ML23334A122

Louisiana Energy Services, LLC, Dba Urenco USA, License Amendment Request for Changes to License Conditions and Raise Enrichment Limit to Less than 1 O Weight Percent for Leu+ Production Systems (LAR-23-02)

ML23334A122
Person / Time
Site:	07003103
Issue date:	11/30/2023
From:	Lorskulsint P Louisiana Energy Services, URENCO USA
To:	Office of Nuclear Material Safety and Safeguards, Document Control Desk
Shared Package
ML23334A121	List: ML23334A122 ML23334A123 ML23334A125 ML23334A130
References
LES-23-130-NRC
Download: ML23334A122 (4)

Text

LES-23-130-NRC Security Related Information Withhold under 10 CFR 2.390 USA The Naliooal Enrichment Facility

November 30, 2023 Attn: Document Control Desk Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Louisiana Energy Services, LLC NRC Docket No. 70-3103

Subject:

License Amendment Request for Changes to License Conditions and Raise Enrichment Limit to Less Than 1 O Weight Percent for LEU+ Production Systems (LAR-23-02)

References : 1) LES-21-0020-NRC, Notice of Intent for UUSA plan to submit License Amendment Requests for changes to License Condition 6B and Enrichment Limit, dated 1 April 2021 (ML21096A120)

2) IN-13-00098-NRC, License Amendment 59, License Amendment Request 13-02 to Revise License Condition 6B of SNM-2010 to Increase the Facility Enrichment Limit (Technical Assignment Control No. L34184), dated 30 October 2013 (ML13290A208)

3) Summary of June 16, 2021 Public Meeting to Discuss a Proposed Increase in the Enrichment Limit for Louisiana Energy Services, dated 28 June 2021 (ML21175A075)

4) Summary of August 9, 2023, Pre-application Meeting with Urenco USA regarding a Forthcoming License Amendment Request for Low Enriched Uranium Plus, dated 18 September 2023 (ML23258A092)

Pursuant to the requirements of Materials License SNM-2010, License Condition 30 and 10 CFR 70.72(d)(1), and in accordance with 10 CFR 70.34, Louisiana Energy Services, LLC (LES), dba Urenco USA (UUSA), hereby requests an amendment to Materials License SNM-2010.

In Reference 1, UUSA notified the Nuclear Regulatory Commission (NRC) of its intent to increase the enrichment limit identified in Materials License SNM-2010. This amendment request proposes an increase of the enrichment limit in Materials License SNM-2010, License Condition 6B from 5.5 weight percent (w/o) 235 U to less than 10.0 w1 0 235 U, allowing UUSA to produce enriched Uranium Hexafluoride (UFs) to support industry demand in using fuel with Low Enriched Uranium Plus (LEU+). In Reference 2, the NRC amended Materials License SNM-201 O License Condition 6B to allow for UUSA to possess up to 5.5 w1 o 235 U to allow for operational margin for fluctuations and deviations within the enrichment cascade and

Enclosures 2, 4, 5, 6 and 7 transmitted by this letter contain Proprietary and/or Security-Related information. When detached, this letter is decontrolled.

Louisiana Energy Services, LLC UUSA I P.O. Box 1789 I Eunice I New Mexico I 88231 I USA T : +1 (575) 394 4646 I W: www.uusa.urenco.com

© 2023 Louisiana Energy Services, LLC LES-23-130-NRC Security Related Information Withhold under 10 CFR 2.390 USA The Nalional Enrichment Facility maintain the assay below the 5 w10 235 U license limit. A similar request is contained in this License Amendment Request (LAR) to allow for the operational flexibility to generate product to satisfactorily fulfill customer orders up to the requested license enrichment limit. This request results in proposed revisions to License Conditions 68, 78 and 88. Additionally, other minor administrative changes to the Materials License are proposed that are necessary to support on site product cylinder operations after the proposed enrichment limit is increased.

UUSA held a public meeting with the NRC on 16 June 2021 (Reference 3) to discuss the LEU+

Project and the planned licensing approach. In that meeting, UUSA indicated the licensing approach would consist of two separate License Amendment Request (LARs), the first for increasing the enrichment level for production systems, followed by a second LAR for raising enrichment for necessary support systems (i.e., recycling systems).

The information related to this LAR is limited to the elements necessary for production,

handling and storage of LEU+ at the UUSA site and the associated interim controls for LEU+

material removed from production processes without use of the installed recycling systems for LEU+ material. A future LAR submittal will address the recycling systems related to the increased enrichment limit and removal of the necessary interim controls needed without recycling system usage for LEU+ material. The scope and contents of this LAR were discussed in a hybrid Partially Closed pre-application meeting held on 9 August 2023 (Reference 4). The basis for two LAR submittals is to provide the NRC staff with an early opportunity to review the production and storage aspects of a higher enriched UF6 product and approve LEU+ production and controls, which allow UUSA the opportunity to satisfy commercial orders while the recycling system analyses are continuing for the non-LEU+

material.

The second LAR, targeted for submittal in Quarter 2 of 2024, will cover the recycling systems analyses/evaluations and associated Items Relied On For Safety (IROFS) controls, as well as the removal of interim controls.

Shipments and transportation of LEU+ will be considered in a separate licensing action, as necessary.

provides an affidavit whereby UUSA considers the information provided in Enclosures 2, 4, 5, 6, and 7 as Sensitive Unclassified Non-Safeguards Information (SUNSI),

and requests that the information be withheld from public disclosure in accordance with 10 CFR 2.390 and the guidance described in RIS-2005-31, Appendix 1.

provides the descriptions and supporting references of the proposed changes for the production systems and storage of LEU+, basis for the change, and safety significance of the proposed changes for the production and storage aspects for the increased enrichment

Enclosures 2, 4, 5, 6 and 7 transmitted by this letter contain Proprietary and/or Security-Related information. When detached, this letter is decontrolled.

Louisiana Energy Services, LLC UUSA I P.O. Box 1789 I Eunice I New Mexico I 88231 I USA T: +1 (575) 394 4646 I W: www. uusa.urenco.com

© 2023 Louisiana Energy Services, LLC LES-23-130-NRC Security Related Information Withhold under 10 CFR 2.390 USA The N8tlooal Enrichment Facility level as well as minor administrative changes to the Materials License. Included in Enclosure 2 are the interim controls to be implemented to ensure segregation between LEU+ approved systems and components and the recycling systems which will not yet be approved for LEU+. contains the mark-up pages of the Safety Analysis Report (SAR), Enclosure 4 contains the mark-up pages of the Integrated Safety Analysis Summary (ISAS), Enclosure 5 contains a version of the ISAS with the changes incorporated into the document, Enclosures 6 and 7 provide the pages of the License Basis Documents proposed to be revised with the changes annotated on the pages and Enclosure 8 contains the environmental information discussion for this LAR.

UUSA respectfully requests the review and approval of this LAR by August 2024. UUSA appreciates the efforts of NRG staff in supporting this review and wishes to support the review by conducting post-submittal meetings with the staff to address any questions to assist in the review. Post-submittal meetings will be coordinated through the NRG Project Manager. If you have any questions regarding this LAR, you may contact Chris Schwarz, Licensing Manager, at 575-394-5783.

R"if.y,

Pa u l Lorskulsint Ch ief Nuclea r Officer

Enclosures : 1 ) Affidavit

2) Description of Proposed Changes for Increased Enrichment Production (LAR 23-02)

3) Mark-up Pages to the Safety Analysis Report

4) Mark-up Pages to the Integrated Safety Analysis Summary

5) Integrated Safety Analysis Summary with changes incorporated

6) Mark-up Pages to the Fundamental Nuclear Material Control Program

7) Mark-up Pages to the Emergency Plan

8) Environmental Information

Enclosures 2, 4, 5, 6 and 7 transmitted by this letter contain Proprietary and/or Security-Related information. When detached, this letter is decontrolled.

Louisiana Energy Servic es, LLC UUSA I P.O. Box 1789 I Eunice I New Mex ico I 88231 I USA T : +1 (575) 394 4646 I W : www.uusa.urenco.com

© 2023 Louisiana Energy Services, LLC LES-23-130-NRC Security Related Information Withhold under 10 CFR 2.390 USA The National Enrichment Facility

cc: via email

Shana Helton, Director, Division of Fuel Management U.S. Nuclear Regulatory Commission Shana. Helton @ nr c.gov

Anthony Masters, Director, Division of Fuel Facility Inspection U.S. Nuclear Regulatory Commission Anthony.Masters@nrc.gov

Samantha Lav, Branch Chief Fuel Facility Licensing U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Samantha. Lav@nrc.gov

Robert Mathis, Projects Branch 1, Chief U.S. Nuclear Regulatory Commission Robert. Math is@nrc.gov

Johnathan Rowley, Project Manager U.S. Nuclear Regulatory Commission Johnathan.Row ley@ nr c.gov

Enclosures 2, 4, 5, 6 and 7 transmitted by this letter contain Proprietary and/or Security-Related information. When detached, this letter is decontrolled.

Louisiana Energy Services, LLC UUSA I P.O. Box 1789 I Eunice I New Mexico I 88231 I USA T : +1 (575) 394 4646 I W: www.uusa.urenco.com

© 2023 Louisiana Energy Services, LLC