ML19213A335

Nuclear Fuel Services, Inc., U.S. NRC Integrated Inspection Report No. 07000143/2019003

ML19213A335
Person / Time
Site:	Erwin
Issue date:	07/31/2019
From:	Robert Williams NRC/RGN-II/DFFI
To:	Stewart J Nuclear Fuel Services
Robert William, DFFI/PB1
References
IR 2019003
Download: ML19213A335 (20)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 July 31, 2019 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 70-143/2019-003

Dear Mr. Stewart:

This letter refers to the inspections conducted from April 1 through June 30, 2019, at the Nuclear Fuel Services, Inc. (NFS) facility in Erwin, TN. The enclosed report presents the results of the inspections. The findings were discussed with members of your staff at the exit meetings held on May 23, 2019, and after the end of the quarter on July 18, 2019.

During the inspections, the Nuclear Regulatory Commission (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. The inspections covered the following areas: safety operations, radiological controls, facility support, and other areas. 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 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.

2 J. Stewart Should you have any questions concerning these inspections, please contact Joel Rivera-Ortiz of my staff at 404-997-4825.

Sincerely,

/RA/

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

Enclosure:

NRC Inspection Report 70-143/2019-003 w/

Attachment:

Supplemental Information cc: (See page 3)

3 J. Stewart 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

ML19213A335 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DC RII:DFFI NAME LHarris JRivera Ortiz BAdkins DAnderson PStartz LPitts R William DATE 07/29/2019 07/26/2019 07/25/2019 07/26 /2019 07/26/2019 7/17/2019 07/31/2019 U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70-143 License No.: SNM-124 Report No.: 70-143/2019-003 Enterprise Identifier: I-2019-003-0032 Licensee: Nuclear Fuel Services, Inc.

Facility: Nuclear Fuel Services, Inc.

Location: Erwin, TN 37650 Dates: April 1, 2019 through June 30, 2019 Inspectors: L. Harris, Senior Resident Inspector (Sections A.1-A.3, A.5, B.1, C.1-C.3, D.1)

B. Adkins, Senior Fuel Facility Inspector (Section A.4)

D. Anderson, Fuel Facility Inspector (Section A.4)

P. Startz, Fuel Facility Inspector (Section C.4)

Approved by: R. E. Williams Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Enclosure

EXECUTIVE

SUMMARY

Nuclear Fuel Services, Inc.

NRC Integrated Inspection Report 70-143/2019-003 April 1 - June 30, 2019 Inspections were conducted by the resident and regional inspectors during normal and off-normal hours in safety operations, radiological controls, facility support, 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.

Safety Operations

• The licensee performed plant operations safely and in accordance with license requirements. The licensee properly implemented and maintained the intended safety function of the selected items relied on for safety. No violations of more than minor significance were identified in this area. (Paragraphs A.1 and A.2)

• The Nuclear Criticality Safety Program was implemented in accordance with license application and regulatory requirements. No violations of more than minor significance were identified. (Paragraphs A.3 and A.4)

• The Fire Protection Program and systems were adequately maintained in accordance with the license application and regulatory requirements. No violations of more than minor significance were identified. (Paragraph A.5)

Radiological Controls

• The Radiation Protection Program was implemented in accordance with the license application and regulatory requirements. No violations of more than minor significance were identified. (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. No violations of more than minor significance were identified.

(Paragraphs C.1 and C.2)

• Adverse conditions were adequately identified, evaluated, and entered into the Corrective Action Program. No violations of more than minor significance were identified. (Paragraph C.3)

• The Plant Modifications program was implemented in accordance with the license application and regulatory requirements. No violations of more than minor significance were identified. (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)

Attachment:

Supplemental Information 3

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 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 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 4

condition of bulk chemical storage tanks and piping, storage of compressed gas containers, as well as 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 to determine the overall status of the plant. The inspectors evaluated the adequacy of the licensees response and approach to resolve safety-significant plant issues during these meetings.

b. Conclusion

No violations of more than minor significance were identified.

2. Safety System Walkdown Inspection (Inspection Procedure 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 that 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. The inspectors selected safety-significant functions, tests, and inspections that were established to assure operability of the safety systems in the Recovery Area D and Area 700 in the production area. For Recovery Area D, the inspectors reviewed IROFS identified as: FAD-1, FAD-2, FAD-3, FAD-8, FAD-10, FAD-17, FAD-23, FAD-24, FAD-25, FAD-26, FAD-27, FAD-28, FAD-29, FAD-33, FAD-35, FAD-36, FAD-37, FAD-38, FIRED-1, FIRED-3, FIRED-5, and FIRED-

6. For Area 700 the inspectors reviewed IROFS identified as: FA6-022, FA7-1, FA7-3, FA7-4, FA7-5, FA7-6, FA7-7, FA7-8, FA7-9, FA7-22, FA7-23, FA7-24, FA7-26, FA7-31, FA7-34, FA7-38, FA7, 39, FA7-40, and FIRE6-6.

To determine the correct system alignment, the inspectors reviewed procedures, drawings, related sections of the ISA, 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

• correct valve position and potential functional impacts such as leakage 5

• electrical power availability

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

• hangers and supports correctly installed

• functional lockout/tag-put 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 (Inspection Procedure 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 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. Nuclear Criticality Safety (Inspection Procedure 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 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 they were consistent with the commitments in the license application, including consideration of the double contingency principle, assurance of subcriticality under normal and credible abnormal conditions with the use 6

of subcritical margin, technical practices and methodologies, and treatment of NCS parameters. The NCSEs were selected based on factors such as risk significance, heavy reliance on administrative controls or unusual control methods, operating history, and whether they were new or revised. The NCSEs reviewed were associated with specific enclosures and processes in the BPF and Commercial Development Line (CDL), as listed in Section 4 of the attachment to this report.

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 BPF.

Criticality Implementation The inspectors performed walk-downs of the BPF uranium metal dissolution and down blending processes to determine whether existing plant configuration and operations were covered by, and consistent with, the process description and safety basis in the selected NCSEs for the BPF and CDL processes. The inspectors reviewed process and system descriptions, drawings, and procedures to verify that engineered controls established in the NCSEs were included and being implemented as specified. The engineered controls reviewed included BDB-14, BPF-19, BPF-20, and BPF-34. The inspectors verified that selected administrative controls established in the NCSEs were properly translated into operating procedures. The administrative controls reviewed included BDB-1, and BDB-9. The inspectors interviewed operators and engineers to verify that administrative actions established in the NCSEs were understood and implemented as specified.

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.

Criticality Operational Oversight The inspectors reviewed records of NCS audits and accompanied a licensee NCS engineer on a weekly inspection of Areas 302 and 400 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, Auditing, Assessing, and Upgrading the NCS Program. The records of NCS audits reviewed included NCS-2019-07, NCS-2019-08, NCS-2019-09, NCS-2019-10, and NCS-2019-11.

The inspectors reviewed the applied management measures for selected NCS IROFS to determine whether the management measures were sufficient to ensure the availability and reliability of NCS IROFS controls. The management measures and NCS IROFS reviewed were selected from the NCSEs for the BPF and CDL processes.

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Criticality Programmatic Oversight The inspectors reviewed selected NCSEs for the BPF and CDL processes to verify that they were performed in accordance with NCS program procedures and received appropriate independent review and approval.

The inspectors reviewed NCS staff qualification records and conducted interviews to verify that NCS engineers and senior NCS engineers had the necessary education and experience and were qualified in accordance with license requirements. The inspectors interviewed the licensees new NCS engineer and reviewed the new engineers training and qualification records to verify the engineer had the required education and experience and was being qualified in accordance with license requirements.

The inspectors reviewed two plant modifications involving NCS controls to determine if the licensee conducted adequate oversight of the changes including review of the modification packages prior to approval and implementation. The following changes were reviewed: ECR-20181229 and 20181538.

Criticality Incident Response and Corrective Action The inspectors reviewed various aspects of the criticality accident alarm system (CAAS) to determine whether the CAAS features met the applicable regulatory requirements in 10 CFR 70.24, and license commitments in Sections 4 and 5 of the license application.

The inspectors reviewed records to determine whether: a) CAAS detector operability was maintained, b) detectors were calibrated, c) all components were functionally tested, d) alarm setpoints were set to promptly actuate upon detecting the minimum accident of concern, and e) access to alarm setpoints was strictly controlled as required. The records reviewed are included in Section 4 of the report attachment.

The inspectors interviewed personnel and reviewed records to determine whether the licensee maintained NCS related emergency response capability consistent with emergency plans and procedures. The inspectors reviewed records to verify that qualified NCS staff was readily available to advise the licensee in an emergency. The inspectors reviewed emergency procedures to determine if these contained instructions to evacuate personnel to accountability points in the event of a CAAS alarm, whether evacuation routes and accountability points were designed to minimize the potential for exposing evacuating personnel to radiation, whether NCS related evacuation drills were conducted consistent with license commitments and whether lessons learned were entered into the licensees CAP.

The inspectors reviewed selected NCS-related CAP entries to verify that anomalous conditions were promptly identified and entered into the CAP, that they received the required level of investigation, and that they were closed out consistent with license commitments and procedures. The inspectors reviewed the associated corrective actions to verify they were sufficiently broad, they were prioritized on a schedule commensurate with their significance, they were completed as scheduled, and they were adequate to prevent recurrence. Additionally, the inspectors reviewed the selected CAP entries to assess whether the licensee followed regulatory requirements and procedures with regards to reporting plant conditions to the Nuclear Regulatory Commission. The CAP entries reviewed included 72862 and 72738.

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

5. Fire Protection Quarterly (Inspection Procedure 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 to determine if they were implemented per site procedures.

The inspectors conducted a walk-down of Production Area 800 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 reviewed a sample of fire-related PIRCS entries to verify that corrective actions were appropriate and that appropriate compensatory actions were implemented, as applicable.

b. Conclusion

No violations of more than minor significance were identified.

B. Radiological Controls

1. Radiation Protection Quarterly (Inspection Procedure 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 associated posted radiologically controlled areas:

• SWP 17244 301RCPT

• SWP 17222 Area 800 Breezeway

• SWP 17257 303 6/7 9

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 observed and/or reviewed a sample of post-maintenance tests (PMTs) 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 for the selected PMTs 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. The safety related equipment (SRE) tests selected for review were:

• SRE Test: N302PSLCWSCWS02

• SRE Test: N303XXXFICS601A

• SRE Test: N303XXXFICS610A

b. Conclusion

No violations of more than minor significance were identified.

2. Surveillance Testing (Inspection Procedure 88135.22)

a. Inspection Scope The inspectors observed portions of and/or reviewed completed test data for the surveillance tests of risk-significant and/or safety-related systems listed below 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. The SRE tests selected for review were:

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• SRE Test: N302FILTERV907

• SRE Test: N333LEVLIT4C01A

• SRE Test: N333LEVLSH4C01B

b. Conclusion

No violations of more than minor significance were identified.

3. Corrective Action Program Review (Inspection Procedure 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. Plant Modifications (Inspection Procedure 88070)

a. Inspection Scope The inspectors reviewed samples of relevant modifications to the uranium processing operations to evaluate if the licensees work control program had adequate requirements to ensure that preparation, review, and approval of plant modification design packages were being completed in accordance with Section 11.1 of the license application and NFS-HS-A-67, Documenting the Safety & Regulatory Review of Facility Changes. The inspectors reviewed a sample of configuration management program procedures to verify that the 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, as described in Section 11.1 of the license application.

The inspectors reviewed samples of plant modification packages including major modifications, minor modifications, administrative changes, 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, as defined in Section 11.1 of the license application.

The following plant modification samples were reviewed:

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• ECR-20171600 Inlet Vestibule Tray Present Transmitter

• ECR-20190054 Solvent Removal/Addition per LOA-2281 W-033, LOA W-034

• ECR-20170880 Off Gas System Improvement

• ECR-20180420 LOA, Install New Pressure Sensors

• ECR-20180168 Set Point Review, Bldg 302/303 Check Valves

• ECR-20180850 LOA-2294X-014-011 Area 800 Operations Blowback Processing

• ECR-20170379 Equivalent for Mettler Toledo Load Cell, Area 200

• ECR-20181094 PSL 600 Start Up Testing

• ECR-20181131 LOA-2294X-050 Acid Flushing of HTEEXCH-0D03

• ECR-20181548 LOA-2325Z-014, Favorable to Unfavorable Transfer, Area E

• ECR-20181528 Required Additional Oversight and Approval for Transfer The inspectors reviewed samples of plant modifications to verify that applicable post maintenance installation and testing requirements were identified and performed prior to turnover to operations in accordance with Section 6.7 of NFS-GH-901, Configuration Management Program. The inspectors reviewed samples of design information to determine if instrument set points accurately reflected the protection of safety limits, considering instrument and calibration uncertainties.

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 documented 10 CFR 70.72 evaluations to determine if the licensee adequately determined whether NRC pre-approval of the change was required, and any required design basis was documented in accordance with procedures FM-ENG-021, Technical Basis, NFS-CM-004, NFS Change Control Process, and 10 CFR 70.64.

The inspectors performed walk-downs of selected modifications to determine if the modifications had been installed in accordance with approved design documents such as drawings and technical reports of the associated work packages.

The inspectors reviewed samples of recent procedure revisions and project design packages, to evaluate compliance with change-management program procedures including NFS-CM-004, NFS Change Control Process; NFS-ENG-001, Engineering Project Design Control; and NFS-HS-A-67, Documenting the Safety and Regulatory Review of Facility Changes. The inspectors evaluated recent revisions and content to determine compliance with Sections 11.1 and 11.4 of the license application.

The inspectors reviewed samples of the licensees CAP to evaluate if issues related to the preparation of change requests and the installation of facility changes were entered into the CAP and were assigned the appropriate corrective actions in accordance with Sections 11.5 and 11.6 of the license application.

b. Conclusion

No violations of more than minor significance were identified.

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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.

These quarterly resident inspectors observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status reviews and inspection activities.

b. Conclusion

No violations of more than minor significance were identified.

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 May 23, 2019, and at the end of the quarter on July 18, 2019, to J. Stewart and staff.

Proprietary and classified information were discussed but not included in this report.

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SUPPLEMENTAL INFORMATION

1. KEY POINTS OF CONTACT Name Title S. Barron Emergency Preparedness Program Manager N. Brown NCS Manager T. Cloyd Fire Protection Engineer 3 M. Eakin NCS Engineer S. Gizzie NCS/ Fire Brigade K. Greer Emergency Services Unit Manager C. Lewis NCS Engineer D. Mann NCS Engineer J. Marshall NCS Engineer J. May Transportation and Waste Management Operations Unit Manager A. Morie Safety & Program Manager R. Rice Radiation Safety E. Shelton BPF Supervisor S. Skiles NCS Engineer R. Storey Configuration Control Manager

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

3. INSPECTION PROCEDURES USED 88015 Nuclear Criticality Safety 88070 Plant Modifications 88135 Resident Inspection Program for Category I Fuel Cycle Facilities 88135.02 Resident Inspection Program Plant Status Activities 88135.04 Resident Inspection Program Operational Safety 88135.05 Resident Inspection Program Fire Protection 88135.17 Permanent Plant Modifications 88135.19 Post Maintenance Testing 88135.22 Surveillance Testing

4. DOCUMENTS REVIEWED Records:

Criticality Alarm Speaker Function Record - Non-SNM Areas, Qtr 1 - 4, 2018, Qtr 1 2019 Criticality Alarm Speaker Function Record - SNM Areas, Jan 2018 - Apr 2019 ECR 20170868 ECR 20190579 ETA-NFS-IA-18-001, Revision 0, Audit of the NFS Configuration Management Program, performed by Edgewater, November 9, 2018 April 5, 2018 HEU Downblending Runsheet 333-15-1, Sales Order 23282, Batch No. 333-HEUFS-446, 4/12/19 IROFS BDB-2, Weekly Trap Check Tank 4C01 Runsheet #333-16-1, 2/4/19 - 5/20/19 N333AIRGAP3E01, Procedure IROFS 333-UGENER, 1/21/19 Attachment

N333LEVELLS4C01, IROFS 333-UDOWNB, 3/22/19 N333MONITRE4B11, SRE Test BDB-10, 5/3/19 N333VALPSHL7N01, Procedure IROFS 333-UGENER, 1/2/19 N333VALPSHL7N03, Procedure IROFS 333-UGENER, 1/4/19 N333VALVPSL7D01, Procedure IROFS 333-UGENER, 4/12/19 N333VALVPSL7D02, Procedure IROFS 333-UGENER, 1/21/19 N333XOVRFLO3E01, Procedure IROFS 333-UGENER, 4/10/19 NFS Assay Request Analysis Report, Sample No. 005013895 and 005013909, 4/12/19 SOP 409, Section 62, Building 301 Off-Gas System Attachment B, Building 301 Enclosure and Off-Gas Log Run Sheet 62A, Rev. 8 dated,1/21/19, 2/8/19. 2/9/19, 2/10/19, 2/11/19, 2/12/19 and 2/13/19 SOP 409, Section 63-301, Rev. 11, Attachment C, Scrubber Daily Monitoring, RS-409-63A-301, dated 2/18/19 and 5/21/19 Procedures:

21T18-0752, HEA-20, ARM-18-053, IROFS 333 UGENER, Rev. 49 21T18-0753, HEA-20, ARM-18-054, IROFS 333 UOXIDE, Rev. 36 ENG-EPS-A-003, Revision (Rev.) 9, Setpoint Verification and Design Parameter Documentation FM-ENG-021, Technical Basis, Rev. 012 NFS-CM-002, Identification and Control of Configuration Items, Rev. 9 NFS-CM-004, NFS Change Control Process, Rev. 19 NFS-CM-005, NFS Change Control Board, Rev. 7 NFS-ENG-001, Engineering Project Design Control, Rev 15 NFS-GH-42, Safety Related Equipment Control Program, Rev. 29 NFS-GH-901, Configuration Management Program, Rev. 21 NFS-HS-A-16, Safety Audits, Assessments, and Inspections, Rev. 16 NFS-HS-A-58, Nuclear Criticality Safety Evaluations (NCSE), Rev. 14 NFS-HS-A-67, Documenting the Safety & Regulatory Review of Facility Changes, Rev. 15 NFS-HS-A-84, Operation of the Downblending In-Line Monitoring System, Rev. 4 NFS-HS-E-02, Emergency Criticality Evacuation, Rev. 46 NFS-HS-E-07, On-Site Radiological Emergency Assessment NFS-M-17, , Calibration System Manual, Rev. 28 NFS-NCSE-NCSWG, Nuclear Criticality Safety Evaluation/Analysis Writers Guide, Rev. 10 NFS-NCSQUALP, Nuclear Criticality Safety Criticality Safety Engineer Qualification Program, Rev. 1 NFS-OPS-001, Conduct of Operations Rev. 11 NFS-TS-009, Configuration Management of Process Change, Rev. 8 SOP-409, HEU Downblending Operations, Rev. 25 Other Documents:

2019 Site ISA Summary Bleu Preparation Facility, Rev. 17, Jan 2019 54T-08-0010, Nuclear Criticality Safety Evaluation BLEU Preparation Facility Downblending, Rev. 8 54T-10-0039, NCS-07-01, Nuclear Criticality Safety Evaluation for the CDL Process Ventilation System, Rev. 4 54T-19-001, NCS-07-01, Nuclear Criticality Safety Evaluation for the CDL Process Ventilation System, Rev. 5 Setpoint Analysis I.D. SA-00322, Setpoint Analysis for Gamma Detector Calibration Response, 9/24/14 Setpoint Analysis I.D. SA-00323, Rev. 2 2

Summary of Results for Criticality Alarm System Analysis Building 105, Rev. 0 PIRCS Written as a Result of the Inspection:

73876, 73914, 73946, 75228 PIRCS Reviewed:

25032, 27419, 32415, 34100, 35290, 35422, 65288, 65289, 65367, 65430, 65473, 65566, 65625, 67514, 67598, 67753, 67833, 67912, 70262, 70457, 71938, 71969, 72167, 72413, 72461, 72465, 72471, 72485, 72543, 72560, 72632, 72666, 72712, 72738, 72787, 72849, 72841, 73969, 75181, 75184, 75187, 75235 3