ML24197A080
| ML24197A080 | |
| Person / Time | |
|---|---|
| Site: | 07109309 |
| Issue date: | 07/15/2024 |
| From: | Moore B Global Nuclear Fuel |
| To: | Division of Fuel Management, Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| M240142 | |
| Download: ML24197A080 (1) | |
Text
Brian R. Moore, Ph.D.
Global Nuclear Fuel - Americas, LLC General Manager, Core & Fuel Engineering P.O. Box 780, M/C A55 Wilmington, NC 28401 USA
M240142 July 15, 2024
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-A Request for Letter Authorization to Increase the Maximum Authorized Fuel Pellet Silicon Concentration for the RAJ-II Transportation Package
Global Nuclear Fuel - Americas LLC (GNF-A) hereby submits a request for a letter authorization (LA) to increase the maximum author ized fuel pellet silicon concentration for the RAJ-II transportation package to 500 µg/gU as allowed by Section 3.1 of ASTM C776. GNF-A has partnered with a BWR utility to deliver approximately four demonstration bundles with an aluminosilicate (AlSi) additive in the UO2 pellets and approximately four lead test assemblies (LTAs) containing lead test rods (LTRs) with AlSi additive in the UO2. This LA is being requested because the timeframe for the delivery of these LTAs is not supported by the time required to revise the Certificate of Compliance (CoC) to increase the maximum authorized silicon concentration for fuel pellets in the RAJ-II transportation package.
GNF-A is requesting an expedited review for this request to support the delivery of the LTA bundles to Edwin I. Hatch Nuclear Plant, Unit 2, as part of the shipment of standard reload fuel bundles in early October 2024. Installation of the LTAs will allow in-reactor experience to be gained for expanded qualification of the AlSi additive product. The accumulation of this experience is important for the industrys efforts to fully implement an advanced fuel pellet that enhances safety and improves performance.
The first demonstration bundle and LTA shipment is scheduled for October 14, 2024. Allowing for time to prepare the necessary shipping documentation, GNF-A requests Nuclear Regulatory Commission (NRC) review and approval of this submittal by September 30, 2024. GNF-A may also establish agreements with other utilities to install the AlSi additive product. It is estimated M240142 Page 2
that an additional shipment may occur once during the Spring of 2026. To support this additional shipment, it is requested that the LA be valid through the end of 2026.
Summary
Per emailed discussions with the NRC (Reference 1), GNF-A is requesting a letter authorization to to use CoC No. 9309, Revision 14 (Reference 2) for the RAJ-II transportation package to ship fuel pellets with a silicon concentration of up to 500 µg/gU. The increased silicon concentration is for Edwin I. Hatch Nuclear Plant, Unit 2 LTAs as part of the GNF-A Accident Tolerant Fuel (ATF) program.
Evaluation
The maximum allowed silicon concentration is not explicitly stated in either Revision 14 of the RAJ-II CoC (Reference 2) nor Revision 11 of the RAJ-II Safety Analysis Report (SAR)
(Reference 3). However, Reference 2 does reference American Society for Testing and Materials (ASTM) C996 (Reference 4) which states, in Section 5.3, a maximum silicon concentration of 250 µg/gU for Uranium Hexafluoride (UF6). GNF-A is requesting to ship fuel pellets that contain a silicon concentration of up to 500 µg/gU. This silicon concentration aligns with the standard for sintered fuel pellets noted in Table 1 of ASTM C776 (Reference 5), which is the form of material shipped in the RAJ-II transportation package. An evaluation of this silicon concentration against each chapter of the RAJ-II SAR (Reference 3) is detailed below.
Table 1: Silicon Concentration Evaluation Results SAR Chapter Evaluation Results Silicon is considered an impurity element and is not a radioactive material per its designation in ASTM C996 (Reference 4). Silicon Chapter 1 concentration is not limited by Table 1-3 in the RAJ-II SAR (Reference 3), and fuel pellets with silicon are made by GNF-A in accordance with the density requirements of SAR Table 1-5.
The 500 µg/gU concentration of silicon in the fuel does not affect Chapter 2 the overall structural performance of the package. The fuel pellets are made in accordance with the dimensions and theoretical density of Tables 3, 4, and 5 of the RAJ-II CoC (Reference 2).
Chapter 3 The silicon content does not contribute to the combustible material content and does not affect the thermal performance of the package.
Chapter 4 The silicon content is not a radioactive material and does not affect the containment analysis of the package.
Chapter 5 The silicon content is not a radioactive material and does not contribute to any dose rate of the package.
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SAR Chapter Evaluation Results The silicon content is not a fissile material and does not affect the Chapter 6 existing analysis. The fuel pellets are made in accordance with the dimensions and theoretical density of Tables 3, 4, and 5 of the RAJ-II CoC (Reference 2).
Chapter 7 The silicon content does not change how the package is operated.
Chapter 8 The silicon content does not change how the package is tested or maintained.
Based on the above evaluation, a concentration of up to 500 µg/gU silicon has no safety effect on the RAJ-II transportation package.
Conclusion
Based on the evaluation contained in this letter authorization request, GNF-A concludes that fuel pellets that contain a silicon concentration of up to 500 µg/gU have been adequately described and evaluated, meet the requirements of 10 CFR Part 71, and can be safely transported in the RAJ-II transportation package.
If you have any questions about the information provided here, please contact Lisa Schichlein at (910) 819-4815.
Sincerely,
Brian R. Moore General Manager, Core & Fuel Engineering Global Nuclear Fuel - Americas, LLC
Docket No. 71-9309
References:
- 1. Email, Pierre Saverot (NRC) to Lisa Schichlein (GNF), EXT: RE: RE: RAJ-II CoC -
Interpretation Question - Response from staff, July 2, 2024.
- 2. RAJ-II Certificate of Compliance for Radioactive Material Package No. 9309, Docket Number 71-9309, Revision 14, Package Identification No. USA/9309/B(U)F-96, July 24, 2023.
- 3. Global Nuclear Fuel, RAJ-II Safety Analysis Report, NEDE-33869P, Revision 11, September 2022.
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- 4. ASTM C996-20, Standard Specification for Uranium Hexafluoride Enriched to Less than 5% 235U.
- 5. ASTM C776-17, Standard Specification for Sintered Uranium Dioxide Pellets for Light Water Reactors.
cc: P. Saverot, USNRC M Catts, GEH/Wilmington SP Murray, GEH/Wilmington PLM Specification 008N7828 Revision 0
Document Components:
001 M240142 Cover Letter.pdf