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American Centrifuge Plant, Construction Inspection Report 707004/2021006
ML21130A343
Person / Time
Site: 07007004
Issue date: 05/10/2021
From: Robert Williams
NRC/RGN-II/DFFI
To: Snider M
American Centrifuge Operating
References
IR 2021006
Download: ML21130A343 (10)


Text

May 10, 2021 Mr. 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 45661

SUBJECT:

AMERICAN CENTRIFUGE PLANT - CONSTRUCTION REPORT 07007004/2021006

Dear Mr. Snider:

This report documents the results of the Construction Inspection that was conducted on March 2

- 3, 2021, at the American Centrifuge Operating, LLC (ACO) facility in Piketon, Ohio. The purpose of this inspection was to determine whether the licensee's design control activities associated with the installation of service modules were implemented in accordance with the license application, quality assurance program description, and regulatory requirements, and to determine whether activities authorized under the license were conducted safely, securely and in accordance with Nuclear Regulatory Commission (NRC) requirements.

The results of this inspection were discussed with members of your staff at an exit meeting held on March 26, 2021.

During this inspection, the NRC staff examined activities conducted under your license as they related to design control and installation of the main service modules and to confirm compliance with the Commissions rules and regulations and with the conditions of your license. Areas examined during the inspections are identified in the enclosed report. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.

No violations of more than minor significance were identified during this inspection.

M. Snider 2 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,

/RA/

Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07007004

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML21130A343 SUNSI Non-Sensitive Publicly Available Review Sensitive Non-Publicly Available OFFICE RII:DFFI/PB1 RII:DFFI/PB1 RII:DCO/B2 RII:DFFI/PB1 NAME Leonard Pitts Roland Womack Alain Artayet Robert Williams DATE 5/7/2021 5/7/2021 5/7/2021 5/10/2021 U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT REGION II Docket Number: 07007004 License Number: SNM-2011 Report Number: 07007004/2021006 Enterprise Identifier: I-2021-006-0060 Licensee: American Centrifuge Operating, LLC Facility: American Centrifuge Plant Location: Piketon, Ohio Inspection Dates: March 02, 2021 to March 03, 2021 Inspectors: A. Artayet, Sr. Construction Inspector L. Pitts, Sr. Fuel Facility Projects Inspector R. Womack, Fuel Facility Inspector Approved By: Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Construction at American Centrifuge Plant, 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.

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REPORT DETAILS PLANT STATUS The American Centrifuge Plant is currently under construction, preparing for centrifuge installation for the High-Assay Low-Enriched Uranium demonstration cascade.

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 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 88020 - Operational Safety The purpose of the operational safety inspection is to determine whether the material condition and as-found configuration of the site, structures, equipment, documentation, personnel, and items relied on for safety (IROFS), conform to regulations and license/certificate requirements, and are appropriate to protect worker and public safety during normal, off-normal, and accident conditions.

Operational Safety 02.01 Identification of Safety Controls and Related Programs.

The focus of the operational safety portion of the construction inspection was to validate that the appropriate activities were identified for review and that the licensee had adequately implemented their NRC-approved methodology for assignment of quality level to specific items.

  • The inspectors reviewed the integrated safety analysis and the design and documentation activities associated with the service modules at the American Centrifuge Plant (ACP) to verify that design activities, control measures, and documentation met applicable regulatory and licensing requirements. The inspectors verified that design assumptions and inputs were validated and that design outputs were adequately translated into design output documents in accordance with the Quality Assurance Program Description (QAPD) and regulatory requirements.
  • The inspectors reviewed Engineering Evaluation (EE) EE-3100-0003 ACP Seismic Design Values, EE-3101-0007 Existing Structure Commercial Grade Dedication Evaluation, EE-3901-0049 ACP Seismic Design Requirements, and ACP High Assay Low Enriched Uranium (HALEU) Items Relied on for Safety (IROFS) Boundary Definition Document, BDD-H-010, Rev. 0, to verify 3

that the appropriate quality and acceptance criteria were applied to the applicable IROFS in accordance with regulatory requirements.

  • The inspectors reviewed the commercial grade dedication (CGD) program to verify that the program met applicable regulatory and licensing requirements. Specifically, the inspectors reviewed the QAPD and implementing procedures to verify that the regulatory requirements, including appropriate definitions of commercial grade item, critical characteristics, dedicating entity and dedication from 10 CFR 21.3, were adequately adopted.
  • The inspectors reviewed CGD packages and the supporting documentation, including design specifications, to determine if the safety function(s) for each item for its intended use was identified. The inspectors reviewed the critical characteristics for each CGD package to determine if the characteristics identified provided reasonable assurance that the item(s) would perform the intended safety function.

OTHER AREAS 55100 - Structural Welding General Inspection Procedure The purpose of the welding inspection was to determine through direct observation whether the structural welding activities performed at the site were done in accordance with the Safety Analysis Report (SAR) and commitments to the American Welding Society (AWS)

Code. Additionally, these inspections determined whether the licensee's structural welding practices, specification, and procedures meet the requirements of the AWS Code and contract requirements.

Structural Welding General Inspection Procedure The inspectors observed welding activities and reviewed documents for the assembly of a quality level 1 (QL-1) cascade main service module (MSM) frame to verify welding and visual inspections were performed in accordance with the requirements of the American Welding Society (AWS) D1.1:2020 Structural Welding Code -

Steel.

  • Specifically, the inspectors reviewed work packages, welding procedures, AWS welding performance qualification test records of ironworker welders, AWS QC-1 welding inspector certifications, certified material test reports (CMTR) for electrodes and structural steel materials, and visual examination reports used for the east-side and south-end of MSM20 and 21 to determine whether materials, welding, and inspections were in accordance with the requirements of AWS D1.1.
  • The inspectors reviewed Geiger Brothers Inc. (GB) work packages WP-010A and WP-010B to verify that direct visual weld inspections were signed-off and dated by the AWS QC-1 certified welding inspector, and traceability of welders was maintained after fit-up alignment tack welds and completion of welds.
  • The inspectors reviewed prequalified welding procedure specification GB-D1.1-SMAW (including attached ironworkers A1 and A2 supplemental welding procedures with additional pertinent details) to verify that its contents were in 4

accordance with the requirements of the AWS D1.1, Section 3, titled Prequalification of WPSs.

  • The inspectors reviewed CMTRs for carbon steel square tubes and plates to verify that mechanical properties and chemical analysis results were in accordance with the requirements of the AWS D1.1, Table 3.1, Prequalified Base Metal-Weld Metal Combinations for Matching Strengths.
  • The inspectors reviewed CMTRs for welding electrodes to verify that mechanical properties and chemical analysis results in the as-welded condition were in accordance with the requirements of the SFA/A5.1 specification for E7018 carbon steel electrodes.
  • The inspectors reviewed welder performance qualification records for five individuals of the Ironworker/AWS Welder Certification Program of North America to verify that welder qualifications on a 1 thick carbon steel plate butt joint with backing bar (B-U2a) were performed within essential variables, bend tested, and certified for all position welding in accordance with the requirements of the AWS D1.1, Section 4, Part C, Performance Qualification.
  • The inspectors reviewed records of the AWS QC-1 welding inspector with certification number 02090021 to verify that certification and visual acuity were currently active in accordance with requirements of the AWS QC1:2007, Standard for AWS Certification of Welding Inspectors.
  • The inspectors reviewed the Professional NDE Services Group (PNDE) Visual Weld Examination procedure QP-VT-001 to verify that the contents were in accordance with the requirements of AWS D1.1, Section 6, Inspection.
  • The inspectors observed final weld surfaces and profiles and reviewed PNDE visual examination reports to determine whether acceptance of welds was performed in accordance with the requirements of the AWS D1.1, Table 6.1, Visual Inspection Acceptance Criteria.

INSPECTION RESULTS No issues were identified.

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

  • On March 26, 2021, the inspectors presented the Exit Meeting inspection results to Kelly Fitch and other members of the licensee staff.

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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 55100 Miscellaneous GB Weld Filler Material Record of Issue and Return, Lot-No. 12/21/2020 10, ESAB, E7018, 1/8 diameter GB Weld Filler Material Record of Issue and Return, Lot-No. 12/22/2020 10, ESAB, E7018, 1/8 diameter ESAB Certified Material Test Report (CMTR) 2-58803-00 08/17/2017 NUC for E7018H4R, 3/32 diameter, Lot-No. 2D711E02, Heat/Package-No. 76614P ESAB CMTR 2-58813-00-0-NUC for E7018H4R, 1/8 08/17/2017 diameter, Lot-No. 2D713B01, Heat/Package-No. 76045P Lincoln Structural Solutions (LSS) CMTR L12305AS-0, 04/27/2007 Lot/Heat-No. 2100266 for square tubes Lincoln Structural Solutions (LSS) CMTR L12327AS-0, 04/27/2007 Lot/Heat-No. 2100270 for square tubes Lincoln Structural Solutions (LSS) CMTR L12328AS-0, 04/27/2007 Lot/Heat-No. 2200770 for square tubes Lincoln Structural Solutions (LSS) CMTR L12329AS-0, 04/27/2007 Lot/Heat-No. 2200774 for square tubes TMK IPSCO Tubulars Inc., Certificate of Testing No. 367285- 09/09/2020 1, chemical analysis of square tubes Heat-Nos. 2100266, 2100270, 2200770, and 2200774 Consolidated Power Supply (CPS) CMTR 6504969, carbon 11/17/2020 steel plate Heat-No. JW17110994, Lot-No. JW17110994451 AWS QC-1 Welding Inspector JC certification number 02090021, expiration date 09/01/2023 GM-MRR-2987 Geiger Brothers Material Receiving Report (MRR) GM-MRR- 12/15/20 2987-Jackson-001 for carbon steel tubes and plate GM-MRR-2987 Geiger Brothers Material Receiving Report (MRR) GM-MRR- 12/16/2020 2987-Jackson-001 for carbon steel electrodes Procedures GB-D1.1-SMAW Geiger Brothers, Inc. Prequalified Welding Procedure 08/10/2018 Specification (WPS)

QP-VT-001 PNDE Visual Weld Examination procedure 10/28/20 Work Orders Geiger Brothers QL-1 Fabrication of Leg Assemblies for Main Service 12/08/2020 QL-1 Work Module Structure including Work Process Description with a 6

Inspection Type Designation Description or Title Revision or Procedure Date Package WP- welding diagram, and Weld Records with PNDE Visual 010A Examination Reports of Weld-No. 1 thru 15 for leg assemblies MSM20-Tag 20 and MSM21-Tag 21 for fit-up/tack and final visual.

Geiger Brothers QL-1 Build Supports for Main Service Module including 12/23/2020 QL-1 Work Work Process Description with a welding diagrams, and Package WP- Weld Records with PNDE Visual Examination Reports of 010B Weld-Nos. MSM2021-1 thru 8 for leg assembly MSM20 for fit-up/tack and final visual.

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