ML20295A353
| ML20295A353 | |
| Person / Time | |
|---|---|
| Site: | 07007003, 07007004 |
| Issue date: | 10/16/2020 |
| From: | Wiehle K American Centrifuge Operating |
| To: | Sabrina Atack Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Security and Incident Response |
| References | |
| ACO 20-0037, EPID L-2020-SPR-0003 | |
| Download: ML20295A353 (5) | |
Text
Security - Related Information - Withhold Under 10 CFR 2.390 Export Controlled Information and Official Use Only
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l----------~.:::----.--------of-Nuchmrt'ow0 October 16, 2020 ACO 20-0037 ATTN: Document Control Desk Ms. Sabrina D. Atack, Director Division of Security Operations Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 American Centrifuge Lead Cascade Facility and American Centrifuge Plant Docket Numbers 70-7003 and 70-7004 License Numbers SNM-7003 and SNM-2011 Supplemental Proposed Changes for American Centrifuge Operating,LLC's Security Plans -
EPID #L-2020-SPR-0003 INFORMATION TRANSMITTED HEREWITH IS PROTECTED FROM PUBLIC DISCLOSURE AS CONFIDENTIAL COMMERCIAL OR FINANCIAL INFORMATION AND/OR TRADE SECRETS PURSUANT TO 10 CFR 2.390 AND 9.17(a)(4)
AND INFORMATION TRANSMITTED HEREWITH IS PROTECTED FROM DISCLOSURE PURSUANT TO 10 CFR PART 810
Dear Ms. Atack:
The purpose of this letter is to provide supplemental proposed changes to the U.S. Nuclear Regulatory Commission (NRC) for review and approval for the American Centrifuge Operating, LLC (ACO) security plans.
Enclosure 1 provides the description of change and justification for the supplemental proposed changes for the following security plans:
- SP-3605-0041, Security Plan for the Protection of Classified Matter at the American Centrifuge Plant (Enclosure 2)
SP-3605-0018, High Assay Low Enriched Uranium (HALEU) Cascade Engineering, Procurement, and Construction (EPC) Temporary Security Plan (Enclosure 3) 331-06-161, American Centrifuge Program Operations Security Plan (Enclosure 4)
Document/matter transmitted contains Security - Related Information - Withhold Under 10 CFR 2.390 Export Controlled Information and Official Use Only When separated from enclosures, this cover letter is uncontrolled.
American Centrifuge Operating, LLC 3930 U.S. Route 23 South - P.O. Box 628 Piketon, OH 45661
Security - Related Information - Withhold Under 10 CFR 2.390 Export Controlled Information and Official Use Only Ms. Sabrina D. Atack .
October 16, 2020 ACO 20-0037, Page 2 1-----~~S=upplemental.pmposed:changes-fro.m-ths-previoosly-sttbmitted-ptans-ar-e noted wit the right-hand margin.
Enclosures 2 through 4 contain Security-Related Information and, in accordance with the guidance provided by the U.S. Department of Energy (DOE), contain Official Use Only information.
Therefore, ACO requests these enclosures be withheld from public disclosure pursuant to 10 CPR 2.390(d)(l). Additionally, Enclosures 2 and 3 have been determined, in accordance with the guidance provided by the DOE, to contain Export Controlled Information and must be protected from disclosure per the requirements of 10 CPR Part 810.
I If you have any questions regjding this matter, please contact me at (740) 897-3859.
Sincerely, /
NJ4fk~
Kelly L. Wiehle Regulatory Manager cc (without enclosures, unless otherwise noted):
B. Brown, NE-ORI, NE-ORSO K. Everly, NRC HQ (Enclosures)
Y. Paraz, NRC HQ (Enclosures)
S. Greene, NE-32, NE (Enclosures)
S. Harlow, DOE HQ J. Hutson, DOE ORO (Enclosures)
M. McCune, NE-ORI, NE-ORSO N. Pitoniak, NRC Region II (Enclosures)
L. Pitts, NRC Region II (Enclosures)
S. Rice, DOE, NE-ORSO (Enclosures)
R. K. Shears, DOE OR E. St. Clair, DOE ORO R. Womack, NRC Region II (Enclosures)
T. Vukovinsky, NRC Region II (Enclosures)
Document/matter transmitted contains Security- Related Information - Withhold Under 10 CFR 2.390 Export Controlled Information and Official Use Only When separated from enclosures, this cover letter is uncontrolled.
Enclosure 1 of ACO 20-0037 Description of Change and Justification for the Supplemental Proposed Changes Information Contained Within Does Not Contain Export Controlled Information Reviewing Official: #1014 Date: 10/13/2020
Enclosure 1 ACO20-0037 Page 1 of2 Detailed Description and Justification On March 31, 2020 (ACO 20-0009), American CentnrugeOperatmg, I:TX~~(Kefl)-submitteci-the-----
initial License Amendment Request for ACO's Piketon Security Plan(s). ACO 20-0009 provided a detailed description,justification, and ACO's significance determination for the proposed new and changed documents as follows:
- New SP-3605-0041, Security Plan for the Protection of Classified Matter at the American Centrifuge Plant
- New SP-3605-0018, High Assay Low Enriched Uranium (HALEU) Cascade Engineering, Procurement, and Construction (EPC) Temporary Security Plan
- New SP-3605-0039, American Centrifuge Classified Cyber System Security Plan (SSP)
- Revised 331-06-161, American Centrifuge Program Operations Security Plan Proposed changes were determined not to decrease the effectiveness of the Security Programs/Plans in accordance with 10 Code ofFederal Regulations (CFR) 70.32; however, the new security plans were determined to be a substantive change iri accordance with 10 CFR 95.19 and required U.S.
Nuclear Regulatory Commission's (NRC) prior review and approval.
On April 29, 2020, staff from the NRC, U.S. Department of Energy (DOE), and ACO held a conference call to discuss questions related to ACO's submittal dated March 31, 2020 (ACO 20-0009). On July 16, 2020 (ACO 20-0019), ACO submitted responses to NRC staff comments specifically related to SP-3605-0041 .
. On June 23, 2020, NRC, DOE, and ACO staff held a conference call to discuss questions related to SEC-18-0002, also submitted on March 31, 2020 (ACO 20-0009). On July 16, 2020 (ACO 20-0019), ACO submitted responses to NRC staff comments specifically related to SEC-18-0002.
On June 30, 2020, during a NRC and DOE on-site inspection, discussions were held regarding SP-3605-0018 and SP-3605-0039. On July 16, 2020 (ACO 20-0019), ACO submitted proposed changes addressing those on-site discussion.
During August 2020, ACO performed an internal readiness assessment in preparation for the NRC' s planned operational readiness review for Piketon, Ohio set for the week of September 14, 2020.
During this assessment, findings* and observations were made which compelled changes to the following plans: SP-3605-0041, SP-3605-0018, and SP-3605-0039, as submitted on September 3, 2020 (ACO 20-0028). On September 10, 2020 (ACO 20-0033), ACO provided proposed changes to SEC-18-0002 which compelled an additional change to Figure 1 of SP-3605-0039.
During the operational readiness review held in Piketon, Ohio on September 15-17, 2020, the NRC reviewed the license amendment request and supplemental changes as discussed above.
Clarifications within SP-3605-0041, SP-3605-0018, and 331-06-131 were requested during this inspection and are being resubmitted as enclosures of this letter.
Enclosure 1 ACO20-0037 Page 2 of2 Proposed changes have been reviewed and determined not to decrease the effectiveness of the r-------------k). ecuricy..Erograms/Plans in accordance with 10 CFR 70.32; however, are being re-submitted in support of the NRC's final approval of the license amendment request. The detailed description, justification, and ACO's significance determination provided by ACO 20-0009 remains unchanged with these supplemental proposed changes.
The proposed changes to the enclosed security plans are identified by the following method:
- - Identifies text to be removed
- ........,....._..,..,...........,,......... Identifies text to be added