ML25094A052
| ML25094A052 | |
| Person / Time | |
|---|---|
| Site: | 07109294 |
| Issue date: | 04/04/2025 |
| From: | Schichlein L Global Nuclear Fuel |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| Shared Package | |
| ML25094A051 | List: |
| References | |
| M250112, TAC L25154 | |
| Download: ML25094A052 (1) | |
Text
Lisa K. Schichlein Global Nuclear Fuel - Americas, LLC Senior Licensing Engineer 3901 Castle Hayne Road Wilmington, NC 28401 USA M250112 April 4, 2025 Director, Division of Spent Fuel Management Office of Nuclear Materials Safety & Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attention: Document Control Desk
Subject:
GNF Request for Revision of the New Powder Container Certificate of Compliance (USA/9294/AF-96)
Pursuant to 10 CFR 71.19, and as discussed with NRC staff on October 24, 2023 and August 28, 2024 (References 1 and 2), Global Nuclear Fuel - Americas, LLC (GNF) is requesting the revision of New Powder Container (NPC) Certificate of Compliance (CoC)
USA/9294/AF-96 (Reference 3) to approve modifications to the authorized contents. No modifications are requested to the previously approved package design.
The NPC Safety Analysis Report (SAR) has been revised as follows:
- To allow for the transportation of homogenous and heterogeneous forms of Type A quantities of uranium bearing compounds with enrichments up to 8 wt.% U-235.
- To increase the allowed quantity (mass) of uranium per shipment.
- To add the requirement for all uranium compounds transported in the NPC to be placed in a polyurethane bottle prior to placement within the Inner Containment Canister Assembly (ICCA).
These changes are reflected in a proposed revision to the NPC package CoC.
Other major revisions to the NPC SAR, which are not reflected in the proposed revision to the NPC package CoC include:
- Replacing the legacy criticality analysis tool GEMER with KENO-VI in Chapter 6 Proprietary Notice This letter transmits proprietary information in accordance with 10 CFR 2.390. Upon removal of Enclosure 1, the balance of the letter may be considered non-proprietary.
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- A complete rewrite of Chapter 6 to align with Regulatory Guide (RG) 7.9 Revision 2
- Conservatively crediting the Chapter 2 Hypothetical Accident Condition (HAC) test results to only analyze optimal moderation in two (2) ICCAs in the Chapter 6 criticality assessments The NPC SAR, NEDE-33881P Revision 8, is provided in its entirety in Enclosure 1. Included in the SAR is a change table with a description and reason for each change to aid the NRC review.
Note that because Chapter 6 has been completely rewritten as noted above, individual changes are not tracked in Chapter 6.
Please note that Enclosure 1 contains proprietary information of the type that GNF maintains in confidence and withholds from public disclosure. The affidavit contained in Enclosure 4 identifies that the designated information in Enclosure 1 has been handled and classified as proprietary to GNF. GNF hereby requests that the information in Enclosure 1 be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and 9.17. is the non-proprietary version of Enclosure 1. Enclosure 3 contains a proposed mark-up of the requested changes to Revision 10 of the CoC.
GNF requests that the NRC issue Revision 11 of the NPC CoC with the required content changes within 12 months of this submittal to support business objectives.
Upon issuance of Revision 11 of the CoC, GNF is requesting that Revision 10 of the CoC also remain in effect for a period of one (1) year, consistent with Condition 9 in Revision 10 of the CoC. Allowing Revision 10 of the CoC to remain in effect will allow fuel assemblies which were designed, manufactured, and prepared for shipment under Revision 10 of the CoC to be shipped using the NPC transportation package.
If you have any questions about the information provided, please contact me at (910) 819-4815.
Sincerely, Lisa K. Schichlein Senior Licensing Engineer Global Nuclear Fuel - Americas, LLC Docket No. 71-9309 TAC No. L25154
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Reference:
- 1. Letter, Lisa K. Schichlein (GNF) to NRC Document Control Desk, Submittal of Presentation Slides for October 24, 2023 NPC Meeting, M230133, October 10, 2023.
- 2. Letter, Lisa K. Schichlein (GNF) to NRC Document Control Desk, Submittal of Updated Final Presentation Slides for August 28, 2024 NPC Meeting, M240193, August 29, 2024.
- 3. GNF Model No. NPC Certificate of Compliance No. 9294, Docket Number 71-9294, Revision 10, Package Identification Number USA/9294/AF-96.
Enclosures:
- 1. NEDE-33881P Revision 8 NPC Safety Analysis Report - GNF Proprietary Information -
Non-Public
- 2. NEDO-33881 Revision 8 NPC Safety Analysis Report - Non-Proprietary Information
- 3. Proposed NPC CoC Revision Mark-ups
- 4. Affidavit cc:
H Yilma, USNRC E Lenning, USNRC M Catts, GEH/Wilmington P Ollis, GNF/Wilmington PLM Specification 008N9790 Revision 0 Document Components:
001 M250112 Cover Letter.pdf 002 M250112 Enclosure 1 Proprietary.pdf 003 M250112 Enclosure 2 Non-Proprietary.pdf 004 M250112 Enclosure 3 Non-Proprietary.pdf 005 M250112 Enclosure 4 Affidavit.pdf