ML20184A282

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Framatome Inc., - NRC Integrated Inspection Report 701257/2020001 and 701257/2020-002
ML20184A282
Person / Time
Site: Framatome ANP Richland
Issue date: 07/02/2020
From: Suzanne Dennis
NRC/RGN-II
To: Land R
Framatome
References
IR 2020001, IR 2020002
Download: ML20184A282 (14)


Text

July 02, 2020 Dr. Ronald J. Land Site Manager Framatome Inc.

2101 Horn Rapids Road Richland, WA 99354-0130

SUBJECT:

FRAMATOME INC. - NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORTS 70-1257/2020-001 and 70-1257/2020-002

Dear Dr. Land:

This letter refers to the Nuclear Regulatory Commission (NRC) inspection oversight activities conducted from January 01 through June 30, 2020, for the Framatome Inc., facility in Richland, WA. 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 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 NRC rescheduled an inspection, originally scheduled for the week of March 23, 2020, to the week of July 23, 2020 (still subject to public health emergency conditions). This inspection was the only inspection originally scheduled during January - March of calendar year (CY) 2020. During the first and second quarters regional inspectors were, and will continue to be, in frequent communication with your facility to discuss regulatory compliance and other concerns.

For the second quarter of CY 2020, NRC staff discussed and implemented alternative inspection methods, techniques, and approaches. As a result, the NRC conducted modified (or partial) inspections by way of computer and telephone during the week of June 1, 2020, in the performance area of radiological controls. Those aspects of the inspection procedures that could be performed offsite are the subject of this quarterly inspection report. A subsequent, onsite inspection will be conducted at a later date for those aspects that require an onsite visit.

The enclosed report presents the results of the modified (or partial) inspections. 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. Within the area of radiological controls, regional inspectors reviewed procedures and representative records remotely and conducted telephonic interviews with site personnel.

The results of the inspections were discussed with you and members of your staff at an exit meeting held on June 04, 2020.

R. Land 2 Based on the results of these modified inspections, the NRC has determined that no violations of more than minor significance were identified.

The NRC will continue evaluating the guidelines and recommendations from federal, state, and local authorities, along with the conditions of your facility, to determine when to resume normal inspection activities. In the interim, the NRC plans to continue to conduct a combination of remote and onsite inspections 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 (10 CFR) 2.390 of the NRC's "Rules of Practice and Procedure," a copy of this letter and its enclosure, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Documents Access and Management System (ADAMS), which is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html If you have any questions, please contact Richard Gibson at 404-997-4718, or via email Richard.Gibson@nrc.gov.

Sincerely,

/RA/

Suzanne K. Dennis, Acting Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 70-1257 License No. SNM-1227

Enclosure:

NRC Inspection Reports 70-1257/2020-001 and 70-1257/2020-002 w/

Attachment:

Supplemental Information cc: Distribution via LISTSERV

ML20184A282 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI\PB2 RII:DFFI\PB2 RII:DFFI\PB1 RII:DFFI\PB2 RII:DFFI\PB2 RII:DFFI\PB2 NAME G. Goff R. Gibson P. Startz S. Dennis DATE 6/29/2020 6/29/2020 6/29/2020 7/2/2020 E-MAIL COPY? YES NO YES NO YES NO YES NO U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70-1257 License No.: SNM-1227 Report Nos.: 70-1257/2020-001 and 70-1257/2020-002 EPID Nos.: I-2020-001-0071 and I-2020-002-0046 Licensee: Framatome Inc.

Facility: Richland Facility Location: Richland, Washington Dates: January 1 through June 30, 2020 Inspectors: R. Gibson, Senior Project Inspector (A.2)

G. Goff, Project Inspector (A.1)

P. Startz, Project Inspector (A.3)

Approved by: Suzanne Dennis, Acting Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure

EXECUTIVE

SUMMARY

FRAMATOME INC.

NRC Integrated Inspection Reports 70-1257/2020-001 and 70-1257/2020-002 January 1 through June 30, 2020 An inspection was conducted remotely by regional inspectors in the performance area of radiological controls. The inspectors performed a selective examination of licensee activities that were accomplished by interviews and discussions with licensee personnel and a review of facility document.

Radiological Controls

  • No violations of more than minor significance were identified related to Radiation Protection. (Paragraph A.1)
  • No violations of more than minor significance were identified related to Waste Management. (Paragraph A.2)
  • No violations of more than minor significance were identified related to Environmental Protection. (Paragraph A.3)

Attachment:

Key Points of Contact List of Items Opened, Closed, and Discussed Inspection Procedures Used Documents Reviewed 2

REPORT DETAILS Summary of Plant Status The Framatome facility converts uranium hexafluoride (UF6) into uranium dioxide (UO2) for the fabrication of low-enriched fuel assemblies used in commercial light water reactors.

During the inspection period, normal production activities were ongoing.

A. Radiological Controls

1. Radiation Protection (Inspection Procedure 88030)
a. Inspection Scope The inspectors reviewed the radiation protection program as part of a remote inspection to verify that the licensees performance in administering the program, monitoring exposures, and implementation of controls was in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 20 and Chapter 4 of the license requirements.

The inspectors reviewed the latest As Low As Reasonably Achievable (ALARA) report, the most recent ALARA committee meeting minutes, and interviewed the radiation protection (RP) manager and radiation safety officer (RSO) to verify that evaluation of doses to personnel, dose trends, and ALARA goals and metrics were being tracked as required by the license application. The inspectors also performed the above actions to verify the RP program was documented; reviewed, at least annually, for content; and implemented in accordance with 10 CFR 20.1101(a) and .1101(c). The inspectors reviewed records to also verify that the dose limits were routinely monitored, that doses were within the regulatory limits established in 10 CFR 20.1201, and that the goals and requirements established in ALARA program were being implemented.

The inspectors interviewed licensee management and technicians to verify that the radiation protection programs function and responsibilities remained independent from operations and other business lines. The inspectors reviewed the latest organizational chart and noted there were no changes in the RP program management since the last RP inspection.

The inspectors reviewed procedures (see the attachment) to verify any safety-significant changes were made in accordance with the licensees procedural revision process. The inspectors interviewed the RP manager and RSO to verify that changes were reviewed and approved by the appropriate management. The inspectors also reviewed the procedures to verify parameters, such as limits and set points, were consistent with the license application.

The inspectors reviewed training material and interviewed health and safety technicians (HSTs) to verify that RP workers received training at the frequency specified in the license application and as required by 10 CFR 19.12. Specifically, the inspectors reviewed training related to the handling of radioactive materials, response to contamination/exposure, and usage of survey instruments. The inspectors also reviewed radiation protection training documents to verify that the training frequency and content was in accordance with 10 CFR 20, Subpart H and the license application.

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The inspectors interviewed RP technicians to determine if workers understood radiation protection hazards and procedural changes related to their jobs and if they had any hesitancy raising radiation safety concerns with management.

The inspectors reviewed recent calibration procedures for survey meters to verify that the licensee had a system to identify instruments and equipment used for quantitative radiation measurements and when they are due for periodic calibration or functional testing as per 10 CFR 20.1501(c). The inspectors also verified that all calibrations are required to be performed to NIST traceable standards. The inspectors also reviewed survey procedures to verify that the licensee had an established mechanism in place to perform scheduled radiation and contamination surveys to meet the requirements of 10 CFR 20.1501(a) and (b).

The inspectors reviewed audit reports related to areas of the facility, specific equipment, specific postings, and HST performance of routine job functions. Inspectors noted that any deficiency or opportunity for improvement was placed into the corrective actions program. The inspectors reviewed HP-related corrective action items to determine whether the licensee was identifying radiation protection issues at a conservative threshold and entering them into the corrective action program as required by the license application.

Inspectors verified that the maximum Total Effective Dose Equivalent (TEDE) results for 2019 was less than the regulatory limit of 5 rem per year. The inspectors reviewed dose records to verify that these records were being maintained in accordance with 10 CFR 20.2106.

b. Conclusion

No violations of more than minor significance were identified.

2. Radioactive Waste Processing, Handling, Storage, and Transportation (Inspection Procedure 88035)
a. Inspection Scope The inspectors reviewed the licensees performance in the processing, handling, storage and transportation of radioactive waste as part of a remote inspection 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.

The inspectors evaluated whether the licensee had established, maintained, and implemented procedures in accordance with license requirements and quality assurance programs. Additionally, the inspectors reviewed changes to the licensees organizational structure since the last Waste Management inspection to verify that the changes complied with the license application.

The inspectors reviewed procedures, referenced in the attachment, related to radioactive waste handling, characterization, receipt, shipping, and packaging to verify that the procedures were clearly written, and that delineated responsibilities related to radioactive waste management were implemented in accordance with Chapters 2, 4, 5, and 11 of the license application.

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The inspectors also reviewed the changes to the licensees procedures to verify that safety significant changes were made in compliance with the license application and that procedures were reviewed and revised at the required frequency.

The inspectors performed interviews with operations and engineering staff about combustible waste collection and processing combustible radioactive waste through the incinerator to recover recycled uranium residues. The inspectors also interviewed an engineer about the storage of licensed material on racks located in Warehouse 7, Storage Rack A1. These operations included items relied on for safety (IROFS), for the storage rack, and for the secondary chamber of the incinerator. The inspectors verified that operators interviewed were familiar with their responsibilities in accordance with the procedures.

The inspectors reviewed aspects of the quality assurance program for radioactive waste management in order to verify that the licensee was performing the required audits per 10 CFR 20, Appendix G. The inspectors reviewed audit reports and corrective action items to verify that findings from these audits were entered in the licensees corrective action program as required by Chapter 11 of the license application.

The inspectors reviewed aspects of the licensees program for classifying low-level radioactive waste and mixed waste in order to verify compliance with 10 CFR 61.55 and 10 CFR 20 Appendix G as well as the procedures for classifying waste and records related to waste. The inspectors reviewed the licensees procedures for labeling and tracking radioactive waste shipments in order to verify that they were in accordance with license requirements.

The inspectors reviewed the training for radiological waste workers in order to verify that the training addressed the various aspects radiological waste handling, packaging, storage, and preparation for shipment. The inspectors reviewed the training records for select radiological waste workers in order to verify that they were qualified and maintained their training current as required by the license application.

b. Conclusion

No violations of more than minor significance were identified.

3. Environmental Protection (Inspection Procedure 88045)
a. Inspection Scope The inspectors evaluated whether the licensee had established and maintained an environmental protection program in accordance with Chapter 9, Environmental Protection, of the license application as part of a remote inspection, and to verify that the program was being implemented in accordance with the license and federal regulations.

The inspectors reviewed the quality assurance program for effluent control and environmental protection to verify that the licensee was performing the required audits.

The inspectors reviewed the findings from these audits to verify entry into the corrective actions program for resolution per the license application.

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The inspectors reviewed events identified in the licensees corrective action program to verify that deviations from procedures and unforeseen process changes were documented, investigated, and resolved.

The inspectors reviewed procedures and supporting data to evaluate the performance of tasks to verify that the procedures were clearly written, and adequately delineated responsibilities related to effluent controls. The inspectors interviewed Health and Safety (H&S) personnel knowledgeable with performing effluent controls and environmental protection activities in order to verify that the technicians were familiar with their responsibilities as they performed their tasks in accordance with procedures.

The inspectors also reviewed training records to verify that personnel received required training and retraining at the specified frequency in accordance with the license application.

The inspectors reviewed the semi-annual effluent reports for the calendar year 2019 to evaluate compliance with effluent requirements of 10 CFR 70.59. The inspectors reviewed the calculation of the maximum possible dose to a member of the public from the normal gaseous effluent release at the licensees fence line, based on review of these same records, to verify compliance with the regulatory limits specified in 10 CFR 20.1101 (d).

The inspectors reviewed a sample of instrument calibration activities used on effluent stacks to verify that effluent stack sampling equipment was being maintained within the required settings and frequency in accordance with the procedures (see the attachment). The inspectors interviewed personnel concerning the functionality and periodic collection of sample media from ambient air stations to verify compliance with the procedures.

The inspectors also conducted interviews regarding the liquid effluent treatment processes and sanitary sewerage waste streams. Inspectors reviewed data logs concerning collection of samples from the lift station to verify that equipment was maintained and operated in accordance with the requirements of the procedure and 10 CFR 20.2003. The inspectors also reviewed the effluent monitoring results (for gaseous, liquid, and sewer) to verify that the values specified in Appendix B of 10 CFR Part 20 were not exceeded.

The inspectors reviewed records for soil, forage, and effluent sludge sample collection results and discussed the results with licensee staff to verify that the levels were within established limits. The inspectors interviewed the environmental engineer and staff to verify their knowledge regarding effluent systems operation and sampling requirements and activities conducted in accordance with approved procedures.

The inspectors reviewed the public dose assessment and determined that the average annual effluent concentrations released in 2019 did not exceed the values specified in Appendix B of 10 CFR Part 20. The total dose to a member of the public likely to receive the highest dose from the licensed operation 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 results were in compliance with the ALARA constraint required by 10 CFR 20.1101(d).

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b. Conclusion

No violations of more than minor significance were identified.

B. Exit Meeting The inspection scope and results were presented to members of the licensees staff at various meetings throughout the inspection period and were summarized on Thursday, June 4, 2020, to R. Land and staff. Proprietary information was discussed but not included in the report.

Executive Summary Statement

  • No violations of more than minor significance were identified in the area of Radiation Protection. (Section A.1)
  • Radioactive waste activities were performed in accordance with regulatory requirements and procedures. (Section A.2)
  • Effluent Control and Environmental Protection program was implemented in accordance with the license application and regulatory requirements. (Paragraph A.3) 7

SUPPLEMENTAL INFORMATION

1. KEY POINTS OF CONTACT Name Title G. Antonioli Sr. Waste Handler W. Done Engineer, Waste Management J. Ferritto Health & Safety Technician C. Gooldy Radiation Protection Manager J. Jones Sr. Waste Handler C. Manning Licensing Manager R. McGlothlen Engineer, Waste Management M. Nelson Health & Safety Technician J. Perryman Plant Support and Waste V. Sakach Radiation Safety Officer T. Tate ESH&L Manager R. Wheeler Health & Safety Technician
2. LIST OF ITEMS OPENED, CLOSED, OR DISCUSSED None
3. INSPECTION PROCEDURES USED 88030 Radiation Protection (Appendix A) 88035 Radioactive Waste Processing, Handling, Storage, and Transportation 88045 Effluent Control and Environmental Protection
4. DOCUMENTS REVIEWED Records:

1723-01-F08, Skills Evaluation, UO2 Decontamination and Volume Reduction Facility, HRR-WST-000019, Revision 004 2018 Annual Groundwater Report - E06-09-011, Version 1.0 2019 Annual Groundwater Report - E06-09-012, Version 1.0 20191209 SKILLS-HRR-RAD-HST-100001 20191209 SKILLS-HRR-RAD-HST-100002 20191209 OJT-HRR-RAD-HST-100003 AID-10094, Reference 101 Dwyer Flowmeters for Room Air Samples, Version 6.0 AID-40382 A, Summary of Waste Packaging Limits and Dispositions, Version 4.0 ALARA Committee Meeting - May 19, 2020 Annual Radioactive Waste Handling Audit Dose Tracking Report 1Q 2020 Final Dose Tracking Report 2Q 2020 Drawing EMF-608,610, Sheet 4, Horn Rapids Road Site Arrangement Sanitary Drain, Revision 016, June 2017 Drawing EMF-608,610, Sheet 6, Horn Rapids Road Site Chemical Drain Arrangement, Revision 4, May 2001 E05-01-021, The ALARA Report - January 1, 2018 - December 31, 2018, Version 1.0 Attachment

E23-01-201802, Inspection report - Radiation Protection & Environmental Protection -

Richland HRR site - 15th to 18th May 2018 F10094, Required Reporting of Effluents 10 CFR 70.59, letter YRS:20:003 dated 2/26/2019 regarding releases July 1, 2019 to December 31, 2019 and letter YRS 19:009 dated 10/28/2019 regarding January 1, 2019 to June 30, 2019 FRM-40665A, LLRW Waste for Ecology (Control Form), Version 3.0 FRM-40665B, Special Waste HEPA Filters for Energy Solutions (Control Form),

Version 3.0 FRM-40665D, Special Waste Filter Cake for Energy Solutions (Control Form),

Version 4.0 FRM-40665E, Special Waste Nitric for Energy Solutions (Control Form), Version 2.0 FRM-40665F, Special Waste Ammonium Nitrate/Ammonia Fluoride for Energy Solutions (Control Form), Version 2.0 FRM-40665H, Special Waste MERF Material for Energy Solutions (Control Form),

Version 5.0 Hand Foot Monitor 17522.80 (Maintenance Work Order 13444615), 01/06/2020 HRR-WST-000013-007, UO2 Decontamination and Volume Reduction Facility Exam Monitor PCM Mens Change Room 17521-75 (Maintenance Work Order 13442278),

01/03/2020 New Employee HST Proficiency Exam (no date)

On the Job Training Instructor Curriculum as of 05/18/2020 Quarterly LLRW Container Storage Inspection Form Plant Effluent Monitoring Station Final Report, daily reports for 1/1/2020 through 4/30/2020 POTW Richland Sludge Data, October 2016 to December 2019 (spreadsheet)

Quarterly LLRW Container Storage Inspection Form, June 4, 2019 Resubmission of Annual Dose Report for 2018, Stack radioactive air missions and resultant dose to the public in support of WAC 246-247-080(3), 11/18/2019 Semi-Annual Environmental Monitoring Audit Summary (Audit No. EMA-51),

July 8, 2019 Semi-Annual Environmental Monitoring Audit Summary (Audit No. EMA-52),

March 17, 2020 Skills Evaluation UO2 Decontamination and Volume Reduction Facility Form (Check List)

SWI-40383 A, Assay System Initialization, Version 6.0 SWI-40383 B, Assaying Drums and HEPA Filters, Version 4.0 SWI-50323 A, SWUR Incinerator Cleanout Inspection, Version 1.0 Uranium Waste Report, Uranium Sample Results, LIMS #520418, 7/18/2019 Waste Training Curricula Reports, Waste Segregation and Packaging, Summary Report Training Status, June 3, 2020 Work Order 13408620, IRM02080 Flowmeter Calibration Checks, 3/9/2019 Work Order 13412585, CO80I007 Flowmeter FT-1541, Calibrate Mini-mag Flowmeter L2IX-NHO3, Functional Location: RICH-CONV-ADU-L2-IX, 4/20//2019 Work Order 13423425, C163P104 IX Feed Interlock Checks, IROFS Ammonia Recovery System, 7/16/2019 Work Order 13423427, C163P102-0001, Sample Sand Filter, IROFS Filter Sand 36X60 IX V-680, 7/25/2019 Work Order 13423456, C163P106 IX Feed TK-714, IROFS IX Feed Polyethylene TK-714, 7/23/2019 Work Order 13427081, IRM02080 Flowmeter Calibration Checks, completed 8/23/2019 2

Work Order 13427394, IRM4300 Flowmeter Calibration Checks, Waste Effluent Monitoring, 8/28/2019 Work Order 13434083, PM003843 Sampler Waste 10/19/2019 Work Order 13434445, C163P004, Proportional Sampler, IROFS Ammonia Recovery System, 10/18/2019 Work Order 13440977, IRM02080 Flowmeter Calibration Checks, (Air Sampler Flowmeters), 12/24/2019 Procedures:

ADM-00003, HST Training & Certification Procedure, Version 7.0 AID-10094, Reference 101 Dwyer flowmeters for Room Air Samples, Version 6.0 AID 10408, Reference 1082 Canberra Sirius-2AB, Hand, Cuff and Foot Contamination Monitor, Version 4.1 AID 10409, Reference, 1083 Canberra Argos- 4AB & 5AB, Personnel Contamination Monitors, Version 5.1 AID-40382A, Summary of Waste Packaging Limits and Dispositions, Version 4.0 AID-40382B, Mauser USA, LLC, Version 2.0 AID-40382C, Meyers Container, Version 1.0 AID-40382D, Uline Plastic Drums, Version 1.0 E05-03-001, Radiation Protection Standard, Version 3.0 E05-12-201903, -201904, -201905, -2019-06, -2019-07, -2019-08, -2019-09, -2019-10, -

2019-11, -2019-12; Surveillance Audit Report (HP-1), Version 1.0 E05-12-202001, -202002, -202003 ; Surveillance Audit Report (HP-1), Version 1.0 E05-13-202001, Radiation Records Audit Report (HP-2), Version 1.0 E05-23-201901, Sources Audit Report (HP-12), Version 1.0 E05-24-202001, Training Audit Report (HP-13), Version 1.0 E05-26-202001, Instrument Audit Report (HP-15), Version 1.0 E06-07-010, Dangerous Waste Training Plan for the Framatome Richland Facility, Version 5.1 E12-03-008, Radiation Protection Records, Version 11.2 E12-03-010, Radiation Protection Program Audit (HP-4), Version 8.0 E12-03-11, ALARA Program Audit, Version 7.1 E12-03-12, Airborne Activity Audit (HP-6), Version 10.0 E12-03-17, RWP/RJP Audit (HP-11), Version 8.0 E12-03-18, Sealed Sources Audit (HP-12), Version 9.0 E12-03-19, Radiological Safety Training Audit (HP-13), Version 9.0 E12-03-21, Radiological Laboratory Instrument Audit (HP-15), Version 10.0 MCP-30107, Radiation Job Permit, Version 6.0 MCP-30108, ALARA Program, Version 9.0 SOP-40025, Routine Facility Radiation Level Surveys, Version 7.1 SOP-40031, Waste Effluent Monitoring & Sampling, Version 17.0 SOP-40032, Radioactive Gaseous Effluent Sampling, Version 25.0 SOP-40033, Environmental Dosimetry, Version 12.0 SOP-40034, Richland WWTF Sludge Sampling, Version 9.0 SOP-40035, Forage Sampling, Version 8.0 SOP-40038, Sampling of Oxides of Nitrogen from Uranium Dissolver Systems, Version 4.4 SOP-40039, Richland WWTF Sludge Sampling, Version 8.0 SOP-40042, Routine Fenceline/Building Exterior Radiation Level Surveys, Version 8.0 SOP-40043, Ambient Air Sampling for Radioactivity, Version 9.0 SOP-40046, Area/Facility Removable Contamination Control, Version 10.0 3

SOP-40059, Radiation Job Permit, Version 9.0 SOP-40358, SWUR Incinerator Cleanout, Version 14.0 SOP-40386, Special/Mixed/Hazardous/Dangerous Waste Handling and Storage, Version 12.0 SOP-40389, Preparing Low Level Radioactive Waste (LLRW), Special, Mixed and Hazardous Material Shipments, Version 8.0 SOP-40487, Contaminated Waste Generator Requirements, Version 18.0 SOP-41064, Air Sample Counting SOP-41070, Stack Sample Counting Using the EHS&L Database, Version 4.0 SWI-40383D, MERF Assay Operation, Version 2.1 SWI-40487A, Waste Generator Disposal Pathways, Version 6.0 SWI-50323A, SWUR Incinerator Cleanout Inspection, Version 1.0 Condition Reports Written as a Result of the Inspection:

None Condition Reports Reviewed:

CR-2019-490, CR-2019-735, CR-2019-756, CR-2019-1219, CR-2019-2958, CR-2019-3485, CR-2019-3802, CR-2019-3869, CR-2020-0114, CR-2020-0260, CR-2020-0333, CR-2020-0773, CR-2020-0999, CR-2020-1034 Other Documents:

Audit, E05-12-202002, Surveillance Audit Report, Version 1.0 Audit, E05-18-202001, Environmental Audit Report (HP-7), Version 1.0 Audit, E06-07-009, Compliance Groundwater Monitoring Plan, Version 2.0 Audit, E06-07-010, Dangerous Waste Training Plan for the Framatome Richland Facility, Version 5.1 EHS&L Organizational Chart (March 2020)

FRM-00003 A, Health and Safety Technician 1 Trainee Record, Version 1.0 FRM-00003 B, Health and Safety Technician 2A Record, Version 1.0 FRM-00003 C, Health and Safety Technician 2B Record, Version 1.0 FRM-00003 D, Health and Safety Technician 2C Record, Version 1.0 How Are We Doing at HRR?

HST Position Posting Organizational Chart for EHS&L, including RP Department Organization Chart Plant Support and Waste RDM-20-006, Annual Radioactive Waste Handling Audit, April 30, 2020 4