ML21298A181: Difference between revisions

From kanterella
Jump to navigation Jump to search
(StriderTol Bot insert)
 
(StriderTol Bot change)
 
(2 intermediate revisions by the same user not shown)
Line 16: Line 16:


=Text=
=Text=
{{#Wiki_filter:October 25, 2021 Mr. Mike Annacone Vice President, Columbia Fuel Operations and Manager, Columbia Plant Westinghouse Electric Company 5801 Bluff Road Hopkins, SC 29061
{{#Wiki_filter:October 25, 2021
 
Mr. Mike Annacone Vice President, Columbia Fuel Operations and Manager, Columbia Plant Westinghouse Electric Company 5801 Bluff Road Hopkins, SC 29061


==SUBJECT:==
==SUBJECT:==
Line 22: Line 24:


==Dear Mr. Annacone:==
==Dear Mr. Annacone:==
On July 29, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Fuel Fabrication Facility. On July 29, 2021, the NRC i nspectors discussed the results of this inspection with you and other members of your staff. Th e results of this inspection are documented in the enclosed report.
No violations of more than minor significance were identified d uring this inspection.


On July 29, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Fuel Fabrication Facility. On July 29, 2021, 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.
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,
Sincerely,
                                              /RA/
 
Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 07001151 License No. SNM-1107
/RA/
 
Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection
 
Docket No. 07001151 License No. SNM-1107


==Enclosure:==
==Enclosure:==
As stated
cc w/ encl: Distribution via LISTSERV
ML21298A181 X SUNSI Review X Non-Sensitive X Publicly Available Sensitive Non-Publicly Available
OFFICE RII/DFFI RII/DFFI RII/DFFI NAME P. Startz T. Sippel E. Michel DATE 10/15/21 10/15/21 10/25/2021
U.S. NUCLEAR REGULATORY COMMISSION Inspection Report
Docket Number: 07001151
License Number: SNM-1107
Report Number: 07001151/2021003
Enterprise Identifier: I-2021-003-0117
Licensee: Westinghouse Electric Company
Facility: Columbia Fuel Fabrication Facility
Location: Hopkins, SC
Inspection Dates: July 26, 2021 to July 29, 2021


As stated cc w/ encl: Distribution via LISTSERV
Inspectors: T. Sippel, Fuel Facility Inspector P. Startz, Fuel Facilities Inspector


ML21298A181 X    Non-Sensitive              X  Publicly Available X    SUNSI Review Sensitive                    Non-Publicly Available OFFICE    RII/DFFI        RII/DFFI              RII/DFFI NAME      P. Startz      T. Sippel            E. Michel DATE      10/15/21        10/15/21              10/25/2021 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:        07001151 License Number:        SNM-1107 Report Number:        07001151/2021003 Enterprise Identifier: I-2021-003-0117 Licensee:              Westinghouse Electric Company Facility:              Columbia Fuel Fabrication Facility Location:              Hopkins, SC Inspection Dates:      July 26, 2021 to July 29, 2021 Inspectors:            T. Sippel, Fuel Facility Inspector P. Startz, Fuel Facilities Inspector Approved By:           Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure
Approved By: Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection
 
Enclosure


==SUMMARY==
==SUMMARY==
The U.S. Nuclear Regulatory Commission (NRC) continued monitori ng the licensees performance by conducting an integrated inspection at Columbia Fuel Fabrication Facility, in accordance with the fuel cycle facility inspection program. Thi s 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 info rmation.


The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Columbia Fuel Fabrication Facility, 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
List of Violations No violations of more than minor significance were identified.
 
Additional Tracking Items None.
No violations of more than minor significance were identified.
2
 
Additional Tracking Items
 
None.
 
2 PLANT STATUS
 
The Westinghouse Facility converts uranium hexafluoride (UF6) i nto uranium dioxide using a wet conversion process and fabricated fuel assemblies for use i n commercial nuclear power reactors. During the inspection period, normal production activ ities were ongoing.
 
INSPECTION SCOPES
 
Inspections were conducted using the appropriate portions of th e inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise note d. Currently approved IPs with their attached revision histories are located on the public web site 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 inspe ction activity were met consistent with Inspection Manual Chapter (IMC) 2600, Fuel Cyc le Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed sel ected procedures and records, observed activities, and interviewed personnel to asse ss licensee performance and compliance with Commission rules and regulations, license condi tions, site procedures, and standards.
 
SAFETY OPERATIONS
 
88015 - Nuclear Criticality Safety
 
The inspectors evaluated selected aspects of the licensees Nuc lear Criticality Safety program to verify compliance with selected portions of 10 CFR 70, inclu ding 70.61, and 70.62, Chapter 6.0, Nuclear Criticality Safety (NCS) Program, of the facilit ys license application, and applicable licensee procedures.


PLANT STATUS The Westinghouse Facility converts uranium hexafluoride (UF6) into uranium dioxide using a wet conversion process and fabricated fuel assemblies for use in commercial nuclear power reactors. During the inspection period, normal production activities were ongoing.
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 program to verify compliance with selected portions of 10 CFR 70, including 70.61, and 70.62, Chapter 6.0, Nuclear Criticality Safety (NCS) Program, of the facilitys license application, and applicable licensee procedures.
Criticality Analysis (IP Section 02.01)
Criticality Analysis (IP Section 02.01)
The inspectors interviewed licensee staff and reviewed nuclear criticality safety evaluations (CSEs), and associated calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including 6.1.1, 6.1.3, 6.1.4, 6.1.5.2, and 6.1.6. Specifically, the inspectors interviewed licensee staff and reviewed CSEs for scrubbers as described below:
* CSE-1-G, "Criticality Safety Evaluation (CSE) for Acid Scrubber S-2A/2B,"
Rev. 13, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences. The inspectors walked down the S2A2B scrubber and other scrubbers that may be exposed to enriched uranium with licensee NCS engineers. The requirements and technical basis for IROFS that were established to prevent criticality accidents.
* CN-CRI-09-11, "S-2A/2B System (With Concrete Walls Near Sump Tanks),"
Rev. 2, which was reviewed because it contained a variety of calculations and information supporting the licensee's evaluation of criticality accident sequences and IROFS in CSE-1-G.
* The inspectors interviewed licensee NCS engineers and the NCS manager about the review, approval, and implementation of CSEs and other NCS documentation. The inspectors interviewed licensee NCS staff about validation and the use of computer codes in the licensee's criticality safety program.
3


Criticality Implementation (IP Section 02.02)
The inspectors interviewed licensee staff and reviewed nuclear criticality safety evaluations (CSEs), and associated calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including 6.1.1, 6.1.3, 6. 1.4, 6.1.5.2, and 6.1.6. Specifically, the inspectors interviewed licensee staff and reviewed CSEs for scrubbers as described below:
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, drawings, plant walkdowns, and operator interviews to verify compliance with 10 CFR 70 and applicable sections of the license application, including, 6.1.2, 6.1.3. Specifically, the inspectors interviewed licensee staff and reviewed the following controls, and their management measures, associated with the CSE listed above:
* CSE-1-G, "Criticality Safety Evaluation (CSE) for Acid Scrubbe r S-2A/2B,"
* IROFS VENT-S2A2B-103, -106, and -122 which are passive IROFS preventing solutions from overflowing/backflowing into unfavorable geometries. The inspectors walked down these controls in the field to verify their presence and condition, and reviewed drawings and maintenance records.
Rev. 13, including the review of what-if analysis, normal, cred ible abnormal, and non-credible accident sequences. The inspectors walked down the S2A2B scrubber and other scrubbers that may be exposed to enric hed uranium with licensee NCS engineers. The requirements and techn ical basis for IROFS that were established to prevent criticality accident s.
* IROFS VENT-S2A2B-116, -117, and -118 which are passive IROFS controlling the credited geometry, absorption, and reflection properties of the scrubber sump. The inspectors walked down these control in the field to verify their presence and condition and reviewed maintenance records.
* CN-CRI-09-11, "S-2A/2B System (With Concrete Walls Near Sump T anks),"
* IROFS ADUSCRA-147 and VENT-S2A2B-131 which are credited as active and passive IROFS to prevent backflow. The inspectors walked down these controls in the field, reviewed drawings and maintenance records.
Rev. 2, which was reviewed because it contained a variety of ca lculations and information supporting the licensee's evaluation of criticality accident sequences and IROFS in CSE-1-G.
* IROFS VENT-S2A2B-107 and -108 which are administrative IROFS to prevent foreign objects from causing blockages in the scrubber. The inspectors walked down portions of these controls and reviewed procedures and maintenance records.
* The inspectors interviewed licensee NCS engineers and the NCS manager about the review, approval, and implementation of CSEs and othe r NCS documentation. The inspectors interviewed licensee NCS staff ab out validation and the use of computer codes in the licensee's crit icality safety program.
* IROFS VENT-S2A2B-109 which is an administrative IROFS to perform a routine inspection and cleanout. The inspectors reviewed maintenance records and condition reports.
 
* IROFS VENT-S2A2B-110 and -124 which are administrative IROFS controlling concentration in the scrubber sump through routine sampling, the inspectors walked down the lab that processes the samples, interviewed lab personnel, and reviewed procedures and sample results.
3 Criticality Implementation (IP Section 02.02)
* IROFS VENT-901 which is an administrative IROFS that limits mass accumulations through routine gamma surveys of selected ductwork; the inspectors also interviewed licensee staff and reviewed applicable procedures, survey records, and related drawings.
 
The inspectors selected engineered and administrative controls from the licensees integrated safety analysis (ISA) summary to verify proper imple mentation through a review of process and system descriptions, drawings, plant walkdowns, and operator interviews to verify compliance with 10 CFR 70 and applicable s ections of the license application, including, 6.1.2, 6.1.3. Specifically, the inspect ors interviewed licensee staff and reviewed the following controls, and their management measu res, associated with the CSE listed above:
* IROFS VENT-S2A2B-103, -106, and -122 which are passive IROFS preventing solutions from overflowing/backflowing into unfavora ble geometries. The inspectors walked down these controls in the fi eld to verify their presence and condition, and reviewed drawings and mainten ance records.
* IROFS VENT-S2A2B-116, -117, and -118 which are passive IROFS controlling the credited geometry, absorption, and reflection p roperties of the scrubber sump. The inspectors walked down these control in the field to verify their presence and condition and reviewed maintenance records.
* IROFS ADUSCRA-147 and VENT-S2A2B-131 which are credited as act ive and passive IROFS to prevent backflow. The inspectors walked do wn these controls in the field, reviewed drawings and maintenance record s.
* IROFS VENT-S2A2B-107 and -108 which are administrative IROFS t o prevent foreign objects from causing blockages in the scrubber. The inspectors walked down portions of these controls and reviewed procedures and maintenance records.
* IROFS VENT-S2A2B-109 which is an administrative IROFS to perfo rm a routine inspection and cleanout. The inspectors reviewed mainte nance records and condition reports.
* IROFS VENT-S2A2B-110 and -124 which are administrative IROFS controlling concentration in the scrubber sump through routine sampling, the inspectors walked down the lab that processes the samples, inte rviewed lab personnel, and reviewed procedures and sample results.
* IROFS VENT-901 which is an administrative IROFS that limits ma ss accumulations through routine gamma surveys of selected ductwor k; the inspectors also interviewed licensee staff and reviewed applica ble procedures, survey records, and related drawings.
 
Criticality Operational Oversight (IP Section 02.03)
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. Specifically, the inspectors performed the following activities:
 
* Reviewed TRN-001-2, "Rad Protection Criticality Safety SSCs Safeguards,"
The inspectors assessed the NCS staffs oversight of plant oper ators, procedures, and operations of systems involving special nuclear material to ver ify compliance with 10 CFR 70 and applicable sections of the license application. Specific ally, the inspectors performed the following activities:
which is NCS training that covers types of controls, IROFS, postings, the double contingency principle, the consequences of a criticality and other NCS topics.
* Reviewed TRN-001-2, "Rad Protection Criticality Safety SSCs Sa feguards,"
which is NCS training that covers types of controls, IROFS, pos tings, the double contingency principle, the consequences of a criticality and other NCS topics.
 
4
4
* Reviewed Criticality & Radiation Safety NSQT, dated September 30, 2020, which is NCS training that covers criticality control parameters, past accidents and other NCS topics.
* Reviewed Criticality & Radiation Safety NSQT, dated September 30, 2020, which is NCS training that covers criticality control parameter s, past accidents and other NCS topics.
* Observed a licensee NCS engineer conduct a weekly Facility Walkthrough Assessment (FWA) in the Scrap Cage area and reviewed the FWA schedule and FWA records for 2021.
* Observed a licensee NCS engineer conduct a weekly Facility Wal kthrough Assessment (FWA) in the Scrap Cage area and reviewed the FWA sc hedule and FWA records for 2021.
 
Criticality Programmatic Oversight (IP Section 02.04)
Criticality Programmatic Oversight (IP Section 02.04)
The inspectors reviewed NCS program procedures, and NCS staff qualification records to verify compliance with 10 CFR 70 and applicable sections of the license application, including 6.1.3.3, and 6.1.10. Specifically, the inspectors interviewed licensee NCS staff, reviewed the following documents, and conducted a walkdown as described below:
 
* COP-815023, "S-2A and S-2B Inspection and Clean Out," Rev. 4, which provides instructions for the periodic inspection and cleanout of the inside of scrubber system components and includes the implementation of IROFS VENT-S2A2B-108, -109, -111.
The inspectors reviewed NCS program procedures, and NCS staff q ualification records to verify compliance with 10 CFR 70 and applicable sect ions of the license application, including 6.1.3.3, and 6.1.10. Specifically, the i nspectors interviewed licensee NCS staff, reviewed the following documents, and conducted a wa lkdown as described below:
* COP-815023, "S-2A and S-2B Inspection and Clean Out," Rev. 4, which provides instructions for the periodic inspection and cleanout of the inside of scrubber system components and includes the implementation of I ROFS VENT-S2A2B-108, -109, -111.
* Various WOs related to the surveying, inspecting, and cleaning ductwork and scrubber systems (e.g., WO 874993).
* Various WOs related to the surveying, inspecting, and cleaning ductwork and scrubber systems (e.g., WO 874993).
* COP-814325, "Scrubbers 2A & 2B," Rev. 31, which includes instructions for taking the IROFS VENT-S2A2B-110 and -124 concentration samples of the scrubber sump water.
* COP-814325, "Scrubbers 2A & 2B," Rev. 31, which includes instr uctions for taking the IROFS VENT-S2A2B-110 and -124 concentration samples of the scrubber sump water.
* RAF-125-5, "Nuclear Criticality Safety Engineer Training Checklist," dated March 30, 2021, which documented the training and qualification of a recently qualified licensee NCS engineer.
* RAF-125-5, "Nuclear Criticality Safety Engineer Training Check list," dated March 30, 2021, which documented the training and qualification of a recently qualified licensee NCS engineer.
* Licensee NCS program procedures, RA-303, RA-305, RA-313, and RA-315 which the licensee recently revised.
* Licensee NCS program procedures, RA-303, RA-305, RA-313, and R A-315 which the licensee recently revised.
* The inspectors also walked down the laboratory where the scrubber sump samples are analyzed for uranium concentration and interviewed lab personnel.
* The inspectors also walked down the laboratory where the scrub ber sump samples are analyzed for uranium concentration and interviewed lab personnel.
 
Criticality Incident Response and Corrective Action (IP Section 02.05)
Criticality Incident Response and Corrective Action (IP Section 02.05)
The inspectors reviewed the licensees criticality accident alarm system (CAAS) and corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application, including 6.1.8. Specifically, the inspectors reviewed documents, and/or interviewed licensee staff concerning the following:
 
The inspectors reviewed the licensees criticality accident ala rm system (CAAS) and corrective action program (CAP) to verify compliance with 10 CF R 70 and applicable sections of the license application, including 6.1.8. Specifica lly, the inspectors reviewed documents, and/or interviewed licensee staff concerning the fol lowing:
* NCS-related corrective action records, including IR-2021-2474, IR-2021-3870, IR-2021-4738, IR-2021-4957, and IR-2021-5048
* NCS-related corrective action records, including IR-2021-2474, IR-2021-3870, IR-2021-4738, IR-2021-4957, and IR-2021-5048
* the evaluation and use of portable criticality detection devices RADIOLOGICAL CONTROLS 86740 - Inspection of Transportation Activities The inspectors evaluated select aspects of the licensees Transportation Activities program to determine whether the licensee has established and is maintaining an effective, management-5
* the evaluation and use of portable criticality detection devic es


controlled program; to ensure radiological and nuclear safety in the receipt, packaging, delivery to a carrier and, as applicable, the private carriage of licensed radioactive materials; and to determine whether transportation activities are in compliance with the applicable Nuclear Regulatory Commission 10 CFR Parts 20 and 71 regulations and Department of Transportation (DOT) (49 CFR Parts 171-178) transport regulations.
RADIOLOGICAL CONTROLS 86740 - Inspection of Transportation Activities
The inspectors examined the licensees procedures and shipment records and observed actual package preparations and operations to verify compliance with the regulations above. Specifically, the inspectors reviewed or observed the following:
 
* receipt contamination surveys, physical inspections, and off-loading of full 30B cylinders from their UX-30s (overpacks) and placement into a UF6 storage yard
The inspectors evaluated select aspects of the licensees Trans portation Activities program to determine whether the licensee has established and is maintaini ng an effective, management-
* inspection/removal of tamper indicating devices (seals) from UX-30 overpacks
 
5 controlled program; to ensure radiological and nuclear safety i n the receipt, packaging, delivery to a carrier and, as applicable, the private carriage of licens ed radioactive materials; and to determine whether transportation activities are in compliance w ith the applicable Nuclear Regulatory Commission 10 CFR Parts 20 and 71 regulations and De partment of Transportation (DOT) (49 CFR Parts 171-178) transport regulations.
 
The inspectors examined the licensees procedures and shipment records and observed actual package preparations and operations to verify compliance with t he regulations above. Specifically, the inspectors reviewed or observed the following:
* receipt contamination surveys, physical inspections, and off-l oading of full 30B cylinders from their UX-30s (overpacks) and placement into a UF6 storage yard
* inspection/removal of tamper indicating devices (seals) from U X-30 overpacks
* removal of the UX-30 overpack lids
* removal of the UX-30 overpack lids
* receipt, inspections, and off-loading of incoming LR-230 uranyl nitrate hexahydrate (UNH) contents
* receipt, inspections, and off-loading of incoming LR-230 urany l nitrate hexahydrate (UNH) contents
* shipment of three truckloads of fuel assembly traveller shipping packages Preparation of Packages for Shipment (IP Section 02.01)
* shipment of three truckloads of fuel assembly traveller shippi ng packages
The inspectors examined the licensees procedures and package preparations to verify compliance with the Chapter 3 of the License Application. Specifically, the inspectors reviewed, verified, and observed the following:
 
* traveller package refurbishment bay including spare parts, procedures, and calibrated tooling
Preparation of Packages for Shipment (IP Section 02.01)
 
The inspectors examined the licensees procedures and package p reparations to verify compliance with the Chapter 3 of the License Application. Speci fically, the inspectors reviewed, verified, and observed the following:
* traveller package refurbishment bay including spare parts, pro cedures, and calibrated tooling
* ongoing preparations of a traveller package
* ongoing preparations of a traveller package
* Nuclear Material Transaction form 741 for Manifest 52-2140933
* Nuclear Material Transaction form 741 for Manifest 52-2140933
* Nuclear Material Transaction form 741 for Manifest WS-53455-0-149
* Nuclear Material Transaction form 741 for Manifest WS-53455 149
* TR-501 Shipment of Liquid Low Enriched Uranium, Rev. 7 Delivery of Completed Packages to Carriers (IP Section 02.02)
* TR-501 Shipment of Liquid Low Enriched Uranium, Rev. 7
The inspectors examined the licensees procedures and shipment records and observed actual transport activities to determine that the licensee met package delivery regulations and Chapter 3 of the License Application. Specifically, the inspectors reviewed or observed the following:
* Shipping Manifest WS-53457-0-001, shipment of LSA-1 waste materials
* Shipping Manifest ISEU (000001-219 through 000023-221), shipment of LSA-1 waste materials
* Shipping Manifest ISEU (000012-229 through 000039-232), shipment of LSA-1 waste materials 6


Receipt of Packages (IP Section 02.03)
Delivery of Completed Packages to Carriers (IP Section 02.02)
The inspectors examined the licensees procedures to verify compliance with 10 CFR 20.1906 and Chapter 3 of the License Application. Specifically, the inspectors reviewed the following:
 
The inspectors examined the licensees procedures and shipment records and observed actual transport activities to determine that the licensee met package delivery regulations and Chapter 3 of the License Application. Specifically, the ins pectors reviewed or observed the following:
* Shipping Manifest WS-53457-0-001, shipment of LSA-1 waste mate rials
* Shipping Manifest ISEU (000001-219 through 000023-221), shipme nt of LSA-1 waste materials
* Shipping Manifest ISEU (000012-229 through 000039-232), shipme nt of LSA-1 waste materials
 
6 Receipt of Packages (IP Section 02.03)
 
The inspectors examined the licensees procedures to verify com pliance with 10 CFR 20.1906 and Chapter 3 of the License Application. Specifically, the inspectors reviewed the following:
* COP-836047, "Uranyl Nitrate Offloading from LR-230 Containers"
* COP-836047, "Uranyl Nitrate Offloading from LR-230 Containers"
* CF-83-239, "LR-230 Offload Checklist"
* CF-83-239, "LR-230 Offload Checklist"
* TR-300, "Unload UF6 Cylinders" Records and Reports (IP Section 02.04)
* TR-300, "Unload UF6 Cylinders"
The inspectors examined the licensees recordkeeping and reports to verify compliance with the regulations above. Specifically, the inspectors reviewed the following:
 
* Certificate of Disposal, Receipt LSA-1 waste for disposal, dated March 3, 2021
Records and Reports (IP Section 02.04)
* Certificate of Disposal, Receipt LSA-1 waste for disposal, dated March 14, 2021 General License Requirements (IP Section 02.05)
 
The inspectors reviewed licensee package certifications utilized for shipment of radioactive material packages to verify compliance with 10 CFR 71, Subpart C, and Chapter 3 of the License Application. Specifically, the inspectors reviewed:
The inspectors examined the licensees recordkeeping and report s to verify compliance with the regulations above. Specifically, the inspectors reviewed th e following:
* Certificate of Disposal, Receipt LSA-1 waste for disposal, dat ed March 3, 2021
* Certificate of Disposal, Receipt LSA-1 waste for disposal, dat ed March 14, 2021
 
General License Requirements (IP Section 02.05)
 
The inspectors reviewed licensee package certifications utilize d for shipment of radioactive material packages to verify compliance with 10 CFR 71, Subpart C, and Chapter 3 of the License Application. Specifically, the inspectors reviewed:
* Certificate of Compliance No. 9291 for the LR-230 container
* Certificate of Compliance No. 9291 for the LR-230 container
* Model UX-30 Certification Type B (U) F Fissile Package Design Certificate USA/9196/B (U) F-96, Rev. 34
* Model UX-30 Certification Type B (U) F Fissile Package Design Certificate USA/9196/B (U) F-96, Rev. 34
* Model 30B Certification Type AF Fissile Package Design Certificate USA/0411/AF-96, Rev. 12 Management Controls (IP Section 02.06)
* Model 30B Certification Type AF Fissile Package Design Certifi cate USA/0411/AF-96, Rev. 12
The inspectors reviewed management controls for transportation activities to verify compliance with Chapter 3 of the License Application. Specifically, the inspectors reviewed:
* COLUMN MC&A Software Guide, Form 741, Domestic UF6 Gas Receipts
* LCTP-20-06, "Management Assessment of the LR-230 Packaging," Rev. 0, dated December 21, 2020
* LCPT-21-02, "Management Assessment of the Traveller Packaging," Rev. 0, dated March 30, 21
* LCTP-21-04,"Management assessment of UF6 incident during transport,"
Rev. 0, dated June 2, 2021 Indoctrination and Training Program (IP Section 02.07)
The inspectors conducted interviews, reviewed training, and indoctrination documentation, and observed activities for shipping container engineering staff involved in transport 7


activities to verify compliance with Chapter 3 of the License Application. Specifically, the inspectors:
Management Controls (IP Section 02.06)
* reviewed ESH-015 DOT Radioactive Materials training records, classroom training required every three years, for employees 4889 and 30696 Quality Assurance Program (IP Section 02.08)
 
The inspectors reviewed the quality assurance documents to verify compliance with 10 CFR 71.137 and Chapter 3 of the License Application. Specifically, the inspectors reviewed:
The inspectors reviewed management controls for transportation activities to verify compliance with Chapter 3 of the License Application. Specifica lly, the inspectors reviewed:
* COP-831010, "Shipping Low Level Radioactive Waste," Rev. 33, dated May 14, 2020
* COLUMN MC&A Software Guide, Form 741, Domestic UF6 Gas Receipt s
* LCTP-20-06, "Management Assessment of the LR-230 Packaging," R ev. 0, dated December 21, 2020
* LCPT-21-02, "Management Assessment of the Traveller Packaging, " Rev. 0, dated March 30, 21
* LCTP-21-04,"Management assessment of UF6 incident during trans port,"
Rev. 0, dated June 2, 2021
 
Indoctrination and Training Program (IP Section 02.07)
 
The inspectors conducted interviews, reviewed training, and ind octrination documentation, and observed activities for shipping container engineering staf f involved in transport
 
7 activities to verify compliance with Chapter 3 of the License A pplication. Specifically, the inspectors:
* reviewed ESH-015 DOT Radioactive Materials training records, c lassroom training required every three years, for employees 4889 and 30696
 
Quality Assurance Program (IP Section 02.08)
 
The inspectors reviewed the quality assurance documents to veri fy compliance with 10 CFR 71.137 and Chapter 3 of the License Application. Specifically, the inspectors reviewed:
* COP-831010, "Shipping Low Level Radioactive Waste," Rev. 33, d ated May 14, 2020
* LCPT-21-02, "Nuclear Fuel Transport assessment"
* LCPT-21-02, "Nuclear Fuel Transport assessment"
* LCPT-20-06, "Management assessment of the LR-230 packaging" Audit Program (IP Section 02.09)
* LCPT-20-06, "Management assessment of the LR-230 packaging"
The inspectors reviewed the assessment reports to verify compliance with 10 CFR 71.137 and Chapter 11 of the license. Specifically, the inspectors reviewed:
 
* LCPT- 21-04, Management assessment of UF6 incident during transport
Audit Program (IP Section 02.09)
 
The inspectors reviewed the assessment reports to verify compli ance with 10 CFR 71.137 and Chapter 11 of the license. Specifically, the inspectors rev iewed:
* LCPT-21-04, Management assessment of UF6 incident during tran sport
* Incident Report 2020-4142
* Incident Report 2020-4142
* Incident Report 2020-11489 Procurement and Selection of Packagings (IP Section 02.10)
* Incident Report 2020-11489
The inspectors examined the licensees recent purchase of new Traveller packages to verify compliance with the federal regulations above. Specifically, for packaging that is used by the licensee to transport or to deliver licensed material to a carrier for transport, the inspectors reviewed the following:
 
* Drawing 10043E83, sheet 1, "Traveller STD Upgrade General Assembly,"
Procurement and Selection of Packagings (IP Section 02.10)
 
The inspectors examined the licensees recent purchase of new T raveller packages to verify compliance with the federal regulations above. Specifically, fo r packaging that is used by the licensee to transport or to deliver licensed material to a carr ier for transport, the inspectors reviewed the following:
* Drawing 10043E83, sheet 1, "Traveller STD Upgrade General Asse mbly,"
Rev. 8, dated November 5, 2019
Rev. 8, dated November 5, 2019
* Sketch 938603-22, "Traveller Shipping Container," Rev. 11, issued August 10, 2017 Preparation of Packages for Shipment (IP Section 02.11)
* Sketch 938603-22, "Traveller Shipping Container," Rev. 11, iss ued August 10, 2017
The inspectors examined the licensees package markings and documentation to verify compliance with applicable parts of the federal regulations above. Specifically, the inspectors reviewed:
 
* MOP-500153, "Pack and Unpack Fuel Assembly - traveler package," Rev. 3, dated July 30, 2020
Preparation of Packages for Shipment (IP Section 02.11)
* MOP-730753, "Pack Fuel Assembly - traveler package," Rev. 54, dated May 13, 2021 8
 
The inspectors examined the licensees package markings and doc umentation to verify compliance with applicable parts of the federal regulations abo ve. Specifically, the inspectors reviewed:
* MOP-500153, "Pack and Unpack Fuel Assembly - traveler package, " Rev. 3, dated July 30, 2020
* MOP-730753, "Pack Fuel Assembly - traveler package," Rev. 54, dated May 13, 2021
 
8 Periodic Maintenance of Packagings (IP Section 02.12)


Periodic Maintenance of Packagings (IP Section 02.12)
The inspectors examined the licensees procedures and ongoing r efurbishment activities to verify compliance with applicable parts of the federal regulati ons above. Specifically, the inspectors reviewed the following:
The inspectors examined the licensees procedures and ongoing refurbishment activities to verify compliance with applicable parts of the federal regulations above. Specifically, the inspectors reviewed the following:
* Drawing 10043E83, sheet 1, "Traveller STD Upgrade General Asse mbly,"
* Drawing 10043E83, sheet 1, "Traveller STD Upgrade General Assembly,"
Rev. 8, dated November 5, 2019
Rev. 8, dated November 5, 2019
* Traveller Refurbishment Verification Checklist, Package Serial Number TX-200, completed June 12, 2021
* Traveller Refurbishment Verification Checklist, Package Serial Number TX-200, completed June 12, 2021
* TR-229, "Traveller Recertification," Rev. 2, dated June 21, 2021 Records, Reports, and Notifications (IP Section 02.13)
* TR-229, "Traveller Recertification," Rev. 2, dated June 21, 20 21
The inspectors reviewed the licensees records and procedures for recordkeeping and reports to verify that a system is in place to verify compliance with the federal regulations above. Specifically, the inspectors reviewed the following:
 
Records, Reports, and Notifications (IP Section 02.13)
 
The inspectors reviewed the licensees records and procedures f or recordkeeping and reports to verify that a system is in place to verify complianc e with the federal regulations above. Specifically, the inspectors reviewed the following:
* 938603-22, "Traveller Shipping Container Checklist"
* 938603-22, "Traveller Shipping Container Checklist"
* Licensee Investigation Report 2020-13034, "LR-230 discovered package defect," dated November 12, 2020
* Licensee Investigation Report 2020-13034, "LR-230 discovered p ackage defect," dated November 12, 2020
* Licensee Investigation Report 2020-4142, "LR-230 tamper seal discovered to be improperly applied," dated March 26, 2020
* Licensee Investigation Report 2020-4142, "LR-230 tamper seal d iscovered to be improperly applied," dated March 26, 2020
* Licensee Investigation Report 2021-1944, "MCC container discovered cracked during preparation for loading," dated February 16, 2021 INSPECTION RESULTS No issues were identified.
* Licensee Investigation Report 2021-1944, "MCC container discov ered cracked during preparation for loading," dated February 16, 202 1
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
 
* On July 29, 2021, the inspectors presented the integrated inspection results to Mike Annacone and other members of the licensee staff.
INSPECTION RESULTS
9
 
No issues were identified.


DOCUMENTS REVIEWED Inspection Type              Designation      Description or Title                                        Revision or Procedure                                                                                                  Date 86740      Drawings          Drawing          Traveller STD Upgrade General Assembly                      Rev. 8 10043E83, sheet 1 of 3 Miscellaneous    ESH-015          DOT Radioactive Materials (classroom training), three years, 11/9/2020 completions for #30696 and 4889 on 11/9/2020 Procedures        Form 741          COLUMN MC&A Software Guide for Form 741, Domestic UF6 Gas Receipts CF-83-239        Offload Checklist                                            Rev. 5 COP-831010        Shipping Low Level Radioactive Waste                        Rev. 33 COP-836047        Uranyl Nitrate Offloading from LR-230 Containers            Rev. 22 MOP-730753        Pack Fuel Assembly - traveler package                        Rev. 54 NOP-500153        Pack and Unpack Fuel Assembly - traveler package            Rev. 3 Sketch 938603-    Traveller Shipping Container Inspection Checklist            Rev. 11 22                Assessment, Management assessment of the LR-230 packaging, performed 12/21/2020 TR-224            Refurbish Traveller Shipping Package                        Rev. 23 TR-229            Traveller Recertification                                    Rev. 2 Traveller        Package Serial Number TX-200, completed 6/12/2021            6/12/2021 Refurbishment Verification Checklist 88015      Corrective Action IR-2021-2474, IR- A sample of various NCS related corrective action records.
EXIT MEETINGS AND DEBRIEFS
Documents        2021-3870, IR-2021-4738, IR-2021-4739, IR-2021-4957, IR-2021-5048, IR-2021-5141, IR-2021-5481, IR-2021-7327 Drawings          313F01HV07        Process Ventilation System Scrubbers S-2A/2B Isometric      Rev. 9 Sheet 01 10


Inspection Type            Designation    Description or Title                                            Revision or Procedure                                                                                                  Date 313F01PI01    Piping Flow Diagram - Scrubbers S-2A & S-2B                    Rev. 18 Sheet 01 313F01PI02    Process Ventilation Flow Diagram Scrubbers S-2A & S-2B          Rev. 25 Sheet 03 313F01PI02    Process Ventilation Filters 1A and 1B P&ID                      Rev. 18 Sheet 04 Engineering      NSA-TR-08-27  Using Electronic Dosimeters as Alarming Personal Criticality    12/2/08 Evaluations                    Detectors at Westinghouse Facilities Miscellaneous                  2021 FWA Schedule Criticality & Radiation Safety NSQT                            9/30/20 PSEDoc-0004972 Results from startup testing for FN-962 for CCF 17-493          Rev. 0 PSEDoc-0005351 Results from startup testing of FN-961 for CCF 17-531          Rev. 0 TRN-001-2      Rad Protection Criticality Safety SSCs Safeguards Procedures      CA-220        Safety Basis Qualification Training                            Rev. 12 CAP-815023    S-2A and S-2B Inspection and Clean Out                          Rev. 4 CN-CRI-003    NCS Manual                                                      Rev. 3 COCL-M14      Use of Agilent 7800 for TMI and PPM U Analysis                  Rev. 4 COP-814325    Scrubbers 2A & 2B                                              Rev. 31 RA-303        Controls of Moderating Materials for Nuclear Criticality Safety Rev. 19 RA-305        Nuclear Criticality Safety Computer Code Validation            Rev. 11 RA-313        Criticality Safety Evaluations (CSEs)                          Rev. 16 RA-314        Implementation of Criticality Safety Evaluations                Rev. 20 Radiation        ROF-05-062-7,  Ventilations Systems Equipment Radiation Survey Monthly -      6/21/21, Surveys          ROF-05-062-7,  S-1030 Survey,                                                  7/23/21, ROF-05-062-8,  Ventilations Systems Equipment Radiation Survey Monthly -      6/21/21, ROF-05-062-8,  S-1030 Survey,                                                  7/23/21, ROF-05-062-11  Ventilations Systems Equipment Radiation Survey Monthly -      6/6/21 S-2A/2B Survey, Ventilations Systems Equipment Radiation Survey Monthly -
The inspectors verified no proprietary information was retained or documented in this report.
S-2A/2B Survey, Ventilations Systems Equipment Radiation Survey Quarterly
* On July 29, 2021, the inspectors presented the integrated insp ection results to Mike Annacone and other members of the licensee staff.
                                          - S-958 Survey Self-Assessments RAF-316-1      Various Nuclear Criticality Safety Checklist for NCS Facility  Various Walkthrough Assessments for various areas in the first and      Dates 11


Inspection Type        Designation Description or Title                                      Revision or Procedure                                                                                    Date second quarter of 2021 Work Orders 38975      52 Week OM81233 SI-Safety, S2A/2B Vacuum Breaks and      Completed Overflow Piping                                          4/30/21 38976      52 Weeks OM818809 SI-Safety, S2A and S2B Scrubbers        Completed Cleaning and Inspection                                  4/20/21 39160      52 Weeks PM81151 SI-Safety, Spring to Close Air Blowdown  Completed Valve Replacement on S2A2B Bag Filters                    4/19/21 4507        52 Weeks PM81155 SI-Safety, S2A2B Bag Filter Blowdown    Completed Back Flow Preventer Ball Valve Leak Check                9/25/20 47230      13 Weeks OM91115 SI-Safety - Gamma Surveys of            Completed Ventilation Systems                                      6//9/21 47341      13 Weeks OM81262 SI-Safety, S2A/2B Filter Instrument Air  Completed Spring Return Valves                                      6/23/21 49609      4 Weeks (Monthly) OM81806 SI-Safety, S2A and S2B          Completed Uranium Concentration Samples                            7/2/21 54052      4 Weeks (Monthly) OM91009 SI-Safety, HP Ventilation      Completed Survey                                                    7/23/21 WO 874988  OM81233 SI-Safety, S2A/2B Vacuum Breaks and Overflow      Completed Piping - 52 Weeks OM                                      4/27/20 WO 874992  OM 818809 SI-Safety, S2A and S2B Scrubbers Cleaning      Completed and Inspection - 52 Week OM                              4/27/20 WO 891490  SI-Safety, Instrument Air Shut-Off Valve for Air to S2A2B Bag Filter Blowdowns - 52 Week OM 12}}
9}}

Latest revision as of 15:52, 19 November 2024

Fuel Fabrication Facility Integrated Inspection Report 07001151/2021003
ML21298A181
Person / Time
Site: Westinghouse
Issue date: 10/25/2021
From: Eric Michel
Division of Nuclear Materials Safety II
To: Annacone M
Westinghouse
References
IR 2021003
Download: ML21298A181 (14)


Text

October 25, 2021

Mr. Mike Annacone Vice President, Columbia Fuel Operations and Manager, Columbia Plant Westinghouse Electric Company 5801 Bluff Road Hopkins, SC 29061

SUBJECT:

COLUMBIA FUEL FABRICATION FACILITY - INTEGRATED INSPECTION REPORT 07001151/2021003

Dear Mr. Annacone:

On July 29, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Fuel Fabrication Facility. On July 29, 2021, the NRC i nspectors discussed the results of this inspection with you and other members of your staff. Th e results of this inspection are documented in the enclosed report.

No violations of more than minor significance were identified d uring 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,

/RA/

Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection

Docket No. 07001151 License No. SNM-1107

Enclosure:

As stated

cc w/ encl: Distribution via LISTSERV

ML21298A181 X SUNSI Review X Non-Sensitive X Publicly Available Sensitive Non-Publicly Available

OFFICE RII/DFFI RII/DFFI RII/DFFI NAME P. Startz T. Sippel E. Michel DATE 10/15/21 10/15/21 10/25/2021

U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Number: 07001151

License Number: SNM-1107

Report Number: 07001151/2021003

Enterprise Identifier: I-2021-003-0117

Licensee: Westinghouse Electric Company

Facility: Columbia Fuel Fabrication Facility

Location: Hopkins, SC

Inspection Dates: July 26, 2021 to July 29, 2021

Inspectors: T. Sippel, Fuel Facility Inspector P. Startz, Fuel Facilities Inspector

Approved By: Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitori ng the licensees performance by conducting an integrated inspection at Columbia Fuel Fabrication Facility, in accordance with the fuel cycle facility inspection program. Thi s 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 info rmation.

List of Violations

No violations of more than minor significance were identified.

Additional Tracking Items

None.

2 PLANT STATUS

The Westinghouse Facility converts uranium hexafluoride (UF6) i nto uranium dioxide using a wet conversion process and fabricated fuel assemblies for use i n commercial nuclear power reactors. During the inspection period, normal production activ ities were ongoing.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of th e inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise note d. Currently approved IPs with their attached revision histories are located on the public web site 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 inspe ction activity were met consistent with Inspection Manual Chapter (IMC) 2600, Fuel Cyc le Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed sel ected procedures and records, observed activities, and interviewed personnel to asse ss licensee performance and compliance with Commission rules and regulations, license condi tions, site procedures, and standards.

SAFETY OPERATIONS

88015 - Nuclear Criticality Safety

The inspectors evaluated selected aspects of the licensees Nuc lear Criticality Safety program to verify compliance with selected portions of 10 CFR 70, inclu ding 70.61, and 70.62, Chapter 6.0, Nuclear Criticality Safety (NCS) Program, of the facilit ys license application, and applicable licensee procedures.

Criticality Analysis (IP Section 02.01)

The inspectors interviewed licensee staff and reviewed nuclear criticality safety evaluations (CSEs), and associated calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including 6.1.1, 6.1.3, 6. 1.4, 6.1.5.2, and 6.1.6. Specifically, the inspectors interviewed licensee staff and reviewed CSEs for scrubbers as described below:

  • CSE-1-G, "Criticality Safety Evaluation (CSE) for Acid Scrubbe r S-2A/2B,"

Rev. 13, including the review of what-if analysis, normal, cred ible abnormal, and non-credible accident sequences. The inspectors walked down the S2A2B scrubber and other scrubbers that may be exposed to enric hed uranium with licensee NCS engineers. The requirements and techn ical basis for IROFS that were established to prevent criticality accident s.

  • CN-CRI-09-11, "S-2A/2B System (With Concrete Walls Near Sump T anks),"

Rev. 2, which was reviewed because it contained a variety of ca lculations and information supporting the licensee's evaluation of criticality accident sequences and IROFS in CSE-1-G.

  • The inspectors interviewed licensee NCS engineers and the NCS manager about the review, approval, and implementation of CSEs and othe r NCS documentation. The inspectors interviewed licensee NCS staff ab out validation and the use of computer codes in the licensee's crit icality safety program.

3 Criticality Implementation (IP Section 02.02)

The inspectors selected engineered and administrative controls from the licensees integrated safety analysis (ISA) summary to verify proper imple mentation through a review of process and system descriptions, drawings, plant walkdowns, and operator interviews to verify compliance with 10 CFR 70 and applicable s ections of the license application, including, 6.1.2, 6.1.3. Specifically, the inspect ors interviewed licensee staff and reviewed the following controls, and their management measu res, associated with the CSE listed above:

  • IROFS VENT-S2A2B-103, -106, and -122 which are passive IROFS preventing solutions from overflowing/backflowing into unfavora ble geometries. The inspectors walked down these controls in the fi eld to verify their presence and condition, and reviewed drawings and mainten ance records.
  • IROFS VENT-S2A2B-116, -117, and -118 which are passive IROFS controlling the credited geometry, absorption, and reflection p roperties of the scrubber sump. The inspectors walked down these control in the field to verify their presence and condition and reviewed maintenance records.
  • IROFS ADUSCRA-147 and VENT-S2A2B-131 which are credited as act ive and passive IROFS to prevent backflow. The inspectors walked do wn these controls in the field, reviewed drawings and maintenance record s.
  • IROFS VENT-S2A2B-107 and -108 which are administrative IROFS t o prevent foreign objects from causing blockages in the scrubber. The inspectors walked down portions of these controls and reviewed procedures and maintenance records.
  • IROFS VENT-S2A2B-109 which is an administrative IROFS to perfo rm a routine inspection and cleanout. The inspectors reviewed mainte nance records and condition reports.
  • IROFS VENT-S2A2B-110 and -124 which are administrative IROFS controlling concentration in the scrubber sump through routine sampling, the inspectors walked down the lab that processes the samples, inte rviewed lab personnel, and reviewed procedures and sample results.
  • IROFS VENT-901 which is an administrative IROFS that limits ma ss accumulations through routine gamma surveys of selected ductwor k; the inspectors also interviewed licensee staff and reviewed applica ble procedures, survey records, and related drawings.

Criticality Operational Oversight (IP Section 02.03)

The inspectors assessed the NCS staffs oversight of plant oper ators, procedures, and operations of systems involving special nuclear material to ver ify compliance with 10 CFR 70 and applicable sections of the license application. Specific ally, the inspectors performed the following activities:

  • Reviewed TRN-001-2, "Rad Protection Criticality Safety SSCs Sa feguards,"

which is NCS training that covers types of controls, IROFS, pos tings, the double contingency principle, the consequences of a criticality and other NCS topics.

4

  • Reviewed Criticality & Radiation Safety NSQT, dated September 30, 2020, which is NCS training that covers criticality control parameter s, past accidents and other NCS topics.
  • Observed a licensee NCS engineer conduct a weekly Facility Wal kthrough Assessment (FWA) in the Scrap Cage area and reviewed the FWA sc hedule and FWA records for 2021.

Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures, and NCS staff q ualification records to verify compliance with 10 CFR 70 and applicable sect ions of the license application, including 6.1.3.3, and 6.1.10. Specifically, the i nspectors interviewed licensee NCS staff, reviewed the following documents, and conducted a wa lkdown as described below:

  • COP-815023, "S-2A and S-2B Inspection and Clean Out," Rev. 4, which provides instructions for the periodic inspection and cleanout of the inside of scrubber system components and includes the implementation of I ROFS VENT-S2A2B-108, -109, -111.
  • Various WOs related to the surveying, inspecting, and cleaning ductwork and scrubber systems (e.g., WO 874993).
  • COP-814325, "Scrubbers 2A & 2B," Rev. 31, which includes instr uctions for taking the IROFS VENT-S2A2B-110 and -124 concentration samples of the scrubber sump water.
  • RAF-125-5, "Nuclear Criticality Safety Engineer Training Check list," dated March 30, 2021, which documented the training and qualification of a recently qualified licensee NCS engineer.
  • Licensee NCS program procedures, RA-303, RA-305, RA-313, and R A-315 which the licensee recently revised.
  • The inspectors also walked down the laboratory where the scrub ber sump samples are analyzed for uranium concentration and interviewed lab personnel.

Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees criticality accident ala rm system (CAAS) and corrective action program (CAP) to verify compliance with 10 CF R 70 and applicable sections of the license application, including 6.1.8. Specifica lly, the inspectors reviewed documents, and/or interviewed licensee staff concerning the fol lowing:

  • NCS-related corrective action records, including IR-2021-2474, IR-2021-3870, IR-2021-4738, IR-2021-4957, and IR-2021-5048
  • the evaluation and use of portable criticality detection devic es

RADIOLOGICAL CONTROLS 86740 - Inspection of Transportation Activities

The inspectors evaluated select aspects of the licensees Trans portation Activities program to determine whether the licensee has established and is maintaini ng an effective, management-

5 controlled program; to ensure radiological and nuclear safety i n the receipt, packaging, delivery to a carrier and, as applicable, the private carriage of licens ed radioactive materials; and to determine whether transportation activities are in compliance w ith the applicable Nuclear Regulatory Commission 10 CFR Parts 20 and 71 regulations and De partment of Transportation (DOT) (49 CFR Parts 171-178) transport regulations.

The inspectors examined the licensees procedures and shipment records and observed actual package preparations and operations to verify compliance with t he regulations above. Specifically, the inspectors reviewed or observed the following:

  • receipt contamination surveys, physical inspections, and off-l oading of full 30B cylinders from their UX-30s (overpacks) and placement into a UF6 storage yard
  • inspection/removal of tamper indicating devices (seals) from U X-30 overpacks
  • removal of the UX-30 overpack lids
  • receipt, inspections, and off-loading of incoming LR-230 urany l nitrate hexahydrate (UNH) contents
  • shipment of three truckloads of fuel assembly traveller shippi ng packages

Preparation of Packages for Shipment (IP Section 02.01)

The inspectors examined the licensees procedures and package p reparations to verify compliance with the Chapter 3 of the License Application. Speci fically, the inspectors reviewed, verified, and observed the following:

  • traveller package refurbishment bay including spare parts, pro cedures, and calibrated tooling
  • ongoing preparations of a traveller package
  • Nuclear Material Transaction form 741 for Manifest 52-2140933
  • Nuclear Material Transaction form 741 for Manifest WS-53455 149
  • TR-501 Shipment of Liquid Low Enriched Uranium, Rev. 7

Delivery of Completed Packages to Carriers (IP Section 02.02)

The inspectors examined the licensees procedures and shipment records and observed actual transport activities to determine that the licensee met package delivery regulations and Chapter 3 of the License Application. Specifically, the ins pectors reviewed or observed the following:

  • Shipping Manifest WS-53457-0-001, shipment of LSA-1 waste mate rials
  • Shipping Manifest ISEU (000001-219 through 000023-221), shipme nt of LSA-1 waste materials
  • Shipping Manifest ISEU (000012-229 through 000039-232), shipme nt of LSA-1 waste materials

6 Receipt of Packages (IP Section 02.03)

The inspectors examined the licensees procedures to verify com pliance with 10 CFR 20.1906 and Chapter 3 of the License Application. Specifically, the inspectors reviewed the following:

  • COP-836047, "Uranyl Nitrate Offloading from LR-230 Containers"
  • CF-83-239, "LR-230 Offload Checklist"
  • TR-300, "Unload UF6 Cylinders"

Records and Reports (IP Section 02.04)

The inspectors examined the licensees recordkeeping and report s to verify compliance with the regulations above. Specifically, the inspectors reviewed th e following:

  • Certificate of Disposal, Receipt LSA-1 waste for disposal, dat ed March 3, 2021
  • Certificate of Disposal, Receipt LSA-1 waste for disposal, dat ed March 14, 2021

General License Requirements (IP Section 02.05)

The inspectors reviewed licensee package certifications utilize d for shipment of radioactive material packages to verify compliance with 10 CFR 71, Subpart C, and Chapter 3 of the License Application. Specifically, the inspectors reviewed:

  • Certificate of Compliance No. 9291 for the LR-230 container
  • Model UX-30 Certification Type B (U) F Fissile Package Design Certificate USA/9196/B (U) F-96, Rev. 34
  • Model 30B Certification Type AF Fissile Package Design Certifi cate USA/0411/AF-96, Rev. 12

Management Controls (IP Section 02.06)

The inspectors reviewed management controls for transportation activities to verify compliance with Chapter 3 of the License Application. Specifica lly, the inspectors reviewed:

  • COLUMN MC&A Software Guide, Form 741, Domestic UF6 Gas Receipt s
  • LCTP-20-06, "Management Assessment of the LR-230 Packaging," R ev. 0, dated December 21, 2020
  • LCPT-21-02, "Management Assessment of the Traveller Packaging, " Rev. 0, dated March 30, 21
  • LCTP-21-04,"Management assessment of UF6 incident during trans port,"

Rev. 0, dated June 2, 2021

Indoctrination and Training Program (IP Section 02.07)

The inspectors conducted interviews, reviewed training, and ind octrination documentation, and observed activities for shipping container engineering staf f involved in transport

7 activities to verify compliance with Chapter 3 of the License A pplication. Specifically, the inspectors:

  • reviewed ESH-015 DOT Radioactive Materials training records, c lassroom training required every three years, for employees 4889 and 30696

Quality Assurance Program (IP Section 02.08)

The inspectors reviewed the quality assurance documents to veri fy compliance with 10 CFR 71.137 and Chapter 3 of the License Application. Specifically, the inspectors reviewed:

  • COP-831010, "Shipping Low Level Radioactive Waste," Rev. 33, d ated May 14, 2020
  • LCPT-21-02, "Nuclear Fuel Transport assessment"
  • LCPT-20-06, "Management assessment of the LR-230 packaging"

Audit Program (IP Section 02.09)

The inspectors reviewed the assessment reports to verify compli ance with 10 CFR 71.137 and Chapter 11 of the license. Specifically, the inspectors rev iewed:

  • LCPT-21-04, Management assessment of UF6 incident during tran sport
  • Incident Report 2020-4142
  • Incident Report 2020-11489

Procurement and Selection of Packagings (IP Section 02.10)

The inspectors examined the licensees recent purchase of new T raveller packages to verify compliance with the federal regulations above. Specifically, fo r packaging that is used by the licensee to transport or to deliver licensed material to a carr ier for transport, the inspectors reviewed the following:

  • Drawing 10043E83, sheet 1, "Traveller STD Upgrade General Asse mbly,"

Rev. 8, dated November 5, 2019

  • Sketch 938603-22, "Traveller Shipping Container," Rev. 11, iss ued August 10, 2017

Preparation of Packages for Shipment (IP Section 02.11)

The inspectors examined the licensees package markings and doc umentation to verify compliance with applicable parts of the federal regulations abo ve. Specifically, the inspectors reviewed:

  • MOP-500153, "Pack and Unpack Fuel Assembly - traveler package, " Rev. 3, dated July 30, 2020
  • MOP-730753, "Pack Fuel Assembly - traveler package," Rev. 54, dated May 13, 2021

8 Periodic Maintenance of Packagings (IP Section 02.12)

The inspectors examined the licensees procedures and ongoing r efurbishment activities to verify compliance with applicable parts of the federal regulati ons above. Specifically, the inspectors reviewed the following:

  • Drawing 10043E83, sheet 1, "Traveller STD Upgrade General Asse mbly,"

Rev. 8, dated November 5, 2019

  • Traveller Refurbishment Verification Checklist, Package Serial Number TX-200, completed June 12, 2021
  • TR-229, "Traveller Recertification," Rev. 2, dated June 21, 20 21

Records, Reports, and Notifications (IP Section 02.13)

The inspectors reviewed the licensees records and procedures f or recordkeeping and reports to verify that a system is in place to verify complianc e with the federal regulations above. Specifically, the inspectors reviewed the following:

  • 938603-22, "Traveller Shipping Container Checklist"
  • Licensee Investigation Report 2020-13034, "LR-230 discovered p ackage defect," dated November 12, 2020
  • Licensee Investigation Report 2020-4142, "LR-230 tamper seal d iscovered to be improperly applied," dated March 26, 2020
  • Licensee Investigation Report 2021-1944, "MCC container discov ered cracked during preparation for loading," dated February 16, 202 1

INSPECTION RESULTS

No issues were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On July 29, 2021, the inspectors presented the integrated insp ection results to Mike Annacone and other members of the licensee staff.

9