ML24054A033

American Centrifuge Plant - Supplement to License Amendment Request for American Centrifuge Operating, LLCs License Application for the American Centrifuge Plant - EPID L-2023-LLA-0024

ML24054A033
Person / Time
Site:	07007004
Issue date:	02/15/2024
From:	Karen Fitch American Centrifuge Operating
To:	John Lubinski Office of Nuclear Material Safety and Safeguards
References
ACO 24-0019, EPID L-2023-LLA-0024
Download: ML24054A033 (5)

Text

February 15, 2024 ACO 24-0019 CUI// SP-SGI I SP-EXPT I SP-SRI// NOFORN Safeguards Information Export Controlled Information Security-Related Information - Withhold Under 10 CFR 2.390 ATTN: Document Control Desk John W. Lubinski, Director Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 American.Centrifuge Plant; Docket Number 70-7004; License Number SNM-2011 Supplement to License Amendment Request for American Centrifuge Operating, LLC's License Application for the American Centrifuge Plant - EPID L-2023-LLA-0024 INFORMATION TRANSMITTED HEREWITH IS PROTECTED FROM PUBLIC DISCLOSURE AS SAFEGUARDS INFORMATION PURSUANT TO 10 CFR 73.22; SECURITY-RELATED INFORMATION PURSUANT TO 10 CFR 2.390; AND AS EXPORT CONTROLLED INFORMATION PUSUANT TO 10 CFR PART 810

Dear John Lubinski:

The purpose of this letter is to pmvide supplemental proposed. changes to the U.S. Nuclear Regulatory Commission (NRC) for continued review and approval to address a request for additional information (RAI) related to American Centrifuge Operating, LLC's (ACO) License Amendment Request (Reference 1 ). Multiple discussions have occurred with NRC staff since November 2023 (References 2-6) related to the physical security aspects of Phase II under the High-Assay Low-Enriched Uranium (HALED) operations contract.

On January 19, 2024 (Reference 5), the NRC issued the formal RAI.

ACO's response to this RAI is being provided as Enclosure 1 ofthis letter. Enclosure 2 provides the related proposed changes to SP-3605-0042, Security Plan for the Physical Protection of Special Nuclear Material at the American Centrifuge Plant. Additionally, ACO is proposing to add a new license condition into LA-3605-0001, License Application for the American Centrifuge Plant, which is provided within Enclosure 3 ofthis letter.

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

• Safeguards Information Export Controlled Information Security-Related Information - Withhold Under 10 CFR 2.390 When separated from Enclosures 1 and 2, this cover letter and Enclosure 3 is uncontrolled.

American Centrifuge Operating, LLC 3930 U.S. Route 23 South - P.O. Box 628 Piketon, OH 45661 306 I

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John W. Lubinski February 15, 2024 ACO 24-0019, Page 2 CUI// SP-SGI / SP-EXPT / SP-SRI// NOFORN Safeguards Information

• Export Controlled Information Security-Related Information ~ Withhold Under 10 CFR 2.390 contains Security-Related Information; therefore, ACO requests this enclosure_ be withheld from public disclosure pursuant to 10 CFR 2.390(d)(l). Enclosure 2 contains Safeguards Information and ACO requests this enclosure be withheld from public disclosure and protected pursuant to 10 CFR 73.22. Additionally, Enclosure 2 has also been determined, in accordance with the guidance provided by the U.S. Department of Energy, to contain Export Controlled Information and must be protected from disclosure per the requirements of 10 CFR Part 810.

ACO respectfully requests NRC's review and approval of the Phase II+ amendment by May 1, 2024, to support continued operations.

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

Enclosures:

As stated

References:

Sincerely, l~:J--41~

Kelly L. Fitch Regulatory Manager

1. ACO 23-0006 from K.L. Fitch to J. Lubinski (NRC) regarding License Amendment Request for American Centrifuge Operating, LLC's License Application for the American Centrifuge Plant dated February 13, 2023

2. NRC Internal Memo from Y.H. Paraz to S. Lav regarding Summary of November 15, 2023, Telephone Call with Centrus-American Centrifuge Operating, LLC Regarding Physical Security of Special Nuclear Material at the American Centrifuge Plant in Piketon, Ohio, dated January 18, 2024

3. NRC Internal Memo from Y.H. Paraz to S. Lav regarding Summary of November 15, 2023, Telephone Call with Centrus-American Centrifuge Operating, LLC Regarding Physical Security of Special Nuclear Material at the American Centrifuge Plant in Piketon, Ohio, dated January 18, 2024 Document/matter transmitted contains CUI// SP-SGI / SP-EXPT /SP-SRI// NOFORN Safeguards Information Export Controlled Information Security-Related Information - Withhold Under 10 CFR 2.390 When separated from Enclosures 1 and 2, this cover letter and Enclosure 3 are uncontrolled.

CUI// SP-SGI I SP-EXPT I SP-SRI II NOFORN Safeguards Information Export Controlled Information Security-Related Information - Withhold Under 10 CFR 2.390 John W. Lubinski February 15, 2024 ACO 24-0019, Page 3

4. NRC Telephone Conference Secure Call Summary regarding American Centrifuge Operating's Request for Clarifications, dated November 28, 2023

5. NRC Internal Memo from Y.H. Faraz to S. Lav regarding Summary of December 18, 2023, Telephone Call with Centrus-American Centrifuge Operating, LLC Regarding Draft Request for Additional Information for Physical Security of Special Nuclear Material, dated January 19, 2024

6. NRC Internal Memo from Y.H. Faraz to S. Lav regarding Summary of January 17, 2024, Telephone Call with Ceiltrus-American Centrifuge Operating, LLC Regarding Draft RAI for Physical Security Phase II+ Application, dated January 31, 2024 cc (without enclosures, unless otherwise noted):

C. Blanton, DOE Idaho S. Bazian, NRC HQ Y. Faraz, NRC HQ (Enclosures)

A. Ford, DOE Idaho T. Harris~ NRC HQ (Enclosures)

J. Hutson, Contractor J. Lingard, DOE Idaho L. Pitts, NRC Region II (Enclosures)

M. Reim, DOE-NE R. Ruppert, NRC HQ J. Tobin, NRC HQ D. Woodyatt, NRC HQ Document/matter transmitted contains CUI// SP-SGI / SP-EXPT /SP-SRI// NOFORN Safeguards Information Export Controlled Information Security-Related Information - Withhold Under 10 CFR 2.390 When separated from Enclosures 1 and 2, this cover letter and Enclosure 3 are uncontrolled.

to ACO 24-0019 Proposed Changes for LA-3605-0001, License Application for the American Centrifuge Plant Information contained within DOES NOT CONTAIN Export Controlled Information Reviewer: Lori Hawk/ ACO Date: 02/12/2024

License Application for the American Centrifuge Plant Proposed Change 1.2.6 Security of Classified Information February 2024 The Licensee is required by 10 CFR 70.22(m) to submit, as part of its application for a license for the ACP, a plan describing the plant's proposed security procedures and controls, as set forth in 10 CFR Part 95, for the protection of classified matter. The Licensee satisfies the 10 CFR 70.22(m) requirements by submittal of the Security Plan for the Protection of Classified Matter at the American Centrifuge Plant. The Security Plan was submitted for NRC review along with this license application.

1.2.7 Security of Special Nuclear Material of Low Strategic Significance and Moderate Strategic Significance Pursuant to 10 CFR 70.22(k) the Licensee is submitting, as part of its application for a license for the ACP, a plan describing the measures used to protect Special Nuclear Material of Strategic Significance that the Licensee uses, possesses, or has access to at the plant. The Licensee satisfies the 10 CFR 70.22(k) requirement by submittal of the Security Plan for the Physical Protection of Special Nuclear Material at the American Centrifuge Plant. Consistent with NRC Regulatory Guide 5.52, Standard Format and Content for a Licensee Physical Protection Plan for Strategic Special Nuclear Material at Fixed Sites, Revision 3, 1994, the Security Plan was submitted for NRC review along with this license application.

The Licensee proposes that the license be conditioned as follows:

ACO shall not produce more than the authorized possession limits beyond those approved on June 11,2021 (SNM-2011, Amendment 19), until such time that the additional physical security measures have been installed and NRC has confirmed they meet the new commitments described within Section 3.7 of SP-3605-0042. Upon a successful NRC validation, ACO will be authorized to continue production efforts up to the approved Phase II+ possession limits. take possession of Category II quantities of SNM or commence Category II SNM product vi'ithdrav,,al and storage under the HA.LEU operations contract until such time that the required Category II physical security and material control and accountability operational readiness reviev,'s (ORRs) by the l>JRC have been completed and AGO has demonstrated adequate compliance with }JR{; requirements for possessing Category II SNM.

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