ML18211A448

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Nuclear Fuel Services, Inc. - U.S. Nuclear Regulatory Commission Integrated Inspection Report Number 07000143/2018003
ML18211A448
Person / Time
Site: Erwin
Issue date: 07/30/2018
From: Robert Williams
NRC/RGN-II
To: Stewart J
Nuclear Fuel Services
References
IR 2018003
Download: ML18211A448 (21)
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Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 July 30, 2018 Mr. John A. Stewart President Nuclear Fuel Services, Inc.

P. O. Box 337, MS 123 Erwin, TN 37650

SUBJECT:

NUCLEAR FUEL SERVICES, INC. - U. S. NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT NUMBER 70-143/2018-003

Dear Mr. Stewart:

This letter refers to the inspections conducted from April 1 to June 30, 2018, at the Nuclear Fuel Services, Inc. (NFS) facility in Erwin, TN. The purpose of these inspections was 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 the inspections. The findings were discussed with members of your staff at the exit meetings held on June 28, 2018 and after the end of the quarter on July 24, 2018.

During the inspections, NRC staff examined activities conducted under your license, as they related to public health and safety and to confirm compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspections consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. The inspections covered the following areas: safety operations, radiological controls, facility support, and other areas.

Based on the results of these inspections, no cited violations or deviations 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.

J. Stewart 2 Should you have any questions concerning these inspections, please contact Leonard Pitts of my staff at 404-997-4708.

Sincerely,

/RA/

Robert E. Williams, Jr. Acting Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No.70-143 License No. SNM-124

Enclosure:

NRC Inspection Report 70-143/2018-003 w/

Attachment:

Supplemental Information cc: (See page 3)

J. Stewart 3 cc:

Jon A. Hagemann Operations Director Nuclear Fuel Services, Inc.

Electronic Mail Distribution Richard J. Freudenberger Safety & Safeguards Director Nuclear Fuel Services, Inc.

Electronic Mail Distribution Debra G. Shults Director, TN Dept. of Environment & Conservation Electronic Mail Distribution Doris D. Hensley Mayor, Town of Erwin 211 N. Main Avenue P.O. Box 59 Erwin, TN 37650 Greg Lynch Mayor, Unicoi County P.O. Box 169 Erwin, TN 37650 Johnny Lynch Mayor, Town of Unicoi P.O. Box 39 Unicoi, TN 37692 David W. Deming Manager, Program Field Office - NFS Naval Nuclear Laboratory 1205 Banner Hill Rd Erwin, TN 37650

ML18211A448 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

NAME LHarris LPitts CRivera-Crespo MCrespo TSippel NPeterka KMcCurry DATE 7/25/2018 7/25/2018 7/25/2018 7/25/2018 7/25/2018 7/25/2018 7/25/2018 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70-143 License No.: SNM-124 Report No.: 70-143/2018-003 Licensee: Nuclear Fuel Services, Inc.

Facility: Nuclear Fuel Services, Inc.

Location: Erwin, TN 37650 Dates: April 1 through June 30, 2018 Inspectors: L. Harris, Senior Resident Inspector C. Rivera-Crespo, Fuel Facility Inspector M. Crespo, Senior Fuel Facility Inspector T. Sippel, Fuel Facility Inspector N. Peterka, Fuel Facility Inspector K. McCurry, Fuel Facility Inspector Approved by: R. Williams, Jr., Acting Chief Projects Branch 1 Division of Fuel Facility Inspection

EXECUTIVE

SUMMARY

Nuclear Fuel Services, Inc.

NRC Integrated Inspection Report 70-143/2018-003 April 1 - June 30, 2018 Inspections were conducted by the resident and regional inspectors during normal and off-normal hours in safety operations, radiological controls, effluent control and environmental protection, transportation, as well as other areas. The inspectors performed a selective examination of licensee activities that was accomplished by direct observation of safety-significant activities and equipment, tours of the facility, interviews and discussions with licensee personnel, and a review of facility records. No safety significant findings were identified during this inspection.

Safety Operations

  • Plant operations were performed safely and in accordance with license requirements. Items relied on for safety (IROFS) were properly implemented and maintained in order to perform their intended safety function. (Paragraphs A.1 and A.2)
  • The Nuclear Criticality Safety (NCS) Program was properly implemented and maintained in order to assure that normal and credible abnormal conditions remained subcritical as required by license and regulatory requirements. Criticality analysis demonstrated double contingency and adequate control of NCS parameters. (Paragraphs A.3 and A.5)
  • The Fire Protection (FP) Program and systems were adequately maintained in accordance with the license application and regulatory requirements. (Paragraph A.6)

Radiological Controls

  • The licensee adequately implemented the Radiation Protection (RP) Program consistent with the license application and regulatory requirements. (Paragraph B.1)

Facility Support

  • The post maintenance testing and surveillance programs were implemented in accordance with the license application and regulatory requirements for work control and safety-related equipment testing. (Paragraphs C.1 and C.2)
  • Adverse conditions were adequately identified, evaluated, and entered into the Corrective Action Program. (CAP) (Paragraph C.3)
  • The Plant Modifications Program was implemented in accordance with the license application and regulatory requirements (Paragraph C 5).

11 Other Areas Violation 70-143/2018-002-01, Failure to Meet Criticality Accident Alarm System Requirements, was closed.

Attachment:

Supplemental Information

REPORT DETAILS Summary of Plant Status The following facility process areas were operating during the inspection period: Naval Fuel Manufacturing Facility (FMF) and the Blended Low Enriched Uranium (BLEU) Preparation Facility (BPF) which includes the Uranium (U)-Metal, U-Oxide, Solvent Extraction and the down-blending lines.

A. Safety Operations

1. Plant Operations Routine (Inspection Procedures (IPs) 88135 and 88135.02)
a. Inspection Scope The inspectors performed routine tours of the fuel manufacturing areas housing Special Nuclear Material (SNM), reviewed log sheets, and interviewed operators, front-line managers, maintenance mechanics, radiation protection (RP) staff, laboratory managers, and process engineering personnel regarding issues with plant equipment and to verify the status of the process operations. The inspectors observed operational and shift turnover meetings throughout the inspection period to gain insight into safety and operational issues.

During the inspection period, the inspectors interviewed operators, front-line managers, maintenance technicians, engineers, RP technicians, and nuclear materials control technicians to verify that each of the individuals demonstrated adequate knowledge of the nuclear criticality safety (NCS) posting requirements, hazards, and the operations procedures associated with their assigned duties.

The routine tours included walk-downs of the FMF, BPF, commercial development line areas, miscellaneous storage areas, the Waste Water Treatment Facility (WWTF), and Building 440. During routine tours, the inspectors verified that operators 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 to verify that operators complied with procedures and material station limits.

The inspectors verified that safety controls, including items relied on for safety (IROFS),

were in place, properly labeled, and functional to ensure proper control of SNM. The inspectors verified the adequacy of communications between supervisors and operators within the operating areas.

The inspectors reviewed operator log books, standard operating procedures (SOPs),

maintenance records, and Letters of Authorization (i.e., temporary procedures) to obtain information concerning operating trends and activities. The inspectors verified that the licensee actively pursued corrective actions for conditions requiring temporary modifications and compensatory measures.

The inspectors performed periodic tours of the outlying facility areas to determine 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

2 containers, and potential degradation of plant security features. The inspectors attended various plan-of-the-day meetings and met daily with the Plant Shift Superintendent throughout the inspection period in order to determine the overall status of the plant.

The inspectors evaluated the adequacy of the licensees response to significant plant issues as well as their approach to solving various plant problems during these meetings.

b. Conclusion

No violations of more than minor significance were identified.

2. Safety System Inspection (IP 88135.04)
a. Inspection Scope The inspectors performed walk-downs of safety-significant systems involved with the processing of SNM. As part of the walk-downs, the inspectors verified as-built configurations matched approved plant drawings.

The inspectors interviewed operators to confirm that plant personnel were familiar with the assumptions and controls associated with the IROFS systems and instrumentation for maintaining plant safety. The inspectors also verified that IROFS assumptions and controls were properly implemented in the field.

The inspectors reviewed the related Integrated Safety Analysis (ISA) to verify that system abilities to perform functions were not affected by outstanding design issues, temporary modifications, operator workarounds, adverse conditions, or other system-related issues.

The inspectors also verified that there were no conditions that degraded plant performance and the operability of IROFS, safety-related devices, or other support systems essential to safety system performance. Safety-significant functions, tests, and inspections to assure operability of the safety system for Area 600 in the production area were specifically inspected.

To determine the correct system alignment, the inspectors reviewed procedures, drawings, related ISAs, and regulatory requirements such as Title 10 of the Code of Federal Regulations (10 CFR) Section 70.61, Performance Requirements. During the walk-downs, the inspectors verified all or some of the following as appropriate:

  • Controls in place for potential criticality, chemical, radiological, and fire safety hazards
  • Process vessel configurations maintained in accordance with NCS Evaluations
  • Correct valve position and potential functional impacts such as leakage
  • Electrical power availabilityMajor system components correctly aligned, labeled, lubricated, cooled, and ventilated
  • Hangers and supports correctly installed and a functional Lockout/Tag-Out program appropriately implemented
  • Cabinets, cable trays, and conduits correctly installed and functional
  • Visible cabling in good material condition
  • No interference with system performance from ancillary equipment or debris

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b. Conclusion

No violations of more than minor significance were identified.

3. Operational Safety (IP 88020)
a. Inspection Scope The inspectors interviewed fuel manufacturing supervisors and operators, one criticality safety engineer and reviewed records associated with Area 600 in the FMF to validate the correct implementation of IROFS and their safety functions, as described by the following accident sequences listed in the ISA summary:
  • 4.1.1.1.a.1, 4.1.1.1.a.2
  • 4.1.1.1.b.1, 4.1.1.1.b.2
  • 4.1.1.1.c, d
  • 4.1.2.1.a, b
  • 4.1.7.b, c
  • 4.1.16 The inspectors reviewed IROFS FA6-001, FA6-005, FA6-006, FA6-007, FA6-012, FA6-013, FA6-015, FA6-021, FA6-002, FA6-020, FA6-017, FA6-018, and FA6-019 associated with the Criticality Safety Evaluation for Area 600 of the Production Fuel Facility, to verify the IROFS were implemented as described in the ISA.

The inspectors reviewed the management measures associated with FA6-001, FA6-005, FA6-006, FA6-007, FA6-012, FA6-013, FA6-015, FA6-021, FA6-002, FA6-020, FA6-017, FA6-018, and FA6-019 to verify that the IROFS were available and reliable to function when needed as described in the ISA summary. The inspectors conducted walk-downs of the process area to verify the physical presence of active engineered safety controls.

The inspectors reviewed procedure NFS-HS-CL-10-06, Nuclear Criticality Safety Buildings 302 and 303- Area 600, to verify that required actions for IROFS FA6-001, FA6-002, FA6-018, FA6-015, FA6-020, FA6-019, FA6-007,and FA6-017, as identified in the ISA Summary were transcribed into written operating procedures. The inspectors evaluated the operating limits documented in the procedure to verify that limits required to ensure safety were properly described.

The inspectors interviewed operators to verify that operators and technicians were knowledgeable of the implementation of the reviewed IROFS. The inspectors conducted interviews and reviewed documentation to verify that the licensee conducted periodic surveillances as required by the ISA Summary for FA6-005. The inspectors reviewed the surveillance procedures to verify the established periodic functional test was being conducted for the IROFS safety function. The inspectors reviewed the condition of the passive engineered control FA6-021 to verify that it would be able to perform its safety function.

The inspectors reviewed the licensees corrective action program (CAP) entries related to Area 600 for the past 12 months to verify that deviations from procedures and unforeseen process changes affecting nuclear criticality, chemical, radiological, or fire safety were documented and investigated promptly.

4 The inspectors reviewed a sample of training qualifications required to be completed by operators in Area 600 to verify that the operators in the FMF were maintaining qualifications in accordance with licensee procedures and requirements. The inspectors reviewed two Criticality Safety Audits performed in Area 600 to verify they were performed and documented in accordance with licensee procedures.

b. Conclusion

No violations of more than minor significance were identified.

4. Nuclear Criticality Safety (IP 88135.02)
a. Inspection Scope During daily production area tours, the inspectors verified that various criticality controls were in place, that personnel followed criticality station limit cards, and that containers were adequately controlled to minimize potential criticality hazards. The inspectors reviewed a number of criticality-related IROFS for operability. The inspectors interviewed operators to verify that they were knowledgeable of the requirements associated with IROFS. The inspectors performed the tours inside various process areas when SNM movements were taking place within the facility.

As part of routine day-to-day activities on-site, the inspectors reviewed CAP entries associated with criticality safety aspects. The inspectors evaluated the licensees response to such entries and held discussions with NCS engineers and production personnel to determine safety significance and compliance with procedures.

b. Conclusion

No violations of more than minor significance were identified.

5. Nuclear Criticality Safety (IP 88015)
a. Inspection Scope Criticality Analysis The inspectors reviewed selected nuclear criticality safety evaluations (NCSEs) to determine whether properly reviewed and approved NCSEs were in place prior to the conduct of new or changed operations and were of sufficient detail and clarity to permit independent review. The inspectors reviewed the selected NCSEs and associated assumptions and calculations to verify that they were consistent with the commitments in the license application. These commitments included the licensees commitment to the double contingency principle, assurance of subcriticality under normal and credible abnormal conditions with the use of subcritical margin, technical practices and methodologies, and treatment of NCS parameters. The NCSEs were selected based on factors such as whether or not they were new and/or revised, their heavy reliance on administrative controls, and their use of unusual control methods. The NCSEs reviewed included 54X-06-0024, Nuclear Criticality Safety Evaluation for Area 600 of the Production Fuel Facility, 54X-17-0008, Addendum 1 to the Nuclear Criticality Safety

5 Evaluation for the PSL Area 600 and 700A Operations, 54X-15-0004, Nuclear Criticality Safety Evaluation Handling Fissile Material in Portable Containers, and those listed in Section 4 of the Attachment The inspectors reviewed selected accident sequences to determine whether the NCSEs systematically identified normal and credible abnormal conditions in accordance with the commitments and methodologies in the license application for the analysis of process upsets. This included the review of accident sequences for which the licensee credited the repeated failure of administrative controls, or credited the duration of a control failure, to determine whether the bases for this credit were consistent with Chapter 3 of the license application, and the licensees procedures, including the Independence Criteria Guidance in Attachment C of NFS-HS-A-68, ISA Risk Assessment Procedure.

This review was conducted primarily for the accident sequences analyzed in the NCSEs for Area 600 and handling of fissile material in portable containers.

The inspectors reviewed the validation report (54T-12-0038, Validation of Computer Codes for NCS for Uranium Systems with Enrichments up to 100 wt.% 235U: SCALE 6.1 with the V7-238 Library from ENDF/B-VII, and SCALE 4.4a with the 27GROUPNDF4 Library from ENDF/B-IV) to verify that it was performed and documented consistent with the technical practices and methodologies in Section 5.5.4 of the license application.

The inspectors also reviewed selected NCSEs, NCS procedure (NFS-HS-A-63, Verification and Validate of Nuclear Criticality Safety Analysis Codes) and a verification report (54T-14-0007, Verification of Computer Codes for NCS for Uranium Systems with Enrichments up to 100 wt.% 235U: SCALE 6.1 with the V7-238 Library from ENDF/B-VII) to verify that the limits established in the validation report were implemented in procedures and NCSEs. The inspectors reviewed the selected NCSEs to determine whether calculations were performed within their validated areas of applicability and consistent with the validation report. Specifically, the inspectors reviewed the materials that were part of the area of applicability to verify that the NCSEs used only the validated materials in their computer code models. Additionally, the inspectors interviewed NCSE engineers and management to verify that the NCS engineers reviewed the NCSEs to confirm the computer code models used were within the area of applicability established by the validation report.

Criticality Implementation The inspectors performed walk-downs in Naval Fuel processing areas, including Area 600 and Area D of Uranium Recovery, as well as outlying buildings (e.g., 440 building) to determine whether existing plant configuration and operations were covered by, and consistent with, the process description and safety basis in the selected NCSEs listed above. The inspectors reviewed process and system descriptions, specifications, drawings, and control flowdowns to verify that engineered controls established in the NCSEs were included. The engineered controls reviewed included, dimension controls and interlocks in the 600 Area. The inspectors reviewed runsheets and postings to verify that selected administrative controls established in the NCSEs were included. The administrative controls reviewed included those associated with the handling of fissile material and mass or piece count limits in gloveboxes.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 NCSEs.

6 Criticality Operational Oversight The inspectors reviewed records of NCS audits and accompanied a licensee NCS engineer on a weekly inspection of the production facility to determine whether NCS staff routinely assessed field compliance with established NCS controls. Additionally, the inspectors interviewed NCS management and engineers to verify that NCS engineers performed weekly inspections of selected site operations as required by Section 5.3.4 of the license application. The records of NCS audits reviewed included 2018-02, 03, 04, 05, 06, 07, 08, 09, 10, 11, and 12.

Criticality Incident Response and Corrective Action 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 corrective actions 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. Additionally, the inspectors reviewed NCS-related CAP entries to assess NRC reportability. The CAP entries reviewed included Problem Identification, Resolution, and Correction System (PIRCS) 63553, 63800, 64335, 64493, 63291, and 60855.

b. Conclusion

No violations of more than minor significance were identified.

6. Fire Protection Quarterly (IP 88135.05)
a. Inspection Scope During routine plant tours, the inspectors verified that transient combustibles were being adequately controlled and minimized in selected process areas. The inspectors reviewed active fire impairments in selected process areas and determined they were implemented per site procedure.

The inspectors conducted a walk-down of the LA area in Building 304 and reviewed the Pre-Fire plan drawing to verify it matched the as-found condition for various fire protection components like extinguishers, and postings. The inspectors reviewed the material condition of fire protection components to verify they were adequately maintained. The inspectors observed detection system testing for the selected area.

The inspectors reviewed a sampling of fire-related PIRCS entries to verify that corrective actions were appropriate and that appropriate compensatory actions were implemented, as applicable. The inspectors observed fire brigade training and rescue exercises.

b. Conclusion

No violations of more than minor significance were identified.

7 B. Radiological Controls

1. Radiation Protection Quarterly (IP 88135.02)
a. Inspection Scope During tours of the production areas, the inspectors observed RP controls and practices implemented during various plant activities including the proper use of personnel monitoring equipment, required protective clothing, and frisking methods for detecting radioactive contamination on individuals exiting contamination controlled areas. The inspectors verified that plant workers properly wore dosimetry and used protective clothing in accordance with applicable Special Work Permits (SWPs). The inspectors also verified that radiation area postings complied with plant procedures and included radiation maps with up-to-date radiation levels. The inspectors monitored the operation of RP instruments and verified calibration due dates.

The inspectors performed partial reviews of select SWPs in effect during the inspection period in different operational areas and conducted a more thorough review for the following SWPs and posted radiologically controlled areas:

  • SWP 18-02-006 302
  • SWP 16904 333
  • SWP 301RCPT 16918
  • SWP18 32 009 333

b. Conclusion

No violations of more than minor significance were identified.

C. Facility Support

1. Post Maintenance Testing (IP 88135.19)
a. Inspection Scope The inspectors observed and/or 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 the licensees completed test procedures to verify that 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 observed and/or reviewed the test data to verify that test results adequately demonstrated restoration of the affected safety function(s). The inspectors verified that PMT activities were conducted in accordance with applicable work order instructions or licensee procedural requirements.

Furthermore, the inspectors verified that problems associated with PMTs were identified and entered into the licensees PIRCS.

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  • Safety-related equipment (SRE) Test: N306SRWSPRINKLR
  • SRE Test N304NNWSPRINKLR
  • SRE Test N304BZWSPRINKLR
  • SRE Test: N302VALVEHOJ26
  • SRE Test N302VALVEHOJ91

b. Conclusion

No violations of more than minor significance were identified.

2. Surveillance Testing (IP 88135.22)
a. Inspection Scope The inspectors observed portions of and/or reviewed completed test data for the following surveillance tests of risk-significant and/or safety-related systems to verify that the tests met the requirements of the ISA, commitments, and licensee procedures. The inspectors observed and reviewed testing to determine if the SSCs were operationally capable of performing their intended safety functions and fulfilling the intent of the associated SRE test requirement. The inspectors discussed surveillance testing requirements with operators performing the associated tasks to determine the adequacy of their procedural knowledge. The inspectors reviewed the calibration of test equipment or standards used to conduct the test(s). The inspectors observed the communications between personnel performing these tests during the completion of each activity.
  • SRE Test N306VENDRAIN004
  • SRE Test N303XFILTER0512

b. Conclusion

No violations of more than minor significance were identified.

3. Corrective Action Program Review (IP 88135)
a. Inspection Scope and Observations The inspectors reviewed the PIRCS to ensure that items adverse to safety were being identified and tracked to closure in accordance with program procedures. The inspectors routinely attended daily PIRCS screening committee meetings and periodic Corrective Action Review Board meetings to evaluate site managements response and assignment of corrective actions or investigations to various issues. The inspectors also performed daily screenings of items entered into the Corrective Action Program (CAP) to aid in the identification of repetitive equipment failures or specific human performance issues for follow-up.

The inspectors reviewed CAP entries that occurred during the inspection period to assess and evaluate the safety significance of issues. For items identified to be more safety significant, the inspectors conducted an additional evaluation to verify the licensee was adequately addressing and correcting the issues to prevent recurrence.

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b. Conclusion

No violations of more than minor significance were identified.

4. Emergency Preparedness Drill (IP 88135)
a. Inspection Scope and Observations On May 22, 2018, the inspectors observed an emergency evacuation drill to verify that facility staff could evacuate and be accounted for during a serious emergency. Also, the inspectors observed a limited scope training session for in the Emergency Control Center. This training session was intended to give participants an opportunity to maintain proficiency with applicable emergency plan implementing procedures. The inspectors also observed the post-training session critique.

b. Conclusion

No violations of more than minor significance were identified

5. Plant Modifications (IP 88070)
a. Inspection Scope The inspectors interviewed senior managers, managers, supervisors, and engineers to verify that the licensee had established an effective configuration management program to evaluate, implement, and track modifications to the site which could affect safety.

The inspectors verified that the licensees work control program had provisions to ensure the adequate pre-job planning and preparation of plant modification design packages.

The inspectors verified that the configuration management program had provisions to ensure that plant modifications did not degrade the capabilities of IROFS or other safety controls that are part of the safety design basis.

The inspectors reviewed a sampling of plant modifications packages including major modifications, minor modifications, administrative modifications, temporary modifications, and Letters of Authorization (LOA) that were completed since the last plant modifications inspection to verify that the change packages were prepared, reviewed, and completed in accordance with approved change management procedures. The following plant modification packages were reviewed:

  • IAC-888 Decontamination & Decommissioning of Groundwater Treatment Plant
  • ECR-20171070 Off Gas improvement study
  • ECR-20171175 LOA-2130Q-009 & LOA-2293Y-056
  • ECR-20170421 Replace Blower-A801
  • ECR-20170454 Replace Blower-A801 (CCP-20170198)
  • ECR-20170586 Permanent replacement Blower-A801
  • ECR-20170913 Replace Blower-A80
  • CR-20171587 Replace Blower-A801
  • ECR-20170625 B306 UPS and Battery Replacement
  • ECR-20170707 Temporary Portable Generator Tie-in

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  • ECR-20171416 LOA-2293Y-67 Handling of Containers of Blowback Solution / Transfer to WWTF
  • ECR-20171262 Change in Material of construction for 302/202-OVRFLO-x305
  • ECR-20171143 LOA-2293Y-024 ENCLOS-1803 Modification Testing &

Processing Extension

  • ECR-20170663 LOA-2293Y-024 ENCLOS-1803 Modification Testing &

Processing

  • ECR-20170923 Setpoint SA-00225, Rev. 5
  • ECR-20170924 Setpoint SA-00368, Rev. 4
  • ECR-20170922 Increase the flow ranges of enclosure purge gas flow meters in 302-600/700 & 303-600/700
  • ECR-20170801 SA-00394 Setpoint Review
  • ECR-20170743 ECR for CCP-20170305
  • ECR-20170681 Review wavier for select SRE items
  • ECR-20170272 LOA for Continued WD/WF discards with faulty check valve 306-CK-08A8 The selected plant modifications were reviewed to verify that applicable post maintenance installation and testing requirements were identified and performed prior to turnover to operations. The inspectors reviewed design information to determine if instrument set points accurately reflected the protection of safety limits taking into account instrument and calibration uncertainties. The inspectors also reviewed the licensees process for making changes to their functional test instructions, which were used to perform post maintenance testing.

The inspectors verified that the licensee addressed the impacts of both facility changes and document modifications on the ISA, ISA Summary, and other safety program documentation developed in accordance with 10 CFR 70.62. The inspectors reviewed completed 10 CFR 70.72 evaluations to determine if the licensee adequately determined whether NRC pre-approval of the change was required.

The inspectors performed walk-downs of selected modifications to determine if they were installed in accordance with approved design documents such as drawings and technical reports.

The inspectors reviewed changes to the licensees change management program procedures since the last inspection to verify that the changes were in compliance with the requirements of the license application.

The inspectors reviewed the licensees CAP to verify that issues related to the preparation of change requests and the installation of facility changes were entered into the CAP and the assigned appropriate corrective actions in accordance with licensee commitments and procedures.

b. Conclusion

No violations of more than minor significance were identified.

11 D. Other Areas

1. Follow-up on Previously Identified Issues
a. VIO 70-143/2018-002-01: Failure to Meet Criticality Accident Alarm System Requirements (Closed)

Inspection Scope In Inspection Report 2018-002 (ADAMS Accession Number: ML18109A306) the NRC identified a Severity Level (SL) IV violation (VIO) of License Application, Section 4.7.12.4, Criticality Detection System, with two examples. First, the licensee failed to ensure that, while in Storm Mode, their criticality accident alarm system (CAASwould respond to the minimum accident of concern, as required by ANSI/ANS-8.3, Section 5.6, Detection Criterion. Second, the licensee failed to periodically test the Storm Mode logic when they tested their CAAS, as required by ANSI/ANS-8.3, Section 6.4, Periodic Tests.

The inspectors reviewed the licensees corrective actions as outlined in their Reply to a Notice of Violation (VIO 70-143/2018-002-01) dated May 14, 2018, and the root cause evaluation contained in PIRCS 63291. The inspectors specifically reviewed the changes the licensee made to the procedures for manipulating the CAAS during times of severe weather and the training toolbox provided to employees for awareness of the procedure changes and the background on the violation. The inspectors interviewed select staff to assess their understanding of the revised procedure for storm compensatory measures and observed a demonstration of how the new process was implemented on the CAAS programmable logic controller.

b. Conclusion

No issues were noted with the licensees corrective actions. This violation is considered closed.

E. Exit Meetings The inspection scope and results were presented to members of the licensees staff at various meetings throughout the inspection period and were summarized on June 28, 2018, to R. Freudenberger and staff, as well as on July 24, 2018, to J. Stewart and staff.

No dissenting comments were received from the licensee. Proprietary and classified information was discussed but not included in the report

SUPPLEMENTAL INFORMATION

1. KEY POINTS OF CONTACT Name Title C. Barron Emergency Preparedness Manager C. Brown MC&A Department Section Manager N. Brown NCS Department Section Manager T. Cloyd Fire Protection Engineer D. Deming Manager, Program Field Office (Bettis)

J. Stewart President J. Eidens BMPC Program Field Office (KAPL)

T. Evans Security Section Manager J. Faddis Environmental Unit Manager R. Freudenberger Safety & Safeguards Director J. Griffith Environmental Scientist J. Hagemann Operations Director H. Jimenez Fuel Facilities Unit Manager T. Knowles Licensing Manager R. Mauer ISA Manager J. May T&WM Ops Unit Manager M. Moore Environmental Protection & Industrial Safety Section Manager A. Morie Safety & Safeguards Program Manager J. Nagy Nuclear Safety Officer Chief B. Rice NCS Engineer R. Rice Radiation Protection and Health Physics Unit Manager D. Rogers Manufacturing Operations Section Manager S. Sanders Training Manager R. Shackelford Nuclear Safety & Licensing Section Manager S. Skiles NCS Engineer R. Storey Configuration Management Unit Manager

2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Closed VIO 70-143/2018-002-01 Failure to Meet Criticality Accident Alarm System Requirements
3. INSPECTION PROCEDURES USED 88015 Nuclear Criticality Safety 88020 Operational Safety 88070 Plant Modifications 88135 Resident Inspector Program For Category I Fuel Cycle 88135.02 Plant Status 88135.04 ISA Implementation 88135.05 Fire Protection 88135.17 Permanent Plant Modifications 88135.19 Post Maintenance Testing 88135.22 Surveillance Testing Attachment

2

4. DOCUMENTS REVIEWED Records:

IROFS 302303-600700A, Completion, dated December 8, 2017 IROFS 302-600700A, Completion, dated January 16, 2017 IROFS 302-600700A, Completion, dated January 15, 2018 OPR-TB-APR18-08, Storm Compensatory Measures, dated April 24, 2018 OPR-TB-MAY18-09, Plant Changes that are Compliant with Regulations and Proposed Actions, dated June 8, 2018 Safety and Safeguards Review Council (SSRC) / Change Control Board (CCB) Meeting Minutes June 15, 2017; February 1, 2018; April 5, 2018 SRE Test: N302FURDOOR600B, Revision (Rev.) 4, completed May 25, 2018 SRE Test: N302STRDOORSEAL, Rev. 2, completed September 9, 2017 SRE Test: N303FURDOOR600B, Rev. 3, completed February 2, 2018 54T-12-0038, Validation of Computer Codes for NCS for Uranium Systems with Enrichments up to 100 wt.% 235U: SCALE 6.1 with the V7-238 Library from ENDF/B-VII, and SCALE 4.4a with the 27GROUPNDF4 Library from ENDF/B-IV, Rev. 0, dated December 12, 2012 54T-14-0007, Verification of Computer Codes for NCS for Uranium Systems with Enrichments up to 100 wt.% 235U: SCALE 6.1 with the V7-238 Library from ENDF/B-VII, Rev. 0, dated April 5, 2014 54X-06-0024, Nuclear Criticality Safety Evaluation for Area 600 of the Production Fuel Facility, Rev. 3 54X-15-0004, Nuclear Criticality Safety Evaluation Handling Fissile Material in Portable Containers, Rev. 1, dated November 10, 2017 54X-16-0011, Nuclear Criticality Safety Evaluation for Area D of the Uranium Recovery System, Rev. 5, dated October 24, 2016 54X-17-0008, Addendum 1 to the Nuclear Criticality Safety Evaluation for the PSL Area 600 and 700A Operations, Rev. 0, dated February 15, 2018 54X-17-0009, NCSE 306 East and West Storage Areas, Rev. 0 302-600700A, Completion, dated August 28, 2017 302-600700A, Completion, dated April 12, 2017 302-600700A, Completion, dated October 3, 2017 Procedures:

Control Flowdown and Field Verification for Area 600 ENG-EPS-A-003, Setpoint Verification and Design Parameter Documentation, Rev. 8 HS-HTG-025, NFS Health and Safety How to Guide, Implementing Storm Compensatory Measures, Rev. 0 NFS-CM-002, Identification and Control of Configuration Items (CIs), Rev. 8.C NFS-CM-004, NFS Change Control Process, Rev. 18 NFS-EP-01, Rev. 3, Standard Operational Guidelines for Evaluation of Unusual Incidents NFS-HA-68, Rev. 7, ISA Risk Assessment Procedure, dated March 29, 2018 NFS-HS-A-21, Operation and Testing of the Criticality, Fire, and CO2 Alarm System, Rev. 33 HS-A-63, Verification and Validate of Nuclear Criticality Safety Analysis Codes, Rev. 7, dated November 2, 2015 NFS-HS-A-68, ISA Risk Assessment Procedure, Rev. 7, dated March 29, 2018 NFS-HS-CL-10-06, Nuclear Criticality Safety Buildings 302 and 303- Area 600, Rev. 9, dated May 10, 2013 NFS-HTG-025, Rev. 001, Implementing Storm Compensatory Measures

3 NFS-WM-001-01, Work Management Program Description, Rev. 4 SOP 401-06, Fuel Manufacturing Facility Building Area 600, Rev. 0, dated December 11, 2017 Other Documents:

300 Complex Production Areas 100 to 900, Integrated Analysis Summary, Rev. 14, dated January 2018 Nuclear Criticality Safety Evaluation for Area 600 of the Production Fuel Facility, Rev. 3, dated January 1, 2007 Area 500/600 Piping and Instrumentation Diagram, dated January 12, 2018 Items Relied on for Safety (IROFS) and Safety Related Equipment (SRE) - Building 302 Areas 600 and 700, Rev. 19, dated December 11, 2017 T&Q Name-OT-302-600/700 A, NFS Training Department (Area 600/700 A).

NCS-2017-10, Ninth Nuclear Criticality Safety Audit of the Nuclear Criticality Safety Evaluation for Area 600 of the Fuel Manufacturing Facility, Rev. 3, dated June 12, 2017 and May 5, 2015 NCS-2015-10, Nuclear Criticality Safety Audit (Writers Guide), Rev. 5, dated May 27, 2016 PIRCS Written as a Result of the Inspection:

64030, 64031, 64039, 64035, 64136, 64181, 64182, 64251, 64295, 64296, 64340, 64455, 64572, 64667, 64979, 64980, 65030, 65038 PIRCS Reviewed:

56686, 58541, 58464, 60712, 60855, 60943, 60944, 61655, 63291, 63553, 63800, 63893, 63981, 64056, 64069, 64101, 64110, 64171, 64175, 64190, 64225, 64288, 64299, 64324, 64335, 64384, 64414, 64425, 64478, 64493, 64549, 64567, 64631, 64684, 64689, 64706, 64711, 64726, 64803, 64826, 64836

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