ML18200A033

BWXT Nuclear Operations Group, Inc., NRC Integrated Inspection Report 07000027/2018003 Final

ML18200A033
Person / Time
Site:	BWX Technologies
Issue date:	07/18/2018
From:	Eric Michel NRC/RGN-II/DFFI
To:	Burch B BWXT
References
IR 2018003
Download: ML18200A033 (20)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 July 18, 2018 Mr. B. Joel Burch Vice President and General Manager BWXT Nuclear Operations Group, Inc.

P.O. Box 785 Lynchburg, VA 24505-0785

SUBJECT:

BWXT NUCLEAR OPERATIONS GROUP - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 70-27/2018-003

Dear Mr. Burch:

This letter refers to the inspections conducted from April 1 through June 30, 2018, at the BWXT Nuclear Operations Group, Inc. (NOG) facility in Lynchburg, VA. The inspections were conducted to determine whether activities authorized under the license were conducted safely and in accordance with U.S. Nuclear Regulatory Commission (NRC) requirements. The enclosed report presents the results of these inspections. The results were discussed with you and members of your staff at exit meetings held on May 17 and July 17, 2018.

During the inspections, NRC staff examined activities conducted under your license, as they related to public health and safety, to confirm compliance with the Commissions rules and regulations and with the conditions of your license. Areas examined during the inspections are identified in the enclosed report. Within these areas, the inspections consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. Based on the results of these inspections, 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, its enclosure, and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction.

B. Burch 2 If you have any questions concerning these inspections, please contact Noel Pitoniak of my staff at 404-997-4634.

Sincerely,

/RA/

Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 70-27 License No. SNM-42

Enclosure:

NRC Inspection Report 70-27/2018-003 w/

Attachment:

Supplementary Information cc:

Joel W. Duling, President BWXT Nuclear Operations Group, Inc.

2016 Mount Athos Road Lynchburg, VA 24505 Christopher T. Terry, Manager Licensing and Safety Analysis BWXT Nuclear Operations Group, Inc.

P.O. Box 785 Lynchburg, VA 24505-0785 Steve Harrison, Director Division of Radiological Health Department of Health 109 Governor Street, Room 730 Richmond, VA 23219

ML18200A033 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI/PB2 RII:DFFI/SB RII:DFFI/SB RII:DFFI/SB RII:DFFI/PB2 RII:DFFI/PB2 RII:DFFI/PB2 RII:DC SIGNATURE RA (feeder) RA (feeder) RA (feeder) RA (feeder) RA (feeder) RA (email) RA (email) RA (email)

NAME CStancil BAdkins DAnderson TGrice RWomack PGlenn NPitoniak NPitoniak DATE 07/14/2018 06/18/2018 06/18/2018 06/18/2018 06/18/2018 07/18/2018 07/18/2018 07/18/2018 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO YES NO U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No: 70-27 License No: SNM-42 Report No: 70-27/2018-003 Licensee: BWX Technologies, LLC (BWXT)

Facility: Nuclear Operations Group, Inc. (NOG)

Location: Lynchburg, VA 24505 Dates: April 1 through June 30, 2018 Inspectors: C. Stancil, Senior Resident Inspector, RII/DFFI/PB2 B. Adkins, Senior Fuel Facility Inspector, RII/DFFI/SB D. Anderson, Fuel Facility Inspector, RII/DFFI/SB T. Grice, Senior Fuel Facility Inspector, RII/DFFI/SB K. Womack, Fuel Facility Inspector, RII/DFFI/SB Approved by: E. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure

EXECUTIVE

SUMMARY

BWXT Nuclear Operations Group, Inc.

NRC Integrated Inspection Report 70-27/2018-003 April 1 - June 30, 2018 Inspections were conducted by the senior resident inspector and regional inspectors during normal and off-normal hours in safety operations, radiological controls, and facility support. The inspectors performed a selective examination of BWXT activities that were accomplished by direct observation of safety-significant activities and equipment, tours of the facility, interviews and discussions with BWXT personnel, and a review of facility records.

Safety Operations

• No violations of more than minor significance were identified related to Plant Operations and Safety System Walkdowns. (Paragraphs A.1 and A.2)

• No violations of more than minor significance were identified related to the Fire Protection Program. (Paragraphs A.3, A.4, and A.5)

• No violations of more than minor significance were identified related to the Nuclear Criticality Safety Program. (Paragraphs A.6 and A.7)

Radiological Controls

• No violations of more than minor significance were identified related to the Radiation Protection Program. (Paragraph B.1)

Facility Support

• No violations of more than minor significance were identified related to the Post-Maintenance Testing Program. (Paragraph C.1)

• No violations of more than minor significance were identified related to items entered into the Corrective Action Program. (Paragraph C.2)

• No violations of more than minor significance were identified related to the Plant Modifications Program. (Paragraph C.3)

• No violations of more than minor significance were identified related to the Emergency Preparedness Program. (Paragraph C.4)

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

REPORT DETAILS Summary of Plant Status During the inspection period, routine fuel manufacturing operations and maintenance activities were conducted in the fuel processing areas, Uranium Recovery (UR) facility, and in the Research and Test Reactors (RTR) facility.

A. Safety Operations

1. Plant Operations (Inspection Procedures 88135 and 88135.02)

a. Inspection Scope The inspectors performed routine tours of plant operating areas housing special nuclear material (SNM) to verify that equipment and systems were operated safely and in compliance with the license. Daily operational and shift turnover meetings were observed throughout the period to gain insights into process safety and operational issues. The inspectors reviewed selected BWXT-identified issues and corrective actions (CAs) for previously identified issues. These reviews focused on plant operations, safety-related equipment (valves, sensors, instrumentation, in-line monitors, and scales),

and items relied on for safety (IROFS) to determine whether BWXT captured off-normal events and implemented effective CAs as required.

The routine tours included walkdowns of the RTR, filler, UR areas, and other manufacturing areas where SNM was being processed. During routine tours, the inspectors observed that operators, front-line managers, maintenance mechanics, radiation protection staff, and process engineering personnel were knowledgeable of their duties and attentive to any alarms or annunciators at their respective stations. The inspectors observed activities during normal and upset conditions for compliance with procedures, and material station limits. The inspectors reviewed selected safety controls, including IROFS, to verify that they were in place, available, and functional to ensure proper control of SNM. The inspectors reviewed operator log sheets, operating procedures (OPs), maintenance records, and equipment and process changes to obtain information concerning operating trends and activities. The inspectors reviewed CAs to verify that BWXT actively pursued CAs for conditions requiring temporary modifications and compensatory measures.

The inspectors performed periodic tours of the outlying facility areas to verify that equipment and systems were operated safely and in compliance with the license. The inspectors focused on potential wind-borne missile hazards, potential fire hazards with combustible material storage and fire loading, hazardous chemical storage, the physical condition of bulk chemical storage tanks and piping, storage of compressed gas containers, and potential degradation of plant security features. In addition, the inspectors periodically toured or inspected BWXTs emergency response facilities to ensure the facilities were maintained in a readily available status.

During these tours, the inspectors also observed that the required NRC Form 3, Notice to Employees, was appropriately and conspicuously posted in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 19.11.

2 The inspectors attended various BWXT meetings, including the Change Review Board, and met periodically with plant senior management and licensing personnel throughout the inspection period to determine the overall status of the plant. The inspectors evaluated BWXTs response to significant plant issues and their approach to solving various plant problems in accordance with Quality Work Instruction (QWI) 2.1.3, Integrated Safety Analysis Methodology, QWI 14.1.4, Reporting Unusual Incidents, and QWI 14.1.10, Safety Evaluation of Unusual Incidents.

b. Conclusion

No violations of more than minor significance were identified.

2. Safety System Walkdown (Inspection Procedure 88135.04)

a. Inspection Scope The inspectors inspected Nuclear Material Control (NMC) and Material Control and Accounting Counters in the Recovery Drum Counting Area, safety-significant systems involved with the processing of SNM to verify compliance with the license and procedures. As part of the walkdowns, the inspectors verified as-built configurations matched approved plant drawings. The inspectors interviewed operators to verify that plant personnel were familiar with the assumptions and controls associated with the IROFS systems and instrumentation for maintaining plant safety as required. The inspectors also reviewed IROFS assumptions and controls to verify proper implementation in the field. The inspectors reviewed the related integrated safety analysis (ISA) to verify system abilities to perform functions were not effected by outstanding design issues, temporary modifications, operator workarounds, adverse conditions, or other system-related issues. The inspectors also reviewed the selected system to verify that there were no conditions that degraded plant performance including the operability of IROFS, safety-related devices, or other support systems essential to safety system performance.

To determine the correct system alignment, the inspectors reviewed procedures, drawings, related ISAs, and regulatory requirements such as 10 CFR 70.61, Performance Requirements. During the walkdowns, the inspectors verified the following as appropriate:

• controls in place for potential criticality, chemical, radiological, and fire safety hazards

• process vessel configurations maintained in accordance with nuclear criticality safety evaluations (NCSEs)

• correct valve position and potential functional impacts such as leakage

• electrical power availability

• major system components correctly aligned, labeled, lubricated, cooled, and ventilated

• hangers and supports correctly installed and functional

• lockout/tag-out program implemented per HS-11-01, Lockout/Tagout/Testing of Hazardous Energy Sources

• cabinets, cable trays, and conduits correctly installed and functional

• visible cabling in good material condition

• no interference of ancillary equipment or debris with system performance

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b. Conclusion

No violations of more than minor significance were identified.

3. Fire Protection Quarterly (Inspection Procedure 88135.05)

a. Inspection Scope The inspectors performed an inspection of Shop Bays 6 through 10 to verify compliance with the license and National Fire Protection Association (NFPA) 801, Standard for Fire Protection for Facilities Handling Radioactive Materials. The inspectors performed fire safety walkdowns and reviewed the fire detection and suppression capabilities in those areas, as applicable. The inspectors also reviewed relevant portions of the Pre-Fire Plan before and during the walkdowns to verify that key features identified on the Plan (e.g., sprinkler control valves) were in place in the field and that fire hazards that existed in the field were reflected in the Pre-Fire Plan. The inspectors reviewed the type of manual firefighting equipment that was provided to confirm that it was appropriate for the type of fire that could occur. Various fire barriers and doors were examined for proper maintenance and function and fire impairments reviewed for adequate compensatory actions as required.

Routine plant tours were conducted for other areas of the plant. The inspectors verified that housekeeping in the areas was sufficient to minimize the risk of fire and that transient combustibles were being adequately controlled and minimized as required.

b. Conclusion

No violations of more than minor significance were identified.

4. Fire Protection Annual (Inspection Procedure 88135.05)

a. Inspection Scope On April 7, 2018, the inspectors observed fire brigade training as part of BWXTs annual emergency team training program to verify compliance with the license and NFPA 600, Standard on Industrial Fire Brigades. The inspectors specifically observed drill coordinators start a planned fire in the burn building, initiate the fire brigade response, extinguish the fire, and conduct a performance critique afterwards. The inspectors observed fire brigade leader command and control, proper donning and use of turnout gear and self-contained breathing apparatus, sufficient availability of firefighting equipment, clear and effective radio communications, coordination of unnecessary personnel, investigation of the incident, and implementation of pre-planned strategies.

b. Conclusion

No violations of more than minor significance were identified.

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5. Fire Protection Annual (Inspection Procedure 88055)

a. Inspection Scope The inspectors reviewed BWXT procedures and toured plant areas containing safety controls to assess the condition of fire protection equipment, systems, and features as required by BWXT License Application Chapter 7, Fire Safety. The inspectors verified that flammable materials were stored in marked cabinets as specified in approved procedures and that housekeeping and the control of combustible materials were adequate and consistent with the approved procedures as required by Chapter 7.

The inspectors accompanied Industrial Health and Safety (IH&S) technicians while performing portable fire extinguisher inspections in order to verify that areas where portable fire extinguishers were credited as IROFS were being implemented and maintained as required by procedures and NFPA 10, Standard for Portable Fire Extinguishers. The inspectors reviewed the procedures for portable fire extinguisher use and inspection in order to verify that the intended safety function of IROFS were met. During walkdowns, the inspectors verified that conditions in the plant met the assumptions highlighted in the Safety Analysis Report (SAR) (SARs 15.22 and 15.23 in the Attachment) by observing sprinkler system locations, moderator controlled area markings, fire loadings, and high-efficiency particulate air (HEPA) filter certifications.

Following walkdowns, the inspectors also reviewed maintenance records for fire dampers credited as IROFS in order to verify that management measures were applied to the controls in order to meet their intended safety function. The inspectors accompanied IH&S technicians while performing monthly checks of sectional valves to verify the checks were performed as required and valves were locked in the correct positions. The inspectors reviewed records to verify fire hydrants were flushed and tested on an annual basis.

The inspectors reviewed audit reports performed by IH&S personnel to ensure that the facility is audited quarterly by IH&S staff. The inspectors verified that audits effectively identified deviations and captured them in BWXTs corrective action program (CAP).

The inspectors reviewed selected CAs to verify that issues were assigned the appropriate severity level and that completed CAs were adequate. The inspectors observed the annual test of the interlock between the heat detector and highly enriched uranium (HEU) hydraulic press to verify the interlock functioned properly and was tested at the required frequency. The inspectors verified that glove boxes were inerted with argon gas and equipped with oxygen monitors to ensure the internal atmosphere was maintained in a manner which would not support combustion. The inspectors interviewed operators to verify furnace over-temperature interlocks were tested on an annual basis.

The inspectors visited the emergency operations center (EOC) and security station in order to verify that up-to-date copies of the Pre-Fire Plan were maintained in the site EOC, emergency team station, security station, and emergency team radio room as required by Chapter 7 of the License Application.

The inspectors reviewed BWXTs fire protection system out-of-service/impairment records to verify that adequate compensatory measures had been put in place for out-of-service, degraded, or inoperable fire protection equipment, systems, or features.

5 The inspectors reviewed training records of IH&S operators as well as operators in the RTRT area in order to verify that annual fire extinguisher training was provided as required in section 2.1.14 of the license and by procedure.

b. Conclusion

No violations of more than minor significance were identified.

6. Nuclear Criticality Safety (Inspection Procedure 88135.02)

a. Inspection Scope The inspectors reviewed the nuclear criticality safety (NCS) program to verify compliance with BWXT License Chapter 5, Nuclear Criticality Safety; the Nuclear Criticality Safety Manual; and implementing procedures. The inspectors conducted daily production area tours to verify various criticality controls, including the implementation of criticality station limit cards and container sizing to minimize potential criticality hazards as required. The inspectors reviewed a number of criticality-related IROFS to verify operability. The inspectors also interviewed and observed operators to verify knowledge of requirements associated with NCS IROFS.

As part of routine day-to-day activities onsite, the inspectors reviewed CAP entries associated with criticality safety aspects. The inspectors evaluated BWXTs response to such entries and, if needed, had discussions with NCS engineers to determine safety significance and compliance with procedures.

b. Conclusion

No violations of more than minor significance were identified.

7. Nuclear Criticality Safety (Inspection Procedure 88015)

a. Inspection Scope Criticality Analysis The inspectors reviewed selected NCS analyses to verify that they were consistent with the commitments in the license including consideration of the double contingency principle, assurance of sub-criticality under normal and credible abnormal conditions with the use of sub-critical margin, technical practices and methodologies, and treatment of NCS parameters. The NCSEs reviewed are listed in the Attachment and focused on RTRT fuel powder and compact processes.

The inspectors reviewed BWXTs generation of accident sequences to determine whether the analyses systematically identified normal and credible abnormal conditions in accordance with the commitments and methodologies in the license for the analysis of process upsets. This included the review of accident sequences/upsets that BWXT determined to be not credible to determine whether the bases for incredibility were consistent with the commitments, definitions, and methodologies in the license and were documented in sufficient detail to permit an independent assessment of credibility.

Additionally, the inspectors reviewed selected accident sequences designated as not

6 credible to determine whether the bases for incredibility relied on any items which should be identified as formal NCS controls or IROFS.

The inspectors verified no changes were made to the validation report since the last NCS inspection.

Criticality Implementation The inspectors performed walkdowns of the RTRT area to determine whether existing plant configuration and operations were consistent with the process description and safety basis in the selected criticality analyses listed in the Attachment. The NCS controls reviewed included mass logs, moderator logs, piece count, geometry, and spacing. The inspectors reviewed OPs and postings to verify that selected administrative controls were properly implemented. The inspectors interviewed operators, engineers, and maintenance personnel to verify that controls established in the criticality analyses were understood and properly implemented. The inspectors reviewed the ISA summary and supporting ISA documentation to determine whether the controls identified in the ISA were supported by technical bases in the NCS analyses.

The inspectors reviewed nondestructive assay (NDA) procedures for the in-line monitor #3 to ensure they contained adequate guidance for conducting NDA activities.

The inspectors reviewed records to verify that BWXT was completing NDA at the prescribed frequency. The inspectors verified that the NDA instruments were properly calibrated.

Criticality Operational Oversight The inspectors reviewed NCS-related training records and material to determine whether operator training included instruction in criticality hazards and control methods.

Additionally, the inspectors interviewed operations staff to determine whether they were cognizant of NCS hazards and control methods as they relate to their specific job function. The NCS-related training records reviewed included general employee safety training, annual refresher training, as well as specialized NCS training for various areas.

The inspectors reviewed the applied management measures for selected NCS controls to determine whether the management measures were sufficient to ensure the availability and reliability of NCS controls. The management measures and NCS controls reviewed were selected from the NCSEs listed in the Attachment and included controls on geometry, spacing, piece count, and moderation, as well as selected management measures for these controls such as maintenance and calibration, procedures, postings, and configuration control.

Criticality Programmatic Oversight The inspectors interviewed operations staff to determine whether they were cognizant of NCS hazards and control methods as they relate to their specific job function. The inspectors reviewed records of recent NCS audits and accompanied a BWXT NCS engineer on a weekly inspection of the hot area drain system to determine whether NCS staff routinely assesses field compliance with established NCS controls. The inspectors reviewed quarterly audit reports of the NCS program to verify that the audits met the requirements of the license with respect to frequency and scope. The inspectors verified

7 that audit findings were entered into BWXTs CAP for resolution. The inspectors reviewed the results of weekly NCS inspections to verify they were conducted at the prescribed frequency including backshifts and weekends. The inspectors verified that NCS staff performing the audits were qualified in accordance with NCS staff qualification requirements.

The inspectors conducted interviews and reviewed records to determine whether NCS staff reviewed new and/or revised fissile material operations and procedures including maintenance plans consistent with program procedures and at a level commensurate with their significance. The inspectors reviewed selected NCS analyses to verify that they were performed in accordance with NCS program procedures and received appropriate independent review and approval. The inspectors reviewed records to verify that NCS staff members only performed those functions for which they were qualified.

The inspectors verified no changes were made to applicable NCSE procedures since the last NCS inspection.

Criticality Incident Response and Corrective Action The inspectors reviewed test records to verify that BWXT performed periodic testing of the criticality accident alarm system (CAAS) and howlers. The inspectors reviewed various aspects of the CAAS to determine whether the features met regulatory requirements and license commitments. The inspectors reviewed test records to determine whether alarm signals were audible within the areas required to be evacuated. The inspectors reviewed records and interviewed cognizant BWXT staff to determine whether CAAS detector operability was maintained including whether detectors were calibrated, whether all components were functionally tested, whether alarm set points were set to promptly actuate upon detecting the minimum accident of concern, and whether access to alarm set points was strictly controlled.

The inspectors reviewed selected NCS-related CAP entries to determine whether anomalous conditions were promptly identified and entered into the CAP, whether they received the appropriate level of investigation consistent with license commitments and procedures, whether proposed CAs were sufficiently broad, whether they were prioritized on a schedule commensurate with their significance, and whether they were completed as scheduled and were adequate to prevent recurrence. The inspectors reviewed NCS-related CAP entries to assess compliance with NRC reportability.

b. Conclusion

No violations of more than minor significance were identified.

B. Radiological Controls

1. Radiation Protection Quarterly (Inspection Procedure 88135)

a. Inspection Scope The inspectors performed a review and observation of posted radiologically controlled areas to verify compliance with BWXT License Chapter 4, Radiation Safety; the Radiation Protection Manual; and implementing procedures. The inspectors reviewed the following radiation work permits (RWPs) to observe radiation barriers, postings, work

8 instructions, appropriate personnel protective equipment and management oversight, and that workers signed the RWPs. In addition to the detailed review noted above, the inspectors performed numerous partial reviews of RWPs during the inspection period in different operational areas.

• RWP 18-12, Leak Test Retention Tank Manual Valves

• RWP 18-35, Splitting of Treatment Plant 55 Gallon Drums >100 g

• RWP 18-42, RTR Mezzanine HVAC HEPA and Pre-Filter Change Out

• RWP 18-43, CA 2018-0469, SFF Vault Legacy Bottles Require Repackaging or Wrapping for Storage

• RWP per OP-61234, "Maintenance in UPRR for Recovery Pump Maintenance The inspectors reviewed BWXTs radiation protection program to verify compliance with 10 CFR 20, Standards for Protection Against Radiation, and license requirements. The inspectors toured the controlled areas to verify that radiological signs and postings accurately reflected radiological conditions within the posted areas. The inspectors observed plant personnel as they removed protective clothing at controlled area step-off pads and as they performed various tasks to verify that proper protective equipment was used to prevent contamination. The inspectors also observed plant employees as they performed exit monitoring at the controlled areas exits to verify that monitoring instructions were followed at the exit point.

b. Conclusion

No violations of more than minor significance were identified.

C. Facility Support

1. Post-Maintenance Testing (Inspection Procedure 88135.19)

a. Inspection Scope The inspectors witnessed and reviewed the post-maintenance tests (PMTs) listed below to verify that procedures and test activities confirmed safety systems and components (SSCs) operability and functional capability following the described maintenance. The inspectors reviewed BWXTs completed test procedures to ensure any of the SSC safety function(s) that may have been affected were adequately tested, that the acceptance criteria were consistent with information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved.

The inspectors also witnessed and/or reviewed the test data to verify that test results adequately demonstrated restoration of the affected safety function. The inspectors verified that PMT activities were conducted in accordance with applicable work order (WO) instructions or licensee procedural requirements. Furthermore, the inspectors verified that problems associated with PMTs were identified and entered into BWXTs CAP.

• WO 20230436 for SER 17-26 Phase 1 Recovery Evaporator 2 Test Plan per Maintenance Plan (MP) 3348, Annual Replacement; MP 3366, Evaporator 2 Heat Exchanger Integrity; and MP 3161, Evaporator 2 Condenser Integrity

• WO 20240859 for Peristaltic Tube Assembly Replacement and testing per MP 4321

• WO 20240998, Scrubber Pump Is In Alarm for scrubber pump repair and leak test

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b. Conclusion

No violations of more than minor significance were identified.

2. Corrective Action Program (Inspection Procedure 88135)

a. Inspection Scope The inspectors reviewed a sample of items entered into BWXTs CAP during the inspection period to ensure that entries pertinent to safety, security, and non-conforming conditions were identified, investigated, and tracked to closure. The inspectors conducted interviews with BWXT staff and reviewed documents to verify that issues of high-safety significance were identified and reviewed for apparent causes as required.

The inspectors reviewed issues requiring extent-of-condition and/or extent-of-cause reviews to verify that the reviews were completed and documented in the applicable CA.

The inspectors also reviewed CAs to prevent recurrence of previous issues to verify that they were identified in the CAP and were reviewed and tracked to completion in accordance with implementing procedure, QWI 14.1.1, Preventive/Corrective Action System, Revision (Rev.) 34.

Furthermore, the inspectors conducted periodic reviews of BWXT audits and third party reviews of safety-significant processes to determine their effectiveness and necessary entries into the CAP. Specifically the inspectors reviewed the following:

• 29 CFR 1910.147 Lockout/Tagout Review Conducted at BWXT Mt Athos Site, February 2018

• LMS-2018-001, Radiation Protection Audits, Inspections 4th Quarter 2017, March 26, 2018

• LMS-2018-002, Radiation Protection Audits, Inspections 1st Quarter 2018, April 25, 2018

• BWXT Management Observation Program, March 7, 2018

• NCS-2018-74, NCS Violation and Observation Summary 1st Quarter 2018, May 10, 2018

b. Conclusion

No violations of more than minor significance were identified.

3. Permanent Plant Modifications (Inspection Procedure 88135.17)

a. Inspection Scope The inspectors reviewed the risk-significant plant modification SER 17-10, Phase 1, Bay 14A Chop Shop Behringer Saw for compliance with the license and the requirements of 10 CFR 70. Specifically, the inspectors evaluated the impacts to associated IROFS and ISA accident sequences in the selected modifications. The inspectors conducted field walkdowns of portions of the modification to validate that the as-found plant configurations were in alignment with the change request documentation and to evaluate the material condition of any associated IROFS. In addition, the inspectors reviewed updates and changes to the ISA/SAR (safety analysis report) and procedures affected by the modifications, as applicable.

10 The inspectors reviewed the change request packages for accuracy and adherence to BWXTs change management process, QWI 5.1.12, Change Management. The inspectors verified that applicable post-maintenance installation and testing requirements were identified in the change request documentation as required. The inspectors verified that BWXT identified and addressed any impacts to the ISA/SAR resulting from modifications.

b. Conclusion

No violations of more than minor significance were identified.

4. Emergency Preparedness (Inspection Procedure 88135)

a. Inspection Scope On June 28, 2018, BWXT conducted its annual evacuation drills for all employees on all three shifts. Inspectors conducted pre-drill walkdowns of the new evacuation areas and interviews with licensee coordinators to verify compliance 10 CFR 70. Inspectors participated in the evacuation and observed alarms and alarm response of BWXT employees. Specifically, the evacuation exercise was intended to identify any BWXT weaknesses and deficiencies in employee notification and response to evacuation alarms and preplanned evacuation routes in accordance with BWXTs Emergency Plan, Emergency Preparedness (EP) Manual, and licensee conformance with other applicable emergency plan implementing procedures. The inspectors reviewed the post-exercise summary and lessons learned to determine whether BWXT staff were properly identifying EP-related issues and entering them into the CAP, as required.

b. Conclusion

No violations of more than minor significance were identified.

E. Exit Meeting On May 17 and July 17, 2018, the inspectors presented the inspection results to Mr. B. J. Burch and members of the BWXT staff. No dissenting comments were received from BWXT. Proprietary information was discussed, but not included in the report.

1 SUPPLEMENTAL INFORMATION

1. KEY POINTS OF CONTACT Licensee Personnel Name Title J. Burch Vice President and General Manager J. Calvert Environmental, Safety, Health, and Security Program Manager M. Edstrom Fire Protection Engineer D. Faidley Nuclear Criticality Safety Manager V. Mauney Department Manager, UPRR L. Morrell Environmental Protection & Industrial Safety Manager L. Ragland Unit Manager, Recovery and Maintenance A. Rander Security Manager C. Reed Operations Manager H. Shaffer Engineering Manager D. Spangler Section Manager, Nuclear Safety and Licensing C. Terry Unit Manager, Licensing and Safety Analysis D. Ward Department Manager, Environmental, Safety, Health, and Safeguards

2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED None

3. INSPECTION PROCEDURES USED 88015 Nuclear Criticality Safety 88055 Fire Protection Annual 88135 Resident Inspection Program for Category I Fuel Cycle Facilities 88135.02 Plant Status 88135.04 ISA Implementation 88135.05 Fire Protection 88135.17 Permanent Plant Modifications 88135.19 Post-Maintenance Testing Attachment

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4. DOCUMENTS REVIEWED Drawings Development Drawing Figure 3.5 LLR Treatment System ML-S1B-PAUT-981, Hot Sectioning Layout, Rev. 0 Sketch LLR Wastewater from Lynchburg Technology Center UPRR-30053, Recovery Evaporators 2, 3, 4, and 5, Rev. 1 UPRR-30125, Evaporators 2-6 System Assembly and Parts WTRT-6000, BWXT Waste Treatment Retention Tank Area System P&ID, Rev. B Records Calibration Reports DCC16 Drum Counter Calibrations, dated April and May 2016 HS-2017-054, Hydrant Flows 2017 dated July 10, 2017 ISAP 97-00338, Fire Loading Calculation for Fire Area 15-1 ISAP 97-00339, Fire Safety Analysis - Ignition Sources for PHA-13 ISAP 97-00341, Fire Loading Calculation for Fire Area 16-1 Lockout/Tagout Permit for Work Order 31162, Retention Tank Valve Replacement, dated February 8, 201823 NCS-1986-038, ATR Compacts at Work Stations in Lots of 24 dated April 28, 1986 NCS-1992-264, HEU Compact Line - 235 Moderating Material dated November 14, 1992 NCS-1993-213, Modify Type 65 through 75 Compact Dimensions dated September 30, 1993 NCS-1997-135, NCS Analysis for SER 97-59, Relocation of Drum Counter, dated July 21, 1997 NCS-2011-083, NCS Justification to Close-Out SAR 15.20 IROFS Verification Corrective Actions dated September 13, 2011 NCS-2011-196, SARs 15.20 and 15.21 E-600 Posting Updates (CR-1037183) dated November 30, 2011 NCS-2014-105, NCS Safety Analysis to Revise NCS Posting for the RTR Compact Glovebox Line per CR-1042967 dated July 24, 2014 NCS-2016-033, Qualification of T. Lotz as an NCS Engineer dated March 28, 2016 NCS-2017-164, SCALE 6.1, Verification for Windows 7 Workstation ESH-452 dated October 5, 2017 NCS-2017-164, SCALE 6.1, Verification for Windows 7 Workstation ESH-468 dated September 21, 2017 NCS-2018-010, NCS Analysis to Increase NCS Limits on RTR LEU Target Powder Glovebox Line per SER 18-002 Phase 01 dated January 25, 2018 NCS-2018-015, Revised NCS Analysis Supporting Revised SER 17-034 Phase 01 -

Install New LEU UALx Target Press Glove Box, February 5, 2018 NCS-2018-018, Safety Concern Analysis for a U-Moly Fuel Can Placed on a Pharmacy Work Table 2018 NCS-2018-019, Safety Concern Analysis for Solution in a Plastic Bag Waste Column Tube dated April 18, 2018 NCS-2018-041, Safety Concern Analysis for Uncontrolled Discharge of Plant Retention Tank to WTF dated March 7, 2018 NCS-2018-059, Nuclear Safety Release Supporting SER 17-034 Phase 01 - New 150-Ton Hydraulic Compacting Press and Associated LEU UALx Target Press Glove Box dated April 23, 2018 NCSE-02, Nuclear Criticality Safety Analyses & Quality Assurance Reviews, Rev. 45 NCSE-03, Nuclear Criticality Safety Audits and Inspections, Rev. 28

3 NCSE-07, Qualification and Training Requirements for a Nuclear Criticality Safety Engineer, Rev. 17 NCSE-11, Verification and Validation of Computer Codes Used for Nuclear Criticality Safety Analyses, Rev. 07 RP-07-103, Form 1, Sounding of the Building Evacuation System dated April 26, 2017 RP-07-103, Form 4, Functionality Test of Speakers and NAWLS completed December 29, 2017 RP-07-104, Form 1, NOG-L CIDAS MkXI Criticality System Calibration dated May 2, October 23, and December 27, 2017 RP-07-104, Form 2, Security Notification of CIDAS Annual Criticality Monitoring System Logic Check dated December 27, 2017 RPTWR 04-014, Evaluation of a Glove Box Fire to Environmental and Occupational 10 CRF 10.61 Limits RWP 18-12, Leak Test Retention Tank Manual Valves RWP 18-13, Cleanup of Spill from Recovery Bay 15A Floor RWP 18-35, Splitting of Treatment Plant 55 Gallon Drums >100 g RWP 18-42, RTR Mezzanine HVAC HEPA Filter Change Out RWP 18-43, CA 2018-0469, SFF Vault 2.5 Liter Legacy Bottles Require Repackaging or Wrapping for Storage SER 17-26, Phase 1 Recovery Evaporator Upgrades - Evaporator 2 Upgrade Work Order 20240859, Maintenance Plan 4321, HF Pump Perist Tube Assembly Work Order 20240998, Recovery Scrubber Pump Repair Procedures E 41-25, Operating Instructions for the Drum Counter, Rev. 39 E 46-79, Operation of Well Counter Systems, Rev. 24 EP-313, General Maintenance for Low-Level Radioactive Waste Treatment Operations, Rev. 12 EP-321, Sampling, Analysis, Reporting, and Release of Retention Tanks for Dynamic U235 Inventory, Rev. 22 HS-03-02, Fire Prevention, Rev. 7 HS-03-03, Ignition Source Permits, Rev. 19 HS-03-04, Electrical Appliance Control, Rev. 9 HS-03-05, Control of Flammable and Combustible Liquids, Rev. 6 HS-03-06, Combustible Metals and Pyrophoric Materials, Rev. 12 HS-03-07, Control of Systems and Equipment for Fire Protection, Rev. 3 HS-03-08, Employee Fire Response and Firefighting, Rev. 7 HS-03-10, Control of Fire Protection Systems Impairments, Rev. 17 HS-11-01, Lockout/Tagout/Testing of Hazardous Energy Sources, Rev.14 HS-FP-006, Portable Fire Extinguishers Inspection, Rev. 12 HS-FP-007, Fire Hydrant Testing and Maintenance, Rev. 6 HS-FP-009, Inspection of Fire Hydrants, Rev. 8 HS-FP-018, Fire Barrier/Fire Damper Inspection, Rev. 11 HS-OP-014, Quarterly General Safety Audits, Rev. 17 OP-0001167, Spill and Leak Handling Emergency, Rev. 33 OP-0061169, Housekeeping and Decontamination in Uranium Recovery Facility, Rev. 11 OP-0061234, Maintenance in UPRR, Rev. 54 OP-0061242, Operating Procedure for In-Line Monitoring System, Rev. 32 OP-1001077, Operating Procedure for Vacuum Furnace Testing for RTRT Contaminated Area

4 OP-1001089, Calculation for U-235 for HEU and LEU Cleanup (U), Rev. 2 OP-1014829, NR Sectioning Bay 14A, Rev. 6, OP-1038057, Operating Procedure for Operation of the NMC Mini-SGS System, Rev. 3 OP-1046241, Operating Procedure for Net Weight/Moderator Spreadsheet in RTR (U),

Rev. 0 QWI 2.1.3, Integrated Safety Analysis Methodology, Rev. 16 QWI 5.1.12, Change Management, Rev. 31 QWI 14.1.1, Preventive/Corrective Action System, Rev. 34 QWI 14.1.4, Reporting Unusual Incidents, Rev. 12 QWI 14.1.10, Safety Evaluation of Unusual Incidents, Rev. 16 QWI 18.1.4, RTRT Personnel Training and Qualification, Rev. 4 RP-07-009, Environmental Air Sampler Flow Meter Calibration, Rev. 9 RP-07-103, Maintaining and Testing of the CIDAS MkXI Criticality Monitoring System, Rev. 7 Other Documents 2017 NCS Annual Refresher Training dated August 15, 2017 BWXT Nuclear Operations Group, Inc. License Number SNM-42, Docket No. 70-27, Amendment 26 CHG-4382, Design and Installation of a New Drum Counter Facility Siting Review 5, Bays 1A, 4A, through 10A and 12A, and Bays 2 through 13, Rev. 3 Maintenance Plan 4213 Management Observation Program Slide Presentation, dated March 7, 2018 NCS General Safety Training dated April 2011 NCS Weekly Inspection Form Procedure: NCSE-03 Inspections October 4 to December 19, 2017; and January 3 to March 28, 2018 Nuclear Criticality Safety Training: Annual 2017 Annual Refresher, dated August 15, 2017 Nuclear Criticality Safety Training: General Training, dated April, 2011 Nuclear Criticality Safety Weekly Inspection form Procedure: NCSE -03 Inspections October 4 thru December 19, 2017 and January 3 thru March 28, 2018 Pre-Fire Plan, Section 5, Bay 5 & 6, Machine Shop, dated 1/3/11 Pre-Fire Plan, Section 6, Bay 7 Component Storage and X-Ray, dated 2/17/10 Pre-Fire Plan, Section 7M, Bay 9 and 2T Mezzanine, dated 4/3/14 Pre-Fire Plan, Section 8, Bays 8, 9, and 10, dated 6/5/14 Requirements and Expectations for Mass Moderator Control, October 2015 SAR 15.5, High-Level Dissolution Process in Uranium Recovery, Rev. 136 SAR 15.6, Low-Level Dissolution Process in Uranium Recovery, Rev. 72 SAR 15.9, Main Extraction and Drum Dryer Process in Uranium Recovery, Rev. 99 SAR 15.20, 235U Counting Process in Nuclear Materials Control Operations, Rev. 45 SAR 15.21, Low-Level Radioactive Waste Processes, Waste Operations, Rev. 72 SAR 15.22, RTRT Fuel Powder and Compact Processes, Rev. 84 SAR 15.22, RTRT Fuel Powder and Compact Processes, Rev. 86 SAR 15.23, Fuel Plate and Element Fabrication Processes RTRT Operation, Rev. 102 SAR 15.37, Higher Tier Assemblies, Rev. 126 Weekly Inspection Schedule for 4th Quarter 2017 dated October 2, 2017 Weekly Inspection Schedule for 1st Quarter 2018 dated December 20, 2017 Corrective Actions 2012-3320

5 2017-0253 2017-0261 2017-0672 2017-0673 2017-0678 2017-0739 2017-0786 2017-0895 2017-1079 2017-1179 2017-1200 2017-1586 2018-0003 2018-0065 2018-0076 2018-0091 2018-0187 2018-0207 2018-0208 2018-0297 2018-0473 2018-0575 2018-0579 2018-0615 2018-0668 2018-0670 2018-0679 2018-0684 2018-0706 2018-0730