ML19301B814
| ML19301B814 | |
| Person / Time | |
|---|---|
| Issue date: | 10/31/2019 |
| From: | James Drake Licensing Processes Branch |
| To: | Raymond Furstenau, John Lubinski, Neih H Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Office of Nuclear Regulatory Research |
| Drake, J, NRC/NRR/LLPB | |
| Shared Package | |
| ML19297F703 | List: |
| References | |
| A11008, EPID L-2017-PMP-0011 | |
| Download: ML19301B814 (15) | |
Text
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Comment Location Comment Proposed NRC Notes Action/Resolution
- Change 1 General The timelines, activities, and Please consider The impacts of high burnup Various portions of text within the impacts associated with partitioning the and increased enrichment entire HBU+IE project plan were increasing burnup and various sections are different (i.e., different revised to clearly indicate which of enrichment are different. into burnup and technical concerns), and the the two technologies (burnup or The appendix sometimes enrichment schedules slightly different, enrichment) are being discussed in discusses both topics and portions of the but the activities for those instances where both were other times is only referring appendix to addressing the impacts are not being addressed.
to one of the two, however, more clearly largely, if not entirely, the it is not perfectly clear at all identify the same because of leveraging times. information resources to perform high relevant to each burnup and enrichment tasks topic. in parallel with ATF. Those areas where there are differences in schedule or activity are delineated in the various tables present in the project plan. And the differences in the technical issues are discussed in the opening paragraphs in each section. Therefore, the decision was made not to partition the project plan.
However, many areas of the project plan were updated with revised wording to clearly indicate, when appropriate, which of the two technologies is being discussed.
2 General In numerous places it Please revise Agree. Revised to identify UF6 or other references UF6 as the only the text to be potential precursor forms that are enriched product used to more generic as enriched above the current limit (5 fabricate UO2. there are weight percent U-235).
possibilities to use other precursor forms that are not UF6.
Attachment
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Comment Location Comment Proposed NRC Notes Action/Resolution
- Change 3 General The draft appendix Please add text 5% weight enrichment is Approach outlined in the project discusses changes to the to indicate that generally understood to be plan does not change depending on standard pellet/clad fuel this appendix is the amount of the uranium- the fuel type. No changes made.
system. In a fuel system only applicable 235 isotope present relative where uranium is the for current UO2 to the amount of all other minority component, a fuel or clarify uranium isotopes.
uranium enrichment could how to treat all be above 5% while the ratio fuel types.
of U235 to all atoms by volume may not be above 5%. Therefore the effective enrichment would be less than 5% despite the ratio of U235 atoms to U atoms being above 5%.
4 General The appendix to the NRC Please revise Discussed during public ATF project plan document to be Project Plan is prepared as the burnup and meeting, the HBU+IE project updated with modified appendix Appendix A, however the enrichment plan will appear as Appendix lettering NRC Project Plan Version appendix or the A in the ATF project plan.
1.0 (ML18261A414) already current project The existing Appendix A in contains an Appendix A plan appendix to the ATF project plan will NRC Plans to Develop be a different become Appendix B.
Analysis Capability. Having letter.
two appendices with the same letter creates an error likely situation.
5 General Where is table A.5? The Please revise Tables A.1 through A.6 now Text revised for consistency appendix appears to skip text for labeled consistently this table. consistency.
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ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Comment Location Comment Proposed NRC Notes Action/Resolution
- Change 6 General, The text indicates NRC staff Please explain Within the scope of the In- Additional discussion within Section Line 25, will participate in a NRC's intentions Reactor performance, a HBU A.1.4 has been provided to clarify Lines coordinated PIRT on in regarding a PIRT is not being developed the In-Reactor intent of an IE PIRT 228292 reactor performance of fuels PIRT for (but a literature search is and a HBU literature search.
with increased enrichment. increased being performed). An IE Delineation is also made between Please provide more burnup and PIRT is being developed. HBU for conventional fuel designs information on the timing, enrichment Clarified the scope of Section and ATF designs. Clarified the scope, and intent of this efforts. A.2.2.2 to include uranium scope of Section A.2.2.2 to include activity. Additional feed material and uranium feed material and information such as the unirradiated fuel. Revised to unirradiated fuel. Revised to information presented eliminate references to eliminate references to higher during the Public Meeting on higher burnup and clarified burnup and clarified the scope of September 12th would be the scope of the PIRTs will the PIRTs will include criticality helpful. include criticality safety and safety and materials The text indicates that the materials properties/performance.
PIRT would only be for properties/performance.
increased enrichment. Is burnup excluded intentionally? Would these activities be NRR focused or more crosscutting across multiple parts of NRC?
The text indicates NRC staff will participate in a PIRT for transportation packages for unirradiated fuel transportation for material with higher burnup and enrichment. Please provide more information on the timing, scope, and intent of this activity.
Please explain higher burnup unirradiated material.
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ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Comment Location Comment Proposed NRC Notes Action/Resolution
this is the first occurrence text as indicated (Phenomena Identification &
Ranking Table) 8 Lines 46 The Appendix states that Please ensure The latter is not contradictory No changes needed.
50 the staff does not anticipate text is consistent in that a gap in the identification of gaps or with intent. regulations for Parts 71 or 72 deficiencies in these would not provide the staff regulations with respect to with a regulatory tool for Part 71 and 72. However, review and approval of a lines 243 244 discuss new proposed transport package transportation packages, or storage cask design. If modification of current holders of a transport packages, or exemptions package certificate of from 10 CFR 71.55(g), compliance for UF6 are able especially subpart (g)(4) and to demonstrate that the its limit of 5.0 w/o. package is subcritical with The latter statements optimum moderation, then an appear to be contradictory exemption is not needed, with respect to gaps in Part and the package design will
- 71. meet Part 71 in its entirety.
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ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Comment Location Comment Proposed NRC Notes Action/Resolution
- Change 9 Lines While updating the Please revise The intent of the word Text revised to meet original intent.
112113 regulatory framework is text to remove "generic" was to attempt to important to ensure indication that capture the standard, regulatory certainty, why regulatory predictable licensing process would such changes that framework used for widespread could include rulemaking, changes are adoption of methods and need to be made before anticipated to be technology. Clarification has either higher enrichments or complete before been provided to indicate the burnups can be licensed? licensing can be NRC staff anticipates This text appears to indicate approved. regulatory changes will be that the common regulatory needed before a predictable practice of using exemptions licensing approach outside first would not be the use of exemptions can be acceptable. Additionally, it is implemented.
inconsistent with the exemption pathway discussed in lines 180182 and the discussion in lines 227230.
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ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Comment Location Comment Proposed NRC Notes Action/Resolution
- Change 10 Lines Two sentences appear to be Please revise Two sentences are indeed Text revised to meet original intent 118123 intermixed and need to be text. intermixed. The paragraph corrected. We believe the was revised by moving the sentences are supposed to intermixed sentence to the read as follows: beginning of the paragraph, While higher burnups and which was its originally increased enrichments may intended location.
impact the way compliance with regulatory requirements is demonstrated, the actual principal design and performance requirements provided by the GDC remain applicable. The degree to which existing regulations and guidance need revision or new regulatory requirements and guidance need to be established, depends on the level of departure from existing burnup and enrichment limits.
11 Tables Tables A.1 and A.2 do not Please review NUREG-1555 in Table A.2 Text revised for consistency A.1 and appear to be in alignment. regulatory has been updated to reflect A.2 Industry believes that 10 impact tables for the same impact as 10 CFR CFR 51 and NUREG1555 consistency. 51 in Table A.1 should have similar impacts.
However 10 CFR 51 is noted as being impacted by both higher burnup and enrichment but NUREG 1555 is only noted as impacted by higher enrichment.
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ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Comment Location Comment Proposed NRC Notes Action/Resolution
- Change 12 Lines Industry performs a review Please remove Section A.1.1 was not Text updated to be clearer.
141159 of whether a LAR qualifies Section A.1.1 as removed. Instead it was for a categorical exclusion it's redundant. updated to be clearer about from the National the NRC staff's intended Environmental Policy Act course of action, should it (NEPA) as part of the become necessary:
standard LAR review streamlining NRC staff process and NRC reviews reviews of categorical that assessment during the exclusions and/or approval of that LAR. As environmental impacts that such, the text discussing do not meet the exclusion.
whether NRC staff needs to reconsider the justification for the continued applicability of the existing Generic Environmental Impact Statement is unnecessary.
13 Line 170 The reference to ADAMS Please revise Agreed Text updated with applicable ML#.
Accession Number text.
ML18100A045 is incorrect.
That was the draft LTA letter from the NRC to NEI which was posted on 53118.
The final LTA letter should be cited, ADAMS Accession Number ML18323A169 dated 62419.
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ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Comment Location Comment Proposed NRC Notes Action/Resolution
- Change 14 Lines The text states that for LTAs Please revise Agreed Text updated to be clearer.
171173 using increased the text to simply enrichments and higher state that LTA burnups, the guidance in the programs for LTA letter may not be higher burnup applicable. The guidance in and increased the LTA letter should be enrichment may applicable to all LTAs require LARs programs. The and remove the determination of whether a text indicating 50.59 or LAR is required is that the LTA made by applying the program may fall guidance on a casebycase outside the basis depending on the guidance. The scope of the LTA campaign determination of and the licensing basis of whether a LAR the reactor. or 50.59 is appropriate is made by applying the guidance in the LTA letter to the specifics of the LTA campaign and the reactor licensing basis.
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ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Comment Location Comment Proposed NRC Notes Action/Resolution
- Change 15 Lines The design of new UF6 Please add text The package designer No changes needed.
241 - packaging must continue to to indicate that should work with licensees to 244 interface with the existing as part of the ensure that any new or plant equipment process consideration of modified package design will (receipt, storage, heating, new package interface with existing facility discharge, cleaning, etc). designs, there equipment.
should be a consideration for how a new packages would interface with existing facility equipment.
16 Lines The Appendix contains two Please add Section A2.2.4.1 was revised Revised text as stated.
235244 citations of 10 CFR 71.55(g) mention of 49 to state that "DOT and one citation of 49 CFR CFR 173.417 in regulations in 49 CFR 173.420 (line 322). There the appendix. 173.417 which provide is no mention of 49 CFR requirements for shipment of 173.417 which sets a 5.0 UF6 heels without a w/o U235 enrichment limit protective overpack also limit for transport within 30inch the enrichment of 30B and cylinders. Given the 30C cylinders to 5 weight regulatory infrastructure percent."
changes discussed in lines 235244 of the Appendix, the need to revise DOTs 49 CFR 173.417 should be captured in some fashion in this Appendix.
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ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Comment Location Comment Proposed NRC Notes Action/Resolution
- Change 17 Table Why does table A.4 not Please provide NUREG-2215 is being No edits are warranted.
A.4 have an opinion on the NRC opinion finalized, which consolidated NUREGs 1536, 1567 or of these fuel both the guidance in 1927? cycle NUREGs NUREG-1567 and NUREG-in table A.4. 1536, Revision 1. The staff expects that the document will be publicly-available prior to any need to store ATF with high burnup and high enrichment. NUREG-2215 will be the review guidance used for the initial period of storage, up to 40 years. The renewals of storage facilties will be addressed in a future revision to this plan, which will include reference to the proper revision of NUREG-1927. At this point, that reference is not warranted.
18 Line 256 safety related issues Please revise Text revised as indicated.
should be safetyrelated text as indicated issues 19 Lines Please use subscripts Please revise All instances of U235 or Text revised throughout document.
266, consistently throughout the text for superscript 235U have been 272, appendix. consistency. updated with "uranium-235" 321, 329 (to maintain consistency with the ATF project plan), UF6 now uses subscript 6, and UO2 now uses subscript 2.
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ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Comment Location Comment Proposed NRC Notes Action/Resolution
- Change 20 Lines The International Handbook Please revise Agree. Text revised as indicated.
328 to of Evaluated Criticality the last bullet 338 Safety Benchmark (lines 336 and Experiments contain 337) to the approximately 30 LWR following:
benchmark cases between increase the 5 and 10 w/o U235 with the onesided k majority near 7 w/o. Pooling effective these benchmark tolerance factor experiments with the larger to account for population of experiments uncertainties in below 5 w/o does present a criticality code challenge but general issue performance due exists in all benchmark to the number of studies as discussed in applicable DSSISG201001 critical (ML110620086). experiments for benchmarking.
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ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Comment Location Comment Proposed NRC Notes Action/Resolution
- Change 21 Lines Are each of the activities Please clarify The NRC staff is not aware Text revised to indicate an 332337 noted are potential methods text. of any higher fidelity "either/or" set of options (or for applicants to overcome computer codes which have combination thereof).
the NRC's stated lack of been demonstrated to have criticality benchmark data? increased predictive Or is the intent that a capability compared to the combination of the denoted previously approved activities would be needed? methods. Insufficient Given the predictive nature representative test data may of first principle codes now prevent adequate validation available, has the NRC staff of higher fidelity codes and reviewed how these result in an inability to assess advanced codes could the code's uncertainty. While resolve the issue? NRC staff is aware that many new codes are able to model detailed physical processes that were previously unable to be modeled, the staff has not reviewed and is not aware of the justification which demonstrates the credibility of these higher fidelity models in areas where data is unavailable.
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ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 22 Lines The text indicates that there Please remove The NRC has historically Revised the text to refer to 353355 is a need for experimental this text. There expected that experimental "unanalyzed" instead of "unknown" confirmation for whether an is no reason an confirmation be obtained and age-related phenomena, and unknown agerelated experimental assessed, which confirms provide perspective on NRC's basis phenomena impact the confirmation for that the spent fuel performs for the expectation.
spent fuel during storage something that as expected. The and transport after storage. isn't known to experimental confirmatory Why would this be the exist is needed. basis that low-burnup fuel case? [45 gigawatt days per metric ton of uranium (GWd/MTU)]
remains in its analyzed configuration during the period of extended operation was provided in NUREG/CR-6745, Dry Cask Storage Characterization Project Phase 1; CASTOR V/21 Cask Opening and Examination (Bare and Torgerson, 2001), and NUREG/CR-6831, Examination of Spent PWR Fuel Rods after 15 Years in Dry Storage (Einziger et al.,
2003). This research demonstrated that low-burnup fuel cladding and other cask internals had no deleterious effects after 15 years of storage and confirmed the basis for the guidance on creep deformation and radial hydride reorientation in NRC's review guidance. The research results in NUREG/CR-6745 and NUREG/CR-6831 support a determination that degradation of low-burnup 13
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Comment Location Comment Proposed NRC Notes Action/Resolution
- Change fuel cladding and assembly hardware should not result in changes to the approved design bases during the first period of extended operation, provided that the cask/canister internal environment is maintained.
The U.S. Department of Energy (DOE) is funding a similar program for high burnup fuel [>45 gigawatt days per metric ton of uranium (GWd/MTU)] at the North Anna independent spent fuel storage installation to gather similar experimental confirmatory data to support the technical basis for storage during the first period of extended operation (EPRI, 2014).
Therefore, the cited discussion is consistent with NRC's expectation that experimental data be obtained to confirm that unanalyzed age-related phenomena is not operable during the dry storage and subsequent transport of spent ATF of higher burnup and higher enrichment.
23 Line 372 "Near term" should be Please revise Text revised as indicated.
"nearterm" text as indicated 24 Line 374 Please revise text to "..only Please revise Revised to delete "however".
one fuel cycle facility has text as indicated shared plans" 14
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Comment Location Comment Proposed NRC Notes Action/Resolution
- Change 25 Line 394 Please revise "unrainum" to Please revise Text revised as indicated.
"uranium" text as indicated 26 Lines The text indicates that near Please clarify Text clarified to indicate Text clarified.
423 - term increases in burnup text. range of consideration for 424 and enrichment limits are impacts expected to be only marginally greater than current limits. Is the 5 - 8 wt% range considered as marginally greater than current limits; or is a stepwise approach between 5 - 8% being envisioned?
What burnup values are considered to be marginal increases?
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