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{{#Wiki_filter:EN 56484 | {{#Wiki_filter:EN 56484 Wyatt Padgett Compliance Manager Louisiana Energy Services dba URENCO USA (UUSA) | ||
URENCO USA P.O. Box 1789 Eunice, NM 88231 | URENCO USA P.O. Box 1789 Eunice, NM 88231 | ||
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==Dear Wyatt Padgett:== | ==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. | 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. | 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. | 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, | Sincerely, Robert Mathis, III, Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07003103 License No. SNM-2010 | ||
==Enclosure:== | ==Enclosure:== | ||
As stated cc w/ encl: Distribution via LISTSERVJuly 14, 2023 Signed by Mathis, Robert on 07/14/23 | |||
ML23193B047 | |||
SUNSI Review X Non-Sensitive X Publicly Available X Sensitive Non-Publicly Available | |||
Facility: | |||
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 | |||
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 | |||
Enclosure | |||
==SUMMARY== | ==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. | |||
2 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) | Criticality Analysis (IP Section 02.01) | ||
The inspectors interviewed licensee staff and reviewed criticality safety analyses (CSAs), | 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: | 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," | 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 3 | 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 | ||
3 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: | 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) | |||
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: | 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) | |||
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: | 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: | ||
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) | 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 4 | ||
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: | 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. | |||
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) | 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. | 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: | Specifically, the inspectors performed the following activities: | ||
licensee processes, structures, and functions. 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 | ||
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) | |||
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 | |||
5 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: | 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: | ||
meetings, and reviewed condition reports/causal evaluations. 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 | ||
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) | |||
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 | |||
6 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: | 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) | |||
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: | 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: | 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 7 | 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 | ||
7 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 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. | On April 27, 2023, the inspectors presented the corrective action program inspection results to Karen Fili and other members of the licensee staff. | ||
DOCUMENTS REVIEWED Inspection Type | 8 DOCUMENTS REVIEWED | ||
NCS-CSA-026 | |||
ISA Summary | Inspection Type Designation Description or Title Revision or Procedure Date 88015 Corrective Action EV 159085, NCS-related CAs Various Documents 159022, 159752, 159632, 159559, 159551, 159529, 159065, 158476, 154070, 152997, 151946, 151497, 151142, 149782 Corrective Action EV 159996 Operator Training Record Not Readily Retrievable 04/05/2023 Documents Resulting from Inspection Engineering NCS-CSA-006 Criticality Safety Analysis of the Product Vent Pump and Rev. 10 Evaluations Chemical Trap Set NCS-CSA-015 Nuclear Criticality Safety Analysis of IROFS C22 PeriodicityRev. 12 NCS-CSA-016 Criticality Safety Analysis of 30B Cylinders Rev. 8 NCS-CSA-025 Criticality Safety Analysis of UUSA Process Gas Pipework Rev. 4 (All Assays) | ||
NCS-CSA-026 Nuclear Criticality Safety Analysis of Assay Units 1001 and Rev. 1 1002 Cascade Valve Frames Miscellaneous SNT-TC-1A ASME Recommended Practice 2006 2006 Procedures CR-3-1000-03 NCS Weekly Walkthroughs and Periodic Assessments Rev. 17 EG-3-2100-05-F-Commercial Grade Dedication Plan Rev. 2 and 3 2 | |||
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 - Rev. 12 RTD Surveillance MA-3-3400-02 IROFS2 Station Heater and Fan High Temperature Trip - TC Rev. 14 | |||
9 Inspection Type Designation Description or Title Revision or Procedure 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 Rev. 14 30B Cylinder NEF-BD-16e Administratively Limit Moderator Mass in a Heeled 30B Rev. 4 Cylinder NEF-BD-16f Administratively Limit Moderator Mass in a Heeled 30B Rev. 4 Cylinder 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 Work Orders WO 1000575639 MA-3-3400-01/02 IROFS 1 and 2 Station Heater and Fan 3/13/2023 High Temperature Trip - RTD and TC Surveillance WO 1000575645 MA-3-3400-01/02 IROFS 1 and 2 Station Heater and Fan 3/14/2023 High Temperature Trip - RTD and TC Surveillance WO 1000575680 MA-3-3400-01/02 IROFS 1 and 2 Station Heater and Fan 3/15/2023 High Temperature Trip - RTD and TC Surveillance WO 1000596717 MA-3-2000-01 PFPE Oil Sample 3/28/2023-3/29/2023 88161 Corrective Action EV 111023 Leak from #2 Slab Tank pump 03/03/2016 Documents 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 EV 144537 Adverse Trend 4/15/2021 | |||
Inspection Type | 10 Inspection Type Designation Description or Title Revision or Procedure 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 03/24/2022 LECTS RCA EV 151070 IROFS35 Rollup Door Issue 04/01/2022 EV 151086 Worker Not Trained in IROFS24C Crossed IROFS24C 04/04/2022 Barrier 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 Business Critical Incident Report (EV 149975) 04/29/2022 Appendix 2 Miscellaneous 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 CAP Program Owners - Organizational Chart | |||
Inspection Type | 11 Inspection Type Designation Description or Title Revision or Procedure Date Audit 2019 Independent Audit of the URENCO USA Employee 12/03/2019 Concerns Program EC-3-1000-01-F-Employee Concerns Program - Concern Disclosure Revision 17 1 Statement EG-3-2100-09-F-Nonconformance Identification and Proposed Disposition 10/14/2022 1 | ||
Employee Safety Conscious Work Environment 2023 Training Employee ReAct Reporter Training (reporting events and action 05/07/2021 Training tracking) | |||
Employee Performance Improvement Program Training Employee General Employee Training (GET) | |||
Training 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 Procedures 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 WC-3-1000-02 Work Package Initiation and Closure Rev. 43 Radiation RP-3-2000-04-F-Radiological Survey 08/04/2016 Surveys 1 Self-Assessments UUSA Safety Culture Assessment with 2014 - 2022 10/13/2022 Comparisons 2022-A-05-010 Report for UUSA Louisiana Energy Services, LLC, 05/31/2022 Performance Assessment and Feedback, NQA-1 Audit SA-2021-020 Employee Concerns Program Self-Assessment 11/08-30/2021 | |||
Inspection Type | 12 Inspection Type Designation Description or Title Revision or Procedure Date SA-2023-011 Corrective Action Program Self-Assessment 02/03/2023 | ||
13}} | |||
Revision as of 18:55, 13 November 2024
| 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 LISTSERVJuly 14, 2023 Signed by Mathis, Robert on 07/14/23
SUNSI Review X Non-Sensitive X Publicly Available X Sensitive 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
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
Enclosure
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.
2 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
3 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 4
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
5 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
6 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
7 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.
8 DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or Procedure Date 88015 Corrective Action EV 159085, NCS-related CAs Various Documents 159022, 159752, 159632, 159559, 159551, 159529, 159065, 158476, 154070, 152997, 151946, 151497, 151142, 149782 Corrective Action EV 159996 Operator Training Record Not Readily Retrievable 04/05/2023 Documents Resulting from Inspection Engineering NCS-CSA-006 Criticality Safety Analysis of the Product Vent Pump and Rev. 10 Evaluations Chemical Trap Set NCS-CSA-015 Nuclear Criticality Safety Analysis of IROFS C22 PeriodicityRev. 12 NCS-CSA-016 Criticality Safety Analysis of 30B Cylinders Rev. 8 NCS-CSA-025 Criticality Safety Analysis of UUSA Process Gas Pipework Rev. 4 (All Assays)
NCS-CSA-026 Nuclear Criticality Safety Analysis of Assay Units 1001 and Rev. 1 1002 Cascade Valve Frames Miscellaneous SNT-TC-1A ASME Recommended Practice 2006 2006 Procedures CR-3-1000-03 NCS Weekly Walkthroughs and Periodic Assessments Rev. 17 EG-3-2100-05-F-Commercial Grade Dedication Plan Rev. 2 and 3 2
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 - Rev. 12 RTD Surveillance MA-3-3400-02 IROFS2 Station Heater and Fan High Temperature Trip - TC Rev. 14
9 Inspection Type Designation Description or Title Revision or Procedure 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 Rev. 14 30B Cylinder NEF-BD-16e Administratively Limit Moderator Mass in a Heeled 30B Rev. 4 Cylinder NEF-BD-16f Administratively Limit Moderator Mass in a Heeled 30B Rev. 4 Cylinder 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 Work Orders WO 1000575639 MA-3-3400-01/02 IROFS 1 and 2 Station Heater and Fan 3/13/2023 High Temperature Trip - RTD and TC Surveillance WO 1000575645 MA-3-3400-01/02 IROFS 1 and 2 Station Heater and Fan 3/14/2023 High Temperature Trip - RTD and TC Surveillance WO 1000575680 MA-3-3400-01/02 IROFS 1 and 2 Station Heater and Fan 3/15/2023 High Temperature Trip - RTD and TC Surveillance WO 1000596717 MA-3-2000-01 PFPE Oil Sample 3/28/2023-3/29/2023 88161 Corrective Action EV 111023 Leak from #2 Slab Tank pump 03/03/2016 Documents 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 EV 144537 Adverse Trend 4/15/2021
10 Inspection Type Designation Description or Title Revision or Procedure 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 03/24/2022 LECTS RCA EV 151070 IROFS35 Rollup Door Issue 04/01/2022 EV 151086 Worker Not Trained in IROFS24C Crossed IROFS24C 04/04/2022 Barrier 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 Business Critical Incident Report (EV 149975) 04/29/2022 Appendix 2 Miscellaneous 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 CAP Program Owners - Organizational Chart
11 Inspection Type Designation Description or Title Revision or Procedure Date Audit 2019 Independent Audit of the URENCO USA Employee 12/03/2019 Concerns Program EC-3-1000-01-F-Employee Concerns Program - Concern Disclosure Revision 17 1 Statement EG-3-2100-09-F-Nonconformance Identification and Proposed Disposition 10/14/2022 1
Employee Safety Conscious Work Environment 2023 Training Employee ReAct Reporter Training (reporting events and action 05/07/2021 Training tracking)
Employee Performance Improvement Program Training Employee General Employee Training (GET)
Training 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 Procedures 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 WC-3-1000-02 Work Package Initiation and Closure Rev. 43 Radiation RP-3-2000-04-F-Radiological Survey 08/04/2016 Surveys 1 Self-Assessments UUSA Safety Culture Assessment with 2014 - 2022 10/13/2022 Comparisons 2022-A-05-010 Report for UUSA Louisiana Energy Services, LLC, 05/31/2022 Performance Assessment and Feedback, NQA-1 Audit SA-2021-020 Employee Concerns Program Self-Assessment 11/08-30/2021
12 Inspection Type Designation Description or Title Revision or Procedure Date SA-2023-011 Corrective Action Program Self-Assessment 02/03/2023
13