|REQUIRED PROCEDURAL CONTROLS WERE NOT FOLLOWED
"Urenco USA is conservatively reporting a condition in that Uranic bearing material was placed into the Small Component Decontamination Train (SCDT) without meeting all conditions of IROFS54a and IROFS54b.
"IROFS54a and IROFS54b are Mass Controls that ensure the configuration of the SCDT remains sub-critical. Bookkeeping elements of the IROFS were performed correctly and the masses of the components were determined properly. However the visual inspection of the SCDT to ensure it is empty, prior to introducing components, was not performed in accordance with procedure instructions.
"The components were removed and the visual inspection was performed which confirmed the SCDT was in fact empty.
"The facility was and remains in a safe and stable configuration."
The licensee will notify NRC Region 2 tomorrow.
* * * RETRACTION ON 1/24/20 AT 1130 EST FROM BLAKE BIXENMAN TO RODNEY CLAGG * * *
"This event was determined to not be reportable.
"Consistent with NRC FCSS ISG-12, Rev 1, 10 CFR Part 70, Appendix A - Reportable Safety Events, UUSA has
concluded that EN54492 was not reportable. All situations where IROFS have failed or degraded are reportable
under Paragraphs (a)(4) or (b)(2), exceptions include the following: The capabilities of the degraded IROFS are
still sufficient to meet the performance requirements of 10 CFR 70.61.
"On 01-17-2020, UUSA completed a discharge of material to the slab tanks in the Liquid Effluent Collection
Treatment & Storage (LECTS) Room. Upon completion of decontamination activities in the SCDT, procedurally
required actions were performed to ensure all in process uranic material was removed and verification of the
uranic material hold-up value was still valid in accordance with IROFS54a&b. IROFS54a&b tags and locks were
then installed indicating the IROFS functions had been performed.
"On 01-22-2020, a new work evolution began which included bookkeeping measurements to ensure the
calculated mass of uranium was below the allowable threshold prior to introduction to the SCDT. In summary, all
requirements of the IROFS54a&b boundary were functionally complete and the capabilities of the degraded
IROFS remained sufficient to meet the performance requirements of 10 CFR 70.61."
Notified the R2DO (Coovert) and NMSS Events Notification (email)