ML23116A086
| ML23116A086 | |
| Person / Time | |
|---|---|
| Site: | BWX Technologies |
| Issue date: | 04/27/2023 |
| From: | Eric Michel NRC/RGN-II/DFFI/FFB2 |
| To: | Bittner J BWXT |
| References | |
| IR 2023001 | |
| Download: ML23116A086 (13) | |
Text
April 27, 2023 James J. Bittner Vice President and General Manager Nuclear Operations Group, Inc.
BWXT Nuclear Operations Group, Inc.
P.O. Box 785 Lynchburg, VA 24505-0785
SUBJECT:
BWXT NUCLEAR OPERATIONS GROUP, INC. - INTEGRATED INSPECTION REPORT 07000027/2023001
Dear James J. Bittner:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection activities conducted from January 1, 2023, to March 31, 2023, for the BWXT Nuclear Operations Group, Inc., facility. On April 26, 2023, the NRC inspectors discussed the results of this inspection with you. The results of this inspection are documented in the enclosed report.
No violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Signed by Michel, Eric on 04/27/23 Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 07000027 License No. SNM-42
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV
ML23116A086 X Non Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI NAME N. Peterka E. Michel DATE 4/26/2023 4/27/2023 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07000027 License Number: SNM-42 Report Number: 07000027/2023001 Enterprise Identifier: I-2023-001-0074 Licensee: Nuclear Operations Group, Inc.
Facility: BWXT Nuclear Operations Group, Inc.
Location: Lynchburg, VA 24505 Inspection Dates: January 01, 2023 to March 31, 2023 Inspectors: M. Doyle, Senior Resident Inspector N. Peterka, Fuel Facility Inspector T. Shewmaker, Fuel Facility Inspector T. Sippel, Sr. Fuel Facility Projects Approved By: Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at BWXT Nuclear Operations Group, Inc.,
in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities. Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.
List of Violations No violations of more than minor significance were identified.
Additional Tracking Items None.
2
PLANT STATUS During the inspection period routine fuel manufacturing operations and maintenance activities were conducted in the fuel processing areas, the uranium recovery (UR) facility, and the research and test reactors (RTR) facility. However, the annular organic waste tank in UR remained isolated and shutdown since January 19, 2023.
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 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
SAFETY OPERATIONS 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees nuclear criticality safety (NCS) program to verify compliance with selected portions of Title 10 of the Code of Federal Regulations (10 CFR) 70, "Domestic Licensing of Special Nuclear Material," including 70.24, 70.50, 70.61, 70.62, appendix A; chapter 5, "Nuclear Criticality Safety," of the facilitys license application; and applicable licensee procedures.
Criticality Analysis (IP Section 02.01)
The inspectors interviewed licensee staff and reviewed NCS evaluations and associated assumptions and calculations to verify compliance with 10 CFR 70 and applicable sections of the license application including portions of sections 5.1, 5.2, and 5.3. Specifically, the inspectors interviewed licensee criticality safety engineers and reviewed the following:
NCS-PA-23-00015, "Nuclear Criticality Safety Evaluation of RTR Fuel Plate Wet Operations," Revision (Rev.) 0, including review of credible accident sequences, assumptions, calculations, and modeling, methodology, and demonstration of double contingency, and supporting technical reference NCS-PA-27-00002, "Nuclear Criticality Safety Evaluation of the NR Element Carts (U)," Rev. 0, including review of credible and non-credible accident sequences, assumptions, and methodology and demonstration of double contingency NCS-2011-172, "Nuclear Safety Release for SER 11-024 Phase 1 - Annular Organic Tank," which was reviewed because it contained a variety information supporting the licensee's evaluation of accident sequences and items relied on for safety (IROFS) for the organic tank 3
Criticality Implementation (IP Section 02.02)
The inspectors selected engineered and administrative controls from the licensees safety analysis report (SAR) to verify proper implementation through a review of process and system descriptions, plant walkdowns, and operator interviews to verify compliance with 10 CFR 70 and applicable sections of the license application including 5.2 and chapter 11, "Management Measures." Specifically, the inspectors interviewed licensee staff and reviewed the following controls and their management measures:
passive engineered air gap used to prevent solution from getting into the ventilation system from the annular organic tank in UR including review of relevant drawings (i.e., UPRR-30073 B) passive engineered overflow drain used to prevent solution from getting into the ventilation system from the annular organic tank in UR including review of relevant drawings (i.e., UPRR-30073 B) administrative control on uranium concentration in organic solutions being transferred in UR and associated operating procedures including OP-0061135, OP-0061137, and OP-0061232 administrative for clean out of the organic tank annulus and associated maintenance work orders (WOs) and maintenance procedures (MPs) passive engineered geometry control of the organic tank's annular thickness as measured in NCS-2011-172 administrative and passive engineered IROFS controls on piece count, spacing, volume, and geometry (e.g., slab height, diameter) were observed while on walkdowns as well as NCS postings for these controls 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 including 5.5, 11.5.1.1, 11.5.1.2, and 11.5.3.1. Specifically, the inspectors performed the following activities:
reviewed 2022 NCS refresher training provided to operators interviewed NCS and UR area staff concerning control methods used to prevent long-term accumulation in tanks and ductwork observed a licensee NCS engineer conduct a weekly NCS inspection and part of the NCS quarterly audit in the Lynchburg Technology Center, reviewed recent audit reports, reviewed recent records of walkdowns, and reviewed the 2023 1st quarter NCS audit plan interviewed licensee NCS engineers and management concerning schedule, conduct, results, and documentation of the weekly NCS inspections and the NCS quarterly audit interviewed research test reactors and targets operators concerning control methods and procedures used to control number of pieces in wash tanks 4
Criticality Programmatic Oversight (IP Section 02.04)
The inspectors reviewed NCS program procedures, audits, and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the license application including 2.1.6, 11.5.1.5, and 11.5.3.3. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:
qualification records for an NCS auditor and two NCS engineers recent audit reports for audits of the NCS program conducted by the quality assurance (QA) group including IA-SAR-2022-02-01, reviewed schedules of QA audits, and interviewed a QA auditor concerning audits of the NCS program the most recent revisions to licensee NCS program procedures NCSE-02, NCSE-03, NCSE-07, NCSE-09, and NCSE-11 the current recent revision of EPR-02-05, "Emergency Preparedness Manual, NCS EOC Guidance," and interviewed licensee NCS engineers and staff qualified in emergency response concerning the licensee's response to NCS events Criticality Incident Response and Corrective Action (IP Section 02.05)
The inspectors reviewed the licensees criticality accident alarm system (CAAS) and corrective action program to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors observed activities, reviewed documents, and/or interviewed licensee staff concerning the following:
recent NCS-related corrective action program entries including how NCS staff verify that resulting actions are completed in accordance with their requirements recent safety concern analyses performed by NCS staff including NCS-2023-009 and NCS-2023-016 the licensee procedures and guidance for making reportability evaluations including quality work instruction (QWI) 14.1.10, "Safety Evaluation of Unusual Incidents," Rev. 19 walked down the CAAS with the cognizant licensee engineer and interviewed licensee staff concerning the performance and any modification to the CAAS 88135.02 - Plant Status The inspectors routinely conducted walkdowns of licensee areas, observed operators, material control and accounting, and security force personnel, inspected postings and licensee guidance documents, interviewed plant personnel, and discussed the results of operational and shift turnover meetings to gain insight into the status of facility activities, risk-inform the selection and implementation of the appropriate core inspection procedures, and ensure compliance with license and regulatory requirements.
5
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.
responded to emergency operations center manning following an arc flash in bay 6 on February 25, 2023 Status Meetings (IP Section 03.02)
The inspectors, on a routine basis, attended and reviewed the results of scheduled licensee meetings to determine plant status and awareness of site activities so that inspection resources were appropriately focused on those activities with the higher safety significance.
attended safety review committee meeting on January 9, 2023 attended change review board meeting on January 19, 2023 attended the critique of corrective action (CA) 202300083 for event notice (EN) 56336, waste organic tank overflow upset, on February 8, 2023 attended change review board meeting on March 16, 2023 attended as low as reasonably achievable (ALARA) meeting on March 23, 2023 Identification and Resolution of Problems (IP Section 03.05)
The inspectors reviewed the selected issues below to determine if the licensee was entering equipment, human performance, and other performance issues in a formalized program to identify, track, and assure correction of safety and safeguard significant problems in accordance with 10 CFR 70.62(a)(3) and applicable license requirements.
CA202300078, incident date January 19, 2023 CA202300092, incident date January 25, 2023 CA202300166, incident date February 9, 2023 CA202300206, incident date February 13, 2023 CA202300306, incident date March, 13, 2023 Radiation Work Permit (IP Section 03.09)
The inspectors reviewed and observed the radiation work permit (RWP) listed below to determine whether the RWP contains the information required by chapter 4, "Radiation Safety," of the license application, the radiation protection manual, and implementing procedures:
RWP 23-0003, "Clean High-Level Dissolver Troughs with Aid of a Small HEPA Vacuum," conducted on January 10, 2023 6
Annual Security and Emergency Preparedness Drills/Exercises (IP Section 03.10)
The inspectors observed the licensees performance during the security force-on-force (FOF) tactical response exercise listed below to determine they were being implemented in accordance with 10 CFR 73.46(b)(9):
security FOF tactical response exercise conducted on March 22, 2023 88135.04 - Resident Inspection Program Operational Safety The inspectors evaluated whether the material condition and as-found configuration of selected site structures, systems, and components, documentation, personnel, and IROFS to verify compliance with 10 CFR 70, the license, the SAR, and/or license application, and licensee policies and procedures; and determine whether they are appropriate, available, and reliable to protect worker and public safety during normal, off-normal, and accident conditions.
Operations Safety Walkdown (IP Section 03.01)
The inspectors evaluated the operational safety of the systems and sub-systems of the listed processes associated with the following operation area:
SAR 15.33, "Vault 7 Operations," Rev. 43 walkdown of IROFS observed lift operations in vault 7 observed vault 7 access controls 88135.05 - Resident Inspection Program Fire Protection (Annual/Quarterly)
The inspectors evaluated the operational status and material condition of fire protection systems, structures, and components 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 801, "Standard for Fire Protection for Facilities Handling Radioactive Materials," as required.
Fire Area Walkdown (IP Section 03.01)
The inspectors walked down and evaluated the fire areas listed below:
bays 2, 3, 4, and 5 88135.19 - Post Maintenance Testing The inspectors evaluated post-maintenance test activities to verify compliance with license application chapter 11, "Management Measures," and test procedures and/or WO instructions to confirm functional capability of the IROFS and/or safety controls following maintenance.
7
Post-Maintenance Testing (IP Section 03.01)
The inspectors reviewed the post-maintenance tests listed below. Tests were either observed directly or test results were reviewed.
WO 20337979, post-maintenance testing of new primary waste column pump on January 5, 2023 facility alarm system (FAS) testing after maintenance on January 19, 2023 88135.22 - Surveillance Testing The inspectors evaluated IROFS and safety controls that required periodic surveillance and/or calibration tests to ensure they were available and reliable to perform their function when needed to comply with license application chapter 11 and the performance requirements of 10 CFR 70.61 and 70.62 and to maintain their operational readiness consistent with the integrated safety analysis.
Surveillance and Calibration Testing (IP Section 03.01)
The inspectors reviewed the surveillance and/or calibration test listed below. The test was either observed directly or test results were reviewed.
weekly pickle area quality and safety checks were observed by the inspectors on March 20, 2023 INSPECTION RESULTS No issues were identified.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On April 26, 2023, the inspectors presented the integrated inspection results to James J.
Bittner and other members of the licensee staff.
On March 16, 2023, the inspectors presented the NCS inspection results to James J.
Bittner and other members of the licensee staff.
8
DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88015 Corrective Action CA202101568 NCS-Related CAs Various Documents CA202201013 CA202201275 CA202201326 CA202201581 CA202300083 CA202300078 CA202300164 CA202300166 CA202300083 CA related to organic tank event Drawings UPRR-30073 B Annular Organic Tank Piping and Instrumentation Drawing Rev. 1, (P&ID) 02/02/2012 UPRR-30116 B Annular Waste Tank P&ID Rev. 4 Engineering NCS-2011-172 Nuclear Safety Release for SER 11-024 Phase 1 - Annular 04/11/2012 Evaluations Organic Tank NCS-2012-037 NCS Safety Analysis for SER 11-024 Phase 1 - Annular 03/14/2012 Organic Tank (Revised)
NCS-2023-009 NCS Safety Concern Analysis for Organic Solution Flowing 01/30/2023 from the Organic Waste Tank into Ventilation Ducting per CA202300083 NCS-2023-016 Revised NCS Safety Concern for Organic Solution Flowing 02/09/2023 from the Organic Waste Tank into Ventilation Ducting per CA202300083 NCS-PA Nuclear Criticality Safety Evaluation of RTR Fuel Plate Wet Rev. 0 00015 Operations NCS-PA Nuclear Criticality Safety Evaluation of the NR Element Carts Rev. 00 00002 (U)
NCS-PR Nuclear Criticality Safety Process Requirements Document Rev. 000A 00015 for NCS-PA-23-00015 NCS-TR-00093 Nuclear Criticality Safety Technical Reference for RTR Fuel Rev. 00 Plate Wet Operations SAR 15.12 Liquid and Solid Waste Handling Processes in Uranium Rev. 86 9
Inspection Type Designation Description or Title Revision or Procedure Date Recovery Miscellaneous 2022 NCS Refresher 2022 NRC The schedule for CY 2022 QA audits used to comply with 11/30/2021 Schedule NRC license application requirements 2023 NRC Audit The schedule for CY 2023 QA audits used to comply with 11/02/2022 Schedule NRC license application requirements NCS-2022-052 Nuclear Criticality Safety Technical Work Record 08/03/2022 (Qualifications for NCS Auditor and Two NCS Engineers)
Procedures EPR-02-05 Emergency Preparedness Manual, NCS EOC Guidance Rev. 9 MP-3404 Drain & Flush the Annular Organic Tank NCSE-02 Nuclear Criticality Safety Analyses Rev. 49 and Rev. 50 NCSE-03 Nuclear Criticality Safety Audits and Inspections Rev. 31 NCSE-07 Qualification and Training Requirements for an NCS Rev. 19 Engineer NCSE-08 Movement of Fuel Rev. 7 NCSE-09 Leaks, Spills, and Floor Scrubbing Rev. 7 NCSE-11 Verification and Validation of Computer Codes used for Rev. 8 Criticality Safety Analyses OP-0061135 Waste Handling and Disposal Enrichment Blending & Rev. 45 Uranium Recovery Facility OP-0061137 General Purpose Area A/B Rev. 50 OP-0061232 Preparation for SNM Inventory in Uranium Recovery Rev. 19 QWI 14.1.10 Safety Evaluation of Unusual Incidents Rev. 19 QWI 17.1.02 Internal Quality Audits Rev. 23 Self-Assessments N/A 1st Quarter 2023 NCS Audit Plan 03/01/2023 IA-2572B-2022- Internal Audit Summary Report, June 2022 Rev. 0 06-01 IA-2572C-2022- Internal Audit Summary Report, July 2022 Rev. 0 07-01 IA-SAR-2022 Internal Audit Summary Report, Feb 2022 05/02/2022 01 N/A NCS Quarterly Audit Checklist 3rd Quarter 2022 11/03/2022 10
Inspection Type Designation Description or Title Revision or Procedure Date N/A NCS Quarterly Audit Checklist 4th Quarter 2022 NA Work Orders WO 20319278 SC Drain/Flush Annular Org Tank 6M Reco 02/23/2022 WO 20327563 SC Drain/Flush Annular Org Tank 6M/EXT 88135.02 Corrective Action CA202300078 UIR-NCS 01/23/2023 Documents CA202300083 Waste organic tank overfill 01/19/2023 CA202300092 Safety near hit 01/26/2023 CA202300166 UIR-NCS 02/13/2023 CA202300206 RP-UIR 02/21/2023 CA202300306 Chemical processing 03/14/2023 Miscellaneous N/A Change Review Board Agenda 03/16/2023 N/A Safety Review Committee Meeting Minutes 01/09/2023 N/A Change Review Board Agenda 01/19/2023 Radiation Work 23-0003 Clean High-Level Dissolver Troughs with Aid of Small HEPA Rev. 00 Permits Vacuum 88135.04 Miscellaneous E4-0000724 Vault Storage Verification Form Rev. 03 Procedures E41-0000042 Nuclear Material General Storage Requirements Rev. 69 E41-201 Vault 7 Operations Rev. 25 E41-207 Nuclear Material Specific Storage Requirements Rev. 21 OP-1000624 Vault 7 Access Control Rev. 7 88135.05 Fire Plans Section 3 Bay 2, Machine Shop 09/10/2014 88135.19 Miscellaneous N/A FAS Testing Plan After Retrofit Phase 3: Area 12 Addition 01/25/2023 Procedures OP-1046323 Operating Procedure for TRISO FAS Detector Calibrations Rev. 7 Work Orders 20337979 Change Primary Waste Column Pump 01/05/2023 88135.22 Procedures M11-P-029 Pickle Area Quality and Safety Checks Rev. 36 OP-0021001 Operating Procedure for Pickling Rev. 96 11