ML19028A028

Global Nuclear Fuel-Americas, LLC - Nuclear Regulatory Commission Integrated Inspection Report 70-1113/2018-005

ML19028A028
Person / Time
Site:	07001113
Issue date:	01/28/2019
From:	Eric Michel NRC/RGN-II/DFFI/FFB2
To:	Beard B Global Nuclear Fuel
References
EA 17-090 IR 2018005
Download: ML19028A028 (14)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 January 28, 2019 EA 17-090 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 NUCLER FUEL - AMERICAS, L.L.C. - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 70-1113/2018-005

Dear Mr. Beard:

This letter refers to the inspections conducted during the fourth quarter of calendar year 2018 (October 1 - December 31, 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, Radiological Controls, 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 an exit meeting held on October 18, 2018.

Based on the results of these inspections, the NRC has determined that no violations of more than minor significance were identified.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 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

Should you have any questions concerning the inspections, 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:

1. NRC Inspection Report 70-1113/2018-005 w/

Attachment:

Supplementary 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

ML19028A028 SUNSI REVIEW COMPLETE FORM 665 ATTACHED RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI SIGNATURE Via FIT Via FIT Via FIT Via FIT Via FIT NAME KMcCurry TSippel PStartz TVukovinsky KWomack DATE 1/28/2019 1/28/2018 1/28/2019 1/28/2019 1/28/2019 1/ /2019 1/ /2019 E-MAIL COPY?

YES NO YES NO YES NO YES NO YES NO YES NO YES NO

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

70-1113 License No.:

SNM-1097 Report No.:

70-1113/2018-005 Licensee:

Global Nuclear Fuel-Americas, L.L.C.

Location:

Wilmington, North Carolina 28402 Dates:

October 1, 2018 to December 31, 2018 Inspectors:

K. McCurry, Fuel Facility Inspector in Training, (Section A.2)

T. Sippel, Fuel Facility Inspector, (Section A.2)

P. Startz, Fuel Facility Inspector, (Section A.1)

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

K. Womack, Fuel Facility Inspector, (Section B.1)

Approved by:

E. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection

EXECUTIVE

SUMMARY

Global Nuclear Fuel - Americas, LLC NRC Integrated Inspection Report 70-1113/2018-005 October 1 - December 31, 2018 Nuclear Regulatory Commission (NRC) regional inspectors conducted inspections during normal shifts in the areas of Safety Operations, Radiological Controls, 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 Nuclear Criticality Safety, no violations of more than minor significance were identified. (Section A.2)

Radiological Controls In the area of Radiation Protection, no violations of more than minor significance were identified. (Section B.1)

Facility Support In the area of Plant Modifications, no violations of more than minor significance were identified (Section C.1)

Special Topics Review of completed Confirmatory Order (EA 17-090) commitments. (Sections D.1 and D.2)

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 by interviewing staff, conducting direct inspection walk-downs of the process areas, and reviewing samples of records and procedures associated with select safety equipment in the DCP area including DCP Homogenization, DCP Blend Pre-Compact, DCP Blend Pre-granulate, and operations within the Rotary Pellet Pressing area to verify the licensee operates the plant safely and in accordance with 10 CFR Part 70, the License, and the License Application (LA). The inspectors reviewed samples of items relied on for safety (IROFS) associated with these areas as defined by the Integrated Safety Analysis (ISA) Nodes:

4010, 4011, 4020, 4021, 4030, 5030, and 5031. The inspectors evaluated representative samples of IROFS of process equipment to determine if the licensee was adequately implementing management measures in accordance with Chapter 3 of the LA, such that IROFS were designed, implemented, and maintained, as necessary, to be available and reliable to perform their function when needed.

The inspectors evaluated procedures and interviewed equipment operators to assess their knowledge of a sample of active IROFS to verify the licensees safety controls were adequately being implemented and communicated to operational personnel.

Specifically, the inspectors reviewed slugger and pellet press equipment IROFS listed in Section 4 of the attachment.

The inspectors reviewed the Criticality Safety Analysis (CSA) titled Rotary Press Unit Analysis, to evaluate if the associated IROFS implemented on the various rotary presses were in alignment with the logic and requirements generated by the CSA.

Inspectors also evaluated whether the CSA and IROFS requirements were adequately flowed down into a series of ten rotary press operating procedures including OP1020.14.000, 7B Rotary Press, through OP 1020.14.300, 7B Rotary Press -

Process Information, as required by Chapter 5.3, Management Measures, of the LA.

The inspectors reviewed a sample of training and qualification records of operators to verify compliance with training requirements listed in Chapter 11.4, Training and Qualifications, of the LA. The inspectors reviewed audits and interviewed licensee staff to verify the licensee performed internal audits that evaluated the application and effectiveness of management controls and implementation of programs related to plant safety in accordance with paragraph 11.2.5 of the LA. The inspectors reviewed event follow-up reports, corrective action program (CAP) entries, and audit reports to

2 determine whether the licensee was identifying plant operational safety issues at an appropriate threshold and entering them into the CAP as required by paragraph 5.3.2.6, Corrective Action Program, of the LA.

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

2.

Nuclear Criticality Safety (Inspection Procedure 88015)

a. Inspection Scope The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety program to verify compliance with selected portions of 10 CFR 70, applicable procedures and Chapter 5, Nuclear Criticality Safety, of the LA.

The inspectors reviewed selected CSAs to determine whether properly reviewed and approved CSAs were in place prior to conducting new or changed operations and were of sufficient detail and clarity to permit independent review. The inspectors reviewed the selected CSAs and associated assumptions and calculations to verify they were consistent with the commitments in the LA. These commitments include the licensees commitment to the Double Contingency Principle, assurance of subcriticality under normal and credible abnormal conditions with the use of subcritical margin, and specified technical practices and methodologies. The CSAs were selected based on their risk-significance, their heavy reliance on moderator control, and the timespan since they were last inspected. The review focused on CSA 1334.01, DCP - Homogenization; CSA 1335.01, DCP - Blend, Pre-Compact, Granulate, & Tumble; the qualitative risk assessments (QRAs) for these areas (QRA-205A, and QRA-206A); and other documents listed in Section 4 of the Attachment. The inspectors also reviewed the ISA summary and the supporting QRAs to determine whether the controls identified in the ISA were supported by technical basis in the CSAs.

The inspectors reviewed the licensees generation of accident sequences to determine whether the CSAs systematically identified normal and credible abnormal conditions in accordance with the commitments and methodologies in the LA for the analysis of process upsets. This included the review of accident sequences the licensee determined to be not credible to verify the bases for incredibility were consistent with the commitments, definitions, and methodologies in the LA, and documented in sufficient detail to permit an independent assessment of credibility. In addition, the inspectors reviewed select accident sequences designated as not credible to determine whether the bases for incredibility rely on items which should be identified as formal NCS controls or IROFS. This review was conducted for incredible moderator introduction sequences on the homogenizer, blender, and some presses.

The inspectors reviewed ISA guidance for assigning frequencies to initiating events, probabilities of failure on demand (PFODs) and duration indexes associated with IROFS failures, as well as applied management measures to verify the analyses in the QRAs were performed in accordance with the methodology committed to in the LA and applicable procedures.

3 The inspectors reviewed changes to the validation report to verify consistency with the technical practices and methodologies specified in the LA. This review focused on the revision to SCALE6.1/KENO-VI Monte Carlo Code Validation Report, which was revised to create an area of applicability for applications involving the neutron absorber Gadolinium, and new benchmark experiments for applications involving the neutron absorber Cadmium. The inspectors reviewed the new benchmarks, and interviewed licensee staff regarding:

the methods used to account for the bias and bias uncertainty, including the determination of normality, the applicability of the benchmark experiments to the application, and the use of an administrative margin in the upper subcritical limit.

The inspectors performed walk-downs of the homogenizer, blender, pre-compaction press, granulator, dry conversion facility HVAC system, sinter test system, and other areas where special nuclear material (SNM) is handled, used, or stored, to verify existing plant configuration and operations were consistent with the process description and safety basis in the selected CSAs listed above. The inspectors reviewed process and system descriptions, purchase specifications, and functional test instructions (FTIs) to verify engineered controls established in the CSAs and QRAs were included and being implemented as specified. The following engineered controls were reviewed:

IROFS 205-03, Homogenizer Lid Design IROFS 205-08, Process Equipment Barrier - Homogenizer IROFS 206-02, Blender Lid Design IROFS 206-04, FBS-BPG/AMM Verification of Moderator Fraction IROFS 206-09, Free Draining Press Base and Oil Catch Pan Geometry The inspectors reviewed operating procedures and interviewed licensee engineers to verify selected administrative controls established in the CSAs and QRAs were well defined to ensure proper function of the associate IROFS and being implemented as specified. The following administrative controls were reviewed:

IROFS 205-04, Non-Hydrogenous Oil IROFS 206-01, Blender External Oil Volume IROFS 206-03, FRS/LIMS Blend Plan Verifies Moderator Content IROFS 206-04, FBS-BPG/AMM Verification of Moderator Fraction IROFS 206-05, Blender Additive Bottle Design IROFS 206-06, Detection of Blender Arm Rotation IROFS 206-08, Routine Inspections of Press Base IROFS 900-05, Non-Hydrogenous Fire Suppression in an MRA The inspectors interviewed operators and engineers to verify administrative actions associated with these IROFS were understood and implemented properly.

The inspectors reviewed records of NCS audits and interviewed a licensee NCS engineer to verify NCS staff routinely assessed field compliance with established NCS controls and to verify audit findings were documented, tracked, and transmitted to Area Managers for appropriate action in accordance with LA Section 5.3.2.2, Auditing, Assessing and Upgrading the NCS Program. Additionally, the inspectors reviewed the

4 audit schedule and procedure for NCS audits, WI-27-104-02, Internal Nuclear Safety Audits, to verify the audits were performed on a planned schedule such that all applicable process and support areas would be audited at least every two years as required by Sections 5.3.2.2 and 11.6.1, Criticality, Radiation, Chemical, and Fire Safety Audits, of the LA. NCS audits reviewed are listed in Section 4 of the Attachment.

The inspectors reviewed aspects of the CSAs listed in Section 4 of the Attachment to verify they were performed in accordance with NCS program procedures and received appropriate independent review and approval. Additionally, the inspectors reviewed records to verify NCS staff members only performed functions they were qualified for.

The inspectors reviewed aspects of the criticality accident alarm system (CAAS) to determine whether the CAAS features met regulatory requirements and license commitments. The inspectors examined if the CAAS was designed and implemented to minimize false alarms, if detector failure was self-announcing, if dual alarm coverage was provided for all required areas, and if conservative assumptions were consistent with license commitments concerning the source strength, spectrum, location, and the amount and location of intervening shielding in accordance with Section 5.3.2.5, Criticality Accident Alarm System (CAAS) Design and Performance Requirements, of the LA. The documents reviewed included OP 2310.00.100, OP 2310.00.200, and 001N7915-R1, Analysis of Criticality Accident Alarm System Coverage in GNF-A Fuel Manufacturing Operation Facilities. The inspectors reviewed the audibility test procedure (OP 2310.00.300) and recent test records (LS 2310.00.05, CAAS Horn Test Log) to determine whether alarm signals were audible within the areas required to be evacuated. The inspectors reviewed test procedures and records to verify CAAS detector operability was maintained, detectors were calibrated, and all components were functionally tested. The procedures and records reviewed include OP 2310.00.400, LS 2310.00.06, Detector Functionality Test Log, and LS 2310.00.07, Detector Trip Test 2 Out Of 3 Functionality Log.

The inspectors interviewed licensee management and NCS engineers and reviewed licensee procedure WI-28-114-04, Nuclear Safety Advisor, to verify qualified NCS staff was readily available to advise the licensee in an emergency. The inspectors reviewed the procedure, conducted walk-downs, and interviewed licensee staff to determine whether the licensee required personnel evacuation to accountability points for a CAAS alarm, whether evacuation routes were posted, and whether the potential for exposing personnel to radiation was evaluated in locating accountability points. The inspectors conducted interviews and reviewed the procedure to verify the licensee had monitoring instrumentation and procedures to promptly assess dose to potentially exposed individuals and to aid in safe reentry and recovery, and to verify provisions were in place for prompt decontamination and medical treatment of exposed individuals.

The inspectors reviewed recent NCS and CAAS related CAP entries to verify anomalous conditions were promptly identified and entered into the CAP, and proposed corrective actions were sufficient and completed as scheduled. The CAP entries reviewed are listed in Section 4 of the Attachment.

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

5 B.

Radiological Controls

1.

Radiation Protection (Inspection Procedure 88030)

a. Inspection Scope The inspectors interviewed licensee staff and reviewed radiation protection program (RPP) documents and procedures to verify the program was being documented in accordance with 10 CFR 20.1101(a) and implemented in accordance with the LA, and to verify the RPPs function and responsibilities were independent from operations. The inspectors reviewed changes in the RPP organization to verify the new manager met the criteria and qualifications listed in the LA. The inspectors attended general employee training to verify the training was in compliance with 10 CFR 19.12.

The inspectors reviewed audits and interviewed licensee staff to verify the RPP performance was being reviewed, at least annually, for content and implementation in accordance with 10 CFR 20.1101(c). The inspectors reviewed records to verify the licensee conducted program audits in accordance with Sections 11.4.7, Evaluation of Training Effectiveness, and 11.6.1, Criticality, Radiation, Chemical and Fire Safety Audits, of the LA. The inspectors reviewed event follow-up reports, corrective action program entries, and audit reports to determine whether the licensee was identifying radiation protection issues at an appropriate threshold and entering them into the CAP as required by the LA.

The inspectors observed select instruments to verify the licensee had a system that identified instruments and equipment used for quantitative radiation measurements and tracked when they are due for periodic calibration or functional testing in accordance with 10 CFR 20.1501(c). The inspectors observed the personnel contamination monitors to verify there were no conditions that could impact the sensitivity of the detectors and they are set to alarm at the specified set points in the LA. The inspectors reviewed procedures and associated forms to verify the licensee performed periodic scheduled radiation and contamination surveys in accordance with licensee procedures to meet the requirements of 10 CFR 20.1501(a) and (b) and Section 4.5.1, Surveys, of the LA.

The inspectors walked-down various areas to verify the licensee posted the areas in accordance with 10 CFR 20.1902 and 20.1903 and that radiological signs and postings accurately reflected radiological conditions within the posted area. The inspectors observed that recent notices of violations as well as NRC Form 3, Notice to Employees, was posted by the licensee accordance with 10 CFR 19.11.

The inspectors interviewed staff to verify the licensee uses, to the extent practical, engineering controls to achieve occupational doses as low as reasonably achievable (ALARA) in accordance with 10 CFR 20.1101(b), as well as using process or engineering controls to control the concentration of airborne radioactive material in accordance with 10 CFR 20.1701. The inspectors interviewed staff and walked-down multiple areas to verify the air sampling program complies with the LA. The inspectors interviewed staff to verify the licensee maintains a program to identify and post areas as Airborne Radioactivity Areas per 10 CFR 20.1003 and 20.1902(d), respectively. The

6 inspectors reviewed procedures and associated forms as well as interviewed engineering staff to verify the licensee was in compliance with procedures for ventilation and airflow requirements in Section 4.3.1, Inter-Area Air Flow Design, of the LA.

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

C.

Facility Support

1.

Plant Modifications (Inspection Procedure 88070)

a. Inspection Scope and Observations The inspectors interviewed senior managers, managers, supervisors, and engineers to verify the licensee had established an effective configuration management program to evaluate, implement, and track modifications to the site which could affect safety as required by Chapter 11 of the LA.

The inspectors reviewed the licensees work control program to verify provisions were in place to ensure adequate pre-job planning and preparation of plant modification design packages occurred. The inspectors reviewed design packages to verify the configuration management program had provisions to ensure that plant modifications did not degrade the capabilities of IROFS or other safety controls part of the safety design basis.

The inspectors reviewed a sampling of plant modifications packages including major modifications, minor modifications, administrative modifications, and temporary modifications that were completed since the last plant modifications inspection to verify the change packages were prepared, reviewed, and completed in accordance with approved change management procedures. The following plant modification packages and their associated implementation documents were reviewed:

Change Request (CR) 18028, Sinter Test Grinder Start-Up CR 21517, Changing Production Grinder to Process Sinter Test CR 21670, Allow Bicones in the Gad MRA for Vibromill Blends CR 22010, Shutdown Converstion Kiln if Cooling Hopper Sample is Unavailable CR 22015, Lower Rad 1 and Rad 2 Pipe Detector Limits The selected plant modifications were reviewed to verify applicable post-maintenance installation and testing requirements were identified and performed prior to turnover to operations. The inspectors reviewed design information to determine whether instrument set points accurately reflected the protection of safety limits, taking into account instrument and calibration uncertainties. The inspectors also reviewed the licensees process of making changes to their functional test instructions, which are used to perform post-maintenance testing.

The inspectors reviewed plant modifications packages to verify the licensee addressed impacts of facility changes and document modifications on the ISA, ISA Summary, and other safety program documentation developed as required by 10 CFR 70.62. The

7 inspectors reviewed completed 10 CFR 70.72 evaluations to verify that the licensee was following their procedures and policies, as described in Chapter 3 of the LA, to determine whether NRC pre-approval of the change was required.

The inspectors performed walk-downs of selected modifications to verify they were installed in accordance with approved design documents such as drawings and technical reports.

The inspectors reviewed changes to the licensees change management program procedure, WI-16-106-01, GNF-A Change Management Process, since the last inspection to verify the changes were in compliance with the requirements of Chapter 3 of the LA.

The inspectors reviewed the licensees CAP to verify issues related to the preparation of change requests and the installation of facility changes were entered into the CAP and assigned appropriate corrective actions as required by paragraph 5.3.2.6, Corrective Action Program, of the LA.

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

D.

Special Topics

1.

Review of Confirmatory Order Section V Item 5 (Inspection Procedure 88020)

a. Inspection Scope The inspectors reviewed the licensees actions regarding Confirmatory Order (CO)

Section V, Item 5 (ML17348A132), which requires the licensee to augment their training for nuclear safety culture and safety conscious work environment for all workers with unescorted access to the GNF-A Controlled Access Area (CAA). The licensee has implemented this enhancement to their general employee training through the use of a mandatory video presentation for all employees that have unescorted access to the CAA. The inspectors, who also had to receive this training, reviewed the training presentation and reviewed a sampling of training records to verify employees with unescorted access had received this training prior to being granted access to the CAA.

The inspectors noted that the augmented nuclear safety culture training will be provided on an annual basis for at least three years as required by the CO.

b. Conclusion The licensee has implemented additional training for all employees with unescorted access in the area of nuclear safety culture and conscious work environment policies.

Based on a review of the training presentation and a sampling of employees with unescorted access, the NRC concludes that GNF-A has met the requirements as stated in the CO,Section V, Item 5. This item is considered closed.

8

2.

Review of Confirmatory Order Section V Item 6 (Inspection Procedure 88020)

a. Inspection Scope The inspectors reviewed the licensees actions regarding CO Section V, Item 6, which requires the licensee to conduct a benchmark assessment of the GNF-A RPP with at least two external RPP organizations in the fuel cycle industry, to identify and implement, as GNF-A deems appropriate, best practices and enhancements to increase the effectiveness of its RPP.

The inspectors reviewed the RPP Benchmark Topics for Discussion developed by GNF-A as a tool to evaluate their RPP against the programs at the BWXT NOG facility and the Westinghouse Columbia Fuel Fabrication facility. The inspectors noted that the benchmark assessments were completed on December 5-6, 2017 and March 20-21, 2018, respectively. The inspectors noted that a comprehensive review was completed in 12 focus areas developed by the licensee. Areas considered best practices were noted and condition reports were written to evaluate the implementation of these best practices from the other fuel facilities.

b. Conclusion The licensee has completed two benchmark assessments of other Fuel Facility RPPs to identify, and implement, as GNF-A deems appropriate, best practices and enhancements to increase the effectiveness of their RPP. Based on a review of the benchmark reports and corrective action program entries, the NRC concludes that GNF-A has met the requirements as stated in the CO,Section V, Item 6. This item is considered closed.

E.

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 October 18, 2018, to B. Beard and staff. No dissenting comments were received from the licensee.

Proprietary information was discussed but not included in the report.

SUPPLEMENTARY INFORMATION Attachment

1. KEY POINTS OF CONTACT Licensee personnel Name Title K. Campbell Manager, DCP & SS M. Connor Manager, Fabrication J. Degoyler FMO Integrted Safety M. Dodds Senior NCS Engineer D. Eghbali Senior NCS Engineer E. Ghantt Radiation Protection Engineer R. Haney Radiation Protection Supervisor B. Henderson Manager, Radiation Protection K. McGowen FMO Training S. Murray Manager, Facility Licensing D. Nay Manager, FMO Manufacturing Engineering P. Ollis Facility Licensing L. Paulson Acting Manager, Nuclear Criticality Safety J. Reeves Manager, Integrated Safety Analysis J. Rohner Manager, EH&S E. Saito Manager, Radiation Protection Program D. Thompson Senior Criticality Safety Engineer

2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Closed

3. INSPECTION PROCEDURES USED 88020 Operational Safety 88015 Nuclear Criticality Safety 88030 Radiation Protection 88070 Plant Modifications CO Section V, Item 5 CO The licensee has implemented additional training for all employees with unescorted access in the area of nuclear safety culture and conscious work environment policies.

(Section D.1)

CO Section V, Item 6 CO The licensee has completed two benchmark assessments of other Fuel Facilities RPP to identify, and implement, as GNF-A deems appropriate, best practices and enhancements to increase the effectiveness of their RPP. (Section D.2)

2

4. DOCUMENTS REVIEWED IROFS reviewed:

401-09, 401-10, 401-15, 401-16, 401-17, 402-08, 402-10, 402-11, 402-15, 402-16, 502-06, 502-07, 502-13, 502-15, 401-17, 401-16, 503-17, and 503-18 Records:

001N7915-R1, Analysis of Criticality Accident Alarm System Coverage in GNF-A Fuel Manufacturing Operation Facilities, dated December 2014 2018 Nuclear Safety Audit - Grind, Rod-Load, Weld, Lathes, Pellet and Rod Storage 2018 Nuclear Safety Audit - Engineering, CheMet and Environmental Labs 2Q18 Nuclear Criticality Safety Audit - Bundle Assembly, Shipping, Tubing/Component Storage, Shipping-Box Factory, Shipping-Pad 12, Shipping Refurbishment 3Q18 Nuclear Safety Audit - UO2/Gad Grind, Rod-Load, Weld, Pellet Storage, Rob Storage Audit Report NQA-2017-06, GNFA Manufacturing FCO-FMO Audit Report NQA-2018-06, FMO Ceramics-DCP CR 18028, Sinter Test Grinder Start-Up CR 21517, Changing Production Grinder to Process Sinter Test CR 21670, Allow Bicones in the Gad MRA for Vibromill Blends CR 22010, Shutdown Conversion Kiln if Cooling Hopper Sample is Unavailable CR 22015, Lower Rad 1 and Rad 2 Pipe Detector Limits CSA 403.00.100, Sinter Test System, Revision (Rev.) 2, dated January 20, 2017 CSA 1334.01, DCP - Homogenization, Rev. 8, dated August 22, 2006 CSA 1335.01, DCP - Blend, Pre-Compact, Granulate, & Tumble, Rev. 09, dated April 4, 2011 CSA 1020.00, Rotary Press Unit Analysis, Rev. 6, dated January 27, 2012 FTI 403-04 F1, Rev. 00, conducted August 29, 2018 FTI 406-04 F2, Rev. 00, conducted August 30, 2018 FTI 406-13 F2, Rev. 00, conducted August 29, 2018 FTI 1335-02, Prevent Setup and Execution of a Blend Plan that Exceeds the Total Moderation Mass Limits for the Blender, conducted May 20, 2018 LS 2310.00.05, CAAS Horn Test Log, dated December 16, 2017 LS 2310.00.06, Detector Functionality Test Log, Various December 2017 dates LS 2310.00.07, Detector Trip Test 2 Out Of 3 Functionality Log, dated December 16, 2017 MMSPI 1-FMO-009, Halocarbon 27 Oil NCS Audit Record, HVAC System Process Barriers to External Moderation NCS Audit Record, 2018 Nuclear Criticality Safety Audit - DSR, GDSR, Dry Conveyor Storage, dated October 11, 2018 NS-13-001, Sprinkler Water Density Calculation, dated March 28, 2013 QRA-205A, Dry Conversion Process: Homogenization, Rev. 1, dated August 29, 2017 QRA-206A, Dry Conversion Process: Blend, Pre-Compact, Granulate & Tumble, Rev. 2, dated November 17, 2017 SCALE6.1/KENO-VI Monte Carlo Code Validation Report, Rev. 3, dated May 2018 WO 240968, Annual Boot Replacement for Homo and Orbit Arm Oil Level Check WO 240970, Annual Shutdown Boot Replacement on Blender and Orbit Arm Oil Level Check WO 795401, Quarterly Calibration ASH-32321, Hydrogen Detector, PM F8A 32321-MO-07, 18 SEP 2018

3 Procedures:

CP-27-114, Integrated Safety Analysis, Rev. 8.0 OP 1020.14.000, 7B Rotary Press OP 1020.14.100, 7B Rotary Press, General Information OP 1020.14.201, 7B Rotary Press, Press Startup OP 1020.14.202, 7B Rotary Press, Start of Shift Checks OP 1020.14.203, 7B Rotary Press, Normal Operations OP 1020.14.204, 7B Rotary Press, Press Cleanout OP 1020.14.205, 7B Rotary Press, Shutdown OP 1020.14.206, 7B Rotary Press, Abnormal Operations OP 1020.14.207, 7B Rotary Press, Alarm Response and Emergency Ops OP 1020.14.300, 7B Rotary Press, Process Information OP 206.00.100, DCP Blend Pre-Compact Granulate, General Information OP 206.00.201, DCP Blend Pre-Compact Granulate, Loading Powder & Additive OP 206.00.202, DCP Blend Pre-Compact Granulate, Press and Granulator Startup OP 206.00.203, DCP Blend Pre-Compact Granulate, BPG Discharge and Cleanout OP 206.00.204, DCP Blend Pre-Compact Granulate, Granulate Blend Only Discharge &

Cleanout OP 206.00.208, DCP Blend Pre-Compact Granulate - Basic Operator Maintenance, Rev. 01 OP 2310.00.100, CAAS - Operating, Maintenance, Testing, and Response Procedure General Information and System Overview, Rev. 02, dated October 27, 2017 OP 2310.00.200, CAAS - Operating, Maintenance, Testing, and Response Procedure System Operations and Response, Rev. 01, dated October 27, 2017 OP 2310.00.201, CAAS - Operating, Maintenance, Testing, and Response Procedure System Operations Response, Rev. 03, dated October 27, 2017 OP 2310.00.300, CAAS - Operating, Maintenance, Testing, and Response Procedure Horn/Speaker Audibility Testing, Rev. 02, dated October 27, 2017 OP 2310.00.400, CAAS - Operating, Maintenance, Testing, and Response Procedure Detector Functionality Testing, Rev. 02, dated October 27, 2017 OP 2310.00.500, CAAS - Operating, Maintenance, Testing, and Response Procedure Routine Maintenance and Troubleshooting, Rev. 01, dated October 27, 2017 WI-16-106-01, GNF-A Change Management Process, Rev. 2.0 WI-27-104-02, Internal Nuclear Safety Audits, Rev. 3.0, dated May 16, 2016 WI-27-104-08, Safestore of Former Fissile Process Equipment, Rev. 1.2, dated March 14, 2018 WI-27-104-27, Nuclear Safety Release Requirements, Rev. 2.1, dated May 14, 2018 WI-28-114-04, Nuclear Safety Advisor, Rev. 0.0 Condition Report Written as a Result of the Inspection:

CR 29879 Condition Reports Reviewed:

CR 27555, CR 27556, CR 27561, CR 27724, CR 27935, CR 28151, CR 28880, CR 28912, CR 28942, CR 28961, CR 28962, CR 29005, CR 29068, CR 29151, CR 29309, CR 29314, CR 29416, CR 29475, CR 29821, CR 29822, CR 29879 Other Document:

Criticality Safety Analysis titled Rotary Press Unit Analysis, CSA# 1020.00, Rev. 06, dated January 27, 2012.