ML20262H155

Supplemental Proposed Changes for American Centrifuge Operating, Llc'S Technology and Manufacturing Center

ML20262H155
Person / Time
Site:	07007004
Issue date:	09/08/2020
From:	Wiehle K American Centrifuge Operating, Centrus Energy Corp
To:	Sabrina Atack Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Security and Incident Response
Shared Package
ML20262H154	List: ML20262H155
References
EPID: L-2020-SPR-0004
Download: ML20262H155 (4)

Text

Security - Related Information - Withhold U oder 10 CFR 2.390 Official Use Only 8 *

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• of Nucleor Power September 8, 2020 ACO 20-0031 ATTN: Document Control Desk Ms. Sabrina D. Atack, Director Division of Security Operations Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 American Centrifuge Plant; Docket Number 70-7004; License Number SNM-2011 Supplemental Proposed Changes for American Centrifuge Operating, LLC's Technology and Manufacturing Center in Oak Ridge, Tennessee - EPID #L-2020-SPR-0004 INFORMATION TRANSMITTED HEREWITH IS PROTECTED FROM PUBLIC DISCLOSURE AS CONFIDENTIAL COMMERCIAL OR FINANCIAL INFORMATION AND/OR TRADE SECRETS PURSUANT TO 10 CFR 2.390 AND 9.17(a)(4)

Dear Ms. Atack:

The purpose of this letter is to provide supplemental proposed changes to the U.S. Nuclear Regulatory Commission for review and approval for the American Centrifuge Operating, LLC (ACO) security plans. provides the description of change and justification for the supplemental proposed changes for the following security plans:

• NR-SP-ACO-OR-0001, Security Program/or American Centrifuge Operating, LLC at Oak Ridge, Tennessee (Enclosure 2)

• Revised PLD1-SP-024PD, Operations Security Plan (Enclosure 3)

Supplemental proposed changes from the previously submitted plans are noted with revision bars in the right-hand margin.

• Enclosures 2 and 3 contain Security-Related Information and, in accordance with the guidance provided by the U.S. Department of Energy, contain Official Use Only information. Therefore, ACO requests these enclosures be withheld from public disclosure pursuant to 10 CFR 2.390(d)(l ).

Document/matter transmitted contains Security- Related Information - Withhold Under 10 CFR 2.390 Official Use Only . ~ /!._ /)g When separated from enclosures, this cover letter is uncontrolled. ;J /

American Centrifuge Operating, LLC

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3930 U.S. Route 23 South - P.O. Box 628 Piketon, OH 45661 ;vr--tsS

Security - Related Information - Withhold Under 10 CFR 2.390 Official Use Only Ms. Sabrina D. Atack September 8, 2020 ACO 20-0031, Page 2 If you have any questions regarding this matter, please contact me at (740) 897-3859.

Sincerely,

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Kelly L. Wiehle Regulatory Manager cc (without enclosures, unless otherwise noted):

B. Brown, NE-ORI, NE-ORSO K. Everly, NRC HQ (Enclosures)

Y. Faraz, NRC HQ (Enclosures)

S. Greene, NE-32, NE (Enclosures)

S. Harlow, DOE HQ J. Hutson, DOE ORO (Enclosures)

M. McCune, NE-ORI, NE-ORSO N. Pitoniak, NRC Region II (Enclosures)

L. Pitts, NRC Region II (Enclosures)

S. Rice, DOE, NE-ORSO (Enclosures)

R. K. Shears, DOE OR E. St. Clair, DOE ORO R. Womack, NRC Region II (Enclosures)

T. Vukovinsky, NRC Region II (Enclosures)

Document/matter transmitted contains Security- Related Information - Withhold Under 10 CFR 2.390 Official Use Only When separated from enclosures, this cover letter is uncontrolled.

Enclosure 1 of ACO 20-0031 Description of Change and Justification for the Supplemental Proposed Changes Information Contained Within Does Not Contain Export Controlled Information Reviewing Official: #1014 Date: 09/08/2020

Enclosure 1 ACO 20-0031 Detailed Description and Justification On February 4, 2020 (ACO 20-0004), American Centrifuge Operating, LLC's (ACO) submitted a request for security facility approval for classified work at ACO' s Technology and Manufacturing Center (TMC) in Oak Ridge, Tennessee. This initial request will facilitate the transfer of ACO's TMC security regulatory oversight from the U.S. Department of Energy (DOE) to the U.S. Nuclear Regulatory Commission (NRC).

ACO 20-0004 provided a detailed description, justification, and ACO' s significance determination for the proposed new and changed documents as follows:

• NR-SP-ACO-OR-0001, Security Program for American Centrifuge Operating, LLC at Oak Ridge, Tennessee

• PLD1-SP-024PD, American Centrifuge Operations - Oak Ridge (ACO-OR) Operations Security P Ian

• SEC-18-0001, Classified Information System S~curity Assessment Report (SAR)

• SEC-18-0002, American Centrifuge Operating, LLC (ACO)-Cyber System Security Plan (SSP) .

• ACO-OR-2019-0026, Balance Stand Classified Cyber Network Proposed changes were determined not to decrease the effectiveness of the Security Programs/Plans in accordance with 10 Code ofFederalRegulations (CFR) 70.32; however, the security plans were determined to be a substantive change in accordance with 10 CFR 95.19 and requires NRC's prior review and approval.

On April 8, 2020, staff from the NRC, DOE, and ACO held a conference call to discuss questions related to ACO's submittal dated February 6, 2020 (ACO 20-0004). On June 11, 2020 (ACO 20-0015), ACO submitted responses to NRC staff comments specifically related to NR-SP-ACO-OR-0001.

During late August - early September 2020, ACO performed an internal readiness assessment in preparation for the NRC' s planned operational readiness review for Oak Ridge, Tennessee set for the week of September 21, 2020, During this assessment, findings and observations were made which compelled changes to the following plans: NR-SP-ACO-OR-0001 and PLD1-SP-024PD.

Supplemental proposed changes have been reviewed and determined not to decrease the effectiveness of the Security Programs/Plans in accordance with 10 CFR 70.32; however, the security plans are being re-submitted in support of the upcoming NRC operational readiness review.

The proposed changes to the enclosed NR-SP-ACO-OR-0001 are identified by the following method:

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