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How does French State owned nuclear behemoth Areva spell regulatory relief? Like Holtec and others: “US NRC”. While the underfunded and understaffed French regulator, the ASN, has been holding Areva’s feet to the fire over defects, of late, the overfunded and overstaffed USNRC continues to coddle Areva. The US NRC claimed that they would receive more information from Areva on potentially flawed Areva-Le Creusot Forge nuclear parts in the US by the end of July. No information can be found. In its stead one finds information about two NRC regulatory exemptions for Areva. The first exemption has to do with spent fuel cask welding defects (still pending). The second, found below, has to do with helping a utility change to an apparently unapproved Areva M5 fuel cladding by granting an exemption, for reasons unknown. In stark contrast, the French regulatory, ASN, continues to provide information on potential Areva defects within France, and occasionally without.

Clearly, Areva’s M5 cladding does not perform the same as Zircaloy or ZIRLO. It may be similar, but it’s not the same. M5 – green dots – fails in fewer cycles and at lower strain amplitude, according to this small sampling. So does M5 red triangles (with MOX). This is from a 2016 presentation. Like Surry which just got an exemption, North Anna has PWRs (Pressurized Nuclear Reactors), though the Surry ones are much older. HB Robinson has a PWR, but Limerick has BWRs.
Areva M5 vs. Zircaloy failure
CIRFT Testing of High Burnup Used Nuclear Fuel from PWR and BWRs“, by J.-A. Wang, H. Wang, H. Jiang, Y. Yan, B. Bevard Oak Ridge National Laboratory, 2016 Nuclear Waste Technical Review Board February 17, 2016 Knoxville, TN: http://www.nwtrb.gov/meetings/2016/feb/bevard.pdf
M5 vs Zirloy vs Zircaloy Cladding
Ductile-to-Brittle Transition Temperatures for High-Burnup PWR Cladding Alloys” Mike Billone and Yung Liu Argonne National Laboratory U.S. NWTRB Winter Meeting November 20, 2013 http://www.nwtrb.gov/meetings/2013/nov/billone.pdf

Now how did Dominion apply for an exemption in September of 2016 and get it in July of 2016? An easy mistake, perhaps, but in many instances this sort of US NRC error could be deadly. They are supposed to be nuclear regulators, after all! It shows carelessness with no one checking their work, or a failure in logic: “SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) is issuing an exemption in response to a September 30, 2016, request from Virginia Electric Power Company (Dominion or the licensee) in order to use AREVA’s M5® alloy fuel rod cladding material at Surry Power Station, Unit Nos. 1 and 2 (SPS). DATES: The exemption was issued on July 27, 2016. https://www.gpo.gov/fdsys/pkg/FR-2016-08-03/pdf/2016-18375.pdf Recall that these are often highly paid professional bureaucrats, though the typist may not be.

According to the US NRC, Areva’s M5 alloy and Zircaloy; Zirlo are similar and that’s good enough for an exemption. If similar is the same, then why aren’t the US NRC workers in a cage? In a zoo? Because they are robots as outdated as the typewriter? Chimps and humans are genetically similar – probably closer than M5 alloy and Zircaloy or Zirlo are similar.
Chimps and humans are similar but not same

In a recent research proposal:”Post Irradiation Examination Plan for High Burnup Demonstration Project Sister Rods“, April 1, 2016 , it was observed that: “Mechanical property data is particularly important for M5® cladding for which publicly available data are inadequate.http://info.ornl.gov/sites/publications/files/Pub61934.pdf In other words, Areva sits on critically important information by claiming proprietary data. (Withholding information is an old French bureaucratic tradition, although other nuclear companies often engage in it too.)

And yet, the US NRC says:
Since the material properties of AREVA’s M5® alloy are similar to those of zirconium-based materials, the NRC staff found it appropriately conservative to apply the criteria in 10 CFR 50.46 and 10 CFR part 50, appendix K. • Material properties of AREVA’s M5® alloy, including cladding thermal conductivity, cladding creep, clad swelling, rupture deformation, and temperature, were found to be very similar to those of Zircaloy-4…https://www.gpo.gov/fdsys/pkg/FR-2016-08-03/pdf/2016-18375.pdf US NRC is apparently using a document written by Areva 16 years ago, in 2000.

In 2004, Dr. Ed Lyman, UCS, testified: “According to IRSN, M5 will form larger balloons than Zircaloy-4 in a design-basis LOCA because it remains more ductile during irradiation. October 2003 IRSN presentation to NRC… The greater retained ductility of M5 as a function of burnup compared to Zircaloy-4 can result in a greater M5 balloon size during a design-basis LOCA for fuel rods of the same burnup. Larger balloons increase the space available for fuel fragments to fall and hence result in a greater propensity for fuel relocation during a LOCA, with an associated increase in PCT and local clad oxidation…. there is an absence of experimental data on the performance of high-burnup, M5-clad fuel, under design-basis LOCA conditions. The Electric Power Research Institute (EPRI) and Areva (parent company of Framatome ANP) apparently continue to deny NRC access to samples of irradiated high-burnup M5-clad LEU fuel for testing at Argonne National Laboratory.” (Excerpted from Dr. Ed Lyman testimony, July 1, 2004: http://www.bredl.org/pdf/889-1_EL_Cont1testimony070104.pdf While this is dated, more recent documents from US nuclear labs, including dated 2016, complain of lack of access due to claims by Areva of proprietary information. )

In 2008, it was observed: “The abnormal fuel assembly growth that terminated the MOX experiment has broader safety implications. The NRC has allowed dozens of AREVA uranium fuel assemblies with the same flaw to remain in other U.S. reactors,… AREVA told the NRC in April that it has not as yet determined the cause of the problem, although it may be related to an experimental alloy known as “M5” AREVA uses in the “guide tubes” where the control rods that shut down the reactor are inserted…http://www.foe.org/news/news-releases/2008-11-nuclear-fuel-test-failure-raises-concerns

It’s not the same material composition, so it can’t have the same properties: Apparently Zircaloy 4 is an Zirconium, Iron, Chromium alloy ( Zr, Fe, Cr); Zircaloy 2 is an Zr, Fe, Cr alloy or Zirconium, Nickel (Zr, Ni) alloy. M5 is ZrNb and Zirlo is ZrSnNbFe (Zirconium, Tin, Niobium, Iron) alloy. (See ANT Int., 2014, Rudling et. al.: http://web.archive.org/web/20160808213958/https://www.antinternational.com/wp-content/uploads/ZIRAT19_IZNA14_AR_sample.pdf
Zirlo was patented: “Zirlo material for light water reactor applications, US 5112573 A “This is an alloy comprising, by weight percent, 0.5-2.0 niobium, 0.7-1.5 tin, 0.07-0.14 iron, and 0.03-0.14 of at least one of nickel and chromium, and at least 0.12 total of iron, nickel and chromium, and up to 220 ppm C, and the balance essentially zirconium. Preferably, the alloy contains 0.03-0.08 chromium, and 0.03-0.08 nickel. The alloy is also preferably subjected intermediate recrystallization anneals at a temperature of about 1200°-1300° F., and to a beta quench two steps prior to final size. US5112573 A http://www.google.com/patents/US5112573 Optimized Zirlo, whatever that is, was given an exemption in 2011: http://www.nrc.gov/docs/ML1116/ML111610044.pdf

Also, fabrication can have an impact upon characteristics. Apparently Areva has had quality concerns for a very long time. According to Thibault et al, 2009, EDF had a “significant number of fuel failures” that “were related to the M5 fuel cladding in 1300 MWe and 1450 MWe units. The M5 FR failures were due to fabrication defects…” (as referenced in ANT International, 2014, Rudling et. al: http://web.archive.org/web/20160808213958/https://www.antinternational.com/wp-content/uploads/ZIRAT19_IZNA14_AR_sample.pdf

NRC robots N'importe quoi

Typical US NRC illogic, raising the question of if it is written by a human or an old robot. Maybe they should be sent to the hottest zone at Fukushima to tunnel looking for the coriums and then we will see.
Comments in brackets.
SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) is issuing an exemption in response to a September 30, 2016, request from Virginia Electric Power Company (Dominion or the licensee) in order to use AREVA’s M5® alloy fuel rod cladding material at Surry Power Station, Unit Nos. 1 and 2 (SPS).
DATES: The exemption was issued on July 27, 2016.
[With this sort of mistake how could anyone trust them with something where not making errors is so important]
[…]
requires, in part, that the Baker-Just equation be used to predict the rates of energy release, hydrogen concentration, and cladding oxidation from the metal/water reaction. The Baker-Just equation assumes the use of zircaloy or ZIRLOTM materials that have different chemical compositions from AREVA’s M5® alloy.” [HERE THEY ADMIT THEY HAVE DIFFERENT CHEMICAL COMPOSITIONS] “As written, these regulations presume only the use of zircaloy or ZIRLOTM fuel rod cladding and do not contain provisions for use of fuel rods with other cladding materials.Therefore, an exemption from the requirements of 10 CFR 50.46 and 10 CFR part 50, appendix K, is needed to support the use of a different fuel cladding material.” [THEY DON’T LIKE WHAT IS WRITTEN, SO THEREFORE AN EXEMPTION IS NEEDED FROM THEY REQUIREMENTS!!!?] “Accordingly, the licensee requested an exemption that would allow the use of fuel rods clad with AREVA’s M5® alloy to be loaded into the SPS reactor cores as non- limiting lead test assemblies (LTAs) in up to eight locations.” [Why do they want or need to use Areva fuel anyway? ]

III. Discussion

Pursuant to 10 CFR 50.12, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of 10 CFR part 50 when the exemptions are authorized by law, will not present an undue risk to public health or safety, and are consistent with the common defense and security. However, 10 CFR 50.12(a)(2) states that the Commission will not consider granting an exemption unless special circumstances are present as set forth in 10 CFR 50.12(a)(2). Under 10 CFR 50.12(a)(2)(ii), special circumstances are present when application of the regulation in the particular circumstances would not serve, or is not necessary to achieve, the underlying purpose of the rule. ” [This makes no sense. The purpose of the rule is to do as they please?]

A. Special Circumstances

Special circumstances, in accordance with 10 CFR 50.12(a)(2)(ii), are present whenever application of the regulation in the particular circumstances is not necessary to achieve the underlying purpose of the rule. The underlying purpose of 10 CFR 50.46 and 10 CFR part 50, appendix K, is to establish acceptance criteria for ECCS performance to provide reasonable assurance of safety in the event of a LOCA.
[ BUT: “According to IRSN, M5 will form larger balloons than Zircaloy-4 in a design-basis LOCA… The greater retained ductility of M5 as a function of burnup compared to Zircaloy-4 can result in a greater M5 balloon size during a design-basis LOCA for fuel rods of the same burnup. Larger balloons increase the space available for fuel fragments to fall and hence result in a greater propensity for fuel relocation during a LOCA, with an associated increase in PCT and local clad oxidation… absence of experimental data on the performance of high-burnup, M5-clad fuel, under design-basis LOCA conditions. The Electric Power Research Institute (EPRI) and Areva (parent company of Framatome ANP) apparently continue to deny NRC access to samples of irradiated high-burnup M5-clad LEU fuel for testing at Argonne National Laboratory.” (Dr. Ed Lyman, 2004: http://www.bredl.org/pdf/889-1_EL_Cont1testimony070104.pdf 2016 documents from US nuclear labs still complain of lack of access due to claims by Areva of proprietary information. AND: “The abnormal fuel assembly growth that terminated the MOX experiment has broader safety implications. The NRC has allowed dozens of AREVA uranium fuel assemblies with the same flaw to remain in other U.S. reactors,… AREVA told the NRC in April that it has not as yet determined the cause of the problem, although it may be related to an experimental alloy known as “M5” AREVA uses in the “guide tubes” where the control rods that shut down the reactor are inserted…http://www.foe.org/news/news-releases/2008-11-nuclear-fuel-test-failure-raises-concerns ]

NRC cont: “The special circumstance that necessitates” [NO SPECIAL CIRCUMSTANCE NECESSITATES THE REQUEST!] “the request for exemption to 10 CFR 50.46 and 10 CFR 50, appendix K, is that neither of these regulations explicitly allows the use of AREVA’s M5® alloy fuel rod cladding material. The ultimate objective of 10 CFR 50.46 is to ensure that nuclear power reactors fueled with uranium oxide pellets within zircaloy or ZIRLO TM cladding must be provided with an ECCS that is designed to provide core cooling following a postulated LOCA. AREVA NP, in its NRC-approved Topical Report BAW–10227–A, ‘‘Evaluation of Advanced Cladding and Structural Material (M5) in PWR Reactor Fuel,” February 2000 (ADAMS Accession No. ML003686365), has demonstrated that the effectiveness of the ECCS will not be affected by a change from zircaloy or ZIRLOTM clad fuel to fuel rods clad with AREVA’s M5® alloy“. [They refer back to an Areva document from 16 years ago – 2000 – whereas there have been concerns raised more recently.] “Normal reload safety analyses will confirm” [WILL CONFIRM?] “that there is no adverse impact on ECCS performance. The objective of 10 CFR 50.46(b)(2) and (b)(3), and 10 CFR part 50, appendix K I.A.5, is to ensure that cladding oxidation and hydrogen generation are appropriately limited during a LOCA and conservatively accounted for in the ECCS evaluation model. Appendix K of 10 CFR part 50 requires that the Baker-Just equation be used in the ECCS evaluation model to determine the rate of energy release, cladding oxidation, and hydrogen generation. AREVA NP has shown in an appendix of Topical Report BAW– 10227–A that the Baker-Just model is conservative in all post-LOCA scenarios with respect to the use of AREVA’s M5® alloy fuel rod cladding material. Based on the regulatory review of the exemption request, the NRC staff concludes that the intent of 10 CFR 50.46 and 10 CFR part 50, appendix K, will continue to be satisfied for the planned operation of SPS with AREVA’s M5® alloy fuel rod cladding material used for non-limiting LTAs and the special circumstance required by 10 CFR 50.12(a)(2)(ii) for granting of an exemption exists.

B. Authorized by Law
This exemption would allow the use of fuel rods clad with AREVA’s M5® alloy in up to eight fuel assemblies at SPS. The regulations in 10 CFR 50.12 allow the NRC to grant exemptions from the requirements of 10 CFR part 50 provided that the exemptions are authorized by law. The NRC staff determined that special circumstances exist to grant the proposed exemption and that granting the exemption would not result in a violation of the Atomic Energy Act of 1954, as amended. Therefore, the exemption is authorized by law.
” [!!!!!??????]

C. No Undue Risk to Public Health and Safety

The provisions of 10 CFR 50.46 establish acceptance criteria for ECCS performance. Topical Report BAW– 10227–A contains the justification to use AREVA’s M5® alloy fuel rod cladding material, a proprietary variant of Zr1Nb, to replace Zircaloy-4 in the construction of fuel assembly components such as fuel rod cladding, guide tubes, and spacer grids.

This justification is required to support the request by Dominion for an exemption to 10 CFR 50.46 to permit the use of AREVA’s M5® alloy fuel rod cladding material, in addition to Zircaloy-4 and ZIRLO TM. AREVA’s M5® alloy is an AREVA NP proprietary material composed of 1.0 percent niobium, 0.125 percent oxygen, and the balance zirconium… Since the material properties of AREVA’s M5® alloy are similar to those of zirconium-based materials, the NRC staff found it appropriately conservative to apply the criteria in 10 CFR 50.46 and 10 CFR part 50, appendix K. • Material properties of AREVA’s M5® alloy, including cladding thermal conductivity, cladding creep, clad swelling, rupture deformation, and temperature, were found to be very similar to those of Zircaloy-4. • The retention of the Baker-Just equation for the calculation of metal- water reaction rate specified in 10 CFR part 50, appendix K, is justified to be suitably conservative. Based on the NRC staff’s evaluation of the exemption request, the staff concludes that the intent of 10 CFR 50.46 and 10 CFR part 50, appendix K, will continue to be satisfied for the planned operation of SPS, with AREVA’s M5® alloy fuel rod cladding material used in up to eight non- limiting LTAs. The probability of postulated accidents is not increased. Also, based on the NRC staff’s evaluation of the exemption request, the consequences of postulated accidents are not increased. Therefore, there is no undue risk to public health and safety due to using M5® alloy fuel cladding and fuel assembly material in up to eight non-limiting LTAs.

D. Consistent With the Common Defense and Security

The proposed exemption would allow the use of AREVA’s M5® alloy fuel rod cladding material at SPS. This change to the plant configuration is adequately controlled by technical specification

An AREVA NP LOCA evaluation showed compliance [AREVA SAYS IT’S OK SO IT IS?] with 10 CFR 50.46. Topical Report BAW–10227–A has addressed all of the important aspects of AREVA’s M5® alloy fuel rod cladding material with respect to ECCS performance requirements, as follows: • Since the material properties of AREVA’s M5® alloy are similar to those of zirconium-based materials, the NRC staff found it appropriately conservative to apply the criteria in 10 CFR 50.46 and 10 CFR part 50, appendix K. • Material properties of AREVA’s M5® alloy, including cladding thermal conductivity, cladding creep, clad swelling, rupture deformation, and temperature, were found to be very similar to those of Zircaloy-4.” [SIMILAR’S NOT THE SAME AND MAY NOT BE GOOD ENOUGH!] • The retention of the Baker-Just equation for the calculation of metal- water reaction rate specified in 10 CFR part 50, appendix K, is justified to be

use AREVA’s M5® alloy fuel rod cladding material, a proprietary variant of Zr1Nb, to replace Zircaloy-4 in the construction of fuel assembly components such as fuel rod cladding, guide tubes, and spacer grids. This justification is required to support the request by Dominion for an exemption to 10 CFR 50.46 to permit the use of AREVA’s M5® alloy fuel rod cladding material, in addition to Zircaloy-4 and ZIRLOTM. AREVA’s M5® alloy is an AREVA NP proprietary material composed of 1.0 percent niobium, 0.125 percent oxygen, and the balance zirconium. [DOMINION WANTS IT SO IT MUST BE JUSTIFIED!?] Read the entire nuclear blah, blah here https://www.gpo.gov/fdsys/pkg/FR-2016-08-03/pdf/2016-18375.pdf or at bottom of this blog post. It’s so crazy that one must see it.

Excerpted from FOE:
HAZARDOUS FUEL BEHAVIOR ANOTHER SETBACK FOR TROUBLED ENERGY DEPARTMENT PROGRAM, HAS IMPLICATIONS FOR OTHER REACTORS…”
The abnormal fuel assembly growth that terminated the MOX experiment has broader safety implications. The NRC has allowed dozens of AREVA uranium fuel assemblies with the same flaw to remain in other U.S. reactors, including Three Mile Island-1 in Pennsylvania, Davis-Besse in Ohio, Oconee in South Carolina, and Crystal River in Florida. AREVA told the NRC in April that it has not as yet determined the cause of the problem, although it may be related to an experimental alloy known as “M5” AREVA uses in the “guide tubes” where the control rods that shut down the reactor are inserted. Whatever the cause, the problem indicates that the NRC’s licensing process for new fuels is inadequate, the groups said.

http://www.foe.org/news/news-releases/2008-11-nuclear-fuel-test-failure-raises-concerns

Excerpted from “PREFILED WRITTEN TESTIMONY OF DR. EDWIN S. LYMAN REGARDING CONTENTION I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION, BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: DUKE ENERGY CORPORATION (Catawba Nuclear Station, Units 1 and 2) Docket Nos. 50-413-OLA 50-414-OLA
A.4. In my professional judgment, Duke’s design-basis loss of coolant (“DB-LOCA”) analysis is inadequate because it does not address the uncertainties associated with relocation effects that M5-clad MOX fuel may experience under LOCA conditions. These uncertainties relate to Duke’s assertion that the action proposed in the MOX LTA LAR will not result in a violation of the emergency core cooling system (ECCS) acceptance criteria in 10 C.F.R. § 50.46: peak cladding temperature (“PCT”), maximum cladding oxidation, and the preservation of a coolable core geometry.

The phenomenon of fuel relocation has been observed in experiments with irradiated LEU fuel under LOCA conditions. While to my knowledge no similar experiments have been done on MOX fuel, there are technical reasons to believe that the impact of fuel relocation effects during a LOCA may be more severe for MOX fuel rods than for LEU fuel rods of the same burnup, due to differences in characteristics such as fuel fragment sizes and fuel-clad interactions. Moreover, calculations in Duke’s LAR indicate that MOX fuel is generally more limiting than LEU fuel with respect to DB-LOCAs. Therefore, the consequences of fuel relocation, and the non-conservatism associated with neglecting them, may be of greater concern for MOX fuel rods than for LEU fuel rods with respect to compliance with LOCA regulatory criteria…
A.13: The MOX LTAs will use M5 cladding, as compared to the Zircaloy-4 or ZIRLO cladding that is extensively used in US PWRs. According to IRSN, M5 will form larger balloons than Zircaloy-4 in a design-basis LOCA because it remains more ductile during irradiation. October 2003 IRSN presentation to NRC at 24. The greater retained ductility of M5 as a function of burnup compared to Zircaloy-4 can result in a greater M5 balloon size during a design-basis LOCA for fuel rods of the same burnup. Larger balloons increase the space available for fuel fragments to fall and hence result in a greater propensity for fuel relocation during a LOCA, with an associated increase in PCT and local clad oxidation.
[…]
This question remains unresolved because there is an absence of experimental data on the performance of high-burnup, M5-clad fuel, under design-basis LOCA conditions. The Electric Power Research Institute (EPRI) and Areva (parent company of Framatome ANP) apparently continue to deny NRC access to samples of irradiated high-burnup M5-clad LEU fuel for testing at Argonne National Laboratory. Letter from Ashok C. Thadani, NRC, to David Modeen, EPRI (April 21, 2004) (ADAMS ACN # ML041130490). A copy of this letter is attached to my testimony as Exhibit K. This lack of cooperation can only cause further delays in the ability of NRC to obtain the experimental data it needs to confirm the safety of high-burnup M5-clad fuel (whether LEU or MOX).

I would underscore the admission of M. Blanpain of AREVA during the ACRS Reactor Fuels Subcommittee Meeting on April 21, 2004 that MOX fuel irradiated in France is predominantly clad in Zircaloy-4, and only “some M5 fuel rods with MOX for experimental purposes” have been used in France. See Transcript at 61-62. For some reason, France is reluctant to use M5-clad MOX fuel domestically and is primarily producing it for export to Germany (and now to the United States). However, even in Germany the use of M5-clad MOX has been extremely limited. And I am unaware of any integral LOCA tests performed with irradiated M5-clad MOX fuel“. http://www.bredl.org/pdf/889-1_EL_Cont1testimony070104.pdf
related: http://www.nrc.gov/docs/ML0416/ML041600354.pdf

Post Irradiation Examination Plan for High Burnup Demonstration Project Sister Rods” April 1, 2016 “Fueled and unfueled mechanical properties supporting modeling and simulation of fuel during storage and transportation, including the hoop stress vs. plastic strain properties of the cladding materials, as well as the engineering values for YS, UTS, and UE. It is important to conduct the test with all four cladding alloys because the database is rather sparse for the temperature range of interest. For fueled segments subjected to simulated drying-storage, the extent of radial hydride precipitation will be characterized and RCTs will be performed to determine possible degradation in properties due to radial hydrides. The test may identify conditions for subsequent fracture toughness conditions (due to an increase in the DBTT induced through the heat treatments applied). Mechanical property data is particularly important for M5® cladding for which publicly available data are inadequate. It is also important for the other alloys because the database is rather sparse for the temperature range of interest.http://info.ornl.gov/sites/publications/files/Pub61934.pdf

This is about BWRs, whereas N. Anna and Surry are PWRs:
ORNL/TM-2015/696
Reactor and Nuclear Systems Division
BWR SPENT NUCLEAR FUEL INTEGRITY RESEARCH AND DEVELOPMENT SURVEY FOR UKABWR SPENT FUEL INTERIM STORAGE
B. B. Bevard U. Mertyurek R. J. Belles J. M. Scaglione
Date Published: October 2015
http://info.ornl.gov/sites/publications/files/Pub60236.pdf

The formation of radial hydrides in zirconium alloy fuel cladding during vacuum drying depends on the details of the manufacturing and the in-reactor history of the cladding. With the advent of new corrosion resistant claddings such as ZIRLO™ and M5®, which were developed for higher burnup up to 62 GWd/MTU, used fuel hydrogen contents and temperatures have become much more variable than in the past.https://e-reports-ext.llnl.gov/pdf/799842.pdf

Areva M5 protective cladding shows higher evidence of failure with higher burnup fuel than previous Zirconium cladding material.” https://sanonofresafety.files.wordpress.com/2011/11/choosesafetyoverprofits2014-05-22.pdf

Federal Register / Vol. 81, No. 149 / Wednesday, August 3, 2016 / Notices
Areva Exemption M5 Fuel Surry 51218 Federal Register / Vol. 81, No. 149 / Wednesday, August 3, 2016 / Notices
Areva Exemption M5 Fuel Surry 51219  Federal Register / Vol. 81, No. 149 / Wednesday, August 3, 2016 /
Areva Exemption M5 Fuel Surry 51218 Federal Register / Vol. 81, No. 149 / Wednesday, August 3, 2016 / Notices
https://www.gpo.gov/fdsys/pkg/FR-2016-08-03/pdf/2016-18375.pdf

Note regarding ASN and NRC staffing: We have not actually compared staffing numbers. The French ASN appear to want to do their jobs, but have declared themselves unable to deal with workload due to staff and financial shortages. They have thus chosen to focus more on monitoring the many old reactors, rather than new ones. They warn of difficulties in the future. So, we take their word for it. The US NRC appears to not being doing its job and to be an almost entirely captured regulator. Thus, we conclude that they are overstaffed and overfunded. In general, US Federal jobs are very highly paid with good benefits, compared to people outside of these jobs. That’s not to say they are well off, only comparatively so.