ML23072A355

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2023 Report on Preparedness for Accident Tolerant Fuel Licensing, Including Higher Burnup and Enrichment
ML23072A355
Person / Time
Issue date: 04/28/2023
From: Christopher Hanson
NRC/Chairman
To: Granger K, Murray P
US SEN, Comm on Appropriations
References
CORR-23-0036; SRM-OGC230103
Download: ML23072A355 (1)
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PREPAREDNESS FOR ACCIDENT TOLERANT FUEL LICENSING, INCLUDING HIGHER BURNUP AND ENRICHMENT A Report for the Senate Committee on Appropriations and the House Committ~e on Appropriations By the U.S. Nuclear Regulatory Commission Enclosure

Introduction The U.S. Nuclear Regulatory Commission (NRC) developed this report as directed by the explanatory statement accompanying the Consolidated Appropriations Act of 2023 (Public Law 117-328). The explanatory statement directed the NRC to report on its preparedness for accident tolerant fuel (ATF) licensing, focusing on the steps being taken to ensure that licensing activities (including for higher burnup and enrichment) support projected deployment schedules.

Potential applicants are moving forward with plans to seek approval to batch load 1 fuel assemblies with one of two ATF concepts (coated claddiflg and doped pellets) or with higher burnup limits and increased enrichment by the mid-to-late 2020s. The enrichment, fabrication, transportation, and use of ATF fuel assemblies in some cases requires NRC approval. The NRC has already received licensing action requests for the use of A TF, including for higher burn up limits with or without increased enrichment levels. The current list of these submittals and their approvals, if applicable, can be found on the NRC's ATF public Web page (Ref. 1).

The NRC completed or is performing tlJe activities detailed in this report to support agency efforts to complete the licensing of ATF, including higher burnuplimits and increased enrichment, in parallel with the U.S. Department of Energy's (DOE's) and the industry's research and development activities. In performing these activities, the NRC verifies that licensee use of A TF technologies will provide reasonable assurance of adequate protection of public health and safety, promote the common defense and security, and protect the environment.

The NRC Is Ready to License Accident Tolerant Fuel Concepts, Higher Burnup, and Increased Enrichment Fuels The NRC staff assessed its regulatory framework (Ref. 2) and found that the existing regulations and guidance will support the licensing of near-term ATF concepts (i.e., coated cladding and doped pellets). Similarly, the NRC found that no changes to the regulatory framework are necessary to support the licensing of fuel with increased enrichment (from 5 to approximately 1O weight-percent uranium-235) and higher fuel burnup limits (from 62 to 75 gigawatt-days per metric ton of uranium (GWd/MTU), rod-average). Although the existing regulatory framework and licensing processes will support the licensing of these new fuel types, the NRC has identified certain areas, discussed further in the remaining sections of this report, in which the framework can be enhanced to improve the effectiveness and efficiency of the process. As noted below, efforts are underway to implement these enhancements.

The NRC developed the ATF Project Plan (Ref. 3) to prepare for reviews of A TF concepts, higher burnup, and increased enrichment fuel designs. The ATF Project Plan, revised in September 2021, addresses the complete nuclear fuel cycle, including fuel enrichment, fabrication, fresh fuel transport, in-reactor requirements, and spent fuel storage and transportation. In developing the plan, the NRC staff engaged extensively with its stakeholders, including licensees, nuclear fuel vendors, industry groups, nongovernmental organizations, and international counterparts, consistent with the NRC's Principles of Good Regulation and statutory requirements. The NRC keeps information contained in the A TF Project Plan current through continued stakeholder interactions.

1 A batch load is the replacement of approximately one-third of the fuel assemblies in the reactor core after each operating cycle.

The A TF Project Plan outlines an enhanced approach to fuel licensing in which the NRC engages with applicants earlier in their research and development phases to help identify and

  • promptly resolve potential safety issues and close information gaps. The NRC continues to pursue opportunities for increased communication and engagement on many fronts. These include routine participation in vendor status meetings, attendance at industry conferences, and actively supporting pre-submittal meetings. These engagements allow the NRC and its stakeholders to exchange information effectively and increase the efficiency of the review process.

Additionally, the NRC continues to hold meetings and issue communications to further support dialogue with stakeholders about specific technical or administrative issues. In January 2022, the NRC sent a letter (Ref. 4) to the Nuclear Energy Institute (NEI) and other industry stakeholders to provide a generic, nominal schedule for the review of topical reports and licensing actions for the deployment of A TF concepts, higher burnup, and increased enrichment fuels. The letter encouraged further engagement on any intended specific topical report or site-specific licensing action targeted for deployment by the mid-2020s and provided generic licensing timelines. In January 2023, the NRC staff and external stakeholders presented an overview of ATF activities to the NRC Commissioners (Ref. 5). The NRC also continues to meet routinely with the DOE to share information on ATF status and research, which helps the NRC staff anticipate what reviews may be needed.

As part of the licensing process for ATF concepts, higher burnup, and increased enrichment designs, the NRC must also evaluate the potential environmental effects of its licensing actions under the regulations in Title 1O of the Code of Federal Regulations (1 O CFR) Part 51, "Enviro*nmental Protection Regulations for Domestic Licensing and Related Regulatory Functions," to implement section 102(2) of the National Environmental Po_licy Act of 1969, as amended (NEPA). NEPA analyses previously performed by the NRC staff addressed the environmental effects for enrichment levels of 5 weight-percent uranium-235 or less and spent fuel burnup levels up to 62 GWd/MTU (see section 4.12.1.1 of NUREG-1437, Revision 1 (Ref.

6) and section 4.14.1.1 of Draft NUREG-1437, Revision 2 (Ref. 7)). Specifically, these NEPA analyses support the continued use of 10 CFR 51.51(b), Table S-3; "Table of Uranium Fuel Cycle Environmental Data," and 10 CFR 51.52(c), Table S-4, "Environmental Impact of Transportation of Fuel and Waste To and From One Light-Water-Cooled Nuclear Power Reactor," as still bounding for light-water reactor licensing actions.

With the nuclear industry considering enrichment levels up to 1O weight-percent uranium-235 and potential burnup levels as high as 75 GWd/MTU along with various forms of ATF, the use of such new reactor fuels is outs_ide of the conditions for the use of Tables S-3 and S-4. Thus, a new environmental review will be needed to support future licensing actions involving these new fuel types. Although these reviews could be performed on a site-specific basis as a part of the licensing review, the NRC is generically evaluating the environmental impacts related to the uranium fuel cycle, transportation of un_irradiated ATF, waste, and decommissioning to improve the efficiency of the licensing process. To this end, the NRC is applying information from past studies to A TF concepts, higher burnup, and increased enrichment designs and assessing the available fuel performance' analyses, data, and studies to develop a generic study of environmental impacts of ATF concepts, increased enrichment and higher burn up fuels. Even if this erivironniental evaluation cannot be applied in a specific future licensing action, the generic study should provide an analytical template for completing such analyses for different enrichment and burnup conditions.

  • The NRC continuously takes steps to ensure its readiness to review license applications for these new fuel types. For instance, the NRC issued reports containing phenomena identification ranking tables (PIRTs} 2 , which rank the relative importance of selected topics associated with ATF to assist the staff in making risk-informed decisions, as well as fuel performance literature reviews. These reports included spent fuel transportation and storage as well as reactor operating and accident conditions. These reports help the agency broaden its understanding of phenomena associated with the various technologies being considered and identify any changes to the regulatory infrastructure that may be needed before receiving submittals. The NRC staff maintains a Web page of ATF-related documents on its p~blic website (Ref. 8).

The NRC continues to deyelop and revise existing computer codes to be used for independent confirmatory calculations. These confirmatory calculations provide insight into fuel and reactor systems behavior, potential consequences of transient and accident scenarios, and the identification of risk-significant factors. For example, the NRC modified some of its codes to add material properties for new ATF materials more easily. This will allow the NRC to quickly update its codes as data and information are received and reduce unnecessary conservatisms in technical evaluations.

Other General Preparatory Activities The NRC participates as an observer in two Electric Power Research Institute (EPRI) groups that are coordinating research on ATF concepts, higher burnup, and increased enrichment limits. The first is the Collaborative Research on Advanced Fuel Technologies for Light-Water Reactors (CRAFT) . The second is the Extended Storage Collaboration Program. 3 Participation in both research groups allows the NRC to be better prepared to review future licensing submittals by providing heightened awareness of vendor plans and research activities. It also provides the NRC with the opportunity to offer feedback to stakeholders as appropriate.

The NRC frequently interacts with international counterparts and subject matter experts through Nuclear Energy Agency (NEA) working groups-most notably the Working Group on Fuel Safety-and through international cooperative research programs to expand its technical database and maintain awareness of relevant policy and technical issues with ATF. Some notable international activities include:

  • The NRC participated in the Organisation for Economic Co-operation and Development

.(OECD)/NEA and supported the Studsvik Cladding Integrity Project led by Studsvik in Sweden. This effort provided data on higher burnup fuel and cladding performance during a simulated loss-of-coolant accident .(LOCA).

  • The NRC engaged with the Japan Atomic Energy Agency which has provided data on chromia doped fuel performance during a reactivity-initiated accident conducted in its Nuclear Safety Research Reactor.

2 The phenomena identification and ranking table (PIRT) process is a systemic way of gathering information from experts on a specific concept and ranking the importance of the information to help guide research or develop regulatory requirements.

  • 3 The NRC's role as an observer in the Extended Storage Collaboration Program involves, .among other things, presenting updates on NRC activities and technical topics, providing input, and being represented on the Extended Storage Collaboration Program Steering Committee.
  • The NRG staff participates in the Gabri International Project, led by the Institute for Radiological Protection and Nuclear Safety in France, which studies the behavior of nuclear fuel and cladding during reactivity-initiated accident~.
  • The NRG staff is participating in the OECD/NEA's QUENCH-ATF project, through which it obtains data on coated cladding behavior in design-basis and beyond-design-basis LOCA conditions.
  • The NRG staff is participating in the OECD/NEA Framework for lrradi.ation Experiments (FIDES), which was launched to continue the international cooperation and highly leveraged access to nuclear safety, fuels, and materials research that was lost with the 2018 closure of the Halden reactor in Norway. The first round of the FIDES Joint Experimental Programmes includes tests on ATF concepts and higher burnup fuel under normal operating conditions, anticipated transients, and design-basis accidents.

Active participation in these international research programs enhances the NRC's understanding of safety-significant fuel and thermal-hydraulic system behavior. It also provides valuable data to develop and validate independent models for the NRC's confirmatory analysis codes. Confirmatory calculations performed during safety*reviews with_analysis codes provide insight on the fuel and reactor systems behavior, during transient and accident scenarios.

Near-Term Accident Tolerant Fuel Concepts The NRG anticipates that coated cladding, doped pellets, higher burnup limits, and increased enrichments levels will be the first set of technologies submitted to the NRG for licensing review.

The next sections describe the NRC's preparations for each of these technologies.

Coated Cladding Nuclear fuel vendors are currently researching and testing fuel that uses a zirconium alloy cladding with a thin outer*coating of either chromium or a proprietary material. This thin coating is intended to provide resistance to corrosion and wear, as well as additional operational flexibility for power reactors. The NRC has not yet received any in-reactor topical reports or license amendment requests for batch loads of fuel with coated cladding. However, the NRG has actively engaged with stakeholders to understand vendor approaches and to obtain information that will facilitate NRG licensing reviews.

The NRG is prepared to review future licensing submittals for coated fuel rod cladding. For example, the NRG contracted with nuclear fuels experts from the DOE's Pacific Northwest National Laboratory to perform a literature review (Ref. 9) and a PIRT exercise on degradation and failure phenomena related to chromium-coated fuel rod cladding. The NRG published interim staff guidance (ISG) on the subject (Ref. 10). This ISG informs NRG staff reviews of topical reports on coated cladding fuels, which should help reduce the potential for schedule uncertainty and delays. As stated above, although the NRG has not yet received any vendor topical reports for batch loads of coated cladding, the NRC has received multiple license amendment requests related to lead test assemblies (L TAs) with coated cladding features, including two with coated cladding and doped pellet features (Refs. 11 , 12). LTAs are fuel assemblies that contain design features or materials-for which additional data may be needed to support approval for unrestricted use. 4 Doped Pellets Fuel vendors are researching and testing fuel pellets that mix other materials, known as dopants, into the pellet during the manufacturing process. These dopants change the physical properties of the resulting fuel pellet with the goal of providing additional operational flexibility during normal operation and promoting fission product gas retention during accident conditions.

The NRC reviewed and approved three doped pellet topical reports 5 for boiling-water reactor fuels (Refs. 13, 14, 15) and four license amendment requests (Refs. 16, 17, 18, 19). The NRC is in the process of reviewing one doped pellet topical report for pressurized-water reactor (PWR) fuels (Ref. 20).

Higher Burnup The current fuel burnup limits differ slightly among fuel vendors and fuel products, b_ut fuel assemblies are limited to a maximum rod-average burnup of 62 G\Nd/MTU. Some potential applicants are interested in raising this limit to a rod-average burnup of approximately 75 GWd/MTU. Burnup limits are not specified in NRC regulations but instead are incorporated into power reactor licenses after they are approved in topical -reports.

The NRC has reviewed and approved .one higher-burnup-related topical report (Ref. 21); which covered increased burn up limits for fuel cladding material. The NRC is also reviewing an additional higher burnup topical report, which would support extending burnup to 68 GWd/MTU in PWRs (Ref. 22). The NRG is currently reviewing an additional request to re-:-insert previously irradiated LTAs with coated cladding and doped pellet technology into a reactor, to gather data about performance at higher burn ups (Ref. 23)..

To enhance the efficiency of the licensing process, the NRC is revising Regulatory Guide (RG) 1.183, Revision 0, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," (Ref. 24), to expand its applicability to encompass fuel burnup extensions up to 68 GWd/MTU (rod-average) and enrichments up to 8 weight-percent uranium-235 for near-term A TF technologies and modern fuel management. The approach to this update is to leverage readily available data and analyses to support these near-term licensing activities. This guidance is intended for large light-water reactor designs and specifies the content that should be included in submittals. This includes the scope, nature, and documentation of associated analyses and evaluations with consideration of impacts on analyzed risk. The guidance describes methods that the NRC staff considers acceptable in complying with regulations for design-basis accident dose corn;equence analysis using an alternative source term . Ongoing research efforts are underway to further expand the applicability of the proposed Revision 1 to RG 1.183 to accommodate the industry's longer-term burnup and enrichment targets. NRC staff is continuing to engage with _stakeholders on both 4

The term "unrestricted use" means that, unlike LTAs, the fuel has been approved for use at a plant without limits on quantity or placement within the core (except for -those limits that are part of the approval). License amendments for approval of unrestricted use are commonly called "fuel transitions." Similar terms sometimes used include "batch quantities* and "reload quantities* of fuel assemblies.

  • _

5 A topical report is a report containing generic technical or regulatory information on a topic relevant.to nuclear power plant safety or licensing. The NRC process is utilized to increase efficiency by providing for a streamlined review of a subject with generic applicability and potential for subsequent referencing in multiple licensing actions.

revisions, through public meetings (Ref. 25), comment periods, and routine engagements. The staff will incorporate the results of this research into the anticipated Revision 2 of RG 1.183. The NRC is working to complete both revisions to RG 1.183 in a timeframe that will support the industry's stated timeline for the deployment of batch loads of higher burn up fuel.

A phenomenon called fuel fragmentation, relocation, and dispersal (FFRD) remains an area of significant interest to the NRC. The NRC's regulations require that the fuel be maintained in a coolable geometry following a design-basis LOCA. In practice, this has meant demonstrating that the fuel stack remains intact and resides within the fuel rod cladding, and that the fuel bundle array is maintained. Research on higher burnup fuel has shown that fuel pellets can break apart into fine (less than 1 millimeter) fragments when subjected to accident conditions.

Experimental data has shown that the extent of fragmentation increases with burnup. Highly fragmented fuel has been observed to relocate axially with gravity, into the regions of the fuel rod that balloon under LOCA conditions. If rod rupture occurs, experiments have shown that the fragmented and relocated fuel can disperse out of the rod into the coolant. Research has also shown that additional fission product gas may be released under LOCA conditions, which may impact fuel rod ballooning and burst behavior. Dispersal of copious quantities of fuel particles creates an unknown geometry, making it difficult to demonstrate long-term residual heat removal for both the intact portion of the core and the dispersed fuel particles. Such dispersal could also present other potential safety concerns (e.g., re-criticality of dispersed fuel and energetic fuel-coolant interactions). The extent to which FFRD could constitute a safety concern is dependent on the design and operational characteristics chosen for the fuel because these characteristics will impact if, or how many, fuel rods are projected to burst during a postulated LOCA. Therefore, fuel vendors and licensees will need to address FFRD as part of their applications for higher burnup fuels.

The NRC has published multiple documents on FFRD-related research over the past 15 years, culminating in the issuance of Research Information Letter (RIL) 2021-13, "Interpretation of

-Research on Fuel Fragmentation, Relocation, and Dispersal at High Burnup," dated December 17, 2021 (Ref. 26). RIL 2021-13 presents research from several domestic and international research programs, including the Studsvik Cladding Integrity Project and the Halden Reactor Project, related to transient fission product gas release and FFRD under LOCA conditions. RIL 2021-13 provides the NRC technical reviewers with timely interpretations of a complex technical issue in a way that is easy to use and presented in the context of fuel safety. The NRC will be sponsoring a PIRT exercise related to fuel dispersal and its consequences, based, in part, on information in RIL 2021-13. This exercise is expected to provide more information on the important aspects of FFRD to better focus the agency's evaluations.

To remain aware of the progress in addressing both the technical and licensing issues associated with FFRD, the NRC staff is encouraging fuel vendors to have preapplication meetings on their licensing approaches to FFRD; three vendors have done so to date. The NRC staff anticipates additional preapplication meetings once vendors have further refined their approaches. Additionally, the NRC's participation as an observer in CRAFT will allow the agency to understand potential applicants' approaches to filling data gaps and the nc:ivel approaches to licensing requests that are being developed for FFRD.

Members of the industry have stated that they intend to pursue a risk..cinformed approach to addressing FFRD for PWRs. The NRC has historically considered risk when licensing the use of nuclear fuel and can use its existing risk-informed framework to inform the licensing reviews of these new fuel types. In June 2021 and August 2022 (Ref. 27, 28), the NRC met with representatives from the nuclear industry for a high-level discussion about an EPRl-led effort to develop an alternative licensing strategy for higher burnup fuel, which includes a risk-informed analysis of LOCA-induced FFRD. TheNRC has encouraged the industry to continue to engage with the agency as it further develops this approach so that the agency can identify any potential technical or policy issues that may arise early and the industry can take steps to address them.

In addition to the ATF Project Plan, the NRC has proactively reached out to potential applicants on higher burnup limits through three NRC-led public workshops. The first, which took place on July 30, 2020 (Ref. 29), included an overview of higher burnup limits and increased enrichment levels, as well as an exchange of information focusing on the components of a quality submittal.

During the followup workshop on June 10, 2021 (Ref. 30), the NRC discussed RIL 2021-13, the environmental aspects of higher burnup limits, and higher burnup spent fuel storage and transportation issues. The third workshop, which took place on August 24, 2022 (Ref. 31),

included an update on the increased enrichment rulemaking, discussed below; industry FFRD risk-informed approaches, discussed in the previous paragraph; and the NRC regulatory framework assessment, discussed above; as well as a discussion on the outlook for ATF technologies. These three workshops provided a valuable exchange of information with a variety of stakeholders.

Increased Enrichment The existing regulatory framework supports the licensing of fuel with increased enrichment levels (from 5 to approximately 10 weight-percent uranium-235) in the near-term using license amendments and exemptions. License amendments would be needed to change the enrichment limits in individual licenses, and each licensee that wishes to exceed the enrichment specified in the regulations could seek an exemption.

In December 2021, the staff provided the Commission SECY-21-0109, "Rulemaking Plan on Use of Increased Enrichment of Conventional and Accident Tolerant Fuel Designs for Light-Water Reactors" (Ref. 32), which requested approval to initiate a rulemaking to amend requirements for the use of light-water reactor fuel containing uranium enriched to greater than 5 weight-percent uranium-235 for increased regulatory efficiency and consistency. On March 16, 2022, the Commission approved the staff's proposal to initiate a rulemaking, as discussed in the staff requirements memorandum for SECY-21-0109 (Ref. 33). This rulemaking will produce a generic approach informed by public comment and reduce the need for individual exemption requests. The staff plans to complete this effort by 2026.

The NRC is in the process of reviewing five topical reports that support increasing enrichment for PWR fuels beyond the current limit of 5 weight-percent uranium-235 (Refs. 34, 35, 36). The NRC is also reviewing a license amendment request to load LTAs with coated cladding, doped pellets, and increased enrichment into a PWR (Ref. 37).

Longer-Term Accident Tolerant Fuel Concepts The NRC monitors progress on the development of iron-chromium-aluminum (FeCrAI) cladding and longer-term ATF concepts, such as silicon carbide cladding. The NRC staff frequently engages with the DOE and fuel vendors to understand the status and future direction of these concepts.

The NRG has not yet received the relevant detailed schedules, specific physical characteristics, or technical data from vendors for FeCrAI or other longer-term A TF concepts. The NRC staff has, however, begun preliminary research to prepare for these reviews and to determine whether, and to what extent, changes to the existing regulatory framework may be needed to safely license these longer-term ATF'concepts. With uncertain submittal timelines for these technologies, it would be premature for the NRC to undertake more intensive preparatory activities at this time.

Front-End and Back-End of the Fuel Cycle Regarding licensing the front-end (i.e., enrichment, fuel fabrication; and fresh fuel transportation) and the back-end (i.e., spent fuel transportation and storage) of the fuel cycle for coated cladding, the NRC staff has reviewed the applicable existing regulations and guidance.

The staff has also performed literature reviews of the rel_evant proposed ATF concepts and has determined that no addjtions or modifications to the front-end or back-end regulatory framework are needed. These literature reviews included consideration of doped pellets, coated cladding, .

and increased enrichment up to 10 weight-percent uranium-235 for both the front-end and back-end of the fuel cycle, as well as increased burnup for the back-end of the fuel cycle. The NRC is identifying areas where more datawould improve confidence in the predictive capabilities of computer codes and reduce uncertainties. This includes key end-of-life characteristics of spent fuel, such as fission product gas release, nuclear fuel rod internal pressure, cladding oxide thickness, and hydrogen content (Ref. 38), in addition to evaluating the impact of increased enrichment and higher burnup fuels on decay heat and radionuclide inventory. These activities will prepare the NRC to efficiently review front-end and back-end _licensing actions consistent with the agency's safety and security mission and in parallel with the industry's efforts.

The NRC has approved multiple licensing actions for fuel enrichment and fresh fuel transportation. For example, with respect to increased enrichment, the NRC has reviewed and approved several licensing actions that serve as preparatory steps to allow fuel cycle facilities to achieve enrichments above 5 weight-percent uranium-235 (Refs. 39, 40). The NRC has issued a variety of approvals related to the transportation of ATF concepts, increased enrichment, and higher burnup fuel designs. For example, the NRC has issued one approval (Ref. 41) that allows a fuel vendor to transport fresh fuel rods with doped fuel pellets, coated cladding,*and enrichments above 5 weight-percent uranium-235. The NRC approved two additional chan*ges to this same transportation package in April 2022 to allow new cladding coating types, doped pellets, and additional increased enrichment contents (Ref. 42); and in January 2023, to allow international shipments of ATF LTAs with coated cladding, doped pellets, and increased enrichments (Ref 43). The NRC also approved a revised certificate of compliance for a transportation package for fresh fuel with coated cladding (Ref. 44). In March 2023, the NRC issued a transportation package approval (Ref. 45) for shipments of uranium hexafluoride with an enrichment up to 20 weight-percent uranium-235.

The NRC is also undertaking actions to ensure efficiency and.effectiveness in its independent safety reviews for the front~end and back-end of the fuel cycle. As mentioned above, the NRC has begun a rulemaking to evaluate the regulations that limit enrichments to 5 weight-percent uranium-235, as discussed in the staff requirements memorandum for SECY-21-0109 (Ref. 33).

Separately, the NRC has also issued letters to potential applicants identifying critical path items for reviewing front-end licensing actions.

  • Conclusion The NRC is ready to review license amendment requests to support the batch-loading of fuel with near-term ATF concepts (i.e., coated cladding and doped pellets), higher burnup limits, and increased enrichment levels. In addition, the NRC continues to take steps to maximize its preparedne_ss and to improve the efficiency of the licensing process to safely license new fuel designs. The NRC will continue to engage potential applicants, licensees, and other stakeholders to ensure that ATF concepts, higher burnup, and increased enrichment licensing reviews are both timely and thorough and that they provide reasonable assurance of adequate protection of public health and safety, promote the common defense and security, and protect the environment.

References

1. U.S. Nuclear Regulatory Commission, A TF-related Licensing Actions, https://www.nrc.gov/reactors/atf/licensinq-actions.html (last reviewed/updated March 30, 2023).
2. U.S. Nuclear Regulatory Commission, "Regulatory Framework Applicability Assessment and Licensing Pathway Diagram for the Licensing of ATF-Concept, Higher Burnup, and Increased Enrichment Fuels," May 2022 (Agencywide Documents Access and Management System Accession No. ML22014A112).
3. U.S. Nuclear Regulatory Commission, "Project Plan to Prepare the U.S. Nuclear Regulatory Commission for Efficient and Effective Licensing of Accident Tolerant Fuels,"

Version 1.2, September 2021 (ML21243A298).

4. Bo Pham, NRC, letter to Nima Ashkeboussi, Nuclear Energy Institute, "Scheduling Expectations Regarding the Licensing of Accident Tolerant, Increased Enrichment, and Higher Burnup Fuels," January 11, 2022 (ML22003A168).
5. "Staff Requirements - Overview of Accident Tolerant Fuel Activities," January 30, 2023 (ML23030A013).
6. U.S. Nuclear Regulatory Commission, "Generic Environmental Impact Statement for License Renewal of Nuclear Plants," NUREG-1437, Volume 1, Revision 1, June 2013 (ML13106A241).
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8. U.S. Nuclear Regulatory Commission, A TF-related Documents, https:/lwww.nrc.gov/reactors/atf/related-docs.html (last reviewed/updated February 9, 2023).
9. K.G. Geelhood and W.G. Luscher, Pacific Northwest National Laboratory, "Degradation and Failure Phenomena of Accident Tolerant Fuel Concepts: Chromium Coated Zirconium Alloy Cladding," PNNL-28437, January 2019 (ML19036A716) and -

PNNL-28437, Revision 1, June 2019 (ML19172A154).

10. U.S. Nuclear Regulatory Commission, "Supplemental Guidance Regarding the Chromium-Coated Zirconium Alloy Fuel Cladding Accident Tolerant Fuel Concept,"

A TF:-ISG-2020-01 ,* January 2020 (ML19343A121 ).

11. Joel S. Wiebe, NRC, letter to Bryan C. Hanson, Exelon Generation Company, LLC, "Byron Station, Unit No. 2 - Issuance of Amendment Regarding Use of Accident Tolerant Fuel Lead Test Assemblies (EPID L-2018-LLA-0064)," April 3, 2019 (ML19038A017).
12. Michael L. Marshall Jr., NRC, letter to David P. Rhoades, Exelon Generation Company, LLC, "Calvert Cliffs Nuclear Plant, Units 1 and 2 - Issuance of Amendment Nos. 339 and 317 Regarding Accident Tolerant Fuel Lead Test Assemblies (EPID L-2019-LLA-0282),"

January 26, 2021 (ML20363A242).

13. U.S. Nuclear Regulatory Commission, "Final Safety Evaluation for General Electric Hitachi Nuclear Energy Americas, LLC, Topical Report NEDC-33406P, Revision 2,

'Additive Fuel Peliets for GNF Fuel Designs' (TAC No. ME3082)," November 9, 2015 (ML15195A459).

14. U.S. Nuclear Regulatory Commission, "Final Safety Evaluation by the Office of Nuclear Reactor Regulation: Topical Report ANP-10340P-A, Revision 0, 'Incorporation of Chromia-Doped Fuel Properties in AREVA Approved Methods,'" Project No. 99902041, May 23, 2018 (ML18144A951).
15. U.S. Nuclear Regulatory Commission, "Final Safety Evaluation by the Office of Nuclear Reactor Regulation for the Westinghouse Electric Company Topical Report WCAP-18482-P/WCAP-18482-NP, Revision 0, 'Westinghouse Advanced Doped Pellet Technology (ADOPT') Fuel,"' June 13, 2022 (ML22125A156).
16. Andrew Hon, NRC, letter to John A. Krakuszeski, Duke Energy Progress, LLC, "Brunswick Steam Electric Plant, Units 1 and 2-lssuance of Amendment Nos. 299 and 327 to Revise Technical Specification 5.6.5b to Allow Application of Advanced Framatome Atrium 11 Fuel Methodologies (EPID L-2018-LLA-0273)," March 6, 2020 (ML20073F186).
17. Sujata Goetz, NRC, letter to Kevin Cimorelli, Susquehanna Nuclear, LLS, ."Susquehanna Steam Electric Station, Units 1 and 2 - Issuance of Amendment Nos. 279 and 260 to Allow Application of Advanced Framatome Atrium 11 Fuel Methodologies (EPID L-2019-LLA-0153)," January 21, 2021 (ML201688004).
18. Kimberly J. Green, NRC, letter to James Barstow, Tennessee Valley Authority, "Browns Ferry Nuclear Plant, Units1, 2, and 3 - Issuance of Amendment Nos. 325, 348, and 308 Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564-A, Revision 2, "Safety Limit MCPR," in Support of ATRIUM 11 Fuel Use (EPID L-2021-LLA-0132)," January 13, 2023 (ML22348A066).
19. Robert F.. Kuntz, NRC, letter to Christopher P. Domingos, Northern States Power Company-Minnesota, "Monticello Nuclear Generating Plant - Issuance of Amendment No. 210 Re: Revised Methodologies for Determining the Core Operating Limits (EPID L-2021-LLA-0144)," January 13, 2023 (ML23012A156).
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'Evaluation of Advanced Cladding and Structural Material (M5) in PWR Reactor Fuel (EPID L-2019-TOP-0054)'," January 13, 2023 (ML22353A089).

22. Westinghouse Electric Company, "Submittal of Topical Report WCAP-18446-P/WCAP-18446-NP, Revision 0, 'Incremental Extension of Burnup Limit for Westinghouse and Combustion Engineering Fuel Designs' Proprietary/Non-Proprietary," December 2020 (ML203508834).
23. Kevin Lueshen, Constellation Energy Generation, LLC, letter to NRC, "License Amendment Request to Reinsert an Accident Tolerant Fuel Lead Test Assembly (EPID L-2022-LLA-0131 )," August. 31, 2022 (ML22243A094).
24. U.S. Nuclear Regulatory Commission, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," RG 1.183, Revision 0, July 2000 (ML003716792).
25. Carla Roque-Cruz, NRC, memorandum to Kevin Hsueh, NRC, "Summary of the August 24, 2022, Source Terms and Radiological Consequence Analyses,"

October 25, 2022 (ML22300A097).

26. U.S. Nuclear Regulatory Commission, "Interpretation of Research on Fuel Fragmentation, Relocation, and Dispersal at High Burnup," RIL 2021-13, December 2021 (ML21313A145).
27. Michael D. Orenak, NRC, memorandum to Dennis C. Morey, NRC, "Summary of the June 2, 2021, Public Meeting with NEI and EPRI on the EPRI Approach to Licensing Higher Burnup Fuel (EPID L-2021-TOP-0012)," June 23, 2021 (ML21167A243).
28. Stephanie Devlin~Gill, NRC, memorandum to Richard Chang, NRC, "Sl,!mmary of the August 30, 2022, Pre-Submittal, Partially Closed Meeting with the Electric Power Research Institute Regarding the Use of the Alternate License Strategy to Address Loss-of-:Coolant Accident Induced Fuel Fragmentation, Relocation, and Dispersal (EPID L-2022-TOP-0044)," September 16, 2022 (ML22249A002).
29. Michael D. Orenak, NRC, memorandum to Dennis C. Morey, NRC, "Summary of the July 30, 2020, Higher Burnup Workshop Category 2 Public Meeting,"

September 24, 2020 (ML20260H000).

30. Michael D. Orenak, NRC, memorandum to Dennis C. Morey, NRC, "Summary of the June 10, 2021, Higher Burnup Workshop 11," June 30, 2021 (ML21176A028).
31. Stephanie Devlin-Gill, NRC, memorandum to Richard Chang, NRC, "Summary of the August 24, 2022, Higher Burnup Workshop Ill," September 22, 2022 (ML22256A017).
32. U.S. Nuclear Regulatory Commission, "Rulemaking Plan on Use of Increased Enrichment of Conventional and Accident Tolerant Fuel Designs for Light-Water Reactors," SECY-21-0109, December 20, 2021 (ML21232A232).
33. U.S. Nuclear Regulatory Commission, "Staff Requirements-SECY 0109-Rulemaking Plan on Use of Increased Enrichment of Conventional and Accident Tolerant Fuel Designs for Light-Water Reactors," SRM-SECY-21-0109, March 16, 2022 (ML22075A103).

34 . Framatome Inc., "Increased Enrichment for PWRs," ANP-10353NP, Revision 0, January 2021 (ML21035A075).

35. U.S. Nuclear Regulatory Commission, "Revision O of LANCR02/PANAC11 and Revision 4 of LANCR02 Licensing Topical Reports," NEDC-33935P, NEDC-3376P, and NEDC-33377P, December 17, 2021 (ML21351A266).
36. U.S. Nuclear Regulatory Commission, "Submittal of Implementation of LANCR02/PANAC11 in Downstream Methods Licensing Topical Report," NEDO-33935, Supplement 1, Revision 0, October 31, 2022 (ML22304A666).
37. Cheryl A. Gayheart, Southern Nuclear Operating Company, letter to NRC, "License Amendment Request and Exemptions to Allow Use of Lead Test Assemblies for Accident-Tolerant Fuel," June 30, 2022 (ML221818156).
38. Ken Geelhood and Beric Wells, Pacific Northwest National Laboratory, "Assessment of FAST for Spent Fuel Calculations on High Burnup and High Enriched Fuel,"

PNNL-32222, October 2021 (ML21298A123).

39. Jacob I. Zimmerman, NRC, letter to Wyatt Padgett, Louisiana Energy Services, LLC, "U .S. Louisiana Energy Services -Amendment 85, Change to License Condition 68 and Enrichment Limit (Enterprise Project Identification Number L-2019-LLA-0264),"

May 19, 2020 (ML20119A040).

40 . Tyrone D. Naquin, NRC, letter to Scott P. Murray, Global Nuclear Fuel-America, "Global Nuclear Fuel-Americas LLC: Review of the Minimum Margin of Subcriticality for up to 8 Weight Percent Enrichment of Uranium-235 and Amendment 16 (Enterprise Project Identifier L-2020-LNS-0002)," August 13, 2020 (ML20219A463).

41 . John B. McKirgan, NRC, letter to Tanya Sloma, Westinghouse Electric Company, LLC, "Revision No. 12 of Certificate of Compliance No. 9297 for the Model Nos. Traveller STD, Traveller XL, and Traveller WER Packages," September 15, 2020 (ML20255A297).

42. Yoira K. Diaz-Sanabria, NRC, letter to Wes Stilwell, Westinghouse Electric Company, LLC, "Certificate of Compliance No. 9380, Revision No. 1, for the Model No. Traveller STD & XL Package," April 7, 2022 (ML22080A172).
43. Yoira K. Diaz-Sanabria, NRC, letter to Wes Stilwell, Westinghouse Electric Company, LLC, "Certificate of Compliance No. 9380, Revision No. 2, for the Model No. Traveller STD & XL Package," January 26, 2023 (ML23024A177).
44. John B. McKirgan, NRC, letter to Timothy J. Tate, Framatome Inc., "Revision No. 11 of Certificate of Compliance No. 9319, for the Model Nos. MAP-12 and MAP-13 Transportation Packages," January 10, 2019 (ML19011A011).
45. Yoira K. Diaz-Sanabria, NRC, letter to Franz Hilbert, Orano NCS GmbH, "Revision No. 0 of Certificate of Compliance No. 9388 for the Model No. DN30-X Package," March 27, 2023 (ML230838979).
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