ML19052A428

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U.S. Department of Energy (DOE) Requests a Simple Content Amendment of NRC Certificate of Compliance (CoC) 9330 for the Model ATR Ffsc (NRC Docket 71-9330)
ML19052A428
Person / Time
Site: 07109330
Issue date: 02/20/2019
From: Shuler J
US Dept of Energy, Office of Packaging and Transportation
To: John Mckirgan
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
Download: ML19052A428 (3)


Text

Department of Energy Washington, DC 20585 February 20, 2019 Mr. John McKirgan, Chief Spent Fuel Licensing Branch U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Two White Flint North - Mail Stop 4 B34 11555 Rockville Pike Rockville, MD 20852-2738

Dear John McKirgan:

The U.S. Department of Energy (DOE) requests a simple content amendment of NRC Certificate of Compliance (CoC) 9330 for the Model ATR FFSC (NRC Docket 71-9330), no later than May 3, 2019. An amendment to the CoC is necessary to transport experimental loose fuel plates to be irradiated in Belgium as part of DOE's Office of Materials Management and Minimization program.

Several experimental loose fuel plates have been designed in the effort to convert the High Flux Isotope Reactor (HFIR) research reactor from using highly enriched uranium (HEU) fuel to low enriched uranium (LEU) fuel. The four plates and their abbreviations are given in the following table:

Fuel Plate Name Abbreviation FUTURE-HFIR Mono FUTURE-HFIR Mono FUTURE-HFIR U3Siz Curved Profile (IFE-ALTl)

FUTURE-HFIR IFE-AL Tl FUTURE-HFIR U3Siz (IFE) THIN FUTURE-HFIR IFE THIN FUTURE-HFIR U3Siz (OFE) THICK FUTURE-HFIR OFE THICK The Small Quantity Payload (SQ) category is described in Section 1.2.2.4 of the A TR FFSC Safety Analysis Report (SAR), Revision 14. The SQ payload category includes a class of research and development plate-type fuels with U-235 as the fissile isotope. The bounding U-235 quantity is :S 400 g with an enrichment of :S 94%. The following considerations demonstrate why the four loose fuel plate types may be shipped in the ATR FFSC package under the Small Quantity payload category by comparing their key physical and nucleonic characteristics to payload descriptions currently authorized in Section 5.(b)(l) of the NRC CoC, Revision 12.

All of the FUTURE-HFIR loose plate types have a construction similar to the other loose plates authorized by the CoC, having a central fuel region (sometimes called the "meat"),

completely surrounded by aluminum alloy cladding. All FUTURE-HFIR shipments shall use the Small Quantity Fuel Handling Enclosure (SQFHE).

The first fuel type, FUTURE-HFIR Mono, is bounded by the U-Mo foils sub-category, which is given in Section 5.(b)(l), paragraph 10 of the CoC as follows:

Docket 71-9330 Page 2 of3 U-Mo Foils. The U-Mo foils are composed of uranium molybdenum alloy in an aluminum-silicon matrix or uranium molybdenum alloy and may contain a zirconium coating. The uranium is enriched to a ma)cimum of 94 weight percent U-235. The maximum mass of U-235 is 160 grams.

More than one U-Mo foil type may be transported at a time. The U-Mo foils must be contained within the Small Quantity Payload Fuel Handling Enclosure, as specified in 5. (a)(3).

The comparison of the Mono fuel to the CoC paragraph is shown in the following table. Note that U-Mo foils is a loose plate sub-category.

Fuel Designation Fuel alloy & matrix Enrichment Mass U-235 FUTURE-HFIR U-Mo, U-I0Mo matrix,

C::20%

22.58g max. per Mono zirconium coating plate NRC CoC, Section

... uranium molybdenum

C::94%

160g maximum in 5.(b)(l), para 10 alloy in an aluminum-silicon this category matrix or uranium molybdenum alloy and may contain a zirconium coating.

The other three fuel types (FUTURE-HFIR IFE-ALTl, FUTURE-HFIR IFE THIN, and FUTURE-HFIR OFE THICK) are bounded by the COBRA loose fuel element plates sub category, which is given in Section 5.(b)(l), paragraph 15 of the CoC as follows:

COBRA loose fuel element plates: COBRA loose plates may either be flat or rolled to the geometry required for assembly into the fuel element and may be taped or wire-tied together. The U-235 content per COBRA loose plate is variable and may be HEU or LEU, but the total payload is limited to 400 grams of U-235. COBRA loose plates are transported as Small Quantity Payloads.

The comparison of these fuels to the CoC paragraph is shown in the following table.

Fuel Designation Fuel alloy & matrix Enrichment Mass U-235 FUTURE-HFIR IFE-19.00g max. per ALTI plate FUTURE-HFIR IFE U3Sh - Al dispersion

C::20%

THIN 9.07g max. per plate FUTURE-HFIR OFE 24.77g max. per THICK plate NRC CoC, Section Fuel alloy and matrix is

... may be 400g maximum in 5.(b)(l), para 15 not specified. (Of note, HEU or this category Section 5.(b)(l), para 9 LEU...

states that COBRA LEU fuel is U3Siz dispersed in aluminum powder.)

As shown in these two tables, the four specified FUTURE-HFIR loose plate types are bounded by existing Small Quantity payload loose plate categories, and can be added to CoC 9330 without additional structural, thermal, shielding, or criticality analyses.

Specifically, DOE requests the following changes to Revision 12 ofCoC 9330:

  • 5.(b)(l), 5th paragraph, change the first line to read: "Small Quantity Payloads (RINSC fuel elements, GRR-1 fuel elements, ATR Full-size plate In Flux Trap Position (AFIP) elements, U-Mo foils, Design Demonstration Elements (DDEs) and similar test elements, MÃT, COBRA or MURR loose fuel element plates, and FUTURE-HFIR loose plates)...

Docket 71-9330 Page 3 of 3

  • 5.(b)(l), 10th paragraph, add the following sentence to the end of the paragraph: "This category includes FUTURE-HFIR Mono loose plates."
  • 5.(b)(l), 15th paragraph, add the following sentence to the end of the paragraph: "This category includes FUTURE-HFIR IFE-ALTl, FUTURE-HFIR IFE THIN, and FUTURE-HFIR OFE THICK loose plates."

Due to the simple nature of this change, DOE requests CoC 9330 be amended based on this letter and in lieu of a revision to the SAR.

The May 3, 2019 need date is based on the shipping schedule of the plates to the BR-2 reactor in Belgium in support of the reactor conversion program, and the time needed for Competent Authority approval by DOT and the Belgian authorities.

If you have any questions or need more details please call at 301-903-5513 or james.shuler@em.doe.gov.

J Dr. James M. Shuler CC: ATTN: Document Control Desk Manager, DOE Packaging Certification Program U.S. Department of Energy Office of Packaging and Transportation EM-4.24, 270CC-Rm 3113 Washington, DC 20585 Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Mr. Pierre M. Saverot, Project Manager