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NRC Reactor Operating Experience Analysis and Trend Summary: 2022 Update

This report presents a summary of the Nuclear Regulatory Commission (NRC) reactor operating experience analyses with data through 2022 as well as the reliability and frequency trends identified in the 2022 update reports for component performance study, loss of offsite power analysis, initiating events analysis, and system study provided on the NRC Reactor Operating Experience Results and Databases website (https://nrcoe.inl.gov/).

99 GENERAL AND MISCELLANEOUS↗

NRC Reactor Operating Experience Analysis and Trend Summary: 2024 Update

This report presents a summary of the Nuclear Regulatory Commission’s (NRC’s) reactor operating experience analyses with data through 2024 as well as the reliability and frequency trends identified in the 2024 update reports for the component performance studies, loss-of-offsite power analysis, initiating events analysis, and system studies provided on the NRC Reactor Operating Experience Results and Databases website (https://nrcoe.inl.gov/).

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

NRC Reactor Operating Experience Analysis and Trend Summary: 2020 Update

This report presents a summary of the reliability and frequency trends identified in the 2020 update reports for component performance study, loss of offsite power analysis, initiating events analysis, and system study provided on the Nuclear Regulatory Commission (NRC) Reactor Operating Experience Results and Databases web site (https://nrcoe.inl.gov/).

99 GENERAL AND MISCELLANEOUS↗

Modular High Temperature Gas-Cooled Reactor: Licensing Part III

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

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Nuclear Safety [Vol. 35, No. 1, January-June 1994]

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. THE CHERNOBYL ACCIDENT: 1 Chernobyl Accident Management Actions, A. R Sich; GENERAL SAFETY CONSIDERATIONS: 25 The IAEA-ASSET Approach to Avoiding Accidents is to Recognize the Precursors to Prevent Incidents, F. Reisch; ACCIDENT ANALYSIS: 36 A Review of the Available Information on the Triggering Stage of a Steam Explosion, D. F. Fletcher; 58 Analysis and Modeling of Flow-Blockage-Induced Steam Explosion Events in the High-Flux Isotope Reactor, R. P. Taleyarkhan, V. Georgevich, C. W. Nestor, U. Gat, B. L. Lepard, D. H. Cook, J. Freels, S. J. Chang, C. Luttrell, R. C. Gwaltney, and J. Kirkpatrick; 74 An Analysis of Disassembling the Radial Reflector of a Thermionic Space Nuclear Reactor Power System, M. S. El-Genk and D. V. Paramonov; CONTROL AND INSTRUMENTATION: 86 Standards for High-Integrity Software, D. R. Wallace, D. R. Kuhn, L M. Ippolito, and L. Beltracchi; DESIGN FEATURES: 98 Adoption of New Design Features for the Next Generation Nuclear Power Reactors, L. S. Tong; 114 Review of Nuclear Piping Seismic Design Requirements, G. C. Slagis and S. E. Moore; ENVIRONMENTAL EFFECTS: 128 PC-Based Probabilistic Safety Assessment Study for a Geological Waste Repository Placed in a Bedded Salt Formation, S. A. Khan; OPERATING EXPERIENCES: 142 Managing Aging in Nuclear Power Plants: Insights from NRC’s Maintenance Team Inspection Reports, A. Fresco and M. Subudhi; 150 Reactor Shutdown Experience, Compiled by J. W. Cletcher; 153 Selected Safety-Related Events, Compiled by G. A. Murphy; RECENT DEVELOPMENTS: 158 Reports, Standards, and Safety Guides, D. S. Queener; 168 Proposed Rule Changes as of Dec. 31, 1993; ANNOUNCEMENTS: 177 Symposium on Radioactive and Mixed Waste—Risk as a Basis for Waste Classification; 177 1995 Incineration Conference 178 Ninth Power Plant Dynamics Control and Testing Symposium; 174 The Authors

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Nuclear Safety [Vol. 35, No. 1, January-June 1994]

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: THE CHERNOBYL ACCIDENT: 1 Chernobyl Accident Management Actions, A. R Sich 25 The IAEA-ASSET Approach to Avoiding Accidents is to Recognize the Precursors to Prevent Incidents, F. Reisch; ACCIDENT ANALYSIS: 36 A Review of the Available Information on the Triggering Stage of a Steam Explosion, D. F. Fletcher; 58 Analysis and Modeling of Flow-Blockage-Induced Steam Explosion Events in the High-Flux Isotope Reactor, R. P. Taleyarkhan, V. Georgevich, C. W. Nestor, U. Gat, B. L. Lepard, D. H. Cook, J. Freels, S. J. Chang, C. Luttrell, R. C. Gwaltney, and J. Kirkpatrick; 74 An Analysis of Disassembling the Radial Reflector of a Thermionic Space Nuclear Reactor Power System, M. S. El-Genk and D. V. Paramonov; CONTROL AND INSTRUMENTATION: 86 Standards for High-Integrity Software, D. R. Wallace, D. R. Kuhn, L M. Ippolito, and L. Beltracchi; DESIGN FEATURES: 98 Adoption of New Design Features for the Next Generation Nuclear Power Reactors, L. S. Tong; 114 Review of Nuclear Piping Seismic Design Requirements, G. C. Slagis and S. E. Moore; ENVIRONMENTAL EFFECTS: 128 PC-Based Probabilistic Safety Assessment Study for a Geological Waste Repository Placed in a Bedded Salt Formation, S. A. Khan; OPERATING EXPERIENCES: 142 Managing Aging in Nuclear Power Plants: Insights from NRC’s Maintenance Team Inspection Reports, A. Fresco and M. Subudhi; 150 Reactor Shutdown Experience, Compiled by J. W. Cletcher; 153 Selected Safety-Related Events, Compiled by G. A. Murphy; RECENT DEVELOPMENTS: 158 Reports, Standards, and Safety Guides, D. S. Queener; 168 Proposed Rule Changes as of Dec. 31, 1993; ANNOUNCEMENTS: 177 Symposium on Radioactive and Mixed Waste—Risk as a Basis for Waste Classification; 177 1995 Incineration Conference 178 Ninth Power Plant Dynamics Control and Testing Symposium; 174 The Authors

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Time at Temperature Experiments on Neutron Irradiated Zircaloy-2 using Conventional & Flash DSC

Dryout events in Boiling Water Reactors (BWRs) are currently treated by NRC regulations as automatic disqualification for continued fuel rod operation, even though this criterion does not account for the rate or duration of power increases, associated changes in material behavior, or the possibility of rewetting. Operational history from Anticipated Operational Occurrences (AOOs) shows that short, transient power excursions often demand only modest heat removal, and industry experience suggests that fuel can briefly enter dryout yet return to safe, stable operation. The lack of detailed understanding of the material response during such events motivates the present series of experiments. This study uses unique and innovative methods to investigate microstructural evolution in irradiated Zircaloy-2 exposed to high temperatures in inert environments. Differential Scanning Calorimetry (DSC) and FlashDSC are combined to build a comprehensive experimental framework capable of identifying the a–ß phase transformation in zirconium and examining defect annealing under steep thermal gradients. FlashDSC enables rapid heating and cooling of Focused Ion Beam (FIB)–prepared large-area lift-outs (LALOs) of irradiated Zircaloy-2 at rates of 1,000 K/s to peak temperatures of 600°C, 750°C, and 900°C. The goal is to determine whether these conditions produce measurable microstructural changes that could influence cladding performance in typical BWR environments. Microstructural characterization includes quantifying dislocation density and assessing secondary phase particle (SPP) size and distribution using Transmission Electron Microscopy (TEM). Ongoing analysis, such as diffraction pattern indexing and 4D STEM processing, will further refine these observations.

36 - MATERIALS SCIENCE↗

Assessment of Technical Information Needs and Considerations for Front-End Activities for Molten Salt Fuel Types

This report details an assessment of the hazards and safety impacts related to front-end operations of molten salt reactors (MSR) as well as an assessment of existing safety guidance. Publicly available information was evaluated to make recommendations to the U.S. Nuclear Regulatory Commission (NRC) for guidance development and information gathering needs. Five different MSR technologies were evaluated along with information from 1960’s about the Atomic Energy Commission programs for the Aircraft Reactor Experiment and Molten Salt Reactor Experiment. Primary areas of evaluation include fuel cycle facilities, transportation and at reactor fuel mixing operations up to reactor startup. In general, there was difficulty synthesizing publicly available information due to the early stage of the MSR development and proprietary information associated with the reactor technology companies analyzed. There are a few specific recommendations from this report. One overarching paradigm shift that the NRC needs to evaluate is the possibility of collocating fuel cycle facilities with operating MSRs. Although there is no specific prohibition to this in the NRC regulations, the collocation of the fuel cycle facilities with the operating MSR presents a novel approach compared to the light water reactor baseline. More guidance and research into thorium operations and regulation is needed. The hazards associated with the stability of stored fuel constituents need to be evaluated. Some reactor fuel cycles use beryllium, and its use and the associated hazards need further analysis. NRC-approved designs for transportation packages for shipping molten salt fuels and factory-built and fueled reactors are not available.

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Degradation and Failure Phenomena of Advanced Reactor Fuel Concepts: Sodium-Cooled Fast Reactor Metallic Fuel

The U.S. Nuclear Regulatory Commission (NRC) is anticipating licensing applications and commercial use of new fuel types in advanced nuclear power reactors that would be designed and built in the United States. Pacific Northwest National Laboratory (PNNL) is providing technical assistance to the NRC related to the newly proposed nuclear fuel and cladding designs that would be deployed in these reactors. This report focuses specifically on the metallic fuel that is being considered for sodium-cooled fast reactors and specifically on mechanisms that would cause damage or failure to the fuel under reactor operating conditions and design basis accident conditions. There is historic experience with both metallic and oxide fuels in experimental sodium-cooled fast reactors, but this report will focus solely on metallic fuel. Currently two U.S.-based reactor designers are engaged with the NRC in the application or pre-application review and considering a sodium-cooled fast reactor. TerraPower is engaged with NRC in pre-application review of its Natrium reactor. The current design for this fuel uses a sodium-bonded uranium-10wt% zirconium (U10Zr) fuel clad in HT9 stainless steel. ARC Clean Technology is engaged with NRC in pre-application review of its ARC-100 reactor. The current design for this fuel uses a sodium-bonded uranium-10wt% zirconium (U10Zr) fuel with steel cladding. This report will focus on this fuel system specifically, with broader information given regarding other metallic fuel systems with other stainless steel alloy claddings. To support the NRC’s readiness efforts, this report will identify and discuss degradation and failure modes of metallic fuel concepts for sodium-cooled fast reactors, including fuel performance characteristics that may not be addressed within existing regulatory documents.

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Challenge of Fielding Experiments at the Annular Core Research Reactor

Conference is the annual Test, Research &Training Reactors (TRTR) meeting. Typically attended by dozens of research reactor operators, educators, trainers, maintenance & service contractors Also, members of the Nuclear Regulatory Commission (NRC) attend. Presentation highlights ACRRs capability and the process used to submit and approve experimental activities. This presentation is adapted from my previous presentation to the Material Test and Research conference, SAND2025-1775526.

Martin, Lonnie E. [Sandia National Laboratories (S↗

Reassessing Double-Ended Guillotine Break Requirements: Evidence-Based Analysis of Regulatory Assumptions After Five Decades of Nuclear Operation

After five decades of nuclear power operation encompassing more than 20,000 reactor-years across 35 countries and 647 reactors, zero double-ended guillotine breaks (DEGBs) have been documented in commercial reactor coolant systems—despite DEGB being the fundamental design-basis assumption driving Emergency Core Cooling System (ECCS) sizing, structural protection requirements, and containment design specifications. This report examines the basis for DEGB requirements in nuclear power plant design. The DEGB postulate assumes the instantaneous, complete circumferential severance of the largest diameter pipes in reactor coolant systems, driving major design requirements under 10 Code of Federal Regulations 50.46, General Design Criterion 4 and containment design specifications. The United States (4,880 reactor-years) and France (2,505 reactor-years) contribute the largest operational datasets. Probabilistic assessments estimate direct DEGB occurrence probabilities with extremely low event frequencies, far below the 10-5/reactor-year thresholds typically used to define non-credible events in nuclear-safety analyses; i.e., events with probability this low fall into beyond-design-basis events. Current material-science knowledge demonstrates that the ductile steel materials used in nuclear piping systems exhibit stable crack-growth behavior fundamentally incompatible with instantaneous severance. International regulatory experience, particularly Germany’s comprehensive break-preclusion implementation, and successful leak-before-break (LBB) applications in almost all of U.S. pressurized water reactor units validate that alternatives can maintain safety performance while reducing economic burden. Current DEGB protection systems impose estimated lifetime costs of hundreds of millions of dollars per unit, over the life of a plant across the nuclear industry (including ongoing costs), representing substantial resource allocation toward scenarios with extremely low probability. Although this report acknowledges uncertainties regarding long-term aging effects, potential synergistic degradation mechanisms, and site-specific seismic considerations that warrant continued evaluation as regulatory policy evolves, there remains no documented evidence that a DEGB has occurred as a consequence of the conditions or mechanisms described in this report. This report acknowledges the Nuclear Regulatory Commission’s (NRC’s) recent efforts—outlined in the draft Interim Staff Guidance (ISG) NRC-DSS-ISG-2025-XX (“Treatment of Certain Loss-of-Coolant Accident Locations as Beyond-Design-Basis Accidents Draft Interim Staff Guidance”)—to reduce overly conservative requirements for large-break loss of coolant accidents through technical justifications and exemptions. However, extensive operating experience and validated methodologies—such as LBB and in-service inspection programs—demonstrate that the probability of a DEGB in reactor coolant-loop piping is extremely low, even under seismic conditions. The authors and reviewers of this report recommend that DEGB be removed as a design-basis event through formal rulemaking, rather than case-by-case exemptions, to better reflect credible failure modes, align with current data, and align with modern, risk-informed safety analysis.

22 - GENERAL STUDIES OF NUCLEAR REACTORS↗

Transport Modeling of As-Run ATR Cycles to Support U-10Mo Research Reactor Fuel Qualification Experiment

The Department of Energy’s (DOE) Office of Materials Management and Minimization has been tasked with converting the five remaining United States High Performance Research Reactors (U.S. HPRR) from highly enriched uranium to low-enriched uranium. The Nuclear Regulatory Commission (NRC) regulates Massachusetts Institute of Technology Reactor (MITR), Missouri University Research Reactor (MURR), and National Bureau of Standards Reactor (NBSR); and DOE regulates the High Flux Isotope Reactor and Advanced Test Reactor (ATR). To meet the high demands of these reactors, the U.S. HPRR program has chosen to use 90% uranium - 10% molybdenum (U-10Mo) monolithic fuel. This plate-type fuel will undergo multiple irradiation experiment campaigns in ATR, from mini-plates to full element tests, over a large range of operating conditions. This will provide data in support of the fuel qualification of each reactor. This summary focuses on the as-run neutronic analysis of the first series of mini-plate (MP-1) experiments, which have been irradiated in the ATR. MP-1 experiment’s main goal is to demonstrate the fabrication process and meet the fuel irradiation performance requirements with primary focus on the fuel plates associated with the three NRC reactors, with a small focus on the low power requirements of the ATR fuel. The MP-1 experiments are planned to be the basis of the monolithic U-10Mo fuel for qualification through the NRC.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Transport Modeling of As-Run ATR Cycles for U-10Mo Fuel Qualification Experiment

The Department of Energy’s (DOE) Office of Materials Management and Minimization has been tasked with converting the five remaining United States High Performance Research Reactors (U.S. HPRR) from highly enriched uranium to low-enriched uranium. The Nuclear Regulatory Commission (NRC) regulates Massachusetts Institute of Technology Reactor (MITR), Missouri University Research Reactor (MURR), and National Bureau of Standards Reactor (NBSR); and DOE regulates the High Flux Isotope Reactor and Advanced Test Reactor (ATR). To meet the high demands of these reactors, the U.S. HPRR program has chosen to use 90% uranium - 10% molybdenum (U-10Mo) monolithic fuel. This plate-type fuel will undergo multiple irradiation experiment campaigns in ATR, from mini-plates to full element tests, over a large range of operating conditions. This will provide data in support of the fuel qualification of each reactor. This summary focuses on the as-run neutronic analysis of the first series of mini-plate (MP-1) experiments, which have been irradiated in the ATR. MP-1 experiment’s main goal is to demonstrate the fabrication process and meet the fuel irradiation performance requirements with primary focus on the fuel plates associated with the three NRC reactors, with a small focus on the low power requirements of the ATR fuel. The MP-1 experiments are planned to be the basis of the monolithic U-10Mo fuel for qualification through the NRC.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Proposal to use the DOE-STD-3009-2014 Methodology to Prepare the Documented Safety Analysis (DSA) for Research Reactor Nuclear Facilities

Sandia National Laboratories (SNL) personnel operate a low power research reactor (the Annular Core Research Reactor, or ACRR), and a zero-power critical experiment assembly referred to as CX. In accordance with 10 CFR 830, Subpart B, Appendix A, the acceptable methodology for developing a Documented Safety Analysis (DSA) for DOE nuclear reactors is the Nuclear Regulatory Commission’s (NRC’s) Regulatory Guide 1.70 (RG 1.70). RG 1.70 does not address certain areas required by 10 CFR 830 and expected by DOE (e.g., full facility hazard analysis).Thus, the current DSAs for SNL’s reactor nuclear facilities are based on RG 1.70, but also of necessity supplemented by DOE-STD-3009-94 methods. SNL personnel, in consultation with the National Nuclear Security Administration (NNSA) Sandia Field Office (SFO), have concluded that an alternate methodology is preferred to RG 1.70. The details of the proposal, and the reasons motivating its development, are discussed in the order described below. The proposed alternate methodology will be applicable to the ACRR and the CX (i.e., it will be applicable to nuclear facilities in which a reactor and/or a critical assembly will be operated).

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

National Reactor Innovation Center NRC Early Site Permit Roadmap

The National Reactor Innovation Center (NRIC) at Idaho National Laboratory (INL) in Idaho Falls, Idaho, was authorized under the Nuclear Energy Innovation Capabilities Act (Public Law 115–248) to provide private sector technology developers with resources and infrastructure for testing, demonstration, and performance assessment to accelerate deployment of new advanced reactor technology concepts. NRIC’s mission is to enable clean, affordable, reliable energy by supporting U.S. government investments in nuclear energy research, development, demonstration, and commercialization of new nuclear energy systems. It intends to provide existing facilities and other undeveloped and previously developed sites at INL to advanced reactor vendors for prototype technology testing and deployment. Some of these demonstration projects may be subject to DOE authorization, while other projects may require approval by the U.S. Nuclear Regulatory Commission (NRC) prior to construction and operation. NRIC and INL are considering whether to pursue one or more ESPs to help facilitate new reactor deployment at the INL Site. An ESP would allow early investment in licensing infrastructure in advance of a reactor design being ready to deploy. Through the ESPs, NRIC would help reduce the cost and time required to deploy demonstration reactors at the INL Site. This also will allow INL to bring its nuclear and siting experience to the ESP development process allowing for better and more efficient improvements and utilization of the Site. A preapproved ESP at INL will also remove the uncertainty of NRC siting approvals from the demonstration project proponents, who may not be well positioned to complete the analyses in a timely manner. The purpose of this NRIC ESP roadmap is to provide rigor and understanding needed for INL and DOE decision-makers to make data-informed decisions on pursuing NRC ESPs in support of future advanced reactor demonstrations at INL. The roadmap provides a structured method for addressing potential challenges and identifying options for resolution.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

National Reactor Innovation Center NRC Early Site Permit Roadmap

The National Reactor Innovation Center (NRIC) at Idaho National Laboratory (INL) in Idaho Falls, Idaho, was authorized under the Nuclear Energy Innovation Capabilities Act (Public Law 115–248) to provide private sector technology developers with resources and infrastructure for testing, demonstration, and performance assessment to accelerate deployment of new advanced reactor technology concepts. NRIC’s mission is to enable clean, affordable, reliable energy by supporting U.S. government investments in nuclear energy research, development, demonstration, and commercialization of new nuclear energy systems. It intends to provide existing facilities and other undeveloped and previously developed sites at INL to advanced reactor vendors for prototype technology testing and deployment. Some of these demonstration projects may be subject to DOE authorization, while other projects may require approval by the U.S. Nuclear Regulatory Commission (NRC) prior to construction and operation. NRIC and INL are considering whether to pursue one or more ESPs to help facilitate new reactor deployment at the INL Site. An ESP would allow early investment in licensing infrastructure in advance of a reactor design being ready to deploy. Through the ESPs, NRIC would help reduce the cost and time required to deploy demonstration reactors at the INL Site. This also will allow INL to bring its nuclear and siting experience to the ESP development process allowing for better and more efficient improvements and utilization of the Site. A preapproved ESP at INL will also remove the uncertainty of NRC siting approvals from the demonstration project proponents, who may not be well positioned to complete the analyses in a timely manner. The purpose of this NRIC ESP roadmap is to provide rigor and understanding needed for INL and DOE decision-makers to make data-informed decisions on pursuing NRC ESPs in support of future advanced reactor demonstrations at INL. The roadmap provides a structured method for addressing potential challenges and identifying options for resolution.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Hypothetical Sodium-Cooled Fast Reactor Fuel Transport Using the Existing ES-3100

Increased industry interest in increased enrichment fuels is associated with a heightened interest in high-assay low-enriched uranium (HALEU)-based systems, as novel designs look to take root as alternatives to traditional LWRs. Increased enrichment with novel reactors can produce designs that, in theory and in some historical experience, are capable of operation at increased burnups, higher energy density, and other unique features compared to conventional LWRs. As part of a Department of Energy (DOE) initiative to increase the availability of HALEU fuel, initial funding sourced from the Inflation Reduction Act of 2022 (H.R. 5376) [1] resulted in the DOE/NRC Criticality Safety for Commercial-Scale HALEU Fuel Cycle and Transportation (DNCSH) project, part of the HALEU Availability Program. The project aims to support the Nuclear Regulatory Commission (NRC) in providing data for criticality safety validation of reactor designs that, while perhaps demonstrated in limited capacity, represent more exotic systems than those that regulators are accustomed to reviewing.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

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

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

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