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Recommendations to Improve Nuclear Licensing: Update to INL/RPT-23-72206, Recommendations to Improve the Nuclear Regulatory Commission Reactor Licensing and Approval Process

In 2023, various stakeholders had asked for BEA’s thoughts and recommendations to improve the U.S. Nuclear Regulatory Commission’s (NRC) licensing review and approval process. This included an April 14, 2023 request from the House Committee on Energy and Commerce on “information and recommendations to improve the licensing review and approval process, . . . as well as the siting, licensing, construction, and oversight of advanced nuclear reactor technologies.” In response to these requests, BEA prepared and published INL/RPT-23-72206, Recommendations to Improve the Nuclear Regulatory Commission Reactor Licensing and Approval Process (2023 Report). The 2023 Report included 13 recommendations related to streamlining NRC hearings, expediting NRC safety and environmental reviews, otherwise improving NRC licensing, and providing financial benefits to new reactor projects. Many of these earlier recommendations were addressed through various legislative actions or changes made by the NRC. Section 2 of this report addresses the current status of those earlier recommendations. BEA recently received a new request from the House Committee on Energy and Commerce seeking any suggestions for additional areas to examine or potential reforms “that may assist in modernizing the licensing and regulatory process that affects civil nuclear deployment.” Additionally, the new Secretary of Energy has identified initial DOE actions to support unleashing the golden era of American energy dominance, including “Unleash Commercial Nuclear Power in the United States” and “Streamline Permitting and Identify Undue Burdens on American Energy.” Given these developments, BEA has prepared a new set of updated recommendations in this report. The recommendations include updated versions of recommendations from the 2023 Report which have not been fully adopted, as well as entirely new recommendations. This set of recommendations has a slightly broader focus with some recommendations focused on DOE authorizations and some recommendations related to nuclear licensing beyond new reactors. Each recommendation below also identifies whether the recommendation would require legislative action or could be addressed directly by the respective agency.

22 GENERAL STUDIES OF NUCLEAR REACTORS

Evaluation of AI-Enabled Digital Documented Safety Analysis: A Case Study

Safety basis documentation development and review under U.S. Department of Energy (DOE) authorization have emerged as critical constraint throttling deployment of advanced nuclear reactors, with traditional processes demanding extraordinary resource investment that delays the delivery of these technologies. Traditional Documented Safety Analysis (DSA) processes rely on static documents with limited traceability [U.S. DOE]. The regulatory review and engagement processes are similarly constrained, often requiring significant effort and extensive manual verification. The scale of this challenge is exemplified by the U.S. Nuclear Regulatory Commission (NRC) review of the NuScale application, which required over 250,000 staff hours and the evaluation of approximately two million pages of documentation [Bergman 2021]. The volume and complexity of information within nuclear licensing applications or authorization reviews demands innovative approaches to document generation and data management.

22 - GENERAL STUDIES OF NUCLEAR REACTORS

The new ITER baseline, research plan and open R&D issues

A new baseline (NB) has been proposed by the ITER Project to ensure a robust achievement of the Projects’ goals, in view of past challenges including delays incurred due to the Covid-19 pandemic, technical challenges in completing first-of-a-kind components and in nuclear licensing. The NB includes modifications to the configuration of the ITER device and its ancillaries (e.g. change from beryllium to tungsten as first wall material, modification of the heating and current drive mix, etc.) as well as additional testing of components (e.g. toroidal field coils) or phased installation (start with inertially cooled first wall before later installation of the final actively water-cooled components) to minimise operational risks. In the NB, the ITER research plan (IRP) will be divided into three main phases: (a) start of research operation, with 40 MW of ECH and 10 MW of ICH, which will focus on the demonstration of 15 MA operation in L-mode, commissioning of all required systems, including disruption mitigation, and the demonstration of H-mode plasma operation in deuterium; (b) DT-1, with 60–67 MW of ECH, 33 MW of neutral beam injection (NBI) and 10–20 MW of ICH, which will demonstrate robust operation in high confinement H-mode plasmas in DT up to Q ⩾ 10 and for burn durations of 300–500 s within an accumulated neutron fluence of ∼1% of the ITER machine’s lifetime total, and; (c) DT-2, with up to 67 MW of ECH, up to 49.5 MW of NBI and up to 20 MW of ICH, with the ITER tokamak and ancillaries in their final configuration to demonstrate routine operation in DT plasmas at high Q and the Q ⩾ 5 long-pulse and steady-state scenarios to the final neutron fluence and to perform R&D on nuclear fusion reactor issues. The logic, physics basis, modelling and experimental evaluations carried out to support the NB and the associated IRP are described. These include the impact of the tungsten wall on plasma scenarios and associated risk mitigation measures, as well as the optimisation of the tokamak components and ancillaries to minimise Project risks. Open R&D issues related to these evaluations and mitigation measures are also described together with experimental, modelling and validation activities required to address them.

ITER

Digital Safety Analysis for Small Modular Nuclear Reactors (SMRs)

The licensing process for any nuclear installation generally requires the review and approval of numerous documents by a regulatory body. Alternate approaches are needed where similar nuclear installations are planned to be built and operated at multiple sites around the world. Such is the case for the deployment of small modular nuclear reactors (SMRs) under development by multiple enterprises in multiple countries. As a use case for this paper, the authors propose an alternative to the Documented Safety Analysis (DSA) required by the United States Department of Energy (DOE) for the licensing of its nuclear installations. The DSA is a DOE construct that requires the review and approval of numerous documents. It includes an in-depth description of hazards, safe boundaries, and hazard controls.

Microreactors

An Approach to Automate tools for the Risk Assessment of Digital Instrumentation and Control Systems

Reliable digital instrumentation and control systems (DI&C) are integral for sustaining the continued operation of nuclear power plants. These systems ensure that nuclear reactors operate safely, efficiently, and within regulatory requirements. Yet, the cost of designing and licensing new nuclear DI&C can be prohibitively expensive. Under the U.S. Department of Energy Light Water Reactor Sustainability Program, Idaho National Laboratory has developed a framework for supporting the risk-informed design of DI&C systems by offering methods to support the identification, quantification, and evaluation of risks for various DI&C design architectures. The framework indicates potential software failure modes and provides pathways for quantifying the potential for these software failures, including common cause failures. Using the framework’s systematic approach, challenges for assessing risks within new and existing nuclear DI&C systems can be reduced. Nevertheless, the current framework can be further improved using the convenience of automation. This paper introduces the development of Software for the Hazard Identification and Evaluation of Digital Systems (SHIELDS). SHIELDS is an engineering software package that enables the identification, elimination, and mitigation of potential risks and reduces the burden of deploying reliable DI&C systems. This work introduces plans and techniques to digitize and improve the manual risk assessment modules of the framework. These improvements will save time and increase the repeatability and usability of the framework, making it more accessible to a wider range of users. Ultimately, this introduces SHIELDS and how its modules support efficient development of safe and reliable DI&C systems.

46 - INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AN

Accelerated Irradiation and Qualification of Ceramic Nuclear Fuels

Accelerated neutron irradiation testing is an component of accelerated qualification of new nuclear fuels for light water reactor (LWRs), microreactors, and other special purpose reactors. The qualification and licensing of nuclear fuel is a lengthy process that can take 20-25 years to bring a new fuel into service. Accelerated fuel qualification combines both experimental and modeling work to expedite the total qualification time to 5-10 years timeframe. The experimental aspect of this is accelerated irradiation aims to reduce the total time needed for neutron irradiation to achieve targeted burnup, which can take years using conventional irradiation profiles. The data that results from this irradiation testing can then be entered into BISON models to develop robust and reliable performance simulations to ensure safe operation under normal and off normal conditions. This milestone focused on the fabrication of test articles for accelerated irradiation testing at the Advance Test Reactor (ATR).

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS

Nuclear Power Plant Colocation with Data Centers

This presentation is an overview of the nuclear siting and licensing process, including specific considerations and challenges for nuclear power plant colocation with data centers.

22 - GENERAL STUDIES OF NUCLEAR REACTORS

Preliminary Design of Engineering-Scale Salt Accident Analysis Facility to Support Molten Salt Reactor Licensing

Systems-level nuclear accident analysis codes for reactor licensing must be validated using experimental data that represent behaviors expected during actual full-scale accidents. Some behaviors may arise from coupled processes and only manifest at large scales. This report presents the preliminary design of the Salt Accident Analysis Facility (SAAF, pronounced “safe”), which is an experimental test facility to be constructed at Argonne that can be used to conduct integrated salt accident tests at an engineering scale. The measurement capabilities of the SAAF are based on previously developed methods and will provide the representative datasets that are needed to support molten salt reactor (MSR) licensing. Details of the design, the processes to be quantified, the measurement techniques for quantifying the processes, the variables that can be adjusted to simulate different accident scenarios, and operational considerations are presented herein. This report provides stakeholders the opportunity to give feedback on the test facility capabilities and planned analyses before it is constructed.

22 GENERAL STUDIES OF NUCLEAR REACTORS

Experimental Investigations into the Corrosion of Alloy 625 Using NaCl-PuCl3 Molten Salt in a Natural Circulation Microloop

Molten salt reactors (MSRs) can potentially revolutionize the nuclear industry by providing a path to a near-zero nuclear waste fuel cycle, contributing to more sustainable energy sources. As a plethora of MSR developers in the United States work toward an aggressive commercialization timeline, many of their fueled-salts—notably, chloride-based compositions—have limited operational testing with nuclear material. Licensing and operating these reactors require an understanding of corrosion effects on reactor materials of construction under operational conditions. The TerraPower Molten Chloride Fast Reactor (MCFR) is a liquid-fueled chloride-salt fast reactor which has received notable interest from the utility sector based on its desirable economic characteristics. The reactor operates at low pressure but does not require the use of highly reactive chemicals, leading to a reduced use of concrete and steel during construction. Additionally, liquid fuel allows for inherently stable behavior and natural circulation during a loss-of-site-power scenario. MCFR can be refueled while operating which makes it compatible with variable generation sources such as wind and solar. MCFR is a breed-and-burn in-situ reactor that does not implement any chemical processing or separations in the fuel cycle. Only mechanical filtration of noble metals and off-gassing of noble gases are utilized while the actinides stay mixed with the fuel at all times. The MCFR will require technology development to reach commercialization. With a breed-and-burn in-situ reactor like MCFR, the transmutation of fertile U-238 to fissile Pu-239 allows for much greater fuel utilization.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS

Framework for a Digital Documented Safety Analysis

This framework is developed to progress the digital implementation of digital tools applied to the DOE authorization process, with future applications to NRC SAR development/review, to accelerate the design and review processes of advanced nuclear reactors. The engineering design and licensing process for nuclear reactors is currently burdened by a document-based approach that leads to duplications and errors due to a lack of traceability among numerous static documents. Changes to design information require labor-intensive manual tracing through these documents, creating a high potential for human error. The adoption of a digital ecosystem, utilizing a digital thread to link various aspects of project design and analysis, promises dynamic documentation generation, automatic updates, and error reduction. Model Based Definition (MBD) and Product Lifecycle Management (PLM) tools are central to this digital transformation.

22 GENERAL STUDIES OF NUCLEAR REACTORS

Strategy to safely enable X-ray computed tomography examination of highly radioactive tristructural isotropic nuclear fuel

Nondestructive post-irradiation examination of nuclear fuels and materials is useful in collecting data to inform commercial licensing of new nuclear concepts. This work details the planning, shielding design, and workflow of an X-ray computed tomography examination of an irradiated AGR-5/6/7 fuel compact with a dose rate of 1318 R/hr on contact from both β and ɤ-ray radiation with 120 R/hr of the dose rate coming exclusively from ɤ-rays. Post-irradiation examination of highly radioactive samples can help reduce the timeframe from conceptualization of novel nuclear concepts to their commercial implementation as not only is less time spent waiting for experiments to decay away to acceptable levels for examinations, but data from these experiments can more quickly inform model efforts and subsequent experiments. While this work represents the hottest radiological sample that has been openly transported and examined at Idaho National Laboratory’s Irradiated Materials Characterization Laboratory to date, it is anticipated that this work and its lessons learned will facilitate future examinations of similar or even more radioactive specimens.

42 - ENGINEERING

DOE ART Graphite R&D Program

Graphite overview: Material science, supply chain facts, nuclear material science, licensing thoughts

11 - NUCLEAR FUEL CYCLE AND FUEL MATERIALS

An In Situ Feed Monitoring System for Molten Salt Reactors with Fast Neutron Energy Spectrum Molten Salt Reactor Applications

Molten salt reactors (MSRs) are one of the six promising advanced reactor technologies selected for further research and development by the Generation IV International Forum. More than twenty MSR designs are actively being developed around the world. Several of these designs are liquid-fueled and intended for operation within the fast neutron energy spectrum.1 National regulations will require liquid-fueled MSRs to control and account for nuclear material within licensed facilities. Additionally, states with comprehensive safeguards agreements with the International Atomic Energy Agency (IAEA) are obligated to declare nuclear material quantities within facilities. In return, the IAEA Department of Safeguards independently verifies these quantities and provides assurance that the nuclear material and facility are being used only for peaceful purposes. One key distinction of liquid-fueled MSRs compared with other types of reactors is that in portions of the facility, the nuclear material is in bulk form rather than discrete items. Traditional nuclear material accounting techniques such as physical item counting and verification of serial numbers on fresh fuel assemblies do not translate directly to all process streams within liquid-fueled reactors. Liquid-fueled MSRs are typically designed with low excess reactivity. This feature provides safety benefits but also means that most MSRs require the addition of makeup fuel salt while a reactor is operational. The nuclear material in the initial fuel salt and in any makeup fuel salt must be quantified. Additionally, distinct nuclear material diversion and reactor misuse scenarios form the basis of the detection methods and monitoring systems developed for liquid-fueled MSRs. For example, the IAEA provides assurance that fuel salt containing nuclear material is not being diverted from the system, that the feed salt matches the reported actinide concentrations and uranium enrichment, and that no additional fertile material is being introduced into the system. Measurement systems currently used for nuclear material control and accounting are not directly applicable to achieving MSR safeguards goals. This paper concerns a system being designed to account for the nuclear material added to liquid-fueled MSRs and monitor for diversion and misuse scenarios related to MSR feed systems.

22 GENERAL STUDIES OF NUCLEAR REACTORS

Fast neutron irradiation capability in existing thermal test reactors

In today’s nuclear industry, momentum towards the design, licensing, and construction of advanced nuclear demonstration plants, including fast reactors, is at a remarkably high level. However, there are currently no dedicated fast spectrum irradiation test facilities in the United States to support the development of fast spectrum technologies. As a result, a unique situation is developing where most of these plants will likely be designed by leveraging historic nuclear material technologies, but where the further optimization and advancement is impeded by the lack of fast neutron irradiation test facilities. While these circumstances present a challenge, there are some near-term opportunities that, if seized, can still help develop advanced fast reactor materials to a meaningful level of readiness to support future commercial fast reactors. Here, in this paper, we assess the feasibility of using thermal neutron filtering materials in existing experiment positions in the Advanced Test Reactor (ATR) at Idaho National Laboratory and the High Flux Isotope Reactor (HFIR) at Oak Ridge National Laboratory to simulate fast reactor test environments for nonfuel test specimens. Items investigated include the incident neutron flux (both fast and thermal), the total neutron fluence and cumulative atom displacements, helium production rate due to thermal neutron capture in nickel, and the potential impact that the thermal neutron filter material has on the cycle length of a given reactor. It is concluded that while HFIR provides the highest fast flux of all the options investigated, it is limited in the amount of thermal neutron filtering material that can be introduced into an experiment position without significantly affecting the operation of the reactor. Irradiation in Outboard-A positions in the ATR was found to be the most realistic near-term experiment avenue due to having ample space for several capsules in a moderately fast flux.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS

Recommendations for an Applicant to Calculate Activity Data for Greenhouse Gases Estimates

In 2009, the U.S. Nuclear Regulatory Commission (NRC) directed the NRC staff to address climate change issues and consider the impacts of the emissions of carbon dioxide (CO 2 ) and other greenhouse gases (GHGs) in its environmental reviews for major licensing actions (NRC 2009b). To implement this direction from the Commission, the staff issued guidance in 2011 and updated guidance in 2014 in Attachment 1 to Interim Staff Guidance COL/ESP-ISG-026 (NRC 2011; NRC 2014). This guidance provides a simpler method than the method described in RG 4.2 Rev. 3, that an applicant can use to meet the plant parameter envelope (PPE) value from the Generic Environmental Impact Statement for Licensing of New Nuclear Reactors (NR GEIS). NRC staff estimated the 97-year lifecycle GHG emissions from a reference 1000 megawatt electrical (MWe) light-water reactor (LWR) for various activities associated with construction, operation (including uranium fuel cycle), and decommissioning of nuclear power plants and presented the results in Appendix H of the NR GEIS. Appendix H of the NR GEIS includes estimates of direct emissions from construction equipment and emergency diesel engines in a nuclear facility and indirect emissions from workforce vehicular traffic, fuel transportation and the uranium fuel cycle. The NR GEIS Section 3.3 extended the estimates in Appendix H for the installation of two 1000 MWe nuclear reactors on the same site. Scaling factors were used to extrapolate the GHG emissions of a reference 1000 MWe reactor to a two-unit nuclear reactor plant (each reactor unit generating 1000 MWe). GHG emission estimates for building, operation, decommissioning and safe storage (SAFSTOR) for a two-unit nuclear reactor plant would be based on the plant’s physical size, and therefore estimates for these source categories were assumed to be twice the value of the reference 1000 MWe reactor. However, GHG emissions from the fuel cycle (including fuel transportation) were scaled upward by a factor of 3, based on plant efficiencies greater than the 80 percent assumption in Appendix H. Table 1 below shows the PPE emissions for two 1000 MWe nuclear reactors as provided in NR GEIS. The total GHG emissions for two 1000 MWe reactors were calculated as 2,534,000 metric tons (MT) of CO 2 equivalent (CO 2 (e)) based on a 97 year GHG life cycle period. The GHG emissions lifetime of 97 years for a reference nuclear reactor includes a 7-year building phase, 40 years of operation, 10 years of active decommissioning, and 40 years of SAFSTOR operations (NRC 2024). Construction equipment and vehicular traffic from workers commute would contribute to the GHG emissions during a 7-year building phase. Uranium fuel cycle, vehicular traffic, fuel and waste transportation, and testing of standby diesel generators would contribute to GHG emissions during the 40-year operations phase. While NRC’s regulations allow up to 60 years of reactor facility decommissioning, Appendix H estimated that most of the GHGs would occur over an estimated 10-year period during which to the licensee would engage in significant demolition and earth-moving activities, as discussed in Supplement 1 to NUREG-0586 (NRC 2002). Vehicular traffic by the workforce during a 40-year SAFSTOR period would additionally contribute GHG emissions. The carbon footprint for a 40-year SAFSTOR period was separately analyzed from the decommissioning activities as provided in Table YYYY-2 of the staff issued guidance in 2011 (NRC 2011).

22 GENERAL STUDIES OF NUCLEAR REACTORS

SPARC - Plans for a New Critical Experiment Facility with a Horizontal Split Table

Several critical experiment facilities, sometimes referred to as zero power reactor facilities, have provided crucial data to aid understanding and validate nuclear-physics models since the beginning of nuclear technology. Indeed, the first man-made reactor, Chicago Pile-1, was essentially this type of reactor. However, there was a downturn in nuclear technology development toward the turn of the millennium, and the need for these specialized research facilities waned. Now there are few of these experimental facilities operational in the world and those that remain have relatively small critical assembly machines. The need for criticality safety benchmark experiments at intermediate neutron energy levels and the modern resurgence of interest in advanced reactors designs, many of which do not have historical precedents in terms of nuclear fuel composition, moderator, and coolant combinations, all combine to create a substantial need for a critical experiment facility with a large horizontal split-table (HST) machine. A HST machine is used to arrange two separate and subcritical parts of a core assembly, bring them together in a precise manner to achieve criticality using remote controls, and separate them to achieve a subcritical configuration again. A new effort was recently performed to develop user needs for a HST, assess candidate locations at the Idaho National Laboratory (INL), and develop a plan for deployment. This project is referred to as the System Physics Advanced Reactor Critical facility (SPARC). A few months after this assessment began, and shortly after as a viable pathway was emerging, a series of important presidential executive orders were issued to revitalize nuclear energy in the United States (U.S.). The relevance of SPARC to these executive orders was immediately apparent. The far-reaching potential of SPARC to these executive orders will reside in its ability to produce data which facilitates licensing of advanced nuclear reactor designs while reducing uncertainties to help increase energy production alongside new criticality safety data to enable more efficient nuclear fuel manufacture, transport, and storage.

22 - GENERAL STUDIES OF NUCLEAR REACTORS