ML21292A285

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Enclosure 4: Centrus Digital I&C IROFS Acp Lic Amd 17
ML21292A285
Person / Time
Site: 07007004
Issue date: 04/28/2022
From: Jacob Zimmerman
NRC/NMSS/DFM/FFLB
To:
American Centrifuge Operating
Jenny Tobin NMSS/DFM/FFL 301-415-2328
Shared Package
ML21292A281 List:
References
Download: ML21292A285 (12)
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NRC FORM Page 1 of 12 374 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 11, 30, 31, 32, 33, 34, 35, 36, 39, 40, 70, 73, and 74 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. American Centrifuge Operating, LLC 3. License Number: SNM-2011, Amendment 17
2. American Centrifuge Plant 4. Expiration Date: See Condition 13 P.O. Box 628
5. Docket No. 70-7004 Piketon, Ohio 45661-0628 Commercial ACP Possession Limits
6. Source, Special Nuclear 7. Chemical and/or Physical 8. Maximum amount that Material, By-product Material Form Under This License Licensee May Possess at any One Time A. Uranium A.1 Physical: Solid, Liquid, A. [Security-Related (natural and depleted) and Gas Information and daughter products Withheld Under A.2 Chemical: UF6, UF4, 10 CFR 2.390]

UO2F2, oxides, metal, and other compounds B. Uranium enriched in B.1 Physical: Solid, Liquid, B. [Security-Related isotope U-235 up to and Gas Information 10 percent by weight and Withheld Under uranium daughters B.2 Chemical: UF6, UF4, 10 CFR 2.390]

UO2F2, oxides, metal, and other compounds C. Tc-99, transuranic C. Any C. [Security-Related isotopes and other Information contamination Withheld Under 10 CFR 2.390]

Enclosure 4

Page 2 of 12 U.S. NUCLEAR REGULATORY COMMISSION License Number SNM-2011, Amendment 17 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-7004 D. Source Material D.1 Physical: Solid, Liquid D. [Security-Related isotopes and other (excluding UF6) Information contamination Withheld Under D.2 Soluble and insoluble 10 CFR 2.390]

Chemicals, metal E. Uranium enriched in E.1 Physical: Solid, Liquid, E. [Security-Related isotope U-235 from 10 percent and Gas Information to 20 percent by weight and Withheld Under uranium daughters E.2 Chemical: UF6, UF4, 10 CFR 2.390]

UO2F2, oxides, metal, and other compounds F. Uranium enriched in F.1 Physical: Solid, Liquid, F. [Security-Related isotope U-235 from 20 percent and Gas Information to 98 percent by weight and Withheld Under uranium daughters F.2 Chemical: UF6, UF4, 10 CFR 2.390]

UO2F2, oxides, metal, and other compounds G. Special Nuclear Material G. Any G. [Security-Related Information Withheld Under 10 CFR 2.390]

H. Special Nuclear Material H. Any H. [Security-Related Source Information Withheld Under 10 CFR 2.390]

I. By-product Material I. Any I. [Security-Related Information Withheld Under 10 CFR 2.390]

HALEU Demonstration Program Possession Limits 6.a. Source, Special Nuclear 7a. Chemical and/or Physical 8a. Maximum amount that Material, By-product Material Form Under This License Licensee May Possess at any One Time A. Uranium (non-fissile) A.1 Physical: Solid, Liquid A. [Security-Related and daughter products (excluding UF6), and Gas Information Withheld Under 10 CFR 2.390]

A.2 Chemical: UF6, UF4, UO2F2, oxides, metal, and other compounds

Page 3 of 12 U.S. NUCLEAR REGULATORY COMMISSION License Number SNM-2011, Amendment 17 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-7004 B. Source Material B.1 Physical: Solid, Liquid B. [Security-Related isotopes and other (excluding UF6) Information Withheld contamination Under 10 CFR 2.390]

B.2 Soluble and insoluble chemicals, metal C. Special Nuclear Material C.1 Physical: Solid, Liquid C. [Security-Related Uranium enriched in isotope (excluding UF6), and Gas Information Withheld 235 U up to 5 percent by weight Under 10 CFR 2.390]

and uranium daughters C.2 Chemical: UF6, UF4, UO2F2, oxides, metal, and other compounds D. Special Nuclear Material D.1 Physical: Solid, Liquid D. [Security-Related Uranium enriched in isotope (excluding UF6), and Gas Information Withheld 235 U from 5 up to but less Under 10 CFR 2.390]

than 20 percent by weight D.2 Chemical: UF6, UF4, UO2F2, oxides, metal, and other compounds E. Special Nuclear Material E.1 Physical: Solid, and E. [Security-Related Uranium enriched in isotope Gas Information Withheld 235 U from 20 up to 25 percent Under 10 CFR 2.390]

by weight E.2 Chemical: UF6, UF4, UO2F2, oxides, and other compounds F. Special Nuclear Material F. Sealed Source F. [Security-Related Plutonium Information Withheld Under 10 CFR 2.390]

G. Special Nuclear Material G. Unsealed Source G. [Security-Related Plutonium Information Withheld Under 10 CFR 2.390]

H. Special Nuclear Material H. Process Contaminants H. [Security-Related Americium Information Withheld Under 10 CFR 2.390]

I. By-product Material I. Any I. [Security-Related Information Withheld Under 10 CFR 2.390]

Page 4 of 12 U.S. NUCLEAR REGULATORY COMMISSION License Number SNM-2011, Amendment 17 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-7004

9. Authorized place of use: American Centrifuge Plant (ACP), located on the Portsmouth Department of Energy Reservation in Piketon, Ohio.
10. The licensee shall conduct authorized activities at the ACP in accordance with the statements, representations, and conditions, or as revised in accordance with Section 19 of the Quality Assurance Program Description, 10 CFR Paragraph 40.35(f) and 10 CFR Sections 51.22, 70.32, 70.72, and 95.19 in:
a. Decommissioning Funding Plan dated August 23, 2004, as modified by revisions dated March 14, 2005, May 23, 2005, June 22, 2005, August 30, 2005, September 2, 2005, October 21, 2005, November 30, 2005, March 17, 2006, August 23, 2006, June 16, 2008, January 30, 2009, April 30, 2010, February 28, 2011, and October 27, 2011.
b. Emergency Plan dated August 23, 2004, as modified by revisions dated March 14, 2005, May 23, 2005, June 17, 2005, August 30, 2005, October 7, 2005, November 7, 2005, November 17, 2005, February 17, 2006, June 1, 2006, August 23, 2006, June 26, 2007, January 14, 2008, January 25, 2008, June 16, 2008, January 30, 2009, September 30, 2009, January 20, 2010, April 30, 2010, August 11, 2010, February 28, 2011, April 29, 2011, April 30, 2012, September 10, 2012, February 28, 2013, October 30, 2013, November 27, 2013, February 28, 2014, August 14, 2015, June 30, 2016, and February 2020.
c. Environmental Report dated August 23, 2004, as modified by revisions dated May 4, 2005, June 15, 2005, July 29, 2005, August 16, 2005, October 21, 2005, November 29, 2005, February 17, 2006, August 23, 2006, January 14, 2008, January 25, 2008, June 16, 2008, December 16, 2008, January 30, 2009, January 20, 2010, April 30, 2010, August 11, 2010, and May 25, 2021.
d. Fundamental Nuclear Material Control Plan dated August 23, 2004, as modified by revisions dated March 14, 2005, May 12, 2005, October 7, 2005, February 17, 2006, August 23, 2006, January 25, 2008, June 16, 2008, October 29, 2008, January 30, 2009, April 30, 2010, October 22, 2010, July 11, 2012, September 10, 2012, October 30, 2013, August 14, 2015, December 18, 2015, and May 25, 2021.
e. License Application dated August 23, 2004, as modified by revisions dated March 14, 2005, April 29, 2005, May 23, 2005, June 15, 2005, June 22, 2005, August 30, 2005, September 2, 2005, September 27, 2005, October 7, 2005, November 7, 2005, November 17, 2005, November 30, 2005, December 2, 2005, January 16, 2006, March 17, 2006, June 1, 2006, August 23, 2006, August 31, 2006, September 6, 2006, June 26, 2007, October 11, 2007, January 14, 2008, January 25, 2008, March 5, 2008, June 16, 2008, October 9, 2008, December 16, 2008, January 15, 2009, January 30, 2009, October 28, 2009, January 20, 2010, February 24, 2010, April 30, 2010, June 7, 2010, August 11, 2010, August 30, 2010, October 22, 2010, November 17, 2010, February 28, 2011, March 18, 2011, April 29, 2011, September 15, 2011, October 27, 2011, September 10, 2012,

Page 5 of 12 U.S. NUCLEAR REGULATORY COMMISSION License Number SNM-2011, Amendment 17 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-7004 February 20, 2013, February 28, 2013, September 5, 2013, November 27, 2013, December 30, 2013, February 28, 2014, August 14, 2015, December 18, 2015, June 30, 2016, and May 25, 2021.

f. Quality Assurance Program Description dated August 23, 2004, as modified by revisions dated March 14, 2005, November 7, 2005, February 17, 2006, January 25, 2008, July 18, 2008, October 9, 2008, January 15, 2009, January 30, 2009, June 10, 2009, September 4, 2009, October 28, 2010, April 30, 2010, August 11, 2010, August 30, 2010, November 17, 2010, September 10, 2012, February 20, 2013, August 14, 2015, June 30, 2016, August 31, 2016, December 16, 2016, and May 25, 2021.
g. DELETED by Amendment 13
h. DELETED by Amendment 5
i. DELETED by Amendment 5
j. DELETED by Amendment 2
k. Security Plan for the Protection of Classified Matter at the United States Enrichment Corporation Headquarters in Bethesda, Maryland, dated January 15, 2009 (Revision 12),

as modified by revision dated February 20, 2013 (Revision 13); Security Plan for the Protection of Classified Matter at Centrus Energy Corp. (formerly USEC) Headquarters dated August 2015 (Revision 0); and Security Plan for the Protection of Classified Matter at Centrus Energy Corp. Headquarters dated March 2016 (Revision 0) and October 2019 (Revision 3).

l. DELETED by Amendment 16
m. DELETED by Amendment 16
n. DELETED by Amendment 16
o. Transportation Security Plan for Classified Matter Shipments dated November 25, 2008, as modified by revisions dated April 12, 2010, November 17, 2010, February 28, 2013, March 13, 2017, and September 30, 2020; and in accordance with statements, representations, and conditions, pertaining to the U.S. Nuclear Regulatory Commissions approval of License amendment application dated March 10, 2020.
p. Operations Security Plan 331-06-161, approved January 20, 2012, as modified by revisions dated December 2012 (approved January 25, 2013), December 2013 (approved on April 1, 2014), November 2014 (approved on July 8, 2015), and March 2020 (approved on October 30, 2020).
q. DELETED by Amendment 5

Page 6 of 12 U.S. NUCLEAR REGULATORY COMMISSION License Number SNM-2011, Amendment 17 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-7004

r. DELETED by Amendment 5
s. Security Plan for the Protection of Classified Matter at the American Centrifuge Plant SP-3605-0041 dated October 16, 2020; and in accordance with statements, representations, and conditions, pertaining to the U.S. Nuclear Regulatory Commissions approval of License amendment application dated March 31, 2020.
t. American Centrifuge Operating, LLC (ACO) Information System Security Plan SEC-18-0002 submittal dated September 10, 2020, as modified by submittal dated March 8, 2022; and in accordance with statements, representations, and conditions, pertaining to the U.S. Nuclear Regulatory Commissions approval of License amendment application dated March 31, 2020 for the Piketon facility, February 6, 2020 for the Oak Ridge facility, and October 27, 2021 for the Oak Ridge, Piketon and Bethesda facilities.
u. High Assay Low Enriched Uranium (HALEU) Cascade Engineering, Procurement, and Construction (EPC) Temporary Security Plan SP-3605-0018 dated October 16, 2020; and in accordance with statements, representations, and conditions, pertaining to the U.S.

Nuclear Regulatory Commissions approval of License amendment application dated March 31, 2020.

v. DELETED by Amendment 16
w. Security Program for American Centrifuge Operating, LLC at Oak Ridge, Tennessee NR-SP-ACO-OR-0001 dated September 8, 2020; and in accordance with statements, representations, and conditions, pertaining to the U.S. Nuclear Regulatory Commissions approval of License amendment application dated February 6, 2020.
x. American Centrifuge Operations - Oak Ridge Operations Security Plan PLD1-SP-024PD dated February 5, 2020; and in accordance with statements, representations, and conditions, pertaining to the U.S. Nuclear Regulatory Commissions approval of License amendment application dated February 6, 2020.
y. Security Plan for the Physical Protection of Special Nuclear Material at the American Centrifuge Plant SP-3605-0042 dated May 25, 2021; and in accordance with statements, representations, and conditions, pertaining to the U.S. Nuclear Regulatory Commissions approval of License amendment application dated June 23, 2020.
z. Classified Distributed Control System Information System Security Plan at the American Centrifuge Plant SP-3605-0043 dated August 2021 (Revision 0), and in accordance with statements, representations, and conditions, pertaining to the U.S. Nuclear Regulatory Commissions approval of License amendment application dated December 22, 2020.

aa. American Centrifuge Operating, LLC Classified Process Telephone System (PTS) for X-3001, X-3012 and X-1107E in Piketon, Ohio (Revision 0), SP-3605-0044 dated November 2021, and in accordance with statements, representations, and conditions,

Page 7 of 12 U.S. NUCLEAR REGULATORY COMMISSION License Number SNM-2011, Amendment 17 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-7004 pertaining to the U.S. Nuclear Regulatory Commissions approval of License amendment application dated April 12, 2021.

11. Introduction of UF6 into any module of the ACP, including the HALEU Demonstration cascade, 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 ACP, including the HALEU Demonstration cascade.
12. The licensee is hereby granted the special authorizations and exemptions identified in Section 1.2.5 of the American Centrifuge Plant License Application, dated September 2006, as modified by Revisions dated December 2012, and May 2021.
13. This license will expire on April 13, 2037.
14. American Centrifuge Operating, LLC (ACO) shall provide to the Commission, at least 120 days prior to the planned date for obtaining licensed material, other than material for the HALEU Demonstration Program, documentation of any liability insurance required to be obtained by ACO under its lease with the U.S. Department of Energy (DOE) for the ACP by that time or, alternatively, the status of ACOs efforts to obtain any such liability insurance.

During the time that ACO is engaged in efforts to obtain liability insurance, ACO shall provide the Commission with status reports regarding those efforts. The status reports shall be submitted at a frequency of at least once every six months following issuance of a license.

ACO shall notify the Commission within 30 days upon receiving notification of denial or approval of commercial liability insurance for the ACP. If commercial liability insurance is required to be obtained under its lease with DOE, within 60 days of receiving notification of approval of commercial liability insurance, ACO shall provide proof of liability insurance coverage and a justification, for Commission review and approval, if ACO is proposing to provide less than $300 million of liability insurance coverage.

15. Construction of each incremental phase of the ACP shall not commence before funding for that increment is available or committed. Of this funding, ACO must have in place before constructing such increment, commitments for one or more of the following: equity contributions from ACO, affiliates and/or partners, along with lending and/or lease arrangements that solely or cumulatively are sufficient to ensure funding for the particular increments construction costs. ACO shall make available for NRC inspection, documentation of both the budgeted costs for such phase and the source of funds available or committed to pay those costs.

Operation of the ACP, with the exception of operation of the HALEU demonstration cascade until expiration of DOEs HALEU Demonstration contract on May 31, 2022, shall not commence until the Licensee has in place either: (1) long term contracts lasting five years or more that provide sufficient funding for the estimated cost of operating the facility for the five

Page 8 of 12 U.S. NUCLEAR REGULATORY COMMISSION License Number SNM-2011, Amendment 17 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-7004 year period; (2) documentation of the availability of one or more alternative sources of funds that provide sufficient funding for the estimated cost of operating the facility for five years; or (3) some combination of (1) and (2).

16. ACO shall provide final copies of the proposed financial assurance instruments to NRC for review at least six months prior to the planned date for obtaining licensed material (except for the sealed source and byproduct material calibration sources described in LC 6 and the HALEU demonstration cascade under the lease agreement with DOE ending May 31, 2022),

and provide to NRC final executed copies of the reviewed financial assurance instruments prior to the receipt of licensed material (except for the sealed source and byproduct material calibration sources described in LC 6 and the HALEU demonstration cascade under the lease agreement with DOE ending May 31, 2022). The amount of the financial assurance instrument shall be updated to current year dollars and include any applicable changes to the decommissioning cost estimate. The decommissioning cost estimate shall include an update to ACO's Analysis of Depleted Uranium Disposal Costs for the ACP. To develop this update, ACO shall coordinate with DOE to determine necessary changes to the DOE contractor's depleted uranium cost estimate utilized as input to the ACO specific analysis.

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

(1) The cost estimate for decontamination and removal of the centrifuges shall be provided on an annual forward-looking basis based on planned incremental enrichment capacity increases; and (2) The cost estimate for depleted uranium byproduct generation shall be provided on a projected annual forward-looking basis. The decommissioning cost estimate shall include an update to ACO's Analysis of Depleted Uranium Disposal Costs for the ACP.

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

Once full capacity operation is achieved, the licensee shall provide cost estimates for depleted uranium byproduct generation on an annual forward-looking basis and cost estimates for decontamination and decommissioning the remainder of the facility at intervals not to exceed 3 years, consistent with the requirements of 10 CFR Paragraphs 30.35(e), 40.36(d) and 70.25(e). The DFP cost estimates shall be provided to NRC for review, and subsequently, after resolution of any NRC comments, final executed copies of the financial assurance instruments shall be provided to NRC.

18. ACO shall utilize its procedure, Item Relied on for Safety (IROFS) Boundary Determination Plan, to define the boundaries of each IROFS. Completed IROFS boundaries for all IROFS shall be available for inspection at the time of the operational readiness review.

Page 9 of 12 U.S. NUCLEAR REGULATORY COMMISSION License Number SNM-2011, Amendment 17 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-7004

19. The licensee shall obtain Commission approval prior to implementing new digital technology within IROFS that use digital technology for previously approved process safety applications, or in any other IROFS of the facility. Such digital technology includes the use of software, firmware, microcode, Programmable Logic Controllers, and/or any digital device, including hardware devices which implement data communication protocols (such as fieldbus devices and Local Area Network controllers). The licensee shall also obtain Commission approval prior to implementing a change to Commission-approved IROFS that incorporate digital technology which adds new or alters the characteristics of existing digital technology as described above.

Proposed licensee digital technology change(s) shall comply with 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:

a. American Society of Mechanical Engineers (ASME) NQA-1-2008 with the NQA-la-2009 Addenda, Part I, Requirement 3, "Design Control," Section 800, Requirement 11, "Test Control," and Part II, Subpart 2.7, "Quality Assurance Requirements for Computer Software for Nuclear Facility Applications."
b. Regulatory Guide 1.168, Verification, Validation, Reviews, and Audits for Digital Computer Software Used in Safety Systems of Nuclear Power Plants, Revision 2, July 2013.
c. Regulatory Guide 1.169, Configuration Management Plans for Digital Computer Software Used in Safety Systems of Nuclear Power Plants, Revision 1 July 2013.
d. Regulatory Guide 1.170, Software Test Documentation for Digital Computer Software Used in Safety Systems of Nuclear Power Plants, Revision 1 July 2013.
e. Regulatory Guide 1.172, Software Requirements Specifications for Digital Computer Software Used in Safety Systems of Nuclear Power Plants, Revision 1 July 2013.
f. Regulatory Guide 1.173, Developing Software Life Cycle Processes for Digital Computer Software Used in Safety Systems of Nuclear Power Plants, Revision 1 July 2013.
20. ACO shall provide a minimum 60-day notice to NRC prior to initial customer product withdrawal of licensed material exceeding 5 wt. percent 235U enrichment. This notice

Page 10 of 12 U.S. NUCLEAR REGULATORY COMMISSION License Number SNM-2011, Amendment 17 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-7004 shall identify the necessary equipment and operational changes to support customer product shipment for these assays.

21. 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 ACP 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 for a period of five years from the date of the change. The licensee shall furnish to the Director, Division of Nuclear Security, Office of Nuclear Security and Incident Response, using an appropriate method listed in 10 CFR Paragraph 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 235U isotope.

22. 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.
23. With respect to the lease for the ACP facilities entitled "Supplemental Agreement No. 1 to the Lease Agreement Between the United States Department of Energy and the United States Enrichment Corporation" dated December 7, 2006, the licensee shall:
a. Provide to the NRC a copy of the written notice that is required to be provided to the DOE regarding lease renewal at the same time that it is provided to the DOE;
b. Provide to the NRC a copy of the written notice that is required to be provided to the DOE regarding the licensee's decision to terminate the lease at the same time that it is provided to the DOE;
c. Inform the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> upon being informed by DOE that it is terminating the lease; and
d. Provide to the NRC a copy of any modifications to the lease within 30 days of the modification being signed.
24. A change to the facility or its processes is evaluated before the change is implemented using the criteria below. The evaluation of the change determines, before the change is

Page 11 of 12 U.S. NUCLEAR REGULATORY COMMISSION License Number SNM-2011, Amendment 17 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-7004 implemented, whether an application for an amendment to the License Application is required to be submitted in accordance with 10 Code of Federal Regulations 70.34.

a. The licensee may make changes to the License Application, without prior NRC approval, if the change:
i. Does not decrease the level of effectiveness of the design basis as described in the License Application; ii. Does not result in a departure from a method of evaluation described in the License Application used in establishing the design bases; iii. Does not result in a degradation in safety; iv. Does not affect compliance with applicable regulatory requirements; and
v. Does not conflict with an existing license condition.
b. If a change to the License Application is made, the affected onsite documentation will be updated promptly per written procedures. The licensee maintains records of changes to its facility. These records include a written evaluation that provides the bases for the determination that the changes to the License Application do not require prior NRC approval. These records are maintained until termination of the license.
c. Changes are communicated to the NRC as follows:
i. For changes that require NRC pre-approval, the licensee submits an amendment request to the NRC in accordance with 10 CFR 70.34 and 70.65.

ii. For changes to the License Application that do not require NRC pre-approval, the licensee submits to the NRC annually, within 30 days after the end of the calendar year during which the changes occurred, a brief summary of the changes.

25. The Licensee will request prior NRC approval before any liquid UF6 operations commence at the ACP.
26. ACO shall not enrich UF6 in excess of 20.0 wt.% 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 20.0 wt.% U-235. ACP shall not input parameters to extract product material for the assay above 20.0 wt.% U-235 at any time.
27. Within 30 days of making any non-administrative changes to the criticality computer code validation report EE-3101-0013, the Licensee shall provide the Commission with a summary of changes and shall provide the revised validation report upon request. The Licensee may not implement changes to reduce the margin of subcriticality for safety (i.e.

factors or methods that would adversely affect the Upper Subcritical Limit) without NRC approval of the change.

Page 12 of 12 U.S. NUCLEAR REGULATORY COMMISSION License Number SNM-2011, Amendment 17 MATERIALS LICENSE Docket or Reference Number SUPPLEMENTARY SHEET 70-7004

28. The Licensee will establish, maintain, and implement a maintenance, testing and calibration program to ensure that security systems and equipment are tested for operability and performance at predetermined intervals, maintained in operable condition, and are capable of performing their intended functions.

FOR THE U.S. NUCLEAR REGULATORY COMMISSION Digitally signed by Jacob I. Jacob I. Zimmerman Zimmerman Date: 2022.04.28 13:53:03 -04'00' Date: See digital signature By: ________________________________

Jacob I. Zimmerman, Chief Fuel Facility Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

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