ML25021A215
| ML25021A215 | |
| Person / Time | |
|---|---|
| Site: | 07003103 |
| Issue date: | 01/21/2025 |
| From: | Bradley Davis NRC/RGN-II/DFRSS |
| To: | Lorskulsint P Louisiana Energy Services, URENCO USA |
| References | |
| EN57246 IR 2024004 | |
| Download: ML25021A215 (22) | |
Text
EN57246 Paul Lorskulsint Chief Nuclear Officer Louisiana Energy Services (LES) dba Urenco USA (UUSA)
Urenco USA P.O. Box 1789 Eunice, NM 88231
SUBJECT:
URENCO USA - INTEGRATED INSPECTION REPORT 07003103/2024004
Dear Paul Lorskulsint:
On November 15, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at URENCO USA 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.
During this inspection period, the NRC conducted follow-up inspections for the Area Needing Improvement (ANI) discussed in URENCO USA-LICENSEE PERFORMANCE REVIEW-NUCLEAR REGULATORY COMMISSION INSPECTION REPORT 70-3103/2024-005, dated March 7, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession Number: ML24061A268). As a result of these inspections the ANI is being closed, and no further inspection of the ANI is planned.
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 Projects Branch 1 Division of Fuels, Radiological Safety, and Security Docket No. 07003103 License No. SNM-2010
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV January 21, 2025 Signed by Davis, Bradley on 01/21/25
SUNSI Review X
Non-Sensitive
Sensitive X
Publicly Available
Non-Publicly Available OFFICE RII/DFRSS RII/DFRSS RII/DFRSS RII/DFRSS RII/DFRSS NAME T. Shewmaker T. Sippel N. Peterka L. Cooke B. Davis DATE 1/21/25 1/21/25 1/21/25 1/21/25 1/21/25
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07003103 License Number:
SNM-2010 Report Number:
07003103/2024004 Enterprise Identifier:
I-2024-004-0050 Licensee:
Louisiana Energy Services (LES) dba Urenco USA (UUSA)
Facility:
URENCO USA Location:
Eunice, NM Inspection Dates:
November 11, 2024 to November 15, 2024 Inspectors:
L. Cooke, Fuel Facilities Inspector N. Peterka, Sr. Fuel Facility Project Inspector T. Shewmaker, Fuel Facilities Inspector T. Sippel, Sr. Fuel Facility Project Inspector Approved By:
Bradley J. Davis, Chief Projects Branch 1 Division of Fuels, Radiological Safety, and Security
2
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 No violations of more than minor significance were identified.
Additional Tracking Items Type Issue Number Title Report Section Status NOV 07003103/2022007-01 Failure to meet performance requirements in 10 CFR 70.61(b) by not establishing IROFS barriers 88020 Closed NOV 07003103/2022007-02 Loss of IROFS 50b/c independence 88020 Closed URI 07003103/2022006-02 Unanalyzed Condition of Vehicles within the CAA 88020 Closed WER 07003103/2024-003-00 ALERT - Seismic Activity Felt On-Site (EN57246) 88020 Closed
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 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees nuclear criticality safety (NCS) program to verify compliance with selected portions of Title 10 of the Code of Federal Regulations (10 CFR) 70, "Domestic Licensing of Special Nuclear Material," including 70.24, 70.50, 70.61, 70.62, Part 70 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 criticality safety analyses (CSAs),
and associated documentation and calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of 5.1.2, 5.2.1.2, 5.2.1.3, 5.2.1.4, and 5.2.1.6. Specifically, the inspectors interviewed licensee staff and reviewed the following CSAs and supporting documents:
NCS-CSA-006, Criticality Safety Analysis of the Product Vent Pump and Chemical Trap Set, Rev. 11, including a review of what if analysis, double contingency principle, normal, credible abnormal, and non-credible accident sequences NCS-CSE-040, Evaluation of Facility Rigs, Rev. 3, including a review of what-if analysis, normal, and credible abnormal accident sequences ETC4100854, Criticality Safety Analysis of the Contingency Dump System, Rev. 11, including a review of what if analysis, double contingency principle, normal, credible abnormal, and non-credible accident sequences NCS-CSA-025, Criticality Safety Analysis of UUSA Process Gas Pipework (All Assays), Rev. 4, including the review of engineering evaluation for implementing item relied on for safety (IROFS) 16a/e/f
4 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, and plant walkdowns to verify compliance with 10 CFR 70 and applicable sections of the license application, including portions of sections 5.1.1 and 5.1.2. Specifically, the inspectors interviewed licensee staff and reviewed the following IROFS associated with the Product Take-Off System, Mobile Rigs, and the Contingency Dump System:
administrative controls for oil and water moderation (IROFS16a/e/f) including review of applicable procedures and training administrative controls for hydrocarbon oil moderation (IROFS30a/b/c) including review of work orders and testing and training requirements the inspectors observed NCS postings in the field to verify they were posted as required and contained IROFS information the inspectors conducted walkdowns in Separation Building Modules (SBM) 1001, 1003, and 1005 including the Product Take-Off System and Contingency Dump System 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 portions of sections 5.1.1, 5.1.5, and 11.3.3.1.1. Specifically, the inspectors performed the following activities:
observed a licensee NCS engineer conduct a NCS walkdown of the Solid Waste Collection System inspectors observed a pressure transducer calibration supporting IROFS16e/f per procedure OP-3-0490-12, "Calibration of IROFS10 and 16 Series Pressure Transducers" inspectors observed a product system cylinder connection per procedure OP-3-0420-01, "Product System," specifically observing IROFS16a inspectors interviewed operators regarding applicable IROFS for product cylinder connection and their involvement with Nuclear Criticality Safety interviewed licensee NCS engineers and management concerning schedule, conduct, results, and documentation of the weekly NCS inspections and the NCS quarterly audits
5 Criticality Programmatic Oversight (IP Section 02.04)
The inspectors reviewed NCS program procedures, audits, and NCS staff qualifications records to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.1.1, 5.1.5, and 11.5. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:
reviewed operator qualifications for IROFS16, including qualifications for pressure transducer calibrations reviewed chemistry and maintenance qualifications for IROFS30 including sampling and analyzing non-hydrogenous oil interviewed NCS staff and supervision concerning schedule, staffing, conduct, results and performance of weekly NCS inspections reviewed the most recent Nuclear Criticality Safety Program Assessment reviewed qualification status for two NCS Engineers and interviewed the NCS Engineers about NCS training and qualification 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. Specifically, the inspectors observed activities, reviewed documents, and/or interviewed licensee staff concerning the following:
reviewed EV165818, "CAAS 1-year discrepancies" reviewed NCS-related corrective action documents listed in the documents section reviewed criticality drill reports for 2022 and 2023 interviewed maintenance personnel regarding CAAS maintenance and EV listed above interviewed the Safety and Emergency Response Manager regarding criticality evacuation drills 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 70.24, 70.61, 70.62, and Chapter 11, Management Measures, of the facilitys license application, and applicable licensee procedures.
6 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 NCS, radiation safety, fire safety, and chemical safety based on the information provided in the ISA summary. The inspectors conducted a general plant tour of the applicable plant operating areas. The process areas and accident sequences selected for review are listed below:
Urenco Technology Center TC1-1, Subsampling Rig Liquid in Cold Traps TC1-2, Subsampling Rig Heater Control TC2-1, Excess Uranic Samples Chem Lab CL3-2, Subsampling Rig Liquid in Cold Traps CL3-3, Subsampling Rig Heater Control Earthquake EE-Seismic, Excessive Seismic Motion EE-Seismic Worker Evac, Seismic Pipe Breach Review of Safety Controls and Related Programs (IP Section 02.02)
The inspectors reviewed information related to administrative, engineered, and passive safety controls or IROFS for the accident sequences selected 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:
IROFS24b, Administratively Establish Airflow Away from Worker (Admin)
IROFS24d, Administratively Establish Airflow Away from Worker (Admin)
IROFSC23, Centrifuge Design Feature (Passive)
IROFS27c, Seismic Design of Buildings (Passive)
IROFS27e, Seismic Design of Buildings (Passive)
IROFS28, Autoclave Integrity (Passive)
IROFS39a, Worker Evacuation (Admin)
IROFS39c, Worker Evacuation (Admin)
IROFS43, Subsampling Hotbox Heater Trip (Engineered)
IROFS46, Verify Samples in Solid State (Admin)
7 Implementation of Safety Controls (IP Section 02.03)
For the selected safety controls listed above, the inspectors reviewed 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:
walked down the Urenco Technology Center and chem lab inspectors observed a product system cylinder connection per procedure OP-3-0420-01, "Product System," specifically observing IROFS16a observed implementation of IROFS24b, 43, and 46 per procedure CH-3-1050-01 during sub-sampling rig operation interviewed chemistry staff regarding chemical IROFS interviewed control room staff regarding earthquake response IROFS observed implementation of IROFSC22 per OP-3-3300-04, Mass Balance Verification Data Sheet, Rev. 44 reviewed URN-23-003-RPT-02, Seismic Inspection Threshold Criteria for IROFS27c, IROFS27e, and IROFS28 SSCs inspectors observed an Operations turnover meeting focusing on IROFS discussions and implementation inspectors observed a plan of the day meeting focusing on maintenance and operations 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. Additionally, the inspectors followed-up on WER 2024-003, "Alert - Seismic Activity Felt On-Site (EN57246)."
Specifically, the inspectors conducted the following:
reviewed work orders for IROFS43 surveillance and recalibration reviewed seismic EVs 166362, 167066, and 167202 reviewed self-assessment of records in operations plan observed lock out tag out training HZ126LP00101LT reviewed IROFS for Chemistry qualifications reviewed IROFS24 surveillances
8 INSPECTION RESULTS NOV Failure to meet performance requirements in 10 CFR 70.61(b) by not establishing IROFS barriers NOV 07003103/2022007-01 88020
==
Description:==
On March 30, 2023, in Inspection Report 07003103/2023007 (Agencywide Documents Access and Management System (ADAMS), Accession Number: ML23066A329),
the NRC issued this violation as part of a Severity Level (SL) II problem, for failure to maintain the risk of a high-consequence event as highly unlikely. Specifically, the licensee failed to implement the appropriate IROFS controls for a credible high-consequence accident sequence included in the ISA Summary, resulting in the accident sequence's risk being 'not unlikely.' The details of the violation having been previously documented in Inspection Report 07003103/2022007, issued on December 8, 2022 (ML22341A606).
The violation was a result of the events described in Special Inspection Report 07003103/2022006 (ML22126A182), issued March 2nd. In which three external site preparation construction vehicles were brought inside the controlled access area (CAA) and driven off their trailers prior to the IROFS50b and 50c barriers being established. Afterwards, the IROFS50b and 50c barriers began to be put into place, but were not declared operable due to deficiencies with barrier placement (e.g., gaps in barrier coverage) and signage. Later, on March 7th, the licensee identified that the construction vehicles were within the CAA without IROFS50b or 50c being declared operable.
The licensee's letter, "Response to Apparent Violations in Inspection Report 07003103/2022-007, EA-22-086," dated February 7, 2022 (ML23038A251), described their immediate and planned corrective actions. The immediate corrective actions have been previously reviewed by the NRC included putting the facility in a safe condition and issuing a stop work memorandum. In addition, the licensee conducted a root cause evaluation titled, "Construction Equipment Brought into CAA Prior to IROFS50 Series Declared Operable."
This root cause evaluation was later expanded to include the events that resulted in NOV 07003103/2023007-02, "Loss of IROFS 50b/c independence." Which was the other violation issued in Inspection Report 07003103/2023007 as part of the SLII problem.
The inspectors reviewed the latest update to the licensee's root cause evaluation report (Root Cause Evaluation Report EV 149740, "Construction Equipment Brought into CAA Prior to IROFS50 Declared Operable," Rev. 4), CAP entries related to IROFS50 (including EV 149740, EV 159122, EV 160170, EV 160336, EV 160352, EV 166090 and associated documentation), and documentation demonstrating that the corrective actions had been implemented. Such documentation included training materials, procedures, and work orders.
Additionally, the inspectors interviewed licensee personnel responsible for implementing IROFS50 series controls, walkdown existing IROFS50 barriers and observed the licensee conduct a breach of IROFS50 barriers.
For the root causes of the event the licensee identified corrective actions to prevent recurrence. These corrective actions focused on clarifying the implementation of the IROFS by revising documents that flow the controls down from the ISA (e.g., training material, implementing procedures and IROFS boundary definition documents), as well as revising programs and procedures to ensure that the work control process implemented IROFS when required and that work that could result in changes to the facility hazards (e.g., by bringing construction equipment onsite) was appropriately controlled through the change management process.
9 The inspectors considered that training was a key corrective action and reviewed the licensee's corrective actions related to creating and revising training material and plans. The licensee has completely restructured how IROFS50 training is performed, by establishing a new three-tiered training framework to ensure that all personnel receive IROFS50 training appropriate for their role in implementing the IROFS. The licensee has also revised additional training related to IROFS50, established qualification plans related to IROFS50 (e.g.,
IROFS50FLAGGER, "UUSA IROFS50 Series Flagger Qualification Standard") and performed retraining of site personnel. The inspectors reviewed the licensee's new and revised training material, including:
IROFS-50Series-Site, "IROFS50 Series Site Training" IROFS-50Series-Dept, "IROFS50 Series Departmental Training" IROFS-50Series-SMInitiator, "IROFS50 Series Shift Manager/Initiator Training" IROFS50f-Crane, "IROFS50f Crane Operator Training" The inspectors reviewed numerous procedures and implementing documents that were revised as part of the licensee's corrective actions to clarify the flowdown of the IROFS control from the ISA through the implementing procedures. The inspectors reviewed corrective actions that resulted from licensee effectiveness reviews of these corrective actions and licensee staff identified improvements to the implementing procedures. The documents reviewed included:
NEF-BD-50f, "Administratively Control Proximity of External Crane Loads" OP-3-1000-01, "Conduct of Operations" OP-3-1000-15, "IROFS50a UBC Storage Pad Barrier Control" OP-3-1000-18, "IROFS50d & 50e UF6 Handling Area Internal Barrier and Spotter Control" OP-3-1000-19, "IROFS50f and 50g External Crane Permit and Barrier Control" OP-3-1000-22, "IROFS50h UBC Storage Pad Barrier Control" OP-3-1000-24, "Managing IROFS50 Series Areas of Concern" OP-3-1000-26, "IROFS50i and 50j UBC Pad Barrier and Spotter Control" ORM 50b-50c, "Administratively Control Site Construction Vehicles Near the Areas of Concern" ORM 50d-50e, "Administratively Control Internal Construction Vehicles within the SBM UF6 Handling Area(s)"
ORM 50f-50g, "Administratively Control Boom OR Load Movement of External Cranes" SY-3-4000-05, "Vehicle Access Control" The inspectors reviewed the changes to the licensee's work control process, specifically how the licensee changed their processes and procedures to require more stringent control of contractor activities, to add stricter hold points, and more thorough consideration of possible safety issues and the impact on IROFS. This review included the reviewing the following documents:
2023-S-05-005, "Review of Open Projects QL-3 Work Orders Surveillance" OP-3-1000-27, "Infrequently Performed Tests or Evolutions" PR-3-2000-02, "Purchase Requisitions" WC-3-1000-02, "Work Package - Initiation through Closure (SAP Order Types PM1/PM3/PM5-6)"
WC-3-1000-06, "Control of Vendor/Contractor Supported Work"
10 Additionally, the inspectors interviewed licensee staff about the above corrective actions, reviewed effectiveness reviews that the licensee conducted as part of their CAP, including effectiveness reviews that documented observations of licensee IROFS50 activities, observed activities and reviewed documentation of the licensee's current usage of their new processes and procedures, including:
"IROFS50a Control Boundary Record" "IROFS50c Breach Permit Log" "IROFS50d & 50e UF6 Handling Area Internal Barrier and Spotter Control Permit 24-001" WO 1000631343, "IROFS50f External Crane Permits: 24-004,24-003, 24-002,24-001" WOs 1000655012 and 1000655013 "1W: IROFS50 Barrier Verification" As a result of this review the inspectors determined that the licensee's corrective actions are sufficiently comprehensive and complete such that no further NRC review is necessary.
Therefore, NOV 07003103/2022007-01, "Failure to meet performance requirements in 10 CFR 70.61(b) by not establishing IROFS barriers" is closed.
NOV Loss of IROFS 50b/c independence NOV 07003103/2022007-02 88020
==
Description:==
On March 30, 2023, in Inspection Report 07003103/2023007 (ML23066A329),
the NRC issued this violation as part of a Severity Level (SL) II problem, for failing to implement the IROFS50c barrier as separate and independent from IROFS50b, such that both IROFS were maintained reliable to reduce the likelihood of occurrence a high-consequence event to highly unlikely. Specifically, one individual performed the flagging duties of IROFS50b and IROFS50c concurrently, thus failing to maintain the required independence between IROFS50b and IROFS50c, so that a single common mode human error could disable both IROFS. The details of the violation having been previously documented in Inspection Report 07003103/2022007, issued on December 8, 2022 (ML22341A606).
The violation was a result of an event reported in EN 55956, on June 21 a single individual was concurrently performing the administrative actions of IROFS50b and 50c by acting as the flagger for IROFS50b and 50c concurrently while a yard truck was breaching the IROFS50 barriers. The IROFS50b and 50c barriers were established around areas of concern sitewide after EN 55770 and 55802, since additional vehicles were being analyzed to see if they required IROFS controls. Vehicle breaches into the IROFS50b and 50c areas of concern were being performed per procedure OP-3-1000-16, "IROFS 50b External Boundary Control,"
and OP-3-1000-17, "IROFS 50c External Boundary Control." These procedures had a note stating, "the same flag person may serve for both the IROFS50b and 50c breaches provided both breaches are in the same vicinity." This was contrary to the IROFS boundary definition documents (e.g., NEF-BD-50b, "Administratively Control Proximity of Vehicles by Use of Barriers," Rev. 9) which required independence of IROFS50b from 50c.
The licensee's letter, "Response to Apparent Violations in Inspection Report 07003103/2022-007, EA-22-086," dated February 7, 2022 (ML23038A251), described their immediate and planned corrective actions. The immediate corrective actions have been previously reviewed by the NRC included putting the facility in a safe condition and issuing a stop work for
11 IROFS50 breaches until the associated procedures were revised and personnel were trained on the revisions. In addition, the licensee updated their root cause evaluation titled, "Construction Equipment Brought into CAA Prior to IROFS50 Series Declared Operable" to include this event.
As described above for NOV 07003103/2022007-01, the inspectors reviewed the latest update to the licensee's root cause evaluation report (Root Cause Evaluation Report EV 149740, "Construction Equipment Brought into CAA Prior to IROFS50 Declared Operable,"
Rev. 4), CAP entries related to IROFS50 (including EV 149740, EV 159122, EV 160170, EV 160336, EV 160352, EV 166090 and associated documentation), and documentation demonstrating that the corrective actions had been implemented. Such documentation included training materials, procedures, and work orders. Additionally, the inspectors interviewed licensee personnel responsible for implementing IROFS50 series controls, walkdown existing IROFS50 barriers and observed the licensee conduct a breach of IROFS50 barriers. The root causes and corrective actions for these two violations were largely the same so the inspectors review was as described above.
As a result of this review the inspectors determined that the licensee's corrective actions are sufficiently comprehensive and complete such that no further NRC review is necessary.
Therefore, NOV 07003103/2022007-02, "Loss of IROFS 50b/c independence" is closed.
URI Unanalyzed Condition of Vehicles within the CAA URI 07003103/2022006-02 88020
==
Description:==
This unresolved item (URI) was initially opened in Inspection Report 07003103/2022006 (ML22126A182) to review the licensee's evaluations and assessments of various vehicles that could potentially result in a hazard requiring controls when operated within the CAA at UUSA. It was later discussed in Inspection Report 07003103/2022003 (ML22298A089), that the licensee identified other vehicles (non-construction vehicles) that met the size and maximum speed thresholds to potentially need controls. E.g., because they were large enough that they could endanger licensed material during an accident. So this URI was left open while the licensee analyzed whether such non-construction vehicles required controls.
In Inspection Report 07003103/2013003 (ML23289A004), the inspectors reviewed ISA-HAZ-0012, "Vehicle and Crane Hazard and Risk Determination Analysis," Rev. 0 and ISA-MEM-0014, "Operate While Constructing," Rev. 18, which evaluate the probability and consequences of accidents sequences caused by operating non-construction vehicles at UUSA to determine if controls are required to comply with 10 CFR 70.61 for non-construction vehicles. The inspectors also reviewed portions of supporting calculations that were applicable to non-construction vehicle accidents.
In this inspection the inspectors reviewed the updated version of CALC-S-00168, "Human Error and Vehicle Crash Likelihood," (Rev. 3) and ISA-HAZ-0012 (Rev. 1), furthermore, NRS staff completed their review of the licensee's ISA methodology and of CALC-S-00170, "Building Impact," Rev. 1. The calculations in CALC-S-00170 analysis the structural effect of different vehicle (e.g., different weight class) impacts on the walls of buildings containing licensed material. While those in CALC-S-00168 evaluate the probability of non-construction vehicle crashes from various causes.
The inspectors review of the licensee's analysis of the hazards of operating non-construction
12 vehicles at UUSA did not identify any violations. Specifically, the inspectors did not identify any cases where additional controls not already in the ISA would be required to meet 10 CFR 70.61 as a result of operating non-construction vehicles within the CAA. As a result of this review URI 07003103/2022006-02, "Unanalyzed Condition of Vehicles within the CAA," is closed.
WER (Closed)
ALERT - Seismic Activity Felt On-Site (EN57246)
WER 07003103/2024-003-00 88020
==
Description:==
An earthquake was felt on-site at the UUSA facility in Eunice, NM on Friday, July 26 at approximately 8:28am (MDT). It was a 5.1 magnitude quake that occurred about 140 miles away at a depth of about 2 miles. When an earthquake is felt on-site, URENCO's procedures require them to activate their emergency response center, declare an Alert, and notify the NRC. Accordingly, the licensee declared an Alert at approximately 8:44am (MDT) and made their required notifications per their emergency response procedures.
The licensee suspended UF6 handling operations, evacuated personnel from UF6 handling areas and performed personnel accountability. Once it had been deemed safe to re-enter, the licensee performed their required post-earthquake walkdowns to look for equipment and building damage and for other evidence of releases. No evidence of building damage or releases were found, there were no power losses onsite and no missing or injured staff.
Three centrifuges were taken out of service due to the seismic event, but no breeches or releases were identified. Based on the results of these walkdowns, the licensee terminated the Alert at 2:30pm (MDT) on July 26, 2024. After cooling down the autoclaves, structural walkdowns of the autoclaves are planned to occur. The licensee provided their 60-day follow-up report to the NRC on September 6, 2024, as "60 Day Report for EN 57246 July 2024 Seismic Event" (ML24253A121).
The inspectors interviewed licensee staff, including control room operators on shift July 26th, reviewed the licensee's earthquake response procedure, the emergency plan implementing procedures, and the results of the seismic damage walkdowns. In addition, the inspectors reviewed revisions to OP-3-0200-04 and EP-3-0200-01 which increased the threshold of declaring an Alert for a seismic event. No violations were identified and WER 07003103/2024-003-00, "ALERT - Seismic Activity Felt On-Site (EN57246)," is considered closed.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On November 15, 2024, the inspectors presented the operational safety, nuclear criticality safety, and area needing improvement (ANI) supplemental inspection results to Paul Lorskulsint and other members of the licensee staff.
13 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 88015 Corrective Action Documents EV 165015, 165818, 165838, 165927 NCS-related CAP entries Various 88015 Engineering Evaluations ETC4100854 Criticality Safety Analysis of the Contingency Dump System Rev. 11 88015 Engineering Evaluations NCS-CSA-006 Criticality Safety Analysis of the Product Vent Pump and Chemical Trap Set Rev. 11 88015 Engineering Evaluations NCS-CSA-025 Criticality Safety Analysis of UUSA Process Gas Pipework (All Assays)
Rev. 4 88015 Engineering Evaluations NCS-CSE-040 Evaluation (NCSE) of Facility Rigs Rev. 03 88015 Miscellaneous 2023 CAAS Drill Report 12/21/2023 88015 Miscellaneous Various IROFS training for Operations including IROFS 16 a/e/f and IROFS 30 a/b/c Various 88015 Procedures AD-3-1000-02 Procedure Use and Adherence Rev. 22 88015 Procedures CH-3-2080-01 CE440 Elemental Analyzer Determination of Hydrogen Oil Content in PFPE Oil Rev. 6 88015 Procedures EG-3-3200-02 Nuclear Criticality Safety Analysis/Evaluation Rev. 17 88015 Procedures MA-3-2000-1 PFPE Oil Addition and Sampling Rev. 8 88015 Procedures NEF-BD-16a Administratively Limit Moderator Mass in a New or Cleaned 30B Cylinder Rev. 15 88015 Procedures NEF-BD-16e Administratively Limit Moderator Mass in a Heeled 30B Cylinder Rev. 5 88015 Procedures NEF-BD-16f Administratively Limit Moderator Mass in a Heeled 30B Cylinder Rev. 5 88015 Procedures NEF-BD-30a Limit Hydrocarbon Oil by Controlling Type Used Rev. 7 88015 Procedures NEF-BD-30b Limit Hydrocarbon Oil by Testing Prior to Adding to Pump Rev. 8 88015 Procedures NEF-BD-30b Limit Hydrocarbon Oil by Testing Prior to Operation Rev. 8 88015 Procedures OP-3-0420-01 Product System Rev. 61 88015 Procedures OP-3-0460-01 Product Blending and Vent System Rev. 20 88015 Procedures OP-3-0490-12 Calibration of IROFS10 and 16 Series Pressure Transducers Rev. 1
14 Inspection Procedure Type Designation Description or Title Revision or Date 88015 Self-Assessments SA-2024-001 Nuclear Criticality Safety Programmatic Self-Assessment 02/02/2024 88015 Work Orders WO 1000638001 Recycling-Pump Rebuild - Add Oil to 1006 Feed Sample Rig Evacuation Pump 01/04/2024 88015 Work Orders WO 1000669462 CAAS Fix-it-Now Maintenance 07/24/2024 88015 Work Orders WO 1000680361 Recycling - Pump Rebuild - Add Oil to Product Evacuation Vacuum Pump 10/10/2024 88020 Corrective Action Documents EV 149740, EV 159122, EV 160170, EV 160336, EV 160352, EV 166090 IROFS50 related CAP Entries 88020 Corrective Action Documents EV 166362 Seismic Event with ERO Response 07/26/2024 88020 Corrective Action Documents EV 166362 Alert Emergency Declaration Summary Report 08/22/2024 88020 Corrective Action Documents Root Cause Evaluation Report EV 149740 Construction Equipment Brought into CAA Prior to IROFS50 Declared Operable Rev. 4 88020 Corrective Action Documents Root Cause Evaluation Report EV 160170 IROFS50f and IROFS50g Violation Rev. 3 88020 Corrective Action Documents Resulting from Inspection EV 167944 88020 Corrective Action Documents Resulting from Inspection EV167975 EALs not Available to Region II 11/15/2024 88020 Engineering Changes AD-3-1000-01-F-1 Program Document Approval Form for EP-3-0200-01, Classification of Emergency Events 02/27/2024 88020 Engineering Evaluations EP-3-0200-01 Approval Package Rev. 12 88020 Engineering ISA-HAZ-004 UTC HAZOP and Risk Determination Analysis Rev. 1
15 Inspection Procedure Type Designation Description or Title Revision or Date Evaluations 88020 Engineering Evaluations ISA-MEM-0014 Operate While Constructing Rev. 20 88020 Engineering Evaluations URN-23-003-RPT-02 Seismic Inspection Threshold Criteria for IROFS27c, IROFS27e, and IROFS28 SSCs Rev. 1 88020 Miscellaneous IROFS50c Breach Permit Log 88020 Miscellaneous UUSA Spotter Awareness Training 05/05/2023 88020 Miscellaneous IROFS50a Control Boundary Record 09/23/2024 88020 Miscellaneous AD-3-1000-02CT Procedure Use and Adherence Continuing Training 07/17/2023 88020 Miscellaneous IROFS-50Series-Dept IROFS50 Series Departmental Training Rev. 1 88020 Miscellaneous IROFS-50Series-Site IROFS50 Series Site Training 10/23/2023 88020 Miscellaneous IROFS-50Series-SMInitiator IROFS50 Series Shift Manager/Initiator Training Rev. 1 88020 Miscellaneous IROFS-IROFS50f/g-JIT-ILT IROFS50f and IROFS50g Just In Time Training 06/15/2023 88020 Miscellaneous IROFS50f-Crane IROFS50f Crane Operator Training 04/22/2024, Rev. 0 88020 Miscellaneous IROFS50FLAGGER UUSA IROFS50 Series Flagger Qualification Standard 06/29/2023 88020 Miscellaneous IROFS50SPOTTER UUSA IROFS50 Series Spotter Qualification Standard 06/29/2023 88020 Miscellaneous LES-24-112-NRC 60 Day Report for EN 57246 July 2024 Seismic Event 09/06/2024 88020 Miscellaneous Permit 24-001 IROFS50d & 50e UF6 Handling Area Internal Barrier and Spotter Control Permit 24-001 10/29/2024 88020 Miscellaneous QTN-2022-002 IROFS50 Rev. 7, 11/18/2022 88020 Miscellaneous QTN-2022-003 IROFS50 Vehicles Rev. 1 88020 Operability Evaluations CH-3-1050-01-F-1 Airflow Away from Worker Surveillance Data Sheet 09/11/2024 88020 Operability Evaluations CH-3-1050-01-F-2 Samples in Solid State Surveillance Data Sheet 09/10/2024 88020 Operability Evaluations OP-3-2000-04-F-1 Seismic Damage Walkdown 07/26/2024 88020 Procedures CH-3-1050-01 Chemistry Surveillance Rev. 7
16 Inspection Procedure Type Designation Description or Title Revision or Date 88020 Procedures EG-3-5200-03 IROFS28 Product Liquid Sampling Autoclave Leak Tight Integrity Inspection Surveillance Rev. 11 88020 Procedures EP-3-0200-01 Classification of Emergency Events Rev. 12 88020 Procedures EP-3-0200-02-F-2 Emergency Notification Form 07/26/2024 88020 Procedures MA-3-3400-13 IROFS43 Sub-Sampling Rig High Temperature Trip RTD Surveillance Rev. 10 88020 Procedures NEF-BD-027e Design Features of the SBM, CRDB Shell, and the UBC Storage Pad Crane Rev. 12 88020 Procedures NEF-BD-24b Establish GEVS Flow for Sample Handling or Transfer Rev. 4 88020 Procedures NEF-BD-24d Establish GEVS Flow for Handling Uranic Materials in UTC Rev. 1 88020 Procedures NEF-BD-27c Design Features of CRDB Bunkered Area Rev. 5 88020 Procedures NEF-BD-28 Design Feature to Maintain Product Liquid Sampling Leak Tight Integrity Rev. 7 88020 Procedures NEF-BD-39a Limit Exposure by Requiring Evacuation of Area on Seismic Event Rev. 12 88020 Procedures NEF-BD-39c Limit Exposure by Requiring Evacuation of Area on Release Event Rev. 12 88020 Procedures NEF-BD-43 Automatic Trip of Sub-Sampling System Hotbox Heaters on High Temperature Rev. 6 88020 Procedures NEF-BD-46 Verification of Samples in Solid State Prior to Transfer Rev. 4 88020 Procedures NEF-BD-50f Administratively Control Proximity of External Crane Loads 04/30/2024, Rev. 11 88020 Procedures NEF-BD-50g Administratively Control Movement of External Cranes by Use of a Spotter 10/25/2023, Rev. 11 88020 Procedures NEF-BD-C23 Design Feature of Centrifuges to Minimize Release Rev. 6 88020 Procedures OP-3-1000-01 Conduct of Operations Rev. 38 and 45 88020 Procedures OP-3-1000-15 IROFS50a UBC Storage Pad Barrier Control 07/03/2024 88020 Procedures OP-3-1000-18 IROFS50d & 50e UF6 Handling Area Internal Barrier and Spotter Control 08/31/2023 88020 Procedures OP-3-1000-19 IROFS50f and 50g External Crane Permit and Barrier Control 05/01/2024 88020 Procedures OP-3-1000-22 IROFS50h UBC Storage Pad Barrier Control 08/05/2024 88020 Procedures OP-3-1000-24 Managing IROFS50 Series Areas of Concern Rev. 6 and 7
17 Inspection Procedure Type Designation Description or Title Revision or Date 88020 Procedures OP-3-1000-26 IROFS50i and 50j UBC Pad Barrier and Spotter Control 09/30/2024 88020 Procedures OP-3-1000-27 Infrequently Performed Tests or Evolutions Rev. 6 and 7 88020 Procedures OP-3-1000-29 Defense in Depth Controls for External Cranes Rev. 0, 10/25/2023 88020 Procedures OP-3-2000-04 Earthquake Response Rev. 20, 21 88020 Procedures ORM 50b-50c Administratively Control Site Construction Vehicles Near the Areas of Concern 02/01/2024, Rev. 7 88020 Procedures ORM 50d-50e Administratively Control Internal Construction Vehicles within the SBM UF6 Handling Area(s) 02/01/2024, Rev. 8 88020 Procedures ORM 50f-50g Administratively Control Boom OR Load Movement of External Cranes 01/31/2024, Rev. 8 88020 Procedures ORM 50i-50j Administratively Control Construction Vehicles in the UBC Pad 02/01/2024, Rev. 4 88020 Procedures PR-3-2000-02 Purchase Requisitions Rev. 31 88020 Procedures SY-3-4000-05 Vehicle Access Control Rev. 18 88020 Procedures WC-3-1000-02 Work Package - Initiation through Closure (SAP Order Types PM1/PM3/PM5-6)
Rev. 43; Rev. 46; Rev. 48, 09/18/2024 88020 Procedures WC-3-1000-06 Control of Vendor/Contractor Supported Work Rev. 8, 02/05/2024 88020 Self-Assessments 2023-S-05-005 Review of Open Projects QL-3 Work Orders Surveillance 05/17/2023 88020 Self-Assessments LES-24-112-NRC 60 Day Report for EN 57246 for July 2024 Seismic Event 09/06/2024 88020 Self-Assessments OP-3-0200-04-F-1 Seismic Damage Walkdowns 07/26/2024 88020 Self-Assessments SA-2024-014 Self-Assessment of Records in Operation Plan 06/28/2024 88020 Work Orders 1000631343 IROFS50f External Crane Permits: 24-004,24-003, 24-002,24-001 07/19/2024, 07/19/2024, 06/18/2024, 06/18/2024 88020 Work Orders 1000655012 1W: IROFS50 Barrier Verification 08/05/2024 88020 Work Orders 1000655013 1W: IROFS50 Barrier Verification 08/12/2024 88020 Work Orders WO 1000655248 IROFS 43 Surveillance for Sub-Sampling Unit 2 10/25/2024 88020 Work Orders WO 1000688895 IROFS43 RTD Recalibration 11/05/2024