ML20175A233
| ML20175A233 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 07/01/2020 |
| From: | Kevin Ramsey NRC/NMSS/DFM/FFLB |
| To: | Murray S Global Nuclear Fuel |
| MABartlett NMSS/DFM/FFL 415.7154 | |
| References | |
| Download: ML20175A233 (4) | |
Text
July 1, 2020 Mr. Scott P. Murray, Licensing Manager Global Nuclear Fuel - America 3901 Castle Hayne Road P.O. Box 780 Wilmington, NC 28402
SUBJECT:
CLOSURE OF THE GLOBAL NUCLEAR FUEL - AMERICAS, LLC AMENDMENT REQUEST TO INCREASE ENRICHMENT LIMIT FROM 5 TO 8 WEIGHT PERCENT AND ACCEPTANCE FOR FORMAL REVIEW OF THE PROPOSED MARGIN OF SUBCRITICALITY
Dear Mr. Murray:
The U.S. Nuclear Regulatory Commission (NRC) staff has received your letter dated June 23, 2020 (Agencywide Documents Access and Management System (ADAMS) ML20175A206),
which requests withdrawal of the request to amend Special Nuclear Material (SNM) License SNM-1097 to increase the enrichment limit in license condition 6(a) from 5.0 to 8.0 weight (wt.)
percent uranium (U)-235. The letter requests NRC to confirm that the licensees existing criticality safety and integrated safety analysis (ISA) methodologies would remain valid to support conducting analyses at 8 wt. percent. The letter also requests the NRC staff to proceed with the review of GNF-As minimum margin of subcriticality (MMS) to support future processing of enrichments up to 8 wt. percent.
Background:
The original request was submitted on October 31, 2019 (ADAMS Accession No. ML19304B896), and supplemented November 27, 2019 (Adams Accession No. ML19331A444),
and February 27, 2020 (Non-public ADAMS Accession No. ML20058G604). The NRC staffs acceptance review of these submittals determined insufficient information to support a detailed review of the enrichment amendment request, which was missing a description of the impacts on the facility, the safety basis, and updates to the ISA.
The NRC staff issued two rounds of requests for supplemental information (RSI) on February 6, 2020 (ADAMS Accession No. ML19350B458), and May 6, 2020 (ADAMS Accession No. ML20092G719) to obtain the necessary information. In response to the RSIs and other interactions, the GNF-A staff determined they need additional time to complete the analyses for the requested enrichment amendment, and to develop the corresponding safety basis documents. The NRC staff cannot accept the enrichment amendment request for review without a complete application. Therefore, the GNF-A staff submitted a letter to withdraw the enrichment amendment and requested that the NRC review the proposed MMS for use up to 8 wt. percent.
S. Murray 2
Withdrawal of Enrichment Amendment Request:
The NRC staff has ceased review of the enrichment amendment request and closed out the Enterprise Project Identification Number (EPID) L-2019-LLA-0245, based on your withdrawal letter. The total hours charged for the acceptance review for the enrichment amendment request, two rounds of RSIs, numerous briefings, alignment meetings, etc. total 209 hours0.00242 days <br />0.0581 hours <br />3.455688e-4 weeks <br />7.95245e-5 months <br /> which corresponds to about $58,102 ($278/hr).
The NRC staff remains committed to give casework for increased enrichments a high review priority compared to other casework as stated in the letter to the Nuclear Energy Institute dated August 26, 2020 (ADAMS Accession No. ML19235A265). This commitment is contingent upon licensees providing a high quality, complete license amendment request (LAR). As GNF-A moves toward development of this type of LAR to increase enrichment limit from 5 to 8 wt.
percent, you should consider holding a preapplication meeting with the NRC staff to discuss plans for the submittal. In the NEI letter mentioned above, the NRC staff identified that deployment of new types of reactor fuel by 2023 requires licensees to submit a high quality, complete LAR to the NRC no later than October 2021. The NRC staff is prepared to support the review of this type of LAR to increase the GNF-A enrichment limit from 5 to 8 wt. percent, once a complete review package is submitted.
Review of Criticality Safety and ISA Methodology:
The NRC staff previously reviewed the criticality safety and ISA programs defined in the license application for SNM-1097 and found reasonable assurance of adequate protection with respect to the applicable regulations. This finding was based, in part, on a review of criticality safety and ISA methodologies. The NRC does not anticipate any interdependence between the enrichment limit in license condition 6(a) and the criticality safety or ISA methodologies described in the license application. Therefore, the NRC has not identified any changes to the existing methodologies that are needed for GNF-A to proceed with internal safety bases evaluations to support a future amendment request to modify the enrichment limit. However, if GNF-A identifies the need for a change in the approved methodologies to support a future amendment request, the proposed change should be submitted for appropriate review and approval as part of the standard amendment process.
Acceptance of Request to Review the MMS for Use up to 8 wt. Percent:
The NRC staff has completed our acceptance of your request for review of the MMS for use up to 8 wt. percent. The NRC staff did not identify any administrative omissions or deficiencies that would prevent us from proceeding with a detailed review.
Please note that the NRC staffs technical review of your submittal may identify issues that require additional information. Based on our preliminary evaluation and projection of current review schedules, we anticipate completing our formal review by early fall. This date could change depending on the findings of our technical review, urgent assignments, or other factors.
We will promptly communicate any significant changes to this schedule. In addition, the NRC staff estimates that completing the review of your submittal will require approximately 100 staff hours, which corresponds to $27,800.00 ($278/hr).
In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room, or from the Publicly Available Records component of the NRCs ADAMS. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
S. Murray 3
If you have any questions regarding this communication, please contact me at 301-415-7506, or via e-mail to kevin.ramsey@nrc.gov.
Sincerely, Kevin Ramsey, Acting Chief Fuel Facilities Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 70-1113 License No. SNM-1097 cc: gnfa@listmgr.nrc.gov Kevin M.
Ramsey Digitally signed by Kevin M. Ramsey Date: 2020.07.01 14:10:14
-04'00'
ML20175A233 OFFICE DFM/FFLB/PM DFM/FFLB/LA DFM/NARA/BC DFM/FFLB/BC (A)
NAME MBartlett ELee (w/comment)
RChang KRamsey DATE 6-25-2020 6-25-2020 6-29-2020 07-01-2020