ML24264A171
ML24264A171 | |
Person / Time | |
---|---|
Site: | Framatome ANP Richland |
Issue date: | 09/20/2024 |
From: | Travis Tate Framatome |
To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
Shared Package | |
ML24264A170 | List: |
References | |
TJT:24:009 | |
Download: ML24264A171 (1) | |
Text
framatome September 20, 2024 TJT:24:009 Page 1 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Director, Office of Nuclear Material Safety and Safeguards Washington, DC 20555-0001
Subject:
License Amendment Request for TRISO Fuel Production at the Framatome Fuel Fabrication Facility in Richland, WA.
References:
- 1) Docket No. 70-1257; SNM-1227
- 2) Pre-Application NRC Presentation, July 12, 2023
Dear Sir,
Madam, Framatome hereby requests an amendment to the referenced license to authorize TRISO fuel fabrication in the Specialty Fuels Building at the Framatome Fuel Fabrication Facility in Richland, WA.
- 1.
Background and Submittal Scope Framatome is submitting this License Amendment Request (LAR) due to the new types of accident scenarios introduced by the addition of the TRISO fuel fabrication project to Framatomes existing licensed activities. See the discussion in section 4 of this letter for additional discussion on the regulatory basis for change. The LAR submittal includes the following documents (markups or in whole) as Attachment 1 through Attachment 4:
a) ATTACHMENT 1: SNM-1227, License Application Changes As discussed in Section 4 below, the License Application for Materials License SNM-1227 has been revised for the TRISO fuel fabrication process. For convenience, a mark-up copy showing affected license page changes with blue underlined lettering for insertions and red strikethrough for deletions is also included in this attachment.
Framatome has used NRCs previously approved safety analysis methodologies and NOS practices for establishing subcritical limits when evaluating the need for and the establishment of IROFS to support this submittal.
Chapter 1 General Information version 9.0 page 1-6 and version 8.0 page 1-6 is to be withheld as security related information per 10 CFR 2.390.
b) ATTACHMENT 2: Integrated Safety Analysis (ISA) Summary The new chemicals involved in the TRISO process are discussed in Part 1 of the ISA Summary, document E15-01-1 (Chapters 1-8).
framatome TJT:24:009 Page 2 The portion of Integrated Safety Analysis (ISA) Summary that addresses the TRISO fuel fabrication project scope and its specific safety related impacts is a revised Part II Chapter 2.11, document E15-01-2.11.The other chapters of the sitewide ISA Summary are not submitted as they have not changed and do not apply to the TRISO fuel fabrication processes.
These documents are to be withheld as proprietary information.
c) ATTACHMENT 3: Supplement to the Environmental Report Framatome had prepared an Environmental Report (ER) for the 2006 license renewal application, Supplement to Applicants Environmental Report September 2024, E06 002, Version 1.0. A Supplement to the ER evaluates the environmental impacts associated with the addition of the TRISO fuel fabrication project and documents changes to key information between 2006 and this submittal. As noted in section 4 Regulatory Evaluation below, Framatome has concluded that an Environmental Assessment is not needed, and that the amendment can be implemented using the identified categorical exclusion from 10 CFR 51.
This document is to be withheld as proprietary information.
d) ATTACHMENT 4: Impacts on the Decommissioning Cost Estimate The impact of the new process on decommissioning costs in the Specialty Fuels Building is described in Attachment 4. These impacts will be included in the next triennial update of the Decommissioning Funding Plan.
This document is to be withheld as proprietary information.
- 2.
Proposed Change The Framatome TRISO fuel fabrication project has been broken into the following process nodes for design and safety analysis development:
Node: System 690: Specialty Fuels - HALEU UF6 Cylinder Receiving & Storage Node: System 691: Specialty Fuels - HALEU Vaporization Node: System 692: Specialty Fuels - HALEU Powder Production Node: System 693: Specialty Fuels - HALEU Dry Conversion Liquid Effluent & HF Recovery Node: System 694: Specialty Fuels - Transport and Storage Containers Node: System 695: Specialty Fuels - Solution Gelation Node: System 696: Specialty Fuels - Kernel Conversion, TRISO Coating, and CVI Node: System 697: Specialty Fuels - Scrap Recovery Node: System 698: Specialty Fuels - Upgrading, Shell Filling, Inspection, He Leak Testing, Block Loading Node: System 699, Specialty Fuels - Ancillary Support Systems The nodes were established based on similarities between system processes establishing clean break points; however, the relationships between the nodes and potential accident scenarios
framatome TJT:24:009 Page 3 that could cross node boundaries or affect a process in a different node was recognized and evaluated within the process hazard analysis. The dry conversion process operations and transport and material storage (Nodes 690-694) that are part of the TRISO fuel fabrication project are processes with which Framatome has extensive experience and creates no new hazards nor uses new technologies that would require NRC prior approval. Increases in U235 enrichment in the Advance Reactor Fuel complex does require prior approval.
The Framatome Specialty Fuels Building ISA Summary Part II Chapter 2.11 focuses on the processes with new accident sequences and repurposed IROFS introduced by the design of the Nodes listed above.
- 3.
Technical Overview Framatome will utilize its dry conversion process for chemical conversion of UF6 to uranium dioxide powder for further processing into TRISO fuel. The process that will be used for TRISO fuel is the same basic design that is currently used at the Fuel Fabrication Facility (FFF).
Equipment sizes will be modified based on criticality safety requirements. The process will be conservatively designed to support less than 20 (wt%) U235 enrichment even though the enrichment for the new process will be less than 10 (wt%) U235.
The fabrication process is composed of two-parts - first the fabrication of TRISO particles, and second, the fabrication of FCM fuel pellets containing those TRISO particles. The first step is to package uranium into spherical kernels using the sol-gel process. Uranium oxide is dissolved in nitric acid to make a broth solution of uranyl nitrate. This yellow solution is combined with an organic solution to create a uranium gelation broth used in the sol-gel process.
For the sol-gel process a liquid uranium broth is cooled and dispersed as droplets into an oil bath. The droplets undergo thermally activated reactions that solidify the droplets into the soft gel spheres, a few millimeters in diameter.
The gel spheres are converted into Uranium Carbon Oxygen mix (UCO) kernels through a high temperature furnace to calcine, convert, and sinter the mixed uranium trioxide and carbon bearing particles from the sol-gel process to high density uranium oxy-carbide or other types of fuel kernels.
The fuel kernels are coated with ceramic layers by injecting gases into a hot fluidized chamber which can reach temperatures to 1700 °C. The gases react to deposit chemicals onto the spheres. TRISO particle layers are coated with a series of engineered ceramic layers using chemical vapor deposition. The thickness, porosity, grain size, and texture are strictly controlled to achieve the desired performance. Silicon Carbide (SiC) and graphite layers maintain their performance characteristics across the intended temperature and irradiation conditions.
The resulting TRISO particles are sorted using quality control processes, rejected material is recovered and recycled.
framatome TJT:24:009 Page 4 TRISO particles are loaded into SiC shells and densified with chemical vapor infiltration into full ceramic microencapsulated (FCM) fuel pellets for use in advanced reactors. FCM fuel contains TRISO particles which contain the radioactive byproducts of fission within layered ceramic coatings and are fully encased within a fully dense silicon carbide matrix.
The process hazards analysis indicates radiological impacts to the worker, public, and the environment are well within regulatory limits and performance requirements of 10 CFR 70.61.
The same process that will be used at the FFF has been tested at Pilot fuel manufacturing (PFM) facility operated by Ultra Safe Nuclear Corporation in Oak Ridge, TN. The PFM facility uses the same production-scale modules for manufacturing TRISO coated particles and FCM fuel that will be used at the FFF. The PFM is a radiological facility capable of producing FCM for testing and qualification of multiple-kilogram quantities of TRISO particles.
The Items Relied on For Safety (IROFS), identified for each Intermediate and High Consequence event, are defined in the ISA and process safety information documents.
- 4.
Regulatory Evaluation The new TRISO fuel process was evaluated against the 10 CFR 70.72(c) Facility Change and Change Process criteria to evaluate the proposed change and identify portions therein that may require prior NRC review and approval. Two of the criteria were identified that related to portions of process nodes 6-10:
(c)(1 )(i) Create new types of accident sequences that, unless mitigated or prevented, would exceed the performance requirements of 10 CFR 70.61 and that have not previously been described in the ISA Summary.
(c)(1 )(ii) Use new processes, technologies, or control systems for which the licensee has no prior experience.
As a portion of the process was identified as a new type of process, the Baseline Design Criteria (BDC) identified in 10 CFR 70.64 applies. The ISA summary Chapter 2.11 for the new process addresses how the BDC have been met for the new process. Defense-in-depth practices for the facility and system design and layout prefer engineered controls over administrative controls and focus on engineering features that reduce the potential for challenges to IROFS. This defense-in-depth design philosophy is applied from the outset based on successive levels of protection such that health and safety will not be wholly dependent upon any single element of the design, construction, maintenance, or operation of the facility.
Framatome has evaluated the dry conversion process (nodes 1-4), transport and storage (node 5) against the criteria in 10 CFR 70.72 (c) and has determined that these nodes do not require prior NRC approval as part of this amendment request. The dry conversion process is the same basic design as is currently used by the FFF. Equipment sizes will be modified based on criticality safety requirements. Likewise, the material and container storage processes have the same basic design as is currently used by the FFF. Increases in U235 enrichment in the Advance Reactor Fuel complex does require prior approval.
framatome TJT:24:009 Page 5 Not included in this submittal are changes to:
a) Framatomes Fundamental Nuclear Material Control Plan as the updates do not represent a substantive change. Framatome has determined that NRC prior approval is not required per 10 CFR 70.32 as the updates do not represent a decrease in effectiveness. Subject to amendment of the Framatome License, these minor program changes will be made and will be available for inspection by the NRC.
b) Framatomes Emergency Plan as updates to the Emergency Plan were not identified as a decrease in effectiveness as described in 10 CFR 70.32(i) and NRC prior approval is not needed. The evaluation to determine whether prior approval for the revision is needed follows Framatomes procedures and will be available for inspection by the NRC.
c) Framatomes security plan has been updated for the new process, but the updates do not decrease the effectiveness of plan pursuant to 10 CFR 70.22(h), 70.22(k) or 73.20(c) and NRC prior approval is not needed. The evaluation to determine whether prior approval for the revision is needed follows Framatomes procedures and will be available for inspection by the NRC.
Framatome also commits to following its approved procedures for training and qualification of employees related to the new process, as appropriate, for both construction and operation of the TRISO fuel production line.
The following license application chapter changes have been identified to support the amendment request:
General change - Where the U235 enrichment is discussed, the text was modified to differentiate the enrichment limits in the Specialty Fuels Building and the remainder of the site.
Chapter 1 - General Information - Changes were made to address the new activities related to TRISO fuel manufacturing to be conducted in the Specialty Fuels Building. This includes changes to the process descriptions, authorized new activities, revised enrichment limits and revisions to the type, quantity, and form of license material.
Chapter 2, - Organization and Administration - No changes were identified.
Chapter 3 - Integrated Safety Analysis and ISA Summary" - No changes were identified.
Chapter 4 - Radiological Protection - No changes were identified.
Chapter 5 - Nuclear Criticality Safety - Chapter was revised from previously approved license amendment 19 (dated November 27, 2023) related to changes in the criticality safety methodology that authorized use of this methodology for U235 enrichments up to <20 wt% U235.
The chapter has also been modified to discuss the new requirements for confirming that
framatome TJT:24:009 Page 6 the enrichment or material introduced to the non-Advanced Reactor Fuel Complex is within the allowed enrichment for the rest of the plant.
Section 5.4.2.5 Limiting Surface Density Limits, is being removed because this technical practice is no longer used. This change does not require NRC approval prior to implementation.
Chapter 6 - Chemical Safety-No changes were identified.
Chapter 7 - Fire Safety - No changes were identified.
Chapter 8 - Emergency Plan - No change to language in application. The revisions to the plan did not decrease the effectiveness of the EP. Copies of the changes will be provided within 6 months as per the license commitment made section 8.3 of the application.
Chapter 9 - Environmental monitoring - No changes were identified.
Chapter 10 - Decommissioning Funding Plan - No changes are required for this chapter.
However, equipment was removed from the Specialty Fuels Building and new equipment will be installed in conjunction with this amendment request. The DFP does not need to be revised with respect to this amendment. Changes related to the new process will be included in the next regular DFP submittal.
Chapter 11 - Management Measures - No changes were required to support the LAR. Two minor clarifications were made to paragraphs 11.1.2 and 11.4. This change does not require NRC approval prior to implementation.
Sitewide ISA summary changes Chapter 1 - Introduction - Changes were made to address the new activities related to TRISO fuel manufacturing to be conducted in the Specialty Fuels Building.
Chapter 2 Horn Rapids Road Site Information. Changes were made to update site information and, in some cases, reference the supplement to the environmental report.
Chapter 3 - Overview of Framatome Facilities, Operations and Hazards - Changes were made in the description of the activities in the Specialty Fuels Building for the new process.
Section 3.3, Hazards Identification was modified to include the new chemical hazards associated with the TRISO fuel process.
Chapter 4 - ISA Team Credentials and Standard Methodologies - No changes.
Chapter 5 - Quantitative Standards for Acute Chemical Exposure. See notes related to Appendix A below.
Chapter 6 - Definition of Terms - No changes.
framatome TJT:24:009 Page 7 Chapter 7 - General External and Facility Hazards - A discussion was added of the chemical consequences, controls and scenarios for the new TRISO fuel fabrication process in the Specialty Fuels Building. A discussion was also added related to the interbuilding accident effects for the new process in the Specialty Fuel Building.
Chapter 8 - Horn Rapids Plant Administrative and Management Measures - No changes.
Appendix A - Appendix A was modified to show the hazardous chemical concentration and consequence categories for the new TRISO fuel process.
Appendix B - Appendix B was modified to include hazardous material interactions for the chemicals that are to be used in the new TRISO fuel process.
Appendix C - Appendix C was modified to show the ISA plan scope alignment removing the previous equipment from the Specialty Fuels Building and adding the new systems for the new TRISO fuel process.
TRISO Process Specific ISA summary for Specialty Fuels Building Part II Chapter 2.11 of the ISA summary for the Specialty Fuels Building has been revised to remove discussions of equipment that has been removed and included discussions and evaluations of the new TRISO fuel fabrication activities that are included in this amendment request.
Other Considerations:
Framatome also anticipates that the NRC will impose a license condition requiring completion of an operational readiness review prior to Framatome introducing SNM into the new TRISO Fuel processes. Additionally, approvals of all required licenses (other than required NRC approval) will be obtained prior to the introduction of radioactive material.
No changes were identified for the specific conditions listed in SNM-1227 associated with the TRISO fuel fabrication process.
The FFF design, as discussed in the ISA summary, considered the most severe documented natural phenomena events for the site.
The SF building was designed and built for a Safe Shutdown Earthquake with a peak ground acceleration of 0.25 g. The furnace addition which was completed in 1994 was designed and built to the 1991 Uniform Building Code (UBC).
Buildings and equipment will therefore withstand any predictable weather event, as well as accelerations associated with a Seismic Zone 2B event, as required by the UBC. The 1997 version of the UBC was the last and the International Building Code (IBC) was adopted which
framatome TJT:24:009 Page 8 classified our site as risk class III and site class D.
The building structure has been designated as an IROFS and management measures have been applied to assure that the IROFS function of the building is available and reliable.
Framatome and prior NRC reviewers have concluded that experiencing a high consequence event due to a natural phenomenon is highly unlikely. Framatome will assure that any modifications or equipment installation to support TRISO fuel fabrication operation will meet the criteria discussed above.
Framatome will also perform an evaluation of the potential impacts of natural phenomena events on the items relied on for safety, including the natural phenomena design loads and interactions of non-safety related equipment impacting the safety function of IROFS in the new configuration of the SFB. This evaluation will be performed after completion of the final design of the TRISO fuel fabrication process. The evaluation cannot be accurately performed until the detailed design of the needed equipment is completed and sufficient anchoring is determined.
The design will follow all of the applicable codes and standards as stated in Section 2.11.3.4 of the ISA summary. The evaluation will be available for on-site inspection by the NRC as part of the operational readiness review.
- 5.
Environmental Considerations The Materials License (SNM-1227) issued by the NRC authorizes Framatome to receive, acquire, possess and transfer byproduct, source, and special nuclear material as designated in the License. The current licensed limit for enriched uranium (U235) is 5.0 wt%. In order to meet forecast needs of our industry partner, Framatome needs Uranium Hexafluoride (UF6) enriched to less than 10 wt% U235, for fabrication of TRISO fuel in the Specialty Fuels Building. This license amendment request that approval. Hexafluoride (UF6) enriched to less than 10 wt% U235, for fabrication of TRISO fuel in the Specialty Fuels Building. This license amendment requests that approval.
Framatome submitted a supplemental environmental report to the NRC in concert with its application for license renewal in 2006. The NRC conclusions in its EA related to the renewal were the continued operation of the Framatome (previously AREVA NP) site in Richland, Washington, will not significantly impact the environment. The facility already exists, and no changes to the facility or its operation are associated with the license renewal. The proposed action can be considered a continuation of impacts and was evaluated based on impacts from past operations. Gaseous emissions and liquid effluents are within regulatory limits for non-radiological and radiological components.
Public and occupational radiological dose exposures are below 10 CFR Part 20 regulatory limits. The NRC determined that all environmental impacts were small with the exception of transportation in which it was small to moderate.
In support of this LAR, Framatome is providing a Supplement to the Environmental Report (SER) (Attachment 3), which, in addition to addressing changes associated with the anticipated TRISO fuel process addition, includes updates for the site as a whole that have occurred since the 2006 ER. The ER concludes that the potential environmental impacts associated with the addition of the TRISO fuel processes are small and outweighed by the socioeconomic benefits associated with the continued plant activities.
framatome TJT:24:009 Page 9 Although a SER has been included in this application, Framatome concludes that the amendment does not require an environmental review as per 10 CFR 51.60(b)(2). The basis for this determination is that the amendment will not result in: a) A significant expansion of the site or construction impact; b) a significant change in the types of effluents; c) a significant increase in the amounts of effluents; d) a significant increase in individual or cumulative occupational radiation exposure; e) a significant increase in the potential for or consequences from radiological accidents; or f) a significant increase in spent fuel capacity.
A review and evaluation of the scope of the amendment request is included in the SER, as well as considerations of cumulative impacts, and demonstrates that an environmental report, or supplement, is not required and a Categorical Exclusion pursuant to 10 CFR 51.22(c)(11) is appropriate. This categorical exclusion is for issuance of amendments to licenses for fuel cycle plants and radioactive waste disposal sites and amendments to materials licenses identified in 10 CFR 51.60(b) which are administrative, organizational, or procedural in nature, or will result in a change in process operations or equipment, provided that (i) there is no significant change in the types or significant increase in the amounts or any effluents that may be released offsite, (ii) there is no significant increase in individual or cumulative radiation exposure; (iii) there is no significant construction impact; and (iv) there is no significant increase in the potential for or consequences from radiological accidents.
Categorical exclusions have been granted for other similar types of fuel cycle license amendments that meet the requirements of 10 CFR 51.22(c)(11). References to examples of other similar fuel cycle license amendments that meet the requirements of 10 CFR 51.22 are a) Louisiana Energy Services, amendment to increase possession limits of various sealed sources (ML15195A258, July 20, 2015), b) Framatome Richland amendment to increase U-235 possession limits, (ML15195A215, December 16, 2014), and c) Westinghouse Columbia fuel fabrication facility possession limit increase (ML15125A273, November 2, 2015).
The licensing action will not individually or collectively have a significant effect on the environment and meets the 10 CFR 51.22(c)(11) criteria for a categorical exclusion.
- 6.
Conclusions This license amendment request proposes changes to SNM-1227, which would authorize Framatome to produce TRISO fuel in the Specialty Fuels Building less than 10 wt% U235 per the established safety basis. The safety analyses presented herein, as supported by the Supplemental ER and the technical supporting documents, confirm that the production of TRISO fuel will be implemented in a safe and acceptable manner and that radiological impacts to the worker, public and environment are well within regulatory limits and performance requirements of 10 CFR 70.61.
framatome TJT:24:009 Page 10 Information contained herein in Attachment 1, chapter 1 contains sensitive information, is marked as "Security - Related Information - Withhold under 10CFR2.390, and is not suitable for public release. Information contained in Attachment 2, 3 and 4 are considered proprietary information, as set forth in the enclosed affidavits; therefore, Framatome requests that this information be withheld from public disclosure. A redacted version of this submittal suitable for public disclosure will be provided under a separate cover letter, if requested.
If you or your staff have any questions, require additional information, or wish to discuss this, please contact Brandon Hanson of my staff at (509)-375-8487 or me at, (509)-375 8550.
Sincerely, Timothy J Tate, Manager Environmental, Health, Safety & Licensing