ML23193B047

Urenco USA Integrated Inspection Report 07003103/2023002

ML23193B047
Person / Time
Site:	07003103
Issue date:	07/14/2023
From:	Mathis R NRC/RGN-II/DFFI
To:	Padgett W Louisiana Energy Services, URENCO USA
References
EN 56484 IR 2023002
Download: ML23193B047 (15)

Text

EN 56484 Wyatt Padgett Compliance Manager Louisiana Energy Services dba URENCO USA (UUSA)

URENCO USA P.O. Box 1789 Eunice, NM 88231

SUBJECT:

URENCO USA - INTEGRATED INSPECTION REPORT 07003103/2023002

Dear Wyatt Padgett:

This letter refers to the U.S. Nuclear Regulatory Commission inspection activities conducted from April 1 to June 30, 2023, at the URENCO USA facility. The results of these inspections were discussed with you and other members of your staff. The results of this inspection are documented in the enclosed report.

No violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Robert Mathis, III, Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07003103 License No. SNM-2010

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV July 14, 2023 Signed by Mathis, Robert on 07/14/23

ML23193B047 X

SUNSI Review X

Non-Sensitive

Sensitive X

Publicly Available

Non-Publicly Available OFFICE RII:DFFI RII:DFFI RII:DFFI RII:DFFI NAME T. Sippel L. Cooke N. Peterka R. Mathis DATE 07/13/2023 07/13/2023 07/13/2023 07/14/2023

Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:

07003103 License Number:

SNM-2010 Report Number:

07003103/2023002 Enterprise Identifier:

I-2023-002-0045 Licensee:

Louisiana Energy Services dba URENCO USA (UUSA)

Facility:

URENCO USA Location:

Eunice, NM Inspection Dates:

April 3, 2023, to April 28, 2023 Inspectors:

L. Cooke, Fuel Facility Inspector G. Goff, Fuel Facilities Inspector N. Peterka, Sr. Fuel Facility Project Inspector M. Romano, MC&A Physical Scientist/Statistic T. Shewmaker, Fuel Facility Inspector Approved By:

Robert Mathis, III, Chief Projects Branch 1 Division of Fuel Facility Inspection

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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 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-026, "Nuclear Criticality Safety Analysis of Assay Units 1001 and 1002 Cascade Valve Frames," Revision (Rev.) 1, including the review of double contingency principle, normal, credible abnormal, and non-credible accident sequences

NCS-CSA-015, "Nuclear Criticality Safety Analysis of IROFSC22 Periodicity,"

Rev. 12, including the review of the engineering evaluation for the periodicity of implementing item relied on for safety (IROFS) C22

NCS-CSA-025, "Criticality Safety Analysis of UUSA Process Gas Pipework (All Assays)," Rev. 4, including normal, credible abnormal, and safe-by design product attributes for the process gas piping

NCS-CSA-016, "Criticality Safety Analysis of 30B Cylinders," Rev. 8, including the review of double contingency principle and normal accident sequences

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:

reviewed maintenance records and procedures for IROFS 1 and 2, administrative controls ensuring cylinder integrity

reviewed maintenance records and procedures for IROFS 16 a/e/f, administrative moderator controls

reviewed maintenance records and procedures for IROFS 30 a/b/c, an administrative moderator control

reviewed records and surveillance results for IROFS 22C, an administrative enrichment control

performed a walkdown of the Product Take-Off 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:

reviewed IROFS initial operator training, General NCS Analysis Training, and the 2022 Nuclear Safety Worker Training

observed a licensee NCS engineer conduct a weekly NCS inspection in the Liquid Effluent and Collection Transfer System (LECTS), reviewed recent weekly NCS walkdowns, reviewed 2022 NCS annual assessment

interviewed licensee NCS engineers and management concerning schedule, conduct, results, and documentation of the weekly NCS inspections and the NCS quarterly audits

observed maintenance technicians performing IROFS 1 and 2 surveillance testing

observed operators performing IROFS C22 mass balance verification 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 recently revised NCS-related procedures CR-3-1100-01, "Verification for implementation of NCS Evaluations and Analyses," Rev. 10, CR-3-1000-02, "Nuclear Criticality Safety Limit Postings," Rev. 8 and 9, CR 1000-03, "NCS Weekly Walkthroughs ad Periodic Assessments," Rev. 16 and 17, EG-3-2100-05, "Commercial Grade Dedication Process," Rev 28, EG 5

2100-09, ID&R of Non-conforming Items," Rev. 11, and EG-3-3100-02, "IROFS Boundary Definitions," Rev. 8

reviewed qualifications for recently qualified NCS Engineer

reviewed a list of qualified Building Operators and validated list versus an Operations watch bill Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees corrective action program (CAP) to verify compliance with 10 CFR 70. Specifically, the inspectors observed activities, reviewed documents, and/or interviewed licensee staff concerning the following:

reviewed NCS-related and criticality accident alarm system (CAAS)-related CAP entries

interviewed Maintenance Supervisor regarding recent CAAS-related CAP entries including EV 149782, EV 159551, EV 159065, EV 159529, EV 158476 FACILITY SUPPORT IP 88161 - Corrective Action Program (CAP) Implementation at Fuel Cycle Facilities The inspectors evaluated selected aspects of the licensees NRC approved CAP to verify compliance with selected portions of Chapter 11 of the facilitys license application, Regulatory Guide 3.75, the quality assurance program document (QAPD), and applicable licensee procedures.

Organization (IP Section 02.01)

The inspectors conducted interviews with the CAP manager and staff and reviewed the structure of the licensees CAP organization to verify that the licensees CAP organization included an independent reviewing organization that was auditable, independent of the licensees production activities, and had appropriate authority to perform its responsibilities.

Specifically, the inspectors performed the following activities:

reviewed the CAP organization chart

reviewed Safety Analysis Report, Rev. 50

interviewed licensee personnel to verify that the independent reviewing organization is the quality assurance (QA) department which is in turn audited by an off-site (3rd party) organization, Anata Solutions

interviewed the licensee point of contacts for screening corrective actions, evaluating the effectiveness of these actions, and determining trending in any certain area(s)

reviewed CA-3-1000-01, Performance Improvement Program Policies, Programs, and Procedures (IP Section 02.02)

The inspectors reviewed CAP policies and procedures to verify that the CAP procedures included expectations, requirements, personal responsibilities, and implementation processes which provide guidance to implement the CAP. The inspectors reviewed procedures to verify that they were updated periodically to maintain consistency with

6 licensee processes, structures, and functions. Specifically, the inspectors performed the following activities:

reviewed CA-3-1000-01, Performance Improvement Program, Rev. 51

reviewed CA-3-1000-02, Apparent Cause Evaluation Guidelines, Rev. 12

reviewed CA-3-1000-06, Event Review Board, Rev. 21

reviewed CA-3-1000-09, Assessment Program, Rev. 17

reviewed Quality Assurance Program Description (QAPD), Rev. 44

interviewed the licensee point of contact for the CAP regarding: implementation of the program, determining severity levels (screening), resolving events/issues, and trending Identification, Reporting, and Documentation of Safety and Security Issues (IP Section 02.03)

The inspectors evaluated implementation of the CAP in the areas of identification, documentation, and reporting of conditions adverse to safety and security; employee training, and safety conscious work environment (SCWE). The inspectors reviewed training records, conducted SCWE interviews, interviewed staff involved in the implementation of SCWE programs, reviewed SCWE program documentation and procedures, and reviewed condition reports. Specifically, the inspectors performed the following activities:

reviewed procedure EC-3-1000-01, Employee Concerns Program, Rev. 17

reviewed form EC-3-1000-F-1, Employee Concerns Program - Concern Disclosure Statement, Rev. 17

reviewed the 2019 Independent Audit of the URENCO USA Employee Concerns Program, dated December 3, 2019

reviewed SA-2021-020, Employee Concerns Program Self-Assessment, November 8 - November 30, 2021

interviewed the Employee Concerns Program (ECP) Manager regarding the implementation of the program, employees' ease of using the program, and any changes as a result of the program

reviewed EC-1-1000-01, Safety Conscious Work Environment Policy, Rev. 4

reviewed UUSA Safety Culture Assessment, dated October 13, 2022

reviewed training program pertaining to the ECP and SCWE as well as select records to ascertain the training program was being followed

interviewed site workers such as pump rebuild technicians, a radiation protection technician, a chemistry analyst, lab manager, a maintenance technician, and an operator regarding the SCWE and the ECP

interviewed the training manager pertaining to the training program requirements as related to submitting corrective actions, SCWE, and ECP and reviewed select records of employee training

observed a shift turnover meeting between operators and managers for communication of safety concerns Significance Assessment and Causal Evaluation of Safety and Security Issues (IP Section 02.04)

The inspectors assessed the licensees process for assessing significance and evaluating causes for items entered into the CAP. The inspectors reviewed the CAP procedure, interviewed the CAP manager and staff, attended event review screening committee

7 meetings, and reviewed condition reports/causal evaluations. Specifically, the inspectors performed the following activities:

attended two Plan of the Day meetings

attended two Event Report Screening Committee (ERSC) meetings

reviewed the quorum functional areas represented for the ERSC

attended the Compliance Bi-Monthly meeting

reviewed material discussed in the Compliance Bi-Monthly meeting

reviewed a sample of EVs written since the last CAP inspection Development and Implementation of Corrective Actions (IP Section 02.05)

The inspectors evaluated the CAP procedure, reviewed condition reports, and conducted interviews to determine whether the licensee was effectively evaluating the actual or potential significance of events, classifying the conditions, and applying a graded approach to corrective action implementation based on the issues significance. Specifically, the inspectors reviewed the following:

interviewed a CAP manager responsible for significance assessment and reviewed the criteria used for making this determination, as described in the performance improvement program procedure

discussed the criteria for a Significant Condition Adverse to Safety/Security versus a Condition Adverse to Safety/Security with the CAP Manager

reviewed the Root Cause Evaluation for the 2022 Significant Inventory Difference

discussed the root cause, the extent of condition, and the actions taken to prevent recurrence with the CAP manager for the Significant Inventory Difference Root Cause Evaluation

reviewed condition reports related to legacy contamination events in LECTS (see Document List)

interviewed the CAP manager and other management involved with the CAP regarding the assessment of severity and priority and the effectiveness of the corrective action to prevent recurrence

reviewed EVs related to implementing IROFS controls Assessment of Corrective Action and Program Effectiveness (IP Section 02.06)

The inspectors verified that the licensee was evaluating the effectiveness of the CAP at specified intervals. The inspectors reviewed self-assessments, program audits, performance indicators, and trend reports. Additionally, the inspectors performed initial follow-up on EN 56484 related to IROFS50 Crane Swing Controls. Specifically, the inspectors reviewed the following:

reviewed the last four independent assessment QA audits conducted by Anata Solutions

reviewed Corrective Action Program Self-Assessment Assessment Number:

SAE 2023-11; January 20 - February 3, 2023

reviewed UUSA Louisiana Energy Services, LLC, Performance Assessment and Feedback, NQA-1 Audit, 2022-A-05-010; dated May 31, 2022

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reviewed the following trend reports and the supporting documentation for each (see the Documents List) to determine if the licensee followed their process for establishing a trend:

o EV 141662 Areas Require Further Evaluation Based on 2020 2nd Semi-Annual Trend Report o

EV 147541 Areas Require Further Evaluation Based on 2021 1st Semi-Annual Trend Report o

EV 149421 Areas Require Further Evaluation Based on 2021 2nd Semi-Annual Trend Report o

EV 156860 Areas Require Further Evaluation Based on 2022 1st Semi-Annual Trend Report

reviewed the latest corrective action for LECTS: EV 159914 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 April 6, 2023, the inspectors presented the nuclear criticality safety inspection results to Paul Lorskulsint and other members of the licensee staff.

On April 27, 2023, the inspectors presented the corrective action program inspection results to Karen Fili and other members of the licensee staff.

9 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date Corrective Action Documents EV 159085, 159022, 159752, 159632, 159559, 159551, 159529, 159065, 158476, 154070, 152997, 151946, 151497, 151142, 149782 NCS-related CAs Various Corrective Action Documents Resulting from Inspection EV 159996 Operator Training Record Not Readily Retrievable 04/05/2023 NCS-CSA-006 Criticality Safety Analysis of the Product Vent Pump and Chemical Trap Set Rev. 10 NCS-CSA-015 Nuclear Criticality Safety Analysis of IROFS C22 Periodicity Rev. 12 NCS-CSA-016 Criticality Safety Analysis of 30B Cylinders Rev. 8 NCS-CSA-025 Criticality Safety Analysis of UUSA Process Gas Pipework (All Assays)

Rev. 4 Engineering Evaluations NCS-CSA-026 Nuclear Criticality Safety Analysis of Assay Units 1001 and 1002 Cascade Valve Frames Rev. 1 Miscellaneous SNT-TC-1A ASME Recommended Practice 2006 2006 CR-3-1000-03 NCS Weekly Walkthroughs and Periodic Assessments Rev. 17 EG-3-2100-05-F-2 Commercial Grade Dedication Plan Rev. 2 and 3 ISA Summary Integrated Safety Analysis Summary Rev. 33b LO-3-1000-04 Cylinder Release for Use Rev. 4 MA-3-2000-01 PFPE Oil Sampling Rev. 6 MA-3-2000-03 Oil Addition to Vacuum Pumps Rev. 11 MA-3-2000-08 Internal Inspection of New or Clean Product Cylinders Rev. 10 MA-3-3400-01 IROFS1 Station Heater and Fan High Temperature Trip -

RTD Surveillance Rev. 12 88015 Procedures MA-3-3400-02 IROFS2 Station Heater and Fan High Temperature Trip - TC Rev. 14

10 Inspection Procedure Type Designation Description or Title Revision or Date Surveillance NEF-BD-01 Auto Trip of Station Defrost Heater and Fan (RTD)

Rev. 3 NEF-BD-02 Auto Trip of Station Defrost Heater and Fan (T/C)

Rev. 3 NEF-BD-16a Administratively Limit Moderator Mass in a New or Cleaned 30B Cylinder Rev. 14 NEF-BD-16e Administratively Limit Moderator Mass in a Heeled 30B Cylinder Rev. 4 NEF-BD-16f Administratively Limit Moderator Mass in a Heeled 30B Cylinder Rev. 4 NEF-BD-30a Limit Hydrocarbon Oil by Controlling Type Used Rev. 7 NEF-BD-30b Limit Hydrocarbon Oil by Testing Prior to Adding to Pump Rev. 8 NEF-BD-30c Limit Hydrocarbon Oil by Testing Prior to Operation Rev. 8 NEF-BD-C22 Verify Subcriticality by Mass Balance Calculation Rev. 14 OP-3-3300-01-F5 Mass Balance Verification (IROFS C22) Data Sheet Rev. 42 OP-3-420-02 IROFS 16e Surveillance Rev. 12 OP-3-460-01 Product Blending and Vent System Rev. 18 QAPD Quality Assurance Program Description Rev. 44 SAR Safety Analysis Report Rev. 49 WO 1000575639 MA-3-3400-01/02 IROFS 1 and 2 Station Heater and Fan High Temperature Trip - RTD and TC Surveillance 3/13/2023 WO 1000575645 MA-3-3400-01/02 IROFS 1 and 2 Station Heater and Fan High Temperature Trip - RTD and TC Surveillance 3/14/2023 WO 1000575680 MA-3-3400-01/02 IROFS 1 and 2 Station Heater and Fan High Temperature Trip - RTD and TC Surveillance 3/15/2023 Work Orders WO 1000596717 MA-3-2000-01 PFPE Oil Sample 3/28/2023-3/29/2023 EV 111023 Leak from #2 Slab Tank pump 03/03/2016 EV 113877 Fixed contamination 08/04/2016 EV 113877 Survey Report 08/04/2016 EV 116283 Liquid Effluent Leak on 684 System 12/07/2016 EV 117238 Contamination Area Identified Underneath Slab Tank Pump 02/28/2017 EV 136211 Leak from #3 / #4 Slab Tank 11/24/2019 88161 Corrective Action Documents EV 144537 Adverse Trend 4/15/2021

11 Inspection Procedure Type Designation Description or Title Revision or Date EV 144539 Adverse Trend 4/15/2021 EV 145966 Rad Waste Handling Audit 2021-A04-006 Finding 1 06/01/2021 EV 148318 Failed IROFS35 Inspections 10/04/2021 EV 148894 Leak from LECTS Slab tank 2 11/29/2021 EV 149668 Liquid Spill in LECTS Room 02/28/2022 EV 149668 Action Tracking - AC 168332 04/27/2022 EV 149668 Action Tracking - AC 168601 05/17/2022 EV 149668 Action Tracking - AC 171609 10/14/2022 EV 149668 Action Tracking - AC 167990 04/01/2022 EV 149805 Possible Significant Inventory Difference EV 149975 Action Tracking - AC 173527 02/23/2023 EV 149975 BCI UUSA NRC Identified NCV - Failure to Report Spill in LECTS RCA 03/24/2022 EV 151070 IROFS35 Rollup Door Issue 04/01/2022 EV 151086 Worker Not Trained in IROFS24C Crossed IROFS24C Barrier 04/04/2022 EV 151253 Autoclave 1LS3 Contamination 04/14/2022 EV 151905 Adverse Trend with Adverse Condition EVs Investigation -

Repeat EV 151908 NRC NCV Regarding Event Screening 6/14/2022 EV 151944 Root Cause Investigation - Significant Inventory Difference EV 156393 Effects of Non-conformance Not Adequately Documented 07/26/2022 EV 159914 Valve Flange 03/29/2023 LS-4-1000-03-F-1 Response to Disputed Non-Cited Violation 02/09/2023 UG-OLL-Proc-01 Appendix 2 Business Critical Incident Report (EV 149975) 04/29/2022 Project Update - ReAct Replacement 04/19/2023 Urenco USA Organizational Chart April 2023 2021 1st Semi-Annual Trend Report 07/29/2021 2021 2nd Semi-Annual Trend Report 02/10/2022 2022 1st Semi-Annual Trend Report Rev. 1 2022 2nd Semi-Annual Trend Report 03/10/2023 Miscellaneous CAP Program Owners - Organizational Chart

12 Inspection Procedure Type Designation Description or Title Revision or Date Audit 2019 Independent Audit of the URENCO USA Employee Concerns Program 12/03/2019 EC-3-1000-01-F-1 Employee Concerns Program - Concern Disclosure Statement Revision 17 EG-3-2100-09-F-1 Nonconformance Identification and Proposed Disposition 10/14/2022 Employee Training Safety Conscious Work Environment 2023 Employee Training ReAct Reporter Training (reporting events and action tracking) 05/07/2021 Employee Training Performance Improvement Program Employee Training General Employee Training (GET)

LES-22-082-NRC Contested Violation - NCV 07003103/2022001-01 06/13/2022 NRC Form 361A EN 55861 (EV 149688 & EV 149975) 02/28/2022 QAPD Quality Assurance Program Document Rev. 44 SA-3-1000-01-F-2 Near Miss Report (for EV 149688) 08/31/2022 SAR Safety Analysis Report Rev. 50 CA-3-1000-01 Performance Improvement Program Rev. 51 CA-3-1000-02 Apparent Cause Evaluation Guidelines Rev. 12 CA-3-1000-06 Event Review Board Revision 21 CA-3-1000-09 Assessment Program Revision 17 EC-1-1000-01 Safety Conscious Work Environment Policy Statement Rev. 4 EC-3-1000-01 Employee Concerns Program Rev. 17 Procedures WC-3-1000-02 Work Package Initiation and Closure Rev. 43 Radiation Surveys RP-3-2000-04-F-1 Radiological Survey 08/04/2016 UUSA Safety Culture Assessment with 2014 - 2022 Comparisons 10/13/2022 2022-A-05-010 Report for UUSA Louisiana Energy Services, LLC, Performance Assessment and Feedback, NQA-1 Audit 05/31/2022 Self-Assessments SA-2021-020 Employee Concerns Program Self-Assessment 11/08-30/2021

13 Inspection Procedure Type Designation Description or Title Revision or Date SA-2023-011 Corrective Action Program Self-Assessment 02/03/2023