ML25097A177
| ML25097A177 | |
| Person / Time | |
|---|---|
| Site: | 07003103 |
| Issue date: | 04/07/2025 |
| From: | Bradley Davis NRC/RGN-II/DFRSS |
| To: | Lorskulsint P Louisiana Energy Services, URENCO USA |
| References | |
| IR 2025001 | |
| Download: ML25097A177 (1) | |
Text
Paul Lorskulsint Chief Nuclear Officer Louisiana Energy Services (LES) dba Urenco USA Urenco USA P.O. Box 1789 Eunice, NM 88231
SUBJECT:
URENCO USA - INTEGRATED INSPECTION REPORT 07003103/2025001
Dear Paul Lorskulsint:
On March 31, 2025, 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. Additionally, portions of this inspection were conducted in support of the Operational Readiness Review (ORR) required by License Conditions 6B and 6B.1.
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 April 7, 2025 Signed by Davis, Bradley on 04/07/25
SUNSI Review X
Non-Sensitive
Sensitive X
Publicly Available
Non-Publicly Available OFFICE RII/DFRSS RII/DFRSS NAME T. Sippel B. Davis DATE 04/07/2025 04/07/2025
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07003103 License Number:
SNM-2010 Report Number:
07003103/2025001 Enterprise Identifier:
I-2025-001-0039 Licensee:
Louisiana Energy Services (LES) dba Urenco USA Facility:
URENCO USA Location:
Eunice, NM Inspection Dates:
March 03, 2025 to March 06, 2025 Inspectors:
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 None.
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 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 5.1.2, 5.1.3, 5.1.4, 5.2.1.2, 5.2.1.4, 5.2.1.5 and 5.2.1.6. Specifically, the inspectors interviewed licensee staff and reviewed the following:
NCS-CSA-035, "Nuclear Criticality Safety Analysis of the Multifunction Decontamination Train (MFDT)," Revision (Rev.) 1; including reviewing the modeling of various credible upset conditions (e.g., flooding) and reviewing the inputs and assumptions used in the models NCS-CSA-043, "Nuclear Criticality Safety Analysis of Sample Cylinder Storage Cabinets," Rev. 3, this review focused on changes to the analysis that were made to clarify that it is a bounding analysis not tied to a specific design For the CSAs listed, the inspectors also reviewed the attached peer review forms to verify that CSAs were being peer reviewed 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, and licensee staff interviews to verify
4 compliance with 10 CFR 70 and applicable sections of the license application, including 5.1.2. Specifically, the inspectors interviewed licensee staff and reviewed the following:
Administrative mass control Item Relied on for Safety (IROFS) 31a/b, reviewed procedure (RW-3-1000-09) and interviewed licensee staff Administrative spacing control IROFS 58a/b for criticality safety approved waste containers, reviewed postings in the field, observed operator aids and interviewed licensee staff Administrative mass control IROFS 56a/b and 57a/b for the MFDT, reviewed procedure (RW-3-4000-02) and interviewed licensee staff Administrative mass control IROFS 55a/b for the Liquid Effluent Collection and Transfer System (LECTS), operator aids (e.g., IROFS tag and lock) and procedure (RW-3-2000-01)
Safe By Design Verification (SBDV) 2024-0042, "SBD Verification of Pumping Train at C1.1A," dated December 18, 2024; and SBDV-2024-0044, "SBD Verification of Pumping Train at 1004-432-10D18," dated December 19, 2024, to verify that NCS-related controlled parameters (e.g., spacing) were being implemented and verified Additionally, the inspectors performed walkdowns in the Decontamination Room and the LECTS Room 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 2.3.3, 11.3.3.1.1 and 11.5.1. Specifically, the inspectors performed the following activities:
reviewed GWRECTECH, "UUSA Recycling Technician Qualification Standard," Rev. 4, which includes training requirements for NCS IROFS (e.g.,
IROFS 55a/b, 56a/b, 57a/b) for recycling technicians interviewed a recycling technician concerning criticality IROFS and control methods, including the use of visual monitoring for long-term accumulations reviewed GXNSWLP00I00ILT, "Nuclear Safety Worker,"
Rev. 13, GXNSWCTCBT, "Nuclear Safety Worker CT CBT 2024," dated June 28, 2024, and NCSASUPILT, "NCSA Supervisor Training," Rev. 0 observed a licensee NCS engineer conduct a weekly audit in Decontamination Workshop and reviewed several recent audit reports (NCSIs) by different licensee NCS engineers 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 2.2.3 and 5.1.5. Specifically, the inspectors:
reviewed qualification records (E-NCS-SS-QG) for two newly qualified NCS Support Staff interviewed licensee NCS staff about the training and qualification process for NCS staff
5 interviewed licensee NCS staff about NCS roles and responsibilities, and reviewed documentation of changes to the licensee's management structure (e.g., GCP-145) the most recent revision to licensee procedure EG-3-3200-02, "Nuclear Criticality Safety Analysis/Evaluation," Rev. 18 reviewed Nuclear Safety Release (NSR) 2024-011, "Installation of WS1001 and WS251 Pumps at Location 1004-432-10D1B," Rev. 0, dated December 19, 2024; and NSR-2017-003, "IROFS58 Series Operations - CSA Waste Containers Decontamination Activities," Rev. 1, dated January 8, 2025; to verify that NCS reviewed changes effecting controlled parameters (e.g.,
spacing, volume)
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 5.3, 5.4 and 11.6. Specifically, the inspectors reviewed the following documents and interviewed licensee staff concerning:
reviewed a sample of recent NCS-related CAP entries; including EV166979, EV167954, EV167940, EV167988, EV167989, EV168056, EVENT-2025-0425, -0543, -0704; and associated documentation CALC-S-00162, "Evaluation of CAAS Placement for LEU+ Activities of CAAS Placement in the SBM," Rev 0, including reviewing the comparison of dose at the detectors for selected cases for LEU and LEU+ operations CALC-S-00178, "Evaluation MobiCAAS placement at the UUSA Site," Rev. 0; including its applicability to LEU+ operations CALC-S-00132, "Evaluation of CAAS Placement in the CRDB - Bunkered Area," Rev. 1; which was reviewed because it is the current basis for the existing CAAS detector placement OPERATIONAL READINESS REVIEW (LICENSE CONDITIONS 6B & 6B.1)
SAFETY OPERATIONS IP 88015 - Nuclear Criticality Safety Criticality Analysis (IP Section 02.01)
In support of the ORR required by license conditions 6B and 6B.1, the inspectors interviewed licensee staff and reviewed CSAs, and associated assumptions and calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors interviewed licensee staff and reviewed the following samples to verify why IROFS 101 was not required.
NCS-CSA-104, "Nuclear Criticality Safety Analysis of the Contingency Dump Traps (LEU+)," Rev. 2, including the basis for the worse case credible accident scenarios, the basis for the IROFS controls required for LEU+ (enrichments between 5 and 10%)
production, and the inputs and assumptions used in the models of upset conditions
6 MA-3-2441-03, "Initial Filling of NaF Traps," Rev. 9; to validate assumptions and model inputs in the CSA 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 March 6, 2025, the inspectors presented the nuclear criticality safety inspection results to Paul Lorskulsint and other members of the licensee staff.
7 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date Corrective Action Documents NCR 2025-0425 Discrepancies with the Accuracy of Measurements Associated with NCS SBD Attributes Rev. 0, 02/06/2025 Corrective Action Documents Resulting from Inspection EVENT-2025-1130 NRC NCS Inspection Observation: Improve Traceability in CALC-S-00168 03/06/2025 Engineering Changes GCP-145 Modification to Organization of Design Safety Basis Functions Rev. 1 Nonconformance Engineering Evaluation Form for NCR 2025-0425, Rev. 0 03/03/2025 Engineering Evaluations LBDCR-24-015 Review of GCP-145 11/21/2024 E-NCS-SS-QG Nuclear Criticality Safety (NCS) Support Staff Completed 11/18/2024 E-NCS-SS-QG Nuclear Criticality Safety (NCS) Support Staff Completed 12/17/2024 GETILT Urenco USA General Employee Training Rev. 17 GWRECTECH UUSA Recycling Technician Qualification Standard Rev. 4 GWRNDATPE00 Operation and Calibration of the Non-Destructive Analysis Equipment Rev. 0 GWSLABTPE00 Operating the Liquid Effluent Collection and Transfer System (LECTS) Slab Tank Rev. 2 GXNSWCTCBT Nuclear Safety Worker CT CBT 2024 06/28/2024 NCSASUPILT NCSA Supervisor Training Rev. 0 OPQ1001BO00 UUSA Operations Building Operator Qualification Standard Rev. 10 Miscellaneous OSIROFSQC00100 Items Relied On For Safety (IROFS) and Operating Requirements Manual (ORM) Qualification Guide Rev. 9 MA-3-2441-01 Initial Filling of NaF Traps Rev. 9 NEF-BD-58a Maintain Subcritical Mass in a Criticality Safety Approved Waste Container Storage Array Rev. 6 RW-3-1000-09 Radioactive Container Setup, Handling and Disposition Rev. 23 RW-3-2000-01 LECTS Operations Rev. 19 88015 Procedures RW-3-4000-02 Startup, Operation and Shutdown of the Multi-Functional Rev. 22
8 Inspection Procedure Type Designation Description or Title Revision or Date Decontamination Train NCSI-24-0046 Solid Waste Collection Room 11/18/2024 NCSI-24-0047 Decontamination Workshop 11/25/2024 NCSI-24-0048 Ventilated Room 11/26/2024 NCSI-24-0051 Liquid Effluent Collection/Waste Treatment Room 12/19/2024 NCSI-25-0003 Technical Services Building (TSB) CAAS 01/23/2025 NCSI-25-0006a Solid Waste Collection Room (SWCR) 02/18/2025 Self-Assessments NCSI-25-0006b Liquid Effluent Collection/Waste Treatment Room 02/18/2025