ML20303A302

Louisiana Energy Services, LLC (Les), DBA Urenco USA (Uusa) - Nuclear Regulatory Commission Integrated Inspection Report 70-3103/2020-003

ML20303A302
Person / Time
Site:	07003103
Issue date:	10/29/2020
From:	Robert Williams NRC/RGN-II
To:	Cowne S Louisiana Energy Services, URENCO USA
References
IR 2020003
Download: ML20303A302 (19)

Text

October 29, 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 70-3103/2020-003

Dear Mr. Cowne:

This refers to the inspection conducted by the U.S. Nuclear Regulatory Commission (NRC) from July 1, 2020 through September 30, 2020, at the URENCO USA (UUSA) facility located in Eunice, New Mexico. During this period, the NRC implemented alternative ways to complete the core inspection program for your site in response to the public health emergency declared by the Secretary of Health and Human Services on January 31, 2020, and the National Emergency declared by the President of the United States on March 13, 2020, regarding the public health risks of the novel coronavirus (COVID-19) disease. On March 19, 2020, the NRC transitioned into a mandatory telework posture for all staff consistent with social distancing and travel recommendations issued to federal agencies. Consequently, the NRC Region II staff continues to evaluate how to best conduct inspections while balancing our determinations of reasonable assurance of adequate protection and ensuring the health and safety of inspectors and the public at large.

The NRC will continue evaluating the guidelines and recommendations from federal and state authorities, along with the conditions of your facility, to determine when to resume inspection activities as normal. In the interim, the NRC plans to continue to conduct a combination of remote and onsite inspections as appropriate. The NRC will also maintain frequent communications with your staff to discuss regulatory compliance matters and gather information to inform the decisions about future inspections.

The enclosed report presents the results of the inspections, which were conducted through remote reviews. The inspectors reviewed activities as they relate to public health and safety, the common defense and security, and compliance with the Commissions rules and regulations, as well as the conditions of your license. The inspections covered the areas of emergency preparedness, fire protection, and problem identification and resolution. Within this area, regional inspectors reviewed procedures and representative records remotely and conducted telephonic interviews with site personnel. The results of this inspection were discussed with members of your staff at an exit meeting held on June 20 and August 16, 2020.

Based on the results of the conducted inspections, the NRC has determined that one Severity Level IV violation of NRC requirements occurred. Because the violation was of low safety significance and UUSA entered the issue into 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.

S. Cowne 2

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 (10 CFR) 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 Agency-wide Document Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

Should you have any questions concerning this report, please contact Brannen Adkins of my staff at 404-997-4620.

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 70-3103/2020-003 w/

Attachment:

Supplementary Information cc w/ encl: Distribution via LISTSERV

ML20303A302 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB1 NAME L. Cooke B. Adkins L. Pitts R. Williams DATE 10/20/2020 10/20/2020 10/20/2020 10/29/2020 E-MAIL COPY?

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

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

70-3103 License No.:

SNM-2010 Report No.:

70-3103/2020-003 Enterprise Identifier: I-2020-002-0057 Licensee:

Louisiana Energy Services (LES), LLC Facility:

URENCO USA (UUSA)

Location:

Eunice, NM Dates:

July 1 through September 30, 2020 Inspectors:

B. Adkins, Senior Fuel Facility Inspector (Section A.1, C.1, and C.2)

L. Cooke, Fuel Facility Inspector (Section B.1 and C.1)

D. Edwards, Fuel Facility Inspector (Section C.1)

Approved by:

Robert E. Williams Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection

EXECUTIVE

SUMMARY

2 Louisiana Energy Services, LLC (LES) dba URENCO USA (UUSA)

NRC Integrated Inspection Report 70-3103/2020-003 July 1 - September 30, 2020 Regional inspectors from the U.S. Nuclear Regulatory Commission (NRC), Region II Office, conducted remote inspections during normal shifts in the areas of fire protection (annual),

emergency preparedness, and corrective action program implementation. The inspectors performed a selective examination of licensee activities by interviewing licensee personnel and reviewing facility records.

Safety Operations No violations of more than minor significance were identified in the area of fire protection (annual). (Section A.1)

Facility Support One NRC identified Severity Level (SL) IV non-cited violation (NCV) was identified in the area of emergency preparedness for failure to correct a deficiency found during the critique of an emergency exercise. (Section B.1)

Other Areas No violations of more than minor significance were identified in the area of corrective action program implementation at fuel cycle facilities. (Section C.1)

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

REPORT DETAILS 3

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.

Fire Protection (Annual) (IP 88055) - Remote Inspection

a. Inspection Scope The inspectors reviewed select aspects of the UUSA fire protection program as part of a remote inspection to verify compliance with the Safety Analysis Report (SAR),

Emergency Plan, fire protection program implementing procedures, and Title 10 of the Code of Federal Regulations (10 CFR) Part 70 to verify that the material condition and operational status of fire protection equipment, systems, and features were implemented in accordance with Chapter 7.0, Fire Safety, of the SAR, 10 CFR 70.61, and 70.62.

The inspectors interviewed licensee personnel and reviewed surveillance records to verify that the control of transient combustible materials, including pre-staged work materials, was consistent with FP-3-1000-02, Flammable and Combustible Materials Control, and that the cutting, welding, and hot work permit program was implemented in accordance with FP-3-1000-03, Hot Work Fire Prevention During Welding, Cutting, and Other Hot Work.

The inspectors reviewed surveillance test records and interviewed licensee personnel to verify that fire protection systems were available, operable, and in proper material condition. The review focused on records associated with the Cylinder Receipt and Dispatch Building (CRDB). Additionally, the inspectors performed the above review to verify that items relied on for safety (IROFS), including IROFS 35, Fire Rated Barriers, and IROFS 36a, Limit Transient Combustible Material in Uranic Areas, were properly implemented to verify their ability to perform their safety function in accordance with Chapter 7 SAR requirements, National Fire Protection Association (NFPA) 801, and fire protection program implementing procedures.

The inspectors reviewed records to verify that the fire water system was operable and capable of supplying the water supply demand listed in the Fire Hazards Analysis (FHA).

Specifically, the inspectors reviewed completed surveillances for the fire water pumps (electric and diesel), fire water tanks, and the 5-year NFPA inspection of the fire water system check valves.

The inspectors reviewed completed surveillance records of CRDB fire hydrants, fire extinguishers, and fire hoses to ensure the inspections were completed in accordance with SAR and NFPA requirements. The inspectors reviewed records to determine whether fire dampers, doors, and penetration seals in the CRDB were being maintained in a condition that would ensure they were available and reliable to perform their fire safety function.

4 The inspectors reviewed the licensee fire protection system out-of-service / impairment log, procedure, and selected records to verify that adequate compensatory measures had been put in place for out-of-service, degraded or inoperable fire protection equipment, systems or features in accordance with NFPA 801 and Section 7.0 of the SAR.

The inspectors reviewed the licensees corrective action program entries for the past 12 months to verify that the licensee was identifying fire protection operability problems at an appropriate threshold and entering them into the corrective action program in accordance with Section 16.0 of the Quality Assurance Program Description (QAPD) and Section 11.6 of the SAR, Incident Investigations and Corrective Action Program.

The specific corrective actions reviewed are listed in Section 4.0 of the Attachment. The inspectors also reviewed the 2019 self-assessment of the fire protection program to ensure that fire protection related deficiencies were being identified and entered into the CAP for resolution as required by Section 11.5.1 of the SAR.

The inspectors reviewed licensee training procedures and records and interviewed staff to verify that the training of operators in the area of fire protection related IROFS (IROFS 35 and 36a) was performed as required by Section 11.3 of the SAR. The inspectors reviewed the training and qualification of one fire protection engineer.

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

B.

Facility Support

1.

Emergency Preparedness (IP 88050) - Remote Inspection

a.

Inspection Scope The inspectors reviewed select aspects of the Urenco USAs (UUSAs) emergency preparedness (EP) program as part of a remote inspection to verify compliance with the SAR, Emergency Plan, Emergency Plan Implementing Procedures (EPIPs), and 10 CFR Part 70. The inspectors reviewed records and interviewed staff to verify that changes made to the Emergency Plan were reviewed by the EP organization as required.

Specifically, the inspectors reviewed the changes made to remove the onsite meteorological tower to verify that it would not result in a reduction in effectiveness of the overall Emergency Plan without receiving prior NRC approval of the changes being made.

The inspectors reviewed a sample of the EPIPs to verify that they were reviewed periodically and approved as required. The inspectors also reviewed the EPIPs to verify that they provided for the detection and proper classification of accidents, assessment or releases, protective action recommendations, and personnel accountability, as required by the Emergency Plan.

5 The inspectors reviewed training records and interviewed licensee staff regarding emergency preparedness training that occurred since the last inspection. The inspectors conducted the interviews and reviewed the training records to verify that the licensee provided position specific training to individuals and that they understood their roles and responsibilities as Emergency Response Organization (ERO) members during a drill or emergency. The inspectors reviewed rosters and conducted interviews to verify that the licensee maintained appropriate staffing levels of trained emergency personnel for all shifts.

The inspectors reviewed the written agreements with off-site support agencies to verify that Memoranda of Understanding between the off-site organizations and the licensee were maintained up to date as required by the Emergency Plan.

The inspectors reviewed drill schedules to verify that required drills, exercises, and communication checks were conducted within the timeframe required by the Emergency Plan and EPIPs. The inspectors reviewed corrective actions and interviewed staff to verify that items identified during critiques were being captured and addressed in the corrective action program (CAP) and resolved.

The inspectors reviewed licensee audit records to verify that the licensee conducted audits in the area of emergency preparedness as required by Emergency Plan. The inspectors verified that the auditors did not have direct responsibility for implementation of the emergency response program and that findings from the audit were communicated to senior facility management and put into the CAP.

b.

Conclusion One NRC identified Severity Level (SL) IV non-cited violation (NCV) was identified in the area of Emergency Preparedness for failure to correct a deficiency found during the critique of an emergency exercise.

==

Introduction:==

An NRC identified SL IV NCV of 10 CFR 70.22(i)(3)(xii) was identified for the licensees failure to correct a deficiency found by the critique of the 2019 NRC evaluated biennial emergency exercise. Specifically, UUSA failed to correct a partially met exercise objective associated with the timely dispatch of radiation protection technicians in support of the fire brigade leader, incident commander, and on-scene responders.

Description The critique of the 2019 emergency exercise identified Objective 9, radiation protection (RP) technicians will be dispatched to support the fire brigade leader, incident commander, and on scene responders, as partially met for two reasons. First, when radiological protection (RP) technicians were called to the control room, they were told that the control room was too busy to make assignments to the RP technicians, which delayed the RP technicians reaching the incident command post. Second, RP technicians were unable to complete habitability checks at the assembly areas and evacuee checks in a timely manner due to limited RP tech resources with multiple concurrent responsibilities. This partially met exercise objective was placed in the CAP as EV133623.

6 The EV generated a series of actions to be evaluated which included (1) placement of RP technicians on the ERO, (2) updating of EP procedures to include an RP checklist, and (3) having fire brigade members perform control room habitability checks. Based on their review of the closed EV, the inspectors concluded that the licensee failed to complete any of the identified actions to address the critique deficiency. Specifically, the first action was not completed because there were not enough qualified RP technicians to add them to the ERO. The second action item was not completed because RP duties were already described in current procedures. Finally, the last action item was not completed because the procedure already required habitability checks to be performed at the onset of EOC activation.

Analysis The inspectors determined that this violation aligned with Inspection Manual Chapter (IMC) 0616 Appendix B Emergency Preparedness Example 8.e, which stated that during an annual emergency preparedness inspection, the inspectors discovered that the licensee failed to correct a deficiency identified during the last biennial exercise. The violation was determined to be of more than minor significance since the licensee had taken no action to correct the critique deficiency. The inspectors determined this violation aligned with a Severity Level (SL) IV violation as defined in Section 6.2.d.7 of the NRC Enforcement Policy, which stated that the licensee fails to meet or implement an emergency planning standard or requirement not associated with assessment or notification.

The potential safety significance of this violation is very low. The drill objective was partially met, and ultimately the RP technicians were able to perform the necessary on-scene support for the drill. During this emergency preparedness inspection, the inspectors reviewed other corrective actions associated with emergency preparedness drills, critiques, and audits, and found that the licensee took actions to correct other identified issues.

Enforcement 10 CFR 70.22(i)(3)(xii) states, in part, that critiques of exercises must evaluate the appropriateness of the plan, emergency procedures, facilities, equipment, training of personnel, and overall effectiveness of the response. Deficiencies found by the critiques must be corrected.

Contrary to the above, on or before August 13, 2020, a deficiency identified in the 2019 NRC evaluated full-scale exercise critique was not corrected. Specifically, the licensee failed to correct a partially met exercise objective associated with the timely dispatch of radiation protection technicians in support of the fire brigade leader, incident commander, and on-scene responders. The critique deficiency was entered into the licensees CAP as part of EV 133623. This EV was subsequently closed on June 04, 2020. On August 13, 2020, during the annual emergency preparedness inspection, the inspectors identified that the licensee failed to complete any of the identified corrective actions listed in EV 133623. The inspectors identified that the failure to correct the critique deficiency was a violation of NRC requirements and the licensee entered the condition into their CAP as EV 139102. As a follow-up to the issue, the inspectors reviewed the corrective actions to ensure they were adequate to correct the noncompliance.

7 The corrective actions included: (1) RP technicians will be included in the ERO team callout group to ensure that they are notified of an emergency at the same time as the ERO, (2) licensee will determine the proper emergency response of the RP group when onsite vs. offsite, and (3) licensee will identify tasks that can be performed by RP task qualified individuals during the initial stages of an emergency. Any required revisions to existing procedural guidance will be captured in the CAP. The inspectors concluded that the corrective actions taken by the licensee were adequate to correct the noncompliance.

This violation is being treated as an NCV consistent with section 2.3.2.a of the NRC Enforcement Policy. This violation was entered into the licensees NRC approved CAP as EV 139102, and the violation was neither repetitive nor willful. This violation will be opened and closed as NCV 70-3101/2020-003-01, Failure to Correct a Deficiency Found During the Critique of an Emergency Exercise.

C.

Other Areas

1.

Corrective Action Program Implementation at Fuel Cycle Facilities (Inspection Procedure (IP) 88161) - Remote Inspection

a. Inspection Scope Policies, Programs, and Procedures The inspectors reviewed the QAPD, Performance Improvement Program (PIP) procedure, and other CAP implementing procedures. The inspectors reviewed the changes made to the CAP implementing procedures to verify that the procedures continued to incorporate the commitments in the QAPD and SAR. The inspectors verified that 10 CFR 70.72 evaluations were performed on the procedural revisions where required. The inspectors also verified that the procedures were being revised at the periodicity specified in the SAR.

Through document reviews and interviews, the inspectors verified the quality assurance (QA) departments involvement in revisions to PIP procedures and related policies. The inspectors reviewed samples of documented QA concurrence by verifying that AD-3-1000-01-F-1, Procedure Approval Form was appropriately reviewed by the QA department when procedures were revised.

Identification, Reporting and Documentation of Safety and Security Issues The inspectors verified that UUSA employees and contractors working under the UUSA QA program were trained on how to identify and enter items into the PIP. Based on interviews with a sample of personnel, employees were knowledgeable regarding use of the electronic corrective action system (ReAct), as well as other methods for entering safety or security concerns via electronic or paper form submission.

The inspectors also verified that UUSA had appropriate controls to ensure that conditions involving sensitive information was managed within the PIP. This entailed generation of an event report with a high-level description of the issue to ensure appropriate management of the issues evaluation, corrective action, tracking, and trending. Specifics of the sensitive or classified information could be cross-referenced in a protected manner outside the PIP system.

8 The inspectors interviewed a cross-section of site employees to determine whether those individuals were aware of the Employees Concerns Program (ECP) and comfortable with the avenues available to raise safety concerns. The discussions also addressed whether those individuals were aware of various locations on site that provided information on how to submit concerns anonymously, directly to ECP personnel and/or contact the NRC.

The inspectors interviewed 19 employees across multiple disciplines to determine if employees felt free to raise safety concerns to supervisory staff and were aware of their PIP responsibilities through training they had received as general employee training (GET). The inspectors interviewed the licensees ECP Manager and reviewed ECP procedures to determine whether the licensee had a process that established and maintained a positive safety culture commensurate with safety and security activities at the site.

The inspectors reviewed the most recent biennial assessment of the ECP as required by EC-3-1000-01, Employee Concerns Program, Rev. 14. The inspectors verified that the assessment was in accordance with NECE-GUID-002, Nuclear Employee Concerns Evaluation Program Evaluation Guidelines, Rev. 1, as stated in section 5.4 Performance and Trending of EC-3-1000-01.

Significance Assessment and Causal Evaluation of Safety and Security Issues The inspectors interviewed the Licensing and Performance Assessment Manager to understand PIP expectations and requirements. The PIP procedure provided the process for classifying the significance of issues associated with conditions adverse to quality, safety and security or significant conditions adverse to quality, safety and security. The inspectors reviewed a total of 65 event records (EVs) to ensure that the licensee appropriately classified the significance of conditions that were entered into the CAP. This included a range of significance categories covering business risk (BR),

adverse condition (AV), significant condition (SC). Causal evaluations performed for those items and activities were appropriate to the items significance and resulted in identification of the issue cause and extent of condition if applicable.

Development and Implementation of Corrective Actions The inspectors attended one event review screening meeting to determine whether the licensee was effective in the following:

a. Evaluating the actual and potential significance of conditions adverse to safety and security,

b. Classifying conditions as significant or non-significant, and

c. Applying a graded approach based on the issues significance, to the timing and scope of response to the issues, including the depth and detail of causal evaluations identifying problems.

9 The inspectors reviewed root cause evaluations (RCEs), detailed apparent cause evaluations (DACEs), apparent cause evaluations (ACEs), and business risk (BR) investigations to determine whether the licensee used a graded approach commensurate with significance. The inspectors reviewed the corrective actions from the reports to verify the actions were closed out in a timely fashion.

The inspectors verified both operational and security activities were adequately screened and assigned an appropriate investigation level that was commensurate with the significance of the problem, and resulting corrective actions were suitable to resolve the issues.

Assessment of Corrective Action and Program Effectiveness The inspectors reviewed PIP procedures and interviewed the PIP staff and UUSA employees to determine whether the licensee developed, implemented, and maintained an assessment process to evaluate the PIP effectiveness in the identification, reporting, assessment, and correction of safety and security issues to prevent the recurrence of the same issues or occurrence of similar issues.

The inspectors also reviewed selective events reports in security and operations to determine whether the following were implemented in the PIP:

a. A process for reviewing conditions adverse to safety and security to determine the existence of adverse trends and repetitive problems,

b. A process to evaluate the timeliness of PIP elements and the ability of the PIP to follow up and enable closure of corrective actions that are past their due date,

c. A process that evaluates the PIP effectiveness at regular, specified intervals,

d. A process that defines actions for the resolution of ineffective corrective actions, trends, and performance issues, and

e. A process that include measures to ensure that conditions and trends that are adverse to safety and/or security are reported to the appropriate level of management.

The inspectors also reviewed the QA department organization and procedures to determine if the licensees programmatic structure and auditing team were adequate to ensure the audit team was independent and remained free of influence from production management. The PIP programmatic activities were also audited to ensure compliance with procedures and license conditions. The inspectors reviewed samples of QA and PIP procedures and licensing documentation; and identified that the QA department reported to the Compliance Manager and Chief Nuclear Officer, who reported to the President and CEO of the company. This organizational structure provided separation from all production-related organizations and provided a high level of independence from production-related influences. In addition, the inspectors verified that the QA organization was periodically evaluated by an independent third-party auditor to ensure compliance with corporate policies and license conditions.

10 The inspectors also interviewed staff in charge of generating trend reports for the PIP to determine whether the process identified trends and significant conditions adverse to quality, safety and security to the appropriate levels of management. The inspectors reviewed the PIP to determine whether timeliness expectations were identified for event reports. The inspectors reviewed trend reports for calendar year 2019, to determine whether the licensee was adequately identifying and assessing operational trends and reporting negative trends to the responsible organization and senior management if applicable.

b.

Conclusion No violations of more than minor significance were identified.

2.

Follow-up on Previously Identified Issues

a. Unresolved Item (URI) 2019-004-03, Evaluate Removal of UBC Pad Fire Hydrants During a plant modifications inspection in 2019, the inspectors identified an Unresolved Item (URI) associated with cutting and capping of a fire line that serviced the north side of the uranium byproduct cylinder (UBC) Pad. Specifically, the licensee implemented a modification to increase the size of the UBC Pad by 50 ft on each end but failed to identify that the pad extension covered an existing fire line which is not permitted by National Fire Protection Association (NFPA) 24. As a result, the licensee cut and capped the fire line which resulted in the loss of all fire hydrants (4) located on the north side of the UBC Pad. The NRC questioned whether the remaining hydrants on the south side of the pad could provide complete coverage in the event of a fire as required by Section 7.5.1.1.1 of the SAR, which states, in part, that exterior fire hydrants, equipped with separate shutoff valves, are provided at intervals to ensure complete coverage of all facility structures including the UBC Pad. Specifically, the NRC was awaiting further information to determine if the (1) remaining fire hydrants can provide complete coverage of the UBC Pad, (2) UBC Pad is subject to the requirements of NFPA 24, and (3) licensee obtained proper approval for the change from the Authority Having Jurisdiction (AHJ) as required by NFPA 24. Specifically, Section 4.2.1 of NFPA 24 states, in part, Hydrants shall be located in a manner that will enable the needed fire flow to be delivered through hose lines to all exterior sides of any important structure.

Hydrants shall be spaced in accordance with the authority having jurisdiction. As a result, the NRC staff opened URI 70-3103/2019-004-003, Evaluate Removal of UBC Pad Fire Hydrants, to further evaluate information related to this issue.

As a follow-up to the URI, the inspectors reviewed the National Enrichment Facility UBC Pad Fire Water Supply Analysis performed by Veritas Fire Engineering, Inc. to determine if the four remaining fire hydrants located on the south side of the UBC Pad were capable of supplying the required fire flow to extinguish a fire located at the farthest point on the north side of the pad. The inspectors reviewed LES-0000-P-PID-694-001-01-08, Piping and Instrumentation Diagram Yard Fire Protection Water System, to determine if the Authority Having Jurisdiction (AHJ), the State of New Mexico, had provided the required approval of the change as required by NFPA 24. The inspectors also compared the length of hose carried on local fire department fire trucks to determine if it was capable of reaching the farthest location on the north side of the UBC pad.

11

b.

Conclusion The inspectors concluded that the four remaining fire hydrants on the South side of the UBC Pad were capable of providing complete coverage of the UBC Pad as required by NFPA 24 and Section 7.5.1.1.1 of the SAR. No violations of more than minor significance were identified. URI-2019-004-03, Evaluate Removal of UBC Pad Fire Hydrants, is considered closed.

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 and August 14, 2020 to Karen Fili, Managing Director UUSA and President and Chief Executive Officer LES. Proprietary information was discussed but not included in the report.

SUPPLEMENTAL INFORMATION 2

1. KEY POINTS OF CONTACT Name Title M. Bogenreider Shift Manager S. Cowne Chief Nuclear Officer (CNO)

A. Bixenman Licensing Specialist I J. Blackshear Decontamination & Recycling Manager J. Dahlin Safety and Emergency Response Manager S. Diggs Security Manager D. Foster Performance Assessment Analyst III D. Lemmons Fire Protection Engineering Supervisor B. Love Licensing Specialist II K. Miller Systems Engineering Supervisor W. Padgett Licensing and Performance Assessment Manager J. Rickman Licensing Specialist A. Riedy Consulting Engineer A. Rojas Fire Protection Engineer R. Shaefer Operations Manager M. Ward Performance Assessment N. Wells Quality Assurance/Employee Concerns Manager S. White Senior Safety and Emergency Preparedness Specialist

2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Closed 70-3103/2019-004-03 URI Evaluate Removal of UBC Pad Fire Hydrants (Section C.2)

Opened & Closed 70-3103/2020-003-01 NCV Failure to Correct a Deficiency Found During the Critique of an Emergency Exercise (Section B.1)

3. INSPECTION PROCEDURES USED 88050 Emergency Preparedness 88055 Fire Protection (Annual) 88161 Corrective Action Program (CAP) Implementation at Fuel Cycle Facilities

4. DOCUMENTS REVIEWED Records:

2017-0164 70.72(c) Evaluation for Proposed Change for CA-3-1000-01 CC-LS-2020-0002, Removal of Meteorological Tower & E-plan Update, Rev. 0, dated June 10, 2020 Emergency Operations Center Training, dated February 13, 2019 Emergency Plan Revision (Rev.) 26, dated January 23, 2019 Emergency Plan Rev. 27, dated June 19, 2020

3 Emergency Plan Overview Training, dated November 05, 2015 Emergency Preparedness Field Monitoring Team Training, dated 2011 Emergency Response Program Overview 2020 Refresher Mass Balance Verification (IROFSC22) Data Sheet for 1006, dated July 30, 2019 Transcript: Eric Carlson, dated August 12, 2020 Transcript: Holly Harvey, dated August 12, 2020 Transcript: Scott Diggs, dated August 12, 2020 UUSA Emergency Preparedness 2019 Drill Schedule UUSA Emergency Preparedness 2020 Schedule Rev. 2 UUSA ERO Duty Assignments, dated July 28, 2020 UUSA Emergency Preparedness NQA-1 Audit 2020-A-0-012, dated August 06, 2020 UUSA Organizational Chart, dated July 2020 UUSA Training Transcript Cory Criswell, July 15, 2020 UUSA Training Transcript George Donaldson, July 15, 2020 UUSA Training Transcript Christopher Pantoya, July 15, 2020 UUSA Training Transcript Jeremiah Sewell, July 15, 2020 WO 1000389499, 1Y; Purifier Load Trap LD Cell Cal WO 1000401262, 1006 CF2 Load Cell Troubleshoot Procedures:

AD-3-1000-01, Requirements for Program Documents, Rev. 34 CA-3-1000-01, Performance Improvement Program, Rev. 44 CA-3-1000-02, Apparent Cause Evaluation Guidelines, Rev. 10 CA-3-1000-03, Root Cause Evaluation Guidelines, Rev. 9 CA-3-1000-06, Event Review Board, Rev. 18 CA-3-1000-09, Assessment Program, Rev. 13 CA-3-1000-11, Differing Professional Opinions, Rev. 6EC-3-1000-01, Employee Concerns Program, Rev. 14 EAP05, Emergency Action Plan for the Cylinder Receipt & Dispatch Building (CRDB), Rev.

5 ESP-FPE-TQ (2), Engineering Support Program Fire Protection Engineer, Rev. 1 FP-1-1000-01, Fire Loss Prevention, Rev. 1 FP-2-1000-02, Fire Protection Program Requirements, Rev. 9 FP-3-1000-02, Flammable and Combustible Materials Control, Rev. 15 FP-3-1000-03, Fire Prevention During Welding, Cutting, and Other Hot Work, Rev. 13 FP-3-1000-04, Fire System or Feature Impairments, Rev. 19 FP-3-2000-04, IROFS 35 Weekly Fire Door Inspection and IROFS 36a Combustibles Control Inspection, Rev. 16 FPE-REV-001, Rev. 21 LS-3-1000-04, 10 CFR 70.72(c) Evaluations for Proposed Changes, Rev. 19 LO-3-2000-01, Receipt and Shipment of Cylinders, Rev. 21 MA-3-3000-08, Cold Trap Load Cell Calibration, Rev. 1 MC-3-6000-02, Tamper-Indicating Devices, Rev. 12 NECE-GUID-002, Nuclear Employee Concerns Evaluation Program Evaluation Guidelines, Rev. 1

4 OP-3-0400-05, Process Service Corridor Operations, Rev. 13 OP-3-0420-01, Product System, Rev. 51 OP-3-3300-01, Operations Surveillance Procedure, Rev. 38 TQ-3-0100-13, Training and Qualification Guidelines, Rev. 9 TQE-3-0100-03, Training and Qualification Guidelines, Rev. 10 Fire Impairments:

2014-0135, Rolling Fire Door Has Fusable Link Side Only 2016-0139, Unapproved Pen Seal in 65 Seals, 06/23/16 2018-064, Seals Identified w/o Proper Seal Material, 08/17/18 2020-014, Heat Detectors Non-Functional, 02/08/20 2020-015, Fire Water Testing, 2/25/20 EV 131848, Failed Drop Test (CRDB), 04/18/19 EV 133212, IROFS 35 Door w/Crack in the Door Shell 09/15/19 EV 134890, Damaged Threshold Failed Surveillance, 10/30/19 EV 137295, 5 YR Inspection Has Lapsed, 02/26/20 Condition Reports Written as a Result of the Inspection:

EV 138786, ECP Independent Assessment Recommendations EV 138788, Incomplete Revision to CA-3-1000-01 Performance Improvement Program EV 138791, Improvement Item - Potential Adverse/Negative Trend Standard EV 138808, NRC Comments on ECP independent assessment EV 138823, EV135015 Investigation Complete without Documented Actions EV 139071 EV 139078 EV 139081 EV 139102 EV 139103 EV 139108 EV 139111 EV 237600 Condition Reports Reviewed:

EV 123013, Crane lift performed without approved paperwork in place EV 124711, Correction Actions in EV 120009 Closed Prior to Completion EV 124725, RCE Actions Not Entered in ReAct EV 124736, ACE Actions Not Entered in ReAct EV 124984, Corrective Action Program Inspection - Minor Violation EV 126491, Calculation Error on IROFS54a/b Surveillance EV 126523, Increase in IROFS Related Event Reports EV 126528, 2T02 IROFS1 Station Trip During Disconnect EV 126873, IROFS Trip During Tails Station Operation EV 126925, IROFS24C Implementation and training for Radiation Protections Technicians EV 126994, Confusing Tare Weight Stamp EV 127025, Applicability of IROFSC22 EV 128531, Audit 2018-A-12-027 Finding 1: Work Order incorrectly classified.

EV 128590, PSC Procedure Conflicts with Use of Natural Feed

5 EV 128623, Adverse Trend Identified with Performing Investigations EV 129914, Negative Trend in Radiological Work Practices EV 129953, Questions regarding calibration of ATC-1 and ATC-2 EV 129994, Confusing Tare Weight Stamp EV 130003, Suspected Cause Investigation Incomplete for EV 126398 EV 130009, Improper Completion of IROFS16e Surveillance EV 130059, Off Gassing During 1S Decontamination EV 130061, BCI UUSA IROFSC22 NCSA-CSA-015 has Non-conservative Periodicities EV 131845, IROFS57 Calculation in Error EV 131890, Potential Non-conservatism in NCS-CSA-015 - Upset Cascade Enrichment %

EV 131917, Multiple Stamped Tare Weights EV 132392, Training Inconsistent with Implementing Documents EV 132565, Error Contained in URENCO CTG Input Data Used in NCS-CSA-015 for IROFSC22 EV 132603, Negative Trend Identified in IROFS Area EV 132753, 1006 Feed Cold Trap Load Cells EV 132796, Heeled 30B Cylinders with Shipper's Tamper-Indicating Devices (TID's)

EV 132806, Nuclear Material Not Controlled IAW the FNMCP EV 132848, Errors in Previous Annual RASCAL Maintenance Confirmations EV 132959, Local Tamper-Indicating Device (TID) Storage Lockers Found Unlocked EV 133037, HPE While Performing IROFS16e/f Surveillances EV 133305, Error in IROFS42 Narrative Log Entry for Product Cylinder Disconnect EV 133306, Incorrect Tare Weight Data Used for IROFS42 Surveillance EV 133324, Incorrect Tare Weight Data Used for IROFS42 Surveillance EV 133383, Tamper-Indicating Device (TID) Applied But Not Verified in SAP EV 133394, Incorrect Product Cylinder Tare Weight Used for IROFS16e/f Surveillance EV 133401, TID Ineffective EV 133463, Incorrect Tare Weight Used for IROFS42 Surveillance EV 133487, Wrong IROFS Used in IROFS42 Entry EV 133516, Trending Event Report for Contamination Events at UUSA EV 133521, 2nd and 3rd Quarter Potential Trend in IROFS Issues EV 133647, Missed Opportunities in the Corrective Action Prog EV 134742, IROFS16a/e/f Surveillance Question EV 134747, Misapplied TID EV 134778, What prevents product cylinder placement on UBC Storage Pad EV 134840, Independent Verification of 6F03 Empty Weight During Disconnect EV 134495 EV 135015, Wrong Empty Weights Used for the Connect Entries (16e/f)

EV 136210, Illegible Tare Weight Dates on Cylinder EV 136382, 1S Bottle Storage Cabinet SBDV Measurements Exceed Tolerances EV 136446, Cylinder Stamp Tare Weight does not Match Receipt Paperwork EV 136682, Red Monthly Limits Reached for Contamination Events and Radiological Practices EV 136720 EV 137028, Procedure Step Performed Incorrectly EV 137331, Incorrect Tare Weight Data Used for IROFS42 EV 137275 EV 137784 EV 137786

6 EV 137863, IROFS16e Procedure Inadequate EV 137994, 2020-A-04-009 Performance Assessment NQA-1 Audit Finding #1 EV 137995, 2020-A-04-009 Performance Assessment NQA-1 Audit Finding #2 EV 137996, 2020-A-04-009 Performance Assessment NQA-1 Audit Finding #3 EV 137997, 2020-A-04-009 Performance Assessment NQA-1 Audit Finding #4 EV 137998, 2020-A-04-009 Performance Assessment NQA-1 Audit Finding #5 EV 137999, 2020-A-04-009 Performance Assessment NQA-1 Audit Finding #6 EV 138000, 2020-A-04-009 Performance Assessment NQA-1 Audit Finding #7 EV 138412, Accident Sequence VR1-5 in ISAS does not say 7 Bar Test Rig is involved Other Documents:

2019 2nd Semiannual Trend Report, dated February 07, 2020 Assessment of Adverse Condition ACEs and Suspect Causes conducted after 6/1/18, Assessment# SA-2018-012, dated December 14, 2018 ECP KPIs for June 2020 EG-TQ-2019-001 Technical Questions, dated March 28, 2019 Extract for NCS-CSA-015 from UUSA-G-Cal-1-14-008868 Issue 7, dated June 18, 2019 LES-0000-P-PID-694-001-01-08, Piping and Instrumentation Diagram Yard Fire Protection Water System SA-2019-005, Fire Protection 2019 Self-Assessment Report, 04/19/19 National Enrichment Facility, UBC Pad Fire Water Supply Analysis, 02/18/20 NEF-BD-C22, Verify Subcriticality by Mass Balance Calculation, Rev. 13 ReAct Reporter Training, Rev. 3 Root Cause Evaluation Report: EV 129970, Rev. 1, dated February 11, 2019 Root Cause Evaluation Report for UUSA 30B Cylinder Drop EV 131808, dated May 17, 2019 Quality Assurance Program Description, Rev. 42 Safety Analysis Report, Rev. 47b Urenco USA 2019 General Employee Training, dated July 24, 2020 UUSA Audit Number 2020-A-04-009, Report for UUSA Louisiana Energy Services, LLC, Performance Assessment NQA-1 Audit, dated May 19, 2020 UUSA Organization Chart, dated May 06, 2020 UUSA SAFETY CULTURE ASSESSMENT with 2014 - 2019 Comparisons dated October 8, 2019 Work Orders:

WO1000353232, 5Y: Sec Fire Insp Mech, 08/10/19 WO1000372749, 5Y: FWPH Fire Insp, 01/07/20 WO1000392061, 1W: IROFS 35 Fire Doors Inspect, 08/15/19 WO1000392604, 6M: Fire Water Tank Maint (1B1/2B1), 08/24/19 WO1000395648, 3M: Inventory Fire Brigade Trailer 08/28/19 WO1000395651, 1M: CRDB Fire Extinguishers, 08/18/19 WO1000395750, 1Y: Fire Extinguisher Inspections, 09/16/19 WO1000396626, 1Y Fire Hose Pressure Test (D), 08/31/19 WO1000401267, 3M: Review Fire Impairments, 09/01/19 WO1000403995, 1W: IROFS 35 Fire Doors Inspect, 10/21/19 WO1000438216, 1W: EFWP Manual Start, 08/03/20 WO1000438222, 1W: DFWP Manual Start, 08/03/20 WO1000421564, 1Y: Test CRDB Emergency Light/Exit Signs, 05/15/20