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Power Uprate September 5, 2024 Public Meeting Slides
	ML24249A115
Person / Time
Site:	Nuclear Energy Institute
Issue date:	09/05/2024
From:	Csontos A, Pimentel F; Nuclear Energy Institute
To:	Michael Mahoney; NRC/NRR/DORL/LPL4
References
	Download: ML24249A115 (12)
	v • d • e

Engineering & Risk, NEI September 5, 2024 Public Meeting to Discuss Power Uprate Reviews

ADVANCE Act - Opportunities to Enable Change Key Provisions:

American Nuclear Leadership Developing and Deploying New Nuclear Technologies Preserving Existing Nuclear Energy Generation Nuclear Fuel Cycle, Supply Chain, Infrastructure, and Workforce Improving Commission Efficiency Aligned with intent of recent NRC Activities:

Reactor Accident Analysis Modernization (RAAM) Project SECY-21-0109: Increased Enrichment Rulemaking SRM-SECY-16-0033: Commission SRM (RI and combine 50.46a/c)

Accident Tolerant Fuel and Power Uprate Project Plan/Charter

©2024 Nuclear Energy Institute 3 Industry seeking to increase regulatory stability for sequential and/or combined LAR submittals Flexibility for sequential, concurrent reviews is afforded to industry through the LIC-109, Acceptance Review Procedures, R2 and LIC-500, Topical Report Process Early communications through pre-application meetings could address the intent of the LIC-109/500 exception process and reduce unnecessary regulatory burden:

Allow combined, sequential LARs for uprates with linked licensing actions:

Detail where reviews can be performed in parallel

Industry examples to be provided today and in a white paper Allow LARs that references unapproved topical reports:

Risk can be minimized by allowing the submittal of LAR after the previous submittal draft SE is issued Allow LAR submittals that depend on the approval of an LAR still under review if requested by the applicant Updating Power Uprate Guidance (LIC-109/500)

22 18 MUR 9

Total Review Time 53 50 Total Calendar Time 76 62

Combined License Applications 100 100 Core Thermal Power (%)

Core Flow (%)

Original Operating Domain 120 EPU ICF

Combined License Applications Increased operational flexibility

Improved flow window

Enables to achieve and maintain EPU power

Less complicated fuel and core design

Less complicated cycle management

Less complicated plant operation

Less HU error opportunities

Less OOS needs @ BOP

Less MCR resource requirement Fewer Control Rod Maneuvers Improved reactivity management ->

improved safety Fewer fuel conditioning flow ramps -

> Improved fuel reliability Reduced Operator Burden ->

improved safety Fewer load drops Higher capacity factor improved equipment reliability Less potential for FM to become dislodged and damage fuel Improved Fuel Cycle Economics Less complicated core design Less complicated cycle management Improved fuel utilization MELLLA+ supports operation at EPU power levels in safe, effective, & efficient manner

Combined License Applications Combined Applications MELLLA+ supports operation at EPU power levels in a safe, effective, and efficient manner Synergy in analytical scope Bundling these LARs into one submittal reduces review time, implementation risk, and operational risk Use of NRC approved methods (including methods in review)

Require IE and HBU to achieve PU (PWRs)

Require IE and HBU to achieve 24m cycles (PWRs)

Benefit from ATF implementation for IE and HBU transition (BWRs and PWRs)

Benefit from ATF implementation for PU (PWRs)

Combined License Applications Power Uprate & Fuel Transition - Combined Applications

AOOs

LOCA

Stability (BWR)

SG tube rupture (PWR)

Locked rotor (PWR)

RIA

ATWS

Dose

Decay Heat

Fire Protection

Station blackout

etc Chapter 4 Chapter 6 Fuel Transition Combined License Applications Chapter 15 Analysis

AOOs

LOCA

Stability (BWR)

SG tube rupture (PWR)

Locked rotor (PWR)

RIA

ATWS

Dose

Decay Heat

Fire Protection

Station blackout

etc Chapter 4 Chapter 6 Power Uprate & Fuel Transition - Analytical Synergy

LIC-100 addresses Obligations as legally binding requirements imposed through applicable rules, regulations, orders and licenses, to be reserved for matters that satisfy the criteria of 10 CFR 50.36 or are otherwise found to be of high safety or regulatory significance.

o Future analyses may need to account for HBU/IE, but current methodologies are not necessarily approved for use for these conditions. (e.g., Spent Fuel Pool Criticality) o Use of License Conditions would restrict implementation of methodologies or analyses until a time when the conditions exist to allow their application.

o Potential for more timely reviews of licensing submittals containing HBU/IE content while maintaining control over when the licensee can implement Improving Efficiency through Conditioning

Core average burnup (end of cycle) increased from 40 to 47 GWD/MTU o

EQ update for sump fluid using AST resulted in a 700% 1-year integrated dose increase vs ~10%

dose increase using TID o

Additional cost of using AST for EQ is estimated to exceed $10M per site due to component replacement and relocation While AST for EQ is specifically noted in the draft of Reg Guide 1.183, Rev. 2 (via referral to Reg Guide 1.89, Rev. 2), results above would lead licensee to elect not to transition to AST from TID o

Utilizing TID source term for EQ is justified from a regulatory and technical position; related submittals would be made using TID o

Each submittal would have to include an individual justification for using TID source term o

These individual justifications would result in increased time to prepare and review submittals Other issues: EQ and Implementing HBU Mandatory application of AST for EQ would impact the decision to pursue HBU/IE

ML24249A115

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