ML25338A301
| ML25338A301 | |
| Person / Time | |
|---|---|
| Site: | 07007038 |
| Issue date: | 12/23/2025 |
| From: | Osiris Siurano-Perez NRC/NMSS/DFM/FFLB |
| To: | Tekia Govan NRC/NMSS/DFM/FFLB |
| References | |
| Download: ML25338A301 (0) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 MEMORANDUM TO:
Tekia Govan, Acting Chief Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards FROM:
Osiris Siurano-Pérez, Project Manager Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
SUMMARY
OF AUGUST 28, 2025, PARTIALLY CLOSED MEETING WITH ORANO ENRICHMENT USA, LLC On August 28, 2025, the U.S. Nuclear Regulatory Commission (NRC) staff held a hybrid, partially closed meeting with representatives from Orano Enrichment USA, LLC (Orano), to continue discussions regarding Oranos plans for submitting an application to the NRC for a Title 10 of the Code of Federal Regulations Part 70, "Domestic Licensing of Special Nuclear Material," special nuclear materials license for the construction and operation of Project IKE, a uranium enrichment facility to be located in Oak Ridge, Tennessee. The purpose of the meeting was to discuss the codes and standards Orano intends to apply to the design and construction of the proposed facility. The meeting was divided into an open and a closed session.
A summary of this meeting is enclosed to this letter. The summary contains no proprietary or sensitive information. The NRC and Orano cognizant staff reviewed this summary for factual correctness.
Docket No. 07007038
Enclosure:
1.
Summary of Partially Closed Meeting with Orano: Codes and Standards Discussion cc: Peter Vescovi, Orano USA CONTACT: Osiris Siurano-Pérez, NMSS/DFM 301-415-7827 December 23, 2025 Signed by Siurano-Perez, Osiris on 12/23/25
ML25338A301 OFFICE NMSS/DFM/FFLB NMSS/DFM/FFLB NMSS/DFM/FFLB NMSS/DFM/FFLB NAME OSiurano-Pérez JGoodridge TGovan OSiurano-Pérez DATE 12/16/2025 12/17/2025 12/23/2025 12/23/2025
Enclosure Summary of Partially Closed Meeting with Orano Enrichment USA, LLC
Subject:
Structural Codes and Standards Discussion for Project IKE Date: August 28, 2025, Time: 9:50 a.m. - 12:00 p.m.
Meeting
Participants:
U.S. Nuclear Regulatory Commission (NRC)
Shana Helton Lindsey Cooke Gerond George Tekia Govan Diane Jackson Danté Johnson Samantha Lav Langston Lewis Juan Lopez Bharatkumar Patel Osiris Siurano-Pérez Benjamin Raticheck Lisa Regner Aditya Savara Yilia Vega-Claudio Brian Wagner Orano Enrichment USA, LLC (Orano)
Lionel Antognelli Rinaldo Hunt Sanjeev Malu Adam Shepard Amit Varma Peter Vescovi Paul Tiao Public Mike Annacone Summary of Discussions Open Session The NRC staff opened the meeting at 9:50 a.m. by providing an overview of the agenda and structure of the session. The NRC staff discussed the logistics for the meeting. The NRC staff stated that this was partially closed, with an open session intended for public participation and general discussion of Oranos approach to structural codes and standards, and a closed session where proprietary and security-related information was to be discussed.
2 Following this introduction, NRC management and Orano management present at the meeting provided introductory remarks. The NRC managers emphasized the importance of early engagement to streamline the licensing process and encouraged clarity in identifying differences between the proposed Project IKE application and the previously reviewed AREVA Eagle Rock Enrichment Facility (EREF) application to avoid duplicative regulatory review. The NRC staff noted that the NRCs new pre-application engagement process had already demonstrated success in reducing review timelines and emphasized the importance of high-quality applications that minimize the need for requests for supplemental information. The NRC staff also noted that natural phenomena hazards and structural standards would be a key area of focus for this application.
Following introductions of the meeting participants, Orano representatives provided an overview of their company and discussed the Project IKE timeline. The facility would be located in Oak Ridge, Tennessee, and would be similar in design to the previously licensed EREF. Orano representatives noted that Orano intends to submit its license application in early 2026, with construction and operations to follow in subsequent years.
The Orano representatives outlined their objectives for the meeting, which included presenting Oranos proposed framework for applying structural codes and standards in a manner commensurate with the risk profile of an enrichment facility. Orano representatives emphasized that Orano is not proposing to build a reactor and that the structural design approach should reflect the lower risk associated with enrichment operations.
The NRC staff and Orano discussed the recent NRC position paper on the designation of buildings as items relied on for safety (IROFS). The NRC staff clarified that buildings must meet the baseline design criteria in Title 10 of the Code of Federal Regulations (10 CFR) Sections 70.64(b)(2) and that whether a building is designated as an IROFS depends on the site-specific integrated safety analysis (ISA). If a building is credited in the ISA, it must be maintained accordingly. If not designated as an IROFS, an exemption may be sought with justification.
Following the above-described discussion, brief questions and answers (Q&A) session followed.
The NRC staff inquired whether Oranos approach to structural codes differed from the EREF application. Orano confirmed that there would be some differences, which were being discussed in detail during the closed session of the meeting.
After the Q&A session, the public was afforded an opportunity to ask questions or provide comments on the topics discussed during the meeting. However, no questions or comments were received from the public.
The open session concluded with closing remarks from both the NRC and Orano staffs who thanked participants and expressed appreciation for the collaborative engagement. The meeting then transitioned to the closed session.
Closed Session The NRC staff opened the closed session by explaining the purpose and regulatory basis under 10 CFR 2.390(d)(1) for categorizing the meeting as closed to the public. Following these introductory remarks, Orano proceeded with its presentation. The session focused on codes and standards for Oranos proposed uranium enrichment facility, Project IKE.
3 Orano started its presentation by discussing the background education and experience of its subject matter experts (SMEs), which led the discussions. Oranos SMEs presented a framework for applying commercial codes with enhancements, rather than nuclear-specific standards, to streamline construction while maintaining safety. Clarification on the definition of credible events in the context of ISA and on risk categories was provided. A general discussion on events with a frequency of 10/year or higher was held. The NRC staff emphasized that such events are considered credible and must be analyzed.
The discussion covered risk categories defined in 10 CFR Part 70 and NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications. Risk categories include: highly unlikely events, which must meet an annual failure risk of 10 or less, and unlikely events, which must meet 10 or less. Orano discussed how these categories relate to performance levels.
The Orano SMEs introduced the Design Basis Designations (DBDs) concept as a method to assign performance expectations to structures based on risk and function. The NRC staff emphasized that performance expectations (or levels) should align with potential consequences and not just on likelihood.
Oranos SMEs discussed the rationale for using commercial codes with enhancements, rather than nuclear-specific standards to avoid the binary burden of the American Society of Mechanical Engineers standard Nuclear Quality Assurance Requirements for Nuclear Facility Applications" NQA-1. The NRC staff acknowledged that 10 CFR Part 70 allows for grading of management measures and emphasized the importance of clear documentation and justification.
Although the Orano SMEs provided answers to the NRC staff questions throughout the discussions, an additional, brief Q&A session was held. The session concluded with agreement on the need for continued collaboration as the ISA is finalized and DBD matrices are populated.
Following this session, the meeting was adjourned at approximately 12:00 p.m.
Action Items For NRC staff:
1.
Continue to provide feedback on Oranos proposed approach to structural codes and IROFS designation.
2.
Provide Orano a copy of Interim Staff Guidance 15.
3.
Provide Orano a copy of the tornado hazard guidance (e.g., NUREG/CR-4461).
4.
Provide Orano information and guidance on credible events.
4 For Orano:
1.
Ensure alignment with 10 CFR 70.64(b)(2) and clarify any exemptions or alternative approaches in the license application.
2.
Finalize ISA and begin mapping IROFS to DBDs.
3.
Develop correlation matrix comparing proposed performance levels to American Nuclear Society 2.26 and DOE-STD-1020.
4.
Request scheduling a follow-up meeting in September/October to review DBD selections and methodology.
PRINCIPAL CONTRIBUTOR Osiris Siurano-Pérez, NMSS/DFM