NGNP Licensing Approach & Status
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1 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)
2 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) 2
3 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
4 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 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 4
5 NGNP Project NRC Pre-Application Process Overview 5
6 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 6
7 Overall License Application & Review Sequence NGNP Pre-application Period Application Submittal & NRC Review NGNP Transmittals Partnership Pre-app Early Site Permit COL application & 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 7
8 Highest Priority White Papers 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 8
9 White Papers Submitted to NRC 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) 9
10 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 10
11 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 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 11
12 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 12
13 The Combined Picture NGNP Licensing Product Development Year 1 Year 2 Year 3 Year 4 Year 5 1 st 2 nd 3 rd 4 th 1 st 2 nd 3 rd 4 th 1 st 2 nd 3 rd 4 th 1 st 2 nd 3 rd 4 th 1 st 2 nd 3 rd 4 th White Papers Gap Analysis COLA Content Guide Start of COLA development tied to 50% preliminary design completion Topical Reports ESP COLA Dev. COLA submittal White Paper Reviews Gap Anal. Review COLA Content Guide Review Topical Report Reviews ESP Review NRC Reviews of NGNP Licensing Products 13
14 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 14
15 Licensing Gap Analysis
16 Regulatory Gap Analysis Comprehensive review to identify gaps between existing LWRfocused 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 16
17 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
18 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
19 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
20 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
21 Process Heat & H 2 Co-Generation Phenomena Ground-hugging gases that could be released from chemical plant Oxygen is a significant byproduct of H 2 production processes Oxygen can be released as a waste Oxygen combustion, plume behavior, and allowable concentration H 2 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
22 NGNP Technology Development and Qualification Summary High Temperature Materials Characterization, Testing and Codification Graphite Characterization, Irradiation Testing, Modeling and Codification Fuel Fabrication, Irradiation, and Safety Testing Design and Safety Methods Development and Validation 22
23 More Information - Links to NGNP Documents All NRC submittals related to NGNP are available through the ADAMS system on NRC s public website, Enter PROJ0748 in the Docket field of the ADAMS search screen INL documents related to NGNP can be found at View Documents Archive The NGNP Licensing Plan is found in the 2009 folder 23
24 Bibliography Licensing Framework Development for NGNP, J. Kinsey, Presentation to NEI/DOE Small Reactor Forum, February Next Generation Nuclear Plant Project Licensing Strategy, J. Kinsey, Presentation to IAEA, November Next Generation Nuclear Plant GAP Analysis Report, S.J. Ball, ORNL/TM-2007/228, July Next Generation Nuclear Plant Phenomena Identification and Ranking Tables (PIRTs), S.J. Ball and S.E. Fisher, NUREG/CR-6944, v1 and 2, March HTGR Technology Course for the Nuclear Regulatory Commission May 24-27, 2010, Idaho National Laboratory and General Atomics.
25 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.
26 QUESTIONS?
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