ML25121A199

1. Email - Answer to Environmental Safety Rsi

ML25121A199
Person / Time
Site:	Framatome ANP Richland
Issue date:	04/15/2025
From:	Bryan Hanson Framatome
To:	Stephen Poy NRC/NMSS/DFM/FFLB
Shared Package
ML25121A195	List: ML25121A198 ML25121A199
References
Download: ML25121A199 (1)

Text

From:

HANSON Brandon (Framatome)

To:

Stephen Poy Cc:

TATE Timothy (Framatome); MANNING Calvin (Framatome)

Subject:

[External_Sender] Answer to Environmental Safety RSI Date:

Tuesday, April 15, 2025 11:17:37 AM Attachments:

image001.png

Stephen, Please see our answer below to the second draft RSI you sent regarding Environmental Safety:

Framatome Answer:

The Supplement to Applicants Environmental Report January 2025 on pg. 42 states:

The highest reported calculated public dose due to air emissions in the past five years was 2.34E-5 mrem during the first half of 2019. If this result was doubled to estimate the full year, it is approximately 0.0005% of the NRC constraint value. If this was conservatively increased by a factor of four, the highest calculated public dose due to air emissions in the past five years would increase to less than 0.002% of the NRC Constrain value. Normal operations at the enrichment requested in this license amendment request (LAR) will have negligible radiological impact on the public or environment.

The consequences and the probability of radiological accidents were evaluated in the ISA Summary for the current license, which the NRC approved in 2009. To support the enrichment increase requested in this LAR, Framatome updated its ISA. This update included an evaluation of the impact of increasing enrichment. No facility changes required to ensure criticality safety at this increased enrichment will increase the probability of an accident with radiological consequences. Potential radiological accidents such as a fire that destroys in service HEPA filters will not result in a different 10CFR70.61 consequence category when the general site enrichment is increased to the level requested in this LAR.

Brandon Hanson Manager, Licensing and Compliance-Framatome 2101 Horn Rapids Rd.

Richland, WA 99354 (509) 375-8487 Office (541) 243-4006 Mobile 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