For powdered fuel processed in the nuclear fuel facilities, flooding is often thought to be the severest condition regarding the nuclear criticality safety evaluation. T h e reactivity of such a heterogeneous system as powdered fuel in water should be almost equal to that of the homogeneous one, when the fuel particle size is very small. The neutron multiplication factor was calculated for an infinite cubic array of slightly enriched UO, sphere particles immersed in water with various enrichments, water to fuel ratios and fuel particle sizes. The calculations were performed with a computer code module based on the collision probability method to solve the ultra-fine energy group equations of neutrons. The change in the neutron multiplication factor from the homogeneous system is dominated first by the change in the resonance escape probability and second by the change in the thermal utilization factor ; these changes and therefore their sum, depend almost completely on the mean uranium concentration (or water to fuel volume ratio) and rarely on uranium enrichment up to 10 wt% for a fuel particle size of l m m . The dependence determines the fuel particle size regarded as homogeneous in proportion to the negligible relative error of the neutron multiplication factors.