomes, as well as the probabilistic risk of core damage event given these outcomes. Safety mitigation procedures were modeled in EMRALD dependent on the attack outcomes by considering human operator uncertainties. The results demonstrate that the number of armed responders can be optimized, while still maintaining the same protection level as the initial security posture. The proposed modeling and simulation framework of integrating FLEX equipment with FOF models enables the nuclear power plants to credit FLEX portable equipment in the plant security posture, resulting in an efficient and optimized physical security system.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Mid–height seismic isolation of equipment in nuclear power plants

An innovative seismic isolation solution for designers of safety-class equipment in advanced nuclear power plants is introduced. The test specimen was a tall, slender, carbon steel vessel that could represent a reactor vessel, steam generator, or a heat exchanger in a nuclear power plant: 240 inches tall, outer diameter of 60 inches, and wall thickness of 1 inch. The vessel was supported by three radial mounts at its mid-height, near its center of gravity, on a steel frame. The vessel was subjected to three-component ground motions using a 6DOF earthquake simulator. The specimen was filled with water for testing to indirectly account for the fluid and internal equipment present inside a prototype vessel. Three configurations were tested: non-isolated, isolated using single Friction Pendulum (SFP) bearings, and isolated using triple Friction Pendulum (TFP) bearings. The test results demonstrate that mid-height seismic isolation is practical and enables a significant reduction in horizontal spectral accelerations. Furthermore, these outcomes are not specific to the spherical sliding bearings used in the experiments but are broadly applicable to mid-height, seismically isolated equipment.

42 ENGINEERING↗

Optimizing long-term monitoring of radiation air-dose rates after the Fukushima Daiichi Nuclear Power Plant

Radiation air dose rates near the Fukushima Daiichi Nuclear Power Plant (FDNPP) have been steadily decreasing over the past eight years since the release of radioactive elements in March 2011. Currently, the radiation monitoring program is expected to transition to long-term monitoring after most of the remediation activities are completed. The main long-term monitoring objectives are to (1) confirm the continuing reduction of contaminant and hazard levels, (2) provide assurance for the public, (3) accumulate the basic datasets for scientific knowledge and future preparation, and (4) detect changes or anomalies in contaminant mobility (if they occur), or any unexpected processes or events. In this work, we have developed a methodology for optimizing the monitoring locations of radiation air dose-rate monitoring. Our approach consists of three steps in order to determine monitoring locations in a systematic manner: (1) prioritizing the critical locations, such as schools or regulatory requirement locations, (2) diversifying locations that cover the key environmental controls that are known to influence contaminant mobility and distributions, and (3) capturing the heterogeneity of radiation air-dose rates across the domain. Therefore, for the second step, we use a Gaussian mixture model to identify the representative locations among multiple environmental variables, such as elevation and land-cover types. For the third step, we use a Gaussian process model to capture and estimate the heterogeneity of air-dose rates across the domain. Employing an integrated dose-rate map derived from Bayesian geostatistical methods as a reference map, we distribute the monitoring locations in such a way as to capture the heterogeneity of the reference map. Our results have shown that this approach allows us to select monitoring locations in a systematic manner such that the heterogeneity of air dose rates is captured by the minimal number of monitoring locations.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

Quantitative evaluation of common cause failures in high safety-significant safety-related digital instrumentation and control systems in nuclear power plants

Digital instrumentation and control (DI&C) systems at nuclear power plants (NPPs) have many advantages over analog systems. They are proven to be more reliable, cheaper, and easier to maintain given obsolescence of analog components. However, they also pose new engineering and technical challenges, such as possibility of common cause failures (CCFs) unique to digital systems. Here this paper proposes a Platform for Risk Assessment of DI&C (PRADIC) that is developed by Idaho National Laboratory (INL). A methodology for evaluation of software CCFs in high safety-significant safety-related DI&C systems of NPPs was developed as part of the framework. The framework integrates three stages of a typical risk assessment—qualitative hazard analysis and quantitative reliability and consequence analyses. The quantified risks compared with respective acceptance criteria provide valuable insights for system architecture alternatives allowing design optimization in terms of risk reduction and cost savings. A comprehensive case study performed to demonstrate the framework's capabilities is documented here in this paper. Results show that the PRADIC is a powerful tool capable to identify potential digital-based CCFs, estimate their probabilities, and evaluate their impacts on system and plant safety.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Plan for the Development and Application of a Risk Assessment Approach for Transportation Package Approval of a Transportable Nuclear Power Plant for Maritime Shipment (Rev. 1)

This plan proposes a strategy for licensing a transportable nuclear power plant, containing its unirradiated and irradiated fuel, as a transportation package for maritime transport using a probabilistic risk assessment framework in order to meet the regulatory requirements of 10 CFR Part 71. It is anticipated that initially, the deterministic transportation package licensing approach will be challenging due to the functional requirements of the transportable nuclear power plant. As such, a partial exemption request from the U.S. Nuclear Regulatory Commission coupled with applied compensatory measures are anticipated in support of providing equivalent safety to the public, worker, and environment. A plan is outlined as to how this would be demonstrated and a pathway is primarily outlined using the accompanying low accident rates which in turn support very low probabilities of release for a maritime application. Wherever possible, the proposed plan is supported by actual accident (casualty) data. Additional supporting information regarding a highway transportation probabilistic risk assessment in support of the Project Pele demonstration reactor that is currently under development is also referenced and discussed.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Evaluation of the Specification for Safety-Related Steel Structures for Nuclear Facilities, ANSI/AISC N690-18, for Application to Nuclear Power Plants

This report describes the assessment of the recently published ANSI/AISC N690-18, Specification for Safety-Related Steel Structures for Nuclear Facilities. This work was performed for the U.S. Nuclear Regulatory Commission for potential endorsement of N690-18 for use in the design of nuclear power plants. Currently the NRC endorses the use of an earlier version: N690-1994 (R2004), and thus, a technical review of the updated N690 Specification, which contains significant changes, is warranted. The N690-18 Specification reflects advances and improvements in steel design gained from experience, analytical studies, and experimental data over the years. The N690-18 specification also contains a new Appendix N9 that addresses the design of safety-related steel-plate composite (SC) walls which are a relatively new type of structural member for which previously there has not been any U.S. code or standard that governs its design. The technical review of N690-18 was performed in order to assess the adequacy of the provisions for use by the NRC in updating its regulatory guidance for nuclear power plants. The research developed the technical basis for acceptance of the new specification and also identified areas where additional staff guidance is needed for the design of safety-related steel structures at nuclear power plants. The results of the research have determined that the N690-18 specification is a significant enhancement from the N690-1994 (R2004) edition. The new specification contains substantial upgrades in the design of structural steel and includes new provisions for design of SC wall sections, which can benefit the nuclear power industry as well as the NRC review process. All of the improvements, if endorsed by the NRC with certain regulatory positions, will allow clearer and more consistent regulatory guidance, and will avoid the need for justification by licensees and related reviews each time certain methods or approaches are used.

42 ENGINEERING↗