ML23334A130

Louisiana Energy Services, LLC, Environmental Information

ML23334A130
Person / Time
Site:	07003103
Issue date:	11/30/2023
From:	Louisiana Energy Services
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML23334A121	List: ML23334A122 ML23334A123 ML23334A125 ML23334A130
References
LES-23-103-NRC
Download: ML23334A130 (1)

Text

LES-23-103-NRC

Enclosure 8

Environmental Information

LAR 23-02

LES-23-103-NRC

Environmental Information for LEU+ Production License Amendment Request (LAR) 23 -02

1.0 Introduction

The Materials License (SNM-2010) issued by the U.S. Nuclear Regulatory Commission (NRC) to Louisiana Energy Services (LES) (dba UUSA) authorizes UUSA to receive, acquire, possess and transfer byproduct, source, and special nuclear material as designated in the License. The current licensed limit for enriched uranium (235U) is 5.5 weight percent (w/o). In order to meet forecast nuclear industry needs for Uranium Hexafluoride (UF6) enriched to less than 10 w/o 235U, LES is proposing a License Amendment Request (LAR) (LAR 23-02) to obtain regulatory authorization to produce, possess, handle and store UF6 enriched to less than 10 w/o 235U. UF6 enriched to greater than 5 w/o 235U and less than 10 w/o 235U is known as Low Enriched Uranium + (LEU+). This LAR is being submitted to the NRC pursuant to the requirements of Materials License SNM-2010, License Condition 30 and 10 CFR 70.72(d)(1), and in accordance with 10 CFR 70.34.

LAR 23-02 is limited in scope in that it is proposing authorization for the production of LEU+

without the reliance on the installed recycling handling systems and components, for which analyses and evaluations have not yet been completed, with the exception of the Gaseous Effluent Vent System (GEVS) which provides ventilation services to involved areas. Material and components exposed to LEU+ that are removed from production process systems authorized for less than 10 w/o 235U will be transferred, segregated and stored in evaluated on-site storage locations that ensure regulatory requirements are satisfied until a future LAR to utilize the recycling systems is approved by the NRC. The future LAR will propose and justify the use of the installed recycling systems and components and support systems for LEU+

handling that will be utilized at the UUSA facility, as well as evaluate potential environmental impacts of that action. The future LAR for these activities is a reasonably foreseeable action and is considered in Section 5, Assessment of Impacts.

UUSA submitted a Supplemental Environmental Report to the NRC in concert with a previous LAR 12-10 to increase the UUSA facility production capacity [LES 2012a]. The proposed production capacity was expanded from 3 to 10 million separative work units (MSWU). The gaseous effluents released from the facility were anticipated to be well below regulatory limits in 10 CFR 20, Standards for Protection Against Radiation. Occupational and public radiation exposures were well below the limits established in 10 CFR 20. The NRC review and findings regarding the facility capacity expansion were that the environmental impacts were SMALL to MODERATE and provided a Finding of No Significant Impact (FONSI) in March 2015 [N RC, 2015a].

Additionally, two previous LARs were submitted to the NRC related to raising enrichment possession and production limits:

1. An authorization request to increase the enrichment possession limit from 5.0 w/o 235U to 5.5 w/o 235U (LAR 13-02) [LES 2013] and,

2. An authorization request that included all necessary processes, systems and components for the UUSA site to produce up to 5.5 w/o 235U (LAR 19-01) [LES, 2019]

LAR 23-02

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The NRC review and evaluation of b oth LARs for raising the enrichment limits concluded there were no significant environmental impacts based on review of the criteria in 10 CFR 51.60(b)(2) and a supplement to the Environmental Report was not necessary for either LAR. Therefore, the NRC determined both LARs met the criteria for, and were determined to be, Categorical Exclusions under 10 CFR 51.22(c)(11) [NRC 2013] [NRC, 2020].

10 CFR 51.60(b)(2) requires that an environmental report be prepared and submitted for issuance of an amendment that would authorize or result in:

(i) a significant expansion of a site (ii) a significant change in the types of effluents (iii) a significant increase in the amounts of effluents (iv) a significant increase in individual or cumulative occupational radiation exposure (v) a significant increase in the potential for or consequences from radiological accidents, or (vi) a significant increase in spent fuel storage capacity A review and evaluation of the scope of LAR 23-02 is included in this environmental information discussion, as well as considerations of cumulative impacts, and demonstrates that an environmental report, or supplement, is not required for the Proposed Action and that a Categorical Exclusion pursuant to 10 CFR 51.22(c)(11) is appropriate.

The proposed changes to the Materials License and supporting Licensing Documents were reviewed for potential environmental impact referencing guidance in NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs

[NRC 2003] and include the topical areas identified in Section 3.3.

UUSA has analyzed the 30B product cylinder and intends to use it for less than 10 w/o 235U and has determined its satisfactory capability for the higher enrichment. Additionally, the NRC has approved the Orano DN30-X transportation package for domestic shipments in either the 30B-10 or 30B-20 product cylinders [NRC, 2023a]. UUSA also intends to have the ability to use the Orano 30B-10 product cylinder for less than 10 w/o 235U. Both cylinders are compatible with existing facilities and physical equipment and changes are not anticipated for their use with LEU+.

There are no physical changes needed for the Uranium Byproduct Cylinder (UBC) Storage Pad as UUSA does not intend to store filled LEU+ product cylinders on the UBC Storage Pad/Outdoor Cylinder Storage Areas. Filled product cylinders have been evaluated for safe storage in the Cylinder Receipt and Dispatch Building (CRDB) and Separations Building Modules (SBMs) in triple stacked arrays that are infinite in two dimensions (x and y planes).

This environmental information discussion is provided to discuss any potential environmental impacts of the Proposed Action and future LAR and provides the basis for the Categorical Exclusion.

LAR 23-02

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2.0 The Proposed Action

The Proposed Action in LAR 23 -02 is to increase the enrichment limit for the production, storage and handling of enriched UF 6 from the current license limit of 5.5 w/o 235U to less than 10 w/o 235U at the UUSA facility in Eunice, New Mexico. The LAR is to also increase the possession limit of 235U to up to 10.8 w/o 235U in a limited quantity to allow for cascade process fluctuations, inefficiencies, instrument tolerances when producing product near the revised licensed limit, but not exceed the license limit of less than 10 w/o 235U for product at the assay.

The regulatory authorization for these licensed increases for enrichment is proposed and justified in LAR 23-02, Enclosure 2. Additionally, included in the LAR 23-02, Enclosure 2, are other administrative changes to the Materials License to allow for:

• using the 30B product cylinder at an enrichment greater than 5 w/o but less than 10 w/o 235U

• using the 30B-10 product cylinder for on-site use for LEU+

o DN30-X transportation package cylinder was approved by the NRC for transportation, which included the 30B-10 and 30B-20 product cylinders

[NRC, 2023]

• exempting the 30B-10 cylinder from marking, consistent with the currently exempted 30B product cylinder (Materials License SNM-2010 License Condition 32)

• limiting an approved exemption to only the 30B product cylinder at an enrichment limit < 5 w/o 235U on the Outdoor 30B Cylinder Storage Areas (Materials License SNM-2010 License Condition 33)

• changing the methodology for criticality evaluations in Safety Analysis Report Chapter 5 The Proposed Action to produce less than 10 w/o 235U is limited to those processes, systems and components that are needed to only produce, handle and store LEU+ at the UUSA site.

The Proposed Action does not include use of the recycling system processes and components, with the exception of the Gaseous Effluent Vent System (GEVS). The excluded recycling system processes and components will be addressed in a separate future licensing action and contain an environmental information discussion with a Proposed Action that addresses the recycling systems and support systems and the potential impacts on the same topical areas resulting from this document.

The Proposed Action for LAR 23-02 does not include authorization for domestic or international shipping or transportation of LEU+.

Other relevant documents concerning raising the enrichment limit at the UUSA facility are discussed in Section 1.0, Introduction, above.

LAR 23-02

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3.0 The Need for the Proposed Action

The need for the Proposed Action is that the nuclear industry is pursuing fuels with slightly higher enrichments than 5.0 w/o 235U for reactors to support industry initiatives, such as Accident Tolerant Fuel (ATF) and Extended Fuel Cycle fuels. Along with other potential fuel changes, slight increases in fuel enrichment can:

• Have better performance in design basis and severe accident conditions

• Widen existing safety margin for nuclear plants

• Extend operating cycles between refueling outages

• Reduce nuclear plant operational and maintenance costs UUSA and other domestic nuclear commercial reactor operators and designers are pursuing advancements in fuel and enrichment in concert with reactor designs that include increasing 235U enrichment from low enrichment (less than 5 w/o 235U) to LEU+ in order to support these initiatives.

Materials License SNM-2010 issued by the NRC to LES authorizes UUSA to receive, acquire, possess and transfer byproduct, source, and special nuclear material as designated.

Furthermore, License Condition 6B specifies, in part, the type of special nuclear material as "Uranium enriched in isotope 235U up to 5.5 percent by weight (wt. percent) and uranium daughters" The need for the Proposed Action is to authorize UUSA to only produce, handle and store UF6 enriched material to less than 10 w/o 235U in preparation to support the nuclear industry objectives as identified and make conforming changes in appropriate License Basis Documents, which are contained in this LAR submittal.

LAR 23-02

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4.0 Environmental Impacts of the Proposed Action

UUSA will use existing facilities and equipment within the established site boundaries to accomplish the Proposed Action. The product cylinders for LEU+ will be the 30B and 30B -10 product cylinders as indicated in LAR 23-02, Enclosure 2. Both types of product cylinders have been analyzed and satisfactorily evaluated for use at enrichments up to 10 w/o 235U and are compatible with existing equipment configurations, resulting in no known operational process changes with their use. Filled LEU+ product cylinders will be stored in the CRDB and SBMs and not outside on the Outdoor Cylinder Storage Areas. LEU+ product cylinder storage arrays in the CRDB and SBMs have been analyzed and evaluat ed and are addressed in LAR 23-02. Additionally, UUSA is proposing a revision to the existing exemption in Materials License SNM-2010 License Condition 33 for the Criticality Accident Alarm System (CAAS) for storing 30B product cylinders on the Outdoor Cylinder Storage Areas. The proposed revision will limit the type of product cylinder addressed by the exemption to filled 30B cylinders with < 5 w/o 235U, thus further prohibiting filled LEU+ product cylinders on the Outdoor Cylinder Storage Areas without CAAS coverage or future additional analysis and licensing action in order to extend the exemption to filled LEU+ product cylinders. Empty and clean 30B-10 cylinders will still be able to be stored on the Outdoor Cylinder Storage Areas.

There will be no construction of new facilities or modifications to existing building structures at the site in order to implement the Proposed Action.

The Proposed Action will not employ new technology for which UUSA has no prior experience and does not propose changes to the total material possession limits in Materials License SNM-2010. Potential impacts to the environment from the Proposed Action are limited to the production, handling and storage of UF6 at an enrichment value slightly higher than currently authorized. The installed recycling systems and components will not be utilized to implement this Proposed Action, with the exception of GEVS, which provides ventilation services to affected areas where LEU+ is produced, handled and stored. The administrative changes to the Materials License as described in LAR 23-02, Enclosure 2, have no potential to impact the environment.

Cumulative effects are those impacts on the environment which result from the Proposed Action when added to the past, present and reasonably foreseeable future actions when added to other past, present and reasonably foreseeable future actions regardless of what agency or person undertakes the action. The past, present and reasonably foreseeable future actions considered in assessing the cumulative impacts of the Proposed Action are included in the discussion in Section 5.0.

LAR 23-02

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4.1 Potentially Affected Environment

• Land Use Because the requested Proposed Action does not involve any new or altered land use, the review indicates there will be no land use impacts as a result of the Proposed Action.

• Transportation Transportation impacts were reviewed with respect to the number of feed cylinder arrivals at the facility and anticipated number of waste cylinder and LEU+ product cylinder shipments.

Feed Cylinders The number of feed cylinder deliveries is not expected to change, nor is the type of feed cylinder transportation vehicles for the Proposed Action.

Waste Cylinders Since this LAR only deals with the production handling and storage of LEU+ and waste systems are not employed, the number of waste cylinders from the facility is not expected to change. The type of waste cylinder transportation vehicles for the Proposed Action also will not change. The implementation of the future LAR to allow for use of recycling systems to decontaminate LEU+ exposed materials and components will not impact waste cylinders.

Product Cylinders The type of product cylinder transportation vehicles is not expected to change for the Proposed Action. However, the n umber of product cylinders transported is dependent on a number of factors, such as existing reactor fuel vendors future orders and new reactor fuel vendors demand for LEU+ and annual shipments may increase with LEU+. The future options for shipping LEU+ from the UUSA facility to customers may include:

1. Obtaining an exemption to certain NRC regulations and deviations from the Certificate of Compliance for the DN30 transportation package and obtaining a Special Permit Authorization from the U.S. Department of Transportation (DOT) to ship 30B cylinders in the DN30 transportation package.

2. When completely certified for domestic transportation of LEU+, utilize the DN30-X (DN30-10 for 10 w/o 235U) transportation package. The DN30-X (DN30-10 for 10 w/o 235U) transportation package has a mass capacity of 1460 kg UF6 when utilizing the 30B-10 product cylinder.

The impact of these options is discussed in Section 5.1.

LAR 23-02

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• Geology and Soils

Because the requested Proposed Action does not involve any geological or soil disturbance, the review indicates there will be no geology or soils impacts as a result of the Proposed Action.

• Water Resources The Proposed Action would not contribute to impacts on surface water in the region because there are no permanent or jurisdictional surface waters or drainage features within the UUSA site and there are no receiving waters for site runoff derived from the facility other than the detention/retention basins that control stormwater discharges. There are no plans to change the outdoor storage arrangements under this Proposed Action so there will be no changes in stormwater runoff impacts. Because the requested Proposed Action does not involve any new or altered uses or discharges to surface water or groundwater, the review indicates there will be no water resources impacts as a result of the Proposed Action.

• Ecological Resources Because the requested Proposed Action does not involve any alterations to terrestrial or aquatic habitats, the review indicates there will be no ecological resources impacts as a result of the Proposed Action.

• Air Quality Process building stacks would continue to release gaseous effluents that would be both radioactive (UF6) and non-radioactive hydrogen fluoride (HF). The principal function of GEVS is to protect both the operators during the connection/disconnection of UF 6 process equipment and the environment by collecting and cleaning all potentially hazardous gases from the facility prior to release to the atmosphere. Releases to the atmosphere would remain in compliance with regulatory limits. Potential health effects from process stack emissions are discussed in Section 5.3.1.

• Noise The requested Proposed Action does not involve any new or altered noise emissions, and therefore the review indicates there will be no additional noise impacts as a result of the Proposed Action.

• Historic and Cultural Resources Because the requested Proposed Action does not involve any disturbance of historic or cultural resources, the review indicates there will be no historic and cultural resources impacts as a result of the Proposed Action.

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• Visual/Scenic Resources Because the requested Proposed Action does not involve any visible changes to the facilities, the review indicates there will be no visual or scenic resource impacts as a result of the Proposed Action.

• Socioeconomics Because the requested Proposed Action does not involve any socioeconomic factors, the review indicates there will be no socioeconomic impacts as a result of the Proposed Action.

• Environmental Justice Because the requested Proposed Action does not involve changes to the current facilities, the review indicates there will be no environmental justice impacts as a result of the Proposed Action.

• Waste Management The installed recycling systems and components at UUSA, with the exception of GEVS, will not be utilized to implement the Proposed Action in LAR 23 -02. Therefore, a significant increased generation of recycling waste is not anticipated. Components removed from LEU+ exposed systems, which retain future value, are not considered wastes and they will be appropriately stored until the future LAR for recycling systems is implemented.

The ventilation systems effluent sample filters will continue to be monitored for gross alpha, gross beta and isotopic uranium and may be changed out on a more frequent basis than the current monthly change out frequency. However, ventilation sample filters were evaluated on a weekly change out frequency in the previous facility expansion Environmental Assessment. It is not anticipated that the GEVS in-line filters will require changeout more frequently than the current annual basis. The previously evaluated projected filter recycling generation rate of 99,790 kg/yr (220,000 lb/yr) [NRC, 2015b] will remain bounding with the potential addition of sample filter materials. Impacts of the Proposed Action with respect to waste management are addressed in Section 5.2.

• Public and Occupational Health The Proposed Action has the potential to slightly increase radiation levels within the UUSA facility for occupational workers. This is due to the fact that unirradiated uranium radioactivity increases approximately linearly with an increase in enrichment, mainly due to the influence of the increase in percentage of 234U and 235U. The potential to increase radiation levels at and beyond the site boundary due storage of UF6 cylinders on the UBC Storage Pad is not anticipated as UUSA does not intend to store filled LEU+ product cylinders on the UBC Storage Pad. Continued use of the GEVS during LEU+ production is also evaluated for dose and uranium intake impact. The impact of the Proposed Action for Public and Occupational Health is discussed in Section 5.3.

LAR 23-02

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5.0 Assessment of Impacts

This section discusses the significance of the relationship between the environmental resource and the Proposed Action. In addition, this Section also considers potential cumulative environmental impacts from the perspective of past, present and reasonabl y foreseeable future actions for not just the Proposed Action of this LAR, but also from a qualitative perspective with respect to the future LAR that will request regulatory authorization for use of the recycling systems and components not included in thi s LAR.

The areas to be considered for review with respect to cumulative impacts include:

1. Impacts of the initial UUSA facility before the facility expansion

2. Impacts of the preconstruction activities to support UUSA facility expansion from MSWU to 10 MSWU

3. Impacts of other past, present and reasonably foreseeable future projects within and outside the UUSA facility site The three categories of past, present and reasonably foreseeable future actions are discussed below.

• Initial UUSA Facility before Facility Expansion The potential environmental impacts of construction, operation and decommissioning of the initial UUSA facility are described in the initial Environmental Impact Statement (EIS) for the facility [NRC, 2005]. The impacts are summarized in the EIS in Section 2.3, Table 2-9.

• Facility Expansion Preconstruction Activities

Preconstruction activities for facility expansion were not considered as part of the Proposed Action for facility expansion from 3 MSWU to 10 MSWU. However, in the Environmental Assessment conducted for the facility expansion, the preconstruction activities were considered to be past actions with the potential for cumulative impacts and those potential cumulative impacts were included for completeness [NRC, 2015c].

• Other Past, Present and Reasonably Foreseeable Future Actions UUSA Facility

The present actions considered include the current facility operations-identified impacts included in the facility expansion Environmental Assessment [NRC, 2015c]

and the future potential impacts after implementing the Proposed Action in LAR 23-02. The potential environmental impacts of implementing the Proposed Action of LAR 23-02 are found in Section 5.1 of this Enclosure. Reasonably foreseeable future actions for the UUSA facility also include the future LAR that will request authorization for use of the recycling systems and components after analyses and evaluations are completed for LEU+ enriched material to provide a more complete assessment.

LAR 23-02

LES-23-103-NRC

Additionally, UUSA has notified the NRC of its intent to further raise the enrichment limit of the Materials License SNM-2010 from the current licensed limit up to 20 w/o 235U in the future. UUSA is proceeding with the planning of necessary changes and modifications needed for the Materials License to allow for construction of a new facility (LES 2023).

Note: This license application and environmental report have not yet been written or submitted, so data is not yet available for the facility changes. It is noted here for completeness.

Projects and facilities outside UUSA facility

The previous Environmental Assessment for facility expansion also evaluated cumulative impacts for local projects and facilities when considering the potential impacts of the expansion where the future actions were those considered during the construction, operation and decommissioning of the expanded facility. The other past, present and reasonably foreseeable future projects and actions considered in the cumulative impact analysis are as identified [NRC, 2015d]. The status of those projects identified in Table 4-11 remain in the same status as identified in that Environmental Assessment. However, in the intervening time interval, additional relevant local projects have been identified:

1. Interim Storage Partners, LLC: Issuance of Materials License No. SNM-2515 for the WCS Consolidated Interim Storage Facility Independent Spent Fuel Storage Installation Docket No. 72-1050, dated 13 September 2021 [NRC 2021a]

2. Holtec, International: Issuance of Final Safety Evaluation Report for the HI-STORE Consolidated Interim Storage Facility Independent Spent Fuel Storage Installation Specific Materials License No. SNM-2516, Docket No.

72-1051, dated May 2023 [NRC 2023b]

3. Eden Radioisotopes, LLC (Eden): Eden has informed the NRC of its intent to submit a license application to construct and operate a medical radioisotope production facility east of Eunice, New Mexico. Eden has stated that it plans to submit license applications to construct and operate the isotope production facility in the second quarter 2024 [Eden, 2023]

Note: This license application and environmental report have not yet been submitted, so data is not yet available for the facility. It is noted here for completeness.

The issuance of the licenses to construct and operate these relatively close proximity Consolidated Interim Storage Facility projects (Interim Storage Partners, LLC: within 1.5 miles (2.4 km); and Holtec, International: within 40 miles (64 km)) and the future construction and operation of the medical isotope facility may influence the potential cumulative impacts of the UUSA Proposed Action for this LAR and the future LAR related to producing LEU+ and utilizing the recycling systems at a future date.

LAR 23-02

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Included in the Licensing action for the Interim Storage Partners, LLC and Holtec, International, projects was an Environmental Impact Statement (EIS) to construct and operate each facility.

1. Environmental Impact Statement for Interim Storage Partners LLCs License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Andrews County, Texas, Final Report, dated July 2021 [NRC, 2021b]

2. Environmental Impact Statement for the Holtec Internationals License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Lea County, New Mexico, as supplemented, dated October 2022 [NRC, 2022a]

The potential impacts from the construction and operation of the Eden facility would be, at this time, speculative due to the limited available plans and documentation.

Therefore, potential Eden facility impacts are not included in cumulative impact determinations.

The geographic scope for the cumulative impacts reviews was taken from the topical areas in the EISs.

Table 5-1 summarizes the impacts of the Proposed Action in LAR 23-02, impacts on the future LAR for use of recycling systems and the cumulative impacts which consider the other past, present and reasonably foreseeable activities identified in Section 5.

Table 5-1 Summary Table of Environmental Impacts of the Proposed Action in LAR 23-02, Future LAR for Use of Recycling Systems, and Cumulative Impacts Considering Reasonably Foreseeable Future Actions

LAR 23-02 Future LAR for Proposed Recycling Cumulative Impact Action System Usage

The proposed project is projected to have no incremental effect when added Land Use No impact No impact to the MODERATE impacts from other past, present, and reasonably foreseeable future actions, resulting in an overall MODERATE cumulative impact to land use.

The proposed project is projected to have a SMALL Transportation SMALL No impact incremental effect for traffic-related impacts and a SMALL

LAR 23-02

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Table 5-1 Summary Table of Environmental Impacts of the Proposed Action in LAR 23-02, Future LAR for Use of Recycling Systems, and Cumulative Impacts Considering Reasonably Foreseeable Future Actions

LAR 23-02 Future LAR for Proposed Recycling Cumulative Impact Action System Usage

cumulative transportation impact.

The proposed project is projected to have no incremental effect when added Geology and Soils No impact No impact to the MODERATE impacts from other past, present, and reasonably foreseeable future actions, resulting in an overall MODERATE cumulative impact to geology and soils.

The proposed project is projected to have no incremental effect when added Water Resources No impact No impact to the MODERATE impacts from other past, present, and reasonably foreseeable future actions, resulting in an overall MODERATE cumulative impact to groundwater resources.

The proposed project is projected to have no incremental effect when added Ecological No impact No impact to the SMALL to MODERATE Resources impact from other past, present, and reasonably foreseeable future actions, resulting in an overall SMALL to MODERATE cumulative impact to ecological resources.

The proposed project is projected to have a SMALL Air Quality SMALL SMALL incremental effect when added

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Table 5-1 Summary Table of Environmental Impacts of the Proposed Action in LAR 23-02, Future LAR for Use of Recycling Systems, and Cumulative Impacts Considering Reasonably Foreseeable Future Actions

LAR 23-02 Future LAR for Proposed Recycling Cumulative Impact Action System Usage

to the MODERATE impacts from other past, present, and reasonably foreseeable future actions, resulting in an overall MODERATE cumulative impact to air quality.

The proposed project is projected to have no incremental effect when added Noise No impact No impact to the MODERATE impacts from other past, present, and reasonably foreseeable future actions, resulting in an overall MODERATE cumulative impact to noise resources.

The proposed project is projected to have no incremental effect when added Historic and Cultural No impact No impact to the SMALL impact from Resources other past, present, and reasonably foreseeable future actions, resulting in an overall SMALL cumulative impact to historical and cultural resources.

The proposed project is projected to have no incremental effect when added Visual/Scenic No impact No impact to the MODERATE impacts Resources from other past, present, and reasonably foreseeable future actions, resulting in an overall MODERATE cumulative impact to visual and scenic resources.

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Table 5-1 Summary Table of Environmental Impacts of the Proposed Action in LAR 23-02, Future LAR for Use of Recycling Systems, and Cumulative Impacts Considering Reasonably Foreseeable Future Actions

LAR 23-02 Future LAR for Proposed Recycling Cumulative Impact Action System Usage

The proposed project is projected to have no incremental effect when added Socioeconomics No impact No impact to the SMALL to MODERATE impacts from other past, present, and reasonably foreseeable future actions, resulting in a SMALL to MODERATE cumulative impact in the socioeconomic region of influence.

The cumulative impacts would Environmental No impact No impact have no disproportionately Justice high and adverse impacts to low-income or minority populations.

The proposed project is projected to have a SMALL Waste Management SMALL SMALL incremental effect when added to the MODERATE impacts from other past, present, and reasonably foreseeable future actions, resulting in an overall SMALL cumulative impact to waste management.

The proposed project is projected to have a SMALL incremental effect when added Public and to the SMALL impacts from Occupational Health SMALL SMALL other past, present, and reasonably foreseeable future actions, resulting in an overall SMALL cumulative impact to public and occupational health.

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As identified in Section 4.1, a number of reviewed areas for potential impact are not affected by the Proposed Action in LAR 23 -02. Additionally, the future use of the installed recycling systems will also not result in any impact to these topical areas.

The recycling systems and process operations will be similar to those in service at present for the current license limit of enrichment.

The non-impacted topical areas are:

• Land Use

• Geology and Soils

• Water Resources

• Ecological Resources

• Noise

• Historic and Cultural Resources

• Visual/Scenic Resources

• Socioeconomics

• Environmental Justice

5.1 Transportation Impacts

Product Cylinders UUSA only ships product cylinders by road transportation methods. Conservatively assuming the same current average annual mass of UF6 produced at the UUSA facility would be required by customers from the UUSA facility and that mass would consist entirely of LEU+, there would an increase in the shipment of product cylinders containing LEU+. There is no impact on product transporta tion from the future LAR to allow use of installed recycling systems and components.

The increase in transportation is due to the lower mass for the DN30 and DN30-X (DN30-10 for 10 w/o 235U) transportation packages for LEU+ material, which are expected to be used for LEU+ transportation. The fill mass may be reduced from 2277 kg UF6 in the DN30 transportation package to 1460 kg UF6 and the maximum authorized fill for the DN30-X (DN30-10 for 10 w/o 235U) is also 1460 kg UF6. This translates to more cylinders needed for the same amount of UF6 to be transported. UUSA conservatively estimates an increase in shipments from a current average of approximately 69 shipments per year to 108 shipments per year, if all the UUSA UF6 product was LEU+.

The destinations of the product cylinder shipments are anticipated to remain consistent as previously evaluated. This anticipated number of product cylinder shipments remains bounded by the 235 product cylinder shipments evaluated in the facility expansion Environmental Assessment [NRC 2015e].

To assess cumulative impact beyond what has currently been evaluated, the Environmental Impact Statements (EISs) for the Holtec, International, and Interim Storage Partners LLC facilities were reviewed for cumulative transportation impacts.

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The conclusions in both EISs would be that the cumulative impact from the proposed shipments with other past, present and reasonably foreseeable actions would be SMALL.

The impact on transportation from raising the enrichment level at the U USA facility would be SMALL and the cumulative impact from raising the enrichment level at UUSA would also be SMALL. No mitigation is required.

5.2 Waste Management With regards to Waste Management, the scope of the Proposed Action is to obtain regulatory authorization for only the production, handling and storage of LEU+.

Production material and components that are removed from the production processes that have being exposed to LEU+ UF 6 will be segregated and stored in analyzed and evaluated locations within the UUSA facility and are not considered waste by UUSA.

These materials and components retain future value to be realized (e.g., future pump rebuilding, future component decontamination) after the recycling systems and components receive regulatory a uthorization for LEU+ handling in a future LAR.

Processing and decontamination of this material will occur after approval of the future LAR. Therefore, decontamination of materials and components exposed to LEU+ will not occur as a result of this Proposed Action and the current waste minimization practices will remain intact. However, the processes and materials used for decontamination after the future LAR is approved will be the same as currently utilized.

The future LAR will allow the recycling systems to be utilized, thus allowing for decontamination of interim stored LEU+ exposed material. However, the type and amount of waste product will be consistent with current production, albeit some will be at a higher enrichment. Raising the enrichment limi t requires additional criticality and safety controls, but is transparent to the decontamination and recycling processing activities.

Gaseous effluents are monitored using continuous air particulate samplers on various effluent vent stacks. The sample filters are changed monthly. For conservatism, it is anticipated that sample filters may need to be changed out on a more frequent basis based on monitoring results with LEU+. The sample filters were evaluated on a weekly change out frequency in the facility expansion Environmental Assessment [NRC, 2015f]

which has now been revised to the monthly periodicity. Even at the previous weekly change out rate, the volume of filters would remain bounded by the facility expansion amount of sample filters. The administrative action levels are set for effluent samples and monitoring instrumentation to allow for corrective actions to be taken before regulatory limits are exceeded. Replaced activated carbon, activated alumina and ventilation filters used at the facility are considered Class A Low Level Radioactive Waste (LLRW) and are disposed of at one of the licensed LLRW disposal facilities.

These facilities can readily accommodate the volumes of UUSA wastes produced [NRC 2015g].

The Proposed Action and future LAR for recycling system use do not involve the generation of any new liquid, hazardous waste or decontamination system fluid volumes

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not previously evaluated. Due to the current less frequent filter change out periodicity, including a conservative assumption of a slight increase in sample filter change out, and the capacity of license waste facilities to accommodate the incremental filter waste the impact from raising the enrichment level and utilization of recycling systems in a future LAR on Waste Management is SMALL. No mitigation is required.

The Proposed Action in LAR 23 -02 and the future LAR approval to use the recycling systems and components will not produce Low Level Radioactive Wastes, hazardous, nonhazardous and sanitary wastes beyond what has been previously evaluated and the disposal facilities capacity remains adequate to manage the waste streams. To better understand the cu mulative waste potential impact, the EISs from the foreseeable future activities for the Holtec, International, and Interim Storage Partners LLC facilities were reviewed. The evaluations from these two EISs conclude that cumulative impacts would be SMALL to MODERATE between these facilities, mainly due to the projected closure of one currently available landfill, absent the creation of another such facility [NRC 2022a], [NRC, 2021b]. However, in the UUSA facility expansion Environmental Assessment, the c onclusion that the cumulative impact on waste streams was that the impact would be considered MODERATE, mainly due to the increase in depleted UF 6 from potential additional domestic enrichment facility operations [NRC, 2015h].

Therefore, the cumulative waste management impacts would remain MODERATE and no additional mitigation is required.

5.3 Public and Occupational Health Impacts 5.3.1 Non-radiological Impacts

Hazards to the Public Facility emissions during normal operations that would cross the site boundary and result in possible exposures to members of the public would be limited to small quantities of UF6 and HF that are not captured by GEVS and are emitted from the rooftop ventilation stack. No other routine chemical emissions would be at levels of potential concern to the public. At the previously evaluated increased plant capacity of 10 MSWU at 5 w/o 235U enrichment, site annual emissions were forecast at 12 g (0.027 lb) uranium and 1.2 kg (2.7 lb) HF. Using the Environmental Protection Agenc ys AERMOD model, these emission rates resulted in an estimated maximum 8 -hour average ambient air concentration of HF of 9.3 x 10-3 g/m3 and of uranium of 9.9 x 10-5 g/m3 [NRC 2015i].

Radiological Assessment System for Consequence Analysis (RASCAL) sce narios were performed across multiple enrichments (5, 10, 20 w/o 235U) and demonstrated that forecast emissions with the Proposed Action for hydrogen fluoride (HF) remain unchanged across the various enrichments (although the proposed enrichment level is limited to less than 10 w/o 235U). That is, the HF concentrations continues to remain several orders of magnitudes below the Emergency Response Planning Guidelines, ERPGS-2, limit of 20 ppm (i.e., the maximum airborne concentration below which nearly all individuals could be exposed to for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> without experiencing or developing

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irreversible or other serious health effects or symptoms which could impair an individuals ability to take protective action) to the workers and members of the public.

Likewise, the mass of uranium deposited or inhaled is not impacted by th e change in enrichment as demonstrated by the same RASCAL scenarios evaluated, based on the International Commission of Radiological Protection (ICRP) 26/30 inhalation dose factors and ranges of enrichment. The soluble uranium intake remains well below th e 10CFR 20.1201(e) limit of 10 mg in a week for workers or members of the public.

The estimated concentration of uranium remains approximately five orders of magnitude below the National Institute for Occupational Safety and Health (NIOSH) and Occupational Safety and Health Administration (OSHA) occupational exposure limit for soluble uranium forms of 50 g/m3 [NRC 2015i].

Although no ambient air quality standards are available, comparison to the occupational standards indicates that the uranium exposures to the public from normal operations remain below levels of public health concern, including the future use of the installed recycling systems to be authorized in a future LAR. The impact of raising the enrichment level or the use of the recycling systems to be approved in a future LAR on Hazards to the Public is SMALL and no mitigation is required.

Occupational Hazards The installed GEVS will continue to function as designed to prevent worker exposure and to collect and trap Hydrogen Fluoride (HF) and uranium compounds in process-line effluent and workspace air. The GEVS will continue to operate as designed after the future LAR is approved and implemented for the ventilated areas where LEU+ handling, decontamination and storage would then be approved. Occupational injuries and chemical exposures at the facility would not change from the current profile due to the Proposed Action or the future use of the installed recycling systems to be authorized in a future LAR and the impact from the higher enrichment level remains SMALL and mitigation is not required.

5.3.2 Radiological Impacts Public Radiological Health Impacts

Gaseous Effluent Impacts The radiological impacts of gaseous releases were previously evaluated for the UUSA facility expansion from 3 to 10 MSWU and found to be only a small fraction of the NRC public dose limit of 1 mSv/yr (100 mrem/yr) as stated in 10 CFR 20.1301(a)(1) at the increased facility capacity. The gaseous release dose impact was based on the conservative assumption that the annual release of uranium would be 800 Ci/yr (29.7 MBq/yr). However, the estimated gaseous dose at the site boundary is a small fraction of the dose from direct exposure [NRC 2015j].

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In accordance with 10 CFR 70.59, Effluent Monitoring Requirements, UUSA submits a semi-annual effluent monitoring report to the NRC regarding radioactivity in effluents during the previous six months. A review of the UUSA facility Semi-Annual Radiological Effluent Release Reports since the facility capacity expansion was approved by the NRC in March 2015 through June 2023 was conducted. In all cases, in gaseous effluents, the gross uranium activities were below the Minimum Detectable Activity (MDA) or were less than 10% of values listed in 10 CFR 20, Appendix B, Table 2, Effluent Concentrations -

Col. 1, Class D for 234U, 235U, and 238U.

The concentrations of isotopic uranium in gaseous effluents were either below the Minimum Detectable Concentration (MDC) or were less than 10% of values listed in 10 CFR 20.1301, 10 CFR 20.1302, and 10 CFR 20.1101(d), as described in NRC Regulatory Guide 4.20, Constraint on Releases of Airborne Radioactive Materials to the Environment for Licensees other than Power Reactors, dated December 1996.

Upon implementation of the Proposed Action and the future use of the recycling systems to be authorized in a future LAR, the estimated annual release of uranium at the UUSA facility is 260 Ci/yr (9.62 MBq/yr). This annual uranium release estimation remains below the conservative estimation utilized in the facility expansion Environmental Assessment. Therefore, there is no impact to public dose due to gaseous effluents and the impact from the higher enrichment level and future LAR remains SMALL and mitigation is not required.

Direct Radiation Impacts The dominant source of offsite radiation would be from direct and scatter radiation from the UBC Storage Pads [NRC 2015j]. The dominant fixed source would not change with the implementation of the Proposed Action or the future LAR approval and implementation to utilize the installed recycling systems and components.

The cylinders on the UBC Storage Pad were previously evaluated for the plant capacity expansion for a triple-stack arrangement for the 48Y feed cylinders and a single-stack arrangement for the enriched uranium 30B product cylinders. The proposed storage arrangement for implementing the Proposed Action or the future LAR for recycling system utilization does not change while retaining the existing 25,000 cylinder limit on the UBC Storage Pad. The estimated annual dose at the nearest site boundary from direct exposure was 9.4 mrem/yr (0.094 mSv/yr), which is well below the 100 mrem/yr (1 mSv/yr) Total Effective Dose Equivalent (TEDE) limit established by 10 CFR 20.1301, Dose limits for individual members of the public, and below the 25 mrem/yr (0.25 mSv/yr) dose equivalent to the whole body and any organ limit established by 40 CFR 190, Environmental Radiation Protection Standards For Nuclear Power Operations [NRC 2015j].

UUSA does not intend to store LEU+ filled 30B or 30B-10 product cylinders on the Outdoor Cylinder Storage Areas (UBC Storage Pad) and is institutionalizing that approach with a proposed revision to the Criticality Accident Alarm System exemption in Materials License SNM-2010 License Condition 33 in the Proposed Action. Since the

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number of cylinders on the UBC Storage Pad or Outdoor Cylinder Storage Areas does not change and cylinder contents remain as previously evaluated, there are no impacts on Public Health from direct radiation and no mitigation is required.

Occupational Exposure Impacts The radiation protection program and industrial safety program at UUSA continues to monitor the occupational workers at the facility for internal exposure from intake of uranium as well as doses from external exposure. The exposure control program maintains exposures as low as reasonably achievable (ALARA) through the use of radiation monitoring systems, personnel dosimetry and mitigation systems to reduce environmental concentrations of uranium. Under the Proposed Action and use of the installed recycling systems to be authorized in a future LAR, the most significant contributor to occupational radiation exposure remains the direct radiation from the stored cylinders on the UBC Storage Pad.

Dose records were reviewed for occupational workers since the facility expansion was authorized in 2015 through 2022. A summary of the TEDE results is presented below.

UUSA Occupational TEDE 2015 - 2022

Number of Collective TEDE Average TEDE Highest Individual Year workers (mrem / mSv) (mrem / mSv) TEDE Received monitored (mrem / mSv)

2015 75 4774 / 47.74 63.7 / 0.637 336 / 3.36 2016 79 4802 / 48.02 60.8 / 0.608 292 / 2.92 2017 65 3862 / 38.62 56.6 / 0.566 258 / 2.58 2018 65 4648 / 46.48 71.5 / 0.715 337 / 3.37 2019 105 5841 / 58.41 44.3 / 0.443 345 / 3.45 2020 59 4943 / 49.43 83.8 / 0.838 310 / 3.10 2021 52 5082 / 50.82 97.7 / 0.977 375 / 3.75 2022 61 4245 / 42.45 69.6 / 0.696 399 / 3.99 Average TEDE to workers: 67.9 mrem (0.679 mSv)

Occupational doses over this period have remained a fraction of the annual regulatory limits in 10 CFR 20.1201, Occupational dose limits for adults, of 5 rems (5,000 mSv).

Occupational dose is expected to increase proportionally to changes in enrichment due to the increased amounts of 234U and 235U at the higher enrichment. Conservatively assuming all future UUSA facility production is LEU+, changing the enrichment from 5 w/o 235U to less than 10 w/o 235U is anticipated to increase dose by a factor of two, including the future use of the recycling systems to be addressed in the future LAR.

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Considering this percentage increase in dose at the higher enrichment and the TEDE for workers for all aspects of facility operations, including using current decontamination processes and recycling systems, has historically remained a small fraction of regulatory limits, occupational TEDE will continue to remain a small fraction of the regulatory dose limit specified in 10 CFR 20.1201.

The impact of raising the enrichment level on Occupational Exposure is SMALL and no mitigation is required.

The Proposed Action in LAR 23 -02 and the future LAR approval to use the recycling systems and components impact to public and occupational health are SMALL. To better understand the cumulative public and occupational health impact, the EISs from the foreseeable future activities for the Holtec, International, and Interim Storage Partners LLC facilities were reviewed. The evaluations from these two EISs conclude that public and occupational health cumulative impacts would be SMALL between these facilities, even when considering the full build-out of each facility as the public dose from all potential sources evaluated would be below the NRC 10 CFR 20 annual public dose limit of 100 mrem (1mSv) [NRC 2022c], [NRC, 2021d]. As there is no change to the direct public exposure from the UBC Storage Pad, the previous Environmental Assessment for facility expansion remains bounding, and the incremental change in occupational exposure is projected to remain a small fraction of NRC limits, the cumulative impact to public and occupational health is SMALL and no mitigation is required.

5.3.3 Accidents

The UUSA Integrated Safety Analysis Summary (ISAS) details credible events and accident sequences with consequences which could exceed the performance criteria of 10 CFR 70.61, Performance Requirements, for the facility. The ISAS analysis and evaluations for the Proposed Action have been performed in accordance with the approved ISA process and the UUSA Quality Assurance Program. There are no new types of accidents identified as a result of the Proposed Action that were previously evaluated and approved in the NRC Safety Evaluation Report for expansion of the UUSA facility [NRC 2015k] and referenced in the supporting Environmental Assessment for facility expansion [NRC 2015a]. Additionally, with the implementation of the future LAR for use of recycling systems at a higher enrichment, there are no anticipated new accident types that may occur.

While there are no new types of accidents identified, there are new and revised accident sequences within some accident categories. The new or revised accident seq uences are based on changing some Safe-By-Design configurations to Items Relied on For Safety (IROFS). Passive Engineered IROFS controls have been introduced to replace Safe-By-Design controls, which include geometry controls and volume controls.

Additional administrative IROFS have also been introduced. As a result, there are no accident severity level change or consequence category changes for accidents. All controls needed to ensure that the performance requirements of 10 CFR 70.61 remain satisfied were identified and satisfactorily evaluated. There is no impact on accidents

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from the Proposed Action and future LAR for recycling system implementation and no additional mitigation is needed.

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6.0 Environmental Impacts of the Alternatives to the Proposed Ac tion

The alternative to the Proposed Action is the no action alternative. The no action alternative is to not increase the enrichment limit at the UUSA facility, maintain the licensed enrichment limit at the current value and not make administrative changes to the Materials License. There are no incremental impacts to the environment if this alternative is chosen, as the status quo will be maintained and impacts have been previously evaluated with the last environmental assessment being performed for facility capacity expansion [NRC 2 015a] and changes to the UUSA Materials License for enrichment increases, which resulted in the application of the Categorical Exclusion under 10 CFR 51.22(c)(11) [NRC 2013] [NRC 2020]. However, the nuclear industry will likely continue to pursue higher enriched UF6 for power reactors due to the benefits provided by LEU+ fuels and the increased enrichment will most likely be produced at another facility with similar environmental impacts.

7.0 Agencies and Persons Consulted No agencies or persons were contacted for this environmental review.

8.0 Conclusion

The results of this environmental information discussion are that there may be incremental impacts to the environment as a result of the Proposed Action and implementation of a future LAR for recycling system use in certain assessed topical areas. However, these impacts are demonstrated or anticipated to be SMALL and remain bounded, based on review and evaluation of the previous Environmental Assessment conducted for the UUSA facility expansion [NRC 2015] and changes to the UUSA Materials License for increased enrichment in the NRC conclusion of the Categorical Exclusion under 10 CFR 51.22(c)(11) [NRC 2020]. The future LAR to authorize the use of recycling systems and components was considered from a qualitative perspective and does not change the potentially impacted areas of review, nor change the result of any impact.

Potential accidents were evaluated in the NRC Safety Evaluation Report for the facility expansion [NRC 2015k] and the Proposed Action and future LAR for recycling systems do not introduce any new accidents or change evaluated accident severity levels or categories.

Evaluation of the cumulative impacts of past, present and foreseeable known future activities with respect to topical areas with potential impact indicate that the cumulative impacts for each are SMALL or does not change the previously evaluated environmental impact significance level.

The Proposed Action for LAR 23-02 meets the requirements for a Categorical Exclusion under 10 CFR 51.22(c)(11). As demonstrated in this document, the changes in this request for an amendment to Materials License SNM-2010 are either administrative, organizational or procedural in nature or involve changes in process operations and equipment which do not

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result in any significant adverse incremental impacts to the environment from the licensed activity. Implementation of these minor and routine types of changes do not significantly alter the previously evaluated environmental impacts associated with the licensed operation, considering any construction impacts, types and amounts of effluents released by the operation, occupational exposure of employees, or potential accidents. Furthermore, this amendment does not affect the scope or nature of the licensed activity.

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9.0 References

Eden 2023, Eden Isotope Production Complex (EIPC) Notice of Intent to Submit License Application, dated 7 August 2023 (ML23230B208)

LES 2012a, Supplemental Environmental Report in Support of License Amendment Request Associated with Capacity Expansion of URENCO USA Facility, dated 10 September 2012 (ML12262A537, ML12262A539)

LES 2013, LES-13-00073-NRC, Submittal of License Amendment Request for Changes to License Condition 6B and Enrichment Limit (LAR-13-02), dated 16 July 2013 (ML13199A444)

LES 2019, LES-19-142-NRC, License Amendment Request to Change License Condition 6B and Enrichment Limit (LAR-19-01), dated 12 November 2019 (ML19322A114)

LES 2023, LES-23-100-NRC, Notice of Intent for UUSA to submit License Amendment Requests to Increase Enrichment Limit for construction of a High Assay Low Enriched Uranium Facility (HALEUF), dated 27 July 2023 (ML23208A261)

NRC 2003, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs, Final Report, NUREG-1748, July 2003 (ML032450279)

NRC 2013, License Amendment 59, License Amendment Request 13-02 to Revise License Condition 6B of SNM-2010 to Increase the Facility Enrichment Limit (Technical Assignment Control No. L34184), dated 30 October 2013 (ML13290A208)

NRC 2015a, Environmental Assessment for the Proposed URENCO USA Uranium Enrichment Facility Capacity Expansion in Lea County, New Mexico, dated 18 March 2015 (ML15072A279)

NRC 2015b, Environmental Assessment for the Proposed URENCO USA Uranium Enrichment Facility Capacity Expansion in Lea County, New Mexico, 18 March 2015, Section 4.1.2.13 (ML15072A279)

NRC 2015c, Environmental Assessment for the Proposed URENCO USA Uranium Enrichment Facility Capacity Expansion in Lea County, New Mexico, 18 March 2015, Section 4.1.5.1.1 (ML15072A279)

NRC 2015d, Environmental Assessment for the Proposed URENCO USA Uranium Enrichment Facility Capacity Expansion in Lea County, New Mexico, 18 March 2015, Table 4-11 (ML15072A279)

NRC 2015e, Environmental Assessment for the Proposed URENCO USA Uranium Enrichment Facility Capacity Expansion in Lea County, New Mexico, 18 March 2015, Table 4-1 (ML15072A279)

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NRC 2015f, Environmental Assessment for the Proposed URENCO USA Uranium Enrichment Facility Capacity Expansion in Lea County, New Mexico, 18 March 2015, Section 3.12.2.3.1 (ML15072A279)

NRC 2015g, Environmental Assessment for the Proposed URENCO USA Uranium Enrichment Facility Capacity Expansion in Lea County, New Mexico, 18 March 2015, Section 2.1.2.3.2 (ML15072A279)

NRC 2015h, Environmental Assessment for the Proposed URENCO USA Uranium Enrichment Facility Capacity Expansion in Lea County, New Mexico, 18 March 2015, Section 4.1.5.1.2.13 (ML15072A279)

NRC 2015i, Environmental A ssessment for the Proposed URENCO USA Uranium Enrichment Facility Capacity Expansion in Lea County, New Mexico, 18 March 2015, Section 4.1.2.12.1 (ML15072A279)

NRC 2015j, Environmental Assessment for the Proposed URENCO USA Uranium Enrichment Facility Capacity Expansion in Lea County, New Mexico, 18 March 2015, Section 4.1.2.12.2 (ML15072A279)

NRC 2015k, Issuance of Amendment 63 for License Amendment Request 12 -10, Expansion of enrichment Capacity from 3.7 to 10 Million Separative Work Units, SNM-2010, Amendment Number 63, Louisiana Energy Services, LLC (TAC No. L34228), dated 23 March 2015 (ML15049A402)

NRC 2020, U.S. Louisiana Energy Services - Amendment 85, Change to License Condition 6B and Enrichment Limit, dated 19 May 2020 (ML20119A043)

NRC 2021a, Issuance of Materials License No. SNM-2515 for the WCS Consolidated Interim Storage Facility Independent Spent Fuel Storage Installation Docket No. 72-1050, dated 13 September 2021 (ML21188A097)

NRC 2021b, Environmental Impact Statement for Interim Storage Partners LLCs License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Andrews County, Texas, Final Report, dated July 2021 (ML21209A955)

NRC 2022a, Environmental Impact Statement for the Holtec Internationals License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Lea County, New Mexico, as supplemented, dated October 2022 Section 5.14 (ML22299A238)

NRC 2022b, Environmental Impact Statement for the Holtec Internationals License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Lea County, New Mexico, as supplemented, dated October 2022 Section 5.14 (ML22299A238)

NRC 2022c, Environmental Impact Statement for the Holtec Internationals License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Lea County, New Mexico, as supplemented, dated October 2022 Section 5.13 (ML22299A238)

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NRC 2022d, Environmental Impact Statement for the Holtec Internatio nals License Application for a Consolidated Interim Storage Facility for Spent Nuclear Fuel in Lea County, New Mexico, as supplemented, dated October 2022 Section 5.13 (ML22299A238)

NRC 2023a, Safety Evaluation Report Docket No 71 -9388 Model No. DN30 -X Package Certificate of Compliance No. 9388 Revision No. 0, dated 27 March 2023 (ML23083B980)

NRC 2023b, Issuance of Final Safety Evaluation Report for the HI-STORE Consolidated Interim Storage Facility Independent Spent Fuel Storage Installation Specific Materials License No. SNM-2516, Docket No. 72-1051, dated May 2023 (ML23075A183)

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