ML24205A163

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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 LISTSERVJuly 25, 2024 Signed by Williams, Robert on 07/25/24

ML24205A163 x Non-Sensitive x Publicly Available x SUNSI Review Sensitive Non-Publicly Available

OFFICE RII/DFFI RII/DFFI

NAME J. Grice R. Williams DATE 7/23/2024 7/25/2024

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

Enclosure

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.

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 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.

3 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:

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  • 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

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  • 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.

6 DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 88020 Corrective Action AC Condition MTE-LC-160 MKS Vacuum Calibrator found to be outside of 05/06/2024 Documents Notification tolerance

  1. 11817 AC Condition Procedure improvements identified for ACD4-OP-035, " 05/06/2024 Notification Operating of the Adventurer Balance Sample Scale
  1. 11819 AX2022."

AC Condition Identification of a freezer, potentially containing flammable 8/17/2023 Notification (CN) refrigerant, that was introduced into the X-3001 Process

  1. 11369 Building AC Condition Corrective Actions assigned for CN #11817 05/07/2024 Notification Action
  1. 17888 AC Condition Subtask to perform the corrective actions described in CN 5/7/2024 Notification Action #17888 SubTask #36629 AC Condition Subtask to remove administrative controls based on the 05/08/2024 Notification results of the extent of condition report from Subtask #36629 SubTask #36640 AC Condition Discovery of gulper flexible intake in degraded condition 05/06/2024 Report #11818 AC Required Required Reading for Plant Shift Superintendent (PSS) Desk 02/13/2024 Reading #17623 Guide Drawings 07-555-0204 Chemical Trap Assembly Rev. 1 07-555-0205 Chemical Trap Assembly Rev. 1 07-555-0206 Chemical Trap Assembly Rev. 1 07-555-0207 Chemical Trap Assembly Rev. 1 Engineering BDD-104-1d Active Design Features for Product Tails Withdrawal Rev. 4 Evaluations BDD-H-001 Building and Equipment Constructed of Noncombustible Rev. 1 Materials BDD-H-002 Control of Combustibles Inside Building Rev. 0 BDD-H-003 Limitations on Fossil Fueled Vehicles Rev. 0 BDD-H-005 Non-Flammable Refrigerant Rev. 0

7 Inspection Type Designation Description or Title Revision or Procedure 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 Rev. 45 Centrifuge Plant in Piketon, Ohio LA-3605-0003A Addendum 1 of the Integrated Safety Analysis Summary for Rev. 33 the American Centrifuge Plant - HALEU Demonstration in Piketon, Ohio NCSE-FWS-002 Nuclear Criticality Safety Evaluation for Withdrawal Rev. 5 Operations Miscellaneous CART Review Agenda 05/09/2024 AC-488 M&TE Use Log Cover Sheet for MTE-LC-160 Portable 3/14/2024 Vacuum Calibrator System AC-617 ACD2-Operating Experience Lessons Learned, Flammable 01/22/2024 RG-007 Refrigerant Screening AC-708 Request for Fossil Fueled Vehicle Within ACP Facilities 04/08/2024 ACP04.02.74-NCSE Training Module for the Feed System and Withdrawal Rev. 1 U01039 Operations (NCSE-FWS-009, NCSE-FWS-002)

ACP12.01.08 - Screening Manager Training Rev. 0B U01092 ACP12.01.09 - Plant Shift Superintendent (PSS) Training Module Rev. 0B U01095 LA-3605-0001 License Application for the American Centrifuge Plant in Rev.71 Piketon, Ohio Docket No. 70-7004 PM-2200001129 Preventative Maintenance (PM) for the Cold Trap Product, 12/05/2022

8 Inspection Type Designation Description or Title Revision or Procedure 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 Procedures 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, Rev. 3 and Component Tracking 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 Rev. 14 Calibration ACP3-ST-004 HALEU Product Cold Box IROFS Surveillance Testing and Rev. 8 Calibration Self-Assessments ACP-2023-A05 Independent Audit of Chemical Process Safety Program 03/06/2024 ACP-MA-2023-16 Management Assessment of the Change Evaluation (CE) 12/14/2023 Program

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