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ENCLOSURE 2
M190098
GE2000 SAR Amendment Meeting Presentation
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IMPORTANT NOTICE
This is a non-proprietary version of Enclosure 1 to M190098, which has the proprietary information removed. Portions of the document that have been removed are indicated by an open and closed bracket as shown here [[ ]].
Pre-Submittal Meeting for the GE Model No. 2000 Safety Analysis Report Amendment to Support Accident Tolerant Fuel
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June 6, 2019
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Meeting AgendaNon-Proprietary Discussion
• Introductions
• Purpose
• Summary of Previous GEH and NRC Meetings
• Overview of the GE Model No. 2000 (GE2000) Safety Analysis Report (SAR) Amendment Strategy
Proprietary Discussion
• Chapter-by-Chapter Technical Approach for Amending the GE2000 SAR to Support the Accident Tolerant Fuel (ATF) Program, Including Technical Approach to Address the Previous NRC Requests for Additional Information (RAIs) for Irradiated Fuel Rods
• Proposed GE2000 Certificate of Compliance (CoC) Mark-ups
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Purpose• Review the technical approach for amending the GE2000 SAR
NEDO-33866 Rev. 3 [ML18058A112] to allow for the transport of irradiated fuel rods to support ATF Post Irradiation Examination (PIE).
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Summary of Previous GEH and NRC Meetings• Monday, December 17, 2018 [ML18346A021]o Overview of GEH’s IronClad and ARMOR ATF Technologies.
o Description of the GE2000.
o GE2000 licensing strategy.
• Tuesday, February 5, 2019 [ML19025A013]o Irradiated fuel rods were previously part of the GE2000 NRC approved content in
Rev. 26 of the CoC [ML14245A208].
o Irradiated fuel rods were part of content in NEDO-33866 Rev. 0 [ML16126A499].
o GEH planned technical approach for NEDO-33866 Rev. 3 amendment.
• Monday, March 11, 2019 [ML19058A070]o Technical approach for amending the GE2000 SAR shielding evaluation.
o Process for calculating the total dose rate and thermal contribution in the GE2000.
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Overview of the GE2000 SAR Amendment• No cask or hardware modifications.
• Irradiated fuel rods will be re-introduced as approved content by amendment to the GE2000 SAR (NEDO-33866 Rev. 3).o A revision to NEDO-33866 Rev. 3 will not be submitted.
• The NEDO-33866 Rev. 3 amendment will incorporate the irradiated fuel rod RAIs [ML16235A154].o GEH will not re-submit formal responses to the RAIs for irradiated fuel rods
[ML17164A290].
• A proposed GE2000 CoC mark-up for including irradiated fuel rods as an approved content will be provided as part of the amendment submittal.
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End of Public Session
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Chapter 1 Amendment• The legacy Chapter 1 RAI 1.1 is for Special Nuclear Material, and
NEDO-33866 Rev. 3 will not be amended to address it.
• Amended to administratively reincorporate irradiated fuel rods as approved content.
• No drawing or cask description amendments.
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Chapter 2 Amendment• No legacy RAIs for Chapter 2.
• No amendments to package gross weight limits or structural components.
• No amendments to structural evaluation.
• No amendment to Chapter 2.
• Relevant background information from Chapter 2:o The Material Baskets are classified as a NUREG/CR-6407 Category B safety
component.
o The Material Basket will be required for transporting irradiated fuel rods and will be specified in other areas of the SAR amendment as required.
o Rod Segment Holders are considered shoring and do not perform a safety function.
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Chapter 3 Amendment• No legacy RAIs for Chapter 3.
• Amended for completeness to reinclude irradiated fuel rods as a contributor to package decay heat.
• The term “irradiated fuel rod” will be added to NEDO-33866 Rev. 3 Section 3.1.2.
o “The derivations of the decay heats for the different contents of the Model 2000 Transport Package are presented in Chapter 5. The decay heat for irradiated hardware and by-product, and cobalt-60 isotope rod, and irradiated fuel rodcontents is determined using watt-per-Curie conversion factors […]”
• No amendment to the thermal limit or the thermal analysis.
• Relevant background information from Chapter 3:o The GE2000 was designed for 3000 W of decay heat, but it is limited to 1500 W.
o A decay heat of 3000 W was conservatively used for the thermal analysis.
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Chapter 4 Amendment• No legacy RAIs for Chapter 4.
• No changes to container containment boundary.
• No amendments to Chapter 4.
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Chapter 5 Amendment – Overview• Amended to address legacy RAIs 5.1, 5.2, and 5.6.
• Amended to include a shielding analysis for irradiated fuel rods.
• No amendment to the dose rate and thermal limits currently imposed in Chapter 5.
o Dose rates are limited to 90% of the 10 CFR 71.47 and 10 CFR 71.51 regulatory limits.
o Decay heat thermal limit is 1500 W.
• The method to calculate the dose rate and thermal response for irradiated fuel rods is consistent with the approved method for Cobalt-60 rods and irradiated hardware in NEDO-33866 Rev. 3
• Fuel rod cladding is treated as irradiated hardware (point source) as stated in NEDO-33866 Rev. 3 Section 5.4.4.3.
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Chapter 5 Amendment – Irradiated Fuel Rod Analysis Parameters
Parameter Value
Minimum Cooling Time (days)a 120
Maximum Exposure/Burn-up (GWd/MTU)a,b 72
U-235 Enrichment Range (wt.%)b 1.5 – 6.0
Specific Power (MWth)a 40
BWR Moderator Density (g/cm3)a,b 0.1
Maximum Burnable Poison Concentration (wt.% Gadolinium-Oxide)a,b 5
Minimum Active Fuel Height (in.) 5.3
Analysis Parameters for Irradiated Fuel Rods
a) Most conservative value from NUREG/CR-6716 [ML010820352].b) Maximum validation of ORIGEN-ARP 10x10 BWR cross-section library
[ORNL/TM-2005/39, Version 6.1].
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Chapter 5 Amendment – Technical Approach• [[
]]o Five (5) Normal Conditions of Transport (NCT) Locations
o Three (3) Hypothetical Accident Condition (HAC) Locations
o [[
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Chapter 5 Amendment – RAI 5.1• RAI 5.1: “Justify the gamma and neutron source term strength. Typical spent
fuel source terms for gammas increase linearly with burnup and to the fourth power for neutrons as discussed in NUREG/CR-6802. […] The applicant needs to justify this atypical source term strength increase with increasing burnup.”
• Approach: Develop a new source term for irradiated fuel rods.o The methodology will be different than the approach used in NEDO-33866 Rev. 0.
o The source term will cover a range of U-235 enrichments at specific exposures/burn-ups.
o [[
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o The source term will start with the maximum isotopes listed in ASTM C996 for Type-B commercial-grade Uranium-Dioxide (UO2) prior to irradiation.
The ASTM C996 Type-B material specific applies to the UO2 constituents in the fresh fuel at 0 GWD/MTU.
o The updated source term strength (intensities) using ORIGEN-ARP now correctly align with NUREG/CR-6802.
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Chapter 5 Amendment – RAI 5.1 Source Intensity Example
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Chapter 5 Amendment – RAI 5.2• RAI: 5.2: “Discuss how fuel assemblies other than GE 10x10 meet both
thermal and external dose rate regulations. Chapter 1 of the SAR does not limit what kind of irradiated fuel will be shipped. All decay heat and external dose rate evaluations are based on source terms from GE 10x10 fuel […]”
• Approach: The irradiated fuel rod source term will be exclusively limited to GE BWR fuel designs. ORIGEN-ARP accounts for BWR lattice physics and the cross-section libraries are based on GE BWR fuel [ORNL/TM-2005/39].
o Ensure the amendment clearly states that the additional content is limited to only GE BWR irradiated fuel rods.
o This approach is to focus on the immediate ATF program PIE needs.
o ATF (ARMOR and IronClad) is considered a GE BWR fuel design.
o ATF claddings are considered irradiated hardware (NEDO-33866 Rev. 3 Section 5.4.4.3) and are already covered under the current Rev. 27 CoC [ML18102B446].
o Cladding is independent of the irradiated fuel rod source term.
The thermal and dose contribution from cladding is accounted for in the Chapter 7 loading tables.
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Chapter 5 Amendment – RAI 5.6• RAI: 5.6: “Justify that the irradiated fuel content will meet the package external
dose rate regulatory limits considering the burnup profile. […] The applicant needs to discuss how they account for the irradiated fuel burnup profile. […] The applicant needs to discuss how fuel qualified for loading is classified […].”
• [[
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o This approach will reduce human performance errors when filling out the loading tables in Chapter 7, ensure public safety, provide a more comprehensive shielding evaluation, and make future content approvals (i.e. SAR revisions) more streamlined.
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Chapter 5 Amendment – RAI 5.6 Approach• The NCT and HAC shielding evaluations will have similar source geometry
assumptions for irradiated fuel rods as in NEDO-33866 Rev. 0.o NCT will conservatively assume all irradiated fuel content is in a single 5.3-inch line source.
o HAC will conservatively assume all irradiated fuel content is in a single point source.
• The irradiated fuel rod NCT and HAC source geometries are similar to the Cobalt-60 rod source geometries in the NRC approved NEDO-33866 Rev. 3.
o It is assumed that all of the irradiated fuel rod content is in either a single (1) line (NCT) or a single point source (HAC).
• [[]]
• Dose rate response for neutrons is determined using hand calculations.
• [[]]
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Chapter 5 Amendment – RAI 5.6 Gamma Dose Rate Example
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Chapter 5 Amendment – RAI 5.6 Gamma Dose Rate Example
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Chapter 5 Amendment – RAI 5.6 Dose Rate Roll-up• [[
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• Dose rate is calculated for each irradiated fuel rod in the shipment.
• Total shipment dose rate is confirmed using the irradiated fuel rod loading tables in Chapter 7.
NCT HACTop
SurfaceSide
SurfaceBottom Surface 2-meter Cab Top
1-meterSide
1-meterBottom1-meter
External Dose Rate Locations
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Chapter 5 Amendment – RAI 5.6 Neutron Dose Rate• The process for determining the dose rate contribution from neutrons
(mrem/hr per g U-235) is identical to that for gammas except that MCNP6 is not required.
• In the absence of shielding, the dose rate for a point and line source can be calculated by hand.[[
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Chapter 5 Amendment – RAI 5.6 Neutron Dose Rate• Ignoring the shielding materials is conservative; therefore, hand equations
can be used to calculate the neutron point and line source intensities at the external locations.
• Use the ANSI/ANS-6.1.1-1977 neutron flux-to-dose rate conversion factors.
Point Source
𝜙𝜙 𝑟𝑟 =𝑆𝑆
4𝜋𝜋𝑟𝑟2
Variable Description Unit
𝜙𝜙(𝑟𝑟) Flux at radius r from the point source S n/sec/cm2
S Source strength n/sec
r Radius (distance) from the point source S cm
From Lamarsh and Baratta, Introduction to Nuclear Engineering, Third Edition.
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Chapter 5 Amendment – RAI 5.6 Neutron Dose Rate
Variable Description Unit
𝜙𝜙(𝑃𝑃) Flux at point P n/sec/cm2
S’ Line source strength n/sec/cm
x Perpendicular distance from the point P to the line source cm
l1 and l2The length of the line source on either side of the perpendicular distance x intersection cm
From Lamarsh and Baratta, Introduction to Nuclear Engineering, Third Edition.
𝜙𝜙 𝑃𝑃 =𝑆𝑆′
4𝜋𝜋𝜋𝜋tan−1
𝑙𝑙2𝜋𝜋
+ tan−1𝑙𝑙1𝜋𝜋
Line Source
𝑙𝑙 = 𝑙𝑙2 + 𝑙𝑙1
x P
𝑙𝑙1
𝑙𝑙2𝑙𝑙
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Chapter 5 Amendment – RAI 5.6 Neutron Dose Rate• For additional conservativism, a sub-critical multiplication factor can be
applied to the ORIGEN-ARP neutron source intensity.
• The sub-critical multiplication factor is applied regardless of the technique used to determine dose rate (hand calculation or MCNP6).
• Assume a k-effective value of 0.95.
𝑚𝑚𝑚𝑚𝑙𝑙𝑚𝑚𝑚𝑚𝑙𝑙𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚 𝑓𝑓𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑚𝑟𝑟 =1
1 − 𝑘𝑘𝑒𝑒𝑒𝑒𝑒𝑒=
11 − 0.95
= 20
Example Comparison of MCNP6 and Hand Calculation of the Neutron Dose Rate
The hand calculated neutron dose rate bounds the MCNP6 model.
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Chapter 5 Amendment – RAI 5.6 Response Summary[[
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• All irradiated fuel rods must be accounted for in the Chapter 7 loading tables.
• Filling out the Chapter 7 loading tables is required prior to each shipment.
• The loading tables will confirm that the irradiated fuel rod content meets the package external dose rate and package thermal limits.
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Chapter 6 Amendment• Amended to address legacy RAI 6.2.
• Amended to reinclude the criticality analyses for irradiated fuel rods from NEDO-33866 Rev. 0.
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Chapter 6 Amendment – RAI 6.2• RAI: 6.2: “Provide specifications for all rod types to be shipped by the GE-2000
package and demonstrate that the criticality safety analyses presented in the SAR bound all fuel types to be shipped. The applicant performed criticality safety analyses for the GE-2000 package containing irradiated fuel rod segments. […] The applicant needs to provide specifications for all rod types to be shipped by the GE-2000 package […].”
• Approach: Irradiated fuel rods will be limited to only GE BWR fuel rods.o Reinclude the criticality analyses from NEDO-33866 Rev. 0.
o Provide a comparison table in the amendment for the general parameters of typical GE BWR fuel rods.
o This will demonstrate that the criticality analyses performed bound the intended content and is consistent with other NRC approved packages (i.e. the RAJ-II [ML18247A218]).
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Chapter 7 Amendment• No legacy RAIs for Chapter 7.
• Reinclude a loading table and procedure for the pre-shipment evaluation of irradiated fuel rods similar to those currently listed in Section 7.5 of NEDO-33866 Rev. 3.
• Remove the operating and handling instructions in Sections 7.1 through 7.4 from NEDO-33866 Rev. 3, but retain the requirements.
o Key parameters like bolt torque values and decontamination requirements will remain.
o The generic operating procedures do not add value in the context of a SAR. They do not provide a safety benefit and/or demonstrate compliance to a NRC regulation. Therefore, these handling procedures will be removed as part of the GE2000 amendment.
o The NEDO-33866 Rev. 3 operating procedures are superseded by GEH’s more restrictive internal package handling procedures.
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Chapter 8 Amendment• No legacy RAIs for Chapter 8.
• Irradiated fuel rods do not impact acceptance testing or package maintenance.
• No amendment to Chapter 8.
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Summary of the GE2000 SAR Amendment• No cask or hardware modifications required to reintroduce
irradiated fuel rods as part of the GE2000 approved content.
• GEH will address all outstanding irradiated fuel rod RAIs in the NEDO-33866 Rev. 3 Amendment.
• No amendments required for Chapters 2, 4, and 8.
• Chapter 3 administrative amendment is for completeness purposes only.
• [[]]
• The required Chapter 7 loading tables will confirm that all content meets the 10 CFR 71 dose limits, and the established GE2000 thermal and U-235 mass limits.
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Proposed CoC Mark-ups for Rev. 28
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Proposed CoC Mark-ups for Rev. 28
GE2000 Cask Handling Operations
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Planning and Timing• [[
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• NEDO-33866 Rev. 3 amendment documentation package provided to the NRC:o List of changed pages.
o Administrative Chapter 1 page amendments.
o Page 3-4 from Chapter 3.
o Chapters 5, 6, and 7 will be provided in their entirety.
o CoC Rev. 27 mark-ups.
o Chapters 2, 4, and 8 will not be included with the amendment documentation.
