ML21028A706

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Louisiana Energy Services, LLC (Les),Dba Urenco USA (UUSA)-Nuclear Regulatory Commission Integrated Inspection Report 70-3103/2020-004
ML21028A706
Person / Time
Site: 07003103
Issue date: 01/28/2021
From: Robert Williams
NRC/RGN-II/DFFI
To: Cowne S
URENCO USA
References
EN 54324 IR 2020004
Download: ML21028A706 (15)


Text

EN 54324 January 28, 2021 Stephen Cowne, Chief Nuclear Officer and Compliance Manager URENCO USA P.O. Box 1789 Eunice, NM 88231

SUBJECT:

LOUISIANA ENERGY SERVICES, LLC (LES), dba URENCO USA (UUSA) -

NUCLEAR REGULATORY COMMISSION INTEGRATED INSPECTION REPORT 70-3103/2020-004

Dear Mr. Cowne:

This letter refers to the inspections conducted by the U.S. Nuclear Regulatory Commission (NRC) from October 1, 2020 through December 31, 2020, at the URENCO USA (UUSA) facility located in Eunice, New Mexico. 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 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 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.

The enclosed report presents the results of the inspections, which were conducted through a combination of onsite and remote reviews. The inspectors reviewed activities as they relate to public health and safety, the common defense and security, and compliance with the Commissions rules and regulations, as well as the conditions of your license. The inspections covered the areas of operational safety, criticality safety, radiation protection, and plant modifications (annual). Within these areas, regional inspectors reviewed procedures and representative records remotely and conducted telephonic interviews with the site. In some instances, regional inspectors were able to conduct routine inspections onsite as originally planned. The results of this inspection were discussed with members of your staff at an exit meeting held on November 19, 2020.

S. Cowne 2 In calendar year 2020, due to the ongoing public health emergency from COVID-19, the NRC did not complete all planned onsite inspection activities for the Urenco USA facility. As a result, in calendar year 2021, some additional onsite inspections in the areas of plant modifications, environmental protection, material control and accounting, and emergency preparedness will be conducted. Based on the inspections conducted in calendar year 2020, as well as feedback from recent Licensee Performance Reviews, effectiveness of the NRC-approved Corrective Action Program (CAP), the risk significance of the incomplete inspections, and the fact that remote inspections were performed for each inspection area, the NRC concluded that the licensee continues to operate in a manner that provides reasonable assurance of adequate protection of public health and safety.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 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 Agency-wide Document 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 this report, please contact Brannen Adkins of my staff at 404-997-4620.

Sincerely,

/RA/

Robert E. Williams Jr., Chief Projects Branch 1 Division of Fuel Facility Inspection Docket No. 70-3103 License No. SNM-2010

Enclosure:

NRC Inspection Report 70-3103/2020-004 w/

Attachment:

Supplementary Information cc w/ encl: Distribution via LISTSERV

ML21028A706 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB1 RII:DFFI/PB1 NAME L. Cooke B. Adkins L. Pitts R. Williams DATE 1/12/2021 1/12/2021 1/20/2021 1/28/2021 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO U. S. NUCLEAR REGULATORY COMMISSION REGION II INSPECTION REPORT Docket No.: 70-3103 License No.: SNM-2010 Report No.: 70-3103/2020-004 Enterprise Identifier: I-2020-004-0045 Licensee: Louisiana Energy Services (LES), LLC Facility: URENCO USA (UUSA)

Location: Eunice, NM Dates: October 1 through December 31, 2020 Inspectors: T. Vukovinsky, Senior Fuel Facility Inspector (Section A.1)

T. Sippel, Fuel Facility Inspector (Section A.2)

R. Gibson, Senior Fuel Facility Inspector (Sections B.1)

M. Ruffin, Fuel Facility Inspector (Section C.1)

Approved by: R. Williams, Chief Projects Branch 1 Division of Fuel Facility Inspection Enclosure

EXECUTIVE

SUMMARY

Louisiana Energy Services, LLC (LES) dba URENCO USA (UUSA)

NRC Integrated Inspection Report 70-3103/2020-004 October 1 - December 31, 2020 Regional inspectors from the U.S. Nuclear Regulatory Commission (NRC), Region II Office, conducted remote and onsite inspections during normal shifts in the areas of safety operations, radiological controls, facility support and other areas. The inspectors observed safety-significant activities and equipment, walked down the facility, interviewed licensee personnel and reviewed facility records.

Safety Operations

  • No violations of more than minor significance were identified in the area of operational safety. (Section A.1)
  • No violations of more than minor significance were identified in the area of nuclear criticality safety. (Section A.2)

Radiological Controls

  • No violations of more than minor significance were identified in the area of radiation protection. (Section B.1)

Facility Support

  • No violations of more than minor significance were identified in the area of plant modifications (annual). (Section C.1)

Other Areas

  • The inspectors performed follow-up activities for EN 54324 involving the failure to close an autoclave pressure boundary valve (IROFS10). This failure represented an additional example of NCV 70-3103/2019-02, documented in inspection report LES IR 2019-004, and is not being documented individually. No additional violations of more than minor significance were identified and this item is considered closed. (Section D.1)

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 URENCO USA facility in Eunice, New Mexico enriches uranium hexafluoride (UF6) using gas centrifuge technology. During the inspection period, the licensee conducted routine plant operations.

A. Safety Operations

1. Operational Safety (IP 88020) - Remote Inspection
a. Inspection Scope The inspectors conducted a remote inspection and reviewed the operation of selected processes to verify compliance with the requirements of Title 10 of the Code of Federal Regulations, Part 70 (10 CFR 70) and the Safety Analysis Report (SAR), as incorporated by reference in Condition 10 of the materials license. The inspectors selected portions of the Decontamination Workshop Room, UF6 Feed System, and the Gaseous Effluent Vent System (GEVS) for an in-depth review. The inspectors main focus was to verify that the licensee implemented a safety program and applied appropriate management measures to items relied on for safety (IROFS) in accordance with the licensing basis of the facility.

Specifically, the inspectors reviewed the following: Decontamination Workshop operating procedures, GEVS operating procedures, and UF6 Feed System operating procedures to verify the following safety limits were incorporated into procedures as described in the Integrated Safety Analysis (ISA) Summary and Section 11.4 of the SAR. These reviews covered the following IROFS:

  • Decontamination Workshop IROFS: 54a/b, 56a/b, 57a/b, and 58a/b, which are criticality safety controls for the Liquid Effluent Collection and Transfer System (LECTS), Small Component Decontamination Train (SCDT), and Multi-functional Decontamination Train (MFDT).
  • GEVS IROFS: 24a/b/c/d, which are safety controls for the GEVS
  • UF6 Feed System IROFS: 4, 5, 53a/b, 62, 63, which are safety controls for the UF6 feed system.

The inspectors reviewed recent changes to the above procedures to verify that safety-significant changes were in compliance with the SAR requirements for procedural control. The inspectors also reviewed a sample of work orders from the above IROFS to verify that the completion of these safety controls was documented in accordance with the applicable implementing procedure.

The inspectors reviewed records regarding initial and continuing training programs to verify compliance with the requirements in Section 11.3 of the SAR. The inspectors reviewed a sample of technician qualification records to verify that the individuals were currently qualified on the IROFS assigned to them. The inspectors also reviewed recent changes to key management positions in the operations area to verify compliance with the position-specific requirements in Section 2.2 of the SAR.

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The inspectors reviewed a sample of CAP entries from the past 12 months to verify that safety-significant plant issues were identified for resolution and corrective actions were initiated in accordance with CAP procedures. The review of corrective actions included the implementation of compensatory measures for unavailable IROFS. Additionally, the inspectors reviewed a sample of audits and self-assessments in the operations area to verify that the licensee completed these at the required frequencies and significant findings were entered into the CAP in accordance with Section 11.5 of the SAR.

b. Conclusion

No violations of more than minor significance were identified.

2. Nuclear Criticality Safety (IP 88015) - Remote Inspection
a. Inspection Scope Criticality Analysis The inspectors conducted a remote inspection of selected aspects of the licensees nuclear criticality safety (NCS) program to verify compliance with Chapter 5 of the facilitys license application, applicable licensee procedures, and with selected portions of 10 CFR 70, including 70.61(d), 70.62(d).

The inspectors reviewed selected criticality safety analyses (CSAs), and associated supporting documentation, to verify that they were consistent with the commitments in the license application. These commitments included the Double Contingency Principle, assurance of subcriticality under normal and credible abnormal conditions with the use of subcritical margin, and selected technical practices and methodologies outlined in Section 5.1.2 of the license application. The inspectors reviewed the selected CSAs to determine whether calculations were performed within their validated area of applicability (AOA) and consistent with the validation report. The CSAs and ISA documentation reviewed are listed in section 4 of the attachment.

The inspectors reviewed the licensees generation of accident sequences to determine whether the CSAs systematically identified normal and credible abnormal conditions in accordance with the commitments and methodologies in the license application for the analysis of process upsets. The inspectors reviewed assumptions made for upset conditions to verify they were clearly described, appropriately conservative, and matched the calculation input files. This included the review of accident sequences that the licensee considered not credible to determine whether the basis for incredibility was consistent with the commitments, definitions, and methodologies in the license application. The inspectors also reviewed the protection and prevention scores assigned in the accident sequences to determine whether they were consistent with the license application and resulted in the scenario being highly unlikely. This review was conducted for various sub-systems of the GEVS. Specifically, the Pumped Extract GEVS (PXGEVS), the Local Extract GEVS (LXGEVS), and the Cylinder Receipt and Dispatch Building (CRDB) GEVS, as well as portions of the Solid Waste Collection System were reviewed.

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The inspectors reviewed changes to the licensees validation reports for MONK (NCS-REP-001-00) and MCNP6 (NCS-REP-002-03) to verify consistency with the technical practices and methodologies specified in the license application. For the MONK validation, the inspectors reviewed the benchmark experiment characteristics identified, the AOA, and the calculated bias to verify that the validation was consistent with sections 5.2.1.1 and 5.2.1.2 of the license application. For the MNCP validation the inspectors reviewed the benchmark experiment characteristics identified, the AOA, the methodology used to calculate the bias, and any extension to the AOA to verify that the validation was appropriate for accident conditions involving currently licensed activities and in accordance with license commitments.

Criticality Implementation The inspectors reviewed IROFS boundary definition documents and procedures to verify that selected administrative controls established in the CSAs were included. The inspectors reviewed the ISA summary and supporting ISA documentation to determine whether the controls identified in the ISA were supported by technical bases in the CSAs. The administrative controls reviewed included, IROFS58a and IROFS58b. The inspectors interviewed licensee engineers to verify that administrative actions established in the CSAs were understood.

Criticality Operational Oversight The inspectors reviewed a record of a recent NCS assessment of operations and interviewed NCS staff to determine whether licensee NCS staff routinely assessed field compliance with established NCS controls. Additionally, the inspectors interviewed NCS management and reviewed procedures to verify that the NCS staff performed the audit and assessments as required by section 11.5 of the license application. The records of NCS assessments reviewed included NCSAS-20-0011, Recycling - IROFS58a/b.

The inspectors reviewed selected sequences related to the accumulation of uranic material in the GEVS to verify that the licensee had established controls on long-term accumulations. Specifically, the inspectors interviewed licensee engineers concerning accident sequences and possible accumulation points in the GEVS, and reviewed records associated with recent filter change outs (e.g., WO 1000296615; Administrative Hold Form for RW-3-1000-18, Bulking Enriched Waste; Apparent Cause Evaluation for EV 138768) to verify that the licensee prevents or mitigates long-term accumulations.

The inspectors reviewed changes to the licensees process for determining the amount of uranium in used filters to verify that common-mode failure was addressed, and the licensees process accounted for uncertainties in the filter materials.

Criticality Programmatic Oversight The inspectors reviewed recently revised NCS program procedures (i.e., CR-3-1000-01, and CR-3-1000-03) to determine whether the licensee implemented license requirements and whether the NCS program was enacted in accordance with them. The inspectors interviewed the NCS program supervisor and reviewed records to determine whether NCS staff reviewed new and revised fissile material operations and procedures, including maintenance plans, consistent with licensee procedures.

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The inspectors reviewed the selected CSAs 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.

Criticality Incident Response and Corrective Action The inspectors reviewed selected NCS-related CAP entries to verify that anomalous conditions were promptly identified and entered into the CAP, were investigated, and were closed out consistent with license commitments and procedures. The inspectors reviewed the associated corrective actions to verify they were consistent with program procedures and appropriate to correct the condition. 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 EV137253, EV137747, EV138768, EV138792, EV139083; as well as the Apparent Cause Evaluation for EV 138768.

b. Conclusion

No violations of more than minor significance were identified.

B. Radiological Controls

1. Radiation Protection (IP 88030 Appendix A) - Onsite Inspection
a. Inspection Scope The inspectors evaluated selected aspects of the licensees Radiation Protection (RP) program as part of an onsite inspection to verify compliance with selected portions of 10 CFR Part 20, license requirements, and applicable procedures.

The inspectors reviewed the radiation protection program as part of a modified (remote) inspection in May 2020. The results from that inspection can be found in inspection report number 70-3103/2020-002 (ML20210M262). This inspection report addresses the onsite follow-up to the May inspection. The inspectors performed the onsite inspection to verify that the licensees performance in administering the program, monitoring exposures, and implementation of controls was in accordance with the requirements of their procedures.

The inspectors observed radiation protection technicians perform calibration and performance checks on hand & foot monitors and personal contamination monitors. The inspectors reviewed documentation of the calibration results to verify compliance with procedures. The inspectors also observed contamination surveys in areas of the CRDB to verify compliance with 10 CFR 20.1501(a) and procedures.

The inspectors reviewed advanced radiation worker training material and interviewed RP technicians 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 use of survey instruments, contamination controls, and posting for radioactive work permit (RWP) areas.

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The inspectors also reviewed radiation protection technician qualification cards to verify that the training frequency and content was in accordance with 10 CFR 20, 10 CFR Part 70 Subpart H and the license application. 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 in discussing radiation safety concerns with management.

The inspectors reviewed the procedure for RWPs to verify compliance with the licensee application. The inspectors reviewed completed RWPs to verify that all required information was included in the paperwork, as per the licensee application.

The inspectors toured the CRDB work and storage areas to verify that the licensee posted the areas in accordance with 10 CFR 20.1902 and 20.1903 and that radiological signs and postings accurately or conservatively reflected radiological conditions within the posted area. The inspectors also verified the licensee had posted the notices to workers, as per 10 CFR 19.11.

The inspectors walked down the equipment used for analyzing contamination smears to verify the equipment was within calibration. Throughout the walkdowns, the inspectors continually observed the calibration stickers on air flow meters, survey meters at step-off pads, personnel contamination monitors, and hand & foot monitors to verify that the equipment was within calibration as required by 10 CFR 20.1501(c).

The inspectors observed a Chemist Analyst performed the monthly flow checks of the fume hoods in the Chemistry Lab as part of the Focus Area Matrix, CL-2 to verify that the Anemometer used by the Chemist was within calibration.

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

C. Facility Support

1. Plant Modifications (annual) (IP 88070) - Remote Inspection
a. Inspection Scope The inspectors conducted a remote inspection and reviewed the licensees configuration management program to determine whether the licensee established an effective program capable of evaluating, implementing, and tracking modifications to facility processes in accordance with 10 CFR 70.72 and SAR Chapter 11.1, Configuration Management. The inspectors reviewed configuration management procedures and interviewed licensee senior managers and configuration management coordinators to verify the configuration management program was being implemented in accordance with the aforementioned requirements.

The inspectors reviewed the licensees configuration management program to verify it addressed preparation of plant modification design packages in accordance with Chapter 11.1 of the SAR and procedures EG-3-2100-01, Configuration Change, AD 1000-10, Change Process Management, and EG-3-4100-02, Plant Modifications.

Inspectors also verified the program had adequate provisions in place to prevent plant modifications from degrading performance capabilities of IROFS or other safety controls that were part of the safety design basis.

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The inspectors reviewed a selection of plant modification design packages implemented since the last plant modification inspection was conducted: 70.72-2019-004, 70.72-2019-070, 70.72-2019-096, 70.72-2019-103, 70.72-2019-114, 70.72-2019-139, 70.72-2019-140, 70.72-2019-158, and 70.72-2019-170. The inspectors reviewed these packages and interviewed licensee staff to verify the change packages were prepared, reviewed, and completed by the licensee in accordance with EG-3-2100-01. Specifically, the inspectors verified that the design packages 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, the necessary training prior to operations, the authorization requirements for the change, and the impacts of the change to the ISA or other safety program information developed in accordance with 10 CFR 70.62. The inspectors reviewed the change packages to verify the licensee identified applicable post-maintenance installation and testing requirements and performed them prior to returning the modified equipment and systems to service. The inspectors also evaluated the packages to verify that completed modifications were adequately reviewed prior to implementation and the responsible evaluators of the packages were qualified.

The inspectors also reviewed the aforementioned design packages to determine whether the licensee adequately evaluated the need for NRC pre-approval of select facility modifications during their 10 CFR 70.72 evaluations. The inspectors reviewed the training records of licensee personnel conducting the 10 CFR 70.72 evaluations to verify they were qualified to perform the evaluations in accordance with Attachment 2 of TQ-3-0100-13, Training and Qualification Guidelines.

The inspectors interviewed licensee staff to verify operators received any needed training on the procedural changes associated with modification 70.72-2019-004 prior to resuming operations. Specifically, the inspectors reviewed records to determine if operators were trained on the steps added to the liquid sampling system procedure, OP-3-0470-01, used in implementing IROFS28.

The inspectors reviewed procedures, drawings and other applicable documents associated with the aforementioned plant modification packages to verify the documents were updated promptly as required by 10 CFR 70.72(e). The inspectors also reviewed the licensees document retention policy to verify that the licensee maintained records of facility modifications, in accordance with 10 CFR 70.72(f).

The inspectors reviewed the most recent audit and assessment of the licensees configuration management program to verify the licensee identified issues and entered them into their CAP in accordance with section 11.1.9, Assessments, of the SAR. The inspectors also reviewed the licensees CAP to verify issues related to the preparation and installation of plant modifications were entered and addressed by the licensee with corrective actions in accordance with SAR Chapter 11.6, Incident Investigations and Corrective Action Process.

b. Conclusion

No violations of more than minor significance were identified.

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D. Other Areas

1. WER 2019-005-01 Open Autoclave Valve (EN 54324)
a. Inspection Scope The inspectors conducted a review of EN 54324, reported to the NRC on October 10, 2019. At that time, the licensee was made aware that on June 5, 2018, pressure isolation valve 1001-41-1A12 was found open when it should have been shut to maintain the IROFS10 pressure boundary on autoclave 1LS1. Prior to the event, on May 31st, 2018, the annual maintenance was performed on autoclave 1LS1. Then a homogenization cycle and UF6 sampling was performed June 1st through 5th on a 30B cylinder. The valve was found to be open during preparations for a subsequent homogenization and closed upon discovery.

b. Conclusion

Leaving the pressure isolation valve open represents an additional example of NCV 70-3103/2019-004-02 (ML19304B933) and is not being documented individually.

The licensee has taken corrective actions to prevent recurrence of the issue and no response is required. No additional violations of more than minor significance were identified and this item is considered closed.

C. 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 November 19, 2020 to Karen Fili, Managing Director UUSA and President and Chief Executive Officer LES. Proprietary information was discussed but not included in the report.

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SUPPLEMENTAL INFORMATION

1. KEY POINTS OF CONTACT Name Title T. Anderson Senior Radiation Protection Technician J. Barraza Chemist Analyst 2 A. Bixenman Licensing Specialist S. Cowne Chief Nuclear Officer T. Creed Radiation Protection Technician J. Lagabed Pump Rebuild/Recycling Supervisor B. Love Licensing Specialist J. Miller Chemistry Manager Q. Newell Programs Engineering Supervisor W. Padgett Licensing and Performance Assessment Manager A. Reidy ISA/NCS Consulting Engineer J. Rickman Licensing Specialist K. Slavings Radiation Protection Supervisor A. Spencer Chemist Analyst 3 X. Thomas Configuration Management Coordinator
2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Closed 70-3103/2019-005 WER Open Autoclave Valve (EN 54324)
3. INSPECTION PROCEDURES USED 88020 Operational Safety 88015 Nuclear Criticality Safety 88030 Radiation Protection (Appendix A) 88070 Plant Modifications
4. DOCUMENTS REVIEWED Records:

2019-A-05-007, Plant Modifications NQA-1 Audit, Rev. 0, dated June 10, 2019 70.72-2019-004, Rev. 0, dated January 23, 2019 70.72-2019-066, Rev. 1, dated April 6, 2020 70.72-2019-070, Rev. 0, dated March 20, 2019 70.72-2019-096, Rev. 0, dated April 19, 2019 70.72-2019-0103, Rev. 0, dated May 28, 2019 70.72-2019-114, Rev. 0, dated May 15, 2019 70.72-2019-139, Rev. 0, dated June 28, 2019 70.72-2019-140, Rev. 0, dated June 13, 2019 70.72-2019-158, Rev. 0, dated August 1, 2019 70.72-2019-170, Rev. 0, dated September 3, 2019 Attachment

70.72 Evaluation Process Exam, FCH-772-01 Exam, Rev. 1, dated October 13, 2020 Apparent Cause Evaluation (ACE) for EV138768, dated October 6, 2020 CC-EG-2018-0011, Rev. 0, dated April 19, 2019 CC-EG-2019-0004, Rev. 0, dated June 11, 2019 CC-MC-2018-0003, Addition of UF6LKR in 1001/1002 UF6 Handling Area, Rev. 0 CC-OP-2019-0008, Rev. 0, dated August 5, 2019 EG-3-4100-02, Plant Modifications, Rev. 23, dated August 10, 2020 EV 138945 Plant Modification Review, dated September 1, 2020 Event Review Board Meeting Minutes 2020-4 ISA-HAZ-0009, Gaseous Effluent Vent Systems (GEVS) HAZOP and Risk Determination Analysis, Rev. 0 ISA-MEM-0048, ISA Team Meeting Minutes for Gaseous Effluent Vent Systems (GEVS),

Rev. 8 MOD-18-0012C, Rev. 0, dated August 22, 2019 MOD-19-0032, Rev. 0, dated May 29, 2019 MOD-19-0036, Rev. 0, dated September 3, 2019 NCS-CSA-007, Nuclear Criticality Safety Analysis of GEVS Units in SBM, Rev. 5 NCS-CSA-013, Nuclear Criticality Safety Analysis of 55-Gallon Waste Drums, Rev. 5 NCS-CSA-022, Safe Spacing for SBD Waste Drums Involving Decontamination Activities, Rev. 1 NCS-REP-001-00, MONK8A Validation and Verification, Rev. 5, dated June 19, 2020 NCS-REP-002-03, URENCO USA (UUSA) MCNP6 Validation, dated June 5, 2020 NCSAS-20-0011, Recycling - IROFS58a/b, dated May 26, 2020 NCSI-20-0022, Solid Waste Collection Room (SWCR), dated July 22, 2020 MOD-19-0038B, Rev. B, dated February 27, 2020 NEF-BD-58a, Maintain Subcritical Mass in a Criticality Safety Approved Waste Container Storage Array, Rev. 2 Procedures:

AD-3-1000-10, Change Process Management, Rev. 14, dated July 1, 2019 CR-3-1000-01, Verification for Implementation of NCS Evaluations and Analyses, Rev. 8 CR-3-1000-03, NCS Weekly Walkthroughs and Periodic Assessments, Rev. 15 EG-3-2100-01, Configuration Change, Rev. 26, dated July 9, 2019 EG-3-4100-02, Plant Modifications, Rev. 23, dated August 24, 2020 MA-3-3400-04, IROFS4 Station Heaters High Temperature Trip - RTD Surveillance, Rev.

14 MA-3-3400-05, IROFS5 Station Heaters High Temperature Trip - TC Surveillance, Rev. 14 OP-3-0400-05, Process Services Corridor (PCS) Operations, Rev. 14 OP-3-0410-01, Feed System, Rev. 58 OP-3-0470-01, Liquid Sampling System, Rev. 31, dated March 11, 2019 OP-3-0660-01, Gaseous Effluent Vent System, Rev. 21 ORM-58a-58b, Maintain Subcritical Mass and Geometry in a Criticality Safety Approved Waste Container Storage Array, dated September 20, 2016 RW-3-1000-18, Bulking Enriched Waste, Rev. 7 RW-3-1000-09, Radioactive Waste Container Setup, Handling and Disposition, Rev. 18 RW-3-4000-01, Startup, Shutdown, and Operation of the SCDT, Rev. 10 RW-3-4000-02, Startup, Operation and Shutdown of the Multi-Functional Decontamination Train, Rev. 18 2

RW-3-5000-03, Emptying of Chemical and NaF Traps, Rev. 8 RW-3-5000-04, Heeled or Cleaned 30B and 48Y Cylinder Component Replacement and Testing, Rev. 7 TQ-3-0100-12, Training Guidelines, Rev. 3, dated July 27, 2020 TQ-3-0100-13, Training and Qualification Guidelines, Rev. 10, dated July 27, 2020 Condition Reports Written as a Result of the Inspection:

EV141126 Condition Reports Reviewed:

EV 133545, EV 134761, EV 134853, EV 134942, EV 136506, EV 136534, EV 136720, EV 137139, EV 137232, EV137253, EV 137331, EV 137487, EV137747, EV 137825, EV 138300, EV138768, EV138792, EV 138945 EV139083 Work Orders:

WO 1000296615, SBM1: 662 GEVS Filters Unsat, dated July 13, 2020 WO 1000414974, TOD: SBD Verification (SBDV-2019-0018)

WO 1000436602, Monthly MFDT OPS & IROFS 57A/B Samples, July 11, 2020 WO 1000436603, Monthly MFDT OPS & IROFS 57A/B Samples, August 17, 2020 WO 1000438792, Monthly MFDT OPS & IROFS 57A/B Samples, September 21, 2020 Other Documents:

10 CFR 70.72 Evaluator Exam, Rev. 1 70.72 Evaluator List November 2020 Administrative Hold Form, for RW-3-1000-18, Bulking Enriched Waste, Rev. 7 CA-3-100009-F-1, 2019 Shift Operations HPE Self-Assessment SA-2019-018, December 10, 2019 E-NCS-SS-QC, Nuclear Criticality Safety (NCS) Support Staff, dated January 22, 2020 EG-3-2100-01-F-1, Configuration Change Form for CC-OP-2020-0001, Feed to 30B IROFS, Rev. 0 EG-3-2100-01-F-1, Configuration Change Form for CC-OP-2020-0005, IROFS C21 Implementation Change, Rev. 0 EG-4-4100-06, Request for Engineering Support, Rev. 1, dated May 1, 2018 Quality Assurance Program Description, Rev. 4, dated November 26, 2018 RW-3-4000-01-F-01, IROFS54a for Uranium Waste Mass Determination by Conservative Estimate, Rev. 10, dated November 10, 12, and 16, 2020 Standing Orders, dated December 7, 2018 3