ML21148A291

Encl 1 SER Ch 1-14 (Public)

ML21148A291
Person / Time
Site:	07007004
Issue date:	06/01/2021
From:	Office of Nuclear Material Safety and Safeguards
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YHFaraz NMSS/DFM/FFL 301.415.7220
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ML21138A826	List: ML21138A827 ML21138A828 ML21148A291
References
EPID L-2020-LLA-0085
Download: ML21148A291 (22)

Text

U.S. NUCLEAR REGULATORY COMMISSION SAFETY EVALUATION REPORT FOR THE HIGH ASSAY LOW ENRICHED URANIUM DEMONSTRATION PROGRAM AT CENTRUS ENERGY CORP./AMERICAN CENTRIFUGE OPERATING, LLCs AMERICAN CENTRIFUGE PLANT IN PIKETON, OHIO DOCKET NUMBER 70-7004 LICENSE NUMBER SNM-2011 June 2021

TABLE OF CONTENTS TABLE OF CONTENTS ............................................................................................................... ii EXECUTIVE

SUMMARY

............................................................................................................. vi 1 GENERAL INFORMATION .................................................................................................... 1

1.1 BACKGROUND

............................................................................................................. 1 1.2 HISTORICAL PERSPECTIVE ....................................................................................... 3 1.3 FACILITY AND PROCESS OVERVIEW ........................................................................ 4 1.3.1 Purpose of The Review ........................................................................................... 4 1.3.2 Regulatory Requirements ........................................................................................ 4 1.3.3 Regulatory Guidance and Acceptance Criteria ....................................................... 4 1.3.4 Staff Review and Analysis ....................................................................................... 5 1.3.5 Evaluation Findings ............................................................................................... 10 1.4 INSTITUTIONAL INFORMATION ................................................................................ 10 1.4.1 Purpose of Review ................................................................................................ 10 1.4.2 Regulatory Requirements ...................................................................................... 10 1.4.3 Regulatory Guidance and Acceptance Criteria ..................................................... 10 1.4.4 Staff Review and Analysis ..................................................................................... 11 1.5 FINANCIAL ANALYSIS ................................................................................................ 12 1.5.1 Purpose of the Review .......................................................................................... 12 1.5.2 Financial Qualification and Liability Insurance Requirements ............................... 12 1.5.3 Financial Qualification and Liability Insurance Guidance ...................................... 12 1.5.4 Evaluation Findings ............................................................................................... 15 1.6 TYPE, QUANTITY, AND FORM OF LICENSED MATERIAL ...................................... 15 1.6.1 Authorized Uses .................................................................................................... 15 1.7 SECURITY OF CLASSIFIED INFORMATION ............................................................. 15 1.8 APPLICABLE CODES AND STANDARDS AND GUIDANCE DOCUMENTS ............. 16 1.8.1 Applicable Codes and Standards .......................................................................... 16 1.8.2 License Application Regulatory Guidance Documents.......................................... 19 1.9 EVALUATION FINDINGS ............................................................................................ 19 1.10 SITE DESCRIPTION.................................................................................................... 20 1.10.1 Purpose of the Review .......................................................................................... 20 1.10.2 Regulatory Requirements ...................................................................................... 20 1.10.3 Regulatory Guidance and Acceptance Criteria ..................................................... 20 1.10.4 Staff Review and Analysis ..................................................................................... 20 1.10.5 Evaluation Findings ............................................................................................... 24 1.11 REFERENCES............................................................................................................. 24 2 ORGANIZATION AND ADMINISTRATION ......................................................................... 27 2.1 PURPOSE OF REVIEW .............................................................................................. 27 2.1.1 Regulatory Requirements ...................................................................................... 27 2.1.2 Regulatory Guidance and Acceptance Criteria ..................................................... 27 2.2 STAFF REVIEW AND ANALYSIS ............................................................................... 27 2.3 EVALUATION FINDINGS ............................................................................................ 29

2.4 REFERENCES

............................................................................................................. 29 3 ISA AND ISA

SUMMARY

..................................................................................................... 31 3.1 PURPOSE OF REVIEW .............................................................................................. 31 3.1.1 Regulatory Requirements ...................................................................................... 31 3.1.2 Regulatory Guidance and Acceptance Criteria ..................................................... 32 ii

3.2 STAFF REVIEW AND ANALYSIS ............................................................................... 32 3.2.1 Process Safety Information ................................................................................... 33 3.2.2 Integrated Safety Analysis ..................................................................................... 34 3.2.3 Management Measures ......................................................................................... 35 3.2.4 ISA Summary ........................................................................................................ 35 3.2.5 Natural Phenomena Hazards ................................................................................ 36 3.3 EVALUATION FINDINGS ............................................................................................ 38

3.4 REFERENCES

............................................................................................................. 38 4 RADIATION PROTECTION.................................................................................................. 40 4.1 PURPOSE OF REVIEW .............................................................................................. 40 4.1.1 Regulatory Requirements ...................................................................................... 40 4.1.2 Regulatory Guidance and Acceptance Criteria ..................................................... 40 4.2 STAFF REVIEW AND ANALYSIS ............................................................................... 40 4.2.1 Radiation Protection Program Implementation ...................................................... 40 4.2.2 ALARA Program .................................................................................................... 41 4.2.3 Organization and Personnel Qualifications ........................................................... 41 4.2.4 Written Procedures ................................................................................................ 41 4.2.5 Radiation Safety Training ...................................................................................... 41 4.2.6 Ventilation and Respiratory Protection Programs ................................................. 42 4.2.7 Radiation Surveys and Monitoring Programs ........................................................ 42 4.2.8 Control of Radiological Risk Resulting from Accidents.......................................... 42 4.2.9 Additional Program Commitments ......................................................................... 43 4.3 EVALUATION FINDINGS ............................................................................................ 44

4.4 REFERENCES

............................................................................................................. 44 5 CRITICALITY SAFETY......................................................................................................... 46 5.1 PURPOSE OF REVIEW .............................................................................................. 46 5.1.1 Regulatory Requirements ...................................................................................... 46 5.1.2 Regulatory Guidance and Acceptance Criteria ..................................................... 46 5.2 STAFF REVIEW AND ANALYSIS ............................................................................... 46 5.2.1 Changes to Chapter 5.0 of the Commercial ACP LA ............................................ 47 5.2.2 Evaluation of Criticality Events for the HALEU Demonstration ............................. 57 5.2.3 Minimum Margin of Subcriticality for Safety .......................................................... 58 5.3 EVALUATION FINDINGS ............................................................................................ 60

5.4 REFERENCES

............................................................................................................. 60 6 CHEMICAL PROCESS SAFETY ......................................................................................... 62 6.1 PURPOSE OF REVIEW .............................................................................................. 62 6.1.1 Regulatory Requirements ...................................................................................... 62 6.1.2 Regulatory Guidance and Acceptance Criteria ..................................................... 62 6.2 STAFF REVIEW AND ANALYSIS ............................................................................... 62 6.2.1 Background ........................................................................................................... 62 6.2.2 Revised Application for HALEU Demonstration .................................................... 63 6.2.3 HALEU Demonstration Chemical Safety Review .................................................. 63 6.2.4 HALEU Demonstration Program Process Description .......................................... 63 6.2.5 HALEU Demonstration Chemical Hazards ............................................................ 64 6.2.6 HALEU Demonstration Chemical Hazards and Accident Sequences ................... 64 6.2.7 HALEU Demonstration Chemical Accident Sequence Likelihood and Consequences ...................................................................................................... 64 6.2.8 HALEU Demonstration Chemical Safety-Related IROFS ..................................... 65 6.2.9 Management Measures ......................................................................................... 65 iii

6.2.10 Baseline Design Criteria ........................................................................................ 65 6.3 EVALUATION FINDINGS ............................................................................................ 65

6.4 REFERENCES

............................................................................................................. 66 7 FIRE SAFETY ....................................................................................................................... 67 7.1 PURPOSE OF REVIEW .............................................................................................. 67 7.1.1 Regulatory Requirements ...................................................................................... 67 7.1.2 Regulatory Guidance and Acceptance Criteria ..................................................... 67 7.2 STAFF REVIEW AND ANALYSIS ............................................................................... 67 7.2.1 Fire Safety ............................................................................................................. 67 7.2.2 Fire Safety Management Measures ...................................................................... 68 7.2.3 Fire Hazard Analysis ............................................................................................. 69 7.2.4 Building/Facility Design ......................................................................................... 70 7.2.5 Process Fire Safety ............................................................................................... 71 7.2.6 Fire Protection and Emergency Response ............................................................ 72 7.3 EVALUATION FINDINGS ............................................................................................ 72

7.4 REFERENCES

............................................................................................................. 73 8 EMERGENCY MANAGEMENT ............................................................................................ 74 8.1 PURPOSE OF REVIEW .............................................................................................. 74 8.1.1 Regulatory Requirements ...................................................................................... 74 8.1.2 Regulatory Guidance and Acceptance Criteria ..................................................... 74 8.2 STAFF REVIEW AND ANALYSIS ............................................................................... 74 8.2.1 Description of the Facility and Materials Used ...................................................... 75 8.2.2 Types of Accidents ................................................................................................ 75 8.2.3 Detection of Accidents ........................................................................................... 76 8.2.4 Evaluation of the Maximum Public Exposure ........................................................ 76 8.3 EVALUATION FINDINGS ............................................................................................ 77

8.4 REFERENCES

............................................................................................................. 77 9 Environmental Protection .................................................................................................. 78 9.1 PURPOSE OF REVIEW .............................................................................................. 78 9.1.1 Regulatory Requirements ...................................................................................... 78 9.1.2 Regulatory Guidance and Acceptance Criteria ..................................................... 78 9.2 STAFF REVIEW AND ANALYSIS ............................................................................... 78 9.2.1 Radiation Safety .................................................................................................... 78 9.2.2 Effluent Monitoring ................................................................................................ 80 9.3 EVALUATION FINDINGS ............................................................................................ 82

9.4 REFERENCES

............................................................................................................. 82 10 DECOMMISSIONING FINANCIAL ASSURANCE ............................................................... 83 10.1 PURPOSE OF REVIEW .............................................................................................. 83 10.1.1 Regulatory Requirements ...................................................................................... 83 10.2 STAFF REVIEW AND ANALYSIS ............................................................................... 83 10.3 EVALUATION FINDINGS ............................................................................................ 84

10.4 REFERENCES

............................................................................................................. 85 11 MANAGEMENT MEASURES............................................................................................... 86 11.1 PURPOSE OF REVIEW .............................................................................................. 86 11.1.1 Regulatory Requirements ...................................................................................... 86 11.1.2 Regulatory Guidance and Acceptance Criteria ..................................................... 86 11.2 STAFF REVIEW AND ANALYSIS ............................................................................... 87 11.2.1 Configuration Management Program .................................................................... 88 iv

11.2.2 Maintenance .......................................................................................................... 89 11.2.3 Training and Qualifications .................................................................................... 90 11.2.4 Procedure Development and Implementation ....................................................... 92 11.2.5 Audits and Assessments ....................................................................................... 92 11.2.6 Incident Investigations ........................................................................................... 92 11.2.7 Records Management ........................................................................................... 93 11.2.8 Other Quality Assurance Elements ....................................................................... 93 11.3 EVALUATION FINDINGS ............................................................................................ 98

11.4 REFERENCES

............................................................................................................. 98 12 FUNDAMENTAL NUCLEAR MATERIAL CONTROL PLAN ............................................. 100

12.1 REFERENCES

........................................................................................................... 100 13 PHYSICAL SECURITY PLAN ............................................................................................ 101

13.1 REFERENCES

........................................................................................................... 101 14 LIST OF PREPARERS ....................................................................................................... 103 v

EXECUTIVE

SUMMARY

American Centrifuge Operating, LLC (ACO), a wholly owned indirect subsidiary of Centrus Energy Corp. (Centrus), possesses two gas centrifuge enrichment facility licenses from the U.S. Nuclear Regulatory Commission (NRC). One license (SNM-7003), initially issued in 2004, is for the demonstration facility known as the American Centrifuge Lead Cascade Facility (LCF) located on a U.S. Department of Energy (DOE) reservation in Piketon, Ohio, which, until December 2016, authorized uranium enrichment in up to 240 operating centrifuges in existing buildings leased by ACO from the DOE. The purpose of the LCF, which operated from 2006 to 2016 and was decommissioned in 2018, was to demonstrate centrifuge cascade operation and obtain performance data. No product was withdrawn from the cascade for commercial purposes. ACOs second license (SNM-2011), issued in 2007 under 10 CFR Parts 30, 40 and 70 for a period of 30 years, is for the commercial production facility known as the American Centrifuge Plant (ACP). The NRCs safety and safeguards review for the commercial ACP is documented in NUREG-1851, which was issued in September 2006. These NRC licenses were subsequently modified in 2014 to reflect USEC Inc.s change of name to Centrus. The LCF lies completely within the commercial ACP site, occupying about 10 percent of the space reserved for the commercial ACP. The commercial ACP site, in turn, lies completely within the southwest quadrant of the DOE's reservation, where an adjoining uranium enrichment facility using a gaseous diffusion process previously operated for several decades. Currently, DOE is decommissioning this facility.

On May 31, 2019, ACO signed a three-year letter contract with the DOE to deploy a cascade of 16 operating uranium enrichment centrifuges to demonstrate production of high-assay, low-enriched uranium (HALEU) fuel up to an enrichment of 19.75 percent uranium-235 (U-235).

The contract terms were finalized on October 31, 2019. The contract states the ACP HALEU Demonstration Program has two primary objectives:

(1) Deploy a 16-machine cascade producing 19.75 percent U-235 enriched HALEU product; and (2) Demonstrate the capability to produce HALEU with existing U.S.-origin enrichment technology and produce for DOE, by the end of the 3-year contract period, between 200 and 600 kilograms of HALEU in the form of uranium hexafluoride (UF6) for future use in DOEs research and development activities and other programmatic missions.

Subsequent to signing the contract, ACO modified and updated the existing commercial ACP License Application (LA) and supporting documents and provided new supporting documents, where needed, to incorporate the HALEU Demonstration Program in the existing commercial ACP LA documents and prepared them for submittal to the NRC for their review and approval.

Between December 2019 and June 2020, ACO provided the NRC a revised LA (RLA) and supporting documents to operate the HALEU cascade under the ACP license until its 3-year contract period with DOE ends on May 31, 2022. At the end of the contract period, the amendment being issued by this licensing action will expire. At that time, ACO will have the option of turning the facility back to DOE, unless it has its ACP license amended by the NRC and its lease agreement for the Piketon facility amended by DOE for a period beyond May 31, 2022.

In reviewing the submitted RLA and supporting documents, the staff focused on the new information in the form of changes and updates made to the previously approved LA and vi

supporting documents and new supporting documents. For the evaluation of areas with new or revised guidance or regulation, the staff also reviewed the descriptions and commitments for the commercial ACP, as approved in NUREG-1851, that are contained in the submitted RLA and supporting documents, to ensure continued demonstration of compliance with the appropriate requirements and consistency with the guidance used to conduct this review.

NRC staff conducted its safety review of the RLA and supporting documents in accordance with NUREG-1520 Revision 2, "Standard Review Plan for Fuel Cycle Facilities License Applications." For the staff's review of the safeguards section of the RLA and supporting documents, the staff used NUREG/CR-5734, "Recommendations to the NRC on Acceptable Standard Format and Content for the Fundamental Nuclear Material Control (FNMC) Plan Required for Low-Enriched Uranium Enrichment Facilities." For its review of the physical protection of special nuclear material (SNM), the staff used Regulatory Guide 5.59, "Standard Format and Content for a Licensee Physical Security Plan for the Protection of Special Nuclear Material of Moderate to Low Strategic Significance."

The staff also reviewed ACOs Quality Assurance Program Description. ACO also submitted supplemental information updating the Environmental Report for the ACP. This information was used to prepare an Environmental Assessment for the HALEU Demonstration Program that was issued on June 4, 2021.

Although ACO can receive, store, assemble, and install the HALEU cascade equipment under its existing approved LCF programs, ACO may not begin enrichment operations until after the Commission verifies through inspection that the HALEU cascade has been installed in accordance with the requirements of the license (see 10 CFR 70.32(k)).

A summary of NRC's review and findings in each of the review areas is provided below:

General Information ACO provided an adequate description of the HALEU cascade and processes so that the staff has an overall understanding of the relationships of the facility features as well as the function of each feature. Financial qualifications were properly explained and outlined in the application.

The updated description of the site continues to include important information about regional hydrology, geology, meteorology, the nearby population, and potential effects of natural phenomena at the facility.

Organization and Administration ACO adequately updated the description of the responsibilities and associated resources for the design, construction, and operation of the facility and its plans for safely and securely managing the HALEU Demonstration Program. The plans and commitments described in the application provide reasonable assurance that an acceptable organization, administrative policies, and sufficient competent resources have been established or committed for safe and secure operation of the HALEU cascade.

"Integrated Safety Analysis" (ISA) and ISA Summary ACO adequately updated information about the site, processes, hazards, and types of accident sequences for the HALEU Demonstration Program. The updated information addressed vii

credible events, their potential radiological and chemical consequences, and their likelihoods.

The ISA Summary and onsite review demonstrated that the performance requirements in Section 70.61 (b), (c) and (d) are met. ACO also provided adequate information about items relied on for safety (IROFS). License Condition 18 will be maintained to ensure that IROFS boundaries will be defined using ACO's IROFS boundary definition procedure.

Radiation Protection ACO provided sufficient information to evaluate the Radiation Protection Program for the HALEU Demonstration Program. The application adequately describes the updates to: (a) the implementation program; (b) the program for ensuring that worker and public doses are as low as reasonably achievable (ALARA); (c) the qualification requirements; (d) the commitment to use written radiation protection procedures including radiation work permits; (e) the necessary training for all personnel who have access to radiologically restricted areas; (f) the ventilation and respiratory protection program; and the radiation survey and monitoring program. These aspects of the HALEU Demonstration Program demonstrate a comprehensive radiation protection program that is adequate to protect workers and members of the public who may be potentially exposed to radiation. This program is supported by the ISA, which identifies the events that could result in radiation exposures and commits to appropriate mitigations.

The labeling and posting special authorizations, as approved in NUREG-1851, continue to be applicable for the HALEU amendment. The alternate container labeling is authorized for UF6 feed, product, and depleted uranium cylinders, and labeling bulk storage areas in lieu of individual container labeling within the radiologically restricted areas at the ACP. The ACO is also approved for an alternative method for controlling access to high radiation areas using radiation work permits and appropriate monitoring.

Nuclear Criticality Safety ACO provided adequate information to evaluate the updated Nuclear Criticality Safety (NCS) program for the HALEU Demonstration Program. ACO described an NCS program that adequately protects against criticality hazards and assures that all nuclear processes are subcritical under normal and credible abnormal conditions, with an approved margin of subcriticality for safety, consistent with regulatory requirements. ACO described an NCS program that will adequately implement and maintain a criticality accident alarm system consistent with regulatory requirements.

Chemical Process Safety ACO adequately described and assessed the updated chemical accident sequences and consequences for the HALEU Demonstration Program that could result from the handling, storage, or processing of licensed materials and that could have potentially significant chemical consequences and effects. ACO performed hazard analyses that identified and evaluated chemical process hazards and potential accidents and established safety controls that meet the regulatory requirements.

Fire Safety ACO committed to engineered and administrative controls to minimize the risk of fires and explosions that may be associated with the HALEU Demonstration Program. The IROFS and defense-in-depth protection discussed in ACO's ISA Summary, along with the safety basis viii

assumptions and planned programmatic commitments in the license application, meet associated regulatory requirements and provide reasonable assurance that operation of the HALEU cascade is protected against fire hazards.

Emergency Management ACO did not modify the commercial ACP Emergency Plan (EP) for the 3-year HALEU Demonstration Program. Instead, in accordance with the regulations in 10 CFR 70.22(i), ACO provided an evaluation for the HALEU Demonstration Program showing that the maximum dose to a member of the public offsite due to an accidental release of radioactive materials would not exceed 1 rem effective dose equivalent or an intake of 2 milligrams of soluble uranium during operations until the expiration of the contract period ending on May 31, 2022. Based on that information, the NRC determined that ACO does not require an EP to operate the HALEU Demonstration Program cascade until ACOs 3-year contract with DOE expires on May 31, 2022. However, if ACO desires to expand the scope of operation of the HALEU Demonstration Program beyond the description in the RLA or extend operations beyond May 31, 2022, it will need to reassess the need for an EP.

Environmental Protection ACO committed to adequate environmental protection measures for the HALEU Demonstration Program, including: (a) environmental and effluent monitoring; and (b) effluent controls to maintain public doses ALARA as part of the radiation protection program. ACO's proposed controls are adequate to protect the environment and the health and safety of the public and comply with the regulatory requirements.

Decommissioning ACO did not modify the ACP conceptual decommissioning plan or the decommissioning funding plan for the 3-year HALEU Demonstration Program, as, per its Lease Agreement with ACO, the Department of Energy has accepted all responsibility for decommissioning the facility after the end of the three-year contract period. However, if ACO desires to expand the scope of operation of the HALEU cascade beyond what is described in the RLA or extend operations beyond May 31, 2022, it will need to modify the terms of its Lease Agreement with DOE. The modified terms of the Lease Agreement will determine at that time whether a decommissioning plan or a decommissioning funding plan is needed.

Management Measures ACO provided updated information in the RLA about management measures that will be applied to the 3-year HALEU Demonstration Program. The revised management measures discussion describes: (a) the overall configuration management program and policy; (b) the maintenance program; (c) training; and (d) the process for the development, approval, and implementation of procedures that are related to the operation and implementation of IROFS and for the management measures supporting the availability and reliability of those IROFS. ACO explained the audits and assessments program as well as incident investigations and records management system. ACO confirmed its commitment to establishing and documenting surveillances, tests, and inspections to provide reasonable assurance of satisfactory performance of the IROFS. The updated management measures are acceptable and meet the regulatory requirements in 10 CFR 70.62(d). ACO continues to request an exemption from the ix

reporting criteria for issuing a written follow-up report within 30 days of the initial event report.

The staff continues to authorize this exemption.

Material Control and Accounting ACO provided updated information describing the Fundamental Nuclear Material Control Plan (FNMCP) for the three-year HALEU Demonstration Program. The increase in the uranium enrichment levels from 10 wt.% for the commercial ACP up to but less than 20 wt.% for the HALEU Demonstration Program warrants an increase in the categorization of the facility from a Category 3 to a Category 2 (see definitions for special nuclear material of low and moderate strategic significance in 10 CFR Part 73). The FNMCP describes the programs to be used to control and account for SNM in the HALEU Demonstration Program. The program meets the applicable regulatory requirements in Part 74.

Physical Protection ACO provided updated information on the policies, methods, and procedures to be implemented to protect SNM of moderate strategic significance used and possessed as part of the HALEU Demonstration Program. Previously, for the commercial ACP, this information was for protecting SNM of low strategic significance. The updated information is acceptable and meets the requirements in Part 73.

x

1 GENERAL INFORMATION American Centrifuge Operating, LLC (ACO) is a wholly owned, indirect subsidiary of Centrus Energy Corp. (Centrus). It possesses two gas centrifuge enrichment facility licenses from the U.S. Nuclear Regulatory Commission (NRC). One license (SNM-7003), initially issued in 2004 is for the demonstration facility known as the American Centrifuge Lead Cascade Facility (LCF) located on a U.S. Department of Energy (DOE) reservation in Piketon, Ohio, which authorized up to 240 operating centrifuges. The NRCs license (NRC, 2004) and its associated Safety Evaluation Report (NRC, 2004a) for the initial approval of the LCF were issued in February 2004 and January 2004, respectively. The purpose of the LCF, which operated between 2006 and 2016 and was decommissioned in 2018, was to demonstrate centrifuge cascade operation and obtain performance data. No product was withdrawn from the cascade for commercial purposes. ACOs second license (SNM-2011) is for a proposed commercial production facility

[that is yet to be built] known as the American Centrifuge Plant (ACP). The proposed commercial ACP would physically encompass the LCF within its footprint. The ACP license (SNM-2011) was initially issued in 2007 under 10 CFR Parts 30, 40 and 70 for a period of 30 years (NRC, 2007). As part of the initial licensing review, the NRC issued its Safety Evaluation Report (SER) for the commercial ACP in September 2006 (NRC, 2006). This SER pertains to an amendment request to the ACP license for the high-assay low-enriched uranium (HALEU)

Demonstration Program submitted by ACO in portions between December 2019 and June 2020 (ACO, 2019a, ACO, 2020, ACO, 2020a, ACO, 2020b, and ACO, 2020c). The HALEU Demonstration Program involves operation of a 16-centrifuge cascade under SNM-2011 to demonstrate and produce a small quantity of HALEU in the form of UF6 for the DOE in the buildings that formerly housed the LCF.

1.1 BACKGROUND

On May 31, 2019, ACO signed a three-year letter contract with the DOE to deploy a cascade of 16 operating uranium enrichment centrifuges to demonstrate production of HALEU fuel up to 19.75 percent U-235. The contract terms were finalized on October 31, 2019 (ACO, 2019).

According to the contract, the HALEU Demonstration Program has two primary objectives:

(1) Deploy a 16-machine cascade producing 19.75 percent U-235 enriched HALEU product; and (2) Demonstrate the capability to produce HALEU with existing U.S.-origin enrichment technology and produce for DOE, by the end of the 3-year contract period, between 200 and 600 kilograms of HALEU in the form of UF6 for future use in DOEs research and development activities and other programmatic missions.

Subsequent to signing the contract, ACO updated and revised the commercial ACP License Application (LA) and supporting documents to incorporate the HALEU Demonstration Program and prepared them for submittal to the NRC for its review and approval. Between December 2019 and June 2020, ACO provided the NRC various submittals pertaining to the revised commercial ACP LA (RLA) and supporting documents to operate the HALEU cascade under the ACP license. These submittals were as follows:

(1) Engineering Evaluation (EE) entitled NCS Code Validation of SCALE 6.2.3 and Cross Section Set v7-252 for keff Calculations (EE-3101-0013) submitted on December 5, 2019 1

(ACO, 2019a). The NRC staffs review of this EE is addressed in Chapter 5 and Appendix B of this SER.

(2) Quality Assurance Program Description (QAPD) (ACO, 2020b), and Integrated Safety Analysis (ISA) Summary submitted on April 22, 2020 (ACO, 2020). The NRC staffs review of the RLA, QAPD, and ISA Summary is documented in Chapters 1 to 11 and Appendix A and B of this SER. ACO requested an approval of this submittal by June 2, 2021. Appendix A and B are non-publicly available and are marked Official Use Only -

Security-Related Information.

(3) Environmental Report (ER) and the Fundamental Nuclear Material Control Plan (FNMCP) submitted on May 7, 2020 (ACO, 2020a), as amended by letter dated June 17, 2020, (ACO, 2020b). The NRC staffs review of the ER is addressed in the environmental assessment (EA) (NRC, 2021) associated with this amendment. The NRC staffs review of the FNMCP is documented in Chapter 12 and Appendix C of this SER. ACO requested an approval of this submittal by June 2, 2021. Appendix C is non-publicly available and is marked Official Use Only - Security-Related Information.

(4) Physical Security Plan (PSP) submitted on June 23, 2020 (ACO, 2020c), as supplemented by letter dated August 5, 2020 (ACO, 2020d). The NRC staffs review of the PSP is documented in Chapter 13 and Appendix D of this SER. ACO requested an approval of this submittal by June 2, 2021. Appendix D is non-publicly available and is marked Safeguards Information.

ACO also provided technical justifications for the proposed changes to the commercial ACP LA.

According to ACO, the design capacity of the 16-centrifuge Demonstration Program facility will be 900 kilograms (Kg) uranium (U) of HALEU per year.

The RLA was developed using the original license application for the commercial ACP operation that was initially approved in 2007 (NRC, 2007). ACO modified the commercial ACP application and identified the changes for which it is seeking approval for the license amendment (modifications to the ACP LA were provided in redline/strikeout format). The NRC staff reviewed the proposed modifications to the ACP LA which are applicable to the HALEU Demonstration Program. The most significant changes in the RLA involved the increase in the operational enrichment limit from 10 wt.% U-235 to 25 wt.% U-235 necessary to operate the HALEU Cascade. The nuclear criticality safety (NCS) program was significantly modified due to changes in ACOs operations and increased enrichment, and the programs for physical protection of special nuclear material (SNM), and material control and accounting (MC&A) were significantly modified due to an increase in the significance of the security level of the facility from a Category 3 to a Category 2 facility. Operation of the relatively small capacity of the HALEU cascade (16 operating centrifuges compared to the approximately 11,500 centrifuges for the commercial ACP) will not require compliance with certain requirements that applied to the much larger proposed commercial facility. For example, ACO demonstrated to the NRC staff that according to the requirements of 10 CFR 70.22(i), an Emergency Plan is not required to operate the HALEU cascade for the duration of this license amendment, which ends with ACOs 3-year contract period with DOE. On May 25, 2021, ACO provided the NRC the entire RLA which is referenced in the ACP license SNM-2011 (ACO, 2021a) (ACO, 2021b) (ACO, 2021c).

Separate from this review, ACO received approvals from the NRC for the classified matter transportation security plan on October 20, 2020 (NRC, 2020), and for the classified matter 2

protection (CMP) plans to enable the re-establishment of ACOs possession facility clearance for its leased facility in Piketon, Ohio on October 30, 2020 (NRC, 2020a). After the NRC issued a facility clearance to ACO on October 30, 2020 to possess classified information, ACO began receiving, assembling, preparing and installing equipment for the HALEU cascade under its existing ACP and LCF licenses.

On February 6, 2020, ACO submitted its CMP plans for the Technology and Manufacturing Center (TMC) in Oak Ridge Tennessee (ACO, 2020e), where ACO manufactures centrifuge parts. The TMC CMP plans submission is separate from the CMP submittals for the facility in Piketon discussed above, and is not related to the amendment addressed in this SER. The NRC staff approved the TMC CMP plans and issued the amendment for the ACP license on March 25, 2021 (NRC, 2021a). This approval permitted the transfer of the TMCs Cognizant Security Agency (CSA) security regulatory oversight and its Authorizing Official (AO) responsibilities from the DOE to the NRC.

1.2 HISTORICAL PERSPECTIVE In the early 1980s, the DOE initiated construction of the Gas Centrifuge Enrichment Plant (GCEP) at the Portsmouth Gaseous Diffusion Plant (PORTS) site in Piketon, Ohio. After installing and operating several hundred centrifuges, the DOE terminated the GCEP project in 1985. In 2004, USEC Inc. signed a Lease Agreement with DOE to use certain GCEP facilities for testing and for eventual commercial production. These activities were to be added to its overall gas centrifuge uranium enrichment project for the purpose of demonstrating the commercial viability of and for deploying new centrifuge enrichment technology.

The NRC issued Materials License No. SNM-7003 for the LCF to USEC Inc. on February 24, 2004 (NRC, 2004). The SER and Environmental Assessment (EA) associated with this licensing action was issued on January 28, 2004 (NRC, 2004b). USEC Inc., under contract with the DOE, dismantled and packaged for transport for offsite disposition, the DOE's contaminated and non-contaminated GCEP classified waste, comprising of centrifuges and equipment. USEC Inc. installed centrifuges in a portion of one of the two existing GCEP process buildings. where USEC Inc. began operating the LCF as a test facility in August of 2006. The LCF test facility was licensed to obtain reliability, performance, cost, and other data, to use in deciding whether to construct and operate a commercial uranium enrichment plant, referred to as the American Centrifuge Plant (ACP).

Separately, the NRC issued Materials License No. SNM-2011 on April 13, 2007 (NRC, 2007) to USEC Inc. for the proposed construction and commercial operation of a gas centrifuge facility known as the ACP. The NRC documented its safety and safeguards review of the ACP application in NUREG-1851, which was issued in September 2006 (NRC, 2006). The LCF lies completely within the ACP site, occupying about 10 percent of the space reserved for the ACP.

The ACP site lies completely within the southwest quadrant of the DOE's reservation, where an adjoining uranium enrichment facility that used a gaseous diffusion process, was operated for several decades. Currently, DOE is decommissioning this facility. The layout of the Piketon site with the existing ACP and LCF buildings (circled) is provided in the figure below.

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Overflight photo of the Piketon site with the existing ACP and LCF buildings (circled) 1.3 FACILITY AND PROCESS OVERVIEW 1.3.1 Purpose of The Review The NRC staff reviewed and approved USEC Inc.s Facility and Process Overview for the commercial ACP as documented in NUREG-1851, which was issued in September 2006 (NRC, 2006). The purpose of NRCs review of ACOs facility and process overview contained in the RLA is to evaluate whether ACO adequately described the HALEU Demonstration Program equipment, processes and facilities that will be used to protect health and minimize danger to life or property in the RLA documents. The areas of review in Chapter 1 of the RLA included; (1) general information, (2) plant and process description (overview), (3) site boundary and plant layout, (4) primary facilities description, (5) secondary facility description, (6) process description (detailed), (7) hazardous material storage, (8) phased modular expansion plan, (9) material of construction, (10) use of lubricants, (11) Chapter 1 Figures, and (12) Chapter 1 Tables.

1.3.2 Regulatory Requirements The regulations in 10 CFR 70.22 Contents of Applications, specifically in 10 CFR 70.22(a),

establish requirements for the contents of the application.

1.3.3 Regulatory Guidance and Acceptance Criteria The guidance and acceptance criteria used to review the facility and process description are contained in the Standard Review Plan for Fuel Cycle Facilities License Applications NUREG-1520, Rev.2 (SRP) (NRC, 2015). Section 1.1.3 of the SRP identifies the areas of review as; (1)

Facility Layout Description, (2) Process Overview, (3) Site Overview, and (4) Descriptive 4

Summary of Licensed Material. The acceptance criteria applicable to the RLA Sections 1.1, 1.2 and 1.3 are contained in Section 1.1.4.3 of the SRP (NRC, 2015).

1.3.4 Staff Review and Analysis 1.3.4.1 General Information In the RLA Section 1.0 General Information, ACO added information relevant to the HALEU Demonstration Program to the existing information applicable to the ACP. According to the RLA Section 1.0, the United States Enrichment Corporation (USEC)) leases portions of the Portsmouth Gaseous Diffusion Plant (GDP) reservation from the DOE through the non-public Lease Agreement between the DOE and USEC for the GCEP (GCEP Lease Agreement).

Centrus subleased space for the LCF and the ACP from the USEC. Centrus, with approval of the DOE, assigned the sublease for the space for the ACP to ACO. ACO and its agents will conduct activities within the leased facilities and control access and egress, as stated in the RLA.

ACO modified the general information to reflect changes in contractual arrangements. ACO clarified that the HALEU Demonstration will not require new facilities for feed, withdrawal, sampling, and blending/transfer operations.

The NRC staff reviewed the changes to the general information section of the RLA. The staff determined that the original text subject to the changes described above adequately and sufficiently describe the licensee and the requested licensing action, and therefore, comply with 10 CFR 70.22(a) and are consistent with the guidance in Section 1.1.4.3 of the SRP (NRC, 2015).

1.3.4.2 Plant and Process Description In the RLA Section 1.1 Plant and Process Description, in addition to editorial/administrative/nomenclature changes, ACO made substantial plant and process changes. For example, the changes reflect the fact that the HALEU cascade will enrich this material to an enrichment less than 20.0 wt.% U-235 in its product stream and will deplete the feed to a target tails stream enrichment of approximately equal to or Iess than 1.0 wt.% U-235, instead of the ACP which would enrich material to less than 10.0 wt.% U-235. The NRC staff reviewed the changes to the plant and process description section of the RLA and determined the changes comply with 10 CFR 70.22(a) and are consistent with the guidance in Section 1.1.4.3 of the SRP (NRC, 2015) and are therefore acceptable.

1.3.4.3 Site Boundary and Plant Layout ACO did not make changes to the commercial ACP LA Sections 1.1.1 Site Boundary and 1.1.2 Plant Layout, where the physical location of the facility, the layout of the buildings, and the controlled access area within the site boundary is described. However, ACO did update figures, which are non-public, to include the HALEU cascade. The NRC staff continues to find this section consistent with the SRP Section 1.1.4.3, and therefore, is acceptable. The NRC staffs review of the non-publicly available figures is provided in Section 1.3.4.12 of this SER.

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1.3.4.4 Primary Facilities Description In the RLA Section 1.1.3 Primary Facilities Description, ACO retained the brief descriptions of the primary facilities associated with the ACP that involves up to about 11,500 operating centrifuges. These include the X-2232C Interconnecting Process Piping (IPP), X-3001 Process Building, X-3002 Process Building, X-3012 Process Support Building, X-3344 Customer Services Building, X-3346 Feed and Withdrawal Building, and X-3346A Feed and Product Shipping and Receiving Building. Other buildings and areas that provide direct support functions to the enrichment process are the X-7725 Recycle/Assembly Building, X-7726 Centrifuge Training and Test Facility, X-7727H Interplant Transfer Corridor, X-745G-2 Cylinder Storage Yard, X-745H (future) Cylinder Storage Yard, and X-7746S, X-7746W Cylinder Storage Yards and Intraplant Roadways and their descriptions are unchanged.

In the RLA Section 1.1.3, ACO described the first phase of enrichment production, the deployment of a cascade with 16 operating centrifuges and 2 spare centrifuges, which will demonstrate the feasibility of producing HALEU in the form of UF6. The primary ACP building/facilities directly involved in the HALEU Demonstration Program are the X-3001 Process Building, X-3012 Process Support Building, X-7725 Recycle/Assembly Building, X-7726 Centrifuge Training and Test Facility, and X-7727H Interplant Transfer Corridor. of the RLA includes non-public drawings of the building layouts. ACO updated the Controlled Access Area (CAA) for the HALEU Demonstration Program in one of the drawings.

No other substantive changes were made to Section 1.1.3 of the RLA.

In the RLA Section 1.1.3, ACO states its long-term goal is the resumption of commercial enrichment production consistent with market demand. The ACP design is modular, with the basic building block of enrichment capacity being a cascade of centrifuges. Modular deployment of additional cascades would accommodate market demand on a scalable, economical gradation. In the RLA Section 1.1.3, ACO states that the Fire Safety Program will be implemented to support the modular deployment, such that the fire protection systems/services are in place when needed.

The NRC staff reviewed the changes to the primary facility descriptions and determined them to be clear and sufficiently detailed, and therefore, in compliance with 10 CFR 70.22(a) and consistent with the guidance in SRP Section 1.1.4.3.

1.3.4.5 Secondary Facility Description In the RLA Section 1.1.4 Secondary Facility Description, ACO describes secondary facilities, including the X-6000 Cooling Tower Pump House, Air Plant, Air Plant Support Systems; X-6002 Boiler System; X-6002A Oil Storage Facility, X-7721 Maintenance, Stores and Training Building, X-7725A Waste Accountability Facility, and X-7745R Recycle/Assembly Storage area. These facilities are depicted in the non-public drawings in Enclosure 3 of the RLA. ACO deleted the X-112 Data Processing Building and the X-1020 Emergency Operations Center from the commercial ACP LA since these two facilities will not be needed for the HALEU Demonstration.

The HALEU Demonstration cascade utilizes a centrifuge design similar to that used for the Lead Cascade. The equipment necessary to perform the HALEU enrichment process is located in the X-3001 Process Building and consists of the product and tails withdrawal system, uranium hexafluoride (UF6) cylinders, centrifuges, and supporting units. The product and tails withdrawal systems use three cold boxes. Sodium fluoride (NaF) traps are used for additional withdrawal capacity during dumping. A 30B UF6 cylinder is used for the feed material. Centrifuges and 6

supporting units are placed in the Train 3 area of the X-3001 Process Building. No other substantive changes were made to Section 1.1.4 of the RLA. The NRC staff reviewed the changes to the secondary facility descriptions and determined them to be clear and sufficiently detailed and therefore, in compliance with 10 CFR 70.22(a) and consistent with the guidance in SRP Section 1.1.4.3.

1.3.4.6 Process Description In the RLA Section 1.1.5 Process Description, ACO addresses (1) centrifuge program history; (2) separation fundamentals; (3) centrifuge fundamentals; (4) enrichment process theory; (5) total process configuration; (6) enrichment process support systems; (7) centrifuge assembly and movement systems; and (8) plant support systems.

In the RLA Section 1.1.5.1 Centrifuge Program History, and in the rest of the Application, ACO made editorial changes by describing various structures as facilities or buildings. Whereas, previously these were exclusively described as facilities.

In the RLA Section 1.1.5.2, Separation Fundamentals, ACO notes that the HALEU Demonstration will increase the enrichment from a feed enrichment of up to 5.0 wt.% U-235 up to a target product enrichment of 19.75 wt.%. However, in its request to amend License SNM-2011, ACO proposed an increase in enrichment from 10 wt.% to 25 wt.%, as indicated in Table 1.2-2 Demonstration Program Possession Limits for NRC Regulated Materials and Substances of the RLA. ACO explained that authorization for the increased product enrichment is to account for in-process fluctuations that may result in small amounts of uranium with U-235 enrichments between 20 and 25 wt.%.

In the RLA Section 1.1.5.3 Centrifuge Fundamentals and in the remainder of the Application, ACO made one global editorial change, replacing the word machine with centrifuge.

In the RLA Section 1.1.5.4 Enrichment Process Theory, ACO did not make any changes.

In the RLA Section 1.1.5.5 Total Process Configuration, in addition to editorial/administrative changes, ACO notes that the centrifuges could be used with either Molecular Pumps or Diffusion Pumps.

In the RLA Section 1.1.5.6 Enrichment Process Support Systems, in addition to editorial/administrative changes, ACO notes that per 10 CFR 70.24, a Criticality Accident Alarm System (CAAS) is required in each area where threshold quantities (e.g., more than 700 grams of U-235) of special nuclear material are handled, used, or stored. Additionally, ACO notes that the CAAS coverage areas are identified on plant drawings, and controls are established to preclude special nuclear material from areas where coverage is not provided. The need for and use of CAAS is addressed in Chapter 5 of this SER.

In the RLA Section 1.1.5.7 Centrifuge Assembly and Movement Systems, in addition to editorial/administrative changes, ACO added the word Cart to the Centrifuge Transporter and clarified that it includes a tugger vehicle and can accommodate a maximum of two centrifuges.

In addition, ACO clarified that it would not be using a separate trailer intra plant tow tractor with a capacity of up to ten centrifuges for the HALEU Demonstration Program.

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The NRC staff reviewed the changes to the process descriptions and determined them to be clear and sufficiently detailed and therefore, in compliance with 10 CFR 70.22(a) and consistent with the guidance in SRP Section 1.1.4.3.

1.3.4.7 Hazardous Material Storage In the RLA Section 1.1.6 Hazardous Material Storage, ACO only made editorial/administrative changes. The NRC staff continues to find this section to be consistent with the SRP Section 1.1.4.3 and therefore acceptable.

1.3.4.8 Roadways In the RLA Section 1.1.7 Roadways, ACO only made editorial/administrative changes. The NRC staff continues to find this section to be consistent with the SRP Section 1.1.4.3 and therefore acceptable.

1.3.4.9 Phased Modular Expansion Plan In the RLA Section 1.1.8 Phased Modular Expansion Plan for the American Centrifuge Plant, ACO deleted the reference to transitioning from the LCF to the ACP commercial plant and replaced it with a description of the HALEU Demonstration Program.

In the RLA Section 1.1.8.1 High Assay Low Enriched Uranium Demonstration, ACO states that the HALEU Demonstration cascade utilizes a centrifuge design similar to that used for the LCF.

The equipment necessary to perform the enrichment process is in the X-3001 Process Building and consists of a product and tails withdrawal system, UF6 cylinders, centrifuges, and supporting systems. The product and tails withdrawal systems use three cold boxes. The NaF traps provide additional withdrawal capacity during dumping. A 30B UF6 cylinder is used to feed UF6 to the HALEU cascade. Centrifuge and supporting units are placed in the Train 3 area of the X-3001 building. A more detailed process description is provided in Addendum 1 of the Integrated Safety Analysis for the American Centrifuge Plant - HALEU Demonstration.

In the RLA Section 1.1.8.1, High Assay Low Enriched Uranium Demonstration, ACO states that DOE amended Appendix 1 of the Lease Agreement between DOE and United States Enrichment Corporation for the Gas Centrifuge Enrichment Plant by renewing and extending the term of the lease through May 31, 2022. Additionally, in Section 1.1.8.1, ACO states that at the conclusion of the three-year HALEU Demonstration Program (Phase 1), the facilities will either be 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.

The RLA Section 1.1.8.2 High Assay Low Enriched Uranium Demonstration Continuation, ACO states that the second phase of deployment would continue operation of the 16-centrifuge HALEU cascade for up to 10 years beyond the expiration of the current lease agreement with DOE.

In the RLA Section 1.1.8.4 Expanded Low Enriched Uranium and High Assay Low Enriched Uranium Production, ACO also discussed a potential future phase involving the addition of one or more 120-centrifuge HALEU cascades and/or LEU cascades and associated Feed and Withdrawal stations in a modular fashion all within the X-3001 building. In this potential phase, the HALEU cascades could be fed directly from associated LEU cascades or directly with LEU 8

cylinders. However, the NRC staff notes that ACO has not identified plans to initiate this expansion.

1.3.4.10 Material of Construction In the RLA Section 1.1.9 Material of Construction, ACO did not make changes. The NRC staff continues to find this section in compliance with 10 CFR 70.22(a), consistent with the SRP Section 1.1.4.3, and therefore acceptable.

1.3.4.11 Use of Lubricants In the RLA Section 1.1.10 Use of Lubricants, ACO did not make any changes. The NRC staff continues to find this section in compliance with 10 CFR 70.22(a), consistent with the SRP Section 1.1.4.3, and therefore acceptable.

1.3.4.12 Chapter 1 Figures The figures in Chapter 1 of the RLA contain sensitive Export Controlled Information (ECI) as well as non-sensitive information. The sensitive figures are in Appendix B to the RLA. Revised Figure 1.1-1 (ECI) contains the outline of the Controlled Access Area for the ACP. Revised Figure 1.1-2 (ECI) in Appendix B identifies existing primary and secondary ACP facilities as well as the proposed, but not yet built, primary and secondary facilities. The non-sensitive Figures 1.1-12 and 1.1-16 illustrate the process flow schematics and show the use of diffusion pumps for the ACP centrifuges. However, ACO noted that the ACP centrifuges for the HALEU Demonstration may also use molecular pumps. The NRC staff reviewed the changes and determined that the modifications are in compliance with 10 CFR 70.22(a), consistent with the SRP acceptance criteria provided in SRP Section 1.2.2, and therefore acceptable.

Sensitive (ECI) RLA Figures 1.1-3. 1.1-4, 1.1-5a, 1.1-5b, 1.1-5c, 1.1-5d, 1.1-5e, 1.1-6, 1.1-7, 1.1-8, 1.1-9, 1.1-10, and 1.1-14, which provide drawings of equipment and process flow layouts, were not modified from the ACP LA (NRC, 2006). Sensitive (ECI) RLA Figures 1.1-11, 1.1-13, and 1.1-15, containing process flow schematics, were not substantially modified. Based on a review of the modifications, the NRC staff determined that they continue to satisfy the SRP acceptance criteria in Section 1.2.2 and are, therefore, acceptable. Accordingly, the NRC staff continues to find this section in compliance with 10 CFR 70.22(a), consistent with the SRP Section 1.1.4.3, and therefore acceptable.

1.3.4.13 Chapter 1 Tables LA Table 1.1-1 entitled American Centrifuge Plant Major Facilities, provides a list of major ACP facilities and their corresponding functions. In addition to identifying editorial/administrative changes, ACO removed references to buildings that would not be utilized for the HALEU Demonstration Program. Specifically, ACO removed reference to the X-112 Data Processing Building, which provided secure housing for the data systems and necessary personnel, the X-1020 Emergency Operations Center, which served as a central location to coordinate any emergencies that occur on the DOE reservation, and the X-3000 Office Building, which housed personnel necessary for plant administration, from the listing. The NRC finds the removal of these three major facilities acceptable because they are not needed for HALEU Demonstration Program. For these reasons, the NRC staff finds the revised Table 1.1-1 to be consistent with the SRP acceptance criteria contained in SRP Section 1.1.4.3, and therefore acceptable.

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1.3.5 Evaluation Findings The staff has reviewed ACOs updated description of the facility and process overview according to Section 1.1 of the Standard Review Plan. Chapter 1 of the application summarizes the updated facility information contained in the ISA Summary and its addendum and includes descriptions of the overall facility layout on scaled drawings. The summary also describes the relationship of specific facility features to the major processes that will be ongoing at the facility.

The major chemical and mechanical processes involving licensed material are described in summary form, based in part on information presented in the ISA Summary. This description includes: (a) reference to the building locations of major process components; (b) brief descriptions of the process steps; and (c) the chemical forms of licensable material in process.

ACO has cross-referenced its general description with the more detailed descriptions elsewhere in the application.

The staff finds ACO has adequately described: (1) the facility and processes so that the staff has an overall understanding of the relationships of the facility features; and (2) the function of each feature. The staff concludes that ACO has met the regulatory requirements in 10 CFR 70.22(a) and acceptance criteria applicable to this section.

1.4 INSTITUTIONAL INFORMATION 1.4.1 Purpose of Review The purpose of NRCs review of ACOs institutional information is to evaluate whether the changes and updates to the information in the previously approved commercial ACP LA (NRC, 2007) continue to adequately identify the licensee and describe the proposed activity. The areas of review included: (1) corporate identity; (2) site location; (3) other reservation activities; (4) foreign ownership control and influence; (5) financial analysis; (6) special exemptions or special authorizations; (7) security of classified information; (8) physical security; (9) transportation security; (10) applicable codes and standards; and (11) license application regulatory guidance documents.

1.4.2 Regulatory Requirements The regulations in 10 CFR 70.22 require each application for a license to include:

(a) information on the corporation applying for a license; (b) the location of the principal office; (c) the names and citizenship of the principal officers; (d) information concerning ownership and control; (e) the proposed site activities; (f) financial qualifications; and (g) the name, amount, and specifications of the licensed material to be used. The regulations in 10 CFR 70.23(a)(5) require that the applicant appears to be financially qualified to engage in the proposed activities in accordance with the regulations. The regulations in 10 CFR 70.40 place restrictions on the ownership of Centrus and ACO. The regulations in 10 CFR Part 95 contain provisions for obtaining a facility security clearance. The regulations in 10 CFR 140.13b require applicants for uranium enrichment facilities to provide and maintain liability insurance.

1.4.3 Regulatory Guidance and Acceptance Criteria The acceptance criteria applicable to the NRC staffs review of the institutional information section of the application are contained in Section 1.2.4.3 of NUREG-1520 (NRC, 2015).

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1.4.4 Staff Review and Analysis 1.4.4.1 Corporate Identity In the RLA Section 1.2.1 Corporate Identity, ACO states that Centrus is a supplier of various components of nuclear fuel to utilities and advanced engineering, design, and manufacturing services to government and private sector customers. USEC Inc., the predecessor to Centrus, was organized in 1998 under Delaware law in connection with the privatization of the USEC.

Centrus' direct and indirect subsidiaries are also registered companies in the State of Delaware.

The address of the principal office of Centrus (formerly USEC Inc.) was modified from 6903 Rockledge Drive, Bethesda, MD 20817 to 6901 Rockledge Drive, Bethesda, MD 20817.

Centrus is listed on the NYSE American under the symbol LEU. The principal officers were updated to Daniel B. Poneman, President and Chief Executive Officer, and Larry B. Cutlip, Sr.

Vice President, Field Operations.

In September 2008, USEC Inc., the predecessor to Centrus, formed five wholly owned subsidiaries in the State of Delaware to carry out future commercial activities related to the American Centrifuge program. These subsidiaries were intended to own the ACP and equipment, provide operations and maintenance services, manufacture centrifuge machines and conduct ongoing centrifuge research and development. These subsidiaries are American Centrifuge Holdings, LLC (ACH), a direct subsidiary to Centrus, and ACO; American Centrifuge Technology, LLC (ACT); American Centrifuge Manufacturing, LLC (ACM); and American Centrifuge Enrichment, LLC (ACE). ACO is the Licensee and operating organization for the ACP. ACO will operate the HALEU Demonstration Program under the NRC ACP license.

ACOs principal officers, all citizens of the United States, are the same as Centrus principal officers. The workers necessary to operate the centrifuge facilities in Piketon, Ohio, will be employed by ACO or its qualified contractors.

Centrus does not plan for near term deployment of a commercial scale uranium enrichment facility. As a result, Centrus consolidated the ACP operations at its Piketon, Ohio facility.

Centrus has consolidated its technical, engineering, and manufacturing activities at the TMC in Oak Ridge, Tennessee.

The mailing address for ACO at the ACP is:

American Centrifuge Operating, LLC American Centrifuge Plant P. O. Box 628 Piketon, Ohio 45661-0628 1.4.4.2 Site Location The site location continues to be on DOE-owned land in rural Pike County, a sparsely populated area in south-central Ohio. Specifically, the ACP is located on the DOE reservation in the former GCEP facilities. The buildings/facilities and grounds are leased by Centrus from the DOE. ACO in turn subleases the buildings and grounds from Centrus.

1.4.4.3 Other Reservation Activities In the RLA Section 1.2.1.2 Other Reservation Activities, ACO removed its reference to operating the gaseous diffusion plant (GDP) on the DOE reservation because the Part 76 license was 11

terminated by the NRC in October 2011. The NRC staff confirmed that the USEC had complied with all applicable NRC requirements and DOE accepted the return of the leased facilities (NRC, 2015a). ACO updated the commercial ACP LA to include: (1) DOEs ongoing decommissioning activities for the GDP on the reservation, which are led by Fluor-BWXT Portsmouth, LLC, and (2) the conversion of depleted UF6 (DUF6) to a stable oxide being undertaken by Mid-America Conversion Services, LLC. ACO also removed the reference to the Ohio National Guards use of an area on the reservation because the Guard is no longer present on the Reservation. ACO also added that Pixelle Specialty Solutions, formerly Glatfelter Specialty Papers, operates a lumberyard on the north edge of the DOE reservation.

This facility is a sorting and transfer area for commercial and paper grade lumber.

1.4.4.4 Foreign Ownership, Control, or Influence (FOCI) 10 CFR 95.17 states, in part, that prior to granting a facility clearance the NRC must determine that a facility is not under foreign ownership, control, or influence to such a degree that granting the facility clearance would be inconsistent with the national interest. Prior to issuing the facility clearance for the Piketon facility on October 30, 2020, the NRC conducted a FOCI review of ACO and its parent company Centrus. On August 14, 2020, as documented in a non-public letter from the NRC to ACO, the NRC staff determined that ACOs FOCI will not pose an undue risk to national security.

1.5 FINANCIAL ANALYSIS 1.5.1 Purpose of the Review The NRC staffs review of ACOs financial analysis and liability insurance evaluates whether the RLA adequately describes the changes and updates made to the financial information approved by the NRC staff for the ACP LA (NRC, 2007).

1.5.2 Financial Qualification and Liability Insurance Requirements The regulations in 10 CFR 70.23(a)(5) require that, when determined necessary, the NRC must determine whether the applicant appears financially qualified to engage in the proposed activities. The regulations in 10 CFR 70.22(n) and 10 CFR 140.13b establish requirements for liability insurance for uranium enrichment facilities.

1.5.3 Financial Qualification and Liability Insurance Guidance The guidance and acceptance criteria used to review ACOs financial qualification and liability insurance for uranium enrichment facility are contained in Section 1.2.4 of the SRP (NRC, 2015).

1.5.3.1 Financial Qualifications In Section 1.2.2 Financial Qualification of the RLA, ACO states that under the HALEU Demonstration Contract (ACO, 2019), DOE agreed to reimburse ACO for 80 percent of its costs 12