ML19304B933

Louisiana Energy Services, LLC (Les), Dba Urenco USA (Uusa) - Nuclear Regulatory Commission Integrated Inspection Report 70-3103/2019-004

ML19304B933
Person / Time
Site:	07003103
Issue date:	10/31/2019
From:	Robert Williams NRC/RGN-II/DFFI
To:	Cowne S URENCO USA
Geanette D
References
EN 53892, EN 54101 IR 2019004
Download: ML19304B933 (28)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 EN 53892 EN 54101 October 31, 2019 Stephen Cowne, Chief Nuclear Officer and Compliance Manager URENCO USA P.O. Box 1789 Eunice, NM 88231

SUBJECT:

LOUISIANA ENERGY SERVICES, LLC (LES), dba URENCO USA (UUSA) -

NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 70-3103/2019-004

Dear Mr. Cowne:

This letter refers to the inspections conducted by the U.S. Nuclear Regulatory Commission (NRC) from July 1 through September 30, 2019, at the URENCO USA (UUSA) facility located in Eunice, New Mexico. The enclosed report presents the results of these inspections, which were discussed with you and members of your staff on August 15 and September 26, 2019.

These inspections examined activities conducted under your license, as they related to public health and safety, to confirm compliance with U.S. NRC rules and regulations and the conditions of your license. The inspection areas covered operational safety, nuclear criticality safety, emergency preparedness, fire protection, and plant modifications, and event follow up.

Within these areas, the inspections consisted of examinations of selected procedures and representative records, observations of activities, and interviews with personnel.

Based on the results of this inspection, the NRC has determined that two Severity Level (SL) IV violations of NRC requirements occurred. Because the violations were of low safety significance and UUSA entered the issues into their corrective action program, these violations are being treated as non-cited violations (NCVs), consistent with Section 2.3.2 of the NRC Enforcement Policy. The NCVs are described in the enclosed inspection report. If you contest the violations or significance of the NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to: (1) the Regional Administrator, Region II; and (2) the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 of the NRCs Rules of Practice and Procedure, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response

S. Cowne 2 should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction.

If you have any questions regarding this matter, please contact me at (404) 997-4664.

Sincerely,

/Joel Rivera Ortiz RA for/

Robert E. Williams Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 70-3103 License No. SNM-2010

Enclosure:

Inspection Report No. 70-3103/2019-004 w/

Attachment:

Supplemental Information cc:

Butch Tongate, Cabinet Secretary New Mexico Department of Environment Office of the Secretary 1190 St. Francis Drive P.O. Box 26110 Santa Fe, NM 87502-0157 Billy Hobbs, Mayor City of Eunice P.O. Box 147/1106 Ave J Eunice, NM 88231 The Honorable Sam D. Cobb, Mayor City of Hobbs 200 E. Broadway Hobbs, NM 88240 Stephen Aldridge, Mayor City of Jal P.O. Drawer 340 Jal, NM 88252 Chair Rebecca Long Lea County Board of County Commissioners Lea County Courthouse 100 North Main Avenue, Suite 4 Lovington, NM 88260 (cc: Contd on page 3)

S. Cowne 3 (cc: contd)

Daniel F. Stenger, Counsel Hogan Lovells VP LLP 555 13th Street, NW Washington, DC 20004 Santiago Rodriguez, Chief Radiation Controls Bureau NM Environment Department PO Box 5469 Santa Fe, NM 87502-5469 Karen Fili, Managing Director UUSA, President and Chief Executive Officer Louisiana Energy Services, LLC URENCO USA P.O. Box 1789 Eunice, NM 88231 Karen.Fili@Urenco.com Lisa Hardison, Manager Communications and Public Relations Louisiana Energy Services, LLC URENCO USA P.O. Box 1789 Eunice, NM 88231 Lisa.Hardison@urenco.com Richard Goorevich, Director Government Affairs Louisiana Energy Services, LLC URENCO Ltd.

1560 Wilson Blvd. Suite 300 Arlington, VA 22209 Richard.Goorevich@urenco.com Perry Robinson, Outside General Counsel URENCO USA P.O. Box 1789 Eunice, NM 88231 Perry.Robinson@urenco.com Richard A. Ratliff, PE, LMP Radiation Program Officer Bureau of Radiation Control Department of State Health Services Division for Regulatory Services 1100 West 49th Street Austin, TX 78756-3189

ML19304B933 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI DC RII: DFFI NAME RWilliams N. Pitoniak RWomack MRuffin TSippel NPeterka BAdkins LCooke LPitts /JERO for/

DATE 10/17/2019 09/19/2019 09/20/2019 10/15/2019 10/17/2019 10/22/2019 10/22/2019 10/23/2019 10/ 31 /2019

U. S. Nuclear Regulatory Commission Region II Docket No.: 70-3103 License: SNM-2010 Report No.: 70-3103/2019-004 Enterprise Identifier: I-2019-004-0015 Licensee: Louisiana Energy Services (LES), LLC Facility: URENCO USA (UUSA)

Location: Eunice, NM Inspection Dates: July 1 through September 30, 2019 Inspectors: B. Adkins, Senior Fuel Facility Inspector (Sections B.3 and C.2)

N. Peterka, Fuel Facility Inspector (Section B.3)

N. Pitoniak, Senior Fuel Facility Inspector (Section B.3)

M. Ruffin, Fuel Facility Inspector (Section B.2)

T. Sippel, Fuel Facility Inspector (Sections A.2 and C.1)

P. Startz, Fuel Facility Inspector (Section A.1)

K. Womack, Fuel Facility Inspector (Section B.1)

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

EXECUTIVE

SUMMARY

Louisiana Energy Services, LLC (LES) dba URENCO USA (UUSA)

Nuclear Regulatory Commission Integrated Inspection Report 70-3103/2019-004 July 1 - September 30, 2019 Regional inspectors from the U.S. Nuclear Regulatory Commission (NRC) conducted announced inspections during normal shifts and in-office reviews. The inspectors observed safety-significant activities and equipment, walked down the facility, interviewed licensee personnel, and reviewed facility documents.

Safety Operations

• The inspectors reviewed a sample of activities in the operations area to verify compliance with conditions of the license and regulatory requirements. No violations of more than minor significance were identified. (Section A.1)

• The inspectors reviewed a sample of activities in the nuclear criticality safety area to verify compliance with conditions of the license and regulatory requirements. No violations of more than minor significance were identified. (Section A.2)

Facility Support

• The inspectors reviewed a sample of activities in the emergency preparedness area to verify compliance with conditions of the license and regulatory requirements. No violations of more than minor significance were identified. (Section B.1)

• The inspectors reviewed a sample of activities in the fire protection area to verify compliance with conditions of the license and regulatory requirements. No violations of more than minor significance were identified. (Section B.2)

• The inspectors reviewed a sample of activities in the area of plant modifications (triennial) to verify compliance with conditions of the license and regulatory requirements. No violations of more than minor significance were identified. One unresolved item, URI 70-3103/2019-004-03, was identified to evaluate the removal of the Uranium Byproduct Cylinder (UBC)

Pad fire hydrants. (Section B.3)

Other Areas

• The inspectors performed follow-up inspection activities for Event Notification53892 involving a non-conservative surveillance frequency calculation for Items Relied on for Safety (IROFS) C22. One Security Level (SL) IV, licensee identified, non-cited violation (NCV) of NRC requirements was identified. Inspection item EN 53892 is considered closed to NCV 70-3103/2019-01. (Section C.1)

• The inspectors performed follow-up inspection activities for EN 54101 involving the failure to close an autoclave pressure boundary valve (IROFS10). One SL IV, licensee identified, NCV of NRC requirements was identified. Inspection item EN 54101 is considered closed to NCV 70-3103/2019-02. (Section C.2)

Attachment Key Points of Contact List of Items Opened, Closed, and Discussed Inspection Procedures Used Documents Reviewed 3

REPORT DETAILS Summary of Plant Status The URENCO USA (UUSA) facility in Eunice, New Mexico, enriches uranium hexafluoride (UF6) using gas centrifuge technology. During the inspection period, the licensee conducted routine plant operations.

A. Safety Operations

1. Operational Safety (Inspection Procedure 88020)

a. Inspection Scope The inspectors evaluated processing equipment, operating procedures, actions of operations personnel, safety basis documentation, and safety-related features of the facility to evaluate compliance with licensees Safety Analysis Report (SAR), license application, and Title 10 of the Code of Federal Regulations (CFR) Part 70 regulations.

The inspectors interviewed staff and reviewed records associated with UF6 processing systems focusing on the feed of natural uranium into the process train, take-off of enriched UF6 product, sampling of UF6 product, and the safe storage of feed and product cylinders. Inspectors reviewed a sample of Items Relied Upon for Safety (IROFS) to evaluate their overall effectiveness in preventing or mitigating the associated accident sequences described in the Integrated Safety Analysis (ISA) Summary.

The inspectors conducted walkdowns of several UF6 feed, take-off, and sampling systems with approved system diagrams to evaluate if the actual equipment status and lineups were configured in accordance with the approved documentation. The inspectors attended a pre-job briefing with operators and maintenance staff in preparation for removing a UF6 sampling apparatus from a UF6 cylinder within an autoclave. Inspectors observed the personnel conducting and completing their activities to verify their work activities were in compliance with the associated work documentation.

The inspectors reviewed the safety postings applicable to the tasks being observed to determine if these postings were current, reflected safety controls, and were followed by the operators. The inspectors reviewed a sample of training and qualification records for operators to verify that their IROFS trainings for the UF6 handling systems were current and operators were knowledgeable of requirements.

The inspectors reviewed records and interviewed engineering staff to verify that fire safety IROFS 35 and 35a were in compliance with drawings and functional specifications to prevent a UF6 release. The inspectors performed physical measurements and compared them to the associated drawings to verify if the protective fire wall was adequate to achieve the safe distance to the UF6 cylinders and that the fire wall was built in compliance with National Fire Protection Association (NFPA) Standard 801.

Inspectors reviewed the transformer installation history to determine if the transformer was filled with a fire-retardant oil as required. The inspectors interviewed operators and reviewed surveillance documents to verify that fire protection management measures

were properly implemented, were present, and were capable of performing their intended safety functions, as required by 10 CFR 70.62.

The inspectors reviewed a sample of training records regarding initial and continuing training programs to verify compliance with the training requirements of the SAR. The inspectors reviewed a sample of operator qualification records for IROFS to verify that the individuals were currently qualified on the systems and equipment to which they were assigned to operate and maintain.

The inspectors reviewed a sample of corrective action program (CAP) entries from the past 12 months to verify that safety-significant issues were entered in the program for resolution and adequate corrective actions were initiated in accordance with Chapter 11 of the SAR. Additionally, the inspectors reviewed a sample of audits to verify that the licensee completed the assessments at the required frequency and entered significant audit findings into the CAP for resolution.

b. Conclusion

No violations of more than minor significance were identified.

2. Nuclear Criticality Safety (Inspection Procedure 88015)

a. Inspection Scope Criticality Analysis The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety (NCS) program to verify compliance with selected portions of 10 CFR 70, including 70.24 and 70.61d, Chapter 5 of the facilitys SAR, and applicable procedures.

The inspectors reviewed selected nuclear criticality safety analyses (NCSAs) to verify that they were consistent with the commitments in the license application. These commitments included the Double Contingency Principle, assurance of subcriticality under normal and credible abnormal conditions with the use of subcritical margin, and process specifications incorporating margin to protect against uncertainties in process variables and limits being accidentally exceeded. The inspectors also reviewed these NCSAs to verify that enrichment upsets were considered by modeling uranium enriched to 6 wt% U-235, in accordance with Section 5.2.1.3 of the SAR. The NCSAs were selected based on factors including whether they were new or revised and their operating history. The NCSAs reviewed included NCS-CSA-006, NCS-CSA-015, NCS-CSA-016, ETC4086371, and those listed in Section 4 of the attachment.

The inspectors reviewed the licensees generation of accident sequences to determine whether the NCSAs systematically identified normal and credible abnormal conditions in accordance with the commitments and methodologies in the SAR Section 5.2.1.5. The inspectors reviewed assumptions made for selected upset conditions, including moderator upsets, enrichment upsets, and mass upsets, to verify they were clearly described and appropriately conservative. This included the review of accident sequences for the Uranium Byproduct Cylinder (UBC) pad that the licensee determined to be incredible to determine whether the bases for incredibility were consistent with the license application. Specifically, the inspectors reviewed the probability calculations in 5

CALC-S-00152 to verify that the incredibility criteria in SAR Section 3.2.5.2, Likelihood Evaluation Method, were satisfied and the basis for the probability numbers used in the calculation to determine whether the basis for incredibility relied on any characteristics provided by IROFS or any facility features which should be identified as IROFS as required by 70.61 and SAR section 3.2.5.2.

The inspectors verified that the most recent changes to the validation report were reviewed by NRC staff during licensing, therefore, no additional review was performed.

Criticality Implementation The inspectors performed walkdowns of the UBC pad, the Cylinder Receipt and Dispatch Building (CRDB), and the autoclaves to determine whether existing plant configuration and operations were covered by, and consistent with, the process descriptions and safety bases in the selected NCSAs listed above. The inspectors reviewed process and system descriptions, drawings, and IROFS boundary documents to verify that controls established in the NCSAs were being implemented as specified.

This review focused on IROFSC22 and other controls related to 30B cylinders. The inspectors reviewed ISA Summary to determine whether the controls identified in the ISA Summary were consistent with the analysis in the NCSAs. The inspectors interviewed operators to verify that administrative actions established in the NCSAs were being implemented as specified in the written documentation.

Criticality Operational Oversight The inspectors reviewed NCS-related training material (including, EOR-GET-CRIT-01, and Nuclear Criticality Safety, 2018 Continuing Training) and interviewed operators to determine whether operator training included instruction in criticality hazards and control methods and whether the licensees established NCS-related operator training was consistent with commitments in Section 2.3.3 of the SAR, including the commitment to satisfy American Nuclear Society (ANS) Standard 8.20. Additionally, the inspectors interviewed operations staff to determine whether they were cognizant of NCS hazards and control methods (specifically, the implementation of IROFSC22 and IROFS53a) related to their specific job function.

The inspectors reviewed NCS weekly walkthrough records and accompanied a licensee NCS staff member on an NCS weekly walkthrough of the CRDB gaseous effluent ventilation system room to determine whether NCS staff routinely assessed field compliance with established NCS controls. The inspectors verified, through interviews with licensee NCS staff, that the NCS engineer prepared for the NCS weekly walkthrough by reviewing applicable documentation as needed to determine the limits for the area being walked down, as well as event reports that applied to the area, as required by CR-3-1000-03 Section 5.2.1. The inspectors interviewed NCS management and reviewed the NCS weekly walkthrough schedule to verify that the areas of the facility with credible NCS scenarios or where enriched material was present were audited by qualified NCS engineers on the frequencies specified in CR-3-1000-03 Sections 5.1.3 and 5.1.4. The inspectors also reviewed NCS weekly walkthrough records and CAP entries to verify that deficiencies were documented in accordance with SAR Section 11.5 by entering them into the CAP.

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Additionally, the inspectors interviewed NCS management and reviewed the most recent NCS self-assessment report, SA-2019-001, Assessment of Training and Posting Site Knowledge, the procedure for self-assessments (CA-3-1000-09), and training records and material (QA Overview) to verify that the licenses self-assessment of the NCS Program was conducted by personnel who have completed Quality Assurance (QA) training in accordance with CA-3-1000-09 Section 5.3.2 and SAR Section 11.5.1, Assessments. The inspectors also reviewed this self-assessment and corrective action entries to verify that items identified were documented in the CAP in accordance with CA-3-1000-09 Section 5.3.3.

Criticality Programmatic Oversight The inspectors reviewed the recently revised NCS program procedure, EG-3-3200-02, Nuclear Criticality Safety Analysis/Evaluation, to determine whether the licensee implemented license requirements and whether the NCS program was enacted in accordance with them. The inspectors interviewed NCS staff and management and reviewed records to determine whether NCS staff reviewed new and revised operations that could affect uranium, consistent with program procedures and at a level commensurate with their significance. The inspectors reviewed the NCSAs listed in the attachment to this inspection report to verify that they were performed in accordance with EG-3-3200-02, including meeting the requirements for independent review and approval.

The inspectors interviewed QA department staff concerning the conduct, planning, and scope of their audits of the NCS program. The inspectors also reviewed the schedule for the QA Audits of the NCS Program, and the audit training provided by QA staff (QA Overview) to verify that the audit of the NCS program was conducted at a frequency and scope consistent with SAR Section 11.5.2. The inspectors conducted interviews to verify that any deficiencies noted in the audits were entered into the CAP and were re-examined during future audits as required by SAR Section 11.5.2.

Criticality Incident Response The inspectors reviewed various aspects of the criticality accident alarm system (CAAS),

including the calculations to determine the immediate evacuation zone boundaries (CALC-S-00150), to determine whether the CAAS features met the applicable regulatory requirements in 10 CFR 70.24, and license commitments in Section 5.0 and 5.3 of the SAR. The inspectors reviewed testing records and interviewed licensee personnel to determine whether alarm signals were audible within the areas required to be evacuated, whether detectors were tested in accordance with manufacturer recommendations, and whether detector alarm setpoints and system logic were functionally tested, as required by ANS Standard 8.3.

The inspectors reviewed procedures (CR-3-1000-04 and EP-3-0200-10) and training content (EOR-GET-CRIT-01) to determine whether personnel were required and trained to evacuate to accountability points in the event of a CAAS alarm, whether consideration was given to routing evacuation routes to minimize the potential for exposing evacuating personnel to radiation, and whether personnel were made familiar with CAAS alarm signals.

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b. Conclusion

No violations of more than minor significance were identified.

B. Facility Support

1. Emergency Preparedness (Inspection Procedure 88050)

a. Inspection Scope The inspectors reviewed the licensees emergency preparedness (EP) program to verify compliance with its license, the Emergency Plan, and 10 CFR 70. The inspectors interviewed staff and reviewed records to verify that changes made to the Emergency Plan or within the facility were reviewed by the EP organization, as required.

Specifically, the inspectors verified that revisions made to change the site fire brigade to an incipient fire brigade were evaluated in order to determine whether the licensee made a programmatic change that would reduce safety without NRC approval as required by 10 CFR 70.32(i). The inspectors also reviewed procedures and interviewed staff and offsite response agencies in order to verify that changes to the program were incorporated into procedures, clearly communicated to staff, and coordinated with offsite support groups and agencies.

The inspectors reviewed a sample of the Emergency Preparedness Implementing Procedures (EPIPs) and toured the Emergency Operations Center (EOC) to determine whether current copies of the EPIPs were readily available to members of the Emergency Response Organization (ERO). The inspectors reviewed the content of the EPIPs to determine whether the procedures provided for the detection and proper classification of accidents, mitigation of the consequences of accidents, assessment of releases, protective actions recommendations, personnel accountability, notification and coordination, authority for initiating evacuation alarms, and safe shutdown as required by the emergency plan. Inspectors reviewed procedures to determine whether nuclear criticality safety precautions for firefighting were included in the procedures and interviewed offsite fire brigades to verify that firefighting considerations were communicated to and understood by offsite support agencies.

The inspectors interviewed staff members and reviewed training records regarding EP training in the past year. The inspectors conducted this review to verify that the licensee provided training for their personnel on emergency equipment as required by the Emergency Plan and that the individuals responsible for using the equipment were qualified and familiar with the procedures that they would use and implement during an actual emergency. The inspectors reviewed training material and observed a tabletop exercise between the ERO and offsite support agencies to verify that the licensee provided training for expected emergency situations consistent with the Emergency Plan.

The inspectors reviewed the written agreements with the off-site agencies to verify that the organizations required by the Emergency Plan had up-to-date agreements. The inspectors interviewed members of Hobbs HazMat First Responders to verify that they maintained an adequate understanding of the written agreements. The inspectors also reviewed communication records to verify that the licensee invited off-site organizations 8

for training and drill participation as required by the Emergency Plan. The inspectors reviewed records submitted to the New Mexico Department of Emergency Management to determine whether the licensee maintained its certification of compliance with the Emergency Planning and Community Right-To-Know Act of 1986.

The inspectors reviewed drill schedules, post-drill critiques, and self-audits to verify that required drills, exercises, and communication checks were conducted within the timeframe required by the Emergency Plan. The inspectors reviewed corrective action program entries to verify that issues identified during critiques and audits were being captured and addressed in the corrective action program.

The inspectors observed the storage of emergency equipment in the EOC to verify that the equipment was maintained as required by the Emergency Plan. The inspectors reviewed a quality assurance audit report of the EP program to verify that the licensee conducted audits in the area of emergency preparedness as required by Section 7.5 of the Emergency Plan.

b. Conclusion

No violations of more than minor significance were identified.

2. Fire Protection (Annual) (Inspection Procedure 88055)

a. Inspection Scope The inspectors reviewed licensee procedures and toured plant areas containing safety controls and IROFS to verify the material condition and operational status of fire protection equipment, systems, and features were in accordance with license specifications, specifically, Chapter 7, Fire Safety, of the SAR.

The inspectors performed walkdowns, reviewed surveillance records, and reviewed transient combustible permit records to verify that the control of transient combustible materials, including pre-staged work materials, was consistent with FP-3-1000-02, Flammable and Combustible Materials Control, and IROFS 36i and IROFS 36a as defined in the ISA Summary. The inspectors reviewed hot work permit records to verify the hot work permit program was implemented in accordance with FP-3-1000-03, Fire Prevention During Welding, Cutting, and Other Hot Work. The inspectors interviewed staff members and reviewed the fire system/feature impairment tracking log to verify that the licensees work planning organization was aware of active fire protection compensatory measures and understood what resulting adjustments were needed in planned work, as required. The inspectors reviewed procedures and performed walkdowns to verify flammable materials were stored in marked cabinets and controlled in accordance with FP-3-1000-02.

The inspectors conducted walkdowns and reviewed test records to verify the physical condition of the fire detection devices did not show physical damage, blockage, or potential interference with functionality in accordance with FP-3-1000-01, Fire Systems and Features Testing and Inspection, and NFPA 72, National Fire Alarm and Signaling Code, 1999 edition. The inspectors also observed a fire detection task inspection to verify operators received visual and audible indication when a fire detection system had 9

been activated and that each fire detection panel received power from two different sources.

The inspectors walked down the fire detection system in Separations Building Module (SBM)-1003 and reviewed the fire detection task inspection records to verify the selected fire protection systems were available, operable, and in proper material condition.

Additionally, the inspectors observed the fire detection task inspection to verify the fire protection systems were tested to verify their ability to perform their safety function in accordance with NFPA 72. The inspectors performed a walkdown in the centrifuge assembly building to verify the sprinkler heads were unobstructed, the water supply control valves to the system were open, and the fire water supply and pumping capability was operable and capable of supplying the water supply demand of the system as required by Chapter 7 of the SAR. The inspectors reviewed the last annual fire pump test and weekly run test records, interviewed licensee staff, and walked down the fire pumps and water tanks to verify the system was operable and capable of providing an adequate water supply in accordance with Chapter 7.5.1.1, Fire Water Supply and Distribution System, of the SAR.

The inspectors walked down several fire hydrants and fire extinguishers to verify firefighting equipment was in proper material condition and provided at the designated locations with unobstructed access in accordance with FP-3-1000-05, Pre-Incident Plan Development and Control.

The inspectors performed walkdowns and reviewed records to determine whether fire dampers, doors (IROFS 35), and penetration seals were being maintained in a condition that would ensure they were available and reliable to perform their safety function in accordance with NFPA 80, Standard for Fire Doors and Fire Windows, MA-3-2670-01, IROFS35 Fire Damper Inspections, MA-3-2826-01, IROFS35 Fire Barrier Penetration Seals Inspection, and MA-3-2826-02, IROFS25 Fire Door Inspections.

The inspectors reviewed the licensees fire protection fire system/feature impairment tracking log and procedure to verify that adequate compensatory measures were in place for out-of-service, degraded, or inoperable fire protection equipment, systems, or features in accordance with FP-3-1000-04, Fire System or Feature Impairments.

The inspectors reviewed the licensees CAP entries of fire related issues for the past 12 months to verify the licensee was identifying safety control or fire protection IROFS operability problems at an appropriate threshold and entering them into the program and appropriately screening events. The inspectors reviewed the Fire Protection 2019 Self-Assessment Report, ASSESSMENT SA-2019-005, to verify the licensee was conducting audits and self-assessments as required by Chapter 11.5, Audits and Assessments, of the SAR and that audit findings were being documented and tracked in the CAP.

The inspectors interviewed staff to verify that the training of maintenance workers responsible for fire protection activities was performed as required by TQ-3-0100-13, Training and Qualification Guidelines.

b. Conclusion

No violations of more than minor significance were identified.

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3. Plant Modifications (Triennial) (Inspection Procedure 88072)

a. Inspection Scope The inspectors reviewed the licensees configuration management program to determine whether the licensee established an effective program capable of evaluating, implementing, and tracking cumulative modifications to facility processes since the facility began operating in accordance with 10 CFR 70.72 and SAR Chapter 11, Management Measures. The inspectors reviewed configuration management procedures and interviewed licensee senior managers, supervisors, and engineers to verify that the configuration management program was being implemented in accordance with the aforementioned requirements.

The inspectors reviewed a selection of plant modification design packages associated with the UBC Storage Pad, liquid sampling area, and fire protection program to determine whether the licensee was implementing their plant modification program as described in the SAR, program procedures, and as required by 10 CFR 70.72 and 10 CFR 70.62(d). Specifically, the inspectors reviewed design and safety basis changes associated with the autoclaves, UBC crane and pad, and fire protection program to verify an adequate technical basis was established and the design assumptions were accurate for the modifications as required by 10 CFR 70.72. The inspectors analyzed the design packages to verify modifications made to interfacing or interconnecting systems did not adversely impact the applicability of the ISA or safety programs as required by 10 CFR 70.72(a)(6) or invalidate the natural phenomena hazards structural analysis as required by 10 CFR 70.62(c). Inspectors also verified the program had adequate provisions in place to prevent plant modifications from degrading performance capabilities of IROFS or other safety controls that were part of the safety design basis.

The inspectors reviewed open/deferred/cancelled work requests, temporary modifications, and operator workarounds and interviewed operations and maintenance staff to determine if components were operated outside of their normal configuration and whether there was any adverse impact to the systems safety basis. Specifically, the inspectors interviewed 10 personnel representing the operations, maintenance, and engineering departments to verify configuration control was maintained during maintenance repair activities and that required documentation and approval was obtained and maintained throughout the activities as required by MA-4-4000-02, Maintenance Troubleshooting Guide, Revision (Rev.) 2.

The inspectors verified that designs of plant modifications met the specific design criteria specified in applicable modification packages. Inspectors reviewed a sample of 10 CFR 70.72 evaluations (refer to Section 4.0, Documents Reviewed of this inspection report) to determine whether the licensee adequately evaluated the need for NRC pre-approval of select facility modifications.

The inspectors reviewed a sample of modifications to verify that design basis, licensing basis, and performance capabilities of IROFS had not been degraded through the modifications. The inspectors performed walkdowns and reviewed post-modification testing documentation to verify that the system conditions and tested capabilities were appropriate and consistent with the design basis and system functionality. Specifically, the inspectors reviewed 12 work orders (WO) associated with implementation of autoclave modifications, surveillance and testing of IROFS safety features, corrective 11

maintenance repairs and post maintenance testing, and preventive maintenance activities. The inspectors observed preventive maintenance activities associated with SBM 1003 autoclaves as documented in WO 1000397253. The observed activities included a pre-job brief, work site walkdown, and verification of authorization to commence work. The inspectors reviewed post-modification testing procedures and test results to verify the acceptance criteria for system parameters were met and valid, unintended system interactions did not occur, and IROFS performed their intended safety functions as required by 10 CFR 70.62(d). The inspectors compared the field condition with the modification packages to verify the following: the modifications were implemented in accordance with the approved design documents in the modification packages, the assumptions in the ISA were valid based on the actual configuration, and that operation of the modified processes and their management measures could be accomplished as assumed in the ISA to ensure the IROFS were available when needed.

Specifically, the inspectors performed walkdowns and field verification of nitrogen isolation valves associated with Engineering Change Request (ECR) 9173, Addition of Isolation Valves to Nitrogen Lines for SBM 1005 Product Station Valve Frames, and modification of seismic restraints of the UBC Pad gantry crane associated with CC-EG-2016-0011, Seismic Restraint Modification.

The inspectors reviewed instrumentation and controls changes associated with the autoclaves to verify that the licensee had established set points to prevent exceeding criticality or chemical safety exposure limits. The inspectors observed UBC crane and autoclave operations to verify that the safety function of the IROFS was adequately tested. Specifically, the inspectors observed activities associated with disconnecting a product cylinder as required per OP-3-0420-01, Disconnecting a Product Cylinder, Rev. 48 and discussed IROFS features with the two operations and maintenance personnel assigned to perform these activities. The inspectors reviewed records and calibration stickers to verify that the measuring and test equipment used in the surveillances was calibrated in accordance with licensee application requirements.

The inspectors reviewed applicable design basis documents to determine whether the licensing documents had been updated or were in the process of being updated promptly to reflect the modifications as required by 10 CFR 70.72(e).

The inspectors reviewed the most recent audit and assessment of the licensees configuration management program to verify that the licensee identified issues at an adequate threshold and entered them into their CAP in accordance with Chapter 11 of the SAR.

The inspectors also reviewed the licensees CAP to verify that issues related to the preparation and installation of plant modifications were properly categorized and addressed by the licensee with adequate corrective actions in accordance with Section 11 of the SAR. A total of 29 CAP entries were reviewed.

b. Conclusion

No violations of more than minor significance were identified. One Unresolved Item (URI) was opened to evaluate the removal of UBC Pad fire hydrants.

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URI 70-3103/2019-004-03: Evaluate Removal of UBC Pad Fire Hydrants Introduction During a review of EV 109724, the inspectors identified a URI associated with cutting and capping of a fire line that services the north side of the UBC Pad. In 2014, the licensee extended the UBC pad, covering an existing fire line, and then cut and capped the fire line, removing the four fire hydrants on the north side of the UBC Pad. SAR 7.5.1.1 requires complete fire hydrant coverage of the UBC Pad and NFPA 24 requires approval from the Authority Having Jurisdiction (AHJ) regarding spacing of fire hydrants.

Description The licensee implemented a modification in 2014 to increase the size of the UBC Pad by 50 ft on each end but failed to identify that the pad extension covered an existing fire line which is not permitted by NFPA 24. The primary concern would be potential pad collapse due to soil erosion beneath the storage pad in the event of a pipe break. As a result, the licensee cut and capped the fire line which resulted in the loss of all four fire hydrants located on the north side of the UBC Pad. The NRC questioned whether the remaining hydrants on the south side of the pad could provide complete coverage in the event of a fire as required by Section 7.5.1.1.1 of the SAR, which states, in part, that exterior fire hydrants, equipped with separate shutoff valves, are provided at intervals to ensure complete coverage of all facility structures including the UBC Pad. The NRC is awaiting further information from the licensee to determine if the (1) remaining fire hydrants can provide complete coverage of the UBC Pad, (2) UBC Pad is subject to the requirements of NFPA 24, and (3) licensee obtained proper approval for the change from the AHJ as required by NFPA 24. Specifically, Section 4.2.1 of NFPA 24 states, in part, Hydrants be located in a manner that will enable the needed fire flow to be delivered through hose lines to all exterior sides of any important structure. Hydrants shall be spaced in accordance with the authority having jurisdiction. As a result, the NRC staff opened URI 70-3103/2019-004-03, Evaluate Removal of UBC Pad Fire Hydrants, to further evaluate information related to this issue.

C. Other Areas

1. Written Event Report (WER) 07003103/2019-002: Non-conservative Surveillance Frequency Calculation (EN53892)

a. Inspection Scope The licensee reported, on February 22, 2019, that the calculation for the IROFSC22 surveillance periodicity contained non-conservative errors. The errors caused them to establish a less frequent surveillance frequency than the correct calculation would have established (e.g., once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> instead of every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />). The licensee submitted a 60-day written event report (ML19109A109) on April 12, 2019, and a supplemental written event report (ML19148A580) on May 21, 2019.

The periodicity calculation is documented in NCS-CSA-015, Nuclear Criticality Safety Analysis of IROFSC22 Periodicity. This calculation determines the required surveillance frequency based, in part, on the number of cascades. The required surveillance frequency decreases as more cascades are brought online. The error was found in NCS-CSA-015 Rev. 9 and corrected in NCS-CSA-015 Rev. 10.

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The inspectors reviewed both revisions, both written event reports, as well as revisions of the IROFS boundary definition document, NEF-BD-C22, Verify Subcriticality by Mass Balance Calculation, the Detailed Apparent Cause Evaluation ER Number: 130061, and other documentation. The inspectors did not identify any instances where the non-conservative surveillance frequency calculation caused a failure of the IROFS.

Therefore, no actual safety impact occurred.

The potential existed, however, for surveillances to have been missed, which could have resulted in a greater enrichment upset than anticipated downstream. The inspectors interviewed licensee staff and reviewed NCSAs for the following downstream processes:

NCS-CSA-016, Criticality Safety Analysis of 30B Cylinders, and ETC4086371, Criticality Safety Assessment of Product Cold Traps at 6% Enrichment for SBM1001, 1003 and 1005. For both of these processes, the NCSAs showed that sufficient margin has been established such that the minor enrichment upset due to a delayed IROFSC22 surveillance was not enough to cause an unsafe condition.

b. Conclusion

10 CFR 70.61(e), requires, in part, that [t]he safety program shall ensure that each item relied on for safety will be available and reliable to perform its intended function SAR Section 5.1, NCS Program, states, in part, that Nuclear criticality safety at the facility is assured by designing the facility, systems and components with safety margins such that safe conditions are maintained under normal and abnormal process conditions and any credible accident.

Contrary to those requirements, the NCS program did not ensure that IROFSC22 was able to perform its intended safety function under normal and abnormal process conditions. Specifically, calculational errors in NCS-CSA-015 resulted in the established surveillance periodicity being potentially inadequate to reliably perform its intended safety function of ensuring subcriticality by preventing greater than a critical mass at more than 6% enrichment from being produced.

This violation was entered into the licensees corrective action program as EV 130061.

The significance of the violation was screened using the Enforcement Policy and the guidance of IMC 0616 Appendix B, Examples of Minor Violations. This violation is more than minor per screening question 8 of IMC 0616 Appendix B; and per example j in the Operations/Chemical Safety examples of minor violations. The violation also aligns with Example 6.2.d.1 of an SL IV violation in the Enforcement Policy.

Therefore, this non-repetitive, licensee identified, and corrected violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. This item, WER 07003103/2019-002: Non-conservative surveillance frequency calculation (EN53892), is being closed to NCV 70-3103/2019-004-01, IROFSC22 Surveillance Periodicity Error.

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2. WER 07003103/2019-004, Open Autoclave Valve (EN 54101)

a. Inspection Scope The inspectors conducted a follow-up review of EN 54101, Open Autoclave Valve, which was reported to the NRC on June 05, 2019. On June 01, 2019, the licensee completed the annual IROFS10 surveillance for autoclave 1LS1. On June 02, 2019, 1LS1 tripped offline from a loss of power during a brownout. The autoclave was approximately two hours from being ready to sample. Following completion of the required extended cooldown period, the licensee performed a valve lineup of the system and discovered that valve 471-1A12-1MP6 was out of its normally required closed position. This valve is only operated once per year during the annual IROFS10 surveillance to verify the leak tight integrity of the autoclave pressure boundary. At this time, it was determined that valve 471-1A12 was left open following maintenance on 1LS1 and was not ensured closed during the autoclave connect. Valve 471-1A12 is an isolation boundary for IROFS10 and failing to ensure this valve was closed during the connect sequence allowed for the autoclave to be placed in operation without ensuring IROFS10 integrity. This resulted in a 24-hour report to the NRC.

In-order to determine the safety significance of the issue, the inspectors conducted a walkdown of the autoclave, reviewed the applicable operations and surveillance procedures, conducted interviews with responsible engineers, and reviewed the applicable accident sequences and IROFS credited in the ISA Summary. The inspectors concluded that IROFS10 is credited as a sole IROFS in accident sequence PB4-3 to prevent the release of UF6 during a liquid sampling process upset.

Specifically, IROFS10 is credited as a passive engineered control/barrier to prevent the release of UF6 to the process area and is necessary to meet the performance requirements of 10 CFR 70.61. The NRC concluded that the overall impact to the risk scoring was negligible based on the following: (1) the licensee performed a soap bubble leak check at 3950 bar following completion of the IROFS10 surveillance, (2) operational run data indicated that the Quality Level (QL)-3 pressure gauge installed downstream of the valve was holding pressure prior to the brownout (950 bar), and (3) the licensee performed an evaluation to credit IROFS 39c, worker evacuation, in the event of a UF6 release. As a result, the NRC concluded that UUSA continued to meet the performance requirements of 10 CFR 70.61.

The inspectors reviewed the licensees corrective actions as documented in EV 132253.

Specifically, the corrective actions include coaching operators on the dangers of becoming complacent, revising procedures across many groups to identify IROFS related steps as critical steps, separating these critical steps from system valve lineups, and placing configuration control locks on the IROFS10 valves.

b. Conclusion

Based on their review of the event, the inspectors concluded that a violation of NRC requirements occurred. Specifically, the inspectors determined that the licensee failed to meet the requirements of 10 CFR 70.62(d) to ensure that IROFS are available and reliable to perform their intended function. Specifically, on June 04, 2019, UUSA failed to implement management measures, specifically Procedures, to ensure that IROFS10 was available and reliable to perform its function when needed, to comply with the performance requirements of 10 CFR 70.61. Specifically, the licensee failed to follow 15

Step 3.5 of OP-3-0470-01 Attachment 1 to ensure closed isolation valve 471-1A12-1MP6, which is credited as part of the liquid sampling autoclave pressure boundary.

This violation was entered into the licensees corrective action program as EV 132253.

The significance of the violation was screened using the Enforcement Policy and the guidance of IMC 0616 Appendix B, Examples of Minor Violations. This violation is more than minor per screening question 9 IMC 0616 Appendix B. The violation also meets the criteria for a SL IV violation based on example 6.2.d.1 of the NRC Enforcement Policy.

Therefore, this non-repetitive, licensee identified, and corrected violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. This item, WER 07003103/2019-004: Open Autoclave Valve (EN 54101), is being closed to NCV 70-3103/2019-004-02, Failure to Close IROFS 10 Autoclave Valve.

D. Exit Meeting The inspection scope and results were presented to members of the licensees staff at various meetings throughout the inspection period and were summarized on August 15 and September 26, 2019 to K. Fili, Managing Director UUSA, and President and CEO LES, LLC and staff. Proprietary information was discussed during the inspection but is not included in this report.

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SUPPLEMENTAL INFORMATION

1. KEY POINTS OF CONTACT Name Title T. Bahra Dayshift Operator B. Bixenman Licensing Specialist A. Blackshear ISA/NCS Engineer T. Boes Emergency Preparedness Specialist S. Cowne Chief Nuclear Officer (CNO)

J. Dahlin Logistics Service Manager K. Fili Managing Director UUSA & CEO LES LLC R. Ginanni Autoclave System Engineer H. Harvey Quality Assurance Specialist J. Huber Safety and Emergency Response Manager J. Lagabed Pump Rebuild/Recycle Supervisor D. Lemmons Fire Protection Engineer R. Medina Acting Licensing Manager K. Miller Structural Engineer Q. Newell ISA/NCS Engineer A. Reidy Senior Criticality & ISA Engineer J. Rickman Licensing Specialist A. Rojas Fire Systems Engineer V. Romero Licensing S. Scott Engineering Manager K. Wolfe Acting Systems Engineering Supervisor M. Woods Dayshift Manager

2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 70-3103/2019-004-03 URI Evaluate Removal of UBC Pad Fire Hydrants (Section B.3)

Closed 70-3103/2019-002 WER Non-conservative Surveillance Frequency Calculation (EN 53892) (Section C.1) 70-3103/2019-004 WER Open Autoclave Valve (EN 54101) (Section C.2)

Opened/Closed 70-3103/2019-004-01 NCV IROFS C22 Surveillance Periodicity Error 70-3103/2019-004-02 NCV Failure to Close IROFS 10 Autoclave Valve

3. INSPECTION PROCEDURES USED IP 88020 Operational Safety Attachment

IP 88015 Nuclear Criticality Safety IP 88072 Plant Modifications (Triennial)

IP 88050 Emergency Preparedness IP 88055 Fire Protection (Annual)

4. DOCUMENTS REVIEWED Records:

2019-A-02-003, Report for the URENCO USA (UUSA) Nuclear Criticality Safety Program NQA-1 Audit, Rev. 0, March 18, 2019 100025407, 1Y Site Fire Hose Pressure Test, March 31, 2018 1000343821, 1Y Fire Detection Tasks, August 3, 2018 1000359015, 1Y Fire Doors 2Do320 & 2Do370 Inspection, December 10, 2018 1000364618, 1Y Fire Pump Testing, January 28, 2019 1000372521, 1Y Site Fire Hose Pressure Test, April 1, 2019 1000374578, SBM3: Repair Non-IROFS Door Issues, April 18, 2019 1000392040, 1W Electric Driven Fire Water Pump Manual Start, August 11, 2019 1000392045, 1W Diesel Driven Fire Water Pump Manual Start, August 11, 2019 1000392062, 1W IROFS35, Fire Doors Inspection, August 12, 2019 1000403272, CAB Fire Riser Check Valve Leak, August 14, 2019 2019-A-06-010, Report for UUSA Emergency Preparedness Audit, June 20, 2019 70.72(c) 2014-0014/DCN-2013-005, Replace IROFS 35 Doors in CRDB with astragal design, March 19, 2014 70.72(c) 2014-0136/MM2006833, Minor Modification on SBM1001X doors removing motors, May 2, 2014 70.72(c) 2014-0311/CC-EG-2013-0028 Rev. 1 Operational Phase of UBC Gantry Crane, December 4, 2014 70.72(c) 2015-0015/EG-3-5200-01, IROFS 27e Structural Inspection UBC Pad Gantry Crane, January 22, 2015 70.72(c) 2016-0010/CC-EG-2016-0010, UBC Crane Quality Level Changes, February 9, 2016 70.72(c) 2016-0011/CC-EG-2016-0011, Seismic Restraint Modification, January 12, 2016 70.72(c) 2017-0128/CC-EG-2017-0007, UBC Crane Rotating Trolley Repair, July 13, 2017 70.72(c) 2013-0486/CC-EG-2013-0028 Rev. 1, UBC Storage Pad Modifications, October 14, 2013 70.72(c) 2015-0021/CC-EG-2015-0008, NEF-BD-27e, Rev 6, Design Features of SBM and CRDB Structures and the UBC Storage Pad Gantry Crane, January 27, 2015 70.72(c) 2015-0025/CC-EG-2015-0020, NEF-BD-35a Initial Issuance, February 2, 0215 70.72(c) 2015-0179/CC-EG-2015-0112, Fire Accident Sequence Revision, September 2, 2015 70.72(c) 2015-0210/CC-EG-2015-0143, UBC Crane Submittals Building Number 1400, September 17, 2015 70.72(c) 2015-0277/ECR-9266, Relocation of six fire dampers in HVAC air handlers in UF6 Handling Area, December 2, 2015 70.72(c) 2015-0283/CC-EG-2015-0171, UBC Crane Bearings and Quality Level, December 1, 2015 70.72(c) 2016-0037/ECR9365, UBC Crane Welding, March 3, 2016 70.72(c) 2017-0067/OP-3-3300-01, Operations Surveillance Procedure, May 4, 2017 70.72(c) 2018-0083/MOD-18-0013, Clarification of difference between IROFS35 boundary and SBM 1001, April 26, 2018 2

70.72(c) 2018-0126/MOD-18-0051, Increase Nitrogen Primary Discharge Pressure, August 20, 2018 70.72(c) 2018-0143/CC-EG-2016-0057/MOD-18-0045, Fire Hazards Analysis Revision for Removal of IROFS 36g, October 2, 2018 70.72(c) 2018-0183/MOD-18-0080, Update CALC-F-00001 and FHA to Reflect Current Design for UBC Pad, October 24, 2018 CALC-S-00150, Immediate Evacuation Zone Calculations at UUSA, Rev. 0 CALC-S-00152, The Probabilistic Assessment of Criticality in a 30B Cylinder due to Participation with Impact/Drop on UBC Storage Pad or other Outdoor Storage Locations, Rev. 0 CC-EG-2014-0163, IROFS 28 Boundary Revision, October 20, 2014 CC-EG-2015-0048, SBM 1003 Autoclave Review for NEF-BD-11, February 5, 2015 CC-EG-2016-0057, Vegetation Control, Rev. 0, October 4, 2016 Drawing LES-1400-E-PHY-001-01-1, Electrical UBS Storage Slab Transformer/Switchgear Pad Detail, Rev. 1, March 3, 2015 ECR-8638, AS builts for Site Perimeter Ditch, March 21, 2014 ECR-9173, Addition of Isolation Valves to Nitrogen Lines for SBM 1005 Product Station Valve Frames, March 17, 2015 ECR-9270A, Engineering Change Request for QL-2AC Designation for the Product System 424/425, May 2, 2016 ECR-9359, Addition of Second Pressure Transducer to System 425 Vent Headers for SBM 1001, 1003, 1005 UF6 Areas, November 21, 2017 EG-3-2100-05, Commercial Grade Dedication Process for Using Burndy Ring Tongue Terminals, May 14, 2014 EG-3-2100-09-F-1, Nonconformance Identification and Proposed Disposition for Autoclave 1001-471-2B1 Non-Specified Terminations in IROFS 12 Equipment, May 9, 2014 EG-3-2100-09-F-3, Nonconformance Closure for SBM 1001 Autoclave #2 IROFS 11 and 12 Terminal Lugs, November 20, 2014 EOR-GET-CRIT-01, Nuclear Safety Training Nuclear Criticality Safety, Rev.3.1 ETC4086371, Criticality Safety Assessment of Product Cold Traps at 6% Enrichment for SBM1001, 1003 and 1005, Issue 9 FP-1-1000-01, Fire Loss Prevention, Rev. 1, January 14, 019 FP-2-1000-01, Fire Protection Program Requirements, Rev. 9, January 14, 2019 FP-3-1000-04-F-5, Fire System/ Feature Impairment Tracking, June 6, 2019 FP-3-1000-05, Pre-Incident Plan Development and Control, Rev. 08, February 12, 2019 FPE-REV-001, Fire Hazards Analysis for URENCO USA, Rev. 20, November 16, 2017 ISA-MEM-0058, UBC Storage Pad and Crane HAZOP and Risk Determination Analysis, February 2, 2018 LES-0000-C-CVL-002-01B-2, Overall Site Plan Field Monitoring Response Plan, March 9, 2015 LES-0000-C-CVL-008-02, Fencing Plan Sheet 2, Rev. 0 Mod 18-0045, Fire Hazards Analysis Revision for Removal of IROFS36g (CC-EG-2016-0057), August 2, 2018 Mod 18-0087, Stillages and Sampling Manifold SBM UF6 Area, December 17, 2018 Mod-ECR-9049, North and East CAA Boundary Fence, November 7, 2014 NCS-CSA-006, Criticality Safety Analysis of the Product Vent Pump and Chemical Trap Set, Rev. 9 NCS-CSA-013, Nuclear Criticality Safety Analysis of 55-Gallon Waste Drums, Rev. 4 NCS-CSA-015, Nuclear Criticality Safety Analysis of IROFSC22 Periodicity, Rev. 5 NCS-CSA-015, Nuclear Criticality Safety Analysis of IROFSC22 Periodicity, Rev. 9 NCS-CSA-015, Nuclear Criticality Safety Analysis of IROFSC22 Periodicity, Rev. 10 3

NCS-CSA-016, Criticality Safety Analysis of 30B Cylinders, Rev. 4 NCSI-19-0028, Trap Room in CRBD Bunker, dated July 15, 2019 NCSI-19-0029, SBM-1003 and SBM-1005 GEVS Rooms, dated July 19, 2019 NCSI-19-0032, Decontamination Workshop, dated August 8, 2019 NCSI-19-0033, Cascade Halls SBM-1003, dated August 22, 2019 NCSI-19-0034, SBM1001 CAAS, dated August 30, 2019 NCSI-19-0035, Cascade Halls SBM-1005, dated August 30, 2019 NEF-BD-11, Automatic Trip of the Autoclave Heater and Fan on Autoclave High Internal Air Temperature (RTD), Rev. 5, January 10, 2017 NEF-BD-53a, Administratively Ensure Uranium Assay Measurement of Feed Cylinder, Rev. 3 NEF-BD-60, Administrative Establishment of Inert Gas Environment Over Trap Opening, (Safety Functions & Boundary) Rev. 2, March 21, 2019 NEF-BD-61, Administrative Purge Carbon Trap to Prevent Deflagration, (Safety Functions &

Boundary), Rev. 1, March 21, 2019 NEF-BD-C22, Verify Subcriticality by Mass Balance Calculation, Rev. 5 NEF-BD-C22, Verify Subcriticality by Mass Balance Calculation, Rev. 11OP-3-1000-09-F-4, Operability Evaluation of SBM 1001 Autoclave IROFS 12 Ring Lugs, May 19, 2014 OP-3-1000-09-F-4, Operability Evaluation of SBM 1001 Autoclaves IROFS 11 Ring Lugs, May 13, 2014 QA Overview, November 17, 2017 SA-2019-001, Assessment of Training and Posting Site Knowledge, August 28, 2019 SA-2019-005, Fire Protection 2019 Self-Assessment Report, March 25th-29th, 2019 SA-2018-007, Emergency Preparedness Self-Assessment, June 18, 2018 SA-2019-008, Emergency Preparedness Self-Assessment, July 10, 2019 Safety Analysis Report, Rev. 46 Work Order 1000131706, SBM 1001 Annual Autoclave # 2 IROFS 11 and 12 Surveillance, June 3, 2014 Work Order 1000144573, SBM 1001 Autoclave #2 IROFS 12 Cable Replacement, June 2, 2014 Work Order 1000144808, SBM1 Autoclave #1 IROFS 11 PMT Following Lug Replacement, June 4, 2014 Work Order 1000144809, SBM 1001 Autoclave #3 IROFS 11 PMT Following Lug Replacement, June 6, 2014 Work Order 1000144810, SBM 1001 Autoclave #1 IROFS 11 RTD Lug Replacement, June 3, 2014 Work Order 1000144811, SBM 1001 Autoclave #2 IROFS 11 RTD Lug Replacement, June 2, 2014 Work Order 1000144812, SBM 1001 Autoclave #3 IROFS 11 RTD Lug Replacement, June 6, 2014 Work Order 1000327434, Sample Carbon Trap, Function UN-NEF-1100-900 Work Order 1000332826, 1Y: Site CAAS Annual Maintenance, performed July 2018 Work Order 1000355604, 1Y: Tuning of CAAS Amp Monitor, November 5, 2018 Work Order 1000364677, SBM 1003 Annual Autoclave IROFS 11 and 12 Surveillance, January 21, 2019 Work Order 1000364679, SBM 1004 Annual Autoclave IROFS 11 and 12 Surveillance, January 29, 2019 Work Order 1000369657, SBM 1001 Autoclave #3 Annual Autoclave IROFS 11 and 12 Surveillance, February 13, 2019 Work Order 1000371688, SBM 1001 Autoclave #2 Annual Autoclave IROFS 11 and 12 Surveillance, February 13, 2019 4

Work Order 1000381832, 1Y: Site CAAS Annual Maintenance, performed May and June 2019 Work Order 1000383857, SBM 1001 Autoclave #1 Annual Autoclave IROFS 11 and 12 Surveillance, May 28, 2019 Work Order 1000382474, Site Engineering Inspection of IROFS 28, March 14, 2019 Work Order 1000397253, Autoclave 3LS1 Mechanical Inspection, October 1, 2019 Procedures:

AD-3-1000-10, Change Process Management, Rev. 14, July 1, 2019 CA-3-1000-01, Performance Improvement Program, Rev. 41, March 12, 2019 CA-3-1000-09, Assessment Program, Rev. 13 CR-3-1000-03, NCS Weekly Walkthroughs and Periodic Assessments, Rev. 13 CR-3-1000-04, Response to Nuclear Criticality Safety Anomalous Condition or Criticality Accident, Rev. 4 EG-3-2100-01, Configuration Change, Rev. 26, July 9, 2018 EG-3-3200-02, Nuclear Criticality Safety Analysis/Evaluation, Rev. 12, July 9, 2019 EG-3-4100-02, Rev. 20, July 2, 2019 EP-3-0200-01, Classification of Emergency Events, Rev. 8, December 19, 2018 EP-3-0200-02, Emergency Notification, Rev. 21, April 10, 2018 EP-3-0200-02, Emergency Notification, Rev. 22, November 19, 2018 EP-3-0200-06, Assembly and Personnel Accountability, Rev. 10, March 11, 2019 EP-3-0200-10, Criticality Emergency Response, Rev. 3 EP-3-0300-01, Maintaining Emergency Preparedness, Rev. 12, July 31, 2017 EP-3-0300-02, Responder Training, Rev. 13, November 21, 2017 EP-3-0300-03, Drills and Exercises, Rev. 5, November 13, 2017 EP-3-0300-04, Emergency Preparedness Inventory and Equipment Operability, Rev. 20, April 3, 2019 FP-3-1000-01, Fire System and Features Testing and Inspection, Rev. 06, August 23, 2018 FP-3-1000-02, Flammable and Combustible Materials Control, Rev. 12, December 3, 2018 FP-3-1000-03, Fire Prevention During Welding, Cutting, and Other Hot Work, Rev. 12, March 18, 2019 FP-3-1000-04, Fire System or Feature Impairments, Rev. 18, June 6, 2019 FP-3-1000-05, Pre-Incident Plan Development and Control, Rev. 08, February 12, 2019 FP-3-1000-08, Fire Barrier Inspection, Rev. 00, February 12, 2010 FP-3-1000-09, Plant fire Brigade & Training, Rev. 01, May 16, 2017 FP-3-2000-01, IROFS36i Combustibles Control Inspection - CTF/PMF, Rev. 05, April 13, 2015 FP-3-2000-03, IROFS35 Weekly Fire Door Inspection and IROFS35/36a/36d Combustibles Control Inspection- CRDB and ICC, Rev. 09, February 4, 2019 FP-3-2000-04, IROFS35 Weekly fire Door Inspection and IROFS36a Combustibles Control Inspection - SBM, Rev. 16, August 1, 2018 LS-3-1000-04, 10 CFR 70.72(c) Evaluations for Proposed Changes, Rev. 19, June 18, 2019 MA-2-1000-01, Conduct of Maintenance, Rev. 3, April 30, 2019 MA-2-1000-02, Preventative Maintenance Program, Rev. 2, July 15, 2019 MA-2-1000-03, Surveillance Program, Rev. 8, August 20, 2018 MA-3-0400-05, Calibration and Adjustment of IROFS 16 Series Pressure Transducers, Rev.

6, January 20, 2019 MA-3-2670-01, IROFS35 Fire Damper Inspections, Rev. 6, December 3, 2014 MA-3-2826-01, IROFS35 Fire Barrier Penetration Seals Inspection, Rev. 11, May 16, 2019 MA-3-2826-02, IROFS35 Fire Door Inspections, Rev. 14, July 15, 2019 5

MA-3-3400-11, IROFS 11, Autoclave Heater and Fan High Temperature Trip - RTD Surveillance, Rev. 10, January 28, 2019 MA-3-3400-12, IROFS 12, Autoclave Heater and Fan High Pressure Trip - Pressure Detector Surveillance, Rev. 10, January 28, 2019 MA-3-3561-01, CAAS Periodic Testing, Rev. 6 MA-4-4000-02, Maintenance Troubleshooting Guide, Rev. 2, March 12, 2019 MA-6-0591-01, Annual Fire Detection Tasks, Rev. 04, April 30, 2019 MA-6-0591-02, Semiannual Fire Detection Tasks, Rev. 03, October 6, 2015 MA-6-0591-03, Quarterly Fire Detection Tasks, Rev. 05, July 16, 2019 MA-6-0591-13, Elevator Fire Detection, Rev. 01, July 15, 2019 MA-6-0694-02, Quarterly Fire System Inspections and Tests, Rev. 04, May 1, 2018 MA-6-0694-11, Annual Fire Pump Maintenance, Rev. 01, September 13, 2012 MA-6-0694-17, Fire Protection Flow Testing, Rev. 09, July 11, 2019 MA-6-0694-20, Monthly Fire Pump Electrical Task Instructions, Rev. 07, May 21, 2018 MA-6-0694-26, Annual Fire Protection Inspections, Rev. 03, July 11, 2019 MA-6-0694-27, Fire Hydrant Annual Maintenance, Rev. 02, July 15, 2019 MA-6-2670-01, Fire Damper Inspections, Rev. 04, March 5, 2018 MA-6-2826-02, Fire Door Inspections, Rev. 04, July 15, 2019 OP-3-0410-01, Feed System, Rev. 53, June 4, 2019 OP-3-0410-02, Transferring Feed Materials to 30B Cylinders, Rev. 8, September 16, 2019 OP-3-0420-01, Disconnecting a Product Cylinder, Rev. 48 OP-3-0470-01, Liquid Sampling System, Rev. 35, August 8, 2019 OP-3-0490-06, Calibration and Adjustment of Pressure Transducers, Rev. 19, September 4, 2018 OP-3-0560-01, Criticality Accident Alarm System, Rev. 3, May 24, 2017 OP-3-0660-01, Gaseous Effluent Vent System, Rev. 21, September 4, 2019 OP-3-1000-01, Conduct of Operations, Rev. 31, September 4, 2019 OP-3-1000-08, Operating Requirements Manual Maintenance, Rev. 7, July 1, 2019 OP-3-1000-11, Operate While Constructing, Rev. 1, June 21, 2017 OP-3-3300-01, Operations Surveillance Procedure, Rev. 37, August 19, 2019 ORM 60-61, Chemical Carbon Trap Sampling Operations, Rev. 1, February 19, 2019 TQ-3-0100-13, Training and Qualification Guidelines, Rev. 8, October 16, 2017 TQ-3-0100-13, Training and Qualification Guidelines, Rev. 9, August 27, 2019 QA-3-2000-01, Quality Assurance Audit, Rev. 21, April 15, 2019 WC-3-1000-02, Work Package - Initiation through Closure, Rev. 30, September 9, 2019 WC-4-1000-02, Conduct of Pre and Post Job Briefs, Rev. 7, August 28, 2019 Condition Reports Written as a Result of the Inspection:

EV 130061, IROFSC22 NCSA has non-conservative periodicities, February 21, 2019 EV 132253, Autoclave Valve Left Open, June 1, 2019 EV 132971, Work Performed Using Information Only Drawing, August 14, 2019 EV 132977, Additional Observation to Audit Finding, August 14, 2019 EV 132978, Emergency Preparedness Procedure Improvement, August 14, 2019 EV 132988, QL-3 Door Not Properly Resolved or Reinspected, August 15, 2019 EV 132996, Drill Participation Needed from Local Medical Center, August 15, 2019 EV 133438, Missed Configuration Change with Pad Expansion, September 25, 2019 EV 133448, Shuttle lifts for UBC pad not included in FHA Combustible Load Calc, September 25, 2019 EV 133464, Probable Error in CALC-S-00152 Concerning Criticality Probability in 30B on UBC, September 26, 2019 6

EV 133466, NRC Observation of CAAS Testing Equipment, September 26, 2019 EV 133467, UBC Pad Fire Equipment Box, September 26, 2019 EV 133468, Label Plate on Valve not as Shown on Drawing, September 26, 2019 EV 133469, NRC Inspection Unresolved Item, September 26, 2019 Condition Reports Reviewed:

Detailed Apparent Cause Evaluation ER Number: 130061 EV 6323, EV 6925, EV 7516, EV 8566, EV 8582, EV 8599, EV 8799, EV 8836, EV 8846, EV 10041, EV 10272, EV 10317, EV 10665, EV 19511, EV 102622, EV 104960, EV 108545, EV 108600, EV 109958, EV 109724, EV 110331, EV 113712, EV 117616, EV 119946, EV 119563, EV 122564 EV 122865, EV 126264, EV 126604, EV 126636, EV 127186, EV 127329, EV 128414, EV 128628, EV 128676, EV 129851, EV 129885, EV 129950, EV 129970, EV 130061 EV 130179, EV 130190, EV 130238, EV 130272, EV 131540, EV 131705, EV 131715, EV 131718, EV 131780, EV 131808, EV 131872, EV 132022, EV 132023, EV 132182, EV 132209, EV 132253, EV 132319, EV 132380, EV 132397, EV 132517, EV 132725, EV 132743, EV 132988 Other Documents:

2019 ERO Roster, Rev. 5 2019 ERO Team Rotation, Rev. 2 2019 EP Drill Schedule 2019-A-05-007, Urenco USA Audit Report of Plant Modification Program, June 10, 2019 AD-3-1000-10-F-1 Change Management Checklist for IROFS 50 series suspension due to completion of major construction activities.

Baker Concrete Construction, 1400-ELEC-720-002, UBC Pad, Power Transformer, subcontractor work package, November 13, 2012, (QL-1F UBC Transformer oil fill, oil certification results)

Email from Charlotta Sanders dated May 28, 2018 Emergency Plan, Rev. 26 EP Training and Drills List EP Program Overview - Refresher Training EV 110648, Operate While Construct Applicability; exiting Construct While Operate phase; IROFS 50 series controls are designated as not applicable.

Fire Hazards Analysis for URENCO USA, FPE-REV-001-20, Appendix D, Page 17 of 36, IROFS 35 Concrete Fire Wall specifications for NFPA 805 requirements Fire System or Fire Impairment Log IROFS 50 Suspension Docs Memoranda of Understanding between City of Hobbs Fire Department and URENCO USA, October 15, 2018 Memoranda of Understanding between Lea Country and URENCO USA, October 5, 2015 Memoranda of Understanding between City of Eunice Police Department, Fire, and Rescue Services and URENCO USA, September 28, 2015 Memorandum GJL-2016-005, Completion of Operate While Construct Phase, February 1, 2016 NFPA 24, Standard for the Installation of Private Fire Service Mains and their Appurtenances, 1995 Edition Nuclear Criticality Safety, 2018 Continuing Training QR-SA-2018-004, Configuration Management Self-Assessment, December 30, 2018 7

RLR-16-001 50 Series IROFS Applicability During Operations, C. Slama, 1/25/2016 The license amendment request (LAR) 09-14, The 50 series of IROFS were suspended upon completion of major construction activities.

URENCO USA COO Organization Chart, May 17, 2019

5. ACRONYMS AND INITIALISMS ADAMS NRCs document system AHJ Authority Having Jurisdiction ANS American Nuclear Society CAAS Criticality Accident Alarm System CAP Corrective Action Program CFR Code of Federal Regulations CRDB Cylinder Receipt and Dispatch Building ECR Engineering Change Request EN Event Notification EOC Emergency Operation Center EP Emergency Preparedness EPIP Emergency Preparedness Implementing Procedure ERO Emergency Response Organization IMC Inspection Manual Chapter IP Inspection Procedure IROFS Items Relied on for Safety ISA Integrated Safety Analysis LES Louisiana Energy Services, LLC NCS Nuclear Criticality Safety NCSA Nuclear Criticality Safety Analysis NCV Non-Cited Violation NFPA National Fire Protection Association NRC U.S. Nuclear Regulatory Commission QA Quality Assurance QL Quality Level Rev. Revision SAR Safety Analysis Report SBM Separations Building Module UBC Uranium Byproduct Cylinder UF6 Uranium Hexafluoride URI Unresolved Item UUSA URENCO USA WO Work Order 8