ML20137F901
| ML20137F901 | |
| Person / Time | |
|---|---|
| Issue date: | 03/26/1997 |
| From: | NRC |
| To: | |
| References | |
| NUDOCS 9704010264 | |
| Download: ML20137F901 (279) | |
Text
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Official Transcript cf Proceedings O NUCLEAR REGULATORY COMMISSION :
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Title:
Technical Exchange on the Fabrication of ;
Mixed Oxide Fuel: Public Meeting i
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Docket Number: (not applicable) I Location: Rockville, Maryland O
Date: Wednesday, March 26,1997 l
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Work Order No.: NRC-1059 Pages 1-139 I h NEAL R. GROSS AND CO., INC. - ,
Court Reporters and Transcribers (,
1323 Rhode Island Avenue, N.W.
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010020 (202) 234a433 g; - j 9704010264 970326 10CFR l]llllll))l[llllll,[{[llllllll
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UNITED STATES OF AMERICA
- - 2 NUCLEAR REGULATORY COMMISSION O
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'4 PUBLIC MEETING !
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TECHNICAL EXCHANGE ON THE FABRICATION 6 OF MOX FUEL l
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7 +++++ l 8 WEDNESDAY ,
i 9 MARCH 26, 1997 ;
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11 ROCKVILLE, MARYLAND 12 1
13 The public meeting was held in the Auditorium 14 of the Nuclear Regulatory Commission, Two White Flint 15 North, 11545 Rockville Pike, at 8:30 a.m., Ted Sherr, 16 Chief, Regulatory and International Safeguards Branch, 17 NMWW, NRC, presiding.
18 19 PRESENT:
20 TED SHERR 21 MARVIN FERTEL 22 DAMIAN PEKO 23 BRYEN MARTIN i
I 24 MICHEL DEBAUCHE 25 GERARD LEBASTARD NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 PRESENT (continued) l 2 CARL DUCKWITZ f' ,
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V 3 MARILYN MEIGS 4 STEVEN DOLLEY 5 BERT STEVENSON 6 TOM CLEMENTS 7 UNTE CHEH 8 DAVID AIROZO !
9 PAUL LEVENTHAL 10 FELIX KILLAR 11 ARJUN MAKHIJANI l
12 13 14 15 16 17 1
18 l
19 20 21 22 23 I
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A-G-E-N-D-A 2 Aaenda Item
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's 3 Welcome, Mr. Marvin Fertel 4
4 Site Infrastructure & Building, Mr. Damian Peko 10 5
Fabrication Review for a MOX 6 Fabrication Facility 7 BNFL, Mr. Bryen Martin 28 8 MOX Fabrication 9 and Licensing Experience 10 Belgonucleaire, Mr. Michel Debauche 57 '
11 MOX Fabrication 12 and Licensing Experience 13 COGEMA, Inc., Mr. Gerard Lebastard 85 l r] l
'O 14 MOX Fabrication 15 and Licensing Experience 16 Siemens Power Corp., Dr. Carl A. Duckwitz 111 17 MOX Fabrication 18 and Licensing Experience 19 Summary, Mr. Marvin Fertel 133 20 21 22 23 24 0%
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- P-R-O-C-E-E-D-I-N-G-S i f 2 '
i, (8:39'a.m.)
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3 CHIEF SHERR: If you please could take your l
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4 seats now. I 5 Good morning. My name is Ted Sherr, Chief of 6
?
the Regulatory and International Safeguards Branch, NRC's l 7 Office of Nuclear Material Safety and Safeguards.
i The NRC 8
is hosting this meeting this morning at the request of the 9 Nuclear Energy Institute.
10 This meeting will comprise of presentations 11 related to the fabrication of mixed-oxide fuel. One of 12 the presentations will be made by a representative from-13 DOE, and the remaining presentations will be made by 14 industry representatives.
15 We look forward to hearing these 16 presentations. Since the DOE publication of the 17 Programmatic Environmental Impact Statement in December of 18 1996 followed by the publication of the Record of Decision 19 in January of 1997, much interest has focused on the mixed 20 oxide option.
21 The mixed -- the use of mixed oxide fuel in 22 nuclear power reactors is one of the two means that DOE 23 has selected for the disposition of weapons-usable fissile 24 materials, specifically plutonium. The other means is the 25 immobilization of plutonium.
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1 DOE anticipates that NRC will have regulatory I 2
authority over the plutonium disposition activities, ;
3 either by virtue of legislation providing for NRC external 1
4 regulation of DOE, or by virtue -- and/or by virtue of the 5 privatization of the activities.
6 As announced in the Federal Register Notice of 7 March 6, 1997, this meeting is being transcribed, and the 8 purpose is to inform the public and NRC staff about issues 9 involving the fabrication of mixed-oxide fuel. This 10 meeting is a follow up to a meeting that was held February 11 21, 1997 that focused specifically on the use of mixed-12 oxide fuel in light water reactors.
13 Before we commence with the presentations, I'd 14 like to make a few administrative announcements. First of 15 all, as I mentioned before, this meeting is being 16 transcribed by a court reporter and is also being j 17 videotaped. The transcripts of the meeting will be l 18 available in the NRC public document room within a couple 19 of weeks.
20 To facilitate the meeting, if the speakers, as l 21 well as questions along the way, individuals identify l 22 their name before making their statements. For you 23 smokers, there's the usual bad news. No smoking in the l 24 building. And the most convenient place is outside the 25 front door. It's sheltered from the rain. That's all we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W (202) 234-4433 WASHINGTON, O C. 20005 3701 (202) 234-4433
6 1 can offer for you.
2 Also, there's no eating or drinking in the
(_,/ 3 auditorium. For those of you who drank before, there are 4
some restrooms outside the back of the auditorium across 5 from the stairs. And that takes care of those things.
6 Our first speaker today will be Marvin Fertel.
7 Marvin is Vice President of Suppliers, International and 8 Fuels at the Nuclear Energy Institute.
9 Marvin, we welcome you, and we appreciace NEI 10 organizing this meeting this morning.
11 MR. FERTEL: Thank you, Ted. And I'd like to 12 thank the NRC for hosting this meeting. I'd like to thank 13 DOE for being willing te come here and give a presentation ia ty_) 14 on where they stand en their program. And I'd like to 15 thank our industry participants who have come from 16 overseas to participate; and some have not had very much 17 sleep, so we really appreciate their participation.
18 Those of you that were at the previous meeting 19 which talked about MOX burning in reactors know that we 20 sent out a bunch of papers after that meeting, and one of 21 the things, again administratively, I'd like you to do is 22 when you signed in, if you didn't put your address down 23 cogently so we can read it, I'd appreciate it if during 24 the break you could do that because it made it really (qj 25 difficult for our folks to mail out the papers after the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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1 meeting because we didn't have everybody's address, t
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1 And at this meeting, we will be doing the same i 3 thing.
4 Some of the papers -- in fact, most of the papers, {
in all honesty, won't be available during this meeting, so l 1
5 we'll be mailing them out afterwards. i They will be 1 l i
6 b
attached to the transcript when it shows up in the PDR, l 7 but we'll try and get those out to you later this week if j 8 we have your address. I'd appreciate that.
3 i
9 This is the second technical exchange that NEI I 4
t 10 has attempted to foster and sponsor as part of the .
i !
} 11 activities of our NEI working group on surplus plutonium ;
12 disposition. This working group was formed last fall.
- 13 It's chaired by Mike Wallace, Senior Vice President, * '
() 14 Commonwealth Edison.
15 Mike could not be here today, sends his 16 regrets; but he's very, very active and very much involved 17 in this particular activity.
18 For those of you that are not familiar with 19 the objectives of the working group, let me just sort of !
l 20 paraphrase them. It's to promote the development and 21 implementation of U.S. policies that achieve safe and 22 effective and timely disposition of surplus U.S. and i 23 Russian weapons plutonium. l l
24 It's to advocate, consistent with U.S. non- j
() 25 proliferation policies, the use of mixed-oxide fuel as a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISI,AND AVE., N W.
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preferable way to dispose of surplus weapons plutonium.
2 It's geared, just like any other NEI working group, to
\/ 3 coordinate industry activities to fulfill the purpose that 4 we have.
5 And we're trying to facilitate the 6
communication of technical policy and regulatory and 7
aconomic information about surplus weapons plutonium 8
disposition and particularly the MOX option. I think this 9 session today is indicative of that. We have a number of 10 countries that have a lot of experience in MOX 11 fabrication.
12 We in the U.S. are looking at licensing a MOX 13 fabrication facility down the road, and we're going to i
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(_-) 14 hopefully hear today about both the licensing process, the 15 safe operation of those facilities, and the lessons 16 learned from our allies in other countries that are doing 17 that right now.
18 Our working group has very broad membership.
19 It includes all of the major fabricators. It includes 20 about 17 utilities, if I remember right; and it includes a 21 number of experts in both non-proliferation policy, and 22 technical experts on the various aspects that we're 23 looking at in MOX fabrication.
24 Let me mention that what we'd like to do on
,c s (j 25 questions and answers, and we'd like to have as much 1
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questions and hopefully get as many answers as we have !
2 questions during this session -- after each speaker, what O 3 we'll do is we'll take on the order of five or ten minutes '
1 4- of questions.
5 And then at tk.e end of the whole session, 6 we'll take questions for the entire panel. Now, Damian, 7
who's going to present the DOE perspective on the program i
8 right now, will give his talk, and then he actually has to 9 leave, so we'll basically take all questions for Damian at 10 the end of his talk and then move into the rest of the 11 program.
I 12 We will take a break after the third speaker 13 and then reconvene here, and hopefully we'll finish on the 14 schedule which says 12:45 or somewhere between 12:30 and i
15 12:45.
16 Let me reiterate what Ted said. I think that 17 whenever anybody asks a question, please use the 18 microphones. Please identify yourself and your company.
19 We'll use the microphones up here for answering the 20 questions, and you can use the microphones there.
1 21 Why don't we start now. Let me introduce '
l
' 22 Damian. Damian is a cognizant engineer in the fissile t
{
23 material disposition group at DOE. He's heavily involved a
j 24 in the overall MOX program, and particularly the pit 25 aspect of it. He's here today to give us his view, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS j 1323 RHODE ISLAND AVE., N.W.
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he's got some help in the audience, I think, if there are 2
some questions that he can't deal with on where the DOE
'\(--)x 3 program is and the MOX fabrication aspects.
4 We certainly at NEI appreciate the fact that 5 DOE was willing to participate in this particular event.
6 They are not part of our industry, obviously; and their 7
insights and experience and their role in this is very 8 instrumental to where the program goes.
9 Damian?
10 MR. PEKO: Good morning.
11 As you've just been told, I'm Damian Peko.
12 And among other things, I'm a cognizant engineer for the 13 MOX fuei fabrication in the Materials Disposition Program.
['\
() 14 I'm actually going to be talking this morning about a 15 review of a feasibility review of DOE sites and buildings 16 for sit _ng a fuel fabrication facility.
17 The briefing information I'm going to be j i
18 discussing has been previously released. The review l
19 results of the DOE sites and facilities for the siting of l l
20 l a MOX plant were published in a December report which I ;
21 have here, Feasibility Assessment of Candidate DOE Sites !
22 and Buildings For a Mixed Oxide Fuel Fabrication Facility 23 For the Disposal of Weapons-Usable Plutonium. l 24 It's a bit long winded, but we are the V
/ 'T 25 govev.iment. Copies of this report are available through
%_)
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1 our office.
This brief is also an opportunity to clarify l
'[ 2 the DOE's position on that review; not that our position 3 has changed or it was ambiguous. The report stands for l
- 4 itself.
- r i i
] 5 But there's been some press articles that <
1 6 :
} stated this report would be the basis of the DOE siting a
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decision for the MOX plant, and that's just not correct.
i j 8 There's actually going to -- there's actually -- this is
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one element of a number of elements that are going to
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support the decision for siting of the MOX plant.
- 11 Next slide, please, t
l
- 12 The purpose of the review was to review the 1
i 13 suitability of sites in existing buildings being 14 considered to host the fabrication facility; again, to I-
[ 15 look at the feasibility, the technical feasibility, of the
- 16 sites and the buildings, not to select a site.
J t
17 Next slide, please.
3 l 18 In terms of the scope of the review, the team 4
j 19 gathered information on site infrastructure such as 20 utility systems, waste management, waste treatment, and
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! 21 the like; basically the infrastructure that would be t
{
22 needed to support a MOX fabrication facility. !
! 23 The team also gathered information on a number 24 of buildings such as the scope of modifications and risks i 4
25 associated with use of a particular building at a
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-1 particular site. The team also estimated rough order of' 2
magnitude cost for use of a particular building. And O 3 additionally, technical comments were specifically l
4 obtained from fuel fabricators and from site 5 representatives.
6 For example, fuel fabricators participated in 7
the review, and also participated. collectively in assembly 8 of the report. However, each of the fuel fabricators, 9 because they have their-particular and unique expertise, 10 also provided independent assessments of the sites and the 11 buildings to the DOE.
12 Next slide, please. i 13 Process parameters for the fabrication 14 facilities such as loading and throughput haven't been 15 determined. We haven't selected a reactor, we haven't 16 selected a fuel form. But to provide a common basis for 17 the review, we made a_ couple of assumptions.
18 Specifically, we assumed a dry MOX facility 19 with no aqueous processing. Additionally, we assumed a 20 throughput of 100 metrotons of heavy metal per year with a 21 ten year time -- with a ten year lifetime, and a plutonium 22 loading of about 5%. There's nothing magic about these 23 numbers; they were just assumptions for the purpose of the 24 review, and time will tell what the actual process
() 25 parameters are going to be.
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1 Also, to ensure that the features that we 2
(~x reviewed at the different sites were reviewed on a common
)
K/ !
3 basis, before the review, each site was provided the same :
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4 checklist and building questionnaire to fill out in !
5 advance or our arrival.
6 I Next slide, please.
7 The team included a DOE team leader (that was 8 me), and representatives from Los Alamos and from Oak l
9 Ridge who are responsible for developing MOX fuel I l
10 fabrication and for implementing reactor disposition of 11 surplas plutonium. Also included on the team were 12 representatives from the current MOX fuel fabricators to 13 make sure we had actual and current processing expertise l
1
(_/ 14 as a part of the team.
15 And it also included representatives from each 16 site to make sure that we have as a member of the team and 17 to help in preparation of the report somebody fron each of 18 the sites who was an authority on the site and could make 19 sure we had all the right information.
20 Site representatives included one 21 representative from the M&O contractor, and one 22 representative from the DOE office on the site.
23 The sites and buildings reviewed included 24 Pantex, which is a weapons disassembly plant in Texas; but 1
('h
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building available at Pantex that would be suitable for 2 the MOX mission.
(_ / 3 Also reviewed was the Savannah River site and l
4 its P-reactor assembly building which is a building built 5 in the 1950's for assembly of fuel for a production 6 reactor. At INEEL, we looked at the fuel processing 7
facility which was a building built, although never quite 8 completed, in the 1980's for the recovery of uranium from 9 spent naval fuel.
10 This building was never used for that mission.
11 At Hanford, we looked at the fuels and 12 materials examination facility which was built in the 13 1970's and the 1980's initially for the examination of (y) 14 breeder reactor fuel, and then subsequently for the 15 fabrication of fuel for the fast flux test facility, 16 although this building was never used for either purpose.
17 Next slide.
18 Regarding the sites' infrastructures, the 19 review concluded that all sites are feasible for a Mox 20 fuel fabrication mission, though not all sites -- although 21 the sites are not uniformly adaptable.
22 For example, at Pantex, there is a very 23 limited radiological waste infrastructure and no special 24 nuclear material processing infrastructure. At Savannah (n) x_,<
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radiological waste management infrastructure and plutonium 2 and uranium purification processing infrastructure, (D
(/ 3 although this plutonium and uranium purification 4 processing is only active at the Savannah River site 5 currently.
6 Next slide, please, t 7 As far as the three buildings go, the team 8 concluded that all buildings are feasible for a MOX 9
fabrication mission with some suitable modifications. And 10 not surprisingly, the team concluded that there are 11 advantages associated with using newer and larger l 12 buildings. 1 13 As mentioned previously, the team included
(~x
( ,) 14 representatives from the various current MOX fuel l
15 fabricators. The fabricators included all of these sites 16 and all of these buildings could be adapted for the 17 mission. However, they did express some concern regarding 18 potential contamination problems at the P-reactor 19 building.
20 Again, the P-reactor building was active for 1
21 many years; and while the site has done a good job of l 22 characterizing the building, anytime you put a new mission l 23 into an old building like that, it raises some concerns i
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regarding inefficiencies associated with adopting their 2
proccss to either the P-reactor building at Savannah River
[n\_j) 3 or the fuel processing facility at Idaho.
4 In other words they were basically saying 5
hey, if you shoehorn -- if we have to shoehorn our process l 6
into these buildings, we can do it; but that may result 7
in, you know, not the most optimum -- not the most optimal 8 layout, and you can have a penalty in terms of your 9 operational costs.
10 Next slide, please.
11 The team developed rough order of magnitude 1 l
12 costs for the installation of a MOX facility at each of 13 these sites and each of these buildings. These A
( ,) 14 installation costs included engineering, construction, and 15 start up. A new building at Pantex, or at any Fed Field 1
16 site for that matter, anywhere on any of the DOE sites l 17 where you basically start with a field and want to 18 construct a MOX facility, the rough cost would be about 19 $500 million dollars.
l 20 This $500 million dollars includes $250 21 million dollars for costs common to all the buildings such 22 as the process equipment and licensing. The remaining 23 costs are for construction and for physical infrastructure 24 upgrades. Use of P-reactor at the Savannah River would
(~)
t_,
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It would be about $100 million dollars savings 2 over a Fed Field site.
fm Use of FPF at INEEL would cost i )
\m/ 3 about $350 million dollars; and use of FMEF at Hanford 4
would cost about $300 million dollars, which would give 5 you about a $200 million dollar savings.
6 It's important to note that these are very 7 rough order of magnitude costs. This was not a detailed 8
cost review and it was never intended to be a detailed 9 cost review. Some of these cost elements that went into 10 these numbers are considered highly uncertain.
11 For example -- well, highly uncertain due to 12 limited understanding of the process. We don't know what 13 the ultimate process is going to be, what the throughput's
(%
( ,) 14 going to be, whether aqueous processing is going to be 15 used, for an example; but we simply made some assumptions 16 for the purpose of the review.
17 Another example of this is the licensing for 18 each of these facilities. We simply assumed that it would 19 be $35 million dollars for each of these facilities. It's 20 not clear to me -- it's not clear that $35 million dollars 21 is what it's going to take to license these facilities. I 22 don't think anybody knows at this point what it would take 23 to license a MOX facility in this day and age.
24 And it's also not obvious that it's going to r^N 25 be the same for all of these facilities. For example, on
(}
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i' 18 1 one extreme, you've got a building built in the 1950's 2
that was used extensively; and on the other extreme, O
i 3 you've got a building that's going to be built from 4
scratch to current codes and standards.
5 The licensing costs may vary considerably.
6 Nevertheless, we really didn't have a solid basis for 7 estimating the licensing costs, so we simply said $35 8 million dollars. The point being that these costs are q
t 9 only estimates and they shouldn't be taken -- they i 10 shouldn't be taken as being too precise.
11 However, the relative costs are considered 12 indicative of the differences among the costs at the sites 13 for facility installation. Also, because -- also, it's
() 14 important to note that these cost differences are minor 15 compared to the estimated life cycle cost, and this is 16 also a rough number of about $1.5 billion dollars. j 17 So the cost differences associated with the 18 installation of the facility could be overcome by 19 operational costs. In other words, we've given a ranking 20 for most expensive to least expensive our estimated costs l 21 for installing a MOX fuel fabrication capability at each 1 1
22 of these sites.
23 But if we also came up with an estimate of the 24 life cycle costs and ranked them from the least expensive
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1 reason -- this doesn't mean or imply that the same ranking 2 would hold.
(~'Ni l
\s / 3 Next slide, please.
4 In summary, all sites and buildings reviewed 5
were suitable for eiting a MOX fuel fabrication facility, 6
though there are differing advantages and disadvantages 7
with the different sites and with the different buildings. i
)
8 Also, one -- previous slide.
9 Also, use of existing facilities could save up 10 front costs, and that's fairly obvious. But, such savings 11 are moderate compared to life cycle costs, and could I
12 actually be overcome by differences in the operating 13 costs, r~'
(,N) {
14 Next slide, please.
15 A couple of final points. This review was 16 only one of many sources that was and that will be used to 17 make programmatic decisions on disposition of surplus {
18 plutonium. This review will be used, along with many l 1
19 other studies. For example, we have technical summary l 20 report out, we've got an environmental impact statement 21 under de,elopment, and there are other things that are 22 going to be used to making the siting decision.
23 That's all I wanted to say, and I'd like to 24 take questions now.
~
25 MR. FERTEL: Please use the microphone to ask
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Damian questions'and introduce yourself and your company. f 2 Thank you.
3 MS. MEIGS: Marilyn Meigs, BNFL.
4 I was wondering whether it was considered l
5 useful to have the NRC representatives on these site tours !
6 and involved in the assessment to give their eye and their !
(
7 experience level to the review of these buildings and i
8 facilities. I know you levelized the cost of licensing, ;
9 but I would imagine that in particular the older buildings 10 with less rigorous documentation may be considerably more l
l 11 expensive to license than, say, green field or some of the l 12 newer facilities.
- 13 MR. PEKO
- You raise a good point. We 14 levelized those costs not because we thought they'd be 15 level, but simply because we didn't have a means to get 16 what we considered a reasonable estimate at the time. And 17 we don't know; they may be level, but maybe not.
18 Nevertheless, the point you made about having 19 the NRC assess the sites I think is entirely appropriate. l l
20 We intend to have these facilities licensed, and the NRC l 21 is going to have to get involved in that sooner or later.
l l
22 And familiarity with the sites would be appropriate. I l
s 23 mean, a review of the sites would be appropriate. i s l I 24 MR. FERTEL: Go ahead.
4 25 MR. DOLLEY: Steven Dolley, Nuclear Control
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21 1 Institute.
2 What was your working assumption for the cost
("')
(__/ 3 of safeguards for the facilities, and what sort of 1
4 safeguards did that include' l
5 MR. PEKO: This would be a Cat One facility.
4 6
We didn't -- as I mentioned previously, this wasn't a very 7 detailed cost review, so we didn't go down in all of these 1
l 8 cases and say well, it's going to cost X dollars for 9 safeguards and security; but we did look at more of a 4
10 macro level. Well, did the pitus have to be upgraded, was 11 there an emergency response force that was available that 12 could be shared with other elements of the site, or would ;
13 the facility have to carry that burden alone?
('~)
( ,/ 14 So I can't give you specific details about
- 15 cost or specific assumptions about safeguards and 16 security, but this would be a cat one facility.
17 MR. KILLAR: Gellis Keller, Nuclear Energy 18 Institute.
19 On the making the RFP for going forward with a 20 licensing and construction of a MOX facility, you're going 21 to have to identify one of these sites. How much in 22 advance of releasing that RFP are you going to identify 23 the site, and how much information are you going to 24 provide as far as the environmental assessment and things f 25 like that to help the various proposals to understand the
(_-
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22 1 site itself?
2 MR. PEKO:
73 Currently the RFP is envisioned as
(
\ >) 3 a two phased process where the first phase is a 4 qualification bid, and then that's followed out with a 5 conceptual design. The sites will -- a specific site will 6 not be identified for the first phase of the bid process.
7 And as far as the schedule of the bid -- as far as the l 8 schedule of the bid for -- it's not even -- it may not be l 9 necessary to identify the site for the start of the 10 conceptual design phase.
11 It may -- the site may be identified sometime 12 after the bid process -- after the second phase of the bid 13 process is initiated.
A
(,) 14 MR. MAKHIJANI: Arden Makhijani from the 15 Institute For Energy and Environmental Research.
16 When I visited the Sellafield SMP plant 17 recently, the officials there told me that the SMP cannot 18 -- the safety analysis of the SMP wasn't for weapons grade 19 plutonium and that it's not designed to handle weapons i 20 grade plutonium. l 21 MR. PEKO: I guess like I said, rules out SMP.
22 MR. MAKHIJANI: Well, I have a question about
- 23 -- you said that you're going to bring in BNFL and so on.
l 24 My question isn't about SMP. It's about the safety l
/~ l (N) 25 analysis and the using the experience of building these l l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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23 1 automated plants.
2 Are you going to -- have you reviewed these t'h
's 3 safety analyses of these automated plants?
4 What are the reference designs?
5 What is the relevant experience regarding 6
weapons grade plutonium specifically that you're going to 7 import from these folks?
8 MR. PEKO: You raise a good point. The 9
current designs and assumptions behind the operating MOX 10 plants are predicated on a different fissile content for 11 the MOX -- or for the plutonium and the going into the MOX 12 fuel. And all of that will have to be reassessed to 13 ensure you don't exceed criticality limits. Effectively,
/G
()_ 14 some parts of the equipment and some parts of the process 15 are going to have to be redesigned.
16 As far as have we reviewed it, not yet.
17 That's getting ahead of the game, and we haven't picked a 18 process, we haven't picked a site, we haven't picked a 19 vendor. And the specifics of the design will have to be 20 reviewed at the appropriate time. And again, it's not for 21 the DOE to come in and tell people what's safe and what's 22 not safe.
23 This plant will be licensed by the NRC, and we 24 don't presume to inject ourselves into that process and to r~
( )s 25 change their way of doing business.
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24 i
1 MR. MAKHIJANI: But I presume that at the I 2 :
/~
appropriate time, all the safety documentation from these '
l
_ 3 foreign vendors will be made public.
4 MR. PEKO: Again, this plant will be licensed 5 by the NRC.
And the NRC will be -- and the NRC and the 6 company, and the vendor and the consortium, or however 7 1 it's worked out, will be -- in going through the licensing !
\
8 process, will assure the safety of the plant. And the DOE I 9 would not presume to inject itself in that process and ,
i 10 tell them how to do their business differently.
L 11 MR. MAKHIJANI: That wasn't the question.
]
12 The question was whether the DOE, which is l
13 going to purchase this plant, is going to make the safety l n
( ,) 14 information public.
15 MR. PEKO: I don't have the answer to that 16 question at this time. I'm not -- the bid package is i
17 being put together by Pat Roades who is a colleague of 18 mine who's also involved with development of this, so I l l 19 can't give you an answer.
20 MR. FERTEL: Paul?
21 MR. LEVENTHAL: Paul Leventhal from the i
22 Nuclear Control Institute.
23 Before the NRC can engage in licensing, I 24 believe you need enabling legislation. And that, of f~ 25 course, is coming out of the DOE study right now on s
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25 1 external regulation.
2 g Can you explain what you're in a position to ks' 3 do or not to do prior to the enactment of that 4 legislation?
5 How far can this process proceed in the 6 absence of enabling legislation?
7 MR. FERTEL: Bert, could you use a microphone.
8 MR. STEVENSON: Bert Stevenson, Department of 9 Energy.
10 The full procurement plan for obtaining the 11 MOX fuel fabrication facility has not been completely 12 prepared. And as we go through that process of obtaining 13 the request for qualifications and the request for g)
(, 14 proposals in that, we do expect to have the licensing 15 information and process so that the people who are l 16 preparing their proposals will have a good cost basis upon 17 which to reply.
l i 18 We don't have all of that information prepered 19 at this point in time, but it is expected that that will
! 20 be part of the RFP.
l 21 MR. FERTEL: Bert, could you just stay there l 22 for a second and let me ask a follow on question given 23 your answer?
24 If I understand what you said correctly,
() 25 you're going to, as part of the RFP process, provide NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAF'D AVE., N W.
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26 1
whoever's going to bid on it information on what they'll l
2 have to submit to get a license, going to a question that i 3
was asked a little earlier of Damian.
4 How much involvement do the NRC folks have in 5 defining that, because it reall', is their side of the 6 fence that you're on when you're trying to say what's 7 going to be required for licensing? )
j 8 MR. STEVENSON: And towards that end, the 9 department has established a dialogue with the NRC that 10 has already been started by some meetings between DOE and I
11 the NRC at which they are going to have working level J 12 meetings and determine a lot of this in parallel with 13 preparing the necessary procurement actions.
14 so it's a very important timing question so 15 that these discussions with the NRC, with the 16 environmental impact statements that have to be prepared, 17 with some of the other technical information, are all 18 accomplished in time to meet the schedule of the issuing 19 of the RFP.
20 MR. FERTEL: This may be unfair and the NRC 21 may not want to respond, but is there anybody from NRC in 22 the audience that wants to give their perspective on how 23 they see that going given this RFP process is moving down ,
1 24 the road? ,
25 And from the standpoint of those of us that NEAL R. GROS 5 I COURT REPORTERS AND TRANSCRIBERS I 1323 RHODE ISLAND AVE., N.W. j (202) 2344433 WASHINGTON. D C. 20005 3701 (202) 2344433 ;
27 1 would like to see this program get implemented p
2 effectively, clearly timing is critical; and good, solid YJ 3 information from the NRC to the DOE process is critical.
4 Ted?
5 CHIEF SHERR: As Bert mentioned, there has l
6 been some meetings. The NRC was involved with DOE in {
l 7 their environmental impact statement development, and we 8 provided the information on the regulatory implications of 9 the various alternatives. l l
10 As a follow on to that activity, we are 11 working to extend the current reimbursement agreement with 12 DOE where DOE is seeking our advice and comment on the i 13 various steps they're taking in the procurement process. ;
(~h '
\ ,) 14 That's basically the status of that. 1 15 I think the question earlier about in terme of 16 would the licensing information or the safety informaticn 17 be available to the public, if NRC's going to be involved 18 in the regulatory proccas, assuming it's not classified 19 information, -- I wouldn't think any of it would be that -
20 - there's no question that the information would be 21 available to the public.
22 MR. FERTEL: Thank you, Ted.
23 Are there other questions from the audience?
24 Are there any questions from members of the (nx -) 25 panel that you'd like to ask of Damian because he's going NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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28 1 to be leaving?
2 Okay, well Damian, thanks very much.
3 Bert, thank you.
4 (Applause.)
5 MR. FERTEL: Our next speaker is Bryen Martin 6 from BNFL. Bryen has spent over 20 years with BNFL in a 7
position of increasing responsibility for both safety 8- evaluations and licensing. He spent about a decade, which 9 maybe indicative of how long it may take to license a 10 facility, licensing Thorpe.
11 And since 1992, he has been heading up a team i
12 of approximately 120 safety engineers that are looking at 13 the safety and licensing for all new BNFL facilities. I 14 think we're -- certainly NEI is very pleased to have Bryen is come over and be at this presentation today to share the 16 knowledge and experience he has.
17 Bryen?
18 MR. MARTIN: Good morning.
19 I'm going to be talking to you today outlining 20 our MOX plant experience in the UK, the basic framework of 21 regulation under which we operate, and get licensing for 22 our plants within the UK, the type of safety management 23 system BNFL has created for itself in response to our goal 24 setting type of regulatory legislation, the particular
() 25 experiences that we've had with the construction and NEAL R. GrsC55 COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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29 1 licensing of the Sellafield MOX Plant; and then I'll draw 2 the talk together with some conclusions.
i A
(_) 3 If we turn to our MOX plant experience which 4 stretches back over three decades, in the 60's, we were !
1 5
involved in the fabrication of a number of lead test 6 assemblies for MOX. That continued in the UK with our 7 experience with our own fast breeder reactor program, 8 during which time we constructed over 95,000 fuel pins.
9 Since 1994, we have been building effectively 10 lead test assemblies for MOX for civil power reactors for 11 our customers at Sellafield. And we are just in the 12 process of commissioning at the moment our new Mox s
13 facility. We also have considerable experience as a
( ,) 14 uranium fuel fabricator both for the UK's first and second 15 generation of gas cooled reactors and now for P and BWR '
16 reactors.
17 Turning to the UK regulatory framework, this 18 begins -- thanks, Tony.
19 Turning to the UK regulatory framework, this 20 begins by recognizing the various international standards, 21 those promulgated by UN agencies, particularly IAEA in 22 both the safety series areas and in safeguards; the advice l
1 23 offered by ICRP, and then that legislation which comes 24 from the European Union level.
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30 i
- 1 and that feeds down to the government departments which !'
2 contain the regulatory agencies within the UK. The
!( 3 Department of Trade and Industry, the DTI, is responsible !
l
- . 4 for the general UK energy policy such as the decisions to b
q 5 proceed with civil MOX fuel construction.
1 1
6 The UK Department of the Environment contains l
j 7 both of the UK based regulatory agencies. Our Health and i
- - 8 Safety Executive, which contains the Nuclear Installations i
9 9 Inspectorate, is responsible for the nuclear safety j 10 licensing of our facilities in the same way as the NRC in 1
4
{ 11 the United States.
i j 12 They're also responsible for the general and i
13 conventional safety aspects, those tasks which I believe i-() 14 are covered by OSHA.
15 Turning to our environmental agency, they both 16 cover the radioactive waste strategy for the UK; and then 4
17 within.that, they grant discharge authorizations for
- 18 emissions from particular facilities. All of the i
j j 19 safeguards regulations within the UK, and indeed within 20 Europe, is covered by EURATOM effectively on behalf of i
21 IAEA which is a European-wide safeguards inspectorate. l 1
22 Turning to the next slide, if we look at our 23 health and safety policy in the UK, this is very much a 24 goal setting process. So the information which is
() 25 available to particular licensees comes in two forms.
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]
-..__..m _ . . . - . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ - - .
31 1 1 First of all, NII published their safety assessment i
2 principles. It's a fairly slim document.
O' 3 And in response to those, all licensees, and '
4 in particular BNFL in this instance, are required to l 5 create a company safety management system which explains 6 how those principles are enacted. And that is where the l
{
7 volumes of documentation start to occur within the UK, '
8 that generated by the operator.
9 The second area is that each nuclear site in :
10 the UK is required to be licensed. And in response to 11 that license, which again is a very slim document, each i I
12 operator is required to create a set of SLR's -- that's 13 site license regulations -- which explain the way in which (
() 14 all those requirements are met.
l 15 Turning to a bit more detail on the safety 16 assessment principles, there are 333 of these, each of 17 about a puragraph in length. And they address such issues 18 as the basic safety standard's, the safety assessment 19 methodologies, those for both deterministic and 20 probablistic type safety assessment and analysis; the 21 design and engineering requirement.
22 So that's some quite specific principles in 23 there such as separation and fire barriers and the length
! 24 of times you would have a withstand capability of a fire, 1
() 25 on to quality assurance principles and issues relating to NEAL R. GROS 5 COURT REPORTERS AND TRANSCRIBERS l
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,, _ _ _ . . - _ - - - - -- - -i
32 1 the siting of nuclear plant within the UK.
n 2 And we'll get some specific details of these
- )
k/ 3 as we turn later in the talk to the MOX facility itself.
4 Turning to the site license, this follows a 5 general format common to all civil nuclear sites. Power 6 reactors, waste treatment plants, MOX fuel facilities, I l
7 uranium fuel fabrication, enrichment facilities -- all of l
8 these are licensed under a common nuclear site license. l 9 It is not prescriptive; but rather it 10 identifies the important areas to safety and requires that !
11 the particular licensee makes appropriate arrangements 12 that is appropriate to the particular challenge of the !
I 13 facility. And clearly, those arr.ngements will be (l 14 different for power reactors to MOX fabrication plants to l 15 uranium fabrication plants.
16 And the Sellafield site license, as with all 17 site licenses, contains 35 standard conditions. And on 18 the next slide, we have some examples of those standard 19 conditions. Of particular interest in licensing a new 20 facility are clearly those that relate to the construction 21 and installation of new plants and the permits we are 22 required to receive from the regulator before we are 23 allowed to commence construction, or to commence 24 commissioning, or to commence operation of a plant;
<m (x, ) 25 The form of the safety documentation that's l NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N W.
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_ m. . . _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ . _ _ . . _ . _ _ _ _ _ . . _ . _
33 1 required to fully support and substantiate those claims 1
2 for the safety of'our activities that we make, and the !
3 types of internal to the company review processes through
)
4 meetings that we call nuclear safety committees-that we i 5 are required to work through before we make any submission 6 of documentation to the regulators.
7 Turning on to the safety management system 8 that BNFL has created in response to this safety objective 9 that the regulators sat down, this falls within four areas 10 within the company. There are our own standards and 11 criteria to which we are working and I'll come on to soine 12 examples of those.
13 There are the assessments which we make to O
14 ensure that we have met the standards and the criteria 15 performance that we have set for ourselves. And 16 independent from this activity within the company, we have 17 an audit capability which reports independently of all l
18 operating and construction divisions to our executive i 19 director of safety, health, and environment that is L
20 responsible for full internal review and independent 21 nuclear safety analysis of those activities we carry out.
22 And this is all conducted within a general 23 framewo.-k of review where we are aiming to continually 24 improve our safety performance and looking for recognition 25 of the general achievement of world class safety in all of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS i 1323 RHODE ISLAND AVE , N.W.
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34 1 our operations.
2 Turning next to the details of the standards
- -x f h x/ 3 and criteria that we apply, we have a number of standards 4
that relate to what we term best engineering practice that 5
we wouid apply to facilities regardless really of the 6 details of any safety analysis simply because it makes 7 sense to have a well constructed, robust plant.
8 We have a number of targets for normal 9
operational dose levels, all of which we are calcu?.ating 10 to ICRP 60 methodology. So they will tend to be 11 conservative with reference to dose levels quoted in the 12 U S.
And we have a number of accident risk criteria which 13 relate to those hazards that we're unable to completely
( ,) 14 eliminate from our processes both for those accidents 15 which are initiated within the plant by process 16 maloperations, and for those which occur external to the 17 plant such as aircraft crash or earthquake.
18 Before I put up a slide of some of our topics, 19 it's necessary to explain the concepts of tolerability of 20 risk within the UK which have been set down by our 21 regulator. The health and safety executive has 22 established these, and they have set them with reference 23 to those industries, those other industries, which are 24 considered safe by society.
I O) v 25 And the basis of this is that there is an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W l (202) 234-4433 WASHINGTON, D C. 20005-2701 (202) 234-4433
35 1 increasing -- there's a spectrum of increasing risk. At !
2 some point, any industrial process would be considered an
(~% 1
(_) 3 intolerable level of risk. And clearly, that is a l
l 4 developing -- that is tending to fall over time if we 5 think of standards in the 18th and 19th century in 6 industry compared to those that we achieve today.
i 7
But there is set at some point a basic safety j l
8 limit, a BSL, above which any activity is intolerable; it 9 would not be licensed. And if it was operating, it would 1
10 be closed down. At some lower level, there is a basic 11 safety objective. And this is the level we are aiming for 12 in new plant design, and that is at the region at which 13 the risks would be considered broadly acceptable.
r'
( ,N) 14 But there's still a requirement even at this 15 level to use the ALARP, as low as reasonably practical 16 principle, to search out wh.ther there are any further 17 safety benefits. In this range between the two, there is 18 very definitely the need for a full ALARP study, full cost 19 benefit analysis to justity continued operations.
20 The type of facilities that fell within this 21 range are that we have some plants that remain containing 22 waste from our weapons program in the 1950's. As much as 23 we might wish them away, when ce wake up in the morning, 24 they're still there. And it's clearly in the interest of n
(
%)
) 25 ourselves as an operator, our regulators, and society in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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. _.._m _ _ _ . _ . _ . _ _.. -_ _ _ _ ... ..._ . _ _ _ _ _ _ _ - _ . . _ . - _ . _ _ . .
36 i
\
i general that we move to immobilize those wastes as quickly "
1 2 as possible.
3 Because we are moving back into old facilities 4 to do that, they are inevitably not designed to the sorts 5 of seismic and other criteria we would design today.
6 Anyway, the topic of today is MOX, so we will 7 move on from that to look at some of these safety 8 standards and criteria that we have adopted. And on the 9 right-hand column, to set the BNFL targets in context, are 10 the basic safety limits and the basic safety objectives 11- are set by the regulator.
' 12 In particular, on operational dose, we are 13 aiming to achieve an average operational dose below five
! 14 millisieverts per year. That's below .5 rem per year.
15 Again, adopting ICRP 60 methodology. When we are looking 16 at accident risk, we are looking at accident risks below 17 10 to the most exposed member of the public, generally 18 taken to be at the site fence.
19 And this is from the whole of the site. And 20 there's various other data there which is available within 21 the slide.
22 Moving on to talk a bit more about safety 23 assurance principles, we are aiming to apply what we call i 24 process safety within the UK. That is, as far as 25 possible, we are looking for passive processes and plant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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l
37 1 with reduced complexity, with reduced inventories of 2 material.
l 3
We are looking for deterministic safety within 4 the design. That is, looking wherever possible for 5 criticalities or hazard. We are looking for geometrically 6 favorable and ever safe designs of process plants. We are ;
7 subjecting all of the systems that we design and bring 8 forward to systematic engineering review. ;
j 9 We carry out a fully detailed probablistic {
)
10 safety assessment, the type of analysis which would be 11 termed Level 3 within IAEA technology for reactor builders 12 and vendors for all of our chemical plants. And we are l
13 passing all of that through the regulatory approval 14 process, and we are carrying out full technical peer 15 review and independent nuclear safety analysis.
l 16 Moving on to talk a little bit more about 17 procese safety, something we are really passionately 1 J
18 committed to, this is aiming to put safety integrated into 19 the design team. This enhances real safety, and it 20 reduces plant complexity. We have learned from j 21 operational experience that if we leave safety out until l
) 1 22 it's been designed, we get a number of bo.ted on trip and j 23 protection systems where we could have hal an ever safe, j 24 physically safe process route.
t 25 Turnine now to the evolution of the MOX plant
(
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I
~ 38 i
i i
safety case, and this is turning to specific experience of r
j 2 1
the Sellafield MOX Plant, we're looking at various stages 5
-- design, construction, commissioning, and operation.
3 i,
{
~4 And we've taken this plant, looking at the time line on '
1 l a
5 the bottom, from the start of the design process in 1993. !
1 6
We're currently now in the commissioning 1 :
j 7 phase, and we expect to be producing our first MOX fuel l i
8 assemblies for our customers from this plant in 1998. [
9 That's being facilitated by building on the considerable c 10 experience we've had with large capital projects on the i
11 Sellafield site as we've upgraded the entire liquid and
^
12 solid waste handling systems over the past ten years on 1 13 that site. l
- . 14 It's also being facilitated by our willingness l 15 to develop methodologies and to adapt methodologies to j 16 those which the regulator finds easy to process. So we
- 17 are submitting material in a form which makes it easy for i
j 18 our regulator to find within our cases the type of
! 19 information that he needs to audit in order to have I
4 20 assurance that we are meeting the targets set.
1 21 If we look at the two lines of safety
, 22 assessment, because environmental and nuclear and i
23 conventional safety is separated out, different regulatory i
L 24 agencies; in the environmental case, we have a planning ,
1 4
! 25 permission process where the local authority at a level i
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i me - - - 1ri-,--+ + - - - -
-,-,,y-- y y - gi-v-y w-
39 1 more local in the UK than a state, but the elected 2 officials in a local authority consider an application for
(~'h
(_ ,/ 3 planning permission -- in this case, for our MOX process -
4 - and decide whether that should be granted or not.
5 And that's also accompanied very early by an 6 environmental impact statement from the plant which is a 7 publicly available document. The stage that we're at at 8 the momenc is we are seeking a discharge authorization for 9 the facility for the airborne -- a small level of airborne 10 discharge that come from the process.
11 That's currently going through a public 12 consultation in the UK which is publicly open to any 13 challenge and indeed, any support that individual members (n) 14 of the public or organizations wish to make. And the 15 regulator is required to take account of all those 16 comments.
17 If we turn to the safety case, very early in 18 the project, we bring forward a preliminary safety case 19 which is aimed at opening a dialogue with our regulator, 20 identifying the main issues, those on which we are doing 21 confirmatory research and development; and allows the 22 regulator to indicate any areas where they would wish us 23 to provide more detail so that we can accommodate a fairly 24 swift, but still rigorous, regulatory process by
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40 l 1 are properly addressed.
2 n And this proceeds through a case required for 1
(._/ 3 construction licensing, a case required for commissioning {
4 licensing, and a case that's required for going into 5 operation.
6 Okay, next slide; thanks.
7 All of this is supported by a very detailed 8 hazard identification technique. Typically in the 9 nuclear chemical industry, we are building plants which 10 are the first rather than the repeat build experience that 11 reactor vendors have. So therefore, we have learned from 12 chemical industry experience and use a technique called I 13 HAZOP, hazard and operability study, which brings together t'~T
( ,) 14 a multi-disciplined team to search out whatever deviations
]
15 and maloperations there may be within the process.
16 We then use more traditional failure modes and 17 effects analysis type techniques to review and to validate
- 18 the result of that study. And as we have the final design 19 information -- that is the drawings and process diagrams 20 which have all of the plant and process lines and 21 equipment on, we repeat that in a very detailed level 22 looking for each process line, for each process vessel, at 23 the effects of -- for example, in a plutonium system, more 24 enrichment than we expected.
,. m 25 That is, more plutonium in the MOX feed than (v)
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l 41 1 expected or maybe less plu-240 content within the 2 plutonium than expected. So we have compiled for a MOX
- ) 3 plant --
for our Mox plant, but that would be the basis of 4 any generic MOX process a hazard listing which is of some 5 considerable thickness.
6 So we understand well the potential hazards of 7 MOX facilities. The main hazards that we identified, not 8 surprisingly because this has been pointed out earlier, is l
9 a plant whose mission is civil plutonium for reuse in l l 10 reactors by our customers. So in this type of material, t
11 there is an operational dose challenge.
12 That operational dose challenge increases with I
l 13 the amount of burn up that the original material had in a
() 14 reactor. So the operationa. dose challenge for a civil l 15 MOX fabrication plant is maybe four to five times that 16 that you would face in a weapons grade disposition MOX l 17 facility.
l 18 A second hazard there is criticality. And the 19 third hazard is loss of containment. Loss of containment 20 in two senses: the first because very small quantities of ,
21 plutonium in air an ingested in air give rise to an 22 internal dose commitment which would exceed our target; and secondly, loss of containment in the safeguards sense
, 23 I 24 because clearly all plutonium facilities require very high
() 25 qualities of safeguards and security systems.
i
- l.
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l 42 1
If we turn now to the details of how we 2 approached our operational dose assessment, we have 3 considerable -- 30 years plutonium facility operation 4 experience at Sellafield. So we have a very good data 5 base from which to validate our dose type assessments for j 6 a MOX facility.
7 And we went through an iterative process of 8 starting with our initial design concept -- the way it 9 would be manned, the way it would be operated, and seeing 10 whether we met our dose targets, and we didn't. And we 11 iterated around the design -- I'll come to that in a 12 minute -- to confirm we had reached ALARP before we 13 finally decided with the third aesign concept that we 14 brought forward that we would meet our targets here.
15 If we turn to the details of this staged dose 16 assessment, we have a target for the plant. The plant 17 will produce 120 tonnes of MOX fuel a year either for PWR 18 or BWR reactors. And those are target figures of five i
19 millisieverts. That's .5 rem per ye .. And the most 20 exposed worker group at ten. Not surprisingly,, the most j 21 exposed worker group will be those involved in, maintenance 22 operations.
23 Well, we started off with a plant concept 24 which married front end plutonium plant technology with 25 really conventicnal uranium fuel fabrication experience.
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43 1 So it had in the back end a fairly high degree of manual f 2 involvement. And that for a civilian MOX facility lent to s- 3 a very unacceptable dose uptake.
- 4 So we have moved to a process which has a-i 5 fully remote fuel assembly. So all of the fuel. assembly i
6 activities are done within shielded caves. And that was a ll 7 significant step forward to hitting our target. We had-i j 8 still not hit our target, so we carried out further i
I 9 automation at the front end of the MOX process.
10 And we now have a plan which, for our highest 11 burn up material, we would predict to achieve 4.6; and for 12 the most normal operational case, we would predict to 13 achieve 3.1.
14 We turn -- move on to talk about the 15 criticality safety case. There is a high degree of 16 process safety within the SMP design. Within its design 17 basis, this is achieved by using vessel and containment 18 geometry. Our criticality assessment techniques in the UK 19 have used our monk code that we have very good 20 relationships with the U.S. criticality community.
21 And we have done considerable experience with 22 benchmarking against KENO. And we have a full capability 23 of running KENO. And clearly, if we were to get involved 24 in designing a' facility for the U.S., we would run on U.S.
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44 j i
i direction. '
i 2 This takes account of really the
( 3 internationally recognized and agreed uncertainties and 4 conservatisms in some parts of MOX fuel validation. We 5 have done all of this, and we have managed to, in process !
6 safety and passive safety terms, reduce the level of 3 7 complexity of the safety and protection systems to three .
8 systems at the front end of the plant which are very high I
9 integrity, very robust system, highly visible both to our '
10 operators and operating rules and maintenance crews; and l l
11 that leads to good production.
32 But they're are also highly visible and clear 13 to our regulators so there's a firm basis for the safety
() 14 case for this plant. And that tends to lead to relatively
- 15 prompt regulatory approval because it's only necessary to l 4 . 16 review in depth three systems here.
17 Within this, we look at -- we've looked at all !
, 18 single failure fault conditions. So a single failure 19 fault condition would be an excessive moderator, so we've 20 looked at the system with normal plutonium / uranium 21 mixtures but optimally moderated. And that's safe i
~
22 throughout the process.
{
23 We've looked at the absence of plu-240, which !
24 is of course the case in a weapons grade material. And 25 for that single failure fault condition, the plant is also No NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 1 safe. We have not licensed the plant on that basis, and 2 we have not analyzed all the fault conditions on that I
(_)i 3 basis, to pick up the earlier question, because that is 4 not the mission of this facility.
5 To move on to the probablistic safety analysis 6 which concerns double contingencies so that's maybe 7
failure of match control and as well as the ingress of 1 l
8 moderator into the process, and this is a completely dry 9 process.
10 The one moderator which is added is a 11 substance, zinc stearate, and a very small gram quantity l 1
12 that's added to kilogram quantities of the Mox material in 13 order to lubricate the flow of the material through the l
(-, 1
( ,) 14 various bore mills so we are not getting that MOX caking 15 or MOX hold up in the process.
16 But nevertheless, and even though we have many 17 safeguards in batch size and controls and trip system, we 18 analyze for optimum ingress of moderator. And in this 19 area, we have carried out a full and extensive 20 probablistic safety analysis of all of these multiple 21 maloperations, and we have demonstrated our confidence 22 that the summed frequency of criticality incidence will be 23 below 10-5 a year.
24 Within that PRA, because there are in
( ) 25 sensitivities in the UK to licensing of process control R)
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i 46 l i
1 software, we have not taken any account of the 2 computerized process control system. These things are, of
\I 3
course, well validated throughout the chemical industry l 4 an, do have a very high degree of reliability and 5 performance. i 6
But nevertheless, we have backed everything up 7 with independent hard wired based system. And we also 8
make no claim for prompt operator actions in response to i
9 any maloperation.
I 10 Moving on to the third area, containment in 11 SMP, we have very high standards of containment. Those 12 are both beneficial to operational dose considerations; l' also very beneficial to safeguards considerations.
,a
( ,) 14 Basically the process runs totally contained l 15 within process vessels or within containers themselves the 16 way the fuel pins are loaded from one end of the fuel pin 17 in chores that we keep -- we maintain for containment 18 right down to the back end of the process while only 19 having a very short, inch or so's length, of the pin 20 coming through into the primary containment.
21 So those then exist within gloveboxes which 22 provide the secondary level of containment. And those are 23 within a general building which is a fairly massive civil 24 structure, both with shielding and earthquake resistance n
() 25 which provides a third level of containment.
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47 4
1 J All of our gloveboxes have an emergency breach k- 2 protection system using vortex amnifires which are some of l
3 these very clever fluidic, non-moving part devices which 4 sense the failure of a glove on a glovebox and flick over -
q
}
l 5 from a low flow, which is what you'd want in normal 't i I
!. 6 operations because you don't wish it to be moved around
\
. 7 the system; to a very large flow through the failed i
8 glovebox, you maintain containment in that category.
e j 9 And all of the plant is seismically qualified. ,
10 We start at this site from a one-in ten thousand year l
11 design basis event. And that, for the Sellafield site, 12 has a .25 g ground acceleration. We've located the 1
l 13 facility fairly sensibly an extra plutonium store in order 14 to minimize the transfers of plutonium around the site. j t
j 15 The store is part of a fairly massive facility ;
J 16 which in an earthquake would kind of wobble like a jelly 4
! 17 and put an additional challenge onto the Mox plant. So l 18' the actual 'esign d basis assessment is a ground level j 19 acceleration of .44 g, and that's because of the coupling 20 between two adjacent buildings.
l 21 And as we use a gravity flow process where the 22 MOX powder flows down through the process to ease movement i
23 of powders, we have some glovebox equipment at the 18 i
] 24 meter type level. We have accelerations up at that level j 25 of around 9 g, and we have seismic qualified the equipment L NEAL R. GROSS i COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 1 to that.
2 We have shake table tested some of the seismic k_) 3 isolators which separate the facilities. So we are very 4
confident in the robust seismic design of this facility.
5 Moving on to SMP safeguards, we are a fully 6 safeguarded operation where we have 30 plus years of 7 experience. EURATOM are the safeguard regulator within 8 the UK and the whole of Europe. We utilize what we call !
9 our standard safeguards tool kit where we are operating i 10 with near real time materials accounting system which are l 11 proven in other facilities on our site.
12 We use nondestructive assay techniques to 13 confirm that the plutonium is where -- or they use those
{}
(_/ 14 to confirm that the plutonium is where we say the 15 plutonium is. We have traditional containment type 16 barriers from the process for the glovebox to the massive 17 shielding.
18 In addition, we obviously have rigorous 19 surveillance and security type measures. We also now have 20 found as process safety that it is best to involve the 21 safeguards people and inspectors in the design from the 22 beginning so their requirements can be integrated into the 23 design and so that they have a high degree of confidence 24 in the process.
,y 25 Clearly, having a dry process is also (w_-)
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49 1 reassuring.
2 Moving on now just into the review phase as we 3 come to our conclusion of this presentation, in normal 4 operations, we have the work force dose that I have talked 5 about of less chan five millisieverts per year. We have 6 off site discharges extremely low from this facility, 10 -'
7 millisieverts per year.
8 And because we have a dry process, we have an 9 effectively zero liquid discharge. If we review the 10 accident sequences, our total frequency of doses exceeding 11 100 millisieverts which includes all criticality accidents 12 where we've conservatively assumed a high dose level even 13 though there is a considerable shielding in some parts of
() 14 the facility -- but anyway, all of those summed together 15 are less than 10-5 per year.
16 Juni the demonstration of an absence of a 17 CLISEP effect, we've looked at the next step down which 18 for us is events in the 50 to 1,000 millisievert range and 19 demonstrated that those are around or just below 10-4 per 20 year.
21 When we come to look offsite, our worst 22 consequence. event which is an incident within the furnace 23 and subsequent fa'. lure of the ventilation system is 24 predicted to be ten millisieverts a year, and that's with
,( ) 25 a frequency below 10-5.
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50 l 1
If we move on to look at the external l
2 initiated events, which in this case is dominated by the I f~
(_)N 3 seismic event, our design basis earthquake, which we've l 4 designed against the .25 g and then multiplied up to take 5 account of adjacent facilities and the height of the 6 process, the consequences post-earthquake are one 7 millisievert.
8 And that effectively requires no post-l 9 earthquake intervention. There are no need for heroic 10 countermeasures in this facility post-earthquake.
11 We draw to the conclusion of this talk. What l I
12 I've aimed to demonstrate and for the one or two people 13 who heard some of the practice runs would know I'd
(~x
(_ji 14 probably be more comfortable running a one week seminar on I 15 MOX plant licensing. But we have extensive Mox !
16 experience.
i 17 We have modern technology which has proved 18 very licensable within the UK which I'm confident that our 19 regulator would support that view and be very comfortable i i
20 discussing the -- his regulatory position with the NRC.
21 And we have a very robust and integrated safety case which i
22 covers all of the nuclear safety and also covers various 23 conventional safety aspects and the few chemicals which 24 are in the process such as zinc stearate which is itself a f^}
x_/
25 fairly benign substance.
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(
T 51 [
1 Okay, I think you for your attention. I
~
2 Thanks. {
l l
s 3 (Applause.)
4 MR. FERTEL: Questions for Bryen? !
4 j 5 MR. DOLLEY: Steven Dolley, Nuclear Control i l
' I 6 Institute. 4 2 1 I'd like to ask about the question of process J
j 7 t
t 8 hold up which was mentioned briefly. And I hope that the J e
9 other presenters will address this question as well. It's 10 been a considerable problem at some MOX facilities in the .
j 11 world, most particularly the PFPF facility in Japan which l 12 experienced approximately a 70 kilogram cumulative hold up ;
13 of plutonium which is still in the process of being 14 cleaned out.
15 You mentioned that zine stearate, I believe, 16 is being added to reduce caking and hold up. I'd like to 17 know if you're making the claim that that will completely 18 eliminate process hold up; and if not, what the 19 approximate percentage relative to annual through put of 20 hold up would be that you anticipate.
21 MR. MARTIN: Okay, thanks for your question. i 1
22 Clearly there's an answer in two parts. I j 23 mean, we expect to be operating this facility around about l l
24 250 days a year to achieve the 120 tonnes through put. l
() 25 Throughout that period, there are various amounts of hold NEAL R. GROSS court REPORTERS AND TRANSCRIBERS I 1323 RHODE ISLAND AVE., N.W.
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52 1
ups within the process which are minimized by the way in
\
2 which we have gone for ever safe geometry.
/
kY 3 So, for instance, the blenders have a typical 4 hold up where we have mixing and homogenizing the 5 plutonium material around about 25 kilograms in an ever 6 safe slab-type geometry. At shut down, we expect --
7 having taken the process material through, we expect there 8 to be very little material hold up within the process.
9 That would be our experience.
10 MR. DOLLEY: Just to follow up quickly, if I 11 could.
12 Any attempt to quantify very little -- 1%, 5%,
13 10%?
(3
(-) 14 MR. MARTIN: Less than 1% of the process 15 through put.
16 MR. DOLLEY: Okay.
17 MR. CLEMENTS: My name is Tom Clements wi*h ;
18 Greenpeace International.
19 The Department of Energy has referred to some 20 of the costs for a facility here. I'm just curious what 1
21 the construction costs were for the Sellafield MOX Plant, !
22 what you project the life cycle cost to be including I
23 decommissioning cost.
24 MR. MARTIN: Okay, the production cost is (3
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, 53 I 1 for this facility. And we -- the other questions 4
2 concerning life cycle costs in the facility -- I mean, i
1 3 here we're looking at a commercial production thing where 4 we respond to our customers' requirements for orders for i
5 processing MOX build.
i4 1.
i 6_ So it's kind of a different scenario-because I l
} 7 this is a commercial built to customer orders from i i
8 utilities in Europe and Japan, and we were willing to meet l
9 their needs. And obviously, we are very active in aiming j
! 10 to sell that 120 tonnes per year through put throughout
! 11 the 20 to 25 year plant life that we have designed for.
j 12 So it's actually kind of a different scenario l 13 there.
14 MR. FERTEL: Do we have a question? The
- i i
4 15 question is decommissioning costs -- any projection for i 16 that, Bryen?
1 j 17 MR. MARTIN: Yes, sure.
18 . I don't have that information with me. We do
.i j 19 have and we do have a requirement within.our safety a
I 20 submission in order to file a full decommissioning plan i
, 21 for the facility. I'm afraid I'll have to get back to you 1
l - 22 with the cost information .
s 4
j 23 MR. AIROZO: Dave Airozo from Nucleonics Week.
j 24 Of the $500 million dollars it costs to build i
t
- 25 this, do you have any idea how much of that could be i 1
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1 1 54 l 1 directly. linked to the process of eventually getting it 2 licensed?
l 3 MR. MARTIN: Yes, I anticipated following the i
4 DOE's presentation a question on licensing costs.
l 5 Because we integrace safety into our design, 6 we don't split out licensing costs directly. We would l
7 want to do virtually all of the safety analysis that we do 8 on this facility ourselves as an operator. I mean, we are
! 9 not compliant driven.
l l
.10 I would guess -- and Tony, because he -- my 11 colleague who is turning the slide, leads the team, would l 12 probably like to shout a number out to me for his team 13 cost today. Yeah, so we're talking about five to six
() 14 million dollars in safety analysis costs for the safety
! 15 team to which we've need to add on some extra costs'for 16 those people who have worked on the environment discharge 17 and authorization process.
l l 18 And as in the U.S., we meet the costs of our l 19 regulator or the industry quite properly the costs of 20 regulation. So we're probably talking around $10 million 21 dollars for the overall process.
22 MR. LEVENTHAL: Paul Leventhal, Nuclear
- , 23 Control Institute.
24 This is a follow up question on safeguards.
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[e i 55
) 1 reprocessing plant that the glovebox assay system can do i ,
2 no better than measurement uncertainty of about 25 to 30% ,
3 in terms of estimating hold up.
4 4 I'd like to know what your experience is in j 5 relation to that.
i.
6 And also, I'd like to know whether BNFL is ,
7 prepared to divulge to the NRC for licensing purposes what ,
, 8 it.s actual experience will be in terms of in process hold
, 9 up so that if your plant is a reference plant for the s 10 purpose of licensing, this information will be known to 1
- 11 the NRC. That's one question.
3 i
12 The second question I'd like to ask is whether j
] 13 your system has any active or passive assay system for the 14 low level waste stream as an assurance against that being l
15 used as a diversion path. Siemens, in designing its new 16 MOX plant, acknowledged that in the Bundestag hearing in 1
s 17 1988 that no such system was designed for that plant.
18 I'd like to know whether such a system is
- 19 devised for this plant. And if so, whether the results of 1
j 20 those assays will also be made available to the NRC.
4 j 21 MR. MARTIN: Okay, thanks for your question.
22 Right, I'll take your second question first.
- 23 It largely relates to my memory -- my short memory. On i
24 the TRU material which comes out of the facility, we 25 measure that. N measure that for waste management and
.i NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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]
56 1 safety reasons because we do not wish to have any critical 2 accumulations within material which we term PCM, plutonium n
l I
\_) 3 contaminated material, in the UK.
4 And because of the disposal roof that we have 5 for that, we need to keep an accurate measurement of that 6 material. And that information also provides a safeguards 7 basis for that route out of the Sellafield MOX facility.
8 Your first question effectively related to the 9 information that BNFL, the team with which we are 10 partners, was selected, as we hope it will be for one of 11 the reference designs. We would make available all of the 12 information that was appropriate to our role in that team 13 at that time.
p
(_,) 14 We would not need to witnm tl information for 15 any reason. But clearly, the scope of that depends on the 16 scope of involvement in any team, and that's a commercial 17 issue. That's not a sensitivity issue.
18 MR. FERTEL: I think let's hold the rest of 19 the questions for Bryen until the end of the session.
20 We'll leave time for questions for the whole panel so we 21 can sort of try and stay on schedule.
22 Thank you.
23 Bryen, thank you.
24 MR. MARTIN: Okay, thanks for your questions.
CN 25 (Applause.)
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57 1 MR. FERTELi Our next speaker is Michel 2 Debauche from Belgonucleaire. Michel is currently the 3 manager of MOX plant engineering. He has over 35 years 4 experience in nuclear engineering for various facilities 5 including research reactors, fast breeder reactors, and -
6 certainly MOX related facilities.
7 Prior to taking this position at 8 Belgonucleaire, he was responsible for all mechanical 9 design and testing there and did work in MOX fabrication 10 activities for them before this.
11 Michel?
12 MR. DEBAUCHE: Ladies and gentlemen, thank 13 you.
14 As you can see, my name is Michel Debauche.
15 And it's a great pleasure for me to be with you today. I 16 am honored to have the opportunity to speak before such a 17 large and knowledgeable audience. I am honored having 18 been invited by NEI -- attend NEI workshop attended by NRC 19 representatives.
20 The NRC is indeed considered in our country as 21 leading licensing organization. I am honored. And in the 22 meantime, I am stressed. I am stressed to speak in front 23 of you a language for which I have so poor knowledge, and 24 especially after having heard the fluent and British
() 25 language of my colleague of BNFL.
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58 l 1
1 (Laughter.) l 4 2 The next slide, please.
l 3 Before speaking about-licensing, I would like
- 4 to introduce a little bit tay country and my organization. {
l 5 As you can see, Belgium is located in western Europe 6 immediately at the center of gravity between France, 7 United Kingdom, and Germany.
)
8 So it's not only an image. In fact, if we are 9 the center of gravity of those three countries which are 10 also invited to speak in front of you today, it's because 11 we have perhaps large experience in MOX, and this 12 situation is a good image of our knowledge.
13 I would like to use three plants to
() 14 illustrate. .The first MOX plant in Belgium has been 15 commissioned'in 1960. The first MOX rods loaded in --
16' ever loaded in a reactor in the world were MOX rods 17 fabricated by Belgonucleaire and loaded in a Belgium j
)
18 reactor named BR-3. It was in 1963.. l 19 And the first MOX in this Europe land 20 commissioned the PO plant belonging to Belgonucleaire has 21 been commissioned in 1972.
22 Next slide, please.
23 To situate now Belgium with respect to United 24 States, you can see how large we are from the point of
() 25 view of comparison of the same scale of Belgium and Texas I
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I
59 1 with some figures to indicate the comparison between Rhode 2 Island and Texas. So we are a small country, but we have 1
(^3 l
(_,/ 3 a long history and a large experience in MOX. :
J 4 Next, please.
1 5 I'm afraid you have to -- okay. Well, 6 licensing is a question of states or organization of i I
7 states, so I would like to give you some words about the 8 Belgium organized state -- organization. Belgium is a l l
9 federal state, but it's not comparable to the United l
10 States.
l 11 Indeed, besides a federal government, we have !
12 two other governments. One for the region which are 13 mainly area; one for the communities. We have indeed p
q
) 14 three communities and three languages in Belgium. You 15 see, so there are -- but as far as the licensing of a 1
16 nuclear facility is concerned, it's only a federal matter, 17 and any involvement of the regional territory mainly about 18 the territory planning, this influence occurs only through 19 the territories themselves.
20 Next, please.
21 So the three regions -- speak more about 22 communities. The three regions which are existing in 23 Belgium are Brussels like the District of Columbia; a 24 Flemish region and a Waloon region. And the Mox plant we
/T 25 have is located in the north of the country, so namely in L)
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60 1 the Flemish region.
2 Now a few words about my company.
3 Belgonucleaire was created in 1957 by Enaminierre.
4' Enaminierre is a Belgian mining company. And we have been 5 created to create fuel, and we have since that time !
6 pioneered in this field. Today, Belgonucleaire is part of l 7 the Tractabel which shares the equity of the society with ,
1 8 the Belgian state roughly 50/50.
9 Tractabel is an international strategy, and is 10 the largest Belgian industrial group. Within its various 11 facilities, the Tractabel group is active and involved in 12 100 countries, and especially in the United States through 13 its subsidiaries, ATC and CRSS, which are electricity 14 producers.
15 Electrabel, which is also one unit of 16 Tractabel, is the private Belgian electricity utility and 17 the major producer of electricity in Belgium. It operates 18 even nuclear reactcr plants with a total capacity of 5,500 19 megawatts which represents nearly 60% of the total energy i 20 needs in Belgium -- electricity needs in Belgium. j 21 Tractabel Engineering, which is another 22 business unit of Tractabel, is the architect engineer of !
23 the nuclear power plant and are responsible for the !
1 24 licensing. Inside the Tractabel group -- next slide, 1
25 please -- Belgonucleaire has two main functions.
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i 61 J l
1 ~First, MOX fuel production; and, second, l 2 nuclear engineering. In nuclear engineering, we are O 3 specialized in MOX fuel design, MOX plant construction, !
J 4 and rad waste conditioning.
5 We operate at 35-ton a year MOX plant in. i l
6 Dessel. And as engineers, we have designed and built this 7 plant, which is named P0. And we have also used our 8 know-how to design a new plant named P1 but also to assist I
9 COGEMA in building the MELOX plant in France. I will.give l
- 10 later more information about the P0 and the P1 plant. I
)
- 11 In the field of plutonium, we also are active i
12 to a daughter company of Belgonucleaire named Transnovel.
t 13 We are active in the field of plutonium transportation.
14 (Slide) 15 MR. DEBAUCHE: I would like to spend one of 16 two minutes now on the licensing rules which are valid in 17 our country. So I talk to you. The nuclear activities 18 are mainly the federal activity, and we are so concerning j 19 the licensing of MOX plants set rules mainly. And I will I
20 take the opportunity to say some words in French, relaxing '
21 my tongue.
22 The main rule is r&glement gsn6ral pour la 23 protection de la population at des travailleurs contre les l
24 radations ionisantes. This being said, not too bad
() 25 translation is general regulation for the public and the NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBER $
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62 1- worker protection against hazards of ionizing radiation.
2 That's a. written document.
O 3 Another kind of document which is related to 4
4 the licensing of nuclear plants is what we call a specific 5 rule document. So for each nuclear plant, one has to 6 establish the safety analysis involved. And, of course, 7 the safety analysis involved is reviewed by safety 8 alternatives, which is the safety evaluation involved.
9 At the end of this process, a very important 10 document is the royal decree. The royal decree summarizes 11 all the specific requirements which are devoted to the 12 licensed plants.
13 (Slide)
O 14 MR. DEBAUCHE: There are also tules which are 15 valid for any industrial plants. They are indicated on 16 this slide. I will not read the sentence. But we have to 17 comply with the industrial rules, too, in the licensing 18 procedure of a plant.
19 The next, please.
20 (Slide) 21 MR. DEBAUCHE: So the process of licensing a 22 plant is briefly described here. I will give more 23 information when speaking about Pl. So the first is the 24 license application to be established by the owner.
() 25 This license application is handed over to an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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63 1 organization the same of the federal states, which is the i 2 province or the governor of the province which i l i
3 consulting in the same as open procedures, consulting the.
4 municipality or municipalities which are involved in the 5 process.
6 After advising the municipalities, the file is 7 given to what I call a Special Commission. The Special 8 Commission is the major acting body in the licensing. The 9 expertise is to make the safety evaluation of the safety 1
10 report established by the applicant. !
i 11 After safety evaluation and discussion, this I 12 commission establishes a first preliminary report. At l l
13 that time we are consulting the European Communities. l 14 Why? Because, as you have seen, Belgium is a small 15 country. And we are a tiny place, really close border for 16 the countries.
l l 17 And so, too, the European Commission as a 18 function of the Article 37 of the Treaty of Rome, we are 19 taking advice of the neighboring countries. After advice, 20 which is coming back to the' European Commission, it is the 21 possible rework of the application file to take the 22 comment of the other countries.
23 After this rework, the commission establishes
- 24 its final report. And up to now, it's only technical.
i 25 After that, it enters into the political matter. And the
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-l
64 1 final report of the Special Commission comes into force 2 only after signatures by the competent minister and by the I,, \
V 3 king.
4 Next.
5 (Slide) 1 6 MR. DEBAUCHE: So the main licensing and 7 control bodies which are involved in the process of I
8 licensing a nuclear plant are the following: first, the 9 state administration. And they are mainly two, the SSTIN 10 and the SPRI, which have different competence, let us say. i 11 The first one is mainly devoted to the safety inside the 12 plant and the SPRI outside the plant, so mainly the 13 population; after that, the Special Commission. I just
()
(j 14 said some work about the Special Commission.
15 And the two first bodies for the state 16 administration, the Special Commission are involved into 17 the licensing. After that, we have to enter into the 18 process of controlling if the plant is conformed to the 19 licensing. And so there are two bodies which are 20 involved.
21 .he authorized inspection agency is an agency, 22 mainly private, which is entitled by the federal 23 government to make the control and the survey of execution 24 of work during construction and during operation of the (n) m 25 plant.
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65 1
The last one, the physical control service, is 2 a service which belongs to the plant operator. He has 3
total independence from the point of view of safety and is 4 permanently controlled by the authorized inspection 3
5 agency. So we are inside the organization of the plant 6 owner, a special service which is attached to the safety 7 and the licensing of the plant.
8 (Slide) 9 MR. DEBAUCHE: So, again, a small picture 10 giving you mainly an involve. I try to indicate the main 11 involved organizations. So you see on the left side of 12 the slide the federal government, which through the 13 Ministry of Interior Affairs involves the safety of 14 nuclear installations, the safety against ionization 15 radiation, and the civil protection in case of appliance ;
I
( 16 of an emergency plant. We depend also on the Ministry of t
-l; i
17 Justice as far as the nuclear security and safeguards of l
l 18 the plant is concerned.
l ll 19 The next, please.
20 (Slide) 21 MR. DEBAUCHE: I will now speak a little bit 22 about the two plants we have licensed in Belgium. The ;
l I
l 23 first one is the PO plant in '70 and the second one the P1 '
l 24 in '91.
t 1
25 You will see a review of the PO facility in NEAL R. GROSS COURT REPORTERS AND TRANSCf.1BERS i
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66 1 Dessel, where we have been fabricating MOX fuel since '73,
- 3 2 including fuel for pressurized and boiling water reactors
\~) 3 but also for fast breed reactors.
4 In the mid '80s, we upgraded the production 5 capacity and developed at the time the MIMAS process in 6 order to meet the growing commercial demand from European 7 utilities for MOX fuel.
8 Using MIMAS, we have produced today more than 9 315 metric ton of fuel, which means more than 170,000 fuel 10 rods. In this, we have total production of about 600 11 metric tons.
12 This plant has produced MOX fuel to 16 nuclear 13 power plants, which are located in Belgium, in France, in (mT
(_) 14 Germany. and Switzerland. And we are now beginning to 15 make MOX fuel for electric utilities in Japan.
16 The next, please.
17 (Slide) 18 MR. DEBAUCHE: I spoke about the MIMAS 19 process. The MIMAS process produced plants which are 20 composed of a solid solution of uranium oxide and 21 plutonium oxide disbursed in a matrix of uranium oxide.
22 This result is achieved through two blending 23 steps, indicated primary blending, secondary blending.
24 And then we have two blending steps to be able to have
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67 1 of-the plutonium is different.
2 So the main events that's of the MIMAS are the 3 following: the primary blend of the evaluation of the 4 plutonium oxide to about 30 persons is prepared in a trend 5 to the pellet fabrication. The same primary blend can be 6 used to produce pellets of various plutonium enrichment.
7 The second of the blending process of high 8 flexibility in plutonium is atopic homogeneity. We are 9 using in the plant special design equipment which are 10 leading to very low powder retention.
11 The advantage of this process is also its 12 economic viability, which has been just demonstrated due 13 to the full capacity of our plants. And since the time we 14 are producing MOX, we can say that this technology is 15 really mature in an industrial level.
16 Also advantage to let COGEMA adopt this same 17 process for the Villieux plant since the beginning and 18 since '96 also for CFCA, its Cadarache plant. So the 19 MIMAS process is expected now to produce out of the 1,400 20 ton of MOX fuel expected in the year 2000, to have 100 ton 21 produced with the MIMAS.
22 PO is a medium sized plant comprising two main 23 fabrication designs, which are read in parallel. It is 24 characterized by high flexibility in terms of fuel design.
() 25- We can make PW or BWR and even fast breeder. We can use NEAL R. GROS 5 COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N W.
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68 1 several plutonium specification. We are qualified for 2
several designs, like Belgonucleaire, ourselves, Siemens, i
\/ 3 FRAGEMA, and Toshiba.
4 Next slide, please.
5 (Slide) 6 MR. DEBAUCHE: The range of parameters which 7 have been demonstrated up to now, are indicated on this 8 slide. So you see the total production which was given of ,
L 9 the end of '96, the fuel type in P&B, several produced, 1
10 the size of campaign, number of plutonium content per l
11 campaign, and the plutonium content in the fuel. We are l 12 working up to eight percent.
13 The licensing of P0 appeared end of the '60s, !
,/3 I
) 14 the royal decree. Giving the authorization, the licensing 15 has been awarded in '70. Since that time, the operation 16 of the plant is made under constant scrutiny of the 17 authorities and of the authorizing inspection agency.
18 (Slide) 19 MR. DEBAUCHE: For this plant, we have 20 performed two important refurbishment programs: one in i 1
21 '84, prior to the scaff of the industrial MOX production 22 aiming at capacity increase and implementation of the 23 MIMAS process; a second one, which is still running now, 24 from '95. And it's planned until '98. It's aiming at rm i ) 25 higher production of the production equipment. Some l
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. . . .. - , - _ _ . - ~ - . . - - _ . - .. - . - - - . _ . . - . . - . .
69
) 1 mechanization is also included of this program.
- 2 As-a result of these efforts,-the maximum
( 3 individual dose to the workers for this plant, which is j 4 mainly manual, the dose is reduced below 20 millisievert a h 5 year.
i 6 (Slide) k 7 MR. DEBAUCHE: Now some information about the 8 P1 facility. The P1 project has been developed to answer-l 9 the increasing demand for Mox fuel in Europe and was
} 10 licensed in April '91. The license was sued one year-t i 11 later before the Supreme Court of Belgium. Thus, the i
12 construction of the plant did not begin. '
! i i 13 And in the meantime other MOX fabrication 14 capacities were constructed or designed. And the expected j
i 15 MOX capacity by the year 2000 will not meet the expected
! 16 demand.
3 i
i 17 For other new plants, these were the United i
f 18 States and in Russia to MOX fabrication for weapons i
i 19 plutonium should be built in response to the decision in 20 both contraries to follow the MOX option. Today P1 is j 21 redesigned to respond to the particular needs of th'e 2
f 22 weapons plutonium transformation into MOX.
I: 23 The main features of this plant before this i t
} 24 ongoing redesign are given now. Here you can see the ;
4
()
25 process is always the MIMAS, the capacity 60 ton. It was
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70 1, intended to produce PWR and BWR fuels. The operator 2 exposure is according to ICRP-60, two lines.
3 The three sintering furnaces with a building 4 footprint to give an ID of 8,200 square meters. The plant 5 flexibility of P1, like Po, is ensured for several 6 plutonium origins, several licensing bodies for fuel, 7 several fuel suppliers.
8 The total personnel involved in the operation 9 of the plant is 250. And the investment cost is expected 10 to be 225 million USD. I speak about price in Belgium, 11 not in the United States. The expected schedule was four 12 years.
13 The next, please.
Q 14 (Slide) 15 MR. DEBAUCHE: As presented, the equipment of 16 P1, the main process is arranged in a U shape, one wing 17 for the powder preparation, the two steps, two blending 18 steps, one wing for the pellet, which is mainly two line 19 except C, sintering furnace. And the last line for the 20 MDT of the rods and the fuel assembly.
21 Next slide, please.
22 (Slide) 23 MR. DEBAUCHE: On this slide you see the same 24 equipment with the building itself. So, as indicated, all
() 25 the production rooms are surrounded by corridors, which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 1 are isolating the production rooms from the outer wall of 2 the building.
These corridors are located below technical
\- \ 3 cavities. In fact, you see in green the technical 4
cavities, where all the ventilation ducts and the cabling l 5 are installed.
6 The ventilation system is organized to feed 7 the air to the main corridors, maintaining them at 8 pressure higher than that of the production rooms. The 9 air is feed under the room ceiling and exhausted at the 10 bottom of the other side of the room to avoid any l 11 migration of contamination into the corridors.
l 12 Like PO, P1 is a flexible plant. It is 13 considered in our opinion the key features. P1 is
'w /l 14 flexible from the point of view of the product, the l
15 process, the equipment, the layout, and the safety.
l 16 Another extremely important advantage of l
j 17 flexible plants is the ability to respond to the future 18 evolution of safety end-user requirements. I- uld like 19 to develop a bit those points.
20 (Slide) 21 MR. DEBAUCHE: Concerning the external l
l 22 accident, P1 is designed to withstand an earthquake and 23 airplane crash. We have constructed for airplane, heavy 24 F16 plane for the design of the sensitive part of the plan
( ) 25 and the small civil plane for the other part.
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4 72 !
'l As far as earthquake is concerned, the design i
i
- 2 of the plant is based on an MSK VI earthquake, which is 1 l 1 3 related to the maximum conceivable grand motion in the
) 4 region of Dessel. But, in any case, the strength of the 5 building is mainly fixed by the airplane crash condition, i l
6 And this building is able to sustain stronger earthquake !
l
- 7 than MSK VI.
) 8 In both accidents, the function of the I i ;
j 9 building is to provide a suitable static confinement.
a i f
l 10 Furthermore, the part of the ventilation system which has '
2 i 11 an important hole in the dynamic confinement of the plant 3
{ 12 is designed against earthquake and against vibration -
(
l 13 generated by an airplane crash.
They are located in the ;
14 part of the building which is designed against the F16 1
l j 15 crash. '
1 16 The situation of P1 as foreseen with P0 i !
17 precludes any flooding and the risk of external explosion 4
- 18 due to all the flood of traffic as well as other human i 19 industrial activities has been evaluated and taken into i
1
- 20 account.
I' i 21 Next, please.
i j 22 (Slide)
I j 23 MR. DEBAUCHE: For the internal accidents, the '
j 24 risk of criticality is kept to a minimum times to a i
j 25 physical layout and must limitation. The plant is l A
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73 1 completely dry. The modification is really met in the 2 protection rooms.
f) xl 3 The plant is divided into small operational 4 units such that any specific configuration of fissile 1
5 materials within the units remains subcritical, even if we 6 take into account double batching. The nuclear material 7 equivalency in the different units occurs in these 8 environments.
9 For the fire risk, the risk of fire is l
10 especially constant in the plant. And a fire protection 11 has been provided. We consider as well the fire from 12 outside the plant as well as fire originating from inner l I
13 source. i
/i
( ),
14 The classical means of fire prevention, such i
l i
15 as limiting any combustible material and fire initiation 1 16 source, is not applicable. The glove boxes are ventilated 17 with nitrogen or helium and not with air.
l 18 Special attention has been also paid to '
19 fire-fighting. It includes the partition of the plant 20 into many fire zones limited by fire-resistant walls.
21 Each zone has its own ventilation subsystem able to 22 isolate it from the neighboring zone. The ventilation is 1
23 designed to remove the fumes generated in the room, 1
24 impeding the access for the fire. It is also designed to l
,m
( \ 25 maintain the room pressure in the damaged zone below that
%J
\
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74 il of the other zone.
2 The location of the filler bank in the 3 technical gallery allows even escape of fire to be' 4 accessed so the fire valve may be actually manually i 5 actuated, even'if they are not responding'to the automatic l 6 control. As being used for fire fighting, we are using !
7 carbon dioxide injection.
8 For operator exposure, the exposure of the 9 plant to the operator, is minimized. To reach this goal, !
l 10 we are using solutions like neutron and gamma shields. So 11 it's the plant which is designed for commercial plutonium, 12 so neutron and_ gamma shields in the glove boxes. We have 13 installed all the fuel sites behind concrete walls. And 14 we are using separate rooms for operation where 15 significant long stays by persons are required.
16 Contamination. To limit the contamination 17 migration, a triple static confinement concept is used l
18 throughout outside: first, the glove box containing 1
19 equipment; the fabrication rooms; and the confinement 20 provided by the building itself, over the static 1
21 confinement, a dynamic confinement is provided by 22 operation, a sophisticated once-through ventilation. This 23 is to ensure air pressure cascades in such a way that any i 24 leak is organized harmless to more zones and, of course, 25 ensure the filtration of the exhaust space.
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1 75 !I 1
i 1
The-blowers and fans are redundant. And the i h
- 2 energy supply for running the fans is provided by 3 redundant emergency generators in case of grid fail. One
- 4 supplementary feature for limiting the contamination is '
1 i t
5 the existence in the glove box of specially designed I 6 plutonium dust collection system and the arrangement of 7 this plant into small rooms, provide as fast as possible 8
8 the elimination of any contamination if this occurs. An
{
4 9 air-monitoring system controls the absence of '
4 1
j 10 contamination inside the rooms and also the accents of 11 contamination at the stack.
I 12 (Slide) l 13 MR. DEBAUCHE: Let me speak now about
() 14 licensing of Pl. The process illustrates according to the l
j 15 rules I just explained some minutes ago. So first that is 4
{ 16 to prepare an application file which is established by the i 17 owner of the plant, by Belgonucleaire in this case. And l :
- 18 we make use of the procedure of the time which is not 4
1 j 19 mandatory of Belgium, but which is possible.
20 It is possible to have a contact board. The 21 contact board is a commission, not official but a 22 commission, with the presence of the administration 23 people, the future people in the Special Commission, 24 people of the authorized inspection agency. And this acts IT
\j 25 as a working group to try to establish in the best way the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 1 content and the structure of the application file.
2 After writing this file, we established and we t
3 entered into the official process the license application.
4 This license application is handed over to the governor of 5 the province where the plant is located. In our case, it 6 is Antwerpen Province. !
7 And the governor asks the advice of the 8 involved municipalities and also the province !
9 administration. With the advice of such population,11e 10 hands over the license application with the results of i 11 advising to the Special Commission.
12 This one began to work a safety evaluation l
13 report on the file application and this realized who, a >
-( 14 contact person inside the Special Commission. This person 15 discusses the file, analyzes it, tries to avoid any i
16 certainties of misunderstanding between the applicant-and 17 ourselves and after that, to make fo. ward any problem, 18 establish an official set of quercions.
19 In the case of P1, we have received 32 20 different sets of questions, for which we were obliged to l
21 give a special file with an answer for each question. ;
22 Those questions were mainly related to: first block, 23 question concerning the operational experience with Po, 24 mainly the operation incidents and their consequences and
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77 1 this operation incident; the second set or block of
(
7
\
2 questions, requirements of improving the safety s
'~'! 3 characteristics and redundancy features of the main energy 4 and fuel feeds; third block, calculation of an accident 5 simulation to confirm the provision which has been 6 focusing for the plant safety; and, the fourth, more, but 7 less important, more activated description of the plant 8 itself to allow the Special Commission a deep analysis of ;
9 the plant safety. I 10 Before the application is filed, the answers j 11 to the 32 sets of questions are the base considered for I 12 the preliminary report by the Special Commission. I'm 13 sorry, but I am unable to read. So the preliminary report I i
'w ' 14 of the Special Commission is written on this basis.
15 Next, please.
16 (Slide) 17 MR. DEBAUCHE: The preliminary report is now 18 at the top of the slide. And with this report to the 19 European Commission on the basis of Article 37 of the j 20 Treaty of Rome, we are consulting experts to see the 21 influence of soil, water, and air space, possibly l
- 22 contamination of the neighboring states. We on the 23 Special Commission take the advice of the experts and of 24 the advice again to the applicant. If they comment on (q),
25 further problems, there is a second rework ofR6Et HEAL R. GROSS COURT AEPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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i 17 8 1 application file.
2 After the end of this process, the Special 3 Commission writes a final report, which is handed over to 4 the ministry, which is competent for the licensing, which 5 is for the time being the Minis.ry of Interior Affairs in 6 Belgium. And the signature of the royal decree by the 7 minister and by the king make the end of the licensing-8 process.
9 -Just a comment at the time of Pl. In '91 it 10 was not the Minister of Interior Affairs which was 11 competent but two different ministries, which are 12 indicated there.
13 So, finally, the license documents are the 14 following: the license application, the preliminary 15 report of the Special Commission, the application 16 according to the Article 37 of the European Commission, 17 the final report of the Special Commission, and the royal 18 decree.
19 The next, please. '
20 (Slide) 21 MR. DEBAUCHE: So some indication concerning 22 the main regulatory limits we are using in Belgium. For 23 surface contamination and fixed contamination, the 24 mandatory is 37 becquerel per square decimeter. And we 25 are using -- the word "use" is perhaps not very well i
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. _. -l
79 1 chosen. We propose to ourself a U of five, and we 2 maintain this one.
,q
( ,/ 3 For air contamination, inside and outside the 4 controlled rooms, we have the following values: 8 times l
i l
5 10-2 becquerel per cubic meter and 1/50 times the value for l 1
6 the air outside the plant; water contamination, two 7 becquerel per liter.
1 8 The operator exposure according to the 9 regulation in Belgium is 50 millisievert per year. And we i i
10 are proposing for ourselves 20. So there I don't indicate 11 the value because those values are so low it's really 12 difficult to measure the real time. So we have to use 13 delayed measurement to perform an analysis of the '
(s
\v) 14 contamination of the air.
{
15 Making delayed measurement, I can say that the 16 proposed value we are using is roughly one-tenth of the 17 mandatory value. And in reality, we are at the value 18 which is 1/1,000 the proposed value.
19 The next slide, please.
20 (Slide) 21 MR. DEBAUCHE: Concerning the maximum 22 individual dose, we were beginning with a rather large 23 dose in P0, decreasing it, and for the time being we are 24 below 20. We have spoken about in the previous slide.
[~) 25 And for the year 1996, the maximum individual dose was 40
(_)
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90 ;
i 1 millisieverts.
y i 2 It is time to try to define some conclus. tons. l 3 And normally we say conclusions and recommendations, but i ;
j 4 today I will not make some recommendations because I mean ;
5 it will be difficult to make in front of the NRC l
- -6 recommendations, only reflection. 1 2
7 (Slide) i 8 MR. DEBAUCHE: The licensing of a MOX plant is
! 9 a long and comp x process. We have used more than three
/
j 10 years between the final application of the P1 plant and 1
- 11 the signature of the royal decree, 40 months, in fact.
1 12 And we have tried to establish the key success-factors for l 13 obtaining a license.
14 The first one according to our experience to I
j 15 have access to the construction and operation experience !
a j 16 during licensing of P0, the question was mainly: What is i a
- 17 the operation experience with the pilot plants you have? l j '
j 18 And during the licensing of P1, the questions were: What o
19 are the operation experience without new PO? l 20 The second point, as in the design in a i
i 21 provision for future safety requirements, we have also
- 22 used a complete dialogue between our authorities and the 23 applicant. I mean tFat to be frank between the safety l 24 organization and your technical people designing the plant i
25 is a factor which is a success factor of licensing where
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81 1 you don't try to put some problem in the 1sket.
2 A point which is not on the slide is perhaps q\~/ 3 also the following sentence: The safety of a plant is not 4 only included into holds. It also includes into the plant 5 itself and in the people running the plant. And we are 6 making a permanent education of the people working by us 7 to be attached to the safety of the plant.
8 Last, but not least, the licensing is in our 9 country a political fact. It must be a political 10 willingness to the licensing of a Mox plant.
11 Thank you for your attention.
12 (Applause.)
13 MR. FERTEL: Why don't we take about five p.
(_ ) 14 minutes of questions for Michel. Then we'll take our 15 break. Then there will be an opportunity for further 16 questions of Michel as well as everybody else.
17 I'd like to tell Michel I thought he did very 18 well with our language, probably better than I do. And 19 also I was pleased that he didn' t of fe c a recommendation 20 to the NRC that they issue a royal decree on anything. I 21 was concerned when he went through that earlier.
22 Any quick questions for Michel? Tom?
23 MR. CLEMENTS: You mentioned Russian and U.S.
24 weapons-grade plutonium.
p i i 25 MR. FERTEL: Tom, could you introduce O
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.- - - - . _ _ . - - - - = . - - .. _ . - - . - . . - . - - . . . . - . - . - . - . . _ .
82 l i
1 yourself?
, 2 MR. CLEMENTS: Yes. Tom Clements, Greenpeace (SW}
\~- 3 International.
\
4 You mentioned Russian and U.S. weapons-grade i
5 plutonium, but it was unclear to : if you were implying l
6 that either the P0 or the P1 plant being flexible, as you )
1 7 said, could handle weapons-grade material for the first 8 question.
l 9 MR. LEBAUCHE: No. PO and P1 were. designed j j
10 both, as you have seen, for commercial plutonium. At that 'l 1
11 time it was not a question of transforming the weapons 12 plutonium into MOX. But now we are working on the 13 redesign of the P1 to be'able to process weapons 14 plutonium.
15 But the indication I gave to you is the 16 previous file because we are just making the jump for the l
17- time being and have no special indication to give to you. j j 18 MR. CLEMENTS: Also, with the P1 plant, I l
l 19 understand and you briefly mentioned that a court decree 20 ruling has blocked the construction. I'm not quite clear i
I 21 on why that is. Could you explain a little bit about what i l l 22 the court ruled in stopping the construction of --
23 MR. DEBAUCHE: Okay. We never began the i
- 24 construction. In fact, we have a plant. P1 is licensed.
25 And for the time being, we have the license. So we are i
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~. -. -~- - . . - . - - . - . . . . .. - - - .. - - .- . - ..
83 1 entitled to begin the plant construction and operation.
2 But anyway it's a claim in front of the Supreme Court. l O 3 So to construct and' operate the plant would be l
4 an economical risk. And we did not will to support this 5 risk if the risk of the Supreme Court within 8 years or 10 6 years would be negative.
7 MR. MAKHIJANI: Arjun Makhijani, Institute for 8 Energy and Environmental Research. l 9 You're investing some resources into the :
10 redesign of this plant of spons' plutonium. Do you have l 11 any indication that this investment will pay off, that ,
1 12 somebody will actually give you a contract, or is it a 13 speculation on your part?
14 MR. DEBAUCHE: Sorry. I didn't hear 15 completely the question. Could you repeat it?
16 -MR. MAKHIJANI: Yes. You are investing some 17 resources into the redesign of the P1 plant for weapons 18 plutonium --
l 19 MR. DEBAUCHE: Yes, yes.
20 MR. MAKHIJANI: -- from the U.S. and Russia. .
I !
21 Do you have any idea that anybody is going to give you a l
l 22 contract or some preliminary indication from someone?'
23 MR. DEBAUCHE: For the time being, no. It's i
- 24 on our own expense we are making this job.
25 MR. MAKHIJANI: What is the magnitude of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. ;
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~B4 l 1 expense? i 1 l
. 2 MR. DEBAUCHE: For the time being because we 3 make small steps, one of them, we are in the order of 4 magnitude of less than one million dollars.
5 MR. FERTEL: Okay. If we could just hold the l i.
6 rest of the questions now until the end of the session?
7 And we'll take a 15-minute break and try and reconvene at f
8 5 past 11:00. Thank you.
9 (whereupon, the foregoing matter went off the j
3 10 record at 10:56 a.m. and went back on the 11 record at 11:15 a.m.)
i 1
[ .12 MR. FERTEL: Our next presenter is Mr. Gsrard i
13 Lebastard from COGEMA. Gsrard has been with COGEMA I 14 guess since 1978. He has had different responsibilities,
, 15 starting out there working to establish spent fuel 16 transportation program.
17 He's been heavily involved in all fuel 18 fabrication activities, not just MOX. He's been in.the 19 Commercial Division and right now is director of their 20 international reprocessing business. He also is President 21 since 1984 of COMMOX, which is a joint effort between 22 COGEMA and Belgonucleaire.
23 We're pleased to.have G6rard here, and I will 24 now turn it over to G6rard.
25 MR. LEBASTARD: Okay. Thank you, Marv.
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85 1 (Slide) 1 2 MR. LEBASTARD: Ladies and gentlemen, good 3 morning. It's my pleasure to present to the audience the
-4 recent achievements of the COGEMA group in the field of 5 MOX fuels.
6 I will include two different subjects, the 7 first one being referring to MOX fabrication experience l 8 and the second one referring to licensing and licensing 9 experience.
10 May I have the first one?
l 11 (Slide) 12 MR. LEBASTARD: So let me start with
! 13 highlights of 1996. The big event of 1996 for the COGEMA
( 14 group was the commercial operation of the MELOX plants.
15 We achieved very good results with what is now the largest 16 MOX fabrication plant in operation.
17 The plant produced 50 tons of pellets, which 18 wc*e delivered to EDF. And the production was on the i
19 order of magnitude cf 65 tons. The plant is now operating 20 at a level of about ten tons per month. It has been 21 operating at this capacity, which is a nominal capacity, I l
22 since the beginning of the year '97. So we are having 23 very good operation for the time being, i
24 Another very important subject for us was in
() 25 1996 to achieve assisting the international agreements, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. l (202) 234 4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 !
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86 1 which were negotiated between the Japanese government and 2 EURATOM and Belgium government on the other side.
3 This was a condition to start the fabrication, 4 as was said by Mr. Debauche, produced the fabrication 5 start of the first Japanese boiling water reactor orders 6 in Belgium, in Dessel. And this was properly sold in.the 7 beginning of 1997. And now the normal work is underway.
8 Third big event for the COGEMA group was 9 Cadarache qualification for German pressurized water 10 reactor MOX fuel. The first reload will be delivered very 11 soon, within the next few days. And Cadarache is now 12 fully allocated to this German work and will be allocated 13 to such work for the ten years.
O 14 Next.
15 (Slide) 16 MR. LEBASTARD: We are also achieving in '96 a 17 very important recycling program in France with ten 18 reactors of electricite de France which are currently 19 loaded with MOX fuels. And we also have achieved loading 20 21 reactors in Europe, mainly added to France or Germany 21 in Belgium.
22 So all that will lead us in 1997, probably in 23 spring, to delivery of 1,000 MOX fuel assemblies, which 24 also will be coupled with the tenth anniversary of loading a
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87
?
1 Laurent was in November 1987. And since then, we have had 2 very good operating results from the reactor side and from O
i 3 the plant fabrication side as well.
4 (Slide) 5 MR. LEBASTARD: A few words about our 6 industrial organization. Our activity in MOX fuel is 7 fabrication plants which are operated by COGEMA. It's the 8 case of Cadarache, and it's the case of MELOX and also on 9 the fabrication plant of Belgonucleaire, which is located 10 in the south.
11 And we have a partnership with Belgonucleaire 12 which includes marketing and sales by COMMOX. COMMOX is a 13 joint venture which has received the exclusivity of sales 14 from Belgonucleaire as well as from COGEMA. And we are 15 also, as was said by Mr. Debauche, cooperating on plant ,
16 construction, engineering and construction.
17 So the plants which are currently operated are 18 COGEMA Cadarache. COGEMA Cadarache has a capacity of 10 2
19 1
ton per year of MOX fuel. This was recently extended to !
20 that level.
l 21 Cadarache has still the possibility to I
22 manufacture on a specific line further the reactor fuel.
i 23 And Cadarache is in charge of fabrication of fast breeder 24 reactor. I 25 We have an operation in Pheonix when the l
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88 1 reactor is' allowed to resume operation and super Pheonix, !
i 2 which is currently shut down but which has been operating 3 very well for the year 1996.
4 We have an operation now at the MELOX plant 5 with a capacity of 160 ton per year, which is a built 6 capacity of today. As I said, for the time being, this 7 plant is operating at about 10 tons per year. So we are 8 foreseeing an extension, which is under construction. And 9 I will comment on that later on. The extension will bring 10 the total capacity of the MELOX site to a level of 250 ton I
11 per year, which is a level which is need to meet market '
12 demand. And the subplant on which we are relying is the ;
i 13 Dessel plant with a capacity of 40 ton per year.
) 14 Next.
15 (Slide) 16 MR. LEBASTARD: So this is our MOX fabrication 17 experience as of the end of December 1996. We delivered 18 to the French utility at EDF 600 PWR fuel assemblies. In 19 the literature you will find by an EDF was presented a few 20 weeks ago a number which is slightly different from that 21 but which is a number which was loaded in the reactors.
22 This is the number which was delivered. So there is a
\
23 small gap between delivered and loaded.
24 We also delivered in Germany 120 MOX fuel
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1 assemblies. In. Switzerland, we delivered 60 fuel !
2 assemblies. And in Belgium, we delivered 40 MOX fuel i 3 assemblies. So the total is.over 800, close to 90 MOX !
l 4 fuel assemblies. And, as I said, in a few weeks, we will i 1
5 manufacture our 1,000 MOX fuel assemblies.
6 Next.
7 (Slide) 8 MR. LEBASTARD: So the operation of the 9 fabrication plant, while the operation has been very good, j 10 Cadarache is very similar to Dessel, and Cadarache is very 11 similar to Dessel P0, in fact, was commissioned in early j 12 '70s. l 13 It's a plant which has been operating since 14 1973 and which was primarily devoted to fabrication of 15 fast breeder reactor fuel when the program fast breeder 16 was very significant. It was converted partly to 17 fabrication of MOX fuel in the '80s and produced in '94 20 18 tons of MOX fuel, mainly for EDF, only for EDF, I should l
19 say.
20 In 1995, the plant was also only working for i
21 EDF fuel and produced and delivered 30 tons of MOX fuel.
22 And in 1996, the plant was converted to German fuel. So 23 we had to go through qualifications, German fuel 24 fabricators, meaning Siemens and FRAGEMA basically, and to 25 get the agreement of different tooth. I guess Dr.
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I l
90 1 Duckwitz will comment on that later on.
2 So we had to go through an extensive i
k l' 3 qualification program for Germany, which was achieved in 4 1996, but which obviously did result in a decrease of the l 5 production. So 23 tons of fuel were delivered from 6 Cadarache in 1996 but which really correspond to the true 7 capacity of the plant.
8 Cadarache was also at .ie same time slightly 9 modified to convert its process, manufacturing process, 10 from the older COCO process, which was a direct process to 11 the MIMAS process, which has been described previously. l 12 And this was also implemented in 1996. So it's another i
13 reason for showing numbers which are lower than the
(_/ 14 capacity.
15 Dessel in 1994 produced a wider variety of 16 different MOX fuel. Thirty-two tons were delivered by 17 COMMOX from the Dessel plant. Nineteen ninety-five was 18 also a year of good operation, with deliveries of 30 tons 19 of MOX fuel from the Dessel plant. And last year, in 20 1996, 36 tons of MOX fuel were delivered from the Dessel 21 plant.
22 So MELOX now is our, as I said, latest 23 fabrication plant, operated in the south of France on the 24 Marcul nuclear site, which includes a reprocessing plant, o
( ,) 25 which includes a fast breeder reactor, Pheonix, and which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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91 I i
I 1 includes also different research on development
- 2 facilities.
4
- l. 3 The plant was really commissioned in 1994 and 4 started commercial operation just at the end of 1994.
We
. 5 were in the -- well, when I said " commercial," it's not l 6 really commercial. It's commissioning. l 7 The commercial start-up of the plant was 4
- 8 really at the end of 1995. And we were in real commercial i
9 operation in 1996, with 50 tons of fuel delivered. All of 10 this fuel was delivered to EDF, these 50 tons.
] 11 MELOX is a plant which is using an advanced i
- 12 MIMAS process. It's a process which has been derived from 1
13 the Dessel and Cadarache process. So all of our products i 14 are now conforming to a standa.ed specification for fuel
) 15 fabrication.
1 4
16 Next.
I
! 17 (Slide) l
! 18 MR. LEBASTARD: So we are supplying a lot of I i 19 different reloads from 1987, which was for also start-up i
j 20 of the real commercial program. We had, as was said j
j 21 previously, some experience with delivery of some fuel but 22 which were not really full reloads. l 1
- 23 EDF decided in 1985 to recycle MOX fuel as j 24 one-third of each reload basically. And the first reactor 25 loaded was Saint Laurent Dizeau along the Louire River in i NEAL R. GROS 5 COURT REPORTERS AND TRANSCRIBERS 1 1323 RHODE ISLAND AVE., N.W.
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1 France, which was loaded in 1987.
j
, 2 So 1988, we continued the loading program of 3 EDF and started to load a lot of European reactors, 4 starting with the Swiss reactors of Beznau and continuing i 5 with German reactors.
I l 6 Next.
. 7 (Slide)
J 8 MR. LEBASTARD: So this is the continuation of I
! 9 this big program of deliveries. '93 was also a year of f
10 delivery to German reactors, '94 start-up of the Belgian l
8 11 program, with the first delivery of MOX fuel to Belgium, 4
1
~
12 and the program is now at full speed with deliveries in I i
j 13 France for the ten reactors. We are about to deliver i 14 seven to eight reloads per year for feeding ten reactors j 15 and German reactors with fuel coming from Cadarache and j 16 from Dessel as well.
I j 17 Next.
1 i
2 18 (Slide) d
- l. 19 MR. LEBASTARD: So, as a summary, this is some
{ 20 figures about respective nuclear programs of these 21 European countries. France has for the time being 56
- 22 reactors in operation.
23 Sixteen of them, which are 900-megawatt i 24 standard type of reactor, other licensed to load MOX fuel.
i !
25 Ten of the 16 are loaded at the end of 1996. And we are j NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS l 1323 RHODE ISLAND AVE., N.W.
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93 1 loading MOX fuel in these ten reactors since 1987.
2 k Germany has 20 reactors in operation. For the l 3
time being, 12 of them have a valid license to load MOX 4 fuel.
Seven of these reactors are loaded with MOX 5 reloads, including two boiling water reactors, 6 Gundremingen. And we are delivering fuel to these seven 7 reactors. And the first reactor going to commercial 8 operation was back in the early '80s. ?
9 Belgium has also seven reactors in operation. !
l 10 l
Two reactors are licensed to load MOX fuel for the time 11 being, are now loaded with MOX fuel and with deliveries 1
12 coming from the Dessel plant. The first loading of the j l
l 13 reactor was in 1995, with delivery of the fuel in.1994. l l
14 And Switzerland has five reactors, four of 15 which are licensed to load MOX fuel. The two reactors for 16 the time being are loaded. A third one will be loaded l
17 very soon. And we are delivering fuel to one and very 18 soon to two reactors. And the commercial program in l 19 Switzerland is also back from 1988. So a lot of i
- i 20 experience in operation.
I 21 So for the French program, the 16 reactors 22 will not be enough to recycle all the plutonium which will 23 be coming out from the reprocessing program of EDF. So 24 this number will be increased to 28. And the licensing f 25 process for all of these reactors is underway. And it's i
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94 1
starting by 4 reactors which will be added to the 16. And 2 EDF is completing that, with a target of completion by the
( i 3- end of this year.
4 So recently Japan has confrmed its MOX 5 recycling program. They published their recycling program 6
in the press and confirming that one boiling water reactor 7
and one pressurized water reactor of Koncai.will be loaded 8 in 1999.
9 And the Japanese program will increase 10 positively to reach at least one reactor per utility and l 11 at a total number of 16 to 18 reactors by 2010. And Japan 12 will rely upon European fabrication for the plutonium, l
u 13 which is currently coming out from the reprocessing l 14 program in U.K. and France and will also rely on domestic 15 fabrication for plutonium coming out from the reprocessing 16 plant of Fegershomoir.
I 17 (Slide) l 18 MR. LEBASTARD: So this is as a summary just 19 to show and to convince you that this MOX utility is 20 really a mature commercial-industry for.the time being.
21 The competitive number of tons of MOX fuel-delivered at 22 the end of '96 is in the order of magnitude of 500 tons, 23 which have been loaded in mostly European reactors. And 24 this number will increase to over 1,200 tons of fuel by 4
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2 95
- 1. for boiling water reactor as well. .;
, 2 (Slide) 1 3' .MR. LEBASTARD: So MELOX plants, we are 1
4 foreseeing some evolution of the plant. As I said, the 5
i fabrication capacity for the time being is about 10 tons 1
6 per month, which means about 100 tons per year.
7 For the time being, it's real?y focuse' en 8 manufacturing PWR fuel on three different fabrication 9
lines with two different cladding lines and one, just one, 10 assembling line.
11 So MELOX is really delivering finished 12 products, finished fuel assemblies. And the Mox fuel is 13 delivered in Europe with the existing containers, which Os 14 are referred to as FS69. This is well-known by people in 15 the industry.
16 In 1999, we will achieve capacity of 160 tons 17 in MELOX, either P or B fuel, with an additional 18 fabrication line which is under construction for the time j 19 being. We will increase the number of cladding lines from 20 two to three by adding a flexible P and B line. And we I 21 will also add MOX assembling line.
22 And we will take into account the necessity i
'23 not to use only the FS69 but also the FS65, which is 24 another type of heavier container for Mox transportation.
() 25 And by 2000, the plants will reach 200, NEAL R. GROSS i COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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96 1 unfortunately only 250, tons of P and B fuel and 4 2
fabrication lines with 4 cladding lines, 2 of them being ;
3 very flexible and also 3 MOX assembling lines to account 4
for all the different types of fuel which will need to be 5 manufactured.
6
-So we will have a wide variety of Mox fuel i 7
casks, which will be used either for European needs, which 8 his the case of FS69 or FS65, but also for overseas )
9 transportation, which is the case of Japan, where we are 10 planning to use the spent fuel casks, TN 12 and TN 17, :
1 1
11 which are the casks which are currently used for spent 12 fuel transportation between Japan and Europe. They will j 13 be used in the other way, from Europe to Japan, with MOX 14 fuel.
'15 And by that time we will have in operation a 16 new family, a new generation of casks which is under
- 17 development with either European or overseas with higher 1
18 contained in MOX fuel, too, to improve the efficiency of
- 19 the transportation system.
20 Next. l 21 (Slide) I 22 MR. LEBASTARD: So that's it for MOX 23 fabrication experience. A few brief summaries of the 24 licensing experience. In France, we have three ministries
)
, 25 which are. involved in all the licensing passages:
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97 1 Industry, Environment, and Health. They are relying upon 3 2 ,
a number of organizations which are working under their !
O- 3- control.
1 4
The first one is CSSIN, which is High Council 5 for Nuclear Safety and Information. This council is in 6 i charge of the information of the local authorities of the 7 public and the media.
And all the members of this council 8 are appointed by the government. So this is basically 9 information to public and media.
I 10 The ministries are also relying upon another 11 I commission, which is CIINB, which is an Interministerial I 12 Commission for Basic Nuclear Facilities. CIINB is, in l 13 fact, in charge of the license application and is doing
( 14 all the safety-related work.
15 Next.
16 (Slide) 17 MR. LEBASTARD: This commission, CIINB, is 4 18 relying upon a number of organizations belonging either to 19 the ministry which is the case for DSIN, which is a 20 directorate of the French Ministry of Industry, or from 21 'the CA, which is the case of IPSN. That is well-known by 22 NRC, I guess.
23 DSIN is, in fact, the entity in charge of the 24 assessment of the safety and is really conducting the
() 25 licensing passage on the safety evaluation. j i
4 NEAL R. GROSS i COURT REPORTERS AND TRANSCRIBERS i 1323 RHODE ISLAND AVE., N W.
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98 1
IPSN is an institute which is doing the 2
,-~ technical analysis and evaluation of safety and making,
(_) 3 producing conclusion recommendation questions to the 4 ministry.
5 Working also for the ministry is a so-called 6
standing group of experts which is working in parallel 7 with IPSN. And the standing group of experts is producing 8 opinions and recommendations on the subjects which are 9 transferred to thei. authorities.
10 So the safety also relies on regional 11 administration, which is also a part of the Ministry of 12 Industry. And they are in charge of all the regional 13 checks and evaluation which are needed by the ministry.
( ,/ 14 This is particularly true for all ont fabrication plants 15 or fuel cycle facilities as well as for all the reactors.
16 Next.
17 (Slide) 18 MR. LEBASTARD: So, just to recall because i
19 it's very similar for MOX fuel fabrication plant on the 20 reactor licensing, we are working on published guidelines 21 which are published by DSIN. You have there the reference 22 of the document.
23 It was a publication which was updated since 1
24 1978, prior to any fuel reloading. And this statement is p) v 25 very specific for reloads to be put in EDF reactors.
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1 99 i-1 Prior to fuel loading, EDF has to submit a fuel reload i
i 2 safety file, which is called DSS, to DSIN. And this
! 3 document is analyzed by the IPSN and by the group of 4 experts if needed.
5 So this document is not a generic document.
6 It's really reactor and fuel reload-specific and includes
', 7 all the information corresponding to the specific reload 8 concern. But DSS obviously --and I guess it's very t
t.
9 similar in the U.S. with topical report -- may refer.to 10 DGS. And DGS is really a topical report. We call that j 11 generic fuel safety evaluation files.
} 12 Next.
- 13 (Slide) 4 j 14 MR. LEBASTARD
- Solid test assemblies, the
} 15 analysis is done in the same way, on a case by case basis.
4
- 16 There is no formal document defining the passage of LTA i
4 l 17 program. But the documents have obviously to comply to i
j 18 their licensing guidelines. And it's also the case in our
- 19 countries prior authorization or qualification is given to
! l 20 reactor operators, fuel designers, and fuel manufacturers. l a
j 21 They are obviously, all of them, submitted to a
,4 4
22 surveillance and audit program by the safety authority.
1 l i
23 Next. '
I l 24 (Slide) 25 MR. LEBASTARD: So now after reactor on fuel NEAL R. GROS 5 I j
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1 reloads, the plant -- when I say " plant," it's fabrication 2 plant licensing. We have several steps to be implemented.
I -
3 The first one is what we call DAC, which is authorization
- 4 of creation decree. Second step is operating license, 1
5 which is, again, a different passage. Third step is i
6 effluent release authorization. And the last step is 7
fissile material reception and processing authorization, i
/
8 which has to be granted prior to commissioning or to
\
9 commercial operation. So let me take the first one of 10 these.
11 Next.
12 (Slide) 13 MR. LEBASTARD: Slightly complicated, but it's I
14 the case in each and every country. The operator has '
15 responsibility for conducting that passage. It is 16 submitting a license application, which is submitted in 17 conjunction with the preliminary safety report. So it's 18 exactly the same process.
19 We are going through three different ster.1, 20 one which is preliminary safety report, one which is 21 intermediate safety report, and one which is final safety 22 report. And this is I guess very similar to what's being 23 done in many countries. So this preliminary safety report 24 is familiar to two ministries, Industry and Environment
() 25 which relies on DSIN for the analysis.
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101 1
We have several passages which are conducted 2 in parallel. One is over there. I'm not sure it's very 3 clear. It's submitted to the local representative of the 4
government, which we call the prefect and not the perfect.
5 I not sure I show it's perfect or prefect, but it's 6 similar to a local governor, in fact.
7 He has authority on local inquiry, which is a 8
public inquiry, which has to be conducted according to the 9 law, to the French law. In parallel, there is within the 10 Ministry of Industry the local authority which is 11 reviewing the documents and IPSN as well. IPSN is doing 12 the safety evaluation.
13 And the other ministers, which might be
() 14 involved, are also consulted in the process. And this is 15 especially true for the Health Minister, which is 16 reviewing all data con rning protection of either the 17 workers or the people around the site.
18 So at the end of this process, there is a 19 review and advice of the standing group of experts, which 20 is submitted to DSIN. So in that case, for the decree, 21 post-IPSN and the standing group of experts are reviewing 22 the documents.
- 23 The conclusion which is submitted to DSIN is 24 in the form of a draft decree, which, in fact, contains
() 25 all limitations, questions, and conditions which are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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102 1
attached to the authorization to proceed with the 2 construction of a nuclear facility, O 3 So the draft decree is reviewed in the 4
Interministerial Commission, which may make comments or 5 modification. It has to receive the formal agreement of 6
the-Health Minister because the Health Minister is not 7
signing the document, but it's giving its agreement on the 8 document. And the construction decree is delivered by the 9 signature of the two ministries: Industry and 10 Environment.
11- So, referring to MELOX, I thought it was 12 interesting to put a few dates and our experience with 13 that. The request for the MELOX plant was made on the
() 14 20th of-November 1987, maybe over there, which is an 15 important date. If you could move the slide? So that 16 public inquiry was implemented around MELOX in February 17 '88 and March '88.
18 The final review, the meeting of the group of 19 experts and the conclusion of the IPSN study was about 20 completed in June '88. This is just referring to the 21 decree and not to the safety report. The safety report 22 will be the second part of this presentation.
23 And in March '89, the Interministersal 24 Commission gave its formal opinion. And the decree for
(}) 25 authorizing the construction of a nuclear facility was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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?
i 103 j 1 granted in May 1990. So it's over two years, two years i 2 and a half.
l4 !
3 Next.
i
' i 4 (Slide) I i J
- 5 MR. LEBASTARD
- So this was referring to the 6 authorization to have a new nuclear facility built in 1 i
\
l 7
l' France. A second process is the operating license, which is, in fact, the safety review for the facility. I 8- '
9 So for the decree creation, we were starting i
j 10 from.the preliminary safety report. After all the
- 11 examination, the analysis which has been performed, the l
12 preliminary report is transformed into a provisional 13 report, which is an intermediate report.
) 14, This report is submitted as the basis for the t
j 15 operating license examinat. ion. It's submitted again to i
16 the same ministries, Industry and Environment, which j 17 really relies on DSIN.
j- 18 IPSN, which is the Department of CA with a lot i
4 l 19 of experts and technical expertise, the subject is t
20 analyzing the document, making recommendation, i
1 21 examination, and sending with a standing group of experts 22 its conclusion to DSIN.
- 23 DSIN is, in fact, relying upon the decision by j 24 the two ministries, Industry and Environment, to grant the 25 license with the requirement. And this operating license NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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104 ;
1
- is needed prior to starting the testing, the commissioning >
2 period with either enriched uranium or any fissile i
') 3 i
material, in fact, either enriched uranium or a plutonium. -
1 4
4 After the testing, this is the commissioning I 5 phase. After the commissioning phase, we are giving all '
6 the results to the same-entities and again same kind of 7
process with a lot of examination and analysis by the same l j 8 groups and people which were involved in the former 9 process.
10 And at the end, we are receiving the final 11 license, which is the condition to being in commercial 12 operation. So unless we have satisfied to the testing 13 period, we are not allowed to go to commercial operation.
) 14 Next.
15 (Slide) 16 MR. LEBASTARD: So, again., just a few, dates to 17 make it as clear as possible. The intermediate safety 18 report was submitted in June 1993. The conclusion of the l 19 group of experts and IPSN was given in March 1994.
20 Testing period was quite long, from November 1993 to !
i 21 January 1994. These tests were reviewed after March, and 22 the final license was given in August 1994. I 23 Next.
1 24 (Slide)
() 25 MR. LEBASTARD: So the third is the effluent NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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105 1 and release licensing procedure, very similar there. So 2
it's almost the-same except that for this particular 3
process, the Health Minister, particularly the Directorate 4 of the Health Minister, is involved. And these people are 5 in charge of radiation protection.
- 6 So the same type of -- I won't expand too much 7
because I'm short of time -- process, which, again, gives 8
conclusion to the Ministry of Industry, relying on the 9 same entities plus the specific division of the Health 10 Minister. i l
11 And then this is specific for the effluent 12 release. All the conclusions are given by the local i
l 13 representative of the Ministry of Industry, which is l
14 holding an administrative conference, which is inside the l 15 administration, and also a public inquiry. So it's open i
16 to the public and to comments before granting the 17 authorization, which is also needed for operation of the i
18 plant.
l 19 Next.
20 (Slide) 1 21 MR. LEBASTARD: Next gives a few dates again, 22 which are just showing the steps which were implemented.
23 So 17 July '91 we went to start discussion for the f
3 24 effluent release.
) 25 The first step was achieved almost one year NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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106 1-later with the preliminary license application, formal 2 application, given in June 1992. Public inquiry was O)
(/
} 3 conducted from June 1993 to July 1993. And the final i
4 license was granted in July 1994, a date which is 5
compatible with the operating license, obviou. sly.
6 So we will go through a process of revision of 7
license because you may conclude - om my presentation that 8
the license of MELOX is not compatible with the program F
9 for modification of the plant, which is true.
10 So the decree was created in 1990, which is 11 quite a long time. And since then, many events have led 12 COGEMA to make modification of the plant. This year we 13 will request a modification of the decree to include 14 manufacturing af different MOX fuel types. And next year, 15 in 1998, we will have to go through a complete process, 16 including a public inquiry, to increase the capacity to 17 the level of 250 tons per year.
18 Next.
19 (Slide) 20 MR. LEBASTARD: So a few conclusions. As I 21 tried to illustrate, our MOX fuel fabrication is already a 22 real mature industry. And we are working on a complete 23 commercial basis. Recycling programs are still under a 24 large development phase. And the capacity will follow.
25 We will expand our capacity to be in a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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107 1 position to meet clearly the market demand. So the basis 2
for that will be as it is today, with MELOX plant expanded l() 3 to 250 tons, with flexibility to manufacture either P or B
- 4 MOX fuel and with batches corresponding to quite large !
5 quantities.
6 i
Cadarache will be used, as it is today, for l 7 i.
PWRs on first neutron reactor fuel. It's a very flexible 8 facility And Dessel will be.used in a similar way for j 9 smaller quantities in MELOX. So we will keep the same j 10 industrial organization to meet the market demand.
11 Next.
12 (Slide) 13 MR. LEBASTARD: And a few words for excess
() 14 weapons plutonium. You knew that we are working on the 15 projects of excess weapons plutonium disposition both in 16 the U.S. and Russia.
17 We are working in Russian question cooperating 18 with Siemens to propose, in fact, a program which is very 19 similar to the one which is being proposed in the U.S.
20 The fabrication capacities do exist in France l 21 for this program. And we feel that quick start-up would 22 be needed for credibility and the full international sweep 23 to illustrate this in the U.S. and in Russia, obviously.
24 Thank yc.u very much.
() 25 (Applause.)
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108 1 MR. FERTEL: We'll take just a few questions 2 for G4rard. And then we'll hold the rest for later.
(._ ) 3 Okay. Go ahead, Tom.
4 MR. CLEMENTS: Tom Clements, Greenpeace.
5 You said that fabrication capacity did exist 6 in France for the weapons-grade material. Would that be 7 at Cadarache or MELOX? And if it is at Cadarache, is the 8 capacity already contracted for the German fuel 9 fabrication? Is there a conflict?
10 MR. LEBASTARD: Well, no, there is no 11 conflict. First, MELOX is exactly in the case of the 12 other facilities. MELOX has been licensed with a limit in 13 plutonium content, which includes a limitation for s ,/ 14 plutonium 240. This is clearly an administrative limit.
15 We know how to deal with military plutonium, 16 which is just a question of criticality assessment, as was 17 said by all my colleagues. So this can be implemented in 18 a very simple way.
19 So I am clearly not referring for the time 20 being to the present MELOX capacity. I was referring to 21 Cadarache as well. And we feel that in this case it 22 depends on the program, in fact.
23 So the answer to your question is not very 24 clear from my side. The program is to be well-known prior rN
(}
w.
25 to defining under what condition can MOX program with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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109 1 1
excess weapons plutonium be implemented. But we feel that 2
start-up of such a program will be involving at first !
3 !
small quantities. So small quantities are compatible with I 4 the existing fabrication capacities.
5 MR. FERTEL: One more question, and then we'll 6
move on to the next speaker and then take more questions 7 later.
i 8 MR. MAKHIJANI:
Yes. Arjun Makhijani. t 9
The kind of fuel that will be made out of '
10 weapons-grade plutonium may have to be different in its ,
11 detailed characteristics from what you are doing with 12 reactor-grade plutonium because plutonium 239 has i 13 different fission characteristics than the other isotepes O- 14 of plutonium.
15 And so I wonder how you are going to val!.date 16 the computer codes and go backwards from there to arrive !
t 17 at an appropriate fuel design and whether you are not 18 rushing in your advocating c:: quickness for international 19 credibility, whether you are not putting the cart before 20 the horse.
21 In other words, the computer codes for 22 validating reactor operation for weapons plutonium with 23 higher 239 content, that work hasn't been completed as 24 yet. So --
() 25 MR. LEBASTARD: Well, this is just partially NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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110 1
true because for the time being -- and BNFL as well may l 2 comment on that -- we have been handling different ,
i l 3 plutonium isotopic composition depending on the fuel which l
4 is being reprocessed.
5 L
And for the time being, the two countries, the 6
U.K. and France, are parroting that on the light water 7
l reactors but also magnets of similar reactors, which have 8 an isotopic content in plutonium 239, which is what I l 9 compare to light water reactors.
10 So the present codes are qualified and were l 11 benchmarked for these types of quality.
l And going to --
12 well, it's at least my understanding. Going to the type j 13 of quality in isotopes corresponding to weapons plutonium l
1 s
14 does not appear to be a significant difficulty for nuclear
- 15 design.
I 16 MR. FERTEL: Our last speaker this morning is 17 Dr. Carl Duckwith, who is going to present to us the !
18 experience that Siemens has.
I 19 Carl has recently retired from Siemens, though 20 he is still consulting to them on fuel-related, 1
21 particularly MOX-related, projects. But prior to 22 retirement, he spent 25 years working with Siemens in fuel 23 cycle-related activities, starting back with R&D on the 24 original Hanau project, working through both test phase r
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111 1
commercial demonstration.
2
, ,y And most recently he's been involved in the
( )
\/ 3 project management for the pilot project in Russia for MOX 4 fabrication at both Germany and France and the Russians 5 are working on to look at the disposition of Russian 6 excess surplus weapons plutonium.
7 Carl?
8 MR. DUCKWITZ: Ladies and gentlemen, thank you 9 for the introduction. I hope I will not talk too long 10 before lurch.
11 I would like to summarize my items on MOX 12 fabrication and licensing experience in five items. I 13 will talk about the site description and MOX facilities c \
(,_) 14 and MOX experience we have; then, something about the 15 Siemens new MOX plant -- design, layout, and process; 16 then, the general licensing requirements in Germany; the 17 main topics of safety criteria which were applied in the 18 Hanau plant; and then a brief summary at the end.
19 (Slide change.)
20 This is not very sharp. I'm sorry. The 21 original is very good, but --
22 (Laughter.)
23 Well, this is an overview about the old Hanau 24 site and the Hanau area. It is a colocation of a uranium
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112 1
many good. reasons to have a colocation in that site. '
i 2
Hanau is located east of Frankfort, about 30 kilometers :
3 east of Frankfort in Germany.
I' 4 (Slide change.)
5 Well, you get some more information about the l.
l 6 MOX fabrication area. We had a given infrastructure.
7 These are two fabrication halls of the old fabrication 8 lines, constructed in '71 and commissioned in '71. We 9
have constructed a new storage building here, beginning i 10 operation in 1980. And this was the given infrastructure,
- 11 so the problem was how to find the best place for a new 12 MOX facility.
13 And this is the concrete block here. We also 14 seem to have here only rod fabrication -- fabrication to 15 the MOX rods. We call the assembly -- what was foreseen 16 to be done in the storage building, and also later on the 17 old facilities were prepared for decommissioning. But 18 also, to continue on a small scale for plutonium, 19 especially for laboratory work and waste treatment.
20 (Slide change.)
21 If I talk about MOX activities, in Hanau, it
, 22 is mainly several areas. First of all, the manufacturing i
23 of MOX fuel for lightwater and fast breeder reactors; then 1
l 24 storage of plutonium; then development of plutonium 25 technology. It's for sure that you cannot buy MOX j NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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113 1 technology on the market.
And so all that was realized in l 2 the Hanau area on MOX is Siemens design, the Siemens
(_
,/ 3 process, the Siemens facilities, and Siemens equipment.
1 4 l And we had some smaller additional activities like l 5 dissolving of H-plutonium oxide and also waste treatment. I 6 (Slide change.)
1 7
Again, this is background and also going back 8 to the '60s, the first MOX handling. We had the first 9 plutonium handling we had in Germany. It's going back to 10 the year '63. There was -- formed a small laboratory by 11 Siemens, working in the Karlsruhe Research Center, and I 12 then some of the equipment was moved to Hanau and we began l 13 the more or less larger fabrication in Hanau starting in j
(~h C/ 14 '72.
i l
15 And in the first part, we had two -- from the l
l 16 beginning on, we had parallel production first for fast l 17 breeder reactors and also for lightwater reactors. So the t l
18 recycling programming, in going and using plutonium in l l
19 lightwater reactors, started in Germany very early. And 20 here you can see a diagram about the whole development
! 21 until '93.
22 So the first part was -- the first recycling 23 program until '78/'79, and then we started the second i 24 recycling program on a real commercial industrial basis, r~5 (v y 25 going from '81 on. And the yellow part here, this is the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISL/JJD AVE , N W.
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114 !
I fabrication of the first core, SNR300.
2 These 20 years of production were,.of course, O 3 the main experience we have made, and this was also the
{
4 basis to enter into the project for a new fabrication ;
1 i
5 plant.
i 6 (Slide change.) l 7
Here again, I repeat two slides which were '
8 given at the presentation in the end of February. This is !
9 the German experience, operating experience with Siemens t l
10 fuel and Siemens reactors on the test phase in the years l
11 '66 until '77, and then the commercial phase is starting i 12 since '73. You can see here the number of fuel assemblies i 13 which were inserted in different power plants in Germany, O 14 mainly PWRs and also BWRs at the end.
I 15 But it should be mentioned that the first j 16 recycling was inserted in the German BWR in the Kahl power 17 plants already in the year 1966. :
1 18 (Slide change.)
19 The next slide shows the overall irradiation 20 experience with different cycles. It looks a little bit 21 complicated, but it summarizes all of the good experience 22 we have since '72 until '96. And it is including also the 23 MOX fuel fabricated in other plants, not fabricated in 24 Siemens' plant. And it should be mentioned that we use
() 25 MOX in German PWRs and also in German BWRs.
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115 1 (Slide change.)
2
,, While this diagram summarizes the present
( l
\'
3 situation, we have the experience of the past until 4
'92/'93, more than 200 tons of MOX fuel fabricated and 5 very high burnup. And it shows the expectation for the 6 future as already Michel has mentioned.
7 We have qualified, because we cannot anymore 8 run the Hanau plant, we have qualified the fabrication 9
plants in Dessel, in Cadarache, not yet Melox, but maybe.
10 And so these companies are working on a subcontract with 11 Siemens, and so this is also good experience for us. Not 12 only the experience we have made in Germany, but also 13 qualifying other plants and having the overall Mox
(~
i (-)T 14 management for recycling.
15 What should be mentioned here also is that for l
16 a certain time, the old plant in Hanau will continue with l 17 its operation. Let's say about three years. This is a 18 part of the decommissioning phase for Hanau, so the l 19 operation will continue until the final decommissioning is 20 done. But I believe you can here see the overall picture, l l 21 200 tons, experience in the past, 300 tons of MOX fuel, 22 and how it looks for the future. l 23 (Slide change.)
24 Now, some explanation about the old plant, (o) 25 about the new MOX plant. The license was already applied NEAL R. GROSS court REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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)
116 l
1 i i for in '75. This is a start date, and this was very l-2 l
j formal, because at that time the German Atomic Energy Act V l i
3 was changed and it had foreseen from that time on that L
j 4 fuel cycle facilities had to follow the'same rules as i 5 nuclear power plants.
t 9
6 And the safety analysis was prepared in.'82,
- _ 7 and we had a public hearing in '84. We received all of ii j 8 the licenses. We received six partial licenses in the i
9 period '87 to '91'. We started the groundbreaking in '87, i
10 and more or less the plant was' finished in '92. You can i
e 11 see that we have opent 1 billion D Mark ror the investment 12 itself, and it is more than 90 percent completed.
i 13 (Slide change.)
L 14 Here is some data about the plant itself --
i j 15 120 tons capacity. I do not want to read everything, but i
1 16 you can get an overview about the plant itself.
4
- 17 (Slide change.)
1.
18 I come back to some details later. Here are l I 19 some figures about the building itself. We can also i.
20 continue with the slides.
.21 (Slide change.)
22 This is a cut through the building itself.
1 23 You see easily we make a different between the process l 24 building, heavily shielded, and auxiliary building for i 25 ventilation, and so on. And the operation was assumed to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W. i (202) 2344433 WASHINGTON, D C. 20005-3701 (202) 234 4433
117 1
take place on three floors in the process building.
2 (Slide change.)
t n
\- / 3 Here is another form of a diagram to see also 4 what is arranged on these three floors. We wanted to 5 start with the pellet preparation on the second floor, 6 sith the whole pelletizing work in the first floor, from 7 ball mills until the sintering and grinding, and the real 8 rod fabrication until the final quality control on the 9 ground floor. So this gives a very good overview about 10 the plant itself.
11 (Slide change.)
12 It was foreseen to have the fabrication within 13 two lines. The starting material was plutonium oxide
(-) 14 coming from the reprocessing plant, and uranium oxide 15 coming from our own production, and then we had mainly the 16 fabrication steps -- powder preparation, pressing, 17 sintering, grinding, stacking, and all fabrication.
18 What should be remarked is that we wanted to l
19 have enough flexibility between the fabrication equipment 20 and have foreseen many storage places, of course, heavily 1
21 shielded. And the end product of the new plant was the )
l 22 fuel rod, and this was then transferred to the storage j i
23 building and for the final assembling. l 24 You'll see also that we wanted to have -- we j r~s ~
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118 !
t i lines, but there was full flexibility between the two f
2 lines. So if we have one repair in one line, you can l'~
i 3
easily transfer the material to the other line, and there i 4 is enough redundancy regarding the equipment itself.
5 (Slide change.) ,
6 Briefly, the process -- in our case, we wanted 7 to start with the optimize co-milling process. It's a 8 master mix preparation. Again, plutonium oxide is 9 starting material. We have a co-milling process, and then 10 blending and homogenizing, and then the normal pressing, 11 sintering.
12 For special cases, we wanted to use also a wet 13 process, where we wanted to start with plutonium nitrate.
( 14 Also there, a co-precipitation process, and then this 15 material fed to the normal way of production.
16 (Slide change.)
17 While the rod fabrication is simple to 18 explain, first weld was done in the uranium plant, second i
19 weld by resistance welding in the MOX plant. And here you I i
20 see the sequence of the rod fabrication, including the
! 21 inspection. This is all normal, and then, please, at the 22 end, the assembling.
23 (Slide change.)
24 This is also a routine process and nothing i 25 new.
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l 119 l i
1 (Slide change.) i l
2 Please, at the end, two slides regarding O 3 safeguards-and waste treatment. These are more or less J l
l 4 added processes to the plant. A safeguard is essential.
t 5 Here you see the main control points. These are the green 6
points where the safeguard authorities are sitting, and 7- the safeguard control is done by EURATOM and IAEA.
! 8 And we have also foreseen to have internal 9 measurement points. These are the red dots. And they 10 have a very good in-line control of the material.
l 11 And the whole system was developed within the l
l l 12 facility attachment with IAEA, with EURATOM, and also with 1
13 the. assistance of Los Alamos.
D 14 (Slide change.)
l 15 At the end of this section, please, waste 16 treatment. Of course, it was necessary to have to handle 17 all of the alpha waste in the Hanau area. We make, of t
18 course, a difference between the waste coming out of the 19 glove boxes. This is shredded, cemented, and you get 20 germs in the end product for final disposal. Or, in the 21 case of burnable waste, we have transferred this out of 22 the Hanau area, and we wanted to use an incineration 23 process, and the ashes are compacted and then brought back i
- 24 to the Hanau plant.
25 (Slide change.)
i l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE N W.
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_ _ _ _ _ . . . _ _ ___ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - __ ._ _ _ __ . - m _ ._
120 ' i i
1 Well, now we come to the licensing overview. I 2
The first three slides was general information. You'll !
3 ,
see in two slides more of the legal requirements, showing 4 the different laws in Germany. Most important is the ,
i 5
Atomic Energy Act, in the middle where all of the general i 6
requirements are laid down, and then we have ordinances 7 and administrative arrangements. And among the 8 ordinances, the most important one is the radiation 9 protection ordinance.
10 (Slide change.)
11 By this overview, you can better understand 12 what is the relative importance of these licensing 13 documents, beginning also with the basic law again -- the i
14 Atomic Energy Act, the ordinances. So these are all of 15 the legal requirements on the federal level, and then on i i 16 the bottom line you have more of the technical elements of i 17 all licensing regulations, guidelines, standards, and the 1
- 18 industries then finally responsible for technical i
19 specifications of components and systems. t 20 (Slide change.)
l 21 I believe this overview shows the interlinks 22 between the different institutions. And if you start as 23 an applicant here, then your first partner is the state
- 24 ministry, and the state ministry in the different states l
l
() 25 in Germany, and the state ministry in our case is working l NEAL R. GROS 5 COURT REPORTERS AND THANSCRIBERS 1323 RHODE ISLAND AVE.. N W.
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, 121 i 1 !
on behalf of the federal ministry, which is responsible !
2 l for the Atomic Energy Act is Germany.
)
3 But this, I believe, is also the crucial point 4-for the German situation, because if you have not complete 5
agreement and a complete good dialogue between the state 6 ministry and the federal ministry and the federal 7
government, then you can have a lot of conflicts, a lot of 8 blockades, and a lot of troubles. And this was more or 9
less our case in Germany, because Siemens was an applicant 10 in the state of Hessen. i l
11 The state of Hessen, for some periods of time, 12 was in good agreement with the federal government, but for I 13 the serious programs of work, they were in complete !
() 14 disagreement with the federal government, and then you are 15 more or less lost.
16 -Well, you can see details here. The applicant 17 has to apply, talk to the state ministry. The state 18 ministry has interconnections to local authorities, and on 19 the left side to technical inspections, technical 20 agencies. .They give orders to technical agencies, and 21 they give also orders to experts for any kind of 22 supervision and expert evaluation.
23 Then, the flow of information is going back to 24 the applicant. Well, on the federal level, you can see.
() 25 also we have reactor safety commission family, which is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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122 1
working under the federal minister for environment. And 2
they have also different institutions here for advising,
(_) 3 and also the federal ministry for environment has to keep 4 !
contact to other ministries on the federal level. !
5 Well, I would say this is similar to the 6 Persian system and the French system, but what is 7
completely different is the importance in Germany of the i 1
8 state ministry.
i 9
Well, this is the general situation, and I 10 come now to some criteria which we have applied in the new 1
l 11 Hanau MOX Plant.
12 (Slide change.)
i 13 The main topics of safety criteria are listed I f~s
(_) 14 up here, and I do not want to repeat everything here. But j 15 I give some details in the following section on radiation 16 protection, on criticality safety, on construction and 17 design, and the accident analysis.
18 (Slide change.)
19 So, first, some overview about the radiation 20 protection ordinance and how the principles were realized 21 in the new Hanau plant. The radiation protection is based 22 on the ICRP principles. We have limit -- to follow and to 23 obey the limitation for the population outside the plant, 24 and we have to follow the limits for the workers inside (J
- 25 the plant.
\-
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i 123 I
] 'l (Slide change.)
f 2
Here you see the detai'Is about the radiation i 3 protection. The overall limit for the equivalent dose was i
- . 4
- 10 millisieverts per year, and this was reached by the -i j i 5 design principles listed up here -- minimization of the (
-6 inventory, shielding within glove boxes. All principle
'I i 7 instruments to handle MOX was the glove boxes, and we i l
l t
8 didn't want to change this.
3 4
9 But we have improved the shielding, of course.
i
! 10 We used double-walled glove boxes. We used combined --
k t 11 gamma shielding.
d 12 We have minimized the manipulation of the 13 staffs by using nearly 100 percent automated procesces.
14 We have applied a barrier concept to prevent contamination i
i 15 and incorporation. And we have air, surface, and personal l
3 16 monitoring.
I i
17 And in addition to these design principles, we 4
}
4 18 have calculated the dose rate at every work'ng i place with 4
19 a special program, and the results are here. A dose rate l
20 of less than 10 millisieverts per year can be easily
{ 21 observed.
} 22 (Slide change.)
- 23 Well, some more information for the radiation i
1 l 24 protection. The whole inventory for the plant was 25 characterized by these figures -- 2.5 tons of plutonium at i
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, -.i. - ,
124 1 one time. We're allowed to handle eight kilograms of i 2 americium, and then the uranium material.
O 3 (Slide change.)
i l
4 And this is the plutonium vector we have used ] !
5 for the radiation protection.
So a very -- let's say, my )
\
6 words, a very bad vector, representing a burnout of 48 7 megawatt days per kilogram uranium. And this was done in ;
8 !
close agreement with the reprocessing companies. And if 9 it would have come to higher burnups, this would have 10 reduced -- the consequences would have been to what you 11 were throughput.
12 (Slide change.)
13 This is an overview of how we realized the 14 barrier concept to have a good instrument for radiation 15 protection. You see in the inside the glove box, then the 16 working area, then the working hall, and then at the 17 outside there is underpressure from inside to outside, and 18 a lot of filter systems from the glove box until the i 19 outside. So this was our concept to realize radiation 20 protection.
21 (Slide change.)
22 Last overview about the radioactive effluents.
23 For the airborne criteria, and then also for liquid 24 material, you can see data. And that means the limits for
() 25 radiation protections also for these cases were observed.
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125 1 (Slide change.)
2 I come to the next point -- design criteria k# 3 for criticality safety. For this reason, for criticality 4 calculations, we used another plutonium vector. This is 5
more or less weapon plutonium, 95 percent plutonium 239, 6
for historical reasons for treating this in Germany.
7 Here you see the boundary conditions for the 8 criticality calculations, the plutonium content in 9 different mixtures and different forms of material, and 10 for criticality calculations the priority was seen for 11 technical measures, geometry, neutron poisoning, 12 moderation control, and administrative measures only in 13 areas with low inventory. And, of course, the overall
+
r~%,
's_/
14 principle was the double failure principle.
I 15 (Slide change.)
l 16 There is some information about the design ;
l 17 basis accidents. The requirement was the effective dose l 18 equivalent should be below 50 millisieverts per year for 19 people outside the plant integrated over a lifetime of 50 20 years, and here you see also the results of our 21 calculations for fire criticality, leakage, crush of the 22 glove box, earthquake.
23 Airplane crash was not design basis accident 24 because the building was designed against this accident.
/~
(v ) 25 And also blast waves from the outside, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ICIAND AVE., N W.
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126 1 (slide change.)
I 2
(~~T The last word on the design principles -- here v- 3 you have one example for the mixing and blending process, 4 how we realized the engineering. For example, for this 5 item, for the filling of any equipment, we had, in the old 6
plant, manual input of powders, and we have developed a l 7 pneumatic powder transport system to avoid any hand 8 operation and to come to a fully automated process. But i 1
9 these are some examples of how we realized the automated i i
i 10 process. l l
11 (Slide change.)
12 Well, this is the end of my overview, and let 13 me conclude with a small summary. I believe we have more
/~N
(,) 14 than 30 years of fuel experience in fabrication, design, 15 irradiation, project management, and plant design, 16 licensing, and operation. And, therefore, we are in a 17 good position to offer qualified services, technologies, 18 resources, and experience for the consumption and handling 19 of weapons grade plutonium in lightwater reactors.
20 Thank you very much.
21 (Applause.)
22 MR. FERTEL: I think what we should do now is 23 take questions for everybody on the panel. Carl will take 24 his seat, and feel free to ask Carl a question, or Gerard
/~N i
25 or Michel or Bryen. Anybody? David?
L~s)
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127 1 MR. AIROZO: Bryen, I just wanted to -- this 2 is for Bryen. I just wanted to clarify --
i 1/ 3 MR. FERTEL: Tell them who you are, David.
4 MR. AIROZO: I'm Dave Airozo with Nucleonics 5 Week.
6 When you were talking about production costs, 7 I think we're going to have a difference of opinion on 8 what that word means -- production costs. You said it 9 would cost $500 million to build the plant. But on an 10 annual basis, what do you think the cost would be, 11 assuming whatever your optimal production is, do you know?
12 MR. MARTIN: Okay. I understand the question 13 you're asking in terms of production cost. That's not
/ \
( ,/ 14 information I have directly at hand. The point that I had 15 made earlier was that, you know, because this is a civil 16 plant, the cost of operation is recovered from the 17 customers in the commercial MOX production contracts we 18 have. And that's in contrast to the operation of a 19 facility that was being designed for the deposition of 20 weapons grade plutonium. But we can certainly provide you 21 with that information outside the meeting.
22 MR. AIROZO: I had one other completely 23 unrelated question. Actually, it's not to anyone on the 24 panel. I'm a little confused. I think someone at NRC
,a
) 25 might be able to address it, actually.
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128
- 1 I,
I'm a little confused as to if the agency does 2
not now have the authority legally to regulate DOE 3
4 facilities, this would be considered within that group.
1 i
4 l This MOX facility would be considered within that group. :
5 i
i I don't see how this schedule can work out. The idea that 6
the NRC is taking over regulation of DOE facilities, j 7 that's a 10-year program. Does this MOX facility fall j
j 8 within that overall takeover of the regulation of DOE 9 facilities? How does this schedule possibly work?
- 10 MR. SHERR
- This is Ted Sherr, NRC.
4 3 11 .
That might be a question better for DOE. But l
12 1
as I understand it, one of -- I think DOE is considering 1
4 13 the licensing of the MOX facility as a privatized
() 14 facility, and that the licensing wouldn't be under the.
15 external regulation legislation. I But it would be covered j 16 by a privatized facility.
17 There are some legal questions in terms of 18 whether or not existing legislation, existing autharity 19 would cover NRC's regulation of that facility or not, 20 given the fact that it would still be owned by DOE. But I 21 think the general sense is that the MOX fabrication plant 22 would be licensed by NRC under the privatization rather i 23 than external regulation.
24 MR'. DOLLEY: Steven Dolley, Nuclear Control
) 25 Institute.
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i i
129 ;
1 And the question, actually, is for each of the '
2 panelists.
It was asked earlier but not really answered, O! 3 at least this part of it, and it goes to the question of' !
4 the uncertainty of measurement of plant holdup.
5 The uncertainty fa'. tor with such technologies 6
as neutron coincidence counting is in the area, as we 7 heard earlier, of 20 to 30 percent measurement 8 uncertainty. And I'd be interested in hearing from each 3
\
9 of the companies what your experience with holdup has !
1 10 been, specifically going to the question of the degree of 11 uncertainty in measurement of in process holdup, and' 12 whether or not that information would be provided to NRC 13 during the licensing process of a MOX plant.
C\
(, ,/ 14 MR. FERTEL: Any member of the panel want to 15 start?
16 MR. DUCKWITZ: I want to explain -- well, that i
- 17 is difficult to answer this question, because any operator l 18 is under the control of authorities like EURATOM and IAEA.
19 And they have only the right to give any information how 20 they control and what are their statistics. So even if we 21 would know these figures, the operator is not in a i
! 22 position to give detailed answers and to publish any l 23 figures about that.
l !
l j 24 MR. DOLLEY: My understanding is the IAEA I 25 leaves that up to the member states, but the IAEA says D
l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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., ~ , - -
.i 130 t 1 they can't disclose it but the member states can. It's not that the IAEA says, "You can't disclose it."
f 2
O 3 MR. FERTEL; I'm not sure. I don't know 4
1 really that we can debate whether their member states or 5 IAEA can disclose that.
6 MR. DUCKWITZ: Well, in the European case, I 7
would say it's not possible by the different government. '
8 It's only possible by EURATOM, and maybe by the agency in 9
Luxembourg, or by the EURATOM supply agency, i 10 MR. LEBASTARD: Well, in fact, I may add 11 simply that if we agree with what was said by Carl, it is 12 try that each equipment for control has its characteristic 13 -- I mean, its attitude, and so on. But in that sense, 14 for what constitutes safeguards, we are independent bodies-15 doing the same thing, like EURATOM is one, and in France 16 there is also a natignal entity doing the same.
17 So it's really statistics, and this 18 combination of controls gives numbers which are very 19 valuable. And we are experienced, not in MOX fabrication 20 in particular, but in plutonium-related activities where, 21 for instance, decommissioning a glove box -- what you 22 measure after the decommissioning work is what you i
23 recover. In fact, it's the -- for a large amount, where
! 24 the -- the incertitude, which was at that time measured.
25 So --
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i 131 j 1 MR. FERTEL: Are there other questions, or 2
does anybody from the NRC have anything they want to ask?
\/ 3 David?
4 MR. AIROZO: Dave Airozo, Nucleonics Week.
5 There has been some talk about perhaps sort of 6 boxing up the Hanau plant and bringing it to the United 7 States. Is there no hope -- does siemens have no hope of 8 ever starting that plant, and would they entertain offers 9 to, in fact, box it up and send it off somewhere else?
10 MR. DUCKWITZ: No. I would say there is no I
11 plan and no real plan and no reality to start again the 12 Hanau plant in Germany. It is not -- it was a decisic.n by 13 Siemens to stop -- to not enter again into MOX fabrication
(_) 14 in Germany. And also, the blockade, which we had in our 15 site between the state government and the federal 16 government, is still the same. And because -- and if you 17 wait for the next elections, or you l you can only wait.
18 So there is no basis to come back to the Hanau MOX plant.
19 MR. AIROZO: And the second part of that?
20 MR. DUCKWITZ: Sorry?
21 MR. AIROZO: The second part of that question?
l 22 MR. DUCKWITZ: Yeah, I got it. Well, Siemens l l
23 has still the capabilities for engineering, for transfer 24 of -- we have all of our experience, and we have realized i
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132 I
government has, in cooperation with the Russian
}
2 government, within this frame we are working with EURATOM. 1 O 3 We have worked on the use of MOX fuel, first on the
{
4 fabrication side but also on the engineering side, on the 5
licensing side, and also on the physics -- how to use in l 6 the Russian reactors.
7 Well, this is underway, and it was also a 8 clear conclusion on the expert conference at the end of 9
October last year to come to a trilateral cooperation 10 between France, Germany, and Russia, and I believe this 11 will go on.
And whether we have chances or can realize at 12 the very end to transfer hardware and equipment from Hanau 13 to Russia, maybe. The planning is possible, but we need a 14 little bit more time for realization. But in general, why 15 not?
16 MR. FERTEL: Any other questions?
1 i
17 MR. CHEH: Unte Cheh, U.S. NRC.
i 18 I have one question about the criticality I 19 safety. I am fairly familiar with CNO and the NCNP code, j i
20 also the code written. However, whenever I look at these l 21 results, and then I always think about the results from 22 Germany or the French, I do not know what kind of code 23 they are using. \
i i
i l
j 24 Someone told me that the French are using the l
25 MORET code, which I heard about but have never seen any NEAL R. GROS 5 t COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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(
133 l l' 1 articles or anything. So I am wondering whether you could i t
j 2 give me the code names at least. What kind of code are t
4 i
, 3 you using to calculate criticality?
4 3 I have been in the nuclear industry about 29 l 5 years, since 1966, as a student. So I am fairly familiar ;
6 with what is going on to calculate this kind of !
7 criticality safety. I still have a question about the 8 German code and French code. '
l 9 MR. LEBASTARD: Well, unfortunately, I am not :
10 !
in a position to answer your question, but we will provide '
11 you with the information.
12 MR. CHEH: Thank you.
13 MR. LEBASTARD: Okay.
14 MR. DUCKWITZ: Well, I can foresee the same.
15 Please give me your name card, and I will contact the 16 German reactor safety commission, who has partly made i 17 these calculations, and they can give you an answer. l 18 MR. CHEH: Yes. Thank you.
19 MR. FERTEL: Thank you. We'll see that you 20 get those answers.
21 Just to quickly summarize, and we can all go 22 each lunch in a minute. I think that from the industry -- !
1 23 Gerard?
24 MR. LEBASTARD: If I can on production costs 25 -- there were several questions on production costs, and I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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134 1 just wanted to put additional comments that.
2 Production costs, as a given information, it f')';
\_ 3 is not really the interesting information. You have to 4
refer to the cost which is analyzed by the utility or by 5
the customer, and there you have to make the comparison 15 with other sources of supply for providing the same 7
service, which is for a nuclear operator, which is to 8 produce kilowatt hour.
9 So today what we can say -- and you have 10 detailed information with your colleagues of nuclear fuel 11 -- they published from France a lot of detailed 12 information in October 1996. EDF clearly made the point 13 that today, according to their specific conditions, which
'n )
x,,/ 14 was implying their cost of procurement for uranium, their I 15 cost of procurement for MOX fuel, was already competitive.
16 But let me stress that it is very important to 17 know what you are fabricating to assess any costs. And as 18 just an example, I would say that fabricating 40 tons of 19 MOX fuel of the standard type to feel, for instance, the 20 need of 10 reactors, which would load the same type of 21 fuel, would not be at all the same cost than feeding, 22 well, 10 reactors, one of each type -- BWRs, PWRs --
23 different designs of the fuel, and so on.
24 So there is a very high sensitivity to the n
( ,) 25 type of program you would be defining.
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i 135 i i 1 MR. FERTEL: I 1
Thank you, Gerard. ;
2
' I think that from what the panel of industry ~
3 l experts familiar with MOX fabrication said, my impression i
4 would be, given the focus, is regulatory process and l i s~
licensing -- that in all of the countries, while there is l
) 6 differences in organizational structure, that all of the }
)
j 7 countries have a very systematic process which in many l
8 instances reflects the same types of issues we deal with 4
l
- 9 in this country in our regulatory process.
- 10 I think they were systematic. I thought the 11 scope was certainly as broad as anything I've.seen us do 1- 12 here for either material licensees or, for that matter, 4
13 power plants.
I D
!. 14 I thought it was interesting that, in many of i
J 15 the cases, they are talking -- and Chairman Jackson may J l 16 have listened to some of this -- they are talking risk- {
i 17 informed, and they certainly seem to be talking
! 18 performance-based from the way they are locking at i
i 3
19 licensing the MOX fabrication facilities in those 20 countries.
- 21 I also thought that the process seemed to be j 22 very open, maybe not as open as ours in some places, but !
l 23 certainly very open for public participation in a number i
j 24 of areas. And it focused on the three major areas --
25 facility safety, safeguards, and environmental. So I saw t.
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.. . - .. , .--. . --- - - . ~ ~ .. - . - . . . ..
136 1
tremendous parallels, and I would hope that the NRC could 2
take some of the models and some of the knowledge.
3 A number of the members of the panel mentioned 4
this is a mature industry from the standpoint of operating 5 facilities for a number of years. I don't think we need 6
to recreate the wheel in many places, but maybe the wheel l l
7 is a little differently shaped here when we look at it. l 8
What I heard from the one presentation we got 9 from DOE is no one should run off thinking that DOE has 10 really identified the facility yet. They have identified I i
i 11 facilities, all of which have pluses and minuses, and they l l 12 are still going through their process to figure out which 13 facility might be the best one for a MOX fabrication j 14 facility.
l 15 I think that they indicated that they are i
16 having a good dialogue with NRC, and I think Ted voiced 17 the same. It does sound like that dialogue would probably 18 have to increase if they were going to include enough 19 information for someone bidding the RFP to know what the 20 licensing requirements are. I'm not sure that there is I
l 21 enough known right now that you could put together a I
( 22 response to an RFP and know that you were coming anywhere I
23 near the bull's-eye.
4 24 And there has been some questions raised about
() 25 how you license under current DOE legal authority, and
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137 j 1 that is something that needs to get cleared up before they ;
4 2 go out.
s i k ,) 3 I think the other thing I heard maybe for the i
i 4 first time was that DOE may not name the facility, the 5
site location, when they come out with their Phase II RFP 6
, at the outset. It may be mentioned or named after that. !
7 That's what I got out of the DOE thing, 8 Again, I thought there was great congruence on the I j 9 industry panel about the experience in the countries. I'd l 10 like to thank all of the members of this panel. They not s
i 11 only put together good presentations, I think Bryen summed ;
4 12 it up. ,
- 13 It's the kind of thing you could probably talk l i
() 14 about for a week if you were going to get into the details 15 and really do it. And to communicate the kind of j 16 information each one of them did in literally 30 to 45 17 minutes, I think they did a real good job. They came a 18 long way, and some didn't get much sleep, so I think we i
19 should give them a hand again for their effort.
1 20 (Applause.)
4 21 I'd like to thank NRC, and particularly Ted l 22 and Liz Ten Eyck who sat through the whole meeting with us
- 23 today listening to this. NEI is clearly committed to
)i 24 trying to facilitate these technical exchanges, going both i
i
() 25 ways. If NRC has things they need from the industry, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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138 i
1 certainly will look to try and do what we can there.
2 3
And I'd like to close by mentioning to the l
() 3 members of the working group that we will be reconvening 4
- for lunch over at the hotel, and the room is Plaza 3. And 5
we'll see you all there, and I'd like to turn it back to 6 Ted just before adjourn. He wants to make a couple of 7 statements.
8 MR. SHERR: I will not hold you~up long. I 9
just wanted to take the opportunity to first express our 10 appreciation for the speakers. It was very informative 11 information, and I think we'll probably be in touch for 12 more information in due course. And we appreciate your 13 coming all of this way to share that with us.
() 14 Again, I'd also like to express our i
15 appreciation to NEI for putting together this workshop, '
16 and it has been very useful and we look forward to other 17 ones as well.
18 Also, I want to express my appreciation for l 19 the audience participation. I think there were a lot of 20 good questions asked, and ones that will help us think 21 through this issue, and also I think there were a lot of 22 good answers as well.
23 I'd like to -- again, I mentioned earlier that 24 there will be a court reporting of this meeting, and I'd j
() 25 like to express my appreciation to the court reporter for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 his good' work.
And that should be available within a 2 couple of weeks.
t O
d 3
{
And last, but certainly not least, I'd like to i 4
express my appreciation to vanice Perin, who is the one 5
who coordinated all of the arrangements for this meeting, 6 and she did a fine job.
7- (Applause.)
8 (Whereupon, at 12:47 p.m., the proceedings in I
9 the foregoing matter went off the record.) I I
10 l 11 12 13 l i
14 15 16 17 18 19 20 l
21 22 23 4
l 24 g@ 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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. . = .. .- . - - . _ . - - . . . ... . .. - . - - . ..
h e
]
O a
d CERTIFICATE ,
j This is to certify that the attached proceedings before the United States Nuclear i
{
Regulatory Commission in the matter of:
1 i
Name of Proceeding: PUBLIC MEETING ON THE FABRICATION i OF MOX FUEL 1
Docket Number: N/A Place of Proceeding: ROCKVILLE, MARYLAND i
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to i
typewriting by me or under the direction of the court l
reporting company, and that the transcript is a true and ;
accurate record of the foregoing proceedings.
$1 & '
1 "CORBETT RINER ,
Official Reporter Neal R. Gross and Co., Inc.
O NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODEISLAND AVENUE.NW (202) 234-4433 WASHINGTON, D.C. 20005 (202)234-4433
._._______.-._.________.__-_..____._.,7
- -l i
1 i
Industry Presentation on the Fabrication of MOX Fuel .
Talking Points Welcome and Introduction of the Meeting 1 .
i Good morning and welcome. My name is Ted Sherr. I am the chief of the Regulatory and Internationa Safeguards Branch in the NRC Office of Nuclear Material Safety and Safeguards NRC is hosting this meeting at the request of the Nuclear Energy Institute. This meeting will com presentations relating to the fabrication of mixed-oxide (MOX) Fuel.
f .
We look forward to hearing the presentations. Since the DOE publication of the Programmatic Emironmental Impact Statement in Dw A.1996, and the Record of Decision in January 1997, much j interest has focussed on the MOX option. The use of MOX fuel in nuclear power reactors is one of the two means DOE has selected for the disposition of weapons-usable fissile materials. The other means is
- immobilization of the plutonium. DOE anticipates that NRC will hast regulatory authority oser the plutonium disposition activities, either by sittue oflegislation prmiding for NRC external regulation of
} DOE activities, and/or by virtue of the privatization of the aethities.
k *
- As announced in the Federal Re=*r Notice of March 6,1997, this is a transcribed publ.ic meeting to
( inform the public and the NRC staff about issues invohing the fabrication of MOX fuel. This meetin!
a followup of the February 21,1997, meetag at which the Nuclear Energy Institute facilitated '
presentations on the la of MOX fuel in nuclear power reactors.
g g
(~
Before we commence with the presentations, I have a few adnunistrative announcements:
- This meeting is being transenbed by a court reporter, and also is being vid~a:=d The transcripts will be available in a couple of weeks through the NRC Public Affairs Office.
- Smoking is not allowed inside NRC facilities, except in designated areas. (most convenient location is probably outside the building)
- No cating or drinking allowed inside the auditorium.
- The restrooms are located outside the auditorium. across from the stairs.
+
Our first speaker today is Mr. Marvin Fertel. Manin is the Vice President for Supphers, internat,onal and Fuels at the Nuclear Energy lastitute.
Manin. welcome, and thank you and NEl for organizing this meeting today.
l l
t
'l O
v i
I.,
3
) .- 9********************
Technical Briefing for Nuclear Regulatory Commission Office of Fissile Materials Disposition 1
Site Infrastructure &
Building Feasibility Review for a 4
MOX Fabrication Facility i
- Damian Peko Office of Fissile Materials Disposition Department of Energy I
\ ed e O O
i I:
l Technical Briefing for i
Nuclear Regulatory Commission
.'; e e e e * **e * * * * * * * * * * *
- Office of Fissile Materials Disposition j
1 Site Infrastructure &
1; Building Feasibility Review l
for a i
i MOX Fabrication Facility c .
l -
I l
- Bert Stevenson l Office of Fissile Materials Disposition l Department of Energy 1
! . G G G
i ISTRODUCTION 4
e o e ee e e e e o e e e e o e o e e e Office of Fissile Materials Disposition i
Today's briefis:
I
! - Previously Released Information j .
i i
- An Opportunity to Clarify DOE's Position I
h PURPOSE OF THE REVIEW
. . . . . . . . . . . . . . . . . . . . orrice orvissite uateriais oisposition i
Review the suitability of sites and existing -
buildings being considered to host the l fabrication facility.
1 i -
NOT. a site selection process l
I
[
i
- e e e
i h SCOPE OF THE REVIEW e o e e o e o e e e e e o e o e o e e o Office of Fissile Materials Disposition 1
Gather Information and Comments i
i Information on Site Infrastructure Building Data Order ofMagnitude Cost Technical Comments from
! Fuel Fabricators Site Experts 4
. O O O
l e
i' 8^ssorx8v8w L
l e e e e e e e e e e e e e e e e e e e e OffjCe of Fissile Materials Disposition 4
i I -
Assumption of generic MOX process (Dry,100 l MTHM/Yr) _
i
, Use of site infrastructure checklist and building j questionnaire i
G 9 8
TEAM PARTICIPANTS i
. . . . . . . . . . . . . . . . . . . . orrice orvissite uateriais oisposition
! l DOE (Team Leader) l National Laboratories (TechnicalRequirements) l Fuel Fabricators (Fuel Fabrication Expertise)
- Belgonucleaire
- BNFL 4
- Cogema l - Siemens
- Sites (Expertise on Each Site) i
- e e e ,
i b*
i i
SITES AND BUILDINGS i
REVIEWED i e e e o e e e e ee e o e e o e e o e e Office of Fissile Materials Disposition Pantex No Building Designated - Building Site Proposed i
Savannah River Site P-Reactor Fuel Assembly Building 3 Idaho National Engineering & Environmental Laboratory .
Fuel Processing Facility (FPF) 4 Hanford
! Fuels & Materials Examination Facility (FMEF)
I O O O
SITEINFRASTRECTURE
, 9 CONCLUSIONS
- * * * * * * * * * * * * * * * * * * * . Office of Fissile Materials Disposition All sites are feasible for MOX fuel fabrication
- Pantex: Limited capacity and operating radiological waste management infrastructure and no special nuclear materials processing infrastructure
- Savannah River: Extensive operating radiological waste management infrastructure and extensive operating Pu and highly enriched uranium (HEU) purification processing infrastructure
- INEEL: Extensive radiological waste management infrastructure and extensive, but inactive, Pu and HEU purification processing infrastructure
- Hanford: Extensive operating radiological waste management infrastructure and extensive, but inactive, Pu purification i processing infrastructure t
9_ _ _ _ _ _ . _ _ . _
9 _
9
r ,
i ;,
.: L. \~
~
- i , ,
BLILDIN G -
~
?,y;.
~r -
CONCLE SIONS .
l 'y.
e ee e e oe e e ,
e,. e o e e e eoee e Office of. Fissile Materials Disposition
.p:
- s. . ,,.
- $ .k- .
i ie
.. - ' s'
. g
7
- y. : &q Conclusions ! '
c' 'j - All building $ are feasible for a MOX fabrication facility g with suitabldmo'difications n
- .. - There are adyantages assbeiated with using newer and
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- O $BNFL 1
1 i
, 1
. ), Licensing of the -
'... SellafieldMOXPlant SMP 1 t
4
- 1 l
i By i
i
- i O ;
i Mr B R Martin Mr A J Tilstone i ;
Paper Presented to Nuclear Regulatory Commission ,
s .
Washington, USA 26 March 1997
$BNFL O
WP2:Al%006. DOC
1 L INTRODUCTION It is BNFL Company Policy that inter alia:
i O
'The Company will as a minimum conduct its activities within the framework of all televant legislation'. ;
j It is therefore important to have a general understanding of the UK Regulato ,
to understand how a commercial scale MOX facility is being developed and BNFL in the UK.
's
]
{ .
nis paperis in two parts; it first describes the majorlegislation relevant to the licensing and operation of a MOX facility at Sellafield and provides an insight into h
. the UK Regulators operate. In the second part it describes how the BNFL Projec arrangements and safety management systems have been developed to address the Company's legal obligations with specific reference to the Sellafield MOX Plant (
project.
, 2. UK LEGISLATION AND REGULATION
- l. 2.1 Introduction British Nuclear Fuels legal obligations result from two different types of legislation.
i a.
That which applies to any industrial ins'tallation in the UK. This coven the requirement for:
e the Health and Safety at Work Act e
the Control of Substances Hazardous to Health (COSHH) Regulations e planning pemtission i
e approval under the Building Regulations e
the Factories Act and associated Regulations e
the Environment Protection Act (1990)
- b. Dat which applies to nuclear installations or to people dealing with radioactive materials.
T In addition to the above, the UK nuclear industry is subject to: \-
- c. European Union Requirements
- d. International Atomic Energy Regulations It is not proposed to expand further on the ' conventional' legislation referred to in (a) s except in relation to the Health and Safety at Work Act which provides the i
underpinning legislation for the majority of safety regulation in the UK including the licensing of Nuclear Installation, but to concentrate on those aspects of legislation, l regulation etc., which are specific to the nuclear industry.
WP2:AT96006. DOC
2.2 Conventional Safety Leeislation
!O i
Health and Safety at Work, Act 1974 A committee was appointed by the UK Govemment in 1970 to consider the whole range oflaw relating to occupational health and safety. It reponed in 1972 and fundamentally criticised the existing legal framework. In panicularit felt that:
1.
, the mass of existing legislation should be replaced by one all embracing statute;
- 2. -
' the law ought to lay down easily understood broad principles, and not a
\, complex mass ofdetailed mies;
- 3. prosecution was not the best primary sanction; 4
the law ought to protect everybody, and not only employees; 5.
there was too much emphasis on technical safety standards, and not enough on management's responsibility to provide systems of work which were actually safe when operated; and
- 6. the workforce ought to be involved in the safety effort. -
The Government introduced legislative proposals based on this repon in May 1973 and these were passed into UK law on 31 July 1974.
O The Act established the Health and Safety Commission and the Health and Safety Executive. It makes provision for securing the health, safety and welfare of persons at I work, for protecting others against risk to health or safety in connection with the activities of persons at work, and other activities related to health and safety. Under this Act the mass of detailed and technical legislation, which was administered and i enforced by a variety of statutory agencies, was replaced by a simpler, coherent and co-ordinated body of regulations supponed by practical guidance, and coming under the scrutiny of one central policy-making and enforcing body. 'Ihat body is the Health and Safety Commission (HSC) with, as its enforcing arm, the Health and Safety Executive (HSE). N-2.3 Nuclear Safety LeelsIntion and Reenlation i The Development of Nuclear Legislation in the UK Regulation of nuclear energy is prescribed through Act of Parliament, but there is no !
single Act in the UK which covers all aspects of control. Subsequent to the stan of the l civil nuclear power programme and to some extent in response to the Windscale fire of ;
l 1957, legislation was enacted to give powers for the regulation of nuclear safety i l (Figure 1).
l O The Secretary of State for Trade and Industry has the general responsibility to parliament for the formulation of energy policy in England and Wales, whereas the WPLAT96006. DOC
responsibilities of the Secretary of State for the Environment include those for general and nuclear safety from operating facilities, and safety of the general public from O discharge and disposal of radioactive waste respectively. Regulation of nuclear fuel cycle activities is undertaken in two main areas. He first, nuclear safety including e
control over design, construction, commissioning, operation and maintenance of plant and facilities is regulated by the Health and Safety at Work Act 1974 and its relevant
[ statutory provisions. He second area, control over accumulation, discharge and j
4 disposal of radioactive waste,is regulated by the Radioactive Substances Act 1960. In
" . the first area controlis exercised by the NuclearInstallation Inspectorate (part of HSE) while %in the second area control is exercised principally by the Environment Agency.
i '
R' egulation and Control of Nuclear Safety J
l The main legislation goveming the safety of nuclear installations is the Health and
- -l Safety at Work Act 1974 and the relevant statutory provisions of the Nuclear j
! Installa: ions Act 1965. Under these Acts no site may be used for commercial nuclear j !
installations unless a Nuclear Site Licence has been granted to a corporate body by the HSE (Figure 2). HSE is the body empowered to take independent action on j enforcement of safety legislation in the UK although it takes general policy instructions from the Health and Safety Commission (HSC). Her Majesty's Nuclear Installations Inspectorate (NII) is that part of the HSE responsible for administering and enforcing .
l the licensing function set out in the Nuclear Installations Act 1965 and for ensuring that j
- any installation is operated safely both for the workforce and the general public. '
4 The Site Licence is the legal document used by the NII to regulate nuclear safety. In i
addition, NII uses the specific requirements ofIonising Radiations Regulations 1985 to i control exposures to ionising radiations (The IRRs 1985 enact in UK I.egislation the j European Council Directives of 90/836 and 84/467 Euratom).
i
! De Site Licence (Ref 1) is a relatively small document and has the same general l content for all UK installation; both power reactors and fuel cycle facilities. Typically for fuel cycle facilities, the Site Licence covers the whole site and is not specific to individual facilities.
4
!' Conditions attached to Site Licences specify requirements of HSE (NII) for the Licensee (BNFL) to make and implement ' adequate arrangements' relating to design, i
construction and installation of plants or processes. Similar conditionq relate to commissioning, plant operations, maintenance, decommissioning and quality assurance arrangements. De Licence allows NII to intervene if arrangements are inadequa:e or i require their approval of arrangement if considered appropriate. It is under these !
- conditions and the Licensee's arrangements that NII exercise a number of powers controlling the activities oflicensees through legal devices such as Consents.
l Approvals,Ikections, Specifications or Agmements. .
t !
< In regulating the activities of the licensees, the NII employs two main techniques.
[
Firstly, by direct inspection of plant and working methods on site and if necessary i manufacturers' works. Inspections are carried out in the main by designated inspectors j P to a planned programme. His planned programme is supplemented by inspection using !
1 multi-disciplined teams ofinspectors to focus in depth on significant aspects of a plant l WP2:A'!96006. DOC
~
or its associated activities. He second activity is assessment oflicensee the proposal to build a new MOX plant). Essentially, before a licensee carries out a O activity which has new nuclear safety implications for the first time or wis existing arrangements, proposals must first be submitted to the NII. The NII will assess these licensee proposals using as a guide its Safety Assessment Princ (Ref 2). Assessment involves the examination of safety case documentation by disciplined team of NIIInspectors. Each Inspector, working within his own disc examines the relevant parts of the safety case. The SAPS, which have been r updated, are published and provide guidance to assessors. They are not prescr the sense that they represent a plant or product specification, rather they set th goals fo( civil nuclear installations. They reflect HSC policies, regulatory requirem and best engineering practice aimed at achieving a tolerable level of risk that is As IAw As' Reasonably Practicable (ALARP) (a UK legal term that is in practice equiva ALARA) based on the pdnciple of defence in depth.
He current version of the SAPS (Ref 2) are much more wide ranging than previous versions and take account of the conclusions of recent nuclear Public Inquiries. The SAPS contain a total of 333 individual pdnciples which address:
Basic safety standards and criteria to be applied to individual plants.
Safety assessment methodologies (deterministic and probabilistic).
Design and Engineering covering all relevant engineering disciplines:
Quality Assurance and general management arrangements.
- Siting of new fr,cilities.
Fm' ally, outside the day-to-day regulatory activities, there is the Advisory Committee on the Safety of Nuclear Installations (ACSNI) whose main objective is to provide the Health and Safety Commission and Ministers with independent and technically competent advice on major policy issues affecting safety of nuclear plants.
Accumulation and Disposal of Radioactive Waste and Effluents The Radioactive Substances Act 1993 regulates the keeping and use of radioactive material and makes provisions as to the accumulation and disposal of radioactive waste.
De Act prohibits the accumulation and disposal of waste except in accordance with i Certificates of Authorisations granted by the Environment Agency (Figuri 3). Separate Authorisations are held by BNFL, for example, for the discharges of liquid and aerial {
effluents from the Sellafield Site and the disposal of solid low level wastes at Drigg. I These Authorisations set down specified limits for waste disposal from (or in the case of a solid waste disposal facility to) the Site.
ne UK Govemment document Cmnd 6820 widened the responsibilities of the Department of the Environment for the overall development of radioactive waste management policy over and above the registration and authorisation requirement of ;
the 1960 Act.
Although specific Authorisations are not required prior to active commissioning of any .
new facility there is consultation between the Environment Agency and the NII in order to ensure that full account is taken both of the implications of waste management for WP2:A196006. DOC
l site safety and of the waste management implications of proposals submitted to NII by operators oflicensed nuclear sites. NII has undertaken that it will not give agreement O under site licences for any proposals which are contrary to the national waste management strategy.
- 3. LICENSING OF A NEW SELLAFIELD MOX PLANT-3.1 Formal Safety Arrangements and Licensing Submissions From the previous description of UK legislation it may be seen that the regulatory l requirdments for a new facility arise mainly from the Nuclear Site Licence and the donditions attached to it. It should, however, also be noted that NII will not agree to any new facility being constructed unless the Environment Agency are happy with any l associated waste management activities. Authorisations are also required prior to j active commissioning to allow for the discharge of any radioactive effluents generated j by the process. I The main feature of the UK System is that it is not in general prescriptive but it '!
identified those areas that may affect the safety of the workforce and the general public l and requires the licensee (eg, BNFL) to develop arrangements in these areas to j adequately address safety. Dat is to say the system defines the safety goals but does not prescribe how to achieve them. It allows the licensees to develop arrangements - i that are appropriate to the nature of their business and the nature of the risk this entails.
The arrangements described here are therefore specific to BNFL and its fuel cycle business, but are generally compatible with those employed by other nuclear licensees O - ux-ne development of an overall Company Safety Management System within BNFL is l the responsibility of BNFL's Safety, Health and Environment Directorate (SHE). SHE l is independent of BNFL's operating Divisions. De Company Safety Management System takes due account of the NII's SAPS and includes definition of the overall {
l organisation and responsibilities for safety within BNFL and the numerical safety j standards, criteria and principles against which new facilities will be developed. ;
Dese standards and criteria address both normal operating and potential fault conditions and define:- -
Engineering best practices (these then form the basis of the detailed Company i Engineering Standards).
Normal operational dose targets to the workforce and the general public (arising from effluent discharges).
A range of dose vs frequency bands that addren potential fault conditions j' (probabilistic criteria).
Detemtinistic and probabilistic criteria for external hazards (eg, seismic, aircraft
=
crash etc.).
WP2:AT96006. DOC
__7._.__.._-._.._..
-i .
- The underlying principles are derived from the NII SAPS and take due account of
. HSE's advice in the document Tolerability of Risk from Nuclear Power Nants (Ref 3) l (O
~
_)
and ICRP's recommendations in Publication 60 (Ref 4). Hey equate to tolerable levels4for the risk of death froin accident for the Sellafield site as a whole of 10* y and
- 10 y for the most affected members of the general public and the workforce, L respectively. Obviously as off site risks may be additive the tolerable risk from
) individual facilities is a small factor of the site risk.
i The S,ite Licence Regulations a developed for the individual site (eg Sellafield). Dey
} specifically define the arrangements being implemented by the Site to address each individu,al condition attached to the Site Licence and have been approved by the NII.
} The Company Safety Management System and the Site Licensing Regulations (SLRs) i together provide the basis of BNFLs working arrangements for the Licensing of any 3.
new facility. This is shown schematically in Figure 4. Working procedures (for i example the SMP project procedures) are developed within the framework provided by these documents. With respect to any new facility that has nuclear safety implications, j' including the new Sellafield MOX Plant, the SLRs required that BNFL must obtain
- NII's ' Agreement' prior to commencing
construction j -
inacdve commissioning i -
active commissioning operation i In order to support BNFL's requests for such ' Agreements', the SLRs also require
- BNFL to perform detailed safety assessments and prepare formal safety reports at a i
number of key stages in the development of a new facility. For SMP, the SMP project
! manager is responsible for producing the formal safety reports and is helped in this task by a specialist safety assessment team who are an integral part of the SMP task force.
He principal safety reports leading to the licensing and operation of a typical new Sellafield facility are:
- 1. Preliminary Safety Report (PSR)in support of the conceptual design. The PSR is optional and is not a formal requirement of the licensing process.-It does !
however allow BNFL to obtain the NII's views of the potential licensability of l the proposed new facility before significant design costs are incurred. If a PSR is submitted NII will either ' acknowledge' the document as providing a suitable basic for further design or ' object',in which case major re-design would be required.
Internally to BNFL, the main function of the PSR is to classify the safety significance of the proposed facility, to provide a safety specification against which the design can develop and to give confidence that the project cost estimate and programme contains adequate provisions for the development, installation and licensing of safety systems.
1
, _ - .-u. --
. ,-e. .
In the case of the SMP, a PSR was not prepared due to programme constraints i which required the early preparation of a more detailed PCSR (Pre-t' N Commencement Safety repon, see below). The PCSR fully addressed all of the i
d issues that would otherwise have been covered by the PSR. A simple safety statement was however issued to NII in June 1993 which provided NII with basic information on the SMP project and the proposed safety management arrangements. This ensured that the NII assessors were up to speed on the SMP project prior to them receiving the first PCSR and ensured that their consideration of the PCSR was as efficient as possible hence minimising the
. potential for delays. '
- 2. , Pre-Commencement Safety Report (PCSR) in suppon of the commencement of construction. He PCSR provides a full safetyjustification of the proposed facility prior to the commencement of any construction work. Typically, the PCSR should be submitted to NII 6 months prior to stan of construction to allow NII to assess the case and to complete any necessary negotiations prior to their agreement to commence construction. In many cases where it is necessary l to construct a new facility to a tight programme, it is not possible to provide full safetyjustification addressing all construction and installations prior to commencing the initial civil construction work. Generally, the design is not sufficiently detailed in all areas at such an early stage. In such cases the PCSR may be phased with separate versions supponing successive construction phases.
I g3 For the Sellafield MOX Plant it was proposed (and accepted by NII) to provide
(~) two versions of the PCSR. The first PCSR was issued to NI!in August 1993 and supponed the commencement of the civil construction and demonstrated that the civil design incorporated all the necessary safety provisions (eg, shielding, seismic performance etc.) without unduly constraining the subsequent safety performance of mechanical, electrical and control systems. Agreement to stan construction was obtained from NIIin March 1994. The second PCSR was issued to NII in June 1994, and provided the design safety justification to support the commencement of mechanical, electrical and instrumentation (ME&I) installation. NII agreement to commence ME&I installation was obtained in October 1994.
- 3. The Pre-Commissioning Safety repon (PCmSR) is produced to suppon the commencement ofinactive safety commissioning. The PCmSR updates the PCSR to the as-built status. It is the definitive design safetyjustification. The PCmSR also provides the basis for defining the safety systems that suppon the safety justification and require to be commissioned during inactive safety commissioning.
He full range of commissioning tests required to suppon the safety case contained within the PCmSR are defined in the Safety Commissioning Schedule (SCS). This is submitted to the NII together with the PCmSR and the commissioning manual describing quality arrangements 6 months prior to the stan of commissioning to allow NII to assess the adequacy of BNFL's proposal d
and complete any necessary inspections prior to their agreement to commence WP2.AT96006. DOC
i .
V. ~
i commissioning. The SMP PCmSR was issued to NIIin May 1996. NII agreement to commence inactive safety =mmissioning was obtained in December 19%.
h 4.
Plant Safety Case (PSC)in support of active commissioning and the initial I operation of the plant. The PSC updates the PCmSR to take account of any i
modifications arising during inactive commissioning. The PSC also defines the
! formal operating arrangements including definition of ' Safety Mechanisms',
, Operating Rules and the Maintenance Schedules required by the SLRs to
', b to N11 to support the programmed date for first fuel production in 1998.
he PSC is typically updated after the first years operation and every five years thereafter to reflect operating experience and changes to plant, equipment and operating procedures.
The overall licensing requirements and their relationship to the main project phases are shown in Figure 5 and the SMP key dates are summarised in Table 1.
a 3.2 The Safety Assessment Process being Applied to SMP Within BNFL the safe design of facilities is achieved via two complimentary routes:
1.
Deterministic safety by the design of the plant against a comprehensive range of q international, national and Company Standards as defined by the Company Q Safety Management System. Central to this system are a number of Company engineering standards which take due account of NII's requirements as defined in their SAPS and define the requirements for safety systems on the basis of the level of potential radiological consequences. Where appropriate, the detailed design proposal is subject to independent peer (engineering) review to confirm i
the relevant standards have been applied and approval is required from the peer review prior to commencing work on site.
- 2. Probabilistic Safety Assessment (PSA) applied to design proposals and operational arrangements to demonstrate that the assessed risk is acceptable by ,
comparison with Company criteria. % i PSA is the main technique applied to the review, assessment andjustif$ cation of any new facility in BNFL and provides the basis of the numerical assessments contained within each of the above safety reports. A new facility is subjected as far as is practicable to a full probabilistic assessment at each stage (ie. each safety report) of the projects life cycle. The scope of the study applied at each stage is shown in Figure 6.
At the PSR (and where prepared the Civil PCSR) stage, the PSA study concentrates on more significant hazards that may occur which would have been identified by HAZOP I 1 study and are based on bounding estimates of the potential on and off-site radiological consequences and initiating event frequencies. The assessments provide a means of l developing a safety schedule which as far as practical, defines the requirements for the principal safety systems in terms of function and where appropriate, integrity. This 1
i WP2:AT96006. DOC
\
then provides a direct link to the relevam Company Engineering Standards and the deterministic safety case.
At the PCSR stage the design is more developed but the final working drawings are no generally available. The PCSR therefore provides a detailed probabilistic safety i
justification based on statements of design intent and assumptions of operational procedures, etc. All hazards with significant radiological consequence (ie. those capable of leading to an off site consequence >5 pSv or a building emergency) identified by a detailed HAZOP 2 study are addressed. As far as practicable, full '
frequency and consequence assessments are performed and the design shown to com Nith tlie pumerical Company Safety Criteria and Standards. There may however still be a number of outstanding issues identified which require resolution prior to ope' ration. !
The PCSR also contains a fully worked up version of the safety schedule which I summarises the probabilistic and deterministic safetyjustification in a tabular form and 1
identifies all the significant engineering provisions and operating assumptions necessary to achieve the necessary level of safety. The safety schedule presents the detailed safety information in a form that can be readily understood by the plant engineer and i
future operators (and the Regulators) and is an imponant aid in ensuring the design and operating requirements are properly understood and implemented. Also by providing the basis of the safety case in a concise manner the safety schedule is an important -
component of change control.
m At the PCmSR stage the design is complete and the final working drawings available.
1 V The PSA contained within the PCSR is updated to reflect the as-built standard and any !
safety significant changes justified. Where appropriate, the hazard assessments are more detailed and take account of any additional hazard identification exercises, eg.
' task analysis of provisional operating procedures. At this stage provisional ' Safety Mechanisms', ' Operating Rules' and ' Maintenance Requirements' are identified. i The PCmSR identifies all safety related equipment and its function (ie. the safety schedule) and provides the basis for defining the safety tests that must be performed i during commissioning to demonstrate the safety performance of the plant prior to
- commencing active operation. Tnese safety tests, including cross-reference to PCmSR, are contained within the Safety Commissioning Schedule (SCS). s-
~
The PSC updates the PCmSR to take account of commissioning and ddfines the formal operating arrangements including definition of.' Safety Mechanisms', ' Operating Rules' and ' Maintenance Schedules' as required by the SLRs. The PSC is updated periodically (typically after 1 years operation and each subsequent 5 years) to reflect operating experience and changes to plant, equipment or operating procedures. !
3.3 Influence of the Safety Assessment Process on SMP Implementation of the safety assessment process as defined in the previous section of this paper has enabled safety considerations to be an integral component of the design
~
process from a very early stage of project. This has enabled a number of potential hazards to be removed or minimised and has reduced the requirements for additional WP2:AT96006. DOC
i safety protection systems which would have added to both complexity of design and operating cost of the plant. This is best illustrated by considering how the potential p hazards of routine operational dose uptake, criticality and loss of containment have V influenced the design of SMP.
i 1
Ooerational Dose Unene :
An iterative strategy has been applied in order to develop a plant design which would ,
result in an acceptable level of dose uptake. His strategy is illustrated schematically in i Figure 7. Implementation of this strategy revealed at a very early stage of the project :
desigri that the use of existing MOX plant technology, which involved a high degree of '
tnanual operations particularly in fuel assembly operations, was unacceptable in terms !
of dose uptake for a production plant with the throughput capability and flexibility of l
SMP. Derefore the design of SMP has been developed largely around the concept of t remote operation with appropriate local or bulk shielding provided around the process ,
stages with relatively high dose rates. His is best illustrated in the fuel assembly areas of SMP where the whole fuel assembly line operations are remotely operated and are enclosed in a concrete shielded room of appropriate thickness.
One of the major components of the operational dose uptake assessment process has !
been the development of a detailed plant operational model broken down to an individual task level. Preparation of this model was commenced very early in the !
project design and drew on the extensive experience gained by BNFL over many years ;
of designing, operating and decommissioning plutonium plants, and more recent experience of operating MOX fuel fabrication plants. His experience provided O valuable data on both the manpower requirements and task durations for both process and maintenance operations, and on the main potential short and long term sources of 4
operational exposure and how these exposures could be adequately controlled.
The SMP dose uptake assessments are therefore based on very robust base data and a detailed estimate of the dose uptake for SMP indicates that the annual average dose i uptake for the SMP workforce including maintenance operations will be less than
)
5 mSv y at full capacity and using high burn-up long aged Pu. l Criticaliev 4 Criticality was recognised as one of the main potential hazards associa.ted with SMP from the beginning of the project design. As a result considerable effort has been concentrated on the development of a plant design which has an acceptable criticality safety case, but which is not constrained in terms of its flexibility to process a wide variety of feed material and manufacture a wide range of fuel assemblies. In order to satisfy this requirement the criticality assessments of the SMP design have been based on the most criticality reactive civil feed materials 'and fuel assemblies which effectively bound all other potential feeds and products. Given this design basis the principal objective of the design was to make plant inherently safe where practicable for normal operations aad potential fault conditions. Only where this objective is not practicable are additional safety protection systems provided. His obviously enhances the i
robustness of the safety of the plant and reduces the requirement for potentially complex safety protation systems which add to both plant design and operational WP2:AT96006. DOC
j -
i (eg, maintenance) costs. An example of where this objective has influenced equipment design include the MOX powder blender in the main powdr processing area which has ;
] been designed as a thin ' slab' type blender (ie. safe shape) compared with conical '
! blenders utilised on other similar plants. 'Ihe short binderless route process j
considerably supports the objective of achieving inherent safety in that the reduced
(
4 powder process times enable the required throughput to be achieved with smaller I
}
4 vessels which are more favourable from a criticality safety perspective. l i
i- i One of the major constraints in developing a criticality safety case for SMP has been the limited reliability data which is accepted by UK Regulators for software based
- controf systems. As described above, SMP is a remotely operated plant relying i
ektensively on such a system for control of the process. It has been identified in the
- extensive hazard identification exercises (eg, HAZOP studies) carried out on the SMP
! design, that failure of multiple functions within the control system could give rise to j potential criticality incidents in certain process vessels which are not practicable to i
remove by equipment design (ie. the vessels would become too small to maintain
- required throughput). Therefore, although the design of SMP has minimised the l requirement, a small number of safety protection systems have been incorporated into
- - the SMP design to prevent potential criticality incidents initiated by multiple failure of a
functions in the control system. These safety protection systems are diverse, and are
! engineered to be fully independent of the control system to avoid potential common ,
i mode failures. The potential for criticality incidents in the SMP plant has been
! calculated as less than 10'8 y. This represents a considerable design achievement given the limited reliability data which is accepted by the UK Regulators for software based control systems.
O Loss of Containment i
Most of the SMP processing operations up to the loading of filled fuel rods into fuel magazines and assemblies are carried out in glovebox containment. A number of {
design features have been incorporated into the design to prevent potential loss of l containment hazards. These include: i prevention of potential impact damage to gloveboxes due to mechanical failure I ofin-box components. This includes the use of protective sheaths around drive !
shafts, physically restricting the movements of equipment, positioning glovebox i windows in appropriate locations, away from potential impact areas; l prevent glovebox pressurisation by fitting process gas supplies with flow restrictors and additional isolation valves which automatically trip if glovebox depression is lost (eg, upon a failure of the glovebox extract system);
utilising vortex amplifiers to provide emergency breach protection should glovebox containment be breached (eg, glove accidentally removed).
Active material handled outside gloveboxes is contained in containment barriers of appropriate integrity (eg, PuO cans, fuel cans). The handling systems for these O materials takes due account of the integrity of the containment barriers, by limiting the forces applied to the contr.inment and minimising potential drop heights.
WP2:AT96006. DOC
-. l i
l
- 4. CONCLUSIONS A MOX fabrication facility at Sellafield is being licensed like any other commercial '
nuclear plant in the UK under the conditions of a Nuclear Site Licence. There are no special requirements for a MOX plant. The construction, commissioning and opera of the facility will be in line with ' arrangements' developed and implemented by the l
' Licensee' as required by the Nuclear Site Licence issued by NII. Discharge Authorisations are also required to allow discharge of aerial and liquid effluents prior to active commissioning. All the necessary arrangements have been developed and are in place and accepted by NII under the existing Sellafield Nuclear Site Licence to suppo the construction and operation of the existing small scale MOX Demonstration Facility ,
(MDF) and the . full scale Sellafield MOX Plant (SMP).' !
+
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WP2:A11NIO06. DOC
l TABLEI l
2 CURRENTSTATUS OFSMP SAFETY DOCUMENTATION l
JUNF. -
SAFETY STATEMENTISSUED TO THE
{ REGULATORS 1 .
AUGUST 1993 -
PCSR (CIVIL) ISSUED TO REGULATORS I MARCEI,994 -
REGULATORY AGREEMENT TO COMhENCE CIVIL CONSTRUCTION j JUNE 1994 -
PCSR (ME&I) ISSUED TO REGULATORS 4
- OCTOBER 1994 -
REGULATORY AGREEMENTTO COMMENCE
- ME&IINSTALLATION
- MAY 1996 -
PCmSR ISSUED TO REGULATORS DEC 1996 -
REGULATORY AGREEMENTTO COMMENCE INACTIVE SAFETY COMMISSIONING iO i
6 i l l I
. 1 i .
\9 1
4 s
d
.a 1
1 l
- O l
1
a l f
4, -
< I l References i l
! ~
! 1.
i Nuclear Site Licence No.31F Sellafield Site 1994, HSE. '
1 i
i i 2.
i Nuclear Installations Inspectorate. Safety Assessment Principles for Nuclear Plants, 'I 1992.
1
- 3. HSE Tolerability of Risk from Nuclear Power Plant.
I .
i
{ 4. ICRP Publication 60.
j ' .
e
% t j
i h \
's .
i 1
1
(
'I E ANE .
~
O O O .
Figure 1: UK Control Framework i
International (UN, IAEA, ICRP, EU) .l.
UK l UK Government Departments / Ministry l Department of Trade and l Department of l Industry l Environment
- l j General Energy Policy IISE/NII ENVIRONMENT AGENCIES i
e ,- -
General & Nuclear Radioactive Waste Discharges Ku IISE Health & Safety Executive Safety Radioactive Waste Strategy NII Her Majesty's Nuclear Installations Inspectorate i DTI Department of Trade and Industry
- OBNFL --
O O O ~!
Fieure 2: General and Nuclear Safety Regulation (Principal Regulator NII) ,
Health & Safety at Work Act 1974 Nuclear Installation Act IRRs 1965 1985 Site Licence Radiological Protection Requirements Environment Specific Agency (Waste Mgt consktauon on Licence waste Issues) M*""gment Conditions
O O 0 .
Figure 3: Radioactive Wastes and Discharees Regulation Discharees Waste Management Strategy (Principal Authorising Body: Environment Agency Responsible Department DOE Radioactive Substances Act Command 6820 Environment Act l Discharge Authorisation
. . National Waste Management Strategy Guidance Notes l
Spec.fic i Limits on Discharge Review of NII BNFL's Waste coasuttati= ?a .
Safety implicahons Nuclear Safet r Management ,, , Regulations (Issue i Proposals uaaasemeat of Consents etc)
Etr doe Department of Environment NII Iler Majesty's Nuclear Installations Inspectorate OBNFL
o O O ~!
Ficure 4:The Overall Development of Working Arrangements for a New Facility '
HSE ./ -
Safety Policy ,- e NII Nuclear Site Safety Assessment Licence Principles BNFL BNFL Company Safety Operating Site Management System SLR's BNFL Project : :
NII Review / Approval Specific Procedures etc ,
ORNR
o o o Figure 5: Evolution of a Plant Safety Case Design '
Construction / Installation Commission .
Operation PSR PCSR PCmsR PSC Safety Case \/ 9 ,
\/ \/ update Update Update .:._
Kev PSR Preliminary Safety Case PCSR Pre-Commencement Safety Report (possibly staged) ,
PCmSR Pre-Commissioning Safety Report PSC Plant Safety Case (Pre-Operation)
QhID
Figure 6: Typical Flow Diagram I for Safety Review Assessment and Justification i
o~ Design Safety Previous Design Design
- Principles Stage Change 1 ,
1 ,, I i :
l Current Design :
Stage Proposal Previousjafety l Reports Recommendation l
4 Safety Advice ,, Advice Modification
' g Design Review m a 1
Hazop etc l
NII Requirements Engineering Validation i I
! Data Bases I Methods etc ; Hazard I
- Assessment l
l
! Safety Standards and
--* Cdteda l : Comparison with Critena i
g
!O i
i 1 1 1 {
} Current Design l Safety Spec for Outstanding l Safety Viable l
l Future Eng Phases Issues l
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Safety Justification l
E -
a Project Checking and Approval l
l 1
- BNFL Peer Review MSC Consideration i
Issue to NII l
1 Discussion O l 1
En MSC Management Safety ^ E ***"
Committee HAZOP Hazard and Operability D
Study D
o o o :
Figure 7: Iterative Strategy Plant Design Source Positio s'
~~
Occupancy Number of Staff .
Source Assumptions Shielding Dose Rate and Dose Calculations l Review Dose Meets NO Targets t
YES NO Confirm
-- ALARP YES Stop OBNFL
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0 v 0 j 1 STATE 3 REGIONS 3 COMMUNITIES i Flemish Flemish Waloon French Brusse. German i I
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Electrabel Distrigas Tractebel Coditel Group Compagnie Tractebel and Fabncom immobili&re Engineering Electrabel de Belgique
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o o Highlights on BELGONUCLEAIRE 9]ig .
I-1 i e MOX fuel fabrication i e Nuclear engineering !
l i
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l li
Licensing rules for an industrial plant {
Federal Rules '
l' e RGPT Rbglement G6ndralpourla Protection du Travail i ARAB Algemeen Reglement voor Arbeid Bescherming General regulation for work protection e General regulation concerning :
a electricity hazards a fire protection a thermalinsulation '
a noise abatement
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Regional Rules t e VLAREM Vlaams Reglement betreffende de Milieu Bescherming ,r t
Flemish regulation concerning the environment protection
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o o O Licensing process of a MOX facility
- e. License application by owner
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Cumulated MOX tonnage 308 tHM '
Fuel rod types (PWR) 14 x 14,15 x 15,16 x 16,17 x 17 Fuel rod types (BWR) 8x8,9x9 Qualified MOX fuel designs FRAGEMA, SIEMENS, BN, TOSHIBA, HITACHI Size of a fabrication campaign 4 to 29 tHM Number of Pu contents per campaign 3 to 6 Pu tot. content in the pellet (over Pu tot. + U) up to 8 % :!
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- Building footprint 8200 m2 (2 acres) !
Plant flexibility Plutonium and uranium from several origins, several fuel suppliers (P and BWR), several ,
licensing bodies Requested personnel 250 i
Total investment cost 225 million USD Fuel assembly production cost (per year) 50 million USD Construction schedule 4 years i i
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!O XMC WSMK3SEESP #N FAMMICATION 1
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i l Meckville. Marylmed. Marcia 26, geny I
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- BELG0NUCLEAIRE 1
i M0X FABRICATION PLANT l
i LICENSING EXPERIENCE l
l Michel Debauche l Mox Plant Engineering Manager i
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TABLE OF CONTENTS
!NTRODUCTION 3
- 1. THE BELGIAN SITUATION. 4 l.l. BELGIUSI in the SIOX world. 4 1.2. The structure of the State. 4
- 2. BELGONUCLEAIRE, AT THE HEART OF THE BELGIAN INDUSTRY. 5 2.1. The TRACTEBEL Group. 5 2.2. The know-how of BELGONUCLEAIRE. 5
- 3. THE BELGIAN MOX PLANT LICENSING RULES. 7 3.1. Applicable avles. 7 3.2. Licensing process. 9 3.3. Licensing and control bodies. 10
- 4. THE BELGIAN EXPERIENCE IN LICENSING MOX PLANTS. 12 4.1. The PO facility. 12 4.2. The P1 facility. 13
- 5. CONCLUSIONS. 19 O
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- INTRODUCTION )
i Ladies and gentlemen, it is a great pleasure for me to be here today. I am honored to have the opportunity l to speak before such a large and knowledgeable audience. '
I am honored having been invited to an NEl workshop attended by NRC representatives. The NRC is indeed considered in Europe since the beginning of the nuclear age as the world leading organization in the nuclear licensing. Today the licensing processes in Belgium and many other countries make great use of the valuable amount of rules and guidance prepared by this organization.
I am honored and in the mean time stressed to use, in front of you , a language for i which I have a so poor knowledge and this, especially, after having heard the fluent I and very British English of my colleague of BNFL. i
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- 1. THE BELGIAN SITUATION.
1 1.1. BELGIUM in the MOX world.
Before speaking about licensing, I would hke to briefly desenbe the situation in Belgium and the authority structure of my country. Belgium is a country located in ;
Western Europe; it is located at he gravity center of France, United Kingdom and :
Germany, three other European countries which have been invited to speak today
)
with us. Our situation is thus unique in the world of the MOX producers. It is not ;
- only an image. You will see later how our position is important in this matter. l I
Three spots to illustrate this . !
i
. first MOX pilot plant in Belgium in 1960, e first MOX rods loaded in the world : MOX rods fabricated by BELGONUCLEAIRE
, and loaded in a Belgian reactor in 1963, 1
. first MOX industrial plant commissioned in 1972.
( We are a small country but we have a large MOX history and competence. l 1.2. The structure of the State. !
Belgium is a federal state but it is not fully comparable to the USA. Indeed, beside the federal government, we have two other governments . region government and community government. Belgium is divided into three regions and three communities; the competences of the regions are mainly in the following fields economy, terntory planning, resources and environment , the competences of the communities being in the field of culture, language and education.
The licensing of the nuclear facilities is a federal matter; any involvement of the l regional authonties proceeds through the federal administration.
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- 2. BELGONUCLEAIRE, AT THE HEART OF THE BELGIAN
- INDUSTRY.
a 2.1. The TRACTEBEL Group.
BELGONUCLEAIRE was created in 1957 by Union Minisre - a Belgian mining i
company - to develop plutonium fuels and has been since its creation a pioneer in this field.
Today, BELGONUCLEAIRE is part of the TRACTEBEL group which shares the equity of the Company with the Belgian State.
4 TRACTEBEL which has an international strategy is the largest Belgian industrial group. Within its various specialities, the TRACTEBEL Group is active in about one hundred countries. The presence of TRACTEBEL in the US is important, especially j
in the field of electricity production. Through its subsidiaries ATC and CRSS, j TRACTEBEL is now the owner of 11 power plants in the United States.
The TRACTEBEL group's key advantages are its human potential and its technical know-how. It has a staff of roughly 37,000.
ELECTRABEL which is one of the business units of TRACTEBEL is the private i
Belgian electncal utility company and the major producer of electricity in Belgium. It !
operates 7 nuclear plants with a total capacity of 5500 MWe representing SA % of the electricity in Belgium. TRACTEBEL ENGINEERING, another business unit, is the AE of all the nuclear power plants in Belgium and responsible for their licensing.
2.2. The know-how of BELGONUCLEAIRE.
Our two main activities are MOX fuel production and nuclear engineering. In this last activity, we are specialized in MOX fuel design, MOX plant construction and radwaste conditioning. We operate a 35 t./ year MOX plant in Dessel, in the Northeast of Belgium. As engineers, we have designed and built this plant named PO and also used our know-how to design a new MOX plant (the P1 plant) and to assist COGEMA to build the MELOX facility in Pance. I will later give more information about the P0 and P1 plants.
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We have been sc: 1',e in the field of plutonium for 40 years and we have gained a unique expenence in the transportation of plutonium bearing material through our daughter company TRANSNUBEL.
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- 3. THE BELGIAN MOX PLANT LICENSING RULES.
As in the United States, the federal authorities in Belgium have primary jurisdiction over the safety of nuclear plants. Regional authonties intervene in the regulatory matters only with respect to the industrial environmental permitting. This occurs through the federal authonties.
A MOX plant is considered in Belgium as part of the fuel cycle facilities. The same sets of rules are valid for nuclear power plants and for fuel cycle facilities. The differences between them are taken into account in some details of the applied rules and procedures.
On the other hand nuclear plants also have conventional aspects and are in this regard submitted to rules applicable to any industrial plant.
Although we also have a large expenence in licensing MOX fuel in reactors, i e focus my remarks today on the rules specific to nuclear facilities and on our licensing n experience with MOX plants.
U 3.1. Applicable rules.
3.1.1. Rules applicable to nuclear facilities.
General rules The rules applicable to nuclear facilities are based on the fundamental Act of March 29, 1958. The rules of February 28, 1963 and regularly amended since their issuance establish the pnnciples of the protection of workers and of the public.
They are known as the R.G.P.R.I. R6glement g6n6ral pour la protection de la population et des travailleurs contre le danger des radiations ionisantes (General regulation for the public and worker protection against hazards of ionizing radiation).
The main concerns of the R.G.P.R.I. are :
e to define different classes of nuclear facilities. The facilities are classified into three different classes according to the quantity, the physical form and the
^) radiotoxicity of the processed nuclear material. A MOX facility pertains to the (d
same class as nuclear power pie,ts ( class 1),
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e to establish Ine procedures to be followed in licensing and controlling the construction and the operation of a nuclear facility. These procedures may differ according to the class of the facility.
. to establish the basic rules to be followed for worker and public health physics protection, Specific rules The licensing of a nuclear facility is based on a specific licensing document. This document, which is issued as a Royal Decree by the Ministry of Interior Affairs, is specific to the plant to be built and operated and is issued after formal licensing application by the owner of the plant.
The R.G.P.R.I. defines the safety rules to be complied with in the plant design and operation as well as the justification documents to be prepared in the frame of the license application and submitted for review and approval by the safety authorities.
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3.1.2. Rules applicable to industrial plants.
The most important rules which are applicable in the licensing of an industrial plant are :
e the R.P.G.T. : R6glement g6ndralpour la protection du travail (General regulation for the protection of workers). These rules aim at the safety of workers, e
other general regulations concerning for instance, electricity hazards, fire protection, noise abatement, thermal insulation,.
e the Belgian norms and standards.
The above rules are valid everywhere in Belgium (federal rules).
The main regional rules applicable to an industrial plant are the rules related to environmental protection. In the North region of BELGIUM where the MOX plant is located, it is the VLAREM Vlaams reglement betreffende de milieuberscherming (Flemish regulation concerning the environment protection). The environment effect of a nuclear facility is addressed in the frame of federal procedures. As far as the conventional part of the nuclear facility is concerned, the design has to be in accordance with the VLAREM.
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(G 3.2. Licensing process.
3.2Ji. Licensing process of nuclear Class 1 facilities.
The nuclear licensing process culminates in the issuance of an " operation license
- The nuclear licensing of a MOX facility involves a long and complex process performed by the federal authorities. It is initiated by a license application submitted to the Governor of the province where the plant is intended to be built. The administration offices initiate an inquiry by the municipality (or municipalities which are closer than 500 m from the plant) concerned by the plant and by the federal administration.
After receiving the results of the inquiries from the municipalities and from the provincial administration, the Governor hands over the licensing application to a federal "Special Commission". This commission is the major body technically acting in the licensing process. Its competence and methodology are described later on; (q
g let us now say that the Special Commission evaluates the license application by iterative processing with the applicant, accepts it and, possibly, raises further requirements if it thinks they are necessary to license the plant and fulfill the rules of the R.G P R.l. Finally the commission agrees with the license application possibly amended.
The Special Commission issues then a preliminary report which is transmitted to the applicant. This report includes the results of the evaluation as well as possible supplementary requirements.
According to Article 37 of the Treaty of Rome, the formal advice of the European Commission (EC) is required concerning the evaluation of release effects to soil, water and airspace of neighboring states. This advice is asked based on a special file established according to the EC rules. This file is different from the license application, but similar in all its major aspects. The EC evaluates the file and transmits its advice to the Special Commission through the Belgian State.
Possible comments of the EC are worked out by the Special Commission and a second iterative process is initiated aiming at preparation of the final report of the Special Commission, including the recommendations of the competent Ministry.
This step is the last technical step of the licensing process. The formal license is then granted by a Royal Decree which includes the conoitions and the requirements p of the final report of the Special Commission. This Decree is issued by the Ministry V of Interior Affairs and enables the applicant to initiate the site works.
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After construc::cn cut before commissioning, as it is the case for industrial plants, a 1 formal certification is performed to establish that the plant execution complies with the licensing Royal Decree requirements. Such certification is needed each time the plant undergoes major modifications.
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3.2.2. Licensing process of industrial plants.
I Before the beginning of any site works, a building license is requested. This license 1 makes part of a separate procedure j
After construction but before commissioning, control certificates of execution t
according to the general rules have to be issued by specialized control bodies.
l 3.3. Licensing and control bodies.
The main licensing and control bodies involved in the process are the federal administration, the Special Commission, the Authorized inspection Agency and the I- Physical Control Service of the applicant. Other local bodies are involved but their
- intervention is mainly administrative or devoted to the conventional aspect of the j licensing.
3.3.1. Federal administration.
The Ministry of Interior Affairs responsible for the licensing process has two different administration offices.
The S.S.T.I N.
Service de saret4 technique des installations nucl6aires (Service for safety of nuclear 1 facilities) which is in charge of all aspects related to the plant safety "on site" : this includes the protection of the personal against nuclear and non nuclear hazards '
(RGPRI and RGPT) ; this includes also the "on site" impact of the safety issues.
The S.P.R.I.
Service de protection contre les radiations ionisantes (Service for protection against the hazards of ionizing radiation) which is in charge of all aspects related to the plant safety "off site" this includes the protection of the public and of the environment D against nuclear hazards (RGPRI) , this includes also the "off site" radioactivity releases and emergency planning.
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3 3.2. Special Commission.
As indicated above, the Special Commission is the major body acting in the licensing process. This commission includes key persons of the competent federal administration, representatives of the regions and independent scientific experts.
The Special Commission performs the job of evaluating the license application, analyzing the safety reports, performing inquiries concerning the safety of the plant in normal and accidental conditions and comparing the concerned file with other >
similar or nearly similar files.
I its work involves an iterative analysis process to take into account the fact that,some questions they may raise during file processing have possibly an existing answer in l the applicant's calculations or evaluations but are not expressed in the application file.
The Special Commission issues only reports and recommendations. The latter l comes into force after signature of the Royal Decree by the competent Minister and l by the King. .
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3.3.3. Authorized Inspection Agency. l 1
This agency, acting by de.'egation of the Ministry of Interior Affairs controls the safety i analyses and evaluations of the application file, issues compliance certificates '
before plant commissioning and permanently inspects the plant during startmp and ,
operation.
3 3.4. Physical Cor, trol Service.
Each licensee must nave in its organization, such service entirely dedicated to the permanent survey of the plant nuclear safety. The Physical Control Service is supervised by the Authorized inspection Agency.
This service is lead by an authorized expert, recognized by the Special Commission and has authority over nuclear plant safety. This service performs the safety analyses and evaluations, prepares the nuclear and non nuclear authorization applications conform to the Royal Decree and submits them to the control of the Authority inspection Ager .y.
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- 4. THE BELGIAN EXPERIENCE IN LICENSING MOX PLANTS.
Two MOX fabrication facilities were licensed in Belgium : the first one (PO) in 1970, the second one (P1) in 1991.
4.1. The P0 facility.
We have been fabricating MOX fuel at our "P0" plant in Dessel, Belgium since 1973, including fuel for pressurized and boiling reactors as well as fast breeder reactors.
In the mid-1980s we upgraded our production capacity and developed the MIMAS process in order to meet the growing commercial demand from European utilities for MOX fuel. Using MIMAS, we have produced today more than 315 metric tons of fuel
- over 170,000 fuel rods - out of a world total production of about 600 metric tons.
The Dessel plant has supplied MOX fuel to 16 nuclear power plants in Belgium, France, Germany and Switzerland, and we are beginning making MOX fuel for electric utilities in Japan.
The MOX pellets obtained by our MIMAS process are composed of a solid solution of UO2 and Pu02 homogeneously dispersed in a UO2 matrix. This result is achieved through two blending steps the primary (or master) blend obtained by ballmilling and the secondary (or final) blend, to reach the specified plutonium content in the pellets.
The MIMAS process presents several advantages compared to other existing fabrication processes. These advantages are :
the primary blend obtained by dilution of Pu02 to about 30 % is prepared in advance of the pellet fabrication. The same pnmary blend can be used to produce pellets of various Pu enrichments, e the two-step blending process allows high flexibility for Pu isotopic homogenization, e the use of especially designed equipment leading to very low powder retention,
. the economical viability has been demonstrated by full capacity production,
. the technology has achieved a very mature industrial level.
These advantages led COGEMA to adopt the same pro' cess for the MELOX plant and, since 1996, also for CFCa (Cadarache plarit). The MIMAS process will thus stay for many years as the world leader for MOX production out of the 1400 tHM 12
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O i MOX fuel excected to be produced by end of the year 2000,1100 tHM will be MIMAS fuel '
The P0 is a medium size plant, comprising two main fabrication lines laid down in parallel.' It is characterized by high flexibility in terms of fuel design (PWR or BWR), l specifications (qualified for several designers BN, SIEMENS, FRAMATOME and '
TOSHIBA / HITACHI / JNF) or Pu02 characteristics (Pu content, isotopic !
composition). The range of parameters already demonstrated is indicated here as I well as the cumulated MOX production in Europe and the place of BELGONUCLEAIRE in this production. l The licensing of P0 occurred end of the sixties. The Royal Decree has been l awarded in 1970. Since that time, the operation of the plant occurred under constant scrutiny of the Authorities and of the Authorized Inspection Agency. ;
Two important refurbishment programs were performed e
one in 1984 prior to the start of the industrial MOX production aiming at capacity l increase and at implementation of the MIMAS fabrication process, e
a second one from 1995 and planned until 1998 aiming at the radioprotection of the production equipment. Mechanization of equipment parts is also included in j this program. As a result of this effort, the maximum individual doses to the l
workers are already reduced below 20 mSv/y. I 4.2. The P1 facility.
4.2.1 Plant description The P1 project was developed to answer the increasing demand for MOX fuel fabrication capacity in Europe and was licensed in Apnl 1991. The license was sued one year later before the Supreme Court. Thus, the construction of the plant did not begin. In parallel, other MOX fabrication capacities were constructed or designed in Europe and the expected MOX capacities by 2000 will now meet the demand.
However, new plants devoted in US and in Russia to MOX fabrication from weapons ;
grade plutonium, should be built in response to decisions in both countries to follow
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the MOX option. Today, P1 is being redesigned to respond to particular needs of 1 the weapons Pu transformation into MOX.
The main features of this plant before this ongoing redesign are given now.
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V As representec ere. the P1 process equipment is arranged in a U shape. One wing is intended for powoer preparation, one for the pellet and rod fabncation, the last one for rod control and assembly preparation. In the center of the plant, rooms are foreseen for the ventilation systems, the waste storage and the analytical ;
laboratones. North of the building are the inlet and outlet airlocks where a truck access for material supply and shipping is provided. West of the plant, a uranium storage room is foreseen.
j As indicated, the process rooms are surrounded by corridors These corridors are located below technical galleries where the ventilation ducts and the electrical cables are installed. The ventilation system is organized to feed the air through the main corridors maintaining them at a pressure higher than that of the production rooms. The air is fed under the room ceiling and exhausted at the bottom of the other side of the room to avoid any spread of possible contamination into the corridors.
Like P0, P1 is a flexible plant. This is considered in our opinion as a key feature. It is flexible from the product, the process, the equipment, the lay-out and the safety points of view.
P1 is based on the P0 operation experience. As far as the process is concerned we (s
are using the process and the equipment technology which have been proved l successful . The only significant changes with respect to P0 are the equipment l arrangement in the plant and some technological improvements as well as some automatization.
Another extremely important advantage of a flexible plant is the ability to respond to the future evolution of safety and user requirements.
Let us develop these points.
Concerning the safety optimization of the plant, we will consider respectively the external and the internal accidents.
External accidents.
P1 is designed to withstand an earthquake and an airplane crash. We have considered a heavy (F 16) plane for the design of the sensitive parts of the plant and a light civil plane for the others. The design of the plant is based on a MSK VI earthquake related to the maximum conceivable ground motion in the region of Dessel. In any case, the strength of the building is mainly fixed by the airplane crash cnterion and it can thus sustain a stronger earthquake than MSK VI.
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In both ac0; cents tr,e function of the building is to provide a suitable static confinement. Furtnermore, the parts of the ventilation system having an important role in the dynamic confinement of the plant are designed against earthquakes and I
vibrations generated by an airplane crash. '
The situation of P1 in Dessel precludes any flooding. The risk of an external i explosion due to road or water traffic as well as human or industrial activities has been evaluated and taken into account. '
internal accidents.
Criticality.
The risk of a criticality is kept at a minimum thanks to physical layout and mass limitations. The plant is completely dry; moderators are strictly limited in the production rooms. The plant is divided into small operational units such that any possible configuration of fissile materials allowed within a unit remains subcritical taking double batching into account The nuclear material accountancy in the different units occurs in nearly real time.
O Fire risk.
The risk of fire is especially considered and advanced fire protection has been provided. We consider as well ingress of fire from outside the plant as fire originating l from inner source.
l The classical means of 1.re prevention such as limiting any combustible material and fire initiation sources are of course applicable. The glove boxes are ventilated with nitrogen or helium in place of air.
Special attention has also been paid to fire fighting. It includes the partition of the plant into many fires zones limited by fire resistant walls. Each zone has its own ;
ventilation subsystem able to isolate it from the neighboring zones. The ventilation is designed to remove the fumes generated in the room impeding the access for the fire fignter crews and to maintain the room pressure in the damaged zone below that of the other zones. A special filter bank is installed to protect the main filters of the plant in case of fire. The location of this filter bank in the technical gallery allows, even in case of fire, to be accessed so that the fire valves may be manually actuated l even if they are not properly responding to the automatic control.
As means used for fire fighting, let us note the existence of a carbon dioxide injection Q system.
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' Operator excesure The exposure of the plant operators is minimized. To reach this goal we have used hardware solutions like neutron and gamma shields on the glove boxes, installed all i
fuel storage behind concrete walls, and used separate rooms for operations where significant long stays by personnel are required. {
l Software solutions are also used. They aim at moving the operator away from the.
equipment. Automatic inspection machines are foreseen and even if the visuel !
control of the process remains important, the control cabinets are installed in I separate control rooms.
j l
Contamination inside and outside the containment. !
A triple static confinement concept is used towards outside : I e the glove boxes containing equipment, i
s
. the fabrication rooms, I
. the confinement provided by the building itself, h
Over this static confinement a dynamic one is provided keeping in operation a j sophisticated once-through ventilation system. The latter insures . air pressure j cascades in such a way that any leak is organized from less to more hazardous zone i
and filtration of the exhausted air. '
I Obviously the blowers and filters are redundant and the energy supply for running the fans is provided by redundant emergency generators in case of grid failure.
Other features for limiting the contamination are the existence in the glove boxes of specially designed plutonium dust collection system and the arrangement of the plant in small rooms avoiding as far as possible the migration of any contamination leaks,
- Air monitoring systems control the absence of contamination inside the halls and at the stack.
O 16
__.._._.___._________-._--____.___._.__._.___,p_.y
.. ^y .4
{
i
! f 17 !
[O l l- 4.2.2. Licensing of the P1 plant.
I 1
The process of licensing the P1 plant follows the rules indicated above. !
{- After having prepared the application file including :
5 l l e , a site and a plant description, l
e a safety analysis,
, I d
. - an evaluation of the generated waste and of radioactivity releases, i e !
the management scheme of the' nuclear material, l
e the personal education and training plan, l e the emergency planning. !
we have applied for license by the Governor of the Antwerpen province in December 1987.
The license application is transmitted by the Governor of the province to the Special .;
Commission after having collected the advises of the involved municipalities. >
l Within the Special Commission, a contact person was nominated who is the contact person between the Commission and the applicant. He must expedite the file :
processing by discussions, questions and answers related to the file with the owner.
After the discussions aiming at a better understanding of the file, thirty-two official sets of questions were raised by the Commission. Each set required a technical i answer file which is then considered to constitute part of.the license application.
The questions may be sorted according to their importance in 4 packages :
. questions concerning the eparation experience of P0 operation incidents and their consequences and solutions which have been developed to minimize or impede them, e
requirements of increasing the safety characteristics and the redundancy features of the main energy and fluid feeds,-
e calculation files and accident simulation to confirm the provision foreseen for the plant safety, O
s 17
l 18
. more accurate desenption of the plant than initially provided to allow deeper ;
analysis of the plant safety by the Commission.
{
i The former application file and the answers to the 32 question sets were the basis considered for the preliminary report of the Special Commission.
The agreement of the neighboring countries was requested based on a special file prepared as foreseen by Article 37 of the Treaty of Rome. The inquiry of foreign countries and the work of the experts of the EC concluded favorably with regard to the safety of the project.
After release of the final report of the "Special Commission", the signature of the l Royal Decree occurred in April 1991.
The total duration of the process was forty one months.
l 4.2.3. License documents.
The formal license documents are binding. They include :
. licensing application e preliminary report of the Special Commission
. application according to Article 37
. final report of the Special Commission
. Royal Decree i
O !
18
"*""994yg, .
19 7,
( \
- 5. CONCLUSIONS.
The licensing of a MOX facility is a long and complex process.
To be successful, we think that the following key factors are important a
the licensing must rely on construction and operation experience gained on former plants. The PO licensing was based on the operation experience of the pilot plant we operated in the sixties. The P1 licensing was based on the experience of P0 we operated safely for more than 20 years.
the design of a plant must have provision for future evolution. This is true for operation purposes but also for the adaptation to new safety rules.
. the licensing process must be an efficient collaboration work between the licensing bodies and the applicant.
V e and last but not least, a political willingness must exist to progress.
t !
,_ /
19
O O .
O ~!
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. ../d:./
COGEMA COGEMA:
MOX FAanICATION AND LICENSING EXPERIENCE Gdrard LEBASTARD President and CEO, COMMOX Director international Business Reprocessing Branch, COGEMA e
g NEl Meeting, 3
March 26,1997
, -i i
HIGHLIGHTS OF 1996 .
MELOX commercial operation:
good results, largest plant in operation with 50 t of pellets delivered, production on target International agreements negotiated between Europe and Japan to start fabrication of first '
BWR MOX fuel batch at Dessel Cadarache plant was qualified for German l PWR MOX fuel first delivery early 97 i
o COGEMA
O O .
O .,
l Hoaxuants OF 1996 10 reactors in France,21 reactors loaded in Europe with MOX fuels !
1 in spring 1997, COMMOX will deliver its 1,000th commercial MOX fuel assembly P
I e O l COGEMA ;
______.__._..________.m _.___ _ _ _ _ _ _ _ _ _ _ _ _______ _ _ _ _ _ _ _ . . _ _ __ . _ _ . . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _
O O O
~
COGEMA anOuP MOX FAanscanON EXPERIENCE (As OF 12/1996) .
i l Delivered MOX fuel assemblies PWR BWR France 600 Germany 120 6A Switzerland 60 Belgium 40 i
i R
b COGEMA
F O O .
O ~; .
--w .!
COGEMA group MOX FABRICADON EXPERIENCE tHM DELIVERED 1994 1995 1996 Cadarache 20 32 23 ;
Dessel 32 30 36 Melox -
start up 50
?
i L
=
2 COGEMA h I
O O .
O ~!
t FUEL COMMERCIAL DELIVERIES Delivery year Power plant MOX reload 1987 EDF 1st reload i
1988 EDF 2 reloads Beznau 1 1st reload l 1989 EDF 4 reloads Beznau 1 2nd reload i 1990 EDF 4 reloads Beznau 1 3rd reload 1991 EDF 4 reloads i EDF 4 reloads 1992 Beznau 1 4th & Sth reloads t Unterweser 1st reload O
COMMOX o
COGEMA
- - - - - - - - - __--------_--------_-----------------------____----_-----------------_-----_j
O O O
-, .i Delivery year Power plant MOX reload EDF 3 reloads 1993 Grafenrheinfeld 1st reload Philippsburg 1st & 2nd reloads -
EDF 5 reloads 1994 Brokdorf 1st reload Belgian NPP 1st reload EDF 6 reloads 1995 Gundremmingen 1st reload Belgian NPP 2nd reload "
Brokdorf 2nd reload EDF 7 reloads 1996 Philippsburg 2 reloads Brokdorf 2 reloads i i
E Q
comuox O
COGEMA ,
, o o .
o -i
.l l
l MOX FUEL - AN INDUSTRIAL REALITY 56 16* 10 10 1987 20 12 7 7 1982 7 2 2 2 1995 1
5 4 2 1 1988 i
- 28 after completion of the licensing procedure underway i
Japan has confirmed on february 1997 loading of one TEPCO BWR and one KEPCO PWR with MOX reloads in 1999. Program to reach 16 to 18 reactors by 2010.
j s
E i
Q COGEMA 4
O O .
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-ll l
i TECHNOLOGICAL AND INDUSTRIAL FEASIBILITW MELOX, THE REFERENCE MOX Fuelprogram tHM Jk 1400 Contracted 1200 1000 800 AcidovW l
600 i 400 l 200 - - -
- o. -- a i_____________
l 86 87 88 89 90 91 92 93 94 95 96 97 98 99 00 l
q Cumulated tonnage for BN - PO, Melox , COGEMA Cadarache a
5 O
COGEMA i
- O O .
O j
l 1
THE MELOX PLANT: EVOLUDON In constant evolution, by 1999 MELOX will manufacture BWR as well as PWR MOX fuels 1
i n
7 100t PWR 3 2 1 FS 69
__ 4 160t PWR 2 1 FS 69 4
! BWR 1* 1* FS 65 i
i FS 69
= PWR FS 65 250t 4 2 1 BWR 2* 2*
TN 12 i
TN 17 MX
- P and B flexible lines i
i H
O COGEMA i
i
i o __.,,,
o .
o '
FRANCE LICENSING EXPERIENCE Ministry of industry, Ministry of Environment and Ministry of Health are in charge Working for the Ministries are:
-CSSIN (High Counsil for Nuclear Safety and Information): information to local Authorities, Public and Media j
-CilNB (Interministerial Commission for Basic ;
Nuclear Facilities) license application j
e s
g COGEMA :
O O O DSIN (Nuclear Facility Safety Directorate):
i! cense procedure and safety evaluation DSIN for assessing the Safety relies on:
6
-IPSN (Institute for Nuclear Safety and Protection):
technical analysis and evaluation of Safety
-Group of Experts: opinions and recommandations
-DRIRE (Regional Directorate for Industry, Research and Environment): regional check i
E COGEMA O
l
__.____--__,_._m __._._-.__-__.m._ ._ . -_.-_--______._-_ _ -____-_._ __ __
o o - o
-l1 i .
l FUEL RELOAD LICENSING Licensing Guidelines published by DSIN Idocument 2323/78) :
Prior to fuel loading, EDF has to submit DSS i: Fuel Reload Safety Files? to DSIN. IPSN provides technical support i
DSS is reactor and fuel reload specific DSS may refer to DGS i: Generic Fuel Safety Evaluation Files)
E O
COGEMA
~
t i
For LTA's analysis by DSIN on a case by case basis No formalized procedure Documents have to comply to licensing Guidelines Prior Authorization or Qualification, Surveillance -
and Audits of Reactor Operator, Fuel Designer and '
Fuel Manufacturer '
l s
a O
COGEMA l f
O O .
O PLANTS LICENSING Several steps:
DAC (Authorization of Creation Decree)
Operating license Effluent release authorization Fissile material reception and processing authorization :
f l
O COGEMA I i
l t
M MELOX BASIC NUCLEAR INSTALLATION g CONSTRUCTION LICENSE PROCEDURE COGEMA l OPERATOR l !
Y
- LICENSE APPUCATiON ACCOMPANIED I c SY PRELIMINARY SAFETY ANALYSIS REPORT l Y
1r If 1F Y CONSULTATION WITH THE PREFECT D.R.I.R E-
~
--_ REPORT INCLUDING HEALTH MINISTER :
1 r Y LOCAL )EVIEW AND ADVICE OF THE STANtjlNG INQUIRY L GROUP OF EXPERTS KiTACHEp TO D. SIN.
[
h 1 r Y 1r Y '
C.I.l.N.B.
ADVICE l
y AGREEMENT OF THE HEALTH >
MINISTER '
T@d *1 Y.F-~5 -
O O .
O -
BASIC NUCLEAR INSTALLATION g E OPERATING LICENSE PROCEDURE cocoa ,
JUQlON OF A PROVISIONAL j "4TLANALYSIS REPORT 1.RS. N.
O REPORT Y
MN ANp ADVICE BY THE !
[p'i..'-
.NG GgOg Of [XPERTS ATTACHED
%,2;TO THE D %.1 R h . X '1kA mummuimummu lTESTlHG PERIOD l SUSMIS$40N dTHE OPERATOR OF THE PINAL SAFETY REPORT RE RT
- ' EXAMINATl@ AND ADYICE BY THE STANDING GROUP OF EXPERTS ATTACHED TO THE D.S I.N a- :
- - - - - - - - - _ _ - _ _ - - - - - - - - - - - _ - - - - _ - - _ - - - - - - ---_- a
O O .
O CONCLUSIONS MOX fuel fabrication: already a mature industry Recycling programs: large developments expected MOX capacity: COGEMA will expend its capacity to be in a position to meet market demand Basis:
-Melox plant: 250 tHM/y, PWRs and BWRs, large quantity
-Cadarache: PWRs and FNRs
-Dessel: PWRs and BWRs, small i
l quantities O COGEMA :
-W RADIDACTIVE LIQUID OR GASEOUS EFFLUENT g; E .
RELEASE LICENSING PROCEDURE COGEMA l OPERATOR l l PREUMINARY STUDY l I
"I ST D VI OTHER MINISTERS CONCERNED v v +
l OPERATOR l RADIOACTIVE RELEASE UCENSE APPUCATION ACCOMPANIED BY FINAL STUDY j
S b$S HEALTH MINISTER SCPRI ADVICE
- 1 Y
ADMINISTRATIVIj _ PUBLIC PREFECTURE < ,
CONFERENCE ' ~ ..
~
._. INQUIRY _ ,
GRANTING OF RADIOACTIVE RELEASE LICENSE BY INTERMINISTERIAL ORDER l
o ,
o . o -l MELOX LICENSE REVISION i
Modification to be requested for the Decree 21/05/1990 1997: flexibility of manufacturing various MOX fuel designs 1998: after public inquiry, increase in capacity i
!3 @
COGEMA
. i
i i
4 i
i
{ Excess weapons Pu:
l
. -US and Russia have to engage in similar j solutions: options, time of implementation...
l
-Fabrication capacities do exist in France
- -Quick start up needed for credibility and full '
international support i,
i l CpGEMb O O
~
O .._ _ _
SIEMENS Industry Presentation on the Fabrication of MOX Fuel l
Siemens Power Corp.
MOX Fabrication and Licensing Experience..
i l
March 26,1997 '
Dr. Carl A. Duckwitz NEl Presentation ~,Q
O O O '!
sieuess i MOX Fabrication and Licensing Experience
=
Table of contents:
II. Siemens New Mox Plant - design, layout, process i lil. Generallicensing requirements IV. Main topics of safety criteria - some applied principles i
V. Summary
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.1 O O O SIEMENS MOX Fabrication and Licensing Experience Summary:
Based on more than 30 years of explicit experience with MOX Fuel covering
. Fabrication
- Project Management
. Design . Plant Design / Licensing / Operation
. irradiation j
, = ,
siemens is in a position to offer:
Qualified Services, Resources, T,echnologies and Experiences- -
! for the Consumption of Weapons-grade Plutonium in LWRs.
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E II.
1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1930 1991 1992 1993 1994 1995 1996_
Year GKN-1 ii"u S
-2 KWG KBR DWR: KRB-A ---------
""~ '
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Commercial MOX insertion in DWRs and PWRs by SIEMENS KWU Group up to Sep.1996
o o o .;
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SIEMENS MOX Plant Licensing Procedure ,
Licence appl.ied for: December 12,1975 Safety Analysis Report: March 1982 Licences: 6 Partial Licences from Oct. 9,1987 to March 11,1991 Ground-breaking: December 1987 Initial Startup scheduled for: 1992 I Project Volume: approx. DM 1 billion Present State of Construction: more than 90 % completed l
Siemens MOX Technology eme. - u g 'l g2=
SIEMENS MOX Plant Design Data Throughput:
120 t HM LWR-MOX Fuel (fast breeder fuel possible)
Volume licensed to be handled: 2.5 t Plutonium Production Lines: 2 (partial redundancies in the lines)
Engineered Features: - Glove Box Handling
- Fully automated normal Operation
- Negative Pressure Zones
- Newly developed Powder Transfer System Radiation Protection: Conservative Design for Working Places: l max.10 mSV, equivalent to 1 rem /a Siemens MOX Technology .-
"-*OR=
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Siemens a dominant MOX-Supplier t HM cum. A 450 -
400 - t
> 100.000 Fuel rods '
350 - 207 t HM corr. to 8,5 t Pu 48 mwd /kg HM 300 - peak rod burnup 250 -
l 200 -
150_ Contracts and LOI
(~ 300 t SM) 100 -. Fabrication at DN,
/ BNFL, COGEMA 50 - . - Operation old
/ _Hanau plant.-.
O ; i i j i i j ; -
1972 1976 1980 1984 1988 1992 1996 2000 2004 Year MOX Overview,1997
-~<>>Q ~
p SIEMENS
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Operating Experience with SIEMENS Mixed Oxide Fuel (Status 8/96)
Testphase for MOX in BWRs and PWRs Commercial MOX insertion (since 1973)
(1966 - 1977)
Plant No. of MOX-FAs Plant No. of MOX-FAs BWR PWR Obrigheim (KWO) 32+29 Kahl (VAK) 113 (since1966) Neckarwestneim (GKN-1) 32 Lingen (KWL) 1 (since1972) Unterweser (KKU) 60 Gundremmingen (KRB-A) 64 (since1974) Grafenrheinfeld (KKG) 60 Big Rock Point (BRP) 28 (since1972) Grohnde (KING) 32 PWR Philippsburg (KKP-2) 32 Obrigheim (KWO) 1 (since1972) Btokdorf (KBR) 24 HVVR Beznau (BZN-2) 52 Karlsruhe (MZFR) 8 (since1972) BWR Gundremmingen B (GUN-B) 32 Gundremmingen C (GUN-C) 16 -
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MOX Plant Licensing Procedure i
Licence applied for: December 12,1975 Safety Analysis Report: March 1982 Licences:' 6 Partial Licences from Oct. 9,1987 to March 11,1991 Ground-breaking: December 1987 Initial Startup scheduled for: 1992 Project Volume: approx. DM 1 billion ;
Present State of Construction: more than 90 % completed l
Siemens MOX Technology =v
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SIEMENS .
MOX Plant Design Data Throughput:
120 t HM LWR-MOX Fuel ,
(fast breeder fuel possible)
Volume licensed to be handled: 2.5 t Plutonium Production Lines: .
2 (partial redundancies in the lines)
Engineered Features:
- Glove Box Handling
- Fully automated normal Operation
- Negative Pressure Zones
- Newly developed Powder Transfer System Radiation Protection:
Conservative Design for Working Places:
max.10 mSV, equivalent to 1 rem /a '
i Siemens MOX Technology ,
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SIEMENS MOX? Plant Building Specifications i
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. Production Buildina Auxiliary Buildina. Total
- l.
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Dimens. ions (Ifix W x H): 59 x 36 x 18 m. 61 x 23 x 21 rn Enclosed! Volume: ~ 42.000 m ~ 23.0.00 m . * ,
~
. 65.000 m*
Thickness of _ Walls, Ceiling, '
Floor Plate: 1,8 m - 2,0 m
.. 0,3 m:- 0;8 ml Amount.iof Concrete.Placed: 19.000 m 3.000.'mI ; 22.000 m Reinforcements'used: 7.500 t 800' t:
8.300 t
- Design" Criteria- against- Earthquake Earthquakea Aircraft Crash Blast Wave - -
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MOX Plant i Waste Treatment : i l Waste from Glove Box r Waste from Control Area solid I fluid inorganic l organic i V i i V i Shredding i i i .
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t SIEMENS t MOX PLANT i Overview over the Legal Basis for the Regulation of Nuclear Safety in Germany ! Federal Acts Ordinances General Administrat. ; ! Constitution Provisions s Art. 74 Nr.11a _ _ _ . _ . , j l Radiation Protection Radiation Exposures Legislative Ordinance Competence l from rad. Effluents l of the Federation i
] X-Ray-Ordinance Radiation Passport l
Art. 87 c
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'l Atomic Energy Act Nuclear Licensing i Administration } Procedure Ordinance on behalf of the Federation , Nuclear Financial I Security Ordinance j r
j Licensing Cost
' i
_ . _ . _ [ Ordinance Act on the Establish-ment of the Fed. Agency Safety Officer and t
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for Rad. Protection incident Reporting . Ordinance
, Act on Precautionary :
Radiological Protection ' Siemens MOX Technology ow Q e
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O O O , SIEMENS t f MOX PLANT i Hierarchy of Licensing Regulation in Germany i i 4
- i Federal Legislator Obligatory for Everybody Federal Government
. Federal Council -- Obligatory for Authorities Federal Government i i Authorities ! Advisory Bodies KTA Industry .eT MichWdi'S%ficatibris fofDErIpEe 7 Written Regulations for Oraganisation, Operation"*"",- Obligatory Regulations in Licensing Documents Siemens MOX Technology muu Q -
o O O .. I SIEMENS i MOX PLANT Participants, Responsibilities, Interactions within the German Licensing Procedure Advisory Committee Federal Minister Reactor Safety Commission i for the Environment, (RSK) and Radiation Pro- N /
, Other Nature Conservation N /
tection Commission (SSK) and Nuclear Safety Federal Ministries instrucions in s particular cases, Company for Reactor Supervision of Safety (GRS) 1-jja " a Information
, Information i
^
Te Inspect,chnical A encies , State Minister as ' N / Licensing Authority N / Local and other State-Authorities Expert's Opinion for g'ueSo"n' the Non Nuclear Part - and Enforcement according to the Atomic PUBLIC Energy Act APPLICANT i Siemens MOX Technology ' meus@
o o o SIEMENS MOX PLANT Main Topics of Safety Criteria 1 e Siting e Criticality Safety e External Events e Construction and Design l l e Fire and Explosion Protection . Quality Assurance i l e Chemical Hazard, Corrosion e Plant Operation l
' e Protection against Leckage e Accident Analysis e Resistance against Overpressure e Waste Management i
e Radiation Protection e Emergency Measures e Decommissioning ,. 1 Some of these topics will be discussed in more detail in the following sections. j Siemens MOX Technology muu @
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SIEMENS_ MOX PLANT ' Radiation Protection Ordinance 1 I e Radiation Protection based on ICRP Principles e Limitation of individual doses for the population e Normal operation including deviations (@@ 44,45) e design basis accidents (@ 28) e Limitation of individual doses for workers i e External radiation and incorporation (@e 52,54) l e Evaluation of risk reduction for extreme events of low probability :l Siemens MOX Technology maw @ _ _j
l SIEMENS t L MOX- Plant l Radiation Protection
- Limit for effective equivalent; dose- , il 10 mSv/a l .
- Design principles.
iminimization of inv.entory~in working areas
- 1 shielding within glove boxes,Luse of double walled glove boxes i
- Luse of combined n/y- shieldings (e.g. polpthene'+11eadI+ neutron absorber):
Lrninimization of manipulation for the staff by-meansLof automated processes
- Lapplication of a barrier concept to prevent contamination and incorpo~ ration
_ 1
. air ,nsurface- and personal monitoring i
- Wcirking places calculated with;special computer program PUDOL
- 8esults (with annual throughput 120 t HM/a, mean1Pu-content 7.2 %,
rnean Americium-content: 1.75 %) t
<10 mSv/a will be well observed collective dose < 1 Sv/a l
Siemens MOX Technology awma-23 m er tz
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SIEMENS MOXiPlant Inventory of Radioactive Material .
-c l22500 kg Pu '
-.. i.8 kg Am (separated from Pu) .
15.50 kg U-235, enriched Uranium.
-150:00'O kg U-nat
- 30.000 kg U-depleted -
Uranium may be fresh or recycled Uranium ' i Siemens MOX Technology == - 23 e 5
o o o ~; l SIEMENS
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iMOXlPiant - lP.u-.V. ec. tor
- Calculatiop for an' annual throughput of 120 t:HM;, '
- me'an Pu-cion' tent 7.2L% .
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Pu-vector Pu-238 2'3 % Pu-239 51,2 /o - r,!ean burn-up 48 mwd /kg U i t Pu-240 26,9 % - higher mean burn-t/ reduces Pu-241 9,7 % throughput ofi m .
. Pu-242 8,1 %
- 1 o Am-241 1,75 % - mean permitted value L
u - higher value reduces throughput s - maximum permitted 3 % - [ - - " Siemens MOX Technology " "-25 jiEi '; e ;
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*i SIEMENS MOXLPlant Radioactive Effluents t
i Airborne
-limit for emission: 5,5 x 10' Bq a/a :
12 3,7 x 10 Bq Rn 220/a
- calculated effective dose for people living outside the plant: <1 pSv/a
- expected emission (below detection limit): < 1,9 x 10' Bqa/a t Liquid .
-limit for emission: 4,4 x 10' Bq a/a
- calculated effective dose for people living outside the plant: < 0,2 pSv/a
- expected emission (experience): 9 x 16 Bqa/a o -
Limits from Radiation Protection Ordinance
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- 300 pSv/a effective dose from airborne and liquid' emissions each (least favourable assumptions) j Siemens MOX Technology = =*-28 m '!
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O 'O O : SIEMENS MOX! Plant-Design Criteria for Criticality Safety l
. i - Ru;ve.ctor: 95 % Pu 239, 5 % Pu 240 ~ - PuLco'ntent in U/Pu mixtures- ;f.
H100 % inLPuO2-storage, pun-storage,,PuOl-feed station, conversion tL 458atin' master: mix :
- > 915 % in LWR fuel - Priority of Technical Measures for Criticality Safetyj i geometry (cylinders, slab containers, volume)- .
neutron' poisoning
- moderation control
-? Administrative Measures in Areas with low inventdry only (laboratory,= waste treatment) .
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- Double Failure Principle Siemens MOX Technology .
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O O O ;- sisusus ; MOX Plant Design Basis Accidents !
= Rsdiation Protection Ordinance: Effective dose equ.ivalent < 50 mSv from L accidentsLfor p.eople' outside '
.the plant least favourablelfield point.
Results of CalculationsT.nSv);- Fire in HEPA filters: 2.7 x 10-8
~ Criticality:
8.3 (main share from lodine) , Leakage: 2.2 x ,10 -7
! Crash of Glove Box:
3.6 x:10 ~8 '
- - Earthquake:
1.2 x 10" L-Air Craft' Crash: not calculated, buildiriglis designed BlastsWave: against these' accidents LAll other accidents: no releaseiof activity:! Siemens MOX Technology =-=- g # a u
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o SIEMENS MOX Fabrication and Licensing Experience mmary: - Based on more than 30 years of explicit experience with MOX Fuel covering
= Fabrication
- Project Management
! Design Plant Design / Licensing / Operation Irradiation 4 Siemens is in a position to offer: - b9 p.-
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- Qualified Services, Resources, Technologies and Experiences k if0 for the Consumption of Weapons-grade Plutonium in LWRs. .
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