ML22298A089

Urenco USA – Integrated Inspection Report 07003103 2022003

ML22298A089
Person / Time
Site:	07003103
Issue date:	10/27/2022
From:	Robert Williams NRC/RGN-II/DFFI
To:	Padgett W Louisiana Energy Services, URENCO USA
References
IR 2022003
Download: ML22298A089 (22)

Text

Wyatt Padgett Compliance Manager Louisiana Energy Services dba Urenco USA (UUSA)

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

SUBJECT:

URENCO USA - INTEGRATED INSPECTION REPORT 07003103/2022003

Dear Wyatt Padgett:

This letter refers to the U.S. Nuclear Regulatory Commission inspection activities conducted from July 1 to September 30, 2022, at your Urenco USA facility. The results of these inspections were discussed with you and other members of your staff. The enclosed report presents the results of these inspections.

Based on the results of this inspection, the NRC has determined that two Severity Level IV violations of NRC requirements occurred. Because Urenco USA has implemented a corrective action program that has been determined to be adequate by the U.S. Nuclear Regulatory Commission and has initiated condition reports to address these issues, these violations are being treated as Non-Cited Violations (NCVs), consistent with Section 2.3.2 of the Enforcement Policy. These NCVs are described in the subject inspection report.

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement.

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 (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07003103 License No. SNM-2010 October 27, 2022 Signed by Williams, Robert on 10/27/22

W. Padgett 2

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML22298A089 X

SUNSI Review X

Non-Sensitive

Sensitive X

Publicly Available

Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME G. Goff P. Startz L. Cooke T. Sippel R. Williams DATE 10/21/22 10/21/22 10/20/22 10/21/22 10/27/22

Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:

07003103 License Number:

SNM-2010 Report Number:

07003103/2022003 Enterprise Identifier:

I-2022-003-0059 Licensee:

Louisiana Energy Services dba Urenco USA (UUSA)

Facility:

Urenco USA Location:

Eunice, NM Inspection Dates:

August 22, 2022 to September 1, 2022 Inspectors:

L. Cooke, Fuel Facility Inspector G. Goff, Fuel Facilities Inspector P. Startz, Fuel Facilities 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 an integrated inspection at Urenco USA, 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 Failure to report as required by 10 CFR 70 Significance Report Section Severity Level IV NCV 07003103/2022003-01 Open/Closed 88020 NRC inspectors identified a Severity Level IV (SLIV) non-cited violation (NCV) of 10 CFR 70 Appendix A, "Reportable Safety Events," for failure to submit a 60-day written report as a follow up to EN55770.

Failure to Conduct Adequate Exercise Critiques Significance Report Section Severity Level IV NCV 07003103/2022003-02 Open/Closed 88020 The NRC identified an SLIV NCV for the licensee's failure to conduct adequate critiques that identified issues with emergency exercise performance.

Additional Tracking Items Type Issue Number Title Report Section Status URI 07003103/2022006-04 Timeliness of reporting to the NRC under 10CFR70 Appendix A 88020 Closed WER 07003103/2022-002-00 Instances of Unanalyzed Conditions Associated with IROFS50b/c (EN55802) 88020 Closed URI 07003103/2022002-02 Failure to Conduct Adequate Exercise Critiques 88020 Closed WER 07003103/2022-005-00 RETRACTED UF6 Leakage Inside Autoclave (EN55930) 88020 Closed URI 07003103/2022006-02 Unanalyzed Condition of Vehicles within the CAA 88020 Open

3 PLANT STATUS The UUSA Facility in Eunice, New Mexico enriches uranium hexafluoride (UF6) using gas centrifuge technology. During the inspection period, normal production activities were ongoing.

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

SAFETY OPERATIONS IP 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees Operational Safety program to verify compliance with selected portions of 10 CFR 70, including 70.61, 70.62, and Chapter 11, Management Measures, of the facilitys safety analysis report (SAR), and applicable licensee procedures.

The inspectors also reviewed open items related to the URENCO USA - SPECIAL INSPECTION REPORT 07003103/2022006 (ML22126A182) and items relied on for safety (IROFS) 50b/c, including reviewing URI 07003103/2022-006-02, URI 07003103/2022-006-04, WER 07003103/2022-001-00, WER 07003103/2022-002-00, and WER 07003103/2022-007-00.

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

The inspectors selected UF6 process areas for inspection based on the safety basis information of the facility, the relative higher risk/safety significance of the process areas involving liquified UF6, and past plant performance documentation regarding containment of UF6 within these process systems during postulated accident sequences. The targeted process areas included the UF6 autoclaves where the UF6 is liquified and sampled, associated piping systems, and measures to ensure the leak tight integrity of the autoclaves. The inspectors selected samples of accident sequences related to chemical safety associated with the autoclave IROFS, based on the information provided in the integrated safety analysis (ISA) summary and associated safety basis documentation. The inspectors conducted a plant tour of each major plant operating area involving liquified UF6. The process areas and accident sequences selected for review are listed below:

Accident Sequences for SEISMIC and TORNADO/HIGH WIND hazards, which credit IROFS27e was evaluated for the building surrounding the autoclaves and the autoclave support structures. Inspectors, along with licensee engineering staff, physically inspected samples of seismic bracing in

4 the areas around the autoclaves. Samples included building structural bracing (wind braces) and overhead bracing of piping, air ducts and electrical wire trays, and other hazards that could affect the autoclaves. The inspectors reviewed the samples of bracing to verify compliance with section 3.4.8 "Actual Seismic Design Detailed Approach" in the SAR.

Accident Sequences PB4-1, PB4-3 and PB4-4, which credit IROFS10 design features to maintain Product Liquid Sampling Autoclave leak tight integrity, were evaluated to verify that the total autoclave leakage was limited to that assumed in the accident consequence analyses thorough review of calculations provided in "ARC-991". Specifically, the inspectors reviewed samples of the engineering calculations package AN-ARC-991, "Archon Engineering Calculation ARC-991, ASME VIII Pressure Vessel Design Calculation for the Autoclave Quality Level - QL1," Revision (Rev.) 1, to verify that the autoclave met the applicable requirements of ASME section VIII, section III and ANSI B31.1 requirements, and that the autoclave was manufactured to these ASME requirements to allow the pressure boundary to be declared QL-1 in support of, in part, IROFS10.

Accident Sequences for SEISMIC and TORNADO/HIGH WIND hazards that credit IROFS 28 design features to maintain Product Liquid Sampling Manifold integrity, were evaluated to verify that the manifold would withstand a design basis seismic event, a free fall event, and were limited to that assumed in a sample of accident consequence analyses thorough review of calculations provided in "ARC-838." Specifically, the inspectors reviewed samples of the engineering calculations package Archon Calculation # ARC-838, "Autoclave Assembly Design Changes Quality Level - QL1," Rev. 3/Addendum 7, to verify that the autoclave Product Liquid Sampling Manifold piping and assembly plates met ASME Boiler and Pressure Code,Section II; and that the autoclave was declared QL-1 in support of, in part, IROFS28.

Review of Safety Controls and Related Programs (IP Section 02.02)

The inspectors reviewed information related to passive engineered IROFS, specifically IROFS10, IROFS27e, and IROFS 28 for their accident sequences, including the identification of the licensees assumptions and bounding cases as they apply to each of the selected accident sequences and associated mitigating 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:

IROFS10, sole IROFS for accident sequences PB4-1 and PB4-3, passive feature to maintain UF6 product liquid sampling autoclave leak tight integrity, chemical safety controls

IROFS27e, design feature of buildings (excluding the SBMs, the CRDB Chemistry Laboratory and associated rooms, Mass Spectrometry Laboratory, and the CRDB Bunker Solid Waste Collection Room and Ventilated Room for solid radioactive waste consolidation) containing UF6 process systems for seismic, and tornado missile, to ensure UF6 process systems integrity

IROFS28, design features to maintain UF6 Product Liquid Sampling Autoclave leak tight integrity during postulated seismic and tornado missile events

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IROFS Boundary Definitions: NEF-BD-10, "Design Features to Maintain Product Liquid Sampling Autoclave Leak Tight Integrity", Rev. 10, the IROFS boundary definition for IROFS10; and NEF-BD-27e, "Design Features of the SBM, CRDB Shell and the UBC Storage Pad Crane," Rev. 12, the IROFS boundary definition for IROFS27e Implementation of Safety Controls (IP Section 02.03)

For the selected safety controls listed above, the inspectors reviewed licensee's 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:

The inspectors walked down buildings SBM-1001 and 1003 with the licensee's System Engineering Supervisor to verify the implementation of inspection procedure EG-3-5200-01, "IROFS27e Structural Inspection Surveillance,"

Rev. 12, which requires periodic inspections to ensure the building and its structures remain intact and prevent seismic damage to the UF6 autoclaves.

The inspector interviewed the supervisor about the various elements of visual evaluation of building structural elements and bracing that held appliances to the ceiling structures.

The inspectors observed a production technician performing a sequence of preparatory operations to disconnect a sampling manifold from a UF6 30B product cylinder, to verify compliance with procedure OP-3-0470-01, "Liquid Sampling System," Rev. 44.

The inspectors reviewed samples of events associated with IROFS10 and IROFS28 to verify compliance with assumptions and bounding definitions/conclusions as specified in procedure OP-3-1000-09, "Operability Determination," Rev. 12.

The inspectors reviewed samples of maintenance work orders (WOs) associated with testing the performance of IROFS 10 to verify that physical inspections/maintenance/calibrations were completed in accordance with the following two work orders, (1) WO1000439083 - 3LS1 "Autoclave Pressure Vessel Inspection" performed with referenced procedure NEF-BD-10, Rev. 5 -

completed February 24, 2022; and (2) WO1000449035, "3LS1 IROFS10 Autoclave Leak Test, " performed with referenced procedure MA-3-2470-01, Rev. 10 - completed January 22, 2021.

Inspectors performed walkdowns to review samples of the Piping &

Instrumentation Diagram (P&ID), LES-1001-P-PID-471-3B1, "Liquid Sample Autoclave," Rev. 0, to verify that the sampling manifold drawing matched one of the actual manifolds used in the autoclaves.

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. Additionally, the inspectors followed-up on WER 07003103/2022-005-00,

6 "RETRACTED UF6 Leakage Inside Autoclave (EN55930)" which is discussed below. Specifically, the inspectors conducted the following:

WER 07003103/2022-005-00 involved operations personnel who visually identified indication of a very small leak of UF6 gas while completing final activities associated with collecting a liquid sample of UF6 from a 30B cylinder, all contained within an autoclave pressure vessel. Initially, it appeared that the controls maintaining the leak tightness of the sampling manifold to the UF6 cylinder, (initially considered part of IROFS28) had failed. The licensee conservatively declared that IROFS28 was inoperable, and reported the event to the NRC as EN55930. The licensee then performed an engineering evaluation of IROFS28 and IROFS10 boundary definitions. It was determined that while the autoclave manifold itself is part of the IROFS28 boundary, the physical connection, and process of torqueing the manifold to the cylinder is not. That placed the failure that resulted in this leak outside of the bounds of IROFS28. IROFS10 was required to ensure the leak tightness of the autoclave and was not impacted by the leak at the connection between the sample manifold and the A4 cylinder valve. IROFS10 boundary included the cylinder/manifold leak. IROFS10 remained fully functional. The licensee retracted EN55930 on June 9, 2022. The inspectors evaluated the licensee's analysis to verify the IROFS boundary definitions were consistent with what was credited in 51-2400533-02-LES, "Blending and Liquid Sampling System HAZOP and Risk Determination Analysis," Rev. 14. Additional detail is included below in the closure of WER 07003103/2022-005-00.

Work Order 1000439083 - 3LS1 "Autoclave Pressure Vessel Inspection" performed with referenced procedure NEF-BD-10, Rev. 5 - completed February 24, 2022; Work Order 1000449035, "3LS1 IROFS10 Autoclave Leak Test," performed with referenced procedure MA-3-2470-01, Rev. 10 -

completed January 22, 2021

Inspectors evaluated the seismic structural analysis associated with the autoclaves

Inspectors reviewed samples of the licensee's corrective action program for compliance with procedure CA-3-1000-01, Rev. 49, "Performance Improvement Program", as follows: EV 148227, EV 149223, EV 151717, and EV 148226

Inspectors reviewed licensee's operations personnel training records "UUSA Operations Building Operator Certification Standard," Rev. 7; and/or OSIROFSQC00100, Rev. 9, "Items Relied Upon for Safety (IROFS) and Operating Requirements Manual (ORM)," to verify that a sample of three operations personnel had completed their on-the-job training and evaluations in their respective areas of operations.

RADIOLOGICAL CONTROLS IP 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 Part 20, Part 61, and Part 70, and the facilitys SAR.

7 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 corrective action program in order to verify the environmental protection program was being implemented in compliance with license requirements. Specifically, the inspectors:

reviewed and discussed SAR Chapter 2.2, "Key Management Positions"

reviewed and discussed corrective actions: EV 144463, EV 151162, EV 151361, EV 154128, and EV 156393

walked down the corrective actions associated with EV 144563 Procedures (IP Section 02.02)

The inspectors selected a sample set of procedures changed since the last inspection and 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 EN-3-2020-01, "EN Air Sampling," Rev. 7, for any reduction in the margin of safety and witnessed this procedure being utilized by site personnel

reviewed EN-3-2020-02, "EN Media Sampling," Rev. 8, for any reduction in the margin of safety and witnessed this procedure being utilized by site personnel

reviewed EN-2-1010-02, "Radiological Effluent Monitoring Program (REMP),"

Rev. 5, for any reduction in the margin of safety

reviewed EN-3-3010-02, "Alpha Monitor (ABPM 201 S) Calibration," Rev. 7, for any reduction in the margin of safety Audits and Quality Assurance (IP Section 02.03)

The inspectors reviewed procedures associated with the conduct of audits and assessments along with completed third-party and self-assessed audits and resulting corrective action entries assessed with the environmental protection program since the last inspection to verify compliance with requirements in the SAR. Specifically, the inspectors completed the following activities:

reviewed 2022-A-03-005, "Report for Urenco USA Environmental Compliance NQA-1 Biennial Audit," May 8, 2022 to verify that any observations, findings, or recommendations were placed into the corrective action program

reviewed the following QA audits for vendors that provide environmental samples analyses:

o 2021-E-10-101, Vendor Evaluation Report - Eberline Analytical, dated November 30, 2021 o

2022-E-08-012, Vendor Evaluation Report - Cardinal Laboratories, dated August 12, 2022 o

2022-E-08-013, Vendor Evaluation Report - Green Analytical Laboratories, dated August 16, 2022

8 o

2022-E-08-014, Vendor Evaluation Report - GEL Laboratories, LLC, dated August 17, 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 SAR requirements.

Specifically, the inspectors:

reviewed EV 144563 - Tear in Pond Liner

reviewed:

o AC 161333 - Report East UBC Pond Corrective Action Plan to NMED o

AC 161501 - Tear in UBC Drain Pond Liner o

AC 162671 - Tear in UBC Drain Pond Liner o

AC 162672 - Tear in UBC Drain Pond Liner o

AC 162673 - Tear in UBC Drain Pond Liner o

LES-21-061-NMED - Damage to the East Basin Liner of Pond 2

walked down the pond liner to verify that corrective actions listed in the corrective action program matched the as-found conditions in the field Training (IP Section 02.05)

The inspectors reviewed the licensees training program in the area of environmental protection to verify compliance with SAR requirements. Specifically, the inspectors reviewed the following:

training and qualification records for the current manager with responsibility for environmental protection

qualification card/record for a technician currently undergoing qualification Radioactive Liquid Effluents (IP Section 02.06)

The inspectors reviewed sample collection and analysis procedures, reviewed radiological effluent monitoring reports and monitoring records, and discussed the radioactive liquid effluent results with licensee staff to verify compliance with aspects of 10 CFR 20.2103 and the SAR. Specifically, the inspectors:

reviewed EN-2-1010-02, "Radiological Effluent Monitoring Program (REMP),"

Rev. 5

interviewed the manager of the environmental protection program regarding liquid effluents released to the environment versus those liquid effluents released to the sanitary sewer

walked down Lift Station #1, retention basins, and groundwater wells M24, M25, and M26 Municipal Sanitary Sewer (IP Section 02.07)

The inspectors reviewed records related to the release of liquid effluents to sanitary sewers to verify compliance with 10 CFR 20.2003 and the SAR. Specifically, the inspectors:

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reviewed sanitary sewer liquid effluent release concentrations in the Semi-Annual Radiological Effluent Release Report for the first and second halves of calendar year 2021 to verify that concentrations were below the federal limits listed in 10 CFR 20 Appendix B Table 3

interviewed the manager of environmental protection to verify that all uranium released was in the soluble form as per 10 CFR 20.2003(a)(1)

walked down Lift Station #1 which controls the process discharge to the city of Eunice public 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 SAR. Specifically, the inspectors:

observed environmental air filter sample collection in accordance with EN 2020-01, "EN Air Sampling," Rev. 7

reviewed the Semi-Annual Radiological Effluent Release Report for the first and second halves of calendar year 2021 to verify that all airborne concentrations were below federal limits 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, the license application, and the ISA. Specifically, the inspectors completed the following activities:

observed calibration of HF monitors used in conjunction with the general effluent ventilation system (GEVS)

walked down and observed alpha and beta monitors and flow meters for airborne effluent in SBM-1001

interviewed the manager responsible for the environmental protection program regarding the monitoring of airborne effluents and liquid discharges to the sanitary sewer Semiannual Effluent Reports (IP Section 02.10)

The inspectors reviewed the licensees effluent monitoring reports to verify compliance with the requirements of 10 CFR 70.59. Specifically, the inspectors completed the following activities:

reviewed the Semi-Annual Radiological Effluent Release Report for the first and second halves of calendar year 2021 to verify that all concentrations (airborne effluent, liquid effluent, and releases to the sanitary sewer) were below the federal limits listed in 10 CFR 20 Appendix B Tables 2 & 3, and that the reports were submitted in compliance within the timeliness requirements of 10 CFR 70.59

10 Quality Control of Analytical Measurements (IP Section 02.11)

The inspectors reviewed procedures specifying methods to verify compliance with the quality control requirements in the SAR. Specifically, the inspectors:

reviewed the following quality control documents:

o QA-3-2000-02, "Commercial Grade Survey," Rev. 6 o

QA-3-2000-08, "Approved Supplier List," Rev. 16 o

QA-3-4000-02, "Approved Vendors List," Rev. 1

reviewed the QA audits for vendors that provide environmental samples analyses listed above

interviewed the licensee environmental protection manager about quality control of measurements Public Dose Analysis (IP Section 02.12)

The inspectors reviewed dose assessment records to verify compliance with 10 CFR 20.1301, 10 CFR 20.1302, and the reporting requirements of 10 CFR 20.2107. Specifically, the inspectors:

reviewed public dose assessment records from all of calendar year 2021 and the first two quarters of calendar year 2022 Environmental Sampling (IP Section 02.13)

The inspectors observed environmental sampling to verify compliance with 10 CFR 20.1501. Specifically, the inspectors completed the following activities:

observed the sampling of soil and vegetation to verify that these activities were conducted in accordance with EN-3-2020-02, "EN Media Sampling",

Rev. 8

interviewed the environmental protection manager regarding results of prior soil and vegetation sampling Minimizing Facility and Environmental Contamination and Facilitating Decommissioning (IP Section 02.14)

The inspectors reviewed decommissioning records to verify compliance with 10 CFR 20.1406. Specifically, the inspectors:

reviewed LES-21-170-NRC, "Response to Request for Supplemental Information Regarding Decommissioning Financial Assurance Estimate,"

dated December 21, 2021, with respect to the discussion of spills and areas with fixed contamination

reviewed "Plant Contaminated Areas" graph

11 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, 10 CFR 61.56, and the SAR. Specifically, the inspectors:

interviewed licensee personnel involved with low level waste classification and characterization and shipment preparations to determine how the licensee classifies and characterizes radiological waste and prepares shipment to an offsite repository

reviewed the following procedures:

o RW-3-1000-07, "Shipping Hazardous, Non-Hazardous and Universal Waste," Rev. 6 o

RW-3-1000-13, "Shipping Radioactive and Mixed Waste," Rev. 8

observed radioactive waste storage areas, specifically the radiological solid waste compactor, liquid effluent collection and transfer system, and labeling on containers

observed containers for shipping solid and liquid radiological waste to verify the integrity of these containers Effluent Treatment (IP Section 02.17)

The inspectors conducted walkdowns and observations and reviewed records of onsite waste treatment facilities and airborne effluent scrubbers and filters to verify compliance with the SAR. Specifically, the inspectors completed the following activities:

walked down banks of pre-filters and HEPA filters for the GEVS INSPECTION RESULTS Failure to report as required by 10 CFR 70 Severity Report Section Severity Level IV NCV 07003103/2022003-01 Open/Closed 88020 The NRC inspectors identified a Severity Level IV (SLIV) non-cited violation (NCV) of 10 CFR 70 Appendix A, "Reportable Safety Events," for the licensees failure to submit a 60-day written report as a follow-up to EN55770.

==

Description:==

The licensee retracted EN55770 on the basis that the accident sequence OC2-1 had been re-evaluated based on probabilities with current site conditions and determined that the initiating event was highly unlikely inherently, and therefore IROFS would not be required to meet the 10 CFR 70.61 performance requirements for the construction vehicles used in the SBM 1001 HVAC Chiller project.

NRC inspectors reviewed ISA-IAD-0034, which documented the licensee's re-evaluation of accident sequence OC2-1 and concluded that the accident sequence OC2-1 remained credible and that IROFS50b/c would be required to meet 10 CFR 70.61(b) performance requirements. ISA-IAD-0034 analyzed the impact of heart attack, stroke, and mechanical failure of a vehicle, and determined the events could be characterized as having an occurrence of less than 1E-05 per year, and therefore assessed to be highly unlikely.

12 However, this analysis did not factor in the risk of human error with respect to the initiating event. In the ISA, human error is one of the factors that can cause the initiating event, and the initiating event frequency index was determined to be -1, representing a few failures may occur during the facility lifetime. This was selected based on limited evidence from industry events involving chemical releases caused by construction vehicles. The licensee's analysis did not address this component of the initiating event frequency.

Corrective Actions: The licensee submitted the required 60-day written event report for EN55770 on September 1, 2022, after the inspectors identified this NCV and informed the licensee.

Corrective Action

References:

60-Day Report for EN 55770 (ML22245A024), EV 156736 Analysis: Enforcement Policy Example 6.9, Inaccurate and Incomplete Information or Failure to Make a Required Report, Example d.5 states "[a] licensee fails to make a report required by... Appendix A to 10 CFR Part 70." Which corresponds to an SL IV violation.

This failure to submit a 60-day follow up report had no actual or potential safety or security consequences. However, a failure to make a required report to the NRC does have regulatory significance. Section 2.2.1(c) of the NRC Enforcement Policy, states in part, that Unless otherwise categorized in the violation examples contained in this Policy (i.e., Section 6.0), the severity level of a violation involving the failure to make a required report to the NRC will depend on the significance of and the circumstances surrounding the matter that should have been reported. the Agency will normally cite a licensee for a failure to report a condition or event if the licensee knew of the information to be reported and did not recognize that it was required to make a report.

Enforcement:

Violation: 10 CFR 70 Appendix A, "Reportable Safety Events," Section (a), "One hour reports" requires, in part, that "Events to be reported to the NRC Operations Center within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of discovery... followed by a written report within 60 days:... An event or condition such that no items relied on for safety, as documented in the Integrated Safety Analysis summary, remain available and reliable, in an accident sequence evaluated in the Integrated Safety Analysis, to perform their function..."

Contrary to the above, a written report was not made within 60 days after the occurrence of an event in which no items relied on for safety, as documented in the Integrated Safety Analysis summary, remained available and reliable, in accident sequence OC2-1. Specifically, the licensee reported EN55770 as a one-hour report under 10 CFR 70 Appendix A section (a) but the subsequently retracted the event notice. As a result, the required 60-day written event report was not made. This violation closes WER 07003103/2022-001-00, "Retracted Failure to Implement IROFS50b/c (EN55770)."

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

The disposition of this violation closes URI: 07003103/2022006-04.

Failure to Conduct Adequate Exercise Critiques Severity Report Section

13 Severity Level IV NCV 07003103/2022003-02 Open/Closed 88020 The NRC inspectors identified an SLIV NCV for the licensee's failure to conduct adequate critiques that identified issues with emergency exercise performance.

==

Description:==

During the planning phase of the emergency drill, which was designed as a seismic event, the licensee modified the scenario shortly prior to execution of the exercise, removing steps that would directly evaluate compliance with IROFS 39A (Seismic-Worker Evacuation). Emergency Plan, Rev. 28, Section 7.3.1 Biennial Exercises, states in part, The exercise objectives and scenario are submitted to the Nuclear Regulatory Commission for review and comment at least sixty days prior to the exercise. The inspectors were not made aware of the change to the exercise until the day before the exercise was scheduled to begin.

Emergency Plan, Section 5.4.1.4, Reentry and Rescue, states in part, Personnel who reenter the affected area during the emergency shall be informed of the potential hazards and choose to accept the associated risk. Reentry shall be performed by more than one person. During the exercise, without performance of the IROFS39A procedural steps of OP-3-2000-04, Earthquake Response, Rev. 18 (due to the scenario modification) the licensee did not analyze plant conditions and discuss with operators the potential hazards, prior to directing licensee staff to re-enter the facility.

OP-3-2000-04, "Earthquake Response," Rev. 18, Section 3.4, requires the licensee to "Make the following announcement to all site personnel 2 times. Attention all site personnel, a seismic event has been detected. Immediately evacuate all buildings and proceed to your assigned assembly area.

OP-3-2000-04 Section 4, requires the licensee to:

"4.2 Check available HF and alpha/beta radiation monitoring instrumentation to check for possible system releases and personnel hazards....

4.4 Dispatch personnel to determine presence of radiation and hazardous material....

4.6 WHEN conditions have been determined, THEN define personnel protective equipment (PPE) required for entry....

4.8 Ensure personnel are prevented from re-entering UF6 Handling Areas without appropriate PPE until atmosphere is determined to be safe by trained personnel.

4.9 Direct building operators to perform walk downs of their respective areas AND document on OP-3-2000-04-F-1, Seismic Damage Walkdown."

On two separate occasions during the exercise, building operators were sent back into the potentially affected area to perform walkdowns without PPE and without consideration of the presence of hazards or conditions having first been determined to be safe by trained personnel. Personnel were not briefed prior to entry into the affected areas for potential hazards, and were not dispatched as a team, as required by the Emergency Plan.

Safety Condition 10 of License SNM-2010 states, in part, that "The licensee shall conduct authorized activities in accordance with the statements, representations, and conditions of the documents listed below, or as revised... [including the] Emergency Plan..."

Emergency Plan, Section 7.3 "Drills and Exercises" states, in part, that "Overall drill and exercise conduct is controlled and evaluated using the following guidelines: Post-drill and post-exercise critiques will be conducted by those involved and appropriate improvements will

14 be implemented."

Emergency Plan, Section 7.4, Exercise Critiques states, in part, The Emergency Plan Implementing Procedures are reviewed after each exercise, against the evaluation findings from the exercise. Exercise evaluations can be very helpful in identifying potential process changes, kinds of material at risk, changes in facility layout, and personnel staffing changes.

The Emergency Plan and Emergency Plan Implementing Procedures are then revised to reflect any changes deemed appropriate as a result of the evaluation.

The inspectors noted that during the exercise critiques, the failure to follow the Earthquake Response procedure, the implementation of IROFS39A, and building re-entry hazards were not identified or discussed by the licensee staff or other participants. The modification of the drill exercise to remove the implementation steps for IROFS39A did not allow the licensee to effectively evaluate the Emergency Plan Implementation Procedure.

Corrective Actions: The licensee has entered the issue into their corrective action program as EV 151516 and will evaluate for corrective actions to be taken.

Corrective Action

References:

EV 151516 Analysis: Section 6.2.d.7 of the Enforcement Policy contains the following example of a SLIV violation related to emergency response: "A licensee fails to meet or implement any emergency planning standard or requirement not directly related to assessment and notification (e.g., emergency response training, emergency equipment maintenance)."

IMC 0616, Appendix B, "Examples of Minor Violations," Section 8, "Emergency Preparedness," example 8.e, is similar to this case. In example 8.e, the violation is "Not Minor If" a licensee fails to correct an identified deficiency.

There was no actual significance to the violation because it occurred during an emergency exercise. The potential significance is very low because it involved failure to identify, and therefore correct, deficiencies that were revealed during emergency exercises. Specifically, related to the licensee's actions that are required following the occurrence of a major earthquake that damages the facility and creates an unsafe condition for operators.

Enforcement:

Violation: Safety Condition 10 of License SNM-2010 states, in part, that "The licensee shall conduct authorized activities in accordance with the statements, representations, and conditions of the documents listed below, or as revised... [including the] Emergency Plan..."

Emergency Plan, Section 7.3 "Drills and Exercises" states, in part, that "Overall drill and exercise conduct is controlled and evaluated using the following guidelines:... Post-drill and post-exercise critiques will be conducted by those involved and appropriate improvements will be implemented."

Contrary to the above, on May 11, 2022, the licensee's post-exercise critiques failed to identify appropriate improvements so that they could be implemented.

Although emergency planning standards do not apply to URENCO, the requirements of URENCO's emergency plan are similar so this violation aligns with Enforcement Policy example 6.2.d.7 of an SLIV violation. Likewise, minor/more-than-minor example 8.e of IMC 0616 is similar because the licensee cannot correct deficiencies that were not identified.

15 Therefore, the inspectors conclude that this violation is more-than-minor and aligns with a SLIV violation based on the IMC 0616 and enforcement policy examples.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

The disposition of this violation closes URI: 07003103/2022002-02.

WER (Discussed)

RETRACTED UF6 Leakage Inside Autoclave (EN55930)

WER 07003103/2022-005-00 88020

==

Description:==

On June 7, 2022, an operator was performing a disconnect sequence on a UF6 cylinder within autoclave 3LS1 in accordance with procedure OP-3-0470-01, Liquid Sampling System. While the operator was inspecting the cylinder through a viewing port, he identified a white/yellowish film on the manifold hex nut and cylinder valve. The operator paused further activities and notified his supervision about a suspected UF6 leak. On June 7, 2022, the licensee initially reported the leak event to the NRC, declaring that IROFS28 was inoperable.

On June 10, 2022 the licensee retracted the event notification based on a follow-up engineering analysis on the leak relative to the specific safety functions of IROFS28. IROFS28 maintains leak tight integrity of the autoclave for accident sequences defined as EE-SEISMIC and EE-TORNADO MISSILE-SBM-PUBLIC by providing physical protection of the sampling manifold/sample vessels and the 30B cylinder per NEF-BD-28 (IROFS Boundary Definition). Specifically, IROFS28 function is not defined to specifically prevent/contain a leak of the sampling manifold connections; it is IROFS10 that is specifically identified to maintain product liquid sampling autoclave leak tight integrity.

IROFS10 is a design feature to maintain product liquid sampling autoclave leak tight integrity. In 51-2400533-02-LES, "Blending and Liquid Sampling System HAZOP and Risk Determination Analysis," Rev. 14, a UF6 leak from the manifold to the interior of the autoclave is considered as the hazard the IROFS protects against. IROFS10 was functional and successfully contained the UF6 leak within the autoclave. The licensee is continuing to follow up on the event through their corrective action program, referenced as EV 151830.

NRC inspectors followed-up on the event during the onsite operational safety inspection.

Specific actions included: reviewed licensee documentation reference above, performed walkdowns of the autoclaves, accompanied an operator who was performing similar UF6 cylinder disconnect activities in another autoclave, reviewed samples of the operating procedures, and verified samples of supporting documentation related to the event. The inspectors determined there was no actual safety or security significance associated with this minor leak. The inspectors verified the licensees procedural compliance and that they continued to follow up with their corrective actions program activities to identify improvements that would prevent recurrence.

WER 07003103/2022-005-00, "UF6 LEAKAGE INSIDE AUTOCLAVE (EN55930)" was reviewed. No violations of NRC requirements were identified, therefore, the WER is closed.

URI (Discussed)

Unanalyzed Condition of Vehicles within the CAA URI 07003103/2022006-02 88020

16

==

Description:==

The inspectors reviewed Urenco's Root Cause Analysis with regard to the analysis of additional vehicles for IROFS50 controls. The ISA accident sequence OC2-1 applies specifically to external site preparation construction vehicles. As part of the root cause analysis, the licensee identified Urenco-owned site preparation construction equipment that met the size and maximum speed thresholds to potentially need additional IROFS50 type controls. Additionally, the root cause analysis identified other vehicles that were not considered site preparation construction vehicles that met the size and maximum speed thresholds to potentially need controls.

Some of the corrective actions from the root cause analysis include analyzing additional vehicles for IROFS50 controls:

Corrective Action 1.1 - Change PR-3-2000-02, Purchase Requisitions, scope of work to include heavy equipment evaluation by ISA.

Corrective Action 1.4 - Define through the ISA process additional vehicles needing control and/or create a list and subsequent controlled document of ISA approved vehicles not needing additional controls The root cause evaluation extent of condition also identified 40 work orders between 2016 and 2022 where site preparation vehicles have been used without IROFS50 proximity controls in place. EV 149759, EV 149990, EV 151002, and EV 151025 were created to evaluate additional vehicles in the CAA.

As part of the follow-up analyses, the ISA for IROFS50 series will be re-evaluated under action item AC 171013. This will include accident sequence descriptions, IROFS and IROFS boundaries, all vehicle usage and applicability to the IROFS50 series, and barrier requirements.

WER 07003103/2022-002-00, "Instances of Unanalyzed Conditions Associated with IROFS50b/c (EN55802)" is closed to this URI. This URI will remain open while the licensee's analyses of additional vehicles that may require controls is ongoing.

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

On August 25 and September 1, 2022, the inspectors presented the Results of the ENV and OPS inspections and the SIT follow-up inspection results to Karen Fili and other members of the licensee staff.

17 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 88020 Engineering Evaluations Root Cause Evaluation: Construction Equipment Brought into CAA Prior to IROFS50 Series Declared Operable Rev. 3 88020 Engineering Evaluations Apparent Cause Evaluation NRU URI #4 Timeliness of Event Notification, EV 151363 Rev. 0 88020 Engineering Evaluations ISA-IAD-0034 Construction Vehicle Accident Probability Determination in Support of EV149740 Rev. 01 88020 Engineering Evaluations ISA-MEM-0014 Operate While Constructing IROFS 50 Series Rev. 16 88020 Miscellaneous EN55770 Retraction Retracted Failure to Implement IROFS50b/c 04/25/2022 88020 Miscellaneous EN55802 Instances of Unanalyzed Conditions Associated with IROFS 50b/c 03/25/2022 88020 Miscellaneous EN55956 Loss of an Item Relied on for Safety 06/22/2022 88020 Miscellaneous LES-22-107-NRC 60 Day Follow up Report IROFS50b/c Independence 08/18/2022 88020 Miscellaneous LES-22-113-NRC 60 Day Report for EN 55770 09/01/2022 88020 Miscellaneous NEF-BD-50b Administratively Control Proximity of Vehicles by Use of Barriers Rev. 9 88020 Miscellaneous NEF-BD-50c Administratively Control Proximity of Vehicles by Use of Barriers Rev. 9 88020 Miscellaneous ORM 50b-50c Administratively Control Site Construction Vehicles Near the Areas of Concern Rev. 5 88020 Miscellaneous PPL-22-03 Stop Work for Site Preparation Vehicles in the CAA 03/07/2022 88020 Miscellaneous PPL-22-08 Lifting of Stop Work for Vehicles Inside CAA 03/30/2022 88020 Procedures OP-3-1000-16 IROFS 50b External Boundary Control Rev. 10 and Rev. 11 88020 Procedures OP-3-1000-17 IROFS50c External Boundary Control Rev. 11 and Rev. 12 88020 Procedures OP-3-1000-24 Managing IROFS50 Areas of Concern Rev. 5 88020 Work Orders WO 1000509387 SBM 1991 Chiller Project Earthwork #1 08/16/2021 88020 Work Orders WO 1000537772 SBM 1001 Chill Water Project IROFS50 02/16/2022 88045 Calibration Records WO#:

1000496667 CRDB: 562 Alpha Monitor Flow Meter Cal 01/26/2022

18 Inspection Procedure Type Designation Description or Title Revision or Date 88045 Calibration Records WO#:

1000496668 SBM3: 562 Alpha Monitor Flow Meter Cal 02/12/2022 88045 Calibration Records WO#:

1000516878 i-Matic Unit Alpha and Beta Detector 01/11/2022 88045 Calibration Records WO#:

1000530386 2W: Check ENV Samplers 05/05/2022 88045 Calibration Records WO#:

1000535825 2W: Check ENV Samplers 05/19/2022 88045 Calibration Records WO#:

1000535826 2W: Check ENV Samplers 06/03/2022 88045 Calibration Records WO#:

1000535827 2W: Check ENV Samplers 06/17/2022 88045 Calibration Records WO#:

1000535866 1M: Alpha MON Cartridge Change 05/09/2022 88045 Calibration Records WO#:

1000535867 1M: Alpha MON Cartridge Change 06/06/2022 88045 Calibration Records WO#:

1000536045 i-Matic Unit Alpha and Beta Detector 06/17/2022 88045 Calibration Records WO#:

1000538546 CRDB: 562-2MA2 PIS Flow Meter Cal 06/02/2022 88045 Calibration Records WO#:

1000539529 3M: SBM1 Alpha Monitor Maintenance 07/07/2022 88045 Calibration Records WO#:

1000539530 3M: SBM3 Alpha Monitor Maintenance 07/21/2022 88045 Calibration Records WO#:

1000539531 3M: CRDB Alpha Monitor Maintenance 07/18/2022 88045 Calibration Records WO#:

1000539532 3M: SBM5 Alpha Monitor Maintenance 07/07/2022 88045 Calibration Records WO#:

1000541276 1100-562--2MA2-PIS Flow Meter Stuck 06/10/2022 88045 Miscellaneous Training Records for Environmental Protection Manager 88045 Miscellaneous Organizational Chart - Environmental Protection Department/Chemistry Department 88045 Miscellaneous Semi-Annual Radiological Effluent Release Report for Jan 1, 08/30/2021

19 Inspection Procedure Type Designation Description or Title Revision or Date 2021 through June 30, 2021 88045 Miscellaneous Semi-Annual Radiological Effluent Release Report for July 1, 2021 through December 31, 2021 02/25/2022 88045 Miscellaneous 2021-E-10-101 Vendor Evaluation Report - Eberline Analytical 11/30/2021 88045 Miscellaneous 2022-E-08-012 Vendor Evaluation Report - Cardinal Laboratories 08/12/2022 88045 Miscellaneous 2022-E-08-013 Vendor Evaluation Report - Green Analytical Laboratories 08/16/2022 88045 Miscellaneous 2022-E-08-014 Vendor Evaluation Report - GEL Laboratories, LLC 08/17/2022 88045 Miscellaneous CHSOILTPE00 Task Performance Evaluation - Collection of Environmental Soil and Vegetation Samples 08/23/2022 88045 Miscellaneous Event 151162 Low pH Discharge to Pond 1 04/08/2022 88045 Miscellaneous Event 151301 Tracking - GEVS outage to support alpha monitor energy calibrations 04/22/2022 88045 Miscellaneous Event 154128 Possible temporary loss of alpha monitoring in 1003 07/02/2022 88045 Miscellaneous Event 156393 Effect of non-conformance not adequately documented 10/10/2021 88045 Miscellaneous LES-21-170-NRC Response to Request for Supplemental Information Regarding Decommissioning Financial Assurance Estimate 12/21/2021 88045 Miscellaneous QA-3-2000-02 Commercial Grade Survey Revision 6 88045 Miscellaneous QA-3-2000-08 Approved Supplier List Revision 16 88045 Miscellaneous QA-3-4000-02 Approved Vendors List Revision 1 88045 Procedures EN-2-1010-02 Radiological Effluent Monitoring Program (REMP)

Revision 5 88045 Procedures EN-3-2020-01 EN Air Sampling Revision 7 88045 Procedures EN-3-2020-02 EN Media Sampling Revision 8 88045 Procedures EN-3-3010-01 Alpha Monitor (ABPM 201S) Operation and Maintenance Revision 3 88045 Procedures EN-3-3010-02 Alpha Monitor (ABPM 201S) Calibration Revision 7 88045 Procedures EN-3-3020-01 MacGiver HF-2 Operation and Maintenance Revision 1 88045 Procedures EN-3-3020-02 MacGiver HF-2 Calibration Revision 3 88045 Procedures RW-3-1000-07 Shipping Hazardous, Non-Hazardous and Universal Waste Revision 6 88045 Procedures RW-3-1000-13 Shipping Radioactive and Mixed Waste Revision 8 88045 Procedures RW-3-3000-12 Operation of the Segmented Gamma Scanner Revision 4 88045 Self-Assessments 2022-A-03-005 Report for Urenco USA Environmental Compliance NQA-1 Biennial Audit 05/08/2022 88045 Work Orders WO#:

1000545181 SBM3: 562-1MA1 No Power to LPDU 05/03/2022

20 Inspection Procedure Type Designation Description or Title Revision or Date 88045 Work Orders WO#:

1000549158 1003: 562-1MA1 Stack Status Not OK 05/13/2022