ML21139A178

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Global Nuclear Fuel Americas Confirmation of Implementation of Confirmatory Order EA-17-090 Report 07001113/2021006
ML21139A178
Person / Time
Site: 07001113
Issue date: 05/19/2021
From: Laura Dudes
Region 2 Administrator
To: Nay D
Global Nuclear Fuel
References
EA-17-090 IR 2021006
Download: ML21139A178 (10)


Text

EA-17-090 May 19, 2021 Mr. Doug Nay Facility Manager Global Nuclear Fuel-Americas, L.L.C.

P.O. Box 780, Mail Code J20 Wilmington, NC 28402

SUBJECT:

GLOBAL NUCLEAR FUEL - AMERICAS - CONFIRMATION OF IMPLEMENTATION OF CONFIRMATORY ORDER EA-17-090 REPORT 07001113/2021006

Dear Mr. Nay:

This letter refers to inspections conducted from December 14, 2017 through December 31, 2020, at the Global Nuclear Fuel-Americas, L.L.C. (GNF-A) facility in Wilmington, NC. The purpose of this report is to acknowledge GNF-As letter dated March 5, 2020, detailing completion of required actions in Section V of Confirmatory Order (CO) EA-17-090 (Agencywide Documents Access and Management System (ADAMS) accession number ML17348A144), and to document completion of the NRCs inspections of your actions required by the CO.

The enclosed inspection report presents the results of this inspection and summarizes the results of previous inspections of CO commitments. The inspectors discussed their findings with members of your staff on May 11, 2021.

Based on the cumulative results of these inspections, the NRC has verified that the commitments detailed in the CO have been implemented and that no violations of more than minor significance were identified.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document

D. Nay 2 Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Laura A. Dudes Regional Administrator Docket No. 07001113 License No. SNM-1097

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML21139A178 SUNSI Non-Sensitive Publicly Available Review Sensitive Non-Publicly Available OFFICE RII: DFFI RII: DFFI RII: DFFI RII: EICS RII: ORA J. Munday for NAME M. Ruffin R. Williams L. Suggs M. Kowal L. Dudes DATE 5/10/2021 5/12/2021 5/17/2021 5/14/2021 5/19/2021 U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT REGION II Docket Number: 07001113 License Number: SNM-1097 Report Number: 07001113/2021006 Enterprise Identifier: I-2021-006-0061 Licensee: Global Nuclear Fuel - Americas, L.L.C.

Facility: Global Nuclear Fuel - Americas Location: Wilmington, NC 28402 Inspection Dates: December 14, 2017 to December 31, 2020 Inspectors: L. Pitts, Sr. Fuel Facility Projects Inspector Approved By: Laura A. Dudes, Regional Administrator Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) conducted inspections during normal shift operations in areas associated with Confirmatory Order EA-17-090 at Global Nuclear Fuel -

Americas, in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities. Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.

List of Violations No violations of more than minor significance were identified.

Additional Tracking Items Type Issue Number Title Report Section Status Confirmatory Order from OR 07001113/2019003-01 successful ADR (EA-17-090) 92702 Closed 2

REPORT DETAILS 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 fuel fabrication operations. During the inspections, normal production activities at the facility were ongoing.

INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Inspections were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER AREAS A. 92702 - Follow-Up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, and Orders

1. Review of Confirmatory Order Section V Item 9
a. The inspectors reviewed the licensees actions regarding CO (ML17348A144),Section V, Item 9. This item required that the licensee submit a letter to the NRC discussing its basis for concluding that the CO had been satisfied. The letter was to be provided within three months of completing implementation of the terms of the CO. On March 5, 2020, GNF-A provided the NRC with a letter discussing its basis for concluding that the Confirmatory Order (CO) has been satisfied (ML20065J964). The NRC acknowledges the receipt of this letter and inspectors have verified that the corrective actions detailed in Section V of the CO were implemented as described. The results of these inspections are detailed in the following sections of this report.

b. Conclusion

Based on the review of all completed actions, the NRC concludes that GNF-A has completed implementation of actions detailed in CO Section V. The licensee has met the requirements stated in CO Section V, Item 9, and this item is considered closed.

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B. Summary of Completed Confirmatory Order Commitments The table below lists modifications to the SNM-1097 license as required by the CO and the corresponding inspection report which details the NRCs inspection of the CO Item:

CO Item Description Due Date Inspection Report (NOTE 1)

CO V.1 GNF-A will make a report to the NRC 01/13/2018 IR 2017-005 Operations Center, pursuant to 10 CFR 20.1906(d)(1), stating that the NRC has concluded that GNF-A received a package on September 29, 2016, which had removable radioactive surface contamination on its 8 external surfaces that exceeded the applicable limits set forth in 10 CFR 71.87(i).

CO V.2 GNF-A shall install a vehicle portal 12/14/2018 IR 2019-003 monitor with a sensitivity to detect vehicle surface radiation levels specified in 10 CFR 20.1301(a)(2). GNF-A agrees to continue to perform surveys for unrestricted release in accordance with the License Application Section 1.3.2. 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.

Once installed, if for any reason the vehicle portal monitor is not available, compensatory measures shall be taken by GNF-A to detect non-manifested vehicle shipments in excess of radiation levels of 10 CFR 20.1301(a)(2).

CO V.3 GNF-A shall make the results of the Nuclear 02/12/2018 IR 2018-002 Safety Culture (NSC) assessment of the Wilmington site available to the NRC for review.

CO V.4 GNF-A shall conduct a NSC assessment of the 06/14/2020 IR 2020-001 GNF-A organization by a third-party independent of GNF-A who is experienced with NRC nuclear safety culture and safety conscious work environment policies. GNF-A shall compare the results of this assessment to the results of the assessment performed under Section III.3.g of this CO in an effort to identify trends. Corrective actions arising from the assessment and comparison will be entered into the corrective action program and tracked to completion. GNF-A shall make results of the final assessment and comparison available to the NRC for review.

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CO V.5 GNF-A shall augment, with the assistance of an 09/14/2018 IR 2018-005 individual independent of GNF-A who is experienced with NRC nuclear safety culture and safety conscious work environment policies, its existing training for all workers with unescorted access to the GNF-A Controlled Access Area, that reinforces nuclear safety culture traits emphasizing questioning attitude, problem identification, effective corrective actions, and effective self-assessment. Training records shall be retained consistent with applicable GNF-A record retention policies and shall be made available to the NRC upon request. New employees shall complete the training prior to the granting of unescorted access to GNF-A. This training shall be provided on an annual basis, for at least three years after issuance of the CO.

CO V.6 GNF-A shall conduct a benchmark assessment 12/14/2018 IR 2018-005 of the GNF-A Radiation Protection Program (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 RP program.

The benchmark assessment shall be performed by an individual or entity experienced in Institute of Nuclear Power Operations (INPO) radiation protection standards, and the assessment shall be made available for NRC review.

CO V.7 GNF-A shall expand its Difference of 12/14/2018 IR 2019-005 Professional Opinion process to include all technical safety matters related to GNF-A licensed activities.

CO V.8 Existing GNF-A supervisors engaged in licensed 12/14/2018 IR 2020-004 facility (SNM-1097) activities, as of the date of issuance of the CO, will complete initial Front Line Supervisor Nuclear Safety Leadership training, which will be informed by INPO 04-003, Guidelines for Effective Nuclear Supervisor Performance. For a period of three years after issuance of the CO, new GNF-A frontline supervisors engaged in licensed facility (SNM-1097) activities shall complete this training within six months of assuming supervisory responsibilities. GNF-A shall make the training materials available to the NRC for review.

CO V.9 Within three months of completion of the terms CO IR 2021-006 of this CO, GNF-A shall provide the NRC with a completion letter discussing its basis for concluding that the + 3 months CO has been satisfied.

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NOTE 1: ADAMS accession numbers and hyperlink to documents are included in the supplemental information section of this report.

INSPECTION RESULTS No issues were identified.

EXIT MEETINGS AND DEBRIEFS The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

  • On May 11, 2021, the inspectors discussed the Confirmation of Implementation of Confirmatory Order EA-17-090 inspection results to Scott Murray and other members of the licensee staff.

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LIST OF PUBLICLY AVAILABLE DOCUMENTS IN ADMAS ASSOCIATED WITH THE CO Inspection Report Number ADAMS ML Number and Hyperlink Confirmatory Order ML17348A144 Consent and Hearing Waiver ML17348A146 IR 2017-003 ML17348A132 IR 2017-005 ML18022A064 IR 2018-002 ML18115A121 IR 2018-005 ML19028A028 IR 2019-003 ML19213A337 IR 2019-005 ML20031D503 IR 2020-001 ML20121A038 IR 2020-004 ML21032A115 Verification of Completion ML20065J964 7