ML21301A002

Global Nuclear Fuel - Americas, LLC - Core Inspection Report 07001113/2021003

ML21301A002
Person / Time
Site:	07001113
Issue date:	10/27/2021
From:	Chutima Taylor NRC/RGN-II/DFFI/FFB1
To:	Nay D Global Nuclear Fuel
References
IR 2021003
Download: ML21301A002 (13)

Text

October 27, 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, L.L.C - CORE INSPECTION REPORT 07001113/2021003

Dear Mr. Nay:

On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Global Nuclear Fuel - Americas, L.L.C. On August 5, 2021, the NRC inspectors discussed the results of this inspection with you 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/

Cynthia D. Taylor, Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07001113 License No. SNM-1097

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML21301A002 SUNSI Review Non-Sensitive Publicly Available Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME M. Ruffin T. Sippel P. Startz C. Taylor DATE 10/25/2021 10/25/2021 10/25/2021 10/27/2021 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07001113 License Number: SNM-1097 Report Number: 07001113/2021003 Enterprise Identifier: I-2021-003-0120 Licensee: Global Nuclear Fuel - Americas, L.L.C Facility: Global Nuclear Fuel - Americas, L.L.C Location: Wilmington, NC Inspection Dates: August 02, 2021 to August 06, 2021 Inspectors: M. Ruffin, Fuel Facility Inspector T. Sippel, Fuel Facility Inspector P. Startz, Fuel Facilities Inspector Approved By: Cynthia D. Taylor, Chief Projects Branch 1 Division of Fuel Facility Inspection Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a core inspection at Global Nuclear Fuel - Americas, L.L.C, 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 None.

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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 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety (NCS) program to verify compliance with selected portions of Title 10 of the Code of Federal Regulations (10 CFR) 70, including 70.24, 70.61, and 70.62, Chapter 5, Nuclear Criticality Safety, of the facilitys license application, and applicable licensee procedures.

Criticality Analysis (IP Section 02.01)

The inspectors interviewed licensee staff and reviewed criticality safety analyses (CSAs) and supporting calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including, 5.1.1, 5.4.2, 5.4.4 and 5.4.5. Specifically, the inspectors interviewed licensee staff and conducted the following inspection activities:

• reviewed CSA-803.00.100, "Primary High-Efficiency Particulate Absorbing (HEPA) Filter Systems," Revision (Rev.) 5, including the review of accident sequences that cover various scenarios such as moderator intrusion, mass accumulation, and the basis for why the licensee screened certain accident sequences as not credible. This evaluation also establishes the basis for the limits controlled by various items relied on for safety (IROFS);

• reviewed CSA-804.00.100, "Secondary HEPA Filter Systems," Rev. 1, including the review of calculation results used to establish safety limits; and

• the inspectors conducted walk-downs in various areas of the facility to observe the different arrangements of HEPA filters, prefilters and IROFS controls that are used in different areas of the facility.

Criticality Implementation (IP Section 02.02)

The inspectors selected engineered and administrative controls from the licensees integrated safety analysis (ISA) summary to verify proper implementation through a review of process and system descriptions, plant walkdowns, and interviews with licensee operators and engineers to verify compliance with 10 CFR 70 and applicable sections of the license application, including, 5.4.1 and 5.4.2. Specifically, the inspectors reviewed the following controls, and their management measures, associated with the CSAs listed above:

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• IROFS 803-01, Primary HEPA Filter Monitoring, an administrative control that includes both the use of differential pressure gages and routine filter changes;

• IROFS 803-02, Process Equipment Barrier - Primary HEPA Housing and Ductwork, a passive control used to prevent moderator intrusion;

• IROFS 803-03, HVAC Duct Design & Holdup Monitoring, an administrative control that includes using routine NDA surveys to prevent mass accumulations;

• IROFS 803-04, Primary HEPA Filter - Safe Geometry, a passive control, some HEPA filters are credited as favorable geometry with controls and postings on the HEPA filter housing;

• IROFS 803-05, Primary HEPA Filtration, an administrative control used to prevent mass accumulations;

• IROFS 803-06, Secondary HEPA Filter Monitoring, an administrative control that includes using routine NDA surveys to prevent mass accumulations; and

• observed licensee staff replace a Primary HEPA filter, and its prefilter, in the Dry Conversion Process (DCP) Powder Outlet area.

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 license application. Specifically, the inspectors performed the following activities:

• reviewed the licensee's annual NCS audit of the NDA program (NS-2021-01);

• interviewed licensee staff concerning monitoring for long-term accumulations in the ducts;

• interviewed licensee NCS engineers and managers about the weekly audits and reviewed the recent audit reports; and

• interviewed the training manager, NCS staff involved in developing and giving NCS training, reviewed training material and tests concerning criticality hazards and control methods.

Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed current NCS program procedures, and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors performed the following:

• reviewed survey records, calibration reports and manuals associated with the use of the Scout II detector to survey for duct accumulations;

• interviewed licensee NCS engineers and the NCS manager about completed and in-progress NCS qualifications; and

• interviewed licensee NCS engineers and the NCS manager about NCS review and verification of facility changes.

Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees criticality accident alarm system (CAAS) and corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable 4

sections of the license application, including, 1.3.11.3, 5.3.2.5, and 5.3.2.6. Specifically, the inspectors reviewed documents and interviewed licensee NCS staff concerning the following:

• recent NCS evacuation drills, training and real events requiring licensee NCS staff support; and

• recent CAAS Needs Evaluations (CSA-703.00.100 and CSA-706.00.101) for changes that effect the CAAS in areas external to the buildings.

88055 - Fire Protection The inspectors evaluated selected aspects of the licensees fire protection program to determine whether the operational status, material condition and design of fire protection systems met the applicable requirements of 10 CFR 70, Chapter 7, "Fire Safety," of the facilitys license application, and applicable licensee procedures.

Selection of Inspection Samples (IP Section 02.01)

The inspectors reviewed licensing documents to select a sample of fire protection features in risk-significant areas/processes, including IROFS and their respective management measures (where applicable). The inspectors also selected licensee activities that support the implementation of the fire protection program based on the program description included in the license application. Specifically, the inspectors performed reviews of selected fire safety IROFS, fire detection and alarm systems, pre-fire plans, fire suppression systems and equipment, and audits of the fire safety program in the following areas:

• uranium oxide processes, including pellet pressing, pellet sintering furnaces, and pellet grinding;

• gadolinium/uranium fuel processes, including pellet pressing, pellet sintering furnaces, and final pellet grinding;

• dry conversion process area, moderation-controlled areas, and adjacent uranium production areas;

• uranium production processes and storage areas; and

• incineration of radiologically contaminated combustibles process.

Preventative Controls (IP Section 02.02)

The inspectors interviewed licensee staff, reviewed documentation, and conducted plant walk-downs to verify the licensees controls for combustibles, ignition sources, and inert atmospheres met the license requirements and applicable requirements in 10 CFR

70. Specifically, the inspectors conducted the inspection activities listed below:

• reviewed quarterly combustible control audit records to verify the combustible control program and the following IROFS were being maintained in accordance with CP-27-108 o IROFS 401-13, UO2 Press Feed Combustible Control Program o IROFS 402-14/503/14 Press Feed Combustible Control Program o IROFS 401-14/503-15, Press Area Combustible Control Program o IROFS 405-11/504-08, Furnace Area Combustible Control Program; 5

• conducted plant walk-downs of the press feed, press, furnace and grinder areas for the UO2 and GAD lines to verify controls of combustible materials;

• interviewed operators to verify combustibles were being controlled in accordance with OP 1002.00.000, "Combustible Material Control -

Fabrication," and CP-27-108, "Combustible Control Program."

• walked down flammable liquid storage cabinets;

• reviewed the following hot work permits to verify hot work was performed in accordance with WI-27-109-01 o 11453285 o 11452974 o 11453053 o 11453206 o 11453216

• reviewed primary and secondary quench chamber water injection systems designed to prevent fire within the incinerator exhaust system; and

• walked down wet sprinkler systems within the incinerator building to ensure compliance with drawings.

Fire and Gas Detection and Alarm Systems (IP Section 02.03)

The inspectors reviewed selected fire detection devices to verify that detection and alarm systems were able to detect the minimal fire within the required time and initiate the safety function credited in the license application, fire hazard analysis (FHA), or the ISA Summary. Specifically, the inspectors conducted the inspection activities listed below:

• interviewed licensee maintenance personnel and reviewed records of the annual FMO smoke detector, duct detector, and heat detector test to verify the fire detection devices remained functional to perform their intended safety functions and were tested in accordance with CP-27-100; and

• conducted plant walkdowns of the press feed, press, furnace and grinder areas for the UO2 and GAD processes to verify the presence of documented fire detection devices in the areas.

Suppression Systems and Activities (IP Section 02.04)

The inspectors interviewed license staff, reviewed fire protection program documents, and conducted plant walk-downs to verify that suppression systems were capable of performing the safety function credited in the license application, FHA, or the ISA Summary. Specifically, the inspectors conducted the following activities:

• interviewed licensee personnel and observed the electric and diesel weekly fire pump run test to ensure the fire pumps were functional to perform the pumping capability needed to meet the water supply demand of the system;

• reviewed the electric driven fire pump testing logs for 2019, 2020, and 2021 to verify that weekly operational testing was being performed and the pump was available to function as designed;

• observed monthly fire extinguisher inspection to verify they were provided at the designated locations, in proper material condition, and the access was unobstructed as required by procedure WI-27-110-01.

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• reviewed records of the fire engine surveillances to verify the equipment was ready and available to perform the intended safety functions;

• walked down and reviewed records of monthly inspections of the licensee's Fire Water Supply Control Valve Inspection program to verify compliance with procedure WI-27-110-16-F02;

• reviewed records of the licensee's Fire Sprinkler Quarterly Inspection Flow Test to verify compliance with procedure WI-27-110-17-F01; and

• reviewed records of the licensee's Fire Sprinkle System Semi-annual Supervisory Device Testing activities to confirm adherence to procedure WI-27-110-18-F01.

Passive Fire Protection Features (IP Section 02.05)

The inspectors reviewed selected passive fire protection features to verify these were in a proper material condition to perform the safety function credited in the license application, FHA, or the ISA Summary. Specifically, the inspectors performed the following activities:

• interviewed licensee staff and conducted plant walk-downs to verify fire walls, fire doors and fire wall penetrations were maintained as required per IROFS 900-19;

• walked down samples of passive fire protection features located in the dry conversion building to verify fire walls were properly marked, fire rated doors were in place and fully functional, and fire dampers were in place and appeared to be fully functional in accordance with samples of drawings 8001E11-1, 8001E11-2, 8011E13-1, and 8011E13-2; and

• walked down a sample of production areas to verify the licensee was managing and minimizing the storage of combustible materials in accordance with IROFS 401-14 and procedure OP 1001.00.100, "Fabrication General -

General Information."

Fire Protection Program Elements (IP Section 02.06)

The inspectors reviewed selected fire protection program elements to verify compliance with the license requirements. Specifically, the inspectors completed the following activities:

• reviewed records of the most recent fire impairment and interviewed licensee staff to verify adequate compensatory measures were put into place and the impairment was conducted as required by procedure WI-27-110-08;

• reviewed records of the fire protection organization to verify it aligned with license requirements;

• conducted plant walk-downs of various areas and reviewed emergency lighting inspection records to verify compliance with procedure WI-27-110-09;

• reviewed Pre-Fire Plans and conducted plant walk-downs to verify the pre-fire plans matched field conditions and were maintained in accordance with the license requirements;

• reviewed radiological incinerator operations for compliance with Technical Report INC-547, "Contaminated Combustible Waste Incinerator;"

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• performed walk-downs to observe samples of incinerator piping, instrumentation and controls and confirm the accuracy of piping and instrumentation diagrams (P&ID) 3000E86P11; and

• reviewed PLC logic software to verify logic rungs existed to ensure the incinerator PLC was capable of monitoring and performing safety functions for the following critical fire protection functions identified in INC-547 as follows:

Logic Rung 0516, for valve 0301, Quench Emergency Water, T-309HI Scrubber Gas temperature above 186 degrees F and T309LO <41 degrees F, prevents exhaust scrubber fire Logic Rung 0061, Exhaust Blower B-101A & 191B cut off, temperature T302H for scrubber gas >221 degrees F, located at quench chamber outlet, prevents a scrubber and potential emissions of fire/smoke into the environment Logic Rung 0061+, Exhaust Blower B-101A & 191B cut off, temperature T309HHH for bottom of packed bed gas >250 degrees F, prevents a scrubber and potential emissions of fire/smoke into the environment.

Identification and Resolution of Problems (IP Section 02.07)

The inspectors reviewed the licensees identification and resolution of fire protection issues to verify compliance with the license requirements. The inspectors followed-up on Event Notification 55364 concerning an impairment of the electric fire pump and Event Notification 55349 concerning an impairment of the backup diesel fire pump. The inspectors also conducted walk-downs to verify repairs associated with corrective actions and reviewed the following CAP entries, audits, and self-assessments:

• Condition Report 37191, Semi-Annual Sprinkler System Supervisory Device Discrepancies, June 15, 2021;

• Condition Report 37150, Quarterly Sprinkler Waterflow Alarm Discrepancies, June 9, 2021;

• Condition Report 37390, Electric Fire Water Pump Lost Its Power Source, July 20, 2021;

• Condition Report 37338, Diesel Fire Water Pump Engine Overheated from a Cooling System Defect, Electric Fire Pump Was Operable, July 10, 2021; and

• Condition Reports 37150 and 37191, Periodic Water Sprinkler System Testing Identified a Variety of Discrepancies.

INSPECTION RESULTS No issues were identified.

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

On August 5, 2021, the inspectors presented the Nuclear Criticality Safety and Fire Protection inspection results to Doug Nay and other members of the licensee staff.

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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88015 Calculations SCALE6.1/KENO-VI Validation Report Rev. 3.1 Calibration QN-00225 ScoutII Qualification for Holdup Measurements in FMO Rev. 1 Records Corrective Action CR 36637, CR 37438 Criticality Safety related corrective action documents Documents Engineering CSA-703.00.100 CAAS Needs Evaluation: Criticality Warning System Rev. 1 Evaluations DAM 20 CSA-706.00.101 Outside Storage Pads CAAS Needs Evaluation Rev. 1 CSA-803.00.100 Primary HEPA Filter Systems Rev. 5 CSA-804.00.100 Secondary HEPA Filter Systems Rev. 1 QRA-803/804 HVAC Rev. 18 Miscellaneous 2Q21 NCS Audit of Nodes 601, 806: Bundle Assembly, 06/25/2021 Shipping Warehouse/Refurb/Pads 2Q21 Nuclear Criticality Safety Audit - Nodes 401-503, 06/23/2021 405-504, 406-505 2021Q2 Nuclear Safety Audit - 205A, 206A, 207: 06/14/2021 Homogenization, BPG & Tumble, Powder Pack 2Q2021 NSE Audit - DCP MRA and Powder Container 06/30/2021 Storage, Transfer Corridor, DCP Additive, DCP Sample Room List of DP gage daily checks 08/02/2021 Radiation Worker Training, Criticality Safety GEE-MISC- Nuclear Emergency Preparedness training 04/21/2021 EMERGENCYPREPAR-NE_001 Technical Report #NDA- Software Design/Maintenance Manual for the Rev. 0 HVAC-001 SuperScout NDE Reports NDA logs of duct surveys Procedures CP-20-314 Criticality Safety Engineer Training and Qualification Rev. 0 OP 2301.00 FMO HVAC Maintenance Operation Rev. 26 WI-27-105-24 Radiological Incidents Rev. 2 WI-27-105-25 HVAC Surveys to Detect Uranium Accumulation Rev. 8 9

Inspection Type Designation Description or Title Revision or Procedure Date Self- NS-2021-01 NDA Program Annual Review 02/25/2021 Assessments Work Orders WO: 4710443, 4710445 Annual Check of Magnehelic Gage 05/03/2021 WO: 4872711, Monthly Prefilter Change 4872713, 4872714, 88055 Drawings Incinerator LM9030 Incinerator Control Logic Charts 09/27/2006 Program Flow Charts, 8 charts total Engineering Technical Report INC- Contaminated Combustible Waste Incinerator, CR 07/06/2017 Evaluations 547, Revision 10 #25042 Fire Plans DCP/FMOX WH GNF-A Pre-Incident Plan 08/2021 FHA 1001.00 Fire Hazards Analysis, Revision 3 09/2020 FMO/FMOX GNF-A Pre-Incident Plan 08/2021 Incinerator GNF-A Pre-Incident Plan 08/2021 Miscellaneous CP-28-113-F17, Weekly Squad-1 Surveillance 8/1/21 CP-28-113-F17, Weekly Squad-1 Surveillance 7/23/21 CP-28-113-F18, Weekly Engine-2 Surveillance 8/1/21 CP-28-113-F17, Weekly Engine-2 Surveillance 7/23/21 80375.39 Red Tag Permit for Fire Impairment 07/21/2021 Generator Building GNF-A Pre-Incident Plan 8/2021 L.FSM.32912 Fire Sprinkler Maintenance Tech License 12/31/2021 Memorandum of Agreement with New Hanover County Fire Rescue 05/03/2019 Understanding Second Quarter Fire 2Q21 Combustible Control Inspection Records 6/30/2021 Safety Audit -2021 Operability Wet System Inspection Report 11/03/2020 Evaluations Procedures CP-27-108 Combustible Control Program 6.1l 6/11/2020 OP 1001.00.100 Fabrication General - General Information Revision 2 OP 1002.00.000 Combustible Material Control - Fabrication Revision 01 OP 1081.01.204 Incinerator - Abnormal Operations Revision 6, 06/09/2020 10

Inspection Type Designation Description or Title Revision or Procedure Date OP 1081.01.206 Incinerator - Basic Operator Maintenance Revision 8, 04/06/2021 OP 1081.01.300 Incinerator - Process Operations Revision 6, 12/09/2020 Shipping WO: 4801367 FMO E-Light Monthly Inspection - DCP, Controlled 6/19/2021 Records Area WO: 4867546 Monthly Calibration of H2 Detector UO2 Fuel Fab 07/15/2021 Sinetering Furnace Area Work Orders WO: 4712366 Bundle Assembly Area, 2nd FL, E-Light, Non- 3/22/2021 Controlled WO: 4865047 FMO E-Light Monthly Inspection - Bundle Assembly 7/19/2021 and Surrounding Non-Controlled Areas WO: 4867547 Monthly Calibration of H2 Detector UO2 Fuel Fab 7/15/2021 Sinetering Furnace Area WO: 4867548 Monthly Calibration of H2 Detector GAD Sinetering 7/15/2021 Furnace Area WO: 4867549 Monthly Calibration of H2 Detector GAD Sinetering 7/15/2021 Furnace Area WO: 4878542 Weekly Fire Pump PM. Diesel 8/5/2021 WO: 4881710 Weekly Fire Pump Test Run Procedure [Electric Driven] 8/5/2021 11