ML25121A198
| ML25121A198 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 04/21/2025 |
| From: | Manning C Framatome |
| To: | Stephen Poy NRC/NMSS/DFM/FFLB |
| Shared Package | |
| ML25121A195 | List: |
| References | |
| Download: ML25121A198 (1) | |
Text
From:
MANNING Calvin (Framatome)
To:
Stephen Poy Cc:
Samantha Lav; Osiris Siurano-Perez; Robert Mathis; HANSON Brandon (Framatome); TATE Timothy (Framatome)
Subject:
[External_Sender] Framatome"s Draft Response to RSI 1)
Date:
Monday, April 21, 2025 6:52:39 PM Stephen; As I mentioned on Friday, the following is Framatomes response to draft RSI 1)
NRCs draft RSI 1):
- 1. Integrated Safety Analysis (ISA) Summary: Please confirm that the parameters/changes within Attachment 2: Integrated Safety Analysis (ISA) Summary (Part I of the ISA Summary Chapters 1-8 and Part II Chapter 2.9-2.23) of the License Amendment Request for increased site enrichment at the Framatome Fuel Fabrication Facility in Richland, WA (ML25020A006) dated January 20, 2025, are based on the Minimum Margin of Subcriticality (MMS) approval dated November 27, 2023 (ML23313A076). If any changes are not a part of the MMS change (such as changing items relied on for safety (IROFS) probability failure of demand scores, e.g., IROFS 1117 and 1118), please identify and provide justifications for those changes as needed for sufficient information pursuant to 10 CFR Part 70.65(b)(4). Additionally, to facilitate a more efficient NRC review, please perform a quality assurance check for mathematical and grammatical changes and provide summary information on updated IROFS and accident sequences.
Framatome proposed response:
Framatome confirms that the parameter changes e.g. mass limits, slab height changes, and moderator limits are based on the Minimum Margin of Subcriticality (MMS) approval dated July 11, 2022 (ML22154A438).
Note: The November 27, 2023 (ML23313A076) is not the correct MMS approval related to AFM, it is the approval related to Advanced Reactor Fuels at up to 20 wt.%. The AFM related approval was for up to 7 wt.% and all the calculations performed for AFM are based on this approval. The AFM related LAR Request dated 11/29/2021 (ML2133A203) and was approved July 11, 2022 (ML22154A438). This text in the yellow highlights is offered by way of explanation and will not be part of any response.
The following new IROFS numbers were added to the ISA specifically for the increase in enrichment requested in Framatomes license amendment request (LAR):
244 - PE 245 - PE 246 - PE 1129 - PE 1603.20 - EA 1821.10 - Admin 3710.10 - PE 6206.10 - PE 6509 - Admin The two 2.5 gal. bucket integrity IROFS were also added only because of AFM but they were added when the 2.5 gal buckets were introduced to the plant a year ago at 5%.
1410.40 - PE 1410.41 - PE Framatome will upload into BOX a table in the following format listing IROFS with changes showing the changes that were made.
RevID IROFSNum IROFSDescription FailureIndexSummary RevID IROFSNum IROFSDescription FailureIndexSummary 450 221 Concentration Control: The UN solution density will be monitored by density instrument, DIT-30501, and will stop the transfer of UN solution from Tk-305 A&B to TK-309 and Tk-310 by closing valves FV-30910, if the density exceeds 1.185 g/cc (138 g U/L).
PFOD=-3 452 221 Concentration Control: The UNH solution density will be monitored by density instrument, DIT-30501, and will stop the transfer of UNH solution from TK-305 A&B to TK-309 and TK-310 by closing valves FV-30910, if the density exceeds 1.1328 g/cc (100 gU/L).
PFOD=-3 A separate file will be provided that will justify those changes where the reason for the change may not have been obvious to the NRC reviewers.
Additionally, to facilitate a more efficient NRC review, Framatome will perform a quality assurance check for mathematical and grammatical change for each of the building specific ISA Summary chapters.
Any needed changes identified as a result of this quality assurance review of the ISA summary information on updated IROFS and accident sequences will be completed and uploaded into BOX as those QA reviews are completed.
A separate listing of the ISA Summary chapters that have been reviewed and confirmed to not need any updates will be provided in a separate file and will be uploaded into BOX.
If you have any additional questions, please feel free to contact me via e-mail or at 509-375-8237 Cal From: Stephen Poy <Stephen.Poy@nrc.gov>
Sent: Friday, April 11, 2025 6:10 AM To: TATE Timothy (FRA-FL) <timothy.tate@framatome.com>; MANNING Calvin (FRA-FL) <calvin.manning@framatome.com>; HANSON Brandon (FRA-FL) <brandon.hanson@framatome.com>
Cc: Samantha Lav <samantha.lav@nrc.gov>; Osiris Siurano-Perez <Osiris.Siurano-Perez@nrc.gov>; Robert Mathis <Robert.Mathis@nrc.gov>
Subject:
Draft RSIs Security Notice: Please be aware that this email was sent by an external sender.
- Tim, As discussed earlier this week during our call, the NRC staff has put together the following draft Requests for Supplemental Information.
- 1. Integrated Safety Analysis (ISA) Summary: Please confirm that the parameters/changes within Attachment 2: Integrated Safety Analysis (ISA) Summary (Part I of the ISA Summary Chapters 1-8 and Part II Chapter 2.9-2.23) of the License Amendment Request for increased site enrichment at the Framatome Fuel Fabrication Facility in Richland, WA (ML25020A006) dated January 20, 2025, are based on the Minimum Margin of Subcriticality (MMS) approval dated November 27, 2023 (ML23313A076). If any changes are not a part of the MMS change (such as changing items relied on for safety (IROFS) probability failure of demand scores, e.g., IROFS 1117 and 1118), please identify and provide justifications for those changes as needed for sufficient information pursuant to 10 CFR Part 70.65(b)(4). Additionally, to facilitate a more efficient NRC review, please perform a quality assurance check for mathematical and grammatical changes and provide summary information on updated IROFS and accident sequences.
- 2. Environmental Safety: From the Environmental Report (ER), Section 1.4 - Framatome is suggesting that a categorical exclusion is appropriate under 51.60(b)(1).
One of the criteria of a categorical exclusion includes in 51.60(b)(1) --there are no significant increase in the potential for or consequences from a radiological accident. There is no additional information in the environmental report to support this claim. The closest support for this statement is located on page 48, Section 4.13 Public and Occupational Health Impacts where it states, Postulated accidents are
described in Integrated Safety Analyses summary. While Framatome recognizes the potential for these types of accidents, the probability of any of them occurring is low due to engineered safety factors incorporated into the process design. Framatome process designs incorporate sufficient safety controls to ensure that any accident sequence (radiological or chemical) resulting in high or intermediate consequences meet the performance requirements specified in 10 CFR Part 70.61. In addition, the ER points to the ISA Summary which has not been evaluated by the safety reviewers.
Therefore, in order to obtain a categorical exclusion, NRC staff needs additional information that supports the requirement stated above. Framatome can respond to the RSI or point to a specific place in the application documents in order for the NRC staff to be able to work on a categorical exclusion.
Please review for comments. Let us know when you can have a response prepared.
Let me know if you have any questions.
- Thanks, Stephen Poy, Project Manager U.S. Nuclear Regulatory Commission (NRC)
Office of Nuclear Material Safety and Safeguards (NMSS)
Division of Fuel Management (DFM)
Fuel Facilities Licensing Branch (FFLB)
Phone: 301-415-7135 Email: stephen.poy@nrc.gov