ML18057A189
| ML18057A189 | |
| Person / Time | |
|---|---|
| Issue date: | 02/27/2018 |
| From: | Proffitt J Office of Nuclear Reactor Regulation |
| To: | |
| Proffitt J | |
| References | |
| Download: ML18057A189 (16) | |
Text
February 27, 2018 I.Brief outline of ATF project planII.Overview of comments received III.Path forward 2
- Developed and maintained by the ATF steering committee and working group
- Outlines activities associated with preparing the agency to conduct efficient and effective reviews of ATF designs
- Includes preliminary estimates of lead time necessary to complete activities in each area
- Intended to be a living document 3
- Assumptions
- Open items
- Stakeholder interactions
- Initiating staff activities
- Preparatory activities:
-Regulatory framework, In-reactor performance
-Fuel cycle, transportation and storage regulatory framework-PRA activities
-Analysis capability development 4
- Draft plan published in the Federal Register on December 21, 2017 for 45 day public comment period
- Received nearly 80 comments from
-U.S. Department of Energy (DOE)
-Louisiana Energy Services (UUSA)
-Nuclear Energy Institute (NEI)
-Pressurized Water Reactor Owners Group (PWROG)
-General Atomics
-Southern Nuclear Company
-Westinghouse Electric Company
-three individuals 5
6 20%13%12%10%10%8%6%5%4%4%4%3%Draft ATF Project Plan Public Comments Licensing Process Codes Coordination/Communication PRA Evolutionary/Revolutionary General Lead Test Assemblies Timeline Regulatory Framework Resources Data/Testing Transportation Adv Rx Codes Coordination/
Communication Evolutionary/RevolutionaryLicensingProcess General LTAs Timeline PRA
- Concerns with regulatory requirements associated with lead test assemblies
- Emphasize importance of communication and coordination
- "Evolutionary" vs. "revolutionary"
- Does not support industry's deployment schedule & staff not employing a graded approach
- Opportunity to transform fuel licensing process
- Leverage DOE/advanced computational capabilities 7
- Comment-Lack of clarity on current requirements
- NRC response
-Outside scope of ATF project plan
-Separate NRC steering committee actively working to address 8
- Comment-Appreciate NRC's project plan effort
-Key to meeting implementation schedule
- NRC response
-Plan relies on early engagement
-Staff committed to continue
-Will seek to enhance 9
- Comment-Oversimplification
-Creates uncertainty
- NRC response
-Project plan is technology independent
-Concept-specific licensing roadmap developed based on PIRT-Remove evolutionary and revolutionary distinction to improve clarity 10
- Comment-Plan does not support industry's deployment schedule
-Staff not employing a graded approach
- NRC response
-The plan did not present a schedule but rather individual activities, many of which can proceed in parallel
-The staff is committed to minimizing the lag between the time required to establish the technical bases for safe operation and the completion of licensing activities
-PIRTs will inform the licensing roadmaps for individual concepts
-PIRTs will facilitate employing a tailored approach for each concept, thus enabling a graded approach 11 12technical basis developmentdevelopment of regulatory infrastructure licensing activities licensing activitiesdevelopment of regulatory infrastructure*old & new oldnew time*as needed 13ATF Project Plan
-Cr-coated Cladding Concept Licensing RoadmapSteel (FeCrAl)
Cladding Concept Licensing Roadmap U 3 Si 2 Fuel Concept Licensing Roadmap SiC Cladding Concept Licensing RoadmapMetallic Fuel Concept Licensing Roadmap SiC CladdingVendor 1 Licensing Approach SiC CladdingVendor 2 Licensing Approach-Steel (FeCrAl) Vendor 1 Licensing ApproachSteel (FeCrAl) Vendor 2 Licensing Approach-
- Comment-ATF presents an opportunity to transform
- NRC response
-Staff continually evaluating potential efficiencies
- Expediting regulatory guidance
- Use of vendor inspections to verify data intended to support licensing activities (e.g., topical reports)
- Change processes for topical reports
- Leveraging the use of DOE/commercial codes
-Staff is open to other specific suggestions 14
- Comment-Use DOE codes in lieu of developing independent NRC capability
-Use advanced simulation techniques in lieu of experimental data
- NRC response
-Need for confirmatory calculations
- Depends on the strength of the technical basis presented by the applicant
-Use of non-NRC codes
- Staff and licensees have used the same codes in the past (e.g., Fluent for dry storage casks)
- Effectiveness and efficiency of using a non-NRC codes depends on many factors (e.g., readiness of existing NRC codes, V&V needs of non-NRC codes, learning curve for the non-NRC codes)
-Simulations in lieu of experimental testing
- At this time, the staff is not aware of any computational tool that obviates the need for experimentation to support licensing decisions
- Staff is receptive to addressing this issue as the state of the art warrants it 15
- Provide staff response to all comments in publically available document
- Incorporate changes to the project plan
- Finalize plan mid-2018
- Continue engagement with stakeholders
- Maintain project plan as "living document" 16