ML18057A189
| ML18057A189 | |
| Person / Time | |
|---|---|
| Issue date: | 02/27/2018 |
| From: | Proffitt J Office of Nuclear Reactor Regulation |
| To: | |
| Proffitt J | |
| References | |
| Download: ML18057A189 (16) | |
Text
February 27, 2018 I. Brief outline of ATF project plan II. Overview of comments received III. Path forward 2
- Developed and maintained by the ATF steering committee and working group
- Outlines activities associated with preparing the agency to conduct efficient and effective reviews of ATF designs
- Includes preliminary estimates of lead time necessary to complete activities in each area
- Intended to be a living document 3
- Assumptions
- Open items
- Stakeholder interactions
- Initiating staff activities
- Preparatory activities:
- Regulatory framework, In-reactor performance
- Fuel cycle, transportation and storage regulatory framework
- PRA activities
- Analysis capability development 4
- Draft plan published in the Federal Register on December 21, 2017 for 45 day public comment period
- Received nearly 80 comments from
- U.S. Department of Energy (DOE)
- Louisiana Energy Services (UUSA)
- Nuclear Energy Institute (NEI)
- Pressurized Water Reactor Owners Group (PWROG)
- General Atomics
- Southern Nuclear Company
- Westinghouse Electric Company
- three individuals 5
Draft ATF Project Plan Public Comments Licensing Process 3% Licensing Process Codes 4%
4% Coordination/Communication 4% 20%
PRA Timeline 5% Evolutionary/Revolutionary General LTAs 6%
Lead Test Assemblies 13% Codes Timeline 8% Regulatory Framework General Resources 10% 12% Data/Testing 10% Coordination/ Transportation Evolutionary/Revolutionary Communication Adv Rx PRA 6
- Concerns with regulatory requirements associated with lead test assemblies
- Emphasize importance of communication and coordination
- Evolutionary vs. revolutionary
- Does not support industrys deployment schedule
& staff not employing a graded approach
- Opportunity to transform fuel licensing process
- Leverage DOE/advanced computational capabilities 7
- Comment
- Lack of clarity on current requirements
- NRC response
- Outside scope of ATF project plan
- Separate NRC steering committee actively working to address 8
- Comment
- Appreciate NRCs project plan effort
- Key to meeting implementation schedule
- NRC response
- Plan relies on early engagement
- Staff committed to continue
- Will seek to enhance 9
- Comment
- Oversimplification
- Creates uncertainty
- NRC response
- Project plan is technology independent
- Concept-specific licensing roadmap developed based on PIRT
- Remove evolutionary and revolutionary distinction to improve clarity 10
- Comment
- Plan does not support industrys deployment schedule
- Staff not employing a graded approach
- NRC response
- The plan did not present a schedule but rather individual activities, many of which can proceed in parallel
- The staff is committed to minimizing the lag between the time required to establish the technical bases for safe operation and the completion of licensing activities
- PIRTs will inform the licensing roadmaps for individual concepts
- PIRTs will facilitate employing a tailored approach for each concept, thus enabling a graded approach 11
old & new old new development of regulatory infrastructure technical basis development of time regulatory development infrastructure*
licensing activities licensing activities
- as needed 12
ATF Project Plan Cr-coated Steel (FeCrAl) SiC Metallic U3Si2 Fuel Cladding Cladding Cladding Fuel Concept Concept Concept Concept Concept Licensing Licensing Licensing Licensing Licensing Roadmap Roadmap Roadmap Roadmap Roadmap Steel Steel (FeCrAl) (FeCrAl) SiC SiC Vendor 1 Vendor 2 Cladding Cladding Licensing Licensing Vendor 1 Vendor 2 Approach Approach Licensing Licensing Approach Approach 13
- Comment
- ATF presents an opportunity to transform
- NRC response
- Staff continually evaluating potential efficiencies
- Expediting regulatory guidance
- Use of vendor inspections to verify data intended to support licensing activities (e.g., topical reports)
- Change processes for topical reports
- Leveraging the use of DOE/commercial codes
- Staff is open to other specific suggestions 14
- Comment
- Use DOE codes in lieu of developing independent NRC capability
- Use advanced simulation techniques in lieu of experimental data
- NRC response
- Need for confirmatory calculations
- Depends on the strength of the technical basis presented by the applicant
- Use of non-NRC codes
- Staff and licensees have used the same codes in the past (e.g., Fluent for dry storage casks)
- Effectiveness and efficiency of using a non-NRC codes depends on many factors (e.g., readiness of existing NRC codes, V&V needs of non-NRC codes, learning curve for the non-NRC codes)
- Simulations in lieu of experimental testing
- At this time, the staff is not aware of any computational tool that obviates the need for experimentation to support licensing decisions
- Staff is receptive to addressing this issue as the state of the art warrants it 15
- Provide staff response to all comments in publically available document
- Incorporate changes to the project plan
- Finalize plan mid-2018
- Continue engagement with stakeholders
- Maintain project plan as living document 16