IR 07100940/2025201

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Urenco USA – U.S. Nuclear Regulatory Commission Inspection Report 710940/2025201
ML25114A042
Person / Time
Site: 07100940
Issue date: 04/30/2025
From: Gerond George
NRC/NMSS/DFM/IOB
To: Lorskulsint P
Louisiana Energy Services, URENCO USA
References
IR 2025201
Download: ML25114A042 (1)
v • d • e


Text

SUBJECT:

URENCO USA - U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT NO. 710940/2025201

Dear Paul Lorskulsint:

This letter refers to the inspection conducted on March 5 - 6, 2025, at the Urenco USA (UUSA)

facility in Eunice, NM. The inspection team continued the inspection activities with an inoffice review and held an exit meeting on March 20, 2025. The purpose of the inspection was to verify and assess the adequacy of UUSAs activities associated with the transportation of radioactive material to determine if they were performed in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 71, Packaging and Transportation of Radioactive Material, 10 CFR Part 71 Certificates of Compliance (CoCs) for packages used by UUSA, and UUSAs U.S. Nuclear Regulatory Commission (NRC)-approved Quality Assurance Program (QAP). The enclosed report presents the results of this inspection.

The inspection examined activities conducted under your NRC-approved QAP as they relate to public health and safety, and to confirm compliance with the Commissions rules and regulations and with the conditions of the applicable CoCs. 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.

April 30, 2025 In accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any), will be made available electronically for public inspection in the NRC Public Document Room (PDR) or from the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. The PDR is open by appointment. To make an appointment to visit the PDR, please send an email to PDR.Resource@nrc.gov or call 1-800-397-4209 or 301-415-4737, between 8 a.m. and 4 p.m. eastern time (ET), Monday through Friday, except Federal holidays.

Sincerely, Gerond George, Acting Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 710940 Enclosure:

Inspection Report No. 710940/2025201 Signed by George, Gerond on 04/30/25

ML25114A042 OFFICE:

DFM E

DFM E

DFM E

NAME:

JTapp SFigueroa GGeorge DATE:

4/25/2025 4/28/2025 4/30/2025

Enclosure U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management

Inspection Report

Docket No.:

710940

Report No.:

710940/2025201

Enterprise Identifier:

I2025201-0010

Licensee:

Louisiana Energy Services (LES) dba Urenco USA (UUSA)

Location:

Eunice, NM

Inspection Dates:

March 5-20, 2025

Inspectors:

Jeremy Tapp, Sr. Transportation and Storage Safety Inspector,

Team Leader

Raju Patel, Transportation and Storage Safety Inspector

Eucherius Rosario, Transportation and Storage Safety Inspector

(In-training)

Approved by:

Gerond George, Acting Chief

Inspection and Oversight Branch

Division of Fuel Management

Office of Nuclear Material Safety

and Safeguards

EXECUTIVE SUMMARY

Urenco USA

NRC Inspection Report 710940/2025201 This routine inspection, performed at Urenco USAs (UUSAs) facility in Eunice, NM from March 5, to March 6, 2025, with additional inoffice review through March 20, 2025, evaluated the ongoing activities related to the transportation of radioactive materials in U.S. Nuclear Regulatory Commission (NRC)-approved transportation packagings. The purpose of the inspection was to verify and assess the adequacy of UUSAs radioactive material transportation activities to determine if they were performed in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 71, Packaging and Transportation of Radioactive Material, the Certificates of Compliance (CoCs) and Safety Analysis Reports (SARs) for packagings used by UUSA, and UUSAs NRC-approved 10 CFR Part 71 transportation Quality Assurance Program (QAP).

Based on the results of this inspection, the NRC inspection team assessed that overall, the implementation of UUSAs QAP was adequate.

Quality Assurance Program The team determined that UUSA conducted quality related activities such as procurement and maintenance of transportation packaging(s) in accordance with the CoCs and QAP. The team determined that UUSA had effective implementing procedures in place. (section 1.1)10 CFR Part 21 The team determined that the provisions of 10 CFR Part 21 were implemented, UUSA personnel were familiar with the reporting requirements of 10 CFR Part 21 and UUSA complied with 10 CFR 21.6, "Posting requirements." (section 1.2)

Fabrication, Testing, and Maintenance The team concluded that UUSA is effectively implementing its maintenance program through use of adequate work instructions and procedures to ensure compliance with the applicable regulations, SAR commitments, CoC conditions, and QAP requirements. (section 1.3)

Procurement Control The team concluded that overall, UUSA is adequately implementing its procurement document control and supplier oversight programs in accordance with UUSAs QAP requirements, site quality procedures, and applicable regulatory requirements. (section 1.4)

Nonconformance and Corrective Action The team concluded that overall, UUSA effectively implemented its nonconformance control program and corrective action program (CAP) and had adequate procedures in place to ensure compliance with the applicable regulations and QAP requirements. (section 1.5)

Personnel Training and Quality Assurance Oversight The team concluded that UUSA had trained and qualified individuals performing activities affecting quality and that UUSA management provided appropriate oversight of quality related activities, as applicable. (section 1.6)

Audit Program The team concluded that UUSA had an adequate audit program in place to schedule, evaluate, and document the results. The team determined that UUSA appropriately identified issues and documented them in the CAP as required. (section 1.7)

REPORT DETAILS

1.0 Applicable portions of Inspection Procedure 86001 - Design, Fabrication, Testing, and Maintenance of Transportation Packagings 1.1 Quality Assurance Program 1.1.1 Inspection Scope The NRC inspection team reviewed UUSA's quality assurance program description (QAPD) and implementing procedures to verify how UUSA conducted 10 CFR Part 71 activities in accordance with their QAP. The team reviewed UUSA's QAPD, revision 45b, and quality procedure QA-3-2000-06 "Quality Assurance Program Description Change(s)," revision 3. The team also reviewed UUSAs QA-1-2000-01, 10 CFR Part 71, Subpart H Quality Assurance Manual for Packaging and Transportation of Radioactive Materials for URENCO USA, revision 3, which is a lower tier quality assurance (QA) document just for 10 CFR Part 71 Subpart H requirements. The team conducted a high-level review of the program and implementing procedures to evaluate the quality program authorities, responsibilities and functions.

1.1.2 Observations and Findings Due to time constraints, the team was not able to review in detail UUSA's document controls and quality records management programs. It should be noted that in all the procedures that were reviewed by the team, reference was made to procedure RM-3-2000-01, "Records Management Program," revision 30, for the control and retention of all quality records. In general, the team found that UUSA was able to find quickly the documents requested by the team. This indicated that record management at the site was adequate.

Overall, the team assessed that UUSA has an effective program and implementing procedures in place to conduct activities in accordance with Part 71 requirements and their QAP. The team verified that UUSA clearly defined and documented the quality program authorities and responsibilities, and that the QA organization functioned as an independent group.

No findings of significance were identified.

1.1.3 Conclusions The team determined that UUSA conducted quality related activities such as procurement and maintenance of transportation packaging(s) in accordance with the CoCs and QAP. The team determined that UUSA had effective implementing procedures in place.

1.2 10 CFR Part 21 1.2.1 Inspection Scope The team reviewed UUSAs 10 CFR Part 21 procedure LS-3-1000-01, "Implementation of 10 CFR 21," revision 12, to evaluate if provisions were in place for evaluating deviations that could cause a substantial safety hazard and complete the required notifications in a timely manner. The team requested a list of Part 21 evaluations and notifications associated with the UX-30 transportation packaging and interviewed personnel to verify if they were familiar with the implementing procedure LS-3-1000-01.

The team also visited three locations where UUSA had posted the Part 21 requirements in accordance with the 10 CFR 21.6, "Posting requirements.

1.2.2 Observation and Findings The team assessed that UUSA has provisions in place for evaluating deviations and reporting defects, as required by 10 CFR Part 21. The team noted that UUSA did not issue any Part 21 reports since the previous NRC inspection.

No findings of significance were identified.

1.2.3 Conclusions The team determined that the provisions of 10 CFR Part 21 were implemented, UUSA personnel were familiar with the reporting requirements of 10 CFR Part 21, and UUSA complied with 10 CFR 21.6, "Posting requirements."

1.3 Fabrication, Assembly, Maintenance and Testing 1.3.1 Inspection Scope The team reviewed selected procedures and records to determine whether testing and maintenance activities met SAR design commitments, procedures, and requirements documented in the CoC. The team reviewed maintenance activities for the UX-30 packaging as it was the primary package used at UUSA to transport uranium hexafluoride cylinders. Specifically, the team reviewed routine and annual UX-30 packaging inspection documentation for a sample of UX-30 packagings currently being used by UUSA. Documentation included work orders, weld inspection reports, completed inspection checklists, and certificates of compliance for annual inspections performed by approved vendors.

The team also performed a walkdown of UX-30 packagings onsite to assess their material condition. Since there were no planned maintenance activities during the time the team was onsite at UUSA, the team observed a weld inspection demonstration by a qualified weld inspector on a UX-30 packaging to verify conformance to site procedures and SAR requirements.

The team reviewed a selection of calibration records for measuring and test equipment (M&TE) used as a part of the routine and annual inspections. This included a scale for UX-30 packaging weight and light meter used for weld inspections and the associated calibration data and certificates from approved vendors.

1.3.2 Observation and Findings The team assessed that UUSA used appropriate maintenance tools and equipment and qualified personnel in accordance with approved procedures to conduct routine and annual maintenance activities for the UX-30 packaging. The team verified that the inspections were comprehensive and met acceptance criteria identified in the maintenance records, procedures, and SAR. The team also verified that annual maintenance records from approved suppliers were adequately completed and included required inspection areas defined in the SAR. Overall, the team assessed that the maintenance activities satisfied the requirements identified in the UX-30 SAR and CoC.

No findings of significance were identified.

1.3.3. Conclusion The team concluded that UUSA is effectively implementing its maintenance program through use of adequate work instructions and procedures to ensure compliance with the applicable regulations, SAR commitments, CoC conditions, and QAP requirements.

1.4 Procurement Control 1.4.1 Inspection Scope:

The team reviewed selected records and interviewed selected personnel to verify that the procurement specifications for equipment and services received by UUSA met the design requirements. The team selected providers of UX-30 annual maintenance and M&TE calibration services for review of procurement documents and receipt records.

The team also reviewed UUSAs processes and procedures that address procurement to determine they are adequate to ensure that any procured material, services, and equipment meet the design specifications.

1.4.2 Observation and Findings:

The team determined that UUSA procured services from approved suppliers listed and current on the approved suppliers list (ASL), and receipt records of the services provided was reviewed and approved as required. The team also noted that for the approved suppliers on the ASL that were used for the services reviewed, supplier audits and evaluations were performed as required. Supplier audits were reviewed by the team as described in section 1.7 of this report.

No findings of significance were identified.

1.4.3 Conclusions:

The team concluded that overall, UUSA is adequately implementing its procurement document control and supplier oversight programs in accordance with UUSAs QAP requirements, site quality procedures, and applicable regulatory requirements.

1.5 Nonconformance and Corrective Action Programs 1.5.1 Inspection Scope The team reviewed nonconformance reports (NCRs) and interviewed selected personnel to evaluate how UUSA implemented their nonconformance control and CAP. The team reviewed a sample of completed NCRs to evaluate if UUSA identified nonconforming items concerning materials, parts, or components in accordance with applicable requirements. The team also reviewed a sample of event reports (EVs) used to document quality issues in the CAP. The team discussed some of the NCRs and EVs with UUSA staff. The team reviewed the following UUSA quality procedures:

  • EG-3-2100-09, "Identification, Disposition, and Resolution of Nonconforming Items," revision 12
  • CA-3-1000-01, "Performance Improvement Program," revision 44
  • CA-3-1000-02, Apparent Cause Evaluation Guidelines," revision 10
  • CA-3-1000-03, "Root Cause Evaluation Guidelines," revision 9 1.5.2 Observation and Findings In general, the team assessed that UUSA effectively implemented the nonconformance and performance improvement programs (UUSA's CAP) and had adequate procedures in place to ensure compliance with the applicable regulations and approved QAP requirements. During the inspection the team reviewed implementation of previous inspection findings documented by UUSA EVs. The team assessed UUSAs implementation of corrective action taken to address the issues identified and documented in EV 131849, 132498, and EV 138086. Based on evaluation of UUSAs corrective actions taken the team found the corrective actions to be effectively implemented.

No findings of significance were identified.

1.5.3 Conclusions The team concluded that overall, UUSA effectively implemented its nonconformance control program and CAP and had adequate procedures in place to ensure compliance with the applicable regulations and QAP requirements.

1.6 Personnel Training and Certifications 1.6.1 Inspection Scope The team reviewed selected records and procedures and interviewed selected personnel to verify that individuals performing activities affecting quality are properly trained and qualified, and to verify that management and QA staff are cognizant and provide appropriate oversight.

The team reviewed selected records and procedures, interviewed personnel, and discussed the maintenance activities affecting the safety aspects of the UX-30 packaging to verify that UUSA provided oversight and had trained and qualified individuals performing inspection and nondestructive examination activities. The team also reviewed a sample of lead auditor qualifications to determine if UUSA performed audits with qualified personnel in accordance with site quality procedures.

1.6.2 Observation and Findings The team found for the sample of UUSA staff members records reviewed, each had completed the required training and attained the applicable qualifications to perform their duties.

No findings of significance were identified.

1.6.3 Conclusions The team concluded that UUSA had trained and qualified individuals performing activities affecting quality and that UUSA management provided appropriate oversight of quality related activities, as applicable.

1.7 Audit Program 1.7.1 Inspection Scope The team reviewed the UUSA audit program to determine if UUSA scheduled, planned, and performed internal and external (supplier) audits in accordance with approved implementing procedures. Specifically, the team reviewed the following quality procedures:

  • QA-3-1000-01, Quality Evaluation of Nuclear Industry Assessment Corporation (NIAC) Assessment Reports, revision 5
  • QA-3-2000-08, "Approved Supplier List," revision 17 The team selected a sample of internal and supplier audits from the previous five years, particularly related to transportation activities. The team reviewed the audit results to determine if UUSA identified deficiencies and addressed the deficiencies within their CAP. The team also reviewed UUSA's ASL to select supplier audits.

1.7.2 Observation and Findings Overall, the team assessed that for the internal audits, surveillances, and supplier audits sampled, UUSA generally scheduled and evaluated applicable elements of the QAP and conducted audits with qualified and certified personnel.

No findings of significance were identified.

1.7.3 Conclusions The team concluded that UUSA had an adequate audit program in place to schedule, evaluate, and document the results. The team determined that UUSA appropriately identified issues and documented them in the CAP as required.

2.0 Exit Meeting and Debrief On March 6, 2025, the NRC inspection team discussed the preliminary results during an onsite debrief with UUSA staff. An exit meeting was held virtually on March 20, 2025, after the in-office review to discuss the final results with UUSA staff.

ATTACHMENT

1. EXIT MEETING/DEBRIEF ATTENDEES AND INDIVIDUALS INTERVIEWED

Name Title Affiliation Onsite Debrief Exit Jeremy Tapp Inspection Team Leader NRC X

X Raju Patel Inspector NRC X

X Eucherius Rosario Inspector in-training NRC X

Gerond George Branch Chief NRC X

Paul Lorskulsint Chief Nuclear Officer UUSA X

Wyatt Padgett Design Basis &

Criticality Safety Manager UUSA X

Shawn OBrien Logistics Manager UUSA X

X Kevin Slavings QA Manager UUSA X

X Brian Dorathy Engineering and Site Projects UUSA X

Gabriel Chavez Training Manager UUSA X

Holly Harvey Licensing UUSA X

Jim Rickman Licensing UUSA X

X Steve Ward Licensing UUSA X

X Quentin Newell NCS UUSA X

Susie Cheslik Logistics/Transport UUSA X

X T.D. Foster Design Safety Basis/ISA Engineering UUSA X

Richard Lehman Design Basis/ISA Engineering UUSA X

Carlos Graybill Design Basis/NCS/ISA UUSA X

William Todd Design Basis/ISA/NCS UUSA X

2. INSPECTION PROCEDURES USED

IP 86001 Design, Fabrication, Testing, and Maintenance of Transportation Packagings NUREG/CR6407 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

3. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Item Number Status Type Description None

4. LIST OF ACRONYMS USED

ADAMS Agencywide Documents Access and Management System ASL Approved Suppliers List CAP Corrective Action Program 10 CFR Title 10 of the Code of Federal Regulations CoC Certificate of Compliance EV Event Report IP Inspection Procedure LES Louisiana Energy Services M&TE Measuring and Test Equipment NCR Nonconformance Report NRC Nuclear Regulatory Commission QA Quality Assurance QAP Quality Assurance Program QAPD Quality Assurance Program Description SAR Safety Analysis Report UUSA Urenco USA

5.

PARTIAL LIST OF

DOCUMENTS REVIEWED

In addition to the documents listed below, licensee documents reviewed during the inspection

are specifically identified in the Report Details above.

Approved Suppliers List

Approved Suppliers List LES, dated February 26, 2025

Event Reports Opened During Inspection

EVENT-2025-1106

EVENT-2025-1126

EVENT-2025-1131

EVENT-2025-1132

EVENT-2025-1133

EVENT-2025-1347

EVENT-2025-1349

EVENT-2025-1352

Maintenance CoCs for UX-30 Packagings

Orano TLI CoC for CHT-1078, dated March 18, 2024

Orano TLI CoC for CHT-1063, dated February 8, 2023

Orano TLI CoC for CHT-1056, dated May 9, 2022

Orano TLI CoC for UREJ870113, dated November 19, 2023

Orano TLI CoC for SPUX0117, May 28, 2024

Orano TLI CoC for PSP-034, dated January 24, 2025

Procedures

EG-3-2100-05, Commercial Grade Dedication Process, revision 29

LO-3-2000-01, Receipt and Shipment of Cylinders, revision 32

LO-3-4000-01, Periodic Inspection of Protective Shipping Packages, revision 16

PR-3-2000-01, UUSA Control of Procurement, revision 24

QA-3-2000-03, Training, Qualification, and Certification of QA Personnel, revision 15

QA-3-3000-02, QC Inspector Training and Qualification, revision 12

QA-3-3000-03, Visual Examinations, revision 4

QA-3-3000-05, Written Practice for Qualification and Certification of Non-Destructive

Examination Personnel, revision 8

QA-3-3000-17, Welding Inspection, revision 11

RM-3-3000-01, Control of Documents, revision 23

Purchase Orders

Purchase Order No. 4500192862 to TAM International LP, dated January 9, 2025

Supplier Audits and Evaluations

24-E-12-105 for Orano TLI, dated December 19, 2024

23-A-02-004 for Orano Nuclear Cargo Services, GmBH, dated May 18, 2023

22-A-09-018 for Orano TLI, dated February 14, 2023

Work Orders

Work Order Number: 1000623717, UX-30 Overpack Inspection, dated March 18, 2024

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