ML23017A096
| ML23017A096 | |
| Person / Time | |
|---|---|
| Site: | Erwin |
| Issue date: | 01/23/2023 |
| From: | Robert Williams NRC/RGN-II/DFFI/FFB1 |
| To: | Dailey R Nuclear Fuel Services |
| References | |
| IR 2022004 | |
| Download: ML23017A096 (33) | |
Text
Ronald Dailey President Nuclear Fuel Services, Inc.
P.O Box 337 MS 123 Erwin, TN 37650-0037
SUBJECT:
NUCLEAR FUEL SERVICES - NRC INSPECTION REPORT 07000143/2022004 AND NOTICE OF VIOLATION
Dear Ronald Dailey:
On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nuclear Fuel Services. On October 27, 2022, November 10, 2022, and January 9, 2023, 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.
Based on the results of this inspection, the NRC has determined that one Severity Level IV violation of NRC requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's Web site at (http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html). The violation is cited in the enclosed Notice of Violation (see Notice in Enclosure 1) and the circumstances surrounding it are described in detail in the subject inspection report (Enclosure 2). The violation is being cited in the Notice consistent with Section 2.3.2 of the Enforcement Policy because it was considered self-revealing and not identified by the licensee.
The NRC has concluded that information regarding: (1) the reason for the violation(s); (2) the corrective actions that have been taken and the results achieved; and (3) the date when full compliance was achieved is already adequately addressed on the docket in the enclosed NRC inspection report (Enclosure 2). Therefore, you are not required to respond to this letter unless the description herein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure(s), and your response, if you choose to provide one, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC January 23, 2023
R. Dailey 2
Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the Public without redaction.
Sincerely, Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 07000143 License No. SNM-124
Enclosures:
- Notice of Violation - NRC Inspection Report 07000143/2022004 cc w/ encl: Distribution via LISTSERV Signed by Williams, Robert on 01/23/23
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available OFFICE RII/DFFI RII/OE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME L. Harris D. Edwards N. Peterka L. Pitts P. Startz J. Rivera R. Williams DATE 1/18/2023 1/18/2023 1/18/2023 1/18/2023 1/17/2023 1/17/2023 1/23/2023 NOTICE OF VIOLATION Nuclear Fuel Services, Inc.
Erwin, TN Docket No.: 07000143 License No.: SNM-124 During an NRC inspection completed on December 31, 2022, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
License Condition S-1 states, in part, that the license is for use in accordance with the statements, representations and conditions in the application. Chapter 11 of the license application, Section 11.4, Procedure Development and Implementation, states in part that Activities involving the handling of special nuclear material (SNM) and/or items relied on for safety (IROFS) are conducted in accordance with written procedures as defined in this section. Additionally, Section 11.4.1, Operating Procedures, of the license application states, in part, that Operating procedures are documents written to authorize the processing of radioactive material; and, within these documents detailed instructions for operation of equipment used in the process or activity, instructions for the disposition of radioactive wastes, and limits and controls established for safety purposes, including IROFS, are identified.
Standard Operating Procedure SOP-401-02-302, "Area 200," Revision 052E, Step 6.2.7, states in part that designated process operators shall "OBSERVE system for 2-5 minutes AFTER initiating processing" to ensure safe process operation.
Contrary to the above, on November 10, 2022, the licensee failed to handle SNM in accordance with written procedure SOP-401-02-302, Revision 052E, in Area 200.
Specifically, a designated operator failed to follow written instructions to observe the process start-up, which resulted in a missed opportunity to identify an incorrect system configuration that ultimately caused a spill of SNM and an unplanned contamination in a process area.
This is a Severity IV violation (Section 6.2.d.2 of the NRC Enforcement Policy)
The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved, is already adequately addressed on the docket in NRC Inspection Report No. 07000143/2022004. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation" and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region II; and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
If you choose to respond, your response will be made available electronically for public inspection in the NRC Public Document Room or in the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
2 Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.]
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days of receipt.
Dated this 23 day of January 2023 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07000143 License Number:
SNM-124 Report Number:
07000143/2022004 Enterprise Identifier:
I-2022-004-0061 Licensee:
Nuclear Fuel Services, Inc.
Facility:
Nuclear Fuel Services Location:
Erwin, Tennessee Inspection Dates:
October 01, 2022 to December 31, 2022 Inspectors:
D. Edwards, Enforcement Specialist L. Harris, Senior Resident Inspector N. Peterka, Fuel Facility Inspector L. Pitts, Sr. Fuel Facility Projects Inspector J. Rivera Ortiz, Sr. Fuel Facility Project Inspector P. Startz, Fuel Facilities Inspector Approved By:
Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection
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SUMMARY
The U.S. Nuclear Regulatory Commission (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 Failure to Follow Procedure Requirements for Area 200 Operations Significance Report Section Severity Level IV NOV 07000143/2022004-01 Closed 88135.02 The inspectors identified a self-revealing, Severity Level IV, cited violation of License Condition S-1 for the licensee's failure to follow a Standard Operating Procedure during operation of the Area 200 process.
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 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, Part 70 (10 CFR 70), including Sections 70.61, 70.62 and 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 and applicable sections of the license application, including 5.1.1 and 5.5.1. Specifically, the inspectors interviewed licensee staff and reviewed portions of the following NCSEs:
54X-21-0001, "Nuclear Criticality Safety Evaluation for the Tube Cleaning Room of the Production Fuel Facility," Revision (Rev.) 6, including the review of what-if analyses and calculations for selected credible accident sequences
54X-21-0002, "Control Flowdown and Field Verification for Tube Cleaning Room of the Production Fuel Facility," Rev. 6, which documented the licensee's verification of the items relied on for safety (IROFS) in the Tube Cleaning Room
54X-12-0002, "Nuclear Criticality Safety Evaluation for Area A of the Uranium Recovery Facility," Rev. 1, including a review of what-if analyses and selected credible accident sequences
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54T-14-0021, "Control Flowdown and Field Verification for Area A of the Uranium Recovery Revision 1 of NCSE Issued April 21, 2012", Rev. 2, which documented the licensee's verification of the IROFS for Area A
54X-07-0021, "Nuclear Criticality Safety Evaluation for the 300 Complex Process and 105 Laboratory Exhaust Ventilation Systems," Rev. 6, including the review of non-credible accident sequences and setpoint analyses
54X-08-0001, "Control Flowdown and Field Verification for the 300 Complex Process and 105 Laboratory Exhaust Ventilation System," Rev. 5, which documented the licensee's verification of the IROFS for the 300 Complex and 105 Laboratory
54X-16-0011, "Nuclear Criticality Safety Evaluation for Area D of the Uranium Recovery System," Rev. 5, including a review of the what-if analyses, double contingency controls, and calculations for selected credible accident sequences
54X-17-0007, "Control Flowdown and Field Verification for Area D Revision 5 of NCSE Issued November 2, 2016", Rev. 8, which documented the licensee's verification of the IROFS for Area D Criticality Implementation (IP Section 02.02)
The inspectors selected a sample of engineered and administrative controls from the licensees integrated safety analysis (ISA) Summary to verify proper implementation through a review of process and control specifications, plant walk-downs, and operator interviews, and to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.3.2, 5.3.7 and 11.2.3. Specifically, the inspectors interviewed licensee staff and performed the activities listed below:
reviewed various NCS Postings
conducted a walk-down of portions of the 300 Complex Process and Tube Cleaning Room to verify the presence of safety controls
conducted a walk-down of Areas A and D of the Uranium Recovery System
reviewed overflow line IROFS FAT-1, including safety-related equipment (SRE) test for N306OVERFLO1803, and set point analysis document SA-00369
reviewed transparent condensate drain IROFS FPV-4, including SRE tests for N306VENDRAIN012 and N306VENDRAIN008, and set point analysis document SA-00906 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 (SNM) to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors performed the following activities:
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reviewed reports of NCS audits conducted in 2022, and interviewed NCS engineers concerning the conduct of and training for NCS audits, and findings and observations identified during the audits
reviewed the most recent revision of licensee procedure NFS-HS-CL-10, "Nuclear Criticality Safety Fuel Manufacturing Facility (U)," Rev. 32
reviewed the most recent revision of licensee procedure NFS-HS-CL-10-08, "Nuclear Criticality Safety Buildings 306 and 307 - Area 800 and Tube Cleaning Room (U)," Rev. 34
reviewed NFS-A-07, "Procedure Listing for Control Lab Samples," Rev. 24
interviewed technicians assigned to the 105 Laboratory concerning criticality control methods and postings
reviewed the most recent revision of licensee procedure SOP 401-08, "Area 800 (U)," Rev. 32.C
reviewed the most recent revision of licensee procedure SOP 401-08A, "FMF, Area 800A Auxiliary System (U)," Rev. 38 and associated safety review records SAREV-20220087 and SAREV-202202228 Criticality Programmatic Oversight (IP Section 02.04)
The inspectors reviewed the licensees criticality accident alarm system (CAAS) and corrective action program entries to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.3.9. Specifically, the inspectors performed the following:
reviewed and discussed PSL-RP-19-002, Rev.0, "Criticality Accident Alarm System Analyses: Building 440," dated October 2019, with cognizant NCS personnel
reviewed NCS engineer qualification records
interviewed licensee staff and reviewed NCS engineer's qualification requirements for Senior NCS Engineer Criticality Incident Response and Corrective Action (IP Section 02.05)
The inspectors reviewed the licensees CAAS and corrective action program entries to verify compliance with 10 CFR 70 and applicable sections of the license application, including 5.3.9. Specifically, the inspectors performed the following:
reviewed a sample of recent NCS-related entries in the problem identification, resolution, and corrective system (PIRCS), and associated event investigations and corrective actions, including those identified by NCS engineers during audits
observed conduct of CAAS speaker audibility testing to verify compliance with licensee procedure NFS-HS-A-21, "Operation and Testing of the Criticality, Fire, and CO2 Alarm Systems", Rev. 39, on 11/08/2022
reviewed a sample of recent NCS-related entries in the PIRCS, and associated event investigations and corrective actions, including those identified by NCS engineers during audits
PIRCS reviewed: 41819, 90559, 90722, 90786, 90692, 88650, 88521, 33063, 31634
6 88055 - Fire Protection The inspectors evaluated selected aspects of the licensees fire protection program to determine whether the operational status, material condition, and design of fire protection systems met the applicable requirements of 10 CFR 70; Chapter 7, Fire Safety, of the facilitys license application; and applicable licensee procedures.
Selection of Inspection Samples (IP Section 02.01)
The inspectors reviewed licensing documents to select a sample of fire protection features in risk-significant areas/processes, including IROFS and their respective management measures (where applicable). The inspectors also selected licensee activities that support the implementation of the fire protection program based on the program description included in the license application. Specifically, the inspectors selected the following fire protection features and licensee activities for review:
fire prevention, detection, and mitigating features in Building 302
IROFS FIRE-1, FIRE-2, FIRE-5, FIRE6-1, FIRE-18 for process areas in Building 302
combustible controls in 300 Complex
general employee training and fire brigade training and qualifications
program implementing documents, particularly procedures, analyses, and testing records
fire program audits
compensatory measures for fire impairments
fire protection organizational changes Preventative Controls (IP Section 02.02)
The inspectors interviewed licensee staff, reviewed documentation, and conducted plant walk-downs to verify the licensees controls for combustibles, ignition sources, and inert atmospheres met the license requirements and applicable requirements in 10 CFR
- 70. Specifically, the inspectors conducted the inspection activities listed below:
conducted walk-downs of process areas in Building 302 to assess the control of transient combustibles and ignition sources
conducted a general walk-down of the process areas in the 300 Complex to assess the control of transient combustibles and ignition sources
reviewed records for recent monthly and weekly combustible controls inspections, including records for IROFS FIRE-2
reviewed procedure for monthly combustible control inspections
conducted walk-down and reviewed records of recent flammable cabinet storage inspections in the 300 Complex
reviewed procedure for hot work permits and a sample of hot work permits for recent activities in the 300 Building Complex
reviewed operating procedures for controlling inert atmospheres in furnace equipment in Building 302
7 Fire and Gas Detection and Alarm Systems (IP Section 02.03)
The inspectors reviewed selected fire and gas detection devices to verify that detection and alarm systems were able to detect the minimal fire within the required time and initiate the safety function credited in the license application, fire hazard analysis (FHA), or the ISA Summary. Specifically, the inspectors conducted the inspection activities listed below:
conducted walk-downs of process areas in Building 302 to assess the condition of smoke and heat detection devices in the area
reviewed procedures for routine testing of detection devices
reviewed records of recent tests performed on smoke and heat detection devices
reviewed calibration and SRE test records associated with IROFS FIRE6-1
reviewed records of recent vendor inspection of heat detectors for the CO2 system (IROFS FIRE-1)
Suppression Systems and Activities (IP Section 02.04)
The inspectors interviewed license staff, reviewed fire protection program documents, and conducted plant walk-downs to verify that suppression systems were capable of performing the safety function credited in the license application, FHAs, and the ISA Summary. Specifically, the inspectors performed the following activities:
reviewed procedures and a sample of recent inspections performed for the CO2 system in Building 302
conducted walk-downs of CO2 system (IROFS FIRE-1) in Building 302 to assess the condition of the system
conducted walk-downs of 300 Complex, with focus on Building 302, to assess the availability and condition of portable fire extinguishers
reviewed results of recent monthly fire extinguisher inspections
reviewed FHA and ISA Summary, and conducted walk-downs of Building 302 to assess whether fire suppression activities could affect safety controls in the process areas Passive Fire Protection Features (IP Section 02.05)
The inspectors reviewed selected passive fire protection features to verify that these were in a proper material condition to perform the safety function credited in the license application, FHAs, and the ISA Summary. Specifically, the inspectors performed the following activities:
conducted walk-downs of the 300 Complex, with focus on Building 302, to assess material condition of fire doors, firewalls, fire penetration seals, oil collection trays, and manual pull stations o
rolling/sliding doors: D333, D336, D005 o
electromagnetic door holders: D337, D338, D339, and D334 o
swinging doors: D006, D339, D338, D334 o
fire barriers: W042, W049, W051, W052
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reviewed records of recent routine inspections conducted for manual pull stations, electromagnetic door holders, swinging fire doors, and fire barriers in Building 302
reviewed testing records for IROFS FIRE-18, associated with Dampers 002, 003, and 004 in Building 302
reviewed inspection records for IROFS FIRE-5 associated with piping integrity in Building 302 Fire Protection Program Elements (IP Section 02.06)
The inspectors reviewed selected fire protection program elements to verify compliance with the license requirements. Specifically, the inspectors completed the following activities:
reviewed an example of compensatory measures put in place for problems with the actuation of the CO2 system in Building 302, Zone 2
interviewed fire protection engineer to discuss the status of fire impairments in Building 302
interviewed the NFS Fire Chief and Assistant Fire Chief, reviewed program documents, reviewed training records for select fire brigade members and walked down site fire brigade equipment to verify fire brigade training and drills met the license requirements
interviewed the NFS Fire Chief, reviewed program documents, and walked down site emergency communications systems to verify these communications systems met the license requirements
interviewed licensee management to verify changes to the fire protection organization, if any, met the license requirements
reviewed training plan for general fire safety training provided to employees
conducted walk-downs of Building 302 and peripheral buildings to assess the condition of emergency lights
reviewed records of recent emergency lights testing
reviewed latest version of the Pre-Fire Plan for Building 302 to verify consistency with the applicable FHA Identification and Resolution of Problems (IP Section 02.07)
The inspectors reviewed the licensees identification and resolution of fire protection issues to verify compliance with the license requirements. Specifically, the inspectors reviewed the following corrective action program entries, audits, and self-assessments:
PIRCS 84489, Transient Combustibles in 304 Breezeway, 8/6/2021
PIRCS 87718, Storage of PVC Adhesive in Cabinet, 3/29/22
PIRCS 90723, Cover not in Place/Unguarded Opening in Enclosure, 10/25/2022
PIRCS 90739, Combustible Liquids Not Stored in Flammable Storage Cabinet, 10/26/2022
PIRCS 90742, Wheeled Fire Extinguisher in Building 306, 10/26/2022
most recent triennial independent assessment of the fire protection program
9 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 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:
Corrective Action Review Board
PIRCS Meetings
Plan of the Day Meetings 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 inspection 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 inspection report as PIRCS.
Event Review (IP Section 03.06)
The inspectors reviewed the plant events listed below to determine if the event warranted the use of formal event review criteria. As applicable, the inspectors reviewed the event to determine whether the licensee reported the issue in accordance with 10 CFR Sections 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). The inspectors also reviewed the licensees response, safety consequences, and corrective actions for the listed events.
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PIRCS report number 90879, dated November 11, 2022, regarding SNM spill in process area due to an operator's failure to observe a processing step during start-up (See "Inspection Results" section of this inspection report for additional details)
Event Notification 56149, dated October 6, 2022, regarding failure/degradation of safety controls in the process ventilation system (See NRC Special Inspection Report 07000143/2022006 for additional details, available in ADAMS via Accession Number ML22332A498)
Audits (IP Section 03.07)
The inspectors reviewed the internal and/or external audits listed below to determine whether they have been performed in accordance with 10 CFR 70.22(h)(1), if applicable, and the license application.
Third Quarter "As Low as Reasonable Achievable" (ALARA) Report
Third Quarter Industrial Safety Report
Quarterly NCS Audits and Inspections
Quarterly ISA Audits and Inspections 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 inspection 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-18317 300 CMPLX
SWP-18284 303 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 safety controls/IROFS listed below associated with processing Areas 600 of 302/303 and PSL.
11 Area 600
FA6-001
FA6-004
FA6-005
FA6-024
FA7-24
FIRE6-1
SRE Test: N302X600CMAXONS
SRE Test: N302VALVEFVA601 Area 600 PSL
FA6-023
FA6C-2
FA6C-9
FA6C-12
FA7C-23
FIRE6C-001
SRE Test: N303X600CMAXONS
SRE Test: N303DOORSEAL652 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 fire area listed below:
Building 306 East, connecting 304 breezeway and reviewed the following:
o FHA for Building 306E o
Daily Atmospheric Tests of Safety Valves o
Annual Fire/Smoke Wall Barrier Inspection Buildings 304 and 306 o
Annual Duct Detector Test Building 306 o
Monthly Combustible Control Inspections Buildings 306 and 304 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.
12 Post-Maintenance Testing (IP Section 03.01)
The inspectors directly observed the post-maintenance test listed below and reviewed records of tests results.
N333NOXDET3X18 and associated Work Order 305522, Building 333 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 directly observed the two surveillance and/or calibration tests listed below.
N302XDRAINHB201, Area 200
N302XAIGAP011, Recovery Area FACILITY SUPPORT 88050 - Emergency Preparedness The inspectors evaluated selected aspects of the licensees emergency preparedness program to determine whether the program is maintained as required by the Emergency Plan, the license and license application, and NRC requirements in 10 CFR Part 70.
Emergency Preparedness Program Review and Implementation (IP Section 02.01)
The inspectors selected the following elements that support the implementation of the licensees emergency preparedness program to verify compliance with 10 CFR 70.22(i)(3),
Chapters 8 and 11 of the license application, and the facility's Emergency Plan. Specifically, the inspectors conducted the following inspection activities:
reviewed emergency preparedness program changes and associated supporting documents, as appropriate, that occurred since the last inspection that could decrease the overall effectiveness of the program
reviewed revisions to Emergency Plan Implementing Procedures (EPIPs)
reviewed the site's source term documents and calculations to verify that they were being completed as required and if necessary, changes to existing accident sequences were adequately evaluated
reviewed the training records for nine of the emergency response team members and interviewed training staff regarding the process for verifying completion of required training
reviewed the site's agreements with off-site agencies and response organizations to verify that NFS was maintaining these agreements as required by the Emergency Plan
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reviewed the training provided to off-site agencies and response organizations to verify that NFS was providing the training required by their mutual aid agreements
interviewed selected off-site agency staff to verify the training provided by the licensee was meeting the needs of the off-site responders
reviewed the 2021 Annual Criticality Drills and Limited Scope Drill Critique and the associated corrective action program entries
reviewed the Emergency Preparedness drills and exercises conducted in 2021 and 2022 and the critiques conducted for those drill and exercises
conducted a walk-down of emergency response equipment staged throughout the protected area
interviewed the NFS Fire Chief and the Emergency Preparedness Program Manager regarding staging and maintaining emergency response equipment
reviewed completed records of emergency response equipment and facility checks
reviewed the 2020 and 2021 Emergency Preparedness Program audits performed to meet the requirements of Chapter 11 of the license application
interviewed the NFS Fire Chief and the Emergency Preparedness Program Manager regarding the Emergency Response Team commitments in Section 7.6.8 of the license application Identification and Resolution of Problems (IP Section 02.02)
The inspectors reviewed the licensees identification and resolution of emergency preparedness issues to verify compliance with the license requirements. Specifically, the inspectors reviewed the following corrective action program entries and audits:
Emergency Preparedness Program - Quality Assurance Audit (QA-20-17) o PIRCS 81247, Industrial Safety Document Reviews o
PIRCS 38176, Industrial Safety Document Reviews Effectiveness Review
Emergency Preparedness Program - Quality Assurance Audit (QA-21-20) o PIRCS 30964, Improvements to Process for Determining Fully Qualified Fire Brigade Members Event Review (IP Section 02.03)
The inspectors reviewed the licensees safety-significant and internal events related to emergency preparedness to verify compliance with 10 CFR 70.22(i)(3), Chapter 8 of the license application, and the Emergency Plan. Specifically, the inspectors performed the following activities:
reviewed the following PIRCS entries for Fire Brigade Responses:
o 87021, 87147, 87943, 88297, 88466, 88510, 88516, 88537, 88698, 88804, 88936, 88958, 88981, 88987, 88994, 89031, 89257, 90513, and 90638
14 88070 - Permanent Plant Modifications The inspectors conducted a review to verify the licensee had established and implemented a configuration management system to evaluate, implement, and track changes to the facility in accordance with the applicable requirements in 10 CFR 70.72 and Chapter 11 of the license application, Management Measures/Configuration Management. The inspectors also verified the licensee had established management measures for changes to the facility in accordance with 10 CFR 70, Subpart H, and the license application, and that modifications involving potential new processes, if any, would be evaluated for compliance with the requirements in 10 CFR 70.64, as applicable.
Sample Selection (IP Section 02.01)
The inspectors reviewed samples of change request documents, plant modifications, changes the licensee determined did not require NRC pre-approval under 10 CFR 70.72, and other changes that could have affected the ISA Summary, to verify the licensee conducted evaluations in accordance to their established configuration/change management program. The inspectors selected the following plant modifications and change requests for review:
Engineering Change Request (ECR) 20221190, N302VENDRAIN001/002/003
ECR 20221191, General 300 Complex Process Ventilation, IROFS/SRE approved on 10/14/2022
ECR 20220769, (LOA-2354B-001),T6 Developmental Production Run
ECR 20220770, (LOA-2354B-002),T6 Developmental Production Run
ECR 20221015, (LOA-2354B-004),T6 Developmental Production Run
ECR 20213442, Permanent Unloader for Final Train Process Facility Change/Modification Process (IP Section 02.02)
The inspectors reviewed the selected modifications listed in Section 02.01 above to verify the licensee established a configuration management system in accordance with 10 CFR 70.72 and the license conditions. Specifically, the inspectors conducted the activities listed below:
reviewed the following procedures to verify the configuration management system was documented in written procedures and that the procedures addressed the aspects described in 10 CFR 70.72(a) o NFS-TS-009, "Technical Review Program," Rev. 10 o
NFS-GH-901, "Configuration Management program," Rev. 23 o
NFS-CM-004, "NFS Change Control Process," Rev. 23 o
NFS-ENG-02, "Engineering Drawings" / Section 4.8 "As-Built," Rev.
15A o
NFS-ENG-001, "Engineering Project Design Control," Rev. 16 o
ENG-EPS-A-003, "Setpoint Verification and Design Parameter Calculations," Rev. 14 o
NFS-ENG-010, "Acceptance Testing Program," Rev. 6 o
NFS-HS-A-67, "Documenting the Safety and Regulatory Review of Facility Changes," Rev. 16 o
NFS-HS-A-68, "ISA Risk Assessment Procedure," Rev. 10
15 o
NFS-EPS-A-003, "Setpoint Verification and Design Parameter Calculations," Rev. 14 o
NFS-GH-43, "Safety-Related Equipment Control Program," Rev. 33 o
NFS-OPS-001, "Conduct of Operations," Rev. 17 o
NFS-WM-001-4, "NFS Work Acceptance & Closure Process," Rev. 4B
reviewed configuration management packages, interviewed licensee staff, and performed walk-downs of the following ECR's to verify the licensees evaluation of changes provided a valid technical bases to determine whether an amendment to the license was required based on the criteria in 10 CFR 70.72(c) o ECR 20213442, Permanent Unloader for Final Train Process o
ECR 20221190, N302VENDRAIN001/002/003, Process Ventilation Drains o
ECR 20221191, General 300 Complex Process Ventilation, IROFS/SRE List
reviewed samples of facility documentation associated with ECR 20221191, General 300 Complex Process Ventilation, to verify the affected documents were updated promptly in accordance with 10 CFR 70.72(e) and the timeframe outlined in the license condition/licensee procedures
reviewed samples of the licensee's 2021 configuration management system records to verify the licensee submitted a summary with facility changes and revised ISA Summary pages to the NRC in accordance with 10 CFR 70.72(d)
Management Measures (IP Section 02.03)
For the selected modifications, the inspectors reviewed a sample of the management measures established for affected IROFS to verify that management measures continued to ensure that IROFS remained available and reliable to perform their intended function as required by 10 CFR 70.61 and the license application. Specifically, the inspectors conducted the inspection activities listed below:
reviewed ECR-20221190-03 revision process involving the updating of drawing 302-F0099-D, "FMF Process Ventilation P&ID North Branch," to verify compliance with change management procedures
interviewed licensee staff and reviewed samples of affected procedures to verify the licensee followed the procedure control process in accordance with the license application
reviewed samples of post-modification testing procedures, post-modification reviews, revised documentation, and functional tests for the following safety systems to verify compliance with licensee procedures (i.e., NFS-HS-A-67 and ENG-EPS-A-003) and Chapter 11 of the license application:
o Revised Glovebox Drains/Physical Changes
ECR 20221190, N302VENDRAIN001/002/003, Process Ventilation Drains
ECR 20221191, General 300 Complex Ventilation
ECR 20221191, Document SA-00156, "Setpoint Analysis for FPV-7 and FPV-8," which included IROFS FPV-7/8 and SRE 302VENDRAIN(1A/1B/2A/2B/3A/3B)
15 o
Revised Glovebox Drains/Performance Evaluations After Modifications
Form NFS-ENG-005, "Construction Acceptance Testing,"
associated with ECR-20221190-001, "Installation of SRE Drains" (dated 10/14/2022)
Form FM-HS-B-44-01, "Process Enclosure Face Air Velocity Report", associated with the testing of 12 enclosures (dated 10/22/2022)
reviewed samples of maintenance and surveillance records associated with ECR 20221190, before and after the modifications, to verify the licensee established periodic maintenance and surveillance testing in accordance with the license application o
N302VENDRAIN001, Rev. 7, procedure "IROFS 300-UPVENT," drain testing and verification procedure form, Process Off-Gas (POG) Line Testing and Verification Procedure form, Assessment of SRE Test, testing completed on 4/30/22 o
N302VENDRAIN002, Rev. 6, procedure "IROFS 300-UPVENT," drain testing and verification procedure form, visual POG Line Testing and Verification Procedure form, Assessment of SRE Test, testing completed on 4/30/22 o
N302VENDRAIN003, Rev. 6, procedure "IROFS 300-UPVENT," drain testing and verification procedure form, POG Line Testing and Verification Procedure form, Assessment of SRE Test, testing completed on 10/02/21 o
N302VENDRAIN01A/1B/2A, Rev. 0, procedure "IROFS 300-UPVENT," drain testing and verification procedure, testing completed on 10/21/22
reviewed samples of training and qualification records, as of 11/09/2022, of personnel who performed safety reviews on ECR 20221190 and ECR 20221191, to verify that personnel were up-to-date on the applicable training and qualification requirements and were qualified to perform their respective reviews
reviewed PIRCS reports 87034, 88741, 88948, 89289, and 90566 to verify that the licensee had identified configuration management, post-modification testing, and/or plant modification issues and corrected the condition in accordance with approved corrective action program procedure NFS-CAP-009, Rev. 10, "The NFS Corrective Action Program" and the license conditions
reviewed the most recent audit of the configuration management system and interviewed licensee staff to verify that the scope and frequency of audits were being conducted in accordance with Section 11.5.1 of the license application and facility procedures o
QA-22-04 "Configuration Management Program - Quality Assurance Audit", dated 3/10/2020
16 License Application Changes (IP Section 02.04)
For the selected modifications, the inspectors interviewed a number of licensee staff and reviewed applicable sections of the license application to verify the licensee evaluated license application changes and conducted NRC pre-approval screenings in accordance with the license requirements. Specifically, the inspectors conducted the inspection activities listed below:
reviewed the implementation of licensees procedure NFS-HS-A-67-A, Rev.
16, "Safety and Regulatory Review", and the associated safety review workflow form NFS-HS-A-67, "Safety and Regulatory Review Routing Form Part 1," for ECR-20213442, "Installation of Permanent Unloader" to verify that the impact of this modification on the license application, if any, was evaluated in accordance with the conditions of the license.
reviewed the implementation of ECR-20221190 to verify that the impact of this modification on the license application, if any, was evaluated in accordance with the conditions of the license.
New Processes at Existing Facilities (IP Section 02.05)
The inspectors reviewed samples of configuration management documentation packages to verify that the licensee addressed the requirements of 10 CFR 70.64, 10 CFR 70.72 and license conditions. Specifically, the inspectors conducted the activities listed below:
interviewed licensee staff, performed walk-downs, and reviewed the configuration management packages for the following processes:
o ECR 20221190, General 300 Complex Process Ventilation o
ECR 20213442, Permanent Unloader for Final Train Process Records Retention (IP Section 02.06)
The inspectors reviewed a sample of plant documents impacted by the selected modifications to verify the licensee maintained records of facility changes in accordance with the license requirements and 10 CFR 70.72. The sample of documents included:
operating procedure SOP 401-11, Rev. 26B, Sections 6.1, 6.9, 6.10, 6.11, and 6.15
Engineering Design Authority (EDA) training records and qualification card
system drawings o
302-F0097-D, "FMF Process Ventilation P&ID demo red-lined working version", Rev. ECR 20221190 o
302-F0097-D, "FMF Process Ventilation P&ID South Branch", Rev.
ECR 20221190, 10/14/22 o
302-F0097-D, "FMF Process Ventilation P&ID South Branch", Rev. As-Built ECR 20221190, 11/01/22 o
302-F0099-D, "FMF Process Ventilation P&ID North Branch", Rev.
ECR 20221190, 10/14/22
17 INSPECTION RESULTS Failure to Follow Procedure Requirements for Area 200 Operations Severity Report Section Severity Level IV NOV 07000143/2022004-01 Closed 88135.02 The inspectors identified a self-revealing, Severity Level IV, cited violation of License Condition S-1 for the licensee's failure to follow a Standard Operating Procedure during operation of the Area 200 process.
==
Description:==
On November 10, 2022, during dayshift, an operator-in-training incorrectly installed equipment in Area 200 while conducting preparation activities for SNM processing. The incorrect equipment installation placed the Area 200 process in an undesired configuration for handling SNM. Subsequently, on the second shift, a trained operator assigned to Area 200 proceeded with routine SNM processing activities in that area. The second shift operator was required to observe the process start-up per Standard Operating Procedure (SOP)-401-02-302, Revision 052E. However, the operator failed to observe the start-up as directed by the procedure and consequently failed to identify the incorrect equipment configuration established by the dayshift operator. As the start-up process in Area 200 continued, SNM spilled on the process floor as a direct result of the incorrect equipment set up performed by the dayshift operator. The spill did not result in the release of SNM outside the radiologically controlled area (RCA) or occupational dose above the NRC regulatory limits. The Area 200 process was returned to normal operations after corrective actions were completed.
Corrective Actions: The licensee's corrective actions for this issue included: (1) placing the affected process areas in safe shutdown, (2) direct management supervision of recovery actions, particularly decontamination efforts and return to operations, (3) establishing additional RCA boundaries, additional personal protective equipment requirements, and radiological monitoring during clean-up activities, (4) successful decontamination of the process area, (5) implementation of credited criticality safety controls to collect spilled SNM in safe containers, and (6) retraining Area 200 operators on proper equipment setup and observation of process start-up.
Corrective Action
References:
The licensee entered the issue in the PIRCS as item number 90879.
Analysis: The inspectors determined the failure of the second shift operator to observe the start-up of the Area 200 process and identify the incorrect system configuration as required by SOP 401-02-302 constituted a violation of License Condition S-1 for not handling SNM in accordance with written procedures as stated in Section 11.4 of the license application. The violation was determined to be self-revealing because it became apparent as a result of a process upset. The inspectors determined the violation was more-than-minor based on the screening criteria of IMC 0616, Fuel Cycle Safety and Safeguards Inspection Reports, Appendix B, Examples of Minor Violations. The inspectors determined the violation could reasonably be considered a precursor to a significant event per Question 1 of the screening process because it was similar to Example 1.a in that the failure to follow procedure resulted in an unsafe configuration of SNM that adversely impacted nuclear or radiological safety of equipment and personnel.
Specifically, the failure to follow procedure resulted in a missed opportunity to identify a precursor to a process upset, which adversely impacted the containment of SNM and caused an unplanned contamination in the process area. This event did not result in serious safety
18 consequences because: (1) the spill was contained within the Material Access Area (MAA),
where physical access is controlled and RCA measures, including contamination boundaries, are normally maintained, (2) the IROFS credited for an SNM spill accident in that process area performed as designed and the performance requirements of 10 CFR 70.61 were still met based on the approved ISA methodology for the facility, (3) the amount of licensed material spilled was bound by the analyzed quantities in the ISA, (4) there was no release of licensed material to the environment, and (5) the event did not result in employee injuries, contamination, or radiological/chemical exposure beyond NRC regulatory limits.
The inspectors determined that the violation was of Severity Level IV significance because the violation aligned with Example 6.2.d.2 of the Enforcement Policy in that it involved the licensees failure to maintain a control required to meet a safety margin where the failure did not result in a Severity Level I, II, or III violation. Additionally, in accordance with Section 2.2.2 of the NRC Enforcement Policy, violations that are less serious but are of more-than-minor concern and result in no or relatively inappreciable potential safety consequences are characterized as Severity Level IV violations.
Enforcement:
Severity: This is a Severity Level IV violation consistent with Example 6.2.d.2 of the NRC Enforcement Policy.
Violation: License Condition S-1 states, in part, that the license is for use in accordance with the statements, representations and conditions in the application. Chapter 11 of the license application, Section 11.4, Procedure Development and Implementation, states in part that Activities involving the handling of SNM and/or IROFS are conducted in accordance with written procedures as defined in this section. Additionally, Section 11.4.1, Operating Procedures, of the license application states, in part, that Operating procedures are documents written to authorize the processing of radioactive material; and, within these documents detailed instructions for operation of equipment used in the process or activity, instructions for the disposition of radioactive wastes, and limits and controls established for safety purposes, including IROFS, are identified.
Standard Operating Procedure SOP-401-02-302, "Area 200," Revision 052E, Step 6.2.7, states in part that designated process operators shall "OBSERVE system for 2-5 minutes AFTER initiating processing" to ensure safe process operation.
Contrary to the above, on November 10, 2022, the licensee failed to handle SNM in accordance with written procedure SOP-401-02-302, Revision 052E, in Area 200.
Specifically, a designated operator failed to follow written instructions to observe the process start-up, which resulted in a missed opportunity to identify an incorrect system configuration that ultimately caused a spill of SNM and an unplanned contamination in a process area. This violation is being treated as a cited violation consistent with Section 2.3.2 of the Enforcement Policy because it was identified through an event (i.e., self-revealing) and not by the licensee.
This violation is identified as VIO 70-143/2022004-01, Failure to Follow Procedure Requirements for Area 200 Operations and is considered closed.
Enforcement Action: This violation is being cited because the licensee does not have an NRC-approved Corrective Action Program and did not identify the violation, consistent with Section 2.3.2 of the Enforcement Policy.
19 EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On January 9, 2023, the NRC Resident Inspector presented the inspection results for the fourth quarter of calendar year 2022 to Ronald Dailey and other members of the licensee staff.
On November 10, 2022, the inspectors presented the NCS (IP 88015) and permanent plant modifications (IP 88070) inspection results to Ronald Dailey and other members of the licensee staff.
On October 27, 2022, the inspectors presented the fire protection (IP 88055) and emergency preparedness (IP 88050) inspection results to Ronald Dailey and other members of the licensee staff.
20 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 88015 Calculations SA-00096 Setpoint Analysts for FPV-0004 (U) 02/27/2020 88015 Calculations SA-00369 Setpoint Analysis for FAT-001 (U) 11/19/2015 88015 Corrective Action Documents 41819, 90559, 90722, 90786, 90692, 88650, 88521, 33063, 31634 88015 Engineering Evaluations 54T-14-0021 Control Flowdown and Field Verification for Area A of the Uranium Recovery Revision 1 of NCSE Issued April 21, 2012 Rev. 2 88015 Engineering Evaluations 54X-07-0021 Nuclear Criticality Safety Evaluation for the 300 Complex Process and 105 Laboratory Exhaust Ventilation Systems (U)
Rev. 6 88015 Engineering Evaluations 54X-08-0001 Control Flowdown and Field Verification for the 300 Complex Process and 105 Laboratory Exhaust Ventilation System (U)
Rev. 5 88015 Engineering Evaluations 54X-12-0002 Nuclear Criticality Safety Evaluation for Area A of the Uranium Recovery Facility (U)
Rev. 1 88015 Engineering Evaluations 54X-16-0011 Nuclear Criticality Safety Evaluation For Area D of the Uranium Recovery System (U)
Rev. 5 88015 Engineering Evaluations 54X-17-0007 Control Flowdown and Field Verification for Area D (U)
Revision 5 of NCSE Issued on November 2, 2016 Rev. 8 88015 Engineering Evaluations 54X-21-0001 Nuclear Criticality Safety Evaluation for the Tube Cleaning Room of the Production Fuel Facility (U)
Rev. 6 88015 Engineering Evaluations 54X-21-0002 Control Flowdown and Field Verification for Tube Cleaning Room of the Production Fuel Facility Rev. 6 88015 Engineering Evaluations 54X-22-0010 Addendum 3 to Nuclear Criticality Safety Evaluation for the 300 Complex Process and 105 Laboratory Exhaust Ventilation Systems (U), Revision 6 Rev. 0 88015 Miscellaneous 105 Lab Scrubber Yearly Non-Destructive Assay Examination Completed 05/12/2022 88015 Miscellaneous 27X-20-0012 Area 900 Operator Training (U)
21 88015 Miscellaneous 27X-21-0006 Operator Training for Building 302 Common (U) 88015 Miscellaneous 302-POG-CALC.XLS FMF POG System Calculation Sheet Completed 05/10 and 05/11/2022 88015 Miscellaneous N302VENDRAIN042 SRE Test 10/05/2022 88015 Miscellaneous N306OVERFLO1803 SRE Test 02/21/2020 88015 Miscellaneous N306VENDRAIN008, SRE Test 10/05/2022 88015 Miscellaneous N306VENDRAIN012 SRE Test 10/05/2022 88015 Miscellaneous SAREV-20220087 Safety Review Record for SOP 401 Section 8A Rev. 0 88015 Miscellaneous SAREV-202202228 Safety Review Record for CCP 202011160 Rev. 0 88015 Procedures 21T-21-0106 Nuclear Criticality Safety Audit Writers Guide Rev. 6 88015 Procedures NFS-A-07 Procedure Listing for Control Lab Samples Rev. 24 88015 Procedures NFS-ACC-062 Procedure for Non-Destructive Assay (NDA) of the 300 Complex Scrubber System, WD01/WD02, Fenton's WF Tanks, and the Process Off-Gas Ductwork Rev. 23 88015 Procedures NFS-ACC-066 Procedure for Yearly NDA of Process Exhaust Ventilation Systems (PEVS)
Rev. 11 88015 Procedures NFS-GH-913 Nuclear Criticality Safety Program Rev. 4 88015 Procedures NFS-HS-A-21 Operation and Testing of the Criticality, Fire, and CO2 Alarm Systems Rev. 39 88015 Procedures NFS-HS-CL-10 Nuclear Criticality Safety Fuel Manufacturing Facility (U)
Rev. 32 88015 Procedures NFS-HS-CL-10-08 Nuclear Criticality Safety Buildings 306 and 307 - Area 800 and Tube Cleaning Room (U)
Rev. 34 88015 Procedures NFS-HS-CL-10-08 Nuclear Criticality Safety Building 306 and 307 - Area 800 and Tube Cleaning Room (U)
Rev. 34 88015 Procedures SOP 401-08 Area 800 (U)
Rev. 32.C 88015 Procedures SOP 401-08A FMF, Area 800A Auxiliary System (U)
Rev. 38 88015 Self-Assessments NCS-2022-21 Nuclear Criticality Safety Audit of the Nuclear Criticality Safety Evaluation for the 300 Complex Process and 105 Laboratory Exhaust Ventilation Systems (U) 07/27/2022 88015 Self-Assessments NCS-2022-25 Nuclear Criticality Safety Audit of the Nuclear Criticality Safety Evaluation for BPF Liquid Waste Discard System (U), Ninth Audit 08/11/2022
22 88015 Self-Assessments NCS-2022-26 Tenth Nuclear Criticality Safety Audit of the SNM Processing Operations for the Shipping and Receiving Vault (U) 08/11/2022 88015 Self-Assessments NCS-2022-29 Third Nuclear Criticality Safety Audit of the SNM Processing Operations for the 300 Complex Rinse Station (U) 10/25/2022 88050 Calculations 54T-18-0002 Estimation of the Potential Dose to Exposed Workers and Off-Site Members of the Public Resulting From an Accidental Criticality Rev. 2 88050 Calculations 54T-20-0005 Estimation of the Potential Dose to Exposed Workers and Off-Site Members of the Public Resulting From an Accidental Criticality Rev. 3 88050 Procedures FB-001 Standard Operating Guidelines for Fire Brigade Operations Rev. 0 88050 Procedures NFS-GH-57 Fire Brigade Organization and Administration Rev. 6 88050 Procedures NFS-GH-903 NFS Emergency Plan Rev. 28 88050 Procedures NFS-HS-E-02 Emergency Criticality Evacuation Rev. 49 88050 Procedures NFS-HS-E-03 Emergency Response Organization Rev. 38 88050 Procedures NFS-HS-E-04 Fire Reporting and Response Rev. 42 88050 Procedures NFS-HS-E-05 Spill Response and Reporting Rev. 41 88050 Procedures NFS-HS-E-07 On-Site Radiological Emergency Assessment Rev. 37 88050 Procedures NFS-HS-E-08 Off-Site Radiological Emergency Assessment Rev. 33 88050 Procedures NFS-HS-E-09 Off-Site Dose Projection for Radiological Emergency Rev. 33 88050 Procedures NFS-HS-E-10 Emergency Communications Rev. 32 88050 Procedures NFS-HS-E-11 Radiological Scene and Contamination Control Rev. 25 88050 Procedures NFS-HS-E-12 24-Hour Emergency Response for Hazardous Material Transportation Rev. 27 88050 Procedures NFS-HS-E-13 Emergency Takeover Rev. 9 88050 Procedures NFS-HS-E-15 Emergency Medical Response Rev. 21
23 88055 Corrective Action Documents Resulting from Inspection PIRCS 90723 Cover not in Place/Unguarded Opening in Enclosure 10/25/2022 88055 Corrective Action Documents Resulting from Inspection PIRCS 90739 Combustible Liquids Not Stored in Flammable Storage Cabinet 10/26/2022 88055 Corrective Action Documents Resulting from Inspection PIRCS 90742 Wheeled Fire Extinguisher in Building 306 10/26/2022 88055 Engineering Evaluations 21X-18-0033 Fire Hazard Analysis, Building 302 Rev. 0 88055 Engineering Evaluations 21X-19-0018 300 Complex and Building 100 Fire ACE Rev. 11 88055 Fire Plans Building 302, Pre-Fire Plan 33 4/29/2021 88055 Miscellaneous Calibration of 302 Area 600 Hydrogen Detectors Performed on 9/16/2022 88055 Miscellaneous 22T-22-2359,SA-GET-1, NFS Training Department General Employee Training Lesson Plan 88055 Miscellaneous 71T-20-0592 Visual Examination Walkdown Punch List, Summary of Integrity Assessment Investigations 10/14/2020 88055 Miscellaneous 71T-21-0041 Visual Examination Walkdown Punch List, Summary of Integrity Assessment Investigations 3/26/2021 88055 Miscellaneous Hot Work Permit 647 Repair CPVC POG Line 10/7/2022 88055 Miscellaneous Hot Work Permit 648 Repair CPVC POG Line 10/7/2022 88055 Miscellaneous Hot Work Permit 655 Repair CPVC POG Line 10/18/2022 88055 Miscellaneous NFS-GH-62-01 Controls of Combustibles - Monthly Performed on 9/1/2022 88055 Miscellaneous NFS-GH-62-01 Controls of Combustibles - Weekly - Zone 2 CO2 System Performed on 9/13/2022 88055 Miscellaneous NFS-HS-B-103 Flammable Storage Cabinet Annual Inspection Performed in December
23 2021 88055 Miscellaneous NFS-HS-B-11 Emergency Lights Monthly Testing Performed in August 2022 88055 Miscellaneous NFS-HS-B-58-12 CO2 System Weekly Visual Inspection Performed on 9/22/22
24 88055 Miscellaneous NFS-HS-B-70 Electromagnetic Door Holders Annual Inspection Performed on 9/15/22 88055 Miscellaneous NFS-HS-B-70 Heat Detectors Annual Test Performed on 1/28/2022 88055 Miscellaneous NFS-HS-B-70 Manual Pull Stations - Annual Performed on 9/2/2022 88055 Miscellaneous NFS-HS-B-70 Smoke Detectors Annual Test Performed on 2/10/2022 88055 Miscellaneous NFS-HS-B-85 Fire Extinguishers Monthly Inspection Performed in August 2022 88055 Miscellaneous NFS-HS-B-95 Fire Barrier Annual Inspection Performed in July 2022 88055 Miscellaneous NFS-HS-B-95 Swinging Fire Doors Annual Inspection Performed in May 2022 88055 Miscellaneous SRE N302XFRDAMP0002 SRE Test for IROFS-18, Equipment N302XFRDAMP0002 1/13/2021 88055 Miscellaneous SRE N302XFRDAMP0003 SRE Test for IROFS-18, Equipment N302XFRDAMP0003 1/13/2021 88055 Miscellaneous SRE N302XFRDAMP0004 SRE Test for IROFS-18, Equipment N302XFRDAMP0004 1/13/2021 88055 Miscellaneous SRE N302XX600MAXONS SRE Test IROFS 302303-600700A, Equipment N302XX600MAXONS, Completed on 3/31/2021 88055 Operability Evaluations 2022-047 Fire System Impairment 2022-047, CO2 System, Zone 2 July 2022 88055 Operability Evaluations FM-HS-A-79-01, HEA-21 Approval for Use of Compensatory Measure for IROFS FIRE-1 in Zone 2 of Bldg 302 7/25/2022 88055 Procedures NFS-GH-25 Hot Work Procedure Rev. 17 88055 Procedures NFS-GH-62-01 NFS Monthly Combustible Control Inspections Rev. 11 88055 Procedures NFS-GH-62-03 NFS Monthly Combustible Control Inspections (Non-IROFS)
Rev. 3 88055 Procedures NFS-GH-939 Piping Integrity Plan Rev. 9 88055 Procedures NFS-HS-B-70 Fire Detection Rev. 11 88055 Procedures SOP 401-06 FMF, Bldg. 302, Area 600 Rev. 2
25 88055 Self-Assessments Triennial Fire Protection Program Assessment - Nuclear Fuel Services 03/05/2021 88055 Work Orders 00424081 302/303 CO2 System Semi-Annual Inspection, ORR Protection Work Order 00424081 Performed on 6/24/2022 88055 Work Orders FO1145305 302/303 CO2 System (Zone 2) Semi-Annual Inspection, ORR Protection Work Order FO1145305 Performed on 8/9/2022 88135.02 Corrective Action Documents 89465 88135.02 Corrective Action Documents 90493 88135.02 Corrective Action Documents 90494 88135.02 Corrective Action Documents 90513 88135.02 Corrective Action Documents 90559 88135.02 Corrective Action Documents 90717 88135.02 Corrective Action Documents 90879 88135.02 Corrective Action Documents 90881 88135.02 Corrective Action Documents Resulting from Inspection 90723 88135.02 Corrective Action Documents Resulting from Inspection 90739 88135.02 Corrective Action Documents Resulting from Inspection 90742 88135.02 Corrective Action 90811
25 Documents Resulting from Inspection 88135.02 Corrective Action Documents Resulting from Inspection 90812 88135.02 Corrective Action Documents Resulting from Inspection 90825 88135.02 Corrective Action Documents Resulting from Inspection 90872 88135.02 Procedures NFS-CAP-009 The NFS Corrective Action Program Revision 010 88135.02 Procedures NFS-ECP-002 Employee Concerns Processing Revision 6 88135.02 Procedures NFS-ECP-003 Ethics and Compliance Program (ECP)
Revision 4 88135.02 Procedures NFS-GH-36-01 Lockout/Tagout-Physical Work Revision 8 88135.02 Procedures NFS-GH-65 Problem Identification Revision 10 88135.02 Procedures NFS-HPL-008 Safety Culture Monitoring Panel (SCMP)
Revision 0 88135.02 Procedures NFS-HS-E-02 Emergency Criticality Evacuation Revision 50 88135.02 Procedures NFS-MGT-04-006 NFS Safety Conscious Work Environment Policy Revision 7 88135.02 Procedures NFS-MGT-10-023 Executive Review Board (ERB)
Revision 8 88135.02 Procedures NFS-MGT-12-029 NFS Ombudsman Program Charter and Protocol Policy Revision 3 88135.02 Procedures SOP 401-02-302 FMF Area 200 BLDG 302 Revision 052E