ML21298A148
| ML21298A148 | |
| Person / Time | |
|---|---|
| Site: | BWX Technologies |
| Issue date: | 10/25/2021 |
| From: | Eric Michel NRC/RGN-II/DFFI/FFB2 |
| To: | Bittner J BWXT |
| References | |
| IR 2021003 | |
| Download: ML21298A148 (35) | |
Text
October 25, 2021 Mr. James J. Bittner Vice President and General Manager BWXT Nuclear Operations Group, Inc.
P.O. Box 785 Lynchburg, VA 24505-0785
SUBJECT:
BWXT NUCLEAR OPERATIONS GROUP, INC. - LYNCHBURG -
INTEGRATED INSPECTION REPORT 07000027/2021003 AND NOTICE OF VIOLATION
Dear Mr. Bittner:
On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at BWXT Nuclear Operations Group, Inc. - Lynchburg. On October 20, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The enclosed report presents the results of the inspection.
This inspection examined activities conducted under your license as they relate to public health and safety, (and/or) the common defense and security, and to confirm compliance with the Commission's rules and regulations and with the conditions of your license. Within these areas, the inspection consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel.
Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's Web site at (http://www.nrc.gov/about nrc/regulatory/enforcement/enforce pol.html). The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in detail in the subject inspection report. The violation is being cited in the Notice because BWXT NOG-Lynchburg does not have an NRC-approved Corrective Action Program and did not identify the violation, consistent with Section 2.3.2 of the Enforcement Policy.
The NRC has concluded that information regarding: (1) the reason for the violation(s); (2) the corrective actions that have been taken and the results achieved; and (3) the date when full compliance was achieved is already adequately addressed on the docket in the enclosed inspection report. Therefore, you are not required to respond to this letter unless the description herein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
J. Bittner 2 If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at BWXT Nuclear Operations Group, Inc. - Lynchburg.
In accordance with Title 10 of the Code of Federal Regulations 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure(s), and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the Public without redaction.
Sincerely,
/RA/
Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 07000027 License No. SNM-42
Enclosures:
- 1. Notice of Violation
- 2. INTEGRATED INSPECTION REPORT 07000027/2021003 cc w/ encl: Distribution via LISTSERV
ML21298A148 x Non-Sensitive x Publicly Available x SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME A. Alen B. Adkins N. Peterka G. Goff E. Michel DATE 10/14/2021 10/14/2021 10/14/2021 10/14/2021 10/25/2021 NOTICE OF VIOLATION BWXT Nuclear Operations Group, Inc. Docket No.: 07000027 Lynchburg, Virginia License No.: SNM-42 During an NRC inspection conducted on July 1, 2021, to September 30, 2021, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
Title 10 of the Code of Federal Regulations (10 CFR) 70.61(e) required, in part, that the safety program established and maintained pursuant to § 70.62 of this subpart, shall ensure that each IROFS will be available and reliable to perform its intended function when needed and in the context of the performance requirements of this section. § 70.62(d) identified the requirements for the safety programs Management Measures element and required, in part, that management measures shall ensure that controls identified as IROFS pursuant to § 70.61(e) are maintained, as necessary, to ensure they are available and reliable to perform their function when needed, to comply with the performance requirements of § 70.61 of this subpart.
Contrary to the above, prior to September 14, 2021, the licensee failed to establish adequate management measures (maintenance and corrective action program) to ensure that the specialty fuel facility waste sink drain line, identified as an IROFS, was maintained such that it remained available and reliable to perform its function, to comply with the performance requirements of 10 CFR 70.61.
This is a Severity Level IV violation (Section 6.2).
Replying to Notice of Violation The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and the date when full compliance was achieved are already adequately addressed on the docket in the enclosed inspection report.
However, you are required to submit a written statement or explanation under 10 CFR 2.201 if the description on the docket does not accurately reflect your corrective actions or your position.
In that case, or if you choose to respond, please mark your reply Reply to a Notice of Violation" and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region 2, and a copy to the NRC Resident Inspector at BWXT Nuclear Operations Group, Inc. - Lynchburg , within 30 days of the date of the issuance of this Notice of Violation.
If you choose to respond, your response will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room consistent with 10 CFR 2.390. Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in Enclosure 1
detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information).
Dated this October 25, 2021 2
U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07000027 License Number: SNM-42 Report Number: 07000027/2021003 Enterprise Identifier: I-2021-003-0032 Licensee: BWXT Nuclear Operations Group, Inc.
Facility: BWXT Nuclear Operations Group, Inc. - Lynchburg Location: Lynchburg, VA 24505 Inspection Dates: July 1, 2021 to September 30, 2021 Inspectors: B. Adkins, Sr. Fuel Facility Projects Inspector A. Alen, Senior Resident Inspector G. Goff, Fuel Facilities Inspector N. Peterka, Fuel Facility Inspector M. Ruffin, Fuel Facility Inspector Approved By: Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure 2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at BWXT Nuclear Operations Group, Inc. -
Lynchburg, in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities. Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.
List of Violations Inadequate Maintenance of Sink Drain Line NCS IROFS Significance Report Section Severity Level IV 88135.22 NOV 07000027/2021003-01 Closed The NRC inspectors identified a cited Severity Level (SL) IV violation of 10 CFR 70.61(e) and 70.62(d) for BWXTs failure to implement adequate management measures to ensure the availability and reliability of the specialty fuels facility (SFF) area waste sink drain line. The drain line was an NCS passive engineered IROFS control to prevent waste solution from exceeding favorable geometry.
Additional Tracking Items None.
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PLANT STATUS During the inspection period, routine fuel manufacturing operations and maintenance activities were conducted in the fuel processing areas, Uranium Recovery (UR) facility, and in the Research and Test Reactors (RTR) facility.
INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Inspections were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
SAFETY OPERATIONS 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees nuclear criticality safety (NCS) program to verify compliance with selected portions of Title 10 of the Code of Federal Regulations (10 CFR) 70, "Domestic Licensing of Special Nuclear Material," including 70.24, 70.61, 70.62; Chapter 5, "Nuclear Criticality Safety," of the facilitys license application; and applicable licensee procedures.
Criticality Analysis (IP Section 02.01)
The inspectors interviewed licensee staff and reviewed nuclear criticality safety evaluations (NCSEs), and associated assumptions and calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application including Chapter 5.
Specifically, the inspectors interviewed licensee staff and reviewed the following NCSEs:
- NCS-2004-139, "NCS Analysis Supporting Revised Phase 2 of SER 04-012 (High-Level Dissolver (HLD) Re-design)," dated June 3, 2005
- NCS-2004-284, "NCS Analysis Supporting Phase 2 of Safety Evaluation Report (SER)04-012 (HLD Re-design)," dated December 7, 2004, which covers various loss of mass or geometry scenarios associated with the re-design of the HLD in the recovery area
- NCS-2007-096, "Level 3 NCS Evaluation: Additional Aluminum-Based Materials for Processing in Recovery SER 07-030 Phase 01," dated May 22, 2007
- NCS-2008-011, "NCS Analysis for New Routine Operating Limits (ROLs) for the Re-designed HLD (Zirc Dissolver)," dated January 24, 2008 3
- NCS-2009-002, "NCS Analysis to Modify HLD Trough's Dimension Limiting Condition of Operation (LCO) and ROL," dated January 7, 2009
- NCS-2010-142, "NCS Analysis for SER 10-029 Phase 1 (Trough Pass-Through Box Safety Analysis & System Modifications)," dated September 15, 2010
- NCS-2010-223, "Revised NCS Analysis for SER 10-029 Phase 1 (Trough Pass-Through Box Safety Analysis & System Modifications)," dated October 27, 2010 Criticality Implementation (IP Section 02.02)
The inspectors selected engineered and administrative items relied on for safety (IROFS) from the licensees integrated safety analysis (ISA) summary to verify proper implementation through a review of process and system descriptions, plant walkdowns, and operator interviews to verify compliance with 10 CFR 70 and applicable sections of the license application including Chapter 5 and Chapter 11, "Management Measures." Specifically, the inspectors interviewed licensee staff and reviewed the following controls, and their management measures, associated with the NCSEs listed above and selected areas:
- passive engineered geometry controls for the HLD, including trough dimensions, drain locations and sizes, and spacing of equipment (safety analysis report (SAR) 15.5 - Accident Sequences HLDR 1a - 1d, HLDR-14)
- administrative mass control (electronic mass log) and NCS posting limits for the HLDs (SAR 15.5 - Accident Sequence HLDR-20)
Criticality Operational Oversight (IP Section 02.03)
The inspectors assessed the NCS staffs oversight of plant operators, procedures, and operations of systems involving special nuclear material to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors performed the following activities:
- reviewed training lesson plans and exams for annual NCS training for personnel that require access to the protected area
- interviewed operators in the UR area to ensure they were knowledgeable of NCS-related IROFS associated with the HLDs, specifically the administrative requirements specified in NCS Posting 15-05-009, Revision (Rev.) 4
- observed an NCS engineer perform a weekly inspection/walkdown of the pickling area Criticality Programmatic Oversight (IP Section 02.04)
The inspectors reviewed NCS program procedures, audits, and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections including Chapter 5 of the license application. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:
- first quarter 2021 audit for the NCS Unit, dated February 19, 2021 4
Criticality Incident Response and Corrective Action (IP Section 02.05)
The inspectors reviewed the licensees criticality accident alarm system (CAAS) and corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors observed activities, reviewed documents, and/or interviewed licensee staff concerning the following:
- licensee's response to the February 26, 2021, SCALE user notification of a cross section error concerning the h-poly material (NCS-2021-025)
- licensee's evaluation of the NCS safety concern related to the concern for geometry error related to chords (NCS-2021-037)
- NCS-TR-00007, "Validation Report for SCALE 6.1 on Windows 7-based computers"
- NCS-TR-00066, "NCS Technical Reference for Portable Criticality Detector Coverage at the Access Control Facility for Radiation Work Permit (RWP)21-002"
- reviewed two emergency preparedness procedures covering recovery and re-entry procedures following an actual criticality accident (EPR-01-01 and EPR-02-03) 88135.02 - Plant Status The inspectors routinely conducted walkdowns of licensee areas, observed operators, material control and accounting and security force personnel, inspected postings and licensee guidance documents, interviewed plant personnel, and discussed the results of operational and shift turnover meetings to gain insight into the status of facility activities, risk-inform the selection and implementation of the appropriate core inspection procedures, and ensure compliance with license and regulatory requirements.
Plant Tours (IP Section 03.01)
The inspectors performed weekly tours of plant operating areas housing special nuclear material (SNM) to verify that licensed activities were conducted safely and in compliance with the license and 10 CFR 70, Domestic Licensing of Special Nuclear Material.
Status Meetings (IP Section 03.02)
The inspectors, on a routine basis, attended and reviewed the results of scheduled licensee meetings to determine plant status and awareness of site activities so that inspection resources were appropriately focused on those activities with the higher safety significance.
Record and Log Reviews (IP Section 03.03)
The inspectors reviewed selected records and logs to assure they were developed, maintained, and reported as required by applicable license and regulatory requirements.
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Identification and Resolution of Problems (IP Section 03.05)
The inspectors reviewed selected issues to determine if the licensee was entering equipment, human performance, and other performance issues in a formalized program to identify, track and assure correction of safety and safeguard significant problems in accordance with 10 CFR 70.62(a)(3) and applicable license requirements.
- corrective action (CA) 2021-0138, delayed ignition noise and shaking during startup of the Waste Treatment facility gas dryers on November 11, 2020, report date July 13, 2021
- CA 2021-0532, operator's personal breathing zone apparatus exceeded action levels due to a glovebox glove tear during blending operations on April 14, 2021, report date June 25, 2021
- CA 2021-0816, fuel element stored in non-fuel bearing storage rack on June 5, 2020, report date August 30, 2021
- CA 2021-0841, SNM-bearing solution spill inside UR facility due to an axial crack of a main extraction polyvinyl chloride or 'PVC' column (IROFS) on June 5, 2021, report date August 16, 2021
- CA 2021-0859, meteorological monitoring station found inoperable on June 15, 2021, report date August 9, 2021
- CA 2021-0870, material containing natural uranium (i.e., source material) powder self-ignites while being removed from WS-145 in the SFF area on June 16, 2021, report date September 8, 2021
- CA 2021-1311, SFF waste sink drain line (IROFS) clogged on September 14, 2021, report date September 29, 2021 Event Review (IP Section 03.06)
The inspectors reviewed the plant events listed below to determine if the event warranted the use of formal event review criteria and to evaluate the licensees response was in accordance with 10 CFR Parts 40.60 (source material), 70.50 (mainly radiological events),
70.52 (criticality and safeguards events), 71.95 (transportation events), 73.71 (safeguards events) and 20.2201, 20.2202, and 20.2203 (radiological and environmental events).
- CA 2021-0975, missing configuration management seal for fixed neutron poison tray in automated storage conveyor on June 28, 2021
- CA 2019-1588, potential failure mode for SFF liquid waste system inline monitor on September 29, 2021 Procedures (IP Section 03.08)
The inspectors reviewed and observed implementation of the procedure listed below to ensure that safety-significant procedures were developed and/or maintained in accordance with Chapter 11, Management Measures, of the license application, the change management system, and implementing procedures:
- OP-0061242, "Operating Procedure for Inline Monitoring System,"
Rev. 36. Procedure revision (CHG-10675) associated with changes to UR's 6
inline monitor system (e.g., inline monitors No. 1, No. 2, and No. 3) replacement of valves, piping, and pots.
Radiation Work Permit (IP Section 03.09)
The inspectors reviewed and observed the RWP listed below to determine whether the RWP contains the information required by Chapter 4, Radiation Safety; of the license application, the Radiation Protection Manual; and implementing procedures:
- RWP 21-0045, "SFF WS-145 Temporary Operation," Rev. 0, observed on September 28, 2021 Annual Security and Emergency Preparedness Drills/Exercises (IP Section 03.10)
The inspectors observed the licensees performance during the evacuation and emergency preparedness exercises listed below to determine they were being implemented in accordance with 10 CFR 70.24(a)(3) and 10 CFR 70.22(I)(3), respectively:
- On July 1, 2021, the inspectors observed the annual evacuation drill for first and third shift employees. The inspectors conducted the following: (1) Pre-drill walkdowns of the evacuation routes to verify they were clearly identified, followed the quickest and most direct routes practicable, and led personnel to a pre-established assembly area. (2) Walkdown of the evacuation area to verify it minimized the potential for exposing the evacuating personnel to radiation. (3) Assessed evacuation alarm performance and employee response from Bay 2A to verify the alarm was audible and employees evacuated promptly. (4) Verified licensee conducted personnel accounting in accordance with established emergency response procedures.
- On August 16, 2021, the inspectors responded and observed, from the emergency operations center (EOC), an actual activation of the licensee's emergency response (ERO) and emergency management (EMO) organizations. An emergency team assembly alert was sounded approximately at 8:35 a.m. after a high-energy steam line break associated with an SNM process vessel in Bay 5A caused multiple smoke detectors to go into alarm. The ERO promptly responded to the scene, took actions to terminate the event, and conducted a damage assessment. There were no personnel injuries nor impacts to the SNM being processed as a result of the incident, and the EOC was de-activated approximately at 9:15 a.m. The inspectors evaluated the EMOs command and control, communications, accident assessment, event classification, and post-event critique. Additionally, the inspectors conducted a post-event walkdown to verify that SNM had not been impacted.
88135.04 - Resident Inspection Program Operational Safety The inspectors evaluated whether the material condition and as-found configuration of selected site structures, systems, and components, documentation, personnel, and IROFS to verify compliance with 10 CFR Part 70, the license, the SAR, license application, and licensee policies and procedures; and determine whether they are appropriate, available, and reliable to protect worker and public safety during normal, off-normal, and accident conditions.
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Operations Safety Walkdown (IP Section 03.01)
The inspectors evaluated the operational safety of the systems and sub-systems and/or processes listed below associated with SAR 15.19, "Waste Handling, Vacuum System, and Ventilation for SFF Operations," Rev. 75:
- liquid waste handling system (WS-56)
- lab sink collection system (WS-30)
- vacuum system
- ventilation system 88135.05 - Resident Inspection Program Fire Protection (Annual/Quarterly)
The inspectors evaluated the operational status and material condition of fire protection systems, structures, and components (SSCs) to verify compliance with the fire protection program as described in Chapter 7, Fire Safety of the license application, and the National Fire Protection Association (NFPA) 801, Standard for Fire Protection for Facilities Handling Radioactive Materials, as required.
Fire Area Walkdown (IP Section 03.01)
The inspectors walked down and evaluated the fire area listed below:
- RTR Facility Bays 13, 14, 15, and 16 conducted September 22 and 24, 2021 88135.17 - Permanent Plant Modifications The inspectors evaluated implementation of the configuration management system for facility changes or modifications to ensure that safety-related systems, structures, and components (i.e., IROFS or other credited safety controls) could adequately perform their intended safety function and that changes did not adversely impact the operability and safety of the facility.
Facility Change/Modifications (IP Section 03.01)
The inspectors reviewed facility changes associated with SFF vacuum, ventilation, and low-level liquid waste handling systems to determine whether they were implemented in accordance with 10 CFR 70.72, Facility changes and change process. Specifically, the inspectors reviewed the following changes:
- CHG-3425, "Valve Replacement in SFF Liquid Waste System No. 2 and Drawing Update," approved January 26, 2018
- CHG-3786, "Maintenance Plan (MP) for SFF Waste System Valve No.
HV-754 (IROFS)," approved February 21, 2018
approved March 12, 2018 8
- CHG-4347, "Documentation Revision to Valve HV-756 (IROFS) on SFF Waste System," approved March 2, 2018
- CHG-6721, "Revise OP-1001832 - SFF Low-Level Waste System No 2,"
approved August 6, 2019
- CHG-7951, "Rebuild Filter Manifold for SFF House Vacuum System,"
approved March 20, 2020
- CHG-7556, "Electrical Changes to SFF Waste System Inline Monitor (IROFS)," approved January 8, 2020 Management Measures (IP Section 03.02)
The inspectors reviewed the following management measures to ensure that IROFS or other credited safety controls affected by the facility changes identified in Section 03.01 remained available and reliable to perform their function when needed to comply with the performance requirements of 10 CFR 70.61 or applicable conditions of the license:
- Configuration Management:
o UPRR-10042 (P&ID), "13A Mezz. House Vacuum System Wet and Dry Vacuum Pumps," Rev. 2 (CHG-7951) o UPRR-10079 (P&ID), "SFF Liquid Waste System Flow Diagram," Rev.
05 (CHG-3425 and CHG-4347) o 13AE4_1017 (P&ID), "CRF Inline Monitor System No. 2," Rev. 4 (CHG-7556)
- Procedures:
o OP-1001832, "Operating Procedure for SFF Low-Level Waste System No. 2," Rev. 21 (CHG-6721)
- Post-Maintenance Testing:
o work order (WO) 20279415, "SFF Inline Monitor / Valve Loss of Power/Air Test following Implementation of CHG-7556," conducted March 2, 2020
- Maintenance/Surveillance:
o MP-2925, "SFF Inline Monitor No. 2 and Interlocked Valve SV-707 Loss of Power/Air Test - Annual" (CHG-7556) o MP-4387, "SFF Waste Columns Process Water Supply Valve (HV-754) Inspection" (CHG-3786 and CHG-4347) o MPs-4388, 4389, and 4390, "SFF Waste Columns V-701, V-702, V-703, and V-704 Vent Inspection" (CHG-3798) o MP-4436, "SFF Waste System to Process Water Backflow Preventer (CV-701) - Annual Test" (CHG-4268) 88135.19 - Post-Maintenance Testing The inspectors evaluated post-maintenance test activities to verify compliance with license application Chapter 11, Management Measures, and test procedures and/or WO instructions to confirm functional capability of the IROFS and/or safety controls following maintenance.
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Post-Maintenance Testing (IP Section 03.01)
The inspectors reviewed the post-maintenance test listed below. Tests were either observed directly or test results were reviewed.
- OP-0061250, calibration of UR inline monitors No. 1, No. 2, and No. 3 (IROFS) following system plumbing changes per change evaluation CHG-10675. Calibrations were conducted July 21, July 23, and July 19, 2021, respectively.
88135.22 - Surveillance Testing The inspectors evaluated IROFS and safety controls that required periodic surveillance and/or calibration tests to ensure they were available and reliable to perform their function when needed, to comply with license application Chapter 11, Management Measures, and the performance requirements of 10 CFR 70.61 and 70.62, and to maintain their operational readiness consistent with the ISA.
Surveillance and Calibration Testing (IP Section 03.01)
The inspectors reviewed the two surveillance and/or calibration tests listed below. Tests were either observed directly or test results were reviewed.
- E61-023 and E61-044, inline monitor operation checks, daily and shift (respectively), conducted July 27, 2021
- MP-3329, "Visual Sink Drain / Overflow Column - 6 Month," conducted September 24, 2021 FACILITY SUPPORT 88072 - Plant Modifications (Triennial)
The inspectors conducted an extensive review into the licensees configuration management system for plant modifications to ensure that safety-related systems and components (i.e., IROFS or credited safety controls) could adequately perform their intended safety function and that system changes had not adversely impacted plant safety and operability. The inspectors review focused on verifying compliance with the applicable requirements in 10 CFR 70 and the license application Chapter 11, Management Measures.
Selection of Modifications (IP Section 02.01)
The inspection team leader reviewed licensing documents and conducted a site preparation visit on July 30, 2021, to discuss plant modifications in risk-significant areas/processes with the licensee. The inspectors selected the following processes for an in-depth review of historical modifications identified as change (CHG) and SERs:
Restart of SFF TRi-structural ISOtropic (TRISO) production equipment:
- CHG-7110, "Restart of Workstation (WS)-300 and WS-250 in SFF," approved September 4, 2019
- CHG-7113, "Restart of WS-100 in SFF," approved September 25, 2019 10
- CHG-7093, "Restart of WS-110 in SFF," approved September 20, 2019
approved May 26, 2021
- SER 20-012, "Removal of titrator, caustic column, and enclosure windows on WS-320 (SFF Scrubber)," approved April 29, 2021
- SER 20-023 Phase 01, "Facility uninterruptible power supply (UPS) to WS-145 and WS-300 backup cooling pumps" Design Process Review (IP Section 02.02)
For the selected modifications listed above, the inspectors reviewed the design process to verify the licensee followed the applicable configuration management requirements in the license application and 10 CFR 70. Specifically, the inspectors conducted the inspection activities listed below:
- interviewed licensee staff, performed walkdowns, and reviewed change packages and supporting documentation to verify that plant changes were developed, reviewed, approved, and implemented in accordance with 10 CFR 70.72, Facility Changes and Change Process, and 70.62(d), Management Measures"
- interviewed licensee staff, performed walkdowns, and reviewed the SAR and safety program information impacted by the modifications to verify compliance with 10 CFR 70.62, 10 CFR 70.72, and the baseline design criteria of 10 CFR 70.64, as applicable
- interviewed licensee staff, performed walkdowns, and reviewed change management packages and supporting documentation to verify that safety systems and components impacted by the modification, including interactions with other systems, would perform their intended safety function as described in the ISA and safety program documentation
- interviewed licensee staff, performed walkdowns, and reviewed documentation to verify the licensee applied management measures to the IROFS affected by the modifications in accordance with 10 CFR 70.62
- interviewed licensee staff, performed walkdowns, and reviewed corrective action documents for plant modification issues to verify compliance with the CAP activities described in Chapter 11, "Management Measures," of the license application. The scope of the corrective action review included outstanding design and operational issues for the processes selected for in-depth review
- reviewed records to verify SFF engineers were trained and qualified to perform their assigned duties
- reviewed records for safety evaluation originators to verify that personnel conducting 10 CFR 70.72 evaluations and SERs were qualified in accordance with licensee procedures 11
System Condition and Capability Review (IP Section 02.03)
For the selected modifications, the inspectors reviewed the system condition and tested capability to verify they were consistent with the applicable design requirements and licensing basis. Specifically, the inspectors conducted the inspection activities listed below:
- conducted walkdowns with SFF process engineering and reviewed records to verify that the as-built configuration of the system/equipment was consistent with the process safety information and SAR changes contained in the plant modification packages
- reviewed SAR 15.18, "SFF Dry-End Processing SFF Operation," to determine if the licensee was maintaining the ISA Summary consistent with the requirements of 10 CFR 70.72
- reviewed SAR 15.17, "SFF Wet-End Processing in SFF Operations," to determine if the licensee was maintaining the ISA Summary consistent with the requirements of 10 CFR 70.72
- reviewed SAR 15.36, "Generator and UPS Power Systems," to determine if the licensee was maintaining the ISA Summary consistent with the requirements of 10 CFR 70.72
- reviewed records to verify that Change Review Board reviews were conducted for CHG-7113 for the TRISO kernel forming workstation (WS-100) restart and CHG -7093 for the wash and dry workstation (WS-110) restart
- conducted interviews, records reviews, and plant walkdowns to verify whether management measures were properly implemented to ensure that IROFS or other safety controls were available, capable, and reliable to perform their function when needed; specifically, the inspectors reviewed the revised NCS posting associated with SER-20-010
- conducted interviews and records reviews to verify that IROFS administrative controls that involve operator action could be accomplished as assumed in the licensees ISA. Specifically, the inspectors reviewed OP-1015720, "Operating Procedure for Coating in the Centorr Furnace for TRISO," to verify that a new administrative IROFS to leak check the furnace and soot filter was added to the procedure Post-Modification Testing (IP Section 02.04)
For the selected modifications, the inspectors interviewed licensee staff and reviewed post-modification testing records to determine whether the plant was in a safe configuration during post-modification testing. The inspectors reviewed the following post-modification tests to determine whether post-modification testing ensured adequate implementation of the design and safety system functionality.
SFF Restart:
- reviewed the electrical/mechanical test plan for changes to the TRISO 6-inch finishing furnace (WS-300) per SER 21-013
- reviewed the TRISO 6-inch finishing furnace and load/unload workstations (WS-300/WS-250) restart plan
- reviewed the annual functional testing of TRISO kernel forming workstation (WS-100) required by CHG-7113 restart 12
- reviewed the TRISO kernel forming workstation (WS-100) restart plan Documentation Review (IP Section 02.05)
The inspectors reviewed the following plant documents impacted by the modifications selected for review to verify the licensee had either updated or was in the process of updating such documents to reflect the modifications in accordance with the license application requirements and 10 CFR 70.72.
- reviewed operating procedures OP-1014625 and OP 1005350 to verify they were updated for the TRISO WS-100 restart
- reviewed piping & instrumentation diagram (P&ID) UPRR-10060 to verify it was updated for the TRISO WS-250/WS-300 restart
- reviewed P&ID 8173-E-1020 to verify the modifications from SER 20-023 (Phase-01), "Facility UPS power to WS-145 and WS-300 backup cooling pumps" were incorporated
- reviewed training records of SFF operators to verify they were trained on procedure changes associated with various modifications INSPECTION RESULTS Inadequate Maintenance of Sink Drain Line NCS IROFS Severity Report Section Severity Level IV 88135.22 NOV 07000027/2021003-01 Closed
Introduction:
The NRC inspectors identified a cited Severity Level (SL) IV violation of 10 CFR 70.61(e) and 70.62(d) for BWXTs failure to implement adequate management measures to ensure the availability and reliability of the specialty fuels facility (SFF) area waste sink drain line. The drain line was an NCS passive engineered IROFS control to prevent waste solution from exceeding favorable geometry.
Description:
SFF operators use the workstation (WS) 30 sink to dispose waste solutions from miscellaneous area operations. The drain line at the bottom of the sink was a passive engineered NCS IROFS to prevent solution from backing up into the sink and exceeding favorable geometry limits (i.e., solution height) as solutions are poured into the sink. The licensee tests/inspects the sink drain line every 6 months to ensure there is no significant buildup or blockage on the drain line. The test is conducted in accordance with instructions contained in maintenance plan (MP) 3329. The MP was identified as a management measure in the ISA Summary (SAR 15.19, Waste Handling, Vacuum System, and Ventilation for SFF Operations, Rev. 75) to ensure the reliability and availability of the drain line.
On September 14, 2021, SFF area operators were disposing waste solutions and noted that solution was draining slowly (i.e., backing up into the sink). Operators stopped waste operations and notified area supervision. WS-30 was placed out of service and the condition was entered in the corrective action program (CAP) under corrective action (CA) report no.
2021-1311 as a degraded IROFS. Per the licensees accident analysis, this condition (an 13
initiating event) was expected to occur at a frequency of once every 10 years. The inspectors conducted an operating history review of corrective maintenance for the SFF sink and noted there had been at least five instances where work requests had been generated to troubleshoot the sink for clogging/blockage issues between February 2019 and September 2021 (~2.5 years). This failure/degradation rate translated to a frequency of approximately 20 upsets every 10 years.
Section 11.2, Maintenance, of license application Chapter 11, Management Measures stated, that a site maintenance program is implemented to ensure engineered IROFS remain functionally available and reliable. The maintenance program consisted of (1) surveillance/functional testing, (2) corrective maintenance, and (3) preventive maintenance activities. It also stated, in part, that in the event of a failed IROFS during a scheduled test or during service a CAP investigation shall be conducted in accordance with Section 11.6, Corrective Action Program, of the license application. The results of the investigation shall provide feedback that may warrant modification to the maintenance or the IROFS itself. The inspectors noted that none of the in-service failures prior to the most recent one (i.e.,
September 14, 2021) had been investigated or captured in the CAP, as required by Sections 11.2 and 11.6 of the license application. The latest failure was captured in the CAP after a heightened sensitivity of area personnel to drain line performance as a result of NRC inspectors concerns that drain line performance issues were not being captured in the CAP for follow-up investigation and corrective actions as required by the license application.
Corrective Actions: The licensee took corrective actions to modify the drain line and make it less prone to clogging and will temporarily monitor drain line performance, daily, to verify the effectiveness of the modifications to maintain the line free of obstructions.
Corrective Action
References:
This issue was entered into the licensees CAP as CA 2021-1311.
Analysis: The failure to implement adequate management measures to ensure the availability and reliability of the SFF area waste sink drain line IROFS was a violation of 10 CFR 70.61(e) and 70.62(d). The inspectors determined the violation was more than minor based on screening criteria question 3 of IMC 0616, Fuel Cycle Safety and Safeguards Inspection Reports, Appendix B, Examples of Minor Violations. Question 3 asked, in part, Is the violation indicative of a programmatic deficiency. The violation was indicative of a programmatic deficiency because it involved multiple examples of failing to implement maintenance and corrective action programs to ensure the availability and reliability of the sink drain line IROFS.
The inspectors determined that the actual and potential safety significance of the violation was low because other IROFS remained in place and the risk of criticality remained highly unlikely; therefore, the performance criteria of 10 CFR 70.61(b) were maintained. Consistent with Section 6.0, Violation Examples, of the NRC Enforcement Policy the violation aligned with the SL-IV violation Example 6.2.d.1 in that it involved the licensees failure to meet a requirement of 10 CFR 70.61 where the failure did not result in a SL I, II, or III violation.
Enforcement:
Severity: Consistent with Section 6.0, Violation Examples, of the NRC Enforcement Policy the violation aligned with the SL-IV violation Example 6.2.d.1 in that it involved the licensees failure to meet a requirement of 10 CFR 70.61 where the failure did not result in a SL-I, II, or III violation.
14
Violation: Title 10 of the Code of Federal Regulations 70.61(e) required, in part, that the safety program established and maintained pursuant to § 70.62 of this subpart, shall ensure that each IROFS will be available and reliable to perform its intended function when needed and in the context of the performance requirements of this section. § 70.62(d) identified the requirements for the safety programs Management Measures element and required, in part, that management measures shall ensure that controls identified as IROFS pursuant to
§ 70.61(e) are maintained, as necessary, to ensure they are available and reliable to perform their function when needed, to comply with the performance requirements of § 70.61 of this subpart.
Contrary to the above, prior to September 14, 2021, the licensee failed to establish adequate management measures (maintenance and corrective action program) to ensure that the SFF waste sink drain line, identified as an IROFS, was maintained such that it remained available and reliable to perform its function, to comply with the performance requirements of 10 CFR 70.61.
Enforcement Action: This violation is being cited because the licensee does not have an NRC-approved Corrective Action Program and did not identify the violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
- On October 20, 2021, the inspectors presented the integrated inspection results to James J. Bittner and other members of the licensee staff.
- On July 29, 2021, the inspectors presented the NCS inspection results to Rich Freudenberger and other members of the licensee staff.
- On September 23, 2021, the inspectors presented the plant modification (triennial) inspection results to James J. Bittner and other members of the licensee staff.
15
DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88015 Corrective 2021-0230 01/28/2021 Action Documents 88015 Corrective 2021-0277 07/26/2021 Action Documents 88015 Corrective 2021-0306 02/26/2021 Action Documents 88015 Corrective 2021-0503 04/08/2021 Action Documents 88015 Corrective 2021-0841 06/05/2021 Action Documents 88015 Drawings 14AM3_1000 Bay 14A Mechanical Trough Detail Rev. 0 88015 Drawings REC-CP-0153 Dissolver Tray HLD Upgrade Rev. 1 88015 Drawings UPRR-30118 Trough Dissolver P&ID Rev. 4 88015 Engineering NCS-2009-035 Nuclear Criticality Safety Release for SER 08-047, 04/02/2009 Evaluations Phase 1, Trough Dissolver System 88015 Engineering NCS-2010-142 NCS Analysis for SER-029 Phase 1, Trough Pass- 09/15/2010 Evaluations Through Box Safety Analysis & System Modifications 88015 Engineering NCS-2010-180 Nuclear Safety Release for SER 10-029 Phase 1, 11/30/2010 Evaluations Trough Pass-through Box Safety Analysis &
System Modifications 88015 Engineering NCS-2010-223 Revised NCS Analysis for SER 10-029 Phase 1, 10/27/2010 Evaluations Trough Pass-Through Box Safety Analysis &
System Modifications 88015 Engineering NCS-2021-025 NCS Safety Concern for SCALE h1-poly Incoherent 03/15/2021 Evaluations Elastic Scattering Error 88015 Engineering NCS-2021-036 NCS Safety Concern for Hydraulic Fluid on Multiple 04/05/2021 16
Inspection Type Designation Description or Title Revision or Procedure Date Evaluations Fuel Components - CA202100277 88015 Engineering NCS-2021-037 NCS Safety Concern for SCALE 3D Geometry 04/05/2021 Evaluations Error Related to Chords 88015 Engineering NCS-2021-042 SCALE Verification for Windows 10 Workstation 04/19/2021 Evaluations LPPAP21 88015 Engineering NCS-2021-054 NCS Safety Concern Analysis for Recovery Leak 06/16/2021 Evaluations per CA202100841 88015 Engineering NCS-PA-25-00001 Nuclear Criticality Safety Evaluation of Recovery Rev. 2 Evaluations Furnace System 88015 Engineering NCS-TR-00007 Validation Report for SCALE 6.1 Rev. 5 Evaluations 88015 Engineering NCS-TR-00066 NCS Reference for Portable Criticality Detector 04/14/2021 Evaluations Coverage at the Access Control Facility (ACF) for RWP21-022 88015 Engineering SCALE Input File High-Level Trough/Column Dissolver System Model 10/27/2010 Evaluations hld_tri_im0_contpos6_overfill (NCSE-2010-223) 88015 Miscellaneous 15-05-009 NCS Posting - Trough Dissolver Enclosure Rev. 4 88015 Miscellaneous E61-001 Uranium Processing and Research Reactors OJT - Rev. 16 Recovery Operations 88015 Miscellaneous E61-459 Uranium Recovery Personnel Training Record Rev. 43 88015 Miscellaneous E61-659 HLD U-235 Log Training 88015 Miscellaneous NCS-2021-009 Qualification of Brittany Williamson as an NCS 02/11/2021 Auditor 88015 Miscellaneous NCS-2021-048 Qualification of John Valenti as an NCS Auditor 05/13/2021 88015 Miscellaneous SAR 15.5 High-Level Dissolution Process in Uranium Rev. 143 Recovery 88015 Miscellaneous TP-REC-0006 Training Plan for High-Level Dissolver Area Rev. 1 88015 Procedures E61-659 High-Level Trough Dissolver U-235 Log Rev. 6 88015 Procedures E61-689 High-Level Trough Dissolution Process Variable Rev. 1 Specification Sheet (PVSS) 88015 Procedures EPR-01-01 Emergency Plant Evacuation Rev. 24 88015 Procedures EPR-02-03 Radiological Procedure for an Unannounced Rev. 14 Sounding of the Howlers 88015 Procedures NCSE-03 Nuclear Criticality Safety Audits and Inspections Rev. 29 17
Inspection Type Designation Description or Title Revision or Procedure Date 88015 Procedures OP-1018680 Recovery High-Level Dissolution Rev. 45 88015 Self- N/A Nuclear Criticality Safety Weekly Inspection Form, 03/30/2021 Assessments Chemical Recovery, Drum D 88015 Self- NCS 1st Quarter 2021 Audit 02/19/2021 Assessments 88072 Corrective 2020-0974, 2021-0024, 2021-0605, 2021-0790 Various Action Documents 88072 Drawings 8173-E-1020 TRISO Finishing Furnace Rev. 0 88072 Drawings UPRR 10045 Workstation 100 & 110 Top & Elevation View Rev. 2 88072 Drawings UPRR 10058 WS 320 Scrubber P&ID Rev. 03 88072 Drawings UPRR-10060 Workstation 300 P&ID Rev. 03 88072 Engineering CHG-10006 WS 300 Upgrades - Cooled Exhaust and New Soot 03/05/2021 Changes Filter 88072 Engineering CHG-10326 Changes to SAR 15.18 Per SER 20-012 PH01 03/29/2021 Changes 88072 Engineering CHG-7093 Restart of WS 110 in SFF 09/20/2019 Changes 88072 Engineering CHG-7110 Restart of WS 300 and WS 250 in SFF 09/04/2019 Changes 88072 Engineering CHG-7113 Restart of WS 100 in SFF 09/25/2019 Changes 88072 Engineering CHG-7311 Change In Location of Mixing Pot within WS 100 10/31/2019 Changes 88072 Engineering CHG-7323 Change in TRISO Mixing Pot 11/01/2019 Changes 88072 Engineering CHG-7345 Equipment Modifications to Workstation 100 - 11/05/2019 Changes TRISO Fuel Fabrication 88072 Engineering CHG-7375 Revision to OP-1014605 11/8/2019 Changes 88072 Engineering CHG-7396 Revision to OP-1000880 11/13/2019 Changes 88072 Engineering CHG-7425 Creation of Training Plans for SFF Work Associated 11/16/2019 Changes with WS 100 and WS 110 18
Inspection Type Designation Description or Title Revision or Procedure Date 88072 Engineering CHG-7602 Revision to OP-1014625 12/20/2019 Changes 88072 Engineering CHG-7603 OP-1014613 Revision for Workstation 110 TRISO 12/20/2019 Changes Restart 88072 Engineering CHG-7615 Modify Soot Collection Bucket on WS 300 01/03/2021 Changes 88072 Engineering CHG-7703 Restart of SFF Scrubber (WS 320) and Removal of 01/23/2020 Changes Titrator, Caustic Column, and Lexan Enclosure Windows 88072 Engineering CHG-7760 Replace Coolant Drain Manifolds on WS 145 and 01/20/2020 Changes WS 300 88072 Engineering SER 20-010 Phase 1 TRISO Workstation 300/Workstation 250 NCS Limit 05/26/2021 Changes Change (Add'l Info 05/11/2020) 88072 Engineering SER 20-012 Phase 01 Removal of Titrator, Caustic Column and Enclosure 04/29/2021 Changes Windows on WS 320 (SFF Scrubber) - (Add'l Info 05/19/2020) 88072 Engineering CHG for TRISO Process Hazards Identification 10/16/2019 Evaluations Checklist 88072 Engineering Process Hazards Identification Checklist for CHG- 10/03/2019 Evaluations 7113. Restart of WS 100 in SFF 88072 Engineering 97-00044-01 Fire Safety Analysis - Ignition Sources for PHA-9 04/10/1997 Evaluations Process Area (CRF "Wet End")
88072 Engineering 97-00045-00 Fire Safety Analysis - Historical Data Review for 03/13/1997 Evaluations PHA-9 (CRF "Wet-Side" Processing) 88072 Engineering N-517 10 CFR 70.72 Change Evaluation Checklist, SER 06/11/2020 Evaluations No.20-012 Phase 1, Removal of Titrator, Caustic Column and Enclosure Windows on WS 320 (SFF Scrubber) 88072 Engineering N-517 10 CFR 70.72 Change Evaluation Checklist for 10/03/2019 Evaluations CHG-7113 Restart of WS 100 in SFF (NCS) 88072 Engineering N-517 10 CFR 70.72 Change Evaluation Checklist, CR 11/08/2019 Evaluations No. 7110 Restart of WS 300 and WS 250 in SFF (LIC) 88072 Engineering N-517 10 CFR 70.72 Change Evaluation Checklist, CR 12/03/2019 19
Inspection Type Designation Description or Title Revision or Procedure Date Evaluations No. 7110, Restart of WS 300 and WS 250 in SFF (IHS) 88072 Engineering N-517 10 CFR 70.72 Change Evaluation Checklist, CR 10/31/2019 Evaluations No. 7110, Restart of WS 300 and WS 250 in SFF (RP) 88072 Engineering N-517 10 CFR 70.72 Change Evaluation Checklist, for 10/08/2019 Evaluations CHG-7113 Restart of WS 100 in SFF (LIC) 88072 Engineering N-517 10 CFR 70.72 Change Evaluation Checklist, for 10/09/2019 Evaluations CHG-7113 Restart of WS 100 in SFF (RP) 88072 Engineering N-517 10 CFR 70.72 Change Evaluation Checklist, for 10/18/2019 Evaluations CHG-7113 Restart of WS 100 in SFF (IHS) 88072 Engineering NCS-2020-039 NCS Safety Analysis Supporting SER 20-012, 06/10/2020 Evaluations Phase 1 - Removal of Titrator, Caustic Column, and Enclosure Windows on WS 320 (SFF Scrubber) -
(Add'l Info 5/19/20) 88072 Engineering NCS-2020-071 NCS Safety Analysis for SER 20-010, Phase 1 to 10/21/2020 Evaluations Increase the NCS Mass Limit for TRISO Workstations 250/300 88072 Engineering NCS-2021-031 NCS Safety Analysis for SER 21-013 for Equipment 05/05/2021 Evaluations Upgrades on TRISO WS300 Furnace and WS230 Scrubber 88072 Engineering NCS-PA-17-00001 Nuclear Criticality Safety Evaluation of SFF Wet 11/21/2019 Evaluations Systems 88072 Engineering NCS-PA-17-00001 Nuclear Criticality Safety Evaluation of SFF Wet 11/21/2019 Evaluations Systems 88072 Miscellaneous Electrical/Mechanical Test Plan for Changes to 08/20/2021 WS300 per SER 21-013 88072 Miscellaneous SFF Operator Training Records 88072 Miscellaneous SER Evaluator Training Records 88072 Miscellaneous E61-001A SFF Operator OJT Rev. 16 88072 Miscellaneous E61-638 Uranium Processing and Research Reactors OJT - Rev. 8 Engineers/Technicians 88072 Miscellaneous MP-3477 & 3478 WS 100 and 110 Annual Functional Testing 02/13/2020 88072 Miscellaneous N-50 Employee Review of Area Documents for OP- 11/15/2019, 20
Inspection Type Designation Description or Title Revision or Procedure Date 1015720 08/26/2020, 09/15/2020, 11/19/2020, 03/17/2021, 06/07/2021, 08/11/2021 88072 Miscellaneous SAR 15.17 SFF Wet-End Processing in SFF Operations Rev. 84 88072 Miscellaneous SAR 15.18 SFF Dry-End Processing SFF Operation Rev. 13 88072 Miscellaneous SAR 15.36 Generator and UPS Power Systems 01/28/2021 88072 Miscellaneous TP-SFF-0012 Training Plan for: Operate WS 100 Rev. 0 88072 Miscellaneous TP-SFF-0017 Training Plan for: Operate WS 300 Rev. 0 88072 Operability Change Review Board Requirements & Readiness 09/03/2020 Evaluations Review Checklist for CHG#
00007110/WS300/WS250 88072 Procedures OP-1001828 Operating Procedure for FAS Interlocks and Rev. 40 Furnace Testing 88072 Procedures OP-1005350 Rev. 12 88072 Procedures OP-1015720 Operating Procedure for Coating in the Centorr Rev. 45 Furnace for TRISO 88072 Procedures QWI 02.1.03 Integrated Safety Analysis Methodology Rev. 18 88072 Procedures QWI 2.1.17 Suspending and Restarting Fuel Operations Rev. 3 88072 Procedures QWI 5.1.12 Change Management Rev. 35 88072 Procedures QWI 5.1.7 Safety Evaluation Requests Rev. 35 88072 Work Orders 20301800 SC WS-110 BNK #12 HEPA 3Y SFF 05/01/2021 88072 Work Orders 20301806 SC HEPA Filter WS-300 3Y SFF 05/01/2021 88072 Work Orders 20301812 SC Hepa Filter WS-100 Bank #16 3Y SFF 05/01/2021 88072 Work Orders 20301813 SC WS-100 HEPA Filter Band #15 3Y SFF 05/01/2021 88072 Work Orders 20301818 SC HEPA FILT WS-110 BNK #11 3 YR SFF 05/01/2021 88072 Work Orders 20307347 SC Change Vac Pump Filt WS 300 1 Yr SFFO 08/01/2021 88135.02 Corrective 2021-0870 Material containing natural uranium (i.e., source Action material) powder self-ignites while being removed Documents from WS 145 in the SFF area, incident June 16, 2021 88135.02 Corrective 2021-0972 Employee did not evacuate as required during 07/01/2021 21
Inspection Type Designation Description or Title Revision or Procedure Date Action annual evacuation drill Documents 88135.02 Corrective 2021-1311 SFF waste sink drain line clogged, incident 09/29/2021 Action 09/14/2021 Documents 88135.02 Corrective CA2021-1358 Recovery blending glovebox capture airflow 09/23/2021 Action velocity at an uncovered glove port was less than Documents the minimum required 100 linear feet per minute, Resulting from incident date 09/15/2021 Inspection 88135.02 Drawings UPRR-10081 Waste Sink PFD Rev. 0 88135.02 Drawings UPRR-30147 Inline Monitors 1, 2, and 3 P&ID Rev. 3 88135.02 Drawings UPRR-30147 Inline Monitors 1, 2, and 3 P&ID Rev. 2 88135.02 Engineering CHG-10675 Inline Replumb in Recovery 06/28/2021 Changes 88135.02 Engineering CHG-10765 Lighting Track for Primary/Raffinate Extraction 06/14/2021 Changes Column LED Lights 88135.02 Engineering CHG-11202 Improve Flow Capability of SFF Sink Drain 09/22/2021 Changes 88135.02 Engineering CHG-8022 Add Power Supply and Control Panel Box for 04/16/2020 Changes Primary Extraction Column LED Lights 88135.02 Engineering SER 21-006 (Phase 1) Waste Treatment LLR Sludge Dryers Gas Feed 03/08/2021 Changes Rework 88135.02 Engineering HS-2021-084 Discussion of Fires Involving Pyrophoric 07/26/2021 Evaluations Material/Combustible Metals in Controlled Areas 88135.02 Engineering NCS-2021-054 NCS Safety Concern for Recovery Column Leak 06/16/2021 Evaluations per CA202100841 88135.02 Engineering NCS-2021-071 NCS Safety Concern for Inadequate Ventilation 08/17/2021 Evaluations Pre-Filter on Workstation 145 - CA202100870 88135.02 Engineering NCS-2021-072 Justification for Continued Operations of SFF 08/17/2021 Evaluations Workstation 145 following CA2021-0870 88135.02 Engineering NCS-2021-089 NCS Safety Concern Analysis for SFF Lab Evaluations Benck/Sink Drain Clog per CA2021-1311 88135.02 Engineering NCS-2021-092 NCS Safety Concern Analysis for Potential Failure 09/29/2021 22
Inspection Type Designation Description or Title Revision or Procedure Date Evaluations Mode for SFF Liquid Waste System Inline Monitor CA201901588) 88135.02 Engineering RPTWR 2021-040 Recommended Additional Management Measures 09/21/2021 Evaluations Toward Assuring Adequate Enclosure Ventilation 88135.02 Engineering RPTWR 2021-041 Glove Breach Airflow Survey at the Met Lab Saw 09/20/2021 Evaluations 88135.02 Miscellaneous Correspondence Industrial Control Specialties, Inc. letter to H. White, 01/18/2021 BWXT NOG-L Waste Operations Engineer,
Subject:
BWXT Watermark Sludge Dryers, Lynchburg Virginia Facility 88135.02 Miscellaneous Correspondence BWXT NOG-Lynchburg - Revision to Chapter 2, 09/09/2021 "Organization and Administration," of License SNM-42 License Application 88135.02 Miscellaneous E61-12 Gamma Well Counter Log (Sample No. 22-Jul 07/22-200001 thru 27-Jul-21-200210) 27/2021 88135.02 Miscellaneous HPB-112/401 Engineering & Installation Guide - Georg Fischer 07/22/2015 Harvel LLC 88135.02 Miscellaneous Memo Recovery Operations Memo to UPRR 06/21/2021 Management, RE: Conduct of Operations Restart (Level 2) - Recovery Processing PVC Column 88135.02 Miscellaneous Memo Conduct of Operations Restart Memo for WS-145, 09/02/2021 WS-140, and WS-300 in the SFF 88135.02 Miscellaneous Memo T.A. Stinson, Manager of Waste Operations, memo 03/03/2021 to Distribution,
Subject:
Waste Treatment LLR Dryers for Restart 88135.02 Miscellaneous N-79 Evaluation of Unusual Incident: Missing seal for 07/22/2021 neutron poison tray in auto storage conveyor 88135.02 Miscellaneous NFPA 86 Standard for Ovens and Furnaces 2015 Edition 88135.02 Miscellaneous SAR 15.12 Liquid and Solid Waste Handling Processes in Rev. 84 Uranium Recovery 88135.02 Miscellaneous SAR 15.21 Low-Level Radioactive Waste Processes Waste Rev. 79 Operations 88135.02 Miscellaneous SAR 15.34 Conventional Filler Operations Rev. 72 88135.02 Miscellaneous SNM-42 Emergency Plan Rev. 34 23
Inspection Type Designation Description or Title Revision or Procedure Date 88135.02 Procedures ADM-NOG-L-0051 Conduct of Operations Rev. 3 88135.02 Procedures EPR-01-01 Emergency Plant Evacuation Rev. 24 88135.02 Procedures EPR-01-01 Emergency Plant Evacuation Rev. 22 88135.02 Procedures EPR-06-07 Plant Evacuation Drill Rev. 7 88135.02 Procedures EPR-06-07 Plant Evacuation Drill Rev. 7 88135.02 Procedures OP-0010101 Filler Fabrication and Operation Rev. 89 88135.02 Procedures OP-0061556 Operating Procedure for Recovery Conversion Rev. 22 Furnace Operations 88135.02 Procedures OP-1015277 Operating Procedure for Fluid Bed Sintering in the Rev. 26 Centorr Furnace for TRISO 88135.02 Procedures OP-1022961 Operating Procedure for Sintering for TRISO and Rev. 10 Other SFF Contracts in the 2.5-inch Furnace at WS-140 88135.02 Procedures QWI 17.1.1 Environmental, Safety, Health & Safeguards Audit Rev. 12 Program 88135.02 Procedures QWI 4.1.5 Attachment 2 - Radiation Protection Engineering Rev. 21 Design Criteria and Guidelines 88135.02 Procedures RP-02-007 Enclosure Air Flow Measurements in Controlled Rev. 11 Areas 88135.02 Radiation RP Air Flow Survey, Area: 14A Recovery 06/02/2021 Surveys Conversion Room, conducted on 88135.02 Radiation Glove Box Glove Survey: Recovery - 14A 02/23/2021 Surveys Conversion (Pages 1 and 2), conducted on 88135.02 Radiation Glove Box Glove Survey: Recovery - 14A 05/18/2021 Surveys Conversion (Pages 1 and 2), conducted on 88135.02 Radiation Alpha Fixed Air Sampling Week Report, Location: 04/18/2021 Surveys UPRR - Recovery, week ending 88135.02 Work Orders 20305764 TRISO Replace Swage Line in Sink Drain, 09/14/2021 completed 88135.02 Work Orders 20308882 TRISO Change Filters 16-HEPA Bank 08/03/2021 88135.02 Work Orders 20311297 TRISO Unclog Sink Drain, completed 09/14/2021 88135.02 Work Orders 20311384 Install Test Flange on Sink Column, completed 09/16/2021 88135.02 Work Orders 20311859 SFF Sink - Replace PVC Test Cap with Stainless 09/24/2021 Components 24
Inspection Type Designation Description or Title Revision or Procedure Date 88135.04 Corrective 2018-1649 Unknown transfer of solution between banks in the 09/03/2021 Action SFF waste column system, incident 11/26/2018 Documents 88135.04 Corrective 2018-0754 SFF vacuum pump high-level probe failed 09/03/2021 Action functional check, incident 05/31/2018 Documents 88135.04 Corrective 2019-0711 Loss of ventilation of SFF dissolver while 09/03/2021 Action conducting testing and rinsing activities, incident Documents 05/22/2019 88135.04 Corrective CA 2021-1377 SFF inline monitor no. 2 Log/Lin Ratemeter/Alarm 10/01/2021 Action module not set (i.e., Linear Range Switch) per OP-Documents 1001832, incident date 09/30/2021 Resulting from CA 2021-1413 Minor procedure and drawing discrepancies 10/08/2021 Inspection identified during review of SAR 15.19 88135.04 Corrective COM-91978 Revise OP-1001832 to clarify normal position of Action inline monitor valve SV-707 Documents Resulting from Inspection 88135.04 Drawings 13AE4_1028 CRF NASH Vacuum Pump Rev. 2 88135.04 Drawings 13AM1_1000 13A First Floor Exhaust Systems Rev. 22 88135.04 Drawings 14AM1_1000 14A Exhaust System - 1st Floor and Mezz Rev. 23 88135.04 Drawings UPRR-10042 13A Mezz. House Vacuum System Wet and Dry Rev. 2 Vacuum Pumps 88135.04 Drawings UPRR-10079 SFF Liquid Waste System Flow Diagram Rev. 05 88135.04 Drawings UPRR-10081 Waste Sink PFD Rev. 0 88135.04 Miscellaneous E41-134 Annual Duct Survey (SFF Ventilation Ductwork), 2019 and conducted 2020 88135.04 Miscellaneous M35-037 SFF Checklist (conducted week of 09/05/2021) Rev. 63 88135.04 Miscellaneous M35-174 Inline Monitor Operational Checks (conducted Rev. 2 08/16/21 - 09/10/2021) 88135.04 Miscellaneous M35-175 Inline Monitor Supervisor's Parameter Setup 06/30/2021 Records (SFF Waste Inline #2) 88135.04 Miscellaneous M35-176 Inline Monitor/LLRWD Actuator Valve Interlock Test Rev. 1 25
Inspection Type Designation Description or Title Revision or Procedure Date
- Weekly (conducted weeks of 03/24/2021 -
09/06/2021) 88135.04 Miscellaneous SAR 15.19 Waste Handling, Vacuum System, and Ventilation Rev. 75 for SFF Operations 88135.04 Miscellaneous SAR 15.19 Appendix Rev. 25 88135.04 Operability OP-1001818 Operating Procedure for Room Monitor Operation Rev. 7 Evaluations 88135.04 Procedures MP-1881 SFF House Vacuum System High-Level Probe Test
- 6 Month 88135.04 Procedures OP-1001766 Operating Procedure for Usage and Maintenance Rev. 24 of Gloveboxes, Hoods, and Oxygen Monitoring Devices 88135.04 Procedures OP-1001832 Operating Procedure for SFF Low-Level Waste Rev. 21 System No. 2 88135.04 Procedures OP-1024990 Operating Procedure for Operation of the SFF Rev. 4 House Vacuum Pumps 88135.04 Work Orders 10266502 SFF Vacuum Trap High-Level Probe Test, 05/31/2018 completed 5/31/2018 88135.04 Work Orders 203077116 SC High Level Probe SFF Vacuum System - 6 08/30/2021 Month 88135.05 Corrective COM-92265 Update pre-fire plan to indicate location of Action aluminum powder storage Documents Resulting from Inspection 88135.05 Corrective COM-92266 Review SAR 15.23 for inclusion of aluminum Action powder storage area Documents Resulting from Inspection 88135.05 Corrective COM-92284 Aluminum storage aisles not maintained for ready Action accessibility Documents Resulting from 26
Inspection Type Designation Description or Title Revision or Procedure Date Inspection 88135.05 Fire Plans N/A Pre-Fire Plan, RTR Controlled Area - Map Section 01/17/2014 12 88135.05 Fire Plans N/A Pre-Fire Plan, RTR Office Mezzanine - Map Section 08/06/2014 11M 88135.05 Fire Plans N/A Pre-Fire Plan, RTR - Map Section 11 04/06/2020 88135.05 Miscellaneous FSR-03 Locations of Focus: Bays 13 through 16 Rev. 4 88135.05 Miscellaneous NFPA 10 Portable Fire Extinguishers 2018 Edition 88135.05 Miscellaneous NFPA 484 Standard for Combustible Metals 2015 Edition 88135.05 Miscellaneous SAR 15.22 RTRT (Research and Test Reactor and Targets) Rev. 102 Fuel Powder and Compact Processes 88135.05 Miscellaneous SAR 15.23 Fuel Plate and Element Fabrication Processes - Rev. 118 RTRT Operation 88135.17 Corrective 2019-1588 Re-Open CA to Address Potential Failure Mode for 09/29/2021 Action SFF Liquid Waste System Inline Monitor Documents Resulting from Inspection 88135.17 Engineering NCS-2021-092 NCS Safety Concern Analysis for Potential Failure 09/29/2021 Evaluations Mode for SFF Liquid Waste System Inline Monitor (CA201901588) 88135.17 Miscellaneous SAR 15.19 Waste Handling, Vacuum System, and Ventilation Rev. 75 for SFF Operations 88135.17 Miscellaneous SAR 15.19 Appendix Rev. 25 88135.17 Procedures PM10129 Backflow Preventer Inspection Report - Mechanical Rev. 2 88135.17 Work Orders 20266465 SFF Waste System to Process Water Backflow 08/16/2019 Preventer (CV-701) - Annual Test 88135.17 Work Orders 20279415 Safety Class - Power Loss Functional Test SV-707 03/02/2020
- Annual Test 88135.17 Work Orders 20286610 SFF Waste System to Process Water Backflow 08/19/2020 Preventer (CV-701) - Annual Test 88135.17 Work Orders 20298209 SFF Waste Column V-701 Vent Inspection - Annual 03/31/2021 Test 88135.17 Work Orders 20298210 SFF Waste Column V-702 Vent Inspection - Annual 03/31/2021 27
Inspection Type Designation Description or Title Revision or Procedure Date Test 88135.17 Work Orders 20298211 SFF Waste Columns V-703 and V-704 Vent 03/31/2021 Inspection - Annual Test 88135.17 Work Orders 20307348 SFF Waste System to Process Water Backflow 08/16/2021 Preventer (CV-701) - Annual Test 88135.19 Calibration E61-003 Inline Monitor High Voltage Plateau Determination 07/15/2021 Records (UR Inline No. 3), completed 88135.19 Calibration E61-003 Inline Monitor High Voltage Plateau Determination 07/23/2021 Records (UR Inline No. 2), completed 88135.19 Calibration E61-003 Inline Monitor High Voltage Plateau Determination 07/15/2021 Records (UR Inline No. 1), completed 88135.19 Calibration E61-004 Inline Monitor U-235 Peak Determination (UR Inline 07/18/2021 Records No. 3), completed 88135.19 Calibration E61-004 Inline Monitor U-235 Peak Determination (UR Inline 07/23/2021 Records No. 2), completed 88135.19 Calibration E61-004 Inline Monitor U-235 Peak Determination (UR Inline 07/21/2021 Records No. 1), completed 88135.19 Calibration E61-007 Inline Monitor Calibration Record (UR Inline No. 1), 07/21/2021 Records completed 88135.19 Calibration E61-007 Inline Monitor Calibration Record (UR Inline No. 2), 07/23/2021 Records completed 88135.19 Calibration E61-007 Inline Monitor Calibration Record (UR Inline No. 3), 07/19/2021 Records completed 88135.19 Calibration E61-107 Inline Monitor Supervisors Parameter Setup Record 07/19/2021 Records (UR Inline No. 3), completed 88135.19 Calibration E61-107 Inline Monitor Supervisors Parameter Setup Record 07/27/2021 Records (UR Inline No. 2), completed 88135.19 Calibration E61-107 Inline Monitor Supervisors Parameter Setup Record 07/21/2021 Records (UR Inline No. 1), completed 88135.19 Drawings UPRR-30147 Inline Monitors 1, 2, and 3 P&ID Rev. 3 88135.19 Engineering CHG-10675 Inline Replumb in Recovery approved Changes 06/28/2021 88135.19 Procedures OP-0061250 Operating Procedure for Calibration of Sodium Rev. 12 Iodine (NAI) Inline Monitors 28
Inspection Type Designation Description or Title Revision or Procedure Date 88135.19 Work Orders 20265906 UPRR Calibration Inline #2 07/29/2019 88135.19 Work Orders 20281270 UPRR Calibration Inline #1 04/01/2020 88135.19 Work Orders 20283295 UPRR Calibration Inline #2 07/30/2020 88135.19 Work Orders 20283296 UPRR Calibration Inline #3 07/13/2020 88135.19 Work Orders 20296270 UPRR Calibration Inline #1 04/19/2021 88135.19 Work Orders 20302151 Visual Sink Drain / Overflow Column 05/11/2021 Inspection/Test - 6 Month, completed 88135.19 Work Orders 20304098 UPRR Calibration of Inline Monitor No. 2 07/23/2021 88135.19 Work Orders 20304099 UPRR Calibration of Inline Monitor No. 3 07/19/2021 88135.19 Work Orders 20304986 Pre-fabricate and Install New Kynar for Inline(s) in 07/20/2021 UR 88135.19 Work Orders 20307596 UPRR Calibration of Inline Monitor No. 1 07/21/2021 88135.22 Corrective 2021-1080 Failure to properly conduct the shift inline monitor 08/02/2021 Action operation check (management measure), incident Documents 07/30/2021 Resulting from Inspection 88135.22 Corrective CA 2021-1311 SFF waste sink drain line (IROFS) clogged 09/29/2021 Action Documents Resulting from Inspection 88135.22 Drawings UPRR-10081 Waste Sink PFD Rev. 0 88135.22 Drawings UPRR-30147 Inline Monitors 1, 2, and 3 P&ID Rev. 3 88135.22 Miscellaneous E61-644 Shift Inline Monitor Operation Check, conducted 06/22, 07/22, 07/24, 07/27 of 2021 88135.22 Miscellaneous SAR 15.12 Liquid and Solid Waste Handling Processes in Rev. 84 Uranium Recovery 88135.22 Miscellaneous SAR 15.21 Low-Level Radioactive Waste Processes Waste Rev. 79 Operations 88135.22 Procedures E61-023 Daily Inline Monitor Operation Check Rev. 15 88135.22 Procedures E61-644 Shift Inline Monitor Operation Check Rev. 3 88135.22 Procedures OP-0061242 Operating Procedure for Inline Monitor System Rev. 36 88135.22 Work Orders 20259104 Check the Sink Drain 02/26/2019 29
Inspection Type Designation Description or Title Revision or Procedure Date 88135.22 Work Orders 20271332 Visual Sink Drain / Overflow Column 11/13/2019 Inspection/Test - 6 Month 88135.22 Work Orders 20281899 Visual Sink Drain / Overflow Column 05/07/2020 Inspection/Test - 6 Month 88135.22 Work Orders 20285893 Check for Blockage on SFF Sink 06/23/2020 88135.22 Work Orders 20291783 Visual Sink Drain / Overflow Column 11/11/2020 Inspection/Test - 6 Month 88135.22 Work Orders 20295655 TRISO Sink Draining Slowly 12/16/2020 88135.22 Work Orders 20311297 TRISO Unclog Sink Drain 09/14/2021 30