The PBMR Fuel Plant (PFP), to be constructed at the Pelindaba site near Johannesburg will fuel the first South African Pebble Bed Modular Reactor. The qualification of the PBMR fuel shall be based on past experience with fuel which was produced in the German NUKEM/HOBEG plant and irradiated in the German AVR reactor. Accordingly, the PFP must produce the same fuel as the German plant did, and consequently, the design of the PFP has in essence to be a copy of the NUKEM/HOBEG plant. As a reminder this plant had been operated in accordance with the German regulatory rules which were defined in the years 1970/80. Since then, the requirements with regard to radiological protection, criticality safety and emission control have been significantly tightened, and of course the PFP must be designed in accordance with the most advanced international norms and standards. The implications which follow from these two potentially conflicting requirements, as defined above, are highlighted, and technical solutions are presented. Hence, the change from administrative criticality safety control to technical control, i.e. the application of safe geometry as far as possible, and the introduction of technical solutions for the remaining safe mass regime will be described. A lot of equipment in the Kernel area and in the recycling areas needed to be redesigned in safe geometry. The sensitive processes for Kernel Calcining, for the Coating and the Overcoating remain under safe mass regime, but the safety against criticality is completely independent from staff activities and based on technical measures. A new concept for safe storage of large volumes of Uranium-containing liquids has been developed. Also, the change from relatively open handling of Uranium to the application of containment enclosures wherever release of radioactivity into the room atmosphere is possible, will be addressed. This change required redesign of all process steps requiring the handling of dry Uranium oxides and uncoated Kernels. Finally, the introduction of processes for the near-total recycling of Uranium and chemicals, as well as for decontamination and purification of liquid and gaseous effluents will be presented. These processes were not available from NUKEM/HOBEG fuel facility and needed to be developed now, also following the above mentioned requirements, with respect to criticality safety and radiological protection.

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