ML22014A421
| ML22014A421 | |
| Person / Time | |
|---|---|
| Site: | Erwin |
| Issue date: | 01/21/2022 |
| From: | James Downs NRC/NMSS/DFM/FFLB |
| To: | Knowles T Nuclear Fuel Services |
| James Downs NMSS/DFM/FFL 301-415-7744 | |
| References | |
| EPID L-2021-LLA-0213 | |
| Download: ML22014A421 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 21, 2022 Mr. Timothy Knowles, Director Safety and Safeguards Nuclear Fuel Services, Inc.
1205 Banner Hill Road Erwin, TN 37650
SUBJECT:
REQUEST FOR SUPPLEMENTAL INFORMATION - APPLICATION FOR U-METAL LICENSE AMENDMENT - ENTERPRISE PROJECT IDENTIFICATION NUMBER L-2021-LLA-0213
Dear Mr. Knowles:
The U.S. Nuclear Regulatory Commission (NRC) staff has received the application from Nuclear Fuel Services, Inc. (NFS), transmitted by letter 21-G-21-0092 dated November 18, 2021 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML21327A099), for the license amendment request related to the uranium purification and conversion (U-metal) services proposed at the facility. The application was assigned Enterprise Project Identification Number (EPID) L-2021-LLA-0213.
The NRC staff performed an acceptance review of the U-metal application to determine if the application contains sufficient technical information in scope and depth to allow the staff to complete the detailed technical review. This letter is to advise NFS that, based on our acceptance review, the application does not contain sufficient technical information. The enclosed request for supplemental information (RSI) describes the information needed to continue our review.
In order to maintain the schedule for our review, the NRC staff is requesting a response to the RSI by February 25, 2022. If the information described is not received by this date, the U-metal application will not be accepted for review. This letter aligns with the e-mail from NRC to NFS on January 19, 2022, and phone call on January 20, 2022, that confirmed understanding of the draft RSI.
A copy of this letter and the enclosure will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records System component of ADAMS. The PDR is currently closed. You may submit your request to the PDR via e-mail at PDR.Resource@nrc.gov or call 1-800-397-4209 between 8:00 a.m. and 4:00 p.m. (EST),
Monday through Friday, except Federal holidays. The ADAMS database is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
T. Knowles 2 If you have any questions regarding this matter, please contact me at 301-415-7744 or by e-mail to James.Downs@nrc.gov.
Sincerely, James R. Digitally signed by James R. Downs Downs Date: 2022.01.21 11:52:27
-05'00' James R. Downs, P.E.
Senior Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.70-143 License No. SNM-124
Enclosure:
RSI on NFS U-metal License Amendment Request cc: nfs@listmgr.nrc.gov
ML22014A421 NMSS/DFM/ NMSS/DFM/ NMSS/DFM/
OFFICE FFLB/PM FFLB/LA FFLB/BC JPiotter for NAME JDowns ELee JZimmerman DATE 01/18/2022 01/19/2022 01/21/2022 Nuclear Fuel Services, Inc.
Erwin, TN 37650 Docket Number 70-143 License Number SNM-124 Request for Supplemental Information (RSI)
Enterprise Project Identification Number: L-2021-LLA-0213 By letter dated November 18, 2021 (Agencywide Documents Access and Management System Accession Number (ADAMS) ML21327A099), Nuclear Fuel Services, Inc. (NFS), submitted to the U.S. Nuclear Regulatory Commission (NRC) a license amendment request related to the uranium purification and conversion (U-metal) services proposed at the facility in Erwin, TN.
The following (RSI-1 through RSI-10) describes the information that is necessary for the NRC staff to continue the review.
RSI-1 (Fire Safety):
In accordance with 10 CFR 70.22(a)(7), the application must include a description of equipment and facilities to protect health and minimize danger to life or property. Furthermore, in accordance with 10 CFR 70.64(a)(4), the design of new facilities/processes must provide for adequate protection against fires and explosions. Additional guidance is available in Chapter 7 of NUREG-1520, Revision 2, Standard Review Plan for Fuel Cycle Facilities License Applications (ADAMS Accession No. ML15176A258).
NFS Site Integrated Safety Analysis (ISA) Summary Section 2.1 states that Utility Building 389 will be built to support the new U-metal process. The building will contain ventilation off-gas scrubber, liquid discard tanks, and several new chemical storage locations.
Since Building 389 is new construction, it plays a vital role in the new U-metal process, and is close to (i.e., could impact) the main process Building 301. Therefore, a description of the basic fire safety design elements of Building 389 is needed. The description may include, but is not limited to:
- 1. the structure type, material, insulation, weight support, and thickness of each building/room (e.g., wall, ceiling, floor, door, window),
- 2. ventilation and exhaust air/particulate systems (e.g., number, locations, and discharge rates of air/effluent outlet ducts),
- 3. temperature/smoke detectors and fire alarm system,
- 4. the separation distance and fire barriers, walls, windows, or other means to contain fire within each fire area,
- 5. electric systems in accordance with NFPA 70, National Electrical Code, and
- 6. the hourly rating of walls, floors, ceilings, doors, and windows per the International Building Code.
Additionally, Section 1.2.2, Facility, of the Emergency Plan (Revision 27-PP) states that the anhydrous hydrogen fluoride (AHF) delivery cabinets and AHF bottle storage are housed in Building 389. Due to the boiling point and melting point of the chemical compound AHF:
Enclosure
- 7. please describe the configuration and material of the AHF delivery cabinet and AHF bottle storage to prevent the potential chemical interaction of AHF and a fire hazard.
RSI-2 (Material Control and Accounting (MC&A)):
In accordance with 10 CFR 70.22(b), the application must contain a full description of the program for control and accounting of special nuclear material that will be in the applicant's possession under license to show how compliance with the requirements of 10 CFR 74.31, 74.33, 74.41, or 74.51, as applicable, will be accomplished. Additional guidance is available in Chapter 12 of NUREG-1520, Revision 2.
The Technical Overview provided in your submittal letter states that design considerations have been made, incorporating MC&A measurement points and inventory, operability, and maintenance activities. Although 10 CFR 70.32(c) allows, without prior NRC approval, for changes that would not decrease the effectiveness of the MC&A program, the NRC must make a determination that the proposed MC&A controls for the U-metal license amendment are adequate in accordance with 10 CFR 70.23(a)(6). Please provide information on the MC&A controls applicable to the U-metal process, elaborate on the design considerations referenced in your letter, and justify any determination made in accordance with 10 CFR 70.32(c).
RSI-3 (Financial Assurance):
In accordance with 10 CFR 70.25(e)(2), licensees must address eight factors as part of an update to the decommissioning funding plan. Additional guidance is available in the Interim Staff Guidance on Decommissioning Funding Plans for Materials Licensees (ADAMS Accession No. ML19079A314).
The following deficiencies must be addressed before the U-metal license amendment can be accepted for formal review:
- 1. Spills of radioactive material - the U-metal license amendment request does not discuss historic spills/releases.
- 2. Waste inventory increases - the U-metal license amendment request does not discuss waste inventory increases.
- 3. Waste disposal cost increases - the U-metal license amendment request does not discuss waste disposal cost increases.
- 4. Facility modifications - the U-metal license amendment request does not discuss facility modifications.
- 5. Changes in authorized possession limits - the U-metal license amendment request does not discuss changes in authorized possession limits. No affirmative statement was provided.
- 6. Actual remediation costs that exceed the previous cost estimate - the U-metal license amendment request does not discuss actual remediation costs that exceed the previous cost estimate.
- 7. Onsite disposal - the U-metal license amendment request does not discuss onsite disposal.
- 8. Use of a settling pond - the U-metal license amendment request does not discuss the use of a settling pond.
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RSI-4 (Financial Assurance):
In accordance with 10 CFR 70.25(e)(1)(ii), a licensee shall identify and justify the key assumptions used in preparing the decommissioning cost estimate. Additional guidance is available in the Interim Staff Guidance on Decommissioning Funding Plans for Materials Licensees. Please describe how any remaining inventory (i.e., radioactive material that is either licensee-owned, customer-owned, or in-process) would be moved offsite during decommissioning.
RSI-5 (Structural/Natural Phenomena Hazards (NPH)):
In accordance with 10 CFR 70.62(c)(1)(iv) and 10 CFR 70.62(c)(1)(v), a licensee shall conduct and maintain an ISA that identifies potential accident sequences caused by credible external events, including natural phenomena, the consequence and likelihood of occurrence of each potential accident sequence identified, and the methods used to determine the consequences and likelihoods. Additional guidance is available in Appendix D to Chapter 3 of NUREG-1520, Revision 2.
Describe how the ISA methodology, defined in Section 5.2 of the Site ISA Summary, considered NPH for the U-metal process in Building 301. In particular, address the following items regarding NPH for the U-metal process in Building 301:
- 1. Describe how the Process Hazard Analysis discussed in Section 4.2, Hazard Evaluations, Accident Sequences, and Consequence Calculations, of the Building 301 ISA Summary considered NPH.
- 2. Describe the accident scenarios that result from NPH.
- 3. Provide an analysis of the consequences of NPH.
- 4. Provide a risk assessment of NPH.
- 5. Describe the items relied on for safety (IROFS) and any associated management measures identified to prevent or mitigate the consequences of NPH.
Section 5.2, ISA Method, of the Site ISA Summary describes the ISA Method, which includes as the first step identifying accident scenarios from the hazard analyses for the consequence analysis. Section 4.2.5, External Event Consequences, of the Building 301 ISA Summary states that Section 1 of the NFS Site ISA Summary addresses earthquake, wind and storm, tornado, and flood hazards. However, Section 1, Site Description, of the Site ISA Summary does not identify accident scenarios for NPH or contain a discussion of a consequence analysis for NPH for U-metal production.
Section 5.2 of the Site ISA Summary describes the ISA Method of performing a risk assessment to evaluate high and intermediate consequence events and identifying IROFS needed to meet the performance requirements in 10 CFR 70.61. Section 4.3, Risk Assessment, of the Building 301 ISA Summary discusses and includes the results of the risk assessment for the U-metal production in Building 301. However, it is not clear to the staff, either from the discussion of the risk assessment in Section 4.3 or the results in Tables 4-5 through 4-8, how the risk assessment for the U-metal production in Building 301 considered NPH and if the licensee identified any IROFS for NPH.
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RSI-6 (Structural/NPH):
In accordance with 10 CFR 70.64(a)(2), the design of new processes at existing facilities shall provide for adequate protection against natural phenomena with consideration of the most severe documented historical events for the site. Additional guidance is available in Appendix D to Chapter 3 of NUREG-1520, Revision 2.
Describe how the baseline design criteria, including those for NPH, were addressed in the design of the systems, structures, and components (SSC) associated with the U-metal production process.
Section 6.2, Baseline Design Criteria for Credited IROFS, of the Building 301 ISA Summary states that the baseline design criteria are addressed through programmatic evaluations or specifically as part of the [e]ngineered design review process and that [f]or other design criteria such as seismic, environmental, dynamic effects, chemical protection, utilities, and instrumentation/controls, each criterion is considered individually for each IROFS as part of the design/review process. From these statements, it is not clear to the staff how the licensee has addressed the baseline design criteria for the U-metal production process. The staff requests a description of how the licensee has considered the baseline design criteria as part of a programmatic evaluation or the design and review process of each IROFS, particularly for design criteria for NPH.
RSI-7 (Structural/NPH):
In accordance with 10 CFR 70.22(a)(7), each application for a license to possess and use special nuclear material shall contain a description of equipment and facilities which will be used by the applicant to protect health and minimize danger to life or property. Additional guidance, specific to NPH, is available in Appendix D to Chapter 3 of NUREG-1520, Revision 2.
Provide a description and safety assessment of the design bases of the building structure and the internal SSCs in Building 389, the Utility Services Building, including provisions for protection against NPH.
Section 1.1.2, Facility Buildings and Structures, of the SNM-124 License Application describes Building 389 as containing [k]ey utility subsystems that support the processes for purification and conversion of uranium in Building 301 (e.g., process off-gas and scrubber system, gaseous utility feed system(s), waste discard tanks, etc. From this statement, it is not clear to the staff what the design bases of the principal SSCs are, how they ensure safety, or what provisions in the design protect against natural phenomena.
RSI-8 (Structural/NPH):
In accordance with 10 CFR 70.64(a)(2), the design of new processes at existing facilities shall provide for adequate protection against natural phenomena with consideration of the most severe documented historical events for the site. Additional guidance is available in Appendix D to Chapter 3 of NUREG-1520, Revision 2.
Describe how the baseline design criteria, including those for NPH, were addressed in the design of the building structure of Building 389 and the internal SSCs associated with the processes that support U-metal production in Building 389.
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Section 1.1.2, Facility Buildings and Structures, of the SNM-124 License Application provides only a brief description of the processes planned for Building 389. From this statement, it is not clear to the staff how the licensee has addressed the baseline design criteria in the design of the building structure and the internal SSCs for the planned Building 389.
RSI-9 (Structural/NPH):
In accordance with 10 CFR 70.62(c)(1)(iv) and 10 CFR 70.62(c)(1)(v), a licensee shall conduct and maintain an ISA that identifies potential accident sequences caused by credible external events, including natural phenomena, the consequence and likelihood of occurrence of each potential accident sequence identified, and the methods used to determine the consequences and likelihoods. Additional guidance is available in Appendix D to Chapter 3 of NUREG-1520, Revision 2.
Describe how the ISA methodology, defined in Section 5.2 of the Site ISA Summary, considered the processes that support U-metal production in Building 389, the Utility Services Building, including for NPH, and clarify whether there are any credited IROFS located in Building 389.
Section 1.1.2, Facility Buildings and Structures, of the SNM-124 License Application describes Building 389 as containing [k]ey utility subsystems that support the processes for purification and conversion of uranium in Building 301 (e.g., process off-gas and scrubber system, gaseous utility feed system(s), waste discard tanks, etc. As the licensee has only provided this description, it is not clear to the staff if the ISA methodology was applied to the processes planned for Building 389, if NPH were considered in the evaluation, or if IROFS were identified.
RSI-10 (Environmental):
A publicly available version of the Environmental Report is needed so NRCs evaluation can publicly demonstrate compliance with 42 U.S.C. 4332(2)(C). Additional guidance is available in Section 3.4.6 of NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs (ADAMS Accession No. ML032450279).
Section 102(2)(C) of the National Environmental Policy Act requires consideration of potentially unavoidable adverse environmental impacts should the proposed action be implemented. The responsible official (i.e., NRC) shall provide a detailed statement (i.e., publicly available) on the environmental impacts that should address both direct and indirect effects, and their significance. Also, the responsible official should consider potentially adverse impacts of alternatives to the proposed action. The discussion of adverse impacts should be thorough, yet brief. Detailed technical information may be incorporated by reference to publicly available materials, but proprietary data should not be incorporated by reference.
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