ML20029E884

Nuclear Fuel Services, Inc. U. S. Nuclear Regulatory Commission Integrated Inspection Report Number 70-143/2019-005

ML20029E884
Person / Time
Site:	Erwin
Issue date:	01/28/2020
From:	Robert Williams NRC/RGN-II/DFFI/FFB1
To:	Stewart J Nuclear Fuel Services
J. Rivera-Ortiz RGN-II/DFFI
References
EN 54218 IR 2019005
Download: ML20029E884 (19)

Text

January 28, 2020 EN 54218 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 70-143/2019-005

Dear Mr. Stewart:

This letter refers to the inspections conducted from October 1 through December 31, 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 an exit meeting held on November 7, 2019, and with you at an exit meeting held on January 16, 2020.

The inspections examined activities conducted under your license as they relate to public health and safety, the common defense and security, and compliance with the Commission's rules and regulations as well as 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.

J. Stewart 2 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 70-143/2019-005 w/

Attachment:

Supplemental Information cc w/ encl: Distribution via LISTSERV

ML20029E884 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFI RII: RII: DFFI RII: RII: RII: RII: RII: DFFI RII: RII: DFFI RII: DFFI NAM LHarris JRivera DEdwar BAdkin LCooke GGoff NPeterk LPitts TSippel RWilliams DATE 1/14/20 1/16/202 1/9/202 1/15/2 1/14/20 1/13/20 1/14/202 1/16/2 1/7/2020 1/28/2020 U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70-143 License No.: SNM-124 Report No.: 70-143/2019-005 Enterprise Identifier: I-2019-005-0014 Licensee: Nuclear Fuel Services, Inc.

Facility: Nuclear Fuel Services, Inc.

Location: Erwin, TN 37650 Dates: October 1 through December 31, 2019 Inspectors: L. Cooke, Fuel Facility Inspector (Section A.6)

G. Goff, Fuel Facility Inspector (Section A.6)

L. Harris, Senior Resident Inspector (Sections A.1 - A.3, A.5, B.1, C.1-C.3, and D.1)

N. Peterka, Fuel Facility Inspector (Section A.4, D.2)

L. Pitts, Senior Fuel Facility Inspector (Section A.6)

T. Sippel, Fuel Facility Inspector (Section A.4, D.2)

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

EXECUTIVE

SUMMARY

Nuclear Fuel Services, Inc.

U.S. NRC Integrated Inspection Report 70-143/2019-005 October 1 - December 31, 2019 Resident and regional inspectors from the U.S. Nuclear Regulatory Commission (NRC), Region II Office, conducted inspections during normal and off-normal hours in the areas of safety operations, radiological controls, facility support, as well as other areas. The inspectors performed a selective examination of licensee activities by direct observation of safety significant activities and equipment, walk-downs of the facility, interviews and discussions with licensee personnel, and review of facility records.

Safety Operations

• No violations of more than minor significance were identified in the area of operational safety. (Sections A.1 and A.2)

• No violations of more than minor significance were identified related to the Nuclear Criticality Safety Program. (Section A.3 and A.4)

• No violations of more than minor significance were identified related to the Fire Protection Program. (Section A.5 and A.6)

Radiological Controls

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

Facility Support

• No violations of more than minor significance were identified in the area of post-maintenance and surveillance testing. (Sections C.1 and C.2)

• No violations of more than minor significance were identified in the area of identification and resolution of corrective actions. (Section C.3)

Other Areas

• No violations of more than minor significance were identified during Resident Inspector observations of security force and material control and accounting personnel. (Section D.1)

• A minor violation was identified related to Event Notification 54218, Criticality Accident Alarm System Speaker Failure in Building 333 LEU and its associated 30-day written event report (WER) 70-143/2019-001-00. This item is considered closed. (Section D.2)

Attachment:

Supplemental Information 2

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 During the inspection period, the inspectors performed routine walk-downs of fuel manufacturing areas housing special nuclear material (SNM), including the FMF, BPF, commercial development line areas, miscellaneous storage areas, the Waste Water Treatment Facility (WWTF), and Building 440 to assess the operational status of those areas. Primarily, the inspectors performed the walk-downs to verify that safety controls, including items relied on for safety (IROFS), were in place, properly labeled, and functional to ensure proper control of SNM.

During the walk-downs, the inspectors interviewed operators to verify they were knowledgeable of their duties and attentive to any alarms or annunciators at their respective stations. The inspectors also observed and reviewed the interactions between supervisors and operators within the operating areas to verify that their communications supported safe operation of licensed activities. The inspectors observed activities during normal and upset conditions to verify that operators complied with procedures and material station limits.

The inspectors performed periodic tours of the outlying facility areas to verify that equipment and systems were operated safely and in compliance with the license. The inspectors focused on potential wind-borne missile hazards, potential fire hazards with combustible material storage and fire loading, hazardous chemical storage, the physical condition of bulk chemical storage tanks and piping, storage of compressed gas containers, as well as potential degradation of plant security features.

The inspectors interviewed plant staff assigned to different disciplines to discuss issues regarding plant equipment. Particularly, the inspectors interviewed operators, front-line managers, maintenance technicians, engineers, radiation protection (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 inspectors reviewed operator log books, standard operating procedures, maintenance records, and Letters of Authorization (i.e., temporary procedures) to obtain information concerning operating trends and activities. The inspectors also reviewed the licensees implementation of corrective actions for conditions requiring temporary modifications and compensatory measures to verify adherence to plant procedures.

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The inspectors observed operational and shift turnover meetings throughout the inspection period to gain insight into safety and operational issues. The inspectors attended various plan-of-the-day meetings and met daily with the Plant Shift Superintendent to assess the overall status of the plant and the licensees corrective actions to resolve safety-significant issues identified in these meetings.

b. Conclusion

No violations of more than minor significance were identified.

2. Safety System Walk-down Inspection (Inspection Procedure 88135.04)

a. Inspection Scope The inspectors reviewed procedures, drawings, related sections of the Integrated Safety Analysis (ISA) Summary, and the license application to identify design attributes, safety functions, tests, and inspections applicable to selected safety-significant systems involved with the processing of SNM. The safety systems selected for review were in Building 301-Calciner; Building 302-Areas A, B, and C; and Building 303-Area B in the production area. The inspectors performed walk-downs of the systems to verify, in part, that system alignment and as-built configurations matched approved plant drawings and that IROFS assumptions and controls were properly implemented in the field. The inspectors also 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 reviewed ISAs for the selected plant systems to verify that their safety functions were not affected by outstanding design issues, temporary modifications, operator workarounds, adverse conditions, or other system-related issues. The inspectors reviewed plant conditions in the selected process areas to verify that the performance and operability of IROFS, safety-related devices, or other support systems essential to safety system performance were not degraded.

During the walk-downs, the inspectors considered the following attributes on a sampling basis and as applicable to the selected systems:

• 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 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 4

The inspectors reviewed the IROFS listed below to verify their implementation in accordance with the applicable requirements in the license application and Title 10 of the Code of Federal Regulations, Part 70 (10 CFR 70).

• Building 301: IROFS identified as CRF-3, CRF-5 through CRF-12, CRF-15, CRF-16, CRF-20 through CRF-26

• Building 302-Areas A, B, and C: IROFS identified as FAA-1, FAB-1, FAB-4 through FAB-8, FAB-11 through FAB-13, FAB-15, FAC-8, and FAC-10 through FAC-12.

• Building 303-Area B: IROFS identified as FAB-1, FAB-5 through FAB-8, FAB-13, FAB-14, and FAB-16

b. Conclusion

No violations of more than minor significance were identified.

3. Nuclear Criticality Safety (Inspection Procedure 88135.02)

a. Inspection Scope The inspectors performed daily production area walk-downs to verify that 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 several criticality-related IROFS for operability and interviewed operators to verify that they were knowledgeable of the requirements associated with the IROFS. The inspectors performed walk-downs 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. The inspectors reviewed the licensees response to such entries and held discussions with NCS engineers and production personnel to understand their safety significance and verify compliance with site 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 evaluated selected aspects of the licensees NCS program to verify compliance with the applicable portions of 10 CFR 70, including 70.24, 70.61b, 70.61d, 70.61e, 70.62d; Chapter 5, Nuclear Criticality Safety, of the facilitys license application; and applicable licensee procedures.

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The inspectors reviewed the assumptions and calculations in selected nuclear criticality safety evaluations (NCSEs) to verify that they were consistent with the commitments in the license application. These commitments included the Double Contingency Principle, assurance of subcriticality under normal and credible abnormal conditions with the use of subcritical margin, having qualified staff review and approve NCSEs, having NCSEs in place prior to conducting new or changed operations, and performing calculations within their validated area of applicability. The NCSEs were selected based on factors such as whether they were new or revised, their operating history, and the length of time since they were last inspected by the NRC. The NCSEs reviewed are listed in Section 4 of the attachment to this report.

The inspectors reviewed NCSEs for plant Areas 300/400 and 800. The inspectors reviewed the licensees generation of accident sequences for these areas 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. The inspectors reviewed assumptions made for upset conditions to verify they were clearly described, appropriately conservative, and matched the calculation input files. The inspectors also reviewed the protection and prevention scores assigned in the accident sequences to determine whether they were consistent with procedural guidance for the IROFS type and resulted in the scenario being highly unlikely as required by 10 CFR 70.61(b).

The inspectors reviewed the validation report applicable to the selected NCSEs to verify that changes to the report, if any, were in compliance with the validation techniques described in Chapter 5 of the license application.

Criticality Implementation The inspectors performed walk-downs of Areas 300, 400, 800, E, and the 105 Lab to determine whether existing plant configuration and operations were covered by, and consistent with, the process description and safety basis in the NCSEs for these areas.

The inspectors reviewed control flow-downs, drawings, and setpoint analyses to verify that engineered controls established in the NCSEs were included and being implemented as specified. The drawings and setpoint analyses selected for review are listed in the attachment to this report.

The engineered controls reviewed for the selected areas included IROFS FA8-15, FA8-21, and FA8-37. The inspectors interviewed operators and walked down equipment to verify that selected administrative controls established in the NCSEs were understood and implemented as specified. The administrative controls reviewed included IROFS 300-23. The inspectors reviewed the ISA summary and supporting ISA documentation to determine whether selected controls listed above were consistent with the NCSEs and were identified as IROFS in the ISA as required by 10 CFR 70.61(e).

Criticality Operational Oversight The inspectors reviewed NCS-related training material for contractors involved in teardown work to determine whether licensee-provided training was consistent with the commitment in Section 5.3.2 of the license application to comply with the training requirements of the 1991 revision of American Nuclear Society Standard 8.20, Nuclear Criticality Safety Training. Additionally, the inspectors interviewed operations staff in 6

Area 800 to determine whether they were cognizant of NCS hazards and control methods related to their specific job function. The NCS-related training records reviewed are listed in Section 4 of the attachment to this report.

The inspectors reviewed records of NCS audits and accompanied a licensee NCS engineer on an NCS audit of Area 800 to determine whether NCS staff routinely assessed field compliance with established NCS controls. Additionally, the inspectors interviewed NCS management and reviewed procedures and schedules to verify that audits of fissile material processing or storage facilities were performed on a biennial frequency by qualified NCS engineers as required by Section 5.3.4 of the license application. The records of NCS audits reviewed included those listed in Section 4 of the attachment to this report. The inspectors also interviewed NCS staff and reviewed the log of NCS Inspections performed by qualified NCS staff to verify that the licensees NCS engineers were performing weekly inspections as required by Section 5.3.4 of the license application.

The inspectors reviewed assumptions in the NCSEs listed above to verify that the licensee addressed accident sequences related to material accumulation. Additionally, the inspectors walked-down ventilation drains in Area 800 and safe geometry controls to verify that the licensee established controls to prevent criticality due to long-term accumulations. The inspectors reviewed lab sampling processes and uranium hold-up assumptions to verify that common-mode failure was addressed and measurement error provided sufficient margin.

Criticality Incident Response and Corrective Action The inspectors reviewed selected NCS-related entries in the PIRCS to verify that conditions adverse to criticality safety were entered into the system and that NCS staff reviewed these conditions for NCS implications. The inspectors reviewed selected corrective actions to verify that the documented conditions were fixed and that NCS staff was involved in the corrective actions. Additionally, the inspectors reviewed the selected PIRCS entries to assess whether the licensee followed regulatory requirements and procedures with regard to reporting plant conditions to the NRC. The PIRCS entries reviewed are listed in Section 4 of the attachment.

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 reviewed licensee controls for transient combustibles in selected process areas to verify compliance with the Fire Protection Program as described in Chapter 7 of the license application. The inspectors reviewed active fire impairments in selected process areas to determine if they were implemented per site procedures.

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The inspectors conducted a walk-down of production areas in Building 303, reviewed scheduled surveillances, and reviewed the pre-fire plan drawing to verify it matched the as-found condition of 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 identified and implemented in accordance with the license application and licensee procedures.

b. Conclusion

No violations of more than minor significance were identified.

6. Triennial Fire Protection (Inspection Procedure 88054)

a. Inspection Scope The inspectors reviewed selected aspects of the licensees fire protection program to determine whether the licensee established a program capable of precluding or mitigating the consequences of a fire in accordance with the requirements of Chapter 7 of the license application, the ISA Summary, and 10 CFR 70.

The inspectors reviewed licensee procedures and walked-down plant areas containing safety controls and IROFS to assess the material condition of passive fire protection equipment, systems, and features such as fire dampers, doors, and penetration seals.

The inspectors conducted these walk-downs to verify that passive fire protection features were maintained in a condition that would ensure availability and reliability to perform their intended safety function. The inspectors also walked-down systems, reviewed records and procedures, and interviewed licensee personnel to verify that fire detection and suppression systems were maintained in working condition, serviced by a fire water supply and distribution system, and met the requirements of the areas Fire Hazards Analysis (FHA). The inspectors reviewed inspection and testing records of fire protection systems to verify that the inspection and testing was appropriate for the credible fire hazards.

The inspectors reviewed changes in the facility pre-fire plans for the 300 Complex and 310 Warehouse to verify that the changes were consistent with the facility FHAs. The inspectors walked-down selected areas with the pre-fire plans to verify that fire hoses, portable extinguishers, and other firefighting equipment were provided at their designated locations and that access to the equipment was unobstructed.

The inspectors toured selected plant areas to verify that transient combustibles were controlled in accordance with approved procedures and that flammable materials were stored in marked cabinets in accordance with National Fire Protection Association (NFPA) 30, Flammable and Combustible Liquids Code. The inspectors reviewed licensee activities for controlling hot-work ignition sources to verify compliance with approved procedures.

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The inspectors interviewed staff to verify that the licensees fire protection program had provisions to control hazardous effluents that could result from firefighting activities. The inspectors walked down containment systems to identify licensee measures to limit the spread of contamination resulting from sprinkler activation and fire hose water runoff.

The inspectors reviewed communications systems to verify that the licensees programs and procedures ensured that communications would be available and reliable in fire response activities. The inspectors walked down fixed emergency lighting to verify that the equipment was being maintained in accordance with NFPA 101, Life Safety Code.

The inspectors reviewed the licensees fire protection system impairment records to verify that compensatory measures were in place for out-of-service, degraded, or inoperable fire protection equipment, systems, or features. Additionally, the inspectors reviewed program audits to ensure that they were routinely performed and that audit findings were captured in the PIRCS. The inspectors reviewed selected PIRCS entries to verify that issues were prioritized and corrected in accordance with program procedures.

The inspectors observed fire brigade training to verify compliance with the training requirements listed in 27T-19-2059, NFS Training Department Lesson Plan. The inspectors also reviewed training records for selected fire brigade members to verify that they were trained at the required frequency.

The inspectors reviewed changes made to the fire protection organizational structure to verify they were properly documented and conducted in accordance with Chapter 7 of the license application.

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 observed plant workers to verify they properly wore dosimetry and used protective clothing in accordance with applicable Special Work Permits (SWPs). The inspectors also reviewed radiation area postings to verify compliance with plant procedures and included radiation maps with up-to-date radiation levels. The inspectors observed a sample of RP instruments to verify their operation and calibration dates were consistent with plant procedures.

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The inspectors performed a review of selected SWPs in effect during the inspection period in different operational areas and conducted a more thorough review for SWPs 333UMET and 19-32-031, and their associated posted radiologically controlled areas, to verify that the SWPs contained the information required by the licensees procedures.

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 reviewed records and observed a sample of post-maintenance tests (PMTs) to verify that procedures and test activities confirmed the operability and functional capability of safety systems and components (SSCs) 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 reviewed test data to verify that test results adequately demonstrated restoration of the affected safety function(s). The inspectors conducted field observations to verify that PMT activities were conducted in accordance with applicable work order instructions or licensee procedural requirements.

Furthermore, the inspectors reviewed PIRCS entries to verify that problems associated with PMTs were identified and entered into the system for resolution. The safety-related equipment (SRE) tests selected for review were:

• N303VALVETG1903

• N307VALVEBAB864

• N307VALVEBAB870

• N307VALVEBAB8D4

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 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.

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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 and observed the communications between personnel performing these tests to verify adherence to plant procedures. The SRE tests selected for review were:

• N333VALVEBA2I52

• N303VALVEBAA525

• N303VALVEBAA601

• N303VALVEBAB601

b. Conclusion

No violations of more than minor significance were identified.

3. Problem Identification Resolution and Correction System Review (Inspection Procedure 88135)

a. Inspection Scope The inspectors reviewed the implementation of the licensees corrective action program through the PIRCS to ensure that items adverse to safety were being identified and tracked to closure in accordance with the license application and 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 identify repetitive equipment failures or specific human performance issues adverse to safety for follow-up. The inspectors reviewed PIRCS entries that occurred during the inspection period to determine whether the licensee prioritized the issues commensurate with their safety significance. Additionally, the inspectors verified whether the licensee was implementing measures to prevent recurrence in accordance with 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.

2. Event Follow-up

a. Written Event Report 70-143/2019-001-00, Criticality Accident Alarm System Speaker Failure in Building 333 Low Enriched Uranium (Event Notification 54218)

On August 13, 2019, during announcements to support a stop movement of SNM around the site, the licensee discovered that the criticality accident alarm system (CAAS) speaker in the Building 333 Low Enriched Uranium (LEU) high bay was inoperable. As a result, the licensee determined that there was no CAAS annunciator coverage in that area. Upon discovery, compensatory measures were implemented, and the affected speaker was replaced later that day. The affected speaker had previously been tested on August 08, 2019 and was considered operable. On August 14, 2019, the licensee reported the condition to the NRC via Event Notification (EN) 54218, followed by a written event report (WER) dated September 12, 2019 (ADAMS ML19262D347).

b. Conclusion

Title 10, CFR 70.24(a) states, in part, that the licensee shall maintain in each area in which such licensed special nuclear material is handled, used, or stored, a monitoring system meeting the requirements of either paragraph (a)(1) or (a)(2), as appropriate, and using gamma- or neutron-sensitive radiation detectors which will energize clearly audible alarm signals if accidental criticality occurs. Contrary to the above, sometime after August 8, 2019, the licensee failed to maintain a monitoring system that would energize clearly audible signals in Building 333 LEU if a criticality would have occurred.

The inspectors determined that there were no actual safety consequences associated with this reportable event. The licensee documented the failure in the PIRCS, promptly corrected the condition, and determined that the likely cause of the speaker failure was age-related degradation. The licensee continued with previously planned site upgrades to the CAAS detectors and speakers. This failure to comply with 10 CFR 70.24(a) 12

constitutes a minor violation in accordance with the guidance in NRC Inspection Manual Chapter 0616, Fuel Cycle Safety and Safeguards Inspection Reports, Appendix B, Example 2.k, and the examples in Section 6.2 of the NRC Enforcement Policy, dated May 28, 2019. This minor violation is not subject to enforcement action in accordance with Section 2.2.2 of the NRC Enforcement Policy. This item is considered closed.

E. Exit Meetings The inspection scope and results were presented to members of the licensees staff at an exit meeting held on November 7, 2019, and to J. Stewart and staff at a second exit meeting on January 16, 2020. Proprietary and classified information were discussed, but not included in this report.

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SUPPLEMENTARY INFORMATION

1. KEY POINTS OF CONTACT Name Title Z. Bass Manager, Fuels Operation N. Brown Unit Manager, Nuclear Criticality Safety J. Buckles Fire Protection Specialist B. Campbell Fire Protection Engineer T. Cloyd Fire Protection Specialist J. Coleman Fire Protection Specialist S. Gizzie Unit Manager, Integrated Safety Analysis and Fire Protection C. Lewis Engineer 4, Nuclear Criticality and Safety D. Mann Engineer 2, Nuclear Criticality and Safety J. Marshall Engineer 2, Nuclear Criticality and Safety A. Morie Acting Licensing Manager K. Odum Training Specialist, Fire Brigade Assistant Chief, Training Officer E. Senter Principal Technical Specialist, Integrated Safety Analysis and Fire Protection R. Shackleford Section Manager, Nuclear Safety & Licensing J. Stewart President, Nuclear Fuel Services

2. LIST OF ITEMS OPENED, CLOSED AND DISCUSSED Closed WER 70-143/2019-001-00 Criticality Accident Alarm System Speaker Failure in Building 333 LEU (EN 54218) (Section D.2)

3. INSPECTION PROCEDURES USED 88015 Nuclear Criticality Safety 88054 Fire Protection (Triennial) 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 88135.19 Post Maintenance Testing 88135.22 Surveillance Testing

4. DOCUMENTS REVIEWED Records:

30-Day Written Notification of Event (NRC Event No. 54218), dated September 12, 2019 54X-00-0019, Nuclear Criticality Safety Analysis for 105/302/303 Laboratory of the Production Fuel Facility, Rev. 1 54X-08-0011, Addendum 3 to Revision 1 of the Nuclear Criticality Safety Analysis for 105/302/303 Laboratory of the Production Fuel Facility, Rev. 1 54X-13-0006, Nuclear Criticality Safety Evaluation 6-inch rocket storage in 105 Laboratory, Rev. 0 Attachment

54X-16-0004, Nuclear Criticality Safety Evaluation for Nominal 6-Inch Diameter Borosilicate Glass Columns, Rev. 1 54X-16-0010, Nuclear Criticality Safety Evaluation for the Storage of Mounts and Discs in 105 Laboratory Stations 20, 21A, 21B, 22, 79, 108, and 109, Rev. 1 54X-18-0001, Nuclear Criticality Safety Evaluation for Area 300/400 of the Production Fuel Facility, Rev. 2 54X-18-0006, Nuclear Criticality Safety Evaluation for Area E of the Uranium Recovery Facility, Rev. 7 54X-19-0004, Nuclear Criticality Safety Evaluation for Area 800 of the Production Fuel Facility, Rev. 11 Apparent Cause Evaluation #I28171 Building 302 Pre-Fire Plan 33, May 17, 2019 Building 303 Pre-Fire Plan 34, May 17, 2019 Building 304, Storage Warehouse Pre-Fire Plan 36, May 17, 2019 Building 307 Pre-Fire Plan 58, May 17, 2019 Building 310, Warehouse Pre-Fire Plan 40, May 17, 2019 FHA Building 302, Rev. 0, September 28, 2018 FHA Building 303, Rev. 1, September 28, 2018 FHA Building 304, Rev. 0, September 28, 2018 FHA Building 309, Rev. 0, March 8, 2019 FHA Building 306E, Rev. 0, April 18, 2019 FHA Building 30S, Rev. 0, March 29, 2019 FHA Building 30W, Rev. 0, September 19, 2019 FHA Building 307 & 306W Area 800, Rev. 0, August 13, 2019 Fire System Impairments: 2018-014; 2019-014, 025, 055, 076, 086 N306VENDRAIN008, Rev. 4, completed October 23, 2019 N306XFILTERA811, Rev. 3, completed August 8, 2019 N306XOVRFLOA802, Rev. 3, completed August 15, 2019 N306XOVRFLOB804, Rev. 1, completed November 19, 2017 N307VENDRAIN031, Rev. 4, completed July 11, 2019 N307XFILTERI811, Rev. 3, completed August 11, 2019 N307XOVRFLOB802, Rev. 3, completed July 8, 2019 NCS-2019-08, Nuclear Criticality Safety Audit of the Nuclear Criticality Safety Evaluation for ENCLOS-5901/-9901 of Area 900 of the Production Fuel Facility, Fifth Audit, dated May 7, 2019 NCS-2019-09, Ninth Nuclear Criticality Safety Audit of the Nuclear Criticality Safety Evaluation for Area F of the Uranium Recovery Facility, dated April 26, 2019 NCS-2019-10, Tenth Nuclear Criticality Safety Audit of the Nuclear Criticality Safety Evaluation for Building 100 NDA Laboratory, dated April 25, 2019 NCS-2019-17, Nuclear Criticality Safety Audit of the Nuclear Criticality Safety Evaluation for BPF Process Ventilation System, Seventh Audit, dated June 20, 2019 SA-00095, Setpoint Analysis for FPV-004, dated January 29, 2014 SA-00153, Setpoint Analysis for FA8-15, dated October 7, 2014 SA-00154, Setpoint Analysis for FA8-21, dated February 25, 2014 Training Attendance Records, Fourth Quarter 2019 Fire Brigade Training, November 6, 2019 Procedures:

FM-HS-A-50-01-1 Attachment A, Form for Telephone Notification, EN 54218, dated August 14, 2019 2

NFS-HS-A-21-01 Attachment A, Criticality Alarm Speaker Function Record - SNM Areas, Rev.1 NFS-WST-031, Waste Packaging for Disposal Inside MAA, Rev. 17 NFS-GH-07-02, Respirator Use Instructions, Rev. 4, May 22, 2019 NFS-GH-62-01, NFS Monthly Combustible Control Inspections (for IROFS), Rev. 9, dated March 15, 2019 NFS-GH-62-03, NFS Monthly Combustible Control Inspections (for Non-IROFS),

Rev. 1, dated August 8, 2019 NFS-HS-A-71, Primary Attack Methods (Attachment E), Rev. 9 NFS-HS-A-71-01, Pre-Fire Plan Master Index (Attachment A), Rev. 1 Other Documents:

000-C0001-D, Plant Layout w/Building Descriptions 000-C0106-D, Fire Protection Waterlines with BLEU Facility, September 7, 2017 000-F0377-D, Fire Protection Waterlines Main Water Loop and Supply, December 6, 2017 013-A1000-D 300 Complex Fire Safety Layout, November 29, 2018 27T-19-2059, NFS Training Department Lesson Plan, Emergency Brigade - 4th Quarter 2019 Fire Brigade Training 304-P2026-D, Sprinkler System Layout Building 304 Breezeway and Building 304 Non-nuclear Storage, June 20, 2013 307-F0304-D, Area 800 Piping & Instrumentation Diagram Sheet 11, dated October 17, 2019 Engineering Change Request ECR-20181235 - Change control package for removing the fire pumps and firewater jockey pumps from service Excel file, NCS Inspection Log, accessed on November 7, 2019 Flow Testing of B-304BZW, 304NN, 306W S&R, 306W Sprinkler Systems General Nuclear Criticality Safety (NCS) Refresher, Building 301 D&D, dated September 2019 MA-CRIT-SAFETY, Annual Criticality Safety Training for Maintenance Personnel NFS Triennial Fire Protection Assessment, September 2017 SA-NCSREFRESH, How to Avoid a Criticality Problem, Identification, Resolution, and Correction System (PIRCS) Documents Reviewed:

36640, 52329, 61702, 63053, 63221, 64299, 64953, 64962, 65400, 65759, 67583, 72124, 72340, 73947, 75094, 75105, 75181, 75464, 75466, 75634, 75657, 75660, 75795, 75868, 76167, 76191, 76305, 76326, 76355, 76418, 76462, 76515, 76562, 76581, 77667, 77676, 77698 PIRCS Written as a Result of the Inspections:

75587, 75754, 75821, 75873, 75821, 76025 76031, 76076, 77693, 77694, 77700, 77703 3