ML23324A191
| ML23324A191 | |
| Person / Time | |
|---|---|
| Site: | 07003103 |
| Issue date: | 11/28/2023 |
| From: | NRC/NMSS/DFM/FFLB |
| To: | Louisiana Energy Services |
| Shared Package | |
| ML23324A189 | List: |
| References | |
| EPID L-2023-LLA-0127 | |
| Download: ML23324A191 (2) | |
Text
Enclosure REQUEST FOR SUPPLEMENTAL INFORMATION LOUISIANA ENERGY SERVICES, LLC LICENSE AMENDMENT REQUEST TO REVISE SNM-2010 TO DELETE LICENSE CONDITION 14 RSI-1 ENVIRONMENTAL REPORT
Background:
Louisiana Energy Services, LLC (LES) is proposing to remove License Condition 14, which prohibits LES from using a deconversion facility that produces anhydrous hydrogen fluoride (HF). The condition was added to the license because of a contention in the U.S. Nuclear Regulatory Commissions (NRC) licensing proceeding (contention EC-4) that LESs environmental report (ER) and the NRCs environmental impact statement (EIS) did not contain an analysis of the impacts of a deconversion facility of the type contemplated by LES (one that produces anhydrous HF rather than aqueous HF). Section 2.2.2.5 of the NRCs EIS for the LES facility, NUREG-1790, Environmental Impact Statement for the Proposed National Enrichment Facility in Lea County, New Mexico, states the reasons that the option of generating anhydrous HF was eliminated from further consideration in the EIS.
Information Needed:
Because the potential impacts associated with anhydrous HF were not analyzed in the EIS for the LES facility, removal of the license condition will require an environmental assessment of these potential impacts. The NRC staff needs additional information to complete its environmental review of the license amendment request (LAR). An ER that addresses the impacts of using a deconversion facility that produces anhydrous HF should be provided by LES. Specifically, the NRC needs the following information:
1.
Describe the proposed action that would be made possible by the NRCs removal of the license condition, such as the shipment of depleted uranium hexafluoride (UF6) to a deconversion facility that produces anhydrous HF. Where possible, quantitative information should be included, such as the quantities and frequency of depleted UF6 shipments and a reasonable distance or range of distances.
2.
Discuss how depleted uranium hexafluoride would be processed using a method that produces anhydrous HF and potential environmental impacts that would result from those activities, including impacts from anhydrous HF storage, transportation, and related accidents.
Deficiency:
In the LAR, LES does not state that the proposed removal of License Condition 14 can be categorically excluded under Title 10 of the Code of Federal Regulations (10 CFR) section 51.22(c), and the NRC staff has concluded that none of the categorical exclusions in 10 CFR 51.22 apply to this action. Therefore, the NRC needs to prepare an environmental assessment (EA) and requires information from LES to support the EAs development. Because LES did
2 not include information in its LAR to support the development of an EA, the LAR needs to be supplemented as described above.
Basis:
The National Environmental Policy Act requires that Federal agencies assess the direct and indirect impacts of major Federal actions affecting the environment. LES produces depleted UF6, and the impacts of managing this byproduct, whether through storage, disposal, or processing, are indirect impacts of operating the LES enrichment facility. License Condition 14 was added because the NRCs EIS for the LES facility (NUREG-1790) did not assess the impacts of using a certain type of deconversion facility. Since LES is currently requesting to remove the license condition, the NRC needs to analyze those impacts as part of its environmental review process.
The NRCs categorical exclusions in 10 CFR 51.22 do not apply to the proposed removal of License Condition 14, and therefore the NRC needs to prepare an EA. In the LAR, LES states that it is not required to submit an ER under 10 CFR 51.60(b)(2). However, the NRC staff has concluded that an ER is required under 10 CFR 51.60(b)(5). The contents of the ER should align with the guidance for a simple EA provided on pages 3-3 through 3-7 of NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs.
Chapter 6 of NUREG-1748 provides detailed discussion of the information that should be provided for each resource area, where applicable.