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3. Non-Proprietary Slide Presentation from 10-22-21 pre-application Meeting (Public)
	ML21308A608
Person / Time
Site:	Framatome ANP Richland
Issue date:	10/22/2021
From:	; Framatome
To:	; Division of Fuel Management
	Rick Jervey NMSS/DFM/FFL 301-415-6201
Shared Package
ML21308A607	List: ML21308A608; ML21308A610; ML21308A611; ML21308A612; ML21312A260;
References
	EPID L-2021-LRM-0111
	Download: ML21308A608 (27)
	v • d • e

Minimum Margin of Subcriticality to Support Licensing Advanced Fuel Management at the Richland Site October 2021 Framatome

Introductions

Framatome

Participants:

Remote Participation NRC

Participants:

Remote Participation Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 2

CONTENT 01 . Overview of Advanced Fuel Management 02 . Two-step Licensing Approach 03 . Project Schedule / Path Forward 04 . Wrap-up Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 3 Restricted Framatome (C=1) © Framatome - All rights reserved

1. Overview of Advanced Fuel Management (AFM)

Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 4

Advanced Fuel Management (AFM) Project As part of the continuing work under the U.S. Department of Energy Enhanced Accident Tolerant Fuel Program (EATF Award DE-NE0009034), Framatome is pursuing an increase in allowable U235 enrichment (>5.0 wt%) for the Horn Rapids Road fuel manufacturing site (HRR)

Advanced Fuel Management (AFM) is Framatomes internal project to implement increased fuel enrichment and increased fuel burnup within the DOE eATF program A key initial step of the AFM project is to obtain approval for the Minimum Margin of Subcriticality for enrichments above 5.0 wt% (MMS)

Equipment upgrades are current critical path.

No new technologies or processes are anticipated as a result of the effort to increase allowed enrichment.

Regulatory approval respecting the schedule is currently viewed as the biggest project risk.

Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 5

XXXXXXXX are Critical Path for AFM Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 6

2. Two-step Licensing Approach Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 7

Step 1 of Two-step Licensing Approach Obtain Approval for Minimum Margin of Subcriticality:

Complete Computer Code Validation for Enrichments above 5.0 wt%

The computer code validation effort will follow guidelines in NUREG/CR-6698

Request the following License change to be applicable for enrichments beyond 5.0 wt%

U-235:

5.4.2.1 The maximum evaluated neutron multiplication factor at normal and credible abnormal conditions shall not exceed k95/95 = 0.95 for normal conditions or 0.97 for worst case credible abnormal conditions, if justified by a sensitivity analysis. The documented justification accompanying this sensitivity analysis shall clearly discuss the sufficiency of the margin of subcriticality in terms of the parameters being controlled.

No other changes are being requested at this time Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 8

Minimum Margin of Subcriticality Amendment Request expected to be submitted in November 2021 Benchmark experiments from the International Handbook of Evaluated Criticality Safety Benchmark Experiments (IHECSBE) as well as benchmarks used in prior validation will be used Codes and Cross sections are limited to SCALE6.2/KENO-VI, ENDF/B-VII.1 continuous energy cross sections Area of applicability for calculation bias will include an upper limit on enrichment that will bound the future possession limit increase.

Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 9

Minimum Margin of Subcriticality The areas of applicability for calculation bias will be established for the following broad groups within this enrichment limit:

Low-moisture content Low-enriched uranium (LEU) systems

Moderated Homogeneous LEU systems

Moderated heterogeneous LEU Systems Sensitivity based Uncertainty Methods (S/U) are used to establish the applicability of the selected benchmarks experiments to application models for each group Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 10 Restricted Framatome (C=1) © Framatome - All rights reserved

AFM Project Licensing Step 2 Plan Pre-application meeting with the NRC For Possession Limit Increase

At least 12 months prior to sending in application meet and discuss:

Project Overview

Project Organization Structure

Project Schedule/milestones

Licensing plans and Schedule License Application and Supplemental Documents:

At least 24 months prior to desired startup provide the following with the license amendment application:

Integrated Safety Analysis Summary (10CFR70.65)

Physical Security Plan (10CFR 73)

Safeguards contingency plan depending on enrichment and materials (10CFR 73)

Fundamental Nuclear Material Control Plan (also need to update DIQ)

Emergency plan Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 11 Restricted Framatome (C=1) © Framatome - All rights reserved

Wrap-up Any final questions or comments from the NRC?

Any final questions or comments from the Framatome team?

Thank You!

Any reproduction, alteration, transmission to any third party or publication in whole or in part of this document and/or its content is prohibited unless Framatome has provided its prior and written consent.

This document and any information it contains shall not be used for any other purpose than the one for which they were provided. Legal action may be taken against any infringer and/or any person breaching the aforementioned obligations.

Acknowledgement This material is based upon work supported by the Department of Energy under Award number DE-NE-0009034, DE-NE0008818 and previously DE-NE0008220.

Disclaimer: This presentation was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof. The views and opinions expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 16 Restricted Framatome (C=1) © Framatome - All rights reserved

Legal Notice Editor and Copyright 2020: Framatome. It is forbidden to reproduce the present publication entirely or partially without prior consent in whatever form. Legal action may be taken against any infringer and/or any person breaching the aforementioned conditions.

Subject to change and error without notice. Illustrations may differ from the original. The contained statements and information are for advertising purposes only and do not constitute an offer of contract. They shall neither be construed as a guarantee of quality or durability, nor as warranties of merchantability or fitness for a particular purpose.

These statements, even if they are future-oriented, are based on information that was available to us at the date of publication. Type, quantity and characteristics of goods and services are subject to formal individual formal contracts.

Step 2 of Two-step Licensing Approach Next Framatome Actions:

Complete safety analyses based on the allowed MMSC

Establish Safety controls based on these analyses

No new technologies or processes are anticipated as a result of this effort Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 18 Restricted Framatome (C=1) © Framatome - All rights reserved

AFM Project Scope Step Two Evaluate each of the plant process equipment systems to determine the modifications required to support above 5.0 wt% U-235 enrichment.

Determine impacts of modifications during production and communicate

Determine recurring impacts/costs resulting from the plant modifications

Identify cost/schedule/manpower to implement

Proactively evaluate non-AFM changes during the design phase are evaluated against the AFM future state Perform Detailed Design Perform all Integrated Safety Analyses (ISAs) to support plant NRC license change Perform required plant modifications

Test and qualify plant modifications Obtain NRC approved update to plant license Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 19 Restricted Framatome (C=1) © Framatome - All rights reserved

Step 2 of Two Step Licensing Approach Request Possession Limit Change in enrichment Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 20 Restricted Framatome (C=1) © Framatome - All rights reserved

Step 2 of Two Step Licensing Approach The Possession Limit Change in enrichment to X.Y wt% U-235 will also include a request for the following change:

5.4.2.8 Designs shall assume 235U enrichment of X.Y wt.% unless at least one of the following criticality safety controls on enrichment is established:

Active engineered controls are established to verify enrichment and to prevent the introduction of uranium at unacceptable enrichment levels within the process system.

Administrative controls are established to prevent the introduction of unacceptable enrichments within a defined subsystem within the same area. Considerations shall include minimizing human error such as using physical separation of areas of differing enrichment limits when practical.

Step 2 of Two Step Licensing Approach All needed changes to the following will be included with this amendment request:

Integrated Safety Analysis Summary (10 CFR 70.65)

Physical Security Plan (10 CFR 73)

Safeguards contingency plan depending on enrichment and materials (10 CFR 73)

Fundamental Nuclear Material Control Plan

The DIQ will also be updated

Emergency plan Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 22 Restricted Framatome (C=1) © Framatome - All rights reserved

Step 2 of Two Step Licensing Approach UF6 cylinder design and licensing could be challenging.

Time required for the NRC license review may require the equipment design to be completed sooner than initially planned

Concerned NRC will not meet the 2026 date for issuing an updated license Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 23 Restricted Framatome (C=1) © Framatome - All rights reserved

Current Status - Technical Basis and Design Criteria Task: Create a technical basis and design criteria document which includes the following information for each sub-task. (Note: This document defines the problem to be solved and how it will be accomplished during the design process)

What technologies will be used. (R&D, Best Practices, Industrial Standards, etc.)

General background and working environment. (radiological, industrial, cleanliness, utility requirements, etc.)

Special Requirements. (product requirements, throughput rates, equipment availability, etc.)

Equipment acceptance requirements Status: Draft input was completed for each sub-task. The final consolidated document will be issued early next year.

Project Assumptions Key Assumptions relative to Licensing

Design, procurement, installation, testing and licensing activities will occur in parallel

All processes within the UO2 building will be upgraded to support the 6.5% enrichment

All modifications will be completed, tested and qualified prior to introduction of >5% material

All licenses will be approved prior to introduction of >5% material

Waste disposal paths will remain unchanged Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 25 Restricted Framatome (C=1) © Framatome - All rights reserved

Activities Underway - Preliminary Design Initial ISA/PHA/IROFS Review Safety Meetings- Slightly behind

Systematic preliminary review of all impacted safety documents with team

Review assumptions made in draft IA (investment authorization)

To maintain capacity, buckets will likely require replacement Risk Assessment and Risk Mitigation Plan- Currently underway

Using Framatome standard methodology

Meetings have begun- Preliminary list of project risks created. Sub-task risk lists being developed

Multiple meetings already held with Richland Site Management to ensure risk are identified and mitigated

Regulatory approval respecting the schedule is currently the biggest risk Detailed WBS Task List- Progressing well

Detailed WBS for each sub-task currently being created.

Will be used to create an overall implementation resources loaded WBS for the entire project

Other Licenses Potentially Impacted by This Project WDOH Licenses

Radioactive Air Emissions License (RAEL)

APQ (by isotope) for each area serviced by an exhaust stack

BACT Analysis if a new or modified stack license is needed

Radioactive Materials License (RML)

No change to this license is anticipated BCAA Permit

No change to this permit is anticipated City of Richland (COR) Wastewater Discharge Permit

No change to this permit is anticipated IAEA DIQ

A change to the DIQ will be required Pre-licensing discussion on minimum margin of subcriticality for 5 wt% U-235 - Tim Tate - Oct. 22, 2021 27 Restricted Framatome (C=1) © Framatome - All rights reserved

v t e Letter Sequence Meeting
EPID:L-2021-LRM-0111, Slides from Framatome Closed Meeting of 10-22-21 - EPID L-2021-LRM-0111 (Open)
Initiation Request Acceptance... Administration Meeting, Meeting Questions Answers Results Approval... Other: ML21308A610, ML21308A612, ML21312A260, ML21335A328
MONTHYEAR2021-10-22 [Table View]

ML21308A608

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