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July 23, 2020 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 70-143/2020-002 Dear Mr. Stewart: This letter refers to the inspections conducted from April 1, 2020, through June 30, 2020, at the Nuclear Fuel Services Facility in Erwin, Tennessee. During this period, the NRC implemented alternative ways to complete the core inspection program for your site in response to the public health emergency declared by the Secretary of Health and Human Services on January 31, 2020, and the National Emergency declared by the President of the United States on March 13, 2020, regarding the public health risks of the novel coronavirus (COVID-19) disease. On March 19, 2020, the NRC transitioned into a mandatory telework posture for all staff (including resident inspectors) consistent with social distancing and travel recommendations issued to federal agencies. Consequently, the NRC Region II staff continues to evaluate how to best conduct inspections while balancing our determinations of reasonable assurance of adequate protection and ensuring the health and safety of inspectors and the public at large. The enclosed report presents the results of the inspections, which were conducted through a combination of remote reviews and on-site observations. The inspectors reviewed activities as they relate to public health and safety, the common defense and security, and compliance with the Commission's rules and regulations, as well as the conditions of your license. The inspections covered the areas of safety operations, radiological controls, facility support, and other areas. Within these areas, regional and resident inspectors reviewed procedures and representative records remotely and conducted telephonic interviews with site personnel. The resident inspector also visited the facility on a weekly basis to monitor plant conditions and conduct focused inspection activities. The findings were discussed with you and members of your staff at exit meetings held on May 6, 2020 and July 9, 2020. Based on the results of these modified inspections, no violations of more than minor significance were identified. The NRC will continue evaluating the guidelines and recommendations from federal and state authorities, along with the conditions of your facility, to determine when to resume inspection activities as normal. In the interim, the NRC plans to conduct periodic resident inspector visits to the site and gradually increase their presence, as appropriate. The NRC will also maintain frequent communications with your staff to discuss regulatory compliance matters and gather information to inform the decisions about future inspections. 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 NRC’s

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Page 1: Nuclear Fuel Services, Inc. - U. S. Nuclear Regulatory ...EXECUTIVE SUMMARY 2 Nuclear Fuel Services, Inc. U.S. NRC Integrated Inspection Report 70-143/2020-002 April 1 – June 30,

July 23, 2020 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 70-143/2020-002 Dear Mr. Stewart: This letter refers to the inspections conducted from April 1, 2020, through June 30, 2020, at the Nuclear Fuel Services Facility in Erwin, Tennessee. During this period, the NRC implemented alternative ways to complete the core inspection program for your site in response to the public health emergency declared by the Secretary of Health and Human Services on January 31, 2020, and the National Emergency declared by the President of the United States on March 13, 2020, regarding the public health risks of the novel coronavirus (COVID-19) disease. On March 19, 2020, the NRC transitioned into a mandatory telework posture for all staff (including resident inspectors) consistent with social distancing and travel recommendations issued to federal agencies. Consequently, the NRC Region II staff continues to evaluate how to best conduct inspections while balancing our determinations of reasonable assurance of adequate protection and ensuring the health and safety of inspectors and the public at large. The enclosed report presents the results of the inspections, which were conducted through a combination of remote reviews and on-site observations. The inspectors reviewed activities as they relate to public health and safety, the common defense and security, and compliance with the Commission's rules and regulations, as well as the conditions of your license. The inspections covered the areas of safety operations, radiological controls, facility support, and other areas. Within these areas, regional and resident inspectors reviewed procedures and representative records remotely and conducted telephonic interviews with site personnel. The resident inspector also visited the facility on a weekly basis to monitor plant conditions and conduct focused inspection activities. The findings were discussed with you and members of your staff at exit meetings held on May 6, 2020 and July 9, 2020. Based on the results of these modified inspections, no violations of more than minor significance were identified. The NRC will continue evaluating the guidelines and recommendations from federal and state authorities, along with the conditions of your facility, to determine when to resume inspection activities as normal. In the interim, the NRC plans to conduct periodic resident inspector visits to the site and gradually increase their presence, as appropriate. The NRC will also maintain frequent communications with your staff to discuss regulatory compliance matters and gather information to inform the decisions about future inspections. 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 NRC’s

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J. Stewart 2

Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Should you have any questions concerning these inspections, please contact Joel Rivera-Ortiz of my staff at 404-997-4825.

Sincerely,

/RA/

Robert E. Williams Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection

Docket No. 70-143 License No. SNM-124 Enclosure: NRC Inspection Report 70-143/2020-002 w/Attachment: Supplemental Information cc w/ encl: Distribution via LISTSERV®

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J. Stewart 3 SUBJECT: NUCLEAR FUEL SERVICES, INC. – U. S. NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT NUMBER 70-143/2020-002 dated July 23, 2020 DISTRIBUTION: D. Marcano, NMSS J. Downs, NMSS R. Williams, RII L. Harris, RII J. Rivera-Ortiz, RII D. Edwards, RII NFS Website PUBLIC

PUBLICLY AVAILABLE NON-PUBLICLY AVAILABLE SENSITIVE NON-SENSITIVE ACCESSION NUMBER: ML20206K838 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB2 RII:DFFI/PB2 RII:DFFI/PB1 NAME L. Harris J. Rivera-Ortiz L. Cooke R. Gibson N. Peterka R. Williams DATE 7/1/2020 7/21/2020 7/2/2020 7/9/2020 7/2/2020 7/23/2020

OFFICIAL RECORD COPY

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U. S. NUCLEAR REGULATORY COMMISSION

REGION II

INSPECTION REPORT

Enclosure

Docket No.: 70-143 License No.: SNM-124 Report No.: 70-143/2020-002 Enterprise Identifier: I-2020-002-0068 Licensee: Nuclear Fuel Services, Inc. Facility: Nuclear Fuel Services, Inc. Location: Erwin, TN 37650 Dates: April 1 through June 30, 2020 Inspectors: L. Harris, Senior Resident Inspector (Sections: A.1 – A.4, B.1, C.1 – C.4, D.1) L. Cooke, Fuel Facility Inspector (Section B.3) R. Gibson, Fuel Facility Inspector (Section B.2) N. Peterka, Fuel Facility Inspector (Section B.4) Approved by: R. Williams, Chief

Projects Branch 1 Division of Fuel Facility Inspection

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EXECUTIVE SUMMARY

2

Nuclear Fuel Services, Inc. U.S. NRC Integrated Inspection Report 70-143/2020-002

April 1 – June 30, 2020 Resident and regional inspectors from the U.S. Nuclear Regulatory Commission (NRC), Region II Office, conducted inspections during normal and off-normal hours in the areas of safety operations, radiological controls, facility support, as well as other areas. Due to the coronavirus (COVID-19) disease, the inspectors performed remote examinations of selected licensee activities in conjunction with focused observations of safety significant activities on site via walk-downs of the facility, interviews with licensee personnel, and review of facility records. Safety Operations • No violations of more than minor significance were identified in the area of operational

safety. (Sections A.1 and A.2)

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

• No violations of more than minor significance were identified related to the Fire Protection

Program. (Section A.4) Radiological Controls • No violations of more than minor significance were identified related to the Radiation

Protection Program (Sections B.1 and B.2).

• No violations of more than minor significance were identified in the area of radioactive waste processing, handling, storage, and transportation. (Section B.3)

• No violations of more than a minor significance were identified in the area of effluent control

and environmental protection. (Section B.4)

Facility Support • No violations of more than minor significance were identified in the area of post-

maintenance and surveillance testing. (Sections C.1 and C.2)

• No violations of more than minor significance were identified in the area of problem identification and resolution. (Section C.3)

• No violations of more than minor significance were identified in the area of emergency

preparedness during the observation of an evacuation drill. (Section C.4)

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Other Areas • No violations of more than minor significance were identified during Resident Inspector

observations of security force and material control and accounting personnel. (Section D.1)

Attachment Supplemental Information

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REPORT DETAILS

4

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. Resident Inspection Program – Plant Status Activities (Inspection Procedures 88135 and

88135.02)

a. Inspection Scope During the inspection period, the inspectors performed routine walk-downs of fuel manufacturing areas housing special nuclear material (SNM), including the FMF, BPF, commercial development line areas, miscellaneous storage areas, the Wastewater Treatment Facility (WWTF), and Building 440 to assess the operational status of those areas. Primarily, the inspectors performed the walk-downs to verify that safety controls, including items relied on for safety (IROFS), were in place, properly labeled, and functional to ensure proper control of SNM. During the walk-downs, the inspectors observed operators to verify they were knowledgeable of their duties and attentive to any alarms or annunciators at their respective stations. The inspectors also observed the interactions between supervisors and operators within the operating areas to verify that their communications supported safe operation of licensed activities. The inspectors observed activities during normal and upset conditions to verify that operators complied with procedures and station material limits. The inspectors performed periodic tours of the outlying facility areas to verify 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 containers, as well as potential degradation of plant security features. The inspectors interviewed plant staff assigned to different disciplines to discuss issues regarding plant equipment. Particularly, the inspectors interviewed operators, front-line managers, maintenance technicians, engineers, radiation protection (RP) technicians, and nuclear materials control technicians to verify that each of the individuals met the applicable training and proficiency requirements in the license application for nuclear criticality safety (NCS) posting requirements, hazards, and the operations procedures associated with their assigned duties. The inspectors reviewed operator logbooks, standard operating procedures, maintenance records, and Letters of Authorization (i.e., temporary procedures) to obtain information concerning operating trends and activities. The inspectors also reviewed the licensee’s implementation of corrective actions for conditions requiring temporary modifications and compensatory measures to verify adherence to plant procedures.

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The inspectors discussed the results of operational and shift turnover meetings throughout the inspection period with plant personnel to gain insight into safety and operational issues. The inspectors discussed items covered during plan-of-the-day meetings and interviewed the Plant Shift Superintendent staff daily to assess the overall status of the plant and the licensee’s corrective actions to resolve safety-significant issues identified in these meetings.

b. Conclusion No violations of more than minor significance were identified.

2. Resident Inspection Program – Operational Safety (Inspection Procedure 88135.04)

a. Inspection Scope The inspectors reviewed procedures, drawings, related sections of the Integrated Safety Analysis (ISA) Summary, and the license application to identify design attributes, safety functions, tests, and inspections applicable to selected safety-significant systems involved with the processing of SNM. The safety systems selected for review were in the Building 330 WWTF. The inspectors performed walk-downs of the systems to verify, in part, that system alignment and as-built configurations matched approved plant drawings and that IROFS assumptions and controls were properly implemented in the field. The inspectors also 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 reviewed ISAs for the selected plant systems to verify that their safety functions were not affected by outstanding design issues, temporary modifications, operator workarounds, adverse conditions, or other system-related issues. The inspectors reviewed plant conditions in the selected process areas to verify that the performance and operability of IROFS, safety-related devices, or other support systems essential to safety system performance were not degraded. During the walk-downs, the inspectors considered the following attributes on a sampling basis and as applicable to the selected systems:

• 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 • 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.

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The inspectors reviewed the IROFS listed below to verify their implementation in accordance with the applicable requirements in the license application and Title 10 of the Code of Federal Regulations, Part 70 (10 CFR 70). The IROFS reviewed in Building 330 WWTF included:

• WWT-1 • WWT-2 • WWT-3 • WWT-4 • WWT-5 • WWT-7 • WWT-10 • WWT-19 • WWT-22 • WWT-26 • WWT-X

b. Conclusion

No violations of more than minor significance were identified.

3. Resident Inspection Program – Nuclear Criticality Safety (Inspection Procedure

88135.02) a. Inspection Scope

The inspectors performed weekly production area walk-downs to verify that 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 several criticality-related IROFS for operability and interviewed operators to verify that they were knowledgeable of the requirements associated with the IROFS. During walkdowns, the inspectors observed SNM movements taking place within the facility. As part of routine day-to-day activities, the inspectors reviewed entries in the licensee’s Problem, Identification, Resolution, and Correction System (PIRCS) associated with criticality safety aspects. The inspectors reviewed the licensee’s response to such entries and held discussions with NCS engineers and production personnel to understand their safety significance and verify compliance with site procedures. The PIRCS records reviewed included:

• 79244 • 79248 • 79472

b. Conclusion

No violations of more than minor significance were identified.

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4. Resident Inspection Program – Fire Protection (Inspection Procedure 88135.05, Quarterly Review)

a. Inspection Scope

During routine plant tours, the inspectors reviewed licensee controls for transient combustibles in selected process areas to verify compliance with the Fire Protection Program as described in Chapter 7 of the license application. 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 production areas in Building 333 and 440, reviewed scheduled surveillances, and pre-fire plan drawings to verify it matched the as-found condition of various fire protection components like extinguishers and postings. The inspectors reviewed routinely scheduled fire safety related inspections to assure they were conducted, and that any identified deficiencies were addressed. The inspections reviewed included:

• safety lights, Building 333 • combustibles control, Building 333 and 440 • sprinkler inspection report, Building 440 • heat detector inspection, Building 333 and 440

The inspectors reviewed surveillance tests for fire dampers in Building 333 to determine if the tests were performed at the required frequency and that any deficiencies were addressed. The following tests were reviewed: N333XFRDAMP0001 through 0007. The inspectors reviewed the material condition of fire protection components to verify they were adequately maintained. The inspectors reviewed a sample of fire related PIRCS entries to verify that corrective actions were identified and implemented in accordance with the license application and licensee procedures. The PIRCS records reviewed included:

• 79180 • 79234 • 79406 • 79662

b. Conclusion

No violations of more than minor significance were identified.

B. Radiological Controls

1. Resident Inspection Program – Radiation Protection (Inspection Procedure 88135.02, Quarterly Review)

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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 observed plant workers to verify they properly wore dosimetry and used protective clothing in accordance with applicable Special Work Permits (SWPs). The inspectors also reviewed radiation area postings to verify compliance with plant procedures and that they included radiation maps with up-to-date radiation levels. The inspectors reviewed a sample of RP instruments to verify their operation and calibration dates were consistent with plant procedures.

The inspectors performed a review of selected SWPs in effect during the inspection period in different operational areas and conducted a focused review for SWP-17552 and the associated posted radiologically controlled area(s), to verify that the SWP contained the information required by the licensee’s procedures.

b. Conclusion

No violations of more than minor significance were identified.

2. Radiation Protection (Inspection Procedure 88030, Appendix A – Remote Inspection)

a. Inspection Scope The inspectors interviewed licensee staff and reviewed radiation protection program documents and procedures as part of a remote inspection to evaluate whether the program was being documented in accordance with 10 CFR 20.1101(a), to verify whether the program was being implemented in accordance with the license application and to verify that the radiation protection program’s function and responsibilities were independent from operations. The inspectors reviewed changes in the radiation protection program organization to verify that new employees met the criteria and qualifications listed in the license application. The inspectors reviewed audits and interviewed licensee staff to verify that the radiation protection program performance was being reviewed, at least annually, for content and implementation in accordance with 10 CFR 20.1101(c). The inspectors reviewed records to verify that the licensee conducted program audits in accordance with Section 2.3.8 of the license application. The inspectors reviewed event follow-up reports, corrective action program entries, and audit reports to determine whether the licensee was identifying radiation protection issues at an appropriate threshold and entering them into the corrective action program as required by the license application. The inspectors reviewed procedures listed in Section 4 of the attachment to this report, and associated forms to verify that the licensee performed periodic radiation and contamination surveys in accordance with licensee procedures to meet the requirements of 10 CFR 20.1501(a) and (b) and Section 4.7.1 of the license application. The inspectors reviewed training records and interviewed staff to verify that employees received training at the frequency specified in Section 4.5 of the license application and as required by 10 CFR 19.12.

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The inspectors reviewed the licensee’s training program to verify that the training included risk awareness for accidents involving licensed activities consistent with Section 4.5 of the license application.

The inspectors interviewed staff to verify that the licensee uses, to the extent practical, engineering controls to achieve occupational doses as low as reasonably achievable (ALARA) in accordance with 10 CFR 20.1101(b), as well as using process or engineering controls to control the concentration of airborne radioactive material in accordance with 10 CFR 20.1701.

b. Conclusion No violations of more than minor significance were identified.

3. Radioactive Waste Processing, Handling, Storage, and Transportation (Inspection Procedure 88035 – Remote Inspection)

a. Inspection Scope

The inspectors conducted a remote inspection of the licensee’s program for handling radioactive waste to verify that it was being implemented in accordance with the license and regulations. The inspectors evaluated whether the licensee had established, maintained, and implemented procedures in accordance with license requirements and quality assurance programs to verify compliance with the requirements of 10 CFR Part 20 and 10 CFR Part 61 as applicable to low-level radioactive waste form, classification, stabilization, and shipment manifests/tracking. Additionally, the inspectors reviewed the changes to the licensee’s organizational structure since the last waste management inspection to verify that the changes complied with the license application. The inspectors reviewed procedures related to radioactive waste handling, characterization, receipt, shipping, and packaging to verify that changes to the licensee’s procedures were made in compliance with Section 11 of the license application. The inspectors also reviewed the procedures to verify that they were reviewed and revised at the required frequency. The inspectors reviewed aspects of the quality assurance program for radioactive waste management to verify that the licensee was performing the required audits per 10 CFR 20, Appendix G. The inspectors reviewed audit reports and PIRCS entries to verify that findings from these audits were entered into the licensee’s corrective action program as required by Section 11 of the license application. The inspectors reviewed aspects of the licensee’s program for classifying low-level radioactive waste and mixed waste, specifically procedures and records for classifying waste to verify compliance with 10 CFR 61.55 and 10 CFR 20 Appendix G. The inspectors also reviewed the licensee’s procedures for labeling and tracking radioactive waste shipments to verify that they were in accordance with license requirements. The inspectors reviewed the training for radiological waste workers to verify that the training addressed operating procedures, alarms, emergency response actions, safety controls, and limits specific to particular work assignments. The inspectors reviewed the training records for select radiological waste workers to verify that they were qualified and maintained their training current as required by Section 11 of the license application.

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Documents reviewed for this inspection are listed in Section 4 of the attachment to this report.

b. Conclusions

No violations of more than minor significance were identified.

4. Effluent Control and Environmental Protection (Inspection Procedure 88045 – Remote

Inspection) a. Inspection Scope

The inspectors discussed changes to the environmental protection program with licensee staff and reviewed records to verify that program changes, including selected procedure revisions, were implemented in accordance with the conditions of the license. The inspectors also reviewed samples of environmental program documentation to determine whether program functions remained independent from operations and in accordance with license conditions. The inspectors reviewed the biannual effluent reports for 2019 to determine if the licensee was in compliance with the radiological limits specified on 10 CFR 70.59 and 10 CFR 20, Appendix B, Table 2. The inspectors also reviewed radiological records to verify that the licensee was complying with the record retention requirements in 10 CFR 20.2107.

The inspectors reviewed calibration records for air monitoring equipment to verify that calibration and functional testing were performed in accordance with Chapter 9 of the license application. The inspectors also reviewed procedure NFS-HS-A-78, “Field Measurements of Effluent Stack/Duct Velocities” to verify whether the basis for air flow set points was consistent with the regulatory limits of gaseous effluents. The inspectors reviewed a sample of records for liquid effluents discharges in 2019 and 2020 to verify all results did not exceed the effluent concentration values in 10 CFR 20, Appendix B, Table 2. The inspectors also reviewed samples of recent monthly records for liquid effluent discharges from the WWTF to the Nolichucky River to verify that the radioactive concentration in these discharges did not exceed the federal regulatory limits and licensee action levels. The inspectors also reviewed sewer sample radiological results to determine compliance with 10 CFR 20.2003 limits. The inspectors reviewed the licensee’s public dose assessment to verify that the total dose to the hypothetical public individual likely to receive the highest dose from licensed operations did not exceed the 10 CFR 20.1301(a)(1) limit for 2019. The inspectors reviewed the airborne portion of the public dose assessment to verify that the result was in compliance with the ALARA constraint required by 10 CFR 20.1101(d).

The inspectors reviewed samples of radiological results for ground water to determine whether the sampling periodicity and analysis were in compliance with license requirements and procedure NFS-HS-B-41, “Routine Groundwater Sampling Procedure.” The inspectors also reviewed a sample of the radiological results for soil, surface water, sediment/silt, and vegetation to verify compliance with license requirements and procedures.

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The inspectors reviewed selected entries from the PIRCS to verify that environmental-related conditions were promptly identified and entered into the program. The inspectors reviewed selected PIRCS records to verify the licensee performed the required level of investigation and resolved the conditions consistent with the requirements of Chapter 9 of the license application.

b. Conclusion

No violations of more than minor significance were identified. C. Facility Support

1. Resident Inspection Program – Post-Maintenance Testing (Inspection Procedure

88135.19)

a. Inspection Scope

The inspectors reviewed records for a sample of post-maintenance tests (PMTs) to verify that procedures and test activities confirmed the operability and functional capability of safety systems and components (SSCs) following the described maintenance. The inspectors reviewed the licensee’s completed test procedures for select PMTs 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 reviewed test data to verify that test results adequately demonstrated restoration of the affected safety function(s). The inspectors conducted field observations to verify that PMT activities were conducted in accordance with applicable work order instructions or licensee procedural requirements. Furthermore, the inspectors reviewed PIRCS entries to verify that problems associated with PMTs were identified and entered into the system for resolution. The safety-related equipment (SRE) tests selected for review were N000XCRITDETSYS and N303X600CMAXONS.

b. Conclusion

No violations of more than minor significance were identified.

2. Resident Inspection Program – Surveillance Testing (Inspection Procedure 88135.22)

a. Inspection Scope The inspectors reviewed completed test data for the surveillance tests of risk-significant and/or safety-related systems listed below to verify that the tests were consistent with the ISA, licensee commitments, and licensee procedures. The inspectors 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 reviewed operator qualifications to assure that staff were qualified in the test areas. The SRE tests selected for review were N333MONITR4RAFF and N333XXXXTIT2P22.

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b. Conclusion

No violations of more than minor significance were identified.

3. Resident Inspection Program – Problem Identification Resolution and Correction System

Review (Inspection Procedure 88135)

a. Inspection Scope

The inspectors reviewed the implementation of licensee corrective actions through the PIRCS to ensure that items adverse to safety were being identified and tracked to closure in accordance with the license application and program procedures. The inspectors routinely reviewed the results of daily PIRCS screening committee meetings to evaluate site management’s response and assignment of corrective actions or investigations to various issues. The inspectors also performed daily screenings of items entered in the PIRCS to identify repetitive equipment failures or specific human performance issues adverse to safety for follow-up. The inspectors reviewed PIRCS entries that occurred during the inspection period to determine whether the licensee prioritized the issues commensurate with their safety significance. Additionally, the inspectors verified whether the licensee was implementing measures to prevent recurrence in accordance with the license application.

b. Conclusion

No violations of more than minor significance were identified.

4. Resident Inspection Program – Emergency Preparedness Drill (Inspection Procedure 88135)

a. Inspection Scope

On June 10, 2020, the inspectors observed an emergency evacuation drill to verify that facility staff could evacuate and be accounted for during a serious emergency in accordance with the Emergency Plan. The inspectors also reviewed pre-drill training materials to determine if they followed guidance given by associated implementing procedures. The following training guidance was reviewed: JUNETBOX-20, June Toolbox Criticality Emergency Procedure Review

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 Personnel and Activities

a. Inspection Scope During the inspection period, the inspectors reviewed actions performed by security and material control and accounting (MC&A) personnel to verify the activities were consistent with applicable license, procedure, and regulatory requirements.

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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.

E. Exit Meetings

The inspection scope and results were presented to Mr. John A. Stewart, President of Nuclear Fuel Services, Inc. and members of his staff at exit meetings conducted on May 6, 2020 and July 9, 2020. Proprietary information was discussed, but not included in this report.

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SUPPLEMENTAL INFORMATION

Attachment

1. KEY POINTS OF CONTACT

Name Title S. Barron Program Manager, Emergency Preparedness T. Blankenship Senior Specialist, Transportation Waste Management N. Brown Unit Manager, Nuclear Criticality Safety J. Buckles Fire Protection Specialist T. Cloyd Fire Protection Specialist J. Coleman Fire Protection Specialist D. Coulter Health Physicist, Programmatic J. Faddis Environmental Unit Manager S. Gizzie Unit Manager, Integrated Safety Analysis and Fire Protection C. Lewis Engineer 4, Nuclear Criticality and Safety S. McKee Shipping Unit Manager, Transportation Waste Management A. Morie Licensing Manager R. Rice Manager, Radiation Protection E. Senter Principal Technical Specialist, Integrated Safety Analysis and

Fire Protection R. Shackleford Section Manager, Nuclear Safety & Licensing J. Stewart President, Nuclear Fuel Services

2. LIST OF ITEMS OPENED, CLOSED AND DISCUSSED None

3. INSPECTION PROCEDURES USED 88135 Resident Inspection Program for Category I Fuel Cycle Facilities

88135.02 Resident Inspection Program Plant Status Activities 88135.04 Resident Inspection Program Operational Safety 88135.05 Resident Inspection Program Fire Protection 88135.19 Post Maintenance Testing 88135.22 Surveillance Testing 88030 Radioactive Waste Processing Handling, Storage, and Transportation 88035 Radioactive Waste Processing, Handling, Storage, and Transportation 88045 Effluent Control and Environmental Protection

4. DOCUMENTS REVIEWED

Records: 2018 NFS Triennial Radiation Protection Program Evaluation 2020 First Quarter 24-Hour Sewer Composite Sample Analyses and Erwin Utilities Industrial

Report A-1122, Surveillance of the Nuclear Fuel Services Waste Certification Program, dated

March 10, 2020 Air Sampler 322 Calibration Record, dated May 08, 2019 Air Sampler 324 Calibration Record, dated May 08, 2019 ALARA Goals for 2020 Annual Stack Velocity Profile and Flow Rate Measurement Results - 2019

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Banner Spring Flow Meter Calibration Record, dated March 26, 2020 Biannual Effluent Monitoring Report, January – June 2019, dated August 26, 2019 Biannual Effluent Monitoring Report, July – December 2019, dated February 14, 2020 Energy Solutions – 0318-05-0210, Uniform Low-Level Radioactive Waste Manifest, dated

February 25, 2020 Fourth Quarter 2019 Occupational ALARA Report Fourth Quarter Management Assessment 2019, dated February 10, 2020 HP Audit of the Radiation Protection Program First Quarter 2020 Individual Qualifications for Ortiz, Mark, dated May 05, 2020 Instrument Calibration Records Investigation 28434, 55 Gallon Drums, dated December 11, 2019 Investigation 28692, Versa-Pac Loading, dated February 27, 2020 NNSS Shipment – NFL20006, Uniform Low-Level Radioactive Waste Manifest, dated

February 13, 2020 NNSS Waste Acceptance Criteria Specific Elements QA Audit QA-19-22,

dated November 6, 2019 Personnel Contamination Event Report (LOA-HS-20-002) Radiation Technician Exams Radiation Warning Signs Inspection Form Safety and Safeguards Review Council Meeting Minutes Second Quarter Management Assessment 2019, dated September 10, 2019 STM-19-002, TWM Quality Improvement (CAP) Assessment, dated April 10, 2019 Third Quarter Management Assessment 2019, dated October 30, 2019 TRWM Waste Packaging Training Records, dated April 23, 2020 WCS Shipment – XC-019903-20002, Uniform Low-Level Radioactive Waste Manifest, dated

February 6, 2020 WST-TRWM Staff Training Records, dated April 23, 2020 Procedures: NFS-GH-28, Personnel Monitoring, Rev. 15 NFS-GH-38, Identification and Handling of Potentially Hazardous Waste, Rev. 7,

dated May 23, 2017 NFS-GH-40, Gaseous Effluent Action Points, Rev. 09, October 30, 2017 NFS-GH-A-12, Radiation Technician Training Procedure, Rev. 12

NFS-HS-A-27, Routine Estimation of Offsite Dose from Radioactive Gaseous Effluents, Revision 11, November 27, 2017

NFS-HS-A-54, Effluent Control & Environmental Monitoring Action Levels and MDC Requirements, Rev. 15, June 5, 2019

NFS-HS-A-78, Field Measurements of Effluent Stack/Duct Velocities, Rev. 9, dated February 15, 2018

NFS-HS-A-82, Routine Estimation of Offsite Dose from Ambient Radiation NFS-HS-B-09, Dosimetry Use and Exchange, Rev. 17 NFS-HS-B-10, Routine Air and Stack Sampler Calibration, Rev. 15, dated May 1, 2019 NFS-HS-B-16, Routine Sampling of Sanitary Sewer, Rev. 35, dated January 06, 2020 NFS-HS-B-18, Collection and Analysis of NFS Stack Samples, Rev. 27, dated May 01, 2019 NFS-HS-B-20, Routine Sampling of Environmental Media, Rev. 25, dated July 17, 2017 NFS-HS-B-31, Performing Survey Releases, Rev. 13 NFS-HS-B-35, Daily Personnel Monitor Source and Response Verification, Rev. 18 NFS-HS-B-38, Performing Nasal and Saliva Surveys, Rev. 6 NFS-HS-B-39, Radioactive Material Receipt and Shipping Surveys, Rev. 27,

dated April 9, 2018

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NFS-HS-B-41, Routine Groundwater Sampling Procedure, Rev. 30, March 5, 2018 NFS-HS-B-49, Posting Radiological Areas and Inspecting Radiation, Rev. 11 NFS-HS-B-62, Surveying Laundered Protective Clothing, Rev. 7 NFS-HS-B-65, Operation of the Ludlum 2929 and 3030 Scalers, Rev. 7 NFS-HS-B-73, Analysis of Environmental Liquid and Environmental Air Samples, Rev. 16,

dated September 02, 2019 NFS-HS-B-77, Operation of the Tennelec Counting System, Rev. 6 NFS-HS-B-80, Contamination Surveys, Rev. 13 NFS-HS-B-97, Sampling of Banner Spring Branch and North West Storm Water Ditch,

Revision 2, April 3, 2017 NFS-HS-B-98, Air Sampler Calibration and Maintenance, Rev. 3 NFS-HS-B-98, Air Sampler Calibration and Maintenance, Rev. 03, dated April 02, 2018 NFS-HS-E-02, Rev. 047 Emergency Criticality Evacuation effective dated August 1, 2019 NFS-WST-021, NFS Waste Characterization Implementation Plan, Rev. 11,

dated January 6, 2020 NFS-WST-022, Waste Packaging Selection, Procurement, and Inspection, Rev. 15,

dated August 9, 2018 NFS-WST-031, Waste Packaging for Disposal Inside MAA, Rev. 17, dated

September 19, 2018 NFS-WST-036, Handling and Packaging of the Versa-Pac, Rev. 4, dated May 04, 2020 SOP-299, Waste Water Treatment Facility, Revision 022, dated August 13, 2017 SOP-335-F, Handling of WWTF Waste, Rev. 11, dated April 10, 2017 SOP-335-J, Waste Packaging for NNSS Disposal, Rev. 13, dated May 9, 2017 Other Documents:

Organizational Chart for the Environmental Safety Department, 2020 Organizational Chart for Transportation & Waste Management, dated April 2, 2020 SSRC-20200029 for SOP 335-J SSRC-WO2020020 for SOP 335-F T&WM Shipping Unit Manger Salaried Job Description, August 29, 2019 Problem, Identification, Resolution, and Correction System (PIRCS) Documents Reviewed: 67028, 75352, 76439, 76573, 77761, 77828, 77838, 78334, 78650, 78749, 78765, 78839, 78879, 78990, 79056, 79171, 79177, 79196, 79235, 79241, 79244, 79248, 79277, 79278, 79284, 79442, 79472, 79526, 79584, 79629, 79655, 79666, 79726, 79842, 79845, PIRCS Written as a Result of the Inspections: None