ML21022A127

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Westinghouse Columbia Fuel Fabrication Facility, U.S. Nuclear Regulatory Commission Inspection Report Number 0701151/2020004
ML21022A127
Person / Time
Site: Westinghouse
Issue date: 01/21/2021
From: Eric Michel
NRC/RGN-II/DFFI/FFB2
To: Annacone M
Westinghouse
References
IR 2020004
Download: ML21022A127 (14)


Text

January 21, 2021 Mr. Mike Annacone Vice President, Columbia Fuel Operations and Manager, Columbia Plant Westinghouse Electric Company 5801 Bluff Road Hopkins, SC 29061

SUBJECT:

WESTINGHOUSE ELECTRIC COMPANY - U. S. NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT NUMBER 70-1151/2020-004

Dear Mr. Annacone:

This letter refers to the inspections conducted from October 1, 2020, through December 31, 2020, at the Westinghouse Columbia Fuel Fabrication Facility in Hopkins, SC. During that period, the U. S. Nuclear Regulatory Commission (NRC) completed routine, on-site and remote inspections as permitted by conditions that existed at that time involving the novel coronavirus disease (COVID-19).

The enclosed report presents the results of the inspections, which were conducted through a combination of document reviews, interviews, 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 and Facility Support. The findings were discussed with you and members of your staff at an exit meeting held on December 3, 2020.

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

Additionally, the inspectors implemented measures during the inspection period to support the determination of reasonable assurance that the public and the environment will be adequately protected from the hazards related to the operation of your facility. These compensatory measures included activities such as supplemental reviews of licensee-submitted reports (e.g.

effluent reports, plant modification reports, and changes to the Integrated Safety Analysis Summary) and increased communications with your staff to discuss the status of plant operations. The compensatory measures did not constitute direct inspection and were intended to address the impact of the COVID-19 public health emergency on the agencys routine oversight program, particularly on the continuous engagement with your facility via periodic site visits and in-person interactions. These proactive actions were taken to obtain additional insights into the safe operation of the facility during the COVID-19 public health emergency.

M. Annacone 2 The NRC will continue evaluating the guidelines and recommendations from federal and state authorities, along with the conditions of your facility, to determine how to best conduct inspections until normality can be achieved. In the interim, the NRC will maintain compensatory measures and 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 NRCs Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary, information so that it can be made available to the Public without redaction.

Should you have any questions concerning these inspections, please contact Tom Vukovinsky, Senior Project Inspector of my staff at 404-997-4622.

Sincerely,

/RA/

Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 70-1151 License No. SNM-1107

Enclosure:

NRC Inspection Report 70-1151/2020-004 w/Supplemental Information cc:

LISTSERV

ML21022A127 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI/PB2 RII:DFFI/PB1 RII: DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB2 NAME T. Vukovinsky J. Rivera K. Womack D. Edwards E. Michel DATE 01/14/2021 01/11/2021 01/11/2021 01/11/2021 1/21/2021 U. S. NUCLEAR REGULATORY COMMISSION REGION II INSPECTION REPORT Docket No.: 70-1151 License No.: SNM-1107 Report No.: 70-1151/2020-004 Enterprise Identifier: I-2020-004-0038 Licensee: Westinghouse Electric Company Facility: Columbia Fuel Fabrication Facility Location: Hopkins, SC 29061 Dates: October 1 through December 31, 2020 Inspectors: J. Rivera, Senior Fuel Facility Inspector (Section B.1)

D. Edwards, Fuel Facility Inspector (Section A.2)

K. Womack, Fuel Facility Inspector (Section A.1)

Approved by: E. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure

EXECUTIVE

SUMMARY

Westinghouse Electric Company Columbia Fuel Fabrication Facility U.S. NRC Integrated Inspection Report 70-1151/2020-004 October 1 - December 31, 2020 Regional inspectors from the U.S. Nuclear Regulatory Commission (NRC), Region II Office, conducted inspections at the Westinghouse Columbia Fuel Fabrication Facility in the areas of safety operations and facility support. 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. No violations of more than minor significance were identified.

Safety Operations

  • No violations of more than minor significance were identified in the Operational Safety area.

(Section A.1)

  • No violations of more than minor significance were identified in the Nuclear Criticality Safety (NCS) area. (Section A.2)

Facility Support

  • No violations of more than minor significance were identified related to the Permanent Plant Modifications (PPM) area (Section B.1)

Attachment Supplemental Information 2

REPORT DETAILS Summary of Plant Status The Westinghouse Facility converts uranium hexafluoride (UF6) into uranium dioxide using a wet conversion process and fabricated fuel assemblies for use in commercial nuclear power reactors. During the inspection period, normal production activities were ongoing.

A. Safety Operations

1. Operational Safety (Inspection Procedure 88020)
a. Inspection Scope The inspectors evaluated the operational safety of the facility in order to verify that the licensee operates the plant safely and in accordance with Title 10 Code of Federal Regulations (CFR) Part 70, the license, and the License Application. The inspectors interviewed area managers, operators, and reviewed records associated with Integrated Safety Analysis (ISA) summary areas 16, 18, and 19 to verify compliance with the License Application. The inspectors reviewed license requirements, quantitative risk assessments, and operating procedures associated with the afore-mentioned areas to verify that the requirements for the process areas were consistent within the licensees documents. The inspectors evaluated 11 Item Relied On For Safety (IROFS) to verify that they were being implemented as described in the ISA and that the licensee was in compliance with the License Application.

The inspectors performed field walkdowns of multiple process areas with approved procedures to verify the field configurations were maintained in accordance with the conduct of operations requirements of the Chapter 3 of the License Application. The inspectors walked down multiple areas of the plant to confirm the IROFS associated with storage of uranium bearing material (ISA-16), laboratory systems (ISA-18), and hoods and containment systems (ISA-19) were present and capable of performing their intended safety functions as required by 10 CFR 70.62. The inspectors evaluated engineered safety controls to verify they were capable of preventing or mitigating associated accident scenarios. The inspectors interviewed operators and area supervisors to verify that they were knowledgeable of administrative controls and limits associated with IROFS.

The inspectors reviewed procedures associated with 11 IROFS to verify that required actions for IROFS, as identified in the ISA Summary, were correctly transcribed into written operating procedures. The inspectors reviewed completed surveillances and functional test instructions of select IROFS to verify management measures were implemented as required by the Chapter 3, Operations, of the License Application and the ISA.

The inspectors reviewed a sample of entries from the licensees corrective action program (CAP) created since the last operational safety inspection to verify that conditions adverse to operational safety were identified, documented, and corrected, as required by Section 3.8 of the License Application.

b. Conclusion

No violations of more than minor significance were identified.

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2. Nuclear Criticality Safety (Inspection Procedure 88015)
a. Inspection Scope Criticality Analysis The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety (NCS) Program to verify compliance with selected portions of 10 CFR 70, including 70.61(d) and 70.62(d), Chapter 6 of the facilitys License Application, and applicable procedures.

The inspectors reviewed selected criticality safety evaluations (CSEs), and NCS calculation notes, to verify that they were consistent with the commitments in the License Application. These commitments included the commitment to the Double Contingency Principle, to assure subcriticality under normal and credible abnormal conditions with the use of subcritical margin, and to have properly reviewed and approved CSEs in place prior to conducting new or changed operations. The inspectors reviewed the selected CSEs to determine whether calculations were performed within their validated areas of applicability and consistent with the validation report. The CSEs were selected based on factors such as whether or not they were new and/or revised and the last time they were reviewed by the NRC. The CSEs reviewed are listed in Section 4 of the attachment to this report.

The inspectors reviewed the licensees generation of accident sequences to determine whether the CSEs 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 that the licensee determined to be not credible to determine whether the bases for incredibility were consistent with the commitments, definitions, and methodologies in the License Application. Additionally, the inspectors reviewed selected accident sequences designated as not credible to determine whether the bases for incredibility relied on any items which should be identified as items relied on for safety (IROFS) as required by 10 CFR Part 70.61. This review was conducted focusing on the areas of ISA-16 Storage of Uranium Bearing Material, ISA-18 Laboratories Systems, and ISA-19 Hoods and Containment Systems.

The inspectors reviewed the validation report to verify that changes made since the last NCS inspection, if any, were consistent with Chapter 6 of the License Application.

Criticality Implementation The inspectors performed walk-downs of the laboratories listed below to determine whether existing plant configuration and operations were covered by, and consistent with, the process description and safety basis in the selected NCSEs.

  • VIPER/Product Engineering (PE) Development Lab
  • Analytical Services Laboratory
  • Metallurgical Laboratory
  • Chemical Development Laboratory 4
  • Health Physics Laboratory
  • IFBA Chemical Laboratory
  • Chemical Process Engineering Laboratory The inspectors reviewed NCS engineers and laboratory staff to verify engineered controls were established in NCSEs were included and being implemented as specified.

The engineered controls reviewed included mass control, and spacing. The inspectors reviewed operating procedures and postings to verify that selected administrative controls established in the CSEs were also included. The inspectors interviewed laboratory staff, operators and engineers to verify that administrative actions established in the CSEs were understood and implemented as specified.

The inspectors reviewed the integrated safety analysis (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 walk-down of the conversion scrap cage area to determine whether NCS staff routinely assessed field compliance with established NCS controls, interacted with operators, and promptly entered issues identified during the walkdown into the licensees corrective action program (CAP) as required by Section 5.1 of RA-316, NCS Facility Walkthrough Assessments. Additionally, the inspectors interviewed NCS management and reviewed procedures and schedules to verify that the qualified NCS engineers adequately prepared for and performed these walkthroughs such that the complete set of fissile material processing areas were assessed quarterly for higher risk areas and semiannually for lower risk areas in accordance with procedure RA-316, NCS Facility Walkthrough Assessments, the associated checklist, and Section 6.1.9 of the License Application.

Criticality Programmatic Oversight The inspectors reviewed the selected NCSEs, listed in Section 4 of the attachment, to verify that they were performed in accordance with NCS program procedures and received appropriate independent review and approval.

The inspectors reviewed document RAF-106-1-00017, EHS Audit for the Nuclear Criticality Safety Program and EHS-AUDIT-20-6, Revision 0, dated November 19, 2020; and interviewed the NCS Engineering manager to verify that the audit of the NCS program was conducted at a frequency consistent with Section 6.1.9 of the License Application and with appropriate thoroughness.

Criticality Incident Response and Corrective Action The inspectors reviewed various aspects of the criticality accident alarm system (CAAS) to determine whether the CAAS features met the applicable regulatory requirements in 10 CFR 70.24, and license commitments in the Section 6.1.8 of the License Application.

The documents reviewed included PM20558, SS4582-3-40684, SI-Safety, Crit Horn Sound Check-52 Week, dated October 22, 2020 and CN-CRI-20-002, Supplemental CAAS Coverage Calculation for Miscellaneous Plant Activities and Operations, Revision 0, dated May 28, 2020.

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The inspectors interviewed the Emergency Preparedness Manager, Nuclear Criticality Safety Engineering Manager, and a NCS engineer to determine whether the licensee maintained NCS related emergency response capability consistent with the emergency plan and procedures. The inspectors conducted interviews to verify that qualified NCS staff was readily available to advise the licensee in an emergency. The inspectors reviewed emergency procedures to determine whether procedures specified personnel evacuate to accountability points in the event of a CAAS alarm, whether evacuation routes and accountability points were designed to minimize the potential for exposing evacuating personnel to radiation, whether NCS-related evacuation drills were conducted consistent with license commitments and SEP-005, Evacuation, Emergency Shelter, Accountability and General Response, Revision 12.

The inspectors reviewed selected NCS-related CAP entries to verify that conditions adverse to safety were promptly identified and entered into the CAP, that they received the required level of investigation, and that they were closed out consistent with license commitments and procedures. Additionally, the inspectors reviewed the selected CAP entries to assess whether the licensee followed regulatory requirements and procedures with regards to reporting plant conditions to the NRC. The CAP entries reviewed included are listed in Section 4 of the attachment.

b. Conclusion

No violations of more than minor significance were identified.

B. Facility Support

1. Permanent Plant Modifications - Annual Review (Inspection Procedure 88070)
a. Inspection Scope The inspectors reviewed the licensees configuration management program to determine whether the licensee established a system to evaluate, implement, and track changes to the facility and activities of personnel in accordance with Title 10 of the Code of Federal Regulations, Section 70.72 (10 CFR 70.72). The inspectors review included configuration management documents and interviews with licensee supervisors, engineers, and operators to verify the program was implemented in accordance with the applicable regulatory requirements. The inspectors also reviewed whether the licensee had a system in place to maintain records of facility changes in accordance with 10 CFR 70.72(f).

The inspectors selected a sample of plant changes based on interviews with licensee staff and the list of plant changes submitted to the NRC on January 6, 2020 (ADAMS Accession Number ML20006F639). The plant changes selected for review are listed in Section 4 of the Attachment to this inspection report.

For the selected plant changes, the inspectors reviewed configuration control packages and supporting documents to verify these contained the following: the technical basis for the change, the impact of the change on safety and health or on the control of licensed material, modifications to operating procedures and necessary training prior to operations, authorization requirements for the change, the impacts of the change to the ISA or other safety program information developed in accordance with 10 CFR 70.62.

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The inspectors also reviewed samples of on-site documents to verify that affected documentation was updated promptly prior to implementing the change as required by 10 CFR 70.72(e). For the selected facility changes that were not submitted to the NRC for approval, the inspectors reviewed configuration control packages to verify these included a written evaluation providing the bases for the determination that the change did not require NRC approval prior to implementation.

The inspectors performed walk-downs of process areas associated with the selected plant changes and interviewed plant staff directly involved with the changes to verify the modifications were consistent with the approved configuration management documents.

The inspectors also reviewed a sample of management measures applied to the selected plant changes to verify compliance with the License Application, Chapter 3, Conduct of Operations and 10 CFR 70.62. Particularly, the inspectors focused on the management measures for IROFS ADUSCRA-122 through -126 and ADUSCRA-128 associated with configuration control package CCF-19428 in the scrap uranium processing area to verify these IROFS were present as described in the configuration management documents.

The inspectors interviewed licensing staff and reviewed the latest version of the License Application to verify that recent changes to license commitments, if any, were evaluated in accordance with the conditions of the license and that NRC prior approval was requested when necessary.

The plant changes selected for review did not involve new facilities or processes requiring a license amendment, therefore the inspectors review did not include whether the licensee addressed the baseline design criteria and concept of defense-in-depth stipulated in 10 CFR 70.64.

b. Conclusion

No violations of more than minor significance were identified.

C. Exit Meetings The inspection scope and results were presented to A. Pope, Organizational Effectiveness Director and other members of the licensees staff on December 3, 2020.

Proprietary information was discussed, but not included in this report.

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SUPPLEMENTAL INFORMATION

1. KEY POINTS OF CONTACT Name Title A. Brown URRS Senior Engineer D. Brown Principle Quality Engineer M. Brown URRS Manager S. Carver Emergency Preparedness Manager P. Donnelly Principle Licensing Engineer T. Graves Lead Conversion Engineer B. Jeffcoat Principle Engineer E. Malek Regulatory Affairs Manager A. Miller EH&S Operations Manager C. Miller Nuclear Criticality Safety Engineering Manager A. Penny Chemical Lab Manager T. Smith Technician 2 K. Zayan Conversion Work Week Manager
2. LIST OF ITEMS OPENED, CLOSED AND DISCUSSED None
3. INSPECTION PROCEDURES USED 88015 Nuclear Criticality Safety 88020 Operational Safety 88070 Permanent Plant Modifications - Annual
4. DOCUMENTS REVIEWED Records:

CF-81-999, Scrap Cage: Safety Significant Interlocks Verification Form, August 8, 2019 CN-CRI-20-002, Supplemental CAAS Coverage Calculation for Miscellaneous Plant Activities and Operations, Revision. 0, dated May 28, 2020 DWG No 301F01PI01, Solvent Extraction I, Sheet 3, Rev. 24 DWG No 313F01PI01, Piping Flow Diagram - Scrubbers S-2A & S-2B, Rev. C1 DWG No 333F05PI04, Liquid Waste Storage Columns, Rev. 1 DWG No 333F05PI05, Scrap Uranium Recovery Equipment Instrument Air Distribution, Rev.

1 DWG No 333F05PI07, Vent Pot (V-1037), Rev. 2 EHS-AUDIT-20-1, Regulatory Component Audit for Configuration Management; Maintenance; Procedures, Training and Qualification; Human Performance; Record Keeping and Reporting; QA, dated March 19, 2020 EHS-AUDIT-20-3, Formal Compliance Audit Report, dated April 16, 2020 IR-2019-8716, Conversion Safety Clock Reset: Elevated Airborne Samples at Blu-M Oven While Employee was Working, May 18, 2019 LTR-EHS-20-55, 2020 Regulatory Component Audit Status and Schedule Update, June 19, 2020 OM30010, PE Lab Storage Rack Verification OM82199, Verification of Oxidation Hood Drainage OM83236, Verification of Oxidation Hood Drainage OM85261, Verification of Oxidation Hood Drainage Attachment

OM86202, Verification of Oxidation Hood Drainage OM91007, Chemical Area Floor Inspection PM20327, Chemical Area Floor Inspection PM30010, FACTS Loop Pressure Relief Valve PSV5820A PM30034, Product Engineering Development Lab Piping Inspection PM30035, Product Engineering Development Lab Roof Inspection PM81057, Moisture Sampler Sensor Test / Replacement PSE Doc-00051262, Preliminary Process Hazard Analysis of Accident Tolerant Fuel (ATF)

Project, Rev. 13 PSE Doc-0005300, CCF 18322, EnCore Accident Tolerant Fuel - Lead Test Rods Program, Independent Technical Review, Phase 1, Rev. 0 PSE Doc-0005301, CCF 18322, EnCore Accident Tolerant Fuel - Lead Test Rods Program, Independent Technical Review, Phase 2, Rev. 0 PSE Doc-0005302, CCF 18322, EnCore Accident Tolerant Fuel - Lead Test Rods Program, Independent Technical Review, Phase 3, Rev. 0 RAF-314-1, Criticality Safety Evaluation Implementation Plan, CSE for the Scrap Uranium Recovery Equipment, CSE-11-H, CSE Rev. 1 RAF-316-1, (Facility Walkthrough Assessments) various Procedures:

CF-81-236, Auto-Sampler Safety Significant Control Verification Form, Rev. 7, dated 09 18 MCP-202037, Criticality Alarm Calibration and SSC Verification (AC-Plant-1-01), Rev. 32, dated September 25, 2018 MCP-2003445, GA-7M Criticality Alarm Calibration and SSC Verification (AC-Plant-1-01),

Rev. 0, dated September 25, 2018 QCI-310905, Inspection of IROFS - Common Containers and Control/Release of UCON, Rev. 20, dated 01/23/20 RA-104, Regulatory Review of Configuration Change Authorization, Rev. 31 RA-106, Regulatory Component Audits at the CFFF, Rev. 40, dated 08-20-20 RA-107, Corrective Action Process for Regulatory Events, Rev. 27, dated March 14, 2019 RA-108, Safety Significant Controls, Rev. 41, dated 11-02-20 RA-312, NCS Calc Note Generation, Format, and Content Requirement, Rev. 8, dated November 19, 2015 RA-313, Criticality Safety Evaluations (CSEs), Rev. 15, dated November 19, 2015 RA-314, Implementation of Criticality Safety Evaluations, Rev. 9, dated November 2, 2020 RA-316, NCS Facility Walkthrough Assessments, Rev. 12, dated October 17, 2019 SEP-005, Evacuation, Emergency Shelter, Accountability and General Response, Rev. 12, dated February 20, 2020 SEPF-009-11, Command Check Sheet- Criticality Alarm Response, Rev. 7, dated March 14, 2019 TA-500, Columbia Manufacturing Plant Configuration Control, Rev. 39, dated 04-02-20 Configuration Control Packages/Forms (CCFs)

CCF-15526, Install New Scrap Uranium Recovery Equipment in Scrap Cage, October 13, 2015 CCF-15580, Integrate Current Model for SOLX V1087 and V1487 Automatic Valve Solenoids, November 9, 2015 CCF-18140, FACTS Loop Circulation Pump Controls Modification, April 16, 2018 CCF-18204, VIPER Internals Drawing for Gosgen 15x15 German Fuel VIPER Test, May 21, 2018 2

CCF-18237, Install New Design Pellet Tray Detailing Funnel on Lines 1, 2, 3 and 5, June 8, 2018 CCF-18322, EnCore Accident Tolerant Fuel - Lead Test Rods Program, August 7, 2018 CCF-18356, Muffle Furnace 3 Replacement in the Chem Lab Uranium Room, September 12, 2018 CCF-19071, Substitution Filter for Flanders 16"x20"x2" Pre-filter, February 11, 2019 CCF-19097, Viper Loop Flow Meter Calibration Test Set-up, March 6, 2019 CCF-19098, New Liquid Penetrant Inspection (LPI) Station, March 6, 2019 CCF-19103, Viper Loop Heater Element (HX-5801A) Replacement, March 12, 2019 CCF-19245, Add Face Velocity Monitor for Conv. Scrap Cage "Blue M" #1 Hood, June 5, 2019 CCF-19246, Add Face Velocity Monitor for Conv. Scrap Cage "Blue M" #2 Hood, June 5, 2019 CCF-19247, Increase Pipe Diameter on V-03 Drain from 1" to 2", June 5, 2019 CCF-19253, Add a Spring Close Actuated Valve on Air Supply to the Blowdowns for S-2A/2B Bag Filters, June 12, 2019 CCF-19428, Replacing Perchloroethylene and Kerosene in SOLX with Dodecane, November 13, 2019 Items Relied on For Safety (IROFS) Reviewed:

BAESCRP-138 l FLOOR-119 l IFBASCRP-138 l PELSCRP-138 l PETLAB-110 l PETLAB-111 l PETLAB-119 l PETLAB-120 l PROCUR-902 l STORAGE-CON-109 l URSSCRP-178 Criticality Safety Evaluations (CSE):

CSE-11-H, Criticality Safety Evaluation (CSE) for the Scrap Uranium Recovery Equipment, Rev. 3 CSE-16-F, Criticality Safety Evaluation for Floor Storage for Special Nuclear Material, Rev. 8 CSE-18-A, Criticality Safety Evaluation for the VIPER/Product Engineering (PE)

Development Lab, Rev. 12 CSE-18-B, Criticality Safety Evaluation for the Analytical Services Laboratory, Rev. 21 CSE-18-C, Criticality Safety Evaluation for the Metallurgical Laboratory, Rev. 2 CSE-18-D, Criticality Safety Evaluation for the Chemical Development Laboratory, Rev. 2 CSE-18-E, Criticality Safety Evaluation for the Health Physics Laboratory, Rev. 1 CSE-18-F, Criticality Safety Evaluation for the IFBA Chemical Laboratory, Rev. 6 CSE-18-G, Criticality Safety Evaluation for the QC Lab Polypak Sampling Hood, Rev. 6 CSE-18-I, Criticality Safety Evaluation for the Chemical Process Engineering Laboratory, Rev. 0 CSE-19-A, Criticality Safety Evaluation for Oxidation Ovens and Hoods, Rev. 4 Condition Reports Reviewed Redbook 75535 IR-2019-14317, IR-2019-17861, IR-2020-124, IR-2020-3300, IR-2020-3637, IR-2020-4521, IR-2020-4637, IR-2020-12553, IR-2020-12556, IR-2020-12557, IR-2020-12558, IR-2020-13037, IR-2020-13387 Work Orders:

WO 853122, SI-Safety V1031B and V1031C Passive Overflow Verification, July 30, 2019 WO 853121, SI-Safety V1037 Vacuum Break and Passive Overflow, July 30, 2019 3

Other Documents:

ISA-16, Storage of Uranium Bearing Materials, Rev. 14, dated 1/22/2020 ISA-18, Laboratories Systems, Rev. 14, dated 1/21/2020 ISA-19, Hoods and Containment System, Rev. 15, dated 01/22/2020 JSA-EHS-0052, Criticality Accident Response, Rev. 1, dated May 21, 2015 LTR-EHS-20-55, 2020 Regulatory Component Audit Status and Schedule Update, dated June 19, 2020, RAF-106-1-00017, EHS Audit for the Nuclear Criticality Safety Program; EHS-AUDIT-20-6, Rev. 0, dated November 19, 2020 TRN-001-6, Alarms, Emergency Response, Fitness for Duty, Site Security and Threats, Rev. 6 TRN-155, HP Emergency Response Training, dated November 12, 2020 2020 Facility Walkthrough Assessment Schedule Site Emergency Plan for the Columbia Fuel Fabrication Facility, Rev. 20, dated January 20, 2020 4