ML22208A127
| ML22208A127 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 07/28/2022 |
| From: | Robert Williams NRC/RGN-II |
| To: | Nay D Global Nuclear Fuel |
| References | |
| IR 2022002 | |
| Download: ML22208A127 (20) | |
Text
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 07001113/2022002
Dear Mr. Nay:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection activities conducted from March 1 to June 30, 2022, for the Global Nuclear Fuel - Americas facility in Wilmington, NC. On May 19 and June 16, 2022, the NRC inspectors discussed the results of this inspection with you. 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, Robert E. Williams, Jr., 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 July 28, 2022 Signed by Williams, Robert on 07/28/22
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME L. Pitts M. Ruffin T. Sippel P. Startz T. Vukovinsky R. Womack J. Rivera R. Williams DATE 7/25/22 7/25/22 7/25/22 7/25/22 7/25/22 7/25/22 7/25/22 07/28/2022
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07001113 License Number:
SNM-1097 Report Number:
07001113/2022002 Enterprise Identifier:
I-2022-002-0061 Licensee:
Global Nuclear Fuel - Americas, L.L.C.
Facility:
Global Nuclear Fuel - Americas, L.L.C.
Location:
Wilmington, NC Inspection Dates:
May 16, 2022 to June 17, 2022 Inspectors:
L. Pitts, Sr. Fuel Facility Projects Inspector M. Ruffin, Project Engineer T. Sippel, Fuel Facility Inspector P. Startz, Fuel Facilities Inspector T. Vukovinsky, Sr. Fuel Facility Project Inspector R. Womack, Physical Security Inspector Approved By:
Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection
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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. (GNF-A), 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.
3 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 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees Operational Safety program to verify compliance with applicable portions of 10 CFR 70, including 70.24, 70.61, and 70.62; 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 integrated safety analysis (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:
Accident Sequence 5.1.5.1, Hot Cylinder Removed from Autoclave
Accident Sequence 5.1.5.2, UF6 Cylinder Breach
Accident Sequence 5.1.5.3, UF6 Cylinder Rupture due to Fire near Cylinder Receipt Area
Accident Sequence 5.1.5.4, UF6 Cylinder Rupture due to Fire on/near Storage Pads
Accident Sequence 5.1.5.5, UF6 Cylinder Rupture due to Fire near Dry Conversion Process (DCP) Staging Area
Accident Sequence 5.1.5.6, UF6 Cylinder Rupture due to Fire near DCP Cylinder Hallway
Accident Sequence 5.2.5.1, Cylinder High Temperature
Accident Sequence 5.2.5.2, Heating an Overweight Cylinder
Accident Sequence 5.2.5.3, Heating a Pressurized Cylinder
Accident Sequence 5.2.5.4, Cold Trap Overfill
Accident Sequence 5.2.5.5, Cold Trap High Temperature
Accident Sequence 5.2.5.6, High Pressure in a Cold Trap Due to Nitrogen
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Accident Sequence 5.2.5.7, Loss of Containment During UF6 Feeding from Autoclave
Accident Sequence 5.2.5.8, Loss of Containment Inside the Autoclave
Accident Sequence 5.2.5.9, Maintenance Activity Leading to Release of UF6 or Reaction Products
Accident Sequence 5.5.3.1, Moisture Enters Powder Outlet Cooling Hoppers
Accident Sequence 5.5.3.2, Powder Outlet Loss of Containment
Accident Sequence 5.5.3.3, Moderator Leaks onto Process Equipment -
Powder Outlet
Accident Sequence 5.6.3.1, External Oil Reservoir Leak
Accident Sequence 5.6.3.3, Loss of Containment - Homogenizer Equipment
Accident Sequence 5.6.3.4, Moderator Leaks onto Homogenizer Equipment
Accident Sequence 5.8.3.1.3, Moderator Leaks onto Process Equipment
Accident Sequence 5.8.3.1.5, Loss of Containment - Powder Pack (Un-controlled Area)
Accident Sequence 5.8.3.2.2, Excess Moderator Leaks onto Process Equipment Review of Safety Controls and Related Programs (IP Section 02.02)
The inspectors reviewed information related to administrative, engineered, and passive safety controls or items relied on for safety (IROFS) for the accident sequences selected in Section 02.01 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:
IROFS 101-01, UF6 Cylinder Skin Temperature, Administrative Control (AC) for Chemical Safety
IROFS 101-02, UF6 Cylinder, Passive Engineered Control (PEC) for Chemical Safety
IROFS 101-08, UF6 Cylinder Handling Combustible Control Program, AC for Criticality Safety/Radiation Safety/Chemical Safety
IROFS 201-01, Vaporization Cylinder Temperature and Pressure Control System, Active Engineered Control (AEC) for Chemical Safety
IROFS 201-02, Vaporization Autoclave Pressure Vessel, PEC for Chemical Safety
IROFS 201-05, Autoclave Leak Detection System, Augmented Administrative Control (AAC) for Chemical Safety
IROFS 201-06, Vaporization Sense and Flee, AC for Chemical Safety
IROFS 201-07, Vaporization Room HF Alarm and Automatic Shutdown System, AEC for Chemical Safety
IROFS 201-19, Portable Wet Scrubber System, AC for Chemical Safety
IROFS 201-20, UF6 Feed Piping, PEC for Chemical Safety
IROFS 201-21, Cold Trap Vessel - Containment, PEC for Chemical Safety
IROFS 201-22, Cold Trap High Pressure Interlock, AEC for Chemical Safety
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IROFS 201-23, Cold Trap High Temperature Interlock, AEC for Chemical Safety
IROFS 201-24, Cold Trap Weight Interlock A, AEC for Chemical Safety
IROFS 201-25, Cold Trap Weight Interlock B, AEC for Chemical Safety
IROFS 201-26, Valve Sequencing Interlocks, AEC for Chemical Safety
IROFS 900-02, Personnel Protective Equipment, AC for Chemical Safety
IROFS 204-01, Kiln Hatch & Nitrogen Purge Pressure, AAC for Criticality Safety
IROFS 204-02, Cooling Hopper Moisture Detection System, AEC for Criticality Safety
IROFS 204-04, Process Equipment Barrier - Powder Outlet, PEC for Criticality Safety
IROFS 205-02, Homogenizer External Oil Volume, AC for Criticality Safety
IROFS 205-03, Homogenizer Lid Design, PEC for Criticality Safety
IROFS 205-08, Process Equipment Barrier - Homogenizer, PEC for Criticality Safety
IROFS 207-02, Safe Geometry - Powder Pack Process, PEC for Criticality Safety
IROFS 207-03, Process Equipment Barrier - Powder Pack Equipment, PEC for Criticality Safety
IROFS 207-09, Process Equipment Barrier - Receipt Transfer Hood, PEC for Criticality Safety
IROFS 207-10, Safe Geometry - Receipt Transfer Hood and Conveyor, PEC for Criticality Safety
IROFS 900-04, Spill Identification and Cleanup, AC for Criticality Safety
IROFS 900-03, GNF-A Facility MRA, AC for Criticality Safety
IROFS 900-06, Safe Geometry - Transportable Containers, PEC for Criticality Safety
IROFS 900-07, Process Equipment Barrier - Transportable Container, PEC for Criticality Safety Implementation of Safety Controls (IP Section 02.03)
For the selected safety controls listed Section 02.02 above, the inspectors reviewed management measures to verify proper implementation in accordance with 10 CFR 70.62(d). 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:
performed a walkdown of the UF6 cylinder pads to verify implementation of IROFS 101-08 and IROFS 101-02
reviewed the postings for IROFS 101-08
performed a walkdown of vaporization process equipment
reviewed the implementation of IROFS 201-07
reviewed the performance of management measure to verify required training associated with IROFS 201-6
reviewed the performance of visual inspections as part of the management measures to verify operability of IROFS 201-24 and 201-25
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reviewed the performance of management measure to verify operability of IROFS 201-05
reviewed the performance of management measure to verify operability of IROFS 201-01
performed a walkdown of powder outlet process equipment and interviewed staff to verify operability of the following IROFS o
204-01 o
204-02
performed a walkdown of homogenization process equipment and interviewed staff to verify implementation of the following IROFS o
205-02 o
205-03 o
205-08
performed a walkdown of powder pack and powder receipt processing areas to verify the use and implementation of the following IROFS o
207-02 o
207-03 o
207-09 o
207-10 o
900-06 o
900-07 Safety Control Support Programs (IP Section 02.04)
The inspectors assessed additional management 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 the following condition reports (CRs) entered in the corrective action program (CAP) for IROFS-related issues o
CR38402 and associated documents for IROFS 101-02 o
CR38304 and associated documents for IROFS 201-24 and 201-25 o
CR39187 and associated documents for IROFS 201-06 o
CR39100 and associated documents for IROFS 204-02 o
CR38621 and associated documents for Line 3 homogenizer
interviewed the control room operators regarding implementation of IROFS 101-01
reviewed the training records for the control room operators
reviewed training records for operators in powder pack and receipt
reviewed training records for operators of the DCP powder outlet and homogenization systems
reviewed the Functional Test Instruction (FTI) 201-07 for Lines 1, 2, and 3
reviewed FTI 201-01A and -01B for Lines 1, 2, and 3
reviewed FTI 204-01A for IROFS 204-01
reviewed FTI 204-02 for IROFS 204-02
reviewed surveillance records to verify management measure implementation for the following IROFS o
204-04 o
900-03
7 o
205-02 o
205-03 o
205-08 o
207-02 o
207-03 o
207-09 o
207-10 RADIOLOGICAL CONTROLS 88045 - Effluent Control and Environmental Protection The inspectors evaluated selected aspects of the licensees environmental protection program to verify compliance with selected portions of 10 CFR 20, Part 40, Part 61, and Part 70, and the facilitys license application.
Program Implementation (IP Section 02.01)
The inspectors reviewed any significant changes to the effluent control and environmental protection program, discussed with the licensee any new unplanned releases or contamination identified, and screened the CAP in order to verify the environmental protection program was being implemented in compliance with license requirements. Specifically, the inspectors completed the following activities:
performed walkdowns of the waste water treatment systems including process area wastewater pre-treatment equipment, two treatment tanks outside the process buildings, and the final settling/aeration basins
reviewed corrective actions and notifications related to CR 37708 Procedures (IP Section 02.02)
The inspectors selected a sample set of procedures changed since the last inspection and, if possible, observed the procedures in use to verify that safety-significant changes to procedures in the area of environmental protection were in compliance with license requirements and 10 CFR 20. Specifically, the inspectors completed the following activities:
reviewed document 2021 COMPLY: V1.7, "Report on Compliance with The Clean Air Act Limits For Radionuclide Emissions," dated January 25, 2022
reviewed procedure WI-27-102-11, "Public Exposure To Airborne Releases"
reviewed significant programmatic changes and procedure revisions that occurred over the past year
conducted walkdowns of the UF6 cylinder storage yards and various radiological waste storage areas on the facility grounds
reviewed procedure WI-27-102-05, "Waste Control and Disposal" Audits and Quality Assurance (IP Section 02.03)
The inspectors reviewed procedures associated with the conduct of audits and assessments of the environmental protection program, along with completed third-party and self-assessed audits and resulting corrective action entries since the last NRC inspection in this area to
8 verify compliance with license application requirements. Specifically, the inspectors reviewed the following documents:
"First Quarter Environmental Audit 2021," dated March 30, 2021
"Second Quarter Environmental Audit 2021," dated June 11, 2021
"Fourth Quarter Environmental Audit 2021," dated December 7, 2021
"2021 ALARA Environmental Monitoring and Effluent Review," dated March 4, 2022 Event Review (IP Section 02.04)
The inspectors reviewed the licensees evaluation of safety-significant events in the area of environmental protection to verify compliance with 10 CFR 20 and license application requirements. Specifically, the inspectors completed the following:
reviewed CAP entries and corrective actions for items related to environmental protection: CRs 36601, 36655, 37785, 38769, 39187, and 39330
reviewed Controlled Access Area (CAA) Temporary Operating Procedure 50199, Revision 02, "Demolition of Equipment in the UCON Skid Area/Chemical Safe-store Areas", effective beginning 4/4/2022 - ending 4/4/2023; to verify that activities under this procedure did not affect the production process wastewater treatment systems next to the UCON area Training (IP Section 02.05)
The inspectors reviewed the licensees training program in the area of environmental protection to verify compliance with license application requirements. Specifically, the inspectors reviewed the following:
a sample of personnel training and qualification records of the environmental protection staff Radioactive Liquid Effluents (IP Section 02.06)
The inspectors observed operations, reviewed sample collection and analysis procedures, reviewed radiological effluent monitoring reports and monitoring records, and discussed the radioactive effluent results with licensee staff to verify compliance with aspects of 10 CFR 20.2103 and the license application. Specifically, the inspectors completed the following activities:
performed walkdowns of the wastewater treatment system including the production area receipt tanks, the first stage of treatment processes (UCON Skid Area/Chemical Safe-store), the lime treatment process, and the neutralization/settling/aeration basins/final process lagoons
accompanied personnel conducting sampling of treated water from the final process lagoons
reviewed operating procedure EPI-O-2, "Environmental Sampling of the Final Process Lagoon System, Aeration Basin, and Site Dam"
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reviewed a sample of liquid effluent data to verify consistency of the data samples with the related "Semiannual Effluent Report" Municipal Sanitary Sewer (IP Section 02.07)
This section is not applicable as GNF-A does not discharge effluents to a municipal sanitary sewer.
Radioactive Airborne Effluents (IP Section 02.08)
The inspectors observed operations, reviewed sample collection and analysis procedures, reviewed radiological effluent monitoring reports and monitoring records, and discussed the radioactive airborne effluent results with licensee staff to verify compliance with aspects of 10 CFR 20.1101, 10 CFR 20.2103, and the license application. Specifically, the inspectors completed the following activities:
accompanied a radiological technician during an exhaust stack sample change-out for the production areas
reviewed operating procedure EPI-O-6, "Stack Sampling Program"
reviewed a sample of raw stack sample data and compared it to the COMPLY V1.7 modeling data input Effluent Monitoring (IP Section 02.09)
The inspectors observed operations, reviewed IROFS and associated surveillance packages, and discussed the results with the licensee to verify compliance with Subpart H of 10 CFR 70 and the license application, and consistency with the ISA Summary. Specifically, the inspectors completed the following activities:
reviewed surveillance records for IROFS 702-07, 702-10, 702-11 o
Task Details 3120156, Annual, "Rad Waste Favorable Geometry Annular Tanks V-262, 264, 9010, 9011, 9500," completed on August 25, 2021
reviewed surveillance records for IROFS 702-09 o
Task Details 3120419, "Annual Rad Waste Favorable Geometry Tank V9010/nozzle functionality," completed on April 7, 2022
reviewed surveillance records for IROFS 702-12 o
Task Details 3120422, "Annual Rad Waste Favorable Geometry Tank V9011/V9500/nozzle functionality," completed on April 5, 2022 Semiannual Effluent Reports (IP Section 02.10)
The inspectors reviewed the licensees effluent monitoring report to verify compliance with the requirements of 10 CFR 70.59. Specifically, the inspectors reviewed the following documents:
licensee report SPM 20-029, M200118, "GNFA Semi-Annual Effluent Monitoring Report January to June 2020," dated August 25, 2020
licensee report SPM 21-007, M210019, "GNFA Semi-Annual Effluent Monitoring Report July 2020 to December 2020," dated February 23, 2021
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procedure EPI-O-5.0, "Generation of Semi-annual Effluent Report" Quality Control of Analytical Measurements (IP Section 02.11)
The inspectors observed analytical laboratory operations and reviewed records of sample methods to verify compliance with the quality control requirements in the license application.
Specifically, the inspectors completed the following activities:
observed the preparation and Inductively Coupled Plasma (ICP) analysis of an environmental sample in the licensee's chemical laboratory
discussed ICP calibration, sample blanks, sample standards, data acquisition and transfer to the Laboratory Information Management System Public Dose Analysis (IP Section 02.12)
The inspectors reviewed dose assessment records and associated reports to verify compliance with 10 CFR 20.1301, 10 CFR 20.1302, and the reporting requirements of 10 CFR 20.2107. Specifically, the inspectors completed the following activities:
reviewed the "2021 ALARA Environmental Monitoring and Effluent Review,"
dated March 4, 2022
interviewed the data analysist about the data and techniques used to populate the COMPLY dose assessment modeling software Environmental Sampling (IP Section 02.13)
The inspectors reviewed environmental sampling records of surface water, sediment, soil, vegetation, ambient air, groundwater, direct radiation, and/ or sanitary sewer sludge, if applicable, to verify compliance with 10 CFR 20.1501 and the license application. Specifically, the inspectors completed the following activities:
accompanied a radiological technician during sample filter paper change-out activities associated with air samplers that were located around the perimeter of the GNF-A facility, and exhaust stack samples located at each exhaust stack
discussed filter paper handling techniques, air volume settings using a rotameter or electronic automated controller, and calibration of the equipment
assessed the material condition, functionality, calibration, and sample filter paper change-out processes
reviewed operating procedures EPI-O-9 "Environmental Ambient Air Sampling Stations" and EPI-O-6, "Stack Sampling Program" Minimizing Facility and Environmental Contamination and Facilitating Decommissioning (IP Section 02.14)
The inspectors reviewed decommissioning records to verify compliance with 10 CFR 70.25(g) and 10 CFR 20.1406. Specifically, the inspectors completed the following:
conducted walkdowns of plant areas around the processing buildings, including UF6 cylinder storage yard, material storage boxes awaiting
11 incineration and material recovery, and the previous wastewater treatment facility to verify radiological materials were properly stored Radioactive Waste Classification, Characterization, and Storage (IP Section 02.15)
The inspectors reviewed documentation and records of facility activities and observed posting and labeling of storage areas and containers to verify compliance with the requirements of 10 CFR 61.55 and the license application. Specifically, the inspectors reviewed the following records:
posting and labeling of four drums of radiologically contaminated machine lubricating oil, labeled "Used Oil" o
Drum #000GW03222/Batch #44 o
Drum #000GW03219/Batch #41 o
Drum #000GW03220/Batch #42 o
Drum #000GW03221/Batch #43 Waste Burial (IP Section 02.16)
This section is not applicable as there is no known history of buried radioactive waste at GNF-A.
Effluent Treatment (IP Section 02.17)
The inspectors conducted walkdowns and observations and reviewed records of on-site waste treatment facilities and airborne effluent scrubbers and filters to verify compliance with the license application. Specifically, the inspectors completed the following activities:
performed walkdowns of the following waste water treatment systems o
process area wastewater pre-treatment equipment o
two treatment tanks outside the process buildings o
final settling/aeration basins FACILITY SUPPORT 88051 - Evaluation of Exercises and Drills The inspectors observed and evaluated the licensees graded biennial exercise conducted on June 16, 2022, as well as briefings and critiques involving both on-site and off-site participants, to verify compliance with 10 CFR 70.22(i)(3)(xii) and the GNF-A Radiological Contingency and Emergency Plan. The scenario involved a simulated natural gas explosion in the incinerator building resulting in a breach of building containment, dispersal of low-level radioactive material in the immediate area North of the building, residual fire impacts, and a contaminated injured person.
Exercise Planning (IP Section 02.01)
The inspectors reviewed the emergency exercise scenario, discussed the exercise objectives with licensee personnel, observed controller, evaluator, and player briefings, and walked down the plant areas before the exercise to verify compliance with the Emergency Plan, Emergency Plan Implementing Procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed the following:
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the frequency of exercises conducted by the licensee
the scenario as it related to testing all elements of the Emergency Plan and probability
pre-staging of equipment in preparation for the exercise
duties and responsibilities for exercise personnel including controllers, evaluators, and observers
confidentiality of the scenario and objectives Exercise Execution and Emergency Plan Implementation (IP Section 02.02)
The inspectors observed the initiation of the emergency exercise, the activation of the Emergency Control Center (ECC), site Emergency Organization (EO), and the site Emergency Response Organization (ERO), and reviewed the off-site dose assessments to verify compliance with the Emergency Plan, Emergency Plan Implementing Procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors observed or reviewed the following:
the licensees analysis of plant conditions including assessment and classification of the accident scenario
staffing for all ECC positions
protective action recommendations implemented by the ECC
drafting of off-site notifications including a review of content and time of issuance
on-site communication to occupational workers as it related to protective action recommendations
occupational workers participation in protective actions (shelter-in-place) and the process to conduct personnel accountability
press release approval and issuance
the Emergency Director and Incident Commander (IC) command and control of the ECC, ERO, and EO
use of applicable Radiological Assessment System for Consequence Analysis software and use of the dose assessment, radiation survey results, and environmental monitoring results during assessment of the accident scenario
response coordinators recommendations regarding conditions for terminating the event and restarting normal operations
recovery and re-entry recommendations implemented by the ECC and IC
establishing the incident command post up wind of the accident
members of the licensees emergency response team assembly at designated assembly areas and the arrival of off-site emergency responders including fire and rescue services
emergency response teams actions including search and rescue activities for casualties, assessment of the affected area, fire fighting, and contamination control
prioritization of the severity of medical injuries versus decontamination of the victim
response to emerging situations to address the exercise scenario and meet the exercise objectives
the Incident Commander's command and control of the emergency response team and coordination of actions with off-site emergency responders
13 Critiques, Exercise Control, and Identification and Resolution of Problems (IP Section 02.03)
The inspectors observed the staff critiques of the emergency exercise and reviewed the licensees related CAP entries to verify compliance with the Radiological Contingency and Emergency Plan, Emergency Plan Implementing Procedures, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed the following:
critiques conducted by the licensee; which included input from off-site participants
discussion regarding whether drill objectives were satisfied
documented deficiencies identified during critiques including items planned for entry into the licensees CAP INSPECTION RESULTS No issues were identified.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On May 19, 2022, the inspectors presented the operational safety (IP 88020) and environmental protection (IP 88045) inspection results to Doug Nay and other members of the licensee staff.
On June 16, 2022, the inspectors presented the emergency preparedness exercise (IP 88051) inspection results to Doug Nay and other members of the licensee staff.
14 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date ALARA Plans 2021 ALARA Environmental Monitoring and Effluent Review 03/04/2021 CALC 900-006 SNM Powder Spill Frequency Rev. 6 Calculations COMPLY: V1.7 Report on Compliance with The Clean Air Act Limits For Radionuclide Emissions 01/25/2022 38304 Cold Trap Load Cell Visual Verification 38402 Visible UO2F2 on 30B Cylinder UREU103096 38621 Ripped Boot on Line 3 Homogenizer 1/11/2022 39100 Line 2 Powder Outlet Moisture Probes Relay 3/15/2022 Corrective Action Documents 39187 1st Quarter 2022 Environmental Audit Finding on Vaporization and Conversion 39594 Line 3 low flow level relays FAL33224 and FAL33205 malfunction for IROFS 204-02 5/19/2022 Corrective Action Documents Resulting from Inspection CR 39566 WO4449760 Annual Inspections for 2021 and 2022 (IROFS 803-08) 05/14/2022 IROFS Requirements Specification (IRS)
IRS-201-01 IROFS 201-01 Vaporization Cylinder Temperature and Pressure Control Rev. 2 IRS-201-05 Vaporization Autoclave Leak Detection System Rev. 2 IRS-201-07 Vaporization Room HF Alarm and Automatic Shutdown System Rev. 2 IRS-201-22 IROFS 201-22 Cold Trap Pressure Interlock Rev. 2 IRS-201-23 IROFS 201-23 Cold Trap Pressure Interlock Rev. 2 IRS-201-25 IROFS 201-25, Cold Trap Weight Interlock Rev. 4 IRS-201-26 IROFS 201-26, Cold Trap Feed Valve Interlock Rev. 2 IRS-204-01 IROFS 204-01 Kiln Hatch Nitrogen Purge Pressure Alarm Rev. 1 IRS-204-02 IROFS 204-02 Cooling Hopper Moisture Detection System Rev. 2 88020 Engineering Evaluations Process Hazard Analysis (PHA)-101 ISA Reference Report for the UF6 Cylinder Handling Node Group Rev. 6
15 Inspection Procedure Type Designation Description or Title Revision or Date QRA-803/804 QRA-803/804, sections 3.2.6.3.4 and 3.3.1.3.3 DSR Baghouse Filters (IROFS 803-08)
Revision 20A CP-20-107-F18 DCP Powder Outlet Qualification Card DCP BPG and Second Floor Additive Make-Up Qualification Card 7/29/2015 DCP Conversion Area Complete Qualification Card 10/14/2019 IROFS Surveillance 204-04, 207-03, 207-09 Powder Outlet and Powder Pack Equipment Barriers Visual Inspection 2/1/2021 IROFS Surveillance 204-04, 207-03, 207-09 Powder Outlet and Powder Pack Equipment Barriers Visual Inspection 1/3/2022 IROFS Surveillance 205-02, 206-01 Weekly Homogenizer and Blender External Oil Reservoir Checks 4/19/2022 IROFS Surveillance 205-02, 206-01 Weekly Homogenizer and Blender External Oil Reservoir Checks 4/25/2022 IROFS Surveillance 205-02, 206-01 Weekly Homogenizer and Blender External Oil Reservoir Checks 5/18/2022 IROFS Surveillance 205-02, 206-01 Weekly Homogenizer and Blender External Oil Reservoir Checks 5/10/2022 IROFS Surveillance 205-03, 205-08, 206-02, 206-10 Homogenizer and Blender Equipment Barriers 2/22/2021 IROFS Surveillance 205-03, 205-08, 206-02, 206-10 Homogenizer and Blender Equipment Barriers 2/22/2022 IROFS Surveillance 207-02, 207-10 Receipt Hood and Conveyor and Powder Pack Conveyor Favorable Geometry 1/28/2021 Miscellaneous IROFS Surveillance 207-02, 207-10 Receipt Hood and Conveyor and Powder Pack Conveyor Favorable Geometry 1/11/2022
16 Inspection Procedure Type Designation Description or Title Revision or Date IROFS Surveillance 900-003 MRA Facilities (DCP/DSR/Gad-MRA) 12/21/2021 IROFS Verification:
IROFS 900-03 GNF-A MRA AC 11/24/2020 ISA Team Meeting form for eCR 50597 QRA-207: CSA Implementation for Pack and Receipt 12/15/2021 Powder Transfer Processes Qualification Card Rev. 0 QRA-201 DCP Vaporization Rev. 16 QRA-204A Dry Conversion Process: Powder Outlet Rev. 4 QRA-205A Dry Conversion Process: Homogenization Rev. 6 QRA-207 Powder Pack/Receipt Rev. 14 Quantitative Risk Assessment (QRA)
-101 UF6 Cylinder Handling Rev. 11 Test No.: 204-01A Kiln Hatch N2 Purge Pressure Alarm PT#2115 2/24/2022 Test No.: 204-01A Kiln Hatch N2 Purge Pressure Alarm PT#2115 12/16/2021 Test No.: 204-02 Cooling Hopper Moisture Detection System 9/23/2021 Operability Evaluations Test No.: 204-02 Cooling Hopper Moisture Detection System 10/7/2021 2022 Environmental/NRC Audit Schedule 1/10/2022 CP-27-114 Integrated Safety Analysis Rev. 11 EPI-E-5.0 Generation of Semi-Annual Effluent Report EPI-O-2.0 Environmental Sampling of the Final Process Lagoon System, Aeration Basin, and Site Dam EPI-O-6 Stack Sampling Program EPI-O-9 Environmental Ambient Air Sampling Stations FMO HVAC Maintenance Operation Revision per CR 50862 OP 201.00.209 DCP Vaporization - Abnormal Operations Rev. 2 Procedures OP-201.00.202 DCP Vaporization - UF6 Cylinder Handling Rev. 1
17 Inspection Procedure Type Designation Description or Title Revision or Date OP-201.00.206 DCP Vaporization - Autoclave Unloading Rev. 07 OP-201.00.210 DCP Vaporization - Alarm Response and Emergency Operations Rev. 2A TOP 50199 CAA Temporary Operating Procedure/TOP 50199, Demolition of Equipment in the UCON Skid Area/Chemical Safe-store Areas. Start 4/4/2022 - end 4/4/2023 Rev. 02 WI-18-104-01 Internal Environmental Protection (EP) Audits Rev. 1.0 WI-27-102-05 Waste Control and Disposal Rev. 2.2 WI-27-102-11 Public Exposure To Airborne Releases (COMPLY tool)
Rev. 0.1 WI-27-105-20 Radioactive Shipment Surveys Rev. 8.0 First Quarter Environmental Audit 2021 3/30/2021 Fourth Quarter Environmental Audit 2021 12/7/2021 Self-Assessments Second Quarter Environmental Audit 2021 6/11/2021 3120156 IROFS Surveillance (IROFS) 702-07, 702-10, 702-11, Task Details 3120156, Annual, Rad Waste Favorable Geometry Annular Tanks V-262, 264, 9010, 9011, 9500 08/25/2021 3120419 IROFS Surveillance (IROFS) 702-09, Task Details 3120419, Annual Rad Waste Favorable Geometry Tank V9010, nozzle functionality 04/07/2022 3120422 IROFS Surveillance (IROFS) 702-12, Task Details 3120422, Annual Rad Waste Favorable Geometry Tank V9011/V9500, nozzle functionality 04/05/2022 4449760 Annual Inspection of CSR Bag House Filter, Baghouse for dry scrap recycle transfer, (IROFS 803-08), start date 06-JAN-2021 N/A WO 4690416 Calibration Inspection; Old Screener Room Accountability Scale 5/20/2021 Work Orders WO 5118090 Quarterly Weight Audit SN 774 Power Pack Hot 2/1/2022
18 Inspection Procedure Type Designation Description or Title Revision or Date WO 5148824 Calibration Inspection Non-ACC Scale Powder Pack Hot 4/5/2022 WO5026211 Check Operation of Line #3 Powder Outlet Moisture Pump/Shut off While Changing 3b Container 10/21/2021 88045 Miscellaneous QRA 803/804 HVAC Rev. 20A 2022 Biennial Evaluated Exercise, Scenario Package Miscellaneous Radiological Contingency and Emergency Plan Rev. 30 WI-28-114-01 Emergency Director Rev. 1.0 WI-28-114-05 Environmental, Health, and Safety (EHS) Advisor Rev. 2.1 WI-28-114-08 Building Manager Rev. 1.0 WI-28-114-09 Field Monitoring Team Management Rev. 3.0 WI-28-114-10 Emergency Response Organization (ERO) Operations Rev. 1.0 88051 Procedures WI-28-114-14 Protective Actions Rev. 2.1