Accident Tolerant FuelDeveloping an Efficient Approval Process

Kristopher CummingsSr. Project Manager, Fuel and Decommissioning

Jack GrobeDirector, Strategic ProjectsExelon

September 7th, 2017Rockville, MD

AGENDA• NEI Committee Structure for ATF• Regulatory Framework for Handling, Irradiation

and Storage of ATF Lead Test Assemblies and Rods

• Regulatory Framework for ATF Fuel Qualification

• Conclusions and Path Forward

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Desired Outcomes• A mutual commitment to develop an approach that will support more

timely fuel qualification and licensing for ATF

• A common understanding on use and implementation of LTR/LTA programs for ATF along with steps/schedule to formalize this understanding.

• Communication of industry proposed process for the development of an efficient and reliable pathway for ATF Fuel Qualification

• Common understanding of NRC ATF Project Plan

• Agreement to quarterly meetings between NRC ATF Steering Committee and NEI ATF Fuel Licensing Task Force3

NSIACGAAC

Accident Tolerant Fuel Working Group (ATFWG)Mission: Guide Industry Policy and Actions on ATF

Executive Sponsor: Joe Grimes, TVANEI Sponsoring Executive: Pamela CowanNEI Sponsoring Director: Rod McCullum

NEI Staff Lead: Andrew Mauer

EPRI ATFResearch Collaboration

Mission: Foster Research Cooperation and Collaboration

Al Csontos, EPRI

National Labs

Universities

International

CAC

ATF External Affairs Task ForceFunding and Schedule Acceleration

Andrew Mauer/Bruce Montgomery, NEITom Craig, Duke Energy Corporation

• Exelon Generation Company, LLC • Tennessee Valley Authority• Duke Energy Corporation• Entergy Operations, Inc.• Southern Nuclear Operating

Company• Dominion Generation • Arizona Public Service Company• Xcel Energy

• GE Hitachi Nuclear Energy • AREVA Inc.• Westinghouse Electric Company • Lightbridge Corporation• General Atomics• Jensen Hughes• Electric Power Research Institute• Nuclear Energy Institute

ATF Fuel Licensing Task ForceFuel Qualification to Deployment

Kris Cummings, NEIJack Grobe, Exelon Generation Company, LLC

Regulators

ATF Safety Benefits Task ForceRealization of Regulatory Benefits

Kris Cummings, NEIJohn Williams, Southern Nuclear Operating Company

Utilities

Fuel Vendors

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ATF Concepts Under Development• DOE down selection to 3 ATF concepts for their Phase 2

program:

• One design by Lightbridge under development outside DOE cost-share program.

• Si-C composite cladding• U3Si2 high density fuel

• Fe-Cr-Al cladding• Conventional UO2 fuel

• Cr-coated zircaloy cladding• Chromium doped UO2

• Metallic uranium alloy

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ATF Path Forward

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REGULATORY FRAMEWORK FORACCIDENT TOLERANT FUEL

LEAD TEST ASSEMBLIES AND RODS

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HISTORY • Handling, irradiation and storage of Lead Test

Assemblies and Rods (LTAs) has been implemented for decades

• Technical Specification 4.2.1 permits the irradiation of LTAs in the reactor core for:o A limited number of LTAs that have not completed

representative testingo Placed in a non-limiting core regions

• LTA Programs are an authorized activity in the facility license8

HISTORY – Cont’d • Licensees planning near-term ATF LTA programs have

scheduled meetings with NRR technical staff to discuss the program:o Southern (Hatch) meeting with NRR regarding Spring

2018 insertion of ATF LTAs with UO2 fuel and ferritic steel cladding in June 2017

o Exelon (Byron) meeting planned with NRR regarding Spring 2019 insertion of ATF LTAs with U3Si2 fuel and chromium coated zircaloy cladding in October 2017

• Several other ATF LTA programs anticipated9

IRRADIATION OF LTAs IN THE CORE• Engineering design control process under 10CFR50,

Appendix Bo Design and safety analysis supporting irradiating LTAs in the core

performed under the design control process

• Confirms the safety basis for the LTAs

• Authorized activity under TS 4.2.1o “…. A limited number of lead test assemblies that have not completed

representative testing may be placed in non-limiting core regions.”• Purpose of irradiating LTAs in the reactor is to collect data and validate

performance• Codes and methods do not need to have been submitted to NRC

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LTAs IN THE CORE – Cont’d• All facility design changes enter the station 10CFR50.59

processo Reactor core irradiation of LTAs is an authorized activity

under the operating license – TS 4.2.1

o 10 CFR 50.59 process is exited since further NRC authorization is not necessary for reactor core irradiation of LTAs

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LTAs IN THE CORE – Cont’d• 10 CFR 50.46 “Acceptance Criteria for Emergency Core

Cooling Systems for Light-Water Nuclear Power Reactors”o “Each … light-water nuclear power reactor fueled with uranium oxide

pellets within cylindrical zircaloy or ZIRLO cladding …”

o This regulation establishes the ECCS criteria for cores of fuel that are comprised of “uranium oxide pellets within cylindrical zircaloy or ZIRLO cladding”

o Therefore, an exemption to 10CFR50.46 is not necessary for fuel that is not “uranium oxide pellets within cylindrical zircaloy or ZIRLO cladding”

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STORAGE OF LTAs • Depending on facility design ATF LTAs will need to be

stored in dry and/or wet storage locations before and after irradiation

• As long as the design control process concludes that ATF LTAs/LTRs are bounded by the current analysis, they may placed in the storage areas.

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HANDLING OF LTAs/ PROCEDURE CHANGES• LTA programs may involve changes in handling equipment and/or plant

procedures:o Any necessary changes would be evaluated, reviewed and approved

under the facility design change process or procedures management process

o Changes in fuel handling equipment/procedures from that described in the facility Updated Safety Analysis Report would be evaluated under 10CFR50.59 to determine whether NRC review and approval of the change would be required.

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ACCIDENT TOLERANT FUEL FUEL QUALIFICATION

REGULATORY FRAMEWORK

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ATF FUEL QUALIFICATION ROADMAP

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Key Activities – Remainder of 2017• Alignment and stability of LTA Regulatory Framework • Development and Alignment of Regulatory Roadmaps with

NRC ATF Project Plano ATF Fuel Qualification (10 CFR Part 50) o ATF Fabrication (10 CFR Parts 70, 73 and 74)o ATF Transportation (10 CFR Part 71)

• Identification of Areas for Rulemaking

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Regulations• 10 CFR 50.46 – ECCS performance criteria for

non-zirconium/UO2 fuel• 10 CFR 50.68 – 5 wt% enrichment limit for the

spent fuel pool• Appendix A (GDC 35) – language specific to “fuel

and clad” and “clad metal-water reaction”• Evaluation of regulations continuing

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Conclusions and Path Forward• ATF provides a significant safety advancement to the current

fleet of light-water reactors• More timely fuel qualification and licensing is needed to support

approval and implementation of ATF designs by early to mid-2020s

• Near-term alignment and stability of LTA Regulatory Framework is needed.

• Continued engagement will be key to making progress

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Questions?

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Acronyms• ATF – Accident Tolerant Fuel• ATR – Advanced Test Reactor• CFR – Code of Federal Regulations• GDC – General Design Criteria• LTA – Lead Test Assembly• LTR – Lead Test Rod(s)• TREAT – Transient Reactor Test Facility

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