ML23255A182

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Enclosure 4 - Safety Evaluation Report
ML23255A182
Person / Time
Site: Erwin
Issue date: 11/07/2023
From:
NRC/NMSS/DFM/FFLB
To:
Nuclear Fuel Services
Shared Package
ML23255A177 List:
References
EPID L-2021-LLA-0213
Download: ML23255A182 (55)
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Text

SAFETY AND SAFEGUARDS EVALUATION REPORT DOCKET NO.: 70-143 LICENSE NO.: SNM-124 LICENSEE: Nuclear Fuel Services, Inc.

Erwin, Tennessee

SUBJECT:

LICENSE AMENDMENT REQUEST FOR URANIUM PURIFICATION AND CONVERSION (U-METAL) SERVICES

1.0 BACKGROUND

By letter 21G-21-0092, dated November 18, 2021 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML21327A099), Nuclear Fuel Services, Inc.

(NFS, or the licensee) submitted a request to amend special nuclear material (SNM) license number SNM-124. The original submittal was supplemented by letter 21G-22-0028 dated February 24, 2022 (ML22066B004), letter 21G-22-0029 dated February 24, 2022 (ML22069A315), letter 21G-23-0005 dated January 31, 2023 (ML23041A235), letter 21G-23-0015 dated January 31, 2023 (ML23040A067), letter 21G-23-0097 dated August 25, 2023 (ML23244A053), and page changes received on April 19, 2023 (ML23251A224), and September 15, 2023 (ML23258A073). Approval of this license amendment request (LAR) would authorize the licensee to perform uranium purification and conversion (U-metal) services at the NFS site pursuant to a contract with the Department of Energys (DOEs) National Nuclear Security Administration (NNSA). The application was assigned Enterprise Project Identification Number L-2021-LLA-0213.

The U.S. Nuclear Regulatory Commission (NRC) staff evaluated the U-metal LAR in accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR), Part 70 and used guidance provided in Revision (Rev.) 2 of NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications (ML15176A258). Prior to accepting the LAR for detailed technical review, the NRC staff issued requests for supplemental information (RSIs) by letter dated January 21, 2022 (ML22014A421). During the detailed technical review, the NRC staff issued requests for additional information (RAIs) by letter dated August 31, 2022 (ML22234A293). Additionally, on June 9 & 10, 2022, NRC staff conducted an observational site visit at NFS to facilitate the NRCs review of the LAR, which is documented in a trip report dated June 13, 2022 (ML23097A099). NRC staff also conducted a clarification call with NFS on March 20, 2023, and documented that discussion in a call summary dated April 11, 2023 (ML23090A153).

In its submittal, NFS stated that NNSA awarded the contract for U-metal services to bridge the gap between legacy uranium processing equipment shutdown at the Y-12 National Security Complex and a new facility startup utilizing electrorefining technology to purify high enriched uranium (HEU) metal. NFS also stated that the proposed design and licensure of a process for uranium purification and conversion to uranium metal would not only provide the oxide conversion, but hedges against the risk associated with the new electrorefining technology.

In accordance with 10 CFR 70.72, NFS determined that the facility changes proposed in the U-metal LAR would require a license amendment because the uranium purification and Enclosure 4

conversion services: (1) have the potential to introduce new accident scenarios to the existing NRC-licensed activities that, unless mitigated or prevented, would exceed the performance requirements of 10 CFR 70.61 and have not previously been described in the integrated safety analysis (ISA) summary; and (2) use new processes, technologies, or control systems for which the licensee has no prior experience.

2.0 DISCUSSION 2.1 General Information Facility and Process Overview Proposed changes to Section 1.1, Facility and Process Information, of the NFS License Application (LA) (ML21327A099 and ML23251A224), state that conversion to HEU metal (U-metal) occurs in Building 301. Highly enriched uranyl nitrate is transferred from the Blended Low Enriched Uranium (BLEU) Preparation Facility (BPF) to Building 301 after purification, where it undergoes conversion to produce uranium metal or oxides ready for processing and shipment. Product that does not meet customer specifications is returned to the BPF or Building 301 uranium recovery area for further processing.

The proposed changes to LA Section 1.1 update the general process description to account for U-metal operations. The descriptions of existing facility buildings and structures were modified to reflect the support that existing processes provide to new U-metal operations. Changes were also made that describe the facility buildings and structures that will contain the new processes for U-metal. Enriched uranium purification and conversion will occur in Building 301, where conversion of purified highly enriched uranyl nitrate occurs through various process steps to produce uranium metal and oxides, as well as recovery of process scrap/slag. The new Utility Services Building (Building 389), which is planned for installation inside the NFS footprint - west of Building 301 - provides key utility subsystems that support the processes for purification and conversion of uranium in Building 301 (e.g., process off-gas and scrubber system, gaseous utility feed systems, waste discard tanks, etc.).

The NRC staff also reviewed the Building 301 HEU Metal Production Facility ISA Summary (ML23244A053 and ML23258A073), which is also known as the U-metal ISA Summary, and the changes made by the licensee to the NFS Site ISA Summary (NFS, 2021a). The ISA Summaries incorporate relevant information regarding the U-metal process and the associated buildings (existing Building 301 and new Building 389, the proposed utility building). The NRC staff finds that the ISA Summaries provide a description of the facility with emphasis on those areas that could affect safety, including an identification of the controlled area boundaries, as required by 10 CFR 70.65(b)(2). Furthermore, as described above and in other sections of this safety evaluation report (SER), the ISA Summaries contain a description of each U-metal process in sufficient detail to understand the theory of the process operations, the hazards that were identified in the ISA, and a general description of the types of accident sequences - as required by 10 CFR 70.65(b)(3).

The NRC staff has reviewed the facility and process information for the U-metal services at the NFS site according to Section 1.1 of NUREG-1520, Rev. 2. NFS has adequately described:

(1) the facility and its processes so that the NRC staff has an overall understanding of the relationships of the facility features; and (2) the function of each feature. NFS has cross-referenced its general description with the more detailed descriptions elsewhere in the application. The NRC staff also confirmed that the information provided in the LA is consistent with the ISA Summary and the emergency management plan. Therefore, the NRC staff concludes that NFS has complied with the general requirements of 10 CFR 70.22, Contents of Applications, and 10 CFR 70.65(b), as applicable to this section.

Institutional Information The changes to the institutional information proposed for this amendment are editorial and administrative. The NRC staff has previously reviewed the substantive institutional information that is applicable to the new U-metal services at the NFS site according to Section 1.2 of NUREG-1520, Rev. 2. The licensee has previously provided all information necessary to understand the ownership, financial qualifications, location, planned activities, and nuclear material to be handled. The NRC staff continues to find this information acceptable.

Based on the review, the NRC staff has determined that NFS has adequately described and documented its corporate structure and financial information and is in compliance with those requirements in 10 CFR 70.22 and 10 CFR 70.65 related to other institutional information.

Site Description The changes to the site description proposed for this amendment in LA Sections 1.3.1, Site Geography, 1.3.2, Demographics, and 1.3.3, Meteorology, are editorial and administrative.

The NRC staff has previously reviewed the substantive information in those sections that is applicable to the new U-metal services at the NFS site according to Section 1.3 of NUREG-1520, Rev. 2. The licensee has previously provided all information necessary to understand the site geography, demographics, and meteorology. The NRC staff continues to find this information acceptable.

The changes to the site description proposed for this amendment in LA Section 1.3.4, Hydrology, update the information on the floodplain and state that the NFS Protected Area is completely outside of the 100-year floodplain and much of the northern portion of the NFS property is outside of the 100-year floodplain. A portion of the north site, 600 feet off Martin Creek along the railroad, and a small section along the Protected Area wall is within the 100-year floodplain based on the 2018 Martin Creek Flood Study Summary (Arcadis, 2018) for NFS as provided in a RAI response (ML23040A067). That flood study is under review by the Federal Emergency Management Agency (FEMA). Due to the potential of flooding near Martin Creek and the North Site during a major rain event, a continued commitment in LA Section 1.3.4 states that NFS personnel will ensure water ways remain clear and remove any debris that could impede this flow. The NRC staffs detailed evaluation of the updated floodplain information is in Section 2.3.4 of this SER. The existing measures in the LA remain acceptable for the updated floodplain. Thus, the NRC staff finds the proposed changes to the LA continue to be acceptable.

The NRC staff also reviewed the U-metal ISA Summary (ML23244A053 and ML23258A073) and the changes made by the licensee to the NFS Site ISA Summary (NFS, 2021a). The ISA Summaries incorporate relevant information regarding the U-metal process and the associated buildings (existing Building 301 and new Building 389, the proposed utility building). The NRC staff finds that the ISA Summaries provide a general description of the site with an emphasis on those factors that could affect safety (i.e., meteorology, seismology) for the U-metal process, as required by 10 CFR 70.65(b)(1).

The NRC staff has reviewed the site description for the U-metal services at the NFS site in accordance with Section 1.3 of NUREG-1520, Rev. 2. NFS has adequately described and summarized general information pertaining to: (1) the site geography, including its location relative to prominent natural and manmade features such as mountains, rivers, airports, population centers, schools, and commercial and manufacturing facilities; (2) population information using the most current available census data; (3) meteorology, hydrology, and geology for the site; and (4) applicable design-basis events. The review verified that the site description is consistent with the information used as a basis for the environmental report, emergency management plan, and ISA Summary.

2.2 Organization and Administration The organization and administration of NFS is unchanged by this amendment. The NRC staff has previously approved the organization, the administrative policies, and the resources to operate the facility. The existing administrative policies (e.g., onsite procedures) include providing operator training and qualification for process operation. In its RAI response (ML23040A067), NFS committed to updating the onsite procedures to reflect operator training and qualification for the U-metal services. That commitment is captured in new condition S-9 that is being added to materials license SNM-124 (see Section 4.0 of this SER). The NRC staff concluded that NFS has an acceptable organization, administrative policies, and sufficient qualified resources to provide for the safe operation of the facility under both normal and abnormal conditions.

2.3 ISA and ISA Summary 2.3.1 Purpose of Review The purpose of this ISA review is to establish whether NFS has met the requirements to perform the following tasks for the new U-metal services:

  • Conducted an ISA of appropriate detail for each applicable process, using methods and staff adequate to achieve the requirements of 10 CFR 70.62(c)(1) and (2).
  • Identified and evaluated, in the ISA, all credible events (accident sequences) involving process deviations or other events internal to the facility (e.g., explosions, spills, and fires) and credible external events that could result in facility-induced consequences to workers, the public, or the environment, that could exceed the performance requirements of 10 CFR 70.61.
  • Designated engineered and administrative items relied on for safety (IROFS) and correctly evaluated the set of IROFS addressing each accident sequence, as providing reasonable assurance, through preventive or mitigative measures and through application of supporting management measures (discussed in Section 2.11 of this SER) that the performance requirements of 10 CFR 70.61 are met.

2.3.2 ISA Information To support this amendment to add the U-metal services at the NFS site, the licensee made changes to the LA (ML21327A099 and ML23251A224) and provided the Building 301 HEU Metal Production Facility ISA Summary (ML23244A053 and ML23258A073), which is also known as the U-metal ISA Summary. The licensee also made changes to the NFS Site ISA Summary (NFS, 2021a) to incorporate relevant information regarding the U-metal process and the associated buildings (existing Building 301 and new Building 389, the proposed utility building). In the NFS Site ISA Summary, the licensee made no changes to the description of the: team, qualifications, and the methods used to perform the ISA; proposed quantitative standard used to assess the consequences in 10 CFR 70.61 (b)(4) and (c)(4); and definitions of unlikely, highly unlikely, and credible as used in the ISA. The NRC staff previously reviewed these descriptions in the SER for the NFS License Renewal, Safety and Safeguards Evaluation Report - Renewal of License SNM-124 for Nuclear Fuel Services, Inc., Erwin, Tennessee - Docket Number 70-143 (ML102780085). Therefore, the NRC staff finds these descriptions applicable and appropriate for the new U-metal services and, therefore, the NRC staff continues to find this information acceptable for the NFS Site ISA Summary.

The NRC staff reviewed the U-metal ISA Summary and other information, including the proposed changes to the LA and NFS Site ISA Summary to confirm that the licensee: performed an ISA of an appropriate level of detail for the complexity of the U-metal process, identified and evaluated relevant credible hazards and accidents as required by 10 CFR 70.61, identified and evaluated appropriate controls, such as IROFS and the associated management measures, and demonstrated that the performance requirements in 10 CFR 70.61 will not be exceeded.

During its review, the NRC staff identified key areas in which to focus its evaluation. These areas included the independence of controls (i.e., common-mode vulnerability, as discussed in NUREG-1520, Rev. 2 and documentation thereof, which could affect the likelihood indices assumed in the ISA for certain event scenarios; evaluation of specific hazards, such as changes to the flood hazard evaluation and the identification and evaluation of specific event scenarios leading to a breach of a (( )); the basis for, and documentation of, the evaluation of certain nodes of the U-metal process which are or have been used for existing facility processes and were considered by the licensee to be outside of the scope of the LAR; and the licensees treatment of natural phenomena hazards (NPH). The NRC staffs evaluation regarding each of these key areas is described below.

2.3.3 Independence of Controls The NRC staff reviewed accident sequences to evaluate their likelihood assessments and ensure appropriate likelihood scores are applied, consistent with the licensees existing ISA methodology as described in the LA for materials license SNM-124, to the initiating event, any enabling events, and the failure of assigned IROFS for each accident sequence reviewed. While the NRC staff found that NFS adequately assessed the likelihood indices of the identified accident scenarios, the NRC staff identified questions regarding certain criticality scenarios for which the likelihood assessments did not appear to consider potential dependence effects among assigned IROFS. The NRC staff had discussions with the licensee during a visit to the licensees site on June 8 and 9, 2022 (ML23097A099) regarding these scenarios and the potential for dependence between IROFS assigned to the scenarios. Based on these discussions, the NRC staff also took into consideration the margins in the accident scenarios assessments, as described below.

Item 9 in Section 3.4.3.2 and Appendix B to Chapter 3 of NUREG-1520, Rev. 2, discuss qualities (e.g., availability, reliability, independence, and margin - or safety margin) that can influence the index scores assigned to IROFS. Thus, in its review, the NRC staff considered what margins, if any, exist to ensure subcriticality and that safety margins need to be evaluated together with the effects of dependence to determine whether the evaluations for these criticality accident sequences demonstrate compliance with 10 CFR 70.61 performance requirements.

For this evaluation of margins, the NRC staff reviewed supporting documentation that provided docketed values to the U-metal ISA Summary (ML23244A053 and ML23258A073). The NRC staff reviewed nuclear criticality safety evaluations (NCSE) for nodes 3, 4, and 5.

The documents provided insights on the docketed information and safety margin in the assessment of the effects of dependence on these criticality scenarios. By reviewing these NCSEs, the NRC staff identified that there are conservatisms in calculations for determining subcriticality, which contribute to margins. The NRC staff also identified that the licensees docketed evaluations show, for relevant accident sequences, margins between what the IROFS allow and what is necessary for criticality to be possible. This includes scenarios that remain subcritical where control limits on mass for example are exceeded significantly or spacing requirements are violated, including in combination with other unfavorable conditions. The demonstration of these margins and the size of the margins help to counter the effects of dependence between the IROFS credited for the accident sequences and support the acceptability of the licensees index scores for them.

The licensees method is to treat credible criticality accidents as high consequence events.

In accordance with 10 CFR 70.61(b), high consequence events must be highly unlikely.

The licensees method defines a total likelihood index score for highly unlikely. The total likelihood index scores for the accident sequences in question, as evaluated by the licensee, are more negative than the score needed to achieve highly unlikely. Thus, in addition to the margins as discussed above, even if the IROFS scores for these accidents were adjusted to account for dependence effects, the NRC staff considers that the total scores for the controlled sequences would still result in the sequences being highly unlikely per the licensees definition.

Therefore, based on the existence and size of the safety margins between the limits and controls established in the IROFS for these criticality accident sequences and the conditions for criticality to be possible as well as the margin in the accident sequences total likelihood scores versus the index score to be highly unlikely, the NRC staff concluded the dependence (or common-mode vulnerability) issue that could potentially affect safety assurance is adequately compensated for and that the analyses of these accident scenarios are adequate to demonstrate compliance with 10 CFR 70.61.

2.3.4 Flood Hazard Evaluation In its review, the NRC staff also considered the licensees evaluation of flood hazards for the site, including the proposed changes to that evaluation as described in Section 1.3.4 of the LA.

The NFS Site ISA Summary (NFS, 2021a) states that the NFS site is not within the 100-year flood plain of the Nolichucky River and Martin Creek. In addition, the NFS Site ISA Summary (NFS, 2021a) also states that the 1997 maps from the flood study conducted by FEMA indicate that portions of the NFS Protected Area are within the 100-year flood plain of Martin Creek. NFS expects that future updated FEMA flood maps of the Erwin area and NFS site will be consistent with the 2018 Martin Creek Flood Study Summary (Arcadis, 2018) that NFS contracted with Arcadis to conduct to provide an updated flood plain map for Martins Creek and indicates that the NFS protected area is no longer within the 100-year flood plain.

The results of the Arcadis study account for the impacts of changes to the area around the NFS site which affect the topography and the hydrology of the area. The proposed changes to Section 1.3.4 of the LA describe some of these changes (e.g., enlarged culvert for the creek to flow through under the railroad that runs adjacent to the site). The description in the NFS Site ISA Summary is unchanged in the LAR, having already included information about the study and the changes to the area around NFS. The proposed changes in the LA make the LAs description of the flood hazard evaluation more consistent with the description in the NFS Site ISA Summary. The proposed changes also initially included removal of the discussion of certain measures that have been relied on to minimize the impacts of flooding on the site (e.g., early warning, relocation of materials and equipment susceptible to water damage).

The 2018 Martin Creek Flood Study Summary (Arcadis, 2018) uses two methods to identify the 100-year flood plain for the area around the NFS site. One method shows the NFS protected area to be out of the 100-year flood plain with only a small part of the northern property in the flood plain. Another method, using light detection and ranging data, also indicates the NFS protected area to be out of this flood plain, but it shows that to be the result of the protected area wall.

The NRC staffs review identified that, even using the 1997 FEMA flood maps, the U-metal process and utility buildings (i.e., Buildings 301and 389) are outside of the 100-year flood plain and the 500-year flood plain. Thus, the change in the flood evaluation has no impact on the proposed U-metal process; however, it is relevant for other licensed processes at the site. The NRC staff notes that, per the current LA, the licensee has implemented measures to mitigate the impacts of flood events. In proposing to remove these measures from the LA, the licensee would be making a change to its commitments regarding the site in relation to flooding hazards.

The NRC staff identified that the change would mean that the protected area wall would be relied on to prevent flooding of the site for those affected processes. This change would necessitate the NRC staffs review of the effects of the changes for those processes and whether the protected wall should be an IROFS for them. The licensee revised its amendment application to restore the existing measures in the LA, which remain acceptable for the updated floodplain. Thus, the NRC staff finds the proposed changes to the LA regarding the flood hazard to be acceptable and the existing commitments for the licensee regarding flood hazards continue to ensure compliance with the performance requirements in 10 CFR 70.61.

2.3.5 Evaluation of (( )) Breach Scenario In its review of the licensees evaluations regarding breaches of the (( )), the NRC staff identified a scenario that did not appear to be addressed in the licensees evaluations. The NRC staff also noted that there was an evaluation that appeared to be incomplete, for which an analysis was needed to determine credibility of the accident. The NRC staff-identified scenario involved (( )). The licensee pointed to one of its analysis scenarios, which it stated bounds the NRC staff-identified scenario but also explained why the NRC staffs particular scenario was not analyzed.

The justification for not analyzing the scenario relies on it taking multiple steps to lead to the failure and appeared to rely on the assumption of independence between those steps. The NRC staff observed that the steps have a significant degree of dependence, leading to the NRC staffs questioning of the licensees conclusion. The NRC staff also recognized the licensee provided some strength data for the (( )) at different temperatures and a conservative calculation of the (( )) maximum temperature, showing the (( )) melting temperature will not be exceeded. However, it was not clear that the cited strength data bounds the temperatures the (( )) could experience with a reaction occurring (( )). Also, while the melting temperature may not be exceeded, it was not clear to the NRC staff that the (( ))

doesnt reach a temperature at which its strength capacity would be insufficient for the pressures generated by the reaction.

The NRC staff had a discussion with the licensee, held on March 20, 2023 (ML23090A153), to get further clarification on the docketed justification as well as to better understand the licensees analyzed accident sequence and how it bounds the NRC staffs scenario in terms of likelihood and consequences. In that discussion, the licensee clarified its docketed method for determining frequency/likelihood scores of initiating events and its approach for considering the

(( )) failure, which assumes that failure happens in the licensees analyzed sequence. The docketed methodology provides a basis for the licensee determining that the analyzed accident sequence bounds the NRC staff identified scenario. The licensees sequence includes several potential initiating events; the NRC staff identified-scenario would be an additional case that also fits within the bounds of the licensees evaluated accident sequence.

The NRC staff also questioned the appropriateness of the frequency score for the analyzed sequences initiating event. Given the licensees qualitative definitions of the frequency index scores, descriptions of the process from which an understanding of the potential number of times the operations will be performed, and basic understanding of human reliability, the NRC staff considered that a frequency score of -1 for this accidents initiating event would be non-conservative and not align with the licensees definition for a -1 score. Instead, the NRC staff considered that, based on the licensees qualitative definition for it, a frequency score of 0 for the initiating event seemed more appropriate. However, the NRC staff noted that even if the initiating event frequency score were raised from -1 to 0 for the licensee-analyzed scenario (whether for what the licensee considered in developing that sequence or to also include the NRC staff-identified scenario), the credited IROFS are sufficient such that the controlled accident sequence does not exceed the performance requirements in 10 CFR 70.61. Based on the above considerations, the NRC staff finds reasonable assurance that the licensees analyzed scenario does not exceed regulatory requirements and is adequate to cover the NRC staff-identified scenario.

For the other accident scenario, the NRC staff requested, and the licensee provided, information about the completed credibility determination for the scenario. The licensees evaluation included historical data (no accident having occurred for this process at another facility), the conservative calculation of maximum (( )) temperature noted above and some additional points regarding temperatures and factors relevant to those temperatures (e.g., rate or reaction and reaction cool down). With this information, the licensee justified that the scenario is not a concern. Based on the NRC staffs review of the scenario description and the licensees response, the NRC staff finds the licensees determination is reasonable.

2.3.6 Out-of-Scope Process Nodes The LAR identified that certain nodes of the U-metal process are outside the scope of the amendment. The basis for this determination was the licensees evaluation of the nodes for the U-metal process against the criteria in 10 CFR 70.72. The nodes that were determined to be out-of-scope are part of processes that are already approved for use at NFS.

The NRC staff identified some information needs regarding the licensees approach of considering some nodes of the process as out-of-scope such that limited information was provided regarding these nodes, i.e., as information-only, without the evaluations that would otherwise be provided. These questions were in part based on the definition of ISA in 10 CFR 70.4, which indicates that an ISA can be performed process by process, but all processes must be integrated, and process interactions considered. The NRC staff asked RAIs (ML22234A293) on this topic based on the necessity of a connection of the entire U-metal process and an understanding of the interfaces between the nodes that are in-scope and those that the licensee determined to be out-of-scope.

In its response to the relevant RAIs (ML23041A235 and ML23040A067), the licensee described the interface between each U-metal process node, including between the out-of-scope and the in-scope process nodes and pointed to other NFS process ISA Summaries which capture evaluations for the out-of-scope process nodes. The transfer mechanisms between the in-scope and the out-of-scope nodes make the nodes significantly independent from each other, though as seen in evaluations for the in-scope nodes, there can still be operations, or deviations from those operations, in one node that affect operations and contribute to the cause of accident sequences in a subsequent node. In its review of the accident sequences in the U-metal ISA Summary for the in-scope nodes and supporting documentation (e.g., NCSEs), the NRC staff identified that the licensees evaluations of accident sequences for these nodes include effects of deviations in the out-of-scope nodes and demonstrates that these nodes are appropriately designated. Based on this review and the RAI response, the NRC staff found that these questions are adequately resolved. Furthermore, in its RAI response, the licensee indicated it will add the out-of-scope node information to the U-metal ISA Summary (ML23244A053 and ML23258A073) prior to a readiness assessment and will provide it to the NRC once construction of all the U-metal process nodes is complete. In addition, the NRC staff will conduct an operational readiness review (new condition S-9 is being added to materials license SNM-124 - see Section 4.0 of this SER) prior to operation of the U-metal process, which will be an opportunity to further confirm the ISA Summaries are up to date and include necessary information, including hazard, IROFS, and identification and evaluation of management measures.

2.3.7 Structural and NPH Safety 2.3.7.1 Purpose of Review The purpose of this review is to evaluate whether the application meets the applicable requirements for the systems, structures, and components (SSCs) for the proposed U-metal services. The NRC staff reviewed how the information in the application addressed the following regulations:

  • 10 CFR 70.61(e) requires, in part, that each engineered or administrative control or control system that is needed to comply with 10 CFR 70.61 (b), (c) or (d) be designated as an IROFS and requires that the safety program ensuring that each IROFS will be available and reliable to perform its intended function when needed.
  • 10 CFR 70.62(c)(iv) requires, in part, that each licensee conduct and maintain an ISA that identifies potential accident sequences caused by credible external events, including natural phenomena.
  • 10 CFR 70.64 requires, in part, that the design of new facility processes incorporate baseline design criteria and defense-in-depth practices and provide adequate protection against NPH.

2.3.7.2 Scope of Review The scope of the NRC staffs review focused on the changes associated with the amendment.

The licensee proposed the following changes to SSCs to support the amendment for the U-metal services:

  • Modifications to the Building 301 structure,
  • Addition of new equipment and internal structures within Building 301,
  • Design of a new building structure, Building 389,
  • Design of a new platform and exhaust stack between Building 301 and Building 389, and
  • Addition of new equipment and internal structures within Building 389.

The NRC staff used the guidance in NUREG-1520, Rev. 2 and Interim Staff Guidance FCSE-ISG-15, Natural Phenomena Hazards in Fuel Cycle Facilities (ML15121A044), in its review.

The NRC staff reviewed the licensees design bases and design criteria for SSCs and NPH, the methods for evaluating and designing the SSCs, and the incorporation of the NPH assessments into the ISA Summaries, including the identification of NPH IROFS and demonstration of the performance requirements in 10 CFR 70.61. The licensee described the NPH for the site in the NFS Site ISA Summary (NFS, 2021a). The NRC staffs review of the licensees determination of these NPH is documented in the NRC SER dated July 6, 2017 (ML17184A050), which evaluated the NFS response to Generic Letter 2015-01, Treatment of Natural Phenomena Hazards in Fuel Cycle Facilities, and was verified by the NRC staff in Inspection Report No. 70-143/2017-006 dated August 4, 2017 (ML17216A146). Many of these NPH were unaffected by changes in this amendment, and thus the hazard determination for these unaffected NPH were outside the scope of this review.

The NRC staff reviewed the structural analyses of risk-significant SSCs to determine if the licensees design approach was consistent with the design bases and design criteria. The NRC staff followed the guidance in Section 3.5 of NUREG-1520, Rev. 2 for performing a vertical slice review and therefore did not perform a complete review and approval of the design of every SSC. Finally, the NRC staff notes that aspects of the licensees design approach for Building 389, the internal SSCs within Building 389, and the new external SSCs (i.e., the mechanical equipment platform and the exhaust stack) will be verified in an operational readiness review as discussed in new condition S-9 that is being added to special nuclear material license SNM-124

- see Section 4.0 of this SER.

The NRC staff evaluated the information the licensee provided for the SSCs in the LA (ML21327A099 and ML23251A224), the U-metal ISA Summary as revised by letter dated August 25, 2023 (ML23244A053), and page changes received on September 15, 2023 (ML23258A073), the NFS Site ISA Summary (NFS, 2021a), and the following supplementary information and design documents available at the licensees offices and made available to the NRC staff for this review:

  • IEPLLC Document No. 22421001-SR-002, Rev. 0, Nuclear Fuel Services U-metal Project NPH Review (IE, 2022).
  • REP-UMETAL-0006, Rev. 0, Equipment Evaluation for Seismic Event (NFS, 2023d).
  • DESCALC-UMETAL-S106, Rev. 0, Building ZZ1 Existing Structure (Floor, Roof, and Walls) (NFS, 2023e).
  • DESCALC-UMETAL-S101, Rev. 0, Building ZZ1 Column Rack Seismic Analysis (NFS, 2022a).
  • DESCALC-UMETAL-S103, Rev. 0, Building ZZ1 Furnace Room Support Seismic Analysis (NFS, 2022b).
  • DESCALC-UMETAL-S105, Rev. 0, Building ZZ1 ModCon Structure (NFS, 2022c).
  • DESCALC-UMETAL-S200, Rev. 0, U-Metals Enclosures Seismic Anchorage Analysis (NFS, 2022d).

The NRC staff closely coordinated its review of the structural and NPH design bases and evaluations of SSCs with the review of accident sequences, the ISA, and the ISA Summary described in other portions of Section 2.3 of this SER.

2.3.7.3 NRC Staff Review and Analysis In reviewing the LAR, the NRC staff noted that the licensees initially proposed approach for NPH differed from how other hazards are treated in the licensees ISA methods. The proposed approach appeared to be similar to the approach used for facility processes that were in existence prior to the implementation of 10 CFR Part 70, Subpart H, which specified the requirements for an ISA. Although multiple nodes of the U-metal process are from already approved processes in the current licensing basis, the NRC staff notes that the U-metal process is a new process at the facility that needs to be addressed appropriately, consistent with the requirements for new facilities and new processes in 10 CFR 70.64 and the identification of controls relied on to meet the 10 CFR 70.61 performance requirements in 10 CFR 70.61 as IROFS, including for NPH.

Prior to accepting the LAR for detailed technical review, the NRC staff issued RSIs by letter dated January 21, 2022 (ML22014A421), which included questions on NPH. During the detailed technical review, the NRC staff issued RAIs by letter dated August 31, 2022 (ML22234A293),

which also included questions on NPH. Furthermore, during a public meeting held with the licensee on June 29, 2023 (ML23206A171), the NRC staff described the additional information needed to ensure that the licensee has identified and evaluated potential accidents for NPH in its ISA, and to establish IROFS and management measures for NPH that comply with the regulatory requirements in 10 CFR 70.61 and 70.64.

By letter dated August 25, 2023 (ML23244A053), and page changes received on September 15, 2023 (ML23258A073), the licensee revised its NPH approach to be consistent with these requirements. In its revised approach, the licensee identified two additional IROFS, one for seismic load resistance and the other for high wind load resistance. Both IROFS include the buildings or structures housing and supporting the new U-metal process as well as the structural components associated with the internal process systems for the new U-metal process. Both IROFS are also sole IROFS and are described in Table 8-1 of the U-metal ISA Summary (ML23244A053 and ML23258A073).

In reviewing the licensees revised NPH approach for the U-metal process, the NRC staff referred to the NFS Site ISA Summary (NFS, 2021a), which describes the NPH hazards that the licensee has determined and evaluated for its site. The U-metal ISA Summary includes additional information regarding these hazards, including the evaluation of means for ensuring compliance with the 10 CFR 70.61 performance requirements for NPH events (Sections 4.2.5 and 4.3.1). The NRC staff did not re-review the NPH identification and evaluation described in the NFS Site ISA Summary (NFS, 2021a), with the exception of the licensees revised flooding evaluation as described in Section 2.3.4 of this SER. The NRC staffs review was limited to ensuring appropriate identification and evaluation of controls (i.e., IROFS) for the U-metal process for NPH previously identified for the site. Based on its review, the NRC staff finds the licensee has appropriately determined the needed IROFS to ensure compliance with the performance requirements in 10 CFR 70.61 and the requirements in 10 CFR 70.64 for NPH events.

2.3.7.3.1 Description of Facility Structures Building 301 houses the main production equipment for the U-metal services. The Building 301 structure consists of (( )). The licensee performed a structural evaluation of the existing building for the new loads on the structure caused by equipment and supports for the U-metal services.

The licensee proposed to install a variety of new equipment and construct internal structures in Building 301 to support the U-metal services. These internal SSCs include (( )). The licensee performed an evaluation to categorize the potential risk and importance of the internal SSCs and performed qualitative or quantitative structural analyses, accordingly.

Building 389 houses utility equipment supporting the U-metal services. The licensee proposed to construct the new building to the west of Building 301. The Building 389 structure consists of

(( )). The East-West lateral load resisting system is a (( )), and the North-South lateral load resisting system consists of (( )). Between Building 301 and Building 389, the licensee also proposed to construct a (( )).

The licensee proposed to install a variety of new equipment and construct internal structures in Building 389 to support the U-metal services. The utility equipment in Building 389 includes

(( )). The internal structures include a (( )).

2.3.7.3.2 Structural Design Bases and Design Criteria The licensee described the design bases and design criteria for the SSCs supporting the U-metal services in the NFS Site ISA Summary (NFS, 2021a), the U-metal ISA Summary (ML23244A053 and ML23258A073), and in the engineering report on NPH, IEPLLC Document No. 22421001-SR-002, Rev. 0 (IE, 2022). The licensee considered NPH including snow, ice, rain, wind-generated missiles, lightning, tornadoes, flooding, seismic, and high winds.

As described in the NFS Site ISA Summary (NFS, 2021a) and discussed in more detail in the U-metal ISA Summary (ML23244A053 and ML23258A073), the licensee determined the design bases and the design criteria for the SSCs from the specified version of the International Building Code (IBC). The IBC requirements include the specialized codes and standards that must be followed for a structure based on its construction materials and other characteristics.

The NRC staff confirmed that these specialized codes and standards are part of the structural designs of the SSCs. As part of that confirmation, the NRC staff conducted a vertical slice review which is further discussed in Section 2.3.7.3.3 of this SER.

For the evaluation of the new loads on Building 301 resulting from the proposed modifications, the licensee determined the structural design loads following IBC 2018 (ICC, 2018) and the American Society of Structural Engineers (ASCE) standard, ASCE 7-16, Minimum Design Loads and Associated Criteria for Buildings and Other Structures (ASCE, 2016). In this evaluation, the licensee demonstrated that the modifications to Building 301 to support the U-metal services remain bounded by the previous structural analysis of Building 301 based on the loads analyzed. As described in the U-metal ISA Summary (ML23244A053 and ML23258A073), the design code for Building 301 is IBC 2012. The NRC staff finds that IBC 2018 is an acceptable code for evaluating the new loads on Building 301 resulting from the proposed U-metal modifications because the later code relies on more current hazards models and results in only minor changes in structural loads based on a comparison by the NRC staff.

The licensee previously analyzed the Building 301 structure in 2016, as described in the NFS Site ISA Summary (NFS, 2021a) and the engineering report, NSA-TR-NFS-14-01, Revision 1, Seismic Evaluation of the Nuclear Fuel Services Fuel Fabrication Facility (NFS, 2016). In the previous analysis, the licensee determined the structural design bases following IBC 2012 (ICC, 2012a) and ASCE 7-10. The licensee also considered guidance from NUREG-1520, Rev. 2 and DOEs DOE-STD-1020-2002, Natural Phenomena Hazards Design and Evaluation Criteria for Department of Energy Facilities (DOE, 2002). The NRC evaluation dated July 6, 2017 (ML17184A050), which evaluated the NFS response to Generic Letter 2015-01, documents the NRC staffs review of the licensees design bases criteria and structural evaluation methodology used for the analysis of Building 301 using IBC 2012 (ICC, 2012a).

The licensee relied on this previous analysis in its evaluation of the modifications to Building 301 as discussed in Section 2.3.7.3.3 of this SER.

The licensee determined the structural design bases for Building 389 and the new external structures (e.g., the mechanical equipment platform) following IBC 2018 (ICC, 2018) and ASCE 7-16 (ASCE, 2016) with consideration of guidance from NUREG-1520, Rev. 2 and DOE-STD-1020-2002 (DOE, 2002). The licensee categorized Building 389 based on criteria in IBC 2018 (ICC, 2018) and the risks associated with the utility equipment inside the building.

From ASCE 7-16 (ASCE, 2016), the licensee determined a design snow load of (( )) pounds per square foot (psf), a design rain intensity of (( )) inches/hour, and a design-basis wind speed of (( )) miles per hour with an exposure category of (( )).

While ASCE 7-16 (ASCE, 2016) and DOE-STD-1020-2002 (DOE, 2002) do not require design for wind missiles based on the design wind speed and performance category of Building 389, the (( )). In a tornado assessment described in the NFS Site ISA Summary (NFS, 2021a),

the licensee concluded that the initiating event frequency of a tornado is highly unlikely. The NRC evaluation dated July 6, 2017 (ML17184A050), which evaluated the NFS response to Generic Letter 2015-01, documents the NRC staffs review of the licensees approach and assessment of tornado events. The NRC staff finds that the previous assessment is unaffected by changes in this amendment and the approach.

The licensee followed National Fire Protection Association (NFPA) 780, Standard for the Installation of Lightning Protection Systems (NFPA 780, 2020), in the design of Building 389 to provide lightning protection and prevent any substantial damage from lightning. The NRC staff notes that the use of NFPA 780 (NFPA 780, 2020) to establish the design basis and criteria for lighting events is consistent with the methodology described in the NFS Site ISA Summary (NFS, 2021a) and previously reviewed by the NRC staff in the NRC evaluation dated July 6, 2017 (ML17184A050). The licensee designed the foundation of Building 389 for an allowable soil bearing pressure of (( )) psf based on previous geotechnical investigations for the site.

The NRC staff notes that the new processes will be verified to have been constructed in accordance with the designs during an operational readiness review, as discussed in new condition S-9 that is being added to materials license SNM-124 - see Section 4.0 of this SER.

The licensee developed the seismic design bases for Building 389 using the seismic design maps in ASCE 7-16 (ASCE, 2016), which are prepared by the United States Geological Survey using the 2014 National Seismic Hazard Model. In the supporting documentation referenced by the U-metal ISA Summary (ML23244A053 and ML23258A073), the licensee documented the selection of a seismic importance factor of (( )), a soil site class of (( )), a seismic design category of (( )), and a response modification coefficient of (( )) and (( )). The licensee determined a short period design spectral response acceleration of (( )) force per unit mass due to gravity at the Earths surface. The licensee then used the Equivalent Lateral Force procedure following ASCE 7-16 (ASCE, 2016) to determine the seismic loads. The NRC staff finds that the selection of the design codes, methodology, and information for determining the seismic design basis aligns with the nationally recognized standard for this type of facility and is acceptable.

The licensee determined the structural design bases for new equipment and internal structures within Building 301 following IBC 2018 (ICC, 2018) and ASCE 7-16 (ASCE, 2016). The licensee primarily considered the seismic loads in design and evaluation of these internal SSCs, since the SSCs are protected from other NPH loads by the building structure. As discussed in REP-UMETAL-006, Rev. 1, the licensee performed a qualitative evaluation of the internal SSCs to determine which SSCs and potential failure mechanisms required engineering analysis or additional NPH requirements following criteria from ASCE 7-16 (ASCE, 2016). In most cases, the licensee relied on a qualitative evaluation to justify continued function of an SSC based on the ability of the facility to meet the performance requirements of 10 CFR 70.61 in the event of SSC failure or the low magnitude of the seismic hazard at the site and structural strength of the SSC. From this evaluation the licensee identified some SSCs in Building 301 for further engineering analysis, (( )). The licensee then determined the design loads for the SSCs following methodology in ASCE 7-16 (ASCE, 2016) for either non-building structures or non-structural components. For non-building structures, the licensee used a seismic design category of (( )), an Importance Factor of (( )), and a response modification coefficient of (( )).

For non-structural components, the licensee used a seismic design category of (( )), an Importance Factor of (( )) based on the criteria in Section 13.1.3 of ASCE 7-16 (ASCE, 2016), and component amplification factors and response modification factors dependent on the component.

For the structural design bases for new equipment and internal structures within Building 389, the licensee stated in Section B2.3 of IEPLLC Document No. 22421001-SR-002, Rev. 0 (IE, 2022) that it performed a qualitative evaluation of the potential impacts to IROFS when Building 389 SSCs are subjected to the design seismic event. In the same section of the report, the licensee stated that certain internal SSCs to Building 389, such as (( )) will be evaluated for seismic loads following IBC 2018 (ICC, 2018) and ASCE 7-16 (ASCE, 2016). The NRC staff notes that the as-built configurations for these designs and evaluations will be verified to be consistent with the design codes and standards during an operational readiness review, as discussed in new condition S-9 that is being added to materials license SNM-124 - see Section 4.0 of this SER.

In the ISA Summaries, the licensee established that the structural design methodology and design criteria for the new building structure and the internal and external SSCs designed for the U-metal services is IBC 2018 (ICC, 2018).

Based on a review of the supplementary information and design documents made available, the NRC staff concludes that the licensee appropriately followed the selected industry codes and standards in developing the design bases and design criteria for the SSCs associated with the U-metal services. Because the structural design bases and design criteria determined for the site are based on industry accepted codes, standards, and procedures that considers historical events, the NRC staff finds that the regulatory requirements of 10 CFR 70.64(a)(2) are met.

The NRC staff also finds that the selected industry codes and standards and the derived design bases and design criteria from using the IBC standard adequately address NPH. The NRC staff finds that the design bases and design criteria are consistent with NUREG-1520 and FCSE-ISG-15 and provide sufficient structural performance allowing SSCs to perform their safety function under the design-basis accidents, including NPH. Thus, the NRC staff finds that the design bases and design criteria are appropriate for demonstrating the NPH requirements of 10 CFR 70.62.

2.3.7.3.3 Structural Analysis Methods As a means of confirming that the licensee design methodology was in accordance with codes and standards described in the ISA, the NRC staff conducted a vertical slice review of selected structural analyses of the Building 301 structure and internal SSCs made available by the licensee, as discussed in Section 2.3.7.2 of this SER. The NRC staff used the guidance in Section 3.5.2.3(3) of NUREG-1520, Rev. 2 in its vertical slice review.

For the Building 301 structure, the licensee evaluated the structural design loads for the building with the modifications for the proposed U-metal services and compared these to the design loads used in the licensees previous structural analysis of Building 301 in the report DESCALC-UMETAL-S106, Rev. 0 (NFS, 2023e). The licensees modifications to Building 301 removed existing equipment and internal SSCs that generate loads on the building structure, and the licensee designed new standalone internal structures to support most of the new equipment. The licensee determined that the modified loads on Building 301 were less than or equivalent to the loads considered in the previous analysis and thus the previous structural analysis of Building 301 is bounding for the U-metal services. For this amendment, the NRC staff reviewed the changes associated with the U-metal services and the SER for the previous analyses of Building 301, and the NRC staff finds that the licensees evaluation of the new loads on Building 301 is acceptable for addressing the proposed changes to Building 301.

For internal structures, the licensee evaluated the SSCs within Building 301 and identified a variety of SSCs for detailed structural analysis in REP-UMETAL-006, Rev. 1 following criteria in the IBC. Consistent with the IBC, the licensee followed the design methodology specified in ACI 318-14, Building Code Requirements for Structural Concrete and Commentary (ACI, 2014) for concrete design, AISC 360-16, Specification for Structural Steel Buildings (AISC, 2016) and AISC Steel Design Guides for steel design, and AISI S100-16, North American Specification for the Design of Cold-Formed Steel Structural Members (AISI, 2016) and AISI S240-15, North American Standard for Cold-Formed Steel Structural Framing (AISI, 2015) for cold-formed steel design.

The licensee performed structural analyses using hand calculations and the structural analysis programs RISA-3D and STAAD. For the concrete anchorage design, the licensee used the Hilti Profis program. The licensee used the Allowable Strength Design method for steel members and connections, Direct Analysis Method for stability of steel members, Ultimate Strength Design for concrete anchorage, and Load and Resistance Factor Design for base plate of the

(( )) structure.

The NRC staff concludes that the inputs, assumptions, and methodologies used in these designs are consistent with industry accepted codes, standards, and procedures and the design bases and design criteria established for the Building 301 SSCs and are therefore acceptable.

The licensee described the design bases and design criteria for the Building 389 structure, the new external structures (e.g., (( ))), and the internal SSCs within Building 389 in the U-metal ISA Summary and IEPLLC Document No. 22421001-SR-002, Rev. 0 (IE, 2022). The NRC staff notes that the structural analyses and designs for these SSCs will be verified to be consistent with the specified design codes and standards during an operational readiness review, as discussed in new condition S-9 that is being added to materials license SNM-124 - see Section 4.0 of this SER.

The NRC staff concludes the licensees design methodology appropriately followed the selected industry codes and standards in designing and analyzing the SSCs associated with the U-metal services to the design bases. The NRC staffs vertical slice review of the structural analyses indicates that the structural portion of the ISA was accurately performed and is as described in the ISA Summary. The NRC staff finds that the licensees design approach and methodologies ensure that SSCs will be designed and constructed to perform the safety function needed to meet the performance requirements of 10 CFR 70.61 for NPH.

2.3.7.3.4 Structural Safety, NPH Accidents, and IROFS The licensee described its risk assessment, designation for IROFS, and establishment of management measures for the seismic and high wind NPH in Section 4.3.1 of the U-metal ISA Summary. In the risk assessment, the licensee describes the design bases and design criteria for the structures and internal SSCs and how the design for these accidents ensures the performance requirements are met for the U-metal services.

As discussed in the previous sections of this SER, the NRC staff finds that the design bases, design criteria, and design approach adequately protect against the design-basis accidents for the building structures and other SSCs. The NRC staff finds that this design information is sufficient to demonstrate that the safety program for structures and NPH meets the performance requirements of 10 CFR 70.61. Thus, the NRC staff finds that the licensee meets the requirements of 10 CFR 70.62(c)(iv) for appropriately addressing NPH in the ISA and 70.64(a)(2) for providing adequate protection against NPH in the design of the facility.

The licensee identified Building 301, Building 389, and the structural components associated with internal process systems as Natural Phenomena IROFS in Table 6-5 of the U-metal ISA Summary. The licensee described the safety function of the structures as providing structural resistance for seismic and wind loads.

The NRC staff finds that the licensee identified the NPH controls and the structural engineered controls necessary for meeting the performance requirements of 10 CFR 70.61 as IROFS for the U-metal services. Thus, the NRC staff finds that the licensee meets the requirements of 10 CFR 70.61(e) for NPH and structural safety.

In Chapter 11 of the existing LA (ML20078K605), the licensee described the management measures for IROFS, including Natural Phenomena IROFS. The management measures program was previously reviewed and approved by the NRC staff, as discussed in Section 2.11 of this SER. In response to RAIs and during an observational site visit, the licensee discussed and presented some of the internal procedures that implement these management measures for the site SSCs, including those associated with the U-metal services. These procedures related to the Configuration Management Program and the Change Control Process, the Piping Integrity Plan, the Preventive Maintenance Program, and the adherence to the Baseline Design Criteria for IROFS. The NRC staff considered the proposed changes to the facility and finds that the existing management measures are acceptable for ensuring that the structural performance of IROFS for the U-metal services is maintained such that the IROFS are available and reliable to perform their functions. The existing management measures are adequate to ensure the availability and reliability of the identified NPH-related IROFS. Thus, the NRC staff finds that the licensees management measures program meets the requirements of 10 CFR 70.62(d) for NPH and structural safety.

2.3.7.3.5 Structural and NPH Safety Considerations for NRC Operational Readiness Review As discussed in Section 4.0 of this SER, a new condition S-9 being added to materials license SNM-124 will allow the NRC staff to perform an operational readiness review prior to the introduction of special nuclear material into the new portions of the U-metal processes. During the operational readiness review, the NRC staff will verify that new processes have been constructed in accordance with design requirements, the ISA Summaries reflect the final design, and the IROFS are fully defined based on as-built conditions.

For structural safety, the NRC staff will verify that the licensee constructed the Building 389 structure, Building 389 internal SSCs, and the new external SSCs between Building 301 and 389 (i.e., the mechanical equipment platform and the exhaust stack) to the code requirements of IBC 2018 (ICC, 2018) and the relevant structural and NPH design information provided to the NRC staff during the operational readiness review.

2.3.7.4 Evaluation Findings for Structural and NPH Safety The NRC staff reviewed the NPH and structural controls designated as IROFS for the U-metal services and finds that these controls ensure compliance with the performance requirements of 10 CFR 70.61 and therefore satisfy the requirements of 10 CFR 61(c) for NPH and structural safety.

The NRC staff reviewed the NFS Site ISA Summary (NFS, 2021a), the U-metal ISA Summary as revised by letter dated August 25, 2023 (ML23244A053), and page changes received on September 15, 2023 (ML23258A073), and the supplementary information and design documents provided by the licensee. The NRC staff finds that the licensee appropriately conducted an ISA that addresses NPH accidents and the structural performance of SSCs and therefore satisfies the requirements of 10 CFR 62(c)(iv) for NPH and structural safety.

The NRC staff reviewed the management measures described in the LA and finds that the management measures ensure that the structural performance of IROFS for the U-metal services is maintained such that the IROFS are available and reliable to perform their functions and therefore satisfy the requirements of 10 CFR 70.62(d) for NPH and structural safety.

The NRC staff reviewed the NFS Site ISA Summary (NFS, 2021a), the U-metal ISA Summary as revised by letter dated August 25, 2023 (ML23244A053), and page changes received on September 15, 2023 (ML23258A073), and the supplementary information and design documents provided by the licensee. The NRC staff finds that the facility design for the U-metal services provides for adequate protection against NPH and therefore satisfies the requirements of 10 CFR 64(a)(2) for NPH and structural safety.

The NRC staff concludes that the licensees description and evaluation of the NPH and structural safety of the U-metal services adequately demonstrates that the proposed amendment meets the requirements of 10 CFR Part 70.

2.3.8 IROFS Designations In its review of the proposed IROFS for the new U-metal process, the NRC staff identified an IROFS that the licensee designates as an active engineered control but seemed to have a component to it that depends upon operator action. Having this operator action component, the NRC staff considered that the IROFS might be an administrative or an enhanced administrative IROFS. In a discussion with the licensee (ML23090A153), the licensee provided clarification regarding the information provided in the U-metal ISA Summary, explaining that the IROFS design does not require operator actions or responses to perform its function. However, set points must be determined, including whether it requires the one aspect that NRC staff asked about (locking of a door). This will be completed after construction of the process and would be verified during the NRCs operational readiness review (new condition S-9 is being added to materials license SNM-124 - see Section 4.0 of this SER). The NRC staff notes that, even if this IROFS were to change to an administrative IROFS and its effectiveness of protection index adjusted accordingly, the accident sequence for which it is credited would not exceed the performance requirements in 10 CFR 70.61. Thus, while the NRC staff may follow up on this IROFS in the operational readiness review, the NRC staff finds the affected accident sequence still satisfies the regulatory requirements.

2.3.9 Evaluation Findings Based on its review, as described above and in other sections of this SER, the NRC staff found that NFS performed an ISA of an appropriate level of detail for the complexity of the U-metal process and identified and evaluated potential hazards and accidents as required by the regulations. The NRC staff reviewed the U-metal ISA Summary (ML23244A053 and ML23258A073), NFS Site ISA Summary (NFS, 2021a), and supporting information. The NRC staff determined that the ISA Summaries contain the information for the U-metal services, as required by 10 CFR 70.65(b). Furthermore, the NRC staff found that the documentation provides reasonable assurance that the licensee has established a safety program, maintains process safety information and an ISA, and established management measures that demonstrate that the safety program meets the performance requirements of 10 CFR 70.61.

The NRC staff found that NFS performed an ISA, of appropriate level of detail for the complexity of the U-metal process and identified and evaluated potential hazards and accidents as required by the regulations. Furthermore, the ISA results, as documented in the ISA Summaries, provide reasonable assurance for the new U-metal services that the IROFS, management measures, and programmatic commitments will make all credible high consequence events to be highly unlikely and all credible intermediate consequence events to be unlikely. The NRC staff concluded that the NFS safety program provides reasonable assurance that the IROFS will be available and reliable to perform their intended safety functions when needed in the context of the performance requirements.

The NRC staff also concluded that the licensees safety program was established and is maintained pursuant to 10 CFR 70.62 and that it is adequate to provide reasonable assurance that the IROFS are available and reliable to perform their intended safety functions when needed, and in the context of the performance requirements of 10 CFR 70.61.

2.4 Radiation Protection 2.4.1 Purpose of Review The NRC staff conducted this review to determine whether the radiation protection program described in the LA (ML21327A099 and ML23251A224) is adequate to protect the radiological health and safety of workers and to comply with the associated regulatory requirements in 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, 10 CFR Part 20, and 10 CFR Part 70 for the U-metal LAR.

2.4.2 NRC Staff Review and Analysis The proposed U-metal operations will be subject to the same radiation protection provisions as the current licensed inventory. The NRC staff previously concluded, in NRCs SER for the NFS License Renewal (ML102780085), that the current license contains adequate: (a) worker qualification requirements; (b) written radiation protection procedures; (c) radiation work permit program; (d) necessary training for all personnel who have access to radiologically restricted areas; and (e) program for ensuring that worker and public doses are as low as is reasonably achievable (ALARA).

As part of its review, the NRC staff issued RAIs (ML22066B006 and ML22069A315) which asked the licensee to provide the value of the total effective dose equivalent to individual members of the public due to the new U-metal operations. The licensee responded that the total effective dose equivalent to individual members of the public from the licensed operations does not exceed 0.1 rem in a year. The licensee demonstrated in previous amendments compliance with this acceptance criteria by showing that the postulated spill scenarios for the NFS Emergency Plan (EP) specified in Table 2-3 of LA do not exceed the radiation doses in Appendix B to 10 CFR Part 20 when averaged over the course of a year for the (( )). The maximum dose for the postulated scenarios in Table 3-2 is 0.06 rem, which is for a spill due to a break in the (( )). This scenario conservatively considers a material concentration of

(( )). The largest potential (i.e., bounding) spill for the U-metal process is from the (( )).

(( )) and the dose for this scenario is 2.56E-05 rem. Based on the maximum dose for the postulated scenario of a spill due to a break in the (( )) exceeding the dose for the rupture of (( )), the NRC staff concluded that the U-metal operations are bounded by the previously evaluated event in Table 2-3. Therefore, the NRC staff concluded that there no changes necessary to the radiation protection program as a result of the addition of the U-metal operations since it will not exceed the previously approved radiation dose limit to a radiation worker or member of the public.

2.4.3 Evaluation Findings The NRC staff has determined that NFS remains committed to the existing, acceptable radiation protection program that includes the following:

  • An effective documented program to ensure that occupational radiological exposures are ALARA.
  • An organization with adequate qualification requirements for the radiation protection personnel.
  • Approved written radiation protection procedures and radiation work permits for radiation protection activities.
  • Radiation protection training for all personnel who have access to restricted areas.
  • A program to control airborne concentrations of radioactive material with engineering controls and respiratory protection.
  • A radiation survey and monitoring program that includes requirements for controlling radiological contamination within the facility and monitoring external and internal radiation exposures.
  • Other programs to maintain records; report to the NRC in accordance with 10 CFR Part 20 and 10 CFR Part 70; and appropriately respond to, investigate, and prevent incidents and accidents involving radiological exposures or uncontrolled releases of radioactive material.

The NRC staff concludes that the NFS radiation protection program is adequate and meets the requirements of 10 CFR Part 19, 10 CFR Part 20, 10 CFR Part 70, and 10 CFR Part 71. The NRC staff has reasonable assurance that the current radiation protection program, as described in the current license, continues to be adequate for the operations and processes, including the proposed U-metal operations, at the NFS site.

2.5 Nuclear Criticality Safety 2.5.1 Purpose of Review The NRC staff conducted its review of the LAR to ensure that the requested changes are consistent with the criticality safety related requirements of 10 CFR Part 70, including:

  • 10 CFR 70.64, Requirements for new facilities or new processes at existing facilities; and
  • Appendix A to Part 70, Reportable Safety Events.

The NRC staffs review was conducted in accordance with the applicable acceptance criteria in Chapter 5, Nuclear Criticality Safety, of NUREG-1520, Rev. 2, as well as applicable portions of NUREG/CR-6698, Guide for Validation of Nuclear Criticality Safety Calculational Methodology (ML050250061).

2.5.2 NRC Staff Review and Analysis The requested amendment relies on the existing NFS nuclear criticality safety (NCS) program and does not involve changes to the management, organization, or administration of the NCS program; NCS training, NCS staff training, and NCS qualifications; management measures applied to the NCS program including characterization and handling of NCS nonconformances, use of procedures, audits, and assessments; use of industry standards; or technical practices such as the performance and documentation of NCS evaluations, treatment of NCS parameters, validation and verification of computational methods, and commitments related to the assurance of subcriticality and the double contingency principle. These elements of the NCS program were previously evaluated and found to be acceptable by NRC staff as documented in the NRCs SER for the NFS License Renewal, Safety and Safeguards Evaluation Report - Renewal of License SNM-124 for Nuclear Fuel Services, Inc., Erwin, Tennessee - Docket Number 70-143 (ML102780085). Therefore, the NRC staffs review of the LAR focused on the criticality hazards presented by the requested changes and the assurance of subcriticality under normal and credible abnormal conditions thereof; impacts to criticality accident alarm system (CAAS) coverage; impacts to NCS-related aspects of emergency planning and response; and the continued appropriateness of the minimum margin of subcriticality (MMS).

Relevant Criticality Hazards - Normal and Credible Abnormal Conditions The proposed amendment does not involve any changes to the licensees commitments related to technical practices, the assurance of subcriticality under normal and credible abnormal conditions, or the double contingency principle. These commitments were previously evaluated and found to be acceptable by NRC staff as documented in NRCs SER for the NFS License Renewal (ML102780085). Therefore, the NRC staffs review focused on whether the proposed activities present any new types of criticality-related accident sequences or normal and credible abnormal conditions, and whether the licensees existing commitments are sufficient to continue to satisfy the requirements of 10 CFR 70.61.

The NRC staff reviewed the LAR and ISA and determined that although the proposed amendment adds criticality-related accident sequences to the existing ISA, it does not involve the addition of any new types of criticality-related accident sequences. The fissionable material composition, physical form, enrichment, (( )) ratio, geometry, neutronic interaction, reflection, and concentration that may be present under normal and credible abnormal conditions are bounded by existing processes and operating experience of the licensee.

Likewise, the nature of normal and credible abnormal conditions (i.e., upset conditions) are bounded by the credible abnormal conditions (e.g., moderation upsets, over-massing upsets, solution backflow upsets, etc.) of existing processes at the NFS site and documented in the ISA and applicable NCS evaluations. Therefore, the NRC staff determined that the LAR does not present any types of criticality-related accident sequences or normal and credible abnormal conditions in which the licensee does not have operating experience and documented in the ISA.

The NRC staff reviewed the LA (ML21327A099 and ML23251A224). Section 5.5 of the LA describes the licensees commitments to technical practices and states that NCS parameters will be assumed to be at their optimum (i.e., most reactive) credible value unless acceptable controls are specified and implemented to limit the parameter to a value less reactive than optimum. The licensee has committed to meeting the double contingency principle, in accordance with 10 CFR 70.64(a)(9), and is subject to the requirements of 10 CFR 70.61, which necessitate that the licensee limit the risk of criticality such that its likelihood of occurrence is highly unlikely in accordance with 10 CFR 70.61(b) and assure subcriticality under normal and all credible abnormal conditions with an approved margin of subcriticality for safety in accordance with 10 CFR 70.61(d). This is required for all processes that pose a credible criticality risk. The NRC staff determined that the requirements of 10 CFR 70.61(b) and 10 CFR 70.61(d) are sufficient to limit the risk of criticality to an acceptable level and that the requested changes do not dilute, alter, or negate the licensees obligation to meet these requirements. Therefore, consistent with the NRC staffs evaluation documented in NRCs SER for the NFS License Renewal (ML102780085), the NRC staff determined that the licensees existing commitments are sufficient to satisfy the requirements of 10 CFR 70.64(a)(9) and 10 CFR 70.61, with respect to criticality-related hazards, and provide reasonable assurance of adequate protection against all credible criticality-related hazards. The NRC staffs evaluation of the proposed changes to the ISA are documented in Sections 2.3 of this SER.

Criticality Accident Alarm System The proposed amendment does not involve any changes to the licensees commitments related to CAAS coverage. These commitments were previously evaluated and found to be acceptable by NRC staff as documented in NRCs SER for the NFS License Renewal (ML102780085).

The activities described in the LAR will mostly take place in Building 301, a location in which fissionable material operations have previously been authorized and performed as part of the licensees former (i.e., decommissioned) commercial development line and subject to existing CAAS coverage. However, the proposed changes do involve modifications to existing CAAS coverage to ensure CAAS coverage of Building 389 - Utilities Building. Therefore, the NRC staff reviewed the licensees existing commitments related to CAAS coverage to ensure that the commitments are sufficient to continue to satisfy the requirements of 10 CFR 70.24.

The licensees existing CAAS and modifications are maintained consistent with the requirements of 10 CFR 70.24 and the methodology described in NRC Regulatory Guide (RG) 3.71, Rev. 1, Nuclear Criticality Safety Standards for Fuels and Material Facilities, (ML051940351). As stated in Section 4.7.12.4 of the LA, failure of the CAAS, either from the detector or from other electronic component failure, will initiate compensatory measures that may include evacuation of personnel, suspension of operations, deployment of auxiliary monitoring equipment, and/or immediate system repair. Compensatory measures are also established whenever the criticality alarm system is out of service, in storm-watch mode, or being tested or repaired. Periods when the CAAS is out of service are minimized to the extent practical. In the event of an inadvertent criticality, the licensee committed to ANSI/ANS-8.23, Nuclear Criticality Accident Emergency Planning and Response (ANS, 2007). Therefore, consistent with the NRC staffs evaluation documented in NRCs SER for the NFS License Renewal (ML102780085), the NRC staff determined that the licensees existing commitments related to CAAS coverage are sufficient for the modifications to CAAS coverage, continue to satisfy the requirements of 10 CFR 70.24, and provide reasonable assurance of adequate protection against all credible criticality-related hazards.

Emergency Planning and Response The LAR involves changes to the NFS EP to add two new emergency scenarios related to the release of (( )). However, the LAR does not involve any criticality-related changes to the NFS EP.

The NRC staff reviewed the proposed changes to the NFS EP and confirmed that the proposed changes do not impact criticality safety. The NRC staffs evaluation of the proposed changes to the NFS EP are documented in Section 2.8 of this SER.

Minimum Margin of Subcriticality The current LA contains two separate upper subcritical limits (USLs) of (( )) for uranium systems enriched to greater than 10 wt.% U and uranium systems enriched to less than or 235 equal to 10 wt.% 235U, respectively. The requested amendment does not involve any changes to the licensees validation methodology, MMS, or USLs. These elements were previously evaluated and found to be acceptable by NRC staff as documented in NRCs SER for the NFS License Renewal (ML102780085). Therefore, the NRC staffs review of the LAR focused on whether the requested changes and new activities are bounded by the licensees existing validation and whether the licensees MMS remains appropriate. Given that the requested activities involve uranium systems enriched to greater than 10 wt.% 235U, the review focused exclusively on the appropriateness of the MMS as it relates to the (( )) USL.

The NRC staff reviewed the licensees validation report, NFS document 54T-12-0038, Validation of Computer Codes for NCS for Uranium Systems with Enrichments up to 100 wt.%

(NFS, 2012) and determined that the licensees existing validation appropriately bounds the normal and credible abnormal conditions of the activities described in the LAR. The validated area of applicability includes enrichments up to 100 wt.% 235U and includes various chemical forms, including uranium oxides, solutions, metals, and any other forms that may be present during uranium purification and conversion activities. Therefore, consistent with the NRC staffs evaluation documented in NRCs SER for the NFS License Renewal (ML102780085), the NRC staff determined that the licensees MMS is acceptable. The NRC staff noted that these conclusions are limited to the (( )) USL and do not apply to the (( )) USL for uranium systems enriched to less than or equal to 10 wt.% 235U as it was not within the scope of the LAR.

2.5.3 Evaluation Findings The NRC staff reviewed the LAR, ISA, NFS EP, and current LA and determined that the licensees existing commitments related to the Double Contingency Principle, assurance of subcriticality under normal and credible abnormal conditions, CAAS coverage, and MMS (with respect to the (( )) USL for uranium systems enriched to greater than 10 wt.% 235U) are adequate to ensure compliance with all applicable criticality-related 10 CFR Part 70 requirements.

The NRC staff concluded that the licensees request provides reasonable assurance of subcriticality under normal and credible abnormal conditions, provides reasonable assurance of adequate protection against the risk of criticality accidents, and otherwise satisfies the applicable requirements of 10 CFR Part 70.

2.6 Chemical-Process Safety 2.6.1 Purpose of Review NFS submitted a LAR to authorize new U-metal services at the NFS site. NFS identified the new U-metal services as involving the following nodes:

  • Node 1: (( ));
  • Node 2: (( ));
  • Node 3: (( ));
  • Node 4: (( ));
  • Node 5: (( ));
  • Node 6: (( ));
  • Node 7: (( ));
  • Node 8: (( )); and
  • Node 9: (( )).

The LAR was limited to nodes 3, 4, and 5 because NFS states that the addition of these operations are the only actions that requires NRC approval according to the provisions of 10 CFR 72.72. In its response to RAIs on the safety analysis of the other nodes (i.e., nodes 1, 2, 6, 7, and 9), NFS stated that the information from the updated safety analysis for those other nodes not specifically part of the amendment would be incorporated into the U-metal ISA Summary for the NRCs operational readiness review (ML23041A235; RAI 28). NFS also stated in response to an NRC request for additional information (ML23041A235; RAIs 4 and 28) that it plans on conducting an internal readiness review after construction of the U-metal services are complete. In this response, NFS also stated that it expected that NRC would conduct its own readiness assessment of the facility. NFS stated that the safety basis and documentation for all nodes would be available for this NRC review. Accordingly, new condition S-9 is being added to materials license SNM-124 regarding the NRCs operational readiness review - see Section 4.0 of this SER.

The purpose of this chemical safety review was to determine if the commitments in the LAR for the production of U-metal in conjunction with information in the supporting documents provides reasonable assurance that NFS will adequately protect workers, the public, and the environment from chemical hazards that are under NRCs regulatory jurisdiction and meet the requirements for granting a license as specified in §§ 70.23, 70.64 and 70.65 as they relate to chemical safety.

2.6.2 NRC Staff Review and Analysis As documented in NRCs 2012 SER for the NFS license renewal (ML102780085), NFS has an existing chemical safety program that has been determined to meet the requirements of 10 CFR Part 70, Subpart H and which has been reviewed and inspected. This chemical safety program has continued to be reviewed and inspected by the NRC staff.

An important part of this chemical safety program is the ISA that includes consideration of chemical safety. The ISA methodology is documented in the NFS Site ISA Summary (NFS, 2021a) and was approved as part of the 2012 license renewal, NFS continues to use this methodology as noted in the LA.

The chemical safety review for the LAR focuses on two activities. The first is the review of the ISA results for the U-metal production operations as they relate to chemical hazards associated with nodes 3, 4, and 5 (the nodes addressed in the LAR). The second part is the identification of chemical safety related topics that the NRC staff confirms during the operational readiness review of the integrated U-metal operations prior to the introduction of SNM to the operation (new condition S-9 is being added to materials license SNM-124 - see Section 4.0 of this SER).

2.6.2.1 Review of HEU Metal Production ISA Results for Nodes 3, 4, and 5 The review of the ISA results related to chemical safety for nodes 3, 4, and 5 focuses on the results of the chemical hazard identification effort, the chemical accident sequences identification and analysis effort, and the chemical safety related IROFS that NFS identified.

Hazard Identification The chemical hazards related to nodes 3, 4, and 5 are discussed in Table 3-1 of the U-metal ISA Summary (ML23244A053 and ML23258A073).

The NRC staff reviewed the information describing the proposed NFS U-metal processing operations, process chemicals, equipment, and design features such as equipment layout and ventilation systems for the nodes of interest. The NRC staff noted features that contribute to chemical safety including limits on hazardous material inventory, engineered systems that contribute to control of hazardous/reactive chemical movement under routine and off-normal operations. The NRC staff reviewed ISA risk assessment documents for nodes 3, 4, and 5 (NFS, 2023a; NFS, 2023e; NFS, 2023b). The NRC staff also reviewed the technical literature for information on toxic/reactive hazards of the materials used in the three nodes and reviewed available information on hazards/operating experience of similar uranium metal production operations (e.g., Y-12 operations).

The NRC staff concluded that NFS has identified the important chemical hazards (toxic and reactive) for nodes 3, 4, and 5. The NRC staff agrees with the NFS assessment that most important toxic and reactive materials are (( )). Both materials are handled in limited quantities. (( )).

Accident Sequence Identification and Analysis The NRC staff also reviewed the chemical accident sequences identified by NFS for nodes 3, 4, and 5. The sequences are presented in Tables 4-1 and 4-2 of the U-metal ISA Summary (ML23244A053 and ML23258A073). The accident sequences are described in more detail in the ISA risk assessment reports for each of the nodes (NFS, 2023b; NFS, 2021b; NFS, 2023c).

These documents also identify proposed IROFS for each accident sequence. The accident descriptions for nodes 3, 4, and 5 are also listed in Table 5-1 of the Occupational/Environmental Chemical Accident Consequence Evaluation report (NFS, 2023a).

The accident sequences with the greatest chemical consequences for nodes 3, 4, and 5 are those involving the release of (( )), the release of (( )), and a spill of (( )). These higher consequence accidents are associated with the operations of node 3. The consequences for these accidents were estimated or assumed to be high for workers. The consequences to individuals outside the controlled area are low. The actual review of consequence estimates is discussed below.

This accident analysis also identified accident sequences associated for node 3 with (( ))

fire scenarios where the chemical occupational and environmental consequences were assigned to the high category in Table 3-2 of the NFS node 3 risk analysis (NFS, 2023b).

These sequences were reviewed as part of the fire safety review.

The NRC staff noted that the NFS response to NRCs RAI showed that NFS continued to update its ISA as the design progressed. Specifically, NFS identified new (( )) in nodes 2 and 9 (ML23041A235, RAI 4) and the changes to the appropriate ISA Summaries will be verified as part of the operation readiness review, as discussed in new condition S-9 that is being added to special nuclear material license SNM-124 - see Section 4.0 of this SER.

The NRC staff chemical safety review concluded there is reasonable assurance that the ISA is identifying the major chemical accident sequences that could present significant chemical hazards to workers or the public from operations proposed for nodes 3, 4, and 5 of the U-metal services.

Chemical Accident Consequence Analysis The NRC staff also reviewed the NFS analysis of chemical accident consequences for nodes 3, 4, and 5 documented in Occupational and Environmental Chemical Accident Consequence Evaluation for Building 301 HEU Metal, Nodes 3, 4, and 5, Revision 4 (NFS, 2023a).

NFS categorizes the consequences of most of the (( )) as high. The NRC staff considers the consequences calculations that are the basis for the categorization to be reasonable. The NRC staff considers the (( )) exposure scenario to be conservative. The (( ))

consequence calculations make conservative assumptions about the release quantity (i.e., the maximum inventory), the release rate (( )), the exposure time (( )). The assumption about (( )). The NRC staff notes that the technical information document supporting the acute exposure guidance level (AEGL) values for (( )) shows that human discomfort occurs for short exposures at levels below AEGL-2 values. This creates a natural sense and flee reaction that will reduce the likelihood of extended exposure that will produce more serious consequences.

The NRC staff finds that the determination of consequences for chemical accident sequences to be acceptable. As noted above, the NFS analysis often uses what are expected to be conservative assumptions about release quantities/rates and exposure times.

The NRC staff also notes that the major accidents identified for the (( )), are discussed in the revised NFS EP accompanying the amendment application.

Chemical Safety IROFS Chemical safety IROFS for nodes 3, 4, and 5 of the U-metal services are identified in Table 6-2 of the U-metal ISA Summary (ML23244A053 and ML23258A073). There are twenty-two IROFS.

Sixteen are engineered controls, four are enhanced administrative controls and two are administrative controls. Most controls are related to the preventing the contact of (( )) with plant workers.

The LAR identified IROFS that are important for preventing or limiting worker exposure to

(( )).

The NRC staff finds the conceptual identification of the chemical safety IROFS to be consistent with the ISA analysis results and reasonable, but the complete definition of the IROFS that are part of engineered control systems (( )) require definition to verify that these IROFS meet the performance requirements of 10 CFR 70.61 for acute chemical exposure consistent with the ISA analysis. The NRC staff notes that the NRCs operational readiness review will confirm that these IROFS are fully defined (e.g., completed boundary packages) and are based on as-built conditions (e.g., set points established), as discussed in new condition S-9 to materials license SNM-124 - see Section 4.0 of this SER.

Overall, the NRC staff review found that the NFS ISA analysis of nodes 3, 4, and 5 used methods that are consistent with the previously approved NFS ISA methodology. Given that new condition S-9 provides assurance that the IROFS will be fully defined and based on as-built conditions prior to the introduction of SNM, the NRC staff found that the results of the ISA are adequate.

2.6.2.2 Chemical Safety Considerations for NRC Operational Readiness Review NFSs planned approach for demonstrating safety of the proposed operations includes an independent NFS operational readiness review that verifies the integration of commitments made as part of the NRC approval of the changes to nodes 3, 4, and 5 with changes made for the other nodes that do not require NRC approval.

Consistent with new condition S-9 being added to materials license SNM-124 (see Section 4.0 of this SER), the NRC staff will perform its operational readiness review before authorizing NFS to introduce SNM into the U-metal services. Topics that are included in the license condition for the operational readiness review include, but are not limited to:

  • Verification that ISAs for all nodes of the U-metal services are updated to reflect final design, including those nodes that are not part of the LAR (i.e., nodes 1, 3, 6, 7, and 9).
  • Verification that the IROFS are fully defined (e.g., set points established).
  • Verification that personnel are trained on the hazards associated with the entirety of the U-metal services operations as stated in Section 2.7 of the U-metal ISA Summary and discussed more generally in Section 4.4 of the Site Wide ISA Summary. This could include the specific training and procedures that are identified as defense-in-depth measures for specific chemical hazards in Table 3-2 of the U-metal ISA Summary (ML23244A053 and ML23258A073).
  • Review of any startup plans for the various nodes, particularly those that involve toxic hazards or energetic reactions (( )).

2.6.3 Evaluation Findings The NRC staff has evaluated the application using the criteria listed in the Chapter 6 of NUREG-1520, Rev. 2. Based on the review of the LA, the NRC staff has concluded that NFS has adequately described and assessed accident consequences that could result from the handling, storage, or processing of licensed materials and that could have potentially significant chemical consequences and effects. The licensee has constructed a hazard analysis that identified and evaluated those chemical-process hazards and potential accidents and established safety controls to provide reasonable assurance of safe facility operation. To ensure that the performance requirements in 10 CFR Part 70 are met, NFS has provided reasonable assurance that controls are available and reliable when required to perform their safety functions. The NRC staff has determined that the commitments in the LA (ML21327A099 and ML23251A224) and the response to RAIs, combined with the supporting documents, provide reasonable assurance that NFS will provide adequate protection of the workers, the public and the environment from the chemical hazards that are associated with U-metal services operations under NRCs regulatory jurisdiction.

Proper implementation of the commitments made in the LA will be confirmed when the NRC staff conducts its operational readiness review, in accordance with new condition S-9 that is being added to materials license SNM-124 (see Section 4.0 of this SER), after NFS completes construction.

The NRC staff concludes that both the licensees plan for managing chemical-process safety and the chemical-process safety controls meet the requirements of 10 CFR Part 70. The NRC staff determined that the licensees submittals provide sufficient information in accordance with the requirements of 10 CFR 70.22 and 10 CFR 70.65 regarding potential chemical hazards, consequences, and required controls for the proposed U-metal processes. The NRC staff has determined that the licensee demonstrated compliance with the performance requirements of 10 CFR 70.61 for chemical safety related to postulated accident scenarios. The design that the licensee proposed also satisfies the requirements of 10 CFR 70.64(a)(5) and the defense-in-depth requirements of 10 CFR 70.64(b).

2.7 Fire Safety 2.7.1 Purpose of Review The purpose of this review is to determine with reasonable assurance that the facility provides adequate protection against fires and explosions for new U-metal services in nodes 3, 4, and 5 in Building 301 and node 9 in Building 389. The review also examines whether the licensee adequately considered the radiological and chemical consequences of fire, and identifies suitable safety controls to protect workers, the public, and the environment.

The NRC staff conducted this review to ensure that the NFS fire safety program meets the requirements required by 10 CFR Sections 70.22, Contents of applications, and 70.65, Additional content of applications. In addition, the fire safety must provide reasonable assurance of compliance with 10 CFR 70.61, Performance requirements, and 70.62, Safety program and integrated safety analysis.

The acceptance criteria that the NRC uses for reviews of fire safety are outlined in Sections 7.4.3.1 through 7.4.3.5 of NUREG-1520, Rev. 2.

2.7.2 NRC Staff Review and Analysis 2.7.2.1 Fire Safety Management Measures The licensee describes the fire safety management measures throughout the LAR. The management measures include fire safety organization; fire prevention; inspection, testing, and maintenance of fire protection systems; emergency response organization and training; and pre-fire plans. These management measures are applied to IROFS to provide reasonable assurance that they are available and reliable to perform their intended functions when needed.

The fire response training for Building 301 will be modified to account for the potential hazard and the fire brigade and emergency responders will have a practice drill once the training has been completed.

The NRC staff finds that fire safety management measures, previously approved by the NRC, are acceptable for this LAR (with new designs/procedures in nodes 3, 4, and 5 added to the U-metal services) and meets the acceptance criteria for fire safety management measures as outlined in Section 7.4.3.1 of NUREG-1520, Rev. 2. The NRC staff confirmed that information provided in the LAR demonstrates compliance with 10 CFR 70.65(b)(4).

2.7.2.2 Fire Hazard Analysis The licensee performed a fire hazard analysis (FHA) that is documented in the report, FHA Uranium Purification and Conversion Services (U-metal) Project (NFS, 2023f). The FHA evaluated fire impacts for the U-metal process in Building 301 and used codes and standards from NFPA, IBC (ICC, 2012a), the International Fire Code (ICC, 2012b), and industry practices.

The licensee is committed to maintain an FHA that meets the guidance in NFPA 801 (NFPA 801, 2014).

As detailed in Section 4.1 of the FHA, two specific fire sizes were selected for the FHA in various operating areas: the (( )) fire represents a normal number of combustibles from daily processing and/or routine maintenance and the (( )) fire represents many combustibles - equivalent to a pallet full of supplies being delivered from the warehouse to the material access area.

The NRC staff determined that (1) the FHA provides a description of the fire areas, detection systems, fire hazards, and other related features, including interlocked valves, and (2) the FHA determines the likely locations (e.g., (( ))) for the fires to occur based on parameters such as process operations, room size, material construction throughout the U-metal process.

Nodes 3, 4 and 5 in U-metal Process Building 301 Section 4.3 of the FHA notes that with flammable gas (( )) used in node 3, the FHA was performed for processing areas in nodes 3: both (( )) and (( )) transient fires are considered for the (( )) which is not separated from nodes 1 and 2; and only a (( )).

Section 4.3 of the FHA notes that there is no water allowed and no water-filled pipes existed in the processing areas in node 4 to contact with (( )). Therefore, there is no credit for a

(( )) transient fire and the FHA was performed only for node 4 with a (( )) transient fire representing (( )). Section 4.3 also notes that the heat, generated (( )) in node 5, is contained within the (( )) and is not considered to be a significant fire source. Therefore, a

(( )) transient fire is not credited, and an FHA was performed for node 5 with a (( ))

transient fire representing two bags of trash.

The NRC staff finds that the FHA accounts for peak heat release rate, bounding convective heat release rate, maximum flame height, combustion heat, mass of combustibles, radiant heat effect and fire temperature effects; and determined the likely locations for the fires based on parameters of process operations, room size, material construction, etc. The NRC staff determined that the application provides an adequate level of evaluations on fire safety and meets the acceptance criteria as outlined in Section 7.4.3.2 of the NUREG-1520, Rev. 2.

Node 9 in Utility Building 389 Section 4.3 of the FHA notes that Utility Building 389 (node 9) contains normal industrial hazards and is fully sprinkled. Therefore, any fire of significance will initiate the sprinkler system to control and suppress the fire with a minimum amount of fire damage in the zone of influence.

The licensee performed analyses for unmitigated (( )) transient fire scenarios.

The NRC staff determined that analysis of only these transient fire scenarios is acceptable because Building 389 contains low concentrations of licensed material in the form of (( ))

which do not contribute to the fire loading in the building.

2.7.2.3 Facility Design U-metal Production Facility (Building 301)

Building 301 is the main process area for the U-metal services. The building is a (( )), in accordance with the IBC (ICC, 2012a) and a (( )) of NFPA 220 (NFPA 220, 2018) and is separated from an adjacent building by (( )) and the main processing space in the building will be divided into (( )). The building, with the current egress doors and egress routes sufficient for the U-metal process, complies with NFPA 801 (NFPA 801, 2014) requirements for noncombustible construction. The licensee provided information on the new/existing fire walls and the egress routes.

The U-metal ISA Summary (ML23244A053 and ML23258A073) states that the new systems/processes performed in the building, consists of the (( )) (node 3), (( )) (node 4), and the (( )) (node 5). Section 2.0 of the FHA notes:

  • Node 3 is not separated from nodes 1 or 2, but is separated from 4, 5, 6, and 7 by

(( )).

  • Node 4 is separated from nodes 1, 2, and 3 by (( )), but is not separated from nodes 5, 6, and part of node 7. It is separated from the (( )) node 7 by (( )).
  • Node 5 is separated from nodes 1, 2, and 3 by (( )). Node 5 is separated from the

(( )) node 7 by (( )).

The NRC staff reviewed the major building structure and configuration changes that are important to fire safety and determined that the U-metal process design has incorporated consideration for minimizing fire hazards. The NRC staff reviewed the egress routes and the fire rated walls marked in Figure 14-1 of ARM-23-003 (ML23040A078) for nodes 3, 4, and 5 and has determined that Building 301, with new designs/processes in nodes 3, 4, and 5 added for the U-metal services, meets the acceptance criteria as outlined in Section 7.4.3.3 of NUREG-1520, Rev. 2, and the associated NFPA Standards.

The NRC staff determined that the licensee has described the fire safety considerations used in the designs of Building 301. The facility construction is adequately designed to prevent the spread of fire in the building which has the fire rated barriers around high-risk areas. Therefore, the facility design of Building 301 is in accordance with 10 CFR 70.64(a)(3) and 70.65(b)(2).

Utility Facility (Building 389)

Building 389 is (( )), in accordance with the IBC (ICC, 2012a) and NFPA 220 (NFPA 220, 2018). The building, offset from Building 301 by (( )), is arranged in accordance with the life safety requirements of the IBC (ICC, 2012a) and NFPA 101 (NFPA 101, 2018). The building is noncombustible with (( )). The building is fully sprinklered except an electrical room, which is separated from the remainder of the facility by (( )). Electrical systems are designed and installed in accordance with NFPA 70 (NFPA 70, 2020). Additionally, the building is provided with lightning protection in accordance with NFPA 780 (NFPA 780, 2020).

The NRC staff accepts that the licensee has described the fire safety considerations used in the designs of Building 389. The facility construction is adequately designed to prevent the spread of fire in the building. The NRC staff finds that the application meets the acceptance criteria as outlined in Section 7.4.3.3 of the NUREG-1520, Rev. 2 and the applicable regulations.

Therefore, the facility design of Building 389 is in accordance with 10 CFR 70.64(a)(3) and 70.65(b)(2).

2.7.2.4 Process Fire Safety Fires in Nodes 3, 4, and 5 (Building 301 for U-metal Process)

The licensee performed the FHA in nodes 3, 4, and 5 in which node 3 contains the main processing areas of (( )). The licensee specified two fire sizes located in the main processing areas: the (( )) fire represents a typical amount of combustibles from daily processing and/or routine maintenance and the (( )) fire represents a large amount of combustibles delivered from warehouse to material access area.

The FHA shows:

  • The (( )) fire would not be expected to cause any structural damage in (( )) and would not be expected to migrate to other areas and cause damage to any equipment in other areas unless there was a continuity of combustibles, which is not anticipated within the U-metal process.
  • The (( )) fire may cause some roof damage due to flame impingement of the

(( )) but would not be expected to migrate to other areas and cause damage to any equipment in other areas unless there was a continuity of combustibles, which is not anticipated within the U-metal process.

Fires at Node 9 (Utility Building 389)

The licensee also performed safety analysis on (( )) and (( )) transient fire scenarios in node 9 processed in Building 389 (Utility Building). The FHA shows:

  • Both (( )) transient fires would not be expected to cause any structural damage, but the (( )) fire may cause some roof damage due to flame impingement (( )).
  • The (( )) fires would not be expected to migrate to other areas and cause damage to any equipment in other areas unless there was a continuity of combustibles, which is not anticipated in Building 389.
  • The (( )) fires would not be expected to migrate to other areas and cause damage to any equipment in other areas unless there was a continuity of combustibles, which is not anticipated in Building 389.

The NRC staff determined that the licensee has identified the potential fire hazards in the operations in nodes 3, 4. and 5 in Building 301 and node 9 in Building 389 and controlled these fire hazards through FHA, fire safety program, and personnel training, consistent with the acceptance criteria as outlined in Section 7.4.3.4 in NUREG-1520, Rev. 2.

IROFS The licensee identified and evaluated the initiating event, enabling event, fire safety IROFS, likelihood index, likelihood category, consequence category, and risk index, as shown in Tables 4-9 and 6-4 of the U-metal ISA Summary. The licensee identified the fire risk events of (( )).

The licensee proposed several IROFS to mitigate the consequences of the events, as explained in the NFS response to the NRC staffs RAIs (ML23041A235), to meet the performance requirements in 10 CFR 70.61.

The NRC staff reviewed licensees evaluation on cause, initiating event, enabling event (EE),

IROFS, effectiveness of protection index, likelihood index/category, consequence category, risk index and defense-in-depth controls presented in Table 5-2 and determined that the licensee has identified and evaluated the mitigating IROFS needed to meet the performance requirements of 10 CFR 70.61. The NRC staff determined that the reliability of the IROFS and the corresponding analyses are adequately detailed and described, consistent with the acceptance criteria in Section 7.4.3.4.2 of NUREG-1520, Rev. 2. Therefore, the NRC staff finds that the fire safety IROFS, as shown in Tables 5-2 and 6-4 provide reasonable assurance to prevent or mitigate fire-induced consequences in accordance with 10 CFR 70.65(b)(6).

2.7.2.5 Fire Protection and Emergency Response Building 301 HEU Metal Production Facility As stated in Section 2.9 of the U-metal ISA Summary, fire at Building 301 is prevented through noncombustible building design, fire rated barriers, combustible and hot work administrative controls, ignition source controls, and compliance of the applicable NFPA code and standards.

Per information provided in the ISA Summary and the FHA:

  • Fire barriers, fire doors, and fire dampers with (( )) rating per UL555, Standard for Safety for Fire Dampers (UL, 2006) will be provided to mitigate fire spread for U-metal process as shown in the FHA. The Main Processing Area is separated from the adjacent building by a (( )) fire barrier wall, in accordance with NFPA 80 (NFPA 80, 2019).

Penetration seals are used in fire barriers to meet the requirements of ASTM E814, Standard Test Method for Fire Tests of Penetration Firestop Systems (ASTM, 2017).

Fire barriers and fire doors are inspected and tested annually.

  • Use of water for fire suppression will be restricted for criticality concerns/controls.

(( )) The hydrants that would be used are located outside the building.

  • Fire alarm system has been designed as required by NFPA 72 (NFPA 72, 2019) and NFPA 101 (NFPA 101, 2018). Fire/smoke detectors, as shown in Figure 14-2 of Enclosure D to the NFS response to RAIs (ML23040A078), are utilized throughout the building, (( )), in accordance with NFPA 72 (NFPA 72, 2019). Manual pull stations are provided at all exits in accordance with NFPA 72 (NFPA 72, 2019).
  • Portable fire extinguishers will be equipped in the U-metal process areas throughout the building in accordance with NFPA 10 (NFPA 10, 2018). NFS employees have been trained on use and inspection of the fire extinguisher.
  • U-metal process, including nodes 3, 4, and 5, will fall under the NFS Hot Work Program and procedures as established and consistent with NFPA 51B (NFPA 51B, 2019).
  • Automatic valves that isolate oxidizing liquids and flammable/toxic gases are interlocked with the fire detection system to isolate the feed source in the event of activation, and spring return valves are located on reagent columns for defense-in-depth.
  • All chemicals are hand-carried into the area by the operator and are packaged at the end of operations, and therefore there is no isolation required in response to a fire alarm.

The NRC staff finds that the application meets the acceptance criteria as outlined in Section 7.4.3.5 of the NUREG-1520, Rev. 2. The licensee has described the fire protection and detection systems in Building 301. The risk of fires starting, or spreading is minimized through using fire barriers, fire dampers, fire alarms/detectors, automatic interlocked valves, and fire suppression equipment to meet the criteria as specified in NFPA 801 (NFPA 801, 2014).

Building 389 Utility Building The licensee documented, in the application and FHA that Building 389 is designed per the IBC (ICC, 2012a) with the following fire protection features:

  • Fire alarm system is comprised of smoke detection, manual pull stations, water flow alarms, and audible and visual notification in accordance with NFPA 72 (NFPA 72, 2019). Smoke detection systems or manual pull stations are connected to the building alarms for notification of operators and the NFS plant-wide fire alarm speaker system for notification of the NFS Plant Fire Brigade.
  • The building is fully sprinklered and complies with NFPA 13 (NFPA 13, 2019). All interior finishes are Class A finishes in accordance with NFPA 801 (NFPA 801, 2014). There is a (( )) fire barrier around the electrical room; all other walls are (( )) and there are no exterior windows on the building structure.
  • The (( )) has a sprinkler deluge system, which is activated by (( )). Access to the (( )) is controlled and restricted to authorized personnel.

The NRC staff finds that the application meets the acceptance criteria discussed in Section 7.4.3.5 of the NUREG-1520, Rev. 2. The licensee has described the fire protection and detection systems in Building 389. The risk of fires starting, or spreading is minimized through using fire sprinkler system, detectors, fire barriers and (( )) in the building meeting the criteria as specified in NFPA 801 (NFPA 801, 2014) for reasonable assurance in fire protection and emergency response.

Emergency Response As stated in the NFS Site ISA Summary (NFS, 2021a), NFS maintains a plant emergency response team (ERT), made up of employees trained in firefighting techniques and first aid procedures, in accordance with NFPA 600 (NFPA 600, 2020). NFS has cooperated with the offsite fire brigades and medical agencies for response to plant fires. The licensee stated, in response to the RAI, that (1) fire response training for Building 301 will have to be modified to account for the additional potential hazard, (2) fire brigade and emergency responders will have practice drills as part of routine training and (3) training for outside agencies will include initial familiarization and an annual refresher and the outside agencies will be invited to participate in the practice drill(s).

Section 2.9.5 of the ISA Summary notes that NFS maintains a pre-fire emergency response plan for each process areas of the U-metal services. The pre-fire plans have been developed for Buildings 301 and 389 to include specific hazards to emergency responders, search and rescue considerations, utility shut offs/start-ups, fire loading concerns, and unique firefighting strategy and tactics. The pre-fire plans conform to the guidance provided in NFPA 801 (NFPA 801, 2014).

The NRC staff finds that the licensee commits to maintain the onsite ERT and a pre-fire emergency response plan for each process area of the U-metal services. The licensee will continue their cooperation and training with the offsite responders, which meets the acceptance criteria as outlined in Section 7.4.3.5 of NUREG-1520, Rev. 2.

2.7.3 Evaluation Findings The licensee has established a fire protection program meeting the acceptance criteria in Chapter 7 of the NUREG-1520, Rev. 2. The program includes an authority having jurisdiction responsible for the fire protection program and resolving any NFPA code issues and a safety discipline director responsible for day-to-day program implementation. Fire prevention; inspection, testing, and maintenance of fire protection systems; and the qualification, drills, and training of facility personnel are in accordance with applicable NFPA codes and standards.

The licensee has conducted an FHA in accordance with NFPA 801 (NFPA 801, 2014). The FHA identified credible fire scenarios that bound the fire risk in the U-metal services. The ISA used these scenarios and identified appropriate IROFS for the U-metal services. A memorandum of understanding with the local fire department documents the required assistance and the annual exercises. Procedures are in place to allow the fire department efficient access to process areas during fire emergencies. Worker egress is designed and maintained in accordance with NFPA 101 (NFPA 101, 2018).

The licensee has demonstrated that it incorporated appropriate fire safety considerations and fire protection systems in the design of the Building 301 for the U-metal services and in the design of the Building 389 for containing licensed material, in accordance with 10 CFR 70.64(a)(3).

Based on this review, the NRC staff determined that the licensees submittals provide sufficient information in accordance with the requirements of 10 CFR 70.22 and 10 CFR 70.65 regarding potential fire hazards, consequences, and required controls for the proposed U-metal processes. The NRC staff has determined that the licensee demonstrated compliance with the performance requirements of 10 CFR 70.61 for fire protection related to postulated accident scenarios. The design that the licensee proposed also satisfies the requirements of 10 CFR 70.64(a)(3) and the defense-in-depth requirements of 10 CFR 70.64(b).

2.8 Emergency Management 2.8.1 Purpose of Review The purpose of the NRC staffs review and evaluation is to determine whether the changes proposed in the NFS EP provided with the U-metal LAR continue to comply with the emergency planning requirements in 10 CFR Part 70. The proposed changes to the EP were included in the scope of the LAR to address proposed changes to the NFS EP for the U-metal services addition to the NFS site.

NFS requests an amendment to their materials license SNM-124 for NRC approval to authorize the U-metal services processes and operation at the NFS nuclear fuel fabrication and uranium processing facility in Erwin, Tennessee. The operation of the U-metal services consists of new processes at the NFS facility with new accident sequences introduced by the U-metal services design. The applications proposed U-metal services changes to the NFS EP include and address the two (2) new U-metal services process emergency scenarios, proposed modifications to the Protective Action Recommendations (PARs) and other related changes such as updates to process descriptions and accident mitigations.

This section focuses on the NRC staffs review and evaluation of the licensees U-metal services proposed NFS EP revisions and changes.

2.8.2 Regulatory Requirements Pursuant to 10 CFR 70.22(i)(1)(ii), an EP must address the response to radiological hazards of an accidental release of SNM and any chemical hazards directly related to the release. Such plans must include the information specified in 10 CFR 70.22(i)(3). The NRC staffs review focused on determining whether the LARs proposed changes to the NFS EP for the U-metal services provide information that demonstrates the NFS EPs continued compliance with the criteria of 10 CFR 70.22(i)(1)(ii).

Pursuant to 10 CFR 70.64(a)(6), the design must also provide for emergency capability to maintain control of: licensed material and hazardous chemicals produced from licensed material, the evacuation of onsite personnel, and onsite emergency facilities and services that facilitate the use of available offsite services.

2.8.3 Regulatory Guidance The guidance applicable to the NRCs review of the control of licensed material, the evacuation of personnel, and the availability of emergency facilities, and evaluation of maximum dose to a member of the offsite public is contained in Chapter 8 of NUREG-1520, Rev. 2.

2.8.4 NRC Staff Review and Analysis The LAR references the current NFS EP, Rev. 26. The changes to the EP are contained in of the LAR. The following documents the NRC staffs review and evaluation of the changes proposed to the EP against the applicable regulations and the acceptance criteria contained in NUREG-1520, Rev. 2, Section 8.4.3, Regulatory Acceptance Criteria.

2.8.4.1 Facility Description The proposed NFS EP Section 1.2, Site and Facility Description, contains the descriptions of the facilities used for the U-metal services. This section also describes various support buildings and the potential hazards in these buildings.

The description of the changes to the NFS EP for the U-metal processes address the acceptance criteria identified in Section 8.4.3.1.1, Facility Description, of NUREG-1520, Rev. 2. Therefore, the NRC staff finds the proposed NFS EP applicable site and facility changes to be acceptable.

2.8.4.2 Types of Accidents The proposed changes to the NFS EP add two new accident types to Section 2.0, Types of Accidents,

  • (( )), and
  • (( )).

The (( )). The major concern of a postulated release (( )) is the chemical toxicity associated with each hazardous chemical. The NRC staff reviewed the worst-case plume descriptions which were modeled without mitigation controls for a release from a (( )) and resulted in a concentration at the site boundary above the emergency response planning guidelines (ERPG) which requires sheltering in place for both onsite and offsite immediate response actions. The plume duration is short, and the release characteristics and plume location are highly dependent upon weather conditions. In addition, when these same postulated releases were evaluated with engineered mitigation controls (i.e., IROFS), the release does not exceed the ERPG levels at the site boundary.

The NRC staff reviewed the postulated radioactive spill scenarios listed in Table 2-3, Postulated Accident Summary for Liquid Radiological Release. The postulated worst-case dose at the NFS site boundary demonstrates that the site boundary dose received from the largest potential spill to the environment of the new U-metal services process is bounded by the existing events.

The NRC staffs evaluation of the proposed updates to the NFS EP of the new types of accidents introduced from the addition of the U-metal services processes at the NFS site finds that the proposed NFS EP changes to describe the new types of accidents address the acceptance criteria contained in Section 8.4.3.1.3, Types of Accidents, of NUREG-1520, Rev. 2. Therefore, the NRC staff finds the proposed changes to the NFS EP to be acceptable.

2.8.4.3 Classification of Accidents The NRC staffs review of the proposed changes to Section 5, Emergency Response Measures, of the NFS EP did not identify changes to the classification system or emergency action levels due to the new U-metal services design and processes.

2.8.4.4 Detection of Accidents As shown in Table 4-9, Fire Safety Risk Assessment, of the U-metal ISA Summary (ML23244A053 and ML23258A073), (( )). The IROFS mitigation actuation will provide local notification via an audible alarm and stack light.

The proposed changes to NFS EP Section 2.2.5, (( )). In addition, gas monitors and detection will be available for personnel monitoring, area monitoring, and environmental assessment following the release of a toxic gas.

The NRC staffs review found that the proposed descriptions of the detection of U-metal services accidents in the NFS EP address the acceptance criteria contained in Section 8.4.3.1.5, Detection of Accidents, of NUREG-1520, Rev. 2. Thus, the NRC staff finds the methods described for detecting U-metal services process accidents in the proposed NFS EP to be acceptable.

2.8.4.5 Mitigation of Consequences The proposed changes in Section 5.3, Mitigating Actions, of the NFS EP state that in the event of (( )), the system would be shut down.

The NRC staff reviewed Table 4-9 of the U-metal ISA summary (ML23244A053 and ML23258A073) and the proposed changes to the Section 5.3 of the NFS EP and conclude that the descriptions for mitigation of consequences for the U-metal services processes address the acceptance criteria contained in Section 8.4.3.1.6, Mitigation of Consequences, of NUREG-1520, Rev. 2. Thus, the NRC staff finds the methods described for mitigation of U-metal services consequences to workers onsite and to the public offsite in the proposed NFS EP to be acceptable. This includes providing for the emergency capability to maintain control of licensed material and hazardous chemicals produced from licensed material, as required by 10 CFR 70.64(a)(6)(i).

2.8.4.6 Assessment of Releases The proposed Section 5.2, Assessment Actions, of the NF EP did not identify changes to the assessment methods and procedures for the release of radioactive material or hazardous chemicals related to the U-metal services. The existing assessment methods and procedures have been previously determined to be acceptable and would continue to be acceptable given the addition of the U-metal services.

2.8.4.7 Responsibilities The proposed Section 5.0, Emergency Response Measures, of the NFS EP did not identify proposed NFS changes to the emergency response organization and administration and control of emergency preparedness activities. The existing emergency response organization and administration have been previously determined to be acceptable and would continue to be acceptable given the addition of the U-metal services. This includes providing for the emergency capability to maintain control of onsite emergency facilities and services that facilitate the use of available offsite services, as required by 10 CFR 70.64(a)(6)(iii).

2.8.4.8 Notification, Coordination, and Information to Be Communicated The proposed Section 5.4, Protective Actions, of the NFS EP states that (( )). In addition, for the event of a release to the offsite environment, initial PARs have been developed for the sheltering of offsite personnel. The applicable PAR will be transmitted to offsite agencies based on the assessment of the accident situation and the projected offsite radiation dose exposure.

Table 5-2, Initial Offsite Protective Action Recommendations, lists the initial PARs and recommended protective actions.

The NRC staffs review of the proposed NFS EP changes did not identify additional proposed changes regarding notification and coordination or information to be communicated during an emergency. Based on the evaluation above, the NRC staff concludes that the proposed U-metal services descriptions in the NFS EP for emergency notification procedures, coordination, and description of planned PARs address the applicable acceptance criteria in Section 8.4.3.1.9, Notification and Coordination and Section 8.4.3.1.10, Information to be Communicated, of NUREG-1520, Rev. 2. Thus, the NRC staff finds the proposed EP notification, coordination, and transmitted PAR information to onsite workers, offsite response organizations, and to the public in the proposed NFS EP for the U-metal services to be acceptable.

2.8.4.9 Training, Exercises and Drills The proposed changes to the NFS EP did not identify changes to training, exercise, or drills.

However, the U-metal ISA Summary (ML23244A053 and ML23258A073), Section 2.7, "Industrial Safety Systems," states that personnel will undergo additional training associated with hazards associated with the U-metal services process, (( )). In addition, the licensees RAI response (ML23041A235 and ML23040A067) to the NRC staffs RAI 17 states that additional training will include shelter in place training for all employees in the event there were to be (( )). In addition to training provided to employees, NFS states that it is also working closely with local offsite agencies (fire/medical response) to prepare them for the additional chemical being brought to the facility. The NRC staffs review of the proposed changes to the NFS EP does not identify necessary updates or changes to emergency response training or the conduct of exercises and drills.

Based on its review, the NRC staff concludes that the NFS LAR applications descriptions of U-metal services specific training, exercises and drills address the applicable acceptance criteria in Section 8.4.3.1.11, Training, and Section 8.4.3.1.13, Exercises and Drills, of NUREG-1520, Rev. 2. Thus, the NRC staff finds the descriptions of specific emergency planning training, exercises, and drills for the U-metal services to be acceptable. This includes providing for the emergency capability to maintain control of the evacuation of onsite personnel, as required by 10 CFR 70.64(a)(6)(ii).

2.8.4.10 Additional NRC Staff Considerations There were no proposed changes to the NFS EP regarding onsite and offsite emergency facilities, recovery and plant restoration, or the administrative procedures for the emergency program. As part of the NRCs 2012 SER for the NFS license renewal (ML102780085), the NRC staff reviewed those portions of the NFS EP according to the applicable acceptance criteria in NUREG-1520, Rev. 2, Section 8.4.3.1.2, Onsite and Offsite Emergency Facilities, Section 8.4.3.1.12, Safe Shutdown (Recovery and Facility Restoration), or Section 8.4.3.1.14, Responsibilities for Developing and Maintaining the Emergency Program and Its Procedures.

The NRC staff continues to find this information acceptable for the new U-metal services at the NFS site.

Section 4, Regulatory Evaluation, of the LA (ML21327A099 and ML23251A224) states that no changes were identified for the specific conditions listed in materials license SNM-124 and that all the license chapters were reviewed and, except for Chapter 1, do not require modification to account for U-metal services operations. Condition S-6 of materials license SNM-124, which documents the current version of the NFS EP, is applicable to the U-metal services. New condition S-9 is being added to materials license SNM-124 (see Section 4.0 of this SER) and states, in part, that the operational readiness review will verify whether the NFS EP is updated and appropriately documented, in accordance with the applicable provisions of 10 CFR 70.32, to reflect the as-built conditions and any changes needed for U-metal services.

2.8.5 Evaluation Findings The NRC staff has evaluated the application and its supplements. Based on its review of the proposed changes to the NFS EP for the U-metal services, as documented above, the NRC staff finds that the application meets the applicable EP requirements contained in 10 CFR 70.22(i), 10 CFR 70.32(i), and 10 CFR 70.64(a)(6); and therefore, the proposed changes to the NFS EP for the U-metal services are acceptable.

2.9 Environmental Protection 2.9.1 Purpose of Review The NRC staff conducted this review to determine whether the environmental protection measures proposed by NFS are adequate to protect public health and safety and the environment, as required by 10 CFR Parts 20 and 70.

The regulations in 10 CFR Parts 20 and 70 provide requirements for environmental controls, monitoring, and reporting for radiation protection. NFS must satisfy the following regulatory requirements regarding environmental protection as applicable:

  • 10 CFR Part 20, Subpart B, Radiation Protection Programs, Subpart D, Radiation Dose Limits for Individual Members of the Public, Subpart E, Radiological Criteria for License Termination, and Subpart F, Surveys and Monitoring, all of which specify the effluent control and treatment measures necessary to meet the dose limits and dose constraints for members of the public, where Subpart F also states the survey requirements. Subpart K, Waste Disposal, specifies the waste disposal requirements; Subpart L, Records, specifies the records requirements; and Subpart M, Reports, specifies the reporting requirements.
  • 10 CFR 70.21(f) requires that an application for an activity which the Commission has determined requires an environmental impact statement, listed in 10 CFR 51.20, must be accompanied by an Environmental Report required under Subpart A of Part 51. The application must be filed at least 9 months prior to commencement of construction, as defined in 10 CFR 70.4.
  • 10 CFR Part 70 requires the licensee to demonstrate that proposed facilities and equipment, including measuring and monitoring instruments and devices for the disposal of radioactive effluents and wastes, are adequate to protect the environment and public health and safety, as specified in 10 CFR 70.22(a)(7).
  • 10 CFR 70.59, Effluent Monitoring Reporting Requirements, outlines the reporting requirements for radiological-effluent monitoring for a 10 CFR Part 70 licensee.

2.9.2 NRC Staff Review and Analysis In performing this review, the NRC staff used the guidance in Chapter 9 of NUREG-1520, Rev. 2. The information to support this review was obtained from the 2009 NFS license renewal application (ML091900061 and ML11258A051), NRCs 2012 SER for the NFS license renewal (ML102780085), the U-metal LAR, the NFS Supplemental Environmental Report (ML21327A101 and ML23041A236), and the NFS response to RAIs (ML23041A235). The NRC staff focused its environmental safety review on the portions of the safety program that NFS proposes to control and assess any potential radioactive and nonradioactive releases (i.e., gaseous, liquid, and solid) to the environment from the U-metal services. Therefore, the NRC staff reviewed the referenced documents from a safety perspective to assess the effluent control portion of the radiation protection program and the effluent and environmental monitoring practices.

2.9.2.1 Environmental Report The NRC staff reviewed and evaluated the environmental report (ER), responses to RAIs, and LAR information submitted by NFS. In support of the LAR, the licensee submitted the Supplemental ER associated with updates and changes since the 2009 license renewal ER.

The Environmental Impact of Proposed Action is addressed in Section 4 of the Supplemental ER Including the public and occupational health impacts in Section 4.12. The annual average environmental surveillance data for 2009-2020 provided in the tables in Section 4.12 of the Supplemental ER show no impacts above the allowable criteria (10 CFR 20) to the air, stream sediment, soil, vegetation, or surface waters (ML21327A101 and ML23041A236).

Supplemental ER Table 24 presents the radiation exposure to members of public for the period 2008 through 2020. The estimated dose to maximally exposed individual is very low and represents a small fraction of the allowable exposure limit of 25 mrem/yr.

In Section 2.0 of the Supplemental ER, a detailed analysis evaluated eight potential accident scenarios. While NFS has classified these scenarios as potential, the probability of any of them to be occurring is low, due to safety factors incorporated into the design for all radiological material related process equipment and systems. The level of protection against significant accidents is substantiated by a review of past incidents. The Supplemental ER Section 2.0 Table 2 lists the environmental releases which triggered an offsite notification during recent facility history covering the period June 1997 through 2021. A review of these events indicates none of the events significantly threatened the safety of members of the public.

In addition to the safety review documented in this section of the SER (i.e., Section 2.9), the NRC staff prepared an environmental assessment (EA) for the licensees NFS LAR, following NRC regulations in 10 CFR Part 51 which implement the National Environmental Policy Act of 1969, as amended (42 U.S.C. 10 CFR 4321), and NRC staff guidance in NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs, (ML032450279).

2.9.2.2 Effluent and Environmental Controls and Monitoring The NFS LAR application proposed no significant changes to the environmental protection program. The NRC staff reviewed qualifications and training that the licensee has established for plant personnel who are associated with environmental protection. NFS has established in Chapter 9 their LAR, Revised Chapter 9 for Renewal of License SNM-124, (ML091900061 and ML11258A051), the minimum qualifications for the manager of the environmental protection function at the facility and for the supporting environmental protection analyst.

The NRC staff found these requirements acceptable.

2.9.2.2.1 Radiation Safety In accordance with 10 CFR 20.1101, NFS implemented a radiation protection program and NRC staff previously evaluated it in the NRCs 2012 SER for the NFS license renewal (ML102780085). Chapter 4 of the LA discusses the radiation protection program for workers.

The environmental review of the radiation protection program focused on the methods by the licensee to maintain public doses ALARA in accordance with 10 CFR 20.1101.

The NFS effluent control program is designed to keep airborne and liquid effluent releases ALARA and protect public health and safety and the environment. The program includes routine monitoring and measurement, comparison of results to action levels set by NFS procedural guidance and reporting of results to NFS management and the NRC, as appropriate. Section 2.9.2.2.2 of this SER discusses the action levels for liquid and airborne effluents.

NFS has committed to review its radiation protection program annually. Additionally, an NFS-generated ALARA report is provided to NFS management quarterly for use in a review of effluent release data, among other items. NFS also maintains performance metrics and makes reports periodically to its internal safety review committee to (1) determine if there are any developing upward trends in effluent releases, (2) determine if effluents might be lowered under the ALARA concept, (3) determine if effluent control equipment at the facility is being properly used, maintained, and inspected, and (4) review the radiation protection program, effluent control and monitoring data.

The environmental review of the radiation protection program also focuses on the NFS waste minimization practices. NFS uses waste minimization techniques to eliminate and minimize the generation of waste during planning, design, and operation of plant activities. Examples of techniques currently used at NFS include, (1) recycling or reuse of obsolete computer equipment and electronic components through donations to schools and disposal through licensed recycling facilities; (2) offsite shipment of out-of-specification diesel fuel for fuel blending and recycling, (3) shipment of nonhazardous oil for recycling, (4) offsite thermal destruction of mixed PCB waste burned for energy recovery, (5) reuse of isopropyl alcohol to the extent technically allowed, and (6) offsite shipment of universal waste (e.g., mercury lamps, ballasts, and batteries) for recycling. A hazardous and mixed waste reduction plan, which is updated annually, describes the waste minimization techniques used at the NFS facility.

Chapter 4 of the NRCs 2012 SER for the NFS license renewal (ML102780085) discusses the NFS radiation protection program addressing occupational doses. No changes are identified for the specific operations associated with U-metal process. Therefore, no modifications for the existing radiation protection and environmental protection programs are presented in the NFS LAR.

2.9.2.2.2 Effluent and Environmental Monitoring NFS has developed programs for effluent and environmental monitoring. The program objectives include (1) ensuring public health and safety, (2) complying with NRC regulatory requirements, and (3) identifying mitigative measures as appropriate. The discussion below describes liquid and air effluent monitoring and controls to minimize process- and facility-related effluents. Environmental monitoring is described also.

NFS has established action levels for airborne and liquid effluents. If an action level for these effluents is exceeded, the NFS environmental protection manager and the responsible NFS process engineering control personnel would be notified, NFS would investigate to identify the cause of the exceedance, and NFS would initiate corrective actions to reduce observed levels and to minimize the likelihood of a reoccurrence.

2.9.2.2.2.1 Liquid Effluent Monitoring NFS has established action levels for liquid effluents before discharge. These action levels, set in NFS procedural guidance, are at or below the concentrations listed in 10 CFR Part 20, Appendix B, Table 2, Column 2. Batch concentrations meeting the action levels are released without further approval by the NFS environmental protection manager; however, waste solutions with alpha or beta concentrations exceeding one of the action levels are discharged only with approval of the NFS environmental protection manager.

Sanitary sewer wastes are discharged through two pathways (one for the BLEU complex and one for the remainder of the NFS plant site) into the City of Erwin publicly owned treatment works. NFS samples both sanitary waste streams continuously and analyzes them daily for gross alpha and gross beta.

To demonstrate compliance with solubility requirements for releases to the sanitary sewer specified in 10 CFR 20.2003, NFS compares the results of the insoluble radioactivity measurements performed on the sanitary sewer samples to the amount of insoluble radioactivity present in similarly processed background samples. If insoluble radioactive materials are present at concentrations statistically greater than the concentrations measured in the background samples, NFS will suspend discharges until corrective actions are taken.

Storm water from the eastern portion of the NFS site drains into Banner Spring Branch and then into Martin Creek, while storm water from the NFS main plant site and the BLEU complex drains into a culvert that parallels the northwest plant boundary and empties into Martin Creek.

Weekly sampling of Martin Creek downstream of the plant site is performed in accordance with a State of Tennessee storm water permit, and samples are analyzed for constituents identified in the permit, including gross alpha and gross beta radioactivity. In addition, samples are taken quarterly, at the two storm water pathways - the Banner Spring Branch and the Perimeter Northwest Ditch location (ML11278A079).

In Section 1.3.4 of the NFS LA, the revised information states that the NFS Protected Area is completely outside of the 100-year floodplain and much of the northern portion of the NFS property is outside of the 100-year floodplain. A portion of the north site, 600 feet off Martin Creek along the railroad, and a small section along the Protected Area wall is within the 100-year floodplain based on the 2018 Martin Creek Flood Study Summary (Arcadis, 2018) for NFS as provided in a RAI response and this flood study is under review by FEMA (ML23041A235). Due to the potential of flooding near Martin Creek and the North Site during a major rain event, NFS personnel would ensure that water ways remain clear and remove any debris that could impede this flow (ML23041A235). The NRC staff also requested additional information from the licensee to address any changes in waste generated due process changes that require additional waste minimization and decontamination modifications. In their response to RAI-26, the licensee states the U-metal process will follow the waste minimization program for the entire site (ML23041A235). Under the NFS Waste Management Policy, NFS-MGT-15-052, the company practices include:

  • Eliminating and/or minimizing the generation of waste is to be a major consideration in research, process design, and plant operations;
  • Participation of all employees in waste reduction practices is necessary to decrease the source of waste ALARA;
  • NFS will operate in full compliance to all Federal and State regulations; and
  • Responsibility for the administration of waste management programs lies within the Waste Management Section.

The waste minimization program practices have been incorporated into current procedures and plans for the entire site.

No modifications to the existing liquid effluent monitoring program are proposed in the NFS LAR. Using the guidance in NUREG-1520, Rev. 2, the NRC staff finds that the existing liquid effluent monitoring program provides assurance that the facility, with the addition of the U-metal process, will meet the public dose limits in 10 CFR 20.1301 during the license term.

2.9.2.2.2.2 Air Effluent Monitoring Airborne effluents are discharged from process stacks in accordance with operating permits issued by the Tennessee Air Pollution Control Board and are required to meet the NRC radiological standards of 10 CFR Part 20.

NFS uses various controls to minimize airborne effluents. The main system, which consists of venturi and demisting scrubbers and HEPA filtration, removes radioactive particulates and chemicals from the effluents. The scrubbers remove chemical compounds, and the HEPA filters remove particulates before their release through the NFS main stack. Additional filters and scrubbers include (1) American Society of Heating, Refrigerating, and Air Conditioning Engineers prefilters that are used on heating, ventilation, and air conditioning recirculation room air handlers, (2) packed bed or sieve tray scrubbers (sodium hydroxide, water, and sulfuric acid are used), and (3) multiple HEPA filters that are used throughout the plant to achieve higher removal efficiencies.

NFS analyzes samples from process stacks and vents for gross alpha and gross beta radioactivity and compares the results to NFS action levels established by procedural guidance. The stack action levels were derived using a dose-based approach with the intent of preventing the maximally exposed offsite receptor from receiving an annual total effective dose equivalent from air effluents greater than the ALARA dose constraint of 0.1 mSv (10 mrem) in 10 CFR 20.1101(d). The NRC staff previously reviewed this dose assessment methodology and found it to be adequate. The NFS LAR has not proposed any changes to this methodology. The NRC staff continues to find this methodology acceptable. The NRC staff finds that the existing air effluent monitoring program provides assurance that the facility will meet 10 CFR 20.1101(d) requirements and the public dose limits in 10 CFR 20.1301 during the license term.

2.9.2.2.2.3 Environmental Monitoring The NFS environmental monitoring program for ambient air, soil, silt/sediment, vegetation, ground water, and surface water are detailed in written procedures. Changes in the program may occur, based on changes in operation or the emergence of new information. If a sample cannot be taken, the NFS environmental protection function manager is notified, and an investigation is initiated to include an assessment of the significance of the event, the cause of the deviation from the plan, and a determination of any necessary corrective action to be performed at that time.

Ambient air monitoring is sampled continuously and analyzed weekly for gross alpha and gross beta. On a quarterly basis, a composite sample is taken and analyzed for isotopic uranium. Additionally, a composite sample is taken annually at the sampling station nearest the predicted maximally exposed offsite receptor and analyzed for additional isotopes of concern based on NFS characterization data of material processed. The samples are collected from eight air sampling stations that are concentrated along the predominant wind directions. NFS reviews air sampling results quarterly and compares results to internal action levels. If action levels are exceeded, then NFS would take appropriate corrective actions to determine the cause of the exceedance.

Surface soil samples are collected quarterly by a grab sample and analyzed for gross alpha and gross beta radioactivity. Four sampling locations concentrated along the predominant wind directions are routinely monitored. When analysis of the samples shows that action levels in the guidance have been exceeded, NFS will perform a specific isotopic analysis (based on materials and processes involved at the plant) on samples from the same sites.

Vegetation samples are collected routinely from four forage vegetation sites and analyzed quarterly for gross alpha and gross beta concentrations. When analysis of the samples shows that action levels in the guidance have been exceeded, NFS will perform a specific isotopic analysis (based on materials and processes involved at the plant) on samples from the same sites.

Shallow silt/sediment samples are collected by grab sampling along streams potentially affected by plant operations and analyzed quarterly for gross alpha and gross beta radioactivity. Where appropriate, upstream samples are collected in addition to downstream samples. When analysis of the samples shows that action levels in the guidance have been exceeded, NFS will perform a specific isotopic analysis (based on materials and processes involved at the plant) on samples from the same sites.

Typical minimum detectable concentrations (MDCs) when analyzing gross alpha for soil, silt/sediment, and vegetation samples are 5 picocuries (pCi) per gram. These MDCs compared to background level demonstrate that NFS can quantify significant levels above background levels (NFS, 2011). This demonstrates that MDCs are low enough to detect action limits and that the instrumentation being used is sensitive enough.

NFS monitors ground water quarterly using grab samples and analyzes for gross alpha and gross beta. NFS committed to monitoring a total of 11 wells - 1 upgradient well and 10 downgradient wells. In addition, NFS has additional wells available to sample if other monitoring data are needed.

If gross alpha activity in a well exceeds 15 pCi/liter, then an analysis for isotopic uranium will be performed. Isotopic plutonium and/or isotopic thorium analysis will be performed when a well contains these contaminants at levels significantly higher than background levels or if potential contamination in the area indicates that these analyses should be performed. If gross beta activity in any well exceeds 50 pCi/liter, an analysis for Tc-99 will be performed.

A facility action plan is in place with the State of Tennessee to monitor ground water onsite, as well as offsite as part of the ground water remediation program. Several monitoring and injection wells in various locations are sampled on an annual, semiannual, and quarterly basis (NFS, 2010).

NFS takes grab samples at upstream and downstream locations on Martin Creek and the Nolichucky River. Samples are taken weekly at the Martin Creek downstream location and quarterly at the other locations, and the samples are analyzed for gross alpha and gross beta (ML091900061 and ML11258A051).

The licensees air effluent monitoring program discussed above has been reviewed previously and the NFS LAR application does not propose any changes in the existing program.

The NRC staff finds that the existing environmental effluent monitoring program provides assurance that the facility will meet the public dose limits in 10 CFR 20.1301 during the license term under this amendment. Therefore, the NRC staff finds that this program is acceptable.

2.9.3 Evaluation Findings As discussed in Section 2.9.2 above, the NFS environmental monitoring program has been previously reviewed and accepted. With respect to past NFS operations, the radiological dose associated with the exposure to airborne and liquid effluents, for the hypothetical maximally exposed individual located at the fence line, has been less than 1 percent of the annual limit of 1.0 mSv (100 mrem) in 10 CFR 20.1301. Public doses from continued NFS operations are expected to remain below 10 CFR Part 20 regulatory limits.

NFS has developed a program to implement adequate environmental protection measures during operation, which include: (1) effluent controls to maintain public doses ALARA as part of the radiation protection program, and (2) effluent and environmental monitoring. The NRC staff concludes that the NFS program as described in the license renewal application previously, and changes associated with NFS LAR is adequate to protect the environment and the health and safety of the public during the license term, and complies with the applicable regulatory requirements in 10 CFR 20.1101, 20.1301, 20.2003, and those in 10 CFR Part 70, Subpart H.

The NRC staff prepared an EA for this action as required by 10 CFR 51.21. On the basis of the EA, the NRC staff has reached a finding of no significant impact, published in the Federal Register (88 FR 76262), Docket ID NRC-2022-0097, on November 6, 2023. Section 3.0, Environmental Review, of this document contains a summary of the actions related to the EA.

The NRC staff finds that the U-metal services will not cause a significant increase in the plant effluents and the existing environmental protection program provides reasonable assurance that the public health and safety, and the environment, will be protected.

2.10 Decommissioning 2.10.1 Purpose of Review Nuclear facilities licensed under 10 CFR Part 70 are required to provide adequate financial assurance for decommissioning, decontamination, and reclamation pursuant to 10 CFR 70.25, Financial Assurance and Recordkeeping for Decommissioning. Pursuant to 10 CFR 70.25(e)(2), NFS is required to submit a decommissioning funding plan and financial assurance every three years (i.e., triennial submittal) for NRC review and approval. The NRC staffs review includes confirmation that the triennial submittal accounts for changes in costs and the extent of contamination.

When the LAR for the U-metal services was submitted in November 2021, the most recently approved triennial submittal for NFS site-wide decommissioning was documented in Amendment 12 to the NFS license (ML20015A560), dated January 23, 2020. The U-metal LAR, submitted in November 2021, included a Decommissioning Cost Estimate (DCE) that was specific to the U-metal services. During the time that the U-metal LAR was under NRC review, the NRC staff issued Amendment 18 to the NFS license (ML23053A149), dated March 3, 2023, which approved the most current triennial submittal for NFS site-wide decommissioning. Note that triennial submittal approved in 2023 did not include any cost estimates related to decommissioning of the U-metal services because it was not an approved facility operation at that time.

To review the DCE submitted by NFS for the U-metal LAR, the NRC staff utilized the applicable regulations in 10 CFR and guidance contained in NUREG-1757, Vol. 3, Rev. 1, Consolidated Decommissioning Guidance Financial Assurance, Recordkeeping, and Timeliness.

2.10.2 Regulatory Requirements NFS remains responsible for the status and future decommissioning of the licensed site and facility; it must continue to abide by all commitments and representations previously made to NRC; and must continue to abide by all constraints, conditions, requirements, representations, and commitments identified in the license. Additionally, as required by 10 CFR 70.25(e), NFS must continue to submit an updated cost estimate for decommissioning for NRCs review at intervals not to exceed three years. After resolution of any NRC comments on the estimate, NFS must submit signed originals of the financial instruments reflecting an amount sufficient to cover the approved cost estimate. NFS remains liable for any decommissioning costs not covered by the financial instruments referenced above.

2.10.3 NRC Staff Review and Analysis The 2021 U-metal DCE, included with the U-metal LAR, estimated the total cost to decommission the U-metal services at $16,054,655 - based on 2023-dollar values for unrestricted use. The U-metal DCE included the quantity and dimensions of the components for the project, which included the U-metal structures, equipment, services (e.g., heating, ventilation, electrical, plumbing), the associated difficulty factors to decontaminate and decommission those U-metal components, a cost per volume to dispose of the waste, various miscellaneous costs for decommissioning, and the labor cost, which was calculated from specific labor rates and categories for an independent contractor to perform the decommissioning. The methodologies and 25% contingency factor discussed in the U-metal DCE aligned with those in the triennial submittals which were approved in 2020 and 2023.

The labor rates utilized by the U-metal DCE aligned with those in the triennial submittal that was ultimately approved in 2023.

The NRC staff sent requests for supplemental information RSIs (ML22014A421) pertaining to the 2021 U-metal DCE. The RSIs covered the following eight main areas: 1) spills of radioactive materials, 2) waste inventory increases, 3) waste disposal cost increases, 4) facility modifications, 5) changes in authorized possession limits, 6) actual remediation costs that exceed the previous cost estimate, 7) onsite disposal, and 8) use of a settling pond. The RSIs also covered key assumptions used in preparing the DCE.

NFS responded to the RSIs (ML22066B004 and ML22069A315), and the NRC staff evaluated the supplemental information provided for the U-metal DCE. Specifically, NFS submitted a detailed cost estimate for decommissioning and provided supplemental information which:

(1) reflects the cost of an independent contractor to perform decommissioning activities, (2) is based on unrestricted use, (3) includes an adequate contingency factor, and (4) identifies and provides justification for key assumptions.

2.10.4 Evaluation Findings The NRC staff determined that the 2021 U-metal DCE, as supplemented by the information from the NFS response to the associated RSIs (ML22066B004 and ML22069A315), is based on reasonable and documented assumptions, and that it reasonably estimates the cost, at this time, to decommission the U-metal services. Furthermore, the NRC staff determined that the 2021 U-metal DCE satisfied the requirements of 10 CFR 70.25(e) and was consistent with NUREG-1757, Volume 3, Rev. 1.

Therefore, the NRC staff concluded that NFSs 2021 U-metal DCE of $16,054,655 is acceptable for the U-metal services. NFS must submit the following documents within 30 days of the date that the U-metal LAR is approved:

  • Signed originals of the financial instruments that guarantee the funds,
  • An updated certification of financial assurance, and
  • Any changes needed to Chapter 10, Decommissioning, of the NFS LA.

Additionally, NRC approval of the updated financial assurance instruments is required prior to completion of the operational readiness review (i.e., before the introduction of special nuclear material into the new portions of the processes to be used for U-metal services), which has been included in the new condition S-9 that is being added to materials license SNM-124 - see Section 4.0 of this SER.

The NRC staff finds the proposed update is acceptable and meets the regulatory requirements to provide financial assurance, as set forth in 10 CFR 70.25(e). The licensee remains liable for any costs not covered by the financial instruments.

2.11 Management Measures The management measures program is unchanged by the U-metal LAR. The licensee has existing commitments for a management measures program in Chapter 11 of its existing LA (ML20078K605). This program has been reviewed and approved by the NRC previously.

The NRC staff continues to find the management measures program to be adequate.

2.12 Material Control and Accounting The NRC staff has evaluated the application using the criteria provided in Chapter 12 of NUREG-1520. Rev. 2. As specified in 10 CFR 70.22(b), a licensee must submit a full description of its program for the control and accounting of the SNM in its possession under license to demonstrate how compliance with the requirements in 10 CFR Part 74, Material Control and Accounting of Special Nuclear Material, will be accomplished. For certain facility types and safeguards categories, this material control and accounting (MC&A) program is provided in the form of a Fundamental Nuclear Material Control Plan (FNMCP). The licensee has an NRC-approved FNMCP for the control and accounting of strategic SNM that describes acceptable methods for achieving the performance objectives in 10 CFR 74.51(a) and the system capabilities of 10 CFR 74.51(b) associated with its current processes.

In the LAR, the licensee stated that while design considerations for the U-metal process related to MC&A measurement points and physical inventory have been made, minor changes to the MC&A program related to the U-metal process were not included in the submittal. The licensee further stated that the minor changes to the MC&A program do not represent a substantive change, do not represent a decrease in effectiveness of the MC&A program, and therefore, in accordance with 10 CFR 70.32, do not require prior NRC approval. While 10 CFR 70.32(c) allows, without prior NRC approval, for changes that would not decrease the effectiveness of the MC&A program, the NRC must make a determination that the proposed MC&A controls for the proposed U-metal process are adequate in accordance with 10 CFR 70.23(a)(6). Therefore, the NRC staff requested the licensee provide supplemental information regarding the MC&A controls applicable to the U-metal process and the anticipated changes to the FNMCP.

In the response to the RSI, the licensee provided, for each section of the FNMCP, a summary of the expected changes that are related to the LAR. The licensee stated that the anticipated FNMCP changes will include the addition of the following descriptions with respect to the proposed U-metal process: new process monitoring control units; item classifications of new intermediate material types; and currently used measurements, measurement controls, and physical inventory preparation that will be applicable. The licensee stated that the modified descriptions utilize similar procedures, classifications, material controls, and techniques that are currently used in other areas of the facility and are currently described in the approved FNMCP.

Consequently, the licensee determined that these FNMCP changes will not decrease the effectiveness of the MC&A program. Additionally, the licensee committed to provide an updated FNMCP in accordance with the provisions of 10 CFR 70.32(c) at a time that is acceptable to the NRC and the licensee, prior to the start of the new U-metal process.

Based on the review of the LAR, the supplemental information, and the licensees current FNMCP, the NRC staff concludes that the licensee provided sufficient information to satisfy the regulatory requirement contained in 10 CFR 70.32(c)(1)(iii) regarding the anticipated changes to the MC&A program associated with the LAR. The changes involve adding new elements and components to the existing MC&A program with respect to process monitoring, item monitoring, alarm resolution, and quality assurance and accounting. The NRC staff therefore finds there is reasonable assurance that the licensees MC&A program will continue to detect and protect against the loss, theft, or diversion of SNM that the licensee will possess, store, and utilize at its facility.

In accordance with 10 CFR 70.32(c), each license authorizing the use of uranium source material at a uranium enrichment facility or authorizing the use of SNM in a quantity exceeding one effective kilogram, must contain a license condition to ensure that such material is adequately controlled and accounted for within the licensed facility. Material license SNM-124 will continue to include license condition SG-1.1, which is applicable to the U-metal services and satisfies the noted regulatory requirement contained in 10 CFR 70.32(c).

Additionally, in the response to RSIs (ML22066B004 and ML22069A315), the licensee committed to providing an updated FNMCP prior to the startup of the U-metal process.

Therefore, a provision will be added to the operational readiness review license condition for this license amendment to ensure that the FNMCP changes have been provided and verify that the appropriate MC&A controls are in place.

2.13 Physical Protection The physical protection program is unchanged by the U-metal amendment. The licensee has several plans for the physical protection of HEU in accordance with 10 CFR Part 73 and several security orders. The plans have been reviewed and approved by the NRC previously. The NRC staff continues to find the physical protection program to be adequate.

Based on the evaluation described above, the NRC staff finds that the plan(s) for physical protection of SNM provide high assurance that the licensee will provide adequate protection for the U-metal services. The NRC staff concludes that the licensee provided an acceptable physical protection plan, including the U-metal services, that will meet the applicable requirements specified in 10 CFR Part 73.

3.0 ENVIRONMENTAL REVIEW The NRC staff prepared an EA for this action in accordance with 10 CFR Part 51. Based on the assessment, the NRC staff concluded that the environmental impacts associated with the proposed action are not significant. A finding of no significant impact was published in the Federal Register (88 FR 76262), Docket ID NRC-2022-0097, on November 6, 2023.

4.0 CONCLUSION

Based on the safety review described above, the NRC staff finds that the LAR satisfies the applicable regulatory requirements in 10 CFR Part 70 and other parts referenced therein. The NRC staff concludes there is reasonable assurance that the activities authorized by the proposed amendment will not pose an undue risk to the health and safety of the public, workers, or the environment. Approval of the U-metal license amendment, with the following condition, is recommended:

S-9 Introduction of special nuclear material into the new portions of the processes to be used for U-metal services shall not occur until the NRC provides written notice to the licensee that the NRC has completed an operational readiness review. The operational readiness review will verify whether: (1) commitments in the amendment request have been fulfilled; (2) management measures for IROFS have been implemented; (3) the new processes have been constructed in accordance with design requirements and startup plans reflect as-built conditions; and (4) other actions necessary for safe operations are complete, including but not limited to: (a) the process safety information and integrated safety analysis summaries are updated for all nodes of the U-metal services to reflect final design, including those nodes that are not part of the license amendment application; (b) the items relied on for safety are fully defined (e.g., completed boundary packages) and based on as-built conditions (e.g., set points established); (c) the plans referenced in the license (e.g., Fundamental Nuclear Material Control Plan, physical protection plans, emergency plan) are updated and appropriately documented, in accordance with the applicable provisions of 10 CFR 70.32, to reflect the as-built conditions and any changes needed for U-metal services; (d) the material control and accounting controls, as specified in the updated Fundamental Nuclear Material Control Plan and applicable to the U-metal services, are in place; and (e) a license amendment to update the financial assurance instruments for the decommissioning of U-metal services has been approved by the NRC staff.

NRC inspection staff has no objection to the proposed action.

5.0 PRINCIPAL CONTRIBUTORS James Downs, NMSS/DFM Suzanne Ani, NMSS/DFM Mike Call, NMSS/DFM Jill Caverly, NMSS/REFS James Chang, RES/DRA Jimmy Chang, NMSS/DFM Jonathan DeJesus, NMSS/DFM Eli Goldfeiz, NMSS/DFM Jim Hammelman, NMSS/DFM Tim Harris, NSIR/DPCP Ken Kline, NMSS/REFS Patrick Koch, NMSS/DFM Juan Lopez, NMSS/DFM Jonathan Marcano, NMSS/DFM Ken Mott, NSIR/DPR Jeremy Munson, NMSS/DFM Donald Palmrose, NMSS/REFS Lisa Pope, NMSS/REFS Rao Tammara, NMSS/REFS Aaron Thomlinson, NMSS/DFM Ashley Waldron, NMSS/REFS

6.0 REFERENCES

(ACI, 2014) American Concrete Institute 318-14, Building Code Requirements for Structural Concrete and Commentary, 2014.

(AISC, 2016) American Institute of Steel Construction 360-16, Specification for Structural Steel Buildings, 2016.

(AISI, 2015) American Iron and Steel Institute S240-15, North American Standard for Cold-Formed Steel Structural Framing, 2015.

(AISI, 2016) American Iron and Steel Institute S100-16, North American Specification for the Design of Cold-Formed Steel Structural Members, 2016.

(ANS, 2007) ANSI/ANS-8.23, Nuclear Criticality Accident Emergency Planning and Response, March 2007.

(Arcadis, 2018) Arcadis, Martin Creek Flood Study Summary, January 2018.

(ASCE, 2016) American Society of Civil Engineers, ASCE 7-16, Minimum Design Loads and Associated Criteria for Buildings and Other Structures 2016.

(ASTM, 2017) ASTM International, Standard Test Method for Fire Tests of Penetration Firestop Systems, 2017.

(DOE, 2002) The United States Department of Energy, DOE-STD-1020-2002, Natural Phenomena Hazards Design and Evaluation Criteria for Department of Energy Facilities, 2002.

(ICC, 2012a) International Code Council, International Building Code, 2012.

(ICC, 2012b) International Code Council, International Fire Code, 2012.

(ICC, 2018) International Code Council, International Building Code, 2018.

(IE, 2022) Integration Engineering, PLLC, Document No. 22421001-SR-002, Rev. 0, Nuclear Fuel Services U-metal Project NPH Review, 2022.

(NFPA 10, 2018) National Fire Protection Association, Standard for Portable Fire Extinguishers, 2018.

(NFPA 13, 2019) National Fire Protection Association, Standard for the Installation of Sprinkler systems, 2019.

(NFPA 51B, 2019) National Fire Protection Association, Standard for Fire Prevention During Welding, Cutting, and Other Hot Work, 2019.

(NFPA 70, 2020) National Fire Protection Association, National Electrical Code, 2020.

(NFPA 72, 2019) National Fire Protection Association, National Fire Alarm and Signaling Code, 2019.

(NFPA 80, 2019) National Fire Protection Association, Standard for Fire Doors and Windows, 2019.

(NFPA 86, 2019) National Fire Protection Association, Standard for Ovens and Furnaces, 2019.

(NFPA 90A, 2018) National Fire Protection Association, Standard for the Installation of Air-Conditioning and Ventilating Systems, 2018.

(NFPA 101, 2018) National Fire Protection Association, Life Safety Code, 2018.

(NFPA 220, 2018) National Fire Protection Association, Standard on Types of Building Construction, 2018.

(NFPA 600, 2020) National Fire Protection Association, Standard on Industrial Fire Brigades, 2020.

(NFPA 780, 2020) National Fire Protection Association, Standard for the Installation of Lightning (Protection Systems, 2020.

(NFPA 801, 2014) National Fire Protection Association, Standard for Fire Protection for Facilities Handling Radioactive Materials, 2014.

(NFS, 2012) Nuclear Fuel Services, Inc., 54T-12-0038, Validation of Computer Codes for NCS for Uranium Systems with Enrichments up to 100 wt.%.

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(NFS, 2021b) Nuclear Fuel Services, Inc., ISA Risk Assessment HEU Metal - Node 4, Vessel Preparation Station, RA-UMETAL-004, Revision 0, HEA-21, EAS-21-043, 21T-21-0885, 2021.

(NFS, 2022a) Nuclear Fuel Services, Inc., DESCALC-UMETAL-S101, Rev. 0, Building ZZ1 Column Rack Seismic Analysis, 2022.

(NFS, 2022b) Nuclear Fuel Services, Inc., DESCALC-UMETAL-S103, Rev. 0, Building ZZ1 Furnace Room Support Seismic Analysis, 2022.

(NFS, 2022c) Nuclear Fuel Services, Inc., DESCALC-UMETAL-S105, Rev. 0, Building ZZ1 ModCon Structure, 2022.

(NFS, 2022d) Nuclear Fuel Services, Inc., DESCALC-UMETAL-S200, Rev. 0, U-Metals Enclosures Seismic Anchorage Analysis, 2022.

(NFS, 2023d) Nuclear Fuel Services, Inc., REP-UMETAL-0006, Rev. 0, Equipment Evaluation for Seismic Event, 2023.

(NFS, 2023e) Nuclear Fuel Services, Inc., DESCALC-UMETAL-S106, Rev. 0, Building ZZ1 Existing Structure (Floor, Roof, and Walls), 2023.

(NFS, 2023a) Nuclear Fuel Services, Inc., Accident Consequence Evaluation for Building 301 HEU Metal, Nodes 3, 4, and 5 - Revision 4, 21T-23-0207, January 2023.

(NFS, 2023b) Nuclear Fuel Services, Inc., ISA Safety Basis Risk Assessment Support and Justification for Building 301 - HEU Metal- Revision 3, RA-301-Umetal Node 3, 21T-22-1743, HEA-20, ARM-22-034, 2023.

(NFS, 2023c) Nuclear Fuel Services, Inc., ISA Safety Basis Risk Assessment Support and Justification for Building 301- HEU Metal, Revision 2, RA-301-Umetal Node 5, 21T-22-1745, HEA-20, ARM-22-036, 2023.

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(NRCNA, 2004) National Research Council of the National Academies Acute Exposure Guideline Levels for Selected Airborne Chemicals Volume 4, May 2004.

(UL, 2006) Underwriters Laboratories Inc., Standard for Safety for Fire Dampers, 2006.

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