ML18211A164

Louisiana Energy Services, LLC, Dba Urenco USA - NRC Integrated Inspection Report 07003103/2018003

ML18211A164
Person / Time
Site:	07003103
Issue date:	07/27/2018
From:	Robert Williams NRC/RGN-II/DFFI
To:	Cowne S Louisiana Energy Services, URENCO USA
References
IR 2018003
Download: ML18211A164 (22)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 July 27, 2018 Stephen Cowne, Chief Nuclear Officer and Compliance Manager URENCO USA P.O. Box 1789 Eunice, NM 88231

SUBJECT:

LOUISIANA ENERGY SERVICES, LLC (LES), dba URENCO USA (UUSA) -

NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 70-3103/2018-003

Dear Mr. Cowne:

This letter refers to the inspections conducted from April 1 through June 30, 2018, at the URENCO USA facility located in Eunice, New Mexico. The purpose of these inspections was to determine whether licensed activities were conducted safely and in accordance with U.S.

Nuclear Regulatory Commission (NRC) requirements. The enclosed report presents the results of these inspections, which were discussed with you and members of your staff on April 19, May 24, and June 26, 2018.

These inspections examined activities conducted under your license, as they related to public health and safety, and to confirm compliance with NRC rules and regulations and with the conditions of your license. The inspection areas covered Safety Operations; Radiation Protection; Radioactive Waste Processing, Handling, Storage, and Transportation; Effluent Control and Environmental Protection; and Corrective Action Program Implementation at Fuel Cycle Facilities. Within these areas, the inspections consisted of examinations of selected procedures and representative records, observations of activities, and interviews with personnel.

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 of the NRCs Agency Rules of Practice and Procedure, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.

S. Cowne 2

If you have any questions regarding this matter, please contact me at (404) 997-4664.

Sincerely,

/RA/

Robert E. Williams Jr., Acting Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 70-3103 License No. SNM-2010

Enclosure:

Inspection Report No. 70-3103/2018-003 w/

Attachment:

Supplemental Information cc: (See page 3)

S. Cowne 3

cc:

Butch Tongate, Cabinet Secretary New Mexico Department of Environment Office of the Secretary 1190 St. Francis Drive P.O. Box 26110 Santa Fe, NM 87502-0157 Billy Hobbs, Mayor City of Eunice P.O. Box 147/1106 Ave J Eunice, NM 88231 The Honorable Sam D. Cobb, Mayor City of Hobbs 200 E. Broadway Hobbs, NM 88240 Stephen Aldridge, Mayor City of Jal P.O. Drawer 340 Jal, NM 88252 Chair Ron R. Black Lea County Board of County Commissioners Lea County Courthouse 100 North Main Avenue, Suite 4 Lovington, NM 88260 Daniel F. Stenger, Counsel Hogan Lovells VP LLP 555 13th Street, NW Washington, DC 20004 Santiago Rodriguez, Chief Radiation Controls Bureau NM Environment Department PO Box 5469 Santa Fe, NM 87502-5469 David Sexton, Managing Director UUSA, President and Chief Executive Officer Louisiana Energy Services, LLC URENCO USA P.O. Box 1789 Eunice, NM 88231 Dave.Sexton@Urenco.com (cc: Contd on page 4)

S. Cowne 4

(cc: contd)

Lisa Hardison, Manager Communications and Public Relations Louisiana Energy Services, LLC URENCO USA P.O. Box 1789 Eunice, NM 88231 Lisa.Hardison@urenco.com Richard Goorevich, Director Government Affairs Louisiana Energy Services, LLC URENCO Ltd.

1560 Wilson Blvd. Suite 300 Arlington, VA 22209 Richard.Goorevich@urenco.com Perry Robinson, Outside General Counsel URENCO USA P.O. Box 1789 Eunice, NM 88231 Perry.Robinson@urenco.com Richard A. Ratliff, PE, LMP Radiation Program Officer Bureau of Radiation Control Department of State Health Services Division for Regulatory Services 1100 West 49th Street Austin, TX 78756-3189

S. Cowne 5

SUBJECT:

LOUISIANA ENERGY SERVICES, LLC (LES), dba URENCO USA (UUSA) -

NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 70-3103/2018-003 DISTRIBUTION:

M. Lesser, RII L. Suggs, RII R. Williams, RII R. Nease, RII J. Rivera Ortiz, RII K. Kirchbaum, RII K. Sturzebecher, NMSS PUBLIC PUBLICLY AVAILABLE NON-PUBLICLY AVAILABLE SENSITIVE NON-SENSITIVE ADAMS:

Yes ACCESSION NUMBER:ML18211A164 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI DC SIGNATURE

/RA/

/RA/

/RA/

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NAME RGibson GGoff PStartz BAdkins KKirchbaum TVukovinsky KMcCurry KKirchbaum DATE 07/17/2018 07/25/2018 07/16/2018 07/17/2018 07/17/2018 07/19/2018 07/16/2018 07/17/2018 E-MAIL COPY YES NO YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICE RII:DFFI SIGNATURE

/RA/

NAME JRivera DATE 07/16/2018 EMAIL COPY YES NO G:\\DFFI\\REPORTS\\Final Reports\\LES\\2018\\LES IR 2018003.docx

U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.:

70-3103 License:

SNM-2010 Report No.:

70-3103/2018-003 Licensee:

Louisiana Energy Services (LES), LLC Facility:

URENCO USA (UUSA)

Location:

Eunice, NM Inspection Dates:

April 1 through June 30, 2018 Inspectors: B. Adkins, Senior Fuel Facility Project Inspector (Section C.1)

R. Gibson, Senior Fuel Facility Inspector (Section B.2)

G. Goff, Fuel Facility Inspector (Section B.1)

K. Kirchbaum, Fuel Facility Inspector (Sections A.1 and C.1)

K. McCurry, Fuel Facility Inspector (Section C.1)

P. Startz, Fuel Facility Inspector (Section B.3)

T. Vukovinsky, Senior Fuel Facility Project Inspector (Section C.1)

Approved:

Robert E. Williams Jr., Acting Chief Projects Branch 1 Division of Fuel Facility Inspection Enclosure

EXECUTIVE

SUMMARY

Louisiana Energy Services, LLC (LES) dba URENCO USA (UUSA)

Nuclear Regulatory Commission Integrated Inspection Report 70-3103/2018-003 April 1 - June 30, 2018 Regional inspectors from the U.S. Nuclear Regulatory Commission (NRC) conducted announced inspections during normal shifts and in-office reviews. The inspectors performed direct observation of safety-significant activities and equipment, tours of the facility, interviews and discussions with licensee personnel, and a review of facility documents.

Safety Operations The inspectors reviewed the implementation of item relied on for safety (IROFS) C23 for Cascade 6.4 to verify compliance with conditions of the license and regulatory requirements.

No violations of more than minor significance were identified. (Section A.1)

Radiological Controls The inspectors reviewed a sample of activities in the radiation protection area to verify compliance with conditions of the license and regulatory requirements. No violations of more than minor significance were identified. (Section B.1)

The inspectors reviewed a sample of activities in the area of radioactive waste processing, handling, storage and transportation to verify compliance with conditions of the license and regulatory requirements. No violations of more than minor significance were identified.

(Section B.2)

The inspectors reviewed a sample of activities in the effluent control and environmental protection area to verify compliance with conditions of the license and regulatory requirements. No violations of more than minor significance were identified. (Section B.3)

Other Areas - Corrective Action Program Implementation at Fuel Cycle Facilities The inspectors determined that the licensee adequately implemented the corrective action program (CAP) in accordance with the licensing basis of the facility. The timelines, threshold, and categorization of issues entered into the CAP were consistent with plant procedures. Generally, event evaluations were effective in identifying appropriate corrective actions and preventing recurrence. The inspectors noted that the Quality Assurance (QA) department was fully involved in revisions to CAP procedures and policies. The inspectors confirmed that employees were aware of the venues available for entering safety or security concerns into the CAP. The inspectors determined that the QA organizational structure provided separation and independence from production-related influences. No violations of more than minor significance were identified. (Section C.1)

Attachment Key Points of Contact List of Report Items Inspection Procedures Used Documents Reviewed

REPORT DETAILS Summary of Plant Status The URENCO USA facility enriches uranium hexafluoride (UF6) using a gas centrifuge technology. During the inspection period, the licensee conducted routine plant operations.

A.

Safety Operations

1.

Operational Safety (Inspection Procedure 88020)

a. Inspection Scope On July 11, 2018, the inspectors conducted an in-office review of records associated with IROFS C23 for the verification of Cascade 6.4. The inspectors verified that the design features of the centrifuge were adequately tested prior to commercial operation as described in the Integrated Safety Analysis (ISA) Summary. The inspectors confirmed that the passive engineered controls were tested and capable of performing their intended safety function. The inspectors interviewed licensee staff to verify that changes to the procedure for the operational validation of IROFS C23, if any, were evaluated in accordance with the licensing basis of the facility.

The previous NRC review of IROFS C23 was for Cascade 6.3, which took place in November 2017. The inspection results for the operational readiness review of Cascade 6.3 were expected to be documented in NRC Inspection Report 70-3103/2017-005; however, these were omitted by error. The inspectors review was similar in scope to the review of Cascade 6.4 described above and did not identify any violations of more than minor significance.

b. Conclusion

No violations of more than minor significance were identified.

B.

Radiological Controls

1.

Radiation Protection (Inspection Procedure 88030 - Appendix A)

a. Inspection Scope The inspectors reviewed a sample of documents and observed activities to verify that the Radiation Protection (RP) program was implemented in accordance with Chapter 4, Radiation Protection, of the Safety Analysis Report (SAR) and procedure RP-2-1000-01, Radiation Protection Program, Revision (Rev.) 9, July 27, 2017. The inspectors also performed the above to verify that the program functions and responsibilities were independent from operations/production. The specific inspection activities performed are further described below.

The inspectors reviewed the latest external and internal audits and conducted interviews with RP personnel to verify that the program was being documented in accordance with 10 CFR 20.1101(a) and (c) and Chapter 11.5, Audits and Assessments, of the SAR.

2 The inspectors reviewed CAP entries from these audits to determine whether the licensee was identifying issues at an appropriate threshold and entering them into the corrective action program as required by Chapter 11.6, Incident Investigations and Corrective Action Process, of the SAR.

The inspectors reviewed organizational changes in the RP program by reviewing the current organizational chart and recent management changes, and conducting interviews with licensee staff, to verify that personnel qualifications met the requirements in Chapter 2.3.3, Training and Qualifications, of the SAR.

The inspectors reviewed changes to program procedures to verify that any changes did not diminish safety and were in compliance with Chapter 4.4, Commitment to Written Procedures, of the SAR. The inspectors also interviewed RP personnel and reviewed current RP procedures to verify these procedures were reviewed at an established frequency as per Chapter 11.4, Procedures Development and Implementation, of the SAR.

The inspectors reviewed RP personnel training records and interviewed RP staff to verify that employees received training at the frequency specified in Chapter 11.3, Training and Qualifications, of the SAR and as required in 10 CFR 19.12. The inspectors reviewed training records to also confirm the licensees RP training program included risk awareness for accidents involving licensed activities. The inspectors reviewed two new qualification cards - one for RP personnel; the other for non-RP personnel who handle special nuclear material (SNM) - to determine compliance with the training program outlined in Chapter 4.5, Training Commitments, in the SAR.

The inspectors reviewed selected radiation work permits (RWPs) (RWP-18-01 and RWP-18-03) to verify that the licensee complied with Chapter 4.4.1, Radiation Work Permits, of the SAR. The inspectors observed the reduction in size of a radiologically controlled area performed under RWP-18-03 to confirm that the requirements in that RWP were implemented in the field.

The inspectors reviewed recent calibration records (sticker labels and computer records) for survey instruments (for each type of nuclear radiation) as well as the licensees software system for identifying calibration due dates (HIS-20) for these instruments in order to verify compliance with Chapter 4.7, Radiation Surveys and Monitoring Programs Commitments, of the SAR and 10 CFR 20.1501(c). The inspectors also observed the daily response checks performed on several survey meters used for detecting alpha, beta, and gamma radiation.

The inspectors observed a functional test performed on a whole-body contamination monitor to verify it responded at the set point specified in RP-3-3000-19, Personnel Contamination Monitors, Revision 7, February 1, 2018. The inspectors later observed decontamination protocol being performed by RP personnel on an employee who was detected by this same monitor to have external contamination in order to verify compliance with RP-3-2000-07, Personnel Contamination Events, Rev. 9, November 30, 2017.

The inspectors observed radiation and contamination surveys in the Cylinder Receipt and Dispatch Building (CRDB) in order to verify that the licensee performed these surveys in accordance with Chapter 4.7 of the SAR, Radiation Surveys and Monitoring

3 Programs Commitments and 10 CFR 20.1501(a) and (b). The inspectors reviewed radiation survey records to verify that such records were maintained for at least three years in accordance with 10 CFR 20.2103.

The inspectors walked-down processing and storage areas to verify that radiological postings complied with 10 CFR 20.1902 and 20.1903. The inspectors observed radioactive material containers in processing and storage areas to confirm that the containers were labeled in accordance with 10 CFR 20.1904 and 20.1905.

The inspectors reviewed a sample of quarterly occupational dose reports to verify compliance with Chapter 4.2, Commitment to an ALARA Program and Chapter 4.8.2, External Exposures in the SAR. The inspectors also reviewed RP-related records to verify that the licensee maintained records for at least three years after the record was made in accordance with 10 CFR 20.2102 and Chapter 11.7, Records Management, of the SAR.

The inspectors reviewed a sample of leak test survey records for sealed sources to verify that the licensee was in compliance with procedure RP-3-2000-04, Radiation and Contamination Surveys, Rev. 10, November 8, 2017. The inspectors reviewed dose rate measurements and observed postings to confirm that the storage of the sealed and unsealed sources was in accordance with 10 CFR 20.1903(c) and 20.2902(e),

respectively. The inspectors also reviewed documentation to verify that these sources were NIST-traceable.

The inspectors reviewed the Total Effective Dose Equivalent results to verify that they did not exceed the regulatory limit of 5 rem/yr. The inspectors reviewed the 2017 occupational dose results to verify that the Lens Dose Equivalent and Shallow Dose Equivalent results did not exceed the regulatory limits of 15 and 50 rem/year, respectively. Through interviews with RP personnel, the inspectors verified that records were maintained in accordance with 10 CFR 20.2106.

The inspectors reviewed bulletin boards at main employee entrances to verify the licensee was posting notices in accordance with 10 CFR 19.11, including NRC Form 3, Notice to Employees.

b. Conclusion No violations of more than minor significance were identified.

2.

Radioactive Waste Processing, Handling, Storage, and Transportation (Inspection Procedure 88035)

a. Inspection Scope The inspectors reviewed the licensees radioactive waste management program to verify that it was being implemented in accordance with the license and regulations. The inspectors evaluated whether the licensee had established and maintained procedures and a quality assurance program for the characterization, classification, stabilization, and shipment manifests/tracking of low-level radioactive waste in accordance with 10 CFR Part 20 and 10 CFR Part 61. The inspectors reviewed the QA program for radioactive waste management to verify that the licensee was performing the required audits,

4 presenting the annual audit results to the management team, and entering audit findings into the licensees CAP for resolution. The inspectors reviewed events identified in the licensees CAP to verify that deviations from procedures and unforeseen process changes were documented and investigated.

The inspectors reviewed procedures and observed performance of tasks related to radioactive waste management to verify that the procedures were clearly written and adequately delineated responsibilities related to radioactive waste management. The inspectors observed recycling technicians performing radioactive waste management activities in order to verify that the technicians were familiar with their responsibilities as they performed their tasks in accordance with on-site procedures. Also, the inspectors reviewed training records to verify that the recycling technicians were trained in accordance with the license application.

The inspectors evaluated the licensees program for classifying low-level radioactive waste by reviewing records relating to waste and procedures for classifying waste. The inspectors reviewed the licensees program for waste packaging to ensure that the waste form met the requirements of 10 CFR 61.55. The inspectors performed visual examinations of collection and waste storage areas located in the CRDB. The inspectors reviewed inventories and inspected a sample of waste containers (55 gallon drums) stored in a designated waste storage area of the CRDB. The inspectors conducted these activities to verify that the licensee was in compliance with federal regulations and their license.

The inspectors evaluated the licensees program for characterizing low-level radioactive waste by reviewing documents and records of activities which have been established and are being maintained to verify whether low-level radioactive waste meets the waste characterization requirements of 10 CFR 61.56.

The inspectors reviewed the licensees procedures for labeling waste shipments and tracking radioactive waste. The procedures stated how radioactive waste was to be properly labeled and specified actions to be taken should the shipments not reach the intended destination in the time specified. The inspectors also reviewed procedures for placement, inspection, and repackaging of radioactive waste to verify that they met the provisions of the license application.

The inspectors performed walk-downs of selected radioactive material storage areas in order to verify that postings and storage of materials in the designated waste storage area was in accordance with the NRC license requirements. The inspectors observed containers to verify both proper labeling of their contents and acceptable physical condition of the containers.

The inspectors observed recycling technicians operate the multi-functional decontamination train (MFDT), which involved the addition of a sample bottle with depleted tail UF6 material for down-blending the liquid waste stream from the MFDT to the slab tanks. The inspectors observed the implementation of IROFS 24c, gaseous effluent ventilation system (GEVS) monitoring and posting; IROFS 55a and b, limiting enrichment in the bulk storage tanks; IROFS 56a and b, limiting uranic mass in the MFDT disassembly and spray stations; and IROFS 57a and b, limiting uranic mass in the MFDT degreaser, citric acid, neutralization, and demineralization baths. The

5 inspectors conducted this activity to verify that the work and checks were in accordance with the Startup, Operation and Shutdown of the Multi-Functional Decontamination Train procedure, RW-3-4000-02, Rev. 10.

The inspectors also observed a Recycling Technician perform compaction of solid radioactive waste material in the Drum Compaction Room. The inspectors conducted this activity to verify that the work and checks were in accordance with procedure RW 1000-17, Operation of the Hydraulic Drum Crusher/Compactor Model HDC-900-IDC, Rev. 0.

b. Conclusion No violations of more than minor significance were identified.

3.

Effluent Control and Environmental Protection (Inspection Procedure 88045)

a. Inspection Scope The inspectors reviewed changes to the effluent control and environmental program and procedure revisions since the last inspection to determine compliance with the requirements described in Chapter 11, Section 11.4.4, Changes to Procedures, of the SAR.

The inspectors reviewed the 2017 semi-annual effluent reports to evaluate compliance with the submission requirements of 10 CFR 70.59. Within the two latest available emissions reports, the inspectors reviewed samples of records of airborne and liquid effluents for Uranium-234, -235, and -238 to determine if total effluent concentrations were below 10 CFR 20 Appendix B, Table 2 limits.

The inspectors directly observed accessible components of 11 process stacks that discharged filtered effluents to the environment as part of the GEVS. The inspectors reviewed samples of monitoring results to evaluate whether monitoring activities were performed in accordance with procedure EN-3-2020-01, EN Air Sampling, and 10 CFR 20.2103(b)(4). The inspectors reviewed airborne radionuclide data used to calculate dose to a hypothetical individual member of the public likely to receive the highest dose from facility operations for compliance with the as low as reasonably achievable (ALARA) requirements in 10 CFR 20.1101(d).

The inspectors observed the locations of all plant fence line perimeter thermoluminescent dosimetry (TLD) and discussed the TLD change out frequency and the procedure for performing the change outs to verify compliance with the license requirements. The inspectors reviewed the latest perimeter TLD data to verify that the total annual public dose did not exceed the limit established in 10 CFR 20.1301(a)(1).

The inspectors directly observed accessible components of five GEVS stacks located across several production buildings. The inspectors observed the configuration and effluent flow path through ductwork, banks of filters, radionuclide and hydrofluoric acid (HF) monitoring equipment, air flow transmitters, sample ports and piping, and the exhaust stack discharges on the roof. The inspectors verified that the accessible equipment appeared fully operational, instrumentation was functioning, and flow indicator calibration labels were current. The inspectors evaluated if GEVS

6 maintenance, operations, and calibrations were in compliance with 10 CFR 20.1501, EN-3-1000-36, Alpha Monitor (ABPM 201 S) Calibration and Maintenance, and EN 100-37, MacGiver HF-2 Monitor Maintenance & Calibration, respectively.

The inspectors walked down systems involved with the collection, transfer, and treatment of waste solutions derived from uranium processes. The inspectors also reviewed portions of other industrial and environmental water discharges not directly related to the main enrichment and decontamination operations, such as storm water runoff, air conditioner condensate, and cooling tower blowdown. The inspectors evaluated if the industrial and environmental water discharges were routed to their correct retention/detention evaporation basins and whether the basin water and sediment had been sampled/analyzed for radionuclides in accordance with Chapter 6 of the Environmental Report. The inspectors performed walkdowns of the west, east, and storm water retention basins to assess their condition and confirm that water sampling from these basins was not possible due to recent extreme drought conditions.

The inspectors reviewed the sanitary wastewater lift station on the southwest corner of the property to assess proper operation, connection to the City of Eunice publically owned treatment works, proper collection of water samples, and if the sample results were in compliance as required by Chapter 6 of the Environmental Report and 10 CFR 20.2003. The inspectors also evaluated all groundwater sampling well locations and reviewed sample results to determine compliance with the New Mexico Discharge Permit DP-1481.

The inspectors reviewed the latest 2017 environmental internal audit to evaluate if the audit was conducted in accordance with Chapter 11.5, Audits and Assessments, of the SAR, and if the findings were entered into the CAP.

b. Conclusion No violations of more than minor significance were identified.

C.

Other Areas

1.

Corrective Action Program Implementation at Fuel Cycle Facilities (Inspection Procedure 88161)

a. Inspection Scope Policies, Programs, and Procedures The inspectors reviewed the UUSA Quality Assurance Program Description (QAPD) and Performance Improvement Program (PIP), also known as the CAP, implementing procedures and documents. The inspectors verified the QAPD commitments were adequately implemented in the PIP. The QAPD included high level commitments for the PIP, including definitions of key terms, PIP expectations, PIP requirements, personnel responsibilities, and implementation processes. The QAPD commits to the prompt identification and correction of conditions adverse to quality, safety, and security. These commitments have also been incorporated into the procedures and processes in the PIP.

7 The inspectors reviewed the QA department involvement in the PIP functions and procedures. Specifically, the inspectors reviewed documents and interviewed PIP staff to verify that QA department personnel were involved in the PIP process from the screening of incoming event records (EVs) to the final implementation of corrective actions and QA management was required to concur on all PIP procedure revisions.

The inspectors also reviewed samples of documented QA concurrence to verify that AD-3-1000-01-F-1, Procedure Approval Form, was appropriately reviewed by the QA department when procedures were revised.

Identification, Reporting and Documentation of Safety and Security Issues The inspectors conducted interviews to verify that UUSA employees and contractors working under the UUSA QA program were trained on how to identify and enter items into the PIP.

The inspectors reviewed the UUSAs security activities, procedures, and records to determine compliance with the PIP programmatic procedure CA-3-1000-01, Performance Improvement Program. Security issues were segregated into three general categories: physical security, information security, and nuclear material control and accountability. The inspectors reviewed security department logs, one log for physical security issues, and another log for information security issues. The logs contained information about the equipment problems, events, compensatory actions taken, and resolution of the problem.

The inspectors also reviewed documents and interviewed personnel to verify that UUSA had appropriate controls to ensure that conditions involving sensitive or classified information were managed within the PIP. This entailed generation of an event report with a high level description of the issue to ensure appropriate management of the issues evaluation, corrective action, tracking, and trending. The inspectors verified that specifics of the sensitive or classified information were cross-referenced in a protected manner outside the PIP system.

The inspectors interviewed site employees, contractors and subcontractors who worked in security and operations to determine whether those individuals were aware of the Employees Concerns Program (ECP) and comfortable with the avenues available to raise safety concerns. The discussions also addressed whether those individuals were aware of various locations on site that provided information on how to submit concerns anonymously, directly to ECP personnel and/or contact the NRC.

The inspectors observed the various drop locations to determine if current ECP information and instructions were available to the licensee employees, contractors, and sub-contractors site wide. The inspectors interviewed 14 employees across multiple disciplines to verify that employees felt free to raise safety concerns to supervisory staff and were aware of their PIP responsibilities through training they had received.

The inspectors interviewed the licensees ECP Manager and reviewed ECP procedures to determine whether the licensee had a process that established and maintained a positive safety culture commensurate with safety and security activities at the site. The inspectors interviewed the ECP manager to also verify that the individual was knowledgeable of the ECP process and the venues available for employees to raise safety and security related concerns.

8 Significance Assessment and Causal Evaluation of Safety and Security Issue The inspectors interviewed the Licensing and Performance Assessment Manager to understand PIP expectations and requirements. The PIP procedure provided a process for classifying the significance of issues associated with conditions adverse to quality, safety, and security; or significant conditions adverse to quality, safety, and security. The inspectors reviewed over 50 EVs to ensure that the licensee appropriately classified the significance of conditions that were entered into the CAP. This included a range of significance categories covering business risk (BR), adverse condition (AC), and significant condition (SC). The inspectors reviewed the causal evaluations performed for those items and activities to determine whether they were appropriate to the items significance and resulted in identification of the issues cause and extent of condition, as applicable.

Development and Implementation of Corrective Actions The inspectors attended one event review screening meeting and reviewed the meeting minutes from three event review board meetings to determine whether the licensee was effective in the following:

evaluating the actual and potential significance of conditions adverse to safety and security, classifying conditions as significant or non-significant, and applying a graded approach, based on the issues significance, to the timing and scope of response to the issues, including the depth and detail of causal evaluations identifying problems.

The inspectors reviewed a sample of root cause evaluations (RCEs), detailed apparent cause evaluations (DACEs), apparent cause evaluations (ACEs), BR investigations to determine whether the licensee used a graded approach commensurate with significance. The inspectors reviewed the corrective actions from the reports to verify the actions were closed out in a timely fashion.

The inspectors also reviewed EVs to verify that both operational and security activities were adequately screened and assigned an appropriate investigation level that was commensurate with the significance of the problem. The inspectors verified that the resulting corrective actions were suitable to resolve the issues.

Assessment of Corrective Action and Program Effectiveness The inspectors reviewed PIP procedures and interviewed the PIP staff and UUSA employees to determine whether the licensee developed, implemented, and maintained an assessment process to evaluate the PIP effectiveness in the identification, reporting, assessment, and correction of safety and security issues to prevent the recurrence of the same issues or occurrence of similar issues.

9 The inspectors also reviewed selective events reports in security and operations to determine whether the following were implemented in the PIP:

a process for reviewing conditions adverse to safety and security to determine the existence of adverse trends and repetitive problems, a process to evaluate the timeliness of PIP elements and the ability of the PIP to follow up and enable closure of corrective actions that are past their due date, a process that evaluates the PIP effectiveness at regular, specified intervals, a process that defines actions for the resolution of ineffective corrective actions, trends, and performance issues, and a process that includes measures to ensure that conditions and trends that are adverse to safety and/or security are reported to the appropriate level of management.

The inspectors also reviewed the QA department organization and procedures to determine if the licensees programmatic structure and auditing team were adequate to ensure the audit team was independent and remained free of influence from production management. The PIP programmatic activities were also audited to ensure compliance with procedures and license conditions. The inspectors reviewed samples of QA and PIP procedures and licensing documentation to verify that the organizational structure provided separation from all production related organizations and a high level of independence from production-related influences. In addition, the inspectors also reviewed documents to verify that the QA organization was periodically evaluated by an independent third party auditor to ensure compliance with corporate policies and license conditions.

The inspectors also interviewed staff in charge of generating trend reports for the PIP to determine whether the process identified trends and significant conditions adverse to quality, safety and security to the appropriate levels of management. The inspectors reviewed the PIP to determine whether timeliness expectations were identified for event reports. The inspectors reviewed first quarter trend reports for calendar year 2018, to determine whether the licensee was adequately identifying and assessing operational trends and reporting negative trends to the responsible organization and senior management, if applicable.

b.

Conclusion The inspectors determined that the licensee adequately implemented the UUSA CAP for operations in the areas of quality, safety and security in accordance with the licensing basis of the facility. The timeliness and threshold for initiating EVs was appropriate and consistent with plant procedures. The issues entered in the CAP were categorized commensurate with their safety/security significance. Generally, event evaluations were effective in identifying appropriate corrective actions and preventing recurrence.

10 The inspectors observed that the QA department was fully involved in revisions to CAP procedures and related policies. The inspectors confirmed that employees were knowledgeable regarding the use of the electronic corrective action system (ReAct), as well as other methods for entering safety or security concerns into the CAP via electronic or paper form submission. The inspectors determined that the organizational structure provided separation of the QA department from all production-related organizations and independence from production-related influences. No violations of more than minor significance were identified.

D.

Exit Meeting The inspection scope and results were presented to members of the licensees staff at various meetings throughout the inspection period and were summarized on April 19, May 24, and June 26, 2018, to Mr. Stephen Cowne, and other members of the staff.

Proprietary information was discussed but not included in the report.

Attachment SUPPLEMENTAL INFORMATION

1.

KEY POINTS OF CONTACT Name Title A. Anaya T. Anderson B. Bixenman J. Blackshear Senior Radiation Protection Technician Radiation Protection Technician III Licensing Specialist Decontamination & Recycling Manager S. Cowne Chief Nuclear Officer (CNO) and Compliance Manager J. Dahlin S. Diggs T. Foster Logistics Manager Security and Safeguards Manager Licensing S. King Radiation Protection Technician S. Magill D. Martinez R. Medina Maintenance Engineer Senior Licensing Specialist W. Padgett J. Rickman Licensing Manager Licensing Specialist M. Rhoads Quality Specialist III J. Rollins J. Sanford Licensing Safety & Emergency Response Manager B. Saucedo S. Scott D. Sexton Senior Chemistry Environmental Specialist Engineering & Projects Managing Director UUSA and President & CEO of LES, LLC R. Shaefer Operations Manager K. Slavinger N. Wells Chief of Staff QA Program Manager M. Ward Performance Assessment

2.

LIST OF REPORT ITEMS None

3.

INSPECTION PROCEDURES USED 88020 Plant Operations 88030 Radiation Protection (Appendix A) 88035 Radioactive Waste Processing, Handling, Storage, and Transportation 88045 Effluent Control and Environmental Protection 88161 Corrective Action Program Implementation at Fuel Cycle Facilities

4.

DOCUMENTS REVIEWED Records:

2017-A-04-007, Report for the URENCO USA Radiation Protection Program Audit, Rev. 0, dated May 10, 2017 Alpha Filters 033117 Records on iMatic Dose Evaluation Reports per Procedure RP-3-4000-03-F-1, Rev. 2 - April 21, 2017 and July 14, 2017 EN Filters 033017 and 041217

2 EN-3-2020-01-F-1, Urenco USA Perimeter Filter Collection EN-3-2020-01-F-2, Urenco USA Stack Filter Collection EN-3-2020-02-F-3, Basin Sediment Sampling EN-3-2020-02-F-6, Domestic Wastewater Sampling EN-3-3010-02-F-1, Cardinal Laboratories Semiannual Sampling Results HR-3-3000-02-F-1, SAR Personnel Qualification Verification Form, Rev. 1 Internal Audit of Radiation Protection Program - URENCO USA (UUSA) Site, dated April 24-28, 2017 Nuclear Safety Curriculum Review Committee (CRC) Minutes, dated May 11, 2017 Occupational Radiation Exposure Reports (1st - 4th Quarters of 2017)

QA-3-2000-03, Training, Qualification, and Certification of QA Personnel, Rev. 11, Section 5.8.2, dated August 22, 2016 RP-3-2000-04, Surveys of Sealed and Unsealed Sources and Source Leak Testing, Rev. 9 (September 20-21, 2017 and October 10, 2017)

RP-3-3000-04-F-2, Declaration of Pregnancy Dose Option Worksheet, Rev. 7, dated January 2, 2018 RP-3-4000-03-F-1, Dose Evaluation Report, Rev. 2, April 21, 2017 and July 14, 2017 Sealed and Unsealed Source Inventory TQ-3-0100-12-F-1, Training Equivalency Form, Rev. 2, dated April 18, 2017 UUSA Qualification Card Recycling Technician, Rev. 0 Procedures:

CA-3-1000-01, Performance Improvement Program, Rev. 39 CA-3-1000-01, Performance Improvement Program, Rev. 40 CA-3-1000-03, Root Cause Evaluation Guidelines, Rev. 8 CA-3-1000-06, Event Review Board, Rev. 18 CA-3-1000-09, Assessment Program, Rev. 12 CA-3-1000-12, Significant Event Response, Rev. 6 CA-4-1000-02, Event Report Analytical Techniques, Rev. 2 CA-4-1000-04, Performance Improvement Trend Code Manual, Rev. 5 EC-3-1000-01-F-1, Concern Disclosure Statement, Rev. 14 EG-3-2100-09, Identification, Disposition, and Resolution of Nonconforming Items, Rev. 7 EN-2-1010-02, Radiological Effluent Monitoring Program EN-2-1010-03, Environmental Regulatory Requirements, Rev. 2 EN-3020-01, MacGiver HF-2 Operations and Maintenance EN-3-1010-03, Air Quality, Rev. 3, dated August 31, 2017 EN-3-2020-01, EN Air Sampling, Rev. 2 EN-3-2020-02, EN Media Sampling, Rev. 4 EN-3-2030-01, Environmental Analysis of Uranium Quadrupole ICP-MS EN-3-2030-02, Metal Concentration in Aqueous Solutions EN-3-2030-03, Environmental Water Analysis EN-3-3010-01, Alpha Monitor EN-3-3010-02, Alpha Monitor (ABPM 201S) Calibration, Rev. 3 EN-3-3020-02, MacGiver HF-2 Calibration, Rev. 1 EN-3-3030-01, i-Matic Operation and Maintenance EN-3-3030-02, i-Matic Calibration LS-3-1000-05, Notifications and Event Reporting, Rev. 13, Attachment 1 Reportability Evaluation OP-3-1000-09, Operability Determination, Rev. 11 RM-3-2000-01, Records Management Program, Rev. 21

3 RP-2-1000-01, Radiation Protection Program, Rev. 9 RP-2-1000-02, ALARA Program, Rev. 6 RP-3-2000-01, Radiation Work Permits, Rev. 12 RP-3-2000-02, Radiological Postings and Access Controls, Rev. 12 RP-3-2000-04, Radiation and Contamination Surveys, Rev. 10 RP-3-2000-07, Personnel Contamination Events, Rev. 9 RP-3-2000-12, Radioactive Source Control, Rev. 6 RP-3-3000-11, Radiological Dose Reports, Rev. 7 RP-3-3000-19, Personnel Contamination Monitors, Rev. 7 RP-3-4000-03, Dose Evaluation Reports, Rev.3 RW-3-1000-01, Waste Management, Rev. 7 RW-3-1000-09, Radioactive Waste Container Setup, Handling and Disposition, Rev. 14 RW-3-1000-13, Shipping Radioactive and Mixed Waste, Rev. 3 RW-3-1000-17, Operation of the Hydraulic Drum Crusher/Compactor Model HDC-900-IDC, Rev. 0 RW-3-1000-19, Conduct of Recycling, Rev. 0 RW-3-1000-21, Storage Array for CSA Waste Containers, Rev. 0 RW-3-2000-01, LECTS Slab Tank Operations, Rev. 9 RW-3-2000-03, LECTS Bulk Storage Tank Operations, Rev. 4 RW-3-2000-04, LECTS Fill Station Operations, Rev. 2 RW-3-3000-12, Operation of the Segmented Gamma Scanner, Rev. 2 RW-3-4000-01, Startup, Shutdown, and Operation of the SCDT, Rev. 6 RW-3-4000-02, Startup, Shutdown, and Operation of the MFDT, Rev. 10 EN-1-1010-01, Environmental Policy, Rev 1 CAP Reports Written as a Result of the Inspection:

EVs 124701, 124702, 124706, 124714, 124715, and 124717 EVs 123099, 123246, 123265, 119269, 119297, 119985, 120009, and 122448 EV 124702, Fire door 1003-826-1DO471 was not closing properly.

EV 124714, Licensee could not provide Gaseous Effluent Ventilation System (GEVS) flow discrepancies.

EV 124956, Investigate possible negative trend in the Corrective Action Program EV 124962, Missing Pages in SAR within Controlled Set 456 EV 124973, NRC Observation regarding EV 108669 EV 124974, CA Procedure Non-Compliance EV 124984, Corrective Action Program Inspection - Minor Violation EV 124985, NRC Observation - CAPR Additional Risk EV 124986, CAP Inspection - BRs and ACs Determinations Inconsistent EV 124987, NRC identified issue with inadequate Event Report Investigations CAP Reports Reviewed:

EVs: 117204, 117296, and 120376 EV 102244, ER-2015-714 IROFS 30 Inconsistencies EV 102423, ER-2014-781 Identifying Criticality Safety Assumptions on Drawings EV 102738, ER-2014-1111, Suggested Improvements for IROFS 16A Pressure Check Documents EV 102830, ER-2014-1006 NCSI-14-0025 - Verification of CAAS Detector Location -

Post Construction EV 105194, ER-2014-1470 SAR Changes in CC-LS-2013-0004 EV 108117, Procedure Change Requirement for OP-3-0450-01-F-3/OP-3-0410-01-F-1 EV 108235, ER-2014-494 1S Sample Bottle Tare Weights Mismatch

4 EV 108669, ER-2015-78 M&TE Calibrated without a Valid Procedure EV 109247, Security EV 109468, ER-2015-266 Late Entry - Loggable ET-US Security Incident EV 109537, ER-2014-513 Adequacy of Not Credible Determination in Table C.3-1 for MFDT in 1S EV 109958, UBC Crane Seismic Components (BCI)

EV 110404, ACECO UBC Pad Crane Weld Inspection Report Discrepancies EV 110700, Possible Gap in Emergency Director Coverage Outside Normal Working Hours EV 110719, Unavailability of Emergency Director Onsite as Required per the Emergency Plan EV 110831, 2016-A-02-005 Maintenance Audit Finding #1 Ineffective Corrective Actions

- M&TE EV 111058, Business Critical Incident (BCI) Failure to Properly Implement IROFS 14b EV 112294, Student Not Completing Instructor-Led Nuclear Criticality Class Prior to CBT EV 112324, Documentation of IROFS Training EV 113428, EP Audit 2016-A-06-020 - Observation #2 - ERO Computer Resources EV 113447, Accident Sequence DS-1 Scope Should Be Reviewed013 EV 114101, NRC Fire Prot. Insp. - Evaluate Fire Pen. Seal Inspection Methodology EV 114619, 1003 Autoclave Saddle Boats EV 114952, Potential Negative Human Performance Trend in OPS EV 115037, Further Corrective Action to EV112427 Incident Report #16-18 EV 116554, NRC NCS/OPS Safety Inspection Notice of Violation 2016-005 EV 116677, Damage to 3LS1 EV 117551, Unapproved Computer Code Used for an Input into NCS-CSA-EV 117584, Potential Violation - Maintenance Management Measure EV 118995, Change of Assay in Agreement with Head Office without Explicit Notification of MC&A EV 118997, Negative Trend for HPEs Related to Procedure Use and Adherence EV 119003, Procedural Compliance Contained in the FNMC not met EV 119080, 48Y Lifting Lug EV 119122, Non-Compliance with RP-3-2000-04 EV 119488, Trend on M&TE Calibrations Performed by Vendors not on the ASLEV 120352, Cylinder Valve Cap Gasket Nonconformance EV 119708, Security Incident 17-28 EV 120009, BCI UUSA Procedure Violation of IROFS 54a/b EV 120204, Trends in Security EV 120386, 30B Heeled Cylinder connected incorrectly EV 121799, BCI UUSA IROFS Surveillance performed on a Heeled Cylinder EV 121985, Security Annual Report to NRC EV 121986, Information Security Inspection RCE Not Performed EV 122041, Receipt Inspection Plan Reports Generated on Incorrect Form Revision EV 122225, Non Conforming Material ANSI N14.1 Port Cap 1 Cylinder Valve Type 51 EV 122271, Potential Violation for EN52866 - Failure to Perform IROFS 54a/b EV 122272, Potential Violation for EN53406 - Failure to perform IROFS 16e/f EV 122356, Kobe Steel - VACGEN Products - UUSA Phase III Valves EV 122455, EV 119488 Requires Rescreening EV 122471, EV 109958 Requires Rescreening EV 122661, EV 110821 Requires Rescreening EV 122755, Evaluate Quality Requirements for QA Level - 2AC EV 122821, STS-1 Reliability

5 Other Documents:

2016-A-03-011, Report for the URENCO USA Performance Assessment and Feedback, dated April 14, 2016 2018-A-04-013, Report for the URENCO USA Performance Assessment and Feedback, dated May 23, 2018 Audit 2017-A-04-006 Dose Equivalent from the Uranium Byproduct Cylinder Storage Pad, 32-2400507-00, dated November 14, 2003 Environmental Compliance Audit, SA-2017-004, dated September 29, 2017 Event Review Board Meetings: Meeting 2018-1, Meeting 2018-2, and Meeting 2018-3 IN-13-00032, Discharge Permit, New Mexico Environmental Department, dated February 13, 2013 Integrated Safety Analysis Summary, Rev. 29 License Number - SNM-2010, Amendment 77 Memorandum; ERSC Membership Groups, dated May 1 2018 Memorandum; ERSC Membership Groups, dated May 21 2018 NEF-BD-55a, Limit LECTS Tank and Tote Uranium Enrichment Inventory, Rev. 2 NEF-BD-55b, Limit LECTS Tank and Tote Uranium Enrichment Inventory, Rev. 2 NELAP Accreditation of Cardinal Labs NIST certifications for sealed and unsealed sources NVLAP Certification for Mirion Technologies ORM 55a-b, Admin Limit LECTS Tank and Tote Uranium Enrichment Inventory, Rev. 1 Radiation Protection KPIs, March 2018 RCE Report: EV Number 120009, Event Date 7/31/17, report dated September 13, 2017 RCE Report: Failure to Properly Implement IROFS 14b EV111058, Event Date: 2016-Mar-2017 RP-RPTQC, Radiation Protection Technician Qualification Card, Rev. 0 RPTQIQC00, UUSA Radiation Protection Task Qualified Individual, Rev. 2 RWPs: 18-01, 18-03,18-011, 18-101 Safety Analysis Report, Rev. 42 UUSA Organization Chart, Rev. 30 Various training records for specific RP personnel