ML21210A010

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Urenco USA (Uusa) - Integrated Inspection Report 07003103/2021002
ML21210A010
Person / Time
Site: 07003103
Issue date: 07/29/2021
From: Robert Williams
NRC/RGN-II/DFFI
To: Padgett W
Louisiana Energy Services, URENCO USA Energy Services
References
IR 2021002
Download: ML21210A010 (26)
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Text

July 28, 2021 Mr. Wyatt Padgett Compliance and Licensing Manager LOUISIANA ENERGY SERVICES (LES) dba URENCO USA (UUSA)

URENCO USA P.O. Box 1789 Eunice, NM 88231

SUBJECT:

URENCO USA (UUSA) - INTEGRATED INSPECTION REPORT 07003103/2021002

Dear Mr. Padgett:

On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at URENCO USA (UUSA) and discussed the results of this inspection with Mr. Wyatt Padgett and other members of your staff. The results of this inspection are documented in the enclosed report.

No violations of more than minor significance were identified during this inspection.

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

Sincerely,

/RA/

Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07003103 License No. SNM-2010

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML21210A010 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI NAME B. Adkins L. Cooke R. Williams DATE 07/23/21 07/26/21 07/28/2021 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07003103 License Number: SNM-2010 Report Number: 07003103/2021002 Enterprise Identifier: I-2021-002-0117 Licensee: LOUISIANA ENERGY SERVICES (LES) dba URENCO USA (UUSA)

Facility: URENCO USA (UUSA)

Location: Eunice, NM Inspection Dates: April 5 - 8 and May 3 - 6, 2021 Inspection Completion Date: June 30, 2021 Inspectors: B. Adkins, Sr. Fuel Facility Projects Inspector L. Cooke, Fuel Facility Inspector P. Glenn, Fuel Facilities Inspector G. Goff, Fuel Facilities Inspector Approved By: Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Enclosure

SUMMARY

The U.S. NRC continued monitoring the licensees performance by conducting an integrated inspection at URENCO USA (UUSA), 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 URI 07003103/2021002-01 Independence of the 88020 Open Radiation Protection Program 2

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.

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.

SAFETY OPERATIONS IP 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety (NCS) program as part of a remote inspection to verify compliance with selected portions of 10 CFR 70, Chapter 5, Nuclear Criticality Safety, of the facilitys Safety Analysis Report (SAR), and applicable licensee procedures.

Criticality Analysis (IP Section 02.01)

The inspectors interviewed licensee staff and reviewed nuclear criticality safety evaluations (CSEs), and associated assumptions and calculations to verify compliance with 10 CFR 70 and applicable sections of the SAR. Specifically, the inspectors interviewed licensee staff and reviewed the following CSEs associated systems related to decontamination, recycle, and rad waste operations:

  • NCS-CSA-031, "NCSA of the Small Component Decontamination Train (SCDT)"
  • NCS-CSA-037, "NCSA of the Slab Tanks"
  • NCS-CSA-035, "NCSA of the Multifunctional Decontamination Train (MFDT)"

Criticality Implementation (IP Section 02.02)

The inspectors selected controls from the licensees integrated safety analysis (ISA) summary and or CSE/A to verify proper implementation through a review of process and system descriptions, and operator interviews to verify compliance with 10 CFR 70 and applicable sections of the SAR. Specifically, the inspectors interviewed licensee staff and reviewed the following controls, and their management measures, associated with the CSEs above and selected areas:

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  • passive engineered design features for the gaseous effluent vent system (GEVS) to prevent loss of safe by design features and supports items relied on for safety (IROFS) 24b
  • administrative measures for accident sequence DS7-1 related to the decontamination workshop to prevent an over mass
  • passive engineered design features for solid waste containers associated with accident sequence SW1-4 to prevent accumulation of uranium mass
  • IROFS 54a, 54b, 24b Criticality Operational Oversight (IP Section 02.03)

The inspectors assessed the NCS staffs oversight of plant operators, procedures, and operations of systems involving special nuclear material to verify compliance with 10 CFR 70 and applicable sections of the SAR. Specifically, the inspectors performed the following activities:

  • Reviewed select IROFS and NCS training documents for recycle and rad waste operations and interviewed two operators assigned to those areas
  • Interviewed NCS staff concerning criticality hazards and control methods
  • Interviewed a licensee NCS engineer who conducted a weekly NCS audit and reviewed the resulting audit report
  • Interviewed recycle and rad waste area operators concerning criticality hazards and control methods, including the use of system IROFS during operations Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures, audits, and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the SAR. Specifically, the inspectors interviewed licensee NCS staff and or reviewed the following documents:

  • NCS NQA-1 Audit 2021-A-01-002
  • NCS procedure CR-3-1000-01, Verification for Implementation of NCS Evaluations and Analysis, Rev. 8
  • Revised NCS CSEs that include NCS-CSE-026 related to the Sample Bottle Outgassing Station and NCS-CSA-007 related to GEVS Units in the Separations Building Modules (SBM)
  • Interviewed NCS manager and NCS staff in training Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees incident response and corrective action programs (CAP) to verify compliance with 10 CFR 70 and applicable sections of the SAR including Chapter 11.6, "Incident Investigations and Corrective Action Process." Specifically, the inspectors reviewed documents and or interviewed licensee staff concerning the following:

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  • Corrective actions as documented in the "Documents Reviewed" section of the report
  • Response to Nuclear Criticality Safety Anomalous Condition or Criticality Accident Procedure CR-3-1000-04
  • Criticality Emergency Response Procedure EP-3-0200-10 IP 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees Operational Safety program as part of an onsite inspection to verify compliance with selected portions of 10 CFR 70, including 70.61, 70.62, and Chapter 11, Management Measures, of the facilitys license application, and applicable licensee procedures.

Identification of Safety Controls and Related Programs (IP Section 02.01)

The inspectors selected specific process areas for inspection based on the safety basis information of the facility, the risk/safety significance of the process areas, the description of plant changes submitted to the NRC, and past plant performance documentation. For the process areas of interest, the inspectors selected a sample of accident sequences in nuclear criticality safety, radiation safety, fire safety, and chemical safety based on the information provided in the ISA summary. The inspectors conducted a general plant tour of each major plant operating area. The process areas and accident sequences selected for review are listed below:

  • Process areas reviewed include the Cylinder Receipt and Dispatch Building (CRDB) and the Separations Building Module 1003
  • Accident Sequence TT2-1, Low temperature takeoff station defrost heater controller fails causing heater to remain on and subsequent cylinder failure and release of UF6
  • Accident Sequence FF15-1, External fire propagation into the UF6 handling area
  • Accident Sequence FF16-1, Fire within the UF6 handling area that results in failure of single cylinder hose
  • Accident Sequence FF16-2, Fire within the UF6 handling area that results in failure of the aluminum piping manifold and 50% inventory release
  • Accident Sequences PB2-6 and PT2-5, Hydrocarbon oil (a moderator) used in place of perfluoropolyether (PFPE) oil during maintenance of vacuum pumps
  • Accident Sequence SW1-4, Accumulation of sufficient uranic mass to cause a criticality in removed filter media
  • Accident Sequence SW2-1, Accumulation of sufficient uranic mass to cause a criticality in a non-safe by design solid waste container
  • Accident Sequence PT5-1, Incorrect sampling sequence resulting in excessive flow of UF6 failing the vacuum pump seals and releasing UF6 Review of Safety Controls and Related Programs (IP Section 02.02)

The inspectors reviewed information related to administrative, enhanced administrative, engineered, high availability engineered, and passive safety controls or IROFS for the 5

accident sequences selected above, including the identification of the licensees assumptions and bounding cases as they apply to each of the selected accident sequences, safety controls, or IROFS. This review was performed to verify that the controls or IROFS were available and reliable to perform their intended safety functions and that the design basis assumptions were reflected in the actual conditions in the field. The specific safety controls selected for review are listed below:

  • IROFS1, Automatic Trip of an SBM-1001 or SBM 1003 defrost heater and fan on high station internal air temperature to ensure cylinder integrity (hardwired resistance temperature detector (RTD) sensor), active engineered control, chemical safety
  • IROFS2, Automatic Trip of an SBM-1001 or SBM 1003 defrost heater and fan on high station internal air temperature to ensure cylinder integrity (hardwired thermocouple sensor), active engineered control, chemical safety
  • IROFS30a, Limit Hydrocarbon Oil by Controlling Type Used, administrative control, criticality safety
  • IROFS30b, Limit Hydrocarbon Oil by Testing Prior to Adding to Pump, administrative control, criticality safety
  • IROFS30c, Limit Hydrocarbon Oil by Testing Prior to Operation, administrative control, criticality safety
  • IROFS31a/b, Limit Uranic Mass Inventory in Non-Safe-By-Design Solid Waste Containers, administrative control, criticality safety
  • IROFS35, Fire Rated Barriers, active engineered control with high availability, fire safety
  • IROFS36a, Limit Transient Combustible Loading in Uranic Areas, sole and enhanced administrative control, fire safety
  • IROFSC21, Flow Restriction for Vacuum Pumps Used for Sampling or Evacuation, passive engineered control (sole IROFS), criticality safety Implementation of Safety Controls (IP Section 02.03)

For the selected safety controls listed above, the inspectors reviewed management measures to verify proper implementation in accordance with 10 CFR 70 and applicable sections of the license application. This review was performed to verify that selected safety controls or IROFS were present, available, and reliable to perform their safety function and that the design basis assumptions were reflected in the actual conditions in the field. The inspectors conducted the following activities to verify the implementation of selected safety controls:

  • observed implementation of the weekly IROFS 36a combustible control inspection in SBM-1003
  • observed implementation of the annual IROFS1 and 2 station heater and fan high temperature trip interlocks for station 1002-434-5B3
  • reviewed calibration records for measuring & test equipment (M&TE) used for functional check and calibration of IROFS1 and 2 interlocks
  • reviewed IROFS30 hydrocarbon oil testing records and observed storage of oil
  • observed implementation of IROFS31 through storage and U-235 mass analysis records for solid waste and trap material 6
  • reviewed installation records for IROFSC21 flow restriction devices Safety Control Support Programs (IP Section 02.04)

The inspectors assessed additional management measures and licensees measures that support the availability and reliability of the selected safety controls to verify these were implemented in accordance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors conducted the following:

  • reviewed weekly inspection records/WOs for IROFS35 fire doors in the CRDB and SBM conducted in March 2021
  • reviewed failure and degradation records for IROFS 1, 2, 30, 35, 36a, and C21
  • reviewed CAP entries/documents for IROFS 1, 2, 30, 35, 36a, and C21
  • reviewed NQA-1 audit 2020-A-10-018 related to implementation of IROFS
  • reviewed NQA-1 audit 2020-A-06-011 related to procedures
  • reviewed quality assurance audits performed on procedures and M&TE
  • reviewed qualification and training documents for one control room/building operator
  • discussed IROFS training and qualification with operators regarding IROFS 30, 31, and 36
  • interviewed the UUSA Operations Manager to discuss recent organizational changes and operator qualification
  • attended the UUSA plan of the day meeting on 05/05/2021
  • observed operations evening shift turnover on 05/04/2021
  • discussed timeliness of closing out open fire protection system impairments with UUSA management RADIOLOGICAL CONTROLS IP 88030 - Radiation Protection The inspectors evaluated selected aspects of the licensees Radiation Protection (RP) program as a partially onsite partially remote inspection to verify compliance with selected portions of 10 CFR 19, 20, 40, 61, and 70, Chapter 4, Radiation Protection, of the facilitys SAR, and applicable licensee procedures.

Radiation Protection Program Implementation (IP Section 02.01)

The inspectors interviewed licensee staff and reviewed licensee procedures and other documentation related to the implementation of the RP and radioactive waste programs to verify compliance with 10 CFR 20.1101(a) and applicable sections of the SAR Chapter 4 -

Radiation Protection. Specifically, the inspectors reviewed documents and interviewed licensee staff concerning the following:

  • RP-2-1000-01, Radiation Protection Program, Rev. 11
  • RP-2-1000-02, ALARA Program, Rev. 7 7
  • RP-3-3000-08, Bioassay, Rev. 9 Radiation Protection Program Review (IP Section 02.02)

The inspectors reviewed the licensees as low as reasonably achievable (ALARA) Reports, audits, and self-assessments to verify compliance with 10 CFR 20.1101, 20.2102, and Chapter 4 of the SAR. Specifically, the inspectors reviewed the following:

  • 2019-A-12-020, UUSA Radiation Protection Program NQA-1 Audit
  • 2021-A-12-020, UUSA Radiation Protection Program NQA-1 Audit
  • 2019-A-04-006, Radioactive Waste Management NQA-1 Audit
  • 2020-S-02-001, Surveillance of Recycling Related IROFS Requirements Flowdown
  • QA-3-2000-01, Quality Assurance Audit, Rev. 23 Radiation Protection and Radioactive Waste Procedures (IP Section 02.03)

The inspectors assessed the licensees review and implementation of RP related changes to the plant and procedures to verify compliance with 10 CFR 70.72, Chapters 4 and 11 of the SAR, and AD-3-1000-01, Requirements for Program Documents. Specifically, the inspectors completed the following activities:

  • reviewed RP-3-2000-02, Radiological Postings and Access Controls, Rev. 19
  • reviewed RP-3-1000-05, Annual ALARA Report, Rev. 0
  • reviewed RP-3-2000-07, Contaminated Individual Response, Rev. 12
  • reviewed NEF-BD-23b, Personal Respiratory Use for Handling Designated Uranic Material in the CRDB, Rev. 3
  • reviewed NEF-BD-24a, Establishment of Airflow Away from the Worker for Handling Designated Uranic Material in the CRDB, Rev. 3
  • walked down solid waste collection system (SWCS) 3 and 4
  • interviewed rad waste manager regarding categorization and shipment of waste
  • observed implementation of IROFS 55a, 55b, 58a, and 58b Training (IP Section 02.04)

The inspectors reviewed RP and radioactive waste related training records, training material, and procedures to verify compliance with 10 CFR 19.12, 19.13, 70.61(f)(2), Chapter 4 of the SAR, and TQ-3-1000-12, Training Guidelines, Rev. 5. Specifically, the inspectors reviewed the following training records for three recycling technicians, two RP technicians, and four RP task qualified individuals:

  • GWRECTECH UUSA Recycling Technician Qualification Standard, Rev. 2
  • RP-RPTQC, Radiation Protection Technician Qualification Card, Rev. 3
  • RPTQIQC00, Radiation Protection Task Qualified Individual, Rev. 5
  • records of fit testing for respirators 8

Safety-Significant Events (IP Section 02.05)

The inspectors reviewed the licensees review of safety-significant events and RP and radioactive waste related CAP entries to verify compliance with 10 CFR 20.2201, 20.2202, 20.2202(a), 20.2202(b), 20.2203, 70.50, 70.52, 70.74, Part 70 Appendix A, and Chapters 4 and 11 of the SAR. Specifically, the inspectors reviewed documents and interviewed licensee staff concerning the following:

  • EV 141584
  • EV 140210
  • EV 140786
  • EV 141551
  • EV 142980
  • EV 140657
  • EV 140786
  • EV 141583
  • EV 141584
  • EV 141585 Radiation Work Permits (IP Section 02.06)

The inspectors interviewed licensee staff and reviewed radiation work permits (RWPs) to verify compliance with the SAR Chapter 4.4.1. Specifically, the inspectors observed work performed under the following RWPs:

  • RWP 21-001, General Facility Access for Inspections, Tours, Planning, and Surveillances
  • RWP 21-003, Routine RP Group Activities
  • RWP 21-005, Routine Maintenance and Facilities Group Activities Instrument Calibration (IP Section 02.07)

The inspectors interviewed licensee staff and reviewed licensee procedures for RP instrument calibration to verify compliance with 10 CFR 20.1501(c) and Chapter 4.7 of the SAR. Specifically, the inspectors observed calibration stickers and reviewed records for the following equipment:

  • alpha, beta, and gamma detectors
  • Tennelec analyzers
  • fixed and portable air monitors
  • criticality accident alarm system (CAAS)

Instruments and Equipment (IP Section 02.08)

The inspectors interviewed licensee staff and reviewed the licensee's use of radiation detecting instruments and equipment to verify compliance with 10 CFR 20.1501(a),

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70.24(b), and Chapter 4.8.4 of the SAR. Specifically, the inspectors observed the operability range and usage of the following equipment:

  • hand-held survey meters
  • hand and foot monitors
  • personnel contamination monitors Posting (IP Section 02.09)

The inspectors observed the posting of radiation areas and radioactive material storage areas to verify compliance with 10 CFR 20.1902, 20.1903, and Chapter 4.7.3 of the SAR. Specifically, the inspectors observed postings in the following areas:

  • radiation area posting in the entry way to the CRDB processing areas
  • internal contamination postings on the trains in the SCDT
  • radiation area postings in various locations throughout the CRDB
  • contamination posting in the chemistry laboratory Container Labeling (IP Section 02.10)

The inspectors observed the labeling of packages and containers that contain radioactive material to verify compliance with 10 CFR 20.1905 and Chapter 4.7.3 of the SAR. Specifically, the inspectors observed the following types of labels:

  • storage areas in the CRDB for containers that may contain radioactive material
  • signs with the wording "Caution Radioactive Material"
  • an exemption to labeling each container that may contain radioactive material as per 10 CFR 20.1905 Posting of Notices (IP Section 02.11)

The inspectors observed the Posting of Notices to verify compliance with 10 CFR 19.11. Specifically, the inspectors observed notices in the following areas:

  • the security entrance/exit area
  • an external warehouse
  • an external office area near the above warehouse Access Control (IP Section 02.12)

The inspectors observed the licensee's access control measures to radiation areas to verify access was in compliance with Chapter 4.7.2 of the SAR. Specifically, the inspectors observed:

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  • access to radiation areas is posted with signage bearing the radiation trefoil and wording, "CAUTION - RADIATION AREA" - in magenta lettering on a yellow background
  • reading and signing the appropriate RWP was required prior to entry
  • procuring a electronic dosimeter was required prior to entry Licensed Material Control (IP Section 02.13)

The inspectors observed the licensees measures to control and maintain constant surveillance of licensed material not in storage to verify compliance with 10 CFR 20.1802. Specifically, the inspectors observed that SNM was stored in labeled containers behind yellow/magenta rope with proper radiological postings in the following areas:

  • CRDB
  • SBM 1003 Radiation Surveys (IP Section 02.14)

The inspectors interviewed licensee staff and reviewed records of external radiation surveys to verify compliance with 10 CFR 20.1501(a), 20.2103, Chapter 4.7 of the SAR, and procedure RP-3-2000-04 (Radiation and Contamination Surveys). Specifically, the inspectors interviewed staff and reviewed radiation surveys related to the following areas:

  • CRDB
  • SBM 1005 Contamination Control (IP Section 02.15)

The inspectors interviewed licensee staff and reviewed records of the licensees contamination control measures to verify compliance with 10 CFR 20.1501(a), Chapter 4.8.1.2 and 4.8.5.1 of the SAR, and procedure RP-3-2000-04, Radiation and Contamination Surveys. Specifically, the inspectors observed activities related to the following:

  • equipment used to measure the contamination levels was within calibration
  • contamination surveys in the CRDB
  • observed air filter change-outs on continuous air samplers of the CRDB Sealed Sources (IP Section 02.16)

The inspectors observed the storage and control of NRC-licensed sealed sources and reviewed records of leak checks to verify compliance with 10 CFR 20.1903(c) and SAR Chapter 4.11.1. Specifically, the inspectors observed or reviewed the following:

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  • the storage room for sealed sources
  • several sealed and unsealed sources listed as NRC-licensed sources
  • reviewed the last two years of leak test records Occupational Dose Results (IP Section 02.17)

The inspectors reviewed records of the occupational doses received by workers to verify compliance with 10 CFR 20.1201, 20.1207, 20.1208, and Chapter 4 of the SAR. Specifically, the inspectors reviewed the following:

  • Occupational Radiation Exposure Report dated 02/05/2020
  • Occupational Radiation Exposure Report dated 05/07/2020
  • Occupational Radiation Exposure Report dated 08/10/2020
  • Occupational Radiation Exposure Report dated 10/09/2020 Exposure Controls (IP Section 02.18)

The inspectors observed engineering controls used to keep doses ALARA by controlling the air flow from areas of lesser contamination to areas of higher contamination in order to verify compliance with 10 CFR 20.1101(b), 20.1701, and Chapters 4.6 and 4.8 of the SAR. Specifically, the inspectors observed:

  • chemical hoods and gloveboxes were maintained at a slightly negative air flow compared to the air flow outside of these units
  • the GEVS for the CRDB was routed through a bank of pre-filters and high efficiency particulate air (HEPA) filters prior to being discharged through an exhaust stack
  • verified IROFS 24b was implemented

The inspectors interviewed licensee staff and reviewed the bioassay program to verify compliance with 10 CFR 20.2103(b)(3) and Chapter 4 of the SAR. Specifically, the inspectors interviewed licensee staff, and reviewed records related to the following:

  • Uranic Bioassay Analysis Results dated 11/16/2020
  • Cardinal Labs Bioassay Analysis dated 02/18/2021
  • RP-3-4000-F-1, Dose Evaluation Report 2020-001 dated 04/17/2020 Whole Body Counting (IP Section 02.20)

The inspectors verified that this section was not applicable as the licensee does not use whole body counters as a means of in vivo counting.

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Dosimetry (IP Section 02.21)

The inspectors observed that dosimetry was properly worn my workers and reviewed dosimetry records to verify compliance with 10 CFR 20.1502(a) and the applicable RWPs 20.1501(d) and Chapter 4.7.5 of the SAR. Specifically, the inspectors reviewed the following:

  • Occupational Radiation Exposure Report dated 02/05/2020
  • Occupational Radiation Exposure Report dated 05/07/2020
  • Occupational Radiation Exposure Report dated 08/10/2020
  • Occupational Radiation Exposure Report dated 10/09/2020
  • Dosimetry worn by licensee personnel working in SNM areas Dose Assessment Programmatic Review (IP Section 02.22)

The inspectors interviewed licensee staff and reviewed records and calculations related to the licensees assessment of the dose to workers to verify compliance with 10 CFR 20.1202, 20.1204, 20.1502(b), 20.2104, and 20.2106, as well as Chapter 4 of the SAR. Specifically, the inspectors interviewed licensee staff and reviewed records related to the following:

  • Uranic Bioassay Analysis Results dated 11/16/2020
  • Cardinal Labs Bioassay Analysis dated 02/18/2021
  • RP-3-4000-F-1, Dose Evaluation Report 2020-001 dated 04/17/2020
  • Radiation Safety Committee Minutes 10/22/2020
  • Radiation Safety Committee Minutes 04/24/2020 As Low As Reasonably Achievable (ALARA) (IP Section 02.23)

The inspectors interviewed licensee staff and reviewed records related to the implementation of the ALARA program to verify compliance with 10 CFR 20.1101(b) and Chapter 4 of the SAR. Specifically, the inspectors interviewed licensee staff and reviewed records related to the following:

  • Annual ALARA Report CY2019, Rev. 0
  • Radiation Safety Committee Minutes 10/22/2020
  • Radiation Safety Committee Minutes 04/24/2020 FACILITY SUPPORT IP 88070 - Permanent Plant Modifications The inspectors performed onsite follow-up to the remote Permanent Plant Modifications inspection detailed in inspection report 70-3103/2020-004 (ML21028A706).

Sample Selection (IP Section 02.01) 13

The inspectors performed field walkdowns, reviewed documents, and observed operator activities related to plant modifications. Specifically, the inspectors performed the following:

  • observed an operator perform Attachment 4 of the autoclave liquid sampling procedure OP-03-0470-01 including implementation of IROFS42 and IROFS28
  • conducted a walkdown of MOD-19-0032, RTD Support Modification for the UTC Sub-Sampling Rig
  • conducted a walkdown of MOD-2019-140, Replace Existing Boiler Unit on SCDT with Tankless Water Heater
  • reviewed revision to ORM C23 and OP-3-0450-03 based on results from CALC-S-00136 regarding the impact on IROFS C23 of crashed/idled machines INSPECTION RESULTS Unresolved Item Independence of the Radiation Protection Program 88020 (Open) URI 07003103/2021002-01

Description:

During a review of the organizational structure of the Operations department, NRC staff identified an Unresolved Item (URI) related to the independence of the RP organization. On April 12th, 2021, Urenco implemented an organizational change that eliminated the RP Supervisor position, merged the Chemistry and RP departments, and created the Chemistry and RP Manager position that reported to the Operations Manager. NRC staff questioned Urenco on how they planned to maintain independence of the RP program with this change. Urenco had not completed a Change Management Plan prior to implementing this change, which would have evaluated how the Urenco RP department planned to maintain it's independence. Independence of the RP program is required per Safety Analysis Report Section 4.1.3, which states that "...the RP program is independent of the facility's production activities. This independence ensures that the RP program maintains its objectivity and is focused only on implementing sound radiation protection principles necessary to achieve doses that are ALARA. As previously noted in section 4.1.1.3, in matters involving radiation protection, the RP Supervisor has direct access to the Chief Nuclear Officer (CNO)." This URI is being opened to determine whether or not a violation exists.

Planned Closure Actions: Urenco is creating a Change Management Plan to address how the Urenco RP department planned to maintain its independence after the organizational change. The Change Management Plan will also evaluate the impact of the organizational change on Urecno's established programs and processes. The results of the Change Management Plan are needed to inform NRC's assessment of the issue of concern.

Licensee Actions: The licensee generated EV 143431 in response to NRC staff's concerns.

They conducted interviews with representatives from Chemistry and RP to inform the change management process and are currently developing the change management package.

Corrective Action

References:

EV 143431 14

EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.

  • On June 30, 2021, the inspectors presented the integrated inspection results to Mr.

Wyatt Padgett and other members of the licensee staff.

  • On May 6, 2021, the inspectors presented the Exit Meeting inspection results to Karen Fili and other members of the licensee staff.
  • On April 8, 2021, the inspectors presented the Exit Meeting inspection results to Karen Fili and other members of the licensee staff.

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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88015 Corrective Action Documents EV 137740 88015 Corrective Action Documents EV 138808 88015 Corrective Action EV 137835 Documents 88015 Corrective Action EV 139011 Documents 88015 Corrective Action EV 140415 Documents 88015 Miscellaneous Urenco USA General Employee Training 06/2019 88015 Miscellaneous SWCS Qualification List 04/01/2021 88015 Miscellaneous 51-2400542 Solid Waste System HAZOP and Risk Determination Rev 3 LES Analysis 88015 Miscellaneous 2021-A-01-002 NCS NQA-1 Audit 02/23/2021 88015 Miscellaneous EG-3-3200-02-F-1 NCS Analysis/Evaluation 11/05/2020 88015 Miscellaneous GWIROFSQC Deco and Recycling IROFS Certification Program - 04/07/2021 Operator Records 88015 Miscellaneous GWRECTECH USSA Recycling Technician Qualification Standard - 04/07/2021 Operator Training Record 88015 Miscellaneous GXNSWLP00I00ILT Nuclear Safety Worker Rev 11 88015 Miscellaneous ISA-HAZ_0009 GEVS HAZOP and Risk Determination Analysis 88015 Miscellaneous NCS Walkthrough Log 88015 Miscellaneous NCS-CSA-007 NCSA of GEVS Units in the SBM Rev 5 88015 Miscellaneous NCS-CSA-007 NCS Analysis of GEVS Units in SBM Rev 5 88015 Miscellaneous NCS-CSA-031 NCSA of the Small Component Decontamination Train Rev 1 88015 Miscellaneous NCS-CSA-035 NCSA of the Multifunctional Decontamination Train (MFDT) Rev 0 88015 Miscellaneous NCS-CSA-037 NCSA of the Slab Tanks Rev 0 88015 Miscellaneous NCS-CSE-008 NCSE of the HVAC Filters Rev. 1 88015 Miscellaneous NCS-CSE-026 NCSE for the Sample Bottle Outgassing Station Rev 6 88015 Miscellaneous TQ-3-0100-12-F-10 Training Approval Form - Nuclear Safety Training: Nuclear 06/23/2020 16

Inspection Type Designation Description or Title Revision or Procedure Date Safety Worker 88015 Miscellaneous TQ-3-0100-12-F-10 Training Approval Form - Qualification GET 06/14/2019 88015 Procedures CR-3-1000-04 Response to Nuclear Criticality Safety Anomalous Rev 4 Condition or Criticality Accident 88015 Procedures EP-3-0200-10 Criticality Emergency Response Rev 6 88020 Calculations 1003-9-2021-011 Cascade Hall 1003/1004 Transient Combustible Permit 05/04/2021 CALC 88020 Calculations CALC-F-00001 Fire Hazard Analysis Combustible Loading Rev. 20 88020 Calculations ETC-UPD0202978 Calculation of the Temperature at which a Full Cylinder will 05/01/04 Hydraulically Rupture 88020 Calculations LES-K-0011 LES Calculation Title Process Station Defrost Heater and 0 Fan High Temperature Trip - RTD (IROFS1) 88020 Corrective Action EV 137784 CRDB IROFS36a Surveillance Unsat Conditions 04/07/2020 Documents 88020 Corrective Action EV 140714 IROFS30a 08/21/2020 Documents 88020 Corrective Action EV137784 CRDB IROFS36a Surveillance Unsat Conditions 04/07/2020 Documents 88020 Corrective Action EV137786 Unsat IROFS 36d Weekly Inspection 04/07/2020 Documents 88020 Corrective Action EV138588 06/29/2020 Documents 88020 Corrective Action EV138592 06/29/2020 Documents 88020 Corrective Action EV138593 06/29/2020 Documents 88020 Corrective Action EV138594 06/29/2020 Documents 88020 Corrective Action EV138595 06/29/2020 Documents 88020 Corrective Action EV138696 06/15/2020 Documents 88020 Corrective Action EV140846 10/22/2020 Documents 17

Inspection Type Designation Description or Title Revision or Procedure Date 88020 Corrective Action EV143153 03/11/2021 Documents 88020 Corrective Action EV 144714 IROFS36a Transient Combustible Inspection SBM 1003 05/04/2020 Documents Resulting from Inspection 88020 Drawings NFT-40012108 Tri-Clamp Orifice Spool Detail Rev. A 88020 Engineering NEF-BD-01 Auto Trip of Station Defrost Heater Fan (RTD) 3 Evaluations 88020 Engineering NEF-BD-02 Auto Trip of Station Defrost Heater & Fan (T/C) 3 Evaluations 88020 Engineering NEF-BD-30a Limit Hydrocarbon Oil by Controlling Type Used Rev. 5 Evaluations 88020 Engineering NEF-BD-30b Limit Hydrocarbon Oil by Testing Prior to Adding to Pump Rev. 7 Evaluations 88020 Engineering NEF-BD-30c Limit Hydrocarbon Oil by Testing Prior to Operation Rev. 7 Evaluations 88020 Engineering NEF-BD-31a Limit Uranic Mass Inventory in Non-Safe-By-Design Solid Rev. 13 Evaluations Waste Containers 88020 Engineering NEF-BD-36a Limit Transient Combustible Loading in Uranic Areas Rev. 17 Evaluations 88020 Engineering NEF-BD-36a Limit Transient Combustibles in Uranic Areas 17 Evaluations 88020 Engineering NEF-BD-C21 Flow Restriction for Vacuum Pumps Used for Sampling or Rev. 8 Evaluations Evacuation 88020 Engineering NF-BD-02 Autotrip of Station Defrost Heater and Fan (T/C) 3 Evaluations 88020 Engineering ORM 30 Limit Hydrocarbon Oil (Moderator Mass) in Enriched Rev. 4 Evaluations Uranium Product 88020 Engineering ORM 36a Administratively Limit Transient Combustible Loading Rev. 9 Evaluations 88020 Engineering ORM C23 Design Feature of Centrifuges to Minimize Releases Rev. 5 Evaluations 88020 Miscellaneous OPQCRO00 Control Room Operator Certification Card for C. Slaughter 03/02/21 18

Inspection Type Designation Description or Title Revision or Procedure Date 88020 Miscellaneous OSIROFSQC00100 IROFS and Operating Requirements Manual Operations Rev. 09 Training Program 88020 Miscellaneous PR-3-2000-02-F-1 Receipt Inspection Plan for PO 4500134982 Rev 22 88020 Miscellaneous QA-3-3000-18-F-1 QC Receipt Inspection Plan Report for PO 4500134982 Rev. 15 88020 Procedures FP-3-2000-04 IROFS35 Weekly Fire Door Inspection and IROFS36a Rev. 18 Combustible Control Inspection SBM 88020 Procedures MA-3-0400-03 Installation and Verification of Flow Restriction Orifice Rev. 2 (IROFSC21) 88020 Procedures MA-3-2000-01 PFPE Oil Sampling Rev. 5 88020 Procedures MA-3-2000-03 Oil Addition to Vacuum Pumps Rev. 10 88020 Procedures MA-3-3400-01 IROFS1 Station Heater and Fan High Temperature Trip - 12 RTD Surveillance 88020 Procedures MA-3-3400-02 IROFS2 Station Heater and Fan High Temperature Trip - 14 TC Surveillance 88020 Procedures RW-3-1000-18 Bulking Enriched Waste Rev. 8 88020 Self-Assessments 2020-A-01-003 Report for UUSA Louisiana Energy Services, LLC 03/11/2020 Maintenance (M&TE) [limited scope] NQA-1 Audit 88020 Self-Assessments 2020-A-06-011 Report for UUSA Louisiana Energy Services, LLC 07/07/2020 Procedures Program Biennial NQA-1 Audit 88020 Self-Assessments 2020-A-10-018 Report for Urenco USA (UUSA) IROFS Compliance NQA-1 11/18/2020 Audit 88020 Work Orders PO 4500134982 Purchase Order for PFPE Oil 09/02/2020 88020 Work Orders WO 1000035476 IROCSC21 Install Flow Restriction Orifice 11/15/2011 88020 Work Orders WO 1000353915 7 Bar Rig C21 Orifice Install 11/15/2018 88020 Work Orders WO 1000461456 IROFS30a, b, and c Add Oil and Sample 09/15/2020 88020 Work Orders WO1000465351 1W: IROFS35, Fire Doors Inspect 03/01/2021 88020 Work Orders WO1000465352 1W: IROFS35, Fire Doors Inspect 03/08/2021 88020 Work Orders WO1000465354 1W: IROFS35, Fire Doors Inspect 03/22/2021 88020 Work Orders WO1000465884 1W: 1003 IROFS36A COMBUST CONT INSP 05/04/2021 88030 ALARA Plans Annual ALARA Report CY2019 04/30/2020 88030 Corrective Action EV 140210 Documents 88030 Corrective Action EV 140657 19

Inspection Type Designation Description or Title Revision or Procedure Date Documents 88030 Corrective Action EV 140786 Documents 88030 Corrective Action EV 140786 Documents 88030 Corrective Action EV 140786 Documents 88030 Corrective Action EV 141476 Documents 88030 Corrective Action EV 141534 Documents 88030 Corrective Action EV 141551 Documents 88030 Corrective Action EV 141583 Documents 88030 Corrective Action EV 141584 Documents 88030 Corrective Action EV 141585 Documents 88030 Corrective Action EV 142980 Documents 88030 Corrective Action EV 143431 Documents Resulting from Inspection 88030 Corrective Action EV 143435 Documents Resulting from Inspection 88030 Miscellaneous Radiation Safety Committee Minutes 04/24/2020 88030 Miscellaneous RMA Exit Monitoring Requirements Training 88030 Miscellaneous UUSA Organizational Chart 01/27/2021 88030 Miscellaneous Integrated Safety Analysis Summary Revision 32 88030 Miscellaneous Safety Analysis Report Revision 48 20

Inspection Type Designation Description or Title Revision or Procedure Date 88030 Miscellaneous Uranic Bioassay Analysis Reslts 11/16/2020 88030 Miscellaneous Cardinal Labs Bioassay Analysis 02/18/2021 88030 Miscellaneous Occupational Radiation Exposure Report 02/05/2020 88030 Miscellaneous Occupational Radiation Exposure Report 05/07/2020 88030 Miscellaneous Occupational Radiation Exposure Report 08/10/2020 88030 Miscellaneous Occupational Radiation Exposure Report 10/09/2020 88030 Miscellaneous NRC Form 3 08/2017 88030 Miscellaneous Posting Locations for NRC Form 3 88030 Miscellaneous Aggregate Source Inventory (excluding UF6 cylinders) 01/26/2021 88030 Miscellaneous GWRECTECH UUSA Recycling Technician Qualification Standard - Rev. 2 Purvis, Beadnell, and Sewell 88030 Miscellaneous Radiation Safety 10/22/2020 Committee Minutes 88030 Miscellaneous RP-RPTQC Radiation Protection Technician Qualification Card - Creed Rev. 3 and Anderson 88030 Miscellaneous RPTQIQC00 Radiation Protection Task Qualified Individual - Anderson, Rev. 5 Holguon, Hurlbut, and Harris 88030 Miscellaneous RW-3-1000-01-F-1 Hazardous Waste Storage Area Weekly Inspection 04/07/2021 88030 Miscellaneous RW-3-1000-01-F-11 Non-Radioactive Used Oil 04/07/2021 88030 Miscellaneous RW-3-1000-01-F-3 Hazardous Waste Storage Area Inventory 04/07/2021 88030 Miscellaneous RW-3-1000-01-F-7 Radioactive Waste Storage Area Weekly Inspection 04/07/2021 88030 Miscellaneous RW-3-1000-01-F-8 Radioactive Waste Storage Area Inventory 04/07/2021 88030 Miscellaneous RW-3-1000-01-F-9 RCRA Weekly Inspection Cover Sheet 04/07/2021 88030 Miscellaneous RW-3-1000-11-F-1 Inspection of Universal Waste Storage Area(s) 04/07/2021 88030 Procedures AD-3-1000-01 Requirements for Program Documents Rev. 34 88030 Procedures EG-3-3100-06-F-7 Integrated Safety Analysis Process (Hazard and Risk Revision 16 Determination Analysis ISA Record Cover Form) 88030 Procedures LS-4-1000-03 Processing Correspondence Revision 4 88030 Procedures NEF-BD-23b Personal Respiratory Use for Handling Designated Uranic Revision 3 Material in the CRDB 88030 Procedures NEF-BD-24a Establishment of Airflow Away From the Worker for Revision 3 Handling Designated Uranic Material in the CRDB 88030 Procedures QA-3-2000-01 Quality Assurance Audit Rev. 23 21

Inspection Type Designation Description or Title Revision or Procedure Date 88030 Procedures RP-2-1000-01 Radiation Protection Program Rev. 11 88030 Procedures RP-2-1000-02 ALARA Program Rev. 7 88030 Procedures RP-2-4000-01 Respiratory Protection Program Revision 6 88030 Procedures RP-3-1000-05 Annual ALARA Report Rev. 0 88030 Procedures RP-3-2000-01 Radiation Work Permits Revision 16 88030 Procedures RP-3-2000-02 Radiological Postings and Access Controls Rev. 19 88030 Procedures RP-3-2000-03 Labeling of Radioactive Material Revision 5 88030 Procedures RP-3-2000-04 Radiation and Contamination Surveys Revision 14 88030 Procedures RP-3-2000-07 Contaminated Individual Response Rev. 12 88030 Procedures RP-3-2000-12 Radioactive Source Control Revision 9 88030 Procedures RP-3-3000-08 Bioassay Rev. 9 88030 Procedures RP-3-3000-19 Personnel Contamination Monitors Revision 10 88030 Procedures RP-3-4000-01 Respiratory Protection Revision 8 88030 Procedures RP-3-4000-03-F-1 Dose Evaluation Report 2020-001 04/17/2020 88030 Procedures RP-3-4000-07 Portable Instruments Revision 10 88030 Procedures RP-3-4000-10 Continuous Air Monitors Revision 6 88030 Procedures RP-3-4000-17 Personal Air Monitors Revision 5 88030 Procedures RP-3-4000-26 QC Checks of the Ludlum Model 2929 Dual Scaler Revision 3 88030 Procedures RP-3-4000-29 Operation of the Ludlum Model 375 Area Radiation Monitor Revision 4 88030 Procedures RW-2-1000-01 Waste Acceptance Program Revision 8 88030 Procedures RW-3-1000-01 Waste Management Revision 9 88030 Procedures RW-3-1000-09 Radioactive Waste Container Setup, Handling and Revision 18 Disposition 88030 Procedures RW-3-1000-18 Bulking Enriched Waste Revision 8 88030 Procedures RW-3-4000-01 Startup, Shutdown, and Operations of the SCDT Rev. 10 88030 Procedures TQ-3-1000-12 Training Guidelines Rev. 5 88030 Radiation 20-0120 Sealed and Unsealed Source Inventory and Survey 07/24/2020 Surveys 88030 Radiation 21-0029 Sealed and Unsealed Source Inventory and Survey January-Surveys March 2021 88030 Radiation Work 21-001 Revision 0 Permits (RWPs) 88030 Radiation Work 21-002 Revision 0 22

Inspection Type Designation Description or Title Revision or Procedure Date Permits (RWPs) 88030 Radiation Work 21-003 Revision 0 Permits (RWPs) 88030 Radiation Work 21-004 Revision 0 Permits (RWPs) 88030 Radiation Work 21-005 Revision 0 Permits (RWPs) 88030 Radiation Work 21-006 Revision 0 Permits (RWPs) 88030 Radiation Work 21-007 Revision 0 Permits (RWPs) 88030 Radiation Work 21-008 Revision 0 Permits (RWPs) 88030 Radiation Work 21-009 Revision 0 Permits (RWPs) 88030 Radiation Work 21-010 Revision 0 Permits (RWPs) 88030 Radiation Work 21-011 Revision 0 Permits (RWPs) 88030 Self-Assessments 2019-A-04-006 Radioactive Waste Management NQA-1 Audit 06/06/2019 88030 Self-Assessments 2019-A-12-020 UUSA Radiation Protection Program NQA-1 Audit 01/11/2020 88030 Self-Assessments 2020-S-02-001 Surveillance of Recycling Related IROFS Requirements 02/28/2020 Flowdown 88030 Self-Assessments 2021-A-01-001 UUSA Radiation Protection Program NQA-1 Audit 02/02/2021 88030 Work Orders 1000421714 05/20/2020 88030 Work Orders 1000438968 11/17/2020 88030 Work Orders 1000466558 04/07/2021 88070 Calculations CALC-S-00136 Impact on IROFS C23 Due to Crashed/Idled Machines Rev. 2 88070 Engineering 10 CFR 70.72(c) Revision to Liquid Sampling Procedure OP-3-0470-01 01/23/2019 Changes Screen 2019-004 88070 Engineering 10 CFR 70.72(c) Modification of IROFS 43 RTD Brackets 05/28/2019 Changes Screen 2019-103 88070 Engineering 10 CFR 70.72(c) Revision to ORM C23 10/01/2019 Changes Screen 2019-206 23

Inspection Type Designation Description or Title Revision or Procedure Date 88070 Engineering 10 CFR 70.72(c) Install Tankless Water Heater on SCDT 06/13/2019 Changes Screening 2019-140 88070 Engineering MOD-18-0012C SCDT Boiler Replacement with Tankless Water Heater Unit 08/01/2019 Changes 88070 Engineering MOD-19-0032 RTD Support Modification for UTC Sub-Sampling Rig 05/25/2019 Changes 88070 Procedures OP-3-0450-03 (U) IROFS C23 Surveillance Procedure 88070 Procedures OP-3-0470-01 Liquid Sampling System 31 24

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