IR 07100940/2020201
| ML20162A158 | |
| Person / Time | |
|---|---|
| Site: | 07100940 |
| Issue date: | 05/04/2020 |
| From: | Jon Woodfield Office of Nuclear Material Safety and Safeguards |
| To: | Rickman J Louisiana Energy Services, URENCO USA |
| JWoodfield NMSS/DFM/IOB 415.8727 | |
| References | |
| IR 2020201 | |
| Download: ML20162A158 (7) | |
Text
Leira Y. Cuadrado-Caraballo Digitally signed by Leira Y. Cuadrado-Caraballo Date: 2020.06.05 17:55:45 -04'00'
Leira Y. Cuadrado-Caraballo Digitally signed by Leira Y. Cuadrado-Caraballo Date: 2020.06.05 17:57:59 -04'00'
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Inspection History
The last on-site inspection of the Eunice, New Mexico URENCO USA (UUSA) facility was performed in April 201 This inspection was the first routine periodic assessment of UUSAs user only Quality Assurance Program (QAP) implementatio The team assessed UUSAs management and maintenance controls for compliance to 10 CFR Part 71, 10 CFR Part 21, and UUSAs NRC approved QA Overall, the team assessed that UUSA was adequately implementing their QA program regarding Quality Assurance, Management Controls, and Maintenance Control One Non-cited Severity Level IV Violation was identified by the inspection tea Contrary to the requirements of 10 CFR 71.115, Control of purchased material, equipment, and services, UUSA failed to perform an audit of a contractor that provided the majority contract services to perform the required annual maintenance on UX-30 transportation packages used for shipping 30-inch uranium hexafluoride cylinder UUSA acknowledged the issue and captured it in their corrective action progra The inspection report is at ADAMS ML19225D17 On January 12, 2009, UUSA was granted an NRC 10 CFR Part 71 QAP Approva The Eunice, New Mexico UUSA facility was opened on June 11, 2010 and had never been inspected by NRC headquarters 10 CFR Part 71 inspectors until the April 2019 inspectio Inspection Purpose
The general purpose of the inspection was to assess UUSAs transportation activities for compliance with 10 CFR Parts 21 and 71, and to verify that the transportation packagings for which UUSA is strictly a user, can be verified to comply with Part 71 and the Certificate of Compliance (CoC) in procurement of spare parts, repair, maintenance, and use requirements, as applicabl The focus of the inspection was to determine whether UUSAs 10 CFR Part 71 user only activities are in accordance with their NRC-approved user only QA program requirements and that the packagings they use for the transportation of radioactive materials are being properly used and maintaine The specific purpose of this inspection was to follow-up on the UUSA event reports written from the April 2019 inspectio The focus was on the event report written to address the external audit of the company RSB, which performed UX-30 maintenance for UUSA and the controlling of UX-30 quality documents and storage at the Eunice, New Mexico facilit Also, the inspection team was to review any new Part 21 and 71.95 reports written since the 2019 inspection and associated event report Primary Inspection Procedures/Guidance Documents
IP-86001, Design, Fabrication, Testing, and Maintenance of Transportation Packagings NUREG/CR-6407, Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety NUREG/CR-6314, Quality Assurance Inspections for Shipping and Storage Containers
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Regulatory Guide 7.10, Establishing Quality Assurance Programs for Packaging Used in the Transport of Radioactive Material
INSPECTOR NOTES: ITEMS REVIEWED BY THE INSPECTION TEAM DURING THE LIMITED SCOPE INSPECTION
Review of UUSA 10 CFR 71.95 Reports Written Since the April 2020 Inspection
The team reviewed the one UUSA 71.95 Report sent to the NRC since April 2019, LES-19-178 NR The report was for a missing 30-inch uranium hexafluoride cylinder valve cap gasket and not UX-30 issue The team also verified that the actual transportation issue reported to the NRC through the 71.95 report was put into UUSAs corrective action program to prevent the issue from reoccurrin The team reviewed associated event report EV134994 and assessed that the resolution was adequat The team again reviewed UUSA procedure LS-3-1000-05, Notifications and Event Reporting, Revision 17 since it addressed 71.95 reporting to determine if any changes had been made since April 201 The team determined that while the procedure was generic, it still covered 71.95 reporting adequatel No Part 21 reports had been made to the NRC since April 201 Review of Event Report EV 132498, Which Was Written to Retrieve Quality Records for UX-30s Owned by UUSAs Parent Company
This event report was written during the April 2019 inspection to retrieve copies of the quality records for the UX-30s owned by UUSAs parent company located in the United Kingdom (UK).
UUSA uses six UX-30 transportation packages which were purchased by its parent company in the UK from United States manufacturer Copies of these quality records are not readily available at the Eunice, New Mexico facilit The team determined that this event report had not been completed and close The team was disappointed to see that this had not been closed within a yea UUSA stated that it was still working on developing a process to have the UX-30 records in the UK readily available for UUS The team determined there was no safety issue since the quality records were available in the UK, just not readily available for revie Review of EV 131819, Which was Written for UUSA Not Providing QAP Biannual Updates to the NRC in Accordance with Regulation 10 CFR 71.106
The team reviewed the closure of EV131819 which had been written in April 2019 to address why the NRC had not received any QAP biannual updates in accordance with regulation 10 CFR 71.10 The resolution was UUSA revised attachment 1 to procedure LS-3-1000-03, Routine and Periodic Reports to Regulatory Agencies, to add this reporting requiremen The team asked UUSA why the reporting date of every second year was August 31 instead of August 28, which was the approval date on the latest NRC Form 311 issued to UUS UUSA stated it did not know why the date was August 31 and wrote event report EV138073 to change the date on attachment 1 in the procedure to August 2 The team assessed that after
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correcting the reporting date, UUSA will have procedures in place to provide QAP biannual updates to the NRC in accordance with the regulation Sample Review of the Latest UX-30 Prior to Shipping Inspection Records and Annual Maintenance Inspection Records for Procedure Compliance
The team reviewed the following procedures addressing prior to shipping and annual maintenance inspections:
- LO-3-2000-01, Receipt and Shipment of Cylinders, Revision 21
LO-3-4000-01, Annual Overpack Inspection, Revision 9
QA-3-3000-02, QC Inspector Training and Qualification, Revision 8
QA-3-3000-03, Visual Examinations, Revision 3
QA-3-3-3000-17, Welding Inspection, Revision 10
The team reviewed the latest prior to shipping and annual maintenance records for seven of the thirty-six UX-30s UUSA uses; two owned by UUSAs parent company in the UK and five UUSA leases from a company called RS The team did find a few documentation issues with these quality inspection record However, none of the documentation issues were significant enough to invalidate the inspections or deem the UX-30 unsafe for transpor UUSA documented the issues on three separate event reports (EV 138086, EV 138089, EV 138091).
Review of UUSA Records Management and Document Control Procedures Since due to Time Constraints During the 2019 Inspection this Area was not Reviewed In-depth
The team reviewed the following procedures addressing records management and document controls:
- RM-2-2000-01, Records Retention, Revision 11
RM-3-2000-01, Records Management Program, Revision 22
RM-3-3000-01, Control of Documents, Revision 19
RM-4-2000-01, Instructions for Processing Incoming Records, Revision 6
The team found all the procedures reviewed to be detailed and provide adequate direction for controlling quality records and controlling revisions of documents such as procedures with no concern The team noted that RM-2-2000-01 provided the guidance needed to classify quality records into categories and provided tables stating the associated retention time period of those records based on their category and applicable regulation Review of Event Report EV 123188, Which was Written to Address Deficiencies in the UUSA QAP
The team reviewed event report EV 123188 which was written prior to the NRCs April 2019 inspection to address deficiencies in the UUSA Quality Assurance Progra At the time of this
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inspection, the event report was closed, and its final resolution transferred to UUSA QA staff to develop a lower tier Quality Assurance document for use by its general staff that just addresses Part 71 requirement UUSA stated that this new document is still under development and currently there are no plans to submit it to the NRC for review once it is complete The current UUSA Quality Assurance Program Description (QAPD) that addresses Part 70 and Part 71 will remain the official NRC approved QAP The team assessed that for UUSA to develop a lower tier quality assurance document just for the requirements of 10 CFR Part 71 Subpart H will improve its staffs understanding of transportation packaging quality requirement Review of Event Report EV 131849, Which was Written to Address the Audit Scope not Being Entered into the Annual Audit Schedule
The team reviewed the resolution of event report EV 131849, Audit scope not entered into the annual audit schedul During the April 2019 inspection, the inspectors identified that the audit schedule did not include all the information required by the QA audit procedure QA-3-2000-01, Quality Assurance Audit Revision 2 QA-3-2000-01, Section 5.1.2 e. requires the audit schedule include audit criteria, scope, frequency, and method of audit As a corrective action, UUSA updated the audit schedule with the information required in QA-3-2000-0 UUSA subsequently revised QA-3-2000-01 to delete the requirements for having the audit scope and method in the annual audit schedule as the audit schedule requirements are not from NQA-1-1994, Basic Requirement 18S-1 or the UUSA QAPD, Rev. 41 Section 18, Audit The team assessed that the corrective actions were adequate with no concern Review of Event Report EV 131846, Which was Written to Address the 2019 Violation for the Protective Shipping Package (UX-30) Supplier Not Being on UUSAs Approved Supplier List (ASL)
The team reviewed the resolution of event report EV 131846, Protective shipping package supplier not on UUSA approved supplier list (ASL). During the previous inspection, the inspectors identified that UUSA did not perform an evaluation to add a supplier, RSB Logistic Inc., to their ASL as required in Section 5.5 of QA-3-2000-08 Approved Supplier Lis RSB Logistic Inc. at the time provided contract services to perform the required annual maintenance/inspections on the UX-30 transportation packages UUSA leases from the As a result, UUSA did not implement QA-3-2000-01, Quality Assurance Audit, to schedule, prepare, and perform an audit of the service provider to assess the effectiveness of the control of quality by the contractor in accordance with the requirements of 10 CFR Part 71, subpart H and ASME NQA-1-1994, QA Program requirement UX-30 annual maintenance/inspections is a required condition of the UX-30 Certificate of Compliance 919 The team assessed during the April 2019 inspection that this was a violation of NRC regulation 10 CFR 71.115(c). 10 CFR 71.115, Control of purchased material, equipment, and services, states in paragraph (c), in part, that the licensee shall assess the effectiveness of the control of quality by contractors at intervals consistent with the importance, complexity, and quantity of the products or servic Page 6 of 6
As a corrective action, UUSAs contractor, RSB Logistic Inc., contracted with a company named Daher to perform UX-30 annual maintenance/inspections required by Certificate of Compliance 919 Daher possesses an NRC approved Quality Assurance Program and was subsequently audited by UUS As a final resolution, UUSA subsequently decided to perform all UX-30 annual maintenance/inspections by its own staff under their own NRC approved Quality Assurance Progra The inspectors reviewed a sample of UX-30 annual maintenance activities and determined that the maintenance activities were performed under an approved Quality Assurance Program and were performed in accordance with requirements of the Certificate of Compliance 9196 with no concerns.