ML25317A573
| ML25317A573 | |
| Person / Time | |
|---|---|
| Site: | 07007033 |
| Issue date: | 10/06/2025 |
| From: | Porterfield D - No Known Affiliation |
| To: | Office of Administration |
| References | |
| NRC-2025-1007, 90FR42988 00006 | |
| Download: ML25317A573 (1) | |
Text
PUBLIC SUBMISSION As of: 11/13/25, 9:41 AM Received: October 06, 2025 Status: Posted Posted: October 29, 2025 Tracking No. mge-nyxv-5s32 Comments Due: October 06, 2025 Submission Type: Web Docket: NRC-2025-1007 Global Laser Enrichment, LLC; Paducah Laser Enrichment Facility, McCracken County, Kentucky; Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement Comment On: NRC-2025-1007-0001 Global Laser Enrichment, LLC; Paducah Laser Enrichment Facility; Notice of Intent To Conduct Scoping Process and Prepare Environmental Impact Statement Document: NRC-2025-1007-0007 Comment from Donivan Porterfield on Global Laser Enrichment, LLC; Paducah Laser Enrichment Facility, McCracken County, Kentucky; Notice of Intent to Conduct Scoping Process and Prepare Environmental Impact Statement Submitter Information Name: Donivan Porterfield Address:
Los Alamos, NM, 87544 Email:donivanporterfield@hotmail.com General Comment See attached file(s)
Attachments NRC-2025-1007_Global_Laser_Enrichment_public_comment_porterfield_2025oct05 11/13/25, 9:43 AM NRC-2025-1007-0007.html file:///C:/Users/BHB1/Downloads/NRC-2025-1007-0007.html 1/1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: Amy Minor, Mary Neely Comment (6)
Publication Date:
9/5/2025 Citation: 90 FR 42988
Mr. Donivan Porter"eld October 5, 2025 Robert Sun Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Re: Docket No. 70-7033; EISX-429-00-000-1754990851; NRC-2025-1007 In response to the invitation for public comments in the Federal Register (Vol. 90, No. 170, pages 42988 and 42989, Friday, September 5, 2025) on the Notice of Intent to Conduct a Scoping Process and Prepare an Environmental Impact Statement for the Global Laser Enrichment Paducah Laser Enrichment Facility (PLEF) I provide the following.
Comment 1 Proposed Action - Any gaseous releases from areas inside the main OB in which UF6 is handled and processed would be captured and routed through a multi-stage air emission control system.
4.12.2.2.2.1, Atmospheric Release Dose Pathway - The design control efficiency for the emission control system would be at least 99.98 percent removal (by weight) of uranium particles.
The quoted 99.98 percent removal is suggestive of the performance of a single-stage HEPA "lter but it is suggested in the other statement that a multi-stage air emission control system would be used. So, this leaves the question of whether the multi-stage air emission control system would achieve the overall performance of a single-stage HEPA "lter or whether the overall performance of the system would be much better through multiple HEPA "lters?
Comment 2 Consideration of Alternatives to the Proposed Action - Further, the U.S. Government committed to support the commercialization of laser technology under the U.S.-SILEX Treaty. This treaty between the U.S. and Australian government outlined the obligations associated with transferring the laser technology to the U.S. for commercialization and deployment.
Mr. Donivan Porter"eld The text describes this as a treaty but the document at ML091680573 is titled as Agreement for Cooperation between Australia and the United States of American Concerning Technology for the Separation of Isotopes of Uranium by Laser Excitation. So, is this agreement considered as a treaty under U.S. law?
Secondly, per the terms of the agreement would any uranium product from the PLEF not be allowed to be further enriched at a later time to weapons grade for miliary application?
Comment 3 1.3, Proposed Action - The PLEF would also process depleted UF6 currently stored at PGDP containing less than approximately 0.5 percent by weight of 235U and enrich that depleted UF6 back to the natural enrichment level of 0.71 percent by weight of 235U, Are any of the uranium materials anticipated to be processed at the PLEF represent recycled spent/used nuclear fuel or has been exposed to cross contamination from cascades / facilities exposed to same and thus may contain radionuclides such as 99Tc, 232U, 233U, 236U, 237Np, 239Pu, 240Pu, and/or 241Am?
Comment 4 1.4, Applicable Regulatory Requirements, Permits, and Required Consultations - This section describes the pertinent regulatory framework as it applies to the PLEF. The status of regulatory agency authorizations and consultations is summarized in Table 1-6.
Should there also be mention of IAEA purview of the PLEF when operational based on following information?
How is the NRC involved in the U.S. - IAEA Safeguards Agreement?
The NRC oversees and facilitates the application of IAEA safeguards at NRC and Agreement State licensed facilities. Licensee compliance with U.S. - IAEA Safeguards Agreement commitments is required by Title 10 of the Code of Federal Regulations (10 CFR); speci"cally, 10 CFR Parts 75 and 110. The NRC also supports U.S. Government negotiations between NRC licensees and the IAEA, transmits accounting reports to the IAEA, and participates in U.S Government coordinating committees such as the IAEA Steering Committee (ISC), the Subcommittee on International Safeguards and Monitoring (SISM) and the Subgroup on IAEA Safeguards in the U.S. (SISUS).
https://www.nrc.gov/materials/fuel-cycle-fac/intl-safeguards/iaea-safeguards-faq Comment 5
Mr. Donivan Porter"eld 2.1.2.4.2.1, Process Design for the PLEF - The GLE laser-based enrichment process would utilize lasers tuned to speci"c frequencies to selectively excite UF6 gas molecules to enable separation of the 235U isotope in uranium feed material.
The nature of the lasing media is not clear from the presented information. Is a solid-state lasing media used or are some of the chemicals noted in table 2-2 constitute a gaseous lasing media?
Comment 6 Table 3-73: Radionuclide Atmospheric Releases (in curies) for the PGDP Site Given that the PLEF GLE laser-based enrichment process is noted to operate quite differently from the legacy centrifuge and gaseous diffusion processes, may a difference in the isotopic abundances of laser-based uranium enrichment allow for legacy contamination to be distinguished from PLEF operations? For example, in the case of a uranyl "uoride particle captured on an air "lter, could the uranium isotopic abundances provide a unique signature that could establish connection to PLEF operations.
Comment 7 4.12.2.2, Radiological Impacts - The Nuclear Safety Function at the PLEF would be responsible for implementing the Nuclear Safety Program and preventing criticality and maintaining radiological safety for all aspects of the nuclear fuel processes, including radioactive material receipt, enrichment, conversion, fabrication, storage, and shipment of products.
4.12.2.2.2.3, Radiological Impacts Accident Analysis - As discussed in Section 4.12.2.1.2.3 (Non-Radiological Impacts Accident Analysis), the bounding radiological accidents identi"ed in the ISA for the Wilmington site are UF6 release and criticality (GLE, 2011).
Has any modeling been done to establish that a nuclear criticality accident within the PLEF, while only remotely possible, would not have any external dose or radiological contamination consequences external to the PLEF?
And that a criticality accident alarm system (CAAS) be included in the PLEF?
Comment 8
Mr. Donivan Porter"eld 4.12.2.2, Radiological Impacts - GLE operations would be conducted under procedures that are written, reviewed, and veri"ed by appropriate individuals in the Nuclear Safety Function to verify that worker dose is ALARA.
Would there be similar controls to ensure that any GLE operations would not compromise established criticality safety controls?
Comment 9 4.12.2.2, Radiological Impacts - Protective clothing (e.g., anti-contamination clothing, gloves, shoe covers, hats, steel-toe shoes, hard hat, safety glasses, respirators).
Consider instead composite-toe safety shoes.
Comment 10 4.13.2.2.2, Solid Wastes Is it anticipated that there would be any effort to clean out any present heels in received UF6 cylinders?
Comment 11 Table 6-2, Summary of Minimum Detectable Concentrations for Radiological Environmental Monitoring Program The air sample information should be accompanied by estimate of the air volume sampled.
It is unclear why the MDC values for gross alpha and gross beta are presented in such different units for Treated process wastewater effluent and Groundwater.
Given the mention of 99Tc in the area groundwater, it is unclear why this analyte is not also included in the groundwater analytes.
Comment 12 I was surprised to not see the topic of laser safety and use of interlocks addressed within.
Comment 13
Mr. Donivan Porter"eld 11, Glossary It is unclear why when beta radiation is addressed that alpha radiation is not similarly addressed.
Special Nuclear Material (SNM) - Nuclear material (e.g., plutonium, uranium-233, or uranium) enriched in the isotopes uranium-233 (233U) or uranium-235 (235U).
Consider instead: Special nuclear material" (SNM) is de"ned by Title I of the Atomic Energy Act of 1954 as plutonium, uranium-233, or uranium enriched in the isotopes uranium-233 or uranium-235, but does not include source material. The de"nition includes any other material that the Commission determines to be special nuclear material. The NRC has not declared any other material as special nuclear material.
https://www.nrc.gov/materials/types/sp-nucmaterials Consider including equivalent-natural uranium hexa"uoride (ENUF6) and criticality accident.
Thank you for the opportunity to provide the above public comments.
Mr. Donivan Porter"eld Los Alamos, NM