ML21158A290
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| ML21158A290 | |
| Person / Time | |
|---|---|
| Site: | 07003103 |
| Issue date: | 06/16/2021 |
| From: | Freels J Louisiana Energy Services |
| To: | Office of Nuclear Material Safety and Safeguards |
| KMRamsey NMSS/DFM/FFL 301.415.7506 | |
| References | |
| Download: ML21158A290 (17) | |
Text
Public Meeting Low Enriched Uranium Plus (LEU+) Project James Freels, P.E.
LEU+ Project Licensing Consultant
© 2021 Louisiana Energy Services, LLC
Introductions
- Urenco USA
- Steve Cowne, Chief Nuclear Officer
- Rick Kohrt, LEU+ Technical Lead
- Wyatt Padgett, Licensing and Performance Assessment Manager
- Andy Thomas, LEU+ Project Manager
- Jim Freels, LEU+ Licensing Consultant 2
Agenda
- Introductions
- Meeting Objectives
- Background information regarding LEU+ Project
- Urenco USA Technological Capabilities for LEU+
- Regulatory Interactions
- Proposed Schedule
- Questions 3
Meeting Objectives
- Communication with Stakeholders regarding LEU+
Project
- Demonstrate continuous focus on Nuclear Safety, Security and any Environmental Impact for Project
- Identify actions taken to date for Project implementation
- Provide general timeline for Project implementation
- Address non-proprietary Project-related questions 4
Background Information for LEU+ Project
- Nuclear industry is interested in pursuing fuels with higher enrichments for reactors (e.g., Accident Tolerant Fuel (ATF) and Extended Fuel Cycle fuel)
- Higher enrichment fuels can:
- have better performance in design basis and severe accident conditions
- widen existing safety margin for nuclear plants
- extend operating cycles between refueling outages
- allow for longer-lived fuel with increased enrichment (less replacement fuel during outages)
- reduce nuclear plant operational and maintenance costs 5
Background Information for LEU+ Project
- Urenco USA can contribute by providing needed fuel enrichment services
- Nuclear industry higher enrichment fuels such as ATF fuel or Extended Fuel Cycle fuel may be less than 10% U235
- Current maximum enrichment level is 5.5% U235 6
Background Information for LEU+ Project
- Potential Impacts of Increasing Enrichment
- Security/Safeguards Arrangements
- Increasing enrichment levels to less than 10% will not change NRC Category for special nuclear material at the Urenco USA facility.
- Classification of fuel facility will remain at Category III
- No additional physical site protection requirements needed
- No changes to the Material Control and Accounting (MC&A) processes or programs are needed
- Environmental Impact Statement
- Preliminary review of impacts to environment of increasing enrichment levels to less than 10% identify no significant environmental impacts
- No amendment to the Environmental Report is anticipated based on scope of proposed changes 7
Background Information for LEU+ Project
- Regulatory Framework for ATF Licensing
- NRC position(1):
- 10 CFR Part 70, Domestic Licensing of Special Nuclear Materials is performance based; therefore, the staff does not anticipate identification of gaps or deficiencies in these regulations for the licensing of enrichment facilities to produce increased enrichment material
- The current rigorous regulatory framework prescribes the processes for facility changes. Urenco USA will follow the established requirements during the LEU+ Project (1)
Project Plan to Prepare the U.S. Regulatory Commission for Efficient and Effective Licensing of Accident Tolerant Fuels, Version 1.1, ML19301B66, page A-2, October 2019, U.S. Nuclear Regulatory Commission 8
Urenco USA Technological Capabilities for LEU+
- Urenco USA Project Plan (non-proprietary)
- Use the applicable sections from 10 CFR 70:
- 70.34: Amendment of licenses
- 70.61: Performance requirements
- 70.62: Safety program and integrated safety analysis
- 70.72: Facility changes and change process
- Implements 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power plants and Fuel Reprocessing Plants
- Other QAPD Quality Level categories can apply:
- QL-1 (IROFS)
- QL-1 Graded (G)
- QL-1 Fire Protection (F)
- QL-2 Administrative Controls (AC)
- QL-3 Commercial Grade 9
Urenco USA Technological Capabilities for LEU+
- Urenco USA Project Plan (non-proprietary)
- Urenco has produced a Technical Feasibility Report assessing ability and capability to implement LEU+ Project
- Report concludes that the LEU+ Project is technically feasible and safe to implement pending review and potential completion of identified modifications and administrative measures to ensure plant safety
- Potential changes needed may relate to:
- Documentation
- Operational procedures
- Physical changes to design of equipment or systems
- Broad Areas reviewed in Report
- Nuclear criticality safety
- Plant performance
- Logistics 10
Urenco USA Technological Capabilities for LEU+
- Urenco USA Project Plan (non-proprietary)
- Nuclear criticality safety
- Possible preliminary outcomes from review:
- Existing design and control measures remain acceptable for LEU+
- Existing design can be made safe with new, or changes to, the existing control measures
- Existing design requires physical changes to ensure safe operation for LEU+
- Plant performance
- Reviews of:
- Assays Units at Urenco USA
- Cascade performance 11
Urenco USA Technological Capabilities for LEU+
- Urenco USA Project Plan (non-proprietary)
- Plant performance (continued)
- Reviews of:
- Flow rates
- Cylinder take-off performance
- Steady state, transient and mode transition conditions
- Logistics
- Reviews of potential work flow bottlenecks:
- Product cylinder options
- Contingency options to minimize/eliminate potential bottleneck s 12
Urenco USA Technological Capabilities for LEU+
- Urenco USA Project Plan (non-proprietary)
- Technical Feasibility Report Conclusions
- Urenco USA can safely implement the LEU+ Program after validating the preliminary findings in the Technical Report for:
- Nuclear Criticality Safety
- Plant performance
- Plant logistics
- Any validated proposed changes, physical or administrative, will follow the rigorous regulatory processes previously identified for their evaluation, approval and implementation
- Configuration management, as well as other management measures, will be followed for necessary document updates 13
Regulatory Interactions
- 1 April 2021- Submittal of Notice of Intent to Submit License Amendment Requests for License Condition 6B and Enrichment Limit
- Anticipated Meetings with NRC
- Pre-submittal meeting to discuss overall approach
- Pre-submittal meetings for each License Amendment Request
- Submittal of License Amendment Request(s)
- Current Licensing Management Plan
- Redundant Items Relied on for Safety (IROFS), submitted 20 August 2020
- Anticipated Programmatic Changes to Safety Analysis Report
- Increasing Enrichment Level for production
- Raising Enrichment Level for Support Systems
Regulatory Interactions
- Requests for Additional Information (RAIs)
- Anticipate questions from NRC technical review to be sent as RAIs
- Responses will be submitted through normal correspondence procedure
- Further discussions with NRC regarding RAI process will be held
- NRC Operational Readiness Review (ORR)
- It is anticipated that NRC will conduct an ORR prior to authorization to start production of higher enriched uranium.
- The schedule for the ORR will most likely be dependent on NRC review of LAR for raising enrichment level.
- Urenco USA staff will be ready and fully support ORR when scheduled 15
Proposed Schedule (non-proprietary)
- Formal schedules are being developed for Project Work Breakdown Structure (WBS)
- LARs are targeted for 2021 through 2024 and will be based on final reviews and approvals of necessary changes referenced in Technical Feasibility Report
- Pre-submittal meetings with NRC will be targeted approximately one month prior to submittal
- Close coordination and communications will be maintained through NRC Project Manager 16
LEU+ Project Questions?
17