ML22301A044
| ML22301A044 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 10/31/2022 |
| From: | Robert Williams NRC/RGN-II/DFFI |
| To: | Nay D Global Nuclear Fuel - Americas |
| References | |
| IR 2022003 | |
| Download: ML22301A044 (11) | |
Text
October 31, 2022 Doug Nay Facility Manager Global Nuclear Fuel - Americas, LLC P.O. Box 780, Mail Code J20 Wilmington, NC 28402
SUBJECT:
GLOBAL NUCLEAR FUEL - AMERICAS, LLC - CORE INSPECTION REPORT 07001113/2022003
Dear Doug Nay:
On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Global Nuclear Fuel - Americas, LLC and 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, Signed by Williams, Robert on 10/31/22 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
ML22301A044 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME J. Rivera-Ortiz N. Peterka L. Cooke P. Glenn R. Williams DATE 10/20/2022 10/21/2022 10/27/2022 10/25/2022 10/31/2022 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07001113 License Number: SNM-1097 Report Number: 07001113/2022003 Enterprise Identifier: I-2022-003-0058 Licensee: Global Nuclear Fuel - Americas, LLC Facility: Global Nuclear Fuel - Americas, LLC Location: Wilmington, NC Inspection Dates: July 25, 2022 to July 29, 2022 Inspectors: P. Glenn, Fuel Facilities Inspector N. Peterka, Fuel Facility Inspector Approved By: Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Enclosure
SUMMARY
The U.S. NRC continued monitoring the licensees performance by conducting a core inspection at Global Nuclear Fuel - Americas, LLC, 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, Part 70 (10 CFR 70), including 70.61 and 70.62; Chapter 5.0, 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 associated assumptions and calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including Sections 5.1.1, 5.4.4, and 5.4.5. Specifically, the inspectors interviewed licensee staff and performed the following activities:
reviewed CSA 704.00.100, "Incinerator Building", Revision (Rev.) 3, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences and the items relied on for safety (IROFS) that were established to prevent criticality reviewed CSA 301.00.100, "Dry Scrap Recycle Oxidation Process", Rev. 2, including the review of accident sequences 3010.1, 3010.2, and 3010.4, which cover various criticality accident scenarios including moderator upsets and loss of geometry controls reviewed the licensee's basis for screening certain accident sequences as non-credible in CSA 706.00.100, "Outside Storage Pads", Rev. 2 walked down the existing Incinerator System, Dry Scrap Recycle Oxidation Process, and the outside storage pads with licensee engineers 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, record reviews, and operator interviews to verify compliance with 10 CFR 70 and applicable sections of the license application, including Sections 5.4.2, and 11.3.4. Specifically, the inspectors interviewed 3
licensee staff, conducted walkdowns in the Radwaste System and control room, and reviewed the following controls, and their management measures, associated with the Radwaste System:
IROFS 301-01, "Furnace Feed Hopper Overfill Interlock," an augmented administrative control in the Dry Scrap Recycle Oxidation Process, and its IROFS training document IROFS 701-01, "Trash Uranium Restrictions," an administrative control in the Decon Facility, its IROFS training document, and function test documentation IROFS 704-09, "Incinerator Mass Controls," an administrative control in the Incinerator area, and its IROFS training document 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, including Sections 5.3.2.2, 5.4.1.1, and 11.4.2.2. Specifically, the inspectors performed the following activities:
observed a licensee NCS engineer perform a verification of passive engineered controls in the GAD Dry Scrap Recovery area reviewed the current audit schedule and audit procedure WI-18-104-02, "Internal Nuclear Safety Audits" interviewed Decon Facility operators on the IROFS in the area and the associated operating procedures Criticality Programmatic Oversight (IP Section 02.04)
The inspectors reviewed NCS program procedures and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the license application, including Sections 2.2.1.6, 5.1.4, and 5.3.2.1. Specifically, the inspectors performed the following activities:
reviewed two NCS engineer qualification records and discussed the NCS engineer qualification and training process with NCS staff reviewed WI-27-104-05, "Nuclear Criticality Safety Posting and Labeling" interviewed NCS staff concerning the NCS review of changes, including changes to operating procedures that may effect NCS, and changes to the facility Criticality Incident Response and Corrective Action (IP Section 02.05)
The inspectors reviewed the licensees criticality accident alarm system (CAAS) and implementation of the corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application, including Section 5.3.2.6. Specifically, the inspectors performed the following activities:
reviewed selected issues entered in the CAP related to NCS and NCS-related IROFS; including selected condition reports identified by NCS staff during their audits 4
reviewed selected 2021 surveillance and maintenance records for the CAAS FACILITY SUPPORT 88050 - Emergency Preparedness The inspectors evaluated selected aspects of the licensees emergency preparedness program to determine whether the program is maintained as required by the Emergency Plan, the license and license application, and NRC requirements in 10 CFR Part 70.
Emergency Preparedness Program Review and Implementation (IP Section 02.01)
The inspectors selected the following elements that support the implementation of the licensees emergency preparedness program to verify compliance with 10 CFR 70.22(i)(3),
Chapter 9 of the license application, and the Emergency Plan. Specifically, the inspectors conducted the following inspection activities:
reviewed changes to the emergency preparedness program, including annual updates to the Emergency Plan reviewed revisions to the Emergency Plan Implementing Procedures (EPIP) that were revised since the last NRC inspection, including revised EPIPs focused on Staging Area Supervisor (WI-28-114-11) and Security Advisor (WI-28-114-06) reviewed training and staffing of the emergency preparedness organization including minimum staffing requirements and qualifications for new members of the Emergency Organization and Emergency Response Organization reviewed training records and conducted interviews of select members of the Emergency Organization and Emergency Response Organization, including the Emergency Director, Interim Emergency Director, Building Manager, Incident Commander, Nuclear Safety Advisor for Criticality review current Memorandums of Understanding agreements and reviewed training offered to offsite support agencies visited and interviewed off site support agencies that included the local hospital and county emergency management conducted interviews related to the 2022 biennial emergency exercise and reviewed records associated with the most recent criticality evacuation and accountability drill conducted interviews, reviewed records, and conducted plant walkdowns of emergency equipment and storage and emergency facilities that included the Emergency Control Center, Alternate Emergency Control Center, Offsite Emergency Operations Center, staging areas, select assembly points, and emergency vehicles Identification and Resolution of Problems (IP Section 02.02)
The inspectors reviewed the licensees identification and resolution of emergency preparedness issues to verify compliance with the license requirements. Specifically, the inspectors reviewed the following CAP entries, audits, and self-assessments:
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reviewed the 2021 GNFA Radiological Contingency and Emergency Plan audit (dated February 23, 2022) of the emergency preparedness program reviewed corrective actions as documented in the documents reviewed section of this inspection report Event Review (IP Section 02.03)
The inspectors reviewed the licensees safety-significant and internal events related to emergency preparedness to verify compliance with 10 CFR 70.22(i)(3), Chapter 9 of the license application, and the Emergency Plan. Specifically, the inspectors performed the following activities:
reviewed implementation of the Emergency Plan associated with internal, nonreportable activations and temporary compensatory measures that included:
o Invalid activation of the emergency alarm annunciation, July 19, 2021 o Dry Conversion Process transformer fire, July 28, 2021 o Interim Emergency Director, Temporary Operating Procedures 28755 and 50029 INSPECTION RESULTS No violations of more than minor significance were identified.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On July 28, 2022, the inspectors presented the Nuclear Criticality Safety (88015) and Emergency Preparedness (88050) 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 Corrective Action CR 29232, 39893, Documents 39996 Engineering CSA 207.01.100 Criticality Safety Analysis Powder Receipt Rev. 2 Evaluations CSA 301.00.100 Criticality Safety Analysis Dry Scrap Recycle Oxidation Rev. 2 Process CSA 304.00.100 Criticality Safety Analysis Dry Scrap Recycle MRA Process Rev. 0 CSA 704.00.100 Criticality Safety Analysis Incinerator Building Rev. 3 CSA 706.00.100 Criticality Safety Analysis Outside Storage Pads Rev. 2 CSA-101.01.100 Criticality Safety Analysis 30B UF6 Cylinder Storage CAAS Rev. 1 Needs Evaluation CSA-706-.00.101 Criticality Safety Analysis Outside Storage Pads CAAS Needs Rev. 1 Evaluation QRA-706/704 Pads/Incinerator Rev. 15 Miscellaneous 2022 Incinerator Shutdown Work List Incinerator Photos 2014 Incinerator Photos 2022 LS 2310.00.03 CAAS Annual Test Summary 2021 LS 2310.00.06 Detector Functionality Test Log 11/09/2021 LS 2310.00.06 Detector Functionality Test Log 11/10/2021 LS 2310.00.07 Detector Trip Test 2 Out of 3 Functionality Conducted 12/29/21 LS 2310.00.08 PIP Tone Test Log 2021 Procedures CP-18-104 EHS Regulatory Compliance Audits Rev. 3.1 CP-20-103 Nuclear Safety Training Rev. 2.1 CP-20-314 Criticality Safety Engineer Training and Qualification Rev. 0 OP 1080.20.202 Decon Facility - Waste Box Normal Operations Rev. 05 OP 1081.01.206 Incinerator - Basic Operator Maintenance Rev. 09 OP-1080.20.100 Decon Facility - General Information Rev. 08 WI-18-104-02 Internal Nuclear Safety Audits Rev. 5 WI-27-104-03 Nuclear Safety Reviews Rev. 4 WI-27-104-05 NCS Posting and Labeling Rev. 2 7
Inspection Type Designation Description or Title Revision or Procedure Date Self-Assessments Q2 2022 NCS Audit - Sintering Furnaces, Boat Storage, 06/29/2022 Grinder, Inspection, and Tray Storage 2Q2022 Nuclear Safety Audit - Node 805 Engineering Labs 06/22/2022 and Node 807 Utilities 2Q2022 NCS Audit - Radwaste, Laundry, Waste Treatment, 06/27/2022 Aeration Basin, Lagoons 2022Q2 Nuclear Safety Audit - 205A, 206A, 206: 06/30/2022 Homogenization, BPG & Tumble, powder containers and Dry Conversion Process (DCP) miscellaneous Work Orders OP 1080.20 Fill Cart Monitor System FTI Conducted 05/04/2022 88050 Corrective Action 37137 Documents 37340 37591 37730 38676 38893 39376 Corrective Action 40112 Documents 40116 Resulting from 40119 Inspection 40120 40200 Miscellaneous Emergency Organization and Emergency Response Organization Position Specific Training Records (Emergency Organization and Emergency Response Organization, including Emergency Director, Interim Emergency Director, Building Manager, Incident Commander, Nuclear Safety Advisor for Criticality)
Emergency Organization Minimum Staff Completion Records 11/08/2021 Offsite Agency Training 09/29/2021 Offsite Agency Training 09/30/2021 Offsite Agency Training 10/01/2021 EO Phone List Roster 06/17/2022 8
Inspection Type Designation Description or Title Revision or Procedure Date NHRCM MOU 07/03/2019 NHCo Sheriff MOU 12/03/2019 NHCo Fire Services MOU 05/03/2019 NHCo EM MOU 07/02/2019 2021/2022 Emergency Organization Training Needs 07/26/2022 GNFA RC&EP Audit 02/23/2022 Monthly Radiation Protection (RP) Surveillance (ECC) Records 05/26/2021 Monthly RP Surveillance (ECC) Records 06/01/2022 Quarterly Alternate ECC Surveillance Records 06/30/2022 Quarterly Alternate ECC Surveillance Records 12/03/2021 Monthly Staging Area Surveillance Records 03/16/2022 Monthly Staging Area Surveillance Records 07/13/2021 Semi-Annual Evacuation Route Surveillance Records 10/06/2021 Semi-Annual Evacuation Route Surveillance Records 07/28/2022 HF Acid Leak Activation Package and Records 07/15/2022 EP-001 & EP 003 Basics Activations Training and Completion Records 02/22/2022 EP-010 EO Requal Training and Completion Records 10/04/2021 EP-011 Annual Requal Training and Completion Records 11/01/2021 M220006 Revision to GNFA RC&EP 01/07/2022 Procedures CP-16-108 Corrective Action Program Rev. 13.3 CP-28-113 RC&EP Surveillance & Maintenance Rev 4.1 CP-28-113-F17 Weekly Squad-1 Surveillance Rev. 0.1 CP-28-113-F18 Weekly Engine-2 Surveillance Rev. 0.1 CP-28-113-F19 Weekly Medic-1 Surveillance Rev. 1.0 CP-28-114 Wilmington Site Emergency Planning Rev 3.0 CP-28-116 Emergency Preparedness Drills and Exercises Rev. 0.2 CP-28-134 Wilmington Site Emergency Response Organization Rev. 0.0 F-07 ERO Admin Manual Rev. 19 TOP 26610 IED Compensatory Measure TOP 28755 IED Compensatory Measure for Covid-19 TOP 50029 IED Compensatory Measure for Covid-19 WI-28-114-06 Security Advisor Rev.1.1 WI-28-114-11 Staging Area Supervisor Rev. 1.3 9