ML24110A043

Global Nuclear Fuel - Americas - Core Inspection Report 07001113/2024001

ML24110A043
Person / Time
Site:	07001113
Issue date:	04/23/2024
From:	Robert Williams NRC/RGN-II/DFFI/FFB1
To:	Huth R Global Nuclear Fuel
References
IR 2024001
Download: ML24110A043 (23)

Text

Ryan Huth Facility Manager Global Nuclear Fuel - Americas, LLC P.O. Box 780, Mail Code J20 Wilmington, NC 28402

SUBJECT:

GLOBAL NUCLEAR FUEL - AMERICAS - CORE INSPECTION REPORT 07001113/2024001

Dear Ryan Huth:

On March 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Global Nuclear Fuels - America and discussed the results of this inspection with Ryan Huth 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 E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07001113 License No. SNM-1097

Enclosure:

As stated cc w/ encl: Distribution via LISTSERVApril 23, 2024 Signed by Williams, Robert on 04/23/24

ML24110A043 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available

OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI

NAME L. Cooke J. Raudabaugh T. Sippel P. Startz R. Williams DATE 4/23/2024 4/22/2024 4/22/2024 4/22/2024 4/23/2024 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Number: 07001113

License Number: SNM-1097

Report Number: 07001113/2024001

Licensee: Global Nuclear Fuel - Americas, LLC

Facility: Global Nuclear Fuels - America

Location: Wilmington, NC

Inspection Dates: February 05, 2024 to March 15, 2024

Inspectors: L. Cooke, Fuel Facility Inspector J. Raudabaugh, Fuel Facility Inspector T. Sippel, Sr. Fuel Facility Project Inspector P. Startz, Fuel Facilities Inspector

Approved By: Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a core inspection at Global Nuclear Fuels - America, 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 WER 07001113/2022-005-00 10 CFR 71.95 - 60 Day 86740 Open Report - NPC Certificate Condition of Approval Not Observed WER 07001113/2024-001-00 60 Day Report - RAJ-II 86740 Open Certificate Condition of Approval Not Observed

2 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

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, Part 70 (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 3.3.3, 5.1.1, 5.3.1, 5.4.2, 5.4.4, 5.4.5.5 and 5.4.5.6. Specifically, the inspectors interviewed licensee staff and reviewed the following CSAs:

• CSA 208.00.100, "DCP MRA Facility and Powder Containers," Revision (Rev.) 4, including the review of accident sequences 2080.4, 2080.9, and 2080.10, which cover various upset scenarios related to criticality safety in the dry conversion process (DCP) such as improper movement of a container into/out of a moderator restricted area (MRA) and moderator leaks onto containers, and reviewing the basis for why the licensee screened certain accident sequences as not credible (e.g., 2081.1, 2081.2).

• CSA 401.00.100, "Pellet Press Processing," Rev. 4, which was reviewed because a qualifying NCS engineer had recently revised it to change certain model assumptions, controls and accident sequences (e.g., 4040.11) primarily related to upsets involving beaker carts.

• CSA 603.00.100, "Bundle Processing (Inspection Pit, Inner Pack, Outer Pack)," Rev. 2, which was reviewed because it contained a variety of calculations and information supporting the licensee's evaluation of criticality accidents in the inspection pit and for loading RAJ-II inner containers.

• CSA 806.00.100, "Shipping Warehouse," Rev. 4, including the review of accident sequences 8060.1, 8060.2, 8060.3, 8060.4, 8060.5, 8060.8, and 8060.16, which cover various upset scenarios related to criticality safety such as over massing drums, moderator instruction, and spacing upsets, and

3 reviewing the basis for why the licensee screened certain accident sequences as not credible.

• QRA-208, "DCP - Miscellaneous," Rev. 9, which was reviewed because it contained a variety of information supporting the licensee's evaluation of accident sequences and items relied on for safety (IROFS) in CSA 208.00.100.

• QRA-601, "Fabrication - Bundle Assembly," Rev. 18, which was reviewed because it contained a variety of information supporting the licensee's evaluation of criticality, accident sequences and IROFS in CSA 603.00.100 and CSA 806.00.100.

• The inspectors compared the upper subcritical limits (USLs) for the areas of applicability used in selected calculations from the above CSAs against those in the current validation report to verify that the licensee was using the correct USL.

Criticality Implementation (IP Section 02.02)

The inspectors selected engineered and administrative controls from the licensees integrated safety analysis summary to verify proper implementation through a review of process and system descriptions, document review, plant walkdowns, and operator interviews to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors interviewed licensee staff and reviewed the following controls, and selected management measures, associated with the CSAs listed above:

• IROFS 208-01, "Process Equipment Barrier - DCP Container," a passive engineered control (PEC) preventing moderator intrusion, through walkdowns and review of training document (TD) 208-01, Rev. 2

• IROFS 208-02, "DCP Container Inspection & Cleanout," an administrative control on mass and moderator, through review of TD 208-02, Rev. 2

• IROFS 208-03, "DCP Container Verification & Tracking," an augmented administrative control on mass and moderator, through review of TD 208-03, Rev. 2

• IROFS 208-04, "Transfer Corridor Container Control," an administrative control on moderator, through review of TD 208-04, Rev. 1

• IROFS 900-03, "GNF-A Facility MRA," an administrative control on moderator (with passive engineered components), through walkdowns in MRAs

• performed walkdowns in the Shipping Warehouse, observed storage of RAJ-IIs, and NPCs, including the implementation of stacking and spacing

• performed walkdown in the MRA and observed the storage of containers of uranic material, the storage of bottles of contaminated oil, the storage of additives, the posting on the additive room door, steam lines and steam condensate lines, and container barriers

• performed a walkdown of the steam boilers and condensate receiver tank (located outside the MRA) that supports operations within the MRA

• performed walkdowns in Bundle Processing, including observing bundles in the inspection pit and the loading of a RAJ-II inner container

4 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. Specifically, the inspectors performed the following activities:

• reviewed the training material for "Radiation Worker Training - Criticality Safety" to verify that operators were trained on the hazards of NCS accidents and on NCS controls, including controls on moderator

• reviewed recent IROFS surveillances conducted by NCS licensee engineers, and the schedule for IROFS surveillances in 2024

• reviewed recent NCS audit reports and the 2024 audit schedule

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 2.2.1.6, 5.2.2 and 5.3.2.1. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:

• qualification and training records for a recently qualified senior NCS engineer

• the CSA 401.00.100 revision authored by a qualifying NCS engineer to verify that it was co-authored and peer reviewed by qualified senior NCS engineers

• the most recent revision to licensee procedure WI-18-104-02, "Internal Nuclear Safety Audits," Rev. 6

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 1.3.11, 5.3.2.5 and 5.3.2.6. Specifically, the inspectors reviewed documents, and/or interviewed licensee staff concerning the following:

• "CAAS Detector Trip Test 2 Out Of 3 Functionality Log," and portions of the "Detector Functionality Test Log"

• training material provided to operators to verify that personnel were trained to recognize and respond to a CAAS alarm

• recent NCS evacuation drill records and performance for 2023

• the NCS-related CAP entries listed in the Documents Reviewed section below, these include entries created as a result of licensee NCS walkdowns, and those resulting from CAAS evacuation drills

• NCS 900.06.100, "CAAS Detector Placement Analysis," Rev. 3 to verify that the CAAS detector placement calculations included consideration of criticality accidents at 8 wt.%, and the inspectors walked down locations of possible criticality accident and detectors

5 RADIOLOGICAL CONTROLS 86740 - Inspection of Transportation Activities

The inspectors evaluated select aspects of the licensees Transportation Activities program to determine whether the licensee has established and is maintaining an effective, management-controlled program; to ensure radiological and nuclear safety in the receipt, packaging, delivery to a carrier and, as applicable, the private carriage of licensed radioactive materials; and to determine whether transportation activities are in compliance with 10 CFR 20 and 71 and Department of Transportation (DOT) (49 CFR Parts 171-178) transport regulations.

Preparation of Packages for Shipment (IP Section 02.01)

The inspectors examined samples of the licensees procedures and observed actual package preparations and operations to verify compliance with the regulations above.

Specifically, the inspectors reviewed the following:

• Operating Procedure (OP) 2000.10, "Shipment of UF6 Material & Containers,"

Rev. 20

• OP 2000.03, "RA Inner Container Refurbishing," Rev. 41

• OP 2000.04.201, "Fuel Bundles in RAJ-II Containers - Shipping Documents,"

Rev. 3

• OP 2000.05.300, "Fuel Bundles in RAJ-II Containers - Process Information,"

Rev. 4

• OP 1339.01.205, "NPC Powder Pack - Basic Operator Maintenance," Rev. 4

• shipping package markings and labeling of six UF6 30-B Cylinders with UX-30 overpacks

Delivery of Completed Packages to Carriers (IP Section 02.02)

The inspectors examined the licensees procedures and shipment records and observed actual transport operations/activities to determine that the licensee met package delivery requirements. Specifically, the inspectors reviewed or observed the following:

• manifest R2400213 shipment preparations of 30-B cylinders within UX-30 overpacks

• nuclear material transaction form 741 for Manifests R2400213, 0998-03-0002, 0998-02-0016, and 0998-03-0001

• OP 2000.04 "Final Shipment Release" OUTGOING TRAILER SURVEY form for Manifest R2400213

• final pre-shipment radioactivity survey results, 0.5 mrem maximum, for manifest R2400213

• bill of lading for manifest R2400231

• custody control documentation

• radiological surveys, final drive-by

• bill of lading documentation

• transport trailers transferred to the carrier properly placarded, final step prior to pickup

• material control and accountability transfer documentation

• certificate of disposal for manifest 0988-03-0001

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• samples of shipping procedures: OP 2000.01, OP 2000.10, OP 2000.04.201, and OP 2000.05.002

Receipt of Packages (IP Section 02.03)

The inspectors examined the licensees procedures and records of incoming shipments to verify compliance with 10 CFR 20.1906 and applicable license requirements. Specifically, the inspectors reviewed the following:

• OP 1080.70.101, "UF6 Cylinder Dock - MC&A," Rev. 5

• OP 1088.70.201, "UF6 Cylinder Dock - Normal Operations," Rev. 22

• OP 1088.70.202, "UF6 Cylinder Dock - Abnormal Operations," Rev. 4

• OP 1088.70.203, "UF6 Cylinder Dock - Emergency Operations," Rev. 0

• OP 1088.70.204, "UF6 Cylinder Dock - Basic Operator Maintenance," Rev. 4

Records and Reports (IP Section 02.04)

The inspectors examined the licensees procedure for recordkeeping and reports to verify compliance with applicable federal regulations. Specifically, the inspectors reviewed the following:

• safety analysis reports for the various types of packages utilized by the licensee

• shipping manifests

• bills of lading

• radiation surveys

• contamination surveys

• control of custody forms

General License Requirements (IP Section 02.05)

The inspectors reviewed Certificates of Compliance (COC) utilized for shipment of radioactive material packages to verify compliance with 10 CFR 71, Subpart C. Specifically, the inspectors reviewed the following:

• NRC COC 9294, Rev. 9

• DOT Competent Authority certification for a type A fissile radioactive materials package design certificate USA/9294/AF-96, Rev. 11

• NRC COC 9196, Rev. 31

• 9196 for UX-30 packages

• 9294 for NPC packages

• 9309 for RAJ-II packages

• 9362 for DN30 packages

Management Controls (IP Section 02.06)

The inspectors reviewed the system of management controls for transportation activities to verify compliance with licensee instructions and procedures. Specifically, the inspectors reviewed:

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• written delegation of authority for the shipping and traffic team

• shipment records for authorization signatures from authorized management

Indoctrination and Training Program (IP Section 02.07)

The inspectors conducted interviews and reviewed training for workers involved in transportation activities to verify compliance with Chapter 11 of the license application. Specifically, the inspectors:

• reviewed transportation HAZMAT training certifications for shipping staff

• observed training of recently onboarded employee

• interviewed mixed waste shipping contractor

Quality Assurance Program (IP Section 02.08)

The inspectors reviewed the quality assurance documents to verify compliance with the licensees quality assurance program. Specifically, the inspectors reviewed:

• NEDO-11209-A, "GE Hitachi Nuclear Energy Quality Assurance Program Description," Rev 17, dated December 8, 2022

• quality assurance records procedure (CP-17-101)

Audit Program (IP Section 02.09)

The inspectors reviewed the latest audits to verify compliance with 10 CFR 71.137. Specifically, the inspectors reviewed:

• most recent internal audit of logistics department (NQA-2022-08)

• condition reports associated with audit findings and observations

• EHS-2023-01, "Radiation Protection Program Self Assessment Final Report 12/11 - 15/2023." along with condition reports generated from observations regarding shipping related surveys

Procurement and Selection of Packagings (IP Section 02.10)

The inspectors examined the licensees packaging refurbishment and repair procedures documentation, drawings, and records to verify compliance with the federal packaging records and regulations above. Specifically, for packaging that is used by the licensee to transport or to deliver licensed material to a carrier for transport, the inspectors reviewed the following:

• Drawing 105E3746, "Inner Container Parts Assembly Licensing Drawing," Rev 4, to supplement physical inspection

• Drawing 177D4970, Revision 1, "GNF New Powder Container (NPC)

Packaging", OAC Assembly

• Drawing 177D4970, Revision 1, "GNF New Powder Container (NPC)

Packaging", Inner Containment Canister Assembly

• Drawing SK105E4037, "Poly Bottle," Rev. 1

• periodic NPC Inner Containment Canister Assembly

8 Preparation of Packages for Shipment (IP Section 02.11)

The inspectors examined the licensees package markings, documentation, and records to verify compliance with applicable parts of the federal regulations above. Specifically, the inspectors reviewed:

• RAJ-II fuel assembly outer package refurbishment bay including spare parts, procedures, and calibrated tooling

• preparations of an RAJ-II Inner Container fuel assembly package including cross brackets and bolt kit to receive new fuel assemblies

• shipping package requirements for markings/manifesting/documenting of metal disposal boxes per Temporary Operating Procedure 50303, "Preparation and shipment of Non-Combustible Waste Boxes," Rev. 1

• 5 working days shipment notification for manifests 0998-02-0017, 0998 0002, 0998-02-0016, and 0998-03-0001

Periodic Maintenance of Packagings (IP Section 02.12)

The inspectors examined the licensees procedures and observed activities in the field to verify compliance with applicable parts of the federal regulations. Specifically, the inspectors:

• observed refurbishment activities to the inner and outer containers of the RAJ-II containers along with the new bolt kit, that allows accountability for the numbers of bolts for each container

• observed the internal arrangements of both the external box and internal box of selected RAJ-II packages to verify that cushioning, linings, braces, bolts, and other stabilizing components were in the proper arrangement and were not damaged in accordance with the procedure

Records, Reports, and Notifications (IP Section 02.13)

The inspectors reviewed the licensees records and procedures for recordkeeping and reports to verify that a system is in place to verify compliance with the federal regulations above. Additionally, the inspectors followed-up on two written event reports (WERs). Specifically, the inspectors reviewed the following:

• documents revised and actions taken in response to WER 07001113/2022-005, "10 CFR 71.95 - 60 Day Report-NPC Certificate Condition of Approval Not Observed" (see Inspection Results section for more detail)

• documents revised and actions taken in response to WER 07001113/2024-001, "10 CFR 71.95 - 60 Day Report-RAJ-II Certificate Condition of Approval Not Observed" (see Inspection Results section for more detail)

• OP 2000.04.300 procedure shipping record retention

• memo of shipment for two RAJ-II shipments from 2021

9 88030 - Radiation Protection

The inspectors evaluated selected aspects of the licensees radiation protection (RP) program to verify compliance with 10 CFR 19, 20, and 70, Chapter 4 Radiation Protection of the facilitys license application, and applicable licensee procedures.

Radiation Protection Program Review (IP Sections 02.01, 02.02, 02.03, 02.23)

The inspectors interviewed licensee staff and reviewed licensee procedures and other documentation related to the implementation of the RP and radioactive waste programs and as low as reasonably achievable (ALARA) programs to verify compliance with 10 CFR 20.1101(a), 20.1101(b), 20.1101(c), 20.2102, 70.72, and the license application.

Specifically, the inspectors reviewed documents, interviewed licensee staff and/or conducted walkdowns of the following:

Radiation Protection Program Implementation and Procedures (IP Section 02.01 &

02.03)

• completed production area walkdowns to verify that components of the airborne radioactivity measurement and control system were functional in accordance with licensee procedure WI-27-105-07

• accompanied RP technician to verify breathing-zone "SAS" air samplers were functioning in accordance with operational criteria and that the air sampler filters were being changed out in accordance with daily schedules, in accordance with licensee procedure WI-27-105-07

• accompanied RP technician calibrating a Tennelec radiation counter to verify compliance with licensee procedure WI-27-105-09

Radiation Program Review and ALARA (IP Section 02.02 & 02.23)

• reviewed 2022 Annual ALARA Review-FMO, WFSC, and SCO units

• license audit: FMO Ceramics Area Radiation Safety Audit (NSE-2023-1227),

12/27/23, reviewed procedures and conducted walkdowns, 1 finding, 2 CR's

• license audit: FMO Ceramics Area, Radiation Safety Audit (NSE-2023-1108),

11/29/23, 3 findings, 5 CR's

• license audit: FMO Dry Conversion Process, Radiation Safety Audit (NSE-2023-1129), 11/29/23, 1 finding, 4 CR's

• license audit: Support Areas, Radiation Safety Audit (NSE-2023-1222),

1/30/24, 2 findings, 3 CR's

• training course on the new Ludlum 3030 Alpha Beta Sample Counter and corresponding Computer Software, and reviewed first shift calibration and normal in-process operations within the RP laboratory

• reviewed radiological waste packaging operations to verify compliance with OP 1080.20.000 "Decon Facility"

Training (IP Section 02.04)

The inspectors interviewed licensee staff and reviewed RP and radioactive waste related training records to verify compliance with 10 CFR 19.12, 19.13, 70.61(f)(2), and the license application. Specifically, the inspectors reviewed training records and documents, and interviewed licensee staff as follows:

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• reviewed RP retraining course on the new Ludlum 3030 Alpha Beta Sample Counter and corresponding Computer Software, and reviewed first shift calibration and normal in-process operations within the RP laboratory

• reviewed 2024Q1 FMO RP continuing training activities

• reviewed APEX AB QC Control Charts training, 2024, regarding the APEX In-Vivo Lung Counter with the new detectors

Safety-Significant Events (IP Section 02.05)

The inspectors reviewed the licensees review of safety-significant events, RP, and radioactive waste related CAP entries to verify compliance with 10 CFR 20.2201, 20.2202, 20.2203, 70.50, 70.52, 70.74, and Part 70 Appendix A and Chapters 4 and 11 of the license application. Specifically, the inspectors reviewed documents and interviewed licensee staff concerning the following:

• Condition Reports (CR) 45316, performing pre-annual shutdown HVAC ventilation inspection for uranium buildup, discovered holdup on 3/10/24 within component 2129ST4, removed 1.4 kg of holdup using safe vacuum cleaner

• CR 44710, Replace Radiological Postings

• additional CR's 42951, 41381, 43803, and 44359

Radiation Exposure Controls (IP Sections 02.06, 02.18)

The inspectors reviewed licensee's measures such as radiological work permits to control the concentration of radioactive material in air or limiting intake to keep doses ALARA to verify compliance with 10 CFR 20.1101(b), 20.1701, 20.1702, and license application chapter 4. Specifically, the inspectors interviewed licensee staff, observed activities, and/or reviewed records related to the following:

• observed activities conducted by a contractor under Radiation Work Permit (RWP) 6298 "Uranium Recovery Unit"

• reviewed Temporary Operating Procedure 50631 "Cleanout of U-Material Accumulation with Vacuum Cleaner", Revision 0

• observed vacuuming of contaminated material on FMO Roof with GM-80CR under RWP 6301

• observed activities being conducted under RWP 6274, General RWP for Controlled Access Areas

• reviewed RWP 6281 for NRC inspectors

• observed an FMO worker undergoing respirator training and two fit tests to verify compliance with procedure E-02 "Respiratory Protection", Revision 12; and WI-27-105-16, "Respiratory Protection Program", Revision 10

• reviewed Lung-Wholebody [radiation] In-vivo Counter Quality Assurance Control Charts after the lung detectors were replaced with newer technology detectors, completed 10/26/23

Instrument Calibration and Surveys (IP Sections 02.07, 02.08, 02.14, 02.15)

The inspectors reviewed licensees procedures and documentation for RP instrument calibration, radiation surveys, contamination control measures; use of radiation detecting instruments and equipment and interviewed licensee staff to verify compliance with 10 CFR

11 20.1501, 20.1902, 20.2103, 70.24, and Chapter 4 of the license application. Specifically, the inspectors observed activities, reviewed documents, and/or interviewed licensee staff concerning the following:

Instrument and Equipment/Calibration (IP Sections 02.07 & 02.08)

• Ludlum 4525 14000 Truck Portal Weekly Response Check

• calibration records for the following:

o Ludlum model 2000 (alpha), Ludlum model 3 with pancake probe (alpha/beta), teletector probe (gamma), Eberline RM 14 (beta gamma),

Ludlum model 177 (alpha) o Argos personnel contamination monitors o Tennelec

• WI-27-105-14, Calibration and Operation of the Personnel Contamination Monitors

• WI-27-105-09, Tennelec Calibration and Operation

Radiation Surveys & Contamination Control (IP Sections 02.14 & 02.15)

• survey of incoming uranium hexafluoride (UF6) Cylinders

• survey of outgoing NPC packages

• reviewed weekly and monthly contamination survey records

• observed weekly contamination survey of the Gad Shop

• WI-27-105-19, Routine Surveys

Postings and Labeling (IP Sections 02.09, 02.10, 02.16)

The inspectors observed the posting and labeling of radiation areas, radioactive material storage areas, radioactive containers, and control of licensed sealed sources to verify compliance with 10 CFR 20.1902, 20.1903, 20.1904, 20.1905, and Chapters 1 and 4 of the license application. Specifically, the inspectors observed the following area posting and reviewed the following records:

Posting/ Container Labeling (IP Sections 02.09 & 02.10)

• Caution - Radiation Area posting in controlled access areas

• Every container in this area may contain radioactive materials posted in controlled access areas

• Respiratory protection required posted in areas with airborne radioactivity concerns

• WI-27-105-01, Posting and Control of Radiological Areas

Sealed Sources (IP Section 02.16)

• observed storage of sealed sources

• reviewed leak test records and sealed source inventory records

• WI-27-105-04, Radioactive State Licensed Sources and Standards

Posting of Notices (IP Section 02.11)

The inspectors observed the posting of notices to verify compliance with 10 CFR 19.11. Specifically, the inspectors observed the following notice:

• NRC Form 3 posted in the plant entrance turnstiles bulletin boards

12 Access Control (IP Section 02.12)

The inspectors observed the licensees access control measures for radiation areas to verify compliance to 10 CFR 20.1502(a)(4), 20.1601, 20.1602, and Chapter 4 of the license application. Specifically, the inspectors observed controls, reviewed documents, and/or interviewed licensee staff concerning the following:

• observed badge reader and turnstile for accessing radiation areas

• observed badge reader for PCM used prior to exiting radiation area

• observed logging time in area

• CP-27-105, Radiation Protection Program

Licensed Material Control (IP Section 02.13)

The inspectors observed the licensees measures to secure stored material and control and maintain constant surveillance of licensed material not in storage to verify compliance with 10 CFR 20.1801, 20.1802, and Chapter 4 of the license application. Specifically, the inspectors reviewed the following:

• storage of sealed sources in the RP office

• Radiation Source Usage Log

• storage of high level sources in a separate area

Dose Assessment Program (IP Sections 02.17, 02.22)

The inspectors interviewed licensee staff and reviewed records and calculations related to the licenses assessment and assignment of doses to workers to verify compliance with 10 CFR 20.1201, 20.1204, 20.1207, 20.1208, 20.1502(b), 20.2104, 20.2106 and the license application. Specifically, the inspectors interviewed licensee staff and/or reviewed records related to the following:

• reviewed 2022 workforce dose assessments, final "NRC Form 5", values were in compliance

• reviewed Oak Ridge Institute Radiation Exposure Information and Reporting System (REIRS), "Data Verification" for 2022 monitoring year, memo dated 4/27/2023, values were in compliance

• discussed practices, policies, and dose assessments regarding pregnant employees

• reviewed internal dose reports, employee Lung Count Analysis reports, Apex-InVivo results, for employee 36376, completed 12/8/2023

• reviewed internal dose reports, employee Lung Count Analysis reports, Apex-InVivo results, for employee 34983, completed12/7/2023

• reviewed Airborne Exposure History report for employee 35256, assessment range for all of 2023

• reviewed Airborne Exposure History report for employee 34983, assessment range 2nd quarter 2023

• reviewed Airborne Exposure History report for employee 34371, assessment range for all of 2023

13 Dosimetry Program (IP Sections 02.19, 02.20, 02.21)

The inspectors interviewed licensee staff and reviewed the implementation and documentation of the internal and external dosimetry programs including bioassay, whole body counting, and use of dosimetry in the field to verify compliance with 10 CFR 20.1502(a), 20.1502(b), 10 CFR 20.2103(b)(3), and the license application. Specifically, inspectors interviewed licensee staff and/or reviewed records related to the following:

Bioassay Program & Whole Body Counting (IP Section 02.19 & 02.20)

• uranalysis preparation and mass spectrometry analysis calibration activities and results processing for 11 urine samples submitted 3/13/24

• RP staff notification for uranalysis results exceeding the action level of 15 ug/L

• mass spectrometry calibration / urine analysis quality control protocols for utilizing sample spikes in accordance with procedure CO1-1013, "Chemet Laboratory Calibration & Operation Instruments"

• LIMS functionality from receipt of bioassay sample receipt through mass spectrometry results data management protocols

• monitored a "Whole Body [radioactivity measurement] Count" conducted on an employee to verify compliance with procedure WI-27-05-36, "Lung and Whole Body Counter Operation and Calibration", Revision 1

• reviewed the replacement detectors

Dosimetry (IP Section 02.21)

• verified National Voluntary Laboratory Accreditation Program (NVLAP) accreditation for the licensee's dosimetry contractor, Marion Technologies Inc, certificate ISO/IEC 17025:2017, applicable 10/2-2023 to 6/30/2024

• reviewed dosimetry used including badge-type thermoluminescent dosimeter (TLD), finger-type TLDs, and electronic dosimeters for visitors and special activities

• dosimetry periodicity from semiannual, quarterly for higher dose rates, monthly for DPWs, and electronic dosimeters for visitors and workers approaching 0.75 rem annual

• current ongoing "extremity exposure study" for higher dose workers who handle uranium product, using finger-type dosimeters, and will conclude in 2024

• respiratory protection fit testing to verify compliance with licensee procedure WI-27-105-16

INSPECTION RESULTS

WER 10 CFR 71.95 - 60 Day Report - NPC Certificate Condition 86740 (Discussed) of Approval Not Observed WER 07001113/2022-005-00

Description:

On October 17, 2022, a customer site notified the licensee that it discovered a ratcheting wrench improperly placed on the outer containment assembly gasket of an NPC shipment made by licensee. This shipment (serial number N-0033) contained low enriched uranium oxide powder. There were no incidents or accident conditions during the use of the affected package and no components or systems of the package failed. The licensee opened CR 2022-40767 to track and remedy the cause of this event. The report (ADAMS Accession

14 Number: ML22342A380) was made in accordance with 10 CFR 71.95 and submitted to the NRC December 8, 2022.

Inspectors performed a visual inspection of NPC package loading operations, confirmed implementation of a new tool checklist verification LS1339.19 (NPC Tool Board Checklist),

and confirmed revision of procedure OP 1339.01.202, "NPC Powder Pack", Revision 15, to include additional inspections/form references.

This WER will remain open pending further NRC inspection from transportation inspectors.

WER 60 Day Report - RAJ-II Certificate Condition of Approval 86740 (Discussed) Not Observed WER 07001113/2024-001-00

Description:

On November 5, 2023, the licensee shipped RAJ-II inner container (IC) serial number RB-2180, containing unirradiated fuel assemblies to a customer without all the required 10 IC top lid bolts being installed and tightened. The customer notified the licensee upon receipt of shipment that two IC top lid bolts were not installed. There were no incidents or accident conditions during the use of the affected package and no components or systems of the package failed. The licensee opened CR 2023-44166 to track and remedy the cause of the event. This report (ADAMS Accession Number: ML24005A241) was made in accordance with 10 CFR 71.95 and submitted to the NRC January 5, 2024.

Inspectors performed a visual inspection of an inner RAJ-II package loading operation to verify a new Bolt-Kit inventory-crosscheck of the number of bolts was included in revised operating procedure OP 1050.70.202, "Fuel Bundle Packing - Packing Channeled Fuel Bundles", Revision 18. The new revision ensures the new Bolt-Kit system provides a bolt count accountability to allow a counter check of what was installed. Additionally, inspectors reviewed operating procedure OP 1050.70.205, "Fuel Bundle Packing - Packing Outer Containers", Revision 15, which includes added bolt number counts.

This WER will remain open pending further NRC inspection from transportation inspectors.

EXIT MEETINGS AND DEBRIEFS

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

• On February 8, 2024, the inspectors presented the nuclear criticality safety and transportation activities inspection results to Ryan Huth and other members of the licensee staff.

• On March 14, 2024, the inspectors presented the radiation protection inspection results to Ryan Huth and other members of the licensee staff.

15 DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 86740 Corrective Action CR44531 Shipping related condition reports Documents CR44538 CR 41283 CR 39049 CR40678 CR40078 CR40933 Miscellaneous Sourcing Logistics Org Chart 01/11/2024 NEDO-11209-A Quality Assurance Program Description Rev. 17 Procedures CP-17-101 Product Quality Assurance Records Rev. 12 OP 1080.70.100 UF6 Cylinder Dock - General Information Rev. 5a OP 1080.70.201 UF6 Cylinder Dock - Normal Operations Rev. 22 OP 1080.70.202 UF6 Cylinder Dock - Abnormal Operations Rev. 4 OP 1080.70.203 UF6 Cylinder Dock - Emergency Operations Rev. 0 OP 1080.70.204 UF6 Cylinder Dock - Basic Operator Maintenance Rev. 4 OP 1080.70.300 UF6 Cylinder Dock - Process Information Rev. 11 OP 1339.01.100 NPC Powder Pack - General Information Rev. 6 OP 1339.01.101 NPC Powder Pack - MC&A Rev. 1 OP 1339.01.201 NPC Powder Pack - Startup Rev. 3 OP 1339.01.202 NPC Powder Pack - Normal Operations Rev. 15 OP 1339.01.204 NPC Powder Pack - Abnormal Operations Rev. 5 OP 1339.01.205 NPC Powder Pack - Basic Operator Maintenance Rev. 4 OP 1339.01.300 NPC Powder Pack - Process Information Rev.1 OP 2000.01.100 Shipment of NPC - General Information Rev. 2 OP 2000.01.201 Shipment of NPC - Shipping Documentation Rev. 1 OP 2000.01.201 Shipment of NPC - Shipping Documentation Rev. 1 OP 2000.01.202 Shipment of NPCs - Shipping Operations Rev. 1 OP 2000.02 RAJ-II Outer Container Refurbishing Rev. 42 OP 2000.03 RAJ-II Inner Container Refurbishing Rev. 41 OP 2000.04.100 Shipping & Traffic - General Information Rev. 4 OP 2000.04.201 Shipping & Traffic - Shipping Operations Rev. 5 OP 2000.04.202 Shipping & Traffic - Receiving Operations Rev. 3

16 Inspection Type Designation Description or Title Revision or Procedure Date OP 2000.04.300 Shipping & Traffic - Shipping Documents Rev. 5 OP 2000.05.100 Fuel in RAJ-II Containers - General Information Rev. 4 OP 2000.05.201 Fuel in RAJ-II Containers - Shipping Documentation Rev. 3 OP 2000.05.202 Fuel in RAJ-II Containers - Loading and Securing Rev. 9 OP 2000.05.300 Fuel in RAJ-II Containers - Process Information Rev. 4 OP 2000.10 Shipment of UF6 Material & Containers Rev. 20 OP-1339.01.203 NPC Powder Pack - Cleanout Rev. 1 WI-27-105-06 Use of Portable Smear Counters Rev. 5 WI-27-105-08 Contamination Measurement and Control Rev. 6 WI-27-105-20 Radioactive Shipment Surveys Rev. 10 WI-27-105-20 Radioactive Shipment Surveys Working Instruction Rev. 10 Self-Assessments EHS-2023-1 FMO Radiation Protection Program Self-Assessment 12/15/2023 NQA-2022-08 Internal Shipping Audit 11/21/2022 Shipping Records MS 33419368 Delivery to Shipping and Memo of Shipment 06/01/2021 MS 33419707 Delivery to Shipping and Memo of Shipment 09/14/2021 88015 Corrective Action CR 44403, CR NCS-related corrective action program entries Various Documents 44534, CR 43537, CR 43538, CR 43540, CR 43541, CR 43542, CR 43545, CR 43546, CR 43547, CR 43548, CR 44588, CR 44753, CR 44973 Engineering CSA 208.00.100 DCP MRA Facility and Powder Containers Rev. 4 Evaluations CSA 401.00.100 Pellet Press Processing Rev. 4 CSA 603.00.100 Bundle Processing (Inspection Pit, Inner Pack, Outer Pack) Rev. 2 CSA 806.00.100 Shipping Warehouse Rev. 4 NSA 900.06.100 CAAS Detector Placement Analysis Rev. 3 QRA-208 DCP - Miscellaneous Rev. 9

17 Inspection Type Designation Description or Title Revision or Procedure Date QRA-601 Fabrication - Bundle Assembly Rev. 18 Miscellaneous EHS Compliance Auditor Certification Completed 11/13/2023 2023 Building Evacuation Drills, Drill Dates: October 25 and November 14, 2023 4Q2023 IED Qualification Drill - FMO CAAS Zone 1 Activation Drill Date: October 25, 2023 Lessons Learned FMO CAAS Zone 1 Activation and IED 12/28/2023 Qualification Drill October 25, 2023 Senior Nuclear Criticality Safety Engineer Qualification & Completed Training Card 11/13/2023 LS 2310.00.06 Detector Functionality Test Log 10/19/2023 LS 2310.00.07 Detector Trip Test 2 Out Of 3 Functionality Log 01/01/2024 NS-2023-111 GNF-A Senior Criticality Safety Engineer Qualification 11/14/2023 Radiation Worker Radiation Worker Training - Criticality Safety 06/2023 Training 2 TD 208-01 Process Equipment Barrier - DCP Container Rev. 2 TD 208-02 DCP Container Inspection & Cleanout Rev. 2 TD 208-03 DCP Container Verification & Tracking Rev. 2 TD 208-04 Transfer Corridor Container Control Rev. 1 NDE Reports QN-02140 E-GUN Qualification for Accounting Measurements of Rev. 1 Uranium in Incinerator Ash Material Operability IROFS Surveillance 208-01 01/31/2024 Evaluations IROFS Surveillance 204-04, 207-03, 207-09 01/31/2024 IROFS Surveillance 702-18, 702-22 09/30/2023 IROFS Surveillance 208-01 01/31/2022 IROFS Surveillance 208-01 01/31/2023 IROFS Surveillance 806-1, 806-02 12/31/2023 Procedures CP-20-314 CRITICALITY SAFETY ENGINEER TRAINING AND Rev. 1 QUALIFICATION Self-Assessments Q4 2023 NCS Audit - Container Storage / Handling, Scrap / 12/14/2023 Utility Hoods, Vacuum Operations

18 Inspection Type Designation Description or Title Revision or Procedure Date 4Q23 Nuclear Criticality Safety Audit - Nodes 401-404, 501-12/13/2023 503 3Q2023 NSE Audit - Process Nodes 207, 705, 806: Powder 09/08/2023 Pack/Receipt/SPF/Warehouse 2023Q4 Nuclear Safety Audit - 205A, 206A, 206: 12/15/2022 Homogenization, BPG & Tumble, powder containers and DCP miscellaneous 1Q24 Nuclear Safety Audit - Powder Pack, Powder Receipt, 01/19/2024 Scrap Pack, Shipping Operations 88030 Calibration Source 43049 Certificate of Calibration Beta Standard 12/11/2017 Records Source 96030 Certificate of Calibration Alpha Standard 10/19/2017 Corrective Action CR 44710 Replacing Radiological Postings 12/15/2023 Documents Corrective Action CR 45352 Radiological Posting not Meeting Expectations 03/12/2024 Documents CR 45381 NRC Observation Related to Respirator Storage 03/13/2024 Resulting from Inspection Miscellaneous Vehicle Monitor Response Form - Semi 02/13/2024 Vehicle Monitor Response Form - Flat Bed 02/13/2024 Vehicle Monitor Response Form - Semi 01/04/2024 WI-27-195 Radioactive Source Usage Log Rev. 1 F01 Operability Ludlum 4525 14000 Truck Portal Monitor Weekly Response 03/13/2024 Evaluations Check Procedures CP-27-105 Radiation Protection Program Rev. 8 OP 202.200.204 DCP Conversion - Normal Operations Rev. 3 OP 2301 FMO HVAC Maintenance Operation [HEPA filter Rev. 32 changes / exhaust systems / air balance / records]

RN-24 (Canberra) Routine Ops Procedure for the Canberra In-Vivo Counting Rev. 8 System at GNF-A WI-18-104-02 Internal Nuclear Safety Audits Rev. 6 WI-27-105-01 Posting and Control of Radiological Areas Rev. 5 WI-27-105-04 Radioactive State Licensed Sealed Sources and Standards Rev. 3 WI-27-105-05 Control of Radioactive Material Rev. 7

19 Inspection Type Designation Description or Title Revision or Procedure Date WI-27-105-07 Airborne Radioactivity Measurement and Control Rev. 7 WI-27-105-08 Contamination Measurement and Control Rev. 6 WI-27-105-09-G-Tennelec Calibration and Operation Guide for Fuel Rev. 1 01 Manufacturing Operations WI-27-105-10 Area and Environmental Dosimetry Monitoring Program Rev. 1 WI-27-105-14 Calibration and Operation of Personnel Contamination Rev. 5 Monitors WI-27-105-19 Routine Surveys Rev. 2 WI-27-105-20 Radiation Shipment Surveys Rev. 10 WI-27-105 Response to Vehicle Monitor Alarms Guide Rev. 0 G01 Radiation RP Monitor Routines - Dayshift 01/2024 to Surveys 03/2024 RP Monitor Routines - Monthly 01/2024 to 03/2024 Radioactive Sealed Source Leak Test Record 01/12/2023, 03/08/2023, 05/09/2023, 01/19/2024 Radioactive Sealed Source Inventory Form 01/12/23, 01/02/2024, 05/09/2023 Controlled Area Radiation Protection Monitor Routines: Day 01/2024 to

& Night 12-Hour Rotation 03/2024 Radiation Protection Monthly/Quarterly Routines 2024 01/2024 to 03/2024 SAS Concentration URU 12 Hour Areas 03/06/2024 to 03/14/2024 Map 276 Gad Shop East 1st Floor 03/13/2024 Map 277 Gad Shop 1st Floor West 03/13/2024 Map 344 HP Weld 03/13/2024 Map 404 Blend Feed 03/07/2024 Map 405 Recycle Feed 03/07/2024

20 Inspection Type Designation Description or Title Revision or Procedure Date Map 407 DCP HVAC 03/07/2024 Map 413 DSR Mezzanine 03/04/2024 Trailer 848504 GNFA Radiation Survey Report for Incoming UF6 Cylinders 03/06/2024

21