ML19213A337
| ML19213A337 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 08/01/2019 |
| From: | Robert Williams NRC/RGN-II/DFFI |
| To: | Beard B Global Nuclear Fuel - Americas |
| Geanette D | |
| References | |
| EA 17-090 IR 2019003 | |
| Download: ML19213A337 (12) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 August 1, 2019 EA 17-090 Mr. Brad Beard Plant Manager Global Nuclear Fuel-Americas, L.L.C.
P.O. Box 708, Mail Code J20 Wilmington, NC 2842
SUBJECT:
GLOBAL NUCLEAR FUEL- AMERICAS, L.L.C - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 70-1113/2019-003
Dear Mr. Beard:
The Nuclear Regulatory Commission (NRC) conducted inspections during the second quarter of calendar year 2019 (April 1 - June 30, 2019), at the Global Nuclear Fuel-Americas, L.L.C facility in Wilmington, NC. The purpose of these inspections was to determine whether activities authorized under the license in the area of Radiological Controls were conducted safely and in accordance with NRC requirements. The inspections consisted of examinations of procedures and representative records, observations of activities, and interviews with personnel. The enclosed report presents the results of these inspections. At the conclusion of these inspections, the inspectors discussed the findings with you and members of your staff at an exit meeting held on June 20, 2019.
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 Section 2.390 of the NRC's "Rules of Practice and Procedure," a copy of this letter and enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
B. Beard 2 Should you have any questions concerning the inspections, please contact Thomas Grice of my staff at 404-997-4477.
Sincerely,
/RA/
Robert E. Williams Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 70-1113 License No. SNM-1097
Enclosure:
NRC Inspection Report 70-1113/2019-003 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
ML19213A337 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI RII:DFFI RII:DFFI RII:DFFI SIGNATURE Via email Via feeder Via feeder /RA/
NAME T. Grice N. Pitoniak N. Peterka M. Ruffin DATE 7/26 /2019 7/22/2019 7/22/2019 7/22/2019 E-MAIL COPY? 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.: 70-1113/2019-003 Enterprise Identifier: I-2019-003-0073 Licensee: Global Nuclear Fuel - Americas, LLC Facility: Global Nuclear Fuel - Americas Location: Wilmington, North Carolina 28402 Dates: April 1, 2019 to June 30, 2019 Inspectors: N. Pitoniak, Senior Fuel Facility Inspector (Section A.2, B.1)
N. Peterka, Fuel Facility Inspector (Section A.1)
Approved by: Robert E. Williams Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Enclosure
EXECUTIVE
SUMMARY
Global Nuclear Fuel - Americas, LLC Nuclear Regulatory Commission Integrated Inspection Report 70-1113/2019-003 April 1 - June 30, 2019 Nuclear Regulatory Commission regional inspectors conducted inspections during normal shifts in the area of Radiological Controls. During the inspections, 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, 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 these inspections.
Radiological Controls
- In the area of Environmental Protection, no violations of more than minor significance were identified. (Section A.1)
- In the area of Transportation, no violations of more than minor significance were identified.
(Section A.2)
Special Topics
- (CLOSED) Confirmatory Order (CO)Section V, Items 2(1) and 2(2), GNF-A shall install a vehicle portal monitor with a sensitivity to detect vehicle surface radiation levels specified in 10 CFR 20.1301(a)(2). Procedures shall be developed and implemented to ensure that all non-manifested vehicle shipments from the Controlled Access Area are monitored and to validate, investigate, and to respond to alarms prior to releasing shipments off-site. (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 inspections, normal production activities at the facility were ongoing.
A. Radiological Controls
- 1. Effluent Control and Environmental Protection (Inspection Procedure 88045)
- a. Inspection Scope Through discussions with licensee staff, the inspectors determined that changes to the environmental protection program since the last inspection were in accordance with license requirements and that management maintained a commitment to keeping exposure as low as reasonably achievable (ALARA). The inspectors reviewed an environmental protection audit to verify that the licensee was identifying and addressing condition reports and that corrective actions were implemented in accordance with license requirements.
The inspectors reviewed environmental protection procedures updated since the previous inspection to verify the changes did not cause a decrease in safety significance or reduction in the control of effluents. The inspectors conducted a walk down of stack filtration housings and ambient air stations. The inspectors observed an environmental protection technician implement procedures for sample collection of four effluent stack monitors in accordance with EPI-O-6.0, Stack Sampling Program, to verify airborne effluent equipment and systems were operable and maintained in accordance with the requirements of the license application section 9.2. The inspectors reviewed the airborne effluent monitoring results from 2018 to verify the values specified in Appendix B of 10 Code of Federal Regulations (CFR) Part 20 were not exceeded.
The inspectors reviewed both semi-annual effluent reports for 2018 to verify the licensee was in compliance with 10 CFR 70.59. The inspectors reviewed records of soil sample collection results, discussed the results with licensee staff, and verified levels were within regulatory limits. The inspectors observed operation of gaseous effluent sample equipment and reviewed records to verify the gaseous effluent monitors were calibrated and the functional checks were performed in accordance with 10 CFR 20.1501.
The inspectors reviewed the public dose assessment to verify the average annual effluent concentrations released in 2018 met the standards of 10 CFR 20.1301 and 20.1302 and the records were being maintained in accordance with 10 CFR 20.2107.
The inspectors reviewed the airborne portion of the public dose assessment to verify results were in compliance with the ALARA constraints required by 10 CFR
2 20.1101(d). The inspectors performed field walk-downs of airborne environmental monitoring stations, well water sample collection points, and process lagoon sampling locations to verify the sampling points were in compliance with license requirements.
The inspectors observed two environmental technicians conduct liquid effluent sampling of the final process lagoon effluent in accordance with procedure EPI-O-2.0, Environmental Sampling of the Final Process Lagoon System, Aeration Basin and Site Dam.
b. Conclusion
No violations of more than minor significance were identified.
- 2. Inspection of Transportation Activities (Inspection Procedure 86740)
- a. Inspection Scope The inspectors evaluated whether the licensee had established, maintained, and implemented a management-controlled program to verify radiological and nuclear safety during the receipt, packaging, delivery to a carrier, and to private carriage of licensed radioactive materials. The inspectors observed transportation activities involving new fuel assemblies and UF6 cylinders to verify compliance with the applicable DOT transport regulations in 49 CFR.
The inspectors reviewed shipping records involving the shipment and receipt of special nuclear material products to verify the appropriate documentation accompanied the packages being shipped as required by CP-13-103, Shipping and Receiving of Radioactive Material. The inspectors performed walk-downs of six racks of UF6 cylinder packages, approximately 60 New Powder Containers (NPCs), and approximately 80 RAJ-II packages to verify compliance with required packaging and/or shipping order information requirements such as the transportation index, criticality safety index, package survey activity, labeling, and placards per OP 2000.10, Shipment of UF6 Material & Containers, OP 2000.01, Shipment of NPC, and OP 2000.05.202, Fuel Bundles in RAJ-II Containers-Container Loading and Securing.
The inspectors reviewed the training records of 10 transportation personnel to verify the licensee had administered 49 CFR 172.704 hazardous materials transportation training to applicable personnel as required by the Department of Transportation and the license.
The inspectors interviewed several refurbishment operators and observed outer and inner RAJ-II container refurbishment activities to verify compliance with OP 2000.02, RAJ-II Outer Container Refurbishment, and OP 2000.03, RAJ-II Inner Container Refurbishment.
The inspectors verified the licensee met the 10 CFR 71.21 conditions required to use the general license provision for transport of licensed material. The inspectors reviewed audits of the transportation program to verify the licensee was performing periodic audits of the program as required by the licensed application and the results of the audits were addressed in the corrective action program (CAP).
3 The inspectors reviewed the licensees CAP entries in the area of transportation for the past 24 months to verify deviations from procedures and unforeseen process changes affecting transportation were documented and investigated promptly. The inspectors reviewed the licensees Quality Assurance Program for packages, observed that it included control of non-conforming packages, and confirmed the control of non-conforming packages in the field. The inspectors reviewed the licensees identification and evaluation of non-conformances of nuclear material packaging to verify compliance with 10 CFR 71.95 requirements.
b. Conclusion
No violations of more-than-minor significance were identified.
B. Special Topics
- 1. Review of Confirmatory Order Items (Inspection Procedures 92703)
- a. Inspection Scope The inspectors reviewed the licensees actions regarding Confirmatory Order (CO)
Section V, Item 2(1) (ML17348A144) which required the licensee to install a vehicle portal monitor with a sensitivity that detects vehicle surface radiation levels specified in 10 CFR 20.1301(a)(2). In addition, the inspectors reviewed CO Section V, Item 2(2),
which required the licensee to develop and implement procedures to ensure all non-manifested vehicle shipments from the Controlled Access Area (CAA) are monitored and to validate, investigate, and to respond to alarms prior to releasing shipments off-site.
The inspectors performed walk-downs of the system installed, specifically the Ludlum Model 4525-14000 Vehicle Gateway Monitor. The inspectors reviewed alarm setpoints to verify the system was capable to detect vehicle surface radiation levels specified in 10 CFR 20.1301(a)(2) and to provide an alarm response. The inspectors observed surveillance, monitoring, and alarm equipment operation and discussed monitoring activities with Radiation Protection technicians and the Radiation Protection Manager. The inspectors reviewed procedure WI-27-105-30, Response to Vehicle Monitor Alarms, to verify vehicles exiting the monitoring area were monitored. The inspectors observed that all inbound commercial vehicles entering the monitoring area were also subjected to vehicle monitoring, despite not being designated as radioactive material shipments. The inspectors reviewed alarm logs for the previous 30 days of operation to verify all alarms were addressed, validated, and investigated as required per WI-27-105-30. The inspectors also reviewed the Ludlum Model 2525-14000 Truck Portal Monitor Detector Response Checks Logs and the Ludlum Model 4525 Radiation Portal Monitor Operators Manual, Version 3.7.8, to verify the availability and reliability of the system to comply with the Confirmatory Order,Section V, Items 2(1) and 2(2) requirements.
b. Conclusion
The licensee has completed the installation of a vehicle portal monitor with a sensitivity to detect vehicle surface radiation levels specified in 10 CFR 20.1301(a)(2) as required by CO Section V, Item 2(1). In addition, the licensee has developed and implemented
4 procedures to ensure that all non-manifested vehicle shipments from the Controlled Access Area are monitored and to validate, investigate, and respond to alarms prior to releasing shipments off-site as required by CO Section V, Item 2(2).
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 June 20, 2019, to Brad Beard, Plant Manager, and staff. No dissenting comments were received from the licensee. Proprietary information was discussed but not included in the report.
SUPPLEMENTARY INFORMATION
- 1. KEY POINTS OF CONTACT Licensee personnel Name Title B. Beard Facility Manager D. Hartsock Lead Logistics Specialist J. Hawkins MC&A Program Leader B. Henderson Radiation Protection Manager A. Heppner Manager, Logistics J. Matthews Manager, Transportation S. Murray Manager, Facility Licensing P. Ollis Facility Licensing J. Rohner Manager, Fuels EH&S C. Ware Container/Packing Specialist K. Williams Environmental Specialist
- 2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed CO Section V, Item 2(1) CO GNF-A shall install a vehicle portal monitor with a sensitivity to detect vehicle surface radiation levels specified in 10 CFR 20.1301(a)(2). (Paragraph C.1)
CO Section V, Item 2(2) CO GNF-A shall develop and implement procedures to ensure that all non-manifested vehicle shipments from the Controlled Access Area are monitored and to validate, investigate, and to respond to alarms prior to releasing shipments off-site. (Paragraph C.1)
- 3. INSPECTION PROCEDURES USED 88045 Effluent Control and Environmental Protection 86740 Transportation of Radioactive Material 92703 Follow-up of Confirmatory Action Letters or Orders
- 4. DOCUMENTS REVIEWED Records:
2018 ALARA Environmental Monitoring and Effluent Review, March 22, 2019 Decommissioning Funding Plan, September 7, 2016, Rev. 6 GNF-A Semi-Annual Effluent Monitoring Report for Jan-Jun 2018 GNF-A Semi-Annual Effluent Monitoring Report for Jul-Dec 2018 NSR/R 09.04.01, Nuclear Safety Release/Requirements - General Warehouse, Rev. 24 Attachment
2 NSR/R 09.01.03, Nuclear Safety Release/Requirements - PAD-12, Rev. 11 NSR/R 09.01.04, Nuclear Safety Release/Requirements - UF6 PAD, Rev. 6 Second Quarter Environmental Audit 2018, date July 13, 2018 Weekly Stack Report Fiscal Week 20 2018 Weekly Stack Report Fiscal Week 33 2018 Weekly Stack Report Fiscal Week 46 2018 WG000853, Torque Wrench WG000853 Calibration Record WI-16-108-04-F02, Non-Conformance Assessment Checklist for CR31338, Rev. 1 Procedures:
2018 ALARA Environmental Monitoring and Effluent Review, March 22, 2019 Decommissioning Funding Plan, September 7, 2016, Rev. 6 EPI-O-2.0, Environmental Sampling of the Final Process Lagoon System, Aeration Basin and Site Dam, Rev. 46 EPI-O-6.0, Stack Sampling Program, Rev. 75 EPI-O-7.0, Soil, Ditch, Vegetation, and State Split Sampling Programs, Rev. 45 EPI-O-8.0, Sample Collection from Site Wells at the GE/GNF-A Wilmington Site, Rev. 60 GNF-A Semi-Annual Effluent Monitoring Report for Jan-Jun 2018 GNF-A Semi-Annual Effluent Monitoring Report for Jul-Dec 2018 CAA Project Temporary Operating Procedure (TOP) 26260, RAJ-II Loading and Securing Configuration in 40 Foot Sea Vans, Rev. 0 CP-13-103, Shipping and Receiving Radioactive Material, Rev. 1 CP-13-106, In-Transit Protection of Special Nuclear Material, Rev. 0 CP-13-110, Audit Program for Carriers of Radioactive Material, Rev. 0 Ludlum Model 4525 Radiation Portal Monitor Operators Manual, Version 3.7.8 OP 1050.70.202, Fuel Bundle Packing - Packing Channeled Fuel Bundles, Rev. 1 OP 1050.70.203, Fuel Bundle Packing - Packing Non-Channeled Fuel Bundles, Rev. 6 OP 1050.70.205, Fuel Bundle Packing - Packing Outer Containers, Rev. 1 OP 2000.01, Shipment of NPC, Rev. 24 OP 2000.02, RAJ-II Outer Container Refurbishing, Rev. 33 OP 2000.03, RAJ-II Inner Container Refurbishing, Rev. 28 OP 2000.04.000, Shipping and Traffic, Rev. 0 OP 2000.04.100, Shipping and Traffic - General Information, Rev. 0 OP 2000.04.201, Shipping and Traffic - Shipping Operations, Rev. 1 OP 2000.04.202, Shipping and Traffic - Receiving Operations, Rev. 2 OP 2000.04.300, Shipping and Traffic - Shipping Documents, Rev. 2 OP 2000.04.301, Shipping and Traffic - RMP (Radioactive Materials Packaging and SR 374 Form, Rev. 1 OP 2000.05.000, Fuel Bundles in RAJ-II Containers, Rev. 0 OP 2000.05.100, Fuel Bundles in RAJ-II Containers - General Information, Rev. 0 OP 2000.05.201, Fuel Bundles in RAJ-II Containers - Shipping Documentation, Rev. 0 OP 2000.05.202, Fuel Bundles in RAJ-II Containers - Container Loading and Securing, Rev. 1 OP 2000.05.300, Fuel Bundles in RAJ-II Containers - Process Information, Rev. 0 OP 2000.10, Shipment of UF6 Material and Containers, Rev. 14 OP 2000.14, Shipment of TNF-XI, Rev. 6 Second Quarter Environmental Audit 2018, date July 13, 2018 Weekly Stack Report Fiscal Week 20 2018 Weekly Stack Report Fiscal Week 33 2018 Weekly Stack Report Fiscal Week 46 2018 WI-13-104-01, Packaging Documentation Control, Rev. 1.1
3 WI-13-104-03, Radioactive Material Shipping Containers, Rev. 2.0 WI-27-105-30, Response to Vehicle Monitor Alarms, Rev. 2.0 Condition Reports Written as a Result of the Inspections:
None Condition Reports Reviewed:
CR 19809 CR 31338 Other Documents:
Audit, dated 11/16/2018 Certificate of Compliance (CoC) 9303, Rev. 12 DBR-0031673, Design Basis Record Design Notes for GNF3 Channeled Fuel Drop Test FTR DBR-0046260, DBR - Design Basis Record Design Notes, Rev. 0 Memo to File: 10 CFR 70.25 Listing, dated November 14, 2018 Model UX-30 Package Safety Analysis Report, Rev. 4 NEDE-33881P, NPC SAR, Rev. 6 New Powder Container (NPC) Safety Analysis Report Nonconformance Assessment Checklist for CR# 19809 NQA-2018-10, GNF-A Manufacturing FCO/10CFR71 Containers/GNF3 Process Qualification NRC License XSNM 3398/05 RAJ-II Safety Analysis Report, Rev. 10