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NGNP Licensing Approach & Status

IAEA Course on High Temperature

Gas Cooled Reactor Technology

Tsinghua University, Beijing

October 22-26, 2012

Presented by: Javier Ortensi

Based on material by Jim Kinsey

Idaho National Laboratory (INL)

NGNP Licensing Path to HTGR Deployment

Overall strategy established in DOE-NRC Report to Congress (August, 2008)

• Recommended the Part 52 Combined License (COL) process be utilized

– Lowers licensing risk - builds on recent industry experience

– Increases project certainty for stakeholders

• Identified initial set of priority licensing issues requiring resolution to license /operate NGNP

– Described process for adaptation of existing LWR rules

– Identified likely need for new or revised regulatory approaches in certain areas

• Established NRC infrastructure & resource needs

• Focused on steps to support NGNP plant deployment

– Licensing pre-application program with NRC

– NGNP license application and NRC review/approval

– Construction and plant startup (with NRC oversight)

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Close Coordination between DOE and NRC

• A collaborative interagency effort was implemented to identify and address HTGR licensing and policy issues

• Activities include:

– Review and feedback on project plans for key licensing support activities (fuel qualification programs, fission product and source term analysis, etc.)

– Periodic agency to agency technical meetings and information exchanges

– Assessment of issues related to the development of technical licensing requirements

– Collaboration and observation of tests & experiments

• NGNP has coordinated regular project interactions with NRC and DOE

3

NGNP Licensing Plan

• Prioritization results are summarized in the NGNP Licensing Plan (2009)

– Identifies priority licensing topics (key policy

and technical issues)

– Describes resolution & implementation plan

• Defines a plan for documenting COL Application (COLA) content for HTGR’s – Utilizes Reg. Guide 1.206 concept (COLA Content Guide for LWR’s) – Key inputs are results of white paper disposition and regulatory gap analysis – Preliminary Design information will be necessary to address Content Guide

open items and to develop license application documents

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NGNP Project

NRC Pre-Application Process Overview

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NRC License Application Development Process

• Pre-Application activities focus on defining the requirements for an HTGR license application – COLA Content Guide, which will be based on 2 primary inputs: – Licensing white paper dispositions

– Regulatory Gap Analysis results

• License application development will follow the Content Guide, and will include development of: – Early Site Permit (optional, but likely)

– Topical Reports

– Combined License Application

It is noted that application development will require design detail at the Preliminary Design level

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Overall License Application & Review Sequence

NGNP Transmittals

Partnership Pre-app

Early Site Permit

COL application & review

NGNP Pre-application Period Application Submittal & NRC Review

Note:

a) “Partnership” refers to the future NGNP Project public-private partnership

b) The potential benefits of an ESP application will be evaluated by the

future partnership; an ESP is not included in current DOE project plans

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• Licensing white paper activities were prioritized to address

issues that:

– Could potentially have significant impact on the plant design and/or

long duration research & development activities

– Will potentially require Commission action, based on the potential

results from NRC Staff review of high priority NGNP licensing white papers

– May represent a potentially significant license application content

issue that could impact the application’s acceptability or NRC review schedule

Highest Priority White Papers

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– Defense in Depth (December 2009)

– High Temperature Materials Qualification (June 2010)

– Fuel Qualification Process (July 2010)

– Mechanistic Source Terms Description (July 2010)

– License Structure for Multi-Module Facilities (August 2010)

– Licensing Basis Event Selection (September 2010)

– Structures, Systems, and Components Safety Classification (September 2010)

– Emergency Planning Zone Size and Emergency Planning Attributes (October 2010)

– NGNP Nuclear-Industrial Facility and Design Certification Boundaries

(September 2011)

– NGNP Probabilistic Risk Assessment (September 2011)

– Modular HTGR Safety Basis and Approach (September 2011)

–

White Papers Submitted to NRC

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Early Site Permit (Based COLA Content Guide)

• Optional approach for applicant to manage license schedule risk

• Allows 10CFR52 site safety and environmental information to be submitted to NRC prior to COLA.

• Vehicle to assist resolution of certain safety, environmental, and emergency preparedness issues.

• Development of ESP application expected to require 2 yrs

• Valid up to 20 years

• Can utilize a plant parameter envelope approach (i.e. use as a surrogate for actual facility information while it is being developed)

• Can be incorporated (by reference) into the COLA

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Topical Reports (Based COLA Content Guide)

• Establish technical basis for specific safety areas to support NRC licensing decision

• Submitted by applicant in advance of FSAR submittal. Submittals may continue past COLA submittal date.

• Used to provide input to plant design and bring regulatory finality to specific topics in the COLA

• HTGR COLA may require 100-150 topical reports

• Topical reports will heavily support the HTGR COLA in: – Part 2: Final Safety Analysis Report,

• Chapter 3, Design of Structures, Systems and Components

• Chapter 4, Reactor

• Chapter 7, Instrumentation and Controls

• Chapter 15, Transient and Accident Analysis

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Important HTGR Topical Reports

• Tritium Generation and Release Mitigation

• Composites study

• Contamination control study

• Air and water ingress analysis

• Multiple module integrated risks

• Fuel Qualification

• Graphite and Material Qualification

• Qualification of Radionuclide Transport Barrier Decontamination Factors

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NRC Reviews of NGNP Licensing Products

NGNP Licensing Product Development

The Combined Picture

Year 1 Year 2 Year 3 Year 4 Year 5

1st 2nd 3rd 4th 1st 2nd 3rd 4th 1st 2nd 3rd 4th 1st 2nd 3rd 4th 1st 2nd 3rd 4th

ESP

White Papers

Gap Analysis

COLA Content Guide

Topical Reports

COLA Dev.

Start of COLA development tied to

50% preliminary design completion

COLA submittal

White Paper Reviews

Gap Anal. Review

COLA Content Guide Review

Topical Report Reviews

ESP Review

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NGNP Licensing Framework Status

• In February 2012 the NRC issued two assessment reports providing the results of its review in the following areas:

– Risk Informed Performance Based Approach

• Licensing Basis Event Selection

• Classification of Structures, Systems, and Components

• Defense in Depth

– Fuel Qualification and Mechanistic Source Terms

• “No obvious fundamental issues that would prevent development of related licensing submittals that meet regulatory requirements…

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Licensing Gap Analysis

Regulatory Gap Analysis

• Comprehensive review to identify “gaps” between existing LWR-focused regulations and those needed to license HTGRs

• Preliminary LWR regulatory assessment completed – June 2008

• Detailed NGNP procedure developed to support HTGR gap analysis

• Gap analysis will provide a thorough regulatory accounting of existing NRC requirements and associated regulatory guidance documents applicable to HTGRs – Enable the advanced resolution of identified informational gaps

– Identified gaps and resolutions will be tracked to completion

– Completed resolutions are then incorporated into the COLA Content Guide for HTGRs

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Accident and Thermal-Fluids

• 4 major gaps identified in accident and Thermal-fluids – Core coolant bypass flow (normal operation)

– Core effective thermal conductivity (DLOFC)

– Reactor cavity cooling system (RCCS) performance (during LOFC)

– Confinement with reactor cavity air ingress

• No major gaps in reactor physics / neutronics

Fission Product Transport

• Uncertainties in confinement design (which have a major impact on “gap priorities”)

• Fission product (FP) releases via normal helium leakage, and dust-borne releases

• Deleterious effects of mechanical shock and vibrations during rapid discharge in postulated D-LOFC accidents which could cause additional releases of FPs that would have otherwise been retained within the primary system

High Temperature Materials

• for the reactor pressure vessel (RPV), crack initiation and subcritical crack growth, surface emissivity, and loss of desired surface layer and other property degradation

• aging and fatigue leading to degradation of insulation materials

• intermediate heat exchanger (IHX) crack initiation and propagation

• structural design methods for control rod composites

• in-vessel surface emissivities and irradiation-induced creep

• structural design and fabrication of composites and

• valve failure in high-temperature conditions

Graphite

• graphite supply uncertainties and inconsistencies

• confirmatory data for new grades to be used in NGNP

• irradiation creep data and effect of creep on properties

• consensus design codes and standards

• extension of current theoretical performance models to higher doses and temperatures

• development of whole-core structural models and nondestructive examination (NDE) methods

• analytical models for oxidation, property changes, and dimensional changes with creep induced by irradiation

Process Heat & H2 Co-Generation

• Phenomena – Ground-hugging gases that could be released from chemical plant

• Oxygen is a significant byproduct of H2 production processes

• Oxygen can be released as a “waste”

• Oxygen combustion, plume behavior, and allowable concentration

• H2 no big issue due to high buoyancy and dilution by air

– Heat exchanger failure effect on primary system

– Safety uncertainties associated with collocation of nuclear and chemical plants are significant since no experience

• Gap analysis results – Potential phenomena resulting from process plant interface with the

reactor are highly design dependent

– Minimize effect on reactor safety

NGNP Technology Development and Qualification Summary

Graphite Characterization, Irradiation Testing,

Modeling and Codification

Fuel Fabrication, Irradiation, and Safety Testing

Design and Safety Methods Development and Validation

High Temperature Materials Characterization, Testing and

Codification

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More Information - Links to NGNP Documents All NRC submittals related to NGNP are available through the ADAMS system on NRC’s public website, www.nrc.gov

– Enter PROJ0748 in the “Docket” field of the ADAMS search screen

INL documents related to NGNP can be found at www.nextgenerationnuclearplant.com

– “View Documents Archive”

– The NGNP Licensing Plan is found in the 2009 folder

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Bibliography

– “Licensing Framework Development for NGNP,” J. Kinsey, Presentation to NEI/DOE Small Reactor Forum, February 2012.

– “Next Generation Nuclear Plant Project Licensing Strategy,” J. Kinsey, Presentation to IAEA, November 2010.

– “Next Generation Nuclear Plant GAP Analysis Report,” S.J. Ball, ORNL/TM-2007/228, July 2008.

– “Next Generation Nuclear Plant Phenomena Identification and Ranking Tables (PIRTs), S.J. Ball and S.E. Fisher, NUREG/CR-6944, v1 and 2, March 2008.

– “HTGR Technology Course for the Nuclear Regulatory Commission” May 24-27, 2010, Idaho National Laboratory and General Atomics.

Acknowledgements

Work partially supported by the U.S. Department of Energy,

Assistant Secretary for the Office of Nuclear Energy,

under DOE Idaho Operations Office Contract

DE-AC07-05ID14517.

QUESTIONS?