ML25125A111

Environmental Assessment for Proposed Removal of Condition 14 from Urenco USAs License for the National Enrichment Facility in Lea County, New Mexico

ML25125A111
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Site:	07003103
Issue date:	05/05/2025
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ML25125A111 EAXX-429-00-000-1746414950 Environmental Assessment for Proposed Removal of Condition 14 from Urenco USAs License for the National Enrichment Facility in Lea County, New Mexico Docket Number: 70-3103 License Number: SNM-2010

i Contents Figures........................................................................................................................................... i Tables............................................................................................................................................ i Abbreviations and Acronyms........................................................................................................ ii 1.0 Introduction.......................................................................................................................... 1 1.1 Proposed Action......................................................................................................... 1 1.2 Purpose of and Need for the Proposed Action........................................................... 1 1.3 Alternative to the Proposed Action............................................................................. 2 1.4 Background................................................................................................................ 2 1.5 Scope of the Environmental Analysis......................................................................... 2 2.0 Proposed Action.................................................................................................................. 3 3.0 NEF Site and Current DUF6 Management........................................................................... 3 4.0 Potential Environmental Impacts......................................................................................... 5 4.1 Resources Not Affected by the Proposed Action....................................................... 5 4.2 Resources Affected by the Proposed Action.............................................................. 6 4.3 Cumulative Effects..................................................................................................... 7 5.0 Agencies and Persons Consulted....................................................................................... 8 5.1 Agency Review........................................................................................................... 8 5.2 National Historic Preservation Act.............................................................................. 8 5.3 Endangered Species Act............................................................................................ 8 6.0 Conclusion and Finding of No Significant Impact................................................................ 9 7.0 References.......................................................................................................................... 9 Figures Figure 1. Location of the UUSA Facility........................................................................................ 4 Figure 2. Roads in the Vicinity of the UUSA Site.......................................................................... 5 Tables Table 4-1. Listed Species Potentially Present in the Area of the NEF.......................................... 9

ii Abbreviations and Acronyms AHF anhydrous hydrogen fluoride (or anhydrous hydrofluoric acid)

ASLB Atomic Safety and Licensing Board ASLBP Atomic Safety and Licensing Board Panel DOE U.S. Department of Energy DOT U.S. Department of Transportation DUF6 depleted UF6 EA environmental assessment EIS environmental impact statement FWS U.S. Fish and Wildlife Service HF hydrogen fluoride LC license condition LES Louisiana Energy Services NEF National Enrichment Facility NHPA National Historic Preservation Act NMSS Office of Nuclear Material Safety and Safeguards PEIS programmatic EIS NRC U.S. Nuclear Regulatory Commission SNM special nuclear material UF6 uranium hexafluoride UUSA Urenco USA

1 1.0 Introduction By letter dated September 1, 2023 (Reference 28), Louisiana Energy Services (LES) (doing business as Urenco USA [UUSA]) submitted a request to the U.S. Nuclear Regulatory Commission (NRC) for an amendment to special nuclear materials license (SNM)-2010 to remove license condition 14. License condition 14 (LC 14) prohibits UUSA from shipping depleted uranium hexafluoride (DUF6) to a deconversion facility that uses a deconversion process involving the production of anhydrous hydrogen fluoride (AHF). Removal of the license condition (the NRCs proposed action) would allow UUSA to ship DUF6 to this type of deconversion facility, though currently in the U.S., no such facility exists.

UUSA operates the National Enrichment Facility (NEF) in Eunice, Lea County, New Mexico (see figure 1). This 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 uranium-235 isotope (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 atoms (Reference 25). After enrichment, the uranium with a higher concentration of U-235 is used in fabricating fuel for nuclear reactors. Large quantities of depleted uranium (uranium with 0.2-0.3 percent U-235) exit the enrichment process in the form of DUF6. UUSA stores DUF6 onsite and is authorized to store up to 25,000 cylinders of DUF6 at the NEF (Reference 16).

After conducting an initial review of UUSAs application for the license amendment, the NRC staff sent UUSA a request for supplemental information dated November 28, 2023 (Reference 17). UUSA provided a response in January 2024, which was superseded by a revised response dated February 6, 2025 (Reference 29). The NRC accepted the application for detailed technical review on February 5, 2024 (Reference 26). A notice announcing the acceptance and providing an opportunity for hearing was published in the Federal Register on January 29, 2025 (Reference 27). The NRC staffs environmental review for the proposed removal of LC 14 is documented in this environmental assessment (EA). The NRC staff is conducting a parallel safety review of the proposed action, which will be issued separately.

1.1 Proposed Action The NRC is proposing to remove a license condition that prohibits UUSA from shipping DUF6 from the NEF to a certain type of deconversion facility. Specifically, LC 14 states, For the disposition of depleted UF6 (DUF6) the licensee shall not use a DUF6 deconversion facility that employs a process that results in the production of anhydrous hydrofluoric acid (Reference 16).

For the foreseeable future, removal of LC 14 would have no effect on the UUSA management of DUF6 because no deconversion facility exists in the U.S. that produces AHF.

1.2 Purpose of and Need for the Proposed Action The purpose of amending licensing SNM-2010 to remove LC 14 is to allow UUSA another option for the disposition of DUF6. If the NRC removes LC 14, and if a deconversion facility that produces AHF is constructed (such as the NRC-licensed, proposed deconversion facility that would be constructed in Lea County, New Mexico [Reference 19]), UUSA could ship DUF6 to this type of facility for processing.

2 1.3 Alternative to the Proposed Action As an alternative to the proposed license amendment, the NRC staff considered no action, which would leave LC 14 in effect in the license. If the condition remains in effect, UUSA would not be able to ship DUF6 to a deconversion facility that produces AHF. Since no such deconversion facility exists in the U.S., the impacts of not removing the license condition would be the same as the reasonably foreseeable impacts of removing the license condition. That is, UUSA would continue to store DUF6 containers onsite and could choose to ship some DUF6 to a U.S. Department of Energy (DOE) deconversion facility. The potential impacts associated with DUF6 management are addressed in the NRCs 2005 environmental impact statement (EIS) for the initial licensing of the NEF (Reference 22) and in the NRCs 2015 EA for the expansion of the NEF (Reference 25). The no action alternative is not addressed further in this EA.

1.4 Background

In December 2003, LES applied to the NRC for a license to construct and operate the NEF now operating in Eunice, New Mexico. In July 2004, the ASLB admitted a contention (contention EC-

4) stating that the application for the NEF did not contain an analysis of the impacts of a specific type of deconversion facility (i.e., one that produces AHF) (Reference 18). Likewise, in the NRCs EIS for the NEF (Reference 22), the NRC did not consider the impacts of shipping DUF6 to a facility that uses the AHF process because that process was not yet in use. After the hearing concluded on this contention, orders issued by the Atomic Safety and Licensing Board (ASLB) (LBP-05-13) and the Commission (CLI-05-28) stated that, given the uncertainty at that time regarding the potential for a facility to be constructed that produces AHF, the consideration of the potential impacts associated with AHF production as a result of the ASLB proceeding was sufficient (References 23 and 24).1 To address the concern expressed in EC-4, LES agreed to the addition of LC 14 prohibiting the use of a deconversion facility that produces AHF. Therefore, per NRC requirements and as stated in Commission order CLI-05-28, LES (UUSA) needs to obtain a license amendment to allow shipment of DUF6 to this type of facility. This EA provides the environmental review for UUSAs request to remove LC 14 from the license.

1.5 Scope of the Environmental Analysis The NRC staff has evaluated the potential environmental impacts of the proposed action to amend license SNM-2010 to remove LC 14, as described in this EA. The NRC staff performed this review in accordance with the requirements in Title 10 of the Code of Federal Regulations Part 51 (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 and responses to the NRCs request for supplemental information (References 28 and 29). The NRC staff also reviewed previous environmental documents for the NEF, including the EIS for the initial licensing of the NEF (Reference 22) and the EA for the NEF expansion (Reference 25), and previous environmental documents published by the DOE (References 7 and 8).

1 The NRC staff notes that uncertainty still exists at the writing of this EA (2025) because, while the NRC has since issued a license for the construction and operation of such a deconversion facility (Reference 19), the NRC staff is not aware of announcements or plans for its construction.

3 Section 3 of this EA identifies potential environmental impacts for the proposed action. In this EA, the NRC staff evaluates the potential impacts of allowing UUSA to ship DUF6 to a facility that produces AHF that were not analyzed in previous environmental reviews. As explained further in section 3 of this EA, the NRC staff determined that the proposed amendment would not result in changes to or new effects on land use, socioeconomic conditions, geologic and soil resources, air quality, waste management, ecological resources, noise receptors, visual and scenic resources, groundwater, or surface water. This EA, therefore, assesses the potential impacts of the proposed action on public and occupational health and on transportation.

2.0 Proposed Action The NRC is proposing to remove a license condition that prohibits UUSA from shipping DUF6 from the NEF to a certain type of deconversion facility. Specifically, LC 14 states, For the disposition of depleted UF6 (DUF6) the licensee shall not use a DUF6 deconversion facility that employs a process that results in the production of anhydrous hydrofluoric acid (Reference 16).

The proposed action would not affect UUSAs enrichment operations at the NEF. In its application, UUSA stated that it would ship depleted uranium in industry standard 48Y cylinders, in which depleted UF6 is now stored at the facility on the uranium byproduct cylinder storage pad. UUSA also stated that, due to logistical complexities, it is unlikely that UUSA would ship more than an average of one cylinder per day (one truck per day), even if a facility could accept UF6 cylinders at a greater rate (Reference 29).

3.0 NEF Site and Current DUF6 Management The NEF is located within a 220-hectare (ha) (543-acre [ac]) parcel of land. 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 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. Oil and gas operations and cattle grazing are prevalent 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).

UUSA receives UF6 cylinders containing natural uranium at an average rate of about one cylinder per day from suppliers. Full cylinders are shipped to the NEF from the Cameco Fuel Services conversion facility in Port Hope, Ontario, or from the Honeywell conversion facility in Metropolis, Illinois (Reference 29). UUSA stores cylinders containing DUF6 on its byproduct cylinder storage pad. In its license, UUSA is authorized to store no more than 25,000, 48Y-type cylinders of DUF6 onsite. In addition, UUSA may not store any one cylinder for a more than 25 years from the date the cylinder was filled (Reference 16).

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

5 Figure 2 Roads in the Vicinity of the UUSA Site (NRC 2015) 4.0 Potential Environmental Impacts This section presents the NRC staffs evaluation of the potential environmental impacts of the proposed license amendment on certain resource areas. Section 4.1 explains why certain resource areas would not be affected by the proposed action. Section 4.2 describes the potential impacts on public and occupational health and transportation. Section 4.3 addresses the potential cumulative impacts of the proposed action when considered with other past, present, or reasonably foreseeable actions.

4.1 Resources Not Affected by the Proposed Action Removal of the license condition would allow UUSA to ship DUF6 to a deconversion facility that produces AHF. This proposed action would not have an effect on most resource areas because the removal of LC 14 would only allow shipment of currently stored DUF6 cylinders from the NEF to a destination other than the DOE facilities in Portsmouth, Ohio, and Paducah, Kentucky.

Despite having issued a license to International Isotopes for a facility that would be located in Lea County near the NEF, the NRC staff is not aware of plans to construct this or another deconversion facility that would produce AHF. However, were such a facility to become available, UUSA could transport DUF6 using existing roads. UUSA would not need to make changes to its NEF operations for this proposed action, and the only change to potential impacts associated with the NEF would relate to the shipment destination. For these reasons the NRC staff finds the proposed removal of LC 14 would not affect land use, geologic and soil resources, air quality, ecological resources, water resources, noise receptors, visual and scenic

6 resources, historic and cultural resources, socioeconomics, or waste management. For these resource areas, the NRC staff concludes that the impacts as assessed in the NRCs EIS for the NEF (Reference 22) and the NRCs EA for the NEF expansion (Reference 25) would remain unchanged.

4.2 Resources Affected by the Proposed Action The proposed action would allow UUSA to transport DUF6 to a deconversion facility that produces AHF, whenever such a facility becomes available. Presently, UUSA stores DUF6 onsite. The potential environmental impacts that could result from UUSAs use of a deconversion facility that produces AHF would relate to the transportation route for shipping the DUF6. In addition, UUSAs use of a facility that produces AHF would be associated with the potential public and occupational health impacts of production, storage, and shipment of AHF.

These activities would be conducted by the deconversion facility, not UUSA, and are therefore indirect impacts associated with UUSA operations at the NEF. These areas are discussed further in the next sections.

4.2.1 Effects of DUF6 Transport to and AHF Transport from a Deconversion Facility The NRC staffs safety evaluation for this proposed action addresses the potential impacts of transporting DUF6 to a hypothetical facility that produces AHF and of shipping AHF from a deconversion facility. UUSA would not be involved in the shipments of AHF product from the deconversion facility.

The NRC staff concluded as a result of its safety evaluation that the potential impacts of DUF6 shipments to the site of the proposed International Isotopes deconversion facility in Lea County are bounded by the assessment in the 2015 EA and would not be significant. Likewise, the safety review concluded that the potential impacts of transporting AHF product from a deconversion facility during normal operations would not be significant. The safety review also assesses the potential for and the possible consequences of accidents involving AHF.

4.2.2 Public and Occupational Health Effects Associated with AHF Production and Storage The NRCs 2012 EIS for the International Isotopes facility assessed the potential environmental impacts of the construction and operation of a deconversion facility that would product AHF (Reference 20). The EIS describes the deconversion process and resulting production of AHF:

After receipt of DUF6 at the proposed International Isotopes deconversion facility, DUF6 cylinders are placed in a containment-type autoclave in the DUF6 autoclave building. The DUF6 vapor is captured in a reaction vessel where it reacts with hydrogen to produce DUF4 powder and AHF. Hydrogen fluoride (HF) offgases are filtered, and any residual DUF6 is trapped on carbon filters. The AHF is then condensed to liquid form and collected in 3,630-kg (8,000-lb) storage tanks. Filled AHF storage tanks are placed in a staging containment building designed to contain a leak. The AHF storage tanks are eventually transferred from the staging containment building to the connected fluoride products trailer loading building and into tanker trucks before being shipped to customers (Reference 20). The AHF staging containment building and the fluoride products trailer loading building are equipped with water-fog nozzles that automatically activate in the event of a leak of AHF or fluoride product chemicals (Reference 20).

7 HF is a colorless gas or fuming liquid commonly used for industrial applications in the U.S. It is an inorganic, corrosive acid. A release of a significant quantity of HF can form dense, white, vapor clouds. Both the liquid and vapor forms of HF can cause severe burns to all parts of the body. Exposure to skin, eyes and inhalation or ingestion can cause severe health consequences, including death. The American Chemistry Council provides comprehensive guidelines for the design, construction, and use of equipment for the storage and transportation of HF (References 29 and 5). The U.S. Environmental Protection Agency (EPA) requires process hazard analysis for facilities that have significant quantities of HF. The EPA regulations include specific requirements for the storage and handling of HF that, in conjunction with industry practices, help reduce the incidence of accidental releases to reduce the risk of injury to workers and the public (Reference 29).

4.3 Cumulative Effects Cumulative effects include the effects of past, present, or reasonably foreseeable actions in the area, as well as the incremental impact of the proposed license amendment. The proposal to remove LC 14 does change the operations of the NEF; UUSA will continue to accumulate and store DUF6 onsite as it is produced. For this reason, the NRC staff finds the cumulative effects will be essentially the same as the effects assessed in the NRCs previous environmental reviews, as described in section 4.4 of the EIS (Reference 22) and in section 4.1.5 of the expansion EA (Reference 25). The cumulative effects related to DUF6 management that were identified in the EA for the 2015 expansion are described below.

The NRCs 2015 EA for the expansion of NEF operations considered the effects of expanded NEF operations on the capacity of the proposed International Isotopes facility and on the existing Paducah and Portsmouth DUF6 deconversion facilities. With respect to the conversion of DUF6 to uranium oxide, the EA noted that other operating or proposed enrichment facilities could also place demands on the available DUF6 conversion facilities of a magnitude similar to that of the NEF.2 The EA determined that the UUSA facilitys expansion would result in the generation of about 150,000 metric tons (MT) (~165,350 tons) of DUF6, about half of the facilitys total projected generation of DUF6 of 300,000 MT (~330,000 tons) or 25,000 cylinders.

More than 63,000 DUF6 cylinders were already being stored at the Paducah and Portsmouth sites as of 2017 (Reference 9). The EA concluded that available and foreseeable conversion capacity provided by the International Isotopes facility and the Paducah and Portsmouth facilities would be strained by the demands of all of the DUF6 produced by the proposed enrichment facilities if these facilities start uranium enrichment operations (Reference 25). Thus, the EA concluded that the cumulative impacts of DUF6 processing needs from the UUSA facility, in conjunction with the DUF6 from any future operation of other enrichment facilities, would be MODERATE. Implementing the proposed action by removing the license condition would not change this conclusion but would allow UUSA the flexibility to send DUF6 to a different type of deconversion facility, if such a facility becomes operational.

The NRC issued a license in 2012 for the construction and operation of the International Isotopes fluorine extraction and depleted uranium deconversion facility near Hobbs, New Mexico, near the NEF. International Isotopes recently announced that it intends to sell its depleted uranium deconversion assets to American Fuel Resources (II 2024). If the facility is constructed and becomes operable, UUSA could choose to send DUF6 there for deconversion.

2 Presently, planned facilities include the American Centrifuge Plant in Piketon, Ohio; the Orano USA Project IKE facility in Oak Ridge, Tennessee; and the Paducah Laser Enrichment facility in Paducah, Kentucky.

8 The availability of an additional deconversion facility would reduce the burden on the existing deconversion facilities in Portsmouth, Ohio, and Paducah, Kentucky.

5.0 Agencies and Persons Consulted 5.1 Agency Review On April 4, 2025, the NRC staff provided the draft EA to the New Mexico Environment Department for review (Reference 30). The NRC received no comments on the draft EA.

5.2 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 UUSAs request to remove license condition 14 would be a Federal undertaking. After reviewing UUSAs application, the NRC staff determined the proposed removal of the license condition and the resulting potential shipment of DUF6 to another type of deconversion facility 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. Therefore, in accordance with 36 CFR 800.3(a)(1), the NRC has no further obligation under Section 106 of the NHPA.

5.3 Endangered Species Act Section 7 of the Endangered Species Act (ES) 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 (Reference 11). Table 1 lists species that may be present around the NEF.

9 Table 1 Listed Species Potentially Present in the Area of the NEF Category Name Status Birds Lesser Prairie-chicken (Tympanuchus pallidicinctus)

Endangered Northern Aplomado Falcon (Falco femoralis septentrionalis)

Experimental population Insects Monarch Butterfly (Danaus Plexippus)

Candidate Critical habitats None The proposed action assessed in this EA would not result in construction activities or land disturbance and would not change current operations at the NEF. If a deconversion facility is constructed that produced AHF, UUSA could ship DUF6 there and would use existing roads.

Consistent with guidance in NUREG-1748, the NRC has determined that even if endangered or candidate species are present in the vicinity of the NEF, the proposed removal of LC 14 and the resulting potential shipments to another type of deconversion facility would not affect such species or their habitats. Therefore, the NRC has no further obligation under Section 7 of the Endangered Species Act.

6.0 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-2010 to remove LC 14 would not significantly affect the quality of the human environment. As described in section 4 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. As a result of removing the license condition, UUSA could choose to ship DUF6 to a deconversion facility that produces AHF, should such a facility become available, instead of shipping to a facility that produces aqueous HF, such as the DOE Paducah and Portsmouth deconversion facilities. 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.

7.0 References

1. 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.

2. 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.

3. 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.

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4. 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.

5. American Chemistry Council. 2024. Hydrogen Fluoride Guidelines. Available at https://www.americanchemistry.com/industry-groups/hydrogen-fluoride-industry-practices-institute-hfipi/hydrogen-fluoride-guidelines, accessed July 3, 2024.

6. Atomic Energy Act of 1954, as amended. 42 U.S.C. §§ 2011-2021, 2022-2286i, 2296a-2297h-13.

7. DOE (U.S. Department of Energy). 1999. DOE/EIS-0269, Final Programmatic Environmental Impact Statement for Alternative Strategies for the Long-Term Management and Use of Depleted Uranium Hexafluoride. Washington, D.C. April 1999.

https://www.energy.gov/nepa/doeeis-0269-alternative-strategies-long-term-management-and-use-depleted-uranium-hexafluoride

8. DOE (U.S. Department of Energy). 2004. DOE/EIS-0359, Final Environmental Impact Statement For Construction And Operation Of A Depleted Uranium Hexafluoride Conversion Facility at the Paducah, Kentucky, Site. Office of Environmental Management. Washington, D.C. June 2004. Available at https://www.energy.gov/nepa/articles/eis-0359-final-environmental-impact-statement, accessed July 2, 2024.

9. DOE (U.S. Department of Energy). 2017. DUF6 Conversion Process. Lexington, Kentucky. February 13, 2017. Available at https://www.energy.gov/pppo/articles/duf6-conversion-process#:~:text=There%20are%20currently%20more%20than,and%20Portsmouth%20(

Piketon)%20sites, accessed July 3, 2024.

10. Endangered Species Act of 1973, as amended. 16 U.S.C. ch. 35 § 1531 et seq.

11. FWS (U.S. Fish and Wildlife Service). 2025. Species List for the Urenco USA National Enrichment Facility, Eunice, New Mexico. February 19, 2025. ML25076A721.

12. II (International Isotopes, Inc.). 2024. Press Release, International Isotopes to Divest Depleted Uranium Deconversion Assets to American Fuel Resources for $12,500,000 cash. Idaho Falls, Idaho. February 8, 2024. Available at www.intisoid.com/wp-content/uploads/2024/02/PR_DUF6-Asset-Transaction_20240208_final.pdf, accessed June 28, 2024.

13. National Environmental Policy Act of 1969, as amended (NEPA). Public Law 91-190; 42 U.S.C. § 4321 et seq.

14. National Historic Preservation Act of 1966, as amended (NHPA). Public Law 102-575; 16 U.S.C. 470.

15. NRC (U.S. Nuclear Regulatory Commission). 2003. Environmental Review Guidance for Licensing Actions Associated with NMSS Programs. NUREG-1748. Washington, D.C.

August 2003. ML032450279.

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16. NRC (U.S. Nuclear Regulatory Commission). 2023. Materials License SNM-2010, Amendment 98. Washington, D.C. June 30, 2023. ML23178A218.

17. NRC (U.S. Nuclear Regulatory Commission). 2023. Letter to Louisiana Energy Services, LLC re: Request for Supplemental Information Regarding Urenco USA License Amendment Request 23-07, Revise Special Nuclear Material-2010 to Delete License Condition 14. Washington, D.C. November 28, 2023. ML23324A189.

18. NRC (U.S. Nuclear Regulatory Commission). 2005. Before the Atomic Safety and Licensing Board, In the Matter of Louisiana Energy Services, L.P., National Enrichment Facility: Direct Testimony Of Dr. Arjun Makhijani Regarding Nuclear Information And Resource Service and Public Citizens Contention EC-4. ASLBP No. 04-826-01-ML.

January 7, 2005. ML050180335.

19. NRC (U.S. Nuclear Regulatory Commission). 2012. Materials License SUB-1011, issued to International Isotopes Fluoride Products, Inc. Washington, D.C. October 2, 2012.

ML12234A496.

20. NRC (U.S. Nuclear Regulatory Commission). 2012. NUREG-2113, Environmental Impact Statement for the Proposed Fluorine Extraction Process and Depleted Uranium Deconversion Plant in Lea County, New Mexico. Washington, D.C. August 2012.

ML12220A380.

21. NRC (U.S. Nuclear Regulatory Commission). 2012. NUREG-2116, Safety Evaluation Report for the International Isotopes Fluorine Products, Inc. Fluorine Extraction Process and Depleted Uranium Deconversion Plant in Lea County, New Mexico. Washington, D.C. May 2012. ML12145A504.

22. NRC (U.S. Nuclear Regulatory Commission). 2005. NUREG-1790, Environmental Impact Statement for the Proposed National Enrichment Facility in Lea County, New Mexico. Washington, D.C. June 2005. https://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1790/v1/index.html.

23. NRC (U.S. Nuclear Regulatory Commission). 2005. Atomic Safety and Licensing Board Order LBP-05-13, In the Matter of Louisiana Energy Services, L.P. (National Enrichment Facility). Washington, D.C. June 8, 2005. ML060740251 (page 385).

24. NRC (U.S. Nuclear Regulatory Commission). 2005. CLI-05-28 Memorandum and Order, In the Matter of Louisiana Energy Services, L.P. (National Enrichment Facility).

Washington, D.C. November 21, 2005. ML053250203.

25. NRC (U.S. Nuclear Regulatory Commission). 2015. Environmental Assessment for the Proposed Louisiana Energy Services, Urenco USA Uranium Enrichment Facility Capacity Expansion in Lea County, New Mexico. Washington, D.C. March 2015.

ML15072A016.

26. NRC (U.S. Nuclear Regulatory Commission). Email re: Acceptance of LAR 23-07 to Delete License Condition 14. February 5, 2024. ML24037A190.

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27. NRC (U.S. Nuclear Regulatory Commission). Federal Register notice re: Louisiana Energy Services, LLC, dba Urenco USA; National Enrichment Facility; License Amendment Application: Opportunity to request a hearing and to petition for leave to intervene. Federal Register Volume 90, Issue 18. January 29, 2025. 90 FR 8407.

28. UUSA (Urenco USA). 2023. UUSA License Amendment Request LAR 23-07, Revise SNM-2010 to Delete License Condition 14. September 1, 2023. ML23244A190.

29. UUSA (Urenco USA). 2025. Revised Response to Request for Supplemental Information Regarding LAR 23-07. February 6, 2025. ML25038A014.

30. NRC (U.S. Nuclear Regulatory Commission). Email to New Mexico Environment Department re: Draft for State Review - EA for amendment to delete LC 14. April 4, 2025. ML25125A247.