ML19304A383
| ML19304A383 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 09/27/2019 |
| From: | Holtzman B Nuclear Energy Institute |
| To: | Office of Administration |
| References | |
| 82FR60633 00012 | |
| Download: ML19304A383 (4) | |
Text
BENJAMIN HOLTZMAN Senior Project Manager, Fuel and Radiation Safety 1201 F Street, NW, Suite 1100 Washington, DC 20004
~I NUCLEAR ENERGY INSTITUTE P: 202.739.8031 bah@nei.org nei.org SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 September 27, 2019 ADD: Jason Drake, Andrew Proffitt Ms. Jane E. Marshall COMMENT (12)
Director, Division of Safety Systems (Acting) PUBLICATION DATE: 12/21/2017 Office of Nuclear Reactor Regulation CITATION 82 FR 60633 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Comments on Draft NRC Project Plan Appendix on Fuel Burnup and Enrichment Extension Preparation Strategy Project Number: 689
Dear Ms. Marshall:
On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI) 1 submits the attached comments on the draft NRC Project Plan Appendix on fuel burnup and enrichment extension preparation strategy. Industry recognizes and appreciates the NRC's commitment to develop the Accident Tolerant Fuel (ATF) Project Plan and continue the collaborative dialogue that has informed the NRC staff's efforts. The industry is committed to the pursuit and development of ATF with increased burnup and enrichment on a timeline that supports phased deployment in a commercial reactor in the early to mid-2020s.
This schedule is of key importance in the decisions our members will need to make when evaluating the ATF benefits against the costs of adopting this technology. As noted during the NRC Public Meeting on September 12th, industry is providing the attached comments on the draft NRC Project Plan Appendix.
Industry requests an opportunity to review the revised draft NRC Project Plan Appendix to understand how our comments have been addressed and potentially another public meeting, if NRC resolution has not addressed key industry concerns regarding the current draft.
One such key concern is the need for experimental confirmation of whether unknown age-related phenomena impact the spent fuel during storage and transportation after storage. The current thermal and radiologica l dose limits are sufficient for the safe storage and transportation of fuel with increased burnup 1
The Nuclear Energy Institute ( NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.
NUCLEAR. CLEAN AIR ENERGY
Ms. Jane E. Marshall September 27, 2019 Page 2 and enrichment. Instead industry agrees with the NRC opinion expressed elsewhere in the draft appendix, which states there are no anticipated gaps or deficiencies in 10 CFR 71 and 10 CFR 72.
Another key industry concern is that the draft NRC Project Plan Appendix proposed changes to the criticality acceptance criteria . Industry believes that the criticality uncertainty can accommodate the uncertainty associated with the benchmark study size for enrichments above 5% by increasing the one-sided k-effective tolerance factor to account for the uncertainties in criticality code performance rather than reducing the allowable maximum k-effective as currently suggested in the draft appendix.
Thank you for your time and attention to this important matter. If you have any questions or require additional information, please contact me.
Sincerely, Attachment c: Andrew Proffitt, NRR, NRC Jason Drake, NRR, NRC Josh Whitman, NRR, NRC Dennis Morey, NRR, NRC NRC Document Control Desk
Comment# Location Comment Proposed Change The timelines, activities, and impacts associated with increasing burnup and Please consider partioning the various sections into burn up and 1 General enrichment are different. The appendix sometimes discusses both topics and other enrichment portions of the appendix to more clearly identify the times is only referring to one of the two, however, it is not perfectly clear at all times. information relevant to each topic.
In numerous places it references UF6 as the only enriched product used to fabricate Please revise the text to be more generic as there are possibilities to 2 General U02. use other precursor forms that are not UF6.
The draft appendix discusses changes to the standard 'pellet/clad' fuel system. In a fuel system where uranium is the minority component, a uranium enrichment could Please add text to indicate that this appendix is only applicable for 3 General be above 5% while the ratio of U235 to all atoms by volume may not be above 5%.
current U02 fuel or clarify how to treat all fuel types.
Therefore the effective enrichment would be less than 5% despite the ratio of U235 atoms to U atoms being above 5%.
The appendix to the NRC Project Plan is prepared as Appendix A, however the NRC Project Plan Version 1.0 (ML18261A414) already contains an Appendix A " NRC Plans Please revise the burnup and enrichment appendix or the current 4 General to Develop Analysis Capability." Having two appendices with the same letter creates project p lan appendix to be a different letter.
an error likely situation .
5 General Where is table A.5? The appendix appears to skip this table . Please revise text for consistency .
The text indicates NRC staff will participate in a coordinated PIRT on in- reactor performance of fue ls with increased enrichment. Please provide more information on the timing, scope, and intent of this activity. Additional information such as the information presented during the Public Meeting on September 12th would be helpful.
General, The text indicates that the PIRT would only be for increased enrichment. Is burn up Please explain NRC's intentions regarding a PIRT for increa sed 6 Line 25, excluded intentionally? Would these activities be NRR focused or more cross*cutting burnup and enrichment efforts.
Lines 228-292 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 t iming, sco pe, and intent of th is activity.
Please explain higher burnup un irrad ia ted material.
Please spell out PIRT as th is ls the fi rst occurrence (Phenomena Identification &
7 Line 24 Please revise text as indicated Ranking Table)
The Appendix states that " the staff does not anticipate identification of gaps or deficiencies in these regulations" with respect to Part 71 and 72. Howeve r, lines 243*
8 Lines 46-50 244 discuss new transportation packages, modification of current packages, or Please ensure text is consistent with intent.
exemptions from 10 CFR 71.55(g), especially subpart (g)l4) and its limit of 5.0 w/o .
The latter statements appear to be contradictory with respect to gaps in Part 71.
While updating the regulatory framework is important to ensure regulatory certainty, why would such changes that could include rulemaking, need to be made before Please revise text to remove indication that regulatory framework either higher enrichments or burn ups can be licensed? This text appears to indicate 9 Lines 112-113 changes are anticipated to be complete before licensing can be that the common regulatory practice of using exemptions first would not be approved .
acceptable. Additionally, it is inconsistent with the exemption pathway discussed in lines 180-182 and the discussio n in lines 227-230.
Two sentences appear to be inter*mixed and need to be corrected . We believe the senten ces are supposed to read as follows :
While higher burnups and increased enrichments may impact the way compliance 10 Lines 118-123 with regulatory requirements is demonstrated, the actual principal design and Please rev is e text.
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 burn up and enrichment limits.
Tables A.1 and A.2 do not appear to be in alignment. Industry believes that 10 CFR 51 Tables A.1 and and NUREG-1555 should have si milar impacts. However 10 CFR 51 is noted as being 11 Please review regulatory impact tables for consistency.
A.2 impacted by both higher burnup and enrichment but NUREG-1555 is only noted as impacted by higher enrichment.
Comment# Location Comment Proposed Change Industry performs a review of whether a LAR qualifies for a categorical exclusion from the National Environmental Policy Act (NEPA) as part of the standard LAR review process and NRC reviews that assessment during the approval of that LAR. As such, 12 lines 141-159 Please remove Section A.1.1 as it's redundant.
the text discussing whether NRC staff needs to reconsider the justification for the continued applicability of the existing Generic Environmnetal Impact Statement is unnecessary.
The reference to ADAMS Accession Number ML18100A045 is incorrect. That was the 13 line 170 draft LTA letter from the NRC to NEI which was posted on 5-31-18. The final LTA Please revise text .
letter should be cited, ADAMS Accession Number ML18323A169 dated 6-24-19.
Please revise the text to simply state that LTA programs for higher The text states that for LT As using increased enrichments and higher burnups, the burnup and increased enrichment may require LARs and remove guidance in the LTA letter may not be applicable. The guidance in the LTA letter the text indicating that the LTA program may fall outside the 14 lines 171-173 should be applicable to all LTAs programs. The determination of whether a 50.59 or guidance. The determination of whether a LAR or 50.59 is LAR is required is made by applying the guidance on a case-by-case basis depending appropriate is made by applying the guidance in the LTA letter t o on the scope of the LTA campaign and the licensing basis of the reactor.
the specifics of the LTA campaign and the reactor licensing basis.
Please add text to indicate that as part of the consideration of new The design of new UF6 packaging must continue to interface with the existing plant 15 Lines 241- 244 package designs, there should be a consideration for how a new equipment process (receipt, storage, heating, discharge, cleaning, etc).
packages would interface with existing facility equipment.
The Appendix contains two citations of 10 CFR 71.55(g) and one citation of 49 CFR 173.420 (line 322). There is no mention of 49 CFR 173.417 which sets a 5.0 w/o U235 16 Lines 235-244 enrichment limit for transport within 30-inch cylinders. Given the regulatory Please add mention of 49 CFR 173.417 in the appendix.
infrastructure changes discussed in lines 235-244 of the Appendix, the need to revise DOT' s 49 CFR 173.417 should be captured in some fashion in this Appendix.
Please provide the NRC opinion of these fuel cycle NUREGs in table 17 Table A.4 Why does table A.4 not have an opinion on NUREGs 1536, 1567 or 1927?
A.4.
18 line 256 "safety related- issues" should be "safety-related issues" Please revise text as indicated Lines 266, 272, 19 Please use subscripts consistently throughout the appendix. Please revise text for consistency.
321,329 The International Handbook of Evaluated Criticality Safety Benchmark Experiments Please revise the last bullet (lines 336 and 337) to the following:
contain approximately 30 LWR benchmark cases between 5 and 10 w/o U-235 with lines 328 to "increase the one-sided k-effective tolerance factor to account for 20 the majority near 7 w/o. Pooling the se benchmark experiments with the larger 338 uncertainties in criticality code performance due to the number of population of experiments below 5 w/o does present a challenge but general issue applicable critical experiments for benchmarking."
exists in all benchmark studies as discussed in DSS-ISG-2010-01 (ML110620086).
Are each of the activities noted are potential methods for applicants to overcome the NRCs stated lack of criticality benchmark data? Or is the intent that a combination of 21 Lines 332-337 the denoted activities would be needed? Given th e predictive nature of first principle Please clarify text.
codes now available, has the NRC staff reviewed how these advanced codes could resolve the issue?
The text indicates that there is a need for experimental confirmation for whether an Please remove this text. There is no reason an experimental 22 lines 353-355 unknown age-related phenomena impact the spent fuel during storage and transport confirmation for something that isn't known to exist is needed.
after storage. Why would this be the case?
23 Line 372 "Near -term" should be "near-term" Please revise text as indicated 24 Line 374 Please revise text to ".. only one fuel cycle facility has shared plans .. Please revise text as indicated 25 Line 394 Please revise "unrainum" to "uranium" Please revise text as indicated The text indicates that near-term increases in burnup and enrichment limits are expected to be only marginally greater than current limits. Is the 5 -8 wt°/o range 26 Lines 423 - 424 considered as "marginally greater than current limits"; or is a stepwise approach Please clarify text.
between 5 -8%being envisioned? What burn up values are considered to be marginal increases?
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