ML060310613
| ML060310613 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute, PROJ0669 |
| Issue date: | 04/05/2006 |
| From: | Ho Nieh NRC/NRR/ADRA/DPR |
| To: | Marion A Nuclear Energy Institute |
| Honcharik M C, NRR/DPR/PSPB, 301-415-177 | |
| References | |
| 1008108, TAC MC7042 | |
| Download: ML060310613 (5) | |
Text
April 5, 2006Mr. Alexander Marion Senior Director, Engineering Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
REQUEST FOR REVIEW OF TOPICAL REPORT 1008108, "LICENSINGCRITERIA FOR FUEL BURNUP EXTENSION BEYOND 62 GWd/tU -
INDUSTRY GUIDE," FOR REVIEW DUE TO MAJOR DEFICIENCIES (TAC NO. MC7042)
Dear Mr. Marion:
By letter dated March 17, 2005, the Nuclear Energy Institute (NEI) submitted Electric PowerResearch Institute (EPRI) Topical Report (TR) 1008108 to the U.S. Nuclear Regulatory Commission (NRC) staff for review. The TR was submitted in support of the NRC's genericregulatory improvements and to form the basis for NRC criteria for use of high-burnup fuel. Afee waiver was granted on May 20, 2005, because this TR supports NRC regulatoryimprovement efforts. The NRC staff has completed an acceptance review of your applicationand the supporting information in accordance with the TR program criteria. We have concluded that there are technical deficiencies in the licensing strategy proposed in TR 1008108 for high-burnup applications and that the TR is not sufficient to support the NRC's rulemakingefforts on this subject. Therefore, the NRC staff is not accepting this TR for review at this time. The technical deficiencies, which were discussed with NEI staff at a November 2, 2005, meeting, are outlined below.I. Evolution of Fuel Pellet Structure with Burnup In this TR, the development of a high burnup rim region is briefly discussed in the context of arod ejection accident. The characterization of the rim region, in addition to the overall pellet structure, needs to be expanded. The impact of these evolutionary changes to the pellet structure needs to be quantified for steady-state, anticipated operational occurrences (AOOs),
and all accident scenarios. Furthermore, the impact on these pellet changes needs to be evaluated with respect to validating fuel performance models (e.g., fission gas release, relocation, swelling).II. Radiological Source Term The fuel pellet and its grain structure are often considered the first boundary to the release offission products. The continued degradation of the fuel pellet structure and the development of a high burnup rim region will affect the radiological source term. It is the industry'sresponsibility to characterize and quantify the fission gas release resulting from normal steady-state operation, power ramps/maneuvers, AOOs, and all accident scenarios.
A. Marion- 2 -III. Short-Term & Long-Term Fuel StorageShort-term fuel storage (i.e., spent fuel pool, dry-cask), transportation, and long-term fuelstorage need to be either specifically addressed or coordinated with a companion TR.IV. Deviations for Licensing Strategy and Future Amendments The EPRI TR defines a uniform licensing strategy for developing and reviewing high burnupapplications. From a process perspective, the TR should briefly define how vendors would successfully deviate from these guidelines. Further, the TR should define a process for amending the information in the TR, if needed (i.e., to integrate new testing information or new operating experience).V. Loss-of-Coolant Accident (LOCA) Acceptance Criteria Based upon the scope of the Argonne National Laboratory research program and theavailability of high burnup clad material, it is not anticipated that Section 50.46 of Title 10 of theCode of Federal Regulations acceptance criteria will be validated beyond 62 GWd/tU. As aresult, it is the responsibility of the industry to conduct LOCA testing data to validate its cladmaterials performance at high burnup.For the reasons stated above EPRI TR 1008108, "Licensing Criteria for Fuel Burnup ExtensionBeyond 62 GWd/tU - Industry Guide" is not being accepted for review. If you wish to submit a revised report addressing the technical deficiencies outlined in this letter, you would not have to request another fee waiver. The fee waiver that was granted on May 20, 2005, would still bevalid. Additionally, a revised report should be accompanied by an appropriately redacted non-proprietary version of the report and address all issues discussed in NRC letter toMr. David J. Modeen dated June 15, 2005.Sincerely,/RA/Ho K. Nieh, Deputy Director Division of Policy and Rulemaking Office of Nuclear Reactor RegulationProject Nos. 669 and 689 cc: See next pages A. Marion- 2 -III. Short-Term & Long-Term Fuel StorageShort-term fuel storage (i.e., spent fuel pool, dry-cask), transportation, and long-term fuelstorage need to be either specifically addressed or coordinated with a companion TR.IV. Deviations for Licensing Strategy and Future Amendments The EPRI TR defines a uniform licensing strategy for developing and reviewing high burnupapplications. From a process perspective, the TR should briefly define how vendors would successfully deviate from these guidelines. Further, the TR should define a process for amending the information in the TR, if needed (i.e., to integrate new testing information or new operating experience).V. Loss-of-Coolant Accident (LOCA) Acceptance Criteria Based upon the scope of the Argonne National Laboratory research program and theavailability of high burnup clad material, it is not anticipated that Section 50.46 of Title 10 of theCode of Federal Regulations acceptance criteria will be validated beyond 62 GWd/tU. As aresult, it is the responsibility of the industry to conduct LOCA testing data to validate its cladmaterials performance at high burnup.For the reasons stated above EPRI TR 1008108, "Licensing Criteria for Fuel Burnup ExtensionBeyond 62 GWd/tU - Industry Guide" is not being accepted for review. If you wish to submit a revised report addressing the technical deficiencies outlined in this letter, you would not have to request another fee waiver. The fee waiver that was granted on May 20, 2005, would still bevalid. Additionally, a revised report should be accompanied by an appropriately redacted non-proprietary version of the report and address all issues discussed in NRC letter toMr. David J. Modeen dated June 15, 2005.Sincerely,/RA/
Ho K. Nieh, Deputy Director Division of Policy and Rulemaking Office of Nuclear Reactor RegulationProject Nos. 669 and 689 cc: See next pagesDISTRIBUTION:PUBLICRidsNrrDprPSPB Reading FileRidsNrrDprPspbRidsNrrLADBaxleyRidsAcrsAcnwMailCenterRidsNrrPMMHoncharikRidsOgcMailCenterRSuriRidsNrrDssSnpbPCliffordAccession No.: ML060310613NRR-106OFFICEPSPB/PMPSPB/LAOFCO/DFM/DSNPB/SCPSPB/(A)BCDPR/DDNAMEMHoncharikDBaxleyMGiwinesFAkstulewiczDCollinsHNiehDATE4/30/064/4/062/10/063/3/064/5/064/5/06OFFICIAL RECORD COPY Electric Power Research InstituteProject No. 669 cc:Mr. David J. Modeen Vice President and Chief Nuclear Officer EPRI 1300 W. T. Harris Boulevard Charlotte, NC 28262Mr. James Lang, DirectorEPRI 1300 W.T. Harris Boulevard Charlotte, NC 28262Mr. Warren Bilanin, DirectorEPRI 3412 Hillview Av enuePalo Alto, CA 94304 12/21/05 Nuclear Energy InstituteProject No. 689 cc:Mr. Anthony Pietrangelo, Senior DirectorRisk Regulation Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708Mr. H. A. Sepp, ManagerRegulatory and Licensing Engineering Westinghouse Electric Company P. O. Box 355 Pittsburgh, PA 15230-0355Mr. James Davis, DirectorOperations Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708Mr. Charles B. Brinkman Washington Operations ABB-Combustion Engineering, Inc.
12300 Twinbrook Parkway, Suite 330 Rockville, MD 20852Mr. Gary L. Vine, Executive DirectorFederal and Industry Activities, Nuclear Sector EPRI 2000 L Street, NW, Suite 805 Washington, DC 20036Mr. Pedro Salas Regulatory Assurance Manager - Dresden Exelon Generation Company, LLC 6500 N. Dresden Road Morris, IL 60450-9765Ms. Barbara LewisAssistant Editor Platts, Principal Editorial Office 1200 G St., N.W., Suite 1100 Washington, DC 20005Mr. Gary WelshInstitute of Nuclear Power Operations Suite 100 700 Galleria Parkway, SE Atlanta, GA 30339-5957 12/21/05