ML24205A163

American Centrifuge Plant - Integrated Inspection Report 07007004/2024002

ML24205A163
Person / Time
Site:	07007004
Issue date:	07/25/2024
From:	Robert Williams NRC/RGN-II/DFFI
To:	Snider M American Centrifuge Operating
References
IR 2024002
Download: ML24205A163 (11)

Text

Matt Snider General Manager American Centrifuge Operations, LLC (ACO)

P. O. Box 628 Mail Stop 7560 Piketon, OH 45661

SUBJECT:

AMERICAN CENTRIFUGE PLANT (ACP) - CORE INSPECTION REPORT 07007004/2024002

Dear Matt Snider:

On June 28, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at American Centrifuge Plant (ACP). On May 9, 2024, the NRC inspector discussed the results of this inspection with you 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, Robert E. Williams, Jr., 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 July 25, 2024 Signed by Williams, Robert on 07/25/24

ML24205A163 x

SUNSI Review x

Non-Sensitive

Sensitive x

Publicly Available

Non-Publicly Available OFFICE RII/DFFI RII/DFFI NAME J. Grice R. Williams DATE 7/23/2024 7/25/2024

Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:

07007004 License Number:

SNM-2011 Report Number:

07007004/2024002 Enterprise Identifier:

I-2024-002-0053 Licensee:

American Centrifuge Operations, LLC (ACO)

Facility:

American Centrifuge Plant (ACP)

Location:

Piketon, Ohio Inspection Dates:

May 06, 2024 to May 10, 2024 Inspectors:

J. Grice, Fuel Facility Inspector Approved By:

Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection

2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a core inspection at American Centrifuge Plant (ACP), in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities. 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. Inspections were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program. The inspector 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 88020 - Operational Safety The inspector evaluated selected aspects of the licensees Operational Safety program to verify compliance with selected portions of Title 10 of the Code of Federal Regulations. Part 70 (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 inspector selected specific process areas for inspection based on the safety basis information of the facility, the risk/safety significance of the process areas, the description of plant changes submitted to the NRC, and past plant performance documentation. For the process areas of interest, the inspector selected a sample of accident sequences in nuclear criticality safety, fire safety, and chemical safety based on the information provided in the integrated safety analysis (ISA) summary and safety basis documentation. The inspector conducted a general plant tour of each major plant operating area. The process areas and accident sequences selected for review are listed below:

Withdrawal Area o

NCSE-FWS-002, Criticality Accidents Process Building o

HD1-2, Large fire in the Process Building results in a release of Uranium Hexafluoride (UF6) from damaged process equipment, centrifuges, cylinders, cold traps, chemical traps or headers o

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 o

HD7-7, Heavy rains result in shallow flooding of Process Building/Interplant Transfer Corridor/Recycle/Assembly Building/CTTF with subsequent damage, as appropriate for a given facility, to the process equipment, centrifuges, cylinders, cold traps, chemical traps or headers and release of UF6.

4 Review of Safety Controls and Related Programs (IP Section 02.02)

The inspector reviewed information related to administrative, engineered, and passive safety controls or items relied on for safety (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 7.3.1.2, Combustible Material Control Program - Inside Buildings Administrative Control, (AC)

IROFS 7.3.1.3, Limitations on Fossil Fueled Vehicles Used in ACP Buildings, AC IROFS 7.3.1.5, Non-flammable Refrigerant, Passive Engineered Control (PEC)

IROFS 7.3.3.2, Vehicle Access Control, AC IROFS 7.3.6.4.1.4, Cold Box Design Features, PEC IROFS 7.3.6.4.1.5, Cold Box Configuration, PEC IROFS 7.3.6.4.1.6, Chemical Trap Design Features, PEC IROFS 7.3.6.10.1.9.2 Cascade Dump Chemical Traps, PEC IROFS 7.3.6.1.1.26, Cascade Dump Traps (NaF) and Withdrawal Outlet Traps (AL2O3), PEC IROFS 7.3.6.4.2.1, Tails Withdrawal Cold Trap Temperature, Active Engineered Control (AEC)

IROFS 7.3.6.4.2.2, Tails Withdrawal Cold Trap Pressure, AEC IROFS 7.3.6.4.2.3, Cold Box Fan Disconnect, Active Engineered Control, AEC IROFS 7.3.6.4.2.4, Cold Box Temperature, AEC IROFS 7.3.6.11.2.4, Cold Box Fan Control, AEC IROFS 7.3.6.4.3.1, Cylinder Acceptance Criteria, Administrative Control, AC IROFS 7.3.6.4.3.2, Cylinder Inspection, AC IROFS 7.3.6.4.3.3, Cylinder Handling, AC IROFS 7.3.6.4.3.4, Pigtail Handling and Storage, AC IROFS 7.3.6.4.3.5, Pig Tail Leak Test, AC IROFS 7.3.6.4.3.6, Manual Isolation Valves for Tails Cold Trap Pressure Transmitters, AC IROFS 7.3.6.4.3.7, Bypass Prohibited in Tails Withdrawal Refrigeration Cycles, AC IROFS 7.3.7.5, Building Finished Floor Elevation Above Storm Drainage Swales, PEC Implementation of Safety Controls (IP Section 02.03)

For the selected safety controls listed above, the inspector 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 inspector conducted the following activities to verify the implementation of selected safety controls:

5 performed walkdown of the processing building to verify the implementation the related IROFS o

7.3.7.5 o

7.3.1.3 o

7.3.1.5 o

7.3.3.2 performed walkdown of the withdrawal area to verify the implementation the related IROFS o

7.3.6.4.2.1 o

7.3.6.4.2.2 o

7.3.6.4.2.3 o

7.3.6.4.2.4 o

7.3.6.11.2.4 o

7.3.6.4.3.6 o

7.3.6.4.1.4 o

7.3.6.4.1.5 o

7.3.6.4.1.6 o

7.3.6.10.1.9.2 o

7.3.6.1.1.26 reviewed procedures that implement the IROFS in the X-3001 Process Building and the Withdrawal Area.

reviewed the Boundary Definition Documents for the IROFS inside the Process Building and the Withdrawal Area.

interviewed one (1) Cascade Operator on applicable IROFS and IROFS training in the Process Building and the Withdrawal Area interviewed two (2) maintenance support techs on applicable IROFs and IROFS training in the Withdrawal Area interviewed one (1) Nuclear Safety (NS) Manager, one (1) NS Consultant, and one (1) NS Trainer on applicable IROFS in the Withdrawal Area and training interviewed Quality Control (QC) supervisor on applicable IROFS implementation Safety Control Support Programs (IP Section 02.04)

The inspector assessed additional management measures that support the availability and reliability of the selected safety controls to verify these were implemented in accordance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspector conducted the following:

reviewed preventative maintenance work orders for active engineered IROFS in the Withdrawal Area o

PM-2200001129, PM for Cold Trap Tails o

PM-2300000166, PM for Cold Trap Tails o

PM-2300001600, PM for Cold Trap Product, Product Cold Box #2 o

PM2200001146, Preventative Maintenance for Cold Trap Tails reviewed ACP-2023-A05, Independent Audit of Chemical Process Safety Program reviewed ACP-MA-2023-16, management Assessment of the Change Evaluation Program

6 reviewed Condition Notifications (CNs) associated with degraded IROFS and IROFS related equipment in the inspection focus areas:

o CN# 11817 o

CN# 11819 o

CN# 11818 o

CN# 11369 reviewed training records to verify IROFS training for the following positions:

o One Plant Shift Superintendent o

One QC Supervisor o

One Cascade Operator o

One Maintenance Support Tech observed Corrective Action Review Team Meeting interviewed Engineering Manager on Corrective action process.

INSPECTION RESULTS No issues were identified.

EXIT MEETINGS AND DEBRIEFS The inspector verified no proprietary information was retained or documented in this report.

On May 9, 2024, the inspector presented the core inspection results to Matt Snider and other members of the licensee staff.

7 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date AC Condition Notification

1. 11817 MTE-LC-160 MKS Vacuum Calibrator found to be outside of tolerance 05/06/2024 AC Condition Notification

1. 11819 Procedure improvements identified for ACD4-OP-035, "

Operating of the Adventurer Balance Sample Scale AX2022."

05/06/2024 AC Condition Notification (CN)

1. 11369 Identification of a freezer, potentially containing flammable refrigerant, that was introduced into the X-3001 Process Building 8/17/2023 AC Condition Notification Action

1. 17888 Corrective Actions assigned for CN #11817 05/07/2024 AC Condition Notification SubTask #36629 Subtask to perform the corrective actions described in CN Action #17888 5/7/2024 AC Condition Notification SubTask #36640 Subtask to remove administrative controls based on the results of the extent of condition report from Subtask #36629 05/08/2024 AC Condition Report #11818 Discovery of gulper flexible intake in degraded condition 05/06/2024 Corrective Action Documents AC Required Reading #17623 Required Reading for Plant Shift Superintendent (PSS) Desk Guide 02/13/2024 07-555-0204 Chemical Trap Assembly Rev. 1 07-555-0205 Chemical Trap Assembly Rev. 1 07-555-0206 Chemical Trap Assembly Rev. 1 Drawings 07-555-0207 Chemical Trap Assembly Rev. 1 BDD-104-1d Active Design Features for Product Tails Withdrawal Rev. 4 BDD-H-001 Building and Equipment Constructed of Noncombustible Materials Rev. 1 BDD-H-002 Control of Combustibles Inside Building Rev. 0 BDD-H-003 Limitations on Fossil Fueled Vehicles Rev. 0 88020 Engineering Evaluations BDD-H-005 Non-Flammable Refrigerant Rev. 0

8 Inspection Procedure Type Designation Description or Title Revision or Date BDD-H-006 Fire Suppression Rev. 4 BDD-H-008 Vehicle Access Control Rev. 1 BDD-H-010 Building Structural Components Rev. 0 BDD-H-012 Structure Design Rev. 1 BDD-H-013 Structure Located Above Flood Rev. 0 BDD-H-014 Building Elevation Rev. 0 BDD-H-104-1a Passive Design Features for Withdrawal Operations Rev. 3 BDD-H-104-1b Active Design Features for Tails Withdrawal Rev. 2 BDD-H-104-1c Active Design Features for Tails Withdrawal Rev. 3 BDD-H-104-2 Administrative IROFS Rev. 1 ESDS-AC-0255 ESDS Cover Sheet for Chemical Traps for HALEU Cascade Rev. 1 LA-3605-0003 Integrated Safety Analysis Summary for the American Centrifuge Plant in Piketon, Ohio Rev. 45 LA-3605-0003A Addendum 1 of the Integrated Safety Analysis Summary for the American Centrifuge Plant - HALEU Demonstration in Piketon, Ohio Rev. 33 NCSE-FWS-002 Nuclear Criticality Safety Evaluation for Withdrawal Operations Rev. 5 CART Review Agenda 05/09/2024 AC-488 M&TE Use Log Cover Sheet for MTE-LC-160 Portable Vacuum Calibrator System 3/14/2024 AC-617 ACD2-RG-007 Operating Experience Lessons Learned, Flammable Refrigerant Screening 01/22/2024 AC-708 Request for Fossil Fueled Vehicle Within ACP Facilities 04/08/2024 ACP04.02.74-U01039 NCSE Training Module for the Feed System and Withdrawal Operations (NCSE-FWS-009, NCSE-FWS-002)

Rev. 1 ACP12.01.08 -

U01092 Screening Manager Training Rev. 0B ACP12.01.09 -

U01095 Plant Shift Superintendent (PSS) Training Module Rev. 0B LA-3605-0001 License Application for the American Centrifuge Plant in Piketon, Ohio Docket No. 70-7004 Rev.71 Miscellaneous PM-2200001129 Preventative Maintenance (PM) for the Cold Trap Product, 12/05/2022

9 Inspection Procedure Type Designation Description or Title Revision or Date Product Cold Box #3 PM-2300000166 PM for Cold Trap Tails 07/26/2023 PM-2300000172 PM for Cold Trap Tails 6/7/2023 PM-2300001600 PM for Cold Trap Product, Product Cold Box #2 12/23/2023 PM2200001146 Preventative Maintenance for Cold Trap Tails 01/31/2023 PM2300000167 PM for Cold Trap Tails 01/03/2024 Training Record Training Record for Maintenance Support Tech 05/09/2024 Training Record Plant Shift Superintendent (PSS) Training Records 05/08/2024 Training Record Training Record for Quality Control Supervisor 05/08/2024 Training Record Training Record for Cascade Operator 05/08/2024 ACD2-FO-003 Vehicle Control Within ACP Facilities Rev. 6 ACD2-MA-002 Work Control Process Rev. 35 ACD2-PM-001 Preventative Maintenance Program Rev. 13 ACD2-QM-101 Inspection Program Rev. 23 ACD2-RG-004 Corrective Action Process Rev.26 ACD2-RG-044 Regulatory and Security Event Notification and Reporting Rev. 26 ACD3-EO-064 Valve Positioning Controls Rev. 7 ACD3-FO-002 Operability Determinations and IROFS Systems, Structure, and Component Tracking Rev. 3 ACP2-EG-017 IROFS Surveillance Program Rev. 6 ACP3-FO-004 Initial Operability Of IROFS For HALEU Operation Rev. 0 ACP3-ST-002 HALEU Tails Cold Box IROFS Surveillance Testing and Calibration Rev. 14 Procedures ACP3-ST-004 HALEU Product Cold Box IROFS Surveillance Testing and Calibration Rev. 8 ACP-2023-A05 Independent Audit of Chemical Process Safety Program 03/06/2024 Self-Assessments ACP-MA-2023-16 Management Assessment of the Change Evaluation (CE)

Program 12/14/2023