ML25183A361
| ML25183A361 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 01/20/2025 |
| From: | Travis Tate Framatome |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| TJT:25:001 | |
| Download: ML25183A361 (1) | |
Text
Soewify-Rckatcd Information-Withhold-tlnder 10CFR2.39e-framatome TJT:25:001 Page 1 January 20, 2025 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Director, Office of Nuclear Material Safety and Safeguards Washington, DC 20555-0001
Subject:
License Amendment Requestfor Increased Site Enrichment atthe 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 increase the maximum enrichment from 5.0 wt.% to 6.5% wt. enrichment 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 overall increase of site enrichment from 5.0 wt.% to 6.5 wt.% to Framatome's 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 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 increased site enrichment. Framatome has used NRC's previously approved safety analysis methodologies and NCS practices for establishing subcritical limits when evaluating the need for and the establishment of IROFS to support this submittal.
Chapter 1 General Information version 8.0 page 1-6 and Chapter 5 version 4.0 page 5-9 is to be withheld as security related information per 10 CFR 2.390.
b) ATTACHMENT 2: Integrated Safety Analysis (ISA) Summary The portion of Integrated Safety Analysis (ISA) Summary that addresses the increased site enrichment project scope and its specific safety related impacts is a revised Part 2 Chapter 2.9-2.23, document E15-01-2.9-23.
These documents are to be withheld as proprietary information.
Security-Related Information-Withhold Ui'ider 10CFR2.'39Q framatome TJT:25:001 Page 2 c) ATTACHMENT 3: Supplement to the Environmental Report Framatome had prepared an Environmental Report (ER) for the 2006 license renewal application, Supplement to Applicant's Environmental Report January 2025, E06 003, Version 1.0. A Supplement to the ER evaluates the environmental impacts associated with an increase to overall site enrichment 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: Framatome Request for Obligation Blending Pre-Approval Letter requested to discuss Framatome MC&A obligations.
This document is to be withheld as security related information per 10CFR2.390
- 2.
Proposed Change The proposed amendment changes the overall site to support the increase of overall site enrichment from 5.0 wt.% U235 to 6.5 wt.% U235. This change will allow Framatome to support anticipated customer needs by providing higher enriched fuel to support longer fuel cycles and anticipated advanced reactor projects.
The change requires small modifications, improvements and fortifications to existing systems and processes to support from a safety perspective this move to a higher enrichment level. This change does not introduce new processes, chemicals, or hazards that would require NRC prior approval; however, this is a change to enrichment levels which does require prior approval.
The Framatome ISA Summary Part II Chapter 2.9-2.23 focuses on the changes with updated accident sequences and IROFS to support the increased site enrichment.
- 3.
Technical Overview Framatome will set up site processes to allow for the safe processing of higher enriched SNM utilizing its dry conversion process for chemical conversion of UF6 to uranium dioxide powder for further processing into fuel rods. The processes utilize the existing design that is currently used at the Fuel Fabrication Facility (FFF).
Equipment sizes will be modified to support enrichment up to 6.5 (wt%) U235 based on criticality safety requirements.
Security-Related Information - Withhold-Urnfer 10CFR2:390 f ramatome p9e 3 The process hazards analysis indicates radiological impacts to the worker, public, and the environment are well within regulatory limits and performance requirements of 10CFR 70.61.
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 increase in site enrichment 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. One of the criteria were identified that related to the change to higher enrichment:
(c)(4) Is not prohibited by this section, license condition or order.
Framatome has determined that increases in U235 enrichment from 5.0 wt.% to 6.5 wt.% does require prior approval.
Not included in this submittal are changes to:
a) Framatome's 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) Framatome's 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 Framatome's procedures and will be available for inspection by the NRC.
c) Framatome's security plan has been updated for increased enrichment, 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 Framatome's 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 increased enrichment, as appropriate.
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 for the change in overall site enrichment.
Security'Related Information Withhold Under lOCFf^.S^fr framatome TJT:25:001 Page 4 Chapter 1 - "General Information"- Changes were made to address increased site enrichment limits.
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 to indicate site enrichment of 6.5 wt.%.
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.
Chapters - Environmental monitoring - No changes were identified.
Chapter 10 - Decommissioning Funding Plan - No changes are required for this chapter. The DFP does not need to be revised with respect to this amendment. Changes related to increased site enrichment will be included in the next regular DFP submittal.
Chapter 11 - Management Measures - No changes were required to support the LAR.
Sitewide ISA summary changes Chapter 1 - "Introduction"- Changes were made to address the increased enrichment level of the site.
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 to discuss the increased enrichment levels of the site.
Chapter 4 - "ISA Team Credentials and Standard Methodologies"- Changes were made to the ISA team used to support this change.
Chapter 5 - No changes were made to this section.
Chapters - "Definition of Terms"- No changes.
Seumity-RelHtoif hifurrnation - Withhulcl Under 'IOCFR2.'39Cr f
a TJT:25:001 t ramateme pge 5 Chapter 7 - "General External and Facility Hazards"- Information was added to discuss the increased enrichment levels of the site.
Chapter 8 - "Horn Rapids Plant Administrative and Management Measures" - No changes.
Appendix A - Appendix A was not modified.
Appendix B - Appendix B was not modified.
Appendix C - Appendix C was modified to show the ISA plan scope alignment for increased enrichment on site.
Part II chapters 2.9 through 2.23 modified to include updated accident sequences and IROFS, to support enrichments up to 6.5 wt.%.
Other Considerations Framatome also anticipates that the NRC will impose a license condition requiring completion of an operational readiness review prior to Framatome introducing increased enrichment SNM to the site.
No changes were identified for the specific conditions listed in SNM-1227 associated with increased site enrichment.
The FFF design, as discussed in the ISA summary, considered the most severe documented natural phenomena events for the site.
Change in enrichment has no effect on structures, systems or components (SSC's) onsite.
- 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%. To meet forecast industry needs, Framatome needs Uranium Hexafluoride (UF6) enriched to not more than 6.5 wt% U235. 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.
Security Related Information - Withliuld Uriclei I0CFR2.390' f
TJT:25:001 t ramatome 6
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 increased site enrichment levels, 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 increased site enrichment are small and outweighed by the socioeconomic benefits associated with the continued plant activities.
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).
- 6.
Conclusions This license amendment request proposes changes to SNM-1227, which would authorize Framatome to increase our site enrichment to 6.5 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 increase in overall site enrichment 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.
Security-Related Information - Withhold Under 10CrR2.390 framatome TJT:25:001 Page 7 Information contained herein in Attachment 1, chapter 1 and Attachment 4 contains sensitive information, is marked as "Security - Related Information - Withhold under 10CFR2.390", and is not suitable for public release. Information contained in the Cover letter, Attachment 2 and 3 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