ML22175A070

GNF-A License Amendment Request for 8 Wt. % U 235 (Leu+)

ML22175A070
Person / Time
Site:	07001113
Issue date:	06/24/2022
From:	Murray S Global Nuclear Fuel - Americas
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML22175A069	List: ML22175A070 ML22175A072
References
M220086
Download: ML22175A070 (10)

Text

Global Nuclear Fuel Scott P. Murray Manager, Facility Licensing 3901 Castle Hayne Road P.O. Box 780 Wilmington, NC 28402 USA Security-Related and Proprietary Information Notice T (910) 819-5950 This letter forwards security-related and proprietary information Scott.murray@ge.com requested to be withheld from public disclosure in accordance with 10 CFR 2.390. Upon removal of Attachment 2, Page 1.8, and Attachment 7 the balance of this letter can be made public.

M220086 June 24, 2022 Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Document Control Desk

Subject:

GNF-A License Amendment Request for 8 wt. % U 235 (LEU+)

References:

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

2) GNF-A/NRC License Amendment Request Pre-Application Meeting, 7/24/19

3) NRC Review of the GNF-A Minimum Margin of Subcriticality for Up to 8 Weight Percent Uranium Enrichment and Amendment 16, 8/13/20

4) GNF-A/NRC License Amendment Request Pre-Application Meeting, 5/3/22

Dear Sir or Madam:

The Global Nuclear Fuel - Americas L.L.C. (GNF-A) facility in Wilmington, North Carolina hereby submits a license amendment request to our approved SNM license and renewal application (Reference 1).

General Information As we discussed on July 24, 2019 and May 3, 2022 (References 2 and 4), pursuant to 10 CFR 70.34, GNF-A is requesting a license amendment to permit nuclear fuel fabrication at material enrichments up to 8.0 wt.% U 235 which is also referred to as LEU+.. This includes receipt, handling, and storage of Model 30B UF6 cylinders. On demand, the 30B UF6 cylinders are transported onsite by Fuel Support personnel to the Dry Conversion Process (DCP) vaporization autoclave process and the UF6 is vaporized; the UF6 gas is fed to the DCP conversion reactor-kiln and converted to UO2 powder where it is discharged to powder outlet cooling hoppers; and after cooling the powder is discharged to powder containers and placed into storage. The downstream powder preparation processes include standard homogenization, blend, precompact, granulate, and tumble operations. Once the powder is ready, it is then transferred to press feed and green pellets are discharged from the rotary presses. The green pellets are stored in pellet boats and then converted to ceramic grade UO2 pellets in the sintering furnaces. The sintered UO2 pellet is then subjected to grind, rod load, and bundle assembly to fabricate a nuclear fuel bundle.

M220086 US NRC 6/24/22 Page 2 of 5 For this license amendment request, the GNF-A nuclear fuel conversion and fuel fabrication facility will be impacted. Fuel support activities such as 30B cylinder receipt, pad storage, incineration, decontamination facilities, liquid radwaste effluent treatment systems will likewise be impacted by the change to permit 8.0 wt.% U 235 enriched uranium to be processed. There are no plans for segmentation of the fuel fabrication facility based on enrichment. The entire fuel fabrication facility will be approved and controlled to safely process material enrichments up to 8.0 wt.% U 235.

There are no changes required to the current license possession limits.

Integrated Safety Analysis SNM-1097 program commitments to document criticality safety analyses (CSAs), conduct process hazards analysis (PHA), document quantitative risk assessments (QRA), and maintain an Integrated Safety Analysis Summary (ISAS) remain unchanged as a result of this license amendment request. GNF-A has re-evaluated and documented CSAs using the current methodologies and minimum margin of subcriticality for existing operations at the requested enrichment limit of 8.0 wt.% U 235.

Based on completed safety analysis work, the enrichment increase does not create new types of accident sequences and there are no plans to use new processes, technologies, or control systems in which GNF-A has no prior experience. In addition, there are currently no sole IROFS identified in the ISAS that could be altered. Controls necessary to meet 10 CFR 70.61 performance requirements were systematically evaluated and changes to Items Relied on for Safety (IROFS) have been identified. GNF-A is not requesting any changes to the existing ISA program commitments in SNM-1097.

As stated in our pre-application meetings, the ISAS will be updated after NRC approval in accordance with internal procedures using the ISA program described in Chapter 3 of SNM-1097.

The ISAS will be revised through the Change Management program described in Chapter 3 and 11 of SNM-1097.

A copy of an updated draft ISAS pursuant to 10 CFR 70.65(b) is provided as Attachment 7 to this letter.

Facility Modifications Several facility changes are underway to support processing of uranium enriched up to 8.0 wt.% U 235. As described in Section 3.5.1 of SNM-1097, evaluations have been performed of each change to determine if it requires prior approval by the NRC. Section 1.3.1.2 of SNM-1097 provides criteria for changes that do not require prior approval by the NRC, which are based on the criteria in § 70.72(c). No facility changes have been identified that require prior NRC approval.

Criticality Safety The criticality safety function has evaluated the proposed amendment and has concluded the request to increase the enrichment to 8 wt.% U 235 will result in modifications to select nuclear criticality safety controls as documented in supporting Criticality Safety Analyses (CSAs) prepared in accord with Chapter 5 of SNM-1097. Current program commitments and practices were followed to assure the system remains subcritical under both normal and credible abnormal operating conditions. Changes to SNM-1097 license chapters are shown in attached; changes to controls elevated to IROFS necessary to meet 10CFR70.61 performance requirements are described in the attached ISAS.

M220086 US NRC 6/24/22 Page 3 of 5 Radiation Safety The radiation safety function has evaluated the proposed amendment and has concluded the request to increase the enrichment to 8 wt.% U 235 will not result in modifications to the radiation protection program described in Chapter 4 of SNM-1097. Current practices and processes are sufficient to contain the uranium and ensure exposures to personnel and the environment are maintained ALARA.

Radiological accident sequences identified in the ISA did not change as a result of this license amendment request. Increasing the enrichment limit increases the maximum specific activity of uranium that could be involved in radiological accident sequences identified in the ISA, which in turn reduces the Material-at-Risk (MAR) threshold masses required to reach intermediate or high threshold consequence severities established in 10 CFR 70.61.Calculations supporting the ISA consequence severities have been updated to address changes in specific activity and MAR thresholds. The reduced MAR thresholds do not result in any increases to the consequence severities of events identified in the ISA.

Chemical Safety The chemical and physical forms of the uranium throughout the GNF-A nuclear fuel fabrication and support processes remain unchanged. The uranium chemistry in the UF6 to UO2 conversion process is not affected by the enrichment change. The uranium compounds and hydrocarbon additives now used in the powder preparation process remain unchanged. The sintered UO2 pellet and product powder material uranium chemical and physical characteristics are likewise unchanged by a change in enrichment. There are no unforeseen chemical or physical forms in the SNM processes involving uranium enriched to 8 wt.% U 235. As a result, the license amendment will not result in modifications to the chemical safety program described in Chapter 6 of SNM-1097; nor are there anticipated changes to the existing acute chemical exposure accident sequences and IROFS that prevent or mitigate these accident sequences currently identified in the current GNF-A ISA Summary.

Fire Safety The license amendment will not result in modifications to the fire safety organization, management, or program elements described in Chapter 7 of SNM-1097. There are no anticipated changes to the existing fire accident sequences or the associated fire safety controls described in fire hazard analysis. In addition, there are no changes to fire safety commitments regarding facility design, process fire safety, or fire protection systems described in Section 7.4 through 7.10 of SNM-1097.

Any changes made to implement the amendment request that could affect fire safety will be evaluated under the existing configuration management program. If changes to existing fire protection systems, fire hazard analyses, pre-fire plans or any other fire safety related document are identified, they will be addressed appropriately.

Emergency Planning The current Radiological Contingency and Emergency Plan (RC&EP) does not specify source terms, IROFS, or estimated exposures thus no changes are required. The RC&EP generally discusses the types of accidents that could occur at GNF-A based on the accident sequences identified in the ISA Summary. The severities of exposures to the public for significant events that could potentially result in high or intermediate consequences to the public are evaluated in the ISA based on the source term, release parameters, and atmospheric dispersion. Information on these types of evaluations is included in ISA documentation as required by procedures. Where necessary the ISA also specifies the preventive or mitigative IROFS required to make high consequence events highly unlikely, or intermediate consequence events unlikely. This detailed information is not reiterated in the RC&EP.

M220086 US NRC 6/24/22 Page 4 of 5 The impact of increasing the maximum enrichment from 5% to 8% is that the maximum specific activity of uranium that could be involved in an event would increase by approximately the same ratio. Radiological exposures to the public from a given event could therefore be slightly higher.

However, the events with the highest potential consequences involve UF6 releases and the chemical consequences from exposure to HF or soluble uranium produced from a UF6 release outweigh the radiological consequences. The chemical consequence severities will not be affected by the change in enrichment and will remain the dominant exposure consequence. Calculations supporting the ISA consequence severities have been updated to address the change in maximum specific activity due to the increase in the maximum enrichment limit.

The incremental increase in potential exposures will not increase the public consequence severities levels of events identified in the ISA.

No new events that could result in public radiological exposures are anticipated as a result of this amendment request. In addition, no changes to facility features or IROFS that prevent or mitigate exposures to the public are anticipated. There are no changes of significance to the process or physical locations where accidents could occur.

Based on the above discussion, the license amendment is not anticipated to have an affect the RC&EP.

Environmental Protection Pursuant to 10 CFR 51.60(b)(2), the license amendment will not require an environmental report 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. The license amendment does not significantly alter the previously evaluated environmental impacts associated with the licensed operation and does not affect the scope or nature of the licensed activity.

Decommissioning There are no changes to the types, amounts, and discharge points of waste materials in solid, liquid, and gaseous forms that are considered in the current decommissioning cost estimate and funding plan. The increase in enrichment does not change waste disposal costs.

In addition, 10 CFR 70.25(e)(2) lists eight events to be considered during a DFP update. Of these, there will be minor facility modifications. For example, the planned enrichment increase will require favorable geometry liquid radwaste process tank dimensions now used at 5% enrichment to be replaced with new favorable geometry tank dimensions to process 8% enriched liquid waste.

These modifications will not affect the current decommissioning cost estimate.

There are no changes required to the decommissioning cost estimate for the other seven events (waste inventory, disposal cost increases, spills of radioactive material producing additional residual radioactivity, changes in authorized possession limits, actual remediation costs that exceeded previous cost estimate, onsite disposal and use of a settling pond).

M220086 US NRC 6/24/22 Page 5 of 5 Material Control and Accounting The Material Control and Accountability (MC&A) function has evaluated the proposed amendment and comrnits that changes to the policie~. procedures, and controls to support the proposed amendment will be implemented consistent with the existing MC&A program. The Fundamental Nuclear Material Control Plan (FNMCP) currently in place for GNF-A will continue to satisfy the requirements of 10 CFR 7 4.31. The information in the Plan demonstrates the adequacy of the compliance program for fulfilling the requirements of 10 CFR 74.31 with regard to the licensing to possess and use special nuclear material of low strategic significance referenced as low enriched uranium (less than 10 wt. percent U235).

SNM-1097 Chapter Revisions A description and reason for the change in each affected renewal application chapter is provided in to this letter to aid NRC Staff review.

Attachments 2, 4, 5 and 6 provide updates to Chapter 1, "General Information", Chapter 5, "Nuclear Criticality Safety, Chapter 8, _"Radiological Contingency and Emergency Plan" and Chapter 10, "Decommissioning". The revised sections are identified with a vertical line in the right:

hand margin on each revised pag~_.

Schedule GNF-A requests NRC review and approval of the amendment within 12 months of this request.

Please contact me on (910) 819-5950 if you have any questions or would like to discuss the request.

Sincerely, g~y.e~ag**

Facility Licensing Attachments: 1) SNM-1 097 Change Table Summary

2) SNM-1097 Chapter 1-Contains Security Related Information

3) SNM-1 097 Chapter 1, Page 1.8 (Public)

4) SNM-1097 Chapter 5

5) SNM-1 097 Chapter 8

6) SNM-1 097 Chapter 10

7) GNF-A Integrated Safety Analysis Summary (Draft), Revision 25A, June 2022 (Contains Security Related Information) cc: J. Rowley, USNRC NMSS/DFM/FFLB J. Rivera, USNRC All SPM 22-023

M220086 US NRC 6/24/22 GNFA License Amendment Request for 8 wt % U 235 Attachment 1 SNM1097 Change Table Summary

M220086 US NRC 06/24/2022 Page 1 of 4 Attachment 1 SNM-1097 License Application Change Table 06/24/2022 Section Description of Change Reason for Change Chapter 1 -GENERAL INFORMATION Section 1.1 - Facility and Second sentence changed Enrichment limit change Process Description enrichment limit value from 5.0 to 8.0 weight percent U-235.

Figures 1.2, 1.3 Updated to reflect I-140 and ATC-2, Update map and facility respectively configuration to reflect current.

Section 1.1.4 - Process First sentence changed enrichment Enrichment limit change Description limit value from 5.0 to 8.0 weight percent U-235.

Section 1.2.2 - Type, Quantity, Sub-bullets 1) and 2) change Enrichment limit change and Form of Licensed Material enrichment limit value from 5.0% to 8.0%

Section 1.3.3.1 - Transfer of Second paragraph changed Enrichment limit change Hydrofluoric Acid (HF) for enrichment limit value from 5.0% to Testing 8.0% U-235.

Section 1.3.3.2 - Transfer of Enrichment limit change Hydrofluoric Acid (HF) as First paragraph changed enrichment Product limit value from 5.0 to 8.0 weight percent U-235.

Section 1.3.3.3 - Transfer of First paragraph, changed enrichment Enrichment limit change Nitrate- Bearing Liquids limit value from 5.0 weight percent U-235 to 8.0 weight percent U-235.

Chapter 5 -NUCLEAR CRITICALITY SAFETY Section 5.1.1 a) - Criticality NCS program commitments Text clarification; words Safety Design Philosophy statement a) remove the words an unnecessary inadvertent from sentence.

Section 5.1.2.1 Second sentence, change in Text reformatting; correct accord to in accordance. grammar.

M220086 US NRC 06/24/2022 Page 2 of 4 Attachment 1 Section 5.1.2.2 Role of the Second sentence changed Text clarification; words Criticality Safety Function commensurate with the risk involved unnecessary to . commensurate with risk.

Section 5.3.2.5 Change first sentence word uniform Improve clarity.

to installed .

Section 5.4.2.3 - Administrative First paragraph describing Text reformatting Controls augmented administrative controls and administrative controls are split into two separate bullets.

Section 5.4.3 - Specific First paragraph, last sentence Historical percentages of Parameter Limits removes percentage basis statement published literature critical for Table 5.1 favorable geometry diameter, slab thickness, values and replaces with new basis and sphere volume are now statement. Acceptable safety derived explicitly.

margins for units listed in this table are documented in accord with Section 5.4.5 analysis methods (keff

+ 3 USL).

Second paragraph, last sentence Text clarification.

changed to acknowledge subcritical limits in accord with Section 5.4.5.

Third paragraph, last sentence Text clarification; uranium changed to acknowledge mass limits enrichment is basis of mass are based on enrichment (not U235 limits.

mass limits).

First bullet in section; second Text clarification; words sentence changed to removed over unnecessary the range of 1.1% to 5% as this enrichment range is no longer valid.

Table 5.1 Favorable Geometry Historical percentages of Values - reported values have been published literature critical replaced with calculated results for diameter, slab thickness, homogeneous UO2 and water, and sphere volume are now homogeneous aqueous uranyl nitrate derived explicitly from and water, and heterogeneous UO2 SCALE/KENO-VI and water mixtures over the calculated minimum critical enrichment range from 5.0 to 8.0 masses using ce_endf_v7 weight percent U-235 as noted cross section library.

above. Theoretical densities used are specified and based on SCALE6.1 standard composition library.

M220086 US NRC 06/24/2022 Page 3 of 4 Attachment 1 5.4.3 Specific Parameter Limits Second paragraph, second sentence Text clarification; words reworded. unnecessary.

Table 5.2 Safe Batch Values for UO2 Table 5.2 lists safe batch and Water - reported values have limits as a function of been replaced with calculated safe enrichment from 5.0 to 8.0 batch results for homogeneous UO2 weight percent U-235.

powder and water and Text update.

heterogeneous UO2 pellets and water mixtures over the enrichment range from 5.0 to 8.0 weight percent U-235.

First paragraph, first sentence; Historical methods using removed reference to Solid Angle Solid Angle methods or methods (SAC code) and Monte GEKENO 16-energy group Carlo code GEKENO, added MCNP. Knight Modified Hansen Removed previous third paragraph Roach cross section data GEKENO summary description set are no longer used in paragraph. production applications.

MCNP is added as it may also be used in support of production applications.

Second paragraph (new) added to Provide summary more fully describe the description of SCALE/KENO-VI Monte Carlo code SCALE/KENO-VI transport used solve eigenvalue solution to the code now used in support neutron transport equation in 3- of production applications.

dimensional space.

Fourth paragraph (new) added to Provide summary more fully describe the MCNP Monte description of MCNP Carlo neutron particle transport code transport code now used in used solve eigenvalues for fissile support of production medium systems. applications.

5.4.4.6 - Spacing (or Unit Remove second paragraph, first Text clarification; words Interaction) sentence as Solid Angle interaction unnecessary- as Solid analysis is no longer used. Angle methods no longer used.

5.4.4.8 Reflection Change second sentence to Clarification of current acknowledge 1-inch water reflection practices consistent with (minimum). NUREG-1520.

5.4.5.3- Validation Techniques

M220086 US NRC 06/24/2022 Page 4 of 4 Attachment 1 First and sixth paragraphs; replace Text update to current ANSI/ANS-8.1-1998 reference with standard.

current ANSI/ANS-8.1-2014 (R2018).

Replace last bullet with clarified and Text clarification; and corrected statement: Statistical acknowledgement of methods may be used to ensure that TSUNAMI code to quantify the extrapolation is not large. The AOAm.

SCALE/TSUNAMI code may be used to compare the application system to the benchmark experiments for similarity and USL penalty determination.

5.4.5.4 - Computer Software &

Hardware Configuration Control Second paragraph; update Acknowledge statistical verification of software to uncertainty permitted in acknowledge results may be verification case set results.

identical or within statistical uncertainty.

Change third paragraph to read, Text clarification; additional Modifications to software and words unnecessary.

nuclear data that may affect the calculational results that fall outside statistical uncertainty require re-validation of the software.

5.4.5.5- Criticality Safety Analysis Sixth bullet: Specifications and Text correction; interface Requirements for Safety; removed considerations for the out of place / incomplete sentence process being analyzed is containing interface previously addressed in the considerations. general process description section of the documented nuclear criticality safety evaluation.

Chapter 8- RADIOLOGICAL Changed third paragraph plan Align with revised 10 CFR CONTINGENCY AND update reporting location 70.32 (i)

EMERGENCY PLAN Chapter 10- Changed first sentence Text updates DECOMMISSIONING decommissioning funding plan date Changed third sentence to remove parent company guarantee reference