ML22336A174

Westinghouse Request for Temporary License Amendment for Storage of Hematite Ash

ML22336A174
Person / Time
Site:	Westinghouse
Issue date:	12/02/2022
From:	Donnelly P Westinghouse
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
References
LTR-RAC-22-62
Download: ML22336A174 (1)

Text

WESTINGHOUSE NON-PROPRIETARY CLASS 3 Westinghouse Electric Company LLC Columbia Fuel Site 5801 Bluff Road Hopkins, South Carolina 29061-9121 USA Director, Office of Nuclear Material Safety and Direct tel: 803-647-1957 Safeguards U. S. Nuclear Regulatory Commission e-mail: donnelpb@westinghouse.com Document Control Desk 11555 Rockville Pike Your ref:

Rockville, Maryland 20852-2738 Our ref: LTR-RAC-22-62 December 2, 2022

SUBJECT:

Request for Temporary License Amendment for Storage of Hematite Ash (Docket No. 70-1151, License SNM-1107)

In accordance with 10 CFR 70.34, Westinghouse Electric Company, LLC (Westinghouse) requests NRC approval to possess ash from the Hematite site labeled as containing as high as 5.17 wt% U235. Our request is limited to the possession of 9 containers of Hematite ash with contents up to 5.5 wt% U-235 under a temporary license condition with a requested duration not to exceed six months after issuance of the amendment. Enclosure 1 provides specific drum and residue identification numbers for the material associated with this request, along with the NRC Form 741 Nuclear Material Transaction Report identification numbers associated with the shipments.

In the first quarter of 2003, Westinghouse was in the process of decommissioning the Westinghouse Hematite site in Hematite, MO. Ash from the incinerator for uranium recovery was sent to the Columbia Fuel Fabrication Facility (CFFF) for processing. The ash has been in storage since that time and CFFF recently began a campaign to process all the ash from Hematite. During that process, as described in NRC Event Notification Number 56199, CFFF employees discovered some bags from the Hematite site have labels that state the ash contents are above or statistically have the potential to be above the 5 wt% U235 limit in our current license. In total, 9 drums containing ash that are potentially above the 5 wt% threshold have been segregated from the remaining Hematite drums and are being stored in an intermodal transport container suspended off the ground on a flatbed trailer.

The historic NRC Form 741 records indicate that samples of the ash were sent to CFFF for testing to perform a shipper/receiver comparison of the uranium content of the shipment. Later on, corrected NRC Form 741 records show the U235 content of the intermodal transport container shipments were reduced, indicating that CFFF found the U235 content of the ash to be lower than indicated by Hematite and Hematite accepted the CFFF test results as resolution to the shipper/receiver difference. The original NRC Form 741 reports are included in Enclosure 3, and the corrected NRC Form 741 reports are included in Enclosure 4. It is also worth noting that

© 2022 Westinghouse Electric Company LLC All Rights Reserved

WESTINGHOUSE NON-PROPRIETARY CLASS 3 LTR-RAC-22-62 December 2, 2022 at the time of decommissioning commencement, Hematite was a Category III fuel facility (Docket No. 70-36, License SNM-33) licensed to possess only up to 5 wt% U235, so it is unlikely the incinerated ash would contain elevated levels of U235.

A nuclear criticality safety (NCS) technical justification of the existing safety basis for the current storage condition of the Hematite Ash is provided in Enclosure 2. Also, the storage of the 9 drums of Hematite Ash falls within the existing safety basis for environmental protection, fire safety, chemical safety and radiological safety, as documented in Integrated Safety Analysis (ISA) 16, Storage of Uranium Bearing Materials. Accordingly, there is no undue risk to public health and safety from approval of a temporary license condition for storage of the subject Hematite Ash Material because the condition is bound by the existing safety basis.

The requested amendment does not decrease the effectiveness of the CFFF Fundamental Nuclear Material Control Plan and will not impact security operations at the facility. As a result, storage of the subject material will not be inimical to the common defense and security.

Pursuant to 10 CFR 51.22(b), no environmental assessment or environmental impact statement need be prepared in connection with approval of this request. The amendment request is categorically excluded under 10 CFR 51.22(c)(11) because the requested license amendment involves no significant change in the types or significant increase in the amounts of any effluents that may be released offsite; no significant increase in individual or cumulative public or occupational radiation exposure; no significant construction impact; and no significant increase in the potential for or consequences from radiological accidents. There are no extraordinary circumstances present that would preclude reliance on this categorical exclusion.

Please contact me at (803) 647-1957 should you have questions or need additional information.

Patrick Donnelly Regulatory Affairs Manager Westinghouse Columbia Fuel Fabrication Facility Docket 70-1151, License SNM-1107 cc:

NRC, Ms. Jennifer Tobin NRC, Mr. Thomas Vukovinsky : Summary of Material Included in Request : NCS Technical Justification - Safety Basis for Storage of Hematite Ash Suspected >5 wt% U235 : Original NRC Form 741 Reports for Hematite Ash Material : Corrected NRC Form 741 Reports for Hematite Ash Material

WESTINGHOUSE NON-PROPRIETARY CLASS 3 LTR-RAC-22-62 December 2, 2022 Enclosure 1 Summary of Material Included in Request (1 Page)

WESTINGHOUSE NON-PROPRIETARY CLASS 3 LTR-RAC-22-62 December 2, 2022 Residue Transaction Drum ID %U235 ZWQ-YLM-184 H029 R0042330 5.170 ZWQ-YLM-184 H033 R0042123 5.028 ZWQ-YLM-184 H058 R0042072 5.020 ZWQ-YLM-184 H104 R0042137 5.010 ZWQ-YLM-190 H032 R0041910 5.000 ZWQ-YLM-190 H096 R0042640 5.000 ZWQ-YLM-184 H022 R0041911 4.999 ZWQ-YLM-184 H023 R0042070 4.960 ZWQ-YLM-184 H068 R0042315 4.957

WESTINGHOUSE NON-PROPRIETARY CLASS 3 LTR-RAC-22-62 December 2, 2022 Enclosure 2 Nuclear Criticality Safety (NCS) Technical Justification - Safety Basis for Storage of Hematite Ash Suspected >5 wt% U235 (3 Pages)

Nuclear Criticality Safety (NCS) Technical Justification - Safety Basis for Storage of Hematite Ash Suspected >5 wt% U235 There are nine drums containing incinerator ash that were shipped to CFFF from the Hematite site in early 2003 that have records indicating some of the contents may include ash with a uranium enrichment that exceeds or is statistically possible to exceed 5 wt% U235. The drums contain individual bags of ash, between two and four bags each. The tables below list the contents of each bag of ash, the cumulative contents of each drum and the average enrichment of each drum based on the shipping documentation. Although the labeled enrichment of each bag varies from 4.04 wt% up to 5.170 wt%, the average drum enrichment does not exceed 4.809 wt%. The maximum U235 quantity in any drum does not exceed 334 grams U235.

CFFF has an existing safety basis for the storage of low uranium density materials in 55-gallon drums. This drum storage is typically referred to as floor storage at CFFF and consists of arrays of drums loaded up to 500 grams U235, without spacing, in non-stacked planar arrays where needed in the facility. Calculations were performed for these drum arrays to show that under normal and upset conditions, the k-effective will remain below license limits. The safety basis is documented in ISA-16, Storage of Uranium Bearing Materials and CSE-16-F, Criticality Safety Evaluation (CSE) for Floor Storage of Special Nuclear Material.

It is recognized that the safety basis for the floor storage drums has been performed with a maximum enrichment of 5.0 wt% U-235. However, the calculations are modeled as an optimally moderated Uranium Dioxide (UO2) and polypropylene homogenous mixture, which is a very conservative representation of incinerator ash. Incinerator ash is typically extremely dry and poorly moderated due to the capability of the incinerator to destroy the hydrogenous material. Further, the models are also considered to bound the ash drums from an enrichment standpoint because the average enrichment of the ash drums is less than 5.0 wt% U235. The fissile mass is also obviously conservatively bounded, as the maximum fissile mass in any of the nine drums is approximately two-thirds of the mass limit for the drum arrays. The nine drums are currently stored in an intermodal container suspended off the ground on a flatbed trailer with 24-inch edge-to-edge spacing (out of an abundance of conservatism),

but the safety basis for the drum storage arrays requires no spacing for drums with a fissile mass below 500 grams U235.

The drums are currently stored, and will remain, within coverage of the CFFF Criticality Accident Alarm System. The drums will be maintained in their current configuration until Westinghouse submits a plan to the NRC for movement, sampling, testing and if necessary, down blending the ash to within the current SNM-1107 license limits.

Drum Content Summary Drums with Contents Labeled >5%

Residue Grams Drum Grams Drum Grams Drum Drum Tare Net %U Grams U %U235 ID U235 U U235 Avg %U235 H029 R0042330 1,050 13,880 5.172 718 5.17 37 H029 R0042062 1,050 19,215 24.365 4682 4.1 192 H029 R0041758 1,050 6,765 11.935 807 4.084 33 6207 262 4.222 H033 R0042123 650 4,580 16.067 736 5.028 37 H033 R0042728 650 13,320 13.5 1798 4.48 81 H033 R0042302 650 14,590 8.379 1222 4.291 52 3757 170 4.526 H058 R0042072 650 5,520 14.987 827 5.02 42 H058 R0042378 650 16,855 27.43 4623 4.4 203 H058 R0042124 650 2,115 4.974 105 4.108 4 H058 R0042795 650 11,490 18.2 2091 4.07 85 7647 334 4.373 H104 R0042137 650 12,430 6.974 867 5.01 43 H104 R0031070 650 6,595 29.315 1933 4.46 86 H104 R0033960 650 905 8.862 80 4.09 3 H104 R0003191 650 16,565 17.536 2905 4.04 117 5785 250 4.326 H032 R0041910 650 14,685 14.238 2091 5 105 H032 R0042131 650 12,655 15.485 1960 4.58 90 H032 R0042119 650 7,735 16.649 1288 4.521 58 5338 253 4.73 H096 R0042640 650 16,820 30.02 5049 5 252 H096 R0042276 650 17,990 7.55 1358 4.1 56 6408 308 4.809 Continued on the next page.

Drums with Contents Potentially >5%

Drum Residue Grams Drum Grams Drum Grams Drum Tare Net %U Grams U %U235 ID U235 U U235 Avg %U235 H022 R0041911 1050 6,760 7.347 497 4.999 25 H022 R0042196 1050 11,395 13.375 1524 4.58 70 H022 R0042296 1050 8,550 5.76 492 4.52 22 H022 R0042290 1050 9,900 8.88 879 4.06 36 3392 153 4.498 H023 R0042070 1,050 6,195 19.839 1229 4.96 61 H023 R0042192 1,050 18,770 15.475 2905 4.41 128 H023 R0042627 1,050 12,445 23.67 2946 4.26 125 7079 315 4.443 H068 R0042315 650 9,335 5.03 470 4.957 23 H068 R0042033 650 11,450 9.51 1089 4.15 45 H068 R0042806 650 18,475 32.78 6056 4.06 246 7615 314 4.128