ML18051A069

Comment (7) of Andrew Mauer on Preparing to License Accident Tolerant Fuel

ML18051A069
Person / Time
Site:	Nuclear Energy Institute
Issue date:	02/05/2018
From:	Mauer A Nuclear Energy Institute
To:	May Ma Rules, Announcements, and Directives Branch
References
82FR60633 00007, NRC-2017-0236
Download: ML18051A069 (17)

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PUBLIC SUBMISSION Docket: NRC-2017-0236 Preparing to License Accident Tolerant Fuel Comment On: NRC-2017-0236-0001 Preparing to License Accident Tolerant Fuel Document: NRC-2017-0236-DRAFT-0007 Comment on FR Doc #NIA As of: 2/8/18 1:56 PM Received: February 05, 2018 Status: Pending_Post Page 1 of 1 Tracking No. lk2-91bx-smur Comments Due: February 05, 2018 Submission Type: Web Submitter Information Name: Andrew Mauer Submitter's Representative: Anya Barry Organization: Nuclear Energy Institute General Comment See attached file( s)

Attachments 1/2 ~~ t.~, '3 3 02-05-18 NRC NEI ATF Letter 02-05-18_NRC_NEI ATF Letter Comment Table Summary_Attachment SUNSI Review Complete Template= ADM-013 E-RIDS= ADM-03 I). /,<J/aJt 7 Add= fJ-rJdrew frtf.i,H L :5Af.s.J https://www.fdms.gov/fdms/getcontent?object1d=0900006482eeefae&format=xml&showorig=false 02/08/2018 I

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ANOREW N. MAUER Technical Advisor 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8018 anm@nei.org nei.org February 5, 2018 Ms. May Ma Office of Administration Mail Stop: OWFN-2-A13 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Submitted via Regulations.gov

~I NUCLEAR ENERGY INSTITUTE

Subject:

Submittal of NEI comments on draft Project Plan to Prepare the U.S. Nuclear Regulatory Commission to License and Regulate Accident Tolerant Fuel, 82 Federal Register 60633, 12/21/2017 (Docket ID: NRC-2017-0236)

Project Number: 689

Dear Ms. Ma:

On behalf of the nuclear energy industry, the Nuclear Energy Institute (NEI)1 appreciates the opportunity to provide comments on the U.S. Nuclear Regulatory Commission's (NRC) draft project plan to license and regulate Accident Tolerant Fuel (ATF). Industry very much recognizes and appreciates the NRC's commitment to develop the ATF project plan and continue the collaborative dialogue that has informed the NRC staff's I

efforts. The industry is committed to the pursuit and development of ATF on a timeline that supports phased deployment in a commercial reactor in the early to mid-2020s. This schedule is of key importance in the decisions our members will need to make when evaluating the ATF safety benefits against the costs of adopting this technology.

Based upon our review of the draft project plan, we do not believe it supports ATF deployment within industry's desired timeframe. The development of the ATF licensing framework provides the NRC with the opportunity to transform the fuel licensing regulatory infrastructure, by applying a graded approach tailored to each ATF concept. A more transformational shift in the NRC's fuel licensing approach is needed and our comments are intended to facilitate changes that would bring the project plan into alignment with such an 1 The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on 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/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.

NUCLEAR. CLEAN AIR ENERGY

• Ms.*May Ma February 5, 2018 Page 2 approach. This will require a close collaboration and alignment between the industry, DOE, the national laboratories, and the NRC.

We support the NRC's assumption and recognition that independent testing is not required and would not provide a benefit for the NRC or industry. However, the project plan was constructed within the current regulatory infrastructure, and contains elements that are not warranted and would not enable deployment in a timeframe worthwhile for the industry to pursue. The lack of regulatory stability and predictability for the insertion of lead test assemblies and full reloads of ATF concepts severely limits industry's ability to innovate for enhanced safety and economic benefits. We believe that the near-term ATF concepts will be able to utilize the existing regulatory framework for current fuel products but the curreAt *.vcll established regulatory framework does not provide guidance for the longer-term ATF concepts creating *regulatory unpredictability.

Moreover, there is uncertainty in the time needed for NRC to develop independent computational models and tools. A truly transformational approach should be built on the considerable advances in modeling and simulation capability that have become available in recent years. NRC's memor.andum of understanding with DOE2, referenced in the project plan, establishes the opportunity for this to be accomplished.

Historically, the licensing of new fuels and cladding within the current regulatory infrastructure has taken

. upward of twenty years. These licensing timeframes are not reasonable for ATF,* given the concomitant benefits of increased safety andfleetsustainment (economic benefits), and an expedfted approach that enables deployment of innovative technologies is necessary to realize such benefits. The use of advanced modeling and simulation capabilities, which we did not have twenty years ago, will be essential. Advanced modeling and simulation could inform a graded approach to the regulatory requirements and facilitate ATF implementation by providing key support to utilities and vendors on design considerations, normal operation evaluations, and ATF fuel performance assessments. These advanced modeling and simulation capabilities

. can also prpvide support to the NRC for licensing reviews. By more closely aligning with DOE and national labs, the NRC can apply these modeling and simulation capabilities in a more efficient and effective independent regulatory review - one that is much more robust than the current approach of developing redundant modeling and simulation capabilities based on the same data sets. The use of these tools can reduce the time and cost needed to introduce innovative technologies into operating nuclear power plants.

An independent confirmatory process needed for a thorough regulatory review would still be maintained, reducing the number of time-consuming and costly experiments and demonstrations, while addressing one of the major hurdles in getting ATF to market.

Additionally, a number of process improvements should be made to the project plan so that it provides for a more innovative graded approach to fuel licensing. Each ATF concept is unique and should be evaluated on its own merits rather than being binned into broad categories (i.e., revolutionary and evolutionary) with limited development timelines based on non-specific lead time durations. The implementation timeline for ATF concept categories would help organize the project plan and determine what types of activities are needed, but each ATF concept should be independently reviewed to determine its own specific implementation 2Addendum to Memorandum of Understanding between U.S. Nuclear Regulatory Commission and U.S. Department of Energy on Nuclear Safety Research of Advanced Technology Fuels, 10/26/2017, ML17130AB15.

Ms~ May Ma February 5, 2018 Page3 schedule with considerations for whether key policy discrepancies exist and where regulatory infrastructure may need to be developed to support that particular concept's implementation. These determinations can and should be started immediately in order to support the alignment of industry development schedules with regulatory licensing schedules using actual dates for each concept..

The implementation of these transformative changes will enable parallel progress for several ATF concepts

• using a graded approach tailored to each ATF concept while leveraging the modeling and simulation work now available to the NRC. Industry supports the framework of the NRC project plan as a living document that is updated by the NRC with stakeholder input. Therefore, industry is providing the attached comments which illustrate key differences between industry's and NRC's vision for how the ATF program will be implemented.

NEI stands ready to work with NRC in furthering the dialogue to enhance the timely implementation of ATF and we look forward to routine dialogue with the NRC's steering committee going forward.

Thank you for your time and attention on this important matter. If you have any questions, please contact me.

Sincerely, Andrew Mauer Attachment c:

Mirela Gavrilas, NRR, NRC Andrew Proffitt, NRR, NRC

NEI Comments on Draft Project Plan to Prepare the U.S. Nuclear Regulatory Commission to License and Regulate Accident Tolerant Fuel

1. General (Assumptions)

3. General In the draft project plan of 9/6/2017, there was a fourth assumption that NRC would be appropriately resourced (staffed) to support the ATF research plan. This statement does not appear in the updated plan.

Page 1 of 13 Eliminate any discussion of near-term designs (existing cladding materials with new coatings) other than the general comments related to near-term designs in the first 4 pages of the document because these concepts should not require a multi-year implementation. Only the new physical, structural, or chemical aspects need to be assessed to ensure no detrimental impact occurs from their addition.

NEI Comments on Draft Project Plan to Prepare the U.S~ Nuclear Regulatory Commission to License and Regulate Accident Tolerant Fuel

5. General

7. General When discussing doped U02 pellets, coated cladding, or more advanced pellet or cladding concepts, it should be clear that the specific material description is an example of the concept.

The NRC project plan is not risk-informed. It starts off with this caveat: "The project plan does not cover existing licensing activities, as they follow existing processes for which schedules and regulatory approaches are well-established." The ATF project plan is above and beyond the existing licensing actions f~r conventional fuels.

Page 2 of 13 Clearly denote that specific materials discussed are used as examples of the technology and do not define acceptable materials for pellet doping elements or cladding coatings, etc.

For fuel concepts that are conventional cladding materials with an additional barrier (coatings) the licensing approach should use the existing licensing process to allow the new concepts to demonstrate their performance. We recommend that the NRC assure the degree of regulatory interest & concern is consistent with the amount of uncertainty and the potential consequence of performance uncertain.

NEI Comments on Draft Project Plan to Prepare the U.S. Nuclear Regulatory Commission to License and Regulate Accident Tolerant Fuel

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NEI Comments on Draft Project Plan to Prepare the U.S. Nuclear Regulatory Commission-to License and Regulate Accident Tolerant Fuel

11. General The document appears to address dry fuel storage Certificates of Compliance only and it omits wet storage of ATF in spent fuel pools. The project plan should include a review of regulatory requirements for storage of ATF in spent fuel pools and identify any changes necessary to allow stora e of ATF in the s ent fuel ool.

Page 4 of 13 A review of regulations for the complete life cycle should be considered for each ATF concept as regulations beyond power operation may be impacted.

NEI Comments on Draft Project Plan to Prepare the U.S. Nuclear Regulatory Commission to License

13. General and Regulate Accident Tolerant Fuel The project plan indicates that the NRC will.: "Identify whether, and if so what, regulatory guidance needs to be.

generated to accommodate licensing ATF designs under the current regulatory framework." The current guidance is based on Zr/U02.

The lack of regulatory guidance for fuel systems that differ from these prescriptive perspectives creates regulatory unpredictability and instability as demonstrated with the ATF LTA issue. The NRC ATF plan does not address the need to update existing regulations or regulatory guides to a higher level path addressing key safety goals rather than the existing prescriptive path for a specific fuel design.

This prescriptiveness of the fuel regulatory process severely limits innovation in fuel designs. Will NRC consider updating the current regulatory process as found NRC needs to update existing prescriptive regulatory processes and guidance to improve regulatory stability and predictability for future fuel reviews. The industry has conducted initial reviews and has identified areas where we believe changes to regulatory guidance are needed: We stand ready to sha.re the results of our initial reviews and provide input to the development of a prioritized schedule to move forward with the necessary updates.

in NUREG-0800 for more eneric fuel reviews?

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The readability of the plan should be enhanced. The organization of the document is confusing, and the.

document does riot contain a roadmap of its contents.

The document appears. to cover each major task twice.

The first 14 pages give an overview of the major tasks, including summary tables of each major task. Then each major task is discussed a second time, but in more detail, in the remainin Page 5 of 13 Near the beginning of the document, provide an overview of the document structure. Use labels and headings throughout the document to enable the reader to understand if he or she is in the overview portion of the document or in the detailed discussion portion of the document. Consider integrating the two sections so that each task is addressed onl once.

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NEI Comments on Draft Project Plan to Prepare the U.S. Nuclear Regulatory Commission to License and Regulate Accident Tolerant Fuel

17. General The GNF NSF experience where the NRC agreed to an expanded Lead Use Channel program is viewed as a best practice for accelerating experience while minimizing concerns over erformance uncertain.

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19. General Has NRC constructed a timeline that integrates Tasks 1-4 with the anticipated availability of data from DOE and industry research efforts? Such a timeline would be beneficial in assessing the reasonableness and scheduler risks of this Ian.

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Page 6 of13 Using currently available information, construct a timeline that integrates Tasks 1-4 with the anticipated.availability of data from DOE and industry research efforts.

NEI Comments* on Draft Project Plan to Prepare the U.S. Nuclear Regulatory Commission to License and Regulate Accident Tolerant Fuel

21. General (Mostly Task

4)

The document places a lot of emphasis on the development of NRC codes to model all of the ATF designs. This effort is duplicative of the industry efforts to develop codes to address the ATF designs.

• The industry does not see a value in Task 4 of the project plan. The NRC could, instead of developing codes to model the ATF designs, rely on the industry developed codes. The NRC could acquire the codes and supporting data from the industry

• and perform a detailed review, including sensitivity studies, as part of their review of the codes. This will result in both a cost and schedule savings to both the NRC and industry.* The document would need to be extensively modified to reflect the use of indust versus NRC codes.

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It is unclear who the MELCOR and MMP meetings and PRA meetin s are with.

Page 7 of 13 EPRI could support these analyses with review and comment b the vendors.

NEI Comments on Draft Project Plan to Prepare the U.S. Nuclear Regulatory Commission to*License and Regulate Accident Tolerant Fuel

27. Task 1 Lead times identified in Table 2 have increased from the 9/6/2017 draft. These increases*likely will impact industry timelines for ATF deployment.

Page 8 of 13

NEI Comments on Draft Project Plan to Prepare the U.S. Nuclear Regulatory Commission to License and Regulate Accident Tolerant Fuel

29. Task 2, Table 4, AND Task 2, Page 2, Unirradiated Fuel Transportation Package Reviews The discussion of transportation packages does not Revise the discussion of transportation packages to address transportation of enriched uranium prior to its include transportation of enriched uranium prior to fabrication into fuel assemblies. Instead, the discussion is its fabrication into fuel assemblies. Address limited to transportation of fresh and used fuel transportation issues with uranium in various forms assemblies. Also, the discussion does not address the enriched to greater than 5 wt%: Address the potential need for critical experiment benchmarks for potential need for critical experiment benchmarks enrichments greater than 5 wt% or for uranium in forms for enrichments greater than 5 wt% or for uranium*

other than those now in use.

in forms other than those now in use.

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The plan does not account for potential synergies between Please consider how ATF concepts may combine with other regulatory programs to impact plant ATF concepts and other regulatory programs.

0 erations.

31. Task 3 Page 9 of13

NEI Comments on Draft Project Plan to Prepare the U.S. Nuclear Regulatory Commission to License and Regulate Accident Tolerant Fuel

33. Task 4 As part of NRC's review of vendor methods, the NRC can develop sufficient knowledge of phenomena to make judgments of adequate protection without spending the time and resources to create yet another independent set of methods based upon the same benchmark data.

Page 10 of 13 The use of the tools now available to the NRC through their collaborations with DOE and national laboratories can reduce the time and cost of introducing innovative technologies into operating nuclear plants by reducing the number of time-consuming and costly experiments and demonstrations. The time and resource savings addresses one of the major hurdles in getting ATF to market

NEI Comments on Draft Project Plan to Prepare the U.S. Nuclear Regulatory Commission to License and Regulate Accident Tolerant Fuel

35. Task 4

37. Task 4 Analysis Capability Development

/ pg 10 The project plc1n indicates that NRC will not perform independent confirmatory testing for specific ATF designs, but, DOE and NRC have an MOU that DOE has said that they perform tests that NRC requests.

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Page 11 of 13 A parallel path for data should exist from the vendor to the DOE and NRC. The DOE path is information only for programmatic considerations.

NEI Comments on Draft Project Plan to Prepare the U.S. Nuclear Regulatory Commission to License and Regulate Accident Tolerant Fuel

39. Task 4 Analysis capability Development

/ pg 10 It is unclear what is intended by "and beyond DBA conditions" with respect to NRC licensing criteria?

Further discussion is needed. We recommend beyond design basis conditions be considered only if an ATF change resulted in a response change to a current re ulation.

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41. Task 4 (Page 10)

Th~ last bullet on Page 10 states that the estimated lead times to develop codes to be able to analyze all currently proposed fuel/cladding types range from three to six years. This appears inconsistent with the Tables 6, 8, and 9, which show the lower end of the range to be 24 months for near-term concepts Page 12 of13 The project plan should differentiate between the types of concepts to provide a high-level roadmap for the implementation of ATF concepts of that type.

It should denote that this high-level timing is meant to be guidance and not a prescription of the exact time durations for implementation as each ATF concept would be evaluated on a timeline specific to that conce t's technical and licensin attributes.

NEI Comments on Draft Project Plan to Prepare the U.S. Nuclear Regulatory Commission to License

43. Task 4.c: Analysis capability Development

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,Forthe near-term cladding technologies (i.e., coated Zr &

FeCrAI), steady state neutronics analysis of the reactor core is largely an effort for the fuel vendors to adequately introduce the nuclear properties (e.g., cross-sections) into the lattice physics methods to be applied.. Validation will be performed via high fidel,ity methods (e.g., MCNP).

Standard processes for lattice physics modeling of different materials are expected to be applicable. The need for an L TR to approve the application of the lattice physics methods may depend upon the methods applied and the specific material.

Page 13 of 13 By more closely aligning with t;)OE and national labs, the NRC can leverage the modeling and

. simulation (M&S) capabilities of their partners in lieu of developing their own redundant modeling and simulation capabilities based on the same data sets. The near-term ATF concepts would be able to use existing vendor and NRC codes with minor modifications; however, the longer.:term ATF concepts could benefit the most with a new advanced modeling paradigm that allows for accelerated implementation of innovative technologies. The NRC will need to develop confidence that these new advanced M&S tools can be used reliably in the regulatory process to

• evaluate* fuel and system performance. We encourage the NRC to work collaboratively with DOE, EPRI, vendors, and industry, to develop.

confidence to support accelerating licensing with CASL, NEAMS, and RISMC capabilities without the need for se arate NRC code develo ment.