ML23244A192
| ML23244A192 | |
| Person / Time | |
|---|---|
| Site: | 07003103 |
| Issue date: | 09/01/2023 |
| From: | Louisiana Energy Services, URENCO USA |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML23244A190 | List: |
| References | |
| LES-23-108-NRC | |
| Download: ML23244A192 (1) | |
Text
LES-23-108-NRC ENCLOSURE 1 UUSA License Amendment Request LAR 23-07, Deletion of Licensing Condition 14
LES-23-108-NRC
1 Background
In December 2003, Louisiana Energy Services (LES) submitted the application for the enrichment facility in Eunice, New Mexico. In July 2004, the Atomic Safety and Licensing Board admitted Environmental Contention EC-4. This contention was that Louisiana Energy Services Environmental Report did not contain an analysis of the impact of a deconversion facility. This contention was further described in January 2005 in the direct testimony of Dr. Arjun Makhijani (ML050180335). LES provided rebuttal testimony in ML050240017. The NRC also testified regarding this contention. This is contained in ML050270248.
As a result of Environmental Contention EC-4, LES accepted a license condition to not use a deconversion facility that employs a process that produces anhydrous hydrofluoric acid. This limitation was placed in the original SNM-2010 license issued in June 2006 as License Condition 14.
Since issuance of the original SNM-2010, two deconversion facilities have commenced operation in the United States. The United States Department of Energy (DOE) Paducah Kentucky facility began operation in 2010 and the DOE Portsmouth Ohio facility began operation in 2011. LES has not utilized either of these facilities. Additionally, International Isotopes Fluorine Products Inc has been issued an NRC license to construct and operate a deconversion facility.
2 Proposed Change License condition 14 is stated as follows; For the disposition of depleted UF6 (DUF6) the licensee shall not use a DUF6 deconversion facility that employs a process that results in the production of anhydrous hydrofluoric acid.
UUSA proposes that license condition 14 be deleted from Material License SNM-2010.
3 Technical Basis for the Change The original environmental contention, that the environmental impact was not evaluated adequately, was subsequently addressed by the DOE facilities environmental impact statements, EIS-0359 and EIS-0360. Additionally, the environmental impact of the International Isotopes facility, yet to be constructed, was also evaluated in NUREG-2113 (ML12220A380).
The International Isotopes facility is designed to produce anhydrous hydrogen fluoride as a marketable product.
LES-23-108-NRC Each of the above environmental impact statements determined the facility was acceptable for use. Therefore, there is no current technical basis for Environmental Contention EC-4.
License Condition 14 is not clear whether it is acceptable for a facility to produce anhydrous hydrogen fluoride in-process or whether only the final output of a facility is prohibited. Urenco USA prefers that the license condition be removed rather than seek clarification from the NRC.
LES is considering initiating conversion and disposal of depleted UF6 as soon as the fuel cycle capability is established. Potential options for conversion include facilities that produce anhydrous hydrofluoric acid.
To support this initiative, the restriction imposed by License Condition 14 that prevents use of these types of facilities needs to be removed.
4 Environmental Considerations There are no significant environmental impacts associated with the change proposed in this License Amendment Request. The proposed change does not meet the criteria specified in 10 CFR 51.60(b)(2) since it does not involve a significant expansion of the site, a significant change in the types of effluents, a significant increase in the amounts of effluents, a significant increase in individual or cumulative occupational radiation exposure, or a significant increase in the potential for or consequences from radiological accidents. Consequently, a separate supplement to the Environmental Report is not being submitted