ML18295A071
| ML18295A071 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 10/22/2018 |
| From: | Eric Michel NRC/RGN-II/DFFI/FFB2 |
| To: | Beard B Global Nuclear Fuel - Americas |
| References | |
| IR 2018004 | |
| Download: ML18295A071 (14) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 October 22, 2018 Mr. Brad Beard FMO Facility Manager Global Nuclear Fuel-Americas, L.L.C.
P.O. Box 708, Mail Code J20 Wilmington, NC 28402
SUBJECT:
GLOBAL NUCLEAR FUEL - AMERICAS, L.L.C - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 70-1113/2018-004
Dear Mr. Beard:
This letter refers to the inspections conducted during the third quarter of calendar year 2018 (July 1 - September 30, 2018), at the Global Nuclear Fuel - Americas, L.L.C facility in Wilmington, NC. The purpose of the inspections was to determine whether activities authorized under the license and implementation of programs and procedures in the areas of Safety Operations and Facility Support were conducted safely and in accordance with Nuclear Regulatory Commission (NRC) requirements. The enclosed report presents the results of these inspections. At the conclusion of the inspections, the inspectors discussed the findings with you and members of your staff during exit meetings held on July 26, 2018 and August 16, 2018.
These inspections examined activities conducted under your license as they relate to public health and safety and compliance with the Commissions rules and regulations and with the conditions in your license. Within the areas mentioned above, the inspections consisted of an examination of selected procedures and representative records, observations of activities, facility walk-downs, and interviews with personnel.
Based on the results of these inspections, the NRC has determined that no violations of more than minor significance were identified.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice and Procedure," a copy of this letter, its enclosure, and your response, if you choose to provide one, 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.
B. Beard 2 If you have any questions, please contact Tom Vukovinsky of my staff at 404-997-4622.
Sincerely,
/RA/
Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 70-1113 License No. SNM-1097
Enclosure:
NRC Inspection Report 70-1113/2018-004 w/Supplemental Information cc:
Scott Murray, Manager Facility Licensing Global Nuclear Fuels - Americas, L.L.C.
Electronic Mail Distribution W. Lee Cox, III, Chief North Carolina Department of Health and Human Services Division of Health Service Regulation Radiation Protection Section Electronic Mail Distribution
ML18295A071 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI SIGNATURE via email via feeder via feeder via feeder via feeder NAME T. Vukovinsky C. Stancil C. Rivera M. Crespo L. Cooke DATE 10/11 /2018 10/18 /2018 10/19 /2018 10/ 19 /2018 10/19 /2018 10/ /2018 10/ /2018 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70-1113 License No.: SNM-1097 Report No.: 70-1113/2018-004 Licensee: Global Nuclear Fuel - Americas, LLC Location: Wilmington, North Carolina 28402 Dates: July 1, 2018 to September 30, 2018 Inspectors: M. Crespo, Senior Fuel Facility Inspector, (Section A.2)
L. Cooke, Fuel Facility Inspector in-Training, (Section A.2)
C. Rivera, Fuel Facility Inspector, (Section B.1)
C. Stancil, Senior Resident Inspector, (Section A.1)
Approved by: E. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure
EXECUTIVE
SUMMARY
Global Nuclear Fuel - Americas, LLC NRC Integrated Inspection Report 70-1113/2018-004 July 1 - September 30, 2018 Nuclear Regulatory Commission (NRC) regional inspectors conducted inspections during normal shifts in the areas of Safety Operations and Facility Support. During the inspection period, normal production activities were ongoing. These announced, routine inspections consisted of a selective examination of licensee activities accomplished by direct observation of safety-significant activities and equipment, walk-downs of the facility including items relied on for safety (IROFS), interviews and discussions with licensee personnel, and a review of facility records and procedures. There were no violations of more than minor significance identified during this inspection.
Safety Operations
- In the area of Operational Safety, no violations of more than minor significance were identified. (Section A.1)
- In the area of Fire Protection, no violations of more than minor significance were identified. (Section A.2)
Facility Support
- In the area of Emergency Preparedness, no violations of more than minor significance were identified. (Section B.1)
Attachment Key Points of Contact List of Items Opened, Closed, and Discussed Inspection Procedures Used Documents Reviewed
REPORT DETAILS Summary of Plant Status Global Nuclear Fuel - Americas (GNF-A), LLC manufactures uranium dioxide (UO2) powder, pellets, and light water reactor fuel bundles at its Wilmington, NC facility. The facility converts uranium hexafluoride (UF6) to UO2 using a Dry Conversion Process (DCP) and performs UO2, gadolinium pellet and fuel fabrication operations. During the inspection period, normal production activities at the facility were ongoing.
A. Safety Operations
- 1. Operational Safety (Inspection Procedure 88020)
- a. Inspection Scope The inspectors evaluated the operational safety of the facility to determine whether the licensee operated the plant safely and in accordance with Title 10 Code of the Federal Regulations (CFR) Part 70, SNM 1097 Global Nuclear Fuel - Americas, the License Application and licensee procedures. The inspectors interviewed the operations and engineering managers, Decon area operators and reviewed records associated with Decon and Scrap Pack facilities in the fuel manufacturing operations building. The inspectors specifically reviewed license requirements, quantitative risk assessments, criticality safety analyses, and operating procedures associated with the facilities. The inspectors reviewed select items relied on for safety (IROFS) associated with these facilities to verify these IROFS were being adequately implemented as described in the integrated safety analysis (ISA) and that the licensee was operating safely and in compliance with requirements. Specific documents and IROFS reviewed are listed in the attached supplemental information.
The inspectors reviewed OP 1080.20, Decon, Revision (Rev.) 6, and OP 2100.00, Scrap Pack, Rev. 2, to verify select IROFS as identified in the ISA Summary were implemented in accordance with written operating procedures. The inspectors toured the facilities to verify that the selected IROFS were present and capable of performing their intended safety functions in accordance with the ISA. Engineered and administrative safety controls were evaluated to verify they were functionally capable of mitigating or preventing associated accident scenarios. Decon operators were interviewed to verify they were knowledgeable of administrative controls and limits and the necessary actions to take for upset conditions.
The inspectors observed activities including trash collection, cart filling and monitoring, combustible and non-combustible trash sorting and monitoring, and Decon inner room cleanup and washdown to verify operators were operating in accordance with approved procedures.
The inspectors reviewed completed surveillances and functional test instructions for select IROFS to verify management measures as required by the ISA and License Application section 11.1, Management Measures, were implemented and corrective actions were taken for negative trends and failures. Furthermore, the inspectors
2 reviewed the licensees corrective action program (CAP) entries for the past 12 months to verify that deviations from procedures and unforeseen process changes affecting nuclear criticality, chemical, radiological, or fire safety were documented, investigated promptly and corrective actions implemented.
b. Conclusion
No violations of more than minor significance were identified.
- 2. Fire Protection Annual (Inspection Procedure 88055)
- a. Inspection Scope The inspectors evaluated the operational status and material condition of the licensees fire protection systems to determine whether the fire protection capabilities were in compliance with Chapter 7.0 of the License Application, Fire Safety and the ISA.
Specifically, the inspectors reviewed licensee procedures and toured the majority of the plant process areas. The inspectors also evaluated whether flammable materials were stored in marked cabinets and if housekeeping and the control of combustible materials, designated as various IROFS throughout the plant, were consistent with the licensees approved procedures and the ISA. The inspectors evaluated whether the cutting, welding, and hot work program was implemented in accordance with approved procedures as required by section 7.2 of the License Application, Fire Protection Program.
The inspectors reviewed portions of the Fire Hazard Analysis (FHA) for the Balance of Plant, Dry Conversion Process (DCP), and the Fuel Fabrication Operating areas to assess the technical basis for fire protection controls. The inspectors verified the pre-fire plans for first responders were available and current. The inspectors evaluated the compliance of fire doors, fire dampers, fire detection and alarm systems, hydrogen detection systems, and fire suppression equipment with sections 7.5, 7.7, and 7.8 of the License Application, titled Ventilation Systems, Fire Detection and Alarm Systems, and Fire Suppression Equipment, respectively. Also, the inspectors confirmed that fire hose connections and portable extinguishers were provided at their designated locations and access was unobstructed. The inspectors conducted walk-downs of site facilities and operating areas as well as reviewed associated records to determine if building construction features including fire walls, fire barriers, and fire wall penetration seals were being maintained in a condition that would ensure they were available and reliable to perform their safety function in accordance with section 7.4, Building Construction of the License Application and the ISA.
The inspectors reviewed records and performed walk-downs to determine compliance with the administrative control IROFS in accordance with procedure CP-27-108, Combustible Control Program, for various areas of the plant.
The inspectors observed the weekly test for the backup diesel fire pump and inspected the condition of the primary diesel fire pump to evaluate compliance with the fire protection requirements of the License Application section 7.9, Fire Protection Water System.
3 The inspectors reviewed samples of surveillance and test records, assessments and audits, to determine that fire protection equipment, systems, and activities were conducted in accordance with section 5.3.15 of the Radiological Contingency and Emergency Preparedness Plan, Rev. 26.
The inspectors reviewed the training provided to new employees to verify the basic fire protection training was provided as required per section 7.2, Fire Protection Program, of the License Application.
The inspectors reviewed samples of the licensees fire protection system impairment records (red tag system) to determine if compensatory measures had been put in place for out-of-service equipment and that the out-of-service was properly communicated to the appropriate stakeholders according to procedure.
The inspectors reviewed samples of the licensees CAP entries for the past 12 months, including the results of the triennial independent audit required by section 11.6.3, Independent Audits, of the License Application, to determine if the licensee was identifying fire related issues at an appropriate threshold and entering them into the CAP.
b. Conclusion
No violations of more than minor significance were identified.
B. Facility Support
- a. Inspection Scope The inspectors evaluated the emergency preparedness program to determine whether the program was in compliance with Chapter 8.0 of the License Application, Radiological Contingency and Emergency Plan, and the Emergency Plan, Rev. 26.
The inspectors interviewed staff and reviewed records to verify changes made to the Emergency Plan or within the facility had been reviewed by the Emergency Preparedness (EP) organization as required by the Emergency Plan. The inspectors reviewed a sample of the emergency plan implementing procedures that had significant revisions since the last EP inspection to verify the procedures remained in compliance with the license and the Emergency Plan, were readily available to members of the emergency management and response organizations, and were maintained current in the appropriate field locations. The inspectors reviewed the licensees emergency call list to verify the list was current.
The inspectors reviewed training records and interviewed members of the emergency response organization regarding EP training provided to emergency response personnel covering their roles and responsibilities as required by the Emergency Plan and emergency plant procedures. The inspectors reviewed the licensee provided training for hypothetical emergency situations to verify the training was effective and consistent with the frequency and performance objectives required in the license, emergency procedures and Emergency Plan.
4 The inspectors reviewed the written agreements with the off-site agencies to verify the organizations required by the Emergency Plan had up-to-date agreements. The inspectors interviewed representatives from the New Hanover Regional Medical Center and the New Hanover Sheriffs Office to verify they maintained an adequate understanding of the written agreements, and that the licensee invited those off-site organizations for training and drill participation as required by the Emergency Plan.
The inspectors observed the storage of emergency equipment and procedures in the Emergency Operations Center (EOC), the main staging area for the FMO/X building, and the New Hanover Regional Medical Center to verify the equipment was maintained as required by the Emergency Plan. The inspectors reviewed the accountability procedure and toured onsite staging areas and the EOC to verify accountability meeting points were accessible and contained operable and adequate communications and other gear as specified in the emergency plan. The inspectors observed the licensee conducting functional testing on one of their emergency vehicles, Engine 2, to verify the testing was conducted in accordance with emergency procedures. In addition, the inspectors observed the licensee conducting a quarterly radiation protection surveillance to verify it was conducted in accordance with licensee procedures and to verify the emergency equipment in the EOC was available as required by license requirements.
The inspectors reviewed licensee audit records, specifically audit NOS-2017-16, and interviewed licensee staff to verify the licensee conducted audits/self-assessments in the area of EP as required by the license and plant procedures. The inspectors reviewed audit records and corrective action documents to verify findings and recommendations were entered into the CAP and that a system was in place for tracking and resolving self-assessment findings.
The inspectors reviewed records to verify the licensees program ensured exercise objectives and scenario details were kept confidential from participants. The inspectors reviewed drill packages to verify the licensees emergency exercises had a credible, and technically correct scenario that tested key elements of the emergency plan, procedures, equipment, and the onsite and offsite response organizations. The inspectors also verified the exercises involved a critical assessment or critique of the response, and were conducted within the timeframe required by the emergency plan and procedures.
The inspectors reviewed corrective action documents to verify items identified during critiques/events were being captured and addressed in the CAP, and that the licensee had provisions to revise the emergency plan based on recommendations from drills and events.
The inspectors reviewed documentation of events that had occurred since the last EP inspection, which required the implementation of the Emergency Plan, to verify problems or deficiencies associated with the Emergency Plan or implementing procedures were entered into the CAP.
b. Conclusion
No violations of more than minor significance were identified.
5 C. 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 July 26 2018 and August 16, 2018, to B. Beard and staff. No dissenting comments were received from the licensee. Proprietary information was discussed but not included in the report.
SUPPLEMENTAL INFORMATION
- 1. KEY POINTS OF CONTACT Licensee personnel Name Title B. Beard FMO Facility Manager K. Campbell Manager, DCP & SS J. Chesson Configuration Manager Controller M. Connor Manager, Fabrication C. Davidson Fire Protection Programs Lead M. Dodds Senior NCS Engineer D. Doliber Fire Protection engineer D. Hart GEH EHS Manager J. Head Senior Vice President Regulatory Affairs (former)
B. Henderson Radiation Protection Manager S. Lee Fire Protection Engineer T. Mays Ventilation Engineer D. Miller Maintenance S. Murray Manager, Facility Licensing D. Nay FMO Manufacturing Engineering Manager P. Ollis Facility Licensing L. Paulson Senior Nuclear Safety Engineer J. Rohner Acting GNF EHS Manager M. Venters Manager, Emergency Preparedness and Fire Protection
- 2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Opened & Closed None Closed None Discussed None
- 3. INSPECTION PROCEDURES USED 88020 Operational Safety 88050 Emergency Preparedness 88055 Fire Protection Annual
- 4. DOCUMENTS REVIEWED Attachment
2 Records:
Agreement with the Sheriff Department dated January 14, 2016.
CALC-101-007, Likelihood Evaluation of Fire That Leads to UF6 Cylinder Rupture, Rev. 0 CP-27-108-F02, Quarterly Combustible Control Inspection Record CP-28-113-F04, Monthly RP Surveillance, dated January 31, February 21, March 15, April 30, June 1, and June 27, 2018 CP-28-113-F07, Quarterly RP Surveillance, dated March 28, 2018 CP-28-113-F07, Quarterly RP Surveillance, dated June 11, 2018 CP-28-113-F18, Weekly Engine 2 Surveillance, Rev. 0, dated June 21, 2018 Criticality Safety Analysis CSA - 701.00 - Decon, Rev. 1 Criticality Safety Analysis CSA - 1080.12 - Waste Box Storage, Rev. 5 Drawing CMW12085, Slab Tank for Waste Oil Collection, Rev. 0 EP-005, Licensing Advisor Position Fundamentals FHA 1320.00, Graded Fire Hazards Analysis Dry Conversion Process, Rev. 4 FHA BOP-01, Graded Fire Hazards Analysis Balance of Plant, Rev. 1 FHA 1001.00, Graded Fire Hazards Analysis Fuel Fabrication Operation, Rev. 1 FM Global Risk Report for visit on August 18, 2017 FTI-202-33, Conversion Hallway Alarm with Hydrogen Isolation, Rev. 0 Integrated Safety Analysis Summary, Rev. 20 New Hanover Regional Medical Center and New Hanover Regional Emergency Medical NOS-2017-16, 2017 GNF-A RC &EP Audit, dated November 2017 Nuclear Safety Release/Requirements NSR/R 13.11.04, Rev. 9 Plant Hazards Analysis PHA - 701, Rev. 4 PM-Z06935-06-AN-07, Calibration Scrap Pack Non-Accountability Scale, dated February 17, 2018 PM-Z15395-03-MO-07, Calibration Scrap Pack Accountability Scale, dated January 1, 2018 PM-Z30009-03-MO-07, Calibration Scrap Pack Accountability Scale Platform Outlet of Ash Can Transfer, dated January 1, 2018 PM-Z07882-03-MO-07, Calibration Scrap Pack Accountability Scale, dated July 16, 2018 PM-Z79319-06-AN-07, Calibration Scrap Pack Accountability Scale, dated January 1, 2018 Quantitative Risk Assessment 701 - Decon, Rev. 12 Radiological Contingency and Emergency Plan for Global Nuclear Fuel-Americas, LLC @
Services agreement dated December 5, 2015.
SPM 18-005 M180018, Updated Integrated Safety Analysis Summary for the GNF Facility, Rev. 21 Surveillance IROFS 701 - 02, Trash Collection Program, dated May 24, 2018 Surveillance IROFS 701 - 16, HVAC Filter Storage Area Geometry, dated July 30, 2018 Surveillance IROFS 701 - 23, Waste Oil Slab Tank Safe Geometry, dated March 26, 2018 Surveillance IROFS 701 - 20, Decon Filter Housing - Safe Geometry, dated November 30, 2017 Wilmington, NC, Re. 26, dated June 21, 2017 Procedures:
CP-18-104, EHS Regulatory Compliance Audits, Rev. 3.0, January 25, 2016 CP-27-108, Combustible Control Program, Rev. 5.1 CP-27-114, Integrated Safety Analysis, Rev. 8 CP-28-113, RC &EP Surveillance and Maintenance, Rev. 3, dated June 21, 2018 CP-28-113-F07, Quarterly RP Surveillance (Hospitals) June 2018, Rev. 1, dated September 23, 2015 Environmental-Chemical/Toxic Hazards, Rev. 31, dated July 21, 2017
3 EO-02-QC, EO Position Qualification Card, Rev. 1, June 13. 2014 Fire & Explosion, Rev. 25, dated August 27, 2014 Functional Test FTI 1080.20 F1, Fill Cart Monitor System FT, Rev. 2.1 Functional Test FTI OP-2100.00 F1, Transfer Hood Scrap Material Can Mass, Hood Mass and Can Count Controls, Rev. 6 Functional Test FTI OP-2100.00 F5, Rework Hood Scrap Material Can Mass, Hood Mass and Can Count Controls, Rev. 6 Functional Test FTI OP-2100.00 F6, Prevent Product Discharge through Discharge Valve XV-1100B, Rev. 0 Severe Weather, Rev. 34, dated August 23, 2016 WI-20-108-01, Emergency Organization Initial qualification and Requalification Training, Rev. 2.2, dated December 18, 2014 WI-20-108-01-F01, Emergency Organization Position Candidate Nomination, Rev. 2, dated April 1, 2014 WI-27-109-01, Hot Work Permits, Rev. 3.1 WI-27-110-02, Wilmington Site Fire Pump Inspection, Test, and Maintenance Program, Rev. 3.1 WI-27-110-08, Fire System Impairment, Rev. 0.0 Condition Reports Written as a Result of the Inspection:
CR 29178 CR 29185 CR 29427 CR 29447 Condition Reports:
CR 27038 CR 27154 CR 27379 CR 27556 CR 27566 CR 27567 CR 27598 CR 27605 CR 28007 CR 28141 CR 28711 CR 29179 CR 29181 CR 29182 CR 29186 Other:
IROFS 701-2, Trash Collection Program IROFS 701-4, Waste Cart Monitoring IROFS 701-5, Waste Box Monitoring IROFS 701-20, Decon Filter Housing IROFS 701-23, Waste Oil Storage Slab Tank - Safe Geometry IROFS 701-26, HVAC Filter Storage Area Controls IROFS 701-27, Decon Station Mass Control IROFS 705-5, FBS Control on Mass of U - Scrap Pack Hood
4 IROFS 705-7, FBS Control on Mass of U - Rework Hood IROFS 705-12, Poly Bottle Process Scale Interlock SNM 1097 Global Nuclear Fuel - Americas, License Renewal Application, dated March 30, 2007 and November 28, 2008