ML18038B080

NEI Letter on Regulatory Path for Introduction of Lead Test Assemblies (Ltas) in Commercial Nuclear Reactors

ML18038B080
Person / Time
Site:	Nuclear Energy Institute
Issue date:	05/19/2017
From:	Mauer A Nuclear Energy Institute
To:	Mirela Gavrilas NRC/NRR/DSS
References
Download: ML18038B080 (2)

Text

ANDREW MAUER Technical Advisor, Nuclear Generation 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8018 anm@nei.org nei.org May 19, 2017 Dr. Mirela Gavrilas Director, Division of Safety Systems Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

Subject:

Regulatory Path for Introduction of Lead Test Assemblies 1 in Commercial Nuclear Reactors Project Number: 689

Dear Dr. Gavrilas:

On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI) 2 wishes to thank the U.S. Nuclear Regulatory Commission (NRC) for providing clarification on the existing regulatory provisions for the introduction of lead test assemblies (LTAs) into commercial nuclear reactors during the Accident Tolerant Fuel (ATF) panel at the 2017 Regulatory Information Conference. The presentation materials and discussions led by Mr. Paul Clifford were informative and supportive of the industrys preparation for the introduction of LTAs of ATF designs in the near future. Establishing clarity and regulatory certainty is important to avoid unnecessary expenditure of NRC and industry resources.

The purpose of this letter is to request confirmation of the following NRC positions expressed during Mr.

Cliffords presentation to assure transparency, regulatory certainty and predictability:

• Certain 10 CFR Part 50 licenses contain Technical Specifications allowing for the irradiation of a limited number of LTAs in non-limiting core regions.

o The number of LTAs may be determined by the licensee based on engineering judgement, and on codes and methods that have not been submitted to the NRC for review and approval.

o The core region for locating the LTAs may be determined by the licensee based on engineering judgement, and on codes and methods that have not been submitted to the NRC for review and approval.

1 In the context of this letter, the nomenclature lead test assembly is intended to encompass both lead test assemblies and lead test rods.

2 The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.

Dr. Mirela Gavrilas May 19, 2017 Page 2

• An exemption to 10 CFR Part 50.46 (or 10 CFR Part 50.46c, if finalized) is not required for LTAs irradiated under these Technical Specification provisions.

We request a response from NRC confirming these key regulatory positions by June 16th, 2017 to support the industrys plans for the introduction of LTAs in commercial operating plants in spring 2018.

Please contact me or Kristopher Cummings (kwc@nei.org) if you have any questions regarding this letter.

Sincerely, Andrew Mauer c: Ms. Shana Helton, NRR/DSS, NRC Mr. Paul Clifford, NRR/DSS, NRC Mr. Brian Benney, NRR/DPR/PLPB, NRC