ML23068A155
| ML23068A155 | |
| Person / Time | |
|---|---|
| Issue date: | 01/24/2023 |
| From: | Glenn Tuttle Division of Fuel Management |
| To: | Richard Jervey NRC/NMSS/DFM/FFLB |
| Shared Package | |
| ML23068A154 | List: |
| References | |
| Download: ML23068A155 (1) | |
Text
From: Glenn Tuttle To: Rick Jervey
Subject:
RE: RE: RE: RE: Possession limit question Date: Tuesday, January 24, 2023 11:42:09 AM Attachments: Framatome questions_1-2023_draft with comments.docx image001.png image002.png
- Rick, Attached is the writeup concerning the possession limit question.
Let me know if there are any questions or comments.
Glenn From: Rick Jervey <Richard.Jervey@nrc.gov>
Sent: Monday, January 23, 2023 9:49 AM To: Glenn Tuttle <Glenn.Tuttle@nrc.gov>
Subject:
RE: RE: RE: RE: Possession limit question Sounds good, thanks!
From: Glenn Tuttle <Glenn.Tuttle@nrc.gov>
Sent: Thursday, January 19, 2023 12:18 PM To: Rick Jervey <Richard.Jervey@nrc.gov>
Subject:
RE: RE: RE: RE: Possession limit question Jim and I talked about this issue yesterday. Hes seen the Framatome emails.
Jim said he would write up something about our response. Ill send it to you when we get it done.
From: Rick Jervey <Richard.Jervey@nrc.gov>
Sent: Thursday, January 19, 2023 11:25 AM To: Glenn Tuttle <Glenn.Tuttle@nrc.gov>
Subject:
FW: RE: RE: RE: Possession limit question Any follow up?
I can arrange a call between the 3 of us if that works better.
From: Rick Jervey Sent: Tuesday, January 17, 2023 6:54 AM To: Glenn Tuttle <Glenn.Tuttle@nrc.gov>
Subject:
FW: RE: RE: RE: Possession limit question Glenn:
From: MANNING Calvin (Framatome) <calvin.manning@framatome.com>
Sent: Friday, January 13, 2023 1:21 PM To: Rick Jervey <Richard.Jervey@nrc.gov>
Subject:
[External_Sender] RE: RE: RE: Possession limit question The origin of the question stems from a practice that we have here that if we have a container that is not lot traceable, the enrichment for NCS purposes is labeled as 5 wt.%. That enrichment stays with the container until such time as a lab analysis is completed to provide an actual enrichment.
Recently, some material that had been labeled as 5 wt.% ended up on an autogenerated report as E2 material. This which lead me to ask some question on listed SNM inventory compared to our NRC (SNM) and State License (source material) possession limits. The actual possession quantities were much less than either the NRC or State licensed possession limits.
The next logical step was to ask questions about the report and why 5 wt.% was listed ast E2 materail. It turns out that our MC&A folks, due to NRC documents interpret up to 5 wt%
as 4.9999999 but not allowing 5 wt%.
My NCS background preconditions me to interpret up to to be the same as <.
So the next question, the one that I posed to you is given our NRC license list the possession limit at 5.00 wt.%, what is the maximum enrichment value that stays in compliance with our license?
The reason for this question is simply to assist in keeping myself aligned with the NRCs interpretation of the license limit of up to 5.00 wt.% U-235.
Now to answer your question, we receive scrap material from offsite on a routing basis. This is typically urania or other uranium compounds such as UO2F2, and UF4.
All incoming scrap is checked for enrichment as an NCS control. For all incoming scrap with a listed enrichment greater than 4.7 wt%, we require a mass spec or equivalent analysis instead of a gamma assay.
Our mass spec analysis for U-235 is reported to have a bias corrected systematic error of 0.057% relative.
cal From: Rick Jervey <Richard.Jervey@nrc.gov>
Sent: Friday, January 13, 2023 8:46 AM
To: MANNING Calvin (FRA-FL) <calvin.manning@framatome.com>
Subject:
RE: RE: RE: Possession limit question Security Notice: Please be aware that this email was sent by an external sender.
Cal, While we are waiting to talk next week, MC&A asked for this:
Could you find out from Framatome what type of material that they are analyzing that is right around 5.00 weight percent? Could you also ask them what measurement method they are using for this material and what is the typical uncertainty for that measurement?
I have not talked to the MC&A folks regarding these details, only forwarded them your question. I stand by my initial response, i.e. have a basis for meeting the limit, of which measurement uncertainty is part of that basis.
Happy weekend! Hope you get a holiday Monday too.
From: MANNING Calvin (Framatome) <calvin.manning@framatome.com>
Sent: Wednesday, January 11, 2023 3:11 PM To: Rick Jervey <Richard.Jervey@nrc.gov>
Subject:
[External_Sender] RE: RE: Possession limit question Just let me know when.
cal From: Rick Jervey <Richard.Jervey@nrc.gov>
Sent: Wednesday, January 11, 2023 12:08 PM To: MANNING Calvin (FRA-FL) <calvin.manning@framatome.com>
Subject:
RE: RE: Possession limit question Security Notice: Please be aware that this email was sent by an external sender.
I engaged the MC&A folks thinking they have specific answers. They havent finished responding yet. How about next week. Im in WDC.
From: MANNING Calvin (Framatome) <calvin.manning@framatome.com>
Sent: Wednesday, January 11, 2023 3:05 PM To: Rick Jervey <Richard.Jervey@nrc.gov>
Subject:
[External_Sender] RE: Possession limit question When would you be available to discuss the items in the e-mail sent to you on January 2nd?
cal From: MANNING Calvin (FRA-FL)
Sent: Monday, January 2, 2023 8:19 AM To: Jervey, Richard <Richard.Jervey@nrc.gov>
Subject:
Possession limit question Richard; Our possession limit states:
Uranium enriched up to 5.00 wt% U-235 (see the screen shot below).
What is the maximum lab assay value of uranium isotopic that would meet this limit? My 8th grade science teacher would say that anything up to 5.004 wt.% U-235 would meet the license limit but anything 5.005 or greater would not. How does the NRC interpret the two decimal point designation in the license limit?
Another question. If we have material that is actually 5.00 wt.% enriched as assayed by the Lab, per NUREG/BR-007 this would be E2 material for safeguards purposes. Does that have any bearing on compliance with the possession limit in the license?
Thanks cal
Calvin D. Manning Manager, Licensing and Compliance 2101 Horn Rapids Road Richland, WA 99354-5102 Office (509) 375-8237 calvin.manning@framatome.com www.framatome.com