ML25169A161
| ML25169A161 | |
| Person / Time | |
|---|---|
| Site: | 07003103 |
| Issue date: | 06/18/2025 |
| From: | Louisiana Energy Services, URENCO USA |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML25169A156 | List: |
| References | |
| LES-25-082-NRC LAR-25-02 | |
| Download: ML25169A161 (1) | |
Text
LES-25-082-NRC LAR-25-02 ENCLOSURE 4 Mark-up Pages to the Safety Analysis Report (LAR-25-02)
Export Controlled Information SAFETY ANALYSIS REPORT Markups for LAR-25-02
3.6 Chapter 3 Tables Safety Analysis Report Page-3.6-3 LAR-25-02 Table 3.1-3 Consequence Severity Categories Based on 10 CFR 70.61 Workers Offsite Public Environment Category 3 High Consequence Radiation Dose (RD) >1 Sievert (Sv)
(100 rem)
Chemical Dose (CD) > AEGL-3 for HF CD > AEGL-3 for U RD > 0.25 Sv (25 rem) 30 mg sol U intake CD > ERPG-2AEGL-2 Category 2 Intermediate Consequence 0.25 Sv (25 rem) <RD 1 Sv (100 rem)
AEGL-2 < CD AEGL-3 for HF AEGL-2 < CD < AEGL for U 0.05 Sv (5 rem) < RD 0.25 Sv (25 rem)
ERPG-1 < CD ERPG-2AEGL-1 <CD AEGL-2 Radioactive release
> 5000 x Table 2 Appendix B of 10 CFR Part 20 Category 1 Low Consequence Accidents of lower radiological and chemical exposures than those above in this column Accidents of lower radiological and chemical exposures than those above in this column Radioactive releases with lower effects than those referenced above in this column Notes:
- The worker that causes the release is expected to immediately sense and recognize the release and will not receive a dose significantly greater than a worker elsewhere in the room.
3.6 Chapter 3 Tables Safety Analysis Report Page-3.6-4 LAR-25-02 Table 3.1-4 Chemical Dose Information High Consequence (Category 3)
Intermediate Consequence (Category 2)
Worker
> 146 mg U/m3
> 139 mg HF/m3
> 19 mg U/m3
> 78 mg HF/m3 Public (outside controlled area)
(1-hr30-minequivalent exposure)
> 1013 mg U/m3
> 16.428 mg HF/m3
> 3.42.4 mg U/m3
> 1.60.8 mg HF/m3 Table 3.1-5 Likelihood Categories Based on 10 CFR 70.61 Likelihood Category Probability of Occurrence*
Not Unlikely 3
More than 10-4 per-event per-year Unlikely 2
Between 10-4 and 10-5 per-event per-year Highly Unlikely 1
Less than 10-5 per-event per-year
- Based on approximate order-of-magnitude ranges
6.3 Chemical Hazards Analysis Safety Analysis Report Page-6.3-4 LAR-25-02 Public Exposure Assumptions Potential exposures to members of the public were also evaluated assuming conservative assumptions for both exposure concentrations and durations. Exposure was evaluated for consequence severity against chemotoxic, radiotoxic, and radiological dose.
Consequence calculations for the Public conservatively assume a one hour equivalent dose consistent with the corresponding ERPG limits. Public exposures were estimated to last for a duration of 30 minutes. This is consistent with Per the self-protective criteria for UF6/HF plumes listed in NUREG-1140, realistically people can be expected to move from locations of dense smoke or irritating fumes to avoid inhalation.
6.3.2.2 Chemical Release Scenarios The evaluation level chemical release scenarios based on the criteria applied in the Integrated Safety Analysis are presented in the NEF Integrated Safety Analysis Summary. Information on the criteria for the development of these scenarios is also provided in the NEF Integrated Safety Analysis Summary.
6.3.2.3 Source Term The methodologies used to determine source term are those prescribed in NUREG/CR-6410 and supporting documents. If calculated release rates are not determined, UUSA will conservatively assume the entire source term is released within one hour. The following methodologies are approved by the U.S. Nuclear Regulatory Commission:
The meteorological data is five years (1987-1991) collected at Midland/Odessa, Texas, which is the closest first order National Weather Service Station to this site. This station was judged to be representative of the NEF site because the Midland Odessa National Weather Service Station site and the NEF site have similar climates and topography. Under assumed worse case conditions, the NEF uses stability class F at 1.00.6 meter per second wind speed for evaluation of public consequences. These very adverse meteorology conditions result in minimal dilution and high plume centerline doses, but also very narrow plumes.
Regulatory Guide 1.145 Dispersion Methodology In estimating the dispersion of chemical releases from the facility, conservative dispersion methodologies were utilized. Site boundary atmospheric dispersion factors were generated using a computer code based on Regulatory Guide 1.145 (NRC, 1982) methodology.
The specific modeling methods utilized follow consistent and conservative methods for source term determination, release fraction, dispersion factors, and meteorological conditions as prescribed in NRC Regulatory Guide 1.145 (NRC, 1982).
ARCON96 Dispersion Methodology The NRC recognized dispersion methodology is the ARCON96 model developed by the NRC and documented in NUREG/CR-6331, Rev.1 (NRC, 1997).
The specific modeling methods utilized follow consistent and conservative methods for source term determination, release fraction, dispersion factors, and meteorological conditions as
6.3 Chemical Hazards Analysis Safety Analysis Report Page-6.3-5 LAR-25-02 prescribed by the NRC. The NEF may use a Hand Calculation to determine the dispersion or the NEF may use the code ARCON96 with validation and verification documentation.
RASCALRASCAL 3.0.5 Dispersion Methodology The NRC recognized dispersion methodology is the Radiological Assessment System for Consequence Analysis (RASCAL). Prior consequence analysis performed by NEF used the RASCAL 3.0.5 model developed by the NRC and documented in NUREG-1887 (NRC, 2007).
The most current NRC recognized dispersion methodology is the RASCAL 4.3.4 model developed by the NRC and documented in NUREG-1940 (NRC, 2015).
The specific modeling methods utilized follow consistent and conservative methods for source term determination, release fraction, dispersion factors, and meteorological conditions as prescribed by the NRC. The NEF may continue to rely onuse the RASCAL 3.0.5 code with validation and verification (V&V) documentation for previously completed consequence analyses. All revisions to prior consequence analysis and all new analyses for the Public and Environment will use the RASCAL 4.3.4 code that was V&Vd by the RASCAL developers as noted in NUREG-1940.
6.3.2.4 Chemical Hazard Evaluation This section is focused on presenting potential deleterious effects that might occur as a result of chemical release from the facility. As required by 10 CFR 70 (CFR, 2003a), the likelihood of these accidental releases fall into either unlikely or highly unlikely categories.
Potential Effects to Workers/Public The toxicological properties of potential chemicals of concern were detailed in Section 6.2, Chemical Process Information. The evaluation level accident scenarios identified in the Integrated Safety Analysis and the associated potential consequence severities to facility workers or members of the public are presented in the NEF Integrated Safety Analysis Summary.
All postulated incidents have been determined to present low consequences to the workers/public, or where determined to have the potential for intermediate or high consequences, are protected with IROFS to values less than the likelihood thresholds required by 10 CFR 70.61 (CFR, 2003b).
Potential Effects to Facility All postulated incidents have been determined to present inherently low consequences to the facility. No individual incident scenarios were identified that propagate additional consequence to the facility process systems or process equipment. The impact of external events on the facility, and their ability to impact process systems or equipment of concern is discussed in the NEF Integrated Safety Analysis Summary.
6.5 References Safety Analysis Report Page-6.5-1 LAR-25-02 References Edition of Codes, Standards, NRC Documents, etc that are not listed below are given in ISAS Table 3.0-1.
CFR, 2003a. Title 10, Code of Federal Regulations, Part 70, Domestic Licensing of Special Nuclear Material, 2003.
CFR, 2003b. Title 10, Code of Federal Regulations, Section 70.61, Performance requirements, 2003.
CFR, 2003c. Title 10, Code of Federal Regulations, Section 70.62, Safety program and integrated safety analysis, 2003.
CFR, 2003d. Title 10, Code of Federal Regulations, Section 70.64, Requirements for new facilities or new processes at existing facilities, 2003.
CFR, 2003e. Title 10, Code of Federal Regulations, Part 20 Appendix B, Annual Limit on Intake (ALIs) and Derived Air Concentrations (DACs) of Radionuclides for Occupational Exposure; Effluent Concentrations; Concentrations for Release to Sewerage, 2003.
CFR, 2003f. Title 29, Code of Federal Regulations, Section 1910.119, Process safety management of highly hazardous chemicals, 2003.
CFR, 2003g. Title 40, Code of Federal Regulations, Part 68, Accidental Release Prevention Requirements, 2003.
CFR, 2003h. Title 29, Code of Federal Regulations, Part 1910, Occupational Safety and Health Standards, 2003.
CFR, 2004. Title 29, Code of Federal Regulations, Section 1910.120, Hazardous waste operations and emergency response, 2004.
DOE, 1988. Monitoring of Corrosion in ORGDP Cylinder Yards, presented at DOE Conference
- Uranium Hexafluoride - Safe Handling, Processing, and Transporting, Henson, H.M., et al, 1988.
NAP, 2004. Acute Exposure Guideline Levels for Selected Airborne Chemicals, Volume 4, National Research Council of the National Academies, National Academies Press, 2004.
NRC, 1982. Atmospheric Dispersion Models for Potential Accident Consequence Assessments at Nuclear Power Plants, Regulatory Guide 1.145, Revision 1, U.S. Nuclear Regulatory Commission, November 1982. (Reissued February 1983 to correct page 1.145-7)
NRC, 1997. Atmospheric Relative Concentrations in Building Wakes, NUREG/CR-6331, Rev.1 U.S. Nuclear Regulatory Commission, May 1997 NRC, 2007. RASCAL 3.0.5: Description of Models and Methods, NUREG-1887, U.S. Nuclear Regulatory Commission, August 2007 NRC, 2015. RASCAL 4.3: Description of Models and Methods, NUREG-1940, U.S. Nuclear Regulatory Commission, May 2015 ORNL, 2001. Prediction of External Corrosion for Steel Cylinders - 2001 Report, ORNL/TM-2001/164, Oak Ridge National Laboratory, Schmoyer and Lyon, September, 2001.
6.6 Chapter 6 Tables Safety Analysis Report Page-6.6-9 LAR-25-02 Table 6.3-2 Licensed Material Chemical Consequence Categories Workers Offsite Public Environment Category 3 High Consequence Radiation Dose (RD) >1 Sievert (Sv)
(100 rem)
For the worker (elsewhere in room),
except the worker (local),
Chemical Dose (CD) > AEGL-3 For worker (local),
CD > AEGL-3 for HF CD >
- for U RD > 0.25 Sv (25 rem) 30 mg sol U intake CD > ERPG-2AEGL-2 Category 2 Intermediate Consequence 0.25 Sv (25 rem) <RD 1 Sv (100 rem)
For the worker (elsewhere in room),
except the worker (local),
AEGL-2 < CD AEGL-3 For the worker (local),
AEGL-2 < CD AEGL-3 for HF
- < CD
ERPG-1 < CD ERPG-2 AEGL-1 <CD AEGL-2 Radioactive release
> 5000 x Table 2 Appendix B of 10 CFR Part 20 Category 1 Low Consequence Accidents of lower radiological and chemical exposures than those above in this column Accidents of lower radiological and chemical exposures than those above in this column Radioactive releases with lower effects than those referenced above in this column Notes:
- NUREG-1391 threshold value for intake of soluble U resulting in permanent renal failure
- NUREG-1391 threshold value for intake of soluble U resulting in no significant acute effects to an exposed individual Table 6.3-3 ERPG and AEGL values for HF ERPG and AEGL Values For HF (values in mg HF/m3)
ERPG AEGL 1-hr 10-min 30-min 1-hr 4-hr 8-hr ERPG-1 1.6 AEGL-1 0.82 0.82 0.82 0.82 0.82 ERPG-2 16.4 AEGL-2 78 28 20 9.8 9.8 ERPG-3 41 AEGL-3 139 51 36 18 18
6.6 Chapter 6 Tables Safety Analysis Report Page-6.6-10 LAR-25-02 Table 6.3-4 ERPG and AEGL values for Uranium Hexafluoride (as soluble U)
ERPG and AEGL Values For UF6 (values in mg soluble U/m3)
ERPG AEGL 1-hr 10-min 30-min 1-hr 4-hr 8-hr ERPG-1 3.4 AEGL-1 2.4 2.4 2.4 NR NR ERPG-2 10 AEGL-2 19 13 6.5 1.6 0.8 ERPG-3 20 AEGL-3 146 49 24 6.1 3.1 Table 6.3-5 Definition of Consequence Severity Categories High Consequence (Category 3)
Intermediate Consequence (Category 2)
Acute Radiological Doses Worker
> 25 rem TEDE Environment (Outside Restricted Area)
Outside Controlled Area
> 5 rem TEDE Acute Radiological Exposure Worker Environment (Outside Restricted Area)
> 5.4 mg U/m3 (24-hr average)
Outside Controlled Area
> 30 mg U intake Acute Chemical Exposure Worker
> 146 mg U/m3;
> 139 mg HF/m3
> 19 mg U/m3;
> 78 mg HF/m3 Environment (Outside Restricted Area)
Outside Controlled Area (30-min1-hr equivalent exposure)
> 1013 mg U/m3;
> 16.428 mg HF/m3
> 3.42.4 mg U/m3;
> 1.60.8 mg HF/m3
- - Not a 10 CFR 70.61 performance requirement.
Table 6.3-6 Health Effects from Intake of Soluble Uranium Health Effects Uranium Intake (mg) by 70 kg Person 50% Lethality 230 Threshold for Intake Resulting in Permanent Renal Damage 40 Threshold for Intake Resulting in No Significant Acute Effects 10 No Effect 4.3