Text

GNF-A 8 Wt % License Amendment Request - Meeting Slides
	ML22104A092
Person / Time
Site:	07001113
Issue date:	04/14/2022
From:	Murray S; Global Nuclear Fuel - Americas
To:	Rowley J; Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
	M220066
	Download: ML22104A092 (20)
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GNii= Global Nuclear Fuel Global Nuclear Fuel Scott P. Murray Manager, Facility Licensing 3901 Castle Hayne Road P.O. Box 780 Wilmington, NC 28402 USA M220066 T (910) 819-5950 scott.murray@ge.com April 14, 2022 Jonathan Rowley, Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Materials Safety and Safeguards US Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Document Control Desk

Subject:

GNF-A 8 wt % License Amendment Request - Meeting Slides

References:

1) NRC License SNM-1097, Docket 70-1113

2) Letter, T.D. Naquin (NRC), to S. P. Murray (GNF-A) "Review of Minimum Margin of Subcriticality for up to 8 Weight percent Enrichment of Uranium -235 and Amendment 18", 8/13/20

Dear Mr. Rowley:

Attached to this letter are Global Nuclear Fuel-Americas (GNF-A) meeting slides regarding a proposed SNM-1097 license amendment to allow fuel fabrication using enrichments up to 8 weight percent uranium-235. This information is being provided for NRC staff review prior to a pre-application meeting scheduled on May 3, 2022.

The meeting slides do not contain proprietary information and can be made publically available.

If you have any questions concerning this information, please call me at (910) 819-5950.

Sincerely, Sci~Ei!?~

Facility Licensing V

Attachment:

GNF-A SNM-1097 License Amentment LEU+ Pre-Application Meeting Slides Cc: SPM 22-019

GNi=

Global Nuclear Fuel SNM-1097 License Amendment Pre-Application Meeting LEU+ Fuel Fabrication USNRC Rockville, MD May 3, 2022

Meeting Agenda

Why LEU+?

Proposed Licensing Action/Elements of Change

Criticality Safety Analyses (CSA)

Facility Modifications

Integrated Safety Analysis Summary

Environmental Impact Considerations

Anticipated License Chapter Changes

Summary/Schedule GNii=

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Why Higher Assay LEU?

LEU+ (Up to 8 wt. % U235) - LWRs

Existing BWRs/PWRs utilizing Accident Tolerant Fuel (ATF) designs such as Ironclad (FeCrAI cladding) or ARMOR coated zirc cladding types require higher enrichments to permit higher exposure (up to -80k MWD/MTU). Anticipated near term peak assay needs are 7 wt. % U235.

The value to reactor utility is very high, as overall fuel fabrication costs could decrease & overall fuel cycle length could be increased in the existing fleet of BWRs and PWRs.

LEU+ will also position PWRs to achieve a desired goal of month fuel cycle.

Higher exposures and longer cycles would also generate less spent nuclear fuel.

HALEU (Up to 20 wt. % U235 - not part of this request) - Advanced Reactor Fuels

Advanced reactors and novel reactor designs utilizing Sodium Fast Reactor (SFR) technology with metallic uranium fuel will require assays up to -20 wt. % U235 GNii=

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© 2022 General Electric Company - All rights reserved

GNF-A LEU+ Elements of Change SNM-1097 License Amendment (LA) approach GNi=

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Criticality Safety Analyses (CSA)

Technical analysis

GNF-A has re-evaluated the nuclear criticality safety bases associated with conversion of UF6 to UO2 and related ceramic and balance of plant processes to manufacture LWR fuel at the designated LEU+ enrichment limit (e.g., 8.0 wt.% U235)

A total of 44 nodal Criticality Safety Analyses (CSAs) were rebaselined to derive necessary subcritical limits and demonstrate double contingency principle was satisfied for all credible criticality safety hazards at 8 wt. % U235 enrichment.

Required changes to Passive Engineered Controls (PECs), Active Engineered Controls (AECs), Augmented Administrative Controls (AACs) and Administrative Controls (ACs) to support nuclear fuel conversion, fuel fabrication, and balance of plant support systems were systematically re-evaluated.

Implementation of the modified controls necessary to meet 10CFR70.61 performance requirements were systematically evaluated and IROFS changes likewise identified (discussed later in more detail).

Necessary changes to SNM-1097 Consolidated License Application Chapter 1 (General Information) and Chapter 5 (Nuclear Criticality Safety) have been drafted.

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Facility Modifications for LEU+ Project Overview

Low to intermediate impact on dry conversion process (DCP) /

powder product line systems located in designated Moderation Restricted Areas (MRAs).

Low to intermediate impact on ceramics fabrication processes including pelletization, grind, rod load, rod storage and bundle assembly systems located in designated Moderation Control Areas (MCAs).

Intermediate to high impact on balance of plant (BOP) support processes such as liquid radwaste systems - existing 5°/o favorable geometry equipment will be replaced or modified to permit material processing at 8 wt.% U235 enrichment.

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Integrated Safety Analysis Commensurate with the SNM-1097 license [amendment] application, an updated integrated safety analysis summary (ISAS) for the GNF-A fuel fabrication facility has also been prepared to demonstrate that high consequence accident sequences remain highly unlikely pursuant 10CFR70.

Criticality Safety Analyses Integrated Safety Analysis Summary Process Hazards Analysis GNii= Global Nuclear Fuel Quantitative Risk Assessments 7

Summary of ISA activities for LEU+ Project Incorporated results of rebaselined nodal criticality safety analyses (CSAs) at 8 wt. 0/o U235 enrichment limit into the GNF-A ISA program Prepared 9 new calculations to support the determination of accident consequence severity levels for all nodes Assessed the impact to all 25 PHAs, which resulted in the revision of 4 PHAs:

Radwaste System (significant changes based on redesign of the radwaste system; no new accident event sequences were created)

DCP Homogenizer (change in safety strategy for a single event sequence)

Powder Pack/Warehouse (added a single accident event sequence to address powder loading enrichment failures associated with one container type)

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Summary of ISA activi'ties for LEU+ Project (Continued)

Assessed the impact to 27 QRAs, which resulted in the revision of 12 QRAs. Summary of changes include:

Changes in mass and container limits, which in a few cases impacted initiating event frequencies and overall event likelihoods

Updated event descriptions based on changes in mass/container limits

Deleted one IROFS and replaced with an existing IROFS at Homogenizer

For Radwaste System, updated entire QRA as a result of revised radwaste system design (no new event sequences; deletion of two IROFS associated with a tank being removed in the redesigned system and the replacement of one IROFS with a new IROFS)

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Summary of ISA activities for LEU+ Project (Continued)

ISA Summary revision for the LEU+ amendment request - incorporates all of the necessary changes required to support the LEU+ project. Main impacts include:

Deleted one IROFS (205-02) and replaced with an existing IROFS (205-04)

Deleted two IROFS associated with equipment being removed (702-09 and 702-10)

Deleted one IROFS and replaced with a new IROFS (replaced 702-22 with 702-24)

Revised name of one IROFS (702-23)

Changes in mass and container limits, which in a few cases impacted initiating event frequencies and overall event likelihoods Summary of ISA program document changes are detailed in CALC-900-012 (prepared to specifically facilitate a project licensing impact review)

All ISA program documents supporting LEU+ project are currently in "approved - not implemented" status GNi=

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LEU+ Environmental Impact Considerations Pursuant to 10 CFR 51.60(b)(2), the amendment will not require an environmental review because it will not result in:

- A significant expansion of the site or construction impact

- A significant change in the types of effluents

- A significant increase in the amounts of effluents

- A significant increase in individual or cumulative occupational radiation exposure

- A significant increase in the potential for or consequences from radiological accidents

- A significant increase in spent fuel storage capacity The licensing action will not individually or collectively have a significant effect on the human environment and meets the 10 CFR 51.22( c )( 11) criterion for categorical exclusion GNi=Global Nuclear Fuel 11

LEU+ License Amendment Anticipated SNM-1097 Changes - Chapter 1

§ 1.1 Facility and Process Description Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235

§ 1.1.4 Process Description Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235

§ 1.2.2 Type, Quantity, and Form of Licensed Material Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235

§ 1.3.3 Authorized Transfer of Contamination-Free Liquids Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235 [§1.3.3.1, Transfer of HF for Testing; §1.3.3.2, Transfer of HF as Product; §1.3.3.2, Transfer of Nitrate-Bearing Liquids]

§ 1.3.8 Authorization for the Use of Materials at Off-site Locations Will confirm safe rod number per license commitments):

For dry fuel reconstitution, not more than 99 (9x9 or 1Ox10 lattices) or 88 (8x8 lattices) unassembled fuel rods may be possessed by GNF-A at any one reactor site at any one time, except when the fuel has been packaged for transport.

For underwater fuel reconstitution, not more than one fuel assembly plus unassembled fuel rods so that the total number of rods, including the assembly, possessed by GNF-A at any one reactor site at any one time does not exceed 99 (9x9 or 1Ox10 lattices) or 88 (8x8 lattices), except when the fuel has been packaged for transport or as described in Section 1.3.8.2.

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LEU+ License Amendment Anticipated SNM-1097 Chapter 5 Changes

§ 5.4.2.3 Administrative Controls

Administrative change: Correct typo - there should be a hard return between the two definitions and a bullet added to the Administrative Control definition.

§ 5.4.3 Specific Parameter Limits

The favorable geometry values of Table 5.1 contain dimensions for sphere, cylinder, and slab which may be used for applicable operations at GNF-A.

Table 5.1 will be modified to include specific subcritical limit values covering the enrichment range from 5.0 to 8.0 wt. % U235

The safe batch values of Table 5.2 may be used for applicable operations at GNF-A.

Table 5.2 will be modified to include specific subcritical limit values for U0 2 and water covering the enrichment range from 5.0 to 8.0 wt. % U235 GNi=

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LEU+ License Amendment Anticipated SNM-1097 Chapter 5 Changes (cont'd)

§ 5.4.5.2 Analytic Methods

Administrative changes:

Remove Solid Angle Code (SAC code) - it is no longer used.

Remove GEKENO 16-group Monte Carlo neutron transport codes - it is no longer used.

Add SCALE/KENO-VI Monte Carlo neutron transport code description.

Add MCNP Monte Carlo neutron-photon transport code description.

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LEU+ License Amendment No Additional SNM-1097 Chapter Changes Anticipated

Chapter 2 Organization and Administration

Chapter 3 Integrated Safety Analysis

Chapter 4 Radiation Safety

Chapter 6 Chemical Safety

Chapter 7 Fire Safety

Chapter 8 Radiological Contingency & Emergency Plan

Chapter 9 Environmental Protection

Chapter 10 Decommissioning

Chapter 11 Management Measures GNi=

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Summary for Manufacturing LEU+

LEU+ amendment will capitalize on other existing programs without significant changes

- Material Control and Accounting Program (provided NUREG/BR-0006 & 0007 E 1 & E2 material type enrichment codes are revised)

- Site physical security and safeguards

- Environmental permits and assessments

- Decommissioning Funding Plan/Cost Estimate (DFP)

- Radiological Contingency and Emergency Plan (RC&EP)

Plan is to submit amendment request late June 2022 for NRC review and approval LEU+ reloads by early 2024 feasible - (between 5-8°/o)

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Backup GNr Global Nuclear Fuel 17

Fresh Fuel RAJ-I I Container Transport Model RAJ-II Type B Fissile Package

[USA/9309/B(U)F-96]

BWR fuel assemblies, BWR/PWR fuel rods, Uranium Carbide rods LEU+ Up to 8% enrichment requires SAR update and corresponding Certificate of Compliance (CoC)changes Separate Request; planned for Fall 2022 GNi=

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Feed Transport: UF6 Cylinder/ UX-30 Model 30B UF6 Cylinder Model UX-30 Overpacks on GNr Global Nuclear Fuel Flatrack 19

ML22104A092

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