ML19226A334

(NEI) - Comments on Draft Interim Staff Guidance on the Chromium-Coated Zirconium Alloy Fuel Cladding Accident Tolerant Fuel Concept

ML19226A334
Person / Time
Site:	Nuclear Energy Institute
Issue date:	08/14/2019
From:	Holtzman B Nuclear Energy Institute
To:	John Marshall Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML19226A334 (7)

Text

BENJAMIN HOLTZMAN Senior Project Manager, Fuel and Radiation Safety 1201 F Street

, NW, Suite 1100 Washington, DC 20004 P: 202.739.8031 bah@nei.org nei.org August 14, 201 9 M s. Jane E. Marshall Director, Division of Safety Systems (Acting) Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

-0001

Subject:

Comments on Draft Interim Staff Guidance on the Chromium-Coated Zirconium Alloy Fuel Cladding Accident Tolerant Fuel Concept Project Number:

689

Dear M s. Marshall:

On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI) 1 submits the attached comments on the draft Interim Staff Guidance (ISG) on the Chromium

-Coated Zirconium Alloy Fuel Cladding Accident Tolerant Fuel Concept (ATF-ISG-01). NEI has been working with the Nuclear Regulatory Commission (NRC) to establish regulatory guidance that may be used by NRC staff reviewing industry applications involving chromium

-coated zirconium alloy clad fuel products. The ISG also provides insights on staff expectations for vendor topical submittals for accident tolerant fuel (ATF). This ISG supplements the guidance in NUREG-0800, "Standard Review Plan." We appreciate the staff's early publication of the draft ISG and the opportunity to present our initial views of the document during the public meeting on August 6, 2019. The attachment represents our initial comments based on a short timeframe review. While there are several areas of agreement

, as noted in our comments, the attachment highlight s key differences between industry's and NRC's expectation for how the ATF coated cladding applications should be assessed. Additionally, we would like to reiterat e one main concern related to the inclusion of the manufacturing process into the ISG that was discussed in industry's presentation at the public meeting. Industry's concern is that the draft ISG significantly expands the traditional licensing scope and attempt s to regulate the manufacturing process through fuel qualification. NUREG-0800 is a performance

-based standard and the manufacturing process is not part of the current regulations.

Furthermore, the coated cladding fuel concepts are not conceptually different from the current fuel products (same base substrate 1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.

M s. Jane E. Marshall August 14, 201 9 Page 2 material with a 10-30 µm thick coating

) and as such, the existing manufacturing oversight framework is considered to be adequate.

Other NRC regulations and oversight, such a s 10 CFR Part 50 Appendix B and vendor quality assurance inspections, are in place to review the manufacturing process. Therefore, manufacturing processes should not be included in the ISG as part of the staff's fuel qualification review. Thank you for your consideration of our comments. We look forward to continue working with the NRC through the ISG publication process and industry's ATF activities as we work to deploy batch reloads by 2023. If you have any questions or require additional information, please contact me.

Sincerely, Ben Holtzman Attachment c: Andrew Proffitt, NRR, NRC Jason Drake, NRR, NRC Josh Whitman, NRR, NRC Dennis Morey, NRR, NRC Robert Lukes, NRR, NRC NRC Document Control Desk