ML25232A170

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Enclosure - Request for Additional Information LES LAR 25-02 (ISA)
ML25232A170
Person / Time
Site: 07003101
Issue date: 08/26/2025
From:
NRC/NMSS/DFM/FFLB
To:
Louisiana Energy Services
Shared Package
ML25232A169 List:
References
Download: ML25232A170 (1)


Text

Enclosure REQUEST FOR ADDITIONAL INFORMATION LOUISIANA ENERGY SERVICES, LLC LICENSE AMENDMENT REQUEST 25-02 SPECIAL NUCLEAR MATERIAL LICENSE NO. SNM-2010 DOCKET NO. 07003103 Integrated Safety Analysis (ISA)

The following requests for additional information are necessary to facilitate the U.S. Nuclear Regulatory Commission (NRC) staffs technical review of the Louisiana Energy Services, LLC, dba Urenco USA (UUSA), license amendment request to revise the ISA Methodology.

RAI-ISA-1 Regulatory Basis:

Title 10 of the Code of Federal Regulations (10 CFR), Paragraph 70.62(c), Integrated safety analysis, requires licensees to conduct and maintain an integrated safety analysis, that is of appropriate detail for the complexity of the process, that identifies, in part:

(iv)

Potential accident sequences caused by process deviations or other events internal to the facility and credible external events; (v)

The consequence and the likelihood of occurrence of each potential accident sequence identified pursuant to paragraph (c)(1)(iv) of this Section, and the methods used to determine the consequences and likelihoods; and (vi)

Each item relied on for safety identified pursuant to §70.61(e) of this Subpart, the characteristics of its preventive, mitigative, or other safety function, and the assumptions and conditions under which the item is relied upon to support compliance with the performance requirements of §70.61.

Guidance in Section 3.4.3.2 of NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications, Revision 2, states that the ISA Summary should provide the basis for the reviewer to conclude that there is reasonable assurance that the identified items relied on for safety will satisfy the performance requirements of 10 CFR 70.61.

Description of Issue: of the license amendment request, Description of Proposed Changes to ISA Methodology (LAR 25-02) provides a detailed description of the proposed changes. Section 3.2 notes: UUSA further proposes to a change in SAR [Safety Analysis Report] § 6.3.2.3, Source Term, to state that if calculated release rates are not determined, UUSA will conservatively assume the entire source term is released within one hour.

Information Needed:

The text change appears to allow for the possibility of assuming a 1-hour release in cases where such an assumption would be non-conservative. Clarify that the 1-hour assumption will only be used in cases where such an assumption is reasonable (or conservative).