ML20118D053

Nuclear Fuel Services, Inc. - U. S. Nuclear Regulatory Commission Integrated Inspection Report Number 70-143/2020-001

ML20118D053
Person / Time
Site:	Erwin
Issue date:	04/27/2020
From:	Robert Williams NRC/RGN-II/DFFI/FFB1
To:	Stewart J Nuclear Fuel Services
References
IR 2020001
Download: ML20118D053 (19)

Text

April 27, 2020 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 70-143/2020-001

Dear Mr. Stewart:

This letter refers to the inspections conducted from January 1 through March 31, 2020, 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 February 13, 2020, and with you at an exit meeting held on April 20, 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 70-143/2020-001 w/

Attachment:

Supplemental Information cc w/ encl: Distribution via LISTSERV

ML2011D053 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB2 RII:DFFI/PB2 RII:DFFI/PB1 NAME L. Harris J. Rivera-Ortiz B. Adkins P. Startz T. Sippel R. Williams DATE 4/15/2020 4/16/2020 4/15/2020 4/15/2020 4/15/2020 4/27/2020

U. S. NUCLEAR REGULATORY COMMISSION REGION II INSPECTION REPORT Enclosure Docket No.:

70-143 License No.:

SNM-124 Report No.:

70-143/2020-001 Enterprise Identifier: I-2020-001-0077 Licensee:

Nuclear Fuel Services, Inc.

Facility:

Nuclear Fuel Services, Inc.

Location:

Erwin, TN 37650 Dates:

January 1 through March 31, 2020 Inspectors:

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

L. Harris, Senior Resident Inspector (Sections A.1-A.3, A.5, B.1, C.1-C.4, and D.1)

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

P. Startz, Fuel Facility Inspector (Section C.5)

Approved by:

R. Williams, Chief Projects Branch 1 Division of Fuel Facility Inspection

EXECUTIVE

SUMMARY

2 Nuclear Fuel Services, Inc.

U.S. NRC Integrated Inspection Report 70-143/2020-001 January 1 - March 31, 2020 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. (Sections A.3 and A.4)

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

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)

No violations of more than minor significance were identified related to the plant modifications program. (Paragraph C.4)

No violations of more than minor significance were identified in the area of emergency preparedness. (Paragraph C.5)

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)

Attachment:

Supplemental Information

REPORT DETAILS 3

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 station material 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 met the applicable training and proficiency requirements in the license application for 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.

4 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 the Building 333 solvent extraction 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

5 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 333: IROFS reviewed included:

N333VALVETW2E37 N333VALVETW2F37 N333VALVEBA2A25 N333VALVEBA2G39 N333VALVEBA2H33 N333VALVEBA2J30 N333VALVEBA2L45 N333VALVEBAO53 N333DRAINH2L06 N333DRAINH107 N333XCONDEN2021 N333XCONDEN2P21 N333XXXXPSH2017 N333XXXXTIT2022 N333XXXXTE2018A N333XXXXPSH2P17 N333XXXXTIT2P22 N333XXXXTE2P18

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.

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4.

Nuclear Criticality Safety (Inspection Procedure 88015)

a. Inspection Scope Criticality Analysis The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety program to verify compliance with selected portions of 10 CFR 70, including 10 CFR 70.24; 10 CFR 70.61(d); Chapter 5, Nuclear Criticality Safety, of the facilitys license application; and applicable licensee procedures.

The inspectors reviewed selected nuclear criticality safety evaluations (NCSEs) to verify that they were consistent with the commitments in the license application. These commitments included the assurance of subcriticality under normal and credible abnormal conditions with the use of subcritical margin, having properly reviewed and approved NCSEs in place prior to conducting new or changed operations, and selected technical practices and methodologies outlined in Section 5.5 of the license application.

The inspectors reviewed the selected NCSEs to determine whether calculations were performed within their validated area of applicability and consistent with the validation report; including that selected materials modeled in the NCSEs were included in the benchmark cases in the validation report. The NCSEs reviewed included 54T-09-0064, Nuclear Criticality Safety Evaluation for the Blended Low Enriched Uranium Preparation Facility Solvent Extraction, 54T-14-0033, Nuclear Criticality Safety Evaluation for BPF Raffinate Solidification System (U), and those listed in Section 4 of the attachment to this report.

The inspectors reviewed the licensees generation of 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. 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 selected accident sequences to determine whether they were consistent with procedural guidance and resulted in the scenario being highly unlikely.

This review was conducted in the area of BPF raffinate and solvent extraction (SX) areas for the NCSEs listed above.

Criticality Implementation The inspectors performed walk-downs of BPF SX and BPF Raffinate to determine whether existing plant configuration and operations were covered by, and consistent with, the process description and safety basis in the selected NCSEs. The inspectors reviewed process and system descriptions, drawings, and setpoint analyses (DAQ 004) to verify that engineered controls established in the NCSEs were included and being implemented as specified. The engineered controls reviewed included, BPF-13, BSX-3, BSX-4, BSX-8, BSX-9, BSX-40, RTD-1, RTD-4, and RTD-5. The inspectors reviewed operating procedures and postings to verify that selected administrative controls established in the NCSEs were included. The administrative controls reviewed included, BPF-2, RTD-2, and RTD-3. The inspectors interviewed operators and engineers to verify that selected administrative actions established in the NCSEs were understood and implemented as specified.

7 The inspectors reviewed the integrated safety analysis ISA Summary and supporting documentation (e.g., SA-00060) to determine whether the controls identified in the ISA were supported by technical bases in the NCSEs. These controls included BSX-40 and RTD-1, RTD-2, RTD-3, RTD-4 and RTD-5.

Criticality Operational Oversight The inspectors reviewed records of NCS audits and accompanied a licensee NCS engineer on a walk-down of Area 700 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 the NCS function performed these audits such that the whole facility is audited every two years by qualified NCS engineers, the NCS manager participates in the audits of the NCS program, and the NCS engineer prepares for the audit as required by Section 5.3.4 of the license application. The records of NCS audits reviewed included 21T-20-0065.

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 inspectors reviewed selected IROFS from the BPF raffinate system to verify that the licensee had established controls on long-term accumulations. Specifically, the inspectors walked down accumulation points at the bottom of tanks in BPF Raffinate and reviewed non-destructive assay (NDA) survey records to verify that the licensee has imposed IROFS to prevent or mitigate long-term accumulations. The inspectors reviewed lab sampling records, inline monitor setpoint calculations, and NDA surveys to verify that common-mode failure was addressed and that uncertainties in material characterization, geometric configuration, and measurement error with sufficient margin were properly accounted for.

Criticality Programmatic Oversight The inspectors reviewed the NCSEs listed in Section 4.0 of the attachment to this report 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 with a newly qualified NCS engineer to verify the engineer had the required education and experience and was qualified in accordance with license requirements.

Criticality Incident Response and Corrective Action The inspectors reviewed a sample of recent detector placement calculations (PSI-RP-18-002) made for the criticality accident alarm system (CAAS) to determine whether the calculations met the applicable regulatory requirements in 10 CFR 70.24 and license commitments in Sections 4.7.12.4 and 5.4.1 of the license application. This included a review of whether modeling assumptions and inputs consistent with license commitments were made concerning the source strength and spectra, source location, and the amount and location of intervening shielding.

8 The inspectors reviewed a sample of records to determine whether the licensee maintained NCS related emergency response capability consistent with emergency plans and procedures as required in Chapter 8 of the license application.

The inspectors conducted interviews to verify that qualified NCS staff were available to advise licensee emergency response staff during an emergency. The inspectors reviewed a sample of emergency procedures to determine whether procedures specified that personnel evacuate to accountability points in the event of a CAAS alarm, and that evacuation routes and accountability locations were designed to minimize the potential for exposing evacuating personnel to radiation. The inspectors also evaluated whether NCS related evacuation drills were conducted consistent with license commitments and that lessons learned were entered into the licensees PIRCS as required by Section 11.6.1 of the license application. The inspectors conducted interviews and performed direct inspections of licensee equipment to verify that the licensee had monitoring instrumentation to promptly assess dose to potentially exposed individuals and to aid in safe reentry and recovery, and whether provisions were in place for the prompt decontamination and medical treatment of exposed individuals as required by 10 CFR 70.24.

The inspectors reviewed testing records to determine whether alarm signals were audible within the areas required to be evacuated. The records reviewed included Criticality Alarm Speaker Function Records - SNM Areas for the months of September, October, November, and December of 2019. The inspectors reviewed records to determine whether CAAS detector operability was maintained, whether detectors were calibrated, whether all components were functionally tested, whether alarm setpoints were set to promptly actuate upon detecting the minimum accident of concern, and whether access to alarm setpoints was strictly controlled as required. The records reviewed included SRE Test N000CAASEMIANN.

The inspectors reviewed selected NCS-related PIRCS entries to verify that anomalous conditions were promptly identified and entered into the PIRCS, that they received the required level of investigation, and that they were closed out consistent with license commitments and procedures. Additionally, the inspectors reviewed the selected PIRCS entries to assess whether the licensee followed regulatory requirements and procedures with regards to reporting plant conditions to the NRC. The PIRCS entries reviewed included 77645, 77740, 77867, 78120, 78127, 78270, 78334, 78379, and 78393.

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.

9 The inspectors conducted a walk-down of production areas in Building 306 East, 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.

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.

The inspectors performed a review of selected SWPs in effect during the inspection period in different operational areas and conducted a focused review for SWP-20 001-302F-J, SWP-20-32-004-333UMET, 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.

10 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:

N333XXXXTIT2P22 N333XXXXTE2918A N333XXXXPSH2P17

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

N333PRSLEEVE009 N333PRSLEEVE004 N333PRSLEEVE006 N333PRSLEEVE005 N302VALVEHV0FC6 N302XFLOWFS0F10

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

3.

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

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a. Inspection Scope The inspectors reviewed the implementation of licensee corrective actions 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.

4.

Permanent Plant Modifications (Inspection Procedure 88135.17)

a. Inspection Scope The inspectors reviewed records, work packages, and supporting documentation associated with the addition of SRE in the 800 BB system to verify that the changes had not affected system operability or availability. The inspectors reviewed licensee procedures NFS-CM-002, Identification and Control of Configuration Items, and NFS-2M-001-1, Work Management Program Description, and selected ongoing and completed work activities to verify that the change was consistent with the design control documents and requirements. The inspectors reviewed procedures to verify that operational details associated with the changes were incorporated into the appropriate operating procedures, as needed. The inspectors performed field observations to verify that the as-built configuration was in accordance with design documents. The inspectors observed and reviewed activities associated with the change to assess the impact on interfacing operating systems. The inspectors also reviewed records and observed licensee activities to verify that post system changes were operational. Specifically, the inspectors reviewed the following for the 800 BB system:

Scope Documentation Change Authorization Safety and Regulatory Review Routing Form Change Control Package - ECR 20190892 Work Request 280178A, B, C, and D Area 800 Piping Diagram

b. Conclusion

No violations of more than minor significance were identified.

12

5.

Emergency Preparedness (Inspection Procedure 88050)

a. Inspection Scope and Observations The inspectors evaluated selected aspects of the licensees Emergency Preparedness Program to verify compliance with 10 CFR 70; Chapter 8, Emergency Management, of the license application; and NFS-GH-903, Emergency Plan, Revision 25.

The inspectors interviewed staff and reviewed records to verify that changes made to the Emergency Plan and its supporting documents or within the facility were properly coordinated with the Emergency Preparedness Program. The inspectors reviewed several Emergency Plan implementing procedures (EPIPs) revised since the last emergency preparedness inspection (see Attachment to this report) to verify that they were reviewed annually, that the proposed changes were reviewed by the licensees emergency preparedness organization, and that the changes did not result in a decrease in effectiveness of the Emergency Preparedness Program, as required by the Emergency Plan.

The inspectors reviewed records and interviewed licensee staff regarding emergency preparedness training completed since the last inspection. Interviews included a security coordinator, an on-scene director, and other personnel with responsibilities associated with the Emergency Operations Center (EOC) and emergency response activities. The inspectors reviewed the records to verify that the licensee provided emergency management and emergency response training for site personnel as required by the Emergency Plan. The inspectors reviewed a sample of qualification records to verify that individuals responsible for using emergency equipment were qualified as required by the Emergency Plan and EPIPs.

The inspectors observed the availability of emergency equipment and documentation in the on-site Emergency Control Center (ECC) and one alternate ECC to verify compliance with the Emergency Plan. The inspectors observed the operation of the automated personnel accountability system and the availability of emergency equipment at the primary assembly area, alternate assembly area, and the Emergency Shelter to verify compliance with procedure NFS-HS-B-40, Inspection Emergency Equipment and Supplies.

The inspectors reviewed written agreements between NFS and off-site agencies to verify that emergency response coordination between the agencies were current as required by the Emergency Plan. The inspectors interviewed the Fire Chief with the Town of Erwin and the Chief Nursing Officer with the Unicoi County Hospital to verify that the licensee was offering them the opportunity to participate in training/drill activities on an annual basis as required in the Emergency Plan.

The inspectors reviewed the licensees independent audits of the Emergency Preparedness Program since the last inspection to verify that a system was in place for scheduling, tracking, and conducting audits. The inspectors also reviewed records associated with EOC activations during drills that occurred since the last inspection to verify that EOC activations were in accordance with the Emergency Plan. The inspectors reviewed licensee documents to verify that problems or deficiencies associated with the implementation of the Emergency Plan were captured in program audits and that critique activities were entered into the PIRCS for resolution in accordance with the license application and the Emergency Plan.

13

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 Personnel and Activities

a. Inspection Scope During the inspection period, the inspectors observed activities from security and material control and accounting (MC&A) personnel to verify 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 an exit meeting held on February 13th, 2020 at the NFS facility, and to J. Stewart and staff at a second exit meeting (via teleconference) on April 20, 2020. Proprietary and classified information were discussed during the February 13th exit meeting, but not included in this report.

SUPPLEMENTARY INFORMATION Attachment

1. KEY POINTS OF CONTACT Name Title J.

Bailey Town of Erwin, Fire Chief S.

Barron Program Manager, Emergency Preparedness N.

Brown Unit Manager, Nuclear Criticality Safety J.

Buckles Fire Protection Specialist T.

Cloyd Fire Protection Specialist J.

Coleman Fire Protection Specialist S.

Gizzie Unit Manager, Integrated Safety Analysis and Fire Protection A.

Jones Unicoi Hospital, Chief Nursing Officer C.

Lewis Engineer 4, Nuclear Criticality and Safety D.

Mann Engineer, Nuclear Criticality and Safety A.

Morie Licensing Manager R.

Rice Manager, Radiation Protection E.

Senter Principal Technical Specialist, Integrated Safety Analysis and Fire Protection R.

Shackleford Section Manager, Nuclear Safety & Licensing S.

Skiles Senior Engineer, Nuclear Criticality Safety J.

Stewart President, Nuclear Fuel Services

2. LIST OF ITEMS OPENED, CLOSED AND DISCUSSED None

3. INSPECTION PROCEDURES USED 88015 Nuclear Criticality Safety 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 88050 Emergency Preparedness

4. DOCUMENTS REVIEWED Records:

21T-16-0547, Nuclear Criticality Safety Audit Writers Guide, Rev. 5 21T-19-1304, CAAS Omission - Buildings 100 and 131, dated October 28, 2019 21T-19-1305, CAAS Omission - Building 110, dated October 28, 2019 21T-20-0002, BLEU Preparation Facility, Rev. 17 54T-09-0064, Nuclear Criticality Safety Evaluation for the Blended Low Enriched Uranium Preparation Facility Solvent Extraction, Rev. 11 54T-14-0033, Nuclear Criticality Safety Evaluation for BPF Raffinate Solidification System (U), Rev. 2 55T-15-0158, Flow Rate Through FO-5C03, September 8, 2015 56T-19-0181, Emergency Preparedness Program Audit (QA-19-25), dated December 12, 2019

2 Agreement between Washington County Johnson City EMS and Nuclear Fuel Services, Inc., dated July 8, 2019 Annual Refresher Training for select ERO personnel DAQ-15-0004, Setpoint Analysis for RTD-004, dated September 28, 2015 Emergency Response Organization (ERO) Organization Chart Estimation of Potential Dose to an Off-Site Receptor Resulting from a Postulated Major Fire or Explosion, Revision 2 Estimation of the Potential Dose to Exposed Workers and Off-Site Members of the Public Resulting from an Accidental Criticality, Revision 2 Executive Organization Organizational Chart FM-NFS-HS-A-67-A, Safety & Regulatory Review Routing Form, Revision 6 Lab Sample Analysis Report for BPF Raffinate Sample ID 5148014, dated January 30, 2020 Letter of Agreement - Radiation Emergency assistance Center/Training Site (REAC/TS)

Support, February 2019 NDA Data Form for Raffinate Tanks (5C03/5C15), dated January 31, 2020 NFS Annual Criticality Alarm Evacuation Drill (for 2019), 21T-19-0478, Planning and Records Package NFS-GH-903, Emergency Plan, Revision 25, dated August 1, 2019 NFS-HS-B-08, Attachment A, Inspection of Fire Brigade Personnel Lockers, Monthly Inventory Checklist, Recent Example NFS-HS-B-08, Attachment B, Inspection of Fire Brigade Response Building, Monthly Inventory Checklist, Recent Example NFS-HS-B-08, Attachment D, Inspection of Fire Brigade Equipment Building, Monthly Inventory Checklist, Recent Example Nuclear Criticality Safety Engineer Qualification Program Record for D. Mann, dated November 26, 2019 PSI-RP-18-002, Criticality Accident Alarm System Analysis: Building 105, Rev. 0 Raffinate Authorization and Discard Procedure Steps, Batch Nos. 333-SX-2005-03 through 2007-08 & 2006-1, dated January 31, 2020 Runsheet 333-14-1, Raffinate Tanks NDA Scan Log, dated February 3, 2020 SA-00060, Setpoint Analysis for BSX-040, Rev. 3 SRE Test N333MONITR4RAFF, performed on September 11, 2019 SRE Test N333MONITR4RAFF. performed on January 6, 2020 SRE Test N333XCONDEN2O21, performed on December 12, 2018 SRE Test N333XCONDEN2O21, performed on December 16, 2019 SRE Test N333XCONDEN2O21, performed on June 28, 2019 Updating Agreement between Mountain States Health Alliance (MSHA) d/b/a Johnson City Medical Center (JCMC) and Nuclear Fuel Services, Inc., (NFS), dated August 8, 2017 Updating Agreement between the Erwin Fire Department and Nuclear Fuel Services, Inc.,

(NFS), dated July 7, 2017 Updating Agreement between the South Unicoi County Volunteer Fire Department and Nuclear Fuel Services, Inc., (NFS), dated July 7, 2017 Updating Agreement between the Town of Erwin and Nuclear Fuel Services, Inc.,) (NFS) dated July 7, 2017 Updating Agreement between Unicoi County Hospital and Nuclear Fuel Services, Inc., dated April 3, 2019 Procedures:

NFS-A-07, Procedure Listing for Control Lab Samples, Rev. 23 NFS-ACC-116, Procedure for NDA of the 333 Building Scrubber System, Raffinate Tanks, Caustic Tanks, and the Process Off-gas Ductwork Using a Portable NDA System, Rev. 6

3 NFS-HS-A-05, Modes of Alarm Activation Test Checklist, dated September 9, 2019 NFS-HS-B-40, Inspection Emergency Equipment and Supplies, Attachment A, Emergency Shelter (Building 350), Revision 28 NFS-HS-B-40, Inspection Emergency Equipment and Supplies, Revision 28, dated June 6, 2019 NFS-HS-E-02, Emergency Criticality Evacuation, Revision 47, dated August 8, 2019 NFS-HS-E-03, Emergency Response Organization, Revision 33, dated August 8, 2019 NFS-HS-E-04, Fire Reporting and Response, Revision 40, dated August 8, 2019 NFS-HS-E-05, Spill Response and Reporting, Revision 38, dated August 8, 2019 NFS-HS-E-07, On-Site Radiological Emergency Assessment, Revision 35, dated August 9, 2018 NFS-HS-E-08, Off-Site Radiological Emergency Assessment, Revision 30, dated August 8, 2019 NFS-HS-E-09, Off-Site Dose Projection for Radiological Emergency, Revision 31, dated August 8, 2019 NFS-HS-E-10, Emergency Communications, Revision 31, dated August 8, 2019 NFS-HS-E-11, Radiological Scene and Contamination Control, Revision 25, dated August 8, 2019 NFS-HS-E-12, 24-Hour Emergency Response for Hazardous Material Transportation, Revision 24, dated August 8, 2019 NFS-HS-E-13, Emergency Take Cover, Revision 9, dated September 9, 2018 NFS-HS-E-14, CO2 Evacuation Alarm Response and Responsibilities, Revision 15, dated August 8, 2019 NFS-HS-E-15, Emergency Medical Response, Revision 18, dated August 8, 2019 SOP 409 Section 12, First Pass Solvent Extraction, Rev. 35 Other Documents:

333-F0453-D, BPF First Pass Evaporator P&ID, dated August 7, 2019 333-F0454-D, BPF SX Interface Solids Filtering P&ID, dated July 31, 2018 333-F0458-D, BPF First Pass Raffinate Storage P7ID, dated October 23, 2018 333-F0603-D, BPF Raffinate Treatment & Disposal P&ID, dated August 22, 2017 Problem, Identification, Resolution, and Correction System (PIRCS) Documents Reviewed:

34142, 35286, 35287, 36790, 71845, 72153, 72168, 72516, 72676, 75516, 76385, 77645, 77740, 77867, 77975, 77976, 77977, 77978, 77979, 77980, 77981, 77982, 77983, 77984, 77985, 77986, 78120, 78127, 78241, 78242, 78270, 78304, 78316, 78317,78334, 78379, 78379, 78393, 78445, 78542, 78559, 78560, 78571, 78572, 78701, 78941, and 78955 PIRCS Written as a Result of the Inspections:

77999, 78023, 78101, and 78618