ML24107B118
| ML24107B118 | |
| Person / Time | |
|---|---|
| Site: | Erwin |
| Issue date: | 04/18/2024 |
| From: | Robert Williams NRC/RGN-II/DFFI/FFB1 |
| To: | Dailey R Nuclear Fuel Services |
| References | |
| IR 2024001 | |
| Download: ML24107B118 (14) | |
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 07000143/2024001
Dear Ronald Dailey:
On March 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Nuclear Fuel Services. On April 9, 2024, 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 April 18, 2024 Signed by Williams, Robert on 04/18/24
R. Dailey 2
SUBJECT:
NUCLEAR FUEL SERVICES - CORE INSPECTION REPORT 07000143/2024001 - DATED APRIL 18, 2024 DISTRIBUTION:
S. Lav, NMSS J. Downs, NMSS O. Siurano, NMSS A. Masters, RII L. Harris, RII L. Cooke, RII S. Price, RII R2EICS ADAMS ACCESSION NUMBER: ML24107B118 OFFICIAL RECORD
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME L. Cooke L. Harris L. Pitts T. Sippel R. Williams DATE 04/17/24 04/17/24 04/17/24 04/17/24 04/18/24
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07000143 License Number:
SNM-124 Report Number:
07000143/2024001 Enterprise Identifier:
I-2024-001-0083 Licensee:
Nuclear Fuel Services, Inc.
Facility:
Nuclear Fuel Services Location:
Erwin, Tennessee Inspection Dates:
January 01, 2024 to March 31, 2024 Inspectors:
L. Cooke, Fuel Facility Inspector L. Harris, Senior Resident Inspector L. Pitts, Sr. Fuel Facility Projects Inspector Approved By:
Robert E. Williams, Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a core inspection at Nuclear Fuel Services (NFS), 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 downblending 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 IP 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees Operational Safety program to verify compliance with selected portions of 10 CFR 70, including 70.24, 70.61, 70.62, and 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 plant changes submitted to the NRC, and past plant performance documentation. For the process areas of interest, the inspectors selected a sample of accident sequences in nuclear criticality safety, radiation safety, fire safety, and chemical safety based on the information provided in the integrated safety analysis (ISA) summary. The inspectors conducted a general plant tour of each major plant operating area. The process areas and accident sequences selected for review are listed below:
110A Lab o
NCS Consequence Analysis for 110A 110B Lab o
NCS Consequence Analysis for 110B o
110-ENV-CHEM-1 110C Lab 110D Lab o
110-ENV-CHEM-2 Occupational Chemical Consequence Summary for 110 Labs
4 Environmental Chemical Consequence Summary for 110 Labs Radiological Safety Consequence Analysis for 110 Labs Fire Safety Consequence Analysis for 110 Labs Review of Safety Controls and Related Programs (IP Section 02.02)
The inspectors reviewed information related to administrative and engineered safety controls or items relied on for safety (IROFS) for the accident sequences selected above, including the identification of the licensees assumptions and bounding cases as they apply to each of the selected accident sequences, safety controls, or IROFS. This review was performed to verify that the controls or IROFS were available and reliable to perform their intended safety functions and that the design basis assumptions were reflected in the actual conditions in the field. The specific safety controls selected for review are listed below:
110A Lab o
110A-10 (Administrative Control for Occupational Chemical) o 110A-11 (Administrative Control for Occupational Chemical) 110 B and D Labs o
FIRE-2 (Administrative Control for Fire Protection) o FIRE-14 (Active Engineered Control for Fire Protection) o FIRE-28 (Administrative Control for Fire Protection)
Implementation of Safety Controls (IP Section 02.03)
For the selected safety controls listed 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 selected safety controls or IROFS were present, available, and reliable to perform their safety function and that the design basis assumptions were reflected in the actual conditions in the field. The inspectors conducted the following activities to verify the implementation of selected safety controls:
walked down 110A, 110B, 110C, and 110D Labs reviewed 110 Labs Radiological Accident Consequence Evaluation, Occupational/Environmental/Chemical Accident Consequence Evaluation, Nuclear Criticality Safety evaluation, and Fire Hazards Analysis assumptions and bounding cases for low consequence events reviewed the Development Lab Special Nuclear Material (SNM) Log reviewed safety related equipment (SRE) tests from 2021 to 2023 for FIRE-14 in Lab 110 B and D reviewed Annual NFS Building 110 Inspection Report by Moody Sprinkler Company reviewed NFS-GH-62 and NFS-GH-62-1 for FIRE-2 reviewed NFS-GH-27 for FIRE-28 reviewed NFS-DC-139 for 110-A-10 and 110A-11 reviewed Process Enclosure Face Air Velocity Reports reviewed monthly combustible control inspections for 110 Labs reviewed air monitoring records for the 110 B Lab in 2023 reviewed breathing zone air sampler records for 110 A Lab from 2018 to 2023
5 Safety Control Support Programs (IP Section 02.04)
The inspectors assessed additional licensees measures that support the availability and reliability of safety controls to verify these were implemented in accordance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors conducted the following:
reviewed NFS-OPS-001 "Conduct of Operations" and NFS-WM-005 "Conduct of Maintenance" to evaluate the general procedural requirements for conducting of Lockout/Tagout evolutions and scope changes to maintenance activities reviewed the status of corrective actions and cause evaluations for the problem identification, resolution, and correction system (PIRCS) entries listed below associated with procedural compliance and lockout/tagout.
o Investigation 33976 o
PIRCS 91626 o
PIRCS 93158 o
PIRCS 93351 o
PIRCS 93396 o
PIRCS 93494 o
PIRCS 98536 o
PIRCS 98695 o
PIRCS 98948 reviewed NFS-GH-928, "Laboratory Chemical Hygiene Plan" reviewed Safety Work Permits for 110 A Lab since 2018 reviewed Standard Operating Procedure 387 for the Development Lab reviewed most recent audits in the 110 Labs reviewed lab hygiene and general safety training reviewed records of training completion for lab staff IP 88135.02 - Plant Status The inspectors routinely conducted walkdowns of licensee areas, observed operators, material control and accounting and security force personnel, inspected postings and licensee guidance documents, interviewed plant personnel, and discussed the results of operational and shift turnover meetings to gain insight into the status of facility activities, risk-inform the selection and implementation of the appropriate core inspection procedures, and ensure compliance with license and regulatory requirements.
Plant Tours (IP Section 03.01)
The inspectors performed weekly tours of plant operating areas housing 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 attended and reviewed the results of licensee meetings on a routine basis to identify the status of plant activities and properly focus NRC inspection resources on activities with the higher safety significance.
6 The inspectors, on a routine basis, attended and reviewed the results of the following scheduled licensee meetings to determine plant status and maintain awareness of site activities so that inspection resources were appropriately focused on those activities with the higher safety significance:
PIRCS Meetings Plan Of the Day Meetings Scheduled meetings with licensing, security, and facility management 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.
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 RWPs (also known as safety work permits or SWPs) listed below to determine whether they contained the information required in Chapter 4, "Radiation Safety," of the license application; the Radiation Protection Manual; and licensee implementing procedures:
SWP 24-12-003 Area 304 SWP 24-14-004 302 - 800 Annual Security and Emergency Preparedness Drills/Exercises (IP Section 03.10)
The inspectors observed the licensees performance during an Emergency Preparedness training exercise listed below to determine they were being implemented in accordance with 10 CFR 70.22(I)(3):
On March 13, 2024, the inspectors observed an emergency response training exercise. The emergency operations center was activated. The scenario
7 involved an accident that required simulated fire brigade response, decontamination of victims, event classification, and simulated offsite notifications.
IP 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 performed walkdowns and evaluated the IROFS listed below associated with the 302 Building processing areas A through C and Building 303 area B.
N302XWOGVNT0A03 N302VALVEBA0A01 N302XDRAINHAA02 N303XPOGVNT0B03 N303XDRAINHBA01 N303VALVEBA0B01 IP 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) standard 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 110 Building and the associated fire safety controls and documents listed below.
Review of fire extinguishers and emergency lights for buildings 110A, B, C, and D Review of fire wall inspection buildings 110 B through D Review of smoke detector testing 110 A, B, and D Review of heat detector testing 110 B and C Review of Duct detector testing 110 B and D Review of combustible control inspections 110 B and D Review of Building 110 sprinkler inspection Fire Brigade Drill Performance Sample (IP Section 03.02)
The inspectors evaluated the fire brigade training during an actual event and drill performance described below:
8 A false fire alarm on February 1, 2024, during which incident evaluation, command, and control, dress-out, and response were observed.
Fire brigade response and participation in an emergency response exercise on March 13, 2024.
IP 88135.17 - Permanent Plant Modifications The inspectors evaluated implementation of the configuration management system for facility changes or modifications to ensure that safety-related systems, structures, and components (i.e., 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.
Management Measures (IP Section 03.02)
The inspectors reviewed the following management measures to ensure that IROFS or other credited safety controls affected by modification activities in areas 200 through 400 of building 303 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:
Area 200:
o N303XCOLUMNB201 o
N303XCOLUMNA201 o
N303VALVEHVB294 and 295 o
N303VALVEHVA294 and 295 o
N303VALVEHVB296 and 297 o
N303VALVEHVA296 and 297 o
N303XDRAINHB201 and A201 Area 300-400:
o N303XXXXPDAA316 and AA318 o
N303XXXXPDAB316 and AB318 IP 88135.19 - Post Maintenance Testing The inspectors evaluated post-maintenance test activities to verify compliance with Chapter 11, Management Measures, of the license application; and test procedures or work orders (WOs) to confirm functional capability of selected IROFS and safety controls following maintenance.
Post-Maintenance Testing (IP Section 03.01)
The inspectors reviewed the post-maintenance tests listed below. The inspectors either observed the tests directly or reviewed test results.
N303XXXXXPIS681 work order 312529 Building 303 N307H2DILXXX800 Building 306-307
9 IP 88135.22 - Surveillance Testing The inspectors evaluated IROFS and safety controls that required periodic surveillance or calibration tests to ensure they were available and reliable to perform their function when needed; to verify compliance with Chapter 11, Management Measures, of the license application, and the 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 building 302 and 333 surveillance tests listed below. Tests were either observed directly or test results were reviewed.
N302PRSLEEVE001 N302PRSLEEVE002 N302PRSLEEVE003 N333OVRFLO1E01A N333OVRFLO1E01B N333OVRFLO1E04A N333OVRFLO1F01A N333OVRFLO1F01B N333OVRFLO1F04A N333OVRFLO1F04B INSPECTION RESULTS No violations of more than minor significance were identified.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On February 15, 2024, the inspectors presented the operational safety (IP 88020) inspection results to Ronald Dailey and other members of the licensee staff.
On April 9, 2024, the inspectors presented the quarterly debrief inspection results to Ronald Dailey and other members of the licensee staff.
10 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date Investigation 33976 Small Team Root Cause Investigation Report for the July 2023, 306 Scrubber Event 10/17/2023 PIRCS 91626 WR 301313 completed and Lockout/Tagout locks were not removed after completion of the work as required by NFS-GH-36-01 02/05/2023 PIRCS 93158 P&IDs component identification does not strictly match the component labels in the plant 07/21/2023 PIRCS 93351 Incorrect circuits were identified on drawings 105-E3053-D
& 303-E3005-D for isolating power to the 105 drum transfer room lighting 08/09/2023 PIRCS 93396 P&ID component identification does not match component labeling associated with WR 308364 08/14/2023 PIRCS 93494 Contrary to the requirements of NFS-WM-005 and NFS-GH-36-01, work was performed outside the scope of the planned work and outside the scope of the approved Lockout/Tagout 08/18/2023 PIRCS 93862 During work for WR 307706 issues were identified with the Lockout/Tagout and the Panel Schedule. All circuits powered by specific breakers were not identified and incorrect breaker types were installed.
09/21/2023 PIRCS 98536 WR 304016 completed and Lockout/Tagout locks were not removed after completion of the work as required by NFS-GH-36-01 12/06/2023 PIRCS 98695 Drawing 306-F0084-D component identification does not strictly match the component labels in the plant 12/20/2023 Corrective Action Documents PIRCS 98948 Inconsistencies in the manner in which components are labeled in the field and on P&IDs is making it difficult to properly identify isolations for Lockout/Tagout 01/23/2024 110 Labs Radiological Accident Consequence Analysis Revision (Rev.) 4 88020 Engineering Evaluations Occupational/Environmental Chemical Accident Consequence Evaluation Rev. 8
11 Inspection Procedure Type Designation Description or Title Revision or Date NCSE of Lab B in Building 110 and Building 131 Lab 08/26/2004 Fire Plans Fire Hazards Analysis Building 110 Rev. 2 Individual Qualifications for Lab Staff 02/13/2024 Development Lab SNM Log 02/13/2024 NFS-GH-62-01 NFS Monthly Combustible Control Inspections 01/01/2023 to 01/01/2024 Report 376 Annual NFS Building 110 Inspection Report by Moody Sprinkler Company 04/26/2023 SA-GEN-SAF-HAZD NFS Lesson Plan for General Safety Hazards Training 11/10/2023 Miscellaneous SA-LAB-HYGIENE NFS Lesson Plan for Laboratory Chemical Hygiene Training 05/07/2014 FM-H-B-44-01 Process Enclosure Face Air Velocity Report 01/04/24, 12/07/23, 11.01/23 N110BXDSPRINKLR IROFS 000 - FIREPREVENT 04/26/2023 N110BXDSPRINKLR IROFS 000 - FIREPREVENT 04/12/2022 Operability Evaluations N110BXDSPRINKLR IROFS 000 - FIREPREVENT 04/12/2021 HFS-HS-A-16 Safety Audits, Assessments, and Inspections Rev. 16 NFS-DC-139 Container Inspection and Repackaging Procedures Rev. 2 NFS-GH-03 Safety Work Permits Rev. 23 NFS-GH-27 Impairments to Fire Protection Systems Rev. 18 NFS-GH-27-01 Applicable Fire System IROFS/RE Rev. 11 NFS-GH-36 Lockout/Tagout - Programmatic Requirements Rev. 18 NFS-GH-36-01 Lockout/Tagout Physical Work Rev. 9 NFS-GH-62 Combustible Controls Rev. 16 NFS-GH-928 Laboratory Chemical Hygiene Plan Rev. 3 NFS-HS-B-44 Process Enclosure Face Air Velocity Measurements Rev. 17 NFS-OPS-001 Conduct of Operations Rev. 21 NFS-WM-005 Conduct of Maintenance Rev. 6 Procedures SOP 387 Development Laboratories Standard Operating Procedure Rev. 12 Radiation Surveys BZA Records for 110A 01/23/2018 to
12 Inspection Procedure Type Designation Description or Title Revision or Date 12/22/2023 REMCon System - Air Monitoring, RMAs Exceeding Weekly Administrative DAC Levels (for 110-RD) 01/2023 to 02/14/2024 REMCon System-Air Monitoring, SAS Count Results Exceeding Administrative DAC Levels (for 110-RD) 01/01/23 to 02/14/24 Radiation Work Permits (RWPs)
WO 1114068 SWP 110-A 05/06/2021 ISA Audit Auxiliary Fire and Chemical IROFS 4Q 2021 ISA Chemical ACE Audit for 110 Laboratories 4Q 2021 ISA Radiological ACE Audit for 110 Laboratories 3Q 2020 Self-Assessments FHA FRE B110 ISA Fire Risk Evaluation Audit for Building 110 2Q 2023 Work Orders Work Package 1114068 SWP 110-A 05/06/2021 PIRCS 100413 PIRCS 100495 PIRCS 98793 PIRCS 98845 PIRCS 98924 PIRCS 98932 Corrective Action Documents PIRCS 99148 FM-SEC-122 Traveler Badge Form Rev. 001 FM-SEC-146 Request For Site Access Rev. 000 NFS-SEC-016 Visitor Access Control Rev. 013 88135.02 Procedures NFS-SEC-077 Control of Vaults and Storage Areas Rev. 014 88135.04 Procedures LOA-HS-E-02 Speaker Audibility Testing N/A