ML22123A143

License Amendment Request for American Centrifuge Operating, LLCs License Application and Supporting Documents for the American Centrifuge Plant

ML22123A143
Person / Time
Site:	07007004
Issue date:	04/28/2022
From:	Karen Fitch American Centrifuge Operating
To:	John Lubinski Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML22123A157	List: ML22123A143
References
ACO 22-0042
Download: ML22123A143 (48)

Text

CUI// SP-EXPT / SP-SRI/ PROPIN // NOFORN Security-Related Information - Withhold Under 10 CFR 2.390 Export Controlled Information, Official Use Only, and Proprietary Information

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• Fueling the Future

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April 28, 2022 ACO 22-0042

ATTN: Document Control Desk Mr. John W. Lubinski, Director Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

American Centrifuge Plant; Docket Number 70-7004; License Number SNM-2011

License Amendment Request for American Centrifuge Operating, LLC's License Application and Supporting Documents for the American Centrifuge Plant

INFORMATION TRANSMITTED HEREWITH IS PROTECTED FROM PUBLIC DISCLOSURE AS CONFIDENTIAL COMMERCIAL OR FINANCIAL INFORMATION AND/OR TRADE SECRETS PURSUANT TO 10 CFR 2.390 AND 9.17(a)(4)

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

Dear Mr. Lubinski :

The purpose of this letter is to request in accordance with 10 Code of Federal Regulations (CFR) 70.34 and 70.65 the U.S. Nuclear Regulatory Commission (NRC) review and approve the proposed amendment for American Centrifuge Operating, LLC's (ACO) License Application for the American Centrifuge Plant (ACP) in Piketon, Ohio (Materials License SNM-2011).

ACO and the U.S. Department of Energy (DOE) entered into the HALEU Demonstration Contract awarded May 31, 2019, and definitized on October 31, 2019. Work under the contract included licensing and construction of the cascade at the ACP in Piketon, Ohio. The HALEU Demonstration Program commenced on June 1, 2019.

The demonstration of HALEU production was on schedule to produce between 200 kg and 600 kg of HALEU using 16 ACl00M centrifuges by June 1, 2022, at the Piketon, Ohio, facility owned by

Jf-J~5 2 D Document/matter transmitted contains CUI// SP-EXPT /SP-SRI/ PROPIN // NOFORN Security-Related Information - Withhold Under 10 CFR 2.390 ('lJJJ55 Export Controlled Information, Official Use Only, and Proprietary Information When separated from Enclosures 3 and 6, this cover letter and Enclosures 1, 2, 4, 5, and 7 are uncontrolled.

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

Mr. John W. Lubinski April 28, 2022 ACO 22-0042, Page 2

DOE. However, the demonstration was affected by COVID-19 related supply chain cost and schedule issues near the completion of the work. The HALED Demonstration contract was initially planned to conclude on May 31, 2022; however, the contract is in the process of being adjusted to allow for a competition for the continuation of the demonstration program. These adjustments were necessary to acknowledge COVID-19 supply chain disruptions and out of contract scope requirements for a Category 2 Special Nuclear Material storage area. Therefore, DOE is extending the current HALED contract with ACO to allow for continuation under revised milestones to bridge the gap between the current activities and the DOE' s planned new contract that will be a competitive award to complete the program to demonstrate the production ofHALEU.

provides a detailed description,justification, and ACO's significance determination for the proposed changes. Enclosure 2 provides the public proposed changes to LA-3605-0001, License Application for the American Centrifuge Plant, and LA-3605-0002, Environmental Report for the American Centrifuge Plant. Enclosure 3 provides the withheld proposed changes to NR-3605..:0005, Fundamental Nuclear Material Control Plan for the American Centrifuge Plant. Enclosure 4 provides corresponding proposed changes to NRC' s Materials License SNM-2011 for the American Centrifuge Plant. Proposed changes from the previously NRC-approved documents are noted with revision bars in the right-hand margin. Based upon the 10 CFR 70.32 and 70.72 evaluations, not all proposed changes depicted warrant the NRC's review and approval; however, are provided for completeness to assist in the review efforts.

Additionally, to support this extension request, the following new references are provided:

• Enclosure 5 provides HALED Demonstration Contract Number 89303519CNE000005, Modification #P000 19 for the HALEU Demonstration Program.

• Enclosure 6 provides Amendment 2 to the Appendix I Lease Agreement Between the US.

Department of Energy and United States Enrichment Corporation for the Gas Centrifuge Enrichment Plant.

contains Proprietary and Security-Related Information. In accordance with the guidance provided by the DOE, Enclosure 6 contains Official Use Only information. Therefore, ACO requests these enclosures be withheld from public disclosure pursuant to 10 CFR 2.390(d)(l). An affidavit required by 10 CFR 2.390(b )(1 )(ii) is provided as Enclosure 7 of this letter. Additionally, has been determined, in accordance with the guidance provided by the DOE, to contain Export Controlled Information and must be protected from disclosure per the requirements of 10 CFR Part 810.

After the NRC staff has had an opportunity to review the enclosures, ACO is available to support a discussion with the NRC to address questions or clarify issues. ACO respectfully requests NRC complete their review and final approval on or before May 31, 2022, to support the six-month extension of the current DOE HALED Demonstration contract.

Document/matter transmitted contains CUI// SP-EXPT /SP-SRI/ PRO PIN// NOFORN Security-Related Information - Withhold Under 10 CFR 2.390 Export Controlled Information, Official Use Only, and Proprietary Information When separated from Enclosures 3 and 6, this cover letter and Enclosures 1, 2, 4, 5, and 7 are uncontrolled.

CUI// SP-EXPT / SP-SRI I PROPIN // NOFORN Security-Related Information - Withhold Under 10 CFR l.390 Export Controlled Information, Official Use Only, and Proprietary Information

Mr. John W. Lubinski April 28, 2022 ACO 22-0042, Page 3

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

Sincerely,

4~/j'fd

Kelly L. Fitch Regulatory Manager

Enclosures:

• As stated*

cc (without enclosures, unless otherwise noted):

Y. Faraz, NRC HQ (Enclosures)

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

J. Tobin, NRC HQ (Enclosures)

T. Vukovinsky, NRC Region II

Document/matter transmitted contains CUI// SP-EXPT /SP-SRI/ PROPIN // NOFORN Security-Related Information - Withhold Under 10 CFR l.390 Export Controlled Information, Official Use Only, and Proprietary Information When separated from Enclosures 3 and 6, this cover letter and Enclosures 1, 2, 4, 5, and 7 are uncontrolled.

Enclosure 7 of ACO 22-0042

Affidavit

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

Date: 04/27/2022 AFFIDAVIT OF LARRY B. CUTLIP SUPPORTING APPLICATION TO WITHHOLD FROM PUBLIC DISCLOSURE CERTAIN INFORMATION PROVIDED TO NRC IN LETTER ACO 22-0042

I, Larry B. Cutlip, of American Centrifuge Operating, LLC (ACO), having been duly sworn,

do herby affirm and state:

1. I have been authorized by ACO to (a) review the information owned by ACO which is

referenced herein relating to ACO's License Amendment Request for the American Centrifuge

Plant (ACP) (NRC Materials License SNM-2011) as the described in letter ACO 22-0042, which

ACO *seeks to have withheld from public disclosure pursuant to section 14 7 of the Atomic

Energy Act (AEA), as amended, 42 U.S.C. § 2167, and 10 CFR2.390(a)(4), and 9.l 7(a)(4), and

(b) apply for the withholding of such information from public disclosure by the Nuclear

Regulatory Commission (NRC) on behalf of ACO.

2. Consistent with the provisions of 10 CFR 2.390(b)(4) of the Commission's regulations, the

following is furnished for consideration by the Commission in determining whether the

information sought to be withheld from public disclosure should be withheld.

1. Th~ information sought to be withheld from public disclosure is owned and has been held in

confidence by ACO.

I

n. The information is of a type customarily held in confidence by ACO and not customarily

disclosed to the public. ACO has a rational basis for determining the types of information

customarily held in confidence by it and, in that connection, utilizes a system to determine

when and whether to hold certain types of information in confidence. The application of that

system and the substance of that system constitute ACO policy and provide the rational basis

required. Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential

competitive advantage, as follows:

a) The information reveals the distinguishing aspects of a process ( or component, structure,

tool, method, etc.) where presentation of its use by any of ACO's competitors without

license from ACO constitutes a competitive economic advantage over other companies.

b) It consists of supporting data, including test data, relative to a process ( or component,

structure, tool, method, etc.), the application of which data secures a competitive

economic advantage ( e.g., by optimization or improved marketability).

c) Its use by a competitor would reduce their expenditure of resources or improve their

competitive position in the design, manufacture, shipment, installation, assurance of

quality, or licensing a similar product.

d) It reveals cost or price information, production capacities, budget levels, or commercial

strategies of ACO, its customers or suppliers.

e) It reveals aspects of past, present, or future ACO or customer funded development plans

and programs of potential commercial value to ACO.

f) It contains patentable ideas, for which patent protection may be desirable.

g) It reveals information concerning the terms and conditions, work performed,

administration, performance under or extension of contracts with its customers or

suppliers.

iii. There are sound policy reasons behind the ACO system which include the following:

a) The use of such information by ACO gives ACO a competitive advantage over its

competitors. It is, therefore, withheld from disclosure to protect the ACO competitive

position.

b) It is information, which is marketable in many ways. The extent to which such

information is available to competitors diminishes ACO's ability to sell products and

services involving the use of the information.

c) Use by our competitors would put ACO at a competitive disadvantage by reducing their

expenditure of resources at ACO expense.

d) Each component of proprietary information pertinent to a particular competitive

advantage is potentially as valuable as the total competitive advantage. If competitors

acquire components or proprietary information, any one component may be the key to

the entire puzzle, thereby depriving ACO of a competitive advantage.

e) Unrestricted disclosure would jeopardize the position of prominence of ACO in the

world market, and thereby give a market advantage to the competition of those countries.

f) The ACO capacity to invest corporate assets in research and development depends upon

the success in obtaining and maintaining a competitive advantage.

iv. The information is being transmitted to the Commission in confidence and, under the

provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

v. The information sought to be protected is not available in public sources or available

information has not been previously employed in the same original manner or method to the

best of our knowledge and belief.

3. The proprietary information sought to be withheld is contained within Enclosure 3 ofletter ACO

20-0013. Enclosure 3 provides proposed changes to NR-3605-0005, Fundamental Nuclear

Material Control Plan for the American Centrifuge Plant. This enclosure provides details of the

Nuclear Material Control and Accountability (NMC&A) Program needed for the deployment of

ACO's high-assay, low-enriched uranium (HALEU) Demonstration Program and American

Centrifuge Plant; therefore, determined to be proprietary.

Public disclosure of this proprietary information is likely to cause substantial harm to the

competitive position of ACO because it may enhancethe ability of competitors to position and

provide similar products. Further, this information has substantial commercial value as follows:

• The development of the information described in part is the result of applying many

hundreds of person-hours and the expenditure of thousands of dollars on design and analysis

activities to achieve the information that is sought to be withheld; and

• In order for a competitor of ACO to duplicate the information sought to be withheld, a

similar process would have to be undertaken and a significant effort and resources would

have to be expended.

Moreover, disclosure of this infomiation may provide insights into the ACO's NMC&A

Program for Special Nuclear Material categorized as Security-Related Information, and Export

Controlled Information. Therefore, this enclosure should also be withheld from public

disclosure pursuant to 10 CFR 2.390(d)(l) and 10 CFR Part 810.

Further the deponent sayeth not.

Larry B. Cutlip, having been duly sworn, hereby continns that I am the Senior Vice

President, Field Operations of American Centrifuge Operating, LLC, that I am authorized on behalf

of ACO to review the infonnation attached hereto and to sign and tile with the U.S. Nuclear

Regulatory Commission this affidavit and the attachments heret_o, and that the statements made and

matters set forth herein are true and correct to the best of my knowledge, infonnation, and belief.

On this 28 th day of April 2022, Larry B. Cutlip personally appeared before me, is known by

me to be the person whose name is subscribed to within the instrument and acknowledged that he

executed the same for the purposes therein contained.

In witness hereof I hereunto set my hand and official seal.

• State of Tennessee Notary Public Anderson County My commission expires October 26, 2024 Enclosure 1 of ACO 22-0042

Detailed Description, Justification, and Significance Determination

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

Date: 04/27/2022 Enclosure 1 ACO 22-0042 Page 1 of5

Detailed Description, Justification, and Significance Determination

Detailed Description of Change

American Centrifuge Operating, LLC (ACO) proposes to amend LA-3605-0001, License Application for the American Centrifuge Plant (ACP); LA-3605-0002, Environmental Report for the American Centrifuge Plant; and NR-3605-0005, Fundamental Nuclear Material Control Plan for the American Centrifuge Plant, to:

1) Remove the "three-year" verbiage or extend the contract end date for the High-Assay Low Enriched Uranium (HALED) Demonstration Program from May 31, 2022, to November 30, 2022.

2) Extend or clarify the Gas Centrifuge Enrichment Plant (GCEP) Lease Agreement amendments to December 31, 2025, and amendment verbiage based upon the fact that two amendments have been issued by the DOE in support of the HALED Demonstration Program.

3) Minor administrative/formatting corrections were also noted within these proposed changes.

Proposed changes are also provided for U.S. Nuclear Regulatory Commission's (NRC) Material License SNM-2011 for the ACP, specifically Conditions #15 and #16, to make corresponding date changes.

There are no changes being proposed to the currently described HALED 16-centrifuge cascade design or operation, and no increase in the approved HALED possession limits approved within SNM-2011. Furthermore, no changes are warranted under the American Centrifuge Lead Cascade Facility (Lead Cascade Facility) license application and supporting documents.

The proposed changes contained within Enclosures 2, 3, and 4 are identified by the following method:

• Blue Strikeout Identifies text to be removed

• Red underline - Identifies text to be added

Justification

Modification P00 19 of U.S. Department of Energy's (DOE) Contract #89303519CNE000005 for the HALED Demonstration Program was approved on April 25, 2022 (Reference 5 of this letter). The purpose of this modification is to extend the period of performance from May 31, 2022, to November 30, 2022, in order to facilitate a six-month extension to the NRC License. Under the authority of FAR 52.217-8, Option to Extend Services.

This contract and GCEP Lease extensions support continued preparation work to be completed that will lead into the final introduction of gas into the 16-centrifuge HALED Demonstration cascade under an anticipated follow-on DOE contract. It is also anticipated that the DOE will be issuing a Enclosure 1 ACO 22-0042 Page2 ofS

Request for Proposal for the final operation of the HALED Demonstration cascade under a separate contract. If awarded to ACO, a separate future amendment will be developed and submitted to the NRC for prior review and approval to support that follow-on contract.

Additionally, Amendment 2 to the Appendix 1 Lease Agreement Between the US. Department of Energy and United States Enrichment Corporation for the Gas Centrifuge Enrichment Plant (GCEP Lease Agreement), approved on September 9, 2021 (Reference 6 of this letter), formally extended the term of the lease until December 31, 2025. Note: Amendment 1 to the Appendix 1 Lease Agreement Between the US. Department of Energy and United States Enrichment Corporation for the Gas Centrifuge Enrichment Plant, was previously provided to the NRC by ACO 19-0008, dated June 27, 2019.

The proposed changes are administrative in nature to amend the completion date of the DOE HALED Demonstration Program and corresponding GCEP Lease Agreement. There are no changes in the HALED cascade process descriptions; number of planned operating centrifuges, or possession limits at the current time. Therefore, the proposed changes will not alter the design or performance of an item or activity as described in the Integrated Safety Analysis; LA-3605-0003, Integrated Safety Analysis Summary for the American Centrifuge Plant; or LA-3605-0003A,Addendum 1 of the Integrated Safety Analysis Summary for the American Centrifuge Plant - HALEU Demonstration.

Likewise, the proposed changes will not: 1) decrease the level of the design basis as described in the ACP License Application; 2) result in a departure from a method of evaluation described in the ACP License Application used in establishing the design bases; 3) result in a degradation in safety; or 4) affect compliance with applicable regulatory requirements.

The corresponding proposed date extensions do, however, conflict with existing license conditions, specifically related to SNM-2011 Conditions #15 and #16; therefore, requires the NRC's prior review and approval.

On June 4, 2021, the NRC issued the Environmental Assessment for the Proposed Amendment of US. Nuclear Regulatory Commission License Number SNM-2011 for the American Centrifuge in Piketon, Ohio (ADAMS Accession No. ML21085A705), which provided for the conclusion and finding of no significant impact (FONSI) for the HALED Demonstration Program. The basis for this FONSI is the proposed action was not expected to result in new construction, and that the HALED cascade would be assembled and operated in existing buildings that previously housed a similar system under the Lead Cascade Facility license. The proposed action previously evaluated related to the number of centrifuges used for the HALED cascade and the possession limits remains unchanged. Therefore, this basis remains unchanged with the newly proposed extension of the DOE contract and GCEP lease dates.

Additionally, during the completion of the Environmental Assessment, NRC staff took into consideration the environmental impacts of operation beyond the contract expiration date of May 31, 2022, specifically anticipated license extensions ofup to 10 years. The proposed extension of the DOE contract and lease dates would not result in any significant impact on the demography, socioeconomics, and environmental justice; public and occupational health and safety; non radiological impacts from normal operations; radiological impacts from normal operations; impacts Enclosure 1 ACO 22-0042 Page 3 ofS

from accidents; waste management; transportation; or cumulative impacts. Therefore, ACO believes the environmental assessment remains valid as written.

In accordance with 10 CFR 70.34 and 70.65, the proposed changes discussed above, require the NRC's prior review and approval. The proposed changes will not decrease the ability of the management measures in the License Application to ensure the availability and reliability ofIROFS.

The proposed changes do not decrease the effectiveness of the design basis as described in the License Application. The proposed changes do not result in a departure from a method of evaluation described in the License Application used in establishing the design bases for the evaluation of HALEU Demonstration Criticality Events; therefore, this results in no degradation of safety. Lastly, the proposed changes do not have an adverse effect on compliance with applicable regulatory requirements.

Significance Determination for Proposed Conforming Changes

The proposed changes are administrative in nature to amend the completion date of the DOE HALEU Demonstration Program and corresponding GCEP Lease Agreement. There are no changes in the HALEU cascade process descriptions; number of planned operating centrifuges, or possession limits at the current time. ACO has reviewed the proposed changes and provides the following Significance Determination.

1. No significant change to any conditions to the License.

The proposed changes are not prohibited by 10 CFR Part 70, license condition, or order.

However, two conditions (#15 and #16) are being modified, to align the dates with the anticipated DOE HALEU contract extension to November 30, 2022, as well as Amendment 2 of the GCEP Lease Agreement for a term extension through December 31, 2025.

2. No significant increase in the probability of occurrence *or consequences of previously evaluated accidents.

The proposed changes do not remove or change an IROFS that is listed in the ACP ISA Summary and Addendum 1. The proposed changes do not alter any IROFS listed in the ISA Summary or Addendum 1, that is the sole item preventing or mitigating an accident sequence that exceeds the performance requirements of 10 CFR 70.61.

3. No new or different type of accident.

• The proposed changes do not create new types of accident sequences that, unless mitigated or prevented, would exceed the performance requirements of 10 CFR 70:61 and that have not previously been described in the ISA Summary/Addendum I.

Enclosure 1 ACO 22-0042 Page 4 of5

4. No significant reduction in the margins of safety.

The proposed changes do not decrease the margin of safety associated with any IROFS being credited to ensure the performance requirements of 10 CFR 70.61 are met.

5. No significant decrease in the effectiveness of any programs or plans contained in the licensing documents.

The proposed changes will not decrease the overall level of security performance needed to protect against the loss or compromise of classified matter, while in use, in storage, or in transit. The control of classified storage areas or vaults, training of classifiers, documentation of classification of matter, etc. will be maintained at an equivalent level.

Security plan SEC-18-0002 provides for the protection of cyber systems, maintaining the necessary computer security requirements at an equivalent level as previously approved by theNRC.

The proposed changes to the Fundamental Nuclear Materials Control Plan (FNMCP) (NR-3605-0005) are administrative in nature to clarify the terms of the HALEU Demonstration Program within Section 1.1 and will have no effect on the FNMCP meeting the applicable requirements of 10 CFR Parts 70 and 74 for ACP. Likewise, the proposed changes do not affect the function or process to control nuclear material as described within the FNMCP.

The proposed changes do not result in a decrease in effectiveness of the approved ACP Emergency Plan. For HALEU demonstration, no Emergency Plan as discussed under 10 CFR 70.22(i) is required. Likewise, the proposed changes will not decrease the abilities of the DOE reservation Responses Organization to mitigate accident consequences or reasonably assure the adequate protection of the health and safety of the off-site and on-site personnel in the event of an emergency.

The proposed changes do not result in a change to the Quality Assurance Program Description; thereby, do not represent a relaxation of a requirement of Quality Assurance Program Description.

Based on the above, the proposed changes will not result in a decrease in the effectiveness of the Security Programs/Plans, FNMCP, Emergency Plan, or the Quality Assurance Program Description contained in the licensing documents..

6. The proposed change does not result in undue risk to: 1) public health and safety; 2) common defense and security; and 3) the environment.

The proposed changes do not involve additional quantities of licensed material and do not change the response to accidents or events associated with licensed material. There will be no generation or increase in hazardous material quantities such that it impacts public health and safety. The proposed changes have no impact to the plant boundary protection, documentation of patrols, performance of rounds, or training of protective force personnel. The proposed changes will not increase the likelihood classified matter or Special Nuclear Material will be Enclosure 1 ACO 22-0042 Page 5 ofS

accessible to unauthorized personnel. Therefore, the proposed changes do not result in undue risk to public health and safety, the environment, or to the common defense and security.

7. There is no change in the type or significant increases in the amounts of any effluents that may be released off-site.

The proposed changes do not result in any new or unusual sources of hazardous substances, hazardous waste, or new waste streams that could be generated or used in unacceptable levels that exceed applicable regulatory requirements as a result of the proposed changes. In addition, there is no change in the type or significant increases in the amounts of any effluents that may be released off-site.

8. There is no significant increase in individual or cumulative occupational radiation exposure.

DAC-3901-0005, Evaluation of No Need for an Emergency Plan for the HALEU Demonstration, provides the evaluation stipulated in 10 CFR 70.22(i)(l)(i) to demonstrate that no Emergency Plan is required for the HALEU Demonstration Program. The evaluation shows that the maximum dose to a member of the public off site due to a release of radioactive materials would not exceed 1 rem effective dose equivalent or an intake of 2 mg of soluble U. Therefore, the proposed changes provided within this License Amendment Request to extend the date for the existing DOE HALEU Contract period will not increase radiological or chemical releases beyond applicable regulatory limits (10 CFR 70.61) and will not create any new or unusual sources of radioactive waste. Likewise, the proposed changes will not result in significant increase in individual or cumulative occupational radiation exposure.

9. There is no significant construction impact.

HALEU Demonstration Program construction activities are currently on hold until the DOE issues the follow-on contract to finalize the construction activities, pass the final NRC required Operational Readiness Review inspections, and receive final authorization to introduce gas into the HALEU cascade to meet the DOE's follow-on contract obligations. Therefore, currently there are no foreseen environmental concerns based upon the fact that the HALEU Demonstration Program is being constructed within leased buildings used during the operations of the previous American Centrifuge Lead Cascade Facility; however, on a much smaller scale.

Additionally, there will be no new building construction planned for the extension of time for this initial deployment phase of the ACP.

Enclosure 2 of ACO 22-0042

Proposed Changes for LA-3605-0001, License Application for the American Centrifuge Plant, and LA-3605-0002, Environmental Report for the American Centrifuge Plant

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

Date: 04/27/2022

_For Information Only License Application for the American Centrifuge Plant Proposed Change April 2022

1.0 GENERAL INFORMATION

This license application was previously submitted by Centrus Energy Corp. (Centrus),

formerly known as USEC Inc., for the American Centrifuge Plant (ACP). It encompasses the construction, manufacturing, start-up, operations, maintenance, and decommissioning of a uranium enrichment facility using American Centrifuge technology that will produce approximately 3.8 million separative work units (SWU) annually.

The United States Enrichment Corporation leases portions of the Portsmouth Gaseous Diffusion Plant (GDP) reservation from the U.S. Department of Energy (DOE) through the Lease Agreement between the US. Department of Energy and United States Enrichment Corporation for the Gas Centrifuge Enrichment Plant (GCEP Lease Agreement). Pursuant to a 2006 amendment to that lease agreement, Centrus subleased space for the American Centrifuge Lead Cascade Facility (Lead Cascade) and the ACP from the United States Enrichment Corporation. Centrus, with approval of the DOE, assigned the sublease for the space for the ACP to the Licensee, American Centrifuge Operating, LLC (ACO). The Licensee and its agents will conduct activities within the leased facilities and access and egress thereto, in accordance with this license application.

The ACP utilizes existing buildings located on the DOE reservation near Piketon, Ohio, that were built to support the gaseous centrifuge process beginning in the 1980s, in addition to several newly constructed buildings and facilities.

The ACP is the third step in the plan to deploy the American Centrifuge technology. The first step was the centrifuge testing in Oak Ridge, Tennessee, to upgrade, and demonstrate an economically attractive gas centrifuge and enrichment process. The second step was the deployment of the Lead Cascade in Piketon, Ohio, which provided reliability, performance, cost, and other vital data on the ACP enrichment process. American Centrifuge technology is modular, with the basic building block of enrichment capacity being a cascade of centrifuges. Information gained and work performed during the centrifuge testing and Lead Cascade projects included vital information on performance, reliability, and economics that will be used in the construction of the ACP. A license application was prepared pursuant to the Atomic Energy Act of 1954 as amended, 10 Code of Federal Regulations (CFR) Parts 70, 40, 30, and other applicable laws and regulations.

The commercial ACP operation is designed to enrich and safely contain and handle uranium hexafluoride (UF6) up to IO-weight (wt.) percent uranium-235 (235 U). This license application includes the High Assay Low Enriched Uranium (HALEU) Demonstration Program which is designed to enrich and safely contain and handle UF6 with an operational limit that is less than 20.0 wt. percent 235 U.

This license application follows the format and content guidelines provided in NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications, Revision 2 (Reference 1 ). The information provided reflects the design in sufficient detail to enable a reviewer to make a definitive evaluation that the ACP can be constructed and operated without undue risk to the health and safety of the public and with no significant impact to the environment.

The ACP uses portions of the Portsmouth Gaseous Diffusion Plant (GDP) and the former DOE Gas Centrifuge Enrichment Plant (GCEP) along with eight new facilities. The ACP utilizes existing utilities and infrastructure that support the DOE reservation along with the utilities and

1-1 For Information Only License Application for the American Centrifuge Plant Proposed Change April 2022

infrastructure that were intended to support GCEP. New facilities are necessary for feed, withdrawal, sampling, and blending/transfer operations. Centrus has updated the American Centrifuge technology from that used in the GCEP program, but the American Centrifuge components remain compatible with existing infrastructure and buildings/facilities.

The HALEU Demonstration Program is a program awarded by DOE's Nuclear Energy Oak Ridge Site Office for the demonstration of the HALEU production to support DOE research and development (R&D) activities and programs. The HALEU Demonstration Contract was awarded on May 31, 2019 and definit ized on October 31, 2019 (Reference 17). The two primary objectives of the HALEU Demonstration Program is for American Centrifuge Operating, LLC (ACO), the licensee, to deploy a 16-machine AC-l00M HALEU cascade in the Piketon facility to produce 19.75% 235 U enriched product and to demonstrate the capability to produce HALEU utilizing US-origin uranium enrichment technology. The HALEU Demonstration will be deployed in a subset of the larger ACP with deviations noted as appropriate in the sections that follow.

It is the intent of the licensee to deploy portions of the ACP in a modular fashion to accommodate market demand on a scalable, economical gradation. This modular deployment will encompass utilization of cascades of LEU production for customer product or feed material into HALEU cascades.

1.1 Plant and Process Description

This section describes the buildings and facilities that comprise the ACP located on the DOE reservation in Piketon, Ohio, and describes the process by which the plant will operate.

Facilities are those buildings and systems identified in the lease agreement between the United States Enrichment Corporation and DOE. The ACP buildings and facilities are grouped in two categories, primary and secondary in the Integrated Safety Analysis (ISA) Summary. Figure 1.1-1 (located in Appendix B) depicts the entire DOE reservation and the area where the ACP resides in the southwest quadrant. Figure 1.1-2 depicts a closer view of the ACP area and shows the Primary and Secondary buildings. Primary facilities are those buildings or areas that could contain licensed material in quantities that could potentially result in consequences that exceed the performance criteria defined in 10 CFR 70.61 resulting from credible accidents or that directly control a primary facility. All other ACP facilities are considered to be secondary. A further description of primary and secondary facilities and a list of these buildings/facilities are in Sections 1.1.3 and 1.1.4 of this license application.

The uranium element appears in nature in numerous isotopes; the three major isotopes of interest have atomic weights of 234, 235, and 238. The 235 U isotopes are fissionable and capable of sustaining a critical reaction. Natural uranium contains 0.711 percent 235 U isotope. Isotopic separation processes separate uranium into two fractions, one enriched in the 235 U isotope, and the other depleted.

Prior to the enrichment process, uranium is combined with fluorine to form UF6 from the uranium feed suppliers. The UF6 arrives at the plant in a solid state and this UF6 is sublimed from a solid to a gas and fed into the system. In the gas centrifuge process, the isotopic separation is accomplished by centrifugal force, which uses the difference in weight of the uranium isotopes to achieve this isotopic separation. UF6 can be enriched up to 10 wt. percent assay 235 U in the

l-2 License Application/or the American Centrifuge Plant Proposed Change April 2022

1.1. 7 Roadways

Two major four-lane highways service the DOE reservation: U.S. Route 23, traversing north-south, and State Route 32/124, traversing east-west. The reservation is situated approximately three and one half miles from the intersection of U.S. Route 23 and State Route 32/124. Ingress and egress from the reservation to these major roadways is by the Main Access Road, which connects to U.S. Route 23. The Main Access Road connects to the Perimeter Road, which encircles the fenced portion of the DOE reservation. Alternative ingress and egress from the reservation can be established from the north access road in the event of significant Main Access Road repairs. Service roads throughout the reservation connect to the Perimeter Road with access to the ACP controlled through security portals. The reservation roadways are depicted in Figures 1.1-1 (located in Appendix B) and 1.1 - 2.

1.1.8 Phased Modular Expansion Plan for the American Centrifuge Plant

It is the intent of ACO to deploy portions of the ACP in a modular fashion to accommodate market demand on a scalable, economical gradation. This modular deployment may encompass utilization of cascades of Low Enriched Uranium (LEU) production for LEU customer product or feed material into HALEU cascades. The ratio of LEU cascades to HALEU cascades would be approximately 6 to 1.

1.1.8.1 High Assay Low Enriched Uranium Demonstration

The HALEU Demonstration cascade utilizes a similar centrifuge design to that used for the Lead Cascade. The equipment necessary to perform the enrichment process is in the X-3001 Process Building and consists of product and tails withdrawal system, UF6 cylinders, centrifuges,

and supporting systems. The product and tails withdrawal systems use three cold boxes. NaF traps are used for additional withdrawal capacity during dumping. A 30B UF6 cylinder is used for the feed material. Centrifuges and supporting units are placed in the Train 3 area of the X-3001 building. For further plant and process specifics related to the HALEU Demonstration Program, refer to LA-3605 -0003A, Addendum 1 of the Integrated Safety Analysis for the American Centrifuge Plant - HALEU Demonstration (Reference 7).

In support of this HALEU Demonstration Program and NRC Materials License (SNM -

2011) Condition 23, DOE amended (Amendment 1) the Appendix 1 Lease Agreement between the US. Department of Energy and United States Enrichment Corporation for the Gas Centrifuge Enrichment Plant (GCEP Lease Agreement) (Reference 71). The amended GCEP Lease Agreement renewed and extended the term of the lease through May 31, 2022. The ACO sublease incorporates the terms of the GCEP Lease Agreement. Furthcnnor in Se temb r 202 1 the() E am ndcd mendment 2 the G 'E P Lea. e A *n: m nt to ex tend th tem1 throu h Dccemb *r l 02. All oth r tcnns of the :i ' EP Leas as amended by Am ndm nt I remaim:d unchanged.

At the conclusion of the lh:ree year HALEU Demonstration Program, the facilities will be either returned to the DOE in accordance with the requirements of the GCEP Lease Agreement or the parties will amend the GCEP Lease Agreement to allow the performance of other work on the leased premises.

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Fluor-BWXT Portsmouth, LLC (FBP) is the DOE contractor for D&D of the GDP. FBP is responsible for the D&D of 415 facilities and structures that supported the uraniwn enrichment operations conducted at the site. During D&D, Fluor-BWXT prepares contaminated facilities for demolition by deactivating ~tilities and removing stored waste, materials, process equipment such as converters and compressors, and piping.

The plant also includes various support structures that provide feed and transfer operations and site services such as maintenance; steam generation; cleaning; process heat removal; electrical power distribution; and water supply storage and distribution.

Pixelle Specialty Solutions', formerly Glatfelter Specialty Papers, operates a lumberyard on the north edge of the DOE reservation. This facility is utilized as a sorting and transfer area for commercial and paper grade lumber.

1.2.2 Financial Qualifications

Under the HALEU Contract (Reference 17), DOE agreed to reimburse the Company for 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 t hree year 111\\LEU contract p riod include constructing and assembling centrifuges and related infrastructure in a cascade formation. 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 (Reference 22).

In support of this HALEU Demonstration Program, DOE amended (Am ndm nt I) 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. Both the GCEP Lease and the Demonstration Contract afford indemnification pursuant to the Price Anderson Act.

The Company has long-term nuclear fuel sales and supply contracts in place that extend to 2030; these contracts will provide a stream of revenue for many years and provide a foundation for growth (Reference 22).

At the time of initial licensing and remains as the basis for the initial Materials License approval, the Licensee estimated the total cost to construct the initial 3.8 million SWU capacity

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to satisfactorily fulfill customer orders up to 20 wt. percent 235 U. 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 oflicensed 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:

• UF6 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 UF6 cylinders during movement.

• Containers located in Restricted Areas within the ACP are exempt from container labeling requirements of 10 CFR 20.1904, as it is deemed impractical to label each and every container. In such areas, one sign stating that every container may contain radioactive material will be posted. By procedure, when containers are to be removed from contaminated or potentially contaminated areas, a survey is performed to ensure that contamination is not spread around the reservation.

• In lieu of the requirements of 10 CFR 20.160l(a), each High Radiation Area with a radiation reading greater than 0. 1 Roentgen Equivalent Man per hour (REM/hour) at 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.

1-61 License Application/or the American Centrifuge Plant Proposed Change April 2022

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.

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 ofHALEU Demonstration Program, as noted in Section 10. 1 of this license application, DOE amended the Appendix 1 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 ( mcndmcnt l}_ GCEP Lease Agreement, DOE assumes all liability for the decontamination and decommissioning of such facilities and equipment installed, and any work performed, under the HALEU Demonstration Contract with the Department including any materials or e nvironmental hazards on the site. Therefore, exempting 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

1-62 For Information Only license Application for the American Centrifuge Plant Proposed Change April 2022

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 l O 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 ofthis license application, the financial assurance for a portion of the decommissioning costs, to include the disposition of centrifuges and UF6 tails, which constitutes a major portion of the decommissioning liability, will be provided incrementally as centrifuges are built/installed and UF6 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: l) 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 UF 6 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

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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 likelihood for a breach to not be identified and repaired before sufficient moderation results in a criticality. Moderation control of UF6 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. UF6 cylinders are uniquely identified and their design requirements are controlled to further ensure cylinder integrity and reliability (i.e., UF6 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 UF6 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 UF6 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

1-64 For I nforrnation Only License Application for the American Centrifuge Plant Proposed Change April 2022

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 exceeds 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 increased 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 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 140.13 b requires, that "Each holder of a license issued under Parts ~O 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

l-65 License Application for the American Centrifuge Plant Proposed Change A pril 2022

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." I

In support of this HALEU Demonstration Program, DOE amended (Amendm nt l) the GCEP Lease Agreement, in which the parties agree that all work performed under the I HALEU Demonstration Contract on leased premises shall be considered a permitted use; any alterations or changes to the premises pursuant to the Demonstration Contract I 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 I HALEU 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 yeElf l lAL EU _ ontract period. I

In support of future expansion of the ACP, in accordance with Section 3107 of the USEC I 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 I Atomic Energy Act (AEA) for liability claims.

The Commission may, pursuant to 10 CFR 140.8, upon application of any interested I 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 I 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 I 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 193(d) of the Atomic Energy Act of 1954, as amended. Section 193(d) states that the I 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 I and in such amounts as the Commission judges appropriate to cover liability claims... "

I 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 I 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 I commencing operations.

I 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 I 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 I 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 I

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I For lnfonnation Only License Application for the American Centrifuge Plant Proposed Change April 2022

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 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

1-67 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 Experzses. Services to *be provided over the th.r~e year HALE eContract peri d include constru~ting and assembling centrifuges and related infrastructure in a cascade formation and production ofup 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 tht=ee yeM 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 and creates a situation where the classification actions may be double counted. Accordingly, in lieu of filing its classification actions with NRC, the Licensee will continue to submit the quarterly classification summary documents to DOE and will make them available for NRC inspection at the facility.

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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/table/1.0/en/DEC/1 O _ SFl/GCTPHl.STl 0/0400000US 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:

hllp ://www.usg s.gov/index.htm l

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

1-138 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/or 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, 20192 as amended

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 UF6 Manual - Good Handling Practices for Uranium Hexafluoride,"

Revision 9, July 2006

20. ASTM C1052, 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-infonnation/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/uranium/documents/index.cfin

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

l-139 License Application for the American Centrifuge Plant Proposed Change April 2022

65. Geraghty & Miller, Analysis of Long-Term Hydro logic Budget for the Portsmouth Gaseous Diffusion Plant, Piketon, Ohio, October 1988-September 1989, Dublin, Ohio, 1990

66. Geraghty & Miller, Quadrant 11, RF/ 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, h ttp ://geosurvey.ohiodnr.gov/earthguakes-ohio se is/guakes-fclt-in-ohio/rece n t-obio regional-quakes

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

70. Appendix I Lease Agreement between the US. Department of Energy and United States Enrichment Corporation for the Gas Centrifuge Enrichment Plant (GCEP Lease Agreement), An:iem:lment daled May 31, 20 l 9as amended

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

1-143 License Application for the American Centrifuge Plant Proposed Change April 2022

10.0 DECOMMISSIONING

In accordance with NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications (Revision 2), this chapter provides an overview of proposed decommissioning activities for the American Centrifuge Plant (ACP). The ACP is located in a leased area of the U.S. Department of Energy's (DOE) reservation in Piketon, Ohio.

10.1 High Assay Low Enriched Uranium (HALEU) Demonstration Program

The Licensee, American Centrifuge Operating, LLC (ACO or Corporation), is deploying a 16-machine ACIO0M HALED cascade in leased areas under contract with the U.S. Department of Energy (DOE or Department). In support of this HALED Demonstration Program, DOE amended the Appendix 1 Lease Agreement between the US. Department of Energy and United States Enrichment Corporation for the Gas Centrifuge Enrichment Plant (GCEP Lease Agreement). The amended (Amendm nt I) GCEP Lease Agreement renewed and extended the term of the lease through May 31, 2022. Additionally, tl he amended GCEP Lease Agreement permit tcds the construction and operation of the demonstration cascade by the Corporation (Licensee), the sublessee of the GCEP Lease and holder of the U.S. Nuclear Regulatory Commission (NRC) American Centrifuge Plant (ACP) Materials License. Furthermore. in

, t rnber 2021 th

• D E amend d Amemlment 2 th CEP L as A *r m nt l xt nd th term throu gh December 31. 2025. All other terms of the GCEP Lease as amended by Amendment I remained w1chW1ged.

The a.menEleEI Amendment 1 of the GCEP Lease Agreement include aj the following statements pertaining to decommissioning liability:

• As of May 31, 2019, the Corporation (Licensee) had fully satisfied the lease turnover conditions and any existing financial assurance provided under Section 4.3 (of the GCEP Lease Agreement) was released, surety bonds were cancelled, and collateral returned to the Corporation (Licensee).

• Any facilities or equipment constructed or installed by the Corporation (Licensee) under the Demonstration Contract with the Department shall be included in Exhibit B ( of the GCEP Lease Agreement) as Leased Personality and may be returned to the Department in an "as is" condition at the end of the lease term (May 31, 2022).

• The Department hereby assumes all liability for the decontamination and decommissioning of such facilities and equipment installed, and any work performed, under the Demonstration Contract with the Department including any materials or environmental hazards on the site. Therefore, no financial assurance for any liability or lease turnover conditions shall be required from the Corporation (Licensee).

_* _ The parties agree that any work performed under the HALEU Demonstration Contract on the leased premises shall be considered a permitted use; any alternations or changes to the premises pursuant to the Demonstration Contract with the DOE shall be a permitted change to the premises; and any liabilities of the Corporation (Licensee) arising from or incident

10-1 License Application for the American Centrifuge Plant Proposed Change April 2022

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.

Pursuant to the modified DOE HALEU Contract, title to depleted uranium hexafluoride (UF6) by-product (tails) from the HALEU enrichment process will be retained by DOE.

At the conclusion of the HALEU Demonstration Program, the facilities will be either returned to the Department in accordance with the requirements of the GCEP Lease Agreement or the Licensee will amend the ACP Materials License to allow phased implementation of expanded centrifuge enrichment cascades as described in Section l.1.8 of the license application. At that time, a revised decommissioning funding plan, including an updated decommissioning cost estimate would be provided to the NRC for prior review and approval to reflect any new decommissioning liabilities.

10.2 American Centrifuge Plant (ACP) Decommissioning

The Licensee previously requested a 30-year license to operate the ACP. At the end of useful plant life, the ACP will be decommissioned such that the facilities will be either returned to the DOE in accordance with the requirements of the Lease Agreement with the DOE or will be released for unrestricted use. The criteria for final disposition of facilities will be established in the Decommissioning Plan (DP) which, as noted below, will be submitted prior to license termination. Nevertheless, for the purposes of the License Application for the ACP, the decommissioning discussions in this application and the decommissioning estimated costs are based on decontaminating the plant to the radiological criteria for unrestricted use in 10 Code of Federal Regulations (CFR) 20.1402. Information about the Licensee, the location of the site, and the types and authorized uses of licensed material are provided in Section 1.2 of the license application and a description of the site and immediate environs is provided in Section 1.3 of the license application.

Similar to the successful decommissioning efforts for the American Centrifuge Lead Cascade Facility, a more detailed DP for the ACP will be submitted by the Licensee in accordance with 10 CFR 30.36 (g), 10 CFR 40.42 (g), and 10 CFR 70.38(g) and applicable risk-informed NRC guidance provided in NUREG-1757, Consolidated Decommissioning Guidance (Volumes 1 - 3) prior to the time of license termination. Prior to decommissioning, an assessment of the radiological status of the ACP will be made. Enrichment equipment will be removed, leaving only the building shells and the plant infrastructure, including equipment that existed at the time oflease with the DOE (e.g., rigid mast crane, utilities, etc.). Classified material, components, and documents will be destroyed or disposed of in accordance with the Security Plan for the Protection of Classified Matter at the American Centrifuge Plant. Requirements for nuclear material control and accountability will be maintained during decommissioning in a manner similar to the programs in force during ACP operation (NR-3605-0005). Depleted UF6 material (tails), if not sold or disposed of prior to decommissioning, will be sold, or converted to a _stable, non-volatile uranium compound and disposed of in accordance with regulatory requirements utilizing facilities constructed by DOE, as authorized by the USEC Privatization Act, and/or other licensed facilities.

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Radioactive wastes will be disposed of at licensed low-level waste disposal sites. Hazardous wastes will be treated or disposed of in licensed hazardous waste facilities. I

• The DP submitted at the time of license termination consists of several interrelated components, including (1) site characterization information, (2) remediation plan, and (3) a final status survey plan. The costs for activities required for these components have been identified in this chapter and estimated ini the Decommissioning Funding Plan (DFP). Costs projected were developed based on the experience at the Portsmouth Gaseous Diffusion Plant during the transition to Cold Standby operation and decommissioning cost estimates developed for the American Centrifuge Demonstration Facility. Additionally, the Licensee had performed dismantling and decontamination work at the gaseous diffusion plants. Data and experience from these activities allowed a realistic estimation of expected decommissioning financial expenditures.

Using the cost data as a basis, financial arrangements are made to cover costs required to release the ACP for unrestricted use and to dispose of the tails. Updates on cost and funding will be provided periodically as described in Section 10.2.10.4. In accordance with 10 CFR 70.22(a)(9), 30.35, 40.36, and 70.25(a)(l), a DFP (NR-3605-0006) was previously submitted as part of the original license application for the ACP.

The following assumptions are utilized in the plan for decommissioning:

• No credit is taken for salvage value of equipment or materials.

• Decontamination liability is anticipated in the X-3001 and X-3002 Process Buildings, X-3012 Process Support Building, X-3344 Customer Services Building, X-3346 Feed and Withdrawal Building, X-3346A Feed and Product Shipping and Receiving Building, X-7725 Recycle/Assembly Building, X-7726 Centrifuge Training and Test Facility, X-7727H Interplant Transfer Corridor, X-2232C Interconnecting Process Piping, and miscellaneous cylinder storage yards.

• No decontamination is anticipated for the other ACP leased facilities.

• Decommissioning estimated costs are based on decontaminating the plant to the radiological criteria for unrestricted use in l 0 CFR 20.1402.

The centrifuge assembly area in the X-7725 building is identified as the Decontamination Service Area (DSA). The centrifuge transport system is used to transport the centrifuges from the cascade area to the DSA.

The remaining sections of this chapter describe decommissioning plans and funding arrangements, and provide a detailed examination of the decontamination aspects of the program.

The information herein was developed in connection with the decommissioning cost estimate and is provided for information. Specific elements of the planning may change with the submittal of the detailed DP required near the time of license termination.

10-3 License Application for the American Centrifuge Plant Proposed Change April 2022

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

The plans are implemented through proper management of Radiation Protection and Industrial Health and Safety programs for the ACP. Decommissioning policies address radioactive waste management, physical security, and nuclear material control and accountability.

10.2.1 Decommissioning Design Features

Specific features are incorporated into the plant design to accommodate decontamination and decommissioning activities. The major features are described below.

10.2.1.1 Radioactive Contamination Control

The following features primarily serve to minimize the spread of radioactive contamination during operation, and simplify the eventual plant decommissioning. As a result, worker exposure to radiation and radioactive waste volumes are maintained as low as reasonably achievable (ALARA).

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

CCZs are buffer zones established where discrete areas of contamination might be occasionally encountered. Areas that are contaminated are called Contamination Areas (CAs). Figure 10.2.1-1 (located in Appendix D of this license application) provides a diagram showing the CCZ boundary. Procedures for these areas are encompassed by the Radiation Protection Program and serve to minimize the spread of contamination and simplify eventual decommissioning.

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

10.2.1.2 Worker Exposure and Waste Volume Control

The following features primarily serve to minimize worker exposure to radiation and minimize radioactive waste volumes during decontamination activities. As a result, the spread of contamination is minimized as well.

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

• Connections in the process systems are provided for thorough purging. This removes a significant portion of radioactive contamination prior to disassembly.

• Design drawings prepared for the plant, simplify the planning and implementing of decontamination procedures.

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10.3 References

I. Appendix 1 Lease Agreement between the US. Department of Energy and United States Enrichment Corporation for the Gas Centrifuge Enrichment Plant (GCEP Lease Agreement), as amended A.mendment Eiat:ed May 31, 2019

2. Federal Register, Volume 68 Number 192, Financial Assurance for Materials Licensees, Final Rule, October 3, 2003

3. HALEU Demonstration Contract Number 893035 l 9CNE000005, awarded May 31, 2019s and definitized on October 31, 2019, a

• amended

4. NUREG-1520, Standard Review Plan for Fue l_Cycle Facilities License Applications, Revision 2

5. NUREG-1757, Consolidated Decommissioning Guidance, Volume 1,, Decommissioning Process for Materials Licensees, Revision 2

6. NUREG-1757, Consolidated Decommissioning Guidance, Volume 2, Characterization, Survey, and Determination of Radiological Criteria, Revision 1

7. NUREG-1757, Consolidated Decommissioning Guidance, Volume 3, Financial Assurance, Recordkeeping, and Timeliness, Revision 1

8. NR-3605-0005, Fundamental Nuclear Material Control Plan for the American Centrifuge Plant

9. NR-3605-0006, Decommissioning Funding Plan for the American Centrifuge Plant

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

11. W. Brown (DOE) letter to Mr. Phil Sewell (USEC), Conversion and Disposal of Depleted Uranium Hexafluoride (DUF6) Generated by USEC at the American Centrifuge Plant in Piketon, Ohio, dated February I 0, 2006

10-21 For lnfonnation Only Environmental Report for the American Centrifuge Plant Proposed Change April2022

In 1991, DOE suspended production of highly enriched uranium (HEU) at PORTS. The plant continued to produce low enriched uranium (LEU) for use by commercial nuclear power plants until May 2001. The GDP transitioned to Cold Shutdown status on October 1, 2005 and the Decontamination & Decommissioning (D&D) of inactive facilities began. In August of2010 the DOE awarded the contract for complete D&D of the GDP (excluding facilities supporting other reservation entities, including the Lead Cascade and ACP). D&D of multiple facilities started in 2010 and at present remains ongoing (FBP-ER-RCRA-WD-RPT-0288).

In accordance with the Energy Policy Act of 1992, the United States Enrichment Corporation, a newly created government corporation, assumed full responsibility for uranium enrichment operations at PORTS on July 1, 1993. DOE retains certain responsibilities for decontamination and decommissioning, waste management, depleted uranium hexafluoride cylinders, and environmental remediation. The NRC granted the United States Enrichment Corporation a Certificate of Compliance for operation of the GDP pursuant to 10 CFR Part 76 on November 26, 1996 and the GDP was officially transferred to NRC oversight on March 3, 1997.

USEC subsequently became a publicly held private corporation on July 28, 1998.

The DOE leases portions of the Portsmouth Gaseous Diffusion Plant to the United States Enrichment Corporation (USEC) through the GCEP Lease Agreement. Pursuant to an amendment to the lease agreement, Centrus subleased space for the Lead Cascade and American Centrifuge Plant (ACP) from USEC. Centrus, with approval from DOE, assigned the sublease for the ACP to American Centrifuge Operating LLC (ACO).. In addition to the GDP buildings, extensive support facilities are required to maintain the diffusion process. The support facilities include administration buildings, a steam plant, electrical switchyards, cooling towers, cleaning and decontamination facilities, water and wastewater treatment plants, fire and security headquarters, maintenance shops, warehouses, and laboratory facilities.

1.0.2 American Centrifuge Plant Program Overview

Following the suspension of development of the Atomic Vapor Laser Isotopic Separation (A VLIS) enrichment technology in June 1999, USEC began an evaluation of centrifuge and other technologies to replace its gaseous diffusion technology. Gaseous diffusion technology requires large amounts of power. These power requirements significantly affect the cost of production of enriched uranium. Since the use of foreign centrifuge technology and other third generation technologies including the Separation of Isotopes by Laser Excitation (SILEX), a laser-based technology under development in Australia, have the potential to lower the cost of production, these alternative enrichment technologies were also investigated. As part of the evaluation, USEC, in partnership with University of Tennessee-Battelle, the operator of DO E's Oak Ridge National Laboratory, undertook to refine gas centrifuge technology under a DOE approved Cooperative Research and Develop Agreement (CRADA).

USEC began design of an improved centrifuge by taking advantage of commercial advances in materials of construction and manufacturing methods. The improved centrifuge technology is intended to achieve performance levels approximately equivalent to those demonstrated in DOE's earlier testing programs, but at a substantially reduced cost.

1-5 Environmental Report for the American Centrifuge Plant Proposed Change April 2022

On June 17, 2002, USEC and the U.S. Government, represented by the DOE, entered into an agreement, which has as one of its fundamental objectives to facilitate the deployment of new, cost effective centrifuge enrichment technology in the U.S. (DOE-USEC Agreement). Assuming successful demonstration of the technology, the DOE-USEC Agreement requires that USEC begin operation of a commercial enrichment plant with annual capacity of 1 million SWU in accordance with certain milestones.

The DOE-USEC Agreement contemplates three steps towards the development of a Commercial Centrifuge Plant, as discussed below. The environmental impacts of the first step, research and development of the centrifuge components (Demonstration Project) in Oak Ridge, were examined in a DOE Environmental Assessment (DOE 2002b) and a Finding of No Significant Impact (FONS!) was issued on October 18, 2002. The environmental impacts of the second step, deployment and system testing through a Lead Cascade Demonstration Facility, were covered in a NRC Environmental Assessment (USEC 2004b) and a FONS I was issued on February 24, 2004. The environmental impacts of an independent third step, a Commercial Centrifuge Plant, are the subject of this ER.

The buildings/facilities and grounds used for this project have been studied and characterized extensively by both the DOE and the Licensee.

Demonstration Proiect

The Demonstration Project demonstrated centrifuge performance in Oak Ridge, Tennessee under DOE regulatory oversight. The standard measure of enrichment in the uranium enrichment industry is the SWU. The Demonstration Project demonstrated that the centrifuge machine design is capable of economically producing 300+ SWU per year. The Demonstration Project verified the integrated centrifuge design while maintaining 300+ SWU per year performance, provided a solid basis for the centrifuge cost estimate, and obtained initial reliability data. The demonstration centrifuges were operated and SWU performance was optimized in highly instrumented test stands in DOE's East Tennessee Technology Park (ETTP) in Oak Ridge, Tennessee. Additional centrifuges were operated in other test stands to evaluate the initial reliability of an integrated centrifuge design. The Demonstration Project ended and final decommissioning efforts were completed in 2019.

American Centrifuge Lead Cascade Dcmonstra.tion Facility

For the Lead Cascade Demonstration Facility, the NRC previously issued a 10 CFR Part 70 license to possess and use special nuclear material. The Lead Cascade Demonstration Facility consisted of up to 240 operating centrifuges at the DOE reservation in Piketon, Ohio. The Lead Cascade Demonstration Facility was a real time demonstration of the basic building block for a gas centrifuge enrichment process in a multiple stage configuration and provided data that is vital to provide reliability, performance, and cost information.

All or part of the centrifuges for the Lead Cascade were manufactured and balanced in Oak Ridge, Tennessee or at the Piketon DOE reservation. Locating the Lead Cascade Demonstration Facility at the DOE reservation required the refurbishment of existing equipment and buildings of the former GCEP. The Lead Cascade operated from 2007 to 2016 and associated releases to air

1-6 Environmental Report for the American Centrifuge Plant Proposed Change A ril 2022

and water, exposure to personnel, and personnel injuries/illnesses were monitored to enable assessment of environmental impacts. Based on this monitoring, it was concluded that operation of the Lead Cascade did not result in any unanticipated releases, discharges, or exposures to the environment, the public, or employees (DP-2605-0001). Decommissioning efforts of the Lead Cascade were completed in 2018.

American Centrifuge Plant

The ACP was the third step in the plan to deploy the American Centrifuge technology. The ACP encompasses the construction, startup, operation, ma intenance, and decommissioning of a uranium enrichment process to produce, as an initial target, 3.8 million SWU per year, potentially expandable to 7.6 million SWU per year, using American Centrifuge technology. The ACP utilizes existing buildings located on the DOE reservation near Piketon, Ohio, that were built to support the gaseous diffusion process beginning in the 1950s and the gaseous centrifuge process beginning in the 1980s, in addition to several newly constructed buildings and facilities.

American Centrifuge technology is modular, with the basic building block of enrichment capacity being a cascade of centrifuges. Information gained and work performed during the Demonstration Project and Lead Cascade included vital information on performance, reliability, and economics that will be used in the final construction of the ACP.

A license application for the ACP was prepared pursuant to the Atomic Energy Act of 1954 as amended, 10 Code of Federal Regulations (CFR) Parts 70, 40, 30, and other applicable laws and regulations. The ACP LEU cascade is designed to enrich and safely contain and handle uranium hexafluoride (UF6) up to 10 weight (wt.) percent 235 U.

The ACP uses portions of the DOE reservation and the former DOE GCEP along with eight new proposed facilities. The ACP utilizes existing utilities and infrastructure that support the DOE reservation including the utilities and infrastructure that were intended to support GCEP. New proposed facilities may be necessary for feed, withdrawal, sampling, and blending/transfer operations. The Licensee has updated the American Centrifuge technology from that used in the GCEP program, but the American Centrifuge components remain compatible with existing infrastructure and facilities.

On October 31, 2019, ACO signed a three year contract with the DOE to deploy a cascade of centrifuges to demonstrate production of high-assay, low-enriched uranium (HALEU) fuel with existing United States origin enrichment technology and provide DOE with HALEU for near term use in its research and development for the advancement of civilian nuclear energy and national security, as well as other programmatic missions. HALEU is a component for advanced nuclear reactor fuel that is not commercially available today and may be required for a number of advanced reactor designs currently under development in both the commercial and government sectors. The program has been under way since the Licensee and DOE signed a preliminary letter agreement on May 31, 2019, which allowed work to begin while the full contract was being finalized.

The Licensee's long-term goal is to resume commercial enrichment production consistent with market demand. It is the intent of the Licensee to deploy portions of the ACP in a modular

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fashion to accommodate market demand on a scalable, economical gradation. This modular deployment will encompass utilization of cascades of LEU production for customer product or feed material into High Assay bow Eruiehed Uranium (HALEU ) cascades. The HALEU cascades will be deployed as part of the DOE's HALEU Demonstration Program which has two primary objectives:

1) Deploy a 16-centrifuge AC-l00M HALEU cascade in the Piketon facility to produce 19.75 percent wt. 235 U enriched product.

2) Demonstration of the capability to produce HALEU.

Results from the operation of the HALEU -demonstration program will be used in preparation of the design for the full-scale ACP facility. The HALED Demonstration will be designed to enrich and safely contain and handle uranium hexafluoride (UF6) up to but less than 20 weight (wt.) percent 235 U. During the process of remediation, construction, infrastructure modification, manufacturing, and test operations for the scope of this ER, the design for these elements are reviewed for compliance with regulatory standards for releases, emissions, and wastes generated and for minimization of the quantity and toxicity of the materials used and wastes generated.

1.1 Purpose and Need for the Proposed Action

Nuclear power generates about 20 percent of the electricity for the United States.

Construction and operation of a gas centrifuge plant utilizing the US-origin advanced technology is key to supporting DOE's national energy security goals by providing a reliable and secure domestic source of enriched uranium. The primary purpose of this action is to allow the Licensee to construct and operate a plant to enrich uranium up to 10 weight (wt.) percent with an initial capacity of approximately 3.8 million SWU expandable to 7.6 million SWU, at the Licensee's option, using advanced U.S. centrifuge technology at the DOE reservation located in Piketon, Ohio.

The gas centrifuge is an enrichment process that increases the concentration of 235 U, the isotope desired for production of nuclear energy. The gas centrifuge process has three inherent characteristics that make it particularly attractive: (1) it is a proven technology ; (2) it has low operating cost; and (3) it is amenable to modular architecture. The low energy requirements of gas centrifuge technology, approximately 5 percent of that required by a comparably-sized Gaseous Diffusion Plant, provide for considerably lower operating costs ( electricity usage comparison shown in Table 1.1-1 ). The modularity of gas centrifuge technology allows for a flexible deployment of enrichment capacity, enabling responsiveness to market demand.

Table 1.1-1 Electricity Usage Estimates

Resource Plant Usage Paducah Usage American Centrifuge 4.6MSWU 7.6MSWU Electricity (megawatt hr) 11,000,000 650,000 (CY 2005 estimate)

1-8 For Information Only Environmental Report for the American Centrifuge Plant Proposed Change April 2022

2.0 ALTERNATIVES

This section describes the alternatives discussed in detail in this ER, as well as those alternatives that were not considered to be reasonable and which were therefore, eliminated from further study. This section also includes a discussion of cumulative effects, as well as a table (Table 2.4 - 1) comparing potential environmental impacts of the Proposed Action, the PGDP Siting Alternative, and the No Action Alternative.

2.1 Detailed Description of the Alternatives

2.1.1 No Action Alternative

This alternative involves not deploying the ACP. This alternative does not meet the need underlined in the Congressional mandate to privatize USEC and provide the nation with an assured source of domestic uranium enrichment capability or the business need for lower cost production and to replace the former GDP. The No Action Alternative is also not consistent with the DOE USEC Agreement. The DOE-USEC Agreement requires the Licensee to deploy an advanced technology enrichment facility.

Other activities on the DOE Reservation will continue, such as the recently constructed depleted uranium hexafluoride (DUF6) Conversion Facility on the reservation adjacent to the ACP, activities related to the D&D of the former PORTS GDP, and environmental restoration activities in a number of locations on the reservation.

2.1.2 Proposed Action

As discussed in section 1.2 above, the Proposed Action is to refurbish, construct and operate the ACP at the DOE reservation in Piketon, Ohio. The purpose of the ACP is to meet the DOE-USEC Agreement requirements for the Licensee to deploy an advanced technology enrichment plant and meet the need for lower cost production and for replacement of the former GDP. D&D of the GDP facilities will continue (DOE 2004b).

C orporate Identity

The Licensee ' s principal office is located at 6903 Rockledge Drive, Bethesda, MD 20817.

Private and institutional investors own the outstanding shares of the Licensee. The principal officers of the Licensee are citizens of the United States.

Proposed Site Location

The DOE reservation is located at latitude 39°00'30" north and longitude 83°00'00" west measured at the center of the DOE reservation on approximately 1,497 ha (3,700 acres) in Pike County, Ohio, one of the state's lesser populated counties. The DOE reservation i s located between Chillicothe and Portsmouth, Ohio, approximately 113 km (70 mi) south of Columbus,

Ohio. Figure 1.0.1-1 shows the regional area surrounding the DOE reservation.

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The DOE reservation consists of approximately 1,497 ha (3,700 acres) with approximately a 526 ha (1,300 acre) central area surrounded by the Perimeter Road. The DOE reservation land outside the Perimeter Road is used for a variety of purposes, including a water treatment plant; lagoons for the process wastewater treatment plant; sanitary and inert landfills; and open and forested buffer areas.

Most of the improvements are located within the fenced core area. The core area is largely devoid of trees, with grass and paved roadways dominating the open space.

The ACP is situated on approximately 81 ha (200 acres) of the southwest quadrant of the Controlled Access Area.

In June 2004, DOE issued a Final Environmental Impact Statement for Construction and Operation of a Depleted Uranium Hexafluoride Conversion Facility at the Portsmouth, Ohio site that described the preferred alternative for managing depleted UF6 (DOE 2004). DOE issued a Record of Decision on July 20, 2004 (DOE 2004c).

In addition, in 2008, DOE constructed a conversion facility at the DOE reservation in Piketon, Ohio, which is currently operated by Mid-America Conversion Services, LLC. The facility converts DOE's inventory of depleted UF6 from the DOE reservation in Piketon, Ohio, and at the ETTP in Oak Ridge, Tennessee, to a more stable chemical form acceptable for transportation, beneficial use/reuse, and/or disposal. A related objective is to provide cylinder surveillance and maintenance of the DOE inventory of depleted UF6, low-enrichment UF6, natural assay UF6, and empty and heel cylinders in a safe and environmentally acceptable manner. The location of the conversion facility is depicted in Figure 3.1-2. The time period considered is an operational period of 18 years, with a 3-year period for D&D of the facility. This assessment is based on the conceptual conversion facility design proposed by the selected contractor, Uranium Disposition Services, LLC (UDS) (DOE 2004).

HALEU Demonstration Program

The initial stage of Uranium Enrichment activities will consist of deploying a 16-centrifuge AC-lO0M HALED cascade to produce 19.75 weight (wt.) percent 235U enriched product as a demonstration project, with enrichment not to exceed 20 wt. percent 235U. On October 31, 2019, the Licensee signed a three yeBf contract with the DOE to operate this prejeef pr grnm. The program has been under way since the Licensee and DOE signed a preliminary letter agreement on May 31, 2019, which allowed work to begin while the full contract was being finalized.

The HALED demonstration program will be similar to, but at a much smaller scale than the full project discussed below. Components for the HALED centrifuges will be manufactured at the Licensee's facilities located in both Piketon, Ohio and Oak Ridge, Tennessee. The project will utilize the four existing facilities recently used in the Lead Cascade Project, and no facilities will be constructed.

The X-3001 Process Building will be used to house the centrifuges and support systems necessary to perform the actual enrichment process, as well as UF6 cylinder receipt and storage.

The X-7725 Recycle/Assembly Building will be used for an area where centrifuges can be

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manufactured, assembled, tested, and maintained. In the HALED Demonstration, the X-7725 building will only be used for temporary storage, heat shield manufacturing shortly before centrifuge assembly, and for interior transport to and from the X-7726 facility. The casings are prepared in the X-7726 facility before being assembled. Some assembly activities may be performed in the X-3001 building including any further preparations of the centrifuges. Areas of the X-7725 building are also designed for shipping, receiving, and storage of materials. The X-7726 Centrifuge Training and Test Facility contains areas where material and components are received; components or subassemblies are inspected and tested; components are manufactured; the components are assembled as centrifuges; casing and component preparation; and the final assembly is evacuated and leak checked. The X-7727H Interplant Transfer Corridor will be used for transport of centrifuges and other materials between the X-7725 building to the process building(s) or back as necessary and movement of feed cylinders. It will also serve as a shipping and receiving area for equipment and components during construction and operation activities.

The X-3012 Process Support Building will be used to house the operational area, maintenance area (For HALED, this is only non-uranium bearing maintenance), and the transfer aisleway that services the X-3002 Process Building.

Design of the full-scale uranium enrichment facilities will be performed after the results of the three year HALED demonstration program have been received.

Full Scale Uranium Enrichment Activities

Under the Proposed Action, refurbishment, construction and operations activities will occur within newly constructed and existing facilities with a production capacity of approximately 3.8 million SWU. This environmental report also examines the impacts of construction of two new process buildings and support facilities that would increase the plant production capacity to approximately 7.6 million SWU annually. Construction of a manufacturing area, process support building, a new withdrawal building, the expansion of the existing feed building and a number of cylinder storage pads are also planned as part of the Proposed Action.

Connected manufacturing/assembly operations may consist of the manufacturing of centrifuge components, assembly and testing of sub-assemblies and assemblies. The option for this manufacturing/assembly process will be an ongoing activity through the production of approximately 12,000 completed centrifuges and sufficient spares to operate a 3.8 million SWU plant and approximately 24,000 centrifuges for the 7.6 million SWU plant. The production rate capability will be developed to ramp up to approximately 16 completed centrifuges per day.

Centrifuge manufacturing could take place on site or at a commercial manufacturing plant located off the DOE reservation. The impacts of manufacturing on the DOE reservation are considered as part of the Proposed Action. The impacts of manufacturing at a commercial manufacturing plant off of the DOE reservation would be similar. Centrifuge manufacturing and assembly operations could be conducted in the X-7725 building or other comparable site building.

The manufacturing/assembly operations consist of the manufacturing of centrifuge components, assembly, and testing of sub-assemblies and assemblies. The manufacturing/assembly process will be an ongoing activity through the production of approximately 24,000 completed centrifuges and sufficient spares to operate a 7.6 million SWU per year plant. Each of the manufacturing/assembly areas has multiple workstations and equipment sets to allow for the

2-3 Enclosure 4 of ACO 22-0042

Proposed Changes for NRC's Materials License for the American Centrifuge Plant SNM-2011

Information Contained Within Does Not Contain E xport Controlled Information Rev iew in g O ffi c ia l : # 1038, AC O

Date: 04 /27/2022 PROPOSED CHANGES April 2022 Pa~e 8 of 12 U.S. NUCLEAR REGULATORY COMMISSION License Number SNM-2011, Amendment 15 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-7004

jncrement ' s construct ion costs. ACO shall 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 the ACP, with the exception of operation of the HA LEU d mon stra tion cascade until expiration of DOE's HALEU Demonstration contract on, shall not commence until the Licensee 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). 31. ~

16. ACO shall provide final copies of the proposed financial assur ce in ments to NRC for review at least six months prior to the planned date for obt

• ing lice n s aterial (except for the sealed source and byproduct material calibration s ces described in L and the HALEU demonstration cascade under the lease ag ement with DOE ending Mll~f't-M~l!il!),

and provide to NRC final executed copies of the r: viewed financial assurance instruments prior to the receipt of licensed material (except i r the sealed source and byproduct material calibration sources described in LC 6 and the ALEU demonstration cascade under the lease agreement with DOE ending, ). The amount of the financial assurance instrument shall be updated to current year dollars and include any applicable changes to the decommissioning cost estimate. The decommissioning cost estimate shall include an update to ACO's Analysis of Depleted Uranium Disposal Costs for the ACP. To develop this update,

ACO shall coordinate with DOE to determine necessary changes to the DOE contractor's depleted uranium cost estimate utilized as input to the ACO specific analysis.

17. The initial and subsequent updated Decommissioning Funding Plan (DFP) cost estimates, up to the time of full capacity operations, and revised funding instruments shall be provided annually and shall provide full funding for decontamination and decommissioning of the full size facility, except:

(1) The cost estimate for decontamination and removal of the centrifuges shall be provided on an annual forward - looking basis based on planned incremental enrichment capacity increases ; and

(2) The cost estimate for depleted uranium byproduct generation shall be provided on a projected annual forward-looking basis. The decommissioning cost estimate shall include an update to ACO's Analysis of Depleted Uranium Disposal Costs for the ACP.

To develop this update, ACO shall coordinate with DOE to determine necessary changes to the DOE contractor's depleted uranium cost estimate utilized as input to the ACO specific analysis.

Once full capacity operation is achieved, the licensee shall provide cost estimates for depleted uranium byproduct generation on an annual forward-looking basis and cost estimates for decontamination and decommissioning the remainder of the facility at Enclosure 5 of ACO 22-0042

DOE Contract #89303519CNE000005, Modification #P00019 for the HALEU Demonstration Program

Information Contained Within Does Not Contain Export Controlled Information Revie win g Offi ci a l : # 10 3 8 ACO

Date: 04 /27/2022 l

AMENDMENTOFSOUCrrATIONIIIOOIACATIONOFCONTRACT 1. CONTRACT ID CODE PAGE OF PAGES 1 2

2. AMENDMENT/MODIFICATION NO. 3. EFFECTIVE DATE 4. REQUtSlTION/PURCHASE REQ. NO. S. PROJECT NO. (If applcsble)

P00019 See Block 16C 5.15SUEOBY CODE 893035 7. ADMINISlERED BY (If olht,r I/Jan 1111m 11) CODE 03011 EM-Oak Ridge OREM EMCBC U.S. Department of Energy U.S. Department of Energy Oak Ridge 200 Administration Road Office of Environmental Management Oak Ridge TN 3 '1831 P.O. Box 2001 Oak Ridge TN 37831

8. NALE ANO ADDRESS OF CONTRACTOR(No.,--. <<->ty, --.I ZIPCode) (X) IIA.. AMENDMENT OF SOLICITATION NO.

American Centrifuge Operating, LLC Attn: Charles Kerner 98. DA.TED (SEE rrat ff) 6901 Rockledge Dr Ste 800 Bethesda MD 208171867 X 10A. MOOIACATION OF CONTRACT/ORDER NO.

89303519CNE000005

108. DATED (SEE ITEM 13)

CODE 079679750 FACLITY CODE 05/31/2019 0 The above numbered eollcitatlon is~ as 581 fof1h In lem 14. Thll hour and dale speclled for receipt of Olkn O II axtanded. D Is not utanded.

Offerw ml.Ill acknowledge nooeipl of this amendmant prior to the hour and dalll specified in the 9Dlicilalion or as Ma1dad, by one of the falowing malhals: (11) By mmplaling Items 8 and 15,.-id ratumill ____ ooplea~lhe amendment (b) By aclcuowla,~,g receipt dtt.. amendrT.,t on -.:t, copy oflha offel...,,..lbed; or (c) By aeparam leltar or elactronic CO!Tlll'Ullcalion wNch indudes a reference to the aolicitation and """"1dll1Mll.....-. FAILURE OF YOUR ACKNOWLEDGEMENT TO BE RECEIVED AT THE PLACE DESIGNATED FOR THE RECBPT Of OFFERS PRIOR TO THE HOUR AND DATE SPECIFED MAY RESULT IN REJECTION OF YOUR OFFER. If by virtue of tlis IWll&l lllrnant yw desire lo c:harcJe an offer allaady submitlwd, sud1 change may boo macS. by letter c, eloclroric oommuniclltim, p,t>YUO<J each letter or efeclronlc communication rnakee rafarenco to lhe aoldtatlon f"d ttia amendment. and Is received pior 1D Iha opemq hcu and dale apeclled.

12. ACCOUNTING AND APPROPRIATION DATA (If requ"8d)

See Schedule

13. lli ITEM ONLY APPUEll 10 IIODIFICATION OF CONTRACTS/ORDERS. rT IIODIFIEI TIE CONTRACTJORDER NO. M DEaCRBED II ITDI 14.

CtECKONE A. THIS CHANGE ORDER IS ISSUED PURSUANT TO: (Specify authorly} THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN Tl£ CONTRACT X FAR 52.217-8 0 tion to Extend Services ORDER NO. IN ITEM 10A.

B. THE ABOVE NUMBERED CONTRA.CT/ORDER approplfalloo dela, efl;.} SET FORTI-I IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR43.103(b). IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (6Udl aschangn in paying olfloe,

C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF:

.0 (S/HICIY 1)1)6 of mod/flt"1lion

E. IMPORTANT: Contractor Dis not 00 is requiNld to sign lhis document and return _____ 1 __ oopiee 1o lhe iuui~ office.

14. DESCRIPTION OF AMENDMENllMOOIFlCATION (Organiz.ed by UCF section heecfngs. includlng l!Oli:ilaronitonfnlct subject mBll8r whete feasible.)

DUNS Number: 079679750 UEI: L8VHV5CNBV97 The purpose of this modification is to extend the period of performance from 31 May 2022 to 30 Nov 2022 in order to facilitate a six month extension to the NRC license. Under the authority of FAR 52.217-8, Option to Extend Services. The Contract per i od of performance is hereby extended from 31 May 2022 to 30 November 2022, however the contractor is not authorizied to pe r form work beyond 31 August 2022, unless a ut horized by the CO beyond that date. All other terms and conditions and conditions remain i n full force and effect.

Continued...

Except** prOYided ho..,;n, al tarma and cond~ of the document -need 1n 110m 9 A or 10A. 111 - changed. remains...manged and In fl.a force end ell'ect.

15A. NAME ANO TITLE OF SIGNER (Type or prtn1J 111A. NAME AND TITLE OF CONTRACllNG OFRCER fTW-or pri,rt)

Jeffrey C. Fogg

188. UNITED STATES OF AMERICA ~ J fig Ye' * -:;:;__ e rey. ogg bATE SIGNED r CJ r1 Date : 202.04.25

---

'~6 :28:52- '00'

Pnwious edition IRlll8ble STANDARD FORM 30 (REV. 11/2016)

Preectlbed by GSA FAR (40 CFR) 53.243 REFERENCE NO. OF DOCUMENT BEING CONTINlED CONTINUATION SHEET 89303519CNE000005/P00019 2

NAME OF OFFEROR OR CONTRACTOR American Centrifuge Operating, LLC

ITEM NO. SUPPllESISERVICES QUANTITY UNIT UNITPRICE AMOUNT (A) (Bl. (C) D) (E) (F)

Payment:

VIPERS https://vipers.doe.gov Any questions, please contact by call/email 855-384-7377 or VipersSupport@hq.doe.gov Period of Performance: 05/31/2019 to 11/30/2022

NSN 754<M>1-152-l!087 OPTIONAL FORM 338 (4-16)

Spomon,d by GSA f/\\ltf-411 Cfft) 53.110