ML20115E452

Louisiana Energy Services, LLC (Les), DBA Urenco USA (Uusa) - Nuclear Regulatory Commission Integrated Inspection Report 70-3103/2020-001

ML20115E452
Person / Time
Site:	07003103
Issue date:	04/24/2020
From:	Robert Williams NRC/RGN-II/DFFI/FFB1
To:	Cowne S Louisiana Energy Services, URENCO USA
References
IR 2020001
Download: ML20115E452 (14)

Text

April 24, 2020 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 70-3103/2020-001

Dear Mr. Cowne:

This letter refers to the inspection conducted by the U.S. Nuclear Regulatory Commission (NRC) from January 1 through March 31, 2019, at the URENCO USA (UUSA) facility located in Eunice, New Mexico. The enclosed report presents the results of this inspection, which were discussed with you and members of your staff on February 27, 2020.

The inspection 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 were operational safety, nuclear criticality safety, and maintenance and surveillance of safety controls. Within these areas, the inspection consisted of examinations of selected procedures and representative records, observations of activities, and interviews with personnel.

Based on the results of this inspection, the NRC has determined that a licensee-identified, Severity Level IV violation of NRC requirements occurred. Because the violation was of very low safety significance and UUSA entered the issue in the corrective action program, this violation is being treated as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. The NCV is described in the enclosed inspection report. If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to: (1) the Regional Administrator, Region II; and (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

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.

S. Cowne 2 A copy of the this letter and its enclosure will also be available from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html.

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

Sincerely,

/RA/

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

Enclosure:

NRC Inspection Report No. 70-3103/2020-001 w/

Attachment:

Supplemental Information cc w/ encl: Distribution via LISTSERV

ML20115E452 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI/PB1 RII:DFFI/PB2 RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB1 R:II DFFI/PB1 NAME L. Cooke T. Sippel L. Pitts J. Rivera B. Adkins D. Anderson R.Wlliams DATE 04/10/2020 03/18/2020 04/13/2020 03/16/2020 04/09/2020 03/27/2020 04/24/2020 U. S. NUCLEAR REGULATORY COMMISSION REGION II INSPECTION REPORT Docket No.: 70-3103 License: SNM-2010 Report No.: 70-3103/2020-001 Enterprise Identifier: I-2020-001-0078 Licensee: Louisiana Energy Services (LES), LLC Facility: URENCO USA (UUSA)

Location: Eunice, NM Inspection Dates: January 1 through March 31, 2020 Inspectors: J. Rivera, Fuel Facility Inspector (Section A.1)

D. Anderson, Fuel Facility Inspector (Sections A.2)

T. Sippel, Fuel Facility Inspector (Sections B.1)

Approved: R. Williams, 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 70-3103/2020-001 January 1 - March 31, 2020 Regional inspectors from the U.S. Nuclear Regulatory Commission (NRC), Region II Office, conducted inspections during normal and off-normal hours in the areas of operational safety, nuclear criticality safety, and maintenance and surveillance of safety controls. The inspectors performed a selective examination of licensee activities by direct observation of safety significant activities and equipment, walk-downs of the facility, interviews and discussions with licensee personnel, and review of facility records.

Safety Operations

• No NRC-identified violations of more than minor significance were identified in the area of operational safety. One Severity Level-IV, licensee-identified, non-cited violation of NRC requirements was identified during the review of retracted event EN 54492. (Section A.1)

• No violations of more than minor significance were identified in the area of nuclear criticality safety. (Section A.2)

Facility Support

• No violations of more than minor significance were identified in the area of maintenance and surveillance of safety controls. (Section B.1)

Attachment Key Points of Contact List of Items Opened, Closed, and Discussed Inspection Procedures Used Documents Reviewed 2

REPORT DETAILS Summary of Plant Status The URENCO USA (UUSA) 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 the operation of selected processes to verify compliance with the requirements of Title 10 of the Code of Federal Regulations, Part 70 (10 CFR 70) and the Safety Analysis Report (SAR), as incorporated by reference in Condition 10 of the materials license. The inspectors selected the liquid effluent collection and transfer system (LECTS) for an in-depth review and reviewed portions of the multi-function decontamination train (MFDT) operation. The inspectors verified that the licensee implemented a safety program and applied appropriate management measures to items relied on for safety (IROFS) in accordance with the licensing basis of the facility.

Specifically, the inspectors reviewed the LECTS operating procedures to verify that the safety limits of IROFS 55a and 55b (criticality safety controls for the LECTS) were incorporated in the procedures as described in the Integrated Safety Analysis (ISA)

Summary and Section 11.4 of the SAR. The inspectors reviewed recent changes to the LECTS operating procedures to verify that safety-significant changes complied with the SAR requirements for procedure control. The inspectors also reviewed a sample of work orders for IROFS 55a and 55b to verify that the completion of these safety controls was documented in accordance with the applicable implementing procedures.

The inspectors performed field walk-downs of the LECTS to verify the system configuration was consistent with the system description in Section 3.5.12 of the ISA Summary and the configuration management requirements in Section 11.1 of the SAR.

The inspectors discussed the steps required to perform IROFS55a and IROFS55b with a qualified technician to determine whether the routine implementation of the IROFS was consistent with their intended safety function as described in the ISA Summary and the SAR. The inspectors also toured the on-site laboratory with chemistry staff to verify that the effluent sample analyses supporting IROFS 55a and 55b were performed in accordance with site procedures.

There were no operational activities of the LECTS during the inspection week; however, the inspectors observed in-progress operation of the MFDT as technicians prepared the system for down-blending activities and the implementation of administrative IROFS applicable to the MFDT. The inspectors observed this MFDT activity as a representative sample of procedure adherence for the same technicians who routinely operate the LECTS. The inspectors also observed the area supervisor and the designated technicians conduct the pre-job briefing for the MFDT evolution to verify that work planning activities were in accordance with site procedures.

The inspectors reviewed records regarding initial and continuing training programs to verify compliance with the requirements in Section 11.3 of the SAR.

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The inspectors reviewed a sample of technician qualification records to verify that the individuals were currently qualified on the IROFS assigned to them. The inspectors also reviewed recent changes to key management positions in the operations area to verify compliance with the position-specific requirements in Section 2.2 of the SAR.

The inspectors reviewed a sample of corrective action program (CAP) entries from the past 12 months to verify that safety-significant plant issues were identified for resolution and corrective actions were initiated in accordance with CAP procedures. The review of corrective actions included the implementation of compensatory measures for unavailable IROFS. Additionally, the inspectors reviewed a sample of audits and self-assessments in the operations area to verify that the licensee completed these at the required frequencies and that significant findings were entered into the CAP in accordance with Section 11.5 of the SAR.

As part of the review of CAP entries, the inspectors reviewed EV 136820 associated with event notification (EN) 54492 reported to the NRC on January 17, 2020. The EN involved a condition where uranic bearing material was placed into the small component decontamination train (SCDT) without meeting all the conditions of administrative IROFS54a and IROFS54b. The licensee retracted the EN on January 22, 2020, on the basis that the capabilities of the degraded IROFS were still sufficient to meet the performance requirements of 10 CFR 70.61. The inspectors interviewed licensing staff and independently reviewed the licensees technical justification for retracting the EN to verify compliance with the reporting requirements in 10 CFR 70.50, Reporting requirements, and Appendix A to 10 CFR 70, Reportable Safety Events.

b. Conclusion

No NRC-identified violations of more than minor significance were identified; however, the review of retracted event EN 54492 resulted in a licensee-identified, Severity Level-IV, non-cited violation of 10 CFR 70.62.

Title 10 CFR 70.62(d), Management measures, states, in part, that management measures shall ensure that engineered and administrative controls and control systems that are identified as IROFS pursuant to § 70.61(e) are designed, implemented, and maintained, as necessary, to ensure they are available and reliable to perform their function when needed, to comply with the performance requirements of § 70.61.

Contrary to this requirement, on January 17, 2020, URENCOs management measures failed to ensure that the administrative controls of IROFS54a and 54b were implemented, as necessary, to ensure they were available and reliable to perform their function when needed. The licensee reported the violation to the NRC via EN 54492 and then retracted it after the licensee determined that the performance requirements of

§ 70.61 were still met. The reported condition did not result in actual safety consequences and was captured in the licensees CAP as EV 136820. The significance of this violation was determined to be Severity Level IV using the guidance in NRC Inspector Manual Chapter (IMC) 0616 (Example J) and the example in Section 6.2.d.1 of the NRC Enforcement Policy. Because the violation was identified through the licensees credited CAP and its significance was determined to be Severity Level IV, it will be dispositioned as a non-cited violation (NCV) in accordance with Section 2.3.2 of the NRC Enforcement Policy, dated January 15, 2020. This violation will be opened and closed as NCV 70-3103/2020-001-01, Failure to Ensure that the Administrative Controls of IROFS54a/b Were Available and Reliable to Perform their Function When Needed.

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2. Nuclear Criticality Safety (Inspection Procedure 88015)

a. Inspection Scope Criticality Analysis The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety (NCS) program to verify compliance with selected portions of 10 CFR 70, including 70.24 and 70.61(d), Chapter 5 of the SAR, and applicable procedures.

The inspectors reviewed selected nuclear criticality safety analyses (NCSAs) and nuclear criticality safety evaluations (NCSEs) to verify that they were consistent with the commitments in the license application. These commitments included the double contingency principle, assurance of subcriticality under normal and credible abnormal conditions with the use of subcritical margin, and process specifications incorporating margin to protect against uncertainties in process variables and the accidental exceedance of limits. The NCSAs and NCSEs were selected based on factors including whether they were new or revised and their operating history with a focus on the LECTS and Contingency Dump System. The NCSAs and NCSEs reviewed included NCS-CSA-037, Nuclear Criticality Safety Analysis of the Slab Tanks, Rev. 0; NCS-CSA-016, Criticality Safety Analysis of 30B Cylinders, Rev. 5; ETC4100854, Criticality Safety Analysis of the Contingency Dump System, Issue 11; NCS-CSE-040, NCSE of Various Rig Systems, Rev. 1; NCS-CSE-034, Nuclear Criticality Safety Evaluation of the LECTS Room, Rev. 4; NCS-CSE-025, General Storage of Fissile Material, Rev. 8 and those listed in Section 4 of the attachment.

The inspectors reviewed changes to the criticality code validation report to verify consistency with the technical practices and methodologies specified in the license application. The validation report changes reviewed included the addition of MCNP6 Version 1 for criticality applications.

Criticality Implementation The inspectors performed walk-downs of the LECTS and Contingency Dump System 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 inspectors reviewed operating procedures and postings to verify that selected administrative controls established in the NCSEs were included. The inspectors interviewed engineers to verify that administrative actions established in the NCSEs were understood and implemented as specified.

Criticality Operational Oversight The inspectors reviewed NCS weekly walkthrough records and accompanied a licensee NCS staff member on an NCS weekly walkthrough of the Process Corridor 1001 to determine whether NCS staff routinely assessed field compliance with established NCS controls. The inspectors verified, through interviews with licensee NCS staff, that the NCS engineer prepared for the NCS weekly walkthrough by reviewing applicable documentation as needed to determine the limits for the area being walked down and by reviewing event reports that applied to the area, as required by CR-3-1000-03, NCS Weekly Walkthroughs and Periodic Assessments, Rev. 14, Section 5.2.1.

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The inspectors also reviewed NCS weekly walkthrough records and CAP entries to verify that deficiencies were documented in accordance with SAR Section 11.5 by entering them into the CAP.

Criticality Programmatic Oversight The inspectors reviewed revised NCS program procedures to determine whether the licensee implemented the NCS program in accordance with license requirements The revised NCS program procedures included: CR-3-1000-03, NCS Weekly Walkthroughs and Periodic Assessments, Rev. 14 and CR-3-1000-05, Preparation and Control of Non-Design Calculations, Rev. 7.

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.

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.

Criticality Corrective Action The inspectors reviewed selected NCS-related CAP entries to verify that conditions adverse to safety were promptly identified and entered into the CAP, that they received the required level of investigation, and that they were closed out consistent with license commitments and procedures. The inspectors reviewed the associated corrective actions to verify they were sufficiently broad, prioritized on a schedule commensurate with their significance, and completed as scheduled. Additionally, the inspectors reviewed the selected 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 EV 130030, EV 130061, EV 130236, and EV 130237.

b. Conclusion

No violations of more than minor significance were identified.

B. Facility Support

1. Maintenance and Surveillance of Safety Controls (Inspection Procedure 88025)

a. Inspection Scope The inspectors reviewed the licensees maintenance and surveillance activities for IROFS and the criticality accident alarm system (CAAS) to determine whether the licensee established an effective program to ensure IROFS remained available and reliable to perform their safety function when needed in accordance with 10 CFR 70.61, 10 CFR 70.24, and Chapter 11, Management Measures, of the SAR. Specifically, the inspectors reviewed work packages, observed pre-job briefings, and IROFS surveillance activities to verify that the licensee was conducting maintenance and surveillance activities to ensure controls were maintained in accordance with the SAR.

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The inspectors reviewed the licensees work control program by reviewing work orders, interviewing personnel, and attending meetings to verify that pre-job planning and preparation of work orders were conducted in accordance with WC-2-1000-01, Work Control Program, and the requirements of the SAR, Section 11.2. The inspectors also reviewed maintenance and surveillance work orders and procedures to verify that the test packages challenged and verified operability of IROFS, that a job hazard assessment was performed, that lockout tagout was provided for, and that IROFS related work orders (WOs) were quality assurance (QA) level 1.

The inspectors observed maintenance work activities on selected systems and processes to verify work activities were conducted in accordance with licensee requirements and approved procedures. Specifically, the inspectors observed operations personnel conduct an IROFS 36A walkdown, and observed maintenance personnel conduct a periodic test of IROFS 1 and 2. The inspectors reviewed IROFS test procedures (e.g., MA-3-3400-01, IROFS1 Station Heater and Fan High Temperature Trip - RTD Surveillance, MA-3-3400-02, IROFS2 Station Heater and Fan High Temperature Trip - TC Surveillance) to verify that they were accurate, specified measurement and test equipment, and were sufficiently detailed so that qualified personnel could perform the test without direct supervision as required by the SAR, Section 11.2.6.2. The inspectors also reviewed the procedures listed in Section 4 of the attachment to this report.

The inspectors interviewed technicians and reviewed completed work orders used to test and maintain the CAAS, to determine whether alarm signals were audible, whether detectors were calibrated, whether operability was maintained, and whether the system was functionally tested periodically and following maintenance. The work orders reviewed are listed in Section 4 of the attachment to this report.

The inspectors reviewed qualification material and interviewed licensee maintenance personnel regarding training and qualifications to verify that the individuals were qualified to perform their assigned activities on safety related equipment. Specifically, the inspectors reviewed training and qualification records associated with IROFS 1 and 2.

The inspectors reviewed selected corrective action program entries to verify that performance issues relating to the maintenance and surveillance of IROFS and the CAAS were entered into the CAP and corrective actions had been implemented when required in accordance with the SAR, Section 11.6. The inspectors reviewed audits and self-assessments of the maintenance and surveillance program from the last year to verify that the licensee was complying with SAR, Section 11.5, and entering findings into the corrective action program.

b. Conclusion

No violations of more than minor significance were identified.

B. 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 February 27, 2020, to K. Fili, Managing Director UUSA, and President and CEO LES, LLC and staff. Proprietary information was discussed during the inspection but is not included in this report.

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SUPPLEMENTAL INFORMATION

1. KEY POINTS OF CONTACT Name Title A. Bixenman Licensing Specialist A. Blackshear NCS Support Staff J. Dahlin Acting EH&S Manager K. Engan Mechanical Maintenance Supervisor R. Kohrt NCS Support Staff J. Lagabed Waste Recycling Supervisor Q. Newell ISA/NCS Engineer W. Padgett Licensing Manager A. Reidy ISA/NCS Engineer L. Wiseman Lead Maintenance Technician W. Wood PCES Maintenance Supervisor

2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened/Closed 70-3103/2020-001-01 NCV Failure to Ensure that the Administrative Controls of IROFS54a/b Were Available and Reliable to Perform their Function When Needed

3. INSPECTION PROCEDURES USED IP 88015 Nuclear Criticality Safety IP 88020 Operational Safety IP 88025 Maintenance and Surveillance of Safety Controls

4. DOCUMENTS REVIEWED Records:

2019-A-02-003, Report for the URENCO USA (UUSA) Nuclear Criticality Safety Program NQA-1 Audit, dated March 18, 2019 2019-A-10-019, Report for URENCO USA (UUSA) IROFS Compliance NQA-1 Audit, Rev. 0 2019-152: Changes to CC-OP-2019-0012 due to revision of NCS-CSA-013, Rev. 0, dated July 3, 2019 2019-154: Changes to NEF-BD-C22 due to revision of NCS-CSA-015, Rev. 0, dated July 17, 2019 2019-250: ISA Summary (Addition of MCNP6 Version 1 for criticality applications), Rev.

30b, dated November 17, 2019 CA-3-1000-09-F-1, Self-Assessment, Rev.12: Assessment of Activities Associated with Maintaining IROFS SA-2018-002, dated December 14, 2018 Completion Records of Training Course GWIROFSQC, Deco and Recycling IROFS Certification Program Items Relied on For Safety (IROFS), Rev. 1 for Two Recycling Technicians CR-3-1000-03-F-1, Criticality Safety Walkthrough, Revision13, Area Inspected: LECTS Room, dated April 12, 2019 CR-3-1000-03-F-1, Criticality Safety Walkthrough, Rev.13, Area Inspected: LECTS Room, dated June 14, 2019 Attachment

CR-3-1000-03-F-1, Criticality Safety Walkthrough, Rev.13, Area Inspected: LECTS Room, dated November 26, 2019 ETC4100854, Criticality Safety Analysis of the Contingency Dump System, Issue 11, dated April 1, 2015 NCS-CSA-016, Criticality Safety Analysis of 30B Cylinders, Rev. 5, dated December 23, 2019 NCS-CSE-021, Movement of Components, Rev. 8, dated December 4, 2019 NCS-CSE-025, General Storage of Fissile Material, Rev. 8, dated August 22, 2019 Qualification records for various NCS Personnel NCS-CSE-034, Nuclear Criticality Safety Evaluation of the LECTS Room, Rev. 4, dated July 31, 2019 NCS-CSE-037, Nuclear Criticality Safety Analysis of the Slab Tanks, Rev. 0, dated December 4, 2019 NCS-CSE-040, NCSE of Various Rig Systems, Rev. 1, dated January 22, 2020 SA-2019-001, UUSA Nuclear Criticality Safety (NCS) Assessment 2019 Assessment of NCS Training and Posting Site Knowledge, dated August 28, 2019 SA-2017-002, UUSA Program Assessment 2017, dated October 30, 2017 SA-2018-001, UUSA Nuclear Criticality Safety Programmatic Assessment 2018, dated June 26, 2018 SA-2019-013, Maintenance Safety Self-Assessment, dated June 21, 2019 SA-2019-019, Maintenance Self-Assessment 2019, dated November 4, 2019 WO 1000351833, 5Y: IROFS27E Structural Inspection WO 1000377410, SBM1: DB Reading at S151 and S152 WO 1000379155, 1Y: IROFS 4 & 5 WO 1000380503, 1Y: IROFS 1 & 2 WO 1000381832, 1Y: SITE CAAS Annual Maint WO 1000382473, SITE: Eng Inspection of IROFS 27E (EMERG)

WO 1000383197, SBM1: Insp CAAS WO 1000390605, SBM3: LOOSE IROFS RTD WIRE 3P5 WO 1000393490, LECTS SLAB/BST OPS IROFS 55a/b, June 5, 2019 WO 1000394654, SITE: CAAS Speaker Repairs WO 1000398598, LECTS SLAB/BST OPS IROFS 55a/b, October 9, 2019 WO 1000407310, 1Y: Tuning of CAAS Amp Monitor WO 1000408937, 1001: 561 Perform Funct Check of KOWLS WO 1000410799, LECTS Fill Station Decon WO 1000413678, SCDT OPS, January 24, 2020 WO 1000414206, 1Y: IROFS 4 & 5 WO 1000416928, 1Y: IROFS10 Autoclave Leak Test WO 1000418055, TSB: CAAS Main Panel Logic Unit Fault WO 1000418546, LECTS SLAB/BST OPS IROFS 55a/b, November 20, 2019 WO 1000421833, 1003 IROFS36A Combustible Control Insp Procedures:

AD-3-1000-02, Procedure Use and Adherence, Rev. 15 CA-3-1000-01, Performance Improvement Program, Rev. 43 CH-2-1020-001, Calibration and Quality Control of Analytical Instruments, Rev. 2 CR-3-1000-03, NCS Weekly Walkthroughs and Periodic Assessments, Rev. 14 CR-3-1000-05, Preparation and Control of Non-Design Calculations, Rev. 7 EG-3-3200-02, Nuclear Criticality Safety Analysis/Evaluation, Rev. 12 E-NCS-CP, NCS Criticality Engineer Demonstration of Continued Proficiency, Rev. 3 E-NCS-CTR-ESP-TG, Criticality ESP (Engineering and Support Personnel Program)

Engineer Orientation, Rev. 1 3

E-NCS-QG, Nuclear Criticality Safety (NCS) Engineer, Rev. 4 E-NCS-Senior-QC, NCS Senior Criticality Engineer, Rev. 0 E-NCS-SS-QG, Nuclear Criticality Safety (NCS) Support Staff, Rev. 2 MA-2-1000-01, Conduct of Maintenance, Rev. 4 MA-3-1000-02, Calibration and Control of Measuring and Test Equipment, Rev. 16 MA-3-2470-01, Autoclave Leak Check Surveillance IROFS10, Rev. 7 MA-3-3400-01, IROFS1 Station Heater and Fan High Temperature Trip - RTD Surveillance, Rev. 11 MA-3-3400-02, IROFS2 Station Heater and Fan High Temperature Trip - TC Surveillance, Rev. 13 MA-3-3400-11, IROFS11 Autoclave Heater and Fan High Temperature Trip - RTD Surveillance, Rev. 10 MA-3-3400-12, IROFS12 Autoclave Heater and Fan High Pressure Trip - Pressure Detector Surveillance, Rev. 10 MC-3-3000-01, Measurement Control, Rev. 13 MC-3-3000-03, Analysis and Qualification of MC&A Analytical Measurements Systems, Rev.

8 MM264TPE01I00, Maintain IROFS 10, Rev. 3 MP254TPERTDI00, Maintain RTD IROFS, Rev. 0 MP254MPTCI00, Maintain TC IROFS, Rev. 0 RW-3-2000-01, LECTS Slab Tank Operations, Rev. 15 RW-3-4000-01, Startup, Shutdown, and Operation of the SCDT, Rev. 9 TQ-3-0100-13, Training and Qualification Guidelines, Rev. 9 WC-4-1000-02, Conduct of Pre-Job and Post-Job Briefs, Rev. 7 WC-2-1000-01, Work Control Program, Rev. 10 WC-3-1000-02, Work Package - Initiation through Closure (SAP Order Types PM1/PM3),

Rev. 35 WC-4-1000-02, Conduct of Pre-Job and Post-Job Briefs, Rev. 7 Condition Reports Written as a Result of the Inspection:

EV 137246, EV 137252, EV 137253 Condition Reports Reviewed:

EV 129954, EV 130030, EV 130059, EV 130061, EV 130201, EV 130236, EV 130237, EV 130238, EV 130239, EV 131848, EV 132016, EV 132333, EV 1302725, EV 133055, EV 133105, EV 133656, EV 134697, EV 136421, EV 136820 Other Documents:

70.72(c) Evaluation 2019-088, Revision to RW-3-2000-01, LECTS Slab Tank Operations, Rev. 13 EOR-GET-CRIT-01, Nuclear Safety Training, Nuclear Criticality Safety, Rev. 3.1 GET Training, Criticality Safety, dated June 12, 2019 LAR 18-04 Addition of MCNP6 for Nuclear Criticality Safety Analysis, dated August 22, 2019 Learner Transcript for ORM/IROFS Training and Qualification, February 24, 2020 NCS-REP-002-02, UUSA MCNP6 Validation, dated May 8, 2019 NEF-BD-54a, Administratively Limit the Calculated SCDT Uranic Mass Inventory, Rev. 2 NEF-BD-55a, Limit Liquid Effluent Collection and Transfer System (LECTS) Tank and Tote Uranium Enrichment Inventory, Rev. 3 4

NEF-BD-55b, Limit Liquid Effluent Collection and Transfer System (LECTS) Tank and Tote Uranium Enrichment Inventory, Rev. 3 Nuclear Criticality Safety 2019 Continuing Training, dated September 19, 2019 SA-2019-002, Self-Assessment of Deco and Recycling IROFS Implementation, December Qualification records for various staff 2019 SA-2019-018, 2019 Shift Operations HPE Self-Assessment, December 2019 4