“HTR Regulatory Framework -Progress and Opportunities”

Jim Kinsey

ART Licensing Director

HTR Symposium 2018May 10, 2018, at Idaho National Laboratory

Regulatory Framework Supporting HTR Deployment

• Barriers to HTR deployment

• Current status and recent progress

• Opportunities and next steps

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Long-standing Regulatory “Show Stoppers”

DOE-NRC Report to Congress (August, 2008)

• “It will be necessary to resolve the following NRC licensing technical, policy, and programmatic issues and obtain Commission decisions on these matters”:

Acceptable basis for event-specific mechanistic source term calculation, including the siting source term;

Approach for using frequency and consequence to select licensing-basis events;

Allowable dose consequences for the licensing-basis event categories;

Requirements and criteria for functional performance of the NGNP containment as a radiological barrier

3

Commission Policy versus Practice: 2013 Snapshot

4

Approach Summarized in Commission's Advanced Reactor Policy

Pre-Licensing

Submit License

ApplicationFinal Design

FSAR(draft)

Pre-Licensing

FSAR(draft)

Submit License

ApplicationFinal Design

Approach Implemented by Commission (based on NGNP Experience)

$20M $300M $800M

Requirements Resolution

Requirements Resolution

Requirements Resolution

Adv. Rx.Development

NRC’s Vision and Strategy

5

NRC’s Non-Light Water Reactor Implementation Action Plans

Advanced Reactor Regulatory Framework Development

Original proposals developed via NGNPDOE cost share of

industry-led LMP, managed by INL

Joint DOE-NRC initiative (supported by multi-lab team)

Commission Policy and Technical Issue Resolution Status

Right-sized Emergency Planning

• Draft rule in 2018

• Regulation change in early CY20

Use of Mechanistic Source Term

• NRC SECY-16-0012 confirms concept

• Siting near population centers still open

Containment functional performance requirements

• Confirmed in Reg. Guide 1.232 design criteria

• SECY to Commission in Summer 2018

Accident sequences and event types

• Industry-led and technology-inclusive LMP addresses:

Event selection and evaluation

Use of PRA

SSC classification

Defense in depth adequacy

• NRC Reg. Guide expected in CY197

Establishing HTR Licensing Technical Requirements

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• Joint DOE-NRC initiative established in 2013 to develop adapted alternative to LWR-based GDCs

• Design criteria for modular HTGRs developed by DOE-lab team, with industry review and input, submitted to NRC in 2014

• NRC completed its review and issued Reg. Guide 1.232, “GUIDANCE FOR DEVELOPING PRINCIPAL DESIGN CRITERIA FOR NON-LIGHT-WATER REACTORS” (April 2018)

• Reg. Guide includes a number of “wins”, including significant improvement in regulatory certainty

SARRDL concept incorporated

Offsite and Onsite power requirements much less prescriptive

Emergency Core Cooling System requirements eliminated

Functional alternative to containment structure accepted

New requirements added to address Reactor Building heat removal and radionuclide release pathway functions

Commission Policy versus Practice: 2018 Snapshot

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Approach Summarized in Commission's Advanced Reactor Policy

Pre-Licensing

Submit License

Application

Final Design

FSAR(draft)

Pre-Licensing

FSAR(draft)

Submit License

Application

Final Design

Approach Implemented by NRC Staff and Commission (2018)

$20M $300M $800M

Requirements Resolution

Requirements Resolution

Adv. Rx.Development

Requirements Resolution

Opportunities and Strategies for Continued Regulatory Framework Development and HTR Risk Reduction

What’s Different?

• Push from industry developers, NGO’s, and Congress for transformation and improvement

Consistent push (a bit inconsistent in the details)

• Focused NRC effort per the agency’s Implementation Action Plans

• Core team of NRC mid and senior level managers and senior technical staff established

• Congress providing “off-fee base” funding for NRC work on advanced reactor regulatory framework

NRC reviews and regulatory issue resolutions are being provided to industry “for free”

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What’s Next to Improve HTR Deployment Prospects?

• NRC endorsement of ASME Section III, Div. 5

• Path to TRISO Particle Fuel Qualification

• Commission policy on siting near population centers

• Development of License Application Content Guide

Alternative to LWR-based SRP markup

• Other thoughts and inputs??

• Must continue to assure that R&D programs are generating the technical information necessary to address NRC licensing issues in support of HTR commercial deployments

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Backup Slides

Policy Issue Relationships

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Multi-Reactor Module HTGR Plant Facility

Selection of Events, incl. Multi-Module Risk

(Policy)

Source Term(Policy)

Containment Requirements

(Policy)

Emergency Planning

Requirements(Policy)

Fission Product Transport

Fuel Performance

(Technical)

Protection of the Public

Regulatory Readiness

• Contributing Activities

• Establish the criteria necessary to reach a safety, security, or environmental finding for non-LWR technologies

• Determine appropriate licensing bases and accident sets for non-LWR technologies

• Identify and resolve gaps in current regulatory framework

• Develop a regulatory review “roadmap” reflecting design development lifecycle and appropriate interactions

Possible research and test reactors

• Update prototype reactor guidance

• Engage on technology- or design-specific licensing project plans and develop regulatory approaches commensurate with the risks posed by the technology

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