ML21158A290

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

© 2021 Louisiana Energy Services, LLC James Freels, P.E.

LEU+ Project Licensing Consultant Public Meeting Low Enriched Uranium Plus (LEU+) Project

2

Introductions

• Urenco USA

• 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

3 Agenda

• Introductions

• Meeting Objectives

• Background information regarding LEU+ Project

• Urenco USA Technological Capabilities for LEU+

• Regulatory Interactions

• Proposed Schedule

• Questions

4 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

5 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

6 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

7 Background Information for LEU+ Project

• Potential Impacts of Increasing Enrichment Security/Safeguards Arrangements

• Increasing enrichment levels to less than 10% will not change NRC Category for special nuclear material at the Urenco USA facility.

• 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

8 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

9 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 (IROFS)

QL-1 Graded (G)

QL-1 Fire Protection (F)

QL-2 Administrative Controls (AC)

QL-3 Commercial Grade

10 10 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

11 11 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

12 12 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 bottlenecks

13 13 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

14 14 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

15 15 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

16 16 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

17 17 LEU+ Project Questions?