ML18298A001

Nuclear Fuel Services, Inc., - U.S. Nuclear Regulatory Commission Integrated Inspection Report Number 07000143/2018004

ML18298A001
Person / Time
Site:	Erwin
Issue date:	10/24/2018
From:	Omar Lopez-Santiago NRC/RGN-II/DFFI
To:	Stewart J Nuclear Fuel Services
References
IR 2018004
Download: ML18298A001 (22)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 October 24, 2018 Mr. John A. Stewart President Nuclear Fuel Services, Inc.

P. O. Box 337, MS 123 Erwin, TN 37650-0337

SUBJECT:

NUCLEAR FUEL SERVICES, INC. - U. S. NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT NUMBER 70-143/2018-004

Dear Mr. Stewart:

This letter refers to the inspections conducted from July 1 to September 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 September 20, 2018, and after the end of the quarter on October 18, 2018.

During the inspections, NRC staff examined activities conducted under your license, as 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 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. 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.

J. Stewart 2

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

Sincerely,

/RA/

Omar R. López-Santiago, Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No.70-143 License No. SNM-124

Enclosure:

NRC Inspection Report 70-143/2018-004 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

ML18298A001 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI RII:DFFI RII:DFFI RII:DFFI SIGNATURE

/RA/

/RA/

/RA/

/RA/

NAME LHarris LPitts RGibson, Jr GGoff DATE 2/23/2018 2/23/2018 2/23/2018 2/23/2018 E-MAIL COPY?

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.:

70-143/2018-004 Licensee:

Nuclear Fuel Services, Inc.

Facility:

Nuclear Fuel Services, Inc.

Location:

Erwin, TN 37650 Dates:

July 1 through September 30, 2018 Inspectors:

L. Harris, Senior Resident Inspector R. Gibson, Jr., Senior Fuel Facility Inspector G. Goff, Fuel Facility Inspector Approved by:

O. López-Santiago, Chief Projects Branch 1 Division of Fuel Facility Inspection Enclosure

EXECUTIVE

SUMMARY

Nuclear Fuel Services, Inc.

NRC Integrated Inspection Report 70-143/2018-004 July 1 - September 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 were properly implemented and maintained in order to perform their intended safety function. (Paragraphs A.1 and A.2)

The Nuclear Criticality Safety Program was implemented in accordance with the license application and regulatory requirements. (Paragraph A.3)

The Fire Protection Program and systems were adequately maintained in accordance with the license application and regulatory requirements. (Paragraph A.4)

Radiological Controls The Radiation Protection Program was implemented in accordance with the license application and regulatory requirements. (Paragraphs B.1 and B.2)

Effluent Control and Environmental Protection Program was implemented in accordance with the license application and regulatory requirements. (Paragraph B.3)

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. (Paragraph C.3)

The Emergency Preparedness Program was implemented in accordance with the Emergency Preparedness Plan and regulatory requirements. (Paragraph C.4)

2 Other Areas No violations of more than minor significance were identified during Resident Inspector observations of Security Force and Material and Control accounting personnel. (Paragraph D.1) 30-Day Written Report of a Legacy Contamination Identification was reviewed by inspectors and closed in this report. (Paragraph D.2)

Licensee Event Report (LER) Event Notification53573, Unauthorized Storm Water Discharge, was reviewed by inspectors and closed in this report. (Paragraph D.3)

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

2 condition of bulk chemical storage tanks and piping, storage of compressed gas 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 Walkdown Inspection (IP 88135.04)

a. Inspection Scope The inspectors performed walkdowns of safety-significant systems involved with the processing of SNM. As part of the walkdowns, 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 systems for Building 306 Area 800 auxiliary and Area 900 in the production area were specifically inspected. For Building 306 Area 800 auxiliary, the inspectors reviewed IROFS and management measures associated with: FA8-13, FAT-1, FAT-5, FAT-6, FAT-9, FAT-20, FAT-23, FAT-24, FIRE-2, FIRE-18, and FIRE-20. For Area 900, the inspectors reviewed selected IROFS and management measures associated with: FA9-1, FA9-3, FA9-4, FA9-7, FA9-9, FA9-12, FA9-22, FA9-24, FA9-25, FA9-29, FA9-35, FA9-42, FA9-45, FA9-46, FA9-47, FA9-48, FA9-49, FA94-1, FA94-2, FA95-4, FA95-5, FA96-5, FA96-9, FA96-11, FA97-5, FA97-6, FIRE9-1, FIRE9-2, and FIRE9-3.

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 walkdowns, 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

3 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 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

b. Conclusion No violations of more than minor significance were identified.

3.

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 entries in the licensees Problem, Identification, Resolution, and Correction System (PIRCS) associated with criticality safety aspects. PIRCS is the licensees Corrective Action Program (CAP). 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.

4.

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 Building 234 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

4 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 exercises.

b. Conclusion No violations of more than minor significance were identified.

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 16994 333 SWP 16999 333 SWP 16998 303 SWP 17004 302

b. Conclusion No violations of more than minor significance were identified.

2.

Radiation Protection (IP 88030 Appendix A)

a. Inspection Scope The inspectors reviewed the licensees RP program to verify compliance with Chapter 4 (Radiation Protection) and Chapter 11 (Management Measures) of the license application; license conditions; and 10 CFR 20 requirements. The inspectors also reviewed RP program documents (see the attachment), observed activities, and conducted interviews to verify that the program was being implemented in accordance with the above requirements.

5 The inspectors reviewed the 2017 ALARA Report and 2017-2018 Site Safety Review Committee (SSRC) meeting minutes to verify that the program was being documented and implemented in accordance with 10 CFR 20.1101(a). The inspectors also reviewed audits and assessments to verify that the program content and performance was being reviewed in accordance with 10 CFR 20.1101(c). The inspectors interviewed the RP manager and a senior health physicist, observed RP activities, and reviewed the aforementioned documents to verify that the RP programs functions and responsibilities were independent from operations/production.

The inspectors reviewed and discussed the organizational chart to determine recent personnel changes in the radiation protection organization. The inspectors also interviewed the RP Manager and reviewed training records to verify that RP employees received and completed required training, including refresher training, at the frequency specified in the procedures and as required by 10 CFR 19.12. The inspectors also reviewed these records to verify that the training content was in compliance with procedural requirements.

The inspectors reviewed changes to procedures to verify that any changes did not reduce safety. The inspectors also reviewed these procedures to verify that the review frequency and revision process were in compliance with license application requirements.

The inspectors reviewed contamination and radiation survey records, training records, as low as reasonably achievable (ALARA) documents, and audits/assessments to verify that the licensee maintained such records for at least three years after the record was made as per 10 CFR 20.2102 and 20.2103.

The inspectors reviewed entries into the licensees CAP to determine whether the licensee was identifying issues at an appropriate threshold and entering these issues into the CAP as required by Chapter 11 of the license application. The inspectors reviewed selected events related to the radiation protection program to verify that the licensee entered the issues into the CAP in a timely manner, considered the extent of condition, identified the root and contributing causes, classified and prioritized the resolution of the problem commensurate with its safety significance, and identified corrective actions to correct the problem and prevent recurrence.

The inspectors reviewed selected SWPs and observed work being performed under those SWPs to verify that personnel complied with the requirements of the SWP and Chapter 4 of the LA. Specifically, the inspectors focused on RP activities being performed under SWPs 16909, 16939, 17039, all of which pertained to on-site excavation activities.

The inspectors reviewed recent calibration records (sticker labels and hard-copy records) and calibration procedures for instruments detecting alpha, beta, and gamma radiation to verify that the licensee maintained such equipment as per Chapter 4 of the license application. The inspectors observed instrument response checks to button-type sources (alpha, beta, and gamma) to verify operability. The inspectors also observed that the licensee had a notification system for when an instrument was due for calibration per 10 CFR 20.1501(c). The inspectors observed personnel monitoring stations such as hand-and-foot monitors and whole body counters to verify these devices were within calibration. The inspectors verified that the sources used for in-house calibration and response checks were NIST-traceable.

6 The inspectors observed radiation and contamination surveys to verify compliance with procedures and to meet the requirements of 10 CFR 20.1501(a) and (b). The inspectors also reviewed contamination/radiation survey records to determine if any results exceeded any licensee action levels.

The inspectors toured highly enriched uranium (HEU) and low enriched uranium (LEU) processing areas to verify that the licensee posted the areas in accordance with 10 CFR 20.1902 and 20.1903 and that radiological signs and postings accurately reflected radiological conditions within the posted area.

The inspectors reviewed the 2017 Total Effective Dose Equivalent results to verify that they were less than the regulatory limit of 5 rem/yr. The inspectors reviewed the 2017 personnel dosimeter results as submitted to the licensee by their contractor to verify that the Lens Dose Equivalent and Shallow Dose Equivalent results were less than the regulatory limits of 15 and 50 rem/yr, respectively. Through interviews and a review of records, the inspectors verified that exposure records were maintained in accordance with 10 CFR 20.2106.

b. Conclusion No violations of more than minor significance were identified.

3.

Effluent Control and Environmental Protection (IP 88045)

a. Inspection Scope The inspectors evaluated whether the licensee had established and maintained an environmental protection program in accordance with Chapter 9, Environmental Protection and Chapter 11, Management Measures of the license application for the Nuclear Fuel Services facility in Erwin, Tennessee. The inspectors reviewed the environmental protection program to verify that the program was being implemented in accordance with the license and regulations.

The inspectors reviewed the quality assurance program for effluent control and environmental protection to verify that the licensee performed the required audits and presented the annual audit results to the management team in accordance with the license application. The inspectors reviewed the findings from these audits to verify that they were entered into the licensees CAP for resolution in accordance with the license application. The inspectors reviewed events identified in the licensees CAP/PIRCS, to verify that deviations from procedures and unforeseen process changes were documented and investigated.

The inspectors reviewed procedures and observed performance of tasks related to effluent control and environmental protection to verify that the procedures were clearly written and adequately delineated responsibilities related to effluent controls. The inspectors observed environmental radiation technicians performing effluent controls and environmental protection activities. The inspectors verified that the technicians were familiar with their responsibilities as they performed their tasks in accordance with onsite procedures. Also, the inspectors reviewed training records to verify that the technicians were trained in accordance with the license application.

7 The inspectors reviewed the semi-annual effluent reports for the calendar year 2017 to verify the licensees compliance with effluent requirements of 10 CFR 70.59. The inspectors reviewed the semi-annual effluent reports that were used to calculate the maximum possible dose to a member of the public at the licensees fence line from the normal gaseous effluent release to verify compliance with the regulatory limits specified in 10 CFR 20.1101 (d).

The inspectors reviewed a sample of the calibration and control program for flow indicators on effluent stack building ventilation velocity measurements to verify that effluent stack filters were being replaced within the required frequency in accordance with the licensee procedure NFS-HS-A-10, Determining Gaseous Effluent Flow Rates and Demonstrating Isokinetic Sampling, Revision 10, and the ambient air procedure NFS-HS-B-10, Routine Air and Stack Sampler Calibration, Revision (Rev.) 14.

The inspectors conducted a walk-down of ventilation stacks and ambient air stations, and observed environmental radiation technicians collecting samples from both systems in accordance with the procedures to verify that effluent equipment and systems were operable and maintained in accordance with the requirements of the procedures.

The inspectors also conducted a walk-down of the waste water treatment process and sanitary sewerage waste stream, and observed a technician collecting samples from the flume outfall to verify that equipment was maintained and operated in accordance with the requirements of procedure NFS-HS-B-16, Routine Sampling of Sanitary Sewer, Rev. 34, and 10 CFR 20.2003.

The inspectors reviewed the effluent monitoring results to verify that the values specified in Appendix B of 10 CFR Part 20 were not exceeded.

The inspectors reviewed records for soil, vegetation, and effluent sludge sample collection results, and discussed the results with licensee staff to verify that the levels were within regulatory limits for reporting in 10 CFR 20.2203 (a)(3)(ii). The inspectors interviewed the environmental health physicist and staff to verify their knowledge regarding effluent systems operations and sampling requirements, and activities were conducted in accordance with approved procedures.

The inspectors reviewed the public dose assessment to determine that the average annual effluent concentrations released in 2017, did not exceed the values specified in Appendix B of 10 CFR Part 20. The inspectors reviewed the airborne portion of the public dose assessment to verify that the results were in compliance with the ALARA constraint required by 10 CFR 20.1101(d). The inspectors verified the calculated total dose to a member of the public likely to receive the highest dose from the licensed operation did not exceed the 10 CFR 20.1301(a)(1) limit for 2017.

b. Conclusion No violations of more than minor significance were identified.

8 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.

Safety-Related Equipment (SRE) Test: N302VALVEBA2904 IROFS 302-900 SRE Test: N333XXXXTE2018A IROFS 333-USVXTR SRE Test: N105VALVEGANG26 IROFS 105-LAB

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 tests. The inspectors observed the communications between personnel performing these tests during the completion of each activity.

SRE Test: N302XXCO2SYSTEM IROFS 300-General SRE Test: N306XXXXPCVCW13 IROFS 000-Facility Support SRE Test: N304VENDRAIN036 IROFS 300-General

9

b. Conclusion No violations of more than minor significance were identified.

3.

Corrective Action Program Review (IP 88135)

a. Inspection Scope 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 PIRCS to aid in the identification of repetitive equipment failures or specific human performance issues for follow-up. The inspectors reviewed PIRCS 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.

b. Conclusion

No violations of more than minor significance were identified.

4. Emergency Preparedness Drill (IP 88135)

a. Inspection Scope On August 23, 2018, the inspectors observed a safety emergency limited scope training drill to verify adequate response, inter-departmental coordination, and procedural implementation. The inspectors also observed the post-training session critique.

b. Conclusion

No violations of more than minor significance were identified D.

Other Areas

1.

Quarterly Resident Inspector Observations of Security and Material Control and Accounting (MC&A) Personnel and Activities

a. Inspection Scope During the inspection period, the inspectors conducted observations of security and MC&A personnel and activities to ensure the activities were consistent with applicable license, procedure, and regulatory requirements. These observations took place during normal and off-normal plant working hours.

10

b. Conclusion

No violations of more than minor significance were identified.

2.

Follow-up on Previously Identified Issues

a. 30-Day Written Report of a Legacy Contamination Identification During the latter quarter of calendar year 1986, licensee personnel decided to redesignate Building 120 from a radiologically controlled area (RCA) to an uncontrolled area. From late 1986 to November 2017, Building 120 remained as an uncontrolled area with its purpose being a storage building for maintenance equipment. In November 2017, the licensee decided to convert Building 120 to a breakroom area. As per the current procedure, contamination surveys were performed on all items being removed as well as the floor, walls, overhead piping, conduit, and roof girders.

During the decontamination process, the licensee discovered that the overhead piping, conduit, roof girders, etc., were contaminated beyond the license application limits. The licensee determined that the contamination was legacy contamination as a result of a failure to adequately survey and subsequently decontaminate the entire building in accordance with the applicable procedure in 1986.

The failure to perform an adequate survey resulted in a violation of 10 CFR 20.1501(a);

however, the licensee calculations showed dose levels below any licensee action levels.

Additionally, based on a review of personnel records, no occupational doses exceeded any dose limits established by 10 CFR 20 regulations.

In accordance with Inspection Manual Chapter (ICM) 0616 Appendix B, Minor/More-than-Minor Examples, Section 6 (Radiological Protection), Example d, this violation constitutes a violation of minor significance that is not subject to enforcement action in accordance with section 2.3.1 of the NRC Enforcement Policy.

The license entered this issue into its CAP as PIRCS 61403. Currently, postings state that any area at or above eight feet in height in Building 120 is considered contaminated.

The licensee has plans to decontaminate the entire building.

b. Conclusion

No violations of more than minor significance were identified. This item is considered closed.

3.

Event Follow-up (Inspection Procedure 88045)

a. LER EN 53573 Nuclear Fuel Services - Unauthorized Storm Water Discharge On August 30, 2018, a report was made to the Tennessee Department of Environment and Conservation (TDEC) and the NRC regarding an unauthorized storm water discharge. As permitted by the State of Tennessee, emulsified vegetable oil was injected into ground water wells located on the North Site of NFS property.

11 At approximately 11:00 a.m., on August 29, 2018, Environmental Safety was notified of a cloudy oil-like substance that was observed in the northwest storm water ditch and the entrance to Martins Creek. In accordance with NPDES Permit No. TNR050873, Tennessee Storm Water Multi-Sector General Permit for Industrial Activities, Section 7.18, the licensee notified TDEC of an unplanned release of a water and emulsified vegetable oil mixture into the storm water drainage system.

The inspectors reviewed documents provided by the licensee which indicated that the injections were immediately ceased. Oil absorbent pads and absorbent socks were deployed and grab samples from both the northwest ditch and Martins Creek were collected and analyzed for the presence of gross alpha and gross beta radioactivity.

The inspectors reviewed the analysis of the grab samples to verify that all results were at background levels for alpha and beta radioactivity. The event was entered into the licensees CAP/PIRCS, Problem ID: 66840. The licensee conducted a General Investigation of the event that was still ongoing at the time of this inspection.

b.

Conclusion Based on the determination that the unauthorized storm water discharge involved no NRC regulatory limits being exceeded, further actions on this event are not required.

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 September 20, 2018, as well as on October 18 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 Attachment

1. KEY POINTS OF CONTACT Name Title L. Armstrong Configuration Management Specialist C. Barron Emergency Preparedness Manager B. Bennett WWTF & Utilities Operations Facility Manager C. Brown MC&A Department Section Manager N. Brown NCS Department Section Manager C. Buchanan Environmental Safety Health Physicist M. Caldwell Radiation Technician T. Cloyd Fire Protection Engineer T. Coates Section Manager, Advisory Economy D. Coulter Senior Health Physicist D. Deming Manager, Program Field Office (Bettis)

R. Dotson T&WM Director B. Edwards Transportation and Waste Operations J. Eidens BMPC Program Field Office (KAPL)

T. Evans Security Section Manager J. Faddis Environmental Unit Manager D. Foster Radiation Technician R. Freudenberger Safety & Safeguards Director C. Gentry Mechanical & Electrical Maintenance Manger K. Greer Emergency Services Unit Manager J. Griffith Environmental Scientist J. Hagemann Operations Director C. Hale Environmental Specialists C. Jarrett Transportation and Waster Operations H. Jimenez Fuel Facilities Unit Manager T. Knowles Licensing Manager G. Lambert Radiation Technician Environmental Laboratory K. Lynch Facilities Support Engineer 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 S. Morie Decommissioning Environmental Unit Manager J. Nagy Nuclear Safety Officer Chief T. Pfefferkorn Facilities Support Engineer K. Rendell Health Physicist for Outside Areas 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 E. Shelton BPF Supervisor S. Skiles NCS Engineer J. Stewart President R. Storey Configuration Management Unit Manager E. Suarez Transportation and Waste Operations D. Tenney Health Physicist for the Fuel Facility J. Tolley Health Physicist

2 J. White Health Physicist for 333 (BPF)

2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Closed 30-Day Written Report of a Legacy Contamination Identification EN 53573, Unauthorized Storm Water Discharge

3. INSPECTION PROCEDURES USED 88030 Radiation Protection (Appendix A) 88045 Effluent Control and Environmental Protection 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

4. DOCUMENTS REVIEWED Records:

2018 Storm Water Sampling Results 2018 First Quarter 24-Hour Sewer Composite Sample Analyses and Erwin Utilities Industrial Report 2018 Second Quarter 24-Hour Sewer Composite Sample Analyses and Erwin Utilities Report Exposure Reports from 1986-1987 and 2014-2017 Flow Meter Calibration Records General H&S Survey Report (333 U Natural Area), dated September 18, 2018 Individual Qualification/Training Records for Radiation Protection Manager, Radiation Technician Manager, and three Radiation Technicians Monthly Discharge Monitoring Report, WWTF batches Monthly Radioactive Airborne Effluent Report Quarterly Assessment of Offsite Ambient Quarterly Assessment of Radioactive Liquid and Gaseous Effluents Dose Safety Work Permits: 16909, 16939, and 17039 Semi-Annual Effluent Reports - dated September 26, 1986; March 27, 1987; September 28, 1987; and March 30, 1988 SSRC Procedure Review records Stacks Building Ventilation Velocity Measurements Various Calibration Records for Survey Meters Ventilation System Inspection Report Procedures:

NFS-DC-103, Decommissioning Sampling Procedure, Rev. 10 NFS-DOC-001, Procedure Implementation Process, Rev. 9, dated September 17, 2018 NFS-GH-01, Contamination Control, Rev. 34, dated June 18, 2018 NFS-GH-28, Personal Monitoring, Rev. 14, dated May 4, 2018

3 NFS-GH-900, Safety and Safeguards Review Council (SSRC) Program, Rev. 22, no date NFS-GH-919, Radiological Safety Training Program, Rev. 3, dated February 15, 2016 NFS-HS-A-10, Determining Gaseous Effluent Flow Rates and Demonstrating Isokinetic Sampling, Rev. 10 NFS-HS-A-12, Radiation Technician Training Procedure, Rev. 12, dated May 24, 2017 NFS-HS-A-42, Drafting Safety Work Permits, Rev. 11, dated August 3, 2017 NFS-HS-A-78, Field Measurements of Effluent Stack/Duct Velocities, Rev. 9 NFS-HS-A-100, Procedure for Calibration of the Ludlum Model 18-P, Rev. 1, dated July 11, 2014 NFS-HS-A-110, Calibration of Flow Measurement Device and Sensor in Sanitary Sewer, Rev. 3 NFS-HS-A-114, Calibration of Flow Measurement Device and Sensor in Banner Spring,

\\Rev. 2 NFS-HS-B-10, Routine Air and Stack Sampler Calibration, Rev. 14 NFS-HS-B-16, Routine Sampling of Sanitary Sewer, Rev. 34 NFS-HS-B-18, Collection and Analysis of NFS Stack Sample, Rev. 26 NFS-HS-B-20, Routine Sampling of Environmental Media, Rev. 25 NFS-HS-B-41, Routine Groundwater Sampling Procedure, Rev. 30 NFS-HS-B-46, Performance of Sealed Source Leak Checks, Rev. 8, May 1, 2015 NFS-HS-B-49, Posting Radiological Areas and Inspecting Radiation Warning Signs, Rev. 10, dated April 2, 2018 NFS-HS-B-67, Storm Water Procedure, Rev. 11 NFS-HS-B-97, Sampling of Banner Spring Branch and North West Storm Water Ditch, Rev. 2 NFS-HS-B-98, Air Sampler Calibration and Maintenance. Rev. 003, dated April 2, 2018 NFS-HS-GH-01, Contamination Control, Rev. 9, dated September 19, 1986 NFS-HS-GH-01, Contamination Control, Rev. 11, dated May 28, 1987 NFS-HS-GH-15, Covering of Plant Surfaces, Rev. 1, dated October 24, 1986 NFS-RPS-QUALP, Radiation Protection Safety Professional Qualification Program, Rev. 2, dated July 23, 2018 Audits:

Triennial Radiological Environmental Safety Assessment/Audit QA Audit Other Documents:

10 CFR 20 (CY 1986)

Calibration Set Points for Model 2241-3, Rev. 1 Event Notification Report Summary 217-18-0760 (53573)

IROFS 333 - U Oxide, IROFS and SRE - Bldg 333 - U Oxide Dissolution, Rev. 35, November 11, 2016 License Number - SNM Amendment 9 License Application -

Chapter 2 (Rev. 5, dated January 3, 2018)

Chapter 4 (Rev. 3, dated January 3, 2018)

Chapter 11 (Rev. 3, dated November 21, 2016)

NFS-MGT-15-046, NFS General Policy, Rev. 1, dated January 8, 2016 Radiation Protection & Health Physics Organization Charts, dated August 21, 2018 Radioactive Material License Radiological Contingency Plan, Rev. 4, dated November 1986

4 SSRC Meeting Minutes/ALARA Reports dated September 7, 2017, December 7, 2017, March 1, 2018, June 7, 2018 Vendor Manuals for:

Ludlum Model 2224-1 Scaler/Ratemeter/ January 2012 Ludlum Model 44-9 Alpha, Beta, Gamma Detector, January 2018 Ludlum Model 44-6 Beta-Gamma Detector, March 2016 PIRCS Written as a Result of the Inspection:

65537, 65556, 65732, 65756, 65758, 66830, 66840, 66869, 66888, 67078, 67090, 67091 PIRCS Reviewed:

61403, 65099, 65102, 65130, 65155, 65182, 65168, 65212, 65220, 65242, 65256, 65278, 65299, 65394, 65391, 65370, 65315, 65408, 65415, 65427, 65370, 65451, 65565, 65577, 65649, 65602, 65664, 65680, 65685, 65696,65714, 65718, 65725, 65743, 66768, 66798, 66810, 66812, 66864, 66840, 66843, 66892, 67012, 67078, 67090, 67091, 67104, 67110, 67118, 67184