ML18144A796

Louisiana Energy Services, LLC Safety Analysis Report (SAR) Update

ML18144A796
Person / Time
Site:	07003103
Issue date:	05/21/2018
From:	Cowne S Louisiana Energy Services, URENCO USA
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
LES-18-063-NRC
Download: ML18144A796 (11)

Text

LES-18-063-NRC Attn: Document Control Desk Director MAY 2 1 2018 Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Louisiana Energy Services, LLC NRC Docket No. 70-3103

Subject:

Safety Analysis Report (SAR) Update In accordance with Materials License SNM-2010, Condition 30, Louisiana Energy Services (LES), dba URENCO USA (UUSA) herewith submits the Safety Analysis Report (SAR) changes made under UUSA's authority. contains the marked up pages to the Safety Analysis Report for revision 43.

A description of each change is provided in the revision history. Revision bars, strikethroughs and underlines were utilized.

Should there be any questions regarding this submittal, please contact Wyatt Padgett, UUSA Licensing and Performance Assessment Manager, at 575-394-5257.

Respectfully,

g(fn~

Chief Nuclear Officer and Compliance Manager

Enclosure:

1)

Marked up pages of the Safety Analysis Report.

LES.PO Box 1789, Eunice, New Mexico 88231, USA T: + 1 575 394 4646 F: + 1 575 394 4545 W: www.urenco.com/LES

LES-18-063-NRC CC: via email (without attachments)

Mike G. Raddatz, Senior Project Manager U.S. Nuclear Regulatory Commission Michael.Raddatz@nrc.gov Marvin Sykes, Chief - Fuel Facility Branch 1 U.S. Nuclear Regulatory Commission Marvin.Sykes@nrc.gov Jacob Zimmerman, Branch Chief - Enrichment and Conversion Branch U.S. Nuclear Regulatory Commission Jacob.Zimmerman@nrc.gov Marked up pages of the Safety Analysis Report (revision bars, strikethroughs and underlines utilized)

SAFETY ANALYSIS REPORT Revision 4342a LES, PO Box 1789, Eunice, New Mexico 88231, USA T* +1 575 394 4646 r +1575394 4545 www.urenco.corr Copyrlght02010 LES

Table of Contents Summary of Changes Issue/

Change Description of Change Date LBDCR 17-0006 MFDT Enriched Operations CC-RW-2015-0003

70. 72 - 2017-0025 Replaces carbon/aluminum oxide mixed.bed Type 'A' trap on the feed sampling pump/trap sets with a Type 'A' trap filled with sodium LBDCR-17-0012 fluoric:1 and aluminum oxide.

MOD-17-0152 70.72 - 2017-0076 43 Modification of the SRC audit freguency based on NRC Approval of LBDCR-17-0022 SRC Audit Frequency (IN-12-0081-NRC)

CC-LS-2015-0001; 70.72 - 2015-0285 Removal of fluorinated carbon from a chemical traQ under an LBDCR 18-001 inert atmosQhere for samQling QUrQoses CC-RW-2017-0003 70.72-2018-0015 Safety Analysis Report Revision

2.2 Key Management Positions 2.2.3 Safety Review Committee The facility maintains a Safety Review Committee (SRC) to assist with the safe operation of the facility. The SRC reports to the Chief Nuclear Officer and provides technical and administrative review and audit of operations that could impact plant worker, public safety and environmental impacts. The scope of activities reviewed and audited by the SRC shall, as a minimum, include the following:

• Radiation protection

• Nuclear criticality safety

• Hazardous chemical safety Industrial safety including fire protection

• Environmental protection

• ALARA policy implementation

• Changes in facility design or operations.

LBDCR-17-0022 The SRC shall ensure construction and operational conduct at least one facility audit§_ per year for the above areas are conducted according to the frequencies specified in Section 11.5.2.

SRC review of audits completed by the QA Department can be credited for meeting SRC review and auditing requirements.

The Safety Review Committee shall be composed of at least five members, including the Chairman. Members of the SRC may be from the LES corporate office or technical staff. The five members shall include experts on operations and all safety disciplines (criticality, radiological, chemical, industrial). The Chairman, members and alternate members of the Safety Review Committee shall be formally appointed by the Chief Nuclear Officer, shall have an academic degree in an engineering or physical science field; and, in addition, shall have a minimum of five years of technical experience, of which a minimum of three years shall relate directly to one or more of the safety disciplines (criticality, radiological, chemical, industrial).

The Safety Review Committee shall meet at least once per calendar quarter.

Review meetings shall be held within 30 days of any incident that is reportable to the NRC.

These meetir;1gs may be combined with regular meetings. Following a reportable incident, the SRC shall reviewthe incident's causes, the responses, and both specific and generic corrective actions to ensure resolution of the problem is implemented.

A written report of each SRC meeting and audit shall be forwarded to the Chief Nuclear Officer and appropriate Managers within 30 days and be retained in accordance with the records management system.

2.2.4 Personnel Qualification Requirements The minimum qualification requirements for the facility functions that are directly responsible for its safe operation shall be as outlined below consistent with NUREG-1520. This includes the Chief Nuclear Officer, Operations Manager, Compliance Manager, Shift Managers, and managers for various safety and environmental disciplines. "Responsible nuclear experience" for these positions shall include (a) responsibility for and contributions towards support of Safety Analysis Report Page-2.2-7 Rev 43~

3.6 Chapter 3 Tables Table 3.4-1 Administrative Control lROFS Support Equipment Monitoring Support Equipment Operated Other Equipment IROFS Equipment Other Equipment Attributes Support Equipment Attributes Equipment IAStHJFA9At fGF deteFFAiAiAg ite1+1 Accmate aAd IROJ;S15 Nooe Nooe

. Nooe Nooe C9AtaiAS A9 eAFicl=ied Feliaele iAdicatieA l:lFaAic 1+1ateFial Instrument for Non LBDCR None viewing cylinder e

17-0006 None None None internal IROFS16a Pressure transducer and local digital display None Accurate and None None None

• (Note 2) reliable indication Weighing Scale System including local digital readout Accurate and from weighing system at the None None None None cylinder stations reliable indication IROFS16e

• (Notes 2 & 3)

Pressure transducer and local Accurate and digital display None None None None

• (Note2) reliable indication Weighing Scale System including local digital readout Accurate reliable IROFS16f from weighing system at the None None None None cylinder stations indication

• (Notes 2 & 3)

Pressure transducer and local Accurate reliable IROFS16f digital display None None None None

• ( Note 2) indication Safety Analysis Report Page-3.6-15 Rev

3.6 Chapter 3 Tables Monitoring Support Equipment Operated Other Equipment IROFS Equipment Other Equipment Attributes Support Equipment Attributes Equipment enrichment level Slab Tanks) liquid sample (wt.% 235LJ),

independent of IROFS55b N/A LBDCR lnstrument(s) for 17-0006 determining uranium Accurate and Circulation Supports withdrawal IROFS55b enrichment level (wt.

reliable indication N/A pumps (for of representative

% 235U), independent Slab Tanks) sample of IROFS55a Instrument for determining gross Accurate and IROFS56a None 235U content None None None reliable indication inde12endent of IROFS56b Instrument for determining gross Accurate and IROFS56b None 235U content None None None reliable indication inde12endent of IROFS56a Instrument for determining gross Accurate and Circulation Su1212orts withdrawal IROFS57a None 235U content None 12um12s (for of re12resentative reliable indication inde12endent of MFDT baths}

sam12le IROFS57b Instrument for determining gross Accurate and Circulation Su1212orts withdrawal IROFS57b None 235U content None 12um12s (for of re12resentative reliable indication inde12endent of MFDT baths}

sam12le IROFS57a Instrument for Accurate and IROFS58a None determining gross reliable indication None

. None None 235U content IROFS58b None None None None Storage Array Provides adequate Safety Analysis Report Page-3.6-19 Rev

3.6 Chapter 3 Tables Monitoring Support Equipment Operated Other Equipment IROFS Equipment Other Equipment Attributes Support Equipment Attributes Equipment spacing None Accurate and reliable indication Provides enclosure Oxygen Sensor None Glove Bag LBDCR of disi:2lacement for inert gas IROFS60 18-001 of 02 by inert gas None None None None Inert Gas Provides non-reactive environment None None None None Inert Gas Provides non-reactive environment IROFS61 None None None None Mobile Rigs Provides method of

~

1) Weigh Scale System including local digital readout

1) Accurate and from weighing system at reliable indication Select cylinder station *(Notes 2 and independent

3)

None isolation None Valve closure valves IROFSC22

2) vent system cold trap load

2) Accurate and

• (Note 2) cells *(Notes 2 and 3) reliable indication Instrument for Verify N/A determining cylinder

3) Accurate and N/A CASCAL Accurate and reliable reliable indication settings content assay document

• (Note 1 Deleted

• (Note 2) Support Equipment meets the requirements for QA Level 2AC.

• (Note 3) An exception to License Condition 20 has been approved by the NRC for this equipment.

Safety Analysis Report Page-3.6-20 Rev

6.2 Chemical Process Information 6.2.1.2.2 Chemical Traps - Activated Carbon, Aluminum Oxide, and Sodium Fluoride Adsorption is the attraction of gas molecules to the surface of an activated solid. There are two classifications of adsorption: physical and chemical. At ordinary temperatures, adsorption is usually caused by molecular forces rather than by the formation of chemical bonds. In this type of adsorption, called physical adsorption, very little heat is evolved. If a chemical reaction takes place between the gas and the solid surface, the process is known as chemisorption. In chemisorption the reaction between surface and gas molecules occurs in a stoichiometric manner, and heat is liberated during the reaction.

Chemisorption is used in the removal of UF6, HF and trace amounts of F2from gaseous effluent streams. It is also used to remove oil mist from vacuum pumps operating upstream of gaseous effluent vent systems. Adsorbent materials are placed on stationary beds in chemical traps downstream of the various cold traps. These materials capture HF and the trace amounts of UF5 that escape desublimation during feed purification or during venting of residual UF5 contained in hoses and/or piping that is bled down before disconnection.

The chemical traps are placed in series downstream of the cold traps in the exhaust streams to the GEVS and may include one or more of a series of three different types of chemical traps; activated carbon or ~Jar traps, sodium fluoride (NaF) traps aluminum oxide (Alz03) traps, and mixed-bed traps, which contain ootR--activated carbon and Alz03 or NaF and Ale0 3 in the same housing. The activated carbon or NaF captures small amounts of UF6 that escape desublimation. Since chemisorption is a pressure sensitive process, HF is not fully adsorbed on carbon at low pressures. In addition, F2 passes through NaF. This necessitates a second type of trap containing a charge of Alz03 to remove HF and/or trace amounts of F2 from the gaseous effluent stream at normal system operating pressure. One or more of a series of these traps is used depending on the process system being served. Additionally, an oil trap (also containing Al20 3) is present on the inlet of the vacuum pumps to prevent pump oil from migrating back into the UF5 cold traps.

Chemisorption of UF6 on activated carbon evolves considerable thermal energy. This is not normally a problem in the chemical traps downstream of the cold traps because very little UF5 escapes desublimation. If multiple equipment failures and/or operator errors occur, significant quantities of UF5 could enter the chemical traps containing activated carbon. This could cause significant overheating leading to release. railuros associatod with tho carbon traps wore evaluated in the Integrated Safety Analysis.

Activated carbon cannot be used in the Contingency Dump System because the relatively high UF6 flow rates during this non-routine operation could lead to severe overheating. A chemical trap containing sodium fluoride (NaF) is installed in the contingency dump flow path to trap UF5.

NaF is used because the heat of UF6 chemisorption on NaF is significantly lower than the heat of UF5 chemisorption on activated carbon. Failures associated with the NaF traps were evaluated in the integrated safety analysis.

LBDCR-17-0012 There are no specific concerns with heat of adsorption of ei#lef-UF5~

or HF with Ab03.

Although the heat of absorption of HF on NaF and F2 on Al20 3 are relatively large, the quantity of HF or F2 present at a pump/trap set is relatively small. Failures associated with the sodium fluoride and aluminum oxide traps were evaluated in the Integrated Safety Analysis.

Safety Analysis Report Page-6.2-3 Rev

6.6 Chapter 6 Tables Table 6.1-5 Physical Properties of UFs Property Value Sublimation Point at 1.01 bar abs (14.7 psia) 56.6°C ( 133.8°F)

Triple Point 1.52 bar abs (22 psia) 64.1°C (147.3°F)

Density Solid @ 20°c (68°F) 5.1 glee (317.8 lb/ft3)

Liquid @ 64.1 °c ( 14 7.3°F) 3.6 glee (227.7 lb/ft3)

Liquid @ 93°c (200°F) 3.5 glee (215.6 lb/ft3)

Liquid@ 113°C (235°F) 3.3 glee (207.1 lb/ft3)

Liquid @ 121 °C (250°F) 3.3 glee (203.3 lb/ft3)

Heat of Sublimation @ 64.1 °C ( 147.3°F) 135,373 J/kg ( 58.2 BTU/lb)

Heat of Fusion @ 64.1 °C ( 14 7.3°F) 54,661 J/kg (23.5 BTU/lb)

Heat of Vaporization @ 64.1 °C ( 14 7.3°F) 81,643 J/kg (35.1 BTU/lb)

Specific Heat Solid @ 21°c (81 °F) 477 J/kg/°K (0.114 BTU/lb/°F)

Liquid@ 72°C (162°F) 544 J/kg/°K (0.130 BTU/lb/°F)

Critical Pressure 46.10 bar abs (668.8 psi a)

Critical Temperature 230.2°C (446.4°F)

LBDCR-17-0012 Table 6.2-1 Properties of Chemical Adsorbents Adsorbent (solid)/

Heat of Adsorption Capacity of Adsorption by Adsorbate (gas) weight Activated Carbon/UFs 293 kJ/kg (126 BTU/lb) 1: 1 Activated Carbon/HF negligible negligible at low pressure Aluminum Oxide/UFs negligible 0.2:1 Aluminum Oxide/HF negligible 0.2:1 Aluminum Oxide/F2 7824 kJ/kg Al20 3 0.12:1

{3364 BTU/lb Al20 3}

Sodium FluorideAGti>JateEl Naj;:/UFs 186 kJ/kg (80 BTU/lb) 1.0-1.5:1 Sodium Fluoride.A.Gtii,1ateEl ~Jai;:/HF 4,052 kJ/kg (1,742 BTU/lb) 1:0.5 Sodium Fluoride/F2 Negligible Negligible Safety Analysis Report Page-6.6-7 Rev

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