ML24254A206
| ML24254A206 | |
| Person / Time | |
|---|---|
| Site: | 07007004 |
| Issue date: | 09/10/2024 |
| From: | NRC/NMSS/DREFS/EPMB2 |
| To: | |
| References | |
| Download: ML24254A206 (21) | |
Text
ML24254A206 Environmental Assessment for Proposed License Amendment to Increase Possession Limits for Licensed Material for the HALEU Program at the American Centrifuge Plant, Piketon, Ohio Docket No. 70-7004 License No. SNM-2011 September 2024 Office of Nuclear Material Safety and Safeguards
iii CONTENTS Figures......................................................................................................................................... iv Tables.......................................................................................................................................... iv Abbreviations and Acronyms........................................................................................................ v
1.0 INTRODUCTION
................................................................................................................. 1 1.1 Proposed Action.......................................................................................................... 1 1.2 Purpose of and Need for the Proposed Action............................................................ 1 1.3 Background................................................................................................................. 2 1.4 Scope of the Environmental Analysis.......................................................................... 2 1.5 Potential Future Actions.............................................................................................. 3 2.0 PROPOSED ACTION AND ALTERNATIVE....................................................................... 3 2.1 Proposed Action and Current Operations................................................................... 3 2.2 No Action Alternative................................................................................................... 4 3.0 AFFECTED ENVIRONMENT AND POTENTIAL IMPACTS................................................ 5 3.1 Description of DOE Site and Surrounding Area.......................................................... 5 3.2 Potential Environmental Impacts................................................................................. 8 3.2.1 Resources Not Affected by the Proposed Action............................................ 8 3.2.2 Resources Affected by the Proposed Action................................................... 9 3.3 Cumulative Effects.................................................................................................... 12 4.0 AGENCIES AND PERSONS CONSULTED...................................................................... 13
5.0 CONCLUSION
AND FINDING OF NO SIGNIFICANT IMPACT........................................ 14
6.0 REFERENCES
.................................................................................................................. 15
iv FIGURES Figure 3-1 Location of the DOE Reservation.............................................................................. 6 Figure 3-2 DOE Reservation - ACP/HALEU facilities in blue and green.................................... 7 TABLES Table 3-1 Comparison of Impacts of the Proposed Action to Impacts in the NRCs 2021 EA for HALEU Enrichment Activities................................................................................. 8 Table 4-1 Listed Species Potentially Present in the Area of the HALEU Cascade.................... 14
v ABBREVIATIONS AND ACRONYMS ACO American Centrifuge Operating, LLC ACP American Centrifuge Plant ADAMS Agency-wide Documents Access and Management System CFR Code of Federal Regulations DOE U.S. Department of Energy EA environmental assessment EIS environmental impact statement EPA U.S. Environmental Protection Agency ER environmental report ESA Endangered Species Act FWS U.S. Fish and Wildlife Service ha hectare(s)
HALEU high-assay low-enriched uranium HF hydrogen fluoride IPaC Information for Planning and Consultation ISA Integrated Safety Analysis kg kilogram km kilometers LAR License Amendment Request LCF Lead Cascade Facility LEU low-enriched uranium NAAQS National Ambient Air Quality Standards NEPA National Environmental Policy Act NHPA National Historic Preservation Act NMSS Office of Nuclear Material Safety and Safeguards NRC U.S. Nuclear Regulatory Commission ODH Ohio Department of Health OH SHPO Ohio State Historic Preservation Office OSHA Occupational Safety and Health Administration SER Safety Evaluation Report SNM special nuclear material UF6 uranium hexafluoride U-235 uranium-235 USEC United States Enrichment Corporation, Inc.
1
1.0 INTRODUCTION
On February 13, 2023, American Centrifuge Operating, LLC (ACO or the licensee) submitted a request to the U.S. Nuclear Regulatory Commission (NRC) for an amendment to Special Nuclear Materials License SNM-2011 (ACO 2023a) for the high-assay, low-enriched uranium (HALEU) operations program being conducted at the American Centrifuge Plant (ACP). If approved, this amendment would increase ACOs licensed material possession limits. This increase would support production of HALEU in the form of uranium hexafluoride (UF6) up to approximately 1,400 kilograms (kg). The NRC accepted the application for detailed technical review on April 13, 2023 (NRC 2023a).1 ACO is producing and storing HALEU for the U.S. Department of Energy (DOE) at the ACP.
HALEU is uranium that has been enriched so that the concentration of the fissile isotope uranium-235 (U-235) is between 5 and 20 percent of the mass of the uranium. The DOE has established a 3-phase contract with ACO to deploy a cascade of 16 operating centrifuges and two spare centrifuges to demonstrate the capability to enrich uranium to the necessary higher level. The NRC initially approved the license amendment for the operation of this cascade in June 2021 (NRC 2021a). The current ACO request to increase the possession limits of licensed material would continue to utilize the 16-centrifuge HALEU cascade. The current Phase 2 of the contract, under which DOE provides funding, will expire on December 31, 2024. Phase 3, involving up to three, 3-year periods of operation of the HALEU cascade, would need Congressional appropriations and the NRCs approval to move forward.
1.1 Proposed Action The proposed action is to increase the authorized limits for possession of licensed material (uranium) to support HALEU production for the life of the HALEU demonstration and operations program. The amendment would change the licensed material possession limits from the currently approved values to those needed to produce approximately 1,400 kg HALEU and would be effective until DOEs contract with ACO expires. ACO operates the HALEU demonstration cascade in the X-3001 building of the former Lead Cascade Facility (LCF), which was decommissioned in 2018. ACO does not propose to construct new buildings, conduct ground-disturbing activities, ship HALEU offsite, or make changes to the HALEU centrifuge cascade design that the NRC approved on June 11, 2021 (ACO 2023a).
1.2 Purpose of and Need for the Proposed Action The purpose of the proposed action is to allow ACO to continue demonstrating the capability to enrich U-235 up to a level necessary to produce HALEU. ACO is under contract with DOE to enrich uranium and produce HALEU using the 16-centrifuge enrichment cascade constructed for this purpose.
1 The NRC requested additional information and ACO submitted a response to that request on June 29, 2023 (ACO 2023b). The response provides a basis for ACOs position that an emergency plan is not required for the proposed production of approximately 1,400 kg of HALEU in the form of UF6.
2
1.3 Background
The HALEU cascade is situated within the building that formerly housed the LCF, which was decommissioned in 2018. The purpose of the LCF was to demonstrate centrifuge and cascade operation and obtain performance data. No product was withdrawn from the LCF cascade for commercial purposes. The buildings that housed the former LCF lie completely within the commercial ACP site.
The licensing of the ACP was initiated by USEC, Inc. (USEC), which later became Centrus Energy Corp (Centrus). The license was transferred to and is now maintained by ACO, a subsidiary of Centrus. ACO has two licenses, license SNM-7003 for the former LCF (and applicable to the LCF building that houses the HALEU cascade) and license SNM-2011 for the ACP under which HALEU operations are being conducted. The NRCs 2021 environmental assessment (EA) provides more detail about the history of uranium enrichment operations at the Piketon location (NRC 2021b).
The NRC approved a license amendment request for the HALEU cascade on June 11, 2021 (NRC 2021b). This amendment involved production of up to 600 kg of HALEU in the form of UF6. On April 28, 2022, ACO requested a license amendment to extend the NRCs authorization of the HALEU demonstration program. The NRCs license amendment approval was issued on August 11, 2022 (NRC 2022). On November 30, 2022, ACO requested the NRC to extend the authorization for HALEU operations to the end of 2024. The NRC approved this request on March 30, 2023 (NRC 2023b). The NRC conducted an operational readiness and management verification review (ORR) of the HALEU demonstration cascade and issued a letter dated June 12, 2023, authorizing ACO to enrich U-235 in the HALEU cascade to the Category III limits, which are defined in Title 10 of the Code of Federal Regulations (10 CFR) Section 70.4 as special nuclear material of low strategic significance (NRC 2023c). The NRC conducted a second ORR to determine whether to issue ACOs authorization for enriching uranium at the Category II levels, which are defined in 10 CFR 70.4 as special nuclear material of moderate strategic significance. On September 21, 2023, the NRC authorized enrichment at the Category II levels (NRC 2023d). ACO began operating the HALEU cascade in August of 2023 (ACO 2024).
1.4 Scope of the Environmental Analysis The NRC staff has evaluated the potential environmental impacts of the proposed action to amend License SNM-2011 and of the no-action alternative, as described in this EA. The NRC staff performed this review in accordance with the requirements in 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, and staff guidance in NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs (NRC 2003). To develop this EA, the NRC staff reviewed information in ACOs license amendment request (ACO 2023a), in the NRCs 2021 EA for the HALEU cascade demonstration license amendment (NRC 2021b), and previous licensing documents for the ACP.
NRCs 2021 EA for the HALEU License Amendment Request The NRCs 2021 EA included reviews of the safety evaluations and EAs for previous licensing actions associated with the American Centrifuge Plant and the former LCF. The NRCs 2021
3 HALEU EA assessed the impacts of a license amendment to increase the U-235 enrichment limit to 25 percent2 from the previous limit of less than 10 percent, to allow ACO to demonstrate the capability to enrich U-235 to the level necessary to produce HALEU to an enrichment of 19.75 percent so that ACO could produce up to 600 kg of HALEU UF6. The EA assessed the impacts of assembling and operating the HALEU cascade in an existing building used previously as part of the LCF. The EA evaluated whether operation of the HALEU cascade would result in any new and significant environmental impacts not previously evaluated in the NRCs environmental reviews for the ACP (NRC 2006) and the LCF (NRC 2004).
Section 3 of this EA identifies potential environmental impacts for the proposed increase in possession limits to support production of approximately 1,400 kg HALEU UF6. Table 3-1 summarizes the impacts determined during the current and 2021 environmental reviews. In this EA, the NRC staff evaluates whether the increase in possession limits would result in any new or additional environmental impacts that were not analyzed in the 2021 EA or in previous reviews. As explained in section 3 of this EA, the NRC staff determined that the proposed increase in possession limits would not result in changes to or effects on land use, socioeconomic conditions, geologic and soil resources, ecological resources, noise receptors, visual or scenic resources, soils, groundwater, surface water, or public health. This EA, therefore, assesses the potential impacts of the proposed action on occupational health, air quality, transportation, and waste management.
1.5 Potential Future Actions ACO has stated that it may submit one or more license amendment requests for authorization to operate the HALEU cascade for up to 10 years (ACO 2023a). The NRCs 2021 EA included a general assessment of the impacts of continuing to operate for 10 years beyond 2022.
However, any future license amendment requests to extend HALEU operations, including an application for an additional 10 years, would require a separate NRC licensing and environmental review.
2.0 PROPOSED ACTION AND ALTERNATIVE This section describes the proposed action, the current HALEU operations, and the ACO site within the DOE reservation. This section also describes the no action alternative, which is denial of the license amendment.
2.1 Proposed Action and Current Operations 2.1.1 Proposed Action The proposed action is to increase the authorized limits for possession of licensed material to support production of approximately 1,400 kg HALEU UF6. The amendment would change the possession limits that support production of approximately 600 kg to 1,400 kg to support HALEU 2 Although ACOs product is enriched to 19.75 percent U-235, the NRCs 2021 authorization allows for enrichment up to 25 percent to account for in-process fluctuations that may result in small amounts of uranium with enrichments of between 20 and 25 percent by weight of U-235 (NRC 2021a).
4 demonstration operations until DOEs contract with ACO expires. The current expiration date of the contract is December 31, 2024. ACO does not propose to construct new buildings, conduct other ground-disturbing activities, or make changes to the HALEU centrifuge cascade design that the NRC approved on June 11, 2021, in license amendment 13 (ACO 2023a).
2.1.2 HALEU Operations Site The site of HALEU cascade activities is about 2200 feet (670 meters [m]) from the nearest member of the public (permanent residence) (NRC 2021b). ACO employs approximately 130 people at the Piketon location (NRC 2024a). HALEU enrichment activities occur in a portion of Building X-3001, an approximately 28,242 square meter (303,994 square feet) building leased from DOE. Building X-3001 and the other buildings leased from DOE provide process and administrative support; centrifuge training and testing; centrifuge storage, handling, and assembly; and transporter storage and maintenance. An enclosed transfer corridor is used to move the centrifuges between the process and testing buildings. These facilities compose approximately 10 percent of the 200-acre (ac) (81-hectare [ha]) ACP site. Section 3.1 describes the DOE reservation and surrounding area.
2.1.3 Uranium Enrichment Process for HALEU Uranium ore usually contains approximately 0.72 percent U-235. Enrichment increases the percentage of the naturally occurring and fissile U-235 isotope and decreases the percentage of U-238 (NRC 2006). ACOs enrichment operations at the former LCF and at the HALEU operation use gas centrifuge technology, which involves a series (cascade) of centrifuges that each contain a large rotating cylinder (rotor) and piping to feed UF6 gas into the centrifuge. After being processed through a cascade of centrifuges, separate enriched and depleted UF6 gas streams are withdrawn. The UF6 feed to the HALEU cascade is low enriched uranium (LEU)3 UF6 with an enrichment of less than or equal to 5 percent U-235. This LEU feed material is shipped in approved U.S. origin 30-B series cylinders that have a 2.5-ton capacity. Both product and tails materials are owned by DOE. ACO stores the materials at the Piketon site for DOE until the materials can be removed. Product material is stored in 5-series cylinders and the tails material is stored in 12-series cylinders (NRC 2021b). Section 1.4 of the NRCs 2021 EA describes the enrichment process in further detail.
2.2 No Action Alternative The alternative considered in this EA is the no-action alternative. Under the no-action alternative, the NRC would deny ACOs request, and ACOs HALEU production and possession limits would remain as currently approved. The no-action alternative would not meet the terms of DOEs contract with ACO. The potential environmental impacts of denying the request would be unchanged from the impacts as assessed in the NRCs 2021 HALEU cascade EA. The no-action alternative is not addressed further in this EA.
3 LEU is fuel in which the weight percent of U-235 in the uranium is less than 20 percent.
5 3.0 AFFECTED ENVIRONMENT AND POTENTIAL IMPACTS This section describes the ACO site, the surrounding DOE reservation, and general area in which the site is located. This section also describes the potential impacts of the proposed increase in possession limits.
3.1 Description of DOE Site and Surrounding Area The ACP site is leased from the DOE and lies within the 3,700 ac (1,500 ha) DOE Gaseous Diffusion Plant reservation (DOE reservation), a developed industrial site. The site is identified by signs and fencing; gates are in place where public roads cross the site boundary. The area is largely treeless; grass and paved roadways cover most of the open space (NRC 2021b).
Although several environmentally sensitive areas lie within the larger DOE site, the areas where the HALEU cascade operates are inside existing concrete-floored facilities previously used for the LCF process operations and are not near these environmentally sensitive areas (NRC 2021b).
The DOE reservation is in Pike County, Ohio, a rural, sparsely populated area in south-central Ohio. The nearest residential center, Piketon, lies about 6 kilometers (km) (4 miles [mi]) north of the site on U.S. Route 23 (see figure 3-1). Waverly, the largest town in Pike County, is located approximately 13 km (8 mi) north of the site. The largest cities within a 50 mi radius of the DOE reservation are Portsmouth, Ohio, (approximately 33 km [20 mi] to the south) and Chillicothe, Ohio (approximately 43 km [27 mi] to the north) (NRC 2021b).
6 Figure 3-1 Location of the DOE Reservation (from ACO 2020)
7 Figure 3-2 DOE Reservation - ACP/HALEU facilities in blue and green (modified from ACO 2020)
8 3.2 Potential Environmental Impacts This section presents the NRC staffs evaluation of the potential environmental impacts on certain resource areas from the proposed increase in possession limits for continued operation of the HALEU cascade. The NRC staff reviewed the EA for the 2021 license amendment that authorized the HALEU demonstration program. Table 3-1 summarizes the impact determinations in the 2021 EA (NRC 2021b) and for the proposed action evaluated in this EA.
Section 3.2.1 explains why certain resource areas would not be affected by the proposed action.
Section 3.2.2 describes the potential impacts on air quality, transportation, occupational health, and waste management. Section 3.2.3 describes the potential cumulative effects.
Table 3-1 Comparison of Impacts of the Proposed Action to Impacts in the NRCs 2021 EA for HALEU Enrichment Activities Resource 2021 HALEU Demonstration EA Increased Possession Limits (this EA)
Land Use No Impact No impact Historic and Cultural No Impact No impact Visual and Scenic No Impact No impact Climate No impact No impact Air Quality Not Significant Not significant - see section 3.2.2.1 Geology and Soils No Impact No impact Water Resources No Impact No impact Ecological Resources No Impact No impact Socioeconomics Not Significant No impact Environmental Justice Not Significant No impact Noise No Impact No impact Transportation Not Significant Not significant - see section 3.2.2.4 Public Health and Safety Not significant No impact Occupational Health and Safety Not Significant Not significant - see section 3.2.2.2 Waste Management Not Significant Not significant - see section 3.2.2.3 Cumulative effects Not Significant Not significant - see section 3.3 3.2.1 Resources Not Affected by the Proposed Action As shown in table 3-1, the proposed increase in the possession limits would not affect several resource areas. This is because the only change to currently licensed activities would be the continued production of HALEU until the possession limits for licensed material are reached.
ACO would not make changes to enrichment processes or to the outside portions of buildings.
All HALEU produced to this limit would be stored onsite. All enrichment activities would continue to take place indoors, resulting in no changes to noise levels assessed in the 2021 EA. Because operations would continue entirely inside buildings, including storage of additional enriched UF6 and wastes, and because the current rate of HALEU production would not change, there would be no change to potential impacts on public health and safety. Because no additional
9 employees would be required for the proposed action, there would be no change to socioeconomic impacts assessed in the 2021 EA.
3.2.2 Resources Affected by the Proposed Action 3.2.2.1 Air Quality Air quality in Pike County is in attainment for the six National Ambient Air Quality Standards criteria pollutants (OEPA 2024). The area where the HALEU cascade operates is inside existing concrete floor buildings enclosed with fencing and gates. The major nonradiological hazardous air emissions associated with the HALEU cascade are from hydrogen fluoride (HF)4. As described in the NRCs 2021 EA, the HALEU cascade operations may result in a slight increase in HF concentrations and a slight increase in diesel emissions from standby electrical generators. For the 2021 EA, the annual average HF concentration for the HALEU cascade was calculated to be 0.00227 micrograms per cubic meter (m3) at the location of the maximally exposed individual. ACO reported that, based on calculations for the period between July and December 2023, the average HF concentration for the maximally exposed individual was 4.8 x 10-9 micrograms/m3 (NRC 2024a). The Occupational Safety and Health Administration (OSHA) has established an 8-hour permissible exposure limit for HF of 2000 micrograms per m3 (OSHA 2024). The exposure would not exceed this level because the production rate under the proposed action would not be affected (NRC 2024a). As stated in the 2021 EA, diesel generators would be used in the unlikely event of a power failure, and ACO estimated it would operate the diesel generators for no more than 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> per year for the HALEU cascade. The increase in possession limits would not affect this estimate. Based on the limited nature of the proposed action and the minimal effect it would have on emissions of HF and diesel as compared with the rates in the 2021 EA, the NRC staff concludes that the nonradiological air emissions impacts of the proposed license amendment would not be significant.
DOEs environmental radiological monitoring program includes the collection of air samples and air modeling to detect releases of radionuclides (NRC 2021b). As described in the 2021 EA, operation of the HALEU cascade results in amounts of radiological air emissions and doses similar to but smaller than those evaluated for the LCF, because the HALEU cascade uses a substantially smaller number of centrifuges of the same design as those used in the LCF. For the period of July 1 through December 31, 2023, ACO reports that air emissions of uranium isotopes from the HALEU process building (X-3001 building) vents were 0.0024 millicuries (U-234), 0.000475 millicuries (U-235), and 0.000745 millicuries (U-238) (ACO 2024). The increase in possession limits would not affect the rate of production. The NRC concludes that the proposed action would not result in any greater radiological air emissions than those evaluated in the NRCs 2021 EA, which in turn concluded that air emissions would be less than those assessed for the LCF (NRC 2021b). Based on the 2021 EA, the emissions ACO reported for 2023, and minor difference the proposed action would have in daily HALEU operations, the NRC staff has determined that the radiological air emissions impacts from the increase in possession limits would not be significant.
4 HF is a byproduct of the enrichment process that uses fluorine and LEU to produce HALEU UF6.
10 3.2.2.2 Occupational Health and Safety This section describes any potential radiological and nonradiological impacts on worker health and safety that could result from the proposed increase in possession limits.
Nonradiological Impacts For operation of the HALEU cascade, environmental monitoring of chemical parameters is required by State and Federal regulation and/or permits. Exposures to chemical agents is limited by administrative and engineering methods or personal protective equipment. Extremely hazardous substances, such as fluorine or HF, are stored and used in accordance with State regulations and permits. ACO takes precautions to avoid impacts from accidental discharges of fuel, waste, and sewage. These precautions, including the use of spill response plans, safety procedures, spill controls, countermeasure plans, and spill response equipment in accordance with Federal and State laws, minimize the likelihood and severity of potential impacts from accidental discharges (NRC 2021b). As described in section 3.2.2.1 of this EA, offsite concentrations from projected airborne releases are very small and thus are unlikely to affect the general public. HF emissions resulting from the proposed increase in possession limits would likely not be detectably different from the current HF emissions. The NRC staff concludes that the potential nonradiological impacts on workers from the proposed increase in possession limits would not be significant.
Radiological Impacts As described in the NRCs 2021 EA, HALEU enrichment activities must comply with NRC regulations and conditions specified in the license, including 10 CFR Part 20, Subpart C, Occupational Dose Limits for Adults, and 10 CFR Part 20, Subpart D, Radiation Dose Limits for Individual Members of the Public. In that EA, the NRC concluded that operation of the HALEU cascade would not result in radiological impacts that would be any greater than those evaluated in the LCF EA (NRC 2021b) and that the radiological impacts from the HALEU cascade amendment would not be significant. ACO began operating the HALEU cascade in August 2023 and submitted an effluent monitoring report for the period of July 1 through December 31, 2023. The report stated that the ACO's total exposure to the nearest resident for that period was 3.49 x 10-06 millirem (ACO 2024). Based on the report, the NRC staff concludes that potential offsite doses are well within the dose limits in 10 CFR Part 20 for workers (50 mSv/yr or 5000 mrem/yr) and members of the public (1 mSv/yr or 100 mrem/yr). The increase in possession limits would not result in a change to operations. As such, the NRC staff concludes that the radiological impacts on workers from activities associated directly with the possession limit increase amendment would not be noticeably different from the impacts of HALEU operation generally, as assessed in the NRCs 2021 EA, and thus would not be significant.
Impacts from Accidents As discussed in more detail in the NRCs 2021 EA for the HALEU demonstration program, NRC regulations governing materials licensees authorized to possess a critical mass of special nuclear material are designed to ensure that any high-and intermediate-consequence accident sequences would be highly unlikely and unlikely, respectively. ACO was required to develop and maintain as a living document an integrated safety analysis (ISA) for the ACP, which it
11 updated for the HALEU cascade, to demonstrate compliance on a continuous basis with the performance requirements in 10 CFR 70.61 to limit the risk of credible high-and intermediate-consequence accident sequences, including nuclear criticality accidents (NRC 2021b).
During its safety review for the 2021 HALEU cascade license amendment and updated ISA summary, the NRC staff did not identify any new types of accident sequences or increases in the likelihood or consequences beyond what was evaluated for the ACP (NRC 2021b). For the proposed increase in the possession limits to support production of approximately 1,400 kg of HALEU UF6, ACO states that the change would not create new types of accident sequences that, unless mitigated or prevented, would exceed the performance requirements of 10 CFR 70.61 and that have not been described in the ISA Summary (ACO 2023). Therefore, the NRC staff concludes that the proposed amendment would not create a new or different type of accident or increase the risk of any accident previously evaluated.
3.2.2.3 Waste Management The NRCs 2021 EA described the potential waste streams from construction and operation of the HALEU cascade for production of up to 600 kg of HALEU, including low-level radioactive waste, low-level mixed waste, Resource Conservation and Recovery Act hazardous waste, sanitary/industrial waste, recyclable waste, and classified/sensitive waste. Onsite sanitary wastewater is treated by a DOE contractor at the DOE Reservation and other wastes are managed using existing DOE sitewide services. DOE is also responsible for the management and disposal of low-level radioactive waste (LLW) from the HALEU cascade operation. Waste is collected, packaged, and segregated for off-reservation disposal or treatment in accordance with applicable State and Federal regulations (NRC 2021b).
The proposed amendment to increase the possession limits would not change HALEU production operations (ACO 2023a), except to insignificantly increase the amount of waste produced. Specifically, ACO estimates 400 cubic feet of LLW to be generated per quarter until December 31, 2024. The NRCs 2021 HALEU EA concluded that the waste types and amounts generated from the HALEU cascade operation would be the same as those generated during LCF operation and as assessed in the LCF EA (NRC 2021b). The NRC staff concludes that this also applies to the impacts of waste management during continued operation of the HALEU cascade with the increased possession limits. Waste would continue to be stored onsite or managed by a DOE contractor. Therefore, the NRC staff concludes that the impacts of waste management associated with the proposed license amendment would not be significant and are bounded by the impacts assessed in the NRCs 2021 EA.
3.2.2.4 Transportation Two major highways serve the DOE site: U.S. Route 23 runs north-south and State Route (SR) 32/124 runs east-west. The site is 5.6 km (3.5 mi) from the intersection of U.S. Route 23 and Ohio SR 32 interchange. Access from the site to U.S. Route 23 is via a four-lane interchange road that is closed to the public. U.S. Route 23 intersects Interstate (I)-270, I-70, and I-71 approximately 113 km (70 mi) north of the site (NRC 2021b).
The only shipments that may occur as a result of the proposed increase in the possession limits would be the additional shipment of feed material needed to support the production of 1,400 kg
12 HALEU. In the 2021 HALEU cascade EA, the NRC staff summarized the assessments in the LCF EA (NRC 2004) and ACP EIS (NRC 2006) of potential transportation impacts. These assessments considered the impacts of construction and operation of the LCF and a full commercial facility (the ACP), respectively. The 2021 EA stated that the potential transportation impacts during operation of the HALEU cascade would be from feed shipments in U.S. origin 30-B series cylinders with a 2.5-ton capacity. For the HALEU cascade, ACO receives a very small fraction of the estimated 1,100 yearly feed shipments for the commercial ACP. As such, the NRC staff determined in section 4.3 of the 2021 EA that operation of the HALEU cascade would not have significant transportation impacts related to feed shipments (NRC 2021b). The 2021 EA also stated that, for the potential license amendment request for operation of the HALEU cascade for another 10 years, three additional shipments of feed material per year would be necessary to meet the expected level of production and that these additional shipments would not result in significant impacts. Likewise, an additional few shipments of feed material that would be needed to support an increased production of HALEU through December 2024 would not result in a noticeable transportation impact and would be significantly fewer than the 1,100 yearly shipments estimated for the commercial ACP. Therefore, the NRC staff concludes that the transportation impacts of the proposed increase in possession limits would not be significant and are bounded by the impacts assessed in the 2021 HALEU cascade EA.
3.3 Cumulative Effects The NRCs 2021 EA evaluated the cumulative effects associated with the proposed construction and operation of the HALEU cascade. Specifically, the EA assessed whether cumulative environmental effects could result from the incremental impact of the HALEU cascade when added to the past, present, or reasonably foreseeable actions in the area. Because the cascade operates on the ACP site within DOEs reservation, the other actions the NRC staff assessed principally included the former LCF and the ACP construction and operations. The 2021 EA found that the construction and operation of the HALEU cascade would not have a significant incremental impact and, when added to the effects of other past, present, or reasonably foreseeable actions, would not result in significant cumulative effects except for a potential increase in air emissions (e.g., dust and heavy equipment emissions) during construction of the full ACP, if built. As stated in the 2021 EA, ACO expects to apply for authorization to extend operation of the HALEU cascade for a period of up to 10 years. The purpose of this extension would be to continue to produce HALEU fuel for DOE in preparation for potential future commercial sales and use.
The proposed action assessed in this EA is limited to allowing ACO to possess and use licensed material that supports production of approximately 1,400 kg of HALEU, which would be produced and stored onsite. This action would result in a small increase in the amount of waste to be managed. The NRC staff has determined that the incremental effects of this proposed possession limit increase would be so minor as to not change the cumulative effects conclusions presented in the NRCs 2021 EA. Therefore, the NRC staff concludes that the cumulative effects analysis presented in the 2021 EA is bounding for the proposed action assessed in this EA.
13 4.0 AGENCIES AND PERSONS CONSULTED Agency Review The NRC staff provided the draft EA to the Ohio Department of Health, Ohio Emergency Management Agency, and Ohio Environmental Protection Agency, as well as the U.S.
Environmental Protection Agencys Region 5 for review comment (NRC 2024b and 2024c, respectively). All agencies responded that they had no comments on the draft EA (OEMA 2024, OEPA 2024, ODH 2024, USEPA 2024).
National Historic Preservation Act Section 106 of the National Historic Preservation Act (NHPA) requires Federal agencies to consider the effects of their undertakings on historic properties. NHPA implementing regulations at Title 36 of the Code of Federal Regulations (36 CFR) Part 800, Protection of Historic Properties, define an undertaking as a project, activity, or program funded in whole or in part under the direct or indirect jurisdiction of a federal agency, including those carried out by or on behalf of a federal agency; those carried out with federal financial assistance; and those requiring a federal permit, license, or approval. The NRCs approval of the proposed increase in the possession limits would be a Federal undertaking. After reviewing ACOs application, the NRC staff determined the proposed increase in the possession limits would not result in ground-disturbing activities and is therefore not a type of activity that has the potential cause effects on any historic properties that may be present. Therefore, in accordance with 36 CFR 800.3(a)(1),
the NRC has no further obligation under Section 106 of the NHPA. The NRC provided a courtesy notification of this proposed undertaking to the Ohio State Historic Preservation Office (NRC 2024d).
The Endangered Species Act Section 7 of the Endangered Species Act (ESA) requires that, prior to taking a proposed action, Federal agencies determine (1) whether endangered and threatened species or their critical habitats are known to be in the vicinity of the proposed action, and, if so, (2) whether the proposed Federal action may affect listed species or critical habitats. If the proposed action may affect listed species, Federal agencies must consult with the U.S. Fish and Wildlife Service (FWS) and/or the U.S. National Marine Fisheries Service. The NRC staff obtained an official species list from the FWSs Information for Planning and Consultation (FWS 2024). Table 4-1 lists species that may be present in the area of the proposed action (on the DOE reservation).
14 Table 4-1 Listed Species Potentially Present in the Area of the HALEU Cascade Category Name Status Mammals Northern Long-eared Bat (Myotis septentrionalis)
Endangered Indiana Bat (Myotis sodalis)
Endangered Tricolored Bat (Perimyotis subflavus)
Proposed endangered Clams Rayed Bean (Villosa fabalis)
Endangered Salamander Mussel (Simpsonaias ambigua)
Proposed endangered Insects Monarch Butterfly (Danaus Plexippus)
Candidate Critical habitats None As described in the NRCs 2021 HALEU EA, previous environmental documents (2004 EA for the LCF facility construction and operation and 2018 EA for the LCF decommissioning) indicated that a favorable habitat does not exist on the DOE site for species of concern (NRC 2021b). The proposed action assessed in this EA (increase in the possession limits) would not result in construction activities or land disturbance and would allow a continuation of HALEU production activities that are already ongoing. Production and storage of HALEU occurs within existing buildings that formerly housed the LCF. Consistent with guidance in NUREG-1748, the NRC staff has determined that even if endangered or candidate species are present in the vicinity of the HALEU cascade building on the DOE reservation, the proposed increase in the possession limits would not affect such species or their habitats. Therefore, the NRC has determined that no further consultation is required under Section 7 of the ESA.
5.0 CONCLUSION
AND FINDING OF NO SIGNIFICANT IMPACT Based on its review of the proposed action and in accordance with the requirements of 10 CFR Part 51, the NRC staff has determined that amending License SNM-2011 to increase the possession limits of licensed material to support production and onsite storage of approximately 1,400 kg of HALEU UF6 would not significantly affect the quality of the human environment. As described in section 3 of this EA, approval of the proposed action would not result in new construction or ground disturbance, would not result in significant differences in the amounts of effluents or emissions generated, and would not significantly affect any resource area. The production of HALEU UF6 would continue in the HALEU operations building (building X-3001),
and the storage would continue onsite. The NRC staff determined that the preparation of an EIS is not required for the proposed action. Therefore, under 10 CFR 51.32, a finding of no significant impact is appropriate.
15
6.0 REFERENCES
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10 CFR Part 51. Title 10 of the Code of Federal Regulations, Energy, Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions. U.S. Nuclear Regulatory Commission, Washington, D.C.
10 CFR Part 70. Title 10 of the Code of Federal Regulations, Energy, Part 70, Domestic Licensing of Special Nuclear Material. U.S. Nuclear Regulatory Commission, Washington, D.C.
36 CFR Part 800. Title 36 of the Code of Federal Regulations, Parks, Forests, and Public Property, Part 800, Protection of Historic Properties. Advisory Council on Historic Preservation, Washington, D.C.
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ACO (American Centrifuge Operating, LLC). 2023a. License Amendment Request for American Centrifuge Operating, LLC's License Application for the American Centrifuge Plant. Piketon, OH. February 13, 2023. ML23047A046.
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§ 4321 et seq.
16 National Historic Preservation Act of 1966, as amended (NHPA). Public Law 102-575; 16 U.S.C. 470.
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NRC (U.S. Nuclear Regulatory Commission). 2021a. Centrus Energy Corp., American Centrifuge Operating - License Amendment 13 - Approval to Operate Sixteen Centrifuges to Demonstrate Production of High-Assay Low-Enriched Uranium In Piketon, Ohio Until May 31, 2022 (EPID L-2020-LLA-0085). Washington, D.C. June 11, 2021. ML21138A826.
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NRC (U.S. Nuclear Regulatory Commission). 2022. NRC Approval of ACOs Request to Extend the HALEU Demonstration Program Authorization Expiration Date by 6 Months. August 11, 2022. ML22208A057.
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NRC (U.S. Nuclear Regulatory Commission). 2023b. Amendment 20 to SNM-2011, Approval of American Centrifuge Operatings Request to Extend the Nuclear Regulatory Commissions High Assay Low-Enriched Uranium Program Authorization Expiration Date (EPID L-2022-LLA-0178).
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