ML24366A038

Enclosure 1: Detailed Description, Justification, and Significance Determination

ML24366A038
Person / Time
Site:	07007004
Issue date:	12/19/2024
From:	American Centrifuge Operating
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML24366A069	List: ML24366A038 ML24366A040 ML24366A041 ML24366A043 ML24366A045
References
ACO 24-0108
Download: ML24366A038 (1)

Text

Enclosure 1 of ACO 24-0108 Detailed Description, Justification, and Significance Determination Information Contained Within Does Not Contain Export Controlled Information Reviewing Official:

Lori A. Hawk, ACO Date:

12/ 18/2024 ACO 24-0108 Page 1 of 11 Detailed Description, Justification, and Significance Determination Detailed Description of Change On September 30, 2024, the U.S. Department of Energy (DOE) provided preliminary notification of intention to exercise Phase Ill - option period I (CUN 00003) of the High Assay Low Enriched Uranium (HALEU) Demonstration Cascade Completion and HALEU Production Contract (Contract Number 89243223CNE000030) from July 1, 2025, to June 30, 2028. This option period, along with the other two option periods, will be funded as outlined in the HALEU Contract for Phase III operations, and are at DOE's sole discretion and subject to the availability of Congressional appropriations. Therefore, American Centrifuge Operating, LLC (ACO) commits to submit to the U.S. Nuclear Regulatory Commission (NRC), the amended contract, funding each of the option periods (1, 2, and 3) of Phase III upon receipt from the DOE.

ACO proposes to amend the licensing documents to I) increase the possession limits supporting the continuation of all three option periods under Phase III to meet the Licensee's planned production needs for a minimum of900 kgs of HA LEU per year to a nominal 19.75 weight percent 235U; 2) clarify administrative descriptions for the newest parameters of the HAL EU Contract and lease to support Phase Ill operations; and 3) revise the dates associated with the reference to Centrus' Annual Report Form 10-K. The proposed changes to the licensing documents are as follows:

• contains proposed changes to LA-3605-0001, License Application for the American Centrifuge Plant, specifically the Inside Cover, Updated List of Effective Pages, and Sections 1.1.8.1, 1.1.8.2, 1.1.8.4, 1.2.2, 1.2.5, 10.1, and I 0.2.

• contains proposed changes to LA-3605-0002, Environmental Report for the American Centrifuge Plant, specifically, the Inside Cover, Updated List of Effective Pages, and Section 1.0.2.

• contains proposed changes to Appendix D of LA-3605-000 I, specifically, the possession limits for Types A and C contained within Table 1.2-2, HALEU Demonstration Program Possession Limits for NRC Regulated Materials and Substances.

• contains proposed changes to NRC's Materials License SNM-20 I 1, specifically, the possession limits for Types A, C, and D for the HALEU Demonstration Program Possession Limits described under Condition 8a.

• contains proposed changes to LA-3605-0003, Integrated Safety Analysis Summary for the American Centrifuge Plant, (ISA Summary) specifically, the Inside Cover, Updated List of Effective Pages, and Section 3.1.

• contains proposed changes to NR-3605-0005, Fundamental Nuclear Material Control Plan for the American Centrifuge Plant, (FNMCP) specifically, the Inside Cover, Updated List of Effective Pages, and Section 1.1. Additionally, general formatting of the withholding categories shown within the headers and footers of the entire document have ACO 24-0108 Page 2 of 11 been made to be consistent with procedure requirements. However, the entire plan is not being submitted for prior review and approval for this administrative change to the header and footer. The pages provided will depict this overall document change.

• contains proposed changes to SP-3605-0041, Secur;ty Plan for the Protection of Classified Matter at the Amer;can Centrifuge Plant ;n P;keton, Ohio, specifically, Section 1.2.2.

• contains proposed changes to SP-3605-0042, Security Plan for the Protection of Special Nuclear Material at the American Centrifuge Plant in Piketon, Ohio, specifically, the Inside Cover, Updated List of Effective Pages, and Section 1.0.

For completeness, general formatting and grammatical corrections are also included within the proposed changes. The proposed changes contained within Enclosures 2 through 9 are identified by the following method:

Blue Strikeout - Identifies text to be removed Red underline - Identifies text to be added Yellow highlighted information identifies text incorporated from the Phase ll+ Extension Amendment Request [EPID L-2024-LLA-0131] (ACO 24-0070 dated September 12, 2024; ACO 24-0090 dated November 7, 2024; and ACO 24-0093 dated November 21, 2024) that is anticipated to receive NRC approval on or before December 31, 2024.

Gray highlighted information identifies text incorporated from NRC's approval on September 20, 2024 [ML24068A194 Pkg A 189] Amendment 24 that is pending implementation by the Licensee.

Justification Ln accordance with l O Code of Federal Regulations (CFR) 70.34 and 70.65, the proposed changes previously discussed, require the NRC's prior review and approval. The proposed changes increase the possession limits to support continued HALEU operations through all three of the 3-year option periods of Phase Ill [nine years total] as defined in DO E's HALEU Contract to meet the production milestones through June 30, 2034. There are no changes being made to the HALEU cascade process descriptions, number of planned operating centrifuges, or Special Nuclear Material/Tai Is storage capacities as previously approved by the NRC. However, there were other description clarifications that are administrative in nature and also included within this amendment.

The proposed changes will not decrease the ability of the management measures in the License Application to ensure the availability and reliability of Items Relied on for Safety (IROFS). The proposed changes do not decrease the effectiveness of the design basis as described in the License Application, nor result in a departure from a method of evaluation described in the License ACO 24-0108 Page 3 of 11 Application used in establishing the design bases for the evaluation of HALEU Demonstration Criticality Events. Therefore, the proposed changes do not result in a degradation of safety, nor have an adverse effect on compliance with applicable regulatory requirements.

Financial Qualifications Determination The November 2022 award included a $30 million cost share during the first year to start up and operate 16 advanced centrifuges in a cascade at ACO's Piketon, Ohio enrichment facility. The contract is a performance-based contract that includes cost-shared no-fee contract line-item numbers (CLINs) and cost-plus-incentive-fee CLINs.

This performance-based contract has three phases. Phase I comprising of one CUN, was awarded on a cost-reimbursement no-fee basis with a minimum of a 50 percent cost share requirement.

Only Phase I shall be priced in accordance with the clause at Federal Acquisition Regulation (FAR) 52.216-12, Cost-Sharing Contract-No Fee. Phase H was awarded on a cost-plus incentive fee (see FAR 52.216-10) basis. After completion of the base contract (Phases 1 and II ending on June 30, 2025), the contract allows DOE to enter a Phase III, which could exercise up to three three-year option periods at a minimum production level of 900 kilograms HALEU per year. Each of these three option periods are structured on a cost-plus incentive fee basis for continued HALEU production. Annual Congressional appropriations will inform the duration of the contract based on the availability of funding.

Following the HALEU Operations contract, the centrifuge technology used at the facility will be available for commercial deployment.

Additionally, Centrus' Annual Report on Form 10-K, filing date of February 9, 2024, for the fiscal year ended December 31, 2023, provides the Licensee's ability to meet the financial contractual requirements defined in the HALEU contract. 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.

Decommissioning Determination Based Upon Gas Centrifuge Enrichment Plant (GCEP)

Lease Agreement Amendment 3 to the Appendix I Lease Agreement Between the U.S. Department of Energy and United States Enrichment Corporation for the Gas Centrifuge Enrichment Plant (GCEP) Lease Agreement, provided by letter ACO 22-0083 regarding Submittal of Reference Material in Support of License Amendment Request for the American Centrifuge Plant, dated December 8, 2022, supports continuation of the HALEU contract under Phases If and III production capabilities.

The DOE continues to assume all liabilities for the decontamination and decommissioning of the facilities and equipment installed, and any work performed, under the HALEU contract with the DOE including any materials or environmental hazards on the site. No financial assurance for any liability or lease turnover conditions shall be required by the Licensee. Likewise, any liabilities of the Licensee arising from or incident to the performance of work under the HA LEU Operations Contract with the DOE shall be governed solely by such contract and any financial protection afforded to the Licensee as a person indemnified under the Act.

Environmental Impact Determination ACO 24-0108 Page 4 of 11 On June 4, 2021, the NRC issued the Environmental Assessment for the Proposed Amendment of US. Nuclear Regulatory Commission License Number SNM-201 I for the American Centrifuge in Piketon, Ohio [ML21085A705], which provided for the conclusion and finding of no significant impact (FONSI) for the HALEU Demonstration Program. The basis for this FONSI is the proposed action was not expected to result in new construction, and that the HALEU cascade would be assembled and operated in existing buildings that previously housed a similar system under the American Centrifuge Lead Cascade Facility license. These facts remain unchanged.

On September I 0, 2024, the N RC issued the Environmental Assessment for Proposed License Amendment to Increase the Possession Limits for Licensed Material for the HALEU Program at the American Centrifuge Plant in Piketon, Ohio [ML2425A206], which provided for the conclusion and FONS!. The basis for this FONS! is the proposed action would not result in new construction or ground disturbance, would not result in significant differences in the amounts of effluents or emissions generated, and would not significantly affect any resource area. The production of HALEU UF6 would continue in the HALEU operations building, and the storage would continue onsite. These facts also remain unchanged.

As described within the license application (LA-3605-0001) and environmental report (LA-3605-0002), ACO operates the HALEU cascade (16 centrifuges) within the leased footprint of the previously regulated, now decommissioned, American Centrifuge Lead Cascade Facility. Final construction efforts to build out the HA LEU cascade were completed under Phase I of the DOE contract. Following the NRC's authorization to introduce uranium hexafluoride (UF6) into the HALEU cascade on June 12, 2023 [ML23163A168], ACO began HALEU cascade operations under Phase II, which included the storage of feed, tails, and HA LEU for the DOE. In February 2023 [ML23047A046], ACO requested an increase in the possession limits supporting the entire Phase II operations. In September 2024 [ML24254A206], the NRC issued an Environmental Assessment that evaluated this increase of the authorized limits for possession of licensed material (uranium) to support HALEU production.

Resources Not Affected by the Proposed Changes The proposed substantial change being evaluated under this amendment is another increase in the possession limits to support continued HA LEU operations through all three of the 3-year option periods of Phase III [nine years total] as defined in DO E's HALEU Contract to meet the production milestones through June 30, 2034. There are no changes being made to the HALEU cascade design or process descriptions; the number of planned operating centrifuges; or the current storage capacities just recently approved by the NRC [ML24324A357 Pkg A356]. HALEU operations, including storage of additional wastes, will continue to be performed within currently leased buildings by existing staff in Piketon, OH. Additionally, ACO does not propose to construct new buildings, conduct ground-disturbing activities, or ship HALEU offsite. Based upon the above discussion, ACO's proposed change to increase the possession limits does not pose an impact on the following resources: land use; historic and cultural; visual and scenic; climate; geology and soils; water resources; ecological resources; socioeconomics; environmental justice; noise; or public health and safety as previously evaluated under the 2024 Increased Possession Limits ACO 24-0108 Page 5 of 11

[ML24254A206]. The following discussions provide the determination of no significant impacts on the remaining five resources.

Resources Affected by the Proposed Changes Air Quality: The HALEU cascade operates within existing buildings with concrete floors, along with being enclosed with fencing and gates. The major non-radiological hazardous air emissions associated with the HA LEU cascade are from hydrogen fluoride (HF), which is a byproduct of the enrichment process that uses fluorine and low enriched uranium (feed) to produce HALEU UF6.

The HALEU cascade operations may result in negligible (minimal) increase in HF concentrations.

As stated within the 2021 Environmental Assessment, the annual average HF concentration for the HALEU cascade was calculated to be 0.00227 micrograms per cubic meter (m3) at the location of the maximally exposed individual. For the period between July and December 2023, the average HF concentration for the maximally exposed individual was 4.8 E-9 micrograms/m3. For the period between January and June 30, 2024, the average HF concentration for the maximally exposed individual was 2.40 E-07 micrograms/m3.

Vent Emissions Basic Summary from current operations of the HALEU cascade are provided below:

78,821, 160 standard cubic feet for the total vent flow from August 2023 to December 2, 2024 July - December 2023 Public Dose due to Gaseous Effluents 1.3 E-06 mrem January - June 2024 Public Dose due to Gaseous Effluents 1.6 E-05 mrem Data not yet available for the second half of calendar year 2024 As stated within Section 4.6.3.1 of the Environmental Report (LA-3605-0002), diesel generators would be used to maintain power to essential systems in the event normal power is lost or interrupted, and ACO estimates it would operate the diesel generators for less than 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> per year for the HALEU cascade. The increase in possession limits will not affect this estimate.

Because of their intermittent use, the impact of diesel generators on non-radiological air quality would be insignificant.

Transportation: Section 4.2.3.2.1.2 of LA-3605-0002, Environmental Report for the American Centrifuge Plant, states in part "The Tails material from HALEU will be stored onsite in 12-series cylinders. Currently, there are no plans for shipment of HALEU Demonstration Tails Material.

The product material from the HALEU demonstration will be stored onsite in 5-series cylinders.

Currently, there are no plans for shipment of HALEU Demonstration product material." The are no changes to the number of operating or spare centrifuges, the only shipments that will occur as a result of the proposed increase in the possession limits would be the additional shipment of feed material needed to support the production levels (i.e., approximately two 30B feed cylinders per year). For the HALEU cascade, ACO receives a very small fraction of the estimated I, 100 yearly feed shipments for the commercial ACP. Therefore, operation of the HALEU cascade for this additional nine-year period will not pose any significant transportation impacts related to feed ACO 24-0108 Page 6 of 11 shipments.

Additionally, the DOE contract does not allow for the shipment of product or tails; therefore, these cylinders are securely stored inside the building. ACO has assessed that the transportation impacts of the proposed increase in possession limits would not be significant and are bounded by the impacts previously assessed in the 2021 HALEU cascade Environmental Assessment.

Occupational Health and Safety:

Non-Radiological Impacts:

As stated within the Environmental Report (LA-3605-0002), for operation of the HALEU cascade, environmental monitoring of chemical parameters is required by state and federal regulations and/or permits. Exposures to chemical agents are controlled by administrative and engineering methods and/or personal protective equipment.

Extremely hazardous substances, such as fluorine or HF, are stored and used in accordance with state regulations and permits. ACO takes precautions to avoid impacts from accidental discharges of fuel, waste, and sewage. These precautions include the use of spill response plans, safety procedures, spill controls, countermeasure plans, and spill response equipment (in accordance with federal and state laws) that would minimize the likelihood and severity of potential impacts from accidental discharges. HF emissions resulting from the proposed increase in possession limits would likely not be detectably different from the current HF emissions; therefore, the potential non-radiological impacts on workers from the proposed increase in possession limits would not be significant.

Radiological Impacts: The increase in possession limits does not result in any significant change in effluents released offsite or any significant increase in individual or cumulative occupational radiation exposure.

The effluents released would be proportional to the production level (centrifuges in use) rather than the possession limit itself. The existing process building exhaust vent remains unchanged and supports this increase in possession limits. Therefore, ACO has assessed there is no change in the type or significant increases in the amounts of effluents that may be released off-site for Phase III operations.

ACO began operating the HAL EU cascade in August 2023 and continues operations to date. ACO has been collecting and submitting an effluent monitoring report for these HALEU activities. For the period of July 1, 2023, through December 31, 2023, ACO' s total exposure to the nearest resident was 3.49 El0-06 millirem [ML24072A044]. The total release data for this same reporting period is as follows:

Radionuclide Total Gaseous Releases Total Liquid Releases Unit of Measure 234u 2.40 E-03 6.04 E-02 milliCurie (mCi) 23su 4.75 E-04 2.30 E-03 mCi 23su 7.56 E-04 3.47 E-02 mCi 99Tc 0.00 E+00 0.00 E+00 mCi 99Tc lab results were undetectable.

ACO 24-0108 Page 7 of 11 For the period of January l, 2024, through June 30, 2024, ACO's public dose due to gaseous effluents was 1.6 x E-05 millirem [ML24253A175]. The total release data for this same reporting period is as follows:

Radionuclide Total Gaseous Releases Total Li ui d Releases Unit of Measure 234u 8.94 E -03 1.30 E -0 l milliCurie (mCi) 23su 1.10 E -03 5.47 E -03 mCi 23su 8.75 E -03 9.08 E -02 mCi 99Tc 0.00 E +00 0.00 E +00 mCi 99Tc lab results were undetectable.

As shown above, the total release data is well below ACO's As Low As Reasonably Achievable goals for both airborne and waterborne radioactive releases as committed within Chapter 9 of LA-3605-0001, License Application for the American Centrifuge Plant. The proposed increase in possession limits would not affect the rate of production and would not result in any greater radiological air emissions than those described above. Therefore, ACO has assessed that the radiological air emissions impacts from the increase in possession limits would not be significant.

Impacts from Accidents: The events presented within LA-3605-0003A, Addendum 1 of the Integrated Safety Analysis Summary for the American Centrifuge Plant - HALEU Demonstration, are consequence based. These consequences are based on a hypothetical maximum inventory for HALEU Demonstration. This inventory is not based on any specific time periods or duration and is significantly greater than the current (and likely any future) possession limits specified in the Materials License. The increase in possession limits remain significantly less than the values analyzed and LA-3605-0003A is conservative and bounding.

Additionally, ACO's ISA Summary documentation (LA-3605-0003 and LA-3605-0003A),

demonstrate comp I iance with the performance requirements in IO CFR 70.61 to I im it the risk of credible high-and intermediate consequence accident sequences, including nuclear criticality accidents. This proposed change does not create any new types of accident sequences that, unless mitigated or prevented, would exceed the performance requirements of 10 CFR 70.61 and that have not been described in the ISA Summary documentation (LA-3605-0003 or LA-3605-0003A).

Waste Management:

The bulk of the waste (i.e., low-level waste) is personnel protective equipment and other non-fissile waste generated in routine maintenance and operations. Based upon the current waste generation rate, it is estimated that seven B-25 boxes would be generated per each three-year option period of Phase 111, meaning a total of approximately 2 I B-25 boxes over the nine-year period. Additionally, these waste containers are stored inside the process building. This radiological waste estimate does not take into consideration any potential decontamination or decommissioning of centrifuges, service modules, or other parts of the process as this is the responsibility of the DOE.

As discussed in Chapter 9.0 of the License Application (LA-3605-0001 ), onsite sanitary wastewater is treated by a DOE contractor at the DOE reservation and other wastes are managed using existing DOE sitewide services. DOE is also responsible for the management and disposal of low-level radioactive waste from the HALEU cascade operation. Waste is collected, packaged, ACO 24-0108 Page 8 of 11 and segregated for off-reservation disposal or treatment in accordance with applicable State and Federal regulations.

Based upon the above, ACO concludes that the impacts of waste management associated with the proposed increase in possession limits would not be significant and are bounded by the impacts previously assessed by the NRC in the 2021 Environmental Assessment.

Cumulative Effects: As previously stated within the 2021 Environmental Assessment, the NRC found that the construction and operation of the HALEU cascade would not have a significant incremental impact and, when added to the effects of other past, present, or reasonably foreseeable future actions in this area, would not result in significant cumulative effects except for a potential increase in air emissions (e.g., dust and heavy equipment emissions) during construction of the full ACP, when built. As ofNovember 8, 2024, the NRC terminated the Materials License (SNM-7003) [EPID L-2023-LLA-0159] for the American Centrifuge Lead Cascade Facility, thereby, eliminating any future cumulative effects from this license.

The increase in possession limits of licensed material would result in a very small increase in the amount of waste and tails material to be managed in comparison to the full commercial ACP; therefore, ACO has assessed the incremental effects of this proposed possession limit increase would be minor as to not change the cumulative effects conclusions presented in the NRC's 2021 Environmental Assessment.

Based upon the above discussions, ACO has assessed that the proposed change to increase the possession limits of licensed material through the end of the DOE contract to support production and onsite storage would not significantly affect the quality of the human environment. Therefore, this conclusion supports a finding of no significant impact as defined under 10 CFR 51.32.

Additionally, ACO has assessed that the proposed amendment to increase the possession limits for Phase III of the HA LEU Operations is bound by NRC's Environmental Assessment for Proposed License Amendment to Increase Possession Limits for Licensed Materials for the HALEU Program at the American Centrifuge Plant in Piketon, Ohio [ML2425A206].

Significance Determination for Proposed Conforming Changes The substantive change being proposed for review and approval is the increase in the possession limits supporting the continuation of all three 3-year option periods under Phase III, meeting the Licensee's planned production needs for a minimum of 900 kgs of HA LEU per year to a nominal 19.75 weight percent 235U. The clarifications in Phase Ill and lease descriptions are administrative in nature to capture the newest parameters of the HAL EU Contract supporting Phase III continued operations. There are no changes being made to the HALEU cascade process descriptions, number of planned operating centrifuges, or Special Nuclear Material/Tails storage capacities as previously approved by the NRC. ACO has reviewed the proposed changes and provides the following Significance Determination.

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

ACO 24-0108 Page 9 of 11 The proposed changes to increase the possession limits and clarify descriptions of Phase Ifl and the lease are not prohibited by 10 CFR Part 70, license condition, or order. However, Materials License SNM-2011, Conditions 6a, 7a, and 8a are being modified to make a corresponding possession limit increases to support continued operations during Phase III through the end of the DOE HALEU contract. No other License Conditions are impacted by this amendment.

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

The proposed changes being made to the ACP Integrated Safety Analysis (ISA) Summary (LA-3605-0003) are administrative in nature to clarify Phase Ill. These proposed changes do not remove or change an IROFS that is listed in LA-3605-0003 or LA-3605-0003A.

Additionally, the proposed changes do not alter any IROFS listed in the LA-3605-0003 or LA-3605-0003A, 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 events presented within Addendum 1 of the Integrated Safety Analysis (ISA) Summary (LA-3605-0003A) are consequence based. These consequences are based on a hypothetical maximum inventory for HALEU Demonstration. This inventory is not based on any specific time periods or duration and is significantly greater than the current (and likely any future) possession limits specified in the Materials License. The increase in possession limits remain significantly less than the values analyzed and LA-3605-0003A is conservative and bounding.

Therefore, the increase in the possession limits will not alter the design or performance of an item or activity as described in ACP lSA Summary (LA-3605-0003) or LA-3605-0003A.

Additionally, the proposed changes do not create any 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 LA-3605-0003 or LA-3605-0003A.

4. No significant reduction in the margins of safety.

The proposed changes to increase the possession limits and clarify descriptions of Phase JII and lease do not decrease the margin of safety associated with any IROFS being credited to ensure the performance requirements of l O 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 being made to security plans SP-3605-0041 and SP-3605-0042 are administrative in nature to clarify Phase lll; therefore, will not decrease the overall level of security performance needed to protect against the loss or compromise of classified matter or SNM, while in use or in storage, nor classified matter in transit. The control of ACO 24-0108 Page 10 of 11 classified storage areas or vaults, training of classifiers, documentation of classification of matter will be maintained at the same level.

No changes are required for security plan SEC-18-0002, Information System Security Plan (ISSP) for Oak Ridge, TN; Piketon, OH; and Bethesda, MD, which provides for the protection of cyber systems, maintaining the necessary computer security requirements at the same level as previously approved by the NRC. Additionally, no changes are required for the following security plans:

NR-3605-0010, Transportation Security Plan for Classified Matter Shipments for the American Centrifuge Plant; NR-SP-ACO-OR-0001,

Security Program for American Centrifuge Operating, LLC at Oak Ridge, Tennessee; SP-3605-0043, Classified Distributed Control System (DCS) Information System Security Plan (ISSP); SP-3605-0044, Classified Process Telephone System (PTS); or SP-3605-0045, Security Plan for the Protection of Classified Matter at Centrus Energy Corp.

Headquarters.

The proposed changes being made to the FNMCP (NR-3605-0005) are administrative in nature to clarify Phase III; therefore, the proposed changes will have no effect on the FNMCPs meeting the applicable requirements of 10 CFR Parts 70 and 74. Likewise, the proposed changes do not affect the function or process to control nuclear material as described within the FNMCP or Addendum I of the FNMCP.

The proposed changes to increase the possession limits and clarify descriptions of Phase III and the lease do not result in a change to the ACP Emergency Plan, nor decrease the effectiveness.

For HALEU Cascade Operations, 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. DAC-3901-0005 (Revision 6) was reassessed and still concludes that "ACO has reassessed the need for an emergency plan and determined that the technical basis provided herein remains applicable if the nuclear material possession limit is increased because total UF6 inventory is not a parameter of the analysis. Even a substantial increase in the number of feed, tails, and product cylinders would not impact the conclusion that no emergency plan is required under the assumption that the operational restrictions and practices used for the HALEU Demonstration remain the same." This amendment request does not propose any new storage of cylinders external to the buildings nor introduce any new chemicals or energy sources that could potentially drive the requirements to have an Emergency Plan. Additionally, since there are no changes being made to the HA LEU cascade process descriptions or the number of planned operating centrifuges, the number of cylinders and hence material on-site is not a factor in changing the need for an Emergency Plan.

The proposed changes to increase the possession limits and clarify descriptions of Phase Ill and the lease do not result in a change to the Quality Assurance Program Description; thereby, do not represent a relaxation of any requirements of Quality Assurance Program Description.

ACO 24-0108 Page 11 of 11 Based on the above, the proposed changes to increase the possession limits and clarify descriptions of Phase Ill 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 to increase the possession limits and clarify descriptions of Phase 111 and the lease 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 SNM will be accessible to unauthorized personnel. Physical protection methods for SNM remain unchanged. 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 to increase the possession limits and clarify descriptions of Phase Ill and the lease 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. In addition, there is no change in the type or significant increases in the amounts of any effluents that may be released off-site. The amount of material is much less than currently evaluated under the American Centrifuge Plant.

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

Based upon current operations, the proposed changes to increase the possession limits and clarify descriptions of Phase IJI and the lease do not result in any significant change in effluents released offsite or any significant increase in individual or cumulative occupational radiation exposure.

9. There is no significant construction impact.

HALEU storage expansion construction activities and Vehicle Barrier System construction activities are being currently planned, material being procured, and material being staged for use in the upcoming calendar year. All of these activities will take place on the currently authorized ACP footprint with minimal impact to ongoing HALEU cascade operations.

Additionally, there are no foreseen environmental concerns for these construction activities as no earth movement is required. Additionally, there will be no new building construction involved during Phase Ill HALEU cascade operations.