ML23325A089
| ML23325A089 | |
| Person / Time | |
|---|---|
| Issue date: | 10/18/2023 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-2580 | |
| Download: ML23325A089 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Fuels, Materials, and Structures Subcommittee (Open)
Docket Number: (n/a)
Location: teleconference Date: Wednesday, October 18, 2023 Work Order No.: NRC-2580 Pages 1-114 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +
7 FUELS, MATERIALS AND STRUCTURES SUBCOMMITTEE 8 + + + + +
9 WEDNESDAY 10 OCTOBER 18, 2023 11 + + + + +
12 The Subcommittee met via Video 13 Teleconference, at 1:03 p.m. EDT, Ronald Ballinger, 14 Chairman, presiding.
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2 1 COMMITTEE MEMBERS:
2 RONALD G. BALLINGER, Chair 3 VICKI BIER, Member 4 VESNA DIMITRIJEVIC, Member 5 GREGORY HALNON, Member 6 JOSE MARCH-LEUBA, Member 7 ROBERT MARTIN, Member 8 DAVID PETTI, Member 9 JOY L. REMPE, Member 10 THOMAS ROBERTS, Member 11 MATTHEW SUNSERI, Member 12 13 ACRS CONSULTANT:
14 DENNIS BLEY 15 STEVE SCHULTZ 16 17 DESIGNATED FEDERAL OFFICIAL:
18 ZENA ABDULLAHI 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 1 ALSO PRESENT:
2 MELANIE ANANIA, Interpreter 3 GAVIN GOBBLE BAKER, Interpreter 4 PHILIP BENAVIDES, NMSS 5 PAUL CLIFFORD, Public Participant 6 ELIJAH DICKSON, NRR 7 DONNA GILMORE, Public Participant 8 SCOTT KREPEL, NRR 9 EDWIN LYMAN, Public Participant 10 SANDRA McCLURE, Interpreter 11 JOSEPH MESSINA, NRR 12 SCOTT MOORE, ACRS 13 DON PALMROSE, NMSS 14 JASON PIOTTER, NMSS 15 ASHLEY SMITH, NRR 16 KALENE WALKER, Public Participant 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 1 CONTENTS 2 Call to Order and ACRS Chairman 3 Introductory Remarks . . . . . . . . . . . . . . 4 4 NRR Staff Leadership Opening Remarks . . . . . . 7 5 Overview . . . . . . . . . . . . . . . . . . . . 9 6 Control Room Design Criterion of 7 10 CFR 50.67 and GDC-19 . . . . . . . . . . 17 8 Criticality Accident Requirements 9 of 10 CFR 50.68 . . . . . . . . . . . . . . 33 10 Environmental Requirements of 10 11 CFR 51.51 and 10 CFR 51.52 . . . . . . . . 31 12 Packaging Requirements of 10 CFR 13 71.55 . . . . . . . . . . . . . . . . . . . 40 14 Fuel Fragmentation, Relocation and 15 Dispersal . . . . . . . . . . . . . . . . . 52 16 Public Comments . . . . . . . . . . . . . . . . . 83 17 Discussion . . . . . . . . . . . . . . . . . . . 91 18 Adjourn 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 1 P-R-O-C-E-E-D-I-N-G-S 2 1:03 p.m.
3 CHAIR BALLINGER: Good afternoon. The 4 meeting will now come to order.
5 This a meeting of the Fuel, Materials and 6 Structures Subcommittee of the Advisory Committee on 7 Reactor Safeguards. Today's meeting is virtual.
8 I'm Ron Ballinger, Chairman of today's 9 Subcommittee meeting.
10 The ACRS members in attendance are Bob 11 Martin, Dave Petti --
12 MEMBER SUNSERI: Matt Sunseri.
13 CHAIR BALLINGER: -- Matt Sunseri, Joy 14 Rempe.
15 There's a lot of people. I'm struggling 16 through here.
17 Steve Schultz, one of our consultants.
18 Tom Roberts, Vesna Dimitrijevic, Vicki 19 Bier.
20 And I have probably missed somebody, like 21 I did earlier this morning. But if I have, I 22 apologize.
23 MEMBER MARCH-LEUBA: Jose. Jose is here.
24 CHAIR BALLINGER: Oh, Jose March-Leuba.
25 Okay.
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6 1 So, if I've missed somebody, I apologize.
2 During today's meeting, Zena Abdullahi is 3 present as the DFO.
4 During today's meeting, the Subcommittee 5 will review the staff's regulatory basis for increased 6 enrichment of conventional and accident-tolerant fuel 7 designs for LWRs and will hold discussions with the 8 NRC staff and other interested people.
9 The ACRS was established by the Atomic 10 Energy Act and is governed by the Federal Advisory 11 Committee Act. The ACRS is independent of the ACRS 12 staff.
13 When applicable, ACRS issues publicly-14 available letters that provide the Commission 15 independent technical reviews for NRC staff's Safety 16 Evaluations of licensees' amendments to their 17 operating licenses.
18 The Subcommittee will gather information, 19 analyze relevant technical topics/facts, and formulate 20 proposed positions and actions, as appropriate for 21 deliberation by the full Committee.
22 Again, today's meeting is being held 23 virtually over Microsoft Teams for ACRS staff members, 24 NRC staff, and the public.
25 There's a telephone bridge line that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 1 been established, as well as a Teams link allowing 2 participation.
3 When addressing the Subcommittee, the 4 participants should, first, identify themselves and 5 speak with sufficient clarity and volume, so that they 6 may be readily heard.
7 When not speaking, we request that 8 participants mute their computer microphone or their 9 phone by pressing *6. If you don't do that, we'll 10 likely get feedback which will cause us issues.
11 And now, I think I need to turn it over to 12 Scott Krepel. Are you going to make initial comments, 13 Scott?
14 MR. KREPEL: (speaking through a sign 15 language interpreter throughout the proceedings) Hi.
16 Yes, I do plan to. Thank you.
17 I am Scott Krepel, speaking through a sign 18 language interpreter. And many of you know me. I am 19 the Branch Chief for the Nuclear Methods and Fuels 20 Analysis Branch. I'm presenting the Division of 21 Safety Analysis.
22 And I have to admit I was a little bit 23 disappointed when I found out that this would be 24 completely virtual because I can't sit on the side 25 table and see everybody in person today, but I do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 1 appreciate being here to take the opportunity to 2 discuss this topic. And I know that we will have more 3 to come on this topic in the future.
4 Soon, you will hear a presentation and you 5 will have the opportunity to ask questions on the 6 regulatory basis for the increased enrichment 7 rulemaking, which has been issued for public comment 8 just a few weeks ago.
9 This is part of a broad effort at the NRC 10 to prepare licensees for accident-tolerant fuel 11 technology and create advanced enrichment and advanced 12 technologies, as well as increased enrichment and high 13 burnup -- with the goal for energy independence and 14 climate change.
15 Hold on one second for the interpreter.
16 So, here in DSS, NMSS, and NRR, we are 17 working collaboratively together to make sure that 18 increased enrichment (audio interference) are 19 maximizing the licensees' ability for pursuing 20 business opportunities, for increasing their 21 enrichment, as well as all aspects of the fuel cycle.
22 Increased enrichment implies high burnup 23 because the licensees, you know, for them to be able 24 to maximize and take advantage of increased 25 enrichment, they would need to go through burnup from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 1 where they are currently licensed. And so, you will 2 hear some discussion about how the NRC plans to 3 address those issues related to high burnup as well as 4 fuel fragmentation, relocation, and dispersal, also 5 known as FFRD.
6 I look forward to your comments and 7 questions for this reg basis, and thank you for your 8 time. I appreciate you allowing me the time to give 9 my remarks.
10 CHAIR BALLINGER: This is Ron Ballinger.
11 I, too, am a bit saddened by us not being 12 in person. This is largely the result of the 13 potential shutdown, and things like that, that just 14 got things a little bit confused. So, I would have 15 liked to have seen in-person as well.
16 So, who is doing the presenting?
17 MR. BENAVIDES: Phil Benavides here. I'll 18 do the presenting.
19 Next slide.
20 CHAIR BALLINGER: Okay. Thank you.
21 MR. BENAVIDES: Yes.
22 Yes, thank you for your time.
23 I am Phil Benavides. I am a Project 24 Manager in the Office of Nuclear Material Safety and 25 Safeguards, assigned as the Project Manager to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 1 rulemaking on the increased enrichment of conventional 2 and accident-tolerant fuel designs for light water 3 reactors. I'm going to provide an overview of the 4 enrichment rulemaking.
5 Next slide.
6 As a way to provide a background of how we 7 got to this point, I'd like to go back to the 8 beginning when the issue was identified. Throughout 9 the last few years, staff has seen an increased 10 interest from industry on the use of fuel enriched to 11 above 5 weight percent U-234.
12 The NRC noted that, although the current 13 regulatory framework allows for licensing of fuel 14 above 5 weight percent, the use of this fuel may 15 result in numerous exemptions requests for licensees.
16 So, as a solution, NRC staff began 17 pursuing rulemaking, rather than licensing by 18 individual exemption. In December of 2021, the staff 19 provided to the Commission SECY-21-0109, requesting 20 approval to begin the rulemaking process.
21 Slide 5, please.
22 In March 2022, the Commission granted 23 approval to begin the rulemaking process, as described 24 in the Staff Requirements Memorandum for SECY-21-0109.
25 The purpose of this rulemaking effort is to provide a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 1 comprehensive review of regulations and guidance that 2 may be impacted by the use of fuel enriched above 5 3 weight percent.
4 The Commission also specified several 5 considerations to evaluate, in addition to what was 6 specified in the rulemaking plan. These are listed in 7 the slide shown.
8 Specifically, the rule should apply to the 9 fuel enriched up to 20 weight percent, or HALEU. The 10 staff should address fuel fragmentation, relocation, 11 and dispersal, and take a risk-informed approach.
12 Slide 6.
13 The NRC issued a regulatory basis on 14 September 8th. This regulatory basis discusses the 15 regulatory issues and alternatives to resolve them; 16 considers legal, policy, and technical issues; 17 considers cost and benefits for each alternative, and 18 identifies the NRC staff-recommended alternative for 19 most regulatory issues, with FFRD being an outlier, 20 which we'll wait for public input received during the 21 public comment period.
22 Stakeholder involvement includes a public 23 meeting scheduled for October 25th and the public 24 comment period, which is open until November 22nd.
25 The proposed rule is currently due to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
12 1 Commission December of 2024.
2 Slide 7, please.
3 The regulatory basis discusses these 4 technical topics.
5 Oh, sorry. Thank you. There's a 6 question?
7 MEMBER REMPE: Yes. This is Joy. Can you 8 hear me okay?
9 MR. BENAVIDES: Yes, we can hear you.
10 MEMBER REMPE: Great. I have a couple of 11 things.
12 First, just to make a point clear, the 13 public meeting will give you some input, but you do 14 not intend to have any additional thoughts on FFRD by 15 the November full Committee meeting? You don't plan 16 to elaborate and make a recommendation in the next 17 couple of weeks? Is that a true statement?
18 MR. BENAVIDES: That is a true statement.
19 We will wait for the comment period to close; use 20 those comments that are received to help inform our 21 path forward, while developing the proposed rule.
22 MEMBER REMPE: Okay. And then, the other 23 question I have, I wasn't sure where to put this. And 24 so, I'm just going to throw it out here now.
25 MR. BENAVIDES: That's okay.
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13 1 MEMBER REMPE: You know, it talks about 2 the Commission wanting you to deal with higher 3 enriched fuel, but, then, the title of this 4 presentation is also pertaining to accident-tolerant 5 fuel designs. And I realize we don't regulate to 6 beyond-design events.
7 But if we're going to include accident-8 tolerant fuel designs, at some point, one needs to 9 think about the fact that You're going to be having 10 this extended period where the cladding still would 11 relocate at a temperature much lower than the fuel --
12 or excuse me, I'm sorry -- that the cladding would 13 relocate at a higher temperature, but the control rods 14 relocate at a much lower temperature still. So, you 15 have this extended period where the control rods are 16 gone and the better cladding that can stay at a higher 17 temperature -- and sometimes you see 30 minutes; 18 sometimes you see an hour.
19 But it seems like somebody needs to think 20 about this. The only place I could even think that 21 this might have come into play was with the Sandia 22 alternative source term update. And they did talk 23 about the fact they had the control rods go at a lower 24 temperature than the cladding and they bumped up the 25 fuel.
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14 1 But I didn't see anything about what the 2 staff is going to do with guidance or something. It's 3 going to have to require something to make sure you 4 have borated water and that you can appropriately 5 predict what would occur with having coolant added.
6 And how is the staff going to deal with 7 that issue? I'm glad to see a head shaking up and 8 down. So, you are aware of what I'm trying to say.
9 Thank you.
10 MR. BENAVIDES: Yes, I think that the 11 staff -- and I don't want to speak for Joey and 12 Ashley, when they get to their portion of the 13 presentation -- I think they're going to take whatever 14 comments that we receive during the public 15 meeting/public comment period, and then, they'll take 16 all that into consideration while going forward.
17 And I think a portion of that will also be 18 dependent on which alternative they're going with as 19 well. So, that will have to be part of what they 20 consider, as we move forward through that process.
21 Joey, do you want to wait?
22 MR. MESSINA: I think we can wait on it.
23 Elijah, did you want to say something on 24 that? I saw you shaking your head. I'm not sure if 25 you wanted to.
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15 1 MR. DICKSON: I have nothing to add to 2 that right now --
3 MR. MESSINA: Okay.
4 MR. DICKSON: -- at this point.
5 MEMBER REMPE: Well, I'm not hearing --
6 I'm not seeing anything in the 200-page document we 7 were provided that talked about that there could be 8 some concerns when you have the control rods gone, and 9 then, the fuel is still sitting there, about what the 10 operator action should be. And so, where will that 11 appear? In this rulemaking? Or will it at least 12 acknowledge that this may need some special 13 considerations?
14 MR. DICKSON: In the FFRD portion of the 15 rulemaking, Alternative 4 is one of the dose-based-16 type alternative in regards to FFRD. And we do 17 discuss in there ways in which we would handle post-18 reflood of the core and operator actions. EOP, SAMGs, 19 things of that nature, would be further explored 20 underneath that all.
21 MEMBER REMPE: Okay. So, I did not take 22 it when I looked through Alternative 4.
23 MR. DICKSON: Okay.
24 MEMBER REMPE: But I will go back and look 25 at it more carefully.
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16 1 Thank you.
2 MR. DICKSON: Understood. Yes.
3 MR. BENAVIDES: All right. Thank you, 4 Joy. Thank you, Elijah and Joey.
5 Let's see, on this slide, what does it 6 say? The regulatory basis discusses the technical 7 topics. They'll be described in detail by the NRC 8 subject matter experts during this presentation.
9 Elijah Dickson will discuss control room 10 requirements in 10 CFR 50.67 and GDC 19.
11 Charlie Peabody will discuss criticality 12 accident requirements in 10 CFR 50.68.
13 Don Palmrose will discuss those 14 environmental topics in 10 CFR 51.51 and 51.52.
15 Jason Piotter will discuss the general 16 requirements for fissile material packaging in 17 10 CFR 71.55.
18 And Joey Messina and Ashley Smith will the 19 topic of fuel dispersal, which is a part of the FFRD.
20 And with that, unless there's any 21 additional questions on the overview of the 22 rulemaking, we can move on to the technical topics.
23 All right. Thank you for your time.
24 And I'll hand it off to Elijah.
25 MR. DICKSON: Thank you very much.
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17 1 My name is Elijah Dickson. I'm a Senior 2 Reliability Risk Analyst in the Division of Risk 3 Assessment. I work in the Radiation Protection and 4 Consequence Branch in the Office of Nuclear Reactor 5 Regulation. And I'll be discussing the general 6 control room design criteria of 10 CFR 50.67 of 7 GDC 19.
8 Next slide, please.
9 GDC 19 and 10 CFR 50.67(b)(2), Item 3, 10 provide very specific dose-based criterion of 5 rem 11 total effective dose equivalent for demonstrating the 12 acceptability of the control room design.
13 The history of fuel utilization for the 14 current light water reactor fleet has seen a gradual 15 progression towards higher fuel discharge burnups and 16 increased enrichments in general. There's been enough 17 margin in the facility design basis to accommodate the 18 criterion, even for power uprates up to 120 percent of 19 the originally-licensed, steady-state thermal power 20 levels.
21 Increased power levels, enrichments, and 22 subsequent fuel burnup have a multifaceted impact on 23 the licensee's analysis of record, design-basis 24 accident radiological consequence analysis results.
25 A rule of thumb is that increased power NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
18 1 has a linear effect on these results. An increase in 2 uranium-235 enrichment necessary to reach the desired 3 burnup levels increases the number of fissions in the 4 reactor core, which proportionately increases these 5 results.
6 The impact of higher burnup on 7 radiological consequence results is non-linear where 8 the abundance of different radionuclides, for the most 9 part, peak at different burnup levels. Therefore, 10 depending on how the reactor core is designed, with 11 increased uranium-235 enrichments, operated at higher 12 burnup levels to reach longer cycle times, the impact 13 on the consequence analysis results used to 14 demonstrate compliance with the control room design 15 criteria would increase and, subsequently, decrease 16 the retained margin maintained by licensees to provide 17 for operational flexibility.
18 The NRC recognizes the challenges that 19 licensees face to retain margin for operational 20 flexibility purposes within their licensing basis and 21 the small amount of margin to the control room design 22 criteria itself. The NRC does not want to 23 unnecessarily penalize licensees in seeking increased 24 enrichments that may, then, result in margin 25 reductions, and thereby, require licensees to perform NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
19 1 potentially extensive analyses to demonstrate 2 compliance without a commensurate increase in safety.
3 On to slide 10, please.
4 I'll give a little bit of background.
5 The general objective of the control room 6 design criteria is to ensure the design of the control 7 room is habitability systems provide for a habitable 8 environment, allowing operators to remain in the 9 control room and not evacuate during an emergency.
10 Ideally, you can think of this as a short-sleeve 11 environment, comfortable for them to perform their 12 safety function in the event of an accident.
13 A little bit of history with the control 14 room design criteria is, it was really developed back 15 in the early '70s when the agency was developing 16 Appendix A of 10 CFR Part 50. It was later amended 17 when the agency finalized 10 CFR 50.67 -- that is the 18 accident source term -- back in the late '90s.
19 The criteria didn't foresee how the 20 licensees currently operate their facilities and 21 manage their fuel, considering fuel enrichments above 22 5 weight percent, or maintain coherence with other 23 regulations concerning the Commission's Comprehensive 24 Radiation Protection Framework, which will also be 25 discussed in later slides.
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20 1 Slide 11, please.
2 We would like to note that the design 3 criteria, while they are computed in terms of dose, 4 they are, in fact, figures of merit used to 5 characterize the minimum necessary design fabrication, 6 construction, testing, and performance of requirements 7 for safety-related SSCs.
8 They do not represent actual occupational 9 exposures received during normal and emergency 10 conditions, which are primarily controlled under 11 10 CFR Part 20, "Standards for Protection Against 12 Radiation," and the consideration of the modification 13 of the control room design criteria to a higher, but 14 still safe, performance level.
15 Changes would not alter normal operational 16 or emergency exposure limits controlled under Part 20, 17 and subsequently, within the emergency plans of 50.47.
18 On to slide 12, please.
19 The staff reviewed and analyzed three 20 different alternatives, and I'll go through each of 21 them here.
22 The first alternative, no action. We 23 would be maintaining the current regulatory framework.
24 We would continue to revise existing guidance with 25 updated source terms when data becomes available and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
21 1 update transport models on an ad hoc basis, as the 2 research and resources become available. We plan to 3 issue this work in Reg Guide 1.183, Rev 2., in fiscal 4 year 2025.
5 On to slide 13, please.
6 Alternative two is to pursue rulemaking to 7 amend the control room design criteria and update the 8 current regulatory guidance accordingly with revised 9 assumptions and models, and continue to maintain 10 appropriate and prudent safety margin. The staff has 11 already assessed and identified a range of acceptable 12 values, based on sound regulatory and scientific 13 recommendations. We would be initiating research and 14 analyses for mechanistic transport models and re-15 baseline several other operational and human health 16 assumptions. We plan to issue this work in Reg Guide 17 1.183, Rev 2, in support of the amended control room 18 design criteria.
19 On to slide 14, please.
20 Slide 14 is our most research-intensive 21 alternative. We would be updating regulatory guidance 22 with revised assumptions and models, and continue to 23 maintain appropriate and prudent safety margin. Just 24 like alternative two, we would be initiating new 25 research and analyses to develop mechanistic transport NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 1 models and re-baseline several other operational and 2 human health assumptions. And we would be assessing 3 other mathematical methods, computational statistical 4 approaches, to reduce unnecessary conservatisms and 5 provide greater flexibility. The plan to commence 6 work on Reg Guide 1.183 would be based on the research 7 that would be wrapped up in Rev 2, when it's issued in 8 fiscal year 2025.
9 On to slide 15, please.
10 Our recommendation. The staff recommends 11 Alternative two and amended control room design 12 criteria and revision to applicable regulatory 13 guidance, considering risk information would be the 14 most cost-beneficial, straightforward, durable, and 15 efficient path forward, when licensing increased 16 enrichments up to 20 weight percent uranium-235.
17 Beneficial impacts on other regulations, such as 50.59 18 and Part 20, would also be realized.
19 It would be flexible enough to consider 20 multiple approaches in amending the regulation and 21 would provide options for a generic resolution to the 22 issues. We would be inviting stakeholder 23 participation on the decision affecting this 24 regulatory area, rather than on a case-by-case basis 25 that would result from the current regulatory NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
23 1 framework.
2 The staff would use ample operating 3 experience, scientific data, technical information, 4 numerous recommendations from national/international 5 organizations responsible for radiation protection 6 standards and regulatory precedents that would support 7 a reevaluation of the control room design criteria.
8 In general, there is a range of regulatory 9 base and external stakeholder base recommendations for 10 radiation exposures to radiation workers under normal 11 and emergency conditions. Per the regulation, 12 occupational workers can technically receive 10 rem 13 over a 12-month period that straddles two calendar 14 years or 10 rem in a specific calendar year, given 15 special circumstances.
16 As well, intergovernmental, national, and 17 international organizations recommending emergency 18 exposures. These recommendations we found range from 19 10 to 25 rem or up to 50 rad whole body. As such, the 20 control room design criteria intended to assess the 21 acceptability of a given control room design is on the 22 lower side of these recommended values.
23 And with that, I would like to end my 24 presentation here and open it up for questions from 25 the Committee.
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24 1 Mr. Roberts?
2 MEMBER ROBERTS: Yes. Elijah, I had a 3 similar question, one I was about to ask at the Reg 4 Guide 1.183 meeting last month.
5 MR. DICKSON: Which is?
6 MEMBER ROBERTS: The verbiage that you had 7 a couple of slides ago talks about emergency and 8 accident conditions, which isn't specific to whether 9 that's a postulated accident from the design basis, 10 whether it could be a severe accident that's beyond 11 the normal design basis.
12 And the prescription for calculating both 13 the control room dose and the technical support center 14 dose are based on kind of a mix of a very conservative 15 fission product release combined with an assumption 16 that the containment meets its normal design 17 assumptions.
18 And so, I was wondering if you had any 19 perspective on what kind of control room doses or 20 technical support center doses would be associated 21 with a severe accident and what's the perspective on 22 it, and where that fits into the overall objectives 23 you are working towards.
24 MR. DICKSON: Right. Right, right. I 25 mean, that's actually a very good point. And I'm glad NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
25 1 you brought that up.
2 You know, there is quite a bit of work 3 that has been done in post-Fukushima work, right? And 4 that's probably one of the best resources to look at 5 to understand how a licensee handled responding to the 6 accident and the incurred doses that were actually 7 incurred.
8 And there's a very, very good document out 9 there. It's published by IAEA. It's IAEA Publication 10 1710 that talks about the number of people that were 11 onsite during the accident itself; the number of 12 people that they tracked during, I think it's like a 13 10-month period or so, and the measured doses that 14 they received during that time.
15 And for the most part, the vast majority 16 of the workers were below their regulatory limit. A 17 handful of them, about 170ish or so, were above their 18 threshold of 10 rem, I think, and there was a couple 19 of outliers in regards to people receiving, I think, 20 doses as high -- these aren't people directly in the 21 control room, but people doing actual actions outside, 22 you know, in the plant responding to this very much 23 beyond-design-basis scenario. And they attributed 24 some of those higher doses to internal intakes and 25 training, actually.
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26 1 MEMBER ROBERTS: Right. So, in terms of 2 overall perspective --
3 MR. DICKSON: Did that answer your 4 question?
5 MEMBER ROBERTS: Yes. In terms of overall 6 perspective, yes, a change to the control room dose 7 requirements, you know, doubling from 5 to 10 rem, 8 say, would, essentially, double the allowed exposure 9 during one of these severe accident or emergency 10 scenarios.
11 And I was trying to understand the 12 perspective. Is there any analysis that a 5 rem dose, 13 per the current analysis methods, corresponds to some 14 sort of dose in a severe accident? Or is there any 15 kind of correlation you could draw that would say, 16 well, doubling that is still within the realm of 17 reason, or whether that would potentially be a problem 18 that isn't there currently?
19 MR. DICKSON: Well, it is within the realm 20 of reason. This is a figure of merit used to assess 21 the acceptability of all the SSCs used to mitigate 22 that source term. It doesn't take in all of the other 23 types of operator actions and emergency replanning-24 type actions that go into actually controlling the 25 dose during an actual event, right?
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27 1 And so, the NRC does have emergency plans 2 under 50.47, I believe, that handles ALARA situations 3 and things of that nature, when they're actually 4 responding to an actual event.
5 During those times, they would be 6 practicing ALARA practices. They could always issue 7 prophylactics such as potassium iodine, too, as well, 8 to keep doses low. That does a very, very good job of 9 blocking exposure to one's thyroid, which is really 10 the driving, I guess, dose in these DBA calculations.
11 MEMBER ROBERTS: Sure. I understand that 12 you certainly would take those actions to try to 13 minimize the consequence of the outliers.
14 MR. DICKSON: Uh-hum.
15 MEMBER ROBERTS: I was, again, just trying 16 to understand if there was any expectation of what 17 those kinds of dose rates would be. The direct report 18 that you issued had a footnote -- I think it was 19 footnote 6 -- that says that the current PRAs don't 20 look at dose in terms of estimating the likelihood of 21 operator actions that are credited being taken, which 22 kind of surprised me.
23 So, it seems like there's an open question 24 of is there a generic desire to keep the control room 25 and the technical support center staffed during a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
28 1 severe accident, or is that not considered to be 2 important? And again, if it is to be important, it 3 seems like there ought to be some assessment of what 4 the habitability conditions are and why they support 5 the actions that are credited.
6 MR. DICKSON: Understood. There are the 7 TMI action plan items, too. I think, specifically, 8 Action Item 2(b)(2) used in regards to assessing 9 mission doses -- to perform certain actions within the 10 plant and things of that nature, too.
11 So, there are assessments in that when 12 they are in these beyond-design-basis conditions.
13 MEMBER ROBERTS: Yes. Okay. Thank you.
14 We probably need to have more discussion 15 in terms of --
16 MR. DICKSON: Uh-hum, understood.
17 MEMBER ROBERTS: -- understanding what 18 kind of the integrated story of here's what the 19 expectation is for control room and TSC dose.
20 MR. DICKSON: Absolutely.
21 MEMBER ROBERTS: Here is whatever 22 assessments exist that support those expectations.
23 MR. DICKSON: Uh-hum.
24 MEMBER ROBERTS: So, I just want to leave 25 it at that here.
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29 1 Thank you.
2 MR. DICKSON: Okay. Thank you.
3 Appreciate it.
4 Yeah. So, we are looking, there's a 5 number of areas that we're looking at right now. You 6 know, as we had spoken in the full committee meeting 7 and the subcommittee meeting on Reg Guide 1.183, 8 there's been -- the staff are, you know assessing and 9 looking at the latest Sandia that takes integrations 10 up to 8 to 10 percent, depending on if it's a PWR or 11 BWR and brings it to 80 gigawatt days per NTU.
12 And, we're looking at, you know, how to 13 best use those, that information. And, some of the 14 information that we are looking at speaks to the idea 15 of looking into mechanistic transport models.
16 And so, often what we hear is that, you 17 know, with these updated source terms, you know, 18 there's a Sandia 2011 source term. There is this 19 latest one. And then, the precursor to all of them is 20 NUREG-1465.
21 And, we're constantly seeing the halogens 22 increase right, from one source term to another. And, 23 that is the containment source term.
24 And, when folks look at those Tables, they 25 see that, you know, the halogens are increasing from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
30 1 one analysis to another. But, that's only part of the 2 story, right.
3 For instance, in BWRs when you look at 4 some of the tables in that 2023 report in the back, 5 when they talk about things like suppressor pool 6 scrubbing and whatnot, they do make a distinction that 7 a lot of the containment source term that does include 8 the dry well and the wet well of a BWR, is actually 9 retained in the wet well, in the water. Right.
10 It does a very, very good job of retaining 11 those radionuclides, if they can maintain their PH at 12 a certain level. And so, we're looking into, you 13 know, can information be gleaned from that report in 14 regards to some of the other transport models that we 15 use in the guide.
16 And so, that's an area of continued 17 research. I'm not really prepared to talk about any 18 of that right now. But, I do know that the Office of 19 Research will be having discussions with you in the 20 next couple of months, I believe, on that subject.
21 MEMBER REMPE: Actually, it'll occur in 22 mid- November on the critique is what I'm seeing now.
23 MR. DICKSON: Okay. Fair.
24 MEMBER REMPE: I think that would be very 25 helpful for us as we try to contemplate how to go NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
31 1 through with this.
2 MR. DICKSON: Understood.
3 MEMBER REMPE: But, it sounds to me like 4 You're going to try and -- because, I mean, actually 5 that report had a higher source term.
6 MR. DICKSON: Yeah. That's right.
7 MEMBER REMPE: And so, this thing about 8 trying to have a reduced one, I'm not sure that report 9 is going to give you much in its current state, even 10 if it does get the review that, you know, if somebody 11 finds something wrong with it, they may have to redo 12 it.
13 But, it sounds like that you want to 14 actually have a lot of research and then have them 15 update that source term again, is your assessment.
16 MR. DICKSON: So, we're gleaning 17 information from the report right now. And, I think 18 it's like Section Five of that report, they talk about 19 like air/soil retention.
20 And, they do present a series of tables in 21 that report that demonstrate how much of this 22 containment source term is actually divvied up between 23 the wet well and dry well. And, in the 2023 report, 24 I think 70 percent of the halogens are deemed to be in 25 that containment that includes both wet well and dry NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
32 1 well.
2 But, if you look at Table, it's like 5.14 3 or 5.15, you can see that 90 percent of that source 4 term is actually in the wet well. So, that's -- we're 5 looking at that type of information.
6 MEMBER REMPE: Is there -- since this is 7 something being done to help future applicants, why 8 not have them pay for this research instead of the NRC 9 paying for this research to come up with this report 10 and such?
11 MR. DICKSON: Right.
12 MEMBER REMPE: That's another question 13 that crossed my mind when I was reading all of this.
14 MR. DICKSON: It's, I mean, it's a 15 question that's crossed my mind. We would -- we would 16 always accept another alternative source term for 17 review.
18 The Agency has always provided this 19 maximum hypothetical source term historically, dating 20 back from the TID source term of the early '60s, to 21 14.56.
22 But, like the new, the new reactors, 23 NuScale, GE, Holtec, you know, they're looking into 24 developing their own source terms as well. NuScale 25 did. You know, NuScale did use their own source term, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
33 1 accent source term.
2 MEMBER REMPE: But, you do think this is 3 something the Agency does need to do, just because 4 it's historically been done, is what You're telling me 5 today?
6 MR. DICKSON: Historically yes. And, it's 7 good for the Agency to kind of put that, I guess this 8 is my own personal perspective, like that, you know, 9 kind of flag in the sand that, you know, we've done 10 this work and this is what we think is a reasonable 11 source term for these types of analysis.
12 And then, gain, you know, stakeholder 13 feedback and involvement in regards to, is this the 14 right source terms. So, yeah, I think so.
15 MEMBER REMPE: Okay. Thank you.
16 MR. DICKSON: Um-hum. Okay. If there are 17 no other questions, we can move on to Charlie Peabody, 18 who will be presenting on criticality accident 19 requirements of 10 CFR 50.68.
20 Thank you.
21 MR. PEABODY: All right. Thanks, Elijah.
22 Can everybody hear me on the room microphone?
23 CHAIR BALLINGER: Okay by me.
24 MR. PEABODY: Good to hear. Okay. So, 25 this is going to be a discussion of the criticality NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
34 1 accident requirements that we're looking as part of 2 this rulemaking. Next slide, please.
3 We're focusing primarily on changes that 4 we're going to make to 50.68. But, this is actually 5 a combination of 10 CFR 50.68 and 10 CFR 70.24.
6 70.24 was the initial rule for criticality 7 safety for fuel storage. It does not have an 8 enrichment limit in it.
9 However, we made 50.68 as a final rule in 10 1998 because 70.24 had requirements that licensees 11 considered burdensome. Mostly that in addition to 12 active criticality monitoring, it also required 13 emergency planning procedures and drills for a full 14 evaluation and rehabilitation of the storage 15 facilities.
16 So, that final rule permits exemptions so 17 there's parts of 70.24 requirements. And, it does 18 that by limiting enrichments to 5 percent weight.
19 And, the way that it does it is that it 20 analyzes the K effective with acceptance criteria that 21 require probability in confidence level.
22 So, if you have a sufficient margin of 23 subcriticality, you can be exempt of the active 24 emergency planning requirements of 70.24.
25 This rule is applicable to Part 50 and 52 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
35 1 licensees, that they have to specifically adopt it as 2 part of the license. Next slide, please.
3 And so, some alternatives that we're 4 considering to 50.68, one would be no action. We've 5 had a couple of licensees come in asking for 6 exceptions to the 50.68 (b)(7) enrichment limit, which 7 we can grant under 50.12.
8 The second option would be a rulemaking to 9 actually increase the enrichment limit from the 10 existing 5 percent level to some other value up to 20 11 percent.
12 And then, the third alternative would be 13 to also do a rulemaking, which would just simply 14 remove the specific enrichment in 50.65(b)(7), and it 15 said, referenced the Tech Spec design feature limit.
16 And, that's the one that we're 17 recommending. Next slide, please.
18 The reason why we're recommending this is 19 because it maintains the existing subcriticality 20 levels at the same effective probabilities and 21 confidence.
22 But, criticality safety impacts will be 23 addressed during the fuel transition license amendment 24 request process. And, it also allows consideration of 25 any enrichment from the existing 5 percent value up to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
36 1 20 percent weight, which is the maximum allowed under 2 50.64.
3 We're also doing a study with Oak Ridge 4 National Lab that's going to kind of determine the 5 feasibility of enrichments for the existing, three 6 existing really commercial fuel designs. That we want 7 to make sure that we have somewhat of a sanity check 8 on the effects of increasing the enrichment on the 9 criticality K effective limits.
10 And one of the best things about this, I 11 think it's the last one that this preserves 50.68 12 compliance for all of the existing fleets who are not 13 affected, because if they were to ask for a higher 14 enrichment that would be a voluntary initiative.
15 They can keep the current enrichments that 16 they have without having to make any changes. Next 17 slide.
18 So, questions about 50.68?
19 Okay. I'm not seeing any. But, I'm 20 seeing Don, So, I'll get --
21 MEMBER PETTI: No, I have a -- this is 22 Dave. I have a question. Go back a couple of slides.
23 I know the preferred option was to take 24 out the specific emission limit today. But, the K 25 effective still stays the same. Is that correct?
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37 1 MR. PEABODY: Yes. So, the K effective 2 limits and (b)(2), (b)(3), and (b)(4) will be the 3 same. (b)(2) and (b)(4) are most limiting. That's 4 going to maintain .95 or 95 percent probability and 5 confidence for wet storage fuel and spent fuel.
6 We will also keep the (b)(3) limit for 7 optimal modernization of like the aqueous bond 8 analysis. If anyone wants to use that then we're not 9 seeing -- we're not planning on removing it. But, 10 it's not utilized at many sites, because most of them 11 are not storing fuel in the, storing new fuel in that 12 storage.
13 MEMBER PETTI: Okay. Thanks.
14 MR. PEABODY: Any other questions?
15 And with that, I'll turn it over to Don 16 Palmrose to discuss environmental considerations.
17 MR. PALMROSE: Okay. Good afternoon. And 18 a quick sound check. Can you hear me okay?
19 MS. ABDULLAHI: Yes.
20 MR. PALMROSE: Okay. Thank you. Yes.
21 Again, I'm Don Palmrose and I'm the Senior Reactor 22 Engineer with environmental center expertise. So, 23 let's go to the next slide, please.
24 Okay. So, the annual fuel cycle and the 25 transportation of fuel waste are connected actions up NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
38 1 to operating, operational use in nuclear power plants 2 under NEPA, the National Environment Policy Act.
3 The staff has previously performed genetic 4 analysis dating back to the 1970s to evaluate the 5 environmental effects of the uranium fuel cycle and 6 the transportation of fuel and waste. These 7 evaluations are documented in WASH 12.48, for the 8 uranium fuel cycle, and then WASH 12.38 for the 9 transportation of fuel and waste, along with other 10 supporting documents.
11 This original analysis was for enrichment 12 levels up to 4 percent, U-235. The uranium fuel cycle 13 analysis was codified into 10 CFR 51.51 as Table S-3.
14 For the transportation of fuel and waste, the 15 environmental effects were codified into 10 CFR 51.52 16 as Table S-4.
17 Subsequent staff evaluations expand the 18 Table S-3 and S-4 to up to 5 weight percent U-235. Of 19 note for Table S-4, there are other conditions that 20 must also be met to use Table S-4 in a licensing 21 action, else a full description and detailed analysis 22 of the transportation impacts would need to be 23 performed as part of the licensing action.
24 The staff has performed additional 25 analysis to extent the measurement levels above 5 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
39 1 weight percent U-235. This has been done in two 2 documents.
3 The first is a study to support accident 4 tolerant fuel deployment published in NUREG-2266, 5 which is currently available for public comment until 6 October 31.
7 Additionally, the advanced nuclear reactor 8 generic environment impact statement that is before 9 the Commission for approval, also addresses' uranium 10 fuel cycle for up to 20 weight percent U-235.
11 Until these documents have been finalized, 12 the current practice for addressing these environment 13 impacts continues as before, as shown in the last two 14 sub-bullets, where the uranium fuel cycle evaluation 15 would be on a case by case basis, as lived on in prior 16 new reactor applications.
17 And, a full description and detailed 18 analysis would need to be performed for the 19 transportation fuel and waste. Next slide, please.
20 The staff considered three alternatives 21 for 51.51 and Table S-3. The first is the current 22 situation as I previously mentioned on the previous 23 slide. Address the environmental effects on a case by 24 case basis.
25 The recommended alternative is to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
40 1 incorporate the updated evaluation in NUREG-2266 and 2 the advanced reactor generic environmental impact 3 statement into the regulations, apply this rulemaking 4 to extend Table S-3 to the highest metric levels these 5 analysis can support.
6 The third alternative would be not to 7 codify the updated evaluations. But, reference them 8 for the environmental findings into individual 9 licensing actions. Next slide, please.
10 The same alternatives were also considered 11 for 51.52 and Table S-4. Again, with the rulemaking 12 and the recommended alternatives.
13 And, with that, that ends my presentation.
14 And I'm available for questions.
15 If there are no questions, I'll pass it 16 onto Jason.
17 MR. PIOTTER: Thanks, Don. My name is 18 Jason Piotter. I'm a Senior Mechanical Engineer and 19 the Senior Program Manager for ATF and Advanced Fuels 20 in the Division of Fuel Management in the Office of 21 Nuclear Material Safety and Safeguards.
22 Today I'm just going to give a brief 23 overview of the packaging requirements of 10 CFR 71.55 24 as it relates to increased enrichment.
25 For this particular effort, the Division NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
41 1 of Fuel Management reviewed applicable regulations in 2 10 CFR Part 71 and 72, to identify any areas where a 3 specific reference to fissile materials enrichment 4 levels was evident.
5 No regulations in Part 72 were identified 6 with an enrichment limitation. And, the regulations 7 in 10 CFR Part 71 do not directly reference or limit 8 enrichment level of the radioactive contents except 9 for 10 CFR 71.55(g) or golf.
10 This provision allows an applicant for a 11 certificate of compliance to utilize an exception to 12 10 CFR 71.55(b) or bravo, and is applicable only to 13 UF6 transport. It specifies an enrichment limit of 5 14 weight percent U-235 per UF6, which does not currently 15 bound the range of enrichment that applicants may 16 choose to ship in their UF6 transportation packages in 17 the future.
18 The regulation at 10 CFR 71.55(b) requires 19 that a single transportation package be designed and 20 constructed and its contents so limited that it would 21 be subcritical if water were to leak into the 22 containment system. This nonmechanistic criticality 23 analysis with moderation ensures criticality safety 24 during transport in the event that moderator leaks 25 into the containment vessel.
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42 1 The exception to 10 CFR 71.55(b) contained 2 in 10 CFR 71.55(g) codified a longstanding NRC and 3 worldwide practice for evaluating watering leaking 4 into UF6 packages.
5 The NRC determined at the time that 6 including the exception in 10 CFR 71.55(g) was 7 warranted, because it would maintain consistency with 8 domestic and worldwide practice that operational 9 experience demonstrated safe shipment of fissile 10 material enriched too less than or equal to 5 weight 11 percent U-235 and that the necessity to transport an 12 essential commodity. And, those were taken directly 13 from 69 FR 3697 in 2004.
14 The particular exception for a UF6 15 transportation package can be used if all of the 16 following conditions in addition to the enrichment 17 limitation are met. The UF6 cylinder remains leak-18 tight following a test specified for the hypothetical 19 accident conditions; the valve body of the cylinder 20 does not impact any other part of the package other 21 than where it is attached to the cylinder; there is 22 adequate quality control in the manufacture, 23 maintenance, and repair of packaging; and, each 24 package is tested to demonstrate closure before each 25 shipment. Next slide, please.
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43 1 Absent using the exception in 71.55(g),
2 applicants for a certificate of compliance have the 3 option of evaluating fissile materials packages, 4 including UF6 packages, in a variety of ways. Number 5 one, with the provisions under 71.55(b), which may 6 require changes to current package designs or perhaps 7 require new package designs to accommodate higher 8 enrichments.
9 An applicant may seek an exemption to 10 71.55(b) or they may use the provisions in 71.55©.
11 71.55© is a -- it also provides for an exception to 12 the requirements of 71.55(b) if the applicant 13 specifies that the package incorporates special design 14 features that ensure no single packaging or would 15 permit leakage.
16 And, that appropriate measures are taken 17 before each shipment to ensure the containment system 18 does not leak. This exception does not limit the 19 enrichment of the package contents. Next slide, 20 please.
21 Based on its evaluation, the staff 22 identified three alternative actions that the NRC 23 could take. The first is no action, utilizing the 24 existing certificate of compliance options.
25 The second option would be to undertake NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 1 rulemaking to increase the enrichment limit up to 20 2 weight percent U-235. Or undertake rulemaking to 3 remove the enrichment limit completely. Next slide, 4 please.
5 The current staff recommendation at this 6 point is to take no action. To date, industry plants 7 communicated to the NRC have not indicated that there 8 would be enough requests for package approvals for 9 transport of UF6 enriched up to but less than 20 10 weight percent U-235 to conclude that rulemaking would 11 be the most efficient or effective process to support 12 package approvals.
13 All alternatives that were considered 14 under nearly cost neutral in terms of implementation 15 but the proportional burden is different for each of 16 those cases.
17 I would like to note here, that we have 18 recently approved a UF6 package with content enriched 19 too just under 20 weight percent, which followed the 20 regulation in 71.55(b) rather than seeking an 21 exemption or using the exceptions in 71.55© or 22 71.55(g).
23 We do have an existing question that is in 24 the FRN right now that we are seeking any additional 25 information that stakeholders can provide to us that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
45 1 might bolster the information that we did get back in 2 the public meeting in June, which essentially was a 3 single question that we had relating to how we were 4 going to interface with DOT and make sure that we were 5 harmonized with DOT regulations.
6 And then, of course, that subsequently 7 leads into how we would be harmonized potentially with 8 IAEA regulations.
9 So, with that, next slide, please. And, 10 I will take any questions.
11 MEMBER REMPE: So, this is Joy. I was 12 curious about if there won't be enough requests. Did 13 anyone indicate that they had a request?
14 MR. PIOTTER: We had gotten no --
15 MEMBER REMPE: Was there any questioning?
16 MR. PIOTTER: We had gotten no additional 17 feedback. I mean, I think currently the fleet that 18 exists is fairly modest.
19 And, I think the fact that we were, at the 20 time we were undertaking a COC evaluation of a package 21 that was going to be able to ship up to 20 weight 22 percent.
23 I wouldn't say that the problem is solving 24 itself. But, there are obviously options that the 25 industry has, multiple options that are performance NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
46 1 based within the regulation.
2 That it appears as if we may not be seeing 3 a large influx or a demand signal for additional 4 packages. We don't know that, which is why we're 5 seeking additional information from industry.
6 MEMBER REMPE: Okay. Thank you.
7 MR. PIOTTER: Any other questions?
8 Okay. I think Phil, we are at a break.
9 Is that correct?
10 CHAIR BALLINGER: I think so. We've 11 actually -- well, I'm anticipating that the next topic 12 is going to have a pretty long discussion.
13 So, I think You're correct. Why don't we 14 take a break. It is now 1:55. Why don't we take a 15 break until 2:15, unless there's an objection?
16 Hearing none, we'll take a break until --
17 and reconvene at 2:15.
18 (Whereupon, the above-entitled matter went 19 off the record at 1:56 p.m. and resumed at 2:15 p.m.)
20 CHAIR BALLINGER: Okay. By my watch it's 21 2:15, and we're back in session. So, I think it's --
22 is it Joe or Ashley they're going to do the 23 presentation?
24 MR. MESSINA: Ashley's going to start off 25 and then she'll hand it over to me.
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47 1 CHAIR BALLINGER: Okay. Your show.
2 MS. SMITH: Okay. Hi, I'm Ashley Smith.
3 Joey and I are here for the fuel dispersal portion 4 under the leaking.
5 I'm going to be going through the first 6 few slides. And then I'll hand it off to Joey. Next 7 slide.
8 First I'm going to discuss what FFRD is.
9 Then I'll discuss its history. Different experiments 10 have shown that the fuel can fragment during a loss of 11 coolant accident, differences in pressure across the 12 siding can lead to ballooning inverse of the cladding.
13 The fragmented fuel can relocate into the 14 balloon region and first occurs the fragments can 15 disperse into the reactor coolant system.
16 The first image is of FFRD testing that 17 was done at Argonne National Labs at 55 gigawatt days 18 prime to yield. It shows fuel fragmentation 19 occurring.
20 The second image is of the core 21 representation showing that once the fuel fragments, 22 the fragmented pieces relocate into other areas of the 23 fuel such as the balloon region.
24 The third image shows results from a LOCA 25 test at the test facility. And, as you can see the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
48 1 burst openings can be large enough for the fuel to 2 disperse into the reactor coolant system. Next slide.
3 This slide has the timberline of the 4 history of FFRD. To start, the 50.46 acceptance 5 criteria for LOCAs were created in 1974 when FFRDs 6 were not known phenomena.
7 In 1980 FFRD was discovered during 8 experiments at several test facilities, indicating 9 that irradiated fuel could fragment into small pieces 10 during a LOCA and may relocate actually, settling into 11 the balloon region.
12 In 1984, NRC put FFRD into the generic 13 issue program as GI-92. But, later concluded that 14 known server systems would offset increased 15 regeneration resulting from fuel relocation.
16 It was dropped from the GI Program in 17 1995. In 2006, tests at Argonne National Labs and 18 Spalding indicated that fragmentation and relocation 19 could result in a loss of fuel particles through the 20 rupture opening.
21 In 2008, Rule 08.01 was issued discussing 22 recent hyper analysis research finding, noting that 23 additional research on fuel dispersal was being 24 conducted. This stated that the current 62 gigawatt 25 days for MTU implement is probably slow enough to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
49 1 prevent significant dispersal.
2 In 2012, NUREG-2121 was issued discussing 3 the knowledge base of FFRD at the time. In 2015, 4 SECY-15-0148 was issued stating that 50.46(b) should 5 not be delayed to include FFRD and that research will 6 continue to be conducted.
7 Future rulemaking may be initiated if 8 necessary. Basically it was believed that there was 9 no imminent safety concern from FFRD up to 62 gigawatt 10 days for MTU.
11 In 2016, the draft final rule for 50.46(b) 12 went out. In 2021, Rule 21.13 was issued. This 13 document is the Office of Research's interpretation of 14 FFRD experimental research to date.
15 In the rule, the staff defines 16 conservative boundaries for FFRD related phenomenon, 17 such as the amount of finely fragmented fuel expected 18 to be dispersed during a LOCA.
19 In 2022, after SECY-2109 was issued by the 20 Commission, directing the staff to address FFRD in the 21 IA rulemaking regulatory basis. And, in 2024, the Lea 22 Hurt conducted on fuel dispersal to help identify 23 further research needs, potential to develop guidance 24 and to help focus NRC staff reviews of applications 25 that may evaluate FFRD. Next slide.
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50 1 This slide discusses the background and 2 regulatory issue of fuel dispersals. As stated in the 3 timberline on the previous slide, the 50.46 acceptance 4 criteria date back to 1974 when FFRDs were not known 5 phenomenons.
6 Acceptable approaches to demonstrate 7 compliance of the regulations have ensured that 8 catastrophic failure of the rod structure and loss of 9 fuel under configuration are concluded.
10 These approaches include annual 11 assessments to show that peak cladding temperature and 12 maximum local oxidation remain below the limits in 13 50.46.
14 Fuel dispersal would be a departure from 15 precedent, because the fuel bundle geometry would be 16 lost. Fuel dispersal is not -- this will be addressed 17 with the current regulation. Next slide.
18 On the timberline in FROM SECY-2109, the 19 Commission asked staff to include FFRD as part of the 20 increased enrichment rulemaking. Staff has developed 21 five alternatives like different pathways that could 22 be pursued.
23 The five alternatives are not considered 24 mutually exclusive or combinations of elements from 25 multiple alternatives could be considered. Staff has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
51 1 also considered --
2 MEMBER PETTI: Ashley? This is David.
3 You said mutually exclusive, but the slide says 4 mutually inclusive.
5 Is the slide correct? You can mix and 6 match.
7 MS. SMITH: Yeah, right.
8 MR. MESSINA: Yes, we can mix and match.
9 Yes.
10 MEMBER PETTI: Okay. Good. Thanks.
11 MS. SMITH: Right. Sorry, what I spoke 12 was the opposite of what's on the slide. I understand 13 that.
14 Staff also has been considering other 15 approaches not included in the five alternatives based 16 on public comment.
17 Joey is going to talk about the 18 alternatives on the next slide.
19 MR. MESSINA: Yes. Hi, thank you. I'm 20 Joe Messina. I work in Nuclear Methods and Fuel 21 Analysis Branch. And, I'll go through each of the 22 specific approaches presented in the Reg basis on 23 FFRD.
24 So, the first -- to start off, the first 25 alternative presented, we start with the status quo.
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52 1 And, we considered maintaining it as one of the 2 licensing pathways.
3 In this alternative, we would keep the 4 current regulatory framework mostly the same, without 5 any major updates. And, continue with the precedent 6 that significant amount of fuel dispersal should not 7 occur.
8 Therefore, the most straightforward 9 licensing approach under this pathway would be to 10 demonstrate that rods susceptible to fine 11 fragmentation do not burst and thus lead to 12 significant dispersal.
13 It is expected that technical solutions 14 would be needed to prevent high burn of rods from 15 bursting, such as changes in fuel design and/or core 16 design.
17 Use of accident tolerant fuel may also 18 help. For example, coating cladding may limit the 19 balloon size for the first and/or the burst opening 20 size.
21 Additionally, since the regulations do not 22 explicitly speak to fuel dispersal, allowing 23 significant dispersal may not technically require a 24 change to the regulatory framework. But, this would 25 lead to regulatory uncertainty and challenges by both NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
53 1 industry and the NRC.
2 Therefore, pathways that consider 3 significant dispersal are discussed as part of other 4 alternatives. Next slide, please.
5 The second licensing pathway presented 6 rethinks a 50.46(a) style modification of ECCS 7 requirements. For those that are not familiar with 8 50.46(a), it was a final rule that went to the 9 Commission in 2010, that risk informed LOCAs.
10 Specifically, it established a transition 11 break size. For breaks smaller than the transition 12 size, LOCAs would be analyzed as they are today.
13 But, for breaks larger than the transition 14 break size, less conservative assumptions and modeling 15 could be employed, such as allowing for credit of 16 offsite power.
17 In this licensing pathway, LOCAs above the 18 transition break size would essentially be treated as 19 beyond design basis. In beyond design basis action 20 analysis, best estimate modeling and more realistic 21 assumptions can be employed, while during design basis 22 accident analysis a 95/95 is the typical standard for 23 modeling.
24 The uses of beyond design basis modeling 25 may help to show that no rod susceptible to fine NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
54 1 fragmentation and of bursting as a result of a large 2 break LOCA, but it still maybe challenging.
3 Therefore, this pathway could be combined with other 4 pathways presented to analyze the consequences of fuel 5 dispersal.
6 Additionally, there would also be obvious 7 benefits outside of FFRD in the LOCA analysis with 8 this approach, such as increased margin to the peak 9 clad temperature and oxidation limits presented in the 10 current version of 50.46.
11 I'll not that this approach would likely 12 not be a simple cut and paste from the 2010 rule.
13 This would be more of a modernization of the rule.
14 We can update it with any knowledge gained 15 since 2010, or to better capture anything in today's 16 landscape as we see fit. Next slide, please.
17 MEMBER ROBERTS: Hey Joe, a quick 18 question. Has there been any like desktop analysis or 19 estimates as to the may on the previous slide?
20 Whether there's a good chance that the 21 limits will be met with the realistic assumptions?
22 Or, you just don't know?
23 MR. MESSINA: The inspect -- well, since 24 -- are you talking about -- the current limits would 25 be expected to be met, because realistic assumptions, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
55 1 there would be increased margins.
2 As for any, you know, the core 3 provability, it's -- that would have to be 4 demonstrated.
5 MEMBER ROBERTS: Yeah. Thank you. I was 6 trying to get some feel for what the word may means.
7 Is a may that is done in the calculations?
8 MR. MESSINA: Oh, yeah.
9 MEMBER ROBERTS: Do you think it will get 10 there? Or have you done calculations and think you 11 won't get there?
12 Or, you just don't know?
13 MR. MESSINA: Oh, okay. So, yes. So, our 14 Office of Research actually in August, they presented 15 a paper at NUREG on fuel dispersal calculations for 16 high burn up fuel during a large break LOCA.
17 And, they estimated about 75 percent of 18 the core would burst. Obviously not all that is high 19 burn up rods. So, not all that would be to dispersal.
20 But, the fact that 75 percent of the core 21 would burst, likely indicates that this approach may 22 not be necessary. But, to better understand that, we 23 did ask questions in the FRN and the Reg basis, 24 whether it is feasible to demonstrate that there are 25 no rods, no high burn up rods that burst even with the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
56 1 best estimate assumptions.
2 MEMBER ROBERTS: Yeah. Okay. Thank you.
3 MEMBER PETTI: So, Joe, You're saying that 4 the NR -- the research staff came up with 75 percent 5 with a best estimate calculation?
6 MR. MESSINA: I believe those were nominal 7 calculations, yes.
8 MEMBER PETTI: Okay. Thanks.
9 MR. MESSINA: Next slide. Okay, yes, this 10 is right. The third licensing pathway proposed in the 11 Reg basis is to provide a safety demonstration of 12 post-fuel dispersal consequences.
13 So, phenomena such as core coolability, 14 re-criticality, and long term cooling would need to be 15 addressed like any other LOCA phenomena. That is to 16 say, that they would need to be modeled with high 17 confidence, you know, to a 95/95 level.
18 As part of this, guidance would be 19 developed regarding analysis of the consequences. We 20 are currently sponsoring a PIRT that Ashley mentioned 21 that is focused on the consequences of fuel dispersal.
22 And, it is expected to be completed 23 sometime early next year. This PIRT would help us to 24 issue guidance with the rule.
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57 1 relatively high level and conservative though since 2 there has not been much experimental research on the 3 consequences conducted to date.
4 Though we envision that if this option is 5 chosen, it could -- it could help with determining 6 what experimental research we will do in the long 7 term.
8 And, once we conduct that experimental 9 research in the long term, we can use that to update 10 the initial guidance to be less conservative and more 11 specific once that research is conducted. Next slide, 12 please.
13 The fourth lessons and pathway would be to 14 provide a generic bounding assessment of dose and use 15 risk insights to address post fuel dispersal 16 consequences. Currently there are dose criteria for 17 most for the DBAs, such as control rod ejection 18 accidents, main steam line break.
19 But, for a 50.46 LOCA that is mitigated, 20 where there's, you know, no fuel melting, we assume 21 that the consequences are bounded by the maximum 22 hypothetical accident dose or the MHA LOCA dose, which 23 assumes an unmitigated LOCA that leads to a 24 substantial meltdown of the core.
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58 1 criterion for the LOCA analyzed under 50.46 with fuel 2 dispersal. So, separate from the MHA LOCA dose.
3 Licensees would need to demonstrate the 4 ability to predict a source term for a LOCA with fuel 5 dispersal. Or, be directed to use a fraction of the 6 MHA LOCA source term based on the amount of fuel that 7 is predicted to be dispersed.
8 Regarding the other consequences of fuel 9 dispersal, in this option we postulate that risk 10 incident could be used to address them. For example, 11 insights from operating experience, other regulatory 12 requirements, and industry initiatives could be used.
13 For example, as Elijah had mentioned 14 earlier, severe accident mitigation guidelines, TMI 15 action plan requirements, emergency operating 16 procedures, and as such. Next slide, please.
17 The fifth licensing pathway presented in 18 the Reg basis is to use probabilistic fracture 19 mechanics to show that leaks in large pipes would be 20 identified before failure, including the need to 21 analyze ECCS performance during large break LOCAs.
22 This would be a major departure from 23 current practice. And, would have implications 24 outside of LOCA space as well.
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59 1 initiatives such as EPRI's alternative licensing 2 strategy or ALS that was presented to the ACRS a few 3 months back.
4 This licensing pathway would use XLPR, or 5 the extremely low probability of rupture code that was 6 jointly developed by our Office of Research and EPRI, 7 as well as the LBB concept, or leak before break 8 concept, to show that leaks in large pipes will be 9 able to be detected and operator action will be able 10 to be taken to shut down the reactor with sufficient 11 probability before a pipe breaks and the large break 12 LOCA occurs.
13 If the large break LOCA does not occur, it 14 would prevent any rod failures and thus, any fuel 15 dispersal. This alternative also states that well, 16 since the large break does not occur, then ECCS 17 performance would not need to be analyzed.
18 We acknowledge that this would have major 19 referral effects outside of just the large break LOCA.
20 And, these effects would be examined in more detail as 21 we access each option and decide on a path forward.
22 Next slide, please.
23 MEMBER PETTI: So, Joe, just a question 24 before you go there.
25 MR. MESSINA: Yeah.
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60 1 MEMBER PETTI: On many of the slides it 2 says this will impact the schedule. But, have you 3 guys looked at it enough to know which ones would 4 impact it more than other alternatives?
5 MR. MESSINA: We have, we don't have like 6 specific numbers yet. That would be determined as we 7 move forward and decide on an option.
8 But, roughly, you know, different options 9 may -- yes, would impact the schedule to different 10 extents.
11 CHAIR BALLINGER: This is Ron Ballinger.
12 As a practical matter, a Licensee could do the 13 increase enrichment, and they already have, by asking 14 for exemptions, right?
15 So, it -- well, which schedule are you 16 actually thinking would be affected?
17 MR. MESSINA: The increased enrichment 18 rulemaking schedule, which the ticketed date is to be, 19 the final Rule June 2026.
20 CHAIR BALLINGER: Oh, okay. So, but it's 21 not really affecting -- it wouldn't necessary effect 22 a licensee wanting to use enrichment beyond 5 percent 23 via exemptions?
24 MR. MESSINA: That is correct.
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61 1 submittals already for exceeding 5 percent that have 2 been approved.
3 MR. MESSINA: Yes. And, we are soliciting 4 industry feedback to help inform, you know, our 5 schedule impacts.
6 But yes, you are correct, there have 7 already been some ones that go above 5 weight percent.
8 And, this would not, you know, this -- they were done 9 before this, so.
10 CHAIR BALLINGER: Got it. Thanks.
11 MR. PEABODY: And, I will say, I mean, 12 I've worked on one of those LARS. This is Charlie 13 Peabody again.
14 We haven't like yet approved it for like 15 an entire batch load. Where you would attend -- like 16 we're still looking at -- we're still looking at like 17 this specific burn up of the test assemblies or any 18 assemblies that are going above this.
19 So, you know, we still have linked to this 20 FFRD issue the 62 as the gigawatt days burn up limit.
21 And, you know, we're still looking at, in terms of all 22 this increased enrichment stuff, we're still looking 23 at how we manage that as well.
24 CHAIR BALLINGER: Well, is it -- am I 25 correct in saying that there's a, there isn't a LAR NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
62 1 that's been submitted or will be for a full batch?
2 MR. PEABODY: I don't think there -- so, 3 I believe they are scheduled to submit LARs for full 4 batches. But, we haven't seen like any justifications 5 for batch loading which would permit burn up beyond 6 the 62 gigawatt days.
7 So, like in theory they could do batch 8 loads and only core -- or only burn assemblies twice 9 instead of thrice. And still stay below that limit.
10 But, you know, like when You're doing an 11 entire batch load, we would expect some fuel 12 assemblies to exceed that 62 gigawatt days limit.
13 And, worse, we still haven't, as a staff, approved 14 that yet.
15 And, there's some hesitancy to approving 16 that without, you know, further studies and 17 justifications as to why it's safe to proceed with 18 that.
19 CHAIR BALLINGER: Thanks.
20 MR. MESSINA: Okay. Next slide, please.
21 So, we provided five lessons in pathways in the Reg 22 basis. But, at this time, we do not provide a 23 recommended pathway, because we feel that stakeholder 24 feedback is important before making a decision on such 25 a complex topic.
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63 1 We provided six questions to the public in 2 the FRN and the Reg basis on FFRD and the alternatives 3 to better help us make a decision.
4 As we previously stated, these 5 alternatives are not mutually exclusive. We will 6 consider combinations of the alternatives presented 7 for any proposed pathways that were not discussed.
8 I've heard it described as a sample space 9 of options, which I believe is a good description. We 10 provided some projected boundaries of this sample 11 space and we are considering options across the space 12 and may consider options outside of it as well if we 13 get reasonable -- if we are provided reasonable 14 options as part of the public comments.
15 And, I believe that concludes my 16 presentation. This slide I just put there for 17 discussion, to put all the alternatives on one side 18 for ease of questions.
19 MEMBER PETTI: So, Joe, I have a question.
20 I think you guys are going to go out for public 21 comment imminently.
22 And then does -- when does that close and 23 you guys get all the comments back?
24 MR. MESSINA: As of now, the public 25 comment period closes November 22.
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64 1 MEMBER PETTI: And then, you would come 2 back to us at some point?
3 MR. MESSINA: We would come back to you 4 before the proposed rule goes to the Commission.
5 Right, before Phil?
6 MR. BENAVIDES: Yeah, correct. Sorry, 7 this is Phillip Benavides, the Rulemaking Project 8 Manager.
9 The path forward is a, and as we do with 10 all proposed rules, we get the option for ACRS review 11 as we're going through concurrence prior to the 12 proposed rule being fully approved.
13 MEMBER PETTI: And, what date is that that 14 you have to give it to the Commission?
15 MR. BENAVIDES: The current SECY date is 16 December 2024. So, with that, we'd probably come to 17 you, you know, August or September'ish of next year.
18 MEMBER PETTI: I think it's going to be an 19 issue for the committee to decide. Do we put our 20 input on FFRD and a letter now, or do we wait?
21 CHAIR BALLINGER: Yeah. This is Ron.
22 I've got a path forward that at least the initial 23 discussion for the committee. So, that's part of it.
24 MEMBER PETTI: Yeah. I mean, I'm just, 25 you know, even if we, you know, said oh, we don't like NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
65 1 this option, but we like this option.
2 We could put some guardrails or some 3 criteria around sort of how we would think about the 4 problem, Ron. And, that maybe helpful for the staff 5 at this point.
6 CHAIR BALLINGER: Yeah. I mean, I 7 appreciate that.
8 MEMBER PETTI: You know, if our letter 9 gave you guys some guidance not about what an 10 alternative is, but what's the thought process that we 11 ourselves think you out to think about as you think 12 about the option space.
13 CHAIR BALLINGER: Yeah. Tom has got his 14 hand up.
15 MEMBER ROBERTS: Yeah. Can you go back to 16 the list of options page? It might be easier to ask 17 my question.
18 I was wondering about the application of 19 defense in depth principles. Particularly for option 20 five.
21 Because it seems like the option is solely 22 dependent on predictions from the XLPR code that the 23 large break LOCA won't happen. Which we seem to 24 require revisiting of documents like NUREG-1829, the 25 explanation of break frequencies.
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66 1 And, comparing that to the EPRI paper, 2 they seem to ask a different question in terms of, you 3 know, is the FFRD during a large break risk 4 significant?
5 As opposed to, is the large break itself 6 risk significant? And so, they talk about defense in 7 depth about things like, containment will be 8 established before the dispersal happens, and that 9 type of thing.
10 And so, they don't go obviously as far as 11 alternative five in terms of what you've go there.
12 But, I was wondering what your thought was on defense 13 in depth and, you know, how sure are you that You're 14 not wrong on the extremely low likelihood of the large 15 break?
16 And, I guess that's my question.
17 MR. MESSINA: Yeah. That's a good point.
18 And, you know, we are, as part of this process, we are 19 assessing, you know, how much we can trust the XLPR 20 code, how much defense in depth is maintained and we 21 find adequate.
22 So, that's all part of the process. And, 23 I can't say, you know, we can't make definitive 24 arguments yet. Or, you know, right now, because we're 25 still assessing it. You know, we'll get public NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
67 1 feedback on this and help us make a firm assessment.
2 MEMBER ROBERTS: Okay. Thank you. So, 3 you think there maybe a, you know, a role for 4 revisiting NUREG-1829 and going back out to a, you 5 know, a different board of experts to see if they 6 would agree with the low likelihood that's predicted 7 by that code?
8 MR. MESSINA: Yes. And NUREG-1829, it was 9 both after elicitation. And, they did do some 10 probabilistic fracture mechanics work.
11 I know Dave Rudland in NRR, he actually 12 wrote a paper, I think, a few years ago, where he used 13 XLPR to compare to the NUREG-1829 LOCA frequencies.
14 And, he said they -- it wasn't wrong to 15 say, it was similar. So, it wasn't drastically 16 different.
17 But, we would obviously still have to 18 evaluate that much more.
19 MEMBER ROBERTS: Yeah. It seems to me 20 that the EPRI recommendation from 2020 might be like 21 a, you talk about these are not mutually exclusive.
22 But, that's kind of like a four and five.
23 It seems like it's a combination of the 24 two of those. I think it fits within what you put out 25 as the five alternatives.
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68 1 Is that a fair representation?
2 MR. MESSINA: Correct.
3 MEMBER ROBERTS: Okay. Thank you.
4 MR. MESSINA: Yes. Yeah, and we again, 5 you know, I like to think, we tried to capture the 6 boundaries of the sample space. And, alterative five, 7 while based on some, you know, the EPRI ALS is an 8 independent alternative that we developed.
9 CHAIR BALLINGER: Scott Krepel? Your hand 10 is up.
11 MR. KREPEL: Yes, hi. Thank you. This is 12 Scott Krepel speaking through an interpreter of 13 course.
14 The first thing that I wanted to say with 15 regards to XLPR, because that also involved potential 16 development for guidance for what would be 17 appropriately applicable of XLPR and what would it be 18 for individual licensees. So, it's not just, you 19 know, doing a survey of LOCA frequency and so on and 20 so forth.
21 But, anyway, the reason I actually raised 22 my hand is because I wanted to go back to something 23 that was said previously about having higher than a 5 24 weight percent. And, you might remember we did 25 present to the ACRS very recently on the Vogtle LTA.
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69 1 And, that did have some rods that were 2 above the 5 percent. But, I should add that we just 3 recently, I want to say within the last two weeks or 4 so, received an LAR with regards to spent fuel pool 5 criticality for above 5 percent.
6 But, that Licensee will, you know, still 7 have to submit a separate LAR for actually operating 8 with above 5 percent.
9 Thank you for your time.
10 CHAIR BALLINGER: Well, Elijah Dickson, 11 please.
12 MR. DICKSON: Oh, thank you. Elijah 13 Dickson with the staff. I'd like to point out that 14 alternative four, it does include another layer of 15 defense in depth, because you assume the source term 16 is based off of a full core melt.
17 And so, you are assessing, you know, 18 containment leakage and things of that nature to 19 actually do those, you know, control room and offsite 20 EAB, exclusionary boundary in low population zone 21 calculations.
22 So, we'd be considering, you know, some 23 defense in depth if you did a combination of, you 24 know, for instance alternative four and alternative 25 five.
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70 1 That's all I have.
2 CHAIR BALLINGER: Thanks.
3 MR. MESSINA: Yes. And, to build up of, 4 I know Scott previously mentioned that XLPR, you know, 5 would not just be used to update the LOCA break 6 frequencies.
7 And, we had some discussions with our 8 XLPR, some of our XLPR experts. And yes, so right now 9 there is a Reg Guide on probabilistic fracture 10 mechanics codes.
11 But, they're not application specific.
12 So, a Reg Guide would be developed as part of 13 alternative five for this application specific use of 14 XLPR as well as any acceptance criteria that goes 15 along with that, with XLPR being used for the 16 application's specific use.
17 CHAIR BALLINGER: This is Ron Ballinger.
18 I do recall actually quite a while ago, there were a 19 number of EPRI projects that produced reports that 20 used probabilistic fracture mechanics to estimate leak 21 rates and times to leak, primary leaks, the effect on 22 CDF.
23 And so, there's been quite a bit done 24 where probabilistic fracture mechanics has been used 25 to analyze breaks.
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71 1 MR. MESSINA: Yeah. And, in the licensing 2 space though for the most part, XLPR has been -- for 3 licensing space for pipes. It's been primarily used 4 for changes in relief requests for inspection --
5 CHAIR BALLINGER: Right.
6 MR. MESSINA: Inspection frequencies.
7 CHAIR BALLINGER: But, these EPRI projects 8 were pre-XLPR. They were done quite a bit before 9 XLPR.
10 MR. MESSINA: Yes.
11 MEMBER PETTI: So, let me just ask a 12 different question. Because I'm kind of losing a 13 little bit of the discussion, not having been involved 14 in the early days of XLPR.
15 Given that this was a tool co-developed by 16 both NRC research and, I guess, is it EPRI. And, 17 given the alternative licensing approach we heard 18 about from EPRI, this sounds like that they want to 19 use this to reestablish the licensing basis for either 20 a historical plant or a new plant, if there were new 21 light water reactor plant coming in for a license.
22 So, it's not like this little rulemaking 23 is the only one that's going to be bumping up to XLPR.
24 I mean, I'm kind of losing context.
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72 1 your shoulders. But, this train already left the 2 station when these guys have been working on this for 3 a number of years.
4 So, now we're worried about how good the 5 code is and asking questions? I mean, that train left 6 the track. I'm a little confused.
7 What am I missing?
8 CHAIR BALLINGER: XLPR has been validated 9 any number of ways. It's been quite a while, I think.
10 MEMBER PETTI: Right. And the fact that 11 EPRI came in and said, you know, we're looking at this 12 seriously as an ultimate licensing strategy, if the 13 staff had a problem with it, they should have flown 14 the challenge flag, you know, then, not as we're 15 sitting here talking about, you know, an enrichment 16 regulation that's going to bump up -- that's bumping 17 into this sort of because of FFRD.
18 CHAIR BALLINGER: FFRD is the elephant in 19 the room for the bigger elephant in the room.
20 MEMBER PETTI: So, you know, I'm 21 struggling because I would have expected it, you know, 22 to be the opposite way, right? That there be some 23 sort of regulatory acceptance for XLPR and that whole 24 alternative licensing approach having some foothold 25 before then you start to see sort of some applications NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
73 1 or growth of that as it touches -- you know, as 2 different issues come up. This seems to be -- it's 3 coming in the back door, which doesn't seem right to 4 me.
5 CHAIR BALLINGER: I mean, we're getting a 6 little bit ahead of my -- I don't want to use the word 7 straw man, but discussion in that every folks -- and 8 I use the word every because it could be industry, is 9 planning on a submittal, a formal submittal on ALS in 10 the first quarter of 2024, I think.
11 MR. BLEY: This is Dennis. I'm going to 12 get things a little out of order trying to think back.
13 One of the applications of this went up to the 14 Commission. And my memory was the Commission never 15 voted on it. Can the staff or Ron, can either of you 16 remember about that?
17 CHAIR BALLINGER: Yeah, I don't remember.
18 You know, XLPR was primarily developed to look at 19 primary water stress erosion cracking. I will have to 20 go back and look. I don't know. That's something 21 that we can surely find out.
22 MR. BLEY: Okay. Because that was a big 23 issue for a while. And I don't remember it ever 24 getting word from the Commission. I think it just 25 kind of languished.
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74 1 MEMBER ROBERTS: Hey, Dennis. This is 2 Tom. I'm wondering if You're thinking about the 3 transition break size ruling, which --
4 MR. BLEY: I must be.
5 CHAIR BALLINGER: Yeah, that was 6 stillborn.
7 MEMBER ROBERTS: This was a question that 8 if you look back in, you know, record safety history, 9 it goes back at least 60 years. And, you know, I 10 stumbled on a 1968 recommendation to not include the 11 large breaks in the design basis, and the AEC staff 12 rejected it because they didn't know enough. It was 13 60 years ago.
14 We have 60 years more knowledge since 15 then, but it seems like as recently as the transition 16 break size discussions, there was an ACRS letter and 17 then there was a -- I think the second they kicked it 18 off, both talk about we need to maintain the large 19 break LOCA for defense-in-depth purposes just to -- if 20 for nothing else, it's always been covered.
21 So it would seem like -- and maybe this 22 XLPR does it, we would have to be pretty confident 23 that after 60 years we really have this nailed and the 24 likelihood of this large break is just that small that 25 we don't need to worry about it.
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75 1 So, again, that's kind of why I asked the 2 question I did, which is that even as recently as 15 3 years ago, there was a board of experts that concluded 4 there was a reasonable probability of this large 5 break. And that was with consideration of looking for 6 a break and probabilistic fracture mechanics.
7 So I'm certainly not an expert in any of 8 those areas, but it seems like the people who are an 9 expert haven't really lined up behind it at least in 10 the past and, yeah, maybe things have changed to the 11 point that they will.
12 CHAIR BALLINGER: Steve Schultz? I hope.
13 MR. SCHULTZ: Yes, Ron. Thank you. I'm 14 on. Joe, just to comment and then a question. And 15 the question relates to what we were talking about 16 earlier with the opportunity to combine different 17 elements of the alternatives that might be appropriate 18 as the process goes forward.
19 You mentioned that the NUREG paper had 20 nominal assumptions in it. As I looked at the paper, 21 one of the things I noted was that as they evaluated 22 high burnup performance in the typical nominal 23 calculations that they seem to have done to put 24 together a core that would go to high burnup with high 25 enrichment, the steady state evaluation demonstrated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
76 1 that there were criteria for normal operation of fuel 2 rods that were violated especially at -- or 3 essentially the internal rod pressure, clad liftoff 4 criteria and so forth. And yet they went ahead with 5 the LOCA evaluation given that and in a certain sense 6 thereby increased the rod performance as it came 7 through with regard to the clad cracking and the 8 dispersion of fuel and so forth.
9 The reason I say this in terms of 10 combining different alternatives, one would assume 11 that the fuel design, as you mentioned earlier, fuel 12 design, cladding design, would be really a part of any 13 solution going forward. And that would then combine 14 Alternative 1, Alternative 4 and Alternative 5 as a 15 possibility, the combination of those.
16 MR. MESSINA: Yes. I'm not sure exactly 17 what the question is, but yeah, different alternatives 18 could be, you know, combined. And the study with the 19 NUREG paper, you know, it was just to get a general 20 idea of how much fuel would be disbursed. You know, 21 we've had discussions with Oak Ridge National Lab and 22 other people on, you know, how could we improve what 23 we did in that work.
24 So but, yeah, ultimately clad design and 25 fuel design, you know, could always be changed to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
77 1 optimize performance for different things and, you 2 know, possibly, you know, help with FFRD so.
3 CHAIR BALLINGER: Well, my comment was 4 that the designers would need to address the steady 5 state fuel operation criteria and limitations before 6 they even address the accident evaluation. But that 7 wasn't a part of the evaluation that was done in the 8 NUREG paper.
9 MR. MESSINA: Yes. They definitely would 10 have to address that.
11 CHAIR BALLINGER: Okay. I guess this is 12 kind of an artificial break between discussion of the 13 presentation and committee discussion because in fact 14 we've been having it for a while.
15 So let me propose -- we now have to have 16 a discussion about path forward. Oops, wait a minute.
17 I'm sorry. Charlie Peabody.
18 MR. PEABODY: Thanks. During the break we 19 were discussing the original question, and I believe 20 Chair Rempe asked about basically the accident 21 tolerant fuels and how, you know, possibly having, you 22 know, fuel cladding with a higher, you know, melting 23 point than the control elements.
24 When we had some more discussions, we kind 25 of believed that we would address that during the like NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
78 1 license amendment phase for a fuel transition and if 2 it was an operating licensee or during the licensing 3 process if it was a new reactor licensee because those 4 are changes to the accident analysis sequence and 5 timing assumptions. So that would be like one we 6 would expect to deal with that not necessarily as part 7 of this rulemaking process.
8 MR. MESSINA: Yeah. The rulemaking 9 process isn't trying to solve every single problem 10 associated with ATF compared to, you know, current 11 field designs. Just, you know, tackle the big issue, 12 the regulatory issues of that.
13 MEMBER REMPE: So this is Joy --
14 CHAIR BALLINGER: Yeah, this goes to Joy's 15 question, right?
16 MEMBER REMPE: Yeah. And this is Joy. I 17 appreciate the additional feedback. I guess, again, 18 I know You're talking about consideration of 19 mitigating strategies in other aspects of this and how 20 that's the source term. So it's good to know that 21 You're not expecting Sandia to include all of this in 22 their updated AST analyses is what I think I'm 23 hearing. You're going to expect the applicants to do 24 this. But I think it might be good to make sure that 25 the applicants are aware of this. Because I don't see NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
79 1 it clearly discussed that You're expecting this under 2 Alternative 4.
3 MR. MESSINA: So this doesn't really --
4 this is kind of outside of the fuel disbursal 5 discussion. This is just purely ATF, you know, the 6 accident timing if someone were to do ATF.
7 MEMBER REMPE: Right. So, again, if you 8 were going to call part of this rulemaking an ATF, it 9 would be good to explain to them that you excluded 10 this from the rulemaking discussion, but it's 11 expected.
12 Again, I'm not sure they get that much 13 extra margin because the margin has decreased with 14 time that we see in some of the more refined analyses.
15 But if they -- you know, it would be good to have that 16 discussed somewhere is all I'm just trying to bring 17 up. That's just why I brought it up at the beginning 18 here.
19 MR. BENAVIDES: Yeah, yeah. I would agree 20 with that. And I think, too, like, a lot of the ATF 21 was originally seen as a precursor to increasing 22 enrichment. But I think that if are looking at 23 increasing enrichment with commercial fuels, I think 24 that you still have, you know, superior efficiency 25 just from an operating standpoint.
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80 1 I don't know that we'll never get any 2 accident tolerant fuel spills. But we at least 3 haven't been hearing that discussed as much since we 4 actually included the commercial in the rulemaking as 5 well the incident tolerant fuels.
6 MEMBER REMPE: Okay. Thank you.
7 CHAIR BALLINGER: Okay. Going back to 8 these alternatives before we start the discussion, my 9 understanding is that Alternative 5 would basically 10 eliminate fuel failure as a possibility during an 11 accident. And if you eliminate fuel failure, you 12 eliminate disbursal. So the cleanest way to address 13 FFRD is to not have it. That may be a leading 14 question, but is that a correct interpretation?
15 MR. MESSINA: Yes. We feel that the 16 simplest way to address FFRD is to prevent high burnup 17 rod burst. So, yes, under Alternative 5 as well as, 18 you know, Alternative 1 and possibly, you know, 19 Alternative 2, as written, would be to prevent rod 20 burst. Obviously 1 and 2 do it differently than 5, 21 but, yeah.
22 CHAIR BALLINGER: Okay. All right. So 23 let's see. I don't see any more hands up. Now we --
24 MEMBER PETTI: Ron?
25 CHAIR BALLINGER: Yeah, yeah.
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81 1 MEMBER PETTI: Let me just make sure I 2 understand where you are coming from. What you are 3 saying is that you are somehow risk informing rod 4 burst being precluded based on some risk.
5 CHAIR BALLINGER: Well, I think that's 6 what XLPR in effect does, right?
7 MEMBER PETTI: But even this Alternative 8 2, with a transition break size appropriately modified 9 as Joe said, is kind of the same idea. You are 10 precluding it from the design basis.
11 CHAIR BALLINGER: Right. Yeah.
12 MEMBER PETTI: Right.
13 CHAIR BALLINGER: Yeah, yeah. Yeah.
14 Okay. So now for my straw man or path forward, I 15 would think that we would write a letter on this 16 topic. And then according to the staff, the input on 17 FFRD will come, and they will incorporate those 18 comments into the proposed rule, which we would get a 19 crack at either before or after public comment.
20 That's up to the committee.
21 In the meantime -- Joy's got her hand up, 22 of course. In the meantime, the EPRI folks will be 23 submitting the ALS process formally, supposedly in the 24 first quarter. And so we will have the advantage of 25 being able to either review that or have a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
82 1 presentation or at some point some way to take a look 2 at that ALS in detail because we've had presentations 3 that discuss ALS, but they have been mostly part and 4 parcel of a larger presentation.
5 So that would be a proposal for going 6 forward. And I'm sure Joy has an opinion.
7 CHAIR REMPE: Actually, my hand is up not 8 for that. I think this discussion about whether we 9 should write a letter or not might be best after 10 public comment. What do you think? Just because I 11 think that it's --
12 CHAIR BALLINGER: Well, here's --
13 CHAIR REMPE: It's just up to you. It's 14 just a suggestion.
15 CHAIR BALLINGER: No, no, no. It's not up 16 to me. It's up to the committee as a whole.
17 subcommittee and the committee as a whole.
18 If that were to happen, then we would not 19 write a letter on this right now. But we wouldn't --
20 that letter would not occur until probably the middle 21 of next year when we would get the rule language if 22 I'm looking at the schedule correctly. That has, by 23 the way, the advantage of --
24 MEMBER PETTI: Ron, Ron, I think you 25 misunderstand Joy. She might be --
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83 1 (Simultaneous speaking.)
2 CHAIR BALLINGER: I am definitely prone to 3 misunderstanding.
4 MEMBER PETTI: I want you to go out to 5 public comment first and then we go to, you know, our 6 next steps.
7 CHAIR BALLINGER: Yeah. So that would 8 mean that public comments, the one that they're -- the 9 public comments that they're expecting are related to 10 FFRD.
11 MEMBER REMPE: No, I'm saying public 12 comments for this subcommittee meeting. And then 13 let's have a larger discussion --
14 CHAIR BALLINGER: Oh, I'm sorry.
15 MEMBER REMPE: -- and then proceed 16 providing input.
17 CHAIR BALLINGER: All right. I am prone 18 to --
19 (Simultaneous speaking.)
20 MEMBER REMPE: Dave and I are talking the 21 same way but, yeah, You're -- anyway. It's up to you.
22 You're the subcommittee chair, but --
23 CHAIR BALLINGER: Hit the rewind button.
24 It's time to go out for public comments. There are 25 100 people on this call. Are there any members of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
84 1 public that would like to make a comment? If you 2 would like to make a comment, please state your name 3 and make your comment. And the numbers keep going up.
4 Ed Lyman?
5 MR. LYMAN: Yes, hi. It's Ed Lyman from 6 the Union of Concerned Scientists. Can you hear me?
7 CHAIR BALLINGER: Yes.
8 MR. LYMAN: Yes. Thank you for the 9 opportunity. I would just like to say, you know, 10 walking down memory lane, I think most people realize 11 this is not a new issue. In the 2005 time frame, we 12 looked at it in the context of MOX fuel because there 13 was -- Duke Energy had applied for an OTA application 14 for MOX fuel test assemblies. There was an issue with 15 potential vulnerability of MOX fuel to high burnup 16 effects, even at lower burnup, including FFRD.
17 IRSN at the time was coming to the NRC and 18 pleading for help in research funding to look at that 19 issue as well as the impact of things like ballooning 20 of multiple fuel rods and three dimensions on heat 21 transfer and core coolability.
22 I don't think any of that work was ever 23 done experimentally. The funding never came through.
24 And so here we are, you know, almost 20 years later 25 with a missed opportunity to possibly have more NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
85 1 informed discussions about that.
2 So long story short, we don't think that 3 there is a technical basis for any option that would 4 essentially wave a risk magic wand and make this issue 5 go away. In fact, it's time that the Commission fully 6 confront the safety issues associated with high burnup 7 fuel and not continue to kick that can down the road.
8 So I don't want to jump the gun on our 9 comments, but I don't think any solution that would 10 essentially remove analysis of this potentially 11 significant safety issue from the design basis would 12 be appropriate. This is a design basis issue. This 13 is a fundamental safety requirement for nuclear power 14 plants is that they can survive a loss of cooling --
15 a design basis loss of cooling accident without, you 16 know, the excessive fuel damage that would potentially 17 lead to a propagation of the accident and a full scale 18 core melt.
19 So, again, we are concerned about these 20 efforts such as Alternative 5 and even Alternative 2 21 to try to just make the issue go away without having 22 to confront it. And that's the sort of preview of 23 what our comments are going to be.
24 One other thing, with regard to Dr.
25 Rempe's observation about the melting of the control NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
86 1 rods before the fuel, I didn't hear a really good 2 response to that.
3 And I would think that -- this rulemaking 4 is an opportunity to look at sort of the broader --
5 some of the broader issues associated with higher 6 enrichment fuel safety issues that might include some 7 additional accident analysis that might envelope 8 considerations such as what Dr. Rempe brought up.
9 Also I want to point out that these -- as you approach 10 10 percent, the void coefficient and the WR starts 11 approaching zero. And that could be a synergistic 12 effect with other impact summary activity in a severe 13 accident.
14 So it seems like there is a wealth of 15 other issues that should probably be encompassed in 16 this rulemaking, especially if the original basis for 17 accident tolerant fuel seems to be going by the 18 wayside that was actually making reactors safer.
19 Instead, we're getting bait and switch that the main 20 basis for the research money that the Department of 21 Energy put into accident tolerant fuel is now being 22 redirected or misdirected toward simply allowing 23 increased enrichment and increased burnup for economic 24 reasons without any common safety benefit.
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87 1 that I think should all be considered in the 2 rulemaking discussion and the package and the 3 associated analysis. That's my comment. Thank you.
4 CHAIR BALLINGER: Thank you. Excuse me.
5 Whoops. Donna Gilmore, please.
6 MS. GILMORE: Can you hear me?
7 CHAIR BALLINGER: Yes, I can.
8 MS. GILMORE: Okay. Thank you. I don't 9 see any mention of an evaluation of the metal hydrides 10 created, you know, during the reactor process. The 11 zirconium hydrides, the uranium hydrides, plutonium 12 hydrides, none of that is addressed.
13 Dana Powers years ago said the NRC has 14 ignored the metal hydride issue which can cause 15 explosions of basically at any temperature. So I 16 would like to know if that is being addressed.
17 We're sitting here at the current plants, 18 like at San Onofre, we have this fuel that impacts 19 hydrides. We've got damaged hydrides or damaged fuel.
20 We've got fragile fuel because, you know, the fuel is 21 thinner, the fuel rods. You know, the uranium pellets 22 are becoming less dense. You know the zirconium is 23 becoming thinner. You know about the radial hydrides.
24 We're not even at the LOCA period. We're just at the 25 period of how damaging the high burnup fuel is right NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
88 1 now and yet we're just trying to jump to higher.
2 Are those issues going to be covered in 3 this rulemaking or NORD? To me this is a major issue.
4 I am concerned that if air gets into these canisters 5 if we're going to be faced with explosions because of 6 these metal hydrides and now we're just talking about 7 just making the problem worse.
8 And my second question/comment is with 9 higher enrichments, you know, there's a normal amount 10 of radiation that's released by normally operating 11 reactors into the environment. You know, what kind of 12 percentage increase are we going to get being released 13 out into the environment from reactors with these 14 higher burnups? Is that addressed anywhere?
15 Those are my two comments/questions.
16 CHAIR BALLINGER: Thank you. Next in line 17 is Paul Clifford.
18 MR. CLIFFORD: Yes. Good afternoon. So 19 several of the fuel disbursal alternatives involve 20 rulemaking, presumably including 5046.
21 If the staff were to propose or recommend 22 one of these alternatives that involve rulemaking, 23 would those changes be relative to the existing 24 regulation or would they be relative to the proposed 25 final 50.46c?
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89 1 I ask because there are portions of 50.46c 2 that are still relevant. The rule could be improved 3 upon to make it more technology neutral and more 4 performance based. And there is an opportunity to 5 combine these changes with the increased enrichment 6 changes that are being discussed today and that there 7 could be really an opportunity for synergy with the 8 implementation of both in a coincident fashion.
9 CHAIR BALLINGER: Thank you. Next, Kalene 10 Walker.
11 MS. WALKER: Hello. So I live in a 12 reactor community where there is stranded spent fuel 13 waste storage. And because of this I have really 14 studied the canister systems and the susceptibility to 15 cracking, corrosion cracking, and also the concerns 16 about the fuel, the high burnup fuel and the condition 17 of the fuel, the hydrides and all of the problems with 18 fuel cladding that the previous caller spoke on, which 19 the NRC seems to kind of ignore, you know, even saying 20 that the canisters are safe to transport when they 21 don't even have a way to inspect one canister or the 22 fuel within it.
23 So when I started listening in on these 24 new reactor fuels and higher burnups and everything, 25 and I heard about fuel fragmentation relocation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
90 1 distribution from a LOCA, I was kind of appalled and 2 shocked because I saw these higher burnups turning the 3 fuel pellets into dust, you know, small particles and 4 dust.
5 So my question is, how in the world would 6 you take -- and broken, damaged fuel. How in the 7 world would you handle damaged fuel where the fuel has 8 become, you know, small particles? Are you going to 9 put that into a pool? Are you going to take -- who is 10 looking at the back end of this? You know that there 11 is going to be a huge problem in the reactors if there 12 is a loss of cooling.
13 But then we have this forever waste that, 14 you know, these reactors create. And I keep looking 15 for Part 72 and all these NUREGs. And they just say, 16 oh, it will just be managed like the previous fuel, 17 you know.
18 And, you know, the only answer I have 19 gotten from the NRC is, oh, we're very early in the 20 process. Well, it doesn't sound like it. It sounds 21 like you are going to be allowing this through 22 exemption to be putting higher enriched fuel, you 23 know, into existing reactors before you start putting 24 in small modular reactors.
25 I mean, at some point, I think the NRC and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
91 1 the ACRS needs to say this is not a good plan. This 2 is not a good path forward regardless of the financial 3 benefit for the industry. But I am very curious when 4 Part 72 will be addressed. Thank you.
5 CHAIR BALLINGER: Thank you. Okay. I 6 want to be sure that we don't miss somebody. Donna 7 Gilmore, your hand is still up. Is that a mistake?
8 MS. GILMORE: Yeah, that was a mistake.
9 CHAIR BALLINGER: Okay. Also again, 10 Kalene Walker, your hand is still up.
11 MS. WALKER: I'm trying to lower it.
12 CHAIR BALLINGER: Okay. Thank you. Okay.
13 I don't know, but are there any other members of the 14 public that are on the line that are not on our list 15 here that would like to make a comment? If there are, 16 please state your name and make your comment.
17 Hearing none, okay, now I think we are re-18 centered a bit. Now additional discussion among the 19 members. What I have -- my initial thoughts were to 20 write a letter on this and then write a second letter 21 or more after we get the rule, and which would include 22 the comments on FFRD, which are not in this -- not 23 incorporated into this current revision.
24 But Dave has had a different thought, 25 which is to say wait until we get the public comments NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
92 1 and do the rule. Is that what I'm hearing, Dave?
2 MEMBER PETTI: No, no. What I'm saying is 3 --
4 CHAIR BALLINGER: Okay.
5 MEMBER PETTI: -- is now is there 6 something that we can help the process by providing 7 not necessarily detail on, you know, which alternative 8 we like, but what criteria? How would we think about 9 the problem? What are the important things to be 10 considered because you have to balance, we've heard --
11 you know, it's a classic case of defense-in-depth 12 versus risk informing. And how do you strike that 13 balance? And, you know, are there words of wisdom 14 that we can give the staff as they think about it?
15 CHAIR BALLINGER: So You're saying that 16 that would be in the form of a letter on this topic, 17 on this document?
18 MEMBER PETTI: Yeah, yeah.
19 CHAIR BALLINGER: Okay. So a letter on 20 this document, and then we would out of necessity have 21 to have -- want to do a letter once we get the rule, 22 which will incorporate the FFRD input, and we would 23 have the benefit -- we will have the benefit of the 24 ALS discussion that we would have with the EPRI folks 25 based on their submittal.
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93 1 But what Dave is proposing is quite a 2 different letter, which is great actually.
3 MEMBER PETTI: I just wonder, what do the 4 other members think?
5 CHAIR BALLINGER: Yeah, that is what I was 6 about to say. We don't have -- we have Bob. We have 7 Den -- well --
8 MEMBER MARTIN: Yeah, this is Bob. I am 9 absolutely in support of providing a letter sooner 10 than later. In some ways my impression from the 11 presentation is, you know, it just kind of scratches 12 the surface for what it might touch. And I think, you 13 know, us getting together and, you know, pooling our 14 thoughts, I think we could really add value to the 15 process. So I'm with Dave there on moving forward, 16 you know, early in this process.
17 CHAIR BALLINGER: Okay. Let's see. I 18 would suggest then that if we're going to have that 19 kind of letter that we have a more formal structured 20 discussion before we do the letter than just having a 21 discussion here because it's a new thought, and it's 22 a pretty significant thought. What do members think?
23 We have plenty of time apparently because 24 we're not expecting anything related to the rulemaking 25 until the end of next year or middle of next year.
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94 1 MEMBER MARTIN: Yeah, I would think we 2 would want to cover this in the full committee. I 3 don't know what our schedule is offhand for November.
4 But I think --
5 MEMBER REMPE: So this is --
6 MEMBER MARTIN: -- go ahead.
7 MEMBER REMPE: I'm sorry. I thought you 8 were done, and I was going to provide input on the 9 schedule for November. We have two letters scheduled.
10 And the first one will be on the Level 3 EPRA, and the 11 second one that was scheduled was this one. Because 12 of the timing and all of that, it would start -- the 13 discussion would start on the second in the morning.
14 I'm not sure I understand what Ron is 15 saying about having a more structured discussion.
16 Does that mean you want staff to not come back with 17 the whole review of all of what's in the regulatory 18 basis document? Are you thinking you would like to 19 delay it a month or so, Ron? But it's fine. We can 20 do that.
21 CHAIR BALLINGER: No. What I'm thinking 22 about is we have -- because I assume that we were 23 going to do a sort of, I call it, a standard letter, 24 we have time allotted during full committee. But we 25 could ask -- because we're talking about a full NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
95 1 committee discussion, we could ask the staff to give 2 that presentation in November because it's already 3 scheduled, but have the discussion a little bit 4 different because now You're addressing the topic to 5 the full committee followed by a discussion which is 6 in much more detail and a little bit different than I 7 had originally anticipated to be pretty much focused 8 on fuel disbursal.
9 So we could use that time to bring the 10 full committee up to date because there are a number 11 of members that are not here, I don't see, that would 12 be -- whose input would be, I'm sure, quite valuable.
13 So that would be a thought on how to 14 proceed, and it doesn't short change anybody.
15 MEMBER ROBERTS: I might have a slight 16 different view than Dave and Bob. And Ron said we 17 were going to get a presentation from EPRI sometime in 18 the first quarter or 2024. And they are going to give 19 us their view of the balance of risk informing versus 20 defense-in-depth. And I think there are pieces of 21 both because defense-in-depth are risk informing 22 includes a defense-in-depth component.
23 And so if we're going to give advice to 24 the staff on how we would approach this, then we might 25 benefit from hearing EPRI's view in more detail than NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
96 1 getting the white paper from a couple years ago. And 2 it may help, if nothing else, kind of crystallize what 3 our view is or at least what we think the issues are.
4 So there's no great hurry to send a letter 5 back. There may be benefit to scheduling the letter 6 to follow that EPRI presentation.
7 CHAIR BALLINGER: Yeah. You know, there 8 is another piece to this and that is -- I'm pretty 9 sure the EPRI people are listening to this discussion 10 -- that our discussion that we've had thus far might 11 help steer or inform the meeting that we would have on 12 ALS when they do their submittal because what Tom is 13 saying is that, you know, this is much broader than 14 FFRD. What do people think about that?
15 MEMBER PETTI: That's a little chicken and 16 egg, right?
17 CHAIR BALLINGER: Well, I don't know if 18 it's chicken or egg. It's just the detailed 19 discussion of ALS that's on the record would be quite 20 informative.
21 MEMBER PETTI: Yeah, no, I'm just saying, 22 you know, who is informing who? Tom would like us to 23 wait until we hear on that in an actual submittal so 24 we can be informed. But then you were sort of 25 implying, well, EPRI's on the line. And if we put NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
97 1 that information out, it may inform them.
2 CHAIR BALLINGER: No, I guess, what I was 3 saying was that a lot of the comments that Tom has 4 made related to defense-in-depth and the like might 5 inform in some respects the ALS discussion. More 6 comments? We need to have at least some kind of path 7 forward anyway.
8 MS. ABDULLAHI: Ron?
9 CHAIR BALLINGER: Yes?
10 MS. ABDULLAHI: Can you ask the staff what 11 they want? Because I was under the impression that 12 they asked for a letter, but it's better to ask them 13 instead of me speak for them.
14 CHAIR BALLINGER: Yeah, I kind of react 15 negatively to that because it's really up to us in the 16 end. What do other members think?
17 MEMBER MARTIN: This is Bob. I hate to 18 throw out a compromise, but we can have a letter now 19 and a letter later, right? There is nothing that 20 precludes we get more information and, you know, I 21 think, you know, with more information we'd have a 22 different message.
23 You know one of the things about waiting 24 is I would be very curious about what the pertinent 25 sites carry. But I do think there are -- you know, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
98 1 prior to public comment, there are messages or 2 recommendations that we might be able to vet out of, 3 you know, our next month discussion that might be 4 worthwhile. And if the staff is interested, I think 5 I support the staff.
6 CHAIR BALLINGER: So let me try to put 7 what people are saying in words that I understand. So 8 as I think I've alluded to, we have a presentation by 9 the staff in November. But based on that discussion 10 -- after that presentation, the committee as a whole 11 has a more detailed discussion amongst themselves.
12 And then the letter that we produce follows that.
13 In other words, it's not a letter that we 14 would have a draft ready for full committee in 15 November. It would be a letter that we would produce 16 for say the following month's full committee that 17 would have the tone that Dave has suggested, among 18 other things. Is that what I'm hearing?
19 MEMBER REMPE: So this is Joy, and I would 20 not be so absolute that it has to wait until next 21 month. First of all, we have often said interim 22 letter, and we know that staff hasn't decided what 23 they are going to do about FFRD yet. So clearly this 24 would be that type of interim letter that will get 25 more informed as things move forward.
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99 1 I strongly support what Dave has suggested 2 about framing the issue and getting some guardrails, 3 I think is the word he used during the discussion. I 4 do not support having a letter that talks about every 5 topic and regurgitates what is in the 200 page 6 regulatory basis document. You know, so I don't think 7 we should have to spend time on letter writing on 8 that. But maybe have this discussion and come up with 9 some key points after the staff gives a truncated 10 presentation of what they went through today.
11 And, you know, maybe Dave and you can work 12 up some preliminary thoughts for guardrails and then 13 bounce it off of the committee during that discussion 14 time.
15 CHAIR BALLINGER: That's a --
16 MEMBER REMPE: We have two letters we're 17 doing in November so we can go back and forth. And 18 that would be on the second day, Thursday of the 19 meeting, during November. And we do have Friday. So 20 we could come close to finishing the letter this 21 month. And then if it does get delayed, it gets 22 delayed and finish it up the next month.
23 But we do have two letters scheduled for 24 December and, you know, saying I'm going to wait and 25 not finish the letter until December, that would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
100 1 create other difficulties because of other things that 2 occur before the full committee meeting in December.
3 Okay? Dead silence.
4 CHAIR BALLINGER: No. I'm trying to make 5 sure that I have things clear in my head.
6 MEMBER PETTI: No, I think that's okay.
7 I mean, Bob clearly has some perspective, Bob and Tom 8 have perspective here.
9 CHAIR BALLINGER: Yeah.
10 MEMBER PETTI: If we could kind of put 11 some thoughts together in preparation for -- what's 12 going to help the full committee is that people have 13 some of these thoughts, you know, ahead of time we'll 14 put the paper so we don't have to do that at the full 15 committee.
16 CHAIR BALLINGER: Okay.
17 MEMBER PETTI: We just have to kind of 18 assemble it, right, and synthesize it. But if 19 everybody would -- what I call guardrails, sort of 20 what are the key things you are going to think about 21 in terms of, you know, a success path, if you will, 22 you know, through this option space?
23 CHAIR BALLINGER: Okay. So --
24 MEMBER PETTI: What are the considerations 25 that are important.
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101 1 CHAIR BALLINGER: So --
2 MEMBER PETTI: That's what I would want to 3 do.
4 CHAIR BALLINGER: Okay. What I'm hearing 5 then is that for the discussion at the full committee, 6 we would put what amounts to an outline together that 7 we would present for discussion at the full committee 8 to basically guide the discussion. And then based on 9 the feedback from the members on that outline, then we 10 would produce a letter. Now I'm hearing silence.
11 MEMBER REMPE: I think that's great. And 12 I do agree that Bob and Tom should also contribute.
13 I just was saying get a small group and have some 14 thoughts ahead of time.
15 I do think we don't want as long of a 16 presentation. But maybe if the staff could give --
17 realizing that the letter is going to be not -- it has 18 a different purpose than perhaps what they thought and 19 maybe give a very small truncated presentation because 20 it's full committee and a different audience.
21 CHAIR BALLINGER: Yeah, here is another 22 thought that I might add. If we can put this outline 23 together quickly, reasonably quickly, certainly before 24 the -- in time to let the staff see it, that might 25 inform their presentation. Maybe we just don't have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
102 1 enough time to do that.
2 MEMBER PETTI: Yeah, I worry about that.
3 I'm pretty busy next week.
4 MS. ABDULLAHI: We don't have to worry 5 about the FACA. I don't really know that we can give 6 an advance.
7 CHAIR BALLINGER: Okay. All right. Gosh.
8 Okay. All right.
9 MEMBER PETTI: But I also think, you know, 10 who is -- we have, what, two or three members that 11 aren't here, right?
12 CHAIR BALLINGER: Yeah, I know, that's the 13 reason why this full committee discussion is 14 important. Greg is not on here. And do I see Matt?
15 There is 98 people on this thing.
16 MEMBER SUNSERI: Matt is on. Matt is on.
17 MEMBER REMPE: Vicki, I'm not sure if 18 Vicki --
19 CHAIR BALLINGER: Okay. So Matt is on.
20 That's important.
21 MEMBER PETTI: I don't think Vicki is on.
22 Is Vesna?
23 MEMBER REMPE: Walt is in France.
24 CHAIR BALLINGER: Yeah, she's on.
25 MEMBER PETTI: Okay. And then Walt, Walt NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
103 1 is in France.
2 CHAIR BALLINGER: Yeah, and those are --
3 that's got to be important input.
4 MEMBER PETTI: Right. That's why I'm 5 saying they need to -- they probably need to hear 75 6 percent of the sides. Oh, there's Vicki. Vicki's on.
7 MEMBER BIER: Vicki is here. But I'm at 8 an airport so I've been following with some 9 difficulty.
10 CHAIR BALLINGER: Okay.
11 MEMBER PETTI: Yeah, so I think it, you 12 know, not -- you know, in the past when we've told the 13 staff high level summary, it's because we've all been 14 in the room at subcommittee. We want fewer slides, 15 but that may still be 75 percent of what you've got 16 because we've got members who were not here.
17 CHAIR BALLINGER: Now I'm asking how much 18 time did we allot for the staff for November? I don't 19 have that information.
20 MEMBER PETTI: It's probably two hours, 21 right, the usual?
22 CHAIR BALLINGER: Yeah, Larry is --
23 MEMBER REMPE: I'm pulling up the agenda.
24 Larry is not here, but I signed off on it. And I'm 25 looking here, quickly.
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104 1 CHAIR BALLINGER: Yeah, Larry is sitting 2 on a beach.
3 MEMBER REMPE: We have 8:30 to 10:30. But 4 because the discussion is going to be a lot more 5 important, we had 10:30 to 11:30 or after 10:30 for 6 the committee deliberations. But I would suggest you 7 try and limit it to an hour, an hour and a half, Ron.
8 But, again, that's just a suggestion to keep people 9 focused.
10 CHAIR BALLINGER: Now are you saying an 11 hour1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, an hour and a half for their presentation or the 12 total?
13 MEMBER REMPE: The agenda allocated two 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> for the presentation and questions from the 15 committee. If I were you, I would suggest that the 16 presentation be abbreviated and not take the full two 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> because I think --
18 CHAIR BALLINGER: Oh, yeah. Okay.
19 MEMBER REMPE: -- that the discussion is 20 going to be more important for getting this letter.
21 CHAIR BALLINGER: So if we were to ask the 22 staff to limit it to an hour, then we have another 23 hour2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br />. And could we add another half hour onto that 24 just for --
25 MEMBER REMPE: Oh, you have -- again, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
105 1 have a very open and flexible agenda. But after that, 2 I already have given you an hour to an hour and a half 3 for discussion for the letter.
4 CHAIR BALLINGER: Okay. All right.
5 MEMBER REMPE: But you can have two and a 6 half or if you want less time --
7 CHAIR BALLINGER: Okay.
8 MEMBER REMPE: -- we can do lunch early 9 and come back.
10 CHAIR BALLINGER: Okay.
11 MEMBER REMPE: You know, there's a lot of 12 flexibility.
13 CHAIR BALLINGER: Okay. I think we're 14 getting a little bit of convergence here.
15 MEMBER PETTI: So --
16 CHAIR BALLINGER: So I'm getting -- Dave?
17 MEMBER PETTI: So, no, I'm just saying, if 18 it's allowed, and I need people to tell me, I would be 19 happy to be the collator of people's thoughts and put 20 it together so that it will just help the focus of the 21 meeting in full committee.
22 MR. MOORE: So this is Scott Moore.
23 MEMBER PETTI: Can we -- do you have --
24 MR. MOORE: Yeah, this is Scott Moore.
25 Can you hear me, Dave?
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106 1 MEMBER PETTI: Yeah.
2 MR. MOORE: Okay. So what the committee 3 members can do is -- the committee members can 4 provide, you know, one member input so they can 5 collate it and put together something. Once that's, 6 you know, assembled, then that would need to be 7 discussed in a public meeting.
8 MEMBER PETTI: Right, right. Okay. Well, 9 I'll volunteer, Ron. You get the boilerplate, and we 10 have to say something about the other parts of the 11 rulemaking. Not that we have to spend a lot of time 12 on it, but we need to at least say whether we agree 13 with, for instance, their recommended approaches on 14 the other side.
15 CHAIR BALLINGER: Yeah, that's, you know, 16 what I'm -- okay, I suppose.
17 MEMBER PETTI: And I'll take the input 18 from the other guys and that will be the start of the 19 last piece, the FFRD.
20 CHAIR BALLINGER: What I'm suggesting is 21 that we don't produce a letter in November because we 22 have to have the committee of the whole discussion, 23 which is a little bit different. What You're saying 24 is --
25 MEMBER PETTI: Let's try. We're going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
107 1 need that. We still need all that stuff that we 2 always have in the beginning of the letters, you know?
3 That all still has to be there. And I think we do 4 want to say whether we agree or disagree with the 5 other parts of the rulemaking. The other pieces that 6 it touches.
7 CHAIR BALLINGER: Yeah.
8 MEMBER PETTI: Because that just --
9 CHAIR BALLINGER: Okay.
10 MEMBER PETTI: -- and that's the reason.
11 I agree with the ones -- the recommended actions. I 12 think we just want to be on record with that.
13 CHAIR BALLINGER: Yeah, okay.
14 MEMBER PETTI: And then this one, you 15 know, it takes a little bit more. It will be really 16 the guts, the important, the meat of the letter. But 17 that will at least focus us.
18 MEMBER REMPE: This is Joy. And --
19 MEMBER DIMITRIJEVIC: So we are still 20 having --
21 MEMBER REMPE: We have two letters -- real 22 quick, Vesna. We have two letters in December. They 23 are already scheduled, and you are the lead on one of 24 the other letters in December. So let's try --
25 MEMBER PETTI: Yes.
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108 1 MEMBER REMPE: -- if it goes on, it goes 2 on. Go ahead, Vesna. I apologize for interrupting.
3 MEMBER DIMITRIJEVIC: That's what I was 4 sort of like trying to decide. Are we discussing now 5 are we going to write a letter or not write a letter 6 or not write a letter in November or how are we going 7 to write a letter? That's what --
8 MEMBER PETTI: I think we should try to 9 write the letter and try to get --
10 MEMBER DIMITRIJEVIC: Maybe we should know 11 more on that day. If it's just how you run things, 12 we shouldn't, you think we should make --
13 CHAIR BALLINGER: I'm thinking that if we 14 want to take the path that Dave is suggesting in terms 15 of providing guardrails as he has mentioned and things 16 like that, then that requires a much more extensive 17 discussion before that piece goes into the letter.
18 And I suggested that we have an outline for at least 19 that part for November for the full committee 20 discussion. I have no problem providing a letter, but 21 I'm thinking a letter that just agreed with what their 22 suggestions are is a different letter. You know, the 23 --
24 MEMBER PETTI: No, no, I'm saying that 25 will all be the beginning of the letter. And then NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
109 1 there will be this final section, which is what we'll 2 focus most on in full committee. I'll have --
3 CHAIR BALLINGER: Okay.
4 MEMBER PETTI: -- received input from 5 people. I'll assemble it, put it in context. And 6 that's how we'll -- you know, we'll go from there.
7 And hopefully, I think -- because I think 8 the stuff that You're going to put in is going to be 9 pretty non-controversial. We can see --
10 CHAIR BALLINGER: Okay.
11 MEMBER PETTI: -- all of that and just 12 focus on this.
13 CHAIR BALLINGER: Yeah, the plan I had in 14 the original letter was to just say by the way, the 15 document is not considered FFRD. And that's for 16 future -- you know, that's going to happen in the 17 future, but it's important.
18 And so instead of that, we would put a 19 much more detailed discussion of what you keep -- you 20 term guardrails and the like. That's fine. But what 21 I'm saying is I don't think we should constrict --
22 maybe there's enough time. Maybe there's plenty of 23 time, and it's no big deal.
24 But I don't think going in we should 25 constrain ourselves to have something finished as a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
110 1 letter in November because we might have input from 2 other members, which are different thoughts, which are 3 valuable input, which we have to digest and to cram --
4 you know, to go back to the hotel at 2 o'clock in the 5 morning and come up with input to me just seems like 6 going a little too fast if that's what comes up.
7 MEMBER MARTIN: I agree, Ron. I think we 8 should commit to doing the best we can with the time 9 available. And we can't foresee what others might 10 think that are not here.
11 CHAIR BALLINGER: There's nothing to 12 prevent us from having a draft letter done in November 13 and having it spill over into December, I don't think.
14 MEMBER REMPE: I agree with what You're 15 saying, Ron. I just think we should try and if it 16 doesn't work, it doesn't work.
17 CHAIR BALLINGER: Try is one thing. But 18 try under penalty of death is another thing. Okay.
19 So I'll produce boilerplate and letter and that kind 20 of stuff, Zena and I will.
21 And Dave will assemble input from folks, 22 which by the way might end up including input based on 23 -- input from member that aren't even here based on 24 the discussion at the full committee meeting and then 25 we'll go from there. What do people think?
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111 1 MR. BLEY: Oh, for God's sake.
2 CHAIR BALLINGER: Who is for God's sake?
3 MEMBER PETTI: She just asked, you need to 4 get votes from the members, Ron, to go around and ask.
5 CHAIR BALLINGER: Yeah, I was kind of 6 hoping I would get more comments, but.
7 MEMBER PETTI: Yeah.
8 CHAIR BALLINGER: Okay. Well, I'll go 9 around the room. Bob, what do you think?
10 MEMBER MARTIN: It sounds good to me.
11 CHAIR BALLINGER: I'm just trying to go 12 exactly -- I don't need to know what Dave is sending.
13 MEMBER SUNSERI: Matt's okay with the 14 plan.
15 CHAIR BALLINGER: Okay. That's Matt.
16 Joy?
17 MEMBER REMPE: The plan sounds good to me.
18 Thanks.
19 CHAIR BALLINGER: Matt we already have.
20 MEMBER BIER: This is Vicki, Ron.
21 CHAIR BALLINGER: Yeah, yeah. Okay. I'm 22 not down to the V's yet.
23 MEMBER BIER: Okay. You want to wait? I 24 can wait.
25 CHAIR BALLINGER: No, no, I was kidding.
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112 1 Go ahead.
2 MEMBER BIER: Okay. I just wanted to say 3 I like the idea of starting in November and going into 4 December if need be. It makes sense to me.
5 CHAIR BALLINGER: Okay. Tom?
6 MEMBER ROBERTS: Yeah, I agree with the 7 try. I think we need to find out what Dave can 8 compile from those of us who probably have different 9 views on this and see how coherent it is before 10 committing to November or even December. So I'm okay 11 with trying.
12 CHAIR BALLINGER: Okay. Vesna?
13 MEMBER DIMITRIJEVIC: I think that this is 14 -- I mean, a good idea to see what can come from the, 15 you know, from Dave compiling the others' opinions.
16 There is no -- I don't know. I mean, you know, in the 17 general, I'm not for writing letters which don't say 18 too much. I mean, that's it.
19 CHAIR BALLINGER: Well, this letter would 20 say quite a bit actually.
21 MEMBER DIMITRIJEVIC: All right. Okay.
22 Well in that case, you may need the more time. So, I 23 mean, you know.
24 CHAIR BALLINGER: Have I missed anybody?
25 MEMBER MARCH-LEUBA: Yeah, in my opinion, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
113 1 let's go for a letter. Too constrained, December is 2 busy so let's try to finish in November.
3 CHAIR BALLINGER: Yeah, okay.
4 MEMBER MARCH-LEUBA: Let's try to figure 5 out what we want to say in the letter before we write 6 the letter. We always end up having a 120 page 7 compendium of irrelevant stuff.
8 CHAIR BALLINGER: Until we get the input 9 that Dave will assemble, we really won't know. I 10 mean, I have some general ideas, but I don't know.
11 MEMBER MARCH-LEUBA: To write a useful 12 letter, you need to know what You're saying before you 13 start to put in --
14 CHAIR BALLINGER: I suspect that we'll 15 know before the full committee meeting at least in 16 general. But it might change during the full 17 committee discussion.
18 We're rapidly approaching beating a dead 19 horse stage. Any other comments from folks? And I'll 20 talk with Dave during the week, I suppose, at his 21 convenience.
22 Okay. I think I understand what we're 23 doing, and everybody seems to more or less agree. If 24 I wait five minutes, we'll have a different vote. So 25 let's not wait five minutes. So I think we are done NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
114 1 for the day unless there are other comments that we 2 need to address.
3 Hearing none, I knew this was going to be 4 an interesting discussion. Thank you very much. And 5 we will, I guess, see you actually in November in 6 person, right?
7 MEMBER REMPE: We hope so.
8 CHAIR BALLINGER: Yeah, we hope so. We 9 hope so.
10 MEMBER REMPE: Thanks, Ron.
11 CHAIR BALLINGER: Thanks.
12 MEMBER REMPE: Thanks to the staff for 13 their presentations.
14 CHAIR BALLINGER: Yeah, yeah, thanks for 15 the staff. Okay. We're done. We are adjourned.
16 (Whereupon, the above-entitled matter went 17 off the record at 3:47 p.m.)
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Regulatory Basis on Increased Enrichment of Conventional and Accident Tolerant Fuel Designs for Light-Water Reactors October 18, 2023 OPEN SLIDES
Opening Remarks Scott Krepel Branch Chief Division of Safety Systems
Overview of Increased Enrichment Rulemaking Philip Benavides Project Manager Reactor Rulemaking & Project Management Branch
Issue Identification
- Regulatory Issue:
- Current licensing framework allows for the use of > 5 weight percent uranium-235; however, technology developments may require numerous exemptions to utilize fuel enriched above 5 weight percent uranium-235.
- Proposed Solution:
- Rulemaking would provide for a generically applicable standard informed by public input, providing consistent and transparent communication, rather than individual licensing requests as discussed in SECY-21-0109, Rulemaking Plan on Use of Increased Enrichment of Conventional and Accident Tolerant Fuel Designs for Light-Water Reactors.
- Commission Rulemaking Plan Approval:
- Staff request to the Commission to pursue rulemaking and develop a regulatory basis was approved by the Commission via SRM-SECY-21-0109.
SRM-SECY-21-0109 Overview
- SRM-SECY-21-0109 issued on 3/16/22, in response to SECY-21-0109.
- The Commission has approved the staffs proposal to initiate a rulemaking to amend requirements for the use of light water reactor fuel containing uranium enriched to greater than 5.0 weight percent uranium-235.
- Fuel Fragmentation, Relocation, and Dispersal (FFRD) should be appropriately addressed.
- Staff should take a risk-informed approach.
Status of Rulemaking Activity
- The NRC staff issued a regulatory basis on September 8, 2023
- Discusses regulatory issues and alternatives to resolve them
- Considers legal, policy, and technical issues
- Considers costs and benefits of each alternative
- Identifies the NRC staff's recommended alternative for most regulatory issues
- FFRD: Alternatives offered with no recommendation at this time
- Stakeholder Involvement:
- Public Meeting scheduled for October 25, 2023
- Comment Period until November 22, 2023
- Proposed rule due to the Commission: December 2024
Regulatory Basis Topics
- The regulatory basis describes the evaluated technical topics:
- Control Room Requirements (10 CFR 50.67 and GDC-19)
- Criticality Accident Requirements (10 CFR 50.68)
- Uranium Fuel Cycle Environmental Data - Table S-3 (10 CFR 51.51)
- Environmental Effects of Transportation of Fuel and Waste - Table S-4 (10 CFR 51.52)
- General Requirements for Fissile Material Packages (10 CFR 71.55)
- Fuel Fragmentation, Relocation, and Dispersal
Control Room Design Criterion of 10 CFR 50.67 and GDC-19 Elijah Dickson Radiation Protection and Consequence Branch NRR Increased Enrichment Regulatory Basis Topics
Control Room Design Criterion of 10 CFR 50.67 and GDC-19:
Summary of Regulatory Issue
- The history of fuel utilization for the current large light-water fleet has seen a gradual progression toward higher fuel discharge burnups and increased enrichments.
- In general, there has been enough margin in the facilities design bases to accommodate the criterion even for power uprates of up to 120 percent of the originally licensed steady-state thermal power level.
- The NRC recognizes the challenges that licensees face to retain margin for operational flexibilities within their licensing basis and the small amount of margin to the control room design criterion itself.
- The NRC does not want to unnecessarily penalize licensees for seeking increased enrichments that may then result in margin reductions and thereby requiring licensees to perform potentially extensive analyses to demonstrate compliance without a commensurate increase in safety.
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Control Room Design Criterion of 10 CFR 50.67 and GDC-19:
Background - 1/2
- Objective: ensure the design of the control room and its habitability systems provide for a habitable environment allowing the operators to remain in the control room and not evacuate during an emergency. Ideally, the environment should be a short-sleeved, comfortable environment for the control room operators. Such an environment was perceived to facilitate operator response to normal and accident conditions.
- History: developed in the 1970s and amended in the 1990s, the criterion did not foresee how licensees currently operate their facilities and manage their fuel, consider fuel enrichments above 5 weight percent U-235, or maintain coherence with other regulations concerning the Commission's comprehensive radiation protection framework.
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Control Room Design Criterion of 10 CFR 50.67 and GDC-19:
Background - 2/2
- Note: While the design criteria are computed in terms of dose, they are figures of merit used to characterize the minimum necessary design, fabrication, construction, testing, and performance of the requirements for SSCs that are important to safety. They do not represent actual occupational exposures received during normal and emergency conditions, which are primarily controlled by 10 CFR Part 20, Standards for Protection Against Radiation.
- Consider modifying the control design criteria to a higher, but still safe performance level; changes would not alter normal operational and emergency exposure limits controlled under 10 CFR Parts 20 and 10 CFR 50.47.
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Control Room Design Criterion of 10 CFR 50.67 and GDC-19:
Alternative 1
- No Action - Maintain the current regulatory framework
- Continue to revise existing guidance with updated source terms when data become available and update transport models on an ad hoc basis as research and resources become available.
- Plan to issue RG 1.183 Rev 2 in FY 2025.
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Control Room Design Criterion of 10 CFR 50.67 and GDC-19:
Alternative 2
- Pursue Rulemaking to Amend the Control Room Design Criteria and Update the Current Regulatory Guidance Accordingly with Revised Assumptions and Models and Continue to Maintain Appropriate and Prudent Safety Margins
- Assess and identify a range of acceptable values based on sound regulatory and scientific recommendations.
- Initiate new research and analyses for mechanistic transport models and re-baseline other several operational and human health assumptions
- Plan to issue RG 1.183 Rev 2 in support of the amended control room design criteria.
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Control Room Design Criterion of 10 CFR 50.67 and GDC-19:
Alternative 3
- Update the Current Regulatory Guidance with Revised Assumptions and Models and Continue to Maintain Appropriate and Prudent Safety Margins
- Initiate new research and analyses for mechanistic transport models and re-baseline other several operational and human health assumptions AND assess other mathematical methods, computational- and statistical approaches to reduce unnecessary conservatism and provide greater flexibility.
- Plan to commence work on RG 1.183 Rev 3 based on new research and analyses soon after RG 1.183 Rev 2 is issued.
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Control Room Design Criterion of 10 CFR 50.67 and GDC-19:
Recommended Alternative Staff recommends Alternative 2: Pursue rulemaking to amend the Control Room Design Criteria and update the current regulatory guidance accordingly with revised assumptions and models and continue to maintain appropriate and prudent safety margins 15
Questions Criticality Accident Requirements of 10 CFR 50.68 Charley Peabody Nuclear Systems Performance NRR Increased Enrichment Regulatory Basis Topics
Criticality Accident Requirements of 10 CFR 50.68: Summary of Regulatory Issue
- Final Rule issued in 1998
- Rule permits exemptions to 10 CFR 70.24 requirements
- Current rule limits application to enrichments of 5% weight Uranium-235
- Applicable at operating Part 50 and 52 licensees
- Utilizes k-effective acceptance criteria with required probability and confidence levels 18
10 CFR 50.68: Alternatives
- 1. No Action - New and Spent Fuel Criticality Safety is determined in accordance with 10 CFR 70.24 or an approved plant-specific exemption
- 2. Rulemaking - Increase Enrichment limit in 10 CFR 50.68(b)(7) to
< 20.0% wt U-235
- 3. Rulemaking - Remove Specific Enrichment Limit and replace with Tech Spec Design Feature Limits (recommended) 19
10 CFR 50.68: Recommended Alternative Staff Recommends Alternative 3: replacing the current enrichment limit with the Technical Specifications Design Feature limits.
- Maintains existing subcriticality margins at the same k-effective probability and confidence levels
- Criticality safety impacts are addressed during the fuel transition license amendment request process
- Allows consideration of low-enriched uranium up to <20.0% weight
- Research Study with Oak Ridge National Laboratory
- Preserves the § 50.68(b) compliance for all existing fleet without backfit 20
Questions Environmental Requirements of 10 CFR 51.51 & 51.52 Donald Palmrose Environmental Review New Reactors Branch NMSS Increased Enrichment Regulatory Basis Topics
Environmental Requirements of 10 CFR 51.51 & 51.52 Summary of Regulatory Issues
- The environmental data of Table S-3 (10 CFR 51.51(b)) and environmental impacts of Table S-4 (10 CFR 51.52(c)) are bounding for enrichments up to 5 wt % U-235.
- Currently no approved assessment of environmental impacts related to the uranium fuel cycle or transportation of fresh unirradiated fuel for increases greater than 5% U-235.
- NUREG-2266 is a draft report for comment that would support these tables to bound up to 8 wt % U-235
- Until further environmental evaluations are completed:
- For Table S-3, advanced reactor construction and operation licensing requests could involve use of up to 20% U-235 and require case-by-case reviews.
- For Table S-4, reactor licensing requests with shipments of fresh fuel with more than 5 wt % U-235, there would need to be a full description and detailed analysis of transportation impacts as directed by 10 CFR 51.52(b).
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10 CFR 51.51: Alternatives
- 1. No Action - Maintain current regulatory framework by assessing environmental impacts from the uranium fuel cycle on a case-by-case site-specific basis with Table S-3 data as bounding
- 2. Rulemaking - Pursue the necessary environmental analysis to justify continued use of Table S-3 for increased enrichment and then pursue rulemaking to modify Table S-3 (recommended)
- 3. Rely on Revised or Updated Environmental Analysis - Rely on the updated analysis when reviewing licensing actions for the use of increased enrichment fuels 24
10 CFR 51.52: Alternatives
- 1. No Action - Maintain current regulatory framework by assessing environmental impacts from transportation of fresh fuel enriched above 5% U-235 per 10 CFR 51.52(b) on a case-by-case site-specific basis.
- 2. Rulemaking - Pursue the necessary environmental analysis to justify continued use of Table S-4 for increased enrichment and then pursue rulemaking to modify Table S-4 (recommended)
- 3. Rely on Revised or Updated Environmental Analysis - Rely on the updated analysis when reviewing licensing actions for the use of increased enrichment fuels 25
Questions Packaging Requirements of 10 CFR 71.55 Jason Piotter Containment, Thermal, Chemical & Fire Protection Branch NMSS Increased Enrichment Regulatory Basis Topics
Packaging Requirements of 10 CFR 71.55:
Summary of Regulatory Issue Current Regulations
- § 71.55(b) applicants evaluate a single package, optimally moderated and reflected
- § 71.55(g) Provides an exception for package containing UF6
- § 71.55(g)(4) Specifies that enrichment cannot exceed 5 weight percent U-235 Regulatory History
- Proposed rule (§ 71.55(g)) issued 67 FR 21390, April 30, 2002, Final Rule issued 69 FR 3698, January 26, 2004
- Codified NRC longstanding practice to provide an exception to § 71.55(b)
External Issues related to enrichment limit of 5 weight percent
- ANSI N14.1, ISO 7195, and DOT limit enrichment in cylinders larger than 8 inches in diameter to 5 weight percent U-235
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10 CFR 71.55: Certificate of Compliance (CoC) Options Options for seeking approval by CoC
- Evaluate UF6 packages with optimum moderation
- current package design
- redesigned package
- Request an exemption to § 71.55(b)
- Request approval under § 71.55(c) for an exception to the optimum moderation requirement in § 71.55(b). (Requires special design feature and adm. controls.)
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10 CFR 71.55: Rulemaking Alternatives
- 1. No Action - Utilize Existing Certificate of Compliance Options
- 2. Rulemaking - Increase Enrichment limit to < 20.0% wt U-235
- 3. Rulemaking - Remove Enrichment Limit 30
10 CFR 71.55(g)(4): Recommended Alternative Staff Recommends Alternative 1: No Action
- To date, industry plans communicated to the NRC have not indicated that there would be enough requests for package approvals, for transporting UF6 enriched up to but less than 20.0 weight percent U-235, to conclude that rulemaking would be the most efficient or effective process to support package approvals.
- All alternatives are nearly cost neutral in terms of implementation;
- FRN Question
- Is there additional information that can be shared to augment comments made by the public in June 2022 regarding the need for rulemaking to support licensing new or existing UF6 transportation package designs?
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Questions Fuel Dispersal Joseph Messina Ashley Smith Nuclear Methods and Fuel Analysis NRR Increased Enrichment Regulatory Basis Topics
Fuel Fragmentation, Relocation, and Dispersal (FFRD)
- At HBU experiments have shown that the fuel can fragment during a LOCA
- Differences in pressure across the cladding can lead to cladding ballooning and burst
- The fragmented fuel can relocate axially into the balloon region of the fuel rod and if burst occurs, disperse into the RCS 34
FFRD: History 1974 - 1984-1995 2015 -
10 CFR - GI-92, SECY 50.46 Fuel 0148 - No 2024 - Fuel criteria Crumbling 2008 - imminent 2021 - Dispersal for During RIL- safety RIL-2021- PIRT to be LOCAs LOCA 0801 concern 13 conducted 1980 - 2006 - 2012 - 2016 - 2022 - SRM-FFRD FFRD NUREG- Draft SECY Discovered testing 2121 final rule 0109 -
showed for Include FFRD gross 50.46c in IE fuel loss Rulemaking at high BU 35
Fuel Dispersal: Background and Regulatory Issue
- The 50.46 acceptance criteria date to 1974 when FFRD were not known phenomena
- Acceptable approaches to demonstrate compliance with the regulations have ensured that catastrophic failure of the fuel rod structure and loss of fuel bundle configuration are precluded
- Fuel dispersal would be a departure of precedent
- Fuel dispersal is not explicitly addressed within the current regulations 36
Fuel Dispersal: Alternatives
- The NRC staff have developed 5 licensing pathways that could be pursued as a part of IE rulemaking
- Alternatives should be seen as mutually inclusive (i.e., combinations of elements from multiple alternatives could be considered)
- NRC staff may consider other approaches based on public comments 37
Fuel Dispersal Alternative 1
- No action
- No major updates to regulatory framework
- Apply existing regulations for treatment of dispersal
- Licensees could show that rods susceptible to fine fragmentation would not rupture to demonstrate compliance
- Consideration of significant fuel dispersal without any major regulatory updates challenges and regulatory uncertainty
- Licensing pathways considering significant dispersal are discussed as part of other alternatives 38
Fuel Dispersal Alternative 2
- 50.46a-style modification of ECCS requirements
- 50.46a was a draft final rule in 2010 that proposed to establish a transition break size (TBS), above which LOCAs can be analyzed with more realistic assumptions
- Best-estimate modeling and more realistic assumptions may help to demonstrate that no rods susceptible to dispersal would burst
- May impact Increased Enrichment rulemaking schedule 39
Fuel Dispersal Alternative 3
- Safety demonstration for post-FFRD consequences
- Criticality, coolability, dose, long-term cooling, etc. should be addressed like any other LOCA phenomena
- Guidance would be issued with the rule, which could be updated to include more specific guidance after more research is performed
- Current state-of-knowledge may lead to conservative guidance, but research could be performed in the long term to relax guidance
- May impact Increased Enrichment rulemaking schedule 40
Fuel Dispersal Alternative 4
- Generic bounding assessment of dose and use risk insights for post-FFRD consequences
- Dose criterion for LOCA with fuel dispersal would be established
- Licensees would demonstrate ability to predict a fuel dispersal source term or be directed to use a fraction of the MHA-LOCA source term based on the amount of predicted fuel dispersal.
- Downstream effects of dispersal could be treated as beyond design basis consequences and addressed with risk insights
- E.g., insights from operating experience and other regulatory requirements, programs, and industry initiatives
- May impact Increased Enrichment rulemaking schedule 41
Fuel Dispersal: Alternative 5
- Probabilistic fracture mechanics to show that leaks in large pipes will be identified before failure, precluding the need to analyze LBLOCAs
- E.g., leak-before-break and xLPR
- Derived from industry initiatives
- Licensees could use LBB to demonstrate that RCS leaks could be detected and operator action taken before a pipe breaks for a postulated LBLOCA, thus precluding a LBLOCA and fuel failure.
- May impact Increased Enrichment rulemaking schedule 42
Fuel Dispersal: Recommended Alternative Staff Has No Recommendation at this time
- The staff has determined that additional stakeholder input is required before finalizing a recommendation.
- 6 questions are posed to the public in the FRN regarding fuel dispersal to better understand stakeholder perspectives.
- The staff will review the stakeholder input on fuel dispersal to determine the path forward during the proposed rule.
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Fuel Dispersal: Alternatives
- Alternative 1: No action.
- Alternative 2: 50.46a-style modification of ECCS requirements.
- Alternative 3: Perform a safety demonstration for post-FFRD consequences.
- Alternative 4: Provide a generic bounding assessment of dose and use risk insights for post-FFRD consequences.
- Alternative 5: Use probabilistic fracture mechanics to show that leaks in large pipes will be identified before failure, precluding the need to analyze LBLOCAs.
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Questions Backup Slides FFRD: Dispersal Estimates
- 2014 NRC RES nominal calculations predicted up to 207 kg of fuel dispersed at current BUs Figure 7.3-11 from Report on Fuel Fragmentation, Relocation, and Dispersal, NEA/CSNI/R(2016)16, OECD Nuclear Energy Agency, October 2016.
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FFRD: Dispersal Estimates
- 2023 RES calculations estimated 0.6% to 3.5% of the fuel in the core is dispersed at HBUs Table II - Dispersal Estimates from NRC's Methodology to Estimate Fuel Dispersal during a Large Break Loss of Coolant Accident, A. Bielen, J.
Corson, and J. Staudemeier, NURETH, August 2023 (ML23116A214).
Core map showing burst and non-burst rods for the base case. Red and magenta indicate burst IFBA and non-IFBA rods, respectively; 48 blue and cyan indicate non-burst IFBA and non-IFBA rods, respectively
Fuel Dispersal: FRN Questions
- 1. Are there any other alternatives not described in Appendix F of the regulatory basis on FFRD that the NRC should consider? Are there elements of the alternatives presented or other alternatives that the NRC should consider? Please provide a basis for your response.
- 2. Stakeholders previously expressed concerns on the proposed § 50.46a rule when it was initially proposed in 2010. What concerns about § 50.46a (i.e., Alternative 2) exist in todays landscape? Please provide a basis for your response.
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Fuel Dispersal: FRN Questions
- 3. Under Alternative 2, as currently proposed in the regulatory basis, the staff would apply the regulatory precedent under which fuel dispersal that would challenge current regulatory requirements would not be permitted under loss-of-coolant accident (LOCA) conditions. Would the increased flexibilities gained from best-estimate assumptions and methods employed during large-break LOCA analyses make this alternative reasonable? Please provide a basis for your response.
- 4. What changes to plant operations, fuel designs, or safety analysis tools and methods would be necessary under each proposed alternative? Please provide a basis for your response.
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Fuel Dispersal: FRN Questions
- 5. Provide any information that would be relevant to more accurately estimate costs associated with each proposed alternative. Please provide a basis for your response.
- 6. What are the pros and cons of each alternative, including the degree to which each alternative is consistent with the principles of good regulation?
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