ML19276D420
| ML19276D420 | |
| Person / Time | |
|---|---|
| Issue date: | 09/17/2019 |
| From: | Kent Howard Advisory Committee on Reactor Safeguards |
| To: | |
| Howard, K, ACRS | |
| References | |
| NRC-0571 | |
| Download: ML19276D420 (117) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Metallurgy and Reactor Fuels Subcommittee Docket Number: (n/a)
Location: Rockville, Maryland Date: Tuesday, September 17, 2019 Work Order No.: NRC-0571 Pages 1-88 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +
7 METALLURGY AND REACTOR FUELS SUBCOMMITTEE 8 + + + + +
9 TUESDAY 10 SEPTEMBER 17, 2019 11 + + + + +
12 ROCKVILLE, MARYLAND 13 + + + + +
14 The Subcommittee met at the Nuclear 15 Regulatory Commission, Two White Flint North, Room 16 T2D10, 11545 Rockville Pike, at 1:00 p.m., Ronald G.
17 Ballinger, Chair, presiding.
18 19 COMMITTEE MEMBERS:
20 RONALD G. BALLINGER, Chair 21 MICHAEL L. CORRADINI, Member 22 VESNA B. DIMITRIJEVIC, Member 23 WALTER L. KIRCHNER, Member 24 DAVID PETTI, Member*
25 HAROLD B. RAY, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 JOY L. REMPE, Member 2 PETER RICCARDELLA, Member*
3 MATTHEW W. SUNSERI, Member*
4 5 DESIGNATED FEDERAL OFFICIAL:
6 KENT HOWARD 7
8 *Present via telephone 9
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3 1 T-A-B-L-E O-F C-O-N-T-E-N-T-S 2 PAGE 3 Opening Remarks 4 4 Update on ATF Activities by Jason Drake 8 5 Chromium-Coated Cladding Draft ISG 6 by Josh Whitman 16 7 Overview of Industry ATF Working Group 8 by Nima Ashkeboussi 48 9 Comments on Chromium-Coated Cladding Draft ISG 10 by Ben Holtzman 51 11 Adjourn 88 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 P R O C E E D I N G S 2 1:00 p.m.
3 CHAIR BALLINGER: Good afternoon. The 4 meeting will now come to order. I'm Ron Ballinger, 5 Chairman of the Metallurgy and Reactor Fuels 6 Subcommittee. This afternoon, the subcommittee will 7 hear presentations on the Draft Interim Staff Guidance 8 ATF-ISG-01 that will facilitate the staff's 9 understanding of the in-reactor phenomena important to 10 the safety for the chromium-coated zirconium alloy 11 fuel cladding concept being pursued by several fuel as 12 part of the U.S. DOE accident tolerant fuel program.
13 ACRS members are Harold Ray, Mike 14 Corradini, Joy Rempe, Walt Kirchner, and Vesna 15 Dimitrijevic. And I believe that Dave Petti and Pete 16 Riccardella are on the line.
17 MEMBER RICCARDELLA: This is Pete. I'm 18 here, Ron.
19 CHAIR BALLINGER: Good enough. Dave?
20 MEMBER PETTI: I'm here.
21 CHAIR BALLINGER: Oh, so Pete got his 22 sandwich. Kent Howard of the ACRS staff is the 23 designated federal official for this meeting. This 24 afternoon, we will hear presentations from the Office 25 of Nuclear Reactor Regulation and the Nuclear Energy NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 Institute. And I think there's an EPRI presenter too, 2 part of it, regarding the draft ISG.
3 The ACRS was established by statute and 4 it's governed by the Federal Advisory Committee Act, 5 FACA. The NRC implements FACA in accordance with its 6 regulations found in Title 10 CFR Part 7. The 7 committee can only speak through its published letter 8 reports.
9 We hold meetings to gather information and 10 preform preparatory work that will support our 11 deliberations at a full committee meeting. The rules 12 of participation in all ACRS meetings, including 13 today's, were announced in the Federal Register on 14 June 13th, 2019.
15 The ACRS section of the U.S. NRC public 16 website provides our charter bylaws, agendas, letter 17 reports, and full transcripts of all full and 18 subcommittee meetings, including slides presented.
19 The meeting notice and agenda for this meeting were 20 posted there. Portions of this meeting can be closed, 21 which I don't think so, as needed to protect 22 proprietary information pursuant to 5 U.S.C.
23 552(b)(4).
24 As stated in the Federal Register notice 25 and in the public meeting notice posted to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 website, members of the public who desire to provide 2 written or oral input to the subcommittee may do so 3 and should contact the designated federal official, 4 that would be Kent Howard, five days prior to the 5 meeting as practical. We have also set aside ten 6 minutes for comments from members of the public 7 attending or listening at our meetings.
8 We have not received comments or requests 9 for time to make oral statements from members of the 10 public regarding today's meeting. A transcript of the 11 meeting is being kept and will be made available on 12 the ACRS section of the U.S. NRC public website.
13 We request that participants at this 14 meeting please use the microphones located throughout 15 the meeting room when addressing the subcommittee.
16 And make sure the green light is on by using the 17 little push thing down at the bottom.
18 Participants should first identify 19 themselves and speak with enough volume and clarity so 20 that they can be readily heard. A telephone bridge 21 line has been established for the public to listen to 22 the meeting. To minimize disturbance of the public 23 line, the public line will kept in a listen-only mode.
24 To avoid disturbance, I request that the attendees put 25 their electronic devices or cell phones in the noise-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 free mode.
2 We'll now proceed with the meeting and 3 call on Jane Marshall to begin the presentations.
4 It's up to you.
5 MS. MARSHALL: Thank you. Good afternoon, 6 Dr. Ballinger, members of the subcommittee. Thank you 7 for your time this afternoon for staff to share with 8 you our progress on the draft version of interim staff 9 guidance that we're developing to assist staff in 10 reviewing chromium-coated cladding ATF applications.
11 The guidance is based on a phenomena 12 identification and ranking for PIRT exercise on 13 chromium-coated cladding which the staff commissioned 14 through Pacific Northwest National Lab in April of 15 this year.
16 This draft guidance is a key step in our 17 implementation of the NRC's AFT Project Plan which we 18 presented to you in February of last year. The 19 guidance is intended to provide direction to both 20 industry and NRC reviewers such that applicants 21 develop a high-quality submittal and the staff can 22 focus on the areas of highest safety significance in 23 reviews.
24 We recently held a public meeting to 25 discuss an earlier draft version of this guidance and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 to seek some initial stakeholder feedback on that 2 document. And we've worked to address the comments 3 that we received in that draft, and those are 4 incorporated in the draft that you have for review.
5 We look forward to a productive discussion 6 here with you today. And following this meeting, 7 we'll again refine our guidance prior to issuing it in 8 the Federal Register for an official public comment 9 period. The staff have targeted completion of the 10 guidance by the end of this calendar year in 11 anticipation of the first chromium-coated Topical 12 Report submittals in early calendar year 2020.
13 At this point, I'd like to turn it over to 14 Jason Drake who will kick off the staff's 15 presentation. Jason?
16 MR. DRAKE: Thank you, Jane. Good 17 afternoon, Dr. Ballinger, and members of the 18 subcommittee. My name is Jason --
19 CHAIR BALLINGER: Excuse me. I need to 20 correct an error. Matt Sunseri is also on the line.
21 MR. DRAKE: Okay.
22 CHAIR BALLINGER: Go ahead.
23 MR. DRAKE: No worries. My name is Jason 24 Drake. I'm the project manager for accident tolerant 25 fuel in the Office of Nuclear Reactor Regulation.
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9 1 Again, today we'll going over the -- presenting the 2 updates and development of the draft interim staff 3 guidance for chromium-coated cladding. With me today 4 presenting are Josh Whitman and Ashley Smith from the 5 Division of Safety Systems.
6 Slide here is key message that we'll be 7 covering throughout the presentation. First bullet 8 noted here, coating a zirconium alloy cladding can 9 impact fuel properties and specify acceptable fuel 10 design limits. More specifically, the PIRT will 11 address this in more detail. And Josh will be getting 12 into it about Slide 7.
13 Second bullet here notes that coated 14 cladding represents a modest departure from currently 15 operating fuel. That is to say vendors can rely on 16 current operating experience in the underlying 17 substrate property database to inform their analyses.
18 And the last bullet to note here is that 19 topical report submittals are expected in 2020. These 20 are vendor identified submittal dates starting in 2020 21 to support their batch loading targets by 2023.
22 We still have to develop the ATF Project 23 Plan that's noted here in this slide to outline 24 preparation strategy for ensuring the staff readiness 25 to perform timely licensing reviews. The ISG will NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 serve as the concept-specific licensing roadmap for 2 NRC staff reviews with applications involving fuel 3 products with chromium-coated zirconium alloy 4 cladding.
5 If you take a look at this illustration 6 here, it's in there distinct areas, blue, purple, and 7 orange arrows respectively. Blue is identified here 8 as ATF Concept Development. More specifically, that's 9 industry and issues which are DOE supported and 10 that'll help them inform their development of their 11 technical bases.
12 The purple areas here reference as the 13 PIRT and the refinement of regulatory infrastructure.
14 These are specific to NRC actions, noting that the ATF 15 Project Plan itself is comprehensive. But it's 16 anticipated that because of the modest departure from 17 current designs that the ISG will be sufficient to 18 support licensing actions. And then the Topical 19 Report and planned specific licensing actions, those 20 are just to identify the industry developed and NRC 21 reviewed actions.
22 CHAIR BALLINGER: Can you -- what does 23 refinement of regulatory infrastructure mean?
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11 1 want to speak to the ISG entirely or what?
2 MR. WHITMAN: So this is from the ATF 3 Project Plan. And I think it may have more parts for 4 some of the other technologies. But for this, I think 5 it's speaking primarily to this ISG.
6 MR. DRAKE: Right. It's supposed to --
7 yeah, it's supposed to be more comprehensive in the 8 totality of the project plan itself and not specific 9 for the ISG. We're just making a notation here that 10 we don't anticipate any infrastructure changes and the 11 ISG will be sufficient. Next slide.
12 So we noted before industry is pursuing 13 batch reloads of coated cladding in 2023 with three 14 major vendors developing concepts, again, DOE 15 supported. It's a very aggressive schedule with the 16 staff, a strategical position to support the 17 deployment.
18 The coating itself is extremely thin up to 19 approximately 20 microns in thickness. And the 20 application processes identified so far, physical 21 vapor deposition and cold-spray. And what that means 22 in the ISG is that, yes, you had to be scoped 23 appropriately in order to accommodate each one of the 24 vendor coating application concepts.
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12 1 licensing varies. That is to say what crediting is 2 sought by each vendor and initial licensing. And 3 that's again concept specific. And we know that LTAs 4 have -- the test assemblies have been deployed and 5 we're fully anticipating that the data acquired will 6 be incorporated into the TR submittal.
7 CHAIR BALLINGER: That was my question.
8 MEMBER REMPE: So I'm sorry, but I was 9 running late from another meeting. And I forgot the 10 beginning of the opening statements to acknowledge 11 that in accordance with our bylaws, I have reviewed 12 this topic in another forum by another agency --
13 MR. DRAKE: Okay.
14 MEMBER REMPE: -- or some aspects of this 15 topic. Thank you.
16 MR. DRAKE: Next slide. This is a vendor 17 example of coated cladding, some of their testing 18 results. And if we start at the right picture, this 19 illustrates the thickness of the coating compared 20 against substrate cladding. You can see -- well, it's 21 hard to depict from the picture.
22 But essentially, this is meant to 23 illustrate that no oxidation in the outer coated 24 diameter was presented when exposed to the high 25 temperature steam environment. If you look at the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 left during the first testing, there was a noticed 2 reduction and deformation in the small burst area.
3 We're about to build a foundation for the 4 ISG. This is supposed to be a -- it's a visual 5 comprehensive of all the interactions and the efforts 6 that have been taken to this point in the ISG. You'll 7 see up front that the Project Plan was issued in 2018 8 at a comprehensive stakeholder engagement and some 9 industry developed reports that were taken account 10 into the guidance development.
11 This is a highly coordinated effort 12 between NRC and stakeholders where the aggressive 13 scheduling to support initially timelines into that 14 2023 target. Noting down below the recent exchange in 15 July 2019 for initial ISG draft and then the August 16 6th public meeting.
17 Stakeholder comments were incorporated 18 into the draft revisions, and then obviously anything 19 the subcommittee brings up today as far as feedback is 20 concerned will be considered into the final product 21 development.
22 MEMBER REMPE: So in your program plan, 23 you mention an industry white paper on chromium-coated 24 cladding that's an important part of this information.
25 Is that the October 2018 analysis? Or what is that in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 this list of items? It's on page -- if you look at 2 the PDF, it's 13 out of 58. You --
3 MR. DRAKE: What we're doing in the ISG?
4 MEMBER REMPE: -- talked about what you're 5 doing, and it mentioned this --
6 MR. DRAKE: In the draft itself? Okay.
7 MEMBER REMPE: -- industry white paper.
8 MR. DRAKE: Josh, do you know exactly?
9 MR. WHITMAN: So there's an EPRI -- the 10 EPRI coated cladding gap analysis was included in the 11 development of the initial document that was sent to 12 all the participants, then eventually incorporated 13 into the final report as well as the NEI reactor 14 screening review. I'm not sure which one 15 specifically. I don't have the document up and I 16 don't have internet. So I can't get to it.
17 MEMBER REMPE: It's pretty vague, and I 18 just was curious --
19 MR. WHITMAN: Okay.
20 MEMBER REMPE: -- which of these it was.
21 But you're saying probably --
22 MR. WHITMAN: Yeah.
23 MEMBER REMPE: -- it's one of those two 24 but you're not quite sure?
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15 1 it, I'm not positive. Those documents as well as a 2 general literature review were incorporated into a 3 report that was sent to the PIRT participants to sort 4 of get them up to speed on what the PIRT was covering.
5 MR. DRAKE: Does that answer your 6 question?
7 CHAIR BALLINGER: Do we have that?
8 MR. WHITMAN: The --
9 CHAIR BALLINGER: That document?
10 MR. WHITMAN: Yes.
11 CHAIR BALLINGER: Because we have the gap 12 analysis report. That, I have. I wasn't sure about 13 the one you just referred to.
14 MR. WHITMAN: The PIRT?
15 CHAIR BALLINGER: We have the PIRT. But 16 you said you supplied --
17 MR. WHITMAN: So that initial report was 18 amended by the PIRT panel.
19 CHAIR BALLINGER: Okay.
20 MR. WHITMAN: It became the final. So 21 there's nothing in there that wasn't in the final 22 document.
23 MR. DRAKE: Okay. This is a good place to 24 turn it over then. So Josh -- I'll turn it over to 25 Josh Whitman. He'll go through that next slide.
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16 1 MR. WHITMAN: Okay. So thanks, Jason. So 2 the question leads right into this next slide. So in 3 April of this year, we convened the PIRT through a 4 contract with PNNL which consisted of participants on 5 the table on the right.
6 As you can see, we have individuals with 7 a range of expertise included on the panel, including 8 members from universities, national labs, multiple 9 industries. The panel was conducted publically to 10 enhance transparency to stakeholders. And the final 11 report of about 120 pages is available on ADAMS with 12 the ML number on the slide. So next slide.
13 So after reviewing the final report, we 14 created interim staff guidance based on the PIRT 15 findings. This guidance will supplement Chapters 4 16 and 15 of the standard review plan.
17 So first, I'll begin with some broad 18 statements on what the ISG does and does not do. The 19 ISG does provide guidance to the staff during reviews 20 of coated cladding Topical Reports and license 21 amendments and what areas are important to focus on 22 during their review.
23 It also provides fuel vendors and 24 licensees information on what the NRC staff expects 25 from industry submittals. But the ISG does not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 introduce any new requirements, rules, or regulations, 2 nor does it prescribe or require any specific testing 3 or analyses. Next slide.
4 So to broadly cover the scope of the ISG, 5 the ISG covers concepts being pursued by the three 6 fuel vendors as part of DOE's ATF program. Two 7 vendors are pursuing thin layers of chromium applied 8 to the outside of the existing full cladding. But the 9 third vendor is pursuing a proprietary coating.
10 The PIRT touched on this where possible, 11 although the public nature of the PIRT and the 12 proprietary nature of that coating has limited the 13 applicability of the PIRT somewhat. However, the ISG 14 does provide general guidance applicable to any 15 coating in addition to specific items on chromium 16 coatings.
17 So for these coatings, the ISG provides 18 the outline of what is expected to be addressed in the 19 Topical Report submitted to the NRC. In the ISG, the 20 narrative provides some guidance on what level of 21 effort is needed which may be dependent on many 22 factors but is especially dependent on whether the 23 benefits of the coatings are being credited in the 24 safety analysis.
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18 1 supplement the SRP. So Chapter 4 makes up the bulk of 2 the ISG and covers fuel properties and SAFDLs which 3 I'll be covering. And then Ash will cover Chapter 15 4 which makes up the remainder of the document.
5 So Appendix B of the ISG covers fuel 6 properties that should be addressed in licensing 7 submittals. These parameters impact figures of merit 8 for Chapter 15 analyses since they're used in 9 thermomechanical fuels codes as well as in 10 thermohydraulic systems codes.
11 On this slide and others, I've labeled 12 some items with asterisks that I'll touch on because 13 they may have a larger impact on the analyses.
14 Although I do want to clarify that the absence of an 15 asterisk doesn't mean that there's no potential 16 impact.
17 So going through the list, I think 18 emissivity is an interesting property because it's one 19 where the coating may negatively impact that the 20 accident progression while other properties are more 21 likely to either have a neutral or positive impact.
22 So in short, the chromium coatings will stay shiny 23 after developing a very thin layer of oxide which can 24 reduce heat transfer through thermal radiation during 25 accidents -- heat transfer to steam.
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19 1 Oxidation rate and hydrogen pick up as 2 well as high temperature steam oxidation are some of 3 the properties that vendors are hoping to improve with 4 the new coating technologies. And we've also see 5 preliminary information like the adjacent slide that 6 shows that the coatings may also improve ballooning 7 and burst behavior.
8 CHAIR BALLINGER: I was thinking about 9 that. And it's really the effect of a smaller 10 transform beta layer. I mean, during a LOCA, the 11 chromium, and during operation prevents oxidation and 12 prevents transport of oxygen through the -- into the 13 cladding. So that's the effect on ballooning 14 behavior. The chromium coating itself has no effect 15 on ballooning behavior. Is that correct?
16 MR. WHITMAN: Well, so we haven't actually 17 received any submittals from the vendors on these. So 18 there's only so much we can talk about. That when it 19 comes in, we'll see what they've credited and their 20 explanations.
21 MEMBER CORRADINI: But I guess he was 22 asking -- well, what I thought he was asking is, do 23 you know the mechanism --
24 CHAIR BALLINGER: Yes.
25 MEMBER CORRADINI: -- for the observation?
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20 1 Is there a mechanism agreed upon as to -- that 2 explains the qualitative observation?
3 MR. WHITMAN: Not that I'm aware of.
4 Like, as I said, we haven't received submittals. And 5 I would kind of expect them to go into details when we 6 finally get topical reports in.
7 CHAIR BALLINGER: Because there's two very 8 different explanations, if you will.
9 MR. WHITMAN: Understood.
10 CHAIR BALLINGER: The chromium coating 11 itself just prevents oxidation. It's not mechanically 12 -- there's not a mechanical effect.
13 MR. WHITMAN: Right.
14 CHAIR BALLINGER: But it prevents oxygen 15 transport into the cladding.
16 MEMBER REMPE: So your ISG discusses the 17 eutectic temperature of the chromium-coated cladding 18 at 1,332 C. So you covered it there. I'm surprised 19 this list doesn't have any other little bullet that 20 says, low temperature eutectics that could impact 21 performance. Because I don't know what's the 22 mysterious one that's proprietary and does it have 23 such a eutectic temperature so that you could address 24 everybody.
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21 1 talk more about the eutectic temperature specifically.
2 This is sort of a list of properties that are needed 3 primarily for the thermomechanical codes that'll need 4 to be updated by the fuel vendors but also for the 5 thermohydraulic codes. And right now, those codes 6 don't involve looking at a eutectic because it's --
7 MEMBER REMPE: Doesn't happen with 8 Zircaloy. So again, to be generic, I'd put another 9 bullet in there, low temperature reactions not 10 anticipated, or something like that, that could happen 11 at --
12 MEMBER CORRADINI: But it's over --
13 MEMBER REMPE: -- lower temperatures.
14 MEMBER CORRADINI: -- 2,200 Fahrenheit.
15 So why is it low? It's -- 1,333 is --
16 MEMBER REMPE: Well, it's a lower 17 temperature than melting is where I'm saying.
18 MR. WHITMAN: So that's included later in 19 the SAFDLs which --
20 MEMBER REMPE: Okay.
21 MR. WHITMAN: -- talk about the melting 22 temperature.
23 MEMBER REMPE: Okay.
24 MR. WHITMAN: So I think it's addressed 25 there.
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22 1 MEMBER REMPE: Okay.
2 MR. WHITMAN: But we can certainly take 3 that into account when we go and revise this before 4 putting out for public comment.
5 MEMBER REMPE: Well, you got it in the 6 ISG. I just was looking at the bullets and thinking.
7 Okay.
8 MR. WHITMAN: All right. Where was I?
9 Oh, okay. So another thing I wanted to point out on 10 this slide is that the PIRT identified that 11 manufacturing may have a first-order effect on some of 12 these parameters. And the NRC staff does not 13 anticipate needing to regulate the details of any 14 manufacturing process for the coatings. But at this 15 preliminary stage, we can't rule out the possibility 16 that some key parameters may need to be included in 17 the approval of the cladding.
18 So this next slide identifies some key 19 places where stakeholder input has been considered in 20 the properties appendix while drafting the ISG 21 already. During the PIRT, emissivity was not 22 identified as a key property that would have a 23 significant impact on the Chapter 15 analyses. But a 24 stakeholder pointed out that the external emissivity 25 is both important and also likely different for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 coated cladding concepts.
2 The PIRT suggested that cracked coating 3 should be tested to assess the oxidation rate of the 4 exposed substrate. And a stakeholder pointed out that 5 intentionally scratching the coatings may be a 6 necessary alternative if cracking the coating isn't a 7 feasible option.
8 CHAIR BALLINGER: I'm a little slow. Can 9 you back up one slide? Okay. Why is not cladding 10 coating thickness on that list? Because I've got some 11 familiarity with cold spray and other kinds of 12 coatings, and there's always a statistical 13 distribution on thickness. And that's got to make a 14 difference.
15 MR. WHITMAN: So I think that -- so this 16 is a list of sort of properties to be included in the 17 thermomechanical codes. And so the thickness goes 18 into how these properties are calculated. And the ISG 19 also goes into different ways of sort of evaluating 20 these.
21 So for example, thermoconductivity could 22 be evaluated as conductivity through the clad and then 23 another part that's conductivity through the coating.
24 Or it could be done as a bulk, what's the sort of 25 average conductivity through both.
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24 1 CHAIR BALLINGER: But you're expecting 2 that a submittal would deal with the uncertainties in 3 that cladding --
4 MR. WHITMAN: Absolutely, absolutely.
5 CHAIR BALLINGER: -- and coating 6 thickness?
7 MR. WHITMAN: Okay. So the only other 8 thing I wanted to mention on this slide is that there 9 was also some language that was tweaked to avoid 10 implying any specific testing requirements. Next 11 slide.
12 So Appendix C of the draft ISG lists 13 SAFDLs and other concerns and breaks them up into a 14 few categories. The first category is SAFDLs related 15 to assembly performance. And while these should be 16 addressed in submittals, the coatings aren't expected 17 to have a significant effect, positive or negative, on 18 many of these.
19 Fretting wear is the one item I start on 20 this list. This is a phenomena where historically the 21 concern has been where on the fuel cladding from the 22 spacer grids. But in this case, that effect may be 23 reversed and instead there may be damage -- there's 24 possibility that there could be damage to the spacer 25 grids from the hardness of the coating. Next slide.
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25 1 CHAIR BALLINGER: Back again. Fuel 2 assembly, lateral deflection, fretting wear, hydraulic 3 lift loads and the like, those all sort of speak to 4 any kind of testing that might have to be done to 5 address delamination or those kinds of things due to 6 bending or something like that. Member Corradini 7 whispered in my ear, but he's conflicted. And I also 8 talked with another one of the members who I know.
9 And was there an issue on the PIRT committee related 10 to how to test for delamination bending versus c-ring 11 testing or that kind of thing?
12 MR. WHITMAN: I'm not sure that there's a 13 -- so again, we don't try and lay out any specific 14 testing in the ISG that we're requiring.
15 CHAIR BALLINGER: But you have to show 16 that you don't get delamination or --
17 MR. WHITMAN: Right.
18 CHAIR BALLINGER: -- the coating stays on 19 in other words.
20 MR. WHITMAN: Right. And that's addressed 21 in, again, a later slide.
22 CHAIR BALLINGER: Okay.
23 MR. WHITMAN: But the ISG doesn't say, 24 you need to do bending testing, or anything like that.
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26 1 case has been made by the submittal. And that's done 2 intentionally because we don't want to put the vendors 3 in a box and make them do a certain testing when 4 perhaps some other form could be just as good.
5 MEMBER PETTI: But you have to demonstrate 6 the integrity of the coating?
7 MR. WHITMAN: I would certainly expect 8 that, especially if any of the benefits of the coating 9 are being taken that the integrity of the coating 10 would certainly be a major part of the review.
11 MEMBER REMPE: So if I read your ISG page 12 2 of 8, finally, if an applicant wishes to take credit 13 for coating behavior up to a certain burnup or during 14 certain accident conditions, it's necessary for the 15 adherence of that coating to the substrate to have 16 been justified for the full operating domain. That 17 sure implies testing to me up to a certain burnup, 18 doesn't it?
19 MR. WHITMAN: Well, it would certainly 20 imply testing, but not any specific --
21 MEMBER REMPE: It seems like you've got to 22 have radiation in there some way or other in that to 23 get that burnup, right?
24 MR. WHITMAN: I would expect it, yes.
25 MEMBER REMPE: Okay.
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27 1 CHAIR BALLINGER: By the way, for folks on 2 the phone, you need to identify yourself if you make 3 a comment so the recorder can know who it is.
4 MR. WHITMAN: So the next section of the 5 appendix covers SAFDLs related to rod performance 6 during normal operation in AOOs. And so to quickly go 7 through the starred items on the list, there's a 8 concern from the PIRT that excessive cladding strain 9 may lead to coatings cracking. And if this is found 10 to be the case, the existing SAFDLs may need to be 11 amended to protect against this behavior.
12 Fatigue lifetime was also identified in 13 the PIRT as a potential area for degraded performance 14 of the coated claddings due to findings from study 15 that was reviewed. And so that's something that 16 should be addressed.
17 Oxidation and hydrating may have improved 18 performance versus the uncoated cladding. But 19 regardless, the existing oxidation and hydrating 20 models almost certainly don't apply. And so therefore 21 the oxidation hydrating SAFDLs should be addressed in 22 the submittal.
23 And then finally, the PIRT identified that 24 these coatings may affect the bubble nucleation 25 behavior of the cladding. And so it's important that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 1 boiling crises be addressed. Next slide.
2 And so we also considered some stakeholder 3 comments on this section of the draft ISG. There was 4 some conflicting discussions about boiling crises in 5 the PIRT and that made their way into the ISG. And so 6 those have been clarified in the draft you guys have 7 seen.
8 And then additionally some general 9 questions were made to clarify the testing 10 expectations. And we don't believe that this is 11 something that we really can or should be trying to do 12 with this document. The level of testing required to 13 make a safety finding is going to depend on a large 14 number of variables, most of which are unknown to the 15 staff at this point or at the very least vary from one 16 vendor to the next.
17 So we also want to make sure that they're 18 not being overly prescriptive -- we're not being 19 overly prescriptive or preventing vendors from 20 addressing data needs in an innovative manner. So we 21 tried to leave things open ended while providing 22 guidance in the narrative that will help the reviewer 23 determine what level of testing is necessary to make 24 a safety finding. Next slide.
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29 1 covers SAFDLs related to rod performance during 2 accidents. There are more stars here for hopefully 3 obvious reasons. With accident tolerant fuel, you'd 4 expect more changes to their accident performance.
5 Cladding overheating should be impacted --
6 could be impacted by changes to the boiling crisis 7 behavior mentioned previously. And the balloon and 8 burst behavior seems to be affected based on 9 preliminary data that we've seen.
10 For cladding embrittlement, the PIRT also 11 pointed to the possibility of embrittlement due to 12 some unknown zirc-chrome interdiffusion. And then 13 clad melting is included because the PIRT raise the 14 possibility of a chrome-zirc eutectic that may form 15 that would need to be considered. And I'll talk about 16 that a little bit more on the next slide.
17 MEMBER REMPE: But --
18 MEMBER PETTI: So I can ask? This is Dave 19 Petti. In terms of cladding embrittlement, did the 20 PIRT identify radiation embrittlement of the chrome 21 itself as a potential problem?
22 MR. WHITMAN: Yeah. So I'm sort of 23 summarizing a relatively large subsection there. But 24 I think the -- basically, regardless of where the 25 embrittlement comes from, the embrittlement needs to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 be addressed and tested.
2 MEMBER KIRCHNER: Did the PIRT come to a 3 conclusion about the -- let's see. These are mainly 4 going to be PWR rods, right? So DNB and CHF. Did 5 they feel that the CHF correlations had to be 6 revisited?
7 MR. WHITMAN: Yeah, I don't think so. I 8 think the PIRT identified them as an area that needs 9 to be addressed. And there's a lot of different ways 10 that they could do it. I think comparative testing is 11 an area where a lot of these properties may be 12 addressed. And so showing that a coated and uncoated 13 rod behaviors similarly is probably sufficient.
14 MEMBER CORRADINI: So from an 15 informational standpoint, that's what's been done is 16 samples with and without the coating with different 17 corrosions have been tested. And they're -- on a 18 relative basis, they look about the same.
19 MEMBER KIRCHNER: About the same. Thank 20 you.
21 MEMBER CORRADINI: But not what I think 22 you want which is prototypical testing. Not yet.
23 MEMBER KIRCHNER: I assume they did just 24 the cladding.
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31 1 back to my earlier question because I guess this is 2 where you said, we'll generalize melting. But with 3 the high temperature oxidation, you went up to 1,200 4 C. What if they have some sort of eutectic that is 5 above operating temperature but is not considered 6 accident conditions? I'm just wondering did you 7 really cover it all. Do you think so?
8 MR. WHITMAN: So I don't think that that 9 eutectic exists for what's being currently proposed by 10 the vendors.
11 MEMBER REMPE: You don't think, but I'm 12 looking at the generic one that we don't know what the 13 material is.
14 MR. WHITMAN: Yeah, so it's difficult with 15 this because of the proprietary nature of that 16 coating. The PIRT was definitely geared towards the 17 type of coating that proprietary coating is. I want 18 to be really careful about -- I know I sound cagey 19 talking about it. But that specific concern isn't 20 more of a concern for that than it is for the --
21 MEMBER REMPE: The others.
22 MR. WHITMAN: -- elemental chrome coated.
23 MEMBER REMPE: Joe comes in with new super 24 duper ATF that you've not seen that's got some sort of 25 coating. And I'm thinking of just how generic do you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 want to be. And maybe it's not going to be an issue.
2 MR. WHITMAN: Yeah.
3 MEMBER REMPE: You hope it wouldn't, but 4 --
5 MR. WHITMAN: Yeah, it's difficult because 6 we had to draw a box somewhere on what's covered and 7 what isn't covered. And this, we sort of chose to 8 draw it around what's currently being proposed. And 9 certainly, there could be future coatings that have 10 some -- can take some benefit from the -- or this 11 applies somewhat but not in other areas. But we had 12 to draw a box because we need to be able to get this 13 document out.
14 MEMBER REMPE: Was the PNNL heard the 15 first time that this low temperature eutectic was 16 identified? Or was it identified by DOE already and 17 they were aware of a vender already and they were 18 aware this would happen?
19 MR. WHITMAN: I believe it was previously 20 identified. I'm not sure to what level who identified 21 it and what level it's addressed.
22 CHAIR BALLINGER: The zirconium-chromium 23 phase diagram is well known.
24 MR. WHITMAN: Exactly, yeah.
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33 1 issue would be a zirconium-niobium-chromium phase 2 diagram where if you have two and a half, three 3 percent or so niobium, now that's enough to have an 4 effect. And I didn't see -- I saw M5 and things. But 5 I didn't see a discussion of whether there might be 6 some unknown phase that forms that's still melting for 7 that system. Although I'm probably sure that our 8 friends in Russia probably know.
9 MR. WHITMAN: That's --
10 CHAIR BALLINGER: Well, no, they use --
11 we're not talking about bad stuff here. They've been 12 using zirconium-niobium cladding forever.
13 MR. WHITMAN: That's something we can look 14 into for the next draft of the ISG. I don't believe 15 that was covered by the PIRT. So the next slide.
16 So we'll get into the eutectic a little 17 bit more on this slide as well. But the final section 18 of Appendix C covers new degradation mechanisms and 19 other topics raised by the PIRT. These new 20 degradation mechanisms need to be addressed in the 21 submittals to the NRC. And for each mechanism, this 22 could mean either showing that they won't occur, 23 showing that existing SAFDLs protect against them, or 24 proposing new SAFDLs or adjusting existing SAFDLs to 25 ensure that these degradation mechanisms aren't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 1 encountered.
2 I'll also note that some of these are more 3 important if credit is taken for improved performance.
4 For example, the chromes are eutectic in form, but it 5 has a melting point greater than 2,200 degrees 6 Fahrenheit. So if a vendor wants to take credit for 7 the improved performance at higher temperatures and 8 try and raise the permissible LOCA PCT, this would be 9 something that we would expect would need to be 10 addressed in greater detail.
11 Finally, I'll point out that some of these 12 are also called out in the draft ISG as being a larger 13 concern for certain application methods. Just to give 14 an example, subsurface damage is likely to be highly 15 process dependent.
16 And so if you guys don't have any more 17 questions, I'll turn the presentation over to Ashley 18 Smith who will walk through the portion of ISG that 19 covers Chapter 15.
20 MEMBER KIRCHNER: But your PIRT did not --
21 I don't see any asterisks on this slide, so --
22 MR. WHITMAN: Yeah, these are all 23 asterisks.
24 MEMBER KIRCHNER: They are all asterisks?
25 Okay.
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35 1 MR. WHITMAN: Yes, sorry. These are the 2 new mechanisms that need to be considered, so --
3 MEMBER KIRCHNER: But I think the 4 definition of the asterisk prior to this was 5 significant. Are any of these significant? Or do you 6 think they just all have to be addressed?
7 MR. WHITMAN: Well, I think they all need 8 to be addressed at certain levels. I mean, if a 9 vendor can show through an extreme test that the 10 coating never delaminates, that could be sufficient to 11 satisfy that.
12 MEMBER KIRCHNER: And to me, that one in 13 particular would stand out. That's why --
14 MR. WHITMAN: Yeah.
15 MEMBER KIRCHNER: -- I was fishing in my 16 questions. Thank you.
17 MEMBER PETTI: Can I just ask a broader 18 question? You seem very focused here on the operation 19 and the potential accident and the credit a vendor 20 might take. But does the purview -- NRC safety 21 purview consider things like during refueling as 22 you're moving assemblies around? If any of these 23 things delaminate because of the movement, that's 24 something I would think the utility would want to know 25 about. And so is the testing that comprehensive that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 1 it's going to look at those sorts of events as well?
2 MR. WHITMAN: Again, we haven't specified 3 any specific testing that would be done. I think that 4 a fuel handling accident is something that needs to be 5 considered during licensing analysis as a part of a 6 license amendment. And so that's something that could 7 come up there. And I would expect that if the coating 8 doesn't delaminate during normal operation, AOOs, or 9 accidents, that it would also hold on during core 10 reshuffles.
11 MEMBER REMPE: So in your program plan, 12 you emphasize the importance of earlier NRC 13 involvement. When you did this PIRT, I mean, I know 14 it says new. But that's with respect to -- different 15 from the Zircaloy-based cladding. Did you guys 16 identify anything new that had not been already 17 addressed by industry or DOE?
18 MR. WHITMAN: So I think it's difficult to 19 know what was addressed before the PIRT because we 20 don't have a submittal. Certainly, a lot of this is 21 stuff that I'm sure -- and I'll say hopefully all of 22 this is stuff that the vendors were already looking 23 at. I don't know if they'd come to us and say, oh, we 24 hadn't thought of that.
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37 1 thought -- I was hoping that they -- you looked at 2 their papers and you could say none of their papers 3 talked about this mechanism when we started that PIRT 4 but it came up afterwards. But you don't have that?
5 MR. WHITMAN: Well, it's difficult because 6 a fair bit of this is proprietary as well. There is 7 some public information that's been released of things 8 like Top Fuel that were considered in the document 9 that was sent out before the PIRT. And so that sort 10 of formed the basis for a lot of this discussion. And 11 I know Korousch was on the PIRT panel. And at MIT, 12 they had actually procured some samples of cold spray 13 coated cladding and run them through some tests 14 themselves and then formed the PIRT. But does that 15 answer your question?
16 MEMBER REMPE: Yeah.
17 MR. WHITMAN: Okay.
18 MS. SMITH: The discussion up to this 19 point has covered SRP Chapter 4. I'm going to cover 20 how the ISG supplements the SRP Chapter 15 analyses 21 and accidents.
22 As described previously, coating cladding 23 may impact the cladding's material properties and 24 mechanical and thermal behavior. These changes should 25 be incorporated where necessary in the Chapter 15 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 1 demonstration.
2 The reviewer should also ensure the impact 3 of coating cladding on each of the Chapter 15 AOOs and 4 postulated accidents should be addressed. And as Josh 5 described, the addition of a coated cladding may 6 necessitate changes to existing SAFDLs or require new 7 SAFDLs. And these impacts will need to be 8 incorporated into the Chapter 15 demonstration. Next 9 slide.
10 For now, LOCA transients coated cladding 11 is not expected to significantly impact or require 12 changes to the LCOs -- initial conditions such as 13 LCOs, fuel rod parameters, core power distribution, or 14 fuel rod peaking factors. There's also no change to 15 the radiological source term or the safety system 16 components and their ability to mitigate them. Based 17 on what we've seen through the PIRT and other 18 interactions, it is expected that many FSAR AORs will 19 remain valid. Next slide.
20 During a postulated LOCA, the design 21 features of the coated cladding are expected to have 22 an impact on the fuel rod's performance. Vendors may 23 or may not take credit for this. Multiple phenomena 24 may be affected such as those listed here. And I 25 wanted to highlight emissivity since it may have a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 1 negative impact as Josh has already described.
2 We don't know with certainty what credits 3 the applicants are going to use in the first topical 4 reports coming in. But we do know the behavior of the 5 transients will be similar to those so that existing 6 models and methods are expected to remain valid.
7 With that, Jason is going to cover the 8 path forward.
9 MR. DRAKE: Thank you, Ash. So the path 10 forward. So thank you for letting us present the 11 details of the draft interim staff guidance here 12 today. It's intended that the NRC staff review 13 applications involving fuel products, zirconium 14 coating or zirconium alloy cladding.
15 Staff will use the information contained 16 within the ISG to ensure that all known degradation 17 failure mechanisms for chromium coating or zirconium 18 alloy fuel cladding are considered such that their 19 impact on acceptance criteria contained in the SRP 20 Chapters 4 and 15 can be assessed.
21 The stakeholder feedback, as we discussed, 22 was incorporated. And how it was incorporated was 23 covered in the presentation, including inclusion of 24 the exchanges in the 8-6 public meeting.
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40 1 published in the Federal Register by the end of the 2 month to elicit public comment. We anticipate having 3 another public meeting at the beginning of December to 4 resolve any comments. And then final guidance is 5 targeted by the end of the year.
6 One question that staff has with respect 7 to processing TRs and LERs on the expedited time table 8 is what level of ACRS expectations is for inclusion of 9 reviews so we can make sure that we have a full scope 10 on what your involvement might be when the submittals 11 start coming in.
12 CHAIR BALLINGER: I guess speaking as one 13 member, I would expect that we'd be able to see the 14 TRs, right? The topical reports?
15 MR. DRAKE: That's what I wanted to 16 clarify as far as comprehensively or --
17 MEMBER CORRADINI: Can I ask the question 18 a little differently?
19 MR. DRAKE: Sure.
20 MEMBER CORRADINI: They'll come in as 21 licensing amendments or just refueling -- as part of 22 the --
23 CHAIR BALLINGER: That's what I was 24 wondering.
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41 1 is --
2 MR. DRAKE: Topical reports are planned 3 initially for the concepts for the new technology.
4 MEMBER REMPE: Can I ask? Right now, 5 you've been focusing on what's needed for a safety 6 case to get the fuel in the reactor as a core reload.
7 It's not the economic benefits that might be 8 associated. I mean, they're probably -- do these 9 topical reports or License Amendment Requests also say 10 what kind of credit they'd like for substantiating an 11 economic case for using this fuel which may be more 12 expensive? I mean, you've not started to look at that 13 at all, right?
14 MR. WHITMAN: I think some of that is 15 covered by the ISG. I mean, certainly, it's up to the 16 vendors as to what -- I mean, oftentimes, it'll be a 17 more difficult case to make that here's higher 18 performance. You would expect more testing to be 19 performed, let's say, to take credit for higher 20 performance than simply saying, this is as good as the 21 status quo for some of these properties. But the list 22 of properties is still going to be the same.
23 But the vendors have sort of -- they 24 haven't submitted their topical reports to us. And so 25 we have an idea from our early engagement with them NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1 what sort of benefits they're going to be claiming and 2 whether they're going to be coming back later to get 3 certain benefits versus just --
4 (Simultaneous speaking.)
5 MEMBER REMPE: See, you said later. And 6 that's what I'm saying. Getting it in the reactor is 7 one thing. But then to say, okay, I have it in the 8 reactor. Now I'd like to do less testing on other 9 components because I have more margin. That's another 10 bar that you've got to meet, right?
11 MR. WHITMAN: Right. And I think that 12 they're not going -- I think that from what we've 13 heard from the vendors, they're not going to be very 14 aggressive with that, with the first round of 15 submittals. But again, I'm sure they're still 16 discussing this in their meetings too about --
17 MEMBER KIRCHNER: Well, it's seems to me 18 --
19 MR. WHITMAN: -- what they want.
20 MEMBER KIRCHNER: -- that since the path 21 that you've taken do not require any changes on the 22 regulatory side. So you still have Appendix K and I 23 don't remember chapter and verse of 50 for ECCS and so 24 on. So the apparent benefit then obviously would be 25 burnup.
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43 1 And although you do not specify testing 2 requirements, somehow that would come back and require 3 either through these lead test assemblies or through 4 other mechanisms some empirical evidence. I would 5 submit that would allow them to capture some gain in 6 the economic realm.
7 MR. WHITMAN: Yeah, I agree with that.
8 MR. DRAKE: Yeah, I agree. I think you'll 9 hear from -- potentially from the industry 10 presentation of the business case that's presented 11 before them as far as their crediting, et cetera. We 12 heard a little bit of that last week on the burnup and 13 increasing enrichment presentation by industry as far 14 as them evaluating the benefits or the credits there 15 and that they'd be taken. But as far as the ISG is 16 concerned, that's really just our guidance on how 17 we're going to be processing the topical reports when 18 they come in.
19 CHAIR BALLINGER: So the topical reports 20 are due in 2020 thereabouts?
21 MR. DRAKE: Yes.
22 CHAIR BALLINGER: And a reload would be, 23 you say, 2023?
24 MR. DRAKE: Correct.
25 CHAIR BALLINGER: Will that require a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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44 1 License Amendment Request?
2 MR. DRAKE: Yes.
3 CHAIR BALLINGER: So there'll be a License 4 Amendment Request sometime between 2020 and 2023 5 obviously?
6 MR. DRAKE: Yes. Each one of the reviews 7 has come in with a requested accelerated schedule for 8 our review in order to accommodate that.
9 MR. WHITMAN: And again, that's our 10 expectation. We haven't received these submittals 11 yet. So --
12 MR. DRAKE: Right.
13 MR. WHITMAN: -- if they wanted -- if a 14 vendor were to choose a different licensing path, 15 that's a possibility.
16 CHAIR BALLINGER: So I would expect that 17 ACRS intersection would be at the topical report 18 stage, unless other members have some other -- we're 19 just trying to understand.
20 MEMBER CORRADINI: We're just trying to 21 understand. What is -- you indicated there's another 22 path. What other path would there be?
23 MR. WHITMAN: Well, I mean, theoretically, 24 a plant could come in with basically a topical report 25 attached to their license amendment and say, this is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 1 our license amendment. I mean, that I don't think is 2 generally a path that they like to take and that we'd 3 like to entertain. But we don't have these 4 submittals, so we're kind of talking what we expect.
5 MEMBER REMPE: Hypothetically speaking, 6 you could have a topical report that's not really with 7 the economic case. It's just is this safe enough.
8 And so there might be some interaction with ACRS on 9 that. And then when they start coming in saying, I 10 want some economic credit, then that's another issue 11 where it seems like it might behoove a look at it.
12 CHAIR BALLINGER: Why would they say 13 anything to us about economic credit?
14 MEMBER REMPE: Because suddenly the 15 significance of things with respect to risk, they're 16 safety issues. If you want to -- I mean, yeah, I 17 don't care what price they pay for the fuel. But if 18 you're starting to say that certain things don't have 19 to be tested as frequently because -- and it won't 20 adversely affect plant safety. I do think I need to 21 -- or somebody needs to think about the safety case, 22 right?
23 CHAIR BALLINGER: But that's the safety 24 case, not the economic case.
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46 1 my part. What I'm trying to say is you're going to 2 change the safety case of the plant because of this 3 fuel, but it is associated with their economic. Then 4 I think there does need to be some safety review.
5 Okay? Did I make it clearer now with what I'm getting 6 to?
7 CHAIR BALLINGER: So noted.
8 MEMBER REMPE: Thank you.
9 MR. DRAKE: Well, that concludes our 10 presentation.
11 CHAIR BALLINGER: Okay. Are there any 12 other questions or comments by members before we 13 change out? We're way ahead of schedule. I probably 14 just jinxed myself.
15 MEMBER KIRCHNER: Then let me ask a 16 question since we're ahead. Just a clarification.
17 The Slide No. 5, 1,800 psi, is that internal pressure?
18 MR. WHITMAN: Yes.
19 MEMBER KIRCHNER: Okay. Thank you.
20 MR. WHITMAN: These are just example 21 slides that --
22 MEMBER KIRCHNER: No, I know. I just want 23 to clarify it wasn't external pressure. It's the 24 internal pressure.
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47 1 presentation is only words without those pictures.
2 Tried to make it a little bit more colorful.
3 CHAIR BALLINGER: Okay. Then -- and let's 4 see. Matt, Pete, or Dave, any additional questions 5 for the staff?
6 MEMBER PETTI: No.
7 MEMBER SUNSERI: This is Matt. I don't 8 have any.
9 MEMBER RICCARDELLA: This is Pete. I have 10 none.
11 CHAIR BALLINGER: Okay. So we should 12 probably just push ahead. And I don't know where the 13 -- you're ready to go. Thank you. This is going to 14 be interesting.
15 (Pause.)
16 CHAIR BALLINGER: You're on.
17 MR. ASHKEBOUSSI: I'm Nima Ashkeboussi 18 with the Nuclear Energy Institute. I want to thank 19 the committee for the invitation today to speak about 20 industry's views on accident tolerant fuel and the 21 draft ISG.
22 We appreciate the interactions that we've 23 had to the staff as they've developed it and the 24 engagements that we've had to date. Before I begin, 25 I just want to clarify for the record the agenda. It NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 1 lists Al Csontos as an NEI member. But just want to 2 correct that as Al is with EPRI.
3 MEMBER CORRADINI: So he's undercover?
4 (Laughter.)
5 MR. ASHKEBOUSSI: We're both doing our 6 numbers. So industry is excited to develop, license, 7 and deploy accident tolerant fuel. And we're working 8 on an accelerated schedule with our efforts to achieve 9 this. We see accident tolerant fuel as a product not 10 that only enhances safety but the one that improves 11 plant economics as well.
12 So for the benefit of the committee, we 13 just wanted to highlight how we're structured. In 14 2016, NEI established the accident tolerant fuel 15 working group. The purpose of this working group is 16 to coordinate industry's efforts in addressing generic 17 issues associated with ATF.
18 This group includes executives from 19 utility vendors, fuel -- excuse me -- fuel vendors, 20 utilities, and engineering supply companies. So we 21 also collaborate with the Electric Power Research 22 Institute, and they lead research efforts in support 23 of ATF.
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49 1 congressional outreach of accident tolerant fuel. And 2 then we have another task force that manages licensing 3 and safety benefits issues associated with ATF. So 4 they looked at what exactly are the safety benefits 5 with these ATF concepts and how do we go about 6 licensing them.
7 So also wanted to highlight some key 8 milestones and where we see ATF moving over the next 9 several years. So we're very proud as an industry to 10 have deployed ATF concepts last year at Plant Hatch.
11 Several have been deployed earlier this year. We have 12 Clinton and ANO deploying concepts this fall. So 13 these concepts represent not just new fuel pellet 14 types but also cladding.
15 MEMBER CORRADINI: So the colors mean 16 something?
17 MR. ASHKEBOUSSI: The colors -- right, 18 each color refers to a different concept.
19 MEMBER CORRADINI: So just for the sake --
20 since there's no legend, let me make sure I 21 understand. Orange is iron clad FeCrAl and light blue 22 is a coating?
23 MR. ASHKEBOUSSI: Yes, that's correct.
24 MEMBER KIRCHNER: And green is pellets?
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50 1 with purple is pellets as well.
2 MEMBER CORRADINI: What is -- oh, okay.
3 MR. ASHKEBOUSSI: So blue, orange, and 4 brown are claddings. Green and purple are pellets.
5 MEMBER CORRADINI: A legend would've 6 helped. Just a thought. Thank you.
7 MR. ASHKEBOUSSI: So as mentioned in the 8 previous presentation, all vendors now have LTAs and 9 reactors. And we expect the first LTAs to come out 10 this coming spring 2020. And we are planning on batch 11 reloads in 2023 with a full core of ATF in 2026.
12 So before I turn it over to my colleague, 13 Ben Holtzman, I just want to say that we agree with 14 what NRC said in the last presentation that these near 15 term concepts are modest departures from the current 16 fuel that is licensed in reactors. But we do have a 17 differing viewpoint when the staff says that the ISG 18 does not add new requirements. And we'll go into that 19 as part of our presentation.
20 MEMBER REMPE: So could I ask you to 21 clarify your statement about all vendors have LTAs.
22 There used to be a differential between near term and 23 longer term concepts. And so is there a caveat you 24 want to say that all vendors' near term concepts have 25 LTA? Or do we now have all the advanced ones also as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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51 1 LTAs with the fuel as well as in the cladding that's 2 intended?
3 MR. ASHKEBOUSSI: So the three vendors, 4 Framatome, Westinghouse, and GE, all have near term 5 concepts --
6 MEMBER REMPE: As LTAs?
7 MR. ASHKEBOUSSI: -- as LTAs. There are 8 longer term concepts by other companies that have not 9 been deployed.
10 MEMBER REMPE: That's what I was thinking.
11 Thank you.
12 MEMBER CORRADINI: I'm still going on the 13 color chart. So something has been put inside a 14 reactor with U3Si2 fuel?
15 MR. ASHKEBOUSSI: Yes.
16 MEMBER CORRADINI: So that's not short 17 term in my view. That's in Byron?
18 MR. ASHKEBOUSSI: That is correct.
19 MEMBER CORRADINI: And the cladding is 20 what? I'm trying to understand. The cladding is 21 chromium-coated cladding?
22 MR. HOLTZMAN: Yes. The Byron -- this is 23 Ben Holtzman from NEI. So the Byron LTAs which were 24 Westinghouse technology, so there's different -- the 25 rods specifically are a combination of those three.
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52 1 They're not a -- it's not a single rod with each of 2 them in there.
3 MEMBER CORRADINI: It's an assembly with 4 a --
5 MR. HOLTZMAN: With different rods. Some 6 of the rods have U3Si2 fuel, uranium silicide.
7 MEMBER CORRADINI: So it's mixed?
8 MR. HOLTZMAN: Correct.
9 MEMBER CORRADINI: Okay.
10 CHAIR BALLINGER: And Westinghouse silicon 11 carbide cladding is in an LTA?
12 MR. HOLTZMAN: No. The silicon carbide 13 cladding which in this chart is the --
14 (Simultaneous speaking.)
15 CHAIR BALLINGER: Oh, that's -- okay, 16 okay.
17 MR. HOLTZMAN: -- brown. Those are 18 further out to the right.
19 MEMBER REMPE: Is it planned to have fuel 20 with that cladding? Because I know we did one LTA or 21 LTR or something. It was just unrodded cladding. But 22 you're planning to put fuel with this cladding in --
23 MR. HOLTZMAN: '22.
24 MEMBER REMPE: -- 2022?
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53 1 they have not yet determined whether or not the 2 silicon carbide LTAs will be fueled or unfueled.
3 MEMBER CORRADINI: So let me make sure 4 I've got this right. I was with you all the way until 5 I saw the purple. So Westinghouse manufactured the 6 U3Si2 fuel?
7 MR. HOLTZMAN: Yes, I believe it was 8 manufactured at INL. But I'd have to confirm with --
9 MEMBER CORRADINI: Okay.
10 MR. HOLTZMAN: -- Westinghouse.
11 MEMBER CORRADINI: Okay. So INL did it?
12 MR. HOLTZMAN: On behalf of Westinghouse, 13 yes.
14 MEMBER CORRADINI: Okay. Thank you.
15 MR. HOLTZMAN: Okay. So as Nima 16 mentioned, I'm Ben Holtzman from NEI. So we wanted to 17 -- we're going to transition a little bit and talk 18 more specifically about kind of our thoughts regarding 19 the ISG. So obviously the durable guidance leads to 20 regulatory stability and predictability. And in order 21 to achieve this durable guidance, we want the ISG to 22 be clear in terms of its requirements.
23 So one aspect of this that we have given 24 the NRC some feedback on, as noted previously, there 25 was a public meeting on August 6th. So some of this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 1 is similar to the feedback. But we wanted to give you 2 guys the same impact in terms of what our thoughts 3 were. And we have some updates with respect to our 4 thoughts regarding how the NRC has been incorporating 5 the comments that we provided, both in our letter and 6 during the public meeting itself.
7 So the ISG kind of puts all the 8 information into a single bin. Essentially, the idea 9 is that as industry have been looking through the ISG, 10 it's not clear necessarily what specifics are solely 11 for fuel licensing actions and what information is 12 more towards the realization of benefits.
13 So we've kind of tried to highlight on 14 this slide kind of where some of this information 15 falls into the different parts of the -- the buckets, 16 if you will. So we kind of view this as kind of 17 having a natural progression for licensing.
18 Obviously, industry needs to cover the 19 material required to license fuel. And some of the 20 vendors will be licensing additional benefits 21 associated with their topical submittals such as the 22 increased burnup and enrichment or other specific 23 benefits as the vendors have the data to support it.
24 MEMBER CORRADINI: So can I say it a 25 different way? You're saying there are certain things NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 1 that appeared in NRC's ISG that is clearly a benefit 2 and it doesn't need to be there or that it doesn't 3 need to be quantified. That's what I'm -- I'm not 4 understanding where you're going.
5 MR. HOLTZMAN: Sure. So in terms of 6 scope, we looked at this and said, we have a current 7 -- we'll call it a box, if you will. There's a 8 current amount of information that is required to 9 license current fuel technologies. And we said, okay, 10 if this is what we're doing for current fuel 11 technology, M5 optimizer, whatever technology we're 12 looking at. And now we wanted to go do a coated 13 cladding technology.
14 So coated cladding is the same base 15 substrate material with a 10-30 micrometer coating on 16 top of it as the previous presentation noted. So if 17 that's what we're looking at, I have my existing 18 requirements and maybe there's a couple specific 19 questions that are coming up solely for coated 20 cladding.
21 If that's what we're calling the base 22 requirements in terms of licensing the fuel, when we 23 read through the ISG, there are additional questions 24 associated with it. Most of those questions in terms 25 of what information they're looking at are things NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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56 1 where from our perspective NRC is trying to identify 2 what are the additional benefits that we're going 3 after and what information would a vendor need to 4 submit in order to realize some of those benefits. So 5 --
6 MEMBER CORRADINI: Before the benefits are 7 even being claimed?
8 MR. HOLTZMAN: Before -- yeah, so the ISG 9 is trying to lay out the framework of what information 10 industry would need to provide for those benefits.
11 But the challenge that we -- the concern that we have 12 is that the ISG is not as clear as it could be in 13 terms of what parts of this are solely part of that 14 base licensing activity and which of these are part of 15 realization of benefits.
16 And the reason why we have that concern is 17 since each of the vendors are going to be submitting 18 their own topicals and they'll likely be submitting 19 their own unique mix of what the benefits are that 20 they're looking at based on the data and the unique 21 properties of what they're proposing.
22 So if a vendor is submitting that mix and 23 they're saying, okay, I want Benefits A, B, C, and D 24 in addition to my current base submittal in terms of 25 information. If the NRC reviewer is looking at the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 1 ISG and saying, the ISG is meant to give me the 2 information to inform my review. And while, yes, 3 there's information on A, B, C, and D but not E, F, G, 4 H, or I which are benefits that that specific vendor 5 in that application did not try to claim benefit for.
6 MEMBER CORRADINI: There's no need to 7 submit.
8 MR. HOLTZMAN: There's no need providing 9 or touching upon those different topics.
10 MEMBER REMPE: Could you give us some 11 examples? I mean, the burnup thing, well, that's 12 normal. I mean, you might not go to the full life.
13 But they can get in as long as they have data. The 14 way they've worded it, as long as you have data to 15 support the intended use. But give me some other 16 examples.
17 MR. HOLTZMAN: Sure. And so obviously the 18 way that the burnup one is written now, obviously as 19 you noted, increasing the burnup limit itself is not 20 specifically tied to a coated cladding topical. But 21 obviously you have a burnup limit that's in every 22 topical report and loaded in there.
23 Some of the additional ones that we kind 24 of -- that we noted, one of which is the eutectic 25 formation. And they're highlighting that as something NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 1 that's occurring above the DBA temperature limit. We 2 recognize that this is something that they're 3 highlighting as potentially in the future we might be 4 trying to increase that number or that at some point 5 that this may become applicable.
6 And I know we talked earlier before, such 7 as for a potential system that this may become 8 something of interest. And obviously if the 9 technology made it so that this did start falling into 10 the current design basis temperature regime and it 11 would then therefore be something considered, that's 12 a different story.
13 But at the moment, it's something that's 14 being called out as beyond the scope of current 15 licensing. We don't normally answer questions in a 16 topical report regarding beyond design basis 17 accidents.
18 MEMBER REMPE: Is that the only example, 19 or do you have others?
20 MR. HOLTZMAN: There are others, and we 21 have some of them noted in the letter. I don't know 22 if you remember a couple other ones off the top of 23 your head, but --
24 MEMBER REMPE: I don't think we got a copy 25 of the letter is why --
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59 1 (Simultaneous speaking.)
2 MR. HOLTZMAN: Okay. We can share the 3 letter with our comments. It makes the way over.
4 It's in ADAMS currently, I know.
5 MEMBER REMPE: Okay. We'll try and get 6 our staffer to give it to us.
7 CHAIR BALLINGER: To reword it a little 8 bit, what you're saying is, is that if it's an actual 9 benefit to you, meaning that you're claiming a 10 relaxation or an increase in some temperature, that's 11 a benefit to you. That has got to be in your 12 submittal. But if it's a benefit, if you will, that 13 you're not claiming buys you anything but it is a 14 benefit, it doesn't need to be addressed?
15 MR. HOLTZMAN: Correct. And the concern 16 that we had was that if the guidance is not clear, we 17 may end up in a do-loop of RAIs coming out of a 18 reviewer who's asking questions about something that 19 has been called out in the ISG but is not part of the 20 review. It's not part of our topical report and is 21 not part of the scope of what we're trying to achieve 22 with that report.
23 MEMBER CORRADINI: So let me -- if I 24 might, let me turn to the staff. Was that their 25 intent that they would have to quantify things that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 1 are potential but not actual? Maybe we're 2 misunderstanding.
3 MR. WHITMAN: Is this on? This is Josh 4 Whitman with the staff. I think we use the term 5 addressed to allow for some wiggle room here. So for 6 example, if we're talking about the eutectic, a 7 licensee could address -- or a vendor could address 8 this by saying the eutectic occurs above the 9 temperatures that we're requesting operation to. And 10 that may be sufficient to address the eutectic.
11 MEMBER CORRADINI: And then if I might 12 just push the point, if there are some of the other 13 ones, if the applicant -- it's not applicable to their 14 current request, not applicable is an acceptable 15 response?
16 MR. WHITMAN: I think so.
17 MEMBER CORRADINI: Now I'll turn back to 18 the applicant. Is that an acceptable answer? I'm not 19 looking to negotiate, but I'm just trying to 20 understand.
21 CHAIR BALLINGER: You're just saying put 22 it in writing is what you're saying?
23 MR. HOLTZMAN: If it's clear, that would 24 be the best. If with the clarification, hopefully 25 that clarification would be applied for -- that would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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61 1 -- the verbal discussion that we just had would be 2 clear to any NRC reviewer when the topical reports 3 came in. So if --
4 MEMBER KIRCHNER: It would seem to me from 5 both sides, it's not unreasonable when you introduce 6 a new material into a well proven system to explore 7 what mechanical material or radiation performance 8 changes are incurred. I would think on the question 9 of eutectic, that's not an unreasonable thing for the 10 regulator to look at.
11 I think you could quickly dispense with it 12 by showing that the eutectic forms at temperatures way 13 above what you're going to license your fuel loads to 14 which is -- because they're not changing the 2,200 or 15 any of the other ECCS and Appendix K regulations.
16 So it would seem to me a quickly addressed 17 manner. But it's not an unreasonable thing in a guide 18 for the regulator or the staff to ask. See where I'm 19 --
20 MR. HOLTZMAN: Yeah, that --
21 MEMBER KIRCHNER: From a physical, 22 phenomenological standpoint. Not from any long-term 23 performance gains and other aspects.
24 CHAIR BALLINGER: But there are other 25 eutectics that exist now, nickel, chromium, iron, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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62 1 nickel-based alloy, 718 grids, zirconium alloy 2 cladding and things like that. But those are way up 3 above there too.
4 MR. HOLTZMAN: Yeah. Can you hit the one 5 forward? So essentially kind of where this is looking 6 at is, and so on the next slide, this slide is kind of 7 highlighting a little bit of kind of the overall scope 8 that was being covered in some of these documents.
9 And so while, yes, there's a path that we can address 10 some of these things.
11 So if you started at the initial gap 12 analysis that EPRI developed and issued in October of 13 last year and then look at that compared to the PIRT 14 rev zero and then the revision of the PIRT rev one 15 which was after the PIRT meeting itself in April. And 16 then we're looking at the initial issuance of the ISG 17 which was the version that we looked at for the August 18 6th meeting.
19 What we were seeing is kind of this slow 20 increase in expansion essentially of what is all the 21 different types of materials or questions that we need 22 to be addressing. And the initial intent of when we 23 kind of talked about this a little bit in 2018 and 24 then when we started off this PIRT exercise was that 25 we were trying to draw a box to constrain the overall NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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63 1 review.
2 The intent was -- and this was the way NRC 3 explained it during our meetings last year was that 4 they were trying to develop essentially a set of 5 bounds to help ensure that when industry topical 6 reports came in, the reviewers had a set of guidelines 7 to look at that said, okay, these things are in scope 8 for us to look at; these things are out of scope for 9 us to look at.
10 And while I agree we have a path forward 11 in terms of how do we address things, for many things, 12 obviously again same base substrate. We can look at 13 this in terms of, well, did this do any harm? Is 14 there any difference in terms of how this is going to 15 perform? Not even whether or not, like, there's a 16 benefit and we want to try to realize that benefit.
17 But just can we demonstrate that this is equivalent to 18 our current materials that were currently licensed?
19 But the challenge that we were having is 20 that, well, if this box in terms of what we're being 21 asked to address just continues to expand, at some 22 point, is this no longer even helpful for the NRC 23 reviewer in terms of making them having an efficient 24 review of the industry topical report? And are we 25 just being asked to cover so many different topics NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 1 that this starts becoming unwieldy to some degree?
2 And obviously, we can do this. We can put 3 in additional information and go forward. But to some 4 degree, this coated cladding is honestly -- this 5 should be the most straightforward ATF implementation, 6 right? This is, again, same base substrate material.
7 So that's kind of more of where our thought process 8 were in terms of answering your question.
9 MEMBER KIRCHNER: Let me ask a rhetorical 10 question. Not knowing the proprietary nature of all 11 the things being considered, is everything, in terms 12 of the coating, 100 percent chromium? Or are people 13 looking at alloys? As you indicated, if you put a 14 little niobium in, it --
15 CHAIR BALLINGER: In the cladding.
16 MEMBER KIRCHNER: -- changes the game.
17 CHAIR BALLINGER: Zirc-niobium --
18 MEMBER KIRCHNER: Yeah, yeah.
19 CHAIR BALLINGER: -- cladding is being 20 used.
21 MEMBER KIRCHNER: Yeah.
22 MEMBER CORRADINI: I don't think they can 23 answer that question from my understanding.
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65 1 they'll be very clear in their topical reports what 2 exactly the technology is and they will get into it 3 there.
4 MEMBER DIMITRIJEVIC: I do have a question 5 which is completely because you're listing all these 6 maybe benefits, maybe not benefits. A lot of plans 7 have a risk-informed application currently approved by 8 NRC. This is definitely going to -- in this risk-9 informed application require plan to maintain the PRA.
10 And whenever some change happen in the design or 11 changing obviously, a significant change which can 12 impact success and therefore can impact PRA. That can 13 impact risk-informed application currently approved 14 for this plan. Was this ever discussed as this?
15 MR. HOLTZMAN: Yeah. So we have been 16 looking at the potential impact on the PRA as well.
17 So generally when we look at in terms of types of 18 benefits, right? Essentially, the benefits fall under 19 at the highest level three different types of 20 categories.
21 There's benefits that industry would be 22 looking at trying to realize that are solely industry 23 scope. It's things that don't impact the licensing 24 basis, don't impact necessarily PRA or things like 25 that. Those are obviously things that industry --
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66 1 they can go off and realize on their own.
2 You then have benefits that would fall 3 under -- that would be NRC review but would be a 4 generic application. And what I mean by that is they 5 would be covering multiple plants in terms of the 6 submittal. So increased burnup and enrichment, for 7 example, is one that would fall under that. And then 8 you have kind of one-offs that would be a specific 9 plant is looking at this. But it would also require 10 NRC interaction.
11 And the reason why I think that kind of 12 distinction is important is that when we were looking 13 at what are the potential impacts for the PRA, to some 14 degree, we were looking at this and saying, okay, for 15 2023, what are the types of benefits that we're 16 looking at and trying to realize. And the things that 17 were impacting the PRA, those are things that we're 18 looking at for a longer term implementation time 19 frame.
20 So Nima had on the previous slide, 21 indicated we're looking at 2026 in terms of full core 22 implementation. Pretty much anything that we are 23 looking for a PRA aspect, we would be realizing once 24 we have full cores.
25 So until then, we'd be looking at this and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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67 1 saying, well, even if there's a potential benefit in 2 PRA space, we're not going to try to realize this 3 until we have the full core anyway in 2026. And so 4 we're not looking at this in terms of a near term PRA 5 impact associated with the 2023 submittals.
6 MEMBER DIMITRIJEVIC: Well, what I wanted 7 to point out, as I say, maybe benefit, maybe not.
8 MR. HOLTZMAN: Yeah.
9 MEMBER DIMITRIJEVIC: It's not necessarily 10 benefit, it existing this --
11 MR. HOLTZMAN: Sure.
12 MEMBER DIMITRIJEVIC: -- information 13 because it's going to impact human performance.
14 Because that's where you're buying more time to your 15 success for the damage to occur. So therefore, if 16 it's impacting human performance, then a lot of risk-17 informed applications are based on proving the 18 agreement is not important. But that change relative 19 importance of the things.
20 So there is costs associated with updating 21 PRA. There is costs associated with maintaining your 22 risk-informed applications. And it may not be benefit 23 or not. You cannot say this is benefit. We're not 24 going to claim it. You will have to maintain PRA --
25 MR. HOLTZMAN: Yeah, we --
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68 1 MEMBER DIMITRIJEVIC: -- if you have a 2 risk-informed application. And almost all plans in 3 the United States have at least risk-informed ISI. So 4 therefore, based on that, they have to maintain the 5 PRA. Once you change, you have to update the PRA.
6 That means you have to update Chapter 50 which provide 7 the success.
8 MS. GAVRILAS: This is Mirela Gavrilas of 9 the staff. Perhaps I can add a bit of clarity. There 10 is an entire cast in the accident tolerate fuel 11 project plan that deals with PRA for exactly the 12 reasons that you just mentioned. So we are fully 13 aware that for PRA to be applicable, it needs to be 14 for the plan as constructed.
15 So we have an entire chapter that deals 16 with that. And we're calling out that if there are 17 differences that -- and by the way, this dialogue has 18 been -- your concern, I know I've raised it about 19 three years ago. And we captured it in the plan. We 20 recognize that it exists. So if there is a deviation 21 in the PRA, they will need to address it if they want 22 their risk programs like ISI or 5069 or 505 to remain 23 applicable.
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69 1 with the coatings, all right, and the other consoles.
2 It's all in our report. Okay? And what we found was 3 that for the coatings, we got an actual improvement.
4 Okay? It's a reduction in core damage frequency for 5 that generic four-loop by about five percent. Okay?
6 When you take the advanced longer term 7 concepts, you're talking about anywhere between 10 or 8 15 percent, okay, reduction of CDF. So what we're 9 talking about here is what needs to be done now. We 10 agree that there's a lot of things that have to be 11 addressed. Okay? The comment is that if you are 12 doing no harm or if you can show that you have a 13 reduced CDF, okay, generically, all right, can you go 14 in and do things now to license versus doing something 15 in 2026?
16 The other question that we have to ask 17 ourselves is when do we need to do these types of 18 analyses? Do you do it after first load -- first 19 batch load? Do you do a second or a third reload?
20 When do you do this? Okay? These are all things that 21 we can have and spend time on over the course between 22 now and 2026 to develop, create those individual, 23 possibly site specific PRA models to address those 24 types of things.
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70 1 looking at here is what needs to be done. What's the 2 minimum that needs to be done now to license products?
3 What's the technical requirements that are needed?
4 Okay. Versus what needs to be done later to get some 5 of these benefits.
6 So for example, if you don't want to take 7 credit to going up to a certain temperature and you 8 keep everything the same now. Do you need to go after 9 and get that data now? Or if you -- or for a vendor 10 or a utility says, we want to go to a higher 11 temperature for our DBA analysis. Then can we bring 12 in that data to you? Okay?
13 Because right now, we have limited 14 facilities. We have limited products. I heard 15 Framatome talking at one of our industry meetings 16 saying they can't make it fast enough. Okay? And so 17 we have limited capabilities to get all these test and 18 to get everything done. Okay?
19 And so we need to figure out we can't --
20 if we're going to take a bite out of this steak which 21 we've got to take small bites. We can't take it all 22 at one time. Okay? And so we need to figure out what 23 do we need to go after.
24 I think going after what's the limited 25 data sets for getting reloads in. That's kind of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 1 focus of what we're talking about. So what testing 2 needs to be done, things like that. The other pieces, 3 we don't disagree that they need to be done. It's 4 just the timing of when they need to be done.
5 MEMBER DIMITRIJEVIC: I got it. I just 6 was trying to warn. And I know that they're thinking 7 that's important. Actually, all this doesn't mean --
8 actually doesn't mean benefit because what contributes 9 to risk change, the risk is relative.
10 So for example, so many of these agendas 11 can become much more important than they were before.
12 And you cannot anymore do the, you know, maintenance 13 online. And it increases your operational cost which 14 is not benefit. So this was just my point. It has to 15 be very particularly addressed. It's absurd, but 16 that's how it goes.
17 MEMBER REMPE: Just a point of 18 clarification in your response, Al, when you go to 19 this benefit of core damage frequency. It's assuming 20 certain properties --
21 MR. CSONTOS: Properties.
22 MEMBER REMPE: -- that are not yet 23 validated with experimental --
24 MR. CSONTOS: Correct. These are --
25 MEMBER REMPE: -- data. So you're --
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72 1 MR. CSONTOS: Oh, no, no, no. Those were 2 provided to us from the DOE program back --
3 (Simultaneous speaking.)
4 MEMBER REMPE: The DOE program --
5 MR. CSONTOS: -- to 2016-17 time frame.
6 MEMBER REMPE: Did DOE have the data to 7 validated the fuel performance to say the core damage 8 frequency has decreased?
9 MR. CSONTOS: No, no, no, no, no. That's 10 not -- I'm talking about the physical properties of 11 the coatings, the physical properties, the 12 temperature, the melt temperature of the different 13 concepts. We have that information.
14 MEMBER REMPE: Okay. You probably needed 15 some sort of MELCOR or map analysis --
16 MR. CSONTOS: Map analysis.
17 MEMBER REMPE: -- to do that. And they 18 don't consider a lot of things like other materials in 19 the core, in a BWR, the cladding channel boxes, et 20 cetera. So put a caveat that you --
21 (Simultaneous speaking.)
22 MEMBER REMPE: Yeah, okay. That's why I 23 just wanted to -- it's not so certain.
24 MR. CSONTOS: We need to update them in 25 the future once we get a better handle of things. But NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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73 1 we're talking about coding. The existing codes are 2 fairly -- they're good enough. And you go to the 3 silicon carbides and things like that --
4 MEMBER REMPE: I'm even talking --
5 MR. CSONTOS: -- I completely agree.
6 MEMBER REMPE: Again, you may change the 7 fuel, but you may not change the severe accident 8 response yet because they don't have that in the codes 9 yet is where I'm going. So put a caveat in there.
10 Okay?
11 MR. CSONTOS: Yeah.
12 CHAIR BALLINGER: For the record, 15 13 percent change in core damage frequency up or down, 14 what's the uncertainty on the number to start with?
15 MR. CSONTOS: Right.
16 CHAIR BALLINGER: So it's basically a 17 wash.
18 MR. CSONTOS: Right. And that's what 19 we're getting at here is that if you're going to be 20 going -- and the concept here is we're putting a thin 21 coating and already approved and already existing.
22 You have all the analysis done. Okay?
23 And so it's a matter of what data do you 24 need to get to go and do the licensing, okay, to show 25 to NRC that it's safe enough? Okay? And then we go NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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74 1 after those benefits. But really those benefits, some 2 may not want to go after those benefits. They'll just 3 take it.
4 CHAIR BALLINGER: One more slide.
5 MR. HOLTZMAN: Well, okay. And so the 6 last thing I wanted to say on this was just that there 7 is no safety imperative for why we're going to be 8 implementing accident tolerant fuel. The current fuel 9 is very safe. It is the determination of the benefits 10 in economic space.
11 Essentially, the marketplace between the 12 vendors and the utilities that'll be moving that'll 13 help us determine what benefits we're trying to 14 realize in our submittals and how we're going to 15 actually implement this for the cross industry.
16 So we talked about some of this on this 17 slide already. One thing that we wanted to highlight 18 as well is that obviously as we -- and NRC kind of 19 talked about this a little bit. So the ISG is 20 intended to provide guidance on chromium-coated 21 zirconium alloy cladding.
22 At some points, it's kind of -- it sounds 23 like this is more specific in terms of generic 24 coatings in general where in other places it's getting 25 into the specifics regarding chromium-coated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 1 applications itself.
2 And so I believe that NRC kind of took --
3 did take some of that feedback to heart from our last 4 meeting and made some denotations on that. So we 5 thank you for that in terms of the adjustments on the 6 previous revision.
7 I think that there's still a few instances 8 where we could potentially look at that for having 9 additional clarification regarding whether or not 10 something is being denoted specifically for the 11 chromium-coated application or for generic 12 applications itself.
13 Additionally, there was a -- in Appendix 14 Bravo, in terms of the oxidation rate, there's a bit 15 of information in terms of how the coatings would 16 impact the thermohydraulic characteristics. The 17 reason why we wanted to bring this up is that again 18 this is something that was not brought up during the 19 PIRT itself. So this is another example for us in 20 terms of how the -- the boxes, if you will, in terms 21 of scope have been increasing as we've been going 22 forward.
23 We don't anticipate that coatings would be 24 severely impacting the thermohydraulic characteristics 25 associated with it. But that's not to mean that we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 1 disagree entirely with the ISG itself. We do note in 2 our comments and we called out a couple during the 3 August 6th meeting as well that there are several 4 instances of agreement between industry and NRC 5 regarding the ISG.
6 So while are discussing a lot of where we 7 have differences, I didn't want you to come away from 8 this with the impression that we disagreed entirely 9 with this document. Oh, is there a letter? Thank 10 you.
11 Okay. So some additional areas of scope 12 creep. So just like today's cladding, it's important 13 that the cladding material and finished fuel rod 14 conform to the specifications and it's free from 15 manufacturing imperfections that would negatively 16 impact fuel performance.
17 The fuel vendors currently produce a very 18 high quality, defect free fuel rods through the 19 current supply chain qualification process. Quality 20 control suppliers, manufacturing, product inspections 21 and certifications under the provisions of 10 CFR 50 22 Appendix Bravo.
23 The coating cladding fuel concepts as we 24 noted before are not conceptually different from the 25 current fuel products. And as such, the existing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 1 manufacturing oversight framework is considered to be 2 adequate. This was something that we noted as well in 3 the public meeting. And NRC noted in their 4 presentation as well that they took that feedback and 5 they tried to make some revisions associated with 6 this.
7 However, as we've been reviewing the 8 current revision of the ISG, it's industry's opinion 9 that there's still some discrepancy regarding the 10 intent regarding the manufacturing requirements.
11 There is some language that still remains in the ISG 12 document. And therefore, some additional cleanup 13 would be required to remove this lingering language to 14 prevent the possibility of different interpretations 15 by different reviewers which again would harm the 16 overall regulatory predictability and certainty.
17 But we agree with the opinion expressed by 18 NRC earlier during their presentation which is that we 19 should not be creating new manufacturing oversight 20 through the ISG. That the current process of QA 21 oversight of manufacturing is adequate and is does 22 ensure that we have the product performance for both 23 coated cladding when we get there and for current fuel 24 technology.
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78 1 listen carefully. So how you framed it at the end is 2 not how it's framed in the ISG? I thought it was.
3 MR. HOLTZMAN: So the -- so again -- so 4 the initial revision of the ISG which was the version 5 that we had for the August 6th meeting --
6 MEMBER CORRADINI: Public.
7 MR. HOLTZMAN: -- public meeting was the 8 entirety -- the mention of manufacturing was calling 9 out saying that they were going to try -- that NRC 10 staff was going to be involving themselves in the 11 manufacturing process. We had the discussion during 12 the August 6th public meeting. NRC management said, 13 yes, we agree. We should be using the current fuel 14 manufacturing process. We would apply the existing 15 vendor QA process to coated cladding. And NRC staff 16 indicated that they would be going through and 17 revising the text to fix that discrepancy.
18 What we found as we've been reviewing this 19 version of the ISG, which is the version that was 20 provided to everyone on this committee, was that --
21 MEMBER CORRADINI: Thank you.
22 MR. HOLTZMAN: -- some instances had been 23 addressed but not all instances regarding the 24 manufacturing impact. And so our comment remains that 25 while we agree with what we are verbally stating and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 1 what we are hearing, we just need -- we want to make 2 sure that the text is clear so that, again, we have 3 regulatory certainty going forward.
4 MEMBER CORRADINI: Okay. Thank you.
5 MR. HOLTZMAN: So additionally, one of the 6 things that we brought up in terms of the Chapter 15 7 impacts. So this was something that we brought up at 8 the August 6 meeting. The original text on this was 9 something that had indicated that the Chapter 15 10 impact would be significantly increasing the scope of 11 work.
12 Essentially, that we would be redoing all 13 of Chapter 15 safety analyses if any parameter that 14 was noted was going to be variable. And NRC actually 15 did a very good job in our opinion on fixing this and 16 revising the text to remove that so that it's clear 17 that now that this may cause an increase which 18 provides additional flexibility and ensures that it's 19 clear that something changing, if it doesn't change 20 outside the existing bounding values that are used as 21 part of the passing of information from the fuel 22 performance. The safety analysis aspects wouldn't 23 require all safety analysis to be redone immediately.
24 So I wanted to leave this in and call that 25 out as NRC doing a good job of being responsive to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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80 1 conversation and discussions that we had from the 2 meeting. So with that --
3 MEMBER REMPE: Talk about the last bullet.
4 What did you have in mind with increasing the burnup?
5 MR. HOLTZMAN: Yeah. So we had talk about 6 this a little earlier which is why I was skipping over 7 it. Initially, there was text that had indicated that 8 we had to be evaluating -- or that she we should be 9 looking at increased burnup and enrichment which was 10 again an example of NRC kind of looking ahead in terms 11 of increasing burnup and enrichment itself is not 12 something explicitly tied to coated cladding or chrome 13 coated cladding applications but is something that 14 industry has expressed and an intention to try to 15 pursue.
16 But the ISG itself shouldn't be noting 17 that there's a requirement to be providing additional 18 burnup data beyond 62 gigawatt-days per MTU for PWR 19 applications obviously in that if for whatever reason 20 a vendor chose not to go to increase burnup associated 21 with their fuel topicals which there shouldn't be a 22 requirement to provide data to do so.
23 MEMBER REMPE: So right now I think I read 24 earlier in the meeting what it says about burnup. You 25 better have data to demonstrate the performance which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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81 1 includes in a radiation environment for this fuel up 2 to whatever you're going to have it in the core for.
3 MR. HOLTZMAN: Correct. And this --
4 MEMBER REMPE: And you seem happy enough 5 with that?
6 MR. HOLTZMAN: Correct. This was another 7 example of NRC changing the ISG based on the feedback 8 and comments that we had provided during the August 9 6th meeting and through our comments. So now we 10 believe that the language us clear that you need to 11 have data to support the main that you're applying 12 for.
13 MEMBER REMPE: But I have a curiosity 14 question. How is industry -- have you discussed with 15 them in your meetings about how they plan to get that 16 data? I mean, you have lead test assemblies. You 17 could try and take it out and do a cook and look. But 18 you've got to ship it to some hot cell somewhere and 19 get that. You don't have Halden anymore. Where are 20 you going to get that data?
21 MR. HOLTZMAN: Just to be clear, your 22 question specifically, have we had discussion with NRC 23 regarding --
24 MEMBER REMPE: No, with industry. Where 25 are they planning to get the data?
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82 1 MR. HOLTZMAN: Sure. So essentially what 2 we've been starting to look at, and obviously this is 3 a little outside the scope --
4 MEMBER REMPE: Absolutely.
5 MR. HOLTZMAN: -- of the ISG.
6 MEMBER REMPE: It's a curiosity question.
7 MR. HOLTZMAN: Sure. So there's a couple 8 pathways available to industry in terms of how to get 9 that data. The current kind of near term path that 10 they're looking at is that industry is interested in 11 increasing the burnup levels to kind of mid-60 12 numbers. So again, in PWR-space, somewhere in the 66, 13 68 ballpark associated with 2023. And that would be 14 an application for both the ATF coated claddings and 15 for the current fuel concepts.
16 So what we would be doing is being able to 17 utilize more than just the LTAs or test samples of ATF 18 but also current high burnup field that exists. And 19 we would be look at this in terms of potentially doing 20 tests in Idaho or at other labs, either inside or 21 outside the United States such as --
22 (Simultaneous speaking.)
23 MEMBER REMPE: Oh, yeah. I'm more 24 interested in the cladding.
25 MR. HOLTZMAN: Sure.
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83 1 MEMBER REMPE: And yeah, maybe you could 2 do something in a foreign reactor somewhere. But in 3 the U.S., you would not use the LTAs and try and ship 4 them to Idaho because that's going to be difficult 5 because --
6 MR. HOLTZMAN: Sure.
7 MEMBER REMPE: -- of political constraints.
8 MR. HOLTZMAN: Sure.
9 MEMBER REMPE: And so I'm just kind of 10 wondering where they're planning to so it. And I go 11 I guess I'm hearing probably the only place you'd have 12 would be to do it overseas?
13 MR. HOLTZMAN: Potentially. The other 14 aspect of this is that in terms of when we need to 15 start doing the additional actual, like, burnup 16 testing itself, some of the vendors have some data 17 already that goes above 62. And we're starting to 18 figure out our plan in terms of whether we could do 19 this with additional methodologies similar to the, 20 like, no burst criterion or something like that.
21 MEMBER REMPE: What about even with ATF-22 coatings? Do you really even have ATF coated fuel 23 that's up to 62 megawatt-days for --
24 MR. HOLTZMAN: Not from the LTA programs 25 yet.
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84 1 MEMBER REMPE: Right. So where are you 2 going to get even the data for 30? I mean, what's the 3 highest burnup you've gotten? What radiated cladding 4 do you have that's AFT cladding with the appropriate 5 fuel pellets? How high a burnup can you go to? If I 6 read that thing, it doesn't say, higher than 60 7 megawatt-days. How high can you go right now with 8 this fuel?
9 MR. HOLTZMAN: Correct. And again, we 10 agree with the way that the text is now written in 11 terms of you have to be able to justify the burnup 12 range associated with it, so --
13 MEMBER REMPE: And how far can they go 14 right now with that text?
15 MR. HOLTZMAN: Sure. So there's two 16 aspects of this essentially for the coated cladding 17 application. So the first again is that it's the same 18 base substrate material in terms of how the cladding 19 is performing in terms of burnup activities. The 20 second aspect is we do have some data associated from 21 the test samples that I know came out of ATR and --
22 (Simultaneous speaking.)
23 MEMBER REMPE: A higher burnup than the 24 ATR?
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85 1 is that he can't give you a specific number because 2 that's between the vendor and NRC. Okay?
3 MEMBER REMPE: You say --
4 MR. CSONTOS: And the negotiation between 5 the vendors and NRC are how to get the data at the 6 time for the applications to submit to a certain 7 burnup range. What Ben was talking about in terms of 8 getting the data sets for NRC for their reviews will 9 be made available to them from the vendors because 10 they're doing testing now.
11 And wherever they're doing testing, there 12 are a lot of places. But they don't want to say where 13 they're doing testing yet, I'm sorry. Okay? And 14 they're collecting the data and they're going to be 15 providing it to NRC. It's between the vendors and NRC 16 in terms of the negotiated maximum range for the 17 highest burnup to the available possible data sets 18 that they have. So it's really between the vendors 19 and their testing program through the DOE program that 20 they have with DOE. And those test plans are with DOE 21 and within the vendor's domain.
22 And what they do is they go out and 23 collect that data, provide it to the NRC and their 24 topicals. And it's really between the vendors and NRC.
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86 1 and you can't give me a number. But is it less than 2 30? Is it less than 10? You just can't say anything?
3 Okay.
4 MR. CSONTOS: Between the vendors and NRC.
5 MEMBER REMPE: Okay. Thank you.
6 MEMBER CORRADINI: She tried.
7 MR. HOLTZMAN: Any other questions?
8 MEMBER KIRCHNER: What is the status of 9 the ISG in response to your August 14th letter? Have 10 you been in negotiations with the staff on 11 incorporating your suggestions, or --
12 MR. HOLTZMAN: We have not yet had 13 discussions with NRC staff regarding our --
14 MEMBER KIRCHNER: Or it's coming out?
15 MR. HOLTZMAN: Our --
16 MEMBER KIRCHNER: Or they're taking it 17 under advisement?
18 MR. HOLTZMAN: Our understanding is that 19 as NRC staff will be posting, I believe, this revision 20 of the ISG for public comment at the end of the month.
21 We'll be providing additional comments regarding how 22 our August 14th letter had been incorporated as well 23 as any additional comments at that time.
24 CHAIR BALLINGER: All set?
25 MR. HOLTZMAN: Yes, sir.
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87 1 CHAIR BALLINGER: Okay. I think now we 2 have to do the go around the room first and then get 3 the line open for public comment. So while we're 4 getting the line open, are there any folks in the room 5 that would like to make a comment? If you would like 6 to make one, come up to the microphone and state your 7 name and make your comment. Seeing no rush.
8 It's open. Is there anybody on the public 9 line at all? Well, must be R2D2 out there. Okay. No 10 people on the public line. We can close that off 11 then. And now Matt, Pete, and Dave, do you have any 12 comments?
13 MEMBER PETTI: No comments. No comments 14 from Dave.
15 MEMBER RICCARDELLA: No comments from Pete.
16 CHAIR BALLINGER: Okay. Last but not --
17 whoops.
18 MEMBER SUNSERI: This is Matt. I 19 appreciate the staff and the industry's updates on 20 progress. That's all. Thank you.
21 CHAIR BALLINGER: Okay. Good. Okay. So 22 let's go around the room and get last comments from 23 members. Vesna?
24 MEMBER DIMITRIJEVIC: Thanks for the 25 presentation and discussion. I don't really have a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 1 comment. I have something to add for your comment 2 about ten percent uncertainty. The reduction in CDF 3 is definitely not benefit. Add the menu for tablet, 4 but tablet is already doing good. The reduction in CDF 5 is actually additional burden. So it could be just 6 one percent or 0.5 percent. The future uncertainty 7 could be burden for the license holder. That's my 8 point.
9 CHAIR BALLINGER: Walt?
10 MEMBER KIRCHNER: Thank you for the 11 presentations. No, I think I don't have further 12 comments at this point.
13 CHAIR BALLINGER: Joy?
14 MEMBER REMPE: I just wanted to say thanks 15 to the staff and industry for their presentations too.
16 But I have no additional comments.
17 MEMBER CORRADINI: No more comments.
18 CHAIR BALLINGER: Harold?
19 MEMBER RAY: And none from me. Thank you, 20 Ron.
21 CHAIR BALLINGER: Well, in that case, 22 thank you very much. Good presentations. And we are 23 adjourned.
24 (Whereupon, the above-entitled matter went 25 off the record at 2:40 p.m.)
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ACRS Subcommittee Meeting:
Draft Interim Staff Guidance for Chromium-Coated Cladding Jason Drake, NRR Josh Whitman, NRR Ashley Smith, NRR September 17, 2019
Key Messages
- Coating zirconium alloy cladding can impact fuel properties and specified acceptable fuel design limits (SAFDLs)
- Coated cladding represents a modest departure from currently operating fuel
- Topical report submittals are expected in 2020 2
ATF Project Plan outlines a new strategy for fuel licensing
- Enables enhanced stakeholder engagement
- Provides framework for activities to proceed in parallel:
- Completion of the technical basis
- Regulatory infrastructure work
- Licensing submittals Phenomena Identification Refinement Plant Specific ATF Concept Topical and Ranking of Regulatory Licensing Development Report (PIRT) Table Infrastructure Actions Exercise 3
Industry pursuing batch reloads of coated cladding in 2023
- Three major vendors developing concepts
- Supported by DOE
- Up to ~20 micron thickness
- Application processes:
- Physical vapor deposition
- Cold-spray
- Amount of benefit sought in initial licensing varies
- LTAs deployed 4
Vendor example of coated cladding Westinghouse 5
Building a foundation for the ISG
- September 2018: NRCs Accident Tolerant Fuel (ATF) Project Plan issued (ML18261A414)
- October 2018: Electric Power Research Institute (EPRI) Coated Cladding Gap Analysis
- November 2018: Nuclear Energy Institute (NEI) ATF In-Reactor Screening Review
- January 2019: Initial NRC report on degradation and failure mechanisms of Cr-coated cladding issued
- April 2019: Expert panel convened to conduct phenomena identification and ranking table (PIRT)
- June 2019: Final NRC PIRT report on degradation and failure mechanisms of Cr-coated cladding issued (ML19172A154)
- July 18, 2019: Initial public ISG draft issued
- August 06, 2019: Public meeting to solicit stakeholder feedback on ISG 6
PIRT panel convened in April 2019
- Conducted under contract Participant Affiliation with PNNL Neal Pierce Hohman Plating & Mfg.
LLC Douglas Wolfe Penn State
- Experts from academia, national labs, and Jeff Venarsky PNNL coating/nuclear industries Koroush Shirvan MIT Michael Corradini Univ. of Wisconsin-Madison
- Panel was conducted as a Gregg Swindlehurst GS Nuclear Consulting, public meeting LLC Charles Berger Hitemco
- Report publicly available: David Senor PNNL ML19172A154 7
ISG will inform staff reviews using PIRT findings
- ISG does:
- provide guidance to staff, informed by the PIRT, on important areas for review
- provide information to vendors and licensees on what is expected
- ISG does not:
- introduce new requirements
- create new rules or regulations
- require specific testing or analyses 8
ISG covers coated cladding concepts currently proposed by vendors
- Focused on Cr-coated cladding
- Covers additional coatings as well
- Provides outline of what should be addressed in a licensing topical report safety evaluation
- Narrative helps inform what level of effort is needed
- Level of effort may differ significantly depending on whether benefits will be credited 9
ISG includes fuel properties that should be addressed in submittal
- thermal conductivity
- axial irradiation growth
- thermal expansion
- oxidation rate*
- emissivity*
- hydrogen pickup*
- enthalpy and specific heat
- high temperature
- elastic modulus ballooning behavior*
- yield stress
- high temperature (800-
- thermal and irradiation 1200°C) steam oxidation creep rate rate*
- = potentially significant impact 10
Stakeholder comments about material properties have been considered
- Emissivity
- Identified as less important by the PIRT
- Stakeholder identified reduced external emissivity as area where current cladding properties are non-conservative
- ISG has been modified to account for this
- Oxidation rate
- Replaced cracked coating suggestion with intentionally damaged
- Noted possible use of non-fueled data
- Tweaked language for other properties to avoid implying specific testing requirements 11
SAFDLs related to assembly performance may be impacted minimally
- Rod bow
- Irradiation growth
- Hydraulic lift loads
- Fuel assembly lateral deflection
- Fretting wear*
- = potentially significant impact 12
SAFDLs related to rod performance during normal operation and AOOs
- Cladding stress*
- Internal hydriding
- Cladding strain*
- Cladding collapse
- Cladding fatigue*
- Overheating of fuel
- Cladding oxidation, pellets hydriding, and crud*
- Pellet-to-cladding
- Fuel rod internal interaction pressure
- Boiling crises*
- = potentially significant impact 13
Stakeholder comments about SAFDLs have been considered
- Discussion on boiling crises updated based on feedback
- Contradictory statements in different appendices were clarified
- General request was made to clarify testing expectations
- Not directly addressed. Difficult to do generally without being overly prescriptive 14
SAFDLs related to rod performance during accident conditions
- Overheating of
- Violent expulsion of fuel cladding*
- Generalized cladding
- Excessive fuel enthalpy melting*
- Bursting*
- Fuel rod ballooning*
- Mechanical fracturing
- Structural deformation
- Cladding embrittlement*
- = potentially significant impact 15
New degradation mechanisms and other considerations
- Coating cracking
- Residual stress
- Coating delamination
- Galvanic corrosion
- Cr-Zr interdiffusion
- Defects
- Radiation effects on Cr
- Eutectic formation
- Subsurface damage 16
SRP Chapter 15 - Transient and Accident Analysis
- Changes to material properties and thermal mechanical behavior should be incorporated
- Impact on each anticipated operational occurrence (AOO) and postulated accident should be addressed
- Impacts of changes to existing SAFDLs should be addressed 17
Non-LOCA Transients
- Coated cladding is not expected to significantly impact or require changes to the following:
- Initial conditions
- Limiting conditions of operations (LCOs)
- Fuel rod parameters (e.g., stored energy)
- Core power distribution or fuel rod peaking factors
- Radiological source term
- Ability of safety-related SSCs to perform mitigating actions
- Many UFSAR non-LOCA analyses of record are expected to remain valid 18
Loss-of-Coolant Accidents
- Coated cladding is expected to impact fuel rod performance during the transient
- Vendors may or may not take credit
- Phenomena which may be affected:
- Heat of oxidation
- Rate of embrittlement due to oxygen ingress
- Hydrogen-enhanced beta-layer embrittlement
- Plastic strains
- Emissivity (may have negative impact)
- With minor modification (depending on credit), existing approved LOCA models and methods are expected to remain applicable 19
Path Forward
- ISG provides guidance to staff reviewing applications with coated cladding
- Initial stakeholder feedback has been incorporated
- Updated draft will be published in Federal Register for public comment by end of the month 20
ISG on Chromium Coated Cladding ATF ACRS Meeting September 17th, 2019 Nima Ashkeboussi, NEI Al Csontos, EPRI Ben Holtzman, NEI
©2019 Nuclear Energy Institute
Government Affairs Nuclear Strategic and Communications Issues Advisory EPRI ATF Advisory Committees Committee Research Collaboration Mission: Foster Research Cooperation and Accident Tolerant Fuel Working Group Collaboration (ATFWG) National Labs Mission: Guide Industry Policy and Actions on ATF
- Exelon Generation Company, LLC
- Westinghouse Electric Company Universities
- Tennessee Valley Authority
- Lightbridge Corporation
- Duke Energy Corporation
- General Atomics International
- Southern Nuclear Operating Company
- X Energy
- Dominion Generation
- NAC International
- Arizona Public Service Company
- Jensen Hughes Regulators
- Xcel Energy
- Excel Services
- GE Hitachi Nuclear Energy
- Electric Power Research Institute
- Nuclear Energy Institute Fuel Vendors Utilities ATF External Affairs Task Force ATF Fuel Licensing and Safety Benefits Task Force Funding and Communications Fuel Qualification to Deployment, and Realization of Regulatory Benefits & Enrichment
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Key ATF Fuel Milestones Framatome Chromia-Enhanced UO2 Fuel Southerns Vogtle Framatome Framatome SiC Cladding Chromia-Enhanced UO2 Fuel Entergys ANO-1 Chrome Coated Cladding Westinghouse Framatome U3Si2 Fuel Chrome Coated Cladding Westinghouse Exelon's Byron Chromia/Alumina-Enhanced UO2 Fuel Westinghouse Chrome Coated Cladding Westinghouse, General Atomics USi Fuel SiC Cladding Chromia/Alumina-Enhanced UO2 Fuel Southerns Hatch GE/GNF IronClad Exelons Calvert Cliffs-2 ARMOR Framatome Exelons Clinton Chromia-Enhanced UO2 Fuel GE/GNF Chrome Coated Cladding Full Core Loaded IronClad ARMOR Batch Reloads Begin 2018 2019 2020 2021 2022 2023 2024 2025 2026
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Coated Cladding Implementation Strategy
- Regulatory Predictability and Certainty Near-Term Regulatory Strategy
- Fuel Licensing
- Licensing coated cladding is
- Burnup and Enrichment*
separate from efforts to realize
- Ancillary Benefits*
benefits. Long-Term Regulatory Strategy
- Several of the high-ranked
- Ancillary Benefits*
mechanisms from the PIRT that are included in the ISG are believed to relate to improved performance due to the coating. ©2019 Nuclear Energy Institute 4
Industry Feedback on the ISG
- Scope Expansion Gap PIRT Rev 1 ISG PIRT Rev 0 Analysis
- Will the Expansion of Scope help NRC Reviewers?
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Potential Areas of Scope Creep
- Manufacturing
- Industry believes that standard 10CFR50 Appendix B quality control programs at fuel manufacturers are adequate to assure product performance for coated cladding
- Chapter 15 Impact
- Regulatory Changes for Increasing Burnup Limits
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Questions?
Questions
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