ML17255A004
| ML17255A004 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 09/07/2017 |
| From: | Cummings K, Grobe J Exelon Corp, Nuclear Energy Institute |
| To: | Office of Nuclear Reactor Regulation |
| Golla J, NRR/DPR, 301-415-1002 | |
| References | |
| Download: ML17255A004 (21) | |
Text
Accident Tolerant Fuel Developing an Efficient Approval Process Kristopher Cummings Sr. Project Manager, Fuel and Decommissioning Jack Grobe Director, Strategic Projects Exelon September 7th, 2017 Rockville, MD
AGENDA
- NEI Committee Structure for ATF
- Regulatory Framework for ATF Fuel Qualification
- Conclusions and Path Forward 2
Desired Outcomes A mutual commitment to develop an approach that will support more timely fuel qualification and licensing for ATF A common understanding on use and implementation of LTR/LTA programs for ATF along with steps/schedule to formalize this understanding.
Communication of industry proposed process for the development of an efficient and reliable pathway for ATF Fuel Qualification Common understanding of NRC ATF Project Plan Agreement to quarterly meetings between NRC ATF Steering Committee and NEI ATF Fuel Licensing Task Force 3
NSIAC GAAC Accident Tolerant Fuel Working Group (ATFWG)
Mission: Guide Industry Policy and Actions on ATF Executive Sponsor: Joe Grimes, TVA NEI Sponsoring Executive: Pamela Cowan NEI Sponsoring Director: Rod McCullum NEI Staff Lead: Andrew Mauer EPRI ATF Research Collaboration Mission: Foster Research Cooperation and Collaboration Al Csontos, EPRI National Labs Universities International CAC ATF External Affairs Task Force Funding and Schedule Acceleration Andrew Mauer/Bruce Montgomery, NEI Tom Craig, Duke Energy Corporation Exelon Generation Company, LLC Tennessee Valley Authority Duke Energy Corporation Entergy Operations, Inc.
Southern Nuclear Operating Company Dominion Generation Arizona Public Service Company Xcel Energy GE Hitachi Nuclear Energy AREVA Inc.
Westinghouse Electric Company Lightbridge Corporation General Atomics Jensen Hughes Electric Power Research Institute Nuclear Energy Institute ATF Fuel Licensing Task Force Fuel Qualification to Deployment Kris Cummings, NEI Jack Grobe, Exelon Generation Company, LLC Regulators ATF Safety Benefits Task Force Realization of Regulatory Benefits Kris Cummings, NEI John Williams, Southern Nuclear Operating Company Utilities Fuel Vendors 4
ATF Concepts Under Development
- One design by Lightbridge under development outside DOE cost-share program.
Si-C composite cladding U3Si2 high density fuel Fe-Cr-Al cladding Conventional UO2 fuel Cr-coated zircaloy cladding Chromium doped UO2 Metallic uranium alloy 5
ATF Path Forward 6
REGULATORY FRAMEWORK FOR ACCIDENT TOLERANT FUEL LEAD TEST ASSEMBLIES AND RODS 7
HISTORY
- Handling, irradiation and storage of Lead Test Assemblies and Rods (LTAs) has been implemented for decades
- Technical Specification 4.2.1 permits the irradiation of LTAs in the reactor core for:
o A limited number of LTAs that have not completed representative testing o Placed in a non-limiting core regions
- LTA Programs are an authorized activity in the facility license 8
HISTORY - Contd
- Licensees planning near-term ATF LTA programs have scheduled meetings with NRR technical staff to discuss the program:
o Southern (Hatch) meeting with NRR regarding Spring 2018 insertion of ATF LTAs with UO2 fuel and ferritic steel cladding in June 2017 o Exelon (Byron) meeting planned with NRR regarding Spring 2019 insertion of ATF LTAs with U3Si2 fuel and chromium coated zircaloy cladding in October 2017
IRRADIATION OF LTAs IN THE CORE
- Engineering design control process under 10CFR50, Appendix B o Design and safety analysis supporting irradiating LTAs in the core performed under the design control process Confirms the safety basis for the LTAs
- Authorized activity under TS 4.2.1 o. A limited number of lead test assemblies that have not completed representative testing may be placed in non-limiting core regions.
Purpose of irradiating LTAs in the reactor is to collect data and validate performance Codes and methods do not need to have been submitted to NRC 10
LTAs IN THE CORE - Contd
- All facility design changes enter the station 10CFR50.59 process o Reactor core irradiation of LTAs is an authorized activity under the operating license - TS 4.2.1 o 10 CFR 50.59 process is exited since further NRC authorization is not necessary for reactor core irradiation of LTAs 11
LTAs IN THE CORE - Contd
- 10 CFR 50.46 Acceptance Criteria for Emergency Core Cooling Systems for Light-Water Nuclear Power Reactors o Each light-water nuclear power reactor fueled with uranium oxide pellets within cylindrical zircaloy or ZIRLO cladding o This regulation establishes the ECCS criteria for cores of fuel that are comprised of uranium oxide pellets within cylindrical zircaloy or ZIRLO cladding o Therefore, an exemption to 10CFR50.46 is not necessary for fuel that is not uranium oxide pellets within cylindrical zircaloy or ZIRLO cladding 12
STORAGE OF LTAs
- Depending on facility design ATF LTAs will need to be stored in dry and/or wet storage locations before and after irradiation
- As long as the design control process concludes that ATF LTAs/LTRs are bounded by the current analysis, they may placed in the storage areas.
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HANDLING OF LTAs/ PROCEDURE CHANGES
- LTA programs may involve changes in handling equipment and/or plant procedures:
o Any necessary changes would be evaluated, reviewed and approved under the facility design change process or procedures management process o Changes in fuel handling equipment/procedures from that described in the facility Updated Safety Analysis Report would be evaluated under 10CFR50.59 to determine whether NRC review and approval of the change would be required.
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ACCIDENT TOLERANT FUEL FUEL QUALIFICATION REGULATORY FRAMEWORK 15
ATF FUEL QUALIFICATION ROADMAP 16
Key Activities - Remainder of 2017
- Alignment and stability of LTA Regulatory Framework
- Development and Alignment of Regulatory Roadmaps with NRC ATF Project Plan o ATF Fuel Qualification (10 CFR Part 50) o ATF Fabrication (10 CFR Parts 70, 73 and 74) o ATF Transportation (10 CFR Part 71)
- Identification of Areas for Rulemaking 17
Regulations
- 10 CFR 50.46 - ECCS performance criteria for non-zirconium/UO2 fuel
- 10 CFR 50.68 - 5 wt% enrichment limit for the spent fuel pool
- Appendix A (GDC 35) - language specific to fuel and clad and clad metal-water reaction
- Evaluation of regulations continuing 18
Conclusions and Path Forward
- ATF provides a significant safety advancement to the current fleet of light-water reactors
- More timely fuel qualification and licensing is needed to support approval and implementation of ATF designs by early to mid-2020s
- Near-term alignment and stability of LTA Regulatory Framework is needed.
- Continued engagement will be key to making progress 19
Questions?
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- ATR - Advanced Test Reactor
- CFR - Code of Federal Regulations
- GDC - General Design Criteria
- TREAT - Transient Reactor Test Facility 21