ML21302A040

Urenco USA, Integrated Inspection Report 07003103/2021003

ML21302A040
Person / Time
Site:	07003103
Issue date:	10/29/2021
From:	Chutima Taylor NRC/RGN-II/DFFI
To:	Padgett W Louisiana Energy Services, URENCO USA
References
IR 2021003
Download: ML21302A040 (26)

Text

October 29, 2021

Mr. Wyatt Padgett Compliance and Licensing Manager LOUISIANA ENERGY SERVICES (LES) dba URENCO USA URENCO USA P.O. Box 1789 Eunice, NM 88231

SUBJECT:

URENCO USA - INTEGRATED INSPECTION REPORT 07003103/202 1003

Dear Mr. Padgett:

On September 30, 2021, the U.S. Nuclear Regulatory Commission ( NRC) completed an inspection at URENCO USA (UUSA) and discussed the results of th is inspection with you and other members of your staff. The results of this inspection ar e documented in the enclosed report.

Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements was identified during the inspect ion. Because UUSA has an NRC-approved corrective action program, placed the violation in to their corrective action program, and restored compliance, this violation is being treat ed as a non-cited violation (NCV) consistent with Section 2.3.2a of the Enforcement Policy. The NCV is described in the subject inspection report. If you contest the violation or the signifi cance or severity of the violation documented in this inspection report, you should provide a resp onse within 30 days of the date of this inspection report, with the basis for your denial, to t he U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555- 0001; with copies to the Regional Administrator, Region II; the Director, Office of Enfo rcement; and the NRC Resident Inspector at URENCO USA.

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 W. Padgett 2

Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Cynthia D. Taylor, Chief (Acting)

Projects Branch 1 Division of Fuel Facility Inspection

Docket No. 07003103 License No. SNM-2010

Enclosure:

As stated

cc w/ encl: Distribution via LISTSERV

ML21302A040 X SUNSI Review X Non-Sensitive X Publicly Available Sensitive Non-Publicly Available

OFFICE RII/DFFI RII/DFFI RII/DFFI NAME B. Adkins L. Cooke C. Taylor DATE 10/26/21 10/26/21 10/29/2021

U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Number: 07003103

License Number: SNM-2010

Report Number: 07003103/2021003

Licensee: LOUISIANA ENERGY SERVICES (LES) dba URENCO USA

Facility: URENCO USA

Location: Eunice, NM

Inspection Dates: August 09 - 12 and September 13 - 16, 2021

Inspectors: B. Adkins, Sr. Fuel Facility Project Inspector L. Cooke, Fuel Facility Inspector T. Sippel, Fuel Facility Inspector P. Startz, Fuel Facility Inspector

Approved By: Cynthia D. Taylor, Chief (Acting)

Projects Branch 1 Division of Fuel Facility Inspection

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitori ng the licensees performance by conducting an integrated inspection at URENCO US A (UUSA), in accordance with the fuel cycle facility inspection program. This is the N RCs 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

Criticality Accident Alarm System (CAAS) inaudibility not repor ted Significance Report Section Severity Level (SL) IV 88015 Non-Cited Violation (NCV) 07003103/2021003-01 Open/Closed The NRC inspectors identified a SL-IV NCV of the reporting requ irements in 10 Code of Federal Regulation (CFR) 70.50(b)(2).

Additional Tracking Items

None.

2 INSPECTION SCOPES

Inspections were conducted using the appropriate portions of th e inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise note d. Currently approved IPs with their attached revision histories are located on the public web site 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 inspe ction activity were met consistent with Inspection Manual Chapter (IMC) 2600, Fuel Cyc le Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed se lected procedures and records, observed activities, and interviewed personnel to asse ss licensee performance and compliance with Commission rules and regulations, license condi tions, site procedures, and standards.

SAFETY OPERATIONS

88015 - Nuclear Criticality Safety

The inspectors evaluated selected aspects of the licensees Nuc lear Criticality Safety (NCS) program to verify compliance with selected portions of 10 Code of Federal Regulation (CFR) 70, including 70.24, 70.50, 70.61, 70.62, and Chapter 5, Nuclear C riticality Safety, of the facilitys safety analysis report (SAR), and applicable licensee procedure s.

Criticality Analysis (IP Section 02.01)

The inspectors interviewed licensee staff and reviewed nuclear criticality safety analyses (CSAs), and associated documentation, to verify compliance with 10 CFR 70 and applicable sections of the SAR, including, 5.1.2, 5.2.1.3, and 5.2.1.4. Sp ecifically, the inspectors interviewed licensee staff and reviewed the following:

• NCS-CSA-006, "Criticality Safety Analysis of the Product Vent Pump and Chemical Trap Set," Revision (Rev.) 10, because it contained a variety of calculations and information supporting the licensee's evaluati on of Safe-By-Design (SBD) components in the Product Liquid Sampling and Prod uct Takeoff Systems

Criticality Implementation (IP Section 02.02)

The inspectors selected SBD controls from the licensees integr ated safety analysis summary (ISAS) to verify proper implementation through a review of process and system descriptions, records, and plant walkdowns to verify compliance with 10 CFR 70 and applicable sections of the SAR, including 3.2.5.2. Specifically, the inspectors performed the following activities:

• reviewed SBD verification (SBDV) forms and nuclear safety rele ases (NSRs) performed by the licensee for the product liquid sampling and p roduct takeoff systems;

• walked down NCS postings and storage areas for fissile baring waste in the cylinder receipt and dispatch building (CRDB); and

• walked down favorable geometry accumulation points (e.g., trap s) in the product liquid sampling and product takeoff systems.

3 Criticality Operational Oversight (IP Section 02.03)

The inspectors assessed the NCS staffs oversight of plant oper ators, procedures, and operations of systems involving special nuclear material to ver ify compliance with 10 CFR 70 and applicable sections of the SAR. Specifically, the inspec tors performed the following activities:

• reviewed the criticality general employee training (GET)/compu ter-based training (CBT) material for compliance with Chapter 11 of the S AR;

• walked down the product liquid sampling and product takeoff sy stems with a qualified NCS engineer; and

• observed a licensee NCS support staff member conduct a weekly walkthrough audit of the separations building module (SBM)-1003 criticality accident alarm system (CAAS).

Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures, and NCS staff q ualifications to verify compliance with 10 CFR 70 and applicable sections of the SAR, i ncluding 2.2.3.F, 5.1.1, and 5.1.5. Specifically, the inspectors interviewed licensee NC S staff and reviewed the following documents:

• procedure used for non-destructive verification of materials u sed in SBD components (QA-3-3000-36);

• qualification guides for licensee NCS engineers and NCS suppor t staff (E-NCS-QG, and E-NCS-SS);

• training records for NCS staff; and

• annual continuing training records for a senior NCS engineer.

Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licen sees CAAS, criticality emergency response procedures, and corrective action program (CAP) to verify compliance with 1 0 CFR 70. Specifically, the inspectors performed the following activities:

• reviewed a sampling of CAAS and NCS-related CAP entries since the last NCS inspection;

• reviewed records of recent maintenance and testing of the CAAS, specifically work orders (WOs) 1000489860 and WO 1000500490;

• interviewed licensee NCS and radiological protection (RP) staf f concerning recent NCS drills, and their roles in emergency response;

• walked down RP equipment that would be used during and after p otential criticality accidents; and

• reviewed a sample of emergency action plans, including the ins tructions and evacuation maps to follow during a CAAS activation.

4 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees Ope rational Safety program to verify compliance with selected portions of 10 CFR 70, includin g 70.61, 70.62, and Chapter 11, Management Measures, of the facilitys SAR, and applicable li censee procedures.

Identification of Safety Controls and Related Programs (IP Sect ion 02.01)

The inspectors selected specific process areas for inspection b ased on the safety basis information of the facility, the risk and safety significance o f the process areas, the description of plant changes s ubmitted to the NRC, and past plant performance documentation. For the process areas of interest, the inspector s selected a sample of accident sequences in fire safety and chemical safety based on the information provided in the ISAS. The inspectors conducted a general plant tour of eac h major plant operating area. The process areas and accident sequences selected for re view are listed below:

• FF-WORKER-EVAC, fire involving excessive transient combustible s within the area or a fire propagating into the area of concern that could result in a fire of sufficient magnitude that results in a release of uranium hexaf luoride (UF6);

• FF6-1, fire propagating into the CRDB general areas from other areas that could result in a release of UF6 inventory;

• FF15-1, fire propagating into the UF6 handling area from other areas that could result in a release of uranium material;

• PB4-2, product liquid sampling autoclave heater fails causing heater to remain on resulting in cylinder and autoclave failure and release of U F6 inventory; and

• PT2-1, product low temperature takeoff station heater defrost controller heater fails causing cylinder and autoclave failure and release of UF6 inventory.

Review of Safety Controls and Related Programs (IP Section 02.0 2)

The inspectors reviewed information related to administrative a nd engineered safety controls or items relied on for safety (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 a nd 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:

• IROFS1, automatic trip of a defrost heater and fan on high int ernal temperature to ensure cylinder integrity (RTD), active engineer ed control; chemical safety;

• IROFS2, automatic trip of a defrost heater and fan on high int ernal temperature to ensure cylinder integrity (thermocouple); active engineered control, chemical safety; IROFS11, automatic trip of the autocl ave heater and fan on high internal temperature to ensure product liquid sampl ing autoclave integrity; active engineered control, chemical safety;

• IROFS12, automatic trip of the autoclave heater and fan on hig h autoclave internal pressure to ensure product liquid sampling autoclave i ntegrity; active engineered control, chemical safety;

5

• IROFS 35, automatic closure of fire-rated barrier opening prot ectives (fire dampers), administrative control, fire and chemical safety; and

• IROFS39b, administratively limit exposure by requiring operato r action to evacuate the area of concern to ensure worker consequences of i nhalation of uranic material and hydrogen fluoride (HF) are low; administrat ive control, fire and chemical safety.

Implementation of Safety Controls (IP Section 02.03)

For the selected safety controls listed above, the inspectors r eviewed management measures to verify proper implementation in accordance with 10 CFR 70 and applicable sections of the SAR. This review was performed to verify that s elected safety controls or IROFS were present, available, and reliable to perform their sa fety function and that the design basis assumptions were reflected in the actual condition s in the field. The inspectors conducted the following activities to verify the implementation of selected safety controls:

• reviewed maintenance procedure MA-3-3400-11 and observed the a nnual IROFS1/2 surveillance test for station 1003-434-7B3;

• reviewed IROFS11/12 engineering setpoint calculations associat ed with accident sequence PB4-2;

• reviewed records to determine if IROFS35 fire dampers were pro perly tested in accordance with National Fire Protection Association (NFPA) 90A requirements; and

• conducted interviews and reviewed training records to determin e if personnel were knowledgeable of evacuation and incipient firefighting pro cedures as specified in the boundary definition for IROFS39b.

Safety Control Support Programs (IP Section 02.04)

The inspectors assessed additional management measures that sup port the availability and reliability of the selected safety controls to verify these wer e implemented in accordance with 10 CFR 70 and applicable sections of the SAR. Specifically, th e inspectors performed the following:

• reviewed WO 1000366586 for IROFS35 and WOs 1000420321/10004389 76 for IROFS 11 and 12 to determine if the licensee was adequately performing IROFS-related functional testing at the proper frequency;

• reviewed the following CAP entries to ensure the licensee was entering items at the proper threshold and correcting conditions adverse to qu ality and safety: event (EV) 123337, 137862, 146038, 145904, 145835, 1446 88, 144687, 143321, 143082, 140675;

• attended the plan of the day meeting on 08/10/2021 to determin e if the licensee was adequately controlling work and addressing operati onal deficiencies;

• reviewed the operations department organizational chart for co mpliance with Chapter 2 of the SAR;

6

• performed interviews of five plant operators to determine thei r knowledge related to IROFS39b including the required actions they would t ake in the event of a fire; and

• observed operations shift turnover on 08/10/2021.

88055 - Fire Protection

The inspectors evaluated selected aspects of the licensees fir e protection program to determine whether the operational status, material condition and design o f fire protection systems met the applicable requirements of 10 CFR 70, Chapter 7, Fire Safety, of the facilitys SAR, and applicable licensee procedures.

Selection of Inspection Samples (IP Section 02.01)

The inspectors reviewed licensing documents to select a sample of fire protection features in risk-significant ar eas and processes, including ROF S and their respective management measures (where applicable). The inspectors also sel ected licensee activities that support the implementation of the fire protecti on program based on the program description included in the SAR. Specifically, the inspectors performed the following:

• observed a weekly IROFS36A combustible material loading walkdo wn by operations personnel;

• observed maintenance and post maintenance testing on IROFS35 f ire doors under WOs 1000496137 and 1000496138;

• observed hot work practical training including use of fire ext inguishers;

• interviewed one control room operator and one control room sup ervisor regarding operation of the fire water system; and

• reviewed electronic operating logs to determine if the license e was maintaining minimum fire water tank levels.

Preventative Controls (IP Section 02.02)

The inspectors interviewed licensee staff, reviewed documentati on, and conducted plant walk-downs to verify the licensees controls for transient comb ustibles and ignition sources met the license requirements and applicable requirements in 10 CFR 70. Specifically, the inspectors conducted the inspection activities listed below:

• interviewed licensee operators and engineers, reviewed records of walkdowns, and conducted plant w alk-downs in the CRDB, SBM-1001 and other areas to verify controls for transient and fixed combusti ble material were being implemented in accordance with procedural requirements;

• conducted plant walk-downs, interviewed engineers and maintena nce personnel, and reviewed records to verify ignition sources were controlled in accordance with procedural requirements; and

• reviewed records of hot work conducted to verify that compensa tory measures were taken and that hot work permits were renewed daily.

7 Fire and Gas Detection and Alarm Systems (IP Section 02.03)

The inspectors reviewed selected fire detection devices to veri fy that detection and alarm systems were able to detect the minimal fire within the require d time and initiate the safety function credited in the SAR. Specifically, the inspectors cond ucted the inspection activities listed below:

• interviewed licensee engineers and reviewed records related to the VESDA system; and

• conducted plant walk-downs in SBM-1001 to verify fire detectio n and alarm systems were installed and maintained as required.

Suppression Systems and Activities (IP Section 02.04)

The inspectors interviewed license engineers, reviewed fire pro tection program documents, and conducted plant walk-downs to verify that suppression syste ms were capable of performing the safety function credited in the SAR, and/or the ISAS. Specifically, the inspectors performed the following activities:

• interviewed licensee engineers, reviewed event reports and mai ntenance WOs, and walked down the fire water tanks and fire water pump h ouse to verify the licensee-maintained fire suppression systems;

• interviewed licensee engineers and maintenance personnel, revi ewed the licensee's pre-fire plan, and conducted walk-downs in the CRDB and SBM-1001 to verify the licensee maintains firefighting equipment (e.g., fire extinguishers, fire risers) in designated locations; and

• walked down areas where water-based suppression was prohibited due to criticality or electrical hazards to verify that water-based su ppression systems were not present.

Passive Fire Protection Features (IP Section 02.05)

The inspectors reviewed selected passive fire protection featur es to verify these were in a proper material condition to perform the safety function credit ed in the SAR, or the ISAS. Specifically, the inspectors performed the following:

• interviewed licensee operators, engineers and maintenance pers onnel; reviewed impairments, procedures, and WOs; and conducted walk-d owns and observed maintenance to verify that IROFS35 fire doors meet the license and ISA requirements; and

• interviewed licensee engineers and maintenance personnel; revi ewed training, condition reports, and procedures to verify ventilation fire da mpers met license and ISA requirements.

Fire Protection Program Elements (IP Section 02.06)

8 The inspectors reviewed selected fire protection program elemen ts to verify compliance with the license requirements. Specifically, the inspectors complete d the following activities:

• interviewed licensee engineers and reviewed training material and impairment records to verify that compensatory measures (e.g., a fire watc h) were imposed when IROFS were impaired;

• reviewed records and conducted interviews to verify that site fire brigade training and drills were conducted in accordance with license r equirements;

• interviewed licensee fire protection staff and the manager res ponsible for fire protection to verify the staffing level, training, and experien ce of the fire protection organization met license requirements;

• observed emergency lighting test in SBM 1005/1006 under WO 100 0465232;

• reviewed the current and previous versions of the pre-fire pla n, and conducted walk-downs in SBM-1001 to verify changes to the pre-fire plans were consistent with the license requirements and that th e pre-fire plan matched conditions in the field; and

• reviewed memoranda of understanding (MOU) with the city of Eun ice and city of Hobbs fire departments to verify that they were renewed peri odically.

Identification and Resolution of Problems (IP Section 02.07)

The inspectors reviewed the licensees identification and resol ution of fire protection issues to verify compliance with the license requirements. Specificall y, the inspectors reviewed the following CAP entries, audits, and self-assessments:

• EV 120693, 123647, 127052, 137600, 140151, 140416, 140595, 140 598, 140701, 140834, 140937, 141490, 142826, 142899, 143194, 143324

• ER-2013-2390; and

• fire protection audit 2020-A-09-015 and associated EVs.

RADIOLOGICAL CONTROLS

86740 - Inspection of Transportation Activities

The inspectors evaluated select aspects of the licensees Trans portation Activities program to determine whether the licensee has established and is maintaini ng an effective, management-controlled program; to ensure radiological and nuclear safety i n the receipt, packaging, delivery to a carrier and, as applicable, the private carriage of licens ed radioactive materials; and to determine whether transportation activities are in compliance w ith the applicable NRC 10 CFR Parts 20 and 71 regulations and Department of Transportation (D OT) (49 CFR Parts 171-178) transport regulations.

The inspectors examined the licensees procedures and shipment records and observed actual package preparations and operations to verify compliance with t he regulations above.

Specifically, the inspectors rev iewed or observed the following :

• receipt contamination surveys and physical inspections of 48Y cylinders on the uranium byproduct cylinder (UBC) storage pad;

9

• crane operations involving the handling of 48Y and 30B cylinde rs;

• radiological survey of Hitman 962/Trailer # L00024;

• shipping documentation for 72 drums solid waste/10 poly cubes of liquid waste;

• shipping documentation for radioactive-low specific activity ( LSA) solid/liquid wastes for treatment/disposal; and

• shipment preparations of six truckloads of UF6 30B cylinders/o verpacks.

Preparation of Packages for Shipment (IP Section 02.01)

The inspectors examined the licensees procedures and package p reparations to verify compliance with federal regulations and licensee procedures LO-3-3000-01, Transport Planning and RW-3-1000-13, Shipping Radioactive and Mixed Was te. Specifically, the inspectors reviewed the following:

• shipping document package and final placarding/verifications f or a shipment of six full 30B cylinders including their UX-30 overpacks;

• cylinder internal inspections/pressure test records (IROFS16a) in accordance with LO-3-1000-04, Cylinder Release for Use, Rev. 3; and

• cylinder external inspections i ncluding cylinder valve accepta nce criteria in accordance with LO-3-2000-01, External Cylinder Inspection, R ev. 19.

Delivery of Completed Packages to Carriers (IP Section 02.02)

The inspectors examined the licensees procedures and shipment records and observed actual transport activities to determine that the licensee met package delivery regulations and Chapter 11.0 of the SAR. Specifically, the inspectors revie wed or observed the following:

• Shipping Manifest 0918-02-0003, Shipment of 72 Drums Radioact ive-LSA-II, UN3321, Fissile Excepted (DAW), to Energy Solutions, dated 12/ 4/2020;

• Shipping Manifest 0918-02-0003, Manifest Tracking 019278840 J JK, Shipment of 10 Poly Totes of Radioactive Solutions for Treatmen t and Disposal, Radioactive-LSA-II, UN3321, Fissile Excepted D002/D00 7, to Energy Solutions, dated 10/28/2019; and

• Shipping Manifest 0918-01-0004, Manifest Tracking 019278841, Shipment of 10 Poly Totes of Radioactive Solutions for Treatment and Dispos al, Radioactive-LSA-II, UN3321, Fissile Excepted, D002/D007, to Ene rgy Solutions, dated 10/25/2019.

Receipt of Packages (IP Section 02.03)

The inspectors examined the licensees procedures to verify com pliance with 10 CFR 20.1906 and Section 11.4 of the SAR. Specifically, the inspecto rs reviewed the following:

• LO-3-2000-01, Receipt and Shipping of Cylinders," Rev. 24;

• LO-3-2000-03, On-Site Handling of UF6 Cylinders, Rev. 14 for compliance with IROFS 36c/e;

10

• samples of incoming and outgoing radiological surveys for comp liance with RP-4-1000, Radioactive Shipment Surveys; and

• records of internal inspections (IROFS 16a) for incoming empty cylinders completed in accordance with LO-3-1000-04, "Cylinder Release fo r Use, Rev. 3.

Records and Reports (IP Section 02.04)

The inspectors examined the licensees recordkeeping and report s to verify compliance with the regulations above, Chapter 11.0 of the SAR, and Section 6 o f the QAPD. Specifically, the inspectors reviewed the following:

• Certificate of Receipt for Manifest 0918-01-0004, Manifest Tr acking 019278841 for Disposal, dated 10/28/2019;

• Certificate of Receipt for Manifest 0918-01-0003, Manifest Tr acking 019278840 JJK for Disposal, dated 10/28/2019;

• Nuclear Material Transaction Report Form 741, Manifest 0918-0 1-0003, dated 10/24/2019; and

• Special Nuclear Material Exemption Certification, dated 10/2 2/2019.

General License Requirements (IP Section 02.05)

The inspectors reviewed licensee package certifications utilize d for shipment of radioactive material packages to verify compliance with 10 CFR 71, Subpart C, and Chapter 11.0 of the SAR. Specifically, the inspectors reviewed the following:

• Model UX-30 Certification Type B (U) F Fissile Package Design Certificate USA/9196/B (U) F-96, Rev. 34.; and

• Model 30B Certification Type AF Fissile Package Design Certif icate USA/0411/AF-96, Rev. 12.

Management Controls (IP Section 02.06)

The inspectors reviewed the system of management controls for t ransportation activities to verify compliance with Chapter 11.0 of the SAR. Specifically, t he inspectors reviewed the following:

• LO-4-2000-03, Inbound 30B and 48Y Release Desktop Guide, Rev. 9;

• 0023-BSH-2016-001, Package Design Safety Report for Package D esign DN-30, Rev. 3; and

• LCTP-21-04, Management Assessment of UF6 Incident During Tran sport, Rev. 0.

Indoctrination and Training Program (IP Section 02.07)

11 The inspectors reviewed training and indoctrination documentati on to verify compliance with Chapter 11 of the licensee application. Specifically, the inspectors reviewed:

• training records showing completion of the class titled "Trans portation Radioactive Materials" for three UUSA employees involved in tra nsportation of radioactive waste

Quality Assurance Program (IP Section 02.08)

The inspectors reviewed the quality assurance documents to veri fy compliance with 10 CFR 71.137, Section 2.3.5.2 of the SAR, and the QAPD. Specifically, the inspectors reviewed:

• UX-30-OMM, Columbia Hi Tech, UX-30 Operation and Maintenance Manual, Rev. 1; and

• UX-30 Manual, Columbia Hi Tech, Manufacturers Practices to I nsure Regulatory Compliance and Longer Useful Life, Rev. 0.

Audit Program (IP Section 02.09)

The inspectors reviewed the assessment reports to verify compli ance with 10 CFR 71.137 and Section 11.5 of the SAR and Section 18 of the QAPD. Specifi cally, the inspectors reviewed:

• UUSA Audit 2021-A-02-003, Logistics and Transportation, date d April 9, 2021

Procurement and Selection of Packagings (IP Section 02.10)

The inspectors examined the licensees packaging, including tho se provided from a vendor and revised procedures and records to verify compliance with th e federal regulations above, Section 11.2 of the SAR, and Section 14 of the QAPD. Specifical ly, for packaging that is used by the licensee to transport or to deliver license d material to a carrier for transport, the inspectors reviewed the following:

• records associated with IROFS 16a cylinder internal inspection s/pressure testing records in accordance with LO-3-1000-04, Cylinder Rele ase for Use, Rev. 3; and

• Model 30B Certification Type AF Fissile Package Design Certif icate USA/0411/AF-96, Rev. 12.

Preparation of Packages for Shipment (IP Section 02.11)

The inspectors examined the licensees package markings and doc umentation to verify compliance with applicable parts of the federal regulations abo ve and Section 13 of the QAPD. Specifically, the inspectors reviewed the following:

12

• LO-3-3000-01, Transport Planning, Rev. 25; and

• RP-3-5000-01, Radioactive Material Shipment Surveys.

Periodic Maintenance of Packagings (IP Section 02.12)

The inspectors examined the licensees records to verify compli ance with applicable parts of the federal regulations above. Specifically, the inspectors reviewed the following:

• calibration records for torque wrenches and thread go and n o-go gauges used on UF6 cylinders

Records, Reports, and Notifications (IP Section 02.13)

The inspectors reviewed the licensees records and procedures f or recordkeeping and reports to verify that a system is in place to verify complianc e with the federal regulations and Chapter 11 of the SAR. Specifically, the inspectors review ed the following:

• EV 140329, involved an error in calculating trace radionuclide content of solid low-level waste was discovered during database testing;

• EV 140435, involved improper removal of cylinder tamper indica ting devices (TIDs) from System Applications and Products (SAP) computer dat abase; and

• EV 144742, involved multiple issues including containers not l isted in uranium accounts, TID accounting issues, TID on wrong cylinder in SAP, and multiple cylinders with TIDs applied in SAP that were no longer physical ly applied to the cylinder.

88045 - Effluent Control and Environmental Protection

The inspectors evaluated selected aspects of the licensees env ironmental protection program to verify compliance with selected portions of 10 CFR 20, Part 70, and the facilitys SAR.

Program Implementation (IP Section 02.01)

The inspectors reviewed any significant changes to the effluent control and environmental protection program, discussed with the licensee any new unplann ed releases or contamination identified, and screened the CAP in order to veri fy the environmental protection program was being implemented in compliance with lic ense requirements. Specifically, the inspectors reviewed the followi ng documents and/or performed the following activities:

• accompanied licensee environmental and radiological staff for demonstrations on use of operating exhaust stack particulate sampling equipmen t, use of operating perimeter ambient air particulate samplers; collectio n of sample media from the equipment, and analysis of the collected samples ; and

• accompanied licensee environmental and radiological staff for demonstrations of collecting water and other environmental samples including v egetation sampling, soil sampling, storm water retention and detention ba sin sediment

13 sampling, and sanitary wastewater samples collected from the ma in sanitary lift station.

Training (IP Section 02.05)

The inspectors conducted interviews, reviewed training and indo ctrination documentation, and directly observed activities of the environmental and radio logical staff performing environmental activities, to evaluate the licensee's compliance with Section 11.3 of the SAR. Specifically, the inspectors reviewed the following:

• Department training records for environmental and radiological staff;

• Procedure TQ-3-0100-13, Training and Qualification Guidelines, Rev. 12

• UUSA Maestro Training Reference Guide, dated 2021;

• Procedure EN-3-2020-01, EN Air Sampling, Rev. 7; and

• Procedure EN-3-2020-02, EN Media Sampling, Rev. 8.

Effluent Monitoring (IP Section 02.09)

The inspectors observed effluent monitoring systems exhaust sta cks from the upstream gaseous exhaust ventilation system (GEVS) systems, discussed ca libration and maintenance with the radiological staff to verify compliance wi th the regulation and Chapter 9.0 of the SAR. Specifically, the inspectors completed the fol lowing activities:

• reviewed WO 1000449078, Alpha Monitor Cartridge Change, (air sampler media) for exhaust stacks UN-NEF-1001-562-1MA1 through UN-NEF-1 005-562-1MA2, dated 12/21/2020;

• reviewed WO 1000466180, Alpha Monitor Cartridge Change, (air sampler media) for exhaust stacks UN-NEF-1001-562-1MA1 through UN-NEF-1 005-562-1MA2, dated 7/6/2021;

• reviewed WO 1000466176, Alpha Monitor Cartridge Change, (air sampler media) for exhaust stacks UN-NEF-1001-562-1MA1 through UN-NEF-1 005-562-1MA2, dated 3/3/2021; and

• observed air sampling conducted in accordance with procedure E N-32020-01, EN Air Sampling, Rev. 7.

Environmental Sampling (IP Section 02.13)

The inspectors reviewed environmental sampling related to ambie nt air, and sanitary sewer, to verify compliance with 10 CFR 20.1501 and Chapter 9.0 of the SAR. Specifically, the inspectors completed the following activities:

• walked down air and water environmental sample points includin g a GEVS air exhaust stack sampler/equipment, ambient air samplers located a round the perimeter of the facility, several retention and detention basi ns for stormwater runoff/condensate from air conditioning, and the final sanitary lift station sampling location;

14

• walked down the I-Matic automatic low background (radionuclide ) counting system located in the main laboratory and confirmed the presenc e of quality control standard sources: thorium 230 alpha source and a techne tium beta source, as required by the operating procedure EN-3-3030-01;

• reviewed procedure EN-3-2020-01, EN Air Sampling, Rev. 7;

• reviewed procedure EN-3-2020-02, EN Media Sampling, Rev. 8;

• reviewed WO 1000449078, Alpha Monitor Cartridge Change, (air sampler media) for exhaust stacks UN-NEF-1001-562-1MA1 through UN-NEF-1 005-562-1MA2, dated 12/21/2020;

• reviewed WO 1000466180, Alpha Monitor Cartridge Change, (air sampler media) for exhaust stacks UN-NEF-1001-562-1MA1 through UN-NEF-1 005-562-1MA2, dated 7/6/2021; and

• reviewed WO 1000466176, Alpha Monitor Cartridge Change, (air s ampler media) for exhaust stacks UN-NEF-1001-562-1MA1 through UN-NEF-1 005-562-1MA2, dated 3/3/2021.

Radioactive Waste Classification, Characterization, and Storage (IP Section 02.15)

The inspectors reviewed documentation and records of facility a ctivities and observed posting and labeling of storage areas and containers to verify compliance with the requirements of 10 CFR 61.55 and the Section 12.6.1.5 of the SA R. Specifically, the inspectors performed the following:

• walked down the liquid effluent collection and transfer system, the bulk storage tank, the multifunction decontamination train, the vacu um pump rebuild workshop and associated area to determine compliance wi th labeling of containers that hold radioactive waste solutions derived fro m equipment decontamination and refurbishment activities;

• reviewed records and conducted a walkdown of the bulk storage tank, the multifunction decontamination train, the vacuum pump rebuild wo rkshop and associated areas to determine compliance with mass limits for I ROFS55a and IROFS55b controls as described in the ISA Summary Section 3.5.1 2, and SAR Section 12.6.1.5.

INSPECTION RESULTS

CAAS inaudibility not reported Severity Report Section Severity Level (SL) IV 88015 Non-Cited Violation (NCV) 07003103/2021003-01 Open/Closed The NRC inspectors identified a SL-IV NCV of the reporting requ irements in 10 CFR 70.50(b)(2).

Description:

One July 20, 2021, during the 2021 annual CAAS ma intenance, licensee employees identified that the CAAS was not clearly audible in r oom 242 of the Technical Services Building (TSB). This was documented in the licensee's CAP as EV 147490. On July 21, 2021, the licensee screened this event as not reportab le because "Compensatory

15 measures which achieve an equivalent safety function were estab lished within 24hrs following the identification of the alarms in the TSB not being clearly a udible."

The CAAS is required by 10 CFR 70.24(a) and license commitments to mitigate the consequences of a criticality accident by ensuring that all per sonnel withdraw to an area of safety upon the sounding of the alarm. In 10 CFR 70.24 the CAAS is required to be "clearly audible". Employees conducting the tests could not hear the al arm and sound pressure readings taken while the CAAS was alarming were only about one decibel dB above those taken while the CAAS was off. Prior to the time of discovery n o redundant equipment was available and operable. No other locations were identified whe re the CAAS was not clearly audible.

This issue is considered an isolated failure to report as no ot her examples of failures to report were found during this inspection, or recent inspections involv ing radiological protection or nuclear criticality safety.

Corrective Actions: On September 17, 2021, the licensee notifi ed the NRC Headquarters Operations Officer in accordance with 10 CFR 70.50(b)(2); which is documented in EN55480, CAAS Alarm Not Clearly Audible.

Corrective Action

References:

This issue was entered into the licensees CAP as EV 148123.

Analysis: The regulations in 10 CFR 70.50(c)(1) require, in pa rt, that "Licensees shall make reports required by paragraphs (a) and (b) of this section... to the NRC Operations Center."

10 CFR 70.50(b) "Twenty-four hour report" requires, in part, that "Each licensee shall notify the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the discovery of any of the follo wing events involving licensed material:... (2) An event in which equipment is disabled or fa ils to function as designed when:

(i) The equipment is required by regulation or licensee conditi on to... mitigate the consequences of an accident; (ii) The equipment is required to be available and operable whe n it is disabled or fails to function; and (iii) No redundant equipment is available and operable to perfo rm the required safety function."

In this instance, the CAAS failed to function as designed as re quired by 10 CFR 70.50(b)(i) by failing to provide a clearly audible evacuation alarm in TSB ro om 242 as required by 10 CFR 70.24 to mitigate the consequences of an accident. In addition, the CAAS was required to be available and operable, both when the failure was found, and du ring any prior period of inaudibility; therefore, criteria (ii) of 10 CFR 70.50(b)(2) wa s met. At and before the time of discovery, no redundant equipment was available and operable to perform the required safety function of the CAAS in TSB room 242; therefore, criteria (iii) of 10 CFR 70.50(b)(2) was satisfied. Because all the criteria in 10 CFR 70.50(b)(2) were met, a report should have been made to the NRC in accordance with 10 CFR 70.50(b).

This failure to report had no actual or potential safety or sec urity consequences. However, a failure to make a required report to the NRC does have regulato ry significance. Per Enforcement Policy Section 2.2.1(c) Unless otherwise categoriz ed in the violation examples contained in this Policy (i.e., Section 6.0), the severity leve l of a violation involving the failure to make a required report to the NRC will depend on the signifi cance of and the circumstances surrounding the matter that should have been repo rted. the Agency will normally cite a licensee for a failure to report a condition or event if the licensee knew of the

16 information to be reported and did not recognize that it was re quired to make a report.

Section 2.3.2 "Non-cited Violation," of the Enforcement Policy states, in part, "If a licensee...

has implemented a CAP that is determined to be adequate by the NRC, the NRC will normally disposition SL-IV violations... as non-cited violations (NCVs) if all the criteria in Paragraph 2.3.2.a. are met."

Enforcement:

Severity: Consistent with Section 6.0, Violation Examples, o f the NRC Enforcement Policy the violation aligned with the SL-IV violation Example 6.9(d)(5 ) in that it involved a licensee failure to make a report required by 10 CFR 70.50(c)(1).

Violation: Contrary to the above requirements in 10 CFR 70.50, from July 21, 2021; to September 16, 2021, the licensee failed to notify the NRC of an event in which equipment failed to function as designed when, the equipment was required by regulation and licensee condition to mitigate the consequences of an accident, the equi pment was required to be available and operable when it failed to function; and no redun dant equipment was available and operable to perform the required safety function on and bef ore the licensee's discovery of the condition.

This is a violation of 10 CFR 70.50(b); which is being document ed as NCV 70-3103/2021003-01, "CAAS Inaudibility Not Reported," and is being opened and c losed in this report.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On August 12, 2021, the inspectors presented the Fire Protecti on and Operational Safety inspection results to Karen Fili and other members of th e licensee staff.

• On September 16, 2021, the inspectors presented the NCS, Trans portation and the 2020 Environmental follow-up inspection results to Karen Fili a nd other members of the licensee staff.

17