ML20211L086

Presentations for July 30, 2020 Higher Burnup Workshop - NRC Quality Submittals

ML20211L086
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Issue date:	07/30/2020
From:	Licensing Processes Branch
To:	Michael Orenak Licensing Processes Branch
Orneak M
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ML20211L075	List: ML20211L077 ML20211L080 ML20211L082 ML20211L086 ML20211L089 ML20211L091
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Higher Burnup Workshop Schedules and What Constitutes a Quality Submittal July 30, 2020

New Paradigm and Cooperation

• ATF Project Plan developed to meet timelines

• ATF, including HBU/IE, has a high priority for the NRC and the industry, however, applications will receive the same level of review

• Early and frequent communication is key

Expectations, Schedules Timeliness NRC will be performing multiple parallel reviews To allocate resources appropriately, NRC would like to:

- Communicate our expectations for submittals

- Discuss submittal and review schedules

- Discuss the amendment technology matrix

- Remain apprised of submittals and know how many licensees are expected to adopt

General Expectations for Quality Submittals

• Assertions or technical assumptions made in submittals need to be supported by a safety and/or technical basis to ensure an efficient and timely review.

• Need for continuous engagement

Expectations for Quality Part 50 Submittals Code/method suite validation

- NRC SRP guidance remains applicable

- Take note of past submittals and learn from them

• Criticality experiments

• Radiochemical assays

• Physics tests measurements

- Reassess and update uncertainty quantification Spent Fuel Pool

- Exemptions and Criticality Safety Fuel Fragmentation, Relocation, and Dispersal (FFRD) Strategy must be addressed for HBU

Schedules and Timeliness for Part 50 Submittals In October 2019, NRC examined critical path for in-reactor HBU/IE submittals to support industrys 2023 goal:

- Anticipated NRC review times:

• 16 - 18 months Topical Reports (TR)

• 12 months License Amendment Requests (LAR)

- Assumption: 18 month technology launch date lead time

- Submittal Time Frame:

• TRs - November 2020/January 2021

• LARs - June 2022 (?)

2019 2020 2021 2022 2023 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Technology Launch Lead Time NRC LAR Reviews NRC TR Reviews

Expectations for Quality Part 70 Submittals Identification of facility changes and safety basis Criticality Safety

- Revision to criticality safety analyses or methodology

- Updates to criticality code validation report

- Update to justification of minimum margin of subcriticality Updates to the Integrated Safety Analysis including changes in items relied on for safety or accident sequences.

Any impact on other technical or program areas identified in NUREG 1520.

Expectations for Quality Part 71 Submittals for Fresh Fuel Criticality safety

- Adequate subcriticality safety margin for optimum moderation of proposed contents

- Adequate critical experiments and radiochemical assay measurements for criticality and depletion code validation

- May incorporate the use of sensitivity

/ uncertainty analyses to show that existing critical experiments are applicable for validating criticality calculation methodology Configuration control

- Adequate materials properties for ATF cladding materials

- Evaluate potential reconfiguration of the assemblies.

Schedules and Timeliness for Part 70 and 71 Submittals

• In August 2019, NRC developed critical path for the front end of the fuel cycle to support industry's 2023 goal with IE:

- Enrichment Facility LAR - August 2021

- UF6 transportation package -

August 2021

- Fabrication Facility LAR -

October 2021

- Fresh fuel transportation package -

February 2022

Expectations for Quality Part 71 and Part 72 Submittals for Spent Fuel Radiation shielding

- Revised isotopic depletion and radiation dose analyses /

verified and validated code analyses Heat removal

- Revised decay heat analyses /

verified and validated code analyses per current staff guidance Age-related phenomena

License Amendment Technology Matrix

• HBU and IE are two technologies that are part of a host of ATF technologies

• Matrix of possible license amendment technology combinations.

• Most common?

ATF Type ATF Credit HBU Phase IE Cr-Coated Yes 1

No Cr-Coated No 2

Yes

Industry-Anticipated Submittals

• Timelines and subject matter of topical reports and license amendment requests

• How many licensee are expected to adopt?

Open Forum Question and Answer

Closing Remarks If you have any remaining questions:

• Use the Contact Us on the ATF website

• Email:

accident_tolerant_fuel@nrc.gov