ML24331A260

Environmental Assessment for Proposed License Amendment to Allow Urenco USA to Enrich Uranium to Less than 10 Weight Percent U-235, Lea County, New Mexico

ML24331A260
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Site:	07003103
Issue date:	12/02/2024
From:	NRC/NMSS/DREFS/EPMB2
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Download: ML24331A260 (26)

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Environmental Center of Expertise Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards ML24331A260 Environmental Assessment for Proposed License Amendment to Allow Urenco USA to Enrich Uranium to Less than 10 Weight Percent U-235, Lea County, New Mexico December 2024 Docket Number: 70-3103 License Number: SNM-2010

iii CONTENTS ABBREVIATIONS AND ACRONYMS.......................................................................................... iv 1

INTRODUCTION................................................................................................................. 5 1.1 Proposed Action.......................................................................................................... 5 1.2 Purpose of and Need for the Proposed Action............................................................ 5 1.3 Background................................................................................................................. 5 1.4 Scope of the Environmental Analysis.......................................................................... 6 1.5 Foreseeable Future Licensing Actions........................................................................ 6 1.5.1 Use of Recycling Systems for LEU+................................................................ 6 1.5.2 Further Enrichment.......................................................................................... 7 2

PROPOSED ACTION AND ALTERNATIVE....................................................................... 7 2.1 Proposed Action.......................................................................................................... 7 2.2 No Action Alternative................................................................................................... 8 3

AFFECTED ENVIRONMENT AND ENVIRONMENTAL IMPACTS..................................... 8 3.1 UUSA Site and Surrounding Area............................................................................... 9 3.2 Potential Environmental Impacts................................................................................. 9 3.2.1 Resources Not Affected by the Proposed Action.......................................... 12 3.2.2 Resources Potentially Affected by the Proposed Action............................... 12 4

AGENCIES AND PERSONS CONSULTED...................................................................... 21 4.1 Agency Review.......................................................................................................... 21 4.2 The National Historic Preservation Act...................................................................... 21 4.3 The Endangered Species Act.................................................................................... 21 5

CONCLUSION AND FINDING OF NO SIGNIFICANT IMPACT........................................ 22 6

LIST OF PREPARERS...................................................................................................... 23 7

REFERENCES.................................................................................................................. 24 FIGURES Figure 1 Location of the UUSA Facility................................................................................... 10 Figure 2 Layout and Construction Proposed for 2015 Expansion License Amendment......... 11 Figure 3 Current Layout of Facility.......................................................................................... 11 Figure 4 Transportation Routes Near the UUSA Facility........................................................ 20 TABLES Table 1 UUSA Occupational Total Effective Dose Equivalent for 2015-2023......................... 16

iv ABBREVIATIONS AND ACRONYMS ADAMS Agency-wide Documents Access and Management System ANSI American National Standards Institute CFR Code of Federal Regulations Ci curie EA environmental assessment ESA Endangered Species Act FWS U.S. Fish and Wildlife Service GEVS gaseous effluent vent system gram g

HALEU high assay low enriched uranium HF hydrogen fluoride IROFS items relied on for safety kg kilogram km kilometer lb pound LECTS liquid effluent collection and transfer system LES Louisiana Energy Services, LLC LEU low-enriched uranium m

meter mi mile mrem millirem mSv millisievert 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 OSHA Occupational Safety and Health Administration SER safety evaluation report SNM special nuclear material SWU separative work units TEDE Total Effective Dose Equivalent U

uranium UBC uranium byproduct cylinder UF6 uranium hexafluoride UUSA Urenco USA w/o weight percent

5 1

INTRODUCTION The U.S. Nuclear Regulatory Commission (NRC) staff has prepared this environmental assessment (EA) in response to a November 30, 2023, request by Louisiana Energy Services, LLC (LES) (doing business as Urenco USA [UUSA]) to amend Special Nuclear Material (SNM)

License SNM-2010 (UUSA 2023a) for UUSAs gas centrifuge uranium enrichment facility. The NRC accepted UUSAs application for detailed technical review on March 1, 2024 (NRC 2024a).

The NRC published a notice of hearing opportunity for this proposed action in the Federal Register on October 8, 2024 (89 FR 81579). If the NRC approves this request, the license amendment would increase the allowed enrichment of uranium-235 (U-235) from the current limit 5.5 weight percent U-235 (referred to as low-enriched uranium or LEU) to less than 10 weight percent U-235 (referred to as LEU+).

UUSA operates the enrichment facility near Eunice in Lea County, New Mexico. Under SNM-2010, issued under Title 10 of the Code of Federal Regulations (10 CFR) Part 70, Domestic Licensing of Special Nuclear Material, UUSA is authorized to receive, acquire, possess and transfer byproduct, source, and SNM as designated in the license (NRC 2023a).

The facility processes natural uranium hexafluoride (UF6) into enriched UF6 using gaseous diffusion technology. Enrichment is the process of increasing the concentration of the naturally occurring and fissionable U-235, as described further in section 2.1.

1.1 Proposed Action The NRCs proposed action is to amend UUSAs license to increase the enrichment limit for the production, storage, and handling of enriched UF6 from the current limit of 5.5 weight percent (w/o) U-235 to less than 10 w/o U-235 at the UUSA enrichment facility. The proposed amendment would also increase the possession limit of U-235 to up to 10.8 w/o U-235 in a limited quantity to allow for cascade process fluctuations, inefficiencies, and instrument tolerances during the enrichment process. When assayed, the enriched U-235 product would not exceed the proposed license limit of less than 10 w/o U-235. Section 2.1 describes the proposed action in further detail.

1.2 Purpose of and Need for the Proposed Action The purpose of the proposed amendment is for UUSA to produce enriched U-235 to support industry pursuit of the use of LEU+ in applications such as accident tolerant fuel and extended fuel cycle fuels. Domestic nuclear commercial reactor operators and designers are pursuing advancements in fuel and enrichment alongside the development of reactor designs that include increasing U-235 enrichment.

1.3 Background

The NRC issued the license to LES for the enrichment facility in 2006 for a thirty-year period, and enrichment operations began in June 2010. NUREG-1790, Environmental Impact Statement for the Proposed National Enrichment Facility in Lea County, New Mexico (NRC 2005), addressed the potential environmental impacts of construction, operation, and decommissioning of the proposed facility with the capacity to produce 3 million separative work units (SWU) per year. In 2012, the NRC extended the license expiration date to June 9, 2040 (NRC 2012). In 2015, UUSA requested authorization to expand the facility in part by increasing its capacity to produce enriched uranium from 3 million to 10 million SWU per year. The NRC

6 developed an EA to address the potential environmental impacts of this expansion (expansion EA) (NRC 2015). The expansion has been partially completed and the facility is currently operating at 4.3 million SWU/year-capacity. UUSA is currently authorized to enrich uranium up to 5.5 w/o U-235 (NRC 2020).

1.4 Scope of the Environmental Analysis The NRC staff has evaluated the potential environmental impacts of the proposed action to amend License SNM-2010 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 UUSAs license amendment request (UUSA 2023a), UUSAs responses to the NRCs request for additional information (UUSA 2024a), the NRCs 2005 environmental impact statement for the initial licensing of the facility (NRC 2005), and the NRCs 2015 EA for the facility expansion (NRC 2015), among others (see section 6 of this EA).

In this EA, the NRC staff evaluates whether the proposed increase in the allowed U-235 enrichment level would result in significant impacts or impacts that were not analyzed in the 2015 EA. As explained in section 3 of this EA, the NRC staff determined that the proposed increase in the enrichment limit would not result in changes to or effects on land use, geologic and soil resources, ecological resources, noise receptors, visual or scenic resources, soils, groundwater, or surface water because all enrichment activities would continue to occur indoors. There would be no changes to staffing that would affect socioeconomic aspects. This EA, therefore, assesses the potential impacts of the proposed action on air quality, public and occupational health and safety, waste management, and transportation. Because the impacts of the proposed action would not be significant in any of these areas, any contribution of these impacts on cumulative impacts would not be noticeable. Therefore, this EA does not include a cumulative impacts analysis.

This EA also includes general discussions, where applicable, of using the facilitys recycling systems to process LEU+. This activity would not be authorized under the proposed action assessed in this EA but may be authorized in a future licensing action, after a separate safety and environmental review. The NRC is including some discussion of the recycling systems in this EA for completeness. Section 1.5.1 below describes the recycling systems.

1.5 Foreseeable Future Licensing Actions The following sections describe connected and additional actions UUSA is proposing or planning.

1.5.1 Use of Recycling Systems for LEU+

UUSA has separately requested NRC approval for use of the existing effluent and recycling systems after demonstrating these systems are suitable for the LEU+ material (UUSA 2024b).

UUSA would operate the effluent and recycling and support systems with LEU+ enrichments in the same manner as these systems are currently operated with LEU. Components that are periodically removed from various enrichment process systems with LEU+ material would be decontaminated and recycled using the same chemicals and processes as are currently used for components and materials exposed to LEU. UUSA stated that a larger amount of depleted

7 UF6 would need to be hydrolyzed for down blending (dilution) of the liquid effluent to meet the safety limit for U-235 w/o concentration in the liquid waste storage tanks and containers. UUSA indicated that the following operations and activities would apply to the requested amendment to allow LEU+ to be processed through the facilitys recycling systems (UUSA 2024a):

Ventilated Room Operations Bulking of waste into 208-liter (55-gallon) waste drums Decontamination Workshop Multi-functional decontamination train Small component decontamination train Storage cabinets for UF6 sample bottles and flex hoses Liquid Effluent Collection and Transfer System Slab tanks, bulk storage tanks, and containers Solid Waste Collection Room 208-liter (55-gallon) waste drums storage Because use of these existing systems for LEU+ is a reasonably foreseeable action, this EA includes a general discussion of the potential impacts from that licensing action (see section 3).

The NRC staff will conduct a separate safety and environmental review to evaluate the effects of the recycling systems for that licensing action.

1.5.2 Further Enrichment UUSA has notified the NRC of its intent to request authorization to further raise the enrichment limit up to 20 w/o U-235. UUSA is identifying the necessary changes and modifications that would be needed to construct a new facility for this purpose (UUSA 2023b). Further information is not yet available regarding this UUSA-planned action.

2 PROPOSED ACTION AND ALTERNATIVE This section describes the proposed action, including current enrichment operations. This section also describes the no-action alternative, denial of the license amendment.

2.1 Proposed Action The proposed action is to authorize UUSA to produce, store, and handle enriched UF6 at an enrichment of less than 10 w/o U-235 at the UUSA enrichment facility. This would be an increase from the currently authorized limit of 5.5 w/o U-235. The proposed amendment would also increase the possession limit of U-235 to up to 10.8 w/o U-235 in a limited quantity to allow for cascade process fluctuations, inefficiencies, and instrument tolerances during the enrichment process. When assayed, the enriched U-235 product would not exceed the proposed license limit of less than 10 w/o U-235. Under the proposed action, UUSA would use the existing facilities and equipment. There would be no construction of new facilities or modifications to existing buildings. In addition, the amendment, if granted, would not allow the shipment or transportation of LEU+ product offsite (UUSA 2023a).

8 The proposed action is limited only to the processes, systems and components needed to produce, handle and store LEU+ at the UUSA site. Material and components exposed to LEU+

that are removed from production process systems authorized for LEU+ would not be processed through the facilitys recycling and waste systems as part of this action (see section 1.5.1). Instead, materials and components removed from the LEU+ production process would be segregated and stored in analyzed, onsite storage locations inside (UUSA 2023a).

The proposed action would apply to the use of the gaseous effluent vent system (GEVS). The GEVS is designed to collect potentially contaminated gaseous effluents and would be used in areas where LEU+ would be produced, handled and stored. The GEVS treats effluents through a filter system before releasing them to the atmosphere through a continuously-monitored vent stack.

LEU+ would be stored in 30B and 30B-10 product cylinders. UUSA has evaluated both types of product cylinders for use at enrichments up to 10 w/o U-235 and found that the cylinders would be suitable for the storage of LEU+, are compatible with the existing equipment configurations, and would not require changes to operational processes. Filled LEU+ cylinders would be stored inside the buildings and not on the outdoor storage pad (UUSA 2023a). Empty, clean 30B-10 cylinders could be stored on the outdoor storage pads. As part of this amendment request, UUSA is also requesting certain administrative changes to the license that relate primarily to the use and storage of the 30B and 30B-10 product cylinders for LEU+ (UUSA 2023a).

Gas Centrifuge Enrichment Process Enrichment is the process of increasing the concentration of the naturally occurring and fissionable U-235. In the gas centrifuge process, centrifuges spin gaseous UF6 at high speeds to separate the lighter U-235 atoms from the heavier uranium-238 (U-238) atoms. To obtain the desired concentration and sufficient volume of U-235 for commercial production, centrifuges are connected in series and parallel (NRC 2015). After enrichment, the uranium with a higher concentration of U-235 will be used at fuel fabrication facilities to manufacture fuel for nuclear reactors.

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 UUSAs request to allow increased enrichment to less than 10 w/o U-235, and the limit would remain at 5.5 w/o. The potential environmental impacts of denying the request would be unchanged from the current facility impacts, including the impacts as assessed in the NRCs 2015 expansion EA. Under this alternative, the nuclear industry would likely continue to pursue higher enriched UF6 for power reactors, and the increased enrichment would most likely be produced at another facility, resulting in similar environmental impacts. The no-action alternative is not addressed further in this EA.

3 AFFECTED ENVIRONMENT AND ENVIRONMENTAL IMPACTS This section describes the UUSA site and the general area in which the site is located. This section also describes the potential impacts of the proposed license amendment to allow increased enrichment.

9 3.1 UUSA Site and Surrounding Area The site is situated along New Mexico Highway (NM) 176, located 8 kilometers (km) (5 miles

[mi]) east of the City of Eunice, New Mexico, in Lea County (figure 1). The UUSA facility is located within a 220-hectare (543-acre [ac]) parcel of land. Figures 2 and 3 show the layout of the facility.

The Texas border lies 0.8 km (0.5 mi) east of the site, and the City of Hobbs, New Mexico, lies 32 km (20 mi) to the north. The nearest large city is Midland/Odessa, Texas, located 103 km (64 mi) to the southeast. The area surrounding the site is mostly open land and industrial areas.

Waste Control Specialists (WCS) operates a low-level radioactive and hazardous waste disposal facility across the border in Texas immediately to the east of the site. The Lea County landfill, a municipal solid waste landfill, lies immediately to the south, about 1 km (0.6 mi) from the site. Wallach Concrete, Inc. operates a sand/aggregate quarry immediately to the north of the site, including two lagoons holding produced water from the oil and gas operations in the area. Major transportation routes in the area are NM 176, which runs east-west immediately south of the facility and provides access to the facility, and NM 18, which runs north-south and intersects NM 176 about 4.0 km (2.5 mi) west of the site. A railroad spur lies near the northern boundary of the site (figure 2) (NRC 2015).

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 the allowable enrichment of U-235 at the UUSA facility. This section also generally describes the future potential use of the recycling systems for decontaminating LEU+-exposed components. 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 of the proposed action on air quality, transportation, public and occupational health, and waste management.

10 Figure 1 Location of the UUSA Facility (NRC 2005)

11 Figure 0 Layout and Construction Proposed for 2015 Expansion License Amendment (UUSA 2013)

Figure 0 Current Layout of Facility (Google Maps 2024)

12 3.2.1 Resources Not Affected by the Proposed Action The proposed increase in the allowed enrichment of U-235 would not affect several resource areas. This is because the only change to currently licensed activities would be the processing of U-235 through the enrichment cascades to a higher level of enrichment. UUSA would not make other changes to enrichment processes or building footprints. All enrichment activities would continue to occur indoors, resulting in no land use changes, no soil disturbance, no visible changes, and no changes to staffing that would affect socioeconomic aspects. All LEU+

produced to the less than 10 w/o U-235 limit would be stored onsite. No shipments of LEU+

would occur until UUSA obtains a separate authorization from the NRC for LEU+ shipments (UUSA 2023a). The proposed action would not result in changes to surface water or groundwater use or discharge. Therefore, the NRC staff concludes the proposed action would not impact the following resources areas: land use, geology and soils, water resources, ecological resources, meteorological conditions, climate, noise receptors, visual and scenic resources, and socioeconomic resources. The potential impacts of the proposed action on air quality, transportation, public and occupational health, and waste management resources are discussed in section 3.2.2.

Likewise, UUSAs separate request to approve the use of recycling systems to process U-235 to a higher enrichment level states that the use of the recycling systems for LEU+ would not involve the construction of new facilities or the modification of existing buildings. UUSA does not anticipate that use of the recycling systems for LEU+ would affect land use, transportation, geology and soils, groundwater or surface water, ecological resources, noise receptors, historic and cultural resources, visual resources, or socioeconomic conditions (UUSA 2023a, 2024a).

The NRC will conduct separate safety and environmental reviews of these systems.

3.2.2 Resources Potentially Affected by the Proposed Action 3.2.2.1 Air Quality Lea County, which encompasses the UUSA site, is located administratively within the Pecos-Permian Basin Intrastate Air Quality Control Region (40 CFR 81.242), along with six other counties in east-central and southeastern New Mexico. Air quality in Lea County is in attainment for the six National Ambient Air Quality Standards criteria pollutants (EPA 2024).

Emissions from the UUSA facility that would continue during the proposed action and could cross the site boundary are small quantities of UF6 and hydrogen fluoride (HF)1 that are not captured by the GEVS and are emitted through the rooftop ventilation stack. All GEVS at the facility have continuous HF monitors upstream and downstream of the filters and in the exhaust stack, with high level alarms to inform operators of HF emissions within the plant GEVS. The NRCs 2015 expansion EA estimated that the annual average HF concentration from the facility operating at 10 million SWU would be less than 1.2 kilograms (kg) per year (2.6 pounds [lb] per year) (NRC 2015). UUSA analyzed the radiological consequences of producing U-235 at multiple enrichments up to 20 w/o U-235 and found that estimated HF emissions remain unchanged across the various enrichments. UUSA concluded from this assessment that UF6 enrichment does not impact HF emissions generation (UUSA 2024a).

In addition, UUSA performed an assessment to determine the maximum HF concentration that could be emitted from the UUSA facility and continue to remain at or below the 2015 EA projection of annual HF emissions of 1.2 kg g (2.6 lb) HF operating at 10 million SWU/year.

1 HF is a byproduct of the enrichment process that uses fluorine in the production of LEU and LEU+.

13 Assuming HF is emitted from the GEVS fans continuously at maximum flowrate for the entire year, UUSA determined that the maximum HF concentration that could be emitted from each vent and result in total emissions that would not exceed the NRCs 2015 EA estimate is 0.0023 milligrams (mg)/cubic meter (m3) (UUSA 2024a). Recent data from four GEVS vents indicate that average concentrations of HF ranged from 0.0003 to 0.0015 mg/m3 (or 0.3 to 1.5 g/m3)

(UUSA 2024a). This range is less than the 0.0023 mg/m3 that corresponds to the 1.2 kg/year HF evaluated in the NRCs 2015 EA. As stated in the NRCs 2015 EA, the estimated HF concentration for the facility operating at 10 million SWU is significantly lower than the most stringent reference level available, the California inhalation reference exposure level of 14 g/m3 for chronic exposures (COEHHA 2024). This analysis indicates that HF levels at offsite locations near the expanded UUSA facility are and would continue to be far below levels of health concern under the proposed action. Therefore, the NRC staff concludes that the proposed actions potential impacts on air quality from HF emissions would not be significant. Because they do not produce HF, the recycling systems do not affect the facilitys HF generation and exposure rates.

The UUSA facility would also continue to generate uranium emissions. The NRCs 2015 expansion EA estimated that site uranium emissions for the facility operating at 10 million SWU would be 29.7 million becquerel (MBq) (800 Ci) per year. The EA found that the radiological impacts of gaseous releases in this quantity are a small fraction of the NRC public dose limit of 1 millisievert (mSv)/year (100 millirem (mrem)/year) in 10 CFR 20.1301(a)(1) (NRC 2015). For the proposed action, the annual release of uranium would be less than 260 Ci/year (9.62 MBq/year), well below the conservative estimate in the NRCs 2015 EA (UUSA 2023a).

In accordance with NRC requirements in 10 CFR 70.59, Effluent Monitoring Requirements, UUSA submitted its semi-annual effluent monitoring report on radioactivity in effluents during the previous six months. For the period of June 2015 through June 2024, the total activities of the uranium isotopes observed in gaseous effluents from the UUSA facility were below the minimum detectable activity or were less than 10 percent of the NRCs regulatory limits in 10 CFR Part 20, appendix B, table 2, Effluent Concentrations, Col. 1, Class D for U-234, U-235, and U-238. The concentrations of individual uranium isotopes (U-234, U-335, and U-238) in gaseous effluents were below the minimum detectable concentration or were less than 10 percent of the NRCs limits in 10 CFR Part 20, appendix B, table 2, and the requirements in 10 CFR 20.1301, 10 CFR 20.1302, and 10 CFR 20.1101(d) (UUSA 2023a, 2024c, 2024d).

The NRC staff evaluated UUSAs estimated annual release of uranium for the proposed action, as discussed above. The NRC staff compared this information with the air effluent data analyzed in the NRCs 2015 EA and concludes the potential air quality impacts associated with uranium emissions from the proposed action would not be significant and the impacts identified in the NRCs 2015 EA are bounding.

3.2.2.2 Public and Occupational Health and Safety This section describes potential radiological and nonradiological impacts on the health and safety of workers and the public from the proposed action. The Atomic Energy Act of 1954, as amended, requires that the NRC promulgate, inspect, and enforce standards that provide an adequate level of protection for public health and safety and the environment. The proposed activities described in UUSAs application must comply with conditions in the UUSA license, as well as with the NRCs regulations, including 10 CFR Part 20, subpart C, Occupational Dose Limits for Adults, and subpart D, Radiation Dose Limits for Individual Members of the Public.

The NRC established the protection limits in 10 CFR Part 20, subpart C and subpart D to protect workers and the public against potential health risks from exposure to effluent discharges from nuclear facility operations.

14 Nonradiological Impacts The primary nonradiological sources of potential impacts on public and worker health are HF and uranium, as discussed below.

Hydrogen Fluoride UUSA performed Radiological Assessment System for Consequence Analysis (RASCAL) assessments to estimate potential emissions from the proposed action. The RASCAL results demonstrate the HF emissions would remain several orders of magnitude below both the Occupational Safety and Health Administration (OSHA) limits of 2 mg per cubic meter (1.2-7 lb/ft3) and the American Industrial Hygiene Associations Emergency Response Planning Guidelines, ERPGS-2, limit of 20 parts per million (LES 2023a). UUSA has placed HF monitors upstream and downstream of filters in the GEVS and in the exhaust stack. These monitors are alarmed in case HF emissions within the plant exceed the level in UUSAs procedures (i.e., level expected for normal operations) (UUSA 2024a).

As discussed in more detail in section 3.2.2.1 of this EA, UUSA determined the maximum concentration of HF emissions from the enrichment facility during LEU+ enrichment operations that would remain within the bounds of the NRCs 2015 expansion EA estimate of 1.2 kg (2.6 lb) of HF annually (UUSA 2024a). UUSA made this determination conservatively assuming the GEVS fans operate continuously at maximum flow rate throughout the whole year. The NRC staff reviewed UUSAs analysis and confirmed (1) the proposed action would not significantly alter annual emissions of HF from the facility, and (2) the previously estimated annual emission rate of 1.2 kg (2.6 lb) of HF remains bounding for the facility. Therefore, the NRC staff concludes the potential impacts of HF emissions from the proposed action would not be significant.

Uranium Uranium is a toxic heavy metal, in addition to being a radioactive element. The RASCAL assessments also showed the proposed action would continue to provide protection to workers and the public. The RASCAL assessments tested a range of enrichments, including 5, 10, and 20 w/o U-235 using the International Commission of Radiological Protection 26/30 inhalation dose factors; the results do not differ significantly from the assessments in the NRCs 2015 EA for the facility expansion (UUSA 2023a, 2024b). The estimated concentration of uranium remains approximately five orders of magnitude below the National Institute for Occupational Safety and Health and OSHA occupational exposure limit for soluble uranium forms of 50 g/m3 (3.12 lb/ft3) (NRC 2015). These limits are based on the effects of uranium metal toxicity to the kidneys.

While there are no ambient air quality standards for uranium, comparison to the occupational standards indicates that the uranium exposures to the public from normal operations would be below levels of concern. The NRC staff concludes the proposed enrichment increase would have no significant impact on public health from nonradiological emissions.

The GEVS would continue to prevent worker exposure and to collect and trap HF and uranium compounds in process-line effluent and workspace air. Because the rate of worker chemical (nonradiological) exposures at the facility would not change as a result of the proposed action, the NRC concludes that the nonradiological impacts from the proposed action on worker health would not be significant.

15 Radiological Impacts Public exposure to radiological gaseous effluents beyond the site boundary would be limited to small quantities of UF6 that are not captured by GEVS and are thus emitted through the ventilation stack. The NRCs 2015 expansion EA estimated that the annual emissions of the facility at 10 million SWU would be 12 g (0.027 lb) uranium (NRC 2015). UUSA conducted air dispersion modeling using U.S. Environmental Protect Agencys AERMOD model and the 12 g (0.027 lb) per year of uranium emissions. This modeling resulted in a maximum 8-hr average ambient air concentration of uranium of 9.9 x 10-5 g/m3 (UUSA 2013). This is roughly 3 orders of magnitude below the NRC limit for uranium in air in 10 CFR Part 20, appendix B, table 2.

As described in section 3.2.2.1 of this EA, UUSA submits a semi-annual effluent monitoring report to the NRC regarding radioactivity in effluents during the previous six months. For the period of March 2015 through June 2024, the gross uranium activities in the gaseous effluent were below the minimum detectable activity or were less than 10 percent of values in 10 CFR Part 20, appendix B, table 2, Effluent Concentrations - Col. 1, Class D for U-234, U-235, and U-238.

UUSA estimates that the annual release of uranium from the site during the production of LEU+

would be 260 µCi/year (9.62 MBq/year), an increase of 20 µCi/year (0.74 MBq/year) from the estimated annual release for the current enrichment level (i.e., LEU) (LES 2023a, NRC 2015).

The increased emissions would come from the ventilation stacks, which represent a small fraction of the offsite public dose risk with the highest dose at 1.77x10-4 mSv/year (1.77x10-2 mrem/year) at the northern boundary (NRC 2015). A 20 µCi/year (0.74 MBq/year) increase in effluent release would not meaningfully change the dose assessment and all doses at or beyond the site boundary would remain well below the NRC limit of 1 mSv/year (100 mrem/year) in 10 CFR 20.1301(a)(1).

UUSA does not intend to store any filled LEU+ product cylinders on the uranium byproduct cylinder (UBC) storage pad, and therefore there would be no increase of radiation levels at or beyond the site boundary from storage. The NRC concluded that storage at the UBC storage pad is the largest contributor to off-site dose (NRC 2015), and this would remain unchanged as a result of the proposed action. The NRC previously determined that the highest direct dose from the storage pad was at the north fence line, at 0.094 mSv/year (9.4 mrem/year), assuming 2,000-hour occupancy at the site north fence line (NRC 2015). The dose at the fence line from the storage unit would remain unchanged from the proposed action. Thus, total public dose from the proposed action would continue to be below the total effective dose equivalent (TEDE) limit in 10 CFR 20.1301 of 1 mSv/year (100 mrem/year) and within the 0.25 mSv/year (25 mrem/year) dose equivalent to the whole body and any organ as provided in Title 40 of the Code of Federal Regulations (40 CFR) Part 190.

Currently, the most significant contributor to occupational radiation exposure is the direct radiation from UF6 cylinders being stored on the UBC storage pad (UUSA 2023a). This source would remain the largest contributor under the proposed action, although under the proposed action filled LEU+ cylinders would not be stored on the UBC storage pad. The largest dose received since 2015 was just under 4.0 mSv (400 mrem) in a year, while the average dose received by all workers has been below 1.0 mSv (100 mrem) each year, as shown in table 1 (UUSA 2023a).

The occupational dose would increase during LEU+ operations due to the higher enrichment of the uranium. This is because the radioactivity of unirradiated uranium increases approximately linearly with an increase in enrichment. UUSA expects that implementing the proposed action in accordance with the established facility radiation protection plan and decontamination

16 processes would result in occupational exposures roughly doubling, conservatively assuming all facility production is LEU+. If all doses in table 1 are doubled, the most exposed individual would receive about 8.0 mSv (800 mrem) in a year, well below the NRC regulatory limit listed in 10 CFR 20.1201(a)(1)(i) of 50.0 mSv (5 rem). UUSA would continue to monitor radiation exposure to ensure all worker exposure is below regulatory limits and as low as reasonably achievable (ALARA) through the use of radiation monitoring systems, personnel dosimetry, and mitigation systems.

Since the facility would likely not produce solely LEU+, the annual maximum occupational dose would likely be less than 8.0 mSv (800 mrem). Therefore, the NRC concludes the proposed action would not have a significant radiological impact on occupational health.

Table 1 UUSA Occupational Total Effective Dose Equivalent for 2015-2023 Year Number of workers monitored Collective TEDE (mrem / mSv)

Average TEDE (mrem / mSv)

Highest Individual TEDE Received (mrem / mSv) 2015 75 4774 / 47.74 63.7 / 0.637 336 / 3.36 2016 79 4802 / 48.02 60.8 / 0.608 292 / 2.92 2017 65 3862 / 38.62 59.4 / 0.594 258 / 2.58 2018 65 4648 / 46.48 71.5 / 0.715 337 / 3.37 2019 105 5841 / 58.41 55.6 / 0.556 345 / 3.45 2020 59 4943 / 49.43 83.8 / 0.838 310 / 3.10 2021 52 5082 / 50.82 97.7 / 0.977 375 / 3.75 2022 61 4245 / 42.45 69.6 / 0.696 399 / 3.99 2023 57 4965 / 49.65 87.1 / 0.871 296 / 2.96 Average TEDE to workers: 72.1 mrem (0.721 mSv) mrem = millirem mSv = millisevert Source: modified from UUSA 2023a, 2024b, 2024f Accidents NRC regulations at 10 CFR Part 70, subpart H, applicable to materials licensees authorized to possess a critical mass of special nuclear material, are designed to ensure that the risk of high and intermediate consequence events is limited. The regulations in 10 CFR Part 70, subpart H, require UUSA to prepare an Integrated Safety Analysis (ISA) for its facility to demonstrate compliance with the performance requirements in 10 CFR 70.61(b), (c), and (d) to limit the risk of credible high and intermediate consequence events, as well as nuclear criticality accidents.

High-consequence accidents are defined in terms of (i) radiation dose to a worker, (ii) radiation dose to an individual located outside the controlled area, (iii) an intake of soluble uranium by an individual located outside the controlled area, or (iv) a chemical exposure to an individual. High-consequence events must be controlled by items relied on for safety such that the event is highly unlikely, or its consequences are less than the defined high consequences.

Intermediate consequence accidents are defined in terms of (i) radiation dose to a worker, (ii) radiation dose to an individual located outside the controlled area, (iii) an environmental release, or (iv) a chemical exposure to an individual. Intermediate

17 consequence events must be controlled by items relied on for safety such that the event is unlikely, or its consequences are less than the defined intermediate consequences.

In the NRCs 2015 expansion EA, the NRC staff determined that accidents with potentially high consequences to workers, the environment, or the offsite public would be kept highly unlikely through existing engineering and administrative controls (NRC 2015). Thus, the staff concluded in the 2015 EA that the impacts of facility accidents due to the facility expansion would not be significant. UUSAs ISA summary for the LEU+ licensing action describes credible events and accident sequences with consequences that could exceed the NRCs performance criteria in 10 CFR 70.61, Performance Requirements, for the facility. In accordance with its approved ISA process and quality assurance program, UUSA evaluated the potential for the proposed action to result in new types of accidents that were not previously evaluated. UUSA found that there would be no types of accidents not already evaluated and considered in the NRCs 2015 safety review for the facility expansion and referenced in the NRCs 2015 expansion EA (UUSA 2023a). UUSA did, however, identify new and revised accident sequences within some accident categories but states that these changes do not result in changes to the accident severity levels or consequence categories.

The NRC staffs safety review for this proposed licensing action assesses the safety features and operating procedures required to reduce the risks from accidents. The combination of items relied on for safety (IROFS) to mitigate emergency conditions and the use of emergency procedures and protective actions in accordance with the emergency plan for the UUSA facility would limit the impacts of accidents that could otherwise extend beyond the UUSA site boundaries. The IROFS include measures such as active and passive engineered controls required by 10 CFR 70.61(e). The NRC staffs safety assessment will be documented in the safety evaluation report (SER) for this proposed licensing action. The SER will include a determination of whether the facility complies with the performance requirements of 10 CFR 70.61, which would also serve to control the environmental consequences of accidents.

The NRC staff concludes, based on UUSAs analysis and the staffs review, that the potential impacts from accidents as a result of the proposed action would not change.

3.2.2.3 Waste Management Table 2-3 of the NRCs 2015 expansion EA provides a detailed list of the quantities and types of wastes that were estimated for the facility operating at 10 million SWU per year (NRC 2015).

The proposed action in this EA (enrichment at less than 10 w/o U-235) would result in slight changes to processes to accommodate the higher enrichment. These changes would result in a minor increase in the generation of filter wastes compared with the current rates and a slight decrease in the generation of depleted UF6 cylinders. The potential future use of the recycling systems to process materials and components that were exposed to LEU+ would result in changes to the processing of liquid low-level radioactive wastes containing depleted UF6. The sections below describe the changes in waste generation from the proposed action and the potential future use of the facility recycling systems for LEU+.

Low-Level Radioactive Wastes Under the proposed action, the ventilation systems effluent sample filters would continue to be monitored for gross alpha, gross beta and isotopic uranium. The NRCs 2015 EA evaluated replacement of these filters on a weekly basis, but UUSA reports that the filters are exchanged approximately monthly and that the proposed action may result in replacement slightly more frequently than monthly. The GEVS in-line filters would also continue to need periodic replacement, and UUSA does not anticipate that the replacement frequency would exceed the

18 current annual frequency (UUSA 2023a). Replaced activated carbon, activated alumina and ventilation filters used at the facility are considered Class A low-level radioactive wastes and are disposed of at licensed low-level radioactive disposal facilities, which can readily accommodate the volumes of UUSA wastes produced (UUSA 2023a, NRC 2015). The NRCs 2015 EA estimated that the UUSA enrichment facility operating at 10 million SWU would generate about 99,790 kg (220,000 lb) of these spent ventilation filters per year. Because the sample filters are exchanged monthly rather than the estimated weekly, and accounting for a slight increase in the replacement frequency of these filters, the NRC staff concludes that the proposed actions impacts on management of these wastes would not be significant.

In the uranium enrichment process, feed UF6 is split into two product streams, enriched product and depleted UF6 byproduct, or tails. The sum of product and tails produced equals the amount of UF6 feed processed. To produce LEU+, the feed material needs further enrichment in U-235.

Extracting more U-235 from the feed material results in a decrease in the amount of U-235 in the tails material (UUSA 2024a). Therefore, the production of LEU+ would result in a decrease in the number of depleted UF6 cylinders generated annually in comparison to the current rate (UUSA 2024a). UUSAs license limits the number of depleted UF6 cylinders stored at the UUSA site to 25,000 cylinders of depleted UF6 (UUSA 2024a).

UUSA collects liquid process waste streams which may be radioactive in bulk storage tanks installed in the liquid effluent collection and transfer system (LECTS). Waste is pumped via a transfer system to containers and transferred for disposal as necessary based on tank volumes.

Two liquid low-level radioactive waste shipments have occurred so far during facility operation.

One shipment of 23,451 kg (25.85 tons) in 2016 and another shipment of 24,109 kg (26.58 tons) in 2019 were both delivered to the Energy Solutions low-level waste facility in Clive, Utah (UUSA 2024e). UUSA does not expect that increasing the enrichment of U-235 would change the generation of low-level radioactive wastes from the types and amount analyzed in the NRCs 2015 expansion EA, which estimated approximately 945,800 kg/year (2,100,000 lb or 1,043 tons per year) (UUSA 2023a).

Because the quantities of low-level radioactive wastes would not change significantly as a result of the proposed action and the total amount would not exceed the amount estimated in the NRCs 2015 expansion EA, the NRC staff concludes that the impacts of low-level radioactive waste management from the proposed action would not be significant.

Components and production material (e.g., oil) removed from LEU+ exposed enrichment systems would be segregated and stored in analyzed locations within the UUSA facility (UUSA 2023a). UUSA does not consider these materials and components to be wastes while they are being stored because UUSA intends ultimately to reuse them. The NRC is conducting a separate safety review for the current action. If the NRC authorizes UUSA to produce LEU+, the NRC will impose a license condition to ensure that these materials are stored properly until they are decontaminated or otherwise dispositioned. The paragraph below describes the potential future use of the recycling systems to decontaminate these stored components and materials.

If the NRC approves UUSAs new request seeking to use the facilitys recycling systems to process LEU+, components from the LEU+ enrichment process would be periodically removed, decontaminated, and recycled using the same chemicals and processes as currently licensed and evaluated, but at a higher enrichment limit. Depleted UF6 from the recycling processes would contain a larger quantity of U-235, and thus more depleted UF6 would need to be processed for down-blending (dilution) of the liquid effluent in the LECTS to meet a safety limit of no more than 1.0 w/o U-235 enrichment in the storage tanks and containers. Even with a change in down-blending operations, UUSA expects these processes would not increase the quantity of low-level radioactive wastes above the 945,800 kg/year (2,100,000 lb or 1,043 tons

19 per year) estimate reported in Table 2-3 of the NRCs 2015 expansion EA for the 10 million SWU facility (UUSA 2024a, UUSA 2024e). The NRC will consider these processes in separate safety and environmental evaluations.

Hazardous and Nonhazardous Wastes The proposed action would not result in changes to the generation of hazardous wastes or nonhazardous wastes (UUSA 2023a). UUSA will continue to temporarily store hazardous waste at the UUSA site for transportation to a licensed off-site hazardous waste facility within the required 90-day timeframe (UUSA 2024a).

3.2.2.4 Transportation As shown on figure 2, NM 176 passes along the southern boundary of the UUSA site. Eunice, New Mexico, lies along NM 176 approximately 8 km (5 mi) to the west of the UUSA site, and the New Mexico-Texas state line is approximately 0.8 km (0.5 mi) to the east (figure 4). NM 176 becomes Texas Highway 176 (TX 176) at the state line, continuing eastward to Andrews, Texas. NM 176 provides direct access to the UUSA site and is a two-lane highway. Four kilometers (2.5 mi) to the west of the site, NM 176 intersects NM 18, which runs north to Hobbs, New Mexico, and south to Jal, New Mexico. NM 18 is a four-lane divided highway that crosses south into Texas, becoming TX 18, and connects with Interstate 20 (I-20) in Monahans, Texas.

UUSA does not expect the number of feed cylinder deliveries or vehicle types to change as a result of the proposed action (UUSA 2023a). The proposed action also would not affect the number or type of waste shipments or the types of vehicles. The higher enrichment production level would result in a decrease in the amount of tails material, and therefore the number of depleted UF6 cylinders produced over time would slightly decrease from the current production rate (UUSA 2024a). The amendment would not authorize the shipment or transportation of LEU+ offsite (UUSA 2023a).

The proposed action to increase the enrichment limit would result in the storage of LEU+

product cylinders onsite. This assumes customers would continue to require the same current average annual mass of UF6 produced at the UUSA facility and assumes that mass consists entirely of LEU+. For shipping LEU, UUSA currently uses cylinders that have a fill mass of 2,277 kg (5,020 lb) UF6 (NRC 20224b). UUSA expects that the cylinders used to ship LEU+ in the future would need to be filled to a lower mass of 1,460 kg (3,219 lb) UF6 (UUSA 2023a). As a result, UUSA conservatively estimates that product cylinder shipments, when authorized, would increase from the current average of approximately 69 shipments per year to 108 shipments per year and that transportation routes would remain unchanged (UUSA 2023a). The estimated 108 shipments per year is less than the 235 product cylinder shipments evaluated in the NRCs 2015 expansion EA (UUSA 2023a, NRC 2015).

Because the proposed action (1) would not result in a change in the shipment of feed or waste shipments, (2) would result in a decrease in the accumulation of depleted UF6, and (3) would not allow for the shipment of LEU+ product, the NRC staff concludes that the proposed actions impacts on transportation would not be significant.

20 Figure 4 Transportation Routes Near the UUSA Facility (NRC 2015)

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AGENCIES AND PERSONS CONSULTED 4.1 Agency Review The NRC staff provided the draft EA to the New Mexico Environment Department on November 5, 2024 (NRC 2024b). The NRC received no comments on the EA.

4.2 The 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 U-235 enrichment limit would constitute a Federal undertaking. The NRC staffs review of UUSAs application, finds the proposed action to increase enrichment of enriched UF6 from the current limit of 5.5 weight percent (w/o) U-235 to less than 10 w/o U-235 at the UUSA facility (1) would not result in ground-disturbing activities, and (2) is not a type of activity that has the potential to cause effects on historic properties that may be present. Therefore, following 36 CFR 800.3(a)(1), the NRC has no further obligations under Section 106 of the NHPA.

4.3 The Endangered Species Act Section 7 of the Endangered Species Act (ESA) requires that, prior to taking a proposed action, Federal agencies determine whether endangered and threatened species or their critical habitats are known to be in the vicinity of the proposed action, and, if so, whether the proposed Federal action may affect listed species or critical habitats. When 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).

As described in the NRCs 2015 expansion EA, ecological monitoring and surveys performed onsite indicated that there are no important ecosystems onsite that are vulnerable to impacts from the facility, and that no important habitats are present, including seasonal habitats (NRC 2015). The proposed action assessed in this EA would not result in construction or land disturbance. The proposed increase in enrichment of U-235 and storage of LEU+ would occur inside existing buildings. 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 UUSA facility, the proposed increase in the enrichment limit would not affect such species or their habitats. Therefore, the NRC has determined that there would be no effect on listed species or critical habitats and no further consultation is required under Section 7 of the ESA.

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CONCLUSION AND FINDING OF NO SIGNIFICANT IMPACT The NRC staff reviewed the proposed action in accordance with the requirements of 10 CFR Part 51. The NRC staff concludes that approval of UUSAs proposed action to produce, store, and handle enriched UF6 at enrichment of less than 10 w/o U-235 at the UUSA enrichment facility would not significantly affect the quality of the human environment. As described in section 3 of this EA, approval of the proposed action will not result in changes to land use, no construction or soil disturbance will take place, no visible changes to the facility or the viewshed will occur, and no staffing changes are anticipated that would affect socioeconomic indicators.

UUSA would store LEU+-exposed, reusable materials and cascade components inside in a designated, approved storage area until further disposition. The NRC does not expect significant radiological or non-radiological impacts from approval of the proposed action, and impacts will remain bounded by the impacts assessed in the NRCs 2015 expansion EA.

Occupational dose estimates associated with the proposed action will continue to be ALARA and fall within the limits identified in 10 CFR 20.1201. Approval of the proposed action is not expected to result in measurable radiation exposure to a member of the public. Therefore, the NRC staff has determined that, pursuant to 10 CFR 51.31, preparation of an environmental impact statement is not required for this proposed action, and pursuant to 10 CFR 51.32, a finding of no significant impact is appropriate. This determination will be published in the Federal Register.

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LIST OF PREPARERS This EA was prepared by the NRC staff.

Contributor Education, Years of Experience Christine Pineda BA Sociology, Env. Studies minor MS Environmental Sciences and Policy 23 years of professional experience Amy Minor BA Environmental Studies Duke NEPA Certificates 23 years of environmental site analysis and evaluations Isaac Johnston BS Marine Science PhD Environmental Engineering and Earth Sciences 2 years of professional experience

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REFERENCES 10 CFR Part 20. Title 10 of the Code of Federal Regulations, Energy, Part 20, Standards for Protection Against Radiation. U.S. Nuclear Regulatory Commission, Washington, D.C.

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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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26 UUSA (Urenco USA). 2023b. Notice of Intent for UUSA to Submit License Amendment Requests to Increase Enrichment Limit for Construction of a High Assay Low Enriched Uranium Facility (HALEUF). Eunice, NM. July 27, 2023. ML23208A261.

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