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{{#Wiki_filter:GNii=   Global Nuclear Fuel Global Nuclear Fuel Scott P. Murray Manager, Facility Licensing 3901 Castle Hayne Road P.O. Box 780 Wilmington, NC 28402 USA M220066                                                                     T (910) 819-5950 scott.murray@ge.com April 14, 2022 Jonathan Rowley, Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Materials Safety and Safeguards US Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Document Control Desk
{{#Wiki_filter:GNii=
Global Nuclear Fuel M220066 April 14, 2022 Jonathan Rowley, Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Materials Safety and Safeguards US Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Document Control Desk Global Nuclear Fuel Scott P. Murray Manager, Facility Licensing 3901 Castle Hayne Road P.O. Box 780 Wilmington, NC 28402 USA T (910) 819-5950 scott.murray@ge.com


==Subject:==
==Subject:==
GNF-A 8 wt % License Amendment Request - Meeting Slides
GNF-A 8 wt % License Amendment Request - Meeting Slides  


==References:==
==References:==
: 1) NRC License SNM-1097, Docket 70-1113
: 1) NRC License SNM-1097, Docket 70-1113
: 2) Letter, T.D. Naquin (NRC), to S. P. Murray (GNF-A) "Review of Minimum Margin of Subcriticality for up to 8 Weight percent Enrichment of Uranium -235 and Amendment 18", 8/13/20
: 2) Letter, T.D. Naquin (NRC), to S. P. Murray (GNF-A) "Review of Minimum Margin of Subcriticality for up to 8 Weight percent Enrichment of Uranium -235 and Amendment 18", 8/13/20  


==Dear Mr. Rowley:==
==Dear Mr. Rowley:==
Attached to this letter are Global Nuclear Fuel-Americas (GNF-A) meeting slides regarding a proposed SNM-1097 license amendment to allow fuel fabrication using enrichments up to 8 weight percent uranium-235. This information is being provided for NRC staff review prior to a pre-application meeting scheduled on May 3, 2022.
Attached to this letter are Global Nuclear Fuel-Americas (GNF-A) meeting slides regarding a proposed SNM-1097 license amendment to allow fuel fabrication using enrichments up to 8 weight percent uranium-235. This information is being provided for NRC staff review prior to a pre-application meeting scheduled on May 3, 2022.
The meeting slides do not contain proprietary information and can be made publically available.
The meeting slides do not contain proprietary information and can be made publically available.
If you have any questions concerning this information, please call me at (910) 819-5950.
If you have any questions concerning this information, please call me at (910) 819-5950.
Sincerely, Sci~Ei!?~
Sincerely, Sci~Ei!?~
Facility Licensing                 V
Facility Licensing V  


==Attachment:==
==Attachment:==
GNF-A SNM-1097 License Amentment LEU+ Pre-Application Meeting Slides Cc: SPM 22-019
GNF-A SNM-1097 License Amentment LEU+ Pre-Application Meeting Slides Cc: SPM 22-019  


GNi=
GNi=
Global Nuclear Fuel SNM-1097 License Amendment Pre-Application Meeting LEU+ Fuel Fabrication USNRC Rockville, MD May 3, 2022
Global Nuclear Fuel SNM-1097 License Amendment Pre-Application Meeting LEU+ Fuel Fabrication USNRC Rockville, MD May 3, 2022  


Meeting Agenda
Meeting Agenda Why LEU+?
* Why LEU+?
Proposed Licensing Action/Elements of Change Criticality Safety Analyses (CSA)
* Proposed Licensing Action/Elements of Change
Facility Modifications Integrated Safety Analysis Summary Environmental Impact Considerations Anticipated License Chapter Changes Summary/Schedule GNii=
* Criticality Safety Analyses (CSA)
2 Global Nuclear Fuel  
* Facility Modifications
© 2022 General Electric Company - All rights reserved  
* Integrated Safety Analysis Summary
* Environmental Impact Considerations
* Anticipated License Chapter Changes
* Summary/Schedule GNii=
Global Nuclear Fuel 2
                      © 2022 General Electric Company - All rights reserved


Why Higher Assay LEU?
Why Higher Assay LEU?
LEU+ (Up to 8 wt. % U235) - LWRs
LEU+ (Up to 8 wt. % U235) - LWRs Existing BWRs/PWRs utilizing Accident Tolerant Fuel (ATF) designs such as Ironclad (FeCrAI cladding) or ARMOR coated zirc cladding types require higher enrichments to permit higher exposure (up to -80k MWD/MTU). Anticipated near term peak assay needs are 7 wt. % U235.
* Existing BWRs/PWRs utilizing Accident Tolerant Fuel (ATF) designs such as Ironclad (FeCrAI cladding) or ARMOR coated zirc cladding types require higher enrichments to permit higher exposure (up to -80k MWD/MTU). Anticipated near term peak assay needs are 7 wt. % U235.
The value to reactor utility is very high, as overall fuel fabrication costs could decrease & overall fuel cycle length could be increased in the existing fleet of BWRs and PWRs.
* The value to reactor utility is very high, as overall fuel fabrication costs could decrease & overall fuel cycle length could be increased in the existing fleet of BWRs and PWRs.
LEU+ will also position PWRs to achieve a desired goal of month fuel cycle.
* LEU+ will also position PWRs to achieve a desired goal of month fuel cycle.
Higher exposures and longer cycles would also generate less spent nuclear fuel.
* Higher exposures and longer cycles would also generate less spent nuclear fuel.
HALEU (Up to 20 wt. % U235 - not part of this request) - Advanced Reactor Fuels Advanced reactors and novel reactor designs utilizing Sodium Fast Reactor (SFR) technology with metallic uranium fuel will require assays up to -20 wt. % U235 GNii=
HALEU (Up to 20 wt. % U235 - not part of this request) - Advanced Reactor Fuels
Global Nuclear Fuel  
* Advanced reactors and novel reactor designs utilizing Sodium Fast Reactor (SFR) technology with metallic uranium fuel will require assays up to -20 wt. % U235 GNii=
© 2022 General Electric Company - All rights reserved 3
Global Nuclear Fuel 3
                              *  © 2022 General Electric Company - All rights reserved


GNF-A LEU+ Elements of Change SNM-1097 License Amendment (LA) approach GNi=
GNF-A LEU+ Elements of Change GNi=
Global Nuclear Fuel
Global Nuclear Fuel  
                    © 2022 General Electric Company - All rights reserved 4
© 2022 General Electric Company - All rights reserved SNM-1097 License Amendment (LA) approach 4  


Criticality Safety Analyses (CSA)
Criticality Safety Analyses (CSA)
Technical analysis
Technical analysis GNF-A has re-evaluated the nuclear criticality safety bases associated with conversion of UF6 to UO2 and related ceramic and balance of plant processes to manufacture LWR fuel at the designated LEU+ enrichment limit (e.g., 8.0 wt.% U235)
* GNF-A has re-evaluated the nuclear criticality safety bases associated with conversion of UF6 to UO2 and related ceramic and balance of plant processes to manufacture LWR fuel at the designated LEU+ enrichment limit (e.g., 8.0 wt.% U235)
A total of 44 nodal Criticality Safety Analyses (CSAs) were rebaselined to derive necessary subcritical limits and demonstrate double contingency principle was satisfied for all credible criticality safety hazards at 8 wt. % U235 enrichment.
* A total of 44 nodal Criticality Safety Analyses (CSAs) were rebaselined to derive necessary subcritical limits and demonstrate double contingency principle was satisfied for all credible criticality safety hazards at 8 wt. % U235 enrichment.
Required changes to Passive Engineered Controls (PECs), Active Engineered Controls (AECs), Augmented Administrative Controls (AACs) and Administrative Controls (ACs) to support nuclear fuel conversion, fuel fabrication, and balance of plant support systems were systematically re-evaluated.
* Required changes to Passive Engineered Controls (PECs), Active Engineered Controls (AECs), Augmented Administrative Controls (AACs) and Administrative Controls (ACs) to support nuclear fuel conversion, fuel fabrication, and balance of plant support systems were systematically re-evaluated.
Implementation of the modified controls necessary to meet 1 0CFR70.61 performance requirements were systematically evaluated and IROFS changes likewise identified (discussed later in more detail).
* Implementation of the modified controls necessary to meet 10CFR70.61 performance requirements were systematically evaluated and IROFS changes likewise identified (discussed later in more detail).
Necessary changes to SNM-1097 Consolidated License Application Chapter 1 (General Information) and Chapter 5 (Nuclear Criticality Safety) have been drafted.
* Necessary changes to SNM-1097 Consolidated License Application Chapter 1 (General Information) and Chapter 5 (Nuclear Criticality Safety) have been drafted.
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Global Nuclear Fuel s
Global Nuclear Fuel  
                                  © 2022 General Electric Company - All rights reserved
© 2022 General Electric Company - All rights reserved s


Facility Modifications for LEU+ Project Overview
Facility Modifications for LEU+ Project Overview Low to intermediate impact on dry conversion process (DCP) /
* Low to intermediate impact on dry conversion process (DCP) /
powder product line systems located in designated Moderation Restricted Areas (MRAs).
powder product line systems located in designated Moderation Restricted Areas (MRAs).
* Low to intermediate impact on ceramics fabrication processes including pelletization, grind, rod load, rod storage and bundle assembly systems located in designated Moderation Control Areas (MCAs).
Low to intermediate impact on ceramics fabrication processes including pelletization, grind, rod load, rod storage and bundle assembly systems located in designated Moderation Control Areas (MCAs).
* Intermediate to high impact on balance of plant (BOP) support processes such as liquid radwaste systems - existing 5°/o favorable geometry equipment will be replaced or modified to permit material processing at 8 wt.% U235 enrichment.
Intermediate to high impact on balance of plant (BOP) support processes such as liquid radwaste systems - existing 5°/o favorable geometry equipment will be replaced or modified to permit material processing at 8 wt.% U235 enrichment.
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Global Nuclear Fuel 6
Global Nuclear Fuel  
                                © 2022 General Electric Company - All rights reserved
© 2022 General Electric Company - All rights reserved 6


Integrated Safety Analysis Commensurate with the SNM-1097 license [amendment] application, an updated integrated safety analysis summary (ISAS) for the GNF-A fuel fabrication facility has also been prepared to demonstrate that high consequence accident sequences remain highly unlikely pursuant 10CFR70.
Integrated Safety Analysis Commensurate with the SNM-1097 license [amendment] application, an updated integrated safety analysis summary (ISAS) for the GNF-A fuel fabrication facility has also been prepared to demonstrate that high consequence accident sequences remain highly unlikely pursuant 1 0CFR70.
Criticality Safety Analyses Integrated Safety Analysis Summary                                                                     Process Hazards Analysis GNii=   Global Nuclear Fuel Quantitative Risk Assessments 7
Criticality Safety Analyses Integrated Safety Analysis Summary Process Hazards Analysis GNii=
                                  © 2022 General Electric Company - All rights reserved
Quantitative Risk Assessments Global Nuclear Fuel  
© 2022 General Electric Company - All rights reserved 7


Summary of ISA activities for LEU+ Project Incorporated results of rebaselined nodal criticality safety analyses (CSAs) at 8 wt. 0/o U235 enrichment limit into the GNF-A ISA program Prepared 9 new calculations to support the determination of accident consequence severity levels for all nodes Assessed the impact to all 25 PHAs, which resulted in the revision of 4 PHAs:
Summary of ISA activities for LEU+ Project Incorporated results of rebaselined nodal criticality safety analyses (CSAs) at 8 wt. 0/o U235 enrichment limit into the GNF-A ISA program Prepared 9 new calculations to support the determination of accident consequence severity levels for all nodes Assessed the impact to all 25 PHAs, which resulted in the revision of 4 PHAs:
* Radwaste System (significant changes based on redesign of the radwaste system; no new accident event sequences were created)
Radwaste System (significant changes based on redesign of the radwaste system; no new accident event sequences were created)
* DCP Homogenizer (change in safety strategy for a single event sequence)
DCP Homogenizer (change in safety strategy for a single event sequence)
* Powder Pack/Warehouse (added a single accident event sequence to address powder loading enrichment failures associated with one container type)
Powder Pack/Warehouse (added a single accident event sequence to address powder loading enrichment failures associated with one container type)
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Global Nuclear Fuel 8
Global Nuclear Fuel  
                            © 2022 General Electric Company - All rights reserved
© 2022 General Electric Company - All rights reserved 8


Summary of ISA activi'ties for LEU+ Project (Continued)
Summary of ISA activi'ties for LEU+ Project (Continued)
Assessed the impact to 27 QRAs, which resulted in the revision of 12 QRAs. Summary of changes include:
Assessed the impact to 27 QRAs, which resulted in the revision of 12 QRAs. Summary of changes include:
* Changes in mass and container limits, which in a few cases impacted initiating event frequencies and overall event likelihoods
Changes in mass and container limits, which in a few cases impacted initiating event frequencies and overall event likelihoods Updated event descriptions based on changes in mass/container limits Deleted one IROFS and replaced with an existing IROFS at Homogenizer For Radwaste System, updated entire QRA as a result of revised radwaste system design (no new event sequences; deletion of two I ROFS associated with a tank being removed in the redesigned system and the replacement of one IROFS with a new IROFS)
* Updated event descriptions based on changes in mass/container limits
* Deleted one IROFS and replaced with an existing IROFS at Homogenizer
* For Radwaste System, updated entire QRA as a result of revised radwaste system design (no new event sequences; deletion of two IROFS associated with a tank being removed in the redesigned system and the replacement of one IROFS with a new IROFS)
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Global Nuclear Fuel 9
Global Nuclear Fuel  
                              © 2022 General Electric Company - All rights reserved
© 2022 General Electric Company - All rights reserved 9


Summary of ISA activities for LEU+ Project (Continued)
Summary of ISA activities for LEU+ Project (Continued)
ISA Summary revision for the LEU+ amendment request - incorporates all of the necessary changes required to support the LEU+ project. Main impacts include:
ISA Summary revision for the LEU+ amendment request - incorporates all of the necessary changes required to support the LEU+ project. Main impacts include:
* Deleted one IROFS (205-02) and replaced with an existing IROFS (205-04)
Deleted one IROFS (205-02) and replaced with an existing IROFS (205-04)
* Deleted two IROFS associated with equipment being removed (702-09 and 702-10)
Deleted two IROFS associated with equipment being removed (702-09 and 702-10)
* Deleted one IROFS and replaced with a new IROFS (replaced 702-22 with 702-24)
Deleted one IROFS and replaced with a new IROFS (replaced 702-22 with 702-24)
* Revised name of one IROFS (702-23)
Revised name of one IROFS (702-23)
* Changes in mass and container limits, which in a few cases impacted initiating event frequencies and overall event likelihoods Summary of ISA program document changes are detailed in CALC-900-012 (prepared to specifically facilitate a project licensing impact review)
Changes in mass and container limits, which in a few cases impacted initiating event frequencies and overall event likelihoods Summary of ISA program document changes are detailed in CALC-900-012 (prepared to specifically facilitate a project licensing impact review)
All ISA program documents supporting LEU+ project are currently in "approved - not implemented" status GNi=
All ISA program documents supporting LEU+ project are currently in "approved - not implemented" status GNi=
Global Nuclear Fuel 10
Global Nuclear Fuel  
                              © 2022 General Electric Company - All rights reserved
© 2022 General Electric Company - All rights reserved 10


LEU+ Environmental Impact Considerations Pursuant to 10 CFR 51.60(b)(2), the amendment will not require an environmental review because it will not result in:
LEU+ Environmental Impact Considerations Pursuant to 10 CFR 51.60(b)(2), the amendment will not require an environmental review because it will not result in:
- A significant expansion of the site or construction impact
A significant expansion of the site or construction impact A significant change in the types of effluents A significant increase in the amounts of effluents A significant increase in individual or cumulative occupational radiation exposure A significant increase in the potential for or consequences from radiological accidents A significant increase in spent fuel storage capacity The licensing action will not individually or collectively have a significant effect on the human environment and meets the 10 CFR 51.22( c )( 11) criterion for categorical exclusion GNi=
- A significant change in the types of effluents
Global Nuclear Fuel  
- A significant increase in the amounts of effluents
© 2022 General Electric Company - All rights reserved 11
- A significant increase in individual or cumulative occupational radiation exposure
- A significant increase in the potential for or consequences from radiological accidents
- A significant increase in spent fuel storage capacity The licensing action will not individually or collectively have a significant effect on the human environment and meets the 10 CFR 51.22( c )( 11) criterion for categorical exclusion GNi=Global Nuclear Fuel 11
                              © 2022 General Electric Company - All rights reserved


LEU+ License Amendment Anticipated SNM-1097 Changes - Chapter 1
LEU+ License Amendment Anticipated SNM-1097 Changes - Chapter 1  
§ 1.1 Facility and Process Description Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235
§ 1.1 Facility and Process Description Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235  
§ 1.1.4 Process Description Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235
§ 1.1.4 Process Description Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235  
§ 1.2.2 Type, Quantity, and Form of Licensed Material Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235
§ 1.2.2 Type, Quantity, and Form of Licensed Material Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235  
§ 1.3.3 Authorized Transfer of Contamination-Free Liquids Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235 [§1.3.3.1, Transfer of HF for Testing; §1.3.3.2, Transfer of HF as Product; §1.3.3.2, Transfer of Nitrate-Bearing Liquids]
§ 1.3.3 Authorized Transfer of Contamination-Free Liquids Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235 [§1.3.3.1, Transfer of HF for Testing; §1.3.3.2, Transfer of HF as Product; §1.3.3.2, Transfer of Nitrate-Bearing Liquids]  
§ 1.3.8 Authorization for the Use of Materials at Off-site Locations Will confirm safe rod number per license commitments):
§ 1.3.8 Authorization for the Use of Materials at Off-site Locations Will confirm safe rod number per license commitments):
For dry fuel reconstitution, not more than 99 (9x9 or 1Ox10 lattices) or 88 (8x8 lattices) unassembled fuel rods may be possessed by GNF-A at any one reactor site at any one time, except when the fuel has been packaged for transport.
For dry fuel reconstitution, not more than 99 (9x9 or 1Ox10 lattices) or 88 (8x8 lattices) unassembled fuel rods may be possessed by GNF-A at any one reactor site at any one time, except when the fuel has been packaged for transport.
For underwater fuel reconstitution, not more than one fuel assembly plus unassembled fuel rods so that the total number of rods, including the assembly, possessed by GNF-A at any one reactor site at any one time does not exceed 99 (9x9 or 1Ox10 lattices) or 88 (8x8 lattices), except when the fuel has been packaged for transport or as described in Section 1.3.8.2.
For underwater fuel reconstitution, not more than one fuel assembly plus unassembled fuel rods so that the total number of rods, including the assembly, possessed by GNF-A at any one reactor site at any one time does not exceed 99 (9x9 or 1Ox10 lattices) or 88 (8x8 lattices), except when the fuel has been packaged for transport or as described in Section 1.3.8.2.
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Global Nuclear Fuel 12
Global Nuclear Fuel  
                                              © 2022 General Electric Company - All rights reserved
© 2022 General Electric Company - All rights reserved 12


LEU+ License Amendment Anticipated SNM-1097 Chapter 5 Changes
LEU+ License Amendment Anticipated SNM-1097 Chapter 5 Changes  
* § 5.4.2.3 Administrative Controls
§ 5.4.2.3 Administrative Controls Administrative change: Correct typo - there should be a hard return between the two definitions and a bullet added to the Administrative Control definition.  
* Administrative change: Correct typo - there should be a hard return between the two definitions and a bullet added to the Administrative Control definition.
§ 5.4.3 Specific Parameter Limits The favorable geometry values of Table 5.1 contain dimensions for sphere, cylinder, and slab which may be used for applicable operations at GNF-A.
* § 5.4.3 Specific Parameter Limits
Table 5.1 will be modified to include specific subcritical limit values covering the enrichment range from 5.0 to 8.0 wt. % U235 The safe batch values of Table 5.2 may be used for applicable operations at GNF-A.
* The favorable geometry values of Table 5.1 contain dimensions for sphere, cylinder, and slab which may be used for applicable operations at GNF-A.
Table 5.2 will be modified to include specific subcritical limit values for U02 and water covering the enrichment range from 5.0 to 8.0 wt. % U235 GNi=
Table 5.1 will be modified to include specific subcritical limit values covering the enrichment range from 5.0 to 8.0 wt. % U235
Global Nuclear Fuel  
* The safe batch values of Table 5.2 may be used for applicable operations at GNF-A.
© 2022 General Electric Company - All rights reserved 13
Table 5.2 will be modified to include specific subcritical limit values for U0 2 and water covering the enrichment range from 5.0 to 8.0 wt. % U235 GNi=
Global Nuclear Fuel 13
                                  © 2022 General Electric Company - All rights reserved


LEU+ License Amendment Anticipated SNM-1097 Chapter 5 Changes (cont'd)
LEU+ License Amendment Anticipated SNM-1097 Chapter 5 Changes (cont'd)  
* § 5.4.5.2 Analytic Methods
§ 5.4.5.2 Analytic Methods Administrative changes:
* Administrative changes:
Remove Solid Angle Code (SAC code) - it is no longer used.
Remove Solid Angle Code (SAC code) - it is no longer used.
Remove GEKENO 16-group Monte Carlo neutron transport codes - it is no longer used.
Remove GEKENO 16-group Monte Carlo neutron transport codes - it is no longer used.
Line 161: Line 141:
Add MCNP Monte Carlo neutron-photon transport code description.
Add MCNP Monte Carlo neutron-photon transport code description.
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Global Nuclear Fuel 14
Global Nuclear Fuel  
                                © 2022 General Electric Company - All rights reserved
© 2022 General Electric Company - All rights reserved 14


LEU+ License Amendment No Additional SNM-1097 Chapter Changes Anticipated
LEU+ License Amendment No Additional SNM-1097 Chapter Changes Anticipated Chapter 2 Chapter 3 Chapter 4 Chapter 6 Chapter 7 Chapter 8 Chapter 9 Chapter 10 Chapter 11 GNi=
* Chapter 2     Organization and Administration
Global Nuclear Fuel Organization and Administration Integrated Safety Analysis Radiation Safety Chemical Safety Fire Safety Radiological Contingency & Emergency Plan Environmental Protection Decommissioning Management Measures  
* Chapter 3    Integrated Safety Analysis
© 2022 General Electric Company - All rights reserved 15
* Chapter 4    Radiation Safety
* Chapter 6    Chemical Safety
* Chapter 7    Fire Safety
* Chapter 8    Radiological Contingency & Emergency Plan
* Chapter 9    Environmental Protection
* Chapter 10    Decommissioning
* Chapter 11    Management Measures GNi=
Global Nuclear Fuel 15
                            © 2022 General Electric Company - All rights reserved


Summary for Manufacturing LEU+
Summary for Manufacturing LEU+
LEU+ amendment will capitalize on other existing programs without significant changes
LEU+ amendment will capitalize on other existing programs without significant changes Material Control and Accounting Program (provided NUREG/BR-0006 & 0007 E 1 & E2 material type enrichment codes are revised)
-    Material Control and Accounting Program (provided NUREG/BR-0006 & 0007 E 1 & E2 material type enrichment codes are revised)
Site physical security and safeguards Environmental permits and assessments Decommissioning Funding Plan/Cost Estimate (DFP)
-    Site physical security and safeguards
Radiological Contingency and Emergency Plan (RC&EP)
-    Environmental permits and assessments
-    Decommissioning Funding Plan/Cost Estimate (DFP)
-    Radiological Contingency and Emergency Plan (RC&EP)
Plan is to submit amendment request late June 2022 for NRC review and approval LEU+ reloads by early 2024 feasible - (between 5-8°/o)
Plan is to submit amendment request late June 2022 for NRC review and approval LEU+ reloads by early 2024 feasible - (between 5-8°/o)
GNii=
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Global Nuclear Fuel 16
Global Nuclear Fuel  
                          © 2022 General Electric Company - All rights reserved
© 2022 General Electric Company - All rights reserved 16


Backup GNr Global Nuclear Fuel 17
Backup GNr 17 Global Nuclear Fuel  
                    © 2022 General Electric Company - All rights reserved
© 2022 General Electric Company - All rights reserved  


Fresh Fuel RAJ-I I Container Transport Model RAJ-II Type B Fissile Package
Fresh Fuel RAJ-I I Container Transport Model RAJ-II Type B Fissile Package
[USA/9309/B(U)F-96]
[USA/9309/B(U)F-96]
BWR fuel assemblies, BWR/PWR fuel rods, Uranium Carbide rods LEU+ Up to 8% enrichment requires SAR update and corresponding Certificate of Compliance (CoC)changes Separate Request; planned for Fall 2022 GNi=
BWR fuel assemblies, BWR/PWR fuel rods, Uranium Carbide rods LEU+ Up to 8% enrichment requires SAR update and corresponding Certificate of Compliance (CoC)changes Separate Request; planned for Fall 2022 GNi=
Global Nuclear Fuel 18
Global Nuclear Fuel  
                                © 2022 General Electric Company - All rights reserved
© 2022 General Electric Company - All rights reserved 18


Feed Transport: UF6 Cylinder/ UX-30 Model 30B UF6 Cylinder Model UX-30 Overpacks on GNr Global Nuclear Fuel Flatrack 19
Feed Transport: UF6 Cylinder/ UX-30 Model 30B UF6 Cylinder GNr Global Nuclear Fuel Model UX-30 Overpacks on Flatrack  
                        © 2022 General Electric Company - All rights reserved}}
© 2022 General Electric Company - All rights reserved 19}}

Latest revision as of 18:28, 27 November 2024

GNF-A 8 Wt % License Amendment Request - Meeting Slides
ML22104A092
Person / Time
Site: 07001113
Issue date: 04/14/2022
From: Murray S
Global Nuclear Fuel
To: Rowley J
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
M220066
Download: ML22104A092 (20)


Text

GNii=

Global Nuclear Fuel M220066 April 14, 2022 Jonathan Rowley, Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Materials Safety and Safeguards US Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Document Control Desk Global Nuclear Fuel Scott P. Murray Manager, Facility Licensing 3901 Castle Hayne Road P.O. Box 780 Wilmington, NC 28402 USA T (910) 819-5950 scott.murray@ge.com

Subject:

GNF-A 8 wt % License Amendment Request - Meeting Slides

References:

1) NRC License SNM-1097, Docket 70-1113
2) Letter, T.D. Naquin (NRC), to S. P. Murray (GNF-A) "Review of Minimum Margin of Subcriticality for up to 8 Weight percent Enrichment of Uranium -235 and Amendment 18", 8/13/20

Dear Mr. Rowley:

Attached to this letter are Global Nuclear Fuel-Americas (GNF-A) meeting slides regarding a proposed SNM-1097 license amendment to allow fuel fabrication using enrichments up to 8 weight percent uranium-235. This information is being provided for NRC staff review prior to a pre-application meeting scheduled on May 3, 2022.

The meeting slides do not contain proprietary information and can be made publically available.

If you have any questions concerning this information, please call me at (910) 819-5950.

Sincerely, Sci~Ei!?~

Facility Licensing V

Attachment:

GNF-A SNM-1097 License Amentment LEU+ Pre-Application Meeting Slides Cc: SPM 22-019

GNi=

Global Nuclear Fuel SNM-1097 License Amendment Pre-Application Meeting LEU+ Fuel Fabrication USNRC Rockville, MD May 3, 2022

Meeting Agenda Why LEU+?

Proposed Licensing Action/Elements of Change Criticality Safety Analyses (CSA)

Facility Modifications Integrated Safety Analysis Summary Environmental Impact Considerations Anticipated License Chapter Changes Summary/Schedule GNii=

2 Global Nuclear Fuel

© 2022 General Electric Company - All rights reserved

Why Higher Assay LEU?

LEU+ (Up to 8 wt. % U235) - LWRs Existing BWRs/PWRs utilizing Accident Tolerant Fuel (ATF) designs such as Ironclad (FeCrAI cladding) or ARMOR coated zirc cladding types require higher enrichments to permit higher exposure (up to -80k MWD/MTU). Anticipated near term peak assay needs are 7 wt. % U235.

The value to reactor utility is very high, as overall fuel fabrication costs could decrease & overall fuel cycle length could be increased in the existing fleet of BWRs and PWRs.

LEU+ will also position PWRs to achieve a desired goal of month fuel cycle.

Higher exposures and longer cycles would also generate less spent nuclear fuel.

HALEU (Up to 20 wt. % U235 - not part of this request) - Advanced Reactor Fuels Advanced reactors and novel reactor designs utilizing Sodium Fast Reactor (SFR) technology with metallic uranium fuel will require assays up to -20 wt. % U235 GNii=

Global Nuclear Fuel

© 2022 General Electric Company - All rights reserved 3

GNF-A LEU+ Elements of Change GNi=

Global Nuclear Fuel

© 2022 General Electric Company - All rights reserved SNM-1097 License Amendment (LA) approach 4

Criticality Safety Analyses (CSA)

Technical analysis GNF-A has re-evaluated the nuclear criticality safety bases associated with conversion of UF6 to UO2 and related ceramic and balance of plant processes to manufacture LWR fuel at the designated LEU+ enrichment limit (e.g., 8.0 wt.% U235)

A total of 44 nodal Criticality Safety Analyses (CSAs) were rebaselined to derive necessary subcritical limits and demonstrate double contingency principle was satisfied for all credible criticality safety hazards at 8 wt. % U235 enrichment.

Required changes to Passive Engineered Controls (PECs), Active Engineered Controls (AECs), Augmented Administrative Controls (AACs) and Administrative Controls (ACs) to support nuclear fuel conversion, fuel fabrication, and balance of plant support systems were systematically re-evaluated.

Implementation of the modified controls necessary to meet 1 0CFR70.61 performance requirements were systematically evaluated and IROFS changes likewise identified (discussed later in more detail).

Necessary changes to SNM-1097 Consolidated License Application Chapter 1 (General Information) and Chapter 5 (Nuclear Criticality Safety) have been drafted.

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Global Nuclear Fuel

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Facility Modifications for LEU+ Project Overview Low to intermediate impact on dry conversion process (DCP) /

powder product line systems located in designated Moderation Restricted Areas (MRAs).

Low to intermediate impact on ceramics fabrication processes including pelletization, grind, rod load, rod storage and bundle assembly systems located in designated Moderation Control Areas (MCAs).

Intermediate to high impact on balance of plant (BOP) support processes such as liquid radwaste systems - existing 5°/o favorable geometry equipment will be replaced or modified to permit material processing at 8 wt.% U235 enrichment.

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Global Nuclear Fuel

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Integrated Safety Analysis Commensurate with the SNM-1097 license [amendment] application, an updated integrated safety analysis summary (ISAS) for the GNF-A fuel fabrication facility has also been prepared to demonstrate that high consequence accident sequences remain highly unlikely pursuant 1 0CFR70.

Criticality Safety Analyses Integrated Safety Analysis Summary Process Hazards Analysis GNii=

Quantitative Risk Assessments Global Nuclear Fuel

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Summary of ISA activities for LEU+ Project Incorporated results of rebaselined nodal criticality safety analyses (CSAs) at 8 wt. 0/o U235 enrichment limit into the GNF-A ISA program Prepared 9 new calculations to support the determination of accident consequence severity levels for all nodes Assessed the impact to all 25 PHAs, which resulted in the revision of 4 PHAs:

Radwaste System (significant changes based on redesign of the radwaste system; no new accident event sequences were created)

DCP Homogenizer (change in safety strategy for a single event sequence)

Powder Pack/Warehouse (added a single accident event sequence to address powder loading enrichment failures associated with one container type)

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Global Nuclear Fuel

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Summary of ISA activi'ties for LEU+ Project (Continued)

Assessed the impact to 27 QRAs, which resulted in the revision of 12 QRAs. Summary of changes include:

Changes in mass and container limits, which in a few cases impacted initiating event frequencies and overall event likelihoods Updated event descriptions based on changes in mass/container limits Deleted one IROFS and replaced with an existing IROFS at Homogenizer For Radwaste System, updated entire QRA as a result of revised radwaste system design (no new event sequences; deletion of two I ROFS associated with a tank being removed in the redesigned system and the replacement of one IROFS with a new IROFS)

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Global Nuclear Fuel

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Summary of ISA activities for LEU+ Project (Continued)

ISA Summary revision for the LEU+ amendment request - incorporates all of the necessary changes required to support the LEU+ project. Main impacts include:

Deleted one IROFS (205-02) and replaced with an existing IROFS (205-04)

Deleted two IROFS associated with equipment being removed (702-09 and 702-10)

Deleted one IROFS and replaced with a new IROFS (replaced 702-22 with 702-24)

Revised name of one IROFS (702-23)

Changes in mass and container limits, which in a few cases impacted initiating event frequencies and overall event likelihoods Summary of ISA program document changes are detailed in CALC-900-012 (prepared to specifically facilitate a project licensing impact review)

All ISA program documents supporting LEU+ project are currently in "approved - not implemented" status GNi=

Global Nuclear Fuel

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LEU+ Environmental Impact Considerations Pursuant to 10 CFR 51.60(b)(2), the amendment will not require an environmental review because it will not result in:

A significant expansion of the site or construction impact A significant change in the types of effluents A significant increase in the amounts of effluents A significant increase in individual or cumulative occupational radiation exposure A significant increase in the potential for or consequences from radiological accidents A significant increase in spent fuel storage capacity The licensing action will not individually or collectively have a significant effect on the human environment and meets the 10 CFR 51.22( c )( 11) criterion for categorical exclusion GNi=

Global Nuclear Fuel

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LEU+ License Amendment Anticipated SNM-1097 Changes - Chapter 1

§ 1.1 Facility and Process Description Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235

§ 1.1.4 Process Description Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235

§ 1.2.2 Type, Quantity, and Form of Licensed Material Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235

§ 1.3.3 Authorized Transfer of Contamination-Free Liquids Administrative change: Align text with new authorized enrichment limit of 8.0 wt.% U235 [§1.3.3.1, Transfer of HF for Testing; §1.3.3.2, Transfer of HF as Product; §1.3.3.2, Transfer of Nitrate-Bearing Liquids]

§ 1.3.8 Authorization for the Use of Materials at Off-site Locations Will confirm safe rod number per license commitments):

For dry fuel reconstitution, not more than 99 (9x9 or 1Ox10 lattices) or 88 (8x8 lattices) unassembled fuel rods may be possessed by GNF-A at any one reactor site at any one time, except when the fuel has been packaged for transport.

For underwater fuel reconstitution, not more than one fuel assembly plus unassembled fuel rods so that the total number of rods, including the assembly, possessed by GNF-A at any one reactor site at any one time does not exceed 99 (9x9 or 1Ox10 lattices) or 88 (8x8 lattices), except when the fuel has been packaged for transport or as described in Section 1.3.8.2.

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LEU+ License Amendment Anticipated SNM-1097 Chapter 5 Changes

§ 5.4.2.3 Administrative Controls Administrative change: Correct typo - there should be a hard return between the two definitions and a bullet added to the Administrative Control definition.

§ 5.4.3 Specific Parameter Limits The favorable geometry values of Table 5.1 contain dimensions for sphere, cylinder, and slab which may be used for applicable operations at GNF-A.

Table 5.1 will be modified to include specific subcritical limit values covering the enrichment range from 5.0 to 8.0 wt. % U235 The safe batch values of Table 5.2 may be used for applicable operations at GNF-A.

Table 5.2 will be modified to include specific subcritical limit values for U02 and water covering the enrichment range from 5.0 to 8.0 wt. % U235 GNi=

Global Nuclear Fuel

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LEU+ License Amendment Anticipated SNM-1097 Chapter 5 Changes (cont'd)

§ 5.4.5.2 Analytic Methods Administrative changes:

Remove Solid Angle Code (SAC code) - it is no longer used.

Remove GEKENO 16-group Monte Carlo neutron transport codes - it is no longer used.

Add SCALE/KENO-VI Monte Carlo neutron transport code description.

Add MCNP Monte Carlo neutron-photon transport code description.

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Global Nuclear Fuel

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LEU+ License Amendment No Additional SNM-1097 Chapter Changes Anticipated Chapter 2 Chapter 3 Chapter 4 Chapter 6 Chapter 7 Chapter 8 Chapter 9 Chapter 10 Chapter 11 GNi=

Global Nuclear Fuel Organization and Administration Integrated Safety Analysis Radiation Safety Chemical Safety Fire Safety Radiological Contingency & Emergency Plan Environmental Protection Decommissioning Management Measures

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Summary for Manufacturing LEU+

LEU+ amendment will capitalize on other existing programs without significant changes Material Control and Accounting Program (provided NUREG/BR-0006 & 0007 E 1 & E2 material type enrichment codes are revised)

Site physical security and safeguards Environmental permits and assessments Decommissioning Funding Plan/Cost Estimate (DFP)

Radiological Contingency and Emergency Plan (RC&EP)

Plan is to submit amendment request late June 2022 for NRC review and approval LEU+ reloads by early 2024 feasible - (between 5-8°/o)

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Global Nuclear Fuel

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Backup GNr 17 Global Nuclear Fuel

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Fresh Fuel RAJ-I I Container Transport Model RAJ-II Type B Fissile Package

[USA/9309/B(U)F-96]

BWR fuel assemblies, BWR/PWR fuel rods, Uranium Carbide rods LEU+ Up to 8% enrichment requires SAR update and corresponding Certificate of Compliance (CoC)changes Separate Request; planned for Fall 2022 GNi=

Global Nuclear Fuel

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Feed Transport: UF6 Cylinder/ UX-30 Model 30B UF6 Cylinder GNr Global Nuclear Fuel Model UX-30 Overpacks on Flatrack

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