ML25069A697
| ML25069A697 | |
| Person / Time | |
|---|---|
| Issue date: | 04/30/2025 |
| From: | Barwell O NRC/OCFO |
| To: | Ewing J Westinghouse |
| Shared Package | |
| ML25069A699 | List: |
| References | |
| OCFO-25-00025 | |
| Download: ML25069A697 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Jerrod Ewing, Manager Operating Plants Licensing Westinghouse Electric Company LLC 1000 Westinghouse Drive, Bldg. 1 Cranberry Township, PA 16066
SUBJECT:
RESPONSE TO WESTINGHOUSES REQUEST FOR A FEE EXEMPTION FOR WCAP-16996-P/NP, REVISION 1, SUPPLEMENT 1, REVISION 0, EXTENSION OF FULL SPECTRUM' LOCA (FSLOCA') EVALUATION METHODOLOGY TO 2-LOOP WESTINGHOUSE PRESSURIZED WATER REACTORS WITH INFORMATION TO SATISFY LIMITATIONS AND CONDITIONS SPECIFIC TO 2-LOOP PLANT TYPES
Dear Jerrod Ewing:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your \
letter dated February 26, 2025 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML25057A397), requesting a fee exemption under Title 10 of the Code of Federal Regulations (10 CFR) 170.11(a)(1)(ii) related to the review and approval of proprietary and non-proprietary versions of Westinghouse Electric Company LLCs (Westinghouse) Topical Report WCAP-16996-P/NP, Revision 1, Supplement 1, Revision 0, Extension of FULL SPECTRUM' LOCA (FSLOCA') Evaluation Methodology to 2-loop Westinghouse Pressurized Water Reactors (PWRs) with Information to Satisfy Limitations and Conditions Specific to 2-loop Plant Types. Based on the NRCs staff review, I am granting your fee exemption request.
The NRC has established regulations for the granting of fee exemptions under 10CFR170.11, Exemptions. An interested person may apply for an exemption under 10CFR170.11 in accordance with 10 CFR 170.5, Communications.1 The NRC staff reviewed your request based on the regulations in 10 CFR 170.11(a)(1)(ii) and 10CFR170.11(d).
Section170.11(a)(1)(ii) states:
No application fees, license fees, renewal fees, inspection fees, or special project fees shall be required for: (1)A special project that is a request/report submitted to the NRC... (ii) When the NRC, at the time the request/report is submitted, plans to use the information to assist the NRC in generic regulatory improvements or efforts (e.g., rules, regulatory guides, regulations, policy statements, generic letters, or bulletins).
1 10 CFR 170.5 provides that All communications concerning the regulations in this part should be addressed to the NRCs Chief Financial Officer, either by mail to the U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; by hand delivery to the NRCs offices at 11555 Rockville Pike, Rockville, Maryland; or, where practicable, by electronic submission, for example, via Electronic Information Exchange, or CD-ROM.
April 30, 2025
J. Ewing Section 170.11(d) states:
All fee exemption requests must be submitted in writing to the Chief Financial Officer in accordance with § 170.5, and the Chief Financial Officer will grant or deny such requests in writing.
In your letter, you state that WCAP-16996-P/NP, Revision 1, Supplement 1, Revision 0, can be used in conjunction with the Electric Power Research Institutes (EPRI) submittal of Technical Report 3002028674, LOCA Analysis of Fuel Fragmentation, Relocation, and Dispersal for Westinghouse 2-Loop, 3-Loop, and 4-Loop Plants - Evaluation of Cladding Rupture in High Burnup Fuel Rods Susceptible to Fine Fragmentation (ADAMS Accession No. ML24121A210) which uses the information provided in WCAP-16996-P/NP, Revision 1, Supplement 1, Revision 0, to justify applicability of composite, bounding modeling approaches to generically demonstrate cladding rupture would likely not occur for small-break and intermediate-break loss of coolant accidents (LOCAs) for specific Westinghouse fuel and 2-loop reactor designs. Thus, Westinghouse stated that WCAP-16996-P/NP, Revision 1, Supplement 1, Revision 0, provides a methodology that qualifies the methods used to conservatively predict margin to rod rupture for 2-loop Westinghouse reactor designs, thereby supporting efforts to analyze and address fuel fragmentation, relocation, and dispersal (FFRD) as part of the overall strategy for licensing high burnup fuel.
In the Project Plan to Prepare the U.S. Nuclear Regulatory Commission for Efficient and Effective Licensing of Accident Tolerant Fuels, Version 1.2, dated September 2021 (ADAMS Accession No. ML21243A298), the NRC committed to enabling the safe use of new technologies, especially those that can make NRC-regulated facilities safer. The U.S. nuclear industry, assisted by the U.S. Department of Energy, plans to deploy batch loads of fuels with higher burnup levels in the operating fleet on an aggressive timeline. To ensure that the NRC was ready to review the batch loads of higher burnup fuels, as well as other options (near-term technologies, coated cladding, doped pellets, iron-chromium-aluminum cladding and increased enrichment), the NRC staff evaluated the regulatory framework and determined the framework is capable of reviewing higher burnup fuels without changes to the current regulations and guidance through the use of existing processes. However, the NRC staff continues to assess the need to update guidance to support the efficient reviews of such applications.
Additionally, the NRC is currently undertaking a rulemaking to facilitate the use of light-water reactor (LWR) fuel containing uranium enriched to greater than 5.0 and less than 20.0 weight percent uranium-235 (U-235) (referred to as the Increased Enrichment Rulemaking). On March 16, 2022, the Commission approved the staffs plan to initiate this rulemaking and directed that the regulatory basis for this rulemaking appropriately address and analyze FFRD issues relevant to fuels of higher enrichment and burnup levels (ADAMS Accession No. ML22075A103). Consistent with that direction, the NRC staff published Increased Enrichment of Conventional and Accident Tolerant Fuel Designs for Light-Water Reactors, RIN Number:
3150-AK79, NRC Docket ID: NRC-2020-0034, Regulatory Basis Document for Public Comment dated September 2023 (ADAMS Accession No. ML23032A504). The regulatory basis assesses five possible alternatives to address FFRD issues, and it consider the impact of each possible alternative.
The NRC staff plans to use the information in WCAP-16996-P/NP, Revision 1, Supplement 1, Revision 0, to assist the NRCs efforts to address FFRD issues relevant to fuels of higher enrichment and burnup levels as part of the Increased Enrichment Rulemaking. EPRI Report 3002028673, Loss-of-Coolant-Accident-Induced Fuel Fragmentation, Relocation and Dispersal with Leak-Before-Break Credit: Alternative Licensing Strategy (ADAMS Accession No.
J. Ewing ML24121A207), which is based, in part, on applicability to 2-loop Westinghouse plants as justified by WCAP-16996-P/NP, Revision 1, Supplement 1, presents a similar approach to Alternative 5 for FFRD issues in the regulatory basis document. Therefore, review and potential approval of WCAP-16996-P/NP, Revision 1, Supplement 1, Revision 0, will assist the NRC staff in considering Alternative 5 as the rulemaking progresses. Further, these TRs could form part of the regulatory framework supporting implementation of a version of Alternative 5.
Additionally, as noted in the regulatory basis, LOCA analyses to date have not accounted for the new phenomenology associated with fuel dispersal. While the analytical approach in WCAP-16996-P/NP, Revision 1, Supplement 1, Revision 0, is specific to Westinghouse reactor designs, review and potential approval of this topical report will assist the NRC staff in analyzing the likelihood for potential for cladding rupture during a LOCA and what, if any, changes are needed to address such a likelihood in developing the Increased Enrichment Rulemaking and associated guidance documents. As such, WCAP-16996-P/NP, Revision 1, Supplement 1, Revision 0, in conjunction with EPRI Reports 3002028673 and 3002028674, constitutes part of the proof of concept demonstration for a successful licensing pathway to high burnup fuel, which will assist the NRC staff in addressing Commission direction to address and analyze FFRD for high enrichment or high burnup fuel as part of the Increased Enrichment Rulemaking.
The NRC staff reviewed Westinghouses fee exemption request and concluded that the request for fees related to the review and approval topical report WCAP-16996-P/NP, Revision 1, Supplement 1, Revision 0, meets the criteria for a fee exemption under 10 CFR 170.11(a)(1)(ii) because the guidance will assist the NRC in generic regulatory improvement efforts to address direction from the Commission to address FFRD as part of a rulemaking effort to facilitate efficient licensing of high burnup fuel.
If you have any questions regarding this determination, please contact Ekaterina Lenning at 301-415-3151. Please contact Billy Blaney, of my staff, at 301-415-5092 for any fee-related questions.
Sincerely, Owen F. Barwell Chief Financial Officer Signed by Barwell, Owen on 04/30/25
J. Ewing
SUBJECT:
RESPONSE TO WESTINGHOUSES REQUEST FOR A FEE EXEMPTION FOR WCAP-16996-P/NP, REVISION 1, SUPPLEMENT 1, REVISION 0, EXTENSION OF FULL SPECTRUM' LOCA (FSLOCA') EVALUATION METHODOLOGY TO 2-LOOP WESTINGHOUSE PRESSURIZED WATER REACTORS WITH INFORMATION TO SATISFY LIMITATIONS AND CONDITIONS SPECIFIC TO 2-LOOP PLANT TYPES, DATED: APRIL 30, 2025 DISTRIBUTION: OCFO-25-00025 NAridi, OCFO MVelasquez, OCFO ELenning, NRR GGeorge, NRR RidsNRROd Resource EXTERNAL DISTRIBUTION:
jerrod.ewing@westinghouse.com ADAMS Accession Number: ML25069A699 Package; ML25069A697 Letter OFFICE OCFO/DOB OCFO/DOB NRR/DORL NRR/DSS NAME BBlaney CGalster Notto SKrepel DATE 03/12/2025 03/12/2025 03/13/2025 03/12/2025 OFFICE NRR/DORL NRR/DSS OGC OCFO/DOC NAME ARivera-Varona VCusumano GMostaghimi*NLO RRevinzon DATE 03/18/2025 03/23/2025 04/09/2025 04/10/2025 OFFICE OCFO/DOC OCFO/DOB OCFO/DOB OCFO/DOB NAME MBlair JAreas LYee MNeville DATE 04/10/2025 04/21/2025 04/21/2025 04/21/2025 OFFICE DCFO CFO NAME CCarroll OBarwell DATE 04/24/2025 04/30/2025 OFFICIAL RECORD COPY