ML23128A350
| ML23128A350 | |
| Person / Time | |
|---|---|
| Site: | 07007004 |
| Issue date: | 05/09/2023 |
| From: | Timothy Sippel NRC/RGN-II/DFFI |
| To: | Snider M American Centrifuge Operating |
| References | |
| IR 2023007 | |
| Download: ML23128A350 (1) | |
Text
Mathew Snider General Manager/Operations Manager American Centrifuge Operating, LLC 3930 U.S. Route 23 South P.O. Box 628 Mail Stop 7560 Piketon, OH 45661water
SUBJECT:
AMERICAN CENTRIFUGE PLANT - INTEGRATED INSPECTION REPORT 07007004/2023007
Dear Mathew Snider:
From April 3, 2023, through April 12, 2023, the U.S. Nuclear Regulatory Commission (NRC) performed the implementation phase of readiness review inspections for Operational Safety, Radiation Protection, Nuclear Criticality Safety, Permanent Plant Modification, and Fire Protection at the American Centrifuge Operating (ACO) American Centrifuge Plant (ACP) and discussed the results of these inspections with L. Cutlip, Senior Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
No violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Tim Sippel, Acting Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07007004 License No. SNM-2011
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV May 9, 2023 Signed by Sippel, Timothy on 05/09/23
SUNSI Review X
Non-Sensitive
Sensitive X
Publicly Available
Non-Publicly Available OFFICE RII/DFFI RII/DFFI NAME L. Pitts T. Sippel DATE 05/09/2023 05/09/2023
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07007004 License Number:
SNM-2011 Report Number:
07007004/2023007 Enterprise Identifier:
I-2023-007-0002 Licensee:
American Centrifuge Operating, LLC Facility:
American Centrifuge Plant (ACP)
Location:
Piketon, Ohio Inspection Dates:
April 03, 2023, to April 12, 2023 Inspectors:
J. Grice, Fuel Facilities Inspector L. Pitts, Sr. Fuel Facility Projects Inspector J. Raudabaugh, Fuel Facility Inspector T. Shewmaker, Fuel Facility Inspector T. Sippel, Sr. Fuel Facility Project Inspector T. Vukovinsky, Sr. Fuel Facility Project Inspector R. Womack, Physical Security Inspector Approved By:
Tim Sippel, Acting Chief Projects Branch 1 Division of Fuel Facility Inspection
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) conducted readiness review inspections in the areas of nuclear criticality safety, operational safety, fire protection, radiation protection, and permanent plant modifications at ACP. The readiness review inspections documented in this report represent an on-site review of items relied on for safety and management measures for selected licensee programs at the ACP. The readiness reviews documented in this report do not represent authorization nor approval of any of the licensees programs reviewed. Additional readiness review activities are planned to be performed by the NRC prior to authorization of licensed activities within the programs reviewed in this report. Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.
List of Violations No violations of more than minor significance were identified.
Additional Tracking Items None.
3 INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
SAFETY OPERATIONS 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety program to verify compliance with selected portions of Title 10 of the U.S. Code of Federal Regulations Section 70 (10 CFR 70), including 70.24, 70.61, 70.62, Chapter 5, Nuclear Criticality Safety, of the facilitys license application, and applicable licensee procedures.
Criticality Analysis (IP Section 02.01)
The inspectors interviewed licensee staff and reviewed nuclear criticality safety evaluations (NCSEs), and associated supporting calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors interviewed licensee staff and reviewed the following NCSEs and criticality related calculations:
NCSE-FWS-002, "Withdrawal Operations," Revision (Rev.) 4, including the review of credible accident sequences involving too many Uranium Hexafluoride (UF6) cylinder at the product withdrawal station, and the review of incredible sequences involving the wrong type (e.g., too large) of UF6 cylinder
NCSE-CAS-003, "Evacuation Vacuum and Purge Vacuum Systems," Rev. 4, including the review of the what-if analysis, normal conditions, and credible accident sequences
NCSE-GEN-006, "Utilities," Rev. 6, including the review of the what-if analysis, normal conditions, and credible accident sequences
DAC-3101-0008, "NCS Study of 30 Inch UF6 Cylinder Storage," Rev. 0; which contains a variety of criticality calculations for the storage of 30B cylinders; including enrichment and moderation upsets
EE-3101-0013, "NCS Code Validation of SCALE 6.2.3 and Cross Section Set v7-252 for keff Calculations," Rev. 1, which was reviewed because it contained benchmark descriptions, calculations, and the evaluation that established the upper subcritical limit (USL) used when performing NCS calculations using SCALE 6.2.3, and includes updates to the area of applicability of the USL Criticality Implementation (IP Section 02.02)
The inspectors selected controls from the licensees integrated safety analysis (ISA) summary to verify proper implementation through a review of process and system descriptions, plant walkdowns, and licensee interviews to verify compliance with 10 CFR 70
4 and applicable sections of the license application. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following related to NCS controls, and their management measures:
Items relied on for safety (IROFS) Surveillance IS-H-040 Rev. 2; which documents the verification of IROFS related to piping and inline component spacing, geometry and volume; including IROFS G.7.3.6.1.1.17, G.7.3.6.1.1.18, 7.3.6.2.1.5.1, 7.3.6.2.1.6, 7.3.6.11.1.1 and 7.3.6.11.1.2
IROFS Surveillance IS-H-057 Rev. 1; which documents the verification of IROFS related to vacuum pumps and centrifuge oils; including IROFS G.7.3.61.1.15, G.7.3.61.1.16, 7.3.6.2.1.8, 7.3.6.11.1.5, 7.3.6.11.1.8, 7.3.6.11.1.16, and 7.3.6.12.1.4.4
ACP 04.02.72 / U01037, "NCSE Training Module for the EV/PV Systems,"
Rev. 0; which provides training to operators on the IROFS established in NCSE-CAS-003
ESDS-AC-0313, "EV/PV Pump Replacement Oil and Oil Exchange Kit,"
Rev. 0; which contains oil procurement specifications that implement IROFS established in NCSE-CAS-003
IC-NCSE-CAS-003R4, "NCSE Implementation Checklist for NCSE-CAS-003 Rev. 4;" which documents the implementation of NCS IROFS from NCSE-CAS-003, including IROFS 7.3.6.2.1.1, 7.3.6.2.1.2, 7.3.6.2.1.3, 7.3.6.2.1.4.1, 7.3.6.2.1.5.2, 7.3.6.2.1.5.3, 7.3.6.2.1.5.4 and 7.3.6.2.18
discussed controls on heating UF6 with NCS engineers; these include 7.3.6.11.1.13 and 7.3.6.11.2.4
and walked down a number of passive and active engineered controls associated with the cascade, withdrawal stations, and utilities; including the passive controls on the product withdrawal station and active engineered control valves on the Nitrogen supply Criticality Operational Oversight (IP Section 02.03)
The inspectors assessed the NCS staffs oversight of plant operators and operations of systems involving special nuclear material to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors performed the following activities:
reviewed ACP08.04.01 / U00155, "Basic Nuclear Criticality Safety Refresher, Rev. 2
reviewed AC-736, "Fissile Material Operations Assessment Checklist," dated July 1, 2021
interviewed licensee NCS staff concerning how long-term accumulations were addressed through monitoring or prevention
interviewed a licensee NCS engineer concerning the conduct of NCS Walk-Throughs and reviewed the most recent NCS Walk-Through Report (NCS-WTR-22-001)
5 Criticality Programmatic Oversight (IP Section 02.04)
The inspectors reviewed NCS program procedures, audits, and assessments to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:
ACP 03.02.03 / U01091, "NCS Response to CAAS Alarm and Criticality Accident," Rev. 0; which is training for licensee NCS engineers in their role in supporting emergency response activities following a CAAS activation
recent annual management assessments of the licensee's NCS program which are documented in ACP-MA-2022-23, "Management Assessment Nuclear Safety Program," and 761-GM-21-066, "Management Assessment Report - Nuclear Criticality Safety Program Background"
the most recent revision to NCS program procedures, including:
o ACP2-EG-010, "Nuclear Criticality Safety Program," Rev. 9 o
ACP3-EG-701, "Nuclear Criticality Safety Engineering," Rev. 9 o
ACP4-EG-704, "Nuclear Criticality Safety Incident Response," Rev. 0 Criticality Incident Response and Corrective Action (IP Section 02.05)
The inspectors reviewed the licensees criticality accident alarm system (CAAS) and corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors observed equipment, reviewed documents, and interviewed licensee staff concerning the following:
Reverse Work Authorization No. 902093, "Fire Services/Emergency Management/PSS Support for High-Assay Low-Enriched Uranium (HALEU);"
which describes the emergency services that the Department of Energy will provide
DAC-3100-0002, "Dose at Site Boundary due to Airborne Releases from a Criticality Event," which evaluates the dose from the postulated largest credible criticality for use in emergency response
X-3001-FEP-001, "Facility Emergency Packet X-3001," Rev. 8; which provides guidance on emergency response and reentry pertinent to a criticality event
Drill Planning Outline Packet FY23-EM-DE-32, "X-3001 CAAS Evacuation Drill," dated March 23, 2023
Drill & Exercise Program After Action Report (AAR) FY23-EM-DE-32, "X-3001 CAAS Evacuation Drill," dated March 23, 2023
the monitoring station and equipment that use to monitor for radiation at the rally point after a criticality event
the emergency response vehicle to observe the equipment (e.g., dosimetry) that would be used during a criticality event
procedures that would be used during a criticality event, including:
o ACD2-HP-006, "Dosimetry Program Standards," dated March 22, 2023 o
ACP2-SH-002, "ACO Site Response Actions," Rev. 2 o
FBP-EM-PRO-00023, "Monitoring Station," Rev. 10 o
FBP-EM-PRO-00041, "Criticality and Radiation Emergencies," Rev. 6
"Nuclear Criticality Safety Duty List," dated March 30, 2023; which lists the licensee NCS engineers who are on-call to support emergency response
6
CAP items: Issue 10722, 10987, 10662, 10652, 10644 11023, 10490, 10651 10660, 10483, 10655, and 10658; which included issues identified by licensee NCS during walkdowns and self-assessments, as well as issues raised by licensee staff 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees Operational Safety program to verify compliance with selected portions of 10 CFR 70, including 70.24, 70.61, 70.62, and Chapter 11, Management Measures, of the facilitys license application, and applicable licensee procedures.
Identification of Safety Controls and Related Programs (IP Section 02.01)
The inspectors selected from IROFS from all process areas for the inspection based on the safety basis information of the facility, the risk/safety significance of the process areas, and the description of plant changes submitted to the NRC. The inspectors selected a sample of accident sequences in nuclear criticality safety, radiation safety, fire safety, and chemical safety based on the information provided in the ISA summary. The inspectors conducted a general plant tour of each major plant operating area. The process areas and accident sequences selected for review are listed below:
HD1-1a Small fire in Process Building
HD1-2 Large fire in the Process Building results in a release of UF6 from damaged process equipment, centrifuges, cylinders, cold traps, chemical traps or headers
HD1-2a Large fire in the Interplant Transfer Corridor / Recycle / Assembly Building / CTTF results in a release of trace amounts of UF6 and contamination by-products from damaged centrifuges, chemical traps, and/or other contaminated items
HD1-3 Fire in the Area Control Room (ACR) results in evacuation of the ACR
HD1-4 Fire near the chemical traps results in damaged equipment and releases of UO2F2 from chemical traps
HD1-5 Fire on the centrifuge transporter cart while transporting or loading centrifuge(s) removed from service to be taken from (or back to) the Process Building results in sufficient damage to the centrifuge(s) or other contaminated items to release contamination or trace amounts of UF6
HD1-6 Large fire in the Process Building due to ongoing construction activities results in a release of UF6 from damaged process equipment, centrifuges, cylinders, cold traps, chemical traps or headers
HD1-7 Samples, standards, vent traps, contaminated equipment or waste, or other miscellaneous contaminated items are involved in a fire due to an on-site transportation accident or any mechanism such as natural phenomena
HD1-8 Fire on a forklift while transporting a feed cylinder results in a release of UF6
HD2-1 Explosion in battery charging room damages centrifuges or process headers resulting in a release of UF6
HD2-1a Explosion in battery charging room damages cylinders, cold traps, chemical traps or headers resulting in a release of UF6
7
HD2-2 Explosion from wrecked centrifuge following backfill with air results in a release of contamination
HD2-3 Battery explosion on the centrifuge transporter cart
HD2-3a Battery explosion on the centrifuge transporter cart impacts cylinders
HD3-1 Leak in centrifuge(s) process piping or coupling to centrifuge(s) or process piping results in a release of UF6
HD3-2 Leak in cylinder process piping or pigtail to feed, product or tails cylinder, cold trap, or chemical trap flange connection results in a release of UF6
HD3-3 Leak in feed, product or tails cylinder, cold trap or chemical trap results in a release of UF6
HD3-5 A centrifuge is dropped while being handled, creating a hole or crack in the casing, and resulting in a release of trace quantities of contamination from wreck by-products (wrecked machine)
HD3-5a A centrifuge is dropped while being handled, impacting a cylinder with a resultant release of UF6
HD3-5b A centrifuge falls onto an array of feed, tails, and/or product cylinders during handling or transport, or due to impact resulting in a release of UF6
HD3-6 A loaded feed, product or tails cylinder is dropped or impacts another object shearing off the valve or breaching the cylinder and resulting in a release of UF6
HD3-6a A loaded feed, product or tails cylinder is dropped or impacts another cylinder shearing off the valve or breaching the cylinder and resulting in a release of UF6
HD3-7 Samples, standards, vent traps, contaminated equipment or waste, or other miscellaneous contaminated items are breached due to an on-site transportation accident or any mechanism such as natural phenomena or explosion
HD3-8 A centrifuge being positioned by the overhead bridge crane impacts multiple operating centrifuges. The mid-height casings of the centrifuges have a hole or crack created by the impact and releases UF6. Alternatively, the centrifuge could impact and breach associated process system piping releasing UF6
HD3-9 Centrifuges or associated process piping is impacted by a forklift, creating a hole or crack in the casing and/or breaching the process piping resulting in a release of UF6
HD6-1 Forest or brushfire impacts Process Building / Interplant Transfer Corridor / Recycle / Assembly Building / CTTF leading to a fire within and a release of UF6 from damaged process equipment, centrifuges, cylinders, cold traps, chemical traps or headers
HD6-2 Fire from an adjacent building spreads to the Process Building/
Interplant Transfer Corridor / Recycle / Assembly Building / CTTF leading to a fire within and a release of UF6 from damaged process equipment, centrifuges, cylinders, cold traps, chemical traps or headers
HD6-3 Fire from vehicle parked or traveling adjacent to the Process Building/
Interplant Transfer Corridor / Recycle / Assembly Building / CTTF spreads to become a fire within and a release of UF6 from damaged process equipment, centrifuges, cylinders, cold traps, chemical traps or headers
8
HD6-5 Fire from diesel fuel storage tank outside Process Building impacts Process Building, damages process equipment, centrifuges, cylinders, cold traps, chemical traps or headers resulting in a release of UF6
HD6-11 Airplane impact into Process Building / Interplant Transfer Corridor /
Recycle / Assembly Building / CTTF results in damage to damaged process equipment, centrifuges, cylinders, cold traps, chemical traps or headers resulting in a release of UF6
HD6-12 Helicopter impact into Process Building / Interplant Transfer Corridor /
Recycle / Assembly Building / CTTF results in damage to damaged process equipment, centrifuges, cylinders, cold traps, chemical traps or headers resulting in release of UF6
HD7-2 Earthquake strikes site and Process Building / Interplant Transfer Corridor / Recycle / Assembly Building / CTTF causing a large follow-on fire, which results in a release of UF6
HD7-4b High winds (e.g., microbursts, large storms), beyond design basis, strike site and Process Building damaging the facility and the process equipment, centrifuges, cylinders, cold traps, chemical traps or headers with a large follow-on fire resulting in a release of UF6 Review of Safety Controls and Related Programs (IP Section 02.02)
The inspectors reviewed information related to administrative, engineered, and passive safety controls or IROFS for the accident sequences selected above, including the identification of the licensees assumptions and bounding cases as they apply to each of the selected accident sequences, safety controls, or IROFS. This review was performed to verify that the controls or IROFS were available and reliable to perform their intended safety functions and that the design basis assumptions were reflected in the actual conditions in the field. The specific safety controls selected for review are listed below:
IROFS 7.3.1.1, Buildings and Equipment Constructed of Noncombustible Material
IROFS 7.3.1.2, Combustible Material Control Program - Inside Buildings
IROFS 7.3.1.3, Limitations on Fossil Fueled Vehicles Used in American Centrifuge Plant Buildings
IROFS 7.3.1.4, Combustible Material Control Program
IROFS 7.3.2.1, Fire Suppression Systems
IROFS 7.3.6.3.1.4, Wasson-ECE Passive Design Features
IROFS 7.3.6.4.2.3, Cold Box Fan Disconnect
IROFS 7.3.6.4.2.4, Cold Box Temperature
IROFS 7.3.6.11.2.1, Nitrogen Line Fail-Safe Isolation Valve
IROFS 7.3.6.11.2.2, Nitrogen Line 2nd Independent Fail-Safe Isolation Valve
IROFS 7.3.6.11.2.3, Plant Air Fail-Safe Isolation Valve
IROFS 7.3.6.11.2.5, Low pressure Nitrogen Boundary Isolation Valve
IROFS 7.3.7.1, Structures Designed for 1000-Year Return Period Seismic Event
IROFS 7.3.7.2, Centrifuge Mountings Designed for 1,000-Year Return Period Seismic Event
IROFS 7.3.7.3, Structures Designed for a 100 mph or 20,000-Year Return High Straight-Line Wind Event
9
IROFS 7.3.7.4, Structures Located Well Above 10,000-Year Return Period Flood Level
IROFS 7.3.7.5, Building Finished Floor Elevation Above Storm Drainage Swales
IROFS 7.3.7.7, Structures Designed for a 90 mph or 3,000-Year Return High Straight-Line Wind Event
IROFS 7.3.8.1, Emergency Response Actions
IROFS 7.3.8.2, Alarm, Notification, and Protective Actions
IROFS 7.3.8.3, Trained Operator Actions
IROFS 7.3.9.1, Inventory Control Program
IROFS 7.3.9.2, On-Site Transportation Inventory Control Program Implementation of Safety Controls (IP Section 02.03)
For the selected safety controls listed above, the inspectors reviewed management measures to verify proper implementation in accordance with 10 CFR 70 and applicable sections of the license application. This review was performed to verify that selected safety controls or IROFS were present, available, and reliable to perform their safety function and that the design basis assumptions were reflected in the actual conditions in the field. The inspectors conducted the following activities to verify the implementation of selected safety controls:
observed IROFS surveillance Testing and Calibration for the following IROFS:
o 7.3.2.1, Fire Suppression System o
7.3.6.4.2.3, Cold Box Fan Disconnect o
7.3.6.4.2.4, Cold Box Temperature o
7.3.6.11.2.1, 7.3.6.11.2.2, 7.3.6.11.2.5 HALEU Nitrogen System o
7.3.6.11.2.4, Cold Box Fan Control
walk-downs performed to verity implementation of the IROFS:
o 7.3.1.1, Buildings and Equipment Constructed of Noncombustible Material o
7.3.1.2, Combustible Material Control Program - Inside Buildings o
7.3.1.3, Limitations on Fossil Fueled Vehicles Used in American Centrifuge Plant Buildings o
7.3.1.4, Combustible Material Control Program o
7.3.6.3.1.4, Wasson-ECE Passive Design Features o
7.3.6.4.2.3, Cold Box Fan Disconnect o
7.3.6.4.2.4, Cold Box Temperature o
7.3.6.11.2.4, Cold Box Fan Control o
7.3.6.11.2.1, Nitrogen Line Fail-Safe Isolation Valve o
7.3.6.11.2.2, Nitrogen Line 2nd Independent Fail-Safe Isolation Valve o
7.3.6.11.2.5, Low pressure Nitrogen Boundary Isolation Valve o
7.3.7.1, Structures Designed for 1000-Year Return Period Seismic Event o
7.3.7.2, Centrifuge Mountings Designed for 1,000-Year Return Period Seismic Event o
7.3.7.3, Structures Designed for a 100 mph or 20,000-Year Return High Straight-Line Wind Event o
7.3.7.4, Structures Located Well Above 10,000-Year Return Period Flood Level
10 o
7.3.7.5, Building Finished Floor Elevation Above Storm Drainage Swales o
7.3.7.7, Structures Designed for a 90 mph or 3,000-Year Return High Straight-Line Wind Event o
7.3.8.1, Emergency Response Actions o
7.3.8.2, Alarm, Notification, and Protective Actions o
7.3.8.3, Trained Operator Actions Safety Control Support Programs (IP Section 02.04)
The inspectors assessed additional licensees measures that support the availability and reliability of the selected safety controls to verify these were implemented in accordance with 10 CFR 70. Specifically, the inspectors conducted the following:
Reviewed CAP entry 11000 associated with ACP3-OP-002, Pump Down Cart Operation
Reviewed ACP-IRR-2023-01, "Final Report of the Independent Readiness Review of the Startup of the High Assay Low Enrichment Uranium Plant" 88055 - Fire Protection The inspectors evaluated selected aspects of the licensees fire protection program to determine whether the operational status, material condition and design of fire protection systems met the applicable requirements of 10 CFR 70, Chapter 7, Fire Protection, of the facilitys license application, and applicable licensee procedures.
Selection of Inspection Samples (IP Section 02.01)
The inspectors reviewed licensing documents to select a sample of fire protection features in risk-significant areas/processes, including IROFS and their respective management measures (where applicable). The inspectors also selected licensee activities that support the implementation of the fire protection program based on the program description included in the license application. Specifically, the inspectors reviewed the completed surveillances and performed walkdowns for the following IROFS:
7.3.1.1, Buildings and Equipment Constructed of Noncombustible Material
7.3.1.2, Combustible Material Control Program - Inside Buildings
7.3.1.3, Limitations on Fossil Fueled Vehicles Used in American Centrifuge Plant Buildings
7.3.1.4, Combustible Material Control Program
7.3.2.1, Fire Suppression Systems Suppression Systems and Activities (IP Section 02.04)
The inspectors interviewed license staff, reviewed fire protection program documents, and conducted plant walk-downs of the service module and UF6 storage areas to verify the associated suppression systems were capable of performing the safety function credited in the license application, fire hazard analysis (FHA), and the ISA Summary.
11 Fire Protection Program Elements (IP Section 02.06)
The inspectors reviewed selected fire protection program elements to verify compliance with the license requirements. Specifically, the inspectors completed the following activities:
interviewed members of the site's emergency response organization to verify the fire protection organization met the license requirements
interviewed licensee staff, reviewed program documents, and walked down the process buildings to verify emergency lighting systems were being maintained as required to meet the license requirements and National Fire Protection Association (NFPA) 101, Life Safety Code RADIOLOGICAL CONTROLS 88030 - Radiation Protection The inspectors evaluated selected aspects of the licensees radiation protection (RP) program to verify compliance with selected portions of 10 CFR 19, 20, 40, 61 and 70, Chapter 4, Radiation Protection, of the facilitys license application, and applicable licensee procedures.
Radiation Protection and Radioactive Waste Procedures (IP Section 02.03)
The inspectors assessed the licensees review of RP related changes to procedures to verify compliance with 10 CFR 70.72. Specifically, the inspectors completed the following activity:
Reviewed changes to the radiation protection program and procedures made following the licensee's Internal Readiness Review Instruments and Equipment (IP Section 02.08)
The inspectors interviewed licensee staff and reviewed the licensees use of radiation detecting instruments and equipment to verify compliance with 10 CFR 20.1501(a).
Specifically, the inspectors completed the following activity:
Reviewed radiation detection equipment capabilities and readiness following the licensee's Internal Readiness Review Posting of Notices (IP Section 02.11)
The inspectors observed the Posting of Notices to verify compliance with 10 CFR 19.11.
Specifically, the inspectors observed the following notices:
NRC Form 3 INSPECTION RESULTS No violations of more than minor significance were identified during this inspection.
12 EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On April 12, 2023, the inspectors presented the integrated inspection results to Larry Cutlip and other members of the licensee staff.
13 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date Drawings X-3001-9500-ME-Z HALEU 16-Machine Cascade Process Gas System Piping and Instrumentation Diagram Rev. 7 BDD-H-101-1a IROFS for NCSE-CAS-001 Passive Design Features for the Centrifuge Cascade - Casing 06/11/2021 BDD-H-101-1b IROFS for NCSE-CAS-001 Passive Design Features for the Centrifuge Cascade - Layout 06/11/2021 BDD-H-101-1c IROFS for NCSE-CAS-001 Passive Design Features for the Centrifuge Cascade - USA 06/11/2021 BDD-H-101-1d IROFS for NCSE-CAS-001 Passive Design Features for the Centrifuge Cascade - Column 06/11/2021 BDD-H-101-1e IROFS for NCSE-CAS-001 Passive Design Features for the Centrifuge Cascade - LSA 03/08/2022 BDD-H-101-1f IROFS for NCSE-CAS-001 Passive Design Features for the Centrifuge Cascade - Total Oil 6/03/2021 BDD-H-101-1g IROFS for Vacuum Pumps and Centrifuge Oils 10/24/2022 BDD-H-101-1h IROFS for the NCSE-CAS-001 Passive Design Features for the Centrifuge Cascade - Header Rev. 2 DAC-3100-0002 Dose at Site Boundary due to Airborne Releases from a Criticality Event Rev. 0 Engineering Evaluations EE-3101-0013 NCS Code Validation of SCALE 6.2.3 and Cross Section Set v7-252 for keff Calculations Rev. 1 Fire Plans X-3001-FEP-001 Facility Emergency Packet X-3001 Rev. 8 ACP03.02.03 /
U01091 NCS Response to CAAS Alarm and Criticality Accident Rev. 0 ACP04.02.68 /
U01019 Criticality Accident Alarm System (CAAS)
Rev. 0A ACP08.04.01 /
U00155 BASIC NUCLEAR CRITICALITY SAFETY REFRESHER Rev. 2 EC7274 Bomb Threat, Criticality and Radiation Emergencies, &
Natural Phenomena Rev. 1 88015 Miscellaneous Reverse Work Authorization No.
Fire Services/Emergency Management/PSS Support for HALEU 12/22/2022
14 Inspection Procedure Type Designation Description or Title Revision or Date 902093 ACP2-EG-010 Nuclear Criticality Safety Program Rev. 9 ACP2-SH-002 ACO Site Response Actions Rev. 2 ACP3-EG-701 Nuclear Criticality Safety Engineering Rev. 9 ACP4-EG-704 Nuclear Criticality Safety Incident Response Rev. 0 Procedures FBP-EM-PRO-00023 Monitoring Station Rev. 10 AC-721 IROFS Surveillance No. IS-H-040 10/24/2022 ACP-MA-2022-23 Management Assessment Nuclear Safety Program 08/30/2022 Self-Assessments NCS-WTR-22-001 NCS Walk-Through Report.
06/01/2022 Corrective Action Documents Condition Notifications (CNs) 11000, 10828 Various Various Corrective Action Documents Resulting from Inspection Condition Notification (CN) 11098 NRC inspector observations 04/06/2023 AC-721 IS-H-001 for ESO-3100-0007 (Nitrogen)
Rev. 2 BDD-H-011 Boundary Definition Document for IROFS 7.3.7.2, Centrifuge Mountings Designed for 1,000-Year Return Period Seismic Event (IC) 10/20/2020 BDD-H-021 IROFS Boundary Definition Document for IROFS 7.3.9.2 On Site Transportation Inventory Control Program Rev. 0 BDD-H-104-1d Boundary Definition Document for IROFS NCSE-FWS-002 Active Design Features for Product and Tails Withdrawal Rev. 3 BDD-H-111-1b Boundary Definition Document for IROFS for NCSE-GEN-006, Active Design Features for Utilities Rev. 1 EE-3901-0022 IROFS Boundary Determination for ISA section 7.3.7.2, Centrifuge Mountings Designed for 1,000-Year Return Period Seismic Event (IC)
Rev. 1 EE-3901-0032 IROFS Boundary Definition for ISA section 7.3.9.2, On-Site Transportation Inventory Control Program Rev. 0 88020 Engineering Evaluations EE-3901-0083 Initial Verification of IROFS Surveillances IS-H-10, IS-H-012, IS-H-013, IS-H-014, and IS-H-016 Rev. 0
15 Inspection Procedure Type Designation Description or Title Revision or Date ACD2-MP-007 Conduct of Operations Rev. 9 ACD3-FO-002 Operability Determinations and IROFS System, Structure, and Component Tracking (Formerly AC3-FO-002)
Rev. 3 ACD4-ON-073 Loss of Nitrogen Rev. 1 ACP2-EG-017 IROFS Surveillance Program Rev. 3 ACP3-FO-004 Initial Operability of IROFS for HALEU Operation Rev. 0 ACP3-ST-001 HALEU Nitrogen System IROFS Surveillance Testing and Calibration Rev. 3 Procedures ACP3-ST-004 HALEU Product Cold Box IROFS Surveillance Testing and Calibration Rev. 6 AC-271 IROFS Surveillance Evaluation NO. IS-H-013 04/03/2023 AC-721 IROFS Surveillance Evaluation No. IS-H-012 04/03/2023 AC-721 IROFS Surveillance Evaluation No. IS-H-010 04/03/2023 AC-721 IFROFS Surveillance Evaluation No. IS-H-019 03/18/2022 AC-721 IROFS Surveillance Evaluation No. IS-H-018 08/02/2022 AC-721 IROFS Surveillance Evaluation No. IS-H-017 03/22/2023 AC-721 IROFS Surveillance Evaluation No. IS-H-011 12/15/2022 AC-721 IROFS Surveillance Evaluation No. IS-H-001 03/13/2023 AC-721 IROFS Surveillance Evaluation NO. IS-H-016 04/03/2023 AC-721 IROFS Surveillance Evaluation No. IS-H-014 04/03/2023 AC-721 IROFS Surveillance Evaluation No. IS-H-021, Rev. 1 03/23/2023 Self-Assessments ACP-IRR-2023-01 Final Report of the Independent Readiness Review of the Startup of the High Assay Low Enriched Uranium Plant 04/04/2023 Corrective Action Documents Condition Notifications (CNs) 10990, 10995, 10949, 11028, 16453, 16534, 16559, 16560, 16561 Various Various 88030 Corrective Action Documents Resulting from Inspection Condition Notifications (CNs) 11120, 11121 Various 04/12/2023
16 Inspection Procedure Type Designation Description or Title Revision or Date BDD-H-001 Boundary Definition Document for ISA section 7.3.1.1 Building and Equipment Constructed of Noncombustible Materials (IC)
Rev. 1 BDD-H-002 Boundary Definition Document for IROFS 7.3.1.2, Combustible Material Control Program - Inside Buildings Rev. 0 BDD-H-003 Boundary Definition Document for IROFS 7.3.1.3, Limitations on Fossil Fueled Vehicles Used in ACP Buildings (IC)
Rev. 0 BDD-H-003 Boundary Definition Document for IROFS 7.3.1.3, "Limitations on Fossil Field Vehicles Used in ACP Buildings (IC)
Rev. 0 BDD-H-004 Boundary Definition Document for IROFS 7.3.1.4, Combustible Material Control Program - Outside Buildings (IC)
Rev. 1 DAC-3001-FP-0100 Fire Hazard Analysis for Building X-3001 Rev. 4 DAC-3101-0024 Analysis of Postulated Forklift Fire Exposure to a 30B Cylinder Rev. 1 DAC-3101-0025 Fire Scenario Document for X-3001 Building Rev. 0 DAC-3101-0025 Fire Scenario Document for X-3001 Building Rev. 0 DAC-3101-0300 HALEU Cascade Service Module Sprinkler System Analysis Rev. 0 Engineering Evaluations EE-3901-0012 IROFS Boundary Definition Document for ACP ISA section 7.3.1.1 Buildings and Equipment Constructed of Non-combustible Materials (IC)
Rev. 1 ACD2-FO-003 Vehicle Control Within ACP Facilities Rev. 4 ACP2-FS-001 Combustible Material Control Program Rev. 2 Procedures ACP2-FS-002 Flammable and Combustible Liquids Rev. 1 AC-721 Management Assessment Surveillance Evaluation for Combustible Material Control Program, Inside Buildings IROFS, 7.3.1.2 09/15/2021 AC-721 Management Assessment Surveillance Evaluation for Combustible Material Control Program, Outside Buildings IROFS, 7.3.1.4 09/15/2021 88055 Self-Assessments AC-721 Management Assessment Surveillance Evaluation for Limitations of Fossil Fuel Vehicles used in ACP Buildings 09/15/2021
17 Inspection Procedure Type Designation Description or Title Revision or Date IROFS, 7.3.1.3 AC-721 IROFS Surveillance Evaluation No. IS-H-006 Rev. 0 04/21/2022 AC-721 IROFS Surveillance No. IS-H-006 Rev. 0 04/14/2022