ML20125A116

American Centrifuge Plant, Proposed Changes for LA-3605-0001, License Application. Part 2 of 2

ML20125A116
Person / Time
Site:	07007004
Issue date:	04/22/2020
From:	American Centrifuge Operating
To:	Office of Nuclear Material Safety and Safeguards
References
ACO 20-0010, LA-3605-0001
Download: ML20125A116 (236)

Text

{{#Wiki_filter:license Application for the American Centrifuge Plant Proposed Change 2020 4.0 RADIATION PROTECTION This chapter describes the American Centrifuge Plant (ACP) Radiation Protection (RP) Program for keeping occupational radiation exposures and radioactive contamination below regulatory limits and as low as reasonably achievable (ALARA). The RP Program addresses the occupational radiation protection requirements set forth in 10 Code ofFederal Regulations (CFR) Parts 19, 20, and 70. The Radiation Protection Manager (RPM) is responsible for the ACP RP Program . The RPM or designee carries out responsibilities of the RPM described in this chapter. 4.1 Radiation Protection Program Implementation In accordance with 10 CFR 20.1 IOI(c), the RP Program content and implementation is reviewed annually . The RPM is responsible for this annual review and preparation of a report documenting the results of the review. The ALARA Committee then reviews the report. Revisions to the RP Program, if warranted, are initiated and processed by the RPM as part of the annual review process. Any resulting changes to the Radiation Worker Training module are also implemented. 4.2 As Low As Reasonably Achievable Program In accordance with 10 CFR 20.1101 , the ACP RP Program is designed to protect personnel entering the ACP from unnecessary exposure to ionizing radiation and radioactive materials. This program is based upon the following principles and is implemented through written procedures.

• Personnel radiation exposures and the release of radioactive effluents shall be maintained in accordance with the ALARA principle.
• No individual shall receive a radiation dose in excess of any regulatory limit.

Responsibility for establishing and ensuring adherence to these principles rests with the Senior Vice President, Field Operations. The General Manager has the overall responsibility and authority for the ALARA Program . The RPM is responsible for establishing and implementing the ALARA Program in accordance with written policies and procedures. 4.2.1 As Low As Reasonably Achievable Committee The ALARA Committee is an independent advisory group to the General Manager and the Plant Safety Review Committee on RP issues. It functions to : (1) monitor selected operational RP issues; (2) advise ACP management on RP concerns; and (3) review proposed designs, work practices, selected suggestions, and selected projects with regard to contamination control and/or ALARA. 4-1

License Application/or the American Centrifuge Plant Proposed Change 2020 The ALARA Committee:

• Communicates management's commitment to the ALARA Program;
• Monitors the implementation of the ALARA Program and serves as the advisor to ACP management for maintaining occupational dose and environmental dose in accordance with ALARA principles; and
• Reviews, for the purpose of occupational dose and environmental dose reduction, proposed designs, practices, selected suggestions, and selected project schedules.

The ALARA Committee also:

• Establishes the annual exposure goals;
• Provides recommendations to ACP management and/or the Plant Safety Review Committee as appropriate, regarding procedural, equipment, or design changes that could have a significant impact on personnel radiation exposure; and
• Forms subcommittees or assigns individuals to undertake special studies or conduct ALARA reviews that will be documented and presented to the ALARA Committee with any recommendations.

Membership consists of persons from various functional disciplines who have the necessary competence and experience to perform the functions of the committee. Standing committee members are the RPM who serves as the chairperson, the vice-chairperson who is appointed by the RPM, the Production Support Manager, Operations Manager, Regulatory Manager, and an operations technician and/or a maintenance technician. Participation from other functional disciplines may vary depending on the issue of concern. The committee chairperson, or designee, is responsible for requesting appropriate functional representation. Committee members may designate an alternate to attend committee meetings in their place. The ALARA Committee meets at least annually and as directed by the chairperson. A quorum consists of five standing com mittee members or their alternates. Ad hoc subcommittees may be established for special studies or reviews pertinent to committee-related issues. The chairperson ensures those functions of the committee and tasks are properly executed. Minutes are provided to the General Manager. The committee issues special reports prepared upon request of ACP management, or as determined by the chairperson.

       '.:f-1:te--enHni t t-ee-Fevi ev. s matters that-ltav-e--0r-may-ha-v-e----rrA--+ffif*iekm----e11lam i nation cen-trel and/or A LARA The ALARA Committee reviews the ALARA Program and the review includes an evaluation of the results of audits performed by Health Physics (HP), reports of radiation levels, contamination levels, employee exposures, and effluent releases. The review determines if there are any upward trends in personnel exposure for identified categories of workers and types of operations. The review also identifies any upward trends in effiuent releases and contamination 4-2

License Application for the American Centrifuge Plant Proposed Change 2020 levels and determines if exposures, releases, and contamination levels are in accordance with the ALARA concept. Specific areas reviewed include, but are not limited to the following:

• Technologies for selected job tasks;
• Current work practices and completed tasks which have/had contamination control or ALARA concerns;
• Radiation protection violations;
• Lessons learned;
• Trends and resulting impacts on contamination control and/or ALARA; and
• Environmental monitoring reports.

The committee also establishes annual contamination control and exposure goals. Minutes are issued that identify committee members and/or alternates in attendance, agenda items, a summary of decisions made, and action items. Copies are made available to ACP management and the committee members. Recommendations of the ALARA Committee are documented and tracked to completion in the Corrective Action Program. 4.3 Organization and Personnel Qualifications The RPM is responsible for providing gui dance and direction for establishment and implementation of the RP Program and has direct access to the General Manager and Senior Vice President, Field Operations for radiological control matters. The RPM reports to the Production Support Manager, which provides independence from operations. The RPM and designee are required to have the technical competence and experience to establish RP programs (RPM qualifications are stated in Chapter 2.0 of this license application) and the management capability to direct the implementation and maintenance of RP programs. The HP Group reports to the RPM and provides radiological protection support to the plant. HP is independent of the organizations responsible for production. The HP Group is staffed with suitably trained individuals who provide oversight and control of the technical aspects of the program elements that affect RP. There are sufficient HP resources available to support ACP activities. HP Technicians &Ae--tlteir manageFS-perform the functions of assisting and guiding workers in the radiological aspects of the job. HP Technicians and their mattfl!:,~have the responsibility and authority to stop radiological work or mitigate the effect of an activity if they suspect that the initiation or continued performance of a job, evolution, or test will result in the violation of approved RP requirements. 4-3

License Application for the American Centrifuge Plant Proposed Change 2020 4.4 Written Procedures 4.4.1 Procedures The RP Program is implemented using procedures. The procedures are prepared consistent with the requirements of 10 CFR Part 20 and are approved, maintained, and adhered to for operations involving personnel radiation exposure and toxicological exposure to soluble uranium . The procedures are reviewed and revised as necessary to incorporate any plant or operational changes, including these-those initiated by changes to the Integrated Safety Analysis (ISA) for commercial ACP operations and for the HALEU Demonstration. These procedures are prepared, maintained and made available to appropriate personnel at the plant as described in Section 11.4 of this license application. 4.4.2 Radiation Work Permits Radiation Work Permits (RWPs) are a basic implementing tool by which radiological controls are established. RWPs provide information to the worker concerning protective clothing, job/task identification, and special instructions such as radiological hold points. Radiological surveys that supplement RWPs provide information regarding radiation and contamination levels. RWPs are required for work activities in Contamination Areas (CAs), High Contamination Areas (HCAs), Airborne Radioactivity Areas (ARAs), Radiation Areas (RAs), High Radiation Areas (HRAs) and other areas as required by HP. Qualified HP personnel are authorized to approve, issue, update, revise, and close RWPs. The RPM may exempt the requirement for an RWP in certain RAs as specified in approved procedures. The limits established for contamination control (surface and airborne) are based on the toxicity of soluble uranium . The contamination control program, of which RWPs are a part, is designed to ensure that the inhalation or ingestion of soluble uranium is below the limits stated in 10 CFR 20.1201(e). An RWP may be issued for any period up to one year, based on the stability and predictability of changes in the radiological conditions of the work area. RWPs are normally closed upon job completion. HP may close an RWP at any time. Radiological surveys are reviewed to evaluate the adequacy ofRWP requirements. RWPs are updated or closed and reissued if radiological conditions change to the extent those the protective requirements need to be modified. HP management reviews the RWP closure package to ensure appropriate actions have been taken . Continuous HP coverage may be used in lieu of RWPs when approved by the RPM. Qualified HP Technicians are authorized to provi de continuous radiological coverage in lieu of an RWP for short duration (less than one shift), non-complex tasks. When continuous HP coverage is used, requirements normally specified on an RWP are communicated to the worker verbally. 4-4

license Application fo r the American Centrifuge Plant Proposed Change 2020 4.5 Training Radiological control is provided by controlling access to areas where radioactive material may be encountered and by requiring that each person who enters those areas or facilities receive the appropriate level of radiological worker training. Personnel are trained commensurate with the hazard per 10 CFR Parts 19 and 20. Details concerning Visitor Site Access Orientation and radiological training are provided in Section 11.3.1 of this license application. The Radiological Worker Training Program addresses the requirements of 10 CFR 19.11 and 19.12 and workers' responsibilities under the Radiation Protection Program. The Radiation Worker Training program is described in Section 11.3 .1.3 of this license application. 4.5.1 Visitor Site Access Orientation Visitors review basic information related to the site and hazards present at the ACP. Trained radiological workers escort visitors who are granted access to the Restricted Areas. 4.5.2 General Employee Radiological Training General Employee Radiological Training covers the employee' s responsibilities for maintaining exposures to radiation and radioactive materials in accordance with the ALARA philosophy. 4.5.3 Radiation Worker Training If a person requires unescorted access to the Restricted Area, radiological worker qualification is required. Radiation Worker Training is a biennial training requirement. Qualified Radiation Workers may be task gualified to perform selected HP Technician duties as authorized by the RPM. 4.5.4 Health Physics Technician HP Technicians are trained and qualified in accordance with an approved qualification standard and training is delivered consistent with applicable training procedures (see Section 11 .3). The qualification standard is based on the requirements of American National Standards Institute (ANSI)/American Nuclear Society 3.1, Selection, Qualification, and Training of Personnel for Nuclear Power Plants, 1987 Edition. HP Technician training develops the skills necessary to perform assigned work in a competent manner. The training consists of initial, on-the-job, and continuing training. HP Technician qualification consists of the standardized core course training material, ACP-specific information, and on-the-job training. Passing a final comprehensive written examination is required . The training program ensures personnel are proficient in radiation measurements, characterization of radiological conditions, release monitoring, and personnel monitoring. Formal remediation protocols are utilized. 4-

license Application f or the A merican Centrifuge Plant Proposed Change 2020 Entry-level prerequisites are established to ensure that HP Technicians meet minimum standards for education. Task qualification for entry-level positions may be used until formal training is completed. Following initial qualification, HP Technicians are requalified every two years. The requalification process requires successful completion of a comprehensive written examination. The written examination may be waived for personnel with National Registry of Radiation Protection Technologist certification. Personnel who maintain qualifications as HP Technicians satisfy the requirements of Radiation Worker Training. HP Technician managers complete and maintain qualifications as HP Technicians. 4.6 Ventilation and Respiratory Protection Programs ACP building ventilation systems are described in Chapter 1.0 of this license application and in the ISA Summary. These systems are primarily designed to maintain the building environment required for proper operation of process and associated equipment. There are no items relied on for safety (IROFS) identified with ventilation systems in the commercial ACP ISA Summary or its Addendum for the HALEU Demonstration. However, building ventilation systems are credited as defense in depth design features that help reduce the consequences of a UF6 release in multiple analyzed events. The ISA accident scenarios also identify use of portable ventilation units (commonly referred to as "gulpers") during applications ranging from pigtail operations to small-scale maintenance tasks to reduce worker exposure. In addition, administrative guidance requires the shutdown of building ventilation systems following detection of a UF6 release to minimize the consequences to personnel (on and off site) during loss of confinement events. 4.6.1 Ventilation In addition to general ventilation systems, and gulpers, portable ventilation units may be employed in the commercial ACP operation for short duration jobs when the unprotected worker could potentially exceed 0.8 Derived Air Concentration (DAC)-hours of exposure. These portable ventilation units are equipped with high efficiency particulate air (HEPA) filters and are de igned to discharge room air at low velocities. The differential pressure of portable HEPA filtered ventilation units is checked per operating procedure for radiological purposes. The operating differential pressure range is based on manufacturer's recommendations or as specified in the technical design basis. HEPA filter systems, both fixed and portable, are efficiency tested in accordance with American Society of Mechanical Engineers (ASME) NSI0-1989, Testing of Nuclear Air- Treatment Systems, as it applies to radiological contaminants likely to be found at the ACP. Portable HEPA filter unit use is normally specified on the RWP. 4-6

License Application for the A merican Centrifuge Plant Proposed Change 2020 HEPA filter ystems used to implement ALARA principles and to control worker exposures are tested in accordance with ASME NSl0-1989. For those systems not designed in accordance with ASME N509-1989, Nuclear Power Plant Air-Cleaning Units and Components, ASME NSI0-1989 is used as testing guidance. The average air velocity through openings in uranium sampling and handling hoods containing readily dispersible uranium is a minimum of 100 linear feet per minute (lfpm). This velocity is checked at least annually . If radiological containments are used, when they are in use and have the potential to generate airborne radioactivity, they will be maintained at a negative differential pressure. 4.6.2 Respiratory Protection The Respiratory Protection Program follows the requirements of 29 CFR 1910.134 and 10 CFR Part 20 for use, issuance, training, and qualifications for respirator users. Procedures for respirator usage follow the requirements of 10 CFR 20. l 703(c)(4). Records of respirator user training and fit testing are maintained as required by Section 11 .7 of this license application . RWPs specify respiratory protection required for radiological protection purposes. Respirator use is considered for activities where an individual may be exposed to soluble uranium that may exceed 0.8 DAC-hours or an intake of 1 milligram (mg) of soluble uranium during a work shift. Engineering and administrative controls, including access restrictions and the use of specific work practices designed to minimize airborne contamination or loss of contamination control are used to minimize worker internal exposure. When engineering and administrative controls have been applied and the potential for airborne radioactivity still exists, respiratory protection is used to limit internal exposures. Use of respiratory protection is considered under any of the following conditions:

• During entry into posted ARAs;
• During breach of contaminated systems or components;
• During work in areas or on equipment with removable contamination levels greater than 100 times the levels in Table 4.6-1 ; and
• During work on contaminated surfaces with the potential to generate airborne radioactivity.

In specific situations approved by the RPM, respiratory protection may not be used due to physical limitations, such as heat stress, or the potential for significantly increased external exposure. In such situations, stay time control to limit intakes are established and continuous workplace airborne monitoring is provided along with expedited analysis of results. 4-7

License Application for the American Centrifuge Plant Proposed Change 2020 Table 4.6-1 Contamination Levels Total (Fixed+ Removable Nuclide0 Removable) (dpm/100 cm 2 t (dpm/100 cm 2) U-natural , 235 U, 238 U, and associated decay products, Transuranics S 2 percent by alpha activity, 99 Tc, and 1,000 5,000 beta-gamma emitters Transuranic modified materials containing > 2 percent and < 8 percent transuranics by alpha 200 1,000 activity, Th-natural, 232 Th, 223 Ra, 224Ra, and 232U 226Ra, 228Ra, 230Th, 228Th, 231Pa, 221 Ac, m 1, 1291, and 20 200 Transuranics > 8 percent by alpha activity The values in this table apply to radioactive contamination deposited on, but not incorporated into the interior of, the contaminated item. Where contamination by both alpha and beta-gamma-emitting nuclides exists, the levels established for the alpha- and beta-ganuna-emitting nuclides apply independently. b The amount of removable radioactive material per 100 square centimeters (cm2) of surface area is detennined by swiping the area with a dry filter or soft absoibent paper while applying moderate pressure and then assessing the amount of radioactive material on tl1e swipe with an appropriate instfUlllent of known efficiency. For objects with a surface area less than 100 cm 2, the entire surface is swiped; and the activity per unit area is based on the actual surface area. Except for transurarucs :::. 8 percent by alpha activity, 228 Ra. 227 Ac, 2~ Th, 23 <>r'h, 23 1Pa, and alpha emitters, it is not necessary to use swiping teclmiques to measure removable contamination levels if direct scan surveys indicate that the total residual contamination is within the levels for remo\'able contamination. The levels may be averaged over one square meter provided the maximum surface activity in any area of 100 cm 2 is less than three times the level specified. For purposes of averaging, any square meter of surface is considered to be above the level G if: (1) from measurements of a representative number of n of sections it is detennined that 1/n Li, S,:::. G, where Si is the disintegration per minute (dpm)/100 cm 2 detemtined from measurements of section i ; or (2) it is detennined that the sum of the activity of all isolated spots or particles in any 100 cm 2 area exceeds 3G. (G is defined as the levels listed above.) 4.7 Radiation Surveys and Monitoring Program The Radiation Surveys and Monitoring Programs are based on the requirements of 10 CFR Part 20, Subpart F and ALARA principles. Written procedures are prepared for the elements of the Radiation Survey and Monitoring Programs discussed in this section . Deficiencies associated with surveys and the monitoring program or results that exceed the administrative control levels are dispositioned in accordance with the Correcti ve Action Program, described in Section 11 .6 of this license application . 4.7.1 Surveys The radiological survey program consists of routine, work support, and material release surveys (refer to Section 4.8.2.4 below). urveys are conducted to support plant activities in a manner that ensures radiological hazards associated with each activity are properly identified, and relative radiation levels and concentrations of radioactive material are determined. Radiological

License Application fo r the A merican Centrifuge Plant Proposed Change 2020 survey for the purposes of establishing personnel protection equipment or for postino requirements are performed by qualified HP-Ieohnte+an-spersonnel. Decontamination is performed as appropriate considering the gained benefit from waste minimization, ALARA principles and worker access. The routine survey program involves surveys to determine workplace radiological conditions, effectiveness of contamination control measures, and proper identification and posting of radiological hazards. Routine survey frequencies are established based on the stability of operations as demonstrated by the consistency of survey results. Areas within the plant are categorized and scheduled for survey commensurate with their relative radiological hazard and contamination potential. Survey frequencies are based on area occupancy, potential for spread of contamination, and process knowledge. The routine survey program is reviewed annually by the RPM, documented, maintained, and modified to reflect changes in radiological conditions. Table 4.7-1 provides the contamination survey program frequencies for ACP areas. In the event that large areas of removable contamination are identified on accessible surfaces exceeding the levels specified in Table 4.6-1 , the area will be re-posted as a Contamination Area (CA} or High Contamination Area (HCA} and actions will be taken to locate the source of contamination. If access is required to the area, decontamination of the area is initiated as soon as practical with consideration of ALARA principles. Work support surveys are a fundamental element of the RWP process. In-process surveys are conducted as necessary to verify radiological conditions at various points in the work activity and to ensure exposure potentials are maintained in accordance with the ALARA principle. When required by work activities, surveys are conducted by qualified personnel to support decontamination efforts and the release of tools, equipment, and waste material from the work area.

4. 7 .2 Personnel Monitoring Both the U.S. Nucl-ear Regulatory Commission {NRC')-and theU S Department of-Energy (DOE) regulated sources of radiation and radioactive materials are interspersed on the reservation .

'.f-his-situation makes sef}affit-ien-ef personnel exposure between NRG aAd DOE regulated sources impractical. If required, +to comply with the personnel monitoring requirements of 10 CFR 20.1502(a) and (b), 10 CFR 20.1202, and the reporting requirements of 10 CFR 19.13, 20.2106, and 20.2206, the ACP tracks exposures for personnel issued National Voluntary Laboratory Accreditation Program (NVLAP)-accredited dosimeters regardless of whether the exposure is from an NRC or DOE regulated source. Whenever worker notification is required by 10 CFR 19.13, the individual ' s "total exposure" while on the site is reported without differentiating between exposure from NRC-regulated sources and DOE-regulated sources. The established A._personnel monitoring program coAsists can includeof the followin~ determined by the RPM:

License Application fo r the American Centrifuge Plant Proposed Change 2020

• An Administrative Control Level (ACL) of 500 millirem (mrem) per year Total Effective Dose Equivalent per person;
• The intake limit for soluble uranium is set at 10 mg per week;
• Personnel dosimeters to measure the external exposure of personnel ;
• Analysis of personnel occupational exposure and maintenance of exposure records; and
• A network of Fixed Nuclear Acci dent Dosimeters (FNADs) situated in the ACP areas requiring a Criticality Accident Alarm System . A NVLAP accredited dosimeter reader processes dosimeters in the FNADs. The ACP maintains onsite capability to determine neutron flux and energy. The FNADs also serve as area monitors.

Personal dosimeters are also evaluated for neutron dose. In addition, permanent site personnel are provided an indium foil that can be evaluated for neutron activation. If the indium foil indicates exposure to a neutron flux exceeding 10 rads, the dosimeter is read and/or biological materials of personnel may be evaluated.

4. 7.3 External Persons requmng radiation exposure monitoring per 10 CFR 20.1502(a) wear beta-gamma-sensitive dosimeters which are processed and evaluated by a processor holding current NVLAP accreditation from the National Institute of Standards and Technology (NIST) .

Dosimeters are exchanged at least quarterly (plus or minus two weeks) unless authorized in writing by the RPM. The dosimeters may be supplemented, as appropriate, by other types- ef dosimeters (eg, -finger rings, direct-reading -dosimeters, and neutmn -dosimeters) an<l by radiation measurements made with radiation survey instruments. Self reading or alarming dosimeters are used for entry into !IRAs or Very High Radiation Areas If an individual exceeds 50 percent of the ACL during a calendar quarter or the ACL in the calendar year, an evaluation is performed by the RPM for approval by the General Manager. The evaluation is performed to determine the types of activities that may have contributed to the worker's exposure. This may include, but is not limited to, procedural reviews, and review of work practices, work locations, and job assignments. Depending upon the conclusions of the evaluation, the individual may be allowed to continue radiological work; however, work restrictions may be imposed on individuals whose exposure exceeds the ACL. Approval for continued work is documented in the evaluation, as described in the preceding paragraph, which requires approval by the General Manager. Investigations to determine cause, assess the exposure, and document the results are conducted in accordance with written procedures. HP determines any unusual trends or exposures during reviews of external dosimetry results. If the external exposure status of an individual is uncertain, the indivi dual is removed from 4-10

License Application fo r the American Centrifuge Plant Proposed Change 2020 further exposure until HP determines the exposure status and advises management of any special controls or restrictions to be applied . To comply with the reporting requirements of 10 CFR 20.2206, the site submits personnel monitoring information for the Radiation Exposure Information Reporting System (REIRS) report based on the personnel exposure database. This includes summation of internal and external doses as outlined in Section 7 of Regulatory Guide 8.34, Monitoring Criteria and Methods to Calculate Occupational Radiation Doses. The occupational exposure received by ACP employees, subcontractors, and visitors must not exceed the 10 CFR Part 20, Subpart C limits. The ACP requires current year exposure history of an occupational worker as required by 10 CFR 20.2104. Personnel declaring pregnancy are advised to control radiation exposure to an embryo or fetus in accordance with the ALARA principle during the entire gestation period. The ACP complies with the guidelines of Regulatory Guide 8.13, Revision 2, Instructions Concerning Prenatal Radiation Exposure. 4.7.4 Internal The chemical characteristics and retention times of soluble uranium processed at the ACP are such that renal toxicity limitations are the limiting conditions for health effects. A bioassay program is employed to confirm the results of radioactive material contamination control and respiratory protection programs. Bioassay results are the primary means of calculating internal doses. Personnel who have the potential to receive intakes resulting in a Committed Effective Dose Equivalent (CEDE) greater than or equal to 0.1 roentgen Roentgen equivalent Equivalent man Man (remREM) CEDE in a year or intakes of 1 mg of soluble uranium per week participate in the routine bioassay program . Personnel submit bioassay urine samples, such as urine or fecal samples, and partil-'ipatetn lnvivo -monit:or~ng as required by the bioassay program . Table 4.7-2 provides a summary of the bioassay program description and the analytical methods employed. The routine sample submission frequencies and administrative control levels are listed in Table 4.7-3 . Because chemical toxicity is limiting when personnel are exposed to soluble uranium, the uranium action levels have been selected to limit an individual's chronic intake to 10 mg of soluble uranium per week. Personnel participate in follow-up bioassay monitoring when their bioassay results exceed administrative control levels or as determined by HP. Special bioassay studies are performed as necessary and investigations performed when intakes are confirmed or suspected to exceed 1 mg of soluble uranium per week . The ACP Licensee collects "random single void" urine samples from personnel. Isotopic analysis ef-fec-al sam-ples---and of 24-hour urine sampling are not routinely performed, however, these-24-hour samplesanalyses will be considered when dose assessments exceed 0.5 rem CEDE. Bioassay results are used to assign internal dose. The sensitivities of lung counting systems are 4-11

License Application for the American Centrifuge Plant Proposed Change 2020 not es effect~v-e-as urinalysis for Class D uranium ; lung counting is considered *Nhen intake est~mates ~c-eed 0.5 rem-f'EDE. The CEDE per unit of intake by inhalation from Federal Guidance Report No. 11, Limiting Values ofRadionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion, is used to calculate internal dose. HP determines unusual trends during reviews of urinalysis results. If bioassay sample results indicate an internal exposure that exceeds action levels or appears uncertain, additional analyses and removal of the individual from further exposure are considered.

4. 7.5 Airborne Radioactivity The ACP air sampling program is consistent with the basic requirements of Regulatory Guide 8.25, Air Sampling in the Workplace, Sections 1, 2, 5, and 6. Routine general area air sampling is established in areas where airborne radioactivity concentrations may exceed 10 percent of the DAC listed in Table 4.7-4, averaged over 8 hours. Table 4.7-4 also summarizes the airborne radioactivity posting levels. Investigations are performed when airborne radioactivity data indicates personnel exposures exceed 0.8 DAC-hours. Special bioassay sampling is required when air samples exceed 0.8 DAC-hours. Adjustment for respirator use is considered in determining bioassay monitoring.

A combination of low-volume, high-volume, and lapel air samplers are used for job coverage and general area air sampling. Low-volume air samplers are used for routine air sampling and are exchanged at least weekly . Due to radon and radon daughter products, routine air samples are allowed to decay for a minimum of three days. Air sample data is not used as the primary method to determine internal dose, .,. howeverHowever, the data is used to prompt bioassay monitoring. Only air samples collected in the workers' breathing zone (approximately 30 cm) are considered representative. Air sample flow measurement devices are calibrated under standard laboratory conditions at least annually . The NIST traceable standards used have accuracy and precision of 20 percent or better. Lapel samplers are calibrated in accordance with a procedure. 4-12

License Application for the American Centrifuge Plant Proposed Change 2020 Table 4.7-1 Routine Contamination Survey Frequencies Area Surveyed Survey Frequency Uranium Centrifuge Area Yearlya Contaminated Maintenance Areas Quarterly Contamination Control Zones (CCZ) Quarterly Lunchrooms/Breakrooms Notec Permanent Boundary Control Stations (BCSt Weekl y Change Rooms Monthly UF6 Sample Handling Areas and Feed and Monthlya Withdrawal Areas Localized area surveys are taken following an indication of release and during maintenance activities. b When personnel contamination is detected at the BCS, the ensuing follow-up activities include a physical survey of the BCS. C Surveys are performed daily during normal working days (i.e., Monday through Friday). Weekends and plant holidays are excluded. 4-13

License Application for the A merican Centrifuge Plant Proposed Change 2020 Table 4.7-2 Bioassay Program Urine Bioassay Capabilities Comment Workers Participation Selected based on work locations Frequency of Urine Monitoring Monthlya Single void sample, between 60 Routine Urine Sample Volume and 100 mL Fluorimetry or Inductively Primary Uranium Analysis Methods Coupled Plasma (ICP) Mass Spectroscopy ICP Mass Spectroscopy Minimum Detectable <0.006 g -;-g/L 235 U Concentration <o.01s 1!_:g/L 238 U Fluorimetry Minimum Detectable Concentration 5 _IJ_:_g /L Total Uranium Additional Analytical Ca 1abilities Alpha Spectroscopy 0.1 pCi/sampleb Uranium Alpha with Proportional Counter 40 dpm/L Total Uranium in urine 0.-2 nCi µiu

 -l-nvive L1:mg Getrnting 4nC+~bl INDOS (Routine Analysis)

Dose Assessment Software CINDY (Develepmental-a-fle Spec1al) a Samples scheduled for submission every four weeks. b Equipment also used for loose contamination and airborne radioactivity samples for characterization efforts. 4-14

License Application for the American Centrifuge Plant Proposed Change 2020 Table 4.7-3 Internal Dosimetry Program Action Levels Bioassay Frequency Action Level Actions to be Taken Technique Resample to confirm result and Monthly 3 5 µg U/L Urinalysis determine intakeb Routine Restrict individual and resample to Monthly 20 µg U/L determine intakeb Resample to confirm result and 5 µg U/L 2-6 hours after determine intakeb intake Restrict individual and resample to 300 µg U/L Urinalysis determine intakeb Special Resample to confirm result and 5 µgU/L 16-30 hours after determine intakeb intake Restrict individual and resample to 50 µg U/L determine intakeb

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                              ~RelJuired                     or

(,~Htlttlg petfufm- uri na-1-ysi-s 7- nf'i +otal 1::1 In addition, personnel may be assigned a special frequency if deemed necessary by HP. b When intake is confim1ed to be > 1 mg uraniwn, an investigation is perfonned to identify the source of the exposure, assess the impact, and if practical, a means to prevent reoccurrence . Table 4.7-4 DAC and Airborne Radioactivity Posting Levels DAcc, d POSTING NUCLIDEa LEVELb 234 230 1.0 X 1o-l O 1.0 X 1o - l I ha based on Class D U and 2 ercent Class W Th ha based on Class D 234 U and 8 ercent Class W 230 Th 3.0 X 10-II 3.0 X 10- 12 3.0 X 10" 12 3.0 X 10"13

.....Gros   Beta-Gamma based on Class Y            234 Th                               6.0 X lQ*8    6.0 X 10-9 a All values are listed with units of J!Ci/mL.

b Posting Levels are 10 percent of DAC. c The values above are asswned as worst case, i.e., 23°Th is present in each mixture at the highest concentrntion per category as described. d Area may be posted based on calculated DACs from actual airborne radioactivity concentration data. 4-15

License Application fo r the American Centrifuge Plant Proposed Change 2020 4.8 Additional Program Elements 4.8.1 Posting and Labeling Caution signs for Radioactive Material Areas (RMAs), ARAs, RAs, and HR.As are maintained as required by 10 CFR 20.1901 , 20.1902, 20. 1903, 20.1904, and 20.1905. RMAs located within a posted CCZ, CA, HCA, ARA, RA, HR.A or other posted radiological area are not required to be posted as an RMA since a higher level of control is already required . In addition, as noted in Section 1.2.5 of this license application, the following exceptions to the applicable 10 CFR Part 20 requirements have been taken and require an exemption:

• UF6 feed, product, and depleted uranium cylinders, which are routinely transported inside the reservation boundary between plant locations and/or storage areas at the plant, are readily identifiable due to their size and unique construction, and are not routinely labeled as radioactive material. Qualified radiological workers attend UF6 cylinders during movement.
• Containers located in Restricted Areas within the ACP are exempt from container labeling requirements of 10 CFR 20.1904, as it is deemed impractical to label each and every container. In such areas, one sign stating that every container may contain radioactive material will be posted. By procedure, when containers are to be removed from contaminated or potentially contaminated areas, a survey is performed to ensure that contamination is not spread around the reservation.
• In lieu of the requirements of 10 CFR 20.160l(a), each High Radiation Area with radiation reading greater than 0.1 rem REM/hour at 30 cm but less than l remREM/hour at 30 cm is conspicuously posted " Caution, High Radiation Area" and entrance into the area is controlled by an RWP. Physical and administrative controls to prevent inadvertent or unauthorized access to High and Very High Radiation Area is maintained .

4.8.2 Contamination Control 4.8.2.1 Access to Restricted Areas Restricted Areas are areas to which access is limited to protect individuals against undue risks from exposure to radiation and radioactive materials. Unescorted access to Restricted Areas requires the successful completion of the appropriate level of radiological worker training and, if required, a personnel dosimeter. Depending upon the type and extent (or amount) of radioactive material present, Restricted Areas are further identified as RMAs, CCZs, CAs, HCAs, ARAs, RAs, orHRAs. Radiological control is provided by controlling access to areas where radioactive material may be encountered and by requiring that each person who enters those areas recei ve the appropriate level of radiological worker training. Access and departure requirements are specified by procedure and/or reiterated in RWPs. Radiological posting is used to alert personnel to the presence of radiation and radioactive materials, aid in minimizing exposures, and prevent the 4-16

license Application for the A merican Centrifuge Plant Proposed Change 2020 spread of contamination. Where contamination 1s present, contami nation controls are implemented. Table 4.8-1 provides definitions and criteria used for posting ACP Restricted Areas. 4.8.2.2 Equipment and Personnel Monitoring Personnel exiting areas controlled for removable contamination (CCZs and CAs) are required to monitor themselves for contamination after removing their protective clothing and prior to leaving the step-off pad area. Personnel monitoring requirements are specified on RWPs. Equipment and materials are monitored and decontaminated if required prior to removal from CCZs and CAs, or are contained and controlled as radioactive material. 4.8.2.3 Personal Protective Equipment Personal Protective Equipment (PPE) is provided for personnel entering contaminated areas. The type(s) of PPE required is consistent with the individual's work assignment and is dependent upon the type and level of contamination anticipated. With the ef xception for ef emergency evacuations, protective clothing is removed prior to exiting the Boundary Control Station as specified in Radiation Worker Training, RWP, area posting, or procedures. During emergency evacuations, personnel report to designated assembly points and/or monitoring stations where protective clothing is removed and contamination monitoring is performed. Industrial safety equipment, such as face shields, goggles, and acid suits are available. In addition. . full-face negative pressure respirators and full-face positive pressure respirators and other National Institute for Occupational Safety and Health and Mine Safety and Health Administration approved devices may also be utilized for respiratory protection in accordance with Section 4.6.2 of this chapter. 4.8.2.4 Release of Materials and Equipment Materials and equipment are not released for unrestricted use unless the surface contamination levels are less than the levels specified in Table 4.6- 1. Contamination surveys are performed on materials, equipment, and facilities to be released from radiological controls. Use histories are used to supplement surveys of materials or equipment that have inaccessible surfaces. Use histories are summaries of the operational history of the item . Use history information includes the function, location(s) where the item was used, and other relevant evidence to assess the item's potential for internal contamination. Total contamination in bulk, aggregate materials, or waste to be released for unrestricted use or disposal is specified in plant procedures. 4-17

License Application for the A merican Centrifuge Plant Proposed Change 2020 4.8.3 Radioactive Source Control The Radioactive Source Control Program maintains administrative and physical control of sealed radioactive sources. The Source Control Program establishes source custodians and requires leak testing, accountability, and control of sealed radioactive sources. Each sealed source containing more than 100 microcuries (g :-Ci) of beta and/or gamma emitting material or more than 10 µCi of alpha emitting material, other than 3H, with a half-life greater than 30 days and in any form other than gas, is tested for leakage and/or contamination at intervals not to exceed six months. In the absence of a certificate from a transferor indicating that a test has been made within six months prior to the transfer, the sealed source is not put into use until tested. Sealed plutonium alpha sources containing 0.1 µCi or more of plutonium, when not in use, are stored in a closed container designed and constructed to contain plutonium that might otherwise be released during storage. When in use, the ACP will test the sources at least every three months using radiation detection instruments capable of detecting 0.005 µCi of alpha contamination. Leak tests are taken from the source or from appropriate accessible surfaces of the container or from the device where the sealed source is mounted or stored where one might expect contamination to accumulate. Leak testing is conducted by HP. The test is capable of detecting the presence of 0.005 µCi or more of removable contamination, or if a plutonium source has been damaged or broken, the source will be deemed to be loosing plutonium . The ACP will immediately withdraw the sealed source from use and repair or dispose of the source, if determined to be leaking. Within five days after determining that any source has leaked, the ACP will file a report with the NRC Director, Nuclear Material Safety and Safeguards, describing the source, test results, extent of contamination, apparent or suspected cause of source failure, and corrective action taken. A copy of the report will be sent to the NRC Regional Administrator, Region II. The periodic leak test does not apply to sealed sources that are stored and not being used . The sources excepted from this test will be tested for leakage prior to any use or transfer to another person unless they have been leak tested within six months, or three months for a sealed plutonium source, prior to the date of use or transfer. 4.8.4 Radiation Protection Instrumentation Radiation dose rate and contamination survey instruments are selected to measure the types and energies of radiation encountered with gas centrifuge enrichment operations. The primary complement of instrumentation includes alpha/beta count rate and scaler instrumentation plus ion chambers used to evaluate shallow dose and deep dose equivalent readings. Table 4.8-2 describes typical instrumentation available to support the operation of the ACP. The RPM is responsible for maintaining adequate quantities of calibrated radiation detection and measurement instruments. 4-18

l icense Application f or the A merican Centrifuge Plant Proposed Change 2020 Radiological portable instruments are calibrated based on specifications derived from applicable vendors manuals and other nationally recognized guidance as appropriate (e.g., National Council on Radiation Protection 112). The standards found in the ANSI N323 (1978) are followed except for Sections 4.6 and 5.1(3). The following requirements apply to all such equipment and instruments:

• Portable radiation detection and measurement instruments are inspected, maintained, and calibrated at least annually or removed from service.
• Instruments are calibrated following any maintenance, modification, or repair deemed likely to affect operation before being returned to service.
• Calibration sources and equipment used for dose rate instruments are within 5 percent (at 2 sigma) of the stated value and have documented traceability links to the NIST.

Large area uranium slab sources are certified to 10 percent by NIST. Calibration sources used to calibrate contamination-monitoring equipment are within 20 percent (at 2 sigma) for activity and 10 percent (at 2 sigma) for surface emission rate.

• Portable HP instruments that are in use but do not have a built in automatic functional test feature are source checked daily, or prior to using the instrument if not used on a daily basis. Instruments with the automatic functional test feature that are in use are checked once a week.

4.8.5 Records and Reports Radiological protection records demonstrate the effectiveness of the overall program and document personnel exposure. Records are maintained in the form required by 10 CFR 20.2110 and are retained as required by 10 CFR 20.2101 through 20.2106 according to the Records Management Program as outlined in Section 11 .7 of this license application. The Licensee follows the guidance contained in ANSI Nl3 .6, Practice for Occupational Radiation Exposure Records Systems, 1999 Edition, for radiological protection records. Reports and notifications of RP issues are made pursuant to 10 CFR Part 20, Subpart M; 10 CFR 30.50; 10 CFR 40.60; 10 CFR 70.50; and/or 10 CFR 70.74. Events requiring reporting to the NRC are investigated, tracked in a database, and monitored through completion in accordance with the Corrective Action Program. Details of reporting and notification for ACP incidents are described in Section 11.6 of this license application. 4-19

license Application f or the A merican Centrifuge Plan/ Proposed Change 2020 Table 4.8-1 Posting Criteria AREA CRITERIA POSTING

    '!.Radiation Area      >0.005 rem/hr                                     "CAUTION, RADIATION AREA" measured at 30 cm       but :;; 0. 1 rem/hr                              "TLD and RWP Required forEntr)' "
    '!.High Radiation      >O. l remREM/hour                            " CAUTION, HIGH RADIATION AREA" Area measured at 30       but :;; 1.0 rem/hr                           "TLD, Supplemental Dosimeter and RWP cm                                                                     ReQuired for Entry"
             !!_High       >1.0 rem/hr                                   "DANGER, HIGH RADIATION AREA" Radiation Area                                                     "TLD, Supplemental Dosimeter and RWP measured at 30 cm                                                                   Required for Entry" i!.Very High      > 500 rads/hr                                     " GRAVE DANGER, VERY HIGH Radiation Area                                                                  RADIATION AREA" measured at l m                                                       " Special Controls Required for Entry"
                                                                                  " Contact PSS Before Entry" Contamination        Levels > l time but :;; 100 times            " CAUTION, CONTAMINATION AREA" (Removable)        Table 4.6-1 values                                      "R WP Required for Entry" High        Levels > 100                                  '*CAUTION, HIGH CONTAMINATIO Contamination       Times Table 4.6-1 values                                          AREA

(Removable) " RWP Required for Entry" Fixed Removable Contamination < Table 4.6-1 " CAUTIO . FIXED CONTAMINATION Contamination* levels and total contamination levels > AREA" Table 4.6-1 column 3 values Airborne Levels 0.1 Times Table 4.7-4 DAC " CAUTION, AIRBORNE Radioactivity Area \'alues RADIOACTIVITY AREA'. or

                                                                                    " CAUTION AIRBORNE RADIOACTIVITY AREA"
                                                                              "' Respiratory Protection Required" Contamination       Levels nonnally less than Table 4.6-1              " CAUTION, CONTAMINATION Control Zone        removable column values with potential                      CONTROL ZONE" to exceed Table 4.6-1 removable column values Radioactive       An amount of radioactive material used                         " CAUTION" Material Area or      or stored exceeding 10 times the quantity              " Radioactive Material Area" Radioactive      of such material specified in 10 CFR Part                           or Material Storage       20, Appendix C                                   " Radioactive Material Storage Area" Areab

• If the area has been sealed with contrasting fixatives or alternative methods and labeled in accordance witl1 metl10ds approved by ilie RPM, the area is exempt from posting as a Fixed Contamination Area.

b Areas posted as a Contamination Control Zone, Contamination Area, High Contamination Area, Airborne Radioactivity Area, Radiation Area. High Radiation Area, or Very High Radiation Area need not be posted as Radioacti\'e Materials Area. 4-20

License Application f or the A merican Centrifuge Plant Proposed Change 2020 Table 4.8-1 Posting Criteria (continued) Definitions Airborne Radioactivity Area (ARA) - Any area where the measured concentration of airborne radioactivity, above natural background, may be reasonably expected to exceed either: (1) 10 percent of the DAC sampled over 8 hours, (2) a peak concentration of 1 DAC sampled over no more than 1 hour, or (3) soluble uranium concentration exceeds 50 gg/m 3 averaged over 8 hours. Contamination Area (CA) - An area where transferable contamination levels are greater than the release limits stated in Table 4.6-1 , but less than or equal to 100 times those limits. Contamination Control Zone (CCZ)-An area where transferable contamination levels are less than the release limits stated in Table 4.6-1. CCZs are essentially buffer zones established where discrete areas of contamination may be occasionally encountered as a result of plant size. Fixed Contamination Area (FCA) - An area containing radioactive material that cannot be readily removed from surfaces by nondestructive means, such as casual contact, wiping, brushing, or washing. High Contamination Area (HCA)- An area where transferable contamination levels are greater than 100 times the limits stated in Table 4.6-1. High Radiation Area (HRA) - An area, accessible to personnel, in which radiation levels could result in a person receiving a dose equivalent in excess of 0.1 rem Deep Dose Equivalent (ODE) in 1 hour at 30 cm from the radiation source or 30 cm from any surface that the radiation penetrates. Radiation Area (RA) - An area, accessible to personnel , in which radiation levels could result in a person receiving a dose equivalent in excess of 0.005 rem ODE in 1 hour at 30 cm from the source or from any surface that the radiation penetrates. Radioactive Material Area (RMA) - An area or structure where radioactive material is used, handled or stored. Restricted Area - An area, to which access is limited for the purpose of protecting individuals against undue risk from exposure to radiation and radioactive materials. Very High Radiation Area (VHRA) - An area, accessible to personnel, in which radiation levels could result in a person receiving an absorbed dose in excess of 500 rads in one hour at 1 meter from a radiation source or 1 meter from any surface that the radiation penetrates. 4-21

licen e Application for the American Centrifuge Plant Proposed Change 2020 Table 4.8-2 Radiological Protection Instrumentation and Capabilitie Instrument Manufacturer Use Detection Limit alpha - 4 pCi Air sample counting and beta-gamma - 8 pCi LB5100 Tennelec Removable contamination alpha- 20 dpm/100 cm2 sample counting beta-gamma - 40 dpm/100 cm2 Personnel contamination ~ m / 1 0 0 cmi---tetal L-BI04JAS Berthcld m-eA-i-lOH:n-g contami nati ona Personnel contamination 5,000 dpm/100 cm 2 total PCM2 Eberline monitoring contamination Alpha personnel Ludlum 12 contamination monitoring with GM Ludlum I 00 cpm above backgroundi,,l! and removable probe contamination surveys Beta-gamma personnel Ludlum 12 contamination monitoring with alpha Ludlum 100 cpm above backgroundi.l! and removable scintillator contamination surveys Health Physics 0 00 I rem (rad)/hr-R~M ~00 NeutreA--9ese/9ese Rate Instruments 999 rem (rad)/hr

 +elelecteF         R}eftt-1-le            fieHt-gamma-Oose/I)ese rnte              0 mR/hr 1,000 Rt'hr R02Q               Ludlum                 Beta-gamma D ose/Dose rate               0 mR/hr - 5 R/hr The Berthold M0111tors-tlre-set - t e-alarn-1 *llh <JS perceRl confidence 1:1pon detect1on--ef-tess----1-ttt!11 or equal lo SJ)OO dpm-total conta11111tattet1 per detector The actual detection hmrts ure appro,imalel:, ~ sigma~

bahgro1:1nd. nnd depend'.:> on detector sire. emcieHC',. buckgro1:111d, and count time

     *"   Personnel are trained in Radiation Worker Training to notify HP when contamination is detected greater than 100 counts per minute (cpm) above background. The maximum acceptable background count rate is 300 cpm.

l!c Minimum calibration frequency is annual or manufacturer recommendations. The instruments listed above are used for routine operations. Additional instruments are available to support emergency response. 4-22

License Application for the American Centrifuge Plant Proposed Change 2020 4.9 References

1. ASME N509-1989, Nuclear Power Plant Air-Cleaning Units and Components

2. ASME N5 10-1989, Testing ofNuclear Air-Treatment Systems

3. ANSI/American Nuclear Society 3 .1, Selection, Qualification, and Training ofPersonnel for Nuclear Power Plants, 1987 Edition

4. ANSI N13.6, Practice for Occupational Radiation Exposure Records Systems, 1999 Edition

5. ANSI N323-1978, Radiation Protection Instrumentation Test and Calibration

6. Federal Guidance Report No. 11, Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion, and Ingestion

7. NUREG-1520,_Standard Review Plan for the Re1 *ie1t' (ifa U cense Application.for a Fuel Cycle Facilitt_gy License Applications, Revision 2

8. Regulatory Guide 8.13, Revision 2, Instructions Concerning Prenatal Radiation Exposure

9. Regulatory Guide 8.25, Revision 1, Air Sampling in the Workplace, Sections 1, 2, 5, and 6

10. Regulatory Guide 8.34, Monitoring Criteria and Methods to Calculate Occupational Radiation Doses, Section 7 4-23

License Application for the American Centrifuge Plant Proposed Change 2020 Blank Page 4-24

License Application/or the American Centrifuge Plant Proposed Change 2020 5.0 NUCLEAR CRITICALITY SAFETY The American Centrifuge Plant (ACP) possesses large quantities of enriches uranium hexafluoride (UF6) at enrichments of ur---+e-!0 weight (wt.) percent uranium 23S (~tB. The commercial ACP operation is designed to enrich and safely handle up to 10 weight (wt.)% uranium-235 (2 35U) . The HALEU Demonstration Program is designed to enrich and safely handle uranium with an operational limit less than 20.0 wt. percent 235 U; however, enrichment levels up to 25 wt. % 235 U are authorized to permit for process fluctuations which can result in higher weight percent material . The maximum acceptable enrichment is identified for each operation evaluated for nuclear criticality safety (NCS). The specific authorized uses for each class of U. S. Nuclear Regulatory Commission (NRC)-regulated material are shown in Table 1.2-2---3 (commercial ACP operation) and Table 1.2-4 QIALEU Demonstration Program) of this license applicati-oo. The Licensee is required to comply with the performance requirements of 10 Code ofFederal Regulations (CFR) 70.61 . 10 CFR 70.6l(d) requires that the risk of nuclear criticality accidents be limited by assuring that under normal and credible abnormal conditions, nuclear processes are subcritical, including use of an approved margin of subcriticality for safety. It also requires that preventive controls and measures must be the primary means of protection against nuclear criticality accidents. Accordingly, these requirements are implemented through this£hapter summarizes the ACP Nudear C'titi-eal1ty Safety ( NCS)_Program . In accordance with the requirements contained in 10 CFR 70.62, the likelihood and risks of an inadvertent nuclear criticality we~re evaluated in the Integrated Safety Analysis (ISA) . The evaluation consider~ea+noderation events, maintettance evolutions, ;:nachine upset conditions, ane e-yl-iilfier operations accident sequences caused by process deviations or other events internal to the facility and credible external events, including natural phenomena. Criticality Events are derived and evaluated through the process of generating Nuclear Criticality Safety Evaluations (NCSEs). In the case of the commercial ACP operation, Nuclear Criticality Safety Reports (NCSRs) were generated that will be transitioned to NCSEs prior to commencement of commercial plant operations. NCSEs will be developed based on the detailed design of the commercial ACP operationThe l~A effort documented these evaluations tn- NCS Reports that wiH-tn tttrn- form the oases-to develop Nuclear Criticality Safety EvalUittt0!1s (NCSEs) addressing the detailed design . If changes to the SANCSEs or NCSRs are identified during the----aevelopment of the NCSEs, the Licensee will revise the ISA, as necessary, to include any new or updated event sequence information, identify additional double contingency controls, or credit additional items relied on for safety (IROFS). The ISA concluded that includes credible nuclear criticality accident scenarios tltat cettkl-he--i-eettt~f'ied-feF---the ACP were controlled lhrough a combination of admffiislrative and engineered controls to assure that all nuclear processes are subcritical under normal and credible abnormal conditions. Additionally, preventative controls and measures are the primary means of protection against criticality in compliance with the performance requirements of 10 CFR 70.61 ( d). The plant has established a threshold of l wt . percent or higher enriched 235 U and 100 g rams (g) or more of 235 U for determining when an evaluation for NCS considerations of planned operations must be performed . This 100 g 235 U mass is a mtA-i-m-um-OHrfactor of +-01 below the minimum critical mass,. al 10 percent :m y e>>fi.chm-en-l,regardless of whether the material is optimally moderated and fully reflectednon-oily, oily, or heterogeneous fur a fuJly rellectedsy-stem . Based on this, the value is sufficiently low to use as a threshold limit. In view of this threshold, 5- 1

License Application fo r the American Centrifi1ge Plant Proposed Change 2020 many of the ACP NCS Program features described in this chapter may not be required to be implemented for operations below the threshold. In this regar<iAs described herein, the NCS Program provides the framework for a defense-in-depth philo ophy to help ensure the risk of inadvertent criticality is maintained acceptably low. The NCS Program also provides the framework and resources for evaluating plant performance in establishing NCS analyses and controls for the design and operation of a uranium enrichment plant. 5.1 Management of the Nuclear Criticality Safety Program 5.1.1 Program Elements The NCS Program described in this chapter is implemented by plant procedures. The NCS procedures address plant personnel NCS responsibilities, adherence to NCSE requirements, review and approval of fissile material operations, posting and labeling requirements, response to NCSE violations, and NCS training requirements. Controls and/or barriers that are relied on to prevent inadvertent criticalities are designated as IROFS in the ISA. The NCS Program meets the Baseline Design Criteria (BDC) requirements in 10 CFR 70.64(a)(2} concerning application of the double contingency principle in determining NCS controls and IROFS in the design of new facilities and new processes. 5.1.2 Program Objectives The NCS Program meets the requirements of 10 CFR Part 70. The objectives of the program include:

• Preventing an inadvertent nuclear criticality;
• Protecting against the occurrence of an identified accident sequence in the ISA Summary that could lead to an inadvertent nuclear criticality;
• Complying with the NCS performance requirements of 10 CFR 70.6 1;
• Establishing and maintaining NCS safety parameters and procedures;
• Establishing and maintaining NCS safety limits and NCS operating limits for IROFS;
• Conducting NCS evaluations to assure that under normal and credible abnormal conditions nuclear processes remain subcritical, and maintain an approved margin of subcriticality for safety;
• Establishing and maintaining NCS IROFS, based on current NCS evaluations;
• Providing training in emergency procedures in response to an inadvertent nuclear criticality;
• Complying with NCS BDC requirements in 10 CFR 70.64(a)(2};

5-2

License Application for the American Centrifuge Plant Propo ed Change 2020

• Complying with the NCS ISA Summary requirements in 10 CFR 70.65(b); and

_* _ Complying with the NCS ISA Summary change process requirements in 10 CFR 70.72; and .

• Complying with the reporting requirements of 10 CFR 70.52 and 10 CFR 70 Appendix A.

5.2 Organization and Administration 5.2.1 Nuclear Criticality Safety Responsibilities The ACP organization and administration are described in Chapter 2.0 of this license application . The General Manager assigns responsibilities and delegates commensurate authority to ACP managers/supervisors for the implementation and oversight of the NCS requirements. The managers/supervisors ensure that sufficient resources are available for implementation of NCS requirements. . The D irector, Nuclear Safety is responsible for implementing the ACP NCS Program . +he-9irector, Nuele-af-Safety reprn1s to the Senior Vice President, field Operations and is responsible for+hedirecl management of the-N(' -A.tnct*ons and admt.nistration ofthe NCS Program on a day-to-day basis The management reporting structure for the ACP is depicted in Chapter 2.0 of this license application. The Director, Nuclear Safety has direct access to the General Manager for nuclear safety matters and reports directly to the Senior Vice President, Field Operations. The ACP organization managers are responsible for ensuring that operations involving uranium enriched to 1 wt. percent or higher 235U and 100 g or more of 235U (hereafter referred to as fissile material operations) are identified and evaluated for NC S considerations prior to initiation of the operation. The organization managers or their designees are also responsible for ensuring NCS evaluations are requested, and for ensuring implementation of the requirements contained in the evaluations for these same operations. For those fissile material operations performed by personnel from multiple organizations, the General Manager assigns responsibility for that operation to a single organization manager or designee. Management is responsible, in their respective operations, for ensuring that personnel are made aware of the requirements and limitations established by approved NCSEs either through pre-job briefings, required reading, training, and/or procedures (based on the complexity of the change). These managers/supervisors are responsible for ensuring fissile material operations that do not have approved NCSEs will not be performed until the necessary approvals have been obtained. Management is responsible for ensuring that only personnel who have received and passed NCS training as specified in ACP NCS procedures will handle fissile material. Managers/supervisors who are responsible for one or more fissile material operations are trained in NCS and ensure appropriate personnel receive NCS training as specified in ACP CS procedures. This training provides personnel with the knowledge necessary to fulfill their NCS responsibilities. Section 11 .3.1.4 of this license application discusses the NCS training program for those who manage, work in, or work near facilities where the potential exists for a criticality accident to occur (i .e. where fissile material handling/operations are performed). 5-3

License Application for the American Centrifuge Plant Propo ed Change 2020 The fissile material operators are responsible for conducting operations in a safe manner in compliance with procedures or work +nstructions and are required to stop operations if unsafe conditions exist. The Director, Nuclear Safety has, as a minimum, a bachelor' s degree in engineering, mathematics or related science or equivalent technical experience, and six years nuclear experience, including six months at a uranium processing plant where nuclear criticality safety was practiced. The Director, Nuclear Safety or designee is responsible for the administration of the NCS Program. This includes reviewing the overall effectiveness of the NCS Program, ensuring that NCS staff members are placed, trained, and qualified in accordance with written procedures, and that NCSEs are prepared and technically reviewed by qualified NCS engineers. The NCS organization is independent of organizations that require NCSEs. Qualified NCS Engineers and Senior NCS Engineers are responsible for performing the following functions :

• Providing NCSEs for fissile material operations;
• Performing walk-throughs of facilities which handle fissile material and advising appropriate management of any NCS concerns;
• Participating in investigation of incidents involving NCS and in the determination of recommendations for eliminating such incidents;
• Assisting in emergency preparedness planning;
• Providing support to the Plant Safety Review Committee (PSRC);
• Participating in the review of procedures that involve fissile material operations to ensure NCSE commitments have been effectively incorporated into operating procedures; and
• Participating in the review of work packages that involve fissile material operations to eHSttre NCSE corl'lffiitments have been effectively incorporated into ,1t*ork paekage instnttt-OA-S For wori-J7avl.cages that are-ttSed-repea+edly-feF-Hte-.sarne kind-ef..job,-th-e review is only -necessary once- For work packages that have the NCSE commitments incrnporated into an app-mved procedure, additional N('S review is not nec-essary, as requested .
• NCS group personnel have the authority to halt any unsafe activity .

The responsibilities of Senior NCS Engineers performing technical reviews of NCSEs are specified in the NCS evaluation and approval procedure. These responsibilities include:

• Verifying that sufficient information is documented to allow independent analysis by a reviewer with knowledge of the process and the C Program ;
• Verifying that credible process upsets related to criticality safety are properly identified 5-4

License Application .for the American Centrifuge Plant Proposed Change 2020 and evaluated;

• Verifying compliance with the double contingency principle;
• Checking for accuracy ; and
• Verifying applicability of the calculational methods.

5.2.2 Nuclear Criticality Safety Staff Qualifications The minimum requirements for a qualified NCS Engineer are:

• Bachelor's degree in engineering, mathematics, or related science;
• Familiarization with NCS by having a minimum of one year experience at an ffift-A-e6 ura-tt*um processittg-+a-tttt-yfacility that process fissionable material where nuclear criticality safety was practiced;
• Completion ofNCS-related training course and KENO V.a training course or equivalent;
• Performance of at least four evaluations under the direction of a Senior NCS Engineer; and
• Performance of walk-through inspections under the guidance of a qualified NCS Engineer.

The Director, Nuclear Safety can modify the minimum qualified NCS Engineer qualification requirements for personnel who have worked for a minimum of three years at other facilities as an NCS Engineer. The minimum requirements for a qualified Senior NCS Engineer are :

• Completion of the minimum requirements for a qualified NCS Engineer;
• Performance of the functions of a qualified NCS Engineer;
• Completion of one year as a qualified NCS Engineer; and
• Approval by the Director, Nuclear Safety.

The Director, Nuclear Safety may modify the minimum Senior NCS Engineer qualification requirements for personnel who have worked for a minimum of five years at other facilities as a nuclear criticality safety engi neer. 5.3 Management Measures 5.3.1 Procedure Requirements 5-5

License Application .for the American Centrifuge Plant Proposed Change 2020 Operations to which NCS pertains are governed by written procedures or work packages These procedures er v,ork packages contain the appropriate NCS controls for processing, storing, and handling fissile material. The NCSE requirements that specify employee actions are incorporated into procedures_or work packages as work instructions and are identified. Identifying these requirements ensures changes to these requirements are not made without review and approval by NCS . The NCSE requirements are incorporated into the appropriate procedures or *,*fork packages as required by the NCS Program procedure. New and modified procedures or work -packages are reviewed by the appropriate safety organizations, including NCS, as specified in the procedure for procedure control and/or work oo>>t-rol-process. NCS reviews the procedures and/or work instruct iens to verify that the appropriate NCSE requirements have been incorporated and to verify that the proposed operation complies with NCS Program requirements. Section 11.4 of this license application provides more details related to the procedure development and change process. 5.3.2 Posting and Labeling Requirements Administrative NCS limits and controls for areas, equipment, and containers are presented through the use of postings and labels-as-spet+led in approved NCSf:~ttreS. Postings and labels are proposed, reviewed, and approved during the NCSE implementation process. review and approval process Postings and/or 1abels are not required for-engineered controls and may not be required for administrative controls when those limits and controls- are included in "in-hand" operating proce*dures These limits and controls are posted on the NCS requirements signs that are controlled and maintained according to as required by the plant NCS procedures. Approved NCSEs specify the wording for the postings Labels are also prepared in accordance with the plant NCS procedures and used as required by determined during NCSEs implementation. Limits and controls are printed or written in an appropriate size, and the postings and labels are placed in conspicuous locations such that they are legible to the operator at the work location, on the specific component, item, or piece of equipment, or posted at the entrance to an operating area or storage area. The specific locations may be specified in the applicable NCSE or determined by the supervision responsible for the material. 5.3.3 Change Control A configuration management (CM) program ensures that any change from an approved baseline configuration is managed so as to preclude inadvertent degradation of safety or safeguards. The CM Program, described in Section 11.1 of this license application, includes organization and administrative processes to ensure accurate, current design documentation that matches the plant's physical configuration . NCS controls that are IROFS are controlled as QL-2 items and NCS controls that are not IROFS are controlled as QL-3 items. The methodology for designating NCS engineered and administrative controls as lROFS is described in Section 3.1.2.3.2.7 for commercial ACP operations and Section 3.1.2.3.2.8 forHALEU Demonstration. The CM program applies toNCS and a change control process is utilized that he! ps ensure that the requirements of 10 CFR 70.72 are met, including the ISA Summary update requirements contained in 10 CFR 70.72(d)(3). Functional and physical characteristics of operationsNCS engineered controls controlled for 5-6

license Application for the American Centrifuge Plant Proposed Change 2020 NCS are described in NCSEs and the ISA. When an NCS engineered control isthose characteristics are required to maintain classified as an IROFS, the management measures described in the CM program associated with the QL-2 classification are applied . Some NCS controls associated with the commercial ACP operations are not IROFS and are classified as OL-3 items.When those functional and physical characteristics are required to maintain double CHntingency, but are not IROFS, the management measures in the-CM program associated with the QL- 3 cfossificationare--appJ.ied. Non- ROFS dou~le-ooflttngency controls will be handled as QL 3 items. QL-3 is a quality grouping for structures, systems, and components required to fulfill the functions and meet the requirements established by the license application. For NCS controls that rely on certain structures, systems, or components, the portions of the CM program within the QL-3 classification as described in this section, as well as the following minimum features, are applied to those structures, systems, and components:

• Components are identified and controlled;
• Modifications are documented and reviewed;
• Change control process is applicable;
• Setpoints and tolerances are established for applicable components;
• Engineering drawings or specifications are provided;
• Procurement controls are provided; and

_* _ Receipt inspection is used when specified. Components and features that are identified in the NCSEs or the ISA are analyzed to determine the "boundary" of the system, encompassing those interconnecting and/or supporting items that are essential to ensure availability and reliability. The boundaries are identified on system drawings and/or other design outputs, and the configuration is verified to be as-built. These components and features are maintained in a design control document for the building or process. Each time a change is planned, the document is reviewed by the individual (e.g., design authority, system engineer, operations manager, maintenance, etc.) planning the change to determine if the change affects an IROFS/NCS ~ ontrol. Changes that could establish new fissile material operations or affect established fissile material operations are reviewed by NCS. The NCS Program establishes and maintains NCS safety limits and NC'S- operating limits -for IROFS/NCS--M{l--deuble contingeney controls in nuc+eaF-processes and maintains adequate management measures to ensure the availability and reliability of the IROFS/NCS and the double co11tingency controls. Operating limits may be established during flow down ofNCS safety limits to ensure their continued reliability and availability. The change control process specifies the organizations required to perform reviews of changes. Changes that affect existing fissile material operations are evaluated by NCS If an item is relied on for the critirnh ty safety--ef.an opera!i{m (i.e., is-an- J..R:GFS or a d{>Uble contingency control), 5-7

License Application .for the American Centrifuge Plant Proposed Change 2020 ll will be identified and NC'S reviews the NC'Sb for the specific OJ}ef ation and to determines if the change affects the analysis performed and the conclusions made in the NCSE. The change request will be approved by NCS only if the change does not adversely impact NCS, or once a revised NCSE has determined that the change is acceptable and meets NCS Program requirements. If a change affects the ISA Summary, it is updated appropriately . In this way, modifications to controlled operations are evaluated and approved prior to implementation and placing the affected structures, systems, or components in service. Records management and document control (RMDC) is another element of CM and is described in Section 11. 7 of this license application. Procedures, documents, and records control programs provide for centralized control and issuance of documents essential to the maintenance of the design history, and a repository for records to verify this maintenance. NCSEs are specifically included in the index of documents that are required to be controlled. 5.3.4 Operation Surveillance and Assessment To ensure that the NCS Program is properly established and implemented, walk-throughs, assessments, and audits are utilized. These activities are specified in ACP procedures. Operating SNMfissile material process areas are reviewed on a regular basis through a combination of walk-throughs and reviews by work crew supervision. NCS walk-throughs of facilities that may contain fissile material operations are performed by NCS personnel to determine the adequacy of implementation of NCS requirements and to verify that conditions have not been altered to adversely affect NCS . These walk-th roughs are performed as specified by the ACP NCS procedure~ on wa~k-throughs . For example, a walk-through inspection can be performed in response to trend data, at the request of the operations personnel, or due to concerns raised by employees or NCS personnel. As a minimum, spet,--.fic fissile material operating areas are assessed by CS personnel via walk-through at least annually, sometimes in conjunction with the assessments discussed below. By distributing the various areas' walk-throughs over a year' s time, NCS personnel are performing a field walk-through on approximately a monthly basis. Work crew supervision provides real-time assessments of fissile material operations within their operating area to ensure NCS requirements are being adequately implemented and operating conditions have not been altered to adversely affect NCS . Fissile material operations management also performs an annual self-assessment to ensure NCS program requirements are being met in the field . ln addition to the annual self-assessments, independent internal audits of the NCS Program are conducted or coordinated by the Piketon Quality Assurance Manager as described in Section 11 .5 of this license application. The purpose of these audits is to determine the adequacy of the overall NCS Program. This includes the adequacy of the NCSEs, internal assessment programs, and implementation of the NCS requirements. The results of these walk-throughs, assessments, and audits are documented and reported to appropriate management. If a condition is identified that is non-compliant with NC S program requirements, field personnel are to report the condition as directed by plant procedures. If the 5-8

License Application fo r the American Centrifuge Plant Proposed Change 2020 condition is not covered by an existing procedure, consultation with a qualifi ed NCS engineer is required before taking any corrective action. Immediate corrective actions may be provided by the responding NCS engineer verbally or in writing. :NCS emergency response is discussed in Section 5.4.2 below and is described in more detail in Chapter 8.0 of this license application. Managers in charge of fissile material operations are provided additional training on NCS and response to NCS deficiencies as described in Section 11 .3.1.4 of this license application and the ACP NCS procedures. Each NCS non-compliance is evaluated by an NCS engineer to determine the impact on double contingency and 10 CFR 70.61 performance requirements. The "as found" field conditions are reviewed against the applicable NCSE and supporting calculational documents to support the shift supervisor in determining reporting requirements. NCS deficiencies are reported in accordance with the requirements contained in 10 CFR Part 70, Appendix A or other appropriate reporting requirements. Incident reporting and investigation is described in Section 11 .6 of this license application. The deficiency data is trended to monitor and prevent future violations. Corrective actions are taken for identified deficiencies in accordance with the Quality Assurance Program Description for the American Centrifuge Plant and the Corrective Action Program as described in Section 11.6 of this license application.:. . _, and FRecords of actions taken are retained in accordance with RMDC requirements described in Section 11 .7 of this license application. 5.4 Methodologies and Technical Practices 5.4.1 Adherence to American National Standards Institute/American Nuclear Society Standards The NCS Program has been developed to comply with the requirements of American National Standards Institute (ANSI)/American Nuclear Society (ANS) ANSI/ANS-8 .l --l-998,2014, ANSI/ANS-8.3-1 997, ANSI/ANS-8.19-2014 l996, and ANSI/ANS-8.20- 1991, ANSI/ANS-8 .21-1995, ANSI/ ANS-8.23-2007, and ANSI/ANS-8.24-2017 standards as discussed in this section with the exceptions noted in Section 1.4. 5.4.2 Process Evaluation and ApprovnlNuclear Criticality Safety Evaluation Each operation involving uranium enriched to 1 wt. percent or higher 235 U and 100 g or more of 235U is evaluated for NCS prior to initiation. The evaluation describes the scope of the operation, evaluates credible criticality accident contingencies, and establishes NCS requirements to maintain the operation subcritical. The evaluation process is governed by written procedures. When an NCSE (or a change to an existing NCSE) is needed for a particular fissile material operation, a request is submitted to the NCS group to evaluate the proposed operation . Other methods for initiating an NCS change include, but are not limited to,_;_ 1) the engineering change process, and 2) the correcti ve actions process, self-assessments, and external audits and inspections. 5-9

License Application fo r the American Centrifuge Plant Proposed Change 2020 In response to the request, an NCS evaluation may be performed or the request may be returned due to inadequate detail , the change is bounded by a current analysis, or the operation does not involve uranium enriched to 1 wt. percent or higher 235 U and with mass of 100 g or more 235 U (see Section 5.4.2.1). If necessary, a NCSE is prepared (or an existing NCSE is revised) to document the analyses performed as specified in the NCS evaluation procedure. A hazard identification process (e.g. , a "What-If' analysis) is used to identify and document potential upset conditions, or contingencies, presenting NCS concerns. Engineering judgment ofthe qualified NCS engineer may indicate the need for a more detailed study. For example, a hazards and operability study may be used if the operation is complex and involves multiple interacting systems that require substantial input from operations, maintenance, and other subject matter experts to identify the possible upset conditions. A contingency analysis is performed in which the subcriticality of a process, given the occurrence of the contingency, is assessed. This analysis demonstrates the double contingency principle for the proposed operation. Fissile material operations must comply with the double contingency principle. The double contingency principle as stated in ANSI/ANS-8.1 -+998,2014, Section 4.2.2, is "Process designs should incorporate sufficient factors of safety to require at least two unlikely, independent, and concurrent changes in process conditions before a criticality accident is possible." The ACP NCS Program meets the double contingency principle by implementing at least one control on each of two different parameters or implementing at least two controls on one parameter. Controls include passive engineered barriers (e.g., structures, vessels, piping, etc.); active engineered features (e.g. , valves, thermocouples, flow meters, etc.); reliance on the natural or credible course of events ( e.g., relying on the nature of a process to keep the density of uranyl fluoride less than a specified fraction of theoretical); and administrative controls that require performance of human actions in accordance with approved procedures or W{)rk instructions, or by other means that limit parameters_within specified values. If two controls are implemented for one parameter, the violations or failure scenarios addressed by the controls will be independent. Application of this principle ensures that no single credible event can result in an accidental criticality or that the occurrence of events necessary to result in a criticality is not credible. The NCSE will document the basis for the conclusion that a change in a process or parameter is "unlikely." The basis may be an engineered feature, administrative control, the natural or credible course of events, or any combination of these or other means necessary to ensure the change is unlikely to occur. Where practical, the use of explicit NCS controls will be used as the preferred approach over the reliance on natural and credible course of events. The parameters or conditions relied on and the limits must be specified and justified in the NCSE and controlled . Management measures described in Chapter 11.0 of this license application and other safety programs are sometimes used to help ensure a change in a process or parameter is "unlikely." For example, the Radiation Safety Program and/or the Fundamental Nuclear Material Control Plan may be credited with providing controls on fissile material handling; the Fire Safety Program may be credited with providing controls on combustible material loading and/or hot work activities in fissile material processing/storage areas; the Procedures Program may be credited with ensuring compliance with procedures; etc. Where the natural or credible course of events is relied upon in whole or in part to prevent a process condition change, no specific additional controls will be necessary to maintain them . The 5-1 0

License Application.for the American Centrifuge Plant Proposed Change 2020 factors that influence the process are described in suffi ci ent detail in the NCSE as items related to NCS and programmatically controlled. For items that are established, maintained, and implemented by non-NCS programs, credit for availability and reliability is established as described in Section 11 .1 of this license application without the need for additional NCS controls. For situations where the NCS-credited controls do not provide adequate assurance of availability or reliability (i.e. , situations where non-NCS programmatic and physical plant changes could adversely affect the intended criticality safety function of the items relied upon for criticality safety), specific NCS controls are established, maintained, and implemented to ensure criticality safety . Use of the- natural and credi-ble course -of events or-other means in lieu of -specific administrative-or engineered controls for double contingency protection requires prior NRG review tnld---approval Tttefefj-uest -for review -aflEl-a ~ ~ i f t - e - a l i-en efwhy administrnlive or-engineered -C-<.)H tr-Ols- a-re-not--need-ee,a des-e-fi--ptttm-6r~ -rneasur-es--m--suffi ci en I detai I to permit an understanding of their safety function , and a justification of their inherent unlikeliness This require-ment does not apply to NC'S reliance on the proper implementation of other r>l-ant prngra+n-s-Br-tttana-gemffil,-fnea-sures----t:fta-t-are--desertbed-Ht-('hapler + 1---0--0f-t-lti-s-hcense apf)H-cali on +hi--s requi-remettt-al-so-dees-n e t - a w ~ ~ R £ e s detern1i-ned-to-be--Aon credible or those sequences which do not result in a critical configuration even with the loss of -both double contingency controls-The NCS evaluation process involves a review of the proposed operation and procedures-or work instruction.,, discussions with the subject matter experts to determine the credible process upsets which need to be considered, development of the controls necessary to meet the double contingency principle, and identification of the assumptions and equipment (i .e., physical controls) needed to ensure criticality safety. Engineering judgment of both the anal yst and the technical reviewer is used to ascertain independence of events and their likelihood or credibility. The basis for this judgment is documented in the NCSEs. Depending on the complexity of the operation, anal ytical methods such as Fault Tree and Event Tree Analyses may be used in the evaluation process to examine potential accident scenarios. When needed to support the analytical method, qQ ualitative or quantitative estimates of event frequency are may be developed to support the determination of the likelihood of an event. Once the NCSE is completed, a technical review of the evaluation is performed and documented. The technical review of an NCS evaluation is performed by a Senior NCS Engineer or is- an N CS Engineer completing the technical review under the guidance of a Senior NCS Engineer. The NCSE documents the NCS requirements for the operation. The NCS requirements include the process conditions that must be maintained to meet the doubl e contingency principle or preserve the documented basis for criticality safety and restrict the modes of operation to those that have been anal yzed in the NCSE . The requirements to be included in operating procedures ftH6/-0F wo1 k instructions, and postings are identified . The NCSE approval process fH'-5-t involves the acceptance of the NC SE by the technical reviewer. The supervisor of the affected operation also reviews the NCSE to confirm the NCSE adequately identifies normal and credible abnormal conditions and establishes requirements that are 5- 11

License Application fo r the American Centrifuge Plant Proposed Change 2020 verifiable and compatible with the planned operation. A review is then per formed by ti he Director, Nuclear Safety performs a review to ensure consistency with other NCSEs and other potentially conflicting requirements or regulations. After approval by the Director, Nuclear Safety, a review is performed in accordance with 10 CFR 70.72 as described in Section 11 .1.4 of this license application to determine whether prior NRC approval of the NCSE is required. PSRC approval is required for initial NCSE approval and for changes that impact the ISA Summary . After +niti-al approval, if NRG approval is not required and the change does not impact the lSA Summary, tile NCSE is revievved by the responsible organization manager. Editorial changes require only the approval of the Director, Nuclear Safety. Editorial changes are defined as changes that do not change the technical basis of the NCSE. Once approved, the NCS controls, limits, evaluation assumptions, and safety items are verified to be fully implemented in the field. The operationsoperating organization and NCS personnel perform this verification process. The documentation of this verification process is maintained as a quality record along with the NCSE . Management of the operating organization is responsible for implementing, through training and procedures or work instrutten-s, the conditions delineated in the NCSE. Operational aids such as postings, labels, boundaries for fissile material operations, and fissile material movement guidelines are providedmay be used to as"5pecified inimplement the NCSE. The manager/supervisor ensures postings and labels are prepared and verify that they are properly installed as-required by the to support implementation of the NCSE. The procedures attd/or work instructions are prepared or modified to incorporate the NCSE requirements. Managers/supervisors are responsible for ensuring the employees understand the procedures and/or work instructions and understand the NCS requirements before the work begins. Each completed NCSE is issued as a controlled document. Completed NCSEs are archived and retrievable as permanent quality records in accordance with the RMDC requirements described in Section 11. 7 of this license application. The NCSE process provides assurance that operations will remain subcritical under both normal and credible abnormal conditions. Emergencies arising from unforeseen circumstances can present the need for immediate action. If NCS expertise or guidance is needed immediately to avert the potential for a criticality accident, direction will be provided orally or in writing. Such direction can include a stop work order or other appropriate instructions. Documentation will be prepared within 48 hours after the emergency condition has been stabilized. New oper-aliO!lS must con~etthle-c-onttngettey prin cif:lle-5.4.2.1 Non-Fissile Material Operations Some operations involve situations in which the uranium has an enrichment ofless than 1 wt. percent 235 U or an inventory of less than 100 g 235 U. These operations are termed "non-fissile material operations" and are performed without the need for NCS double contingency controls. The determination of which operations are fissile versus which operations are non-fissile are made by NCS and may be contained within a NCSE or as a separate document. When the detenninati-efl--i-s mtt-si-oe a -NCSE, the determination need net-be performed by a qualtfted-NCS Engineer The determination of an operation being non-fissile must include normal and credible abnormal upset conditions to ensure the enrichment and/or inventory are maintained below 1 wt. percent 235 U or 5-1 2

License Application fo r the American Centrifuge Plant Proposed Change 2020 below 100 g 235 U. Controls are sometimes applied to a non-fissile material operation to ensure it does not inadvertently involve fissile material. This determination is made by an NCS engineer in collaboration with the responsible line manager. 5.4.3 Design Philosophy and Review Through the CM Program, designs of new fissile material equipment and processes must be approved by NCS before implementation. Where practical , the use of engineered controls on mass, geometry, moderation, volume, concentration, interaction, or neutron absorption will be used as the preferred approach over the use of administrative controls. Advantage will be taken of the nuclear and physical characteristics of process equipment and materials, provided control is exercised to maintain them if they may credibly degrade such that control of the parameter is jeopardized. The preferred des-ign approach includes two goals The first is to design equipment such that N{'-&--i-ttFHie-j:}eA-Oett~e-anteum-ef+R-temal moderation oF-fi ssi Ie concen~r-ee-ef ~>>ters-pei=sed-HlOderatiet-1 oet-weetH.mt-l-5*;--of-the-thickness of reflectors The second i-s-t-o-rn-i-ni-m~ possibility -of accumulating fissile material in inac£essible locations and, where practical, to use favorable geometry for those inac<:essible locations Passive design controls are preferred to active design-ootttrel-s - The preferred design approach establishes a ru-efeffee-hierarchy of controls. The use of passive engineered controls: in particular, passive engineered geometry control is the most preferred . The order of preference for NCS controls is ( 1) passive engineered, (2) active engineered, (3) enhanced administrative, and (4) simple administrative controls. The adherence to thisthe preferred design approach is eetet=m-i->>edutilized during the preparation and technical review of the NCSE performed to support the equipment design . This preferred design approach is implemented as described in NCS procedures. Deviations from the preferred design approach are justified in supporting documentation to the NCSEs. Fissile material equipment designs and modifications are reviewed to ensure that engineered controls are used for NCS to the extent practical . Administrative limits and controls will be implemented to satisfy the double contingency principle for those cases where the preferred design approach is not practical. 5.4.4 Criticality Accident Alarm System Coverage A criticality accident alarm system (CAAS) that complies with 10 CFR 70.24 and ANSl/ ANSl -8 .3-1997 is provided to alert personnel if a criticality accident occurs. The system utilizes an audible and/or visual signal to alert personnel in the area to evacuate to reduce radiation exposure resulting from the incident. The need for CAAS coverage is considered during the development process for CS evaluations. In general , coverage is provided for fissile material operations, except the UF6cylinder storage yards as specified in Section 1.2.5 of this licen se application. Other exceptions to CAAS coverage are documented in NCS evaluations and are based on a conclusion in the NCSE that a criticality accident is non-credible in the area where the fissile material operation is ongoing. Conclusions of non-credibility require at a minimum that the inventory of 235 U in the area is Jess than 700 g. In addition, CAAS is not required for areas having material that is either packaged or stored 5-1 3

license Application for the A merican Centrifuge Plant Proposed Change 2020 in accordance with 10 CFR Part 71 or specifically exempt according to 10 CFR 71..Ll.53 . Areas that do not contain fissile material operations do not require a NCSE and do not require CAAS coverage. The CAAS is designed to detect gamma neutron radiation levels that would result from the minimum criticality accident of concern as defined by ANSI/ANS 8.3-1997 and to provide an audible evacuation alarmannunciation by audible evacuation alarms that are supplemented by visual alarms in some areas, such as high-noise areas. A secondary function is to activate the building radiation warning lights and alarms at the X-3012 Process Support Building Area Control Room (ACR).,_and the X-1020 Emergency Operations-Center For each area requiring CAAS coverage, a monitoring system is installed that provides coverage of the area by at least !:we-one independent detection units,each-wi-Httheability to actuate the alarm This arrangement allows for one detection unit to be temporarily out of service with fissile operations continuing under the coverage of the other detection unit. A detection unit is a set of at least three neutron sensilive--radiation detectors that may be co-located or may be distributed over the area. The detection logic of the system requires that two of the three neut-ret1-detectors must be activated to initiate the building evacuation alarm system . Each detector may be logically part of more than one detection unit. The building evacuation alarm system includes interior evacuation horns and exterior radiation warning lights to deter personnel from re-entering the building after an evacuation. In addition, facilities within 200 125 feet of a building/faci lity requiring CAAS coverage have radiation evacuation horns installed inside and radiation warning lights installed on the exterior. Personnel who have routine access to these facilities have been trained to recognize and respond to these indications as described in Section 11.3. 1.1.2 of this license application. To protect against the loss of coverage, the CAAS includes redundant decision logic, a backup power supply, detector status information and system self-diagnostic information are provided to the X-3012 building ACR and X-H}20 building. The CAAS has been designed to survive and/or withstand credible abnormal events as described in the accident analysis for a sufficient time to warn personnel to evacuate. In the event CAAS coverage is lost for an operation, plant procedures provide for compensatory actions, which may include shutdown of equipment, limiting access, halting movement of uranium-bearing material, or other actions, such as use of personal alarming dosimeters for personnel that must access the area during a CAAS outage. Potential criticality accident locations and predicted accident characteristics are evaluated and documented in sufficient detail to assist in emergency planning as described in ANSI/ANS-8.23-2007. Additional information t)fO'vided by the-CAAS includes a historical log of events ai=Hl the ffif"labtht-y-tot11onitor-att-O--fecefd--the-efi+i-Rl~ty accidenl for managing the post accident situation and any -remedf.al--aetten---Nregarding nuclear accident planning and response is discussed in SectionChapter 8 2 24 {>f the Emergency Plati for the Ameri-0an CentFi-fuge--Plant. 5-14

1 License Application for the American Centrifi,ge Plant Proposed Change 2020 5.4.4.1 Portable CAAS In the event a fissile material operation requiring CAAS coverage is performed beyond the detection range of established CAAS instrumentation, a portable unit may be used. The portable unit has the same detection capabilities as the permanently installed units, although those capabilities may be based {m gamma radiation. Alarm annunciation, however, is usually limited to the immediate area within the audible range (confirmed to 65 feet or more) of the unit's alarm with an additional telemetric link to the X-3012 ACR and X 1020. This link will transmit the location of the unit, if mobile, and allow the use of the plant PA system to warn personnel within 125 200 feet of the area of the portable unit to evacuate. A portable unit will not be used for more than 24 continuous hours and it may be located indoors, outdoors, or on a vehicle. If fissile material operations in an area without a permanently installed CAAS are required to exceed 24 continuous hours, all personnel not directly involved in the affected operations, or otherwise required for the safety or security of the facility, will be evacuated from an area within a 6-5 125 foot radius of the fissile material until the operations are concluded. In addition, affected operations shall be terminated as soon as safely achievable. 5.4.5 Technical Practices 5.4.5.1 Application of Parameters The primary parameters utilized in the NCSEs are summarized below, along with examples of how the parameters are controlled at the ACP. More details on the technical practices associated with evaluating and implementing controlled parameters is provided in the NCS program procedures. Moderation Water is considered to be the most efficient moderator commonly found in the ACP . This is because optimally moderated U 0 2F2/water solutions are more reactive than hydrocarbon oi}/UF4 solutions at worst credible concentrations experienced in vacuum pumps (Reference +.H S). When moderation is not controlled either optimum moderation or worst credible moderation is assumed as the normal case when performing analyses. When moderation is controlled, credible abnormal process upset conditions determine the worst-case moderated conditions. Generally, moderation control is not maintained by measurement; however, when used, dual independent sampling methods are implemented. Moderation control is applied to prevent moderators (other than moderation due to air in-leakage) from entering plant equipment containing UF6. In areas where greater than the safe mass of uranium (as defined below) is handled, processed, or stored and moderation controls are applied, that facility ' s pre-fire plan (reference Section 7.1.4 of this license application) includes any unique firefighting strategy or tactics that may be needed to limit the use of moderator material. However, even in these areas, the application of the double contingency principle ensures the worst credible loss of moderation control cannot result in a critical configuration without an additional independent and concurrent upset event. 5-15

license Application.for the American Centrifuge Plant Proposed Change 2020 The centrifuge process equipment is comprised of a variety of closed systems designed to process gaseous UF6. This closed system prevents minimizes the introduction of moderation due to wet air in-leakage. Al-se;--bBecause UF6 reacts chemically with moisture (a moderator) to produce solid uranium-bearing compounds that impedes the proper operation of the process equipment, the UF6 bearing systems are designed to minimize introduction of moisture. Moderating materials can be present as interstitial moderators that are in solution or intermixed into the fissionable material compound (e.g., water in uranyl fluoride solution). Moderating materials may also be present as interspersed moderators that exist as moderating materials located between distinct lumps or regions of fissionable material (e.g. sprinkler activation). lnterstitial Interspersed moderation issues are discussed in the Reflection section, below. Volume Volume limits are used as specified in NCSEs. The bases for volume limits are provided in each NCSE prepared for those operations requiring containers. Specific details of these bases can be obtained by referring to the applicable NCSE. When volume control is used, the size of the containers is ensured through the CM Program and/or by procedurally requiring the use of certain containers for fissile material operations. Interaction Interaction is controlled by spacing items bearing fissile material when those items could result in a criticality accident if not properly spaced. The spacing necessary to maintain a safe array of fissile material units is determined in the NCSE performed for the array. The amount of spacing needed between items is determined based on analysis of the normal and credible abnormal process upset conditions for the particular operation. The basis for the spacing is documented in NCSEs. In accordance with the preferred design approach, described in Section 5.4.3 of this chapter, passive engineered controls are used to the extent possible to ensure spacing requirements are maintained. When used, the structural integrity of the spacers or racks is sufficient to maintain spacing for normal and credible abnormal upset conditions. Geometry Geometry control is applied by limiting equipment dimensions for those systems that depend on the geometry for criticality safety. The geometry is determined in the NCSE that is performed for each system and depends on the normal and credible abnormal process upsets conditions related to the specific system. Geometry controls are specified in the NCSEs, are maintained by the CM Program, and are verified prior to authorizing initial operation. "Safe geometry" is a term typically used to describe systems that are not dependent on any other nuclear parameter for criticality safety.

"Favorable geometry" is a term typically used to describe systems that rely on one or more stated parameters to maintain criticality safety. However, the use of these terms is not rigidly applied throughout the available literature. Both "safe geometry" and "favorable geometry" dimensions may be obtained from established standards or operation specific reactivity calculations.

5-16

license Application for the American Centrifuge Plant Proposed Change 2020 Mass controls are applied on a case-by -case basis depending on the fissile material operation involved. The acceptable mass is determined based on the specific NCSE performed for the operation . The safe mass value depends on many factors including the geometry, the 235 U enrichment, composition, etc. Safe mass values may be obtained from established standards or operation specific reactivity calculations. "Safe mass" is defined as being not more than 43 .S percent of mi-flimum critical (keti: - 1.0) mass for specific system conditions of enrichment, geometry, moderation, reflection, etc. the quantity of fissile material that is safely subcritical under the most reactive credible conditions (defined for a given isotopic composition and physiochemical form), including allowance for overbatching. Experimental data is not used as the sole source for safe mass values. Safe mass values are chosen to ensure no single credible upset can result in a critical configuration. When safe mass values are dependent on the geometry, enrichment, composition, or some other parameter, the combination of mass and the other parameter is used as one control to meet the double contingency principle. The safe mass values are communicated to the operating personnel via the operating procedures and/or v,ork packages. Unless specifically controlled, an item containing enriched uranium is assumed to contain the most 235 U credible based on the available volume. When mass is determined through measurement, instrumentation that is subject to management measures is used . Enrichment Uranium-containing material in the ACP with 235 U enrichment Jess than 1 wt. percent is considered incapable of supporting a nuclear chain reaction, but interaction of such materials with materials of higher enrichment is taken into consideration in the specific NCSE for those operations which invol ve material enriched to greater than 1 wt. percent. The maximum 235 U enrichment ofUF6in the ACP HALEU cascade is lO limited to less than 20 wt. percent with the potential for momentary enrichment transients up to 25 wt. % 235 U during HALEU cascade operations. Small quantities of greater than -l-020 wt. percent 235 U may also be present outside of plant equipment in the form oflaboratory samples or standards. Some buildings on the reservation may be used to process and/or store fissile material from both the ACP and Portsmouth Gaseous Diffusion Plant (GDP). Although the GDP has historically processed material at greater than 2 10 wt. percent 235 U, this material is no longer readily available to interact with ACP operations. However, for conservatism, some operations in these common buildings may be analyzed at greater than 2rn wt. percent 235 U enrichment. HALEU Demonstration does not involve buildings that contain legacy equipment. The maximum 235 U enrichment for each operation is established by the specific NCSE. The NCSE specifies the maximum acceptable enrichment for each operation. Credible process upset conditions that could alter the 235 U enrichment are also considered in the NCSEs. -9tte--t.o-the et-f+IBHhy +n--0btaining rel-table; -real-t-i+ne-en d-ohmern -measurements-that-areooth accurate-and precise enough to -use as a NC'S control, enrichment is assumed to he the maximum -c-re<:iible for -each opernt*en . When the enrichment of uranium needs to be measured for an NC S control, the measurement is obtained using either installed equipment or based on samples analyzed in a 5- 17

License Application for the American Centrifuge Plant Proposed Change 2020 laboratory . Density The density of materials used in a given operation is justified in the NCSE for the operation being considered. If the density must be controlled to maintain compliance with the double contingency principle, it will be documented in the specific NCSE for the operation and it will be measured using instrumentation. UF6 in the gaseous phase, at any credible pressures and temperatures existing in the plant equipment, is incapable of supporting a nuclear chain reaction even when intermixed with hydrogenous material (e.g., hydrogen fluoride [HF]). UF6 in the gaseous phase in plant equipment has low material density . Heterogeneity Heterogeneous configurations are considered for those operations that involve small fissile material and moderator regions. Heterogeneous grnupings rn-ay-oc-atf-f-or-tke-ttaRGH-JtgBf-sm-al+-sa+Hp~tmtaiAeP.r.-however, I0 wtc-percent ;n,u is assumed-fef-s-ample~h~-safe.mass basis. Usittg-t-he-homogeneous safe mass of IO wt percent ~~u is also safe for heterogeneous W wt percent ~ l I because, -at this enrichment, the homogeneous and heterogeneous minimum criti<>al masses are close in value. Concentration Concentration controls are used on a case-by-case basis. When the criticality safety of-an OJ:}Cralion depeoo'5"-ett--t+le-eoocenl-fation-ef...fts-sHe-tnateri-al , the nledtttm is samplee-twice, the samf*eS are verifi-ed-to-oo-f>>'E}f}eH-Y taken by a second-individual, and the-tv.o samples are-i-fttiependently analyzed as required oy the specific N('SE for the operation involved The specific controls and details are documented in the NCSE for each operation that relies on concentration controls. No OJ:}CJ"-ations exist at the plant-wher-e-efteett+ra-lton control is appHee--t&filloperntiott-+n-vol-vtng more than a safe mass of uraAttttn A container with concentration controlled solution is kept normally closed Precipitating agents, including freezing, are controlled as necessary to ensure they do not inadvertently increase the concentration . A-typt£-al-eper-atmg-l+ltlt! ~ 5 g 21 "Y-peH-i-tet=, r~dless of enriehmen-t- _A concentration of 235 11 .6 g U per liter is considered subcritical at any enrichment, as recognized by ANSI/ ANS-8 .1: 2014. If, under all postulated conditions, the concentration is always less than 11 .6 g 235 U per liter, the operation is considered subcritical. Reflection Normal and credible abnormal reflection is considered when performing NCS evaluations. The possibility of full water reflection is considered when performing analyses. 1nlerstitial Interspersed moderation is evaluated with either full water reflection or water films with a bounding water density value to simulate sprinkler activation or precipitation combined with full density water blocks to simulate personnel. It is recognized that concrete can be a more efficient reflector than 5-18

License Application for the American Centrifuge Plant Proposed Change 2020 water, and its potential presence is considered. Reflection controls are used to limit the potential reactivity of a fissile material operation. Neutron Absorption When neutron absorbers are used as NCS controls, the intended distributions and concentrations under both normal and credible abnormal conditions are maintained in accordance with the requirements of the applicable NCSE and ANSVANS-8.21-1995 . These requirements are: representative sampling of the neutron absorber, sampling at a frequency based on the environment to which the neutron absorber is exposed, analyzing of samples for all material attributes for which credit is taken in the NCSE, and periodic inspections of fixed neutron absorbers to ensure adequate distribution as specified in the NCSE. An NCS evaluation can take credit for the neutron absorption properties of the materials (1) added specifically for the purpose of absorbing neutrons, and (2) of construction, provided an allowance has been made for manufacturing and dimensional tolerances, corrosion, chemical reactions, neutron spectra, and uncertainties in the neutron cross-sections. 5.4.5.2 Methods of Calculation Experimental Data

        ~Fl+nentat da-ta-are-AOH.peci fie -enough-to-aUoweval uati on of.'. operal iens peFfeA-nee i A-t-tte A-GP- The genertc Aalttre-ef-t-he--e~e1imental data does not address the variables present in the different operations However, Experimental data are used for validation of the computer code (e.-g, KENO V.a) used to perform the calculations needed to support the development ofNCSEs.

The experimental data used are discussed in the code validation report (Reference ++ 14). Handbooks and Standards Handbooks and standards {e.g., ANSI/ANS-8.1-2014) are also used in some cases when simple systems are being evaluated. Handbooks and standards used for ACP operations are nationally recognized throughout the NCS industry as high_quality analyses that have been confirmed through many years of use or based on experimental data. Most of the operations performed in the ACP are too complicated to be adequately addressed by data in a handbook/standard. When isolated operations are performed with small amounts of fissile material, referencing handbooks/standards is useful to support conclusions in the NCSE. Examples of the handbooks used include, but are not limited to, ARH-600, Criticality Handbook and LA-10860-MS, Critical Dimensions of Systems Containing 235 U, 239Pu, and 233 U. Other handbooks are held to similar criteria for excellence, industry acceptance, and quality of data to be used at the ACP without further verification calculations. 5-19

License Applicationfor the American Centrifuge Plant Proposed Change 2020 Because handbooks and standards tend to give minimum critical or maximum subcritical values, use of these values for criticality controls is not appropriate to meet the double contingency principle. Instead, these values are reduced such that subcriticality can be demonstrated under normal and credible abnormal conditions. Hand Calculations Applicable methods for evaluating single units include Modified Two Group Diffusion Equation (i .e., Critical Equation), Buckling Conversion, and Comparative Analysis.

• Modified Two Group Diffusion Equation - This method is applicable to, and most widely used for, solution systems.
• Buckling Conversion - The method of buckling conversion or shape conversion is applicable to all materials.
• Comparative Analysis - This method involves direct companson of the system configurations to subcritical data from NCS handbooks.

Applicable methods for evaluating arrays include the Solid Angle Method and the Surface Density Method using unit shape factor.

• Solid Angle Method - This method is applicable to solution systems. It is not useful if reflection is more effective than a thick water reflector located at the array boundary .

The conditions that must be satisfied in order to successfully apply the solid angle method are (1) k effecti ve (kerr) ofany unreflected unit does not exceed 0.80; (2) each unit is subcritical when completely reflected by water; (3) the minimum surface-to-surface separation between units is 0.3 meters; and (4) the allowed solid angle does not exceed 6 steradians.

• Surface Density Method using unit shape factor - This method can be used as an approximation for large arrays of identical units containing solutions and metals. This method determines the spacing and mass of units independent of the number of units.

An important feature of the Surface Density Method is that it is equally applicable to more irregular geometries. When hand calculations are used, the specific methodology employed will be as described in "Nttct ear {-'-Fi ltfl itt y Safety" by R--A--Knet{ nH~Finn Nuclear So6et y-, l 99 +-a A<l-sub-j ec+to-a tot a i sy,;te11Heatfwty-of0-9Sft1r atkred+eie1:)l'f-1tor+l-l-ftk.vents-based on industry-accepted methods (e.g., areal density, solid angle technique, etc.), subject to the limitations of those methods. Computer Calculations For those cases- where adequate references are not avai !able, NCS computational analyses are 5-20

License Application f or the American Centrifuge Plant Propo ed Change 2020 performed, which involve the calculation of kerr, may be used to determine whether the system will be subcritical under both normal and credible abnormal process conditions. Computer codes that simulate the behavior of neutrons in a process system or that solve the Boltzmann transport equation are used. Computer calculations ofketr provide a method to relate analytical models of specific system configurations to experimental data derived from critical experiments. A critical experiment is defined as a system that is intentionally constructed to achieve a self-sustaining neutron chain reaction or criticality . Critical experiments that have specific, well-defined parametric values and are adequately documented are termed benchmark experiments. Computer codes are validated using experimental data from benchmark experiments that, ideally, have geometries and material compositions similar to the systems being modeled. See Appendix F of this license application for the computer code validation applicable to the HALED Demonstration Program . Validation of the computer code determines its calculational bias orunce11ainty as well as the effective margin -0f-suec-ri-ttca~i-ty-:- -+he-validation involves the model+n-g or benchmark criticai experiments over a rnnge of applicability Because -the ken value of a critical experi-ment is essentiaUy I, the bias of the code is taken to he the eeviation of the calculated values-of k...11 from unity 8tatistic-ai -analysis is employed -to e5t+mat~ the calculational-b1-as-,-whi-e-tHttclttdes the ttMertainty in the bias and u-ttc,er-taim-t-esdue to extensions of the area of-af>t}ttcaOH+ty, as well as the effective margin of subcriticality Un0e1iainty in the bias- is a measure of both lhe-precisi-on of the calculations and the accuracy -of the -ex-per-i-mental data The validation of the com-puter code specif1£-aHy--0eftttes-tlte ma'<-imum-acCJ*altle--k&'-ltSed lo determifl.e"5tlec-Fi-t-ica~~ly-- The margin of suhcri tic al ity used for the plant results i-n a-ken up-per safety Ii mit that -ensures that there is- a 95 percent conf~dence that 99 9 percent offuture-k.-n values less than this limit will be sttb-c--+ttical A mitttmum-ma~riticality of 0.02 in-k..a--f.s.ttsed---te-estahlish the acceptance eri leri a (i e , upper -safoty-t-i-1t1+t'j for criticality calculat.f on- for abnorntal-OA4tiens-at 5 percent n ~u enrichment and below Above 5 percent ~u enrichment, a mini-mum margin of suhcriticality of 0 05 in ken- is used Also, for normal case calculatK)ns supporting processes that are flot under medef.a.lion control, a n+ini+1tum tlH.lfgtRof.subcriticality of0.05 in ke4i+s-usea -Ab-oormal condili-en:s afe changes lo a conHoHed-parameter that result in a violat~-e.f-t~limit on that parameter. 17or example, in an nperation that relies on maintaining spacing betweefl fissile units, an error that results in the unitsbcing closer than the limit would represent an ab-normal condition Sirnilarly, operations Htat re+y-en-ntederation c-<.t11lrnl-Of--L...l.¥" *.vould be in an abnorrnal-c-Ondi-tion when the moderaliet1 cOAt-rol-was 1-0st--atta-epei:atioltS-t-hat rely on control orn~umass would be in an aooormal conditio>> when the mass ttmit was violated The upper~et-y-l-ttt1i-t---va-Ft-esw t-h the c-0mpu-ter syslem, oodes,ross sections, and-mateFi--ak t+sed-i-n-th e val ida tieft-ThecalculatiHn <>f k...n is accorn~~ished by the use ofc-0mpu-ter-t.'00es-that utH~zeMonteCado lei.~~ermine-k...u of a system Computer models ref)resen-ting the geomet1'tal-eeaf.i--gurntion and mater1al {'-Ornpesi-t-Hms---OHhe-system~eveloped for use within-+he code The development of -appropriate models must account for or conservat*vely hoona both- flOFmal and credihle abnormal process conditions-. 5-2 1

License Application for the American Centrifuge Plant Proposed Change 2020 When NCS is based on computer code calculations of kef1, controls and limits-areestabtished t-o enSt1retltat t-tte m-a-,-imtttlt-k,.woomplies v.tt-h--the--ftf3plicabl e code validation-fer the type of system 0e+>>g evaluated f.Bt-e*afltf}le,NG-8-ret-ated+RGFS developed during initial li-eense-apl')lteation were developed using reactivity cakulations performed on personal computer<; wnning the Microsoft Windows XP operating system an<l validated as described in Reference 11 -GeneraHy,-these calculations were performed with an upper safety limit of 0.955 up toS percenF2~U enrichmenl;- hov,*ever, specific cases may use a higher or lower limit based on equations from Table 14 of Reference l 1 Above 5 percent ~Uenrichment, a margin of-subcriticality of 0.05 will be applied to calculations performed using the personal computers described above with-a re ulting upper safety J.i.mi+ef O 925 Reac--t-i-vity calewations, pet+ermed-afteH-Rtlial license application,oom-p-t-y--w-i-th-the rode validalien--fer-t.Jte-s-peet+ic system used !o-perferm the calculation Sc-oping and analysis calculations may be performed utilizing vari<>US unvalidated computer codes, however, ootttpttter-cakulations of-k~'-ttSed as-Hte basi-s-for NCS evaluatiottS--are-onfirmed ey, -er -rer.forrne-d ttStng, configuration co11-treHed-ooes- and cross section hbraries-fo1-wltteh documented vahdations are performed with at least the same degree of conservati-sm as -that presented ~n Reference 11 an<l are in accordance with ANSI/ANS-8 1- 1998 Calculations are pet-.fem-l-ea--ttsi ng -Htttter+-al'> oko-1tst-futi-fH1----a-n<l --et-her--p-ar-anteters--etlSistenl Vv it h the area of a-pplicability describedbythe relevant validation report The area of applicability used by Referette I I covers enrichments from 2 percent to 30 percent ~u enrichment with moderation levels from an H/~.$lJ of8to 1,438 with an average energy group of 151 7 to220 using the 238--group ENDl<'./U--V rnss-sec+i-en hbrnry Moderat-i-ng- -maleftal +ro1t1 -Referenc-e--++ it1cltt-de--wate+ -aoo- pafftffin-and reAeclors range from bare sy-5-t-etltS-t-e-retlection \\.il-tt-water, steel, paraffin;--j.IBl-yet-hylene. c-onc1ete;- and lead Other materials induded in the area of applicability-from Reference 11 are stainless steel, zirconium, aluminum, fluorine, and o,ygen E *tensi-0ns--ro-tlte-area of apJ->>-i--ability - a ~--when using lec-hniqttes described in Nl JRE(i/('R--6698 When materials of construction are used that are not represented in the area of applicabih-ty, the NC'S engineer has -several -options available to address that s-ituati<m. First, the speci fie material cafl-ee ~eft-oul-of-the-model Second, a differern m-ateriak-a-n be substituted that-~ within the-AOA aoo- pttwtdes---a--si-milar (or m-ere atmservative) amount of neutren-m-edeffiti-en, multi-pli-cation, or reflection Third, the material can be included based on a revieW{}ftts neutron cross sections that conclude no significant imp-act can occur from that material f<ourth, the material can be--i-ne-1-ueed-but-withan-adJustmenl i-A~l5tty--so thal-a-tty-tn1-koov,n effea-is mini-m-i-r.ed- hflH~ t-he m-ateri-al c-a-n b-e-i-H-l-uded-wi-t-lt-a-red-uai{1n to the upper safely li-m-i-H-e-at,~,}unt--fur-tlte--aed-i--l+ettal-unce11ainty Lastly, additional benchmark experiments can be-added to the validation to specifically include the-material The NRC will be uoti-f~+A the-event anexten. ion-to the-area of applicability ,v-i-11-n-et adeq-uately encomf*l-ss-t+1e parameters--ef-i-nterest for a spec-i-fie--aleul-at-ioo-a-nd a revisien-te Referenc-e--l~ahl-i-sh--a-new-area of appl icabi Ii ty Prior to im pl ementi ng changes to J}rocesses based on calculations requi ri ng-e,tension te the vali{Jated--area-ofappltcaotti-ty as determined in the validati-en report, -N-RC review-attd~shaH beol"\ta-in~ l'-lte-n~quest for-NR{'-rw~ and approval ..Jtal-l. include adesc-rip#-en of the change, tl1e reason that such a change is needed, an<l the method used to e'{teoo-the area of applicability 5-22

License Application for the American Centrifage Plant Proposed Change 2020 The methodology used in a validation report involves statistical analysis to determine the bias and bias uncertainty for the critical experiments 1nduded in the validation Guidance from NU REG/CR 6698, ( ;:,idefor l 'a/.tdw-im,-Hj-N-iu:lear ( 'ritu*altty Safety ( 'akw!ttllflHRI--A4elhodoH-JK_r,+s tts-ed-te perform-the validatH:)tl-+Ae upper safely limit is computed by subtracting the absolute val-ue of the bias, the bias uncertainty, and the minimum margin of subcriticality from unity -Positive bias is not credited The exact statistical technique used to obtain the bias and bias uncertainty depends ofl--t--he---s.recific validation report The techniques used in Reference 11 included-the 10 .ver tolerance 1 limit or the lower tolerance band for normally distributed data and a non parametric technique for non-normally distribHted data. The computer codesfttld cross sections used in performing k..Aceal-etttations are mainta+Hed-tn ac-00rdance with-a configurnti-On-ooatH:W-fttan Quarterly, or prior lo-use. en~ the follov.ittg-ts performed a bit-by-bit comparison of the production version of the software (executable modules and data libraries) versus an archived production version, or a comparison of the output from all validation cases ve'1s-afl-1+veaootf*.-1t-of all validation cases from the original valida~erfermed wlteA the pr-oduc-t1-011 version-was -i-nst-aUee- -te-ett5ttfe-tm-4a+i-ges-tn the cal-uktted-k..tt-for-t-he validation cases. f:ttattges-to lhe hardware--OF-softwa1-eare evalualed in accorda-nce-witl+ IO CFR 70 72 change Feql:l+Fements. Some changes ar~d-t:o result in-changes lo the cal-ttl-attetttll-a~Fi-thm and will require a new validation . Such changes include revisions to the software used to calculate reactivity, updates to the cross section libraries, changes to the operating system kernel , changes to the central precessingtttt it,-er-eha-nges-to the1netlterboani---Other-1ta nges are flOt: ~oo~-to +-esu+t-it1-h-anges 1B t-hecalculali-On-a+-algoR+htt1-nnJ-wi+l-t=eJlti-re-on-ly that the-vamiat-tet1 cases be re run and-effii*red to the original results Such changes include increasing the available RAM, changi-ng a hard drive, graphics card, network interface card, or other pe6pheral ln the Microsoft Windows environment, J}eftOOic-clttmges-t-O-emfH:}flen-l5--e~eperat+n-g-syst-em are cemmon as Mi-reseft issues upeates-er patc+1es to the platfonn- -Also, mst-aJl-ati-On -aoo modification of software not l+sed-t-o-ealetttate reactivity will be performed to support day-lo-day business needs These minor changes are not expected to impact any reactivity calculations, but to ensure this, a verification of the >validation cases- .'vill be perfoffiled at least quarterly as described above:- 1 The System Administrator, an NCS engineer, is resp<msible for controlling access to the software 5-23

license Application for the A merican Centrifuge Plant Proposed Change 2020 5.5 References

1. ANSI/ ANS-8 .1-+99&,2014 Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors

2. ANSI/ANS-8 .3-1997, Criticality Accident Alarm System

3. ANSI/ ANS-8.19-2014+9%, Administrative Practices for Nuclear Criticality Safety

4. ANSI/ANS-8 .20-1991, American National Standard for Nuclear Criticality Safety Training

_5._ ANSI/ANS-8 .21-1995, Use ofFixed Neutron Absorbers in Nuclear F acililies Outside Reactors

6. ANSI/ ANS-8.23 -2007, Nuclear Criticality Accident Emergencv Planning and Response

~ 7. ANSI/ANS-8 .24-2017, Validation ofNeutron Tramport Methods for Nuclear Criticality Safety 6 L ARH-600, Criticality Handbook, Volumes I, II, and III, Atlantic Richfield Hanford Co. Report (1968) 7 L LA-3605-0003 , Integrated Safety Analysis Summa,y for the American Centrifuge Plan( &~ LA-I 0860-MS, Criticality Dimensions of Systems Containing 235 U, 239 Pu, and 233 U, 1986 Revision 9 .lL_NRC Regulatory Guide 3.71 , Revision ,10, Nuclear Criticality Safety Standards for Fuels and Material Facilities, Revision 3 IO li.:.__NUREG-1513, Integrated Safety Analysis Guidance Document ~ l.L_NUREG-15 20, Standard Review P Ian for the-Re v+ti.+t-f-fa-1-lffn-!'ft! -r1p11ltcali0Hf+F-ff fuel Cycle Facilities+* License Applications. Revision 2 12 H,_ WSM\j-CRT-03-0093, 1l111ted Stolt!.., J,11nd1111e111 ( 'mpom/1011 (( !SU') I'< '-S< ',1/I, -1.-la ral1tllH10H ((1}, Revi-si-01t-2-,--Nevem-ber 2(~EE-3101-0013, NCS Code Vcllidation ofSCALE 6.2.3 and Cross Section Set v7-252 for keff Calculations, Rev. 0, December 2019 -l J NURbG-/('-R-6698, ( ;uule.for ~ a/1-dot1011 <!f NHdear 0-*11t-ca/1~-v S<(fl!ty ( 'alrnla!Hmtfl Mt!--ll1<-1tlolo~y-, January 2GO I .li:._NCS-C ALC-04-00 I, Storaxe r?f J If, oil A-hxtul't's III Saft' i 'ol11111t* ( '-<mlt-1i1lt!n, September 2-00-5 DAC-3101 -0006, Safe Mass Study for UF-1 and Oil, February 2020

16. "International Handbook of Evaluated Criticality Safety Benchmark Experiments,"

NENNSC/DOC (95) (03), Nuclear Energy Agency Science Committee, Organization for Economic Co-Operation and Development, July 2018 Edition. 5-24

License Application for the American Centrifuge Plant Proposed Change 2020 Jordan, W.C., Landers, N.F., Petrie, L.M., "Validation of KENO Va Comparison with Critical Experiments," ORNL/CSD/TM-238, Martin Marietta Energy Systems, Contract Number DE-AC05-840R21400, December 1986. lL. 14. Blank Page 5-25

License Application for the American Centrifuge Plant Proposed Change 2020 r~h

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t5~! ll h\.l. Figure 1.1-16 Machine Cooling Water System Flow Schematic (For I-IALE U Demonstration, a molecular pwnp \\ill be used in plal'c of the diffusion pwnp and docs not require MCW) 1-55

license Application for the American Centrifuge Plant Proposed Change 2020 6.0 CHEMICAL PROCESS SAFETY The American Centrifuge Plant (ACP) operations require limited quantities of radioactive, hazardous, and toxic chemicals for maintenance and production activities that are performed in support of the basic uranium enrichment process. For the ACP Commercial Plant, +these chemicals are discussed in the Integrated Safety Analysis (ISA) Summary for the American Centrifuge Plant, Chapters 5.0 and 6.0, as well as their appendices. For the ACP HALEU Demonstration, these chemicals are discussed in Addendum 1 of the ISA Summary for the American Centrifuge Plant HALEU - Demonstration, Chapters 5.0 and 6.0, as well as their appendices. Pursuant to 10 Code of Federal Regulations (CFR) 70.62, the plant safety program includes process safety information to address hazardous materials. This chapter summarizes the chemical process safety program for the ACP, the integration of chemical safety with uranium enrichment operations, and the management systems used by the plant for chemical safety. A description of the plant and uranium enrichment process is provided in Section 1.1 and a description of the reservation is provided in Section 1.3 of this license application. The uranium hexafluoride (UF6) inventory that is integral to enrichment is addressed in the ISA Summary. The risks associated with UF6 and its airborne release reaction products, hydrogen fluoride (HF) and uranyl fluoride (U02F2), are discussed in the ISA Summary, Sections 5.2.1, 5.2.1.1, 5.2.1.2, 6.1.1 , 6.1.1.1, 6.1.1.2, 6.1.1.3, and 6.1.1.4; and Appendix D, Sections D. l through D.16 for the ACP Commercial Plant. The risks associated with UF6 and its airborne release reaction products, HF and U02F2, are discussed in Addendum 1 of the ISA Summary for the American Centrifuge Plant HALEU - Demonstration, Sections 5. L 6.1.1.1, 6.1.1.2, 6.1.1.3, 6.1.1.4, 6.1.1 .6, and 6.1.1.7; and Appendix D, for the HALEU Demonstration . The ACP chemical process safety program is implemented through written procedures. Records for process safety compliance are retained in accordance with records management and document control (RMDC) requirements described in Section 11.7 of this license application. The Radiation Protection Manager/Supervisor is responsible for the plant chemical process safety program . Chemical safety incorporates engineering and administrative controls to manage risk. Prevention is the preferred approach. Workers use personal protective equipment (PPE) when it is specified in procedures. 6.1 Process Chemical Risk and Accident Sequences Chemical inventories at the ACP are maintained below the threshold quantities set forth in the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Standard (29 CFR 1910.119) and the Environmental Protection Agency (EPA) Risk Management Program (RMP) Standard (40 CFR Part 68); therefore, these regulations do not apply to the ACP. Chemical safety consists of the integration of environmental, safety, and health management systems to address chemical hazards. Chemical safety controls are designed to prevent the adverse effects of toxic materials used in the uranium enrichment process to workers, 6-1

License Application for the American Centrifuge Plant Prop osed Change 2020 the public, and the environment. To achieve thi obj ecti ve, afety analy e and Indu trial Hygiene and Safety (IHS) programs are utilized. Chemical safety controls are limited to non-radiological materials. Radiological materials are addressed throughout the ISA Summary for the ACP Commercial Plant and Addendum 1 of the ISA Summary for the American Centrifuge Plant HALEU - Demonstration and in Chapter 4 .0 of this license application. Chemical process safety is addressed in the ISA. The ISA Summary and Addendum l of the ISA Summary for the American Centrifuge Plant HALEU - Demonstration, Chapter 6.0 identifies potential accident sequences and Chapter 7.0 designates selected controls (i .e., items relied on for safety [IROFS]) to either prevent such accidents or mitigate their consequences to an acceptable level. Chemicals with significant radiological impact are limited to UF6 and its release products, HF and D02F2, as indicated in Sections 5.1 and 5.2 of the ISA Summary and Addendum 1 of the ISA Summary for the American Centrifuge Plant HALEU - Demonstration. Other chemical hazards, which are not considered to have any radiological impact, are listed in Appendix B of the ISA Summary and Addendum 1 of the ISA Summary for the American Centrifuge Plant HALEU - Demonstration. Techniques and assumptions for estimating airborne concentrations and predicting toxic footprints from chemical releases are presented in Appendix D of the ISA Summary and Addendum 1 of the ISA Summary for the American Centrifuge Plant HALED - Demonstration, which also presents source terms and vapor dispersion models used to calculate airborne concentrations of UF6 and its release products. The American Industrial Hygiene Association (AIHA) Emergency Response Planning Guidelines (ERPGs) have been selected as the chemical response standard for the ACP . The ERPGs provide airborne concentration limits to effectively protect individuals against toxic exposure to hazardous chemicals. These guidelines are discussed in Appendi x A of the ISA Summary and Addendum 1 of the ISA Summary for the American Centrifuge Plant HALED - Demonstration. Management measures are established to provide reasonable assurance of the avai lability and reliability of IROFS. The ISA includes consideration of the toxicity of uranium, radiological hazards, and chemical hazards that may impact radiological safety. The details of the analysis are provided in the ISA Summary. 6.2 Items Relied on fo r Safety and Management Measures Safety in normal operations is maintained through implementation of the defense-in-depth engineering design philosophy . The ISA Summary and Addendum 1 of the ISA Summary for the American Centrifuge Plant HALED - Demonstration describes the basis for providing successive levels of protection such that health and safety of employees and the public is not wholly dependent upon any single element of the design, construction, maintenance or operation of the facility. The schemes employed to ensure safe operation of the ACP include management measures that provide for the reliability of IROFS. These measures include configuration management (CM), maintenance, procedures, training, surveillance, and testing. Management measures are described in Chapter 11.0 of this license application. 6-2

License Application for the American Centrifuge Plant Proposed Change 2020 6.2. 1 Items Relied on for Safety Chemical process safety controls that prevent accidents or mitigate their consequences are identified in Section 7.2 of the ISA Summary and Addendum l of the ISA Summary for the American Centrifuge Plant HALEU - Demonstration . These controls are designated as IROFS and address the chemical hazards that may impact radiological safety. Tables 6.1 -1, 6.1-2, 6.1 -3, and 6.1-4 of the ISA Summary and Addendum 1 of the ISA Summary for the American Centrifuge Plant HALEU - Demonstration, identify both radiological and non-radiological accident sequences with regard to performance criteria. These are also discussed in Section 7.3 of the ISA Summary and Addendum l of the ISA Summary for the American Centrifuge Plant HALEU - Demonstration . 6.2.2 Management Measures Each of the management measures that helps ensure the IROFS are available and reliable, are bri efly described in the following sections. 6.2.2.1 Procedures 6.2.2.1.1 Operating Procedures Procedures are prepared in accordance with the requirements of a formal procedure system. The Procedures Program is described in Section 11.4 of this license application. 6.2.2.1.2 Safety and Health Program Procedures Centrus Energy Corp., with approval of the DOE, assigned the sublease for the space for the ACP (including the HALEU Demonstration) to the Licensee, ACO. The Licensee subleases,. from tlte-lJ.rn-1.ed States f:'+ltteltrnettl----tefperatiBHCentrus Energy Corp., certain support buildings/facilities on the DOE reservation. The ACP and the DOE have their own chemical safety programs and share information regarding hazardous chemicals used by each entity. The DOE environmental restoration contractors and sub-contractors may also be present on the reservation. The DOE provides information regarding any hazardous chemicals used by these "third-parties" that could impact ACP operations. Third-party chemicals are covered by a shared site agreement with DOE and reviewed in accordance with procedures. IHS programs used for chemical safety and implemented by safety and health program procedures include:

• Lockout/Tagout
• Hazard Communication
• Confined Space Entry
• Safety and Health Work Permit 6-3

License Application for the American Centrifuge Plant Proposed Change 2020

• Hot Work Permit
• Personal Protective Equipment
• Signs/Labeling/Tagging
• Safety Training These safety and health programs apply to chemical safety as described in the program implementation documents.

6.2.2.2 Training The Training and Procedures Manager has overall responsibility for employee training. ACP operators, maintenance personnel, management, and emergency response personnel have prerequisite and periodic training requirements that are necessary for initial and continued job qualification. Personnel who operate, maintain, manage, handle, and have emergency response duties for chemicals are adequately trained for the particular chemical system or related activity. This training supplements the plant Training Program described in Section 11 .3 of this license application and occurs at the job-specific level. Contractor (typically construction, maintenance, and service) personnel receive access training and plant-specific safety training prior to starting work. The contractor or the contractor-designated Safety and Health Officer has the contractual responsibility for internal contractor employee training. The Licensee also approves the contractor's Safety and Health Plan. The Site Technical Representative is the liaison between the contractor and the Licensee. If construction activities interface with chemical systems, ACP representatives ensure appropriate job review, training, and guidance is provided. 6.2.2.3 Maintenance and Inspection Maintenance and inspection programs are summarized below and described in Sections 11 .1 and 11.2 of this license appli cation, and in the Quality Assurance Program Description (QAPD) for the American Centrifuge Plant. Engineering develops maintenance and inspection requirements and criteria for chemical systems in conjunction with the specific plant maintenance organization, manufacturer' s recommendations, and ISA Summary and Addendum 1 of the ISA Summary for the American Centrifuge Plant HALEU - Demonstration. These chemical safety requirements are based on the functions of IROFS identified in the ISA Summary, Addendum I of the ISA Summary for the American Centrifuge Plant HALEU - Demonstration, and manufacturer' s recommendations for a particular chemical component/system . 6-4

License Application for the American Centrifuge Plant Proposed Change 2020 6.2.2.3.1 Calibration and Inspection Specific calib ration and inspection requirements are based on operating characteristics, past operating experience, system operating environments, and manufacturer's recommendations. Maintenance of chemical systems is performed in accordance with the plant maintenance programs. These plant programs are based upon calibration and inspection requirements from operational experience and characteristics of the system. 6.2.2.3.2 Maintenance Work Packages Maintenance work packages are prepared to provide the necessary technical and safety guidance for maintenance activities as described in Section 11.2 of this li cense application. These work packages are applicable to chemical systems and equipment. Supporting maintenance procedures are subject to the requirements of the Procedures Program described in Section 11.4 of this license application. 6.2.2.3.3 Preventive Maintenance and Quality Considerations Manufacturers' recommendations are used as guides for preventive maintenance on specific chemical systems and equipment. If operational experiences or system characteristics indicate a need for a different preventive maintenance schedule, the preventive maintenance baseline can be changed after appropriate review. ACP personnel perform inspection and testing to fulfill requirements for quality in accordance with the CM Program, which is described in Section 11.1 of this license application. Independent overview of maintenance act1v1t1es on chemical system hardware and requirements are addressed by the QAPD and CM Program, as applicable. These independent overview programs include:

• Procurement Quality Requirements
• Construction Inspection
• Testing and Pre-Operational Inspection
• Pressure Vessel Inspection
• Crane Inspection
• Pre-Operational Safety Review and Pre Start-up Safety Review Programs
• Plant Safety Review Committee (PSRC)

The pre-operational safety review process is conducted in accordance with program implementing procedures. The scope of the safety review is determined by the PSRC which considers the specific issue and system being reviewed and the potential safety concerns present. 6-5

License Application for the American Centrifuge Plant Proposed Change 2020 Deficiencies associated with maintenance activities are dispositioned in accordance with the QAPD and the Corrective Action Program, as described in Section 11.6 of this license application. 6-6

License Application for the A merican Centrifuge Plant Proposed Change 2020 6.2.2.4 Configuration Management The CM Program is described in Section 11 .1 of this license application . Director, Engineering+echnical Services, as the design authority for the ACP and HALEU Demonstration, administers the CM Program . The CM Program includes an organizational structure and administrative processes and controls to ensure that accurate, current design documentation is maintained that matches the building physical configuration. 6.2.2.5 Emergency Planning Emergency Management is described in Chapter 8.0 of this license application. The Emergency Management Plan for the American Centrifuge PlantACP outlines the roles and responsibilities of personnel during an emergency and describes the emergency response measures, including on-site and off-site protective actions. Chapter 8.0 Section 8.1 details that No Emergency Plan as discussed under 10 Code of Federal Regulations (CFR) 70.22(i) is needed for the HALEU Demonstration Program . Personnel who have emergency response assignments or duties associated with chemical safety are adequately trained to respond to chemical and operational upsets per 29 CFR 1910.120(q) requirements. Operators, in compliance with the plant " See and Flee" policy, are not expected to participate in emergency response activities for chemical releases. The policy specifies that employees promptly move to a safe location, away from the immediate release area. Mitigating actions, as described by procedure, may be performed during evacuation from the immediate release area if they do not hinder safe egress. Personnel outside the immediate release area may perform mitigating actions, as described by procedure, prior to evacuation. If plant procedures direct an employee response to a minor spill , an employee can implement the plant response procedure after "See and Flee" requirements have been accomplished and the area may be reentered . 6.2.2.6 Incident Investigation Identification, reporting, and incident investigation, described in Section 11.6 of this license application, are conducted in accordance with plant procedures. The level of investigation is based upon severity and significance of the event, as well as the regulatory requirements involved. Unacceptable performance deficiencies are addressed in accordance with the ACP Corrective Action Program . Documentation is retained in accordance with RMDC requirements described in Section 11.7 of this license application. Occupational injury and illness investigations related to chemical safety are part of the IHS programs. Investigations are conducted in accordance with OSHA requirements. 6-7

License Application for the American Centrifuge Plant Proposed Change 2020 6.2.2. 7 Audits and Inspections Formal audit responsibilities are assigned to the Piketon Quality Assurance Manager. In addition, internal organizations have monitoring programs, assessments, and reviews as required by program implementation procedures. The Audit and Assessment Program is described in Section 11 .5 of this license application and includes chemical safety. 6.2.2.8 Quality Assurance The QAPD describes the programmatic requirements that apply to Quality Level (QL)-1 and QL-2 items. These quality assurance elements and requirements apply to chemical safety items classified as QL-1 or QL-2 in a graded approach, as described in the QAPD. Additional discussion regarding the ACP graded approach to quality assurance is provided in Chapter 11.0 of the License Application. 6.2.2.9 Human Factors Human factors design responsibility for plant and system design in the ACP is assigned to engineering, with specific technical assistance from Industrial Safety personnel. Human factors reviews address the interface of people with processes and its impact on system operation. The Human Factors Engineering program is described in Section 2.6 of the ISA Summary. 6.2.2.10 Detection and Monitoring Chemicals with significant radiological impact such as UF6, HF, and U02F2 that are processed in the various ACP facilities are provided with detection and monitoring systems to identify chemical releases as appropriate to the release event. Non-radiological chemicals that do not have significant radiological impact are maintained below PSM/RMP threshold quantities and do not require detection and monitoring. 6.2.2.11 Chemical Safety Control Strategy The chemical safety control strategy first requires that the chemicals used be identified and the listing of chemicals be kept current. Then the chemicals are reviewed for potential hazards. In order of decreasing risk and decreasing significance, the chemical hazards are addressed within the ISA Summary, Addendum 1 of the ISA Summary for the American Centrifuge Plant HALEU - Demonstration, and by the applicable IHS programs. 6.2.2.11.1 Identification and Inventory Control Three processes are used to identify hazardous or toxic chemicals to be evaluated/controlled and to ensure that inventories are maintained below PSM/RMP threshold quantities. Material Safety Data Sheets/Safety Data Sheets (MSDSs/SDSs) are maintained in a central location in the ACP and are available at all times to plant employees, including emergency response and fire department personnel from on- and off-site. The first process identifies and inventories chemicals used at the ACP. This process ensures that chemicals used at the plant are 6-8

License Application f or the A merican Centrifuge Plant Proposed Change 2020 appropriately addressed for safety. The process includes:

• Purchase requisition reviews;
• A listing of chemicals used;
• A centrally-located MSDS/SDS library, which is maintained and routinely updated by Industrial Hygiene; and
• Identification of new chemicals for the review process .

The second process is the formal request for engineering services required for modifications to existing systems. The request process provides a mechanism that identifies new or revised usages of chemicals, chemical processes, and/or associated possible logistics that require engineering involvement. A request for engineering services may not be required unless physical modifications or updated engineering evaluations are needed. If changes to hazardous chemical inventories or locations exist as a result of a request for a new, modified, or decommissioned building, process or storage location, an appropriate chemical safety review is applied to address regulatory requirements. Physical changes to the plant, including inventory limits and changes of location for hazardous chemicals, are evaluated in accordance with the requirements of IO CFR 70.72. The third process is associated with contractors on-site. When work is to be performed by contractors, a review of the contractors' Safety and Health Plan is conducted to identify the presence of hazardous and toxic materials to be brought onsite by the contractor. The contractor provides the latest revision of MSDSs/SDSs for these chemicals. Hard copies are maintained by the contractor at the job site, by Industrial Hygiene in a central location, and by appropriate Facility Custodians. 6.2.2.11.2 Chemicals Addressed By Integrated Safety Analysis Summary The ISA addresses risks associated with UF6 and its airborne release reaction products, HF and U02F2. Chapter 6.0 of the ISA Summary and Addendum 1 of the ISA Summary for the American Centrifuge Plant HALEU - provideDemonstration provides an evaluation of accidents that involve the release of UF6, including both radiological and toxicological hazards. The HF, which evolves from a UF6 relea e, is one of the toxicological hazards. The analyses identify IROFS . Appendi x B of the ISA Summary and Addendum 1 of the ISA Summary for the American Centrifuge Plant HALEU - Demonstration identifi eys other chemicals and typical industrial materials (e.g ., acetone, sol vents, acids, fuels, and oils) that are used in the ACP (including HALEU Demonstration) for assembl y and maintenance acti vities. 6-9

license Application fo r the A merican Centrifuge Plant Proposed Change 2020 6.2.2.11.3 Chemicals Addressed by Process Safety Management and the Risk Management Program Chemical quantities are maintained below Process Safety Management (PSM}/Risk Management Program (RMP} threshold quantities as described in Sections 6.2.2.11 .1 and 6.3 of this license application. 6.2.2.11 .4 Industrial Hygiene and Safety Program Managed Chemicals Hazardous and toxic chemicals are effectively managed using ms programs. To address these hazards, the IHS program provides the necessary protective barriers and controls that enable safe use of these chemicals in accordance with OSHA requirements (29 CFR Part 1910). Commercial chemicals have varying toxicity and hazardous ranges and categories. Because chemicals can be used within the facilities for various purposes, the ms program applications to chemical safety are comprehensive and are based on industry accepted standards and regulatory requirements for controlling occupational exposures. To address the potential exposure risks associated with ms program managed chemicals, the ACP uses chemical review programs, program procedures, and MSDSs/SDSs. Implementation of these IHS programs provides employee protection from hazardous chemicals during daily operations and emergency response. 6.2.2.12 Multi-Occupancy of the Department of Energy Reservation The Licensee subleases, from the--Untted-States Enrichmem-{'orporation Centrus Energy

     ., certain support buildings/facilities on the DOE reservation. The ACP and the gaseous diffusion plant are separate entities for purposes of chemical safety . Each has its own chemical safety programs and shares information regarding hazardous chemicals used by the other. The DOE environmental restoration contractors and sub-contractors use the remaining reservation sectors. The DOE provides information regarding any hazardous chemicals used by these "third-parties" that could impact ACP operations. Third-party chemicals are covered by a shared site agreement and reviewed in accordance with procedures.

6.3 Requirements for New Buildings/Facilities or New Processes at Existing Facilities System design requirements adhere to the 10 CFR 70.64 Baseline Design Criteria for chemical protection in new ACP buildings/facilities. Revision or modification to an existing chemical system is initiated via a request for engineering services that initiates the design process and includes a 10 CFR 70.72 review. For systems that become subject to the requirements of the PSM/RMP program, a pre-startup safety review is performed based on changes to the process safety information . The pre-startup safety review is an independent review to address the readiness of the system hardware, associated hazard controls, personnel (including required training), procedures, and process safety information. Records of chemical releases and documentation relating to chemical process safety are retained in accordance with Records Management and 6-10

License Application for the American Centrifuge Plant Proposed Change 2020 Document Control (RMDC) requirements described in Section 11 .7.1.5 of this License Application to ensure compliance with NRC' s chemical process safety requirements. 6.4 References

1. 29 CFR Part 1910, Occupational Safety and Health Standards

2. 29 CFR 1910.1 19, Process Safety Management ofHighly Hazardous Chemicals

3. 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response

4. 40 CFR Part 68, Chemical Accident Prevention Provisions

5. LA-3605-0003, Integrated Safety Analysis Summary for the American Centrifuge Plant

6. NR-3605-0003 , Quality Assurance Program Description for the American Centrifuge Plant

7. NRC Information Notice No. 88-100: Memorandum of Understanding between NRC and OSHA Relating to NRC-Licensed Facilities (53 Federal Register 43950, October 31 ,

1988), December 23, 1988

8. NUREG-1 51 3, Integrated Safety Analysis Guidance Document

9. NUREG-1520, Standard Review Plan for the N.ei*iew <!/ a fxeme AJ>J>lin,tion fin

• a Fuel Cycle 1,*acili~FFacilities License Applications, Revision 2

   ~ NUREG-1601 , Chemical Process Safety at Fuel Cycle Facilities IO 11 . LA-3605-0003A, Addendum 1 of the ISA Summary for the American Centrifuge Plant HALEU - Demonstration 6-11

License Application for the American Centrifuge Plant Proposed Change 2020 Document Control (RMDC) requirements described in Section 11.7.1.5 of this License Application to ensure compliance with NRC' s chemical process safety requirements. 6.4 References I. 29 CFR Part 1910, Occupational Safety and Health Standards

2. 29 CFR 1910.119, Process Safety Management ofHighly Hazardous Chemicals

3. 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response

4. 40 CFR Part 68, Chemical Accident Prevention Provisions

5. LA-3605-0003, Integrated Safety Analysis Summary for the American Centrifuge Plant

6. NR-3605-0003 , Quality Assurance Program Description for the American Centrifuge Plant

7. NRC Information Notice No. 88-100: Memorandum of Understanding between NRC and OSHA Relating to NRC-Licensed Facilities (53 Federal Register 43950, October 31, 1988), December 23, 1988

8. NUREG-1513, Integrated Safety Analysis Guidance Document

9. NUREG-1520, Standard Review Plan f or the N.ePiew <la Uce11se AJ>plicalion for a Fuel Cycle h1e1/i1yFacililies U cense Applications, Revision 2 lQ,_NUREG-1601, Chemical Process Safety at Fuel Cycle Facilities IO 11 . LA-3605-0003A, Addendum J of the ISA Summary for the American Centrifuge Plant - HA LEU Demonstration 6-11

License Application for the A merican Centrifuge Plant Proposed Change 2020 7.0 FIRE SAFETY The American Centrifuge Plant (ACP), including the HALEU Demonstration has provisions to provide adequate protection against fire and explosions. This chapter provides descriptions of the Fire Safety Program and fire protection systems and equipment used to ensure employee and public health and safety from fires in the ACP. The Fire Safety Program is part of the safety program that is designed to meet the requirements established in 10 Code of Federal Regulations (CFR) 70.62(a). The Fire Safety Program complies with requirements established in 10 CFR 70.61 , 10 CFR 70.62, and 10 CFR 70.64; and the guidance provided in NUREG: 1520, Standard Review Plan for lhe RevieH of a

 -hiee-1-1se Application .for a Fuel Cycle /s'ucilityFacilities License Applications (Revision 2). The Fire Safety Program addresses fire safety requirements for the ACP.

The Fire Safety Program addresses requirements for ensuring the fire protection systems and fire services supporting the ACP are adequate and maintained properly. Fire services refer to emergency and fire response services, fire inspection services, and fire testing services. As discussed in Section 1.1.8 of this license application, ACO' s long-term goal is to resume commercial enrichment production consistent with market demand. The ACP design is modular, with the basic building block of enrichment capacity being a cascade of centrifuges. Modular deployment would accommodate market demand on a scalable, economical gradation. The Fire Safety Program will be implemented to support the modular deployment, such that the fire protection systems/services are in place when needed. The next phase of enrichment production includes the deployment of a cascade of centrifuges to demonstrate production of high-assay, low-enriched uranium (HALEU) fuel for advanced reactors. The primary building/facilities directly involved in HALEU Demonstration are the X-3001 Process Building, X-3012 Process Support Building, X-7725 Recycle/Assembly Building, X-7726 Centrifuge Training and Test Facility, and X-7727H Interplant Transfer Corridor. The Licensee will notify NRC well in advance of the transition into any future phases of ACP deployment. The ACP is comprised of buildings/facilities located on the U.S . Department of Energy' s (DOE) reservation in the former Gas Centrifuge Enrichment Plant (GCEP) buildings. Additional structures will be constructed to meet the specific needs of the ACP. Many of the buildings/facilities that comprise the ACP were designed and constructed in the 1970s and 1980s to meet the codes and standards applicable at those times. These . buildings/facilities have been analyzed for fire hazards, which are discussed further in Section 7.2 of thi s chapter. The fi re protection equipment, structural features, and fi re suppression systems are designed to detect, contain, and suppress fires . The major physical components of the fire protection system include fire detection, firewater supply system, pumps, sprinkler systems, fire alarms, and other firefighting equipment. The location and operating characteristics of these components are described in Section 7.3 of this chapter. Fire protection design provides for adequate protection against fires and explosions in accordance with the Baseline Design Criteria contained in 10 CFR 70.64(a) and the defense-in-depth requirements of 10 CFR 70.64(b). 7-1

License Application for the A merican Centrifuge Plant Proposed Change 2020 The Fire Safety Program with regard to building/facility, system, and equipment design, maintains the fire protection systems in existing buildings/facilities in accordance with the codes and standards that were applicable at the time of construction and installation. New buildings/facilities meet codes and standards applicable at the time of design. Modifications to existing buildings/facilities are evaluated relative to the safety benefit that could be achieved from applying current codes and standards. Justification for any deviations from the codes and standards of record are documented in writing and approved by the Authority Having Jurisdiction (AHJ). The Configuration Management Program as described in Section 11 .1 of this license application, identifies the applicable codes and standards via the system requirements documents for each building/facility. The Fire Hazard Analyses (FHA) also provide this information. National Fire Protection Association (NFPA) 801-2020G3-, Standard for Fire Protection for Facilities Handling Radioactive Materials, addresses fire protection requirements for buildings/ facilities handling radioactive materials and generally references other NFPA codes and standards dealing with each specific type of equipment or program. The daughter standards are written for general commercial facilities and may not be applicable to uranium enrichment facilities. The Fire Safety Program and the ACP were reviewed to determine applicability and level of compliance with NFPA 801 and applicable daughter standards. Some ACP buildings/facilities do not meet NFPA 801 and the applicable daughter standards because they were built or established under earlier versions or different codes and standards applicable at the time of construction and installation. The standards applicable to these ACP buildings/facilities will be documented during the baseline configuration assessment effort as described in Section I l .-l -of -thi%+i-e-ense appl ~c-ation . The Fire Safety Program consists of five parts to provide a defense-in-depth approach to reduce the likelihood of occurrence, consequences, and damage that results from fires. First, a number of management measures are in place to ensure the availability and reliability of the fire protection items relied on for safety (IROFS), prevent fires, and minimize the consequences and damage from fires . Second, FHAs have been performed to determine vulnerability of the ACP to fires. Third, the ACP design incorporates fire prevention and fire protection requirements. Fourth, process fire safety ensures that enrichment process hazards are properly identified and addressed to ensure the health and safety of the workforce and public. Fifth, fire protection equipment and emergency response personnel are in place to minimize the consequences and damage from fires . 7.1 Fire Safety Management Measures Fire Safety management measures are in place to ensure that IROFS are available and reliable. This is accomplished through the following, which are described in Chapter 11.0 of this license application.

• The Configuration Management Program ensures that the ACP facilities are controlled in accordance with the baseli ne configuration.
• The Maintenance Program ensures that IROFS equipment is maintained and tested to ensure their reliability and availability.

7-2

License Application for the A merican Centrifitge Plant Proposed Change 2020

• The Training and Qualification program ensures that personnel performing fire protection activities relied on for safety have the applicable knowledge and skills necessary to operate and maintain the ACP in a safe manner.
• Procedures are utilized to ensure safe operations and thorough response to upset conditions involving fires .
• Audits and assessments ensure that the Fire Safety Program is adequate and effectively implemented.
• Incident reporting and investigations are performed to identify and document fire incidents to continually improve operations and programs to ensure the health and safety of the workforce and public.
• Records are maintained and controlled to ensure that IROFS for fire protection are available and reliable.

The Fire Safety/Emergency Management Manager is responsible for the Fire Safety Program, including fire services and reports to the Production Support Manager. This manager has the authority to ensure that fire safety receives appropriate priority. An experienced fire professional is assigned as the AHJ with the responsibility for the interpretation and application of applicable fire codes and standards. The AHJ is a qualified fire protection professional having a bachelor's degree in engineering or a technical curriculum and at least six years applicable experience. These requirements are similar to the eligibility requirements as Member grade in the Society of Fire Protection Engineers. The specific NFPA standards applicable to the ACP are identified in Table 7.1-1 of this chapter. Any changes where full compliance with the applicable NFP A standards is not maintained will be documented and justified by the AHJ. Modifications to fire protection systems and programs are made in accordance with 10 CFR 70.72. The Plant Safety Review Committee, as described in Chapter 2.0 of this license application, provides a review role of fire safety at the ACP. The membership, structure, and responsibilities of this multi-discipline committee are defined in a plant procedure. The procedure includes the responsibility to review fire safety issues and to integrate changes to the plant with adequate consideration of fire safety. The ACP Fire Safety Program management measures are grouped into four areas:

• Fire prevention;
• Inspection, testing, and maintenance of fire protection systems;
• Emergency response organization qualifications, drills, and training; and 7-3

license Application for the American Centrifuge Plant Proposed Change 2020

• Pre-fire plans.

7.1.1 Fire Prevention Fire prevention is a program across the ACP to minimize the potential for an incipient fire . The following are the major points that are addressed by the program .

• Workers are required to review and understand fire safety information including fire prevention procedures, emergency alarm response, and fire reporting. Documented building/facility inspections are conducted periodically and remedial actions are taken when conditions of concern are identified (i .e., accumulation of unnecessary transient combustibles, the presence of uncontrolled ignition sources, or obstruction of egress routes) .
• General housekeeping practices and control of transient combustibles are established .
• Control of flammable and combustible liquids and gases is handled in accordance with the NFPA 30- 20.IBOJ , Flammable and Combustible Liquids Code and NFPA 55-2020~ , Standard for the Storage, Use, and Handling of Compressed Gases and Cryogenic Fluids in Portable and Stationa,y Containers, Cylinders, and Tank.
• Ignitions sources are controlled.
• Fire reports documenting fire investigation and corrective actions are documented through the Corrective Action Program as described in Section 11.6 of this license application.
• Smoking is restricted to designated areas outside of the buildings/facilities .
• Construction activities are performed in a manner that meets the requirements of NFPA 241 -20 1900, Standard for Safeguarding Construction, Alteration, and Demolition Operations.

7.1.1. 1 Con trol of Im pairment to Fire Protection Systems Impairment of fire detection, fire alarms, and fire barriers requires notification to the building custodian of the reason for the impairment, the specific impairment, the expected duration of the impairment, and system restoration time. Compensatory actions are initiated when detection, alarms, or barriers are out of service and may include suspension of hot work or other hazardous processes, personnel notifications, fire patrol s, or other action necessary as determined by the Fire Safety/Emergency Management Manager. Closure of ACP valves on the water system suppl ying the fire suppression systems is controll ed by a written permit system. Fire services controls the valve closure permit sy tern ; therefore, fire services is notified of the impairment of fire suppression system s. Only groups 7-4

License Application for the A merican Centrifuge Plant Proposed Change 2020 authorized by the Fire Safety/Emergency Management Manager have the authority to issue permits and operate fire protection valves. ___ The ACP firewater permit system provides for notification to the building custodian of the reason for the impairment, the expected duration of the impairment, system restoration time, and residual partial system impairment (e.g., branch line removed). Compensatory actions are initiated when bui lding sprinkler systems are out of service and may include suspension of hot work or other hazardous processes, personnel notifications, fire patrols, or other action necessary as determined by the Fire Safety/Emergency Management Manager. ACP systems taken out of service for repair are usually returned to service within an eight-hour period; however, the extent of the actual repairs will affect completion time. 7.1.1.2 Hot Work Permits Hot work is controlled by procedure complying with NFPA 51B-20 19W , Standardfor Fire Protection During Welding, Cutting, and Other Hot Work and applicable Occupational Safety and Health Administration (OSHA) requirements per 29 10 CFR Part 1910.252 The permit system ensures that cutting, welding, and other hot work conducted in plant areas not normally used for such purposes will be conducted utilizing a permit system/process and performed in a manner that is consistent*with industry fire prevention practices. This includes pre-job inspection, stationing a fire watch during the hot work as required, and post-job fire watch to prevent delayed ignition of any combustibles. Selected managers and supervisors are trained and authorized to write hot work permits. Personnel performing fire watches receive additional training. The Fire Safety/Emergency Management Manager, or designee, is notified by the line manager prior to the initial use of a hot work permit. The permits are logged and a field surveillance of work is conducted during routine building inspections and when concerns or unusual circumstances exist. 7.1.2 Inspection, Testing, and Maintenance Fire protection equipment is inspected and tested upon installation in accordance with NFPA 25-2002_4, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems. Periodic inspection and testing of fire protection equipment are performed by or overseen by trained personnel to help ensure that fire safety related IROFS are av~;iable and reliable. The testing and inspection of equipment is performed in accordance with procedures that include test frequencies as defined by the Fire Safety/Emergency Management Manager. The major elements of the plant inspection program are identified as follows .

• Flow test sprinkler systems
• Test manual fire alarms (pull stations)
• Test sprinkler water flow alarms
• Test supervisory alarm devices including control valves, low air pressure, low temperature, and loss of power 7-5

l icense Application for the American Centrifuge Plant Proposed Change 2020

• Operate sprinkler system control valves
• Test special fire alarm indicators, such as heat and smoke detection systems
• Inspect major bui ldings to evaluate housekeeping, check fire emergency equipment, and exit pathways
• Inspect sprinkler systems risers
• Inspect portable fire extinguishers 7.1.3 Emergency Response Organization Qualifications, Drills, and Training The ACP relies upon a qualified provider to perform emergency response to fire and other types of accident scenarios occurring at the ACP . Employees receive initial and biennial fire safety training as part of General Employee Training (GET) on emergency preparedness. This includes emergency reporting, bui lding/facility evacuation, and fire extinguisher familiarization . GET is described in Section 11.3 . l. l of this license application.

A qualified supplier provides fire department response to an emergency . This supplier is staffed, trained, and equipped adequately to meet the needs of the ACP and the commitments contained in this license application. The qualified provider will have adequate resources to meet the needs of the ACP. This requires appropriately trained and qualified -Are-fighlingfirefighting personnel, available 24-hours per day, as well as a minimum complement of equipment. There will be a minimum of four qualified fire fighters and one supervisor available to respond per shift. These four fire fighters cover entry and backup (two each). Equipment requirements include one pumper truck with a minimum capacity of 1,000 gpm, one ambulance, and one HAZMAT truck with radiological and rescue equipment. The time to apply water onto a fire will not exceed 20 minutes, 90 percent of the time. This is assured through assessments performed in accordance with Section 11.5 of this license application that confirms that the level of service is consistent with performance requirements specified in a letter of agreement. Firefighter training is equivalent to the state certified firefighter training curriculum . Emergency medtal medical response personnel meet requirements for state certification as emergency ttteru-a+medical technician and are ttStra+l-y also firefighters . Qualified instructors provide a range of classroom and hands-on trarnmg to maintain standards of performance for all response personnel. Training needs are reviewed annually and the training program modified to meet identified needs. Training records are kept of the training acti vities. Training is based on national standard emergency response methodology with plant-specific training on issues unique to the plant. Specific training activities include firefighting, hazardous material response, confined space rescue, emergency medical response, radiological emergencie , and rescue. Drills are conducted as part of the plant emergency plan . 7-6

license Application for the American Centrifuge Plant Proposed Change 2020 7.1.4 PreFire Planning Prefire plans are developed as part of the building emergency packet-fet:.,_ Pre-fire plans for HALEU Demonstration include the following buildings and areas~~ X: 3001 Process Building; X3002 Process Bui lding; X: 301 2 Process Support Building; X-3344 Customer .Services-Bui lding; X3-346 Feed and Withdrawal Buil-0ing; X3346A -Feed -and Pr-oduct Shipping- -and -Ree,~v-ing Bui lding; X: 7725 Recycle/Assembly Faci lityBuilding; X: 7726 Centrifuge Training and Test Facility; and X: 7727H Interplant Transfer Corridor; and the Cylinder Storage Yards (X745G2, X +4SH, -X1746S, -and X7746W). Pre-fire plans for other facilities will be developed prior to deployment of operations involving licensed materials in those facilities. Each pre-fire plan contains the foll owing applicable information about the building or area:

• Facility description/construction,
• Specific hazards to emergency responders,
• Search and rescue considerations,
• Fire protection equipment/systems available,
• Utility shut-offs/start-ups,
• Fire loading concerns,
• Unique fire fighting strategy and tactics,
• Fire extension concerns, and
• Ventilation methodology.

Trained personnel review these pre-fire plans as part of the building inspection. As buildings are modified to meet the changing operations, the pre-fire plans are scheduled for review and updates to assure the revised conditions are addressed. As new buildings are added to meet the changing operations, pre-fire plans will be developed prior to placing the buildings in operation. Table 7.1-1 Applicable National Fire Protection Association Codes and Standards Code No. Title Revision NFPA 10 Standard for Portable Fire Extinguishers 20.IBG+/- NFPA 13 Standard for the Installation of Sprinkler Systems 200212 NFPA 15 Standard for Water Spray Fixed Systems for Fire Protection 20G+l1 7-7

license Application for the American Centrifuge Plant Proposed Change 2020 NFPA25 Standard for the Inspection, Testing, and Maintenance of Water-20024 Based Fire Protection Systems NFPA30 Flammable and Combustible Liquids Code 20l]_W-NFPA 51B Standard for Fire Prevention During Welding, Cutting, and Other 201203 Hot Work NFPA55 Standard for the Storage, Use, and Handling of Compressed Gases and Cryogenic Fluids in Portable and Stationary Containers, 202005 Cylinders, and Tanks NFPA 70 National Electric Code 2005 NFPA 72 National Fire Alarm Code 2002 NFPA 75 Standard for the Protection ofElectronic Computer/Data 2003 Processing Equipment NFPA80 Standard for Fire Doors and Fire Windows 1999 NFPA 101 Life Safety Code 20l]_03 NFPA220 Standard on Types ofBuilding Construction 1999 NFPA232 Standard for the Protection ofRecords 2000 NFPA 241 Standard for Safeguarding Construction, Alternation, and 201200 Demolition Operations NFPA 801 Standard for Fire Protection for Facilities Handling Radioactive 202003 Materials 7.2 Fire Hazards Analysis FHAs have been performed for the following buildings and areas; X-3001 , X-3002, X-3012, X-7725, X-7726, X-7727H, X-3344, X-3346, X-3346A, X-745G-2, X-7746S, and X-7746W . The FHAs applicable to HALEU Demonstration include those for X-3001, X-3012, X-7725 X-7726 and X-7727H. These FHAs and supporting analyses ensure that the fire prevention and fire protection requirements have been evaluated and incorporated. The analyses consider the building's/facility's specific design, layout, and anticipated operating needs and considers acceptable means for separation or control of hazards, the control or elimination of ignition sources, and the suppression of fires . A FHA wiH be performed for the X-~H prior t<> construction .FHAs for other facilities will be developed and implemented prior to deployment of operations involving licensed materials in those facilities .

• This informationThe FHAs and supporting analyses were was used in the Integrated Safety Analysis (ISA) for the ACP to determine the credible fire accident scenarios, their likelihood of occurrence, the associated consequences, and the necessary IROFS to reduce the likelihood of occurrence and/or the consequences to meet performance requirements. The results of the ISA are presented in the ISA Summary for the American Centrifuge Plant and Addendum 1 of the ISA Summary for the American Centrifuge Plant - HALEU Demonstration .

To ensure an adequate level of safety is maintained, fire hazards for each of the buildings are evaluated periodically and documented in a building survey. The building survey results are 7-8

license Application for the American Centrifuge Plant Proposed Change 2020 used to update the FHAs and ISA as necessary. Further discussion of the FHA, ISA, and building survey approaches are described below. For new buildings or facilities, FHAs are perfonned during the design development process to ensure that the fire prevention and fire protection requirements have been evaluated and incorporated into the design. The analysis considers the facility ' s specific design, layout, and anticipated operating needs and considers acceptable means for separation or control of hazards, the control or elimination of ignition sources, and the suppression of fires . 7.2.1 Fire Hazards Analysis Approach Fire Hazards Analyses provide a general description of the physical characteristics of the buildings/facilities that outlines the fire prevention and fire protection systems to be provided. A FHA defines the fire hazards that can exist, and states the loss_limiting criteria to be used in the design of a building and/or facility . FHAs provide a formal review and periodic evaluation of the occupancy and the fire protection associated with a building/facility and includes the following elements:

• A listing of the codes and standards is used for the design of the fire protection systems, including the published standards of NFPA.
• The FHA defines and describes the characteristics associated with potential fires for areas that contain combustible materials, such as fire loading, hazards of flame spread, smoke generation, toxic contaminants, and contributing fuels.
• The FHA lists the fire protection system criteria and the criteria to be used in the basic design for such items as water supply, water distribution systems, and fire pump supply.
• The FHA describes the performance criteria for the detection systems, alarm systems, automatic suppression systems, manual systems, chemical systems, and gas systems for fire detection, confinement, control, and extinguishment.
• The FHA describes the design for suppression systems and for smoke, heat, and flame control; combustible and explosive gas control; and toxic and contaminant control as necessary. The FHA also describes the operating functions of the ventilating and exhaust systems to be used during the period of fire extinguishment and control.
• The FHA uses the features of building and facility arrangements and the structural design features to generally define the methods for fire prevention, fire extinguishing, fire control, and control of hazards created by fire. Fire barriers, egress, firewalls, and the isolation and containment features provided for flame, heat, hot gases, smoke, etc., are also addressed.
• The FHA identifies the dangerous and hazardous combustibles and the maximum quantities estimated to be present in the building/facility. The FHA 7-9

Licen e Application for the American Centrifuge Plant Proposed Change 2020 also identifies where these materials can be located appropriately m the building/facility .

• Based on the expected quantities of combustible materials, the types of potential fires, their estimated severity, intensity, duration, and the potential hazards created for each fire scenario reviewed, the probable and possible maximum losses from fires are described in the FHAs.
• Where safe shut down of safety related equipment is necessary, the FHA will define the essential electric circuit integrity needed during fire, and evaluates the electrical and cable fire protection; the fire confinement control ; and the fire extinguishing systems that will be needed to maintain their integrity.
• The FHA evaluates life safety, protection of critical process/safety equipment, lightning protection, provision to limit contamination, potential for radioactive release, and restoration of the building/facility after a fire .

7.2.2 Integrated Safety Analysis An ISA of the design, construction, and operation of the commercial ACP was conducted in accordance with the guidance provided in NUREG-1513, Integrated Safety Analysis Guidance Document and the requirements of 10 CFR 70.62(c). An associated Addendum to the ISA Summary was also performed for the HALEU Demonstration applying the same guidance and process. The ISA contains the following elements:

• Accident analysis including major fire scenarios;
• The effects of fire safety measures in preventing fire scenarios;
• The effect of the fire protection system in controlling and mitigating the fire scenarios; and
• Toxic and radiological hazards from a release regardless of the initiator.

A number of the release scenarios evaluated in the ISA have an explosion or fire as the initiating event and are evaluated for the FHAs. The ISA determines the likelihood of occurrence for the fire scenarios and resulting consequences associated with the release of uranium hexafluoride (UF6) and its airborne release reaction product, hydrogen fluoride (HF) assuming the fire is unmitigated. Then the ISA identifies IROFS and related management measures necessary to prevent the accident and/or mitigate the consequences in accordance with the performance criteria in 10 CFR 70.61. This information is presented in the ISA Summary for the American Centrifuge Plant and Addendum I of the ISA Summary for the American Centrifuge Plant - HALEU Demonstration . UF6 is the primary hazardous material in the commercial ACP operation and HALEU Demonstration and the ISA provi des an evaluation of accidents that involve the release of UF6, including both radiological and toxicological hazards. The HF, which evol ves from a UF6 release, 7-10

License Application for the American Centrifuge Plant Proposed Change 2020 is considered as one of the toxicological hazards from a UFGrelease and is also addressed in the ISA. 7.2.3 Building Surveys The building surveys are conducted, in accordance with written procedures on a periodic basis, to ensure the buildings/facilities, systems, and operations continue to meet the codes and standards to which they were built and operated, and do not violate any safety basies that were established in the ISA for the credible accident scenarios. The building surveys also ensure no new credible fire scenarios have been created. 7.3 Building/Facility Design There are fire hazards related to the enrichment process. Fire hazards are typical industrial hazards, including maintenance; incidental use of chemicals and flammable liquids; and energized electrical equipment in the buildings. Accident potentials are discussed in the FHAs and ISA. The ACP buildings/facilities are large and spread across the DOE reservation, which minimizes the effects that a fire or explosion could have on adjacent buildings and operations. Ventilation supply and exhaust locations are considered with regard to contamination potential and smoke control. R-Oer surfaces are finished to support contamination control The primary ACP buildings/facilities are X-3001 , X-3002, X-3012, X-3344, X-3346, X-3346A, X-7725 , X-7726 buildings/facilities, and X-7727H corridor. Only X-3001, X-3012, X-7725, X-7726, and X-7727H are used for HALEU Demonstration. The X-3001, X-3002, X-3012, X-3344, X-3346, X-3346A, X-7725 , X-7726 buildings/facilities, and X-7727H corridor are constructed of heavy unprotected steel frame, concrete floors, insulated metal panel exterior walls, and a built up roofing and/or spray applied polyurethane, silicone material on a metal deck. Each building is considered a single fire area with exception of the X-3346, X-7725 , X-7726 buildings/facilities, and X-7727H corridor. Sprinkler coverage is provided in each building/facility. The sprinkler and water systems are described below. There are no water-exclusion areas in the ACP. Combustible loading is typically low and the fire hazards are limited to normal industrial activities. Exceptions are identified in the building survey report or by the building/facility manager. These include such things as electrical switchgear and transformers, and maintenance activities. Use of firewater and potential firewater accumulation has been reviewed in each of the buildings/facilities to assure no unsafe accumulations can occur with regard to criticality, equipment loss, or spontaneous combustion . Firewater runoff to the environment is controlled by the presence of holding ponds that can reduce or terminate releases as necessary to minimize environmental impact. There are no credible accident scenarios that could result in a criticality event in the holding ponds. As indicated previously, the X-3001 , X-3002, X-3012, X-3344, X-3346A, X-745G-2, X-7746S, and X-7746W are each considered single fire areas, but the X-7725 building and X-7726 7-11

License Application for the A merican Centrifuge Plant Proposed Change 2020 facili ~ ies, and X-7727H corridor are considered as a single fire area and the X-3346 building is considered as two fire areas (Feed Area and Withdrawal Area). Fire areas are considered to be any location bounded by fire rated construction with a minimum rating of two hours and equivalently fire rated doors, dampers, or penetration seals. Building and area separation is used as a method of limiting fire spread. The X-7725 fa-ci lity and X-3001 buildin~ are, connected by the X-7727H corridor, of the same construction. Each are protected by automatic sprinkler system, and have acceptable amounts of combustibles. Review of the emergency egress paths for the existing buildings/facilities is accomplished using NFPA 101-20liW , Life Safety Code, as guidance. Some buildings do not comply with the travel distances due to their size. Exit arrangements are adequate because of the low occupancy levels, low combustible loading, large number of exits, and fixed fire suppression systems in the buildings. Combustible storage in the buildings is considered as part of the hazard evaluation described in Section 7.2 of this chapter. There are no significant quantities of flammable liquids or gases used in the enrichment process; however, centrifuge component manufacturing may be performed in the X-7725 and involve significant quantities of flammable liquids. The use of these liquids and incidental use of other flammable liquids and gases is controlled in accordance with NFPA 30-20liOJ., Flammable and Combustible Liquids Code and NFPA 55-202005, Standard for the Storage, Use, and Handling of Compressed Gases and C,yogenic Fluids in Portable and Stationary Containers, Cylinders, and Tanks. Electrical systems are installed in accordance with NFPA 70-2005, National Electric Code . ACP building/facility design elements include fire protection lighting and fire barriers to ensure personnel safety in accordance with the applicable NFPA identified in Table 7.1-1. Security provisions to maintain control of classified material during fire events are addressed in the Security Plan for the Protection of Classified Matter Seat-fity Program-for the American Centrifuge Plant (Reference 22). New buildings/facilities are designed, constructed, and operated to meet the codes and standards applicable at the time of design development. The Cylinder Storage Yards (-X-745G-2, X-745H, X-7746S, and X-7746W) have fire hydrants equipped with monitor nozzles. Workers are trained to initiate the nozzles should a fire occur within the yards. Cylinder handling equipment for handling 2 5-ton -yhndern or farger are-equiwed with fue..sl:1-j}presser-systems for the eitgin-e-oompartments. 7.3.1 Fire Suppression Systems 7-12

License Application for the A merican Centrifuge Plant Proposed Change 2020 Fire Su ression i rovided in the followin buildin s/facilities to su ort HALEU Demonstration: X 3001, X-3012, X-7725, X-7726, and X-7727H. Fire suppression is provided in the following buildings/facilities to support commercial ACP operation: for the X-3001 , X-3002 , X-3012, X-3344, X-3346, X-3346A, X-7725, X-7726 buildings/facilities, and X-7727H corridor is provided by sprinkler systems. The systems are hydraulically designed and installed to meet or exceed the NFPA recommended sprinkler densities for Ordinary Hazard Group 1 occupancies and storage occupancies. The systems consist of sprinklers located at the ceilings/roof level and in other areas where needed. The sprinkler heads are supplied by piping fed from a riser connected to the firewater distribution system. This design is sufficient to ensure that credible fire related accident scenarios can be controlled given the building designs, equipment layout, and anticipated combustible loadings. Fire Suppression in other buildings/facilities (e.g., X-3002, X-3346, X 3346A) will be provided prior to deployment of operations involving licensed materials in those facilities . Existing suppression systems are maintained in accordance with the applicable codes and standards enforced at the time of construction and installation. New suppression systems will meet NFPA 13-201 92~ , Standard for the Installation of Sprinkler Systems and NFPA 25-20172002, Standard for Water Spray Fixed Systems for Fire Protection. When modifying existing buildings/facilities, the safety benefit from applying current codes and standards will be evaluated to determine if the change is justified. The evaluation and decision made will be documented. 7.3.2 Fire Alarms The sprinkler systems are connected to the Fire Alarm system . This system meets the requirements ofNFPA 72-2002, National Fire Alarm Code. The system alarms include sprinkler water flow alarms from the sprinkler systems and manual pull stations located in the X-3001 , X-3002, X-3012, X-3344, X-3346, X-3346A, X-7725, X-7726 buildings/facilities, and X-7727H corridor. Alarms are received in the X 1020-- -Emergency Operations CenterX-300 Plant Control Facility and the X-1007 Fire Station. Alarm announcement is not local, but building evacuation can be manually initiated from the X-l-020 Emer-gency Operations ('enter, frent-- -t he X-3012 Area Control Room, X-300, and X-1007 or locally in some areas. 7.4 Process Fire Safety The ACP has addressed process fire safety through the design of the buildings and operations such that consideration is taken for fire hazards that may be present in order to protect the workforce and public. Hazardous areas are identified to ensure the workforce is cognizant of hazardous material and operations. The ISA has been performed to identify the credible accident scenarios and establish the necessary IROFS to ensure the health and safety of the workforce and public. The IROFS for the ACP are identified in the ISA Summary for the commercial ACP operation. The IROFS for HALEU Demonstration are identified in Addendum 1 of the ISA Summary. IROFS associated only with the commercial ACP operation will be implemented prior to deployment of operations involving licensed materials in those facilities. The ACP buildings/facilities cl;fe designed in accordance with the codes and standards as identified in Section 7.1 above. The ACP hazardous areas are identified as part of the pre-fire 7-13

License Application for the American Centrifuge Plant Proposed Change 2020 plans required in Section 7.1.4 above. The ACP ISA is discussed in Section 7.2.2 of this chapter and Chapter 3.0 of this license application . The ISA determines the likelihood of occurrence for the explosion and fire scenarios and resulting consequences associated with the release ofUF6 and its airborne release reaction product, HF assuming the accident is unmitigated. The ISA identifies IROFS and related management measures necessary to prevent the accident and/or mitigate the consequences in accordance with the performance criteria in 10 CFR 70.61. The IROFS identified by the ISA to prevent or mitigate explosion and fire related scenarios are grouped in the following three categories.

• Combustible Material Control
• Fire Suppression and Response
• Fire/Explosion Prevention UF6 is the primary hazardous material in the ACP. In the presence of moist air, UF6 reacts to form HF gas and U0 2F2. The ISA considers tJ U0 2F2 for radiological and toxicological hazards and HF for toxicological hazards. Other chemicals evaluated are activated alumina pellets used in the alumina traps to filter UF6 gas, compressed gases (e.g. , nitrogen, acetylene), perfluorocarbon fluid used in the equipment brine heating/cooling system, other refrigerants used in the various process refrigeration systems, janitorial supplies, fire extinguishing agents, and non-flammable oils used within the centrifuge upper and lower support assemblies. These other chemicals are not considered to have a significant hazardous interaction capability.

If centrifuge component manufacturing is performed within the ACP, additional materials are required for the process that will present fire safety and health concerns. These additional materials include carbon fibers, resin systems (resins, hardeners, and modifiers), prepregs (fibers/resin system) and for cleaning chemicals such as acetone, alcohols, carbon dioxide, ethanol , and Freon 134. 7.5 Fire Protection and Emergency Response The design and operation of the buildings/facilities are evaluated on a periodic basis to ensure fire hazards are controlled. Fire protection system are present to further reduce the risk of fires that could result in a release of hazardous material. Emergency response is provided to add defense-in-depth to the fire protection systems and respond to areas where fire protection systems do not exist. 7.5.1 Fire Protection Engineering Fire protection engineering support is available to evaluate fire hazards; review changes to maintenance and process systems; and provide in-house consultation under the direction of the Fire Safety/Emergency Management Manager. They also perform the building surveys as described in Section 7.2. 3 of this chapter. 7-14

License Application for the American Centrifuge Plant Proposed Change 2020 Fire protection engineers assist in the development of project design criteria, perform design review, and conduct routine engineering consultation as necessary . Fire protection engineering is part of project design teams and routinely reviews project design packages to ensure applicable fire safety issues are addressed. These issues may include construction, egress, building/facility protection, separation of fire areas, detection systems, and special hazard protection. Fire protection engineers are either graduates of a technical program or have at least six years experience in fire protection work. Reported fires are investigated using a graded approach through the Corrective Action Program. This includes investigations by fire officers, engineers, or by multidiscipline teams as warranted. Results of investigations are considered for distribution throughout ACP operations to prevent future reoccurrences. Details of incident investigation in the ACP are described in Section 11 .6 of this license application. 7.5.2 Alarm and Fixed Fire Suppression Systems The ISA credits fire suppression to ensure that credible fire accident scenarios do not result in consequences that would exceed the performance criteria established in 10 CFR 70.61. The alarm and fire suppression systems are designed and installed with adequate capabilities to detect and suppress the credible accident scenarios identified by the ISA. The alarm and fixed fire suppression relied on for HALEU Demonstration is identified in Addendum 1 of the Integrated Safety Analysis - HALEU Demonstration. The firewater supply to support fire suppression systems is provided by the DOE reservation system . The firewater supply is sufficient to meet the anticipated needs of the ACP. To ensure the firewater is available and reliable, assessment requirements of Section 11 .5 of this license application are performed. See Section 7.5.3 of this chapter. Fire detection is based upon heat and is an integral part of the fire suppression systems. Fire suppression systems have sprinkler heads with fusible links or gas expansion actuators to initiate water flow when specific temperatures are reached. Water flow alarms on the fire suppression systems provide fire detection. System flow is monitored to provide alarms for emergency response. The fire alarm system monitors fire suppression systems in the ACP buildings. Alarms caused by non-fire conditions (i.e., spurious water flow alarms from pressure surges) are reviewed by fire safety personnel and identified for maintenance as needed. The system includes alarm notification to the X-l 020 Emergency---Operati-ens Center X-300 and the-X-1007 -cf-ire -Station. Alarm rooms are manned as necessary to support prompt notification of emergency response personnel to investigate and respond to alarm conditions. Manual pull stations are located throughout the buildings/facilities to provide additional alarm capability. Operation of a pull station initiates an alarm at the central alarm receiving locations (X-1007,--X-+-O-W,-_and X-300X 3012 buildings), but is not announced locally. 7-15

License Application for the A merican Centrifuge Plant Proposed Change 2020 The ACP has evacuation alarm initiation capability in areas that can be initiated locally, in addition to remote initiation capability from the X 1020 and X-3012 Area Control Room, X-300, and X-1007 buildings. Fixed automatic fire suppression systems provide the means of detection, control , and suppression of fires at the ACP. These fixed fire suppression systems are inspected, tested, and maintained on a regular basis in accordance with approved procedures. 7.5.3 Firewater Distribution System The ACP fire suppression systems are part of the DOE reservation firewater distribution system . This system is capable of supplying firewater at rates and durations adequate to meet the anticipated needs of the ACP. The firewater distribution system is an underground piping system laid out such that each ACP building/facility can be supplied from at least two sources. The fire hydrants adjacent to ACP buildings/facilities are also supplied by the firewater distribution system . Additional components that support firewater distribution of the firewater storage tanks and firewater pumps. The firewater storage tanks include one 300,000 :gallon elevated tank and two 2,000,000

gallon surface tanks. The firewater pumps include two electric pumps and one diesel pump each with a capacity to pump up to 4,000 gallons per minute. The diesel pump has enough fuel to run for the durations needed to meet the anticipated needs of the ACP.

7.5.4 Mobile and Portable Equipment Mobile and portable fire protection equipment are provided by a qualified supplier. Portable fire extinguishers are available throughout the ACP. Size, selection, and distribution of extinguishers are determined in accordance with NFPA I0-20li02, Standard for Portable Fire Extinguishers. 7.5.5 Emergency Response The ISA credits emergency response to ensure that credible fire accident scenarios do not result in consequences that would exceed the performance criteria established in 10 CFR 70.61. Fire department emergency response is provided by a qualified supplier. This supplier is staffed, trained, and equipped adequately to meet the needs of the ACP. See Section 7.1.3 of this chapter. ACP workers are trained as indicated in Section 11.3 of this license application to recognize emergency conditions and alert the emergency response group. 7.5.6 Control of Combustible Materials The ISA credits combustible materials control programs inside and outside the ACP buildings/facilitie to ensure that credible fire accident scenarios do not result in consequences that would exceed the performance criteria established in 10 CFR 70.61 . This covers the ACP primary facilities and is addressed on a continuous basis by the building/facility custodians. It also includes 7-16

License Application for the A merican Centrifuge Plant Proposed Change 2020 limited use of fossil fuel and other combustible material. Combustible materials control is assured through training and procedures as discussed in Sections 11.3 and 11.4 of this license application. 7.5. 7 Use of Non combustible Materials The ISA credits use of noncombustible materials in the construction and operation of the ACP buildings/facilities to ensure that credible fire accident scenarios do not result in consequences that would exceed the performance criteria established in 10 CFR 70.61. This includes use of construction material such as concrete, steel, insulation, and refrigerant. Use of noncombustible materials is assured through the Configuration Management Program discussed in Section 11.1 of this license application . 7 .5.8 Control of Combustible Mixtures The ISA credits control of combustible gases and mixtures in the construction and operation of the ACP buildings/facilities and manufacture of equipment to ensure that credible fire accident scenarios do not result in consequences that would exceed the performance criteria established in 10 CFR 70 .61 . Control of combustible mixtures is assured through the Maintenance Program discussed in Section 11.2 of this license application. 7.5.9 Placement of Equipment and Operations The ISA credits placement of equipment in ACP buildings/facilities to ensure that credible fire accident scenarios do not result in consequences that would exceed the performance criteria established in 10 CFR 70.61. Proper placement of equipment and operations is assured through the Configuration Management Program discussed in Section 11 .1 of this license application . 7.6 References

1. 29 CFR Part 1910.252, Occupational Safety and Health Standards

2. LA-3605-0003 , Integrated Safety Analysis Summary for the American Centrifuge Plant

3. NFPA 10-201]_02, Standard/or Portable Fire J:,xtinguishers

4. NFPA 13-2<XP- 19, Standard for the Installation of Sprinkler Systems

5. NFPA 15-200-1 11, Standard for Water Spray Fixed Systems/or Fire Protection

6. NFPA 25-200k4 , Standard for the inspection, Testing, and Maintenance of Water-Based Fire Protection Systems

7. NFPA 30-20.l]_W , Flammable and Combustible Liquids Code J .

7-17

License Application for the American Centrifuge Plant Proposed Change 2020

8. NFPA 51B-2012.0J, Standard/or Fire Prevention During Welding, Cutting, and Other Hot Work

9. NFPA 55-2020~ , Standard/or the Storage, Use, and Handling of Compressed Gases and Cryogenic Fluids in Portable and Stationary Containers, Cylinders, and Tanks

10. NFPA 70-2005, National Electric Code

11. NFP A 72-2002, National Fire Alarm Code

12. NFPA 75-2003 , Standard for the Protection ofElectronic Computer/Data Processing Equipment 13 . NFP A 80-1999, Standardfor Fire Doors and Fire Windows

14. NFPA 101-20J_B(l3, Life Safety Code

15. NFP A 220-1999, Standard on Types ofBuilding Construction

16. NFPA 232-2000, Standard/or the Protection ofRecords

17. NFP A 241-2012.0G, Standard for Safeguarding Construction, Alteration, and Demolition Operations

18. NFPA 801-2020(};, Standard/or Fire Protection/or Facilities Handling Radioactive Materials

19. NUREG: 1513, Integrated Safety Analysis Guidance Document

20. NUREG: 1520,_Standard Review Plan f or 1he Re-Piew of-a UH H.'it! 11pp./ffa-11011for a Fuel 1

Cycle Fadli~vFacilities License Applications, Revision 2

21. LA-3605-0003A, Addendum 1 of the ISA Summary for the American Centri"fuge Plant -

HALEU Demonstration 20.22. SP-3605 -0041, Security Plan for the Protection of Classified Matter at the American Centrifuge Plant 7-18

License Application fo r the American Centrifuge Plant Proposed Change 2020 8.0 EMERGENCY MANAGEMENT As discussed in Section 1.1.8 of this license application, it is the long-term goal of the Licensee to deploy the American Centrifuge Plant (ACP) in a modular fashion on a scalable, economical gradation consistent with market demand. American Centrifuge Operating, LLC (ACO), the Licensee, would develop and submit future license amendments to allow additional phases of modular deployment up to the currently U.S. Nuclear Regulatory Commission (NRC)- approved full capacity operation of 3.8 million separative work units . Pursuant to 10 Code of Federal Regulations (CFR) 70.22(i), the Licensee developed an NRC-approved ftfl-Emergency Plan for the fully deployed American C'~ntrifuge Plant ACP has been developed . The Emergency Plan is written to ene-0mpass the J\mer*can CeAtfifuge Plant and other on-going activities on the U.S . Department of Energy (DOE) reservation in Pike County Ohio. The previously NRC-approved plan conforms to the Regulatory Guide 3.67, Standard Format and Content for Emergency Plans for Fuel Cycle and Materials Facilities, dated January 1992. Although not required or implemented for the High Assay Low Enriched Uranium (HALEU) Demonstration Program, the Emergency Plan will support future ACP deployment phases. The information documented in this plan the previously NRC-approved emergency plan includes: 1) description of the facility ; 2) summary credible emergencies; 3) classification and notification of accidents; 4) responsibilities; 5) emergency response measures; 6) equipment and facilities designated for use during emergencies; 7) methods for maintaining emergency preparedness; 8) emergency records and reports; 9) recovery and restoration measures; and 10) a commitment to comply with the Community Right-To-Know Act. The previously NRC-approved plan remains is submitted for review as part of this license application as document NR-3605-0008 , Emergency Plan for the American Centrifuge Plant in Piketon, Ohio. The Licensee would notify the NRC well in advance of the transition into any future phases of deployment that would require use of this previously NRC-approved NR-3605-0008 . 8.1 High Assay Low Enriched Uranium Demonstration No Emergency Plan as discussed under 10 CFR 70.22(i) is needed for the HALEU Demonstration Program . DAC-3901-0005, Evaluation o(No Need for an Emergencv Plan for the HALEU Demonstration, provides the evaluation stipulated in 10 CFR 70.22(i)(l)(i) to demonstrate that no Emergency Plan is required for the HALEU Demonstration Program . The evaluation shows that the maximum dose to a member of the public offsite due to a release of radioactive materials would not exceed 1 roentgen equivalent man (rem) effective dose equivalent or an intake of 2 milligrams (mg) of soluble uranium (U). DAC-3901-0005 uses "factors" provided in 10 CFR 70.22(i)(2) to support making the determination that no Emergency Plan is required. Relevant guidance provided in NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications (Revision 2), is also used . Key "factors" used in the HALEU Demonstration Program evaluation include recognition of engineered safety features as necessary and operating restrictions or procedures to prevent 8-1

License Application for the American Centrifuge Plant Proposed Change 2020 exceeding 1 rem or 2 mg U intake at the DOE reservation boundary . The e were applied for the evaluation of certain fire scenarios. With engineered safety features as necessary and operating restrictions or procedures, no fire scenario can be identified that would cause consequences that would require an Emergency Plan. Fluor BWXT Portsmouth, LLC (FBP); Portsmouth Mission Alliance, LLC; and Mid-America Conversion Services, LLC are the DOE's primary contractors at the DOE Portsmouth site. FBP currently serves as the Decontamination and Decommissioning contractor and provides emergency response capabilities at the site compliant under DOE Order 151.lD, Comprehensive Emergency Management System . Through a reverse work authorization arrangement, FBP provides emergency response to the ACP. With augmentation and coordination with ACO personnel where appropriate, FBP provides the following :

• Emergency Response Organization
• Emergency Facilities and Equipment/Systems
• Fire Department Response*
• Emergency Operations Center (EOC)
• Alternate EOC
• Joint Information Center
• Plant Shift Superintendent/Incident Command Support
• Emergency Medical Support
• Offsite Response Interfaces
• Announcement of Protective Actions
• Emergency Public Information
• Communications and Notifications, as appropriate
• Consequence Assessment
• Support with Termination and Recovery, as appropriate
• Support with Coordinating and Assessing Readiness Assurance
• FBP operates and maintains the X-1007 Fire Station on the DOE reservation. . This is a 24 hours a day/7 days a week dedicated fire department which has minimum staffing requirements to maintain appropriate manpower for emergency response on the DOE reservation. Fire personnel are certified as State of Ohio Level II (Professional Firefighters) and minimum State of Ohio Emergency Medical Technicians with one Paramedic per shift.

8.1. l Nuclear Criticality The primary radiation alarm system is the Criticality Accident Alarm System (CAAS), designed to detect a nuclear criticality and provide annunciation by audible evacuation alarms that are supplemented by visual alarms in some areas, such as high-noise areas that will alert personnel to evacuate the immediate area. Operations involving fissile material are evaluated for Nuclear Criticality Safety (NCS) considerations prior to initiation. The need for CAAS coverage is considered during the evaluation process. CAAS coverage is provided, unless it is determined that coverage is not 8-2

License Application for the American Centrifuge Plant Proposed Change 2020 required per the requirements of 10 CFR 7024 and the finding i documented in an C Evaluation . CAAS coverage is provided for HALEU Demonstration fissile material operations. The CAAS is designed to detect gamma radiation levels that would result from the minimum criticality accident of concern as defined in 10CFR70.24(a)(l}. The CAAS is designed to provide annunciation by audible alarms that are supplemented by visual alarms in some areas, such as in high-noise areas. The criticality detection system consists of detector clusters and an alarm system. When a criticality accident alarm activates, a radiation alarm is generated actuating building local horns. Alarm activation requires evacuation of personnel from the affected area to a designated monitoring station that is located a minimum evacuation distance of 125 ft from the facility with the active CAAS alarm. Trained emergency responders are dispatched to the facility evacuation point to provide evacuees and Incident Command with additional guidance, as appropriate. Based on the alarm location, Incident Command can direct the actions necessary to respond to the accident in coordination with technical personnel. The EOC is activated and provides coordinated support for the response. Emergency response to CAAS alarms and/or nuclear criticality events is consistent with guidance contained m ANSI/ANS-8 .23 -2007, Nuclear Criticality Accident Emergency Planning and Response. Coordinated response exercises and local drills are performed periodically to familiarize personnel with proper response actions and assembly locations. 8.2 References

l. American National Standards Institute (ANSI)/ American Nuclear Society (ANS) 8.3-1997, Criticalitv Accident Alarm System

2. American National Standards Institute (ANSI)/ American Nuclear Society (ANS) 8.23 -2007, Nuclear Criticality Accident Emergency Planning and Response

3. Regulatory Guide 3.67, Standard Format and Content for Emergency Plans for Fuel Cycle and Materials Facilities, Revision 1

4. NR-3605-0008, Emergency Plan for the American Centrifuge Plant

5. DAC-3901 -0005, Evaluation of No Need for an Emergency Plan for the HALEU Demonstration

6. NUREG-1520, Standard Review Plan for hie/ Cycle Facilities License Applications.

Revision 2

7. DOE Order 151 . 1D, Comprehensive Emergency Management System 8-3

License Application for the American Centrifuge Plant Proposed Change 2020 Blank Page 8-4

License Application f or the A merican Centrifuge Plant Proposed Change 2020 9.0 ENVIRONMENTAL PROTECTION The American Centrifuge Plant (ACP) is located in Piketon, Ohio on the U.S. Department of Energy (DOE) reservation, adjacent to the former U.S . Nuclear Regulatory Commission (NRC) regulated Portsmouth Gaseous Diffusion Plant (GDP), an existing facility with a similar mis~ion .,_ rhe Portsmouth GDP has radioactive efiluent c-o nt1ob and as lo\,\- as reasonably achievable (ALARA) prograrn-s l-hnt meet US Nuclear Regulalory-(:'ommission (NRG) requirements .,_ The ACP Environmental Protection Program is modeled on after the existing well -seasoned GDP environmental protection program. The ACP program thus takes advantage of the well-established programmatic elements and experience and many years of existing environmental data. This approach will provide maximum protection to the public and the environment. The Production Support Manager is responsible for the ACP Environmental Protection Program. Details of the minimum requirements for the managers and staff supporting the Environmental Protection Program are provided in Chapters 2.0 and 11.0 of this license application. As discussed in Section l. l.8 of this license application, American Centrifuge Operating, LLC ' s (ACO) long-term goal is to resume commercial enrichment production consistent with market demand . The ACP design is modular, with the basic building block of enrichment capacity being a cascade of centrifuges. Modular deployment would accommodate market demand on a scalable, economical gradation. As such, the Environmental Protection Program will be implemented to support the modular deployment. The next phase of enrichment production includes the deployment of a cascade of centrifuges to demonstrate production of high-assay, low-enriched uranium (HALEU) fuel for advanced reactors. The primary building/facilities directly involved in HALEU Demonstration are the X-3001 Process Building, X-3012 Process Support Building, X-7725 Recycle/Assembly Building, X-7726 Centrifuge Training and Test Facility, and X-7727H Interplant Transfer Corridor. The Licensee will notify NRC well in advance of the transition into any future phases of ACP deployment. For further plant and process specifics related to the HALEU Demonstration Program, refer to LA-3605-0003A, Addendum 1 of the ISA for the American Centrifuge Plant - HALEU Demonstration. The general use of the term ACP in the remainder of this chapter is intended to refer to both the commercial ACP operation and the HALED Demonstration. HALEU Demonstration will be specifically noted, as necessary, when the context is uniquely applicable to HALEU Demonstration. 9.1 Environmental Report The regulatory requirements for an Environmental Report are contained in 10 Code of Federal Regulations (CFR) Part 51 . The NRC promulgated these regulations to implement the National Environmental Policy Act of 1969, which requires an assessment of the environmental impacts associated with all maj or Federal actions. For licen ing actions that are not categorically excluded, the NRC conducts an independent assessment on the basis of the information submitted in the Environmental Report. 9- 1 I_

License Application for the A merican Centrifuge Plant Proposed Change 2020 An update to the Environmental Report for the American Centrifuge Plant meeting the requirements of 10 CFR 51.45 was prepared and is submitted for review as part of this license application as document LA-3605-0002, Environmental Report for the American Centrifuge Plant,. Revision 17. 9.2 Environmental Protection Measures 9.2.1 Radiation Protection Program The ACP Environmental Radiation Protection Program is based on the following policies:

• The dose to members of the public resulting from gaseous emissions and liquid effluents shall be maintained in accordance with the ALARA principle and below legal limits.
• It is the responsibility of each employee to conduct their activities in such a manner so as to prevent or minimize the discharge of radioactive materials to the environment, and to report any unusual or excessive discharge of such material.

9.2.1. 1 Radiological (As Low As Reasonably Achievable) Goals for Efflu ent Control The ACP maintains and uses gaseous and liquid effl uent treatment systems, as appropriate, to maintain releases of radioactive material to unrestricted areas below the limits specified in 10 CFR 20.1301 and 40 CFR Part 190, and in accordance with the ALARA policy described below. Gaseous effluent control systems are also used to maintain releases of radioactive material to unrestricted areas below the dose constraint in 10 CFR 20.1101 and the dose limit in 40 CFR 61.92. Unrestricted areas are those areas beyond the DOE reservation boundary and to which any member of the public has unrestricted access . The ALARA goal for airborne radioactive releases from the ACP is five percent of the NRC constraint (10 CFR 20.1101) and Environmental Protection Agency (EPA) limit (40 CFR 61.92), or an annual Total Effective Dose Equivalent (TEDE) of 0.5 millirem (mrem) to the most exposed member of the public, calculated as described in Section 9.2.2.1.2. This is also less than 15 percent of the most restrictive limit under 40 CFR Part 190, based on site experience. The ALARA goal for waterborne radioactive releases from the ACP is ten percent of the airborne ALARA goal, or an annual TEDE of 0.05 mrem to the most exposed member of the public. This is equivalent to 0.05 percent of the 10 CFR 20.1301 limit on annual public dose. This goal is based on the assumption that: 1) the effluent limits in 10 CFR Part 20, Appendix B , Table 2 are equivalent to an annual public dose of 50 mrem ; and 2) maximum public exposure occurs in the Scioto River with a dilution factor of at least 100: 1. The principal liquid effluent stream from the ACP discharges directl y to the ri ver via a buried pipeline and the actual dilution factor between 9-2

License Application/or the American Centrifuge Plant Proposed Change 2020 site efflu ents and the Scioto Ri ver is on the order of5,000: 1. Con equently, the econd a umption should be very conservative. The ACP also establishes Baseline Effluent Quantities (BEQs) for each monitored vent and monitored outfall and compares measured weekly effluents to these BEQs. Weekly effluents that are less than the BEQs cannot approach the dose limit in 10 CFR 20.1301 or the dose constraint in 10 CFR 20.1101. Weekly effluents that are not less than the applicable BEQs are evaluated as described in Sections 9.2.2.1.3 and 9.2.2.2.3 of this chapter, to determine whether they may cause the ACP to exceed regulatory limits or the ALARA goals. Notifications and corrective actions are implemented as described in those sections and Table 9.2-1. 9.2.1.2 Effluent Controls 9.2.1.2.1 Control of Airborne Effluents X-3346 Feed and Withdrawal Building The X-3346 operations are applicable to commercial ACP operations only and are not used in the HALEU Demonstration . The Feed Area of the X-3346 building sublimes uranium hexafluoride (UF6) for feed to the enrichment process and sublimes and desublimes UF6 for blending/ transfer operations between cylinders and transfer of UF6 material to customer cylinders for shipment as described in Section 1.1 of this license application and contains a variety of potential sources for radioactive effluents, both as gaseous UF6 and particulate uranyl fluoride (U0 2F2). These sources are vented to the atmosphere through an evacuation system located in the Withdrawal Area of this building, which has separate subsystems to control gaseous and airborne particulate effluents. Both sub-systems exhaust to a continuously monitored combined vent. The Withdrawal Area of the X-3346 building withdraws and desublimes both the product and tail streams from the enrichment process as described in Section 1.1 of this license application and contains a variety of potential sources for radioactive effluents, both as gaseous UF6 and particulate U0 2F2. These sources are vented to atmosphere through an evacuation system located in the Withdrawal Area. There are separate evacuation systems, which have separate subsystems to control gaseous and airborne particulate effluents. The cylinder burping/heeling system , feed ovens, freezer/sublimers, cold boxes, sampling system, and process piping in these areas are manifolded to the gaseous effluent side of their respective evacuation systems. Gases evacuated from process systems, which can contain high concentrations of UF6, are processed through cold traps to desublime the UF6 and separate it from the non-UF6 gases. Residual gases leaving the cold trap have a very low concentration of UF6, which is further reduced by passing the gas through an alumina trap. When an evacuation system cold trap becomes full , it is val ved off from the vent and its contents sublimed to a dump cylinder so the material can be fed to the enrichment plant. The cold traps can be bypassed to allow rapid evacuation of a volume that does not contain radioactive material. The alumina traps cannot be bypassed. 9-3

License Application for the A merican Centrifuge Plant Proposed Change 2020 Cylinder connections and disconnections have the greatest potential for small releases of UF6 to the workspace. UF6 released in this manner reacts quickly with ambient humidity to form U02F2. A WISP system is used to collect these gases from fixed operational points (e.g. feed oven cylinder connection) through the evacuation system. Portable gulper systems are used to collect any small release of material during maintenance operations. Gulper systems utilize a flexible hose or hood to evacuate the air in the immediate area where the connection is being made or broken. The captured gases are passed through a roughing filter followed by a High Efficiency Particulate Air (HEPA) filter to collect the U0 2F2 particulate. The portable gulpers are exhausted within the building in which they are being used. The effluents from the WISP sub-systems are combined and vented to the atmosphere through a common vent after each subsystem associated with the evacuation system has removed the uranium. The vent is equipped with continuous gas flow monitoring instrumentation with local readout as well as the analytical instrumentation required to continuously sample, monitor and to alarm UF6 breakthrough in the effluent gas stream. The continuous vent monitor/sampler is described in Section 9.2.2.1 of this chapter. Ventilation air in the X-3346 is monitored under the Radiation Protection Program as described in Section 4.7 of this license application. Environmental Compliance personnel review summaries of the monitoring data at least quarterly to verify that ventilation exhausts are insignificant as defined in NUREG-1520, Standard Review Plan for lhe Re-Piew <d" a /,u:e+1'tf! App-lu.: alion for a Fuel Cycle Facilitiest' License Applications. Revision 2 (SRP) (i.e., less than 3 x 10- 13 microcuries per milliliter [µCi /mL] uranium). X-3001 and X-3002 Process Buildings The process buildings house the operating centrifuge~ machines that separate the UF6 into enriched product and depleted tails as described in Section 1.1 of this license application and contain a limited variety of potential sources for radioactive effluents, primarily as gaseous UF6. These sources are vented to atmosphere through either the Purge Vacuum (PV) or Evacuation Vacuum (EV) Systems. Both systems exhaust to a common continuously monitored vent. Enrichment equipment operates at sub-atmospheric pressures. Equipment operation requires the removal of any air that leaks into the process. The PV/EV Systems are used to remove air in the enrichment equipment. Since the air may contain traces ofUF6 the gas removed by these systems is passed through a shared set of alumina traps prior to venting. The PV/EV systems in each half (north and south) of each process building are manifolded to one process building vent. For HALEU Demonstration, the PV/EV system is only in the north half (Train 3) of the X-3001 Process Building. Additionally, for HALEU, there is also a bank of Sodium Fluoride (NaF) traps to facilitate removal of UF6 inventory from the cascade should it be necessary . The discharge of the NaF traps is subsequently routed to PV/EV systems. Each process building vent is equipped with continuous gas flow monitoring instrumentation with local readout, as well as analytical instrumentation to continuously sample, monitor, and alarm UF6 breakthrough in the effluent gas stream. The continuous vent monitors/samplers are described in Section 9.2.2.1 of this chapter. 9-4

License Application f or the A merican Centrifuge Plant Propo ed Change 1020 Valving and piping allow the EV systems to bypass the ch~mical traps du6ng-the initia~ pump down of machines that have n~Jt been previously exposed to l lh, Th-is reduces the chances e-f-desorb-iRg-prevK>Usly trapped-llf(+ ff-om the traps-:------Gthen,,.ise, the EV systems-ttir-eughfwt-w-i-U 1}frSS H-1reugh the chemical t-raps along ,... ith-PV system throughput Ventilation air in the process buildings is monitored under the Radiation Protection Program as described in Section 4.7 of this license application. Environmental Compliance personnel review summaries of the monitoring data quarterly to verify that ventilation exhausts are insignificant as defined in the SRP (i .e., less than 3 x 10-13 µCi/mL uranium). X-3344 Customer Services Building The X-3344 operations are applicable to commercial ACP operations only and are not used in the HALEU Demonstration. The Customer Services Building liquefies UF6for quality control sampling of UF6 material as described in Section 1.1 of this license application and also contains multiple potential sources for radioactive effluents, both as gaseous UF6 and particulate U02 F2. These effluents are vented from X-3344 building through piping to an evacuation system in the X-3346 building through a continuously monitored combined vent. The autoclaves, sampling manifolds, sample containers and piping and process piping are manifolded to the gaseous effluent side of the appropriate WISP evacuation system . Gases evacuated from process systems, which can contain high concentrations of UF6, are processed through cold traps located in the X-3346 Withdrawal Area to desublime the UF6 and separate it from the non-UF6 gases. Residual gases leaving the cold trap have a very low concentration of UF6, which is further reduced by passing the gas through an alumina trap. When an evacuation cold trap becomes full , it is valved off from the vent and its contents sublimed to a cylinder. The evacuation cold traps can also be bypassed to allow rapid evacuation of a volume that does not contain significant amounts of radioactive material. The alumina traps cannot be bypassed. Cylinder connections and disconnections have the greatest potential for small releases of UF6 to the workspace. UF6 released in this manner reacts quickly with ambient humidity to form U02F2 . A WISP system is used to collect these gases from fixed operation points (e.g. feed oven cylinder connection) through the evacuation system . Portable gulper systems are used to collect any small release of material during maintenance operations. Gulper systems utilize a flexible hose or hood to evacuate the air in the. immediate area where the connection is being made or broken. The captured gases are passed through a roughing filter followed by a HEPA filter to collect the U02F2 particulate. The portable gulpers are exhausted within the building in which they are being used . The effluents from the WISP sub-systems are combined and vented to the atmosphere through a common vent after each sub-system associated with the evacuation system in the X-3346 building has removed the uranium . The vent is equipped with continuous gas flow monitoring instrumentation with local readout as well as the analytical instrumentation required to continuously sample, monitor and to alarm UF6 breakthrough in the effluent gas stream . The continuous vent monitor/sampler is described in Section 9.2.2.1 of this chapter. 9-5

license Application for the American Centrifuge Plant Proposed Change 2020 Ventilation air in the X-3344 building is monitored under the Radiation Protection Program as described in Section 4.7 of this license application. Environmental Compliance personnel review summaries of the monitoring data at least quarterly to verify that ventilation exhausts are insignificant as defined in the SRP (i.e., less than 3 x 10-13 µCi /mL uranium) . X-3012 Process Support Building The X-3012 building provides process control functions and maintenance support as described in Section 1.1 of this license application. The ACR provides central operating functions to monitor and control HALEU Demonstration processes in the X-3001 process building. 8eme small quantities of uranium materials may be present in this building associated with operation of mass spectrometers, maintenance activities, or other activities. from ti me--lo-tttll-e;----<<mta-mtAa-t-ed compnnents may be serviced in the maintenance shops tn the X--3-012 building. Components requiring repair or examination that have been in service will be opened using -ilj)[}ropriate perseA-ttel--protec-tive--eqt1ipment fP--P-et aoo mai, al56----indu<le---engineered-loc-al-ven-ti-lat.f.en-~y-stem-s to carmtre-a>>y- res<<itial uF-amum Ventilation air in the X-3012 building is monitored under the Radiation Protection Program as described in Section 4.7 of this license application . Environmental Compliance personnel review summaries of the monitoring data quarterly to verify that ventilation exhausts are insignificant as defined in the SRP (i.e., less than 3 x 10-13 µCi /mL uranium) . X-7725 Recycle/Assembly FndHtyBuilding; X-7726 Centrifuge Train ing and Test Facility; and X-7727H lnterplant Tran sf er Corridor Centrifuges are assembled and may be disassembled for repair or inspection as described in Section 1.1 of this license application in either the X-7725 building or X-7726 facilityiei.. The extent to which a centrifuge is disassembled depends upon the nature of the fault. Centrifuges requiring repair or examination that have been in service will be opened using appropriate PPE, and may also include engineered local ventilation systems to capture any residual uranium . As described in Section 1.1 of this license application, some completely assembled centrifuge~ machine-, are tested with UF6 in the Gas Test Stands in the commercial ACP operation. In the HALEU Demonstration, the X-7725 building will only be used for temporary storage and for interior transport to and from the X-7726 facility . This is a separate room within X-7725 facility building with its own ventilation and emission control system. UF6 for the test stands is supplied from a small cylinder within this room . Exhaust from the test stands passes through alumina traps to a continuously monitored vent. The vent is equipped with continuous gas flow monitoring instrumentation with local readout, as well as the analytical instrumentation required to continuously sample, monitor, and to alarm UF6 breakthrough in the effiuent gas stream . The continuous vent monitor/sampler is described in Section 9.2.2.1 of this chapter. Ventilation air in both the X-7725 building and X-7726 facili tyies is monitored under the Radiation Protection Program as described in Section 4.7 of this license application. Environmental Compliance personnel review summaries of the monitoring data quarterly to verify 9-6

License Application fo r the American Centrifuge Plant Proposed Change 2020 that v ntilation exhausts are insignificant as defined in SRP (i .e., less than 10-13 µCi /mL uranium). As described in Section 1.1 , the X-7727H corridor is used only to provide indoor transport for sealed components (e.g. , individual centrifuges) between the X-7725 facility building and the process buildings and is closed off from these buildings except when such transport is actually occurring. Consequently, the X-7727H corridor is never directly exposed to a source of gaseous uranium although it does have some air transfer from the process buildings and X-7725 facihtybuilding. At worst, the airborne uranium concentration in the X-7727H corridor will not exceed that in the process buildings or X-7725 facility building. This is insignificant as defined in the SRP (i .e., less than 3 x 10- 13 µCi/mL uranium). Waste Management The ACP obtains waste management services for various radiological and non-radiological materials. The radiological waste management services are obtained from a qualified provider licensed/certified by the NRC or an agreement state. Laboratory Services The ACP obtains analytical services for various radiological and non-radiological materials. The radiological analytical services are obtained from a qualified laboratory licensed/certified by the NRC or an agreement state. 9.2.1.2.2 Control of Liquid Effluents The centrifuges and PY/EV vacuum pumps are cooled by a closed-loop Machine Cooling Water (MCW) system to minimize the amount of water potentially contaminated by uranium. There is no routine blowdown from the MCW system . Waste heat from the MCW system is discharged via heat exchangers to the Tower Water Cooling (TWC) system , which is cooled by a single cooling tower. Waste heat from the cold trap refrigeration systems in X-3346 and X-3356 buildings is also discharged to the TWC system . Currently, the TWC discharges its blowdown to the GDP Recirculating Cooling Water (RCW) system under a service agreement, which in turn discharges its blowdown directly to the Scioto River via an underground pipeline (National Pollutant Discharge Elimination System [NPDES] Outfall 004). The RCW system does not provide any treatment of the TWC blowdown; it simply provides a convenient pathway to a suitable permitted discharge point. At some point in the future, DOE is expected to decommission and decontaminate the GDP, including the RCW system . By that time, the TWC blowdown will have to be modified to bypass the RCW system and discharge directly to the RCW discharge pipeline. The schedule for this has not been established. There should be no licensed material in the TWC blowdown . In the interim, the GDP RCW system has ample capacity to accept the TWC effluent without either physical modification or adju tment to its discharge limit Tl=ie G9P RCW svstem consists of three setiuential loops, which have design capacities of 48,000 gallon per minute (X-626 ), 153,000 gallons per minute (X-610), and 489,000 gallons per minute (X-633) Current flow 9-7

license Application/or the A merican Centrifuge Plant Proposed Change 2020 rates in these loops are only~ 000 17 000 and 20 000 gallons per minute ( 17 percent, 11 percent, and 4 percent of design) and are not expected to increase The TWC system is currently fitted with three 10,800 gallon per minute pumps and even assuming a conservative blowdown rate of ten percent, TWC blowdown flow will be no more than 3,240 gallons per minute. A-dd-i-ng-trus--t:o-t-lle current flow-; in the GDP R{'W loops gives ma imum flows that are only 23 percent, 13 percent, and 5 percent of the respective design capacities of the three loops Discharges from the RCW System are monitored by an automated sampler, which collects a weekly composite sample of the liquid effluent for radiological analysis as well as sample(s) for NPDES-mandated analyses. This data is available to the ACP as assurance that no unanticipated discharge of licensed material has occurred. Leakage from the MCW system and incidental spills of water elsewhere in the ACP, are collected by the Liquid Effluent Collection (LEC) system. The LEC system consists of a set of drains and underground collection tanks for the collection and containment of leaks and spills of chemically treated water. The drains are located throughout the ACP. The tanks have a capacity of 550 gallons (gal) each and are monitored by liquid level gauges mounted above grade on pipe stands. Water accumulated in the LEC tanks is sampled and analyzed prior to disposal. If the contents meet the requirements of 10 CFR 20.2003, they may be pumped to the reservation sanitary sewer system . Otherwise the tank contents will be containerized for off-site disposal. An integrity assurance plan developed by Engineering assures that the tanks are not leaking as the ACP take possession of them . This plan will be completed and will be added to this application as a reference prior to the NRC ' s pre-operational inspections. Following completion of this integrity assurance plan, inventory monitoring of the tank contents is used to detect leaks from the LEC System. Storm water runoff from the ACP area, along with some once-through cooling water (sanitary water), drains to a pair of holding ponds.

• The X-2230 West Holding Pond (NPDES Outfall 012) provides a quie cent zone for settling suspended solids, dissipation of chlorine, and oil diversion and containment.

The pond discharges to the same unnamed tributary of the Scioto River as X-2301-5. An automated sampler collects a weekly composite sample of the liquid effluent for radiological analysis as well as sample(s) for NPDES-mandated analyses.

• The X-2230M Southwest Holding Pond (NPDES Outfall 013) provides a quiescent zone for settling suspended solids, dissipation of chlorine, and oil diversion and containment. The pond discharges to an unnamed tributary of the Scioto River. An automated sampler collects a weekly compo ite sample of the liquid effluent for radiological analysis as well as sample(s) for NPDES-mandated analyses.

The X-6002 Recirculating Hot Water Plant, which provides heat to multiple buildings at the ACP, contains a particulate separator (NPDES Outfall 613) that removes suspended olid from the water used in the plant. Samples from the blowdown of the particulate separator are taken prior to its discharge to the DOE reservation sewage treatment plant (GDP NPDES Outfall 003). 9-8

License Application fo r the American Centrifuge Plant Proposed Change 2020 Outdoor c linder stora e ads will be u ed in the commercial ACP o eration; however all cylinder storage will be maintained inside the X-3001 facility in the HALEU Demonstration. Most of the ACP cylinder storage pads are within the drainage of the X-2230M and X-2230N Holding Ponds. The ACP also uses cylinder storage pads on the north end of the reservation (X-745G-2 and X-745H). The ACP conducts an inspection and maintenance program for its UF6 cylinders to ensure that no licensed material is released to the storage pads in accordance with USEC-651 , Uranium Hexafluoride: A Manual ofGood Handling Practices. Storm water runoff from the north pads drains to holding ponds in accordance with a service agreement. Holding pond effluents are currently continuously monitored with automated samplers in accordance with the NRG-certified GDP environmental protection plan discussed in (EOEF-FBP-001, Basis for Interim Operation of Former Uranium Enrichment Facilities (FUEF) at the Portsmouth Gaseous Diffusion Plant. Piketon, OHGIBJ:Hef ~. I, USF('--G2, Applieati-0n fef --l:J.rn+ed-- -Stales- Nttc-1-ea-r Regulak:wy Commission Ce11ification , Portsmouth Gaseous Oiffusion Plant, Safety Analysis Repm1). This data is available to ACP environmental personnel as assurance that no unanticipated discharge occurred. 9.2.1.3 As Low As Reasonably Achievable Reviews and Reports to Management Action levels for control of both gaseous and liquid radioactive effluents from the ACP have been established based on the ALARA philosophy . The action levels described in Table 9.2-1 ensure operational control system deficiencies are documented and acted upon in a responsible manner and in a timeframe to remain well within the regulatory limits and below ALARA goals. The required actions described in Table 9.2-1 include the analyses of trends in release data, evaluations of the probable impact of the releases and an assessment of the need for additional effluent controls to meet the ALARA goals. The Senior Shift Supervisor is responsible for assuring that action levels are acted upon. The BEQs used in Table 9.2-1 is the maximum effluent expected under normal operation . BEQs have been established by the ACP environmental personnel and the responsible building management for every continuously monitored radiological vent and liquid discharge point to unrestricted areas. These BEQs are reviewed annually, at a minimum, by environmental personnel , the responsible building management and the ACP ALARA Committee to ensure the principles described in the ACP ' s ALARA policy are followed . This review also includes analyses of trends in radioactive effluents and environmental monitoring data. The results of this review are reported to the Production Support Manager and other senior management as described in Chapter 4.0 of this license application. The specific values of the BEQs are listed in Table 9.2-2. The liquid release points are existing discharges and, while the ACP does not increase releases beyond historic levels, it does not decrease them either. Therefore, the liquid BEQs in Table 9.2-2 are based on GDP historic release rates. 9-9

License Application for rhe American Centrifuge Plant Proposed Change 2020 9.2.1.4 Waste Minimization Radioactive waste minimization and pollution prevention acti vities are coordinated by ACP environmental compliance and waste management personnel with the support of senior management. Individual waste streams are identified and characterized based on process knowledge, routine radiation surveys as described in Chapter 4.0 and laboratory analysis, as needed . Generation of individual waste streams and waste management costs are tracked through a formal Request-for-Disposal database system administered by waste management personnel and the annual budgeting process. Waste generating activities are evaluated for waste mm1m1zation opportunities with emphasis on those that generate hazardous wastes, low-level mixed wastes (LLMW), and low-level radioactive wastes (LLRW). Both LLMW and LLRW waste generation is inherently reduced in the ACP by the fact that the process operates under a high vacuum, which prevents radioactive material from escaping. Equipment that must be removed for maintenance is evacuated to the rest of the process first. The routine radiation surveys described in Chapter 4.0 of this license application verify that there is no spread of contamination within or out of the ACP . Hazardous waste generation is minimized by minimizing the procurement and use of hazardous substances. Waste that is generated is treated to the extent practical to reduce the volume, toxicity, or mobility before storage or disposal. The Licensee provides annual employee training that includes waste minimization information and encourages employee suggestions. The Licensee provides environmental and waste management professionals with opportunities to attend offsite training and conferences for the purpose of seeking and exchanging technical information on waste minimization. Waste minimization recommendations are evaluated by waste management and environmental compliance personnel and implemented, as appropriate, by waste management, materials procurement (for hazardous materials), and operations personnel. This applies to ACP operations, associated support operations, and ACP subcontractors that generate waste. 9.2.2 Effluent and Environmental Monitoring Based on historic GDP experience and operating plans, the radionuclides anticipated to be present in ACP gaseous effluents are 234 U, 235 U, and 238 U . The intention is to not introduce feedstock contaminated with significant concentrations of other nuclides into the process. Feed material that meets the American Standards for Testing and Materials (ASTM) specification for recycled feed may be used in the commercial ACP operation, which may contain radionuclides such as 236 U and Technetium (99 Tc). Feed material for the HALEU Demonstration could also be UF6 meeting the ASTM UF6 product standard. produced in former enrichment operations external to ACP (e .g. GDP operations). Based on historic GDP experience 99Tc may eventually appear in some ACP gaseous effluents. The radionuclides anticipated to be present in ACP liquid effluents 9-IO

license Application f or the American Centrifuge Plant Proposed Change 2020 are 2 4U, 235 U, 238 U, and 99Tc, due to historic contamination of the re ervation. Consequently, ACP effluents will be analyzed for these four nuclides as described in the applicable sections below. 9.2.2.1 Airborne Effluent Monitoring 9.2.2.1.1 Anticipated Effluent Levels The maximum anticipated gaseous effluents from the ACP have been modeled using the EPA-approved and distributed dispersion model, CAP88-PC, and reservation meteorological data from calendar years 1998-2002. The results are summarized in Table 9.2-3 . The maximum gaseous effluent anticipated under normal operations is 1.1 millicuries (mCi) of uranium over a week, or up to 0.057 curie (Ci) per year. The maximum exposed individual (MEI) for the ACP is located in the south-southwest sector of the reservation boundary. The projected maximum airborne concentration of total uranium due to ACP operations is only 3.2x10- 15 µCi /mL, with an associated TEDE of 0.33 mrem . The uranium concentration is roughly three orders of magnitude lower than the applicable values in 10 CFR Part 20, Appendix B, Table 2. The projected TEDE due to ACP operations contributes roughly 66 percent to the ALARA goal given in Section 9.2.1.1 of this chapter, even assuming the average annual emission rates are equal to the maximum weekly emission rates. Average emission rates are expected to be much lower. It is noted that HALEU Demonstration isotopic distributions may vary from these analyses performed for the commercial ACP operation, due to the use of enriched product as feed to the HALEU Demonstration. However, the HALEU Demonstration is limited to a cascade of only 16 centrifuges: whereas the original analyses for the commercial ACP operations were applicable to cascade containing thousands of centrifuges deployed in a cascade configuration with up to 3.8 million SWU/year. The commercial ACP analyses referenced in this section will conservatively bound any small variations in isotopic distribution that might be applicable to the HALEU Demonstration. 9.2.2.1.2 Demonstration of Compliance Characterization of the radiological consequences of radionuclides released to the atmosphere from the ACP is accomplished by comparing measured emissions to the values in 10 CFR 20, Appendix B, Table 2 and the requirements of IO CFR 20.1301, as applicable. The results are incorporated into emiannual reports submitted to the NRC in accordance with 10 CFR 70.59. Characterization of the radiological consequences of radionuclides released to the atmosphere from the ACP is also accomplished by annually calculating the TEDEs to the maximally exposed person and to the entire population residing within 80 kilometers (km) (50 miles) of the plant. This approach is mandatory under the EPA regulations at 40 CFR Part 61 and has been accepted by the NRC for previous uranium enrichment operations at the reservation . The annual National Emission Standards for Hazardous Air Pollutants (NESHAP) Report includes the reservation identification, a description of plant operations (whether included under this license or not) during the previous year, the amount of radionuclides released to the atmosphere duri ng the previous year, and the calculated TEDE to the most exposed member of the public. 9-11

License Application for the American Centrifuge Plant Proposed Change 2020 Annual radionuclide releases to air are measured by the continuous vent sampler , as described in Section 9.2.2.1.3 of this license application, or estimated in accordance with guidance in 40 CFR Part 61, Appendices D and E . Atmospheric dispersion of the releases is modeled and the consequent public radiation dose is estimated using the EPA approved computer models in accordance with EPA guidance. An annual report summarizing the atmospheric releases and the dose assessment results is submitted in accordance with 40 CFR Part 61 , Subpart Hand EPA guidance. In accordance with EPA requirements, the reported public dose includes gaseous radioactive effluents from the DOE reservation. The dose calculations are made using either the original CAP88 package of computer codes or the CAP88-PC package distributed by the EPA. The CAP88/CAP88-PC packages contain an EPA approved version of the AIRDOS-EPA and DARTAB computer codes and the ALLRAD88 radionuclide data file. The AIRDOS-EPA computer code implements a steady-state, Gaussian plume, atmospheric dispersion model to calculate concentrations ofradionuclides in the air and on the ground based on radionuclide releases to the atmosphere and annualized meteorological data. It then uses Regulatory Guide 1.109, Calculation ofAnnual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance ,,vith 10 CFR Part 50, Appendix I (October 1977), food-chain models to calculate radionuclide concentrations in foodstuffs (e.g. , vegetables, meat, milk) and subsequent intakes by individuals. The DART AB computer code then uses these calculated uptakes and radionuclide data from the ALLRAD88 data file to calculate annual radiation doses to members of the public. The annualized meteorological data used in the calculations consist of joint frequency stability array distributions of wind direction , wind speed, and atmospheric stability that are prepared from data collected from the reservation meteorological tower. Data from the National Weather Service may be used in lieu of or to supplement reservation meteorological data in the event the on-site tower becomes inoperable. The reservation has a consistent annual pattern of low-level southwesterly winds predominating over the year. During the winter season, northeasterly winds are common though. This is largely attributable to the channeling effect of the hills and ridges on either side of the reservation, which runs roughly southwest to northeast. Distances to the nearest residences are taken from U.S Geological Survey maps and population distributions are from the 2000 census data. EPA published default values for other off-site parameters (such as local crop productivity) are used in the AIRDOS-EPA model and, in accordance with EPA recommendations; rural patterns for food sources (i.e., home grown versus local production versus national supermarket chains) are assumed. It is noted that HALEU Demonstration isotopic distributions may vary from these analyses performed for the commercial ACP operation, due to the use of enriched product as feed to the HALEU Demonstration. However, the HALEU Demonstration is limited to a cascade of only 16 centrifuges; whereas the original analyses for the commercial ACP operations were applicable to cascade containing thousands of centrifuges deployed in a cascade configuration with up to 3.8 million SWU/year. The commercial ACP analyses referenced in this section will conservatively bound any small variations in isotopic distribution that might be applicable to the HALEU Demonstration. 9-12

License Application for the A merican Centrifuge Plant Proposed Change 2020 9.2.2.1.3 Monitoring of Gaseous Release Points Each process vent in the X-3001 , X-3002, X-3346, and X-7725 buildings has gas flow monitoring instrumentation with local readout as well as analytical instrumentation to continuously sample; monitor and to alarm UF6breakthrough in the effluent gas stream . The locations of these vents are shown in Figure 9.2-1. The continuous vent sampler draws a flow proportional sample of the vent stream through two alumina traps in series by way of an isokinetic probe. Both vent and sampler flows are monitored by the sampler's electronic controller. The controller adjusts a control valve in the sample line to maintain a constant ratio between the vent and sample flows. The flow instruments are calibrated at least annually. The primary sample trap is equipped with an automated radiation monitor to conti nuously monitor the accumulation of uranium in the sampler. This radiation monitor provides the real-time indicator of effluent levels for operational control of the gaseous effluent control systems. Detailed effluent calculations are based on laboratory analysis of the collected samples. Each vent sampler has two traps permanently dedicated to each trap position, with one in-service and the other either being processed or standing by to replace the in-service trap. Normally, the primary sample traps are replaced weekly and the secondary traps are replaced quarterly . In the event of an unplanned or seriously elevated release, the involved sampler traps are collected for immediate analysis as soon as the situation has stabilized. Alternatively, the sampling period may be extended, provided the sampler is operating continuously while the vent is operating. A hydrated alumina is used in the vent samplers to convert absorbed UF6 to U02F2 . The U02F2 does not easily separate from the alumina, so no special handling is necessary to avoid loss of uranium between sample collection and analysis. Annually, the sampler tubing and traps are also replaced and rinsed, and the rinsates analyzed for the same parameters as the alumina. Vent samples are analyzed for 234U, 235 U, 238U, and 99 Tc as described in Section 9.2.2.5 of this chapter. GDP experience in uranium enrichment has shown that these three uranium isotopes account for more than 99 percent of the public dose due to uranium emissions. 99 Tc is a fission product that has contaminated much of the fuel cycle. Feed material that meets the ASTM specification for recycled feed may be used in the commercial ACP operation, which may contain additional radionuclides (i .e., 236U and 99 Tc). Feed material for the HALEU Demonstration could also be Uf 6 meeting the ASTM UF6 product standard, produced in former enrichment operations external to ACP (e .g. GDP operations). Based on GDP historic experience 99 Tc may eventually appear in some ACP gaseous effluents. The ACP therefore monitors process vent samples for technetium as a precautionary measure. Weekly gaseous effluents are calculated based on the primary trap analytical results and measured flows . These are compared to the action levels in Table 9.2-1 to determine whether gaseous effluents are threatening to exceed regulatory limits or ALARA goals. The weekly effluents are also accumulated to provide source terms for the annual public dose assessment required under 40 CFR Part 61. Quarterly and annual corrections to the accumulated weekly effluents are calculated based on the secondary trap and rinsate anal yses, respectively, to complete the source terms. Anticipated radionuclide concentrations in ventilation exhausts from occupied areas are insignificant as defined in the SRP. Radionucl ide concentrations in room air are monitored as described in Section 4.7 of this license application. The results are reviewed by environmental 9-13

License Application f or the A merican Centrifuge Plant Proposed Change 2020 engineers at least quarterly to verify that airborne concentrations are less than ten percent of the applicable values in 10 CFR Part 20, Appendix B, Table 2. In the event of a radionuclide release outside the effluent monitoring system, the activity of the release will be estimated based on available data and engineering calculations (i .e., inventory data and mass balances). 9.2.2.1.4 Action Levels Action levels for control of gaseous radioactive effluents from ACP operations have been established based on the ALARA ppilosophy . The action levels described in Table 9.2-1 ensure operational control system deficiencie are documented and acted upon in a responsible manner and in a timeframe to remain well within the regulatory limits and below ALARA goals. The BEQs used in Table 9.2-1 are the maximum effluents expected under normal operating conditions. BEQs have been established for every continuously monitored radiological vent. The specific BEQ values established for the monitored ACP vents are listed in Table 9.2-2. 9.2.2.1.5 Other Permits and Licenses New air pollutant sources or modifications of existing sources in the State of Ohio are required to have a Permit-to-Install (PTI) from the Ohio EPA prior to installation of the source. The ACP therefore needs PTis for its process vents . Within one year of the PTI being issued, the ACP also needs to apply to the Ohio EPA for a modification to its Title V permit to incorporate the entire ACP into the existing permit. The Title V permit supersedes the PTI once it is modified . Sources of airborne radionuclides at DOE-owned plants are covered by an EPA Permit-By-Rule issued under 40 CFR Part 61 , (NESHAP) Subpart H This rule imposes a limit on airborne effluents of 10 mrem/year to the MEI, which applies to the entire reservation regardless of who "owns" any individual source within the reservation . The rule also requires an annual report, submitted by June 30 of the following year, detailing the processes at the reservation, the airborne effluents from each source, and annual TEDE to the MEI as calculated by a method approved by the EPA. A copy of this report is available to NRC as described in Section 9.3.2 of this chapter. Also, under the NESHAP rule, new or modified sources of airborne radionuclides at DOE-owned plants are required to have prior Permi ssion to Construct from EPA unless the change has a projected maximum public TEDE of less than 0.1 mrem/year. This will be necessary for the ACP since it has the potential to exceed this threshold . 9.2.2.2 Liquid Effluent Monitoring 9.2.2.2.1 Anticipated Effluent Levels Anticipated routine radioacti ve eftluents from the ACP are expected to be minimal. The bulk of liquid radioacti ve effl uents from a uranium enrichment plant are decontamination and cleaning solutions. Centrifuges will not be routinel y changed out, but routine maintenance such as instrument repair or repair to the PV/EV systems occurs. There are also maintenance acti vities 9-14

license Application for the A merican Centrifuge Plant Proposed Chang e 2020 that require cleaning and/or decontamination. The ACP uses dry decontamination methods to the extent practical to minimize liquid releases. Spills are accumulated in the LEC system. The LEC collection tanks are sampled and analyzed for radioactive constituents prior to being emptied. If analysis indicates that LEC tank contents meet the criteria of 10 CFR 20.2003, the contents may be discharged to the reservation sanitary sewer. Otherwise, LEC tank contents will be containerized for disposal off-site. These are the only anticipated liquid discharges of licensed material from the ACP. Actual sanitary wastewater (i .e., excluding LEC discharges) from the ACP is not anticipated to contain licensed radioactive material. Any licensed material that may be discharged will be released in accordance with the requirements of 10 CFR 20.2003 . Consequently, anticipated radionuclide concentrations in the sanitary wastewater itself are anticipated to be insignificant as defined in the SRP. There are no anticipated radioactive effluents from the MCW system, since it is a closed-loop system with no routine blowdown. The TWC system is a standard industrial recirculating water system with a routine blowdown stream to control the accumulation of solids within the cooling water. The TWC does not come in contact with licensed material unless there is leakage from the process to the MCW and then from the MCW to the TWC. This is unlikely since the MCW lines are on the outside of the centrifuge casings. Consequently, radionuclide concentrations in the TWC blowdown are also anticipated to be insignificant as defined in the SRP. Storm water runoff and some once-through cooling water (sanitary water) flows through two holding ponds as described in Section 9.2.1.2.2 of this chapter, then discharges to the Scioto River in accordance with 10 CFR 20.1301. Radioactive materials in these streams are dominated either by naturally occurring radioactive materials or existing contamination from previous reservation operations. ACP effluents are not expected to cause any significant difference from historic release levels, which are insignificant as defined in the SRP. The commercial ACP operation will use cylinder storage pads on the north end of the plant (X-745G-2 and X-745H) . All cylinder storage will be maintained inside the X-3001 facility in the HALEU Demonstration. A cylinder inspection and maintenance program ensures that no licensed material is released to the storage pad. Nevertheless, runoff from the pads may drain to the existing X-230L North Holding Pond. This pond is maintained and monitored in accordance with 10 CFR 20.1301 and the monitoring data is available to the ACP. ACP operations are not expected to have any measurable impact on these ponds. Anticipated radioactive releases from these points are summarized in Table 9.2-4, along with the limits from 10 CFR Part 20, Appendix B, Table 2 for comparison. The anticipated discharge levels are at least one order of magnitude below the Table 2 limits even before they mix with the Scioto River. Activity concentrations in the table are based on monthly grab samples from 1995 through 2000 for the X-2230M and X-2230N holding ponds. Activity concentrations for the other ACP-influenced continuous discharges are based on weekly composite samples from 9-15

license Application for the A merican Centrifuge Plant Proposed Change 2020 1998 through 2002. Activity concentrations for the LEC system are based on the effluent being characterized prior to discharge. No other ponds or impoundments at the ACP manage special nuclear material (SNM) and since the concentrations involved are well below the 10 CFR Part 20, Appendix B discharge limits, leakage to the soil is not a concern. The only underground tanks that potentially manage SNM are the LEC System described in Section 9.2.1.2.2 of this chapter. Inventory monitoring will be used to detect leakage from these tanks. 9.2.2.2.2 Demonstration of Compliance Characterization of the radiological consequences of radionuclides released in liquid effluents from the ACP is accomplished by comparing measured concentrations to the values in 10 CFR Part 20, Appendix B, Tables 2 and 3 and the requirements of 10 CFR 20.1301 and 10 CFR 20.2003 , as applicable. The results are incorporated into semiannual reports submitted to the NRC in accordance with 10 CFR 70.59. Accumulated liquids in the LEC tanks are sampled for uranium and technetium prior to being removed from the tanks. ACP environmental personnel track the analytical results, volumes and disposition of the liquids. LEC liquids that do not meet the requirements of 10 CFR 20.2003 and 10 CFR Part 20, Appendix B, Table 3 are containerized for disposal at a suitable NRC-licensed site. LEC liquids that do meet the requirements of 10 CFR 20.2003 and 10 CFR Part 20, Appendix B, Table 3 may be either containerized for disposal off-site or discharged to the reservation sanitary sewer. Sanitary wastewater from the ACP (exclusive of LEC effluents) is not expected to be contaminated with licensed material. Therefore, the ACP does not sample or analyze the untreated sewage. The sanitary sewer discharges to a sewage treatment plant located on the reservation that is regulated by both the Nil(' DOE and the OEPA for radionuclides and which does sample and analyze it's effluent for uranium and technetium. This data is available to the ACP and is tracked by ACP environmental personnel against the applicable values 10 CFR Part 20, Appendix B, Table 2. The other liquid effiuent streams from the ACP are monitored as described in Section 9.2.2.2.3 of this chapter and compared to the applicable values in 10 CFR Part 20, Appendix B, Table 2 to demonstrate compliance with 10 CFR 20.1301 . These streams are the TWC blowdown, X-2230M Southwest Holding Pond discharge, and X-2230N West Hording Pond discharge. The ACP will use existing cylinder storage pads at the north end of the plant (X-745G-2 and X-745H) . Runoff from the pads drain to the X-230J-5 Northwest Holding Pond and X-230L North Holding Pond, both of which are sampled and analyzed for uranium and technetium . This data is available to the ACP and these discharges will be tracked against the applicable values in 10 CFR Part 20, Appendix B, Table 2. 9-16

l icense Application for the A merican Centrifuge Plant Proposed Change 2020 9.2.2.2.3 Monitoring of Liquid Release Points There are only two ACP outfalls that discharge directly to publicly accessible areas, the X-2230M and X-2230N holding ponds. The locations of these outfalls are shown in Figure 9.2-2. The TWC blowdown discharges to a utility system (the RCW system) that provides a pathway to the Scioto River but does not provide any radiological treatment. These three discharges are equipped with automated samplers and continuous flow measurement. The flow monitors are calibrated at least annually. The combined discharge of the RCW system, the DOE reservation sewage treatment plant discharge and other reservation holding ponds are also equipped with automated samplers and continuous flow measurement. The data from these outfalls are available to the ACP as a defense in depth. Outfall samples are analyzed for Gross Alpha and Gross Beta Activities, 99 Tc Activity and Total Uranium concentration as described in Section 9.2.2.5 of this chapter. Measurable Gross Alpha Activity is presumed to be due to uranium discharges from uranium enrichment operations, while Gross Alpha Activities below the Minimum Detectable Activity (MDA) are presumed to be due to naturally occurring radioactive materials. The isotopic distribution of enriched uranium discharges (i .e. , 234U, 235 U, and 238U) is estimated to match the measured Gross Alpha Activity based on process knowledge . .99Tc is a fission product that has contaminated much of the national fuel cycle and is present on the reservation . Measured 99Tct:ecl-ttlettum concentrations in reservation outfalls have been falling for several years, but are detected occasionally. The ACP therefore routinely monitors radioactive efiluents for technetium . The only underground tanks in the ACP used to collect material that might contain radionuclides are the tanks of the LEC system. The LEC system consists of a set of drains and collection tanks primarily for collecting leaks and spills of chemically treated water. The drains are located throughout the process buildings. The tanks have a capacity of 550 gal each. Liquid level gauges mounted above grade on pipe stands monitor the tanks. Routine monitoring of the tanks' contents is based on observing and tracking the levels indicated on the gauges. Inventory tracking is relied on to indicate any leaks from the tanks. The contents of the LEC system will be sampled and analyzed for the same parameters as the continuous outfalls prior to disposal. If analytical results indicate that LEC contents meet the requirements of 10 CFR 20.2003, they may be released to the reservation sanitary sewer system . Otherwise they will be containerized for disposal off-site. 9.2.2.2.4 Action Levels Action levels for control ofliquid radioactive effluents from the ACP have been established based on the ALARA philosophy. The action levels described in Table 9.2-1 ensure operational control system deficiencies are documented and acted upon in a responsible manner and in a timeframe to remain well within the regulatory limits and below ALARA goals. The BEQs used in Table 9.2-1 are the maximum effluents expected under normal operating conditions. BEQs have been established for every ACP liquid discharge point to unrestricted areas (i.e., X-2230M and X-2230N holding ponds) and for the TWC blowdown to the GDP area. BEQs have also been established for the LEC discharges, which are characterized before they are discharged, based on 9-17

License Application for the American Centrifuge Plant Proposed Change 2020 ten percent of the 10 CFR 20.2003 requirements. The specific BEQ values established for the ACP outfalls are listed in Table 9.2-2.

• The ACP sanitary sewers, TWC blowdown, and runoff from the north cylinder storage pads discharge to NRC' DOE regulated units operated a service provider. The service provider has established and administers BEQ-based action levels for these discharges as documented in POEF-FBP-001, Basis for Interim Operation o(Former Uranium Enrichment Facilities (FUEF) at the Portsmouth Gaseous Diffusion Plant, Piketon, OH. USEC 02, llnifetl States Nuclear NegH-le-if-Jf'j'

( 'ommission Cerl-Ui-mf ion<!/ ( '<m1plia11ce .fi>r the Porf.,;moulh Ga.w(>HS I )(ffi+sioH l'la11/ 9.2.2.2.5 Other Permits and Licenses Point discharges to waters of the State of Ohio are required to be authorized under a NPDES Permit issued by the Ohio EPA. There are twothree NPDES Permits currently issued to the site.,_ with two ,--of them 11et\veen--+hem, these permits a~rea-e-y: covering_ all liquid discharges from the ACP . The third site NPDES permit is for the DUFGconversion facility . The ACP is required to submit a permit modification to collect all its discharge points into one or the other of the permits. 9.2.2.3 Waste Management 9.2.2.3.1 Waste Segregation and Collection ACP generated wastes are collected and packaged by the individual(s) generating the waste. However, this is not appropriate in cases where waste would have to be "double handled" (e.g., surveying wastes expected to be contamination-free). In this case, it is most appropriate to survey prior to packaging. Wastes known to be suitable for release to unrestricted areas based on the point and process of generation are segregated at the source, when possible, from wastes not suitable for release to unrestricted areas. Wastes from areas controlled for loose radioactive contamination are considered to be potentially contami nated until characterized. Wastes requiring characterization to determine whether they may be released to unrestricted areas are segregated upon completion of such characterization. 9.2.2.3.2 Waste Packaging and Labeling Containers known to contain radioactive waste, including packaging, are labeled in accordance with procedural requirements developed in accordance with the commitments in Section 11.4 of this license application and 10 CFR Part 20. Waste is packaged in appropriate containers to meet U. S. Department of Transportation (DOT) and 10 CFR Part 71 requirements. Some general types of waste packaging include, but are not limited to:

• Solid Waste (5-, 30-, 55-, or 110-gal drums)
• Liquid Wastes (5-, 30-, or 55-gal drums) 9-18

Licen *e Application fo r the American Centrifuge Plant Proposed Change 2020

• Corrosives, Acids (Polybottles or polydrum )
• Scrap Metal (B-25 boxes or other similar boxes, and various drums)

In addition, 85- and 110-gal overpacks may be used for damaged containers if the wastes are appropriate for these size containers. 9.2.2.3.3 Radioactive Waste Storage Those ACP wastes that are regulated for radiological content only are removed from the generating building and stored at an on-site radioactive waste storage area prior to final disposal. Those ACP wastes that are regulated for both radiological content and hazardous constituents and/or characteristics are stored at an on-site radioactive waste storage area under a conditional exemption for mixed waste (40 CFR Part 266, Subpart N [Federal] and Ohio Administrative Code-3745-266 [State]) prior to final disposal. Other areas may be utilized as waste storage areas as required by plant operations. If outdoor storage is necessary, radioactive wastes with removable contamination are packaged in containers, and wrapped or covered to prevent the release of radioactivity . Storage areas are posted in accordance with procedural requirements. Access to waste storage containers is restricted to trained personnel in accordance with 10 CFR 20.1905 . Containers are inspected quarterly, at a minimum, to ensure container integrity and to identify and correct any leaks or other problems. 9.2.2.3.4 Radioactive Waste Treatment Mixed aqueous wastes that cannot be processed on-site are stored until treatment is available at commercial treatment plants that are licensed in accordance with 10 CFR Part 61 , or applicable NRC Agreement State requirements. 9.2.2.3.5 Off-site Waste Shipments For Commercial ACP operation, 0 Qff-site shipments of radioactive wastes are manifested in accordance with 10 CFR 20.2006. Waste shipments are packaged, labeled, and manifested in accordance with applicable State, DOT, NRC, and EPA requirements. 9.2.2.3.6 Waste Disposal ACP generated radioactive wastes are disposed of at commercial disposal facilities that are licensed in accordance with 10 CFR Part 61 or applicable NRC Agreement State requirements. Packages are inspected prior to shipment, as appropriate, to verify compliance with applicable packaging and transportation requirements. Copies of the disposal site license are retained in accordance with procedural requirements. 9-19

license .,.Jpplication fo r the A merican Centrifuge Plant Proposed Change 2020 Waste di posal s arein compliancewith l OCFRPart 20, SubpartK. Wa tedi po al records are retained in accordance with 10 CFR 20.2108. Classified waste is disposed of in accordance with 10 CFR Part 95 and Security Program-Plan requirements. 9.2.2.3. 7 Waste Tracking and Documentation LLRW and LLMW generated at the ACP are tracked through a Request for Disposal system . Each waste container is given a unique identification number. The identification numbers are entered and maintained in a computer-based database. The database is updated to reflect locati on, characterization, treatment data, and waste disposal information. 9.2.2.3.8 Other Permits and Licenses The ACP is a generator of Resource Conservation and Recove,y Act of 1976 hazardous wastes, which transfers solid wastes to appropriately permitted Treatment, Storage, and Disposal Facilities in accordance with applicable state and federal regulations. 9.2.2.4 Environmental Monitoring The ACP is located contiguous to an existing uranium enrichment plant (the GDP) with approximately 50 years of accumulated experience in managing uranium and UF6. The GDP was operated by the United States Enrichment Corporation, a subsidiary of USEC, from 1993 until it was placed in standby, and by predecessor organizations of the United States Enrichment Corporation prior to 1993 . The environmental monitoring system for the ACP is based on the experience and data accumulated at the GDP. 9.2.2.4.1 Air Monitoring Between 1980 and 1999, annual gaseous uranium effluents from the GDP ranged between 0.97 and 0.010 Ci/yr. Ambient air samples collected over this period by the GDP operators showed that these levels of effluents do not produce a quantifiable difference in ambient air concentrations in unrestricted areas. ACP operations are not expected to exceed these levels of effluents. Consequently, ambient air monitoring is not useful in detecting or evaluating a public impact due to routine gaseous effluents from the ACP . In addition, experience at the GDP has shown that any release large enough to produce high or intermediate consequences will first produce a large and very visible cloud of white smoke at the point of release. The ACP has a written procedure for dealing with unplanned releases (" See and Flee") that includes the immediate reporting of observed releases to the Senior Shift Supervi sor (Operations Shift Supervisor during HALEU Demonstration) and evaluation by environmental professionals based on available credible information. Effluent monitoring will quantify routi ne gaseous efflu ents, but some accidental release scenarios may require information such as mass balances or measured environmental contamination to quantify an accidental release that did not pass through a monitored vent. 9-20

License ,,.J. pplication fo r the A merican Centrifuge Plant Proposed Change 2020 The United States Enrichment Corporation ceased sampling ambient air and returned the reservation ' s network of permanent air samplers to DOE in 1999, which upgraded the samplers for its own purposes. Based on the DOE Annual Environmental Reports published since 1999, average airborne uranium concentrations have been 1.1 x 10-15 micrograms per milliliter (µg/mL) on-site (i .e., within the DOE reservation), 7.4 x 10- 16 µg/mL in unrestricted areas, and 5.5 x 10- 16 µg/mL at the DOE background station. These results are consistent with the gross activity monitoring conducted prior to the turnover/upgrade. They are also a minimum of three orders of magnitude less than the applicable discharge limits for uranium isotopes in 10 CFR Part 20, Appendix B. The reservation maintains a meteorological tower that is located on the southern section of the reservation . The tower is equipped with instruments at the ground, 10-, 30-, and 60-meter levels. Among the parameters measured are air temperature, wind speed, wi nd direction, relative humidity, solar radiation, barometric pressure, precipitation, and soil temperature. Data from the National Weather Service or other local sources may be used in lieu of or to supplement reservation data. The effluent monitoring and meteorological data are used to calculate the environmental impacts of airborne effluents from the ACP using EPA-approved dispersion models as described in Section 9.2.2.1 of this chapter. 9.2.2.4.2 Soil and Vegetation Between 1980 and 2002, annual gaseous uranium effluents from the GDP have ranged between 0.97 and 0.005 Ci/yr. Soil and vegetation samples collected over this period by the GPO operators show that these levels of effluents do not produce a statistically significant difference in soil and vegetation concentrations in unrestricted areas. (Liquid effluents do not have a direct impact on soil and terrestrial vegetation around the reservation.) ACP operations are not expected to exceed these levels of effluents. Consequently, soil and vegetation monitoring is not useful in detecting a public impact due to gaseous effluents from the ACP. Therefore, atmospheric impacts of ACP operation, including action levels, will be based on gaseous effluent monitoring or other effluent information and atmospheric dispersion modeling as described in Section 9.2.2.1 of this chapter. Soil and vegetation monitoring may be useful in assessing the long-term impacts of effluents from ACP operations or DOE environmental remediation projects or in assessing the impact of a high or intermediate consequence release that has already been detected and controlled . Therefore, the ACP maintains a soil and vegetation monitoring program for these purposes. Soil and vegetation (wide-blade grass, typical of local cattle forage) samples are collected semiannually . The sampling networks completely surround the reservation, including the predominant downwind directions, and are administratively divided into on-site, off-site (up to 5 kilometers) and remote (5 to 16 kilometer off-site). A map of sampling location in each group is provided in Figure 9.2-3 . Soil amples are analyzed for gross alpha activity, gross beta activity, technetium beta activity, and total uranium concentration . Vegetation samples are analyzed for 9-21

License Application f or the A merican Centrifuge P/a111 Proposed Change 2010 technetium beta act1 v1ty and total uranium concentration . pecific detail of the analytical methods are presented in Section 9.2.2.5 of this chapter. See Table 9.2-5 for a summary of the last !+,.-e--eal-endaF-years-of soil and vegetation results (1998-2002). In addition to the semiannual vegetation samples, the ACP also collects annual crop samples from local gardeners and farmers on a voluntary basis. Because of the voluntary nature of these samples, the sampling locations change from year to year. Crop samples are normally analyzed for technetium beta activity and total uranium concentration only . The analytical methods are the same as for the vegetation samples. No contamination has been found in crop samples. 9.2.2.4.3 Surface Water Between 1980 and 2002, annual waterborne uranium effluents from the GDP have ranged between 0.71 and 0.026 Ci/yr. Surface water samples collected over this period by the GDP operators show that these levels of effluents do not produce a statistically significant difference in the Scioto River. ACP operations are not expected to exceed these levels of effluents. Consequently, surface water monitoring is not useful in detecting or evaluating a public impact due to liquid effluents from the ACP . Therefore, impacts of ACP operation on local receiving waters, including action levels, will be based on effluent monitoring and pathways modeling as described in Section 9.2.2.2 of this chapter. Surface water monitoring may be useful in assessing impacts of effluents from DOE environmental remediation projects or historical contamination. The ACP maintains a surface water monitoring program for this purpose. Radiological analyses are performed on grab samples from upstream and downstream locations in Little Beaver Creek, Big Beaver Creek, Big Run Creek, and the Scioto River. A map of the sampling locations is found in Figure 9.2-4 . Samples are collected weekly from the Scioto River and one location (RW8) in Little Beaver Creek. Other locations are sampled monthly. Specific details of the analytical methods are presented in Section 9.2.2.5 of this chapter. See Table 9.2-6 for a summary of-the- last live calen4ar--yeari;-of surface water results (1998-2002). 9.2.2.4.4 Sed iment Monitoring Between 1980 and 2002, annual waterborne uranium effluent from the GDP have ranged between 0.71 and 0.026 Ci/yr. Sediment samples collected over this period by the GDP operators show that these levels of effluents do not produce a statistically significant difference in the Scioto River. ACP operations are not expected to exceed these levels of effluents. Consequently, sediment monitoring is not useful in detecting a public impact due to liquid effiuents from the ACP . Therefore, impacts of ACP operation on local receiving waters, including action level , will be based on effluent monitoring and pathways modeling as described in Section 9.2.2.2 of this chapter. 9-22

License Application for the American Centrifuge Plan/ Proposed Change 2020 Sediment monitoring may be useful in assessing the long-term impacts of effiuent from DOE environmental remediation projects or historical contamination. The ACP maintains a sediment monitoring program for this purpose. Sediment sampling around the reservation is conducted semiannually to assess potential radionuclide accumulation in the surrounding receiving streams. The sampling locations include both upstream and downstream locations. A map of the sample locations is provided in Figure 9.2-5 . Sediment sample analyses include gross alpha activity, gross beta activity, and technetium beta activity and total uranium concentration. Specific details of the analytical methods are presented in Section 9.2.2.5 of this chapter. See Table 9.2-7 for a summary of the last five calendar yea-F-S of sediment results (1998-2002). 9.2.2.4.5 Groundwater Due to historical operations, the reservation has multiple plumes of groundwater contamination . The primary contaminate in the plumes is the halogenated solvent trichloroethylene, but limited areas of technetium contamination also exist. DOE is conducting a site-wide environmental remediation program under an Agreed Order with the State of Ohio. As part of this program, reservation groundwater monitoring is under the control of DOE and the data is reported as part of DOE ' s Annual Environmental Report for the reservation . The ACP does not conduct a separate groundwater monitoring program . The current nuclides of interest in the DOE groundwater monitoring program are 99Tc, 234U, 235 U, 236 U, 238U, 231Np, 238Pu, 240Pu, and 241Am . 9.2.2.4.6 Direct Gamm a Radiation Monitoring The only significant sources of environmental gamma radiation introduced to the reservation by man are the uranium isotope 235 U and the short-lived 238 U daughters. There are small amounts of other gamma emitters present on site as sealed sources and laboratory standards, but these are not detectable at any large distance. Gamma radiation levels in unrestricted areas around the ACP are dominated by naturally occurring radioactive materials. The reservation conducts external gamma radiation monitoring consisting of lithium fluoride thermoluminescence dosimeters (TLDs) positioned at various site locations and at locations off-site. There are nine dosimeters spaced within Perimeter Road on the reservation; eight dosimeters spaced around the reservation boundary; and two dosimeters located off-site. Maps of the TLD locations are presented in Figures 9.2-6 and 9.2-7. These dosimeters are collected and analyzed quarterly . Processing and evaluation are performed by a processor holding current accreditation from the National Voluntary Laboratory Accreditation Program of the National Institute of Standards and Technology (NIST). See Table 9.2-8 for a summary of the last five-cale-ooar ve-afs ofTLD results (1998-2002). 9-23

License Application for the A merican Centrifuge Plant Proposed Change 2020 9.2.2.5 Laboratory Standards A National Voluntary Laboratory Accreditation Program-certified service provider processes the site' s environmental TLDs as described in Section 9.2.2.4.6. A laboratory licensed/certified by the NRC or an Agreement State provides other radiological and chemical analyses. The following description is based on current services that have been provided by the oo-stte X 710 building laboratory, which is certified by the NRCon-site laboratory in the past, but is not part of the ACP . Off site ven-defs providing aAnalytical laboratory services for the ACP will be required conducted by certified provider to meet the equivalent standards as part of the contract. Vent samples (i .e., activated alumina) are analyzed for uranium isotopes (2 34U, 235U, and 238 U) and 99 Tc. Uranium isotope concentrations are determined using either alpha spectrometry or Inductively Coupled Plasma/Mass Spectrometry (ICP/MS). Technetium concentrations are determined using liquid scintillation counting. Analytical results are reported in micrograms of analyte per gram of alumina. These results are converted to grams released using recorded flow data and the measured weight of alumina in the sampler and to activity using published specific activities for individual isotopes. Gaseous effluents equivalent to an annual public dose of less than 0.1 mrem are routinely quantified. Since the airborne concentrations in 10 CFR Part 20, Appendix B, Table 2 are equivalent to an annual -dose of 50 mrem , the MDA of these methods are equivalent to less than 0.2 percent of the 10 CFR Part 20, Appendix B, Table 2 values. Water samples from NPDES outfalls are analyzed for gross alpha and gross beta activity, technetium beta activity, and total uranium concentration. The gross activities are determined by proportional counter and the technetium activity by liquid scintillation. The MD As are 5 x 10*9 µCi /mL for gross alpha, 1.5 x 10*8 µCi /mL for gross beta, 2 x 10*8 µCi /mL for technetium beta. The total uranium concentration is determined by ICP/MS, with a minimum detectable concentration of 0.001 µg/mL. The isotopic distribution of the total uranium is estimated to match the calculated uranium alpha activity to the measured gross alpha activity. The Table 2 values for liquid releases are 3 x 10*7 µCi /mL for each of the uranium isotopes and 6 x 10-5 µCi/mL for technetium. Consequently, the MDAs for liquid effluents are less than two percent of the applicable 10 CFR Part 20, Appendix B, Table 2 values. Environmental samples are analyzed for gross activities by proportional counter and technetium activity by liquid scintillation. Uranium concentrations in environmental samples are determined either by alpha spectrometry or ICP/MS . The minimum detectable activities/concentrations are comparable to those for effluent samples. Laboratory quality control (QC) includes the use of a dedicated Chain of Custody system, formal written procedures, NIST-traceable standards, matrix spikes, duplicate, and replicate samples, check samples, and blind and double-blind QC samples. The laboratories used shall participate in appropriate perfonnance testing (PT) programs and maintai n appropriate certifi cations for the types of analyses requested. For example. personnel safety monitoring analyses shall be performed by a laboratory certified by the American Industrial Hygiene Association for the analytes of interest, which would require them to successfully 9-24

License Application fo r the American Centrifuge Plant Proposed Change 2020 participate in PT programs for these analytes by performing them using ational In titute of Occupational Safety and Health or Occupational Safety and Health Administration (OSHA) methodology . Samples analyzed for environmental programs shall be performed by laboratories participating in appropriate certified PT programs, such as the following :

• EPA Discharge Monitoring Report-Quality Assurance Study for NPDES and Clean Water Act samples
• EPA Water Pollutant for waste water samples
• EPA Water Supply for drinking water samplesAey-l--a.boratory-providin~ analytieal services te---the--A(.:P-w-1~-FetttttfeG to-pafti ci pate In -at Iea:,t oA-e 1abefat.ery-i+nercern-pftfi5ett program covering each type of analysis contracted for (ntercomparisionlntercomparison pr<¥~rams that the United State l:.nrichment Corporation's X-7 W building laboratory currently parlt-etf*i~+n--+nc-ltttie ~ l ~ ~ t - e r i - f l g Report-Study; National

        -lttst-itu~'-ttpatiooal-- -Safety and H-ealth +NIGs+--1-) ProA-ctettey Analytical-+esti-11g Program, EPA Water PoUutio~ Performance Evaluation Study, bPA Water Supply Study, NI-OSH environmental Lead Pwftciency Analytical Testing Program, Ptoftciency
        ~n-v+fORmeRt-al T5t+ng pregram --a i()flHnern-ia-l- p-r-ognttH- sponsored--b_     too -A-nalytic-at-Pt:eeti6ts- De-partmeRt ef B-elfH=e-, -Ohin, DGE- l'-f-wi-roo-mem-a-1 -Measmemettts -J-,ab-er-alet=y-Radionuclide Quality Assessment Prog1am , and DOE's lixed Analyte Performance Evaluation Program .

9.2.2.6 Description of Status of Federal/State/Local Permits/Licenses The ACP must comply with the applicable regulations under the Atomic Energy Act of 1954, as amended; 10 CFR Part 40; and 10 CFR Part 70 to hold a license to possess and use source and SNM. In addition, the ACP must comply with pertinent NRC regulations in 10 CFR P art 20 related to radiation dose limits to individual worker and members of the public. Y-8-e(' The Licensee suemtHedis submitting an an update to the previously approved Environmental Report to the NRC for the HALEU Demonstration program in accordance with 10 CFR Part 51. As described in previous sections, the ACP will require PTis from the State of Ohio to install all new air emission sources followed by a modification to the existing Title V air permit for the operation of those sources. The ACP will also be subject to the Radionuclide NESHAP administered by the EPA Region V. An additional PTI from the State of Ohio will be needed if the ACP installs any new wastewater lines _ A modification to the existing NPDES permit will be needed to allow construction and operation of the ACP . These are the only Federal, State and local permits or other authorizations that the Licensee expects will be necessary for the ACP. Table 9.2-9 gives a full listing of the Federal, State and local permits and other authorizations and consultations that potentially could be required and the current status of each. The ACP permit and reporting requirements will be incorporated and administered in the l lnited States f<nnchment CnrporationAmerican Centrifu e O eratin LLC permits and reporting requirements until the Licensee establishes a compliance organization. The head CascadeHALEU Demonstration fa-i-li-ty, X-3001 purge vacuum and evacuation vacuum system, is currently 9-25

License Application for the American Centrifuge Plant Proposed Change 2020 incorporated in the United States Enrichment Corporation American Centrifuoe 0 LLC Title Vair permit (PTI number 06-07470ermit Number POl l 5127). Informal consultations have been made with the responsible agencies in compliance with the following:

• Section 7 of the Endangered Species Act
• Fish and Wildlife Coordination Act
• National Historic Preservation Act (NHP A), Section 106
• Farmland Protection Policy Act (FPPA)/Farmland Conservation Impact Rating Consultation letters and responses are incl uded in Appendix B of the accompanying Environmental Report.

9.2.3 Integrated Safety Analysis Summary An Integrated Safety Analysis (ISA) Summary, meeting the requirements of 10 CFR 70.65(b ), was prepared in accordance with the guidance contained in Chapter 3.0 of the SRP and NUREG-1513, Integrated Safety Analysis Guidance Document. The ISA Summary for the American Centrifuge PlantACP is submitted for review (separate from this license application) as document LA-3605-0003, Integrated Safety Analysis Summary for the American Centrifuge Plant. Additionally, LA-3605-000JA, Addendum I of the Integrated Safety Analysis Summary for the American Centrifj,ge Plant HALEU Demonstration, has also been developed and summarizes the ISA Summary frn the ACP for the HALEU Demonstration Program award by the DOE for the demonstration of the HALEU production to support DOE research and development activities and programs. 9.3 Reports to the Nuclear Regulatory Commission 9.3.1 10 Code of Federal Regulations 70.59 Reports The ACP submits a written report to the NRC Regional Office and the Office of Nuclear Material Safety and Safeguards by March 1 and August 30 of the each year detailing: uranium and technetium (if any) amounts and concentrations in gaseous and liquid effiuents during the previous reporting period (July through December and January through June, respective! ) in accordance with 10 CFR 70.59. These reports also include an estimate of the public dose due to gaseous effluents over the previous year. 9.3.2 National Emission Standards for Hazardous Air Pollutants Reports The ACP submits a written report to the EPA and OEPA by June 30 of each year detailing: plant operations and gaseous effluent monitoring during the previous calendar year, gaseous radioactive effiuents over the previous year, an assessment of the public TEDE caused by those 9-26

license Application for the American Centrifuge Plant Proposed Change 2020 effluents, and an explicit comparison of the calculated TEDE to the EPA public dose limit (10 mrem annually). This report would become monthly if the maximum public TEDE exceeds 10 mrem annually. This report is required under 40 CFR 61.94 and by the conditions of the Title V Permit issued by the State of Ohio. It also supports the requirement to demonstrate compliance with 10 CFR 20.1301 and 10 CFR 20.1101 as described in Section 9.2.2.1.2 of this chapter and is available upon request for inspection at the plant. 9.3.3 Baseline Effluent Quantity Reports The ACP assesses any weekly effluent that exceeds any of the action levels as described in Table 9.2-1 . Many years of experience by the GDP operators have shown that radioactive effluents less than the action levels in Table 9.2-1 cannot produce a public radiation dose that is within an order of magnitude of the dose restriction in 10 CFR 20.1101 , let alone the dose limit of 10 CFR 20.1301. Any weekly effluent that exceeds the action levels in Table 9.2-1 requires a written estimate of the probable impact of the effluent, in conjunction with other monitored effluents from ACP operations, on the annual public radiation dose. These reports are available on request by the NRC. They are not routinely submitted to outside authorities because they are considered interim assessments that are 5tif**"£~ee-superseded by the semiannual reports and annual public dose assessment described in Sections 9.3.1 and 9.3.2 of this chapter. In the event that evaluated releases threaten to exceed the public dose constraint in IO CFR 20.1101 , the NRC will be notified according to written procedures. 9.4 References

1. LA-3605-0002, Environmental Report for the American Centrifuge Plant

2. NUREG-1520, Standard Review Plan for t-he---Rt'We:++'-ffa lkt1me---A--pp/-1t.-'f:f:l-i-ffl.l-jfw-H-Fuel Cycle FacilitieSl' License Applications, Revision 2

3. U .S. Department of Energy, Portsmouth Annual Environmental Report for 2000, DOE/OR/l 1-3077&Dl , December 2001

4. U .S. Department of Energy, Portsmouth Annual Environmental Report for 2001 ,

D0E/OR/11-3106&D1 , November 2002

5. Regulatory Guide 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with JO CFR Part 50, Appendix I, October 1977 9-27

License Application for the American Centrifuge Plant Proposed Change 2020

6. USEC-02, Uni-ted S-ta-tes Nuclear Regufatory Commission Certification of Complianc-e for the Portsmouth Gaseous Diffusion Plant POEF-FBP-001, Basis for Interim Operation of Former Uranium Enrichment Facilities (FUEF) at the Portsmouth Gaseous Diffusion Plant, Piketon. OH

7. LA-3605-0003, Integrated Safety Analysis Summary for the American Centrifuge Plant

8. LA-3605-0003A, Addendum I of the Integrated Safety Analysis Summarv for the American Centrifuge Plant - HALEU Demonstration

   &-9.USEC-651 , Uranium Hexafluoride: A Manual a/ Good Handling Practices, Revision 9 9-28

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-1 American Centrifuge Plant Action Levels for Radionuclide Effluents Weekly Sample Results Uranium a Technetium a Required Actions h BEQ BEQ Review release data for previous six months for trends, and estimate probable impact over calendar year. Evaluate whether additional controls would significantly reduce public exposure. 10 x BEQ 80xBEQ Determine whether increased releases are ongoing or a or or single spike. 2xBEQ 16 xBEQ Initiate investigation into cause(s) of increased releases. averaged over 6 averaged over 6 Evaluate whether mitigative and/or corrective measures are months months necessary to reduce public dose. Implement mitigative and/or corrective measures as needed. EPA Reportable EPARQC Notify Operations Shift Supervisor [HALEU Quantityc (RQ) (10 Ci in 24 Demonstration operations] or Senior Shift Supervisor (0.1 Ci in 24 hours) [commercial operations only] hours) Trace source of abnormal releases and establish control or shutdown as needed. If releases cannot be mitigated within 24 hours, elevate to next level. 1 Cid 8 Cid Close affected discharge points until control of releases is re-established. a Uranium has an approximately 8-fold greater dose rate response than 99Tc over air dominated exposure pathways. Uranium dose response completely dominates 99J'c over water dominated exposure pathways. b Required actions for any level include required actions listed under lower emission levels. C RQ does not include permitted emissions. The ACP is regulated under 40 CFR Part 61 , Subpart H for release of airborne radionuclides from the entire reservation up to the equivalent of 10 mrem/year TEDE to the most exposed member of the public. d 1 Ci or 8 Ci in one weekly sample analysis. Note: The QQerations Shift Sugervisor fHALEU Demonstration o~rations] or Senior Shift Supervisor rcommercial ooerations onlv l has the authority to allow a restart . 9-29

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-2 Baseline Effluent Quantities for merican Centrifuge Plant Discharges Release Point Total Uranium Technetium Vents X-300 1 North Vent 0.2 mCi/week 0.1 mCi/week a X-3001 South Vent 0.2 mCi/week 0.1 mCi/week a X-3002 North Vent 0.2 mCi/week 0.1 mCi/week a X-3002 South Vent 0.2 mCi/week 0.1 mCi/week a X-3346 Vent b 0.08 mCi/week 0.1 mCi/week a X-7725 Gas Test Stands Vent 0.01 mCi/week 0.1 mCi/week a Outfalls 3 x 10-7 µCi/ mL or 6 x 10-5 µCi/ mL or LEC Effluents c I 0.1 Ci/year X-2230N West Holding Pond 2.5 x 10-8 µCi/ mL 1.0 x 10-1 µCi/ mL (NPDES 012) X-2230M Southwest Holding Pond 2.5 x 10-8 µCi/ mL 1.0 x 10-1 µCi/ mL (NPDES 013) TWC System Blowdown 5.9 x 10-8 µCi/ mL 1.0 x 10*1 µCi/ mL a Technetium BEQs for vents are based on five times the MD A. b X-3346 Vent serves the X-3346 Feed and Withdrawal Areas and X-3344 Customer Services Building. C LEC effluents are characterized before being discharged to the site sanitary sewer. The 100 mCi/yr standard includes uranium and technetium isotopes discharged to the site sanitary sewer during a calendar year. 9-30

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-3 Anticipated Gaseous Effluents Discharge Point Total Uranium a Technetium

                                          !!<l)Ci/ mL b          mCi/wk c           !!<l)Ci/ mLb          mCi/wk c X-3346 Feed and Withdrawal
                                                                    <0.08                                      0 Building (1 vent)

X-3001 and X-3002 Process

                                                                     <0.8                                      0 Buildings (4 vents)               <3.2  X 10" 15                            1.2 X 10" 16 X-7725 Gas Test Stands Vent                                       <0.01                                      0 XT-847 Glovebox Vent                                         0.0004                                   0.005 Laboratory Hoods d                                          0 .17                                  0.035 10 CFR Part 20, App. B, Table 3 X 10" 12              ------             8 X 10*9             ------

2 I I a Since uranium isotopes present at the ACP have the same discharge limit, uranium isotope activities are combined into a Total Uranium activity for simplify comparison to the Table 2 limits. b Anticipated concentrations are maximum ambient concentrations at the DOE reservation boundary due to emission sources and are based on emission estimates and atmospheric dispersion modeling. Anticipated technetium concentration is based on no detectable releases from the X-7725 fac illl~ building and X-3000 series builcli ngs. c Anticipated discharges are measured at the vent and, by definition. are less than the Baseline Effiuent Quantities. Anticinated technetium discharges from the X-7725 foei-1-i-1+-builclirnr and X-3000 series buildings are zero. d Bounding case for associated analytical services. 9-31

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-4 Anticipated Liquid Effluents a Discharge Point Total Uranium b Technetium

                                                                   !!¢ Ci/ mL                   !!<l>Ci/ mL LEC Effluents                            <3 x 10* 7 and <0.1 Ci/yr       <2 x 1o- 8 ( <MDA)

TWC System Blowdown <3 X 10" 8 <2 X 10*8 (<MDA) X-2230N West Holdi ng Pond

                                                                    <1 X 10"8              <2  X  10"8 (<MDA)

(NPDES Outfall 01 2) e X-2230M Southwest Holding Pond

                                                                    <1  X 10"8             <2 X 10*8 (<MDA)

(NPDES Outfall 013) e Sanitary wastewater

                                                                    <3  X 10"8             <2  X  10*8 (<MDA)

(excluding LEC effluents) North Cylinder Pad Runoff <1 X 10"8 <2 X 10"8 (<MDA) 10 CFR Part 20, App . B, Table 2 3 X 10"7 I 6 X 10* 5 10 CFR Part 20, App . B, Table 3 3 X 10"6 6 X 10"4 a ACP contributions only. Combined effluents from other site operations remain the responsibility of the individual operator. b Since uranium isotopes present at the ACP have the same discharge limit, uranium isotope activities are combined into a Total Uranium activity to simplifv comoarison to the Tab le 2 limits. C By definition, anticipated activity discharges are less than the BEQ. d LEC effluents are characterized prior to discharge. One Ci/yr limit applies to combined uranium and technetium activities. e Anticipated concentrations are annual averages based on monthly grab samples from 1995 through 2000. 9-32

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-5 Environmental Baseline Activities/Concentrations 1998-2002 Total Uranium Technetium Gross Alpha Gross Beta

                                 µgig                  pCi/g                 pCi/g                   pCi/g Reservation (9 Sampling Locations)

Soil Num . of Samples 117 (0) 117 (93) 117 (59) 117 (64) Average 2.8 <0.2 <8 < 14 Minimum 0.6 <0.1 <2 8 Maximum 4.4 1.5 21 36 Ve.getati on Num. of Samples 116(113 ) 116 (103) ----- ----- Average <0.25 <0. 3 ----- ----- Minimum <0.04 <0.1 ----- ----- Maximum 0.9 7.3 ----- ----- Off Reservation (6 Sampli ng Locations) Soil Num . of Samples 74 (0) 74 (32) 74 (38) 74 (41) Average 2.9 <0.2 <7 < 14 Minimum 0.7 <0.1 <2 <8 Maximum 4.6 3.8 14 47 Vegetation Num . of Samples 73 (73) 73 (61) ----- ----- Average <0. 24 <0.3 ----- ----- Minimum <0.05 I <0.1 ----- ----- Maximum <0.34 3.3 ----- ----- The "number of samples" shows the total number of samples collected, including replicate and duplicate samples collected for quality assurance (QA) purposes, followed by tJ1e number of samples that were lower than the Minimum Detectable Concentration in parentheses. QA sample locations for soil and vegetation are assigned indeoendently, so the number of samples in each group does not necessarily matclt 9-33

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-5 Environmental Baseline Activities/Concentrations 1998-2002 Total Uranium Technetium Gross Alpha Gross Beta

                               µgig                  pCi/g                   pCi/g                 pCi/g Remote (12 Sampling Locations)

Soil Num. of Samples 139 (0) 139 ( 133) 139 (73) 139 (77) Average 3.0 <0.2 <7 <14 Minimum 0.7 <0.1 <3 <7 Maximum 5.9 0.8 16 22 Ve,getation Num. of Samples 137 (80) 137 (1 28) ----- ----- Average <0.23 <0.2 ----- ----- Minimum 0.08 <0.1 ----- ----- Maximum <0.28 <0.5 ----- ----- Background (4 Sampling Locations) Soil Num. of Samples 40 (0) 40 (36) 40 (17) 40 (26) Average 3.5 <0.2 <8 < 14 Minimum 1.7 <0.1 <5 <8 Maximum 6.8 0.5 16 25 Vegetation Num. of Samples 40 (23) 40 (37) ----- ----- Average <0.24 <0.2 ----- ----- Minimum <0.14 <0.1 ----- ----- Maximum 0.28 0.5 ----- ----- The "number of samples" shows the total number of samples collected, including replicate and duplicate samples collected for QA purposes, followed by the munber of samples that were lower than the Minimum Detectable Concentration in parentheses. QA sample locations for soil and vegetation are assigned independently, so the number of samples in each group does not necessarily match. 9-34

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-6 Environmental Baseline Activities/Concentrations 1998 - 2002 Total Uranium Technetium Gross Alpha Gross Beta ug/L pCi/L pCi/L pCi/L Surface Water/Upstream Big Run Creek Num. of Sampl es 60 (56) 60 (60) 60 (57) 60 (3 9) Average <1.3 <15 <5 < 13 Minimum <0.1 <6 <l <6 Maxi mum 23 .5 <28 <8 30 Surface Water/Downstream Bi ~ Run Creek Num. of Samples 11 8 (68) 11 8(1 16) 118 (106) 11 8 (82) Average <1.5 <15 <6 <13 Mini mum 0.2 <6 1 6 Maximum 23.2 <28 < 140 33 Surface Water/Upstream Little Beaver Creek Num. of Samples 60 (59) 60 (60) 60 (56) 60 (4 1) Avera,ge <0.9 <15 <5 < 11 Minimum <0.1 <6 <l <6 Maximum 1.3 <28 < 12 <22 Surface Water/Downstream Little Beaver Creek Num. of Samples 321 (34) 322 (246) 322 (1 82) 322 (101 ) Average < 1.7 <16 <6 I < 15 Minimum <0.6 <8 2 <7 Maximum 9.4 43 44 78 Surface Water/Upstream Big Beaver Creek Num. of Samples 60 (36) 60 (58) 60 (48) 60 (25) Average <1.2 <16 <5 <14 Minimum 0.3 <8 2 <7 Maximum 5.8 <28 37 62 The "number of samples" shows the total number of samples collected, including replicate and duplicate samples collected for QA purposes. followed by the number of samples that were lower than the Minimum Detectable Concentration in parentheses. 9-35

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-6 Environmental Baseline Activities/Concentrations 1998 - 2002 Total Uranium Technetium Gross Alpha Gross Beta

                                µg/L                   pCi/L                    pCi/L                    pCi/L Surface Water/Downstream Big Beaver Creek Num. of Sam ples              60 (50)                 60 (5 8)                 60 (51)                  60 (36)

Average < I.I <16 <6 <14 Minimum <0.1 <6 <I <6 Maximum 5.2 <28 72 108 Surface Water/Upstream Scioto River Num. of Samples 261 (8) 261 (251) 261 (2 13 ) 261 (1 51) Average < 1.9 <15 <6 < 13 Minimum < 1.0 <6 2 <6 Maximum 32.6 <28 < 13 40 Surface Water/Downstream Scioto River Num. of Samples 261 (6) 261 (254) 261 (206) 261 (156) Average < 1.8 <16 <6 < 13 Minimum < 1.0 <6 2 <7 Maximum 9.5 <29 86 34 Surface Water/Background Creeks Num. of Samples 240 (2 14) 240 (237) 240 (223) 240 (1 79) Average <1.0 <16 <4 < 11 Minimum <0.1 <6 <I <6 Maximum 6.9 114a 11 46 The "number of samples" shows the total number of samples collected, including replicate and duplicate samples collected for QA purposes, followed by the number of samples that were lower than the Minimum Detectable Concentration in parentheses.

• One sample from a background location was analyzed at 114 picocuries per liter (pCi/L) of technetium, a beta emitter, but only 12 pCi/L of gross beta activity. The technetium activity is believed to be a case of cross contamination. The next highest technetium activitv at the background locations was 28 pCi/L.

9-36

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2- 7 Environmental Baseline Activities/Concentrations 1998 - 2002 Total Uranium Technetium Gross Alpha Gross Beta

                                µgig                  pCi/g                pCi/g                    pCi/g Sediment/X-2230M Southwest Holding Pond Discharge Num. of Samples                10 (0)                 10 (6)               10 (4)                   10 (4)

Average 3.8 <0.2 <9 <16 Minimum 1.8 <0.1 <4 <7 Maximum 6.2 0.3 18 <36 Sediment/X-2230N West Holding Pond Discharge Num. of Samples 13 (0) 13 (4) 13 (4) 13 (11) Average 3.2 <0.3 <7 < 11 Minimum 2.3 <0.1 <3 <7 Maximum 4.9 0.6 10 < 17 Sediment/Upstream Little Beaver Creek Num. of Samples 15 (0) 15 ( 13 ) 15 (6) 15 (11 ) Average 2.8 <0.1 <7 - - -

                                                                                                     <13 Minimum                          1.5                   <0.1                   <4                     <7 Maximum                          5.7                    0.2                   11                      18 Sediment/X-230J-7 Discharge Num. of Samples                17 (0)                 17 (0)               17 (7)                   17 (4)

Average 5.9 7.1 < 16 <32 Minimum 2.7 0.7 <5 <7 Maximum 21.2 31.3 83 170 Sediment/Downstream Little Beaver Creek Num. of Samples 28 (O) 28 (6) 28 (3) 28 (9) Average 7.0 <64.5 < 17 <85 Minimum 1.8 <0.1 <5 <10 Maximum 35 .1 801 a 61 924 The "number of samples" shows the total number of samples collected. including replicate and duplicate samples collected for QA purposes. followed by the number of samples that were lower than the Minimum Detectable Concentration in parentheses. 9-37

license Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2- 7 Environmental Baseline Activities/Concentrations 1998 - 2002 Total Uranium Technetium Gross Alpha Gross Beta ug/g pCi/g pCi/g pCi/g Sediment/Upstream Big Beaver Creek Num. of Samples 10 (O) 10 (2) 10 (4) 10 (6) Average 2.1 <0.3 <7 <13 Minimum 0.9 <0.1 <5 <7 Maximum 4.6 0.7 9 25 Sediment/Downstream Big Beaver Creek Num. of Samples 10 (0) 10 (0) 10 (I) 10 (2) Average 4.0 4.7 < 11 <18 Minimum 2.8 1.1 <6 < 12 Maximum 5.5 14.6 33 24 Sediment/Upstream Big Run Creek Num. of Sam ples 11 (0) 11 (8) 11 (3) 11 (8) Average 3.8 <0.2 <7 <13 Minimum 2.3 <0.1 4 9 Maximum 4.8 <0.2 13 <17 Sediment/Downstream Big Run Creek Num. of Samples 29 (0) 29 (6) 29 (6) 29 (18) Average 4.1 <0.8 <9 <14 Minimum 1.1 <0.1 <4 <7 Maximum 5.9 I 2.7 33 28 Sediment/Upstream Scioto River Num. of Samples 11 (0) 11 (1 1) 11 (7) 11 (8) Average 2.1 <0.1 <7 <12 Minimum 0.9 <0.1 3 <7 Maximum 4.6 <0.2 <9 <17 The " number of samples" shows the total number of samples collected, including replicate and duplicate samples collected for QA purposes, followed by the number of samples that were lower than the Minimum Detectable Concentration in parentheses. 9-38

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-7 Environmental Baseline Activities/Concentrations 1998 - 2002 Total Uranium Technetium Gross Alpha Gross Beta u g/g pCi/g pCi/g pCi/g Sediment/Downstream Scioto River Num. of Samples 10 (0) 10 (8) 10 (5) 10 (6) Average 2.1 <0.2 <9 <14 Minimum 1.4 <0.1 5 <8 Maximum 4.4 0.4 17 19 Sediment/Background Creeks Num. of Samples 40 (0) 40 (37) 40 (22) 40 (25) Average 3.2 <0.2 <6 < 13 Minimum 1.3 <0.1 <3 <7 Maximum 6.8 2.7 13 24 The "number of samples" shows the total number of samples collected, including replicate and duplicate samples collected for QA purposes, followed by the number of samples that were lower than the Minimum Detectable Concentration in parentheses.

• In Fall 2002, duplicate samples taken at the RM8 sample point contained 689 and 801 pCi/g of technetium. A replicate sample taken at the same time and a few yards away contained only 13 pCi/g of technetium. The RM8 sample taken the following spting contained only 13 pCi/g, which is consistent with previous samples.

Table 9.2-8 Environmental Baseline Radiation Levels 1998-2002 Area of Readings Average Minimum Maximum Reservation (includes 518, 737, 862, 906, 10.5 µRad/hr 6.4 µRad/hr 17.9 µRad/hr 933, 1404A, A35, A36, and A40) X-746 Cylinder Yard 70.5 µRad/hr 60. 1 µRad/hr 82. 3 µRad/hr (includes 874) Boundary (includes A3 , A8, A9, A12, 10.5 µRad/hr 6.2 µRad/hr 22.6 µRad/hr A15, A23 , A24, and A29) Piketon (includes A6) 9.6 µRad/hr 7.4 µRad/hr 13 .9 µRad/hr Camp Creek 10.4 µRad/hr 7.8 µRad/hr 14.9 µRad/hr (includes A28) Note: Locations ACP-1, ACP-2, ACP-3, ACP-4, and ACP-5 are new monitoring locations that will be established as the ACP is built. 9-39

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Air Quality Protection Title V Operating Permit: Required for Ohio Clean Air Act Centrus Energy Corp. (the Licensee)United sources that are not exempt and are major Environmental (CAA), Title States EnriclHnent Corporation is the holder of a sources, affected sources subject to the Acid Protection V, Sections final Title V Operating Permit (Facility ID Rain Program, sources subject to new source Agency (OEPA); 501-507 (US. 0666000000) with an issue date of July 31 , performance standards (NSPS), or sources U .S. Code, Title 42, ~ July 27,. 2017 and effective date of August subject to National Emission Standards for Environmental Sections 7661- 21 , 2003 August 17, 2017. The plant is subject Hazardous Air Pollutants (NESHAPs). Protection 766 lf [42 to Code of Federal Regulations, Title 40, Part Agency (EPA) USC 7661- 61 , Subpart H (40 CFR Part 61, Subpart H), 7661:f]); Ohio "National Emissions Standards for Emissions of Administrative Radionuclides which is included in the terms and Code (OAC) conditions of the Title V Operating Permit. 3745-77-02 Ohio Permit to Install (PTI): Required for OEPA CAA, Title I, USEC The Licensee has determined that the (1) any source to which one or more of the Sections 160- PSD, nonattainment area, and NSPS programs following CAA programs would apply: 169 (42 USC do not apply to the ACP. However, air emission prevention of significant deterioration 7470-7479); sources requiring an Ohio PTI would apply to (PSD), nonattainment area, NSPS, and/or OAC 3745 the ACP and the LicenseeY,S.I;G will submit a NESHAPs; and (2) any source to which one 02 timely PTI application to the OEP A. or more of the following state air quality programs would apply; Gasoline Dispensing Facility Permit, Direct Final Permit, and/or Small Maximum Uncontrolled Emissions Unit Registration. 9-40

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Air Quality Protection (Cont.) Ohio Permit to Operate: Required for (1) OEPA CAA, Title I, Centrus Energy Corp. (the Licensee) United any source to which one or more of the Sections 160- States Enrichment Corporation is the holder of a following CAA programs would apply; 169 (42 USC final Title V Operating Permit (Facility ID PSD, nonattainment area, NSPS, NESHAPs; 7470-7479); 0666000000) with an issue date .o f July 27, 20 17 and (2) any source to which one or more of OAC 3745 and effective date of August 17, 20 l 7issue date the following state air quality programs 02 of July 31 , 2003 and effective date of August 2 L would apply : State Permit to Operate and/or 2003 . Sources requiring a PTI will be registration of operating unit with potential incorporated in the Title V Operating Permit. air emissions of an amount and type considered minimal; this permit is not required, however, for any facility that must obtain a Title V Operating Permit. Risk Management Plan (RMP): Required EPA; OEP A CAA, Title 1, USEC The Licensee has determined that no for any stationary source that has regulated Section 112(r) regulated substances would be stored at the ACP substance (e.g., chlorine, hydrogen fluoride, (7) (42 USC in quantities that exceed the threshold levels. nitric acid) in any process (including 7412); 40 CFR Accordingly, an RMP will not be required. storage) in a quantity that is over the Part 68; OAC threshold level. 3745-104 9-41

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Air Quality Protection (Cont.) CAA Conformity Determination: OEPA CAA, Title 1, Pike County, Ohio has been designated as Required for each criteria pollutant (i .e., Section 176 "Cannot be Classified or Better Than Standard" sulfur dioxide, particulate matter, carbon (c) (42 for criteria pollutants. Because the county is in monoxide, ozone, nitrogen dioxide, and USC~ attainment with National Ambient Air Quality lead) where the total of direct and indirect 7506); 40 CFR Standards for criteria pollutants and contains no emissions in a nonattainment or maintenance 93 ; OAC maintenance areas, no CAA conformity area caused by a federal action would equal 3745-102; determination is required for any criteria or exceed threshold rates. pollutant that would be emitted as a result of the proposed action. Existing air quality on the site is in attainment with National Ambient Air Quality Standards (NAAQS) for the criteria pollutants. Water Resources Protection National Pollutant Discharge Elimination OEPA Clean Water The Licenseetl-S-E-G has determined that System (NPDES) Permit - Construction Act(CWA) construction of the ACP and new cylinder Site Storm Water: Required before making (33 USC 1251 storage yards would require an NPDES Permit point source discharges into waters of the et seq.); 40 for the construction site storm water discharges. state of storm water from a construction CFR Part 122; Centrus Energy Corp. United States Enrichment project that disturbs more than 5 acres (2 ha) OAC-3745- Corporation is the holder of NPDES Perm it of land. 33-02, 3745- number OIS00023AD0IS00023ED. If 38-02, and requested, a Storm Water Pollution Prevention 3745-38-06 Plan (SWPPE) will be submitted to the OEPA at the appropriate time. Storm water will discharge through existing outfalls covered by a NPDES Permit. 9-42

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Water Resources Protection (Cont.) National Pollutant Discharge Elimination OEPA CWA (33 The LicenseeUSEC has determined that storm System (NPDES) Permit - Industrial USC 1251 et water would be discharged from the ACP site Facility Storm Water: Required before seq.); 40 CFR during operations. making point source discharges into waters Part 122; Storm water will discharge through existing of the state of storm water from an industrial OAC-3745- outfalls covered by a NPDES Permit. site. 33-02, 3745-38-02, and 3745-38-06 National Pollutant Discharge Elimination OEPA CWA (33 The ACP will process industrial wastewater System (NPDES) Permit- Process Water USC 1251 et through an existing NPDES permitted facility Discharge: Required before making point seq.); 40 CFR and through existing outfalls covered by the source discharges into waters of the state of Part 122; NPDES Permit. industrial process wastewater. OAC-3745-33-02, 3745-38-02, and 3745-38-06 Ohio Surface Water PTI: Required before OEP A OAC-3745- If required, before construction of sewer lines constructing sewers or pump stations. 31-02 and pump stations at the ACP a PTI to modify the existing NPDES permit would be submitted to the OEP A at the appropriate time. Ohio Surface Water PTI: Required before OEP A OAC-3745- If required, a PTI to modify the existing NPDES constructing any wastewater treatment or permit would be submitted to the OEPA at the 31-02 collection system or disposal facility . appropriate time. 9-43

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Water Resources Protection (Cont.) CWA Section 404 (Dredge and Fill) U.S. Army Corps CWA (33 The Licensee~ believes that construction of Permit: Required to place dredged or fill of Engineers USC 1251 et the ACP would not result in dredging or material into waters of the United States, (USACE) seq.); 33 CFR placement of fill material into wetlands within including areas designated as wetlands, Parts 323 and the jurisdiction of the USACE. If construction unless such placement is exempt or 330 activities are subject to the CW A Section 404 authorized by a nationwide permit or a Permit program, they may be covered under a regional permit; a notice must be filed if a USACE Nationwide CW A Section 404 Permit nationwide or regional permit applies. (i.e., No. 14 [Linear Transportation Projects], 18 [Minor.Discharges], or 19 [Minor Dredging]). If necessary, ~ the Licensee will consult with the USACE concerning the project and, if appropriate, submit either a pre-construction notification about activities covered by a nationwide permit or an application for an individual Section 404 Permit. Ohio General Permit for Filling Category OEPA Ohio Revised USEC The Licensee believes that construction 1 and Category 2 Isolated Wetlands: Code (ORC) of the ACP would not result in dredging or Required where the proposed project Sections placement of fill material into wetlands within involves the filling or discharge of dredged 6111.021- the jurisdiction of the OEPA isolated wetlands material into Category 1 and Category 2 6111.029 program. However, if necessary, submit to the isolated wetlands, causing impacts that total OEPA a Pre-Activity Notice of activities 0.5 acre (0.20 ha) or less. covered under the General Permit for Filling Isolated Wetlands. 9-44

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Water Resources Protection (Cont.) Ohio Individual Isolated Wetland OEPA ORC Sections USEC The Licensee believes that construction Permit: Required where the proposed 6111.021- of the ACP would not result in dredging or project involves the filling or discharge of 6111.029 placement of fill material into wetlands within dredged material into Category 1 and the jurisdiction of the OEPA isolated wetlands Category 2 isolated wetlands, causing program. Accordingly, LSEC the Licensee will impacts that total greater than 0.5 acre (0.20 consult, if necessary, with the OEPA concerning ha) for Category 1 isolated wetlands and/or the project and, if appropriate, submit to the greater than 0.5 acre (0.20 ha) but not OEPA an application for an Individual Isolated exceeding 3 acres (1.2 1 ha) for Category 2 Wetland Permit. isolated wetlands. Spill Prevention Control and EPA CWA(33 -A-SPCC plan ESH-343 018 has been Countermeasures (SPCC) Plan: USC 1251 et developed and approved for the American Required for any facility that could seq.); 40 CFR Centrifuge Plant. SPCC plan would be required discharge oil in harmful quantities into Part 112 USEC The Licensee will develop and implement navigable waters or onto adjoining a SPCC plan at the appropriate time. shorelines. CWA Section 401 Water Quality OEPA CW A, Section USEC The Licensee believes that it would not be Certification: Required to be submitted to 401 (33 USC required to obtain a CWA Section 401 Water the agency responsible for issuing any 1341 ); ORC Quality Certification for construction or federal license or permit to conduct an Chapters 119 operation of the ACP or new cylinder storage activity that may result in a discharge of and 6111 ; yards. If LSEC the Licensee determines that a pollutants into waters of a state. OAC Chapters federal license or permit is required (e.g., a 3745-1 , 3745- CW A Section 404 Permit), a CWA Section 401 32, and 3745- Water Quality Certification will be requested 47 from the OEPA at the appropriate time. 9-45

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Water Resources Protection (Cont.) Public Water System : A completed OEPA OAC-3745- The Licensee will procure services from a application for an initial public water 84-0 1(B )(b) qualified vendor. system license is required prior to the operation of the public water system. Underground Storage Tank (UST) Ohio Department OAC 1301 :7- +wB---One UST systems areis installed at the Installation Permit: Required before of Commerce, 9-06(D) ACP. Registration number: 66005107-ROOO 10 beginning installation of a UST system (i.e., Ohio Bureau of Tank Number: a tank and/or piping of which 10 percent or Underground T00007 more of the volume is underground and that Storage Tank T00016 contains petroleum products or substances Regulations defined as hazardous by the Comprehensive (BUSTR) Environmental Response, Compensation, and Liability Act [CERCLA], except those hazardous substances that are also defined as hazardous waste by the RCRA). New UST System Registration : Required EPA; Ohio RCRA, as If new UST systems would be installed at the within 30 days of bringing a new UST BUSTR amended, ACP the Registration would be filed at the system into service. Subtitle I (42 appropriate time. USC 699la-699li); 40 CFR 280.22; OAC 1301 :7-9-04 9-46

License Application for the A merican Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Water Resources Protection (Cont.) Above Ground Storage Tank (AST): A Ohio Department OAC 1301 :7- AST fuel storage tanks will be required for the PTI required to install, remove, repair or of Commerce, 7-28(A)(3) ACP. Permits to install will be filed at the alter any stationary tank for the storage of State Fire 40 CFR 112.8 appropriate time. flammable or combustible liquids. Marshal Waste Management and Pollution Prel'ention Submit Determination Results: Required OEPA OAC 3745 Upon characterization of newly generated waste when a person who generates waste in the 11 streams from the ACP, notification would be State of Ohio or a person who generates made to the OEP A. waste outside the state that is managed inside the state determines that the waste he/she generates is hazardous waste. Registration and Hazardous Waste EPA; OEP A Resource Centrus Energy Corp.United States Enrichment Generator Identification Number: Conservation Corporation Hazardous Waste Generator Required before a person who generates and Recovery Identification Number OHD987054723 . over 220 lb (100 kg) per calendar month of Act(RCRA), hazardous waste ships the hazardous waste as amended off-site. (42 USC 6901 et seq.), Subtitle C; OAC 3745 12 9-47

License Application for the A merican Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Waste Management and Pollution Prevention (Cont.) Construction and Demolition Debris OEPA or Pike OAC 3745 Construction debris would not be disposed of on Facility License: Required before County Board of 01 site at the ACP. Therefore, no Construction and establishing, modifying, operating, or Health Demolition Debris Facility License would be maintaining a facility to dispose of debris required. from the alteration, construction, destruction, or repair of a man-made physical structure; however, the debris to be disposed of must not qualify as solid or hazardous waste; also, no license is required if debris from site clearing is used as fill material on the same site. Low-Level Radioactive Waste Generator Ohio Department OAC 3701 :1- The Licensee will file a Low-Level Radioactive Report: Required within 60 days of of Health 54-02 Waste Generator Report with the Ohio commencing the generation of low-level Department of Health at the appropriate time. waste in Ohio. ODH ID Number 52 2109255. 2107911 9-48

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Waste Management and Pollution Prevention (Cont.) Hazardous Waste Facility Permit: EPA; OEPA RCRA, as Hazardous waste would not be disposed of on Required if hazardous waste will undergo amended (42 site at the ACP. Should ACP become a large nonexempt treatment by the generator, be USC 6901 et quantity generator and waste require storage on stored on site for longer than 90 days by the seq.), Subtitle site for greater then than 90 days for generator of 2,205 lb (1,000 kg) or more of C; OAC 3745- characterization, profiling, or scheduling for hazardous waste per month, be stored on site 50-40 treatment or disposal a Hazardous Waste Facility for longer than 180 days by the generator of Permit would be required and submitted at the between 220 and 2,205 lb (100 and 1,000 kg) appropriate time. of hazardous waste per month, disposed of on site, or be received from off-site for treatment or disposal. Low-Level Mixed Waste (LLMW): OEPA OAC 3745- The Licensee will manage LLMW in LLMW is a waste that contains both low- 266; 40 CFR compliance with 40 CFR Part 266 Subpart N and level radioactive waste and RCRA Part 266 Ohio Administrative Code Chapter 3745-266. hazardous waste. Subpart N Industrial Solid Waste Landfill Permit to OEPA OAC 3745 Industrial solid waste would not be disposed of Install: Required before constructing or 06 on site at the ACP. Therefore, no Industrial expanding a solid waste landfill facility in Solid Waste Landfill Permit to Install would be Ohio. required. 9-49

License Application/or the American Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Emergency Planning and Response List of Material Safety Data Sheets: Local Emergency Emergency The Licensee will prepare and submit a List of Submission of a list of material Safety Data Planning P fanning and Material Safety Data Sheets at the appropriate Sheets is required for hazardous chemicals Commission Community time. (as defined in 29 CFR Part 1910) that are (LEPC); Ohio Right-to-Know stored on site in excess of their threshold State Emergency Act of 1986 quantities. Response (EPCRA), Commission Section 311 (SERC) (42 USC 11021); 40 CFR 370.20; OAC 3750 15 Annual Hazardous Chemical Inventory LEPC; Ohio EPCRA, United States Enrichment CorporationThe Report: Submission of the report is SERC; local fire Section 312 Licensee will prepare and submit an Annual required when hazardous chemicals have department (42 USC Hazardous Chemical Inventory Report each been stored at a facility during the preceding 11022); 40 year. Centrus Energy Corp.United States year in amounts that exceed threshold CFR 370.25; Enrichment Corporation Facility ID Number quantities. OAC 3750 45661NTDST3930U 01 9-50

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Emergency Planning and Response (Cont.) Notification of On-Site Storage of an Ohio SERC EPCRA, United States Enrichment CorporationThe Extremely Hazardous Substance: Section 304 Licensee will prepare and submit the Submission of the notification is required (42 USC Notification of On-Site Storage of an Extremely within 60 days after on-site storage begins of 11004); 40 Hazardous Substance at the appropriate time, if an extremely hazardous substance in a CFR 355.30; such substances are determined to be stored in a quantity greater than the threshold planning OAC 3750 quantity greater than the threshold planning quantity. 05 quantity at the ACP. Facility ID Number 45661NTDST3930U Annual Toxic Release Inventory (TRI) EPA:OEPA EPCRA, United States Enrichment CorporationThe Report: Required for facilities that have 10 Section 313 Licensee will prepare and submit a TRI Report or more full-time employees and are (42 USC to the EPA each yearns appropriate. Facili ty ID assigned certain Standard Industrial 11023); 40 Number 45661NTDST3930U. Classification (SIC) codes. CFR Part 372; OAC 3745-100-07 9-51

License Application for the A merican Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Emergency Planning and Response (Cont.) Transportation of Radioactive Wastes U.S. Department Hazardous Centrus Energy Corp .United States Enrichment and Conversion Products Certificate of of Transportation Materials Corporation Certificate of Registration Number Registration: Required to authorize the (DOT) Transportation 052803005022LN. registrant to transport hazardous material or Act (HMTA), cause a hazardous material to be transported as amended by or shipped. the Hazardous Materials Transportation Uniform Safety Act of 1990 and other acts (49 USC 1501 et seq.); 49 CFR 107.608(b) 9-52

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Emergency Planning anti Response (Cont.) Transportation of Radioactive Wastes DOT HMTA(49 When shipments of radioactive materials are and Conversion Products Packaging, USC 1501 et made, the Licensee will comply with DOT Labeling, and Routing Requirements for seq.); Atomic packaging, labeling, and routing requirements. Radioactive Materials: Required for Energy Act packages containing radioactive materials (AEA), as that will be shipped by truck or rail. amended (42 USC 2011 et seq.); 49 CFR Parts 172, 173, 174, 177, and 397 9-53

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Other Land Resources Farmland Protection and Policy Act U.S. Department Farmland Con sultation letters are included in Appendi x B (FPPA): Prime farmland is land that has the of Agriculture Protection and of this ERLA-3605-0002, Environmental Report best combination of physical and chemical Policy Act for the American Centrifuge Plant. characteristics for producing crops of (FPPA) of statewide or local importance. Prime 1981 Public farmland is protected by the Farmland Law 97-98; 7 Protection and Policy Act (FPPA) of 1981 USC 420l[b]; which seeks " ... to minimize the extent to 7 CFR Part 7, which federal programs contribute to the paragraph 658 unnecessary and irreversible conversion of farmlands to nonagricultural uses ... " Biotic Resources Threatened and Endangered Species U.S. fish and Endangered Consultation letters are included in Appendix B Consultation : Required between the Wildlife Service; Species Act of of this E RLA-3605-0002, Environmental Report responsible federal agencies and affected Ohio Department 1973, as for the American Centrifuge Plant. states to ensure that the project is not likely of Natural amended (16 to (1) jeopardize the continued existence of Resources USC 1531 et any species listed at the federal or state level seq.); ORC as endangered or threatened or (2) result in 1531.25-26 destruction of critical habitat of such species. and 1531.99 9-54

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Cultural Resources Archaeological and Historical Resources Ohio State National CSEC The Licensee has consulted with the Ohio Consultation: Required before a federal Historic Historic SHPO regarding previous archeological and agency approves a project in an area where Preservation Preservation architectural surveys at the DOE reservation. archaeological or historic resources might be Officer (SHPO) Act of 1966, as Consultation letters are included in Appendix B located. amended (16 of LA-3605-0002, Environmental Report for the USC 470 et American Centrifuge Plant. seq.); Archaeological and Historical Preservation Act of 1974 (16 USC 469-469c-2); Antiquities Act of 1906 (16 USC 431 et seq.); Archaeological Resources Protection Act of 1979, as amended (16 USC 470aa-mm) 9-55

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Other (cont) Environmental Report (ER) Required by NRC National LA-3605-0002, Environmental Report for the 10 CFR Part 51 , this ER is being submitted Environmental American Centrifuge Plant This ER was to the U.S . Nuclear Regulatory Commission Policy Act of prepared in accordance with the U.S. Code of (NRC) to support licensing of the ACP. 1969, as Federal Regulations, IO CFR Part 51, which amended implements the requirements of the National (NEPA) (42 Environmental Policy Act (NEPA) of 1968, as USC 4321 et amended (P.L.91-190). seq.); 40 CFR Parts 1500-1508; 10 CFR Part 1021 ; 10 CFRPart 51 P.L. 91-190 Depleted UF6 Management Measures: OEPA OAC 3745- The Licensee will manage the ACP Depleted Establishes requirements for management, 266; 40 CFR UF6 tails cylinders in accordance with 40 CFR inspection, testing, and maintenance Part 266 Part 266 Subpart N and Ohio Administrative associated with the ACP Depleted UF6 Subpart N Code Chapter 3745-266 while in storage. storage yards and cylinders owned by the Licensee~ at the DOE reservation as stipulated in the ACP License Application. 9-56

License Application for the American Centrifuge Plant Proposed Change 2020 Table 9.2-9 Potentially Applicable Consents for the Construction and Operation of the American Centrifuge Plant License, Permit, or Other Consent Authority Relevance and Status Other (Cont.) Standard Industrial Classification (SIC): OSHA SIC system SIC 2819 Industrial Inorganic Chemicals, Not The SIC system serves as the structure for Elsewhere Classified collection, aggregation, presentation, and analysis of the U.S. economy. An industry consists of a group of establishments primarily engaged in producing or handling the same product or group of products or in rendering the same services. 9-57

License Application for the American Centrifuge Plant Proposed Change 2020 D ~ lDOD 1:500 SC..U: FEET Ill PRlt.fARY ACP FACILITIES

                                                          ~ SECONDARY ACP FACIU11ES I!     NEW PRIMARY ACP FACILITIES 1ml    NEW SECONDARY ACP FACILITIES
                                                          .1(,,. N:.P Monitored Vents RAI 1-1-B-4, R2 PROPOSED 9-58

License Application for the American Centrifuge Plant Proposed Change 2020 E

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      --~IIIR>RIIATION CONTAINED WITHIN DOES NOT CONTAIN EXPORT CONTROU!D INfllRMATION 1-1-8-4, R1 Figure 9.2-1 Locations of American Centrifuge Plant Monitored Vents 9-59

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License Application for the A merican Centrifuge Plant Proposed Change 2020

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CP- 030 - RO Figure 9.2-3 Locations of Soil and Vegetation Sampling Points 9-62

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             * ~ Sedlmct CP-029-RO s.m,un,                            Rll10S (10 milea) t Figure 9.2-5 Locations of Stream Sediment Sampling Points 9-64

License Application for the American Centrifuge Plant Proposed Change 2020 This figure is withheld pursuant to IO CFR 2.390 and is located in Appendix B of this license application Figure 9.2-6 Locations of Environmental Thermoluminescence Dosimeters on the U.S. Department of Energy Reservation 9-65

License Application for the American Centrifuge Plant Proposed Change 2020 s

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      * ~~°<<,~~i:~~!~~!21i~~~eters 18-RO Figure 9.2-7 Locations of Environmental Thermoluminescence Dosimeters Outside the U.S. Department of Energy Reservation Boundary 9-66

License Application for the American Centrifuge Plant Proposed Change 2020 Blank Page 9-67

License Application for the American Centrifuge Plant Proposed Change 2020 10.0 DECOMMISSIONING In accordance with NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications (Revision 2), this chapter provides an overview of proposed decommissioning activities for the American Centrifuge Plant (ACP). The ACP is located in a leased area of the U.S. Department of Energy' s (DOE) reservation in Piketon, Ohio. 10.l High Assay, Low-Enriched Uranium (HALEU) Demonstration Program The Licensee, American Centrifuge Operating, LLC (ACO or Corporation), is deploying a 16-machine AClOOM HALEU cascade in leased areas under contract with the U.S . Department of Energy (DOE or Department). In support of this HALEU Demonstration Program, DOE amended the Appendix I Lease Agreement between the U.S. Department o(Energy and United States Enrichment Corporation for the Gas Centrifuge Enrichment Plant (GCEP Lease Agreement). The amended GCEP Lease Agreement renewed and extended the term of the lease through May 31, 2022. Additionally, the amended GCEP Lease Agreement permits the construction and operation of the demonstration cascade by the Corporation (Licensee), the sublessee of the GCEP Lease and holder of the U.S . Nuclear Regulatory Commission (NRC) American Centrifuge Plant (ACP) Materials License. The amended GCEP Lease Agreement includes the following statements pertaining to decommissioning liability:

• As of May 31, 2019, the Corporation (Licensee) had fully satisfied the lease turnover conditions and any existing financial assurance provided under Section 4.3 (of the GCEP Lease Agreement) was released, surety bonds were cancelled, and collateral returned to the Corporation (Licensee).
• Any facilities or equipment constructed or installed by the Corporation (Licensee) under the Demonstration Contract with the Department shall be included in Exhibit B (of the GCEP Lease Agreement) as Leased Personality and may be returned to the Department in an "as is" condition at the end of the lease term (May 31, 2022).
• The Department hereby assumes all liability for the decontamination and decommissioning of such facilities and equipment installed, and any work performed, under the Demonstration Contract with the Department including any materials or environmental hazards on the site. Therefore, no financial assurance for any liability or lease turnover conditions shall be required from the Corporation (Licensee).
• The parties agree that any work performed under the HALEU Demonstration Contract on the leased premises shall be considered a permitted use; any alternations or changes to the remise ursuant to the Demonstration Contract with the DOE shall be a ermitted chanoe to the premises; and any liabilities of the Corporation (Licensee) arising from or incident to the performance of work under the Demonstration Contract with the DOE shall be governed olely by uch contract and any financial protection afforded to the Corporation (Licensee) as a person indemnified under the Act.

10- 1

License Application fo r the A merican Centrifuge Plant Proposed Change 2020 Title to depleted uranium hexafluoride (UF6) by-product (tails) from the HALEU enrichment process has yet to be determined. However, should the DOE determine that the Licensee owns the tai ls material, the Licensee commits to the submittal to the NRC a license amendment request to provide the required decommissioning surety required by 10 CFR 30.35, 40.36, and 70.25 for prior review and approval. At the conclusion of the HALEU Demonstration Program, the facilities will be either returned to the Department in accordance with the requirements of the GCEP Lease Agreement or the Licensee will amend the ACP Materials License to allow phased implementation of expanded centrifuge enrichment cascades as described in Section 1.1.8 of the license application. At that time, a revised decommissioning funding plan, including an updated decommissioning cost estimate would be provided to the NRC for prior review and approval to reflect any new decommissioning liabilities. 10.2 American Centrifuge Plant (ACP) Decommissioning In accordance with Reference I, this ehapter provides iHl -Overview of proposed aec-ommissioning activities for-t-he-Amer~can teftlFHttge-P+attt (ACP) The ACP is loCftted in a ~eased area-of-t+ie U.S. Depa11ment of Energy ' s (DOE) reservation in Piketon, Ohio USEC Inc (USEC')The Licensee previously requested a 30-year license to operate the ACP. At the end of useful plant life, the ACP will be decommissioned such that the facilities will be either returned to the DOE in accordance with the requirements of the Lease Agreement with the DOE or will be released for unrestricted use. The criteria for final disposition of facilities will be established in the Decommissioning Plan (DP) which, as noted below, will be submitted prior to license termination. Nevertheless, for the purposes of the License Application for the American Gentrifuge PlantACP, the decommissioning discussions in this Af!pplication and the decommissioning estimated costs are based on decontaminating the plant to the radiological criteria for unrestricted use in 10 Code ofFederal Regulations (CFR) 20.1402. Information about the Licensee, the location of the site, and the types and authorized uses of licensed material are provided in Section 1.2 of the license application and a description of the site and immediate environs is provided in Section 1.3 of the license application . Similar to the successful decommissioning efforts for the American Centrifuge Lead Cascade Facility, Af! more detailed DP for the ACP will be submitted by the Licensee in accordance with 10 CFR 30.36 (g), 10 CFR 40.42 (g), and 10 CFR 70.3 8(g) and applicable risk-informed lJ S Nudear Regulatory Commission (NRC ) guidance provided in NUREG-1757, Consolidated Decommissioning Guidance (References 2, 3, and 4Volumes 1 - 3) prior to the time of license termination. Prior to decommissioning, an assessment of the radiological status of the ACP will be made. Enrichment equipment will be removed, leaving onl y the building shells and the plant infrastructure, including equipment that existed at the time of lease with the DOE (e.g., rigid mast crane, utilities, etc. ). Cl assified material, components, and docum ents will be destroyed or disposed of in accordance with the Security Plan for the Protection of Classified Matter P.l!fJKmm .for at the American Centrifuge Plant fReferenee-~ . Requirements for nuclear material control and accountability will be maintained during decommi ssioning in a manner similar to the programs in force during ACP operation (Reference 6NR-3605-0005). Depleted uranium 10-2

License Application for the American Centrifuge Plant Proposed Change 2020 hexatluortde (UF6) material (tails), if not sold or disposed of prior to decommissioning, will be sold, or converted to a stable, non-volatile uranium compound and disposed of in accordance with regulatory requirements utilizing facilities constructed by DOE, as authorized by the USEC Privatization Act, and/or other licensed facilities. Radioactive wastes will be disposed of at licensed low-level waste disposal sites. Hazardous wastes will be treated or disposed of in licensed hazardous waste facilities . The DP submitted at the time of license termination consists of several interrelated components, including (1) site characterization information, (2) remediation plan, and (3) a final status survey plan. The costs for activities required for these components have been identified in this chapter and estimated in the Decommissioning Funding Plan (DFP). Costs projected were developed based on the experience at the Portsmouth Gaseous Diffusion Plant during the transition to Cold Standby operation and decommissioning cost estimates developed for the American Centrifuge Demonstration Facility. Additionally, USEC the Licensee hags performed dismantling and decontamination work at the gaseous diffusion plants. Data and experience from these activities allowed a realistic estimation of expected decommissioning financial expenditures. Using the cost data as a basis, financial arrangements are made to cover costs required to release the ACP for unrestricted use and to dispose of the tails. Updates on cost and funding will be provided periodically as described in Section 10.J J 0.4. In accordance with 10 CFR 70.22(a)(9},__ and 30.35, 40.36, and 70.25(a)(l), a DFP (NR-3605-0006) is was previously submitted as part of the original license application for the ACP (Reference 7-). The following assumptions are utilized in the plan for decommissioning:

• No credit is taken for salvage value of equipment or materials .
• Decontamination liability is anticipated in the X-3001 and X-3002 Process Buildings, X-3012 Process Support Building, X-3344 Customer Services Building, X-3346 Feed and Withdrawal Building, X-3346A Feed and Product Shipping and Receiving Building, X-7725 Recycle/Assembly FacilityBuilding, X-7726 Centrifuge Training and Test Facility, X-7727H Interplant Transfer Corridor, X-2232C Interconnecting Process Piping, and miscellaneous cylinder storage yards.
• No decontamination is anticipated for the other ACP leased facilities .
• Decommissioning estimated costs are based on decontaminating the plant to the radiological criteria for unrestricted use in 10 CFR 20.1402.

The centrifuge assembly area in the X-7725 fac-ility-building is identified as the Decontamination Service Area (DSA). The centrifuge mac--hine transport system is used to transport the centrifuge~ mac-hi-nes from the cascade area to the DSA. The remaining sections of this chapter describe decommissioning plans and funding arrangements, and provide a detailed examination of the decontamination aspects of the program. The information herein was developed in connection with the decommissioning cost estimate and 10-3

license. lpp!ication fo r the A merican Centrifuge Plant Proposed Change 2020 is provided for information. Specific elements of the planning may change with the submittal of the detailed DP required near the time of license termination.

         -t--0-.--t---Deent missioning Progro m The plan for decommissioning is to decontaminate or remove materials from the facilities promptly after cessation of ACP operations. Decommissioning planning begins by incorporating special design features into the plant. These features simplify dismantling and decontamination.

The plans are implemented through proper management of Radiation Protection and Industrial Health and Safety programs for the ACP . Decommissioning policies address radioactive waste management, physical security, and nuclear material control and accountability . 10.l..1. I Decommissioning Design Features Specific features are incorporated into the plant design to accommodate decontamination and decommissioning activities. The major features are described below. 10.2. 1.L--l Radioactive Contamination Control The following features primarily serve to minimize the spread of radioactive contamination during operation, and simplify the eventual plant decommissioning. As a result, worker exposure to radiation and radioactive waste volumes are maintained as low as reasonably achievable (ALARA).

• Areas of the plant are sectioned off into clean areas and potentially contaminated areas, called Contamination Control Zones (CCZs) that have access control requirements.

CCZs are buffer zones established where discrete areas of contamination might be occasionally encountered. Areas that are contaminated are called Contamination Areas (CAs). Figure 10.£..1-1 (located in Appendix B of this license application) provides a diagram showing the CCZ boundary. Procedures for these areas are encompassed by the Radiation Protection Program, and serve to minimize the spread of contamination and simplify eventual decommissioning.

• Non-radioactive process equipment and systems are minimized in locations subject to likely contamination . This limits the size of the CCZs, and limits the activities occurring inside these areas.

10.2. 1. l .2 Worker Exposure and Waste Volume Control The following features primarily serve to minimize worker exposure to radiation and minimize radioactive waste volumes during decontamination activities. As a result, the spread of contamination is minimized as well.

• Ample access is provided for efficient equipment dismantling and removal of equipment that may be contaminated . This minimizes the time of worker exposure.

10-4

License Application for the American Centrifuge Plant Proposed Change 2020

• Connections in the process systems are provided for thorough purging. This removes a significant portion of radioactive contami nation prior to disassembly.
• Design drawings prepared for the plant, simplify the planning and implementing of decontamination procedures.
• Worker access to contaminated areas is controlled to assure that workers wear proper protective equipment and limit their time in the areas.

10-5

License Application for the American Centrifuge Plant Proposed Change 2020 The information within this figure has been determined to contain Export Controlled Information and is located in Appendix B of this license application Figure 10.2.1-1 Commercial ACP Contamination Control Zone 10-6

l icense Application fo r the American Centrifuge Plant Proposed Change 2020 10.2.2 Decommissioning Steps Decommissioning may begin immediately following termination of operation, since only low radiation levels exist at this plant. Overall, the decommissioning is estimated to require approximately six years from plant shutdown to completion of the final status survey of radiological conditions. The order of activities to support decommissioning will generally be: planning and preparation; process system purging; equipment dismantling and removal ; decontamination; disposition of equipment and material (including classified items); disposal of wastes; completion of a final status survey. The following sections provide an overview and explanation of each of these steps. 10.2.2.1 Overview The intent of decommissioning is to return the ACP to an unrestricted use state. Removed equipment includes the centrifuges, the feed and withdrawal equipment, piping and components from systems providing UF6 containment, systems in direct support of the centrifuges (e.g., cooling water), radioactive and hazardous waste handling systems, contaminated air filtration systems, etc. The remaining plant infrastructure includes utility services such as electrical power supply, sanitary water, fire suppression, ventilation, communications, and sewage treatment. Decontamination of the plant will not require the installation of a new facility dedicated for that purpose since the X-7725 fac il ity building will serve as the DSA and wi ll accommodate repetitive equipment decontamination of centrifuges and other components. The DSA is described in Section I 0.2.8.1 of this license application and will be the location for decontamination activities. Although certain unclassified components may be reused or sold as scrap, for conservatism this plan assumes only that components will be decontaminated in accordance with radiation protection requirements. Classified parts will be dispositioned in accordance with an approvedthe Security Plan Program . Table 10.2.2-1 of this license application lists components for potential decontamination at decommissioning. The Licensee intends to evaluate possible commercial uses of UF6 tails. UF6 tails which are not commercially reused will be converted to a stable form and disposed of in accordance with the USEC Privatization Act and other applicable statutory authorizations and requirements at DOE ' s UF6 conver ion facilities and/or other licensed facilities. UF6 tails are stored in steel cylinders until the tails material can be processed in accordance with the disposal strategy established by the Licensee. The Licensee provides financial assurance to fund the estimated cost of conversion and disposal of the depleted uranium inventory as it is generated during operation. This funding is described in the DFP and is in addition to the funding requirements for decommissioning the ACP . At full capacity, the ACP will generate approximately 8,400 Metric Ton (MT) of UF6 tail s annually . Over the 30-year license, that is a total of approximately 214,400 MT of UF6tails, as noted in Table C3 .19 of the DFP. Depending on technological developments and the existence of facilities available prior to ACP hutdown, the tail may have commercial value and may be marketable for further enrichment or other processes. However, funding provisions are made to dispose of the tails should that become necessary. 10-7

license Application f or the American Centrifuge Plant Proposed Change 2020 Contaminated portions of the buildings will be decontaminated . Structural contamination is expected to be limited to the areas indicated on Figure 10.2.J-1 (located in Appendix B) inside the CCZ of the plant. The remainder of the ACP is not expected to require decontamination. Good housekeeping practices during normal operation and cleanup activities following spills or contamination events will maintain these other areas contamination free . Decontamination activities will continue until facilities satisfy the specified radiological criteria. 10.2.2.2 Purging At the end of useful operation, the ACP is shut down and UF6 material is removed to the fullest extent possible by normal process operation. This is followed by evacuation and purging of process systems. This shutdown and purging portion of the decommissioning process is estimated to take approximately three months. 10.2.2.3 Dismantling and Removal Dismantling is the process of unbolting, disconnecting, cutting, etc., of components requiring removal. The dismantling and removal acti vities are simple but labor intensive. They generally require the use of protective equipment. The work process will be optimized, considering the following :

• Minimize spread of contamination and the need for protective equipment;
• Balance the number of cutting and removal operations with the resultant decontamination and disposal requirements;
• Optimize the rate of dismantling with the rate of decontamination plant throughput;
• Provide storage and laydown space required, as impacted by retrievability, criticality safety, security, etc.; and
• Balance the cost of decontamination with the cost of disposal.

Details of the complex optimization process will be decided near the end of plant useful life, taking into account specific contamination levels, market conditions, and available waste disposal sites. To avoid laydown space and contamination problems, dismantling will proceed generally no faster than the downstream decontamination process. The time frame to accomplish both dismantling and decontamination is estimated to be fi ve years. 10.2. 2.4 Decontamination The decontamination process is addressed separately in Section 10.2.8 of this chapter. The decommissioning estimated costs are based on decontaminating the plant to the radiological criteria for unrestricted use in 10 CFR 20.1402. 10-8

License Application for the American Centrifuge Plant Proposed Change 2020 10.2.2.5 Salvage and Sale Items to be removed from the facilities can be categorized as potentially re-usable equipment (whether contaminated or decontaminated), recoverable decontaminated scrap, and wastes. Based on a 30-year plant operating life, operating equipment is not assumed to have a significant reuse value. Uranium-bearing equipment that remains in the plant will be treated and disposed of appropriately. Smaller amounts of steel, copper, and other metals can be recovered and sold at market price. However, for conservatism, no credit is taken for salvage value in the DFP. Other items are considered waste. Wastes have no salvage value. 10.2.2.6 Disposal Wastes produced during decommissioning will be collected, handled, and disposed of in a manner similar to that described for those wastes produced during normal operation. Wastes will consist of normal industrial trash, non-hazardous chemicals and fluids, small amounts of hazardous materials, and low-level mixed (LLMW) and radioactive (LLRW) wastes. The radioactive waste will primarily be crushed centrifuge rotors, trash, and citric cake. Citric cake consists of uranium and metallic compounds precipitated from citric acid decontamination solutions. It is estimated that approximately 76,388 cubic feet of compacted radioactive waste will be generated during the decommissioning operation. This waste may be subject to further volume reduction prior to disposal. Radioactive wastes (both LLRW and LLMW) will ultimately be disposed of in licensed low-level radioactive waste disposal facilities (this includes radioactive source and byproduct material sources). Hazardous wastes will be disposed of in hazardous waste disposal facilities . Non-hazardous and non-radioactive wastes will be disposed of in a manner consistent with good industrial practice and in accordance with applicable regulations. A more complete estimate of the wastes and effluent to be produced during decommissioning will be provided in the DP to be submitted at or about the time oflicense termination. The ultimate disposal of UF6 tails remains to be determined between potential commercial uses or processing at the DOE Uf 6 conversion facility in Piketon, Ohio. However, for conservatism, the Licensee provides financial assurance to fund the estimated cost of conversion and disposal of the depleted uranium inventory. This funding is described in the DFP and is in addition to the funding requirements for decommissioning the ACP. Classified components and documents will be disposed of in accordance with the requirements of the Security ProgFtHll Plan for the Protection of Classified Matter /&Hit the American Centrifuge Plant. 10.2.2. 7 Final Status Survey A final status survey of the radiological conditions of the plant is performed to verify proper decontamination . The evaluation of the final radiation survey is based, in part, on an initial radiation survey performed prior to operation. The initial survey determines the background 10-9

License Application for the American Centrifuge Plant Proposed Change 2020 radiation of the area; providing a datum for measurements that determine any increase in levels of radioactivity . The final status survey will systematically take measurements and perform sampling to describe radioactivity over the ACP. The intensity of the survey will vary depending on the location (i.e., the buildings, the immediate area around the buildings, the controlled fenced area, and the remainder of the site). The survey procedures and results will be documented in a report. The results of the report will become part of the application to terminate the license. The format and content of the report will follow current NRC guidance (Section 4.5 of Reference 3Volume 2 of NUREG-1757). 10-10

License Application for the American Centrifuge Plant Proposed Change 2020 Table 10.2.2-1 Components for Potential Decontamination/Disposal at Decommissioning Components Description [units] Estimated Quantity 1 2 Internals: Rotor Assemblies, Motors, Suspensions and Centrifuges

• 12,000 Mounts (Classified) 2 0 Service Modules Structural Components Less than I in Process Piping length (Lft) Includes 0

Piping Tubing 3 1-16 in. Process Piping length (Lft) 271 ,840 Blowers Feed/Withdrawal Exhaust Blowers 2 Pumps Vacuum (Evacuation/Purge); RHW Pumps 119 Ventilation Ductwork; Miscellaneous WISP Ducting (ft3 ) 3 3,677 4 Surfaces Building Floors, Yards, Equipment (ft2) 2,494,819 Process valves and MIVs (excluding Sheetmetal) 18,63 1 Valves Miscellaneous valves 1,385 Source and byproduct material sources used at the Sources 11 Lead Cascade Process Equipment Feed Ovens, Autoclaves, Cold Boxes 91 Ridge Mast (RMC), Bridge, Wall and Jib Cranes; Cranes 29 Cylinder Transporters, Trolleys Scales Process Weighing Equipment 12 Compressors Process Gas Compressors 4 Machine Cooling Water HX, Freezer/Sublimers, Tails Heat Exchangers (HX) 36 Coolers Chemical traps (8 banks of 4 ), Cold Traps, Traps 71 Roughing Filters, Miscellaneous Traps Tanks (UF6) Holdup, Surge, and Dump Tanks 3 Upender Trailer Upender (X-7725)(ft3) 3 Cylinders Tails - 48G/48X (14, 10 Ton) 17,191 Cylinders Product and Feed (2.5 Ton) Gas Test Area (12B) 450 UF6Portable Carts; Buffer Storage Stands; Mass Spectrometers; Contaminant Monitors; Miscellaneous Other Equipment 69 Platfonns; and Gas Test Stand Center (GTC) Stand Stmctures Note 1: Amotu1t includes 11,520 operational units plus 480 contaminated spare centrifuges. Note 2: Centrifuge casings and service module structural steel is not considered waste. These items are to be removed, disassembled, decontaminated to NRC ' Free Release' criteria, and stored for later disposition. Note 3: Piping < l " (assumed to be instrument piping/tubing), ventilation ductwork, and heat exchangers are assumed to not be internally contaminated. Therefore, these components can be externally decontaminated and remain as part of the building Balance of Plant. Note 4: Amount of wall area (ft2) not provided, because it is not anticipated to need decontamination at the time of decommissioning. Note 5: Equipment re-utilized from operational phase (not new or purchased). Note 6: Equipment procured ( see Table C3.15 of the Decommissioning Fwtding Plan for the ACP). 10-11

license Application for the A merican Centrifuge Plant Proposed Change 2020 Components Description (units] Estimated Quantity Centrifuge Transporter~ 2 Cranes (Process Area - RMC) 5 8 Cranes, Bridge X-7725 5 2 Centrifuge Mobile Equipment 5 -l Decontamination Centrifuge Dismantling Equipment 8 Equipment (6/X-7725 and 2/X-7726 Assembly Stands)6 Cutting Machines6 2 Degreasers6 2 Decontamination Tanks 6 4 Wet Blast Cabinets6 2 Cmsher' 1 10.2.3 Management/Organization Management of the decommissioning program will assure proper training and procedures are provided to assure worker health and safety. The programs will focus on minimizing waste volumes and worker exposure to hazardous or radioactive materials. Qualified contractors assisting with decommissioning will be subject to ACP security and training requirements, and procedural controls. 10.2.4 Health and Safety Consistent with the policy during ACP operation, the policy during decommissioning is to keep individual and collective occupational radiation exposure with the ALARA principle. A Radiation Protection Program will identify and control sources of radiation, establish worker protection requirements and direct the use of survey and monitoring instruments. 10.2.5 Waste Management Radioactive and hazardous wastes produced during decommissioning will be collected, handled, and disposed of in accordance with regulations applicable to the ACP at the time of decommissioning. Generall y, procedures will be similar to those described for wastes produced during operation. These wastes will ultimately be disposed of in licensed radioactive or hazardous waste disposal facilities. Non-hazardous and non-radioactive wastes will be disposed of consistent with good industrial practice, and in accordance with appli cable regulations. 10.2.6 Security and Nuclear Material Control Requirements for physical security and for nuclear material control and accountability will be maintained during decommi ssioning in a manner similar to the program s in force during ACP operation . This includes requirements for control of classified information and classified equipment described in the Security Plan for the Protection of Classified Maffer Pr~11-fi+r at the American Centrifuge Plant and the requirements for control of nuclear material s in the Fundamental Nuclear Material Control Plan f or the American Centrifuge Plant. The DP is 10-1 2

License Application for the American Centrifuge Plant Proposed Change 2020 submitted near the end of plant life and will provide a description of revisions to these programs. 10.2. 7 Record Keeping Records important for safe and effective decommissioning of the ACP are maintained in accordance with established Records Management and Document Control procedural requirements. Information maintained in these records include:

• Records of spills or other unusual occurrences involving the spread of contamination in and around the plant, equipment, or site. Records of spills or other unusual occurrences may be limited only to instances when contamination remains after any cleanup procedures or when there is reasonable likelihood that contaminants may have spread to inaccessible areas as in the case of possible seepage into porous materials such as concrete. These records will include any known information on identification of involved radionuclides, quantities, fonns, and concentrations;
• As-built drawings and modifications of structures and equipment in areas where radioactive materials are used and/or stored, including locations that possibly could be inaccessible (e.g., buried pipes which may be subject to contamination); and
• A list contained in a single document that is updated every two years of the following :

Areas designated and formerl y designated as restricted areas as defined under 10 CFR 20.1003 . Areas outside of restricted areas that reqwre documentation under 10 CFR 70.25(g)(l). Areas outside of restricted areas where current and previous wastes have been buried as documented under 10 CPR 20.2108. Areas outside of restricted areas that contain material such that, if the license expired, the Licensee would be required to either decontaminate the area to meet the criteria for decommissioning in 10 CFR Part 20, Subpart E or would apply for NRC approval for disposal under 10 CFR 20.2002.

• Records of the cost estimate performed for the DFP, and records of the funding method used for assuring funds, including a copy of the financial assurance mechanism and any supporting documentation.

10.2.8 Decontamination The DSA, the general procedures used to decontaminate, and the expected results of decontamination are described in the paragraphs below. Table 10.2.2-1 lists the major components and structures that may need to be decontaminated to some extent at the plant. Other components and structure will generally not require any decontamination. The Licensee anticipates low 10-13

License Application for Lhe American Centrifuge Plant Proposed Change 2020 amounts and areas of actual contamination due to strict adherence to ALARA principles throughout the plant's life. There are two general methods of decontamination, which may be used to decontaminate the ACP : dry and wet. Dry involves using an always safe vacuum cleaner (vacuuming), scooping up the material with a dust pan (low abrasive materials), sweeping material up with a brush or broom, or high abrasive (chipping or wire brush). Wet decontamination involves using films of cleaning solutions with mops, squeegees, rags, or dip tanks. Although wet decontamination or a dry decontamination variation, such as dry ice blasting, may be utilized for decontamination of the ACP, these methods are not anticipated to be utilized to a significant extent, and, therefore, are not included in the DFP estimate. For decontamination and decommissioning of the ACP and establishing the associated funding, it is assumed that a dry decontamination process is utilized throughout. The actual decontamination method or methods to be utilized to decontaminate and decommission the ACP will be established based upon the site characterization survey performed during the decommissioning planning and preparation phase and will be described in the Decommissioning Plan. The DFP estimate does consider scarifying, to a 1/8-inch depth, the cylinder yard areas in their entirety as a conservative action . Any time surfaces are disturbed, such as with scarifying concrete, there is a potential to produce airborne radioactivity. To mitigate these concerns, airborne monitoring for the personnel performing the work would be provided, these individuals would be included in the internal monitoring program (urinalysis), and if the conditions exist, respiratory protection may be required . Furthermore, scarifying equipment may use a water spray to minimize dust, cool the cutting wheels, or use a limited amount of water as a media, but this is not considered to be a liquid waste as it is anticipated to evaporate to leave a dry debris for solid waste disposal . 10.2.8. 1 Decontamination Service Area The centrifuge assembly area within X-7725 facility building is identified as the DSA. The centrifuge m-ah-iRe--transport system would be used to transport the centrifuge~ t-tt-a.-A~nes- from the process buildings to the DSA. The DSA handles centrifuges, feed, withdrawal, sampling and transfer equipment to be disassembled and dispositioned along with the UF6 vacuum pumps, valves, piping, and other miscellaneous equipment. Unusable material will be destroyed . The DSA will have four functional areas: disassembly area, buffer stock area, decontamination area, and scrap storage area. Equipment in the decontamination area may include:

• Transport and manipulation equipment
• Dismantling area
• Cutting machines
• Dismantling boxes and tanks (e.g., B-25 boxes)
• Degreasers 10-14

License Application for the American Centrifuge Plant Proposed Change 2020

• Citric acid and demineralized water baths
• Contamination monitors
• Wet blast cabinets
• Crushers or size reducti on equipment
• Shredding equipment
• Scrubbing facility There is no normal operational need for the ACP to have a decontamination facility readily available.

10.2.8.2 Procedures Procedures for decontamination will be developed and approved by plant management to minimize worker exposure and waste volumes, and to assure work is carried out in a safe manner. At the end of useful plant life, some of the equipment, most of the buildings, and the outdoor areas should already be acceptable for release for unrestricted use in accordance with 10 CFR 20.1402. If these areas were inadvertently contami nated during ACP operation, they would likely be cleaned up when the contamination is discovered. This limits the scope of necessary decontamination at the time of decommissioning. The centrifuges will be processed and the following operations will be performed:

• Removal of external fittings;
• Removal of bottom flange, motor and bearings, and collection of contaminated oil;
• Removal of top flange, and withdrawal and disassembly of internals;
• Degreasing of items, as required; and
• Destruction of classified parts by shredding, crushing, burial, etc.

10.2.8.3 Results Recoverable items will be externally decontaminated and suitable for reuse except for a very small amount of internally contaminated items where recovery and reuse is not feasible. There is potentially a small amount of salvageable scrap material. Material requiring disposal will be process piping, trash, and residue from the effluent treatment systems. No problems are anticipated which will prevent the facilities from being released for unrestricted use. 10-15

License Application for the American Centrifuge Plant Proposed Change 2020 10.2.9 Agreements with Outside Organizations The decommissioning activities described herein and in the DFP provide for decontamination of the ACP for unrestricted use. As such, no agreements with outside organizations are required for control of access to the plant following shutdown and decommissioning. 10.2. 10 Arrangements for Funding This section provides a general estimate of plant decommissioning costs and UF6 tails disposition costs, as well as explains the arrangements made to assure funding is available to cover these costs. A more detailed description of these costs and the financial assurance mechanism is provided in the DFP. 10.2. 10.1 Plant Decommissioning Costs Table 10.2.J O-l , provides a summary of the cost estimates of the major decommissioning activities described in Section 10.2.2. Costs are provided in 2008 dollars with a 25 percent contingency factor added based on the NRC guidance (Reference 4Volume 3 of NUREG- 1757). As noted below, the total estimated cost to decommission the 3.8 million SWU ACP, excluding UF6 tails disposition, is $377.3 million. Since costs will likely change between the time oflicense issuance and actual decommissioning, the Licensee will adjust the cost estimate annually prior to operation of the facility at full capacity, and after full capacity is reached, no less frequently than every three years consistent with the requirements of 10 CFR 70.25(e) and recent NRC changes to financial assurance requirements for materials licensees (Referent-"e SFederal Register. Volume 192). The method for adjusting the cost estimate will consider the following :

• Changes in general inflation (e.g., labor rates, consumer price index);
• Changes in price of goods (e.g., packing materials);
• Changes in price of services (e.g., shipping and disposal costs);
• Changes in plant condition or operations; and
• Changes in decommissioning procedures or regulations.

These costs are estimated as explained below: Planning and Preparation: $3.3 million Scope to be completed in one year and includes developing and submitting a detailed DP as a license amendment for NRC review and approval. Activities anticipated during this phase include:

• Develop Project Execution Plan and Schedule (including the organization and staffing plan and needed services);

10-16

License Application/or the American Centrifuge Plant Proposed Change 2020

• Develop and submit the Decommissioning Plan;
• Develop/implement Site Characterization Plan;
• Review/approve Site Decommissioning Plan by the NRC ;
• Develop Decommissioning Activity Procedures; and
• Design Decommissioning Service Area (DSA).

Decontamination and/or Dismantling of Radioactive Facilities: $51.5 million This is based upon utilizing salary and hourly workers at their respective average cost over a five-year duration . For conservatism, decommissioning estimated costs are based on decontaminating the plant to the radiological criteria for unrestricted use in 10 CFR 20.1402. Activities anticipated during this phase include:

• Prepare the decontamination Service Area;
• Internal decontamination of facilities;
• Dismantle centrifuge~--+1-l-affi-nes to include waste segregation and staging;
• Dismantle facilities and components; and
• Tails cylinder movement/disposition to include material title transfer to DOE.

Restoration of Contaminated Areas On Plant Grounds: $0.9 million This is based upon utilizing salary and hourly workers at their respective current average cost distribution over a two-year duration . This assumes the contamination of the plant grounds from the ACP operations will be minimal. Activities anticipated during this phase include:

• External decontamination of facilities;
• Perform Health Physics surveys;
• Scarify cylinder storage yard surfaces; and
• Collect/dispose of yard debris.

Final Status Survey: $1.6 million This is based upon utilizing salary technicians at their current average cost distribution for a period of 2.5 years. Costs do not include any NRC confirmatory surveys to verify the results of the Final Status Survey. Activities anticipated during this phase include: 10-17

License Application fo r the A merican Centrifuge Plant Proposed Change 2020

• Develop/implement survey plans;
• Collect/analyze data;
• Perform confirmatory surveys;
• Develop final survey report; and
• Prepare License Amendment to terminate the license .

Site Stabilization and Long-Term Surveillance: $3.0 million As previously stated, the intent of decommissioning is to return the plant to the radiological criteria for unrestricted use. To accomplish this activity , stabilization and surveillance is required due to the number of components involved and the duration of the decommissioning effort. This scope of work occurs throughout the six year decommissioning period and involves maintenance and surveillance activities on IROFS, as required, until the license is terminated. Packing Materials, Shipping, and Waste Disposal: $61.6 million This is based upon shipping and disposal of the internals for 12,000 centrifuge~ m-aeh-tt1es----(which includes operating 1na+1+HeS-centrifuges as well as contaminated spares), feed and withdrawal equipment, and other components totaling approximately 76,388 cubic feet of solid waste, 16,225 gallons of liquid waste from the centrifuge internals and 1,728,000 cubic feet of classified waste in non-reusable packaging. Equipment and Supply: $19.6 million This includes the purchase or lease of dismantling, cutting, degreasing, and crushing equipment; decontamination tanks, wet blast cabinets, and over 20,000 containers (i.e., B-25 boxes and 55 gallon drums) . Laboratory: $1.5 million This includes labor costs for sampling, transport, testing, and analysis of samples. Indirect Services: $71.9 million This includes support services (such as laundry, janitorial, etc.,) and infrastructure costs (such as water, power, etc.J not included in other tasks. Miscellaneous: $41.6 million This includes direct costs of $2.9 million for mi cellaneous material for decommissioning and $38 .7 million for indirect costs, such as NRC review fees for the submitted DP, license fees, DOE lease fees, and business insurance. 10-18

license .,./.pplication for the A merican Centrifuge Plant Proposed Change 2020 Subtotal $256.5 million General and Administrative (6 percent) $15.4 million Contractor Profit (15 percent) 1 $29.9 million Contingency (25 percent) $75.5 million Total Plant Decommissioning Cost Estimate $377 .3 million 1 Contractor Profit= 0. 1S[Subtotal + General and Achninistrative - Other Indirect Costs (excluding insurance) - Outside Services portion ofU1e Packaging, Shipping, and Waste Disposal Costs] 10.2. 10.2 UFG Tails Disposition Costs Cost estimates to dispose of UFGtails generated during ACP operation are separate from the cost estimates to decommission the plant. As noted previously, the ultimate disposal of UF6 tai ls remains to be determined. The Licensee intends to evaluate possible commercial uses of UF6 tails before having the tails processed by the DOE UF6 conversion facility in Piketon, Ohio. UF6 tails are stored in steel cylinders until they can be processed in accordance with the disposal strategy established by the Licensee. Depending on technological developments and the existence of faci lities available prior to ACP shutdown, the tai ls may have commercial value and may be marketable for further enrichment or other processes. However, for the purposes of calculating the UF6 tails disposition cost, the Licensee assumes that the total quantity of tails generated during ACP operation are processed by the DOE UF6 conversion facility in Piketon, Ohio. For conservatism, the Licensee provides financial assurance to fund the estimated cost of conversion and disposal of the depleted urani um inventory as it is generated during ACP operation. This funding is described in the DFP and is in addition to the funding requirements for decommissioning the ACP . As with plant decommissioning, the cost estimate will likely change between the time of license issuance and actual decommissioning. The Licensee commits to adjust the cost estimate for tails disposal annually . The method for adjusting the cost estimate will consider the same factors as previously described in Section 10.2.._ l 0.1 of this chapter. At full capacity, the ACP will generate approximately 8,400 MT of UF6 tails annually. As with other decommissioning costs, the disposal cost estimate for UF6tails disposal is provided in 2008 dollars. Consistent with the recommendation in the NRC ' s guidance on decommissioning (Section A.3 .1.2.3 of Volume 3 ofNUREG-l 757Referenc-e 4), a 25 percent contingency factor is applied to the tails disposal cost estimate. The total estimated cost to dispose of UF6 tails over the 30-year license, including a four-year ramp up to full capacity and the 25 percent contingency factor, is $896.9 million. The basis for this estimate is provided in the DFP. 10-19

License Application for the American Centrifuge Plant Proposed Change 2020 10.2. 10.3 Total Decommissioning Liability The Licensee' s total decommissioning liability is the sum of the total plant decommissioning costs and the tails disposition costs. The Licensee' s total liability for decommissioning the ACP, including applicable contingencies, is: Plant Decommissioning Cost $ 377.3 million UF6 Tails Disposition Cost $ 896.9 million Total Decommissioning Liability $1 ,274.2 million 10.2. 10.4 Funding Arrangements Per the exemption request in Section 1.2.5 of this license application, the financial assurance for a portion of the decommissioning costs to include disposition of centrifuge§ machines and UF6 tails will be provided incrementally as centrifuges are built/installed and UF6 tails generated. The modular aspect of the American Centrifuge technology allows enrichment operations to begin well before the full capacity of the plant is reached . Thus, the decommissioning liability for centrifuge§ machines and UF6 tails is incurred incrementally as more centrifuge§ ffttlOO+HeS, and associated equipment, are added to the process, until such time as full capacity of the facility (i .e., 3.8 million SWU) is achieved. Once full capacity of the facility is achieved, the UF 6tails are generated at a relatively constant rate throughout the life of the plant. Full funding for decommissioning of the facilities will be provided in the initial executed financial assurance instrument. To ensure adequate financial assurance is in place as centrifuge§ machines, and associated equipment, are added to the process and placed into operation, the Licensee will forecast and update the cost estimates and provide a revised funding instrument to NRC annually to cover the upcoming year of operation . This incremental funding approach will be utilized until operation at full capacity. Once full capacity of the facility is achieved, the Licensee will annually adjust the cost estimate for UF6tails disposal and all other decommissioning costs will be adjusted periodically, and no less frequently than every three years. In this way, financial assurance will be made available as the decommissioning liability is incurred. This exemption is justified based on the unique modularity aspects of centrifuge technology that allow enrichment operations to begin well before the full capacity of the plant is reached. In addition, the NRC has accepted an incremental approach to funding disposal cost of tails for the Ggaseous f)diffusion Pplants. Financial assurance will be provided in the form of a surety method or other guarantee method as required by 10 CFR 70.25(t). The selected guarantee method is described in the DFP, included as part of this license application. In the DFP, methods are described for periodic adj ustments in the cost estimate and resulting necessary adj ustments to the funding method. 10-20

License Application for the American Centrifuge Plant Proposed Change 2020 10.J I I References

1. Appendix 1 Lease Agreement between the U.S. Department o(Energy and United States Enrichment Corporation for the Gas Centrifuge Enrichment Plant (GCEP Lease Agreement), Amendment dated May 31, 2019 2 . Federal Register, Volume 68 Number 192, Financial Assurance for Materials Licensees, Final Rule, October 3, 2003

3. HALEU Demonstration Contract Number 89303519CNE000005, awarded May 31, 2019 and definitized on October 31, 2019

    ~ .4.NUREG-1520,       Standard Review Plan for the l?eview <if tl U ce11.'it' App/1catw11.f<,r a Fuel Cycle Facilitiesv. License Applications, Revision 2March 2-002 2-:-_i_NUREG-1757, Consolidated NMSS Decommissioning Guidance, Volume 1, -Rev-i-siffll t , Decommissioning Process for Materials Licensees, Revision 2Final Report, September 2003 .

J-:.6 .NUREG-1757, Consolidated NM.£8-- Decommissioning Guidance, Volume 2, Characterization, Survey, and Determination of Radiologicah:gulation Criteria, Revision l Final Repert, .Septembt* 2GOJ 4-7.NUREG-1757, Consolidated NMSS Decommissioning Guidance, Volume 3, Financial Assurance, Recordkeeping, and Timeliness, Revision 1F'.tnal Report, Sef}tember 2003 6 8.NR-3605-0005 , Fundamental Nuclear Material Control Plan for the American Centrifuge Plant 1--9 .NR-3605-0006, Decommissioning Funding Plan for the American Centrifuge Plant 8 10. SP-3605-0041, Security Plan for the Protection of Classified Matter at the American Centrifuge Plant 11 . W . Brown (DOE) letter to Mr. Phil Sewell (USEC), Conversion and Disposal ofDepleted Uranium Hexafluoride (DUF6) Generated by USEC at the American Centrifuge Plant in Piketon, Ohio, dated February 10, 2006 9 feEi-rnl Register, Volttt11e- 68 Number 1-9--2, h+1t11-1< *i<..-d 1_,,"f',HFffllt.'~Lfol' Alt-1/t'l"f(ff:'t J,k ~ '., , rinal Rule, October 3, 2003 10-21

License Application for the American Centrifuge Plant Proposed Change 2020 Table 10.2.10-1 Plant Decommissioning Cost Estimates and Expected Duration Cost Estimate Approx. Task/Item (Millions, 2008 dollars) Percentage Planning and Preparation $3.3 1% Decontamination and/or Dismantling of

                                                                      $51 .5            20%

Radioactive Facilities Restoration of Contaminated Areas On Plant

                                                                       $0.9              1%

Grounds Final Status Survey $1.6 1% Site Stabilization and Long-Term Surveillance $3 .0 1% Packing Materials, Shipping, and Waste

                                                                      $61 .6            24%

Disposal Equipment and Supply $19.6 8% Laboratory $1.5 1% Indirect Services $71 .9 28% Miscellaneous $41.6 16% Subtotal $256.5 100% General and Administrative (6%) 15.4 Contractor Profit (15%) 29.9 Contingency (25%) $75 .5 I Total Plant Decommissioning Cost $377.3 UF6 Tails Disposal Costs $717.6 UF6 Tails Contingency (25%) I $179.4 I I Total UF6 Tails Disposition Cost $896.9 Total Decommissioning Liability $1,274.2 10-22

License Application for the American Centrifuge Plant Proposed Change 2020 11.0 MANAGEMENT MEASURES Management measures are functions that are applied to items relied on for safety (IROFS) to provide reasonable assurance that the IROFS are available and reliable to perform their functions when needed. The phrase "available and reliable," as used in 10 Code of Federal Regulations (CFR) Part 70, means that, based on the analyzed, credible conditions in the Integrated Safety Analysis (ISA), IROFS will perform their intended safety function when needed to prevent accidents or mitigate the consequences of accidents to an acceptable level . Management measures are implemented to provide reasonable assurance of compliance with the performance requirements, considering factors such as necessary maintenance, operating limits, common-cause failures, and the likelihood and consequences of failure or degradation of the IROFS and the measures. This chapter addresses each of the management measures included in the 10 CFR Part 70 definition of management measures, i.e., configuration management (CM), maintenance, training and qualifications, procedures, audits and assessments, incident investigations, records management, and other quality assurance (QA) elements. Management measures are applied in a graded approach . The degree to which management measures are applied to the IROFS is a function of the item's importance in terms of meeting the performance requirements as evaluated in the ISA. The Licensee will periodically review IROFS per the requirements of 10 CFR 70.62(a)(3) to ensure their availability, reliability, and have not changed. As the final design is developed for the American Centrifuge Plant (ACP), the management system and design approach will require that the final designs be reviewed against the ISA to ensure the ISA is bounding. As discussed in Section 1.1.8 of this license application, American Centrifuge Operating, LLC's (ACO) long-term goal is to resume commercial enrichment production consistent with market demand. The ACP design is modular, with the basic building block of enrichment capacity being a cascade of centrifuges. Modular deployment would accommodate market demand on a scalable, economical gradation. As such, the Management Measures will be implemented to support the modular deployment. The next phase of enrichment production includes the deployment of a cascade of 16 centrifuges to demonstrate production of high-assay, low-enriched uranium (HALEU) fuel for advanced reactors. The primary building/facilities directly involved in HALEU Demonstration are the X-3001 Process Building, X-3012 Process Support Building, X-7725 Recycle/Assembly Building, X-7726 Centrifuge Training and Test Facility, and X-7727H Interplant Transfer Corridor. The Licensee will notify NRC well in advance of the transition into any future phases of ACP deployment. For further plant and process specifics related to the HALEU Demonstration Program, refer to LA-3605-0003A, Addendum I of the ISA for the American Centr(fuge Plant - HALEU Demonstration. The general use of the term ACP in the remainder of this chapter is intended to refer to both the commercial ACP operation and the HALEU Demonstration. HALEU Demonstration will be specifically noted, as necessary, when the context is uniquely applicable to HALEU Demonstration. 11-1

license Application fo r the American Centrifuge Plant Proposed Change 2020 11.1 Configuration Management The Configuration Management (CM) Program for the American Centrifuge Plant (ACP) is described in the following paragraphs. 11.1.1 Configuration Management Policy In accordance with IO CFR 70.72, a CM Program is implemented to ensure that changes from the plant baseline configuration are identified and controlled to help ensure safety through consistency among the plant design and operational requirements, the physical configuration, and the plant documentation. The CM Program includes:

• Identification and documentation of IROFS;
• Organizational descriptions of duties and responsibilities; and
• Administrative controls, procedures and policies, to implement and document activities that maintain the plant' s configuration.

The goal of the CM program is to ensure that the ACP has accurate, current documentation that matches the plant's physical/functional/operational configuration, while complying with applicable requirements. 11.1.1.1 Program Overview The Piketon Engineering Manager has primary responsibility for the implementation of the CM Program for the ACP. The CM Program is applicable to the plant, structures, processes, systems, equipment, components, computer programs, and activities of personnel, regardless of the item ' s Quality Level (QL) classification. CM Program procedures provide for a graded application of resources taking into consideration :

• QL (risk significance);
• Applicable regulations, industry codes, and standards;
• Complexity or uniqueness of an item or activity and the environment in which it has to function ;
• Quality history of the item in service;
• Degree to which functional compliance can be demonstrated or assessed by test, inspection, or maintenance methods; 11-2

License Application for the American Centrifuge Plant Proposed Change 2020

• Anticipated life span;
• Degree of standardization;
• Importance of data generated;
• Reproducibility of results; and
• Consequence of failure.

QLs are established in accordance with their importance to safety as foll ows: Level Criteria QL-1 A single IROFS that prevents or mitigates a high consequence event. QL-2 Two or more IROFS that prevent or mitigate a high consequence event; or one or more IROFS that prevents or mitigates an intermedi ate consequence event. QL-3 Any item other than QL-1 and QL-2. The CM Program implementing procedures provide a management system to evaluate, implement and track each change to the plant, structures, processes, systems, equipment, components, computer programs, and activities of personnel. Procedures are util ized to ensure that the following items are addressed, in accordance with 10 CFR 70.72(a)(l) through (6), prior to implementing any change:

• The technical basis for the change;
• Impact of the change on safety and health or control oflicensed material;
• Revisions, if required, to existing operating procedures, including any necessary training or retraining before operation;
• Authorization requirements for the change;
• For temporary changes, the approved durati on (i.e., expiration date) of the change; and
• The impacts or modifications to the ISA, ISA Summary, Addendum I of the ISA Summary for the ACP - HALEU Demonstration, or other safety program information that is part of this application.

11-3

License Application for the American Centrifuge Plant Proposed Change 2020 11.1.1.2 Key Program Responsibilities The following responsibilities are identified by the responsible ACP manager and functional area: 11.1.1.2.1 Piketon Engineering Manager

• Manages and maintains the CM Program .
• The Design Authority (DA) resides with the Director, Engineering and is delegated to the Piketon Engineering Manager.l-s-tl1e delegated Design Authority (DA) The DA is responsible for:

             >"" Establishing the design requirements
             >"" Ensuring design output information ( documents and data) appropriately and accurately reflects the design input

• Performs and approves design/modification processes that implement the design control and design change control requirements established in the Quality Assurance Program Description (QAPD) for the American Centrifuge Plant, which includes controls for design bases, inputs, design verification (including analysis software),

design changes, design interfaces and design documentation and records.

• Develops Integrated Systems and Test Plans (ISTPs).
• Manages the Temporary Change Process.
• Performs reviews of facility changes in accordance with the requirements of 10 CFR 70.72.
• Establishes inspection and acceptance criteria for IROFS.
• Ensures that appropriate documents and procedures are updated to be consistent with modifications.
• Issues the documentation that defines boundaries for IROFS in the CM Program.
• Establishes and maintains a controlled database for IROFS information.
• Assists in work package preparation and identification of post-maintenance test requirements to assure that the critical design characteristics of IROFS are satisfied .

11.1.1.2.2 Director, Nuclear Safety

• Maintaining the plant's ISA.. an<l ISA Summary, and Addendum 1 of the ISA Summary for the ACP - HALEU Demonstration.

11-4

license Application for the American Centrifuge Plant Proposed Change 2020

• Identifies and defines IROFS as part of the ISA process.

11.1.1.2.3 Procurement Manager

• Develops procedures in accordance with the QAPD for procurement and control of items.
• Purchases IROFS and replacement parts only from authorized vendors and in accordance with the requirements and technical specifications as identified by the Engineering organization.

11.1.1.2.4 Operations Manager

• Ensures modifications are not made to a design or operational configuration without proper review and approval .
• Assists in pre-operational tests/checks, operational , post maintenance tests/checks and post-modification tests are performed and documented to assure IROFS are operating as intended.
• Ensures work requests or other authorizations are issued prior to maintenance, testing, or modification activities.
• Ensures the occurrence of tests, calibrations, and maintenance activities are recorded .
• Ensures approved procedures are used for operations involving the replacement or adjustment of IROFS.

11.1.1.2.5 Maintenance Work Center Supervisor

• Develops and implements procedures to execute a work control process which provides for :

             ~   Verification of data, performance or documentation where specified by the DA; and
             ~   Documentation of material used to ensure design specifications are met.

• Ensures maintenance personnel are knowledgeable of requirements for working on IROFS .
• Performs work on IROFS only after receiving issuance of an approved maintenance work package.
• n ure modification are not made to a design or operational configuration without proper review and approval.

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License Application for the A merican Centrifuge Plant Proposed Change 2020

• Identifies and transmits completed work packages for lROFS to Records Management and Document Control (RMDC) in a timely manner.
• Ensures that only accepted IROFS are stored and issued for work.
• Maintains items in a manner that complies with engineering issued requirements.

Maintenance is described in Section 11.2 of this license application. 11.1.1.2.6 Training and Procedures Manager Procedures The Procedures process is described in Section 11.4 of this license application. A procedures control program is utilized to ensure technical, operations, maintenance, and administrative procedures used to apply the CM Program processes are properly developed, reviewed, approved, revised, and controlled. Training

• Provides technical training support to plant personnel who are relied upon to operate, maintain, inspect, or modify IROFS .
• Provides training support to engineering, operations, and maintenance personnel to ensure training is updated as a result of changes to the plant.

Training and Qualification is described in Section 11 .3 of this license application. Records Management and Document Control

• Develops and operates a RMDC program that controls and issues designated documents and acts as the repository with retrieval capabilities for controlled documents and records necessary to maintain the plant's design history .
• Maintains an index of documents and software that are required to be controlled.

RMDC is described in Section 11. 7 of this license application. 11.1.1.2.7 Piketon Quality Assurance Manager

• Assists in the development and implementation of the acceptance process to assure that the critical design characteristics are satisfied for non-commercial grade IROFS .
• Assists in the acceptance process for commercial grade IROFS.
• Verifies that DA supplied acceptance criteria are met and that accepted items are appropriately identified.

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License A pplication for the A merican Centrifuge Plant Proposed Change 2020

• Establ ishes a program for in-process inspection of maintenance work in accordance with acceptance criteria contained in maintenance procedures or provided by the DA to assure that the critical design characteristics of IROFS are satisfied.
• Conducts audits and surveillances of processes that implement the CM Program, as specified by the QAPD.
• Audits vendors and suppliers in accordance with the QAPD.

11.1.1.2.8 Integrated Systems Test/Start-up Manager

• Assists in the development of and execution of the ISTPs which demonstrate the proper operation of completed systems to ensure that the systems meet their intended design functions.
• Ensures acceptance of turnover from the Engineering, Procurement, and Construction contractors/vendors to the Licensee, initial acceptance testing, and initial start-up of equipment and support systems.

11. 1.2 Design Requirements

• Design requirements are developed to support safety functions, environmental impact-oriented functions, and mission-based functions . Defense in depth practices are applied to design, to the extent practicable. This includes the preference for engineered controls over administrative controls and minimizing challenges to IROFS.

             ~   IROFS are identified in the ISA Summary and Addendum 1 of the ISA Summary for the ACP - HALEU Demonstration, with the emphasis for engineered controls over administrative controls when possible. Design requirements for IROFS or for other systems or components are required to meet the basel ine design criteria (BDC) as defined in 10 CFR 70.64.
             ~   IROFS and other systems or components that support environmental impact-oriented functions and mission-based functions are identified in System Requirements Documents (SRDs).

• The design requirements to support the IROFS and other systems or components are developed by the Piketon Engineering organization and documented in Design Input and Output D ocuments written for each system, area, and/or function. Prior to approval, these documents are reviewed to determine their adequacy, accuracy, and completeness.
• Design Input Documents provide the design basis and design requirements for the ACP.

The design basis and design requirements information i-s-are found in the ISA Summary,. Addendum 1 of the ISA Summary for the ACP - HALEU Demonstration, and SRDs.

• The DA approves Design Output Documents.

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License Application for the American Centrifuge Plant Proposed Change 2020

• After approval by the DA, the Design Output Documents provide the baseline configuration for the plant. Drawings and specifications are examples of Design Output Documents.
• Changes to any design basis or design requirements that modify the site, structures, processes, systems, equipment, components, computer programs, or activities of personnel are controlled by the change control process described in Section 11.1.4 of this license application.
• The Design Input and Output Documents are controlled documents. When modifications result in changes to these documents, the changes are controlled in accordance with the RMDC requirements described in Section 11 .7 of this license application.

11.1.3 Document Control Procedures, documents, and records control programs provide for centralized control and issuance of documents necessary for the maintenance of the ACP configuration and provide a repository for records to verify this maintenance. RMDC requirements are described in Section 11.7 of this license application. 11.1.3.1 Procedures The procedure control program assures that procedures are generated, reviewed, approved, and distributed in a controlled manner. Section 11.4 of this license application describes the procedure control program. 11.1.3.2 Records Management and Document Control A document control program ensures that changes to approved and controlled documents are:

• Issued in a timely manner;
• Distributed to controlled copy holders; and
• Maintained available to support daily work activities.

Controlled documents, in support of the CM Program, are identified in the procedures that require generation of the documents. RMDC personnel maintain an index of documents that are required to be controlled. The documents include, but are not limited to, such documents as:

• Procedures addressing activities affecting IROFS
• Design documents (e.g. , drawings, analyses, and calculations)
• The IROFS database change records 11-8

License Application for the American Centrifuge Plant Proposed Change 2020

• Engineering specification data sheets, which include the technical requirements, vendor data requirements, and if applicable, the commercial grade dedication requirements
• The ISA Summary, Addendum l of the ISA Summary for the ACP - HALEU Demonstration, and other hazard analyses
• Procedures and plans addressing emergency operating and response plans
• Records to support maintenance and verification of the plant configuration such as:

            )"' Design modification packages
            )"' Acceptance records for receipt of material , shop and field inspection of work processes supporting maintenance, repair, and testing records
            )"" Maintenance, repair, and modification construction and installation work packages
            )"' Documentation used by operations to record verification and test data The RMDC Program is described in Section 11 .7 of this license application.

11.1.4 Change Control In accordance with 10 CFR 70.72, the Licensee may make changes to the plant, structures, processes, systems, equipment, components, computer programs, and activities of personnel, without prior U.S . Nuclear Regulatory Commission (NRC) approval, if the change:

• Does not:

           ~   Create new types of accident sequences that, unless mitigated or prevented, would exceed the performance requirements of 10 CFR 70.61 and that have not previously been described in the ISA Summary; or
           )"' Use new processes, technologies, or control systems for which the licensee has no prior experience.

• Does not remove, without at least an equivalent replacement of the safety function, an IROFS that is listed in the ISA Summary;
• Does not alter any IROFS, listed in the ISA Summary, that is the sole item preventing or mitigating an accident sequence that exceeds the performance requirements of 10 CFR 70.61; and
• Is not otherwise prohibited by 10 CFR 70.72, a license condition, or an NRC order.

In accordance with the requirements of 10 CFR 70.72, the ACP implements change control processes for changes to the physical plant and for changes to procedures and controlled documents. These processes are described in Sections 11.1.4.1 and 11.1.4.2 of this license 11-9

License Application for the A merican Centrifuge Plant Proposed Change 2020 application, respectively . The Plant Safety Review Committee reviews appropriate changes to the ACP or to ACP operations, including tests and experiments, as specified in procedures. Procedures also specify the approval authority for the changes. 11.1.4.1 Control of Changes to the Physical Plant The ACP has implemented a change control process using written procedures to control changes to the physical plant. This change control process meets the requirements established in 10 CFR 70.72 and in the QAPD. Key elements of the change control process are described in the following paragraphs:

• Requests for engineering assistance, after initiator's management approval , are forwarded to the DA for:

           ~   Review to determine if the proposed change is acceptable based upon scope, applicability , justification, and/or technical merit;
           ~  Engineering approval ; and
           ~  Disposition and assignment to the appropriate engineering discipline.

• Construction Project requests for plant modifications, additions, or changes have a 10 CFR 70.72 review performed to determine if the change can be made without prior NRC approval. Information utilized in the 10 CFR 70.72 review includes the following, as appropriate:

           ~   SRDs;
           ~  Drawings/specifications; and
           ~   Other documentation providing a project description .

• Modifications (permanent and temporary) are evaluated, as appropriate, for any required changes or additions to the plant's procedures, personnel training, testing programs, or the ISA Summary, or Addendum 1 of the ISA Summary for the ACP -

HALEU Demonstration. Modifications are also evaluated, as appropriate, for potential radiation exposure, potential chemical exposure, and worker safety requirements and/or restrictions. Other areas of consideration in evaluating modifications may include: modification costs, similar completed modifications, QA aspects, potential equipment availability or maintainability concerns, constructability concerns, environmental considerations, and human factors. Modifications that establish new fissile material operations or affect existing fissile material operations are evaluated by nuclear criticality safety (NCS).

• Critical repair parts for IROFS are identified during the design process.

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license A pplication for the American Centrifuge Plant Proposed Change 2020

• Proposed plant changes receive an independent, technical review that considers the technical feasibility and merit of the proposed change and the identification of appropriate interfaces for inclusion in the change package (e.g., procedures, training, safety).

A final review prior to release for operation is conducted which verifies that:

• The safety analysis documentation is complete and approved
• Operational procedure changes, if required, are completed and other supporting procedure changes have been initiated
• Operational training and qualification changes, if required, have been completed
• Design changes are completed and any as-built changes are identified and approved
• Document changes, if required, are completed
• For temporary changes, the change duration is documented and the modified equipment tagged
• Post-modification testing has been successfully completed
• Appropriate approvals have been obtai ned 11.1.4.2 Control of Changes to Procedures and Controlled Documents Changes to procedures and controlled documents are controlled in accordance with the programs described in Sections 11.4 and 11.7 of this license application, respectively .

11.1.5 Assessments The CM Assessment Program systematically evaluates the development and effective implementation of the CM Program processes. It assesses the adequacy of the implementation of administrative requirements, the configuration of items, and their documentation. The CM Assessment Program includes both initial and periodic assessments. Both document assessments and physical assessments (system walk downs) are conducted periodically to confi rm the adequacy of the CM function . Initial assessments of the CM program are performed during readiness reviews of the ACP. The initial assessment provides for field verification of design requirements and design documentation, verification of procedures, and verification of training. Periodic assessments of the CM Program are performed as part of the commitments contained in Section 11.5 of this license application and the QAPD. 11- I l

License Application for the American Centrifuge Plant Proposed Change 2020 Any deficiencies or recommendations for programmatic improvements are identified, documented, and addressed in accordance with the requirements established in the ACP ' s Corrective Action Program, described in Section 11.6 of this license application. 11.1.6 Design Verification Many of the structures for the ACP were built by the U.S . Department of Energy (DOE) for the Gas Centrifuge Enrichment Plant program and are leased by the Licensee. Where the ACP uses existing structures, systems, or components (SSCs), the design and construction of those SSCs are verified to ensure they meet the design requirements for the ACP. The verification process includes:

• An assessment of the SSC is conducted to compare the configuration of the SSC with original drawings, construction specifications, and procedures to the extent possible and to determine the current condition of the SSCs to the extent possible. Where appropriate, system walk-downs are performed as part of the assessment.
• The assessment results are evaluated to determine if there is a discrepancy between the installed SSC and the baseline configuration information.
• If it is determined there is a discrepancy, the necessary changes are made to correct the discrepancy.
• When it is verified that the SSC, or modified SSC, meets the design requirements, the SSC is incorporated into the baseline configuration information.

11.2 Maintenance The Maintenance organization provides reliable and cost-effective maintenance of the ACP equipment. Maintenance programs related to corrective and preventive maintenance are established to provide a level of inspection, calibration, repair, replacement, and testing that ensures each IROFS will be available and reliable to perform its intended function . 11.2.1 Maintenance Organization and Administration The Maintenance Organization has policies, procedures, and programs that establish requirements and standards related to maintenance of plant equipment. These policies, procedures, and programs address:

• Personnel qualification and training
• Design/work control
• Corrective maintenance 11-12

License Application for the American Centrifuge Plant Proposed Change 2020

• Preventive maintenance
• Surveillance/monitoring
• Post-maintenance testing
• Control of measuring and test equipment
• Equipment/work history These requirements and standards are established for compliance with the QA and configuration management programs. Effective implementation and control of maintenance activities are achieved through application of these standards that are periodically reviewed and assessed for compliance.

The Operations_Manager is responsible for the overall coordination and management of the organization to provide safe and efficient performance during maintenance of plant equipment. Maintenance Work Center Supervisor reports to the Operations Manager. The Maintenance Work Center Supervisor is responsible for directing the activities of the Balance of Plant Operations Shift Supervisors and of the Maintenance Shift Supervisors in the performance of preventive, predictive, and corrective maintenance to provide support on facilities and equipment, with the e,(ceptioo-of centrifuge~ machines, _within approved programs, processes, ait4 procedures, and personnel training limitations. These activities may include maintenance of electrical equipment; electronic and pneumatic instrumentation and controls; computers and programmable controllers; and mechanical maintenance, such as valve, pump, and mechanical equipment repair and replacement. Maintenance Shift Supervisors, who report to the Maintenance Work Center Supervisors, are responsible for execution of maintenance on equipment. These responsibilities include:

• Supervision of craft personnel
• Coordination with support groups
• Ensuring that maintenance activities are appropriately planned in accordance with the work control process
• Qualification of personnel assigned to perform maintenance on equipment
• Review of work practices by craft for compliance with maintenance and plant safety procedures Craft personnel are responsible for :

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license Application for the American Centrifuge Plant Proposed Change 2020

• Compliance with safety procedures while performing maintenance
• Compliance with maintenance procedures while performing maintenance
• Completion of documentation related to the maintenance activity 11.2.2 Personnel Qualification and Training The selection and qualification of personnel in the Maintenance organization is documented and implemented through procedures. Qualification requirements are established for craft maintenance positions.

Qualification requirements for craft positions are established specific to each classification. The level of knowledge of each candidate in the related field is described in Section 11.3 .9 of this license application. Employees are required to successfully complete classroom and on-the-job training programs. An analysis of the responsibilities of each classification is performed to establish the content and type of training required for the position. This review considers each of the activities performed by each classification and the importance of that activity to safe operation of the ACP and maintenance of IROFS . Consideration is also given to the complexity of the activity, frequency performed by maintenance personnel , and the consequences if an error is made during the evolution. Skill-of-the-craft and availability of procedures or other approved technical documents that direct performance of the maintenance activity is also considered as part of this task analysis. Contractors that work on or are performing activities that could affect IROFS follow the same maintenance guidelines as maintenance personnel. In addition, a member of the ACP organization provides oversight of contractor activities. 11.2.3 Design/Work Control Maintenance of ACP equipment is performed in a manner that maintains the documented configuration of plant systems. Prior to modification of systems, it is necessary to complete actions required by Section 11.1 of this license application. A work control process establishes the necessary control, review, and approval process to maintain the documented configuration of ACP systems. The need for maintenance is identified when an equipment owner initiates a request for work or by the generation of preventive maintenance (PM) tasks or surveillances. The activity described by the request is evaluated to determine the class of work specified for the item requiring maintenance. The Piketon Engineering organization classifies plant equipment to a specific QL. QLs are established in accordance with the equipment's relation to safety as determined by the ISA or Addendum 1 of the ISA Summary for the ACP - HALEU Demonstration. Additional information regarding the graded approach taken to determine the QL of an item is found in Section 11.1 of this license application and in Section 2.0 of the QAPD. 11-14

License Application for the American Centrifuge Plant Proposed Change 2020 The QL of an item requiring maintenance establishes the level of planning, extent of reviews, and approval required to perform the maintenance task. A work package is developed to direct and document maintenance activities involving QL-1 and QL-2 items. Work packages contain, as a minimum, a task description, approved work instructions or procedure, post-maintenance tests and equipment history documentation. The package contents may also include equipment drawings, vendor manuals, and safety permits. Compensatory actions are established prior to an IROFS being removed from service for maintenance. Minor maintenance may be performed on equipment classified as QL-3. Such activities can normally be considered within the skill and training of the craft. These minor maintenance activities do not require work instructions, procedures, or development of a work package. A QL-3 work package is required when the maintenance activity would result in a change to or creation of a quality record or a change to the configuration of the system or for a complex evolution, even though working on a non-safety system . The planning process addresses support required of other ACP organizations. The repair and/or replacement of IROFS are performed with like-for-like parts or substitute parts approved by the .Piketon Engineering organization. Modifications to ACP systems may only be performed following evaluation and approval of the Piketon Engineering organization. The work package to perform the maintenance activity is reviewed and approved by the appropriate disciplines. Appropriate technical and safety reviews and approvals are performed. At a minimum, review and approval of a representative from maintenance and the equipment owner is required before a work package can be used to perform maintenance on ACP equipment. The Piketon Engineering organization is required to review and approve work packages created for maintenance of QL-1 and QL-2 items and packages developed for modification of ACP systems. Maintenance activities are scheduled through an established work control process. The equipment owner establishes priorities for maintenance in his/her area of responsibility . A schedule is created and published which establishes a date for execution of the maintenance activity. The work is scheduled in advance to accommodate completion of the planning process. The process accommodates emergent, high priority work. Operations authorizes the performance of maintenance and removal of an IROFS from service. Operations is also responsible for ensuring safe operations during removal of IROFS from service, including establishing any necessary compensatory measures. Operations is notified upon completion of maintenance activities. The work control process provides configuration control of ACP equipment. This process requires an evaluation for availability of:

• Qualified personnel to perform the maintenance;
• pproved work instruction and/or procedure ;

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License Application for the American Centrifuge Plant Proposed Change 2020

• Approved parts or substitutes;
• Drawings; and
• Safety permits.

Other documentation related to the maintenance activity may be included in the package. 11.2.4 Corrective Maintenance Corrective Maintenance is the action to check, troubleshoot, and repair equipment that has degraded or failed. The identification, prioritization, planning, and scheduling of corrective maintenance activities are accompli shed following the work control process described in Section 11.2.3 of this license application. Corrective actions are performed to remediate unacceptable performance deficiencies in an IROFS and to eliminate or minimize the recurrence of these deficiencies. 11.2.5 Preventive Maintenance Preventive Maintenance (PM) is the activity performed on a periodic basis to prevent failures, facilitate performance, and maintain or extend the life of equipment. PMs help ensure that IROFS are avai lable to perform their function and are reliable. The bases for PM tasks are developed through a review of manufacturer recommendations, available industry standards, and historical operating information, where avail able. The rationale for any deviations from industry standards or manufacturer's recommendations is documented. PMs are included in the work control process to facilitate planning, scheduling, and execution of these tasks. The identification, prioritization, planning, and scheduling of preventive maintenance activities are accomplished following the work control process described in Section 11.2.3 of this license application. Establishment of a PM task is coordinated by engineering and maintenance and requires input from various disciplines within the Piketon Engineering organization, as well as operations and maintenance personnel, as appropriate. The formal documented bases for the tasks are developed, evaluated, and approved by the Piketon Engineering organization. PM tasks may be changed, new tasks added or deleted, and recommendations made by operations, maintenance, or engineering personnel. Changes to tasks may be warranted as a result of a review of a system ' s performance. Feedback from PM, corrective maintenance, and incident investigations is used, as appropriate, to modify the frequency or scope of a PM activity. Specifically, preventive measures to alleviate premature failure may be added to the PM activity, or a reduction in frequency of a particular PM due to as-found conditions indicating that the PM is occurring more often than necessary, may be initiated. 11.2.6 Surveillance/Monitoring Surveillances and monitoring at specified intervals are performed to verify the proper operation of IROFS and to measure the degree to which IROFS meet performance specifications. 11-16

License Application for the American Centrifuge Plant Proposed Change 2020 These surveillances are in the form of performance checks, calibrations, tests, and/or inspections. The ISA Summary, or Addendum 1 of the ISA Summary for the ACP - HALEU Demonstration identifies the IROFS that are credited to be available and reliable to perform their design function for mitigation of credible events. The Surveillance Program provides a periodic check of the ability of these IROFS to perform their design safety function when called upon to do so. The Surveillance Program design adheres to the 10 CFR 70.64, Inspection, Testing, and Maintenance Baseline Design Criteria. Surveillances are included in the work control process to permit timely planning, scheduling, establishment of system or plant conditions, execution of the activity, and creation of documentation that identifies the results of the surveillance. The established frequencies are determined by the IROFS degree of safety importance. The results of surveillance activities are trended to support the determination of performance trends for IROFS. When indicated by potential performance degradation, preventive maintenance frequencies are adjusted or other corrective actions taken as appropriate. 11.2. 7 Functional Testing A post-maintenance testing (PMT) program is established to provide assurance IROFS that require a work package will perform their intended function following maintenance activities. This test confirms that the maintenance performed was satisfactory, the identified deficiency has been corrected, and the maintenance activity did not adversely affect the reliability of the IROFS. This test is performed with acceptable results prior to return of the equipment for service. PMT requirements are developed and included in work packages during the work planning process. The Piketon Engineering organization may provide support to the Operations and Maintenance organizations in identifying PMT requirements. The PMT meets applicable codes and technical requirements and specifies acceptance criteria. The results of the PMT are documented and retained in the work package with other documentation generated during the maintenance evolution. 11.2.8 Control of Measuring and Test Equipment Maintenance programs include control of measuring and test equipment (M&TE) used during maintenance of ACP equipment. These programs require M&TE to be properly controlled, calibrated and adjusted, if necessary, at specified periods. The following are elements of the M& TE Control Program :

• M&TE is assigned a unique identifier
• Calibration intervals are defined
• M&TE is labeled to identify calibration/certification status 11-17

License Application for the A merican Centrifuge Plant Proposed Change 2020

• An M&TE inventory is maintained
• M&TE determined to be out of tolerance during calibration is identified and an investigation conducted of equipment use since the previous calibration
• Calibration records are retained
• Control and storage requirements are defined for M&TE Standards used for calibration of M&TE have the required accuracy, range and stability for the application. These standards are certified and traceable to the National Institute of Standards and Technology. If no national standard exists, the bases for calibration is documented and approved by the Pi--lret-oo-Engineering organization.

Additional requirements and standards are established as necessary to ensure compliance with Section 12.0 of the QAPD. 11.2.9 Equipment/Work History Maintenance programs include data collection in the work control process. Maintenance on an IROFS requires the preparation of a work package that contains an equipment history form . This form is used to collect information from the craft personnel that are performing PM and corrective maintenance activities on an IROFS. The work package also contains a work-in-progress log used to document actions taken during the maintenance activity. This documentation provides information regarding the as-found condition of an IROFS . This data is used to identify the need for modifications and improvements for the maintenance program, to improve the reliability of an IROFS, and to ensure maintenance personnel are devoting their efforts to activities important to safety. The information obtained from work packages is retained in a database for historical reference. The Piketon Engineering organization may use this database to evaluate the reliability of IROFS . This data, in addition to other indicators (e.g., results of incident investigations, the review of failure records required by 10 CFR 70.62(a)(3), and identified root causes) of item performance allow for a thorough review to determine if modifications to a system or a change in the maintenance program is necessary to ensure that IROFS are reliable and available when called upon. The actual documentation generated at the time of the maintenance evolution is retained in the work package and is controlled according to RMDC program practices. 11.3 Training and Qualification The Training and Qualification program is designed to ensure that those personnel who perform activities relied on for safety have the applicable knowledge and skills necessary to design, operate, and maintain the plant in a safe manner. The Performance Based Training (PBT) methodology is used for those tasks associated with the design, modification, operation, or 11-18

Licen e Application for the American Centrifuge Plant Proposed Change 2020 maintenance of IROFS identified in the ISA Summary, or Addendum l of the ISA Summary for the ACP - HALEU Demonstration. Personnel are indoctrinated, trained and tested as necessary to ensure that they are qualified on practices important to public and worker safety, safeguarding of licensed material, and protection of the environment. 11.3.1 Organization and Management of the Training Function The Training and Procedures Manager is responsible for establishing procedures governing the application of the PBT methodology for the analysis, design, development, implementation and evaluation of the training programs. Training personnel are assigned by the Training and Procedures Manager to interface with line managers for training development and implementation. Instructors and subcontractors hired to develop training materials have ready access to designated subject matter experts (SMEs) who assist them when developing training materials. Training program materials are reviewed and approved by SMEs, training, and line management prior to implementation. The functional organization managers are responsible for defining the job-specific training needs and ensuring completion of indoctrination, training~ and qualification for personnel within their organization. Training attendance is tracked by training and line management. The training group notifies line management of personnel who have not successfully completed initial training or who are past due for identified continuing training. Line management is responsible for placing work restrictions or removing employees from duty where training is deficient. Workers relied upon to design, operate, or maintain IROFS are trained and evaluated for qualifications prior to assignment of these duties. Initial training contains the classroom and on-the-job training (OJT) necessary to provide an understanding of the fundamentals, basic principles, systems, procedures, and emergency responses involved in an employee's work assignments. Initial task or duty area qualification is granted by line management based on successful evaluation of the employee's mastery of the learning objectives presented during the training. Maintenance of qualification is contingent upon successful completion of continuing training and/or through satisfactory OJT evaluations. Personnel may be exempted from training as defined in training procedures. New hires or position incumbents may be considered for exemption from segments of classroom training and OJT. Exemptions are based on one of the following methods:

• Management review of an individual's prior training records and/or job performance history provides information demonstrating that the individual has achieved the necessary required skills; or
• Employee demonstrates minimum knowledge requirements by passing module examination in lieu of training (test-out); or 11-19

License Application for the American Centrifuge Plant Proposed Change 2020

• Employee demonstrates minimum skills/proficiency requirements by successfully completing task performance evaluations in lieu of OJT.

Training materials are linked to the CM system to provide reasonable assurance that design changes and modifications are accounted for in the training. The training materials are matrixed to procedures such that design changes or plant modifications are analyzed by line and training personnel for impact on training. Training attendance records, examinations, employee qualification records, and program needs are maintained in an accurate, auditable manner to document each employee's training. The programmatic and individual training and qualification records are maintained in accordance with RMDC guidelines. Plant functional organization managers develop and maintain a description of each individual ' s training requirements within their organization. These requirements are identified in individual Training Requirement Matrices (TRMs) approved by the line and training management. The TRMs include training required by regulatory and or corporate requirements in addition to the applicable Performance Based Training Requirements. Plant personnel , contractors, and visitors receive the following training as applicable to their position or function :

• General Employee Training for persons who require unescorted access (Section 11.3 .1.1).
• Security Education is provided to personnel requiring plant access (Section 11 .3.1.2).
• Radiation Worker Training for personnel whose job requires them to have unescorted access to radiological restricted areas (Section 11.3.1.3).
• Nuclear Criticality Safety Train ing for personnel who handle or manage the handling of fissile material and work within Fissile Material Operations Areas (Section 11 .3.1.4).
• Environmental, Safety, and Health Training for those persons who have training requirements defined by laws and regulations (as defined in Section 11.3 .1.5).
• Operations and Maintenance Personnel Training for those persons relied upon to operate or maintain IROFS . This training includes the operations and maintenance first line supervisors. (Section 11.3.1.6).
• System Engin eer Training for those persons who review design modifications to IROFS (Section 11 .3.1.7).
• Nuclear Criticality Safety Engineer/Specialist Training for those persons who perform the Nuclear Criticality Analyst functions described in Chapter 5.0, Nuclear Criticali ty afety, of thi li cen e application ( ection 11.3 .1. 8).

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License rlpplication for the American Centrifuge Plant Proposed Change 2020

• Health Physics Technician Training for those persons re ponsible for the evaluation of radiological conditions in the plant and the implementation of the necessary radiological safety measures identified in Chapter 4.0, Radiation Protection, of this license application (Section 11.3 .1.9).
• Laboratory Technician Training !commercial ACP operations only) for those persons who work in the laboratory technician classification (Section 11.3 .1.10).
• Fire Protection and Emergency Management Training for those persons identified in the Emergency Plan for the American Centrifuge Plant (Section 11.3.1.11).
• Visitor Site Access Orientation is provided for plant visitors who are escorted. It utilizes self-study of an orientation handbook and covers the following general information :

             ~    Driving Rules
             ~    Compliance with postings and signs
             ~    Use of eye, head, hearing, and respiratory protection
             ~    Emergency Phone Numbers
             ~    Radiological protection concerns
             ~    Emergency Preparedness
             ~    Security requirements and limitation of access and items prohibited 11.3.1.1 General Employee Training General Employee Training (GET) provides awareness level training on the hazards and proper response to alarms that a person may encounter. It is required for personnel having unescorted access to the plant. GET includes the following subject areas:

• General Employee Radiological Safety
• NCS
• General Topics
• Hazard Communication
• Emergency Preparedness 11.3.1.1.1 General Employee Radiological Safety General Employee Radiological Training covers the individual ' s responsibilities for maintaining exposures to radiation and radioactive materials in accordance with the as low as reasonably achievable (ALARA) philosophy. Thi s training reviews natural background and manmade sources of radiation, the whole body radiation dose limit for non-radiological worker ,

the potential biological effects from chronic radiation doses, embryo and fetus protection, ALARA 11-21

License Application for the American Centrifuge Plant Proposed Change 2020 concepts and practices, and methods used to control radiological materials and contamination. If a person requires unescorted access to a radiological restricted area, additional radiological safety training is provided as discussed in Section 11 .3.1.3 of this license application. 11.3.1.1.2 Nuclear Criticality Safety An overview of the NCS program is provided. The training emphasizes the prevention of accidental nuclear criticality, describes the hazards and risks of a nuclear criticality accident, explains NCS responsibilities, and teaches the proper response to a nuclear criticality alarm. Additional NCS trammg based on American National Standards Institute (ANSI)/American Nuclear Society (ANS) ANSI/ANS-8 .20-1991 , American National Standard for Nuclear Criticality Safety Training, is provided for personnel who handle or manage the handling of fissile material and work within Fissile Material Operations Areas. 11.3.1.1.3 General Topics General Topics include a general overview of: (1) health and safety awareness programs; (2) the employee's rights and responsibilities and the employer's duties as defined by laws and regulations; and (3) use of procedures and conduct of operations. 11.3.1. 1.4 Hazard Communication The purpose of this awareness-level trammg is to inform personnel that hazardous chemicals are present in the work place and to help them understand the function of warning labels and signs, Material Safety Data Sheets/Safety Data Sheets, and the written Hazard Communication Program . Additional chemical safety training is provided to those personnel who handle or supervise the handling of hazardous chemicals identified in Chapter 6.0, Chemical Process Safety, of this license application. 11.3.1.1.5 Emergency Preparedness This training introduces personnel to basic emergency response E+H-et:gel-ley---Pl-att-elements including: (1) emergency plan safety objectives and priorities; (2) ways to report emergencies; (3) recognition and correct responses to plant alarm signals; (4) evacuation guidelines for radiological and non-radiological emergencies; (5) personnel accountability procedures; (6) fire extinguisher familiarization ; and (7) personnel responsibilities during emergencies. 11.3.1.2 Security Education Security Education briefings are described in the Security Program for the American Centrifuge Plant. These include Initial Briefings, Refresher Briefings, Termination Debriefings, and Foreign Travel Briefings. 11-22

License Application fo r the American Centrifuge Plant Proposed Change 2020 11.3.1.3 Radiation Worker Training Radiation Worker Training is a biennial training requirement for personnel whose job requires them to have unescorted access to radiological restricted areas. The training includes a comprehensive curriculum consisting of the following, as appropriate:

• Fundamentals of atomic structure, radiological definitions, types of ionizing radiation, units of measurement, dose, and dose rate calculations
• Biological effects of ionizing radiation including cell sensitivity and chronic and acute exposure
• Radiation work permit applications and use
• Radiation limits for occupational and non occupational workers as well as the general public
• ALARA practices for protection from exposure to radiation or radioactive materials
• Personnel Monitoring Programs in place to monitor the worker's exposure to radiation
• Radioactive Contamination Control to minimize and control the spread of contamination
• Radiological Postings and Controls for familiarization with the signs and postings in the work area
• Emergencies involving radiological material and the correct response
• Chemical Toxicity of Soluble Uranium Compounds This training includes knowledge examinations and practical factor examinations of the personal protective equipment, personnel monitoring, and radiation measurements, if needed.

Radiation Worker Training is reviewed and approved by the Radiation Protection Manager. The extent of the course material is commensurate with the potential for exposure. The training program is reviewed and evaluated every two years. 11.3.1.4 Nuclear Criticality Safety Training NCS training based on ANSVANS-8.20-1991 is provided for personnel who manage, work in, or work near hand~ or man-age the handling of fissile material and weFk wi-tltln-Fissile Material Operations Areas. This training is reviewed and approved by the NCS technical staff and includes a di scussion of the following :

• The fission process
• Controllable factors and examples of their application at this plant 11-23

License Application for the American Centrifuge Plant Proposed Change 2020

• NCS postings
• NCS emergency procedures
• Consequences of historical criticality accidents Personnel are trained to report defective or anomalous NCS conditions and to perform actions only in accordance with written, approved procedures. Personnel are trained that unless a specific procedure deals with the situation, they will take no action until the NCS personnel have evaluated the situation and provided recovery guidance. NCS refresher training is required every two years.

Managers of personnel described above receive additional training on the managerial responsibilities relating to NCS. In addition to demonstrating a basic knowledge ofNCS concepts, the principles associated with the management of fissile material workers, and the oversight responsibilities of fissile material operations, NCS training for managers includes the following topics:

• Description of the plant's nuclear criticality safety policy;
• Explanation for the use of check li sts, sign-off sheets, and documentation in the execution of procedures that are pertinent to criticality safety;
• Discussion of relevant procedures that pertain to criticality safety with em phasis given to criticality safety limits, controls, and emergency procedures;
• Description of the policy that relates to situations not covered by procedure and to situations in which the safety of the operation is in question; and
• Emphasizing the fact that employees are to be informed of their right to question any operation they believe may not be safe.

11.3.1.5 Environmental, Safety, and Health Training This training covers environmental, worker safety, and health subject areas required by appli cable local, state and federal regulations. It is provided to personnel commensurate with their job assignments. Specific modules identified as required compliance training for plant employees are contained in each individual ' s training requirement matrix. Some of the areas include:

• Radiological Worker Safety
• NCS
• Respiratory Training 11-24

License Application for the American Centrifuge Plant Proposed Change 2020

• Hearing Conservation
• Occupational Safety and Health Administration (OSHA) Hazard Communication
• Hoisting and Rigging
• Mobile Equipment Operations
• Lockout/Tagout Work Permits
• Safety and Health Work Permits
• Resource Conservation and Recovery Act for Hazardous Waste Generators
• OSHA Hazardous Waste Operations and Emergency Response Standard
• Personal Safety
• Spill Prevention Control and Countermeasure Plan 11.3.1.6 Operations and Maintenance Personnel Training Training is designed, developed, and implemented to assist plant employees in gaining an understanding of applicable fundamentals, procedures, and practices specific to the plant. It is also used to develop the skills necessary to perform assigned work in a safe manner. If a task is identified to operate or maintain an IROFS, then the PBT methodology is used. Initial and continuing training is provided for the following operations and maintenance job categories reli ed on to operate and/or maintain IROFS.

11.3.1.6.1 Operations Technician This program is designed for personnel who monitor and operate centrifuge feed, withdrawal, product, equipment and supporting systems. They operate systems necessary to support the plant, perform integrated system testing, execute valving orders, adjust equipment settings, start-up, and shutdown equipment. The Operations Technician also assemble, transfer, install, repair, and test centrifuge~;lnllttfte5. The Operations Technician training and qualification program is separated into three sequential phases:

• Phase I provides classroom training on basic fundamentals and consists of the following: Centrifuge Operations Orientation; Uranium Enrichment Technology; Operating Principles and Theory of Centrifuge Equipment; Process Control; and Process Support Systems.

11-25

License Application for the American Centrifuge Plant Proposed Change 2020

• Phase II provides classroom and OJT dn the design, assembly, transport, and repair of centrifuge~ ma-chines.
• Phase III provides classroom and OJT on the IROFS identified in the ISA Summary,.

or Addendum l of the ISA Summary for the ACP - HALEU Demonstration; NCS limits and controls; equipment operations; support systems; and normal, off-normal, and emergenc-y alarm response operating procedures for the plant. 11.3.1.6.2 Operations Shift Supervisor This program is designed for personnel who supervise the Operations Technician and make operational decisions during normal , off normal, and emergency operations. The Operations Shift Supervisor is the senior person on shift and directs equipment start-up, shutdown, and changes in system alignments. The Operations Shift Supervisor training and qualification program is separated into four sequential phases:

• Phase I provides classroom training on basic fundamentals and consists of the following : Centrifuge Operations Orientation; Uranium Enrichment Technology; Operating Principles and Theory of Centrifuge Equipment; Process Control; and Process Support Systems.
• Phase II provides classroom and OJT on the design, assembly, transport, and repair of centrifuge~ machines.
• Phase ill provides classroom and OJT on the IROFS identified in the ISA Summary,_

or Addendum l of the ISA Summary for the ACP - HALEU Demonstration; NCS limits and controls; operations; support systems; and normal , off-normal, and emeFgency alarm response operating procedures for the plant.

• Phase IV provides classroom and OJT on the supervisory roles and responsibilities for the safe operation of the plant.

11.3.1.6.3 Maintenance Support Technician This program is designed for maintenance pei:-sonnel who service and repair computers, programmable controllers, and electrical, electronic, and pneumatic support systems and components. The Maintenance Support Technician training and qualification program is separated into three sequential phases:

• Phase I provides classroom tra1mng on Centrifuge Operations Orientation and Operating Principles and Theory of Centrifuge Equipment.
• Phase II provi des classroom and OJT on the plant electrical , instrument, and electronic control systems and components.

11-26

License Application for the American Centrifuge Plant Proposed Change 2020

• Phase III provi des classroom and OJT on maintenance procedures, programs, and practices.

11.3.1.6.4 Maintenance Technician This program is designed for maintenance personnel who install, remove, repair, and service mechanical equipment and systems in the field and in shop locations. The Maintenance Technician training and qualification program is separated into three sequential phases:

• Phase I provides classroom training on Centrifuge Operations Orientation and Operating Principles and Theory of Centrifuge Equipment.
• Phase II provides classroom and OJT on the plant mechanical systems and components.
• Phase ID provides classroom and OJT on maintenance procedures, programs, and practices.

11.3.1.6.5 Maintenance Shift Supervisor This program is designed for the supervisors of the Maintenance and Maintenance Support Technicians. The Maintenance Shift Supervisor training and qualification prograin is separated into four sequential phases:

• Phase I provides classroom trammg on Centrifuge Operations Orientation and Operating Principles and Theory of Centrifuge Equipment.
• Phase II provides classroom and OJT on the plant mechanical, electrical, instrument, and electronic control systems and components.
• Phase III provides classroom and OJT on maintenance procedures, programs, and practices.
• Phase IV provides classroom and OJT on the supervisory roles and responsibilities for the safe operation of the plant.

11.3.1. 7 System Engineer Training System Engineer training is provided to those persons who provide engineering support; review of the design and modi fications of IROFS; and review process equipment operational parameters, analyze the data and determine equipment settings. System Engineers are responsible for reviewing design proposals and modifications; ensuring that the appropriate documents and procedures are updated to be consistent with modifications; and assisting in work control preparation and identification of post-maintenance test requirements for IROFS. The System Engineer has, as a minimum, a bachelor's degree in engineering or the physical sciences or equivalent technical experience, and three years of nuclear experience. The training is based on a 11-27

license Application for the A merican Centrifuge Plant Proposed Change 2020 review of job analysis data, training requirements for specific systems, and existing training materials. 11.3.1.8 Nuclear Criticality Safety Engineer Training Qualified Nuclear Safety personnel administer Nuclear Criticality Safety Engineer training and qualification. Training is based on ANSI/ANS-8 .20-1991 and ANSUANS-8 .19---19962014, Administrative Practices for Nuclear Criticality Safety. NCS procedures define educational and experience prerequisites, along with required training courses and OJT activities to be completed prior to qualification. 11.3.1.9 Health Physics Technician Training Health Physics support training and qualification is administered in accordance with guidelines provided in the Training Development and Administrative Guide (TDAG) for Health Physics Technicians. It utilizes the performance ::based training methodology and applies to those individuals, both plant and contractor, who are engaged in the evaluation ofradiological conditions in the plant and the implementation of the necessary radiological safety measures as they apply to nuclear plant workers and members of the general public. 11.3.1.10 Laboratory Technician Training [commercial ACP operations only] Laboratory support training and qualification is administered in accordance with the guidelines set down in the TDAG for the Laboratory and Technician Training Program. The training utilizes the performance-:based training methodology . Training is provided in the areas of Laboratory Controls and Standards, Mass Spectrometry, Process Services, Chemical Technology, Uranium Sampling, and Uranium Analysis. 11.3.1.11 Fire Protection and Emergency Management Training 11.3.1.11.1 Fire Protection Training State certification requirements provide the basis for firefighter trammg programs. Emergency medical response personnel meet requirements for state certification as emergency medical technician (these are usually also firefighters) . Qualified instructors provide a range of classroom and hands-on training to maintain standards of performance for response personnel. Training needs are reviewed annually and the training program modified to meet identified needs. Drills are conducted quarterly, as part of the Emergency Plan training. 11.3.1.11.2 Emergency Management Training Training is conducted in the areas of: 11-28

License Application for the American Centrifuge Plant Proposed Change 2020

• Specialized en:l-ei:geticy Planemergency response training for the Emergency Response Organization
• Off-site Emergency Management training Emergency Management drills and exercises are conducted to develop, maintain, and test the response capabilities of personnel, facilities, equipment, and training.

11.3.2 Analysis and Identification of Functional Areas Requiring Training A needs/job analysis is used to identify the tasks affecting worker or public safety, safeguards of regulated material, or protection of the environment as identified in the ISA Summary, or Addendum 1 of the ISA Summary for the ACP - HALEU Demonstration. The analysis is conducted with applicable program area SMEs and training personnel. The training programs for the following plant job positions/worker classifications are based on a needs/job analysis:

• Operations Technician
• Operations Shift Supervisor
• Maintenance Technician
• Maintenance Support Technician
• Maintenance Shift Supervisor
• System Engineer
• NCS Engineer
• Health Physics Technicians
• Laboratory Technicians The plant-specific task li st is developed for each of the above positions/classifications. The task lists are analyzed based on input from line management and SMEs, rating each task on degree of difficulty, importance of the task, and frequency of task performance. From this analysis, the tasks are selected for training based on their rating. The ratings are:
• Overtrain - requires initial and continuing training;
• Train - requires initial training; 11-29

License Application for the American Centrifuge Plant Proposed Change 2020

• Pre-train or just-in-time - requires training but 1s not taught until that specific knowledge or skill is needed; or
• No train -formaJ training is not required.

The tasks selected for training are matrixed to the associated procedures and training materials. The matrices are reviewed and updated in conjunction with the periodic review of the associated procedures. Procedure changes, equipment changes, job scope changes, pl ant modifications and other changes affecting task performance are monitored and evaluated for their impact on the development or modification of initial and continuing training programs. The affected training materials are modified or new materials developed, based on the significance of the change, and modifications are documented in the program files . The training materials are updated prior to conducting training. 11.3.3 Position Training Requirements Plant procedures and individual TRMs delineate initial and continuing training requirements for employees. The training program requirements for those positions relied on for safety or personnel who perform actions that prevent or mitigate accident sequences described in the ISA Summary, or Addendum 1 of the ISA Summary for the ACP - HALEU Demonstration, are defined in TDAGs. The TD AGs include :

• Organization and Administration Responsibilities
• Trainee Selection Criteria, including the minimum educational, technical , experience, and physical requirements
• Course Loading for Initial and Continuing Training
• Test/Evaluation Guidelines
• Training and Evaluation Documentation Guidelines
• Training Courses or Modules for Specific Qualification Areas 11.3.4 Developm ent of the Basis for Training, Including Obj ectives Learning objectives are established to identify the training content and to define satisfactory trainee performance for the task or group of tasks selected for training from the job analysi . Learning objectives state the requisite knowledge, skills, and abilities the trainee must demonstrate. The conditions under which the required actions take place and the standards of performance required of the trainee are also determined in development of the learning objective .

11-30

License Application for the American Centrifuge Plant Proposed Change 2020 Leaming objectives are sequenced within training materials based on their relationship to one another. Leaming objectives are documented in lesson plans and training guides and are revised as necessary based on changes in procedures, plant systems/equipment, or job scope. 11.3.5 Organization of Instruction, Using Lesson Plans and Other Training Guides Leaming objectives derived from the rated task lists are analyzed to determine the appropriate training setting. Classroom lesson plans, OJT guides, or other instructional materials are procured or developed based on this instructional analysis and design. Lesson plans and other training guides provide the guidance and structure necessary to ensure consistent delivery of training material from trainer to trainer and class to class. The lesson plans and other training guides provide the evaluation tools necessary to ensure mastery of the learning objectives. Classroom lessons are used primarily to provide cognitive learning on the fundamentals, theory, basic operating and maintenance principles, individual system , system inter-relations, safety requirements, and processes used in the plant. Other forms of instructional materials, such as video, computer-based training and self-study may be used as alternatives or supplements to classroom instruction. Classroom lesson plans, OJT guides, and other instructional materials receive technical reviews by designated SMEs and instructional reviews by training management as part of the approval process. The responsible line managers and Training and Procedures Manager approve training materials before issuance. Designated SMEs or technical trainers provide classroom training and/or OJT evaluations. These personnel receive training and are qualified on the instructional methods and techniques applicable to the training setting. 11.3.6 Evaluation of Trainee Learning Within the job position/worker classification, training programs are logical instructional blocks or "modules" presented in such a manner that specific learning objectives are accomplished. Trainee progres is evaluated by line and training management through a variety of performance demonstrations such as written examinations, oral examinations, and practical tests to ensure mastery of the job performance requirements or learning objectives contained in these modules. Comprehensive qualification programs contain periodic evaluations of trainee performance. Remediation is provided as appropriate. 11.3.7 Conduct of On-The-Job Training OJT is a systematic method of providing training on job-related skills and knowledge for a position. This training is conducted in the work environment and demonstrates actual task performance whenever practical. When the actual task cannot be performed, the conditions are 11-3 1

License Application for the American Centrifuge Plant Proposed Change 2020 documented and the task may be simulated. Applicable tasks and related procedures for each technical area provide the input for the OJT that is designed to supplement and complement training received through formal classroom or laboratory training and to ensure personnel are qualified to perform their assigned tasks. 11.3.8 Evaluation of Training Effectiveness Systematic evaluations of training effectiveness and its relation to on-the-job performance are used to ensure that the training program conveys required skills and knowledge and to revise the training, where necessary, based on the performance of trained personnel in the job setting. The student feedback of the training received and the line manager' s evaluation of the student's performance on the job after training is completed are utilized to determine the training effectiveness and areas for refinement. Student feedback occurs at several points in the training program . At the completion of training, the student evaluates the instructor and course. Post training evaluations of the effectiveness of training is requested from students and supervisors after completion of training. Each of these evaluations is specified in plant training procedures. Plant design changes, modifications, or changes in task performance are analyzed by line and training personnel for impact on training. Corrective actions involving training are assigned, scheduled and tracked to completion. Lessons learned, which have an impact on initial training, are factored into training materials prior to the delivery of the next training session . Line and training management conduct self-assessments and evaluations of the individual training programs. QA auditors provide additional assessments through the audit program. These assessments and evaluations are used to determine training program strengths and weaknesses for continuous improvement of the training. 11.3.9 Personnel Qualification Personnel are selected for entry into the trammg and qualification programs in conformance with the established general employment policies. The minimum education; experience, and qualification requirements for engineers, and technical professional staff, technicians, and maintenance personnel are described below. The minimum education, experience, and qualification requirements for managers and supervisors are provided in Chapter 2.0, Organization and Administration, of this license application . Engineers and other technical professional staff, who affect the design, modification, operation, or maintenance of IROFS identified in the ISA Summary, or Addendum 1 of the ISA Summary for the ACP - HALEU Demonstration, have, as a minimum, a bachelor' s degree in engineering or the physical sciences or equivalent technical experience, and three years of nuclear experience. Other technical professional staff, whose actions are not relied upon for safety, have, as a minimum , a bachelor' s degree in engineering or the physical sciences or equivalent technical experience, and one year of nuclear experience. Operations technicians, maintenance personnel and technician , and other staff whose actions are relied upon for safety have as a minimum a high chool diploma or satisfactory 11-32

licen e Application for the American Centrifuge Plant Proposed Change 2010 completion of the General Education Development test and three years of industrial/chemical/nuclear plant operations, maintenance, engineering, or support experience. Technician candidates not meeting the experience requirements are placed into entry-level associate technician positions. Construction personnel, plant technicians, maintenance personnel, and other staff whose actions are relied upon for safety complete the applicable training programs or have equivalent experience or training. 11.3.10 Provisions for Continuing Assurance Continuing training and periodic requalification is provided for employees in the interest of promoting safety, safeguards and security, and environmental protection awareness. Continuing training is also provided as a means to maintain and improve job-related knowledge and skills and is based on the following factors :

• Frequency required by regulatory agencies and national standards
• Overtrain tasks identified in PBT-based programs
• Training needs as determined by line management. This includes, but is not limited to, nuclear criticality safety assessments, plant or system changes, component changes, procedure changes, lessons learned (including industry and in-house operating experiences, and event reports), and emergency response procedures.

11.3.11 References

1. ANSI/ANS-8 .20-1991 , American National Standard for Nuclear Criticality Safety Training

2. ANSI/ANS-8 .19-+9f){~2014, Administrative Practices for Nuclear Criticality Safety 11.4 Procedures The Licensee is committed to the use of approved and controlled written procedures to conduct nuclear safety, safeguards, and security activities for the protection of the public, plant employees, and the environment. Procedures are used to ensure safe work practices and apply to workers, visitors, contractors, and vendors. A balanced combination of written guidance, craftsman skills, and work site supervision is utilized . The procedure process utilizes a graded approach to provide the necessary rigor for safe plant operation, meet regulations and standards, and assure a balance of effective safety with practical efficiency in plant operations. Activities involving nuclear material and/or IROFS are conducted in accordance with approved procedures.

11-33

License Application for the American Centrifuge Plant Proposed Change 2020 A management controls program for procedures includes the basic elements of identification, development, verificati on, review and comment resolution, approval, validation, issuance, and change control, and periodic review. These elements are outlined in a procedures management writer's guide and described in implementing procedures. 11.4.1 Types of Procedures Procedures are intended to prescribe those essential actions or steps needed to safely and consistently perform operations and maintenance activities. Procedures that are related to the operation of IROFS where human actions are important and for the management measures supporting those IROFS are governed by the requirements of this section. The two general types of procedures used at the ACP are Operating and Administrative. 11.4.1.1 Operating Procedures Operating procedures are used to directly control process operations at the workstation and include, as necessary, direction for normal operations, off-normal operations, maintenance, alarm response, and emergency operations caused by failure of an IROFS or human error. These procedures provide reasonable assurance of NCS, chemical safety, fire safety, emergency planning, and environmental protection. Operating procedures contain the following elements, as applicable:

• Purpose of the activity
• Regulations, policies, and guidelines governing the procedure
• Type of procedure
• Steps for each operating process phase
• Initial start-up
• Normal operations
• Temporary operations
• Emergency shutdown
• Emergency operations
• Normal shutdown
• Start-up following an emergency or extended downtime
• Hazards and safety considerations 11-34

License Application for the American Centrifuge Plant Proposed Change 2020

• Operating limits
• Precautions necessary to prevent exposure to hazardous chemicals (resulting from operations with special nuclear material) or to li censed special nuclear material
• Measures to be taken if contact or exposure occurs
• IROFS associated with the process and their functions
• The timeframe for which the procedure is valid Maintenance procedures involving IROFS for corrective and preventative maintenance, functional testing after maintenance, and survei ll ance maintenance activities describe:
• Qualifications of personnel authorized to perform the maintenance or surveillance
• Controls on and specification of any replacement components or materials to be used
• Post-maintenance testing to verify operab ili ty of the equipment
• Tracking and records management of maintenance activities
• Safe work practices (e.g., lockout/tagout; confined space entry; moderation control or exclusion area; radiation or hot work permits; and criticality, fire, chemical, and environmental issues)
• Pre-maintenance activities require reviews of the work to be performed, including procedure reviews for accuracy and completeness
• Steps that require notification of affected parties (technicians and supervisors) before performing work and on completion of maintenance work. The discussion includes potential degradation of IROFS during the planned maintenance.

Alarm Response Procedures provide information that identifies the symptoms of the alarm, possible causes, automatic actions, the immediate operator action to be taken, and the required supplementary actions. Off-Normal Procedures describe actions to be taken during unusual or out-of-the ordinary situations. Emergency Operating Procedures direct actions necessary to mitigate potential events or events in progress that involve needed protection of on-site personnel; public health and safety; and the environment. 11-35

License Application for the American Centrifuge Plant Proposed Change 2020 11.4.1.2 Administrative or Management Control Procedures Administrative procedures or "management control procedures" are used for activities that support the process operations. These procedures are used to manage activities such as configuration management, radiation protection, maintenance, QA, training and qualification, audits and assessments, incident investigations, record keeping, and reporting. Administrative procedures direct the following activities:

• Design
• Configuration Management
• Procurement
• Construction
• Radiation safety
• Maintenance
• QA elements
• Training and qualification
• Audits and assessments
• Incident investigations
• Records management
• Criticality safety
• Fire safety
• Chemical process safety and reporting requirements 11.4.2 Procedure Process Procedures are developed or modified through a formal process incorporating the change controls described in Section 11 .1 of this license application. The procedure process ensures that:
• Procedures are identified and developed as needed;
• Procedures are provided for those operations of IROFS where human actions are necessary and for the Management Measures described in this chapter; 11-36

License Application for the American Centrifuge Plant Proposed Change 2020

• Essential elements that are generic are included as applicable. These include: nuclear criticality; chemical process and fire safety; warnings and cautions; notes or reminders of pertinent information regarding specific hazards or concerns; Material Safety Data Sheet/Safety Data Sheet avail ability; special precautions; radiation and explosive hazards; and special personal protective equipment;
• Procedures are approved under the guidelines of the configuration management program by personnel responsible and accountable for the operation;
• Procedures are verified and validated through field tests by workers and technicians during procedure development to provide assurance that they are usable and accurate;
• Procedures are periodically reviewed and re-verified and validated;
• Current procedures are available to personnel and that users are qualified on the latest version;
• Operati ng limits and IROFS are specified in the procedure;
• Safety limits and IROFS will be clearly identified, as such, in the procedure for operations;
• Procedures include required actions for off-normal conditions of operation, as well as normal operations;
• If needed, hold points or safety checkpoints are identified at appropriate steps in the procedure;
• A mechanism is specified for revising and reissuing procedures in a controlled manner;
• Current procedures are available and used at work locations; and
• The plant Training Program trains the required persons in the use of the latest procedures available.

The procedure process utilizes nine basic elements to accomplish procedure development, review, approval, and control : Identification; Development; Verification; Validation; Review and Comment Resolution; Approval; Issuance; Change Control; and Periodic Review. These elements are discussed in the following sections. 11.4.2.1 Identification 11 -37

License Application f or the American Centrifuge Plant Proposed Change 2020 ACP organization managers have the responsibility for identifying which tasks will be proceduralized within their areas of control, using the criteria in the following paragraphs below and Section 11.4.9 of this license application. As a minimum, a procedure is required for :

• The operation of IROFS and the management measures supporting those IROFS as identified in the ISA Summary and Addendum 1 of the ISA Summary for the ACP -

HALEU Demonstration

• Operator actions necessary to prevent or mitigate the consequences of accidents described in the ISA Summary and Addendum l of the ISA Summary for the ACP -

HALEU Demonstration

• Safe work practices to control processes and operations with special nuclear material, IROFS, and/or hazardous chemicals incident to the processing of licensed material.

A detailed procedure is normally not needed if the task analysis determines that:

• The work is not complex or only involves a few actions (unless failure to properly conduct those actions could result in significant consequences)
• The task requires those skills normally possessed by a qualified person (otherwise known as "skill -of-the-craft"
• The consequences of an error would be minimal Maintenance activities can be addressed by written procedures, documented work instructions, or drawings appropriate to the circumstances as discussed in Appendix A.6, paragraph (a), of ANSI/ANS 3.2-1994, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants.

11.4.2.2 Development Procedure development and quality is the user organization' s responsibility . Procedure development is accomplished in accordance with procedural guidance. A general description follows :

• A system is in place to track and document the procedure process.
• The following elements will be considered for procedure incorporation :

           >-    Title and identifying information, such as number, revi ion, and date
           );""' Statement of applicability and purpose 11-38

License Application for the American Centrifuge Plant Proposed Change 2020

           >-' Prerequisites
           )'-" Precautions (including warnings, cautions, and notes)
           ;,. Important human actions
           ;,. Limitations and actions
           )..- Acceptance criteria
           ;,. Checkoff li sts
           ;,. Reference material

• Interviews with procedure users and process walk downs are utilized to ensure procedures are usable; reflect as-built conditions and process operations; and maintain management controls for nuclear safety, safeguards, and security.
• The procedure use category is determined. This determination documents the designation of a procedure as In-Hand (Continuous Use), Reference Use, or Information Use. The designation is based on the administrative or non-administrative use of the procedure, and the safety or financial consequences of failing to adhere to procedural requirements. Procedure use is discussed in Section 11. 4.7 of this license application.
• As the procedure is drafted, attributes that enhance procedural use are included, such as standard style organization, format, cautions, and warnings.
• Input and review by affected parties is required. Other selected reviews are obtained, such as QA to ensure that QA requirements are identified and included in operating procedures.
• The approval process for the procedure is described in Section 11.4.2.6 of this license application.

11.4.2.3 Verification Verification is a process that ensures the technical accuracy of the procedure and that it can be performed as written. Procedures are verified by the procedure owner/user during the procedure development/change process. There are two basic attributes of the verification process. The first attribute relates to the technical accuracy of the procedure. It ensures that technical information including formulas, set points, and acceptance criteria are correctly identified in the procedure. The second attribute is administrative, in that it verifies the procedure format and style and that it is consistent with the procedure-writing guide. A standard checklist is used to ensure required attributes are included. 11.4.2.4 Validation The purpose of procedure validation is to ensure that no technical errors or human factor issues were inadvertently introduced during the procedure review process. Validation is required for new procedures or for intent changes to the procedure. Validation is performed in the field by qualified personnel, and may be accomplished by detailed scrutiny of the procedure as part of a 11-39

license Application fo r the American Centrifuge Plant Proposed Change 2020 walk-through exercise or as part of a walk-through drill (particularly for emergency or off-normal procedures). If the particular system or process is not available for a walk-through validation, talk-through may be performed in the particular shop or training environment. Performance of procedure validation is documented. 11.4.2.5 Review Drafts of new procedures and procedure changes are distributed for technical reviews, safety discipline reviews (e.g., nuclear criticality, fire, radiation, industrial, and chemical process safety), and cross-discipline reviews, as needed. Nuclear criticality safety reviews drafts of new procedures and procedure changes that could affect fissile material operations. Functional area and cross-discipline reviews are performed for the new procedure or procedure change. Comments/questions generated during the review process are resolved with the originating organizations. 10 CFR 70.72 and intent/non-intent screenings are performed for new and changed procedures (except minor administrative changes that are processed according to the procedure process). Any new or revised NRC requirements that are promulgated are evaluated to determine the impact on existing implementing procedures or to identify the need for new implementing procedures. Procedures are reviewed following unusual incidents; such as an accident, unexpected transient, significant operator error, or equipment malfunction to determine if changes are appropriate based on the cause and corrective action determination for the particular incident. Procedure changes that are necessary because of a system modification are addressed in Section 11 .1 of this license application, as part of the modification control process. In addition, the Plant Safety Review Committee will review:

• Each new procedure required by Section 11.4.2.1 for this license application
• Each proposed change to procedures required by Section 11.4.2.1 of this license application, if the proposed change constitutes an intent change (i .e., a change in scope, method, or acceptance criteria that has safety significance) 11.4.2.6 Approval Following the resolution of review comments, procedures are approved . Approval authority rests with the applicable ACP organization manager responsible for the activity.

Managers ensure that appropriate training is completed on new and revised procedures. 11.4.2. 7 Issuance and Distribution 11-40

License Application for the American Centrifuge Plant Proposed Change 2020 Procedures are issued and controlled in accordance with the RMDC program procedures. Copies of current approved procedures are available to users via electronic and/or hard copy distribution in the work areas. 11.4.3 Procedure Hierarchy The procedure hierarchy is established in four levels. The levels are:

• Level 1 - Policy statements issued by executive management that apply to ACP personnel
• Level 2 - Standard Practice Procedures that apply to more than one organization

        * . Level 3 - Procedures issued at the organization level that apply to more than one group within a larger group or specific organization

• Level 4 - Procedures issued within a group or sub-function 11.4.4 Temporary Changes Temporary changes to procedures required by Section 11.4.2.1 of this license application can be made, provided:
• The temporary change does not result in a change to the ISA or Addendum 1 of the ISA Summary for the ACP - HALEU Demonstration as determined by the 10 CFR 70.72 review
• The temporary change does not constitute an intent change (i.e., a change in scope, method or acceptance criteria that has safety significance)
• The change is documented utilizing the procedure process These temporary changes to procedures may be used for a period of time, which should not exceed 30 days or a period for which the temporary condition exists whichever is greater.

Temporary changes that need to exceed this period are assessed to ensure it is appropriate to extend the use of the temporary change or to process a permanent change. Temporary changes to procedures may be made permanent once the change is reviewed and approved as required by Section 11.4.2.4 of this license application. 11.4.5 Temporary Procedures Temporary procedures may be issued only when permanent procedures do not exist to:

• Direct operations during testing, maintenance, and modifications 11-41

License Application for the American Centrifuge Plant Proposed Change 2020

• Provide guidance in unusual situations not within the scope of permanent procedures
• Ensure orderly and uniform operations for short periods when the building, a system, or component of a system is performing in a manner not covered by existing permanent procedures, or has been modified or extended in such a manner that portions of existing procedures do not apply These temporary procedures may be used for a period of time, which should not exceed 60 days or a period for which the temporary condition must exist, whichever is greater. Temporary procedures that need to exceed this period are assessed to ensure it is appropriate to extend the use of the temporary procedure or to develop a permanent procedure. These temporary procedures are subject to the same level of review and approval as required for permanent procedures.

11.4.6 Periodic Review Approved procedures are periodically reviewed to ensure their continued accuracy and usefulness. Procedures are periodically reviewed according to established criteria. The periodicity of these reviews is based on procedure content as follows: Periodi c Review Cycle Procedures to Be Reviewed 1 year Emergency Operating, Alarm Response and procedures dealing with highly hazardous chemicals as defined by the chemical safety program 5 years Procedures not included as part of the one-year review cycle When conducting the periodic review, the procedure owner or SME performs a complete administrative and technical (requirements and references) review ensuring information is complete and accurate and that the procedure is usable as written. 11.4.7 Use and Control of Procedures In-Hand (Continuous Use) procedures are followed step-by-step and are present in the work area while the task is being performed. In-Hand procedures, approved equipment alignment check sheets (e.g., valve lineups or electrical switching orders), or approved operator aids (e.g., process flow-charts or component identification tables) are developed for IROFS that have:

• Extensive or complex tasks;
• Tasks which are infrequently performed; or
• Tasks in which operations must be performed in a specified sequence.

11 -42

license Application f or the A merican Centrifuge Plant Proposed Change 2010 Reference Use procedures are provided for routine procedural actions that are frequently repeated or of minimal complexity, and can be performed from memory. Reference Use procedures are not required to be present in the work area. Information Use procedures are followed to implement administrative or programmatic requi rem en ts. Hard copy controlled copies of procedures are marked "Controlled Copy." Working copies of procedures are marked "Working Copy," and verified as the latest version prior to use. Information Only copies of In-Hand (Continuous Use) or Reference Use procedures are marked "Information Only" to indicate they are not controlled copies and are not used to perform work. Procedures may be accessed and used directly from the electronic document management system. If a step of a procedure cannot be performed as written, work is stopped, the system is immediately placed in a safe condition, and corrective actions are initiated in accordance with plant procedures. Responsible managers ensure personnel are trained on the use of procedures and are appropriately trained and qualified on the current version of the procedure as described in Section 11.3 of this license application. 11.4.8 Records Records generated during procedure use are identified in the governing procedure and controlled according to the ACP RMDC program practices as described in Section 11 . 7 of this license application. 11.4.9 Topics to be Covered in Procedures Activities defined by Section 11.4.2.1 of this license application are the minimum activities that are to be covered by written procedures. In addition, any activity described in Section 11.4.2.1 of this license application and listed below is covered by a written procedure (except for the maintenance activities listed below which may be covered by written procedures, documented work instructions, or drawings appropriate to the circumstances). This list is not intended to be all-inclusive, because many other activities carried out during plant operations may be covered by procedures not included in this list. Similarly, this listing is not intended to imply that procedures need to be developed with the same titles as those in the list. This listing provides guidance on topics to be covered rather than specific procedures.

• ADMINISTRA TJVE PROCEDURES (Management Control)

            >- Training
            >- Internal audits and inspections 11-43

License Application for the American Centrifuge Plant Proposed Change 2020

           }.> Incident investigations and reporting
           }.> Records Management Document Control (RMDC)
           }.> Configuration Management
           }.> Changes in facilities and equipment
           }.> Modification design control
           }.> Quality Assurance
           }.> Equipment control (lockout/tagout)
           }.> Shift turnover
           }.> Work control
           }.> Management control
           }.> Procedures management
           }.> Nuclear Criticality Safety
           }.> Fire safety or protection
           }.> Radiation protection
           }.> Radioactive waste management
           }.> Maintenance
           }.> Environmental protection
           }.> Chemical process safety
           }.> Operations
           }.> IROFS surveillances
           }.> Calibration control
           }.> Preventive maintenance
           }.> Procurement 11-44

License Application for the American Centrifuge Plant Proposed Change 2020 OPERA TING PROCEDURES

• SYSTEM PROCEDURES THAT ADDRESS START-UP, OPERATION, AND SHUTDOWN

           ~  Electrical power
           ~  Ventilation
           ~   Shift routines, shift turnover, and operating practices
           ~   Sampling
           ~  UF6 cylinder handling
           ~  UF6 material handling equipment
           ~  Decontamination operations
           ~  Facility utilities (for example: air, nitrogen, cooling water, sanitary water, site water)
           ~  Temporary changes in operating procedures
           ~  Purge and evacuation vacuum systems
           ~  Installation and removal of centrifuge~--ntae4i-Res

• ABNORMAL OPERATION/ALARM RESPONSE

           ~  Loss of cooling
           ~  Loss of instrument air
           ~  Loss of electrical power
           ~  Fires
           ~  Chemical process releases
           ~  Loss of feed capacity
           > Loss of withdrawal capacity
           ~  Loss of purge vacuum 11-45

License Application for the American Centrifuge Plant Proposed Change 2020

• MAINTENANCE ACTIVITIES THAT ADDRESS SYSTEM REPAIR, CALIBRATION, INSPECTION, AND TESTING

           };,, Repairs and preventive repairs of IROFS
           };,, Calibration of IROFS
           };,, Functional testing of IROFS
           };,, High-efficiency particulate air filter maintenance
           };,, Safety system relief valve replacement
           };,, Surveillance/monitoring
           };,, Piping integrity testing
           };,, Containment device testing
           };,, Repair of UF6 valves
           };,, Testing of cranes
           };,, UF6 cylinder inspecti on and testing
           };,, Centrifuge assembly/install ation

• EMERGENCY PROCEDURES

           };,, Toxic chemical releases (including UF6) 11.4.10 References

1. ANSVANS 3.2-1994, Administrative Controls and Quality Assurance for the Operational Phase ofNuclear Power Plants

2. LA-3605-0003, Integrated Safetv Analysis Summarv for the American CenMfuge Plant 1.3. LA-3605-0003A, Addendum l of the Integrated Safety Analysis Summary for the American Centrifuge Plant - HA LEU Demonstration 11.5 Audits and Assessments The ACP implements a system of audits and assessments to help ensure that the health, safety, and environmental programs, as described in this license application are adequate and effectively implemented. The system is designed to ensure comprehensive independent oversight 11-46

License Application for the American Centrifuge Plant Proposed Change 2020 of the QA program at least once every three years (except as noted below). The system is comprised of two distinct levels of activities. These are audits and assessments. 11.5.1 Audits Audits are conducted by the Piketon QA 0 Qrganization in accordance with written procedures or checklists by qualified auditors. The auditorsingorganizations are independent from operations Bf the plantactivities being audited. Audits verify the effectiveness of health, safety, and environmental programs and their implementation and determine the effectiveness of the process being assessed. Audits further verify that the plant operations are being conducted safely in accordance with regulatory requirements, license application commitments, and the ISA. These audits and their associated frequencies are conducted in accordance with Section 18.0 of the QAPD and use written procedures or checklists. Audits are performed under the direction of a Lead Auditor, qualified in accordance with the American Society of Mechanical Engineers (ASME) NQA-1 -2008, Part 1,Stt~enl 2S 3 Requirement 2, Section 300, Oualification Requirements, and Section 400, Records* of Oualification. Lead Auditors and staff auditors are functionally and organizationally independent of the programs and activities that are examined. Where appropriate, audit teams are supplemented with plant and/or external technical specialists. In addition to periodically evaluating aspects of the QAPD, audits are conducted for the areas of radiation safety; NCS [every two years]; nuclear safety; chemical safety; fire safety; environmental protection; emergency management; QA; CM, maintenance; training and qualification; procedures; incident investigation; records management; security (every two years); and operations. Audit results are documented and reported to the plant senior management as specified in plant procedures. Provisions are made for reporting and corrective action, where warranted. The plant Corrective Action Program, described in Section 11.6 of this license application, is administered by the Regulatory Organization to ensure proper control of corrective actions as defined in Section 16.0 of the QAPD. 11.5.2 Assessments Management responsible for implementing portions of the QAPD performs assessments to verify the adequacy of the part of the QAPD for which they are responsible and to assure its effective implementation. Results of assessments are documented. The responsible organization manager resolves any observations from these programmatic assessments. Organization managers maintain an assessment process within their organization to assess the adequacy of, and effectiveness of, the implementation of the programs under their cognizance. As a minimum, these assessments are conducted for the areas of radiation safety, NCS; nuclear safety; chemical safety; fire safety; environmental protection; emergency management; QA; CM; maintenance; training and qualification; procedures; incident investigation; records management; 11-47

License Application for the American Centrifuge Plant Proposed Change 2020 and operations. Operational assessments will also be performed to ensure the operational assumptions as defined in the ISA Summary and Addendum 1 of the ISA Summary for the ACP - HALEU Demonstration are valid. Assessment results are documented and reported as specified in the plant procedures. Provisions are made for reporting and corrective action, where warranted, in accordance with the plant's Corrective Action Program. Additional requirements for performing Nuclear Criticality Safety Assessments are specified in Chapter 5.0 of this license application. 11.6 Incident Investigations This section encompasses the identification, reporting, and investigation of abnormal events or conditions, including precursor events that may occur during operation of the ACP. This includes identification and categorization of the incident, as well as an analysis to determine the specific or generic causes, as well as generic implications. The ACP is required by 10 CFR 70.50 and 70.74 to notify the NRC of certain events and conditions and to determine the root cause of the event, including all factors that contributed to the event and the manufacturer and model number (if applicable) of any equipment that failed or malfunctioned. Corrective actions taken or planned to prevent occurrence of similar or identical events in the future and the results of any evaluations or assessments must also be provided. The ACP satisfies these requirements by following administrative procedures relating to incident identification and reporting. These procedures work together to ensure that abnormal events and conditions occurring at the ACP are promptly reported to appropriate personnel, assessed, and when required, reported to the NRC Operations Center or designated NRC office. 11.6.1 Incident Identi~cation, Categorization, and Notification In accordance with procedures, plant personnel are required to report to their line manager or directly to the Operations Shift Supervisors and/or Plant Shift Superintendent (PSS) abnormal events or conditions that may have the potential to harm the safety, health, or security of on-site personnel, the general public, or the environment, including precursor events. These conditions may require an emergency response. The Operations Shift Supervisors and/or PSS, in accordance with procedures, assesses and categorizes abnormal events or conditions using the notification and reporting criteria set forth in 10 CFR 70.50 and 70. 74 and other applicable regulations. In making the assessment, the 0 erations Senior Shift Supervisor may consult with ACP senior management or other personnel pos essing expertise or knowledge concerning the type of event or condition being assessed. 11-48

License Application for the American Centrifuge Plant Proposed Change 2020 If an event or condition within the plant is categorized as a reportable event, the PSS makes initial notification to the NRC Operations Center or designated NRC office and provides, to the extent known at the time of notification, the information specified in 10 CFR 70.SO(c)(l). Notification is made as soon as possible, but not later than the time period stated in the regulations. Notification time periods vary between 30 minutes and 24 hours. Verbal and/or written communication involving classified information is conducted in accordance with the SP-3605-0041. Security Plan for the Protection of Classified Matter ( 'hap/er 2. 0 <!f the Sernrity ProKrnm .ffH'-at the American Centrifuge Plant. 11.6.2 Conduct of Incident Investigations The level of investigation of abnormal events and precursor events is based on a graded approach relative to the severity of the incident. Each reportable event where a follow-up written report to the NRC is required is investigated to determine the cause and corrective actions necessary to prevent recurrence. This investigation is conducted and documented in accordance with procedures. Other events not requiring a written report are evaluated using the Corrective Action Program to determine actions to be taken. The investigation process includes a prompt risk-based evaluation and, depending on the complexity and severity of the event, one individual may suffice to conduct the evaluation or an event investigation team may be warranted. Investi gations will begin within 48 hours of the abnormal event, or sooner, depending on the safety significance of the event and commensurate with the safety of the investigators. The investigator(s) are independent from the line function involved with the incident under investigation. A procedure provides a documented plan for investigating abnormal events and includes the functions, responsibilities, and scope of authority of investigators. This plan is separate from any required Emergency Plan or emergency response. A reasonable, systematic, structured approach is used to determine the specific or generic root causes and generic implications of abnormal events, such as the Tal}R-ee-T methodology . The record of IROFS failures required by 10 CFR 70.62(a)(3) for IROFS is reviewed as part of the investigation and updated in accordance with regulatory requirements. For each event or condition that requires a follow-up written report to the NRC, the incident investigation report includes a description, contributing factors, a root cause analysis, and findings and recommendations. Auditable records and documentation related to abnormal events, investigations, and root cause analyses are maintained. Documentation relating to the investigation is retained for two years or for the life of the operation, whichever is longer. The original investigation reports are available to the NRC upon request. The investigator(s) have the authority to obtain all the information considered necessary during the course of the investigation and participants of an investigation team are assured of no retaliation for participation in an investigation. Line management cooperates fully with the investigators. The individual leading the investigation is trained and qualified in root cause analysis techniques. This individual is responsible for ensuring the conduct of the investigation is in accordance with procedures and that the outcome of the investigation is properly documented and reported to appropriate levels of management with responsibility for the abnormal event. If a 11-49

License Application for the A merican Centrifuge Plant Propo *ed Change 2020 team is used, it includes at least one process expert in addition to the trained root cause investigator. An individual is chosen to lead the incident investigation based on experience and knowledge of the particular area involved with the event or condition. 11.6.3 Follow-up Written Report When required by regulations, a report summarizing the results of the event investigation is prepared in accordance with procedures. The report contains, at a minimum, the information specified in 10 CFR 70.50(c)(2). The written report is forwarded to the NRC within the time limit specified in the applicable NRC regulations, with the exception that the follow-up written reports required by 10 CFR 70.50(c)(2) are submitted within 60 days. The 10 CFR 70.50(c)(2) reporting criteria require that the ACP submit a written follow-up report within 30 days of the initial report required by 10 CFR 70.50 (a) or (b) or by 10 CFR 70.74 and Appendix A of Part 70. In lieu of the 30-day requirement described in 10 CFR 70.50(c)(2), NRC approval to submit the required written reports within 60 days of the initial notifications is hereby requested . This exemption request is provided in Section 1.2.5 of this license application. 11.6.4 Corrective Actions For each significant condition adverse to quality or reportable event where a follow-up written report to the NRC is required, corrective actions to prevent recurrence are developed by responsible management, tracked in a database, and monitored through completion in accordance with the Corrective Action Program. Corrective actions are taken within a reasonable period, commensurate with the safety significance of the event. Evidence files used to support action closure are maintained in accordance with approved records management procedures. Documentation is maintained so that " lessons learned" may be applied to future operations of the ACP . Details of the event sequence are compared with accident sequences already considered in the ISA. Should it be necessary, the ISA Summary and Addendum 1 of the ISA Summary for the ACP - HALEU Demonstration is are modified to include evaluation of the risk associated with accidents of the type actually experienced. Relevant findings from incident investigations are reviewed with affected ACP personnel. The Corrective Action Program also requires that initiating events, as defined in the ISA Summary and Addendum I of the ISA Summary for the ACP - HALEU Demonstration, will be reviewed and tracked to ensure that the frequency with which they occur does not exceed the assumptions made in the ISA. Should those reviews indicate that the frequencies are not conservative, appropriate actions will be taken to ensure the 10 CFR 70.61 Performance Requirements are met. 11-50

License Application for the A merican Centrifuge Plant Propo ed Change 2020

11. 7 Records Management and Document Control RMDC programs are established to ensure records and documents required by the QAPD are appropriately managed and controlled. These programs are designed to meet the specific record keeping and document control requirements set forth in 10 CFR Part 70 and the applicable provisions of other parts of 10 CFR. These programs provide administrative controls that establish standard methods and requirements for collecting, maintaining, and disposing of records. These programs also ensure that documents are controlled and distributed in accordance with identified written requirements and authorizations. The administrative controls for the generation and revision of records and documents are contained in implementing procedures. The principal elements of each of the RMDC programs and a brief description of the manner in which the functions associated with each element are performed are provided below, along with a list of the types of records that are retained for the duration of the licensed activities.

11.7.1 Records Management Program The Records Management program provides direction for the handling, transmittal, storage, and retrievability of records. Records Management design provides for adequate assurance that the appropriate records of IROFS are maintained in accordance with the BDC contained in 10 CFR 70.64(a) and the defense in depth requirements of 10 CFR 70.64(b)-, and the requirements contained in the Quality Assurance Program Description (QAPD). Records maintained pursuant to 10 CFR Part 70 may be the original, a reproduced copy, electronic media, or microform, if such reproduced copy, electronic media, or microform is duly authenticated by authorized personnel and is capable of producing clear, complete, accurate and legible copies through storage for the period specified by regulation. Records such as letters and check lists must include pertinent information such as stamps, initials, and signatures. Initials and signatures may be authenticated electronic reproductions. Records are categorized and handled in accordance with their relative importance to safety and storage needs. Special provisions are made for handling contaminated records and ensuring their inclusion in the program. This program is implemented through procedures that provide guidance for the following program elements. 11.7.1.1 Legibility, Accuracy, and Completeness Documents designated to become records must be legible, accurate, complete, and contain an appropriate level of detail commensurate with the work being performed and the information required for that type of record. 11.7.1.2 Identification of Items and Activities Records clearly and specifically identify the items or activities to which they apply. 11-51

License Application for the American Centrifuge Plant Proposed Change 2020 11.7.1.3 Authentication Records are authenticated or validated by the manager of the organization that originates the record, or A--i-s--designee, as specified in the procedure, which controls the generation and revision of these records.

11. 7.1.4 Indexing and Filing Methods are specified for indexing, filing, and locating records within the record system to ensure the records can be retrieved in a timely manner.

11. 7.1.5 Retention and Disposition Records retention times are specified by the manager, or designee, of the organization that originates the record. Lifetime records are retained for the life of the item to which they apply or as required by a regulatory agency. The process for disposition of records that have reached the end of their retention lifetime is specified by procedures and conforms to applicable requirements.

11.7.1.6 Corrections Corrections to records are approved by the organization that created the record unless other organizations are specifically designated. Changes are made by clearly indicating the correction, the date of the correction and the identification of the individual making the correction. 11.7.1.7 Protection of Records Controls are established for protection of records from deterioration, loss, damage, theft, tampering, and/or unauthorized access for the life of the record. Requirements include instructions on protection of records by the record originator until they are transferred to Records Management. Lost or damaged records are replaced, unless deemed impractical with the concurrence of the QA organization. Single copy records are checked out of storage only if they cannot be copied and then only for a limited period. Temporary protection in such cases is provided by prudent business practices (e.g ., record of custody, office environment, and workplace security). Instructions for the protection of special record media such as radiographs, photographs, negatives, microform and magnetic media are provided to prevent damage from excessive light, stacking, electromagnetic fields, temperature, humidity, or any other condition adverse to the preservation of those records. Records, which cannot be duplicated, are stored in a fashion that minimizes deterioration. 11.7.1.8 Storage Requirements Records encompassed by the QAPD are stored in authorized facilities or containers providing protection from fire hazards, natural disasters, environmental conditions, and infestations of insects, mold, eF rodents and dust or airborne particles. The applicable document that specifies the record indicates those to be forwarded for lifetime storage. Storage facilities are 11-52

License Application for the American Centrifuge Plant Proposed Change 2020 maintained to ensure continuous protection of the records. Requirements are specified for both permanent and temporary storage of records.

• Permanent Storage Records are permanently stored in facilities satisfytng the following requi-rements

           };,, Single S~torage consist of facility, vault, room or container with a minimum 2-hour fire rating. The design and construction of a single storage facility, vault room, or container shall be reviewed for adequacy by a person competent in fire protection or contain a certification or rating from an accredited organization. 2-hour-rated Bnmi iteffi m. eeting--N-a-t-i en-a-1-fi-r~n Associ ati 01t-fN-£l.PA-) 23 2 2000 'N~H+-t-fle e+a-Fi-f-+at~n- t-4at--i-f+he-Nf PA 2J2 met-h-ee-of storab~lBHHated contaiAers-i--s used, any e:-.ceptions to this standard will be documented and justifted by the authority havingjurisdiction; or
           };,, Dual £1.Bt'flge-facilities, containers or a combination thereofe-f-eH-13-l-icate copies in separate facilities that are sufficientl y remote from each other to eliminate the possibility of exposure to simultaneous hazard s"'; or
           ,---Sternge-ifl fac-i--1--ities that-Have--+~1~-ew+Ag . doors, struetH-res,+r-arnes, and lrnrdw-a-re that comply with a minimum 2----hour fire rating, a fire protection system, hour fire rated dampers on boundary penetrations, sealed floor surtace to minimize concrete dtts-~etju-ate---a-ces-s--------a-H<l -aisle ways-;---anEl-a--pmh+biti-en Btt--eat+t1g~H-ki ng, or sm okttt-g-a 1td-)*rfor-rn-t n-g- --\-vork--Bt Rer--+-lta-1t-+h-a+-as-so-i-a-t-e-d- wi-th--Fec--BF6s--slBr-at,,e---er retrieval

• Temporary Storage The RMDC process requires that those completed records documenting nuclear safety or safeguards and security matters, which are being held temporarily by originating organizations, be properly protected by maintaining them in I-hour, fire-rated facility or containers. If I-hour fire-rated containers~ are used they either bear an Underwriters Laboratory label ( or equivalent) certifying I-hour fire protection, or the containers-are_lli certified for I-hour fire protection by an authorized individual competent in the field of fire protection. Procedural requirements are used to limit the length of time during which records may be maintained in temporary storage, based on the significance of the record.

11.7.1.9 Receipt of Records A record transmittal process is used to formally transmit records to Records Management. The process includes a receipt acknowledgment that notifies the sending organization that the records have been received and accepted. 11-53

License Application for the American Centrifuge Plant Proposed Change 2020

11. 7.1.10 Access to Records and Accountability for Removed Records Requirements for controlling access to records and maintaining accountability for records are provided to ensure that only authorized personnel have access to records and to prevent loss, damage, or inadvertent destruction of records.

11.7.1.11 Records Requirements for Procured Goods or Services Records management requirements for goods or services procured from outside suppliers are specified in the applicable procurement documents. These requirements cover:

• Supplier methods for collection, storage, and maintenance of records
• Identification of required records and applicable retention periods
• Records submittal plans or indexes
• Availability, accessibility, and if applicable, disposition criteria for records retained by the supplier
• Accessibility of the supplier's records prior to the final transfer to the purchaser 11.7.1.12 Control of Sensitive Records Control, accountability, protection, and disposition of classified and sensitive records are in accordance with SP-3605-0041, Security Plan for the Protection of Classified MatterCha111er 2.0 <tff/,e r'wrnri~v Frogrum}<>r al the American Centrifuge Plant and any other applicable security and privacy requirements. Control of contaminated records is in accordance with applicable radiological control requirements.

11.7.1.13 Types of Records The requirements for records management vary according to the nature of the plant and the hazards and risks posed by it. Examples of the records required by 10 CFR Parts 19, 20, 21 , 25, and 70 are identified in Section 11.7.5 of this license application. The records are listed under the chapter headings of the NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications ( SR P). The list is not intended to be exhaustive or prescriptive. Different or additional records may be required in certain circumstances. 11.7.1.14 Usage and Control of Computer Codes and Data Computer programs used in the Records Management program are controlled and maintained in accordance with classified information systems security and administration procedure requirements, unclassified computer security plan requirements, and information technology operations guidance. These requirements and practices provide for virus protection as 11-54

License Application for the A merican Centrifuge Plant Propo ed Change 2020 well as access control to the Records Management program database and ensure continuing usability of the codes as hardware and software technology change. Routine backups of the Records Management database are performed by appl ication administrators. Precautions are taken to ensure that computer data that constitute a record are stored in a format that is readily retrievable even as hardware and software technology evolve. The storage format of computer data is reviewed as required to determine threats to future retrievability, and if necessary, the data are translated to an updated format and verified acceptable. 11.7.1.15 Items Relied On For Safety Failures Records of IROFS failures are kept and updated in accordance with 10 CFR 70.62 (a)(3). Record revisions necessitated by post-failure investigation conclusions will be made promptly in accordance with 10 CFR 70.62(a)(3) based on the nature of the record, extent ofrevision necessary, and potential safety significance. Necessary record revisions will be made within 30 days of the completion of the investigation, unless specifically approved by ACP management 11.7.1.16 Assessment The overall effectiveness of the Records Management program is evaluated through the audit program described in the Section 18 of the QAPD. Deficiencies identified are corrected in a timely manner in accordance with the procedures described in Section 11 .6 of this license application.

• 11 .7.2 Document Control Program The Document Control program provides direction for the handling, distribution, and transmittal of documents important to nuclear safety and safeguards and security that specify quality requirements or prescribe activities affecting quality, such as procedures, drawings, and calculations. This program is implemented through procedures that provide guidance on the
• following program elements.

11.7.2.1 Unique Identifier A unique identification number is assigned or obtained by the generator for each document requiring controlled distribution . Document Control concurs with the numbering scheme for each document type.

11. 7.2.2 Approval and Release of Documents For documents and changes to documents required by the QAPD, requirements are established forverified ade uate approvedal and released of those documents for distribution .

Organizations that are authorized to approve and distribute controlled documents are identified in the plant procedures. Changes to controlled documents are approved. After approval, the documents are forwarded to Document Control for control and distribution pursuant to the personnel on the approved distribution list. 11-55

license Application for the American Centrifuge Plant Proposed Change 2020 11.7.2.3 Master Copy A master copy of approved controlled documents is maintained by Document Control to ensure the document is available for controlled copy issuance. 11.7.2.4 Controlled Document Index and Distribution Lists Creation and maintenance of a controlled document index and controlled distribution list(s) for each document or document type are required . The controlled document index is used to maintain a list of controll ed documents and to track the current (latest) approved revision levels of those documents. The index is available to users to verify current document revision levels. The controlled document index and the distribution lists are maintained and updated by Document Control.

11. 7.2.5 Copies of Controlled Documents Each controlled copy is stamped, marked, or otherwise identified. A method is established in procedures for duplicating and marking controlled documents so that duplicates are distinguishable from the controlled version. Copies of controlled documents that are not marked or otherwise identified in accordance with procedural requirements are considered information only.

11. 7.2.6 Distribution Controll ed documents are distributed in accordance with controlled distribution lists to ensure that they are available in a timely manner at locations where work is being performed.

Specific time requirements are established for controlled document distribution and receipt acknowledgment. Document Control uses a transmittal form to distribute controlled documents to copyholders. Copyholders sign, date, and return the transmittal form to confirm that they have received the documents. Document Control tracks the issuance and receipt of transmittals. 11.7.2.7 Voided, Canceled, or Superseded Documents When notified by the generator of a controlled document that the document has been voided, canceled, or superseded, Document Control removes the document from distribution and notifies copy holders of the changed status. The approved revised document is distributed at the time that the original document is superseded. The Document Control database is updated to identify the latest approved revision of the document. Distribution of revised documents is described in the Document Control Program procedure and using a Transmittal Form distributed by either interoffice mail or hand delivery . The holder of the Controlled Copy is required to acknowledge receipt by returning a signed Transmittal Form to Document Control. Document distribution is completed in accordance with the safety significance of the document being distributed. 11-56

License Application for the American Centrifuge Plant Proposed Change 2020 11.7.2.8 Marking Sensitive Documents Proper marking and handling of documents designated as classified or sensitive documents is accomplished in accordance with SP-3605-0041, Security Plan for the Protection of Classified Malter at the American Cenlrifilge Plant f'-h-apler 2 0 of the Securi t-y- P.rngram for the-,'.\ffiCH-a-H Centrifuge Plant and any other applicable security and privacy requirements. 11.7.2.9 Change Documents Change documents are documents that are used to modify controlled documents. Controls are also applied to the change documents to provide revision approval and distribution controls equivalent to the original document until completion of installation, at which time the original document is revised. Documents shO\ying the current configuration are not changed until the modifications are completed.

• 11.7.2.10 Revision Identification The controlled document revision level is clearly identified on the document.

11.7.2.11 Document User Responsibilities Responsibilities of the end user and copyhol ders are defined . Responsibilities include requirements for the use of controlled documents an d working copies. Copyholders of controlled documents update their controlled documents each time a revision or change is sent out, and promptly return the transmittal form acknowledging receipt. 11.7.2.12 Usage and Control of Computer Codes and Data Computer programs used in the Document Control program are controlled and maintained in accordance with classified information systems security and administration procedure requirements, unclassified computer security plan requirements, and information technology operations guidance. These requirements provide for virus protection as well as access control to the Document Control program database and ensure continuing usability of the codes and data as hardware and software technology change. For example, procedures allow older forms of information and codes for ol der computing equipment to be transferred to contemporary computing media and equipment. Routine backups of the Document Control database are performed by application administrators.

11. 7.2.13 Assessment The overall effectiveness of the Document Control program is evaluated through the audit program described in Section 18.0 of the QAPD. Defi ciencies identified are corrected in a timely manner in accordance with the requirements described in Section 11.6 of this license application.

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License Application for the American Centrifuge Plant Proposed Change 2020 11.7.2.14 Archiving Documents Revisions of controlled documents are transmitted to RMDC and the previous revision of the document is archived in accordance with the requirements of the Document Control Process. 11.7.3 Organization and Administration

11. 7.3.1 Responsibilities The Training and Procedures Manager is responsible for the RMDC program. These responsibilities include:

• Directing the activities and personnel of the RMDC programs
• Directing the development, implementation, and maintenance of methods and procedures encompassing a records management program
• Directing the development, implementation, and maintenance of methods and procedures encompassing a document control program
• Assuring that the laws, codes, standards, regulations, and company procedures pertaining to record keeping and document control requirements are met
• Select RMDC activities may be contracted from a qualified provider.

11. 7.3.2 Training and Qualifications Appropriately trained and qualified personnel manage the RMDC programs. No specific experience related to the control of documents or management of records is required, although previous technical or RMDC experience is recommended.

11.7.4 Employee Training General training in RMDC is provided to employees as part of the general topics covered in GET, as described in Section 11.3 of this license application. 11.7.5 Examples of Records The following are examples of the types of records maintained by RMDC.

• Chapter 1.0 - General Information

           ~  Construction records 11-58

License Application for the American Centrifuge Plant Proposed Change 2020

          >> Plant and equipment descriptions and drawings
          >>   Design criteria, requirements, and bases for IROFS as specified by the ACP CM function
          >> Records of plant changes and associated integrated safety analyses, as specified by the ACP CM function

>> Safety analyses, reports, and assessments

          >> Records of site characterization measurements and data
          >> Records       pertaining to on-site disposal of radioactive or mixed wastes in surface landfills
          >> Procurement records, including specifications for IROFS

• Chapter 2.0 - Organization and Administration

           >> Administrative procedures with safety implications
           >> Change control records for nuclear material control and accounting program
           >> Organization charts, position descriptions, and qualification records
           >> Safety and health compliance records, medical records, personnel exposure records, etc.
           >> QA records
          >> Safety inspections, audits, assessments, and investigations
          >> Safety statistics and trends

• Chapter 3.0 - Integrated Safety Analysis
• Chapter 4.0 - Radiation Safety

           >> Bioassay data
          >> Exposure records
          >> Radiation protection (and contamination control) records 11-59

License Application for the American Centrifuge Plant Proposed Change 2020

           >> Radiation training records
           >> Radiation work permits

• Chapter 5.0 - Nuclear Criticality Safety

           >> Nuclear criticality control written procedures and statistics
           >> NCS evaluations
           >>  Records pertaining to nuclear criticality inspections, audits, investigations, and assessments
           >> Records pertaining to nucl ear criticality incidents, unusual occurrences, or accidents
           >> Records pertaining to NCS evaluations

• Chapter 6.0 - Chemical Safety

          >>   Chemical process safety procedures and plans
          >> Records       pertaining to chemical process inspections, audits, investigations, and assessments
          >> Chemical process diagrams, charts, and drawings
          >> Records pertaining to chemical process incidents, unusual occurrences, or accidents
          >> Chemical process safety reports and analyses
          >> Chemical process safety training

• Chapter 7.0 - Fire Safety

          >> Fire Hazard Analysis
          >> Fire prevention measures, including hot-work permits and fire watch records
          >>   Records pertaining to inspection, maintenance, and testing of fire protection equipment
          >>   Records pertaining to fire protection training and retraining of response teams
          >>   Pre-fire emergency plans 11-60

License Application for the American Centrifuge Plant Proposed Change 2020

• Chapter 8.0 - Emergency Management

           >> Emergency plan(s) and procedures
           >>   Comments on emergency plan from outside emergency response organizations
           >>   Emergency drill records
           >> Memoranda of understanding with outsi de emergency response organizations
           >> Records of actual events
           >> Records pertaining to the training and retraining of personnel involved in emergency preparedness functions
           >> Records       pertaining to the inspection and maintenance of emergency response equipment and supplies

• Chapter 9.0 - Environmental Protection

           >> Environmental release and monitoring records
           >> Environmental report and supplements to the environmental report, as applicable

• Chapter 10.0 - Decommissioning

          >> Decommissioning records
          >> Financial assurance documents
          >> Decommissioning cost estimates
          >>   Site characterization data
          >> Final survey data
          >> Decommissioning procedures

• Chapter 11.0 - Management Measures

          >>   Section 11 .1 - Configuration Management
              *!* Safety analyses, reports, and assessments that support the physical configuration of process designs, and changes to those designs 11-6 1

License Application for the American Centrifuge Plant Proposed Change 2020

               *!* Validation records for computer software used for safety analysis or nuclear material control and accounting
               *!* ISA documents, including process descriptions,           plant  drawings     and specifications, purchase specifications for IROFS
               *!* Approved, current operating procedures and emergency operating procedures
           }.> Section 11.2 - Maintenance
                *!* Record oflROFS failures (required by 10 CFR 70.62)
                *!* PM records, including trending and root cause analysis
               *!* Calibration and testing data for IROFS
               *!* Corrective maintenance records
           }.> Section 11.3 - Training and Qualification
               *!* Personnel training and qualification records
               *!* Training procedures
               *!* Training modules
           }.> Section 11.4 - Procedures
               *!* Standard operating procedures
               *!* Functional test procedures
           }.> Section 11 .5 - Audits and Assessments
               *!* Audits and assessments of safety and environmental activities
           }.> Section 11 .6 - Incident Investigations
               *!* Investigation reports
               *!* Changes recommended by investigation reports, how and when implemented
               *!* Summary of reportable events for the term of the license
               *!* Incident investigation policy 11-62

License Application for the American Centrifuge Plant Proposed Change 2020

           }.,, Section 11 .7 - Records Management
                *!* Policy
                *!* Material storage records
                *!* Records of receipt, transfer, and disposal of radioactive material
           }.,, Section 11.8 - Other QA Elements
                *!* Inspection records
                *!* Test records
                *!* Corrective action records 11.8 Other Quality Assurance Elements The plant has developed QA principles as described in Section 1.0 of the QAPD.

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