ML21158A290

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LES Presentation for Public Meeting 2021-06-16
ML21158A290
Person / Time
Site: 07003103
Issue date: 06/16/2021
From: Freels J
Louisiana Energy Services
To:
Office of Nuclear Material Safety and Safeguards
KMRamsey NMSS/DFM/FFL 301.415.7506
References
Download: ML21158A290 (17)


Text

Public Meeting Low Enriched Uranium Plus (LEU+) Project James Freels, P.E.

LEU+ Project Licensing Consultant

© 2021 Louisiana Energy Services, LLC

Introductions

  • Steve Cowne, Chief Nuclear Officer
  • Rick Kohrt, LEU+ Technical Lead
  • Wyatt Padgett, Licensing and Performance Assessment Manager
  • Andy Thomas, LEU+ Project Manager
  • Jim Freels, LEU+ Licensing Consultant 2

Agenda

  • Introductions
  • Meeting Objectives
  • Background information regarding LEU+ Project
  • Urenco USA Technological Capabilities for LEU+
  • Regulatory Interactions
  • Proposed Schedule
  • Questions 3

Meeting Objectives

  • Communication with Stakeholders regarding LEU+

Project

  • Demonstrate continuous focus on Nuclear Safety, Security and any Environmental Impact for Project
  • Identify actions taken to date for Project implementation
  • Provide general timeline for Project implementation
  • Address non-proprietary Project-related questions 4

Background Information for LEU+ Project

  • Nuclear industry is interested in pursuing fuels with higher enrichments for reactors (e.g., Accident Tolerant Fuel (ATF) and Extended Fuel Cycle fuel)
  • Higher enrichment fuels can:
  • have better performance in design basis and severe accident conditions
  • widen existing safety margin for nuclear plants
  • extend operating cycles between refueling outages
  • allow for longer-lived fuel with increased enrichment (less replacement fuel during outages)
  • reduce nuclear plant operational and maintenance costs 5

Background Information for LEU+ Project

  • Urenco USA can contribute by providing needed fuel enrichment services
  • Nuclear industry higher enrichment fuels such as ATF fuel or Extended Fuel Cycle fuel may be less than 10% U235
  • Current maximum enrichment level is 5.5% U235 6

Background Information for LEU+ Project

  • Potential Impacts of Increasing Enrichment
  • Security/Safeguards Arrangements
  • Classification of fuel facility will remain at Category III
  • No additional physical site protection requirements needed
  • No changes to the Material Control and Accounting (MC&A) processes or programs are needed
  • Environmental Impact Statement
  • Preliminary review of impacts to environment of increasing enrichment levels to less than 10% identify no significant environmental impacts
  • No amendment to the Environmental Report is anticipated based on scope of proposed changes 7

Background Information for LEU+ Project

  • Regulatory Framework for ATF Licensing
  • NRC position(1):
  • 10 CFR Part 70, Domestic Licensing of Special Nuclear Materials is performance based; therefore, the staff does not anticipate identification of gaps or deficiencies in these regulations for the licensing of enrichment facilities to produce increased enrichment material
  • The current rigorous regulatory framework prescribes the processes for facility changes. Urenco USA will follow the established requirements during the LEU+ Project (1)

Project Plan to Prepare the U.S. Regulatory Commission for Efficient and Effective Licensing of Accident Tolerant Fuels, Version 1.1, ML19301B66, page A-2, October 2019, U.S. Nuclear Regulatory Commission 8

Urenco USA Technological Capabilities for LEU+

  • Urenco USA Project Plan (non-proprietary)
  • Use the applicable sections from 10 CFR 70:
  • 70.34: Amendment of licenses
  • 70.61: Performance requirements
  • 70.62: Safety program and integrated safety analysis
  • 70.72: Facility changes and change process
  • Reviews and processes are governed by Urenco USA Quality Assurance Program Description (QAPD)
  • Implements 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power plants and Fuel Reprocessing Plants
  • Other QAPD Quality Level categories can apply:
  • QL-1 Graded (G)
  • QL-1 Fire Protection (F)
  • QL-2 Administrative Controls (AC)

Urenco USA Technological Capabilities for LEU+

  • Urenco USA Project Plan (non-proprietary)
  • Urenco has produced a Technical Feasibility Report assessing ability and capability to implement LEU+ Project
  • Report concludes that the LEU+ Project is technically feasible and safe to implement pending review and potential completion of identified modifications and administrative measures to ensure plant safety
  • Potential changes needed may relate to:
  • Documentation
  • Operational procedures
  • Physical changes to design of equipment or systems
  • Broad Areas reviewed in Report
  • Nuclear criticality safety
  • Plant performance
  • Logistics 10

Urenco USA Technological Capabilities for LEU+

  • Urenco USA Project Plan (non-proprietary)
  • Nuclear criticality safety
  • Possible preliminary outcomes from review:
  • Existing design and control measures remain acceptable for LEU+
  • Existing design can be made safe with new, or changes to, the existing control measures
  • Existing design requires physical changes to ensure safe operation for LEU+
  • Plant performance
  • Reviews of:
  • Assays Units at Urenco USA
  • Cascade performance 11

Urenco USA Technological Capabilities for LEU+

  • Urenco USA Project Plan (non-proprietary)
  • Plant performance (continued)
  • Reviews of:
  • Flow rates
  • Cylinder take-off performance
  • Steady state, transient and mode transition conditions
  • Logistics
  • Reviews of potential work flow bottlenecks:
  • Product cylinder options
  • Contingency options to minimize/eliminate potential bottleneck s 12

Urenco USA Technological Capabilities for LEU+

  • Urenco USA Project Plan (non-proprietary)
  • Technical Feasibility Report Conclusions
  • Urenco USA can safely implement the LEU+ Program after validating the preliminary findings in the Technical Report for:
  • Nuclear Criticality Safety
  • Plant performance
  • Plant logistics
  • Any validated proposed changes, physical or administrative, will follow the rigorous regulatory processes previously identified for their evaluation, approval and implementation
  • Configuration management, as well as other management measures, will be followed for necessary document updates 13

Regulatory Interactions

  • 1 April 2021- Submittal of Notice of Intent to Submit License Amendment Requests for License Condition 6B and Enrichment Limit
  • Anticipated Meetings with NRC
  • Pre-submittal meeting to discuss overall approach
  • Pre-submittal meetings for each License Amendment Request
  • Submittal of License Amendment Request(s)
  • Current Licensing Management Plan
  • Redundant Items Relied on for Safety (IROFS), submitted 20 August 2020
  • Anticipated Programmatic Changes to Safety Analysis Report
  • Increasing Enrichment Level for production
  • Raising Enrichment Level for Support Systems
  • Reviews may result in additional LARs or information included in planned LARs 14

Regulatory Interactions

  • Requests for Additional Information (RAIs)
  • Anticipate questions from NRC technical review to be sent as RAIs
  • Responses will be submitted through normal correspondence procedure
  • Further discussions with NRC regarding RAI process will be held
  • NRC Operational Readiness Review (ORR)
  • It is anticipated that NRC will conduct an ORR prior to authorization to start production of higher enriched uranium.
  • The schedule for the ORR will most likely be dependent on NRC review of LAR for raising enrichment level.
  • Urenco USA staff will be ready and fully support ORR when scheduled 15

Proposed Schedule (non-proprietary)

  • Formal schedules are being developed for Project Work Breakdown Structure (WBS)
  • LARs are targeted for 2021 through 2024 and will be based on final reviews and approvals of necessary changes referenced in Technical Feasibility Report
  • Pre-submittal meetings with NRC will be targeted approximately one month prior to submittal
  • Close coordination and communications will be maintained through NRC Project Manager 16

LEU+ Project Questions?

17