ML20121A038
| ML20121A038 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 04/30/2020 |
| From: | Robert Williams NRC/RGN-II |
| To: | Beard B Global Nuclear Fuel |
| References | |
| IR 2020001 | |
| Download: ML20121A038 (14) | |
Text
April 30, 2020 Mr. Brad Beard Plant Leader Global Nuclear Fuel-Americas, L.L.C.
P.O. Box 708, Mail Code J20 Wilmington, NC 2842
SUBJECT:
GLOBAL NUCLEAR FUEL-AMERICAS, L.L.C. - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 70-1113/2020-001
Dear Mr. Beard:
The Nuclear Regulatory Commission (NRC) conducted inspections during the first quarter of calendar year 2020 (January 1 - March 31, 2020), at the Global Nuclear Fuel-Americas, L.L.C.
facility in Wilmington, NC. The purpose of these inspections was to determine whether activities authorized under the license in the area of Safety Operations were conducted safely and in accordance with NRC requirements. The inspections consisted of examinations of procedures and representative records, observations of activities, and interviews with personnel. The enclosed report presents the results of these inspections. At the conclusion of these inspections, the inspectors discussed the findings with you and members of your staff at an exit meeting held in person on January 30, 2020.
Based on the results of these inspections, the NRC has determined that no violations of more than minor significance were identified.
In accordance with Title 10 of the Code of Federal Regulations Section 2.390 of the NRC's "Rules of Practice and Procedure," a copy of this letter and 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 Web site at http://www.nrc.gov/reading-rm/adams.html.
B. Beard 2
Should you have any questions concerning the inspections, please contact Leonard Pitts of my staff at 404-997-4708.
Sincerely,
/RA/
Robert E. Williams Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 70-1113 License No. SNM-1097
Enclosure:
NRC Inspection Report 70-1113/2020-001 w/
Attachment:
Supplementary Information cc w/ encl: Distribution via LISTSERV
ML20121A038 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB2 RII:DFFI/PB1 RII:DFFI/PB2 NAME L. Pitts M. Ruffin N. Pitoniak D. Edwards R. Williams DATE 4/27/2020 4/28/2020 4/23/2020 3/24/2020 4/30/2020 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO
U. S. NUCLEAR REGULATORY COMMISSION REGION II INSPECTION REPORT Enclosure Docket No.:
70-1113 License No.:
SNM-1097 Report No.:
70-1113/2020-001 Enterprise Identifier: I-2020-001-0087 Licensee:
Global Nuclear Fuel - Americas, LLC Facility:
Global Nuclear Fuel - Americas Location:
Wilmington, North Carolina 28401 Dates:
January 1, 2020 to March 31, 2020 Inspectors:
N. Pitoniak, Senior Fuel Facility Inspector (Section A.1, B.1)
D. Edwards, Fuel Facility Inspector (Section A.2)
Approved by:
R. Williams, Chief Projects Branch 1 Division of Fuel Facility Inspection
EXECUTIVE
SUMMARY
2 Global Nuclear Fuel - Americas, LLC Nuclear Regulatory Commission Integrated Inspection Report 70-1113/2020-001 January 1 - March 31, 2020 Nuclear Regulatory Commission regional inspectors conducted inspections during normal shifts in the area of Safety Operations. During the inspections, normal production activities were ongoing. These announced, routine inspections consisted of a selective examination of licensee activities accomplished by direct observation of safety-significant activities and equipment, walkdowns of the facility, interviews and discussions with licensee personnel, and a review of facility records and procedures. There were no violations of more than minor significance identified during these inspections.
Safety Operations In the area of Operational Safety, no violations of more than minor significance were identified. (Section A.1)
In the area of Nuclear Criticality Safety, no violations of more than minor significance were identified. (Section A.2)
Other Areas (Closed) Confirmatory Order Section V, Item 4 GNF-A shall conduct an NSC assessment of the GNF-A organization by a third party independent of GNF-A who is experienced with NRC nuclear safety culture and safety conscious work environment policies. (Section B.1)
Attachment Key Points of Contact List of Items Opened, Closed, and Discussed Inspection Procedures Used Documents Reviewed
REPORT DETAILS 3
Summary of Plant Status Global Nuclear Fuel - Americas (GNF-A), LLC manufactures uranium dioxide (UO2) powder, pellets, and light water reactor fuel bundles at its Wilmington, NC facility. The facility converts uranium hexafluoride (UF6) to UO2 using a Dry Conversion Process (DCP) and performs fuel fabrication operations. During the inspections, normal production activities at the facility were ongoing.
A. Safety Operations
- 1. Plant Operations (Inspection Procedure 88020)
- a. Inspection Scope The inspectors evaluated the operational safety of the facility to verify the licensee operates the plant safely and in accordance with Title 10 Code of Federal Regulations (CFR) Part 70, the license, and the license application. The inspectors interviewed operators, engineers, laboratory technicians, and the laboratory manager, and reviewed records associated with UO2 furnaces (Node Group 405), the Gad furnaces (Node Group 504), and the Chemet laboratory (Node Group 805) to verify compliance with Chapter 3, Integrated Safety Analysis, and Chapter 11, Management Measures, of the license application. The inspectors reviewed license requirements, quantitative risk assessments, criticality safety evaluations, and operating procedures associated with the UO2 and Gad sintering furnaces and the Chemet laboratory (see enclosure) to verify the requirements for these areas were consistent within the licensees documents. The inspectors specifically evaluated the following IROFS to verify they were being implemented as described in the Integrated Safety Analysis (ISA):
IROFS 405-06/504-06 IROFS 405-07/504-07 IROFS 405-10 IROFS 405-11/504-08 IROFS 405-12/504-09 IROFS 405-13 IROFS 405-16/504-11 IROFS 405-18 IROFS 405-19/504-13 IROFS 405-20/504-14 IROFS 405-15/504-10 IROFS 900-01 IROFS 802-05 IROFS 805-02 IROFS 807-07
4 The inspectors performed walkdowns of the UO2 furnaces and the laboratories to verify the field configurations were maintained in accordance with the configuration control requirements of Chapter 11 of the license application. The inspectors walked down these systems and facilities to confirm the associated IROFS were present and capable of performing their intended safety functions as required by 10 CFR 70.62.
The inspectors evaluated engineered and administrative safety controls to verify they were capable of preventing or mitigating associated accident scenarios.
The inspectors reviewed furnace operating procedures to verify required actions for associated IROFS, as identified in the ISA Summary, had been transcribed into written operating procedures. The inspectors evaluated the procedures contents with respect to operating limits and operator responses to upset conditions to verify the limits needed to assure safety were described in the procedures.
The inspectors reviewed completed surveillances and functional test instructions of select IROFS (see enclosure) to verify management measures, as required by the ISA and Chapter 11 of the license application, were implemented and corrective actions were planned or taken for negative trends and failures.
The inspectors reviewed the licensees corrective action program (CAP) entries since the last operational safety inspection to verify deviations from procedures and unforeseen process changes affecting nuclear criticality, chemical, radiological, or fire safety were documented and reviewed promptly, per Section 5.3.2.6 of the license application. In addition, the inspectors reviewed the licensees corrective actions to verify they were adequate to address and resolve the issue as required per Chapter 11 of the license application.
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 Part 70, including Subpart H and Appendix A; Chapter 5, Nuclear Criticality Safety, of the license application; the licensees NCS manual; and applicable procedures. The inspectors reviewed selected criticality safety analyses (CSAs) and associated assumptions and calculations to verify they were consistent with the commitments in the license application, including the Double Contingency Principle and assurance of subcriticality under normal and credible abnormal conditions. The inspectors reviewed the accident scenarios outlined in the CSAs to determine whether process upsets analyzed in the CSAs remained highly unlikely with the application of IROFS.
5 The inspectors also reviewed the protection and prevention scores assigned to initiating events, active engineered IROFS, passive IROFS, and administrative controls documented for the respective scenarios in the ISA Summary to verify the licensee used the approved methodology outlined in their license application and procedures.
The CSAs reviewed were associated with the UO2 Furnace (Node Group 405), GAD Furnace (Node Group 504), and Chemet Laboratory (Node Group 805) and are listed in the supplementary information attached to this inspection report.
Criticality Implementation The inspectors performed walkdowns of the UO2 Furnace, and Chemet Laboratory to determine whether the existing plant configuration and operations were consistent with the process descriptions and safety bases in the selected CSAs. The inspectors reviewed process and system descriptions to verify engineered controls established in the CSAs were included and being implemented as specified. The inspectors reviewed the engineered controls in place to control mass, geometry, spacing, and moderation. The inspectors reviewed operating procedures and postings to verify selected administrative controls established in the CSAs were being implemented.
The inspectors interviewed operators, engineers, and laboratory staff to verify administrative actions established in the CSAs were understood and implemented as specified.
Criticality Operational Oversight The inspectors reviewed NCS audit reports to determine whether NCS staff routinely assessed field compliance with established NCS controls, interacted with operators, and entered issues identified during walkdowns into the CAP promptly. Additionally, the inspectors interviewed NCS management and reviewed audit procedures and schedules to verify qualified NCS engineers prepared for and performed the walkthroughs, ensuring the complete set of fissile material processing areas were assessed within two years as outlined in the Internal Nuclear Safety Audits procedure.
Criticality Programmatic Oversight The inspectors reviewed new and revised NCS program procedures, including WI 104-04, Nuclear Safety Design Criteria, to determine whether the licensee developed the NCS program in accordance with license requirements.
The inspectors reviewed the triennial nuclear criticality safety audit deliverable to verify the recommendations were entered in the CAP.
Criticality and Corrective Action The inspectors reviewed selected NCS-related CAP entries to verify conditions adverse to safety were promptly identified and entered into the CAP, that they received the required level of investigation, and were closed out in accordance with license commitments and procedures. The inspectors reviewed the associated corrective actions to verify they were documented and reviewed promptly, per Section 5.3.2.6 of the license application.
6 In addition, the inspectors reviewed selected corrective actions to verify they were adequate to address and resolve the issue as required per Chapter 11 of the license application and to verify the licensee followed regulatory requirements and procedures with regards to reporting plant conditions to the NRC. The CAP entries reviewed included CR 28961, CR 29781, and CR 32710.
b. Conclusion
No Violations of more than minor significance were identified.
B. Other Areas
- 1. Review of Confirmatory Order Section V Item 4 (Inspection Procedure 92703)
- a. Inspection Scope The inspectors reviewed the licensees actions regarding Confirmatory Order (CO)
Section V, Item 4 (ML17348A144), which required GNF-A to conduct a Nuclear Safety Culture (NSC) assessment of the GNF-A organization by a third party, independent of the GNF-A organization. The independent organization was required to be experienced with NRC nuclear safety culture and safety conscious work environment policies. GNF-A was required to compare the results of this assessment to the results of the assessment performed under Section III.3.g of the CO in an effort to identify trends. In addition, GNF-A was required to enter corrective actions from the assessment and comparison into the corrective action program, track them to completion, and make results of the final assessment and comparison available to the NRC for review. The inspectors reviewed the GNF-A NSC assessment conducted by an independent third-party organization in May-June 2019 and the subsequent final report submitted in August 2019. The inspectors reviewed the assessors background and determined they were experienced with the NRC nuclear safety and safety conscious work environment policies as required. The inspectors reviewed the comparison between the 2019 and 2017 NSC assessments and the resulting trends identified by GNF-A and determined the trends identified were sufficient and complete.
The inspectors interviewed the Fuels Environmental Health and Safety Manager and the Facility Manager and reviewed the corrective actions resulting from the comparison of the 2017 and 2019 NSC assessments and determined the corrective actions were adequate. The inspectors verified these corrective actions were entered, tracked, and documented in the corrective action program as required, specifically under CRs 27516, 33074, 33075, 33076, 33077, and 33277.
b. Conclusion
The inspectors determined the independent third party was experienced with the NRC nuclear safety and safety conscious work environment policies as required. The inspectors determined the trends identified from the comparison of the 2019 and 2017 NSC assessments were sufficient and complete and the established corrective actions were adequate. The inspectors determined that GNF-A has met the requirements as stated in the CO,Section V, Item 4. This item is considered closed.
7 C. 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 January 30, 2020 to B. Beard and staff. Proprietary information was discussed but not included in the report.
SUPPLEMENTARY INFORMATION Attachment
- 1. KEY POINTS OF CONTACT Licensee personnel Name Title B. Beard Facility Manager N. Buddin Laboratory Manager J. Degolyer Integrated Safety Analysis Engineer D. Eghbali Senior Criticality Safety A. Lang ISA Engineer M. Martin Area Engineer S. Murray Manager, Facility Licensing P. Ollis Facility Licensing L. Paulson Criticality Safety Program Manager J. Rohner Manager, Fuels EHS B. Stone ISA Manager
- 2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed CO Section V, Item 4 CO GNF-A shall conduct an NSC assessment of the organization using a third party independent of GNF-A who is experienced with NRC nuclear safety culture and safety conscious work environment policies. (Section B.1)
- 3. INSPECTION PROCEDURES USED 88015 Nuclear Criticality Safety 88020 Operational Safety 92703 Follow-up of Confirmatory Action Letters or Orders
- 4. DOCUMENTS REVIEWED Records:
- 1 Sintering Furnace Main Pusher Overload Shutdown Functional Test Instruction (FTI) completed 6/24/19
- 1 Sintering Furnace In-Out Logic Functional Test Instruction completed 6/24/19
- 2 Sintering Furnace Main Pusher Overload Shutdown Functional Test Instruction (FTI) completed 11/23/15
- 2 Sintering Furnace In-Out Logic Functional Test Instruction completed 11/23/15
- 3 Sintering Furnace Main Pusher Overload Shutdown Functional Test Instruction (FTI) completed 6/24/19
- 3 Sintering Furnace In-Out Logic Functional Test Instruction completed 6/24/19
2
- 4 Sintering Furnace Main Pusher Overload Shutdown Functional Test Instruction (FTI) completed 4/29/19
- 4 Sintering Furnace In-Out Logic Functional Test Instruction completed 11/25/19
- 5 Sintering Furnace Main Pusher Overload Shutdown Functional Test Instruction (FTI) completed 7/11/18
- 5 Sintering Furnace In-Out Logic Functional Test Instruction completed 8/29/19
- 6 Sintering Furnace Main Pusher Overload Shutdown Functional Test Instruction (FTI) completed 7/30/19
- 6 Sintering Furnace In-Out Logic Functional Test Instruction completed 7/24/18 2018 Nuclear Safety Audit - Engineering, Chemet and Environmental Labs, dated June 29, 2018 2Q19 Nuclear Safety Audit - Press Feed, rotary Press, Scrap Press, Gad DM-10/Tumble, Sinter Test Grind, Sintering Furnace, Boat Conveyors, Boat Storage, dated June 29, 2019 3Q18 Nuclear Safety Audit - UO2/GadGrind, Rod-Load, Weld, Pellet Storage, Rod Storage, dated October 4, 2018 3Q19 Nuclear Safety Audit - Node(s) 401-503; 405-504; 406-505, dated October 1, 2019 4Q19 Nuclear Criticality Safety Audit - DCP Vaporization, Conversion, Powder Outlet, Cylinder Handling and Storage, dated December 10, 2019 4Q19 Nuclear Safety Audit - Node(s) 301, 507, 801, 802, dated December 11, 2019 BGS-COR-0060, Global Nuclear Fuel-Americas, Purchase Order No. 900678423, 2019 Triennial Nuclear Criticality Safety Audit Deliverable, dated November 13, 2019 CSA-405.01.100, Sintering Furnaces, Rev. 6 CSA-805.00.100, Chemet Lab, Rev.1 CSA-805.03.100, Support Labs, Rev.00 CSA-CHEMET, Chemet Lab - General, Rev. 13 Inspection of DA Piping completed 4/25/19 Inspection of H2 Piping completed 9/22/19 IROFS 405-15/504-10, Flammable Gas Survey completed 1/13/20 IROFS 405-19/504-13, Natural Gas Line Inspection completed 4/30/19 IROFS 405-20/504-14, Natural Gas Line Survey completed 1/13/20 PHA-805, ISA Reference Report for the 805 Node Group, Rev. 6, dated July 16, 2019 QRA-805, Laboratory, Rev. 6, dated July 16, 2019 Procedures:
CP-18-104, EHS Regulatory Compliance Audits, Rev. 3.0, dated January 25, 2016 CP-18-202, Focused Self-Assessments, Rev.12.1, dated December 9, 2019 CP-20-103, Nuclear Safety Training, Rev. 2.1, dated August 14, 2019 OP 1001.00.000, Fabrication General, Rev. 00 OP 1001.00.100, Fabrication General - General Information, Rev. 16 OP 1001.00.101, Fabrication General - MC&A, Rev.03 OP 1001.00.201, Fabrication General - Operations, Rev. 05 OP 1001.00.202, Fabrication General - Abnormal Operations, Rev. 03 OP 1001.00.203, Fabrication General - Emergency Operations, Rev. 00 OP 1030.10.000, UO2 Sintering Furnaces 1, 3, 4, & 6, Rev. 00 OP 1030.10.100, UO2 Sintering Furnaces 1, 3, 4, & 6 - General Information, Rev. 06 OP 1030.10.101, UO2 Sintering Furnaces 1, 3, 4, & 6 - MC&A, Rev. 00 OP 1030.10.201, UO2 Sintering Furnaces 1, 3, 4, & 6 - Pre-Startup, Rev. 03 OP 1030.10.202, UO2 Sintering Furnaces 1, 3, 4, & 6 - Heat Up, Rev. 05 OP 1030.10.203, UO2 Sintering Furnaces 1, 3, 4, & 6 - Normal Operations, Rev. 07 OP 1030.10.204, UO2 Sintering Furnaces 1, 3, 4, & 6 - Shutdown, Rev. 06 OP 1030.10.205, UO2 Sintering Furnaces 1, 3, 4, & 6 - Alarm Response, Rev. 05
3 OP 1030.10.206, UO2 Sintering Furnaces 1, 3, 4, & 6 - Emergency Operations, Rev. 05 OP 1030.10.207, UO2 Sintering Furnaces 1, 3, 4, & 6 - Basic Operator Maintenance, Rev.
07 OP 1030.10.300, UO2 Sintering Furnaces 1, 3, 4, & 6 - Process Information, Rev. 05 OP 1030.20.000, UO2 Pellet Sintering Furnace #2, Rev. 00 OP 1030.20.100, UO2 Sintering Furnace #2 - General Information, Rev. 07 OP 1030.20.101, UO2 Sintering Furnace #2 - MC&A, Rev. 00 OP 1030.20.201, UO2 Sintering Furnace #2 - Pre-Startup, Rev. 03 OP 1030.20.202, UO2 Sintering Furnace #2 - Heat Up, Rev. 04 OP 1030.20.203, UO2 Sintering Furnace #2 - Normal Operations, Rev. 08 OP 1030.20.204, UO2 Sintering Furnace #2 - Shutdown, Rev. 04 OP 1030.20.205, UO2 Sintering Furnace #2 - Alarm Response, Rev. 04 OP 1030.20.206, UO2 Sintering Furnace #2 - Emergency Operations, Rev. 04 OP 1030.20.207, UO2 Sintering Furnace #2 - Basic Operator Maintenance, Rev. 05 OP 1030.20.300, UO2 Sintering Furnace #2 - Process Information, Rev. 05 OP 1030.30.000, UO2 Sintering Furnace #5, Rev. 00 OP 1030.30.100, UO2 Sintering Furnace #5 - General Information, Rev. 05 OP 1030.30.101, UO2 Sintering Furnace #5 - MC&A, Rev. 00 OP 1030.30.201, UO2 Sintering Furnace #5 - Pre-Startup, Rev. 02 OP 1030.30.202, UO2 Sintering Furnace #5 - Heat Up, Rev. 04 OP 1030.30.203, UO2 Sintering Furnace #5 - Normal Operations, Rev. 06 OP 1030.30.204, UO2 Sintering Furnace #5 - Shutdown, Rev. 04 OP 1030.30.205, UO2 Sintering Furnace #5 - Alarm Response, Rev. 02 OP 1030.30.206, UO2 Sintering Furnace #5 - Emergency Operations, Rev. 02 OP 1030.30.207, UO2 Sintering Furnace #5 - Basic Operator Maintenance, Rev. 03 OP 1030.30.300, UO2 Sintering Furnace #5 - Process Information, Rev. 03 OP 1070.40.200, Gad Sintering Furnace Room Flammable Gas Leak, Rev. 00 OP 1070.41.000, Gad Wellman Sintering Furnace, Rev. 00 OP 1070.41.100, Gad Wellman Sintering Furnace - General Information, Rev. 04 OP 1070.41.101, Gad Wellman Sintering Furnace - MC&A, Rev. 00 OP 1070.41.201, Gad Wellman Sintering Furnace - Pre-Startup, Rev. 01 OP 1070.41.202, Gad Wellman Sintering Furnace - Heat Up, Rev. 03 OP 1070.41.203, Gad Wellman Sintering Furnace - Normal Operations, Rev. 06 OP 1070.41.204, Gad Wellman Sintering Furnace - Shutdown, Rev. 03 OP 1070.41.205, Gad Wellman Sintering Furnace - Alarm Response, Rev. 02 OP 1070.41.206, Gad Wellman Sintering Furnace - Emergency Operations, Rev. 03 OP 1070.41.207, Gad Wellman Sintering Furnace - Basic Operator Maintenance, Rev. 03 OP 1070.41.300, Gad Wellman Sintering Furnace - Process Information, Rev. 02 OP 1070.42.000, Gad Harper Sintering Furnace, Rev. 00 OP 1070.42.100, Gad Harper Sintering Furnace - General Information, Rev. 04 OP 1070.42.101, Gad Harper Sintering Furnace - MC&A, Rev. 00 OP 1070.42.201, Gad Harper Sintering Furnace - Pre-Startup, Rev. 02 OP 1070.42.202, Gad Harper Sintering Furnace - Heat Up, Rev. 02 OP 1070.42.203, Gad Harper Sintering Furnace - Normal Operations, Rev. 07 OP 1070.42.204, Gad Harper Sintering Furnace - Shutdown, Rev. 03 OP 1070.42.205, Gad Harper Sintering Furnace - Alarm Response, Rev. 02 OP 1070.42.206, Gad Harper Sintering Furnace - Emergency Operations, Rev. 03 OP 1070.42.207, Gad Harper Sintering Furnace - Basic Operator Maintenance, Rev. 03 OP 1070.42.300, Gad Harper Furnace - Process Information, Rev. 02 OP 2310.00.400, CAAS Operating, Maintenance, Testing, and Response Procedure Detector Functionality, Rev. 03, dated November 16, 2018 WI-18-104-02, Internal Nuclear Safety Audits, Rev. 4.0, dated May 29, 2019
4 WI-27-104-02, EHS Administrative Action Guidelines, Rev. 0.3, dated December 2, 2019 WI-27-104-04, Nuclear Safety Design Criteria, Rev. 3.0, dated January 29, 2020 Condition Reports Written as a Result of the Inspection:
CR 33600 Condition Reports Reviewed:
CR 27516 CR 28961 CR 29781 CR 32710 CR 33074 CR 33075 CR 33076 CR 33077 CR 33277 Other Documents:
Comparison of 2017 and 2019 GNF-A Safety Culture Assessment Results GEH-GSC-0001, Controlled Access Area Training, Revised June 2016 NSE Audit Schedule 2019 PHA-805, ISA Reference report for the 805 Node Group, Rev. 6 QRA-805, Laboratory, Rev. 6 TD 805-02, HF Exposure Treatment Training Material, Rev. 0