ML25216A053
| ML25216A053 | |
| Person / Time | |
|---|---|
| Site: | 07109309 |
| Issue date: | 08/04/2025 |
| From: | Schichlein L Global Nuclear Fuel |
| To: | Office of Nuclear Material Safety and Safeguards, Document Control Desk |
| Shared Package | |
| ML25216A052 | List: |
| References | |
| M250198 | |
| Download: ML25216A053 (1) | |
Text
Lisa K. Schichlein Global Nuclear Fuel - Americas, LLC Senior Licensing Engineer 3901 Castle Hayne Road Wilmington, NC 28401 USA M250198 August 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 Letter Authorization to Use the RAJ-II Transportation Package for 11x11 Fuel As discussed with NRC Spent Fuel Storage and Transportation staff on November 13, 2024 and May 8, 2025 (References 3 and 4) Global Nuclear Fuel - Americas, LLC (GNF) hereby submits a request for a letter authorization to use the RAJ-II package for shipment of a new 11x11 fuel assembly design. GNF is in the process of negotiating with utility customers for the delivery of 11x11 Lead Use Assemblies (LUAs) at currently operating nuclear power plants. This letter authorization is needed because the timeframe for the delivery of these LUAs is not supported by the time required to revise the CoC to add the new fuel design as an authorized content in the RAJ-II package. The first LUA shipment is scheduled for July or August of 2026 and up to two additional shipments are expected through September 2027. For this reason, GNF requests NRC review and approval of the attached submittal by March 31, 2026.
SUMMARY
GNF is requesting a letter authorization to use Certificate of Compliance (CoC) No. 9309, Revision 14 and the Model RAJ-II transportation package to transport a new 11x11 fuel assembly design. The Model RAJ-II package is currently authorized to transport unirradiated fuel rods and fuel assemblies and will not be modified for this request. The 11x11 design, while similar to contemporary GNF fuel designs, is not covered by certain fuel assembly parameters in the current RAJ-II CoC. All other requirements of the current CoC remain applicable. In a letter authorization request (Enclosure 1), GNF provides sufficient assessment and supplemental evaluations that the new assembly design does not affect the ability of the package to meet the requirements of 10 CFR 71 and can be approved.
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.
M250198 Page 2 EVALUATION The 11x11 fuel assembly design is described in Enclosure 1. The parameters of the 11x11 design that are not within the current RAJ-II CoC, Table 3 Fuel Assembly Parameters are highlighted in Table 1-1 in Enclosure 1.
Also in Enclosure 1, GNF provides the letter authorization request and technical basis for NRC staff review based on the current Model RAJ-II Radioactive Material Transport Package Safety Analysis Report, Revision 11 (Reference 2). The Enclosure 1 information has been formatted consistent with NRC Regulatory Guide 7.9 Standard Format and Content of Part 71 Packages for Radioactive Material to aid NRC staff review and approval.
GNF has performed specific structural and criticality evaluations to supplement the RAJ-II package Safety Analysis Report for these LUA shipments. A structural evaluation demonstrates that the 11x11 fuel assembly within the RAJ-II package meets all of the structural requirements of 10 CFR 71.71 and 10 CFR 71.73 and is bounded by the package testing performed for the current authorized contents. Criticality safety evaluations demonstrate that the RAJ-II package design has sufficient reactivity margin under normal and accident conditions to safely transport the 11x11 fuel assembly design. These evaluations are provided in Enclosure 1, Chapter 2.0 (Structural Evaluation) and Chapter 6.0 (Criticality Evaluation).
Except for certain fuel assembly parameters shown in the current RAJ-II CoC, all other requirements of CoC No. 9309, Revision 14 remain applicable.
CONDITIONS For the LUA shipments, the following conditions will apply and have been incorporated into the GNF specific evaluations:
- 1. The LUA shipments will be restricted based on a crticiality safety index of 11.2.
- 2. The fuel assemblies will contain UO2 and gadolinium only, with an additional allowance for trace amounts of silicon.
- 3. The fuel assemblies will contain commercial grade uranium enriched up through 5.0 wt% 235U and meet Type A material contents.
- 4. The fuel assemblies will be shipped unchanneled.
CONCLUSION Based on the statements and representations contained in the letter authorization request and the conditions listed above, GNF concludes that the 11x11 fuel assembly design has been adequately described and evaluated, meets the requirements of 10 CFR Part 71, and can be safely transported in the Model RAJ-II package.
M250198 Page 3 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
References:
- 1. Model RAJ-II - Certification Number 9309 Revision 14, Docket Number 71-9309, Package Identification USA/9309/B(U)F-96
- 2. Global Nuclear Fuel, RAJ-II Safety Analysis Report, NEDE-33869P, Revision 11, September 2022.
- 3. NRC/GNF Meeting, November 13, 2024
- 4. NRC/GNF Meeting, May 8, 2025
Enclosures:
- 1. 11x11 RAJ-II Letter Authorization Request and Technical Basis - GNF Proprietary Information - Non-Public
- 2. 11x11 RAJ-II Letter Authorization Request and Technical Basis - Non-Proprietary Information
- 3. Affidavit cc:
N Garcia Santos, USNRC M Catts, GEH/Wilmington P Ollis, GNF/Wilmington PLM Specification 009N8985 Revision 0 Document Components:
001 M250198 Cover Letter.pdf 002 M250198 Enclosure 1 Proprietary.pdf 003 M250198 Enclosure 2 Non-Proprietary.pdf 004 M250198 Enclosure 3 Affidavit.pdf