ML22297A250
| ML22297A250 | |
| Person / Time | |
|---|---|
| Site: | Erwin |
| Issue date: | 10/26/2022 |
| From: | Robert Williams NRC/RGN-II/DFFI |
| To: | Dailey R Nuclear Fuel Services |
| References | |
| IR 2022003 | |
| Download: ML22297A250 (21) | |
Text
Ronald Dailey President Nuclear Fuel Services, Inc.
P.O. Box 337 MS 123 Erwin, TN 37650-0337
SUBJECT:
NUCLEAR FUEL SERVICES - CORE INSPECTION REPORT 07000143/2022003
Dear Ronald Dailey:
On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nuclear Fuel Services. On October 12, 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 LISTSERV October 26, 2022 Signed by Williams, Robert on 10/26/22
SUNSI Review X
Non-Sensitive
Sensitive X
Publicly Available
Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME L. Harris J. Rivera-Ortiz C. Taylor L. Cooke R. Williams DATE 10/20/22 10/20/22 10/20/22 10/21/22 10/26/2022
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07000143 License Number:
SNM-124 Report Number:
07000143/2022003 Enterprise Identifier:
I-2022-003-0061 Licensee:
Nuclear Fuel Services, Inc.
Facility:
Nuclear Fuel Services Location:
Erwin, Tennessee Inspection Dates:
July 01, 2022 to September 30, 2022 Inspectors:
L. Harris, Senior Resident Inspector J. Rivera-Ortiz, Senior Fuel Facility Project Inspector C. Taylor, Senior Fuel Facility Project Inspector Approved By:
Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection
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SUMMARY
The U.S. NRC continued monitoring the licensees performance by conducting a NRC inspection at Nuclear Fuel Services, 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.
3 PLANT STATUS The following facility process areas were operating during the inspection period: 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, 70.62; 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 nuclear criticality safety and radiation 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:
Production Area LA: Accident Sequences 4.1.7.4.3, 4.1.7.4.2, 4.1.7.4.1, 4.1.2.4.2, 4.1.5.4.1, L-1, L-6, and L-20
BLEU Prep Facility (BPF) Four-Reactor System: Accident Sequences 50.001, 50.018, 50.004, and 50.018 Review of Safety Controls and Related Programs (IP Section 02.02)
For the accident sequences listed 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 select a sample of
4 IROFS (i.e., safety controls) for inspection. The specific IROFS selected for review are listed below:
Production Area LA: IROFS FAL-1, FAL-5, FAL-6, FAL-8, FAL-9, FAL-18, FAL-19, FAL-25, FAL-26, FAL-30, FAL-31, FAL-32, FAL-33, FAL-34, and FAL-55
BPF Four-Reactor System: IROFS BRC-23, BRC-24, BRC-26, BRC-27, BRC-28, and BRC-29 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:
reviewed nuclear criticality safety evaluations for Area LA, Accident Sequences 4.1.7.4.3, 4.1.7.4.2, 4.1.7.4.1, 4.1.2.4.2, and 4.1.5.4.1, and discussed assumptions and results with licensee staff
reviewed calculations of radiological consequences for Area LA, Accident Sequences L-1, L-6, and L-20, and discussed assumptions and results with licensee staff
reviewed calculations of radiological consequences for BPF Four-Reactor System, Accident Sequences 50.001, 50.018, 50.004, and 50.018, and discussed assumptions and results with licensee staff
interviewed operators on shift regarding the implementation of administrative IROFS FAL-1, FAL-8, FAL-9, FAL-33, and FAL-34 in Area LA
reviewed operating procedure SOP 401-41 to verify administrative IROFS FAL-1, FAL-25, FAL-26, FAL-8, and FAL-9 for Area LA were implemented consistent with the ISA Summary
reviewed operating procedure SOP 409 to verify administrative IROFS BRC-28 and BRC-29 for the BPF Four-Reactor System were implemented consistent with the ISA Summary
reviewed procedure WSF-008 to verify administrative IROFS FAL-5 was implemented consistent with the ISA Summary
reviewed material processing logs (a.k.a. running sheets) for ongoing operations in Area LA to verify implementation of IROFS FAL-1
reviewed safety related equipment (SRE) test procedures and the most recent SRE test results for IROFS BRC-023, BRC-024, BRC-026, BRC-027, BRC-028, and BRC-029
reviewed SRE test procedures and the most recent SRE test results for IROFS FAL-025, FAL-026, FAL-029, FAL-030, FAL-031, and FAL-032
reviewed setpoint analyses for active engineered IROFS BRC-023, BRC-024, BRC-026, BRC-027, BRC-028, BRC-029 and interviewed facility engineers on the calculations
reviewed setpoint analyses for active engineered IROFS FAL-025, FAL-026, FAL-029, FAL-030, FAL-031, FAL-032 and interviewed facility engineers on the calculations
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performed walk-downs of Area LA to verify the implementation of IROFS FAL-6, FAL-18, FAL-19, FAL-025, FAL-026, FAL-029, FAL-030, FAL-031, FAL-032, and FAL-55
performed walk-downs of BPF Four-Reactor System Area to verify the implementation of IROFS BRC-023, BRC-024, BRC-026, BRC-027, BRC-028, and BRC-029 Safety Control Support Programs (IP Section 02.04)
The inspectors assessed additional management measures that support the availability and reliability of the selected IROFS to verify these were implemented in accordance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors conducted the activities listed below. Documents reviewed are listed in the "Documents Reviewed" section of this inspection report.
reviewed training plan and a sample of qualification records for Area LA Operators
reviewed training plan and a sample of qualification records for BPF Four-Reactor System Operators
reviewed a sample of issues entered into the corrective action program to address degraded or failed IROFS
reviewed a sample of evaluations for IROFS issues requiring compensatory measures
interviewed licensing staff to identify organization changes, if any, that would be subject to the position-specific requirements in the license application
reviewed a sample of audits related to the facility's safety program
performed general walk-downs of the following production areas: LA, 200, 300, 400, 500, 600, 700, 800, and 900 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 insight into the status of facility activities, risk-inform the selection and implementation of the appropriate core IPs, 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:
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Corrective Action Review Board
Problem Identification, Resolution, and Correction System (PIRCS)
Record and Log Reviews (IP Section 03.03)
The inspectors reviewed selected records and logs to ensure they were developed, maintained, and reported, as required by applicable license and regulatory requirements. The records selected for review are listed in the "Documents Reviewed" section of this report.
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.
Procedures (IP Section 03.08)
The inspectors reviewed selected procedures to determine if the licensee was using and maintaining them in accordance with applicable license requirements. The procedures selected for review are listed in the "Documents Reviewed" section of this report.
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 contained the information required by Chapter 4, "Radiation Safety," of the license application; the Radiation Protection Manual; and implementing procedures:
SWP 22-34-024, associated with Work Request 304635
SWP22-21-019, associated with Work Request 292389-C Area 800 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/training evolution listed below to verify compliance with 10 CFR 73.46(b)(9).
Security FOF tactical response exercise conducted in August 2022.
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
7 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 safety controls/IROFS listed below associated with processing Area 200.
N302OVRFLOB202
N302COLUMNA201
N302XDRAINHA201
FA1-21 88135.05 - Resident Inspection Program Fire Protection (Annual/Quarterly)
The inspectors evaluated the operational status and material condition of selected fire protection 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 applicable.
Fire Area Walkdown (IP Section 03.01)
The inspectors walked down and evaluated the two fire areas listed below:
Building 310 and reviewed the following:
o fire safety tests N310XXDSPRINKLER, 310FRDAMP-001, 310 PULL STATIONS o
310 PRE-FIRE PLAN
Building 306 Vault Storage Areas and reviewed the following o
306 PRE-FIRE PLAN o
311 PRE-FIRE PLAN 88135.17 - Permanent Plant Modifications The inspectors evaluated implementation of the configuration management system for facility changes or modifications to ensure that 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 the installation of a new permanent end-of-process equipment setup for Area 800 Unit K to determine whether it was implemented in accordance with 10 CFR 70.72, Facility changes and change process. Specifically, the inspectors reviewed the following:
ECR-20213442 and associated work instructions for installation
Work Request 297498 and associated pre-job brief
Conducted a walkdown of the area after installation
8 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 installation of a new permanent end-of-process equipment setup for Area 800, Unit K, 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:
Procedure LOA 2366C-082, Area 800
SOP 401-08, Revision 32B, Area 800
IROFS list for Area 800, Revision 34 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 work instructions to confirm functional capability of selected IROFS and/or safety control(s) following maintenance.
Post-Maintenance Testing (IP Section 03.01)
The inspectors reviewed the four post-maintenance tests listed below by either observing the tests directly or reviewing test results.
N303XIGNTBSS672, Area 600
N302VALVEHV0B33, Area B
N302XXXLSH0544 and associated SWP22-34-024 and Work Request 30463S
N302XXXXLSH0545 and associated SWP22-34-024 and Work Request 30463S 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 verify compliance with license application Chapter 11, Management Measures, and the performance requirements of 10 CFR 70.61 and 70.62; and to verify the IROFS maintained their operational readiness consistent with the ISA Summary.
Surveillance and Calibration Testing (IP Section 03.01)
The inspectors reviewed the nine surveillance tests listed below by either observing the tests directly or reviewing test results.
N302XFILTERV201
N303VALVEA01
N303VALVEB01, Area B
N333XCOLUMN4A01, Downblend
N302VALVETW0A60, Area A
N302XFLAREX0601, Area 600
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N302XFLAREX0602 Area 600
N302N2INDFN068, Area 600
N302N2INDFN0630, Area 600 RADIOLOGICAL CONTROLS 86740 - Inspection of Transportation Activities The inspectors evaluated select aspects of the licensees transportation 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 the applicable regulations in 10 CFR Parts 20 and 71, and Department of Transportation (DOT) (49 CFR Parts 171-178) transport regulations.
Preparation of Packages for Shipment (IP Section 02.01)
The inspectors reviewed the licensees procedures and shipment records to verify compliance with the regulations above. Specifically, the inspectors reviewed the following:
NFS-ACC-033, Shipping Procedure for Nuclear Material, Rev. 46
NFS-HS-B-39, Radioactive Material Receipt and Shipping Survey, Rev. 29
FM-HS-B-39-05, Shipping Container Survey Report Liquid Rad (LR) 230 Shipment, Rev. 2
FM-WSR-010, Checklist for Returning Empty Shipping Containers, Rev. 5
Certificate of Compliance (COC) # 9291, USA/9291/B(U)F-96, Model No.: LR Transport Unit Package, Rev. 11
P30286, shipping documentation for contamination surveys and physical inspections of LR-230 content for shipments LR027, LR037, LR036, LR035, and LR032 Delivery of Completed Packages to Carriers (IP Section 02.02)
The inspectors reviewed the licensees procedures and shipment records to determine whether the licensee met package delivery requirements. Specifically, the inspectors reviewed the following:
NFS-WST-022, Waste Packaging Selection, Procurement and Inspection, Rev. 16
SOP 335-K, NNSS Certification and Shipping Documentation, Rev. 23
SOP 335-Q, WCS Certification and Shipping Documentation, Rev. 2
NFS-WSR-036, Handling and Packaging of the VERSA-PAC, Rev. 36
Shipping Manifest WIPP22002, Shipment of LSA-II Waste Materials
Shipping Manifest NFL20010, Shipment of LSA-1 and LSA-11 Waste Materials
Shipping Manifest FWF-22-0009, Shipment of Type A Package Various Waste Materials
10 Receipt of Packages (IP Section 02.03)
The inspectors reviewed the licensees procedures and records of incoming shipments to verify compliance with 10 CFR 20.1906 and applicable license requirements. Specifically, the inspectors reviewed the following:
NFS-WST-008, Guidelines for Receiving Radioactive Materials, Rev. 30
Straight Bill of Lading, TVA2021001
Straight Bill of Lading, TVA2021007
Straight Bill of Lading, TVA2021008 & NDA2022001
Straight Bill of Lading, TVA2020003
PO43-67464, Gamma Sealed Source Receipt Documentation
PO43-68596, Standards for Gamma Spectroscopy Receipt Documentation
PO43-67968, Plated Sources Receipt Documentation
PO43-68597, Cs-137 Standard Receipt Documentation Records and Reports (IP Section 02.04)
The inspectors reviewed the licensees records for recordkeeping and reports to verify compliance with the regulations above. Specifically, the inspectors reviewed the following:
Metal Solutions Design vendor evaluation dated 10/7/21, vendor services include manufacturer, test, repair and refurbishment DOT 7A Type A containers
MHF Packing vendor evaluation dated 10/20/21, vendor services include package servicing for 7A Type A 5, 10, 30, 55 and 85 -gallon carbon steel drums
Shipping Manifest WIPP22002, shipment of LSA-II waste materials and certification of compliance for NRC Type A packages
Shipping Manifest NFL20010, shipment of LSA-1 and LSA-11 waste materials and certification of compliance for NRC Type A packages
Shipping Manifest FWF-22-0009, shipment of Type A package various waste materials and certification of compliance for NRC Type A packages General License Requirements (IP Section 02.05)
The inspectors reviewed the licensee's transportation commitments in licensing documents utilized for shipment of radioactive material packages to verify compliance with 10 CFR 71, Subpart C. Specifically, the inspectors reviewed the following:
Certificate of Compliance (COC) # 9291, Rev. 11, USA/9291/B(U)F-96, Model No.: LR Transport Unit Package, Docket # 71-9291
Certificate of Compliance (COC) # 9315, Rev. 16, USA/9315/B(U)F-96, Model No.: ES-3100, Docket # 71-9315
Certificate of Compliance (COC) # 9342, Rev. 16, USA/9342/AF-96, Model No.: Versa-Pac, VP -55, Docket # 71-9342
Revised Quality Assurance (QA) Program for Shipping Packages for Radioactive Materials, Rev. 19, Attachment 56T-20-0100, dated August 13, 2020
Versa-PAC, Safety Analysis Report, Rev. 12
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ES-3100, Safety Evaluation Report, dated January 5, 2021
Model LR 230, Safety Evaluation Report, dated February 13, 2019 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 performed the following:
reviewed FM-WST-068, Statement of Authorization - Shipping Source Material
reviewed Docket 71-0249, Revised QA Program for Shipping Packages for Radioactive Materials, Section: NFS QA Policy and Authority, Rev. 19
reviewed the Transportation and Waste Management Organization Structure, dated 8/8/22
interviewed licensing staff to identify organization changes, if any, that would be subject to the position-specific requirements in the license application
observed the transportation "Plan of the Day" daily pre-job brief and status work activities on 8/30/22 and 8/31/22 with supervisors for transportation and waste management (TWM), specifically daily operations, shipping, technical services, and decommissioning operations Indoctrination and Training Program (IP Section 02.07)
The inspectors conducted interviews, reviewed training and indoctrination documentation, and observed activities for workers involved in transport activities to verify compliance with Chapter 11 of the licensee application. Specifically, the inspectors performed the following:
reviewed radioactive materials training records, specifically transportation training for employees 13095, 2697, and 5478
reviewed Carrier HazMat training materials for one of the licensee carrier contractor, Specialty Transport
observed non-destructive evaluation (NDE) assay of LSA-1 and LSA-11 waste materials prior to shipment Quality Assurance Program (IP Section 02.08)
The inspectors reviewed licensee documents to verify compliance with the licensees QA program. Specifically, the inspectors reviewed:
Revised QA Program for Shipping Packages for Radioactive Materials, Rev.
19, Attachment 56T-20-0100, dated August 13, 2020
NFS-GH-49, Implementing Procedure for the Transportation QA Program, Rev.9
NFS-Q-224, QA Shipping Vendor Qualification Procedure, Rev. 2
NFS-WST-026, Handling/Shipping Instructions for the ES-3100 Drum, Rev. 16
ES-3100 Package Shipping Manifests and Inspection Checklists for POs: 61450 dated 8/29/22, 61509 dated 10/19/22, and 30243 dated 6/21/22 Audit Program (IP Section 02.09)
12 The inspectors reviewed audit procedures and internal and external audits reports to verify compliance with 10 CFR 71.137. Specifically, the inspectors reviewed:
NFS-Q-178, QA Audit, Rev 10
NFS-M-48, QA Program for Shipping Packages for Radioactive Materials, Rev.18, Section 18 (Audits)
Implementing Procedure for the Transportation QA Program, Section 4.I7.1 (Audits)
Interviewed lead representative from the QA Department for oversight of transportation audits and assessments
Internal Transportation QA Audits:
o (QA-21-08) Annual Transportation QA Audit, dated 05/25/21; observations entered into the Corrective Action Program (CAP) o (QA-22-10) Annual Transportation QA Audit, dated 4/27/22, PIRCS entries 88006, 88026 and 88023/88027 o
T&WM Scales/Torque Wrenches (M&TE) Assessment, dated 3/18/21; observations were entered in the CAP
External Vendor Audits:
o NFS-Q-224, QA Shipping Vendor Qualification Procedure, Rev. 2 o
NFS Shipping Approved Vendor List dated 4/29/22, 56T-22-0067 o
(QA-20-04) American Mountain Technologies (AMT) Audit Report, dated 2/19/20 o
(QA-20-04) AMT audit findings closed by licensee in letter dated 11/16/20 Procurement and Selection of Packaging (IP Section 02.10)
The inspectors reviewed the licensees packaging and 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 reviewed the following:
NFS-GH-48, Procurement of Radioactive Shipping Containers, Rev. 10
NFS-WST-022, Waste Packaging Selection, Procurement and Inspection, Rev. 16
Metal Solutions Design vendor evaluation, dated 10/7/21, vendor services included manufacturer, test, repair and refurbishment DOT 7A Type A containers
MHF Packing vendor evaluation, dated 10/20/21, vendor services included package servicing for 7A Type A 5, 10, 30, 55 and 85-gallon carbon steel drums
Shipping manifest XC-9251-0001, WCS dated 8/21/20, SeaLand container
P29725, Straight Bill of Lading Department of Energy (DOE) dated 8/19/20, 55 gallon drums Preparation of Packages for Shipment (IP Section 02.11)
The inspectors reviewed the licensees documentation and records to verify compliance with applicable parts of the federal regulations above. Specifically, the inspectors reviewed:
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P30286, Shipping Bill of Lading dated 8/25/22 for compliance with COC 9291 requirements for loading and shipping the LR-230 package (LR-230 containers: LR027, LR037, LR036, LR035, LR032)
SOP 409-SEC 45, Rev. 18, Attachment C, Loading and Staging LR-230 containers
Shipping Container Survey Report LR 230 Shipment. dated 8/25/22 Periodic Maintenance of Packaging (IP Section 02.12)
The inspectors reviewed the licensees procedures and records to verify compliance with applicable parts of the federal regulations above. Specifically, the inspectors performed the following:
walked down warehouse where Miron VEGAS 2 germanium detectors are used for NDE assay of various geometries (drums, sea landers) to quantify radioactive materials present in containers prior to waste disposal transport
reviewed Miron VEGAS 2 calibration records performed on 4/20/22 for four VEGAS detectors:
o detector 1 SN# 11251 (fixed upper) o detector 2 SN# 11244 (fixed lower) o detector 3 SN# 11247 (mobile upper) o detector 4 SN# 11255 (mobile lower)
reviewed procedure, NFS-ACC-129, Energy and Resolution Verification Calibration, Rev. 1
interviewed nuclear measurement specialists and supervisor about VEGAS 2 calibration process and day-to-day instrument functional checks for the VEGAS 2 detectors Records, Reports, and Notifications (IP Section 02.13)
The inspectors reviewed the licensees records and procedures for recordkeeping and reports to verify that a system is in place to verify compliance with the federal regulations above. Additionally, the inspectors reviewed transportation issues captured in the corrective action program. Specifically, the inspectors reviewed the following:
NFS-OPS-001, Conduct of Operations, Rev.16
NFS-CAP-009, Corrective Action Program, Rev. 10
Closed PIRCS entries o
79428, Mismatch Packing List Seal Number o
79711, TWM Shipper Missing Label on Shipping Container (10293116) o 79702, Hole in Waste Sack (9752130) During Certification Inspection o
83405, Shipping Difficulty Flat Liner Failed Heat Seal 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.
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On October 12, 2022, the inspectors presented the core inspection results to Ronald Dailey and other members of the licensee staff.
On September 1, 2022, the inspectors presented the operational safety (IP 88020) and transportation activities (IP 86740) inspection results to Ronald Dailey and other members of the licensee staff.
15 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date Calibration Records Miron VEGAS 2 Germanium Detector Calibration 04/20/2022 PIRCS 79428 Mismatch Packing List Seal Number PIRCS 79702 Hole in Waste Sack (9752130) During Certification Inspection PIRCS 79711 TWM Shipper Missing Label on Shipping Container (102931116)
Corrective Action Documents PIRCS 83405 Shipping Difficulty Flat Liner Failed Heat Seal 6T 0100 Revised QA Program for Shipping Packages for Radioactive Materials 19 FM-WSR-010 Checklist for Returning Empty Shipping Containers 5
NFS-WST-008 Guidelines for Receiving Radioactive Materials 30 USA/9291/B(U)F-96, Model No.: LR Transport Unit Package; Docket #
71-9291 Certificate of Compliance, COC 9291 11 USA/9315/B(U)F-96, Model No.: ES-3100, Docket # 71-9315 Certificate of Compliance, COC 9315 16 Miscellaneous USA/9342/AF-96, Model No.: Versa-Pac, VP -55, Docket
- 71-9342 Certificate of Compliance, COC 9342 16 FM-HS-B-39 Shipping Container Survey Report for LR 230 Shipment 2
FM-WST-068 Implementing Procedure for the Transportation QA Program 9
NFS-ACC-033 Shipping Procedure for Nuclear Material, 46 NFS-ACC-129 Energy and Resolution Verification Calibration 1
NFS-CAP-009 Corrective Action Program 10 NFS-GH-48 Procurement of Radioactive Shipping Containers 10 NFS-HS-B-39 Radioactive Material Receipt and Shipping Survey 29 86740 Procedures NFS-OPS-001 Conduct of Operations 16
16 Inspection Procedure Type Designation Description or Title Revision or Date NFS-Q-178 QA Audit, 10 NFS-Q-224 QA Shipping Vendor Qualification 2
NFS-WST-022 Waste Packaging Selection, Procurement and Inspections 16 NFS-WST-026 Handling/Shipping Instructions for the ES-3100 Drum 16 P30286 LR 230 Shipping Container Survey Reports 08/15/2022 Radiation Surveys PO43-67464 Gamma Sealed Source Receipt Documentation Metal Solutions Design Vendor Evaluation 10/07/2021 MHF Packing Vendor Evaluation 10/20/2021 TWM Scales and Torque Wrenches (MT&E) Assessment 03/18/2021 QA-20-04 AMT Vendor Audit 02/19/2020 QA-21-08 Annual Transportation Quality Assurance Program Audit 05/25/2021 Self-Assessments QA-22-10 Annual Transportation Quality Assurance Program Audit 04/27/2022 FWF-22-0009 Shipping Manifest 06/29/2022 PO43-68596 Gamma spectroscopy Standards Receipt Documentation 30243 ES-3100 Package Shipping Manifest 06/21/2022 61450 ES-3100 Package Shipping Manifest 08/29/2022 61509 ES-3100 Package Shipping Manifest 10/19/2022
- NFL20010, Shipping Manifest 08/19/2020 P30286 LR-230 uranyl nitrate hexahydrate (UNH) containers:
LR027, LR037, LR036, LR035, LR032 08/25/2022 TVA2021001 Straight Bill of Lading, CAMECO 10/5/2021 TVA2021007 Straight Bill of Lading, CAMECO 05/03/2022 TVA2021008 &
NDA2022001 Straight Bill of Lading, CAMECO 06/21/2022 WIPP22002 Shipping Manifest 04/19/2022 Shipping Records XC-9251-0001 WCS Shipping Manifest 08/21/2020 21T-22-0127, HEA-21, MSU-22-030 BPF Four Reactor System - Radiological Accident Consequence Evaluation Rev. 0 21X-17-0038,NFE-17-0234, HEA-21, DTM-17-004 Production Fuel Facility - Radiological Consequence Evaluation Rev. 5 SA-00029 Setpoint Analysis for FAL-025, FAL-026, FAL-031, FAL-032 11/29/2016 88020 Calculations SA-00042 Setpoint Analysis for BRC-023, BRC-024 03/07/2022
17 Inspection Procedure Type Designation Description or Title Revision or Date SA-00044 Setpoint Analysis for BRC-026, BRC-027 02/16/2022 SA-00045 Setpoint Analysis for BRC-028, BRC-029 02/16/2022 SA-00210 Setpoint Analysis for FAL-029, FAL-030 12/13/2018 PIRCS 84801 Operations outside the bounds of the IROFS setpoint analysis 9/1/2021 PIRCS 88074 Safety Basis for Radiological Accident Evaluations 5/3/2022 PIRCS 88596 Operator sent solution to 302-COLUMN-0B04 6/21/2022 Corrective Action Documents PIRCS 89037 Degradation of IROFS FIRE-5, Piping Integrity 8/7/2022 Corrective Action Documents Resulting from Inspection PIRCS 89266 Labeling/Posting Incorrect 08/30/2022 304-F0251-D BPF Four Reactor System - Sht. 2 Rev. K 304-M4000-D Column Assembly Column-3J01, 3K01, 3L01, 3M01, BPF Four-Reactor System 8/21/2015 Drawings 304-M4001-D Column Details Column-3J01, 3K01, 3L01, 3M01, BPF Four-Reactor System 3/19/2007 21T-22-1513 4 Burner Technical Write-up 09/22/2022 54X-12-0010, NFE-12-0301, NCS-03-02, Nuclear Criticality Safety Evaluation for Area LA Rev. 4 FM-HS-A-79-01 Compensatory Measures Evaluation Form, IROFS FIRE-1, Zone 2 of Bldg 302 CO2 System 7/25/2022 Engineering Evaluations FM-HS-A-79-01 Compensatory Measures Evaluation Form, IROFS UBP-3, UBP-4, UBP-6, UBP-7 8/25/2021 Training and Qualification Records for two BPF Four Reactor System Operators Training and Qualification Records for two Area LA Operators 22T-22-2077 NFS Training Department Lesson Plan, BPF Four Reactor System 27X-14-0002 NFS Training Department Lesson Plan, Area LA Operator Training Miscellaneous 3Y-304-LA 3Y Re-qualification Checklist for 2 LA Operators 3/24/2020, 6/15/2022
18 Inspection Procedure Type Designation Description or Title Revision or Date ISA-SUM-BPF BLEU Preparation Facility Rev. 20 (Draft)
N304XXXXPSV3J01 IROFS 304-CONV 06/24/2022 ENG-EPS-A-003 Setpoint Verification and Design Parameter Calculations Rev. 14 N304XXXXPCV3M01 IROFS 304-CONV Rev. 5 N304XXXXPCV3M02 IROFS 304-CONV Rev. 5 N304XXXXPSV3M01 IROFS 304-CONV Rev. 3 NFS-HS-A-61 ISA Accident Consequences Evaluations Rev. 15 NFS-WST-008 Guidelines for Receiving Radioactive Materials Rev. 30 SOP 401-41 FMF Area LA Rev. 24 Procedures SOP-409 Section 42, 304 Processing System Rev. 18A 21T-21-0961 4th Quarter 2021 ISA Chemical Apparent Cause Evaluation (ACE) Audit 12/1/2021 21T-22-1090 2nd Quarter 2022 ISA IROFS Audit - Fuel Support Fire IROFS 5/31/2022 Self-Assessments 21T-22-1280 2nd Quarter 2022 ISA Audit for 100 NDA Laboratory Radiological ACE Rev. 1 88840 Desk Aid 89103 Maintenance Operations 89127 Equipment Piping 89320 Speaker System 89324 Area 900 89327 Safety Culture Corrective Action Documents 89338 Equipment Difficulty Corrective Action Documents Resulting from Inspection 88839 Tamper safe Device 88135.02 Procedures NFS-GH-903 Emergency Plan Rev. 028 Corrective Action Documents 89465 Fire Safety - Inspection 88135.05 Procedures NFS-GH-27 Impairments to Fire Protection Systems Rev.17
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