Text

American Centrifuge Operating, LLC, Request for Approval: Proposed Changes to Security Plans
	ML22102A092
Person / Time
Site:	07007003, 07007004
Issue date:	04/07/2022
From:	Karen Fitch; American Centrifuge Operating
To:	Samson Lee; Document Control Desk, Office of Nuclear Security and Incident Response, Division of Security Operations
References
	ACO 22-0031
	Download: ML22102A092 (48)
	v • d • e

CUI// SP-EXPT/SP-SRI // NOFORN Security-Related Information - Withhold Under 10 CFR 2.390 Export Controlled Information

.-... ***** Centrus..

: ! ** *... *

Fueling the Future

* * *

of Nuclear Power

April 7, 2022 ACO 22-0031

A T1N: Document Control Desk Samuel Lee, Acting 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

Request for Approval: Proposed Changes to American Centrifuge Operating, LLC's Security Plans

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)

AND INFORMATION TRANSMITTED HEREWITH IS PROTECTED FROM DISCLOSURE PURSUANT TO 10 CFR PART 810

Dear Samuel Lee,

On January 20, 2022, American Centrifuge Operating, LLC (ACO) staff held a closed discussion with U.S. Nuclear Regulatory Commission (NRC) staff regarding ACO ' s gap analysis for implementation of the new 32 Code of Federal Regulations (CFR) Part 117, National Industrial Security Program Operating Manual (NISPOM), and the Security Executive Agent Directive 3, Reporting Requirement s for Personnel With Access to Classified Information or Who Hold a Sensitive Position (SEAD 3), requirements. The purpose of this letter is to submit an amendment request to the NRC for review and approval, the following security plans which implement the NISPOM and SEAD 3 requirements :

SP-3605-0041, Security Plan for the Protection of Classified Matter at the American Centrifuge Plant

Document/matter transmitted contains CUI// SP-EXPT/SP-SRI // NOFORN Security-Related Information - Withhold Under 10 CFR 2.390 Export Controlled Information When separated from Enclosures 1-4, this cover letter and Enclosure 5 are uncontrolled.

American Centrifuge Operating, LLC 3930 U.S. Route 23 South - P.O. Box 628 Piketon, OH 45661 CUI// SP-EXPT/SP-SRI // NOFORN Security-Related Information - Withhold Under 10 CFR 2.390 Export Controlled Information

Samuel Lee April 7, 2022 ACO 22-0031, Page 2

SP-3605-0042, Security Plan for the Physical Protection of Special Nuclear Material at the American Centrifuge Plant

SP-3605-0045, Security Plan for the Protection of Classified Matter at Centrus Energy Corp. Headquarters

NR-SP-ACO-OR-0001, Security Program for American Centrifuge Operating, LLC at Oak Ridge, Tennessee Enclosure 1 provides a detailed description, justification, and ACO's significance determination for the proposed changes. Enclosure 2 provides the proposed changes to SP-3605-0041.

Enclosure 3 provides the proposed changes to SP-3605-0045. Enclosure 4 provides the proposed changes to NR-SP-ACO-OR-0001. Enclosure 5 provides supporting, non-substantive proposed changes for the following licensing documents:

LA-2605-0001, License Application for the American Centrifuge Lead Cascade Facility

LA-3605-0001, License Application for the American Centrifuge Plant

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

Based upon the security markings of SP-3605-0042, this security plan is being transmitted under separate cover, ACO 22-0032.

The proposed changes to the security plans were determined not to decrease the effectiveness of the Security Programs/Plans in accordance with 10 CFR 70.32; however, were determined to be substantive changes in accordance with 10 CFR 95.19 and requires NRC's prior review and approval. Proposed changes from the previously submitted plans are noted with revision bars in the right-hand margin.

Enclosures 1, 2, 3, and 4 contain Security-Related Information and ACO requests these enclosures be withheld from public disclosure pursuant to 10 CFR 2.390(d)(l). Additionally, Enclosure 2 has been determined, in accordance with the guidai+ce provided by the U.S. Department of Energy, to contain Export Controlled Information and must be protected from disclosure per the requirements of 10 CFR Part 810.

After the NRC staff has had an opportunity to review the enclosures, ACO is available to support any needed discussions to address questions or clarify issues. ACO respectfully requests NRC complete their review and approval on or before July 13, 2022, to support ACO's committed 180-day implementation date of July 20, 2022.

Document/matter transmitted contains CUI// SP-EXPT/SP-SRI // NOFORN

\\ Security-Related Information - Withhold Under 10 CFR 2.390 Export Controlled Information When separated from Enclosures 1-4, this cover letter and Enclosure 5 are uncontrolled.

CUI// SP-EXPT/SP-SRI // NOFORN Security-Related Information - Withhold Under 10 CFR 2.390 Export Controlled Information

Samuel Lee April 7, 2022 ACO 22-0031, Page 3

If you have any questions regarding this matter, please contact me at (740) 897-3859.

Sincerely,

~'l~*U Kelly L. Fitch Regulatory Manager

Enclosures:

As Stated cc (without enclosures, unless otherwise noted):

S. Bazian, NRC HQ (Enclosures)

K. Everly, NRC HQ (Enclosures)

Y. Faraz, NRC HQ (Enclosures) '

S. Harlow, DOE HQ J. Hutson, Contract Support N. Pitoniak, NRC Region II L. Pitts, NRC Region II (Enclosures)

S. Rice, Contract Support (Enclosures)

J. Tobin, NRC HQ (Enclosures)

T. Vukovinsky, NRC Region II

Document/matter transmitted contains CUI// SP-EXPT/SP-SRI // NOFORN Security-Related Information - Withhold Under 10 CFR 2.390 Export Controlled Information When separated from Enclosures 1-4, this cover letter and Enclosure 5 are uncontrolled.

Enclosure 5 of ACO 22-0031

Supplemental Proposed Changes

Information Contained Within Does Not Contain Export Controlled Information Reviewing*

Official: #1038, ACO

Date: 04/05/2022 NRC FORM 374A Page 3 of6 U.S. Nuclear Regulatory Commission License Numbe r SNM-7003, Amendment 20 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-7003

g. OFigiABI See1:1ri~ ProgFBA'I EleteEI J1:1ly a, 2002, as modified by FetJisi0AS dated Noi.iember ao, 200e, JaA1:1ai:y 27, 2008, J1:1Ae 1e, 2008, September 1, 2008, Jt:1Ae 4, 2007, A1:Jgust 17, 2007, JaAl:IOPf 14, 2008, JaAl:lOfY 26, 2008, MeroR 7, 2008, J1:1Ae 27, 2008, OREi

.laAUBI)' ao, 2000. Rop loeed by Seo1:1rity Pro gmm refeFeReed iR SNM 2011 dat.ed A1::1gust 12, 2000, OS modi#iod ey FOYiOiOR9 dated Ootober 28, 2000, No i.iember 18, 2009,

April 12, 2010, April ao, 20 10,.lBRl:lBI)' 28, 2011, Marel'I 18, 2011, FeBFl:lBfY 28, 2013, Septemeer e, 2013, Feer1:1ai:y 24, 2014, April 1S, 2014, S013tember 26, 2014,.~f:IFil 10, 2016,

.~1:1gust 14, 2016, J1:1Ao 30, 2018, A1::1g1:Jst 31, 2018, Doeefflbe r 18, 2018 aRd Merel'! 13, 2017 ;

BREI iR eoeorElaRee witR etatemeRlS, represeAtalieRB, BREI 88A&itiOAS, perteiniAg to tRe NRG's Blf)f:IFOIJOI of LiOORSO BffleA&meAt a9elieatio A Elated September 16, 2016, BREI No\\1efflber 18, 2018. DELETED

h. Fundamental Nuclear Material Control Plan dated February 11, 2003, as modified by revisions dated July 1, 2005, November 30, 2005, October 16, 2006, July 10, 2007, January 25, 2008, January 15, 2009, January 30, 2009, April 10, 2009, October 22, 2010, November 17, 2010, October 12, 2011, January 31, 2012, September 10, 2012, February 20, 2013, December 18, 2015, June 30, 2016, December 16, 2016, and March 13, 2017.

i. Original Quality Assurance Program Description dated July 19, 2002, as modified by revisions dated July 1, 2005, November 30, 2005, January 26, 2006, January 26, 2006,

.June 30, 2006, January 25, 2008, and July 23, 2008. Replaced by Quality Assurance Program Description referenced in SNM-2011 dated July 18, 2008, October 9, 2008, January 15, 2009,* January 30, 2009, June 10, 2009, September 4, 2009, October 28, 2009, April 30, 2010, August 11, 2010, November 17, 2010, September 10, 2012, February 20, 2013, August 14, 2015, June 30, 2016, August 31, 2016, December 16, 2016, and March 13, 2017.

j. Deleted by Amendment 19.

k. Deleted by Amendment 19.

I. Transportation Security Plan for Classified Matter Shipments dated November 25, 2008, as modified by revision dated April 12, 2010, November 17, 2010, February 28, 2013, March 13, 2017, and September 30, 2020; and in accordance with statements, representations, and conditions, pertaining to the U.S. Nuclear Regulatory Commission 's approval of License amendment application dated March 10, 2020.

m. Operations Security Plan 331-06-161, approved January 20, 2012, as modified by revisions dated December 2012 (approved January 25, 2013), December 2013 (approved on April 1, 2014), November 2014 (approved on July 8, 2015), and March 2020 (approved on October 30, 2020).

n. Deleted by Amendment 19.

3 LA-2605-0001

License Application

American Centrifuge Lead Cascade Facility in Piketon, Ohio

Proposed Change

Docket No. 70-7003 April 2022

Information Contained Within Does Not Contain Export Controlled Information Reviewing Official: #1038 -------

Date: 04/05/2022 License Application for th e American Ce ntrifuge Lead Cascade Facility Proposed Change April 2022

2.1.6 Director, Engineering........................................................................... 2-11

2.1.6.1 Piketon Engineering Manager...................................................... 2-12

=2=*-=-l."-'-7....... Director, Corporate Security............................................. 2-13

2. 1.-7~ Plant Shift Superintendent (Contractor)............................................. 2-1+/-;

2.1. &.2_ Shift Crew Composition.................................................................... 2-1 ! ;

2.2 Management Controls.................................................................................... 2-1 ~

2.2.1 Faci lity Safety Review Committee.................................................... 2-1 1 6

2.3 Pre-operational Testing and Initial Start-up................................................... 2-1 1 6

2.3.1 Pre-operational Testing Objectives.................................................... 2-1 ~ +

2.3.2 Turnover, Functional, and Initial Start-up Test Program................... 2-1 ~ +

2.4 References...................................................................................................... 2-1.2_&

3.0 INTEGRATED SAFETY ANALYSIS AND INTEGRATED SAFETY ANALYSIS

SUMMARY

.............................................................................................. 3-1

3.1 Safety Program and Integrated Safety Analysis Commitments......................... 3-1

3.1.1 Process Safety Information.................................................................... 3-1

3.1.2 Integrated Safety Analysis..................................................................... 3-2

3.1.3 Management Measures.......................................................................... 3-3

3.2 Integrated Safety Analysis Summary................................................................. 3-3

3.3 References.......................................................................................................... 3-4

4.0 RADIATION PROTECTION...................................................................................... 4-1

4.1 Radiation Protection Program Implementation................................................. 4-1

4.2 ALARA Program............................................................................................... 4-1

4.2. 1 ALARA Committee............................................................................... 4-2

4.3 Organization and Personnel Qualifications....................................................... 4 -3

4.4 Written Procedures............................................................................................. 4-4

4.4.1 Procedures.............................................................................................. 4-4

4.4.2 Radiation Work Permits......................................................................... 4-4

iii FOR INFORMATION ONLY Lice nse Application f or th e Ame ri can Centrifug e Lead Cascad e Fa c ility Proposed Change April 2022

1.2.2 Financial Qualifications

The Licensee receives its financing through operating and management agreements from ACE. ACE receives its financing through USEC Inc. (capital infusion obligations), loans, and related agreements, potential future third party investors, and once operations of the ACP commences, revenues generated from the sale of enriched uranium. The Lead Cascade refurbishment and operating costs are documented in Appendix D of the E nvironmental Report for the American Centrifuge Lead Cascade Facility.

As reported in USEC Inc.' s fiscal year 2002 Annual Report (Reference l), based on customers ' estimates for enrichment requirements and certain other assumptions, including estimates of inflation rates, at June 30, 2002, USEC Inc. had long-term requirements contracts aggregating $4.5 billion through fiscal 2011 (including $2.7 billion through fisca l 2005). Net income amounted to $16.2 million (or $.20 per share) in fiscal 2002. The latest USEC Annual Report may be consulted for current information.

ACE is the provider of funds for the construction and operation of the Lead Cascade through

operating and management contracts to the Licensee. Expenditures related to the Lead Cascade, includin g any related cost over-runs, will be paid by AC E from a variety of sources including existing and projected capital infusion from USEC Inc. and loans.

1.2.3 Type, Quantity, and Form of Licensed Material

The type, quantity, and form of NRC-regulated source and special nuclear material are s hown in Table 1.2-1.

1.2.4 Authorized Uses

The Lead Cascade enriches UF 6 up to 10 wt. percent 23 5U. The Lead Cascade is operated on recycle where the enriched product stream is recombined with the depleted stream prior to bein g re-fed to the cascade. No product withdrawals are made from the Lead Cascade except for samples taken for laboratory analysis. Withdrawal of small quantities of depleted material ma y also be performed on an infrequent basis for operational considerations, with subsequent addition of feed to the cascade. The Lead Cascade may possess up to 250 kg U F6. The specific authorized uses for each class of NRC -regulated material are shown in Tabl e 1.2-2.

1.2.5 Special Exemptions or Special Authorizations

The following exemption to the applicable 10 CFR Part 20 po sting and labeling requirements are identified in Section 4.8.1 of this license application:

Five, eight, and twelve-inch uranium cylinders are routinely transported between faci l ity locations and/or storage areas at the Lead Ca scade a nd are readil y identifiabl e due to th e ir size and unique c o nstru ction. T hese are no t rou t in e ly lab e led a s radioactive material. The transportation of UF 6 cylinders and U F6 sample cont a iners are constantly attended by qualified Radiological Workers during movement.

1-40 Lice nse Appli cation for the Ameri can Ce ntrifug e Lead Cas cade F a cility Propo sed Change April 2022

The following exemption to the applicable 10 CPR 70.50 reporting requirement is identified in Section 11.6.6 of this license application :

The 10 CPR 70.50( c )(2) reporting criteria requires t hat the Licensee submit a written report within 30 days of the initial report required by 10 CPR 70.50 (a) or (b) or by 10 CPR 70.74 and Appendix A of Part 70. In lieu of the 30-day requirement described in 10 CPR 70.50(c)(2), the Licensee requests NRC approval to submit the required written reports within 60 days of the initial notifications.

The following Special Authorization has been identified in this license application:

Surface Contamination Release Levels for Unrestricted Use - Items may be released for unrestricted use if the surface contamination is less than the lev e ls listed in Table 4.6-1.

The following exemption from the requirements in 10 CPR 95.57(c) is identified in Section 2-l, 17.c) of the Seettrity Program SP-3605-0041, Security Plan for the Protection of Classified Matter at the American Centrifuge Plant :

NRC regulations in 10 CPR 95.57(c) require that all classification actions (documents classified, declassified, or downgraded) to be submitted to the NRC Division of Security Operations. These may be submitted either on an " as completed " basis or monthly. The information may be submitted either electronically by an on-line system or by paper copy using NRC Form 790. Hi storically, USEC has utilized NRC Form 790 for each classification action, ha s compiled them monthly, and submitted them to the NRC. US E C must also submit a quarterly clas sification summary document to the DOE for all derivative classification decisions made during the previous quarter. This dual reporting is burdensome to the Derivative Classifiers and the Classification Officer and creates a situation where the classification actions may be double counted. Accordingly, in lieu of filing its classification action s with NRC,

USEC will eontintte to sttbmit the qttarterly classification sttmmary doettments to they will be made by the Classification Officer to the DOE at a frequency (e.g., annually) and in the format specified by the DOE.,_ ---aflti-These documents will be made make them available for NRC inspection at the facility.

1.2.6 Security of Classified Information

The Licensee is required by 10 CPR 70.22(m) to submit, as part of its application for a license for the Lead Cascade, a plan describing the facility ' s proposed security procedures and controls, as set forth in 10 CPR Part 95, for the protection of classified matter. The Licensee sati sfied this requirement by submission o f its plan for the protection of cla ss ified matter as Chapter 2 of the Security Program SP-3605-0041, Security Plan for the Protection of Classified Matter at the American Centrifuge Plant.

1-41 License Application for the American Ce ntrifuge Lead Cascade Facility Proposed Change April 2022

1.5 References

1. USEC 2002 Annual Report

2. U.S. Bureau of the Census, 2000, " Profiles of General Demographic Characteristics:

2000 Census of Population and Housing, Ohio ", U.S. Department of Commerce, May 2001, Website: http://www.census.gov/prod/cen2000/dp1/2kh39.pdf

3. 329 - 10-002, ACP Memo dated October 15, 2010, " Worker and Transient Populations in and around PORTS DOE Reservation, as of October 2010", S. E. Keller

4. USEC-02, Application for United States Nuclear Regulatory Commission Certification,

Portsmouth Gaseous Diffusion Plant, Safety Analysis Report

5. Ohio Department of Natural Resources, Website accessed October 21, 2002, http://www.dnr.state.oh.us/parks/parks/lkwhite.htm

6. U.S. Department of the Interior, U.S. Geological Survey, Reston, VA, Website :

http://www. usgs. gov /index.html

7. Tetra Tech, Inc. correspondence, " Methodology for the 5-mile Population Grids,"

November 2002

8. CDR-2000-0001, Lead Cascade Conceptual Design Report, Revision 0, January 13, 2003

9. SP-3605-0041, Security Plan for the Protection of Classified Matter at the American Centrifuge Plant Lead Caseade Seeurity Program, AET 02 0004, Ste*f'en A. Toelle letter to Mr. Marttn J. Vtrgtlto, dated Jui)' 3, 2002

10. NUREG-1520, Standard Review Plan for the Review of a License Application for a Fuel Cycle Facility

1-96 License Application for the American Centrifuge Lead Cascade Facility Proposed Change April 2022

mechanical maintenance, such as valve, pump, and mechanical equipment repair and replacement.

The Maintenance Work Center Supervisor is also responsible for integrated planning,

scheduling, and materials management. This includes maintenance of logs and records; managing daily work control activities ; maintenance of an integrated work schedule to initiate, screen, evaluate, and prioritize maintenance work; coordinating shop maintenance activities ; and coordinating development of work control guidelines.

Maintenance Work Center Supervisor has, as a mm1mum, a high school diploma or satisfactory completion of the General Educational Development test, and three years of industrial/chemical/nuclear plant operations, maintenance, engineering or support experience.

Maintenance Work Center Supervisors must have one year of supervisory experience or completion of a supervisory training course.

2.1.2.3.5.1 Balance of Plant Operations Shift Supervisors

BOP Operations Shift Supervisors report to the BOP Process Area Manager and are responsible for directing the activities for plant utilities processes and facilities within approved programs, processes, and procedures.

BOP Operations Shift Supervisors have, as a mm1mum, a high school diploma or satisfactory completion of the General Educational Development test, and three years of industrial/chemical/nuclear plant operations, maintenance, or engineering experience. BOP Operations Shift Supervisors must have one year of supervisory experience or completion of a supervisory training course.

2.1.2.4 Production Support Manager

The Production Support Manager reports to the Enrichment Operations Plant Manager.

This manager is responsible for fire safety; emergency management; radiation protection (RP),

which includes chemical process safety, health physics, industrial hygiene, industrial safety,. and environmental/waste management; seeurity; and training and procedures, which includes records management and document control. During commercial operations, this manager will also be responsible for the Customer Order Management program.

The Production Support Manager has, as a minimum, a bachelor's degree in engineering or the physical sciences or equivalent technical experience, and four years of nuclear experience.

2.1.2.4.1 Fire Safety / Emergency Management Manager

The Fire Safety/Emergency Management Manager reports to the Production Support Manager. This manager is responsible for the Fire Safety program ; fire protection systems and services (i.e., including emergency and fire response, fire inspection, fire testing services,

interpretation and application of applicable fire codes and standards) ; and emergency management.

2-8 License Application for the American Centrifuge Lead Cascade Facility Proposed Change Apri l 2022

The Fire Safety/Emergency Management Manager has, as a minimum, a bachelor 's degree or equivalent technical experience, four years of fire protection experience, and six months of nuclear experience.

2.1.2.4.2 Radiation Protection Manager/ Supervisor

The Radiation Protection Manager (RPM)/Supervisor reports to the Production Support Manager. The RPM/Supervisor is responsible for the RP Program and administration on a day to -day basis, including providing guidance and direction for establishment and implementation of the RP Program and has the authority to deny access to radiological areas by personnel who do not adhere to radiological protection requirements. The RPM/Supervisor also has oversight of radiological protection procedures in order to maintain the integrity of the RP Program. The RPM/Supervisor has direct access to the Enrichment Operations Plant Manager and the Senior Vice President for RP matters.

This position also has programmatic responsibilities for chemical process safety, health physics, industrial hygiene, and environmental/waste management activities.

The RPM/Supervisor has, as a minimum, a bachelor 's degree in engineering, health physics, RP, or the physical sciences or equivalent technical experience, and four years experience in RP, including six months of prior Radiation Protection Manager/Supervisor experience at a nuclear facility.

2.1.2.4.3 Sec tion Reserved for Future Use urity Moeoger

The Security MaAager reports to the ProductioA Support MaAager. This ml1/4Ilager is respoAsible for the strategic directioA of the site security operatioAs l1/4Ild programs for safeguards aAd security services. The Security MaAager has direct access to the EnrichmeAt OperatioAs Plant MaAager aAd SeAior Vice PresideAt for security matters.

The Security MaAager has, as a miAimum, a bachelor's degree or equivaleAt technical e:x:perieAce, aAd four years security e~e:perieAce.

2.1.2.4.4 Training and Procedures Manager

The Training and Procedures Manager reports to the Production Support Manager. This manager is responsible for preparation, presentation, and documentation of employee orientations ; and for technical and qualification training program development and implementation. This manager is also responsible for the development and implementation of the Procedures program and the programmatic oversight of the Records Management and Document Control (RMDC) programs.

The Training and Procedures Manager has, as a mm1mum, a bachelor 's degree in engineering or the physical sciences or equivalent technical experience, and four years of nuclear experience.

2-9 li ce nse Appli cation for th e Ameri can Ce ntrifu ge Lead Ca sc ade F a cility Prop os ed Change April 20 22

2.1.6.1.3 Piketon Design Engineering Manager [commercial operations only]

The Piketon Design E ngineering Manager reports to the Piketon E ng ineering Manager.

Thi s manager has responsibility for the design engineering activities in s upport of plant operations, which includes providing en g ineerin g support and review of the design and modification s of IROFS.

The Piketon Design E ngineering Manager has, as a minimum, a bachelor ' s degree in engineering or the physical sciences or equivalent technical experience, and four years of nuclear experience.

2.1.7 Director, Corporate Security

The Director, Corporate Security reports to the Senior Vice President, Field Services, and is independent from production, plant operating costs, and production schedule concerns. This director has authority to direct actions necessary for the safeguarding of classified information within the enterprise and to achieve or maintain compliance with applicable regulatory requirements. The Director, Corporate Security oversees the work of each of the site Security Managers, Classification Officer, and Information System Security Manager.

The Director, Corporate Security is appointed as the Senior Management Official (SMO) for the protection of the Licensee ' s classified technology regardless of location within the enterprise. This director is also responsible for the establishing the entity's security policy and strategy for implementation throughout the enterprise.

The Director, Corporate Security has, as a minimum, a bachelor ' s degree or equivalent technical experience, and six years security and safeguards experience.

2.1.7.1 Security Manager

The Security Manager reports to the Director, Corporate Security. This manager is responsible for the strategic direction of the site security operations and programs for safeguards and security services. The Security Manager has direct access to the Enrichment Operations Plant Manager and Senior Vice President for security matters. The Security Manager has matrixed responsibilities directly to the Enrichment Operations Plant Manager in support of secured operations at the Piketon ACP facilities.

The Security Manager has, as a minimum, a bachelor ' s degree or equivalent technical experience, and four years security experience.

2-13 License Application for the American Ce ntrifuge Lead Cascade Facility Proposed Change April 2022

2.1. ~ + Plant Shift Superintendent (Contractor)

The Plant Shift Superintendent (PSS) reports to the contractor management. The PSS is responsible for accumulation and dissemination of information regarding site activities, serving as or designating an Incident Commander during emergencies, and making notification of events.

The PSS has the authority and responsibility to make decisions as necessary to ensure safe site operations, including stopping work. The PSS provides a centralized point for incident identification, screening, and reporting. The PSS's responsibilities are consistent with those exercised at the gaseous diffusion plant for emergency response.

The PSS has, as a minimum, a bachelor 's degree in engineering or the physical sciences or equivalent technical experience and four years experience at a gaseous diffusion plant, or a high school diploma plus 12 years experience at a gaseous diffusion plant.

2.1.,28 Shift Crew Composition [only during operational phases with licensed material]

The minimum operating shift crew consists of an Operations Shift Supervisor, a Radiation Protection/Industrial Hygiene technician, and one operations technician per process building. Other personnel, such as NCS, will be available on an as needed basis.

2-14 License Appli cation for the Am eri can Centrifuge Lead Cascade Fa cility Propo sed C ha nge April 2 02 2

Senior Vice Preoldent, Field Operations

Director, Qua lity Director, Engineering, Director, Nuclear Director, Engineer ing Assurance Procurement, and -------,----~---- Safety ( Design Authority )

Construct ion Enrlchm-Operations

, __________...__ ___ Plant Monacer....,. ___ _

Piketon Quality Nuclear Criticality Piketon Engineering Assuranc.e I,..__ ______ __, I Safety ( Delegated Design Authority)

-------------- - - -----J I

'- -------------------- Systems Enginee ri ng I

Regulatory Bus iness Ope rat ions

Nu clear Cascade/ Recycl e Mater ials - -- *{ Procurement and Assemb ly Fire Safety/ Emergency Operations Shift Management Control and Superv isors Accountability Rad iat ion Protection Packaging, Manager/ Superv isor Health Phys ics and Transportation, Indu stri al Hygiene and Materia ls Management Secur ity

BOP Process Env ironmental / Waste Area Manager Training and Management

Procedu res BOP Operations Ma intenance Shift Superv isor Sh ift Superv isors Records Management/

Document Contro l Figure Being Deleted

2-15 License App/icat ianfar the American Centrif uge Lead Cascade Fac ility Proposed Cha nge April 2022

SaftiofVice P,-sident., F..ad Opamion.1

Director, Qua lity Director, Encineerinc, Director, En,cineuinc Anura nce Procura mttn t, and OirKtOr, Nuclear ( Desicn Authority ) Directo r, Corponte Construction Enrichment Ope-rations S.fety Security PlantMINP,

Piketon Q-u1ljfy Nuc ~ar Criti ca lity Piketo n £nc in ee rinc Security Assunn ca -----------'

. - - - -~ - - -- -- - -~ -'*-_ tv __ -_-_-_-_~j.__( 0_0_1e_1~*-tod_ o.. __ icn_ A_u_th_o_mv_ )__,

------------ --------i Systom, En1inHrin1

Re1ul1tory BusinHS Operations Productio n Se rvices Support Confi1ur1 tio n

~scad* / Retycie Miln~Jement Nuclear lntct,nted and Assembty Fire Sllfety / Em ercency MUeri1ls - - *f~_P,_ocur __ *m_*_"'~ Systems Test/ Operat ions Shift Manacament Contro l and Start-up Supervisors Accounub ilfty R1di.ation Protection P1ck11 in1, M1n*1er / Supervisor Hea lth Physics and Tnnspo rt1t ion,

ind M1teri1l1 Industrial Hy1 i*n*

M1n11ement Tn lninc1 nd Proce duru Env ironmenta l / Waste BOP Proces.s Manapment Ar** M.an11*r Records Manasement /

BOP Ope,..tions Maintena n ce lndu1trl1I Document Control

Shift Supervisor Shift Supervisors S.foty

Figure 2.1 -1 American Centrifuge Organization Chart

2-16 LA-3605-0001

License Application

for the American Centrifuge Plant in Piketon, Ohio

Proposed Change

Docket No. 70- 7004 April 2022

Information Contained Within Does Not Contain Export C ontrolled Information Reviewing Official: ___.c....c#l---'--'03'-"-8 __ _

Da te: 04/05/2022 license Application for the American Centrifuge Plant Proposed Change April 2022

2.0 ORGANIZATION AND ADMINISTRATION............................................................ 2-1

2.1 Organizational Commitments, Relationships, Responsibilities, and Authorities.......................................................................................................... 2-2

2.1.1 Senior Vice President, Field Operations................................................ 2-2

2.1.2 Enrichment Operations Plant Manager.................................................. 2-3

2.1.3 Director, Quality Assurance................................................................... 2-9

2.1.4 Director, Engineering, Procurement, and Construction....................... 2-10

2.1.5 Director, Nuclear Safety...................................................................... 2-10

2.1.6 Director, Engineering........................................................................... 2-11

2.1. 7 Director, Corporate Security................................................................ 2-12

=2.=1~.8_ Plant Shift Superintendent (Contractor)............................................. 2-IJi

2.1.28-Shift Crew Composition [ only during operational phases with licensed material]........................................................... 2-IJi

2.2 Management Controls...................................................................................... 2-14

2.2.1 Plant Safety Review Committee.......................................................... 2-15

2.3 Pre-operational Testing and Initial Start-up..................................................... 2-15

2.3. 1 Pre-operational Testing Objectives...................................................... 2-16

2.3.2 Turnover, Functional, and Initial Start-up Test Program..................... 2-16

2.4 References........................................................................................................ 2-16

3.0 INTEGRATED SAFETY ANALYSIS AND INTEGRATED SAFETY AN.AL YSIS

SUMMARY

.............................................................................................. 3-1

3.1 Safety Program and Integrated Safety Analysis Commitments......................... 3-1

3.1.1 Process Safety Information.................................................................... 3-1

3.1.2 Integrated Safety Analysis..................................................................... 3-2

3.1.3 Management Measures........................................................................ 3-31

Ill Lice nse Application for the American Centrifuge Plant Proposed Change April 2022

Figure 1.3-11 Location of the Ancient Newark (Modern Scioto) and Teays Valle ys in the U.S. Department of Energy Reservation Vicinity............................... 1-111

Figure 1.3-12 Geologic Cross Section in the U.S. Department of Energy Reservation Vicinity.......................................................................................................... 1-112

Figure 1.3-13 Geologic Column at U.S. Department of Energy Reservation..................... 1-113

Figure 2.1-1 American Centrifuge Organization Chart...................................................... 2-1 ~ :3-

Figure 9.2-1 Locations of American Centrifuge Plant Monitored Vents............................. 9-57

Figure 9.2-2 Locations of American Centrifuge Plant Outfalls Discharging to Waters of the United States.......................................................................................... 9-58

Figure 9.2-3 Locations of Soil and Vegetation Sampling Points......................................... 9-59

Figure 9.2-4 Locations of Surface Water Sampling Points.................................................. 9-60

Figure 9.2-5 Locations of Stream Sediment Sampling Points.............................................. 9-61

Figure 9.2-6 Locations of E nvironmental Thermo luminescence Dosimeters on the U.S.

Department of Energy Reservation.................................................................. 9-62

Figure 9.2-7 Locations of Environmental Thermoluminescence Dosimeters Outside the U.S. Department of Energy Reservation Boundary................................... 9-63

Figure 10.2.1-1 Commerc ial ACP Contamination Control Zone........................................... 10-5

xv FOR INFORMATION ONLY License Application for the American Centrifuge Plant Proposed Change April 2022

The type, quantity, and form of NRC-regulated special nuclear, source, and by-product material are shown in Table 1.2-1 for the proposed commercial plant and Table 1.2-2 for the HALEU Demonstration Program (see Appendix D of this license application).

1.2.4 Authorized Uses

The commercial ACP operation enriches UF6 up to 10 wt. percent 235 U. The specific authorized uses for each class of NRC-regulated material are shown in Table 1.2-3.

The HALEU Demonstration cascade enriches UF6 up to a target enrichment of 19.75 wt.

percent 235 U, but less than 20 wt. percent mu. Enrichment levels up to 25 wt. percent 235 U are authorized to permit for process fluctuations which can create small amounts of higher weight percent material. The specific authorized uses for each class of NRC-regulated material for the HALEU Demonstration Program are shown in Table 1.2-4. The Licensee proposes that the license be conditioned as follows :

ACP shall not enrich UF 6 in excess of 20 wt. percent 235 U other than in the course of cascade performance adjustments, thus providing the operational flexibility to generate material to satisfactorily fulfill customer orders up to 20 wt. percent mu. ACP shall not input parameters to extract product material for the assay above 20 wt. percent 235 U at any time.

Within the ACP Operations, the Licensee will provide a minimum 60-day notice to the NRC prior to initial customer product withdrawal of licensed material exceeding 5 wt. percent 235 U enrichment. This notice will identify the necessary equipment and operational changes to support customer product withdrawal, storage, processing, and shipment for these assays.

1.2.5 Special Exemptions or Special Authorizations

The following exemption to the applicable 10 CFR Part 20 requirements are identified in Section 4.8 of this license application:

UF 6 feed, product, and depleted uranium cylinders, which are routinely transported inside the DOE reservation boundary between ACP locations and/or storage areas at the ACP, are readily identifiable due to their size and unique construction and are not routinely labeled as radioactive material. Qualified radiological workers attend UF 6 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 20.1601(a), each High Radiation Area with a radiation reading greater than 0.1 Roentgen Equivalent Man per hour (REM/hour) at

1-74 FOR INFORMATION ONLY Lice nse Application for the American Centrifuge Plant Proposed Change April 2022

30-centimeters (cm) but less than 1 REM/hour at 30 cm is posted Caution, High Radiation Area and entrance into the area shall be controlled by an RWP. Physical and administrative controls to prevent inadvertent or unauthorized access to High and Very High Radiation Areas are maintained. The on-site radiological impacts from the proposed exemptions to the requirements of 10 CFR 20.1904 and 20.1601 would be minimal and are consistent with previously approved exemptions found in the GDP certification. Moreover, pursuant to the regulations in 10 CFR 20.2301, the requested exemption is authorized by law and would not result in undue hazard to life or property.

The following exemption from the applicable 10 CFR 70.50 reporting requirement is identified in Section 11.6.3 of this license application :

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.

10 CFR 70.17 allows the Commission, upon application of any interested person or upon its own initiative, to grant such exemptions from the requirements of the regulations in this part as it determines are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. The requested exemption is authorized by law because there is no statutory prohibition on extending the reporting period to 60 days.

Furthermore, granting this exemption request will not endanger life or property or the common defense and security, in that the exemption request does not relieve the ACP from other requirements contained in 10 CFR 70.50 (a) or (b) or by 10 CFR 70.74 and Appendix A of Part 70, such as 1-hour, 4-hour, and 24-hour reporting requirements for defined events.

The proposed exemption would result only in written reports being submitted within the time limit currently allowed under 10 CFR 50.73 for commercial nuclear power plants.

It would be consistent with the exemption granted to the gaseous diffusion plants for reporting of events pursuant to 10 CFR 76. 120(d)(2) (67 Federal Register 68699,

November 12, 2002) and the exemption granted to the Lead Cascade during licensing.

This proposal allows for completion of required root cause analyses after event discovery and fewer supplemental reports, thereby reducing regulatory burden and confusion. Thus, it is clearly consistent with the public interest.

The Licensee notes that the requirements of 10 CFR 20.2201 and 20.2203 require written reports of certain events within 30 days after their occurrence. The Licensee is not requesting an exemption from these reporting requirements.

1-75 FOR INFORMATION ONLY License Application for the American Ce ntrifug e Plant Proposed Change April 2022

The following exemption from the requirements of 10 CFR 70.25(e) and 10 CFR 40.36(d) addressing the decommissioning funding requirements is identified in Section 10.1 of this license application :

10 CFR 70.25(e) and 10 CFR 40.36(d) require, in part, that " The decommissioning funding plan must also contain a certification by the licensee that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning... ".

In support of HALEU Demonstration Program, as noted in Section 10. 1 of this license application, DOE amended the Appendix I Lease Agreement between the US Department of Energy and United States Enrichment Corporation for the Gas Centrifuge Enrichment Plant (GCEP Lease Agreement). In the amended GCEP Lease Agreement, DOE 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 environmenta l hazards on the site. Therefore, exempt ing ACO from any financial assurance for any liability or lease turnover conditions shall be required from the Corporation (Licensee).

Additionally, as stated within the amended GCEP Lease Agreement, the parties agree that should any liabilities of the Corporation (Licensee) arise from or incident to the performance of work under the Demonstration Contract with the DOE shall be governed solely by such contract and any financial protection afforded to the Corporation (Licensee) as a person indemnified under the Act.

The following exemption from the requirements of 10 CFR 70.25(e) and 10 CFR 40.36(d) addressing the decommissioning funding requirements is identified in Section 10.2. 10.4 and the DFP of this license application :

10 CFR 70.25(e) and 10 CFR 40.36(d) require, in part, that "The decommissioning funding plan must also contain a certification by the licensee that financial assurance for decommissioning has been provided in the amount of the cost estimate for decommissioning... ".

In support of future expansion of the ACP, as noted in Section 10.2.10.4 of this license application, the financial assurance for a portion of the decommissioning costs, to include the disposition of centrifuges and UF 6 tails, which constitutes a major portion of the decommissioning liability, will be provided incrementally as centrifuges are built/installed and UF 6 tails generated. Full funding for decommissioning of the facilities will be provided in the initial executed financial assurance instrument.

This exemption is justified for the following reasons : 1) It is authorized by law because there is no statutory prohibition on incremental funding of decommissioning costs. 2)

The requested exemption will not endanger life or property or the common defense and security for the following reasons: the unique modular aspects of the American Centrifuge technology allow enrichment operations to begin well before the full capacity of the plant is reached. Thus, the decommissioning liability for centrifuges and

1-76 FOR INFORMATION ONLY License Application for the American Centrifuge Plant Proposed Change April 2022

UF6 tails is incurred incrementally as more centrifuges are added to the process, until full capacity of the facility is reached; at which point the UF6 tails are generated at a relatively constant rate throughout the life of the plant. As such, requiring full funding for decommissioning liability, to include centrifuges and UF6 tails disposition, incurred over the lifetime of the plant, at the time of initial license issuance, produces an unnecessary financial burden on the licensee.

Furthermore, incremental funding of decommissioning costs, to include centrifuges and UF6 tails disposition, is justified based upon the Licensee's commitments to update the cost estimates and provide a revised funding instrument for decommissioning annually, to cover the upcoming period of operation, prior to operation at full capacity, and after full capacity has been reached to annually adjust the cost estimate for UF6 tails disposition and to adjust all other decommissioning costs periodically, and no less frequently than every three years. In addition, the relative stability of the factors, which are utilized to generate the UF6 tails volumes, allows actual inventory values to be provided for prior periods of operation and reliable estimates for the upcoming periods of operation. The NRC has previously accepted an incremental approach to decommissioning funding costs for the United States Enrichment Corporation's operation of the GDPs. 3) Finally, granting this exemption is in the public interest for the same reasons as stated above and will facilitate deployment of gas centrifuge enrichment technology by eliminating an unnecessary financial burden on the licensee.

The following exemption from the requirements of 10 CFR 70.24 addressing criticality monitoring is identified in Section 3.10.6 of the ISA Summary and discussed in Section 5.4.4 of this License Application. Exemption is required for criticality monitoring of the UF6 cylinder storage yards.

10 CFR 70.24, Criticality Accident Requirements, requires that licensees authorized to possess special nuclear material in a quantity exceeding 700 g of contained 235 U shall maintain in each area in which such licensed special nuclear material is handled, used, or stored, a monitoring system capable of detecting a criticality that produces an absorbed dose in soft tissue of 20 rads of combined neutron and gamma radiation at an unshielded distance of two meters from the reacting material within one minute.

10 CFR 70. 17 allows the Commission, upon application of any interested person or upon its own initiative, to grant such exemptions from the requirements of the regulations in this part as it determines are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. The requested exemption is authorized by law because there is no statutory provision prohibiting the grant of the exemption. The requested exemption will not endanger life or property or the common defense and security and is otherwise in the public interest for the reasons discussed below.

Transportation, handling and storage of solid UF6 filled cylinders are doubly contingent.

Double contingency is established by multiple controls that limit the likelihood for a solid product cylinder to be breached during transportation, handling or storage, and the

1-77 FOR INFORMATION ONLY license Application for th e Ameri can Ce ntrifuge Plant Proposed Change April 2022

likelihood for a breach to not be identified and repaired before sufficient moderation results in a criticality. Moderation control of UF 6 filled cylinders is maintained by ensuring cylinder integrity through periodic cylinder inspections. If a UF6 filled cylinder is found to be breached, the cylinder is covered within 24-hours after discovery to reduce the potential accumulation of moderating material, i.e., rainwater. This time limit ensures a corresponding heavy rainfall will not result in accumulation of sufficient amounts of water to cause a criticality. Damaged cylinders are repaired as necessary and emptied. UF 6 cylinders are uniquely identified and their design requirements are controlled to further ensure cylinder integrity and reliability (i.e., UF 6 cylinders are QL-1 components and are controlled in accordance with the Quality Assurance Program Description), and the Licensee implements onsite cylinder handling practices (i.e.,

requiring the use of approved equipment in accordance with approved procedures),

which reduces the likelihood that a solid UF 6 cylinder would be breached. These requirements are established as items relied on for safety to ensure the health and safety of the public and workers.

The UF 6 cylinders stored in storage yards are not covered by a criticality monitoring system unless those cylinders contain licensed material greater than 5.0 weight percent 235 U. NCS evaluation of product cylinders of any size, configured in infinite planar arrays, containing material enriched up to 5.25 weight percent 235 U, has concluded that subcritical conditions are maintained. The ACP ISA has concluded that cylinders containing licensed material less than or equal to 5.0 weight percent 235 U cannot be involved in a criticality accident sequence that has a probability of occurrence that e x ceeds 5 x 10-6/year.

The frequencies of criticality events in the cylinder yards have been decreased to the Highly Unlikely range (< 10-5/year) through the establishment of preventive controls established by the ISA in accordance 10 CFR 70.62. Considering the conservatism of the ISA methodology in developing the unmitigated frequency and actual historical data related to cylinder operations, the frequency values could be reduced further. This additional reduction considers the fact that during 50 years of GDP operations, only one cylinder breach has occurred due to mishandling or equipment failure. Since that occurrence, cylinder handling equipment has been redesigned and cylinder handling methods have been revised to minimize the potential for breaches to occur. Another fact not considered in the ISA is that holes with a dimension of less than one inch will self-seal such that moderating material cannot infiltrate the breach. A third factor not considered in the ISA is that enriched cylinder operations require constant use and monitoring of cylinders such that corrosion breaches in enriched cylinders are highly unlikely. Allowing for this additional reduction in frequency, the probability for a criticality event becomes incredible, therefore CAAS coverage is not necessary.

The increased vehicular and pedestrian traffic in support of CAAS maintenance and calibration requirements would cause a subsequent increased likelihood for impact events involving cylinders and there would be an increa s ed safety risk for workers from radiation exposure due to the ongoing CAAS maintenance and calibration requirements.

To meet the CAAS coverage requirements in ANSI 8.3 and the operating requirements

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for the ACP, enriched cylinder storage yards would require a minimum of 60 clusters.

Clusters would need to be at a height of approximately 40 feet, which would require maintenance equipment and pedestrian traffic to perform testing and preventative maintenance tasks to ensure their reliability and operability. This equipment and traffic would increase the likelihood for fire and impact events in the cylinder storage yards such that workers would be at a higher risk for injury and exposure relative to the minimal mitigative value produced by the presence of CAAS.

The following exemption from the requirements of 10 CFR 140.13b crediting DOE indemnity in lieu of nuclear liability insurance as discussed in Section 1.2.2 of this license application.

10 CFR 140. 13b requires, that "Each holder of a license issued under Parts 40 or 70 of this chapter for a uranium enrichment facility that involves the use of source material or special nuclear material is required to have and maintain liability insurance. The liability insurance must be the type and in the amounts the Commission considers appropriate to cover liability claims arising out of any occurrence within the United States that causes,

within or outside the United States, bodily injury, sickness, disease, death, loss of or damage to property, or loss of use of property arising out of or resulting from the radioactive, toxic, explosive, or other hazardous properties of chemical compounds containing source material or special nuclear material. Proof of liability insurance must be filed with the Commission as required by § 140.15 before issuance of a license for a uranium enrichment facility under parts 40 and 70 of this chapter."

In support of this HALEU Demonstration Program, DOE amended the GCEP Lease Agreement, in which the parties agree that all work performed under the HALEU Demonstration Contract on leased premises shall be considered a permitted use; any alterations or changes to the premises pursuant to the Demonstration Contract with the DOE shall be a permitted change to the premises ; and that 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 solely by such contract.

Therefore, the Demonstration Contract exempts ACO from any financial assurance for any liability insurance during the three-year contract period.

In support offuture expansion of the ACP, in accordance with Section 3107 of the USEC Privatization Act, the Lease with DOE for the DOE owned facilities that will be used for the ACP includes an indemnity agreement from DOE under Section 170d of the Atomic Energy Act (AEA) for liability claims.

The Commission may, pursuant to 10 CFR 140.8, upon application of any interested person or upon its own initiative, grant such exemptions from the requirements of the regulations in this part as it determines are authorized by law and are otherwise in the public interest. This exemption is authorized by law because there is no statutory prohibition on crediting the DOE indemnity agreement in lieu of nuclear liability insurance. The DOE indemnity agreement contained in the Lease pursuant to DOE ' s authority in Section 170d of the AEA is sufficient to meet the requirements of Section

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193( d) of the Atomic Energy Act of 1954, as amended. Section 193( d) states that " the Commission shall require, as a condition of the issuance of a license... for a uranium enrichment facility, that the licensee have and maintain liability insurance of such type and in such amounts as the Commission judges appropriate to cover liability claims... "

The Lease requires that the Licensee obtain "financial protection to cover public liability, [as defined in the AEA] in such amount and of such type as is commercially available at commercially reasonable rates, terms and conditions " (Lease at Section 10.l(c)). To the extent required by the Lease, the Licensee will obtain such financial protection and will provide proof of such financial protection to the NRC prior to commencing operations.

The indemnity agreement contained in the Lease will " cover liability claims arising out of any occurrence within the United States that causes, within or outside the United States, bodily injury, sickness, disease, death, loss of or damage to property, or loss of use of property arising out of or resulting from the radioactive, toxic, explosive, or other hazardous properties of chemical compounds containing source material or special nuclear material." Section 193( d) affords the Commission the discretion to determine the type and amount of liability insurance that is required to cover liability claims. The Commission has the discretion to conclude that no liability insurance is required in light of the DOE indemnity agreement. Therefore, the requested exemption is authorized by law.

Moreover, the requested exemption is in the public interest since it will facilitate deployment of the ACP, thereby maintaining domestic enrichment capacity using more efficient centrifuge technology. Requiring separate nuclear liability insurance would at best impose an unnecessary financial burden on the licensee and at worst preclude the construction of the ACP if commercial insurance ultimately is unavailable for facilities, such as the ACP, which are located on a DOE owned site. ANI, the only company providing commercial nuclear liability insurance in the U.S., has informed us that it has never insured a facility located on a DOE owned site. Furthermore, the separate liability insurance would not provide a commensurate benefit to the public since the DOE indemnity covers any public liability under Section 170 of the AEA up to the statutory limit of liability. The DOE indemnity agreement in the Lease adequately provides financial protection for the public for public liability as defined in the AEA. Therefore, the requested exemption is in the public interest.

The following exemption from NRC ' s Materials License Condition 15 related to financial funding as discussed in Section 1.2.2 of this license application.

In order to meet the financial qualifications requirements for construction and operation of the facility, the Licensee proposes that the license be conditioned as follows :

Construction of each additional incremental future expansion of the ACP shall not commence before funding for that increment is available or committed. Of this funding, the Licensee or affiliates must

1-80 FOR INFORMATION ONLY Lice nse Appli cati o n for the Ameri can Ce ntrifuge Plant Proposed Change April 2022

demonstrate before constructing such increment, arrangements that solely or cumulatively are sufficient to ensure funding for the particular increment's construction costs. The Licensee will make available for NRC inspection, documentation of both the budgeted costs for such phase and the source of funds available or committed to pay those costs.

Operation of additional expansion of the ACP shall not commence until the Licensee or affiliates has in place, either : (1) long term contracts lasting five years or more that provide sufficient funding for the estimated cost of operating the facility for the five year period; (2) documentation of the availability of one or more alternative sources of funds that provide sufficient funding for the estimated cost of operating the facility for five years; or (3) some combination of (1) and (2).

In general, the Licensee ' s financial qualifications to construct and operate the HALEU 16-centrifuge cascade under the Demonstrations ' Contract is demonstrated by the contract with DOE and the Selected Financial Data and detailed Consolidated

1-81 License Application for the American Centrifuge Plant Proposed Change April 2022

Financial Statements within the latest information filed with the U.S. Securities Exchange Commission by its parent Centrus.

Under the HALEU Contract, DOE agreed to reimburse the Company for up to 80 percent of its costs incurred in performing the contract. The Company's cost share is the corresponding 20 percent and any costs incurred above these amounts. Costs under the HALEU Contract include program costs, including direct labor and materials and associated indirect costs that are classified as Cost of Sales, and an allocation of corporate costs supporting the program that are classified as Selling, General, and Administrative Expenses. Services to be provided over the three-year contract include constructing and assembling centrifuges and related infrastructure in a cascade formation and production of up to 600 kgU HALEU. When estimates of remaining program costs to be incurred for such an integrated construction-type contract exceed estimates of total revenue to be earned, a provision for the remaining loss on the contract is recorded to Cost of Sales in the period the loss is determined. Our corporate costs supporting the program are recognized as expense as incurred over the duration of the contract term. The accrued loss on the contract will be adjusted over the remaining contract term based on actual results and remaining program cost projections. The Licensee requests an exemption to this condition during the three year HALEU Contract period.

The following Special Authorization has been identified in this license application:

Surface Contamination Release Levels for Unrestricted Use - Items may be released for unrestricted use if the surface contamination is less than the levels listed in Table 4.6-1.

The following exemption from the requirements in 10 CFR 95.57(c) is identified in Section 1.17.c) of the Security Plan for the Protection of Classified Matter at the American Centrifuge Plant:

NRC regulations in 10 CFR 95.57(c) require that all classification actions

( documents classified, declassified, or downgraded) to be submitted to the NRC Division of Security Operations. These may be submitted either on an "as completed "

basis or monthly. The information may be submitted either electronically by an on line system or by paper copy using NRC Form 790. Historically, the Licensee has utilized NRC Form 790 for each classification action, has compiled them monthly, and submitted them to the NRC. The Licensee must also submit a quarterly classification summary document to the DOE for all derivative classification decisions made during the previous quarter. This dual reporting is burdensome to the Derivative Classifiers and the Classification Officer arid creates a situation where the classification actions may be double counted. Accordingly, in lieu of filing its classification actions with NRC, the y will be made by the Classification Officer to the DOE at a frequency (e.g.,

annually) and in the format specified by the DOE. Lieensee will eontim1e to submit the quarterly elassifieation summary doeuments to DOE and will make them These documents will be available for NRC inspection at the facility.

1-82 FOR INFORMATION ONLY license Application for the American Centrifuge Plant Proposed Change April 2022

1.6 References

1. NUREG - 1520, Standard Review Plan for Fuel Cycle Facilities License Applications, Revision 2

2. Final Environmental Impact Statement for Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the Portsmouth, Ohio Site, DOE/EIS-0360, U. S. Department of Energy Oak Ridge Operations - Office of Environmental Management, June 2004, Website: http://web.ead.anl.gov/uranium/documents/index.cfm

3. Form 10-Q, for the quarter ended June 30, 2008

4. U.S. Bureau of the Census, 2000, " Population, Housing Units, Area, and Density: 2010 -

State - Place and (in selected states) County Subdivision 2010 Census Summary File 1",

U.S. Department of Commerce, accessed on September 4, 2019, Website :

http ://factfinder.census.gov/bkmk/tab le/1. 0/ en/DEC/ 10 _ SF 1 /GCTPH 1. ST 10/0400000US 39

5. 329-10-002, ACP Memo dated October 15, 2010, Worker and Transient Populations in and around PORTS DOE Reservation, as of October 2010, S. E. Keller

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

7. LA-3605-0003A, Addendum 1 of the ISA for the American Centrifuge Plant - HALEU Demonstration

8. United States National Oceanic and Atmospheric Administration, National Environmental Satellite Data, and Information Service, National Climactic Data Center, Asheville, NC,

Climatology of the United States, No. 81, 33 Ohio, Monthly Station Normals of Temperature, Precipitation, and Heating and Cooling Degree Days 1971-2000, February 2002, [NOAA 2003b]

9. Huff, Floyd A. and Angel, James R., Rainfall Frequency Atlas of the Midwest, Bulletin 71 (MCC Research Report 92 -03) Midwestern Climate Center, Climate Analysis Center, National Weather Service, National Oceanic and Atmospheric Administration, Illinois State Water Survey, A Division of the Illinois Department of Energy and Natural Resources [NOAA 2003c]

10. Ohio Department of Natural Resources, Website accessed September 4, 2019, http :/ /parks.ohiodnr.gov/lakewhite

11. U.S. Department of the Interior, U.S. Geological Survey, Reston, VA, and Website:

http://www.usgs.gov/index.html

12. Tetra Tech, Inc. correspondence, Methodology for the 5-mile Population Grids, November 2002

1-167 FOR INFORMATION ONLY License Application for the American Centrifuge Plant Proposed Change April 2022

13. United States Oceanic and Atmospheric Administration, National Climactic Data Center,

Asheville, NC, Waverly and Piketon Ohio Weather Stations data from 1930 through 2019, and Website: https://www.ncdc.noaa.gov/data-access/land-based-station-data

14. Regulatory Guide 1.59, Design Basis Floods for Nuclear Power Plants, Revision 2

15. ORO-EP-123, Preliminary Safety Analysis Report for the Gas Centrifuge Enrichment Plant, Portsmouth, OH, U.S. Department of Energy Oak Ridge Operations Office, July 1980

16. ORO-EP-120, Seismic Design Criteria for the Gas Centrifuge Enrichment Plant - GCEP, U.S. Department of Energy Oak Ridge Operations Office, Office of the Deputy Manager for Enrichment Expansion Projects, Oak Ridge, Tennessee, August 1980

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

18. Gas Centrifuge Enrichment Plant, Portsmouth, Ohio, Geotechnical Investigation, Law Engineering Testing Company, Project MK7502, Contract No. EY-77-C-05-5614,

April 1978

19. USEC-651, "The UF 6 Manual - Good Handling Practices for Uranium Hexafluoride,"

Revision 9, July 2006

20. ASTM Cl 052, Standard Practice for Bulk Sampling of Liquid Uranium Hexafluoride,

2014

21. Final Report of Site-Specific Seismic Study, USEC American Centrifuge, Piketon, Ohio, Prepared by Engineering Consulting Services, LLC, ECS Project No. 14-03046, January 2006

22. Annual Report on Form 10-K filing date April 14, 2020 for the fiscal year ended December 31, 2019, Website : http://investors.centrusenergy.com/financial-information/sec-filings

23. The Engineering Analysis Report for the Long-Term Management of Depleted Uranium Hexafluoride, UCRL-AR-124080, Volumes 1 and 2, Revision 2, Depleted Uranium Hexafluoride Management Program, Lawrence Livermore National Laboratory, May 1997, Website : http://web.ead.anl.gov/uraniurn/documents/index.cfm

24. ANSI Nl4.l, Nuclear Materials - Uranium Hexafluoride - Packaging for Transport, American National Standards Institute, 2012

25. Daniel, P. L., Corrosion of Metals by Gaseous Uranium Hexafluoride (U), GAT-901,

November 1983

1-168 FOR INFORMATION ONLY License Application for the American Centrifuge Plant Proposed Change April 2022

26. Construction Materials for Process Gas Applications in Gaseous Diffusion Cascades (U),

GAT-T-3000, Part 8, April 1, 1977

27. S. C. Blue and D. E. Underwood, The Corrosion of Highly Alloyed Metals by Fluorinating Gases, KY/L-1990, August 10, 1990

28. Depleted Uranium Hexafluoride Conversion Facility Documented Safety Analysis, DUF6-X-G-DSA-001, Revision 2

29. Nolen, C. and Rhoden W., Summary of ACP Seismic Design Values, EE-3100-0003, Revision 2, June 2021

30. Final Report of Subsurface Exploration and Geotechnical Engineering Evaluation, USEC American Centrifuge, Piketon, Ohio, Prepared by Engineering Consulting Services, LLC,

ECS Project No. 14-03046, March 2006

31. Geotechnical Investigation - American Centrifuge Plant, Project No. FACP-2063,

Prepared by Fugro, William, Lettis and Associates Inc., June 2010

32. Menne, Matthew J., Imke Durre, Bryant Korzeniewski, Shelley McNeal, Kristy Thomas, Xungang Yin, Steven Anthony, Ron Ray, Russell S. Vose, Byron £.Gleason, and Tamara G. Houston (2012): Global Historical Climatology Network - Daily (GHCN-Daily),

Version 3. [USC00338830]. NOAA National Climatic Data Center.

doi :10.7289N5D21 VHZ, accessed on December 3, 2019

33. Anthony Arguez, Imke Durre, Scott Applequist, Mike Squires, Russell Vose, Xungang Yin, and Rocky Bilotta (2010). NOAA's U.S. Climate Normals (1981-2010).

[USC00338830]. NOAA National Centers for Environmental Information.

DOI:10.7289/V5PN93JP, accessed on December 3, 2019

34. Keller Ohio Office of Strategic Research, Population Projections,

https://development.ohio.gov/files/research/P6090.pdf, accessed on February 5, 2020

35. Missouri Census Data Center, http://mcdc.missouri.edu/cgi bin/broker? PROGRAM=apps.capsACS.sas& SERVICE=MCDC long& debug=&latit ude=39.012&longitude=83.0014&radii=5&sitename=&dprofi le =on&eprofile=on&sprof i le=on&hprofile=on&units =+&cntypops=on&printdetail=on

36. National Center for Education Statistics, Public School Data,

https://nces.ed. gov/ccd/districtsearch, accessed on February 11, 2020

37. Kaylor, Keith, Record of Conversations with community facilities, February 11 - 18, 2020

38. LA-2605-0001, License Application for the American Centrifuge Lead Cascade Facility in Piketon, Ohio, Piketon, Ohio

1-169 FOR INFORMATION ONLY Lice nse Application for the American Centrifuge Plant Proposed Change April 2022

39. Roberts, K.A., Record of Conversations with Lauderback, B, Rockcreek Campground Owner, March 26, 2020

40. Kornegay, F. C. et al., Portsmouth Gaseous Plant Environmental Report for 1990,

ES/ESH-18/V4, Martin Marietta Energy System, Inc., Oak Ridge, Tennessee, 1991

41. Ruffner, J. A., Climates of the States, National Oceanic and Atmospheric Administration Narrative Summaries, Tables, and Maps for Each State with Overviews of State Climatologist Programs, 3rd ed., Gale Research, Detroit, Michigan, 1985

42. Johnson, R. 0., J. C. Wang, and D. W. Lee, Local Drainage Analysis of the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio, During an Extreme Storm, K/GDP/SAR-29, Martin Marietta Energy Systems, Inc., Oak Ridge, Tennessee, 1993 NOAA Storm Event Database, https://ncdc.noaa.gov, accessed on February 11, 2020

43. OHDNR (Ohio Department of Natural Resources), Water Inventory of the Scioto River Basin, Ohio Water Plan Inventory Report No. 17, Ohio Department of Natural Resources,

Division of Water, Co lumbus, Ohio, 1963

44. USGS (U.S. Geological Survey), (photo inspected). Piketon Quadrangle Ohio-Pike County 7. 5 Minute Series Topographic Map, DMA 4462 III SW-Series v852, Reston, Virginia, 1979

45. USGS National Water Information System,

https://nwis.waterdata.usgs.gov/nwis/inventory/?site no = 03234500&agency cd=USGS, accessed on February 11, 2020

46. Hydrology of the Ohio River, Appendix C, Ohio R~ver Basin Comprehensive Survey Vol.

JV, U.S. Army Engineer Division, Ohio River, Cincinnati, Ohio, 1966

47. ERDA, Final Environmental Impact Statement, Portsmouth Gaseous Diffusion Plant Site, Piketon, Ohio, ERDA-1555, 1977

48. ORSANCOM (Ohio River Valley Water Sanitation Commission), Ohio River Water Quality Fact Book, Cincinnati, Ohio, 1988

49. Rogers, J. G., et al., Portsmouth Gaseous Diffusion Plant Site Environmental Report for 1988, Martin Marietta Energy Systems, Inc., Oak Ridge, Tennessee, 1989

50. DOE, Environmental Survey Preliminary Report, Portsmouth Uranium Enrichment Complex, Piketon, Ohio, DOE/EH/OEV-04P, Office of Environmental Audit,

Washington, D.C., 1987

51. USGS, Water Resourc es Data, Ohio, Water Year 1991, Water-Data Report OH-91-1,

prepared in cooperation with the State of Ohio and other agencies, Columbus, Ohio, 19926

1-170 FOR INFORMATION ONLY License Application for the American Centrifuge Plant Proposed Change April 2022

52. Rehme, J., Planning Division, Special Studies Branch, U.S. Army Corps of Engineers, Huntington, West Virginia, personal communication to R.O. Johnson, Oak Ridge National Laboratory, Oak Ridge, Tennessee, December 5, 1990

53. Wang, J.C., R. 0. Johnson, and D. W. Lee, Extreme Flood Estimates Along the Scioto River Adjacent to the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio, K/GDP/SAR-6, Martin Marietta Energy Systems, Inc., Oak Ridge, Tennessee, 1992

54. Johnson, R. 0., J.C. Wang, and D. W. Lee., Local Drainage Analysis of the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio, During an Extreme Storm, K/GDP/SAR-29, Martin Marietta Energy Systems, Inc., Oak Ridge, Tennessee, 1993

55. Linsley, R. K. Jr., M.A. Kohler, and J. L. H. Paulhus, Hydrology for Engineers,

McGraw-Hill, New York, 1982

56. LETC (Law Engineering Testing Co.), Final Report : Gas Centrifuge Enrichment Plant,

Portsmouth, Ohio, Geotechnical Investigation, Law Engineering Testing Co., Marietta,

Georgia, 1978

57. Lee, R. R, Portsmouth Gaseous Diffusion Plant Safety Analysis Report, Section 3.5. 1, Regional Subsurface Hydrology, Oak Ridge National Laboratory, Oak Ridge,

Tennessee, 1991

58. Kornegay, F. C., et al., Portsmouth Gaseous Diffusion Plant Environmental Report for 1989, POEF-2025, MMES, ORNL, and PORTS, 1990

59. LETC (Law Engineering Testing Co.), Soil and Ground Water Investigations for the GCEP Landfill Pathways Analysis-Final Report, Denver, Colorado, 1982

60. Norris, S. E., Aquifer Tests and Well Field Performance, Scioto River Valley, Ohio, Part I Groundwater, 21 (3), 1983

61. USGS, USGS Groundwater Site Inventory Database for Pike County, Ohio, 1990 (May 17)

62. Walker, A., Ground-water Res ources of Jackson and Vinton Counties, ODNR, Division of Water, 1985

63. Geraghty & Miller, Site-Wide Ground-Water Flow Model of the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio, Dublin, Ohio, 1989

64. Geraghty & Miller, Ground-Water Quality Assessment of Four RCRA Un its, Port s mouth Gaseous Diffusion Plant, Piketon, Ohio, Dublin, Ohio, 1989

1-171 License Application for the American Centrifuge Plant Proposed Change April 2022

65. Geraghty & Mi ll er, Analysis of Long-Term Hydrologic Budget for the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio, October 1988-September 1989, Dublin, Ohio, 1990

66. Geraghty & Miller, Quadrant II, RFI Draft Final Report, for the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio, Dublin, Ohio, 1992

67. ERCE, Portsmouth Gaseous Diffusion Plant Final Safety Analysis Report, Section 3.6, Geology and Seismicity, 1990

68. Ohio Geological Survey, Recent Ohio/ Regional Earthquakes, http :// geos urv ey. o hi odnr. gov/ earthquakes-ah i ose is/ q uakes -fe I t - i n-o hi o/recen t -ohi o regi onal-q uakes

69. FBP-ER-RCRA-WD-RPT-0288, Portsmouth Gaseous Diffusion Plant Annual Site Environmental Report - 2017

70. Appendix 1 Lease Agreement between the US. Department of Energy and United States Enrichment Corporation for the Gas Centrifuge Enrichment Plant (GCEP Lease Agreement), Amendment dated May 31, 2019

71. Regulatory Guide 3.71, Nuclear Criticality Safety Standards for Nuclear Materials Outside Reactor Cores, Revision 3

72. ASCE 7-2002, Minimum Design Loads for Buildings and Other Structures

73. K -DA -603, Revision 2, Gas Centrifuge Enrichment Plant General Design Criteria,

DOE, February 1982

74. SP-3605-0041, Security Plan for the Protection of Classified Matter at the American Centrifuge Plant

75. SP-3605-0042, Security Plan for the Physical Protection of Special Nuclear Material at the American Centrifuge Plant

1-172 Lice nse Application for the Ameri can Ce ntrifuge Plant Proposed Change April 202 2

2.1.2.4 Production Support Manager

The Production Support Manager reports to the Enrichment Operations Plant Manager. This manager is responsible for fire safety ; emergency management; radiation protection (RP), which includes chemical process safety, health physics, industrial hygiene, Industrial Safety and environmental/waste management; security ; and training and procedures, which includes records I management and document control. During commercial operations, this manager will also be responsible for the Customer Order Management program.

The Production Support Manager has, as a minimum, a bachelor ' s degree in engineering or the physical sciences or equivalent technical experience, and four years of nuc lear experience.

2.1.2.4.1 Fire Safety / Emergency Management Manager

The Fire Safety /Emergency Management Manager reports to the Production Support Manager. This manager is responsible for the Fire Safety program; fire protection systems and services (i.e., including emergency and fire response, fire inspection, fire testing services,

interpretation and application of applicable fire codes and standards) ; and emergency management.

The Fire Safety/Emergency Management Manager has, as a minimum, a bachelor ' s degree or equivalent technical experience, four years of fire protection experience, and six months of nuclear experience.

2.1.2.4.2 Radiation Protection Manager/ Supervisor

The Radiation Protection Manager (RPM) /Supervisor reports to the Production Support Manager. The RPM/Supervisor is responsible for the RP Program and administration on a day -to day basis, including providing guidance and direction for establishment and imp lementation of the RP Program and has the authority to deny access to radiological areas by personnel who do not adhere to radiological protection requirements. The RPM/Supervisor also has oversight of radiological protection procedures in order to maintain the integrity of the RP Program. The RPM/Supervisor has direct access to the Enrichment Operations Plant Manager and the Senior Vice President for RP matters.

This position also has programmatic responsibilities for chemical process safety, health physics, industrial hygiene, and environmental/waste management activities.

The RPM/Supervisor has, as a minimum, a bachelor ' s degree in engineering, health physics,

RP, or the physical sciences or equivalent technical experience, and four years experience in RP,,

including six months of prior Radiation Protection Manager/Supervisor experience at a nuclear facility.

2.1.2.4.3 Seeurity Mttnttger Section Reserved for Future Use

The Seeurity Manager reports to the Produetion Support ManagerEflfiehment Op erations Plant Mana ger. This manager is responsible for the strategie direction of the site security operations

2-8 License Application for the American Centrifuge Plant Proposed Change April 2022

and programs for safeguards and security serYices. The Security Manager has direct access to the Enrichment Operations Plant Manager and Senior Vice President for security matters.

The Security Manager has, as a minimum, a bachelor ' s degree or equiYalent technical eKperience, and four years security eKperience.

2.1.2.4.4 Training and Procedures Manager

The Training and Procedures Manager reports to the Production Support Manager. This manager is responsible for preparation, presentation, and documentation of employee orientations; and for technical and qualification training program development and implementation. This manager is also responsible for the development and implementation of the Procedures program and the programmatic oversight of the Records Management and Document Control (RMDC) programs.

The Training and Procedures Manager has, as a minimum, a bachelor ' s degree in engineering or the physical sciences or equivalent technica l experience, and four years of nuclear experience.

2.1.2.4.4.1 Records Management and Document Control Manager

The RMDC Manager reports to the Training and Procedures Manager. This manager is responsible for the RMDC programs.

The RMDC Manager has, as a minimum, a bachelor's degree in engineering or the physical sciences or equivalent technical experience, and four years of nuclear experience.

2.1.3 Director, Quality Assurance

The Director, QA reports to the Senior Vice President. Th is Director is a member of the senior management team of the American Centrifuge Project and has been designated the responsibility for ensuring that the project achieves its quality targets and meets its regulatory driven quality commitments in a safe manner. This Director is responsible for QA for the operations,

including future decommissioning as applicable, at the Piketon, Ohio and Oak Ridge, Tennessee faci l ities; for vendors and suppliers; and for construction and manufacturing activities, both for interna l and external customers.

This Director advises and provides guidance to the Senior Vice President on matters of safety and QA. The Piketon QA Manager reports to the Director, QA and are independent from production, plant operating cost, and production schedule concerns to ensure appropriate independent oversight of project activities.

The Director, QA has, as a minimum, a bachelor 's degree in engineering or the physical sciences or equivalent technical experience, and six years of nuclear experience, and six years of management experience which may be concurrent with the nuclear experience.

2-9 Licen se Application for th e American Ce ntrifuge Plant Proposed Change April 2022

The Piketon System Engineering Manager has, as a mm1mum, a bachelor 's degree in engineering or the physical sciences or equivalent technical experience, and four years of nuclear experience.

2.1.6.1.3 Piketon Design Engineering Manager [commercial operations only]

The Piketon Design Engineering Manager reports to the Piketon Engineering Manager. This manager has responsibility for the design engineering activities in support of plant operations, which includes providing engineering support and review of the design and modifications of IROFS.

The Piketon Design Engineering Manager has, as a minimum, a bachelor ' s degree in engineering or the physical sciences or equivalent technical experience, and four years of nuclear experience.

2.1. 7 Director, Corporate Security

The Director, Corporate Security reports to the Senior Vice President, Field Services, and is independent from production, plant operating costs, and production schedule concerns. This director has authority to direct actions necessary for the safeguarding of classified information within the enterprise and to achieve or maintain compliance with applicable regulatory requirements. The Director, Corporate Security oversees the work of each of the site Security Managers, Classification Officer, and Information System Security Manager.

The Director, Corporate Security is appointed as the Senior Management Official (SMO) for the protection of the Licensee ' s classified technology regardless of location within the enterprise.

This director is also responsible for the establishing the entity ' s security policy and strategy for implementation throughout the enterprise.

The Director, Corporate Security has, as a minimum, a bachelor ' s degree or equivalent technical experience, and six years security and safeguards experience.

2.1.7.1 Security Manager

The Security Manager reports to the Director, Corporate Security. This manager is responsible for the strategic direction of the site security operations and programs for safeguards and security services. The Security Manager has direct access to the Enrichment Operations Plant Manager and Senior Vice President for security matters. The Security Manager has matrixed responsibilities directly to the Enrichment Operations Plant Manager in support of secured operations at the Piketon ACP facilities.

The Security Manager has, as a minimum, a* bachelor ' s degree or equivalent technical experience, and four years security experience.

2-12 Lice nse Application for th e Ameri can Ce ntrifuge Plant Proposed Change April 2022

2.1.8 Plant Shift Superintendent (Contractor)

The Plant Shift Superintendent (PSS) reports to the U.S. Department of Energy (DOE) reservation contractor management and provides support through approved reverse -work authorizations with the DOE. The PSS is responsible for accumulation and dissemination of information regarding site activities, serving as or designating an Incident Commander during emergencies, and making notification of events. The PSS has the authority and re sponsibility to make decisions as necessary to ensure safe site operations, including stopping work. The PSS provides a centralized point for incident identification, screening, and reporting. The PSS ' s responsibilities are consistent with those exercised at the gaseous diffusion plant for emergency response.

The PSS has, as a minimum, a bachelor ' s degree in engineering or the physical sciences or equivalent technical experience and four years experience at a gaseous diffusion plant, or a high school diploma plus 12 years experience at a gaseous diffusion plant.

2.1.82 Shift Crew Composition [only during operational phases with licensed material]

The minimum operating shift crew consists of an Operations Shift Supervisor, a Radiation Protection, and an Industrial Hygiene technician, and one operations technician per process building.

Other personnel, such as NCS, will be available on an as needed basis.

2-13 License Application for the American Centrifug e Plant Proposed C ha nge Apri l 2022

Senior Vice Prelldent, Field Operation Director, Qua lity Direc tor, En gineering, Directo r, Nudear Director, En gineerin g Assurance Procurem e nt, and ---- ---,,.----~---- Safet y ( Des ig n Auth o rity )

Co ns t ruct io n Enrld!ment Operation PbintMa..,.,

Piketon Quality...... -----..--- Nuclea r Crit ic.a li ty Piketo n En gineerin g Ass urance *----------------------1 Safe ty ( De leg a t e d De si g n Au t ho rity )

I '--------' I

------ -- -- - --------- - J I

-- - - - - - - - - - - - - - - - - - - - Sy stems Eng ineer ing I

I

Design Eng inee ring

Regul a t o ry Bus iness Operat ion s Pro duction Se rv ices Sup po rt Confi sur at ion Cascad e / Re cycl e Manageme nt Nuclear - - - - { Procur e m e nt a nd Assem bly Fire Safety / Em e fl!en cy Mate rials Operat ions Sh ift Man a ge ment Control a nd Superv isors Accou n tab ility Radia tion Pro tection Packa ging, Manager/ Superv iso r He alth Phys ics and Tra nsportation, I and Materia ls I Indust ria l Hyg ien e Man age m en t ~- -

' I Secur ity I Env ironm e nta l / W a ste BO P Process I Management I

Area Manage r I Training a nd Procedures BOP Oper at io ns Maintenance Sh ift Su perv isor Shift Superv iso rs Records Ma nasement /

Document Control Figure Being Deleted

2-14 License Application for the Am er ican Centrifuge Plant Pro posed C ha nge A pril 2022

SeNOtVia President. Field Ope~*-

Dir-actor, Qua lity Director, En1 inee rin1, Director, En1inurin1 Procureme nt, *nd Oir.ctor, Nucia r Oir.cto r, Corponta Anuranc* Construction Enrk -hment Ope:r.tions S*fwty I Dos i1n Authority I Security

Plant Man.ace, Piketon Qu *lity - - - - - - - - - - _ I ___ -------~------.----Nuclear Cri *u lity Piketon En 1in eerinr A11unnce S.fo ty ( O.l*1*t*d Du i1n Authority )

- -- ---- ------------~ Synom, En1inHrin1

Dtsicn En cinffrinc

Reeul1tory Business Oper ations Pro duction Services Support Confiau ratio n Cucade / Re::yc M Manage-m*nt Nuclur lnt e inted 1ndAnembty Fire ~fety / Emercency Mnerlllls --*f Proc u romont Systems Test / Ope-r ations Shift Man*J*m* nt Contr ol and Start -u p Supervisors Acco un t.llbility P1 ck11 in1, Radiadon Pr otection Tn1nsp ort1tion, M1n*1*r / Supervisor Hu fth Physics and

ndMUe riills Industrial Hyl1&f1e

M1 n1c emMt Tninin g and Proced urei Emriro nm*nU I / Wu te BOP Proces.s M anase ment Aru M1na1er Re cords M1n11*m*nt /

BOP Operations M ainte n 11n c* ln dustri1I Docum*nt Co ntrol Shift Supuvisor Shift: Supe rvisors S.foty

Figure 2.1-1 American Centrifuge Organization Chart

2-15 NR-3605-0003

Quality Assurance Program Description

for the American Centrifuge Plant in Piketon, Ohio

Proposed Change

Docket No. 70- 7004 April 2022 Docket No. 70- 7003

Information Contain ed Within Does Not Contain Ex port C ontrolled Information Reviewing Official : # 1038

Date: 04/05 /2022 FOR INFORMATION ONLY Quality Assurance Program Description for the American Centrifuge Plant Proposed Change April 2022

TABLE OF CONTENTS

1.0 INTRODUCTION

................................................................................................................. 1

2.0 QUALITY ASSURANCE PROGRAM.............................................................................. 5

3.0 DESIGN CONTROL............................................................................................................ 7

4.0 PROCUREMENT DOCUMENT CONTROL................................................................... 8

5.0 INSTRUCTIONS, PROCEDURES, AND DRAWINGS................................................. 9

6.0 DOCUMENT CONTROL................................................................................................. 10

7.0 CONTROL OF PURCHASED ITEMS AND SERVICES............................................. 10

8.0 IDENTIFICATION AND CONTROL OF ITEMS......................................................... 16

9.0 CONTROL OF PROCESSES........................................................................................... 17

10.0 INSPECTION...................................................................................................................... 17

11.0 TEST CONTROL............................................................................................................... 18

12.0 CONTROL OF MEASURING AND TEST EQUIPMENT........................................... 19

13.0 HANDLING, STORAGE, AND SHIPPING.................................................................... 20

14.0 INSPECTION, TEST, AND OPERATING STATUS..................................................... 21

15.0 CONTROL OF NONCONFORMING ITEMS............................................................... 21

16.0 CORRECTIVE ACTION.................................................................................................. 22

17.0 QUALITY ASSURANCE RECORDS.............................................................................. 22

18.0 AUDITS............................................................................................................................... 23

19.0 PROVISIONS FOR CHANGES....................................................................................... 25

20.0 REFERENCES

.................................................................................................................... 26

Ill Quality Assurance Program Description for the American Centrifuge Plant Proposed C ha nge April 2022

FIGURES

Figure 1.1 1 Amerieen Centrifuge Orgen~etionel Chert..................................................... 27

iv Quality Assurance Program Description for the American Centrifuge Plant Proposed Change April 2022

1.0 INTRODUCTION

The Quality Assurance Program Description (QAPD) described herein applies to the design, procurement, refurbishment/construction, manufacturing, testing, start-up, operation, inspection, maintenance, modification, and future decommissioning of the American Centrifuge Lead Cascade Facility (Lead Cascade) and the American Centrifuge Plant (ACP) and meets 10 Code of Federal Regulations (CFR) 70.64 (a)(l).

The Lead Cascade and ACP are located in Piketon, Ohio. The QAPD is applied using a graded approach as described in Section 2.0 of this QAPD.

1.1 Organization

The Licensee maintains overall responsibility for design, procurement, refurbishment/construction, manufacturing, testing, start-up, operation, maintenance, and future decommissioning of the Lead Cascade and the ACP.

Figure 2.1-1 of the License Application 1.1 1 of this plan shows the American Centrifuge organization. The organization is managed by Licensee staff and operated by a combination of Licensee personnel, contractor, supplier-provided augmented staff, and consultants where appropriate.

1.2 Responsibilities

The Senior Vice President, Field Operations reports to the President and Chief Executive Officer, and has overall responsibility for the safe operation and the deployment of American Centrifuge Project(s), including facility design; process equipment procurement; machine design, testing, and manufacturing; enrichment plant refurbishment/construction; testing of facilities; and tum-over to operations. The Senior Vice President provides strategic leadership and direction for the enrichment operations organization, including the functions of operations; maintenance; project support; engineering; system(s) testing; transportation; procurement; materials handling and storage; industrial, radiological, and nuclear safety; conduct of operations; and future decommissioning.

The Senior Vice President is responsible for the quality assurance (QA) program and for determining the status, adequacy, and effectiveness of the QAPD. The Senior Vice President has designated the Director, QA the responsibility for ensuring that the project achieves its quality targets and meets its regulatory driven quality commitments. This director is responsible for QA for the operations, including future decommissioning as applicable, at the Piketon, Ohio and Oak Ridge, Tennessee facilities; for vendors and suppliers; and for construction and manufacturing activities, both for internal and external customers.

FOR INFORMATION ONLY Quali ty As s uran ce Pro g r a m Descripti on for th e Am eri can Ce ntrifuge Plant Propo sed C han g e April 2022

The Senior Vice President has designated the Director, Engineering, Procurement, and Construction, during the refurbishment/construction of the American Centrifuge facilities, the responsibi l ities for providing technical administration and direction to the Engineering, Procurement, and Construction contractor(s) ; providing the primary interface with the refurbishment/construction contractor(s) who are building out the licensed facilities, and managing the execution of the Balance of Plant work which the Licensee self performs for the deployment of the ACP.

The Senior Vice President has designated the Enrichment Operations Plant Manager the responsibility for the day -to - day safe operation and associated support activities for the American Centrifuge Project(s). The Enrichment Operations Plant Manager is responsible for the American Centrifuge Program and overall responsibility for implementation of the QAPD.

The QAPD is binding on all Licensee and contractor personnel involved with the American Centrifuge Project(s), as identified in contractua l documents.

The Director, Nuclear Safety reports to the Senior Vice President and is matrixed directly to the Enrichment Operations Plant Manager. This director is responsible for developing and implementing the nuclear safety program, including technical oversight of nuclear safety, including nuclear criticality safety and maintenance of the Integrated Safety Analysis, safety analysis training, review of procedures involving fissile material operations, and assessments of program implementation.

The Piketon E ngineering Manager reports to the Director, E ngineering and is the delegated design authority for Piketon operations and is matrixed directly to the Enrichment Operation s Plant Manager. This manager is responsible for Piketon engineering activities in s upport o f operations and future decommissioning, which includes maintaining the configuration management program ; systems and design engineering; review of design and modifications of items relied on for safety (IROFS) ; and supporting procurement services. This manager is also responsible for development of the Integrated Systems and Test Plans (ISTPs) and acceptance test coordination, including test control ; and approving disposition of nonconforming items when dispositioned as "repair" or " use - as-is."

The Operations Manager reports to the Enrichment Operations Plant Manager and is responsible for fissile material operations, centrifuge operations, and shift operations. This manager is responsible for directing activities of the Cascade/ Recycle and Assembly Operations Shift Supervisors in operation of the cascade, feed and withdrawal, and gas test, as well as the Maintenance Work Center Supervisor for maintenance and operations of the plant equipment,

Balance of Plant utilities processes, and facilities. This includes centrifuge assembly, drying,

transportation, and installation in the cascade ; safe operation of the uranium hexafluoride (UF 6) processes in accordance with approved procedures; proper receipt, storage, handling, and onsite transportation of UF 6; execution of the ISTPs, initial start-up, and operation of the centrifuges,

equipment, and s upport s ystems. Other activities include select repair of centrifuges ;

maintenance ; classified equipment control ; accountable property inventory, segregation, and disposition ; contractor support ; int e grated planning and scheduling ; caretaker activities; materials management support ; and future decommissioning and disposal activities, ensuring activities are performed in accordance w ith approved programs, processes, and procedures.

2 Quality Assuranc e Pro g ram Description for the Ameri can Ce ntrifuge Plant Proposed Change April 2022

The Integrated Systems Test/Start-up Manager reports to the Operations Manager and is responsible for assisting in the development and execution of the ISTPs which demonstrate the proper operation of completed systems to ensure that the systems meet their intended design functions. This manager is also responsible for the acceptance of turnover from Engineering,

Procurement, and Construction or from turnover from contractors/vendors to the Licensee; initial acceptance testing; and initial start-up of equipment and support systems.

Maintenance Work Center Supervisor reports to the Operations Manager. The Maintenance Work Center Supervisor is responsible for directing activities of the Balance of Plant Operations Shift Supervisors and of the Maintenance Shift Supervisors in the performance of preventive, predictive, and corrective maintenance and to provide support services on facilities and equipment within approved programs, processes, 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.

The Production Support Manager reports to the Enrichment Operations Plant Manager and is responsible for fire safety ; emergency management ; security; radiation protection, which includes chemical process safety, health physics, industrial hygiene, and environmental/waste management ; and training and procedures, which includes records management/document control.

The Training and Procedures Manager reports to the Production Support Manager and is responsible for development and implementation of programs for indoctrination and training identified in Section 2.0 of this QAPD. Also, this manager is responsible for the program for development, review, approval, and issuance of procedures and the records management and document control program.

The Business Services Manager reports to the Enrichment Operations Plant Manager and is responsible for procurement ; packaging, transportation, and materials management; finance ;

and information technology in support of the American Centrifuge Project( s).

The Procurement Manager reports to the Director, Procurement and Contracts and is responsible for providing support services to the Business Services Manager for procurement and providing procurement material control services (including supplier qualification coordination,

purchasing, contracting). This manager is also responsible for supply strategy and development of qualified long-lead-time and complex-system suppliers.

The Regulatory Manager reports to the Enrichment Operations Plant Manager and is responsible for regulatory oversight functions and commitment management. The Regulatory Manager, as delegated by the Senior Vice President and E nrichment Operations Plant Manager,

maintain s the day -to-day interface with U.S. Nuclear R e gulatory Commission (NRC) representatives on matters of regulatory compliance. This manager has re sponsibility for maintaining the plant change process and ensuring the plant change reporting requirements are met. The Regulatory Manager is also responsible for implementing the Corrective Action

3 Quality Assurance Program Description for th e American Ce ntrifug e Plant Proposed Change April 2022

20.0 REFERENCES

1. 10 CFR 70.4, Definitions

2. 10 CFR 70.72, Facility Changes and Change Process

3. American Society of Mechanical Engineers (ASME) standard NQA-1, Quality Assurance Requirements for Nuclear Facility Applications, 2008 edition with the NQA-la-2009 addenda

4. SNT-TC-1 A, The American Society for Nondes tructive Testing Recommended Practice, June 1980 Edition

5. 10 CFR Part 21, Reporting of Defects and Noncompliance

L CMP-3603-0001, Graded Approach to Configuration Management and Quality Assurance

6-:7. LA-2605-0001, License Application for the American Centrifuge Lead Cascade Facility

+.-8. LA-3605-0001, License Application for the American Centrifuge Plant

26

L Quality Assurance Program Description for the American Centrifuge Plant Proposed Change Apri l 2022

Senior Vice President, Field Operat ions

Director, Quality Director, Engineering, Director, Engineering Procurement, and Director, Nuclear Assurance Construction -------.,----~-------.. Safety ( Design Authority )

Enrichment Operations Plant Manager Piketo n Quality -----------* Nuclear Criticality Piketon Engineering Assurance Safety ( Delegated Design Authority )

Systems Engineering

Design Engineering

Production Support Configuration

Cascade / Recycle Management Integrated and Assembly Fire Safety/ Emergency Materials Systems Test/ Operations Shift Management Control and Start-up Supervisors Accountability Radiation Protection Packaging, Transportation, I Manager/ Supervisor Health Physics and I Industrial Hygiene and Materials L __

Management I Secu rity Env ironmental / Waste BOP Process Management Area Manager Training and Procedure s BOP Operations Maintenance Shift Supervisor Shift Supervisors Records Management/

Document Control

FiguFe 1.1 1 AmeFieen CentFifuge OFgenimtienel Chert

27

v t e Letter Sequence Request
EPID:L-2022-SPR-0007, American Centrifuge Operating, LLC, Request for Approval: Proposed Changes to Security Plans (Open)
Initiation Request Acceptance... Administration Questions Answers Results Approval... Other: ML22346A160
MONTHYEAR2022-12-13 [Table View]

ML22102A092

Text

Dear Samuel Lee,

Enclosures:

SUMMARY

SUMMARY

1.0 INTRODUCTION

20.0 REFERENCES

1.0 INTRODUCTION

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