ML23311A381

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Safety Evaluation Report for GNF-A Request for 8 Weight Percent Uranium 235
ML23311A381
Person / Time
Site: 07001113
Issue date: 12/11/2023
From:
NRC/NMSS/DFM/FFLB
To:
Global Nuclear Fuel - Americas
Shared Package
ML23311A379:ML23311A379 List:
References
EPID L-2022-LLA-0065
Download: ML23311A381 (20)
v • d • e


Text

DOCKET: 70-1113 LICENSE: SNM-1097 LICENSEE: Global Nuclear Fuel - Americas LLC

SUBJECT:

GLOBAL NUCLEAR FUEL - AMERICAS - AMENDMENT 18, GNF-A LICENSE AMENDMENT REQUEST FOR EIGHT WEIGHT PERCENT URANIUM 235 (ENTERPRISE PROJECT IDENTIFICATION NUMBER L-2022-LLA-0065)

1.0 BACKGROUND

On June 24, 2022 (Agencywide Documents Access and Management System [ADAMS]

Accession No. ML22175A070), Global Nuclear Fuel - Americas LLC (GNF-A or the licensee) requested a license amendment to Special Nuclear Materials (SNM) License SNM-1097 to permit nuclear fuel fabrication at enrichments up to 8.0 weight percent (wt. %) uranium 235 (U-235). The request provided a description and analysis of the proposed change, basis for the change, and safety significance of the proposed change.

The U.S. Nuclear Regulatory Commission (NRC) staff issued a request for additional information (RAI) by letter dated July 3, 2023 (ML23156A183), to obtain information needed to facilitate a detailed technical review. By letter dated July 28, 2023 (ML23209A676), GNF-A provided a response to the NRC staffs request.

The NRC staff conducted its review in accordance with NUREG-1520, Revision 2, Standard Review Plan for Fuel Cycle Facilities License Application (ML15176A258), NUREG-1065, Acceptable Standard Format and Content for the Fundamental Nuclear Material Control (FNMC) Plan Required for Low-Enriched Uranium Facilities (ML031340288), and NUREG/CR-6698, Guide for Validation of Nuclear Criticality Safety Calculational Methodology (ML050250061). The NRC staff also reviewed the request for compliance with the requirements in Title 10 of the Code of Federal Regulations (10 CFR) Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, 10 CFR Part 20, Standards for Protection Against Radiation, 10 CFR 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, 10 CFR Part 70, Domestic Licensing of Special Nuclear Material, and 10 CFR 74, Material Control and Accounting of Special Nuclear Material.

2.0 TECHNICAL EVALUATION

2.1 Integrated Safety Analysis The NRC staff conducted its review of the license amendment request (LAR) to ensure that the requested changes are consistent with the requirements in 10 CFR Part 70, including:

  • 10 CFR 70.62, Safety program and integrated safety analysis Enclosure 1 1
  • 10 CFR 70.72, Facility changes and change process The NRC staffs review was conducted in accordance with Chapter 3 of NUREG-1520.

GNF-A stated in its LAR (ML22175A070) that the increase in enrichment does not create new types of accident sequences and that it does not have plans to use new processes, technologies, or control systems in which it does not have prior experience.

Because the requested amendment does not modify the licensees existing ISA methodology and program commitments, the NRC staff determined that the licensees safety program continues to provide reasonable assurance that:

  • The licensee conducted an ISA of appropriate detail for each applicable process using methods and qualified staff adequate to achieve the requirements of 10 CFR 70.62, Safety program and integrated safety analysis;
  • The licensee identified and evaluated in the ISA credible events 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, Performance requirements, and
  • The licensee appropriately designated IROFS, evaluated those IROFS for preventing or mitigating the applicable accident sequences and applied its management measures program to demonstrate compliance with the performance requirements of 10 CFR 70.61.

To reach this determination, the NRC staff reviewed the ISA summary as well as supporting documentation, including quantitative risk assessments and CALC documents. This review focused on areas where signification revisions were made, particularly where IROFS were deleted, replaced, or modified. Changes include updating event descriptions, replacing IROFS, and updating event frequencies because of the change in safe mass limits. These changes were generally minor, and the methods used in the revised ISA summary are judged to be reasonable.

The NRC staff notes that the frequency assigned to IROFS 802-05 is at the low end of the range of values listed for administrative controls in NUREG-1520, table A-10. Values on the low end of this range are found acceptable when technically supported in the ISA and properly documented. While this would not be acceptable if used throughout the ISA, this particular IROFS is only used in sequences where the total frequency is significantly less than the definition of highly unlikely used in the ISA as required for high-consequence events in 10 CFR 70.61(b). For these reasons, the NRC staff finds the overall approach is reasonable.

2.2 Radiation Protection The NRC reviewed the radiation protection program described in the GNF-A license application to determine whether the radiological health and safety of workers is adequately 2

protected, as required by the regulations at 10 CFR Part 19, Notices, Instructions and Reports to Workers: Inspection and Investigations, 10 CFR Part 20, Standards for Protection Against Radiation, and 10 CFR Part 70, Domestic Licensing of Special Nuclear Material.

The proposed inventory of U-235 will be subject to the radiation protection provisions in the current licensed inventory (ML18288A002). The NRC staff finds the current license satisfies:

(1) worker qualification requirements; (2) written radiation protection procedures; (3) the radiation work permit program; (4) necessary training requirements for all personnel who have access to radiologically restricted areas; and (5) provides a program to ensure that worker and public doses are as low as is reasonably achievable.

The NRC staff concluded the current radiation survey and monitoring program is adequate to protect workers and members of the public who may potentially be exposed to radiation in Safety and Safeguards Evaluation Report for the Renewal of SNM-1097 - Global Nuclear Fuel - Americas Wilmington, North Carolina, issued in 2009 (ML091000554). The requested amendment does not change GNF-As radiation protection program. Therefore, the NRC staff finds reasonable assurance that the current radiation protection program, as described in the current license, is adequate for the proposed 8.0 wt. % U-235 enrichment.

2.3 Nuclear Criticality Safety The NRC staff reviewed 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, Revision 2, as well as applicable portions of NUREG/CR-6698.

Nuclear Criticality Safety Program The requested amendment relies on the existing GNF-A nuclear criticality safety (NCS) program and does not involve changes to the (1) management, organization, or administration of the NCS program; (2) NCS training, NCS staff training, and NCS qualifications; (3) management measures applied to the NCS program including characterization and handling of NCS nonconformances, use of procedures, audits, and assessments; (4) use of industry standards; or (5) 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 3

program were evaluated previously and found to be acceptable by NRC staff as documented in the NRC staffs safety evaluation report (SER) for the 2009 license renewal (ML091000554).

In that SER, the NRC staff found reasonable assurance that (1) the licensees managers, supervisors, engineers, process operators, and other support personnel are qualified to develop implement, and maintain the NCS program in accordance with the facility organization and administration; (2) the licensees conduct of operations is based on NCS methodologies and technical practices which will ensure that fissionable material will be possessed, stored, and used safely according to the requirements in 10 CFR Part 70; (3) the licensee has developed, implemented, and will maintain a criticality accident alarm system (CAAS) in accordance with the requirements in 10 CFR 70.24 and the facility emergency management program; and (4) the licensee has an NCS program which is in accordance with the subcriticality of operations and margin of subcriticality for safety requirements in 10 CFR 70.61(d) and baseline design criteria requirements in 10 CFR 70.64(a) (ML091000554).

The LAR states the enrichment increase does not create new types of accident sequences, nor will GNF-A use new processes, technologies, or control systems with which GNF-A has no prior experience. In addition, GNF-As NCS program remains unchanged and will continue: (1) to document nuclear criticality safety analyses (CSAs), (2) to conduct process hazards analysis (PHA), (3) to document quantitative risk assessments (QRA), and (4) to maintain an ISA summary are unchanged in the amendment request. Because the amendment does not modify the licensees NCS program or the NCS technical practices, the NRC staff determines the current amendment is bounded by the conclusions documented in NRC staffs SER prepared of license renewal (ML091000554).

Minimum Margin of Subcriticality The requested amendment relies on the licensees existing criticality safety analytical methods, validation techniques, and minimum margin of subcriticality (MMS). These elements were previously evaluated and found to be acceptable by the NRC staff for enrichment up to 20 wt. % U-235 as documented in the NRCs approval letter, Approval of Safety Analytic Methods for Enrichment up to 20 Weight Percent Uranium-235 (ML22199A252), dated August 2, 2022. The NRC staff concludes the licensees current NCS analytic methods, validation techniques, and MMS are acceptable for use up to 20 wt.

% U-235 for the purposes of performing NCS analyses. The NRC staff finds that the amendment request for enrichments up to 8.0 wt. % U-235 is bounded by the NRC staffs previous evaluation, which approved enrichments up to 20 wt. % U-235 (ML22199A252).

Criticality Accident Alarm System The requested amendment does not involve changes to the licensees CAAS coverage or commitments. Section 1.3.11 of the current LAR notes that the NRC granted an exemption from the requirements of 10 CFR 70.24 because the licensee demonstrated that a criticality accident is not credible for (1) a quantity of finished reactor fuel rods equal to or less than 45% of a minimum critical number under conditions in which double batching is credible, or equal to or less than 75% of a minimum critical number under conditions in which double batching is not credible; or (2) the quantity of uranium authorized for delivery to a carrier when fully packaged for transport according to a valid NRC authorization for such packages 4

without limit on the number of such packages, provided storage locations preclude mechanical damage and flooding; or (3) individual areas where there is negligible risk of criticality due to the amount or configuration of fissile material. The NRC staff documented these finding in the SER granting the exemption from 10 CFR 70.24, Global Nuclear Fuel -

Americas - Exemption to Criticality Monitoring System Requirements License Amendment Request and Amendment 12 (ML16048A160). At the time of granting this exemption, the licensees possession limits were limited to enrichments of 5.0 wt. % U-235 or less.

The NRC staff requested that GNF-A provide information to demonstrate that the exemption from the requirements of 10 CFR 70.24 remains protective at enrichments up to 8.0 wt. %

U-235, by letter dated July 3, 2023 (ML23156A183). The licensee explained the effects of changing source terms to 8.0 wt. % U-235 were evaluated and documented for CAAS detector coverage in GNFs, Analysis of Criticality Accident Alarm System Coverage in GNF-A Fuel Manufacturing Facilities (see GNF-A Response to NRC Request for Additional Information, ML23209A676). The NRC staff re-examined the grant of the exemption from the requirements for a criticality monitoring and alarm system under 10 CFR 70.24 (ML16048A160). The NRC staff finds the exemption remains warranted and finds reasonable assurance that the licensee will continue to properly apply the exemption criteria.

The LAR does not modify the licensees existing process for determining whether an exemption from the requirements of 10 CFR 70.24 is warranted. The licensees existing process is a function of whether a credible criticality risk exists independent of U-235 enrichment. The NRC staff finds that the 8% enrichment level in the current amendment is bounded by the NRC staffs conclusions granting the exemption to criticality monitoring system requirements (ML16048A160).

Nuclear Criticality Safety Evaluations The NRCs regulations at 10 CFR) 70.61(d) require, in part, the risk of nuclear criticality accidents be limited by assuring that under normal and credible abnormal conditions, all nuclear processes are subcritical, including use of an approved margin of subcriticality for safety.

Section 5.3.B.2 of NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications, Revision 2, states that the NRC staff reviews should include, in part, any new or changed assumptions, controlled parameters, safety limits, controls, or safety margin, as well as new or changed criticality accident sequences. Section 5.3.B.5 of NUREG-1520 states that NRC staff reviews should also include the justification for requested changes, including revised criticality safety basis documents (process hazards analyses, criticality safety evaluations, calculations, and other supporting technical documents) that are needed to demonstrate adequate protection against the risk of accidental criticality.

In an RAI dated July 3, 2023 (ML23156A183), the NRC staff requested GNF-A provide a sample of nuclear criticality safety analyses (CSAs). In its response to the NRC staffs request (ML23209A676), the licensee provided the following CSAs:

  • CSA 206.00.100 - Dry Conversion Process (DCP) Blend, Pre-Compact, and Granulate Process 5
  • CSA 407.00.100 - Rod Processing
  • CSA 801.00.100 - General Can Storage; and
  • CSA 702H.00.100 - 8.0 wt. % Liquid Radioactive Waste System.

The requested increase to 8 wt. % U-235 in the LAR necessitates the revision of existing CSAs, modification of certain limits on controlled parameters, and modification of limits associated with certain IROFS. However, the licensees methodology for conducting and documenting CSAs, establishing limits on controlled parameters, and the designation of IROFS remains unchanged. Furthermore, the licensees commitments to NCS technical practices, the assurance of subcriticality under normal and all credible abnormal conditions, and the double contingency principle likewise remain unchanged. In addition, the NRC staff evaluated GNF-As NCS program, including NCS technical practices, during its review for the 2009 license renewal (ML091000554) and found the NCS program to be acceptable.

The NRC staff also notes that the licensees NCS program is consistent with Chapter 5, Nuclear Criticality Safety, of NUREG-1520, Revision 2. The NRC staff finds the NCS program is sufficient to identify credible criticality hazards, limit the risk of credible criticality hazards such that the likelihood of inadvertent criticality is highly unlikely, and assure subcriticality under normal and all credible abnormal conditions.

The NRC staff reviewed the revised CSAs and analyses submitted as RAI responses. The revised CSAs and analyses are consistent with the NCS technical practices and commitments described in the license renewal application (ML18288A002). Those technical practices and commitments were evaluated by NRC staff and found to be acceptable, as documented in the NRC staffs SER of GNF-As license renewal (ML091000554). Therefore, the NRC staff finds the licensees NCS program continues to provide reasonable assurance of subcriticality under normal and all 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, including 10 CFR 70.61(b) and 70.61(d).

Nuclear Criticality Safety Related Changes to the Integrated Safety Analysis The NRC staffs evaluation of the requested amendments impact on the ISA and ISA summary is discussed earlier in this chapter in Section 2.1 of this report. The NRC staff evaluated the LAR for consistency with Section 5.3.B.2 of NUREG-1520, which states that NRC staff reviews should include, in part, portions of the ISA summary affected by the requested changes, including any changes to process descriptions, new or changed assumptions, and new or revised criticality accident sequences and IROFS.

SNM-1097 License Renewal Chapter 5 Revisions1 Section 5.3.B.1 of NUREG-1520 recommends the NRC staff review portions of the license application that are changed in order to ensure the effectiveness of license commitments is not reduced, and that the licensee demonstrates adequate protection against the risk of an accidental criticality.

1 See GNFA License Amendment Request for 8 wt % U 235, Attachment 4, SNM1097 (ML22175A072). Attachment 4 to the current LAR identifies revisions made to Chapter 5, Nuclear Criticality Safety of the license renewal application, as revised, submitted by GNF-A in 2008 (ML18288A002).

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The NRC staff reviewed the requested changes to Sections 5.1.1, 5.1.2.1, 5.1.2.2, 5.3.2.5, 5.4.2.3, 5.4.4.6, 5.4.4.8, 5.4.5.3, 5.4.5.4, and 5.4.5.5 of the Materials License SNM-1097 license renewal application (ML22175A072) and determined that the changes do not represent significant technical changes to or dilution of existing commitments. In addition, the NRC staff determined that certain changes to Section 5.4.3 of the SNM-1097 license renewal application were administrative or otherwise did not represent any significant technical changes to, or dilution of, existing commitments; however, there were also technical changes to this section that warranted additional analysis. The NRC staffs evaluation of the requested technical changes to Section 5.4.3 of the LAR is presented below.

Section 5.4.3 - Specific Parameter Limits. Table 5.1 of the SNM-1097 license renewal application currently provides favorable geometry values for critical cylinder diameter, critical slab thickness, and critical sphere volume for homogeneous uranium dioxide - water (UO2-H2O) mixtures, homogeneous aqueous uranyl nitrate solutions, and heterogeneous UO2-H2O mixtures for enrichments varying from 2.0 wt. % to 5.0 wt. % U-235. The values provided in Table 5.1 are currently based on 93% of the minimum critical cylinder diameter, 88% of the minimum critical slab thickness, and 76% of the minimum critical sphere volume per industry consensus standards or technical references. Table 5.2 of the SNM-1097 license renewal application currently provides safe batch values for homogeneous UO2 powder and water mixtures and heterogeneous UO2 pellets and water mixtures for enrichments varying from 1.1 wt. % to 5.0 wt. % U-235. Requested changes to Section 5.4.3 would update the favorable geometry values provided in Table 5.1 to include enrichments ranging from 5.0 wt. % to 8.0 wt. % U-235 derived explicitly from SCALE/KENO-VI calculations and would update the safe batch values provided in Table 5.2 to include enrichments ranging from 5.0 wt. % to 8.0 wt. % U-235.

The NRC staff reviewed the requested changes to Section 5.4.3 of the SNM-1097 license renewal application and determined that the changes are appropriate for enrichments up to 8.0 wt. % U-235. The values added to Tables 5.1 and 5.2 were derived using the licensees MMS and analytical methods described in Sections 5.4.5.3 and 5.4.5 of the SNM-1097 license renewal application, respectively. The licensees MMS was previously evaluated by NRC staff and found to be acceptable for use up to 20 wt. % U-235 as documented in NRC letter dated August 2, 2022 (ML22199A252). In addition, the licensees analytical methods were previously evaluated by NRC staff and found to be acceptable as documented in NRC staffs SER for the license renewed in 2009 (ML091000554). Therefore, the NRC staff determined that the requested changes to Section 5.4.3 of the SNM-1097 license renewal application are bounded by the NRC staffs previous conclusions and are therefore acceptable.

Segmentation of the Facility The operating history at a Japanese fuel fabrication facility demonstrates that attempts to segment facility processes to handle two or more enrichments present a credible criticality risk. This is evidenced by the criticality accident that occurred at the Japan Nuclear Fuel Conversion Company (JCO) Fuel Fabrication Plant on September 30, 1999, in Toki-mura, Ibarakin prefecture, Japan. Three buildings were licensed to handle fissionable materials, with one building authorized to process enrichments up to 20 wt. % U-235, while the other two buildings were authorized to enrich up to 5 wt. % U-235 or less. Procedures specified 7

different mass limits for the different enrichments, which contributed to procedural non-compliances that resulted in a criticality accident (ML003731912).

The NRC staff issued RAIs asking if GNF-A plans to segment facility processes into areas that handle enrichments up to 5.0 wt. % U-235 and into areas that process enrichments greater than 5.0 wt. % U-235 up to 8.0 wt. % U-235 (ML23156A183). The licensee responded that there are no plans to segment the facility based on enrichment and that the entire fuel fabrication facility will be approved and controlled to safely process material enrichments up to 8.0 wt. % U-235 (ML23209A676). For this reason, the NRC staff finds GNF-As facility will not be segmented, and all U-235 be assumed to have a bounding enrichment of 8.0 wt. %, which will eliminate the potential for process upsets related to the misapplication of limits due to varying enrichments.

The NRC staff imposes a license condition ensure that the licensee does not segment the facility based on enrichment. Materials License SNM-1097 is amended to prohibit the segmentation of the facility by license condition S-7:

The licensee shall control the entire fuel fabrication facility to safely process enrichments up to 8.0 wt.% U-235 and shall not segment the facility based on enrichment.

Operational Readiness Review The NRC staffs review of the LAR finds reasonable assurance of subcriticality under normal and all credible abnormal conditions, finds reasonable assurance of adequate protection against the risk of criticality accidents, and finds that the licensee satisfies the applicable requirements of 10 CFR Part 70, including 10 CFR 70.61(b) and 70.61(d). However, the NRC staff is requiring an operational readiness review (ORR) be completed as a condition to the approval of the LAR because of the higher enrichment of U-235 and its potential impact on licensed activities at the facility. The NRC staff amends Materials License SNM-1097 with license condition S-8:

Except for the special nuclear material authorized under Items 6.B, 6.C, 7.B, 7.C, 8.B, and 8.C of Materials License SNM-1097, GNF-A shall not receive, possess, handle, store, or process any special nuclear material in excess of 5.0 wt. %

U-235 until the NRC completed an operational readiness review that verifies the facility will be operated safely and in accordance with the requirements of Material License SNM-1097. GNF-A will notify the NRC at least 120 days prior to the receipt of special nuclear material in excess of 5 wt. % U-235, other than special nuclear material authorized in Items 6.B and 6.C.

The NRC staff concludes that the licensees request provides reasonable assurance of subcriticality under normal and all credible abnormal conditions, provides reasonable assurance of adequate protection against the risk of criticality accidents, and satisfies the applicable requirements of 10 CFR Part 70, including 10 CFR 70.61(b) and 70.61(d).

2.4 Chemical Process Safety The purpose of this chemical process safety review is to determine if the GNF-A commitments and planned modifications to its facility and operations for the processing of 8

material with up to 8.0 wt. % U-235 enrichment provide reasonable assurance of adequate protection of workers, the public, and the environment from chemical hazards that are under NRCs regulatory jurisdiction.

This review evaluated the LAR to determine compliance with the requirements of 10 CFR 70.22 and 70.65 which identify the general and additional contents of the application. The review also evaluated the application against the requirements of 10 CFR 70.23 and 70.66 which identify the requirements for approval of applications.

In particular, the NRC staffs review of chemical process safety determines if there is reasonable assurance that GNF-A facility modifications and operational changes for processing material up to 8.0 wt. % U-235 enrichment provide reasonable assurance of compliance with the chemical safety requirements contained in 10 CFR 70.61, 70.62, and 70.64.

This review focused on chemical hazards that are under NRCs regulatory jurisdiction as provided in the memorandum of understanding (MOU) between NRC and the Occupational Safety and Health Administration. The most recent update of this MOU was issued in 2013 (ML11354A432).

The acceptance criteria the NRC staff applied in its review of chemical process safety are in Section 6.4.3 of NUREG-1520, Revision 2.

The NRC staffs review of chemical safety focused on (1) the adequacy of the GNF-A chemical safety program commitments that support chemical safety (i.e., the identification and management of chemical hazards that are under NRCs regulatory jurisdiction) and (2) the GNF-A implementation of the chemical safety-related commitments as they relate to the processing of material that is enriched up to 8.0 wt. % U-235.

Review of Chemical Safety Program 10 CFR 70.62(a) requires a licensee to establish a safety program that will adequately protect the worker, public health and safety, and the environment from the chemical hazards of licensed material.

The current GNF-A license is for possession and use of 5 % enriched material and was renewed in 2009. The NRC staffs review for the 2009 renewal considered commitments related to chemical safety including:

  • Assignment of chemical safety responsibility to area managers and shift supervisors.
  • Identification of minimum qualifications for the individual responsible for the chemical safety function.
  • Inclusion of chemical safety in the charter of the Wilmington Safety Review Committee.
  • Development and maintenance of Process Safety Information that includes chemical safety information.
  • Implementation of a defined ISA process that includes consideration of chemical safety.
  • Implementation of an ISA change management process that includes consideration of chemical safety.

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  • Inclusion of chemical safety expertise on the ISA team.
  • Implementation of its Chemical Safety Program (Chapter 6 of the application) that includes commitments related to ISA, employee training, and incident investigation.
  • Conduct of audits and assessments of the chemical safety program.
  • Conduct of incident investigations for chemical safety events.

The NRC staff reviewed the chemical safety program as part of the 2009 license renewal process and found it to be acceptable. The safety evaluation report documented the NRC staffs review of the GNF-A chemical safety program along with other safety issues.

(ML091000554).

The GNF-A application submitted for the license amendment to authorize the production of fuel with 8.0 wt. % U-235 enrichment maintains the previous commitments related to chemical safety including keeping the ISA up to date and complying with the chemical safety commitments made in Chapter 6 of the application.

Review of changes to support chemical safety while processing 8.0 wt. % U-235 enriched material The application to produce fuel with up to 8.0 wt. % U-235 enrichment was accompanied by the ISA summary that discussed and evaluated the proposed changes that are to be implemented.

The NRC staff reviewed the proposed changes, most of which were related to criticality safety. The ISA summary identified changes in the radwaste treatment system that were discussed in section 5.19.

To better understand these changes and their potential impact on chemical safety, the NRC staff examined GNF-A documents that presented the quantitative risk assessment (QRA) for the current radwaste and waste treatment facility as well as the draft QRA for the planned changes to this system. The planned changes identified in the documents were the elimination of some non-geometrically favorable tanks and the introduction of new geometrically safe waste tankage. The liquid waste treatment system involves neutralization, precipitation, and filtration of the wastewater. There were no changes in the basic processes used in the liquid waste treatment system that would introduce new chemical hazards.

After reviewing this material, the NRC staff agreed with the GNF-A conclusion that there are no changes to the existing acute chemical exposure accident sequences and no changes required to items relied on for safety that prevent or mitigate chemical accident sequences.

The NRC staff concludes that continued compliance with the existing license commitments related to chemical safety will continue to provide reasonable assurance of adequate protection of health and minimization of danger to life and property from chemical hazards that are under NRCs regulatory jurisdiction. Continued compliance will also provide reasonable assurance that the performance requirements of 10 CFR 70.61 related to acute chemical exposure will be met.

Preparation of the ISA summary demonstrates compliance with the existing license commitments. The ISA summary results support the finding that there is reasonable 10

assurance the proposed 8.0 wt. % U-235 enriched material processing operations will comply with the chemical safety performance requirements of 10 CFR 70.61.

The NRC staff agrees with the GNF-A conclusion that there are no new chemical hazards that would be introduced because of the planned changes to process 8.0 wt. % U-235 enriched uranium. The NRC staff agrees that the dominant chemical hazards will continue to be those associated with releases of uranium hexafluoride (UF6) and hydrogen fluoride (HF).

These hazards will not change because of processing higher enriched material.

Based on the NRC staffs review, the NRC staff finds that the proposed changes, related to chemical safety at the GNF-A facility, in the amendment request to process 8.0 wt. % U-235 enrichment material are acceptable, and that the facility remains in compliance with the chemical safety requirements contained in 10 CFR 70.61, 70.62, and 70.64.

2.5 Fire Safety The primary purpose of this fire safety review is to determine if the licensees planned facility modifications and operational changes to support the processing of material with up to 8.0 wt.% U-235 enrichment, as described in the LAR, will provide reasonable assurance of adequate fire protection of workers, the public, and the environment from fire hazards that are under NRCs regulatory jurisdiction.

The NRC staffs review evaluated the LAR to determine whether GNF-As application complies with the requirements for the contents of an application in 10 CFR 70.22 and 70.65. The review also considers compliance with the requirements in 10 CFR 70.23 and 70.66 which identify the information that is required in an application in order to be approved by the NRC staff. The fire safety review determines if reasonable assurance of compliance with fire safety requirements of 10 CFR 70.61, 70.62, and 70.64 has been demonstrated in the LAR. This review also refers to Chapter 7 of NUREG-1520, Revision 2, as NRC staff guidance in fire safety.

The acceptance criteria for the NRCs review of fire safety are outlined in Section 7.4.3 of NUREG-1520, Revision 2. The National Fire Protection Association (NFPA) National Fire Codes are also used, as appropriate, to evaluate a reasonable assurance of fire safety.

The application was submitted with a revised ISA summary for the proposed changes that would be implemented if the amendment were approved.

The NRC staffs fire safety review has focused on (1) the adequacy of the commitments that support fire safety (e.g., the identification and management of fire hazards that are under NRCs regulatory jurisdiction) and (2) the implementation of the fire safety-related commitments to support processing of 8.0 wt. % U-235.

Review of Fire Safety Program For the proposal in this LAR to process 8.0 wt. % U-235, the NRC staff reviewed the applicants commitments related to fire protection (Chapter 7) of the current GNF-A license, including specifically:

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Site fire hazard analyses Facility design and building construction Process fire safety (e.g., hot work permit)

Use and storage of combustible and flammable material Fire protection and detection systems (e.g., sprinklers, alarms, fire-extinguishers, hydrants)

Fire evacuation training and drill practice of workers Fire emergency response team (e.g., organization, qualification, training)

Fire safety management (e.g., maintenance program, internal quarterly audits, routine self-assessment)

Cooperation/agreements with local authorities (e.g., fire department, police department)

The NRC staff reviewed the fire safety program approved as part of the 2009 license renewal process during the current LAR review and finds it applicable. The NRC staff also reviewed to Chapter 7 of the 2009 SER (ML091000554), which documented the NRC staffs review of the GNF-A fire safety program and other safety issues and finds them applicable to the current LAR. The NRC staff determined that the GNF-A application, submitted for the license amendment to authorize the production of 8.0 wt. % U-235 fuel, continues to maintain the previous commitments related to fire safety including keeping the ISA up to date and complying with the fire safety commitments made in Chapter 7 of the application.

Review of Changes to Support Fire Safety for 8.0 wt. % Fuel Fabrication The LAR states that the increase in enrichment from 5.0 wt. % to 8.0 wt. % U-235 does not require changes to GNF-As fire safety commitments in (1) fire protection to facility design and building construction, (2) process fire safety, (3) the fire protection and detection systems, and (4) the combustible control program. Therefore, an additional fire hazards analysis is not necessary.

The LAR states that the enrichment increase from 5.0 wt. % to 8.0 wt. % U-235 will not result in modifications to the fire safety organization, management, or program. The applicant will continue to maintain a Fire Emergency Response Team, made up of employees trained in fire-fighting techniques, first aid procedures, and emergency response as well as a Mutual Aid agreement with the local fire department for response to plant fires that escalate beyond the sites ability to handle.

After reviewing information in the LAR and information in the ISA summary, as well as comparing information presented in ISA summary for the current 5.0 wt. % enrichment with information presented in ISA summary for the proposed 8.0 wt. % enrichment, the NRC staff has the following findings which are related to fire safety:

The Fuel Manufacturing Operation building still meets the building code and Factory Mutual requirements for fabrication of the 8.0 wt. % U-235 fuel.

The fire hazards, accident sequences and mitigating IROFS, identified in Sections 5.1 through 5.27 of the ISA summary for the 5.0 wt. % U-235 fuel 12

fabrication, are still applicable for the 8.0 wt. % U-235 fuel fabrication and there are no new fire hazards and no need for new or revised fire IROFS.

There are no significant changes in fire protection and detection systems which are a function of facility design and processes and are not directly influenced by enrichment level.

There are no significant changes needed in training and emergency response which were developed per facility design and processes and are not significantly influenced by the enrichment level.

For these reasons, the NRC staff finds that GNF-As facility continues to maintain an adequate level of fire protection and the fire protection program is consistent with the criteria in Chapter 7 of NUREG-1520, Revision 2, for fabrication of the 8.0 wt. % U-235 fuel. The NRC staff also finds (1) that the updated ISA summary provides reasonable assurance of compliance with NRCs applicable regulations, and (2) that the fire safety program approved in the SER prepared for the 2009 license renewal is also still acceptable for this LAR.

The NRC staff determined that there are no new fire hazards and therefore, new or revised IROFS are not needed. In addition, the NRC staff finds that the facility, including equipment, operations, protection/detection systems, training, and emergency response provisions, as described in the LAR, will continue to provide reasonable assurance that adequate fire protection will be provided and maintained for fabrication of the 8.0 wt. % U-235 fuel to meet the fire safety performance requirements of 10 CFR 70.61.

2.6 Environmental Protection The activities authorized under the GNF-A license must comply with the NRCs regulations, including 10 CFR 20, Subpart C, Occupational Dose Limits for Adults, and 10 CFR 20, Subpart D, Radiation Dose Limits for Individual Members of the Public and with conditions specified in the Materials License SMN-1097 for operation of the facility.

The licensee has committed to adequate environmental-protection measures, including: (1) environmental and effluent monitoring; and (2) effluent controls to maintain public doses as low as is reasonably achievable (ALARA) as part of the radiation protection program. As part of the license renewal process in 2009, GNF-A provided NRC an Environmental Report Supplements dated March 30, 2007 (ML071000137 and ML071000144). The NRC reviewed this information and issued an Environmental Assessment (ML0911180239) on May 14, 2009, in support of the proposed license renewal.

As such the environmental protection program has been previously reviewed and approved by the NRC. The NRC staff concludes, with reasonable assurance, that the licensees conformance to the application and license conditions is adequate to protect the environment and public health and safety and to comply with the regulatory requirements imposed by the NRC in 10 CFR Part 20, 10 CFR Part 51, and 10 CFR Part 70.

The NRC staffs previous environmental reviews considered the impacts of the GNF-A facilities. The exposure pathways that could affect the public include direct irradiation, airborne effluents, and liquid effluents from the GNF-A facility. Direct irradiation levels are taken by measuring gamma radiation exposure at the GNF-A site boundary and were found to be indistinguishable from background readings in the GNF-A license renewal 13

Environmental Report supplement dated March 30, 2007 (ML071000137). Following a higher radiation reading in 2021, the Model 30B cylinder storage pad was moved away from the fence line to reduce exposure levels (ML22278A155). Readings taken in 2022 demonstrated that the levels are once again indistinguishable from background.

Several effluent treatment systems are in place at GNF-A, as well as an effluent monitoring program to ensure that potential releases to the environment are within federal and state regulations and are maintained ALARA. GNF-A sources of radioactive liquid and airborne effluents are controlled and monitored, and monitoring data have verified the controls effectively limit radioactive releases to below regulatory limits ((ML071000137). The most likely public exposure pathway is by inhalation of airborne effluents. Calculated annual radiological doses to the public from GNF-A operations from 1995 to 2005 were at most approximately 4 percent of the 0.1 mSv [10 mrem] annual dose limit from 10 CFR 20.1101 for air emissions of radioactive material. Using data from the most recent semi-annual effluent monitoring report, dated August 15, 2022 (ML22227A048), the calculated approximate public annual dose is 0.5 percent of the 0.1 mSv [10 mrem] annual dose limit due to air emission. If this estimate is adjusted for up to 8.0 wt. % U-235 the approximated dose due to air emissions would increase to 0.84 % (0.00084 mSv [.084 mrem]) of the 0.1 mSv [10 mrem] annual dose limit (ML22278A155). As stated in the GNF-A response (ML22278A155) to NRCs request for supplemental information (RSI), airborne and liquid effluents are below and anticipated to remain below regulatory limits in 10 CFR Part 20 for radiological contaminants. Also, the licensee indicated that over the past decade there have been additional reductions in many of these results (ML23209A676).

The request to increase the enrichment to 8.0 wt. % U-235 will not result in any significant modifications that would effect changes to the radiation protection program described in Chapter 4 of the 2009 SER (ML091000554). Current practices and processes are sufficient to contain the uranium and ensure exposures to personnel and the environment are maintained ALARA.

Based on the public and occupational health information reviewed, the radiological environmental impacts due to the proposed license amendment would not be significant.

Therefore, the NRC staff finds that the request to increase the enrichment to 8.0 wt. %

U-235 will not cause a significant change 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.

2.7 Financial Assessment (Decommissioning)

Nuclear facilities licensed under 10 CFR Part 70 are required to provide adequate financial assurance for decommissioning, decontamination, and reclamation pursuant to 10 CFR Section 70.25, Financial Assurance and Recordkeeping for Decommissioning. GNF-A (or the licensee) is the holder of SNM-1097. Pursuant to 10 CFR 70.25(e)(2), GNF-A is required to submit a decommissioning cost estimate (DCE) and financial assurance at least every 3 years for the U.S. Nuclear Regulatory Commission (NRC) review and approval. GNF-A submitted an updated DCE dated March 23, 2022 (ML22084A578), as required by 10 CFR 70.25(e)(2).

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The NRC staff utilizes NUREG-1757, Volume 3, Revision 1, Consolidated Decommissioning Guidance Financial Assurance, Recordkeeping, and Timeliness, (ML12048A683) as guidance to evaluate the DCEs submitted by 10 CFR Part 70 licensees.

GNF-A remains responsible for the status and future decommissioning of the licensed site and facility; will continue to abide by all commitments and representations previously made to the NRC; and will continue to abide by all constraints, conditions, requirements, representations, and commitments identified in the license. As required by 10 CFR 70.25(e)(2), GNF-A must continue to submit an updated cost estimate for decommissioning for the NRCs review at intervals not to exceed 3 years. After resolution of any NRC comments on the estimate, GNF-A will submit, as necessary, revised financial instruments reflecting an amount sufficient to cover the approved cost estimate. GNF-A remains liable for any decommissioning costs not covered by the financial instrument.

The Decommission Funding Plan (DFP) was submitted by letter dated October 4, 2022 (ML22277A540). The DCE, included in the DFP, documents the total cost of decommissioning as $289,952,966, including a 25 percent contingency factor of

$57,990,593.

GNF-A previously submitted a DCE dated October 1, 2019 (ML19274C651), which was approved on January 14, 2020 (ML20008D389). During the review the NRC staff discussed GNF-As plans for the disposition of inventory during decommissioning. GNF-A stated that all inventory would be processed and taken off site prior to decommissioning, or the owner of the inventory would be responsible for removing any inventory prior to decommissioning.

The NRC staff found the DCE acceptable as it meets the regulatory requirements of 10 CFR 70.25(e). Specifically, the GNF-A submittal: 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.

Further, the October 4, 2022, submittal addresses the following:

Spills of radioactive material:

The 2022 DCE describes 3 areas on the site where uranium and associated constituents have been identified in soil and groundwater and how the costs for remediating these areas are included in the DCE (pages 4.5 - 4.6).

Waste inventory increases:

The 2022 DCE states waste volumes are reviewed and updated every 5 years as necessary (page 7.1). Table 6.8 of the 2022 DFP reflects increases in waste volumes since GNF-As 2019 DFP and associated increases in decommissioning costs (page 6.10). NRC staff issued an RAI regarding the licensee updating waste disposal costs every five years as 10 CFR 70.25 (2) requires costs to be updated at least every three years. The licensee responded to the RAI indicating, it updates disposal costs annually based on inflation and approximately every five years the waste disposal costs are rebase-lined by an independent contractor. The NRC staff found this response acceptable as it meets the 10 CFR 70.25 (2) requirement to update costs every three years.

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Waste disposal cost increases:

The 2022 DCE states changes in waste categories, waste disposal options, and waste disposal rates are reviewed and updated every 5 years as necessary (page 7.1). For example, Table 6.8 of the 2022 DFP includes updates to the waste burial cost per cubic foot since GNF-As 2019 DFP (page 6.10). The NRC staff issued an RAI regarding the licensee updating waste disposal costs every five years as 10 CFR 70.25 (2) requires costs to be updated at least every three years. GNF-A responded to the RAI indicating, it updates disposal costs annually based on inflation and approximately every five years the waste disposal costs are rebase-lined by an independent contractor. The NRC staff found this response acceptable as it meets the 10 CFR 70.25 (2) requirement to update costs every three years.

Facility modifications:

The 2022 DCE states that the status of any ongoing or planned facility modifications is reviewed and updated annually as necessary (page 7.1).

Changes in authorized possession limits:

GNF-As authorized possession limits have not changed relative to GNF-As DFP submitted on October 1, 2019 (page 1.2); therefore, there are no associated effects on the DCE.

Actual remediation costs that exceed the previous cost estimate:

The 2022 DCE states the cost estimate is updated to reflect completed decommissioning activities annually as necessary, and the 2022 submittal did not include any updates based on remediation costs incurred (page 8.1).

Onsite disposal:

The 2022 DCE describes the process for handling and disposing of waste offsite. Therefore, no onsite disposal costs are included in the DCE (pages 2.3 - 2.5).

Use of a settling pond:

The DCE does not explicitly mention use of a settling pond. The 2022 DCE does state that effluent from the radioactive waste treatment system and laundry water are included in the combined process wastewater treatment system for final precipitate settling and pH adjustment prior to discharge in accordance with permit requirements (page 2.5.). The DCE also describes the remediation of a final process lagoon area (page 4.5).

Based on the review of the March 23, 2022, DCE and the October 4, 2022, DFP submittals, the NRC finds the submitted DCE is based on reasonable and documented assumptions, and that it reasonably estimates the cost, at this time, to decommission the facility.

Accordingly, the NRC considers GNF-As 2022 DCE satisfies the requirements of 10 CFR 70.25(e) and is generally consistent with NUREG-1757, Volume 3, Revision 1.

Therefore, the NRC concludes that GNF-As 2022 DCE of $289,952,966 is acceptable.

GNF-A shall, as necessary, revise its financial assurance mechanisms and Certification of 16

Financial Assurance and submit these for the NRC review. GNF-A has indicated it will provide this in an upcoming submittal.

The NRC staff concludes there is reasonable assurance the proposed 2022 DCE would continue to provide adequate protection of public health, safety, safeguards, security, and the protection of the environment. Therefore, 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 instrument(s).

2.8 Material Control and Accounting The purpose of this review is to determine whether the proposed license amendment request to permit nuclear fuel fabrication at material enrichments up to 8.0 wt. % U-235 as referenced in the submittal will not result in any significant impact from a safeguards perspective.

As specified in 10 CFR 70.22(b), each licensee authorized to possess and use special nuclear material (SNM) in a quantity exceeding one effective kilogram must provide a full description of its program for material control and accounting (MC&A) of such SNM to show how compliance with applicable requirements of 10 CFR Part 74, Material Control and Accounting of Special Nuclear Material, will be accomplished. Regulations in 10 CFR Part 74 Subpart B, General Reporting and Recordkeeping Requirements, and in 10 CFR 74.31, Nuclear Material Control and Accounting for Special Nuclear Material of Low Strategic Significance, apply to the establishment of an MC&A program for Category III fuel fabrication facilities. The requirements in 10 CFR 74.31 cover the specific MC&A program capabilities needed to establish an acceptable MC&A program. Category III fuel fabrication facilities are required to have a fundamental nuclear material control plan (FNMCP) describing how the performance objectives in 10 CFR 74.31(a), the system capabilities of 10 CFR 74.31(c) and the recordkeeping requirements of 10 CFR 74.31(d) will be met.

The NRC regulatory guidance for an acceptable MC&A program applicable to Category III fuel fabrication facilities is NUREG-1065, Acceptable Standard Format and Content for the Fundamental Nuclear Material Control (FNMC) Plan Required for Low-Enriched Uranium Facilities. The NUREG is divided into separate chapters for each of the program areas listed with associated commitments and acceptance criteria for each program area.

The NRC staff reviewed the LAR regarding specific MC&A impacts of the increase in the enrichment level up to 8.0 wt. % U-235. The licensee stated that the MC&A function evaluated the proposed amendment and commits that changes to the policies, procedures, and controls to support the amendment will be implemented consistent with the existing MC&A program. Additionally, the licensee stated that the FNMCP in place will continue to satisfy the applicable requirements of 10 CFR Part 74. The NRC staff reviewed the currently approved FNMCP, Revision 22, dated October 1, 2021, as required by 10 CFR 70.22(b).

The FNMCP describes the licensees MC&A program and demonstrates how the licensee complies with the requirements the applicable general recordkeeping and reporting requirements 10 CFR Part 74, Subpart B and of 10 CFR 74.31 with respect to the possession and use of SNM of low strategic significance.

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The NRC staff determined additional information was needed to complete the review. On July 3, 2023 (ML23156A183), the NRC staff sent a request for additional information (RAI) to the licensee. By cover letter dated July 28, 2023 (ML23209A676), the licensee provided a response to the RAI. In the response, the licensee stated that no changes are required to the FNMCP or the MC&A program for an increase in the enrichment level up to 8.0 wt. %

U-235. Additionally, the licensee stated that minor software changes will be needed to internally track and report quantities up to 8.0 wt. % U-235. A discussion was held on August 31, 2023, with the licensee to discuss the response to the RAI. The licensee provided additional information (ML23244A181) regarding the potential minor changes related to measurement control and reporting software that clarified the response to the RAI.

Based on the review of the submittal, the FNMCP, the RAI response, and the clarification discussion, the NRC staff has determined that the proposed license amendment to permit nuclear fuel fabrication at material enrichments up to 8.0 wt. % U-235 will not result in any significant impact from a safeguards perspective. The licensees MC&A program as described in the approved FNMCP will continue to provide reasonable assurance that loss, theft, or diversion of SNM will be detected and protected against. The NRC staff finds that the licensee continues to meet the applicable MC&A requirements in 10 CFR Part 74, the 10 CFR 70.23(a)(6) requirement for approving applications has been met, and therefore recommends approval of the proposed license amendment request based upon the licensees commitment that changes to the policies, procedures, and controls related to the MC&A program will be implemented consistent with the existing MC&A program and FNMCP. This includes: (1) acquiring a new isotopic standard to cover the new enrichment range; (2) evaluating the statistical and analytical calculations to determine direct impacts of the increased enrichment level; and (3) analyzing potential changes to software to handle inventory and nuclear material transaction reporting.

3.0 ENVIRONMENTAL REVIEW The NRC staff conducted an environmental review in accordance with the requirements in 10 CFR Part 51. The NRC staff determined that approval for GNF-A to fabricate nuclear fuel using higher enriched U-235 would not significantly affect the quality of the human environment.

In conducting the review, the NRC staff independently evaluated information regarding the affected environment as well as activities associated with the proposed license amendment with the potential to result in new or significant environmental impacts on the affected environment.

The NRC staff determined the proposed action would not impact the following resources areas:

land use, geology and soils, water resources, ecology, meteorology, climate, air quality, noise, transportation, visual and scenic resources, and socioeconomic resources. This determination was based on the following: (1) the licensee would continue to conduct fuel fabrication activities within existing facilities; (2) the proposed action would not result in any additional land disturbing activities, increases in staffing, or changes in the number of number of shipments of special nuclear material or quantity of waste generated at the site; and (3) liquid and air effluents would remain below regulatory limits in 10 CFR Part 20.

The licensee also committed to taking adequate environmental protection measures for the use of 8.0 wt. % U-235 in their facilities, including (1) environmental and effluent monitoring, and (2) effluent controls to maintain public doses as low as reasonably achievable as part of the radiation protection program. For these reasons, the NRC staff finds reasonable assurance that 18

the licensees conformance to the application is adequate to protect the environment, and the health and safety of the public.

The NRC staff finds that approval of the proposed action will result in no significant radiological or non-radiological impacts. Occupational dose estimates associated with the proposed action are expected to be ALARA and within the limits identified in 10 CFR 20.1201. Approval of the proposed action is not expected to result in measurable radiation exposure to a member of the public. Approval of the LAR would not result in construction or land disturbance activities. the NRC staff finds that pursuant to 10 CFR 51.31, the preparation of an environmental impact statement is not required for this proposed action. Therefore, the NRC staff determines that a finding of no significant impact is appropriate (ML23291A150).

4.0 CONCLUSION

The NRC staff reviewed the licensees LAR together with supporting analyses and responses to the NRC staffs RAIs. The NRC staff concludes that the licensees request provides reasonable assurance that the current ISA program, radiation program, nuclear criticality program, chemical safety program, fire safety program, MC&A program, and environmental protection program satisfy the applicable requirements of 10 CFR Parts 19, 20, 51, 70, and 74, as stated in this report. Additionally, the licensee reasonably estimates the cost to decommission the facility.

The NRC staff approves this license amendment request to permit nuclear fuel fabrication at enrichments up to 8.0 wt. % U-235. Materials License SNM-1097 is amended by modifying Item 6.A from 5 percent to 8 percent U-235, by modifying Item 6.C from >5% to <10% to >8% to

<20% U-235, and by the addition of License Conditions S-7 and S-8 as follows:

S-7. The licensee shall control the entire fuel fabrication facility to safely process enrichments up to 8.0 wt.% U-235 and shall not segment the facility based on enrichment.

S-8. Except for the special nuclear material authorized under Items 6.B, 6.C, 7.B, 7.C, 8.B, and 8.C of Materials License SNM-1097, GNF-A shall not receive, possess, handle, store, or process any special nuclear material in excess of 5.0 wt. % U-235 until the NRC completed an operational readiness review that verifies the facility will be operated safely and in accordance with the requirements of Material License SNM-1097. GNF-A will notify the NRC at least 120 days prior to the receipt of special nuclear material in excess of 5 wt. % U-235, other than special nuclear material authorized in Items 6.B and 6.C.

Also, Items 7.B and 7.C of Materials License SNM-1097 are being revised to clarify and add detail on the authorized use of the specified forms of U-235 indicated in relationship to Items 6.B and 6.C.

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5.0 PRINCIPAL CONTRIBUTORS The individuals and organizations listed below are the principal contributors to the preparation of this SER:

Jeremy Munson, NMSS Lisa Pope, NMSS Eli Goldfeiz, NMSS James Hammelman, NMSS Jimmy Chang, NMSS Suzanne Ani, NMSS Brian Wagner, NMSS Rao Tammara, NMSS Donald Palmrose, NMSS Jean Trefethen, NMSS 20

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