ML20260H000

Summary of the July 30, 2020, Higher Burnup Workshop Category 2 Public Meeting

ML20260H000
Person / Time
Issue date:	09/24/2020
From:	Michael Orenak Licensing Processes Branch
To:	Dennis Morey Licensing Processes Branch
Orenak M
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Download: ML20260H000 (9)

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September 24, 2020 MEMORANDUM TO: Dennis C. Morey, Chief Licensing Processes Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Michael D. Orenak, ATF Lead Project Manager /RA/

Licensing Processes Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUMMARY

OF THE JULY 30, 2020, HIGHER BURNUP WORKSHOP CATEGORY 2 PUBLIC MEETING On July 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff held the Higher Burnup Workshop, a Category 2 public teleconference with representatives from the nuclear industry, including the Nuclear Energy Institute (NEI), Westinghouse Electric Company (Westinghouse),

Electric Power Research Institute (EPRI), and Nuclear Energy Agency (NEA). The meeting had three purposes: (1) provide the general public with information about higher burnup (HBU) and increased enrichment (IE), (2) provide an open question and answer period on accident tolerant fuel (ATF) subjects for the public, and (3) hold an exchange of information with industry on HBU and IE, focusing on the components of a quality submittal. The meeting notice can be found in Agencywide Documents Access and Management System (ADAMS) at Accession No. ML20211L893. The meeting slides can be found at ADAMS Accession No. ML20211L075.

The NRC staff requested the meeting be recorded, but a problem with the bridgeline operators system prevented recording.

At the start of the meeting, the NRC staff stated that the meeting was focused on HBU and IE, and as with all NRC public meetings, no regulatory decisions will be made. After Joe Donoghue, Director of the Division of Safety Systems, in the Office of Nuclear Reactor Regulation (NRR) made opening remarks, a combination of Michael Orenak, Kevin Heller, Roberto Torres, and Marilyn Diaz from the NRC discussed an overview of HBU and IE. The presentation detailed what are HBU and IE; anticipated impacts HBU and IE, and the associated regulations. The presentation also detailed NRCs activities related to HBU and IE and provided a short demonstration of the revised ATF public website.

CONTACT: Michael Orenak, NRR 301-415-3229

D. Morey Next, Ben Holtzman of NEI presented the wholistic industry perspective on HBU and IE. Then Jeffrey Kobelak of Westinghouse presented Westnghouses progress and plans to incorporate HBU and IE in its fuel designs. Afterward, Fred Smith of EPRI presented on a developing method to risk-inform the analysis of fuel fragmentation, relocation, and dispersal (FFRD).

Dr. Tatiana Ivanova of the NEA gave the last presentation on the International Perspective and Framework for Irradiation Experiments (FIDES) Program.

After the industry presentations, the NRC held a public question and answer period. Some of the significant questions and answers were:

A member of the public asked how can the NRC be putting HBU fuel in reactors today if the presentation states there is a need for data. The NRC staff first clarified the question by phrasing it as "How can the NRC be putting HBU fuel in reactors if the data needed to approve its use hasn't been collected yet?" The staff then began describing the lead test assembly program that allows limited quantities of fuel rods (a very few rods) in non-limiting locations (that being locations that ensure there are wide margins to safety limits) that allow data to trickle in while maintaining safety limits. As an example, the staff discussed the FFRD phenomenon where HBU fuel would be put in locations with such wide margins that it would preclude the possibility of FFRD manifesting.

A member of the public asked if the NRC's decision to explore rulemaking for IE could ultimately result in the decision of not to proceed with rulemaking. The NRC staff indicated yes, clarifying that there is the possibility the NRC may not decide to do rulemaking because part of the decision to pursue it is highly dependent upon the number of licensees seeking to adopt IE. If only one licensee decides to adopt IE, then the NRC would not see a need to complete resource-intensive rulemaking and the NRC would instead review only an exemption request. The questioner appreciated the answer but responded by saying that the NRC should do rulemaking even if only one licensee adopts because they thought it is more rigorous. The questioner also requested the proposed rule also include a realistic accident and consequence analysis that would all comments from the public.

A member of the public inquired why the NRC is defining IE using an enrichment range of 5 percent to 10 percent, why the NRC does not just call it HALEU [high enriched low assay uranium], and why the NRC doesn't just define IE and HALEU based on reactivity instead of enrichment. The NRC staff responded by explaining that IE and HALEU have different delineations within transportation and storage space. The NRC staff asked for clarification on "defining based on reactivity" since enrichment level directly impacts reactivity, but did not receive a clarification on this point.

A member of the public inquired about research work previously conducted by Argonne National Laboratory (ANL) and why the work was not included in the recent NRCs assessment on HBU fuel in dry storage and transportation, as documented in NUREG-2224. The NRC staff responded that the caller had previously asked the question at a prior public meeting on spent fuel activities and informed the member of the public that NUREG-2224 did address ANLs research on ductility of HBU spent fuel during ring compression testing. The NRC staff was then corrected by the member of the public that the question pertained to other ANL research. The NRC staff requested information on the name of the researcher and type of work, and provided an option for the member of the public to contact directly the NRC staff to provide this information.

D. Morey The staff clarified that until that information is received, it is difficult for the staff to address the specifics of that research and relevance to HBU fuel. The member of the public has not yet contacted the NRC staff to provide the information.

After the lunch break, the NRC provided a presentation that detailed the NRCs expectations for submittal quality and submittal timelines to support the industrys target date(s) for batch loading. The NRC staff detailed what should be contained within each type of HBU and IE submittal to address NRC licensing concerns. The NRC staff also discussed obtaining knowledge of the types and dates of forthcoming submittals so the agency can adequately prepare. Afterward, a short NRC-industry dialogue was held where the industry stated that they generally agreed with the submittal timelines provided by the NRC and had no significant comments on the rest of the NRC presentation.

After this dialogue, the NRC held another public question and answer period. Some of the significant questions and answers during this period were:

A member of the public inquired where in the regulations is there an explicit limit on burnup, and where an explicit limit on enrichment exists. The NRC staff answered by drawing attention back to the presentation slides. For burnup, there is no explicit limit, but Title 10 of the Code of Federal Regulations (10 CFR) 50.34 requires licensees to perform safety analyses using codes and methods. These codes and methods are reviewed by the NRC to ensure technical accuracy and compliance with the regulations, and it is in the approval of these methods that the NRC places limits on burnup. The basis for the burnup limit is the range of data presented in code validation and knowledge of FFRD existing beyond 62 gigawatt days per metric ton of uranium (GWd/MTU). The IE limit is explicitly stated in 10 CFR 50.68(b)(7) and 10 CFR 71.55(g)(4).

Regarding slide 8 of the second NRC presentation, a member of the public inquired as to why depletion code validation was important for the safety analyses related to fresh fuel transportation. The NRC staff clarified that depletion code validation is only relevant to spent fuel management.

Various members of the public inquired about the state of knowledge related to high burnup fuel, and whether there exists sufficient technical basis for licensing of HBU fuels, particularly when considering their extended storage. The NRC staff clarified that the licensing and certification for dry storage of spent fuel is based on the safety basis provided in NRC applications. The NRC staff recognizes that there are a number of technical information needs that applicants will have to address to support the safe storage of HBU fuels, as discussed in the workshop (i.e., beyond 62 GWd/MTU). The staff further clarified that data on the performance of HBU fuels is still being generated to address these technical information needs (e.g., post-irradiation examination data to be generated from irradiated lead test assemblies). The NRC staff will continue to assess the information to ensure that applicants conclusions are consistent with the results.

The NRC staff also clarified that the NRC is sponsoring various research activities in support of analytical codes and other assessments that will allow the staff to perform confirmatory calculations, as needed.

A member of the public inquired whether the NRC is relaxing regulatory requirements to meet industrys schedule for the deployment of HBU fuels on a batch load basis. The

D. Morey member of the public expressed particular concerns about the safety of transportation of HBU fuels. The staff clarified that the regulatory requirements are not being relaxed due to industrys proposed schedule for batch loading of HBU fuels. The NRC staff clarified that applications for transportation packages will be reviewed per the regulatory requirements for normal conditions of transport per 10 CFR 71.71 and hypothetical accident conditions per 10 CFR 71.73. The NRC staff clarified that these regulatory requirements codify the specific tests and test sequences that need to be evaluated to demonstrate safety during transport.

No regulatory decisions were made in the meeting.

Enclosure:

List of Attendees

ML20260H000 (Summary)

ML20211L893 (Meeting Notice)

ML20211L075 (Meeting Slides) *via e-mail OFFICE NRR/DORL/LLPB/PM NRR/DORL/LLPB/LA NRR/DORL/LLPB-1/BC NAME MOrenak DHarrison DMorey DATE 9/18/20 9/23/2020 9/24/20 OFFICE NRR/DORL/LLPB/PM NAME MOrenak DATE 9/24/20 List of Attendees July 30, 2020, Higher Burnup Workshop First Name Last Name Organization Al Csontos Electric Power Research Institute (EPRI)

Kristy Bucholtz U.S. Nuclear Regulatory Commission (NRC)

Hatice Akkurt Unknown John Budzynski NRC Josh Borromeo NRC Hang Vu NRC Kent Wood NRC Daniel Ju NRC Ronda Lane Unknown Ashley Smith NRC Kent Halac Global Nuclear Fuels (GNF)

Jeff Seals Unknown Antonio Gomez NRC Clinton Hobbs NRC Nathan Capps Unknown Andrea Kock NRC Joshua Miller NRC Bob St. Clair Unknown Natreon Jordan NRC Jeffrey Reed Unknown John McKirgan NRC James Stavely Unknown Storm Kauffman Unknown Diane Jackson NRC Gregory Suber NRC Donald Palmrose NRC Kim Webber NRC Michael Orenak NRC Kenneth Kellar Unknown Norbert Carte NRC James Hammelman NRC Jeff Seals Unknown Ken Yueh Unknown Charles Folsom Unknown Carl Thurston NRC Tam Tran NRC Aaron Totemeier Unknown Stephanie Devlin-Gill NRC Ryan Nolan NRC Enclosure

First Name Last Name Organization Steven Hayes US Department of Energy (DOE)

Diane Jackson NRC Mohammed Abdoelatef Unknown Andrea Jennetta Unknown Kevin Pusateri NRC Kim green NRC Eva Brown NRC Jean Trefethen NRC Devonte' Hinton NRC Frank Goldner DOE Bob Hoffman NRC Michel Call NRC Kate Lenning NRC Timothy Tate Unknown Joan Olmstead NRC MJ Ross-Lee NRC Fred Smith EPRI Kevin Heller NRC Jeffrey Kobelak Westinghouse Electric Company (Westinghouse)

Marilyn Diaz NRC Josh Whitman NRC Ricardo Torres NRC Ben Holtzman Nuclear Energy Institute (NEI)

Paul Clifford NRC Tatiana Ivanova Nuclear Energy Agency (NEA)

Joe Donoghue NRC Michelle Bales NRC Elijah Dickson NRC Cecile Dame MPR Rob Daum EPRI Alexus Willis NRC Michael Keegan Unknown Sam Lafountain Enercon Zeses Karoutas Westinghouse Kayleh Hartage NRC Juan Arellano NRC Brandon Wise NRC Scott Stanchfield Entergy John Masse NRC Valerie Gray NRC Justin Coury NRC Karen Sida NRC 2

First Name Last Name Organization Alex Siwy NRC Matthew Abenante Strategic IR Luis Colon NRC Rodmon Kliewer Framatome Michael Boone Westinghouse Dennis Morey NRC Christina Jones Framatome Rebecca Steinman Exelon Camille Levine NRC Gary Jenkins NRC Nicholas Szewczyk Southern Nuclear Operating Company (SNC)

Nima Ashkeboussi NEI Thomas Meade Energy Resources International Donna Gilmore Unknown Emma Haywood NRC Muzammil Siddiqui NRC Jack Gwo NRC Manna Greene Unknown Jenny Tobin NRC Susan Hoxie-Key SNC Louis Caponi NRC Dan Wachs DOE Barbara Warren, RN, MS Unknown Timothy Hooker NRC Tyler Beck NRC Seth Grae Lightbridge Ernie Dee Unknown Kirk Tien NRC Russell Chazell NRC Brian Wagner NRC Michael Shockling Westinghouse Joseph Messina NRC Kristopher Cummings NuScale Ed Stutzcage NRC Corey Dukehart Unknown Ruwan Ratnayake EPRI Robert Quinn Westinghouse Jonathan Marcano NRC Jordan Glisan NRC Dave Mitchell Westinghouse Kate Richardson DOE Madeline Feltus DOE 3

First Name Last Name Organization Lucas Kyriazidis NRC Nick Mertz NRC Andrew Atwood Westinghouse Hayden Brundage NRC Hayden Page NRC Kallie Metzger Westinghouse James Park NRC William Maxson Framatome Jason Harp DOE Jeffery Norrell Westinghouse Tanya Sloma-DeLosier Westinghouse Nicolas Woolstenhulme DOE Daniel Ju NRC Tim McCartin NRC John Thorp NRC Henry Marchlewski NRC David McIntyre NRC John Grasso NRC Matt Hiser NRC Jerry Holm Framatome Lisa Matis Tetra Tech Andrew Barto NRC Kalene Walker Unknown Mathew Panicker NRC Christopher Regan NRC Jose Jimenez-Guzman NRC James Fornof Lightbridge John Williams SNC Corey Dukehart NRC Brian Doan NRC Undine Shoop NRC 4