ML21341A003

NRC Staff Presentation for December 7, 2021 Public Meeting to Discuss the Accident Tolerant Fuels Project Plan Comment Responses

ML21341A003
Person / Time
Issue date:	12/07/2021
From:	Office of Nuclear Reactor Regulation
To:
Wentzel M
References
Download: ML21341A003 (18)

Text

Public Meeting to Discuss Comment Responses on Draft ATF Project Plan December 7, 2021 10:00 am - 11:00 am

Introductions and Meeting Logistics Welcome

• Participants will be on mute until the presentation is complete.

• Bo Pham - Director, Division of Operating

• The NRC will call on those with Reactor Licensing their hands up one at a time to

• Joe Donoghue - Director, provide feedback.

Division of Safety Systems

• Todays meeting is an Observation meeting. The public will have an Presenter opportunity to participate prior to

• Michael Wentzel - Lead the end of the meeting.

ATF Project Manager

• No regulatory decisions will be made at todays meeting.

• To be included in the attendance list: accident_tolerant_fuel@nrc.gov 2

Purpose

• To discuss the NRC staff responses to comments received on the draft ATF Project Plan.

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ATF Project Plan, Version 1.2

• Designed to:

- Describe staffs strategy to ensure readiness for ATF, higher burnup, and increased enrichment licensing actions

- Increase regulatory stability and certainty

- Enhance and optimize NRC review

• Version 1.2 Timeline

- Update started in early 2021

- Draft Version 1.2 issued July 8, 2021

- Public meeting to discuss draft on July 22, 2021

- NEI comment letter submitted August 5, 2021

- Final Version 1.2 issued September 30, 2021 4

Changes Between Draft and Final

• Editorial changes to enhance clarity

• Changes to address comments received

• Additional streamlining to improve focus

• Regulatory Framework Applicability Analysis (Appendix A) and the Licensing Pathway Diagrams (Appendix B) separated from the plan 5

Comments on the Draft

• 41 unique comments received

- 2 from July 22 public meeting (ML21208A152)

- 39 included in August 5 letter (ML21221A130)

• NRC staff responses issued on November 19, 2021 (ML21314A531).

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Industry Comments 7

General Comments and Responses

• Comment: NRC should thoroughly review and incorporate industry comments into this revision.

• Staff response: The NRC staff has fully considered the industrys comments and has made updates throughout the ATF Project Plan, as appropriate.

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General Comments and Responses (contd)

• Comment: NRC should prioritize efforts to generically evaluate environmental impacts

• Staff response: The NRC staff is developing a plan to perform a bounding analysis of the environmental impacts associated with the deployment of ATF technologies, the details of which will be made available to the public, once finalized.

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General Comments and Responses (contd)

• Comment: The Project Plan should be more responsive to the use of riskinformed applications.

• Staff response: The ATF Project Plan was revised to make clear that the NRC staff will continue to take a riskinformed approach to nuclear fuel licensing; however, the Project Plan is not intended to convey guidance on how to pursue riskinformed licensing of ATFconcept, higher burnup, and increased enrichment fuels. The NRC staff continues to encourage vendors and licensees considering a risk informed approach to engage early with the staff to identify and resolve the relevant technical and policy issues.

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General Comments and Responses (contd)

• Comment: NRC should clarify its inclusion of doped pellets within Appendix A.

• Staff response: The NRC staff revised the Regulatory Framework Applicability Analysis table to clarify the inclusion of doped pellets, as appropriate. Although the NRC has previously licensed fuel with doped pellets, it is possible that the agency's current regulatory framework (i.e., guidance documents) may not be fully applicable to all future doped pellet concepts; therefore, the information in the doped pellets column will be retained.

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General Comments and Responses (contd)

• Comment: NRC should clearly indicate that the Project Plan is not regulatory guidance

• Staff response: The NRC staff agrees that the ATF Project Plan is not intended to convey regulatory requirements or guidance. The NRC staff clarified that the ATF Project Plan and the Regulatory Framework Applicability Analysis table should not be interpreted as new regulatory requirements or guidance.

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Next Steps 13

Next Steps

• Finalize Regulatory Framework Applicability Analysis and Licensing Pathway diagrams.

• Develop schedulerelated communication to industry to help prioritize agency resources.

• Continue to look for opportunities to engage stakeholders.

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Planning Information Needed Hypothetical Licensing Timeline*

2022 2023 2024 2025 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Topical Report License Amendment Request(s)

• Nominal review times used for illustration purposes only.

• Licensing timeframes are dependent on vendor approach and plantspecific licensing bases.

• Staff would benefit from additional planning information to ensure that resources are focused appropriately. E.g.:

- Number of licensees by fuel concept

- Estimated submittal dates

NRC/Industry Discussion 16 16

Public Questions 17

For further information, please visit https://www.nrc.gov/reactors/atf.html 18