ML18130A779

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LAR 17-05 LES License Amendment 80 (Public) Rev 5 10 2018
ML18130A779
Person / Time
Site: 07003103
Issue date: 05/24/2018
From: Jacob Zimmerman
NRC/NMSS/DFCSE/ECB
To: Padgett W
Louisiana Energy Services, URENCO USA
Sturzebecher K
Shared Package
ML18130A778 List:
References
Download: ML18130A779 (13)
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OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION NRC FORM 374 Page 1 of 13 U.S. NUCLEAR REGULATORY COMMISSION MATERIALS LICENSE Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974 (Public Law 93-438), and Title 10, Code of Federal Regulations, Chapter I, Parts 30, 31, 32, 33, 34, 35, 36, 39, 40, and 70, and in reliance on statements and representations heretofore made by the licensee, a license is hereby issued authorizing the licensee to receive, acquire, possess, and transfer byproduct, source, and special nuclear material designated below; to use such material for the purpose(s) and at the place(s) designated below; to deliver or transfer such material to persons authorized to receive it in accordance with the regulations of the applicable Part(s). This license shall be deemed to contain the conditions specified in Section 183 of the Atomic Energy Act of 1954, as amended, and is subject to all applicable rules, regulations, and orders of the U.S. Nuclear Regulatory Commission now or hereafter in effect and to any conditions specified below.

Licensee

1. Louisiana Energy Services, LLC 3. License Number: SNM-2010, Amendment 80
2. 275 Highway 176
4. Expiration Date: See Condition 13 P.O. Box 1789 5. Docket No. 70-3103 Eunice, New Mexico 88231
6. Source and/or Special 7. Chemical and/or Physical 8. Maximum amount that licensee Nuclear Material and/or Form may possess at any one time Byproduct Material under this license A. Uranium A.1 Physical: Solid, Liquid, A. 251,000,000 kg (natural and depleted) and daughter products A.2 Chemical: UF6, UF4, UO2F2, oxides and other compounds B. Uranium enriched in isotope B.1 Physical: Solid, Liquid, B. [REDACTED]

U-235 up to 5.5 percent by and Gas weight (wt. percent) and uranium daughters, subject to the following additional B.2 Chemical: UF6, UF4, constraints: UO2F2, oxides, metal and other compounds URENCO USA Facility (UUSA) shall not produce product material in excess of 5.5 wt. percent U-235 other than in the course of cascade performance adjustments, thus providing the operational flexibility to generate material to satisfactorily fulfill customer orders up to the 5.0 wt. percent U-235 limit. UUSA shall not input parameters into the plant control system to produce material for the assay above the 5.0 wt.

percent limit.

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION Enclosure 3

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION NRC FORM 374A U.S. NUCLEAR REGULATORY COMMISSION Page 2 of 13 License Number SNM-2010 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-3103 Amendment 80 C. Tc-99, transuranic C. Any C. Amount that exists as isotopes and other contamination as a contamination consequence of the historical feed of recycled Uranium at other facilities D. Deleted D. Deleted D. Deleted E. Deleted E. Deleted E. Deleted F. Deleted F. Deleted F. Deleted G. Co-60 G. Sealed per §30.32(g)(1) G. [REDACTED]

H. Deleted H. Deleted H. Delete I. Deleted I. Deleted I. Deleted J. Deleted J. Deleted J. Deleted K. Sr-90 K. Sealed per §30.32(g)(1) K. [REDACTED]

L. Deleted L. Deleted L. Deleted M. Deleted M. Deleted M. Deleted N. Deleted N. Deleted N. Deleted O. Deleted O. Deleted O. Deleted P. Deleted P. Deleted P. Deleted Q. Cs-137 Q. Sealed per §30.32(g)(1) Q. [REDACTED]

R. Deleted R. Deleted R. Deleted S. Po-210 S. Sealed per §30.32(g)(1) S. [REDACTED]

T. Th-230 T. Sealed per §30.32(g)(1) T. [REDACTED]

U. U-232 U. Sealed per §30.32(g)(1) U. [REDACTED]

V. U-233 V. Sealed per §30.32(g)(1) V. [REDACTED]

W. U-234 W. Sealed per §30.32(g)(1) W. [REDACTED]

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION NRC FORM 374A U.S. NUCLEAR REGULATORY COMMISSION Page 3 of 13 License Number SNM-2010 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-3103 Amendment 80 X. U-235 X. Sealed per §30.32(g)(1) X. [REDACTED]

Y. U-236 Y. Sealed per §30.32(g)(1) Y. [REDACTED]

Z. U-238 Z. Sealed per §30.32(g)(1) Z. [REDACTED]

AA. Am-241 AA. Sealed per §30.32(g)(1) AA. [REDACTED]

BB. Cf-252 BB. Sealed per §30.32(g)(1) BB. [REDACTED]

CC. Cs-139 CC. Sealed per §30.32(g)(1) CC. [REDACTED]

DD. Co-60 DD. Unsealed per §30.32(i)(1)(ii) DD. [REDACTED]

EE. Sr-90 EE. Unsealed per §30.32(i)(1)(ii) EE. [REDACTED]

FF. Cs-137 FF. Unsealed per §30.32(i)(1)(ii) FF. [REDACTED]

GG. Po-210 GG. Unsealed per §30.32(i)(1)(ii) GG. [REDACTED]

HH. Th-230 HH. Unsealed per §30.32(i)(1)(ii) HH. [REDACTED]

II. U-232 II. Unsealed per §30.32(i)(1)(ii) II. [REDACTED]

JJ. U-233 JJ. Unsealed per §30.32(i)(1)(ii) JJ. [REDACTED]

KK. U-234 KK. Unsealed per §30.32(i)(1)(ii) KK. [REDACTED]

LL. U-235 LL. Unsealed per §30.32(i)(1)(ii) LL. [REDACTED]

MM. U-236 MM. Unsealed per §30.32(i)(1)(ii) MM. [REDACTED]

NN. U-238 NN.Unsealed per §30.32(i)(1)(ii) NN. [REDACTED]

OO. Am-241 OO. Unsealed per §30.32(i)(1)(ii) OO. [REDACTED]

PP. Cs-139 PP. Unsealed per §30.32(i)(1)(ii) PP. [REDACTED]

QQ. Eu-152 QQ. Sealed per §30.32(g)(1) QQ. [REDACTED]

RR. Ba-133 RR. Sealed per §30.32(g)(1) RR. [REDACTED]

SS. TC-99 SS. Sealed per §30.32(g)(1) SS. [REDACTED]

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION NRC FORM 374A U.S. NUCLEAR REGULATORY COMMISSION Page 4 of 13 License Number SNM-2010 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-3103 Amendment 80

9. Authorized place of use: UUSA, located 5 miles east of Eunice, New Mexico, on Highway 176 in Lea County, New Mexico.
10. The licensee shall conduct authorized activities at the National Enrichment Facility (NEF) in accordance with the statements, representations, and conditions, or as revised in accordance with Section 19 of the Quality Assurance Program Description (QADP), Title 10 of the Code of Federal Regulations (10 CFR)

Paragraph 40.35(f), 10 CFR Section 51.22, 10 CFR Section 70.32, 10 CFR Section 70.72, or 10 CFR Section 95.19 in:

a. Application for Material License, U.S. Nuclear Regulatory Commission (NRC) Form 313 dated December 12, 2003.
b. Safety Analysis Report (SAR) dated December 12, 2003, as revised by letters dated February 27, 2004; July 30, 2004; September 30, 2004; April 22, 2005; April 29, 2005; May 25, 2005; June 10, 2005; February 16, 2006; February 28, 2006; March 16, 2006; March 24, 2006; January 29, 2007; April 10, 2007; July 30, 2007, October 12, 2007; October 19, 2007; November 2, 2007; November 12, 2007; November 30, 2007; February 28, 2008; November 19, 2008; January 23, 2009; March 5, 2009; September 24, 2009; November 25, 2009; January 29, 2010; March 31, 2010; May 2, 2010; May 16, 2010; May 23, 2010; May 25, 2010; May 26, 2010; June 2, 2010; June 3, 2010; June 23, 2010; July 16, 2010; March 22, 2011; March 29, 2011; April 11, 2011; September 19, 2011; and September 22, 2011.
c. Deleted per Amendment 70.
d. Physical Security Plan dated December 12, 2003, as revised by letters dated May 12, 2004; July 30, 2004; December 10, 2004; January 12, 2005; February 12, 2008; August 11, 2008; May 1, 2009; July 16, 2009, February 5, 2010, September 20, 2010, and October 2, 2015.
e. Fundamental Nuclear Material Control Plan dated December 12, 2003, as revised by letters dated February 27, 2004; July 30, 2004; October 7, 2004; December 7, 2004; April 22, 2005; October 23, 2006; October 19, 2007; November 30, 2007; September 4, 2009; and September 24, 2009; January 13, 2010; January 14, 2010; June 30, 2010; November 12, 2010; April 7, 2011; May 3, 2011; June 1, 2011; and June 28, 2011.
f. QADP dated April 9, 2004, as revised by letter dated April 22, 2005; October 23, 2006; November 12, 2007; July 30, 2007, October 12, 2007, October 19, 2007; November 12, 2007; July 31, 2008; January 21, 2009; March 2, 2009; March 5, 2009; September 24, 2009; November 25, 2009; January 29, 2010; March 31, 2010; and June 23, 2010; July 16, 2010; October 1, 2010; December 10, 2010; December 16, 2010; June 21, 2011; August 17, 2011; September 19, 2011, and October 15, 2013. Exception to license condition 10.f is granted for the Cylinder Receipt and Dispatch Building superstructure/footers, as amended by correspondence dated October 14, 2011.
g. Emergency Plan dated December 12, 2003, as revised by letters dated July 30, 2004; September 30, 2004; April 22, 2005; October 23, 2006; July 30, 2007; October 19, 2007; November 2, 2007; March 10, 2008; September 4, 2008; September 30, 2008, February 19, 2009, March 5, 2009; April 16, 2009; September 24, 2009; November 25, 2009; January 29, 2010; March 31, 2010; June 21, 2011; August 17, 2011 and September 19, 2011.
h. Standard Practice Procedure Plan (SPPP) for the Protection of Classified Matter dated December 12, 2003, as revised by correspondence dated July 30, 2004; March 16, 2006; November 21, 2006; November 22, 2006; March 20, 2007; April 27, 2007; July 19, 2007; OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION NRC FORM 374A U.S. NUCLEAR REGULATORY COMMISSION Page 5 of 13 License Number SNM-2010 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-3103 Amendment 80 October 12, 2007; November 30, 2007; February 4, 2008; May 1, 2008; May 7, 2008; June 26, 2008; July 7, 2008; August 4, 2008; September 4, 2008; September 5, 2008; October 6, 2008; October 16, 2008; November 20, 2008; November 25, 2008; February 12, 2009; March 2, 2009; December 29, 2009; May 25, 2010; July 15, 2010; October 22, 2010; February 11, 2011; and March 8, 2011; April 19, 2011; May 20, 2011; May 25, 2011; June 29, 2011; July 18, 2011; December 21, 2011; October 7, 2015; and February 29, 2016.

i. SPPP for the Protection of Classified Matter at the Enrichment Technologies-United States.

Location of the NEF dated October 11, 2007, as revised by letters dated December 3, 2007; April 21, 2008; July 2, 2008; October 8, 2008; October 29, 2008; November 26, 2008; March 26, 2009; August 30, 2009; December 11, 2009; December 29, 2009; January 15, 2010; May 11, 2010; August 5, 2010; September 13, 2010; October 27, 2010; and November 22, 2010; February 11, 2011; April 29, 2011; May 31, 2011; December 21, 2011; and September 14, 2015.

j. Deleted per Amendment 64.
k. Movement Plan for Transportation of Classified Centrifuge Components/Materials between Tripartite Countries and the US dated February 26, 2008, as revised by letter dated December 8, 2017.
l. Deleted per Amendment 80.
m. Deleted.
n. Deleted Per Amendment 75.
o. Deleted per Amendment 64.
p. Deleted per Amendment 64.
q. Notwithstanding the commitments in Sections 2.0 and 3.0 of the Fundamental Nuclear Material Control Plan identified in Condition 10 to use certified reference standards, the licensee shall have until August 1, 2010, to fulfill the above-stated commitments relative to the use of well characterized materials for its instrument calibration identified in the February 1, 2010, request letter.
r. Information SSP for the High Assurance Guard, LES ISSP 3.0, dated February 1, 2010, as revised by correspondence dated March 19, 2010.
s. Deleted per Amendment 64.
t. Deleted per Amendment 64.
u. Deleted per Amendment 64.
v. Deleted per Amendment 64.
w. Deleted per Amendment 64.
x. Notwithstanding the requirements of 10 CFR 74.33(c)(4)(i) and Section 5.3.1 of the Fundamental Nuclear Material Control Plan identified in Condition 10.e. to perform bimonthly dynamic physical inventories for the Centrifuge Test Facility (CTF), the licensee shall have until the completion of the CTF conversion to resume its inventory program for the CTF area as identified in the August 4, 2010, request letter. This exemption will expire when the CTF conversion is complete.
y. The licensee is granted a waiver to the U.S. Department of Energy (DOE) National Security System Manual, paragraph EN-10 of DOE M 205.1-4, for external labeling of junction boxes for Louisiana Energy Services (LES) Information system security plan (ISSP) 1.0. The conditions to which this waiver applies are covered under the Standard Practice Procedure Plan (SPPP) for Protection of Classified Matter.
z. URENCO USA Facility, Classified Plant Management System, Information System Security Plan, (UUSA-CPM-ISSP) Revision 3, dated March 21, 2015.

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION NRC FORM 374A U.S. NUCLEAR REGULATORY COMMISSION Page 6 of 13 License Number SNM-2010 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-3103 Amendment 80 aa. URENCO USA Facility, Encrypted Point to Point Data Exchange, Information System Security Plan, (UUSA-P2P-ISSP) Revision 1, dated April 14, 2015, subject to revision to integrity setting for the Point to Point Data Exchange from Secure Hash Algorithm (SHA) -1 to, at least, SHA-256 setting as required by the Committee on National Security Systems (CNSS) Policy Number 15, National Information Assurance Policy on the Use of Public Standards for the Secure Sharing of Information Among National Security Systems, dated October 1, 2012. This revision must be made no later than October 1, 2015, with a letter of confirmation submitted to the NRC upon completion.

ab. URENCO USA Facility, Plant Control System, Information System Security Plan, (UUSA-PCS-ISSP)Revision 1, dated April 14, 2015.

ac. URENCO USA Facility, Centrifuge Monitoring System, and Medium Frequency Drive, Information System Security Plan (UUSA-CMS- MFD-ISSP), Revision 1, dated April 14, 2015.

ad. URENCO USA Facility, Plant Control Training System and Enhanced Training System Information System Security Plan, (UUSA-PCTS-ETS-ISSP) Revision 1, dated April 14, 2015.

ae. UUSA Information System Security Baseline Common Control Catalog, Revision 1, dated April 14, 2015.

11. Introduction of UF6 into any module of the NEF shall not occur until the Commission completes an operational readiness and management measures verification review to verify that management measures that ensure compliance with the performance requirements of 10 CFR Section 70.61 have been implemented and confirms that the facility has been constructed and will be operated safely and in accordance with the requirements of the license. The licensee shall provide the Commission with 120 days advance notice of its plan to introduce UF6 in any module of the NEF.
12. The licensee is hereby granted the special authorizations and exemptions identified in Section 1.2.5 of the UUSA Safety Evaluation Report, dated June 2013.
13. This license was originally issued for a period of 30 years from the date of license issuance. Based on an amendment request dated May 6, 2011, the license expiration date has been extended to June 9, 2040.
14. For the disposition of depleted UF6 (DUF6) the licensee shall not use a DUF6 deconversion facility that employs a process that results in the production of anhydrous hydrofluoric acid.
15. a. The licensee shall provide proof of $5 million liability insurance, as required under 10 CFR Paragraph 140.13b, at least 30 days prior to the planned date for obtaining possession of test material (less than or equal to 50 kg) of depleted or natural UF6.
b. The licensee shall provide proof of full liability insurance, as required under 10 CFR Paragraph 140.13b, at least 30 days prior to the planned date for obtaining feed material (greater than 50 kg UF6). If the licensee is proposing to provide less than $300 million of liability insurance coverage, the licensee shall provide, to the NRC for review and approval, an evaluation supporting liability insurance coverage in amounts less than $300 million, at least 120 days prior to the planned date for obtaining feed material.
16. a & b Deleted OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION NRC FORM 374A U.S. NUCLEAR REGULATORY COMMISSION Page 7 of 13 License Number SNM-2010 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-3103 Amendment 80

c. The licensee shall provide an updated Decommissioning Funding Plan, including a decommissioning cost estimate update and final copies of the proposed financial assurance instruments, to NRC for review at least 6 months prior to initiating operations in the next cascade in an Assay Unit within any subsequent separation building module (SBM) or licensed material into CRDB-2. Final executed copies of the reviewed financial assurance instruments, along with a revised certification of financial assurance reflecting the updated amount of the financial assurance instruments, shall be provided to NRC at least 21 days prior to initiating operations in the next cascade. For the first cascade in a new SBM, the Decommissioning Funding Plan update must provide for full funding for decontamination and decommissioning of the SBM structure, first cascade, and the common equipment of the new Assay Unit. The amount of the financial assurance instrument shall be updated to current year dollars and include any applicable changes to the decommissioning cost estimate.
d. After the first three years of initial plant production, subsequent updated decommissioning cost estimates and revised funding instruments for depleted uranium disposition shall be provided annually on a forward-looking basis to reflect projections of depleted uranium byproduct generation. The depleted uranium disposition cost estimate shall include an update to the DOE depleted uranium disposition cost estimate. The total amount funded for depleted uranium disposition shall be no less than the updated DOE cost estimate.
17. Deleted
18. Deleted
19. To define the boundaries of each item relied on for safety (IROFS), the licensee shall utilize its procedure, IROFS Boundary Definitions. Completed IROFS boundaries for all IROFS shall be available for inspection at the time of the operational readiness review.
20. [REDACTED] Should the design of any IROFS be changed to include any of the preceding features, the licensee shall obtain Commission approval prior to implementing the change(s). The licensees design change(s) shall adhere to accepted best practices in software and hardware engineering, including software quality assurance controls as discussed in the Quality Assurance Program Description throughout the development process and the applicable guidance of the following industry standards and regulatory guides as specified in SAR Chapter 3:
a. American Society of Mechanical Engineers (ASME) NQA-1-1994, Part II, subpart Part 2.7, Quality Assurance Requirements of Computer Software for Nuclear Facility Applications, as revised by NQA-1a-1995 Addenda of NQA-1-1994 and ASME NQA-1-1994, Part 1, Supplement 11S-2, Supplementary Requirements for Computer Program Testing. (Refer to SAR Chapter 11, Appendix A, Section 3).
b. Electric Power Research Institute (EPRI) NP-5652, Guideline for the Utilization of Commercial Grade Items in Nuclear Safety Grade Applications, June 1988.

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION NRC FORM 374A U.S. NUCLEAR REGULATORY COMMISSION Page 8 of 13 License Number SNM-2010 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-3103 Amendment 80

c. EPRI Topical Report (TR) -102323, Guidelines for Electromagnetic Interference Testing in Power Plants, Revision 1, December 1996.
d. EPRI TR-106439, Guideline on Evaluation and Acceptance of Commercial Grade Digital Equipment for Nuclear Safety Applications, October 1996.
e. Regulatory Guide 1.152, Criteria for Digital Computers in Safety Systems in Nuclear Power Plants, Revision 1, January 1996.
f. Regulatory Guide 1.168, Verification, Validation, Reviews, and Audits for Digital Software Used in Safety Systems of Nuclear Power Plants, Revision 1, February 2004.
g. Regulatory Guide 1.169, Configuration Management Plans for Digital Computer Software Used in Safety Systems of Nuclear Power Plants, September 1997.
h. Regulatory Guide 1.170, Software Test Documentation for Digital Computer Software Used in Safety Systems of Nuclear Power Plants, September 1997.
i. Regulatory Guide 1.172, Software Requirements Specifications for Digital Computer Software Used in Safety Systems of Nuclear Power Plants, September 1997.
j. Regulatory Guide 1.173, Developing Software Life Cycle Processes for Digital Computer Software Used in Safety Systems of Nuclear Power Plants, September 1997.

If any above changes result in IROFS requiring operator actions, a human factors engineering review of the human-system interfaces shall be conducted using the applicable guidance in NUREG-0700, Human-System Interface Design Review Guidelines, Revision 2, dated May 2002 (NRC, 2002d), and NUREG-0711, Human Factors Engineering Program Review Model, Revision 2, dated February 2004.

[REDACTED].

21. Onsite storage of DUF6 generated at the NEF shall be limited to a maximum of 25,000 48Y cylinders (or the equivalent amount of uranium stored in other NRC accepted and Department of Transportation

[DOT] certified cylinder types) of DUF6. The generation of any additional DUF6 to be stored onsite by the licensee beyond this limit shall constitute noncompliance with the license. The licensee shall suspend production of any additional DUF6 for onsite storage until this noncompliance is remedied. In no event shall the licensee store DUF6 generated at the NEF in New Mexico other than at the NEF.

22. Onsite storage of any one cylinder of DUF6 generated at the NEF shall be limited to a maximum of 25 years, beginning from the date that each cylinder is filled in accordance with the licensees standard procedures. The storage of any one DUF6 cylinder beyond this limit by the licensee shall constitute noncompliance with the license. The licensee shall suspend production of any additional DUF6 for onsite storage until this noncompliance is remedied. In no event shall the licensee store DUF6 generated at the NEF in New Mexico other than at the NEF.

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION NRC FORM 374A U.S. NUCLEAR REGULATORY COMMISSION Page 9 of 13 License Number SNM-2010 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-3103 Amendment 80

23. The licensee shall provide financial assurance for the offsite disposal of DUF6 from the NEF using a minimum contingency factor of twenty-five percent (25 percent).

Upon reaching 24,000 cylinders of DUF6 in 48Y cylinders (or the equivalent amount of uranium stored in other NRC accepted and DOT certified cylinder types) in onsite storage, the licensee shall immediately increase the financial assurance to provide a fifty percent (50 percent) contingency factor for disposition of DUF6 stored at the NEF unless: (a) an application to construct and operate a de-conversion facility outside of New Mexico that is specifically designated to de-convert the DUF6 stored onsite at the NEF has been docketed by the agency responsible for reviewing the application; (b) an application for such a facility has been approved by the agency responsible for reviewing the application; or (c) the licensee is using another alternate method for removing the DUF6 stored onsite.

In addition, upon reaching the limit of 25,000 cylinders of DUF6 in 48Y cylinders (or the equivalent amount of uranium stored in other NRC accepted and DOT certified cylinder types) in onsite storage, the licensee shall immediately increase the financial assurance to provide fifty percent (50 percent) contingency factor for disposition of DUF6 stored at the NEF if the contingency factor has not already been increased to fifty percent (50 percent). The contingency factor shall remain at fifty percent (50 percent) until the number of cylinders stored onsite is reduced to ninety-eight percent (98 percent) of the 25,000 cylinder limit and either: (a) an application to construct and operate a de-conversion facility outside of New Mexico that is specifically designated to de-convert the DUF6 stored onsite at the NEF has been docketed by the agency responsible for reviewing the application; (b) an application for such a facility has been approved by the agency responsible for reviewing the application; or (c) the licensee is using another alternate method for removing the DUF6 from New Mexico.

Nothing herein shall release the licensee from other financial assurance obligations set forth in applicable laws and regulations.

24. The licensee shall maintain and follow the Fundamental Nuclear Material Control Program for control and accounting and measurement control of uranium source material and special nuclear material at the NEF pursuant to 10 CFR Paragraph 74.33(b). The licensee shall make no change to material control procedures essential for the safeguarding of uranium source material or special nuclear material that would decrease the effectiveness of the material control and accounting program implemented pursuant to 10 CFR Paragraph 74.33(b) without prior approval of the Commission. If the licensee desires to make changes that would decrease the effectiveness of its material control and accounting program or its measurement control program, the licensee shall submit an application for amendment to its license pursuant to 10 CFR Section 70.34.

The licensee shall maintain records of changes to the material control and accounting program made without prior Commission approval a period of five years from the date of the change. The licensee shall furnish to the Director, Division of Nuclear Security, Office Nuclear Security and Incident Response, using an appropriate method listed in 10 CFR 70.5(a), a report containing a description of each change within six months of the change if it pertains to uranium enriched less than 20 percent in the uranium-235 isotope.

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION NRC FORM 374A U.S. NUCLEAR REGULATORY COMMISSION Page 10 of 13 License Number SNM-2010 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-3103 Amendment 80

25. If there are any revisions to the nuclear criticality safety validation report, then the licensee shall provide a letter to NRC describing the changes and shall provide the revised validation report upon request.

The licensee may not implement the changes in the revised validation report until NRC approves the changes.

26. The licensee shall not use, process, store, reproduce, transmit, handle, or allow access to classified matter except provided by applicable personnel and facility clearances as required under 10 CFR Part 95.
27. [REDACTED]
28. The Licensee is exempted from the definitions of a commercial grade item, basic component, critical characteristics, dedicating entity, and dedication in 10 CFR Section 21.3, as replaced by the following:

Commercial grade item: A commercial grade item means a structure, system, or component, or part thereof that affects its IROFS function that was not designed and manufactured as a basic component.

Commercial grade items do not include items where the design and manufacturing process require in-process inspections and verifications to ensure that defects or failures to comply are identified and corrected (i.e., one or more critical characteristics of the item cannot be verified).

Basic component: A basic component means a structure, system, or component, or part thereof that affects their IROFS function, that is directly procured by the licensee or activity subject to the regulations in part 70 and in which a defect or failure to comply with any applicable regulation in this chapter, order, or license issued by the Commission would create a substantial safety hazard (i.e., exceed performance requirements of 10 CFR Section 70.61). In all cases, basic components include IROFS-related design, analysis, inspection, testing, fabrication, replacement parts, or consulting services that are associated with the component hardware whether these services are performed by the component supplier or others.

When applied to fire protection systems procured for facilities and other activities licensed under 10 CFR Part 70 of the chapter, basic component means a structure, system, or component, or part thereof, that affects their safety function, in which a defect or failure to comply with any applicable regulation in this chapter, order, or license issued by the Commission could create a substantial safety hazard. For fire protection systems designated as items relied on for safety, a basic component may be directly procured from a commercial entity by a Part 70 licensee if: (1) the system, structure or component is manufactured to an established, acceptable national code or standard that includes some independent product endorsements based on qualification testing or periodic testing of selected characteristics of the component; and (2) the acceptability of the items manufacture, testing, and/or certification has been reviewed and verified by the licensee prior to use as a basic component. Once the acceptability of the item has been verified by LES and the item has been designated for use as a basic component, the licensee accepts responsibility for Part 21 reporting.

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION NRC FORM 374A U.S. NUCLEAR REGULATORY COMMISSION Page 11 of 13 License Number SNM-2010 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-3103 Amendment 80 Critical characteristics: Critical characteristics are those important design, material, and performance characteristics of a commercial grade item that, once verified, will provide reasonable assurance that the item will perform its intended IROFS function.

Dedication: Dedication is an acceptance process undertaken to provide reasonable assurance that a commercial grade item to be used as a basic component will perform its intended IROFS function and, in this respect, is deemed equivalent to an item designed and manufactured under a 10 CFR Part 50, Appendix B, Quality Assurance Program. This assurance is achieved by identifying the critical characteristics of the item and verifying their acceptability by inspections, tests, or analyses performed by the purchaser or third-party dedicating entity after delivery, supplemented as necessary by one or more of the following: commercial grade surveys, product inspections or witness at holdpoints at the manufacturers facility, and analysis of historical records for acceptable performance. In all cases, the dedication process must be conducted in accordance with the applicable provisions of 10 CFR Part 50, Appendix B. The process is considered complete when the item is designated for use as a basic component.

Dedicating entity: Dedicating entity means the organization that performs the dedication process.

Dedication may be performed by the manufacturer of the item, a third-party dedicating entity, or the licensee itself. The dedicating entity, pursuant to Section 21.21(c) of this part, is responsible for identifying and evaluating deviations, reporting defects and failure to comply for the dedicated item, and maintaining auditable records of the dedication process. In cases where the licensee applies the commercial grade item procurement strategy and performs the dedication process, the licensee would assume full responsibility as the dedicating entity.

Prior to implementing the above commercial grade procurement strategy and dedication process, the licensee shall submit a license amendment request to the NRC for approval amending its Quality Assurance Program Description to include its commitments described in its exemption request submittals dated November 21, 2008, and November 24, 2008.

29. Deleted.
30. The licensee is granted the special authorization as requested in correspondence dated May 24, 2012, (LES-12-00074-NRC). Specifically:

a) The licensee shall not make changes to the SAR, without prior NRC approval unless the criteria in paragraph b are satisfied. For changes requiring prior NRC approval, the licensee shall submit to the NRC, for review and approval, an application to amend the license. Such changes shall not be implemented until approval is granted unless prior written Authorization is provided by the NRC.

b) Upon documented completion of a change request for a facility or process, the licensee may make changes in the facility or process as presented in the SAR, or conduct tests or activities not presented in the SAR that would normally be described therein, without prior NRC approval, subject to the following conditions:

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION

OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION NRC FORM 374A U.S. NUCLEAR REGULATORY COMMISSION Page 12 of 13 License Number SNM-2010 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-3103 Amendment 80

1. There is no decrease in the level of effectiveness of the design basis for safety functions as described in the SAR, and;
2. The change does not result in a departure from a method of evaluation described in the SAR used in establishing the design bases for safety functions, and;
3. The change does not result in a decrease in effectiveness of safety commitments as described in the SAR, and;
4. The change does not affect compliance with applicable regulatory safety requirements, and;
5. The change does not conflict with any condition specifically stated in LES Materials License SNM-2010.

Changes to the SAR shall be evaluated, documented and reported in accordance with the commitments in Enclosure 1 of correspondence dated May 24, 2012 (LES-12-00074-NRC). Records of such changes shall be maintained, including technical justification and management approval, in dedicated records to enable NRC inspection upon request at the facility. A periodic report containing a description of each such change, and appropriate revised sections to the license application, shall be submitted to the NRC every six months.

31. Prior to designating areas where the dissemination of classified information will routinely occur, NRC will be notified to determine if additional security measures are required. If NRC does determine the need for additional security measures, an amendment request must be submitted, and approved, prior to establishment and use of the area(s).
32. Notwithstanding the requirements for labeling of containers in 10 CFR Paragraph 20.1904(a), UF6 feed, tails, and product cylinders (48Y and 30B) do not require labeling. Waste containers and contaminated equipment staged in Restricted Areas may be simply labeled as caution - radioactive material or the equivalent.
33. The licensee is exempted from the specific requirement in 10 CFR Paragraph 70.24(a) requiring gamma or neutron sensitive radiation detectors in the existing Cascade Halls and proposed future Cascade Halls that are designed consistent with the halls analyzed in LAR 13-01. This exemption is also granted for Outdoor 30B Cylinder Storage Areas as discussed in LAR 17-03.

SECTION 3.0 -- INTERNATIONAL SAFEGUARDS SG-3.1 [REDACTED]

SG-3.2 [REDACTED]

SG-3.3 [REDACTED]

SG-3.4 [REDACTED]

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OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION NRC FORM 374A U.S. NUCLEAR REGULATORY COMMISSION Page 13 of 13 License Number SNM-2010 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-3103 Amendment 80 FOR THE U.S. NUCLEAR REGULATORY COMMISSION Date: May 24, 2018 By: ____/RA/___________________

Jacob I. Zimmerman, Chief Enrichment and Conversion Branch Division of Fuel Cycle Safety, Safeguards, and Environmental Review Office of Nuclear Material Safety and Safeguards OFFICIAL USE OFFICIAL ONLY - SECURITY - RELATED INFORMATION

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