ML22271A936

Requests for Supplemental Information for the Acceptance of Global Nuclear Fuel - Americas License Amendment Request for 8 Weight Percent Uranium-235

ML22271A936
Person / Time
Site:	07001113
Issue date:	10/04/2022
From:	Rowley J Storage and Transportation Licensing Branch
To:	Nay D Global Nuclear Fuel
J Rowley NMSS/DFM/STLB 301-415-4053
References
EPID L-2022-LLA-0065
Download: ML22271A936 (5)

Text

October 4, 2022 Doug Nay Facility Manager Global Nuclear Fuel Global Nuclear Fuel Americas Facility 3901 Castle Hayne Road P.O. Box 4780 Wilmington, NC 28402

SUBJECT:

GLOBAL NUCLEAR FUEL - AMERICAS, LLC, REQUESTS FOR SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR 8 WEIGHT PERCENT URANIUM-235 (ENTERPRISE PROJECT IDENTIFICATION NUMBER L-2022-LLA-0065)

Dear Doug Nay:

By letter dated June 24, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML22175A070), Global Nuclear Fuel - Americas (GNF-A) submitted an application to amend materials license SNM-1097. GNF-A requested a license amendment to permit nuclear fuel fabrication at material enrichment limits up to 8 weight percent Uranium-235.

The U.S. Nuclear Regulatory Commission (NRC) staff performed an acceptance review of your 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 you that, based on our acceptance review, the application does not contain sufficient technical information. The information needed to continue our review is described in the enclosure to this letter. In order to schedule our technical review, this information should be provided within 30 business days of the date of this letter. If the information described is not received within that time, the application will not be accepted for review. This letter confirms our Microsoft Teams call on September 27, 2022, with respect to the supplemental information needed and the date for your submittal.

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter and the enclosure will be available electronically for public inspection in the NRC Public Document Room (PDR) or from ADAMS. The PDR is currently closed. You may submit your request to the PDR via email 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. ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

D. Nay 2 If you have any questions regarding this communication, please contact me at 301-415-4053, or via email to jonathan.rowley@nrc.gov.

Sincerely, Signed by Rowley, Jonathan on 10/04/22 Jonathan G. Rowley, Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 07001113 License No. SNM-1097

Enclosure:

Request for Supplemental Information cc: gnfa@listmgr.nrc.gov

ML22271A936 OFFICE NMSS/DFM/PM NMSS/DFM/LA NMSS/DFM/BC NMSS/DFM/PM JZimmerman NAME JRowley ELee JRowley JDowns (acting)

DATE 9/30/2022 9/30/2022 10/03/2022 10/04/2022 REQUEST FOR SUPPLEMENTAL INFORMATION GLOBAL NUCLEAR FUEL - AMERICAS, LLC LICENSE AMENDMENT REQUEST FOR 8 WEIGHT PERCENT U-235 RSI-1 SAFETY - ENVIRONMENTAL PROTECTION Information Needed:

Provide descriptions with appropriate references to sections of current licensing basis documents (e.g., past license renewal documents) and the June 24, 2022, license amendment request (LAR) documents that requested changes to the 30B cylinder receipt, pad storage, incineration, decontamination facilities, liquid radwaste effluent treatment systems that would occur for uranium fuel fabrication at 8.0 weight percent Uranium-235 (U-235).

Deficiency:

The section entitled Environmental Protection of the Global Nuclear Fuel - Americas (GNF-A)

LAR submittal dated June 24, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22175A070), only steps through each item under Title 10 of the Code of Federal Regulations (10 CFR) Paragraph 51.60(b)(2) and makes general conclusions regarding the categorical exclusions of 10 CFR 51.22(c)(11) and environmental impacts under the submitted LAR. However, no detailed justifications are provided such as referring to the appropriate text in other portions of the LAR application or to the environmental impacts assessed under the prior license renewal to support the statements in the Environmental Protection section. According to other information provided in the LAR, changes are proposed to the criticality safety analysis and controls that may impact the 30B cylinder receipt, pad storage, incineration, decontamination facilities, and liquid radwaste effluent treatment systems.

Basis:

The U.S. Nuclear Regulatory Commission (NRC) staff needs additional information to make an acceptance determination with respect to environmental protection. The NRC staff must evaluate the changes and modifications proposed in the LAR and determine whether there are significant changes to effluent releases, environmental monitoring, and postulated accidents for a safety review of environmental protection.

RSI-2 ENVIRONMENTAL REPORT Information Needed:

The NRC staff needs additional information to complete its environmental review of the LAR.

Pages 3-3 through 3-7 of NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs, provide a discussion of the information that is needed for the development of an environmental assessment (EA) for a simple licensing action. Additionally, Chapter 6 of NUREG-1748 provides a detailed discussion of the information needed for each of the resource areas to include in your environmental report (ER).

The ER for the GNF-A license renewal application should be supplemented in accordance with the guidance in NUREG-1748. Specifically, the ER should include relevant information Enclosure

regarding changes that have occurred since the March 30, 2007, GNF-A Wilmington Environmental Report Supplement (ML071000137), provided with GNF-As 2007 license renewal application. Additionally, the ER should include any details on how the nuclear fuel conversion, fuel fabrication facility, and fuel support activities will be impacted due to the increased enrichment. This should include the impact on the 30B cylinder receipt, pad storage, incineration, decontamination facilities, and liquid radwaste effluent treatment systems as indicated in your letter dated June 24, 2022. In this discussion, please provide details on the changes to receive shipments of higher enriched U-235, modifications to store the higher enriched materials onsite, specific impacts to air and water due to effluents, and specific estimated values of increases in public and occupational dose, such that the NRC can complete an assessment of these impacts.

Deficiency:

In the LAR, GNF-A indicates that its request can be categorically excluded under 10 CFR 51.22(c)(11). However, the considerations noted by GNF-A include topics that the NRC staff must evaluate during the safety review. The NRC staff has not yet been provided sufficient information to conclude that this action can be categorically excluded.

Basis:

Section 51.60 of 10 CFR, Environmental report - materials licenses, outlines the information that should be provided by the licensee for the NRC staff to assess the significance of the environmental impacts of the proposed action and decide if a categorical exclusion or the preparation of an EA and finding of no significant impact is appropriate for this action.

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