ML18131A064
| ML18131A064 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 05/10/2018 |
| From: | Murray S Global Nuclear Fuel |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML18131A063 | List: |
| References | |
| M180107 | |
| Download: ML18131A064 (12) | |
Text
Global Nuclear Fuel M180107 May 10,2018 Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Document Control Desk
Subject:
NRC License SNM-1 097-License Amendment Request
References:
- 1) SNM-1 097, Docket 70-1113 Global Nuclear Fuel Scott P. Murray Manager, Facility Licensing 3901 Castle Hayne Road P.O. Box 780 Wilmington, NC 28402 USA T (91 0) 819-5950 Scott.murray@ge.com
- 2) Letter S.P. Murray (GNF-A) toT. Naquin (NRC), "GNF-A SNM 1097 Proposed License Amendment Request", 2/26/18
- 3) Telecom, GNF-A/NRC Staff, 3/16/18
Dear Sir or Madam:
The Global Nuclear Fuel-Americas L.L.C. (GNF-A) facility in Wilmington, North Carolina hereby provides a license amendment request for Chapter 5 "Nuclear Criticality Safety" and minor administrative updates to five other Chapters of our approved SNM license renewal application (Reference 1 ).
The requested changes to Chapter 5 have been internally reviewed and documented as changes to license commitments requiring prior NRC approval in accordance with SNM 1097 Section 1.3.1.2 and 10 CFR 70. 72. The minor administrative updates to Chapters 2, 4, 9, 10 and 11 have been internally reviewed and documented as changes to license commitments that do not require prior NRC approval in accordance with SNM 1097 Section 1.3.1.2 and 10 CFR 70.72 A description and reason for the change in each Chapter is provided in Attachment 1 to this letter to aid in the NRC Staff review.
Attachments 2 through 7 provide updates to Chapter 2, "Organization and Administration", Chapter 4 "Radiation Safety", Chapter 5 "Nuclear Criticality Safety", Chapter 9 "Environmental Protection",
Chapter 10, "Decommissioning" and Chapter 11, "Management Measures". The revised sections are identified with a vertical line in the right hand margin on each revised page.
Please contact me on (91 0) 819-5950 if you have any questions or would like to discuss the request.
Qrely,
- Scot'd/l2~
Facility Licensing
~(/7'
M180107 US NRC May 10, 2018 Page 2 of 2 Attachments: 1) SNM-1097 Change Table Summary
- 2) SNM-1097 Chapter 2
- 3) SNM-1097 Chapter 4
- 4) SNM-1097 Chapter 5
- 5) SNM-1097 Chapter 9
- 6) SNM-1097 Chapter 10
- 7) SNM -1097 Chapter 11 cc: RK Johnson, USNRC NMSS TD Naquin, USNRC NMSS T. Vukovinsky, USNRC RII SPM 18-031
M180107 US NRC May 10, 2018 Page 1 of 10 SNM-1097 License Application Chapter Change Table Section Description of Change Reason for Change Chapter 2 -ORGANIZATION AND ADMINISTRATION Section 2.2.1.1 Organization and Administration Figure 2.1 GNF-A Organization Chart Second paragraph, first sentence added or equivalent to the GNF-A Facility Manager.
Separated EHS Functions on Chart Administrative Update Administrative Update Chapter 4 - RADIATION SAFETY Section 4.5.1 Surveys Last sentence, last paragraph deleted or personal clothing Clarification Chapter 5 - NUCLEAR CRITICALITY SAFETY Chapter 5 Section 5.1.1, Criticality Safety Design Philosophy First sentence changed The Double Contingency Principle as identified to The Process analysis as discussed in section 4.1.2 and the Double-contingency principle as identified Changed (1998) is the fundamental technical basis to (2014) are fundamental bases Added bullet points:
Before a new operation with fissionable material is begun, or before an existing operation is changed, it shall be determined that the entire process will be subcritical under both normal and credible abnormal conditions.
Process designs should incorporate sufficient factors of safety to require at least two unlikely, independent, and concurrent changes in process conditions before a criticality accident is possible.
Second paragraph deleted an inadvertent and added or process condition changes Administrative Update Administrative Update Administrative Update Align with updates to ANSI/ANS 8.1 Administrative Update
M180107 US NRC May 10, 2018 Page 2 of 10 SNM-1097 License Application Chapter Change Table Section Description of Change Reason for Change Continued:
Section 5.1.1, Criticality Safety Design Philosophy Third paragraph The established to Established b) deleted an inadvertent e) deleted IROFS added parameter Administrative Update Administrative Update Administrative Update Section 5.1.2.1 Changes to Facility First paragraph added criticality safety and removed chemical hazards Third paragraph added ISA documents are updated per section 11.2 Clarification Clarification Section 5.1.4.1, Posting of Limits and Controls Updated second paragraph to refer to internal procedures Administrative Update Section 5.3.1 General Configuration Management First sentence changed 2005 to 2014 Administrative Update Section 5.3.2.1, Training and Qualification of NCS Staff Removed The most effective training is on the job facility specific training, which, added CSE qualifications and changed senior NCS management to NCS management in last sentence of second paragraph Clarification Section 5.3.2.2, Auditing, Assessing and Upgrading the NCS Program Fourth paragraph, second sentence changed reported in writing to documented and provided and changed who disseminates the report to line are to and facility Second paragraph, last sentence changed Results in the form of corrective action requests to Findings requiring corrective action Clarification Content not applicable to NCS Section 5.3.2.4, Modifications to Operating and Maintenance Procedures Second sentence, second paragraph changed concerned personnel to affected personnel Clarification 5.3.2.5 Criticality Accident Alarm System (CAAS) Design and Performance Requirements Second sentence changed 2003 to (R2012)
Administrative Update Section 5.3.2.7, NCS Records Retention Moved to first paragraph of Section 5.4.5.5 Administrative Update Section 5.4.1, Control Practices First paragraph First sentence, added limits and controls and deleted effective Administrative Update
M180107 US NRC May 10, 2018 Page 3 of 10 SNM-1097 License Application Chapter Change Table Section Description of Change Reason for Change Continued:
Section 5.4.1, Control Practices Second sentence deleted Prior to use in any enriched uranium process, nuclear criticality safety controls are verified against criticality safety analysis criteria. The ISA program described in Chapter 3 implement performance based management of process requirements and specifications that are important to nuclear criticality safety.
and added The Area Manager, with NCS support, implements the limits and controls documented in the CSA.
Clarification that the Area Manager is responsible for establishing controls necessary for the CSA Section 5.4.1.1, Verification Program First paragraph, third sentence changed Criticality safety function personnel observe or monitor the performance of initial functional tests and conduct pre-operational audits to verify that the controls function as intended and the installed configuration agrees with the criticality safety analysis. To Criticality safety function personnel conduct pre-operational audits (e.g.,
field verification of design features, functional test review), as needed, to verify that the installed configuration agrees with the criticality safety analysis.
Second paragraph, first sentence deleted subsequent and changed or verification to or other verification means Clarification to provide a better description of the verification program Clarification Section 5.4.1.2., Maintenance Program Changed first sentence from The purpose of the maintenance program is to assure that the effectiveness of IROFS designated for a specific process are maintained at the original level of intent and functionality. to The purpose of planned and scheduled maintenance of safety controls is to assure that systems are kept in a condition of readiness to perform the planned and designed functions when required.
Second sentence added calibration Clarification of maintenance program Administrative update
M180107 US NRC May 10, 2018 Page 4 of 10 SNM-1097 License Application Chapter Change Table Section Description of Change Reason for Change Section 5.4.2, Means of Control Changed simple administrative controls to administrative controls in the fourth sentence Administrative update Section 5.4.2.1, Passive Engineered Controls First sentence deleted without any required human action from first sentence.
Added second sentence Beyond appropriate installation, a passive engineered control requires no human action to perform its safety function Clarification Clarification of a passive engineered control Section 5.4.2.2, Active Engineered Controls First sentence deleted without any required human action from first sentence.
Added second sentence Beyond appropriate installation, an active engineered control requires no human action to perform its safety function in second sentence Last sentence changed controls are designed to be fail-safe (i.e., meaning failure of the control results in a safe condition). to controls that are designed to be fail-safe (i.e., meaning failure of the control results in a safe condition) are preferred Clarification of an active engineered control Clarification of an active engineered control Clarification of an active engineered control Section 5.4.2.3, Administrative Controls Deleted first sentence Either an augmented administrative control or a simple administrative control as defined herein:
Second bullet changed Simple Administrative Controls to Administrative Controls First sentence, last paragraph changed is to should be Administrative Update Administrative Update Administrative Update Section 5.4.3, Specific Parameter Limits First sentence changed safe geometry values of Table 5.1 below are specifically licensed for use to favorable geometry values of Table 5.1 contain dimensions for sphere, cylinder, and slab which may be used for applicable operations Clarification of safe geometry values
M180107 US NRC May 10, 2018 Page 5 of 10 SNM-1097 License Application Chapter Change Table Section Description of Change Reason for Change Continued:
Section 5.4.3, Specific Parameter Limits Second sentence, first paragraph added and the moderating material is not more effective than water Second paragraph Deleted or explicit stochastic or deterministic modeling methods and added last sentence When not applicable, the Criticality Safety Engineer may use approved validated stochastic or deterministic codes to determine subcritical limits First sentence, third paragraph changed are specifically licensed for use at GNF-A to may be used for applicable operations at GNF-A.
Application of these safe batch values is limited to situations where the neutron reflection present does not exceed that due to full water reflection and the moderating material is not more effective than water.
Added second sentence to third paragraph Application of these safe batch values is limited to situations where the neutron reflection present does not exceed that due to full water reflection and the moderating material is not more effective than water.
Changed kgs to kg in formula Deleted bullet point Where engineered controls prevent over batching, a mass of 75% of the minimum critical mass shall not be exceeded.
Changed Subject to provision for adequate protection against precipitation or other circumstances which may increase concentration, the following safe concentrations are specifically licensed for use at GNF-A: to The safe concentration values below may be used for applicable operations at GNF-A subject to provision for adequate protection against precipitation or other circumstances which may increase concentration. In paragraph under second bullet Clarification of application of geometry controls Clarification of the dimensional limitations of Table 5.1 Administrative Update Clarification of safe batch values Typographical Correction Clarification - No longer used Clarification of safe concentration values
M180107 US NRC May 10, 2018 Page 6 of 10 SNM-1097 License Application Chapter Change Table Section Description of Change Reason for Change Table 5.1 Favorable Geometry Values Change table title from Safe to Favorable Clarification Table 5.2, Safe Batch Values for UO2 and Water Changed Kgs to kg in table Typographical Correction Section 5.4.4.1, Geometry First paragraph, fourth sentence changed conservatively assuming unlimited water or concrete equivalent reflection, optimal hydrogenous moderation, worst credible heterogeneity, and maximum credible enrichment to be processed. to conservatively assuming worst credible conditions (e.g., reflection, moderation, heterogeneity, and enrichment) for the material to be processed.
Clarification of favorable geometry control Section 5.4.4.2, Mass First paragraph, first sentence changed Mass control to Mass Third sentence added along with adequate measurement uncertainty Second paragraph, first sentence changed potential to worst credible Deleted last sentence in second paragraph Administrative Update Clarification of mass control methods Clarification of mass control methods Clarification of mass control methods Section 5.4.4.3. Moderation First paragraph, first sentence changed Moderation to Moderator Added second sentence Moderator control areas shall be defined in the process evaluation in which moderators are limited and controlled for nuclear criticality First paragraph, third sentence changed from When moderation is used in conjunction with other control methods, the area is posted as a moderation control area. to For areas where moderation is used in conjunction with other control methods, the area is classified as a moderation control area (MCA)
Administrative Update Clarification of moderation control Clarification of moderation control
M180107 US NRC May 10, 2018 Page 7 of 10 SNM-1097 License Application Chapter Change Table Section Description of Change Reason for Change Continued:
Section 5.4.4.3. Moderation First paragraph, last sentence deleted primary design focus and is designated as a the, changed posted to classified as a, and added (MRA)
Deleted second paragraph and bullet points deleted and added Process evaluations for MCA/MRA designated areas shall explicitly identify the limits, controls, and engineered barriers for designated moderator control areas.
Material properties, credible moderator present in, introduced to, or accumulated in an MCA/MRA shall be considered. Credible non-uniform distribution of moderators, moderator content measurement, and fire suppression methods shall also be considered.
Clarification of moderation control area postings Clarification Section 5.4.4.4, Concentration (Density)
Deleted second and third sentence in first paragraph Administrative update for simplification Section 5.4.4.5, Neutron Absorber Changed second paragraph to last sentence in first paragraph Credit may also be taken for neutron absorber added to fuel, such as gadolinia.
Moved first bullet point to last bullet point and added For fuel bundles Added third paragraph and third bullet point Clarification of neutron absorber control Clarification of neutron absorber control Clarification of neutron absorber control Section 5.4.4.6, Spacing (or Unit Interaction)
Added may be to first sentence Added or arrays and deleted either of the following from second sentence Deleted or in first bullet Deleted the larger of in second bullet, added comma and moved remainder of bullet after or to a third bullet Clarification of spacing control Clarification of spacing control Clarification of spacing control Clarification of spacing control
M180107 US NRC May 10, 2018 Page 8 of 10 SNM-1097 License Application Chapter Change Table Section Description of Change Reason for Change Continued:
Section 5.4.4.6, Spacing (or Unit Interaction)
Deleted (e.g. Solid Angle methods from last paragraph second sentence Changed 5.3 to 5.4.5.5 in last sentence of last paragraph Clarification of spacing control Updated reference Section 5.4.4.8, Reflection Added first sentence Second sentence replaced Most with Generally Changed second sentence from However, subject to approved controls which limit reflection, certain system designs may be analyzed, approved, and operated in situations where the analyzed reflection is less than optimum. to However, subject to an approved analysis documenting controls or process conditions which limit reflection, certain system designs may be approved and operated in situations where the analyzed reflection is less than optimum.
Clarification of definition for reflection Administrative Update Clarification of definition for reflection Section 5.4.5.1, Keff Limit Deleted second sentence in first paragraph including applicable bias and bias uncertainty corrections, for credible process upset (accident) conditions are and added (keff) of the system plus three (3) times the standard deviation of the Monte Carlo code must be Second paragraph, second sentence changed accident to upset Clarification of definition of K effective Administrative Update Section 5.4.5.2, Analytical Methods First sentence added SCALE/KENO Changed Additional to Additionally and deleted Monte Carlo codes (e.g., Keno-Va. and MCNP) or Sn from second sentence Provided additional examples of analytical methods Administrative Update
M180107 US NRC May 10, 2018 Page 9 of 10 SNM-1097 License Application Chapter Change Table Section Description of Change Reason for Change Section 5.4.5.3, Validation Techniques Second paragraph under Minimum Margin of Subcriticality (MMS) added plus three (3) times the standard deviation for the Monte Carlo code Twelfth bullet added outlined in the validation report the USL is defined as and deleted For all benchmark experiments absolutely critical (kexp =
1.0)
Fifth paragraph changed accident to upset Seventh paragraph changed is to are Thirteenth bullet changed to to in and needed to included Clarification of definition of MMS Clarification of definition of MMS Administrative Update Grammatical correction Grammatical correction Section 5.4.5.4, Computer Software & Hardware Configuration Control Second sentence added For codes developed or modified at GNF Clarification Section 5.4.5.5, Criticality Safety Analysis (CSA)
First paragraph moved from Section 5.3.2.7 Changed The scope and content of any particular CSA reflects the needs and characteristics of the system being analyzed and includes applicable information requirements as follows: to The scope and content of any particular CSA reflects the needs and characteristics of the system being analyzed, as specified in internal procedures, and typically includes the following elements:
Added Process Description Methodology (e.g., computer code, area of applicability)
Criticality Safety Hazards (i.e., list of credible upset process conditions)
Assumptions, Design Features, Limits / Requirements Models, Sample input file, and Results Deleted remainder of section Administrative Update Administrative Update Administrative Update Administrative Update
M180107 US NRC May 10, 2018 Page 10 of 10 SNM-1097 License Application Chapter Change Table Section Description of Change Reason for Change Chapter 9 - ENVIRONMENTAL Figure 9.5c Locations of WT Series Wells Around Waste Treatment Facility (Typical)
Deleted well WT-2 Administrative Update Chapter 10 -
DECOMMISSIONING Changed date of current Decommissioning Funding Plan Administrative Update Chapter 11 - MANAGEMENT MEASURES Section 11.3.3 Surveillance/Monitoring Last Sentence, second paragraph Deleted reference to Table 3.7 Administrative Update