ML22297A134
| ML22297A134 | |
| Person / Time | |
|---|---|
| Site: | BWX Technologies |
| Issue date: | 10/27/2022 |
| From: | Eric Michel NRC/RGN-II/DFFI/FFB2 |
| To: | Bittner J BWXT |
| References | |
| IR 2022003 | |
| Download: ML22297A134 (1) | |
Text
October 26, 2022 James J. Bittner Vice President and General Manager Nuclear Operations Group, Inc.
BWXT Nuclear Operations Group, Inc.
P.O. Box 785 Lynchburg, VA 24505-0785
SUBJECT:
BWXT NUCLEAR OPERATIONS GROUP, INC. - INTEGRATED INSPECTION REPORT 07000027/2022003
Dear James J. Bittner:
On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at BWXT Nuclear Operations Group, Inc. and 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, Signed by Michel, Eric on 10/26/22 Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 07000027 License No. SNM-42
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV
ML22297A134 x Non-Sensitive x Publicly Available x SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DRP RII/DFFI RII/DFFI RII/ORA NAME M. Doyle A. Alen P. Glenn T. Sippel K. McCurry DATE 10/25/2022 10/26/2022 10/25/2022 10/24/2022 10/24/2022 OFFICE RII/DFFI RII/DFFI RII/DFFI NAME P. Startz L. Pitts E. Michel DATE 10/24/2022 10/25/2022 10/26/2022 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07000027 License Number: SNM-42 Report Number: 07000027/2022003 Enterprise Identifier: I-2022-003-0057 Licensee: Nuclear Operations Group, Inc.
Facility: BWXT Nuclear Operations Group, Inc.
Location: Lynchburg, VA Inspection Dates: July 01, 2022 to September 30, 2022 Inspectors: A. Alen, Senior Project Engineer M. Doyle, Senior Resident Inspector P. Glenn, Fuel Facilities Inspector K. McCurry, Technical Assistant L. Pitts, Sr. Fuel Facility Projects Inspector T. Sippel, Sr. Fuel Facility Projects P. Startz, Fuel Facilities Inspector Approved By: Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at BWXT Nuclear Operations Group, 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 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, the uranium recovery (UR) facility, and 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, 70.50, 70.61, 70.62, appendix A; 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, chapter 5 of the license application, and applicable sections of the safety analysis report (SAR) including sections 15.20 (U-235 Counting Process in Nuclear Materials Control (NMC) Operations), 15.28 (Metallographic Laboratories), 15.30 (NMC Vaults, Storage Rooms, and Carts), and 15.33 (Vault 7 Operations). Specifically, the inspectors interviewed licensee staff and reviewed the following CSEs associated with those areas:
NCS-PA-30-00005, "Nuclear Criticality Safety Evaluation of Vault 2 (U),"
Revision (Rev.) 0, including review of credible and non-credible accident sequences; assumptions, calculations, and modeling; methodology and demonstration of double contingency; and supporting technical reference NCS-PA-30-00002, "Nuclear Criticality Safety Evaluation of the Shipping &
Receiving Container Operations," Rev. 3, with focus on Massachusetts Institute of Technology and Advanced Test Reactor fuel shipments to cross tie samples with transportation NCS-PA-33-00001, "Nuclear Criticality Safety Evaluation of Vault 7 (U)," Rev.
1, including review of credible and non-credible accident sequences; assumptions, calculations, and modeling; methodology and demonstration of double contingency; and the supporting process requirement document 3
various supporting NCS justification and safety analyses to add or modify new accident sequences, controls, and/or safety limits to the NCSEs and plant conditions as listed in the documents reviewed section Criticality Implementation (IP Section 02.02)
The inspectors selected engineered and administrative controls from the licensees SAR 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 11, "Management Measures." Specifically, the inspectors interviewed licensee staff and reviewed the following controls and their management measures associated with the CSEs listed above:
passive engineered geometry and reflection controls and administrative mass, moderation (both interspersed and interstitial), piece count, and spacing controls for the vault and vault carts in vault 2 passive engineered controls for neutron poison and geometry and administrative controls for material specification, interspersed moderation, and stacking during shipping and receiving container operations passive engineered geometry, spacing, and fixed neutron poison controls as well as administrative mass, moderation (both interspersed and interstitial),
and piece count controls performed by operators in vault 7 including various postings credited as management measures 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:
performed field walkdowns of operations associated with met lab (SAR 15.28),
NMC vaults, storage rooms, and carts (SAR 15.30), and vault 7 operations (SAR 15.33) interviewed NMC vault operators and the NMC first line supervisor concerning criticality hazards and control methods including administrative controls and monitoring for moderator intrusion in areas susceptible to moderator interviewed met lab area operators concerning criticality hazards and control methods including the use of administrative items relied on for safety (IROFS) and NCS postings during operations observed a licensee NCS staff member conduct a weekly inspection and quarterly NCS audit of the Lynchburg Technology Center (LTC) and LTC operations 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 of the license application. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:
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NCSE-02, "Nuclear Criticality Safety Analyses & Quality Assurance Reviews,"
Rev. 49, specifically the change to require management measures for an active engineered control to be tested as part of the nuclear safety release and sampled three Nuclear Safety Releases (NSRs) listed in the documents reviewed section NCSE-03, "Nuclear Criticality Safety Audits and Inspections," Rev. 30, and the associated change package CHG-00011795 dated 02/03/2022 NCS-07, "Qualification and Training Requirements for an NCS Engineer,"
Rev. 19, and the associated change packages CHG-00005918 dated 02/01/2019 and CHG-00011638 dated 12/22/2021 NCS qualification records for staff that in training currently including one staff member's NCS auditor training credentials NCS training and associated records for select NMC vault operators and met lab operators NCS audits, inspections, and observations summary for first and second quarter of 2022 as listed in the documents reviewed section NCS weekly inspection schedules as listed in the documents reviewed section safety review committee inspection and audit trends report dated 08/23/2022 Criticality Incident Response and Corrective Action (IP Section 02.05)
The inspectors reviewed the licensees corrective action program to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors reviewed the following corrective action documents to verify the events were not reportable, performance requirements were still met for the associated accident scenarios, and appropriate corrective actions (CAs) were taken:
CA 2022-0070 and supporting NCS safety concern NCS-2022-012 for recovery blend box mass log error (01/26/2022)
CA 2022-0079 and supporting NCS safety concern NCS-2022-011 for over pickle event (01/24/2022)
CA 2022-0140 and supporting NCS safety concern NCS-2022-019 for recovery scrubber high level probe freezing (02/14/2022)
CA 2022-0151 and supporting NCS safety concern NCS-2022-021 for inaccurate chem lab inline monitor calibration solution (02/24/2022)
CA 2022-0195 and supporting NCS safety concern NCS-2022-023 for pickle operations broken timer condition (02/23/2022)
CA 2022-0289 and supporting NCS safety concern NCS-2022-029 for special fuel facility (SFF) lab bench/sink drain clog (03/16/2022)
CA 2022-0640 and supporting NCS safety concern NCS-2022-042 for recovery phase separator overflow unapproved modification (06/07/2022)
CA 2022-0999 and supporting NCS safety concern NCS-2022-061 for water leak into vault 2 (08/18/2022)
CA 2022-1182 and supporting NCS safety concern NCS-2022-079 for increased concentration in area 'A' column (09/16/2022)
CA 2022-1197 and supporting NCS safety concern NCS-2022-078 for water leak into vault 2 (09/19/2022) 5
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.
including reviewing plant preparations for the remnants of Hurricane Ian 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.
Identification and Resolution of Problems (IP Section 03.05)
The inspectors reviewed the selected issues below 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.
CA 2022-1023, incident date July 25, 2022 CA 2022-1013, incident date August 1, 2022 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 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 2022-0894, contractors working in tank effected by fumes on July 6, 2022 6
Audits (IP Section 03.07)
The inspectors reviewed the internal and/or external audit listed below to determine whether they have been performed in accordance with 10 CFR 70.22(h)(1) and the license application:
Health Physics Audit - 2nd Quarter 2022 dated September 12, 2022 Radiation Work Permit (RWP) (IP Section 03.09)
The inspectors reviewed and observed the RWP listed below to verify whether the RWP contains the information required by Chapter 4, "Radiation Safety," of the license application, the radiation protection manual, and implementing procedures:
RWP 22-0048, "Recover A4 from Waste Container per Instructions Listed in the RWP Request," Rev. 00, conducted on September 20, 2022 Annual Security and Emergency Preparedness Drills/Exercises (IP Section 03.10)
The inspectors observed the licensees performance during the security force-on-force (FOF) tactical response exercise listed below to determine they were being implemented in accordance with 10 CFR 73.46(b)(9):
security FOF tactical response exercise conducted on the evening of August 24, 2022 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 70, the license, the SAR and/or 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.
Operations Safety Walkdown (IP Section 03.01)
The inspectors evaluated the operational safety of the systems and sub-systems of the listed processes associated with SAR 15.20, 235U Counting Process in Nuclear Materials Control Operations, Rev. 49.
container storage racks 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 7
National Fire Protection Association 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 bays 13, 14, 15, and 16 on July 28, 2022. SSCs reviewed included those listed below:
water-based fire suppression system fire barriers (fire doors, walls, and penetrations) fire detection portable fire extinguishers control of combustibles in all areas with a focus on ignition source controls for welding activities implementation of the licensee changes to ignition source permits The inspectors observed fire brigade, hazmat, and site evacuation training to the onsite first responders on Saturday, August 27, 2022 the inspectors followed the first responders offsite and drove the site evacuation route 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 control(s) following maintenance.
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.
observed testing of entry security gates after maintenance was performed 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 integrated safety analysis.
Surveillance and Calibration Testing (IP Section 03.01)
The inspectors reviewed the surveillance and/or calibration tests listed below. Tests were either observed directly or test results were reviewed.
maintenance plan (MP)-1716, "Monthly SC FLM HF SEC CONT LEAK DET,"
the monthly functional test of the HF detectors for the low-level and high-level 8
dissolvers in UR, performed under work order (WO) 20328820 conducted during the week of August 1, 2022 "SC COMP COL FILTER HOUSING 3M RECO" performed under WO 20329640 conducted on September 15, 2022 "SC FT COMP COL CK VALVES B 1M RECO" performed under WO 20331401 conducted on September 15, 2022 RADIOLOGICAL CONTROLS 86740 - Inspection of Transportation Activities The inspectors evaluated select aspects of the licensees transportation activities program to determine whether the licensee has established and is maintaining an effective management-controlled program to ensure radiological and nuclear safety in the receipt, packaging, delivery to a carrier, and as applicable, the private carriage of licensed radioactive materials and to determine whether transportation activities are in compliance with 10 CFR 20, "Standards for Protection Against Radiation," 10 CFR 70, "Domestic Licensing of Special Nuclear Material,"
and the U.S. Department of Transportation (DOT) 49 CFR Parts 171-178.
Preparation of Packages for Shipment (IP Section 02.01)
The inspectors examined samples of the licensees procedures, forms, shipping packages, and observed actual package preparations and shipping operations to verify compliance with licensee procedures. Specifically, the inspectors reviewed, verified, and observed the following preparations:
verified that samples of pre-shipment documentation including #ZBHF-VDM-1407 was prepared and routed in accordance with licensee procedure quality work instruction (QWI) 15.14, "Hazardous Material Shipping," Rev. 1 verified that samples of pre-shipment documentation included the radioactive material packing list, shipment/document #ZBHF-VDM-1407, bill of lading 1990, shipped 07/28/2022, regarding containers: 55G metal drums, fissile excepted, were completed in accordance with the above/linked licensee procedure verified that samples of pre-shipment documentation including #ZBHF-VDM-1407, BWXT carrier identification LSA/SCO shipment, shipment/document
- ZBHF-VDM-1407, certifications of shipper provided emergency procedures and shipping vehicle placards, this certification signed 07/28/2022, were completed in accordance with the above/linked licensee procedure conducted on-site evaluation of a shipping vehicle for exclusive use shipments via commercial company, Hittman transport trailer #W10295, tractor 3065, and verified that the tractor/trailer inspection list was completed 07/28/2022 in accordance with the above/linked licensee procedure verified that samples of pre-shipment documentation including the radiological "survey form" for waste shipments vehicle, procedure RP-09-002, Rev. 12, shipment/document #ZBHF-VDM-1407, was completed and surveyed as below limits on 07/28/2022 9
Delivery of Completed Packages to Carriers (IP Section 02.02)
The inspectors examined the licensees procedures and shipment records and observed actual transport operation/activities to determine that the licensee met package delivery requirements. Specifically, the inspectors reviewed or observed the following:
verified that a shipment did include a radioactive material packing list for DOE/shipment #ZBF-XSP-00100, bill of lading: 2004, container USA/9330/AF-36, shipped 09/20/2022 verified that a shipment did include the RMS-02 Attachment 34, "Vehicle Inspection Check List," for DOE/shipment #ZBF-XSP-00100, completed 09/20/2022 verified that a shipment did include form, "Hazardous Material Shipment Form," Rev. 5, DOE/shipment #ZBF-XSP-00100 verified that a shipping container certification/certificate of compliance (CoC) 9930 was included on form E4-676A, "ATR FFSC Fresh Fuel Shipping Container," Rev. 4, for DOE/shipment #ZBF-XSP-00100 verified that a shipment did include a shipping container that did have an associated package specification and inspection report for CoC 9330, ATR Package, Rev. 19/RMS-02 Attachment 38, completed 09/07/2022 Receipt of Packages (IP Section 02.03)
The inspectors examined the licensees procedures and records of incoming shipments to verify compliance with 10 CFR 20.1906 and applicable license requirements. Specifically, the inspectors conducted the following activities:
reviewed receipt of a radioactive material shipment (within ES-3100 packages) to verify compliance with E41-09, "Radioactive Material Receiving Procedure," Rev. 49 observed the unloading activities of multiple ES-3100 packages to verify compliance with procedure RMS-02, Attachment 26, "CUSIR for CoC 9315, ES-3100 Package," Rev. 26 verified that the individual who received the ES-3100 shipment was listed on the "Certified Authorized Recipients List for Radioactive Materials Shipments,"
expiration 04/08/2023, to support receipt requirements on E41-09, "Radioactive Material Receiving Procedure," Rev. 49 Records and Reports (IP Section 02.04)
The inspectors examined the licensees procedures and records for recordkeeping and reports to verify compliance with the regulations above. Specifically, the inspectors reviewed the following:
portions of NCS-PA-30-00002, "Nuclear Criticality Safety Evaluation of the Shipping & Receiving Container Operations," Rev. 3, dated 05/25/2022, to verify that package USA/9330/AF-36 were loaded in accordance with the NCS evaluation four sets of shipping documentation to verify compliance with licensee procedure E42-3, "Accounting Procedure," Rev. 28, in that the records were 10
being retained in accordance with 10 CFR 74.59(g), IAEA per 10 CFR 75.24, and waste disposal shipments per 10 CFR 20.2108(b) performed a follow up review of corrective action CA 2019-0926, rail car release prior to shipping documentation being completed, to evaluate the implementation of final corrective actions. The inspectors reviewed procedure OP-0168902, "Movement and Positioning of Railcars by BWXT Personnel,"
Rev. 12, and verified that corrective action statements were added to page 12 of OP-0168902 in compliance with CA 2019-0926 corrective action entries for compliance with chapter 11 of the license application: CAs 2021-0541, 2021-1490, 2021-1728, 2022-0534, 2022-0571, 2022-0577, 2022-0579, 2022-0588, and 2022-0594 General License Requirements (IP Section 02.05)
The inspectors reviewed the licensee's shipping package procedures and processes utilized for shipment of radioactive material packages to verify compliance with 10 CFR 71, subpart C. Specifically, the inspectors conducted the following activities:
physically inspected portions of two UNC-2600 shipping packages to verify compliance with the CoC #5086 dated 12/06/2019 reviewed QWI 15.1.4, "Hazardous Material Shipping," Rev. 10, that established a program for the preparation and distribution of shipping documentation to verify that the procedure fulfills the requirements of 49 CFR 172.101 and/or appendix to 49 CFR 172.101 reviewed NCS-PA-30-00002, "Nuclear Criticality Safety Evaluation of the Shipping & Receiving Container Operations," Rev. 3, dated 05/25/2022 to verify that packages USA/9330/AF-36 are utilized in accordance with the NCS evaluation Management Controls (IP Section 02.06)
The inspectors reviewed the system of management controls for transportation activities to verify compliance with licensee instructions and procedures. Specifically, the inspectors conducted the following activities:
verified that the individual who received the ES-3100 shipment on 9/21/2022 was included on the licensee's certified authorized recipients list for radioactive materials shipments dated expiration 04/08/2023, to support receipt requirements on E41-09, "Radioactive Material Receiving Procedure,"
Rev. 49 reviewed samples of procedure QWI 5.1.4 to verify that the licensee had established a program for the preparation and distribution of shipping documentation that fulfills the requirements of 49 CFR 172.101 and/or appendix to 49 CFR 172.101 Indoctrination and Training Program (IP Section 02.07)
The inspectors conducted interviews, observed shipping activities, and reviewed training records for a cross section of shipping/transportation personnel to determine if those 11
workers were in compliance with chapter 11 of the licensee application. Specifically, the inspectors:
accompanied shipping/transportation personnel and their management team during shipping activities, including preparation, package loading, truck driver documentation interactions, shipment receiving and truck unloading operations, shipping package inspections/repairs, and maintaining package certificate of compliance activities; the inspectors selected a cross section of shipping/transportation personnel and evaluated their training compliance via the licensee's electronic training management program to verify compliance with licensee procedure RMS-17, "Training," Rev. 14 Quality Assurance Program (IP Section 02.08)
The inspectors reviewed the licensee's quality assurance procedures and policies to verify compliance with the licensees quality assurance (QA) program. Specifically, the inspectors reviewed:
a sample of licensee procedure QAP-0088, "Quality Assurance Plan for Shipping Program," Rev. 26, dated July 2021 to verify that the QAP was in compliance of the requirements of 10 CFR 71, subpart H, excluding shipments exempt to 10 CFR 71.15 a sample of licensee procedure QWI 6.1.13, "Procurement of Materials, Components, and Services for Radioactive Material Shipping Containers,"
Rev. 7, to verify that shipping packages and repair items would maintain the CoC of the packages identified in this inspection Audit Program (IP Section 02.09)
The inspectors reviewed the latest licensee audits to verify compliance with 10 CFR 71.137. Specifically, the inspectors reviewed:
samples of the audit IA-2616B1-2021-10-01 summary report, 261-6B1 nuclear materials control (radioactive materials transportation and waste disposal),
dated October - November 2020, to verify that this annual audit of the shipping program was completed in accordance with procedure QWI 15.1.5, paragraph 7.0.15 samples of audit 258-3B radiation protection (transportation and waste disposal) and 261-6B1 nuclear materials control (radioactive materials transportation and waste control) dated October 2021 to verify that this audit of the radiological component of the licensee's shipping program was completed in accordance SNM-42, chapter 11, paragraph 11.5.1.5 for the quarterly audit of radiation protection Procurement and Selection of Packagings (IP Section 02.10)
The inspectors examined the licensee's packaging including those provided from a vendor and revised procedures and records to verify compliance with the federal regulations above. Specifically, for packaging that is used by the licensee to transport or to deliver licensed material to a carrier for transport, the inspectors conducted the following activities:
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physically inspected two Type-5086 packages to verify that the packages are currently being maintained in accordance with "Certification 5086," Rev.16, CoC for radioactive material package USA/5086/B(U)F, renewal, dated 09/18/2019, expires 12/31/2024 physically inspected the two above Type-5086 packages to verify compliance with safety evaluation report for the UNC-2600 package, CoC 5086, Rev. 15, includes 7.0 "Operating Procedures," and 8.0 "Acceptance Tests and Maintenance Program," dated March 2016 physically inspected samples of the two above Type-5086 packages to verify compliance with drawing B-2600-2, "UNC-2600 Upgraded Package," Rev. 3 Preparation of Packages for Shipment (IP Section 02.11)
The inspectors examined the licensees package markings, documentation, and records to verify compliance with applicable parts of the federal regulations above. Specifically, the inspectors reviewed:
the radioactive shipping actions associated with the shipment of an organic/radiological waste solution to Diversified Scientific Services Inc. for treatment, bill of lading 1997, manifest/DOE 741 document ZBFH-XSK-0045, shipped 08/23/2022, to verify compliance with licensee procedure QWI 15.1.5, "Shipment of Radioactive Materials," Rev. 12 the radioactive shipping actions associated with the shipment of material including disposal notification and certification form, declared as a D002 waste, bill of lading 1997, manifest/DOE 741 document ZBFH-XSK-0045, signed 08/23/2022, to verify compliance QWI 15.1.5 the radioactive shipping actions associated with a sample waste shipment check sheet (E4-345), manifest/DOE 741 document ZBFH-XSK-0045, signed 08/23/2022, to verify compliance QWI 15.1.5 Periodic Maintenance of Packagings (IP Section 02.12)
The inspectors examined the licensees procedures and records to verify compliance with applicable parts of the federal regulations above. Specifically, the inspectors reviewed the following:
procedure RMS-16, "Package Maintenance," Rev. 11, to verify that the licensee established a management program to maintain compliance with the package CoC maintenance requirements to verify the program in accordance with section 8 of the SAR for the applicable package table 1.2.1.1, "List of Implementing Procedures," of QAP-0088, "Quality Assurance Plan for Shipping Program," Rev. 26, dated July 2021 to verify the QAP specifies that inspection/maintenance/use activities conform to approved CoC referenced drawings/manuals used in the design, fabrication, procurement, analysis, and repair of shipping packages for which the licensee is the principle CoC holder 13
Records, Reports, and Notifications (IP Section 02.13)
The inspectors reviewed the licensees procedures for recordkeeping and reports to verify that a system is in place to verify compliance with the federal regulations above. Specifically, the inspectors reviewed the following:
adherence to procedure E42-3, "Accounting Procedure," Rev. 28, by evaluating shipping records of four packages to ensure the records were being retained in accordance with 3-year minimum (10 CFR 74.59(g)), IAEA (10 CFR 75.24), and waste disposal (10 CFR 20.2108(b))
samples of records for shipping packages associated with manifest/DOE 741 FCW-YVA-00355, to NIST, Center for Neutron Research, shipped 08/25/2022, to verify compliance with procedure E42-3 samples of records for shipping packages associated with manifest/DOE 741 ZBF-ZNK-00227, to University of Missouri, Nuclear Research Reactor, shipped 09/13/2022, to verify compliance with procedure E42-3 INSPECTION RESULTS No violations of more than minor significance were identified.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On October 20, 2022, the inspectors presented the integrated inspection results to Rich Freudenberger and other members of the licensee staff.
On September 22, 2022, the inspectors presented the Nuclear Criticality Safety (88015) and Transportation (86740) inspection results to D. L. Spangler and other members of the licensee staff.
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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88015 Corrective Action CA202201287 Corrective Action Document 09/22/2022 Documents Resulting from Inspection Engineering NCS-2022-009 NCS Safety Analysis to Modify Items Allowed on Standards 02/11/2022 Evaluations Rack for CHG-00010996 NCS-2022-009 NCS Safety Analysis to Modify Items Allowed on Standards 02/11/2022 Rack for CHG-00010996 NCS-2022-040 NCS Safety Concern related to excess moderating material 06/07/2022 NCS-2022-047 Nuclear Safety Release for NCS-2022-009 - Modification of 06/21/2022 Items Allowed on Standards Rack NCS-2022-048 Nuclear Safety Release for SER 22-012 Phase 1 - Install 08/05/2022 Temporary Fuel Racks in TRISO Area NCS-2022-055 NCS Justification Analysis for RWP 22-0042 - Transfer HFIR 07/26/2022 Packs from RTR Controlled Area to Bay 15 and Store Racks with Temporary NCS Posting NCS-2022-059 Nuclear Safety Release for RWP 22-0042 - Transfer HFIR 08/03/2022 Packs from RTR Controlled Area to Bay 15 and Store Racks with Temporary NCS Posting NCS-2022-074 NCS Safety Analysis Supporting a Temporary NCS Posting 09/07/2022 for the Met Lab Savage Saw per CHG-00012695 (U)
NCS-PR PR for Vault 7 Rev. 00A 00001 NCS-TR-00059 Nuclear Criticality Safety Calculations for Vault #2 Cart - Rev. 0 Outside of Vault NCS-TR-00071 Nuclear Criticality Safety Technical Reference for Waste Rev. 1 Collection Cylinders NCS-TR-00081 Nuclear Criticality Safety Technical Reference for </= 2.5- Rev. 00 Liter Containers - No U Metal Miscellaneous NCS Weekly Inspection Schedule for 1st Quarter 01/20/2022 NCS Weekly Inspection Schedule for 2nd Quarter 04/04/2022 NCS Weekly Inspection Schedule for 3rd Quarter 06/27/2022 15
Inspection Type Designation Description or Title Revision or Procedure Date NCS 1st Quarter Audit 02/28/2022 NCS 2nd Quarter Audit 06/06/2022 Met Lab Operator Training Records 09/21/2022 NMC Vault Operator Training Records 09/21/2022 NCS-2022-031 Audit, Inspection, and Observation Summary - 1st Quarter 04/19/2022 2022 NCS-2022-052 NCS Qualification Records 08/03/2022 NCS-2022-053 Audit, Inspection, and Observation Summary - 2nd Quarter 07/14/2022 2022 Posting 15 Vault 7 Rev. 01 010 Procedures NCSE-02 Nuclear Criticality Safety Analyses & Quality Assurance Rev. 49 Reviews NCSE-03-01 NCS Quarterly Audit Checklist Rev. 7 NCSE-03-03 NCS Inspection Form Rev. 5 88135.02 Corrective Action 2022-0894 Contractors working in tank effected by fumes 07/06/2022 Documents 2022-1128 Critique Meeting Minutes, Human errors associated with NMC Miscellaneous A5-268 Inclement Weather Checklist Rev. 0 Procedures OP-1000312 Operating Procedure for Tamper-Safing of SNM Stored On Rev. 28 Site Radiation Work 22-0048 Recover A4 From Waste Container per Instructions Listed in Rev. 00 Permits (RWPs) the RWP Request 88135.04 Corrective Action 2017-1219, 2018- Corrective Action Documents various Documents 0191, 2019-1039, 2020-1542, 2021-1645, 2022-0687 COM-66027, Corrective Action Documents various COM-93499, COM-68166, COM-68167, COM-68168, COM-96405 Drawings LT-3626-E 2 1/2-Liter Container Rack for Recovery Rev. 0 16
Inspection Type Designation Description or Title Revision or Procedure Date SK-LT-4454 Storage Container Rack Rev. 6 Engineering CHG-11983 Changes to SAR 15.20 and SAR Appendix 15.20 per Action approved Changes Item 08618 05/11/2022 CHG-2487 Update Procedure and Forms for Control of Standards approved 04/27/2017 CHG-4382 Design and Installation of a New Drum Counter approved 07/24/2019 CHG-5944 Change to SARs 15.07, 15.12, 15.13, 15.14, 15.20; approved Appendix 15.14, 15.17, per Action Item 03080 04/01/2019 CHG-6361 Design and Installation of New Drum Counter and Crane approved 09/06/2019 CHG-7826 Changes to SAR 15.20 and SAR 15.20 Appendix per SER approved 18-013 Phase 2 and CHG-7618 06/22/2020 CHG-8234 Drum Counter Final Design approved 04/28/2020 CHG-9779 Revision to E41-25 for New Drum Counter approved 02/02/2021 Engineering NCS-PA NCSE Poisoned <2.5-Liter Container Racks (4-Column Rev. 1 Evaluations 00001 Single Poison Plate, 4-Column Double Poison Plate, 2-Column Single Poison Plate) and <2.5-Liter Container Storage/Transport Carts Miscellaneous SAR 15.20 U-235 Counting Process in NMC Operations Rev. 49 SAR Appendix U-235 Counting Process in NMC Operations Rev. 23 15.20 Procedures E41-25 Operating Instructions for the Drum Counters Rev. 41 E46-80 Processing Containers in the Drum Count/SGS Area Rev. 49 OP-1027271 Operating Procedure - Low-Level Rad Waste Loaders Rev. 7 Training/Testing 88135.05 Fire Plans Section 12 Bays 14-16 04/06/2020 Procedures HS-03-03 Ignition Source Permits Rev. 23 88135.17 Drawings UPRR 10068 W.S.145 Piping & Instrumentation Drawing (P&ID) Rev. 4 Engineering CHG-00011471 WS0145 Sintering Furnace Exhaust Modifications Rev. 0 Changes SER 21-041 WS-145 TRISO Sintering Furnace Exhaust Modifications 02/16/2022 Phase 01 17
Inspection Type Designation Description or Title Revision or Procedure Date Engineering N-517 WS-145 TRISO Sintering Furnace Exhaust Modifications Various Evaluations Dates NCS-2022-016 NCS Justification Analysis for SER 21-041, Phase 1 for WS- 02/02/2022 145 TRISO Sintering Furnace Exhaust Modifications Miscellaneous SAR 15.18 SFF Dry-End Processing SFF Operation Rev. 141 SAR Appendix SFF Dry-End Processing SFF Operation Rev. 72 15.18 88135.22 Procedures MP 1716 Monthly SC FLM HF SEC CONT LEAK DET 18