ML19024A094

Louisiana Energy Services, LLC (Les), Dba Urenco USA (Uusa) - Nuclear Regulatory Commission Integrated Inspection Report 0703103/2018005

ML19024A094
Person / Time
Site:	07003103
Issue date:	01/24/2019
From:	Omar Lopez-Santiago NRC/RGN-II
To:	Cowne S Louisiana Energy Services, URENCO USA
References
EN 53604 IR 2018005
Download: ML19024A094 (18)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 January 24, 2019 EN 53604 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 70-3103/2018-005

Dear Mr. Cowne:

This letter refers to the inspections conducted by the U.S. Nuclear Regulatory Commission (NRC) from October 1 through December 31, 2018, at the URENCO USA facility located in Eunice, New Mexico. The enclosed report presents the results of these inspections, which were discussed with you and members of your staff on December 13, 2018.

These inspections examined activities conducted under your license, as they related to public health and safety, to confirm compliance with U.S. NRC rules and regulations and the conditions of your license. The inspection areas covered operational safety, criticality safety, and plant modifications. Within these areas, the inspections consisted of examinations of selected procedures and representative records, observations of activities, and interviews with personnel. No violations of more than minor significance were identified.

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 of the NRCs 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 website at http://www.nrc.gov/reading-rm/adams.html.

S. Cowne 2 If you have any questions regarding this matter, please contact me at (404) 997-4703.

Sincerely,

/RA/

Omar R. López-Santiago, Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 70-3103 License No. SNM-2010

Enclosure:

Inspection Report No. 70-3103/2018-005 w/

Attachment:

Supplemental Information 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 Rebecca Long Lea County Board of County Commissioners Lea County Courthouse 100 North Main Avenue, Suite 4 Lovington, NM 88260 (cc: Contd on page 3)

S. Cowne 3 (cc: contd)

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 Karen Fili, Managing Director UUSA, President and Chief Executive Officer Louisiana Energy Services, LLC URENCO USA P.O. Box 1789 Eunice, NM 88231 Karen.Fili@Urenco.com 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 4

SUBJECT:

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

NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 70-3103/2018-005 DISTRIBUTION:

L. Suggs, RII O. López-Santiago, RII J. Rivera Ortiz, RII K. Sturzebecher, NMSS PUBLIC PUBLICLY AVAILABLE NON-PUBLICLY AVAILABLE SENSITIVE NON-SENSITIVE ADAMS: Yes ACCESSION NUMBER:ML19024A094 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/ /RA/ /RA/ /RA/

NAME TVukovinsky BAdkins MRuffin JRivera-Ortiz LCooke LPitts DATE 1/22/2019 1/18/2019 1/22/2019 1/18/2019 1/18/2019 1/22/2019 E-MAIL COPY YES NO YES NO YES NO YES NO YES NO YES NO YES NO YES NO G:\DFFI\REPORTS\Final Reports\LES\2018\LES IR 2018005.docx

U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70-3103 License: SNM-2010 Report No.: 70-3103/2018-005 Licensee: Louisiana Energy Services (LES), LLC Facility: URENCO USA (UUSA)

Location: Eunice, NM Inspection Dates: October 1 through December 31, 2018 Inspectors: B. Adkins, Senior Fuel Facility Inspector (Section, A.2, C.1, and C.2)

M. Ruffin, Fuel Facility Inspector (Section B.1)

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

Accompanying E. Stamm, Senior Project Inspector Personnel:

Approved: Omar R. López-Santiago, 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 70-3103/2018-005 October 1 - December 31, 2018 Regional inspectors from the U.S. Nuclear Regulatory Commission (NRC) conducted announced inspections during normal shifts and in-office reviews. The inspectors observed safety-significant activities and equipment, walked down the facility, interviewed licensee personnel, and reviewed facility documents. There were no violations of more than minor significance identified during this inspection.

Safety Operations

• The inspectors reviewed a sample of activities in the operational safety area; no violations of more than minor significance were identified. (Section A.1)

• The inspectors reviewed a sample of activities in the nuclear criticality safety area; no violations of more than minor significance were identified. (Section A.2)

Facility Support

• The inspectors reviewed a sample of activities in the plant modifications area (annual review); no violations of more than minor significance were identified. (Section B.1)

Other Areas

• The inspectors performed follow-up inspection activities for unresolved item (URI) 2018-002, Review of Safety Basis for MFDT Modifications, and no violations of more than minor significance were identified. This item is considered closed. (Section C.1)

• The inspectors performed follow-up inspection activities for Event Notification53604, Preplanned Outage of a Required Safety Monitoring System, and no violations of more than minor significance were identified. This item is considered closed. (Section C.2)

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

REPORT DETAILS Summary of Plant Status The URENCO USA facility in Eunice, New Mexico, enriches uranium hexafluoride (UF6) using 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 The inspectors reviewed site requirements contained in the Safety Analysis Report (SAR) and LES License Application, Chapter 11. The inspectors interviewed staff and reviewed records associated with the UF6 feed system, including refeed of depleted tails up to natural enrichment. Specifically, the following accident sequences and their associated items relied on for safety (IROFS) were reviewed: EC3-1, EC7-1, UF1-1, UF2-3, and OC3-1.

The inspectors reviewed records, interviewed operators and technicians, and observed IROFS surveillance activities to verify that IROFS required for UF6 feed system operation were available and reliable as credited in the integrated safety analysis (ISA) of the facility.

The inspectors conducted a walk down of the UF6 feed systems with approved system diagrams to verify that the actual equipment status and lineup were in accordance with the approved configuration. The inspectors attended a pre-job brief with two operators and observed them conducting activities to administratively verify uranium assay measurement of feed cylinders as specified by IROFS 53a and IROFS 53b in accordance with procedure OP-3-0410-01, Feed System, Revision (Rev.) 50. The inspectors observed two operators administratively verifying assay subcriticality by mass balance calculations to verify the status of IROFS C22 in accordance with procedure OP-3-3300-01-F-5, Mass Balance Verification (IROFSC22) Data Sheet, Rev. 34.

The inspectors reviewed the postings applicable to the tasks being observed to determine if these postings were current, reflected safety controls, and were followed by the operators. The inspectors reviewed training and qualification records for seven operators to verify that their IROFS training for the UF6 feed systems was current and that they were knowledgeable of the systems requirements.

The inspectors observed operators and reviewed records to verify UF6 feed lineups were completed and documented in accordance with procedure OP-3-0410-01 and IROFS 53a/b prior to initiating feed.

The inspectors reviewed records and interviewed a system engineer to verify that IROFS 4 and IROFS 5 for the UF6 feed systems were installed with approved system diagrams to verify that the actual equipment status and lineup were in accordance with

2 the approved configuration. The inspectors interviewed operators and reviewed surveillance documents to verify that management measures were properly implemented for IROFS 4 and IROFS 5 in accordance with the SAR, Section 11.2.

The inspectors reviewed the most recent operations self-assessment, report 2017-A 009, Industrial Health and Chemical Safety Audit, and 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 and appropriately resolved. In addition, the inspectors reviewed the corrective actions associated with operational safety entries to assess their completion status.

b. Conclusion

No violations of more than minor significance were identified.

2. Nuclear Criticality Safety (Inspection Procedure 88015)

a. Inspection Scope Criticality Analysis The inspectors reviewed selected nuclear criticality safety evaluations (NCSEs) to determine whether properly reviewed and approved NCSEs were in place prior to conducting new or changed operations and that the NCSEs were of sufficient detail and clarity to permit independent review. The inspectors reviewed the selected NCSEs to determine whether calculations were performed within their validated area(s) of applicability and consistent with the validation report. The inspectors reviewed the selected NCSEs and associated assumptions and calculations to verify that they were consistent with the commitments in the License Application. These commitments included the licensees commitment to the Double Contingency Principle, the assurance of subcriticality under normal and credible abnormal conditions with the use of subcritical margin, and the specified technical practices and methodologies. The NCSEs were selected based on factors such as their risk-significance, whether they were new and/or revised, their complexity, their unusually heavy reliance on administrative controls, their use of new technology or unusual control methods, and their operating history. The NCSEs reviewed included NCS-CSA-006, NCS-CSE-019, NCS-CSA-036, and NCS-CSA-026, and those listed in Section 4 of the Attachment to this report.

The inspectors reviewed the licensees generation of accident sequences to determine whether the NCSEs systematically identified normal and credible abnormal conditions in accordance with the commitments and methodologies in the License Application for the analysis of process upsets. The inspectors verified that no changes were made to the validation report since the last nuclear criticality safety (NCS) inspection.

Criticality Implementation The inspectors performed walk-downs of the UF6 Feed System, which included refeed of depleted tails cylinder up to natural enrichment and feed sampling, to determine whether existing plant configuration and operations were covered by, and consistent with, the process description and safety basis in the selected NCSEs listed above. The

3 inspectors reviewed process and system descriptions, specifications, drawings, and procedures to verify that engineered controls established in the NCSEs were included and being implemented as specified. The inspectors reviewed operating procedures and postings to verify that selected administrative controls established in the NCSEs were included in the procedures and postings. The administrative controls reviewed included IROFS C22 and IROFS 53a/b. The inspectors interviewed operators and engineers to verify that administrative actions established in the NCSEs were understood and implemented as specified.

The inspectors reviewed the ISA summary and supporting ISA documentation to determine whether the controls identified in the ISA were supported by the technical bases in the NCSEs.

Criticality Operational Oversight The inspectors reviewed NCS-related training material, records, and procedures to determine whether operator training included instruction in criticality hazards and control methods, whether the licensees established NCS-related operator training was consistent with commitments in Section 5.1.1 and 11.3 of the SAR, including compliance with American Nuclear Society Standard 8.20, and whether NCS staff were involved in the development of operator training. Additionally, the inspectors interviewed operations staff to determine whether they were cognizant of NCS hazards and control methods related to their specific job function. The NCS-related training records reviewed included training materials/lesson plans, completed exams, and records showing completion of required criticality training courses.

The inspectors reviewed records of NCS audits and accompanied a licensee NCS engineer on a walk-down of Separations Building Module (SBM) 1003 to determine whether NCS staff routinely assessed field compliance with established NCS controls.

Additionally, the inspectors interviewed NCS management and reviewed procedures and schedules to verify that the NCS function performed these assessments as required by Section 5.1.5 of the SAR and implementing procedure CR-3-1000-03. The records of NCS audits reviewed included NCSI-18-0002, 0016, 0025, 0027, 0028, 0030, and 0037.

Criticality Programmatic Oversight The inspectors reviewed new and/or revised NCS program procedures to determine whether the licensee incorporated license requirements into the procedures and whether the NCS program was implemented in accordance with the procedures. The new and/or revised NCS program procedures included CR-3-1000-01, CR-3-1000-02, CR-3-1000-03, and CR-3-1000-04. The inspectors conducted interviews and reviewed records to determine whether NCS staff reviewed new and/or revised fissile material operations and procedures, including maintenance plans, consistent with program procedures and at a level commensurate with their significance.

The inspectors reviewed the selected NCSEs listed above to verify that they were performed in accordance with NCS program procedures and received appropriate independent review and approval.

4 The inspectors reviewed audit report 2018-A-03-007 and interviewed NCS staff to verify that the audit of the NCS program was conducted at a frequency consistent with license requirements and with appropriate thoroughness. The inspectors conducted interviews and reviewed CAP entries to verify that audit observations and findings were communicated to licensee management and entered in the CAP for resolution.

The inspectors reviewed NCS staff qualification records and conducted interviews to verify that NCS engineers and senior NCS engineers had the necessary education and experience and were qualified in accordance with license requirements. Additionally, the inspectors reviewed records to verify that NCS staff members only performed those functions for which they were qualified.

Criticality Incident Response and Corrective Action The inspectors reviewed records, including analyses and testing records, to determine whether alarm signals were audible within the areas required to be evacuated. The inspectors reviewed records to determine whether criticality accident alarm system (CAAS) detector operability was maintained, whether detectors were calibrated, whether all components were functionally tested, whether alarm setpoints were set to promptly actuate upon detecting the minimum accident of concern, and whether access to alarm setpoints was strictly controlled. The records reviewed included Work Orders (WOs) 100300428, 100316341, 100350199, 100352999, and 100355174.

The inspectors reviewed selected NCS-related CAP entries to determine whether anomalous conditions were promptly identified and entered into the CAP and whether they received the appropriate level of investigation consistent with license commitments and procedures. The inspectors reviewed the associated corrective actions to verify that they were sufficiently broad, prioritized on a schedule commensurate with their significance, completed as scheduled, and appropriate to correct the identified condition.

Additionally, the inspectors reviewed NCS-related CAP entries to assess whether the licensee followed regulatory requirements and procedures with regards to reporting plant conditions to the NRC. The CAP entries reviewed included EV128441, 126613, 126823, 124694, 124886, 126378, 126526, and 124765.

b. Conclusion

No violations of more than minor significance were identified.

B. Facility Support

1. Plant Modifications (Inspection Procedure 88070)

a. Inspection Scope The inspectors reviewed the licensees configuration management program to determine whether the licensee established an effective program capable of evaluating, implementing, and tracking modifications to facility processes in accordance with Title 10 Code of Federal Regulations (10 CFR) 70.72 and License Application Chapter 11.1, Configuration Management. The inspectors reviewed configuration management procedures and interviewed licensee managers to verify that the configuration

5 management program was implemented in accordance with the aforementioned requirements and the governing configuration management procedures: EG-3-2100-01, Configuration Change and EG-3-4100-02, Plant Modifications.

The inspectors reviewed the licensees configuration management program to verify that it addressed pre-job planning and preparation of plant modification design packages.

The inspectors also verified the program had adequate provisions in place to prevent plant modifications from degrading performance capabilities of IROFS or other safety controls that were part of the safety design basis.

The inspectors reviewed the following plant modification design packages implemented since the last plant modification inspection was conducted: 70.72-2016-0250, 70.72-2017-0018, 70.72-2017-0067, 70.72-2017-0096, 70.72-2017-0097, 70.72-2017-0076, 70.72-2017-0086, 70.72-2017-0191, and 70.72-2017-0206. The inspectors reviewed these packages and interviewed licensee staff to verify the change packages were prepared, reviewed, and completed by the licensee in accordance with procedure EG 2100-01. Specifically, the review was to ensure the design packages contained the following: the technical basis for the change, the impact of the change on safety and health or on the control of licensed material, the necessary training prior to operations, the authorization requirements for the change, and the impacts of the change to the ISA or other safety program information developed in accordance with 10 CFR 70.62. The inspectors reviewed change packages MOD-17-0152 and MOD-17-0181 to verify the licensee identified applicable post-maintenance installation and testing requirements and performed them prior to implementing the plant modifications. The inspectors also evaluated the packages to verify completed modifications were adequately reviewed prior to implementation and reviewed training records to verify the responsible evaluators of the packages were qualified.

The inspectors reviewed a sample of 10 CFR 70.72 evaluations to determine whether the licensee adequately evaluated the need for NRC pre-approval of selected facility modifications in accordance with procedure LS-3-1000-04, 10 CFR 70.72 (c)

Evaluations for Proposed Changes. The inspectors also reviewed the training records of licensee personnel conducting the 10 CFR 70.72 evaluations to verify they were qualified to perform the evaluations in accordance with procedure TQ-3-0100-13 , 10 CFR 70.72(c) Training and Qualification Program.

The inspectors performed walk-downs of MOD-17-0034, MOD-17-0181, and MOD 0152 to ensure the modifications were installed in accordance with approved design documents, including drawings and technical reports. The inspectors also reviewed the SAR, ISA, and other related on-site documentation to verify it was updated with the modifications promptly as required by 10 CFR 70.72(e).

The inspectors reviewed training records to verify operators received necessary training on the new modifications prior to resuming operations. The inspectors also reviewed the licensees document retention policy to verify records of facility modifications were maintained in accordance with 10 CFR 70.72(f).

The inspectors reviewed the licensees CAP to verify issues related to the preparation and installation of plant modifications were entered into the CAP and properly addressed by the licensee with appropriate corrective actions in accordance with License Application Chapter 11.6, Incident Investigations and Corrective Action Process.

6

b. Conclusion

No violations of more than minor significance were identified.

C. Other Areas

1. Unresolved Item 2018-002, Review of Safety Basis for MFDT Modifications

a. Inspection Scope During a routine NCS inspection in March 2018, the inspectors identified an Unresolved Item (URI) associated with a design change that installed holes in the front panel of the Multi-Function Decontamination Train (MFDT) drip tray. Specifically, the holes were credited as a safe-by-design (SBD) feature for the prevention of criticality in the event of a line break accident above the drip tray. At the time of the inspection, the licensee could not provide a documented technical basis for the design change, including the bases for the hole diameter, number of holes, and hole locations, as required by 10 CFR 70.72(a)(1). Subsequently, the licensee conducted an analysis (CALC-M-00077) to determine if the holes would be capable of performing their intended safety function to limit the liquid slab height inside the drip tray to a specified safety limit during a line break accident. The inspectors reviewed the calculation and agreed with the methodology selected for the analysis (circular weir), as well as the associated design inputs and calculated results.

The inspectors determined that the lack of technical basis for the MFDT drip tray modification was a violation of NRC requirements, specifically 10 CFR 70.72(a)(1), for the failure to assure that the technical basis for the change was addressed prior to implementing the change. This violation was determined to be of minor significance based on the screening criteria (Screening Question #8) in Appendix B of Inspector Manual Chapter (IMC) 0616 because the noncompliance did not adversely affect the ability of an IROFS or safety related component to perform its intended safety function.

The licensee entered this condition into their corrective action program as EV123529, No Formal Calculation to Support Number & Size of Holes in MFDT Drip Tray. The licensee took corrective actions to restore compliance. This minor violation of 10 CFR 70.72(a)(1) is not subject to enforcement action in accordance with Section 2.3.1 of the NRC Enforcement Policy.

b. Conclusion

No violations of more than minor significance were identified. This item is considered closed.

2. Event Follow-up EN 53604 Preplanned Outage of a Required Safety Monitoring System

a. Inspection Scope On September 14, 2018, the licensee reported that the CAAS would be temporarily disabled during planned corrective maintenance for approximately 30 minutes on Saturday, September 15, 2018. This activity would affect the CAAS in the

7 SBM 1001/1002 and the Cylinder Receipt and Dispatch Building (CRDB). The CAAS in the remaining portions of the facility was unaffected. The planned outage was reported in accordance with 10 CFR 70(b)(2) for an event in which equipment is disabled or fails to function as designed when the equipment is required by regulation (10 CFR 70.24) or license condition to prevent exposures to radiation or to mitigate the consequences of an accident.

As a follow-up to this issue, the inspectors reviewed LES-18-116-NRC, 10 CFR 70.50(c)(2) 30 Day Report, and conducted interviews with licensee personnel to determine if the actions taken by the licensee were consistent with NRC regulations and licensing basis requirements, including the requirements to report the issue to the NRC.

Based on their review of the event, the inspectors concluded that the licensee took adequate compensatory measures to limit impact of the disabled safety system as described in Section 3.1.5 of the ISA Summary. The specific compensatory actions taken by the licensee included (1) limiting access to only essential personnel inside the Controlled Access Area (CAA) during the maintenance activities; (2) use of temporary criticality detection equipment for personnel in the CAA; (3) evacuation of non-essential personnel from the areas of concern and the Immediate Evacuation Zone (IEZ) before removing the equipment from service; (4) limiting access into the facility; and (5) restricting Special Nuclear Material (SNM) movement until CAAS coverage was verified operational. The CAAS was returned to service at approximately 0930 Mountain Daylight Time (MDT) on September 15, 2018, following the completion of the scheduled maintenance. During the maintenance period, the licensee did not observe any abnormal radiation readings. The inspectors concluded that the licensee took adequate and conservative compensatory measures to mitigate the safety impact of the CAAS outage and no violations of NRC requirements were identified.

b. Conclusion

No violations of more than minor significance were identified. This item is considered closed.

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 December 13, 2018 to R. Shaffer, Operations Manager. Proprietary information was discussed the inspection but not included in this report.

SUPPLEMENTAL INFORMATION

1. KEY POINTS OF CONTACT Name Title B. Bixenman Licensing Specialist S. Cowne Chief Nuclear Officer (CNO)

R. Kohrt Consulting Engineer R. Medina Senior Licensing Specialist K. Miller Systems Engineering Supervisor Q. Newell Programs Engineering Supervisor W. Padgett Manager, Licensing and Performance Assessment A. Reidy NCS Engineer R. Schumaker Maintenance Supervisor R. Shaffer Operations Manager N. Wells Quality Assurance & ECP Manager

2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Closed URI 2018-002 Review of Safety Basis for MFDT Modifications (Section C.1)

EN 53604 Preplanned Outage of a Required Safety Monitoring System (Section C.2)

3. INSPECTION PROCEDURES USED IP 88020 Operational Safety IP 88015 Nuclear Criticality Safety IP 88070 Plant Modifications

4. DOCUMENTS REVIEWED Records:

2018-A-03-007, Report for the Urenco USA (UUSA) Nuclear Criticality Safety NQA-1 Audit, dated April 12, 2018 32-2400503-02-LES, Attachment C, ISA Consequence Assessments for Airborne releases Attachment C: Material at Risk/UF6 Release Source Terms, Rev. 04, dated October 25, 2016 32-2400503-06-LES, Attachment J, ISA Consequence Assessments for Airborne releases Attachment J: Miscellaneous Accident Scenarios, Rev. 03, dated October 25, 2016 70.72-2016-0250 70.72-2017-0018, Rev. 0, dated February 23, 2017 70.72-2017-0067 70.72-2017-0076, Rev. 0, dated August 9-10, 2017 70.72-2017-0086 70.72-2017-0096 70.72-2017-0097, Rev. 0, dated July 26, 2017 70.72-2017-0191, Rev. 0, dated October 4, 2017 Attachment

2 70.72-2017-0206, Rev. 0, dated December 21, 2017 ARC-971, Attachment 6: FEA Results - Inclined Vessel, Rev. 1 CALC-LES-K-0013, IROFS4 Station Heaters High Temperature Trip - RTD CALC-LES-K-0014, IROFS5 Station Heaters High Temperature Trip - TC CC-EG-2016-0055, Overfilled UF6 Cylinders, Rev. 0 CC-OP-2016-0001, Refeeding in Non-reconfigurable Cascades, Rev. 0 CGDP-010-0047, Commercial Grade Dedication Plan for Pressure Vessel, Stillage, Skid &

Pipe Train Assembly, dated September 24, 2013 EG-3-4100-02, Plant Modifications, Rev. 18 ESR #2018-016 ISA-MEM-0063, IROFS38 Elimination ISA Team Meeting Minutes, Rev. 0, dated December 16, 2016 LBDCR 17-0012, dated June 30, 2017 LBDCR 17-0019, dated July 20, 2017 MA-3-3862-01, Calibration of the WHWA Type 2 Inventory Weight Scale System, Rev. 4, dated May 12, 2017 Maintenance Work Order Number 1000305118, SBMs Overpressure Protection MOD 0181, dated July 26, 2017 Maintenance Work Order Number 1000307061, SBM Repl Carbon in Type A MOD-17-0152, dated August 11, 2017 MOD-17-0034, Autoclave Saddle Locks IROFS28 Materials Parts List, dated September 20, 2016 MOD-17-0152, Replace Carbon in Type A Traps on Feed Sampling Rigs MOD-17-0181, Overpressure Protection for Rotary Vane Pump on Feed Sampling Rigs MOD-17-0195, CMS RPU Replacement MOD-17-0195A, CMS RPU Replacement MWO 1000213489 NCS-CSA-006, Criticality Safety Analysis of the Product Vent Pump & Chemical Trap Set, Rev. 9 NCS-CSA-026, Nuclear Criticality Safety Analysis of Assay Units 1001 and 1002 Cascade Valve Frames (CIC), Rev. 3 NCS-CSA-036, NCSA of an Assay Dump to a Single Tails Cylinder, Rev. 0 NCS-CSE-019, NCSE of the Mobile Feed Sampling Rig, Rev. 3 NCSI-18-0002, LECTS Room, dated January 8, 2018 NCSI-18-0016, CRDB 30B Cylinder Storage Areas, dated April 20, 2018 NCSI-18-0025, LECTS Room, dated June 22, 2018 NCSI-18-0027, SBM 1005 and the CTP CAAS, dated July 3, 2018 NCSI-18-0028, SWCR, dated July 13, 2018 NCSI-18-0030, SBM-1003 CAAS, dated July 27, 2018 NCSI-18-0037, UF6 Area SBM 1005, dated September 14, 2018 NEF-BD-10, Design Features to Maintain Product Liquid Sampling Autoclave Leak Tight Integrity, Rev. 6 NEF-BD-28, Design Feature to Maintain Product Liquid Sampling Leak Tight Integrity, Rev. 5 NEF-BD-53A, Administratively Ensure Uranium Assay Measurement of Feed Cylinder, Rev. 3 NEF-BD-53B, Administratively Ensure Uranium Assay Measurement of Feed Cylinder, Rev. 3 NEF-BD-C22, Verify Subcriticality by Mass Balance Calculation, Rev. 9 NSR-2015-035, Mobile Feed Sampling rigs (System 492), Rev. 0 OP-3-3300-01, Operations Surveillance Procedure, Rev. 30, dated May 26, 2017

3 Pin Gauge set, PG-4 SA-2018-001, UUSA Nuclear Criticality Safety (NCS) Programmatic Assessment, June 26, 2018 WO, 1000172010, Install C21 Orifice on 1D1 WO 1000213337, Install C21 Orifice on Pressure Transducer Cal Rig WO 1000300428, 1Y: Tuning of CAAS Amp Monitor, dated November 15, 2017 WO 1000316341, SBM2: CAAS Power Panel Lights WO 1000327191, Verifying IROFSC21 Orifice Size WO 1000330499, IROFS 4/5, dated May 1, 2018 WO 1000330547, IROFS 4/5, dated April 30, 2018 WO 1000330665, IROFS 4/5, dated May 2, 2018 WO 1000350199, SBM1: Repair Failed Speakers for CAAS, dated August 22, 2018 WO 1000352999, Spurious 1001 CAAS Alarms, dated August 7, 2018 WO 1000355174, TSB: Replace Fault Det Card CAAS, dated September 15, 2018 Procedures:

AD-3-1000-01, Rev. 29, dated December 3, 2018 AD-3-1000-10, Change Management Process CR-3-1000-01, Verification for Implementation of NCS Evaluations and Analyses, Rev. 7 CR-3-1000-02, Nuclear Criticality Safety Limit Postings, Rev. 7 CR-3-1000-03, NCS Weekly Walkthroughs and Periodic Assessments, Revs. 12 and 13 CR-3-1000-04, Response to Nuclear Criticality Safety Anomalous Condition or Criticality Accident, Revs. 3 and 4 EG-3-2100-01, Configuration Change, Rev. 26, dated July 9, 2018 EG-3-4100-02, Plant Modifications, Rev. 18, dated April 18, 2018 E-NCS-QG, NCS Criticality Engineer, Rev. 03 LS-3-1000-04, 10 CFR 70.72 (c) Evaluations for Proposed Changes, Rev. 17, dated May 22, 2017 LS-3-1000-06, Maintenance of License Basis Documents, Rev. 20, dated July 11, 2018 LS-3-1000-08, Control of License Amendment Request (LAR) and Implementation of License Amendments, Rev. 10, dated October 26, 2017 MA-2-1000-02, Preventative Maintenance Program, Rev. 1 MA-2-1000-03, Surveillance Program, Rev. 8 MA-3-0400-03, Installation and Verification of Flow Restriction Orifice (IROFSC21), Rev. 1 MA-3-3400-05, IROFS5 Station Heaters High Temperature Trip - TC Surveillance, Rev. 10 MA-4-3400-04, IROFS4 Station Heaters High Temperature Trip - RTD Surveillance, Rev. 11 OP-3-0400-05-F-1, IROFS 53a/b Cascade Setting Data Verification, December 9 -11, 2018 OP-3-0410-01, Feed System, Rev. 50 OP-3-0420-01, Product System, Rev. 46 OP-3-1000-08, Operating Requirements Manual Change Request, Rev. 6 OP-3-1000-18, IROFS50d & 50e UF6 Handling Area Internal Barrier and Spotter Control, Rev. 5 TS-3-0100-13, Training and Qualification Guidelines, Rev. 08, dated October 16, 2017 Condition Reports Written as a Result of the Inspection:

EV 128441, EV 128515, EV 128518

4 Condition Reports Reviewed:

EV 116677, EV 122422, EV 122446, EV 122865, EV 123338, EV 123357, EV 123529, EV 124694, EV 124744, EV 124765, EV 124886, EV 124994, EV 125088, EV 126378, EV 126389, EV 126523, EV 126526, EV 126613, EV 126694, EV 126807, EV 126826, EV 126975, EV 127025, EV 127316, EV 128417, and EV 128441 Other Documents:

10 CFR 70.72 Training Records CALC-M-00077, Determine the Volume of the MFDT Pump Skid and the Total Flow Rate from the Forty-Three 1 inch Orifices Implemented through MOD-17-0175A, Rev. 0 CALC-S-00144, IROFS 53a and IROFS 53b Acceptance Criteria, Rev. 2 Drawing LES-1001-E-WIR-010-04-2, Electrical Separation Building Module Schematic Diagram IROFS 4/5 EG-3-3200-03-F-1, SBD Attribute Verification Form MFDT Drip Trays (Pump Side), dated December 8, 2017 EOR-NCS-EXAM-01V1, Nuclear Criticality Safety Exams 2013-001 and 002 FCH-772-01: 10 CFR 70.72 Process, Rev. 10, July 27, 2017 Integrated Safety Analysis, Rev. 28a MOD-17-0175B, Multi Function Decon Train/Catch Basin Modification, dated May 15, 2018 NEF-BD-4, Auto Trip of Station Heater on High Temperature (RTD), Rev. 2 NEF-BD-5, Auto Trip of Station Heater on High Temperature (T/C), Rev. 2 NEF-BD-50e, Administratively Control Movement of Internal Construction Vehicles in the UF6 Handling Area by Use of Spotters, Rev. 8 NEF-BD-C22, Verify Subcriticality by Mass Balance Calculation, Rev. 9 Organization Chart 2018- COO at UUSA Enrichment Ops, dated November 5, 2018 ORIROFSQC00100, ORM/IROFS Training and Qualification