ML22256A017
| ML22256A017 | |
| Person / Time | |
|---|---|
| Issue date: | 09/22/2022 |
| From: | Stephanie Devlin-Gill Licensing Processes Branch |
| To: | Richard Chang Licensing Processes Branch |
| Devlin Gill S, NRR/DORL | |
| Shared Package | |
| ML22244A071 | List: |
| References | |
| Download: ML22256A017 (8) | |
Text
September 22, 2022 MEMORANDUM TO: Richard Chang, Chief Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Stephanie Devlin-Gill, ATF Lead Project Manager /RA/
Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE AUGUST 24, 2022, HIGHER BURNUP WORKSHOP III On August 24, 2022, the U.S. Nuclear Regulatory Commission (NRC) staff held the Higher Burnup Workshop III, an observation meeting, with the nuclear industry and other stakeholders.
This workshop included presentations by the NRC staff and representatives from the Nuclear Energy Institute (NEI), the Electric Power Research Institute (EPRI), Southern Nuclear Operating Company (SNC), Constellation Energy Corporation, the U.S. Department of Energys (DOE)
Idaho National Labs (INL), and the DOE Oak Ridge National Laboratory (ORNL). The meeting had three purposes: (1) provide all stakeholders with updated information about the current NRC and industry activities for higher burnup (HBU) and increased enrichment (IE) fuel, (2) exchange of information between the NRC staff and industry stakeholders on HBU IE activities, and (3) provide an opportunity for members of the public to ask questions of the NRC staff. The meeting notice can be found in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML22235A740. The NRC and industry meeting slides can be found at ADAMS Accession Nos. ML22230D012 and ML22235A640, respectively. A recording of the meeting can be found at:
https://youtu.be/GQZKZitYPYk Joe Donoghue, Director of the Division of Safety Systems (DSS) in the Office of Nuclear Reactor Regulation (NRR), made opening remarks and Aladar Csontos from NEI provided the industrys opening remarks. The first presentation given by the NRC staff provided an overview and status update on the IE Rulemaking, required by Staff Requirements Memorandum (SRM)-SECY-21-0109. The IE Rulemaking staff provided schedule updates and discussed impacts of the June 22, 2022, public meeting. The SRM-SECY-21-0109 and the public meeting summary can be found in ADAMS at Accession Nos. ML22075A103 and ML22208A001, respectively. The next NRC staff presentation provided an overview of the Regulatory Framework Applicability Assessment (RFAA), available at ADAMS Accession No. ML22014A112. The presentation provided examples from the RFAA table and described how the tables applicability analysis assesses the NRCs regulatory framework to identify regulations and guidance that could be impacted by the licensing of ATF-concept, HBU, and IE fuels, whether pertinent regulations and guidance do not speak to phenomena unique to HBU, IE, or near-term ATF concepts, and how those could be addressed.
Next, the NRC staff provided a presentation regarding the Office of Nuclear Regulatory Research associated Research Information Letter (RIL) on fuel fragmentation, relocation, and dispersal (FFRD). The presentation described RIL 2021-13, available at ADAMS Accession No. ML21313A145, and how it summarized the NRC interpretation of recent FFRD research in:
(1) fine fragmentation burnup threshold, (2) strain threshold for fragmentation, (3) dispersible mass fraction, (4) transient fission gas release, and (5) fuel packing fraction. The NRC staff emphasized intentions of continued participation in experimental programs and review of industry research.
Next, the EPRI representatives presented an overview of EPRIs HBU Alternative Licensing Strategy (ALS), specifically the objective, approach, and scope planned for the ALS topical report (TR). EPRI representatives stated that the objective of the ALS TR will be to address loss-of-coolant accident (LOCA)-induced FFRD in pressurized water reactors using a generically applicable method. EPRI plans to submit the TR in the fourth quarter of calendar year 2023. The SNC representatives then presented on the utility perspectives on EPRIs ALS, focusing on the industrys goals to achieve fuel licensing infrastructure to support burnup and enrichment extensions (LEU+) beyond legacy limits in the mid-2020s and safely and economically enable 24-month cycle operation for the entire fleet of existing light water reactors.
After these presentations, an NRC/industry discussion was held. The NRC staff asked about EPRIs ALS, specifically how leak-before break (LBB) prevents the dispersal within the phenomenon of FFRD. EPRI representatives stated crediting LBB, and operator response times limit transient temperature, thus preventing fuel cladding rupture in large-break LOCAs. EPRI representatives stated that the specific FFRD analysis is detailed in LOCA methods and analysis outlined in EPRIs ALS, for a variety of LOCA sizes and locations. The NRC staff then commented that EPRIs ALS relied on an interpretation of the Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix A, General Design Criteria for Nuclear Power Plants (GDC), specifically Criterion 4, Environmental and dynamic effects design bases (GDC 4) from 1987. GDC 4 provides a criterion for environmental and dynamic effects design bases, which ALS relies on expansion of current interpretations of local dynamic effects for cladding rupture in a LOCA. The NRC staff and EPRI representatives both affirmed such interpretation would require additional information and NRC review. The NRC staff then questioned EPRIs bounding behavior in the provided extremely low probability of rupture (xLPR) code example, specifically emphasizing uncertainties in the model. The EPRI representatives provided a background in xLPR, a probabilistic tool, emphasizing conservative uncertainties support current Technical Specification requirements regarding operator response times. Further discussions regarding EPRIs ALS and xLPR are expected at a partially closed pre-submittal meeting on August 30, 2022, details are available under ADAMS Accession No. ML22249A002. The NRC staff then asked the industry representatives about its intent for submissions of license amendment requests (LAR) regarding HBU up to 75 gigawatt days per metric ton of uranium (GWd/MTU).
Representatives from SNC answered that incremental or mid-range increases in burnup would rely on vendor specific methodologies coupled with plant specific applications. Of note, the industry representatives emphasized mid-range or intermediate burnup increases do not rely on EPRIs ALS, only burnup above 74 GWd/MTU would rely on the ALS TR. The NRC staff then commented that a risk exists in submitting a LAR, while the vendors associated TR is under review. After that question, a short break was held.
After the break, the NRC representatives provided a presentation on performing transportation evaluations of ATF with IE and HBU. The National Environmental Policy Act evaluations, aligned with 10 CFR Part 51.52, Environmental Effects of Transportation of Fuel and Waste - Table S-4 were discussed, for IE above 5 weight-percent U-235 and burnup higher than 62 GWd/MTU.
Next, the NRC staff presented on HBU and IE spent fuel transportation, dry storage research, and licensing. Updates were provided on ATF High-Assay Low-Enriched Uranium (HALEU) research and associated licensing activity, in conjunction with DOE ORNL. The NRC is actively reviewing and certifying transportation packages for ATF and continuing to proactively maintain front and back end regulatory readiness for the nuclear fuel cycle. The next presentation was provided jointly by representatives of EPRI, Constellation, DOE INL, and DOE ORNL. It provided an update on the Collaborative Research on Advanced Fuel Technologies for Light-Water Reactors (CRAFT), the Issue Tracking Matrix, and the Consensus LOCA Test Plan.
After these presentations, an NRC/Industry discussion was held. The NRC staff asked DOE and industry representatives how CRAFT supports licensing timelines industry proposed for ATF.
DOE emphasized its role is to prioritize and develop technology for stakeholder use, however, defers licensing to the NRC. The industry representatives then explained the Consensus LOCA Test Plan specifically schedules and prioritizes activities to support current industry ATF licensing timelines. Then a representative from Framatome inquired about the NRC staffs perspective on the 10 CFR 50.46c emergency core cooling system performance during a LOCA rulemaking. The NRC staff confirmed awareness of the proposed rule, its implications, and the NRCs readiness for licensing applications. Of note, the NRC representatives emphasized that the rule has not yet been finalized. After that question, a public comment period was held.
There were nine public comments received during the public comment period. First a member of the public asked the NRC staff about maintenance timing requirements at operating reactors.
The NRC staff answered that maintenance effectiveness is the subject addressed by the Maintenance Rule, 10 CFR 50.65, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. Working toward public understanding of the regulation, the industry provides its guidance to NRC licensees, and then the NRC provides regulatory guides that may endorse the industry guidance, but additionally may take exceptions. A member of the public then asked a series of questions regarding potential nuclear proliferation of HALEU fuel for weapons and international intentions for enrichment supply. The NRC staff acknowledged all comments and questions for consideration; however, such topics were beyond the scope of the meeting. Then a member of the public asked the NRC staff for a means to convert megawatt days per metric ton of uranium (MWD/MTU) to months or years. The NRC staff provided clarification that MWD/MTU conversion to time depends on various factors, such as: core power level, position of fuel assembly, fuel power level, and rod position in core. Thus, no direct conversion can be made without providing additional factors for consideration. Members of the public then noted concern for HALEU fuel coefficient of criticality, emphasizing the need for transparency. Further, members of the public then noted concern with assumptions within EPRIs ALS, specifically xLPR and leakage LBB assumptions. The NRC staff acknowledged both comments from the public and will take them into consideration.
Next, a member of the public asked the NRC staff to discuss potential consequences of storing and transporting FFRD, focusing on damaged fuel canisters. First, the NRC staff indicated that FFRD is an accident phenomenon discussed for consideration of unlikely hypothetical accident scenarios. Further, the NRC staff provided information on damaged fuel canister requirements, design, and associated package approval. A member of the public then asked how many operating reactors are utilizing HBU fuel. The NRC staff indicated no NRC regulated reactors are operating with loads that have burnups exceeding current limits. Then, a member of the public asked for clarification on the confirmatory codes utilized for ATF technology, and the associated selection process. The NRC staff answered that the confirmatory code is based on research collected at a variety of facility and projects, specifically the Studsvik Cladding Integrity
Project was mentioned. Identified independent confirmatory calculation code for fuel performance, thermal hydraulics, neutronics, and severe accidents can be found at:
https://www.nrc.gov/reactors/atf/independent-confirm-calc.html Joe Donoghue, Director of DSS in NRR made closing remarks and Aladar Csontos from NEI provided industrys closing remarks.
No regulatory decisions were made in the meeting.
Enclosure:
List of Attendees
List of Attendees Higher Burnup Workshop III August 24, 2022 U.S. Nuclear Regulatory Commission (NRC)
First Name Last Name Donald Algama Noushin Amini Brent Ballard Andrew Barto Philip Benavides Andrew Bielen Mark Blumberg Perry Buckberg Richard Chang Alice Chung James Corson Stephanie Devlin-Gill Elijah Dickson Joseph Donoghue James Dunavant Blaylock Dwayne Kenneth Erwin Hossein Esmaili Mike Franovich James Hammelman Nicholas Hansing Kevin Heller Kevin Hsueh Tara Inverso Lios James Stacy Joseph Daniel King Andrea Kock Scott Krepel Lucus Kyriazidis John Lehning Ekaterina Lenning Michael Mahoney Sean Meighan Nicolas Mertz Joseph Messina Ed Miller Tony Nakanishi Ngola Otto Donald Palmrose John Parillo Bo Pham Jason Piotter April Pulvirenti William Rautzen Carla Roque-Cruz David Rudland Michael Salay Fred Schofer Neil Sheehan Enclosure
U.S. Nuclear Regulatory Commission (NRC)
First Name Last Name Zachary Stone Edward Stutzcage Rao Tammara Brian Wagner Kimberly Webber Sunil Weerakkody Bernie White Josh Whitman John Wise Non-NRC First Name Last Name Affiliation (if provided)
Adam Stein Breakthrough Institute (BTI)
Rich Augi GE Power Portfolio Aylin Kucuk Electric Power Research Institute (EPRI)
Jenner Baker Elijah Balltrip Kevin Barber David Barrientos GE Power Portfolio Bob Baxter Framatome, Inc. (Framatome)
Michael Boone James Breuninger Brain Mount Nathan Capps Department of Energy (DOE) Oak Ridge National Labatory Cecile Dame MPR Associates Johnathan Chavers Southern Nuclear Company (SNC)
Rachel Christian Westinghouse Electric Company Christopher Canniff Excel Services Corporation Colby Jenson DOE Idaho National Labs Connie Kline Aladar Csontos Nuclear Energy Institute (NEI)
Robert Daum EPRI Peter Diller GE Power Portfolio Steven Dolley Dwayne Blaylock Fred Smith Framatome Jeff Gabor Shane Gardner GE Power Portfolio William Gassmann Constellation Nuclear Lisa Gerken Framatome Michelle Guzzardo Framatome Kent Halac GE Power Portfolio Robert Hall Zachary Harper Stanley Hayes Feinroth Herb David Hindera GE Power Portfolio J. Phillips Jason Schulthess Jim Anderson Ryan Joyce Julianna Duarte Kalene Walker Zeses Karoutas Thomas Kindred SNC Jeffrey Kobelak
Non-NRC First Name Last Name Affiliation (if provided)
Leigh Lloveras BTI Matthew Leonard Guangjun Li GE Power Portfolio Alan Meginnis Framatome Michael Keegan Kurshad Muftuoglu GE Power Portfolio Carole Naugle Framatome Kari Osborne Frances Pimentel Ian Porter GE Power Portfolio Kevin Quick Framatome Deann Raleigh Robert Fortner Robert Armstrong Baris Sarikaya Constellation Nuclear Tyler Schweitzer GE Power Portfolio Scott Stanchfield Entergy Lawrence Svetlana Jennifer Uhle Yong-Joon Choi Note: Attendance list based on Microsoft Teams participant list and in person attendee sign in sheet. This list does not include individuals who did not provide their last name either in registering for the meeting or by a follow-up email.
ML22256A017 (Meeting Summary)
ML22244A071 (Package)
OFFICE NRR/DORL/LLPB PM NRR/DORL/LPL2-1 PM NRR/DORL/LLPB LA NRR/DORL/LLPB BC NAME DKing SDevlin-Gill DHarrison RChang DATE 09/13/2022 09/13/2022 09/13/2022 9/14/2022 OFFICE NRR/DSS/SNSB BC NMSS/REFS/RRPB BC NMSS/DFM/NARAB BC NMSS/REFS/ERNRB BC NAME SKrepel IBerrios DMarcano KErwin DATE 9/14/2022 9/14/2022 9/22/2022 9/21/2022 OFFICE RES/DSA/FSCB BC NRR/DORL/LPL2-1 PM NAME HEsmaili SDevlin-Gill DATE 9/20/2022 9/22/2022