Environmental Review DiscussionNRC Project Number 99902088 supporting pre-application licensing activities

Dr. Tony HillNEXT Lab, Licensing Director

November 8, 2021

Licensing Approach

Outline• Update of ACU MSRR project status• ACU MSRR site selection• SERC facility description• SERC construction not included in ACU Environmental

Review• Scope and depth of the ACU Environmental Review

Status of ACU MSRR Project • ACU Regulatory Engagement Plan (Rev 0) submitted September 2020• Included initial approach for pre-application engagement (completed)

ü Introductory meeting – project overview with scope and scheduleü 10CFR50.10(a)(2)(x) Interpretationü Security Plan discussionsü QAPD Topical Report

• Approach needs to be updated and synchronized (evolving landscape)• A number of guidance documents endorsed after REP submission• Release of “DRAFT Preapplication Engagement to Optimize Application Reviews”• Optimize both safety and environmental application reviews• Topical Reports• Meetings, Audits, and White Papers• Environmental Activities (initial discussion later in this meeting)

• Minimizing time to criticality is a primary driver for ACU• ACU would like to work with the NRC to better understand the preapplication process

and benefits from using the process

Status of ACU MSRR Project • Initial project timeline in ACU REP (Rev 0)• CP was not submitted by the end of FY21• Detailed project plan exists• Uncertainty in PSAR content versus FSAR guidance remains an issue

• Initial project timeline contained levels of aggressiveness and optimism

• We would like to work towards a realistic and synchronized plan that:• Optimizes time to PSAR submission and CP issuance (grants and contracts)• Optimizes time to criticality under 104c for a University MSRR (primary mission driver)

ACU MSRR Site Selection Summary• Site selection process• Region of Interest• Candidate Sites• Proposed Site

Licensing Approach

MSRR Site Selection Process• Objectives• Determine and document the preferred site for the MSRR based on three categorical

factors important to ACU:

• Methodology• Rank scoring (1st , 2nd , 3rd) for the six considerations in each of the three categories• 1st is top choice

Environmental Impact1) Site preparation2) Facility construction3) Reactor construction4) Reactor operations5) Reactor decommissioning6) Facility decom & remediation

Mission ImpactA) Timeline to Criticality

1) Site preparation2) Facility construction3) Reactor construction

B) Proximity 1) Education2) Security3) Emergency Response

Financial Impact1) Site preparation2) Facility construction3) Reactor construction4) Reactor operations5) Reactor decommissioning6) Facility decom & remediation

ACU Region of Interest

6 miles

Abilene Regional AirportDyess AFB

Lake Fort Phantom Hill

Kirby Lake

ACU Main Campus

• Candidate Area• North Abilene area

AbileneUS I-20

Abilene PD

• Candidate Area• North Abilene area

• Potential Sites• ACU-owned

ACU Region of Interest

6 miles

Abilene Regional AirportDyess AFB

Lake Fort Phantom Hill

Kirby Lake

ACU Main Campus

AbileneUS I-20

Abilene PD

• Candidate Area• North Abilene area

• Potential Sites• ACU-owned

• Candidate Sites• Existing utilities• ~100m of space

around facility

ACU Region of Interest

6 miles

Abilene Regional AirportDyess AFB

Lake Fort Phantom Hill

Kirby Lake

ACU Main Campus

AbileneUS I-20

SERC FacilitySherrod Site

Rhoden Farm Site

Abilene PD

ACU Main Campus Area

ACU Main Campus

SERC FacilitySherrod Site

Hendrick’s Hospital

Abilene Fire Station 5

ACU Police

US I-20

Rhoden Farm Site (10 mile drive)

1 mile

Licensing Approach

Rhoden Farm Site• Active Research Farm• ~300 acres• ACU A&E Sciences Dept• Sustainable agriculture• Environmental systems

• Products consumed locally

Sherrod Site

Cedar Creek

Floodway

100-yr Floodplain500-yr Floodplain

• Sherrod Apartments• Student housing units• No longer in use• Will need to raze (asbestos)• Drains to Cedar Creek• Frisbee park

Main Campus

Licensing Approach

SERC Facility

• SERC Facility• Main campus location• Short walk from Chemistry,

Engineering & Physics Depts.• Pre-existing facility designed to

potentially house a variety of radiation producing devices

ACU Science and Engineering Research Center

Cedar Creek

Floodway

100-yr Floodplain500-yr Floodplain

ACU Main Campus

Licensing Approach

Ranking Candidate Sites

1) Site preparation2) Facility construction3) Reactor construction4) Reactor operations5) Reactor decommissioning6) Facility decom & remediation

Rhoden Farm Site

EnvironmentalImpact

Sherrod Site SERC

1 1 11 1 11 1 11 1 11 1 11 1 1

3rd 2nd 1st

3rd 2nd 1st

1st 1st 1st

1st 1st 1st

1st 1st 1st

2nd 2nd 1st

Licensing Approach

Ranking Candidate Sites

1) Site preparation2) Facility construction3) Reactor construction4) Reactor operations5) Reactor decommissioning6) Facility decom & remediation

Rhoden Farm Site

EnvironmentalImpact

Sherrod Site SERC

1 1 11 1 11 1 11 1 11 1 11 1 1

3rd 2nd 1st

3rd 2nd 1st

1st 1st 1st

1st 1st 1st

1st 1st 1st

2nd 2nd 1st

The primary difference between these sites is that construction of a new facility will need to included in the project and the Federal licensing action at the Rhoden Farm and Sherrod sites.

“Drop-in” style reactor has roughly the same environmental impact for all candidate sites with regard to the reactor construction, operations, and decommissioning activities.

Licensing Approach

Ranking Candidate Sites

1) Site preparation2) Facility construction3) Reactor construction4) Reactor operations5) Reactor decommissioning6) Facility decom & remediation

Rhoden Farm Site

FinancialImpact

Sherrod Site SERC

2nd 3rd 1st

3rd 2nd 1st

2nd 1st 1st

2nd 1st 1st

2nd 1st 1st

3rd 2nd 1st

Licensing Approach

Ranking Candidate Sites

1) Site preparation2) Facility construction3) Reactor construction4) Reactor operations5) Reactor decommissioning6) Facility decom & remediation

Rhoden Farm Site

FinancialImpact

Sherrod Site SERC

2nd 3rd 1st

3rd 2nd 1st

2nd 1st 1st

2nd 1st 1st

2nd 1st 1st

3rd 2nd 1st

The financial impact rankings are primarily driven by costs associated with the construction of a new purpose-built facility at the Rhoden Farm or Sherrod sites.

Added costs are incurred for reactor construction, operations, and decommissioning at the Rhoden site due to the remote location.

A) Timeline to Criticality1) Site preparation2) Facility construction3) Reactor construction

B) Proximity 1) Education2) Security3) Emergency Response

MissionImpact

2nd 2nd 1st

2nd 2nd 1st

2nd 1st 1st

3rd 2nd 1st

3rd 2nd 1st

2nd 1st 1st

Ranking Candidate Sites

Rhoden Farm Site Sherrod Site SERC

A) Timeline to Criticality1) Site preparation2) Facility construction3) Reactor construction

B) Proximity 1) Education2) Security3) Emergency Response

MissionImpact

2nd 2nd 1st

2nd 2nd 1st

2nd 1st 1st

3rd 2nd 1st

3rd 2nd 1st

2nd 1st 1st

Ranking Candidate Sites

Rhoden Farm Site Sherrod Site SERC

Proximity to central campus supports deeper and broader integration with departments and students. Security posture and emergency response times increase with distance from campus and first responders.

The construction of a new purpose-built facility as part of the CP application will result in a substantial delay in primary project driver to minimize the timeline to criticality.

Licensing Approach

SERC Facility is the Proposed Site

28,000 ft2 multi-use NEXT Lab facilityü 6,000 ft2 research bayü Research Laboratoriesü Training Roomsü Faculty Officesü Collaborative spaces

üDesigned by ParkhillüConstruction by Linbeck Group

üConstruction activities started: 2021• Anticipated completion: early 2023• Planned research independent of

MSRR to begin once completed

ACU Science and Engineering Research Center The SERC multi-use facility was designed to

attract/support projects such as the MSRR at ACU.

Research Labs,Training Rooms

Offices, Collaborative SpacesResearch Bay

80’

15’

25’

40t NOG-1 Crane

120’

50’

Research Bay

80’

15’

25’

40t NOG-1 Crane

120’

50’

“If, as ACU asserts, the SERC is: (1) a building which will be used for activities such as research, teaching, and/or office work that are not part of any reactor facility operation; and (2) a building which has space for installation of a

reactor facility and may be used to house a reactor facility, the planned SERC could be considered the type of building referred to in 10 CFR 50.10(a)(2)(x).” – NRC staff response to regulatory interpretation request (ML20366A053)

80’

15’

25’

40t NOG-1 Crane

120’

50’

“If, as ACU asserts, the SERC is: (1) a building which will be used for activities such as research, teaching, and/or office work that are not part of any reactor facility operation; and (2) a building which has space for installation of a

reactor facility and may be used to house a reactor facility, the planned SERC could be considered the type of building referred to in 10 CFR 50.10(a)(2)(x).” – NRC staff response to regulatory interpretation request (ML20366A053)

How do we move from“…the planned SERC could be considered…”

to “…the SERC is considered…”?When will ACU know for sure?

Licensing Approach

MSRR Environmental Review Will Include…• MSRR “Drop-in” Construction • MSRR fabrication will be carried out in various machine shops and shipped to SERC• MSRR assembly activities will be inside the SERC, limited to added light delivery/worker traffic• Potential/uncertain internal modifications to the SERC (minimize through MSRR design)• Minimal non-radiological waste management

• MSRR Operations (initial power level ~10kW)• Minimum non-radiological waste management• Minimal impacts from the transportation of RRI fuel salt (initial loading, maybe small make-up quantities)• Radiological health impacts (10 CFR Part 20 exposure analysis, annual population dose, non-human biota dose)• Postulated accidents• Minimal radiological waste• Impacts from transportation of returned DOE RRI fuel salt

• MSRR Decommissioning• MSRR disposition (minimal impact)

Timing of SERC demolition is not related to MSRR decommissioning.Does the NRC agree that the SERC demolition is not a connected activity?

Licensing Approach

Scope & Depth of ER• An acceptable Scope of a research reactor ER is given in the ISG to

NUREG 1537• The Depth of an ER is dependent on project size and complexity• “For example, construction and operation of a new nuclear facility at a previously

undisturbed site near sensitive environmental resources would require more detail than construction and/or modification and operation of a facility within an existing building at an industrial site.”

• There can be LARGE differences between EA and EIS levels of detail• Available examples vary widely• University TRIGA relicensing (EA)• Medical isotope facility commercial projects like SHINE and NWMI (EIS)

• NUREG 1478 ER Guidance for Licensing Actions

Licensing Approach

NUREG-1748 ER Guidance for Licensing Actions• 3 Preparing an EA• The level of assessment should be commensurate with the anticipated impacts

and the degree of public concern• 3.3 EA for Simple Licensing Actions• “Describe how the proposed action complies with appropriate regulations and

brief supporting statement describing minimal impacts, e.g., ‘Public exposure to radiation will be less than _% of the limits in 10 CFR 20’ “

• 3.4.6 Environmental Impacts• From the list of 10 typical impacts, MSRR is limited to “Increased radiation dose to

workers and/or members of the public”• 3.4.6.3 Evaluation of Significance• 10 questions that must be answered “no” but MSRR may be limited to two• Are there undesirable public health or safety effects?• Are the impacts on the quality of the human environment controversial?

• 3.4.7 Mitigation Measures• Appropriate monitoring and license requirement for mitigation measures should

be identified

Is there any reason to believe that the Federal action for this project will NOT be an EA (FONSI or mitigated FONSI)?

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9/29/20 First Public Meeting to Discuss Licensing Topics 28

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