“…The RIL highlights burnup as the primary parameter driving FFRD. However, data generated through the Nuclear Fuel Industry Research (NFIR) [6] program and recent high-burnup microscopy data [7][8][9] suggest that FFRD may be influenced by the fuel rod's power history (i.e., temperature) and therefore suggests that there may be burnup and fuel temperature thresholds operating in tandem. In parallel, the microstructure evolution directly contributes to the amount of FGR during steady-state operation and in turn increases the rod's internal pressure, which is the force driving cladding deformation during the transient: a higher pressure increases the probability of cladding failure.…”