ML19344C125
| ML19344C125 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 11/25/2019 |
| From: | Holtzman B Nuclear Energy Institute |
| To: | Joseph Donoghue Office of Administration, Office of Nuclear Reactor Regulation |
| References | |
| 84FR57057 00001, ATF-ISG-2019-XX, NRC-2019-0208 | |
| Download: ML19344C125 (4) | |
Text
Page 1 of 1 SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD: Tekia Govan As of: 12/4/19 2:02 PM COMMENT (1) Received: November 25, 2019 Status: Pending_Post PUBLIC SUBMISSION PUBLICATION DATE:
10/24/2019 CITATION 84 FR Tracking No. 1k3-9dii-640h 57057 Comments Due: November 25, 2019 Submission Type: API Docket: NRC-2019-0208 Supplemental Guidance Regarding the Chromium-Coated Zirconium Alloy Fuel Cladding Accident Tolerant Fuel Concept Comment On: NRC-2019-0208-0001 Supplemental Guidance Regarding the Chromium-Coated Zirconium Alloy Fuel Cladding Accident Tolerant Fuel Concept Document: NRC-2019-0208-DRAFT-0001 Comment on FR Doc # 2019-23186 Submitter Information Name: Benjamin Holtzman Address:
1201 F Street, NW, Suite 1100 Washington, DC, 20004 Email: bah@nei.gov Organization: Nuclear Energy Institute General Comment Comments on Draft Supplemental Guidance Regarding the Chromium-Coated Zirconium Alloy Fuel Cladding Accident Tolerant Fuel Concept (ATF-ISG-2019-XX)
Attachments 11-25-19_NEI Response on Draft Supplemental Guidance _
https://www.fdms.gov/fdms/getcontent?objectId=09000064841b00e9&format=xml&showorig=false 12/04/2019
BENJAMIN HOLTZMAN Senior Project Manager, Fuel and Radiation Safety 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8031 bah@nei.org nei.org November 25, 2019 Mr. Joseph E. Donoghue Director, Division of Safety Systems Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Comments on Draft Supplemental Guidance Regarding the Chromium-Coated Zirconium Alloy Fuel Cladding Accident Tolerant Fuel Concept (ATF-ISG-2019-XX)
Project Number: 689
Dear Mr. Donoghue:
On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI) 1 submits the attached comments on the draft Interim Staff Guidance (ISG) Supplemental Guidance Regarding the Chromium-Coated Zirconium Alloy Fuel Cladding Accident Tolerant Fuel Concept (ATF-ISG-2019-XX). NEI has been working with the NRC to establish regulatory guidance that may be used by NRC staff reviewing industry applications involving chromium-coated zirconium alloy clad fuel products. The ISG also provides insights on staff expectations for vendor topical submittals for accident tolerant fuel (ATF). This ISG supplements the guidance in NUREG-0800, Standard Review Plan. We appreciate the staff soliciting public comment on the draft ISG and the opportunity to present our initial views of the document during the public meeting on August 6, 2019.
The ISG has evolved over the past several months and has been clarified regarding NRCs expectations with respect to how the ATF coated cladding applications should be assessed. While industry appreciates the NRCs efforts to address the previous NEI comments transmitted in our August 14, 2019, letter there remain a couple areas that could still be improved to provide regulatory certainty to industry. Industrys concerns are that the draft ISG continues to allow for the interpretation by a reviewer that the NRC is attempting to regulate the manufacturing process through fuel qualification rather than the current provisions of 10 CFR 50 Appendix B. This position is contrary to how fuel products are currently qualified where the fuel suppliers produce high-quality, defect free fuel rods through the current supply chain qualification process, quality 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. NEIs 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.
Mr. Joseph E. Donoghue November 25, 2019 Page 2 control of suppliers and manufacturing, product inspections and certifications. NRC can then audit the vendor quality assurance program. As such, the existing manufacturing oversight framework is considered to be adequate. NUREG-0800 is and should remain a performance-based standard. This position was agreed upon by NRC management at the public meeting on August 6.
Additionally, while the NRC is transforming to become a modern, risk-informed regulator - Fuels licensing continues to lag behind the rest of the NRC in becoming risk-informed. Adequate protection - no undue risk
- does not mean zero risk. The area of Fuels licensing continues to be regulated deterministically on design-basis accident considerations only. This approach is unnecessarily conservative and demonstrates a lack of risk-informed perspective. Per the direction provided by the Commission in SRM-SECY-19-0036, industry would like risk-informed performance-based ideas written in the ISG directing the staff to apply risk-informed principles when the prescriptive application of deterministic criteria is unnecessary to provide for reasonable assurance of adequate protection of public health and safety.
Thank you for your consideration of our comments. We look forward to continue working with the NRC through the ISG publication process and industrys ATF activities as we work to deploy batch reloads by 2023. If you have any questions or require additional information, please contact me.
Sincerely, Ben Holtzman Attachment c: Jason Drake, NRR, NRC Robert Lukes, NRR, NRC Michael Orenak, NRR, NRC Andrew Proffitt, NRR, NRC Mary Jane Ross-Lee, NRR, NRC Josh Whitman, NRR, NRC NRC Document Control Desk
Comment # Location Comment Proposed Change Industry recognizes the importance of process controls in manufacturing but believes that the NRC should not license specific manufacturing processes. Industry has brought up this concern at the NRC Public Meeting on August 6th and NRC Please revise the text as noted:
management agreed that the vendor suppliers produce highquality, defect free fuel Currently it is not possible to definitively state what data are available rods through the current supply chain qualification process, quality control of to justify these properties, because small d. Differences in applicant suppliers and manufacturing, product inspections and certifications under the specific processes can have a significant impact on the final mechanical provisions of 10CFR50 App B. NUREG0800 should remain a performancebased and material properties. Therefore, the applicant should provide data standard. Furthermore, there was agreement that the coated cladding concepts or other justification from its specific cladding product to justify Appendix B addressed in the ISG are not conceptually different from the current fuel products 1 material property models. (Appendix B page 1 of 7)
(as noted) and that the existing manufacturing oversight framework is adequate.
...microstructures, and higher ductilitycompliant layers can be utilized However, the ISG text still references PIRT Section 6.4.2 and states that the applicant to reduce interface strains. The important mechanical and material should ensure the performance concerns referenced in the PIRT Section are properties to be reviewed are those of the finished applicantspecific addressed. This creates the potential for a reviewer to regulate on process rather fuel product, not those during an interim manufacturing process.
than follow the current performancebased regulatory process as noted as the intent (Appendix B.2, page 3 of 7) by NRC management in the August 6th Public Meeting. Therefore, the ISG text should be clarified that the specifics of the manufacturing process should not be included in the licensing criteria.
Please revise the text as noted:
The NRC is transforming to become a modern, riskinformed regulator but Fuels Potential new damage mechanisms have been identified in Appendix continue to lag behind the rest of the NRC in becoming riskinformed. The mission of C, Section C.4, of this ISG. The reviewer should ensure that these the NRC is reasonable assurance of adequate protection of public health and safety mechanisms have been ruled out sufficiently by the applicant for the as noted in the NRC letter Applying the Principles of Good Regulation as a Risk domain approved by the NRC such that the entirety of the fuel in Informed Regulator. Adequate protection (no undue risk) does not mean zero risk. concert with the supporting systems maintains the reasonable The area of fuels licensing continues to be regulated deterministically on designbasis assurance of adequate public health and safety, that existing SAFDLs accident considerations only. Any riskinformed performancebased idea, while already protect against the mechanisms, or that new SAFDLs have Appendix A accepted in principle, are not implemented in regulations or guidance as there is a been developed to protect against them.
2 (As noted) fear a failure for any aspect of the fuel product at any time.
Based upon an investigation of available performance testing and This approach is unnecessarily conservative and demonstrates a lack of riskinformed known data gaps, Section 6.4.2 of the PIRT report identified several perspective. The fuel pellet matrix and fuel cladding are the first two boundaries performance concerns for chromiumcoated zirconium alloys. The protecting the public, but they are not the only boundaries. A failure of the fuel reviewer should ensure that these performance concerns have been matrix and fuel cladding does not create a situation where the reasonable assurance ruled out sufficiently by the applicant for the domain approved by the of adequate protection of public health and safety is no longer maintained - though it NRC such that the entirety of the fuel in concert with the supporting is a bad and costly day for both the fuel supplier and utility systems maintains the reasonable assurance of adequate public health and safety, that existing SAFDLs already protect against the damage mechanisms, or that new SAFDLs have been developed to protect against them. (Appendix A, pages 2 and 3 of 9)
The PIRT report also suggests two paths that an applicant may take to analyze each property: treating the cladding and coating as separate layers and treating the cladding and coating together as a composite material. A subset of the composite material strategy may be to demonstrate that the coating will have a negligible impact on a property and to use the property of the underlying substrate. Any of these paths may be appropriate provided sufficient justification from the applicant such that the entirety of the fuel in concert with the supporting systems maintains the reasonable assurance of adequate public health and safety, and a variety of these strategies may be used to disposition the various properties. (Appendix A, page 4 of 9)