ML24109A126

American Centrifuge Plant - Integrated Inspection Report 07007004/2024001

ML24109A126
Person / Time
Site:	07007004
Issue date:	04/23/2024
From:	Robert Williams NRC/RGN-II/DFFI
To:	Snider M American Centrifuge Operating
References
IR 2024001
Download: ML24109A126 (14)

Text

Matthew Snider General Manager American Centrifuge Operating, LLC 3930 U.S. Route 23 South P.O. Box 628 Mail Stop 7560 Piketon, Ohio 45661

SUBJECT:

AMERICAN CENTRIFUGE PLANT - INTEGRATED INSPECTION REPORT 07007004/2024001

Dear Mathew Snider:

On March 29, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at the American Centrifuge Plant (ACP) and discussed the results of this inspection with Matthew Snider, General Manager, 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 LISTSERVApril 23, 2024 Signed by Williams, Robert on 04/23/24

ML24109A126 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available

OFFICE RII/DFFI RII/DFFI RII/DFFI NAME T.Sippel L.Pitts R. Willams DATE 4/17/2024 4/17/2024 4/23/2024

U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Number: 07007004

License Number: SNM-2011

Report Number: 07007004/2024001

Licensee: American Centrifuge Operating, LLC

Facility: American Centrifuge Plant (ACP)

Location: Piketon, Ohio

Inspection Dates: March 25, 2024, to March 29, 2024

Inspectors: T. Sippel, Senior Fuel Facility Projects Inspector M. Day, Fuel Facility Inspector (In-Training)

Approved By: Robert E. Williams, 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 core inspection at the 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.

2 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

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 Part 70 (10 CFR 70), including 70.24, 70.61, 70.62, and Appendix A 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 documents, to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.4.2 and 5.4.5.1. Specifically, the inspectors interviewed licensee staff and reviewed the following:

• EE-3101-0065, "Review of Criticality Events Identified in NCSE-MNT-004 for 10 CFR 70.61 Performance Requirements," Revision (Rev.) 1, which was reviewed because it contained the licensee's evaluation of how the items relied on for safety (IROFS) and accident sequences in NCSE-MNT-004, Rev.

1 comply with the performance requirements of 10 CFR 70.61

• NCSE-FWS-0009, "Nuclear Criticality Safety Evaluation for UF6 Feed," Rev.

1, including the review of the what-if analysis, normal conditions and credible abnormal (e.g., spacing upset) accident sequences, and calculation results for selected upsets

• NCSE-GEN-010, "Nuclear Criticality Safety Evaluation for Decontamination and Waste Operations," Rev. 2, including the review of accident sequences, models calculations, and controls involving the storage and handling of visibly contaminated items.

• NCSE-MNT-004, "Nuclear Criticality Safety Evaluation for Trap Media Removal," Rev. 1, including the review of the what-if analysis, normal conditions, credible and non-credible accident sequences.

• selected process descriptions and IROFS controls in LA-3605-0003A, "Addendum 1 of the Integrated Safety Analysis Summary for the American Centrifuge Plant - HALEU Demonstration," Rev. 32 (hereafter, referred to as the ISA Summary), which were reviewed to verify consistency with the above NCSEs

3 Criticality Implementation (IP Section 02.02)

The inspectors selected engineered and administrative controls from the licensees integrated safety analysis (ISA) summary to verify proper implementation through a review of process and system descriptions, implementing document reviews, plant walkdowns, and interviews to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.3.1, 5.3.2, and 11.3.1.4. Specifically, the inspectors interviewed licensee staff and reviewed IROFS, and their management measures, including:

• IROFS 7.3.6.6.1.4, a passive engineered geometry control, by walking down the control, interviewing licensee engineers, and reviewing training material (ACP04.02.74 - U01039),

• IROFS 7.3.6.6.1.5, a passive engineered spacing control, by walking down the control, interviewing operators, and reviewing training material (ACP04.02.74 -

U01039),

• IROFS 7.3.6.13.1.4, a passive engineered geometry control, by walking down the control, interviewing operators, and reviewing training material (ACP05.02.34 - U01045),

• IROFS 7.3.6.6.3.2, an administrative spacing control, by walking down the area, interviewing operators, observing postings, and reviewing training material (ACP04.02.74 - U01039),

• IROFS 7.3.6.6.3.6, an administrative moderation control, by walking down the area, interviewing operators and engineers, and reviewing training material (ACP04.02.74 - U01039),

• IROFS 7.3.6.6.3.8, an administrative moderation control, by interviewing operators and engineers,

• IROFS 7.3.6.7.3.12, an administrative moderation control applied to the use of firefighting water, by interviewing Department of Energy (DOE) staff provided fire services and licensee engineers, and reviewing training material and pre-fire plans,

• IROFS 7.3.6.8.3.1, an administrative geometry control, by interviewing operators and engineers, and reviewing training material

• IROFS 7.3.6.8.3.2, an administrative spacing control, by interviewing operators and engineers, and reviewing training material

• IROFS 7.3.6.15.3.15, an administrative mass control, by reviewing training material (ACP16.02.03 - U01046),

• IROFS 7.3.6.15.3.16, an administrative volume and geometry control, by reviewing training material (ACP16.02.03 - U01046),

• IROFS 7.3.6.15.3.27, an administrative spacing control, by reviewing training material (ACP16.02.03 - U01046),

• the inspectors also performed walkdowns to verify that a sample of required components (e.g., IROFS 7.3.6.6.1.7) were made out of fire-resistant materials of construction as required,

• additionally, the training materials reviewed covered many more IROFS

4 Criticality Operational Oversight (IP Section 02.03)

The inspectors assessed the Nuclear Criticality Safety (NCS) staffs oversight of plant operators, procedures, 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 NCS training material, including ACP08.02.02 - U00156, "Nuclear Criticality Safety for Managers," and IROFS/NCSE specific training material such as ACP16.02.03 - U01046, "NCSE Training Module for Decontamination and Waste Operations"

• interviewed NCS and operations staff concerning criticality hazards and control methods, including monitoring for long-term accumulations

• interviewed Uranium Hexafluoride (UF6) Feed area operators concerning criticality hazards and control methods, including the use of selected IROFS during operations

Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures and interviewed licensee NCS staff about audits to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.2.1 and 5.3.4. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:

• the most recent revision to licensee NCS program procedures, including ACP2-EG-010, "Nuclear Criticality Safety Program" and ACP3-EG-701, "Nuclear Criticality Safety Engineering"

• interviewed licensee NCS staff about audits, assessments, tracking of trends and IROFS failure information, changes to the NCS program and reporting requirements

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, including 5.4.4 and 8.1.1. Specifically, the inspectors:

• reviewed a number of recent NCS related CAP entries (e.g., CN-11464) and NCS Incident Reports, including NCS-INC-23-001, NCS-INC-23-002, NCS-INC-23-003, NCS-INC-23-004, NCS-INC-23-005 and NCS-INC-23-006; and interviewed licensee NCS staff and operators

• interviewed DOE staff who provide emergency response services and walked down emergency equipment that would be used during a criticality event

• reviewed recent NCS evacuation drill records (FY23-EM-DE-32) and interviewed licensee staff about drill performance

• walked down portions of the CAAS and interviewed licensee operations staff and engineers to verify that the CAAS had not been changed and had not been having reliability issues

5 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 Safety," 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 areas with or near licensed material, 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 selected the following fire protection features and licensee activities:

• DAC-3101-0024, "Analysis of Postulated Forklift Fire Exposure to a 30B Cylinder," Rev. 1 and interviewed licensee staff; to verify that the forklift observed in the field was bounded by the analysis and that the analysis supports the ISA's determination of accident sequences and IROFS

• 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 - Outside Buildings

• 7.3.2.1, Fire Suppression Systems

• 7.3.2.2, Fire Department Response

• 7.3.3.2, Vehicle Access Control

• As well as, fire detection systems, and fire doors and other fire barriers

Preventative Controls (IP Section 02.02)

The inspectors interviewed licensee staff, reviewed documentation, and conducted plant walk-downs to verify the licensees controls for combustibles, ignition sources, and inert atmospheres met the license requirements and applicable requirements in 10 CFR

70. Specifically, the inspectors:

• performed plant walk-downs and interviewed licensee staff to verify controls for combustible material were being implemented; observed combustible material control postings in Building X-3001

• reviewed ACP2-FS-001, "Combustible Material Control Program" and records of monthly Combustible Materials Controls Inspections to verify controls for combustible material were being implemented

• performed walk-downs to verify ventilation was as described in the applicable fire hazard analysis (FHA) (DAC-3001-FP-0100, "Fire Hazard Analysis for Building X-3001," Rev. 5)

• interviewed DOE staff providing fire and emergency services (per Reverse Work Authorization Form 902093) and licensee staff concerning training for licensee personnel performing Fire Watch duties

• reviewed Fire Watch Training, Fire Watch Refresher Training, and Fire Watch Qualification card

6 Fire and Gas Detection and Alarm Systems (IP Section 02.03)

The inspectors reviewed selected fire or gas detection devices to verify that detection and alarm systems were able to detect the minimal fire within the required time and initiate the safety function credited in the license application, the FHA, or the ISA Summary. Specifically, the inspectors:

• interviewed DOE staff providing fire and emergency services, and walked down the fire station to verify that fire alarm systems were being monitored 24/7

• reviewed Wet Pipe Sprinkler System Test records for the X-3001 building to verify that flow alarms were being tested

• reviewed Duct Smoke Detector Inspection and Test Reports for monthly inspections in 2023

• reviewed a manual pull station test record for the X-3001 building

Suppression Systems and Activities (IP Section 02.04)

The inspectors interviewed license staff, reviewed fire protection program documents, and conducted plant walk-downs to verify that suppression systems were capable of performing the safety function credited in the license application, the FHA, or the ISA Summary. Specifically, the inspectors:

• interviewed DOE staff providing fire and emergency services (e.g., fire watch),

licensee operations and fire protection staff; reviewed Impairment 24-020, fire patrol log for March 26, 2024; and performed walk-downs of portions of the sprinkler system to verify that sprinkler locations were as described in the FHA, including over selected hazards, that sprinklers were not blocked, that the sprinkler system appeared to be in good condition and that the licensee was maintaining the system, including imposing compensatory measures when needed

• reviewed Fire Extinguisher Field Inspection documents from Oct 2022 to Feb 2024, and walked down the High-Assay Low-Enriched Uranium (HALEU)

Demonstration Cascade and supporting areas to verify that the licensee maintains firefighting equipment (e.g., fire extinguishers)

Passive Fire Protection Features (IP Section 02.05)

The inspectors reviewed selected passive fire protection features to verify these were in a proper material condition to perform the safety function credited in the license application, the FHA, or the ISA Summary. Specifically, the inspectors performed the following activities:

• performed interviews and walk-downs to verify fire walls meet the requirements and were in good condition with no unsealed penetration noted; and reviewed First Floor Plan Wall and Ceiling Construction Drawings to verify construction of fire walls

• performed walk-downs to verify fire doors meet the license requirements

• performed walk-downs to verify flammable liquid storage meets the license requirements

7

• walked down fire hazards in or near areas with Special Nuclear Material (SNM) to verify that they were in as analyzed in the FHA

Fire Protection Program Elements (IP Section 02.06)

The inspectors reviewed selected fire protection program elements to verify compliance with the license requirements, including license application section 7.1.1.2, 7.1.3, and 7.1.4. Specifically, the inspectors completed the following activities:

• reviewed open Impairment 24-020, a fire patrol log, and interviewed staff and walked down the area to verify compensatory measures meet the license requirements

• interviewed DOE staff providing fire services to the licensee to verify that the fire brigade training is being performed

• reviewed the training provided to licensee staff about firefighting (e.g.,

ACP09.03.02 - U00124, "Fire Watch Qualification Card," Rev. 1) to verify the license requirements were being met

• performed walk-downs and reviewed X-3001-FEP-001, "Facility Emergency Packet X-3001," dated November 29, 2023, to verify that changes to the Pre-Fire Plan were consistent with the license requirements and reflected conditions in the field

Identification and Resolution of Problems (IP Section 02.07)

The inspectors reviewed the licensees identification and resolution of fire protection issues to verify compliance with the license requirements. Specifically, the inspectors reviewed the following corrective action program entries:

• FP related CAP Entries, including those opened as a result of licensee inspections and audits, and associated corrective action documentation: CN-11058, CN-11138, CN-11238

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 28, 2024, the inspectors presented the nuclear criticality safety and fire protection inspection results to Mattew Snider and other members of the licensee staff.

8 DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 88015 Corrective Action CN-11464, CN-NCS related CAP entries Various Documents 11467 NCS-INC-23-001 NCS Incident Report 07/31/2024 NCS-INC-23-002 NCS Incident Report 10/02/2023 NCS-INC-23-003 NCS Incident Report 10/21/2023 NCS-INC-23-004 NCS Incident Report 10/26/2023 NCS-INC-23-005 NCS Incident Report 10/26/2023 NCS-INC-23-006 NCS Incident Report 10/31/2023 Engineering NCSE-GEN-010 Nuclear Criticality Safety Evaluation for Decontamination and Rev. 2 Evaluations Waste Operations Miscellaneous Trending spreadsheet for NCS IROFS issues ACP04.02.71 - NCSE Training Module for Utilities Rev. 1 U01036 ACP04.02.74 - NCSE Training Module for the Feed System and Withdrawal Rev. 1 U01039 Operations ACP05.02.34 - NCSE Training Module for Trap Media Removal Rev. 0 U01045 ACP08.02.02 - Nuclear Criticality Safety for Managers Rev. 4 U00156 ACP16.02.03 - NCSE Training Module for Decontamination and Waste Rev. 1 U01046 Operations Procedures ACP2-EG-010 Nuclear Criticality Safety Program 02/13/2024 ACP3-EG-701 Nuclear Criticality Safety Engineering` 02/13/2024 ACP4-EG-704 Nuclear Criticality Safety Incident Response 06/19/2023 Self-Assessments FY23-EM-DE-32 CAAS Evacuation Drill After Action Report 03/23/2023 88055 Calculations DAC-3101-0024 Analysis of Postulated Forklift Fire Exposure to a 30B Rev. 1 Cylinder Corrective Action CN-11058, CN-Fire Protection Related CAP entries Various Documents 11138, CN-11238 Corrective Action CN-11747 Fire Protection CN for fire extinguisher form indicating six 03/25/2024 Documents year maintenance date out of periodicity.

Resulting from CN-11748 Fire Protection CN for a fire protection impairment permit 03/26/2024

9 Inspection Type Designation Description or Title Revision or Procedure Date Inspection completed incorrectly CN-11750 Fire door gap exceeds NFPA 80 standards 03/28/2024 CN-11756 Documents potential increased risk of large lithium ion 03/28/2024 rechargeable batteries were introduced to the site CN-11761 Non-sealed penetration of fire barriers in each of the two 03/28/2024 diesel generator rooms. Work order submitted for repair.

CN-11762 Roll up fire door open half way, the door electric operation 03/28/2024 was not functional, door was manually closed Drawings Emergency Generator Room Floor Plans, Elev, and Section 11/16/1979 First Floor Plan Wall and Ceiling Construction 02/14/1983 Engineering BDD-H-002 Boundary Definition Document for IROFS 7.3.1.2 Rev. 0 Evaluations "Combustible Material Control Program - Inside Buildings" BDD-H-003 Boundary Definition Document for IROFS 7.3.1.3 "Limitations Rev. 0 on Fossil Fueled Vehicles Used in ACP Buildings (IC)"

BDD-H-004 Boundary Definition Document for IROFS 7.3.1.4 Rev. 1 "Combustible Material Control Program - Outside Buildings (IC)"

BDD-H-006 Boundary Definition Document for IROFS 7.3.2.1 "Fire Rev. 4 Suppression Systems" BDD-H-007 Boundary Definition Document for IROFS 7.3.2.2 "Fire Rev. 1 Department Response" BDD-H-017 Boundary Definition Document for IROFS 7.3.8.1 Rev. 1 "Emergency Response Actions" BDD-H-018 Boundary Definition Document for IROFS 7.3.8.2 "Alarm, Rev. 0 Notification, and Protective Actions" DAC-3001-FP-Fire Hazard Analysis for Building X-3001 Rev. 5 0100 Fire Plans X-3001-FEP-001 Facility Emergency Packet X-3001 Rev. 9 Miscellaneous Fire Extinguisher Field Inspection various Monthly inspections provided Oct 2022 to Feb 2024 dates Inspection and Operational Test of Fire Doors 03/27/2023, 04/25/2023, 05/20/23, 09/29/2023

10 Inspection Type Designation Description or Title Revision or Procedure Date Dry Pipe Sprinkler Systems Monthly Inspection, Various Records of September 2023 to January 2024 inspections Dates Combustible Materials Controls Inspections Various Records of monthly inspections Dates, Feb 2023 through Jan 2024 IROFS Surveillance Area 2 Wet Pipe Sprinkler Systems and various Monthly Inspection and Test records from March 2023 to July dates 2023 IROFS Surveillance and wet pipe sprinkler monthly various inspections and test from Aug 2023 to Feb 2024 dates List of Combustible Material Storage Areas Manual Fire Alarm Pull Station Alarm Test Report 11/14/2023 for Building X-3001 License Application for the American Centrifuge Plant Revision 54 Chapter 7 Fire Safety Permit 24-020 Fire Protection Impairment Permit for X7725 11/22/2023 ACP09.02.02 - Fire Watch Training for Welding/Burning / Hot Work Rev. 2 U00094 Practices ACP09.03.02 - Fire Watch Qualification Card Rev. 1 U00124 ACP09.04.11 - Fire Watch for Welding/Burning/Hot-Work Refresher Rev. 0 U00095 FPB-FS-PRO-Duct Smoke Detector Inspection and Test Report 00060-F01 Jan 2023 through Feb 2024 Inspection #24-Facility Fire Protection Inspection Results various 157 Monthly inspection results from Feb 2023 through Jan 2024 dates Tech Spec Master Specifications - Unit Masonry section section 04200 part 2.03 Tech Spec Master Specifications - Fire Resistant Coatings section 09840 section 2.03 Work Reverse Work Authorization Form: Fire Services/ Emergency 03/04/2024

11 Inspection Type Designation Description or Title Revision or Procedure Date Authorization Management/ PSS Support for HALEU 902093 Procedures ACP2-FS-001 Combustible Material Control Program 06/02/2023 ACP2-FS-002 Flammable and Combustible Liquids 06/02/2023

12