NUREG-1537, Part 2 - NRC

9.4 Fuel Element Handling and Storage
Areas of Review
HEU TO LEU CONVERSION
The reviewer should evaluate all issues related to fuel storage of new and
irradiated fuel. These issues comprise physical protection, self-protection,
criticality avoidance, radiation shielding, and heat removal.
If fuel handling and storage requirements should be different for the LEU fuel
because of changed physical security or self-protection requirements, the licensee
should have addressed the issues in the facility security plan and provided a nonsafeguards
sunmary in this section of the SAR (In some cases, security
requirements may be relaxed after HEU fuel is removed). The physical security
requirements and plan should be reviewed along with this section, as necessary,
and under the guidance of Section 12. For example, provisions for maintaining
and assessing self-protection of fuel (100 rem/h at 3 ft) should be reviewed in this
section if facility changes are required because LEU will not require related
safeguard procedures. Capability and authorization to simultaneously possess and
store both HEU and LEU fuel, if required, should be reviewed, including proposed
changes to license conditions and technical specifications.
Analyses of any changed requirements or capability to maintain subcritical
configurations and adequately cooled geometries during storage of new and used
fuel should be reviewed.
Acceptance Criteria
Acceptance criteria should be based on the following considerations: Any changes
from the conversion of HEU to LEU in fuel storage systems or procedures should
not significantly decrease safety margins for radiation shielding, maintaining
subcritical configurations, storage conditions (e.g., temperature and water quality)
or convection cooling (i.e., acceptance criteria should continue to be satisfied).
Fuel handling systems should be appropriately designed for any changes in fuel
element parameters, such as size,'weight, or fissile material content. Continued
interim storage of HEU must conform to applicable regulations, such as 10 CFR
73.6, 73.60, and 73.67, and should be summarized here and discussed in detail in
Section 12, 'Conduct of Operations," under the discussion of the physical security
plan.
Review Procedures
The reviewer should confirm that the licensee has described and analyzed any
changes in the facility or in procedures'required by the conversion from BIEU fuel.
These changes might include interim increased storage capability and authorization
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