ML24263A214
| ML24263A214 | |
| Person / Time | |
|---|---|
| Site: | 07007004 |
| Issue date: | 09/20/2024 |
| From: | NRC/NMSS/DFM/FFLB |
| To: | American Centrifuge Operating |
| Shared Package | |
| ML24068A189 | List: |
| References | |
| EPID L-2023-LLA-0024 | |
| Download: ML24263A214 (1) | |
Text
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 1
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION SAFETY AND SECURITY EVALUATION REPORT DOCKET NO.:
70-7004 LICENSE NO.:
SNM-2011 LICENSEE:
American Centrifuge Operating, LLC (ACO)
SUBJECT:
ASSESSMENT OF AMERICAN CENTRIFUGE OPERATINGS POSSESSION LIMIT INCREASE NEEDED FOR ITS HIGH-ASSAY LOW-ENRICHED URANIUM OPERATIONS PROGRAM AT THE AMERICAN CENTRIFUGE PLANT (ACP) IN PIKETON, OHIO (EPID NO. L-2023-LLA-0024) 1.
INTRODUCTION On February 13, 2023, ACO submitted a license amendment request (LAR) (Agencywide Document Access and Management System Accession No. ML23047A089) to increase its possession limits associated with an increase of high-assay low-enriched uranium (HALEU) production from the currently approved [REDACTED] to [REDACTED] until ACOs current HALEU operations contract expires. The current expiration date is December 31, 2024. The U.S. Nuclear Regulatory Commission (NRC) accepted the application for detailed technical review on April 13, 2023 (ML23086A088).
This Safety and Security Evaluation Report (SER) presents the staffs evaluation of ACOs HALEU operations program possession limit increase and the associated (1) analysis for determining that an emergency plan continues to be not warranted, (2) financial qualifications, decommissioning financial assurance, and nuclear insurance and indemnity requirements, and (3) physical security requirements for the protection of special nuclear material (SNM).
- 2.
ANALYSIS FOR DETERMINING AN EMERGENCY PLAN IS NOT WARRANTED 2(a)
REGULATORY REQUIREMENTS The regulations in Title 10 of the Code of Federal Regulations (10 CFR) 70.22(i) require that applications contain either (1) an evaluation showing that the maximum dose to a member of the public offsite due to a release of radioactive material would not exceed 1 rem effective dose equivalent (EDE) or an intake of 2 milligrams (mg) of soluble uranium (section (i)(1)(i)), or (2) an emergency plan (section (i)(1)(ii)).
2(b)
REGULATORY GUIDANCE AND ACCEPTANCE CRITERIA The guidance for NRC staffs review of the evaluation of the maximum dose to a member of the public offsite is contained in Chapter 8 of the Standard Review Plan for the Review of a License Application for a Fuel Cycle Facility, NUREG-1520, Revision 2 (ML15176A258). The specific NRC guidance for assessing whether an emergency plan is required at a fuel cycle facility is presented in Section 8.3.2. The regulatory acceptance criteria for the review of the evaluation are presented in Section 8.4.3.2. The review procedure is presented in Section 8.6.2.2.2(c).
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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION 2(c)
STAFF REVIEW AND ANALYSIS In June 2021, the NRC issued a license amendment for ACOs HALEU demonstration program at the ACP that allowed production of up to [REDACTED]. Chapter 8 of the NRC staffs 2021 SER (ML21148A291) and its Appendix E ([REDACTED]), which were issued as part of the NRCs June 2021 amendment approval, assessed ACOs analysis. The NRC staff determined the 10 CFR 70.22(i)(1)(i) threshold dose of 1 rem EDE and an intake of 2 mg uranium in soluble form at the site boundary were not exceeded. The SER concluded ACO met the criteria of 70.22(i)(1)(i) and that an emergency plan was not required for the HALEU demonstration program operations involving possession and use of up to [REDACTED].
The current ACO license amendment seeks approval to possess and use [REDACTED] during the proposed phase of the HALEU operations program, for the duration of the contract between the Department of Energy (DOE) and ACO that ends on December 31, 2024. This proposed operation with higher HALEU production would continue to utilize the 16-machine AC-100M HALEU cascade.
The NRC staff issued a request for additional information (RAI) dated June 8, 2023 (see forwarding email ML23146A110, public) regarding ACOs evaluation of no need for an emergency plan for the HALEU demonstration. On June 22, 2023, ACO responded by supplementing its LAR with a revised evaluation, DAC-3901-0005, Rev. 6, Evaluation of No Need for an Emergency Plan for the HALEU Demonstration, (see forwarding letter ML23187A143, public). The RAI response supports ACOs position that an emergency plan continues to be not required for the proposed increase in licensed material possession limits to support production of approximately 1,400 kg of HALEU in the form of UF6.
Section 2 of ACOs evaluation describes the HALEU facility and its proposed operations.
Section 3 of the ACO evaluation provides information on the types of accidents evaluated.
Section 4 of the evaluation discusses detection of accidents. Section 5 of the evaluation analyzes the maximum public exposure for the accidents identified by ACO.
The NRC staff reviewed the information presented in the ACO evaluation against the six acceptance criteria in Section 8.4.3.2 of NUREG-1520: (1) the description of the facility, (2) the types of materials used, including both radioactive material and hazardous chemicals, (3) the types of accidents, (4) the detection of accidents, (5) site-specific information used to support the evaluation and (6) the evaluation of the consequences.
2(c)(1) Description of the Facility and Materials Used Section 2 of the ACO evaluation contains the site and facility description, including a description of the site and the major facilities used for the proposed phase of the HALEU operations program. The processing and storage of UF6 for the proposed phase of the HALEU operations program, which occurs primarily in the process area of the X-3001 building, is described. The ventilation systems for the buildings are described. The section also describes various support buildings and the potential hazards in these buildings. ACO describes the operations involving UF6, which are primarily cylinder handling, enrichment with feed and withdrawal operations, and UF6 sampling. The HALEU operations program does not use aqueous, or scrap recovery
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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION options in operations. ACO has minimized the use of combustible material in the buildings and in operations involving uranium. Although some operations involve the handling of centrifuge components and the assembly/disassembly of centrifuges, these do not involve uranium.
The description of facility and materials used in the ACOs proposed phase of the HALEU operations program meets the acceptance criteria identified in Section 8.4.3.2.1 of NUREG-1520; the amendment request includes a detailed drawing of the site including major facilities and site boundaries; stack height and flow rates; and a description of other activities conducted at the site.
2(c)(2) Types of Accidents Section 3 of the ACO evaluation (Types of Accidents) identifies and discusses a range of accidents considered in the evaluation for the proposed phase of the HALEU operations program. The evaluation considered fire events, explosion events, loss of confinement events, external events, criticality events and natural phenomena events.
Section 3.1 of the evaluation discusses the ACO analysis of fire events [REDACTED]
The staff reviewed the accident identification and analysis and considered the accident scenarios to be reasonable and conservative given the nature of the proposed phase of the HALEU operations program, [REDACTED] to be appropriate.
[REDACTED], ACO did postulate in section 5.1 of the evaluation a bounding UF6 release
[REDACTED]. ACOs analysis noted that its bounding release quantity is consistent with historical [REDACTED] events.
The NRC staff reviewed the analysis and the basis for the bounding release scenario and finds them reasonable for the proposed phase of the HALEU operations program. The staff confirmed ACOs statement that the bounding release quantity is consistent with historical [REDACTED]
releases [REDACTED].
Sections 3.2 through 3.5 consider explosion events, loss of confinement events, external events and natural phenomena events [REDACTED]. ACOs assessment of these events concluded that only small releases (i.e., less than the bounding [REDACTED] release) would occur as a result of explosion events, such as from [REDACTED].
The staff reviewed the ACO examination of [REDACTED] and confirmed that these events would not result in credible [REDACTED] releases that are greater than the bounding release scenario.
Section 3.6 of the ACO evaluation discusses the potential for criticality events because the operations at the facility involve enriched material. The section discusses how controls are identified and implemented for ACO operations. Section 5.2 of the evaluation concludes that the maximum credible criticality event will not exceed [REDACTED] fissions.
The staff examined the proposed phase of the HALEU operations and concludes the estimates of a criticality event involving [REDACTED] fissions were properly calculated for the proposed
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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION activities. The proposed operations do not involve activities with the potential to produce a criticality event with a greater number of fissions (e.g., scrap recovery operations, solution processing).
The staffs assessment of the consequences of these potential accidents is presented in Section 4.4 of this SER.
Based on its review of the proposed phase of the HALEU operations program, the staff concludes that the ACO evaluation has adequately identified the credible accidents that could impact the offsite public and need to be evaluated in order to determine the need for an emergency plan.
2(c)(3) Detection of Accidents Section 4 of the revised ACO evaluation (Detection of Accidents) discusses the detection of accidents associated with the proposed phase of the HALEU operations program.
[REDACTED].
The discussion of detection of accidents in the updated evaluation complies with the acceptance criteria in Section 8.4.3.2.3 of NUREG-1520 and was determined to be acceptable.
2(c)(4) Evaluation of the Maximum Public Exposure Section 5 of the revised ACO evaluation (Evaluation of Maximum Public Exposure) discusses the public exposure from accidents. The accidents of concern involve UF6 releases and an accidental criticality. A criticality accident could result in both direct radiation and the release of material that could contribute to an offsite dose.
Evaluation of Consequences of UF6 Release The updated evaluation presented the analysis of the ACO bounding UF6 release of
[REDACTED] with a leak path factor (LPF) of [REDACTED]. The ACO evaluation reported the calculated dose at the site boundary as [REDACTED]) with an intake of soluble uranium of
[REDACTED].
The staff conducted an independent analysis to estimate the potential consequences to offsite individuals from moderate UF6 releases using the current Radiological Assessment System for Consequence Analysis (RASCAL) code (v4.3.4 Description of Models and Methods, NUREG-1940 Supplement 1, 2015).
The staff evaluated the consequences of the ACO release of [REDACTED] applying the same conservative meteorological conditions used in the ACO analysis [REDACTED]. The staff estimate of soluble uranium intake from a [REDACTED] was a factor of two higher than the ACO estimate of [REDACTED] soluble uranium, but fell well below the 2 mg limit specified in 10 CFR 70.22(i)(1)(i). The staff also analyzed other potential release scenarios given the uncertainty in the source term estimate. The NRC staffs independent analysis supports the
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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION conclusion that the consequences of credible [REDACTED] releases are less than a 1 rem EDE dose and soluble uranium intake of less than 2 mg.
Evaluation of Consequences of Criticality ACOs updated evaluation estimated the dose to an individual at the fence line as a result of (1) direct radiation, (2) inhalation, and (3) submersion. The estimated dose from direct radiation was [REDACTED], the estimated dose from inhalation was [REDACTED], and the estimated dose from submersion was [REDACTED] for a total EDE of [REDACTED]. ACO estimated the soluble uranium intake to an offsite individual following the criticality event as [REDACTED].
The NRC staff conducted an independent analysis of the consequences of a criticality accident discussed in ACOs revised evaluation (ML23187A143). The staffs independent analysis of the updated documentation was performed using RASCAL with the same conservative meteorology as used for the [REDACTED] consequence analysis. The NRC staff concludes the total dose to a receptor at [REDACTED], following a criticality event involving [REDACTED] fissions, was about [REDACTED] which is below the 1 rem threshold for requiring an emergency plan as stated in 70.22(i)(1)(i), and was comparable to ACOs estimate.
3.
FINANCIAL QUALIFICATIONS, DECOMMISSIONING FINANCIAL ASSURANCE, AND NUCLEAR INSURANCE AND INDEMNITY 3(a) REGULATORY REQUIREMENTS Under 10 CFR 70.25(a)(1), each applicant for a specific license for a uranium enrichment facility must submit either a decommissioning funding plan as described in paragraph (e) of that section or submit a certification of financial assurance in the amount prescribed in paragraph (d) of that section. Under 10 CFR 70.25(e), the funding plan must include a cost estimate of all decommissioning activities and a financial instrument that satisfies the requirements in paragraph (f) of that section. 10 CFR 70.25(f)(5), in turn, provides that financial assurance for decommissioning funding may be provided when a governmental entity is assuming custody and ownership of a site, an arrangement that is deemed acceptable by such governmental entity. The regulations in 10 CFR 140.13b require applicants for uranium enrichment facilities to provide and maintain nuclear liability insurance.
3(b) REGULATORY GUIDANCE AND ACCEPTANCE CRITERIA The NRC staff evaluated the applicants financial qualifications, and DOEs indemnification of ACOs decommissioning financial assurance and nuclear liability using NUREG 1520, Revision 2.
3(c)
STAFF REVIEW AND ANALYSIS 3(c)(1) Financial Qualifications The NRC staff previously reviewed ACOs financial qualifications for the production of HALEU through December 31, 2024, and found ACO financially qualified to continue its HALEU
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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION enrichment licensed activities at the ACP through December 31, 2024 (ML23083B961). As part of this review, the NRC staff confirmed that the ACOs contractual arrangements with the Department of Energy have not changed since the previous review. Therefore, the NRC staff finds that ACO continues to be financially qualified to continue its licensed activities under the HALEU authorization through December 31, 2024.
3(c)(2) Decommissioning Financial Assurance The NRC staff previously assessed whether ACO is required to provide decommissioning funding assurance. Amendment 3, Appendix 1 of the Gas Centrifuge Enrichment Plant (GCEP) lease agreement was signed on November 30, 2022, (ML22353A529). It includes language relevant to DOEs indemnification of decommissioning funding as follows:
The Department hereby assumes all liabilities for the decontamination and decommissioning of the facilities and equipment installed and any work performed, under the HALEU Ops Contract with the Department including any materials or environmental hazards on the site.
Therefore, ACO is not required to provide decommissioning funding assurance for the duration of its current HALEU operations contract with DOE.
3(c)(3) Nuclear Insurance and Indemnity ACO submitted Amendment 3 to Appendix 1 to the GCEP lease agreement and HALEU contract in the supplement to the LAR to demonstrate DOEs indemnification of nuclear liability for the duration of the HALEU contract, pursuant to the Price-Anderson Act. The NRC staff finds ACO remains in compliance with the liability insurance requirements in 10 CFR 140.13b because DOE continues to provide indemnity for the HALEU operations program.
4.
PHYSICAL SECURITY OF SNM The NRC staff reviewed the physical security plan for SNM1, dated April 2022, to determine if any additional supplemental security measures would be needed for the proposed increase in U-235 possession limit to ensure adequate protection of public health and safety and common defense and security. The NRC staff determined that vehicle barriers would be required in order to mitigate the potential for a vehicle-assisted gross theft. [REDACTED].
[REDACTED] ACO also proposed a new license condition (LC) (below) to require a vehicle barrier system and to limit the possession of U-235, until NRC validates the installation and function of the new vehicle barriers.
LICENSE CONDITION:
LC 30: ACO shall establish and maintain a Vehicle Barrier System in accordance with Section 3.7 of SP-3605-0042. Additionally, ACO shall not produce more than the authorized possession limits beyond those approved on June 11, 2021, until 1 The security plan contains safeguards information and is not publicly available.
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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION such time that the additional physical security measures have been installed and NRC has confirmed they meet the new commitments described within Section 3.7 of SP-3605-0042. Upon a successful NRC validation, ACO will be authorized to continue production efforts up to the authorized possession limits described in SNM-2011.
The NRC staff reviewed the proposed security plan changes and the proposed LC 30 and determined that they would adequately mitigate the potential for a vehicle-assisted gross theft of HALEU SNM.
5.
ENVIRONMENTAL REVIEW The NRC staff prepared an environmental assessment to determine whether there would be any significant environmental impacts associated with this amendment request (ML24254A206).
6.
EVALUATION FINDINGS Emergency Plan The NRC staff reviewed the ACO evaluation (ACO 2023b) to assess compliance with the requirements of 10 CFR 70.22(i)(1)(i). The staff review used the guidance in NUREG-1520. The staff finds that an emergency plan is not required for the proposed phase of the HALEU operations program because the maximum dose to a member of the public due to a release of radioactive materials would not exceed 1 rem EDE or an intake of 2 mg of soluble uranium for credible accidents associated with the project.
The NRC staff notes that although an emergency plan is not required by 10 CFR 70.22(i)(1)(i),
the DOE Portsmouth Site Emergency Plan provides emergency response capabilities at the entire DOE site, including ACOs operation at the HALEU facility. The NRC staff finds the additional protection provided by the DOE emergency plan demonstrates additional assurance that potential accidents during ACOs proposed phase of the HALEU operations program would have limited impact on the public.
Financial The NRC staff finds ACO appears to be financially qualified to continue its licensed activities under the HALEU authorization, is not required to provide decommissioning funding assurance, and remains in compliance with the liability insurance requirements in 10 CFR 140.13b through December 31, 2024, because of the DOEs indemnifications under its contract with ACO.
Physical Security of SNM The NRC staff finds that ACOs commitments in its physical security plan and commitment memorialized in LC 30 of License SNM-2011, Amendment 24, to establish and maintain a vehicle barrier system, will provide adequate protection of the SNM from a vehicle-assisted theft thereby ensuring adequate protection of public health and safety and common defense and security.
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OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION PRINCIPAL CONTRIBUTORS:
Jim Hammelman, NMSS/DFM Nicole Cortes, NMSS/DFM Tim Harris, NSIR/DPCP Trent Wertz, NMSS/REFS Yawar Faraz, NMSS/DFM