ML24138A128

Pre-submittal May 15, 2024 Meeting Presentation License Amendment Request: Public Slides

ML24138A128
Person / Time
Site:	07003103
Issue date:	05/15/2024
From:	Louisiana Energy Services
To:	Office of Nuclear Material Safety and Safeguards
References
Download: ML24138A128 (1)

Text

© 2023 Urenco Limited License Amendment Request (LAR 24-01)

NRC Pre-Submittal Public Meeting 15 May 2024 Presented by UUSA LEU+ Project Team

2 UUSA is North Americas only large-scale commercial operating uranium enrichment facility

3

Introductions

• UUSA

• Wyatt Padgett, Head of Strategic Licensing & Design Safety Basis

• Rick Kohrt, LEU+ Project Technical Lead

• Gerard Poortman, LEU+ Project Manager

• Alex Riedy, NCS/ISA Consultant

• Charlotta Sanders, NCS Consultant (Remote)

• Jim Freels, Licensing Consultant

4 Meeting Agenda Schedule information LAR 24-01 Structure Scope of LAR Submittal Contents of LAR General Review of Impacts Questions

5 Schedule Information LEU+ License Amendment Requests

• LAR 23-02, LEU+ for Production, Handling and Storage Submittal date Nov 2023 Target date for NRC LAR decision Nov 2024

• LAR 24-01, LEU+ for Recycling and Support Systems Target date for submittal Q2 2024 Requested NRC review completion

+ 9 months

6 LAR 24-01 Structure

• LAR 24-01 is significantly smaller in scope and is less complex than LAR 23-02

• LAR 24-01 will only contain information that requires NRC approval for implementation for LEU+ use in recycling and support systems and removal of interim controls based on regulatory evaluations

• Other needed changes are being evaluated under other regulatory programs and do not require NRC approval for implementation

• LAR 24-01 assumes LAR 23-02 obtains approval and submitted text is basis for LAR 24-01

• Structure of LAR 24-01 generally follows structure and content of LAR 23-02

7 Scope of LAR 24-01

• This presentation will:

• Identify the changes needed where prior NRC approval is required

• Identify the changes needed where prior NRC approval is not required based on internal evaluations

• Additional details will be provided in the Closed meeting

8 Scope of LAR 24-01 Revise Materials License to:

Authorize use of the Materials License licensed limit of LEU+ for recycling and support systems Remove interim IROFS controls for segregation for removed components from LEU+ exposed production systems

9 Scope of LAR 24-01 Modify Constraints to License Conditions

• Prohibit use of recycling and support systems and removal of interim controls for segregation for LEU+ until after NRC conducts readiness review

• Request readiness review notification to NRC at least 60 days prior to planned implementation of LAR

10 Scope of LAR 24-01 Revise Licensing Basis Documents (Safety Analysis Report, Integrated Safety Analysis Summary)

Description and bases for changes requiring prior NRC approval are in LAR Analysis performed at 11 w/o 235U enrichment Roadmap showing relationship between Nuclear Criticality Analysis/Evaluations, Hazard and Operability Studies and ISA Team Meetings included

11 Integrated Safety Analysis Summary Discussion in LAR Section 4.1 and Enclosures 4 and 5 UUSA analyses and evaluations performed in accordance with approved ISA process and Quality Program Associated HAZOPs updated for LEU+

No severity level or consequence category changes For new IROFS only created/revised for LEU+, the numbering scheme has been modified New IROFS for LEU+ are designated with an extra digit for identification

• IROFSXX becomes IROFS1XX

12 Integrated Safety Analysis Summary For existing IROFS where the accident sequence and IROFS functionality were not changed, the numbers remain intact. Minor changes were made to some definitions.

All controls needed to ensure 10 CFR 70.61 performance requirements remain satisfied were evaluated No changes to External Events and Natural Phenomena Hazards New or revised IROFS requiring human action will be captured as Change Management Actions and evaluated for Human Factors under UUSA procedure

13 Integrated Safety Analysis Summary Existing Management Measures were used No changes were made to Management Measures

14 Integrated Safety Analysis Summary

• Examples of changes requiring NRC prior approval

• Changing from Safe-By-Design (SBD) to IROFS

• SBD Tables deleted from ISAS

• Crediting existing structural materials for neutron absorption

• New and deleted accident sequences

• Two revised accident sequences

• New or deleted IROFS

• One revised sole IROFS

15 Integrated Safety Analysis Summary

• Examples of changes not requiring NRC prior approval (but cannot be implemented until LAR 24-01 is approved)

• Substituting Upper Safety Limit (USL) for keff value

• Editorial changes (Conforming changes to text and Tables)

• Revising some IROFS Description of Safety Function for clarification

16 Criticality Safety Discussion in LAR Section 4.2 and (SAR Chapters 3 and 5)

MCNP6 code (v1.0) validation previously approved for higher enrichment ranges Nuclear Criticality Safety Analyses (NCSAs) and Evaluations (NCSEs) performed to support the enrichment up to less than 10 w/o 235U Criticality analyses performed at a bounding value of 11 w/o 235U

17 Criticality Safety Methodology follows changes proposed in SAR Chapter 5 LAR 23-02 was the submittal of those changes for NRC approval Criticality safety analyses remain below the UUSA upper safety limit USL=0.958 (LAR 21-03)

18 Interim Controls for LEU+ Segregation Discussion in LAR Section 4.3 Interim controls previously implemented (LAR 23-02), due to not having completed analyses for recycling systems for processing LEU+ exposed components, have been removed LAR 23-02 introduced

• Temporary accident sequences

• IROFS to segregate LEU+ exposed material and the installed recycling and support systems until approval of LAR 24-01 LAR 24-01 removes need for interim controls for segregation as analyses demonstrate performance requirements of 10 CFR 70.61 are satisfied

19 Safety Analysis Report Discussion in LAR Section 4.4 and Enclosure 3 Mark-up pages requiring NRC prior approval are included in the LAR submittal SAR Chapters 3 and 5 were revised to address:

Changes from Safe-By-Design (SBD) to IROFS for recycling systems Conforming changes Revised Critical and Safe Values of enriched UO2F2 at 11 w/o 235U and removal of values for 6 w/o 235U UUSA will retain capability in SAR to use SBD

20 Environmental Information / NEPA Discussion in LAR Section 4.5 and Enclosure 6 Information provided in LAR 23-02 considered cumulative impacts from its Proposed Action, past, present and reasonably foreseeable future actions both within UUSA and external to UUSA LAR 23-02 considered future use of recycling and support systems to be included in LAR 24-01 from a qualitative perspective The results from the review for LAR 24-01 confirms that environmental impacts remain bounded by earlier analyses Conclusion is that impacts are SMALL and Categorical Exclusion criteria under 10 CFR 51.22(c)(11) remain satisfied

21 Additional Programs Reviewed for Impact Non-impacted Programs (LAR Section 4.6)

Radiation Safety (LAR Section 4.6.1)

Chemical Process Safety (LAR Section 4.6.2)

Fire Safety (LAR Section 4.6.3)

Emergency Planning (LAR Section 4.6.4)

Decommissioning (LAR Section 4.6.5)

Fundamental Nuclear Material Control and Accounting (LAR Section 4.6.6)

Physical Security (LAR Section 4.6.7)

Cyber Security (LAR Section 4.6.8)

Information Security (LAR Section 4.6.9)

22 Additional Programs Reviewed for Impact Non-impacted Programs (LAR Section 4.6) (continued)

Existing Exemptions to NRC Regulations (LAR Section 4.6.10)

Facility Modifications (LAR Section 4.6.11)

• Previous potential to lower LECTS tank berm height evaluated as not required

© 2023 Urenco Limited on our promises We deliver Energy security for North America through increased capacity Advanced fuels for future nuclear reactors Creating a net zero future