ML24296A071

Global Nuclear Fuels - America – Core Inspection Report 07001113-2024003

ML24296A071
Person / Time
Site:	07001113
Issue date:	10/23/2024
From:	Bradley Davis NRC/RGN-II/DFRSS/FOB1
To:	Huth R Global Nuclear Fuel
References
IR 2024003
Download: ML24296A071 (12)

Text

Doug Nay Facility Manager Global Nuclear Fuel - America, LLC PO Box 780, Mail Code J20 Wilmington, NC 28402

SUBJECT:

GLOBAL NUCLEAR FUELS - AMERICA - CORE INSPECTION REPORT 07001113/2024003

Dear Doug Nay:

This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection activities conducted from July 1, 2024, to September 30, 2024, for Global Nuclear Fuels - America. On August 8, 2024, the NRC inspectors discussed the results of these inspections with you. The results of these inspections 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, Bradley J. Davis, Chief Fuel Oversight Branch 1 Division of Fuel, Radiological Safety, and Security Docket No. 07001113 License No. SNM-1097

Enclosure:

As stated cc w/ encl: Distribution via LISTSERVOctober 23, 2024 Signed by Davis, Bradley on 10/23/24

ML24296A071 SUNSI Review Non-Sensitive Publicly Available Sensitive Non-Publicly Available

OFFICE RII/DFRSS RII/DFRSS RII/DFRSS RII/DFRSS

NAME L. Pitts N. Peterka J. Raudabaugh B. Davis DATE 10/22/2024 10/22/2024 10/23/2024 10/23/2024 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Number: 07001113

License Number: SNM-1097

Report Number: 07001113/2024003

Licensee: Global Nuclear Fuel - America, LLC

Facility: Global Nuclear Fuels - America

Location: Wilmington, NC

Inspection Dates: August 05, 2024 to August 08, 2024

Inspectors: N. Peterka, Sr. Fuel Facility Project Inspector J. Raudabaugh, Fuel Facility Inspector

Approved By: Bradley J. Davis, Chief Fuel Oversight Branch 1 Division of Fuel, Radiological Safety, and Security

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a core inspection at Global Nuclear Fuels - America, 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.

2 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 70.24, 70.61, 70.62, and Appendix A, Chapter 5, Nuclear Criticality Safety, of the facilitys license application, and applicable licensee procedures.

Criticality Analysis (IP Section 02.01)

The inspectors interviewed licensee staff and reviewed nuclear criticality safety analyses (CSAs), and associated assumptions and calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including 3.3.3, 5.1.1, 5.3.1, 5.4.2, 5.4.4, 5.4.5.5 and 5.4.5.6. Specifically, the inspectors interviewed licensee staff and reviewed the following CSAs and Quantitative Risk Analysis (QRA):

• CSA 205.00.100, "DCP Homogenization Process," Revision (Rev.) 1, including the review of accident sequences 2050.3, 2050.7, and 2050.20, which cover various upset scenarios related to criticality safety in the homogenizer system such as high moderator material enters the system, moderator leaks onto the homogenizer, and moderator enters the homogenizer through the internal oil reservoir

• CSA 801.00.100, "General Can Storage," Rev. 6, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences

• CSA 802.00.100, "Scrap Hoods, Utility Hoods, and Vacuums," Rev. 3, including the review of what-if analysis, normal, and credible abnormal accident sequences

• QRA-205A, "Dry Conversion Process: Homogenization," Rev. 6, which was reviewed because it contained a variety of information supporting the licensee's evaluation of accident sequences and items relied on for safety (IROFS) in CSA 205.00.100.

3 Criticality Implementation (IP Section 02.02)

The inspectors selected engineered and administrative controls from the licensees integrated safety analysis summary to verify proper implementation through a review of process and system descriptions, document review, and plant walkdowns to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors interviewed licensee staff and reviewed the following controls, and selected management measures, associated with the CSAs listed above:

• IROFS 205-02, "Homogenizer External Oil Volume," an administrative control (AC) limiting the amount of external moderator available, through walkdowns and review of operating procedures

• IROFS 205-03, "Homogenizer Lid Design," a passive engineered control (PEC) on moderator ensuring the integrity of the homogenizer lid, through walkdowns

• IROFS 205-04, "Non-Hydrogenous Oil," an AC on moderator limiting the internal oil used to non-hydrogen-based oil, through review of operating procedures

• IROFS 205-08, "Process Equipment Barrier," a PEC on moderator ensuring the integrity of the homogenizer and its associated support systems, through walkdowns

• IROFS 801-08, "Dry Can Floor Storage Area - Safe Geometry," an AC on geometry (with passive engineered components), through walkdowns of can storage areas and review of operating procedures.

• performed a walkdown of the Homogenization Process and select dry can floor storage areas and observed the storage of containers of uranic material, the material condition of the homogenizer, and postings for the moderator restricted area

Criticality Operational Oversight (IP Section 02.03)

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

• interviewed NCS staff regarding criticality safety hazards and control methods, and monitoring for accumulation of uranium within the Homogenization system

• reviewed NCS staff analysis of annual nondestructive assay surveys of heating and ventilation systems for uranium holdup/accumulation in 2024

• reviewed recent NCS audit reports and the 2024 audit schedule

• reviewed audit procedure WI-18-104-02, "Internal Nuclear Safety Audits"

4 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 2.2.1.6, 5.2.2 and 5.3.2.1. Specifically, the inspectors performed the following:

• reviewed the qualification and training records for a recently qualified senior NCS engineer

• discussed the NCS engineering qualification and training process with a recently qualified NCS engineer

• interviewed NCS staff concerning the NCS review of changes, including changes to operating procedures that may affect NCS, and changes to the facility

• reviewed the most recent revision to licensee procedure WI-27-105-25, "HVAC Surveys to Detect Uranium Accumulation," Rev. 10

Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees criticality accident alarm system (CAAS) and corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application, including 1.3.11, 5.3.2.5 and 5.3.2.6. Specifically, the inspectors reviewed documents, and/or interviewed licensee staff concerning the following:

• NCS-related CAP entries listed in the documents reviewed section of this report and associated documents (e.g. critique meeting minutes, root cause analyses)

• NCS analysis for Cesium-137 source decay which supports the CAAS source check distances

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 10 CFR 70.

5 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 70.32(i),

Chapter 9 of the license application, and the Emergency Plan. Specifically, the inspectors performed the following:

• reviewed the process for evaluating plant changes and modifications that could potentially impact the emergency preparedness program

• reviewed revisions to the emergency procedures that occurred since the last inspection to verify the overall effectiveness of the procedures had not been decreased due to those changes.

• reviewed training material and training records for the emergency preparedness organization including qualifications for new members of the Emergency Organization (EO) and Emergency Response Organization (ERO)

• reviewed emergency preparedness equipment surveillance records since the last inspection, including:

o quarterly medical clinic surveillance o quarterly procedure surveillance for Emergency Control Center (ECC) o quarterly Radiation Protection surveillance for offsite hospital o quarterly ECC and Alternate ECC surveillances o semi-annual evacuation route surveillance

• conducted interviews of select members of the EO and ERO, including the Emergency Preparedness Manager, Emergency Director, Fire Safety and Emergency Response Coordinator, and Nuclear Safety Advisor for Criticality

• conducted interviews and plant walkdowns of emergency equipment and storage and emergency facilities including the ECC, Alternate ECC, select assembly points, and emergency vehicles

• observed monthly Hydrogen Fluoride (HF) kit surveillance

• reviewed current Memorandums of Understanding agreements and reviewed training offered to offsite support agencies

• visited and interviewed offsite support agencies including the local hospital and fire department

• reviewed drill and exercise records to verify that the licensee was performing the required drills and that items identified during drill critiques were being captured and addressed

• observed tropical storm Debbie preparation status meeting

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:

• 2022 Radiological Contingency and Emergency Plan Audit (dated September 2022) of the emergency preparedness program

• 2023 Radiological Contingency and Emergency Plan Audit (dated November 2023) of the emergency preparedness program

• corrective actions as documented in the documents reviewed section of this inspection report

6 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 70.32(i), Chapter 9 of the license application, and the Emergency Plan. Specifically, the inspectors reviewed the following:

• implementation of the emergency plan associated with internal, nonreportable activations and temporary compensatory measures that included:

o HF Line Leak - July 15, 2022 o DCP Arc Flash Event - January 13, 2024

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 August 08, 2024, the inspectors presented the NCS and Emergency Preparedness inspection results to Ryan Huth and other members of the licensee staff.

7 DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 88015 Corrective Action CR #41745, NCS-related CAP Entries, accessed during inspection Various Documents 43690, 46185, 46214, 46215, 46216, 46217, 46265 Engineering CSA 205.00.100 Criticality Safety Analysis - DCP Homogenization Process Rev. 1 Evaluations CSA 208.00.100 Criticality Safety Analysis - DCP MRA Facility and Powder Rev. 4 Containers CSA 801.00.100 Criticality Safety Analysis - General Can Storage Rev. 6 CSA 802.00.100 Criticality Safety Analysis - Scrap Hoods, Utility Hoods, and Rev. 3 Vacuums NSA-900.06.101 Determination of Distance Between the Source and CAAS Rev. 0 Detector for Detector Functionality Test PHA-204-205-206 ISA Reference Report for the DCP Powder Node Group Rev. 12 PHA-801-802 ISA Reference Report for the 801-802 Node Group Rev. 11 PHA-807 ISA Reference Report for the 807 Node Group Rev. 4 QRA-205A Dry Conversion Process: Homogenization Rev. 6 QRA-801/802 Auxiliary Operations Rev. 20 QRA-807 Utilities Rev. 5 Miscellaneous NS-2024-02 NDA Program Annual Review 02/26/2024 Procedures CP-20-103 Nuclear Safety Training Rev. 3 CP-20-314 Criticality Safety Engineer Training and Qualification Rev. 1 CP-20-314-G01 Criticality Safety Engineer Training Guide Rev. 0 CP-27-104 Nuclear Safety Assurance Rev. 3 OP 1001.00.201 Fabrication General - Operations Rev. 20A OP 205.00.209 DCP Homogenization - Basic Operator Maintenance Rev. 05 WI-18-104-02 Internal Nuclear Safety Audits Rev. 6 WI-27-104-03 Nuclear Safety Reviews Rev. 5 WI-27-104-04 Nuclear Safety Design Criteria Rev. 4 WI-27-104-07 Nuclear Safety Release Requirements Rev. 4 WI-27-104-15 NCS Calculational Methods and Verification Rev. 5

8 Inspection Type Designation Description or Title Revision or Procedure Date WI-27-105-25 HVAC Surveys to Detect Uranium Accumulation Rev. 10 Self-Assessments 2Q2024 Nuclear Safety Audit - Node 805 Support Labs, 04/05/2024 Node 807 Utilities 2Q24 Nuclear Safety Audit - Rad Waste - Node(s) 702, 703 06/14/2024 (Aeration/Process Lagoons) 2Q24 Nuclear Safety Audit - Sintering & Grind Operations - 06/28/2024 Nodes 405-406 & 504-505 2Q2024 Nuclear Safety Audit - UO2/UO2-Gad Press/Press 06/14/2024 Feed/UO2-Gad Vibromill and Tumbler 2024Q2 Nuclear Safety Audit - 205, 206, 208: 06/21/2024 Homogenization, BPG & Tumble, Miscellaneous 88050 Corrective Action CR # 44808, EP Related CAP entries reviewed during inspection Various Documents 44885, 44284, 44283, 42609, 40200 Miscellaneous NHCo Sherriff MOU 08/17/2023 NH NHRMC MOU 04/26/2023 NHCFR MOU 04/26/2023 Emergency Organization Training Verification Report 07/18/2024 ERO Role Training Report 08/08/2024 NHCo EM MOU 05/03/2023 Procedures CP-20-108 Radiological Contingency and Emergency Plan Training Rev. 3 CP-28-112 Radio Communications Equipment Rev. 5 CP-28-113 RC&EP Surveillance & Maintenance Rev. 5 CP-28-114 Wilmington Site Emergency Planning Rev. 3.1 CP-28-116 Emergency Preparedness Drills and Exercises Rev. 0.3 WI-20-108-01 Emergency Organization Initial Qualification and Rev. 6 Requalification Training WI-20-108-02 Emergency Organization Training Lesson Plans Rev. 4 WI-20-108-03 Emergency Organization Qualification Cards Rev. 5 WI-20-108-04 Emergency Response Organization Initial and Continuing Rev. 0 Training WI-28-114-01 Emergency Director Rev. 1.1

9 Inspection Type Designation Description or Title Revision or Procedure Date WI-28-114-02 Licensing Advisor Rev. 0.2 WI-28-114-03 Recorder Rev. 1.1 WI-28-114-04 Nuclear Safety Advisor Rev. 4 WI-28-114-05 Environmental Health and Safety Advisor Rev. 2.3 WI-28-114-06 Security Advisor Rev. 2 WI-28-114-07 Communications Advisor Rev. 5 WI-28-114-08 Building Manager Rev. 3 WI-28-114-09 Field Monitoring Team Management Rev. 4 WI-28-114-10 Emergency Response Organization Operations Rev. 3 WI-28-114-11 Staging Area Supervisor Rev. 2 WI-28-114-12 Severe Weather Preparations Rev. 1 WI-28-114-13 Termination and Recovery Rev. 0.1 WI-28-114-14 Protective Actions Rev. 2.2 WI-28-114-15 Emergency Organization Activation Rev. 7 WI-28-114-16 Emergency Classification & Notification Rev. 5 WI-28-114-17 Hazard Assessment Rev. 2.3 WI-28-114-18 Pre-Fire Plan Maintenance and Control Rev. 1 WI-28-118-01 Emergency Plan Review Guide Rev. 3 WI-28-118-02 Emergency Organization Administration Rev. 0 WI-28-118-03 Notification Database Maintenance Rev. 4.1

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