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
6 20%
13%
12%
10%
10%
8%
6%
5%
4%
4%
4% 3%
Draft ATF Project Plan Public Comments Licensing Process Codes Coordination/Communication PRA Evolutionary/Revolutionary General Lead Test Assemblies Timeline Regulatory Framework Resources Data/Testing Transportation Adv Rx Codes Coordination/
Communication Evolutionary/Revolutionary Licensing Process General LTAs Timeline PRA
- 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
12 technical basis development development of regulatory infrastructure licensing activities licensing activities development of regulatory infrastructure*
old & new old new time
- as needed
13 ATF Project Plan
Cr-coated Cladding Concept Licensing Roadmap Steel (FeCrAl)
Cladding Concept Licensing Roadmap U3Si2 Fuel Concept Licensing Roadmap SiC Cladding Concept Licensing Roadmap Metallic Fuel Concept Licensing Roadmap SiC Cladding Vendor 1 Licensing Approach SiC Cladding Vendor 2 Licensing Approach
Steel (FeCrAl)
Vendor 1 Licensing Approach Steel (FeCrAl)
Vendor 2 Licensing Approach
- 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