Licensing proposed ATF fuel concepts under the current regulatory framework will likely require the adoption of state-of-the-art criticality safety validation techniques, which may result in a significant reduction in operating margin.
Commercial nuclear power plant (NPP) operating strategies, spent fuel pool (SFP) management practices, and nuclear fuel design have evolved to a point where it is common for SFP nuclear criticality safety (NCS) analyses to show little remaining margin to regulatory limits for subcriticality. As a result, ensuring that all significant sources of uncertainty or bias are properly considered and accounted for in the NCS analyses has taken on increased significance. A large amount of SFP NCS analysis work has been performed in recent years that includes investigation of a broad variety of SFP storage configurations and possible reactivity sensitivities that could result in erosion of existing subcriticality margins. Due to ongoing efforts to develop detailed guidance for performing SFP NCS analyses that will be used by commercial NPP licensees, NRC staff has been performing a review of documents submitted to the NRC with uncertainty and sensitivity related information, including approved license amendment requests and publicly available studies. This paper presents some of the resulting findings and recommendations for future study.
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