 Well, good morning everyone and welcome To those of you who have ventured out and joined us on this soggy Tuesday morning Thank you very much for being here and for those who might be participating and listening in through the webcast You might have picked a very wise way to join us here today And for those in the room, I would note that Commissioner Caputo is on her way We'll probably come breathlessly into the room momentarily but had to address an unexpected other matter this morning So she will join us in progress when she arrives But the commission convenes this morning to hear an update on the status and issues associated with the path to licensing What we've all termed accident tolerant fuel occasionally I hear it referred to as advanced technology fuel and other things that fit the same acronym But for the purposes of our meeting we're talking about what's termed accident tolerant fuel For use in commercial nuclear power reactors. This is not a new topic the agency staff has been very involved with operators and also with the Fuel vendors for a number of years now on this topic but the commission viewed that since this is a very active area it would be a good good meeting to have and just to check in to see how everything's going and and What the efforts are and any issues that the commission may You know need to weigh in on or bring to its own attention to we will hear from two panels this morning already seated at the table Are the participants in our external panel following that? We will have a very brief break and then we will hear from the NRC staff after that short break With each panel we will hold questions till the end and then we will Hear questions from the commissioners for the panel. So with that we will begin with our external panel But I will ask first if the colleagues who have made it to the room and aren't rushing up from the garage and elsewhere Have any remarks to make hearing none? We will simply begin with the panel's presentation. So I intend to proceed in the Order in which you all are listed on the public notice for the meeting that we've put out and you're seated So I assume unless you've arrived at any other agreement amongst yourselves We will begin with our interagency partner We will begin with mr. Andrew Griffith who joins us from the Department of Energy Office of Nuclear Energy Where he serves as the deputy assistant secretary for nuclear fuel cycle and supply chain mr. Griffith welcome and please proceed Great, thank you commissioner. Thank you commissioners for having me here This is a very important topic and and I think it's timely to check in with you all on our progress So I'm going to speak briefly On the history and background of the topic bring us all up to date Talk a little bit about our industry and other partners in which they will go into detail more on on their portion of the presentation And then wrap up with a a timeline and a brief recap So this challenge really started with Fukushima However, there were some technologies that were being considered before that I think reflecting back The uranium has irkloy fuel at the time had been optimized over decades of incremental improvements And it was perform performing at a very very high level. I think one of the things that The events at Fukushima showed us is that perhaps we can do better in the extreme conditions And also this was an opportunity to take a look at that technology and move forward Fortunately with the 2012 appropriations Congress agreed and they supported us beginning this program So the next slide recaps One of the first things we did at the time is define. What do we mean by accident-tolerant fuel? This is slide four so Looking at the range of conditions that were experienced at Fukushima as well as other Postulated conditions that could exist in light water reactors What types of things do we mean by the ability to? Tolerate or survive Add coping time etc in these extreme type of events And so this is how we defined it with improve kinetic reaction to kinetic since Besteem improve fuel properties improve cladding properties and enhance retention of fishing products And there's more detail on the slide These are pretty much held constant throughout the program so far and they kind of remain the the performance Areas that we look for improvement as we proceed Next slide slide five We've been fortunate and that we've partnered with a lot of really excellent organizations excellent people From the fuel vendors to national laboratories reactors owners operators Universities and our international colleagues Without this collaborative Partnership, I don't think we would be where we're at we where we are making I think solid progress and and making a Difference in advancing the technology for light water reactors and of course we couldn't be where we're at without the constant Engagement with independent regulatory oversight the NRC staff has been excellent in Asking excellent questions engaging in areas appropriate, and I think making this all better Next slide summarizes the Areas of focus for the three fuel vendors Clearly the evolutionary improvements that are now in play the coded cladding with dope pellets Those are those are making good progress. However, they're all pursuing a longer change longer range Technologies that could play an even greater role in the future next slide national laboratories Clearly the key Contribution from the Department of Energy We have a range of test facilities. They're Helping this program progress Not only creating long-term or Steady-state type of conditions for this technology, but also pushing them to the extremes of either temperature or Reactor dynamics transients The the accident-tolerant fuel program was the key driver for resuming operations of the Transient reactor test facility in Idaho National Laboratory and and It will be playing an absolutely critical role as we go forward also important are the advanced advancements we've made in post-radiation examination in Examining these experiments when they've come out of the test reactors The the range of technologies that we now have in play Help us not only Understand the performance of the the experiments that they're examining, but they also provide Significant amount of data that feeds into high-performance computers that will enable us to predict the performance more accurately Next slide slides So here's a range of contributions from our universities and our international partners Clearly the universities are able to contribute in early-stage type of Conceptual evaluation and development But they're also Help educate and prepare the scientists and engineers in our universities for entering the workforce in the future So we see this as a really double benefit to engage with the universities and this important technology Clearly nuclear energy is a global technology Engagement with the international community is essential especially if we're developing light water reactor Advanced light water reactor fuel Clearly there's global implications and the the clear potential for global deployment of this technology that again will contribute to the the better application of the technology around the world and we've gotten a lot of benefit I think from the Engagement of these international partners and they're questioning why we're doing what we're doing and so forth slide number nine Is a overview of the the schedule it it starts at 2018 several years into the program And I did a great job of capturing and summarizing The steps were currently engaged in and those steps remaining The hatch experiments were pulled out earlier this month The test assembly and they they're going to be I understand they'll be shipped to the Idaho National Laboratory at the end of this calendar year And that's just one example I think of the excellent teamwork between the industry partners both the the fuel vendors the utilities and our national laboratories clearly we have a Ways to go before we get into batch reloads and full core reloads, but we're learning a lot as we go and and Clearly NRC is playing a prominent role in in the schedule going forward as you see To wrap up, I'll be brief here. I think we've got a really good team. It's making good progress I can't overemphasize the constructive nature of the NRC engagement along the way. They're asking really hard questions clearly we have to Meet the standards to go forward I think we're making great progress, but but clearly we have more work to do Funding is always a challenge with federal government programs However, hopefully we can sustain continued congressional support affecting the integration of high burn-up and enrichment fuels is going to be a challenge and Then defining that final stuff of commercial deployment will be a challenge There's a there's a point which DOE has to let go and let industry take over and I think everyone in the program Recognizes that so thank you look forward to your questions. Thank you very much. Mr. Griffith next we will hear from mr. Pete Senna who currently is the executive vice president and chief nuclear officer for southern company He also is here or predominantly here today in his role as executive sponsor for the industry Accident-tolerant fuel working group. Pete. Please proceed. All right. Thank you and good morning And you know we very much appreciate the opportunity to brief the commission on the industry's development of accident-tolerant fuel an ATF really represents an innovative technology where Cycle efficiency and safety are coupled together and that these are not mutually exclusive concepts Next slide, please Now this is an overview of the ATF working group Established in 2016 and you can see it's comprised of utilities National labs fuel vendors and EPRI and essential to the progress is the independent research being done by EPRI and Neil Wilhelm health will provide a briefing next There are two main task force within the working group There is the external affairs task force and the fuel licensing and safety benefits task force Now the external affairs task force is essentially providing messaging to the external stakeholders media Congress on the benefits of Accident-tolerant fuel while the second task force is focused on the identification and resolution of Generic issues for the development and deployment of accident-tolerant fuel and really the biggest benefit the Generic benefit that we've identified by these efforts thus far is the utilization of higher burn-up and higher enrichment Which is really enabled by the safety enhancements of accident-tolerant fuel Our goal is to deploy batch reload quantities of ATF with increased enrichment by the mid 2020s Next slide, please You can see this is a little bit of a busy chart But you know there are essentially five different applications of accident-tolerant fuel Test leads installed today between Southern Company Entergy and Exlon with all three vendors All with various combinations of dope fuel pellets and coated cladding The next major milestone will be the submittal of topical reports later this year NRC approval the topical reports will pave the way for the industry to then submit the licensing documents to support the battery loads There is a path forward here But it's predicated not just upon the research and testing but also upon the regulatory clarity predictability and stability Now we do appreciate that the NRC staff is working on potential transformative changes to the NRC's regulatory framework and culture and infrastructure So that the agency can be more agile in adopting to new and novel technologies such as accident-tolerant fuel And in particular, we do want to thank the staff for their work on issuing the coded cladding Coated cladding interim staff guidance. We believe that this ISG does provide the necessary guidance to the industry To assist in the development of the topical reports But it's also equally critical that the staff stick to the guiding themes of the project plan That states that no confirmatory testing outside of the poster-rated lab testing is needed per the Project plan the NRC has adopted the position that near-term ATF actions can move forward using the exemption process Should widespread adoption of these technologies become apparent the longer-term strategy of rulemaking would be needed for more predictable and stable licensing process Historically the fuel licensing process has been a 20-year evolution Now there have been considerable advances in modeling and simulation capabilities to allow for the safe accurate and timely review of the design specifications and testing and thus allowing for the timely deployment of ATF within the next five years Next slide please Now you can see here the benefits enabled by ATF can be grouped into the following broad categories Whether it be enhanced fuel performance improved coping times enhanced fuel reliability improved operational flexibility improved fuel cycle optimization The improved safety margins of the ATF concepts would then allow for the increased burn-up and enrichment and then thus reduce Reload sizes reduce spend fuel-pull waste and now plants to cycle to transition to a 24-month cycle Next slide please now you can see here At or a hatch plant After two years of service the lead test assemblies that plan hatch have now been removed and they will be shipped to Oak Ridge Not Idaho this coming fall the lead test assemblies from Plain Vogel will then also be removed this fall several of the test assemblies will remain at Hatch for a next operating cycle for additional irradiation In in closing To support the deployment of ATF in the mid-2020s it will require sustained Coordinated and well-managed effort between the industry NRC and DOE and I truly believe that we have an awesome opportunity in front of us But only if we all embrace it. Thank you Thank you very much next on the panel we will hear from Neil Wilmshurst who is the vice president and Of nuclear and the chief nuclear officer of the Electric Power Research Institute Neil welcome and please proceed Thank you. Good morning. Thank you for this opportunity As Andrew said this accident tolerant fuel effort really has its basis coming out of Fukushima and is really one of the Long-term actions and one which is being engaged in globally and certainly the work being done in the US is being Watched globally and I can tell the Commission that EPRI is fully engaged Globally in the accident tolerant fuel work and was certainly very engaged with IEA and OECD NEA in this work And as I was preparing for this I read a paper that one of my one of the team Who's actually in the room here today wrote and I thought was appropriate to quote it the ideal ATF? Will improve plant safety while also reducing plant operating costs, and that is really the context that I'm coming to this briefing with and Really consistent with what Pete and Andrew have both said I think the progress to date Shows that that objective about improving safety and reducing plant cost is Very likely achievable through this ATF effort. So next slide please so The discussion they'll give insights into where we are and what needs to be done to bring this effort to conclusion As Pete just said the near-term concepts of being tested for deployment in the mid 2020s and this today It has been a substantial collaborative win between the DOE the utilities EPRI NRC the vendors Where tremendous? probably Unprecedented in some ways progress has been made in the time frame so we've come so far So I really want to give credit where credit is due to everyone who has been involved in this So the benefits So we have run Simulations done studies and analysis to show that the concepts that are being deployed and that are being tested in some of Pete's plants Will well very likely have an increase in safety talking about increased coping time in a case of loss of cooling of Maybe two one to two to maybe three hours and that at first sounds short but in those situations one two or three hours can make all the difference gives time to deploy flex equipment give times to take Compensate reactions and we're shown from analysis a reduction in CDF over the order of 10 to 15 percent With no additional actions and maybe an additional 10 to 15 with mitigating actions. So My message would be there is safety benefit in these early deployed Technologies even though we may at first blush say one to two or three hours that doesn't seem much Other benefits were seeing Increased operational safety margins by virtue of the fact of the materials being used Potentially the fuel is more reliable due to greater debris resistance And also the fuel is fun could be fundamentally stronger to support more flexible operating strategies So those are what we're seeing already studying the concepts that are being tested so next slide, please But the challenge is Deploying ATF Will not be a low cost the current fuel is accepted as safe and the widespread Adoption of ATF will need an economic driver To put it simply if there's no market then won't be supplied for it So that really is the question which peaked it up very well is If we believe the safety benefits are there what can be done to bring a Economic driver to enable the safety benefits to be realized. So next slide, please So we have done some studies working with our industry partners Looking at the impact of higher burn-up and higher enrichment Utilizing the benefits of the ATF design which All indications are will be fundamentally stronger and more reliable when deployed This shows the benefit of looking at enrichment above 5% Maybe as high I believe the numbers were talking fire up to Five to maybe six seven eight percent Better fuel like utilization getting the fuel cycle costs down due to that improved reliability Reduces the reload cost reduces the throughput of fuel assemblies give longer cycle lives And that there are hundreds of millions if not billions of dollars of fuel cycle savings The industry could realize if The combination of high burn-up and high enrichment with the ATF technology was deployed So that is the opportunity. I think we need to look at As a as a group of people collaborating on this effort to see how we can bring High-end at the ATF fuels to fruition. So next slide, please And the ultimate thing that does that deploys Accident tarot fuel with the safety benefits and the economic benefits which should Support the sustainability of the current fleet So next slide please So what is EPRI done? Pete referred to the research. We've done to support the discussions We've looked at those feasibility studies and accident tarot fuel produced reports on the effectiveness of the cloud of the coated clads and Technologies like that. We've done Economic analyses on the high burn-up high enrichment and documented those and we've hosted many technical workshops So this work has really informed the discussion and if we go to the next slide, please again giving credit where credit's due our work has informed the NRC staff and Actually our work on coated clads Supported the NRC staff guidance and coated clads which gave regulatory confidence to the vendors and the utilities to move forward So again, this work has been a Very strong collaboration across all the stakeholders and is Shows all the hallmarks have been able to continue to actually move this different deployment further forward So next slide, please This is a slide we showed last time I had the pleasure to brief the commission over the traditional means of Studying accent of studying fuel and deploying fuel shows about 20 years to get the fuel land and We were discussing last time I was here the benefits of a parallel path to actually work these Ideas and concepts in parallel with the benefits of utilizing Modeling and simulation technologies that are now mature The progress to date shows that that approach has worked All the parties have collaborated together and we've actually got to position where accident-tolerant fuel technology is close to deployment The potential is there for this parallel path to work working on high enrichment high burn-up and I would Urge us all to look at what we can do to work in a similar framework around high enrichment at high burn-up next slide, please and Again, this is a slide. I showed last time To show on one picture the what I'll call the early deployment Fuel technologies and then the fact the later deployment fuel technologies You'll see the later deployment fuel technologies which have greater safety benefits The bars are red. Those are showing that the tech that the work and R&D and the gaps are greater in those technologies There are big benefits from going to the later deployment technologies But we should all remember that there's a lot more gaps to close a lot more work to be done to get what I'll call the ultimate prize which could be Realized from the the later deployed Options and my final slide, please so inclusion in conclusion The near-term ATF and high in it high enrichment high burn-up has safety and economic benefits We still have to all work together to actually do the research needed to enable that deployment and the the benefit of the longer-term deployment of the More advanced technologies will need us to continue to work beyond the mid 2020 time frame We've talked about to actually get the the final prize of the the bigger safety benefits. Thank you Thank you very much Neil for the final presentation on this panel the commission will hear From dr. Ed Lyman who is the director of nuclear power safety for the Union of Concerned Scientists Ed welcome or welcome back. Please proceed. Good morning and once again, and we appreciate the opportunity to brief the commission on This very important topic So may have the second slide, please So we heard from the previous speakers about that accident-tolerant fuel development is a There are two potential Sides to it one is improving safety and increasing safety margins and the other is improving reliability and economics for the industry as Mr. Griffith pointed out the original Consolidated Appropriations Act that only specified that this was enhancing for enhancing the safety of light water reactors But the industry has made it pretty clear that their priority or To put it mildly is Improving their economic performance and I provide the quote from mr. Holtzman from NEI that said there is no safety imperative For why we're going to be implementing ATF So that concerns me now the nuclear energy innovation modernization Act NEMA has Redefined centrally congressional authorization for what accident-tolerant fuel is so that it covers both But it's still unclear to us that they can be realized at least At the same level and I do appreciate mr. Sena saying they aren't mutually exclusive, and I hope that's true next slide, please So we do believe the primary purpose and focus of ATF fuel is to increase reactor safety margins And since the taxpayers have been Funding some of this work through the Department of Energy. We think that that's That's really the public's goal rather than enhancing the industry's bottom line And our concern again is as I discussed two years ago is we're worried the NRC could undermine this goal if it undertakes measures that try to Qualify and deploy this fuel too quickly before the safety analysis has had a chance to catch up So if the licensing standards for enabling the program to go forward continue to Take shortcuts We're concerned about that if batch loading is approved before Obtaining and reviewing sufficient and representative safety data Both under normal and accident conditions has been performed there could be risks and if credit For ATF for reducing safety margins in other areas for the economic benefit of the industry is granted It could end up being a wash or even reducing safety next slide, please So I won't reduce I won't won't repeat These numbers which we also heard from EPRI just now But you could look at these in different ways that these are actually the safety benefits are fairly marginal So far in most cases and I would read from an EPRI a document that was presented late last year Where it said it is noted that at the time these analyses were performed that was coping time studies These results were considered surprising as industry expectations had been that ATF would be capable of extending These coping times by much larger amounts. So it The benefit seemed to be more modest than originally anticipated and that's fine But one should also recognize that maybe there isn't as urgent a driver to deploy them In addition to the Studies that have done analytical work there are also issues associated with reduced safety or increased uncertainty in the performance of some of these materials for instance as the Interim staff guidance on coded fuel points out if the Clad coatings are delaminated or if there are interactions between the clad and the substrate Those could those introduce new mechanisms of concern and also if you're looking at more advanced fuels other than uranium oxide There's a breakaway oxidation of the psilocides and nitrides, which is the reason why from atom is not pursuing Alternatives to uranium oxide fuel. They're only looking at new cladding's in their own program next slide So The the economic benefits to industry think we're still seem unclear It seems like there's been a bait and switch since this process started that originally the motivation was a greater safety And now it's trying to increase enrichment burn up For economic benefit again, that's okay, but there has to be a documented safety case for that And it's not clear looking at the numbers that any eye has generated that The the actual benefits are going to be that significant on a per reactor basis We also are concerned that the safety criteria may have to be changed to enable some of these features to be credited and In addition to the what I pointed out in the slide that every has said You may have to go to a cladding strength criterion to evaluate certain accidents instead of the current minimum Departure of nuclear boiling because otherwise the benefits of ATF wouldn't show up in the regulatory analysis And the eye has also pointed out that to get the full benefit of higher enrichment and higher burn up They may need more aggressive changes to design limits to obtain that full benefit Including peaking factors moderator temperature coefficient shutdown margin as one so Again, we are concerned that That the focus has to be on increasing safety margin that's what the public and taxpayers paid for and The the any economic benefits to the industry should be secondary next slide please So in that context, what is the rush? We think the timetable for batch loading of ATF by 2023 is unrealistic and may compromise safety that the Lack of any real specific and standardized testing requirements raises questions Traditionally you would want to have at least Some LTAs and representative conditions in a reactor for the full Campaign the full number of cycles and burn up that you're planning the batch loading for in this case There's going to be an overlap between batch loading and LTA Radiation and again that could be okay, but it would put me in an are seeing a difficult position if it if data suggested that the industry would have to Pull the batch Because the data does not support safer radiation for another cycle and the industry of course would have to pay Or provide for alternative fuel for that cycle That's the risks on the industry, but the industry should be wary of that and again We think there should be pretty well-defined standards for Representative fuel radiation to the burn up and also at the enrichment that would be used for the batch campaign And that so that that fairly long process as we know Could take more than just a few years that we've already had for LTA radiation and Then PIE and then there's the issue of transient and local testing And no one has mentioned the fact that the Halden reactor shut down Really disrupted the original timetable for LTA development except the schedules haven't seemed to change and it's not clear that capability will be adequately compensated for next slide, please So so There are a couple of things the industry is also pushing the NRC to do the staff did not agree to do them and in In revising its interim staff guidance on the coded fuel and we support the staff on those We think that the the fuel integrity Needs to remain a fundamental safety objective and also that the NRC certainly should Have the opportunity to review manufacturing parameters for coded fuels because of the The potential sensitivity of the fuel performance to the way the coding is applied So we we think that's perfectly reasonable next slide, please I I Brought this up two years ago. The Commission still has before it the 5046 C Draft rule and it would seem that approving that rule would help to clarify the And in fact enable the ATF vendors to get the credit for the main benefit of For instance the coded cladding which beat would be to reduce Oxidation and hydriding at high burn-up so This would provide a the structured process instead of having to go to exemptions For evaluating this fuel and we would urge you again to approve that rule making in a timely fashion next slide, please UCS was disappointed that the NRC staff followed through with issuing its LTA reinterpretation that Allowed for LTAs to be used or to be deployed without necessarily seeking review on approval from the NRC or applying for an exemption we there are a number of staff who objected to that reinterpretation and we Stand by those comments So we believe that licensing approaches for anything but also for accent tolerant fuel should maximize Opportunities for public input and that means favoring rule makings and license amendment requests and Formal topical report reviews instead of more informal processes or things that the public does not have any opportunity to actually Participate in with regards to the licensing process and with that I'll stop and I apologize again for exceeding my time Thank you very much. Dr. Lyman and thank you to all the panelists for their presentations We will begin the questions today with Commissioner Caputo. Good morning. Good morning Thank you all for coming Mr.. Senate The scope of work needed to support the industry's goal of batch loading in 2023 is Substantial what activities do you think have the potential to delay achieving that goal? Well to me we have the testing regimen already established we have Alignment between the industry and the staff on The ISG topical reports to me. It's the predictability of the regulatory process So I think the technology is there It's really about can we jump through all the hurdles all right and not just on the regulatory process But on the fuel manufacturing to there needs to be that certainty from the fuel manufacturers that they have customers For the customers to be there. We need to see the regulatory process with predictability So is that a matter of making sure that there's a timely review of the topical reports? So the industry can file license amendments to a batch loading correct because we're looking at 2025 So there's a little bit of a chicken and egg there with you folks filing license amendments on the utility side and Fuel vendors making investments to proceed. Okay, and How long do you expect to or have we said how long we anticipate review of those license amendments to take? Give that to you. What's the time when? I had 12 to 24 months On the topicals Okay, okay. I'm trying to think through I know there's a timeline for So if we're looking at topicals by the end of 2020 right and review completion at the latest the end of 2023 Which then allows for the license amendments The fuel cycle facilities will need to be filing amendments to modify the plants prior to that. That's correct there are This is not an easy process You know to be clear and it is just it is multifaceted and the more predictability we have In the regulatory process. I think the more predictability we can have between the licensees and the fuel vendors Okay I would like to say it's you know a plus b equals c but it is just it's I think this is more things are more of calculus and Obviously this becomes with topical reports being one of the first Points, it's incredibly important that the vendors are turning in high quality and that's on us. Correct. Okay Mr. Wilmer's Do you from what you know of our research efforts here at the NRC? Do you for near-term ATF technologies? Do you believe our research efforts are sufficient and proceeding at a pace to support? these licensing reviews With a goal of batch loading in 2023. I Don't have the up close Information I'm going to call Al Santos, please if you're in the room now to answer that with the I'm sorry Could you introduce yourself? And so the answer is yes with caveats Just to watch what's being done with the project plan that NRC has created and we looked at that reviewed it everybody in the industry as well as every and Also with the ISG we feel confident that we have a path forward here, but it's just what happens Downstream as more information comes in are there new items that come up, but yes, we are aligned Mr. Griffith and Perhaps mr. Sonna, but I'll start with mr. Griffith So you listed a number of testing examination facilities available at national labs I know mr. Sonna mentioned that the first LTAs are out of hatch As far as the rest of the LTAs go Where and when do you anticipate doing the testing examination of those? lead test assemblies well while Mr. Sena corrected me in saying that the first one was going to Oak Ridge National Laboratory in Idaho The long-term plan does include our facilities at Idaho We have Compliance challenges that we need to address there that should be addressed By the end of this calendar year or early into the next calendar year What do you mean compliance challenges so there is a facility Integrated waste treatment unit that needs to process Certain amount of waste Before we are allowed to bring in spent nuclear fuel into the Idaho side as part of our compliance agreement with them Once that is Satisfied, we will have an opportunity to bring a range of other Follow-on experiments or lead test assemblies in Idaho for post-radiation examination Okay, I'm as a follow-on question My recollection is there were Challenges associated with getting lead test assemblies shipped to the plants because of lack of canisters Now we're going to be talking about canisters or shipping irradiated lead test assemblies. Do we have canisters available? Certified for this There there are Truck qualified shipping containers that are available. It's all a matter of lining up the schedules Yeah, we don't see an issue in shipping can any of your test assemblies for the first one going out from hatch this coming fall Okay, so we have approved shipping containers for irradiated. That is correct. Okay Mr. Sana Dr. Lyman stated in his slides that NEI has requested the NRC weakened deterministic standards for ensuring fuel and cladding integrity. I Believe this is a reflection on a public meeting that was held at one point Would you please provide some additional clarity regarding any eyes comment that he might be referring to certainly if I can just Yeah, just provide some color Yeah, I grew up in Long Island And I was within 10 miles of the shawrm EPS a waiting river school district So in the 70s, I recall all the angst about shawrm being licensed and in the end local lost the public trust of Suffolk County and to me that was the death knell of that plant and Yeah, as I operate Vogel Farley and Hatch You know, I look at those as my plants my people my local community And I'm not going to put my plant my people my local communities in jeopardy in Augusta, Georgia Vidalia, Georgia or Delta in Alabama So we the industry are not advocating regulatory shortcuts or weakening of standards We're looking for regulatory predictability and efficiency. This is not the 1970s okay One last quick question for mr. Wilmshurst just a little bit of a clarification you mentioned flexible operation and operation flexibility What exactly is that a reference to and mr. Son of China and if you choose to I'm guessing maybe load following Are there other aspects though? That's really that's really a load following and some of the transients that may be predicted at the fuel Could be more More sustainable with it with the increased Strength of the new cloud material. So it's really reference to the flexible operation Okay, that's all I have. Thank you. Thank you very much. Next. We'll hear from Commissioner Wright. Please proceed Thank you So first of all, thank y'all for being here today Couple weeks ago. I was in Knoxville at the advanced reactor summit and it's quite impressive. There's a great collaboration going on people Government at you know academia. They were all there and fully participating. So that was that was good to see And since you are our guests from another agency, mr. Griffith, I'm gonna start with you It's my understanding Is that DOE is also supporting the appointment of high SALE fuel for advanced reactors how if at all Do the two efforts ours and yours And form each other and can you provide me maybe some examples of where the two? Intersect or overlap That's a good question. I think there's a lot of synergy between the two programs especially with our Potential for deploying advanced reactors into the future for with high-assay low-enrich uranium in the near term the accident on fuel provides an opportunity to Touch all those Regulatory technical Logistical steps for Considering greater than 5% enrichment both in fresh fuel and in spent fuel transportation and The fuel supply chain if you will So I know the the one enrichment Operation in the u.s. It's Operating that they have plans if they I believe they've already engaged with NRC formally to increase Their enrichment Capability there in order to meet the expected demand for accident on our fuel Beyond that it gets into the closer to 19.75 percent enrichment for the future and so I think in the near term exercising the process will pave the way for Addressing the longer term So, um, thank you for that. It was recently announced also that DOE's office of nuclear energy was funding a collaboration between Fram at home and general atomics to develop nuclear reactor channel boxes for BW ours Using the silicone carbide composite so given that this technology was originally developed for Advanced reactors, but is being applied for fuel design for the current fleet. Do you see? other future opportunities for your office to get involved in funding and development in this area I Do I think both from a fuel perspective as well as the structural aspects of extending the The lifetime of the existing fleet presents a range of opportunities Thank you Mr. Senna How are you this morning? So you're the one licensee at the table and I'm curious about your view on Other potential licensing impacts that the the panel has a discussed The staff identified in its draft fuel burn-up and enrichment extension preparation strategy that there could be an impact on the staff's Environmental review specifically with continued use of the generic basis presented in the The guise for license rule so have you engaged the staff on what those impacts might be and I guess if so Can you share how that might factor into your decision-making going forward for deploying? Yeah? I'm gonna have to John John John Williams is my director of nuclear fuels. Let me just defer to John Hey, good morning. My name is John Williams. I'm the director of nuclear fuel and analysis at Southern Company So yeah, we have engaged the staff and we had a public meeting about the generic exemption And I think right now the industry and the staff are aligned that that that can continue forward and we're in dialogue with You know, we'd be open to any conversation with the regulator if if that that changes, but at this time we believe it's appropriate Okay. All right. Thank you So also, mr. Senator one of the things that we've heard from any eye Before is that there should be a larger role in modeling and simulation So we'll and I know we're gonna hear more in the second panel about this too On their approach. Can you share maybe how the industry is using modeling and simulation to expedite the license and process? And what efficiencies if any have been gained and again, I'll have to defer to John my nuclear engineer So really the intent of the modeling and simulation is to inform our test as you know We're working on an accelerated timeline and therefore it's it's going to be critical that the test that we perform Get us the the answers that we need and so the purpose of the modeling and simulation is really to to give us the Where where do we need testing and and make sure that that's very informative and very focused. All right. Thank you Coming again So southern company's been on the leading edge as far as accident-toler fuel With hatch installing ironclad and armor lead test rods so and Vogel to installing the world's first Complete so have a couple of questions concerning that. Have you having been the first and involved in this process the longest? Are there any insights you would share for future licensees? See I told you I Think you know we are encouraging our our peer utilities to to pursue a tf I think that some of the things we've learned being first, you know, we did have some shipping concerns with with the hatch LTAs and so I think the learnings that we have had is to Want engage with the staff early and often make sure they are aware of what you're pursuing And and what your plans are so that that we can both be aware of the concerns and address those in a timely fashion Okay, don't go anywhere. You might need you again so the last question that I have would be that For you is at whether the NRC's clarifying guidance on lead test assembly Which was issued last year increased predictability on the licensing process and are there areas where maybe further Clarification would be helpful So, yeah, we do believe that did provide the clarity that was very helpful for the LTAs With respect to other licensing areas where there would be helpful if Rulemaking around 5068 if that were to proceed and were initiated by the staff That would be very very helpful because we do see that as a as a challenge for us. Okay. Thank you You had a good job Mr. Wilmhurst with the time I have left here My final question was is going to be this so my my understanding is that Epri has has developed a series of reports You know that highlight the safety benefits of ATF so Today I think you implied that Epri's also considered maybe the economic cost of ATF So this question has maybe three parts to it Has Epri also considered the potential downsides of ATF other than perhaps cost And if so, do you plan to issue reports on the topics? or revised existing reports and then the last part of that would be And are there any downsides that would affect the NRC's review of ATF? Very good questions, which I'm going to refer to mr. Santos, please So I'll if you could go to the podium, please I Alessando separate. Yes, there are some downsides Neutronics penalty is one of them, which is a it can be a cost inhibitor to to adoption, okay And as research and their second part of your question as research evolves as we get more information from the LTA's and other things You know things may pop up that we may need to go follow up with so that's kind of what I was saying earlier Is that as we follow up with these pie examinations post-radiation examinations? Other data collection efforts that we get from lead tests for assembly You know testing there may be things that we have to go and follow up And that's just something that typically happens with sure product development Thank you very much He'll back Thank you very much. I have a few questions for the panel perhaps I'll begin with you mr. Griffith although other panelists may have a view on this I had a note here about Halden of course dr. Lyman mentioned it specifically, but the I think many of us expected Halden to be operating for a number of years It is only one Part of the infrastructure that supports this type of work, and I know that DOE is Seeking Congress's support for the versatile test reactor and and other items in their budget So that there is at least some requested effort to enhance the R&D Infrastructure in the United States to do this type of work Can you talk at all about kind of some of the atrophy over the last 10 or 15 years in the? laboratory in R&D infrastructure for doing nuclear work of this kind and how you see a Halden's Closure kind of playing into that and then maybe measures that the national labs and DOE have on the horizon to Address it. Do you still think that that getting to batch loads in 2023? I think is possible with Halden's demise We're yes. I think it is We are working to incorporate some of those test capabilities that were lost when Halden shut down Into our programs in the Department of Energy Specifically transient testing for at the treat facility is in the works There is key testing capability that we need to use the advanced test reactor for which will require some adjustments to that reactor during critical phase and its Maintenance cycle if you will in 2021 we have a core internals change out scheduled which is just a routine replacement of the Structural components in the advanced test reactor that receive high dose over its lifetime those components are replaced and that presents a window for us to Incorporate some important test capabilities that would Replace the Halden capabilities if you will and the key component. There's the top head plate on the pressure head which will enable some Experiment experimental loop to be incorporated in its capabilities. So We're working hard to incorporate that The advanced test reactor is an absolute vital Capability that the Navy reply relies on and so we are Doing appropriate diligence to make sure those capabilities don't interfere or Impact the Navy data collection process Well, thank you for that and I know Obviously from my time in Idaho that ATR has been an absolute workhorse for the United States for a long period of time But there is important other national security work to be done there. So which cannot be Displaced so thank you for that and I know that those efforts could probably consume their own meeting And it's it's a substantial ongoing focus for DOE and for the entire nuclear enterprise On Neil's slides don't appear to be numbered But he had to this slide he had presented previously and it has kind of the old model and the new model on the old model Took 20 years, but I know ever since Secretary Rumsfeld used the phrase just kind of overused but the unknown Unknowns, but you know what you got in that old system took a long time, but you have a lot of Data and testing that you did and you had a lot of knowledge Before you excused my language potentially fouled up, you know a really expensive asset like a power reactor With something that you know could have unknown unknowns It was kind enough not to use that phrase, but the other behavioral degradation that could possibly emerge I mean, it's a it's a big thing to foul up a reactor again, those are not insignificant assets so I Guess my question is you know knowing that I'll I'll pick on Pete though Those are your assets you've talked about them and you know you view them as yours So you don't want to put something in there that you're not sure about how are you balancing those uncertainties as an industry operator? well, it's It comes down to they are a billion-dollar asset, so that's why we're asking, you know Research but from the regulator, you know strong reviews and so it's a So how much do you need to know and it's all about the modeling the capabilities that we have today Are they sufficient? Well, what's the level of reasonable assurance that we all need? Together you need it. I need it and so collectively it's it is a very good question I can't give you a generic answer that this is good enough So we have to be sure and that goes back to you know with the industry will not advocate You know any type of regulatory shortcuts, but again What do we know today from the lessons learned from the 70s from that 20-year process on what can we apply today? Just because we did it in the past doesn't make it right for the future either Well, and as your presentation and others acknowledge though and I call it kind of the continuum of exotic You know there are friend in an accident tolerant fuels There are things that push the boundary of our current knowledge and experience less than other things and the other things as some of your Presentation seemed to indicate some of the more exotic things on the higher end of the exotic continuum in theory based on your kind of computations and calculations may actually yield you, you know the the increased robustness slash kind of safety margin Enhanced coping times and things like that, but also might help you with your your economics, so I You know that's an unknown unknown for our staff and I guess I just want to put that out there So it's appreciated the difficulty. It's not just resistance for regulators It is okay We used to be able to have access to this amount of data and I I take the argument first of all that something shouldn't take 20 years, I mean I'm not crazy, but but second of all that That doesn't mean we needed all that it just means that we're accustomed to having all of that and the certainty or enhanced Certainty that that can create for us So our difficult thing is we've got to navigate How much of that might be extra and might not be needed? So we just you know appreciate that it isn't just a failure to want to be open to new things It's complicated for regulators just like it's complicated for you not wanting to follow up a really really expensive machine So together we've got to navigate that and it sounds like we are having the right discussions I think there's also this philosophical undercurrent while interesting I don't know that I should take a lot of our time with it but but this program as I think every panelist recognized had its origins in Fukushima, but Something can have its catalyst in something like that, but that doesn't mean that as it moves forward it Becomes still centrally about having fuel that is more robust and and safer and let me be clear You know my view is if the regulator views the current fuel as safe Which we obviously do because it's being used at every actors across the country if we're not going to mandate something Then a whole set of other inducements have to come into play It has to be you know something that demonstrates its value in the marketplace I guess a curious philosophical question is if you could have this Enhanced fuel of enhanced safety which is such a hard thing for me to say as an engineer because it's not really defined But if it were more robust and gave you the increased coping times and it costs the same as the fuel you had now This is completely theoretical. I assume you would do it because it would be better fuel if it had enhanced coping times and was safer so so I Do think that there's some peril in keeping to talking about this as it has to improve economics I mean if the truth is if it were the same cost and It allowed you the increased coping times. I think you would still purchase it I guess I shouldn't answer for you That goes back to just the operating philosophy of the u.s. Nuclear reactor fleet, you know So if there's always opportunity to improve safety margins, we do it You know and that's if we have an opportunity to deploy the accident tolerant fuel Just to improve safety margin, but at no increased cost. We would do it as a regulated utility I have a prudency review with with my public utility commission and so I would have to present to them And again, yeah, I mean if we don't mandate it then it has to be something that you freely elect to do I Will say though that it would seem to me just on basic kind of thermal and Radiological phenomenology for materials. I'm not a material scientist, but this isn't a complicated thing I'm about to say but you know, we begin to challenge the materials when we go to the higher burn ups and I understand that drives the economics But I'll go back to my kind of speaking for the NRC staff Which I also shouldn't do and they'll have an opportunity shortly to speak for themselves But their difficulties they're being asked to yield a little bit on margin To make it something that you all would want to deploy and have a reason to deploy because we have not found a basis to Require it so we're not making the industry have different fuel than it has now So that's a part of the balancing of factors and the tug of war and kind of accepting risk and yielding Unsafety margins that the NRC staff has to do to find this sweet spot of a review that doesn't take 20 years of an amount of Physical or testing data that is not as much as they used to have so this is really like you said It's not a plus b equals, you know see it is a multi variable equation We have different coefficients than you do and we will each arrive at these decisions differently, but I Do think that fuel is like anything else and there's opportunity for innovation based on the US operating this many reactors for this long I do think that a 20-year approval process has had an artificial Locking in in time of the types of fuels we use now and that there is a Possibility to have better fuel and more economic fuel. I think they can coexist I guess that would be my answer to dr. Liman's question, but how and what it looks like and how much the economics drive the question versus the improved Safety are something that NRC is gonna have to keep front of mind And then we don't ultimately yield so much safety margin in a qualification of a new fuel Whatever you want to call it accident tolerant or not that we actually end up with kind of less Safety rigor around fuel than we had that would be in my mind a very very odd outcome from Fukushima So that's all say about that and I'll turn it over to Commissioner Baron Thanks. Well, thank you all for being here and for what's been a good discussion I want to start there's been a lot of focus on the timelines of how this all plays out I wanted to get a little bit of clarity about that My my understanding had been that the industry goal was to do batch loading in 2023 There's also been some talk today about mid 2020s like 2025 for batch loading of higher Burnup higher enriched Fuel ATF Are those two separate targets? Are these the same target? Are you envisioning that someone is gonna batch load? I'll call it regular, you know, non higher burn up non higher enrichment ATF in Hopefully by 2023 that being the goal or Or our folks thinking of skipping directly to the higher burn up again. I'm speaking mainly you know mid 2020s So 23 24 25, that's all the same window just recognizing the timeline that Topical reports will be submitted by year-end and then it's a 12 to 24 month process for the review and approval by the regulator at the same time you have The industry and the fuel vendors working together if we have that regulatory certainty that the topicals will be submitted Then we can start making the contracts with the fuel vendors because they have to modify their facilities So it's just there was so much interplay Right, I would like to tell you that January 1 2023 as a certainty, but just because of the unknowns in the interplay. It's gonna be the mid 2020s for the Deployment of ATF with higher enrichment higher burn up And you think that's the first deployment. There is deployment. There isn't an earlier regular ATF deployment That's the first okay, and that kind of goes to the quiet I mean that when the NRC staff looks at this, you know, if you look at the project plan I think they see the critical path as being the irradiated testing necessary to fully understand and characterize how the an ATF design acts under different conditions and the modeling of those characteristics and And And what I'm trying to get a sense of is do we think and if it's 2025 that's an extra couple years compared to 2023 But do we think there is going to be enough time for that? You know when Al was talking he was mentioning. Well, you know, we have lead test assemblies in there and you can get unexpected results from that and that you know could create additional Work or efforts. I mean if the target is 2023 2024 2025 Does this require like everything going perfect on the experimental testing side? Is this the kind of best-case scenario for all that work that needs to be done or we think it's More straightforward than that Here comes Al. I'm gonna ask Al to take that one. I think To tee up. I believe in research. You don't know what's gonna happen. They're always gonna be uncertainties There is a high level of understanding of some of these variables which gives a level of confidence that those time frames are achievable about let I'll add some color to that So there are what we call single effects testing and then integral tests Okay, and LTA is integral to a reactor to a certain burn-up rate or burn up, you know and in that way The vendors have done a lot of testing and they've done it in their labs and they've done it in radiations MIT are other facilities around the world Okay So there is some data that they have and we have a good belief in certain things and before it goes into a into a Commercial reactor, there's a strong behavioral analysis that is being developed through DOE's work through the vendors work through our work and It goes to a place where there's a there's a belief in a safety You know that that this is safe to put into a reactor the questions are are there other unknowns? Unknowns unknowns or known unknowns that occur You know after so much of a burn-up or after so much Irradiations and that is where we have to build that knowledge level up And so that's where the the road may divert and we have to do additional research Maybe it's making the coatings larger or thicker things along these lines that are can't be done fixed through either additional research or additional Manufacturing changes. So there's a lot of opportunities here to optimize as we go forward. It took us a long time We took us 40 to 50 years to optimize Zerk UO2 Okay, that came through operational data development and also research So the combination of both as a function of time and irradiations will get us there It just it's going to take a sin. So there's an iterative iterative approach to this when we You might as well just stay there for a second now. So when The when we last had a commission meeting just focused completely on accident tolerant fuel I think that was April 2018 and at that time there really wasn't this focus I don't think on the higher burn-up higher enrichment That seems like it's been kind of a fairly late-breaking development the last year or two How much does that complicate the kind of experimental side of this to get the data? You would need to make a schedule feasible for mid-2020s It is a challenge, especially with a halden shutdown But there are activities and we're working my colleagues and I are working on Plans of how do we pull this in we did discuss higher enrichment on that slide that that has the we called the Christmas tree Chart the red green yellow we identified Higher enrichment, you know as a possibility because then they get more economic driver to The ATF deployments back in 2018 and we talked about in our reports as well But the focus has been that we now believe we can really you know some of the data coming out of the testing and the And the results that have come out of the LTA's and other things We're seeing a lot more, you know Benefits of the ATF to then so further support the higher burn-up the higher enrichment And so now that we've seen that it seems like it's much more doable And so now it's become much more of a of an opportunity To get us safety benefits, but also allowing the vendor or the vendors and utilities to have the economic drivers to introduce something that's safer Thank you Yeah, Pete you mentioned there are a lot of moving parts here one of them this was not intended as upon but one of those is transportation packages and You know if we're talk not about lead test assemblies for a minute, but if we're thinking more about batch loading full-core You know the new fuels are likely going to need new transportation packages Both for the fresh fuel before it goes into a reactor and then afterwards for spent fuel after it's been irradiated I think that's particularly true for the higher burn-up fuels for higher enrichment levels beyond 5% What's the status of efforts to develop and then seek NRC approval for those transportation packages? so that's a big focus for the Licensing and safety benefits task force for 2020 There really is one package that that we believe will be The most critical and that is the the uf6 package to transport the enriched Material from the enrichment plan to the fabrication plan so the the package we use today is a 30b And so work needs to be done on on that package to license it to carry greater than 5 weight percent enrichment So we believe that's the critical path I don't want to speak too much for the vendors But I would say that the initial efforts that they've shared with that task force is that they do not see Significant hurdles with respect to their fabricated fuel new packages. Okay, is that true on the back end too? I mean I know now we're talking to several years in the future, but after you had you know a full core You know that had been irradiated Do do we have my sense is we don't have Transportation packages now that are certified for that. Yeah, especially if it's higher burn up higher enrichment That's right. So the big focus on the back end is around dry storage Okay, and so every hosted immediate dry casket certified. That's right. So it's to begin the development of the storage packages For these fuels. Okay. All right, so that's underway, but we're that's down the road a bit. That's correct. Okay. Thank you In terms of the question about improved plant economics, I think both, you know, Pete and Neil had slides talking about that is the Do you see the main economic driver for ATF the economic driver the main economic driver being, you know, the ability to move PWRs to a 24 month Refueling cycle is that what you see is kind of the thing that delivers the biggest. Yes, correct So just about every US boiling water reactor. I think except one is on a 24 month cycle This would then afford the opportunity for the large for loop PWRs to move to that 24 month cycle as well And that's where you really you think that's where you get the real bang for your buck Yes, okay, and then I just had one other question, which really isn't a 51 second kind of question But I'll just ask it anyway and get any thought you have the NRC staff. I think is leaning pretty heavily On expert elicitation for phenomena identification. That's the pert process. We didn't talk about too much on the first panel But I think the staff will talk about a little bit more on the second panel For new concepts and technologies that may differ significantly from fuels currently used How how do we make sure that the pert process is capturing all of the relevant safety significant issues? I guess this goes a little bit to the point that chairman was making about the unknown unknowns I think you could have really brilliant people sitting around and looking at the literature and trying to think through What are the phenomena should we should be thinking about but how do we make sure we're not going to miss something vital in that process? Any thoughts on that in seven seconds? Answering it cold a little bit I think What I see is this Fairly unique and open collaboration between all the stakeholders coming together you have DOE the utilities EPRI the NRC staff all coming together and having these open dialogues around what their concerns are and From what I've observed from the outside looking in this is actually doing a great job Bubbling up just those issues just those concerns and getting people aligned around what needs to be done Yeah, I'd agree. I think it's that upfront alignment and communication as opposed to the industry DOE The research being done in a vacuum and then forwarding in all the information to the regulator for their review And then you all go okay now what about x y or z but if we can do it in parallel and all the questions being answered up front I think that's where the efficiencies are gained And I just add That's kind of what we were founded on this kind of open challenging ourselves as well as welcoming You know the NRC staff and to challenge us as we go Universities and international Participants have also challenged us. So I think it's been healthy. Yeah I think fundamentally we want to get it right and we want to make sure you get it right too Yeah, if you don't mind So yeah, so humans are fallible. So obviously that per process has to be informed by confirmatory data and so I would again stress that There are unknowns, you know historically you can see that Things crop up in in fuel behavior that are surprises and that's why I would again urge You not to take too many shortcuts. Maybe 20 years is excessive, but I'm not too short in this timeline too significantly and potentially miss safety significant safety significant Factors that could imperil the batch or full-core loading and for instance in the example you just discussed it seems Maybe I'm wrong but the LTA data that's been collected so far is not on high enriched You know higher enrichment fuel and so it seems like there's a gap That's developed between the current data. They've collected in the batch loading They're saying could be as early as 2023. So it seems that If that's the case there needs to be a gap analysis to see if there aren't any phenomena. They're being missed and in At least the early stages of a radiation of these higher enrichment fuels. Thank you Well, thank you again to my colleagues and to all the panelists We will take a break now a seven minute break, but we will reconvene sharply at 10 30. Thank you You everyone the meeting will recommence now with the NRC staff panel And we will be let off today by Dan Dorman the deputy executive director for reactor and preparedness programs who is Substituting for our executive director today Dan. Thank you very much and please proceed Thank you chairman. Good morning chairman and commissioners The staff appreciates the opportunity this morning to provide you with an update on our efforts to in our progress in the licensing of Accident tolerant fuel or ATF this panel will give you an overview of the work That's being done across the agency to support the implementation of ATF for the operating reactor fleet While maintaining a strong focus on the agency's mission to protect public health and safety and the environment Because ATF has the potential to provide benefits to the public and to the operating reactor Licenses through increased reactor safety and reduced operating costs the implementation of ATF has national strategic importance The Congress has continued to maintain attention on and funding for ATF technologies over the last decade in section 107 of the nuclear energy innovation and modernization act Otherwise known as NEMA required the submission of a report from the NRC on the licensing status of ATF And that report was submitted in January on January 9th of this year As we just heard from the external stakeholder panel a number of our licensees Similarly view ATF as a high priority for their fleets Especially considering the introduction of high burn-up and increased enrichment into the ATF domain over the past two years Finally, we also understand that the success with the ATF is important to the Commission and the risks associated with ATF are Being tracked in our quarterly performance review to ensure that we continue to have a high level of leadership engagement on this important topic The next slide please in the last Commission meeting on ATF, which was held on April 12th 2018 the NRC staff described the ATF project plan And how the NRC's approach to licensing ATF will be different than the approach that we took to licensing fuels in the past Since that last meeting we have effectively implemented the strategies laid out in the project plan to enable the safe use of emerging fuel Technologies and as a result we are preparing now to license the near-term ATF concepts We are committed to efficient and effective reviews for ATF applications focusing on the areas of greatest safety Significance and setting aggressive milestones for completing our reviews We're continually learning from our interactions with stakeholders to sharpen our focus on the issues and building off of our own successes such as the successful completion of the chromium coated part the phenomenon identification and ranking table which was mentioned During the earlier panel and the associated interim staff guidance that will be discussed by others here at the table We continue to work towards being a more modern fuel agile and risk-informed regulator The current framework is sufficient for us to successfully license accident tolerant fuels However to meet the proposed aggressive ATF development and deployment schedules This framework is needs may need to be modified to improve our review and licensing efficiency while maintaining the agency's safety goals We will be innovative in our review approach for the topical reports and other licensing applications using available data Risk-informed thinking engineering judgment and well-crafted limitations and conditions on licenses as needed To make our finding of reasonable assurance of adequate protection One example of becoming a more risk-informed regulator is the current use of the perks Historically perks were completed after the regulatory infrastructure was fully developed if at all For accident tolerant fuel We are put using perks in the development of the regulatory infrastructure thereby helping us to focus our approach on these new technologies Looking into the future. We plan to implement a timely and efficient review Process for ATF technologies and together with external stakeholders We will continue to focus on the development and regulation of these technologies to enable their safe use Next slide, please Our first speaker will be Andrea Vale who will provide an overview of our ATF activities She will be followed by Mike Ornack to her right Who will discuss the readiness for licensing near-term concepts? After Mike Marilyn Diaz to my far right We'll discuss fuel cycle and transportation readiness for accident tolerant fuel licensing After Marilyn will come back to my left to Josh Whitman who will discuss the technical basis for the review of the chromium coated cladding and Reactor burn-up extension and finally James Corson on my far left We'll provide an update on the preparation of the confirmatory analysis tools for ATF concepts next slide, please And with that introduction, I will turn the presentation over to Andrea Vale I recently appointed deputy director for engineering in the office of nuclear reactor regulation Thanks, Dan and good morning chairman and commissioners I'd first like to start with thanking the many staff members that have worked on ATF and have since moved on to different parts of the Agency and also some represented here, but there's a lot of staff working on this project It's very complex not just because of the technology that you've heard about but also as you heard from the first panel We're not following the 20-year model. So there's some what of a compressed time frame I was in the office of nuclear Regulatory research before coming to this project. So I'm also bringing those observations and insights next slide, please In order to set ourselves up for success while of course maintaining public health and safety We're engaging in three very important activities The first one is early and frequent engagement with stakeholders The second is examining the regulatory framework and the processes as you heard some earlier and also Following emergent technical issues next slide, please With regard to current status we fully understand how important it is to engage early with our stakeholders and When we do engage we stress getting timely information about potential topical report submittals Applications and amendments this allows us to really plan Effectively to avoid any licensing bottlenecks or any resource implications But at the same time we set very clear expectations every time we engage As Dan mentioned, we'll be flexible in our review But that is absolutely contingent on complete applications and justifications For us to make our determination of reasonable assurance and that is something that is stressed every meeting that we go to We visit often with our colleagues in the Department of Energy We go to test facilities Manufacturing facilities and that engagement also encourages good communications with the actual national laboratories where the testing is occurring We also engage very frequently with the international community in particular the Office of Nuclear Nuclear Regulatory Research fosters those international relationships both by going to international labs and going to research Reactors in the international community One aspect of the international as you heard earlier is the closing of Halden and so you can hear more about that from James Corson But we have considered that in our deliberations Research is also engaging in a very important activity Which is refining the confirmatory analysis codes, which James will also detail on his presentation Within the NRC the ATF steering committee and the ATF working group meets at least monthly But sometimes we're often as needed to address emerging issues and to assess those issues as they come up And in my opinion i'm early to the project But this project is an excellent example of successfully working in a matrix organization and keeping focus on the project Next slide, please You've heard a lot in the first panel about the regulatory framework and we are assessing that regulatory framework and processes as you also heard Ten CFR 50.68 has an explicit limit of five percent enrichment for fuel assemblies There are currently two materials licensees part 70 materials licensees that are in house with amendments This gets convoluted very quickly But the part 70 licensees have amendments in house for reactor operators and exemption would be required to receive fuel enriched above five percent Another known challenge of course is NRC resources We currently have the skill sets and the resources needed to license these technologies But of course in our engagements we stress the importance of having up-to-date information So that we can continue to plan for the foreseeable future But I do want to stress we do have the skill sets and resources for what we know Is forthcoming for ATF licensing next slide, please The staff is following emerging technical issues and as you know reactor designs meaning uranium dioxide pellets with the Zirconium alloy cladding has virtually remained unchanged for the past 50 years in the us fleet So we're following these emerging technical issues because it's evolving and it takes our focus And we really have to react quickly to figure out you mentioned unknown unknowns To kind of stack the deck and figure out as much as we can with the information that we have By following these emerging issues we can react quicker Now of course, we're not making any presupposed promises, but this could result in Faster issuance of regulatory guidance or safety evaluations if we have more information up front And although it's not a new phenomenon the the commission and the tas have heard about Fuel fragmentation relocation and dispersal in different ca briefs and in other meetings Or otherwise known as ffrd and you'll hear more about that in josh whitman's presentation So in summary overall, we spend a significant amount of time understanding both licensing challenges And technical challenges surrounding ATF licenses And we have confidence that we can license in the requested time frame frames, but of course I can't stress That's contingent on complete applications and those applications have to reflect the lessons learned that we've both Discussed in collaboration and put very clear messages out In every interaction that we have with both DOA vendors licensees and whoever else will listen to us about ATF Next slide, please The next speaker will be mike ornac. Who's the project manager for the atf project? Thank you. Thank you, andrea I'm good morning chairman and commissioners. I'm here today to discuss the readiness for licensing near-term atf concepts next slide, please We consider atf technologies near-term when we can rely on the existing data models and methods in a review of industry submittals The three technologies that we consider near-term First is crime-encoded cladding One vendor stated that we're coming in with top of report in 2020 No power actor licensees have stated they're going to adopt crime-encoded cladding yet Second technology is dope pellets. We've approved dope pellets for bwr applications When it comes to pdb r applications a couple vendors are exploring that too Third technology is fredex still alloy cladding, which is also known as fecal cladding Two two licensees have lead test assemblies inside the reactors However, no top of report submittal days have been told to us yet Next slide, please The atf project plan is being being followed in the april 2018 commission meeting new paradigm was introduced In this new paradigm the development of technical bases by the licensee will happen in parallel with the refinement of the regulatory infrastructure Benefit of this arrangement is that it allows licensing to start earlier We're previously that the licensing that happened after the development of the technical bases Next slide, please Two examples of how we're following the project plan as dan had discussed earlier We completed a chromium coated pert in january of 2019 The use of the pert is a proactive eliciting approach that allows more efficient refinement of the regulatory infrastructure We use the pert in the development of the interim staff guidance Perts for other subjects are currently scheduled and that will be discussed by james later The second example is our issuance of the interim staff guidance The interim staff guidances are normally issued after applications are received because the staff will finally have an idea on What the licensees are going to present to us? Uh because of our interactions with vendors and stakeholders Our interactions have allowed the early issuance who well before received any top reports or license amendment requests Both documents support staff efficiency They avoid multiple rai rounds And provide regulatory certainty for licensees Next slide, please The staff is being flexible and responsive to stakeholder needs The industry uses lead test assemblies to obtain data to make the safety case for new fuel designs Since the last commission meeting NEI had requested clarification on licensing requirements due to the interest in Accidental fuel lead test assemblies We issued a response of june of last year The LTA letter provides guidance on terms limited number and non-limiting core regions The use of approved codes and methods The use of 10 cfr 50 59 Which is changes tests and experiments The use of exemptions to 10 cfr 50 46 Which acceptance criteria for emergency core cooling The LTA letter ensured regulatory consistency and reduced misunderstandings regarding the insertions of LTAs A second example of us being responsive is the issuance of appendix a to the project plan Which is entitled fuel burn up and enrichment extension preparation strategy Due to industry and department of energy activities regarding high burn up and increased enrichment Revive we decided to rise of project plan and that was issued in october of 2019 Next slide, please Early infrequent communication is key to the success of the project plan and the inner staff is following through If you look on the top row of the slide, I've already discussed the project plan in the LTA letter And on the top right is risk 2019-03 Which is pre-application communication scheduling for atf submittals This risk requested scheduling formation for part 70 71 and 72 Vendors and this assists the nrc staff and workload planning To date we received two responses And we hope to receive the third response in the middle of next month We continue to engage vendors and licensees These interactions allow us to stay updated on technical developments Changes to licensing strategies and schedules We encourage pre-application meetings with the vendors and licensees To take care of any issues before they arise when we ever have applications One example of an interaction with vendors was the development of the isg is accelerated to the end of 2019 originally We had planned to issue the isg at a later date, but when one vendor came in and said they Submit a top report by the end 2019 We accelerated our schedule and managed to issue it. I said on january 3rd of this year. Well before received any topic reports We meet with industry representatives and working groups and provide and during these meetings industry provides a high level overview of direction and schedules And finally we put for a significant effort to interact with stakeholders, especially the public And some of the public meetings as you can see on the slide There was not a open subject Sorry, open portion of the meeting. These are totally proprietary the staff decided to Are requested an open portion of at the beginning of those meetings to interact with the public Next slide, please We are ready for known forthcoming applications The current regulatory framework is suitable for review and licensing of atf For high burn-up and increase in enrichment The framework is still continues to be acceptable However, as discussed earlier by Andrea regarding 10c far 5068 Should widespread adoption occur of increase in enrichment Rulemaking we're commenced to facilitate a more predictable licensing process For chromium code we've issued we've completed the pert and issued this In from staff guidance and we're waiting for the top of report applications The staff will review the need for other guidance documents on a routine basis To ensure we're ready for power reactor license member requests We're developing a licensing roadmap This licensing roadmap accounts for variations within amendment requests for coded cladding Cladding changes increased enrichment and high burn-up For this roadmap will identify resources timelines review steps and special circumstances such as reviewed with the acrs Once we complete the draft licensing roadmap We'll perform validation and verification using non-standard previous fuel reviews to confirm that all parts of the licensing process are taken account for After we're completed with the licensing roadmap We're executed a couple tabletop exercises That process the process simulated amendment requests to identify bottlenecks and other resource needs And finally when the lend amendment requests do come in we will have the analysis tools ready To make our safety case And those will be discussed by james and his presentation Overall, we are following the project plan We're completing licensing actions in parallel with industry progress on the technical bases And our communication with stakeholders allow us to be ready for the forthcoming at atf technologies I'd like to turn the presentation over to marylandias a chemical engineer in the office of nuclear materials safety and safeguards Thank you mike. Good morning chairman and commissioners I will be providing an overview of the status of accident-tolerant fuel as it relates to the front and back end of the fuel cycle Including the accomplishments with which achieved so far During my presentation. I will address how nmss is focused on preparing for these new technologies Next slide, please We are effectively implementing strategies to support the industry's 2023 goal of deploying atf We have taken a bigger role at the table with industry increased interest on deploying atf with higher enrichment levels and burn up We are making progress and here are some of our Recent accomplishments. We issued two special authorizations for the achievement of the lead test assemblies or lta's This action allows fuel vendors to transport a limited number of lta's through the reactor sites We also issue a revision to a certificate of compliance for one transportation package vendor authorizing the transfer of atf assemblies For chromium coated cladding and up to five percent enrichment This action allows the fuel vendor to transport an unlimited amount of ats assemblies to the reactor site Since the last commission meeting nmss staff worked with nrr to issue appendix a of the project plan addressing the strategy to prepare the agency for the review of future licensing actions Including license amendments to go beyond the current five percent enrichment limits And lastly staff develop a critical path identifying the schedule and timeframe For licensing actions needed to support the industry plan to deploy atf with higher enrichments in 2023 This critical path was sent to the nuclear energy institute in august 2019 To support 2023 deployment of atf with high assay low enrich uranium nrc must receive an application to increase fuel enrichment by august 2021 next slide, please We are effectively implementing strategies Identify in the project plan as we continue to license these new technologies and prepare for the future actions We are building on our processes in a smarter way We continue to enhance and revise our own licensing practices We continue to make progress in becoming a modern risk informed regulator For example in preparation for the atf and hail you a member request We gather a team representing each technical area to evaluate the risk associated with the future applications The risk insights gained from the approach better inform the scope of the reviews In october we received our first license amendment request to fabricate fuel with enrichments up to a percent from global nuclear fuel americas And in november we received a license amendment request from louisiana energy services to allow them to enrich up to 5.5 percent enrichment Additionally, we received an application from g e hitachi for transport of irradiated atf in the g 2000 package increased communication with licensees and asking questions early Like issuing requests for supplemental information during the acceptance review has improved the efficiency of these reviews To prepare for these technologies We have also been conducting assessment of the current regulatory framework and processes to identify and resolve any licensing issues We evaluate tensi of our part 70 and 71 for the review of enriching fuel above 5 percent for the transportation of u of 6 uranium hexafluoride For fuel fabrication and fresh fuel transportation of the atf near term concepts with hail you Today, we have not identified any significant regulatory or technical challenges for the near term atf concept with hail you For the front end of the fuel cycle We continue to evaluate our regulations to determine if review of these technologies will require rule making To date no changes to tensi of our part 70 or 71 Is needed to accommodate these new technologies? We will engage the commission if rulemaking is needed an example of our analysis Is that staff has identified that for transporting u of 6? Hail you licensees will be required to provide an evaluation of optimum moderation per tensi of our 71 55 One viable option is that licensees may request an exemption from this requirement In addition, we're working with office of research to assess the availability Of criticality benchmarking data for higher enrichments and cladding performance for spent fuel Next slide, please Another strategy we're successfully implementing is early and frequent engagement We have amplified our engagement with internal and external stakeholders This facilitates a common understanding of the new technology technologies We will need to be prepared to license and the timelines for the proposed deployment of these technologies For example, as mentioned before staff sent a letter to NEI Identifying when we need to receive applications for the use of atf with hail you to support the 2023 goal During the 2020 regulatory information conference We have a fuel management track which includes a session on licensing storage and transportation of atf Through different forums like this conference other public meetings and communications with industry We're working to identify and address challenges early We're also actively participating in the industry's atf working group that was formed to discuss regulatory and technical Initiatives that are needed to support atf with hail you Additionally, we're actively engaging and encouraging Pre-application interactions and utilizing our various forms for engaging external stakeholders For example staff has engaged in pre-application interactions with licensees Regarding their upcoming amendment to transport atf fuel with hail you their licensing action is expected to be submitted In early 2020 next slide, please Lastly, we're engaging in early training research requests and continued dialogue with internal and external Stakeholders as new information comes available on these technologies With the goal of ensuring that our workforce is fully equipped with knowledge and skills needed to support the workload To ensure we can support the expected amendments and new applications We factor the skills necessary to support these reviews into the strategic workforce planning process So we have the staff needed to meet the workload demand for example We're ensuring staff completes cross qualifications in key technical areas to enhance their agility and enable the review of future license applications In addition, we're conducting training for nrc staff We successfully coordinated a seminar given by Oak Ridge national labs last july on atf This seminar was recorded for future use by the nrc staff We will continue to assess the need to train staff on specific topics related to atf and hail you This reaches the end of my presentation I will now turn it to Josh Whitman Josh is a nuclear engineer in the office of nuclear reactor regulation And we'll be talking about the technical basis for common coded cladding and higher burn up Thank you, Marilyn and good morning chairman and commissioners Next slide please So i'll start by talking about one of our biggest accomplishments since the last commission meeting the issuance of the interim staff guidance or the isg on chromium coded cladding Which was issued in january of this year The isg describes what should be addressed and licensing submittals for for coded cladding So first i'll step through this pyramid from the bottom up describing the process and inputs that we use to get to the final isg We began with a literature search performed by pacific northwest national labs or pnnl This used the epregap analysis other documents in the public literature as well as pnnl's expertise from providing contract support for fuel reviews to create a document that was Described the state of knowledge of chromium coatings on in their use in reactors This document was then provided as background to experts who would form the phenomena identification and ranking table panel also knows a pert panel This panel then met in april of last year And added their the experts reviewed this document and provided their professional recommendations and insights And based on their expertise These experts were from the nuclear and coating fields in both industry and academia And they worked through and created a ranked list of material properties specified acceptable fuel design limits also known as saftles and new degradation mechanisms and ranked them by knowledge and importance level so these rankings as well as the Discussion at the pert panel were then incorporated into the final pert report, which was released in june of last year From there we created the isg by adapting the pert report adding more focus guidance for reviewers And we completed this all on an accelerated schedule going from the final pert report to issued guidance in just about seven months We did that in order to ensure that the isg was issued before the first coded cladding topical reports were submitted to the nrc for review Although we had an accelerated process We also did we also incorporated stakeholders throughout the process and throughout the development of the isg By holding the pert publicly releasing the pert report publicly Holding multiple public meetings throughout the isg development process including a acrs subcommittee meeting and by uh Noticing the isg for public comment and incorporating uh stakeholder feedback Next slide please So what is in this isg? The isg is intended to supplement the standard review plan or srp And the plan is to eventually incorporate it into the srp after we've had the ability to exercise it through the first Topical reports the middles and work out any kinks that we might find The isg contains guidance for reviewers To supplement the guidance in chapter 4 reactor in chapter 15 transient accident analysis of the standard review plan It also includes that list of material properties saftels and new degradation mechanisms. I just I talked about on the pert slide By issuing the isg We hope to ensure or we will ensure regulatory reliability and consistency between reviews and Different reviewers for the coded cladding as they are submitted to us Next slide please So with the issuance of the isg the nrc is now ready to review coded cladding topical reports But there is one key challenge, which is the limited data at high burn up that's going to be available for these technology as well. They're submitted Now as the previous panel discussed a little bit historically Fuel vendors have waited until they've collected data at the full range of requested burn up before submitting a topical report to the nrc for review Well, this simplifies the review process It has the downside of requiring many years just to achieve the burn up and then additional time to perform the poster radiation examinations and collect the data from In order to submit that with the topical report Additionally, if there's any benefits for the new fuel design Many plants may need to wait until they've achieved a full core of that design through three reloads before they can fully Achieve those benefits and licensing space So to help alleviate some of that lag We're willing to look at a phased approach to licensing of the coded cladding designs, which is what's Described in the diagram on the slide In a phased approach Vendors would first submit topical reports with data collected to an intermediate burn up level and staff would put appropriate conditions and limitations on burn up Based on this data Then in the future as they collect more data vendors could submit this data to the nrc as a supplement to the topical report to Either remove or raise the limitation on burn up Additionally Fuel vendors would likely need to submit a separate topical report or supplement the topical report to claim the benefits For the new cladding materials or the new coatings As they collect that data And so that can be done in parallel with the first Plants starting to load To starting to batch load these coded claddings Next slide, please so another major accomplishment that we've Had since the last commission meeting is the high burn up and increase enrichment appendix to the atf project plan Which was issued in october of last year The appendix follows the same general format as the atf project plan with four major focus areas in reactor regulatory framework regulatory framework for fuel cycle transportation and storage probabilistic risk assessment activities and independent confirmatory calculation activities The purpose of the project plan appendix is to prepare the agency for efficient and effective licensing of high burn up and increased enrichment when the When submittals come in We included input from the public in this process through a public meeting and submitted comments And we're now working to implement the plan much like we're working to implement the atf portion of the project plan Next slide, please So as part of this process, we need to develop the technical basis for high burn up fuel As we described in secchi 15 148 One phenomena sensitive to high burn up is fuel fragmentation relocation and dispersal also known as ffrd Ffrd is the observation that under certain accident conditions High burn up fuel may break into small pieces Which could then relocate within the fuel rod and potentially disperse into the primary coolant if the fuel cladding were to rupture We have a growing understanding that shows that fuel is not susceptible to ffrd Until it achieves greater than the current burn up limits, but it may be susceptible below the burn up limits being proposed by industry As you can see from the slide below the current burn up limits the fuel particles are large Whereas above the current burn up limits The fuel fragments into much smaller pieces that would have a greater propensity to relocate or disperse So industry is aware of ffrd and Recognizes its importance to demonstrating the safety of high burn up fuel Both industry and the nrc participate in international research programs that are working to gain further understanding of the phenomena And as part of the early engagement Described in the project plan appendix nrc attended a EPRI workshop on high burn up fuel just last month where ffrd was a primary topic of discussion But ffrd is not currently addressed in any licensee as an analyses of record and Moving to high burn up fuel and may need to be disposition Next slide, please So as laid out in the project plan and the project plan appendix Staff have had considerable early engagement with all of our stakeholders industry do e the national labs epri and the public In the last year we visited both oak ridge national lab where the picture on the left was taken and Idaho national labs to view experimental setups and experiments being run on atf This can provide invaluable context to data that's submitted with top reports that are collected from these experimental setups for the context for the reviewers and help to Reduce the questions and improve the review process We've also observed coding processes at two different vendor sites And as industries stepped up their focus on high burn up, we've stepped up our engagement there as well Attending to epri high burn up workshops, and we're also holding a rick session in a couple weeks on the same topic We've also attended do e's advanced fuel campaign meetings and epri do e inl atf workshop where I was at last week where Industry presents Some of the new developments in research Some of the new data they've collected and do e goes over some of their plans for the program We've also attended top the top fuel fuel the top fuel conference where atf has been a hot topic in recent years And finally we have regular interactions with vendors to understand changes in their licensing strategies as they evolve We hold these as Notice meetings with open portions to improve transparency with the public and our other stakeholders So next up i'm going to hand it over to james corsen who will be discussing the preparation of confirmatory analysis tools for atf concepts. Thank you Thanks josh. Good morning chairman and commissioners So i'm going to be talking about the various activities that we have ongoing in the office of nuclear regulatory research To support licensing of accident tolerant fuel Next slide, please So our efforts in the office of research fall into three broad categories The first is preparation of our confirmatory analysis tools for fuel performance Neutronics thermal hydraulics and severe accidents and source term And these light are these confirmatory analysis tools help our licensing process by Verifying the the type of information that the vendors are submitting The second major area of activity is participation in international research programs To obtain data for our code development and for validation And to increase our understanding of safety significant phenomena And then the third major area The office of research is leading the literature reviews and pert activities For accident tolerant fuel and for burn up and enrichment extension and as previous speakers have mentioned Perts are a really key part of our atf project plan They help us to become a more modern risk informed regulator Because they help us identify the areas that are of greatest safety significance So that we can focus our review on those things So i'll be discussing our efforts in these three areas on the following slides Next slide, please So first are we've done a lot of work to update our computer codes to be more modular and flexible So that they can support different fuel types On the left of the slide you see a representation of the old way of doing things Where the material properties and the physics models and solution methods Are all sort of jumbled together and this makes it a lot more difficult to change out new material properties As a result of that we've made a number of efforts to remove those material properties and put them In separate libraries, so for our fast fuel performance code We've actually created a separate material properties library So this makes it more resource efficient to modify existing fuel properties As well as to add properties for new concepts like chromium coated cladding So of course this reduces a lot of redundancy and a lot of effort, which is a good thing And this has benefits not just for atf which motivated this activity, but for existing fuels as well So the material properties that we use in our codes come from a variety of sources They come from the open literature They come from international research programs and from material properties handbooks that are published by the department of energy and the national labs Likewise, we work closely with our counterparts at the labs and with our international counterparts to develop new models for our codes And also to obtain the data we need to validate the codes And as just josh mentioned getting this data is of course a challenge But we interact quite frequently with the department of energy and the vendors to remain up to date On their test plans so that we're as prepared as we can be Next slide, please So I already mentioned how we separated out the material properties from our fast fuel performance code into a dedicated library We can also use this same material properties library in some of our other tools like the trace thermal hydraulics code And again, this just reduces some of the redundancy for code development Which is very useful when we're adding new properties, but then it also has benefits for existing uh uo2 zerk When we have to do long-term maintenance on the codes So just another area where we've significantly improved our codes as a result of atf activities Next slide, please The second area where The office of research is leading activities related to atf and burn up and enrichment extensions is international research So we rely heavily on international research to obtain the data we need for code development for material properties and for validation data And these international research programs greatly increase our understanding of safety significant phenomena So I have just a few of the programs we participate in listed here First up is the studs Vic cladding integrity project Which has provided valuable data on fuel fragmentation relocation and dispersal phenomena that josh had mentioned previously Um, the skip program also provides information on the back end of the fuel cycle. So that's relevant to work on going in nmss I also have listed Reactivity insertion accident Uh tests that we follow There have been some tests done at the nuclear safety research reactor in japan on doped fuel So we follow those tests and we also participate in the cabri international project at the cabri reactor in france To obtain data on high burn up and doped fuel ria tests And then the last thing I have listed up here Is we've obtained valuable information on iron chromium aluminum cladding behavior during the loka and subsequent quench From the quench facility in germany So all of these programs provide valuable data for our codes as well as enhance our understanding of safety significant phenomena Next slide, please So the last area I want to talk about is parts and the previous speakers have Uh mentioned quite a bit the chrome coated part. So I'm not going to dwell on that any further I'll also mention that uh more recently we've completed a literature review On fuel performance considerations and data needs for fuel above current uh burn up limits So that literature review was completed by our contractors at pacific northwest national lab and it's publicly available So it identified what data is already out there for our codes as well as some of the data that needs to be collected to support licensing of high burn up fuel We also have literature reviews ongoing with pnnl related to chrome coated cladding and iron chromium aluminum cladding fresh fuel transport and spent fuel transport and storage so those are those um Literature reviews will be published in the next couple years And then the last major Pert activity I want to talk about is the severe accident and source term part Which will be coming later this year Next slide, please So the severe accident and source term pert for atf and burn up and enrichment extensions Will increase our knowledge of severe accident and source term behavior And this will feed into a number of different activities at nrc So this knowledge improves our ability for emergency planning and incident response Uh it also helps with our code development activities for the melcore severe accident and source term code And melcore is used to help support regulatory source term development And it's also used to help support development of surrogate criteria for a probabilistic risk assessment And the surrogate criteria in turn are used in regulatory cost benefit analysis anytime we need to evaluate new requirements or backfits So these are just some of the areas that the severe accident pert will help feed into it'll help identify areas where Atf or high burn up fuel may behave differently than the existing uo uo2 zerk system, and it'll help us identify where we need to adjust our guidance So those are the activities that we have ongoing in the office of research I'd like to now turn it back to dan for some closing remarks Thank you, james If I could have the next slide And the next one So I I want to conclude with the people You see here a number of the nrc staff working on the implementing the atf project plan including several of the folks here at the table This is not obviously an exclusive list. We have as you see before you Several offices of the agency actively engaged in in the full life cycle of accident tolerant fuel And making sure that we're thinking through all of the implications of accident tolerant fuel But I I would be remiss to stop there and not acknowledge the significant collaboration that you've heard about from both panels I think the the collaboration and particularly the pre-application discussions are critical to our success in in meeting The objectives for a timely implementation of accident tolerant fuels the the Preparation that that goes into that enables the staff to be better prepared for the applications that will come Before us that you see translated into interim staff guidance which is review guidance for the staff But also helps guide people preparing applications to know What are what are the important issues that the staff will be focused on in reviewing their application? And enables us to have more confidence that we will be able to deliver a timely safety decision At the appropriate time. So with that that concludes the staff remarks and we look forward to your questions Well, thank you very much dan in addition to that photo of that happy bunch I want to note that something very rare I've sat around this table at a lot of commission meetings for over 12 years now and we have achieved gender parity around this table I have to tell you that's very very rare I don't know how many times this has ever occurred for us, but with that we will um, I will turn to my colleague Thank you for helping with gender parity on this side of the table commissioner cabuto Thank you And I'd like to just start by making an observation just about the wealth of expertise I'm sitting at this table And I know that for each one of you that are here There is a cadre of staff who also contribute their expertise to the nature of what's being done here But I do think it's really remarkable just The level of intellectual health that's being applied here And so thank you for all contributing your best work to this effort um Mr. Dorman, let me start with you with a question. I think this should be fairly easy and straightforward, but Do you believe the staff is proceeding with an appropriate safety focus on accident tolerant fuel or Is there a risk of compromising safety in order to meet the industry's preferred schedule as dr. Lyman contends I I do believe we're maintaining an appropriate safety focus on this If I could briefly leverage the the question The chairman mentioned unknown unknowns this process that is Much shorter than our traditional 20-year process is a stepwise process As I as I mentioned in my opening remarks and I think josh touched on it as well There there may be license restrictions and conditions as we go through the steps of the process And the approvals that we will have will be for the next step of the process until we get to the point of a full approval of Ultimately full load of course And those will be based on on the data that we have at the time We make those decisions that give us enough confidence in the safety determination to go the next step Definitely a strong safety focus. Okay. Thank you Um Dan i'm going to come back to you with another one so nuclear energy innovation and modernization act required us to submit a report to congress on our progress on this issue And we reported that the existing regulatory framework is generally acceptable for licensing near-term ati fuel designs Using amendments and exemptions Now andrea has indicated that we still We're still assessing the need for rulemaking and new updated guidance documents And I know this is also mentioned by uh, mr. Ornack So Can you just give me a little clarity here? Sure So and andrea touched on on a couple of areas and I think dr. Lyman touched on 50 46 So there's a number of things in play that could Adjust the framework if you made a decision on 50 46 68 obviously at some point if if there is broad Implementation of higher enrichments than five percent in the reactor fleet It would be prudent for the commission to update its framework to reflect the higher enrichment than what is currently allowed in 50 68 But that this is not an impediment to us improve approving on a case basis The use of accident tolerant fuels going forward so we can do an exemption to 50 68 as an example To to allow more than a five percent enrichment in the reactor. So so we can Do it in the existing framework If this ends up being a broadly deployed Material in in the fleet at some point it will be prudent for us to update the regulatory framework I think between now and some point in the future. We're going to continue to learn more That will be valuable in forming the regulatory basis of what such an update to the regulatory framework would look like Okay, so if I can shift to mic and maybe have him contribute a little bit here because on slide 13 He has a bar that says refinement of regulatory infrastructure, which both precedes and overlaps licensing activities So that suggests that there is regulatory work That needs to be done regulatory work meaning the interim staff guidance. I mean at least that's for chromium coating cladding Okay, so the interim staff guidance was issued But only for The chromium cladding correct So this applies this implies that there is refinement of other regulatory infrastructure for other atf technologies This is the atf project plan is a general framework for all of the technologies And so for the other ones, I don't think we have it defined on what we're going to do for the regulatory infrastructure yet Is that the only one we see you know forthcoming right now is chromium coated cladding? Okay Well, this takes me to my other question So I've heard several times this morning that we're prepared to license near-term atf concepts But i'm hearing there may be regulatory infrastructure work that needs to be done And there is also the potential for assessing criticality research and whether there's available Enough data available and there's also the discussion of preparing Confirmatory analysis tools so So I guess my question is you know, we're prepared to license But does that actually mean we're ready now? Or we'll be ready by the time applications come in or we'll finish getting ready after applications come in Because if we need to wait and see what applications look like in order to provide guidance Then applicants don't have the benefit of the guidance in preparing their applications Which makes it more difficult for application for for applicants to submit complete high quality applications, so I'm I'm sort of struggling to figure out our degree of preparedness because It doesn't sound like we are prepared is quite the clear definitive statement That it would suggest So I'll go back to pete senna's comment about a plus b plus c and then it's calculus I think we're in the transition to calculus so up to this point. We've been from the regulator side Doing the pert doing the isg We've been doing the a plus b plus c what we need is the data What we need is the topicals so that's the next step and we're ready to get that data and get those topicals There's a potential for the unknown unknown in the topical We'll see But that will be the next step that will prepare The applicants for the lars the license amendment requests that they will need to batch load the fuel so so there is there is a An element of of yeah, there's a lot if there's a lot of moving parts here And we as we get closer to each moving part We're I think what what we're seeing in the collaboration and the implementation of the project plan Is the engagement that we need to have confidence that at the next step. We're going to be ready We are ready for the next step. We're ready to receive the topical report on chromium cladded fuels But and and we're also I'll take this opportunity to jump into to tiger teams and acceptance reviews and some of the more General things that are broader than just atf that are going on throughout the agency To to improve the process of accepting the the application for review and laying out a review plan That will be very focused on the important safety issues So I think so I so i'm confident that we're ready for the next step I'm confident that we have a project plan that will have us ready for the further steps as they come And I'd like to just add that um, this is partly what happened when the initial atf plan was sent out there wasn't and a Expectation that they increased Enrichment and high burner will be coming at the same time as atf And that's why we have such early and frequent engagement when the staff became aware that that was going to be something that the Industry was going forward with that's when we got together got the appendix out last october So we are iterating. I think as is it? Mr. Santel said from epri on the information that we get and then executing based on that information But we are ready to license chromium coated Okay Now i'm just going to make a caution here that I think if we're going to make statements that we are prepared to license near term atf concepts There's a difference between we are prepared And we're getting prepared and given the level of scrutiny And public attention to this. I think we need to be incredibly frank and precise in our use of language um Because if we say that we're prepared that's very easily interpreted by external stakeholders. Oh, okay. They're ready But We're not because there's still a fair amount of work being done. So I think we just need to be a little bit more precise in our language um And and a little more clear about the nature of that Um so Ms. Diaz one Last quick question for you Uh, you stated that you're working with the office of research to assess the availability of criticality benchmarking data If the necessary data isn't available How long do you think it takes to develop that data? So what we're saying is that Currently for the near term concepts We are ready to review license applications with higher enrichments more for about five percent The work that was being done with the office of research and the the literature review that will be done Is to further inform our reviews and to more efficiently conduct our review. So We've There is a plan that will address for higher enrichments going from five percent to eight percent And that will be conducted in the near term to inform that For right now, I think we have enough Um to review the applications with all their terminal alternatives like The applications will the will need to provide a bigger margin of safety when it comes to criticality and We'll have to provide additional information on the uncertainty and sensitivity analysis for the criticality safety evaluations Okay safety evaluations So does that mean you need that data in order to Make licensing decisions on near term. So we believe we don't need the data to be able to review If something comes in tomorrow safety evaluations, is it that you need to have this data by and what's the time frame for that? I think how far out are we looking so um More or less. Do you have the time you need to develop the data you need if it's not available? Um, I have here drew barred dough for the office of barred dough and mss. Um, so Critical experiments have been done in the past. This is the kind of data that we're looking for for criticality code validation They're they're likely aren't going to be any more Done so as far as that type of data coming down The the pike it doesn't look like we're going to get any more. So we're in a situation you have More than a thousand critical experiments below five weight percent available to you We're looking at now. What's available above five weight percent and that's not to say If there's not as many which we already know there's not as many that you you can't validate you can validate We already have in our nrc guidance methods for Extrapolating code bias and bias uncertainty beyond your range of applicability Necessarily your margins your margins to get larger because the uncertainty is larger So there's there's an option there for how to do that. We also have Better computational tools for looking at existing critical experiments And those are the sensitivity uncertainty analysis techniques That have been developed Primarily by Oak Ridge national lab for looking at critical experiments So there's lots of critical some critical experiments in that range that might not look like they're applicable to what we want License that may in fact be applicable So we just have to do that work to look at that but we can we can license this now with existing methods for Extrapolating beyond the range of applicability for code bias and bias uncertainty Okay, thank you Thank you next we'll hear from commissioner right Thank you. Thank you for the discussion today and preparation. I do agree with your comments earlier Andrea that a lot of people backing you up and with you know, they They they are appreciated for what they do um We kind of Probably going to go back into some of this again That's already been discussed to some level and i'm going to start with you again Andrea and and please Marilyn if you feel like you need to jump in jump in My understanding is that many of the issues we're discussing today And I think I referred to it in the first panel For accident-tolerant fuel with higher enrichments and burn-up will be applicable to advanced reactor fuels That may use the highest alio Can you give me a little bit more detail maybe an overview of how you're integrating these efforts? and will the Resolution of technical and policy issues for Accident-tolerant fuel with higher enrichments and burn-up also apply to And make it easier to license advanced reactor fuels. Can you maybe talk a little bit about that? I can start at a high level and then Marilyn may be able to add more for hay lew but some of the Lessons learned that we're getting both in the confirmatory analysis tools and some of the other knowledge We're getting with um assessing some of the accident-tolerant fuel technologies Are helping us to number one gain efficiencies because we don't have the the 20 years and the Benefit of the data that the chairman talked about so we do have to use innovative techniques to figure out How we're going to license this and no way are we minimizing safety or Trying to take shortcuts in in any way So it's really stretching the staff's capabilities And that's why the perts are so important And by nature of a pert you're getting the experts in the field So you're going out getting the people no matter where they are that are experts in the field to do this So we are working together and abroad You know across the agency as a broad project to try to get that information And to help both the advanced reactor fuels cold development And it's touching many other aspects of what we do at the agency And I I think it's a great example of one of the innovative projects that we're we're doing to try to move ahead And as you can see even the slides don't have the dense words and all the things that you normally see So we're trying to demonstrate that across the entire project right I would just add that um In nms as we've been following both the atf and advanced reactor Program closely some of the same people that are involved in the atf licensing actions are also involved in the Preparing the agency for the advanced reactor So I think I agree with um andrea's statements that we are closely working together towards What we learn in one program can be learned in the other one and we're we're in close communication with both programs Okay, thank you Mike you um And I guess Marilyn if you jump in here if you want to but the regulatory issue summary 20 1903 On pre-application communication and scheduling Was issued in november 2019. It's my understanding that the RIS contained a list of questions That address these could voluntarily Respond to within about 60 days or something I'm interested in maybe knowing a little bit more about the types of responses you got And has the response been what the staff expected And how will these responses I guess better Prepare staff some of the questions were such as what technologies do they intend to submit or tend to apply for? What What topical reports are coming in the future? The responses we have received have been very helpful to us when it comes to Scheduling out and when the when other resources will be needed and approximately the timelines Going into You know into license applications Okay, thank you. Um I'm going to come over to mr. Corson here. Um Very good presentation too by the way. Thank you. Um, you discussed And in the first panel we I refer to this one. I think mr With mr. Seno from southern You discussed a lot of the good work that the staff's doing to improve the codes and models for fuel analysis In the accident tolerant fuel project plan, it's noted that the staff has No indication that fuel vendors intend to rely on advanced modeling In simulation to support license amendments for near-term Concepts, um Can you give me a little bit more detail on the benefits if any for an applicant to utilize such models for license applications? Sure, so I will say the one area where the vendors have talked about potentially using advanced modeling in simulation is in Reducing the number of experiments that they need to perform so what I'll say the shortcoming of these advanced modeling and simulation tools the atomistic scale or mesoscale models Is they're very hard to validate Because it's hard to get a lot of the the information on you know, basic properties that you need to validate these codes So it's hard to rely on them to develop Uh a model that you're actually going to use But it's very useful in identifying trends in the data So you could see you know, maybe at this Weight percent of a dopant you might expect this behavior and you might expect it to be better than this other weight percent So in that respect, I think advanced modeling and simulation could be very useful In sort of narrowing the window of experiments that you need to perform And really targeting those experiments to look at what is really important You know, what do you really need to measure in order to help you validate your codes? So I would say, you know, none of the vendors are really talking about directly using Advanced modeling and simulation in their license applications But they are I believe doing some work to help them identify important experiments and important things to to measure Okay, thank you Ms. Diaz, I'm going to come with you the last last question I've got here. I think um, you mentioned that the staff didn't anticipate needing to Make any changes to part 70 71 or 72 But they may need to make some changes to guidance. Um, what types of changes to guidance are Have you identified and for the fuel designs that you expect to see the near term in what year is your timeline? Maybe for implementing them So right now we believe that part 70 71 72 we won't need any rulemaking or any guidance changes Um, there has been some recent updates to the guidance for transportation Um, and cladding materials that has recently been issued for high burn up So that's one we just issued and we believe that the guidance provided in that guidance and other guidance Are gonna be applicable for what we're expecting in the near term concepts of atf Um, I guess our understanding is as we move forward with the research activities that we're conducting and we're planning to conduct There's going to be in for the criticality Literature review and there's some other research activities that will be for the cladding properties Based on what comes out of those report and there There'll be another part on that based on what comes out of those report and part We'll we'll know more about what changes to our guidance will be needed For the next step Okay, thank you very much You're the only one from in and mess us up here. So You did a good job. Thanks Well, I joined my colleagues in thanking the staff and all of those who supported their presentations for a lot of Great updates and information today Andrea, um, you had I think made a comment that the way that the nrc is structuring itself to approach this work Is akin to a kind of a matrix organization approach Historically nrc has it made it somewhat cumbersome sometimes to assign Individuals to work and we were a little more stovepiped in the way we were approaching things I've long been an advocate for kind of cross functional multidisciplinary teams given the the complexity of the type of work that we do Should I draw from your statement Andrea that that in your observation? We're getting a little bit more agile as an organization to to have this kind of a getting the capacity to the work No matter where people are assigned in the organization Yes, I would make that conclusion because I've seen it in other areas as well We are not encumbered by bureaucracy or hierarchy If I need to read it, you know reach out to mike I reach out to mike I don't have to reach out to his division director or deputy or branch chief So I've seen this model work. Well, particularly in this project, but i'm also seeing it in other projects as well So I think the needle is moving. Thank you very much. That's encouraging and I I know when we saw that post fukushima We had some difficulty in getting staff on all the analysis and review work we had to do I think we acknowledged the problem at that stage So it's good to hear that we've moved to the needle away from from some of that which is Classic, you know where you're kind of doing something to yourself. So it's it's good that we've we've worked on that Can someone on the panel just briefly give an overview Of how the advisory committee on reactor safeguards is involved in this work and at what points How is the staff structuring its engagement with the acrs? gosh, please yeah, um So It depends on exactly. Oh, okay. So sorry the for the isg. We had a subcommittee meeting With the acrs to go over that that's part of the isg process is going through the acrs. We've also had um Additional atf acrs meeting. I think at least one maybe two where we've gone over the project plan um, and then For the near term concepts that we expect some middles in the very near future I think we're all anticipating that the acrs would like to see those and so we're kind of scheduling into our review time that Okay, thank you and since you mentioned the project plan um, I noted that um when You all became aware that the higher burn up and higher enrichment stuff was going to emerge Maybe a little sooner than you thought you did the appendix a update to the project plan Is that Your conceptual approach going forward is maybe a series of appendices to the project plan Or do you consider the project plan the basic structure of your approach? And you wouldn't really need to revise that or updated. Do you have any concept? Yeah, Michael you look about every six months to update the project plan for current events I mean And so yeah, if we do have if we have a need for new appendix or update the project plan We will go ahead and do it at the time. Okay, so both the plan itself, but you can also supplement it through Appendices thank you in the last yeah in the last revision we did a few revisions just for updating of completion of activities And if we need something larger, yeah, then we'll add a new appendix to it. Okay on the previous panel There was a description of perhaps some industry suggestion that the staff Maybe confined its regulatory reach into the fuel manufacturing process parameters And it was indicated by the panelists that the staff Had not adopted that suggestion I wasn't really following that but it raises a kind of an interesting point Could one of you talk very generally About the engagement in terms of the actual manufacturing process You know of this fuel what kind of Considerations how active are you in terms of any maybe restrictions or limits or qualifications and things you want in that area Just at a very high level. I realize it could be very detailed Yeah, so I'll try and be pretty brief The current fuel relies on ASTM standards for a lot of their testing and so the nrc has the Ability to go and inspect those processes and they have something to inspect it against There was a comment on the isg that requested that some language be added that the nrc would not I guess Regulate the manufacturing process. I forget the exact terminology and it was based on the fact that in the Pert there's some discussion About certain material properties where it might you know, there's some background on all those material properties in the list And it says, you know, this material property may be particularly affected by the Coding application process And so I think there was some sensitivity that they don't want it. They didn't want us to go in and Kind of like design the actual Application of a coding and what kind of nozzle would do it and things like they didn't want the specification to go there And I think it's it would have been premature for us to say Hands down. We're not going to ever look at that because it's The vendor needs to define what coding they want approved And for the current process, you know, it's a zirconium alloy They talk about the alloying elements and the different impurity levels that are allowed And that's all stuff that can be inspected and can also be inspected against a STM standard With something like the coatings where there is no standard, you know It's up to them to define that and if it turns out that they need to use a very specific nozzle to get this performance And without that nozzle they get completely different performance Then they may need to use that and their top will report As a way of defining that coding. I don't think that's going to be the case But it didn't seem appropriate to remove that possibility At the isg. Okay. That's a very helpful Dan. Did you want to say something just briefly at a little bit higher level? so The commission regulates the fabricator of the fuel For the safety of the public around that facility and the workers at that facility separately we regulate their customer The reactor and and through the reactors quality assurance plan they regulate their vendors And and I think what josh is touching on is the standards for what they're regulating on this safety related component We have clear standards for the existing fuel. There are not consensus standards for the next generation of fuel And that's where this discussion is happening Thank you. That um, that's a very I think helpful discussion and clarification about that James you talked about it was very Interesting discussion about the confirmatory analysis tools and you had a slide where I think you said, you know The materials properties were kind of jumbled up inside. It was a gear Was call kind of baked in there and now we've we have materials properties libraries and things so you can do a more stylized kind of confirmatory analysis You also mentioned though the importance of You know validation when you alter the machinery in that way and you kind of say well You're going to draw these properties from a library instead of having them invoked in some other way within the model itself Do we have at nrc? Are we are we documenting though the validation process when we go through that because I know often It's very helpful if if analysts later 10 or 15 years later can can have insights into how you validated That what you thought the model was analyzing it was actually analyzing once you made This type of change. Can you talk a little bit about how we document that for the future? Sure, so I was talking about this in the context of our Fast code and fast is a combination of our older frappe con and frappe tran codes So frappe con and frappe tran. This is where things were sort of jumbled together And we have a validate validation documents for both frappe con and frappe tran Uh, they're available on our our website for the the frappe con frappe tran codes So you can see the sorts of experiments that we're using to validate our codes for various models integral data We'll have that same sort of document when we release fast Uh To the public or not to the public to a user group in the next month So you'll see that same sort of validation And you should see that the results haven't really changed after we've removed these material properties for the existing properties Now when we start to add new materials, then we would need to do we would need to essentially append This assessment document to say it's also valid for these fuel types so right now, uh, the of course the The assessment document focuses primarily on uo2 zerk up to a certain burn up But I believe there will also be test cases for metallic fuels that are used in like advanced reactors So you'll see, you know, how some of those things have been added to fast once we've, you know, updated the codes I hope that answers your question. Yes. Thank you. That is um That's very helpful. Um, and with that I will turn to commissioner baron Great. Thanks. Well, thank you all for your presentations. Uh, it sounds like industry is really heading in the direction with atf Of higher Enrichment higher burn up fuel So I have some questions about that. Um, I know that the chairman noted that, you know, when you look at the project plan There's actually appendix just focused on that. I don't know if that means the appendix is taking over the entire plan at this point, but um, sounds like maybe it has um Starting kind of at the beginning of the timeline if we think about lead test assemblies I'm just going to ask these questions to the whole panel and whoever wants to answer can jump in um We'll lead test assemblies for accident tolerant fuels with higher burn up or enrichment beyond five percent Uh, require nrc approval through license amendment requests Um, so in general, it's uh, Sort of continued on the licensee to go through their 50 59 process and determined when a license amendment is needed For any change the reactor not just lta's but You know, we provided the lta guidance letter to help Uh, make clear the agency's position on the use of 50 59 So I don't want to say that there's You know, basically we wrote a letter that said indeed, you know, here's how you make the decision So I don't want to make the decision myself But I would say that personally it's it would be difficult for me to fathom a Insertion of a higher enrichment lta that would meet the guidance and be allowed to be inserted without a license And it would require an exemption In addition to exceed the five percent So so they would need that prior approval Okay, and then um, if we kind of move forward a little bit to batch loading in the regulatory framework for that um, the staff's project plan Discusses how higher burn up and higher enrichment ATF might not fit into some of the current regulatory requirements Including those for emergency core cooling systems accident source term criticality accidents And alara there are others too um With respect to inreactor performance An approval to batch load ATF with higher burn up and enrichment Inreactors, it sounds like changes to the regulations are probably going to be needed But it also The project plan also talks about near-term applicants Needing to request exemptions And demonstrate compliance with safety requirements And this is I guess is a little bit of a follow-up to that some of the questions that Commissioner Caputo is asking but I guess I'm struggling a little bit with what the right regulatory framework is for this Do we want to have Do we want to go the rulemaking route and have an actual regular regulation? In place for ATF with higher burn up higher Enrichment or are we satisfied with an exemption approach at least in the early years? Do folks have additional thoughts on that? I'll start at a general level and then josh may want to add some detail For rulemaking I would struggle with saying to what percent It's it's the unknown unknowns if you go down the path of rulemaking you're assuming there's widespread adoption of ATF So are you rulemaking to an absolute limit 10 20 percent? Are you rulemaking to 5.4 percent? So we would need to know more about adoption potentially benefits or margins that applicants or licensees are going to Ask for and we are looking at this this time frame Right now if we were to try to engage in rulemaking for let's let's say for chromium coated, which is not needed at this point It would be a bit like taking a hammer to you know to hit a nap We have the interim staff guidance and we're prepared to license chromium coated So the exemption was the more feasible and more durable way to handle chromium coated right now But that's why we're assessing rulemaking because as commissioner caputo pointed out Some of the more exotic and the chairman also said some of the more exotic technologies if we Get an idea that there's apparent widespread adoption then that may require rulemaking Yeah, so I guess there's two places where Exemptions may be needed in the near future one would be for Different coding there may be the need for 50 46 exemptions But for the 50 68 exemptions, I do think we are for the 50 68 rule which limits plants to loading Less than 5 percent enrichment into their spent fuel pools I think we do intend to to regulate through an exemption at the beginning before Determining whether there's going to be widespread adoption. It's worth the resources to Invest in new rulemaking for that I mean does the you know, it sounds like that The time frame involved is kind of slipping potentially from 2023 to more like 2025 and it sounds like there's a shift really from What I've been calling regular atf to, you know, maybe exclusively high burn up high enrichment Does that affect the way you look at whether rulemaking makes sense? I mean it potentially provides additional time Even if you didn't get all the way to final The documents that you're creating for that rulemaking process, which actually includes some public involvement exemptions don't You know Reg basis proposed rule those those documents would be presumably quite helpful to your technical reviews Of of applications that were to come in even if the rule weren't final by that I mean does that does the kind of changing time frame in the changing nature of what's coming in? How you think about this issue? I would offer. I think about it the other way Okay The so so the the nearest term appears to be a chromium coated at some level of enrichment above 5% And and through the through the lead test assembly data through criticality benchmark data through all the data that will be gathered to Provide a technical basis to support the exemptions needed to In place that fuel in a batch in a reactor To to provide some alternative to 5046 for the eccs performance criteria for that We're going to learn a lot through that process That would help us in forming the regulatory basis For a subsequent rulemaking if we wait for the for all the data And get the regulatory basis and go through the rulemaking process We're not going to we're not going to get there in that time frame number one. I think number two. I think that that You know then then we're deferring the licensing until after we get through a rulemaking process And I don't think that's necessary for us to be able to reach safety conclusions about specific applications I wanted to ask about an issue that um a commissioner right actually mentioned with the first panel which is that The project plan suggested that nrc's existing license renewal generic environmental impact statement Might not adequately address the environmental impact of higher burn up higher enrichment ATF can someone walk through that issue in a little bit more detail right now whenever we're developing the Licensing roadmap when it comes to generic environmental impact statement We're going to be reviewing what's going to be needed for high burn up and increase enrichment I know currently right now that The staff is reviewing at least for license renewal and are aware of atf issues For the for an extra vision to that you may say the geist So is this I mean this is kind of an open question about For the purposes of licensing, you know atf in the near term Whether is there an open question about whether a geist adequately covers this Or there's going to be additional environmental information that would need to be provided by an applicant I'm right now. I think it's an open question Okay, and and What is it going to take to answer that question? We have to see what people submit or there's an analysis going on of The existing environmental impact statement and what it does or does not cover Things we're going to have to see what the licensees submit And and and it will need to look at okay the changes in the material properties and in the associated impacts on effluence and inputs that would go into the environmental Impact statement are they bounded by what's already in the geist or Would there be some other environmental? Considerations that need to be addressed in that licensing process, whether it's through an EA or or or a Modification or a regular certainty point of view. I guess our communication then is To a potential applicant you yourselves are going to need to analyze whether or not what you have is bounded by And we need and we need to continue in in in these collaborations And the engagements with stakeholders as they develop the data from LTA's and from other sources to Understand that as well going forward Thank you Anything further? No. Well again, I wanted to thank