ML22122A196

Nuclear Fuel Services, Inc. - Core Inspection Report 07000143/2022001

ML22122A196
Person / Time
Site:	Erwin
Issue date:	05/03/2022
From:	Robert Williams NRC/RGN-II/DFFI
To:	Dailey R Nuclear Fuel Services
References
IR 2022001
Download: ML22122A196 (14)

Text

Mr. Ronald Dailey President Nuclear Fuel Services, Inc.

P.O. Box 337, MS 123 Erwin, TN 37650-0337

SUBJECT:

NUCLEAR FUEL SERVICES, INC. - CORE INSPECTION REPORT 07000143/2022001

Dear Mr. Dailey:

On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nuclear Fuel Services, Inc. On April 13, 2022, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

No violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) 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, in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07000143 License No. SNM-124

Enclosure:

As stated cc w/ encl: Distribution via LISTSERVMay 3, 2022 Signed by Williams, Robert on 05/03/22

ML22122A196 * = concurred by email Non-Sensitive Publicly Available SUNSI Review Sensitive Non-Publicly Available

OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME L. Harris* B. Adkins* M. Ruffin* J. Rivera-Ortiz* L. Cooke* R. Williams DATE 05/02/2022 04/29/2022 04/29/2022 04/29/2022 04/29/2022 05/03/2022

U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Number: 07000143

License Number: SNM-124

Report Number: 07000143/2022001

Licensee: Nuclear Fuel Services, Inc.

Facility: Nuclear Fuel Services, Inc.

Location: Erwin, Tennessee

Inspection Dates: January 01-March 31, 2022

Inspectors: B. Adkins, Sr. Fuel Facility Projects Inspector L. Harris, Senior Resident Inspector M. Ruffin, Project Engineer

Approved By: Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a core inspection at Nuclear Fuel Services, Inc., 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

No violations of more than minor significance were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 07000143/2022001-01 Application of Setpoint 88020 Open Methodology for Item Relied on for Safety WER 07000143/2022-001-00 Event Notification: 88135.02 Open Unplanned Chemical Reaction/Fire (EN 55712)

2 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-Oxide (U-Oxide), solvent extraction and the down-blending lines. Normal support services and departments were operational during the inspection period.

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

88020 - Operational Safety

The inspectors evaluated selected aspects of the licensees operational safety program to verify compliance with applicable portions of Title 10 of the Code of Federal Regulations, Part 70 (10 CFR 70), including 70.24, 70.61, 70.6; Chapter 11, Management Measures, of the facilitys license application; and applicable licensee procedures.

Identification of Safety Controls and Related Programs (IP Section 02.01)

The inspectors selected specific process areas for inspection based on the safety basis information of the facility, the risk/safety significance of the process areas, the description of recent plant changes submitted to the NRC, and past plant performance documentation.

For the process areas of interest, the inspectors selected a sample of analyzed accident sequences in fire safety and chemical safety based on the information provided in the integrated safety analysis (ISA) summary. The process areas and accident sequences selected for focused review are listed below. The inspectors also conducted a general tour of each major plant operating area.

BPF solvent extraction system Accident Sequences 10.055, 12.185, 12.186, 12.187, 12.188, 12.190, 12.204, and 15.155 (red oil explosion events)

BPF U-Oxide dissolver system Accident Sequences 1.245, 1.247, and 1.248 (nitrous oxide release events)

3 Review of Safety Controls and Related Programs (IP Section 02.02)

For the accident sequences selected in Section 02.01 above, the inspectors reviewed information related to administrative, engineered, and passive items relied on for safety (IROFS), including licensees assumptions and bounding cases as they apply to each of the selected accident sequences and IROFS. This review was performed to verify that selected IROFS were available and reliable to perform their intended safety functions and that the design basis assumptions were reflected in the actual conditions in the field. The specific IROFS (i.e., safety controls) selected for review are listed below:

BSX-12, -13, and -14 (active engineered controls for chemical/fire safety)

BSX-20, -23, and - 29 (passive engineered controls for chemical/fire safety)

BSX-25, -43, BUM-29, and BUM-40 (administrative controls for chemical/fire safety)

BPF-42, -43, and -50 (enhanced administrative controls for chemical safety)

Implementation of Safety Controls (IP Section 02.03)

For the selected IROFS listed in Section 02.02 above, the inspectors reviewed management measures to verify proper implementation in accordance with 10 CFR 70 and applicable sections of the license application. This review was performed to verify that IROFS were present, available, and reliable to perform their safety function and that design basis assumptions were reflected in the actual conditions in the field. The inspectors conducted the following activities to verify the implementation of the selected IROFS:

conducted a walkdown of the BPF solvent extraction area and BPF U-Oxide dissolver system, including firewall separating U-oxide operations from solvent extraction conducted a walkdown of IROFS BSX-20, BSX-23, BSX-29, BPF-42, BPF-43, and BPF-50 reviewed operations procedure SOP-409, Sections 1 and 8 reviewed Engineered Change Request (ECR) 20213292, Down-blending Process Engineering reviewed an engineering calculation associated with sizing of wet off gas lines for IROFS BSX-20, BSX-23, and BSX-19 (red oil event) reviewed engineering calculation regarding production of nitrous oxides (NOx) in the dissolver columns and the potential concentration of NOx release to determine whether the setpoint of process area detectors was consistent with calculation results interviewed operators and supervisors of the U-Oxide dissolver system conducted a detailed follow-up of problem identification, resolution, and corrective system (PIRCS) item 84837

Safety Control Support Programs (IP Section 02.04)

The inspectors assessed additional management measures that support the availability and reliability of the selected safety controls to verify these were implemented in accordance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors conducted the following:

4 reviewed test records for IROFS BSX-12, BSX-13, and BSX-14 reviewed corrective action management measures for PIRCS 84837 which involved the failure of IROFS BSX-12 reviewed the 3rd Quarter ISA IROFS Audit - Building 333 and 301 Fire IROFS reviewed training documents for one BPF solvent extraction operator performed a detailed review of setpoint calculation SA-00048, "Setpoint Analysis for BPX-12 and BSX-16" reviewed setpoint analysis SA-00291, "Setpoint Analysis for IROFS BUM-029, BUM-040, BUM-041" reviewed procedures governing the calibration of IROFS BPF-42 reviewed calibration records for IROFS BPF-43, BPF-50, and BPF-42

88135.02 - Plant Status

The inspectors routinely conducted walk-downs 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 insights 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 become aware of site activities so that inspection resources were appropriately focused on those activities with the higher safety significance. The inspectors selected the following meetings for review:

Safety and Safeguards Review Council Corrective Action Review Board

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.

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. The issues selected for review are listed in the "Documents Reviewed" section of this report as PIRCS.

5 Event Review (IP Section 03.06)

The inspectors reviewed the plant event listed below to determine if the event warranted the use of formal event review criteria. As applicable, the inspectors reviewed the event to determine whether the licensee reported the issue 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 20.22 (radiological and environmental events):

Event Notification55712, "Unplanned Chemical Reaction/Fire," reported on January 25, 2022, and follow-up written event report (WER) dated February 22, 2022 (ADAMS ML22066B008). See "Inspection Results" section of this report for additional details.

Radiation Work Permit (RWP) (IP Section 03.09)

The inspectors reviewed and observed the radiation work permits (RWPs)/safety work permits (SWPs) listed below to determine whether they contain the information required by Chapter 4, "Radiation Safety," of the license application; the Radiation Protection Manual; and implementing procedures:

SWP-22-02, Waste Process SWP-18101, 3023/4/5

88135.04 - Resident Inspection Program Operational Safety

The inspectors reviewed the material condition and as-found configuration of selected site structures, systems, and components (SSCs); reviewed corresponding documentation, and interviewed licensee personnel to verify compliance with 10 CFR Part 70 and the license application. The inspectors also verified whether the selected SSCs were available and reliable to adequately protect plant workers and the public during normal, off-normal, and accident conditions.

Operations Safety Walkdown (IP Section 03.01)

The inspectors evaluated the operational safety of systems and sub-systems associated with uninterrupted power supplies and associated generator systems. The inspectors performed the following:

reviewed operational testing and inspection of Generators 138, 480, and 365

88135.05 - Resident Inspection Program Fire Protection (Annual/Quarterly)

The inspectors evaluated the operational status and material condition of fire protection SSCs to verify compliance with the fire protection program as described in Chapter 7, Fire Safety, of the license application, and the applicable provisions of National Fire Protection Association (NFPA) 801, Standard for Fire Protection for Facilities Handling Radioactive Materials.

6 Fire Area Walkdown (IP Section 03.01)

The inspectors walked down and evaluated the fire areas listed below:

Area 303, status of carbon dioxide (CO2) system replacement.

Area 304, sprinkler alarm valves and associated testing

88135.17 - Permanent Plant Modifications

The inspectors evaluated the implementation of the configuration management system (CMS) for facility changes or modifications to ensure that IROFS and 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 changes associated with the CO2 fire suppression system to determine whether it was implemented in accordance with 10 CFR 70.72, Facility changes and change process. Specifically, the inspectors reviewed the following:

change control package elements including: ECR 20212286 and Work Request Form 290237, "Safety and Regulatory Review Routing Form" walkdown of changes to Building 303 CO2 fire suppression Zones 7 and 8 review of confirmation testing of remaining CO2 system test, N302XXCO2SYSTEM

88135.19 - Post Maintenance Testing

The inspectors evaluated post maintenance testing (PMT) activities to verify compliance with the license application, Chapter 11, Management Measures, and test procedures and/or work order instructions to confirm functional capability of the IROFS and/or safety controls following maintenance.

Post-Maintenance Testing (IP Section 03.01)

The inspectors reviewed the PMTs listed below by either direct observation of the tests or review of test results.

N303X600CMAXONS associated with Work Order 299008 N306XOVRFLOA802 N307XOVRFLOB802

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.

7 Surveillance and Calibration Testing (IP Section 03.01)

The inspectors reviewed the surveillance and/or calibration tests listed below by either direct observation of the tests or review of test results.

N303DOORSEAL653 N333VALVHV5A01A N333VALVHV5A01B N303VENDRAIN022 N303VENDRAIN040 N303VENDRAIN038

INSPECTION RESULTS

Unresolved Item Application of Setpoint Methodology for Item Relied on for 88020 (Open) Safety URI 07000143/2022001-01

Description:

During a review of engineering setpoint calculation SA-0048, the inspectors questioned the licensee about considering instrument loop uncertainty (i.e., opening/closing times) for multiple contactors used in the control circuit for IROFS BSX-12 (SRE-7). This IROFS is an active engineered control to prevent the possibility of a red oil explosion in the BPF solvent extraction process. Pressure transmitter PIT-2017 supports the function of IROFS BSX-12. Periodic testing of the instrumentation's response to an established setpoint serves as a management measure to ensure IROFS BSX-12 is available and reliable to perform its function when needed. Failure to properly account for the contactors' response time may adversely impact the current acceptance criteria used for testing of the IROFS function.

The inspectors requested additional information from the licensee to determine whether management measures for IROFS BSX-12 have been implemented in accordance with NRC regulations and the license requirements. Specifically, the inspectors requested information demonstrating that: (1) the setpoint calculation properly accounted for the "as found" drift tolerance in the IROFS calibration procedure as required by Section 4.2.7, "System Drift," of procedure ENG-EPS-A-003, "Setpoint Verification and Design Parameter Calculations," (2) the setpoint calculation properly applied the 20 percent margin specified in Section 4.2.8, "Setpoint Safety Margin Allowance," of the same procedure, and (3) the setpoint calculation and IROFS testing procedures properly incorporated vendor technical data for the subject circuit contactors.

The inspectors reviewed NFS's ISA summary and interviewed licensee staff to determine, with reasonable assurance, that sufficient safety controls were in place to meet the performance requirements of 10 CFR 71 despite the open questions about instrument loop uncertainty for IROFS BSX-12.

Planned Closure Actions: Once the requested information is available, the inspectors will review the information and have discussions with licensee staff to determine whether a violation of NRC requirements occurred.

8 Licensee Actions: The licensee entered this condition into the PIRCS for resolution and corrective action. The licensee also confirmed there are sufficient safety controls in place to meet the performance requirements of 10 CFR 70.61 for red oil events.

Corrective Action

References:

The licensee entered this issue into their corrective action program as PIRCS 87990.

WER Event Notification: Unplanned Chemical Reaction/Fire (EN 88135.02 (Open) 55712)

WER 07000143/2022-001-00

Description:

On January 25, 2022, a chemical reaction occurred in a 2-liter bottle of cleanup material during material inventory activities in a fuel processing area. The contents were observed smoldering, which then resulted in a small fire inside a process enclosure. The container was damaged in the fire, releasing its content to the enclosure. The NFS Fire Brigade responded and successfully extinguished the fire inside the enclosure upon identification. The licensee did not identify equipment damage outside of the process enclosure. Additionally, the licensee did not identify any personnel injuries, exposures, contamination, or releases to the environment exceeding regulatory limits. The licensee reported the event within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under the provisions of 10 CFR 70.50. The licensee entered this issue into their corrective action program as PIRCS 87147.

On January 25th, the NRC resident inspector responded to event to determine whether licensee's actions met NRC requirements and were consistent with plant procedures. The NRC's follow-up of this event is still in progress, pending licensee's completion and NRC review of the final cause evaluation report.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On March 24, 2022, the inspectors presented the operational safety (IP 88020) inspection results to Ronald Dailey and other members of the licensee staff.

On April 13, 2022, the inspectors presented the core inspection results to Ronald Dailey and other members of the licensee staff.

9 DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or Procedure Date 88020 Calculations BPF Chem ACE, Rev. 12 Appendix A Consequence Calculation NOx Release from Process Rev. 12 Table A-5.

Calibration Bldg 333 - 3E01 NOx Calibration of 333 HEU NOx Detectors 11/29/2021 Records Detector Calibration Bldg 333 - 3E01 NOx Calibration of 333 HEU NOx Detectors 02/25/2022 Detector Calibration Bldg 333 - 3X18 NOx Calibration of 333 HEU Column Dissolver NOx 11/24/2021 Detector Calibration Detectors Bldg 333 - 3X18 NOx Calibration of 333 HEU Column Dissolver NOx 02/24/2022 Detector Calibration Detectors PA-2072 (333-PDI-6G14) Calibration Data sheets 2020 & 2021 2020 & 2021 Corrective Action 84837 Selected PIRCS entry 09/09/2021 Documents 87384 Selected PIRCS entry 02/21/2022 Drawings 333-F0453-D BPF - First Pass Evaporator P&ID 05/20/2021 333-I7102-D Safety-Related Equipment (SRE) Loop for HEU 09/30/2014 NOx Detectors AE/AIT-3E01A, AE/AIT-3E01B, AE/AIT-3E01c N333XNOXDET3E01 333-I7108-B SRE Instrument Loop Diagram for Pressure Switch Rev. C High PSH-017 N333XXXXPSH2017 333-I7108-B SRE Instrument Loop Diagram for Pressure Switch Rev. C High PSH-2017 N333XXXXPSH2017 Engineering ECR-20213292 Downblending Process Engineering 09/10/2021 Changes Engineering Occupational/Environmental BLEU Prep Facility Rev. 12 Evaluations Chemical Accident Consequence Evaluation SA-00048 BSX-012, BSX-016 Evaporator Steam Pressure Rev. 5 Setpoint Analysis SA-00053 Setpoint Analysis for BSX-020, BSX-027 12/14/2021

10 Inspection Type Designation Description or Title Revision or Procedure Date SA-00291 [P005.1] Setpoint Analysis for BUM-029, BUM-040, BUM- 04/23/2013 041 Miscellaneous Square D NEMA Contactor, Type S, Nonreversing, Size 3, 90A, 50 HP at 575 VAC, 3 Phase, up to 100 kA, 3 pole, 120 VAC coil, open SRE Test History N333XXXXPSH2017 03/22/2022 Individual Qualifications for Employee Number 03/23/2022 16221 21T-22-0002 Blended Low-Enriched Uranium Preparation FacilityRev. 19 333-UOXIDE Control Flowdown and Field verification For Bldg 33 Rev. 09 U-Oxide Dissolution Non-Criticality IROFS Control Flowdown and Field ISA-CF-333-UGENER Rev. 6 Verification for Bldg 333 General IROFS and SRE Non-Criticality IROFS IROFS 333-UGENER IROFS and SRE - Bldg. 333 Rev. 53 IROFS-333-USVXTR SRE Test for N333XXXXPSH0017 09/09/2021 ISA Safety Basis Risk For Building 333 - BLEU Prep Facility, RA-333-Rev. 4 Assessment Support and UGENER Justification ISA-CF-301-Facility Control Flowdown and Field Verification for Bldg Rev. 12 301 General IROFS and SRE Non-Criticality IROFS N333XXXXPSH2OT7 IROFS 333-USVXTR 02/05/2020 N333XXXXTE2O18A IROFS-333USVXTR 02/11/2022 Process Hazards Analysis PHA-333-UOXIDE Rev. 1 Table BPF U-Oxide Dissolution Procedures ENG-EPS-A-0003 Setpoint Design Verification and Setpoint Design Rev. 14 Parameter Calculations ENG-EPS-A-003 Setpoint Verification and Design Parameter Rev. 06 Calculations IROFS 333-USVXTR IROFS and SRE - Building 333 Solvent Extraction Rev. 34 N333WOGVNT2O13A IROFS 333-USVXTR Rev. 3 N333XAIRGAP2IO8 IROFS 333-UGENER Rev. 1

11 Inspection Type Designation Description or Title Revision or Procedure Date NFS-CAP-009-01 Corrective Action Program (CAP) Screening Rev. 06 Process NFS-GH-21-01 Applicable fire System IROFS/SRE Rev. 08 NFS-GH-27 Impairments to Fire Protection Systems Rev. 16 NFS-GH-43-04 SRE Operational Testing Guide Rev. 0 NFS-HS-B-29-M-10 Use of the Industrial Scientific Ventis Pro 5 Multi Rev. 3 Gas Meter and DSX Docking Station NFS-HS-B-29-M-10-01 Calibration and Bump Test of the Ventis Pro Multi Rev. 0 Gas Meter NFS-M-17 Calibration System Manual Rev. 32 NFS-WM-008 Calibration of Electronics Equipment by Electronics Rev. 1 Maintenance SOP 409 Section 12 First Pass Solvent Extraction Rev. 39 SOP 409, Section 1 General Requirements for BLEU Preparation & Rev. 49 Associated Facilities SOP 409, Section 12, Minimum Level for Operating Column-2O11 During March 2022 Attachment L Extraction SOP 409, Section 8 U-Oxide Dissolution Rev. 74.A SOP Section 12, Observing for Solvent in Columns-2O14 & 2O24 Jan/Feb Attachment M 2022 88135.02 Corrective Action 87143, 87147, 87268, Selected PIRCS entries Various Documents 87293, 87295, 87425, 87430, 87435, 87443, 87473, 87518, 87583, 87589, 87594, 87595 Procedures NFS-CAP-10 Assigning and Performing Effectiveness Rev. 002 Evaluations NFS-Q-240 Suspect/Counterfeit Item Awareness Rev. 0 SOP 401-17 FMF Cleaning Rev. 010A WM-HTG-004 How-To Guide for Plant Coordination Rev. 002

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