ML26034C009
| ML26034C009 | |
| Person / Time | |
|---|---|
| Site: | 07109294 |
| Issue date: | 01/30/2026 |
| From: | Schichlein L Global Nuclear Fuel |
| To: | Office of Nuclear Material Safety and Safeguards |
| References | |
| M260001, EPID L-2025-LLA-0079, CAC 001029 | |
| Download: ML26034C009 (0) | |
Text
GNi=
Global Nuclear Fuel Proprietary Notice This letter transmits proprietary information in accordance with 10 CFR 2.390. Upon removal of Enclosures 1 and 3, the balance of the letter may be considered non-proprietary.
M260001 January 30, 2026 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 Lisa K. Schichlein Global Nuclear Fuel - Americas, LLC Senior Licensing Engineer 3901 Castle Hayne Road Wilmington, NC 28401 USA Lisa.Schichlein@gevernova.us
Subject:
GNF Response to NRC Request for Additional Information for the Review of Certificate of Compliance No. 9294, Revision 11, New Powder Container This letter transmits, in Enclosure 1, the Global Nuclear Fuel - Americas, LLC (GNF) response to the Nuclear Regulatory Commission (NRC) Requests for Additional Information (RAis)
(Reference 1) for the review of Revision 8 of the New Powder Container (NPC) Safety Analysis Report (SAR), NEDE-33881 P (Reference 2).
Enclosure I contains proprietary information of the type that GNF maintains in confidence and withholds from public disclosure. Enclosure 2 is the non-proprietary version of Enclosure 1.
This letter also transmits, in Enclosure 3, electronic media containing input files for modeling the three configurations discussed in Enclosure 1. Enclosure 3 and the associated electronic media contains detailed information that is of the type GNF considers to be proprietary in its entirety.
GNF hereby requests that the information in Enclosures I and 3 and the associated electronic media be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390 and 9.17.
The affidavit contained within Enclosure 4 identifies that the information contained in Enclosures I and 3 and the transmitted electronic media have been handled and classified as proprietary to GNF and subject to the United States export control Jaws and regulations. A non-proprietary version of information contained in Enclosure 3 and the transmitted electronic media have not been provided in accordance with NRC Information Notice 2009-07, which states: "In instances in which a nonproprietary version would be of no value to the public because of the
!l)HS524
/v1-f5-5
M260001 Page 2 extent of the proprietary information, the agency does not expect a nonproprietary version to be submitted."
It is GNF's expectation that the NRC staff will use the proprietary information in Enclosure 3 and in the electronic media solely for their review activities for Revision 8 of the NPC SAR. At the conclusion of the NRC review activities or when requested, GNF expects all copies of the electronic media will either be destroyed or returned to GNF and that all files installed, copied, or modified from the files contained on the electronic media will be securely destroyed.
If you have any questions about the information provided, please contact me at (91 0) 819-4815.
Sincerely, Lisa K. Schichlein Senior Licensing Engineer Global Nuclear Fuel -Americas, LLC Docket No. 71-9294 CAC/EPID No. 00 I 029/L-2025-LLA-0079
References:
- 1. Letter, Norma Garcia Santos (NRC) to Lisa K. Schichlein (GNF), "Request for Additional Information for the Review of Certificate of Compliance No. 9294, Revision l I, Model No.
New Powder Container (Cost Activity Code/Enterprise Project Identification Numbers 00 I 029/L-2025-LLA-0079)," December 18, 2025.
- 2. Letter, Lisa K. Schichlein (GNF) to NRC Document Control Desk, "GNF Request for Revision of the New Powder Container Certificate of Compliance (USA/9294/AF-96),"
M250112, April 4, 2025.
Enclosures:
- 1. Response to the NRC RAI for the Review of Certificate of Compliance No. 9294, Revision 11, New Powder Container -GNF Proprietary Information - Non-Public
- 2. Response to the NRC RAJ for the Review of Certificate of Compliance No. 9294, Revision 11, New Powder Container-Non-Proprietary Information
- 3. Electronic Media Supporting Configurations in Enclosure I - GNF Proprietary Information -
Non-Public
- 4. Affidavit
M260001 Page 3 cc:
Garcia Santos. US RC E Lenning, USNRC M Catts. GCf-I/Wilmington P Ollis, GNF/Wilmington PLM Specification 008N9790 Re\iision 3
ENCLOSURE2 M260001 Response to the NRC RAI for the Review of Certificate of Compliance No. 9294, Revision 11, New Powder Container Non-Proprietary Information IMPORT ANT NOTICE This is a non-proprietary version of Enclosure I, from which the proprietary information has been removed. Portions of the enclosure that have been removed are indicated by an open and closed bracket as shown here ((
)).
M260001 Criticality Safety Evaluation RAI-Cr-1 Non-Proprietary Information Page I of 6 Provide a supplement to the criticality safety evaluation Revision 11 for the Model No. NPC package assuming that all ICCAs are being fully flooded and explain how the evaluation demonstrates compliance with 10 CFR 71.55(b). Include this information in the application.
In Section 6.1 of NEDE-33881 P, Revision 8, of the NPC Safety Analysis Report (SAR), it is stated:
"Water exclusion from all but two of the [Inner Containment Canister Assemblies] ICCAs is required for this package design. Each containeT arrays under optimal moderation conditions. The most reactive configuration of the ICCAs for the packages was identified."
The criticality analysis included in the report follows this approach. However, NRC staff (the staff) identified a potential regulatory concern with this methodology.
Specifically, this approach may not align with the requirements of 10 CFR 71.55(b), which states the following:
"Except as provided in paragraph ( c) or (g) of this section, a package used for the shipment of fissile material must be so designed and constructed and its contents so limited that it would be subcritical if water were to leak into the containment system, or liquid contents were to leak out of the containment system so that, under the following conditions, maximum reactivity of the fissi le material would be attained:
(I)
The most reactive credible configuration consistent with the chemical and physical fonn of the material; (2)
Moderation by water to the most reactive credible extent; and (3)
Close full reflection of the containment system by water on all sides, or such greater reflection of the containment system as may additionally be provided by the surrounding material of the packaging."
The most reactive credible extent of moderation would involve all ICCAs being fully flooded, not just two. This interpretation is consistent with current regulatory expectations and with the methodology used in the previous revision of the SAR for this package.
To assess the potential safety implications, staff conducted preliminary calculations using the input files provided by the licensee as a starting template. These calculations indicate that, under conditions where all ICCAs are fully flooded and loaded with 8 weight percent (wt.%) uranium 235 (U-235), using the Heterogeneous Optimal Particle Size Fuel model, there is a potential to exceed the Upper Subcritical Limit (USL) and a kerrof 0.95 for a single package.
The staff requests that the applicant reviews this issue and provide clarification or revised analysis demonstrating compliance with 10 CFR 7 I.55(b).
M260001 GNF Response Non-Proprietary Information Page 2 of 6 A supplemental analysis for the New Power Container (NPC) was performed to demonstrate compliance with IO CFR 71.SS(b ). Three configurations are presented in the supplemental analysis: a Normal Conditions of Transport (NCT) single package configuration, an as-designed single package configuration, and an extreme single package configuration.
The NCT single package configuration refers to the most reactive NCT single package configuration as determined in Section 6.3.4.5.1 of the NPC Safety Analysis Report (SAR)
Revision 8 (Reference I). Two flooded Inner Containment Canister Assemblies (ICCAs) are assumed in the NCT single package configuration. ((
)) Results of the NCT single package configuration for a range of fuel loading in terms of UO2 mass per [CCA are shown in Figure I, and these results include the limiting result of the NCT single package configuration reported in Table 6.2 of the NPC SAR Revision 8 (Reference 1).
The as-designed single package configuration is constructed to meet the requirements of 10 CFR 71.SS(b). The as-designed single package configuration is different than the NCT single package configuration for the following two applied assumptions:
- 1) ((
))
- 2) ((
))
Dimension and material tolerances have been considered in the as-designed single package configuration and in the NCT single package configuration, which is described in Section 6.3.1 and Section 6.3.2 of the NPC SAR Revision 8 (Reference I), respectively. A full water boundary has been applied in the as-designed single package configuration and in the NCT single package configuration, as described in Section 6.3.1.6.1 of the NPC SAR Revision 8 (Reference I).
M26000l Non-Proprietary Information Page 3 of6 Therefore, the as-designed single package configuration with all ICCAs flooded to the limiting credible W/F ratio meets the requirements of IO CFR 71.SS(b).
Results of the as-designed single package configuration for a range of fuel loading in terms of UO2 mass per ICCA are presented in Figure I and confirm that the as-designed single package configuration is bounded by the NCT single package configuration.
The extreme single package configuration is constructed to demonstrate the safety margin of the NPC. All nine ICCAs in the extreme single package configuration are flooded with suspended fuel spheres in water with the optimal W/F ratio applied in the flooded ICCAs in the NCT single package configuration. Results of the extreme single package configuration are shown in Figure I. Even in the extreme single package configuration, the system is still subcritical with an Upper Subcritical Limit (USL) of0.9407.
Thus, the supplemental analysis for the NPC has demonstrated compliance with 10 CFR 71.SS(b) with a large safety margin.
((
))
Figure 1: 10 CFR 71.55(b) Single Package Sensitivity Analysis Results
M260001
References:
Non-Proprietary Information Page 4 of 6 I.
Global Nuclear Fuel, "NPC Safety Analysis Report," NEDE-33881 P, Revision 8, April 2025.
- 2.
Dunn, E., et.al., "Credible Moderation Content of Uranium Oxide Powder and Pellet Systems," ANS NCSD 2013 Topical, September 2013.
Revisions to the NPC SAR to be Incorporated into Revision 9:
Note that the changed pages of the NPC SAR Revision 8 immediately follow Items 1 through 5.
I)
The following sentence will be deleted from the 4th paragraph in Section 6.1 of the NPC SAR:
"Water exclusion from all but two of the ICCAs is required for this package design."
- 2)
The following sentence will be added after the 3rd sentence of the I st paragraph m Section 6.1.2 of the NPC SAR:
"Demonstration of compliance with IO CFR 7 l.55(b) is presented in Section 6.9.4."
- 3)
The following sentence will replace the last sentence of the 8th paragraph m Section 6.3.1.1 of the NPC SAR:
"The assumption of water in-leakage in two ICCAs for the NCT models satisfies water moderation conditions under IO CFR 7 I.55(d) and 10 CFR 7 l.59(a)(l )."
- 4)
The following reference will be added to Section 6.9.1 of the NPC SAR:
6.17 Dunn, E., et.al., *'Credible Moderation Content of Uranium Oxide Powder and Pellet Systems," ANS NCSD 2013 Topical, September 2013.
- 5)
A new Section 6.9.4 will be added to the NRC SAR to include the supplemental analysis.
The text of this new section is provided below.
6.9.4 Supplemental Analysis to Demonstrate Compliance with 10 CFR 71.SS(b}
A supplemental analysis was performed to demonstrate compliance with 10 CFR 7 l.55(b ). The supplemental analysis consists of three configurations:
A NCT single package configuration An as-designed single package configuration An extreme single package configuration The NCT single package configuration refers to the most reactive NCT single package configuration determined in Section 6.3.4.5.1. Results of the NCT single package configuration for a range of fuel loading in terms of UO2 mass per ICCA are shown in Figure 6.34, and these results include the limiting result of the NCT single package configuration shown in Table 6.2.
M260001 Non-Proprietary Information Page 5 of 6 The as-designed single package configuration was constructed to meet the requirements of 10 CFR 7l.55(b). The as-designed single package configuration is different than the NCT single package configuration for the following two applied assumptions:
l) ((
))
- 2) ((
))
Dimension and material tolerances have been considered in the as-designed single package configuration and in the NCT single package configuration, which is described in Section 6.3.1 and Section 6.3.2, respectively. A full water boundary has been applied in the as-designed single package configuration and in the NCT single package configuration, as described in Section 6.3.1.6.1. Therefore, the as designed single package configuration with all ICCAs flooded to the limiting credible W/F ratio meets the requirements of 10 CFR 71.SS(b).
Results of the as-designed single package configuration for a range of fuel loading in terms of UO2 mass per ICCA are presented in Figure 6.34 and confirm that the as-designed single package configuration is bounded by the NCT single package configuration.
((
)) Results of the extreme single package configuration are shown in Figure 6.34. Even in the extreme single package configuration, the system is still subcritical with the USL of 0.9407.
Thus, the supplemental analysis for the NPC has demonstrated compliance with 10 CFR 71.SS(b) with a large safety margin.
M26000I
((
Non-Proprietary Information Page 6 of 6
))
Figure 6.34 - 10 CFR 71.SS(b) Single Package Sensitivity Analysis Results
NEDO-33881 Revision 8 - CHANGED PAGES Non-Proprietary Information
6.0 CRITICALITY EVALUATION
6.1 Description of Criticality Design This criticality safety analysis is performed to demonstrate the safety of the N PC. This transport package meets applicable International Atomic Energy Agency (IAEA) No. ST-1 (Reference 6.1) and 10 CFR 71 requirements for a Type A fissile material-shipping container for homogeneous and heterogeneous uranium compounds enriched to a maximum of8 wt.% Uranium-235 (U-235).
The NPC transport package design features include an internal 3 x 3 array of stainless steel ICCAs enclosed in a near cubic stainless steel reinforced OCA as described in Section 1.2.
The uranium contents are contained within up to three polyethylene bottles (poly bottles) stacked vertically inside 8.515-inch (21.63 cm) maximum Inner Diameter (ID) stainless steel canisters internally spaced on nominal 12.0-inch (30.48 cm) center-to-center positions within the OCA.
Manufacturing tolerances on package models are addressed in Section 6.3.2.2.
Water eKeh:1sioA from all e1:1ttwo of the JGGAs is req1:1ired for this paekage desigA. Each cylindrical inner container within the package was analyzed in both undamaged and damaged container arrays under optimal moderation conditions. The most reactive configuration of the ICCAs for the packages was identified.
This analysis was performed at an enrichment of 8 wt.% U-235 for both homogeneous Uranium Oxide (UO2) powder and heterogeneous UO2 in the form of pellets and spherical elements to represent unrestricted particle size (i.e., OD) of the particles was varied through optimal reactivity).
The most reactive condition was modeled for the authorized payload to demonstrate safety.
Table 6.1 summarizes the uranium mass limits per ICCA and per package for the N PC container.
Uranium compounds complying with the maximum loading requirements stated in Table 6.1 are acceptable for shipment provided the equivalent uranium payloads are not exceeded.
Results of the analyses performed for shipping up to 8 wt.% U-235 (Section 6.3.4) identified an optimal, bounding, particle size for uranium compounds transported in the NPC. The optimal particle size studies in Section 6.3.4.3 were shown to bound all homogeneous and heterogeneous pellet configurations. The optimal particle size results are used as the basis for the mass limits in Table 6.1 and cover pellet chips and other uranium compound pru1icle resizing effects during transportation.
6-1
NEDO-33881 Revision 8-CHANGED PAGES Non-Proprietary Information The modeled OCA lid includes JO-gauge, 43.21-inchx43.21-inchx5.9-inch outer dimension Type 304L stainless steel box that is mated to the lower body assembly via 16 guide pins, which ensure proper lid seal alignment during closure. The outermost periphery again includes a modeled I-inch ceramic fiberboard. The foam layer beneath the ceramic fiberboard includes a 3.5-inch layer of 15 lb/ft3 (nominal) density polyurethane foam insulation. The lower I 3/8-inch layer is rigid 40 lb/ft3 (nominal) density polyurethane foam to protect the interface between the OCA body assembly and OCA lid assembly mating surfaces. This higher density 40 lb/ft3 foam section in the lid includes cutouts to accommodate the upper lock ring closure of the I CCA.
The OCA lid dimensions include additional corner support structures, flanged edges, and ~2.3-inch overlap of I 0-gauge stainless steel protecting the OCA body/lid interface (which are ignored in the final model construct for conservatism). Closure of the OCA is provided by sixteen 1/2-13 UNC socket head cap screws. The closure is further secured by the OCA closure strips and twenty-four 7 /16-l 4UNC hex head bolts. The NPC packaging is illustrated in Figure 1.1-1. Full details of the NPC packaging design are provided on the drawings in Section 1.3.1. The OCA body containing up to nine loaded lCCAs, coupled with the OCA lid constitutes the entire NPC assembly.
6.1.2 Summary Table of Criticality Evaluation Table 6.2 lists the bounding criticality analysis cases performed for the NPC. The cases include NCT and HAC for a single package and for package arrays. The NCT single package case was constructed to meet requirements of 10 CFR 71.SS(b) and 10 CFR 71.SS(d), the HAC single package case to meet requirements of IO CFR 71.SS(e), the NCT array case (SN array) to meet requirements of 10 CFR7l.59(a)(l), and the HAC array case (2N array) to meet requirements of 10 CFR 71.59(a)(2). Demonstration of compliance \\\\ith 10 CFR 71.SS(b) is presented in Section 6.9.4. Model configuration details are presented in Section 6.3. I. The most limiting results are reported in Section 6.4.2 for the NCT and HAC single packages, in Section 6.5.2 for the NCT array, and in Section 6.6.2 for the HAC array. The Upper Subcritical Limit (USL) provided in Table 6.2 is described in Section 6.8.
Table 6.2 - Summary Table of Criticality Evaluation USL: 0.9407 Case Number of kcrr kcrr+ 2a Packages (J
HAC Array Configuration 2N = 150 0.92469 0.00029 0.92527 NCT Array Configuration SN = oo 0.90601 0.00032 0.90665 HAC Single Package I
0.86422 0.00029 0.86480 Configuration NCT Single Package I
0.86338 0.00030 0.86398 Con figuration 6-4
NE00-33881 Revision 8 - CHANGED PAGES Non-Proprietary Information The 8.515-inch (21.63 cm) ID of the 18-gauge ICCA includes the maximum manufacturing tolerance. Modeled sheet gauge dimensions incorporate the maximum manufacturing tolerance specified in ASTM-A240 as shown in Table 6.7. Because iron, chrome, and nickel constituents of stainless steel exhibit thennal and resonance absorption, the use of minimum sheet thickness values is considered conservative.
For cadmium, a 25% reduction is applied to the actual 20-mil (minimum) thickness, for a modeled thickness of 15-miJs (0.0381 cm)16 and section width of I 0.025-inches (25.4635 cm). The as-built stack-up of the axial cadmium wraps allow for a maximum seam gap of 0.1-inches (0.254 cm).
This gap is conservatively modeled as 0.15-inches (0.381 cm).
The HOPE is 30.3-inches (76.962 cm) in height and uniformly surrounds the cadmium, with no gaps, and its thickness ensured to be a minimum 0.570-inch (1.4478 cm) thickness by continuous wrapping of 15-mil (nominal) sheets and a Quality Control (QC) weight confirmation. To account for the small density reduction in the layered poly wrap, the HOPE (0.94 g/cm3 to 0.98 g/cm3 density) sheet material is conservatively modeled as a uniform low-density polyethylene (0.92 g/cm3) over the 0.570-inch thick (I.4478 cm) wrap (minimum hydrogen areal density= 0.199 g/cm2). The minimum required thickness, height, and quality weight measurements confirm this effective polyethylene thickness and density is achieved.
The ICCA model also includes three poly bottles stacked inside the ICCAs. Each poly bottle is modeled as a cylinder of outer radius 4.1-inches ( 10.414 cm) and an outer height of 10.30-inches (26.1620 cm). The wall thickness of the poly bottle at the side and bottom is 0.13-inches (0.3302 cm), and the poly bottle lid thickness is 0.24-inches (0.6096 cm). The fuel region inside each poly bottle is modeled as a cylinder of radius 3.97-inches (I 0.0838 cm) and a height of 9.93-inches (25.2222 cm). The internal fuel region is filled with either a wet fuel mixture in the case of a flooded ICCA with water in-leakage, or a dry fuel mixture in the case of a non-flooded ICCA with no in-leakage. D1y fuel contains an assumed water weight fraction of 5 wt.%
(50,000 ppm max) to account for humidity.
Water in-leakage is conservatively assumed for two of nine ICCAs in the NPC for both NCT and HAC models.
Each ICCA is individually prepared as required in Section 7.1.2 and no single packaging error could cause water in-leakage in two JCCAs at the same time. NCT test results in Section 2.6 show negligible effects on the NPC. Nine undamaged JCCAs were subjected to a water immersion test and results documented in Section 2.7.6 show no observed water in-leakage into the ICCAs. The assumption of water in-leakage in two ICCAs for the NCT models satisfies water moderation conditions under 1G CfR 71.SS(b), 10 CFR 71.SS(d) and 10 CFR 71.59(a)(l).
16 Note: Limiting added absorber material credit 10 75% without comprehensive tests is based on concerns for potential
.. streaming" of neutrons due 10 non-unifonnities. The 75% value demonstrated b)' this work is conscrvati\ e for several reasons: (I) cadmium is elemental and therefore homogeneous and is not distributed in granular fashion, and (2) the experimental work is based on the use of a monodircctional beam of neutrons. while in this package design, an isotropic neutron source exists, reducing intragranular transmission effects (if an)).
6-7
NEDO-33881 Revision 8-CHANGED PAGES Non-Proprietary Information 6.7 ANSI/ANS 8.26-2007, Criticality Safety Engineer Training And Qualification Program, ANSI/ANS, June 20, 2007.
6.8
((
))
6.9 GNFA Quality Notice, Documentation of the Bulk Density, Tap Density, and Agglomerate Size Distribution for Various Powder Samples in FMO, QN-01279, Revision I, November 2004.
6.10 ARJ-l-600, Criticality Handbook, Advance Process Development Section, Research and Development Department, Chemical Processing Unit, Atlantic Richfield Hanford Company, Volume II, p. II.D.2-1, Physical Properties of Uranium Compounds, 1968.
6.11 Crystal Data Determinative Tables, US Department of Commerce National Bureau of Standards, Third Edition, Volumes 5 and 6.
6.12 Smith, A. L., et al., Thermodynamic investigation of Na2U2O1 using Knudsen effusion mass spectrometry and high temperature X-ray diffraction, J. Chem. Thermodynamics, 90, pp. 199-208, 20 I 5.
6.13 Wells, A. F., Structural Inorganic Chemistry (4th Edition). Oxford: Clarendon Press.
pp. 999, 1975.
6.14 Nakahara, M., Dictionary of Inorganic Compounds & Complexes, Koudansya Scientific,
- p. 801 [UF4].
6.15 Nuclear Criticality Data for Uranium Mass and Sphere Volume of Homogeneous Water-Reflected and Moderated ADU, Yuichi Komuro, Yasushi Hirano, JAERI, November 1987.
6.16 Bergman, W., Safety Repo11 for the Container Type BU-D for the Transport of Uranium Compounds, NCS 0601, Revision I, October 2008.
6.17 Dunn, E., et.al., Credible Moderation Content of Uranium Oxide Powder and Pellet Systems, ANS NCSD 2013 Topical, September 2013.
6.9.2 Data Tables for Figures in Chapter 6 This section of the appendix provides the tabulated data corresponding to the figures presented in Chapter 6.
6-63
Case I
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I I
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I NEDO-33881 Revision 8 - CHANGED PAGES Non-Proprietary [nforrnation Table 6.48 - KENO-VI k,., Tabulated Results (Continued)
Weight kerr (J
k,.,= kerr+ 2a Fraction H2O 0.00 1.20346 0.00040 1.20426 0.01 1.20241 0.00043 1.20327 0.02 1.20223 0.00038 1.20299 0.03 1.20164 0.00041 1.20246 0.04 1.19926 0.00040 1.20006 0.05 1.19814 0.00039 1.19892 0.10 1.18836 0.00036 1.18908 0.15 1.17324 0.00052 1.17428 0.20 1.15484 0.00044 1.15572 0.25 1.13144 0.00039 1.13222 0.30 1.10546 0.00040 I.I 0626 0.35 1.07406 0.00039 1.07484 0.40 1.03981 0.00043 1.04067 0.45 0.99955 0.00041 1.00037 0.50 0.95468 0.00041 0.95550 0.55 0.90473 0.00044 0.90561 0.60 0.84805 0.00044 0.84893 0.65 0.78528 0.00053 0.78634 6.9.4Supplemental Analysis to Demonstrate Compliance with 10 CFR 71.SS(b)
AEG 210.275 210.661 211.035 211.357 211.706 211.993 213.384 214.561 215.491 216.352 217.052 217.691 218.248 218.739 219.174 2 I 9.564 219.917 220.227 A supplemental analysis was performed to demonstrate compliance with IO CFR 7 I.55(b). The supplemental analysis consists of three configurations:
- A NCT single package configuration
- An as-designed single package configuration
- An extreme single package configuration The NCT single package configuration refers to the most reactive NCT single package configuration determined in Section 6.3.4.5.1. Results of the NCT single package configuration for a range of fuel loading in terms of UO2 mass per ICCA are shown in Figure 6.34, and these results include the limiting result of the NCT single package configuration shov,n in Table 6.2.
6-88
NEDO-33881 Revision 8 - CHANGED PAGES Non-Proprjetary Information The as-designed single package configuration was constructed to meet the requirements of IO CFR 71.SS(b). The as-designed single package configuration is different than the NCT single package configuration for the following two applied assumptions:
lL((
))
ill[
))
Dimension and material tolerances have been considered in the as-designed single package configuration and in the NCT single package configuration, which is described in Section 6.3. I and Section 6.3.2, respectively. A full water boundary has been applied in the as-designed single package configuration and in the NCT single package configuration, as described in Section 6.3.1.6.1. Therefore, the as designed single package configuration with all lCCAs flooded to the limiting credible W/F ratio meets the requirements of IO CFR 71.SS(b).
Results of the as-designed single package configuration for a range of fuel loading in terms of UO2 mass per ICCA are presented in Figure 6.34 and confirm that the as-designed single package configuration is bounded by the NCT single package configuration.
((
)) Results of the extreme single package configuration are shown in Figure 6.34. Even in the extreme single package configuration. the system is still subcritical with the USL of 0.9407.
Thus, the supplemental analysis for the NPC has demonstrated compliance with IO CFR 71.SS(b) with a large safetv margin.
6-89
((
NED0-33881 Revision 8 - CHANGED PAGES Non-Proprietary Information Figure 6.34 - 10 CFR 71.55(b) Single Package Sensitivity Analysis Results 6-90
))
ENCLOSURE4 M260001 Affidavit
Global Nuclear Fuel - Americas AFFIDAVIT I, Lisa K. Schichlein, state as follows:
(!) I am a Senior Licensing Engineer, Fuels and Digital Engineering, Global Nuclear Fuel -
Americas, LLC ("GNF"), and have been delegated the function of reviewing the information described in paragraph (2) which is sought to be withheld and have been authorized to apply for its withholding.
(2) The information sought to be withheld is contained in Enclosures l and 3 of GNF letter, M260001, Lisa K. Schichlein (GNF) to Document Control Desk (US NRC),
Subject:
"GNF Response to NRC Request for Additional Information for the Review of Certificate of Compliance No. 9294, Revision 11, New Powder Container," dated January 30, 2026 and the associated electronic media. The electronic media in Enclosure 3 contains files that are proprietary in their entirety. The electronic media is labelled with the notation "GNF Proprietary Information - Withhold in Accordance with IO CFR 2.390" and "GNF Proprietary Information -
Non-PublicPl." The superscript notation Pl refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary determination.
GNF requests that the Enclosure 3 electronic media be withheld from public disclosure.
GNF proprietary infonnation within text and tables in Enclosure I is identified by a dotted underline inside double square brackets. [lThis _sentence_ is __ an_ example.PlJ] Figures and other large objects containing GNF proprietary information are identified with double square brackets before and after the object. In each case, the notation Pl refers to Paragraph (3) of this affidavit, which provides the basis for the proprietary detennination.
(3) In making this application for withholding of proprietary information of which it is the owner or licensee, GNF relies upon the exemption from disclosure set forth in the Freedom of Infonnation Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18 USC Sec. I 905, and NRC regulations IO CFR 9. l 7(a)(4), and 2.390(a)(4) for "trade secrets" (Exemption 4). The material for which exemption from disclosure is here sought also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975F2d87 I (DC Cir. 1992), and Public Citizen Health Research Group v. FDA, 704F2d 1280 (DC Cir. I 983).
(4) Some examples of categories of infonnation which fit into the definition of proprietary information are:
- a.
fnfonnation that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by GNF's competitors without license from GNF constitutes a competitive economic advantage over other companies;
- b.
Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product; M260001 Enclosure I Affidavit Page I of3
- c.
Information which reveals aspects of past, present, or future GNF customer-funded development plans and programs, resulting in potential products to GNF;
- d.
Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.
The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.
(5) To address IO CFR 2.390 (b) ( 4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GNF, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by GNF, no public disclosure has been made, and it is not available in public sources. All disclosures to third parties including any required transmittals to NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence.
Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.
(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge, or subject to the terms under which it was licensed to GNF.
(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his delegate), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation.
Disclosures outside GNF are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.
(8) The information identified in paragraph (2) is classified as proprietary because it contains details of GNF's processes and designs. The development of this information was achieved at a significant cost to GNF.
The development of this information is derived from an extensive experience database that constitutes a major GNF asset.
(9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of GNF's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost.
The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply M260001 Enclosure 1 Affidavit Page 2 of3
the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.
The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF.
The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.
GNF's competitive advantage will be lost if its competitors are able to use the results of the GNF experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.
The value of this information to GNF would be lost if the information were disclosed to the public.
Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive GNF of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing and obtaining these very valuable analytical tools.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 30th day of January 2026.
M26000 I Enclosure I Affidavit Lisa K. Schichlein Senior Licensing Engineer Global Nuclear Fuel-Americas, LLC 390 I Castle Hayne Road Wilmington, NC 2840 I Lisa.Schichlein@gevernova.us Page 3 of 3