ML23117A018

Global Nuclear Fuel - Americas - Core Inspection Report 07001113/2023001 and Notice of Violation

ML23117A018
Person / Time
Site:	07001113
Issue date:	05/03/2023
From:	Robert Williams NRC/RGN-II/DFFI
To:	Huth R Global Nuclear Fuel
References
IR 2023001
Download: ML23117A018 (24)

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 07001113/2023001 AND NOTICE OF VIOLATION

Dear Ryan Huth:

This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection activities conducted from January 1 to March 31, 2023, for the Global Nuclear Fuel - Americas facility in Wilmington, NC. On February 3 and March 24, 2023, the NRC inspectors discussed the results of this inspection with you or other members of your staff. The results of these inspections are documented in the enclosed report.

The inspections examined activities conducted under your license as they relate to public health and safety, and the common defense and security, and to confirm compliance with the Commission's rules and regulations and with the conditions of your license. Within these areas, the inspections consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.

Based on the results of these inspections, the NRC has determined that one Severity Level IV violation of NRC requirements occurred.

The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's Web site at ( https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html). The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is being cited in the Notice because it was not considered licensee-identified since it was self-revealed by an unrelated plant event involving loss of instrument air.

The NRC has concluded that information regarding: (1) the reason for the violation; (2) the corrective actions that have been taken and the results achieved; and (3) the date when full compliance was achieved is already adequately addressed on the docket in your event follow-up report submitted to the NRC on February 1, 2023, and the NRC inspection report enclosed to this letter. Therefore, you are not required to respond to this letter unless the description herein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.May 3, 2023 R. Huth 2 In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the Public without redaction.

Sincerely, Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07001113 License No. SNM-1097

Enclosures:

- Notice of Violation - NRC Inspection Report 07001113/2023001 cc w/ encl: Distribution via LISTSERV Signed by Williams, Robert on 05/03/23

ML23117A018 Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available

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

NAME G. Goff T. Sippel M. Greenleaf J. Rivera R. Williams DATE 05/01/23 05/03/23 04/28/23 04/27/23 05/03/23 NOTICE OF VIOLATION

Global Nuclear Fuel - Americas, LLC Docket No.: 07001113 Wilmington, NC License No.: SNM-1097

During a Nuclear Regulatory Commission (NRC) inspection completed on March 31, 2023, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

10 CFR 70.61(e) requires, in part, that the licensee's safety program, established and maintained pursuant to § 70.62 of Subpart H, shall ensure that each item relied on for Safety (IROFS) will be available and reliable to perform its intended function when needed and in the context of the performance requirements of this section.

10 CFR 70.62(d) requires, in part, that "management measures shall ensure that administrative controls identified as items relied on for safety are designed, implemented, and maintained, as necessary, to ensure they are available and reliable to perform their function when needed, to comply with the performance requirements of § 70.61 of this subpart."

Contrary to these requirements, prior to December 2, 2022, the licensee's safety program established pursuant to § 70.62 failed to establish management measures to ensure that administrative IROFS 403-04, "Sinter Test Grinder Swarf Collection Mass Balance," would be designed, implemented, and maintained, as necessary, to ensure it was available and reliable to perform its function when needed, to comply with the performance requirements of § 70.61. Specifically, 1) the operating procedures failed to ensure that accumulation of special nuclear material, such as holdup above the hatch valves, would be cleaned out before re-zeroing the mass balance for the system, and 2) neither the operating procedures or functional testing instructions ensured that the hatch valves were working to ensure the accumulated swarf in the system would be collected in the can.

This is a Severity Level IV violation in accordance with Section 6.2 of the NRC Enforcement Policy.

The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved, is already adequately addressed on the docket in the licensees vent follow-up report submitted to the NRC on February 1, 2023 (ADAMS ML23032A214), and NRC Inspection Report 07001113/2023001 (ADAMS ML23117A018). However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation (NOV 07001113/2023001-01)," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region II, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

Enclosure 1 If you choose to respond, your response will be made available electronically for public inspection in the NRC Public Document Room or in the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days of receipt.

Dated this 3rd day of May 2023

2 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Number: 07001113

License Number: SNM-1097

Report Number: 07001113/2023001

Licensee: Global Nuclear Fuel - Americas, LLC

Facility: Global Nuclear Fuel - Americas

Location: Wilmington, NC

Inspection Dates: January 30, 2023 to March 24, 2023

Inspectors: G. Goff, Technical Assistant M. Greenleaf, Technical Assistant T. Sippel, Sr. Fuel Facility Projects

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

Enclosure 2

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a core inspection at Global Nuclear Fuel - Americas, 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

Sinter Test Grinder Swarf Collection Mass Balance Failure Significance Report Section Severity Level IV 88015 NOV 07001113/2023001-01 Closed A Severity Level (SL)-IV, cited violation of 10 CFR 70 was identified for the failure of an item relied on for safety associated with the Sinter Test Grinder Swarf Collection Mass Balance.

Additional Tracking Items

Type Issue Number Title Report Section Status WER 07001113/2022-004-00 Degraded/Failed IROFS in 88015 Closed Sinter Test Grinder (EN56256)

WER 07001113/2022-003-00 Concurrent Notification - Fire 88055 Closed System Impairment (EN 56159)

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 5.0, 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) to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.1.1, 5.1.2.1, 5.3.1, and aspects of 5.4.4 and 5.4.5. Specifically, the inspectors interviewed licensee staff and reviewed the following CSAs and related documents:

CSA 206.00.100, "Dry Conversion Process (DCP) Blend, Pre-Compact, Granulate, and Tumble," Rev. 3, including the review of calculations and information related to the licensee's evaluation of the use of new moderating materials CSA 403.00.100, "Sinter Test Process," Rev. 3, including the review of the what-if analysis, normal, credible abnormal, and non-credible accident sequences and the controls used to prevent credible sequences CSA 403.00.100, "Sinter Test Process," Rev. 4, including the review of accident sequences involving moderator intrusion into the swarf collection system, and review of related calculation models and results CSA 406.00.100, "Grinder Equipment, Apitron Filtration System, Off-line Sorting," Rev. 4, including review of the what-if analysis, normal, credible abnormal, and non-credible accident sequences and the controls used to prevent credible sequences Quantitative Risk Assessment (QRA) 401-503, "Fabrication - Press," Rev. 20

3 Criticality Implementation (IP Section 02.02)

The inspectors selected engineered and administrative controls (i.e., items relied on for safety or IROFS) from the licensees integrated safety analysis (ISA) summary to verify their implementation through a review of management measures and process descriptions, plant walk-downs, and operator interviews. The inspectors conducted the specific activities listed below to verify compliance with 10 CFR 70 and applicable sections of the license application, including 3.5.3 and 5.4.2.

observed the physical design characteristics of IROFS 206-05, "Blender Additive Bottle Design" and IROFS 206-11, "Tumbler Additive Bottle Design,"

during a walk-down observed the condition of the press feed area to assess the implementation of IROFS 402-14, "Press Feed Combustible Control Program" reviewed the as-installed condition of IROFS 403-03, "Process Equipment Barrier - Sinter Test Grinder Swarf Collection System," a passive engineered control (PEC) preventing the introduction of moderator reviewed records of recent functional tests, operating procedures, corrective action records, cleanout records, and non-destructive assay (NDA) records for IROFS 403-04, "Sinter Test Grinder Swarf Collection System Mass Balance,"

an augmented administrative control (AAC) on mass reviewed the as-installed condition of IROFS 406-01, "Process Equipment Barrier - Grinder," a PEC preventing the introduction of moderator reviewed the as-installed condition of IROFS 406-03, "Grinder Equipment -

Safe Geometry," a PEC controlling equipment dimensions to within safe limits reviewed a record of a recent functional test for IROFS 406-04, "Swarf Hood Can Present Sensor," an active engineered control (AEC) to ensure the can is present to collect swarf in a favorable geometry reviewed a record of a recent functional test for IROFS 406-05, "Apitron Filter System," an AEC to prevent the grinder from operating if the blowback is not working observed the condition of the grinder area to assess the implementation of IROFS 406-15, "Grind Area Combustible Control Program," an administrative control on combustible material loading

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 (SNM) to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.3.2.2. Specifically, the inspectors performed the following activities:

reviewed a sample of recent NCS audit reports, the 2023 NCS audit schedule, and interviewed NCS staff concerning NCS audits

4 interviewed NCS staff and licensee engineers concerning criticality control methods, focusing on controls applied to the grinders and swarf collection systems observed a licensee NCS engineer conduct portions of an NCS audit

Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures, external audits, and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the license application, including 2.2.1.6, 5.3.2.1, 5.3.2.2, 5.4.1.1, and 11.6.3. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:

NS-2022-02, "NDA Program Annual Review," dated February 18, 2022 various qualification records for qualified NCS engineers that were completed in 2022, including NS-2022-12, "GNF-A Senior Criticality Safety Engineer Qualification," dated December 14, 2022 the most recent external audit of the licensee's NCS program which was documented in "Triennial External Nuclear Criticality Safety Audit Report,"

dated December 11, 2022 the most recent revision to licensee NCS procedures, including WI-27-104-03, "Nuclear Safety Review" and WI-27-104-07, "Nuclear Safety Release Requirements"

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) entries to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.3.2.5 and 5.3.2.6. Additionally, the inspectors followed up on written event report (WER) 07001113/2022-004-00, "Degraded/Failed IROFS in Sinter Test Grinder (EN56256)." Specifically, the inspectors reviewed documents and interviewed licensee staff concerning the following:

CAAS-related CAP Entries: CR 41402, CR 40459, CR 40460, CR 40302, CR 40301, CR 40211, and selected related documents NCS-related CAP Entries: CR-40438, CR-41262, CR-40584, CR-40570, CR-40314, CR-41173, CR-41107, CR-41129, CR-40775, CR-40801, CR-40586, CR-40219, and selected related documents including the Safety Assessments for CR-40219 and CR-41262 procedures related to the use of the CAAS during a criticality event

88055 - Fire Protection

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

5 Selection of Inspection Samples (IP Section 02.01)

The inspectors reviewed licensing documents to select a sample of fire protection features in risk-significant areas/processes, including IROFS and their respective management measures (where applicable). The inspectors also selected licensee activities that support the implementation of the fire protection program based on the program description included in the license application. Specifically, the inspectors reviewed fire protection features in the areas listed below and selected a sample of IROFS for focused review.

Node Group 401, UO2 Press:

o IROFS 401 Press Hood Level Sensors (Optical Sensor) o IROFS 401 Feed Tube Level Sensor o IROFS 401 Press Feed System with Heat Detector and Isolation o IROFS 401 Press Turntable Overflow Sensor

Node Group 501, Gadolinium (GAD) Vibromill:

o IROFS 501 Combustible Control Program o IROFS 900 Non-Hydrogenous Fire Suppression

Node Group 502, GAD Slugger:

o IROFS 502 Safe Geometry o IROFS 502 Feed Hopper & Feeder Safe Geometry o IROFS 502 Slugger/Granulator Hood Optical Sensor o IROFS 502 Additive Hood/Tumbler Safe Geometry o IROFS 502 Slugger/Granulator Area Combustible Control o IROFS 502 Feed Tube Level Sensor o IROFS 502 Feed System with Heat Detector and Isolation

Node Group 503, GAD Press:

o IROFS 503 Press Hood Level Sensors (Optical Sensor) o IROFS 503 Feed Hood Optical Sensor o IROFS 503 Feed Tube Level Sensor o IROFS 503 Press Feed System with Heat Detector and Isolation o IROFS 503 Press Turntable Overflow Sensor

Preventative Controls (IP Section 02.02)

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

walked down the node areas listed in Section 02.01 above to verify controls for transient combustibles and ignition sources walked down flammable liquid storage cabinets

6 interviewed fire protection personnel regarding the combustible controls program and control of ignition sources such as hot work, electrical panels, and motors interviewed operators regarding fire response training and control of combustibles as per OP1002.00.000, "Combustible Material Control Program

- Fabrication", Rev. 1 reviewed fire hazards, process hazards, and the ISA summary to verify that the transient combustible control program and operations procedures incorporated appropriate controls for transient and flammable materials reviewed hot work procedures, condition reports, the fire hazards analyses, and the ISA summary to verify that ignition sources are controlled in accordance with license requirements and procedures reviewed procedure CP-27-108, "Combustible Control Program", Rev. 6.1 reviewed procedure WI-27-109-01, "Hot Work Permits", Rev. 3.1

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

The inspectors reviewed selected fire detection devices to verify that detection and alarm systems were able to detect the minimal fire within the required time and initiate the safety function credited in the fire hazards analysis (FHA) or procedures. Specifically, the inspectors conducted the inspection activities listed below:

conducted walk-downs of the node areas listed in Section 02.01 above to verify the presence of smoke and heat detectors as per the ISA summary and drawings, and observed the physical condition of these detectors interviewed licensee personnel about the bases for the locations of the smoke and heat detectors interviewed licensee personnel and reviewed maintenance records regarding these smoke and heat detectors performed walk-downs of the Security Dispatch, Emergency Control Center, and the process areas including and surrounding the GAD and UO2 press areas to assess the material condition and location of fire detection equipment observed functional testing of oxygen and hydrogen detectors and associated alarms that monitor and control atmospheres inside furnaces

Suppression Systems and Activities (IP Section 02.04)

The inspectors interviewed license staff, reviewed fire protection program documents, and conducted plant walk-downs to verify that suppression systems were capable of performing the safety function credited in the license application, FHAs, or the ISA summary. Specifically, the inspectors:

observed the condition of automatic, wet fire sprinkler system in the GAD Slugger area to assess for corrosion and obstruction observed diesel and electric fire pump routine testing to verify functionality

7 observed fire water system repair work and associated compensatory measures walked down the GAD and UO2 press process areas to confirm the presence of non-hydrogenous fire extinguishers and confirm that they were readily accessible; within their service life; and displayed in the green range on the pressure gauge in accordance with procedure WI-27-110-01, "Fire Extinguisher Inspection, Maintenance and Replacement", Rev. 4.4 reviewed FHAs and confirmed that active and passive engineering controls credited in the analyses were installed and functional via visual inspection and via review of calibration/maintenance records interviewed emergency preparedness staff and performed a walk-down of the sites dam to verify the ability to prevent fire suppressant from being released following a fire - in accordance with the FHA reviewed the latest weekly maintenance test runs of the electric fire pump (primary) and the backup diesel fire pump

Passive Fire Protection Features (IP Section 02.05)

The inspectors reviewed selected passive fire protection features to verify these were in a proper material condition to perform the safety function credited in the ISA summary. Specifically, the inspectors performed the following activities:

reviewed drawings for fire doors and fire walls including those designated as IROFS walked down fire doors and fire walls including those designated as IROFS in the DCP area, fuel manufacturing operations (FMO) building, and powder warehouse interviewed fire protection personnel regarding fire doors, fire dampers, and fire walls designated as IROFS reviewed the most recent audit of fire doors and fire walls designated as IROFS observed the licensee test fire doors designated as IROFS for proper closure observed penetration seals for fire walls designated as IROFS reviewed FHA assumptions for GAD and UO2 press oil collection systems and verified assumptions bounded the as-built design

Fire Protection Program Elements (IP Section 02.06)

The inspectors reviewed selected fire protection program elements to verify compliance with the license requirements. Specifically, the inspectors completed the following activities:

observed a live modification of a fire water supply line that included excavation and installation of a new post indicator valve, fire hydrant, and pipe section followed by post-modification testing

8 interviewed licensee personnel regarding compensatory measures such as fire watches for areas impacted by the above modification as required by WI-27-110-08 interviewed operators and an area lead regarding fire safety training for their areas of operation interviewed emergency response operations (ERO) coordinator and reviewed the radiological controls & emergency preparedness (RC&EP) to verify ERO training was performed in accordance with the license application reviewed new employee orientation materials pertaining to fire suppression performed a walk-down of the emergency communications center, security dispatch, and firehouse to verify emergency communication systems are operable interviewed licensee staff regarding emergency lighting maintenance and testing to verify its availability and operability, when needed reviewed Pre-Fire Plans for the Nodes listed in Section 02.01 above interviewed the deputy fire marshal of New Hanover county regarding training opportunities and site familiarity offerings provided by the licensee

Identification and Resolution of Problems (IP Section 02.07)

The inspectors reviewed the licensees identification and resolution of fire protection issues to verify compliance with the license requirements. Additionally, the inspectors followed up on event notification56159 and associated follow-up report submitted to the NRC on December 12, 2022 (WER 07001113/2022-003-00, ADAMS ML22346A070) related to an overheating condition during flow test of the backup diesel fire pump. Specifically, the inspectors reviewed the following corrective action program entries and audits:

corrective action program entries: CR 39256, CR 39257, CR 39260, CR 39218, CR 39940, CR 40550, CR 41270, CR 41271, CR 41279, CR 40395, CR 38320, and CR 40732 fire protection-related audits:

o 1st Quarter 2022 Combustible Controls Audit o 2nd Quarter 2022 Combustible Controls Audit o 3rd Quarter 2022 Combustible Controls Audit o 4th Quarter 2022 Combustible Controls Audit o 2022 GNF-A Fire and Explosion Triennial Audit (NQS-2022-36) o IROFS Surveillance 900-19: Fire Barrier, Sunday, November 20, 2022 o Nuclear Insurance Inspection Report, March 22-24, 2022 o FM Global Risk Report, October 19, 2022 documentation related to corrective actions for EN 56159, WER 07001113/2022-003-00, including a walk-down of the system, review of the latest performance records, and observation of the system operation as part of a current modification at the time of the inspection

9 INSPECTION RESULTS

Sinter Test Grinder Swarf Collection Mass Balance Failure Severity Report Section Severity Level IV 88015 NOV 07001113/2023001-01 Closed A Severity Level (SL)-IV, cited violation of 10 CFR 70 was identified for the failure of an item relied on for safety associated with the Sinter Test Grinder Swarf Collection Mass Balance.

Description:

On November 29, 2022, a mass of dry uranium oxide powder greater than expected was identified in the Sinter Test Grinder (STG) swarf collection can prompting a shutdown of the STG and further investigation. Specifically, a transient in the plant air system had caused the hatch valves at the bottom of the STG swarf collection enclosure to cycle, resulting in a release of holdup material that had been trapped between the hatch valves. The licensee's investigation found that the bottom hatch valve had been failed closed for some time, including the last two annual cleanouts in 2022 and 2021. When the air pressure transient cycled the hatch valves on November 29, the holdup fell into the swarf collection can below, and triggered the alarm on the scale that monitors the swarf collection can and revealed the event. When operators changed the collection can they discovered 18.4 kg of dry uranium oxide powder in the can, which was greater than the ~5 kg of holdup mass indicated by IROFS 403-04, "Sinter Test Grinder Swarf Collection Mass Balance," at the time.

Subsequent equipment cleanout identified and removed an additional ~10 kg, for a total of 28.4 kg of dry uranium oxide compared to the system safety limit of 43.4 kg. The licensee's investigation determined that the swarf collection system was not completely cleaned out prior to the mass balance being zeroed during the 2022 and 2021 cleanouts. The licensee's investigation also determined that the safety limit could have been exceeded if swarf continued to build up and that IROFS 403-04 would not have been able to prevent an accumulation of greater than 43.4 kg while the hatch valve was stuck.

On December 2, 2022, the licensee reported the failure of IROFS 403-04 to the NRC because it was determined to not be available and reliable to perform its intended safety function in the STG swarf collection system. This was reported to the NRC as EN 56256. On February 1, 2023, the licensee submitted a written follow-up report in accordance with 10 CFR 70, Appendix A (ADAMS Accession Number ML23032A214).

IROFS 403-04 is a mass balance IROFS to ensure that the mass of material inside the grinder and dust collection system is equal to or less than an established administrative limit.

When pellets are ground, a percentage of the weight of the pellets is assumed to remain in the system until removed. When this assumed mass exceeds the process limit, the system gives the grinder operator an error message and prevents further grinder operation so that actions can be taken to reduce the holdup mass either by emptying the collection can and subtracting the mass removed from the assumed holdup mass, or by a more thorough equipment clean out, including changing the filter, and setting the holdup mass to zero.

However, the licensee's operating procedures neither required cleaning between the hatch valves prior to zeroing the mass balance nor operator verification that the hatch valves were functioning so that material would be able to fall into the can. Additionally, the licensee's functional test instructions (FTIs) applicable to the system (e.g., FTI 1020.25 F2, "STG HVAC Interlocks") did not require the hatch valves functionality to be verified when verifying the

10 IROFS's function.

An IROFS for moderation control, IROFS 403-03, "Process Equipment Barrier - Sinter Test Grinder Swarf Collection," remained in place during the time IROFS 403-04 was determined to be in a failed status to prevent the introduction of moderator in the event of a moderator upset and thereby prevent a criticality accident.

Corrective Actions: The licensee's immediate corrective actions included shutting down the STG, conducting thorough cleanouts and NDA to find and remove any additional material.

As described in the licensee's written follow-up report dated February 1, 2023, short term corrective actions include adding "a step to the operations procedure to manually test the hatch valve to validate the dust collection system is functioning as expected" and creating "a process to ensure the mass balance on a process accumulation station has been cleaned out prior to station balance reset."

The licensee's long term corrective actions included: 1) revising OP-1020.25.201, "Sinter Test Grinder - Grinder Operations," to require the hatch valves to be cycled during cleanouts so as to prevent material from accumulating between them, 2) revising OP-1020.25.201 and adding scales and interlocks to physically measure and track the accumulation of swarf as part of IROFS 403-04 and prevent the STG from running when too much has accumulated, and updating the IROFS in the ISA to reflect these changes, 3) revising procedures to provide improved cleanout guidance and reporting usual conditions to licensee management, and 4) modifying the tracking system to better ensure that accumulations are removed before the mass is zeroed in the tracking system.

Corrective Action

References:

The circumstances and corrective actions associated with this violation were documented in the following documents:

corrective action program entry CR-41107 nonconformance assessment NS-2022-09, "STG Safety Margin Assessment," dated 12/09/2022 licensee's 60-day follow-up report to the NRC (ADAMS ML23032A214), dated February 1, 2023

Analysis: The inspectors determined the failure of IROFS 403-03 constituted a violation of 10 CFR 70.61(e) and 70.62(d) for not establishing management measures to ensure IROFS 403-04 was available and reliable to perform its intended safety function. The violation was determined to be self-revealing because it became apparent as a result of an event involving loss of plant instrument air. The inspectors determined the violation was more-than-minor based on the screening criteria of Inspector Manual Chapter (IMC) 0616, Fuel Cycle Safety and Safeguards Inspection Reports, Appendix B, Examples of Minor Violations. The violation met Question 2 of IMC 0616, Appendix B, because if left uncorrected, it had the potential to lead to a more significant safety or safeguards concern. Particularly, had the IROFS failure not been revealed by a plant event, it could have eventually led to a more significant material accumulation. Also, the violation aligned with Example 1.b of IMC 0616, Appendix B, in that the use of an inadequate procedure (i.e., the procedure for cleanouts) adversely impacted the positioning and safety function of an IROFS. In this specific case procedure OP-1020.25.201 did not contain appropriate or adequate guidance to instruct the operators to cycle the hatch valves or otherwise address accumulation due to a stuck valve.

11 This violation resulted in no actual safety or security consequences. Based on the most limiting ISA accident sequence described in QRA 401-503, Section 3.2.20, "Moderator Leaks onto the Sinter Test Grinder Swarf Collection System," the initial potential safety consequence of the violation resulted in the likelihood of a high consequence accident to not be "highly unlikely" if no credit is given to IROFS 403-03. However, the subject accident sequence used a very conservative initiating event frequency. An analysis documented in "Reassessment of the Overall Likelihood of the Sinter Test Grinder Event," Rev. 0, determined that all the affected accident sequences would remain "highly unlikely" when considering a more realistic initiating event frequency and other applicable IROFS (e.g., IROFS 403-03).

Because the analysis in "Reassessment of the Overall Likelihood of the Sinter Test Grinder Event," Rev. 0, demonstrated that the applicable accident sequences would remain "highly unlikely" based on the approved ISA methodology, the most applicable Enforcement Policy Example based on the potential safety significance is SL IV violation Example 6.2.d.1: "Under 10 CFR Part 70, Subpart H, a licensee fails to meet the requirements of 10 CFR 70.61, Performance Requirements, and the failure does not result in a SL I, II, or III violation."

Enforcement:

Violation: 10 CFR 70.61(e) requires, in part, that the licensee's safety program, established and maintained pursuant to § 70.62 of Subpart H, shall ensure that each IROFS will be available and reliable to perform its intended function when needed and in the context of the performance requirements of this section.

10 CFR 70.62(d) requires, in part, that "management measures shall ensure that administrative controls identified as items relied on for safety are designed, implemented, and maintained, as necessary, to ensure they are available and reliable to perform their function when needed, to comply with the performance requirements of § 70.61 of this subpart."

Contrary to these requirements, prior to December 2, 2022, the licensee's safety program established pursuant to § 70.62 failed to establish management measures to ensure that administrative IROFS 403-04, "Sinter Test Grinder Swarf Collection Mass Balance," would be designed, implemented, and maintained, as necessary, to ensure it was available and reliable to perform its function when needed, to comply with the performance requirements of § 70.61. Specifically, 1) the operating procedures failed to ensure that SNM accumulations, such as holdup above the hatch valves, would be cleaned out before re-zeroing the mass balance for the system, and 2) neither the operating procedures or functional testing instructions (FTI)s ensured that the hatch valves were working to ensure the accumulated swarf in the system would be collected in the can.

This violation will be tracked as VIO 07001113/2023001-01, "Sinter Test Grinder Swarf Collection Mass Balance Failure," and is considered closed.

Enforcement Action: This violation is being cited because the licensee does not have an NRC-approved Corrective Action Program and did not identify the violation, consistent with Section 2.3.2 of the Enforcement Policy.

12 WER Degraded/Failed IROFS in Sinter Test Grinder (EN56256) 88015 (Closed) WER 07001113/2022-004-00

Description:

The inspectors reviewed the licensee's response to EN 56256, reported to the NRC on December 2, 2022, and its corresponding follow-up event report (ADAMS ML23032A214) summited to the NRC on February 1, 2023. The issue involved a failure of IROFS 403-04 in the STG dust collection system. The inspectors reviewed documents, interviewed personnel, and conducted plant walk-downs to assess the licensee's actions and determine whether violations of NRC requirements occurred. The inspectors identified a violation of NRC requirements related to management measures as discussed in NOV 07001113/2023001-01 (see "Inspection Results" section of this inspection report for details). WER 07001113/2022-004-00 is considered closed to NOV 07001113/2023001-01.

WER Concurrent Notification - Fire System Impairment (EN 88055 (Closed) 56159)

WER 07001113/2022-003-00

Description:

On October 12, 2022, the licensee notified the New Hanover County Deputy Fire Marshall per State code requirements that the fire suppression system encompassing the FMO was impaired. During a flow test, the backup diesel fire pump experienced an overheating condition. As a result, the diesel fire pump was placed in the manual "Off" position. The electric fire pump remained fully operational and available to perform its safety function. The diesel pump was repaired and returned to operation on October 13. Because the New Hanover County Deputy Fire Marshall was notified, a concurrent notification to the NRC Operations Center was made per 10 CFR 70, Appendix A(c). On December 12, 2022, the licensee submitted a written follow-up report to the NRC (ADAMS ML22346A070).

The inspectors reviewed the corrective actions and conducted walk-down of the affected equipment. The inspectors observed an operational run of the repaired equipment and reviewed records of weekly functional tests since the repair was performed in mid-October 2022. No violations of NRC requirements were identified.

EXIT MEETINGS AND DEBRIEFS

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

On February 3, 2023, the inspectors presented the NCS (IP 88015) inspection results to Scott Murray, Facility Licensing Manager, and other members of the licensee staff.

On March 24, 2023, the inspectors presented the Fire Protection (IP 88055) inspection results to Ryan Huth, Facility Manager, and other members of the licensee staff.

13 DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 88015 Corrective Action Safety Assessment for CR-40219 Documents Safety Assessment for CR-41262 CR 41107 NCA Nonconformance Assessment for CR 41107 Rev. 0 Checklist CR 41402, CR CAAS-related CAP Entries, accessed during inspection Various 40459, CR 40460, CR 40302, CR 40301, CR 40211 CR-40438, CR-NCS-related CAP Entries, accessed during inspection Various 41262, CR-40584, CR-40570, CR-40314, CR-41173, CR-41107, CR-41129, CR-40775, CR-40801, CR-40586, CR-40219 CR-41107 CR for the Sinter Test Grinder event 03/28/2023 version Engineering Software Modification Plan to add real time monitoring of the 12/02/2022 Changes swarf can scale and hatch valves eCR-51435 Replace Sinter Test Press/Grinder Scale and update STG Rev. 1 mass control Engineering Reassessment of the Overall Likelihood of the Sinter Test Rev. 0 Evaluations Grinder Event CSA 206.00.100 DCP Blend, Pre-Compact, Granulate, and Tumble Rev. 3 CSA 403.00.100 Sinter Test Process Rev. 4 CSA 403.00.100 Sinter Test Process Rev. 3 CSA 406.00.100 Grinder Equipment, Apitron Filtration System, Off-line Rev. 4

14 Inspection Type Designation Description or Title Revision or Procedure Date Sorting NS-2022-09 STG Safety Margin Assessment 12/09/2022 QRA-401-503 Fabrication - Press Rev. 20 Miscellaneous email concerning STG NDA 02/13/2023 FTI 1020.25 F1 Sinter Test Grinder (STG) Non-IROFS Interlocks Performed 10/27/2022 FTI 1020.25 F2 STG HVAC Interlocks Performed 10/27/2022 FTI 1040.05 F1 Prevent can overfill at discharge of UO2 Grind Utility Scrap Performed Hood 04/19/2022 FTI 1040.12 F1 UO2 Pellet Grind Hard Scrap Can Interlocks Performed Rev. 1.2 10/07/2022 LS 2310.00.06 Detector Functionality Test Logs Completed 12/07/2022, 12/08/2022 LS 2310.00.07 Detector Trip Test 2 Out Of 3 Functionality Log Completed 12/09/2022 NS-2022-04 GNFA Senior Criticality Safety Engineer Qualification 04/28/2022 NS-2022-05 GNFA Senior Criticality Safety Engineer Qualification 05/06/2022 NS-2022-12 GNFA Senior Criticality Safety Engineer Qualification 12/14/2022 TD 802-04 Vacuum Moderation Control Rev. 1 Procedures OP-1020.25.100 Sinter Test Grinder - General Information Rev. 2, 02/20/2023 OP-1020.25.201 Sinter Test Grinder - Grinder Operations Rev. 6 OP-1020.25.201 Sinter Test Grinder - Grinder Operations Rev. 8, 03/06/2023 OP-2310.00.200 CAAS - Operating, Maintenance, Testing, and Response Rev. 2 Procedure System Operations and Response OP-2310.00.601 CAAS - Operating, Maintenance, Testing, and Response Rev. 1 Procedure ECC Remote Panel Operations TOP 50353 Production Grinder for Sinter Test Rev. 0 WI-27-104-03 Nuclear Safety Review Rev. 5.0

15 Inspection Type Designation Description or Title Revision or Procedure Date WI-27-104-07 Nuclear Safety Release Requirements Rev. 3.0 Self-Assessments 3Q22 Nuclear Criticality Safety Audit - Nodes 101, 201, 202, 9/16/2022 204: Cylinder Receipt, Handling and Storage, DCP Vaporization, Conversion, Powder Outlet 2022 Nuclear Safety Audit - Nodes(s) 301, 302, 303, 304, 09/20/2022 507, 508 Triennial External Nuclear Criticality Safety Audit Report12/11/2022 NS-2022-02 NDA Program Annual Review 02/18/2022 NSE-2022-0926 Nuclear Safety Audit of Nodes 803, 804 09/26/2022 Work Orders WO 5219647 Check Yellow Amp 4 speaker loop for water intrusion, and 08/23/2022 repair as needed to restore normal loop voltage 88055 Calculations CALC-900-005 Evaluation of General Fire Area Size for Use in QRAs Rev. 0 Corrective Action CR 39218 Documents CR 39256 CR 39257 CR 39260 CR 39940 CR 40550 CR 41270 CR 41271 Corrective Action CR 42042 NRC Fire Safety Inspection - 480 V electrical cabinets not 03/22/2023 Documents identified as ignition sources in QRA/PHA Resulting from CR ID #42042 Condition Report 42042 03/22/2023 Inspection Drawings 2077D08 FMO GAD Mezzanine North GAD Slugger/Granulator Press REV 3 24 VDC E-Stop Wiring & Press Controls 2090D08 FMO GAD Mezzanine North GAD Slugger/Granulator REV 4 Press/Pressdump 480/120 VAC Wiring Schematic & 24 VDC I/O from Press 2163D98, Sht. 1 GAD Rotary Press 24 VDC Wiring Schematic Rev. 4 2176D98, Sht. 1 FMO GAD Rotary Press Dump 480/120 VAC Wiring Rev. 5 Schematic and 240 Volt I/O From Press 2203D98, Sht. 1 3B Rotary Press Press Controls 24 VDC Wiring Schematic Rev. 2 8001E11 DCP First Floor Vaporization FHA Fire Barriers REV 3

16 Inspection Type Designation Description or Title Revision or Procedure Date 8001E11 DCP Second Floor Conversion FHA Fire Barriers REV 4 8001E11 DCP Third Floor Powder Areas FHA Fire Barriers REV 3 8001E11 FMO/Powder Warehouse Powder Warehouse FHA Fire REV 0 Barriers 8011E13 FMOX Building (BOP) Combustible Control FHA Fire Barrier REV 2 8011E13 FMOX Building (BOP) Combustible Control FHA Fire Barrier REV 1 8012E13 FMO/FMOX Building (BOP) Combustible Control Area REV 0 Ground Floor 8012E13 FMO/FMOX Building (BOP) Combustible Control Area REV 3 Mezzanine Level 8012E13, Sht. 3 FMO/FMOX Building (BOP) Combustible Control Area Rev. 0 Ground Floor 8012E13, Sht. 4 FMO/FMOX Building (BOP) Combustible Control Area Rev. 0 Ground Floor 8012E13, Sht. 7 FMO/FMOX Building (BOP) Combustible Control Area Rev. 3 Mezzanine Level F-P Evolution General Electric Company / Wilmington, NC / INDEX 2023 Drawing 08375.39 & 08375.48 / Drawing #2/3 Engineering FHA 1001.00 Graded Fire Hazards Analysis Fuel Fabrication Operation Rev. 3 Evaluations NQS-2022-36 2022 GNF-A Fire and Explosion Triennial Audit 10/26/2022 PHA-401/503 ISA Reference Report for the Fabrication - Press Node Rev. 14 Group QRA-401-503 Fabrication - Press Rev. 21 SPM 23-003 Integrated Safety Analysis Summary Rev. 26 M230006 Fire Plans FHA-1001 Graded Fire Hazards Analysis Fuel Fabrication Operation Revision 3 Miscellaneous ISA Summary Revision 26 Memorandum of Understanding with New Hanover County May 3, 2019 Fire and Rescue Emergency Preparedness and Fire Protection Organization Chart Quarterly Oil Sample on Diesel Motor on Back-Up Fire 10/17/2022 Pump Quarterly Test Coolant Sample on Diesel Motor for Back-Up 10/17/2022

17 Inspection Type Designation Description or Title Revision or Procedure Date Fire Pump Sprinkler Inspection Certificate 03/13/2023 Pre-Fire Plan for FMO/FMOX Areas Electronic copies of weekly records for fire pump testing 2022-2023 Weekly Test on Electrical Fire Pump and Diesel Back-Up 03/13/2023 Fire Pump Quarterly Test on Diesel Motor on Back-Up Fire Pump 10/17/2022 Functional Test Slugger Heat Detector Sensor Rev 0.2 Instruction (FTI)

Functional Test GAD Slugger Powder Spill Sensors 1.0 Instruction (FTI)

Functional Test GAD Slugger Feed Tube High Level Sensor Rev. 3.0 Instruction (FTI)

Procedures CP-06-216-T01 Mass Control at Feed Tubes on Presses 3B, 4B, & 6B Using Rev. 5 Capacitive Sensors - Test F1 CP-18-104 EHS Regulatory Compliance Audits Rev. 3.1 CP-27-108 Combustible Control Program Revision 6.1 CP-27-114 Integrated Safety Analysis Rev. 11 CP-27-114 Integrated Safety Analysis Revision 11 OP 1002.00.000 Combustible Material Control Program - Fabrication REV 01 OP 1721.00.100 Gad R53 Slugger / MF6 Granulator - General Information Revision 2 OP 1721.00.202 Gad R53 Slugger / MF6 Granulator - Normal Operations Revision 3 OP 1721.00.205 Gad R53 Slugger / MF6 Granulator - Abnormal Operations Revision 1 OP 1721.00.206 Gad R53 Slugger / MF6 Granulator - Alarm Response and Revision 0 Emergency Operations OP 1721.00.300 Gad R53 Slugger / MF6 Granulator - Process Information Revision 1 PRI 5-05 UO2 Heat Detector Sensor - Test F8 Rev. 5 PRI 5-05 GAD Heat Detector Sensor - Test F12 Rev. 1.1 RC&EP Radiological Contingency & Emergency Plan Rev. 31 WI-27-109-01 Hot Work Permits Revision 3.1 WI-27-110-01 Fire Extinguisher Inspection, Maintenance and Replacement Revision 4.4 WI-27-110-08 Fire System Impairment Revision 3.0 WI-27-110-09 Fire Protection Program Revision 2.0

18 Inspection Type Designation Description or Title Revision or Procedure Date WI-27-110-16 Sprinkler System Water Supply Valve Monthly Inspection Revision 3.1 WI-27-110-17 Sprinkler System Quarterly Inspection and Flow Alarm Test Revision 5.1 WI-27-110-18 Sprinkler System Semi-Annual Supervisory Device Test Revision 1.2 Self-Assessments IROFS Surveillance 900-19: Fire Barrier 11/20/2022 Nuclear Insurance Inspection Report 03/22-24/2022 FM Global Risk Report 10/19/2022 1st Quarter 2022 Combustible Controls Audit 04/01/2022 2nd Quarter 2022 Combustible Controls Audit 06/30/2022 3rd Quarter 2022 Combustible Controls Audit 10/03/2022 4th Quarter 2022 Combustible Controls Audit 12/21/2022 NQS-2022-36 2022 GNF-A Fire and Explosion Triennial Audit

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