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{{#Wiki_filter:ATF Project Plan V1.1                                                                                                           October 2019 Stakeholder Comment Disposition Table Comment   Location   Comment                           Proposed         NRC Notes                     Action/Resolution
{{#Wiki_filter:ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Attachment Comment Location Comment Proposed Change NRC Notes Action/Resolution 1
#                                                      Change 1        General   The timelines, activities, and   Please consider   The impacts of high burnup     Various portions of text within the impacts associated with          partitioning the  and increased enrichment       entire HBU+IE project plan were increasing burnup and            various sections  are different (i.e., different revised to clearly indicate which of enrichment are different.        into burnup and  technical concerns), and the   the two technologies (burnup or The appendix sometimes            enrichment        schedules slightly different, enrichment) are being discussed in discusses both topics and        portions of the  but the activities for         those instances where both were other times is only referring    appendix to      addressing the impacts are     not being addressed.
General The timelines, activities, and impacts associated with increasing burnup and enrichment are different.
to one of the two, however,      more clearly      largely, if not entirely, the it is not perfectly clear at all  identify the      same because of leveraging times.                            information      resources to perform high relevant to each  burnup and enrichment tasks topic.            in parallel with ATF. Those areas where there are differences in schedule or activity are delineated in the various tables present in the project plan. And the differences in the technical issues are discussed in the opening paragraphs in each section. Therefore, the decision was made not to partition the project plan.
The appendix sometimes discusses both topics and other times is only referring to one of the two, however, it is not perfectly clear at all times.
Please consider partitioning the various sections into burnup and enrichment portions of the appendix to more clearly identify the information relevant to each topic.
The impacts of high burnup and increased enrichment are different (i.e., different technical concerns), and the schedules slightly different, but the activities for addressing the impacts are largely, if not entirely, the same because of leveraging resources to perform high burnup and enrichment tasks in parallel with ATF. Those areas where there are differences in schedule or activity are delineated in the various tables present in the project plan. And the differences in the technical issues are discussed in the opening paragraphs in each section. Therefore, the decision was made not to partition the project plan.
However, many areas of the project plan were updated with revised wording to clearly indicate, when appropriate, which of the two technologies is being discussed.
However, many areas of the project plan were updated with revised wording to clearly indicate, when appropriate, which of the two technologies is being discussed.
2         General   In numerous places it             Please revise     Agree.                         Revised to identify UF6 or other references UF6 as the only        the text to be                                  potential precursor forms that are enriched product used to          more generic as                                  enriched above the current limit (5 fabricate UO2.                    there are                                        weight percent U-235).
Various portions of text within the entire HBU+IE project plan were revised to clearly indicate which of the two technologies (burnup or enrichment) are being discussed in those instances where both were not being addressed.
possibilities to use other precursor forms that are not UF6.
2 General In numerous places it references UF6 as the only enriched product used to fabricate UO2.
Attachment
Please revise the text to be more generic as there are possibilities to use other precursor forms that are not UF6.
Agree.
Revised to identify UF6 or other potential precursor forms that are enriched above the current limit (5 weight percent U-235).  


ATF Project Plan V1.1                                                                                                       October 2019 Stakeholder Comment Disposition Table Comment   Location   Comment                         Proposed           NRC Notes                   Action/Resolution
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 2
#                                                    Change 3        General   The draft appendix             Please add text    5% weight enrichment is      Approach outlined in the project discusses changes to the       to indicate that  generally understood to be  plan does not change depending on standard pellet/clad fuel     this appendix is  the amount of the uranium-  the fuel type. No changes made.
Comment Location Comment Proposed Change NRC Notes Action/Resolution 3
system. In a fuel system       only applicable    235 isotope present relative where uranium is the           for current UO2    to the amount of all other minority component, a           fuel or clarify    uranium isotopes.
General The draft appendix discusses changes to the standard pellet/clad fuel system. In a fuel system where uranium is the minority component, a uranium enrichment could be above 5% while the ratio of U235 to all atoms by volume may not be above 5%. Therefore the effective enrichment would be less than 5% despite the ratio of U235 atoms to U atoms being above 5%.
uranium enrichment could       how to treat all be above 5% while the ratio     fuel types.
Please add text to indicate that this appendix is only applicable for current UO2 fuel or clarify how to treat all fuel types.
of U235 to all atoms by volume may not be above 5%. Therefore the effective enrichment would be less than 5% despite the ratio of U235 atoms to U atoms being above 5%.
5% weight enrichment is generally understood to be the amount of the uranium-235 isotope present relative to the amount of all other uranium isotopes.
4         General   The appendix to the NRC         Please revise      Discussed during public      ATF project plan document to be Project Plan is prepared as     the burnup and    meeting, the HBU+IE project  updated with modified appendix Appendix A, however the         enrichment        plan will appear as Appendix lettering NRC Project Plan Version       appendix or the    A in the ATF project plan.
Approach outlined in the project plan does not change depending on the fuel type. No changes made.
1.0 (ML18261A414) already       current project    The existing Appendix A in contains an Appendix A         plan appendix to  the ATF project plan will NRC Plans to Develop           be a different    become Appendix B.
4 General The appendix to the NRC Project Plan is prepared as Appendix A, however the NRC Project Plan Version 1.0 (ML18261A414) already contains an Appendix A NRC Plans to Develop Analysis Capability. Having two appendices with the same letter creates an error likely situation.
Analysis Capability. Having   letter.
Please revise the burnup and enrichment appendix or the current project plan appendix to be a different letter.
two appendices with the same letter creates an error likely situation.
Discussed during public meeting, the HBU+IE project plan will appear as Appendix A in the ATF project plan.
5         General   Where is table A.5? The         Please revise     Tables A.1 through A.6 now   Text revised for consistency appendix appears to skip        text for          labeled consistently this table.                    consistency.
The existing Appendix A in the ATF project plan will become Appendix B.
2
ATF project plan document to be updated with modified appendix lettering 5
General Where is table A.5? The appendix appears to skip this table.
Please revise text for consistency.
Tables A.1 through A.6 now labeled consistently Text revised for consistency  


ATF Project Plan V1.1                                                                                                         October 2019 Stakeholder Comment Disposition Table Comment   Location   Comment                         Proposed         NRC Notes                     Action/Resolution
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 3
#                                                    Change 6        General,   The text indicates NRC staff     Please explain    Within the scope of the In-    Additional discussion within Section Line 25,  will participate in a           NRC's intentions  Reactor performance, a HBU    A.1.4 has been provided to clarify Lines      coordinated PIRT on in         regarding a      PIRT is not being developed    the In-Reactor intent of an IE PIRT 228292    reactor performance of fuels     PIRT for          (but a literature search is    and a HBU literature search.
Comment Location Comment Proposed Change NRC Notes Action/Resolution 6
with increased enrichment.       increased        being performed). An IE        Delineation is also made between Please provide more             burnup and        PIRT is being developed.      HBU for conventional fuel designs information on the timing,       enrichment        Clarified the scope of Section and ATF designs. Clarified the scope, and intent of this       efforts.          A.2.2.2 to include uranium    scope of Section A.2.2.2 to include activity. Additional                               feed material and              uranium feed material and information such as the                           unirradiated fuel. Revised to  unirradiated fuel. Revised to information presented                             eliminate references to        eliminate references to higher during the Public Meeting on                       higher burnup and clarified    burnup and clarified the scope of September 12th would be                           the scope of the PIRTs will    the PIRTs will include criticality helpful.                                           include criticality safety and safety and materials The text indicates that the                       materials                      properties/performance.
General, Line 25, Lines 228292 The text indicates NRC staff will participate in a coordinated PIRT on in reactor performance of fuels with increased enrichment.
PIRT would only be for                             properties/performance.
Please provide more information on the timing, scope, and intent of this activity. Additional information such as the information presented during the Public Meeting on September 12th would be helpful.
increased enrichment. Is burnup excluded intentionally? Would these activities be NRR focused or more crosscutting across multiple parts of NRC?
The text indicates that the PIRT would only be for increased enrichment. Is burnup excluded intentionally? Would these activities be NRR focused or more crosscutting across multiple parts of NRC?
The text indicates NRC staff will participate in a PIRT for transportation packages for unirradiated fuel transportation for material with higher burnup and enrichment. Please provide more information on the timing, scope, and intent of this activity.
The text indicates NRC staff will participate in a PIRT for transportation packages for unirradiated fuel transportation for material with higher burnup and enrichment. Please provide more information on the timing, scope, and intent of this activity.
Please explain higher burnup unirradiated material.
Please explain higher burnup unirradiated material.
3
Please explain NRC's intentions regarding a PIRT for increased burnup and enrichment efforts.
Within the scope of the In-Reactor performance, a HBU PIRT is not being developed (but a literature search is being performed). An IE PIRT is being developed.
Clarified the scope of Section A.2.2.2 to include uranium feed material and unirradiated fuel. Revised to eliminate references to higher burnup and clarified the scope of the PIRTs will include criticality safety and materials properties/performance.
Additional discussion within Section A.1.4 has been provided to clarify the In-Reactor intent of an IE PIRT and a HBU literature search.
Delineation is also made between HBU for conventional fuel designs and ATF designs. Clarified the scope of Section A.2.2.2 to include uranium feed material and unirradiated fuel. Revised to eliminate references to higher burnup and clarified the scope of the PIRTs will include criticality safety and materials properties/performance.


ATF Project Plan V1.1                                                                                                             October 2019 Stakeholder Comment Disposition Table Comment   Location   Comment                         Proposed             NRC Notes                       Action/Resolution
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 4
#                                                    Change 7        Line 24   Please spell out PIRT as         Please revise        PIRT spelled out                Text revised as indicated.
Comment Location Comment Proposed Change NRC Notes Action/Resolution 7
this is the first occurrence     text as indicated (Phenomena Identification &
Line 24 Please spell out PIRT as this is the first occurrence (Phenomena Identification &
Ranking Table) 8         Lines 46 The Appendix states that         Please ensure        The latter is not contradictory No changes needed.
Ranking Table)
50        the staff does not anticipate   text is consistent  in that a gap in the identification of gaps or       with intent.        regulations for Parts 71 or 72 deficiencies in these                                 would not provide the staff regulations with respect to                         with a regulatory tool for Part 71 and 72. However,                             review and approval of a lines 243 244 discuss new                           proposed transport package transportation packages,                             or storage cask design. If modification of current                               holders of a transport packages, or exemptions                               package certificate of from 10 CFR 71.55(g),                                 compliance for UF6 are able especially subpart (g)(4) and                         to demonstrate that the its limit of 5.0 w/o.                                 package is subcritical with The latter statements                                optimum moderation, then an appear to be contradictory                            exemption is not needed, with respect to gaps in Part                          and the package design will
Please revise text as indicated PIRT spelled out Text revised as indicated.
: 71.                                                  meet Part 71 in its entirety.
8 Lines 46 50 The Appendix states that the staff does not anticipate identification of gaps or deficiencies in these regulations with respect to Part 71 and 72. However, lines 243 244 discuss new transportation packages, modification of current packages, or exemptions from 10 CFR 71.55(g),
4
especially subpart (g)(4) and its limit of 5.0 w/o.
The latter statements appear to be contradictory with respect to gaps in Part
: 71.
Please ensure text is consistent with intent.
The latter is not contradictory in that a gap in the regulations for Parts 71 or 72 would not provide the staff with a regulatory tool for review and approval of a proposed transport package or storage cask design. If holders of a transport package certificate of compliance for UF6 are able to demonstrate that the package is subcritical with optimum moderation, then an exemption is not needed, and the package design will meet Part 71 in its entirety.
No changes needed.


ATF Project Plan V1.1                                                                                                         October 2019 Stakeholder Comment Disposition Table Comment   Location   Comment                         Proposed           NRC Notes                     Action/Resolution
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 5
#                                                    Change 9        Lines     While updating the               Please revise      The intent of the word        Text revised to meet original intent.
Comment Location Comment Proposed Change NRC Notes Action/Resolution 9
112113    regulatory framework is         text to remove      "generic" was to attempt to important to ensure             indication that    capture the standard, regulatory certainty, why       regulatory          predictable licensing process would such changes that         framework          used for widespread could include rulemaking,       changes are        adoption of methods and need to be made before           anticipated to be  technology. Clarification has either higher enrichments or     complete before    been provided to indicate the burnups can be licensed?         licensing can be    NRC staff anticipates This text appears to indicate   approved.          regulatory changes will be that the common regulatory                           needed before a predictable practice of using exemptions                         licensing approach outside first would not be                                  the use of exemptions can be acceptable. Additionally, it is                     implemented.
Lines 112113 While updating the regulatory framework is important to ensure regulatory certainty, why would such changes that could include rulemaking, need to be made before either higher enrichments or burnups can be licensed?
inconsistent with the exemption pathway discussed in lines 180182 and the discussion in lines 227230.
This text appears to indicate that the common regulatory practice of using exemptions first would not be acceptable. Additionally, it is inconsistent with the exemption pathway discussed in lines 180182 and the discussion in lines 227230.
5
Please revise text to remove indication that regulatory framework changes are anticipated to be complete before licensing can be approved.
The intent of the word "generic" was to attempt to capture the standard, predictable licensing process used for widespread adoption of methods and technology. Clarification has been provided to indicate the NRC staff anticipates regulatory changes will be needed before a predictable licensing approach outside the use of exemptions can be implemented.
Text revised to meet original intent.


ATF Project Plan V1.1                                                                                                     October 2019 Stakeholder Comment Disposition Table Comment   Location   Comment                       Proposed           NRC Notes                   Action/Resolution
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 6
#                                                  Change 10       Lines     Two sentences appear to be     Please revise      Two sentences are indeed    Text revised to meet original intent 118123    intermixed and need to be     text.              intermixed. The paragraph corrected. We believe the                          was revised by moving the sentences are supposed to                         intermixed sentence to the read as follows:                                   beginning of the paragraph, While higher burnups and                           which was its originally increased enrichments may                         intended location.
Comment Location Comment Proposed Change NRC Notes Action/Resolution 10 Lines 118123 Two sentences appear to be intermixed and need to be corrected. We believe the sentences are supposed to read as follows:
impact the way compliance with regulatory requirements is demonstrated, the actual principal design and performance requirements provided by the GDC remain applicable. The degree to which existing regulations and guidance need revision or new regulatory requirements and guidance need to be established, depends on the level of departure from existing burnup and enrichment limits.
While higher burnups and increased enrichments may impact the way compliance with regulatory requirements is demonstrated, the actual principal design and performance requirements provided by the GDC remain applicable. The degree to which existing regulations and guidance need revision or new regulatory requirements and guidance need to be established, depends on the level of departure from existing burnup and enrichment limits.
11       Tables    Tables A.1 and A.2 do not      Please review      NUREG-1555 in Table A.2    Text revised for consistency A.1 and    appear to be in alignment. regulatory          has been updated to reflect A.2        Industry believes that 10      impact tables for  the same impact as 10 CFR CFR 51 and NUREG1555         consistency.        51 in Table A.1 should have similar impacts.
Please revise text.
Two sentences are indeed intermixed. The paragraph was revised by moving the intermixed sentence to the beginning of the paragraph, which was its originally intended location.
Text revised to meet original intent 11 Tables A.1 and A.2 Tables A.1 and A.2 do not appear to be in alignment.
Industry believes that 10 CFR 51 and NUREG1555 should have similar impacts.
However 10 CFR 51 is noted as being impacted by both higher burnup and enrichment but NUREG 1555 is only noted as impacted by higher enrichment.
However 10 CFR 51 is noted as being impacted by both higher burnup and enrichment but NUREG 1555 is only noted as impacted by higher enrichment.
6
Please review regulatory impact tables for consistency.
NUREG-1555 in Table A.2 has been updated to reflect the same impact as 10 CFR 51 in Table A.1 Text revised for consistency


ATF Project Plan V1.1                                                                                                       October 2019 Stakeholder Comment Disposition Table Comment   Location   Comment                           Proposed           NRC Notes                   Action/Resolution
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 7
#                                                      Change 12       Lines     Industry performs a review       Please remove      Section A.1.1 was not      Text updated to be clearer.
Comment Location Comment Proposed Change NRC Notes Action/Resolution 12 Lines 141159 Industry performs a review of whether a LAR qualifies for a categorical exclusion from the National Environmental Policy Act (NEPA) as part of the standard LAR review process and NRC reviews that assessment during the approval of that LAR. As such, the text discussing whether NRC staff needs to reconsider the justification for the continued applicability of the existing Generic Environmental Impact Statement is unnecessary.
141159    of whether a LAR qualifies       Section A.1.1 as  removed. Instead it was for a categorical exclusion       it's redundant. updated to be clearer about from the National                                   the NRC staff's intended Environmental Policy Act                             course of action, should it (NEPA) as part of the                               become necessary:
Please remove Section A.1.1 as it's redundant.
standard LAR review                                 streamlining NRC staff process and NRC reviews                             reviews of categorical that assessment during the                           exclusions and/or approval of that LAR. As                             environmental impacts that such, the text discussing                           do not meet the exclusion.
Section A.1.1 was not removed. Instead it was updated to be clearer about the NRC staff's intended course of action, should it become necessary:
whether NRC staff needs to reconsider the justification for the continued applicability of the existing Generic Environmental Impact Statement is unnecessary.
streamlining NRC staff reviews of categorical exclusions and/or environmental impacts that do not meet the exclusion.
13       Line 170   The reference to ADAMS           Please revise      Agreed                      Text updated with applicable ML#.
Text updated to be clearer.
Accession Number                 text.
13 Line 170 The reference to ADAMS Accession Number ML18100A045 is incorrect.
ML18100A045 is incorrect.
That was the draft LTA letter from the NRC to NEI which was posted on 53118.
That was the draft LTA letter from the NRC to NEI which was posted on 53118.
The final LTA letter should be cited, ADAMS Accession Number ML18323A169 dated 62419.
The final LTA letter should be cited, ADAMS Accession Number ML18323A169 dated 62419.
7
Please revise text.
Agreed Text updated with applicable ML#.


ATF Project Plan V1.1                                                                                       October 2019 Stakeholder Comment Disposition Table Comment   Location   Comment                       Proposed           NRC Notes     Action/Resolution
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 8
#                                                  Change 14       Lines     The text states that for LTAs Please revise      Agreed        Text updated to be clearer.
Comment Location Comment Proposed Change NRC Notes Action/Resolution 14 Lines 171173 The text states that for LTAs using increased enrichments and higher burnups, the guidance in the LTA letter may not be applicable. The guidance in the LTA letter should be applicable to all LTAs programs. The determination of whether a 50.59 or LAR is required is made by applying the guidance on a casebycase basis depending on the scope of the LTA campaign and the licensing basis of the reactor.
171173    using increased               the text to simply enrichments and higher         state that LTA burnups, the guidance in the   programs for LTA letter may not be         higher burnup applicable. The guidance in   and increased the LTA letter should be       enrichment may applicable to all LTAs         require LARs programs. The                 and remove the determination of whether a     text indicating 50.59 or LAR is required is   that the LTA made by applying the           program may fall guidance on a casebycase     outside the basis depending on the         guidance. The scope of the LTA campaign     determination of and the licensing basis of     whether a LAR the reactor.                  or 50.59 is appropriate is made by applying the guidance in the LTA letter to the specifics of the LTA campaign and the reactor licensing basis.
Please revise the text to simply state that LTA programs for higher burnup and increased enrichment may require LARs and remove the text indicating that the LTA program may fall outside the guidance. The determination of whether a LAR or 50.59 is appropriate is made by applying the guidance in the LTA letter to the specifics of the LTA campaign and the reactor licensing basis.
8
Agreed Text updated to be clearer.


ATF Project Plan V1.1                                                                                                           October 2019 Stakeholder Comment Disposition Table Comment   Location   Comment                         Proposed           NRC Notes                       Action/Resolution
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 9
#                                                    Change 15       Lines     The design of new UF6           Please add text    The package designer            No changes needed.
Comment Location Comment Proposed Change NRC Notes Action/Resolution 15 Lines 241 -
241 -      packaging must continue to     to indicate that    should work with licensees to 244        interface with the existing     as part of the      ensure that any new or plant equipment process         consideration of    modified package design will (receipt, storage, heating,     new package        interface with existing facility discharge, cleaning, etc).     designs, there     equipment.
244 The design of new UF6 packaging must continue to interface with the existing plant equipment process (receipt, storage, heating, discharge, cleaning, etc).
should be a consideration for how a new packages would interface with existing facility equipment.
Please add text to indicate that as part of the consideration of new package designs, there should be a consideration for how a new packages would interface with existing facility equipment.
16       Lines     The Appendix contains two       Please add          Section A2.2.4.1 was revised    Revised text as stated.
The package designer should work with licensees to ensure that any new or modified package design will interface with existing facility equipment.
235244    citations of 10 CFR 71.55(g)   mention of 49      to state that "DOT and one citation of 49 CFR      CFR 173.417 in      regulations in 49 CFR 173.420 (line 322). There       the appendix.      173.417 which provide is no mention of 49 CFR                             requirements for shipment of 173.417 which sets a 5.0                           UF6 heels without a w/o U235 enrichment limit                          protective overpack also limit for transport within 30inch                       the enrichment of 30B and cylinders. Given the                               30C cylinders to 5 weight regulatory infrastructure                           percent."
No changes needed.
changes discussed in lines 235244 of the Appendix, the need to revise DOTs 49 CFR 173.417 should be captured in some fashion in this Appendix.
16 Lines 235244 The Appendix contains two citations of 10 CFR 71.55(g) and one citation of 49 CFR 173.420 (line 322). There is no mention of 49 CFR 173.417 which sets a 5.0 w/o U235 enrichment limit for transport within 30inch cylinders. Given the regulatory infrastructure changes discussed in lines 235244 of the Appendix, the need to revise DOTs 49 CFR 173.417 should be captured in some fashion in this Appendix.
9
Please add mention of 49 CFR 173.417 in the appendix.
Section A2.2.4.1 was revised to state that "DOT regulations in 49 CFR 173.417 which provide requirements for shipment of UF6 heels without a protective overpack also limit the enrichment of 30B and 30C cylinders to 5 weight percent."
Revised text as stated.


ATF Project Plan V1.1                                                                                                         October 2019 Stakeholder Comment Disposition Table Comment   Location   Comment                       Proposed           NRC Notes                       Action/Resolution
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 10 Comment Location Comment Proposed Change NRC Notes Action/Resolution 17 Table A.4 Why does table A.4 not have an opinion on NUREGs 1536, 1567 or 1927?
#                                                  Change 17       Table     Why does table A.4 not         Please provide    NUREG-2215 is being              No edits are warranted.
Please provide the NRC opinion of these fuel cycle NUREGs in table A.4.
A.4        have an opinion on             the NRC opinion    finalized, which consolidated NUREGs 1536, 1567 or           of these fuel     both the guidance in 1927?                          cycle NUREGs      NUREG-1567 and NUREG-in table A.4.      1536, Revision 1. The staff expects that the document will be publicly-available prior to any need to store ATF with high burnup and high enrichment. NUREG-2215 will be the review guidance used for the initial period of storage, up to 40 years. The renewals of storage facilties will be addressed in a future revision to this plan, which will include reference to the proper revision of NUREG-1927. At this point, that reference is not warranted.
NUREG-2215 is being finalized, which consolidated both the guidance in NUREG-1567 and NUREG-1536, Revision 1. The staff expects that the document will be publicly-available prior to any need to store ATF with high burnup and high enrichment. NUREG-2215 will be the review guidance used for the initial period of storage, up to 40 years. The renewals of storage facilties will be addressed in a future revision to this plan, which will include reference to the proper revision of NUREG-1927. At this point, that reference is not warranted.
18       Line 256   safety related issues       Please revise                                       Text revised as indicated.
No edits are warranted.
should be safetyrelated      text as indicated issues 19       Lines     Please use subscripts         Please revise     All instances of U235 or         Text revised throughout document.
18 Line 256 safety related issues should be safetyrelated issues Please revise text as indicated Text revised as indicated.
266,      consistently throughout the    text for          superscript 235U have been 272,      appendix.                      consistency.      updated with "uranium-235" 321, 329                                                    (to maintain consistency with the ATF project plan), UF6 now uses subscript 6, and UO2 now uses subscript 2.
19 Lines
10
: 266, 272, 321, 329 Please use subscripts consistently throughout the appendix.
Please revise text for consistency.
All instances of U235 or superscript 235U have been updated with "uranium-235" (to maintain consistency with the ATF project plan), UF6 now uses subscript 6, and UO2 now uses subscript 2.
Text revised throughout document.


ATF Project Plan V1.1                                                                                       October 2019 Stakeholder Comment Disposition Table Comment   Location   Comment                       Proposed           NRC Notes     Action/Resolution
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 11 Comment Location Comment Proposed Change NRC Notes Action/Resolution 20 Lines 328 to 338 The International Handbook of Evaluated Criticality Safety Benchmark Experiments contain approximately 30 LWR benchmark cases between 5 and 10 w/o U235 with the majority near 7 w/o. Pooling these benchmark experiments with the larger population of experiments below 5 w/o does present a challenge but general issue exists in all benchmark studies as discussed in DSSISG201001 (ML110620086).
#                                                  Change 20       Lines     The International Handbook   Please revise      Agree.        Text revised as indicated.
Please revise the last bullet (lines 336 and 337) to the following:
328 to    of Evaluated Criticality     the last bullet 338        Safety Benchmark             (lines 336 and Experiments contain           337) to the approximately 30 LWR         following:
increase the onesided k effective tolerance factor to account for uncertainties in criticality code performance due to the number of applicable critical experiments for benchmarking.
benchmark cases between       increase the 5 and 10 w/o U235 with the   onesided k majority near 7 w/o. Pooling effective these benchmark               tolerance factor experiments with the larger   to account for population of experiments     uncertainties in below 5 w/o does present a   criticality code challenge but general issue   performance due exists in all benchmark       to the number of studies as discussed in       applicable DSSISG201001               critical (ML110620086).               experiments for benchmarking.
Agree.
11
Text revised as indicated.


ATF Project Plan V1.1                                                                                                           October 2019 Stakeholder Comment Disposition Table Comment   Location   Comment                         Proposed         NRC Notes                       Action/Resolution
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 12 Comment Location Comment Proposed Change NRC Notes Action/Resolution 21 Lines 332337 Are each of the activities noted are potential methods for applicants to overcome the NRC's stated lack of criticality benchmark data?
#                                                    Change 21       Lines     Are each of the activities     Please clarify    The NRC staff is not aware      Text revised to indicate an 332337    noted are potential methods     text.            of any higher fidelity          "either/or" set of options (or for applicants to overcome                       computer codes which have        combination thereof).
Or is the intent that a combination of the denoted activities would be needed?
the NRC's stated lack of                         been demonstrated to have criticality benchmark data?                       increased predictive Or is the intent that a                           capability compared to the combination of the denoted                       previously approved activities would be needed?                       methods. Insufficient Given the predictive nature                       representative test data may of first principle codes now                     prevent adequate validation available, has the NRC staff                     of higher fidelity codes and reviewed how these                                result in an inability to assess advanced codes could                              the code's uncertainty. While resolve the issue?                                NRC staff is aware that many new codes are able to model detailed physical processes that were previously unable to be modeled, the staff has not reviewed and is not aware of the justification which demonstrates the credibility of these higher fidelity models in areas where data is unavailable.
Given the predictive nature of first principle codes now available, has the NRC staff reviewed how these advanced codes could resolve the issue?
12
Please clarify text.
The NRC staff is not aware of any higher fidelity computer codes which have been demonstrated to have increased predictive capability compared to the previously approved methods. Insufficient representative test data may prevent adequate validation of higher fidelity codes and result in an inability to assess the code's uncertainty. While NRC staff is aware that many new codes are able to model detailed physical processes that were previously unable to be modeled, the staff has not reviewed and is not aware of the justification which demonstrates the credibility of these higher fidelity models in areas where data is unavailable.
Text revised to indicate an "either/or" set of options (or combination thereof).


ATF Project Plan V1.1                                                                                                         October 2019 Stakeholder Comment Disposition Table 22       Lines     The text indicates that there   Please remove      The NRC has historically      Revised the text to refer to 353355    is a need for experimental     this text. There   expected that experimental     "unanalyzed" instead of "unknown" confirmation for whether an    is no reason an    confirmation be obtained and   age-related phenomena, and unknown agerelated            experimental        assessed, which confirms       provide perspective on NRC's basis phenomena impact the            confirmation for    that the spent fuel performs   for the expectation.
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 13 22 Lines 353355 The text indicates that there is a need for experimental confirmation for whether an unknown agerelated phenomena impact the spent fuel during storage and transport after storage.
spent fuel during storage      something that      as expected. The and transport after storage. isn't known to      experimental confirmatory Why would this be the          exist is needed. basis that low-burnup fuel case?                                              [45 gigawatt days per metric ton of uranium (GWd/MTU)]
Why would this be the case?
Please remove this text. There is no reason an experimental confirmation for something that isn't known to exist is needed.
The NRC has historically expected that experimental confirmation be obtained and assessed, which confirms that the spent fuel performs as expected. The experimental confirmatory basis that low-burnup fuel
[45 gigawatt days per metric ton of uranium (GWd/MTU)]
remains in its analyzed configuration during the period of extended operation was provided in NUREG/CR-6745, Dry Cask Storage Characterization Project Phase 1; CASTOR V/21 Cask Opening and Examination (Bare and Torgerson, 2001), and NUREG/CR-6831, Examination of Spent PWR Fuel Rods after 15 Years in Dry Storage (Einziger et al.,
remains in its analyzed configuration during the period of extended operation was provided in NUREG/CR-6745, Dry Cask Storage Characterization Project Phase 1; CASTOR V/21 Cask Opening and Examination (Bare and Torgerson, 2001), and NUREG/CR-6831, Examination of Spent PWR Fuel Rods after 15 Years in Dry Storage (Einziger et al.,
2003). This research demonstrated that low-burnup fuel cladding and other cask internals had no deleterious effects after 15 years of storage and confirmed the basis for the guidance on creep deformation and radial hydride reorientation in NRC's review guidance. The research results in NUREG/CR-6745 and NUREG/CR-6831 support a determination that degradation of low-burnup 13
2003). This research demonstrated that low-burnup fuel cladding and other cask internals had no deleterious effects after 15 years of storage and confirmed the basis for the guidance on creep deformation and radial hydride reorientation in NRC's review guidance. The research results in NUREG/CR-6745 and NUREG/CR-6831 support a determination that degradation of low-burnup Revised the text to refer to "unanalyzed" instead of "unknown" age-related phenomena, and provide perspective on NRC's basis for the expectation.


ATF Project Plan V1.1                                                                                                         October 2019 Stakeholder Comment Disposition Table Comment   Location   Comment                         Proposed           NRC Notes                       Action/Resolution
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 14 Comment Location Comment Proposed Change NRC Notes Action/Resolution fuel cladding and assembly hardware should not result in changes to the approved design bases during the first period of extended operation, provided that the cask/canister internal environment is maintained.
#                                                    Change fuel cladding and assembly hardware should not result in changes to the approved design bases during the first period of extended operation, provided that the cask/canister internal environment is maintained.
The U.S. Department of Energy (DOE) is funding a similar program for high burnup fuel [>45 gigawatt days per metric ton of uranium (GWd/MTU)] at the North Anna independent spent fuel storage installation to gather similar experimental confirmatory data to support the technical basis for storage during the first period of extended operation (EPRI, 2014).
The U.S. Department of Energy (DOE) is funding a similar program for high burnup fuel [>45 gigawatt days per metric ton of uranium (GWd/MTU)] at the North Anna independent spent fuel storage installation to gather similar experimental confirmatory data to support the technical basis for storage during the first period of extended operation (EPRI, 2014).
Therefore, the cited discussion is consistent with NRC's expectation that experimental data be obtained to confirm that unanalyzed age-related phenomena is not operable during the dry storage and subsequent transport of spent ATF of higher burnup and higher enrichment.
Therefore, the cited discussion is consistent with NRC's expectation that experimental data be obtained to confirm that unanalyzed age-related phenomena is not operable during the dry storage and subsequent transport of spent ATF of higher burnup and higher enrichment.
23       Line 372   "Near term" should be         Please revise                                     Text revised as indicated.
23 Line 372 "Near term" should be "nearterm" Please revise text as indicated Text revised as indicated.
                      "nearterm"                    text as indicated 24       Line 374   Please revise text to "..only   Please revise                                     Revised to delete "however".
24 Line 374 Please revise text to "..only one fuel cycle facility has shared plans" Please revise text as indicated Revised to delete "however".  
one fuel cycle facility has    text as indicated shared plans" 14


ATF Project Plan V1.1                                                                                                     October 2019 Stakeholder Comment Disposition Table Comment   Location   Comment                         Proposed           NRC Notes                 Action/Resolution
ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 15 Comment Location Comment Proposed Change NRC Notes Action/Resolution 25 Line 394 Please revise "unrainum" to "uranium" Please revise text as indicated Text revised as indicated.
#                                                    Change 25       Line 394   Please revise "unrainum" to     Please revise                                 Text revised as indicated.
26 Lines 423 -
                      "uranium"                        text as indicated 26       Lines     The text indicates that near   Please clarify    Text clarified to indicate Text clarified.
424 The text indicates that near term increases in burnup and enrichment limits are expected to be only marginally greater than current limits. Is the 5 - 8 wt% range considered as marginally greater than current limits; or is a stepwise approach between 5 - 8% being envisioned?
423 -      term increases in burnup         text.              range of consideration for 424        and enrichment limits are                           impacts expected to be only marginally greater than current limits. Is the 5 - 8 wt% range considered as marginally greater than current limits; or is a stepwise approach between 5 - 8% being envisioned?
What burnup values are considered to be marginal increases?
What burnup values are considered to be marginal increases?
15}}
Please clarify text.
Text clarified to indicate range of consideration for impacts Text clarified.}}

Latest revision as of 06:43, 2 January 2025

Comment Disposition Table for ATF Project Plan V1.1
ML19301B814
Person / Time
Issue date: 10/31/2019
From: James Drake
Licensing Processes Branch
To: Raymond Furstenau, John Lubinski, Neih H
Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Office of Nuclear Regulatory Research
Drake, J, NRC/NRR/LLPB
Shared Package
ML19297F703 List:
References
A11008, EPID L-2017-PMP-0011
Download: ML19301B814 (15)
v • d • e


Text

ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table Attachment Comment Location Comment Proposed Change NRC Notes Action/Resolution 1

General The timelines, activities, and impacts associated with increasing burnup and enrichment are different.

The appendix sometimes discusses both topics and other times is only referring to one of the two, however, it is not perfectly clear at all times.

Please consider partitioning the various sections into burnup and enrichment portions of the appendix to more clearly identify the information relevant to each topic.

The impacts of high burnup and increased enrichment are different (i.e., different technical concerns), and the schedules slightly different, but the activities for addressing the impacts are largely, if not entirely, the same because of leveraging resources to perform high burnup and enrichment tasks in parallel with ATF. Those areas where there are differences in schedule or activity are delineated in the various tables present in the project plan. And the differences in the technical issues are discussed in the opening paragraphs in each section. Therefore, the decision was made not to partition the project plan.

However, many areas of the project plan were updated with revised wording to clearly indicate, when appropriate, which of the two technologies is being discussed.

Various portions of text within the entire HBU+IE project plan were revised to clearly indicate which of the two technologies (burnup or enrichment) are being discussed in those instances where both were not being addressed.

2 General In numerous places it references UF6 as the only enriched product used to fabricate UO2.

Please revise the text to be more generic as there are possibilities to use other precursor forms that are not UF6.

Agree.

Revised to identify UF6 or other potential precursor forms that are enriched above the current limit (5 weight percent U-235).

ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 2

Comment Location Comment Proposed Change NRC Notes Action/Resolution 3

General The draft appendix discusses changes to the standard pellet/clad fuel system. In a fuel system where uranium is the minority component, a uranium enrichment could be above 5% while the ratio of U235 to all atoms by volume may not be above 5%. Therefore the effective enrichment would be less than 5% despite the ratio of U235 atoms to U atoms being above 5%.

Please add text to indicate that this appendix is only applicable for current UO2 fuel or clarify how to treat all fuel types.

5% weight enrichment is generally understood to be the amount of the uranium-235 isotope present relative to the amount of all other uranium isotopes.

Approach outlined in the project plan does not change depending on the fuel type. No changes made.

4 General The appendix to the NRC Project Plan is prepared as Appendix A, however the NRC Project Plan Version 1.0 (ML18261A414) already contains an Appendix A NRC Plans to Develop Analysis Capability. Having two appendices with the same letter creates an error likely situation.

Please revise the burnup and enrichment appendix or the current project plan appendix to be a different letter.

Discussed during public meeting, the HBU+IE project plan will appear as Appendix A in the ATF project plan.

The existing Appendix A in the ATF project plan will become Appendix B.

ATF project plan document to be updated with modified appendix lettering 5

General Where is table A.5? The appendix appears to skip this table.

Please revise text for consistency.

Tables A.1 through A.6 now labeled consistently Text revised for consistency

ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 3

Comment Location Comment Proposed Change NRC Notes Action/Resolution 6

General, Line 25, Lines 228292 The text indicates NRC staff will participate in a coordinated PIRT on in reactor performance of fuels with increased enrichment.

Please provide more information on the timing, scope, and intent of this activity. Additional information such as the information presented during the Public Meeting on September 12th would be helpful.

The text indicates that the PIRT would only be for increased enrichment. Is burnup excluded intentionally? Would these activities be NRR focused or more crosscutting across multiple parts of NRC?

The text indicates NRC staff will participate in a PIRT for transportation packages for unirradiated fuel transportation for material with higher burnup and enrichment. Please provide more information on the timing, scope, and intent of this activity.

Please explain higher burnup unirradiated material.

Please explain NRC's intentions regarding a PIRT for increased burnup and enrichment efforts.

Within the scope of the In-Reactor performance, a HBU PIRT is not being developed (but a literature search is being performed). An IE PIRT is being developed.

Clarified the scope of Section A.2.2.2 to include uranium feed material and unirradiated fuel. Revised to eliminate references to higher burnup and clarified the scope of the PIRTs will include criticality safety and materials properties/performance.

Additional discussion within Section A.1.4 has been provided to clarify the In-Reactor intent of an IE PIRT and a HBU literature search.

Delineation is also made between HBU for conventional fuel designs and ATF designs. Clarified the scope of Section A.2.2.2 to include uranium feed material and unirradiated fuel. Revised to eliminate references to higher burnup and clarified the scope of the PIRTs will include criticality safety and materials properties/performance.

ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 4

Comment Location Comment Proposed Change NRC Notes Action/Resolution 7

Line 24 Please spell out PIRT as this is the first occurrence (Phenomena Identification &

Ranking Table)

Please revise text as indicated PIRT spelled out Text revised as indicated.

8 Lines 46 50 The Appendix states that the staff does not anticipate identification of gaps or deficiencies in these regulations with respect to Part 71 and 72. However, lines 243 244 discuss new transportation packages, modification of current packages, or exemptions from 10 CFR 71.55(g),

especially subpart (g)(4) and its limit of 5.0 w/o.

The latter statements appear to be contradictory with respect to gaps in Part

71.

Please ensure text is consistent with intent.

The latter is not contradictory in that a gap in the regulations for Parts 71 or 72 would not provide the staff with a regulatory tool for review and approval of a proposed transport package or storage cask design. If holders of a transport package certificate of compliance for UF6 are able to demonstrate that the package is subcritical with optimum moderation, then an exemption is not needed, and the package design will meet Part 71 in its entirety.

No changes needed.

ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 5

Comment Location Comment Proposed Change NRC Notes Action/Resolution 9

Lines 112113 While updating the regulatory framework is important to ensure regulatory certainty, why would such changes that could include rulemaking, need to be made before either higher enrichments or burnups can be licensed?

This text appears to indicate that the common regulatory practice of using exemptions first would not be acceptable. Additionally, it is inconsistent with the exemption pathway discussed in lines 180182 and the discussion in lines 227230.

Please revise text to remove indication that regulatory framework changes are anticipated to be complete before licensing can be approved.

The intent of the word "generic" was to attempt to capture the standard, predictable licensing process used for widespread adoption of methods and technology. Clarification has been provided to indicate the NRC staff anticipates regulatory changes will be needed before a predictable licensing approach outside the use of exemptions can be implemented.

Text revised to meet original intent.

ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 6

Comment Location Comment Proposed Change NRC Notes Action/Resolution 10 Lines 118123 Two sentences appear to be intermixed and need to be corrected. We believe the sentences are supposed to read as follows:

While higher burnups and increased enrichments may impact the way compliance with regulatory requirements is demonstrated, the actual principal design and performance requirements provided by the GDC remain applicable. The degree to which existing regulations and guidance need revision or new regulatory requirements and guidance need to be established, depends on the level of departure from existing burnup and enrichment limits.

Please revise text.

Two sentences are indeed intermixed. The paragraph was revised by moving the intermixed sentence to the beginning of the paragraph, which was its originally intended location.

Text revised to meet original intent 11 Tables A.1 and A.2 Tables A.1 and A.2 do not appear to be in alignment.

Industry believes that 10 CFR 51 and NUREG1555 should have similar impacts.

However 10 CFR 51 is noted as being impacted by both higher burnup and enrichment but NUREG 1555 is only noted as impacted by higher enrichment.

Please review regulatory impact tables for consistency.

NUREG-1555 in Table A.2 has been updated to reflect the same impact as 10 CFR 51 in Table A.1 Text revised for consistency

ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 7

Comment Location Comment Proposed Change NRC Notes Action/Resolution 12 Lines 141159 Industry performs a review of whether a LAR qualifies for a categorical exclusion from the National Environmental Policy Act (NEPA) as part of the standard LAR review process and NRC reviews that assessment during the approval of that LAR. As such, the text discussing whether NRC staff needs to reconsider the justification for the continued applicability of the existing Generic Environmental Impact Statement is unnecessary.

Please remove Section A.1.1 as it's redundant.

Section A.1.1 was not removed. Instead it was updated to be clearer about the NRC staff's intended course of action, should it become necessary:

streamlining NRC staff reviews of categorical exclusions and/or environmental impacts that do not meet the exclusion.

Text updated to be clearer.

13 Line 170 The reference to ADAMS Accession Number ML18100A045 is incorrect.

That was the draft LTA letter from the NRC to NEI which was posted on 53118.

The final LTA letter should be cited, ADAMS Accession Number ML18323A169 dated 62419.

Please revise text.

Agreed Text updated with applicable ML#.

ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 8

Comment Location Comment Proposed Change NRC Notes Action/Resolution 14 Lines 171173 The text states that for LTAs using increased enrichments and higher burnups, the guidance in the LTA letter may not be applicable. The guidance in the LTA letter should be applicable to all LTAs programs. The determination of whether a 50.59 or LAR is required is made by applying the guidance on a casebycase basis depending on the scope of the LTA campaign and the licensing basis of the reactor.

Please revise the text to simply state that LTA programs for higher burnup and increased enrichment may require LARs and remove the text indicating that the LTA program may fall outside the guidance. The determination of whether a LAR or 50.59 is appropriate is made by applying the guidance in the LTA letter to the specifics of the LTA campaign and the reactor licensing basis.

Agreed Text updated to be clearer.

ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 9

Comment Location Comment Proposed Change NRC Notes Action/Resolution 15 Lines 241 -

244 The design of new UF6 packaging must continue to interface with the existing plant equipment process (receipt, storage, heating, discharge, cleaning, etc).

Please add text to indicate that as part of the consideration of new package designs, there should be a consideration for how a new packages would interface with existing facility equipment.

The package designer should work with licensees to ensure that any new or modified package design will interface with existing facility equipment.

No changes needed.

16 Lines 235244 The Appendix contains two citations of 10 CFR 71.55(g) and one citation of 49 CFR 173.420 (line 322). There is no mention of 49 CFR 173.417 which sets a 5.0 w/o U235 enrichment limit for transport within 30inch cylinders. Given the regulatory infrastructure changes discussed in lines 235244 of the Appendix, the need to revise DOTs 49 CFR 173.417 should be captured in some fashion in this Appendix.

Please add mention of 49 CFR 173.417 in the appendix.

Section A2.2.4.1 was revised to state that "DOT regulations in 49 CFR 173.417 which provide requirements for shipment of UF6 heels without a protective overpack also limit the enrichment of 30B and 30C cylinders to 5 weight percent."

Revised text as stated.

ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 10 Comment Location Comment Proposed Change NRC Notes Action/Resolution 17 Table A.4 Why does table A.4 not have an opinion on NUREGs 1536, 1567 or 1927?

Please provide the NRC opinion of these fuel cycle NUREGs in table A.4.

NUREG-2215 is being finalized, which consolidated both the guidance in NUREG-1567 and NUREG-1536, Revision 1. The staff expects that the document will be publicly-available prior to any need to store ATF with high burnup and high enrichment. NUREG-2215 will be the review guidance used for the initial period of storage, up to 40 years. The renewals of storage facilties will be addressed in a future revision to this plan, which will include reference to the proper revision of NUREG-1927. At this point, that reference is not warranted.

No edits are warranted.

18 Line 256 safety related issues should be safetyrelated issues Please revise text as indicated Text revised as indicated.

19 Lines

266, 272, 321, 329 Please use subscripts consistently throughout the appendix.

Please revise text for consistency.

All instances of U235 or superscript 235U have been updated with "uranium-235" (to maintain consistency with the ATF project plan), UF6 now uses subscript 6, and UO2 now uses subscript 2.

Text revised throughout document.

ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 11 Comment Location Comment Proposed Change NRC Notes Action/Resolution 20 Lines 328 to 338 The International Handbook of Evaluated Criticality Safety Benchmark Experiments contain approximately 30 LWR benchmark cases between 5 and 10 w/o U235 with the majority near 7 w/o. Pooling these benchmark experiments with the larger population of experiments below 5 w/o does present a challenge but general issue exists in all benchmark studies as discussed in DSSISG201001 (ML110620086).

Please revise the last bullet (lines 336 and 337) to the following:

increase the onesided k effective tolerance factor to account for uncertainties in criticality code performance due to the number of applicable critical experiments for benchmarking.

Agree.

Text revised as indicated.

ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 12 Comment Location Comment Proposed Change NRC Notes Action/Resolution 21 Lines 332337 Are each of the activities noted are potential methods for applicants to overcome the NRC's stated lack of criticality benchmark data?

Or is the intent that a combination of the denoted activities would be needed?

Given the predictive nature of first principle codes now available, has the NRC staff reviewed how these advanced codes could resolve the issue?

Please clarify text.

The NRC staff is not aware of any higher fidelity computer codes which have been demonstrated to have increased predictive capability compared to the previously approved methods. Insufficient representative test data may prevent adequate validation of higher fidelity codes and result in an inability to assess the code's uncertainty. While NRC staff is aware that many new codes are able to model detailed physical processes that were previously unable to be modeled, the staff has not reviewed and is not aware of the justification which demonstrates the credibility of these higher fidelity models in areas where data is unavailable.

Text revised to indicate an "either/or" set of options (or combination thereof).

ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 13 22 Lines 353355 The text indicates that there is a need for experimental confirmation for whether an unknown agerelated phenomena impact the spent fuel during storage and transport after storage.

Why would this be the case?

Please remove this text. There is no reason an experimental confirmation for something that isn't known to exist is needed.

The NRC has historically expected that experimental confirmation be obtained and assessed, which confirms that the spent fuel performs as expected. The experimental confirmatory basis that low-burnup fuel

[45 gigawatt days per metric ton of uranium (GWd/MTU)]

remains in its analyzed configuration during the period of extended operation was provided in NUREG/CR-6745, Dry Cask Storage Characterization Project Phase 1; CASTOR V/21 Cask Opening and Examination (Bare and Torgerson, 2001), and NUREG/CR-6831, Examination of Spent PWR Fuel Rods after 15 Years in Dry Storage (Einziger et al.,

2003). This research demonstrated that low-burnup fuel cladding and other cask internals had no deleterious effects after 15 years of storage and confirmed the basis for the guidance on creep deformation and radial hydride reorientation in NRC's review guidance. The research results in NUREG/CR-6745 and NUREG/CR-6831 support a determination that degradation of low-burnup Revised the text to refer to "unanalyzed" instead of "unknown" age-related phenomena, and provide perspective on NRC's basis for the expectation.

ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 14 Comment Location Comment Proposed Change NRC Notes Action/Resolution fuel cladding and assembly hardware should not result in changes to the approved design bases during the first period of extended operation, provided that the cask/canister internal environment is maintained.

The U.S. Department of Energy (DOE) is funding a similar program for high burnup fuel [>45 gigawatt days per metric ton of uranium (GWd/MTU)] at the North Anna independent spent fuel storage installation to gather similar experimental confirmatory data to support the technical basis for storage during the first period of extended operation (EPRI, 2014).

Therefore, the cited discussion is consistent with NRC's expectation that experimental data be obtained to confirm that unanalyzed age-related phenomena is not operable during the dry storage and subsequent transport of spent ATF of higher burnup and higher enrichment.

23 Line 372 "Near term" should be "nearterm" Please revise text as indicated Text revised as indicated.

24 Line 374 Please revise text to "..only one fuel cycle facility has shared plans" Please revise text as indicated Revised to delete "however".

ATF Project Plan V1.1 October 2019 Stakeholder Comment Disposition Table 15 Comment Location Comment Proposed Change NRC Notes Action/Resolution 25 Line 394 Please revise "unrainum" to "uranium" Please revise text as indicated Text revised as indicated.

26 Lines 423 -

424 The text indicates that near term increases in burnup and enrichment limits are expected to be only marginally greater than current limits. Is the 5 - 8 wt% range considered as marginally greater than current limits; or is a stepwise approach between 5 - 8% being envisioned?

What burnup values are considered to be marginal increases?

Please clarify text.

Text clarified to indicate range of consideration for impacts Text clarified.

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