ML21026A010

Nuclear Fuel Services, Inc. - U. S. Nuclear Regulatory Commission Integrated Inspection Report Number 70-143/2020-004

ML21026A010
Person / Time
Site:	Erwin
Issue date:	01/26/2021
From:	Robert Williams NRC/RGN-II/DFFI
To:	Stewart J Nuclear Fuel Services
References
IR 2020004
Download: ML21026A010 (17)

Text

January 26, 2021 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 70-143/2020-004

Dear Mr. Stewart:

This letter refers to the inspections conducted from October 1, 2020, through December 31, 2020, at the Nuclear Fuel Services (NFS) facility in Erwin, Tennessee. During that period, the U. S. Nuclear Regulatory Commission (NRC) implemented alternative ways to complete the core inspection program for your facility when routine onsite inspections could not be performed due to the public health emergency declared by the Secretary of Health and Human Services on January 31, 2020 (as renewed on April 21, 2020, and July 23, 2020), and the National Emergency declared by the President of the United States on March 13, 2020, concerning the novel coronavirus disease (COVID-19).

The enclosed report presents the results of the inspections, which were conducted through a combination of remote reviews and onsite observations. The inspectors reviewed activities 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 areas of safety operations, radiological controls, facility support, and other areas.

Within these areas, the inspectors reviewed procedures and representative records remotely and conducted telephonic interviews with site personnel. In some instances, regional inspectors were able to conduct routine inspections onsite as originally planned. The resident inspector also visited the facility two or more times per week to monitor plant conditions and conduct focused inspection activities. The findings were discussed with you and members of your staff at exit meetings held on held on December 17, 2020 and January 14, 2021.

Based on the results of these modified inspections, no violations of more than minor significance were identified.

Additionally, the inspectors implemented measures during the inspection period to support the determination of reasonable assurance that the public and the environment will be adequately protected from the hazards related to the operation of your facility. These compensatory measures included activities such as supplemental reviews of licensee-submitted reports (e.g.

effluent reports, plant modification reports, and changes to the Integrated Safety Analysis Summary) and increased communications with your staff to discuss the status of plant operations.

J. Stewart 2

The compensatory measures did not constitute direct inspection and were intended to address the impact of the COVID-19 public health emergency on the agencys routine oversight program, particularly on the continuous engagement with your facility via periodic site visits and in-person interactions. These proactive actions were taken to obtain additional insights into the safe operation of the facility during the COVID-19 public health emergency.

The NRC will continue evaluating the guidelines and recommendations from federal and state authorities, along with the conditions of your facility, to determine how to best conduct inspections until normality can be achieved. In the interim, the NRC plans to conduct periodic resident inspector visits to the site and gradually increase their presence, as appropriate. The NRC will also maintain compensatory measures and frequent communications with your staff to discuss regulatory compliance matters and gather information to inform the decisions about future inspections.

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.

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 70-143/2020-004 w/

Attachment:

Supplemental Information cc w/ encl: Distribution via LISTSERV

ML21026A010_

OFFICE RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB1 NAME L. Harris J. Rivera-O ti N. Peterka T. Sippel DATE 1/7/2021 1/11/2021 1/8/2021 1/7/2021

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

70-143 License No.:

SNM-124 Report No.:

70-143/2020-004 Enterprise Identifier: I-2020-004-0066 Licensee:

Nuclear Fuel Services, Inc.

Facility:

Nuclear Fuel Services, Inc.

Location:

Erwin, TN 37650 Dates:

October 1 through December 31, 2020 Inspectors:

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

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

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

Approved by:

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

2 Nuclear Fuel Services, Inc.

U.S. NRC Integrated Inspection Report 70-143/2020-004 October 1 - December 31, 2020 Resident and regional inspectors from the U.S. Nuclear Regulatory Commission (NRC), Region II Office, conducted inspections at the Nuclear Fuel Services (NFS) facility during normal and off-normal hours in the areas of safety operations, radiological controls, facility support, as well as other areas. Due to the coronavirus (COVID-19) disease, the inspectors performed remote examinations of selected licensee activities in conjunction with focused observations of safety significant activities on site via walk-downs of the facility, interviews 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 problem identification and resolution. (Section C.3)

No violations of more than minor significance were identified in the area of emergency preparedness during the review of a training drill. (Section C.4)

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.

Resident Inspection Program - Plant Status Activities (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 Wastewater 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 observed operators to verify they were knowledgeable of their duties and attentive to any alarms or annunciators at their respective stations. The inspectors also observed 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 operating procedures associated with their assigned duties.

The inspectors reviewed operator logbooks, 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 discussed the results of operational and shift turnover meetings throughout the inspection period with plant personnel to gain insight into safety and operational issues. The inspectors discussed items covered during plan-of-the-day meetings and interviewed the Plant Shift Superintendent staff daily 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.

Resident Inspection Program - Operational Safety (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 304/306 waste and process container cleaning areas. 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).

The IROFS reviewed in Building 304/306 waste area included:

FLW-2 WWT-7 FLW-11 N306MONITR4WD01 N306VALVFCVWD24 N306VALVFCVWD25 The IROFS reviewed in Building 304 process container cleaning area included:

FCC-2 FLW-7 N304XFILTERCC02

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

3.

Resident Inspection Program - Nuclear Criticality Safety (Inspection Procedure 88135.02)

a. Inspection Scope The inspectors performed weekly 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. During walk-downs, the inspectors observed SNM movements taking place within the facility.

As part of routine day-to-day activities, 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.

The PIRCS records reviewed included:

80668 80748 80898

6

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

4.

Nuclear Criticality Safety (Onsite Inspection - 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 70.61(d) and 70.62(d); Chapters 3, 5, and 11 of the facilitys license application; and applicable licensee procedures.

The inspectors reviewed selected nuclear criticality safety evaluations (NCSEs) and associated control flowdowns 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, and review and approval of NCSEs prior to conducting new or changed operations. The inspectors reviewed the selected NCSEs to determine whether calculations were performed within their validated area of applicability and consistent with the validation report. The NCSEs were selected based on factors such as whether or not they were new or revised, and whether or not they were recently reviewed by NCS staff. The NCSEs reviewed are 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 selected 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 credited for IROFS in the 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 areas of the support systems for the 300 Complex.

Criticality Implementation The inspectors performed walk-downs in the 300 Complex, including the 311 Storage Area, to determine whether existing plant configuration and operations were covered by, and consistent with, the process descriptions and safety bases in the selected NCSEs listed in Section 4 of the attachment to this report. The inspectors reviewed control descriptions, control flowdowns, and test records to verify that engineered controls established in the NCSEs were included and being implemented as specified. The engineered controls reviewed included FACR-5, FA5-016, FA5-017, and FA5-024. The inspectors reviewed postings in the field and interviewed operators and engineers to verify that selected administrative controls established in the NCSEs were implemented as specified. The administrative controls reviewed included various IROFS controls related to mass, spacing, and moderator controls.

7 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. These controls included IROFS FACR-5, and others listed above for walk-downs.

Criticality Operational Oversight The inspectors reviewed NCS-related training records and material to determine whether operator training included instruction in criticality hazards and control methods, whether the licensees established NCS-related operator training was consistent with commitments in Chapter 5 of the license application, including the licensees commitment to American Nuclear Society Standard 8.20 and whether NCS staff was involved in the development of operator training as required. Additionally, the inspectors interviewed operations staff to determine whether they were cognizant of NCS hazards and control methods related to their specific job function. The NCS-related training records and materials reviewed included OPR-TB-MAY20-02, Nuclear Criticality Safety Awareness; JUNTBOX-20, June Toolbox - Criticality Evacuation Emergency Procedure Review, and various operators training records.

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 listed in Section 4 of the attachment to this report and included IROFS FACR-5, FA5-016, FA5-017, and FA5-024. The records reviewed associated with these management measures included postings observed in the field, as well as test records such as N302XFILTER0502, completed on September 17, 2020; N302XXXXLSH0544, completed on September 24, 2020; and N302XXXXLSH0545, completed on September 24, 2020.

The inspectors reviewed selected non-destructive assay (NDA) records and IROFS related to preventing accumulations from the NCSEs listed above to verify that the licensee had established controls on long-term accumulations. Specifically, the inspectors walked down controls on accumulations associated with support systems in the 300 complex and reviewed NDA records to verify that the licensees controls prevent or mitigate long-term accumulations.

Criticality Programmatic Oversight The inspectors reviewed new and/or revised NCS program procedures to determine whether the licensee implemented license requirements and whether the NCS program was enacted in accordance with them. The new and/or revised NCS program procedures included, NFS-GH-43, Safety-Related Equipment Control Program. The inspectors conducted interviews and reviewed records to determine whether NCS staff reviewed new and/or revised fissile material operations and procedures, including maintenance plans, consistent with program procedures and at a level commensurate with their significance.

The inspectors reviewed the NCSEs listed in Section 4 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.

8 The inspectors reviewed the triennial audit report and interviewed the licensee NCS manager to verify that the audit of the NCS program was conducted at a frequency consistent with license requirements and with appropriate thoroughness.

Criticality Incident Response and Corrective Action The inspectors interviewed licensee engineers and operators to determine whether the licensee conducted training on NCS emergency response consistent with license requirements including whether such training instructed personnel to evacuate to accountability points in the event of a CAAS alarm, whether the training on evacuation routes included guidance to minimize the potential for exposing evacuating personnel to radiation, and whether NCS-related evacuation drills were conducted consistent with license commitments. The inspectors interviewed licensee RP technicians to verify that they were trained to use monitoring instrumentation to promptly assess dose to potentially exposed individuals and to aid in safe reentry and recovery as required by 10 CFR 70.24.

The inspectors reviewed selected NCS-related PIRCS entries to verify that safety conditions were promptly identified and entered into the PIRCS, that they received the required level of investigation, and that they were corrected and 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 regard to reporting plant conditions to the NRC. The PIRCS entries reviewed are listed in Section 4 of the attachment to this report.

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

5.

Resident Inspection Program - Fire Protection (Inspection Procedure 88135.05, Quarterly and Annual Review)

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.

The inspectors conducted a walk-down of production areas in Building 304, reviewed scheduled surveillances, and pre-fire plan drawings to verify it matched the as-found condition of various fire protection components like extinguishers and postings.

The inspectors reviewed routinely scheduled fire safety related inspections to assure they were conducted, and that any identified deficiencies were addressed.

The inspections reviewed included:

safety lights, Building 304

9 fire impairment, Door D362 annual heat detector test, Building 304 fire extinguisher inspection, Building 304 fire wall inspection, Building 304 Due to system changes in Building 302/303, the inspectors reviewed surveillance tests for the CO2 system in Building 302 to determine if the tests were performed at the required frequency and that any deficiencies were addressed. The following test was reviewed: N302XXCO2SYSTEM.

The inspectors reviewed the third quarter onsite fire brigade drill and first quarter annual offsite training at the South Carolina Fire Academy to evaluate the readiness of the licensees personnel to prevent and fight fires.

Specific training records reviewed included:

first quarter training plan practical exercise form job hazard analysis, South Carolina Fire Academy training records for live firefighting class third quarter training plan training records, 3rd quarter 2020 The inspectors reviewed fire brigade responses to plant alarms and medical emergencies to determine that protective gear, equipment, directives, communications, and pre-planned strategies were sufficient to respond to the fire/emergency.

Specific responses reviewed included; Building 302 Area J smoke (false) alarm Building 100 duct detector (false) alarm Medical calls, November 24 and 30, 2020 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.

The PIRCS records reviewed included:

80708 80836 81063 81242

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

10 B.

Radiological Controls

1.

Resident Inspection Program - Radiation Protection (Inspection Procedure 88135.02, Quarterly Review)

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 that they included radiation maps with up-to-date radiation levels. The inspectors reviewed 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-20-52-017 (300 complex) and SWP 17699 (303 building) and the associated posted radiologically controlled area(s), 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.

Resident Inspection Program - Post-Maintenance Testing (Inspection Procedure 88135.19)

a. Inspection Scope The inspectors reviewed records for 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 select 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.

11 The inspectors also 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 N333XDRAINH3F12 and N333NOXDET3X18.

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

2.

Resident Inspection Program - Surveillance Testing (Inspection Procedure 88135.22)

a. Inspection Scope The inspectors observed 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 reviewed the 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 reviewed operator qualifications to assure that staff were qualified in the test areas. The SRE tests selected for review were N302XCOLUMNB201 and N302XCOLUMNA201.

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

3.

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

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 reviewed the results of daily PIRCS screening committee 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 in 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.

13

4.

Resident Inspection Program - Emergency Preparedness Drill (Inspection Procedure 88135)

a. Inspection Scope The inspectors reviewed the training scenario and results of a training drill conducted on December 17, 2020 to verify that the licensees response, inter-departmental coordination, and procedural implementation were consistent with the emergency preparedness objectives of NFS-GH-903, Emergency Plan.

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 reviewed actions and training exercises performed by security and material control and accounting (MC&A) personnel to verify the activities were consistent with applicable license, procedure, and regulatory requirements.

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 Mr. John A. Stewart, President of Nuclear Fuel Services, Inc. and members of his staff at exit meetings conducted on December 17, 2020 and January 14, 2021. Proprietary information was discussed, but not included in this report.

SUPPLEMENTAL INFORMATION Attachment

1. KEY POINTS OF CONTACT Name Title 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 D. Coulter Health Physicist, Programmatic M. Eakin Engineer, Nuclear Criticality Safety J.

Faddis Environmental Unit Manager S. Gizzie Unit Manager, Integrated Safety Analysis and Fire Protection B. Graham Licensing Specialist T.

Knowles Director, Safety & Safeguards C. Lewis Engineer 4, Nuclear Criticality and Safety J.

Marshall Engineer, Nuclear Criticality Specialist 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 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

4. DOCUMENTS REVIEWED Records 21T-20-0719, CAAS Omission - 234 Excavation Facility, dated August 19, 2020 21X-19-0004, 300 Complex Support Systems Integrated Safety Analysis Summary, Rev. 14 27T-20-2095, OPR-TB-MAY20-02, Nuclear Criticality Safety Awareness 27T-20-2091, JUNTBOX-20, June Toolbox - Criticality Evacuation Emergency Procedure Review 54T-20-0001, Nuclear Criticality Safety Evaluation for the High Security Storage Area in Building 311, Rev. 9 54T-20-0003, Control Flowdown and Field Verification for the Building 311 High Security Storage Area, Rev. 11 54X-10-0001, Control Flowdown and Field Verification for Check Weighing Areas, Rev. 1

2 54X-10-0002, Control Flowdown and Field Verification for FMF Transfer Carts, dated March 10, 2010 54T-15-0004, Nuclear Criticality Safety Evaluation for 300 Complex Waste Handling, Rev. 1 54T-15-0008, Control Flowdown and Field Verification for 300 Complex Waste Handling, Rev. 1 54X-20-0001, Nuclear Criticality Safety Evaluation for Area 500 and Area 400 Discard Columns of the Production Fuel Facility, Rev. 2 54X-20-0002, Control Flowdown and Field Verification for Area 500 and Area 400 Discard Columns of the Production Fuel Facility, Rev. 4 54X-09-0012, Nuclear Criticality Safety Evaluation of the Check Weighing Areas, Rev. 1 54X-99-0078, Nuclear Criticality Safety Evaluation Packaging of Finished and Semi-Finished Fuel Samples, Rev. 0 54X-99-0077, Nuclear Criticality Safety Analysis Transfer Carts and Process Floor Storage Racks, Rev. 1 N302XFILTER0502, completed September 17, 2020 N302XXXXLSH0544, completed September 24, 2020 N302XXXXLSH0545, completed September 24, 2020 Procedures NFS-GH-43, Safety-Related Equipment Control Program, Rev. 31, dated October 15, 2020 NFS-GH-63 Rev 4 Unrestricted Equipment/Item Release NFS-HS-CL-10-10 Rev 27 Nuclear Criticality Safety Buildings 302,303,304,306 NFS-HS-CL-10, Nuclear Criticality Safety Fuel Manufacturing Facility, Rev. 31, dated April 17, 2018 NFS-HS-CL-13, Nuclear Criticality Safety Buildings 304, 306, and 311, Rev. 20, dated April 17, 2018 NFS-HS-A-68, ISA Risk Assessment Procedure, Rev. 9 SOP 401-20 Rev 19 FMF, Can Cleaning Other Documents 2020 Independent Triennial Nuclear Criticality Safety Program Review for Nuclear Fuel Services, Inc., dated October 15, 2020 Fuel (Bldg. 302) POG Ductwork Data Survey, performed October 1, 2020 Fuel (Bldg. 302) POG Ductwork Data Survey, performed November 30 and December 3, 2020 Fuel (Bldg. 302) POG Ductwork Data Survey, performed November 14, 2020 Restart Instructions/Restart Checklist for PIRCS 80769 and 80794 Various operators training records Problem, Identification, Resolution, and Correction System (PIRCS) Documents Reviewed 80393, 80423, 80453, 80551, 80677, 80700, 80709, 80718, 80726, 80769, 80748, 80794, 80849, 80880, 80890, 80898, 80941, 80987, 81056, 81073, 81106, 81169, and 81177.

PIRCS Written as a Result of the Inspections 81151 Investigative PIRCS Reviewed 80794-129536 80898-129568