ML20058G604
| ML20058G604 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 02/27/2020 |
| From: | Murray S Global Nuclear Fuel |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| M200032 | |
| Download: ML20058G604 (6) | |
Text
Global Nuclear Fuel M200032 February 27, 2020 Jacob Zimmerman, Chief Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Attn: Document Control Desk Global Nuclear Fuel Scott P. Murray Manager, Facility Licensing 3901 Castle Hayne Road P.O. Box 780 Wilmington, NC 28402 USA T (910) 819-5950 Scott.murray@ge.com
Subject:
GNF-A Response to NRC Request for Supplemental Information
References:
- 1) NRC License SNM-1097, Docket 70-1113
- 2) GNF-A License Amendment Request, 10/31/19
- 3) Letter, J.l. Zimmerman to S. P. Murray, "GNF-AAcceptance Review and Request for Supplemental Information", 2/6/20
Dear Mr. Zimmerman:
Attached is Global Nuclear Fuel -Americas, LLC (GNF-A) response with the supplemental information that you requested on February 6, 2020 (Reference 3).
If you have any questions concerning this information, please call me at (91 0) 819-5950.
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Scott Murray, Man~
Facility Licensing ag/
Attachment(s): 1) GNF-A Response to NRC Request for Supplemental Information M. Bartlett, USNRC NMSS SPM 20-009
J. Zimmerman US NRC M200032 2/27/2020 Page 1 of 5 GNF-A Response to NRC Request for Supplemental Information for SNM-1097 8% Enrichment License Amendment Request NRC RSI 1: Provide a safety basis for the proposed increase in the enrichment limit, which gives reasonable assurance of adequate safety for the proposed change.
Describe how the proposed increase in enrichment is expected to impact plant operations and clarify how these changes will be analyzed (e.g., under 70.72) for compliance with the regulations and the license.
GNF-A RESPONSE TO RSI 1:
The SNM-1097 license amendment request was principally to permit nuclear fuel fabrication at material enrichments up to 8.0 wt.% 235U. GNF-A considers this a small extrapolation from existing enrichment limit of 5.0 wt.% 235U. Current internal criticality safety code validation report(s) remain valid in this range and have a well-defined statistical methodology to establish the Upper Subcritical Limit (USL) for each defined Area of Applicability. The current validation report has been provided to NRC staff; as well as the documented Criticality Safety Analysis (CSA) that determines the SNM-1097 License Application Table 5.1 and Table 5.2 subcritical limits. In this regard, the SNM-1097 license amendment was intended to demonstrate ability to calculate subcritical limits in the 5-8 wt.% 235U enrichment range, and provide licensed subcritical limits, for which the NRC staff can independently confirm. Process specific criticality safety analyses are conducted to demonstrate subcriticality under both normal and credible abnormal conditions. These CSAs may utilize Table 5.1 and Table 5.2 subcritical limits or explicitly derive subcritical limits in accord with Chapter 5, Section 5.4.5, Analysis Methods.
Pursuant to § 70.34, GNF-A has requested a license amendment to allow possession and processing of uranium enriched up to 8.0 wt.% 235U. Since the current enrichment limit is 5.0 wt.% 235U; the increase to 8.0 wt.% 235U is anticipated to result in changes to some criticality controls in ways that will affect the Integrated Safety Analysis (ISA). The degree of impact is actively being assessed.
SNM-1097 program commitments to document CSAs, conduct process hazards analysis (PHA), document quantitative risk assessments (QRA), and maintain the ISA Summary (ISAS) remain unchanged as a result of this license amendment request. GNF-A is currently re-evaluating documented CSAs for existing operations at the requested enrichment limit of 8.0 wt.% 235U. These re-evaluations are necessary to support fuel manufacturing at the higher assay to document the derivation of subcritical limits for process applications, and document new or modified controls. GNF-A is also currently re-evaluating radiological consequence calculations used to derive severity rankings for events in the PHA. These updates are necessary to account for the higher specific activity of the uranium at the new enrichment limit of 8.0 wt.% 235U. When the CSAs and radiological calculations are complete, the ISA documentation will be reviewed by an ISA Team to evaluate if revisions are required. These revisions will be approved and issued
J. Zimmerman US NRC M200032 2/27/2020 Page 2 of 5 when the necessary facility and document changes are implemented to support processing of uranium enriched up to 8.0 wt.% 235U.
As stated in our pre-application meeting conducted July 24, 2019, the ISA will be updated in accordance with internal procedures using the ISA program described in Chapter 3 of SNM-1097. GNF-A is not requesting any changes be made to the existing ISA program commitments in SNM-1097. The ISA will be revised through the Change Management program described in Chapter 3 and 11 of SNM-1097. Several changes are anticipated to support processing of uranium enriched up to 8.0 wt.% 235U. As described in Section 3.5.1 of SNM-1097, an evaluation will be performed of each change to determine if it requires prior approval by the NRC. Section 1.3.1.2 of SNM-1097 provides criteria for changes that do not require prior approval by the NRC, which are based on the criteria in § 70.72(c). If a change requires prior approval, then GNF-A will submit a supplemental amendment request with the associated ISAS revisions to the NRC for approval prior to implementing the change. Changes that do not require prior approval will be implemented as permitted by § 70.72(c) and included in the following annual ISAS submittal as described in Section 1.3.1.4 of SNM-1097.
§ 70.72(c) provides the following criteria for evaluating changes:
(c) The licensee may make changes to the site, structures, processes, systems, equipment, components, computer programs, and activities of personnel, without prior Commission approval, if the change:
(1) Does not:
(i) Create new types of accident sequences that, unless mitigated or prevented, would exceed the performance requirements of § 70.61 and that have not previously been described in the integrated safety analysis summary; or (ii) Use new processes, technologies, or control systems for which the licensee has no prior experience; (2) Does not remove, without at least an equivalent replacement of the safety function, an item relied on for safety that is listed in the integrated safety analysis summary and is necessary for compliance with the performance requirements of § 70.61; (3) Does not alter any item relied on for safety, listed in the integrated safety analysis summary, that is the sole item preventing or mitigating an accident sequence that exceeds the performance requirements of § 70.61; and (4) Is not otherwise prohibited by this section, license condition, or order.
J. Zimmerman US NRC M200032 2/27/2020 Page 3 of 5 SNM-1097 license condition 6(A) specifies an enrichment limit. As such the license amendment must be approved by the NRC to change that limit per § 70.72(c)(4). The GNF-A license amendment request to permit fuel fabrication up to 8.0 wt.% 235U does not itself require NRC prior approval based on § 70.72(c)(1 through 3). However, subsequent changes made to the facility and ISA to support processing of uranium enriched up to 8.0 wt.% 235U could require prior approval by the NRC.
Based on ongoing safety analysis work, the enrichment increase is not expected to create new types of accident sequences and there are no plans to use new processes, technologies, or control systems that GNF-A has no prior experience. In addition, there are currently no sole IROFS identified in the ISAS that could be altered. It is anticipated that changes will be made to existing IROFS, and some could be replaced with new IROFS as a result of control changes. As described above, GNF-A is committed to evaluating such changes in accordance with the existing Change Management program to determine if prior approval by the NRC is required.
NRC RSI 2(a): Describe the impact that the proposed request for higher enrichment will have on plant systems, the ISA, and ISA summary.
GNF-A RESPONSE TO RSI 2(a):
Ongoing CSA work is being managed to assess the impact of processing 8% enriched material. A structured re-evaluation effort of the factory is well underway. To date, this work has demonstrated the planned enrichment increase will require select modifications to existing processes and related IROFS (for example, favorable geometry liquid radwaste process tank dimensions now used at 5% enrichment, will likely require replacement with new favorable geometry tank dimensions to process 8% enriched liquid waste). In addition, existing IROFS mass limits may also need adjustment (for example, the current gross weight limit on the 3-gallon container at 5% enrichment, will likely be reduced to support general can storage configurations at 8% enrichment).
Additional work on primary HEPA filtration systems has demonstrated that select primary HEPA housings that now rely on favorable geometry HEPA cartridges will likely need modification to a new housing or new filter cartridge design.
Impact of changes from the re-evaluated nodal CSAs will identify changes in parameter controls that are necessary to accommodate the increase in the maximum process enrichment limit. Changes or modifications to existing parameter controls used to satisfy double contingency principle will in turn will be evaluated on a node by node basis for impact to the current IROFS and ISA documentation.
J. Zimmerman US NRC M200032 2/27/2020 Page 4 of 5 NRC RSI 2(b): Confirm that all changes to the plant to support the increased enrichment will be evaluated consistent with GNF-As approved change process.
GNF-A RESPONSE TO RSI ITEM 2(b):
As stated in GNF-A response to NRC RSI 1 above, the GNF-A facility modifications will be analyzed separately under the existing GNF-A change management program now described in SNM-1097.
NRC RSI 2(c): Clarify if the change in enrichment will result in environmental impacts or if the proposed changes are categorically excluded.
GNF-A RESPONSE TO RSI ITEM 2(c):
10CFR51.22(c) states:
The following categories of actions are categorical exclusions:
(c)(11) states:
Issuance of amendments to licenses for fuel cycle plants and radioactive waste disposal sites and amendments to materials licenses identified in § 51.60(b)(1) which are administrative, organizational, or procedural in nature, or which result in a change in process operations or equipment, provided that (i) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, (ii) there is no significant increase in individual or cumulative occupational radiation exposure, (iii) there is no significant construction impact, and (iv) there is no significant increase in the potential for or consequences from radiological accidents.
Based on ongoing analysis work, the enrichment increase does not cause a significant change in the types or amounts of any effluents that may be released offsite, there will be no significant increase in individual or cumulative occupational radiation exposure, there will be no significant construction impact, and there will be no significant increase in the potential for or consequences from radiological accidents.
As a result, the GNF-A license amendment to permit fuel fabrication up to 8.0 wt.% U235 will not result in significant environmental impacts and meets the 10CFR51.22(c)(11) criterion for categorical exclusion not requiring an environmental review.
J. Zimmerman US NRC M200032 2/27/2020 Page 5 of 5 NRC 2(d): Provide a commitment for an operational readiness review.The readiness review should focus on those areas of the plant impacted by the proposed increase in enrichment.
GNF-A RESPONSE TO RSI ITEM 2(d):
GNF-A commits to an NRC staff operational readiness review prior to possessing or processing licensed material above the current limits in license condition 6(A).
NRC RSI 3(a): Provide a discussion of the appropriate updates to all safety basis documents, including the ISA.
GNF-A RESPONSE TO RSI ITEM 3(a):
As stated in GNF-A Response to NRC RSI 1 above, GNF-A plans to re-evaluate and revise affected safety basis documents including the ISA under the existing GNF-A change management program now described in SNM-1097.
NRC RSI 3(b): Provide a revised ISA summary with this amendment request per 10 CFR 70.65(b) or a justification for why it is not necessary.
GNF-A RESPONSE TO RSI ITEM 3(b):
As stated in GNF-A Response to NRC RSI 1 above, the ISAS revisions will be made when safety analysis re-evaluations at the new enrichment limit of 8.0 wt.% 235U are completed. These changes will be made in accordance with the existing Change Management program described in SNM-1097. Changes that require prior approval by the NRC will be submitted in subsequent amendment requests for approval. Changes that do not require prior approval will be submitted in the following annual ISA Summary submittal. Refer to response 1 for additional information.