ML25181A763

GNF-A Documentation Request - NCS2 Env - 2025-003

ML25181A763
Person / Time
Issue date:	06/24/2025
From:	Gregory Goff NRC/RGN-II/DFRSS
To:
References
IR 2025003
Download: ML25181A763 (4)

Text

NUCLEAR CRITICALITY SAFETY AND EFFLUENT CONTROL & ENVIRONMENTAL PROTECTION INSPECTION DOCUMENT REQUEST SITE: Global Nuclear Fuel - Americas INSPECTION REPORT NUMBER: 2025-003 (GNF-A)

INSPECTION DATES:

July 21-24, 2025 NRC INSPECTOR(S):

Nicholas Peterka (Lead), nicholas.peterka@nrc.gov Gregory Goff, gregory.goff@nrc.gov ACCOMPANYING PERSONNEL:

None IDENTIFIED LICENSEE CONTACTS:

Licensing:

Phillip (Phil) Ollis, Phillip.Ollis@ge.com EHS Manager:

Jonathan Rohner, Jonathan.Rohner@ge.com NCS:

Lon Paulson, Lon.Paulson@ge.com ASSOCIATED PROCEDURES:

88015 - Nuclear Criticality Safety (NCS) 88045 - Effluent Control and Environmental Protection (ENV)

DOCUMENTATION REQUESTED

1. Effluent and Environmental Controls (88045) - G. Goff

a. Latest organizational chart of the ENV division (and their contact information if they can support the inspection). Please denote any personnel changes since the last ENV inspection in May 2022. Provide qualification and training records of any new person in environmental protection.

b. Provide a list of any environmental protection-related IROFS and their function.

c. Procedures relating to calibration and set point verification for liquid and gaseous effluent monitors. This would include the most recent calibration package for stack monitors (rotameters/flowmeters) and/or liquid effluent monitors, as applicable.

d. Independent audits or assessments of the ENV program performed since last inspection.

Also include a sampling of quality assurance (QA) surveillances performed since the last inspection.

e. Audits/assessments of subcontracted laboratories/vendors used for processing samples.

Include, as necessary, a vendors supply list for environmental, remediation, effluent, and waste services. In the list, please identify the services provided by the vendor.

f.

Sampling of calibration records for analytical equipment used for analysis of samples that provide data input to effluent releases.

g. Provide a data stream sample used as input into the last available software calculations and a sample of software printouts that will allow confirmation of public exposure.

Include a copy of any available manual backup calculations that was used to confirm the accuracy of the software program.

h. List of corrective actions for the last 12 months pertaining to environmental and effluent activities. This will include findings identified in audits/assessments, upsets, exceedances, events, other issues, etc.

i.

Sampling of data sheets relating to daily functional checks/control charts for analytical equipment (if applicable).

j.

Maintenance history (past 12 months) for effluent monitoring equipment.

k. Environmental operational procedures, such as airborne and liquid effluent sample collection, sample analysis, and data collection/reporting. These would be procedures for changing/maintaining stack filtration systems, wastewater treatment systems, and environmental scrubbers.

l.

Documentation that describes and/or defines individual radiological exhaust/ventilation stacks and other gaseous discharge points; and the methods used for collecting samples and/or monitoring airborne radioactive emissions data.

m. Documentation that describes and/or defines individual radiological liquid outfalls and any other liquid effluent discharge points, and the methods used for collecting samples and/or monitoring radioactive effluent data.

n. Provide documentation for groundwater sampling data (including contamination data) summarizing the contaminants, plume characterization, potential impact on environment, remediation, monitoring program, and other relevant information within the last year.

o. Documentation that shows compliance with 10 CFR 20.1406(c). This would include procedures for environmental and subsurface contamination control processes.

p. Procedures for adding vendors to approved supplier lists and for auditing those vendors; event reporting procedures (including what needs to be reported internally), etc.

q. For new or changed procedures (since the last inspection), please also include the old procedure, or a markup showing the changes. The change package used to change the procedure, if any. Include any training associated with the change.

r. Documents transmitted to local, state, and federal for gaseous/air discharges via stacks, liquid discharges to the sewer, and storm water discharges.

s. Specific air sampling items:

• Documentation from assessing and/or reassessing flow rates from stacks. When were these calibrations performed?

• Documentation that presents the actual calculations and their use to quantify and determine compliance with dose to the public.

• Any occasional hand calculations performed to confirm automated calculations accuracy.

t.

Radiological waste procedures for classification.

u. Radiological waste procedures for characterization.

v. Radiological waste procedures for handling and storage.

w. Radiological waste shipment records over the last 12 months.

x. If applicable, records and monitoring of buried waste and waste ponds. Include any monitoring to determine that buried non-radioactive waste is indeed non-radioactive.

2. Information and Support Requested for NCS Inspection (Peterka)

a. Any new and/or revised CSAs completed since the last NCS inspection (in February, 2025)

b. Any new or revised NCS procedures, manuals, and guidance since the last NCS inspection

c. CSAs and QRAs for Node 207 (Powder Pack / Receipt) and Node 805 (Laboratory)

d. Any audits of the NCS program since the last NCS inspection

e. Any new or revised validation reports since the last NCS inspection

f.

List of NCS and CAAS-related Corrective Action Program entries and any related NCS safety analyses or evaluations since the last NCS inspection

g. NCS audit reports since the last NCS inspection, and the schedule for walkdowns and inspections in 2025

h. Qualification records for any NCS staff who are currently qualifying or newly qualified since the last NCS inspection (e.g., NCS qual, ISA qual, auditor quals, etc)

i.

General NCS training material provided to operators

j.

Documentation for any changes to the CAAS since the last NCS inspection

k. List of any planned CAAS tests; NCS audits; NCS NDA activities; NCS related IROFS tests, PMs, or calibrations scheduled for the inspection week; other NCS related activities occurring during the inspection week

l.

Please schedule an NCS weekly walk-down for the NRC to observe

m. Please provide us the schedule for any IROFS Surveillances / Compliance Calendar items that NCS performs the week of the inspection

Documents/Support Requested for the On-site Portion of the Inspection

1) Inspectors will need site support to conduct the tours, as needed, and observe ongoing effluent control and environmental activities.

2) The inspectors will need site support to coordinate interviews with plant personnel.

3) The inspectors will need site support to attend the plan of the day meetings.

4) Please keep inspectors informed of ENV-related activities on a daily basis.

5) Please inform the inspectors of any updates to Effluent Control and Environmental Protection program that has occurred since this document request was issued.