ML19114A003

Nuclear Fuel Services, Inc. - U.S. Nuclear Regulatory Commission Integrated Inspection Report No. 70-143/2019-002

ML19114A003
Person / Time
Site:	Erwin
Issue date:	04/23/2019
From:	Leonard Pitts NRC/RGN-II/DFFI/FFB1
To:	Stewart J Nuclear Fuel Services
References
IR 2019002
Download: ML19114A003 (21)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 April 23, 2019 Mr. John A. Stewart President Nuclear Fuel Services, Inc.

P. O. Box 337, MS 123 Erwin, TN 37650-0337

SUBJECT:

NUCLEAR FUEL SERVICES, INC. - U. S. NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT NUMBER 70-143/2019-002

Dear Mr. Stewart:

This letter refers to the inspections conducted from January 1 through March 31, 2019, at the Nuclear Fuel Services, Inc. (NFS) facility in Erwin, TN. The enclosed report presents the results of the inspections. The findings were discussed with members of your staff at the exit meetings held on March 14, 2019, and after the end of the quarter on April 16, 2019.

During the inspections, the Nuclear Regulatory Commission (NRC) staff examined activities conducted under your license, as related to public health and safety and to confirm compliance with the Commissions rules and regulations and with the conditions of your license. Within these areas, the inspections consisted of selected examination of procedures and representative records, observations of activities, and interviews with personnel. The inspections covered the following areas: safety operations, radiological controls, facility support, and other areas.

Based on the results of these inspections, no violations of more than minor significance were identified.

In accordance with Title 10 of the Code of Federal Regulations Section 2.390 of the NRC's "Rules of Practice and Procedure," a copy of this letter and enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

J. Stewart 2 Should you have any questions concerning these inspections, please contact Joel Rivera-Ortiz of my staff at 404-997-4825.

Sincerely,

/RA/

Leonard Pitts, Acting Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No.70-143 License No. SNM-124

Enclosure:

NRC Inspection Report 70-143/2019-002 w/

Attachment:

Supplemental Information cc: (See page 3)

J. Stewart 3 cc:

Jon A. Hagemann Operations Director Nuclear Fuel Services, Inc.

Electronic Mail Distribution Richard J. Freudenberger Safety & Safeguards Director Nuclear Fuel Services, Inc.

Electronic Mail Distribution Debra G. Shults Director, TN Dept. of Environment & Conservation Electronic Mail Distribution Doris D. Hensley Mayor, Town of Erwin 211 N. Main Avenue P.O. Box 59 Erwin, TN 37650 Greg Lynch Mayor, Unicoi County P.O. Box 169 Erwin, TN 37650 Johnny Lynch Mayor, Town of Unicoi P.O. Box 39 Unicoi, TN 37692 David W. Deming Manager, Program Field Office - NFS Naval Nuclear Laboratory 1205 Banner Hill Rd Erwin, TN 37650

ML19114A003 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DFFI RII:DC SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

NAME LHarris JRivera Ortiz JMunson KMcCurry GGoff LPitts DATE 4/23/2019 4/23/2019 4/23/2019 4/23/2019 4/23 2019 4/23/2019 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO

U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70-143 License No.: SNM-124 Report No.: 70-143/2019-002 Licensee: Nuclear Fuel Services, Inc.

Facility: Nuclear Fuel Services, Inc.

Location: Erwin, TN 37650 Dates: January 1, 2019 through March 31, 2019 Inspectors: L. Harris, Senior Resident Inspector J. Munson, Nuclear Process Engineer (Section A.4)

K. McCurry, Fuel Facility Inspector (Section A.4)

G. Goff, Fuel Facility Inspector (Section C.4)

Approved by: L. Pitts, Acting Chief Projects Branch 1 Division of Fuel Facility Inspection Enclosure

EXECUTIVE

SUMMARY

Nuclear Fuel Services, Inc.

NRC Integrated Inspection Report 70-143/2019-002 January 1 - March 31, 2018 Inspections were conducted by the resident and regional inspectors during normal and off-normal hours in safety operations, radiological controls, facility support, as well as other areas.

The inspectors performed a selective examination of licensee activities that was accomplished by direct observation of safety significant activities and equipment, tours of the facility, interviews and discussions with licensee personnel, and a review of facility records.

Safety Operations

• Plant Operations were performed safely and in accordance with license requirements. Items relied on for safety were properly implemented and maintained in order to perform their intended safety function. No violations of more than minor significance were identified in this area. (Paragraphs A.1 and A.2)

• No violations of more than minor significance were identified related to the Nuclear Criticality Safety Program. (Paragraphs A.3 and A.4)

• The Fire Protection Program and systems were adequately maintained in accordance with the license application and regulatory requirements. (Paragraph A.5)

Radiological Controls

• The Radiation Protection Program was implemented in accordance with the license application and regulatory requirements. (Paragraph B.1)

Facility Support

• The Post-Maintenance Testing and Surveillance Programs were implemented in accordance with the license application and regulatory requirements for work control and safety-related equipment testing. (Paragraphs C.1 and C.2)

• Adverse conditions were adequately identified, evaluated, and entered into the Corrective Action Program. (Paragraph C.3)

• The Emergency Preparedness program was implemented in accordance with the Emergency Plan and regulatory requirements. (Paragraph C.4)

2 Other Areas

• No violations of more than minor significance were identified during Resident Inspector observations of Security Force and Material and Control accounting personnel.

(Paragraph D.1)

• The inspectors reviewed 60-Day Written Event Report, Shipment to Westinghouse Columbia, dated November 30, 2017. No violations of more than minor significance were identified. This item is considered closed. (Paragraph D.2)

Attachment:

Supplemental Information

REPORT DETAILS Summary of Plant Status The following facility process areas were operating during the inspection period: Naval Fuel Manufacturing Facility (FMF) and the Blended Low Enriched Uranium (BLEU) Preparation Facility (BPF), which includes the Uranium (U)-Metal, U-Oxide, Solvent Extraction and the down-blending lines.

A. Safety Operations

1. Plant Operations Routine (Inspection Procedures (IPs) 88135 and 88135.02)

a. Inspection Scope The inspectors performed routine tours of the fuel manufacturing areas housing Special Nuclear Material (SNM), reviewed log sheets, and interviewed operators, front-line managers, maintenance mechanics, radiation protection (RP) staff, laboratory managers, and process engineering personnel regarding issues with plant equipment and to verify the status of the operations. The inspectors observed operational and shift turnover meetings throughout the inspection period to gain insight into safety and operational issues.

During the inspection period, the inspectors interviewed operators, front-line managers, maintenance technicians, engineers, RP technicians, and nuclear materials control technicians to verify that each of the individuals demonstrated adequate knowledge of the nuclear criticality safety (NCS) posting requirements, hazards, and the operations procedures associated with their assigned duties.

The routine tours included walk-downs of the FMF, BPF, commercial development line areas, miscellaneous storage areas, the Waste Water Treatment Facility (WWTF), and Building 440. During routine tours, the inspectors verified that operators were knowledgeable of their duties and attentive to any alarms or annunciators at their respective stations. The inspectors observed activities during normal and upset conditions to verify that operators complied with procedures and material station limits.

The inspectors verified that safety controls, including items relied on for safety (IROFS),

were in place, properly labeled, and functional to ensure proper control of SNM. The inspectors verified the adequacy of communications between supervisors and operators within the operating areas.

The inspectors reviewed operator log books, standard operating procedures (SOPs),

maintenance records, and Letters of Authorization (i.e., temporary procedures) to obtain information concerning operating trends and activities. The inspectors verified that the licensee actively pursued corrective actions for conditions requiring temporary modifications and compensatory measures.

The inspectors performed periodic tours of the outlying facility areas to determine that equipment and systems were operated safely and in compliance with the license. The inspectors focused on potential wind-borne missile hazards, potential fire hazards with combustible material storage and fire loading, hazardous chemical storage, the physical condition of bulk chemical storage tanks and piping, storage of compressed gas

2 containers, as well as potential degradation of plant security features. The inspectors attended various plan-of-the-day meetings and met daily with the Plant Shift Superintendent throughout the inspection period in order to determine the overall status of the plant. The inspectors evaluated the adequacy of the licensees response to significant plant issues as well as their approach to solving various plant problems during these meetings.

b. Conclusion

No violations of more than minor significance were identified.

2. Safety System Walkdown Inspection (IP 88135.04)

a. Inspection Scope The inspectors performed walkdowns of safety-significant systems involved with the processing of SNM. As part of the walkdowns, the inspectors verified that as-built configurations matched approved plant drawings.

The inspectors interviewed operators to confirm that plant personnel were familiar with the assumptions and controls associated with the IROFS systems and instrumentation for maintaining plant safety. The inspectors also verified that IROFS assumptions and controls were properly implemented in the field.

The inspectors reviewed the related Integrated Safety Analysis (ISA) to verify that system abilities to perform functions were not affected by outstanding design issues, temporary modifications, operator workarounds, adverse conditions, or other system-related issues.

The inspectors also verified that there were no conditions that degraded plant performance and the operability of IROFS, safety-related devices, or other support systems essential to safety system performance. Safety-significant functions, tests, and inspections to assure operability of the safety systems for the Recovery Areas F-J in the production area were specifically inspected. For Recovery, the inspectors reviewed IROFS identified as: FAF-1, FAF-2, FAF-4, FAF-6, FAF-8, FAF-9, FAF-17, FAF-18, FAF-20, FAF-21, FAF-23, FAF-28, FAF-30, FAF-31, FAF-32, FAG-1, FAG-3, FAG-5, FAG-6, FAG-7, FAG-8, FAG-9, FAG-12, FAG-23, FGHJ-1, FIRESX-1, FIRESX-2, and FIRESX-3.

To determine the correct system alignment, the inspectors reviewed procedures, drawings, related sections of the ISA, and regulatory requirements such as Title 10 of the Code of Federal Regulations (10 CFR) Section 70.61, Performance Requirements.

During the walkdowns, the inspectors verified all or some of the following as appropriate:

• controls in place for potential criticality, chemical, radiological, and fire safety hazards

• process vessel configurations maintained in accordance with NCS Evaluations

• correct valve position and potential functional impacts such as leakage

• electrical power availability

3

• major system components correctly aligned, labeled, lubricated, cooled, and ventilated

• hangers and supports correctly installed

• functional lockout/tag-put program appropriately implemented

• cabinets, cable trays, and conduits correctly installed and functional

• visible cabling in good material condition

• no interference with system performance from ancillary equipment or debris

b. Conclusion

No violations of more than minor significance were identified.

3. Nuclear Criticality Safety (IP 88135.02)

a. Inspection Scope During daily production area tours, the inspectors verified that various criticality controls were in place, that personnel followed criticality station limit cards, and that containers were adequately controlled to minimize potential criticality hazards. The inspectors reviewed a number of criticality-related IROFS for operability. The inspectors interviewed operators to verify that they were knowledgeable of the requirements associated with IROFS. The inspectors performed tours inside various process areas when SNM movements were taking place within the facility.

As part of routine day-to-day activities on-site, the inspectors reviewed entries in the licensees Problem, Identification, Resolution, and Correction System (PIRCS) associated with criticality safety aspects. PIRCS is the licensees Corrective Action Program (CAP). The inspectors evaluated the licensees response to such entries and held discussions with NCS engineers and production personnel to determine safety significance and compliance with procedures.

b. Conclusion

No violations of more than minor significance were identified.

4. Nuclear Criticality Safety (IP 88015)

a. Inspection Scope Criticality Analysis The inspectors reviewed selected nuclear criticality safety evaluations (NCSEs) to determine whether properly reviewed and approved NCSEs were in place prior to conduct of new or changed operations and were of sufficient detail and clarity to permit independent review. The inspectors reviewed the selected NCSEs and associated assumptions and calculations to verify they were consistent with the commitments in the license application, including consideration of the double contingency principle, assurance of subcriticality under normal and credible abnormal conditions with the use of subcritical margin, technical practices and methodologies, and treatment of NCS parameters. The NCSEs were selected based on factors such as risk significance, heavy reliance on administrative controls or unusual control methods, operating history,

4 and whether they were new or revised. The NCSEs reviewed were associated with specific enclosures and processes in the BLEU, BPF, Area 900, and High Security Storage Area, as listed in Section 4 of the attachment.

The inspectors reviewed selected accident sequences to determine whether the NCSEs systematically identified normal and credible abnormal conditions in accordance with the commitments and methodologies in the license application for the analysis of process upsets. This included the review of accident sequences for which the licensee credited the repeated failure of administrative controls, or credited the duration of a control failure, to determine whether the bases for this credit were consistent with Chapter 3 of the license application and the licensees procedures, including the Independence Criteria Guidance in Attachment C of NFS-HS-A-68, ISA Risk Assessment Procedure.

This review was conducted primarily for the accident sequences analyzed in the BPF.

The inspectors reviewed the validation report (54T-12-0038, Validation of Computer Codes for NCS for Uranium Systems with Enrichments up to 100 wt. % 235U: SCALE 6.1 with the V7-238 Library from ENDF/B-VII, and SCALE 4.4a with the 27GROUPNDF4 Library from ENDF/B-IV) to verify that there were no changes since the last NRC review.

The inspectors reviewed the selected NCSEs to determine whether calculations were performed within their validated areas of applicability and consistent with the validation report.

Criticality Implementation The inspectors performed walkdowns in both the high-enriched and low-enriched sides of the BPF, naval fuel processing areas including Areas 100 through 700, 900, and uranium recovery to determine whether existing plant configuration and operations were covered by, and consistent with, the process description and safety basis in the selected NCSEs. The inspectors reviewed process and system descriptions, specifications, drawings, and control flowdowns to verify that engineered controls established in the NCSEs were included. The inspectors also reviewed operating procedures and postings to verify that administrative controls established in the NCSEs were included. The inspectors interviewed operators and engineers to verify that selected controls established in the NCSEs were understood and being implemented as specified.

The inspectors reviewed the ISA summary and supporting ISA documentation to determine whether the controls identified in the ISA were supported by technical bases in the NCSEs.

Criticality Operational Oversight The inspectors reviewed records of NCS audits and accompanied a licensee NCS engineer on a weekly inspection of uranium recovery Areas D through F to determine whether NCS staff routinely assessed field compliance with established NCS controls.

The inspectors reviewed the applied management measures for selected NCS controls to determine whether the management measures were sufficient to ensure the availability and reliability of NCS controls. The management measures reviewed included functional tests of safety-related equipment, calibration records, operating procedures, and visual inspections.

5 Criticality Incident Response and Corrective Action The inspectors reviewed selected NCS-related PIRCS entries to determine whether anomalous conditions were promptly identified and entered into PIRCS, whether they received the appropriate level of investigation consistent with license commitments and procedures, whether proposed corrective actions were sufficiently broad, whether they were prioritized on a schedule commensurate with their significance, whether they were completed as scheduled, and whether the assigned corrective actions were appropriate to correct the condition. Additionally, the inspectors reviewed NCS-related PIRCS entries to assess whether the licensee followed the regulatory requirements and procedures to report plant conditions to the NRC. The PIRCS entries reviewed included PIRCS 70437, 71991, 71988, and 72188.

b. Conclusion

No violations of more than minor significance were identified.

5. Fire Protection Quarterly (IP 88135.05)

a. Inspection Scope During routine plant tours, the inspectors verified that transient combustibles were being adequately controlled and minimized in selected process areas. The inspectors reviewed active fire impairments in selected process areas to determine if they were implemented per site procedures.

The inspectors conducted a walk-down of Building 302 and reviewed the Pre-Fire plan drawing to verify it matched the as-found condition for various fire protection components like extinguishers and postings. For Building 300 complex, the inspectors reviewed tests for the following fire IROFS: N302XFRDAMP0002, N302XFRDAMP0003, and N302XFRDAMP0004.

The inspectors reviewed the material condition of fire protection components to verify they were adequately maintained. The inspectors reviewed a sampling of fire-related PIRCS entries to verify that corrective actions were appropriate and that appropriate compensatory actions were implemented, as applicable. The inspectors observed fire brigade exercises.

b. Conclusion

No violations of more than minor significance were identified.

6 B. Radiological Controls

1. Radiation Protection Quarterly (IP 88135.02)

a. Inspection Scope During tours of the production areas, the inspectors observed RP controls and practices implemented during various plant activities including the proper use of personnel monitoring equipment, required protective clothing, and frisking methods for detecting radioactive contamination on individuals exiting contamination controlled areas. The inspectors verified that plant workers properly wore dosimetry and used protective clothing in accordance with applicable Special Work Permits (SWPs). The inspectors also verified that radiation area postings complied with plant procedures and included radiation maps with up-to-date radiation levels. The inspectors monitored the operation of RP instruments and verified calibration due dates.

The inspectors performed partial reviews of select SWPs in effect during the inspection period in different operational areas and conducted a more thorough review for the following SWPs and associated posted radiologically controlled areas:

• SWP 19-03-001 302 F-J

• SWP 17192 303/600

• SWP 19-32-007 333

• SWP 19-21-004 302

b. Conclusion

No violations of more than minor significance were identified.

C. Facility Support

1. Post-Maintenance Testing (IP 88135.19)

a. Inspection Scope The inspectors observed and/or reviewed the post-maintenance tests (PMTs) listed below to verify that procedures and test activities confirmed safety systems and components (SSCs) operability and functional capability following the described maintenance.

The inspectors reviewed the licensees completed test procedures to verify that any of the SSC safety function(s) that may have been affected were adequately tested, that the acceptance criteria were consistent with information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved.

The inspectors also observed and/or reviewed the test data to verify that test results adequately demonstrated restoration of the affected safety function(s). The inspectors verified that PMT activities were conducted in accordance with applicable work order

7 Instructions or licensee procedural requirements. Furthermore, the inspectors verified that problems associated with PMTs were identified and entered into the licensees PIRCS. This was conducted for the following safety related equipment (SRE) tests:

• SRE Test: N333XXXXPCV4DC4

• SRE Test: N333XNOXDET3E01

b. Conclusion

No violations of more than minor significance were identified.

2. Surveillance Testing (IP 88135.22)

a. Inspection Scope The inspectors observed portions of and/or reviewed completed test data for the following surveillance tests of risk-significant and/or safety-related systems to verify that the tests met the requirements of the ISA, commitments, and licensee procedures. The inspectors observed and reviewed testing to determine if the SSCs were operationally capable of performing their intended safety functions and fulfilling the intent of the associated SRE test requirement. The inspectors discussed surveillance testing requirements with operators performing the associated tasks to determine the adequacy of their procedural knowledge. The inspectors reviewed the calibration of test equipment or standards used to conduct the tests. The inspectors observed the communications between personnel performing these tests during the completion of each activity.

• SRE Test: N303XFILTERR703

• SRE Test: N303XFILTERR704

• SRE Test: N303XIGNTBSS761

• SRE Test: N303XINGTBSS762

• SRE Test: N303XINGTBSS763

• SRE Test: N303XXXFICS601A

• SRE Test: N303XXXFICS602A

• SRE Test: N303XXXFICS610A

• SRE Test: N303XXXFICS620A

• SRE Test: N303XXXFICS630A

• SRE Test: N303XXXXFICS671

• SRE Test: N303XXXXFICS672

• SRE Test: N303XXXXFICS673

• SRE Test: N303XXXXPSVS601

• SRE Test: N303XXXXPSVS602

b. Conclusion

No violations of more than minor significance were identified.

8

3. Corrective Action Program Review (IP 88135)

a. Inspection Scope The inspectors reviewed the PIRCS to ensure that items adverse to safety were being identified and tracked to closure in accordance with program procedures. The inspectors routinely attended daily PIRCS screening committee meetings and periodic Corrective Action Review Board meetings to evaluate site managements response and assignment of corrective actions or investigations to various issues. The inspectors also performed daily screenings of items entered into the PIRCS to aid in the identification of repetitive equipment failures or specific human performance issues for follow-up. The inspectors reviewed PIRCS entries that occurred during the inspection period to assess and evaluate the safety significance of issues. For items identified to be more safety significant, the inspectors conducted an additional evaluation to verify the licensee was adequately addressing and correcting the issues to prevent recurrence.

b. Conclusion

No violations of more than minor significance were identified.

4. Emergency Preparedness (IP 88050)

a. Inspection Scope The inspectors performed an Emergency Preparedness (EP) inspection to determine whether the licensees Emergency Preparedness Program (EPP) is maintained in a state of operational readiness; properly coordinated with off-site support agencies; and audited in such depth as to provide assurance that the EPP is being properly maintained and implemented in accordance with requirements and commitments in the license application.

The inspectors reviewed NFS-GH-903, Emergency Plan, Revision (Rev.) 24, to verify compliance with Chapter 8.0, Emergency Management, of License SNM-124. The inspectors also reviewed the Emergency Plan Implementing Procedures (EPIPs) which had revisions since the last EP inspection to verify that these revisions did not diminish safety and that the procedures remained in compliance with the Emergency Plan (E-Plan). The inspectors also interviewed the EPP manager to determine that the EPP addressed corrective actions; implemented required training; and had independent, annual audits as per Chapter 11 of the license application.

The inspectors observed the storage of emergency equipment and documentation in the on-site Emergency Control Center (ECC, Building 320) and one alternate ECC (the Training Center) to verify compliance with the Emergency Plan. The inspectors observed the operation of the automated personnel accountability system and verified the emergency equipment storage at the primary assembly area (Emergency Monitoring Supply Center), alternate assembly area (Building 345), and the Emergency Shelter (Building 350) to determine compliance with procedure NFS-HS-B-40, Inspection Emergency Equipment and Supplies," Rev. 27. Inspectors performed call-in checks with the NRC Emergency Operations Center on the NRC-dedicated phones at the ECC and alternate ECC to verify functionality. Inspectors also walked down Building 105 (Criticality Alarm Room), the Central Alarm Station (CAS), and the Secondary Alarm Station (SAS) to verify compliance with the E-Plan.

9 The inspectors reviewed written agreements between NFS and off-site agencies to verify that emergency response coordination, required by the E-Plan, was current. The inspectors interviewed representatives from Johnson City Medical Center, Town of Erwin Fire Department, South Side Volunteer Fire Department, Unicoi County Hospital, and MedicOne Medical Response (EMS) to assess their knowledge and understanding of the written agreements and that each entity was offered training/drill participation at least annually as per the E-Plan.

The inspectors reviewed corrective actions captured from emergency exercises/drills that had occurred since the last inspection. The inspectors also reviewed the annual, independent audit of the EP program to verify compliance with Chapter 11 of the license application and the E-Plan. The inspectors verified that that observations/findings from this audit were also entered into the licensees CAP for resolution.

The inspectors reviewed training records provided to the licensee emergency response organization (ERO) covering their roles and responsibilities to verify it met the training requirements in the E-Plan and Chapter 11 of the license application. The inspectors also interviewed select members of the ERO to determine if each knew his/her responsibilities.

The inspectors reviewed licensee-provided training for hypothetical emergency situations to verify the training was consistent with the frequency and performance objectives required in the E-Plan.

b. Conclusion

No violations of more than minor significance were identified.

D. Other Areas

1. Quarterly Resident Inspector Observations of Security and Material Control and Accounting (MC&A) Personnel and Activities

a. Inspection Scope During the inspection period, the inspectors conducted observations of security and MC&A personnel and activities to ensure the activities were consistent with applicable license, procedure, and regulatory requirements. These observations took place during normal and off-normal plant working hours.

These quarterly resident inspectors observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors' normal plant status reviews and inspection activities.

b. Conclusion

No violations of more than minor significance were identified.

10

2. Event Follow-up (IP 88135)

a. 60-Day Written Notification of Event - Shipment to Westinghouse Columbia, dated November 30, 2017 (ML17346A686)

On October 10, 2017, the licensee shipped nine Liquid-Rad (LR) Transport Unit Packages (Model LR-230) containing low enriched uranyl nitrate solution to the Westinghouse Columbia Fuel Fabrication Facility (Westinghouse). Upon receipt and inspection of the LR-230s, Westinghouse personnel identified that one of the secondary lid bolts of an LR-230 package was not tightened to the applicable specifications.

Conclusion 10 CFR 71.17(c)(2) states, in part, that each licensee shall comply with the terms and conditions of the license application, certificate, or other approval, as applicable.

Certificate of Compliance Number 9291 for LR Transport Unit Package, Rev. 9, states that the package must be prepared for shipment and operated in accordance with the Operating Procedures in Chapter 7 of the application. The operating procedures in Chapter 7 of the application (Safety Analysis Report Section 7.1.2(c)) require the secondary lid bolts to be torqued to 75 ft-lb. Contrary to the above, on October 10, 2017, the licensee failed to torque a secondary lid bolt on a LR-230 package to the required specifications.

Throughout shipment, the other secondary lid bolts and the 16 primary lid bolts remained torqued to the required specifications. Additionally, the tamper-indicating device was still intact upon receipt. Westinghouse personnel did not identify any indications of radioactive material release during transport or volume discrepancies.

The licensee conducted an investigation and determined that the likely cause of the failure of the bolt to have the required amount of torque upon receipt was human error.

The licensee also confirmed that the secondary lid leak test had been conducted successfully prior to shipment.

The licensee documented the occurrence in PIRCS and revised SOP 409 to require a peer check by another employee to assure all bolts are torqued to specifications. This failure to comply with 10 CFR 71.17(c)(2) constitutes a minor violation in accordance with the guidance in NRC Inspection Manual Chapter 0616, Fuel Cycle Safety And Safeguards Inspection Reports, and the examples in Section 6.8 of the NRC Enforcement Policy, dated May 15, 2018. This minor violation is not subject to enforcement action in accordance with Section 2.2.2 of the NRC Enforcement Policy.

This item is considered closed.

E. Exit Meetings The inspection scope and results were presented to members of the licensees staff at various meetings throughout the inspection period and were summarized on March 14, 2019, and at the end of the quarter on April 16, 2019, to J. Stewart and staff.

No dissenting comments were received from the licensee. Proprietary and classified information was discussed but not included in the report.

SUPPLEMENTAL INFORMATION

1. KEY POINTS OF CONTACT Name Title N. Auman Senior Project Manager J. Bailey Fire Chief, Town of Erwin S. Barron Emergency Preparedness Program Manager J. Bryant Captain, South Side Volunteer Fire Department N. Brown NCS Manager T. Cloyd Fire Protection Engineer 3 J. Dyson Training Specialist 2 T. Eilers Industrial Safety Principal Tech Specialist (Senior)

K. Elliott Radiation Technician M. Eakin NCS Engineer S. Gizzie NCS/ Fire Brigade K. Greer Emergency Services Unit Manager A. Jones Director of Nursing, Unicoi County Memorial Hospital J. Kemp Operations Manager, MedicOne Medical Response J. Kerr Emergency Services Specialist R. Kirk Electronic Maintenance Supervisor C. Lewis NCS Engineer J. May TWM Operations Unit Manager R. Mauer Fire Protection and ISA Manager B. McAllister Environmental Scientist P. McNutt Radiation Safety Officer for Johnson City Medical Center A. Morie Safety & Program Manager E. Shelton BPF Supervisor S. Skiles NCS Engineer

3. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed 60-Day Written Notification of Event - Shipment to Westinghouse Columbia, dated November 30, 2017 Discussed None

3. INSPECTION PROCEDURES USED 88015 Nuclear Criticality Safety 88050 Emergency Preparedness 88135 Resident Inspection Program for Category I Fuel Cycle Facilities 88135.02 Resident Inspection Program Plant Status Activities Attachment

2 88135.04 Resident Inspection Program Operational Safety 88135.05 Resident Inspection Program Fire Protection 88135.19 Post Maintenance Testing 88135.22 Surveillance Testing

4. DOCUMENTS REVIEWED Records:

302-F0331-D 302-F0332-D 302-F0338-D 302-F0339-D 302-F0355-D 333-F0710-D, ENCLOS-1R01 P&ID, Rev. D Calibration of Scales and Balances, for Instrument I.D. No. WC-184, dated February 19, 2019 Calibration of Weights and Masses, for NFS I.D. No. ECS-351, dated July 9, 2018 Scheduled Test Record for Equipment No. N333VALVEBA4A44, dated November 15, 2018 56T-18-0165, Emergency Preparedness Audit (QA-18-18), dated December 14, 2018 2018 Tier Two Reporting - Section 312 SARA Title III Requirements, dated February 25, 2019 Annual Refresher Training for select ERO personnel FM-NFS-HS-A-67-A, Safety & Regulatory Review Routing Form, Rev. 6 NFS-GH-903, Emergency Plan Distribution Sheet, Rev. 24 NFS-HS-A-24, Attachment A, Quarterly Emergency Checklist, Rev. 12, dated December 19, 2018; September 28, 2018; June 29, 2018; and March 29, 2018.

NFS-HS-B-40, Inspection Emergency Equipment and Supplies, Attachment A, Emergency Shelter (Building 350), Rev. 27D, dated March 2018 - January 2019 NFS-HS-B-40, Inspection Emergency Equipment and Supplies, Attachment C, Emergency Control Center (Building 320), Rev. 27D, dated March 2018 - January 2019 NFS-HS-B-40, Inspection Emergency Equipment and Supplies, Attachment E, Emergency Monitoring Supply Center (EMSC), Rev. 27D, dated March 2018 -

January 2019 Agreement between MedicOne Medical Response and Nuclear Fuel Services, Inc., dated July 14, 2017 Letter of Agreement - Radiation Emergency assistance Center/Training Site (REAC/TS)

Support, dated October 19, 2015 Updating Agreement between the Erwin Fire Department and Nuclear Fuel Services, Inc.,

dated July 14, 2017 Updating Agreement between Mountain States Health Alliance (MSHA) d/b/a Johnson City Medical Center (JCMC) and Nuclear Fuel Services, Inc., dated August 2, 2017 Updating Agreement between the South Unicoi County Volunteer Fire Department and Nuclear Fuel Services, Inc., dated July 14, 2017 Updating Agreement between the Town of Erwin and Nuclear Fuel Services, Inc., dated July 15, 2017 Updating Agreement between Unicoi County Memorial Hospital and Nuclear Fuel Services, Inc., dated October 13, 2016

3 Procedures:

NCS-03-02, Control Flowdown and Field Verification for Uranium Recovery Solvent Extraction Areas G, H, and J.

NFS-EC-22, Calibration of Weights, Rev.4, dated February 13, 2017 NFS-HS-A-68, ISA Risk Assessment Procedure, Rev. 9, dated March 8, 2019 NFS-HS-A-24, Inspection of Emergency Supplies, Rev. 12, dated March 31, 2017 NFS-HS-A-24, Attachment C, Monthly Emergency Communication Checklist, Rev. 12, dated March 31, 2017 NFS-HS-B-40, Inspection Emergency Equipment and Supplies, Rev. 27, dated May 2, 2016 NFS-HS-B-40, Inspection Emergency Equipment and Supplies, Attachment A, Emergency Shelter (Building 350), Rev. 27D, dated December 1, 2018 NFS-HS-B-40, Inspection Emergency Equipment and Supplies, Attachment C, Emergency Control Center (Building 320), Rev. 27D, dated December 1, 2018 NFS-HS-B-40, Inspection Emergency Equipment and Supplies, Attachment E, Emergency Monitoring Supply Center Checklist and BLDG. 345 EMSC Extension, Rev. 27D, dated December 1, 2018 NFS-HS-E-02, Emergency Criticality Evacuation, Rev. 46, dated September 12, 2018 NFS-HS-E-03, Emergency Response Organization, Rev. 32, dated September 12, 2018 NFS-HS-E-04, Fire Reporting and Response, Rev. 39, dated September 12, 2018 NFS-HS-E-05, Spill Response and Reporting, Rev. 37, dated September 12, 2018 NFS-HS-E-07, On-Site Radiological Emergency Assessment, Rev. 35, dated September 12, 2018 NFS-HS-E-08, Off-Site Radiological Emergency Assessment, Rev. 29, dated September 12, 2018 NFS-HS-E-09, Off-Site Dose Projection for Radiological Emergency, Rev. 30, dated September 12, 2018 NFS-HS-E-10, Emergency Communications, Rev. 30, dated September 12, 2018 NFS-HS-E-11, Radiological Scene and Contamination Control, Rev. 24, dated December 11, 2015 NFS-HS-E-12, 24-Hour Emergency Response for Hazardous Material Transportation, Rev. 23, dated September 12, 2018 NFS-HS-E-13, Emergency Take Cover, Rev. 9, dated September 12, 2018 NFS-HS-E-14, CO2 Evacuation Alarm Response and Responsibilities, Rev. 14, dated September 12, 2017 NFS-HS-E-15, Emergency Medical Response, Rev. 17, dated September 12, 2017 NFS-GH-01, Contamination Control, Rev. 35, dated March 22, 2019 NFS-GH-28, Personal Monitoring, Rev. 15, dated March 22, 2019 SOP-409-45. Loading and Staging LR230 Containers, Rev. 15, dated January 3, 2018 Nuclear Criticality Safety Evaluations (NCSEs):

NCS-03, Nuclear Criticality Safety Evaluation for the High Security Storage Area in Building 311 (U), Rev. 8 NCS-03-02-09, 54X-17-0002, Nuclear Criticality Safety Evaluation for ENCLOS-5901/-9901 in Area 900 of the Fuel Manufacturing Facility (U), Rev. 4 NCS-07-01, 54T-08-0010, Nuclear Criticality Safety Evaluation for BLEU Preparation Facility Downblending, Rev. 8 NCS-07-01, 54T-14-0027, Nuclear Criticality Safety Evaluation for the BPF Splitting, Sampling, and Combining Enclosure, Rev. 0 NCS-14-0024, Nuclear Criticality Safety Evaluation for the Uranium Metal Sampling and the Uranium Metal Shear System (U), Rev. 5

4 Other Documents:

ANSI 8.3, Criticality Accident Alarm System, 1986 Emergency Response Organization (ERO) Org Chart Emergency Management Council Meeting Invitation (Unicoi County), dated December 10. 2018 Executive Organization Org Chart NFS Emergency Personnel Call List, dated October 25, 2018 Radiation Protection for Emergency Response for Off-site Agency Training and Orientation for Johnson City Medical Center, dated November 1, 2018 Radiation Protection for Emergency Response for Off-site Agency Training and Orientation For Unicoi County Hospital, dated December 4, 2018 Recommended Medical Treatment for Hydrofluoric Acid Exposure, 2018 PIRCS Written as a Result of the Inspection:

70418, 70456, 71586, 71720, 71901, 72099, 72151, 72153, 72186, 72188, 72228, 72278 PIRCS Reviewed:

23782, 26392, 31274, 31275, 31930, 31931, 31932, 31942, 31941, 63325, 63331, 63421, 64817, 65047, 70216, 70219, 70221, 70222, 70223, 70347, 70377, 70409, 70413, 70418, 70432, 70437, 70457, 70459, 70481, 71576, 71621, 71617, 71632, 71633, 71656, 71666, 71772, 71950, 71845, 71988, 71991, 72102, 72119, 72121, 72128, 72144, 72143, 72153, 72165, 72188, 72263, 72264, 72270, 72294, 72315