ML24116A284
| ML24116A284 | |
| Person / Time | |
|---|---|
| Site: | BWX Technologies |
| Issue date: | 04/26/2024 |
| From: | Eric Michel NRC/RGN-II/DFFI |
| To: | Bittner J BWXT |
| References | |
| IR 2024001 | |
| Download: ML24116A284 (15) | |
Text
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 07000027/2024001
Dear James J. Bittner:
On March 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at BWXT Nuclear Operations Group, Inc., facility. On April 2, 2024, the NRC inspectors discussed the results of this inspection with Richard Freudenberger 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, 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 April 26, 2024 Signed by Michel, Eric on 04/26/24
SUNSI Review X
Non-Sensitive
Sensitive X
Publicly Available
Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI RII/DFFI RII/DFFI NAME N. Pitoniak M. Doyle N. Peterka C. Oelstrom E. Michel DATE 4/26/2024 4/26/2024 4/26/2024 4/26/2024 4/26/2024
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07000027 License Number:
SNM-42 Report Number:
07000027/2024001 Enterprise Identifier:
I-2024-001-0064 Licensee:
Nuclear Operations Group, Inc.
Facility:
BWXT Nuclear Operations Group, Inc Location:
Lynchburg, VA Inspection Dates:
January 01, 2024 to March 31, 2024 Inspectors:
M. Doyle, Senior Resident Inspector P. Glenn, Fuel Facilities Project Inspector N. Peterka, Sr. Fuel Facility Project Inspector Approved By:
Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection
2
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 Type Issue Number Title Report Section Status NOV 07000027/2023-006-01 Air Gap IROFS Failure 88015 Closed NOV 07000027/2023-006-02 Overflow Drain IROFS Failure 88015 Closed
3 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 licensee's 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, 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 portions of 5.2. Specifically, the inspectors interviewed licensee staff and reviewed the following:
NCS-PA-21-00001, "Waste Treatment Facility Low Level Radioactive Dry Waste Process," Rev. 2, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences NCS-PA-21-00002, "Low Level Radioactive Dry Waste Process," Rev. 3, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences NCS-PA-23-00017, "Nuclear Criticality Safety Evaluation of RTR Box-Type Element Wet Operations, Rev. 0, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences Criticality Implementation (IP Section 02.02)
The inspectors selected engineered and administrative controls from the licensees integrated safety analysis (ISA) summary 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 11.2.
Specifically, the inspectors interviewed licensee staff and reviewed the following controls:
passive and administrative controls associated with the Low Level Radioactive Waste Process in NCS-PA-21-00001, Rev. 2 and NCS-PA-21-00002, Rev. 3
4 active engineered controls for over temperature and overpressure IROFS for the Advanced Test Reactor (ATR) autoclave and associated maintenance work orders administrative piece count and spacing control IROFS for the ATR autoclave, and associated NCS postings and operating procedures Criticality Operational Oversight (IP Section 02.03)
The inspectors assessed the NCS staffs oversight of plant operators, procedures, and operations of systems involving special nuclear material to verify compliance with 10 CFR 70 and applicable sections of the license application including 5.5. Specifically, the inspectors performed the following activities:
reviewed 2023 NCS refresher training provided to operators and supervisors interviewed ATR autoclave and waste treatment and water operations area operators concerning criticality hazards and control methods, including the use of IROFS during operations reviewed training documents and interviewed waste treatment operators and the front-line manager for waste operations interviewed NCS staff concerning criticality hazards and control methods related to waste operations and RTR autoclave operations observed a licensee NCS engineer conduct a weekly audit in the Recovery area involving glovebox operations Criticality Programmatic Oversight (IP Section 02.04)
The inspectors reviewed NCS program procedures, quarterly NCS audit records, and NCS staff qualifications to verify compliance with 10 CFR 70 and applicable sections of the license application including 11.5.1. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following documents:
the most recent revision to licensee procedure QWI 05.1.26, Nuclear Criticality Safety Postings Rev.13 interviewed current NCS engineers in training and reviewed training records for a recently qualified NCS Auditor reviewed select weekly inspection records and interviewed NCS engineers who conducted the inspections Criticality Incident Response and Corrective Action (IP Section 02.05)
The inspectors reviewed the licensees corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application including 11.6. Additionally, the inspectors followed up on notice of violation (NOV) 07000027/2020004-01, "Failure to Meet the Performance Requirements of 10 CFR 70.61(b) for a high consequence event." Specifically, the inspectors reviewed:
recent NCS-related corrective action program entries including how NCS staff verify that resulting actions are completed in accordance with their requirements
5 recent safety concern analyses performed by NCS staff including NCS-2024-013 and NCS-2024-014 NCS Technical reference NCS-TR-00027 for Air Gaps, Siphon Breaks, and Vacuum Traps 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.
Record and Log Reviews (IP Section 03.03)
The inspectors reviewed selected records and logs to assure they were developed, maintained, and reported as required by applicable license and regulatory requirements.
reviewed the nuclear materials control accountability operations monitoring human errors log Posting of Notices (IP Section 03.04)
The inspectors reviewed the following notices to determine if they were posted in accordance with 10 CFR 19.11.
verified the items listed in 10 CFR 19.11 and EA-21-035, notice of violation were posted on regulatory boards 1, 2, 3, and 4.
Radiation Work Permit (RWP) (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 24-0012, relocate blend box in recovery on March 26, 2024 Annual Security and Emergency Preparedness Drills/Exercises (IP Section 03.10)
The inspectors observed the licensees performance during the emergency preparedness exercise/training evolution listed below to determine whether they were being implemented in accordance with 10 CFR 70.32(i):
On March 13, 2024, the inspectors observed an emergency exercise. The exercise simulated an uncontrolled release of radioactivity within the site boundary. The emergency operations center (EOC) was activated, and the scenario exercised a live-fire scenario, decontamination of a contaminated
6 victim and its transport to the local hospital, event classification, and notification of offsite of offsite organization.
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 items relied on for safety (IROFS) to verify compliance with 10 CFR Part 70, the license, the safety analysis report (SAR) and/or license application, and licensee policies and procedures; and determine whether they are appropriate, available, and reliable to protect worker and public safety during normal, off-normal, and accident conditions.
Operations Safety Walkdown (IP Section 03.01)
The inspectors evaluated the operational safety of the systems and sub-systems of the listed processes associated with SAR 15.22, Research Test Reactor and Targets Fuel Powder and Compact Processes, by conducting the following activities:
the inspectors reviewed and walked down management measures and IROFS the inspectors reviewed corrective action documents associated with SAR 15.22 88135.05 - Resident Inspection Program Fire Protection (Annual/Quarterly)
The inspectors evaluated the operational status and material condition of fire protection systems, structures, and components (SSCs) to verify compliance with the fire protection program as described in Chapter 7, Fire Safety of the license application, as required.
Fire Area Walkdown (IP Section 03.01)
The inspectors walked down and evaluated the fire area listed below:
railyard storage building on March 9, 2024 Fire Brigade Drill Performance Sample (IP Section 03.02)
The inspectors evaluated the emergency team response to chemical spills by conducting the following activities:
the inspector performed a review of the emergency team response logs the inspector reviewed air sampling equipment the inspector reviewed the personal protective equipment used by the emergency team during a spill response 88135.19 - Post Maintenance Testing The inspectors evaluated post-maintenance test activities to verify compliance with license application Chapter 11, Management Measures, test procedures and work order (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 two post-maintenance tests listed below. Tests were either observed directly or test results were reviewed.
WO 20359420, "Replace Complex Horizontal Columns," leak test of horizontal complex column IROFS associated with SAR 15.05, "High-Level Dissolution Process in Uranium Recovery," on January 16, 2024, during a recovery outage WO 20359544, "Change Columns," leak test of columns IROFS associated with SAR 15.05 on January 16, 2024, during a recovery outage 88135.22 - Surveillance Testing The inspectors evaluated IROFS and safety controls that required periodic surveillance and/or calibration tests to ensure they were available and reliable to perform their function when needed, to comply with license application Chapter 11, Management Measures, and the performance requirements of 10 CFR 70.61 and 70.62, and to maintain their operational readiness consistent with the Integrated Safety Analysis.
Surveillance and Calibration Testing (IP Section 03.01)
The inspectors reviewed the surveillance test listed below. Tests were either observed directly or test results were reviewed.
SAR 15.12, SC-REC-RMECH-0179, monthly inline #4 interlock test of raffinate collection column transfer pump 30-22
8 INSPECTION RESULTS NOV Air Gap IROFS Failure/Overflow Drain IROFS Failure NOV 07000027/2023-006-01/02 88015
==
Description:==
This violation was opened in NRC integrated inspection report 70-27/2023-007 (ML21029A157). During this inspection, the inspectors reviewed licensee CAP entry Corrective Action (CA) 202300083 which documented licensee short-term and long-term CAs resulting from the violation. The licensee took CAs to immediately shutdown/locked-out the annular organic waste tank and removed the rupture disk from the overflow drain, restoring compliance on January 19, 2023. Additionally, the licensee completed (1) an extent-of-condition review to identify other overflow drains and siphons breaks throughout the facility and implement measures to ensure they are not adversely affected by similar conditions (inadequate design, blockage of overflow drains), (2) revised Quality Work Instruction level guidance to aid in defining acceptance process and hazards identification practices during Safety Evaluation Requests, and (3) providing criteria for completion of post-maintenance testing to verify the functionality of safety related equipment prior to releasing the equipment/process for operation.
Considering this review the inspectors have determined that the licensee has completed their CAs as documented in CA 202300083. These items are closed.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On March 28, 2024, the inspectors presented the nuclear criticality safety inspection results to James Bittner and other members of the licensee staff.
On April 2, 2024, the inspectors presented the integrated inspection results to Richard Freudenberger and other members of the licensee staff.
9 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 88015 Corrective Action Documents CA202300083, CA202301287, CA202300083, CA202400203, CA202400314, CA202300868, CA202400314, CA202400321 NCS-related CAP entries Various 88015 Engineering Evaluations NCS-2023-108 NCS Safety Analysis for SER 23-033 Phase 01, INL/BR2 HEU UALX Fabrication Capacity 01/18/2024 88015 Engineering Evaluations NCS-2024-013 NCS Safety Concerns Analysis for Excess Mass 03/13/2023 88015 Engineering Evaluations NCS-2024-014 NCS Safety Concerns Analysis for Abnormal Interspersed Moderation in Furnace 03/13/2024 88015 Engineering Evaluations NCS-PA 00001 Nuclear Criticality Safety Evaluation of the Waste Treatment Facility Low Level Radioactive Waste Process Rev. 2 88015 Engineering Evaluations NCS-PA 00002 Nuclear Criticality Safety Evaluation of Low Level Radioactive Dry Waste Processes 11/21/2023 88015 Engineering Evaluations NCS-PA 00017 Nuclear Criticality Safety Evaluation of RTR Box-Type Element Wet Operations Rev. 00 88015 Engineering Evaluations NCS-TR-00027 Nuclear Criticality Safety Technical Reference for Air Gaps, Siphon Breaks, and Vacuum Traps Rev. 1 88015 Engineering Evaluations SAR 15.23 Fuel Plate and Element Fabrication Processes RTRT Operation Rev. 123 88015 Miscellaneous 2023 NCS Refresher Training 88015 Miscellaneous Specialized Nuclear Criticality Safety Training Test 88015 Miscellaneous NCS Operator and Front-Line Manager Training Records Various 88015 Miscellaneous NCS-2024-015 NCS Work Record - Qualification of NCS Auditor 03/08/2024 88015 Miscellaneous NCSE-03-03 Form NCS Inspection Form Record - LTC 03/12/2024 88015 Miscellaneous NCSE-03-03 Form NCS Inspection Form Record - LTC, Lab 10/30/2023
10 Inspection Procedure Type Designation Description or Title Revision or Date 88015 Miscellaneous NCSE-03-03 Form NCS Inspection Form Record - Waste Treatment 11/09/2023 88015 Miscellaneous NCSE-03-03 Form NCS Inspection Form Record - SFF 03/12/2024 88015 Procedures NCSE-03 Nuclear Criticality Safety Audits and Inspections Rev. 31 88015 Procedures NCSE-07 Qualification and Training Requirements for an NCS Engineer Rev. 19 88015 Procedures OP-0006115 Operating Procedure for Boehmite Prefilming of ATR Elements Rev. 5 88015 Procedures QWI 05.1.26 Nuclear Criticality Safety Postings Rev. 13 88015 Procedures QWI 4.1.5 Design Criteria for NCR Licensed Activities Rev. 27 88015 Procedures QWI 5.1.38 UPRR Non-Customer/Non-Product Drawing Control System Rev. 05 88015 Procedures QWI 5.1.7 Safety Evaluation Requests Rev. 38 88015 Procedures SC-AUTOCLV-ELECT-001 Autoclave Furnace Overtemperature Alarm and Shutdown Test Electrical Rev. 8 88015 Self-Assessments NCSE-03-03 Audits, Inspections, and Observations Summary - 1st Quarter 2024 02/01/2024 88135.02 Corrective Action Documents CA202400153 NCS - UIR 01/24/2024 88135.02 Corrective Action Documents CA202400203 NCS - UIR 02/02/2024 88135.02 Corrective Action Documents CA202400324 NCS - UIR 02/21/2024 88135.02 Corrective Action Documents CA202400414 records incomplete/incorrect 03/13/2024 88135.02 Corrective Action Documents CA202400429 records incomplete/incorrect 03/15/2024 88135.02 Corrective Action Documents Resulting from Inspection E4-603 nuclear materials control accountability operations, monitoring human errors Rev. 11 88135.02 Engineering Evaluations NCS-2024-003 NCS safety concern CA202400153 02/12/2024 88135.02 Engineering NCS-2024-008 NCS concern CA20240153 02/14/2024
11 Inspection Procedure Type Designation Description or Title Revision or Date Evaluations 88135.02 Procedures E41-129 nuclear materials control operations Rev. 18 88135.02 Radiation Work Permits (RWPs) 24-0012 relocate blend box in recovery Rev. 00 88135.02 Radiation Work Permits (RWPs) 24-0012 relocate blend box in recovery Rev. 00 88135.04 Corrective Action Documents CA202200408 physical environment change management 03/28/2022 88135.04 Corrective Action Documents CA202201275 NCS-UIR 09/26/2022 88135.04 Corrective Action Documents CA202300324 improvement suggestion 03/17/2023 88135.04 Corrective Action Documents CA202300325 improvement suggestion 03/17/2023 88135.04 Corrective Action Documents CA202300326 improvement suggestion 03/17/2023 88135.04 Corrective Action Documents CA202300536 work instructions incomplete/incorrect change management 03/28/2023 88135.04 Corrective Action Documents CA202300761 NCS - UIR 06/18/2023 88135.04 Corrective Action Documents CA202300886 change management 07/20/2023 88135.04 Corrective Action Documents CA202301379 physical environment 11/06/2023 88135.04 Corrective Action Documents CA202301548 RP -UIR 12/13/2023 88135.04 Corrective Action Documents CA202400321 NCS - UIR 02/21/2024 88135.05 Corrective Action Documents Resulting from Inspection CA202400439 physical environment 03/18/2024 88135.05 Drawings HS-2010-072 railyard storage building 04/20/2010 88135.05 Fire Plans Section 38 railyard storage building 06/24/2011
12 Inspection Procedure Type Designation Description or Title Revision or Date 88135.05 Procedures EP-HS-016 personal protective equipment for hazmat response 11/30/2015 88135.05 Procedures EP-HS-017 hazmat incident control & mitigation 11/30/2015 88135.05 Procedures EP-HS-018 decontamination of personnel during hazmat response Rev. 7 88135.05 Procedures EP-HS-022 industrial safety assessment for hazmat response 11/30/2015 88135.05 Procedures EPR-02-01 initial emergency incident assessment 08/07/2015 88135.05 Procedures EPR-03-02 industrial health & safety response to fire/explosion 11/30/2015 88135.05 Procedures EPR-03-20 hazardous material remediation 01/29/2021 88135.19 Work Orders WO 20359420 Replace Complex Horizontal Columns 01/16/2024 88135.19 Work Orders WO 20359544 Change Columns 01/15/2024 88135.22 Procedures CHG-00014727 update SC-REC-RMECH-0179 2/2/2024 88135.22 Work Orders WO 20357843 SC Inline Alarm #4 Test 1mon urpsm b 01/30/2024